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THE SOUTH BAY PILOT PROJECT :
POLLUTION PREVENTION EFFORTS
IN THE
SOUTH SAN FRANCISCO BAY AREA
A Report by the
U.S. Environmental Protection Agency
Region IX
75 Hawthorne Street
San Francisco, CA 94105-3901
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THE SOUTH BAY PILOT PROJECT:
POLLUTION PREVENTION EFFORTS IN THE
SOUTH SAN FRANCISCO BAY AREA
A report by the
U.S. Environmental Protection Agency
Region IX
75 Hawthorne Street
San Francisco, CA 94105-3901
Authors: Ben Macho1, Environmental Engineer (415) 744-1941
Claire Elliot, Environmental Engineer
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ACKNOWLEDGMENTS
We would like to thank the following people for their assistance:
Phil Bobel, Environmental Compliance Division Manager,
City of Palo Alto
Virginia Cummings, Chief, Pollution Prevention Team,
Construction Grants Branch,
U.S. EPA Region IX
Helen Farnham, Environmental Operations Manager,
City of Sunnyvale
Dale Hopkins, Surface Water Protection Division,
Regional Water Quality Control Board
San Francisco Region
Patrick Kwok, Technical Services Division Manager,
City of San Jose
Keith Silva, Pretreatment Coordinator, Pretreatment and
Compliance Program Section,
U.S. EPA, Region IX
Harry Seraydarian, Director, Water Management Division,
U.S. EPA Region IX
Robert Wills, Chief, Pretreatment and Compliance Program Section,
U.S. EPA Region IX
Teng-chung Wu, Chief, Surface Water Protection Division,
Regional Water Quality Control Board,
San Francisco Region
This report has been developed as part of EPA's pollution
prevention efforts to help states, cities, and POTWs develop
pollution prevention policies and programs.
The contents of this report do not necessarily reflect the view
of the above individuals or organizations. The mention of
commercial" products, commercial services, their sources or their
use in connection with material reported herein is not to be
construed as actual or implied endorsement of such products or
services.
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EXECUTIVE SUMMARY
SOUTH BAY PILOT PROJECT REPORT
The South Bay Pilot Project represents an innovative
approach to reducing water pollution. Through the cooperative
efforts of federal and state environmental agencies and three
publicly owned treatment works (POTWs), pollution prevention
measures were identified and implemented.1 These measures helped
Palo Alto Regional Water Quality Control Plant, San Jose/Santa
Clara Water Pollution Control Plant, and Sunnyvale Water
Pollution Control Plant comply with strict discharge
requirements.
BACKGROUND
In the late 1980s, high concentrations of heavy metals were
found in the San Francisco Bay, just south of the Dumbarton
Bridge. The high concentrations of these pollutants were due to
a combination of factors, including urban runoff, discharges from
three publicly owned treatment works, and poor dilution from
tidal or freshwater flows to the Bay.
The water quality in this part of the San Francisco Bay was
of such concern that it was included in the Environmental
Protection Agency's (EPA) list of California's impacted waters.
As the State had been delegated the responsibility to determine
how the San Francisco Bay water quality could be improved, the
California Regional Water Quality Control Board - San Francisco
Bay Region (RWQCB) attempted to solve this problem by addressing
the quality of the POTWs1 influent.
ROLES/RESPONSIBILITIES OF PROJECT PARTICIPANTS
Through amended discharge permits, RWQCB required that the
three South Bay POTWs complete two studies: 1) source
identification studies to identify the origin of the pollutants
of primary concern (copper, lead, nickel, zinc, cyanide, and
silver); and 2) waste minimization studies to identify possible
mitigation projects.
In response to these requirements, Palo Alto developed a
pollution prevention program that targeted silver dischargers
(primarily photoprocessors and x-ray labs); San Jose/Santa Clara
1 The EPA defines pollution prevention as "the use of materials,
processes, or practices that reduce or eliminate the creation of pollutants or
wastes at the source. This includes practices that reduce the use of
hazardous materials, energy, water or other resources, and practices that
protect natural resources through conservation or more efficient use."
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targeted industries that discharged copper, zinc, and lead
(primarily radiator shops and auto parts cleaning shops); and
Sunnyvale focused on industries that were sources of nickel,
copper, and lead (electroplaters and metal finishers).
EPA Region 9 joined forces with the RWQCB, anticipating an
opportunity to promote pollution prevention measures. EPA
assisted RWQCB by reviewing the POTWs1 source identification
studies and waste minimization plans. In addition, EPA conducted
pollution prevention training courses and workshops for
inspectors.
SOURCE IDENTIFICATION STUDIES
In their source identification studies, the POTWs found
that:
1. Commercial sources, including unregulated/unpermitted
industries, accounted for a significant percentage of
metal loadings. All POTWs found that photoprocessors
were major sources for silver, while automotive
industries were major sources for lead. In addition,
some of the POTWs found that photoprocessors and
automotive industries were sources for copper and
nickel.
2. Industrial sources accounted for a significant
percentage of the copper, lead, nickel, and silver
coming into the POTWs. Sunnyvale estimated that over
one half of the copper and nickel contributed by
industry came from a handful of large electroplaters
and a metal finishing facility.
3. The water supplied by the Santa Clara Valley Water
District accounted for up to 90% of the zinc found in
the POTWs' influent.
WASTE MINIMIZATION STUDIES
In their waste minimization studies, the POTWs found that:
1. The most likely sources to target for waste
minimization efforts were those that used photographic
processes and automobile repair shops (including
radiator repair shops).
:>. Fifty percent of the cyanide used in electroplating and
metal finishing could be reduced through product
substitution. Fifteen to twenty percent of the
industrial contribution of metals could be reduced
through waste minimization.
3. Proposed zinc levels would not be met by their waste
reduction efforts unless zinc levels in the water
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supply were reduced.
PERMIT REQUIREMENTS
The RWQCB and EPA reviewed the source identification and
waste minimization studies, and the RWQCB modified the POTWs1
discharge permits. The RWQCB then required the POTWs to
implement additional pretreatment and waste minimization measures
which are summarized below:
• require target industries to measure their flows;
regulate auto repair and photoprocessing firms;
increase enforcement and inspection activities;
implement industry specific pollution prevention
programs;
provide public education;
keep the other POTWs updated on progress; and
submit progress reports.
The POTWs took steps to meet the more stringent permit -
requirements through various means. They now:
Measure wastewater flows of over 37% of the industrial
users in their service areas and nearly all of their
targeted industrial users.
Permit, and have written Best Management Practices for,
auto repair facilities and photoprocessors in their
service areas.
Implement rigorous pollution prevention programs for
their targeted industries (Palo Alto - photoprocessors,
San Jose/Santa Clara - auto repair shops, and Sunnyvale
- metal finishers and electroplaters).
Require many of their significant industrial users to
submit waste minimization plans, so that the POTWs can
identify the most feasible pollution prevention options
for their facility.
Conduct workshops in their communities to increase the
public's knowledge of waste generation.
Develop options for reducing pollution.
111
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PROJECT SUCCESSES AND BARRIERS TO POLLUTION PREVENTION
To measure the success of the South Bay Project, EPA
interviewed representatives of metal plating and photoprocessing
businesses in the South Bay area. The metal plating shops had
implemented numerous low technology waste reduction measures such
as using spray rinses and air knives, and returning drag out to
plating baths. Additionally, they implemented a number of water
conservation measures (e.g. use of conductivity controlled flow
restrictors, counter flow rinses, aerated rinses, and allowing
water to flow in the rinse tanks only when needed). The
photoprocessing laboratories now use less silver in their film;
they have stopped using cyanide as a complexing agent.in their
bleaches; and, reportedly, they are saving over one million
gallons of water per year.
Despite their successes, the industry representatives
expressed concern about several barriers that impeded them from
implementing additional pollution prevention measures. They
noted that companies were restricted from making environmentally
beneficial changes, because:
1. smaller companies do not always have the capital
available;
2. management is not always committed;
3. there is a lack of on-site technical assistance; and
4. some regulations limit the pollution prevention options
available to industry.
RESULTS AND RECOMMENDATIONS
As a result of their efforts, the POTWs have made
significant progress toward reducing metal concentrations in
their influent. They have promoted greater public awareness of
pollution prevention opportunities in their service areas and
have successfully assisted local industries in making beneficial
changes. For example, many radiator repair shops have decided to
stop discharging wastes into the sewer systems rather than adding
treatment. The Santa Clara Valley Water District conducted
research to reduce zinc in the water supply and has now found a
successful method. Finally, many companies in the POTWs1 service
areas have reported that pollution prevention measures have led
to significant reductions in pollutant discharges.
Pollution prevention techniques have helped South Bay POTWs
make significant progress towards meeting stringent permit
limits. Although the sensitive waters of the South Bay were the
driving force of the South Bay Pilot Project, the tools developed
here can be used by any POTW. The following recommendations are
based on the successes and problems encountered during the South
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Bay Pilot Project:
1. Water quality standards should be more fully utilized
to provide impetus for pollution prevention
initiatives.
2. All POTWs can benefit from pollution prevention and
should consider implementing programs.
3. POTWs should examine mass-based limits as a way to
minimize water use and to set precise discharge limits.
Although mass-based limits are conducive to water
conservation, there are problems with this approach
(e.g. measuring flow, establishing flows for an
industry, evaluating increased allocations based on
production increases).
4. POTWs and industries should have access to non-
regulatory assistance.
5. To have successful pollution prevention programs,
company management must be willing to commit the
necessary resources.
6. Small businesses should be given economic incentives to
encourage them to implement pollution prevention*
measures.
7. Source reduction and recycling offer the best means of
insuring overall waste reductions. Pollution prevention
efforts must take a cross-media approach so that total
waste generation is minimized.
8. The fact should be emphasized that pollution prevention
measures often offer long-term savings to companies.
The South Bay Pilot Project has affirmed that POTWs can help
reduce impacts to the environment if they implement pollution
prevention programs. Although the impetus for this project was
regulatory, its success demonstrates that cost-effective
technologies and practices that reduce pollutants at the source
are available. The benefits of source reduction include reduced
treatment costs, improved operations and productivity, and better
water quality.
POTWs elsewhere should promote similar pollution prevention
programs in their service areas for a number of reasons. First,
improved influent wastewater quality will enable POTWs to more
easily comply with water quality standards, air emission
requirements, and sludge disposal requirements, and to maintain
compliance with these regulations despite population growth.
Second, reduced wastewater flow and loading can help extend the
useful lives of POTWs. Third, it is less expensive to institute
pollution prevention practices than to install new treatment
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systems. Fourth, treatment plant workers would be exposed to
less hazardous conditions. Finally, and perhaps the most
compelling reason of all, POTWs would be meeting the public's
demand for a cleaner environment.
VI
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SOUTH BAY PILOT PROJECT
TABLE OF CONTENTS
Page
I. Introduction 1
II. Roles/Responsibilities of Project Participants 4
III. Source Identification Studies 7
A. Palo Alto 7
B. San Jose/Santa Clara 10
C. Sunnyvale 13
IV. Waste Minimization Studies 17
A. Palo Alto 17
B. San Jose/Santa Clara 18
C. Sunnyvale 18
V. Permit Requirements 21
A. Palo Alto 22
B. San Jose/Santa Clara 26
C. Sunnyvale 30
D. Santa Clara Valley Water District Progress 33
VI. Project Successes and Barriers 34
VII. Results and Recommendations 37
VIII. List of Acronyms 42
IX. Appendices 43
Appendix A: Water Quality Documents 44
Appendix B: Survey Questionnaire 47
Appendix C: RWQCB's Waste Minimization Program .... 52
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I. INTRODUCTION
In the late 1980s, high concentrations of heavy metals were
found in the San .Francisco Bay, just south of the Dumbarton
Bridge. The high concentrations of these pollutants were due to
a combination of factors, including urban runoff, discharges from
three publicly owned treatment works (POTWs), and poor dilution
from tidal flows or freshwater inflow to the Bay. Two water
quality reports documented the concentrations of the pollutants
of concern (see Appendix A).
The three publicly owned treatment works (POTWs) that
discharge effluent into the South Bay are: the Palo Alto Regional
Water Quality Control Plant, the San Jose/Santa Clara Water
Pollution Control Plant, and the Sunnyvale Water Pollution
Control Plant (see Figure 1). For all three POTWs, copper, lead,
nickel, and zinc were the pollutants of concern. In addition,
chromium in Sunnyvale, and cyanide and silver in San Jose and
Palo Alto were the pollutants of concern.
To address this problem, the California Regional Water
Quality Control Board (RWQCB) amended the discharge permits of
the three POTWs. The permits stipulated that the POTWs conduct
studies to identify the origin of the metals and potential
mitigation projects. Anticipating an opportunity to promote
pollution prevention measures, EPA Region 9 joined forces with
the RWQCB and provided technical assistance.
Definitions of Pollution Prevention Terms
A national policy for pollution prevention was established
in the Pollution Prevention Act of 1990. In the Act, Congress
declared that henceforth, America's first priority should be to
prevent or reduce pollution at the source wherever possible.
Pollution that cannot be prevented should be recycled in an
environmentally safe manner. If prevention or recycling is not
possible, pollution should be treated. Disposal or other release
into the environment should be used only as a last resort.
