p2infohouse.orgABSTRACT This report describes some of the pollution prevention programs currently...

POLLUTION PREVENTION IN CALIFORNIA __

AN OVERVIEW OF CALIFORNIA'S POLLUTION PREVENTION PROGRAMS AND TECHNOLOGIES

CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCES CONTROL

ALTERNATIVE TECH NOLOCY DIVISION

PETE W I L S O N G O V E R N O R STATE OF C A L I F O R N I A

J A M E S M. STROCK, SECRETARY C A L I F O R N I A E N V I R O N M E N T A L PROTECTION AGENCY

W I L L I A M F. SO0 HOO, DIRECTOR D E P A R T M E N T OF T O X I C SUBSTANCES CONTROL

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ABSTRACT This report describes some of the pollution prevention programs currently being implemented by State and local governments in California. The Department of Toxic Substances Control, the Air Resources Board, the Water Resources Control Board, the San Francisco Bay Regional Water Quality Control Board, and the Integrated Waste Management Board all have program components that can be considered as pollution prevention. Case studies illustrate industry's response to the high costs of generating pollutants: reducing their generation of pollutants.

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THIS REPORT WAS PREPARED BY:

Kathryn Barwick (Editor), Department of Toxic Substances Control (DTSC)

Clay Booher, DTSC

Donna Chen, City of Los Angeles Public Works Department, Hazardous and Toxic Materials Program

Joe Denk, Karen McDonough, and David Grabiec, San Jose/Santa Clara Department of Water Pollution Control

Loma Dobrovolny, Integrated Waste Management Board

Terry Escarda, DTSC

Robert Ludwig, DTSC

Terry Macaulay, P.E., DTSC

Mark Malachowski, Industrial Waste Inspector, City of Sunnyvale Water Pollution Control Plant

Eric Nichol, DTSC

Adriana Renescu, P.E., County Sanitation Districts of Orange County

UNDER SUPERVISION OF:

James T. Allen, Ph.D. Kim Wilhelm, P.E. David Hartley, M.P.H.

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ACKNOWLEDGEMENTS

The Department would like to acknowledge the cooperation of the following:

Jim Behrmann, Kathleen Mead, and Clifford Popejoy, California Air Resources Board, Toxic Air Contaminants Branch

David W. Brooks, Joseph Berquist, and Mary Clifford, Hewlett-Packard, Sunnyvale, California

Matt Chadsey, Palo Alto Regional Water Quality Control Plant

Virginia Cummings, Ben Machol, and Claire Elliott, U.S. EPA Region IX

Chris DeGroot and Linda Marten, City of Sunnyvale

Larry Dungan, Advanced Micro Devices

Anthony Eulo, Local Government Commission

Daniel Q. Garza, California Department of Toxic Substances Control, Alternative Technology Division

Dale Hopkins, California Regional Water Quality Control Board, San Francisco Bay Region

Patrick Kwok, San Jose/Santa Clara Department of Water Pollution Control

William La Marr, Southern California Edison

Lew Jones, East Bay Municipal Utility District

John Mahajan, Califomia Electroplating Company

Clem Molony, Tandem Computers

Steve Seemer, Executive Enterprises Inc.

Walt Shannon, Nonpoint Source Section, State Water Resources Control Board

Ken Smarkel, Ph.D., California Department of Toxic Substances Control, Alternative Technology Division

Maria Tikoff, California Environmental Protection Agency

Thomas von Kuster, Jr., Water Technologies, Inc., Minneapolis, Minnesota

DISCLAIMER

The mention of commercial products or companies, their source, or their use in connection with material reported herein is not to be construed as either an actual or implied endorsement of such products.

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TABLE OF CONTENTS

LIST OF TABLES AND FIGURES .................................................................................................. xi

... EXECUTIVE S U M M A R Y ................................................................................................................ xiii

CHAPTER ONE: POLLUTION PREVENTION IN CALIFORNIA .................................... 1

Pollution Prevention and Sustainable Development .................................................................. Governmental Pollution Prevention Programs ..........................................................................

Hazardous Waste Minimization ................................................................................................................. Reducing Pollutants Discharged to Water .................................................................................................. Air Emissions Minimization ......................................................................................................................

Status of Pollution Prevention Activities in California .............................................................. Local Government Pollution Prevention Efforts ........................................................................................ The Green Lights Program ........................................................................................................................

Barriers to Pollution Prevention ................................................................................................................

Media Transfer of Pollutants .....................................................................................................................

Issues Confronting Pollution Prevention Programs ..................................................................

Measuring Pollution Prevention ................................................................................................................

