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


                            TABLE OF CONTORTS
        •          ,
        •  '   .'
  -    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     .  •  •. •  • •  *  *  *  * * •*•••'."

                                                                 • •   *
                        Msistanoe and Outreachr and    ,. .
             coilaborative aalatiohslues   •-...... .....•••
                   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 '             •..'•' '


context of detemoiiing how  es            proram efforts have
                     .          factors that affect decisions by
     While there ^e a.r^^r°fVTf^o adopt pollution prevention
       Flexibility                                   .   .
        barriers and ^^^^^thin a tmilti-aedia framework.


Economic Realities

Technical iaad Financial A»»i*tance      '

 Open Coonuhicatioft •.              ' ' -.   .
          o£ pollution.

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.

      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


                      .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.

     1.3  "organization of Report

          «•   \  •= * bri^f introduction to the study.   Section 2
     Section ^.^of^f OUr major incentives/disincentives areas:


pollution prevention.

StriTof completed telephone contacts.


    «e -s

econonic incentive ^Pf^^^i^Ses (lov^r disposal       -

          f                          '
 cy isnueta >« *^- — - —                  ,         .   _.»


        poUution P^^oS^ef a^S^ "*** to explore
            toine    esoeaa  ac
                         facility -go for

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
     compliance inspections
     where NOVs are tied to a-
     pollution prevention
     message (e.g., referral to
     state technical assistance
     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
      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
                              single-media permits that
                              focus on end-of-pipe
                              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

 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
 use            .     .    -
permit writers.;'that may be;
outdated and focus on .end-
of-pipe' solutions"
standards .that may
discourage water    ;
use         ,-    ••'..•

      Economic  Factors  in  Pollution  Prevention  Decisions
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

 "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  • '•   -.
                                       with changed product may
                                       mean loss of revenue

            '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-) '


      • „. ical/In^ional Factors  in  Pollution Prevention
.3  Technical/mi      Decisions
V ' f^- Lf"*"***	™"	   .    ,—"   x^^*

                                    or to take risk

                                              , misrepresent
                                                    and the
                                       facility falls out of



------- .'writer and inspector
 t raining*on'how pollution
 prevention can achieve,
. jalntain,'or even go beyond
 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
                                     proprietary information
                                     concerns—^disincentive to
                                     sharing information, data,
                                     and/or experiences with new
                                     processes  ,

 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

 '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
                  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

                  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
                              '< .-    .' • { .
                   "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;

	(and betveen-)
-iralatbry agencies;
openess _to pollution
                                     j—*. —-^—•
                                     broke, don't fix it.

   . 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

and compliance personnel.                       •       .
                      is key, even within a single media
aStuallfadopting pollution prevention measures.

 pollution control equipment anyway.
      This is
                             . 16

                      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

                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


     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

            OF pQliTIjr-L"• •Lrr-

are «E»™nt:' tor MtjOgat^'*^*^ =ase studies/ sl»

                                —-^ ^^
         a                       .

                     _ . _ :. v^ij nuch orxatdse for platers
                                          can foster

          prevention*     •   '•

      31               rd. «. Outdat-
      ^cuxr^ national :**S^J»SZ%Sf  fS

                                           U ~
   categorical standards*.


                                      ;«' 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. . .           .
   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

             Comparison of Categoricals and Local Limits
           POIW Local
                         FOOT Local
                                             no Limit
                                             no limit
                                             no limit
                                            Limits for
As of August 1991.
Preculaated in Jun
Limits for
200 POTWS*
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.

  ''•' v '  •" .'   •    '  ';.. "'•.__,  ,^'th the'Strides 'that have -teei

1 a^-ac*/- -- "."—3 is;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
           than, categorical standard*, _a°»^Jha pow, its voWcars

                u»«» -IfS^op** of developing
                                   iS pretrea^ent program.

                                         to derive' the limits.

