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,
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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.
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