3 4 5 6 7 7 8 9

10 10 11 13

CHAPTER TWO: CALIFORNIA’S HAZARDOUS WASTE MINIMIZATION PROGRAM ....................................................................................................................................... 15

The Waste Minimization Program .............................................................................................. 15 The Department’s Work with Local Government Programs ...................................................................... 16 Coordinating State Pollution Prevention Programs .................................................................................... 17 New Programs: Incinerable Hazardous Waste and SB 14 .......................................................................... 17

Case Studies in Hazardous Waste Minimization ....................................................................... 20 The California Hazardous Waste Reduction Grant Program ..................................................................... 20 - The Envirostat Project ........................................................................................................................ 20 - Recycling for the Dry Cleaning Industry .............................................................................................. 22

- Fluoride- and Boron-Free Stripper for the Removal of Solder from Printed Circuit Boards ....................... 24 - Reclamation of Waste Foundry Sands .................................................................................................. 30 - Using Waste Minimization Conditions in Enforcement Actions .............................................................. 32 The Waste Reduction Innovative Technology Evaluation (WRITE) Program ............................................ 35

- Advanced Reverse Osmosis System for Nickel Recovery ...................................................................... 35 City of Los Angeles Hazardous and Toxic Materials Program: City of Los Angeles Mayor’s

Award of Excellence ............................................................................................................................ 39 - Department of General Services/Building Maintenancdonversion to Water-Based Paints .................... 39 - Hazardous Waste Minimization Program at the Hyperion Wastewater Treatment Plant ............................ 40 - Department of General Services/Fleet Services/CFC-12 Recycling ......................................................... 43

CHAPTER THREE: REDUCING DISCHARGES O F POLLUTANTS TO WATER ........... 45 Point Source Programs ................................................................................................................. 45

The South Bay Pilot Project ....................................................................................................................... 45 Palo Alto’s Waste Minimization Program .................................................................................................. 48 The San JodSanta Clara Waste Minimization Program ........................................................................... 50 Sunnyvale’s Waste Minimization Program ................................................................................................ 50 County Sanitation Districts of Orange County Waste Minimization Program ............................................ 51

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The California Regional Water Quality Control Board. San Francisco Bay Region’s Basin Plan ................................................................................................................................................. Storm .Water Permit Program ...................................................................................................................

Nonpoint Source Pollution Prevention ........................................................................................ The Role of the State Water Resources Control Board in Nonpoint Source Pollution Prevention ................

Waste Minimization Case Studies ...............................................................................................

. California Electroplating Company ........................................................................................... 1 ..........

. Tandem Computers.. A Small Computer Development Lab ....................................................................

. Advanced Micro Devices. Inc .............................................................................................................

. Hewlett-Packard’s Sunnyvale Facility ..................................................................................................

. Organic Chemical Industry .................................................................................................................

. Paint Stripping ...................................................................................................................................

. Food Industry ....................................................................................................................................

San JosdSanta Clara

Sunnyvale

County Sanitation Districts of Orange County

54 56 57 58 60

60 62 62

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68 67 70

CHAPTER FOUR: AIR EMISSIONS MINIMIZATION ...................................................... 73

Stationary Source Regulations at the Local Level ...................................................................................... 74 Stationary Source Regulations at the State Level ....................................................................................... 74 California’s Air Toxics Pro gram ................................................................................................................ 74

Consumer Products ................................................................................................................................... 76

Pollution Prevention Through Regulatory Requirements ........................................................ 73

Motor Vehicle-Related Measures ............................................................................................................... 75

Incentives Approaches to Pollution Prevention ......................................................................... 76 Technical Guidance ................................................................................................................................... 76 Market-Based Incentives ........................................................................................................................... 76 Public Education ....................................................................................................................................... 77

Growth Management and Energy Consumption ....................................................................... 77 Cross-Media Program Efforts ..................................................................................................... 78

Hazardous Waste and Air Interface ........................................................................................................... 78 Solid Waste and Air Interface .................................................................................................................... 78

ARB Chrome Plating Control Demonstration Project .............................................................. 78 Case Studies in Air Pollution Minimization ............................................................................... 85

The Clean Air Coatings Technology Program ............................................................................................ 85 - Ultraviolet: Safetran Systems, Inc ....................................................................................................... 87

- Powder Coating and Infrared Curing: Los Angeles Times ..................................................................... 90 - Powder Coating and Infrared Curing: Hendry Telephone Products ......................................................... 90 - Ultraviolet: West Coast Samples, Inc .................................................................................................. 91

. - High Solids: U.S. Coachworks, Inc ..................................................................................................... 88

CHAPTER FIVE: WASTE MINIMIZATION IN SOLID WASTE ....................................... 93 Mission of the Integrated Waste Management Board ............................................................... 93

CALMAX, the Board’s Materials Exchange Program ............................................................. 94

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The Business Assistance Team ..................................................................................................... 94

Large Scale Diversion Facilitation ............................................................................................... 95 Recycling Market Development ................................................................................................... 96

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APPENDICES ..................................................................................................................................... 97 A Department of Toxic Substances Control-Regional Offices ............................................. 99

Pollution Prevention Publications .......................................................................................... 101 B

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LIST OF TABLES AND FIGURES

TABLES

Table 1:

Table 2:

Table 3:

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Table 5:

Table 6:

Table 7:

FIGURES

Figure 1:

Figure 2:

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Figure 6:

Figure 7:

Figure 8:

Figure 9:

Figure 10:

Figure 11:

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Figure 13:

Figure 14:

Figure 15:

Voluntary Participants in the Department’s Incinerable Waste Minimization Project ...................................................................................................... 18

Tabular Summary of Waste Reductions: 1989 vs . 1990 ........................................................ 41

Tabular Summary of Economic Benefits: 1989 vs . 1990 ...................................................... 43

