incentives and Disincentives, for
f Pollution Prevention Measures
Under the Water Program
Prepared by:
Susan R* April
Kerr 6 Associates/ Inc
Reston, VA 22091
EPA Contract I68-CO-003S
work Assignoent 12-41
2/4/94
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TABLE OF CONTORTS
• ,
EXECUTIVE -SUKMAH*
• ' .'
1 , INTRODUCTION
''
- 11
.1.3 organization of Report
,2 OVERVIEW OF': iNCENirVES/DISINCENTIVES- . .' • • '• • • ' ' • ' .. 7
2 i Regulatory Incentives and Disincentives, .... 16
22 ESnondc incentives and -Disincentives. ..... - «
- . 2.3 TShnical/lnformational incentives and. ^ ^ ^ ^ ^ _-.^.. . ^ .
2.4 Mana^Snt/Institutional incentives and ; /; . :' 19
, " Disincentives . • •. • • • * * * * * •*•••'."
3
• • *
ti
'
Are
Msistanoe and Outreachr and ,. .
coilaborative aalatiohslues •-...... .....•••
4 CASE EXSHPLE OF SOCCESSfOt UnESMUCM OE POIIMT1C.I
hL/i'IVKTORS • ..... * * * *
;;
Provisiona -.. - - - • • ' • * * * * ".* ... 56
,4.3: POiW Data Findings •• ° •••*"*"**.,... 58
4.4 Regional Board Follow-up . • •,--.• • • .• 59
4.5. POTW- Follow-up . •••'•-••:,.••• ...... .".". . . . 61
4 6 Relevance to Incentives Study .......
'"-' ' ' -:'H. '••'• "•.'.• ' " •''•'.'.-.... . .'• • ''-63'
REFERENCES- . • .- • • •'- •••..• ' ' ' * ' * .* '
•'•••• ' ' - --:- •• • .. ;-'. •• •;•,-" .'....•:'-.. --66
APPENDICES . . -'-;. .« • > •••• • ".•..*' * V ' •..'•' '
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context of detemoiiing how es proram efforts have
*
barriers
. factors that affect decisions by
While there ^e a.r^^r°fVTf^o adopt pollution prevention
""
Flexibility . .
barriers and ^^^^^thin a tmilti-aedia framework.
T-~
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Economic Realities
S
;
Technical iaad Financial A»»i*tance '
-jsgi
P
Open Coonuhicatioft •. ' ' -. .
'wSSrS&sSSSS".;'
o£ pollution.
.2
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Specific Findings . ''
<-ur study indicates that for metalfinishers and platers who
roay fce considering pollution prevention the following motivational
factors are most important:
o Categorical standards are outdated and increasingly
irrelevant for metalplaters because non-technology based .
standards (e.g., limits based on Water Quality Criteria) have'
superseded them in most cases.
o Mass-based standards are motivators for pollution prevention;
however, there has been difficulty in implementing them.
Regulators should be allowed the flexibility to use either
mass- or concentration-based standards to achieve their
goals. ' ' ."'.-'.-'
o When anforcaoaafe and compliance activities are tied to a
strong pollution prevention message, they can be a key
motivator for facilities to adopt pollution prevention.
o Bcononic factors have the potential to be key motivators, but
there are also significant barriers.
zero-discharge system* hold much promise for platers seeking
to maximize water efficiency and plating chemical
recycling/re-use, but there are both regulatory and
technical/informational barriers.
Flexibility in, the regulatory network, supportive
assistanee/outreachv and collaborative relationships between
industry, regulators, and the public can foster continuous,
industry-wide improvement, in pollution prevention.
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INTRODUCTION
r.l Purpose and Objectives . • ' .s,
PPA'S pollution Prevention Strategy establishes pollution :
'prevention, including both source reduction and toxics use /
redStion? as. the priority approach for reducing releases of
SlSnts ijito "t^e-environment. As part of EPA's-emphasis on &
pollution prevention, the .Agency set aside 2% of the FY91 and FY92
contract budgets for new pollution prevention initiatives. ;The
industrial Pollution Prevention Project (IPPP), for'which this
report 'was written, is one of-the Agency's 2% set-asides. The
IPPP is an Agency-wide, multi-media project, the objectives of
which are to: 1) incorporate pollution prevention into industrial
effluent guidelines;and 2) reach out to industry and the'public
to' spread and establish the pollution prevention ethic.
'-,--*• . ' ' - . '. ' , ' ' f : .: . ' ...
This study examines son® o'f the/key regulatory,' economic,
technical, and institutional incentives and disincentives
affecting decisions by industry to adopt pollution prevention ;
measures. While the analysis was approached from, a multi-media
perspective, a focal point of the study was to examine incentives
and disincentives that are driven by EPA, state, and local water
Droqram requirements and objectives. Because; incentives and
disincentives that: affect decisions to adopt (or not adopt)
pollution prevention need to be considered within the concrete
context of specific alternatives faced by particular facilities,
this study focused on a single industry, we were asked to focus on
the Metal Finishing Industry .in particular. Since the majority of
metalplaters discharge industrial wastewater to Publicly Owned
Treatment works (POTWs), the principal emphasis was on incentives .
and disincentives faced by indirect dischargers? however, direct
dischargers (i.e., those with NPDES permits) were also examined.
The objective of the incentives study is to present
information and findings that; would help the Agency better
understand aspects of decision-making with respect to, industrial
dischargers. Much- of past water program efforts have been driven,
if not by direct "end-of-pipa" statutory and regulatory
requirements,, then at least: by an "end-of-pipe" mentality or
approach to interpreting statutory and regulatory requirements.
. while some of these requirements may have promoted materials ,
substitution, process change, or better operating and^maintenance
(O&M) practicesv some have been neutral towards promoting
pollution prevention over conventional control, and still others
may have actually discouraged companies from exploring or adopting
pollution prevention alternatives—even when .those alternatives
could have been more economically beneficial. The objective of ..
this study is to assist EPA and other regulatory agencies .»'..-
- designing programs to encourage and support companies to consider
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.prevention approaches in the course _pf
to Let their water quality .and effluent
discharge obligations. - , . ' ,- • . . •
1.2 Study Approach and Data/ information Sources _
local, and POTW representatives. • :
"in addition to the detailed assessaentsfnore general^
^SS^fS^f^SS^^ .
vidru information about motivational aspects of the
!n ^nSndii sTLiterature dlta and other case study reports v*re
-
Environmental Management* . ' . , . :
rn a/wi<-ion to the site visits, case studies, and literature
S2!£ -
follow-up contacts vere made vath both ^stryjnd POTW_ further
representatives on the focus group to clarify contents and further.
explore ways to improve upon the report.
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1.3 "organization of Report
«• \ •= * bri^f introduction to the study. Section 2
Section ^.^of^f OUr major incentives/disincentives areas:
Of
^
pollution prevention.
StriTof completed telephone contacts.
6
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«e -s
•
econonic incentive ^Pf^^^i^Ses (lov^r disposal -
f '
cy isnueta >« *^- — - — , . _.»
^ss^.
poUution P^^oS^ef a^S^ "*** to explore
toine esoeaa ac
facility -go for
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Table 2.1
psoularory Factors in Pollution Prevention Decisions
flexible/ multi-media
regulatory framework
specific toxics use
reduction laws or facility
planning statutes that
encourage firms to do P2
opportunity assessments and
audits
compliance inspections
where NOVs are tied to a-
pollution prevention
message (e.g., referral to
state technical assistance
program)
flexibility within.
compliance and enforcement
programs (e.g.,extended
compliance schedules phased
to pollution prevention
activities, -soft landings"
for technical failure of
innovative technologies)
strict local limits, with
POTW ordinance; authority to
implement/enforce?
regulatory pressures on
POlWs such as EPA sludge
regulations, or air toxics
reduction requirements,
motivating POIW* to push
upstream sources- to lower
metals in wastewaters—
ideally through pollution.
prevention measures
single-media regulatory
framework
single-media permits that
focus on end-of-pipe
requirements
single-media inspections
with ho pollution
prevention message (i.e.
quicfc-fije, end-of-pipe
compliance focus)
inflexible approach to
media-specific enforcement
actions that allows no time
for process innovation or
exploration of pollution
prevention solutions
reliance on EPA categorical
limits which may be
outdated and set too low a
compliance level
pecific regulatory
barriers" such as RCRA
part B permit requirements
for facilities implementing
reuse/recovery technologies
or "zero discharge" systems
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SE?s witn pollution i -
prevention requirements;
brccotion of pollution ;.
prevention:1 alternatives in
enforescent case context
nvass-based or total .
loadings-based standards—
-.especially, for water
intens ive 'industries—that
may encourage water
reclamation/recyclirig/re-
use . . -
permit writers.;'that may be;
outdated and focus on .end-
of-pipe' solutions"
concentration-based
standards .that may
discourage water ;
reclaniation/recycling/rer.
use ,- ••'..•
9
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Economic Factors in Pollution Prevention Decisions
lower
costs that may include:
environmental management
cost savings (e.g., from
eliminating RCRA sludges,
or decreased wastewater
treatment costs)
— production or process
cost savings, due to lower
material or chemical use
~ utility cost savings due
to lower water, sewer, and
energy usage-
— lower liability costs
fee structures based on
pollutant loadings (permit
fees, EOIW fees, etc.) can
act as economic incentive
for pollution prevention
^^^^__^_^^^.^^^^^^^^^»»^""^
'R & D challenge grants, low
interest loans, ^j^6***
for equipment upgrades, ana
other funding assistance. .
mechanisms can be powertui
incentive—but only it
message.gets tacon^any
about availability and if
application process is not
onerous
"enhanced product quality
and/or corporate image may
lead to higher revenues
^™
capital investment
requirement difficult or
impossible for many firms:
— firms may have limited
'or no capital availability
due to low profit margins,
competing investment
priorities, or too much
environmental liability (a
"bad risk" for lendersy
.— "sunken investments" in
conventional pollution
control equipment
— many small firms—
especially "job shops"—,
cannot tolerate down-time
for equipment upgrades or
process change/experiments
economies of scale for sons
technologies may not be
realistic at smaller firms
(e.g., metal recovery
technologies, automatic
systems vs. batch)
R & D costs for new
technologies and/or process
modifications may be
difficult to bear—also, ,
firm must be concerned with
potential enforcement
related costs if technology
fails • '• -.
customer
dissatisfaction
with changed product may
mean loss of revenue
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'Cost account .ir.g'
can help.
