United States
        Environmental Protection
        Agency
Office of Water
4301
EPA-820-R-94-004
   August 1994
EPA  INDUSTRIAL POLLUTION
        PREVENTION:

        Incentives and Disincentives
      An Industrial Pollution Prevention Project (IPS) Study

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                           TABLE OF CONTENTS


EXECUTIVE SUMMARY     	       1

1     INTRODUCTION     	       5

      1.1   Purpose and Objectives    	      5
      1.2   Study Approach and Data/Information Sources       ...     6
      1.3   Organization of Report    	      7

2     OVERVIEW OF INCENTIVES/DISINCENTIVES    	      8

      2.1   Regulatory Incentives and Disincentives     ....       9
      2.2   Economic Incentives and Disincentives      	    10
      2.3   Technical/Informational Incentives and
           Disincentives	      11
      2.4   Management/Institutional Incentives and
           Disincentives    	      12

3     DISCUSSION OF POLLUTION  PREVENTION
      INCENTIVE/DISINCENTIVE FINDINGS FOR METALPLATERS       ...    13

      3.1   Categorical Standards Are Outdated and Irrelevant        14
      3.2   Mass-Based Standards Are Motivators for Pollution
           Prevention   	'.	      18
      3.3   Enforcement and Compliance Activities  Tied to a
           Pollution Prevention Message is Key Motivator      .  .    25
      3.4   Economic Factors For Metalfinishers Have The
           Potential To Be Key Motivators, But There Are
           Significant Barriers    	     34
      3.5   Zero-Discharge Systems Can Promote Pollution
           Prevention But There Are Regulatory and
           Technical/Informational Barriers      	    39
      3.6   Flexibility in the Regulatory Netvrork, Supportive
           Technical Assistance and Outreach; and
           Collaborative Relationships      	     44

4     CASE EXAMPLE  OF SUCCESSFUL INTEGRATION OF POLLUTION
      PREVENTION MOTIVATORS    	     49

      4.1   Background:  Regional Water Quality Control Board        49
      4.2   Approach to Implementing NPDES Waste Minimization
           Provisions   	      50
      4.3   POTW Data Findings    	     50
      4.4   Regional Board Follow-up    	     52
      4.5   POTW Follow-up   	     53
      4.6   Relevance to Incentives Study     	    55

REFERENCES  -	- .  . . .  n „  .,.	      57

APPENDICES	.'»	      60

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                        EXECUTIVE SUMMARY

     This study examines the key regulatory,  economic,  technical,
and institutional incentives and disincentives affecting
decisions by industry to adopt pollution prevention measures.
The objective is to assist EPA and other regulatory agencies in
designing programs to encourage companies to consider and
implement pollution prevention approaches -- specifically, in the
context of determining how best to meet water quality and
effluent discharge obligations.  Much of past water program
efforts have been driven,  if not by direct "end-of-pipe"
requirements, then by an "end-of-pipe" mentality or approach to
interpreting the requirements.  Puller understanding of the
incentives and barriers faced by industry should help regulators
build pollution prevention into their regulatory and compliance
programs in a more meaningful way.

     While there is a range of factors that affect decisions by
facilities to either adopt or fail to adopt pollution prevention
measures, it seems there is often one key motivator --or
"trigger" incentive -- which can make the other acting incentives
more compelling, and which has the power to overcome the other
disincentives.  Trigger incentives will vary depending on
facility size and type, compliance history, and regulatory
motivation for pollution prevention.  In many instances,
enforcement action, coupled with a goal of working with the
company  (in terms of both regulatory flexibility and technical
assistance) toward a pollution prevention solution, has been a
strong trigger incentive.

     General Findings

The key motivational incentives and disincentives we found during
the course of this study are the following:

o    Flexibility

     Flexibility is perhaps the most important incentive to
     emphasize with respect to any regulatory or compliance
     program interested in fostering pollution prevention.  Those
     involved in developing regulations, permit writers who must
     translate those regulations and requirements into permit
     conditions, and compliance/enforcement personnel need to be
     aware of pollution prevention opportunities -- and they must
     be willing to work with companies to overcome both technical
     barriers and rigid regulatory interpretations.  Flexibility
     achieves its optimum value within a multi-media framework.
     Multimedia inspections, for example, encourage a
     comprehensive examination by both plant and compliance
     personnel for cross-media environmental improvements.  This
     reduces the risk of narrow, single-media solutions that can
     simply produce shifting of pollution.

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Economic Realities

Clearly, economic considerations are of paramount
importance. Companies are profit-motivated and while
pollution prevention can hold the promise of future cost
savings, if capital is needed for such changes, companies
can find themselves in a Catch-22 type situation.  Lower
operating costs could improve profits, but the extra capital
may simply not be available to pay for the necessary
improvements.  This is especially true of firms with low
profit margins and who are perceived by lenders to be a bad
investment risk.  For those companies who can raise the
capital, pollution prevention measures still hold an element
of risk -- they can be technically more complex, require
higher skill levels to operate and maintain, and they
sometimes fail to provide the kind of compliance "certainty"
an end-of-pipe system can engender.

Technical and Financial Assistance

Technical/informational incentives can work together to
facilitate pollution prevention.  Particularly for small
companies that do not have the resources, personnel, or
expertise to pursue and obtain reliable pollution prevention
information, a network of technical assistance is vital.
Whether the assistance comes from state programs, POTWs,
EPA, trade associations, or vendors, is not as important as
the fact that a system of information dissemination and
technical expertise is out there reaching companies who need
it.  Larger companies have more technical resources on hand
to experiment with in-process changes.  Small and
medium-size firms may need both technical assistance and
financial incentive mechanisms -- tax breaks, low-cost
loans, matching grants, etc. --to move them toward
pollution prevention.

Open Communication

An open door policy that allows all stakeholders to have a
say in how best to optimize pollution prevention
opportunities is key.  This is true for both companies and
regulatory agencies.  Upper management support for the
principles of pollution prevention can make all the
difference when either regulatory staff  (permit writers,
inspectors) or plant-level personnel  (engineers, shop
foremen, workers) have ideas they would like to see put into
practice.  Innovation and effective communication will
always remain the heart of pollution prevention.

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The following tables summarize the regulatory,  economic,
technical/informational, and management/institutional factors
that affect whether facilities decide to adopt  or fail to adopt
pollution prevention measures.

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       Regulatory Factors in Pollution Prevention Decisions
 REGULATORY INCENTIVES
                                   REGULATORS? TYTS i ur*i«!tfi11 v/fcsi
 flexible, multi-media
 regulatory  framework
                                     single-media regulatory
                                     framework
                                     single-media permits that
                                     focus on end-of-pipe
                                     requirements
specific toxics use
reduction laws or facility
planning statutes that
encourage firms to do P2
opportunity assessments and
audits
                                     single-media inspections
                                     with no pollution
                                     prevention message (i.e.,
                                     quick-fix, end-of-pipe
                                     compliance focus)
compliance inspections
where NOVs are tied to a
pollution prevention
message (e.g., referral to
state technical assistance
program)
 flexibility within
 compliance and enforcement
 programs   (e.g.,extended
 compliance schedules phased
 to pollution prevention
 activities, "soft landings"
 for technical  failure of
 innovative technologies)
                                     inflexible approach to
                                     media-specific enforcement
                                     actions that allows no time
                                     for process innovation or
                                     exploration of pollution
                                     prevention solutions
strict local  limits, with
POTW ordinance  authority  to
implement/enforce
                                    reliance on EPA categorical
                                    limits which may be
                                    outdated and set too low a
                                    compliance level
regulatory pressures on
POIWs such as EPA sludge
regulations, or air toxics
reduction requirements,
motivating POTWs  to push
upstream sources  to lower
metals in wastewaters—
ideally through pollution
prevention measures
                                    specific regulatory
                                    "barriers" such as  RCRA
                                    Part B permit requirements
                                    for facilities implementing
                                    reuse/recovery technologies
                                    or "zero discharge" systems

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SEPs with pollution
prevention requirements;
promotion of pollution
prevention alternatives in
enforcement case context
mass-based or total
loadings-based standards—
especially for water
intensive industries—that
may encourage water
reclamation/recycling/re-
use
guidance documents used by
permit writers that may be
outdated and focus on end-
of-pipe solutions
concentration-based
standards that may
discourage water
reclamation/recycling/re-
use

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      Economic Factors in Pollution Prevention Decisions
  ECOMOMIC INCENTIVES
 lower facility operational
 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
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 lenders)
— "sunken investments"
conventional pollution
control equipment
in
— many small firms—
especially "job shops"—
cannot tolerate down-time
for equipment upgrades or
process change/experiments
 fee structures  based on
 pollutant loadings (permit
 fees,  POIW fees,  etc.) can
 act as economic incentive
 for pollution prevention
economies of scale for some
technologies may not be
realistic at smaller firms
(e.g., metal recovery
technologies, automatic
systems vs. batch)
R & D challenge grants, low
interest  loans, tax breaks
for equipment upgrades, and
other funding assistance
mechanisms can be powerful
incentive—but only if
message gets to company
about availability  and if
application process is not
onerous
enhanced product quality
and/or corporate image may
lead to higher revenues
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
customer dissatisfaction
with changed product may
mean loss of revenue

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full/total cost accounting
methodologies can help
firms identify economic
savings and opportunities
not readily apparent—but
there is a real need for
simpler, user-friendly,
methods such as a quick
checklist or worksheet that
small firms can use
full/total cost accounting
to justify pollution
prevention expenditures can
be complex, time-consuming,
and expensive (especially
for small firms)

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       Technical/Informational Factors in Pollution Prevention
                          Decisions
 TECH/INFO INCENTIVES
technical assistance to
facility via state TAP or
POTW pretreatment programs
can  overcome many
informational barriers
facility unfamiliar with
pollution prevention and
potential for in-process
changes
targeted outreach to a
particular industry sector
via pollution prevention
workshops,  seminars,  or
training—provide forum for
industry to share success
stories  and concerns
facility uncertain of
pollution prevention's
ability to meet discharge
limits; afraid to be first
or to take risk
vendor lists or
certification  programs  to
assure prospective
purchasers/service users
that vendor is both
reputable and  knowledgeable
about pollution prevention
technologies
unscrupulous vendors who
misinform, misrepresent
and/or install inferior
equipment; so-called
"pollution prevention
experts" who sell a product
then disappear when the
system falls and the
facility falls out of
compliance
detailed knowledge of waste
generation and chemical
usage via facility audit/
opportunity assessment
lack of detailed knowledge
of waste streams and extent
of in-process use of toxic
chemicals
trade and industry
associations that encourage
and disseminate pollution
prevention information
customer satisfaction
concerns—potential impacts
of pollution prevention on
product quality,
appearance, or performance
that could translate into
loss of customer acceptance

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permit writer and inspector
training on how pollution
prevention can achieve,
maintain, or even go beyond
compliance
chemical or product
substitution concerns: will
it: a) do the job; b) be
consistently available; c)
not become expensive; and
d) not trigger some other
unforeseen regulatory
nightmare
                                    proprietary information
                                    concerns—disincentive to
                                    sharing information, data,
                                    and/or experiences with new
                                    processes

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            Management/Institutional Factors in Pollution
                    Prevention Decisions
MGMT/IMSTIT. INCENTIVES
 corporate policy supporting
 pollution prevention or
 incorporating it into
 strategic planning
                                     no upper management
                                     commitment to pollution
                                     prevention
 accountability within
 management structure for
 integrated (i.e., across
 departments, groups, or
 divisions) environmental
 responsibility
                                     lack of coordination and
                                     accountability among
                                     different groups in the
                                     company (e.g., process
                                     engineers/product design
                                     engineers not talking to
                                     environmental engineers)
 willingness to take risks
                                     low tolerance for failure;
                                     policy of risk avoidance
                                     closed shop mentality;
                                     afraid to ask questions—
                                     "What I don't know won't
                                     hurt me."
willingness to engage in
open dialogue with both
regulators and technical
assistance personnel
 TQM programs that empower
 employees to seek pollution
 prevention opportunities
                                    bean-counting disincentives
                                    at regulatory agencies that
                                    tie performance reviews to
                                    number of enforcement
                                    cases, number of permits,
                                    etc.  instead of rewarding
                                    quality environmental
                                    results
potential for favorable
publicity;  pollution
prevention helps present a
"good guy" image; like to
show progress (e.g.,  lower
TRI  numbers)
                                     do not want to call
                                     attention to themselves—
                                     e.g., if company has been
                                     "burned" once by EPA, will
                                     be reluctant to try
                                     anything new which might
                                     draw more attention

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inertia: "If it ain't
broke, don't fix it."
supportive environment
within (and between)
regulatory agencies;
openess to pollution
prevention

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Specific Findings

     Our study indicates that,  for metalfinishers and platers who
may be 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 enforcement and compliance activities are tied to a
     strong pollution prevention message, they can be a key
     motivator for facilities to adopt pollution prevention.


o    Economic factors have the potential to be key motivators,
     but there can also sometimes be significant barriers
     countering this potential.


o    Zero-discharge systems 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 to the successful use of
     such systems.


o    Flexibility in the regulatory network, supportive
     assistance/outreach, and collaborative relationships between
     industry, regulators, and the public can foster continuous,
     industry-wide improvement in pollution prevention.

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     INTRODUCTION
     1.1  Purpose and Objectives

     EPA's Pollution Prevention Strategy establishes pollution
prevention, including both source reduction and toxics use
reduction, as the priority approach for reducing releases of
pollutants into the 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 (IP3), for which this
report was written, is one of the Agency's 2% set-aside
initiatives.  The IPS is an Agency-wide, multi-media project, the
objectives of which are to: 1)  incorporate pollution prevention
into the industrial effluent guidelines process; and 2) reach out
to industry and the public to spread and establish the pollution
prevention ethic.

     This study examines some of 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
program 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-pipe" 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) practices, 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

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agencies  in designing programs  to  encourage companies to consider
and implement  pollution prevention approaches in the course of
determining how best to meet  their water quality and effluent
discharge obligations.


      1.2   Study Approach and  Data/Information Sources

      The  technical  approach focused on providing--to as great an
extent  as possible--both specific  information about decisions to
adopt (or not  adopt)  pollution  prevention measures at individual
metalfinishing facilities,  and  more general information on
choices faced  by a  broader  range of facilities, including other
metals  dischargers  and the  POTWs themselves.  This involved
on-site visits to six facilities and  three POTWs in the
Massachusetts  and Rhode Island  areas  (summarized in Appendix A) .
The site  visits were undertaken in order to obtain a fairly
detailed  assessment of particular  decisions at a limited number
of facilities,  including record review  (where possible), tour of
plating shops,  tour of wastewater  treatment plants, and in-depth
interviews and meetings with  facility personnel and knowledgeable
EPA regional,  state,  local, and POTW  representatives.

      In addition to the detailed assessments, more general
assessments of decisions at a larger  number of facilities were
undertaken,  largely through telephone interviews and database or
literature searches.   Over  100  metalfinishing case studies from
EPA's Pollution Prevention  Information Clearinghouse (PPIC)
database  were  reviewed; however, the  PPIC case studies are
technology-oriented,  rather than behavior-oriented, and seldom
provide useful information  about motivational aspects of the
pollution prevention alternative  (such as why the company had
explored  pollution  prevention in the  first place and whether or
not it  was ever implemented) .   Although there were many relevant
PPIC  case studies,  only 5 representative PPIC cases are presented
in Appendix B.   Literature  data and other case study reports were
obtained  from  a variety of  sources, including the California
Department of  Health Services and  the Massachusetts Department of
Environmental  Management.

      In addition to the site  visits,  case studies, and literature
reviewed,  telephone contacts  were  made with metalplaters and
state and local (both regulatory and  non-regulatory) personnel in
other geographic regions, including California, Florida,
Illinois,  Minnesota,  and North  Carolina, to obtain a broader
perspective  on the  national range  of  incentives and disincentives
faced by  platers.   Members  of the  IPS Focus Group have reviewed
and provided comments on early  drafts of this report.
Subsequently,  follow-up contacts were made with both industry and
POTW representatives  on the Focus  Group to clarify comments and
further explore ways  to improve the report.

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     1.3  Organization of Report

     Section 1 is a brief introduction to the study.

     Section 2 presents an overview of four major
incentives/disincentives areas: regulatory, economic,
technical/information, and management/ institutional factors that
can act upon the decision matrices of companies thinking of
adopting pollution prevention measures.

     Section 3 gives a detailed discussion of the study's
findings of the key motivating factors relative to pollution
prevention for metalplaters.

     Section 4 offers a detailed case example of a regulatory
POTW program that illustrates how incentives and disincentives
can function together to motivate a change to pollution
prevention.

     The Appendices contain more specific information about the
case studies and site visits completed for this project.
Appendix A covers the industrial and POTW site visits in Rhode
Island and Massachusetts.  Appendix B presents the selected PPIC
case studies and discusses their relevance to this study.
Appendix C is a matrix of completed telephone contacts.

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2   OVERVIEW OP POLLUTION PREVENTION INCENTIVES AND DISINCENTIVES


     We present here four summary tables and a general discussion
of the range of factors that affect decisions by facilities --
specifically, metalplaters --to either adopt or fail to adopt
pollution prevention measures.  Generally, these factors can be
viewed as either behavioral incentives or disincentives/ however,
that is not to say that one single factor, acting alone, will
push a company either toward or away from pollution prevention.
A facility will most likely adopt pollution prevention measures
when it is being acted upon by an array of incentives.  Likewise,
it will be the cumulative effect of a number of disincentives
which makes a company decide not to do pollution prevention.
Sometimes, Incentives and disincentives tend to cancel each other
out -- i.e., they have equal weight in the decision process --
the result being no progress is made toward pollution prevention.
For example, the economic incentive of potential cost savings due
to decreased environmental management expenditures (lower
disposal fees for less toxic waste, lower chemical usage, etc.)
is oftentimes counterbalanced by the fact that the capital needed
to implement the changes cannot be raised.  This is especially
true of certain metalplating firms which have low profit margins
and are perceived by lenders to be a bad investment risk.

