Benefits for the Project Sponsor. This project will bring about a significant re- duction in paperwork and savings in time and labor, both for public utilities and environmen- tal regulatory agencies, which can then redi- rect such resources to other environmental needs.
Benefits for the Project Sponsor. In 1997, Xxxxx reported that the preparation of standardized work procedures increased the Xxxxx facility staff’s awareness of the environ- mental aspects of their jobs. The improved work procedures also standardized environ- mental testing at the facility and raised its level 113 Project Status and Results of compliance by reducing its incidences of minor violations of environmental regulations.
Benefits for the Project Sponsor. 185 • The XL program, complete with an EMS, third-party auditing, and a general NPDES per mit, will ultimately be a less complex mecha nism and less costly system than obtaining individual NPDES permits for each facility. Initially some facilities may incur additional costs in making improvements to their facili ties in order to qualify for participation. 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.
Benefits for the Project Sponsor. Implementing bioreactor operations at the Maplewood and King Xxxxxx facilities will result in several direct economic benefits to WMI through: (1) decreased leachate manage ment costs resulting from an increase in the amount of leachate being consumed in bioreactor landfill, and (2) increased disposal capacity due to an increased and more rapid stabilization of waste in a bioreactor system.
Benefits for the Project Sponsor. Xxxxxx will be granted regulatory flexibility under Project XL by receiving approval of the redevelopment and its associated transporta- tion projects as a TCM, a step taken to reduce vehicular emissions and improve air quality. In return, Xxxxxx is working to bring a contami- nated site back to productive use, and in turn, examine whether the basis for considering the entire redevelopment project a TCM can xx- xxxxxx environmental benefits in air quality. Issues Needing Resolution • Major project milestones are slightly behind schedule. Due to minor setbacks, the construc- tion of the 00xx Xxxxxx Bridge/Extension has been delayed for a year. Xxxxxx expects to remain on-track in meeting its scheduled com- mitments, however, and bridge construction is expected to begin in July 2001. Lessons Learned • Since the Atlantic Steel redevelopment project is still in its early stages, the principal lesson to be learned is whether smart growth strategies can be applied to brownfields and transporta- tion projects, such that air quality and other environmental performance can be improved, as part of an overall community revitalization plan. • A number of stakeholders were not satisfied with the stakeholder involvement process. They felt as though the process was unclear from the beginning, did not provide a sufficient fo- rum for input, and was managed as a formal- ity. To avoid this problem in the future, Xxxxxx will sponsor additional public meetings and en- courage more direct stakeholder involvement. Information Resources The information in this summary was obtained from the following sources: (1) The February 15, 2000 Atlantic Steel XL Summary Report; (2) the Sep- tember 7, 1999 Atlantic Steel FPA; (3) The Xx- XxXx¬➢ v j7 tfro¿➢ct Statzs aud {➢szLts cember 1999 XL Project Progress Report— Atlantic Steel Redevelopment (EPA 100-R-00- 014); (4) Project XL Stakeholder Involvement Evaluation, Draft Final Report (April 2000); (5) News articles from the Atlanta Journal Constitu- tion: “Steely Determination: Green Light is Given for Design Work on 17th Street Bridge” (August 25, 2000), “Designer Sees 00xx Xxxxxx Bridge as Unique Gateway into Atlanta” (August 25, 2000), “Development Plan Falls into Place” (August 25, 2000); and (6) News article from Xxxxxxxxxxx.xxx/ atlanta: “Designer Picked for 00xx Xxxxxx Xxxxxx” (August 24, 2000). XxXx¬➢ v j& tfro¿➢ct Statzs aud {➢szLts Sro¬μtou Sorμoratcou Scst➢rsvcLL➢ ™accLcty ({or¬➢rLy Wctco) FINAL PROJECT AGREEMENT SIGNED OCTOBER 1...
Benefits for the Project Sponsor. As a result of WM/PP efforts, Crompton saved $228,000 in 1997, $25,000 in 1998, $650,000 in 1999, $381,000 in the first half of 2000, and identified potential future cost savings of over $1 million per year. • As a result of the RCRA deferral, Crompton expects future savings of about $700,000 over the life of the project. Issues Needing Resolution • Crompton incorporated a section into the WM/ PP study that described regulatory barriers to implementing some of the study’s findings, which will need to be addressed. • Crompton needs to evaluate additional WM/ PP opportunities identified in the study relative to other facility projects competing for capital funds. • Federal and state agency stakeholders ex- pressed interest in seeing greater participation in the XL project from the six surrounding com- munities. Currently only one community rep- resentative is involved in the project, but EPA and the West Virginia Department of Environ- mental Protection would like to see a minimum of one representative from each community. Lessons Learned • During the development of the FPA, project participants should: – Show more trust for each other. – Simplify the process. – Involve program offices early and through- out. – Meet face-to-face on a frequent basis. – Draft the legal implementation document and the FPA at the same time. – Keep the FPA simple; put the details in the legal implementation document. – Speed EPA Headquarters review times. – Work from drafted language; it is easier than discussing general concepts. • EPA should encourage other project sponsors to include WM/PP studies in XL projects. • One stakeholder noted that the key to commu- nity participation results from understanding lo- cal culture. • Two community stakeholders noted that it would have been positive if EPA had interacted more with local officials earlier in the project. • A company stakeholder emphasized that the Crompton XL project provided a means for EPA and Crompton to learn how to work to- gether more effectively. • For a variety of possible reasons, sometimes community residents simply will not participate in an XL project despite noteworthy efforts made by the project sponsor to encourage it.