•f. irss identify economic
•savings and opportunities
• "not readily -apparent—but
'there is a real need for
simpler, user-friendly, :
nethods such as a quick • •
checklist or \«rJcsheet that
small firms can use
to justify pollution
prevention expenditures can.
be complex. tiitE-consuming,..
and expensive (especially .
for pcall firms-) '
11
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• „. ical/In^ional Factors in Pollution Prevention
.3 Technical/mi Decisions
prevention's
prevention
V ' f^- Lf"*"*** ™" . ,—" x^^*
«
or to take risk
, misrepresent
the
and the
facility falls out of
prevention
technologes
chendcals
pollution
12
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perr.it. .'writer and inspector
t raining*on'how pollution
prevention can achieve,
. jalntain,'or even go beyond
compliance
chemical or.product •
substitution concerns: will
_it: a) do the jcb; b) be
"consistently available: c)
not become expensive;' and
d) not trigger sane other.
unforeseen regulatory
nightmare;'
proprietary information
concerns—^disincentive to
sharing information, data,
and/or experiences with new
processes ,
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Table 2.4
Facers in Pollution
Prevention Decisions
"corporate policy support W
pollution prevention or
Incorporating it into
strategic planning
"Accountability witnuT
management structure for
integrated (i.e., across
departments, groups, or
divisions) environmental
responsibility
'willingness to take risks"
-willingness to engage^"
ooen dialogue with botn
?l^latorrand technical
assistance personnel
that empower
ioy to seek pollution
jSvention opportunities
"potential for favoraoieT
Publicity; pollution-
Invention helps present a
"good guy" image? Jj**«L
sh^progress. (e.g., lower
TRI numbers)
no upper management
commitment to pollution
prevention
lack of coordination"
accountability among .
different groups in tne
company (e.g., process
engineers/product design
engineers, not talking to
environmental engineers)
low tolerance iot T—
policy/of risk avoidance
_^m""""
closed shop
afraid to ask questions-
«What I don't know won't
hurt me."
at regulatory agencies that
tie performance reviews to
number of enforcement _ . .
cases, number of permits,
etc. instead of rewarding,
quality environmental
results
'< .- .' • { .
"do not want to call
attention to themselves-
e.a., i^ company has been
-bSrned" onceby EPA, will
be reluctant to. try
anything new which might
draw more attention;
14'
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(and betveen-)
-iralatbry agencies;
openess _to pollution
prevention
j—*. —-^—•
broke, don't fix it.
15
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. 2.1 Regulatory Incentives and Disincentives (Table 2.1)
•*-«,•< hi litv is the most important'incentive to emphasize with
Flexibility-istneinos ^*Tlianca program interested in
ss^-wsp-.
and compliance personnel. • .
is key, even within a single media
aStuallfadopting pollution prevention measures.
pollution control equipment anyway.
This is
f
. 16
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2.2
r .br--.gir,g. themselves .into r.ew regulator/
pciiht is tl» issue of threatened .RGJA Parr. 3
facilities considering "zero discharge"
l the: iredia pftgrans present a unof^,
:Econoaic incentives and Disincentivea (Tabl« 2.2)
ra Sid the promise of future cost savings .
• Sv^Sents needed for such changes, ccoipanaes- . ,
* 52r old? wastevater treatnent system
^ investment- that, syst
.
T« a ,«rv ecnnetitive industry, custonar satisfaction is key.
'.n- -S. ataS^ SSS^S»S«" [surface finishing industry
prevent ccSpaiSs from taking pollution prevention actions.
inies in
Thera is a difference between large and small conpanies
terms ol t^ef 1 Jvet oi capital investment and there ability tq
17
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3
l'Su'cSS-*- carmot ignore oastc^r
satisfaction csoncerns.
2.3 T^chnical/lnfomational incentives and Disincentives
(Table 2.3)
washing syatens ^.^SLS^t ofT» and other ozone
firxna. Today, ^^^IgSS reoulatory discouragement towards
the nost
^ssj-ssragSSS^:^ sss's-
, •o.-ee tj» "i^^-^r^ss^^^sss0
18
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r-'"•"••
2.4 Managanent/lnstituticnal Inttentivea and Disincentives -
(Table 2.4)
reguj.a-coiry »»-«^ \t~ *rtT-aii»n. workers l have ideas they
fear of retribution*
For larger companies, an incentive for wxlertaldjig
ti» goals of pollution prevention
19
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INCENTIVE/DISINCENTIVE
OF pQliTIjr-L"• •Lrr-
ri^r^es^^^^^^
are «E»™nt:' tor MtjOgat^'*^*^ =ase studies/ sl»
—-^ ^^
are:
a .
_ . _ :. v^ij nuch orxatdse for platers
can foster
3b&*»
prevention* • '•
31 rd. «. Outdat-
^cuxr^ national :**S^J»SZ%Sf fS
U ~
categorical standards*.
20
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;«' cose liance ''with the new
•o*-Kec local
U<—n<=^ i**—' • w^ «/f Tja^PT CTUa_LitV a t^i* »•»**• »••• — — — —- _ ,
•increasingly ut^i^J. 2reChemical-specific limits and, lower
resulting ^.^h?^'their'pretreatnent programs,; POTWs will
limits overall, .WJJg? from their service area users-- ^_
£SludSgSSS!plSS~S help, them conply with tighter NPDES
permit conditions.
service areas. .The f?1*^ ®t2reasinalY dictated not by the
water SW^^^S^wJS^c through pretreatoent prograas or
3 i ! categorical Limits , and Pollution Prevention
addition to en^-^^PiP^SSS^^sVtSe should be a stronger
prevention npre fully. . . .
the
earlyT980's; there was essentiallyi»^*S32&"15±Srind
NSPS—with the..exception; of slightly io^r^ m-plant
the development^ocui^t^wh^e^c^r^some^, yg ^^ chefflical
5. The
21
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Comparison of Categoricals and Local Limits
Metals
Warwick*
POIW Local
Limits
(ag/1)
Upper
Blackstone*
FOOT Local
Limits
(ng/1)
0.69
Cadmium
Chronium
total
Copper
no Limit
no limit
no limit
U.S.EPA*
Categorical.
Limits for
ttetal
Finishers
a
5
d
As of August 1991.
Preculaated in Jun
Minimi
Reported
Local
Limits for
200 POTWS*
(ag/i)
Pronulgated in Jun* 1983, _ ^TT_,m .,„., -ruiv 1991
u s EPA National Pretreatmsnt progran KX-, 'iiai
Proposed changea to POW's NPDES permit, August 1991.
22
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''•' v ' •" .' • ' ';.. "'•.__, ,^'th the'Strides 'that have -teei
1 a^-ac*/- -- "."—3 is tr.at;f ^even n 'urZQ Deduction technical
^=-/ cf ths s ,-':nu reduction tecnica
S:st^/^« .^-•gsLrs.sgsr'
. they
th the o='«f(^|iSf jri, h « schii>g w
have already invested in- *??iS^-i~37ioharge" syatans), nay
SSed-loop recycling .^"^f wfS^SST Sa •JSUuinUhing
less likely .».,»• ^fiS^sanalaSly « i» ooojonotion with the
effluent ,catego2~«iShe= ?SS (««> gui*>"» <*° 51^, „«
312 Local Limits and Pollution Prevention
• -
piogtaffls the ^.-- rerolat. as
a°»
.-
than, categorical standard*, _a°»^Jha pow, its voWcars
u»«» -IfS^op** of developing
iS pretrea^ent program.
23
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to derive' the limits.
eiqnDoruig city's limits or values
information collection activities
include:
o iJ^tiSS?8£filSfiSS! ^stry dat,,
water data, etc.) .
EPA' s Pretreatment inipletentation Raview Team (PIST) Final
Po their NPDBS permit
(i.e., every 5 years).
for^tals "J^JS^Js- Ss tiw low than the national
vMch would coat several million dollars.
i However, -the July. 1991
deri^Ti^s^dCSa^^4r^lSariS^liSnSivtly
fiff^ti \rt-*fj L i Jill W 3 Tfl^^U JU«* »***»^^, ^ ^^ ^ • • _a
\Jt»tJ«vc\^ ^^^n»to*»«* ^» ^ . _^—l M^9«%j4a^nQ
higher than the minnnufli national stanaaraa.
• • . 24
-------
• «.**«. t-hers is rxs guarantee tliat by. singly
point: rs that therejs ^ TO s pollution prevention
iiarsa you ^ P^JLJ ^Slackstons , could meet. their
KTTWs S
, .
^ponse. KTTWs, S^ JitSuS^heting down on -industrial
HPCES.and sludge i^^S ^duStry" to install conventLonAl .
ussrs. or they cculd push -^stry . ^^^^ ^ .^^ the
pretreatment SY3*^^'^^ pollution prevention technical
lower limits are f^£^illth£e be a greater liJcelihood that
' lore
«»
pollution prevention options
v changes, such as "overnight"
. . .
because firms (a) do ^J^°VjT_lJS\hav can nake the limits in
shopping," ?gy^yf£ tesponding to regulatory changes .coupled
3.2 Hass-Baa«a Standardly ^ At« Motivators for Pollution
. Pi«v
-------
POIW Experience With Mass-Sased Limits
~2
to implement them, other^™ However, in many cases, either
ES-S
even /Jj^n^SS^ntaii^ed an
mass-based limitations. . The i!?ih™ohjiits the relaacation of
^anti-backsliding" Prw^?n jf^LtinTpermit is rewritten or
treatment requirements when J" fj^tign^ a concentration-
.
the needed flexibility *J deal wxtn^ Iijait3 as the
dilution of
^i^ipla^ dilution of v^tes. .
S^re^hinking,,- but ^J'^'lhfliSbilSy to choose *nat
l^ortatt-t thing is «> all^jj?^9 ^co^entration^based, or soma
-
-
pollution prevention programs.
; 3.2.2. EPA Experience With Mass-Based Limits
26
-------
. ra rfce-Deveiopnent Document for .Existing Source pretjea^
^r .^^JrtVcqlating Point Source Category (August, 19/9}, E
' ;?^er«ass-based pretreatmsnt standards for the eleft£°P±atlI1<3
gives mass ^7" ^ s olatina arid printed circuit board
category and electro^ spia ring^ ^^^ated frcin conceiitration-
subcategories. T^^?a1^ian plant water usage data for the three
based standards, us-u £ lg .^33 defined to be the liters of
:SSgfeS&»i^»J?e^-si5^
concentration-based limitations."*
s ss saraas.sss3S5S£%«r'
-
.
of nctaTf inishiiig manufacturing
Althouah early consideratijon of a nass-basetf or total
^S^5S>SStf39gS'
2 U.S. EKU 1979, Developnent^ Docunent.. .Electroplating Point
Source Category* pp. 396-406. ; . .•-,--"
3 U.S. EPA. 1983, Developnwvt pccunient... Metal Fiiiishiiig
Point Source-category, p. 1-1* '
-------
to te finalized. ..^^^ <« focused toward
-
compliance.
323 ^..Based v. Coo=entration-Based Li«its
aSs^^3£sr£S«4
28
-------
;, ^r.ed to preclude thepossiUity-of "upset or even .
-£~^£ -oncoopliance". This . "choreography- discounts _ the
„
visited in ^ ^fbrin?Se ^reat^nt process under.
rn .
cyanide (See Appendix A). . .- •
sons of the programs we've contacted have argued that
s
recovery techniques. The counterpunctual disincentive « that
rnncentration-based limits discourage water use reduction.