     Sometimes, it seems there is one key motivator,  or "trigger"
incentive which, once activated, makes the other acting
incentives more compelling, and which has the power to overcome
the various disincentives.  Enforcement -- whether in the context
of bringing a firm into compliance or implementing new
requirements (e.g., more stringent discharge limits)  -- is one
example of a "trigger"  (some would say a "hammer" motivator), in
that a behavioral decision is forced to occur.  If the
enforcement or compliance message supports pollution prevention
and is flexible towards allowing for the necessary time and
resources a facility needs to explore and implement such
solutions, then the disincentive hurdles may be lowered just
enough to make the facility "go for it."
                                8

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     2.1  Regulatory Incentives and Disincentives (Table 2.1)

     Flexibility is the most important incentive to emphasize
with respect to any regulatory or compliance program interested
in fostering pollution prevention.  On the permitting side,  those
involved in developing regulations,  as well as the permit writers
who must translate those regulations and requirements into permit
conditions, need to be aware of the range of pollution prevention
opportunities available for the industry sector under question.
Unlike standard, end-of-the pipe, pollution control options,
pollution prevention techniques and technologies may require more
research and lead time to implement.  On the compliance end,
inspectors and enforcement personnel must be willing to work with
those companies who are seeking pollution prevention rather than
simply control solutions --no industry will try anything
innovative if threatened with both the loss of capital and costly
enforcement actions in spite of their best efforts.  Many of the
firms we visited would not have even attempted pollution
prevention alternatives if they did not have the support of both
regulators and compliance personnel.

     Although flexibility is key, even within a single media
regulatory framework,  it achieves its optimum value -- pollution
prevention-wise -- when it occurs within a multi-media framework.
Multimedia inspections, for example, may identify opportunities
or threats to more than one media and reduce the risk of narrow,
single-media solutions that can simply produce media shifting of
pollution.  Multimedia inspections encourage a comprehensive
examination by both plant and compliance personnel for total
environmental management opportunities.  When such inspections
are augmented by technical assistance programs -- especially for
small to medium-sized firms -- there is a higher likelihood of a
facility actually adopting pollution prevention measures.

     On the other hand, the largest disincentive for any firm
considering pollution prevention is concern about the difficulty
(real or perceived) of working with permitters and inspectors who
are inflexible, who might not listen to their innovative ideas,
who may -- regardless of intent or potential for quality
environmental benefits down the road  (e.g., from permanent
reduction of toxics via process changes) -- enforce so strictly
that the firm's only safety will be to, in the end, install or
upgrade pollution control equipment anyway.

     This is also where a single media regulatory and compliance
framework works as a disincentive.  A facility may have an air
permitter or inspector willing to listen and work with them on
pollution prevention, but unless they are equally confident about
the other media programs' support of the concept, they may be
unwilling to try something new for  fear of either falling out  of
compliance on those permits during  the  "trial and error" stage  of
process changes, or of bringing  themselves into new regulatory

                                 9

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Table 2.1  Regulatory Factors in Pollution Prevention Decisions
     REGULATORY INCENTIVES
REGULATORY DISINCENTIVES
     flexible,  multi-media
     regulatory framework
 single-media regulatory
 framework
     specific toxics use
     reduction laws or facility
     planning statutes that
     encourage firms to do P2
     opportunity assessments and
     audits
 single-media permits that
 focus on end-of-pipe
 requirements
    compliance inspections
    where NOVs are tied to  a
    pollution prevention
    message (e.g., referral to
    state technical assistance
    program)
 single-media inspections
 with no pollution
 prevention message (i.e.,
 quick-fix, end-of-pipe
 compliance focus)
    flexibility within
    compliance and enforcement
    programs   (e.g.,extended
    compliance schedules  phased
    to pollution  prevention
    activities, "soft landings"
    for technical failure of
    innovative technologies)
 inflexible approach to
 media-specific enforcement
 actions that allows no time
 for process innovation or
 exploration of pollution
 prevention solutions
    strict local  limits, with
    POTW ordinance authority to
    implement/enforce
 reliance on EPA categorical
 limits which may be
 outdated and set too low a
 compliance level
    regulatory pressures on
    POTWs such as EPA sludge
    regulations, or air toxics
    reduction requirements,
    motivating POTWs  to push
    upstream sources  to lower
    metals in wastewaters—
    ideally through pollution
    prevention measures
 specific regulatory
 "barriers" such as RCRA
 Part B permit requirements
 for facilities implementing
 reuse/recovery technologies
 ™- "zero discharge" systems
or

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SEPs with pollution
prevention requirements;
promotion of pollution
prevention alternatives in
enforcement case context
mass-based or total
loadings-based standards—
especially for water
intensive industries—that
may encourage water
reclamation/recycling/re-
use
guidance documents used by
permit writers that may be
outdated and focus on end-
of-pipe solutions
concentration-based
standards that may
discourage water
reclamation/recycling/re-
use

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realms.   A case in point is the issue of threatened RCRA Part B
permitting for those facilities considering  "zero discharge"
solutions.  Unless all the media programs present a unified,
pollution prevent ion-friendly front, a  firm  will be less likely
to  "take the risk."


      2.2  Economic Incentives and Disincentives  (Table 2.2)

      Clearly,  economic considerations are of paramount importance
to  industry.  Companies are prof it-motivated, and while pollution
prevention measures can hold the promise of  future cost savings,
if  capital investment is needed for such changes, companies --
especially low profit margin platers -- can  find themselves in a
Catch-22 type situation.  Lower operating costs could improve
profits,  but extra capital may not be available to make the
necessary improvements.  We visited one firm, New England Plating
 (see  Appendix A) , that spent 14% of its annual sales income on
keeping  an overtaxed, 20-year old,  wastewater treatment system
operational.  In addition to the "sunken investment" that system
represented, the firm operated on such  a low margin, they could
not tolerate downtime for major equipment changes.  There were
also  space considerations -- multiple rinse  tanks would take up
more  linear space than available in the current location.
Moreover,  their financial situation was so precarious that no
bank  would consider them for a loan.  The pollution prevention
economic incentive "carrot" in such cases is therefore quite
useless  unless accompanied by some means of  facilitation -- such
as  low cost loans or tax breaks for equipment upgrades.

      In  a very competitive industry, customer satisfaction is
key.   The "job shop" service sector of  the surface finishing
industry lives and dies by serving the needs of a variety of
customers.  The job shop that gives the best turnaround time at
the lowest per part cost will get the most business.  The
customer wants quality plating at low cost according to his time
schedule -- he is usually not really interested in how that is
done  (i.e.,  whether in the most environmentally friendly way.)
In  considering pollution prevention measures, especially those
involving changes in plating chemistry, concern about potential
customer dissatisfaction with the new product or with longer
turnaround times  is real and a very potent disincentive.  One
plater spoke about how his largest customer  wanted the insides of
a computer housing cabinet plated with  copper cyanide (one of the
more  toxic plating chemistries) ,  because he  was presenting the
item  at  a trade show and wanted the inside of the cabinet to show
off "that  pretty  blue color."  The realities of trying to satisfy
customer  requirements can sometimes prevent  companies from taking
pollution prevention actions.

     There is  a difference between large and small companies in
terms  of  the level of capital investment and their ability to

                                10

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Table 2.2  Economic Factors in Pollution Prevention Decisions
       ECONOMIC
ECONOMIC DISINCENTIVE!
      lower facility operational
      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
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 lenders)
— "sunken investments"
conventional pollution
control equipment
in
— many small firms—
especially "job shops"—
cannot tolerate down-time
for equipment upgrades or
process change/experiments
      fee structures based on
      pollutant loadings (permit
      fees,  POTW fees,  etc.)  can
      act as economic incentive
      for pollution prevention
economies of scale for some
technologies may not be
realistic at smaller firms
(e.g., metal recovery
technologies, automatic
systems vs. batch)
      R & D challenge grants,  low
      interest loans, tax breaks
      for equipment upgrades,  and
      other funding assistance
      mechanisms can be powerful
      incentive—but only if
      message gets to company
      about availability and if
      application process is not
      onerous
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
fans
      enhanced product quality
      and/or corporate image may
      lead to higher revenues
customer dissatisfaction
with changed product may
mean loss of revenue

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full/total cost accounting
to justify pollution
prevention expenditures can
be complex, time-consuming,
and expensive (especially
for small  firms)
full/total cost accounting
methodologies can help
firms identify economic
savings and opportunities
not readily apparent—but
there is a real need for
simpler, user-friendly,
methods such as a quick
checklist or vrorksheet that
small firms can use

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raise it.  Large companies with captive plating shops,  such as in
the aerospace industry, can absorb more risk -- both in terms of
investment and in the regulatory arena.  They also have more
technical resources on hand to experiment with in-process
changes.  However, both large and small companies cannot ignore
customer satisfaction concerns.
     2.3  Technical/Informational Incentives and Disincentives
          (Table 2.3)

     All of the technical/informational incentives work together
to facilitate pollution prevention.   Particularly for small
companies that do not have the resources,  personnel,  or expertise
to pursue and obtain good technical  information,  a network of
technical assistance is vital.  Whether the technical assistance
comes from state programs, POTWs, EPA,  trade associations, or
vendors, is not as important as the  fact that a system of
information dissemination and technical expertise is  out there
reaching companies who need it.  As  success stories build and
innovative technologies become more  commonly used, a  domino
effect can ripple through an industry-   Five years ago, aqueous
parts washing systems were fairly new,  used by only the more
adventurous firms.  Today, with the  phase-out of TCA  and other
ozone depleters, as well as growing  regulatory discouragement
towards chlorinated solvents of any  kind,  aqueous systems are
finding their way into even the most staid shops.  This is due to
the concerted effort of all technical outreach channels.

     Continued, coordinated technical assistance and  outreach are
the most appropriate tools for industry-wide progress in
pollution prevention.  As discussed  in section 2.1, compliance
mechanisms can be a key motivator for pollution prevention, but
one characteristic of such "hammer"  incentives is that their
application and effect does not necessarily promote pollution
prevention consistently either industry-wide or across all media.
Pollution prevention may take place  because of an enforcement
action, but not all facilities industry-side face such actions.
Technical assistance and outreach is the best way to reach all
facilities -- including those in compliance -- and show them how
to not only "meet their limits," but go beyond.

     One of the biggest disincentives,  however, in the technical/
informational area is concern about  the unscrupulous vendor.  One
bad "horror story" -- about a vendor who installs a so-called
pollution prevention technology, then skips town when the system
fails, and EPA or the state starts breathing down the company's
neck -- can also ripple through an industry, turning many away
from trying anything new.  This is a problem faced mostly by
smaller companies who rely more on outside expertise.  Any vendor
can set himself up as a pollution prevention "expert."  Companies
selling pollution prevention equipment proliferate seemingly

                                11

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Table 2.3  Technical/Informational Factors in Pollution Prevention
                              Decisions
      TECH/INFO  INCENTIVES
     technical assistance to
     facility via state TAP or
     POTW pretreatment programs
     can overcome many
     informational barriers
facility unfamiliar with
pollution prevention and
potential for in-process
changes
     targeted outreach to a
     particular industry sector
     via pollution prevention
     workshops, seminars, or
     training—provide forum for
     industry to share success
     stories and concerns
facility uncertain of
pollution prevention's
ability to meet discharge
limits; afraid to be first
or to take risk
     vendor lists or
     certification programs to
     assure prospective
     purchasers/service users
     that vendor is both
     reputable and knowledgeable
     about pollution prevention
     technologies
unscrupulous vendors who
misinform,  misrepresent
and/or install inferior
equipment;  so-called
"pollution prevention
experts" who sell a product
then disappear when the
system fails and the
facility falls out of
compliance
     detailed knowledge of waste
     generation and chemical
     usage via facility audit/
     opportunity assessment
lack of detailed knowledge
of waste streams and extent
of in-process use of toxic
chemicals
     trade and industry
     associations that encourage
     and disseminate pollution
     prevention information
customer satisfaction
concerns—potential impacts
of pollution prevention on
product quality,
appearance, or performance
that could translate into
loss of customer acceptance

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permit writer and inspector
training on how pollution
prevention can achieve,
maintain, or even go beyond
compliance
chemical or product
substitution concerns: will
it: a) do the job; b) be
consistently available; c)
not become expensive; and
d) not trigger some other
unforeseen regulatory
nightmare
                                    proprietary information
                                    concerns—disincentive to
                                    sharing information, data,
                                    and/or experiences with new
                                    processes

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overnight,  often with little  basis  in  capital or technology.  The
problem is  the vendor who sells  the equipment then either goes
out  of  business or renegs on  his guarantees.  One way to deal
with this issue is to provide facilities with approved vendor
lists or to initiate some sort of vendor certification program
 (perhaps through one or more  trade  associations).


      2.4 Management/Institutional  Incentives and Disincentives
           (Table 2.4)

      An open door policy that allows all stakeholders to have a
say  in  how  best to optimize pollution  prevention opportunities
can  be  a key factor.  This is true  for both companies and
regulatory  agencies.  Upper management support for the principles
of pollution prevention can make all the difference when either
regulatory  staff (permit writers, inspectors) or plant-level
personnel (engineers,  shop foremen,  workers) have ideas they
would like  to see put into practice.   If you don't think your
boss will be receptive,  you won't risk opening your mouth.  The
same goes for interactions between  regulators and the regulated
industry.  If there is an atmosphere of mistrust, even good
questions won't get asked. At one  facility we visited, Parker
Metals  (see Appendix A), the  Environmental Coordinator was
forbidden by his management to call EPA with questions because of
an incident in the past when  one of those "innocent little
questions"  caused a party of  inspectors to come pay an
unscheduled visit.   That is why  Massachusetts's technical
assistance  program,  MassOTA,  is  housed in a non-regulatory
agency-   They want it clearly understood that facilities can come
to them with problems and questions without fear of retribution.

      For larger companies, an incentive for undertaking pollution
prevention  is the opportunity for improving their public image.
For  TRI  reporters,  reducing the  release of toxics and moving
lower down  on the list of "top polluters" can be a way to
demonstrate corporate environmental progress.  Such good press
can  often translate into increased  revenues as the company
becomes  perceived as being pro-environment, or at least more
environmentally conscious than other competitors.  Governor's
awards and  other publicity-related  incentives are also part of
this  reward system.   EPA's 33/50 program, "Green Lights" program,
and  other public-private partnerships  have been most successful
in harnessing this need for good press and motivating companies
to voluntarily reduce toxic discharges and emissions.  Even for
smaller  companies,  any kind of positive reinforcement -- such as
articles  in the local  paper or in a trade journal -- can make a
difference  and encourage them to continue pursuing the goals of
pollution prevention.
                                12

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Table  2.4  Management/Institutional Factors in Pollution
                   Prevention Decisions
                     HJ*
MGMT/INSTIT. DISINCENTIVES
corporate policy supporting
pollution prevention or
incorporating it into
strategic planning
  no upper management
  commitment to pollution
  prevention
accountability within
management structure for
integrated (i.e., across
departments, groups, or
divisions) environmental
responsibility
  lack of coordination and
  accountability among
  different groups in the
  company (e.g., process
  engineers/product design
  engineers not talking to
  environmental engineers)
willingness to take risks
  low tolerance for failure;
  policy of risk avoidance
willingness to engage in
open dialogue with both
regulators and technical
assistance personnel
  closed shop mentality;
  afraid to ask questions—
  "What I don't know won't
  hurt me."
TQM programs that empower
employees to seek pollution
prevention opportunities
  bean-counting disincentives
  at regulatory agencies that
  tie performance reviews to
  number of enforcement
  cases, number of permits,
  etc. instead of rewarding
  quality environmental
  results
potential for favorable
publicity; pollution
prevention helps present a
"good guy" image; like to
show progress (e.g., lower
TRI numbers)
  do not want to call
  attention to themselves—
  e.g., if company has been
  "burned" once by EPA, will
  be reluctant to try
  anything new which might
  draw more attention

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inertia: "If it ain't
broke, don't fix it."
supportive environment
within  (and between)
regulatory agencies;
openess to pollution
prevention

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3    DISCUSSION OP POLLUTION PREVENTION INCENTIVE/DISINCENTIVE
     FINDINGS FOR METALPLATERS

     We discuss here some of the key factors we found important
for metalplaters who may be considering pollution prevention.
These findings are based on case studies, site visits,  industry
and POTW/regulatory agency contacts, as well as discussions
involving the IPS Focus Group.  The six main findings are:

     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 enforcement and compliance activities are tied to
          a strong pollution prevention message, they can be a
          key motivator for facilities to adopt pollution
          prevention.

     o    Economic factors have the potential to be key
          motivators, but there can also sometimes be significant
          barriers countering this potential.

     o    Zero-discharge systems 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 to the
          successful use of such systems.

     o    Flexibility in the regulatory network, supportive
          assistance/outreach, and collaborative relationships
          between industry, regulators, and the public can foster
          continuous, industry-wide improvement in pollution
          prevention.


     3.1  Categorical Standards Are Outdated and Irrelevant

     The current national categorical standards for
electroplaters and metal finishers were promulgated  in June,
1983, and have not been revised since.  Most platers can and do
now achieve much lower numbers.  Local limits placed on them by
their POTWs  (many platers are indirect dischargers and thus  do
not have their own NPDES permits) are increasingly governed  by
water quality criteria, which very often translates  into lower
limits than the categorical standards.

                                13

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     Another consideration for POTWs  is compliance with the new
 sludge  regulations:   high metals  in sludges may limit what
 options POTWs have for sludge  disposal.  Even where POTWs have
 not  set their own lower local  limits  -- due to either sludge
 quality or other local considerations -- NPDES permit renewals
 for  POTWs are increasingly utilizing  water quality standards for
 toxics  resulting in both newer, more  chemical-specific limits and
 lower limits overall. Through  their pretreatment programs, POTWs
 will push for source reductions from  their service area users --
 including metalplaters --to help them comply with tighter NPDES
 permit  conditions.

     Direct dischargers also have not escaped from the recent
 push towards water quality based  limits. Implementation of CWA
 section 304(1)  -- which requires  states to identify receiving
 waters  where technology-based  effluent limits have not resulted
 in achievement of water quality standards for toxics -- indicates
 that metal-finishers are the single largest category of direct
 discharger sources on states'  Individual Control Strategy  (ICS)
 lists of impaired waters.   In  addition, many POTWs also appear on
 the  state ICS lists, in part due  to metal finishing facilities in
 their service areas.  The combined effect is that, for the
 majority of metalfinishers,  compliance is increasingly dictated
 not  by  the 1983 technology-based  national categorical limits, but
 by evolving water quality-based standards, implemented through
 modified NPDES permits for point  sources or through pretreatment
 programs or local limits at their POTW.  Table 3.1 compares
 selected local limits and categorical limits for metalfinishers.