Test Locations. Control Equipment and Other Information ................................................... 79

System Emissions ...................................................................................................................... 81

Removal Efficiency. Control Device Only-No Process Modifications .............................. 79

Effect of Process Modifications Upon Emissions ................................................................... 82

Combination Distillation/Adsorption Treatment Process ....................................................... Simplified Porbaix Diagram for Copper .................................................................................. Summary of Acid Screening Work ........................................................................................... Solder Strip and Copper Etch Rates ......................................................................................... Bath Life of Two Optimized Baths .......................................................................................... System Schematic for Foundry Sand Reclamation System .................................................... Schematic Diagram of the Advanced Reverse Osmosis System (AROS) ........................... Silver Discharge Concentration (ug/l) ...................................................................................... Silver Concentration in Mucoma Bulthicu Near Sand Point ..................................................

Total Heavy Metals Concentrations in Raw Sewage ........................................................ Waste Minimization Measures Checklist ................................................................................. Plating Tank Process Parameters That May Affect Emissions ..............................................

Emissions After Control (mg/amp-hr) ...................................................................................... Average System Emissions .......................................................................................................

Control Equipment Performance (w/o Process Modifications) ..............................................

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EXECUTIVE SUMMARY

T h e early 1990's has been a time of change in California's environmental regulatory environment. With the creation of the Califomia Environmental Protection Agency (CalEPA) comes opportunities for helping Califomia businesses to improve their competitiveness by increasing efficiency through pollution prevention.

The development and implementation of governmental pollution prevention programs have been an integral part of this effort. This report illustrates the role pollution prevention plays in helping businesses become more competitive, and in helping to establish a sustainable economy. Although not exhaustive, this report does provide a thorough overview of the kinds of programs currently in existence.

REPORT ORGANIZATION

This report describes the pollution prevention activities of various State and local environmental regulatory agencies. These are generally "medium- specific" agencies-they regulate the generation and discharge of pollutants into one environmental medium: land, air, or water. (Sometimes, as in the case of waste management, hazardous and nonhazardous solid wastes are regulated by different agencies.) This delineation of regulatory activities by environmental medium extends from federal medium-specific legislation (the Clean Air Act, the Resource Conservation and Recovery Act, the Clean Water Act, etc.) to the State, then to the local government level.

Some environmental regulatory agencies have not traditionally considered pollution prevention to be among their activities. However, many of the regulatory activities of these agencies in fact fall under the definition of pollution prevention. For example, the sunsetting of certain chemicals by the Air Resources Board has forced industry to develop substitutes for these chemicals. The imposition of "best management practices" (BMPs) by regulatory agencies forces operational changes in order to minimize the generation of wastes, emissions, or discharges. This report identifies many of those

pollution prevention activities currently performed by regulatory agencies. Case studies are presented to illustrate industry's response to the regulatory environment and the need to reduce wastes.

CHAPTER ONE: INTRODUCTION

Chapter One introduces and defines the concept of pollution prevention and the part government can play in promoting pollution prevention as industry's preferred production philosophy. A short description of pollution prevention activities conducted by California's regulatory agencies is followed by a discussion of the issues confronting pollution prevention programs: barriers to pollution prevention, how to measure pollution prevention, and the transfer of pollutants from one environmental medium to another through pollution prevention or regulatory activities.

CHAPTERTWO: CALIFORNIA'S HAZARDOUS WASTE MINIMIZATION PROGRAM

The Department of Toxic Substances Control's (Department) hazardous waste minimization program is widely recognized as one of the most advanced in the nation. Chapter Two contains a detailed description of this program, including case studies that illustrate industry's response to the need to minimize its generation of hazardous waste.

T H E HAZARDOUS WASTE REDUCTION G R A N T PROGRAM

Case studies from the Hazardous Waste Reduction Grant Program include:

the application and evaluation of a new computer software system to track hazardous materials and hazardous waste generated. The payback period for this system, installed at a major university, was approximately six months (based on labor savings alone). The implementation of this system resulted in a concerted effort to find waste minimization opportunities and implement cost- effective measures;

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thedemonstra- tion of a process to purify perchloroethylene to a level that would allow dhwt reuse by the dry cleaning industry. This process was successful. The company’s payback period for this process was approximately eight months;

thedevelop- ment of commercially useable solder strippers that do not contain toxic ingredients (for the printed circuit board industry);

thedemonsm- tion of a

process to reclaim hazardous foundry sands. This process has eliminated the disposal of all spent sand and has reduced this company’s purchase of virgin sand by about 800 tons year. The payback period for the system is less than two years; and

a description of the Department’s use of waste minimization conditions in an enforcement action.

T H E WASTE REDUCTION INNOVATIVE TECHNOLOGY EVALUATION (WRITE) PROGRAM

A case study is presented that demonstrates the use of an Advanced Reverse Osmosis System (AROS) on a double counterflow rinse tank system. The project’s goal was to determine if the system could be operated to reclaim and reuse Watts nickel bath and rinsewater and to reduce the generation of

hazardous plating sludge generated from the existing wastewater precipitation system. The process was successful. Cost savings occurred in the following areas: 1) water and sewer costs, 2) chemicals for precipitation, 3) disposal costs, 4) deionized water costs, and 5 ) recovered Watts nickel plating bath costs.

