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Project Report for Material Handling for Pharmaceutical Company


Project Report for Material Handling for Pharmaceutical Company document sample

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									                                                                                                                  Project Status and Results
Ortho-McNeil                                           from the waste mixture. This bench-top oxidation
                                                       process will allow OMP to process LLMW in the
Pharmaceutical                                         same, secure laboratory where it is created, limit­
                                                       ing lab worker exposure and reducing the risk from
Company                                                releases during storage, transportation, and han­
FINAL PROJECT AGREEMENT SIGNED SEPTEMBER 22, 2000      dling. In addition, the process captures the radio-
                                                       active components of the waste rather than
Background                                             releasing it through the incineration process, which
                                                       makes these waste products amenable to recycling
The Project Sponsor: Ortho-McNeil Pharmaceu­           and reuse. This XL project would allow OMP to
tical (OMP) and the R.W. Johnson Pharmaceuti­          transition the treatment process from an initial test­
cal Research Institute (PRI), divisions of Johnson     ing phase to a long-term development phase, with
& Johnson, are jointly sponsoring this XL project.     the ultimate goal of providing this technology and
OMP manufactures and markets pharmaceutical            the permitting provision exclusion to similar gen­
products in several therapeutic categories, includ­    erators of small quantities of LLMW.
ing women’s health, central nervous system, in­
fectious disease, and wound healing. OMP’s             The Flexibility: Assuming OMP’s LLMW is a
research and development efforts are conducted         RCRA hazardous waste, the HTCO process meets
by PRI, a sister company. PRI develops and uses        RCRA’s definition of treatment, because the oxi­
radiolabeled compounds for the research and de­        dation destroys the organic components of the
velopment of pharmaceuticals/drugs. OMP is             samples. With few exceptions, under RCRA, a
headquartered in Raritan, New Jersey, and employs      process that is considered treatment typically trig­
more than 2,000 people. The company has manu­          gers a requirement to obtain a RCRA Treatment,
facturing operations in Raritan, New Jersey; Spring    Storage, and Disposal Facility (TSDF) permit.
House, Pennsylvania; and Manati and Dorado,            With this project, OMP will be able to treat small
Puerto Rico. This project is being conducted at        volumes of LLMW on-site with its HTCO process
the Spring House, Pennsylvania, site.                  without a RCRA TSDF permit. To encourage use
                                                       of the oxidation process, the OMP XL project ex­
The Experiment: OMP is testing a unique tech­          cludes the small volumes of LLMW created and
nology that treats a waste byproduct (consisting       treated using OMP’s HTOC process within a NRC-
of both organic and radioactive components) of its     licensed pharmaceutical research and development
pharmaceutical research and development. In or­        laboratory from RCRA’s regulatory definition of
der to meet the Food and Drug Administration’s         hazardous waste in 40 CFR§ 261.4(b). However,
requirements for studying the safety and efficacy      OMP’s LLMW remains a solid waste and subject
of new pharmaceuticals in the human body, PRI          to other RCRA authorities, including EPA’s author­
uses drugs labeled with radioisotopes, which en-       ity under RCRA Section 7003, which addresses
able the drugs’ bioabsorption and metabolism in        situations of “imminent and substantial endanger­
the body to be tracked with precision. As a result     ment to health or the environment.” The State of
of these studies, a waste mixture consisting of ra­    Pennsylvania Department of Environmental Pro­
dioactive material and an organic compound are         tection (PADEP) has been authorized to adminis­
produced. EPA regulates low-level mixed waste          ter and implement most of the hazardous waste
(LLMW) under the Resource Conservation and             program in lieu of EPA, including the “mixed
Recovery Act (RCRA), and the radioactive com­          waste” portion of the regulatory program.
ponent is regulated by the Nuclear Regulatory
Commission (NRC) as a low-level waste under the        Other Innovations: (1) Innovative Recovery of
Atomic Energy Act of 1954.                             Radioactive Waste. The HTCO process enables
                                                       the capture of the radioactive component of OMP’s
The high temperature catalytic oxidation (HTCO)        LLMW as a uniform, consistent waste stream that
process uses catalytic oxidation to destroy the haz­   is amenable to recovery and reuse. (2) Improved
ardous component and capture the radioactivity         Waste Handling and Safety. The OMP HTCO
Project Status and Results

                                   process is designed to handle all LLMW on-site in       Progress in Meeting Commitments
                                   the NRC-regulated, controlled laboratory environ­
                                                                                           (As of August 2001)
                                   ment in which it was generated, thereby further
                                   reducing the minimal potential for spills or releases   •	   EPA committed to propose and issue a site-
                                   during the on-site and off-site handling and trans­          specific rule, amending 40 CFR § 261.4, which
                                   portation. (3) Technology Transfer. If this project          applies to the OMP Spring House facility, al­
                                   is determined to be successful and this regulatory           lowing the facility to run its LLMW catalytic
                                   flexibility is adopted at a national level, the HTCO         oxidation process without obtaining a permit
                                   technology developed by OMP may be transfer-                 under RCRA.
                                   able to other organizations that generates or treats
                                   small amounts of mixed wastes, such as pharma­               –	 EPA published the Notice of Proposed
                                   ceutical companies, research institutions, and col­             Rulemaking in the Federal Register on July
                                   leges and universities. While testing its technology,           24, 2001, allowing for the site-specific
                                   OMP has decided not to patent the technology and                exclusion under RCRA that would enable
                                   has made it available to all interested parties. By             OMP to utilize the HTCO process to treat
                                   enabling OMP and other organizations to utilize                 LLMW on-site without a RCRA permit.
                                   this technology, the technology and its environ­
                                   mental and economical benefits may be made avail-       •	   PADEP committed to propose and issue a per­
                                   able to a much larger number of users.                       mit by rule as necessary under state law, 25
                                                                                                Pennsylvania Code 270a.60, or use other le­
                                   The Superior Environmental Performance:                      gal mechanisms to allow for the implementa­
                                   As a result of the expanded regulatory flexibility           tion of this XL project.
                                   granted through Project XL, OMP will be able to
                                                                                                –	 PADEP action by rule is pending publica­
                                   continue developing and testing the HTCO pro­
                                                                                                   tion of the final rule by EPA.
                                   cess. By treating LLMW on-site where it is gen­
                                   erated, the HTCO process results in several
                                                                                           •	   OMP committed to monitor and report bian­
                                   environmentally superior and transferable benefits
                                                                                                nually: (1) destruction removal efficiencies for
                                   as compared to presently available commercial
                                                                                                all organic components of the LLMW subject
                                   treatment and disposal alternatives involving in­
                                                                                                to treatment and (2) capture efficiencies for
                                   cineration or land disposal. For example, the ra­
                                                                                                the radioactive component of the LLMW sub­
                                   dioactive component of OMP’s LLMW is captured
                                                                                                ject to treatment.
                                   and made available for recovery and reuse, as op­
                                   posed to being lost during incineration. In addi­            –	 The 2000 Treatability Study Annual Re-
                                   tion, OMP will handle all LLMW on-site in the                   port for OMP’s Spring House facility, out-
                                   controlled laboratory environment in which it is                lining both the destruction removal
                                   generated, thereby limiting lab worker exposure                 efficiencies (DREs) and capture efficien­
                                   and reducing the minimal potential for spills or                cies for the radioactive component of
                                   releases during on-site and off-site handling and               LLMW subject to treatment, was submit­
                                   transportation. The use of the technology among                 ted to both PADEP and EPA on March 12,
                                   generators of small amounts of mixed wastes may                 2001. A second report is due September
                                   create a more economically favorable environment                15, 2001.
                                   for the commercial development of low-level waste
                                   recycling.                                                   –	 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
                                                                                                                Project Status and Results
         resulted in a DRE of approximately 99.998         –	 At this time, the Council’s activities have
         percent and a destruction removal recov­             been discontinued due to reorganization
         ery rate of 99.3 percent (+/– 3 percent).            and downsizing at the Rhom & Haas Cor­
         The second study resulted in a DRE of                poration, which heads the CAC.
         approximately 99.999 percent and a de­
         struction removal recovery rate of 96.8      •    OMP will host annual stakeholder meetings.
         percent (+/– 3 percent).
                                                           –	 OMP meets with the LGT quarterly, and
•	   OMP committed to make available its HTCO                 will hold larger, annual stakeholder meet­
     technology to all companies and institutions             ings as needed.
     that generate research-and-development quan­
     tities of LLMW.                                  Benefits for the Environment
     –	 OMP scientists continue working with a        •	   OMP’s processing of LLMW in the same labo­
        number of outside organizations, which in­         ratory in which it is created limits lab worker
        clude several international and domestic           exposure and enables the capture of radioac­
        corporations and the Lawrence Berkeley             tive components of the waste rather than los­
        National Laboratory, to develop the HTCO           ing it to the incineration process.
        technology, provide technical assistance,
        and share data.                               •	   To date, the OMP process is effectively cap­
                                                           turing the radioactive components of the waste
     –	 OMP presented information on the cata­             rather than losing it to the incineration pro­
        lytic oxidation treatment process to inter­        cess, making these waste products amenable
        ested parties at a symposium sponsored by          to recycling and reuse.
        the International Radioisotope Society in
        Mason, Ohio, on May 17, 2001. The sym­        Benefits for Stakeholders
        posium was co-organized and co-chaired
        by representatives from OMP. At the sym­      •	   OMP is sharing the environmentally benefi­
        posium, a representative from PRI re-              cial HTCO technology freely with other re-
        viewed current and developing treatment            search institutions and government agencies
        and disposal techniques, while focusing on         that also generate LLMW. Through extensive
        the HTCO process being utilized by PRI.            outreach to state and federal regulatory agen­
                                                           cies; the local community, local, state, and
•	   OMP committed to meet quarterly with the              national environmental groups; and other in­
     Lower Gwynedd Township (LGT) Industrial               terested parties, including government labo­
     Compact, an environmental group, to provide           ratories, domestic and international
     a regular forum for public discussion.                pharmaceutical research companies, and com­
                                                           mercial pharmaceutical manufacturers, OMP
     –	 OMP provides quarterly status reports at
                                                           has increased information sharing and learn­
        its regular meetings with the LGT Indus­
                                                           ing about the HTCO process and its potential
        trial Compact. In addition, the OMP site
                                                           environmental benefits. The company is col­
        manager attends monthly LGT supervisor
                                                           laborating with these outside organizations that
        meetings and is available to answer any
                                                           are working to develop the HTCO technology,
        questions raised by LGT or township citi­
                                                           providing technical assistance, guidance, and
        zens during these meetings.
                                                           data sharing.
•	   OMP committed to meet quarterly with mem­
     bers of the Community Advisory Council
     (CAC) sponsored by Rhom & Haas Corpora­
     tion to discuss environmental issues.

Project Status and Results

                                   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 × $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.

                                                                                                                Project Status and Results
Pennsylvania                                           formance of BMPs and this alternate strategy in
                                                       PADEP’s efforts to address AMD.
Department of
                                                       The Flexibility: An existing amendment to the
Environmental                                          Clean Water Act (CWA) provides remining opera­
                                                       tions an exception to the effluent limitation per­
Protection Coal                                        mitting requirements for iron, manganese, and pH
                                                       for preexisting discharges from abandoned mine
Remining and                                           lands mined before 1977. Instead, the project per­
                                                       mit may set site-specific numeric effluent limita­
Reclamation Project                                    tions representing best available technology on a
FINAL PROJECT AGREEMENT SIGNED SEPTEMBER 22, 2000      case-by-case basis for these parameters. These lim­
                                                       its are to be set so that the permit may not allow
Background                                             the levels of acidity, iron, and manganese dis­
                                                       charged to exceed preexisting levels from past
The Project Sponsor: The Pennsylvania Depart­          mining operations in the area before the remining
ment of Environmental Protection’s (PADEP’s)           activity begins. The remining operation must dem­
mission is to protect Pennsylvania’s air, land, and    onstrate the potential for improved water quality
water from pollution and to provide for the health     from the remining.
and safety of its citizens through a cleaner envi­
ronment. PADEP works as a partner with indi­           Under this project, PADEP will continue to apply
viduals, organizations, governments, and               current effluent limitations and permitting require­
businesses to prevent pollution and restore natural    ments to preexisting discharges that are comingled
resources. Six district mining offices within          with discharges from active remining operations.
PADEP oversee Pennsylvania’s mining program.           PADEP will require in-stream compliance moni­
Their duties include licensing, bonding, permitting,   toring rather than point-of-discharge compliance
and inspecting all surface and underground anthra­     monitoring for preexisting, non-encountered dis­
cite and bituminous coal mines, coal preparation       charges and all preexisting discharges after active
plants, coal refuse disposal, and industrial mineral   remining operations.
quarries. The offices also concentrate on industry
compliance assistance as well as all aspects of        Other Innovations: (1) Alternative Approaches
pollution prevention advocacy.                         to Reducing AMD through Regulatory Innovation.
                                                       The use of BMPs without numeric limits is an in­
The Experiment: PADEP proposed this XL                 novative approach that focuses on preventing pol­
project to explore a new approach to encourage         lution at the source(s) in the abandoned mine land
the remining and reclamation of abandoned coal         areas of the watershed regardless of whether they
mine sites. The approach would be based on the         will be disturbed (encountered) during the
implementation of best management practices            remining. NPDES permits for remining currently
(BMPs) instead of compliance with in-stream pol­       establish site-specific numeric effluent limitations
lutant concentration limits and implementation of      representing best available technology. PADEP is
compliance with the National Pollutant Discharge       implementing its alternative permit approach so
Elimination System (NPDES) numeric effluent            that reminers may comply with non-numeric limi­
limitations measured at individual discharge points.   tations in the form of specific BMPs, as well as in-
This XL project will test this approach in up to       stream monitoring requirements to measure the
eight watersheds with significant acid mine drain-     performance of reclamation activities on water
age (AMD) pollution. The project will collect data     quality in the watershed. (2) Gaining Experience
to compare overall in-stream pollutant concentra­      with Remining BMPs. This XL project will also
tions versus the loading from individual discharge     allow PADEP, EPA, and the reminers to gain more
points and provide for the evaluation of the per­      experience in implementing, developing, and
Project Status and Results