           3.1.. 1     Categorical Limits and Pollution Prevention

     Categorical standards by  design  reflect what pollution
 reductions can be achieved using  the  Best Available Technology
 (BAT) economically achievable  (33 USCA 1317, Sec. 307) .  EPA
 defines BAT as the "very best  control and treatment measures that
 have been or are capable of being achieved."  In the guideline
 development process, EPA may consider in-plant process changes in
 addition to end-of-pipe treatment measures.  For new sources  (New
 Source  Performance Standards--NSPS) ,  there should be a stronger
 consideration of alternative production processes, operating
 methods,  in-plant control procedures  and other major design
 elements that should, theoretically,  encompass pollution
 prevention more fully.

     However,  for the metalfinishing  categoricals developed in
 the  early 1980's,  there was essentially no difference between BAT
 and  NSPS -- except for slightly lower cadmium limits.  And the
 development document, while covering  some types of in-plant
process  change  options,  in the end recommended the same chemical
precipitation end-of-pipe technology  for both BAT and NSPS.  The

                                14

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  Table 3.1  Comparison of Categoricals and Local Limits
Metals

Cadmium

Chromium
(total)
Copper

Cyanide
(total)

Lead

Nickel

Silver

Zinc

Antimony

Arsenic

Beryllium

Mercury

Thallium
Warwick*
POTW Local
Limits
(mg/1)
Upper
Blackstone*
POTW Local
Limits
(mg/1)
0.05
0.5
0.7 / O.ld
0.2
0.15 /0.03d
0.5
0.05 /0.01d
1.0
0.5
0.1
0.1
0.03
0.1
0.69
2.77
3.38
1.20
0.69
3.98
0.43
2.61
no limit
no limit
no limit
no limit
no limit
U.S.EPAb
Categorical
Limits for
Metal
Finishers
(mg/1)

0.69

2.77

3.38

1.20


0.69

3.98

0.43

2.61

no limit

no limit

no limit

no limit

no limit
Minimum
Reported
Local
Limits for
200 POTWsc
(mg/1)

0.0019

0.05

0.03

nd


0.02

0.05

0.03

0.05

0.02

nd

0.022

nd

0.2
a  As of August 1991.
b  Promulgated in June 1983.
c  U.S. EPA National Pretreatment Program RTC, July 1991.
d  Proposed changes to POTW's NPDES permit, August 1991.
                                15

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 legacy of  this is that,  even now,  with the  strides that have been
 made  in waste minimization and source reduction technical
 assistance for platers,  97% of metalfinishers  still utilize
 end-of-pipe chemical precipitation as their primary compliance
 mechanism.  Improvements have been made, both  to the treatment
 systems themselves and nup-pipe"  in metalfinishing operations
 (some 90%  of metalf inishers in a  recent NAMF survey stated that
 they  have  implemented some system or in-plant  improvements) ;
 however, metalf inishers  do not seem likely  to  give up the
 certainty  that comes with having  a treatment system they know
 will  at least keep them  in compliance with  BAT.

      In most cases, therefore,  pollution prevention measures
 considered by metalfinishers for  their facilities need to be
 compatible with the chemical precipitation  treatment systems they
 have  already invested in.  Radical changes, such as switching to
 closed-loop recycling (so called  "zero-discharge" systems), may
 be  less likely to be explored.  As EPA re-visits the
 metalfinishing effluent  category  -- either  separately or in
 conjunction with the new Metal Products and Machining  (MP&M)
 guideline  (to be promulgated by May 1996) -- fuller consideration
 may be needed of how pollution prevention measures can more fully
 be  incorporated into the guideline development process so that
 facilities are allowed real choices between control and
 prevention.   The important thing  is to provide industry some
 measure of certainty that given configurations of either control
 or  prevention can be used to achieve BAT or NSPS limits.


           3.1.2     Local Limits  and Pollution Prevention

      Rather than using the categorical standards in their
 pretreatment program,  a  POTW may  elect to seek passage or
 modification of a local  sewer use ordinance to establish more
 stringent  local limits.   As pretreatment standards applicable to
 all nondomestic dischargers,  local limits are  used to ensure
 compliance with the general and specific prohibitions of the
 general federal pretreatment regulations  (40 CFR 403).  Because
 they  apply to both categorical and noncategorical users, they
 give  pretreatment programs the needed latitude to set more
 stringent  standards than categorical standards, and regulate as
 wide  a group of nondomestic users as necessary to protect the
 POTW,  its  workers and the environment.  The POTW also has the
 option of  developing plant-specific permits to implement its
 pretreatment program.

      Although the development of  site-specific local limits is
 simple in  concept,  implementation is often  difficult and
 cumbersome.   EPA reported in its  July 1991  Report to Congress
 (RTC)   on the National  Pretreatment Program  that while 90% of the
pretreatment programs  they evaluated had adopted local limits for
 one or more  toxic constituents, the majority did not perform a

                                16

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headworks analysis as recommended by EPA to derive the limits.
These POTWs either adopted a neighboring city's limits or values
published in the literature.  Information collection activities
needed for headworks analyses include:

     o    identification of pollutants of concern
     o    determination of applicable environmental criteria
          (e.g., water-quality criteria)
     o    site-specific data (POTW data, industry data,  receiving
          water data, etc.)

     EPA's Pretreatment Implementation Review Team (PIRT)  Final
Report (January, 1985) found that POTWs generally did not
understand the relationship between categorical and local limits,
nor how to develop local limits.  Largely as a result of this,
the pretreatment regulations were amended in October 1988 to make
adoption of technically-based local limits a prerequisite for
program approval. Local limits derived from site-specific
information are considered technically-based limits.   More recent
amendments  (DSS, July 1990), require POTWs to evaluate the need
for updating local limits as part of their NPDES permit renewals
(i.e., every 5 years).

     Because of their application to all nondomestic dischargers,
local limits do provide some incentive for pollution prevention
strategies.  For example, local limits have been used to justify
non-discharge recycling strategies for silver users and auto
repair shops in Palo Alto.  Local limits for metalplaters are
often lower than categoricals.x  Table 3.1 shows that local
limits for metals in Warwick, R.I., as well as for some 200 POTWs
nationwide, are from 15 to 350 times lower than the national
standards.  The July 1991 RTC notes that only 6.8% of POTWs
required to have pretreatment programs use categoricals as the
basis for their local limits.  At our site visits in
Massachusetts, one POTW  (the Upper Blackstone Water Pollution
Abatement District) was using the 1983 metalfinishing categorical
standards for their pretreatment program local limits.  However,
they were also facing a NPDES permit renewal which, for the first
time, would specify fairly low metal limits for the POTW.
Because they felt that lowering their local limits -- i.e.,
passing on the responsibility of reducing metal discharges to
upstream sources -- would be politically unacceptable, the POTW
was researching how to comply with the new limits at the
treatment plant itself.  One option was to install a reverse
osmosis system to control metals which would cost several million
     1      However,  the  July 1991 RTC indicated that, for some
areas, use of the national  categorical standards in lieu of
locally derived  limits would have resulted in local limits
significantly higher  than the minimum national standards.


                                17

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dollars.

      The point  is  that  there  is no guarantee that by simply
lowering limits you will  produce a desired pollution prevention
response.   POTWs,  such  as the Upper Blackstone, could meet their
NPDES and  sludge limits without ratcheting down on industrial
users.  Or they could push industry to install conventional
pretreatment  systems, i.e., end-of-pipe controls.  Only when the
lower limits  are combined with pollution prevention technical
assistance and  outreach will  there be a greater likelihood that
industries needing to comply  with the lower limits will explore
pollution  prevention options.

      Moreover,  rapid regulatory changes, such as "overnight"
changes in local limits may well cause a treatment response
because firms (a)  do not  want to risk ultimately being out of
compliance,  (b)  may not be convinced they can make the limits in
time  using pollution prevention, or  (c) do not want to make
process changes hurriedly.  Another undesired response could be
for companies to move their facilities  (sometimes it need only be
"down the  street")  to a less  stringent POTW service area.
Regulators we spoke with  in Rhode Island had seen such
"POTW-shopping," especially with smaller, more mobile job shop
platers. Sufficient lead  time for responding to regulatory
changes coupled with flexibility in a pollution
prevent ion-supportive environment seems to be key in the choice
to respond to a regulatory stimulus with prevention rather than
treatment.
      3.2  Mass-Based Standards Are Motivators for Pollution
          Prevention

      For metalplaters,  mass-based limits  (whether
production-based or concentration-derived) are stronger pollution
prevention  motivators than concentration-based limits alone.
Mass-based  limits are more likely to foster rinsing process
modifications and true source reduction.  Many POTWs feel that
having the  flexibility to  adapt concentration-based standards to
mass-based  is vital to achieving their pollution prevention
goals.  Concentration-based  limits tend to discourage water use
reduction,  which is the heart of rinsing process modification and
critical to many metals recovery technologies.
Product ion-indexed mass-based limits, while supporting these
types of pollution prevention technologies, can be difficult to
calculate for metalplating,  however.  And everyone agrees that
concentration-based limits are easier to implement and enforce
against.  Nevertheless,  if EPA, states, and POTWs partner
together to overcome the difficulties and allow for more
flexibility in using mass-based limits, this could provide the
single largest incentive for electroplaters and metal finishers
to incorporate pollution prevention into their operations.

                                18

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          3.2.1     POTW Experience With Mass-Based Limits

     In California, POTWs in Orange County,  Palo Alto,  and Los
Angeles are either already using mass-based limits or are working
to implement them.  Other POTWs in North Carolina and Georgia are
actively pursuing the possibility.  However,  in many cases,
either state or EPA regional officials have been less than
supportive.  It appears that the POTWs are being treated less
like customers and more like regulated entities, as in fact they
are -- and the state/EPA positions have been that such regulated
entities  (POTWs) might be allowing CWA backsliding in terms of
failing to meet concentration-based limits,  even if total
loadings decrease due to mass-based limitations.  The 1987 CWA
amendments contained an wanti-backsliding" provision which
prohibits the relaxation of treatment requirements when an
existing permit is rewritten or renewed.  If the original permit
condition was a concentration-based one, there is some debate as
to whether switching to a mass-based standard -- even one which
is derived from the concentration-based limit -- represents
backsliding.  Different states and EPA regions have held
different opinions.  POTWs that have been able to implement
mass-based limits usually have done so only after long
negotiations with their regulators.

     The Orange County Sanitation Districts has been using
mass-based limits since August 1990.  They find it beneficial,
allowing them the needed flexibility to deal with diverse
technical and compliance problems.  They selected mass-based
limits as the compliance basis for all dischargers because of an
understanding that waste minimization -- reduction of water usage
and recycling.of wastes --is basically a concentrating process
which results in an increased waste stream concentration.  Orange
County has found that mass limits have encouraged water use
reductions  (important in water-poor southern California) and have
eliminated in principle the dilution of wastes.

     Mass limits are not used widely at POTWs around the country-
Even in California, few POTWs have taken that important step.
However, the experience is that mass limits are feasible even for
such large and diverse systems as the Orange County Sanitation
Districts.  The use of mass limits does require some retraining
and * re -thinking," but the benefits are worth the effort.  The
important thing is to allow POTWs the flexibility to choose what
works best for them -- mass-based, concentration-based, or some
combination.  POTWs need a range of choices that they can
translate into flexibility and incentives in their compliance and
pollution prevention programs.
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           3.2.2      EPA Experience With Mass-Based Limits

      In  the  Development Document  for Existing Source Pretreatment
for the  Electroplating Point  Source Category  (August, 1979), EPA
gives mass-based pretreatment standards for the electroplating
category and electroless plating  and printed circuit board
subcategories.   These limits  were calculated from
concentration-based standards,  using median plant water usage
data  for the three plating categories.  Water usage was defined
to be the liters of water used per each square meter plated for
each  plating operation.  "These limitations were calculated
specifically to  benefit a plant achieving water usage (i.e.,
volume of water  per unit of production) lower than the median
plant water  usage for its plating category-... In order to avoid
penalizing these plants or discouraging their water conservation
practices, mass-based limitations are calculated below,  as an
alternative  to the concentration-based limitations."2

      The Metal Finishing Point Source Category Development
Document (June 1983) ,  included electroplating as a unit
operation, and in some cases, superseded the August 1979
guideline.   In the 1983 document, it states that "Effluent
limitations  and  standards are expressed in concentration units
 (mg/1) without accompanying production based units.  Basing
limitations  and  standards on  production based units was rejected
after numerous attempts failed to find production related factors
which could  be correlated in  a statistically reliable manner with
wastewater flow.  This lack of correlation is understandable in
light of the number and complexity of metal finishing
manufacturing operations."3

      Although, early consideration of a mass-based or total
loadings alternative standard (essentially derived from the
concentration-based limits) seemed promising, it was abandoned
for the  metalfinishing category.  Since 1983, therefore, the
status quo for most metalfinishers has been compliance with a
strictly concentration-based  limitation.  The new Metal Products
and Machinery (Phase I) Effluent  Guideline -- to be proposed by
November 1994 and promulgated by  May 1996 --is reconsidering the
use of mass-based limits.   The MP&M guideline will cover
facilities that  manufacture,  rebuild or maintain finished metal
parts, products, or machines.  It is possible that changes to the
applicability of the 40 CFR 433 (Metal Finishing) and 40 CFR 413
     2      U.S.  EPA.  1979.  Development Document.. .Electroplating
Point Source Category,  pp.  396-406.


     3      U.S.  EPA.   1983.   Development Document...Metal
Finishing Point Source  category,  p.  1-1.


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(Electroplating) rules will be proposed along with the MP&M
proposal.  That means that if mass-based limits are chosen for
MP&M subcategories which overlap the 413 and 433 categories,  the
new limits may supersede those concentration-based limits.
Applicability issues have yet to be finalized.

     The current MP&M development effort is focused toward
gathering and analyzing data to decide between a mass-based and a
concentration-based guideline.  Various normalizing parameters,
such as pound of metals removed (i.e., from metal machining
operations), are being studied.  For plating,  parameters might
include micrograms plated per pound of production or pounds of
metal applied per square footage of production.  Various surface
area configurations and production scenarios may be considered.
Also being studied are ways to covert typical concentration-based
units, such as micrograms per liter, into a total loading-type
unit, such as milligrams per day.   At a minimum, EPA would like
to see flow control options worked into the guideline.

     Mass-based effluent guidelines are not really new for EPA --
they are simply proving a little more difficult to develop for
complex operations such s metal working, finishing, and plating.
Of the existing metals industry guidelines, ten are already
mass-based.  These guidelines include Aluminum Forming, Iron &
Steel Production, Nonferrous Metals Manufacturing, Battery
Manufacturing, among others.  Mass-based standards require more
data collection and analysis, and are typically viewed as more
difficult for the permit writer to implement. Concentration-based
standards may be easier to implement, but without some flow
control they can lead to poor water use practices to achieve
compliance.


          3.2.3     Mass-Based v.  Concentration-Based Limits

     The technical problems  (of permitting and reporting mass or
total loadings in addition to, or instead of, concentration)  are
not trivial.  But when metalplaters are given the option of
complying by cutting flows and improving metals management, some
of them will excel at preventing pollution from their shops.   A
perhaps obvious question arises:  if at any moment the physical
reality of the mass of metal and the flow of wastewater from a
facility are no different whether the limits are in terms of mass
or concentration  (i.e., if they are interchangeable or
"convertible"), what difference does it make which units the
limits are expressed in?

     It turns out to make a big difference in terms of pollution
prevention and planning for changes at a given  facility.
Concentration-based limits discourage water use reduction, which
is the heart of rinsing process modification  and  critical to many
recovery technologies.  In order to do pollution prevention in

                                21

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the  shop under a concentration-based limit, either the treatment
system must  be oversized or  all of the changes must be very well
choreographed to preclude the possibility of upset or even
marginal noncompliance.   This "choreography" discounts the
necessity of learning from trying things out, fine tuning and
adjusting in implementation.  At the Parker Metals facility we
visited in Worcester,  MA,  for example, it has taken four years of
tweaking and refinement  to bring the treatment process under
acceptable levels of control, after they made a radical chemistry
change on the line,  eliminating hexavalent chromium, nickel and
cyanide (See Appendix A) .

      Some of the programs we've contacted have argued that
establishing mass-based  limits would provide the most compelling
incentive for pollution  prevention.  Such limits would allow
firms to reduce water use without fear of exceeding
concentration-based limits;  water use reduction in turn
facilitates  some metal recovery techniques.  The counterpunctual
disincentive is that concentration-based limits discourage water
use  reduction.  Concentration-based limits are easy to measure
for  compliance.  Some plants (perhaps most) do not currently have
the  capacity to accurately measure their flow.  This is not to
say  the technology doesn't exist, but flow measurements have not
been necessary and so few shops take them.

      Concentration-based limits are easier to translate from one
POTW's situation to another  and to apply across categories.
Mass-based limits could  depend on many factors, related both to
each company's individual circumstance and the cumulative effect
at the treatment plant.   However, devices for estimating local
limits based on maximum  allowable headworks loadings  (such as
PRELIM software)  may work well with either case, since they are
based on a mass balance  including the mass of each metal in the
influent.  The more dilute stream that a concentration
based-limit  encourages is less likely to be aquatically toxic and
less likely  to cause a spike or other problem at the POTW.  The
extent to which this is  an issue depends on dilution factors
globally across the system and possibly locally where the
discharge enters the system.