The Act defines source reduction "as any practice which (1)
reduces the amount of any hazardous substances, pollutant, or
contaminant entering any waste [pollutant] stream or otherwise
released into the environment (including fugitive emissions)
prior to recycling, treatment, and disposal; and (2) reduces the
hazards to public health and the environment associated with the
release of such substances, pollutants, or contaminants. The
term includes equipment or technology modifications, process or
procedure modifications, reformulation or redesign of products,
substitution of raw materials, and improvements in housekeeping,
maintenance, training, or inventory control." Source reduction
does not entail any form of waste management (e.g. recycling and
treatment). The Act excludes from the definition of source
reduction "any practice which alters the physical, chemical, or
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DUMBARTON
BRIDGE
.SANlJOSE/SANTA CLARA
San Francisco Bay
SUNNYVALE
»W"ta»
101
LEGEND
Wastewater Treatment Facility
Outfall
North
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biological characteristics or volume of a hazardous substance,
pollutant, or contaminant through a process or activity which
itself is not integral to and necessary for the production of a
product or the providing of a service."
The EPA defines pollution prevention as "the use of
materials, processes, or practices that reduce or eliminate the
creation of pollutants or wastes at the source. [It] includes
practices that reduce the use of hazardous materials, energy,
water or other resources, and practices that protect natural
resources through conservation or more efficient use."
For the purposes of this report, waste minimization focuses
specifically on reducing the quantity of toxic pollutants
released to waters by major municipal and industrial dischargers.
It emphasizes source reduction, but also includes improved water
and petroleum product use, wastewater treatment and expanded
pretreatment programs. Waste minimization techniques will allow
for the protection of surface and ground water, and include
material recycling and reuse, water and material conservation,
material substitution, product substitution, and process
modifications.
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II. ROLES/RESPONSIBILITIES OF PROJECT PARTICIPANTS
There were a member of agencies that were involved in the
South Bay Pilot Project. The roles and responsibilities of the
various regulatory agencies and POTWs are described in this
section.
A. REGULATORY AGENCIES
Regional Water Quality Control Board (RWQCB)
The Clean Water Act protects beneficial uses of water bodies
by requiring the State and EPA to set water quality standards
based on these beneficial uses. In California, te Regional
Water Quality Control Board (RWQCB) sets these standards in Basin
Plans. Because of the lack of dilution from tidal action or
freshwater inflow to South San Francisco Bay, the Basin Plan
developed for the Bay prohibited discharges south of the
Dumbarton Bridge, and did not set water quality standards.
Exceptions to this prohibition were available where the
dischairger could demonstrate a net environmental benefit and
water quality enhancement resulting from the discharge.
The Palo Alto, San Jose/Santa Clara, and Sunnyvale POTWs
petitioned for an exception from the discharge prohibition, and
submitted a five-year monitoring study to support their petition.
The RWQCB issued a regional order stating that the study did not
support a finding of net environmental benefit and water quality
enhancement. Nevertheless, the RWQCB determined that the POTWs
could continue to discharge into the South Bay as long as they:
a) submitted studies to determine the origin of the potentially
harmful pollutants; b) implemented mitigation projects; c)
developed source pollution minimization programs; and d)
evaluated waste re©v.stion alternatives. After the POTWs complied
with the conditions of the RWQCB order, they had to implement
specific waste minimization projects, as defined in their amended
discharge permits.
Environmental Protection Agency (EPA)
Under the Clean Water Act, EPA is authorized to set site-
specific limits for POTWs. These limits are addressed in NPDES
permits.
In an effort to reduce metal loadings to the Bay, EPA
Region 9 helped RWQCB review the POTWs1 studies of pollutant
origins and possible waste minimization programs.
In addition, EPA assisted the RWQCB in promoting pollution
prevention in the following ways:
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Training. EPA conducted a training course titled "Introduction
to Pollution Prevention for Inspectors." The one-day course
covered significant legislation, and included agency and industry
examples of pollution prevention. Vendors supplied information
about equipment and technologies available. The course had a
multimedia focus and allowed for interaction between inspectors
from numerous regulatory agencies and media programs in the Bay
Area.
Workshops. EPA, in conjunction with the County of Santa Clara,
conducted two workshops on waste reduction techniques for the
metal finishing industry. The first workshop emphasized rinse
process modifications and the second addressed procedures for
reclaiming metals from concentrated solutions.
Coordination. EPA assisted the POTWs when they did research for
their source identification and waste minimization studies. EPA
led meetings that were attended by the three POTWs to ensure that
each POTW was aware of the findings of the others, and did not
duplicate the efforts of any other POTW.
Video. EPA sponsored the production of a video entitled "Rinsing
Process Modifications for Metal Finishers."
B. POTWS
Palo Alto Regional Water Quality Control Plant
The Palo Alto Regional Water Quality Control Plant treats an
average of 23.1 mgd of wastewater from six different communities.
The water supply for the Palo Alto service area comes from Hetch
Hetchy (82% of total), groundwater (10%), and the Santa Clara
Valley Water District (8%). Before the initiation of the South
Bay Pilot Project, Palo Alto regulated 59 industrial sites in
their pretreatment program.
Initially, Palo Alto was required to conduct source
identification and waste minimization studies. These studies
were also required of the two other POTWs that discharged
effluent into the South Bay. When the discharge permits were
amended, Palo Alto was required to make pretreatment program
improvements and implement a pollution prevention program that
targeted silver dischargers (primarily photoprocessors and x-ray
labs).
San Jose/Santa Clara Water Pollution Control Plant
The San Jose/Santa Clara (SJ/SC) Water Pollution Control
Plant treats an average dry weather flow of 119 mgd wastewater
from eight different communities. The water supply for the
service area comes from groundwater (49% of total), surface water
(11%), and the Santa Clara Valley Water District (40%). The
POTW's pretreatment program issued permits for 352 industrial
sites before the initiation of the South Bay Pilot Project.
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Like Palo Alto, SJ/SC had to complete the preliminary source
identification and waste minimization studies. In the amended
NPDES permits, SJ/SC also had to make pretreatment program
improvements and implement pollution prevention programs that
targeted industries that discharged copper, zinc, and lead
(primarily radiator repair shops and auto parts cleaning shops).
Sunnyvale water Pollution Control Plant
The Sunnyvale Water Pollution Control Plant treats an
average of 13.8 mgd of wastewater. The water supply for the
service area comes from three different sources. The
contributions of the sources varies during the year, but the
average contributions are approximately 40% Hetch Hetchy, 15%
groundwater, and 45% from the Santa Clara Valley Water District.
Sunnyvale has a four-group permit system. Before initiation
of the South Bay Pilot Project, Sunnyvale regulated 74 industrial
sites :ln the Main Contributing Industries and Intermediate
Industries groups (both groups containing federal categorical and
non-regulated categorical industries subject to local limits).
They a.'Lso regulated 46 industries in the Small Industry group
(including radiator shops, chemical companies, electronics firms,
laboratories, etc.), and 1,730 A-Z Industry/Commercial
Establishments (including auto shops machine shops,
photoprocessors, printers, cleaners, restaurants, etc.).
Sunnyvale was required to perform source identification and
waste minimization studies and to identify implementation
measures to reduce metals in its effluent. Based upon these
studies;, the amended permit required Sunnyvale to: 1) improve
its pro-treatment program; 2) implement a pilot waste minimization
program focusing on industries that were sources of nickel,
copper, and lead (electroplaters and metal finishers); and 3)
conduct a public education and outreach program for communities
to reduce nickel, copper and lead in residential wastewater.
In addition to conducting source identification and waste
minimisation studies, Sunnyvale was required to improve their
pretreatment program and implement pollution prevention programs
focusing on industries that discharged nickel, copper, and lead
(primarily electroplaters and metal finishers).
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III. SOURCE IDENTIFICATION STUDIES
In response to the RWQCB's order, the South Bay POTWs
conducted studies to determine if all controllable sources of
pollutants had been identified and regulated. These studies were
to address, at a minimum: chromium, copperasilver, lead, nickel,
zinc, and cyanide. These pollutants were chosen because some
effluent values had exceeded Basin Plan limits.
In their studies, the POTWs used the following categories to
classify the origin of pollutants: water supply, regulated
industries, unregulated/unpermitted industries, commercial
facilities, and residential areas. The findings of these studies
are summarized below.
A. Palo Alto Source Study
Palo Alto conducted an industrial user survey for potential
unregulated sources of metals, and then initiated a sampling
program. The sampling was necessary to estimate the amount of
metals coming from the potable water supply, as well as
regulated, unregulated/commercial, and residential sources.
The industrial user survey was conducted using telephone
directories, numerous business directories, records of other
regulatory agencies, water use records, etc. Numerous potential
dischargers were identified. The report indicated that
substantial effort was still needed (site visits or phone calls)
to determine which user actually discharged contaminants of
concern to the sewer. Palo Alto now estimates that there are 375
photoprocessors and 350 auto repair facilities in their service
area.
To estimate the amount of metals coming from the potable
water supply, Palo Alto took several samples. The samples were
necessary to verify the historical data provided by the water
purveyors. The sample data confirmed that the water purveyors do
have accurate data and, therefore, the historical data should be
used to determine the average metals contribution of the water
supply.
Palo Alto sampled ten percent of the regulated facilities to
verify industrial waste contributions as measured by the
industrial pretreatment program. This sampling found lower
concentration and flow rates than previously estimated.
Therefore, the data from the industrial pretreatment program was
considered a conservative estimate of the regulated industries'
metals contribution.
Palo Alto (along with the two other POTWs) estimated
commercial and unregulated industrial concentrations by averaging
the results of trunk sewer sampling of nine different businesses.
These included retail outlets, radiator repair shops,
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TABLE!
AVERAGE SOUTH BAY UNREGULATED
INDUSTRIAL/COMMERCIAL LOADINGS
Contribution
Element (pounds per day)
1. Arsenic 0.03
2. Cadmium 0.49
3. Chromium 0.57
4. Copper 4.61
5. Cyanide 1.41
6. Lead 2.06
7. Mercury 0.
8, Nickel 6.51
9. Selenium 0.
10. Silver 5.2
11. Zinc 20.65
From Table 7-9 of Palo Alto's Metals Source Identification Study.
photoprocessing shops, machine shops, print shops, and a dental
facility. The resulting loadings are shown in Table 1. The
contribution levels shown in Table 1 were calculated by
multiplying concentration data by the estimated flow rate, 6.5
mgd (described above).
Palo Alto also conducted water sampling at five unregulated
industrial/commercial operations to get an idea of how many
pounds of pollutants per day were discharged by various
businesses. The results of this sampling are shown in Table 2.
The results shown in Table 2 were not used in determining the
commercial or unregulated industrial contribution of metals to
the sewer.
Residential concentrations were calculated using trunk sewer
sampling results from all three POTWs. Palo Alto conducted
sampling of two residential areas for seven days. One of these
areas was a high density residential area, and the other was a
neighborhood of single family dwellings. The resulting data from
the sampling efforts of all three POTWs were combined to increase
the data base and the results were averaged. These results are
summarized in Table 3.
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TABLE 2
UNREGULATED INDUSTRIAL/COMMERCIAL OPERATIONS
(PALO ALTO SAMPLE RESULTS)
Industry:
Element :- '' A- •
^!im -: 14<--- ^Wim^7- ..:;.
1. Cadmium y-;;4.;':>;', ;:K. •::••<)•
3. • • '}Chromium:I;;=!;• ;.•:;:• • ••<2.?• -,-.':':,::<2i-^ij;;t::•.<2.••::;:';:- <2:^|: "'*:• <'2.
4. ;:Copperv;t ;:F;;::::;:--:10.::: ;';-i9l:i|:''j l||ll ^^ ' :;:;26,; "f; ^59.-
. 5., :Cjanidev'-l^P^lQ;;:;1.^'•<13^%S::44-:.••,.:'' 478. < 10;'::: \ 1125v
6. -.^Leacl"-'. /:;t-: ';:F312.::.:.;,; ;:."::<^2^^J;.j3'iir: f^LC^<^..'./:::: ;.:34..
:.:7.: •yMercury:;:•.'^A\ ^ '^£s ^^j§(J:^'^^ .•• ,5j|i:;-:-:.^.,.:;Ji^^; 3.-
9..: .•-Seleniiim • ^- <'^4\^<^^!<^^'- ' '<10^r:. ":''<:10;:;l^>
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TABLE3
AVERAGE SOUTH BAY RESIDENTIAL WASTEWATER
CONCENTRATIONS
Element Concentration Qzg/D
l..-;- Arsenic
2. iCadraium <2
3.;,; CbromiUm
4.
..,, ..... ,m-;, 7
7. ^^ercury ::;^
'';-; 5
10. liver 12
iiv •^nc-:; ;;;;9^v-;^ll;||[il
Brora T^le 6^|!of P^ Atto's ^fe
entering the POTW on a percentage basis. Therefore, when the
total source contribution is 50%, only half of the sources of a
pollutant have been accounted for. If the total source
contribution is over 100%, then the estimates of source
contributions were too high. Results reported below detection
limits (the lowest detectable concentration) are reported as
zero. The true values for the undetected metals obviously lie
somewhere between zero and the detection limit.
Figure 2 illustrates that regulated industry represents a
large percentage of the copper, lead, nickel, and silver
loadings. Unregulated industry/commercial facilities are found
to contribute most to the copper, lead, silver, and zinc
loadings. Residential loadings of copper, lead, and zinc are the
highest.
B. San Jose/Santa Clara Source Study
SJ/SC, unlike Palo Alto, did not complete an industrial use
survey for potential unregulated source metals. The POTW
services a much larger and more industrial area, and a
comprehensive survey would have been far more difficult.