Although the payback period in this case study was estimated at four and one-half years, the unit was operated at less than 10 percent capacity, resulting in a lower volume of movered plating bath solution and rinse water. A payback of approximately one year would have been realized if the AROS had operated near capacity.

T H E C I M O F LOS ANGELES’ HAZARDOUS AND TOXIC MATERIALS (HTM) PROGRAM

Three case studies from the City of Los Angeles’ HTM Program illustrate the City’s response to the Mayor’s Award of Excellence for Pollution Preven- tion. In these case studies:

the City’s Department of General Services Building Maintenance Division phased out its use of solvent- and lacquer-based paints and thinners, specifically to comply with South Coast Air Quality Management District regulations, reduce disposal costs, and prevent employee health risks.

the City’s Hyperion Treatment Plant instituted a plant-wide strategy to preserve the environment and save money, through waste minimization. Waste minimization was achieved through:

instituting a task force, developing and implementing a tracking system,

0 examining and changing existing waste accumulation and storage practices, and identifying and implementing reuse and recycling opportunities.

By instituting these measures, the city realized a 64 percent reduction in waste management costs.

the City’s Department of General Services installed chlorofluorocarbon (CFC-12) recycling equipment in all municipal fleet repair facilities. The payback period for this measure is estimated to be one and a half to two years.

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CHAPTERTHREE: REDUCING DISCHARGES O F POLLUTANTS TO WATER

The State’s water quality control programs have instituted a wide variety of approaches to promote pollution prevention. This chapter discusses both industrial discharge and nonpoint source reduction programs.

Publicly owned treatment works in the South San Francisco Bay area have been implementing focused pollution prevention programs, largely due to National Pollutant Discharge Elimination System (NPDES) permit requirements. In addition, the San Francisco Bay Regional Water Quality Control Board has established a region-wide pollution prevention program. This program requires that dischargers develop and implement pollution prevention plans. Other State programs require the development of pollution prevention plans for stormwater runoff, and best management practices for nonpoint sources.

* Case studies from local publicly owned treatment works illustrate industry’s response to these requirements.

PAL0 ALTOS TOXICS REDUCTION PROGRAM The City of Palo Alto’s NPDES permit required it to reduce the toxicity of its treatment plant discharges. As part of its plan to meet this requirement, the plant developed a source reduction program, initially focusing on reducing silver discharges. Due to the new program, the maximum silver discharge to San Francisco Bay was reduced from 14 parts per billion in 1989 to 2.4 parts per billion in 1991. This focused program is helping to eliminate the need for additional treatment equipment (and operating costs) that would add an estimated $20 million per year to the plant’s current annual operating costs.

THE SAN IOSEISANTA CLARA WATER POLLUTION CONTROL PLANT

Three case studies from the San Jose/Santa Clara Water Pollution Control Plant (a publicly owned treatment works) illustrate industry’s response to waste minimization requirements imposed by this plant’s “DES permit:

at an electroplating shop, product substitution was used to convert zinc cyanide plating baths to alkaline zinc solutions. Additional source reduction and water conservation efforts have resulted in less pollutants discharged into the sanitary sewer and less use of water and treatment chemicals.

a small computer development lab was rede- signed so as to handle changing chemistries. The lab has discontinued its use of CFC solvent as a degreasing agent, using instead a water soluble substitute in a new cleaning machine. Plating process chemistry has been modified to increase efficiency, and procedures modified to prevent excess dragout from plating baths. Good housekeeping practices have been instituted to prevent the unnecessary generation of wastes.

waste segregation was used at a semiconductor manufacturer to facilitate the treatment of fluoride wastewaters from the fabrication area. Source reduction measures additionally implemented included:

the installation of high pressure spray nozzles, the installation of covers to prevent fluoride fumes from reaching the fume scrubbers, the installation of air aspirators to reduce wastewater volume, and the installation of a vertical tube wash, which recycles hydrofluoric acid internally.

THE CITY OF SUNNYVALE’S WASTE MI N IM IZATION P ROC RAM The City of Sunnyvale’s Water Pollution Control Plant was required by the San Francisco Bay Regional Board to reduce its discharge of copper, nickel and lead to the sanitary sewer system. Its pilot waste minimization program includes both public education and the preparation of waste minimization plans by industrial dischargers. dc

Included in this section is a case study of Hewlett- Packard’s company-wide waste minimization program, which focused on copper, lead, and nickel as pollutants of concern. Implementation of this program resulted in an approximate savings of over more than $100,0o0 a year through treatment improvements and $1 10,0o0 through plating line consolidation, as well as reduced corporate liability for these and other processes.

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COUNTY SANITATION DISTRICTS O F ORANGE COUNTY

Three case studies are presented from the County Sanitation Districts of Orange County:

at an organic chemical company, which formu- lates and fills aerosol containers with a variety of janitorial, industrial and household chemical cleaning products, the following waste minimization strategies were implemented:

water phases are now batched in the same

batch volumes are increased before washout

if a formula group batch change is required in

tanks without washouts;

is required;

a tank, deionized water is used for tank washout. The rinse/washout is recycled; washouts and leftover active ingredients are saved for the next batch; and a batching schedule that maximizes rotation of compatible products is used.