      Mass-based limits are not what most POTWs, states, or EPA
are  using now for metal  finishers.  To use them will require
training;  guidance documents; ordinance changes; changes to
effluent guidelines -- plus, in general, overcoming opposition to
change.   One problem arises, however.  If mass-based limits are
not  tied to  production,  they might represent a ceiling so that a
permit change would be required for the firm to increase
production.   Even if permit  changes are not required, such
increases  might violate  "no  backsliding" provisions of the Clean
Water  Act.
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          3.2.4     Production-Indexed Mass Limits

     Production-indexed mass-based limits can be very difficult
to calculate for plating, especially in job shops where the
surface area of the plated parts may vary widely.  One way to get
around this difficulty would be to calculate mass limits from
average or maximum flow and concentrations as currently
permitted.  That approach raises a concern that without indexing
to production level such a permit might act to restrict
expansion.  For example, to add a new nickel plating line in an
existing shop without renegotiating the permit or the limits with
the POTW, a company would have to reduce mass emissions of nickel
from other sources in the plant to compensate for any
addition--sort of a plant-wide bubble in pounds for each
pollutant.  POTWs could justify such limits by allocating
loadings across sources in the community, considering treatment
capacity, VOC emissions from the plant, and sludge regulations.

     Alternatively, mass-based limits could be tied directly to
production.  This raises nightmarish visions of inspectors
reviewing weekly production logs to determine the
frame-of-reference of compliance.  Such logs are often kept for
other purposes, and their data may be proprietary.  But apart
from the questions about accountability, the technical capability
exists for utilizing production information to calculate or
normalize mass-based limits.  Surface-area data is now available
or calculable for plating operations, including job shops.  Shops
may have in place, or have access to, computers and software to
quickly determine surface area for any job  (such products are
widely advertised in the trade literature) .  Lack of data or ease
of calculation for surface area was an impediment for widespread
use of production-based mass limits in the late 1970s or early
1980s, but it may be worth another look in 1990s to see if the
impediments are that insurmountable.

     To develop mass-based limits might require that EPA or other
technical resources gather information on drag-out associated
with part shapes, holes, threading, and other factors key to drag
out of metal finishing solutions by parts from one tank to the
next.  This information would more accurately tie potential
pollution to production rates than straight surface-area data.
Why go to all this trouble?  A better question might be, if the
POTWs see a need and are willing to work on it, why not let them?
The answer, as to why to go to all this trouble, lies in the
disincentive to change that concentration-based limits provide.
Concentration-based limits discourage water use reduction -- why
risk going out of compliance?  It can be much worse for a firm to
go out of compliance than to waste water.  Concentration-based
limits discourage rinsing process innovation -- again, why risk
reducing water use, thereby increasing  concentrations?
Concentration-based limits, by discouraging water use reduction,
make it very difficult to implement recovery/treatment

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technologies.  But the principles of pollution prevention dictate
that water efficiency, energy efficiency,  and toxics reductions
are the goal. These goals are technically achievable. We simply
need some collective will-power to make it happen.


          3.2.5     Examples of Pollution Prevention Technologies
                    Fostered by Mass-Based Limits

     Technologies that rely on separating metals or other
contaminants from water, such as ion exchange, electrolytic
recovery, electrowinning, electrodialysis, reverse osmosis,
vacuum distillation, even evaporative recovery, are generally
fostered by mass-based limits and discouraged by
concentration-based limits. High volume waste streams require
large recovery/treatment systems requiring large capital
investment.  Such an expensive and radical change in a
metalfinishing operation must not put the company in jeopardy of
noncompliance.  Implementation of water use reduction and
recovery systems does not always happen all-at-once; during
interim stages firms are vulnerable to violating
concentration-based limits, even if total mass loadings have
decreased.  That is why mass-based limits are more conducive to
giving facilities the added flexibility and assurance they need
to make such important changes.

     There is a distinguishable difference between source
reduction and recycling as they apply to electroplating.  Most of
the following list of source reduction approaches consists of
rinsing process modifications which are supported by mass-based
limits; most of the activities on the list of recycling and
treatment approaches are easier to do with less flow to handle.


     Source Reduction for Platers & Metal Finishers

     -- bath substitution/reformulation
     -- lower bath concentrations
     -- bath maintenance
     -- slow withdrawal rate
     -- fog/spray rinsing
     -- DI water use
     -- racking parts
     -- other dragout prevention
     -- rinsing to meet spec
     -- conductivity-sensing flow controls
     -- preset flow controls
     -- countercurrent rinsing
     -- reactive rinsing
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     Recvclinq/Recoverv/Other Treatment for Platers & Metal
     Finishers

     -- dragout return (with evaporation)
     -- modular & global ion-exchange
     -- plate-out cells/electrowinning
     -- vacuum distillation
     -- electrodialysis
     -- in-process cyanide destruction
     -- precipitation
     -- volume reduction
     -- filter presses & sludge dryers


     3.3  Enforcement and Compliance Activities Tied to a Strong
          Pollution Prevention Message is Key Motivator

     A strong, consistent program of enforcement,  coupled with a
commitment to promoting source reduction as a means of coming
into compliance, can be a key pollution prevention incentive.
Such a  program  must, however, allow for latitude in how, and at
what pace, firms exploring and initiating pollution prevention
measures come into compliance.  While a company that is in
compliance may have less motivation to consider source reduction
measures, a facility that has been served notices  of violation
(NOVs), or is otherwise under an enforcement action by a
regulatory agency, is in a very receptive position to be
motivated toward pollution prevention.  For enforcement programs,
pollution prevention can be a means of not only bringing
facilities into compliance, but potentially going beyond what
could be achieved with conventional, end-of-pipe responses.


          3.3.1     Pollution Prevention Action Often Triggered
                    By Pending Enforcement

     According to both regulators and technical assistance
personnel we interviewed for this report, the experience is that,
for many facilities, action towards investigating and
implementing pollution prevention measures very often is first
taken due to an outstanding or anticipated enforcement against
the firm.  Several metalplating shops we visited in Massachusetts
took their first steps towards source reduction because of
anticipated enforcement actions.

     Neles-Jamesbury, a machine tool manufacturer that was
originally visited by the Blackstone Multimedia Inspection Team,
was found to be combining a water stream from an apparently
unnecessary piece of air pollution control equipment with a
categorical wastewater stream, thereby meeting their categorical
limits through the effect of dilution.  The inspectors deemed the
practice unacceptable, and their POTW required them to lower

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their metals loadings.  With encouragement from the Massachusetts
Department  of Environmental Protection  (DEP) and the POTW, and
with direct technical assistance provided by the state's
nonregulatory Office of technical Assistance  (OTA), the company
chose to source reduction measures  (counter-current rinses, dead
rinses,  flow controls,  etc.)  to come  into compliance.

      Interestingly,  representatives of  the firm had previously
attended pollution prevention workshops, including sessions
focused  on  the very source reduction  measures Neles-Jamesbury
eventually  implemented.  They also were offered, but had chosen
not  to accept, a free on-site waste reduction audit provided by
the  state.   It took the "trigger" of  an enforcement action,
coupled  with the knowledge that a prevention-focused solution
would please the regulatory agencies, to cause action.

      Another facility visited by the  Blackstone Team, The Lowell
Corporation, a small machine tool shop  manufacturing specialty
ratchets, was found to be way out of  compliance on its zinc
limits (4.47 mg per liter vs.  the categorical standard of 2.6 mg
per  liter).  The violations stemmed from their zinc phosphate
plating  line.  Shutting down the line and sending parts out for
plating  elsewhere would have cost them  an additional $26,000 per
year.  After referral to Mass.  OTA, which provided on-site
technical assistance,  the company chose to install a dead-water
drag-out tank on the phosphating line.  The tank carried a very
modest price tag and took only ten minutes to install.  After
that the wastewater zinc levels dropped to 1.55 mg per liter,
well below  the permitted limit.  If the compliance message had
not  been tied so strongly to pollution  prevention goals, the
company  may have faced losing a considerable part of their
business.   For small shops that cannot  bear the expense of large
pretreatment systems,  such in-process modifications are often the
only practical alternative for coming into compliance -- other
than closing down the line.


          3.3.2     Flexible Compliance Mechanisms Are Needed

      For many new or innovative pollution prevention
technologies,  difficulties in implementation may not provide
assurance of a return to compliance within the time frame that a
conventional treatment system might accomplish.  As stated
earlier,  strong,  consistent enforcement can promote pollution
prevention  by enhancing the desire of the regulated community to
reduce potential liabilities and the  resulting costs of
noncompliance.   However,  efforts to achieve  (and potentially go
beyond)  compliance through pollution  prevention need to be
facilitated by flexible enforcement mechanisms, e.g., extension
of the compliance timelines for facilities adopting pollution
prevention  measures.


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     EPA's Interim Policy on Pollution Prevention Conditions in
Enforcement Settlements and Policy on Supplemental Environmental
Projects both encourage the use of pollution prevention,
recycling conditions, or innovative technologies in enforcement
settlements, either as injunctive relief or as "supplemental
environmental projects" (SEPs) incidental to the correction of
the violation itself.  In particular, if a pollution prevention
activity is presented as the means of correcting the violation,
the EPA settlement team may extend the compliance schedule,
especially if the remedy involves innovative technology-   In
deciding whether to extend the compliance timeline, one of four
factors Federal negotiators must consider is the
reliability/availability of the innovative pollution prevention
technology -- the more experimental the technology, the more
cautious negotiators may be about timeline extensions.

     In exchange for an SEP or a pollution prevention initiative
to correct the violation,  the punitive portion of the penalty
owed the government can be reduced.  However, under no
circumstances will a respondent be granted additional time to
correct the violation in exchange for a SEP.  However,  the
concept of SEP has been expanded to include innovative
technology, either pollution control or prevention.  Many states
and EPA Regions have drafted enforcement settlements designed to
promote pollution prevention.  When we first began our research
for this report  (May 1991), the pollution prevention SEP concept
was just getting off the ground.  Several Regions now report
(October 1993) that SEPs have since become institutionalized into
their enforcement programs. There is more training for inspectors
on how to look for pollution prevention opportunities,  and more
cases are being examined for ways to fold in pollution
prevention.

     In one enforcement case, Region I has worked closely with a
facility seeking to address pretreatment violations via pollution
prevention measures.  There has been no formal enforcement so
far, only section 308 letters, and many meetings between EPA, the
POTW, and the company.  There has been no administrative orders,
no penalties, but technical assistance has been facilitated
through EPA contacts and a private consultant hired by the
company.  The facility has implemented a range of pollution
prevention process changes after doing a toxics use reduction
analysis.  These actions have been accomplished in a
"carrot--stick" type approach, by leveraging the pollution
prevention with the threat of a more formal enforcement action  if
the work is not done.  When this approach goes as  far as it can,
a Compliance Order may be written  (if the facility is still out
of compliance) that will fold in the pollution prevention
implementation requirements, along with a timeline designed to
allow the facility to make incremental progress towards full
implementation.


                                27

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     Allowance for the extended  timeframe often needed to fine-
tune process changes or unfamiliar systems and equipment can be
crucial  to the successful  implementation of pollution prevention
technologies.   This is true not  only for innovative technologies,
but also for some "off-the-shelf" technologies or systems.
Parker Metals,  a Massachusetts metal parts manufacturer we
visited,  had decided to switch from nickel-chrome plating
 (requires highly toxic cyanide solutions) to alkaline zinc
plating.   Although the change-over seemed fairly straightforward
-- or  so it was promoted by the  equipment vendor and
environmental consultant employed at that time -- Parker found
the change not only affected the plating line in unpredictable
ways,  but also affected the performance of their wastewater
treatment systems.   They found that it took at least 4 years to
fully  understand the chemistries to keep the limits in control.
They were fined by EPA Region I  for not having a pretreatment
system up and running on time, and they were forced to complete
the current system under a consent order.  Technical
uncertainties associated with changing to an unfamiliar process,
coupled  with the need to "meet your limits" within a specified
time frame,  can be an overwhelming disincentive to companies who
need some measure of certainty associated with their
environmental performance  in order to avoid the risk of costly
liabilities associated with noncompliance.


           3.3.3     Pollution Prevention In Enforcement Actions

     As  discussed above, EPA Regions, states, and public interest
groups are now drafted more enforcement settlements designed to
promote  or require the adoption  of pollution prevention measures.
EPA Region 1 has settled cases where pollution prevention
measures have not only achieved, but allowed the facility to go
beyond compliance.   Massachusetts officials have used
administrative orders to force early toxics use reduction
planning under the Mass. Toxic Use Reduction Act  (TURA) .  In
California/  the Orange County Sanitation Districts have used
enforcement actions to encourage industrial facilities to carry
out pollution prevention.   While Orange County feels this has
been a successful initiative, they also note that, although
effective,  it can be costly for  POTWs to pursue.  Also, many
POTWs  feel uncomfortable in the  role of "strong-arming" action.
A preferable mode would be to reach facilities with technical
assistance before noncompliance  escalates to the point of
enforcement actions and compliance orders.

     The  Atlantic States Legal Foundation  (ASLF), working on
behalf of a citizens group seeking civil action under the CWA,
settled  a case  with electroplaters in Fort Wayne, Indiana, that
resulted  in limited pollution prevention implementation. Of an
original  group  of five platers that were cited in the suit, four
chose  to  pay the fine and  come into compliance without signing a

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pollution prevention agreement.  Only one plater chose a
reduction in fine and signed the agreement to do a pollution
prevention study  (at a cost not to exceed 15K) .  When asked why
the other tnetalplaters did not "bite" the pollution prevention
carrot, Mr. Hayes, the ASLF lawyer, said that most companies he's
dealt with do not like outside entities fiddling with their
product line.  They do not mind so much if you put requirements
on how they manage their waste, but when it comes to the process,
they say "Don't tell us how to make our product."

     Other problems with folding pollution prevention conditions
into enforcement documents are that the costs associated with not
only the pollution prevention study but implementing the results
of the study are so open-ended.  People want certainty.  Their
attitude is in many cases: "Pay the fine, sign the order, get
into compliance quickly and they'll all get off my back."  It is
hard to make pollution prevention agreements self-implementing.
In the Fort Wayne case, ASLF is just hoping that the study turns
up some cost-saving, environmentally-beneficial pollution
prevention for the facility to implement, but there are no
guarantees.

     We also talked to EPA Region 9 about a settlement involving
pollution prevention.  Settled in February 1991, the case
involved Alta Plating, a small "Mom-and-Pop" operation, that was
in violation of the pretreatment requirements.   The settlement
involved a cash penalty along with a pollution prevention SEP-
It required the facility to do a waste assessment audit and waste
minimization plan, to be submitted to Region 9 "for review and
approval."  The agreement has a default penalty such that if the
facility does not implement the plan, they would have to pay a
penalty of $6K.  We asked what if the audit says the facility
should implement a pollution prevention measures that would cost
more than $6K, could Alta Plating then choose to pay the fine and
not do the pollution prevention?  Laurie Kermish, of the Regional
Counsel's Office, said yes -- but since what they are trying to
do is make the facility go beyond compliance, that's the best
they could get.


          3.3.4     Importance of Agency Openness To Pollution
                    Prevention

     It is clear that whether a firm chooses pollution prevention
or traditional end-of-pipe technology to return to compliance  is
highly influenced by the enforcing agency's openness to pollution
prevention.  While POTWs have often been criticized for their
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lack of  aggressive  enforcement,4 they are nevertheless in a
unique position to  use  both their  close working relationship with
their service  area  industries  and  their role as
regulators/enforcers  to promote pollution prevention in a
meaningful  way.   Being  on the  "front-line," POTWs develop first
hand knowledge of industries,  their processes and technologies.
POTWs are also in the unique position of sharing that knowledge
and developing training and technical outreach programs for their
service  areas.   POTWs themselves are regulated entities and
unless their regulators (EPA and the states) are supportive of
pollution prevention, the POTW may find it hard to implement the
kind of  quality pollution prevention program they are in the
position to do.

     In  1989,  EPA and the Department of Justice began a major
enforcement initiative  against 61  large cities as a result of
inadequate  POTW pretreatment programs.  The effort has led many
POTWs to take  aggressive enforcement actions against their
dischargers.   POTWs are also under the gun for implementing a
wide range  of  new,  more stringent  regulations, such as the DSS
sludge rules,  air toxics rules, new water quality limits, along
with increasingly lower NPDES  permit limits overall.  As with
industrial  facilities,  POTWs need  time to explore pollution
prevention  or  source  reduction options.  Building the concepts
and practices  of pollution prevention into their pretreatment
programs cannot happen  overnight.

     States with delegated pretreatment programs may have greater
latitude than  non-delegated states with regard to building in
such program elements as pollution prevention-focused inspections
and technical  assistance/outreach.  In nondelegated states, EPA
is responsible for  inspections and enforcement of indirect
dischargers, and while  the EPA inspectors may be open to
pollution prevention, there are serious time and resource
constraints that do not allow  the  close, day-to-day,
"collaborative"  relationship that  may characterize a delegated
state's  approach.   Pretreatment programs at the Woonsocket and
Warwick  (Rhode Island)  POTWs,  for  example, have been very
effective in promoting  source  reduction, largely due to
           The 1989 GAO Report:  Improved Monitoring and
Enforcement Needed for Toxic  Pollutants Entering Sewers
(RCED-89-101), was highly critical of POTW enforcement actions
stating that  POTWs are reluctant to take stronger actions
because: "(1) POTWs have  traditionally been service-oriented
toward industries and are uncomfortable in the role of
regulators; and  (2) they  have received unenthusiastic enforcement
support by local government officials...because of possible
economic impacts."
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pretreatment program coordinator training and their technical
understanding of industrial users (Woonsocket: textiles; Warwick:
platers and casters) as well as a willingness to work on a
day-to-day, one-on-one, basis with individual firms who are
working towards compliance via pollution prevention measures.

     A major enforcement case at Woonsocket involved the Seville
Dyeing Company.  Mike 0'Conner, Woonsocket's Pretreatment
Coordinator, worked very closely with Seville to encourage source
reduction and water conservation measures as a means of coming
into compliance.  The facility was seriously out of compliance on
BOD, largely due to high COD from chemical sources, such as
polyvinyl acetate  (textile sizing) and dyes.  The compliance
order written for Seville specifically limited the number of
black dye runs  (found to be the largest contributor to the high
COD) the facility could do within a given time frame.  Savings
realized by Seville after incorporating process modifications and
other source reduction measures promoted by Woonsocket were in
the $150K/year range, largely from reduced water, sewer, and
chemical costs.
          3.3.5     Inspectors Can Play A Key Role

     By inspecting firms, agencies can identify potential
compliance problems and call the firms' attention to them.  They
can also be a first line of communication to regulated entities
of the potential opportunities for, and savings achievable
through, the use of pollution prevention measures.  This may come
via handout of technical material, brochures, or checklists;
direct referral to state or POTW technical assistance programs;
or  coordinated, multi-media inspections, such as piloted in the
Blackstone Project.  Whenever regulating agencies communicate
with regulated entities, they have the opportunity to reiterate
the preferred waste management hierarchies and to underscore
their agency's preference that firms use pollution prevention as
a means of achieving compliance.  The Blackstone Project
illustrates how this communication can successfully occur within
the context of facility inspections.