Sits are easy to measure for ocopliance.
) do not Currently have the capacity to
:flow. This is not to say the technology
flow ffleasurenents have not been necessary and
so few shops take them.
Concefitration-based lijnits. are easier to translate from one
a^S5u£ion to another, to apply across categories. Mass-
POIW. The extent to which
.
dilution factors globally across the system
%*»» the discharge enters the system.
limits are not what nost POIWs, states, or EPA are
To »** theffl ^^^ requiretraining;
Scksliding^provisions of the Clean water Act.
3.2.4- Production-indexed Mass Limits
-------
this difficulty «2*LEL£iSi «' currently permitted. That
maxisum flow and ^^^Sf without indexing to production
approach raises a..concern ^^^^zifft expansion. For example,
level such a permit J^r*0^ iTan^istlng shop without
to add a new nickel Pj-Jtang i^^^s with the POTW, a ccopany
renegotiating the P8^* °jL^ir£13 nickel from other sources
' ft- «- P1-, and
sludge regulations.
-
Turret
^S01^ ^^^^SSof inf SmaSSn tl?Sa!SlaS^r noraalire
for utilizing ^f^SSaSS^a data is now available or .^
mass-based laaa". .^SSSSwr ScludUig job shops. Shops may
calculable for Plating gS^SJ'ooBDBttM aad software to
have In place, ,or ^^f^Sa for any^job (such products are
quickly detenu^ RB22*1SS literature). Lack of data or ease
2idely advertised in the -^Ja1*** an ^npediaBnt: for widespread
re %hat insurmountable.
technical resources fa^e5^oSdtcSerfact6rs key to drag out ..
ara vdlling ^J^S."^^^ iTtMidisUicentiv. to
t
.
to «hy to go to «^^i!-tESd ilSS .provida. Coneantratixjn-
change tlatconcattoj-b^l^ta^^ ^ ^ o£
that
30
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are -the goal. These goals
vnll- •
r to rake.it happen.-;
"
3<2'5
....
Examples of Pollution Prevention Technologies
Fostered by Mass-Based Limits .
•
. Technologies
contaminants
reiv on separating metals or other
rely on M *s exchange, electrolytic
Averse osncsis,
generally fostered by
recovery systens ^J^J^^tT^iolatiJig concentration- t
changes.
bath subatitution/refornulation
lower bath concentraticns
bath nainten
slow withdrawal
fog/spray rinsinqr .
DI vater u» -
racking parta • - ' . '
other dragoufe preventooit
rinsing to neefe spee _^ .*-*.-£-.
conductivity-sensing, flow controls,
preset flow control»
countercurrent rinsing
reactiva rinsing
31
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±raqout return' '(with evaporation)
rxxiuiar & global ion-exchange
Slate-out cells/electrcwiiming
vacuum distillation
electrcdialysis ,-.<„„
in-process cyanide destruction
precipitation _
volume reduction .
filter presses & sludge dryers
3.3 fenforcenent and Compliance Activities Tied to a Strong
Pollution Prevention Message is Key Motivator
& ai-T-oner consistent program of enforcement, coupled with a
rv-«t« into comDliance. While a company tnac is in W,«I%M i™».« «»j
r .
g
SeyonSgwhIt could be achieved with conventional,
end-of-pips responses.
3.3.1 Pollution Prevention Action Often Triggered By
Pending Enforcement
According to both regulators and technical assistance
actions.
c
was found to be combining a water stream from anf^
32
-------
, V~— Vac "Veal assistance provided by the state's
irect -90.ru.cai |sjg^ Cal Assistance (OTA) , the
ncnragulatory °«J«£f ensure slcounter-current rinses, dead
-
' '•• ' iv reoresentatives of the firm had previously
interestingly , re^^tcludiii eggipng
attended, pollution EtfWjntionwMKM S^OT, Neles-Jaafisbury
focused on the;very ***<* ^S~Sere offered, but had chosen
' eveflJuaiSBSplrSf ii-SS .Sl^Uction au
-------
conditions, or 1^}^ ^lief or as "supplemental environmental
either as iW^^JentS £ 3». correction of the ' violation
pro3ects" ( SEPs ). ^f^ga pollution prevention activity is
itself, in P^^j^'f correcting the violation, the •' EPA
presented as the ir^L2LC?geSroliance schedule, especially ; if . .
settlement team^may extend tne ^g^Jgy. In deciding whether to
the remedy involves «novat£J '-^™n£Sr factors Federal
timeline extensions.
'
i
ESS
— ^"^ £ot
sss
by leveraging thft; P2J?2f?fS3rSS ^iTnot done, when this
formal enf orceoent JP^^JJ^SSJS Ordet nay be vnritten
approach goes .as far ^it ^o« cSStance) that will fold in the
towaidTtull •..
of
34
-------
- for 'innovative tecfcnqloqies ,
-^-r-clc^es. -Jf Q -ghli-hnologies or systems. Parser
bur also for sore °":t^^;tr1.^anufadturer *e visited, had
.ue-ls, 'a Massachusetts ^^ j^^ating (requires highly'
decided to. -switch fr^^etT2liS zinc- plating. Although the
^toxic cyanide «olutJ2J> *? tSlSSSrward-lor so it was promoted
change-over seeded L^ and Svironnfintal consultant enployed at -.
by' the .equipment vendor and env^onm^ ^ f theplat'^g
.that t:une--Parker tou^JL1 ^^ affected the perforaance of
line ^ u«Preda?tf5i!1^S systems . They found that it took at
their wastewater "ff^Jerstand the chemistries to keep the •
least 4 years^to ^^"Sere^ined by EPA Pegion I for not having.
the ^""^•Jggn nnfaiar process
™ a
0
associated with ^ nonconpliance.
!: ; 3:3.3> Pollution prevention In Eiiforcea^t Actons
^^^^^^1^
orders
Atlantic State,
choie to pay the, fane *«* ««J ^Sl?Se^later chose a reduction
pollution P^^0"^^?^;! ??dVTpbllution prevention
35
-------
^
Hayes', the- ASLF lawyer, said g^^^i^^ir product line.
do not like outside ^^^J^t requirements on how they
They do not ndnd so ch j£you put^equ ^ ^^^ ^ say
our product." .
M also t»-«-f-ji*S«'1j
pollution. prevent^. .S^3.JSpr5SUion, that vaa.in
a
&3Sfe
could get. . • ; •
'. • 3.3.4 la^rtanc* of Agency Opanness TO Pollution
nmauan+'ian: • • .
prevention:
i,
« i, ^CM ^^iJ^r^^^iS
4 The 1989 GftO Iteportr rPP^>1 ^^i^89.101)
H for Torlr ^^^J^^aS^nn •V^^- that POIWs are
-------
-, .«* both their close worJcing 'relationship with -their '.
•position -to JS® bo^.r2er;Hc:ieir .role-as radiators /enforcers, to
"front-line," EOTWJ ^g^J^gg. paws are also in the .unique
•their Processes .and ^S^aSBSg* and developing training and
position : of sharing 0^JSforthe ir service areas. POIWS .
technical ^^^ifS^titieTand unless their regulators (EPA-
themselves ^ VSe^uroSiv^f > pollution -prevention, the PCIW
X? rin^IfKrd'S gSSSTth. &d of quality pollution
veSfofro^a^tie? are in the, position to do, - ,
rn 1989 EPA and the Department of : justice began an .aajor
cannot happen overnight
• ,_ __ .m-Lrti- /
-------
vas seriously out of cotrpliance on
3.3.5 inspectors Can Play A Key Role
Oam. ff'Sg.o. «**
handout ot ^s^1""- «w« technical assistance v****"?^' ir_
sSiSS^sr^^^^SHSSs*
1988. With grant suP^r^._l5«rtfld a series of nultimaooa
n«-Ai«»«+•"ion. ill 1990 DBr UTJJ!%*«*• __,_ ^.+ anATvrv and ^/iW lieifl Stati.
SatwaaSSauartss
s .saa
= .
s
Coordinating «tat» ^^igji STS^artaltB pollution
» — ——•
38
-------
a" •• -earn inspectors .went into sone '30 facilities—the vast
"7 -v "were 'plating or metal finishing shops.. BlacJcstone fie
°^ Identified specific source reduction opportunities at 16
^
Of those JJe reduction (.20 because of enforcement
3 facilities with no enforcement motivator)
3~3~.6 . Example of POIW Implementation- of New Metal
Reduction Ordinance
The three manor opportunities that a -regulating agency has to
influence behavior towards pollution prevention are, •
-------
The pilot program was developed to
tS sW-Ti*its.
The pilot program has proven successful based on the
following accccpli^hfflents:
. publication of ii^fonnational newsletter and other, educational
materials
. Public .workshops to explain the need for. silver reductions
and conpliance methods
'
schedule regular pickups ,
Established" drop-off facility for silver-bearing photo-
chemicals from households
•
permits
of
.
regulation .
. successful lobbying of tha stat«^«*»ly « ctang. the staf
law regulating photcprocessing. wastes
.
NPDES permit.
40
-------
34 gcoacmic Factors: For Metalfiaisfaers Hav« The
To Be -Key'Motivators, But There. Are Significant Barriers
.heavy
silver and gold
covers the electroplating of 'various j^*»?
cadmium, copper, -chromium, 'nickel, zinc, lead,
caami 4o^"nBtai.^Urfa<* preparation and
The electroplating
ssasc^
^IryindStry, to shops associated with
facilities, both large, and small.
function of the following variables :« .
Reduced raw material. costs
, Value oi recovered material
Reuse potential of vater •
value of recovered material
of sewer fees . • _
of hazardous waste disposal costs
Reduction of liability-related costs
Although many source reduction
caoital ^westBBht f several resource recovery, reuse,, recycling,
: : 5 i one-mari shoo in Rhode Island specializes in silver platiiig
histbrical^Sces'fol mu^eu^(e.g., thranithsonian); everything
is done by hand using two small ..batch-process tanks,.
>p incentive* Analysis,
41
-------
to nurchase and install.7
management technologies),_whi Uution prevention technologies
dollars, even the nigner-priwsu.t~
can seem attractive. .
nractices and single process modifications,
such as countercurrent ^^f^ ?nvestnfint. They nay hcvrever,
n of '
e
toring of ^' *?*£*£?%> SS^lTwin7 s cussed
smaller) ccopanies .may not ^JSinas^ndicate that, for metal
-ESFaSS
a decision to
'iotly econc-*
3'4'1 ^ISSnTiSSva^
,_ ^*,*«» ar-o manv docufflsne exanples of profitable
Although there are "W^^SSSjJSTli metal finishing
pollution Preventic« ^t^t^ u^rtaKen ^ £ijjd ^ t
u*aa
not arrived at by a S^fu*a^aiSSlpally 5 jultify th* capital
th© envelopa" .calcula^n^ doM P™Jxg^ ^dy decide to do
expenditure (i-.e-i^ ?^J?l^iS^engii»er, they installed the
expen -.-i^ iengii»er, e
7 California DHS,
May 1988, p. 14
-------
*ound that: nest o^anies seemed less liXsiy w/isp
than to maintain 'the status quo, even
-
on conpliancst ^ ^ ^^ ^ r.iativ«ly
i^^^^^
S^glSSS by its POIW SWiOuto. "^S1"!?^^^
••safe asins'SiWs .
dSaSd a^oolSnoi^lan within 30 days. Tha plan had to. tollew
tS^3fe?«?«iteiaSag8nBnt hierarchy and explore the
a« a bit unreaJ.iatic for.a
for a mere 512K cap
six nooth*, the effluent was In conpliance with
^^hfS^^t^^Se^
tnr"Trt™a Analysis. Oct. 1988, p.. '111-38
9 Recovery technologies, unless they
hard-piped, c2* mate a facility subject to RCRA TSD
ao Additional detail provided herft. is f rcmRosenblun.and -
Naser, -Heavy Metalsi waste Minimizations Practice and Pittaiis,
in twiner £*&>.*?*** Finishing. April 1991.