Instead, SJ/SC conducted a literature review and determined that
potential commercial contributors of metals were medical and
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g
•u
c
i
1)
u
120
METAL SOURCES TO SOUTH BAY POTWs
PALO ALTO
ReguIated I ndustry j
MetaI Sources
Commerc i a I / UnpermI t. IxTTl Res I dent I a 11 I Water Supp I y
FIGURE 2
dental offices and laboratories, auto repair shops, car and truck
washes, photoprocessors, dry cleaners, laundries, and printing/
publishing facilities.
SJ/SC used Santa Clara County Business Patterns data to
estimate the number of such facilities in their service area.
They assumed that 70% of the County's commercial facilities were
within the service area of the SJ/SC plant, since the plant
serves 70% of the population of the County. The resulting
numbers of commercial facilities are listed in Table 4.
The composition of the water supply was estimated using a
combination of historical data from water purveyors, field
sampling, and the other two POTWs. Data for flow rates were
obtained from the water purveyors.
SJ/SC attempted to verify flow data from self monitoring
reports with data from the water suppliers. They found that the
water company records averaged about 20% higher than flow rates
described in the self monitoring reports. This is probably due
to sanitary and irrigation flow rates. Although many of the
industries do not have flow meters, and some used their permitted
capacity as their actual flow in their self monitoring reports,
SJ/SC decided to use the self monitoring reports instead of the
water company records. These reports seemed to be as close of an
estimate as the water company records, and were much easier to
- 11 -
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TABLE 4
APPROXIMATE NUMBER OF COMMERCIAL GROUPS IN
SJ/SC SERVICE AREA
• /.-;... .Number,,;:p:;V:'-;^ .
Business Type Number* Permitted11 Metals of Concern6
1/Hospitals/Climcs/Labs 164 ; Ag,Cd
-2. Automotive Repair .: :4&^f:-^^ Cu,Pb;Zn
"3; Car/Tmcki"WMes>1;;|v:;;;::,-;:.;::::22 . " &M : ;;;du,Pb,Zn
4. Phbto processors 111 7
'.5l Dry Cleaners 65 0
6. Laundries 36 6 Cu,Cr,Pb,Zn
7, Printing/Publishing 289 4 Ag,O
a Data from U;S, Department ^ Census,
Comity Business Patterro 15^(5i
bl^atafro^
c Data froni^UiS, ^A^ Study,
1989i DraJ^
Prom SJ/SC's Polliitaiit Sources Evaluatiisii
obtain. Therefore, these values were used for calculating the
mass balances.
Like Palo Alto, ten percent of the regulated industries were
sampled for verification of industrial contributions. SJ/SC also
found lower concentration and flow rates than historically found.
They thought this might be due to the lower detection limits
used, or the success of the pretreatment program to affect
reductions. For loading calculations, SJ/SC used the data
available for the 35 facilities involved in the verification
sampling, and the historical data for 90% of the other
industries.
Residential and commercial concentrations were calculated by
averaging the results of sewer sampling by all three POTWs.
SJ/SC conducted sampling of five sites. Two sites were mixed
residential/commercial and three were purely residential. To
calculate commercial contributions, the residential results were
subtracted from the results for the mixed areas. The values
obtained by the averaging of unregulated industrial loadings are
shown in Table 1. The values from the averaging of residential
- 12 -
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340
METAL SOURCES TO SOUTH BAY POTWs
SAN JOSE/SANTA CLARA
f
-
8
|
31
Ag
Zn
Pb Ml
Metal Sources
Regulated I ndustry j:!ggg:| Commerc la I/ Unpermit .[•:-:•:•! Residential I I Water Supply
FIGURE 3
loadings are shown in Table 3.
Loadings of metals from the four categories are shown in
Figure 3. Data in this figure was calculated using values below
the detection limit as equal to the detection limit. Mass
balances for copper, lead, and silver are particularly poor.
SJ/SC concluded that the metals unaccounted for (approximately
55% and 40% for copper and lead respectively) may have come from
batch discharges from industries, radiator repair shops, or auto
repair shops. Silver amounts were estimated to be three times
higher than the actual influent loadings, as can be seen by the
figure.
This data shows that regulated industry is responsible for a
large percentage of the accounted metal loadings. The commercial
sector is responsible for a large percentage of the nickel and
silver loading, and, to a lesser degree, lead.
C. Sunnyvale Source Study
Source water samples were taken to determine water supply
contributions. These results were combined with some of the
results from the other two POTWs and from historic data for Hetch
Hetchy water. Historic data for Santa Clara Valley Water
- 13 -
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District water was not used, because the detection limits used
for this data were too high. Weighted averages of the three
sources were calculated, using the detection limit value rather
than zero if the result was less than the detection limit.
Tc confirm historical data, verification sampling was
conducted at the seven industrial sites which contribute 40% of
the industrial flow to the plant. Separate estimates were made
for process and sanitary loadings. Sunnyvale also took samples
from 13 of the smaller industries (which contribute 20% of the
industrial flow to the plant) to increase the data base. The
results of this sampling indicate that mass loading estimates of
nickel and mercury were much higher in the verification sampling.
But, for most metals of concern, the verification results are not
far from the historical data. Therefore, Sunnyvale used the
verification sampling data to determine the mass and percent
loadings.
Sunnyvale used the data collected and pooled by the three
POTWs to estimate commercial and unpermitted industrial
concentrations. As mentioned before, these concentrations were
calculated by averaging the results of trunk sewer sampling of
nine different areas. These areas included, retail outlets,
radiator repair shops, photoprocessing shops, machine shops,
print shops, and a dental facility. The results are shown in
Table 1.
Sunnyvale also conducted individual commercial samplings at
the req;uest of the RWQCB in order to sample for suspected sources
of metals in Sunnyvale's influent. The commercial establishments
sampled, included a medical/dental complex, an automobile service
station,, four car dealerships, and a drive-through carwash.
Sunnyvale also reviewed historical data for a large radiator
shop.
The results of the medical/dental complex sampling showed
that higher-than-expected levels of chromium and lead were
detected at photoprocessing operations, although local limits
were met. This sample data also verified that this category was
a potential source of silver, although the levels measured were
not excessively high.
The results of the automotive industry samplings indicated
relatively high concentrations of copper, chromium, lead, and
zinc. The radiator repair shop showed levels of lead and copper
in sewer discharges, even though dip tank discharge was
prohibited. The carwash sampling indicated that this was not a
serious source of the metals of concern.
Sunnyvale did not use the individual commercial sampling
results to determine the actual commercial or unpermitted
industrial contributions of metals to the sewer, but used them to
- 14 -
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make recommendations for program changes in their waste
minimization study.
Residential concentrations were calculated using trunk sewer
sampling results from all three POTWs. Sunnyvale conducted
sampling of three solely residential areas. As with Palo Alto,
these areas were chosen to represent different densities, ranging
from apartments to single family homes. The resulting data from
the sampling efforts of all three POTWs were combined to increase
the sample size and were then averaged. These results are
summarized in Table 3.
After concentration values were derived, loadings were
calculated using estimated flow rates. These rates were
estimated using the water use records for industrial, commercial,
and residential zones. The rates were adjusted to account for
water used for irrigation purposes and lowered by 8% to match the
influent flow rate to the plant. The flow rates for the
permitted industries (from the pretreatment program database)
were subtracted from the combined flows for industrial and
commercial categories to derive the flow rate for the commercial
category.
Contributions of metals from the four source categories are
shown in Figure 4. Values below detection limits were assumed-to
0>
TJ
(0
0
-------
equal the detection limit. Sunnyvale achieved a relatively good
mass balance for loading, except for silver which, as SJ/SC
found, has an average influent loading much lower than the sum of
the contributing loads. This may be due to the outliers in the
commercial sampling data.
Figure 4 includes the pollutants that Sunnyvale would have
been discharging in violation of the Basin Plan limits, if those
limits had been in effect at the time. On the Sunnyvale graph,
chromium was inadvertently left out. Estimates accounted for
only 36% of the total chromium loading. This is apparently due
to one very high chromium value measured in the influent. The
largest source of chromium was the water supply, and the next
largest source was industry.
Sunnyvale concluded that the water supply was probably the
primary source of arsenic, cadmium, chromium, mercury, and zinc.
Permitted industries were the primary source of lead, and were
also important sources of nickel and copper, with over half the
loading of nickel and copper coming from a handful of
electroplaters and one metal finisher. Key contributors of lead
were a metal finisher, a local (non-categorical) industry, and
two large government facilities with a large combined flow. The
commercial sector identified as the primary source of nickel and
silver. The residential sector was identified as the primary
source of copper and selenium.
Sunnyvale expressed concern that chromium, copper, mercury,
nickel, and zinc were found in the water supply in levels which
usually exceeded the Basin Plan limits for effluent
concentrations.
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IV. WASTE MINIMIZATION STUDIES
In addition to source identification studies, RWQCB's order
also required that each of the POTWs submit reports identifying
feasible waste minimization measures to reduce or eliminate toxic
loadings. The results of these three reports are summarized
below.
A. Palo Alto Waste Minimization Study
Palo Alto evaluated measures to reduce cyanide, copper,
lead, nickel, silver, and zinc, since these contaminants needed
to be reduced to meet the RWQCB's Basin Plan limits. Palo Alto
calculated the range of influent loading values for these
pollutants by using existing plant removal rates, and rates
calculated using a linear correlation between influent and
effluent metals concentrations (although, only weak correlations
were found). Palo Alto then evaluated whether waste minimization
measures could be successful in meeting these loading values.
The study found that significant reductions in copper, lead,
nickel, and silver from regulated industry and from unregulated/
commercial facilities were required to meet the Basin Plan
limits. To meet the zinc limit, reductions from all categories
were needed. The report also stated, however, that waste
minimization may not ever be enough to reduce the metals to the
Basin Plan limits, because:
1. unaccounted for contributions of chromium, copper, and
lead are almost enough by themselves to reach the Basin
Plan limits, and it is difficult to identify waste
minimization measures for unaccounted for sources; and
2. the amounts of influent metals and plant removal rates
fluctuate, making it difficult to set useful limits.
Some of the unaccounted for metals could have come from spills or
batch discharges from regulated industry, which could be
controlled through the implementation of waste minimization
programs.
Palo Alto conducted interviews at three facilities, a large
photo finisher, an electroplater, and a metal finisher, to
determine the potential for reducing cyanide and metals in
industry. Using the results of these interviews and knowledge of
the local industrial make-up, Palo Alto estimated that 50% of the
cyanide used in electroplating and metal finishing could be
reduced through product substitution. Moreover, 15 to 20 percent
of the industrial contribution of metals could be reduced through
waste minimization.
Palo Alto also conducted interviews with representatives of
three unregulated commercial operations: a photoprocessing shop,
- 17 -
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a commercial printer, and a radiator repair shop. Feasible waste
minimization measures were only identified for the
photoprocessing shop.
Palo Alto listed the following as residential waste
minimization measures: increasing public awareness, providing
alternative disposal methods, and product bans or substitutions.
Palo Alto's review of the Gurnham study "Control of Heavy Metal
Content of Municipal Wastewater Sludge" (1979) led them, to
conclude that product ban or substitution was not warranted at
the time, because typical household products did not appear to be
major contributors of metals. (However, Palo Alto has since
banned the use of copper sulfate for control of root growth in
sewer lines.)
B. San Jose/Santa Clara Waste Minimization study
SJ/SC focused on reducing the levels of copper, lead,
nickel, silver, and zinc in wastewater, to meet Basin Plan
limits,
SJ/SC proposed to address water supply loadings by
supporting, subsidizing, and/or requiring changes in the zinc-
based corrosion inhibitor used by the Santa Clara Valley Water
District (SCVWD). Residential loading was found to be primarily
a concern for copper, lead, silver, and zinc. SJ/SC planned to
conduct public awareness programs and to develop a comprehensive
household waste collection program and a public education
program. If data were available to demonstrate a need, product
bans or enforced reformulations would be considered.
SJ/SC evaluated the current waste minimization efforts of
industries of concern by distributing questionnaires and
conducting eight case studies. Out of 67 responses to the
questionnaires, 40 industries responded that they had conducted
waste minimization studies. The eight case studies demonstrated
that, in general, the most affordable and effective measures had
been implemented.
SJ/SC listed their alternatives for reducing industrial
loading as: lowering discharge limits, improving compliance,
regulating or permitting additional industrial generators of
metals of concern (including auto repair, radiator repair shops,
photoprocessors), promoting waste minimization by providing
technical assistance, and requiring waste minimization audits.
The report stated that the commercial categories with the
greatest impact for metals reduction were photoprocessors and
radiator/auto repair shops.
C. Sunnyvale Waste Minimization Study
In 1989, Sunnyvale was unable to meet Basin Plan limits for
chromium, copper, lead, nickel, and zinc. Sunnyvale determined
- 18 -
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that local waste minimization efforts should focus on these
metals and silver. They concluded that the primary industrial
sources of copper and nickel were electroplaters and metal
finishers. Therefore, waste minimization efforts should focus on
these industries.
In their waste minimization study, Sunnyvale found that the
water supply was the primary source of zinc. Sunnyvale indicated
that it was also a key contributor of nickel. Sunnyvale stated
in their report that they would encourage SCVWD to work on
finding an alternative corrosion inhibitor to reduce the zinc
loading.