     The Massachusetts DEP began planning and training for
multimedia compliance inspections in coordination with the
Massachusetts Office of Technical Assistance  (OTA) in November
1988.  With grant support from the USEPA Office of Pollution
Prevention, in 1990 DEP conducted a series of multimedia
inspections  (coordinating the work of agency and POTW field staff
specializing in air quality, industrial wastewater, hazardous
waste, right-to know, and toxics use reduction) in various
inspection team formats as a pilot project.  Named for the river
basin that served as a focus, the Blackstone Project has  served
as a model for multimedia inspection pilots planned by other
states. While a principal goal of the Project was to test

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alternative  ways  of  conducting  inspections of industrial
facilities and for coordinating state and local regulatory
actions  across the media programs, a second objective was to
undertake pollution  prevention-focused enforcement actions, where
warranted.

     DEP has initiated a number of enforcement actions to
encourage firms to consider  source reduction and recycling as the
preferred methods for reducing  releases to the environment.  At
our meeting  with  the Blackstone inspectors in June 1991, we
received an  update on the  progress of the enforcement evaluation.
In all,  team inspectors went into some 80 facilities -- the vast
majority were plating or metalfinishing shops.  Blackstone field
staff  identified  specific  source reduction opportunities at 16
facilities and made  a general referral to Mass. OTA at 30
facilities.  Of those facilities, 23 did some sort of pollution
prevention or toxics use reduction  (20 because of enforcement
letters  or NOVs,  plus 3 facilities with no enforcement
motivator).


          3.3.6     Example  of  POTW Implementation of New Metal
                     Reduction Ordinance

     The three major opportunities that a regulating agency has
to influence behavior towards pollution prevention are:  (1) when
new standards are developed  and come into effect; (2) when
re-permitting actions occur; and (3) when a company falls out of
compliance.   Previous subsections have dealt with enforcement in
the context  of noncompliant  facilities.  It is important to
understand that the  initial  tack a regulatory agency takes in
implementing new,  usually  more  stringent, regulatory requirements
can set  the  stage for encouragement of pollution prevention --or
it can put up barriers.

     The Regional Water Quality Control Plant  (RWQCP), a POTW
operated by  the City of Palo Alto  (Calif.) has been successful in
promoting pollution  prevention  with industry through a carefully
developed strategy under its pretreatment program.  The effort
was developed in  response  to state waste minimization
requirements,  which  in turn  had been promulgated because of the
City's violation  of  five heavy  metal limits in its NPDES permit.
In 1989, the regional plant  had been discharging as much as 9
parts per billion (ppb) of silver to the South San Francisco Bay.
Under new, stricter  discharge limits set by the Regional Water
Quality  Control Board,  Palo  Alto's silver concentration was to be
reduced  to 2.3 ppb,  a 75%  reduction. The principal concern with
silver was because of elevated  concentrations found in clams and
mussels  near the  wastewater  discharge point.  Elevated silver
concentrations were  also found  in the livers and kidneys of
diving ducks in the  area.


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     Photoprocessing operations, including x-ray and microfilm
development processes were determined to be the major silver
sources in the area.  Silver is a component of the paper and film
used in these processes and is released in the fixer or
bleach-fix stage of image development.  The City developed a
silver reduction pilot program to facilitate implementation of
the Silver Reduction Ordinance, an amendment to local sewer
ordinances.  The ordinance regulates all dischargers of silver in
spent photochemicals within the service area,  and sets stringent
discharge limits.  The ordinance was passed by the plant's five
member communities during Fall 1990 and required compliance by
June 30 or September 30, 1991, depending on volume.  The pilot
program was developed to facilitate compliance with the stringent
limits.

     The pilot program has proven successful based on the
following accomplishments:

_    Publication of informational newsletter and other
     educational materials

_    Public workshops to explain the need for silver reductions
     and compliance methods

_    Sponsorship of silver waste reclamation program -- the POTW
     has entered into agreements with photo waste haulers to
     operate pickup and reclamation services for spent fixer and
     bleach fix.  This makes it economical for small generators
     to schedule regular pickups.

_    Established drop-off facility for silver-bearing
     photo-chemicals from households

_    More than 90,000 gallons per year of spent fix, bleach fix,
     and stabilizers had been accounted for as of August 1991 --
     349 facilities will haul approximately 32,000 gallons per
     year and 27 firms which together generate approximately
     60,000 gallons per year have applied for on-site treatment
     permits.

_    Coordination of regulatory administrative requirements --
     POTW staff have coordinated with local fire departments,
     County and State Health Departments to streamline permitting
     and inspection procedures, minimize fees, and eliminate
     redundant regulation.

_    Successful lobbying of the State Assembly to change the
     state law regulating photoprocessing wastes

     The success of this program can generally be attributed  to
its phased approach to  controlling silver discharges.  Rather
than single-mindedly relying on enforcement of the new silver

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 limit,  the POTW first emphasized public outreach,  technical
 assistance,  and regulatory coordination.   This ensured a
 multi-media approach to the problem and won the sympathy and
 support of the regulated community.  It is important  to note,
 however,  that the initial action (to implement a strict silver
 reduction program throughout its service area)  was motivated by
 Palo Alto's pressing need to come into compliance with tough new
 metal limits in the POTW's  NPDES permit.


      3.4   Economic Factors For Metalfinishers Have The Potential
           To Be Key Motivators, But There Are Significant
           Barriers

      Metalfinishing covers the electroplating of various kinds of
 heavy metals,  like cadmium, copper, chromium,  nickel,  zinc,  lead,
 silver and gold.  It also covers metal surface preparation and
 coating,  and the anodizing of aluminum.  The electroplating
 process is used by specific electroplating shops (job shops) as
 well as by manufacturing companies (captive shops).   Job shops
 can range from extremely small, uMom-and-Pop"  operations located
 in a garage or basement5,  to  fairly large  (>100  employees) shops
 that have steady, on-going plating contracts,  and are often
 located near,  for example, automobile assembly plants or major
 computer  manufacturers.  Captive shops can range in size and
 complexity,  from specialty precious metalplating shops,
 associated with the jewelry industry,  to shops associated with
 manufacturing facilities, both large  and small.

      In short,  the metal finishing industry can be characterized
 as being  heterogeneous, with profit margins ranging all over the
 board.  Operating costs are highly dependent on not only the type
 of metal  plated, but on water use,  energy use,  volume of
 wastewater treated,  volume of sludge  treated/disposed,  etc.  Cost
 savings that can be realized by metal finishers are generally  a
 function  of  the following variables:6

      •     Reduced raw material costs
      •     Value of recovered material
      •     Reuse potential of water
      •     Value of recovered material
      •     Reduction of sewer fees
     5     A  one-man shop in Rhode Island specializes  in silver
plating historical pieces for museums  (e.g.,  the  Smithsonian);
everything is done by hand using two small batch-process tanks.


     6     NJ DEP, Design of Programs  To Encourage Hazardous
Waste Reduction:  An Incentives  Analysis.  Oct. 1988,  p.  111-13,


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     •    Reduction of hazardous waste disposal costs
     •    Reduction of liability-related costs

     Although many source reduction technologies require little
capital investment, several resource recovery, reuse, recycling,
and alternative pollution prevention technologies require
significant capital investments.  For example, on-site process
chemical or metal recovery systems, such as ion exchange or
electrolytic recovery, can cost over $2OK to purchase and
install.7  The savings to a small  company may not warrant  the
cost of the system.  Compared to the cost of installing a
wastewater treatment plant  (i.e.,  employing conventional
precipitation and sludge management technologies) ,  which can
start at around $1 million dollars, even the higher-priced
pollution prevention technologies can seem attractive.

     Good housekeeping practices and simple process
modifications, such as countercurrent rinsing or drag-out
minimization, can be implemented for little capital investment.
They may however, require a dedication to maintenance of plating
chemistries, monitoring of flow, drag-out time, etc., that many
(especially smaller) companies may not wish to troubled with.  As
discussed in the following section, our findings indicate that,
for metal plating facilities, the economic benefits of pollution
prevention are not, by themselves, good predictors of a firm's
adoption or rejection of pollution prevention measures. In many
cases, it seems that financial analyses  (if they were done at
all) were done largely "after the fact" to rationalize a decision
to implement that was motivated by other than strictly economic
motives.
          3.4.1     Economic Benefit of Pollution Prevention
                    Alone Not Strong Motivator

     Although there are many documented examples of profitable
pollution prevention initiatives undertaken at metal finishing
facilities, it is seldom a straightforward task to find out what
originally motivated the facility towards pollution prevention.
For example, in our Massachusetts and Rhode Island site visits,
only one facility  (Allied Manufacturing) appeared to have
initiated source reduction based on expected cost efficiencies,
rather than to address some outstanding regulatory requirement
(e.g., firm out of compliance, POTW setting new limits,
implementing pollution planning requirement, etc.).  The
closed-loop coolant/metal recovery system that was installed was
estimated to have a three year payback; however, the numbers were
     7     California DHS, Waste Audit Study:  Metal Finishing
Industry. May 1988, p.14.


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 not arrived at by a rigorous analysis,  more by way of  a "back of
 the envelope"  calculation,  done principally to justify the
 capital expenditure (i.e.,  they had basically already  decide  to
 do something).  According to the firm's engineer,  they installed
 the recovery system more as a good business practice,  because it
 made more sense to recycle the coolant  than to keep paying  for
 fresh coolant.  Their product also improved in quality (less
 scratches from metal-laden coolant that had to be  reworked).

      We found that most companies seemed less likely to implement
 pollution prevention than to maintain the status quo,  even  when
 they saw potential economic benefit.  Electroplaters tend to
 focus on compliance with wastewater treatment standards,  rather
 than recovery technologies, even though recovery can offer  a
 relatively short payback,  economic savings,  and reduced
 liability.8  We  were always hearing the phrase  "We can meet our
 limits."  Platers are not very interested in rocking the boat,  so
 to speak.  If they are meeting their limits via conventional
 pretreatment technologies,  they will not risk potential
 noncompliance (or,  worse,  being pulled  into regulatory limbo  of
 potential RCRA TSD permitting).9

      The California silver plater cited in the PPIC case studies
 (Appendix C)  is another example of a firm that decided not  to
 adopt pollution prevention measures,  even though the economic
 cost/benefit data were highly favorable -- and the facility was
 being pushed by its POTW to seek source reduction  solutions.10
 The company's  rinse-wastewater treatment plant had been
 frequently violating the discharge standard for silver,  and the
 local POTW  demanded a compliance plan  within 30 days.   The plan
 had to follow the preferred waste management hierarchy and
 explore the facility's opportunities for source reduction as  a
 mean of achieving compliance.   While incorporating opportunity
 assessments into compliance plans is a  worthwhile  activity  on the
     8      NJ DEP,  Design of  Programs To  Encourage  Hazardous
Waste Reduction:  An Incentives  Analysis,   Oct.  1988, p.  111-38.
     9     Recovery technologies,  unless  they are  closed-looped
and hard-piped,  can make  a  facility subject  to RCRA TSD
permitting.


     10     Additional detail provided here is from Rosenblum and
Naser, "Heavy Metals Waste  Minimization:  Practice  and  Pitfalls,"
in Plating and Surface Finishing.  April 1991.


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part of the POTW, the 30 day time limit was a bit unrealistic for
a facility that had never previously thought about source
reduction.  They initially adopted some in-line pollution
prevention measures  (e.g., more efficient air knives,
electrolytic recovery cells, flow restricters on all rinses),
resulting in a $470K/year savings in material and water for a
mere $12K capital investment.

     For the first six months, the effluent was in compliance
with silver limits; however, violations gradually began to occur,
returning to their previous high levels.  Investigations showed
that significant changes in production and inadequate maintenance
of the system had eliminated the initial pollution prevention
improvements.  Although the problems could have been resolved
with improved maintenance procedures, management decide to focus
on installing a new, but conventional, 250 gal./min. wastewater
treatment plant at an estimated cost of $1 million.  Management
was unhappy that the source reduction measures failed to achieve
permanent, "one-shot" compliance (they disliked the need for
fine-tuning and the potential of being at-risk); they also
believed that building a conventional treatment system would
return them to compliance faster.


          3.4.2     Lack of Capital is Barrier for Many Platers

     A company's efforts to prevent pollution may be stymied by a
lack of capital.  Unavailability of capital can prevent
implementation of some pollution prevention projects with good
payback potential; electroplaters and metalfinishers may have
more trouble getting capital than many other industrial sectors
do because of.tight cashflow, low equity value of current plant,
environmental issues, etc.  Because metalfinishing facilities
typically have limited capital resources, they often must depend
on grants or bank loans to fund pollution prevention projects.
For example, the before-tax profits for the metalfinishing
industry in California range from 2% to 15%, averaging 5.4%
overall and the return on equity ranges from 12% to 25%,
averaging 19.0%."-   Pollution prevention investments would need
to produce returns exceeding this latter percentage in order to
be seriously considered by the industry.

     In the California study, financial assistance was identified
as a significant factor influencing pollution prevention
initiatives by California metal finishers. This concern over lack
of funds is echoed by a metal finisher  we visited  in
     11     Thomas  Barren, Evaluation of DHS Waste Audit  Study
Program, Cal.  DHS,  May 1991.
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 Massachusetts (New England Plating).   The  company blames  its
 limited profits on the expense of building and  operating  an
 end-of-pipe treatment system needed to satisfy  NPDES permit
 discharge requirements (New England Plating has operated  a
 conventional metals precipitation system since  the beginning  of
 the NPDES program.)   New England Plating views  pollution
 prevention with some bitterness because of the  required further
 capital investment needed.  Lacking the necessary capital for
 these changes,  company management points out that bank loans  are
 unobtainable for facilities like theirs.   Generally, small metal
 finishing operations will not demonstrate  the profitability and
 stability necessary for bank loans.


           3.4.3     Total Cost Accounting  Not An Effective Tool
                     For Smaller Firms

      Total cost accounting (TCA)12 is not usually an effective
 tool for promoting pollution prevention to small electroplaters.
 Requiring or even suggesting detailed  TCA  before implementing
 pollution prevention may act as a disincentive  -- many firms  are
 reluctant to go to the trouble of such accounting if not
 otherwise required.   In particular,  detailing potential
 liabilities may pose SEC problems for  publically-held companies
 unless they put cash in escrow to cover those liabilities once
 they are calculated.

      A study completed for the California  Department of Health
 Services reports that,  of the industries surveyed, good payback
 and affordability are two dominant factors affecting industry
 response to waste minimization projects. This study found thatthe
 larger firms were further along with projects involving
 significant equipment purchases,  while the smaller firms  were
 found more likely to seek out and implement inexpensive and
 cost-effective  changes first.  This  is noteworthy because most of
 the  metalfinishing facilities in California are small  (i.e.,  less
 than 20  employees).   More complicated  pollution prevention
 initiatives require  detailed technical evaluation to arrive at
 reliable cost-benefit evaluations.   In this regard, a consultant
 to metal finishers in the northeast  (Peter Gallerani) noted that,
 in his experience, a company's orientation towards pollution
prevention depends on whether or not it involves itself in
long-range planning.   Those companies  that view their operations
in the short-term are wary of changes,  and prefer the security of
     12     Several total  cost  accounting  (TCA) approaches have
been developed to facilitate analysis of pollution prevention
investments:  EPA's Pollution  Prevention Benefits Manual. GE's
Financial Analysis of Waste Management Alternatives, and
PRECOSIS. developed by George  Beetle Company.
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proven profits under existing conditions.


          3.4.4     Fees as Motivators for Pollution Prevention

     Many pretreatment programs recuperate a portion of their
expenses through fees from industrial users based on wastewater
flows and strength.  The potential use of  fees as an economic
incentive for pollution prevention is noteworthy because under
the traditional regulatory enforcement of  limits there is no
mechanism to encourage facilities to continue abating pollution
beyond the standard.  Without such an incentive,  industries
discharging cleaner wastes might even be motivated to scale back
on treatment costs.

     POTWs may apply fees for mass loadings above a baseline
which would provide a strong incentive to  reduce loadings.
Sliding-scale fees can provide effective incentives to change
behavior. A continual scale will not necessarily make a continuum
of impact, however; it is useful to identify thresholds which
cause action. The Cranston, R.I., POTW that we visited, for
example, uses a industrial user fee system proportional to the
flow-based sewer use fee plus a surcharge  which is related to the
highest concentration  (over the billing year) of metals, cyanide
and TTO.  While this does discourage high releases of certain
pollutants, it doesn't force a pollution prevention response, per
se.  Companies could simply improve the operation of their
end-of-pipe pretreatment systems to get their numbers  (and fees)
down.

     Linking industry fees to the amount of pollution generated
addresses the failure of our market system to internalize the
costs of environmental pollution.  Some argue that because POTWs
in this country have been constructed largely with federal funds,
their treatment of industrial wastes amounts to a public subsidy
of industrial activity.  Most importantly perhaps, economic
mechanisms such as fees, tax incentives, etc., mark a break with
the more confrontational nature of our current standards-based
system.  By internalizing the cost of environmental protection
for industries, regulatory agencies can establish environmental
protection more clearly as a mutual goal for industries and
government alike.  Making reduced sewer fees a function of
improved production efficiency and wastewater quality  introduces
a positive profit incentive  (i.e.CarTOt V. Stick approach).
     3.5  Zero-Discharge  Systems Can Promote Pollution Prevention
          But There Are Regulatory and Technical/Informational
          Barriers

     Pollution prevention and control systems which allow  the

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 reuse  of  almost  all  water by electroplaters and metal finishers
 have been promoted as  one way for  them to avoid the uncertainty
 of  changing  limits.  Under appropriate conditions such systems
 can save  companies a lot  of money  and eliminate their burden on
 waterways or treatment plants.   However, the systems' regulatory
 status remains in question,  and they are not to be considered
 pure source  reduction;  at the current level of market and
 technology development they are not appropriate for every
 facility.