"/.'. ' ". • • '43 • • ' • -• • ' ' -
-------
4-na 250 qal./min. wastawater
new, tut TO"Y^S^o4t of 51 million. Management
nt at ™£^£££* ^** **?<*£ S^I
faster.
342 Lade of Capital is Barrier for Many Platers
SSusa of tight cMh 1t
environmental issues,
ffiSS'cSL5S?Sgg£5 gStSRfiW-^-
considered by tl» industry. identified
. . aaassttsst?^^?2SSr— -
i
O«t ]_ V-1 Iftiii-g J«^ ^*^«—— « fl*»A I M 'Jig jJiT\V pJ.nrTTlr iw*r **"*^ • JT _^_
points out
§§^^SnS^?S^
* l» *«• *«* «"*
Cal. DBS, May 1991. • ^
-------
. ,' '•• • • -. ' . . •,,n.vU2 i=r not. usually 'ah. effective tool
**
Requiring or even suggesting ^^disincentive-many firm «r» .
pollution P^^tion may_act as a such accounting if not otherwise
Sluctant to;go to. the '»^mng potential -liabilities nay pcse
rsquired.. h
-------
, . . , , TV~. nooe^arilv make a continuum of impact,
-cr.--ir.ual scale will not ^gJ^&Sholds which cause action.
r.owever; it is usefulto idem: JJY J"^ for example, uses a
The CraMton, R.I., rtiona! to the flow-based sev^r
p
industrial user fe?h^e\!hich is related to the highest
use fee plus a sur^h J2ebSling year ) of netals, cyanide and TTO.
concentration (^l^^$£% releases of certain pollutants, it
While this does ^£|f nation response, per se. Ccopanies
doesn ' t force a P^u^e ooeration of their end^»f -pipe
ee?Seir n^ers (a«d fees) d
addresses the ^» °* SLKsrgua that because POWs
costs of environ^ntalpollutio^^oDB ^u ^ ^^^ f
in this country. ^Bg2JrSSaSSSi aaoimt. to! a public, subsidy
their treataent^of . iBdus-triai ^J^^ perhaps, economc .
of industrial activity. "?®t,Sn;J5S/etc., narlc a brealc with
^hanisns such as^fee^ ^u^tc^ScuSni standaids-based
the more co^r^fS?SSa^n^coSt of environmental protection for
Can Promote- Pollution prevention
3M IT i imm Til ^^nTBTTTW 0 V D «»^BB^V ^^iB^A
.9
Barriers
waterways or "^"^.li^ii SSU4 not S te considered pure
status rauains in S^S^Srrent iSsl °t narket and technology
every
"Tfiro1* diacharge> systeais
««*s« disdiE iSudin?3SiSriodiiSas=i, «=*•
^aL^^S^^^^5-811— fiS>2
over the last decade
.46
-------
sometimes . chemical ^^^"r^, throuah the treatment steps are
ahd other .<^*aSS^^5iS«5 off site'either
.a
.
Indiana* • .. . •••-•..-. . • •,'•-...'' • '•"•"
3.5.1 zero-Discharge and Pollution Prevention
in order to successfully inclement a closed-loop system ; a ,. •
olatina Soo usually -mat. reduce^ water use throughout th» plant.
?on SIhaSgl, rev^L osaosis and ultraf iltration ahara th* .
H?«i-Tnetion of becomiiw nueh aora expensive to mplenent as th»
,,^4 «,+. S^»T fiow»^ Once sucb a system is installed, operating^
•S2t?LrSr markedly S£ SS cost* «« end-of-pipe pretreatnent
1^3n^yand p^d^quality usually proves from better, vater
quality control '
For esanple, i» the case of the Robbins; CcopMy of Attlefcoro,
capital and $120^000 » year to run-XThe
§30,000 a fl
$71,000 per year in operating costs even:
spend on^he old under-sized system, and Kc
ISnge ha» teen directly paid.baclt ingles * ^
also^he Fernanda case study ui Append« A and the
case study- in AppendiacB.y
47
-------
- '" fc>,e poiw's perspective, not only are even trace amounts
~* -'a^ retail eliminated from the plant's influent but also the
SAsl^'v of interference- or pass-through due to an upset from such
JI-oTis elSXISL Sane authorities have required that drains
or sILf connections be cemented over to guarantee this advantage.
instead of costly periodic monitoring for metals the authority
makes an annual site visit to assure continued compliance with a
"zero discharge permit" — a permit to operate in the authority s
jurisdiction without discharge, except for domestic water uses.
3.5.2 Regulatory Barriers to Zero-Discharge
3.5.2*1-
In response to the installation of . substandard systems in
Rhode Island, the Rhode island Department of Environmental
Management. (RI DEM) raised questions of the legality of zero
discharge systems with the USEPA Office of Solid Waste. If ; for
example, a plating shop no longer has a wastewater discharge, then
the water treatment steps- which allow reuse of the water in the
shop may no longer fit the RCRA exemption for hard-pipedprocesses
of wastewater treatment systems. This is the tack RI DEM -as
taken, requiring RCRA Part ,B permits for such systems unless they
also have no air discharge. .
3.5.2.2 F^ili1^ Out of Regulatory Loop
Some officials have expressed discomfort with the idea that
no permit would be needed for such a system and that they would
havelittle oversight authority. Some POTWs make annual
inspections of plants certifying that they have no process.
discharge. In the San Francisco Bay area the East Bay Municipal
utilities District requires facility planning to reduce hazardous
materials use — unles* the metal finisher converts to a zero
discharge system, in which case the requirement so longer applies.
Air emissions are usually "nonmajor" (see next section), and solid
wastes may go to exempted refiners and recyclers rather thaiv to
RCRA TSDE*, so thatTstate authorities may become uncomfortable
with their ostensible lack of control of a potentially risky
process. . ' ," . ' . '. • -'. • • •
3.5.2.3 ptpgfliblQ gross-Media Impacts— Air
As mentioned -above, the atmospheric evaporators of ten used in
zero wet discharge 'system* may be misapplied, with the argument
that the only air release is steam, the air discharge from the
system may be uncontrolled* without even a mist eliminator*. The
air streams are rarely tested to verify that no metals (or .
chlorides, or ammonia) are carried over. ** ^^f* case'
emissions tests have detected no organics—the release is
48
-------
• • _ _ .« ' ' nn t-he other hand/ RI DEM officials "
'32 -t^jr*
3524 g»I" Mr Apd Water Discharge
V*1-LJ~LW*' T~i^r.ji. •>«,* r»Tjrrt-*»r 1990 Research Newsj.ecwz> .u* «
!£!£?£ iSs2^2S^ST^S.^th Bl^ttoucluologiB.."
These system* nave two major drawbaclcst (1) high capital
yatltT I 1 ar^ TT-iii^l I ^<^%^*O
orSblems, especially with the vacuum pumps. ..^L^?^
pI-Zi«S h«*h«« durability and the ease of maintenance,
1^3TT?^^m^^d^«^«^a'i«» to the cost and east
reputation remamsv «*»*
atmospheric evaporatMii
35 3 • Technical/informational Barriess Associated
* , . with Zero Discharge
49
-------
...
T^usands of ^llars. Unless they^^u^ ^ install, even
f—d hydroxide PreciptJS larle sludge disposal costs over tine.
wwa * •
one or two metals, PluV^^able tecausi they will shut down
maintenance. Upsets ^.^^^h tte treatment system supplies
the whole plating CP6?*^ Sundown the ijnpure water may cause
SSUr; if the ^^^^^LfSaW ordelays. word of the
very costly parts daaaf*' !£iSed^olutions traveled fast, so that
.
reuse may IcoJc. lite, an "2S2f5ttS " company as a managemsnt
n tha Bd*in» CMS, e early in his
siss^rsis? s
without organized
3.5.4 problem* With Vendors
or
tha «ater
i
sasrfe^J^-^SS2'sff«iffl2s?
.
50
-------
. *.
seems to have 'been a particular problem for' one hub of national
electtcSlating activity, the Providence, R.I., ^-fc*»«' the
JrcSS £512 irore widespread than has been detected by most . .
regulatory agencies. ••';•• % •'-;••. , •- .
the treatment technologies may distract
lLfications. From the plater's .point of
POW's), this; is recycling, not source ^
some source reduction nay be done to cut
the treatment technologies .similarly diverts .
capital from doing a better job running the rest of
shop ncdifying rinses, identifying .new =^^'ruP£f:£g ,
lines, or proving product quality. Peters wouldrather be _
plS?lrs than^waste theaters or metal recoverers. Once the system
is in place people may have a disincentive for further reduction.
One source of unqualified vendors may be people who have some
'F£'£M™<2$
thJe inSSSSs may Ignore
te
Requlators have expressed concern that cross-media
are dlten ignored b?both vendors and facilities seeking
to, install such systems.
: 3 6 Flexibility in the Regulatory Het*»rk; Supportive
* Technical Assistance and Outreach; and Collaborative
Relationships Overall May Be Best Way To Foster lx»g-
Tetm Pollution Prevention
3>6.1 need For Open Dialogue .
There must be room in the regulatory network ^or^opei
dialogue on pollution prevention. For example, a *™*™
encouraged) to discuss questions of permitti
ith theiTstate or Regional office regulators
aborvereaon o
regulatory agencies should >»rk to promote the free exchange of
information. ~. •' '. " ,
There i is a complex of stakeholders
ii^ and Dretreatmeht. Among these stakeholders some
eionlniS nSy^rSnSy be characterized by mistrust^or fear-
f or exampleV between some pretreatment program nenagersand some
corEanybfficials, or between some POOW officials and some^state
Srfederal officiks. One problem this gives rise to is an
SnwillSgneS to innovate and a lack of support, of . innovation,
aSgwiSl crossed coiraunications and ineffective jmt^tives.
innovation and effective conminication are at the heart of
pollution prevention. .. "
51
-------
=
Sr™
leSS« JhSS^JTrS fo/open conminication among players,
process there as room *"*• "£•"-• objectives and development of .
