United States
                         Environmental Protection
     Office of Water
September 1993
    &EPA   ^Streamlining  Administrative
  Case Studies
     In 1989, more than 8,000 pounds of metals were
discharged into South San Francisco Bay by the Regional
Water Quatity Control Plant (RWQCP) in Palo Alto,
California Levels of silver in clams in the immediate vicinity
of RWQCP's discharge were ten times what they were
elsewhere in San Francisco Bay. As a result of these elevated
levels and violations of water quality objectives for silver,
RWQCP faced a mandate from the Bay Area Regional Water
Quality Control Board to reduce the heavy metals it discharges
to the South Bay.  RWQCP developed a Source Reduction
Program for the five communities it serves; those communities
then adopted silver reduction amendments to their local sewer
ordinances. The ordinances focus on discharge of spent
photoprocessing and x-ray solutions (mainly fixer and
stabilizer) that contribute most of the silver entering RWQCP.
For the first time, all dischargers of silver to the sewer  from
the smallest dentist offices to the largest photoprocessing
facilities - were regulated. The silver reduction ordinances
went into effect on June 30,1991 for facilities discharging
greater than 20 gallons of fixer, bleach fix, or stabilizer waste
per month and on September 30,1991 for all other facilities.
The ordinances have been instrumental in helping RWQCP
reduce its silver effluent by 75 percent

     RWQCP, in conjunction with the Santa Clara Valley
Nonpoint Source Pollution Control Program and the .Metals
Advisory Group, has identified vehicle service facilities as
potentially significant contributors of metals to both sanitary
and storm sewers. The communities served by RWQCP have
developed new sewer use ordinances for these facilities.
RWQCP is developing a Vehicle Service Facility Waste
Minimization Program to educate approximately 325 facilities
about the new sewer ordinances and about best management

     RWQCP found that many of the existing requirements for
hazardous waste generators were designed to regulate large
quantity generators rather than small quantity generators (e.g.,
small businesses such as the medical community and photo  ,
processing industry). RWQCP believed that subjecting these
small quantity generators to an "army" of regulators and the
stringent regulations for large quantity generators could be both
cosdy and inefficient considering the large number of small
quantity generators and silver's low toxicity to human health.

     RWQCP, with the cooperation of other regulatory
agencies as discussed below, set out to establish a less
burdensome regulatory system for small quantity generators.
RWQCP hopes that by accomplishing the following objectives
it will be able to facilitate and encourage small quantity
generators to meet new ordinance requirements.
Objective 1:    Coordinate and streamline requirements
Objective 2:    Minimize fees
Objective 3:    Communicate the reasons for new regulations
Objective4:    Involve the regulated community in planning

     The goal of the Vehicle Service Facility Waste  
Minimization Program is to protect water quality in San
Francisco Bay through a pollution reduction program aimed at
vehicle service facilities in the service area of the Palo Alto
RWQCP. The program involves two major components:

Q   Information and assistance will be provided to vehicle
    service facilities. Facilities will be encouraged to
    implement BMPs and to comply with new local sewer
    use ordinances.

a   An incentive program to encourage pollution reduction
    by recognizing and rewarding facilities that have made
    extra efforts to prevent pollution.


Cooperation Between RWQCP and Regulatory Agencies
     Storage of hazardous materials - including spent
photoprocessing solutions and some virgin photochemicals  is
regulated by local fire departments or in some areas by the
county health department RWQCP encouraged the Palo Alto
Fire Department to exempt photoprocessors from the
requirement to obtain a storage permit for up to 30 gallons of
spent fix, bleach fix, and stabilizer. By allowing storage of
small quantities of spent wastes without a permit, this
exemption makes it easier for small quantity generators to store
these wastes for subsequent silver recovery. Secondary
containment, proper labeling, and all of the other substantive
requirements of the fire code still apply. The exemption does
not apply to storage of corrosives with pH below 2 or above 12,

