Cost Savings and Paperwork Reduction. While MSD has seen a short term increase in costs (collection system monitoring, receiving stream monitoring, administration and stakeholder interaction) during the initiation of this project, the following cost savings and reinvestments are expected over the long-term: Less permitting Additional monitoring Fewer inspections Source identification Less data entry Special investigations Less time spent on compliance Pollution prevention issues Reductions in monitoring, sampling, reporting for selected users Outreach, technical assistance and education Watershed management
Cost Savings and Paperwork Reduction. Laboratory waste management currently accounts for the most substantial expense for environmental, health and safety programs at the XL Participants. This University Laboratory XL Project will allow academic institutions to more effectively promote and implement waste minimization programs in laboratories. This will result in reduced waste disposal costs and reduced chemical purchasing costs without diminishing the level of environmental protection associated with the proper handling and/or disposal of hazardous laboratory wastes. The opportunity to develop a systematic, planned procedure for the pickup, consolidation and disposal of laboratory wastes will also enable participating institutions to more effectively utilize their EH&S staff for proactive activities. However, since RCRA requirements will remain in full effect at the institutional level, the XL Participants do not expect to significantly reduce the paperwork associated with compliance.
Cost Savings and Paperwork Reduction. Granting of a process exemption for the copper plating rinsewaters and the resulting declassification of the wastewater treatment sludges results in several benefits to IBM, USEPA, and the State of Vermont.
1. Classification of the sludges as non-hazardous will remove the sludge from the annual RCRA report. Despite a minimal change in sludge composition with the addition of the copper plating process, IBM will increase its reportable hazardous waste production by approximately 167 %, from 2.25 M pounds per year to 5.99 M pounds per year based on 1997 actuals. While a minimal paperwork burden, reclassification of the sludge does have a significant potential for causing negative publicity for the IBM Burlington facility despite the fact that the environmental impact of the sludge and the operations has not appreciably changed.
2. IBM will not have to file an annual “Request for Export of Hazardous Waste” to Canada. Preparation of the application requires 2 hours of engineering time and then 2 to 3 hours of phone calls and follow-up to assure that the application is being processed expeditiously. The USEPA will not have to process and track the Request for Export resulting in some manpower savings to the Agency.
3. IBM will not have to prepare manifests for each shipment of sludge. IBM is presently making 2 sludge shipments per week to a Canadian disposal facility. Preparation, tracking and close-out of a RCRA hazardous waste shipment manifest is estimated to take 1.5 hours per shipment. This represents 150 hours per year of additional effort at a cost of $3.5 K/yr. Similar savings will be accrued by the state of Vermont and the Canadian Waste Disposal facility.
Cost Savings and Paperwork Reduction. This project will provide savings from both financial burden and paperwork. Without XL flexibility, the implementation of comprehensive Storm Water Program compliance activities would require the City of Xxxxxx to encumber the cost of developing an additional department or division. Without a relaxation of the programmatic activities associated with the City of Xxxxxx Pretreatment Program Monitoring and Enforcement schedule as approved in 1993, the efforts of staff to accomplish any Storm Water activities is significantly reduced. The reapportionment of City of Xxxxxx staff and resources and the combined involvement of UNT students and staff will allow the initiation of an innovative approach toward the accomplishment of Storm Water program requirements. The use of electronic remote monitoring and data transmission provides significant paperwork reduction.
Cost Savings and Paperwork Reduction. Cost Savings Avoided Costs
Cost Savings and Paperwork Reduction. Granting an exemption for the copper metallization process and the resulting declassification of the wastewater treatment sludges results in reduced costs and administrative burdens to IBM, EPA and VTDEC. Specifically:
1. IBM expects to see operational savings of $100,000 to $200,000 per year when the conversion to the copper metallization process is complete. The sources of these savings include reduced material costs (e.g., PFCs), and energy savings.
2. IBM currently has an exemption from the VT hazardous waste tax that saves them approximately $225,000.00 per year. Completion of this project would make those savings permanent.
3. The exemption will shorten IBM’s annual RCRA report by not requiring information on the wastewater treatment sludges.
4. IBM would not be required to file an annual “Request for Export of Hazardous Waste” to Canada for its wastewater treatment sludge. Administrative costs associated with the preparation of the application and necessary follow-up to assure that the application is being processed expeditiously would be saved. In addition, EPA will not have to process and track the Request for Export resulting in some manpower savings to EPA.
5. IBM would not be required to prepare United States hazardous waste manifests for each shipment of sludge from the wastewater treatment plant. Administrative costs associated with preparation, tracking and close-out of a RCRA hazardous waste manifest for this sludge would be eliminated. Estimated costs savings here are approximately $3,500/year. Similar savings will be accrued by the State of Vermont.
6. IBM has been reviewing options to send its sludge to a cement kiln to serve as a feedstock to the cement manufacturing process. The sludge has a percentage of active lime which can be used beneficially in the cement manufacturing process. By using the sludge as a cement feedstock, the sludge disposal costs will be reduced by a conservative estimate of approximately $60,000. Use of the sludge as a feedstock to the cement manufacturing process will eliminate the need to send the material for disposal at a secure disposal facility and put it to beneficial use. While the cement manufacturer is interested in using the IBM sludge in its process, they are unwilling to evaluate the material in detail as long as the sludge carries an F006 listing. Successful completion of this project XL will allow IBM to pursue the beneficial reuse of the sludge material.
Cost Savings and Paperwork Reduction. Utilities will realize direct cost savings and, through the need for reduced resources, time and paperwork, indirect savings. DEC and USEPA will also realize indirect savings through reduced resource demands, time saved (including computer time), and reduced paperwork. Utilities will realize direct cost savings in many ways, including the following:
1. EPA ID Number acquisition process costs;
2. Database management for each remote location as an individual generator;
3. Annual Hazardous Waste Report preparation costs;