Commercial sources were identified as a significant source
of silver, nickel, and lead. Commercial photoprocessors and
printers were suspected to be the primary sources of silver and,
possibly, lead. Further study was recommended to identify the
source of nickel from the commercial sector. The study suggested
that auto repair shops may be good targets, since processes which
generate metals are limited.
Sunnyvale concluded that the residential sector was a
significant source of copper, silver, and lead. Results of
sampling at the tap indicated that the copper and lead primarily
came from residential plumbing. Silver could come from household
products and home photoprocessing operations.
Sunnyvale estimated that, since the pretreatment program had
already significantly reduced metals loading, additional
decreases as a result of a waste minimization program would
probably range from 10 to 15 percent for specific metals (copper,
lead, nickel, and silver). They expressed concern that this
amount may be masked by the variability of the influent
wastewater. Another concern was that the nonlinear relationship
between metals in the influent and the effluent may result in the
reduction of metals leaving the plant in sludge, and not in
wastewater.
Survey questionnaires (see Appendix B) were developed and
sent to industries to determine what existing waste minimization
measures were being employed by industry, and to identify
industries to interview. One of the two surveys used was sent to
all permitted industrial sites and the other was sent to the
smaller unpermitted industrial sites. With an 82% response rate,
the results indicated that a fair number of these industrial
sites have implemented some type of waste minimization measures.
The majority responded that these measures were implemented to
meet pretreatment limits or to reduce hazardous wastes hauled
off-site.
Sunnyvale conducted interviews with representatives from
seven facilities. The intent of the interviews was to gain more
insight into existing waste minimization techniques employed by
- 19 -
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industry. Most of these facilities had conducted formal waste
minimization audits. They all had instituted worker education
programs in waste minimization practices and they declared that
these programs were essential to the success of their programs.
The study suggested a waste minimization program for
Sunnyvale which would include educational and regulatory
components. The educational component "would include developing
and distributing educational materials, compiling reference lists
of information to make available to industry, arid increasing
efforts on the part of the pretreatment staff. This staff effort
would include presenting talks, assisting with household
collection days, and coordinating more closely with the city's
hazardous materials programs on routine inspections, spills, etc.
Further, the study suggested that the regulatory aspect of
the program include the following: 1) requiring more accurate
metering of process streams; 2) enforcing mandatory waste
minimization measures for industrial dischargers who fail to
comply with discharge limits; and 3) increasing inspections and
monitoring of automotive repair shops and photoprocessors for
compliance with existing requirements. The study also
recommended a modification to the sewer ordinance so that the
POTW can require preparation and implementation of waste
minimization plans. The study suggested that this authority be
used for industries that are out of compliance with their
pretreatment limits.
- 20 -
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V. PERMIT REQUIREMENTS
After the RWQCB and EPA reviewed the POTWs' source
identification and waste minimization studies, the permits were
modified to require each POTW to implement additional
pretreatment and waste minimization measures. These requirements
are summarized in Table 5. The permit language for each of the
POTWs was very similar.
TABLES :§!§§
'PERMIT AMHS^^ SOURCE CONTROLS
A. Pretreatment Program Improvements:
1 . ; Implement system to rexjuire permitted firms to accurately
measure their pto<^ss-was;te;;ilows to t^e seps|!
2. Regulat^ auto repair and pi^
3. Implement more frequent inspections and more aggressive
enforcement actions^
fi. Pilot \^te iriimizatibn :Prpgrarn:
1 . Target efforts toward the following businesses:
a. Palo Alto Hphoto-prp^sors, x-ray la^s; and other
important silver -dischargers;-^" -;%-'/^-::;:-:- ; si ;
b. Sunnyvale ^ electrpjplat^ finishers, and
other pbtehti|lly im^rtant sources of M^ ^; and PB;
c. Sah Jose - radiator repair shops, auto parts cleaning
shops, and other impc^
2. Implement a public edjyication erlfort;
3^ Develop a set of b^st management ; practices and Avaste
mihimiz^On altern^ assistancei
4. Require industries to submit waste^mininii^^
5, Ci
-------
of "targeted industries" accurately measure their process flow
rates to the sewer.
After reviewing the source identification and waste
minimization studies, RWQCB and EPA concluded .that auto repair
shops (including radiator repair shops) and photoprocessing shops
were potentially significant sources of metals. The permits,
therefore, were amended to require the POTWs to regulate these
facilities, increase the number of inspections, and take more
aggressive enforcement actions.
The permits also require the development and implementation
of pilot waste minimization programs. Each POTW must target a
different industry and dischargers of specific metals, as
described below. These programs need to include the development
of best management practices (BMPs) and waste minimization
alternatives for each industry. Additionally, the programs must
require, that some facilities develop and implement waste
minimization plans. The POTWs are also required to provide
technical advice to industries, and direct public education
efforts; toward reducing the disposal of metals into the sewers.
In addition, the POTWs are required to coordinate their
efforts; with each other and, after completion of the pilot
programs, must expand their programs to address other categories
of industry. Lastly, the POTWs are required to submit progress
reports to the RWQCB. Their progress, and that of the Santa
Clara Valley Water District, is discussed below.
A. Palo Alto Permit
Palo Alto has developed a phased approach to reduce the
metals loading to the treatment plant. Phase I includes the
activities required by their NPDES permit: developing base
industrial waste program enhancements, a photoprocessing control
plan, and an automotive repair control plan. Phase II through IV
expands; these activities in anticipation of receiving more
stringent metals limits and includes: developing BMPs for
additional commercial sectors, developing recommendations and
restrictions for the use of chemicals and products, requiring
additional industries to develop waste minimization plans, and
developing mass-based local limits. A schedule for Phases I and
II is shown in Table 6.
Base Industrial Waste Program Enhancements
Palo Alto has adopted a Waste Minimization Resolution to
notify dischargers of their commitment to source reduction. As
with each POTW program, Palo Alto has required flow monitoring of
all "targeted industries" (in this case, the six largest silver
dischargers), and now monitors 37% of their permitted facilities.
Palo Alto recognizes the need for accurate meters to control and
track ;metal loadings, and will make installation of meters a
- 22 -
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TABLE 6
PALO ALTO REGIONAL WATER QUALITY CONTROL PLANT
SCHEDULE OF PHASE I AND PHASE II
Task
Approximate Completion Date
PHASE I
A. GENERAL
A.1 Adopt waste minimization resolution
B. BASE INDUSTRIAL WASTE PROGRAM ENHANCEMENTS
B.I a Require flow monitoring of targeted industries
B.1b Require flow monitoring at permitted industries
B.lc Row monitoring inspection and verification
B.2a Increase industrial self-monitoring to monthly
B.2b Increase industrial self-monitoring frequency
B.3 Increase documented inspections from 1 to 2 per year
B.4 Adopt & implement administrative penalty procedures
B.5 Decrease local limit for zinc
B.6 Establish technically-based local limit for Pb, Zn, Cu, & Ni
B.7 Adopt mass-based discharge fees for metals
B.8a Adopt ordinance requiring WM studies
B.8b Develop silver pilot prioritization scheme
B.8c Require WM studies w/ enforcement orders or permits
B.8d Establish consultant contract to review studies
B.8e Review WM studies from targeted silver sources
B.8f Review WM studies from Tier I industries
B.9a Establish detailed document tracking system
B.9b Establish computerized data management system
C. PHOTOPROCESSING CONTROL PLAN
C.I a Initial source identification
C.lb Conduct latter survey
C.lc Establish technically-based local limit for silver
C.ld Develop draft ordinance
C.le Complete workshops on draft ordinance
C.lf Adopt ordinance by all jurisdictions in service area
C.1g Send informational compliance packets
C.lh Conduct informational workshops on ordinance
C.li Receive hauling/treatment compliance plans
C.lj Review plans for businesses choosing treatment
C.Ik Issue short form permits
C.1I Evaluate & enter self-monitoring data
C.lm Modify appropriate industrial permits
C.ln Inspect photoprocessing facilities
C.lo Issue warning letters and enforcement orders
C.lp Review annual reports of those hauling waste
C.lq Prepare quarterly noncompliance reports
09/89
12/90
02/91
08/91
09/89
02/90
01/91
01/90
09/90
06/92
07/90
09/89
02/90
06/90
09/90
10/91
08/91
07/91
09/91
04/90
05/90
09/90
05/90
08/90
10/90
12/90
03/91
04/91
06/91
06/91
07/91
07/91
09/91
09/91
02/92
09/91
From Table 4-1 of Palo Alto's Progress Report
- 23 -
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TABLE 6 (continued)
Task
C.2a Public education for photoprocessors
C.2b Technical assistance for photoprocessors
C.2c Support of A.B. 646 Legislation
C.2d Coordinate w/State and County programs
C.2e Decide .on city-sponsored hauling programs
C.2f Implement hauling program or other assistance
D. AUTOMOTIVE REPAIR CONTROL PLAN
D.I Condjct Inspections at sample ARFs
D.2 Dove'op inventory and facilities mailing list •
D.3 Deve op informational request/permit application form
D.4 Deve op initial draft BMPs
D.5 Form ARF subcommittee of Metals Advisory Group
D.6 Develop model permit for discharging facilities
D.7 Race ve BMPs from San Jose and SCVWD
0.8 Finalize BMPs
D.9 Develop draft ordinance'
D.10 Adoot ordinance for all jurisdictions
D.1 1 Send informational compliance packets
D.I 2 Conduct informational workshops on ordinance
D.I 3 Issus permits for discharging facilities
D.I 4 Conduct inspections
D.15 Commence enforcement actions
E. OTHER ENHANCEMENT ACTIVITIES
E.1 Coordinate program w/ other 2 South Bay dischargers
E.2a Submit progress report by 1 2/1 /90
E.2b Submit status report by 8/1/91
PHASE II
F. ENHANCEMENT OF INDUSTRIAL SOURCE REDUCTION
G. ENHANCEMENT OF COMMERCIAL SOURCE REDUCTION
G.I Implement reduction program for laboratories
G. 1 a Estnblish laboratory subcommittee of MAG
G.1b Develop BMPs for laboratories
H. IMPLEMENTATION OF RESIDENTIAL SOURCE REDUCTION
H.I Identify residential product groups of concern
H.2 Implement reduction program for copper
H.2a Identify copper sources and pathways
H.2b Invustigate major copper sources
H.2c Commence copper reduction measures
H.3 Investigate impacts of drain-clearing chemicals
H.3a Conduct bench-scale tasting
H.4 Support control programs for water treatment chemicals
H.5 Eva uate additional products and control measures
Approximate Completion Date
09/91
12/91
07/91
Ongoing
12/90
06/91
01/91
04/91
04/91
03/91
03/91
05/91
06/91
08/91
07/91
11/91
12/91
02/92
04/92
08/92
08/92
Ongoing
12/90
08/91
01/91
01/91
07/91
01/91
02/91
05/91
02/91
08/90
Ongoing
- 24 -
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requirement for all major dischargers through the permit renewal
process.
As required by their permit amendments, Palo Alto has
increased industrial self monitoring, increased documented
inspections, and implemented new administralirve enforcement
procedures. They have decreased the local discharge limit for
zinc to the range of the other South Bay dischargers, from 5 mg/1
to 2 mg/1. Silver limits have also been reduced, as discussed
below. Palo Alto plans to establish technically-based local
limits for metals after water quality-based limits are imposed on
the POTW.
Palo Alto has directed its public education efforts toward
household waste reduction. Specifically, Palo Alto has developed
brochures targeting home photoprocessors. Palo Alto now operates
a household hazardous waste collection facility on a quarterly
basis, and is looking into the possibility of allowing small
commercial facilities to use this service. Palo Alto also
operates a drop-off facility for household silver-bearing wastes.
They are also investigating alternatives to usage of copper
sulfate to inhibit root growth in residential sewers.
As required by the permit, Palo Alto solicited waste
minimization studies from their targeted industries (six
facilities which discharge 97% of the industrial loading of
silver). Palo Alto will be requiring all "Tier 1" facilities
(facilities which contribute 80% of the loading of six other
metals) to submit waste minimization plans in their renewed
permits. The industrial waste program staff, with the assistance
of a consultant, will review these studies and meet with the
industries to agree upon an implementation plan.
In addition to required measures, Palo Alto revised sewer
rate charges in July 1990 to include a discharge fee for metals
as an incentive for waste reduction. This fee is $10,000 for
1,000 pounds of toxins (sum of Cr, Cu, CN, Pb, Ni, Ag, and Zn).
Photoprocessing Control Plan
In addition to their efforts with the major silver
discharging industries, Palo Alto has launched a major effort
targeting commercial dischargers of silver. These dischargers
include those who use photographic, photostat, or x-ray processes
(e.g. photoprocessors, research labs, printers, dentists, and
hospitals). The program began with the development of a survey
which was sent to 650 potential silver dischargers. Seventy
percent of those contacted returned the forms, and 53% of those
responding indicated that silver-bearing chemistries were being
used.
Palo Alto then developed a technically-based local limit of
0.25 mg/1 of silver. They used the Basin Plan limit of 2.3 Mg/1
- 25 -
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as a limit for the POTW. Palo Alto wrote a draft ordinance to
set the limit for silver and formed a Metals Advisory Workgroup.
Palo Alto also held five workshops for businesses to help
carryout the new limits. After receiving comments, Palo Alto
adopted a final ordinance that defined allowable silver levels.