                               Printed on Recycled Paper

or photographic materials that are hazardous because of
properties other than silver content  storage of more than 10
gallons of these materials at any time still requires a permit with
annual fees beginning at $385.
     At the request of RWQCP, the medical community, and
photoprocessors, the CaBfornia Assembly's Environmental
Safety and Toxic Materials Committee amended the state
health department's regulations affecting treatment of
photoprocessing and x-ray wastes. A law enacted in the Fall of
1991, exempts treatment of silver-bearing wastes from permit-
by-rule requirements - including permit fees and liability
assurance - provided that a facility's monthly volume of
hazardous wastes, with silver as the only hazardous constituent,
does not exceed 150 gallons per month for on-site treatment.
This exemption reduces the regulatory costs associated with on-
site treatment for small quantity generators.
      In response to comments from RWQCP staff and Palo
Alto city officials, the Santa Clara County Health
Department lowered its Hazardous Waste Generator Permit fee
for generators of less than 27 gallons per year of hazardous
wastes to reduce regulatory costs imposed on small quantity
generators (dentists, other small x-ray operators, and some
small volume photoprocessors). The fee for this group will be
$100 per year and $300 for generators of between 27 gallons
and five tons.
Regional Water Quality Control Plant
      Utilizing their own resources, RWQCP has accomplished,
 several tasks:

0  To inform and take comments from as many people as
    possible, RWQCP holds frequent informational
     workshops and provides outreach material including fact
     sheets and bi-monthly updates.

 Q   For the vast majority of small volume silver dischargers in
     the area, on-site treatment is not cost-effective. RWQCP  tf
     has developed three options:

     1. Based on a state regulation for household hazardous
        waste collection programs, the plant received a
         variance that allows non-commercial silver
        dischargers to drop off spent fix at RWQCP during
         regular business hours.

     2.  RWQCP encouraged the City of Palo Alto's
         household hazardous waste collection program to
         initiate a hazardous waste drop-off program for small
         businesses in the plant's service area. The program
         will be one of the first monthly small business
         hazardous waste collections.

      3.  RWQCP approved hazardous waste plans from two
         hauling/silver reclamation firms for spent fix from
         medical offices and businesses. Although businesses
         are not required to contract with these two companies,
                                                                   RWQCP's screening process provides some assurance
                                                                   of the firms' reliability, as well as approved fee

                                                            a  RWQCP is establishing a data base to handle the
                                                               administrative functions for a larger number of facilities.
                                                               The data base will allow quick access to information about
                                                               each facility and allow RWQCP to address potential
                                                            "  compliance issues efficiently. Prior to the Silver Reduction
                                                               Program there were approximately 50 permitted industrial
                                                               facilities. RWQCP currently permits and/or regulates
                                                               approximately 1200 facilities. RWQCP issues permits to
                                                               facilities discharging treated photoprocessing wastes and
                                                               sends a "hauling acknowledgement"  to any facility not
                                                               discharging waste solutions to inform the facility of the
                                                               hauling requirements of the ordinance.

                                                            Q  RWQCP distributes to facilities apreinspection notice to
                                                               highlight common violations and to help facilities remedy
                                                               compliance problems prior to inspections. These notices
                                                                have reduced administrative burdens for both facilities and
                                                            Q^  RWQCP has generated preprinted individualized annual
                                                                reports for dischargers mat simplify report completion.

                                                                 Currently, there are approximately 20 permitted
                                                            dischargers and 350 generators regulated under the silver
                                                            reduction amendments to local sewer ordinances. Since the
                                                            middle of. 1991, with the help of the regulated community,
                                                            RWQCP-has attained the goal of reducing silver effluent by 75
                                                            percent  The annual maximum silver concentration in
                                                            RWQCP^effluent decreased from 14 parts per billion (ppb) in
                                                            1989 to 9 ppb in 1990, and to 2.4 ppb in 1991. The current
                                                            NPDES  requirement is 2.3 ppb. The early reduction in 1990
                                                            was due to both the extensive outreach and information
                                                            campaign anticipating the upcoming ordinances, and the
                                                            industrial waste program's successes in general. RWQCP
                                                            plans to continue streamlining adniinistrative requirements in an
                                                            effort to reach the NPDES requirements for silver and duplicate
                                                            their success with other metals.

                                                                  The Vehicle Service Facilities Waste Minirnization
                                                             Program is in its early stages. As RWQCP conducts shop
                                                             visits, disseminates information, and conducts workshops
                                                             demonstrating BMPs, the level of compliance with the new
                                                             ordinances is expected to increase and the level of pollutants
                                                             dishcarged will decrease.

                                                             FOR  MORE INFORMATION
                                                                  To obtain additional information on Palo Alto's Source
                                                             Reduction Program, contact Suzanne Healy (415-329-2117) or
                                                             Ken Torke (415-329-2421) or write to:

                                                                        Regional Water Quality Control Plant
                                                                              2501 Embarcadero Way
                                                                             Palo Alto, California 94303
  For additional information about the MWPP Program, contact the U.S. EPA Office ofWastewater Enforcement and
  Compliance, (202) 260-5856.