Specially ^^^<^^%rSS;levSws of e2Stion of
- -
inclement the guidelines. , .
or loans, to allow^PeoPi;f*?4^cv—£rom brown bag lunches
counterparts operate; «»SJgn^tJ^5«i statements of support
o
ffiJS^iS1SSK?^«5SiSS
52
-------
3.6.2 Technical/Informational Channels Are Inportant
- ' External (non-EPA) technical and information channels fulfill
a vital- role in providing technical assistance to platers and to
regulatory personnel? outreach has had varied success in
different areas to date, but there is a need for better diffusion.
The electroplating industry is a relatively heterogeneous
industry; however, source, reduction, recycling, recovery and reuse
technologies are largely available on the market (a few
technologies are still emerging). Therefore, basic technology
development is not as important as technology diffusion. There is
clearly a role, for vendors and trade/industry associations to
educate platers and metalfinishers about the range of technical
options that are currently available. v
Outreach programs by government agencies, trade and
professional associations have been effective in some cases in
meeting the technical and informational needs of industrial users;
diffusion may still be inadequate. That is, there is plenty of
good information out there for the fundamentals of plating & metal
finishing pollution prevention, but (a) there is probably much
more, good information that is not finding its way into the trade
literature, (b) there are more sophisticated questions that have
not been answered, and (c) some people still haven't heard the
basic message in a way they understood and thus were willing to
act. - .''/', '-".' •- " •-" \ / - - • .<•;•• '
Regulatory agencies at,the local, state, and federal level
need more technical, support to understand the myriad pollution
prevention options open to manufacturers at the process level.
Although it is not necessary (or perhaps possible) for every
permit writer or inspector to understand every process in every
industry, it is important that they have access to reliable
information so that they become comfortable allowing process
innovations as well as, end-of-pipe controls. .
3.6.3 Collaborative Relationships
Experience in the San Francisco Bay and elsewhere has shown
that industrial .pretreatment programs are particularly well suited
to promote pollution prevention to their service area industries.
They provide the single closest working 'relationship between
industries and ah environmental regulatory authority. PCTWs have
institutional frameworks in place to promote pollution prevention.
Many K>TWs are increasingly using their .permitting, .inspection,
and engineering systems to diffuse source reduction and other
pollution prevention options to, not only industrial, dischargers
53
-------
but also contrercial establishments (e.g., Palo Alto POIW targeting
silver reduction at photo finishing establishments).
Through the pretreatment program's permitting, aj^f«-£^
ction and sampling activities, pretreatment staff can become
Sith an^dustry's production process. They are then in
Ssition .to promote pollution prevention through
f orS? oSSach (e.g., by the inspection . staff ), .technology
transfer and diffusion (e.g., by the engineering staff),, and
systems design guidance (by both permitting and engineering
Sf IT. Becausi of the recurring presence of pretreatment staff
^industrial facilities and their environmental concerns,
S; ol FoiSSon prevention tasks into pretreatment
is evident. Furthermore, the focus of pollution
provides a level of complexity and interest to the
nob which could be lost under the more superficial
required under the General Pretreatment Regulations
At a recent EPA conference on pollution prevention, JDr.
Philips (ofthe Sanitation Districts of los. Angeles County
califdrnia summarized the ^*^*^ ,^^* .*?*^*
relaSveto pollution prevention technology and information
rSullling^hl Scili^ under the Clean water Act. POOWs have
trldiSo^lTasked fS detailed piping plans and Process flow
olSSms forYpermit applications, and these^anscan form the
and benefiting the overall environment. «
13 Philip Lo, "Pollution preventions A Winning Proposition
For A > . . _
Pol, lotion Prevention; Cl
Washington, DC, June 10-13, 1990.
54
-------
CASE EXAMPLE OF SUCCESSFUL IOTBt2«IIOH OF POLLUTION
PREVENTION MOTIVATORS
oresent here a fairly detailed case examples of where
S3£i
SS£ calixolnia? ,^32 goal ifto present an integrated
tow both the array of potential, factors and the key
£ve played themselves out in the -real world."
4.1 Background: Regional Water .Quality Control Board
^ ' i "
An excellent model for requiring the inclusion of pollution
prevei^ion^iSatSS in local POTW pretreatment programs is .
ErovSed bylSe experience of the California ^^."f^ ^
oSlitv Control Board (RWQCB) - San Francisco Bay Region. The San
^cSco^^ioMlBoard^Sreartet referred to as the Regional.
SSdTS oSoHine regional boards «hich,i* con^unctaon wxth
the state Water Resources Control Board (WRCB), manage
calif oraL'^teTresources, and are delegated to admunster the
Federal water pollution control laws.
The leverage for requiring pollution prevention activities in
communities of Palo
oyvaln San Jose/Santa Clara. These
?he elwironmentally sensitive southern portion of San Francisco
Bay. ..'".. • , • •..-.. .
for the protection of South San Francisco Bay's
isTrbvidea in the water Quality Control Plan for
Francisco Bay Basin (the Basin Plan), which *s the
orograk of lotions to meet both state and federal
e and enhance the region's water resources.
ally prohibits the discharge of wastewater
Bay; Sd establishes other.prova.ons for
s
protecting the bay which were not being met by the three
wastewater treatment plants
in 1981, the South Bay Dischargers Authority J^^>v5 joint:
s acaencv involving the communities served by the three
walS^ea^n^^Icilities, obtained a ^^S SsS8 T^
Plan prohibitions on grounds of excessive associated costs. A
nuntoer of water quality studies and reclamation projects were
required of SBDA in granting the deferral.
Continuing concern over heavy metal concentrations in the
aroS TfrcS these plants, however, led to the inclusion of
retirements in their amended NPDES permits in
55
-------
s
other means
4.2 Approach to implementing NFDES Waste Minimization
Provisions
in a phased approach, the' Regional Board first
minimization efforts.
4.3 FOTW Data Findings
The mass balance studies evaluated heavy. ^^9^^^°^
.
lor extrene values resulting from spoils, etc.).
Industrial -Sources?
56
-------
Palo Alto - significant source of nickel,, cyanide, copper, lead
and silver ' . • . ':. . •'
San Jose - copper and lead; significant source of arsenic,
cadmium, chromium, nickel and cyanide
Sunnyvale '- significant source of lead, cadmium, chromium, copper,
nickel and silver
Water Supply Systems:
Palo Alto - significant zinc source (most of the comnercial
sector); copper and nickel loads were relatively low
(approximately 5% of total POTW load).
Sap Jose - arsenic, cadmium/ mercury, zinc, and cyanide;
significant copper load. , • " ;
Sunnyvale - arsenic, cadmium, chromium, mercury and most
significantly zinc, which is added as. a corrosion inhibitor.
Commercial Sources:'
Palo Alto - significant source of silver, lead, zinc and to a
lesser degree, copper and cyanide (approximately 20% of total POTW
load)..
San Jose -. nickel and silver; significant source of cadmium,
copper, lead, mercury, selenium and cyanide.
Sunnyvale - significant source of nickel, silver, cadmium and
lead. . - / ' - .;. : • ' • ".-.,•"•,.
Residential Sources: ..
Palo Alto - significant source of copperi«, lead and zinc; some
nickel and silver noted (approximately 5% of total ,POTW load).
San Jose - selenium; significant source of copper, silver, zinc,
and cyanide. .; - .
Sunnyvale - significant source of copper, lead, arsenic and
silver..
14 The copper came largely from the copper sulfate root
control agents many households pat down drains to kill tree roots
that invade pipes and cause plumbing backups; 20% of the copper
entering the.Palo Alto treatment plant was estimated to come from
this source. - •
. '"• •" 57
-------
as summarized below:
POTW
Palo Alto
San Jose/Santa Clara
Sunnyvale
Targeted Metals
Silver
Targeted
Lead, Copper,
Nickel
__ srcial and industrial
photoprocessors , X-Ray
labs and other
potentially inportant
sources
_ _
Radiator repair, auto
" — • — cleaning shops and
potentially
source •
««.-. Finishers,
slectropiaters and other
aotentially inportant
sources .
44 Regional Board Follow-up
programs:
Be tailored to address the targeted industrial sector(s)
. .
Include public education
Coordinate efforts with the county toxics program to provide
technical assistance to targeted f iras
o
o
o
o
' applicants.
o coordinate program development and share, findings
58
-------
Based on the' success of its waste .minimization requirements,
al Beard has developed similar pretreatment and waste
on re^uireLnts undet the Mass Emissions Strategy (MES),
for Sithe State; Water Resources control Board's,
Policy Socunent for the San Francisco Bay-Delta. The
S tS Regional. Board to develop limitations on the mass
e of tSiclollutants to reduce the overall quantity, of
toxic emissions into the Region's watersheds.
The Regional Board's waste minimization program aims to
eliminate the discharge into water of toxic wastes from
manufacturing processes, commercial facilities, and .the coraminity
at larqe Waste minimization requirements similar to those
established for SBDA would be* instituted for POTWs as well as
direct industrial dischargers in the San Btancisco Bay region.
Public outreach and educational programs would also be an
important component of the Regional .Board's waste mirumization
program. '
4.5 POTW Follow-up
Differences in service area characteristics/ legal ..
authorities, administrative priorities and other^factors unique to
e^h areTare reflected in the approaches adopted byeach of the
POTWs. Based on their experience and findings in meeting the .
waste minimization requirements, the SBDA cities-have initiated
tne following significant changes to their pretreatment programs:
Palo Alto:
Sewer Use ordinance Revision - waste minimization audits
required for permit issuance and following industry discharge
violations
waste Minimization Study (WMS) Review Process - Industries
identified as being "major contributors" of. heavy metals are
reqSSeS to sutait a WS report to.the.POTW. The WS review
process involves the active participation of the POTW, the .
POTW's consultant for the waste minimization program, and tne
industry. Eollowing Wffi acceptance by. the POTW, Jdie_
discharger oust conform to the plan of action and schedule.
progress reports and Notices of Completion may also be
required.
Waste Minimization Program Status Report - these reports
document program accomplishments and procedures as they
develop. '• ; / •
Silver Reduction Pilot Program - *his program couples
publicity and education with waste collection services and
59
-------
waste haulers have been
Mass
net decreases in P°1?O!2 enalizing facilities
•
San JOGO:
o
discharge violations
industrial users
protection.
requires facility managers to^|eh^|nj*circuinwent a
after the first vj£1*5152l«r 25k and tiae loss associated
considerable amount 9fPy^A::iraiBnts On penalties and
with discharge violations. AgreemBn^o^ resulting in
to
Sunnyvale
0
waste
minimization
industry discharge
s
Ordinance was
Three of.
completed audits to
60
-------
• date- it is expected that'the remainder will be completed
' within three years tine. The waste .minimization audits are
^conducted either by/industry personnel or by outsode
consultants• . • / •
o Detailed Facility Inspections - these include a detailed
review of industrial processes and material storage and
handling procedures aimed at promoting pollution prevention.