Avoided capital costs total approximately $100,000, and avoided operation and waste treatment costs are estimated at approximately $25,000 annually. In addition, costs were eliminated or reduced in the following areas:

transportation and disposal of offsite wastes, compliance costs for permits, monitoring and enforcement of approximately $5,000 annually,

reuse, and

sewerage system.

production costs through recycling and

$1,000 through eliminating the use of the

a company that strips paint off large parts and old automobiles has reduced its waste generation and saved approximately $30,000 in avoided capital costs, $7,000 in annual operational costs, and approximately $2,000 in reduced permits, monitoring and enforcement costs. These cost savings were realized through operational and process modifications made at the facility.

a tomato processing company, which was discharging excessive amounts of wastes with a high biological oxygen demand (BOD) to the Districts' facility, instituted process and procedural modifications that resulted in the following:

a 25 percent reduction in BOD, an approximate 20 percent reduction in

avoided onsite capital and operational waste

0 cost savings of approximately $1 million due

water usage,

treatment costs of about $2 million, and

to reduced use of the sewerage system.

CHAPTER 4: AIR EMISSIONS MINIMIZATION

The existing regulatory program for point and nonpoint air emissions includes many activities that are considered to be pollution prevention. Chapter Four contains a description of these programs, including the "Toxic Hot Spots" program, the Criteria Pollutants Program, the institution of regulations to reduce smog-forming components found in consumer products, and motor vehicle- related measures. These programs have resulted in product reformulations, process modifications, equipment redesign, and the institution of improved housekeeping procedures. Also described in this chapter is the Air Resources Board's chrome plating pollution prevention demonstration project, where a combination of source reduction and treatment options were evaluated in the interest of meeting strict emissions standards.

Case studies are presented from Southern California Edison's Clean Air Coatings Technology Program.

A company that makes signal warning systems for railroad grade crossings now saves an estimated $18,000 a year due to the installation of an ultraviolet (UV) curing technology. The company saved money, increased production, and kept air emissions to acceptable levels.

A manufacturer of specialized trucks and utility beds, under pressure to reduce the amount of VOCs emitted through spray painting operations, began using high solids coatings. This changeover solved the emissions problems and at the same time significantly reduced the amount of coating required to cover each cab and chassis.

The Los Angeles Times, which manufactures and coats its own newspaper racks, switched to powder coating and infrared curing. This operational change enabled the Times to achieve

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compliance with air quality regulations, meet conservation goals, and maintain its positive public image.

A manufacturer of swatch and sample books for the textile industry installed a UV system to replace one of its conventional solvent-based printing lines.

CHAPTER FIVE: S O L I D WASTE MI N IM I ZATl ON

The California Integrated Waste Management Board was established to coordinate the implementation of new solid waste management priorities. These priorities shift the focus away from reliance on landfill disposal of wastes and toward source reduction, recycling, and composting. Chapter Five describes these new directions in solid waste management.

CONCLUSION

While the Department of Toxic Substances Control has been widely recognized for its pollution prevention efforts, the other Cal/EPA boards and departments, as well as the local environmental regulatory agencies, have been equally vigorous. This has provided California with an effective multimedia approach. With CalEPA’s efforts to coordinate these activities, especially in the prevention of unwanted media transfers of pollutants, California can move to the forefront in pollution prevention.

Clearly, pollution prevention is the exciting new direction for governmental environmental regulatory programs. The promise that pollution prevention holds is that economic development and environmental protection are not mutually exclusive. This report demonstrates the effectiveness of govemmental pollution prevention programs in encouraging, requiring, and assisting industry in implementing pollution prevention approaches.

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POLLUTION PREVENTION IN CALIFORNIA

T h e California Health and Safety Code, Article 7, Section 25 17 1, directs the Department of Toxic Substances Control to

. . .prepare and issue to the public a report that contains an assessment of the best available technologies for the treatment, storage, recycling, source reduction, and disposal of hazardous waste. . .

In fulfillment of that directive, this report is prepared by the Department of Toxic Substances Control’s (Department) Alternative Technology Division (Division).

The “best available technologies” for hazardous waste management are found in approaches that focus on preventing the generation of hazardous pollutants. Therefore, this is a report on the status of pollution prevention programs in California. Pollution prevention is a multimedia approach that eliminates or reduces the generation of pollutants at the source, thereby reducing the need to manage those pollutants. This approach is radically different from the previous “end-of-pipe” pollution control approach most often mandated by environmental regulations. Pollution prevention is a relatively new term in the field of environmental regulation. Pollution prevention programs represent a critical shift in our approach to protecting the environment.

The traditional approach to dealing with the unwanted byproducts of these activities has been to send them “away”, to “somewhere else”. Typically, our air, water, and land were the recipients of these byproducts. Before the 1970’s, it was felt that such disposal had minimal associated costs. We now have substantial evidence that such disposal is not “free” or even “cheap”; in fact, there are significant costs associated with such activities. We have learned that, indeed, there is no “away”.