                                   refining the application of new and existing BMPs.        Progress in Meeting Commitments
                                   It will also provide data on the most effective BMPs
                                                                                             (As of February 2001)
                                   and information on possible improvements in their
                                   use.                                                      The project is in its initial stages and activities are
                                                                                             just getting underway. The following commitments
                                   The Superior Environmental Performance:
                                                                                             have been made in the FPA.
                                   This pilot project is expected to provide superior
                                   environmental performance by encouraging coal             •	   PADEP will collect data to compare in-stream
                                   operators to undertake remining projects that oth­             pollutant concentrations with the loading from
                                   erwise would have been too risky or expensive be-              individual discharge points to provide for the
                                   cause of the potential to have to treat preexisting            evaluation of the performance of BMPs.
                                   acidic discharges following the remining. In re-
                                   turn for this lessening of the risk associated with       •	   PADEP will test the BMPs approach in up to
                                   potential treatment costs, the reminers would                  eight watersheds with AMD pollution.
                                   implement more reclamation activities in the wa­
                                   tershed than existing Pennsylvania regulations or              –	 On February 7, 2001, Sky Haven Corpo­
                                   federal law require. With this proposal, the                      ration signed the first PADEP Mining Per­
                                   reminers would still be responsible for an equally                mit and Consent Order and Agreement for
                                   protective standard of maintaining overall water                  a remining project in the Surveyor Run wa­
                                   quality in the stream but would accomplish this                   tershed in Clearfield County, Pennsylva­
                                   via BMPs. Under this project, treatment of dis­                   nia. The remining started in late February.
                                   charges would be undertaken only as a last resort                 Four other projects are currently in devel­
                                   if the BMPs fail (or were not implemented) and                    opment.
                                   water quality is degraded. Remining (with recla­
                                                                                                  –	 BMPs that will be applied at the Surveyor
                                   mation to present-day standards) is an effective way
                                                                                                     Run Watershed project include revegeta­
                                   to reclaim abandoned mine lands and improve
                                                                                                     tion of 50 acres, blending acid forming
                                   water quality, at little or no cost to taxpayers. These
                                                                                                     strata with alkaline strata, and eliminating
                                   pilots are designed to increase the number of
                                                                                                     16,300 linear feet of dangerous highwall.
                                   remining operations providing reclamation and to
                                   enhance the degree of reclamation and AMD-                •	   Reminers will meet or improve water quality
                                   abatement measures taken on remining operations.               at an in-stream monitoring point (or points)
                                                                                                  rather than at each individual discharge to the
                                   Each of the pilot watersheds has been severely
                                   degraded by AMD from abandoned mine dis­
                                   charges and either is currently listed on                 •	   PADEP will continue to apply current efflu­
                                   Pennsylvania’s CWA list of impaired waters that                ent limitations/permitting requirements to pre-
                                   do not meet water quality standards or has been                existing discharges that are physically
                                   identified as a water body that does not meet wa­              encountered and collected with discharges
                                   ter quality criteria due to abandoned mine drain-              during active remining operations.
                                   age. For each watershed, PADEP expects that
                                   remining efforts will be an integral part of a water      •	   PADEP and EPA will make all project infor­
                                   quality remediation plan and that water quality                mation available to stakeholders in a form that
                                   improvements will be achieved by implementing                  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
                             170                                                                  and water quality monitoring results to EPA.
                                                           Project Status and Results
•	   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

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.          171
Project Status and Results

                                   PPG Industries,                                           dition, PPG believes that many other companies
                                                                                             can develop environmentally preferable products
                                   Inc.                                                      by applying the P2 Framework, especially at the
                                   FINAL PROJECT AGREEMENT SIGNED SEPTEMBER 14, 2000         R&D stage of product development.

                                   Background                                                The Flexibility: TSCA governs the manufacture,
                                                                                             importation, processing, distribution, use, and dis­
                                   The Project Sponsor: PPG Industries, Inc., (PPG)          posal of industrial chemical substances, including
                                   is a leading global supplier of coating, continu­         new chemicals. Annually, EPA evaluates approxi­
                                   ous-strand fiberglass, flat and fabricated glass, and     mately 1,500 to 2,000 new chemical notices sub­
                                   chemicals. As a technological leader for 116 years,       mitted by industry. Section 5 of TSCA requires
                                   PPG has introduced many new products and pro­             prospective manufacturers (or importers) to wait
                                   cess innovations, especially in the area of new           90 days after submitting a premanufacture notice
                                   chemical development. These new chemical sub-             (PMN) before they can begin to manufacture (or
                                   stances are developed in PPG’s research and de­           import) a new chemical substance. Within the 90-
                                   velopment (R&D) facilities located in Monroeville,        day period, EPA must evaluate the report, identify
                                   Allison Park, and Harmarville, Pennsylvania, in           potential risks of the new chemical substance, and
                                   the greater Pittsburgh area.                              specifically determine whether the substance may
                                                                                             present an unreasonable risk to human health or
                                   The Experiment: EPA’s Pollution Prevention                the environment. Unless the requirements for an
                                   (P2) Framework is a new screening methodology,            exemption are met, a PMN submitter may not
                                   based on a set of computerized risk screening tools,      manufacture a new chemical substance until 90
                                   to assist in characterizing the fate and hazards likely   days after it has submitted a PMN to EPA.
                                   to arise from the manufacture, use, and disposal of
                                   new chemicals. The P2 Framework, developed by             Under this project, because PPG is using the P2
                                   EPA’s Office of Prevention, Pesticides and Toxic          Framework, EPA has agreed that PMN substances
                                   Substances, was created to calculate or estimate          submitted by PPG, which EPA determines to
                                   important risk-related properties based on analy­         present a low risk, can be manufactured prior to
                                   ses of chemical structures and to design safer            day 90 of the review period pursuant to a test mar­
                                   chemicals, reduce waste generation, and identify          keting exemption (TME). Additionally, for chemi­
                                   other pollution prevention opportunities. In chemi­       cal substances for which PPG uses the P2
                                   cal manufacturing, companies invest substantial           Framework, PPG may submit combination TME
                                   resources into new product development before             applications and PMNs for concurrent review by
                                   seeking EPA approval, which is necessary under            EPA. Although EPA generally discourages simul­
                                   the Toxics Substances Control Act (TSCA) for new          taneous submittals, for the purposes of Project XL,
                                   industrial chemicals. As a result, chemical prod­         EPA will allow such concurrent submissions to be
                                   uct developers would like to minimize costs and           sustained when the TME is granted and the corre­
                                   risks associated with worker exposure, reporting,         sponding PMN is dropped from further review
                                   testing, recalls, and product liability. Recogniz­        during the first 30 days of the review period.
                                   ing the potential environmental and economic ben­
                                   efits, EPA is making the P2 Framework                     Other Innovations: (1) Pollution Prevention. EPA
                                   methodologies available to the chemical manufac­          expects that PPG’s use of the P2 Framework to
                                   turing industry to help promote the selection and         prescreen its product development options will re­
                                   application of safer chemicals and processes dur­         sult in increased opportunities for pollution preven­
                                   ing the early stages of decision making regarding         tion by preventing the generation of pollution rather
                                   chemical development. Applying the P2 Frame-              than controlling pollution once it has been created.
                                   work, PPG will incorporate environmental and              (2) Reducing the Regulatory Burden. The use of
                                   health information into the early stages of its           the P2 Framework allows PPG to anticipate and
                                   chemical development operations, as well as iden­         address EPA’s concerns prior to PMN submission,
                                   tify opportunities for pollution prevention. In ad­       greatly decreases the probability of adverse
                                                                                                                 Project Status and Results
regulatory action later, and improves the efficiency             evaluated using the P2 Framework assess­
of EPA’s PMN review process. (3) Stakeholder In-                 ment. Of the 20 products, 14 have been
volvement. Directly involving business and techni­               submitted to EPA. Of the 14 submissions,
cal stakeholders in the project is key to the goal of            five have been submitted as simultaneous
encouraging use of the P2 Framework during de­                   TME/PMN notifications. In addition,
velopment of new chemicals submitted as PMNs to                  three more products will be submitted as
EPA. The sharing of this new technological tool by               PMNs to EPA in the near future.
EPA and the communication of its benefits by PPG
with other stakeholders represents an unprecedented          –	 In the chemicals division, PPG has applied
cooperative approach to pollution prevention.                   the P2 Framework to five chemicals.
                                                                These chemicals will be submitted to EPA
The Superior Environmental Performance:                         for PMN review.
PPG’s commitment to use the P2 Framework and
promote its use within the industry reflects a com­     •	   PPG committed to conduct a validation study
mitment to pollution prevention, as companies are            to compare measured aquatic toxicity data with
not required to test new chemical substances un­             structure activity relationships (SARs) predic­
der TSCA prior to submission to EPA. New prod­               tions from ECOSAR (Ecological SAR), which
uct research and development can be a very                   is a personal computer software program de-
expensive process. Therefore, it is cost-effective           signed to estimate the toxicity of chemicals
to shepherd the “best” chemical candidate through            used in industry and discharged into water.
later phases of the product development process.             ECOSAR uses SARs to predict the aquatic
By using the P2 Framework, it is expected that PPG           toxicity of chemicals based on their structural
will develop innovative, cleaner, and more envi­             similarity to chemicals for which aquatic tox­
ronmentally benign products and processes be-                icity data are available. SARs express the cor­
cause it will be able to identify early on any               relations between a compound’s physico­
problems with the chemical development and it will           chemical properties and its aquatic toxicity.
avoid carrying problem chemicals through prod­               SARs measured for one compound can be used
uct development cycles which could result in irre­           to predict the toxicity of similar compounds
coverable costs. In addition, it is expected that            belonging to the same chemical class.
PPG’s manufacturing processes and waste handling             –	 PPG committed to work with EPA to vali­
processes will operate at higher levels of environ­             date certain SAR predictions with the
mental performance due to an increased emphasis                 ECOSAR program. PPG submitted to
on pollution prevention.                                        EPA an SAR validation report in Decem­
                                                                ber 2000. SAR predictions were gener­
Progress in Meeting Commitments                                 ated for 38 polymeric chemicals submitted
(As of August 2001)                                             by PPG to EPA as PMNs. These predic­
                                                                tions using SAR data were compared to
•	   Overall, PPG has been able to meet all of its              actual measured data on the same set of
     environmental commitments to date for the                  chemicals.
                                                             –	 The results indicate 87 to 90 percent agree­
•	   PPG committed to applying the P2 Framework                 ment between the predictions and mea­
     in its new product development program and                 sured data. Data were considered to be in
     submitting PMNs to EPA based on P2 Frame-                  agreement if SAR predictions were within
     work analysis data.                                        the same order of magnitude (less than a
                                                                tenfold difference) as measured data, or
     –	 PPG has used the P2 Framework success-                  there were no effects at saturation and the
        fully on approximately 20 new products                  measured data showed no effects at the
        in the coatings division, primarily paints              maximum attainable or limit test values.
        and resins. All of the products have been               The actual data are classified as TSCA
Project Status and Results

                                            Confidential Business Information and        Benefits for the Environment
                                            cannot be released; however, an abstract
                                            of the SAR study was presented as a poster   •	   As chemical screening is not required under
                                            at the March 2001 annual meeting of the           TSCA, the use of the P2 Framework represents
                                            Society of Toxicology in San Francisco.           a huge step in effectively trying to minimize
                                                                                              the environmental impacts of new chemical
                                        –	 PPG, independent of the FPA, conducted
                                                                                              and product development. Use of the P2
                                           a second SAR study on chlorinated ben­
                                                                                              Framework highlights areas and opportunities
                                           zenes. This study was presented at the
                                                                                              for pollution prevention during the beginning
                                           October 2000 Allegheny-Erie Society of
                                                                                              R&D phases of new chemical development,
                                           Toxicology meeting in Pittsburgh.
                                                                                              which decreases the toxicity and pollution
                                                                                              potential of chemicals.
                                   •	   PPG committed to communicating with other
                                        industries on the uses and benefits of the P2
                                                                                         •	   PPG’s use of the P2 Framework to success-
                                        Framework and to promote understanding
                                                                                              fully screen chemicals has allowed them to
                                        about the P2 Framework through outreach to
                                                                                              submit PMNs to EPA with the knowledge that
                                        industry and other stakeholders.
                                                                                              they have, to the extent possible, been able to
                                        –	 PPG has conducted outreach by giving               reduce environmental impacts and make their
                                           several presentations about the beneficial         chemicals and products safer.
                                           uses of the P2 Framework at the follow­
                                           ing meetings: (1) Allegheny-Erie Society      •	   Through extensive outreach, PPG will be able
                                           of Toxicology, fall meeting in Pittsburgh,         to share their experiences with the P2 Frame-
                                           October 13, 2000; (2) Pittsburgh Chapter           work and help more chemical manufacturers
                                           of the Society for Risk Analysis, meeting          use and understand this tool to produce more
                                           in Pittsburgh, December 11, 2000; (3) So­          environmentally sound products.
                                           ciety of Toxicology, National Meeting in
                                           San Francisco, March 2001; and (4) Green      Benefits for Stakeholders
                                           Chemistry and Engineering Conference in
                                                                                         •	   Through the outreach component of this
                                           Washington, D.C., June 2001.
                                                                                              project, more informal partnerships between
                                        –	 PPG also will assist EPA, as necessary,            chemical manufacturers, EPA, state agencies,
                                           with its own outreach on the P2 Frame-             and the public have been created to increase
                                           work and a similar innovative idea known           information sharing and learning about new
                                           as the PBT Profiler, which is a new risk           tools to minimize environmental impacts of
                                           screening methodology that is designed to          chemicals.
                                           help companies identify chemicals that are
                                           persistent (P), bioconcentrate (B), and       Benefits for the Project Sponsor
                                           present toxicity (T) issues of concern. PPG
                                           will conduct an evaluation of the PBT         •	   Generally, early screening of new chemicals
                                           Profiler and make suggestions for im­              presents a definite competitive edge for PPG.
                                           provement and comment on its utility in            For example, with the P2 Framework in use,
                                           PPG’s product stewardship efforts.                 there is more effective decision making on
                                                                                              chemical products and chemical candidates for
                                   •	   Key focus areas for the PPG project over the          use, which helps PPG avoid potential regula­
                                        next six months will mostly likely include PPG        tory delays. Without regulatory delays, PPG
                                        submitting five PMNs for new chemicals that           will see a faster time to market in a highly com­
                                        have successfully passed the P2 Framework             petitive industry and can experience reduced
                                        and PPG reviewing, commenting on, and mak­            manufacturing costs for its products.
                                        ing suggestions for improving EPA’s PBT
                                        Profiler in PPG’s product stewardship efforts.
                                                     Project Status and Results
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.