* * '•" ** • " - .
4.6 Relevance to Incentives Study
The Regional Board *s: experience provides a. successful example
of state imposition of pollution prevention requirements through
local bretreatment programs. The difference in unplementation of
the three SBDA pretreatment programs demonstrates the latitude
provided in the 'Regional Board's approach. Differences in^seryice
area characteristics, legal authorities, administrative priorities
and other factors unique to each area are effectively.
^or^tcomponents of the Regional Board's pretreatment program
regulatory approach can be summarized as follows:
o Establishment of a close working relationship with the local
prctreatment authorities - this has facilitated mutual
understanding and the development of a logical, iterative
approach to developing waste minimization, strategies
o Emphasis on monitoring and inspections - accurate and
frequent sampling, pollutant data tracking and detailed,
frequent facility inspections a concerted effort to
determine:the source and fate of the toxic pollutants
entering the system. ,
o Effective enforcement - require POTW enforcement response
v plans; set goal of 100% compliance? potential Regional Board
enforcement against industries
o Stringent effluent limits - Setting high water quality
objectives justifies the initiation of pollution prevention
: activities .
o Adequate legal authority - the combined authority of the
State administered NPDES requirements and the local Sewer Use
Ordinances are adequate to establish pollution prevention
requirements under the pretreatment program
Further evidenceof the Regional Board's success in
administering the pretreatment program is that Sunnyvale was
61
-------
awarded EPA's National Pretreatment Award for 1991 and other Eay
Area pretreatment programs have won the award, in previous years.
By encouraging information sharing between local pretreatment
programs and recognizing program accomplishments, the Regional
Board has generated a healthy competitiveness between the local
programs. A'number of other pretreatment programs in the San
Francisco Bay area have now adopted pollution prevention
activities on their own initiative (e.g. East Bay Municipal
Utilities District, Union Sanitary District, and the.Cities of San
Francisco, Hayward, Benicia, San Leandro).
62
-------
REFERENCES
n Thomas S., revaluation of the DHS Waste Audit Study ,
: California Department of Health Services. May 1991
Brown , Gardner and Ralph Johnson, The Efflueni- qfrnfr.- ffiyffiH In .
the Federal Republic of Gei-many; An Example of the Economic
incentive Based Approach to Abating Water Pollution. 1983.
Gallfornia Department of Health Services, waste Reduction for
Metal- Fiiijaherai Fact Sheet. Toxic Substances Control
Program, 1989. .
.California Department of Health Services, Hazardous
Reduction Checklist and Assessment Manual for the Metal-
. . Finishing industry. Toxic Substances Control Program, May
' ' ' '
California Department of Health Services, waste Aud4,t Si^gy»_
Metal FJ "Ashing iixiustry. Toxic Substances Control Program,
May 1988. .
Chen, Donna and Deborah Hanlon, fr^? M]9??Qg city's Expanded
industrial waate Pretreatment Program and Hazardous Waste
* Management Survey Results. 1991. . . .
Cleary , : Edward J. , "Managing Water Resources : Lessons for the
u.s..'' in Urban innovations Abroad. Feb. 1983. • - •
Coomonwealth of Massachusetts, FY 90 Report on the
pro-iect. Departaent of Environmantal Protection and
Department of Environmental Management, JUly 23, 1990
Dillon, Patricia S., Pizzolongo, Peter J. and Gerald JV Fttbin,
Environmental Manaoement Practcest •
Processes and Performange Measurement. U.S. ^
- university Center for Environmental Manageir^nt, Workshop
Proceedings, July 17, 1990.
Fromm; Carl H. and David Butler, Practical Guidelines for
Estimating the Profitability of waste Minimization Measures .
Gireiner, Timothy J.. closed-Looped V***'* vanishing Processes.
Massachusetts Department of Environmental Management, April
•• •. 1990.- , -;. • .' , •":-./•;''.•.'•/• •• ' '•
Jones, Lewis S., Chapman, Nancy Jo and John F. Grittin, VSoux
Control Program for waste Minimization at Metal Finishing
Facilities," East Bay Municipal Utility District
(California)v paper presented at the KA+* annual
63
-------
poiltition cont-ml Federation Conference, Oct. 6-10, 1991,
Toronto, Canada.
Lo, Philip, "Pollution Prevention: . A
row," los Angeles County Sanitation D:
at international conferee
13, 1990, Washington, DC
_
and ClAan Products. June 10-
of Environmental Protection, Pegiqn 9f
«"«^
.
Analysis^ Final Report Oct. 21,
ylnishina. April 1991
Govent uxsaxou,
CA, Dec. 1988.
united States Envixonnehtal
on the NatJ9nal
. July
July 24, 1990.
Preventions -,
EPA/625/7-90/006, July 1990
United States Environmental
jn re*al Par*-? TVawq-
united States Environmental protection Agency,
... j_. /•*_*.** o«.<*«4naa f\f MimJTHzaTlJ
83/091, June 1983.
1982. ' . .
64
-------
United States General, Accounting Office;-Serious Problems Confront
Enlarging Municipal Sludge Management Program..GAO/RCED-91-
'154., July 1991. ' : .';:;• • . ' ' ,' ;
United States General Accounting Office, Improved Monitoring and
Enforcement Needed for Toxic•Pollutants Entering Sewers,
GAQ/RCED-89-101, April 1989.
Walton, c.w., sillier, A.C. and G.L. Poppe, "Process Options for
Waste Minimization and Metal Recovery for the Metal Finishing
Industry," paper presented at international Conference on
Pollution Prevention; Clean Technologies and Clean Products.
June 10-13, 1990, Washington, DC. <
65
-------
APPENDICES
66
-------
Appendix A:
Site Visits
Below is a matrix of site visits conducted by Kerr & ,
fir the Incentives Project, in June and July, 1991,
the matrix are exerpts from our site visit memos to EPA
of July 2 and Aug. 22, 1991.
Facility
Allied
Manufacturing
Fernando Originals
Neles-Jaraesbury
New England
Plating
Location
Auburn, MA
Providence,
RI •'•••.
Worcester,
MA
Parker Metals
Seville Dyeing Co,
Worcester,
MA
Metalwork;
mirror
finish
machining
Jewelry
design and
manufacture.
Valve
manufacturer
Worcester,
MA
Zinc
plating;
some chrome
plating
POTW
Cranston water
Control Facility
Upper. Blacks-tone .
Water Pollution
Abatement District
Warwick Sewer
Authority
woonsocket,
RI •
Location
Manufactures
nails,
screws,
shopping
carts .
Textile
manufacturer
Cranston, RI
Auburn, MA
Warwick, RI
Size
23 MGD
35 MGD
3.. 5 MGD
Comments
Medium-size job
shop? ho
plating lines
Medium-size
captive shop;
precious metal
plating
Large captive
.shop; tumbling,
phosphating and
plating lines
Large job shop;
direct
discharger
Large captive
shop; switched
to alkaline
zinc plating
No plating;
reduced COD
loadings
Fee system for
users indexed
to toxics
loadings
Multimedia
inspections
with MA PEP/DEM
Strict local
limits;
promotes zero
discharge
-------
Allied Manufacturing
Auburn, MA
Allied does mirror-finish machining for several customers.
They have installed recovery systems for most of the coolants that
they use to machine and grind parts. Some metalworking companies
discharge such waste streams, laden with FOG and metals, to POTWs;
others ship off substantial quantities as hazardous waste. Allied
uses filters and centrifuges to remove metal chips and tramp oils,
and then makes up the evaporative or dragout losses with water and
coolant concentrate. They have found that by maintaining the
coolant, rather than allowing it to become more and more
contaminated until it must be discarded, they, improve the quality
of the machining process and eliminate scratches .which would
require rework.
The company chose to install the recovery systems, to save on
waste disposal and fresh coolant costs. They estimated that their
investment would pay back in about three years, and they believe
that it has—perhaps in even less time because the coolant has
lasted much longer than they expected. They did not do a rigorous
economic analysis, nor will they; they had sufficient information
to make their decision and they have been pleased with the
outcome. One possible hypothesis would be that rough estimates to
.justify capital expenditures are typical not only of small- to
mid-sized firms but also of some larger firms.
Fernando Originals
Providence, RI
A subsidiary of Erwin Pearl, Fernando Originals designs and
manufactures costume jewelry for department stores and other
upscale outlets. They have received an award from the Office of
Water for their zero discharge wastewater treatment system.
Recently they applied to the Narragansett Bay Commission (their
POTW) for a "zero discharge permit" and have not yet had a
response. Both new to this company, Michael Weinergast and Abel
Santos believed the zero discharge system had been installed to
cut water costs and to reduce the impact that changing regulations
have on cost. .
In answer to our question as to whether, as a jewelry
manufacturer, they would be more insulated from recession than the
job shops we had seen, they said that they.have a much larger
profit margin with more value added. .In the first place, costume
jewelry tends to- be somewhat reces.s ion-proof. Secondly, they take
a product from concept or sample, .through manufacturing and
plating. If costs associated with plating go up they have many
more business areas 6ver which to distribute the cost than would a
job shop. Plating actually represents less of the cost of the
. part than does design and tooling.
-------
Neles-Jamesbury '.,-.. '
Worcester, MA ".• r '' ; ". ' - •• :
Neles-Jamesbury manufactures valves. for industrial and '
commercial' use. We examined the; tumbling and phosphating lines
.and spoke with Paul Sonier. The company had been taking advantage
of a -categorical designation for a defunct air pollution abatement"
system (a wet rotoclone) which used water to capture airborne
metals from a grinding operation to dilute their categorical metal
coating waste stream. During a multimedia inspection, the MA
Department of. Environmental Protection and Upper Blackstone Water
Pollution Abatement District (UBWPAD) personnel discovered this
practice and deemed it unacceptable. UBWPAD required that they
drop the metal and FOG loadings from the isolated metal finishing
waste stream, which would otherwise have been in violation of the
categorical standard for zinc and the FOG limit. Jamesbury chose
to use pollution prevention to come into compliance, with strong
encouragement from the state and-the POTW and with specific how-to
information provided by the Mass. OTA.
The firm had previously used an ion exchange system to polish
the metal finishing waste stream before combining it with the
rotoclone stream; prior to-the inspection they had disconnected
the system without notifying the POTW because of difficulty
maintaining it. They chose to implement pollution prevention
options (counter-current rinsing, dead rinses, reactive rinsing,
and flow controls) rather than to reinstall the resin columns.
One management adjustment that they made was to raise the job
grade of the operator of the metal finishing line and put a
skilled, reliable person in that position.
•*•,,• ' •"•.'" } : -
Neles-Jamesbury's internal environmental committee is
promoting a closed-loop system for installation next year at a
cost of about $6OK. They want to avoid the uncertainty of
changing regulations arid thus changing costs; they don't expect
the closed-loop system to pay back on water use, but to generally
cost less than other alternatives. They may not install the
system now under consideration because they haven't seen it in
operation and they're not sure it will meet their needs.