Benefits for the Project Sponsor. In 1997, Xxxxx reported that the preparation of standardized work procedures increased the Xxxxx facility staff’s awareness of the envi- ronmental aspects of their jobs. The improved work procedures also standardized environmen- tal testing at the facility and raised its level of compliance by reducing its incidences of mi- nor violations of environmental regulations. XxXx¬➢ v t7 tfro¿➢ct Statzs aud {➢szLts Key Issues Needing Resolution • Not Applicable Lessons Learned • Ultimately, for the Xxxxx project to have got- ten back on track, each organization involved would have to had made a new or renewed commitment, with well-defined roles and re- sponsibilities of each partner and a new clear timeline for accomplishing the various tasks involved. • While the organizations involved had different perspectives about the project’s implementa- tion, all of them agreed on the following: test- ing the COP concept is still a good idea; FPAs for XL projects need to describe the steps that should be taken by the signatories should a change in a facility’s owner or operator occur; and EPA needs to clarify XL’s incentives to attract and maintain the interest of small busi- nesses like Xxxxx. • For all XL projects, the commitment of all par- ties, the division of responsibility, and timelines must be very clear from the beginning. Also, the EPA and state regulators must make an accurate assessment of the resources avail- able and the internal capabilities of the com- pany to implement the project. • If a facility management changeover occurs during a project, the EPA and state regulators must start working with the new company as soon as possible to ease the project’s transi- tion. • XL FPAs must include language that spells out the time frame for making a decision about pro- ceeding with the project when the management of the facility changes.
Benefits for the Project Sponsor. Merck expects to avoid millions of dollars worth of potential production delays in the competi- tive first-to-market pharmaceutical industry by eliminating repetitive permit reviews. • Merck is provided flexibility to make produc- tion changes without first obtaining permitting approval, as long as emissions remain below capped levels. • The permit streamlines content requirements of the application for Merck’s Title V operat- ing permit and compliance certification. Issues Needing Resolution • It is unclear how this project will address the recently issued pharmaceutical maximum MACT requirements. Merck, EPA, and the State of Virginia are working to ensure that XL project flexibility gains can continue under these recently issued regulations. • Because the facility-wide caps do not place an individual subcap on VOCs, the community and National Park Service are concerned about the potential impacts of increased VOC emissions. Actual VOC emissions will be tracked closely, and VOC impact analyses will be updated as needed. • Stakeholders believed that it was premature to try to identify barriers to project implementa- tion in 1998, since Merck’s PSD permit has just been issued by the Commonwealth of Vir- ginia. • The stakeholders did not anticipate the length of time needed to secure a natural gas supply connection to the boilers. The delay led to more limited interaction between Merck and some of the stakeholder groups, including the Na- tional Park Service and local community mem- bers, presumably due to a lack of information to report. Lessons Learned • Technical support for community stakeholders is needed early in the process. • EPA needs to communicate clear goals at the beginning of project development negotiations. • Third-party facilitation would have helped the negotiation process. • Transaction costs for community stakeholders were particularly high. • An incentive-based permit provided Merck with the motivation to purchase the lowest emission technology available. • Community stakeholders felt they were not in- cluded in some crucial negotiations. • For this XL project, stakeholders did not an- ticipate the delay in securing a natural gas line. Nonetheless, the conversion was completed before the August 2000 deadline. Stakehold- ers caution others to anticipate worst case sce- narios and to build in time for potential delays.
Benefits for the Project Sponsor. Deferral of hazardous waste determination from the laboratory to a central on-site loca- tion will allow the more effective management of laboratory waste at the institutional level and thus increase reuse and recycling opportuni- ties. • Increase of permissible time for waste pick- ups from 3 to 30 days will allow for a more coordinated and efficient pickup and delivery system, which frees up staff time. • The benefits of this project include the devel- opment of infrastructure and training designed to increase waste minimization and an orga- nized and coordinated campus-wide chemical reuse system. Information Resources The information in this summary comes from the following sources: (1) the FPA for the New En- gland Universities Laboratories Project, Septem- ber 1999; (2) Project XL Site Specific Rulemaking for University Laboratories, Final Rule, published in the Federal Register September 28, 1999; (3) Amendments to Vermont’s Hazardous Waste Man- agement Regulations, March 2000; (4) Boston College’s Draft Environmental Management Plan, April 2000; and (5) New England Laboratories Project XL Baseline Assessment, June 28, 2000. XxXx¬➢ v 6q tfro¿➢ct Statzs aud {➢szLts ft➢w \orL Stat➢ D➢μart¬➢ut o{ “uvcrou¬➢utaL Sous➢rvatcou FINAL PROJECT AGREEMENT SIGNED JULY 12, 1999 Background The Project Sponsor: The New York State De- partment of Environmental Conservation (New York State DEC) was created on July 1, 1970, to bring together in a single agency all state programs di- rected toward protecting and enhancing the envi- ronment. The New York State DEC is responsible for administration and enforcement of the New York State Environmental Conservation Law. The New York State DEC has three main functions: natural resource management, environmental qual- ity protection, and the promotion of human health, safety, and recreation. The Experiment: The New York State DEC project would allow public utilities located in New York State to consolidate hazardous wastes gener- ated at remote locations (e.g., manholes). The project will allow the utilities to consolidate the waste at a central collection facility for up to 90 days before transport and disposal, rather than hav- ing to transport piecemeal such wastes directly to permitted hazardous waste treatment/disposal fa- cilities. The Flexibility: RCRA regulations generally re- quire utility companies that generate hazardous wastes at remote locations (e.g., manholes) to trans- port such wastes directly to treatment, st...
Benefits for the Project Sponsor. This project will bring about a significant re- duction in paperwork and savings in time and labor, both for public utilities and environmen- tal regulatory agencies, who can then redirect such resources to other environmental needs. Key Issues Needing Resolution • The outcome of the Petition for Review may impact the implementation of this Project. In light of this, New York State DEC has placed a moratorium on accepting applications from utilities to participate in the project.