                              eiqnDoruig city's limits or values
                              information collection activities

     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

 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
to implement them,  other^™     However, in many cases, either
                            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

   .  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

 concentration-based limitations."*

     s ss saraas.sss3S5S£%«r'


         of nctaTf inishiiig manufacturing
     Althouah early consideratijon of a nass-basetf or total
      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

        323   ^..Based v. Coo=entration-Based Li«its



;,      ^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


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.

 ^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

  to «hy to go to «^^i!-tESd ilSS .provida.  Coneantratixjn-
  change tlatconcattoj-b^l^ta^^      ^       ^ o£


                                        are -the goal. These goals
                                                          vnll- •
    r to happen.-;
                     Examples of Pollution Prevention Technologies
                     Fostered by Mass-Based Limits   .
  .   Technologies
                       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


         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

        ±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                    .
                   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
 was  found to be combining a water stream from anf^


      , V~— Vac "Veal assistance provided by the state's
      irect |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.



                                          — ^"^ £ot
  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                     •..


                   -                  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

 associated with ^ nonconpliance.

  !: ;        3:3.3>   Pollution prevention In Eiiforcea^t Actons

            Atlantic State,

   choie to pay the, fane *«* ««J ^Sl?Se^later chose a reduction
   pollution P^^0"^^?^;! ??dVTpbllution prevention

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


  could get.  .      •  ;       •

  '.   •     3.3.4     la^rtanc* of Agency Opanness TO Pollution
                     nmauan+'ian: •                •       .

       « 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_
1988.  With grant suP^r^._l5«rtfld a series of nultimaooa
n«-Ai«»«+•"ion. ill 1990 DBr UTJJ!%*«*• __,_ ^.+ anATvrv and ^/iW lieifl Stati.

         s       .saa
        =        .
 Coordinating «tat» ^^igji STS^artaltB pollution
                         » — ——•


   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
.     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



       regulation     .

 .     successful lobbying of tha stat«^«*»ly « ctang. the staf
       law regulating photcprocessing. wastes

  NPDES permit.

     34  gcoacmic Factors: For Metalfiaisfaers Hav« The

          To Be -Key'Motivators, But There. Are Significant Barriers

 silver and gold
                    covers  the electroplating of 'various j^*»?
                  cadmium, copper, -chromium, 'nickel,  zinc, lead,
                  caami  4o^"nBtai.^Urfa<* preparation and
                                        The electroplating
^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,

                                        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     '
    toring of ^' *?*£*£?%> SS^lTwin7  s    cussed
smaller) ccopanies .may not ^JSinas^ndicate that, for metal
                                       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

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
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
               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


        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— -

 O«t ]_ V-1 Iftiii-g J«^ ^*^«—— «  fl*»A I M 'Jig jJiT\V pJ.nrTTlr iw*r **"*^ •  JT   _^_

                                         points out

                          * 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
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
  waterways or "^"^.li^ii SSU4 not S te considered pure
  status rauains in S^S^Srrent iSsl °t narket and technology
        "Tfiro1* diacharge> systeais
  ««*s« disdiE iSudin?3SiSriodiiSas=i, «=*•

  ^aL^^S^^^^5-811— fiS>2

   over the last decade

sometimes . chemical ^^^"r^, throuah the treatment steps  are
ahd other .<^*aSS^^5iS«5 off site'either
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

      -   '" 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

      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.                                     .
          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.            .   '      ," .  '  .   '.        •      -'.       • •     •
            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

             •     •  _ _ .« ' ' 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



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

                                             tha «ater

. *.
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

                                thJe inSSSSs may Ignore
             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.                ..    "


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


           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

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.


        oresent here a fairly detailed case examples of where

        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
 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

other means

      4.2  Approach to implementing NFDES Waste Minimization
      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?

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
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
       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:
Palo Alto
San Jose/Santa Clara
                          Targeted Metals
                       Lead, Copper,
                                           __ srcial and industrial
                                           photoprocessors , X-Ray
                                           labs and other
                                           potentially inportant
                                                  _ _
                                           Radiator repair, auto
                                           " — • — cleaning shops and
                                                     source •
««.-. Finishers,
slectropiaters and other
aotentially inportant
sources	.	
      44   Regional Board Follow-up


       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



      '  applicants.

  o     coordinate program development and share, findings

     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

      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

      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

                                          waste haulers  have been

     net decreases in P°1?O!2      enalizing facilities

      discharge violations
      industrial users

       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



        industry discharge
                                                    Ordinance was
                                              	   Three of.
                                          completed audits to

•     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

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).

