United States Environmental Protection Agency Office of Water (WH-547) EPA832-F-93-008 September 1993 &EPA ^Streamlining Administrative Requirements Case Studies PROGRAM DESCRIPTION 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 practices. PROGRAM OBJECTIVE 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. PROGRAM ACCOMPLISHMENTS 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 ------- CO o r»- i PJ Q. 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 structures. 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 inspectors. 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. ------- |