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3.1 Categorical Standards Are Outdated and Irrelevant 14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
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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
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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
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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.
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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
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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.
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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.
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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
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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.
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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
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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
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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.
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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
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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.
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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
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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
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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.
-------
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,
-------
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.
-------
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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