This case illustrates the value of enforcement in triggering
pollution prevention activity. Representatives of the firm had
already attended workshops describing the particular changes they
eventually implemented and had not taken any action. Free on-site
consultations had been offered; but they availed themselves of the
opportunity only after the inspection. They chose pollution
prevention to come into compliance. They implemented changes
inexpensively, saved money on chemicals and labor, and no longer
.maintain an onerousrtreatment systenu Their motives to change
production rather than to add treatment seem to have been: a) to
avoid the maintenance burden of the ion exchange system; b) to
avoid spending capital on a new treatment system; and c) to please
the POTW and state officials promoting pollution prevention.
-------
New England Plating
Worcester, MA
,„
along with ^me nickel ana ^^.^^.^-^-^^^ New -
of the Blackstone ( MU1 BrooK ^ u hydroxide sludge
to
^swo
intervening years
Ne« England ^tin, can us-jal^-eet their per^t
Parker M«tml»
Worcester, M*.
order
switched from nickel-chrome <^"^g.^an^ reduce health risks
s . reuce ea
5S^!n!drSand ^e^ater t.eat^nt costs.
-------
Three 'points stood1 out:, first, Bob Larson, the Engineering
VP. :™% .» - ef ; rSSMS LSTiK4SSoSr;iS5i.
Ws MnageSent finally bought in. Second,
Dltin line but also the wastewater treatment system
S ^
SE?1^^
tankSthe^des^gnS tSeir own mechanism for controlling the.
traced zinc metal surface area, and to consistently precipitate
Sine ?neir coSJufiant and their operator have experimented .with
several aspects of the treatment system.
in addition to pollution prevention through material
aff js^^
running the wastewater. treatment plant,
Seville Dyeing Company
Woonsocket, RI
we vetted a textile mill in Woonsocket, RI, that has worked
closet wi?h its%J?W ("wlonsocket) to reduce COD loadings and save
^ both water and energy use using pollution prevention measures.
?hePOTW has been recognized nationally for the.excellence of .
thSi? ?ret?Jatment program, and we wanted to pursue the question
of what distinguishes pretreatment program,managerswho are
within the plant, the.restrictions will be modified. They are
«iv-ino Sl50K/vr in water, sewer, and raw material costs .as a
SiS? of thelhaSgef they developed .after encouragement from the
'.POTW. ; ;•:. . ;' ._ ' '.'..- ' - ' ; -•;..'. •;'-.-'
One of the changes Seville has just begun to P^f^jf^
heat exchangers instead of live steam-to warm ^.r^anqels,
the dyeing kettles, with properly maintained heat exchangers,
-------
•1! M,** TO** fuel for the boilers than they currently do,
they will use ^sfueltor t superneated steam escapes from the
because a substa£^al J^unt °£ *operated. In addition to that
dye kettles as they are currenrxyj^ gge ^ ^^. reductxon
energy savings, Seville 8 °^e^rom ^ and other .
in re-dyes due to quality ^D^±I t the dye solutions in the
contaminants carried ff°"J tjjfj^i!:^ in quality control (as
Cranston Water control Facility
Cranston, RI
pretreatment program
the discharge permit limit) are ^ted |s ze^ elojninate
conventional pretreatment . .
vpper Bi.ck.tone Kat«r Pollution »b.t«»nt Di.trict (UBHPAD)
Auburn/ MA
^
Layer gne, Laboratory Manager.
-------
Massachusetts does not have OTA delegation from, EPA; EPA^
Massjcnusevts aoe PQTW'S current NPDES permit does
conununxt^es won' t^support local iimz compliance with their NPDES
permit requires--be caus e gey are i ^ erned that ^hey
penoit, they don t^see^proD^ |he new .permi-t comes into
B-
install and operate.
' we discovered that the POTW doesn't perceive itself to have
sewer pipes in the vicinity of their plant
with ^is^^irs^L^ra^
sear -«is sw^ssss-^S
ow^ increasing familiarity with and promotion of pollution
prevention options.
Warwick Sewer Authority
Warwick, RI , •• ' '•/'••. • .. -• "- '-•;-•/_ ' -
The Warwick Sewer Authority in Warwick, *?< "Jf^ ' S5?1
.. -
^
Warwick has had local limits ; since February of 1986 which are
sanitary wastes. We met with Howard Hadfield, the WarwicK
Pretrtati^ni Coordinator and President of the Rhode Island
PrXreatment Forum. Mr.. Hadfield maintains that the. stricter
-------
local lists *a*e the
to use ^tter Ejanageje ^
categorical sta?2?SU Jew thrust because some firms use too much
prevention is also ^e new t hrust again soon, in part
water— the sewer use charges WIIA y pollution Prevention
to drive water use "fj^Ji^, aS the state technical
Council is studying alternatives ^anarn ^ ThQ
assistance program is effective injpreaa g platers . during
have^ney to invest in process
changes.
that they should be regulated.
earssr - -
-------
Appendix B: Selected PPIC Case Studies
1 Name & Location of Company .' < >' .
Bass Plating Company
Old Windsor Road v
;Bioomfield, CT ,
2 Relevance to Incentives Study ;
Example of small plating firm that chose to implement
pollution prevention. Participation in ConnTAP's matching
grant program may have helped overcome both informational and
financial barriers. Pollutionprevention.options implemented
were low-cost, low-tech, but with high Q:& M savings and
short pay-back period (less than 6 months).
3 Case Study Summary, ,
3.1 Process and Waste Information: The company -specializes
in zinc, cadmium, niqkel-cadmium, and tin plating arid
. passivating.; Metal hydroxide sludge is generated from
the three plating lines which all contain cadmium. The
company conducted a waste minimization assessment at
the facility. .;
, Many of the low-cost, good operating practice and waste
minimization options identified were implemented.
These included increasing drip times, elevating plating
bath temperatures, improving drip containment and
redesigning plating racks.
3.2 Scale of Operation: The company employs 35 people.
3.3 Stage of Developments The options identified above
have been implemented. Other options have been
identified which may be implemented in the future.
• "- - - - . x .-..,. , l - • . . • _ • • ,.."__
.4 Economics . ,
4.1 Investment Costs: The cost was reported as $12,000,
4.2 Operational & Maintenance Costs: Savings in operating
expenses were reported as $96,100 per year. ,
4.3 Payback.Times Payback period is. 5.8 months.
5 Cleaner Production Benefits: 120 tons of metal hydroxide ,
sludge were expected to be generated in 1989, representing a
. 15'% decrease in sludge generation in 1988.
-------
reported
Contacts and Citation
Contacts and Cta • _ 1988-89,
"
'•••wES.w--
Clean ^=»nology£Ca«gory« The teohnolo|y
' 5S
8 Clean ^= ng
-------
1 Name & Location of Company
Pratt fit Whitney Aircraft
North Haven, CT • -
2 Relevance to incentives Study
Example of large captive shop associated with major metal
nSS manufacturer. Ultimate goal is zero discharge, but ;
facility is proceeding in phased implementation steps. New
pStingline? "alread? on the drawing boards" were re-
Ixaminld in light of facility-wide pollution prevention^ .
.program. Designs were revised to incorporate whole range of
plating source reduction and recycling/reuse options.
3 Case Study Summary.
. 3 i Process and Waste informations This,facility produces
mljor metal-finished rotating parts such as discs, hubs,
and shafts* In 1987, they were discharging ,• .
. . approximately 1,000,000 GPD of treated .wastewater,
400,000 of which was generated by metal-finishing
operations, implementation of a "zero discharge
program involved 6 phases.
Tn Phase One good operating practices were defined. .
These include defining minimum water quality standards;
, using Undercurrent rinses to reduce water usage; using.
continuous process purification versus batch ^
purificatioS to maintain consistent process quality
Tie .dummy plating and carbon and particulate
fii^rationTI using Sn-line process monitors,to control
solution addition!; optimizing process solutions to
control dragout; optiniizing preplate rinsing to control
dragin of contaminants; installing automatic l^el _
controls on all heated processes; training operators to
SndeStlnd proper rinsiSg and ^«ork transfer. techniques
to reduce dragout. and dragin; and treating small
conlSntrated batches as opposed to high volume dilute
wastestreams* •
. Phase Two^ is to implement Phase One.
Phase Three is designed to verify closed-loop technology
on a single process. This was conducte
-------
cadmium, chromium, and nickel stripping, and (3)
titanium descaling were already on the drawing boards.
Initial plans were revised to incorporate countercurrent
rinses; ion exchange; atmospheric evaporation? deionized
water in all critical rinses and softened water in all
noncritical rinses and noncritical evaporation makeup.
Phase Five was to install the plating lines.
Phase Six involved renovating remaining existing
processes, including cadmium cyanide plating and
chromating.
3.2 Scale of Operation: The facility encompasses I,000,000
square feet. It was discharging 1,000,000 GPD of
treated wastewater, 400,000 GPD of which was generated
from metal finishing operations. •
3.3 Stage of Development: Phases I - III fully implemented
Economics .
4.1 investment Costs: N/A
4.2 Operational & Maintenance Costs: N/A
4.3 Payback Time: Anticipated payback time is -less than two
years.
Cleaner Production Benefits: The metal finishing contribution
to the total wastestream volume has been reduced from 40% to
5%. Raw material costs have been reduced by .approximately
90%. Transportation and disposal costs and associated
liabilities, have also been reduced by the same order of
magnitude due .to the-decreased sludge production and
decreased shipments of concentrated solution wastes to a
treatment facility. Product quality has.also improved and
operator acceptance has been very good despite initial
skepticism. . . .
Obstacles, Problems, and/or Known Constraints:. None mentioned.
Contacts and Citation
7.1 Citations American Electroplaters. and Surface Finishers
Society, Inc., and the Environmental Protection Agency;
"12th AESF/EPA Conference on Environmental Control for
the Surface Finishing-Industry? January, 1991; pp.
. 75-89. .
-------
., Name & Location of Company'
precious metal ,,*"'
3.2 Scale of Operation: Information riot provided.
3.3 Stage of Development: Recommendations riot implemented
3.4 Material/Energy Balances and Substitutions /Example 11«
-------
-. Quantity Quantity
Material Category Before . After
silver drag-out reduction . _
rinse-wastewater: , 240> 0.00 gpd 155,000 gpd
silver concentration
in influent: 5 mg/1 0.5 mg/1
silver concentrations •
in effluent: N/A < 0.15 mg/1
Economics
4.1 Investment Costs: In the first example, the capital
investment for silver drag-out reduction was $12,000.
The capital cost to install the reverse osmosis units in
the second example was estimated at $525,000.
4.2 Operational & Maintenance Costs: N/A
4.3 Payback Time: Without expanding the .capacity of the
plant, the payback period for installing waste
minimization in the production line in the first example
was projected to be less than one month.
The marginal payback period for the in-line reuse
system for the second example, (as compared to the
existing off-site reclamation) was projected as 5
months.