Project Status and Results

                                   Progressive Auto                                         In addition, by offering this system, Progressive is
                                                                                            helping to reduce the negative environmental im­
                                   Insurance Company                                        pacts that are the result of vehicle miles traveled
                                   FINAL PROJECT AGREEMENT SIGNED JULY 27, 2000             (VMT).

                                   Background                                               In this XL project, EPA is working cooperatively
                                                                                            with the U.S. Department of Transportation on an
                                   The Project Sponsor: Progressive Auto Insur­             analytical study to determine the environmental
                                   ance is the fourth largest auto insurer in the United    impact of Progressive Auto’s usage-based auto
                                   States, insuring more than 5 million people and          insurance product to determine if drivers are mo­
                                   operating more than 350 offices nationwide. In           tivated to drive less, and thereby reduce VMT. As
                                   August 1998, Progressive began a limited market­         a part of this XL project, Progressive will make
                                   ing test in Houston, Texas, of a new product,            available to EPA aggregated data on participants’
                                   AutographSM, which bases auto insurance premi­           driving mileage gathered throughout the duration
                                   ums in part on when, where, and how much a ve­           of the study. These data will be used to make cer­
                                   hicle is driven. In August of 1999, the company          tain correlations between offering customers finan­
                                   expanded the test throughout the State of Texas.         cial incentives to drive less and corresponding
                                   Progressive has piloted this voluntary insurance         environmental impacts of lower VMT associated
                                   policy using Autograph SM to determine a                 with AutographSM customers.
                                   consumer’s auto insurance rate. With the use of a
                                   global positioning system installed in the               The Flexibility: As this project is an analytical
                                   consumer’s vehicle, actual vehicle usage, includ­        experiment, no regulatory flexibility is being re-
                                   ing when and how much the vehicle is driven, can         quested and Progressive does not obtain modifi­
                                   easily be monitored.                                     cations of any future laws or regulations. However,
                                                                                            as the project progresses, if it is found that the in­
                                   The Experiment: With the AutographSM system,             surance system proves to be environmentally ben­
                                   Progressive seeks to create and test a variable in­      eficial, it is possible that some alternatives would
                                   surance cost that will be influenced by the              be explored for offering incentives to key groups
                                   customer’s driving activity and will provide a fi­       who enable the expansion of this type of insur­
                                   nancial incentive for customers to drive less and        ance.
                                   choose alternative forms of transportation, such as
                                   public transportation or walking. Auto insurance         The Superior Environmental Performance:
                                   rates are traditionally based on variables, includ­      EPA’s interest in the Progressive pilot program
                                   ing vehicle age; vehicle manufacturer and value;         derives from the possibility that insurance pricing
                                   driver’s age, sex, marital status, place of residence,   plans like AutographSM might alter driving habits,
                                   and driving record; types of coverage; and               as well as distinguish existing differences in hab­
                                   deductibles selected. However, more specific in-         its, as drivers learn how their driving habits affect
                                   formation about customer driving patterns, such          their costs. With this program, EPA can collect
                                   as mileage driven and time of day and location of        data on whether people who sign up for a volun­
                                   driving, are generally not taken into account be-        tary program like AutographSM will reduce their
                                   cause of the difficulty involved in monitoring and       total driving or their driving during congested pe­
                                   tracking the information. Progressive’s piloted          riods, as understanding total VMT is essential to
                                   insurance program using AutographSM will deter-          promoting and crafting EPA’s policies dealing with
                                   mine a consumer’s auto insurance rate based on           congestion, smog, vehicle emissions, and “smart
                                   actual vehicle usage, including when and how             growth” concerns. For more information on the
                                   much the vehicle is driven. This system is designed      innovative concept behind the Progressive pilot
                                   not only to lower costs for Progressive’s custom­        program please contact Edmund Coe in EPA’s Of­
                                   ers, but also to encourage positive driving behav­       fice of Air and Radiation, Office of Transporta­
                                   iors, leading to a reduction in accidents and thefts.    tion and Air Quality, at
                                                        Project Status and Results
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.


Project Status and Results

                                   Steele County Project                                           for facilities to conserve water. Concentration-
                                                                                                   based limits can be a disincentive for water con­
                                   XLC9 FINAL PROJECT AGREEMENT SIGNED MAY 31, 2000
                                                                                                   servation since the greater the volume of water
                                   Background                                                      discharged, the less concentrated the pollutant will
                                                                                                   be in the wastewater. The facilities have also com­
                                   The Project Sponsor: A group of nine industrial                 mitted to participate in a training to learn how to
                                   facilities in Steele County, Minnesota (Wenger                  develop an ISO 14000-based environmental man­
                                   Corporation, Cybex International, Inc., SPX Cor­                agement system (EMS) to promote continual im­
                                   poration-Service Solutions Division, Josten’s, Inc.,            provements in environmental performance and
                                   Truth Hardware Corporation, Uber Tanning,                       compliance.
                                   Viracon, Inc., Crown Cork & Seal Company, Inc.,
                                   and Atofina), primarily small- to medium-sized                  In Phase II, which is not covered by the current
                                   facilities, including some metal finishers, have                FPA, these industrial partners would aim to expand
                                   agreed to work together to reduce the levels of in­             their efforts to a multimedia approach to environ­
                                   dustrial pollutants and water flow discharging to               mental permitting, based on overall community
                                   the local wastewater treatment facilities. Eight of             performance, rather than individual facility per­
                                   the facilities are located in the Town of Owatonna,             formance, in the areas of air emissions, solid waste,
                                   a growing community of 30,000 residents includ­                 hazardous waste, chemical storage, and commu­
                                   ing 40 industrial firms. Atofina is located in nearby           nity sustainability. They will test to see if this com­
                                   Blooming Prairie.                                               munity approach to environmental permitting
                                                                                                   based on overall performance for the nine compa­
                                   The Experiment: The project has been divided                    nies (rather than individual facility performance)
                                   into two phases. In Phase I, Owatonna participants              will be more effective in reducing environmental
                                   will specifically address reducing the discharge of             impacts and more economically efficient for the
                                   four priority metals (chromium, nickel, zinc, and               companies and the local government.
                                   copper) by 20 percent and total water flow by 10
                                   percent within five years. Atofina, the Blooming                The Flexibility: The FPA outlines five key areas
                                   Prairie participant, committed to reduce the con­               of regulatory flexibility needed for the Steele
                                   centration of biological oxygen demand (BOD),                   County XLC project to proceed with Phase I. On
                                   total suspended solids (TSS), and total Kjeldahl                October 6, 2000, EPA promulgated a site-specific
                                   nitrogen (TKN) by 20 percent in the first five years.           rule (65 FR 59738) giving flexibility described in
                                   The industrial participants also made commitments               the FPA to the Owatonna WWTF for six Owatonna
                                   to reduce stormwater runoff from their facilities               project sponsors (Viracon, Wenger and Atofina do
                                   and assist the Owatonna Wastewater Treatment                    not discharge to the Owatonna WWTF and there-
                                   Facility (WWTF) in educating the community                      fore are not covered by the site-specific rule). The
                                   about stormwater-related problems such as im­                   site-specific rule covers the following four areas:
                                   proper residential sump pump connections.
                                                                                                   •	   Monitoring Frequency Reduction. The site-
                                   This project is also testing whether the use of mass-                specific rule gives the Owatonna WWTF the
                                   based limits (e.g., overall amount of pollutant be­                  discretion to reduce monitoring requirements
                                   ing discharged by a facility, measured in pounds                     to once per year for the six participating fa­
                                   per day) rather than the current concentration-based                 cilities after the first metals reduction goal of
                                   limits (e.g., concentration of a pollutant, measured                 20 percent has been met.
                                   in parts per million) might serve as an incentive
                                                                                                   •	   Mass Based Limits. The site-specific rule pro­
                                                                                                        vides discretion to the Owatonna WWTF to
                                    Project XLC, eXcellence and Leadership for Communities,
                                   encourages local public sector and community organizations
                                                                                                        convert concentration-based limits to mass-
                                   to come forward with new approaches to demonstrate com­              based limits for the Owatonna sponsors cur­
                                   munity-designed and directed strategies for achieving greater        rently subject to concentration-based
                                   environmental quality consistent with community economic             categorical standards.
                                                                                                                    Project Status and Results
•	   Elimination of Monitoring for Pollutants not        of Mass-based Limits. The project will test whether
     Discharged. The rule gives discretion to the        mass-based limits are an effective incentive for
     Owatonna WWTF to not require participants           reducing water usage. It will provide valuable in-
     to monitor for pollutants not expected to be        formation to EPA, who is considering allowing
     present at levels greater than influent back-       publicly owned treatment works (POTWs) to set
     ground levels following comparison with three       equivalent mass-based limits as an alternative to
     years of effluent data.                             concentration-based limits to meet concentration-
                                                         based categorical pretreatment standards on a na­
•	   Alternative Significant Noncompliance Ap-           tional scale through the proposed rule:
     proach. The rule gives discretion to the            Streamlining the General Pretreatment Regulations
     Owatonna WWTF to publish notices of sig­            for Existing and New Sources of Pollution (July
     nificant noncompliance events, where the vio­       22, 1999 64 FR 39564). (3) Reduced or Elimi-
     lations did not cause a pass-through or             nated Monitoring for Regulated Pollutants Not
     interference violation and the sponsors have        Present. By testing the flexibility to waive or re­
     acted to promptly to correct them, on the Min­      duce monitoring for categorical standard pollut­
     nesota Pollution Control Agency’s (MPCA’s)          ants not expected to be present in the waste stream,
     Web site rather than in the local newspaper.        the Steele County project approach could be ap­
                                                         plied broadly by POTWs. This reduced monitor­
The FPA provides flexibility to the Blooming Prai­       ing approach was proposed as part of the July 22,
rie WWTF to use its discretion to evaluate the re-       1999, proposed rule affecting the National Pretreat­
cent performance of the Atofina facility and may         ment Regulations. (4) Peer Group Approach to
reduce monitoring requirements to twice per month        Correcting Noncompliance. This project tests the
on the basis of a satisfactory compliance record.        value of having a non-biased group of peers assist
After the Atofina facility has reached the 20 per-       a noncompliant facility’s return to compliance. The
cent reduction goal for BOD, TSS, and TKN, the           goal of the peer group is that peers will help a
Blooming Prairie WWTF may reduce monitoring              noncompliant facility better understand the nature
frequency to once per month.                             and causes of the violation and assist in identify­
                                                         ing actions for quickly returning to compliance and
Finally, several participating facilities also plan to
                                                         staying in compliance. Further, the peer group
use non-regulatory flexibility available from
                                                         experiment shows promise in “leading by example”
MPCA to self-certify that their industrial materi­
                                                         and can thereby promote and spread environmen­
als and operations are not exposed to stormwater.
                                                         tal stewardship to the greater Steele County indus­
Following this self-certification, sponsors will no
                                                         trial community.
longer be required to obtain stormwater permits.
Qualifying sponsors, however, agree to maintain          The Superior Environmental Performance:
their stormwater pollution prevention plan to en-        The 20 percent reduction in the four metals and
sure continued non-exposure to stormwater.               other priority pollutants will be made within the
                                                         first five years of the project. These reductions
Other Innovations: (1) Industry-Organized and
                                                         will reduce treatment loads at the local WWTF’s.
Community-Based Environmental Protection
                                                         Flow reductions, should result in fewer sewer over-
Model. This collaborative approach may: (a) lead
                                                         flow events into the nearby Straight River. When
to greater cooperation and creativity in approach­
                                                         there is excess water volume beyond capacity due
ing environmental regulations by regulators and
                                                         to a storm event and overflow does occur, pollut­
industrial participants; (b) set an example of envi­
                                                         ants in that effluent reaching the river should be
ronmental stewardship for other commercial in­
                                                         reduced, causing less environmental harm. In ad­
terests throughout Steele County; and (c) educate
                                                         dition, more environmental benefits should be re­
the public in Owatonna and Blooming Prairie about
                                                         alized because of participating Owatonna facilities’
environmental impacts of their actions. This in­
                                                         commitments to develop environmental manage­
dustrial partnership model could be exported to
                                                         ment systems and pollution prevention audits and
other industrial facilities in Steele County and
                                                         to assist the city in alleviating the problem of storm
throughout the United States. (2) Testing the Use                                                                 179
                                                         sewer overflow.
Project Status and Results

                                   Progress in Meeting Commitments                                                  Owatonna Effluent Metals Reduction

                                   (As of October 2001)                                                       First Quarter 2001                               0.94

                                                                                                                  2000 Average                               0.83

                                   •	   EPA promulgated a federal site-specific rule                                Project Goal                                    1.01

                                        on October 6, 2000, (65 FR 59783) that pro­                                    Baseline                                            1.26

                                        vides regulatory flexibility for the participat­                      First Quarter 2001                        0.70

                                        ing industrial facilities (participating industrial

                                                                                                                  2000 Average                                             1.21

                                        users) in Owatonna and the Owatonna WWTF.                                   Project Goal                                      1.17

                                                                                                                       Baseline                                                   1.46

                                   •	   The Owatonna WWTF has submitted a pre-                                First Quarter 2001       0.04

                                        treatment program modification to the MPCA,

                                                                                                                  2000 Average           0.2

                                        which will be incorporated into the Owatonna                                Project Goal          0.25

                                        WWTF’s National Pollutant Discharge Elimi­                                     Baseline                0.31

                                        nation System permit.                                                 First Quarter 2001          0.23

                                                                                                                  2000 Average                   0.49

                                   •	   The Owatonna WWTF has issued amended                                       Project Goal                       0.68

                                        pretreatment permits containing mass limits to                                 Baseline                                0.85

                                        each of the participating facilities in Owatonna.                                          0           0.5             1             1.5              2
                                                                                                                                                      Pounds Per Day

                                   •	   MPCA has worked with several of the facili­
                                        ties in Owatonna to utilize existing state flex­      Figure 47
                                        ibility to provide an exemption from                  Owatonna effluent metals reduction.
                                        stormwater permitting (following an on-site
                                        inspection) for two facilities in Owatonna.