In recognition of the increasingly evident and substantial costs of the “free” disposal of hazardous waste to land, emissions of toxic constituents to the air, and discharge of toxic solutions to surface and ground waters, sizable bodies of statutes and regulations were created at the federal and State levels to both control the management of wastes and clean up the problems created by past mismanagement. In essence, these statutes and regulations, as represented by hazardous waste control laws, the superfund laws, and the clean air and water acts, among others, have “internalized” the previously externalized costs associated with the generation and unregulated disposal (into the air, water, and land) of pollutants. This system of regulation has gone far to place a more appropriate value on the “services” provided by natural environments @e., as a provider of resources, and as a “sink” for waste products), values not accounted

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for in traditional economic analyses. David Pearce, Ani1 Markandya, and Edward B. Barbier, in their book Blueprint for a Green Economy, explain the concept:

The elementary theory of supply and demand tells us that if something is provided at a zero price, more of it will be demanded than if there was a positive price. Very simply, the cheaper it is the more will be demanded. The danger is that this greater level of demand will be unrelated to the capacity of the relevant natural environments to meet the demand. For example, by treating the ozone layer as a resource with a zero price there never was any incentive to protect it. Its value to human popula- tions and to the global environment in general did not show up anywhere in a balance sheet of profit or loss, or of costs and benefits.’

POLLUTION PREVENTION AND SUSTAINABLE DEVELOPMENT

The generation of pollutants is a result of ineficient production. Largely because of the lack of accounting for environmental value described above, a linear system (of production) has developed. Raw materials go in one end, products and wastes come out the other. In contrast, natural systems operate in a circular fashion. There is no such thing as “waste” in the total system: materials exiting one system are input materials for another. A simple example: oxygen, a byproduct of photosynthesis, is a requirement for animals’ respiration. Carbon dioxide, a byproduct of respiration, is required for photosynthesis. Thus, materials circulate through the biosphere. Manufacturing processes must strive to mimic natural processes in order to “close the loop” on the generation of wastes.

Pollution prevention is an attempt to replicate this natural, circular flow of materials, within the unnatural world created by humans. Such a system would represent the most efficient use of resources possible. For wastes generated despite effective source reduction measures, recycling further maximizes use of resources.

This new approach significantly alters the relationship between regulators and the regulated community. Because pollution prevention is intrinsically beneficial to industry, i.e., it increases efficiency, and, therefore, competitiveness, govemment’s promotion of pollution prevention as the preferred waste management approach actually places govemment, industry, and environmental organizations on the same side of the fence, no longer adversaries.

The focus of California’s pollution prevention programs, source reduction and recycling, is essential because of the almost overwhelming pressure within industry to invest in “tried and true” end-of-pipe environmental solutions (i.e., treatment or control technologies). Government, by regulating the discharge of pollution at the end of the pipe, has in part helped to institutionalize the end-of-pipe approach. Government should play a role in helping “push” pollution prevention as a more appropriate production philosophy. Govemmental pollution prevention programs can best counteract the pressure to invest in end-of-pipe pollution solutions by demonstrating the economic and environmental benefits of a source reduction approach, making technical information available, and providing technical assistance to those attempting to reduce their generation of pollutants. Michael E. Porter, in his article “The Competitive Advantage of Nations”, argues that

Government’s proper role is as a catalyst and challenger, it is to encourage-or even push-companies to raise their aspirations and move to higher levels of competitive performance. . . Government policies that succeed are those that create an environment in which companies can gain competitive advantage. . .z

Pollution prevention is such a policy. Pollution prevention as a production philosophy also conforms to the ideals of sustainable development. Many definitions of sustainable development exist. Pearce et a1 offer a variety of definitions, which include the following concepts:

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The value of the environment Sustainable development involves a substantially increased emphasis on the value of natural, built and cultural environments. This “higher profile” arises either because environmental quality is seen as an increasingly important factor contributing to the achievement of “traditional” development objectives such as rising real incomes, or simply because environmental quality is part of the wider development objective of an improved “quality of life”.

Extending the time horizon Sustainable development involves a concern both with the short- to medium-term horizons, say the five to ten years over which a political party might plan and implement its manifest, and with the longer-run future to be inherited by our grandchildren, and perhaps beyond.

Equity Sustainable development places emphasis on providing for the needs of the least advantaged in society (“intragenerational equity”), and on a fair treatment of future generations (“intergenerational eq~i ty”) .~

The central underlying theme integrating these three concepts is that “future generations should be compensated for reductions in the endowments of resources brought about by the actions of present generations.” In other words, each generation should bequeath to its succeeding generation the same amount of “environmental wealth” that it inherited.

GOVERNMENTAL POLLUTION PREVENTION PROGRAMS

Governmental pollution prevention programs can be voluntary or regulatory, or a combination of both. Because government does not have the authority (or, generally, the expertise) to regulate production activities, many existing programs are voluntary. These programs persuade businesses to consider and implement pollution prevention, largely through a combination of education, technical assistance, and financial incentives. Most of the Department of Toxic Substances Control’s waste minimization program uses the voluntary approach. The Department assumes that once hazardous waste generators take a serious look at waste minimization, that it will make sense for them, and that they will implement source reduction approaches. Indeed, the State’s hazardous waste source reduction facility planning law (“SB 14”), although mandating that companies subject to the law prepare and implement source reduction plans, does not authorize the Department to dictate which measures are selected, or their implementation schedules.