     "Zero"  discharge  systems are  so called because they
 eliminate wastewater discharges from electroplating facilities.
 Through a variety of approaches including rinsing modifications,
 drag-out  recovery and  wastewater treatment they allow a plating
 shop to reuse almost all  water from the process.  They have been
 widely promoted  by pretreatment coordinators and pollution
 prevention programs, and  their installation nationwide has grown
 remarkably over  the  last  decade.

     Wastewater  treatment steps in these systems usually include
 ion exchange (IX)  or reverse osmosis  (RO) or ultrafiltration
 (UF),  possibly electrolytic recovery  (ER) or electrodialysis, and
 sometimes chemical treatment and precipitation.  Metals, salts,
 and other contaminants removed through the treatment steps are
 usually concentrated by evaporation and shipped off site either
 for metal recovery or  disposal as  hazardous waste.  Filters and
 carbon adsorption units used for rinse water purification are
 also shipped off site.  Thus although the systems allow a plating
 shop to run  without  water releases, there are definitely still
 solid  waste  and  air  releases;  some industry representatives have
 suggested the phrase "zero wet discharge" as a clarification.

     Pretreatment program managers and other water regulatory
 authorities  often like the concept of systems which will
 eliminate toxic  discharges from their influent.  And for platers
 the idea  of  being immune  to changes in categorical standards or
 local  limits has similar  appeal.   Many of the pollution
 prevention programs  we've contacted promote them, including
 programs  in  California, Connecticut, Florida, Illinois, North
 Carolina, Massachusetts,  and Rhode Island.  The Atlantic States
 Legal  Fund,  an environmental group based in Syracuse, NY, has
 promoted  closed-loop systems as part of prevention-biased
 enforcement  settlements in Fort Wayne, Indiana.

          3.5.1      Zero-Discharge and Pollution Prevention

     In order to successfully implement a closed-loop system a
plating shop usually must reduce water use throughout the plant.
 Ion exchange, reverse  osmosis  and  ultrafiltration share the
distinction  of becoming much more  expensive to implement as the
volume of water  to be  treated increases.  Thus the capital cost
to change over from  no  controls or hydroxide precipitation to one

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of these separation technologies will drive efforts to modify
rinses and cut water flows.  Once such a system is installed,
operating costs may be markedly less than costs for end-of-pipe
pretreatment systems, and product quality usually improves from
better water quality control.

     For example, in the case of the Robbins Company of
Attleboro, MA, managers estimated that an upgraded
precipitation-based treatment plant with discharge would cost
about $500,000 in capital and $120,000 a year to run.  (The
upgrade would be required to ensure compliance and meet tighter
limits.)  The closed-loop system they elected to install instead
cost $220,000 in capital and costs about $30,000 a year to run;
they save $71,000 per year in operating costs even from what they
used to spend on the old under-sized system, and the cost for a
necessary change has been directly paid back in less than three
years.  (See also the Fernando case study in Appendix A and the
Pratt & Whitney case study in Appendix B.)

     From the POTW's perspective, not only are even trace amounts
of plated metals eliminated from the plant's influent but also
the possibly of interference or pass-through due to an upset from
such a shop is eliminated.  Some authorities have required that
drains or sewer 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

               3.5.2.1   RCRA Applicability

     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-piped
processes of wastewater treatment systems.  This is the tack RI
DEM has taken, requiring RCRA Part B permits for such systems
unless they also have no air discharge.

               3.5.2.2   Facility 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
have little oversight authority.  Some POTWs make annual
inspections of plants certifying that they have no process

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discharge.   In the San Francisco  Bay area the East Bay Municipal
Utilities  District requires  facility planning to reduce hazardous
materials  use --  unless the  metal finisher converts to a zero
discharge  system,  in which case the  requirement no longer
applies.   Air emissions are  usually  "nonmajor"  (see next
section) ,  and solid wastes may go to exempted refiners and
recyclers  rather  than to RCRA TSDFs,  so that state authorities
may become uncomfortable with their  ostensible lack of control of
a potentially risky process.

                3.5.2.3   Possible Cross-Media Impacts -- Air

     As mentioned above,  the atmospheric evaporators often used
in  zero wet discharge systems 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.  In the
Robbins case,  air emissions  tests have detected no organics --
the release is "essentially  water vapor."  On the other hand, RI
DEM officials have seen jury-rigged  evaporators from which only
ash remains after extended "evaporation".  Most of these sources
get relatively little attention from air programs -- platers and
metal-finishers often fall into a second tier of nonmajor sources
 (less than 100 tons total air emissions) that states routinely
inspect about every three years  (if  that often).

                3.5.2.4   Zero Air And Water Discharge

     Closed systems,  without air  releases, do exist for
concentrating metals or solids and removing water.  One approach
is  to capture the air stream from the atmospheric evaporator and
recondense the water.   A second process, alternatively called
"vacuum distillation"  or "freeze  vaporization", distills water
from concentrates under a vacuum  at  temperatures much lower than
those required for atmospheric evaporation.  In addition to
capturing  the steam for reuse as  distilled water, these units are
much less  susceptible to corrosion because they run at lower
temperatures,  and may in some cases  (with sufficient segregation)
return  a concentrate that could be further purified for reuse in
the shop.   Running at  lower  temperatures retards the breakdown of
organic brighteners into undesirable byproducts.  Southern
California  Edison published  a description of a vacuum heat pump
evaporator  in their 2nd Quarter 1990 Research Newsletter, in a
feature on  "Reducing Hazardous Wastes with Electrotechnologies."

     These  systems have two  major drawbacks:   (1) high capital
cost,  and  (2)  a reputation for maintenance problems.  Special
corrosion-resistant alloys used in the heat exchangers and the
controls necessary for operating  in  the proper ranges add to the
initial cost.   These  systems  were first used in metal finishing
only about  ten years ago,  and most shop personnel still are not

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familiar with them; the early units were notorious for
maintenance problems, especially with the vacuum pumps.  Some
vendors have improved both the durability and the ease of
maintenance, but the reputation remains, and in comparison to the
cost and ease of atmospheric evaporation presents a major hurdle.


          3.5.3     Technical/Informational Barriers Associated
                    with Zero Discharge

     Despite the compelling attraction of such systems, many
facilities have rejected zero discharge.  The primary reason is
probably technical applicability:  for some shops with a diverse
range of metals, the metal soup produced by combining rinse
waters can be difficult to treat to a level acceptable for
rinsing, especially if contaminants will be concentrated over
time and dragged in from one tank to the next, impairing solution
quality.

     Large vacuum distillation systems are especially costly, as
are large-scale IX, RO, or UF systems, running into hundreds of
thousands of dollars.  Unless they reduce water use, platers will
find hydroxide precipitation systems cheaper to install, even
though they will run into large sludge disposal costs over time.
It may be easier to cover operating costs than to come up with
capital, as in the case of New England Plating (see Appendix A) .

     In addition to the applicability question, there are
technical difficulties in fine-tuning a system that manages only
one or two metals, plus a technical learning curve for
maintenance.  Upsets are intolerable because they will shut down
the whole plating operation to which the treatment system
supplies water; if the system is not shut down the impure water
may cause very costly parts damage, solution damage or delays.
Word of the substandard systems which ruined solutions traveled
fast, so that there is resistance in some quarters to the whole
idea.

     While resistance by a company to the whole idea of water
reuse may look like an information barrier from outside a
company, the same resistance may manifest within a company as  a
management barrier.  Even if company management see the value  of
converting to a zero wet discharge system, operators  (and
managers) on the plating lines may resist changes, particularly
ones so radical.  In the Robbins case,  for instance, the
environmental manager accomplished some water use reduction  early
in his tenure by going around cranking  down valves at  night, a
little at a time.

     Even without organized resistance, there may be formidable
buy-in and training opportunities to  reduce operator-controllable
waste.  Operators must also cooperate in preventing contamination

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of the system  (for  example, oil slugs or chelating cleaner slugs
to an ion  exchange  system can be fatal to the resins).  Again in
the Robbins  case, the manufacturing manager won platers' support
by explaining  the financial reality -- the modifications would
work or the  plating would be sub-contracted, with their jobs in
the balance.   Once  on board, the platers have made the critical
difference in  making the system work.


           3.5.4     Problems With Vendors

     Some  unscrupulous or unqualified vendors have capitalized on
platers' motivation to explore zero discharge by installing
substandard  systems.  Two likely scenarios result:   (1)  the
water discharged from the system for reuse in the shop becomes so
contaminated that product quality suffers, sometimes even to the
point that baths must be discarded at great expense  (and great
RCRA waste volume), or  (2) the air releases from "overcooking"
the concentrates, sludges and solids pose an unacceptable (or at
best uncontrolled)  threat to human health and the environment.
This seems to  have  been a particular problem for one hub of
national electroplating activity, the Providence, R.I., area.
However, the problem may be more widespread than has been
detected by  most regulatory agencies.

     Implementing the treatment technologies may distract from
rinsing process modifications.  From the plater's point of view
(as opposed  to the  POTW's), this is recycling, not source
reduction, although some source reduction may be done to cut
costs.  Running the treatment technologies similarly diverts
expertise  and  capital from doing a better job running the rest of
the shop,  modifying rinses, identifying new markets, upgrading
lines, or  improving product quality.  Platers would rather be
platers than waste  treaters 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 expertise in wastewater treatment but little or none in air
pollution  control.  In attempting to capitalize on the zero
discharge  trend, these individuals may ignore possible
cross-media  transfers.  Regulators have expressed concern that
cross-media  concerns are often ignored by both vendors and
facilities seeking  to install such systems.


     3.6  Flexibility in the Regulatory Network, Supportive
          Technical Assistance and Outreach, and Collaborative
          Relationships Overall May Be Best Way To Foster
          Long-Term Pollution Prevention

          3.6.1     Need For Open Dialogue


                                44

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     There must be flexibility, not only in the regulations
themselves, but also in the regulatory network to enable open
dialogue on pollution prevention.  For example, a POTW must
safely be able  (even encouraged) to discuss questions of
permitting or enforcement with their state or Regional office
regulators.  Collaborative relationships among individuals within
the various regulatory agencies should work to promote the free
exchange of information.

     There is a complex of stakeholders involved in effluent
guidelines and pretreatment.  Among these stakeholders some
relationships may currently be characterized by mistrust or fear
(e.g., between some pretreatment program managers and some
company officials, or between some POTW officials and some state
or federal officials).   One problem this gives rise to is an
unwillingness to innovate and a lack of support for innovation,
along with crossed communications and ineffective initiatives.
Innovation and effective communication are at the heart of
pollution prevention.

     Several management tools in use today may be brought to bear
on this opportunity.  The Total Quality Management (TQM) approach
in vogue throughout industry and EPA includes a process known as
Hoshin planning.  One concept from Hoshin planning is critical
here; translated from Japanese as "catch-ball," as distinct from
"hardball," it refers to an openness among players at different
levels of hierarchies or in different hierarchies.  Within a
process there is room for open communication among players,
especially during deployment of objectives and development of
plans, but also during regular progress reviews of execution of
these plans.  This aspect of relationship seemed to be missing
with several of the people we interviewed, especially between
some pretreatment programs and Regional Office personnel.

     Although the EPA headquarters Office of Water may now
consider POTWs to be "customers," the EPA Regional Offices often
treat POTWs as regulated entities in adversarial relationships,
marked by detailed inspections using strict measures of adequacy
and little room for negotiation.  These relationships impede
technical transfer and discourage innovation.  Management support
is necessary for pollution prevention.  This is true of
industrial management and of governmental management, from CEOs
to small business owners to foremen, and from Administrators,
AAs, RAs, and Commissioners to POTW directors to program
coordinators.

     The training and attitude of pretreatment coordinators
critically influences whether or not regulated entities will  use
pollution prevention as a compliance tool.  Pretreatment program
inspectors can  fill a crucial gap in providing technical
information or promoting technical assistance programs,  if  they
find a way to do so without compromising their enforcement

                                45

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relationship.   Several programs  have  done  so.  However, when
inspectors don't dare ask "higher levels of authority" for
information or support,  they don't get  adequately trained and
they don't share the valuable information  they learn in the field
with people who could use it. Similarly,  when POTWs don't feel
safe talking with States or Regional  Offices about their
programs,  they may end up reinventing the  wheel or using policies
that don't best implement the guidelines.

      Possible approaches or solutions might include the
following:  inter-agency personnel agreements  (IPAs), rotations,
peer matches or loans,  to allow  people  to  see in exactly what
context  their counterparts operate; training activities -- from
brown bag lunches to off-site facilitated  sessions; high-level
statements of support for collaboration (for example, a vision of
POTWs as "customers");  and modifying  recognition/reward and
accountability structures to allow people  to count different
beans; and modifying conditions  for base grants to states.  This
process  of opening communication channels  seems to have already
begun, but there may be several  things  the Agency can do to
hasten the process.


           3.6.2     Technical/Informational Channels Are
                     Important

      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.

      Outreach programs  by government  agencies as well as 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 understand and thus
making them willing  to  act.


                                46

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     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 an environmental regulatory authority.
POTWs have institutional frameworks in place to promote pollution
prevention.  Many POTWs 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 commercial establishments (e.g., Palo Alto
POTW targeting silver reduction at photofinishing
establishments).

     Through the pretreatment program's permitting and on-going
inspection and sampling activities, pretreatment staff can become
familiar with an industry's production process.  They are then in
an ideal position to promote pollution prevention through
information outreach  (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
staff).  Because of the recurring presence of  pretreatment staff
at industrial facilities and their environmental concerns,
incorporation of pollution prevention tasks into pretreatment
activities is evident.  Furthermore, the focus of pollution
prevention provides a level of complexity and interest to the
inspector's job which could be lost under the  more superficial
routine tasks required under the General Pretreatment
Regulations.

     At a recent EPA conference on pollution prevention, Dr.
Philip Lo  (of the Sanitation Districts of Los Angeles County,
California) summarized the advantageous position POTWs are in
relative to pollution prevention technology and information
diffusion:  "The POTW framework appears to have considerable
advantages over other frameworks for promoting pollution
prevention...POTW inspectors  seem to command more of a presence
at industrial facilities than inspectors from other  agencies.
POTW engineers are usually much more familiar with the  industrial
processes in a facility, given the experience of over a decade
regulating the facility under the Clean Water Act.   POTWs  have

                                47

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 traditionally asked for detailed piping plans and process  flow
 diagrams  for permit applications,  and  these plans can  form the
 basic  materials for identifying pollution prevention
 opportunities...a POTW is (therefore)  in a unique position to
 promote and effectuate pollution prevention, both helping  itself
 and benefiting the overall  environment."13
     13     Philip Lo,  "Pollution Prevention:  A Winning
Proposition For A POTW,"  paper presented at the International
Conference on Pollution Prevention:  Clean Technologies and Clean
Products. Washington, DC, June 10-13, 1990.


                                48

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4    CASE EXAMPLE OF SUCCESSFUL INTEGRATION OF POLLUTION
     PREVENTION MOTIVATORS

     We present here a fairly detailed case example of where
pollution prevention incentives have worked:  a regulatory
program example of the San Francisco Regional Water Quality
Control Board, California.  The goal is to present an integrated
picture of how both the array of potential factors and the key
motivators have played themselves out in the "real world."


     4.1  Background:  Regional Water Quality Control Board

     An excellent model for requiring the inclusion of pollution
prevention initiatives in local POTW pretreatment programs is
provided by the experience of the California Regional Water
Quality Control Board  (RWQCB) - San Francisco Bay Region.  The San
Francisco Regional Board  (hereafter referred to as the Regional
Board) is one of nine regional boards which, in conjunction with
the State Water Resources Control Board (WRCB),  manage
California's water resources, and are delegated to administer the
Federal water pollution control laws.

     The leverage for requiring pollution prevention activities
in the Regional Board's water regulatory programs was generated
by the violation of certain water quality prohibitions by the
three wastewater treatment facilities serving the communities of
Palo Alto, Sunnyvale and San Jose/Santa Clara.  These POTWs
discharge to the environmentally sensitive southern portion of
San Francisco Bay.

     Authority for the protection of South San Francisco Bay's
water quality is provided in the Water Quality Control Plan for
the San Francisco Bay Basin  (the Basin Plan), which is the
Region's program of actions to meet both state and federal
requirements to preserve and enhance the region's water
resources.  The Basin Plan specifically prohibits the discharge
of wastewater to South San Francisco Bay, and establishes other
provisions for protecting the bay which were not being met by the
three wastewater treatment plants.

     In 1981, the South Bay Dischargers Authority  (SBDA), a joint
powers agency involving the communities served by the three
wastewater treatment facilities, obtained a deferral to the Basin
Plan prohibitions on grounds of excessive associated costs.  A
number of water quality studies and reclamation projects were
required of SBDA in granting the deferral.

     Continuing concern over heavy metal concentrations in the
discharges from these plants, however, led  to the  inclusion  of
waste minimization requirements in their amended NPDES permits  in
1988.  At that time, the  term waste minimization was  still widely

                                49

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used,  and was defined by the  Regional Board as "the reduction in
toxic  pollutant  generation by product substitution, recycling,
and other means  ...".
      4.2   Approach to Implementing NPDES Waste Minimization
           Provisions

      In a phased approach,  the Regional Board first required a
Metals  Source Identification Study from each of the three POTWs
to  identify significant  influent metals sources.  This involved a
mass  balance effort in which total metals loads from regulated
 (i.e.,  monitored)  industrial sources were compared to the totals
measured  in the plant influent.  Data needs were identified to
fill  gaps in identifying all metals sources discharging to the
plants.   The quantification of mass loadings by source identified
the potential for further controls under the pretreatment
program.