                                   •	   MPCA provided training for participating fa­                                         Owatonna Water Use Reduction
                                        cilities in development of an Environmental
                                        Management System on October 15, 2001.                     First Quarter 2001                                                        400,000

                                                                                                             2000 Average                                       390,000
                                   •	   Preliminary data for 2000 and early 2001
                                        (January – First Quarter 2001) show that av­                          Project Goal                     373,500

                                        erage reductions in the discharge for chro­
                                                                                                                 Baseline                                                                415,000
                                        mium, copper, and zinc exceeded the 20
                                                                                                                       350,000 365,000 380,000 395,000 410,000 425,000
                                        percent reduction goal compared to the five-
                                                                                                                                               Gallons Per Day
                                        year baseline. Nickel flows were 17 percent
                                        below baseline in calendar year 2000 (see Fig­        Figure 48
                                        ure 47). The Owatonna WWTF will continue              Owatonna water use reduction.
                                        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.

                                                                                                                 Project Status and Results
Benefits for the Environment                            Information Resources: The information sources
                                                        used to develop this progress report include: (1)
•	   This collaborative approach may lead to            the FPA for the Steele County Community XL
     greater cooperation and creativity in approach­    Project, dated 31 May 2000; (2) Project XL 2000
     ing environmental regulations by regulators        Comprehensive Report, Volume 1: Directory of
     and industrial participants and set an example     Regulatory, Policy, and Technology Innovations;
     of environmental stewardship for other com­        and Volume 2: Directory of Project Experiments
     mercial interests throughout Steele County.        and Results, November 2000; (3) information from
                                                        EPA’s Office of Wastewater Management Web
•	   Several of the industrial participants have re-    page,; and (4) Informa­
     ported that this XLC project has helped raise      tion provided at a project participants meeting held
     environmental awareness in their companies,        on July 17, 2001, at the Steele County Adminis­
     especially at the upper management level.          tration Center in Owatonna, Minnesota.

•	   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

•	   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

•	   Increased environmental awareness on behalf
     of employees.

                                   United Egg
Project Status and Results

                                                                                            CAFO regulations, which were proposed in Janu­
                                                                                            ary 2001 (public comment period closed July 30,

                                   Producers                                                2001) and are slated for promulgation in 2003. It
                                                                                            is UEP’s understanding that the final CAFO regu­
                                   FINAL PROJECT AGREEMENT SIGNED OCTOBER 25, 2000
                                                                                            lations may well require most UEP members, due
                                   Background                                               to their size, to obtain individual NPDES permits.
                                                                                            In lieu of obtaining an individual permit, this
                                   The Project Sponsor: United Egg Producers                project includes a comprehensive program to help
                                   (UEP) is a farmer cooperative representing more          participating facilities achieve superior environ­
                                   than 300 egg producers in more than 20 states.           mental performance by implementing an EMS
                                   Most farms are integrated from the point of pro­         through a general permit issued by individual states
                                   duction through the final marketing of the eggs.         or EPA. Because the new CAFO rules are not due
                                   The commercial egg production industry is signifi­       to be promulgated until 2003, this project brings
                                   cantly concentrated, and approximately 318 com­          egg-producing facilities under an NPDES general
                                   panies now produce 96 percent of the nation’s 80         permit that includes superior environmental per­
                                   billion eggs annually. Most farms (approximately         formance through the implementation of EMSs
                                   80 percent) are solely dry litter operations, in which   several years earlier than otherwise would have
                                   chicken litter is collected and stored in watertight     occurred. This innovative project, which will also
                                   cement pits below the bird cages; dried for several      include a third-party auditing component, will uti­
                                   months; and annually removed to be sold or given         lize those common procedures and on-farm man­
                                   to third parties (65 percent), spread on nearby farm-    agement practices most likely to result in superior
                                   land owned or controlled by the egg producer (15         environmental performance. EPA, working with
                                   percent), or composted into mulch or pellets for         UEP, states, and others, developed a model gen­
                                   sale into the nursery or retail garden markets (20       eral permit that states can choose to adopt where
                                   percent). Small egg production operations (EPOs)         they are the permitting authority. EPA will use the
                                   are more likely (75 percent) to sell their eggs to       general permit and the EMS program requirements
                                   larger operations for washing and processing,            in states where it continues to administer the pro-
                                   where collection and disposal of egg wash water          gram.
                                   is often a permitted activity. Most large EPOs store
                                   egg wash water and spread it on land they own or         The Flexibility: In exchange for implementation
                                   control. Although egg wash water lagoons are most        of an EMS subject to third-party audits on an an­
                                   common among those who wash eggs on-site, some           nual basis, participating egg-producing facilities
                                   operators collect egg wash water in large tanks and      will be subject to NPDES general permits rather
                                   haul it weekly to water treatment centers. Most          than individual permits anticipated under EPA’s
                                   UEP farmers are large enough (having more than           new CAFO rules to be promulgated in 2003.
                                   100,000 birds) to be defined as concentrated ani­
                                   mal feeding operations (CAFOs) under the Clean           The Superior Environmental Performance:
                                   Water Act (CWA). Under current permitting pro­           It is anticipated that the superior environmental per­
                                   cedures and CWA regulations, only 12 percent of          formance from this project will result from egg-
                                   egg production farms operate under the federal           producing facilities participating in a more
                                   National Pollution Discharge Elimination System          comprehensive program that is based on (1) com­
                                   (NPDES) permits (although the majority operate           pliance with a NPDES general permit, including
                                   under state and/or local permits and requirements).      appropriate land application of manure; (2) devel­
                                                                                            opment and implementation of a multimedia EMS
                                   The Experiment: The XL project proposed by               that helps reduce environmental impacts from ac­
                                   UEP uses a less costly and less complex mecha­           tivities that are not regulated under conventional
                                   nism—a general permit and an environmental               NPDES permits; and (3) ongoing audits of EMSs
                                   management system (EMS)-based program—to                 by an independent third party, in addition to rou­
                                   secure superior environmental results. This project      tine NPDES compliance inspections.
                                   is designed in anticipation of EPA’s final NPDES
                                                                                                                      Project Status and Results
Progress in Meeting Commitments                               competency, (3) protocols and other written
                                                              tools used to conduct the audits, (4) sample
(As of October 2001)
                                                              audit finding reports to be used when sharing
•	   Participants in this project committed to col­           information with regulatory agencies and lo­
     lecting, analyzing, and presenting information           cal stakeholders, and (5) the method UEP will
     that examines the effectiveness of using best            use to oversee the operation of the auditing
     management practices to help protect water               program.
     quality. All parties committed to environmen­            –	 Working with EPA and America’s Clean
     tal performance indicators that will help indi­             Water Foundation, UEP has completed a
     cate the degree to which the project is                     Third-Party Audit Checklist for the UEP
     succeeding in meeting its superior environmen­              XL Project and Training Guide for XL
     tal performance goals. These goals are listed               Auditors. Trained auditors employed by
     in the Table 16.                                            the non-governmental organization,
                                                                 America’s Clean Water Foundation, will
In addition, the UEP, EPA, and the states have made
                                                                 conduct the audits and oversee the audit­
the following commitments.
                                                                 ing program.
                                                         •	   UEP committed to develop an outreach pro-
•	   UEP committed to develop detailed guidance               gram designed to help off-site users of manure
     to assist individual facilities in developing all        from egg producers manage this manure in an
     of the elements of an acceptable EMS. One                environmentally responsible manner.
     component of the guidance will be a “Model               –	 UEP has drafted Know How Much You
     EMS Template for Egg Producers.”                            Haul and Use, a worksheet and manure
     –	 UEP has completed the guidance for indi­                 nutrient credit calculator for determining
        vidual egg producers entitled: “Design­                  off-site manure spreading rates. This tool
        ing and Implementing an EMS: A                           will be field-tested and improved as
        Step-by-Step Instruction for Egg Produc­                 needed for use in 2002. This tool also will
        ers Participating in the UEP XL Project to               be demonstrated in the UEP training work-
        Develop and Implement an Environmen­                     shops and featured in UEP newsletters.
        tal Management System.”
•	   UEP committed to developing an EMS Train­
                                                         •	   EPA committed to offer NPDES general per­
     ing and Technical Assistance Action Plan.
                                                              mits to qualified facilities in states that are not
     –	 UEP provided training workshops on the                authorized to administer the NPDES program.
        XL project and on developing an EMS at
                                                              –	 EPA is developing a general permit for two
        their October 2001 annual meeting. UEP
                                                                 states, New Mexico and Oklahoma, that
        will also co-host Regional Workshops on
                                                                 have not been delegated the NPDES pro-
        the XL project, as necessary, across the
                                                                 gram. Additional non-delegated states
        country that will provide additional infor­
                                                                 may also participate in this manner.
        mation and project support for egg pro­
        ducers. The first of these workshops was         •	   EPA committed to perform a national compli­
        held on September 28, 2001, in Dallas,                ance screen of all egg-producing facilities to
        Texas.                                                identify those facilities that would not be eli­
                                                              gible to participate in the program.
•	   UEP committed to developing a third-party
     EMS auditing program. At a minimum, this                 –	 The national compliance screen is under-
     program will include (1) necessary qualifica­               way for all egg producing facilities.
     tions of auditors, (2) training to ensure auditor
Project Status and Results
                                   Table 16: Environmental Performance Indicators for the UEP XL Project
                                   Table                                                         Project

                                   Indicator             Measure                Source(s)          Frequency        Status

                                   1.	 Extent of         Number of              Association of     Annually, on     Several states have
                                       state             states issuing XL      States and         anniversary of   committed to moving
                                       participation     general permits        Water Interstate   FPA signing      forward with the process
                                                                                Pollution Control                    to issue a general permit

                                                                                Administrators,                     for egg producers in their

                                                                                Regional EPA                        states.

                                                                                Administrators, UEP

                                   2. Extent of egg      Number of egg          America’s Clean    Annually         In August 2001, more than
                                      producer           producers granted      Water Foundation                    80 egg producers signed
                                      participation      XL NPDES               (ACWF)                              a petition, circulated by
                                                         general permits                                            UEP, indicating a
                                                                                                                    commitment to participate
                                                                                                                    in the project.

                                   3. Value of UEP       UEP promotion of         UEP              Annually         To date, UEP has featured
                                      expanded            an education                                              the XL project at its Area
                                      industry           program through:                                           Meetings (held in August
                                      education          -number of fact sheets                                     2001) and discussed the
                                      program             and employee training materials;                          project at its Annual
                                                         -number of seminars, workshops                             Meeting in October 2001.
                                                          and XL presentations;                                     A training session on the
                                                         -number of seminars, workshops                             XL project took place
                                                          and XL presentations;                                     at the UEP Annual
                                                         -number of newsletters                                     Meeting in October 2001.
                                                          and articles on key XL topics;
                                                         -survey indications that third-party
                                                          manure users program is perceived
                                                          as valuable

                                   4. Value of           First-time audit       ACWF, UEP          Annually         Data are pending.
                                      on-farm            success rate for
                                      assessments        producers who
                                                         underwent pre-audit
                                                         assessments vs.
                                                         those who did not

                                   5. Environmental      Evidence that EMS     States, UEP, ACWF Annually           Data are pending.
                                      improvements	      systems and practices
                                                         have reduced negative
                                                         impacts on the
                                                         environment and
                                                         enjoyment of property
                                                         by surrounding locale
                                                         of farms

                                   6.	 Continued MS      Absence of:              States, UEP, ACWF Annually        Data are pending.
                                       implementation    follow-up audit,
                                       among XL          failures, state actions,
                                       participants       loss of general permits

                                   7.	 More rapid            Number and            UEP, ACWF       Annually         Data are pending.
                                       adoption of           percentage of
                                       Comprehensive UEP manure/
                                       Nutrient              egg wash user
                                       Management            facilities with CNMPs
                                       Plans (CNMPs)
                                       by participating
                                       facilities vs. others

                                   8.	 Regulatory        Compliance rates       States, EPA        Annually         Data are pending.
                                       compliance by     of XL participants
                                       XL participants

                                                                                                                  Project Status and Results
•	   EPA committed to provide advice to UEP to               America’s Clean Water Foundation prior to
     assist in achieving the objectives of the FPA.          commencement of EMS development under
                                                             the XL project. Thirty percent of UEP mem­
     –	 EPA has agreed to co-host a series of re­            bers have already undergone these comprehen­
        gional workshops to educate producers                sive assessments and are using the information
        about the UEP XL project and solidify                to reduce their environmental impacts.
        their participation. The first of these work-
        shops took place on September 28, 2001,         ·	   The inspection and oversight of environmen­
        in Dallas, Texas. Additional workshops               tal management will be expanded to a new and
        will take place, as necessary, in late 2001          previously unregulated set of EPOs. Currently,
        and early 2002.                                      only a portion of EPOs are fully inspected by
                                                             regulatory agencies. Facilities participating in
The States                                                   this program will be subject to EMS audits on
                                                             a regular basis.
•	   The participating states in this program com­
     mitted to issuing NPDES general permits un­
     der their applicable state statutes and
                                                        Benefits for Stakeholders
     regulations that are consistent with the model
                                                        •	   This project brings together a number of di­
     NPDES general permit and will use the EMS
                                                             verse groups—EPA, states, UEP, and a vari­
     guidance developed under this project to
                                                             ety of non-governmental organizations—to
     supplement their NPDES general permits.
                                                             help plan the appropriate tools and guidance
     –	 Several states have begun the process for            necessary for egg producers to promote and
        developing a general permit for egg pro­             achieve superior environmental performance
        ducers in their state. These states include          at their facilities. UEP continues to work with
        Illinois, Minnesota, Colorado, Florida, and          key egg production states to educate them on
        Utah.                                                the program and encourage them to participate
                                                             by issuing general NPDES permits for egg pro­
Benefits for the Environment                                 ducers.