The local silver limits adopted are 0.25 mg/1 for non-
photoprocessing dischargers, 0.5 mg/1 for photoprocessors, and
1.0 mg/1 for any photoprocessors that have waterless systems, or
water reuse systems. This approaches a mass-based limit which
provides businesses with more incentive to reduce waste.
Palo Alto is providing, and will continue to provide,
assistance to the regulated businesses. This will include
additional workshops, information packages, press releases, and
newsletters. Technical assistance to individual facilities will
be provided upon request, with the understanding that only
suggestions will be made and that the ultimate responsibility for
compliance lies with the facility.
The program also includes standard pretreatment program
components including: permitting, inspections, annual report
submittals, and enforcement actions.
Auto Repair Control Program
Palo Alto has also developed a program targeting vehicle
service facilities. The program includes education of facility
staff, recognition of compliant facilities, and new requirements
mandated in a recent ordinance. Palo Alto worked closely with
San Jose and Santa Clara County to develop BMPs that included
tips on cleaning up spills without water, preventing leaks, and
eliminating discharges to the sewer and stormwater drains. The
BMPs included a listing of the most preferred ways to store and
dispose of the various liquid and solid wastes generated at
automotive-related industries (for example, gear oil should be
segregated, stored in a drum, and disposed of at an oil
recycler).
B. Sa:n Jose/Santa Clara Permit
SJ/SC's permit requirements are virtually identical to Palo
Alto's, except that the pilot waste minimization program is
targeted toward radiator repair shops, auto parts cleaning shops,
and any other groups identified as important target sources of
copper, zinc, and lead. The status of their activities is
summarized in Table 7, and is discussed below.
SJ/SC has made progress toward having industries monitor
their own process flows. Forty-three percent of their permitted
industrial wastewater dischargers monitor their flow. Like Palo
Alto, they are surpassing permit requirements by requiring all
260 of their major dischargers to install flow meters as a
condition of permit renewal. As part of the industrial permit
- 26 -
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TABLE 7
SAN JOSE/SANTA CLARA WATER POLLUTION CONTROL PLANT
STATUS OF ACTIVITIES
RWQCB PERMIT
PROVISION NUMBER
WASTE MINIMIZATION TASK
PRETREATMENT PROGRAM IMPROVEMENTS
A.1. Implement Flow
Measurement For
Permitted Industries
A.2. Regulate Radiator Repair
and Auto Parts Cleaning
by August 1, 1991
A.3. Implement More Frequent
Inspections and More Aggressive
Enforcement
o Install and Maintain Flow
Measurement Equipment
o Inspect and Approve Installations
o Verify Data by Comparison
with Water Use Data
o Pass Waste Minimization Resolutions
o Establish Threshold Levels to Determine
Which Shops to Regulate
o Develop and Implement New Sewer
Ordinances
o Increase Sampling Frequency
o Increase Inspection Frequency
o Implement More Aggressive Enforcement
o Involve City Attorney More Aggressively
o Train WPC Inspectors to Collect Evidence
o Use Toxicity Detection Unit
o Document Success of Compliance
PILQT WASTE MINIMIZATION PROGRAM
B. 1 . Target Cu, Zn, Pb
B.2. Public Education Effort
B.3. Pilot Waste Minimization Program
for Auto Parts Cleaning and
Radiator Repair
B.4. Require Waste Minimization
Plans from Significant Violators
or Large Dischargers
o Form Task Force
o Distribute Waste Minimization Information to
Residential/Commercial Community
o Conduct Industry Workshops to Distribute
Waste Minimization Information
Waste Minimization for Radiator Repair
o Identify Facilities
o Establish Waste Minimization Alternatives
o Establish Permitting Requirements
o Provide Technical Assistance to Industries
o Implement New Regulations
Waste Minimization for Auto Parts Cleanina
o Identify Facilities
o Conduct Representative Site Visits
o Establish Waste Minimization Alternatives
o Provide Technical Assistance to Industries
o Implement New Regulations
o Identify Significant Violators
o Identify Major Metals Dischargers
o Prepare Sample Waste Minimization Plans
From Table 1 of SJ/SC's Status Report
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TABLE 7 (continued)
RWQCB PERMIT
PROVISION NUMBER
WASTE MINIMIZATION TASK
B.4. (continued)
o Prepare "Best-Management Practices"
Guidelines
o Revise Sewer Use Ordinance
o Conduct Workshops in Waste
Management Plans
o Conduct Follow Up Inspections
B.5. Coordinate With Other Two
South Bay Dischargers
o Meet Monthly with Representatives from
Palo Alto and Sunnyvale
PROGRESS/STATUS REPORTS
C.1. Submit Progress Report on
December 1, 1990 and Status
Report on August 1, 1991.
o Prepare Monthly Status Reports to City
o Prepare Progress Report to RWQCB
o Prepare Status Report to RWQCB
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requirements, SJ/SC has ordered approximately 70 industries to
complete waste minimization plans. Also, SJ/SC has developed a
computer database management program that catalogs industrial
user monitoring data and compliance history information.
SJ/SC is required to regulate auto repair and
photoprocessing facilities. They have developed an auto repair
program as part of their pilot waste minimization program and are
permitting photoprocessing facilities. SJ/SC anticipates they
will use the modified threshold limits and waste minimization
alternatives developed by Palo Alto. In addition, they have
increased inspection and enforcement activities which now include
evening and weekend inspections. SJ/SC has also increased their
budget to pay commercial laboratory and consultant services, and
to fund a new inspection staff (which has increased from 9 in
1989, to 19 in 1992) and additional monitoring equipment. As
part of their source control program, SJ/SC has increased the
number of industries under permit~or regulation from 360 in 1989,
to 1420 in 1991.
The pilot waste minimization program for SJ/SC includes a
public education effort. Their program will include direct
mailings to residences, pamphlets included in utility bills,
workshops for the residential and commercial sectors, billboard
advertisements, and public service announcements on radio and
television. Five workshops have already been provided to
industries. These courses include workshops for plating,
electronics, and printed circuit board industries, as well as
workshops for small quantity generators and industries that need
to submit waste minimization plans.
The pilot program for auto repair shops is directed toward
two categories of shops that are considered to be the major
sources of metals: radiator repair and auto parts cleaning shops.
SJ/SC reviewed trade publications, and contacted manufacturers
and industry sources to learn what options were available for
reducing metals discharge. Two options were identified: either
zero discharge to the sewer, or increased treatment at the
facilities to meet discharge limits.
Twenty-seven radiator repair shops were identified. Eight
of these were contacted to learn what means of information
dissemination would work best. SJ/SC then mailed out a
questionnaire and a letter describing the program. The letter
notified the facilities of their options, gave them a timetable
for compliance, and invited them to attend a workshop. Forty
people, including representatives from 13 of the 27 shops,
attended the workshop. All of the radiator repair shops are now
regulated.
SJ/SC has identified 1,150 potential auto parts cleaning
facilities in their service area. In order to determine how many
are actually contributing metals to the POTW, SJ/SC developed a
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questionnaire which was sent to all of the facilities. SJ/sc has
begun developing discharge options for the affected industries,
and will acquaint them with the requirements in a workshop.
SJ/SC has performed other tasks related to waste reduction
that go beyond their NPDES permit requirements. These tasks
include the development of a training manual for new inspectors
on the history of the waste minimization program, the program
goals, and implementation of the program.
C. Sunnyvale Permit
Sunnyvale has program requirements similar to those of Palo
Alto and SJ/SC. An outline of Sunnyvale's current efforts and
their future plans is included in Table 8.
Sunnyvale's status report documented compliance with the
flow measurement requirement. The report stated that all
permitted facilities have been required to verify their flow
records since 1981. In addition, 49% of industrial users have
been required to accurately measure process-waste flow to the
sanitary sewer. If users do not measure process-waste flow, they
must document the amount of their water usage, and list the
estimated or measured sanitary and irrigated water usage.
.'Sunnyvale's commercial users have had to submit a permit
application form. These records provide the City with good
information on which of these facilities to target. Like Palo
Alto and SJ/SC, Sunnyvale is required to regulate the
photoprocessors and auto repair facilities. Sunnyvale
incorporated the information and procedures that they deem
appropriate into a regulatory program.
Sunnyvale's inspection and enforcement activities have
helped produce a 90% compliance rate by their industrial users.
Enforcement has included a $231,800 fine in civil penalties of a
local company for dumping hazardous waste into the sewer.
Sunnyvale's program improvements include an update of their
database, and a change in laboratory procedures so that the
detection limits for the industrial sample analyses can be
lowered. Sunnyvale's active pretreatment program earned them the
1990 EPA National Pretreatment Award.
The pilot waste minimization program includes public
education efforts. Letters summarizing the changes to the
pretreatment program have been sent to local industry groups.
The pretreatment staff has initiated a publicity campaign to
inform industry groups about seminars and workshops on waste
minimization. The staff has also made presentations at local
schools and community events, established an environmental awards
program, provided technical assistance, and worked with
representatives of other cities and Santa Clara County to
establish a reference library.
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TABLE 8
CITY OF SUNNYVALE WPCP PILOT WASTE MINIMIZATION PROGRAM
TASK DESCRIPTION
PRODUCT —*•
COMPLETION
DATE
TASK 1: IMPROVED PROCESS FLOW MEASUREMENTS (REQUIRES 0.8 FULL-TIME EMPLOYEES. FTE)
1 . 1 Assessment of Existing Flow Monitoring
Devices
1 .2 Requirement for Additional Flow Measurement
Devices
SOP documenting
assessment protocols
flow monitoring
assessment report
documentation of flow
monitoring
1/91
8/91
TASK 2: REGULATION OF AUTO REPAIR AND PHOTO PROCESSING FIRMS (REQUIRES 1.3 FTE)
2.1 New Permitted Industries Auto Repair
2.2 New Permitted Industries Photo Processing
2.3 Radiator Repair Shop Monitoring
documentation of
categorization, new
permits, updated
inspection forms
sampling records
categorization,
characterization,
waste min, NPS focus
by 7/91
inspection &
monitoring started
7/91
8/91
TASK 3: INSPECTION & ENFORCEMENT PROGRAM (REQUIRES 1.9 FTE»
records in IU files
8/91
TASK 4: ADMINISTRATIVE. LABORATORY. AND FIELD SAMPLING ACTIVITIES (REQUIRES 0.5 FTE)
database updates
modified laboratory
SOPs
mass estimates
water audit verification
summary reports
1/92
12/90
ongoing
3/91
From Table 3 of Sunnyvale's Workplan for Implementation of
Pretreatment and Pilot Waste Minimization Programs
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TABLE 8 (continued)
TASK DESCRIPTION „
PRODUCT
COMPLETION
DAT*
TASK 5: PUBLIC EDUCATION EFFORT FOR REDUCING Ni. Cu. & Pb DISCHARGES (REQUIRES 0.5 FTE)
5.1 Outreach Program for the Communities
5.2 Identification & Education for Small Quantity
Generators
5.3 Seminars and Workshops on Waste
Minimization
letter summarizing
program for local
industry groups
develop library of
resources
12/90
3/91
ongoing
TASK 6: TECHNICAL ASSISTANCE FOR TARGETED INDUSTRIES (REQUIRES 0.6 FTE)
6.1 Develop List of Firms in the Targeted
Categories
6.2 Technical Assistance for Targeted Industries
6.3 Waste Minimization Plans for Targeted
Industries
list of firms
technical
information/library of
resources
waste minimization
plans
TASK 7: ADDITIONAL STAFFING REQUIREMENTS
inspections
field
clerical
lab
8/90
3/91
3 complete by 8/91
4/91
12/90
11/90
12/90
TASK 8: COORDINATION OF FURTHER PROGRAM DEVELOPMENT WITH OTHER SOUTH BAY POTWS
meetings with other
dischargers
quarterly
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Program coordination has included participation in the Bay
Area Hazardous Waste Reduction Committee, the South Bay
Workgroup, the Santa Clara County Tanner Technical Advisory
Committee, and the Hazardous Waste Enforcement Group. The waste
minimization efforts have been coordinated with the Nonpoint
Source Project.
D. Santa Clara Valley Water District Progress
The Santa Clara Valley Water District (SCVWD) supplied a
portion of the water to all three POTWs. They used zinc
orthophosphate as a corrosion inhibitor; thus, a large percentage
of the zinc for all of the POTWs came from the water supply.
The SCVWD played a significant role in minimizing metals
discharge into the South Bay. They researched ways to reduce the
amount of zinc that they added to the water supply.
Historically, SCVWD used zinc orthophosphate as a corrosion
inhibitor to ensure that metals, such as copper and lead, were
not leached from pipelines in quantities harmful to human health
and the environment. Zinc has been used because it is not
harmful to human health in the dosages used. However, the zinc
levels entering the Bay have been potentially dangerous to
aquatic life.
SCVWD evaluated several alternatives to zinc orthophosphate.
One common method of corrosion inhibition that SCVWD considered
was increasing the pH of the water. However, SCVWD found that
elevated pH levels increased the formation of trihalomethanes.
They also tried, and later switched to, a zinc orthophosphate
product with a zinc to phosphate ratio of 1:2 instead of the 1:1
ratio of the previous product. Because of this change, zinc
concentrations in the SCVWD water supply have dropped from 0.8
mg/1 to 0.4 mg/1.