Cleaner Production Benefits: For the first example, the
operating savings of silver drag-out reduction versus
treatment is $470,000 per year. For the first six months
after implementation of the reduction process, all discharge
standards were being met. . "
In the second example, the net savings of the in-line reuse
system versus the off-site reclamation were estimated at
$825,000. According to laboratory tests, more than 90%
recovery is feasible with the reverse osmosis units.
Obstacles, Problems'; and/or Known Constraints: There were
fiscal and organizational limits to implementation of waste
minimization for these processes. , The silver drag-out
.reduction program, required considerable attention from
production Q/A personnel. Despite initial improvements from
waste discharge standards, by the end of a year, silver
violations had returned to their former level. This was due
to significant changes in production and inadequate new
treatment plant and the company decided not to continue with
the waste minimization efforts.
-------
Due to the large capital cost needed'for the in-line reuse
system in the second example, the facility also decided not
to adopt the in-line silver reclamation system.
. '. . ;'.'',_ '/
1 . Contacts and Citation ,•-.': -'•...•
7.1 source: American Electroplaters and Surface Finishers
Society, Inc., and the Environmental Protection Agency;
"12th AESF/EPA Conference on Environmental Control for
the Surface Finishing Industry"; January, 1991; pp.
_' • • - . 59-69. ' :. •. ... •• . - - '" . ,,..-. . .• • /
7.2 industry/Program Contact and Address: John Rosenblum,
.Rosenblum Environmental Engineering, 3502Thorn Road,
Sevastopol, CA 95472. Mazen J. Naser, Plating and Waste
Management Consulting, 96 Lycett Circle/ Daly City, CA
.. ' '• •- ; ' 94015. .-"..,..•'-. ' ' • - , •'':•. .'. ••' _" _ '" ,
8 Clean Technology Category: The clean technologies evaluated
in this case study consisted of the modification of air-
knives, electrolytic recovery cells and flow restrictors to
reduce silver drag-out and the installation of reverse
osmosis units as in-line reuse systems.
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1 . ' "; Name &: Location of Company . . '
Seaboard Metal Finishing Go., Inc.
50 Fresh Meadow Road
West Haven, CT 06516
2 Relevance to incentives Study
An example of a firm which received technical assistance
without a compelling regulatory need, and has not acted, on
the suggestions, pollution prevention options were low-cost,
low-?ech; and would -have decreased facilities. RCRA F006 waste
generation by 16 tons/year and would have reduced copper,
' hex. chrome, cyanide and nickel wastewaters by 75%.
3 Case Study Summary. , . . ••
31 process and waste information: The facility has six
process, plating lines, including copper, automatic
nickel, barrel copper/nickel, bulk chrome, hard chrome
and rack nickel/chrome plating. The resulting FO06
sludge requires off-site disposal.
A waste minijfiizatiQn study of the six. electroplating^
lines was conducted. A mass balance was determined by
analyzing the discharges for metals and determining an.
average discharge rate. A waste inventory was peformed
and critical sources of waste were identified, waste
minimization alternatives were analyzed for technical
feasibility and cost effectiveness. The proposed
alternatives included recycling rinsewaters, automating
plating lines, installing evaporation technology and
additional rinse tanks with reduction of countercurrent
- '-flow. . . •• \ . . , •
3.2 scale of Operation: The facility employs.,45. plant
personnel.
33 Stage of Development: The proposed alternatives had
not been implemented at the time the case study was
• 'written. •'-."'*,' , •-' ' -.- '... . / '..
4 Economics ' .
4.1 investment Costs:. The cost is estimated at $13,500 for
several new rinse tanks and evaporation unit.
: 4.2 operational & Maintenance Costs: Annual savings of
more than $15,000 are anticipated. •.
4.3 Payback Timet The payback period is estimated, at 1.2
years. . ' - -: •'" ' • •
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Cleaner Production senents: ^ -^ alternatives were
Ca.eeuu=i. r-i---~' . . ~ y^a would be achieved for
iir^plemented, a reauctio^^^ cyanide, and nickel wastewater.
AhouJr'l6 tons of F006 sludge, now requiring off-site
disposal, would be eliminated.
6 obstacles, Problems, and/or Known Constraints«. None
mentioned.
7 Contacts and Citation ,
7.1 Citation: connT^Matching Challenge Gra^s-1988-8_9,
..50
Fresh Meadow Road, West Haven, CT 06516 (203) 933
1603. '. • , ' . '
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4.1- Investment'Costs: The anticipated capital expenditures
during 1990-1991 on this project are $80; 000.-' This
includes costs for aqueous cleaning systems, waste
- water collection equipment, and equipment installation.
4.2 Operational & Maintenance Costs: $15,000 in utility
costs are required for' heating and pumping aeneous
':. fluids. ~ "'. • •.'"••'.'' ..'••;'...' . •'. ' ..'•'..
4.3 Payback Time: with an approximate annual savings of.
$56,500 and $80,000 in capital costs, the. pay back .,
period,-is approximately 1.4 years.
Cleaner Production Benefits: A net savings .of $7,000 is
expected from reduced disposal costs, since the disposal
costs in 1988 were $9,000 and they expect that the cost for
disposal of separated oils will be $2,000* In.addition, the
annual cost saving associated .with the disposal of absorbents
no longer contaminated with TCA is $34,00.0. . , .
A net savings from replacing virgin TCA and .aqueous cleaners
will be $7,000. This was calculated from the- difference in
the 1988 cost of virgin TCA ($27,000) and the 1991 costs for
aqueous cleaning solution ($20,000).Overall, the.potential
-savings from eliminating TCA is approximately $56,500 per
year (including the extra utility costs discussed below).
Obstacles, Problems, and/or Known Constraints: There is an
extra electrical cost associated with.heating and pumping
aqueous cleaning fluids equal to. $15,000 per year. TCA cold
cleaning had no utility cost. ,
Contacts and Citation
' '
7.1 Citation: American Electro-platers and Surface
Finishers Society, Inc., and the Environmental
Protection Agency? "12th AESF/EPA Conference on .
Environmental Control for the Surface Finishing
Industry"; January, 1991; pp. 165-181..
7.2 industry/Program Contact and.Address: Kevin P. vidmar,
Div. Manager, Environmental Affairs, Stanley Fastening
Systems, Route 2, East Greenwich,,RI 02818.
Clean Technology Category: The clean technology involved
initially reducing 1,» 1, l^trichlorethane use and finally
eliminating its use by installing aqueous cleaning systems.
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Name & Location of Company
Stanley Fastening Systems
EastVreenwich, RI 02818
\ , '
Relevance to incentives Study
"plants exceeding discharge limit).
Case Study Summary
3.l'
manufactures
these fasteners
aluminum,
parts, a^
treatment and
Prior to many
a cold aPP^
TCA was being
twice as high
are made of
To produce these
drung lathe working, heat
^witlon* are employed.
ns , parts are cleaned .in
Srichloroethane (TCA) . ,
^ tt levels
limit. Absorbents used
levels of TCA that
-
scale of operations was
3 3 - Stage of Development, 'In the implementation stages-all
3 l^ufpment is not yet fully installed .
Economics " •
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Appendix C: Telephone Contacts List
Institution
Acteron Metal-
Finishers
Atlantic
States Legal
Fund -
Barren
Consulting
California
DBS
Alternative
Technology
Division
Location
Redwood
City, CA
Syracuse,
NY
Lafayette,
CA
Contact
pat Burt
Alan
Hayes
Comments
Chairman, NAMF Waste
Minimization committee.
Gave industry
perspective and further
technical contacts*
Tom.
Barren
Kathryn
Barwick
Attorney handling CWA
citizen,suit cases;
pollution prevention in
enforcement settlement.
California
DBS
Alternative
Technology
Division
California
Local
Government
Commission
California '
Regional
water Quality
Control Board
.California
Regional
Water Quality
control Board
EPA, Region 1
Authored "Evaluation of
Waste Audit Study
Program" for CA DBS
Alt. Tech. Div.;
evaluated audit program
impacts on 6
industries...
Gave DBS perspective of
state, regional, and
local.POTW pollution
prevention initiatives.
Contact person for CA
Waste Reduction Act of
1989 (SB-14); discussed
CA waste audit guidance
documents.
Has been involved with
pollution prevention in
CA for several years;
gave local government
perspective.
chief, Surface water
Div.; pioneered
incorporation of
pollution prevention
requirements into POTW
NPDES permits.
pretreatment
Coordinator for RWQCB.
Perspective on using
pollution prevention
requirements in
enforcement context
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Laurie
Kermis h
San
Francisco,
CA
EPA, Region
Peter
Gallerani
Bethany, CT
Integrated
Technogies
Barbara
Kelly
Boston', MA
Mass. DEM
Office of
Technical
Assistance
Mass. DEM
office of
Technical
Assistance
Tim
Greiner
Boston, MA
Providence,
RI '
Narragansett
Bay
Commission
Palo Alto,
Palo Alto
Water
Pollution
Control Plant
Gina
Friedman
Providence,
RI
Rhode island
DEM, water ,
Resources
Division
Providence, | Bev
Migliori
Rhode Island
DEM, Air &
Hazardous
waste
Division
Attorney in Office of
Regional Counsel; metal
plater enforcement case
with pollution
prevention planning
requirement in Consent
Order '
Former owner of VT
metal finishing shop;
consultant and promoter
of pollution prevention
with nation-wide
experience.
Director of OTA; gave
non-regulatory
technical assistance
perspective
Contact on Blackstone
Project; perspective on
zero discharge systems
•in. Mass, (permit); gave
leads, on facilities for
site visits.
Pretreatment program
Manager; talked about
EPA audits of
pretreatment programs;
also leads on zero
dischargers and jewelry
platers.
POTW perspective;
progressive pollution
prevention program
targeted to
photofinishers;
formerly with EPA and
CA' DBS,
state Pretreatment
Coordinator;
perspective on
delegated states; gave
contacts.for site
visits and follow-up;
zero discharge and
vendor issues
Regulatory perspective
on RI interpretation of
possible RCRA
violations associated
with zero discharge
systems^
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Rose.nblu.in.
Environmental
Engineering.
Sunnyvale
Water
Pollution
Control Plant
Sunnyvale
Water
Pollution
Control Plant
Sunnyvale
Water
Pollution
Control Plant
Sebastopbl,
CA
Sunnyvale,
CA
Sunnyvale,
CA
Sunnyvale,
CA
John
Rosenblum
Helen
Farnham.
Pamela
Morrison
Chris
DeGroot
Consultant in pollution
prevention with
expertise in energy and
water conservation;
performed many waste •
audits for SF Bay metal
finishers.
General Manager of POTW
that won 1991 EPA
Pretreatment Award;
pollution prevention
requirements in NPDES
permit; POTW targets
metal finishers and v
electroplaters for PP.
Pretreatment Manager;
gave details on POTW's
sampling and QA/QC
protocols; 10 years at
Sunnyvale POTW.. _
Pretreatment Inspector;
former process engineer
in a printed circuit
board plant; gave both
technical and
regulatory perspective.
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