•	   EMS requirements for this project will help        •	   This project provides for greater local input
     egg-producing facilities to remain in compli­           than is available under EPA’s existing NPDES
     ance and improve areas of their production that         general permitting regulations. A requirement
     need attention. It will also help ensure that           of participation in the XL program is to main­
     well-functioning facilities continue to perform         tain ongoing communications with neighbors
     at high levels and continue to address envi­            and the public. Local communities surround­
     ronmental issues of concern, and not just those         ing egg-producing facilities will be able to
     issues related to water quality.                        access environmental performance information
                                                             about the egg producing facilities in their com­
•	   By utilizing trained independent auditors, more         munity on an ongoing basis from their respec­
     oversight of egg-producing facilities can take          tive states through EMS audit results.
     place than would be possible with just federal
     and state resources. The results of audits, in­    Benefits for the Project Sponsor
     cluding areas where improvements are needed,
     will be shared by UEP with other smaller fa­       •	   The XL program, complete with an EMS,
     cilities that may fall below the regulatory             third-party auditing, and a general NPDES per­
     threshold but nonetheless could use the infor­          mit, will ultimately be a less complex mecha­
     mation to reduce their environmental impacts.           nism and less costly system than obtaining
                                                             individual NPDES permits for each facility.
•	   UEP urges all egg producers to undergo a vol­           Initially some facilities may incur additional
     untary, comprehensive on-farm assessment by             costs in making improvements to their facili­
                                                             ties in order to qualify for participation.        185
Project Status and Results

                                   •	   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.

                                                                                                                 Project Status and Results
U.S. Postal Service                                     Because LEVs are not available to meet the USPS’s
                                                        special needs, the Postal Service has proposed they
Denver                                                  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
Background                                              combination of the two. Compared with gasoline-
                                                        fueled vehicles, most E-85-fueled vehicles produce
The Project Sponsor: With more than 200,000             lower CO and carbon dioxide (CO2) emissions (as
vehicles nationwide driving more than 1.1 billion       much as 39 to 46 percent lower CO2). Emissions
miles annually, the U.S. Postal Service (USPS) has      of hydrocarbons and nitrous oxides are generally
the nation’s largest civilian fleet of vehicles. USPS   the same as, or even lower than, gasoline-powered
has been working for many years to test and pilot       vehicles. While these FFVs do not meet federal
alternative fuels and technologies across the coun­     standards as LEVs, they are certified as Transi­
try, including electric vehicles, vehicles that run     tional Low-Emitting Vehicles (TLEVs) that have
on compressed natural gas (CNG), and flexible fuel      lower emissions than standard vehicles, but not as
vehicles (FFVs) that can run on either gasoline or      low as the LEVs.
ethanol. Nationwide, the USPS currently has more
than 7,500 vehicles that use CNG, and they have         The USPS will test whether FFVs can effectively
purchased more than 21,000 FFVs. By 2002, the           meet the goals of the CFFP. The USPS expects to
USPS expects its fleet of alternative fuel vehicles     demonstrate lower overall emissions, because 100
to exceed 30,000. The USPS is undertaking ef­           percent of vehicles replaced will be TLEVs, in-
forts to maximize the amount of clean fuels they        stead of only 50 percent of the replacements being
use in order to reduce their contribution to air pol­   LEVs. The USPS plans to concentrate 810 FFVs
lution, particularly in urban areas. They are in a      in the City of Denver. For each E-85 vehicle that
position to establish greater visibility and infra­     the USPS deploys in Denver, it has agreed to re-
structure growth for clean fuels because of the size    move either a pre-1984 vehicle or a 1987–1991
of their fleets.                                        vehicle from service in the Denver area. The USPS
                                                        projects that, as a result of this project, 512 pre-
Denver, Colorado, including parts of six adjacent       1984 delivery vehicles will be destroyed.
counties (Adams, Arapahoe, Boulder, Denver,
Douglas and Jefferson) is currently classified as a     The Flexibility: The FFVs being acquired by the
nonattainment area for carbon monoxide (CO)             USPS do not meet current Colorado CFFP require­
under the Clean Air Act (CAA), but the region is        ments as LEVs. Therefore, the USPS has requested
in the process of petitioning for attainment status.    flexibility in meeting the standards and acquiring
In accordance with CAA regulations, states with         pollution credits from the Colorado Department
ozone and CO nonattainment areas are required to        of Public Health and Environment’s (CDPHE’s)
implement a Clean Fuel Fleet Program (CFFP).            Air Pollution Control Division (APCD). Under
CFFPs aim to improve air quality by encouraging         current pollution credit requirements, USPS would
institutions with fleets of vehicles, such as the       not be eligible to receive credits for the purchase
USPS, to use cleaner-burning and less-polluting         of non-LEV vehicles even though substantial pol­
vehicles.                                               lution will be prevented with the FFVs (TLEVs)
                                                        and retirement of older vehicles. With this XL
The Experiment: This project is examining an            project, the APCD will offer the USPS credits for
innovative approach to managing a new fleet of          the purchase of TLEVs accompanied by the re­
FFVs for the USPS. The Colorado CFFP requires           moval of existing vehicles. No federal flexibility
that new vehicle fleet purchases consist of at least    is required for the implementation of this project.
50 percent low-emitting vehicles (LEVs). The
USPS was unable to find a supplier when it re-          Other Innovations: (1) Demonstration of Etha-
quested bids for the required number of LEVs.           nol Tank Conversion. The USPS has developed

Project Status and Results

                                   technical specifications for modifying an existing           of CO, 24 tons of hydrocarbons, and 10 tons
                                   underground storage tank to properly house E-85              of nitrogen oxides.
                                   fuel and converted one of its fuel underground stor­
                                   age tanks to hold E-85 fuel in January 2001. This       •	   Reduction in evaporative emissions of hazard­
                                   modified underground storage tank can provide                ous chemical constituents (e.g., benzene) as­
                                   fuel for approximately 70 vehicles and will serve            sociated with unleaded fuel dispensing.
                                   as a demonstration project for public evaluation
                                   of alternative fuel storage. (2) Encouraging De-        •	   Increased market demand for E-85 fuel, both
                                   velopment of an Ethanol Infrastructure. The USPS             through the USPS’s addition of the approxi­
                                   is committed to helping stimulate the development            mately 800 vehicles and the publicity that the
                                   of a Denver-area E-85 infrastructure to support its          project will provide regarding alternative fuel
                                   vehicles. This infrastructure will also be avail-            vehicles. These two factors will provide eco­
                                   able to the public. The addition of over 800 ve­             nomic incentives for retail fuel providers to
                                   hicles in the Denver region that use E-85 fuels will         convert existing gasoline storage tanks to E-
                                   provide a significant market incentive for indi­             85 storage tanks. The USPS’s involvement in
                                   vidual fuel stations to provide E-85 fuels. The              Project XL and the Colorado Environmental
                                   USPS will work with the National Ethanol Vehicle             Leadership Program (CELP) are expected to
                                   Coalition to identify and encourage fueling stations         increase the visibility and promote the uses of
                                   to install E-85 fueling tanks. (3) Public Education          E-85 and alternative fuel vehicles. Addition-
                                   and Awareness. The use of over 800 FFVs in a                 ally, as the commercial availability of E-85
                                   relatively small area will provide an active and             increases, the purchase of dedicated alterna­
                                   visible demonstration of this emerging technology.           tive fuel vehicles, including FFVs and those
                                   USPS delivery vehicles will be present in hundreds           that meet LEV or cleaner emissions standards,
                                   of neighborhoods on a daily basis. FFV technol­              by vehicle fleets and private individuals will
                                   ogy will generate media attention that can be used           increase, thereby reducing mobile source emis­
                                   to inform the public about the availability of this          sions further.
                                   new technology and its flexibility of operation us­
                                                                                           •	   Creation of a USPS alternative fuel vehicle
                                   ing different fuels. (4) Transferability. The USPS
                                                                                                model for metropolitan areas that could be ex­
                                   project could serve as a model for vehicle fleets
                                                                                                panded and applied to other areas.
                                   across the country in replacing older vehicles with
                                   alternative fuel vehicles and developing an E-85
                                   infrastructure. As the project proceeds, there will     Progress in Meeting Commitments
                                   also be an opportunity to examine and evaluate the      (As of August 2001)
                                   opportunities and barriers in developing and main­
                                   taining an E-85 fueling infrastructure.                 •    The USPS committed to joining CELP.

                                                                                                –   USPS joined the CELP in May 2000.
                                   The Superior Environmental Performance:
                                   The following are the projected environmental ben­      •	   The USPS committed to taking delivery of at
                                   efits that are expected from this project:                   least 794 USPS FFVs certified as TLEVs ca­
                                                                                                pable of operating on either unleaded gasoline
                                   •	   A significant decrease in USPS’s contribution
                                                                                                or E-85. For each E-85 vehicle deployed in
                                        to vehicle emissions within the Denver metro­
                                                                                                the Denver area, the USPS will remove or
                                        politan area. The model year 2000 vehicle
                                                                                                transfer an older, more polluting vehicle within
                                        engines are cleaner burning and more fuel-ef­
                                                                                                120 days. Furthermore, 512 pre-1984 vehicles
                                        ficient than the older model year vehicle en­
                                                                                                will be scrapped, and 282 1987–1991 vehicles
                                        gines they are replacing. For example, each
                                                                                                will be relocated outside the Denver
                                        of the vehicles to be replaced emits 250 pounds
                                                                                                nonattainment area.
                                        per year more CO than each of the replace­
                                        ment FFVs. The net emissions reduction over             –	 Delivery of vehicles began in November
                                        a 20-year life cycle is estimated to be 432 tons           2000; 500 new FFV vehicles have been
                             188                                                                   delivered to date.
                                                                                                                 Project Status and Results
     –	 To date, 278 vehicles have been destroyed                proposed the acceptance of the SIP revi­
        and 208 vehicles have been relocated.                    sion and the substitution of the USPS
                                                                 project for Colorado’s CFFP.
•	   The USPS committed to helping stimulate the
     development of a Denver area E-85 infrastruc­      Benefits for the Environment
     ture to support its vehicles, which would also
     be available to the public.                        •	   The USPS conversion to E-85 vehicles will
                                                             result in significantly lower emissions. Net
     –	 Conversion of a USPS underground stor­
                                                             emissions reduction over a 20-year life cycle
        age tank to accommodate E-85 was com­
                                                             is estimated to be 432 tons of CO, 24 tons of
        pleted in January 2001. The USPS intends
                                                             hydrocarbons, and 10 tons of nitrogen oxides.
        to use the tank to operate at least 71 postal
        vehicles on E-85.                               •	   The increased visibility of E-85 vehicles con­
                                                             centrated in the Denver region may increase
•	   Whenever purchased, replacement vehicles
                                                             market demand for alternatively fueled ve­
     will meet or exceed California TLEV certifi­
     cation standards. If the fleet size is expanded,
     new vehicles will meet or exceed federal Tier
                                                        Benefits for Stakeholders
     1 certification standards.

     –	 500 replacement vehicles have been de-          •	   Denver area residents will benefit from cleaner
        livered. No fleet expanding vehicles have            air and fewer emissions from USPS delivery
        been purchased at this time.                         vehicles.

•	   Six months after delivery of the first E-85 ve­    •	   Residents with FFVs may benefit from ex­
     hicles, the USPS committed to submitting a              panded E-85 infrastructure in the region.
     semiannual report to CDPHE and the EPA.
     Thereafter, the USPS will submit an annual         Benefits for the Project Sponsor
                                                        •	   With the flexibility offered by this project,
     –	 The USPS submitted a semiannual report               USPS can purchase new fuel-efficient vehicles
        in May 2001.                                         (TLEVs) instead of continuing to operate its
                                                             existing older, more polluting, vehicles.
•	   CDPHE committed to proposing an amend­
     ment to the Air Quality Control Commission         •	   If purchased FFV vehicles run on ethanol
     Regulation Number 17 that will clarify the              rather than gasoline, USPS may accumulate
     provision of emission credits as an incentive           emissions credits that can be applied toward
     for the CELP.                                           fleet expansion.

     –	 The amendment was adopted March 16,             Information Resources: The information in this
        2000, and went into effect May 30, 2000.        summary was obtained from the following sources:
                                                        (1) the FPA for the USPS Denver XL Project,
•	   EPA will consider the submission of certain        signed May 22, 2000; (2) supplementary proposal
     parts of this project by the CDPHE as a sub­       materials; (3) Regulation Number 17: Clean Fuel
     stitute for the Clean Fuel Vehicle Program pre-    Fleet Program, Colorado Air Quality Control Com­
     scribed under part C of subchapter II of the       mission (last adopted 1/11/01 and effective 3/2/
     CAA as a revision of the Colorado State Imple­     01); (4) U.S. Department of Energy Alternative
     mentation Plan (SIP) after the USPS has re­        Fuel News stories; (5) USPS press releases and
     ceived at least 794 FFV vehicles.                  Web site; and (6) the 2000 Project XL Compre-
     –	 EPA published a proposed rule in the Fed­       hensive Report, Volume 2: Directory of Project
        eral Register on August 22, 2001. The rule      Experiments and Results, November 2000.
Project Status and Results