The regulatory approach can take many forms. Generally, governmental agencies do not require that companies implement specific source reduction approaches per se; rather, they use regulatory approaches as tools to push businesses toward source reduction. For instance, the inclusion of pollution prevention requirements in enforcement settlement agreements is becoming a more commonly used tool to facilitate pollution prevention. Similarly, pollution prevention requirements may be included in permit conditions. There are many examples of regulatory pollution prevention approaches in this report. For example, the program implemented by the County

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Sanitation Districts of Orange County uses enforcement settlements to encourage businesses to adopt pollution prevention options rather than invest in expensive pretreatment facilities.

HAZARDOUS WASTE MINIMIZATION

Pollution prevention programs originated largely in the hazardous and solid waste fields. This is partly due to the nature of hazardous and solid wastes: they can be easily seen and measured (by the truck load).

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Our capacity for land disposal of these wastes is observably limited. For these reasons, hazardous waste management agencies in Califomia, at both the State and local levels, have provided the foundation for the development of true multimedia programs. California’s hazardous waste minimization program has been conducted primarily by the Department’s Alternative Technology Division. Hazardous waste regulations, including the Superfund law, the Resource Conservation and Recovery Act, State and federal land disposal restrictions, and other laws and regulations provide both regulatory and economic incentives for eliminating or reducing wastes. In addition to implementing SB 14 (described above), the Department’s waste minimization program provides information and support to generators wishing to minimize their waste generation. (Chapter Two contains a full description of the Department’s waste minimization activities.)

Local government work in this area is significant. City and county environmental health agencies, as well as fire departments and utility districts, work directly with generators of hazardous waste. In California, the Department works closely with local agencies to support their work with generators. In general, the Department finances research and development, develops pollution prevention educational and technology transfer materials, provides speakers for workshops and other events, develops and administers symposia and training, provides funding, and helps organize local government programs. Local government’s role is to

Plating operator allows paints to drip onto a bridge that allows dragout to f low back to plating tank.

work directly with industry to help it reduce its waste generation, while the State program directly supports these efforts.

REDUCING POLLUTION DIZCHARGCD TO WATER

Most of the regulatory activities of the State Water Resources Control Board and nine Regional Water Quality Control Boards have focused on end-of-pipe treatment. However, because of localized water quality problems, some National Pollution Discharge Elimination System permits recently (within the last five years) issued by the regional boards have included waste minimization program requirements. In addition, the San Francisco Bay Regional Water Quality Control Board initiated a focused pollution prevention program to reduce both point and nonpoint sources of toxic discharges to the south San Francisco Bay, because of the lack of natural cleansing (i.e., flushing) in the South Bay. Dramatic reductions of toxic discharges have been achieved due to these programs.

Currently being implemented by the State Water Resources Control Board is the storm water permit program, which will require all facilities that discharge industrial storm water to, among other requirements, develop and implement a storm water pollution prevention plan. And, nonpoint sources of pollution are being addressed by the State Water Board through the development and implementation

of pollution.

Increasing the transfer efSiciency in paint

reducing the generation of hazardous sludges. applications can reduce air emissions as well as of best management practices that prevent the creation

6

(Chapter Three contains a description of the pollution prevention activities currently taking place in the water pollution control agencies.)

AIR EMISSIONS MINIMIZATION

In the field of air emissions, point source emissions have been regulated through the use of “control technologies”. There has traditionally been no differentiation between end-of-pipe and in-process controls in the air regulation field. For example, the use of certain chemicals has been banned (“sunsetted”). This approach forces the development of alternatives-input substitutions or product reformulation-both considered to be pollution prevention strategies.

Controls have been mandated in order to meet specific emission concentration requirements for subject constituents. For example, the Air Resources Board’s Compliance Program provides assistance to local districts in conducting more comprehensive, consistent, and accurate compliance inspections, and provides industry with information and tools to help them become aware of how to stay in compliance. The Air Resources Board’s publication “Surface Coating Operations-Metal Parts and Products” recommended control strategies include many pollution prevention approaches. Such approaches include: requiring the use of low VOC coatings

(i.e., input substitution) and providing for exemption from the required use of low VOC coatings only for very small sources. This category includes the use of high solids coatings, water-borne coatings, powder coatings, electro/auto deposition, electrodeposition, autodeposition, ultraviolet light, electron beam and infrared radiation. Another approach is to require high transfer efficiencies for the majority of coating applications (Le., process modification). This includes using air atomized spray, air spray, air-assisted airless spray, high volume low pressure spray (HVLP), and electrostatic spray equipment. All of these recommendations are considered to be pollution prevention. (A description of these and other activities related to pollution prevention in the air regulatory programs is contained in Chapter Four.)

STATUS OF POLLUTION PREVENTION ACTIVITIES IN CALIFORNIA

Environmental regulation in California has been characterized primarily by its demarcation into medium-specific statutes and regulations. This is in large part due to the environmental compartmentali- zation of the federal environmental laws that are implemented through State programs. Accordingly, environmental regulatory agencies have evolved to be primarily medium-specific. This compart- mentalization extends to the local government level,

t

7

where environmental health agencies assist the Department in administering hazardous waste laws, publicly owned treatment works are regulated by the regional water quality control boards (and so pass on the regulatory program to their industrial dischargers), and air pollution control districts or air quality management districts work with the Air Resources Board to regulate industries emitting air pollutants.