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VI. PROJECT SUCCESSES AMD BARRIERS TO POLLUTION PREVENTION
To measure the success of the South Bay Project, EPA
interviewed several industry representatives in the South Bay
Area. They discussed pollution prevention achievements and
barriers that industries experienced when trying to reduce
pollutant discharge. The successes of metal plating shops and a
photoprocessing laboratory are described below. Several barriers
common to a variety of industries are also presented.
A. SUCCESSES
The; results of the interviews demonstrated the importance of
conduct Jung a waste reduction assessment, maintaining management
commitment, and training employees.
Metal Plating
EPA interviewed employees at three metal plating shops.
These enployees indicated that they had implemented a variety of
source reduction measures such as: reduction in chemical use and
chemical substitution, and water conservation.
Plating chemical usage was reduced by allowing parts to drip
longer over plating baths, utilizing spray rinses, using air
knives over the plating baths, returning drag out to plating
baths, and reducing the amount of treatment chemicals used.
Also, chemical use was minimized by increasing the life span of
plating baths (by optimizing the addition of process chemicals),
and by installing in-tank filter systems. In a large shop,
electrolytic recovery was used to reclaim silver (although
reverse osmosis had been considered for closed-loop recycling of
silver). The shops made chemical substitutions for plating
solutions that contained cyanides, and for chlorinated cleaning
solvents.
Water conservation efforts included the use of conductivity
controlled flow restrictors to minimize the flow of rinse water
while still maintaining product quality, and installing counter
flow rinses. Also, by prolonging dripping and spraying over the
plating baths, and by using aerated rinses, the shops were able
to increase the efficiency of the rinsing process and therefore
reduce water usage. One of the surveyed shops estimated that
they were able to cut water usage by a factor of ten.
The plating shops also reduced the amount of sludge they
generated. They did this by reducing chemical and water usage,
and sometimes by dewatering the sludge. Although the companies
consider sludge dewatering as a type of waste minimization, it
does not fit into the definition used in this report (it is not
source reduction or recycling). Sludge dewatering does not
result in a reduction in the amount of toxic material wasted,
because the mass of metals remains the same (only the overall
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volume of sludge decreases). Therefore, it is a form of
treatment. However, the increased concentration of valuable
metals in the sludge makes it more attractive to companies who
purchase sludges for metal reclamation. Therefore, though sludge
dewatering is considered a type of treatment, it can lead to
recycling and can help eliminate land disposal practices.
Photoprocessing Laboratory
EPA also conducted an interview at a photoprocessing
laboratory. The laboratory has saved approximately one million
gallons of water per year by recycling wash water. And, because
they recycle the heated wash water, they now reclaim additional
silver (through ion exchange) and conserve energy, because less
water is heated. Silver is also reclaimed electrolytically from
the fix solutions.
Source reduction efforts include training employees to
closely monitor process baths to optimize chemical usage. For
further silver discharge reductions, film manufacturers must
reduce silver content in film and paper. According to a Kodak
lab manager, Kodak has adopted several source reduction
technologies in their manufacturing processes. They have reduced
the amount of silver in their film and are currently researching
ways to further reduce the use of silver. In a new process
(RA4), less silver is put in the paper and developing agents are
added to reduce the need for processing chemicals. They have
also substituted EDTA for cyanide as a complexing agent in the
bleaches, thereby reducing the toxicity of the waste.
B. BARRIERS
Industry representatives mentioned several barriers to
reducing pollutant discharge. They noted the following
restrictions.
Economics
The size of the company also limits the capital available
for recovery equipment. Smaller companies may not be able to
afford the equipment necessary for processes such as reverse
osmosis, ion exchange, or electrolytic recovery.
Management Commitment
Industry representatives noted that a lack of commitment
from management represents a significant barrier to pollution
prevention. Management must be willing to commit the time and
resources necessary to improve process control, prevent waste
generation, and avoid production problems while developing a new
program. .Commitment can be encouraged through publicizing
successes and through technology transfer. Management will also
be more inclined to implement waste minimization measures if they
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believe that it will be economically beneficial. If the true
costs of waste handling (e.g. treatment, disposal, liability,
insurance) are emphasized, managers will see the advantages of
source reduction and recycling.
Lack of On-Site Technical Assistance
Sources of technical assistance for industries include
industry trade associations, consultants, regulatory agencies,
and, in some states, nonregulatory assistance programs. Industry
trade associations are beginning to become more involved in
helping their members reduce the generation of their waste. In
California, technical information is available from the
Alternative Technology Division of the Department of Toxic
Substances Control, and increasingly from local agencies such as
the POTWs. However, unlike other states, there is no
nonregulatory technical assistance program in California that
provides on-site assistance to industries that cannot afford
consulting fees. Without this assistance, smaller companies may
not always be able to properly identify and implement beneficial
waste minimization measures.
Regulatory Barriers
Regulations, that require facilities to pay fees to receive
permits for on-site treatment, discourage businesses from
treating wastes and promote disposal or transportation of wastes
off-site. This has happened in California with the Permit-by-
Rule regulations. These regulations require industries to pay
administrative costs for P.E. certification and remedial action
plans. In addition, they must pay a set fee of $1000 to do
treatment on-site. While this cost may be trivial to larger
facilities, smaller sites are now more inclined to haul waste
off-site rather than pay the permit fees.
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VII. RESULTS AND RECOMMENDATIONS
The goal of the South Bay Pilot Project was to encourage the
use of pollution prevention to help meet more stringent permit
limits. The RWQCB revised the permits for the South Bay POTWs
and required them to submit source identification and waste
minimization studies. RWQCB also required the POTWs to improve
their pretreatment programs and to develop and implement waste
minimization programs.
Source identification studies showed significant
contributions of metals from: the water supply, residential
sources, commercial sources, and industrial sources. The water
supply was a significant source of zinc (which is an ingredient
of the corrosion inhibitor). Residential wastewater was a
substantial contributor of copper and lead. And commercial
dischargers were significant sources of silver (mostly from
facilities with photographic processes), copper, and nickel.
Finally, industries accounted for significant portions of copper,
lead, nickel, and silver.
The POTWs1 reports all concluded that it is cost effective
to implement waste minimization programs. One POTW estimated
that 50% of the cyanide used by metal finishing industries could
be reduced through product substitution, and 15 to 20 percent of
the industrial contribution of metals could be reduced through a
variety of waste minimization measures. All three POTWs
identified commercial facilities using photographic processes and
auto repair shops as the most likely commercial sources to target
for initial efforts.
Waste minimization measures were identified and are being
implemented by the water supplier and the POTWs. One water
supplier, SCVWD, has evaluated alternative corrosion inhibitors
and has chosen a new one that reduces zinc concentrations by 50%.
Current efforts underway include educational activities to
reduce residential contributions. At least one POTW is
evaluating the option of product bans to reduce metal loadings to
the plant. There are workshops and new regulatory programs for
commercial and industrial dischargers (e.g. photoprocessing
facilities and auto repair shops) that have not been regulated in
the past. And regulated industries are being required to develop
and implement waste minimization plans.
The goal of the waste minimization programs is to improve
the quality of Bay water. In evaluating progress towards
achieving this goal, we must ensure that pollution prevention
measures are truly responsible for the reductions. Although any
reduction in metals discharge to the Bay will be beneficial,
measures which are not truly pollution prevention measures may
achieve this reduction by transferring pollutants from the sewers
to the air or landfills. It is important to be aware of this and
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to ensure that other current education programs, such as
hazardous waste programs and underground injection programs,
encourage source reduction and not just transfer pollution to
other m«dia.
Tho successes of the POTW programs in implementing waste
minimization programs and coordinating their efforts should be
apparent. The South Bay POTWs have started to notice drops in
concentrations of some of the metals reaching their plants. Palo
Alto has shown measurable success in their efforts directed
toward
-------
published by the Local Government Commission of Sacramento,
California, can help POTWs organize successful programs.
3. Pollution Prevention Hierarchy. The hierarchy of waste
management practices should be followed. Source reduction
and recycling alternatives are more desirable than treatment
and disposal. Activities that promote the substitution of
practices that are higher up on the hierarchy should be
encouraged. Also, it is important that pollution .prevention
efforts take a cross-media approach so that total waste
generation is minimized.
4. Emphasize Monetary Benefits. There are many economic
benefits associated with pollution prevention. A few
reasons why companies should consider pollution prevention
are: savings due to reduced chemical costs, reduced
liability, and higher production efficiency. And in the
South San Francisco Bay, it is often cheaper for radiator
repair shops to go to zero-discharge rather than install
costly new treatment systems. To help encourage industries
to implement pollution prevention programs, monetary
benefits should be stressed. Benefits are further described
in the Local Government Commission report referenced above.
5. Publicize Successes. Public, private, and government
organizations will be more willing to implement pollution
prevention programs if they receive positive reinforcement.
If the pollution prevention successes are well publicized,
people will be more inclined to begin their own programs.
6. Management Commitment. Industry management must be
committed to their companies' waste minimization programs.
If a company's program is to have any success, management
must support the time and resources needed to identify and
implement possible pollution prevention measures. Agencies
and trade associations should promote successful waste
minimization measures that may convince managers that
pollution prevention is not only beneficial to the
environment, but can also improve community relations,
increase employee safety, and save money.
7. Mass-Based Limits. POTWs should examine mass-based limits
as a way to minimize water use and set precise discharge
limits. Although mass-based limits are conducive to waste
conservation, there are problems with this approach (e.g.
measuring flow, establishing flows for an industry,
evaluating increased allocations based on production
increases) .
8. Small Business Incentives. Some monetary incentives should
be available for smaller businesses to implement waste
minimization measures. Small businesses are frequently
impeded from making environmentally beneficial changes,
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because of the amount of capital involved. Therefore,
government organizations should consider offering incentives
(e.g. grants, rebates, or tax credits) to encourage
companies to.install environmentally useful equipment that
they would otherwise not be able to afford..
9. Non-Regulatory Assistance. There is a need for non-
regulatory assistance for POTWs and industries in every
State, currently, some states (e.g. Minnesota, Tennessee,
Nevada, and North Carolina) do have some type of assistance
program available. These programs are typically affiliated
with universities. Also, EPA Headquarters is considering
the use of the Pollution Prevention Information
Clearinghouse and electronic bulletin board as a forum to
share information of specific interest to POTWs. If well
advertised, this information should be of significant value
to POTWs that are developing waste minimization programs.
10. Agency Coordination. There is a need for good coordination
among public and private groups. Government agencies from
each level (federal, state, and local), industries, and
public interest groups must have clearly defined
responsibilities to ensure a successful pollution prevention
program. This is particularly important because there are,
as of yet, few established procedures for pollution
prevention programs.
11. Regulatory Barriers. Any law that impedes or restricts a
business from choosing the most environmentally favorable
waste management option should be re-evaluated and made as
flexible as possible. There is a need for laws that promote
waste management decisions which consider all media (air,
water, and land), and allow the best options to be
implemented.
12. Household Hazardous Wastes. Lastly, there is a need for
more detailed research, and a repository for all gathered
information on consumer products. The source identification
studies conducted in the South Bay Area noted that
residential areas were a significant source of many
pollutants of concern. If information on consumer products
is readily available, communities will be able to decide
which products could be substituted for those that contain
high amounts of pollutants of concern.
In conclusion, the South Bay Pilot Project has affirmed that
POTWs can help reduce impacts to the environment if they
implement pollution prevention programs. Although the impetus
for this project was regulatory, its success demonstrates that
cost-effective technologies and practices are available that can
reduce pollutants at the source. The benefits of source
reduction include reduced treatment costs, improved operations
and productivity, and better water quality.
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POTWs elsewhere should promote similar pollution prevention
programs in their service areas for a number of reasons. First,
improved influent wastewater quality will enable POTWs to more
easily comply with water quality standards, air emission
requirements, and sludge disposal requirements, and to maintain
compliance with these regulations despite population growth.
Second, reduced wastewater flow and loading can help extend the
useful lives of POTWs. Third, it is less expensive to institute
pollution prevention practices than to install new treatment
systems. Fourth, treatment plant workers would be exposed to
less hazardous conditions. Finally, and perhaps the most
compelling reason of all, POTWs would be meeting the public's
demand for a cleaner environment.
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VIII. LIST OF ACRONYMS
1. AET - Apparent Effects Threshold
2. BMP - Best Management Practice
3. CN - Cyanide Compound
4. CBE - Citizens for a Better Environment
5. CWA - Clean Water Act
6. DHS - California Department of Health Services
7. EDTA - Ethylenediamine Tetraacetate Dihydrate
8. ICS - Individual Control Strategy
9. mg/L - Milligram Per Liter
10. NPDES - National Pollutant Discharge Elimination System
11. PPIJ - Part per Billion
12. PPI) - Pollution Policy Document
13. PPM - Part per Million
14. POTW - Publicly Owned Treatment Works
15. RWQCB - California Regional Water Quality Control Board
16. SCCMG - Santa Clara County Manufacturing Group
17. SCVWD - Santa Clara Valley Water District
18. SJ/SC - San Jose/Santa Clara
19. TRI - Toxic Release Inventory
20. jug/1 - Microgram Per Liter
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IX. APPENDICES
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APPENDIX A: Water Quality Documents
Two documents, were reviewed to determine which pollutants
were of concern in the South Bay. They are the State Water
Resources Control Board's "Pollutant Policy Document" and the
Citizens; for a Better Environment's "Toxic Hot Spots in San
Franciscjo Bay." The following is a discussion of the findings of
the two reports.