                                   USFilter Recovery                                         The Flexibility: In order to promote use of this
                                                                                             system, flexibility has been granted to allow par­
                                   Services, Inc.                                            ticipating generators and transporters of the
                                                                                             USFilter ion exchange wastes to replace certain
                                   FINAL PROJECT AGREEMENT SIGNED SEPTEMBER 21, 2000
                                                                                             existing Resource Conservation and Recovery Act
                                                                                             (RCRA) requirements for hazardous waste genera-
                                   Background                                                tors and transporters with an alternative system of
                                                                                             controls implemented by USFilter. EPA published
                                   The Project Sponsor: USFilter Recovery Ser­
                                                                                             a site-specific rule for the USFilter project on May
                                   vices, Inc., (USFilter) is a subsidiary of Paris-based
                                                                                             22, 2001, effective November 23, 2001. The State
                                   Vivendi, the leading global provider of commer­
                                                                                             of Minnesota must implement a rule adopting the
                                   cial, industrial, municipal, and residential water and
                                                                                             federal regulations before the project can be imple­
                                   wastewater treatment systems, products, and ser­
                                                                                             mented. New regulations will ensure that genera-
                                   vices, with operations in more than 100 countries.
                                                                                             tors and transporters properly store and transport
                                   The USFilter facility, located in the Minneapolis
                                                                                             the USFilter water treatment ion exchange resins,
                                   and St. Paul suburb of Roseville, Minnesota, is in
                                                                                             but reduce the burden of RCRA regulations that
                                   the business of treating inorganic industrial waste.
                                                                                             would likely be triggered by on-site recycling and
                                   Whenever technically and economically feasible,
                                                                                             treatment. Any new requirements are enforceable
                                   USFilter recovers the chemicals or metals from the
                                                                                             in the same way that current RCRA standards are
                                   received wastes for recycling and reuse.
                                                                                             enforceable. If the approved generator, transporter,
                                   The Experiment: In most electroplating and                or USFilter fails to comply with the new require­
                                   metal-finishing manufacturing processes today,            ments, then it will have violated RCRA and may
                                   wash and rinse water is used once, treated on-site,       be subject to enforcement action for such viola­
                                   and then discharged to a publicly owned treatment         tions.
                                   works (POTW) or surface water under permits is-
                                                                                             The Superior Environmental Performance:
                                   sued pursuant to the Clean Water Act. Metal slud­
                                                                                             This XL project will test an integrated waste stream
                                   ges are generally disposed of off-site. USFilter
                                                                                             process that will likely result in an increase in the
                                   proposes to install an ion exchange system at cer­
                                                                                             recovery and recycling of metals from electroplat­
                                   tain approved facilities that removes metal con­
                                                                                             ing operations, a reduction in the amount of haz­
                                   taminants from the water, making them available
                                                                                             ardous chemicals that are discharged to the local
                                   for reuse. The system consists of ion exchange
                                                                                             POTWs, and a reduction in the amount of water
                                   canisters that USFilter would install on the
                                                                                             used in the manufacturing process. The project
                                   customer ’s (primarily metal finishers and
                                                                                             expects to realize over the next three years a re­
                                   electroplaters) process lines that contain wastewa­
                                                                                             duction in discharge of neutralized effluent to the
                                   ters. The ion exchange, or deionization, process
                                                                                             POTW by approximately 2.3 million gallons and
                                   causes the metals in the wastewater to adhere to
                                                                                             recovery of approximately 2,250 pounds of cop-
                                   the resin material in the canister, rendering the
                                                                                             per, nickel, and zinc that would have been landfilled
                                   water free of metal contaminants. The water can
                                   then be reused in the customer’s process lines.
                                   USFilter would periodically collect the spent can­
                                   ister containing the metals (using Minnesota De­          Progress In Meeting Commitments
                                   partment of Transportation hazardous waste                (As of September 2001)
                                   licensed transporters), replace it with a fresh one
                                   at the generator facility, and treat the spent resin at   •	   The federal site-specific rule enabling this XL
                                   USFilter’s facility to regenerate it. Recovered acid           project was finalized on May 22, 2001. It will
                                   and hydroxide from resin regeneration would then               become effective November 23, 2001.
                                   be used at USFilter, and a secondary metals recov­
                                                                                             •	   The State of Minnesota is currently working
                                   ery company would recover the resulting metal
                                                                                                  toward implementation of state regulations that
                                                                                                  would enable the project to move forward.
                                                                                                                 Project Status and Results
     Once finalized, the State of Minnesota will       Benefits for Stakeholders
     issue permits under the Minnesota’s XL stat­
     ute to electroplating manufacturers and trans-    •	   For communities with industrial participants
     porters that have signed the FPA and agreed to         in this project, off-site discharge and disposal
     the conditions of the regulations.                     of wastewater and sludge containing heavy
                                                            metals would be reduced.
•	   Electroplating waste generators and transport­
     ers will commit to conditions spelled out in      Benefits for the Project Sponsor
     the site-specific rule.
                                                       •	   Through this XL project, USFilter will be able
•	   USFilter has committed to the following as the         to offer its customers a means of reducing their
     project is implemented:                                water consumption and increasing the recov­
     –	 USFilter will submit an annual report on            ery of metals from their industrial processes,
        October 1 on all USFilter XL wastes. It             while removing the trigger of increased regu­
        will provide information separately for             latory burden.
        each USFilter XL waste generator.
                                                       Information Resources: The information in this
     –	 USFilter will submit a quarterly report to     summary comes from the following sources: (1)
        EPA, Minnesota Pollution Control               the FPA for the USFilter XL Project, signed Sep­
        Agency, and the county agencies on Octo­       tember 21, 2000; and (2) the 2000 Project XL Com-
        ber 1, January 1, April 1, and July 1. It      prehensive Report, Volume 2: Directory of Project
        will include information regarding supe­       Experiments and Results, November 2000.
        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
•	   Implementation 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.
                                   Waste Management,
Project Status and Results

                                                                                           very slowly, thus leaving waste in a relatively
                                                                                           undecomposed state for a long period. In this case,
                                   Inc., Virginia                                          waste continues to be a potential source of ground-
                                                                                           water contamination throughout the post-closure
                                   Landfills Bioreactors                                   period of the landfill. Because biodegradation
                                                                                           occurs slowly, the liner system is potentially ex-
                                   Project                                                 posed to leachate for a relatively long period of
                                   FINAL PROJECT AGREEMENT SIGNED SEPTEMBER 29, 2000       time.

                                   Background                                              The purpose for implementing the bioreactor
                                                                                           projects is to increase the rate of biodegradation
                                   The Project Sponsor: Waste Management, Inc.,            in the landfills and to facilitate the management of
                                   (WMI) provides comprehensive waste manage­              leachate and other liquid wastes. This project will
                                   ment services to more than 10 million residential       test two different methods for recirculating and
                                   customers and 1 million businesses. Based in            adding leachate to the waste at the different land-
                                   Houston, Texas, WMI operates a network of ser­          fills in order accelerate waste decomposition. The
                                   vice facilities throughout the United States,           Maplewood bioreactor predominately will involve
                                   Canada, Mexico, and Puerto Rico and is the larg­        the recirculation of leachate generated at the facil­
                                   est company in its industry. As a part of this XL       ity, and the King George bioreactor will involve
                                   project, USA Waste of Virginia and King George          addition of a quantity of liquid at a rate of about
                                   Landfills, Inc., wholly owned subsidiaries of WMI,      twice that applied at the Maplewood landfill. Op­
                                   will implement and operate different bioreactor         erating these landfills using two different applica­
                                   operations (involving the addition and/or recircu­      tion rates will allow the relative performance and
                                   lation of bulk liquids, including landfill leachate)    cost-saving benefits of the two bioreactor ap­
                                   at the Maplewood Recycling and Waste Disposal           proaches to be compared. Moreover, the waste re­
                                   Facility (Maplewood) in Amelia County, Virginia,        ceived at these landfills is primarily municipal solid
                                   and the King George County Landfill and Recy­           waste, making this experiment unique when com­
                                   cling Center (King George) in King George               pared to other bioreactor projects in the XL pro-
                                   County, Virginia. The Maplewood facility is lo­         gram.
                                   cated approximately 30 miles southwest of Rich­
                                   mond, Virginia, and the King George facility is         The Flexibility: As part of this project, WMI will
                                   located approximately 50 miles north-northeast of       be granted regulatory flexibility from the require­
                                   the city. Both landfills receive similar waste          ments of the Resource Conservation and Recov­
                                   streams.                                                ery Act (RCRA) that prohibit application of bulk
                                                                                           liquids in municipal solid waste landfills
                                   The Experiment: WMI will operate test areas of          (MSWLFs) and prohibit the placement of liquid
                                   the Maplewood and the King George County land-          waste other than leachate/gas condensate and non-
                                   fills as bioreactors, recirculating or adding con-      septic household waste in any MSWLF with alter-
                                   trolled quantities of liquids, primarily leachate, to   native liner systems, as presented in 40 CFR
                                   accelerate the biodegradation rate of waste and the     Section 258.28. This regulatory flexibility will
                                   stabilization of the waste relative to what would       allow Amelia and King George counties to recir­
                                   occur within a conventional landfill. (See Figure       culate leachate in test areas in the Maplewood and
                                   49.)                                                    King George facilities. Both landfills were con­
                                                                                           structed with alternative liner systems.
                                   The design goal of a “traditional” landfill is to
                                   minimize the quantity of water introduced into the      Other Innovations: Exploring leachate recircu-
                                   landfill, thus minimizing leachate generation           lation rates for bioreactors. The key innovation
                                   (leachate is liquid that drains from the waste). The    of the WMI Virginia landfills project is the infor­
                                   disadvantage to this approach is that the lack of       mation it will provide about the impact of differ­
                                   liquid causes the biodegradation process to occur       ent rates of leachate recirculation on landfill waste
                                                                                                                         Project Status and Results
settlement and other environmental parameters.                   Reducing the volume of the waste translates
This project will also provide EPA with the op­                  into either longer landfill life in place and/or
portunity to obtain data on the differing impacts                less of a need for additional landfill space.
that geography, climate, construction, design, main­
tenance, and waste streams may have on the per­           •	     Minimizing Long-Term Leachate, Groundwa­
formance of a bioreactor system.                                 ter, and Surface Water Concerns: Research
                                                                 has shown that bioreactor processes tend to
The Superior Environmental Performance:                          reduce the concentration of many pollutants
WMI’s commitment to develop and test bioreactor                  in leachate, including organic acids and other
technologies at its Maplewood and King George                    soluble organic pollutants. Since a bioreactor
facilities strives to demonstrate improved pollu­                operation brings pH to near-neutral conditions,
tion prevention methodologies in comparison to                   metals of concern are largely precipitated and
current RCRA-permitted municipal solid waste                     immobilized in the waste.
disposal methods currently in use. The following
superior environmental benefits are expected with         •	     Increasing Landfill Gas Control: While add­
this project:                                                    ing liquids to the landfills will increase the rate
                                                                 of the gas generation, the period of landfill gas
•	   Landfill Life Extension: The life of a landfill,            generation will be compressed. WMI plans to
     when operated as a bioreactor, should be ex-                take advantage of this by exploring use of the
     tended due to the biodegradation of the waste.              landfill gas as a fuel for producing electrical
     This more rapid biodegradation increases the                power. This is expected to further minimize
     apparent density and decreases the volume of                fugitive methane and volatile organic com­
     the in-place waste remaining in the landfill.               pound emissions from the landfills.

Figure 49
Bioreactor process flow diagram for King George and Maplewood.
Project Status and Results

                                   Progress in Meeting Commitments                         •	   The bioreactor technology will result in an in-
                                                                                                creased rate of waste stabilization, resulting
                                   (As of August 2001)
                                                                                                in increased waste disposal capacity and the
                                   WMI, EPA, and the Virginia Department of Envi­               delay or avoidance of siting a new waste dis­
                                   ronmental Quality (VADEQ) are in the prelimi­                posal facility.
                                   nary stages of complying with the environmental
                                   commitments for this project. They have agreed          Benefits for Stakeholders
                                   to the following commitments in the FPA:
                                                                                           •	   Throughout the evolution of the project, stake-
                                   •	   EPA committed to propose and issue a site-              holders have been involved in and informed
                                        specific rule amending 40 CFR Part 258.28 for           about this project and have been encouraged
                                        Amelia and King George counties to allow re-            to share their ideas and concerns through writ-
                                        circulation of leachate over cells constructed          ten comments and meetings open to the gen­
                                        with an alternative liner.                              eral public, providing residents access to
                                                                                                information and decisions regarding the
                                   •	   VADEQ committed to hold public hearings in              project.
                                        respective localities as part of the amendment
                                        process for the current solid waste permits.       •	   The information obtained from this project will
                                                                                                provide EPA and the waste disposal industry
                                   •	   VADEQ committed to provide for landfill gas             with more data on bioreactors and their use as
                                        monitoring, record keeping, and reporting re­           a potentially integral part of long-term opera­
                                        quirements, for the bioreactor testing under            tions at these and other municipal solid waste
                                        their Title V air permitting program. The Title         landfill sites.
                                        V Permit for the King George landfill was
                                        signed on July 31, 2001. The Title V Permit        Benefits for the Project Sponsor
                                        for the Maplewood landfill is under develop­
                                        ment.                                              •	   Implementing bioreactor operations at the
                                                                                                Maplewood and King George facilities will
                                   •	   WMI committed to install trench systems and             result in several direct economic benefits to
                                        gas management structures at the Maplewood              WMI through: (1) decreased leachate manage­
                                        and King George landfills. This will be done            ment costs resulting from an increase in the
                                        during implementation of the bioreactor test­           amount of leachate being consumed in
                                        ing.                                                    bioreactor landfill, and (2) increased disposal
                                                                                                capacity due to an increased and more rapid
                                   •	   WMI committed to provide semiannual and                 stabilization of waste in a bioreactor system.
                                        annual groundwater, surface water, and gas
                                        monitoring reports to VADEQ for review.            Informational Resources: The information in
                                                                                           this summary comes from the following sources:
                                   •	   WMI committed to meet periodically with rep­       (1) the FPA for the Waste Management, Inc., Vir­
                                        resentatives from each stakeholder group to        ginia Landfills Bioreactors Project, signed Septem­
                                        discuss issues of concern and to disseminate       ber 29, 2000; and (2) the 2000 Project XL
                                        information.                                       Comprehensive Report, Volume 2: Directory of
                                                                                           Project Experiments and Results, November 2000.
                                   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
                             194        groundwater sources and surface water.

