United States
Environmental Protection
Agency
Office of Water
(WH-547)
EPA 832-F-93-OQ7
September 1993
4>EPA Enforcement Requirements
Case Studies
PROGRAM DESCRIPTION
The pollution prevention (PP) program of the County
Sanitation Districts of Orange County, which regulates over
1,000 facilities in its pretrearment program, emphasizes
enforcement. P.P requirements are incorporated into written
enforcement orders that are issued to facilities not complying
with indirect discharge permits. As part of these orders,
companies must conduct PP assessments and submit PP
assessment reports. Descriptions of proven PP techniques, their
application and benefits, and a PP checklist are provided to
facilities for their use. In addition to issuing enforcement
orders, an Orange County engineer or inspector visits each
facility to review its manufacturing processes, assess PP
opportunities, and answer questions about Orange County's
requirements. Facilities must implement those techniques
identified by their PP assessment to be technically and
economically feasible. Through this program, Orange County
has reduced industrial wastewater flow volume and heavy
metals loadings by 50 percent over five years.
PROGRAM OBJECTIVE
Orange County's objective is to implement a PP program
to control and reduce the quantity of toxic materials discharged
by industrial users to the County's sewage system. Orange
County's toxic control activities include promotion of source
reduction, safe materials substitution, and educational activities
directed at industrial and household users.
PROGRAM ACCOMPLISHMENTS
In 1984, Orange County promulgated mass emission
limits (setting limits of pounds of pollutants per day) for each
permitted discharger. Mass emission limits promote water
conservation by preventing facilities from using dilution to meet
concentration-based limits; they limit the total quantity of
pollutants released to the environment. Compliance is based on
the results of samples collected at each discharger's facility and
average water usage. As part of the initial effort to enforce
mass emission limits, permittees were required to install flow
restrictors or control valves to ensure wastewater reduction and
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to prevent companies from achieving compliance by dilution.
Permittees' facilities are inspected and checked for water
conservation control equipment at least annually.
In 1989 Orange County revised its wastewater discharge
regulations and established PP requirements. These regulations
require all significant users of the sewage system (as defined by
EPA effluent guidelines) to develop PP plans that address water
conservation, investigate raw material substitution, establish
inventory controls, implement educational activities, and take
any other steps needed to prevent pollution. Orange County
uses both Enforcement Compliance Schedule Agreements and
Probation Orders to promote implementation of PP measures.
Orange County may require a company to complete the
necessary improvements specified in the facility's proposed PP
plan under the terms and conditions of an Enforcement
Compliance Schedule Agreement The agreement is a contract
between Orange County and a company in non-compliance that
temporarily amends the facility's industrial wastewater
discharge permit and establishes a compliance schedule for the
development and implementation of an effective PP program.
In addition to Enforcement Compliance Schedule
Agreements, Orange County uses Probation Orders to reduce
wastewater discharges. Probation Orders direct a facility to:
1. Immediately cease all non-compliant discharges by:
a implementing a PP plan,
Q reducing the manufacturing production level, water
usage, and discharge,
a hauling waste off site, or
3 using any other effective method.
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2. Conduct an industrial waste survey that identifies:
a all pollution sources,
3 characteristics of industrial wastewater,
3 wastewater flow rates,
3 alternatives for PP and recycle/reuse, and
a necessary characteristics of a pretreatment system.
3. Develop an effective waste management program that
includes:
3 actions to reduce the generation of wastes at their
source,
3 recycling and reuse of wastes, and
3 treatment of discharged wastes.
Orange County has 20 inspectors who perform quarterly
and annual inspections. Each inspector is responsible for
approximately 40 facilities. Orange County's 400 Class I (i.e.,
federally regulated) facilities are inspected every three months
and receive a detailed annual inspection. Twelve permit and
enforcement engineers assist facilities with the development of
their PP plans. The inspectors and engineers receive training in
PP opportunities and Orange County's enforcement
requirements.
Recently, Orange County declassified hospitals as
significant users because, although high in volume, their wastes
(e.g., silver) are not significant in toxicity, primarily due to
improved x-ray technology. Orange County offered hospitals
the incentive to be exempt from more stringent sampling and
inspection regulations provided they submit a PP plan.
Over the past five years. Orange County's PP program :
has achieved significant environmental improvements. These
improvements include a 50 percent reduction in the volume of
industrial wastewater discharged to Orange County's sewage
system and about a 50 percent reduction in heavy metals in the
POTW influent As a result of the PP program, over 95
percent of the 400 Class I facilities, including 149 metal
finishers, have installed flow restrictors or control valves to
reduce wastewater usage or have installed PP equipment to
reduce waste and wastewater volume. Orange County is
currently conducting an ongoing survey of facilities to
determine their individual accomplishments.
FOR MORE INFORMATION
To obtain additional information on Orange County's PP
program, contact Adriana Renescu at (714) 962-2411
extension 3828 or write to:
County Sanitation Districts of Orange County
Pollution Prevention Program
10844 Ellis Avenue
Fountain Valley, California 92708
For additional information about the MWPP Program, contact the U.S. EPA Office of Wastewater Enforcement and
6 Compliance, (202) 260-5856.
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