      Based on findings in the metals source studies, waste
minimization studies further identified reduction target sources,
feasible  waste minimization technologies and measures, and
estimates of the program's costs to the POTWs and targeted
sources.   All studies found that further reductions of metals
entering  the sewer system were possible through a combination of
expanded  pretreatment restrictions and the initiation of waste
minimization efforts.
     4.3  POTW Data  Findings

      The mass balance  studies evaluated heavy metal
contributions  from different  service area sectors.  The studies
compared influent  loads of  heavy metals with the loads measured
from each individual sector.  Because elevated concentrations
from any one sector  are dampened in influent measurements, the
mass balance calculations often show loads from a specific sector
exceeding the  total  load measured at the influent.  Thus, while
the mass balance calculations provide good initial estimates of
pollutant loads, more accurate determinations  result from longer
term data collection efforts  (i.e., to identify errors in
measurement and compensate  for extreme values resulting from
spills, etc.).

     The relative  source contribution of the total load for each
metal varied for each POTW.   The flows generated from each source
directly influenced  pollutant loadings calculation  (i.e.,
concentration  x flow =  loading) .  Results are summarized below:

     Industrial Sources:

Palo Alto - significant source of nickel, cyanide, copper, lead

                                50

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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  commercial
sector); copper and nickel loads were relatively  low
(approximately 5% of total POTW load).

San 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 load).

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 copper14, 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
silver.
           The copper came largely from the copper sulfate root
control agents many households put 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.
                                51

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     As a  result  of  these  findings, each of the POTWs targeted
different  metals  and sources  for waste minimization initiatives,
as summarized below:
POTW                  Targeted Metals    Targeted Sources

Palo Alto             Silver             Commercial and
                                         industrial
                                         photoprocessors,  X-Ray
                                         labs and other
                                         potentially important
                                         sources

San Jose/Santa Clara Lead, Copper, Zinc Radiator repair,  auto
                                         parts cleaning shops and
                                         other potentially
                                         important sources

Sunnyvale             Lead, Copper,      Metal Finishers,
                      Nickel             electroplaters and other
                                         potentially important
                                         sources
     4.4  Regional  Board Follow-up

     The Regional Board amended  its  1988 NPDES waste minimization
requirements  in May 1990 to reflect  the metals study findings.
The amended permits require that pilot waste minimization
programs:


o    Be tailored to address the  targeted industrial sector(s)

o    Establish best management practices  (BMPs) and waste
     minimization alternatives for the targeted industries

o    Include  public education

o    Coordinate efforts with the county toxics program to provide
     technical assistance to targeted firms

o    Require  waste  minimization  plans in response to industry
     violations and as  a condition of permitting for new permit
     applicants

o    Coordinate program development  and share findings


                                52

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     Regional Board staff have worked closely with SBDA
representatives to ensure success of the individual programs.

     Based on the success of its waste minimization requirements,
the Regional Board has developed similar pretreatment and waste
minimization requirements under the Mass Emissions Strategy
(MES),  as called for in the State Water Resources Control Board's
Pollutant Policy Document for the San Francisco Bay-Delta.  The
MES requires the Regional Board to develop limitations on the
mass emissions of toxic pollutants 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 community
at large.  Waste minimization requirements similar to those
established for SBDA would be instituted for POTWs as well as
direct industrial dischargers in the San Francisco Bay region.
Public outreach and educational programs would also be an
important component of the Regional Board's waste minimization
program.


     4.5  POTW Follow-up

     Differences in service area characteristics, legal
authorities, administrative priorities and other factors unique
to each area are reflected in the approaches adopted by each of
the POTWs.  Based on their experience and findings in meeting the
waste minimization requirements, the SBDA cities have initiated
the following significant changes to their pretreatment programs:

Palo Alto:

o    Sewer Use Ordinance Revision - waste minimization audits
     required for permit issuance and following industry
     discharge violations

o    Waste Minimization Study  (WMS) Review Process - Industries
     identified as being "major contributors" of heavy metals are
     required to submit a WMS report to the POTW.  The WMS review
     process involves the active participation of the POTW, the
     POTW's consultant for the waste minimization program, and
     the industry.  Following WMS acceptance by the POTW, the
     discharger must conform to the plan of action and schedule.
     Progress reports and Notices of Completion may also  be
     required.

o    Waste Minimization Program Status Report  - these reports
     document program accomplishments and procedures as they
     develop.


                                53

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     Silver Reduction  Pilot Program - This program couples
     publicity  and  education with waste collection services and
     regulatory coordination  (e.g., local Fire Department, County
     and State  Health  Departments) to ensure elimination of
     redundant  regulation and the minimization of permit fees.
     The POTW now has  a drop-off facility for silver-bearing
     photochemicals. Contracts with local waste haulers have been
     drawn up to facilitate industry compliance.

     Mass Discharge Limit - The POTW has developed a protocol for
     incorporating  both mass loadings and pollutant
     concentrations into industry compliance determinations.
     Because pollution prevention initiatives often result in
     reduced flows, pollutant concentrations may increase as a
     result, despite net decreases in pollutant loadings to the
     POTW.  This protocol recognizes this and avoids penalizing
     facilities that have made significant accomplishments.
San Jose:
     Revised  its  Sewer Use Ordinance  - notably, to require waste
     minimization plans  for permit  issuance and following
     industry discharge  violations.

     Best Management  Practices  - Targeted sources and significant
     industrial users are required  to develop pollutant mass
     balances, best management  practices, and institute material
     inventory controls  in their waste minimization plans.

     Zero Discharge Requirements -  Automotive and radiator repair
     shops are not allowed to discharge to the sewer system. The
     POTW is  exploring ways of  ensuring optimal management of the
     prohibited wastes to ensure multi-media environmental
     protection.

     Enforcement  Hearings - To  avoid  time losses associated with
     regulatory follow-up to discharge violations, San Jose
     requires facility managers to  appear at enforcement hearings
     after the first  violation.  These hearings circumvent a
     considerable amount of paper work and time loss associated
     with discharge violations.  Agreements on penalties and
     compliance deadlines are set at  the hearing, resulting in
     much faster  resolution of  the  noncompliance.   The hearings
     furthermore  serve as effective forums to communicate the
     POTW7 s environmental concerns  directly to company
     management.
Sunnyvale:
     Waste Minimization Audits  - Sunnyvale requires waste
     minimization audits for permit issuance and following
     industry discharge violations.  The  Sewer Use Ordinance was
                                54

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     found to provide adequate authority for this.   Three of
     Sunnyvale's 68 industrial users have completed audits to
     date; it is expected that the remainder will be completed
     within three years time. The waste minimization audits are
     conducted either by industry personnel or by outside
     consultants.

     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 pretreatment programs.  The difference in
implementation of the three SBDA pretreatment programs
demonstrates the latitude provided in the Regional Board's
approach.  Differences in service area characteristics, legal
authorities, administrative priorities and other factors unique
to each area are effectively accommodated.

     Important components of the Regional Board's pretreatment
program regulatory approach can be summarized as follows:

o    Establishment of a close working relationship with the local
     pretreatment 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
     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
                                55

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     Further evidence of the Regional Board's success in
administering the pretreattnent program is that Sunnyvale was
awarded EPA's National Pretreatment Award for 1991 and other Bay
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).
                                56

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REFERENCE
Barren, Thomas S., Evaluation of the DBS Waste Audit Study
      Program. California Department of Health Services, May 1991.

Brown, Gardner and Ralph Johnson, The Effluent Charge System in
      the  Federal Republic of Germany;  An Example of the Economic
      Incentive Based Approach to Abating Water Pollution. 1983.

California Department of Health Services, Waste Reduction for
      Metal  Finishers;  Fact Sheet,  Toxic Substances Control
      Program, 1989.

California Department of Health Services, Hazardous waste
      Reduction Checklist and Assessment  Manual for the Metal
      Finishing Industry. Toxic Substances Control Program, May
      1989.

California Department of Health Services, Waste Audit Study;
      Metal  Finishing Industry. Toxic Substances Control Program,
      May  1988.

Chen, Donna and  Deborah Hanlon, Los Angeles City's Expanded
      Industrial  waste 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.

Commonwealth  of  Massachusetts, FY 90 Report on the Blackstone
      Project. Department of Environmental Protection and
      Department of Environmental Management, July 23, 1990.

Dillon, Patricia S.,  Pizzolongp, Peter J. and Gerald J. Filbin,
      Industrial Environmental Management Practices;  Decision
     	ses and Performance Measur^"*^nt. U.S. EPA/Tufts
     University Center for Environmental Management, Workshop
     Proceedings, July 17, 1990.

Fromm, Carl H.  and David Butler, Practical Guidelines for
     Estimating the Profitability of Waste Minimization Measi
Greiner, Timothy J.,  Closed-Looped Metal Finishing Process*
      Massachusetts Department of Environmental Management,  April
      1990.

Jones, Lewis S.,  Chapman,  Nancy Jo and John F. Grittin, "A  Source
      Control Program for Waste Minimization at Metal Finishing
      Facilities," East Bay Municipal Utility District
      (California), paper presented at the 64th Annual Water
                                   57

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      Pollution Control Federation Conference, Oct. 6-10, 1991,
      Toronto, Canada.

 Lo,  Philip, "Pollution Prevention:  A Winning Proposition for  a
      POTW," Los Angeles County Sanitation Districts, paper
      presented at International conference on Pollution
      Prevention;  Clean Technologies and Clean Products, June 10-
      13, 1990, Washington, DC.

 New Jersey Department of Environmental  Protection, Design of
      Programs to Encourage Ha7.ardo»g waste Reduction;  An
      Incentives Analysis, Final Report, Oct.  21,  1988.

 Rosenblum,  John and Mazen J.  Naser, "Heavy Metals Waste
      Minimization;  Practice and Pitfalls," Journal of Plating anc
      Metal Finishing, April 1991.

 Sherry,  Susan,  Reducing Industrial Toxic Wastes and  Discharges;
      The Role of POTWs, Local Government Commission, Sacramento,
      CA, Dec. 1988.

 United States Environmental Protection  Agency, Report to Congress
      on the National Pretreatingnt Program, July 1991.

 United States Environmental Protection  Agency, "General
      Pretreatment and NPDES Regulations, Final Rule,"  Domestic
      Sewage Study (DSS) Regulations,  55 Federal Register 30082.
      July 24, 1990.

 United States Environmental Protection  Agency, Guide to Pollution
      Prevention;  T1^ fabricated Met-^l Products Industry. ORD:
      EPA/625/7-90/006, July 1990.

 United States Environmental Protection  Agency, Waste Minimisation
      in  Mer^ii Parts Cleaning,. OSW,  Aug. 1989.

 United States Environmental Protection  Agency, Waste
      Audit Reports  Cflse Studies of Minimization of Cyanide from
      Electroplating Operations. ORD:  EPA/600/S2-87/056, Jan.
      1988.

United States Environmental  Protection Agency, Development
      Document for Effluent Limitations Guidelines and standards
      for the Metal Finishing Point Source Category, EPA 440/1—
      83/091, June 1983.

United States Environmental  Protection Agency, Control and
      Treatment Technology for the Metal Finish ing Tndustrv— — In
      Plant Changes ( Summary Report) , ORD:  EPA/625/8— 82/008, Jan.
      1982.
                                  58

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United States General Accounting Office, Serious Problems Confront
      Emerging Municipal Sludge Manaaen^nt Program. GAQ/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., Hillier, 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 Preventioni   Clean  Technologies and Clean Products,
      June 10-13, 1990,  Washington,  DC.
                                   59

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APPENDICES
      60

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Appendix A:
Site Visits
     Below is  a matrix of site visits conducted by Kerr &
Associates  for the  Incentives Project in June and July, 1991.
Following the  matrix are exerpts from our site visit memos to EPA
of July 2 and  Aug.  22, 1991.
Facility
Allied
Manufacturing
Fernando Originals
Neles - Jamesbury
New England
Plating
Parker Metals
Seville Dyeing Co.
POTW
Cranston Water
Control Facility
Upper Blackstone
Water Pollution
Abatement District
Warwick Sewer
Authority
Location
Auburn, MA
Providence,
RI
Worcester,
MA
Worcester,
MA
Worcester,
MA
Woonsocket,
RI
Location
Cranston, RI
Auburn, MA
Warwick, RI
Type
Metalwork;
mirror
finish
machining
Jewelry
design and
manufacture
Valve
manufacturer
Zinc
plating;
some chrome
plating
Manufactures
nails ,
screws ,
shopping
carts
Textile
manufacturer
Size
23 MGD
35 MGD
3.5 MGD
Comments
Medium- size job
shop; no
plating lines
Medium- size
captive shop;
precious metal
plating
Large captive
shop; tumbling,
phosphating and
plating lines
Large job shop;
direct
discharger
Large captive
shop ; switched
to alkaline
zinc plating
No plating;
reduced COD
loadings
Comments
Fee system for
users indexed
to toxics
loadings
Multimedia
inspections
with MA DEP/DEM
Strict local
limits;
promotes zero
discharge

-------
 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 recession-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 over 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.

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Neles-Jamesbury
Worcester, MA

     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 Blacks tone 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 $60K.  They want to avoid the uncertainty of
changing regulations and 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 onerous  treatment system.  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.

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 New England Plating
 Worcester,  MA

      New England Plating, a contract  shop, plates primarily zinc
 along with some nickel and chrome.  They discharge to a tributary
 of  the Blackstone ("Mill Brook") under an NPDES permit.  New
 England Plating installed a traditional hydroxide sludge
 precipitation system in the late Sixties/early Seventies when
 NPDES first addressed electroplaters.  They spend about 14% of
 their annual sales on wastewater treatment, and they blame that
 expenditure—at least to some extent—for their current precarious
 financial position.  They argue that  competitors who elected to
 discharge to the POTW installed treatment systems much later than
 they themselves did, and so had the use of those funds for the
 intervening years.

      New England Plating can usually  meet their permit limits now,
 but their permit is up for renewal and they are afraid they will
 not be able to afford to change the plant to meet tighter limits.
 Both Bruce Warner and Joe Diaz are aware of pollution prevention
 opportunities for the shop, but do not plan to act on them.  For
 example, they have considered switching over from cyanide zinc to
 alkaline zinc plating.  In order to avoid blistering (a major
 quality problem), they would need to  run lower current densities
 than they do now.  Since plating would require more time at a
 lower current density, to keep the same throughput (= income) they
 would have to build a longer line.  The payback in reduced
 wastewater treatment and in raw material savings should offset the
 construction and downtime costs in less than a year, but the firm
 has little cash and would not qualify for a loan.

      In addition to cash position, other barriers to change at the
 facility include the investment in large automatic equipment (now
 over fifty years old). The firm's many years of experience in
 traditional preciptiation/sludge management may make them less
 receptive to technical assistance.  Mr. Warner has developed his
 own expertise in reduction and precipitation systems to the point
 that he teaches classes for wastewater treatment operators.
Parker Metals
Worcester, MA

     Parker  Metal Corporation manufactures nails,  screws,
fasteners, shopping carts,  and custom items on a contract basis.
We saw the zinc plating line  for the shopping carts and the
wastewater treatment area.  They had been fined by EPA Region  I
for failure  to  install  a pretreatment system on schedule—they
completed their current system under a consent order.  They
switched from nickel-chrome (requiring cyanide) to alkaline zinc
plating of shopping carts a few years ago, to reduce health risks
associated with cyanide and to reduce wastewater treatment costs.

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     Three points  stood out:  first, Bob Larson, the Engineering
V.P.,  had proposed the alkaline zinc process for some time
without success; when a French competitor introduced zinc-plated
carts in the U.S., his  management finally bought in.  Second,
based on previous  experience with the EPA Regional Office, the
Environmental Coordinator  (Rod Swenson) was forbidden to call
Boston with questions for  fear of retribution.  Lastly, when the
firm made the decision  to  switch chemistries, it affected not only
the plating line but also  the wastewater treatment system design.
They found it has  taken four years to understand the process
sufficiently to keep it in control, and they still find variations
(within the limits) that they couldn't predict and don't really
understand.  To control the zinc concentration within the plating
tanks they designed their  own mechanism for controlling the
exposed zinc metal surface area, and to consistently precipitate
zinc their consultant and  their operator have experimented with
several aspects of the  treatment system.

     In addition to pollution prevention through material
substitution, Parker Metals has reduced the volume of water
treated and sludge generated by implementing Massachusetts OTA
suggestions such as fog rinsing, dragout recovery, rinse flow
control by conductivity, reactive rinsing, and reuse of compressor
water.  They also  substituted hydrochloric for sulfuric acid in
wastewater treatment.   Their motivation has been to reduce the
costs associated with running the wastewater treatment plant.
Seville Dyeing Company
Woonsocket, RI

     We visited  a textile mill in Woonsocket, RI, that has worked
closely with its  POTW (Woonsocket) to reduce COD loadings and save
on both water and energy use using pollution prevention measures.
The POTW has been recognized nationally for the excellence of
their pretreatment program, and we wanted to pursue the question
of what distinguishes pretreatment program managers who are
effective at promoting pollution prevention, even though in
Woonsocket textile production dominates over plating.  Through
enforcement actions the Woonsocket POTW has encouraged the Seville
Dyeing Company to reduce their COD contribution to the plant—in
particular, by limiting the number of black dye runs.  If the firm
demonstrates that most of the COD loadings come from other sources
within the plant,  the restrictions will be modified.  They are
saving $150K/yr  in water, sewer, and raw material costs as a
result of the changes they developed after encouragement from the
POTW.

     One of the  changes Seville has  just begun to pursue is to  use
heat exchangers  instead of live steam to warm the river water in
the dyeing kettles.  With properly maintained heat exchangers,

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 they will use less fuel for the boilers than they currently do,
 because a substantial amount of superheated steam escapes from the
 dye kettles as they are currently operated.  In addition to that
 energy savings, Seville's owner expects to see a marked reduction
 in re-dyes due to quality problems from rust and other
 contaminants carried from the boiler  to the dye solutions in the
 steam.  The cost reduction opportunity in quality control (as
 opposed to energy savings) has been their primary motivator in
 speeding up the modification to all of the other kettles, but they
 only discovered the opportunity when  they saw re-dyes virtually
 eliminated in the first kettle changed to save energy.
 Cranston Water Control Facility
 Cranston, RI

      The Industrial Pretreatment Program for the City of Cranston,
 RI  is managed by Tutela Engineeing Associates with 100% industrial
 cost recovery.  The secondary wastewater treatment facility, sized
 for 23 MGD,  serves a population of 70,000 and discharges about 12
 MGD to the Pawtuxet River.   There are  88 significant industrial
 users (SlUs) and about 250  non-significant  industries in the
 pretreatment program.