                                                                                                                 Project Status and Results
                                                        solving tank, calciner (a type of industrial kiln),
                                                        and combination boiler (the facility’s four major
Company, Flint River                                    sources of emissions) to be operated to their de-
                                                        sign capacity without triggering permit review and
Operation                                               (2) a cap covering all facility sources except those
                                                        four major sources. The dual emission caps con­
                                                        tain separate limits for particulate matter (PM),
Background                                              sulfur dioxide (SO2), nitrogen oxides (NOx), car-
                                                        bon monoxide (CO), volatile organic compounds
The Project Sponsor: The Weyerhaeuser Com­              (VOCs), and total reduced sulfur (an odor-caus­
pany is one of the largest private owners of forest,    ing pollutant). The modified air quality permit also
with 5.4 million acres in the United States. Among      streamlines the permit renewal process, includes
its products are timber, paper, and pulp.               alternate excess emission reporting protocols, and
Weyerhaeuser’s Flint River pulp manufacturing           includes a protocol for conducting manufacturing
facility in Oglethorpe, Georgia, manufactures           process experiments without triggering a permit
320,000 tons per year of absorbent fluff pulp used      review. EPA Region 4 and the State of Georgia
in diapers. The facility was opened in 1981 and is      have agreed to provide Weyerhaeuser the flexibil­
located 100 miles southwest of Atlanta, Georgia.        ity to demonstrate hazardous air pollutant (HAP)
                                                        emission reductions that would use innovative
The Experiment: Weyerhaeuser is striving to             pollution prevention approaches rather than end-
minimize the environmental impact of its manu­          of-pipe HAP controls. Weyerhaeuser prepared an
facturing processes on the Flint River and the sur­     alternative compliance plan that presented the HAP
rounding environment by pursuing a long-term            emission reductions to be achieved by the facility
vision of a minimum impact mill. “Minimum im­           following the April 15, 1998, promulgation of the
pact manufacturing” (MIM) contains the elements         maximum achievable control technology (MACT)
of a comprehensive pollution prevention program         cluster rule for the pulp and paper industry. EPA
designed to minimize the use of raw materials and       used a site-specific rule making to authorize alter-
to stop waste generation rather than to rely on “end-   native MACT compliance. EPA Region 4 and the
of-pipe” remedies. MIM involves multi-                  State of Georgia will modify Weyerhaeuser’s solid
disciplinary teams employing a systems engineer­        waste permit to allow nonhazardous industrial
ing approach, waste reduction, and a commitment         wastes containing free liquids to be disposed of in
to continuous improvement rather than the more          a permitted, onsite landfill.
traditional “project” focus. Specifically, the
Weyerhaeuser project tests a facility-wide permit­      Other Innovations: (1) Reporting Burden Reduc-
ting approach addressing water effluent discharges,     tion. The Weyerhaeuser project allows the facil­
air emissions, and solid waste generation that is       ity to consolidate reporting for some of the
designed to promote the MIM concept.                    applicable federal, state, and local permitting and
                                                        regulatory programs into two comprehensive re-
The Flexibility: EPA Region 4 and the State of          ports each year. Also, the facility is allowed to
Georgia have revised Weyerhaeuser’s National            eliminate fish tissue sampling requirements due to
Pollution Discharge Elimination System (NPDES)          improvements in process technologies that have
permit both to include more stringent effluent lim­     eliminated detectable dioxin levels in effluents,
its on biological oxygen demand (BOD), total sus­       remove a requirement for additional assimilative
pended solids (TSS), and absorbable organic             capacity studies, and perform annual compliance
halides (AOX), and to streamline the permit re­         certification in lieu of periodic discharge monitor­
newal process. EPA Region 4 and the State of            ing reporting due to the company’s 16-year his-
Georgia have modified the facility’s existing air       tory of meeting all required discharge levels. (2)
quality permit to include dual emission caps for        Environmental Management System (EMS).
air pollutants. The dual emission caps are (1) a        Weyerhaeuser will voluntarily institute an ISO
cap that allows the recovery furnace, smelt dis­        14001 EMS at the Flint River facility. The facility
Project Status and Results

                                   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

                                   Progress in Meeting Commitments
                                   (As of September 2001)
                                                                                                             Weyerhaeuser – Particulate Matter
                                   •	   Overall, Weyerhaeuser has been very success­              2000 Actual               433

                                        ful in meeting its environmental commitments              1999 Actual              395
                                        under the project.
                                                                                                  1998 Actual              390

                                        –	 Weyerhaeuser’s site-wide air quality per­              1997 Actual              385

                                           mit for the Flint River facility in                    1996 Actual               423

                                           Olgethorpe, Georgia, includes dual emis­
                                                                                                  1995 Actual                457
                                           sion caps for air pollutants. The follow­                Total Dual
                                                                                               Emissions Cap                       589
                                           ing caps are based on a 60 percent                  Effective 12/97
                                                                                              Allowable Under                                               1,472
                                           reduction from the levels a standard per­          Standard Permit
                                                                                                                 0   300          600       900   1,200   1,500
                                           mit would allow—PM at 589 tons per year,                                               Tons per Year
                                           total reduced sulfur at 62 tons per year,
                                           SO2 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        Figure 50
                                                                                          PM emissions data.
                                           Flint River facility’s actual emissions were
                                           the following: PM at 390 tons, total re­
                                           duced sulfur at 33 tons, SO2 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, SO2 at 582 tons, NOx at 795
                                           tons, CO at 1,573 tons, and VOCs at 632
                                                                                                                                                       Project Status and Results
    tons. In 2000, the Flint River facility’s
    actual emissions were the following: PM
    at 443 tons, total reduced sulfur at 35 tons,                               Weyerhaeuser – Bleach Plant Flow
    SO2 at 405 tons, NOx at 826 tons, CO at                      2001 YTD
    1612 tons, and VOCs at 646 tons (See fig­
                                                                2000 Actual                                                           20.0
    ure 50). Weyerhaeuser will report the 2001
                                                                1999 Actual                                                           20.0
    actual emission values at the end of 2001.
                                                                1998 Actual                                                           20.0

–	 Weyerhaeuser will (1) reduce the allow-                      1997 Actual                                                           20.0

   able air emissions by 60 percent under the                   1996 Actual                                                           20.0

   dual emission caps and (2) continue to look                    FPA Goal
                                                                   by 2006
   for new developments that may help reach              Baseline (1993-95
                                                         monthly averages)
   the goal of reducing bleach plant effluent                                   9 10 11 12 13 14 15 16 17 18 19 20 21
   by 50 percent over a 10-year period.                                  Cubic Meters per Air-Dried Metric Ton of Finished Product

   Weyerhaeuser has committed to research­
   ing the feasibility of implementing future
   technological developments in the indus­
   try that may allow the facility to reduce        Figure 51
                                                    Bleach plant flow data.
   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
                                                                       Weyerhaeuser – Biological Oxygen Demand
   approximately half of the plant’s water
                                                                  2001 YTD
   usage) and reductions in effluent limits on                   (1/01-6/01)

   BOD, TSS, and AOX. To reach its goal,                        2000 Actual                                             3.49

   Weyerhaeuser has conducted feasibility                       1999 Actual                                    2.83

   studies on reducing its water use. Al­                       1998 Actual                             2.13

   though attainment of this goal is not cur­                   1997 Actual                                      3.01

   rently feasible, technological innovations                   1996 Actual                                              3.52

                                                                *Permit Level
   continue to be assessed. An ultrafiltration               Effective 1-1-98                                                  3.80

                                                          Baseline (1993-95
   pilot test has been completed at another               monthly averages)                                                            4.32

                                                             Allowable under
   Weyerhaeuser facility. The results of the         Guideline Requirements

   pilot study are being evaluated for possible                                 0        1          2          3          4
                                                                                Pounds per Air-Dried Metric Tons of Finished Product

   further feasibility in reducing bleach plant                     *Units used in the NPDES permit are pounds per day.
                                                                    This data is collected as required by the permit and is available.
   effluent flow at the Flint River facility.                       The permit level has not been exceeded.

   Weyerhaeuser already has modernized
   several components of the pulping process,
   reducing the amount of BOD and TSS in            Figure 52
                                                    BOD in effluent discharge.
   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
Project Status and Results

                                       slightly increased to 2.83 pounds per
                                       ADMT and TSS in effluent increased to                                Weyerhaeuser – Total Suspended Solids
                                       3.87 pounds per ADMT. In 2000, the BOD                              2001 YTD                                     5.21
                                       increased to 3.49 pounds per ADMT and                             2000 Actual                            3.92
                                       TSS increased to 3.92 pounds per ADMT.                            1999 Actual                          3.87
                                       For the first half of 2001, Weyerhaeuser                          1998 Actual                   2.80
                                       reported discharging 3.97 pounds per
                                                                                                         1997 Actual                     3.13
                                       ADMT of BOD and 5.21 pounds per
                                                                                                         1996 Actual                          3.58
                                       ADMT of TSS (see Figures 52 and 53).                             *Permit Level                            4.09
                                                                                                     Effective 1-1-98
                                       Both BOD and TSS were higher than the                      Baseline (1993-95                                    4.65
                                       Phase IV goals during these six months as                  monthly averages)
                                                                                                     Allowable under
                                       they usually are for the first half of the year.      Guideline Requirements
                                                                                                                        0        2         4          6          8       10
                                       During the late summer and fall of the year,                                     Pounds per Air-Dried Metric Ton of Finished Product

                                       the holding pond is steadily filled to re-                         *Units used in the NPDES permit are pounds per day.
                                                                                                          This data is collected as required by the permit and is available.
                                       main within the NPDES permit for efflu­                            The permit level has not been exceeded.

                                       ent color while the river flow is extremely
                                       low. In January the holding pond begins
                                                                                          Figure 53
                                       to be emptied over several months when             Total suspended solids in Flint River effluent.
                                       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                     Weyerhaeuser – Adsorbable Organic Halides
                                       higher than the Phase IV goal on a pounds
                                                                                                         2001 YTD
                                       per ADMT basis, the NPDES permit lim­                            (1/01-6/01)                                      0.09

                                       its have not been exceeded (which are in                        2000 Actual                                       0.09

                                       pounds per day units).                                          1999 Actual                                            0.10

                                                                                                       1998 Actual                                            0.10
                                   –	 AOX results continued at a low rate (see
                                                                                                       1997 Actual                                            0.10
                                      Figure 54). The permit also allows the dis­
                                                                                                       1996 Actual                                            0.10
                                      charge of 0.15 kilograms of AOX per
                                                                                                       *Permit Level
                                      ADMT. In the first half of 1998, absorb-                      Effective 1-1-98

                                                                                                 Baseline (1993-95
                                      able organic halide levels peaked at 0.13                  monthly averages)

                                                                                                    Allowable under
                                      pounds per ADMT due to an increase in                 Guideline Requirements                                                       0.156

                                      customer demand for high-brightness pulp.                                   0.00       0.04         0.08         0.12        0.16
                                                                                                                  Kilograms per Air-Dried Metric Ton of Finished Product
                                      As a result, the facility has altered its use
                                                                                                         *Units used in the NPDES permit are pounds per day.
                                      of brightening chemicals in the bleach                             This data is collected as required by the permit and is available.
                                                                                                         The permit limit has not been exceeded.
                                      plant area and was able to regain the
                                      project average of 0.10 kilograms of AOX
                                                                                          Figure 54
                                      per ADMT for 1998 overall. In 1999,                 Adsorbable organic halides in effluent discharge.
                                      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.

                                   –	 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
                             198      the river. Weyerhaeuser’s long-term goal
                                                                                                                                                      Project Status and Results
    is to further reduce total water withdrawal
    voluntarily (see Figure 55). Baseline wa­
    ter withdrawal at the facility was a 11.18                            Weyerhaeuser – Raw Water Usage
                                                                                 Monthly Average
    MGD monthly average based on average                       2001 YTD
    monthly values for 1993 through 1995.
                                                             2000 Actual                                                      11.11
    Water use reductions anticipated from                    1999 Actual                                                             11.92
    modernization projects were not sufficient               1998 Actual                                                        11.49
    to offset increased water usage from other               1997 Actual                                                         11.74
    facility process areas, which resulted in                1996 Actual                                                             11.91
    1997 raw water use of a 11.74 MGD                     Voluntary Goal                                                     10.18

    monthly average. In 1998, the total usage          Baseline (1993-95
                                                       monthly averages

    returned to a 11.49 MGD monthly aver-                    Permit Goal                                                         11.50

    age through the daily water conservation          Enforceable Permit                                                               12.50

    focus of the production operators. In 1999,                               0                 5                       10                     15
                                                                                          Millions of Gallons per Day
    the water use increased to a 11.92 MGD
    monthly average. The primary cause for
    this increase was a customer demand for a
                                                  Figure 55
    higher-brightness pulp. In January 2000,      Raw water usage data based on monthly averages.
    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                  Weyerhaeuser – Solid Waste Generation
    to the Georgia Environmental Protection               2001 YTD                                               564
    Division to lower the Surface Water With­            (1/01-6/01)

    drawal Permit limit by 1.0 MGD. This                2000 Actual                                   489

    application was approved. Water usage               1999 Actual                                       498

    was 11.28 MGD for the first half of 2001.           1998 Actual                                 461

    In the second half of 2001, Weyerhaeuser            1997 Actual                       409
    will be evaluating a project that may lower
                                                        1996 Actual                                        505
    water usage by another 0.75 MGD.
                                                           FPA Goal
                                                            by 2006
–	 Weyerhaeuser’s goal is to reduce its 1995                Baseline
                                                         (1995 level)
   level of solid waste generation by 50 per-                           300         400              500               600              700
   cent by the year of 2006 (see Figure 56).                            Pounds per Air-Dried Metric Ton of Finished Product

   This goal will be accomplished through
   source elimination and byproduct recy­
   cling and reuse. Weyerhaeuser has mod­
                                                  Figure 56
   ernized several components of its pulping      Solid waste generation from Flint River facility.
   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
Project Status and Results

                                             levels. However, solid waste generation                    plication of process residuals where the com­
                                             for the first half of 2001 increased to 564                pany does not retain control of the use of the
                                             pounds per ADMT. Part of this increase                     residuals or the land where the residuals are
                                             is due to continued problems with the                      applied. The company will continue to explore
                                             calciner. The calciner continues to run                    beneficial uses of the solid waste materials in
                                             unreliably and the frequency of descaling                  controlled settings. Further investigations of
                                             operations, which produce lime mud, have                   the viability and economics of composting mill
                                             been increased, resulting in the increase                  wastes is planned to start in the second half of
                                             in lime mud waste product. Replacing the                   2001.
                                             calciner with a different piece of equip­
                                             ment would greatly reduce lime mud solid              •	   Weyerhaeuser has completed a facility-wide
                                             waste and overall solid waste amounts.                     energy conservation study as well as three
                                             Weyerhaeuser is considering replacing the                  small-scale energy conservation studies. As
                                             calciner in long-term capital planning. The                an outcome of the Energy Conservation Study,
                                             Weyerhaeuser study of application of com­                  an energy goal of 20,000 pounds of steam/
                                             post and some process wastes on small test                 ADMT has been set. For the first half of 2001,
                                             plots as forest amendments continue.                       the recovery boiler has been running with a
                                                                                                        new soot blower strategy. Weyerhaeuser de-
                                   •	   On June 27, 2001, EPA published a final rule                    creased steam usage in the first half of 2001 to
                                        (66 FR 34119)10 , approving revisions to the                    20,140 pounds of steam/ADMT. In 2002,
                                        National Emission Standards for Hazardous                       Weyerhaeuser plans to replace the steam driven
                                        Air Pollutants, which concerns the control of                   chiller in the pulping unit with a more effi­
                                        HAP emissions from the pulp and paper in­                       cient unit.
                                        dustry. These revisions are one of EPA’s steps
                                        to implement the FPA for Weyerhaeuser’s XL                 •	   Weyerhaeuser has met its commitments to up-
                                        project. Operation of the plant continues un­                   grade equipment, study process changes, re­
                                        der this rule, which ensures that fewer HAPs                    duce effluent discharges, reduce air emissions,
                                        are released than if the plant operated under                   reduce hazardous substance use, recycle solid
                                        the standard MACT rule. This completes the                      wastes, implement timberland management
                                        administrative procedures for implementing                      practices, conduct stakeholder meetings, and
                                        this project in the FPA.                                        prepare progress reports.