Pollutant Policy Document
Thti State Water Resources Control Board's "Pollutant Policy
Document" (PPD) assesses the effects of levels of pollutants
found in the Bay water, fish and shellfish on human health and
aquatic biota. The levels of pollutants are related to water
quality criteria and shellfish tissue standards (including EPA
and FDA criteria levels, DHS maximum contaminant and residue
levels, Ocean Plan objectives, and Water Quality Control plans).
Although concentrations of pollutants in the sediments are
listed, they are not evaluated in the PPD for potential toxic
impacts (no federal or site-specific sediment quality criteria
exist at present). The ability to completely assess the effects
of these pollutants on aquatic life is hampered by this lack of
sediment criteria, and by a lack of data on the synergistic and
additive effects of the various pollutants.
A summary of the findings of the PPD for metals of
particular concern in the South Bay POTW effluents is included
below:
Cadmium - Higher dissolved cadmium concentrations are found in
the South Bay than elsewhere in the Bay, with a high dissolved Cd
concentration of 0.25 ppb. This is well below all state and
federal criteria for freshwater or marine organisms. However, Cd
is highly bioaccumulated and is found in Bay mussels and oysters
at 1 ppm wet weight. This is a concern for humans and others who
feed on these organisms.
Chromium - The PPD does not list any data for South Bay chromium
concentrations in water. It does cite one study that found local
sources: in the South Bay did increase Cr levels in mo Husks, and
another study that did not result in the same finding.
Apparently, most studies show tissue levels below the level of
concern for human consumption.
Copper - Dissolved copper is found in the South Bay in
concentrations ranging from 2.5 to 4.0 ppb. The upper end of
this range exceeds EPA'S marine acute and chronic copper criteria
of 2.9 ppb. Copper-enriched sediments are also present in the
South Bay. Some South Bay waterfowl liver tissue has been found
to contain copper in levels equaling the median international
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standard. The PPD concludes that this is not considered a human
health problem.
Lead - According to the PPD, dissolved lead levels in the South
Bay waters are higher than in the Central Bay, but do not exceed
the EPA marine chronic criteria of 5.6 ppb. High levels of lead
in mussel tissue have been detected, but apparently not in the
South Bay.
Mercury - Apparently, little reliable data is available on
concentrations of mercury in Bay Waters. But, sediment
concentrations in the South Bay have reached 7.0 ppm dry weight
compared to a high of 0.49 ppm dry weight in the Central Bay.
The PPD indicates that mercury levels found in the tissues of
South Bay mussels have reached the 0.5 ppm wet weight standard
for human consumption.
Nickel - Nickel has been found in South Bay waters at 8.0 ppb
which approaches the EPA marine chronic criteria of 8.3 ppb.
Higher nickel levels in mussels have been found in other areas of
the Bay.
Silver - Water concentrations of silver as high as 0.31 ppb have
been found in the South Bay. This exceeds the EPA fresh water
chronic criteria of 0.12 ppb. Silver levels in the sediment are
also higher in the Palo Alto area (up to 4.0 ppm dry weight) than
in most other parts of the Bay. Levels of silver found in
shellfish tissue increase toward the south of the Bay, with the
highest levels found seasonally at Palo Alto approaching 200 ppm
dry weight. This amount is apparently not hazardous to humans.
Zinc - Some elevated levels of zinc have been detected in South
Bay waters, but no samples have shown levels greater than the EPA
freshwater or marine water quality criteria. Sediments close to
the Palo Alto outfall have been found to exhibit high zinc
concentrations. Zinc levels in mussels have been found at
moderately elevated levels in some parts of the South Bay (47.5
ppm dry weight at the Dumbarton Bridge), but are below levels for
human health concern.
Toxic Hot Spots
Another document which summarizes pollutant areas of concern
is Citizens for a Better Environment's (CBE) Report entitled
"Toxic Hot Spots in San Francisco Bay." In this study, the same
shellfish standards are used as in the PPD. Unlike the PPD, the
sediment pollutant levels were evaluated for potential toxicity
using the Apparent Effects Thresholds (AETs) developed as type-
specific sediment quality criteria for analysis of Puget Sound
sediments. The resulting "Toxic Hot Spots" include the following
areas, which receive discharges from the three South Bay POTWs:
Coyote Creek, Guadalupe Slough, and Palo Alto Outfall.
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Coyote Creek
The CBE report specifies that Coyote Creek (which receives
the outfall from the San Jose/Santa Clara POTW) sediments contain
levels of cadmium, chromium, silver, nickel, mercury and iron
which exceed the Puget Sound AETs. The report also stated that
shrimp from this area have contained levels of chromium which
exceed chromium standards for edible shellfish.
Guadalupe Slough
According to the CBE report, the sediments in Guadalupe
Slough, which receives effluent from the Sunnyvale POTW, have
contained chromium, mercury, nickel and silver in levels
exceeding those found to adversely affect aquatic life in Puget
Sound.
Palo Alto Outfall
Silver levels in the sediments near the Palo Alto outfall
exceed levels found to have adverse affects on aquatic life.
Copper and silver have bioaccumulated in clams in this area to
the highest levels ever reported. The copper levels exceed the
median international standard for edible shellfish.
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APPENDIX B
CITY OF SUNNYVALE UATER POLLUTION CONTROL PUNT
UASTE MINIMIZATION SURVEY OUESTIOHHNAIRE
(REDUCTION Of HEAVY METALS AND CYANIDE IN UASTEUATEI) (CROUP A)
{Facility Name:
i
'facility Representative's Nine: Title:.
Facility Street Address:
Type of Business: •
Nuifcer of Employees: Nu-ber of Years in Business Within the City of Sunnyvale:
1. Volune of Uasteuater discharged to the sanitary sewer: Process Flow ______ gal/day; Total Flow gal/day
Hours in Operation: -
Days of the Ueek.in Operation (circle): N T U TN F SAT SUN
'2. List All Processes That Generate Heavy Metals and/or Cyanide That Are Discharged In Wastewater to the Sanitary Sewer:
(e.g. Copper Plating, Photographic Processing, SiIkscreening, Cooling Tower, Etching, etc.)
(Attach additional sheets for processes if necessary)
3. Do you keep an updated inventory list of chemicals stored and used at this facility?
|T] NO Q YES Q DON'T KNOU
4. Do you have a Hazardous Materials Storage Permit or • Spill Plan approved by the City of Sunnyvale Fire Prevention Department?
I Q NO [3 YES Q DON'T KNOW
j
5. In the last three years, have you substituted chemical products in any processes that may have reduced the amount of seta I c
ond/or cyanides in process wastewaters? This should apply only to process Mastewaters. with or without pretreatment. that was
discharged to the sanitary sewer (e.g., substituting a chromic acid bright dip with one using sulfuric acid/hydrogen peroxide).
NO YES, Briefly describe what was substituted:.
L
. If yes to question f5 above, was the chemical product substitution done:
Q To neet the City's Pretreatment Requirements, Q To reduce the amount of hazardous waste disposed of off-site,
Q Because your chemical supplier suggested it, Q Other, Briefly describe: ____________________________
7. In the last three years, has your discharge of heavy metals and/or cyanide to the sanitary sewer changed?
Q Decreased Q Increased Q No change Q Don't Know
If the discharge decreased, was this due to one or more of the following: (check all that apply)
Q A reduction in production, Q Implementation of waste minimization measures,
Q Discontinuance or replacement of the process, Q To meet the City's Pretreatment Requirements,
Other (please specify): ____________________________________________
If the discharge increased, was this dot to:
An increase in production, Other (please specify):
(NOTE: PLEASE FEEL FREE TO PROVIDE ADDITIONAL COMMENTS.] ffOA, Inc., Revised 8/4/89)
- 47 -
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CITY OF SUNNYVALE WATER POLLUTION CONTROL PLANT
UASTE MINIMIZATION SURVEY QUESTIONNAIRE
(REDUCTION OF HEAVY METALS AND CYANIDE IN UASTEUATER) • Continued (GROUP A)
£. In the last three years, have you reduced or recycled any wastes or wastewater* resulting In UBS metals and/or cyanides in
in wasteuater discharges? (e.g. plating metal wastes in rinse water were reduced by decreasing drag-out time or by installing
drag-out time or by installing drain boards; or wastes were recycled by regenerating spent cupHc chloride etchant with a
chlorine oxidizcr; or using the first-stage rinse water as makeup for the process bath; or by installing a metal recovery unit!
PI NO. If no, please go on to question «9 below. Q DON'T KNOU,-go en to question #9 bellow.
Q YES. If yes,, please check all of the following that apply to your facility.
A. We have undertaken the following measures in the last three years:
ri Separate process wastestreams _ Q Nave drain boards between bath and rinse tanks _
P] Use non-cheliite process chemicalo _ _ Q Minimize process bath chemical concentration _
Us« recyclable materials _ _ Q Maximize process bath temperature _
Spray rinse *>rkpiece before tank rinse ______ Q Use ion exchange to recover metals from rinse water
static, multi-stage dip rinse tanks _ _ Use electrolysis to recover metals from rinse water
PI Countercunreit multi-stage rinse _ [""] Periodic staff training on material and waste handling,
t~~l process changes, and good housekeeping practices __
Q Hove workpiece automatically in rinse tank „ _
Q Aerate rinse water _______ ("J Other: _ ______________________
B. Please indicate with an asterisk (*) in *9.A. above which measures also resulted in a reduction in water usage, and
provide an estimate, if known, of the percent (X) of total process water usage that was reduced
For example: static, multi-stage dip rinse * IPX reduction
C. The following Material and/or Waste Recycling efforts have been used in the last three veers:
Q Spent etchert regeneration ^decant/filter) Qu<« reverse osmosis to recover both solution
PI Spent photoresist stripper regeneration F1 Use spent acid or alkaline cleaners as neutralizing chemicals
in waste treatment
|~) Dragout wetcr is used as bath makeup
11 Periodic staff training on recycling procedures
|| Evaporation is used to recycle process baths
)_: n Other: ,
Ij Recycling treated wastewater
D. If Wastewceer Treatment Measures (or Pretreatmtnt System) hove been undertaken over the lost three years to reduce
dischargee of heavy metals and/or cyanides to the sanitary sewer, briefly describe the measures:
9. Has your investomt in equipment or materials for metals and cyanide reduction, recycling, or waste treatment measures been
recovered in cest: savings for waste disposal or material purchases?
Q All Costs Recovered QJ Some Costs Recovered Q No Costs Recovered [__ DON'T KNOU
Garments: _____ _________________________________________________________________
0. If the City's (local discharge standards for metals and cyanides were reduced to allow discharges no greater than 0.01 ppm
of copper, 0.0023 ppm of lead, 0.0036 ppm of'nickel, 0.0012 ppm of silver, 0.029 ppm of sine, and 0.0125 ppm of cyanide
what would you hive to'do in order to meet those standards? (Note: These values are based upon formal requests
made by Regional Board staff, i.e. SOX of Basin Plan Table IV-1 discharge standards.)
(continue on reverse side, if necessary) tEOA, Inc., Revised B/A/GB
_ 48 -
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CITY OF SUNNYVALE WATER POLLUTION CONTROL PLANT
WASTE MINIMIZATION SURVEY QUESTIONNNA1RE
(REDUCTION OF HEAVY METALS AND CYANIDE IN UASTEUATER) - Continued (CROUP A)
11. What do you estimate the annual cost would be to do the things in question *10 in order to Met the hypothetical discharge
standards? (Amortize the capital costs over a ten year period.)
< $1.000 Q $50,001 - $250,000 Q > $1,000,000
r~] $1,001 - $10,000 Q $251.001 - $500,000 Q Actual Estimate. If Available:
•] $10.001 • $50.000 Q $500.001 • $1,000,000 Q DON'T KNOW
12. If the City's local discharge standards for metals and cyanide were reduced to require discharges no greater than
the Regional Board's Basin Plan Table IV-1 Units (that is, 0.02 ppn of copper, 0.0056 ppm of lead, 0.0071 ppm of nickel.
0.0023 ppm of silver, 0.058 ppn of zinc, and 0.025 ppm of cyanide), what whould you have to do in order to meet those standards?
(Note: These values are what the City nay have to meet in its Water Pollution Control Plant discharge.)
I. What do you estimate the annual cost would be to do the things in question f12 in order to meet the hypothetical discharge
standards? (Amortize the capital costs over • ten year period.)
< $1.000 Q $50.001 - $250.000 Q > $1.000,000
$1.001 • $10,000 Q $251,001 - $500,000 Q Actual Estimate, If Available:
$10,001 • $50,000 Q $500,001 • $1,000,000 Q DON'T KNOW
. Has your company performed a waste audit for wastewater or that included wastewater evaluations?
Q NO. If no, go on to question «16. Q DON'T KNOW, go on to question «16.
Q YES. If yes, was the audit done: QBy facility staff
Q By a consultant
Q More than once
PI Other:
15. If you had an audit performed, did the results show that: (please check all that apply)
Q Cost saving measures were identified.
Q No cost saving measures were identified.
Q No changes were made.
II Changes were made. Please describe:
Comments:
16. Are you currently using the California Waste Exchange for uastewater treatment residues?
Q NO Q YES Q DON'T KNOW
17. Would you or your staff be willing to discuss current or possible*waste minimization practices and their associated costs with
Sunnyvale's consultant? *
NO Q YES. If yes, please give Contact:
Title: _
Phone:
[NOTE: PLEASE FEEL FREE TO PROVIDE ANY ADDITIONAL COMMENTS.]