      The cost recovery program, described to us by Al Tutela,
 provides incentives to firms to reduce water use and avoid upsets:
 one fee is proportional to  the flow-based sewer use fee collected
 by  the city, with a surcharge for SlUs based on the highest
 concentration measured during the billing year for each of nine
 pollutants (Cd, Cr, Cu, Pb,  Ni, Ag,  Zn,  total CN, and TTO).
 Concentrations, below the Sewer Use Ordinance limit (markedly below
 the discharge permit limit)  are counted  as  zero for billing
 purposes, providing an economic incentive to reduce or eliminate
 releases of these materials.  The program does not distinguish
 among loadings reduced through pollution prevention or
 conventional pretreatment.
Upper Blackstone Water Pollution Abatement District  (UBWPAD)
Auburn/ MA

     The  UBWPAD serves the City of Worcester and the Town of
Auburn.   A 35 MGD plant near the headwaters  of the Blackstone
River, its flow constitutes about 70% of the 100-year drought  dry
weather flow.   We met  with Paul Richard, the UBWPAD  Pretreatment
Coordinator who participated with the Massachusetts  Department of
Environmental Protection (DEP)  and Office of Technical Assistance
(OTA) in  multimedia inspections for the Blackstone Project; Tim
Deegan, the current UBWPAD Pretreatment Coordinator;  and  Debra
LaVergne,  Laboratory Manager.

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     Massachusetts  does  not have CWA delegation from EPA;  EPA
Region I regulates  the POTW.  The POTW's current NPDES permit does
not include discharge limits for metals; however, the proposed one
would.  UBWPAD uses the  EPA categorical limits (40 CFR 413 and 40
CFR 433) as local limits.  Apparently the governing board and the
communities won't support local limits stricter than the NPDES
permit requires—because they are in compliance with their NPDES
permit, they don't  see a problem.  They are concerned that they
may need to institute local limits if the new permit comes into
effect as proposed, despite vociferous opposition from the
business community.  A reverse osmosis system their consultant has
specified to control metals would cost several million dollars to
install and operate.

     We discovered  that  the POTW doesn't perceive itself to have
the authority that  EPA does.  On the basis of a conflict with a
categorical source, they had concluded that they could not enforce
limits at the end of the treated process (before the waste stream
was combined with sanitary wastes and other diluting streams).
The firm in question, which occupies several city blocks, owns the
sewer pipes in the  vicinity of their plant.

     The Pretreatment Coordinator asserted that by coordinating
with a state multimedia  inspection team and a technical assistance
program, he became  more  effective in promoting pollution
prevention.  One factor  of this effectiveness may have been his
own increasing familiarity with and promotion of pollution
prevention options.
Warwick Sewer Authority
Warwick, RI

     The Warwick Sewer Authority in Warwick, RI, treats about 3.5
MGD before discharge to the Pawtuxet River, which has a flow of
about 50 MGD.  The Cranston and West Warwick authorities also
discharge to the Pawtuxet.  Their NPDES permit is up for renewal,
and the proposed numbers are significantly less than the previous
permit:  silver  - one  microgram/liter; lead - three
micrograms/liter; and  copper - ten micrograms/liter.  The numbers
were based on a  water  quality study from the University of Rhode
Island.  Warwick will  do bioassays with Daphnia Pulex and flathead
minnows to establish what concentrations would have toxic effects.
Three-fourths of the Pawtuxet flow is from treatment plants.

     Warwick has had local  limits since February of 1986 which  are
much stricter than the categorical limits.  Their ordinance
authorizes them  to measure  as EPA does, after the process stream
has been treated but before combination with diluting waters like
sanitary wastes. We met with Howard Hadfield, the Warwick
Pretreatment Coordinator and  President of the Rhode Island
Pretreatment Forum.  Mr. Hadfield maintains that the stricter

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local limits make  the  firms more efficient because they have had
to use better  management practices to come into compliance—that
categorical standards  are  "way behind the times."  Pollution
prevention is  also the new thrust because some firms use too much
water—the sewer use charges will be going up again soon, in part
to drive water use reduction.  The state Pollution Prevention
Council is studying alternatives, and the state technical
assistance program is  effective in spreading the word.  The
jewelry industry has not suffered as much as other platers during
the economic downturn—they still have money to invest in process
changes.

     Howard raised the "zero discharge" question that directly
affects pollution  prevention choices made by platers in Rhode
Island:  if a  manufacturer reduces water and chemical use enough
to allow reuse of  the  water in the process and some evaporation
rather than discharge  under NPDES or to a POTW, do they then lose
the RCRA exemption for water treatment and require a Part B
permit?  A few Rl  shops have been shut down over air complaints—
it bears further study under what conditions "zero discharge"
systems are desirable  and  how logically as well as statutorily
that they should be regulated.

     One Warwick plater invested heavily to develop a closed-loop
system using ion exchange.  The RI DEM Air & Hazardous Materials
Division shut  them down with a cease & desist order because they
did not have a RCRA Part B permit to run the unit.  Rather than
taking on the  legal battle, the plant president chose to spend
additional money and resume discharge to the sewer.

     In each quarterly newsletter the pretreatment program focuses
on a particular company in the community.  The program gets calls
from other companies wanting to be recognized for their
environmental  achievements—the distribution to other significant
users and to legislators and DEM is seen as valuable press.

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Appendix B:     Selected PPIC Case Studies
     Name  & Location of Company

     Bass  Plating Company
     Old Windsor Road
     Bloomfield, CT

     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.  Pollution prevention options implemented
     were  low-cost, low-tech, but with high O & M savings and
     short pay-back period (less than 6 months).

     Case  Study Summary

     3.1   Process and Waste Information:  The company specializes
           in zinc, cadmium, nickel-cadmium, and tin plating and
           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  Development:  The options identified above
           have been implemented.  Other options have been
           identified which may be implemented in the future.

     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 Time:   Payback period is 5.8 months.

     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.

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6    Obstacles,  Problems, and/or Known Constraints:  None
     reported.

7    Contacts  and  Citation

     7.1   Citation:   ConnTAP Matching Challenge Grants - 1988-89,
          Connecticut Hazardous Waste Management Service, pp. 4-
          5.   "Summary Report, Cadmium Waste Management Program,
          Bass Plating Company," Bass Plating Company, June 1989.

     7.2   Indus try/Program  Contact and Address:  Rocco
          Mastrobattista, Project Manager, Bass Plating Company,
          Old Windsor Road, Bloomfield, CT  06002, (203) 243-
          2557-

8    Clean Technology Category:  The technology involves
     implementation of good operating practice and waste
     minimization  options such as increasing drip times, elevating
     plating bath  temperatures, improving drip containment and
     redesigning plating racks.

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Name & Location of Company

Pratt & Whitney Aircraft
North Haven, CT

Relevance to Incentives Study

Example of large captive shop associated with major metal
parts manufacturer.  Ultimate goal is zero discharge, but
facility is proceeding in phased implementation steps. New
plating lines "already on the drawing boards" were re-
examined in light of facility-wide pollution prevention
program. Designs were revised to incorporate whole range of
plating source reduction and recycling/reuse options.

Case Study Summary

3.1  Process and Waste Information:  This facility produces
     major 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.

     In Phase One good operating practices were defined.
     These include defining minimum water quality standards;
     using countercurrent rinses to reduce water usage; using
     continuous process purification versus batch
     purification to maintain consistent process quality
     (i.e., dummy plating and carbon and particulate
     filtration); using on-line process monitors to control
     solution additions; optimizing process solutions to
     control dragout; optimizing preplate rinsing to control
     dragin of contaminants; installing automatic level
     controls on all heated processes; training operators to
     understand proper rinsing and work transfer techniques
     to reduce dragout and dragin; and treating small
     concentrated 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 conducted on an existing
     nickel plating process encompassing a Woods nickel
     strike and four sulfamate nickel plating tanks.

     Phase Four incorporates good operating practices and
     closed-loop technologies in the design of planned and
     appropriated new plating lines.  New plating  lines,
     encompassing  (1) nickel and chromium plating,  (2)

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     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
     chromating.

3.2  Scale of Operation: The facility encompasses 1,000,000
     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
     years.

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  Citation:   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.

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Name & Location of Company

precious metal (Ag) plating
California

Relevance to incentives Study

Two examples from a plating company which, despite waste
minimization audits and on-site technical assistance, decided
not to adopt recommended pollution prevention measures.  One
was a fairly low cost option (drag-out minimization) that was
implemented for a while, then abandoned when violations in
silver limits returned to original (pre-process modification)
levels.  The other involved a capital outlay of $500K for the
proposed in-line reverse osmosis (RO) system that would have
resulted in an annual savings to the company of some $825K in
maintenance costs (for the current reclamation system),
however the company chose not to pursue it. Instead they
devoted over $1 million to upgrade their conventional
wastewater treatment plant.

Case Study Summary

3.1  Process and Waste Information: in the first example, the
     plant's wastewater treatment was frequently violating
     the discharge standard for silver.  The major sources of
     the silver were rinses following silver-cyanide plating
     in the reel-to-reel lines.  The plant evaluated whether
     or not to modify the treatment system or introduce
     waste minimization in the production line.  A strategy
     to reduce silver drag-out was initiated, including:
     efficient air-knives installed at the rinse tanks, more
     efficient electrolytic recovery cells installed on the
     dead rinses following the silver plating baths, and
     flow restrictors installed on all rinses.

     In the second example, to replace off-site silver
     reclamation, on-site silver reclamation was proposed
     to reclaim silver from the silver dead rinses.  This
     in-line reuse system consisted of 6 reverse osmosis
     units.  The installation would involve conversion of
     the dead rinse and Dl-Water rinse stations to a two-
     stage counter flow rinse, conductivity control of DI
     Water supply, and recirculation pumps for rinsing to
     reduce the flow rate.

3.2  Scale of Operation:  Information not  provided.

3.3  Stage of Development:  Recommendations  not  implemented

3.4  Material/Energy Balances  and  Substitutions  (Example 11;

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                              Quantity            Quantity
 Material Category            Before              After

 silver drag-out reduction
      rinse-wastewater:        240,000 gpd        155,000 gpd
 silver cpncentration
       in influent:           5 mg/1             0.5 mg/1
 silver concentrations
       in effluent:           N/A                < 0.15 mg/1


 Economics

 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
      months.

 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.

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     Due to the large capital cost needed for the in-line reuse
     system in the second c^rampi«»f the facility also decided not
     to adopt the in-line silver reclamation system.

7    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, 3502 Thorn Road,
          Sebastopol, 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.

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Name & Location of Company

Seaboard Metal Finishing Co., Inc.
50 Fresh Meadow Road
West Haven, CT  06516

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-tech, 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%.

Case Study Summary

3.1  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 F006
     sludge requires off-site disposal.

     A waste minimization 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
     personnel.

3.3  Stage of Development:  The proposed alternatives had
     not been implemented at the time the case study was
     written.

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 Time:  The  payback period is  estimated at  1.2
     years.

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5    Cleaner Production Benefits:  If the alternatives were
     implemented, a reduction of 75% would be achieved for
     copper, hexavalent chromium, cyanide, and nickel wastewater.
     About 16 tons of F006 sludge, now requiring off-site
     disposal, would be eliminated.

6    Obstacles, Problems, and/or Known Constraints:  None
     mentioned.

7    Contacts and Citation

     7.1  Citation:  ConnTAP Matching Challenge Grants - 1988-89,
          Connecticut Hazardous Waste Management Service, pp. 8-
          9.  "Waste Minimization Study." YWC, Inc., April 1989.

     7.2  Industry/Program Contact and Address:  John Conroy,
          Project Manager, Seaboard Metal Finishing Co.,  Inc., 50
          Fresh Meadow Road, West Haven, CT  06516 (203)  933-
          1603.

8    Clean Technology Category:  A waste minimization study,
     including performing a mass balance and waste inventory,
     identified alternatives for future implementation.

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Name & Location of Company

Stanley Fastening Systems
Route 2
East Greenwich, RI  02818

Relevance to  Incentives Study

Example of medium-size metalworking firm that eliminated use
of TCA by installing aqueous parts washing systems.
Motivation to eliminate TCA was both economic and regulatory
(plant was exceeding discharge limit).

Case Study Summary

3.1  Process  and Waste Information:  This facility
     manufactures nails, staples, and the tools to drive
     these fasteners.  The fastening tools are made of
     aluminum, magnesium and carbon steel.  To produce these
     parts, grinding, milling, drilling, lathe working, heat
     treatment and metal finishing operations are employed.
     Prior to many of these operations, parts are cleaned  in
     a cold application using 1,1,1-trichloroethane  (TCA).
     TCA was  being discharged in the wastewater at levels
     twice as high as the allowable limit.  Absorbents used
     around the machine tools also showed levels of  TCA that
     prevented disposal in the regular trash.  The company
     decided  to eliminate the use of TCA.

     A task force identified reasons for excessive use of
     TCA:  too much availability of cleaners, unnecessary
     dumping  of TCA, lack of operator awareness, and
     unnessary parts cleaning.Initially, the firm reduced  the
     number of cleaning stations from 37 to 27.  Costs
     associated with dumping of cleaners were make the
     responsibility of each department.  Operators were
     surveyed to identify TCA use and determine alternatives.

     The selected pollution prevention measure was to
     installed 13 aqueous washing systems and 2 mineral
     spirits  cleaning systems.  They expect to have  a total
     of 15 aqueous systems, which are centralized within
     departments to replace 37 former TCA locations.

3.2  Scale of Operation: Approximately  6500 gallons  per year
     of TCA were originally used. No other measure of the
     scale of operations was provided.

3.3  Stage of Development:  In the implementation stages-all
     equipment is not yet fully  installed

Economics

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      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 aqueous
           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.

5     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 $34,000.

      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).

6     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.

7     Contacts and Citation

      7.1  Citation:  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. 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.

8     Clean Technology Category: The  clean technology involved
      initially  reducing 1,1,1-trichlorethane use and finally
     eliminating its use  by installing aqueous cleaning systems.

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Appendix C:
Telephone Contacts List
Institution
 Location
Contact
Comments
Acteron Metal
Finishers
 Redwood
 City, CA
Pat Hurt
Chairman, NAMF Waste
Minimization Committee.
Gave industry
perspective and further
technical contacts.
Atlantic
States Legal
Fund
 Syracuse,
 NY
Alan
Hayes
Attorney handling CWA
citizen suit cases;
pollution prevention in
enforcement settlement.
Barron
Consulting
 Lafayette,
 CA
Tom
Barron
Authored "Evaluation of
Waste Audit Study
Program" for CA DBS
Alt. Tech. Div.;
evaluated audit program
impacts on 6
industries.
California
DHS
Alternative
Technology
Division
 Sacramento,
 CA
Kathryn
Barwick
Gave DHS perspective of
state, regional, and
local POTW pollution
prevention initiatives.
California
DHS
Alternative
Technology
Division
 Sacramento,
 CA
Arvind
Shah
Contact person for CA
Waste Reduction Act of
1989 (SB-14); discussed
CA waste audit guidance
documents.
California
Local
Government
Commission
 Sacramento,
 CA
Tony Eulo
Has been involved with
pollution prevention in
CA for several years;
gave local government
perspective.	
California
Regional
Water Quality
Control Board
 Oakland, CA
Teng-
chung Wu
Chief, Surface Water
Div.; pioneered
incorporation of
pollution prevention
requirements into POTW
NPDES permits.	
California
Regional
Water Quality
Control Board
 Oakland, CA
Dale
Hopkins
Pretreatment
Coordinator for RWQCB.
EPA, Region 1
 Boston, MA
Joe
Canzano
Perspective on using
pollution prevention
requirements in
enforcement context

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 EPA,  Region 9
San
Francisco,
CA
Laurie
Kermish
Attorney in Office of
Regional Counsel; metal
plater enforcement case
with pollution
prevention planning
requirement in Consent
Order
 Integrated
 Technogies
Bethany, CT
Peter
Gallerani
Former owner of VT
metal finishing shop;
consultant and promoter
of pollution prevention
with nation-wide
experience.	  	
Mass.  DEM
Office of
Technical
Assistance
Boston, MA
Barbara
Kelly
Director of OTA; gave
non-regulatory
technical assistance
perspective.	
Mass.  DEM
Office of
Technical
Assistance
Boston, MA
Tim
Greiner
Contact on Blackstone
Project; perspective on
zero discharge systems
in Mass, (permit); gave
leads on facilities for
site visits.
Narragansett
Bay
Commission
Providence,
RI
Tom Uva
Pretreatment Program
Manager; talked about
EPA audits of
pretreatment programs;
also leads on zero
dischargers and jewelry
platers.	
Palo Alto
Water
Pollution
Control Plant
Palo Alto,
CA
Phil
Bobel
POTW perspective;
progressive pollution
prevention program
targeted to
photofinishers;
formerly with EPA and
CA DHS.
Rhode Island
DEM, Water
Resources
Division
Providence,
RI
Gina
Friedman
State Pretreatment
Coordinator;
perspective on
delegated states; gave
contacts for site
visits and follow-up;
zero discharge and
vendor issues
Rhode Island
DEM, Air &
Hazardous
Waste
Division
Providence,
RI
Bev
Migliori
Regulatory perspective
on RI interpretation of
possible RCRA
violations associated
with zero discharge
systems	

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Rosenblum
Environmental
Engineering
Sebastopol,
CA
John
Rosenblum
Consultant in pollution
prevention, with
expertise in energy and
water conservation;
performed many waste
audits for SF Bay metal
finishers.
Sunnyvale
water
Pollution
Control Plant
Sunnyvale,
CA
Helen
Famham
General Manager of POTW
that won 1991 EPA
Pretreatment Award;
pollution prevention
requirements in NPDES
permit; POTW targets
metal finishers and
electroplaters for PP.
Sunnyvale
Water
Pollution
Control Plant
Sunnyvale,
CA
Pamela
Morrison
Pretreatment Manager;
gave details on POTW's
sampling and QA/QC
protocols; 10 years at
Sunnyvale POTW.	
Sunnyvale
Water
Pollution
Control Plant
Sunnyvale,
CA
Chris
DeGroot
Pretreatment inspector;
former process engineer
in a printed circuit
board plant; gave both
technical and
regulatory perspective.

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