      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

     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.   '                                 .                    .

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.                          <


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.
Fernando Originals
New England
     Auburn, MA
     RI •'•••.
 Parker Metals
 Seville Dyeing Co,
design and
some chrome
 Cranston water
 Control Facility
 Upper. Blacks-tone  .
 Water Pollution
 Abatement District
 Warwick Sewer
      RI    •
                     carts	.
      Cranston, RI
      Auburn, MA
      Warwick, RI
                                     23 MGD
                                     35 MGD
 3.. 5 MGD
                              Medium-size job
                              shop? ho
                              plating lines

                              captive shop;
                              precious metal
                              Large captive
                              .shop; tumbling,
                              phosphating and
                              plating lines
                              Large job shop;
                Large captive
                shop; switched
                to alkaline
                zinc plating
                               No plating;
                               reduced COD
                Fee system for
                users indexed
                to toxics
                with MA PEP/DEM
                               Strict local
                               promotes zero

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

 intervening years
      Ne« England ^tin, can us-jal^-eet their per^t

  Parker M«tml»
  Worcester, M*.


switched from nickel-chrome <^"^g.^an^ reduce  health risks
  s                                     .       reuce  ea
              5S^!n!drSand          ^e^ater^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  ^
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 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

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

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.


Contacts  and Citation
   Contacts and Cta          •             _ 1988-89,
 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

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

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

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

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.


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

      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.    .       '     -   -:            •'"   ' •   •

     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


7    Contacts and Citation                               ,

     7.1   Citation:   connT^Matching Challenge Gra^s-1988-8_9,
           Fresh Meadow Road, West Haven, CT  06516 (203) 933
           1603. '.   •                            ,             '  . '

 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.

Name & Location of Company

Stanley Fastening Systems

EastVreenwich, RI  02818
                                     \  , '

Relevance to  incentives Study

"plants  exceeding  discharge  limit).

Case Study  Summary

these fasteners
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                      "  •

Appendix C:     Telephone Contacts List
Acteron Metal-
States Legal
Fund  -

City, CA
pat Burt
Chairman, NAMF Waste
Minimization committee.
Gave industry
perspective and further
technical contacts*
Attorney handling CWA
citizen,suit cases;
pollution prevention in
enforcement settlement.

 California '
 water Quality
 Control Board
 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
             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
                           Has been involved with
                           pollution prevention in
                           CA for several years;
                           gave local government
                           chief, Surface water
                           Div.; pioneered
                           incorporation of
                           pollution prevention
                           requirements into POTW
                           NPDES permits.
                           Coordinator for RWQCB.
                            Perspective on using
                            pollution prevention
                            requirements in
                            enforcement context

                              Kermis h
EPA, Region
                Bethany, CT
                 Boston', MA
Mass. DEM
Office of
Mass. DEM
office of
                 Boston, MA
                RI '
                Palo Alto,
Palo Alto
Control  Plant
 Rhode island
 DEM, water ,
                  Providence,  | Bev
Rhode Island
DEM, Air &
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
Director of OTA; gave
technical assistance
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
                                            POTW perspective;
                                            progressive pollution
                                            prevention program
                                            targeted to
                                            formerly with EPA and
                                            CA' DBS,
 state Pretreatment
 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

Control Plant
Control Plant
 Control Plant
Consultant in pollution
prevention with
expertise in energy and
water conservation;
performed many waste  •
audits for SF Bay metal
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.