(EOA. Inc.. Revised 8/4/891
- 49 -
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CITY OF SUMUVVALE UATER POLLUTION CONTROL PLANT
UASTE MINIHIZATIQN SURVEY QUESTIONNAIRE
(REDUCTION Of HEAVY METALS AID CYANIDE IN UASTEUATER) (CROUP B)
Facility Name:
acility Representative's Name: Title:
facility Street Address: __________________________________________________
"ype of Business: ___^_____________________________^____________
Itandard Industrial Cede (SIC). If known:
Ntmber of Employees: __________________________ Nunber of Yeart In Business Within tha City of Sunnyvale: ________
1. Average amount of water purchased from City of Sunnyvale: Q Per water bill _ ccf/nonth
Q Don't Know, bill is paid by building owner
I. Estimated amount of water discharged into the sanitary sewer: _______ (SOX. 9CK. or other of amount purchased, or Don't Kncai
... List All Processes That Generate Heavy Hetals and/or Cyanide That Are Discharged in Uasteuater to the Sanitary Sewer:
(e.g. Machining. Hilling-contact cooling water. Boiler Blowdown. Radiator Repair, Cas Station. Auto Maintenance. Car/Truck Uash,
Auto Body Repair/fainting. Laboratory-rinse water, Photographic Processing. Restaurant* wash ing. Restaurant- grease trap)
(Attach additional sheets for processes if necessary)
Do you keep an ufriated inventory list of chemicals stored and used at this facility?
Q NO Q \'K Q DON'T KNOW
List all heavy totals or cyanides stored or used at this business. If you have an inventory list, please attach a copy.
6. Do you know what waste minimization is?
Q Never heard of it
Q Have heard of it
Q Have used or are using waste minimization practices
In the last throe years, have you substituted chemical products in any processes that nay have reduced the amount of metals
or cyanide in process wastewaters that reached the sanitary sewer?
DNO
Q YES7 Briefly describe what was substituted: ______________________„__________________,
Q DON'T KNOW
If yes to question 17 above, uat the chemical product substitution done:
Q To neet the City's Pretreatnent Requirements, Q To reduce the amount of hazardous waste disposed of off •site.
Q Because your chemical supplier suggested it, Q Other, Briefly describe: ________________________
[NOTE: PLEASE FEEL FREE TO PROVIDE ADDITIONAL COMENTS ON ANY OF THESE QUESTIONS.]
[EOA. Inc.. Revised 8/«>»l
- 50 -
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CITY OF SUNNYVALE WATER POLLUTION CONTROL PLANT
INVENTORY OF UASTE MINIMIZATION SURVEY QUESTIONNNAIRE
(REDUCTION OF HEAVY METALS AND CYANIDE IN VASTEUATER) • Continued (CROUP B)
9. In the last three years, have you reduced your heavy metal or cyanide usage?
Quo
FJ YES. Briefly describe: __
FJ DON'T KNOU
D. If yes to question *8 on the previous page, was the reduction in chemical usage done:
FJ To neet the City's Pretreataent Requirements, PI To reduce the amount of hazardous waste disposed off-site,
FJ Because the process was discontinued, FJ Because the process was replaced; replaced by __^^^_______
FJ Other: _____
\. If the City's local discharge standards for various Detail and cyanides were reduced to the Regional Board's Basin Plan
Table IV-1 Units (that is, no discharge greater than 0.02 ppn of copper, 0.0056 ppm of lead, 0.0071 pen of nickel,
0.0023 ppm of silver, 0.058 ppm of zinc, and 0.025 ppm of cyanide), what would you have to do in order to neet those standards?
B. What do you estimate the annual cost would be to do the things In question f10 above in order to meet the hypothethlcally
more stringent standards?
Q < $500 FJ $10.001 - $50,000 FJ $501,001 • $1.000,000 FJ DON'T KNOU
FJ $501 • $1,000 FJ $50.001 • $250.000 FJ > $1,000.000
FJ $1,001 - $10.000 FJ $250.001 • $500,000 FJ Actual estimate, if known:
|f. Has your company performed a waste audit for wastewater or that included a wastewater •valuation?
FJ NO. If no. go on to question *U. FJ DON'T KNOU, go on to question fU.
FJ YES. If yes, was the audit done: FJ By facility staff
Q By a consultant
FJ More than once
FJ Other: ^
If you had an audit performed, did the results show that: (please check all that apply)
FJ Cost saving measures were identified.
FJ No cost saving measures were identified.
FJ No changes were made.
FJ Changes were made. Please describe: _____________________________^__________________
Contents:
15. Are you currently using the California Waste Exchange for wastewater treatment residues?
Q NO FJ YES Q DON'T KNOW
•5. Uould you or your staff be willing to discuss current or possible waste minimization practices and their associated costs with
Sunnyvale's consultant?
FJ NO FJ YES. If yes, please give Contact:
Title:
(NOTE: PLEASE FEEL FREE TO PROVIDE ANY ADDITIONAL COMMENTS.)
{EOA. Inc., Revised 8A/891
- 51 -
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APPENDIX C
Waste Minimization Program
of the
California Regional Water Quality Control Board
San Francisco Bay Region
(From Basin Plan Dated 1/17/92)
- 52 -
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WASTE MINIMIZATION
POLICY STATEMENT
For • Man Emissions Strategy (MES), as called for In the
State Water Resources Control Board's Pollutant Policy
Document for the San Francisco Bay-Delta, a necessary
component Is a prelreatment and waste minimization
program for point source discharges. 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 supports reducing toxic discharges
throughmoreefficientuse, conservation, recycling, reuse,
and waste reduction. The waste minimization program is
a pollution prevention and source reduction measure
designed to eliminate the discharge into water of toxic
wastes from manufacturing processes, commercial
facilities, and the community at large. Waste minimiza-
tion will be increasingly demanded as alternative uses of
wastewater such as reclamation are developed. Waste
minimization, techniques will allow for the protection of
surface and ground water and Include material recycling
and reuse, water end material conservation, material
substitution, product substitution, and process modifies-
tions. Waste minimizations applied here la focused
specifically on reducing the quantity of toxic pollutants
released to the waters of the basin by major municipal
and industrial dischargers. H empjhaslzes source reduc-
tion but also includes improved water and petroleum
product use, wastewater treatment and expanded pre-
treatment programs.
The San Francisco Bay Region'a Waste Minimization
Program will be a two-tiered program consisting of a
targeted and general program. The Regional Board's
source control program focuses on indirect discharges
that ere regulated through Publicly Owned Treatment
Works (POTWs) and major industrial dischargers that
discharge directly to surface water. These programs will
take multimedia concerns into account by coordinating
with other relevant regulatory programs related to air and
land disposal.
TARGETED WASTE MINIMIZATION PROGRAM
The targeted waste minimization program wilt first
identify pollutants and areas of concern In the Bay by
identifying where numerical and narrative water quality
objectives are exceeded and beneficial uses are impaired
or threatened based on analysis of available data and data
from regional end local monitoring program monitoring
programs conducted by the Regional Board and other
entities. Second, in those areas of the watershed or
estuary system identified as having exceedances or
Impairments, point source dischargers will be identified
and required to participate In a targeted waste
minimization program. Through amendments to their
NPDES permits, this program will be directed toward
reducing the specific pollutants of concern. This step
may necessitate further monitoring of water, sediment
and biota by POTWs and direct discharges at and near
their discharge locations In order to determine the effects
of particular discharges on the waters of the basin.
Impacting point sources will be required, through amend-
ments to their NPDES permits, to develop and implement
a targeted waste minimization program that will reduced
the identified pollutants of concern.
The targeted program will Include all elements of the
general program and may require other options such as
performance-based efflunetconcnetrationtimtts and mass
limitations for the pollutants of concern, in order to attain
water quality objectives In the receiving water body.
Phased implementation of the program will be carried out
incoordinationwtth the development and Implementation
of other tasks of the Mass Emissions Strategy required In
the Pollutant Policy Document
POTW TARGETED PROGRAM
The POTW source reduction/waste minimization program
will include
1) Determination of contributions of target metal and
organic pollutants discharged to the POTW from (a)
regulated industrial users, (b) commercial facilities.
(c) water aupplies, end (d) domestic sewage.
2) Enhancement of existing pretreatment programs
through Improved auditing, Inspection, monitoring,
enforcement, end Information management This
would include a program of waste minimization
audits for selected groups of significant industrial
users (IUJ. Increased inspection and monitoring, of
regulated IDs, increased enforcementfor IUviolation,
improved processflowmeasurements, and improved
information collection and management are other
components that may be required in the target
program.
3) Identification of previously unregulated Industrial
users and commercial facilities that discharge the
pollutants of concern to the POTW. The Regional
Board will assist In prioritizing currently unregulated
categories of industry and development of technical
assistance programs for local Industries.
4) Public education and outreach including household
hazardous waste collection programs, information on
toxics disposal to POTW customers, and presents
1991 Update / Printed 01/17/92
- 53 -
IV-21
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tions to industrial, eommarclal and rasldantial discharg-
ars.
5) Development of monitoring or othar •valuation
measurac to gauge end documant their affactivaoaas
of the program.
DIRECT INDUSTRIAL DISCHARGER TARGETED
PROGRAM
Similar to POTWu, priority diract dischargars will be
identified from existing monitoring information on watar
quality of surface waterbodies In tha Region. Oiraet
dischargers may ba raquirad to conduct furthar monitor*
ing. ThoM idantifiad as impacting watar quality will ba
raquirad to carry out a watta minimization program. Tha
program should raduca or aliminata tha pollutants of
concam to meet tha watar quality objactivas of tha Basin
Plan. Programs will Includa all applicsbla elements of
PO7W programs. Tha program will also includa investi-
gation of upctraam soureas of pollutants of concam.
GENERAL WASTE MINIMIZATION PROGRAM
All major dischargars not raquirad to Implement targeted
programs will ba mandatad to conduct a ganaral program
within thair jurisdiction. In tha first phasa of tha ganaral
program, all major industrial dischargars and POTWs not
includad in th« targatad program, having approvad
pratraatmant programs, and with an avorage dry waathar
diseharga graatar than 10 MGD will ba raquirad to
prapara and submit a plan for a ganaral wasta minimiza-
tion/source reduction program and for Ragional Board
approval. Tha plans ara dua on July 1,1092. An irrtarim
prograss raport will ba dua from all POTWs on January
1,1993 and July 1,1993. Prograss raports should have
a datailad dascription of tha program. Including staffing,
funding, and training for instituting tha program.
POTW GENEPAL PROGRAM
For POTWs includad in tha first phasa. tha general
program will includa Idantification of two Industrial
estagorias for axpansion of ragulatory maasuraa. In tha
aacond phas*. all othar POTWs with pratraatmant
programs will ba raquirad to develop aourca reduc-
tion/waste minimization programs. Tha plan for tha
program will ba dua to tha Ragional Board on January 1,
1993, with prograss raports on tha program dua by July
1, 1993 and Dacambar 31, 1993.
Tha ganaral program- for a POTW should contain all
applicable alamants from tha targatad program (alamants
2-5); tha general program is daslgnad to ba mora flaxlbia
and allow tha Individual POTWs to davaiop and diract
thair wasta minimization afforts according to local naads.
Gaoarsl progrsms should includa tha following elements:
1) Pratraatmant program raviaw for Idantification of
opportunities for axpansion and anhancamant This
irtcludas opportunities for Incorporating wans
raduction goals into inspections, enforcement, and
parmitting.
2) Wasta minimization audits for industrial user* on
a priority datarminad by tha POTW. Criteria for
prioritization should includa diseharga of pollutants
of concam, voluma of flow, IU complisnca, and
opportunitias for wasta raduction.
3) Public outraach Including aducation programs,
advertisement in local madia, mallars, and household
hazardous wasta programs.
4) Program axpansion by davatoping a plan for
Incraasad ragulation for at laast two additional
calagorias of soureas that contrlbuta pollutants of
concam to tha POTW Influant Examples of addi-
tional catagorias ara watta oil disposal, housahold
products, car and truck washing oparations. medical
and dantal facilities, paint and ralatad product
disposal, dry claaning facilities, and photofinishlng
laboratories.
5) Coordination whh othar programs Involving
racycling, rausa, and sourca raduction of toxic
chemicals. This Inciudas programs Involving othar
madia, air toxic, hazardous wasta, and land disposal.
This might includa davaloping programs for joint
inspaetions and sharing In anforcamant activhiac.
«) A monitoring program specifically daslgnad to
maasura tha affactivanass of wasta minimization
activities in radueing toxic loads to tha receiving
watershed, air. or land via aludga disposal.
DIRECT INDUSTRIAL DISCHARGER GENERAL
PROGRAM
Tha diract industrial discharger wasta minimization
program must ansura eompllanca with Tha Hazardous
Wasta Sourca and Managamant Raviaw Act of 1989,
SB14 (CRC Titia 22, Ch 30, art 6.1) wasta minimization
program raquiramants as wall as complianca with thair
NPDES parmit affluant limitations.
Tha diract dischargar aourca raduction/wasta
minimization program plans must includa datailad
descriptions of tasks and tima sehadulaa to invastigata
and implement various alamants of watta minimization
taehnlquaa. Thasa tachniquas should Includa toxic
raduction avaluations, material substitution, proeass
modifications, watar conservation, onsha and offsfta
racycling, and good housakaaping practicat.
P/-22
1991 Updata / Prirrtad 01/17/92
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