                                   •	   Weyerhaeuser has feasibility studies in                    •	   Weyerhaeuser reorganized and documented the
                                        progress on composting facility byproducts and                  Flint River EMS to conform to the ISO 14001
                                        applying the composted material on timber-                      standard. In November 2000, an audit of the
                                        lands. This trial is continuing into the third                  EMS was conducted. The Lands & Timber
                                        growing season. In addition, composting of                      organization received confirmation in early
                                        solid waste materials has been evaluated and                    2001 that their registration audit was success­
                                        successfully tested in recent years. Early in                   ful and that organization is now certified to
                                        2001, a new company policy on land-applica­                     ISO 14001. This resulted from an indepen­
                                        tion of residuals and solid wastes with the po­                 dent audit by the Quality Management Insti­
                                        tential to contain detectable concentrations of                 tute, which is a division of the Canadian
                                        dioxins and furans was implemented. The                         Standards Association. This achievement is
                                        policy discourages new endeavors in land ap-                    an enhancement to the completed Phase V
                                                                                                        project titled “Timberlands Resource Strate­
                                     Inadvertently when EPA published the final rule on June
                                                                                                        gies.” In addition to certification under the
                                   27, 2001, the date April 16, 2001 was used in two sections of        ISO 14001 EMS standard, Georgia
                                   the rule instead of the date April 16, 2002 which had been           Weyerhaeuser forest practices have been cer­
                                   used in the proposed rule. EPA published a technical correc­         tified to the American Forest and Paper
                                   tion on October 16, 2001 (66 FR 52537) to correct these two
                                   typographical errors.                                                Association’s Sustainable Forestry Initiative
                             200                                                                        standard.
                                                                                                                   Project Status and Results
•	   In the next six months, Weyerhaeuser plans to      •	   The Weyerhaeuser approach to solid and haz­
     identify and implement water conservation               ardous waste reduction (e.g., recovering lime
     measures to drive towards the goal of 10.18             mud) is providing a case study that the State
     MGD total water usage. In addition,                     of Georgia will use with other pulp and paper
     Weyerhaeuser will continue efforts in energy            mills.
     conservation to make progress toward the goal
     of 20,000 pounds of steam/ADMT for total           •	   By working directly with a state-of-the-art fa­
     steam usage and continue to operate the EMS             cility, EPA is gaining real-world information
     and schedule a certification audit.                     and experience about pulp and paper facilities.

Benefits for the Environment                            Benefits for the Project Sponsor

•	   As of June 2001, the amount of solid waste         •	   Weyerhaeuser achieved an estimated savings
     generated has been reduced by 30 percent.               of $176,000 in reporting burden costs during
                                                             the first year of operation as a result of the
•	   Over the course of the project, actual air emis­        successful revision and reissue of the facility’s
     sions of PM, total reduced sulfur, NOx, and             air quality and wastewater discharge permits.
     CO, have been reduced with decreases rang­
     ing from 17.7 percent for total reduced sulfur     •	   Weyerhaeuser foresees avoiding $10 million
     to 8.3 percent for NOx.                                 in capital spending on air pollution control
                                                             equipment throughout the term of the agree­
•	   After initiating several energy conservation            ment, although the actual savings is not quan­
     measures by June 2001, the total plant steam            tifiable.
     usage has decreased by 3.4 percent and the
     power boiler steaming rate has decreased by        •	   The “bubble” concept for air emission regula­
     20.3 percent.                                           tions (i.e., the dual emissions cap) allows the
                                                             company to avoid costly unnecessary permit
Benefits for Stakeholders                                    reviews.

•	   Stakeholders have a better understanding of        •	   The MACT applicability assessment and site-
     facility operations.                                    specific rule will allow the company to meet
                                                             or exceed the environmental benefits that
•	   Stakeholders continue to have better access to          would have resulted from new regulations in
     project information directly from the facility          a manner that is less costly for the facility.
     in a simplified, consolidated report.
                                                        •	   EMS implementation has begun to increase
•	   Stakeholders also continue to have the oppor­           staff education and awareness of the environ­
     tunity to learn more about the project and its          mental aspects of their jobs.
     progress in meeting project goals status by at-
     tending Weyerhaeuser Company’s annual              Information Resources: The information in this
     stakeholder meeting.                               summary comes from the following sources: (1)
                                                        the December 2000 XL Project Progress Report—
•	   The cooperative relationship between regula­       Weyerhaeuser Flint River Operations (EPA 100-
     tors and the company has had benefits beyond       R-00-006); (2) focus group discussions on
     the company because of the company’s efforts       December 1998 with representatives of the fed­
     to educate other pulp and paper facilities and     eral and state regulatory agencies, Weyerhaeuser
     timber suppliers. Specifically, Weyerhaeuser       Flint River Operations, and a local stakeholder in­
     is working with other timber suppliers and the     volved in the project; (3) annual and midyear re-
     Georgia Forestry Commission to promote best        ports prepared by Weyerhaeuser Corporation
     management practices on timberland and plan­       available through June 2001; (4) focus group dis­
     tations.                                           cussions in January 2000 with representatives of
Project Status and Results

                                   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.

Yolo County

                                                                                                                   Project Status and Results
                                                         fill. Conventional landfills do not use liquid addi­
                                                         tions, and landfill operators must receive regula­
Bioreactor                                               tory flexibility from EPA in order to operate a
                                                         bioreactor. This acceleration in the decomposi­
                                                         tion process is beneficial because it can increase
Background                                               landfill capacity and subsequent landfill life, im­
                                                         prove opportunities for treating the leachate liq­
The Project Sponsor: The Yolo County Central             uid draining from the landfill, reduce landfill
Landfill (YCCL) is a 722-acre landfill operated          post-closure management activities, and produce
by Yolo County Planning and Public Works De­             a methane gas byproduct that can be captured and
partment. It is located two miles northeast of the       used as a renewable energy resource.
City of Davis in northern California. Adjacent to
the site are the City of Davis’ Wastewater Treat­        In the first phase of this 20-acre project, Module
ment Plant lagoons, a highway bypass, and agri­          D has been constructed. This 12-acre module con­
cultural crops. There are also approximately 28          tains one 9.5-acre cell, which will be operated
residences within a two-mile radius of the land-         anaerobically, and a 2.5-acre cell to be operated
fill, the closest one being 1,600 feet to the south.     aerobically. The county will construct the second
The YCCL originally opened in 1975 for the dis­          phase of Module D in two years and, depending
posal of construction debris and non-hazardous liq­      on the results of the first phase of Module D, the
uid and solid waste. Current onsite operations           county may operate the second phase either anaero­
include an 11-year-old landfill methane gas recov­       bically or aerobically. The monitoring and report­
ery and energy generation facility, a drop-off area      ing of the second phase of Module D are not
for recyclables, a metal recovery facility, a wood       discussed in this proposal as the county intends to
and yard waste recovery and processing area, and         revise the FPA in two years when more data be-
a concrete recycling area. Under the Resource            come available from phase one of the project. The
Conservation and Recovery Act (RCRA), the site           county decided to construct this 20-acre cell in two
is characterized as a Class III non-hazardous mu­        phases to reduce the construction cost of the project
nicipal landfill (i.e., it accepts most types of solid   and to apply what is learned from the first phase to
and liquid waste, most of which comes from house-        the second phase.
                                                         This project is testing whether the following envi­
The Experiment: Yolo County is proposing a 20-           ronmental and waste management benefits can be
acre module of the YCCL for use as a controlled          accrued with a bioreactor landfill:
bioreactor landfill. A bioreactor landfill converts
and stabilizes decomposable waste in an acceler­         •	   Maximization of landfill gas control and cap­
ated manner. The process requires a liquid addi­              ture of methane and volatile organic com­
tion to the waste, which can include recycled                 pounds emissions;
leachate (i.e., water that collects contaminants as
                                                         •	   Landfill life extension and/or reduced landfill
it trickles through wastes) from the landfill itself.
A bioreactor landfill uses controlled quantities of
liquid to accelerate the otherwise slow decompo­
                                                         •	   Greater capture of leachate and a decrease in
sition of the waste. This acceleration increases
                                                              the pollutant loads of leachate;
the biodegradation of the solid waste and can de-
crease the composting time from over 30 years            •    More rapid waste stabilization; and
down to 5 to 10 years. In this type of landfill sys­
tem, liquids are added and circulated through the        •	   Decreased long-term risks associated with the
waste, as appropriate, to accelerate the natural bio­         landfill.
degradation rate of waste and therefore decrease
the waste stabilization and decomposition time
relative to what would occur in a conventional land-
Project Status and Results

                                   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         Figure 57
                                   amend 40 CFR §258.28 for Liquid Restrictions on           Control Cell—Note how pile is still raised in the center.
                                   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          Figure 58
                                                                                             Test Cell – Note how pile is sagging in the center. This is
                                   be used in the bioreactor. While these types of           due to the accelerated decomposition.
                                   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       accomplished through the addition of liquids to the
                                   ditions under several sections of California laws         waste pile, which speed up the composting, stabi­
                                   governing waste management under the Califor­             lization, and generation of methane (see Figures
                                   nia Code of Regulations, Title 27, Environmental          57 and 58). The methane will be captured at a
                                   Protection, which addresses the recirculation of          slight vacuum from a freely gas-permeable shred­
                                   liquids in lined municipal landfills.                     ded tire collection layer beneath the low-perme­
                                                                                             ability cover. Near complete extraction using this
                                   Other Innovations: (1) Evaluating Innovative              approach has already been demonstrated at a test
                                   Approaches to Solid Waste Management. This                cell where YCCL has been operating a smaller
                                   project assists in understanding how the perfor­          bioreactor demonstration project for over three
                                   mance of bioreactor landfills and liquid additions        years.
                                   affect operations under anaerobic and aerobic de-
                                   composition conditions. (2) Exploring RCRA Flex-          The demonstration test cell project is a an anaero­
                                   ibility for Landfills. Under RCRA, liquid additions       bic controlled bioreactor landfill, which consisted
                                   are prohibited at landfills, but the bioreactor sys­      of two demonstration landfill cells, each filled with
                                   tem requires the use of liquids to properly func­         approximately 9,000 tons of curbside garbage. The
                                   tion. EPA has been requesting information on the          “test” cell, or enhanced cell, received controlled
                                   liquid additions and is currently considering re-         liquid additions and recirculated leachate, while
                                   vising 40 CFR Part 258 to allow for leachate recir­       the “control” cell served as a control or baseline to
                                   culation in bioreactor landfills with the proper liner.   represent a conventional landfill. The demonstra­
                                   Through this XL project, EPA can further evalu­           tion project showed close to a 10-fold increase in
                                   ate whether allowing leachate recirculation in land-      methane recovery rate and an 18 percent decrease
                                   fills can prove beneficial.                               in the volume of solid waste compared to conven­
                                                                                             tional landfills. The full-scale bioreactor project
                                   The Superior Environmental Performance:                   proposed in the Project XL program is a larger-
                                   The full-scale Yolo County Bioreactor Project will        scale replication of this demonstration project.
                                   combine the acceleration of waste decomposition
                                   and the efficient capture of methane gas. The ac­
                                   celeration of the waste decomposition will be
                                                                                                                   Project Status and Results
Progress in Meeting Commitments                              draining from the landfill, reduce landfill post-
                                                             closure management activities, and produce a
(As of October 2001)
                                                             methane gas byproduct that can be captured,
•	   Many of Yolo County’s commitments will be               which decreases emissions and can be used as
     met after testing is completed. The testing was         a renewable resource. The bioreactor will be
     scheduled to begin in summer 2001. The con­             able to accept more waste over its lifetime
     struction of the aerobic liner was completed            making its environmental performance supe­
     in August 2001, and waste is currently being            rior to that of a conventional landfill.
     placed into the cell. Waste was placed in the
     cell until October 2001. Yolo County worked        Benefits for Stakeholders
     toward meeting all of its commitments as test­
     ing progresses throughout the fall of 2001.        •	   Present landfill capacity at YCCL is sufficient
                                                             until the year 2040, but with successful imple­
•	   EPA committed to propose and issue a site-              mentation of the bioreactor, the county and its
     specific rule, amending 40 CFR Part 258.28,             residents could see that lifespan extend,
     that applies specifically to this landfill.             thereby reducing the need for additional land-
                                                             fills in the county.
     –	 The rule was proposed on May 9, 2001.
        The final rule was published in the Fed­        Benefits for the Project Sponsor
        eral Register on August 13, 2001.
                                                        •	   Along with stakeholders, project sponsors will
•	   In October 2000, Yolo County submitted an               benefit from the extended life of the landfill
     application to Yolo-Solano Air Quality Man­             and the decreased long-term risks associated
     agement District (YSAQMD) requesting a fed­             with the landfill. Additionally, the effective
     erally enforceable state operating permit               and efficient capture of methane gas and its
     (FESOP) regarding gas monitoring require­               subsequent conversion to electricity could be
     ments. In addition, YSAQMD has been noti­               sold to the local grid, farmers, or the City of
     fied by Yolo County regarding the progress that         Davis.
     is being made at the landfill. The gas collec­
     tion and control system is scheduled for           Information Resources: The information in this
     completion by the end of November 2001 and         summary comes from the following sources: (1)
     water additions are scheduled to begin in De­      the FPA for the Yolo County Bioreactor Landfill
     cember. YSAQMD stated that they would              Project, signed September 14, 2000; and (2) the
     have the draft revised FESOP permit com­           Project XL Comprehensive Report, Volume 2: Di-
     pleted by mid November 2001.                       rectory of Project Experiments and Results, No­
                                                        vember 2000.
•	   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
      Project Status and Results


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