INNOVATIVE PARTNERHIPS WITH INDUSTRY VIA PROJECT XL FOR AN EFFECTIVE PRETREATMENT PROGRAM

Project XL, which stands for “eXcellence and Leadership” is a national pilot program to test the extent to which regulatory flexibility and other innovative environmental approaches can be used to achieve superior environmental performance and reduce economic burden.The Metropolitan Water Reclamation District of Greater Chicago (District) is a publicly owned treatment works (POTW) that treats wastewater from domestic, commercial, and industrial sources located in the City of Chicago and 126 surrounding communities in Cook County, Illinois. The District has maintained an effective industrial waste Pretreatment Program for more than 30 years. Through its Pretreatment Program, which it is required to operate under its National Pollutant Discharge Elimination System (NPDES) permits, the District regulates process wastewater discharges from approximately 500 Significant Industrial Users (SIU), including 345 Categorical Industrial Users (CIU). In 1996, the United States Environmental Protection Agency (USEPA) awarded the District the National Excellence Award for Pretreatment Programs in the Large Category (greater than 100 SIUs).Based on the success of its traditional command-and-control Pretreatment Program, the District has initiated a pilot program under Project XL, incorporating many of the regulatory reinvention initiatives being explored by the USEPA, the Association of Metropolitan Sewerage Agencies, the Water Environment Federation, and the regulated industrial community.In the District's XL Project, four interrelated activities will demonstrate the application of performance-based oversight flexibility within the District's existing Pretreatment Program framework. Resources currently allocated to programmatic activities with low potential for environmental benefit will be reallocated to new Pretreatment Program activities with a greater potential for environmental benefit. These four activities are summarized briefly below.The District will exercise regulatory flexibility in its oversight of small CIUs having little or no environmental impact. Such flexibility will allow the District to reallocate currently committed resources to other activities with greater potential for environmental benefit.The format of the District's Pretreatment Program Annual Report will be revised to focus on detailed information regarding environmental performance rather than simple programmatic outputs.Approximately 250 of the 345 CIUs regulated under the District's Pretreatment Program are electroplating/metal finishing facilities. To further promote the objectives of the USEPA's Metal Finishing Strategic Goals program and other Sector Initiatives, the District will create Strategic Performance Partnerships (Partnerships) with facilities that participate in Sector Initiatives and fully achieve the individual facility goals outlined in their respective Sector Initiatives. Under these Partnerships, the District will work cooperatively with demonstrated sector leaders to develop, test, and implement alternative measurement systems for demonstrating environmental performance.Like most POTWs across the nation, the District has achieved substantial environmental gains relative to the non-conventional pollutants and heavy metals, which have been regulated under the NPDES and the District's local limits for many years. However, the same cannot be systematically said for other priority pollutants that may be of concern on a local scale. To address these pollutants, the District will develop Toxic Reduction Action Plans (TRAPs). Under TRAPs, the District will commit to specific reductions in the levels of select pollutants in WRP emissions through innovative source control initiatives such as educational outreach, pollution prevention assistance and market mechanisms.This paper will discuss the history behind and the drivers for the District's XL Project, describe the four project components, and report the current status of the project.