Although there is much crossover and information exchange between these agencies, true multimedia pollution prevention requires that California’s regulatory agencies continue to stress communication and coordination. In July 1991, the first step of that process was taken: the creation of a multimedia environmental regulatory agency, the Califomia Environmental Protection Agency (Cal/EPA). This agency has brought together the Department of Toxic Substances Control, the State Water Resources Control Board and the nine Regional Water Quality Control Boards, the Air Resources Board, the Integrated Solid Waste Management Board, the newly created Department of Pesticides, and the Office of Environmental Health Hazard Assessment into one agency, in order to facilitate increased coordination. Pollution prevention is high on the list of priorities for the new agency.

Most of the Department of Toxic Substances Control’s work in the area of waste minimization has been single-medium in focus. There have, however, been some pioneering efforts in the area of pollution prevention conducted in the past two years. With the award of a Pollution Prevention Incentives for States (PPIs) grant from the U.S. EPA, the Department embarked on an ambitious program to promote multimedia pollution prevention through pilot programs at the local govemment level. (See sidebars pages xii, 7.)

The U.S. EPA was looking for projects that address the problems of media transfer of pollutants. In addition, it wished to promote the transfer of pollution prevention strategies and technologies to industry. In California, the point of contact between small- and medium-sized generators and regulators often occurs at the local govemment level, so it was imperative to actively involve and support local governments in any outreach programs.

Ultraviolet curable coatings can significantly reduce the release of volatile organic compounds into the atmosphere.

The program, although still ongoing, has succeeded in many of its goals. Over 300 inspectors from various agencies attended the pollution prevention technical training sessions. The Technical Educational Assistance Model (TEAM) Project was also very successful. Of particular note was the TEAM Project’s experience in identifying overlaps in the regulatory program, through its multimedia, multiagency committee work. Even more promising, the multiagency committees established in the three counties implementing the TEAM Project have elected to continue in order to promote pollution prevention and multiagency coordination.

LOCAL GOVERNMENT POLLUTION PREVENTION EFFORTS

Pollution prevention at the local level has also been led by the hazardous waste regulatory programs. Ventura County began its landmark efforts in 1986 when it established a focused waste minimization program via a grant from the Department of Toxic Substances Control. This program reduced Ventura’s generators’ hazardous waste by 25 to 70

8

percent (uncertainty due to one-time generation of wastes, business closures, and data variability) and provided the model other programs have subsequently built upon.

Many local government programs now conduct waste minimization activities. In an effort to share information and increase coordination, three pollution prevention committees have formed. These (geographically determined) committees meet on a regular basis to discuss issues specific to local government pollution prevention programs, hear speakers from industry talk about their program implementation, and share information. (Further information regarding these committees is presented in Chapter Two.)

T H E GREEN LIGHTS PROGRAM

One of the first initiatives of Cal/EPA is the Green Lights Program. Green Lights is a program sponsored by the United States Environmental Protection Agency to encourage corporations, governments and other entities to install energy- efficient lighting technologies which dramatically reduce energy consumption and deliver the same or better quality lighting. Under this voluntaw, nonregulatory program, facilities are upgraded with energy-efficient lighting wherever it is profitable and maintains or improves lighting quality.

Green Lights produces multiple benefits by addressing critical issues of energy efficiency, pollution prevention, and economic competitiveness. Corporations, governments, and other entities that make the commitment to Green Lights profit by lowering their electric bills, improving lighting quality, and increasing worker productivity. They will also reduce the air pollution caused by electricity generation, which includes carbon dioxide, sulfur dioxide and nitrogen oxides.

California was the first state to become a Green Lights partner. Governor Wilson, on behalf of the State, signed a Memorandum of Understanding with the U.S. EPA on May 20,1991. As a partner, California agreed to assess existing lighting within State-owned buildings during the next five years and retrofit those buildings with energy-efficient lighting technologies, where economically feasible. The Office of Energy Assessments within the Department

of General Services is in charge of retrofitting the State upgrades. In addition, Cal/EPA agreed to solicit corporate participation in the program and publicize the program through various events and activities. The California Energy Commission also agreed to help publicize the program.

Changing to more efficient lighting will save California approximately three billion kilowatt-hours each year. This savings in electricity translates into a $255 million savings yearly in taxpayer-funded energy costs once all of the State-owned spaces are upgraded.

Environmentally, this increased energy efficiency in State buildings translates into the prevention of significant amounts of pollution. It is estimated that by installing energy efficient lighting technologies, we can prevent the release of 2.1 billion pounds of carbon dioxide, 1.99 million pounds of sulfur dioxide and 6.5 million pounds of nitrogen oxide. Also eliminated will be unnecessary waste and pollution associated with power generation, such as boiler ash, scrubber waste and waste from coal mining.

Finally, Green Lights is a voluntary program in which the public and private sector work together to increase the competitiveness of the State and maintain its natural environment at the same time. By becoming a Green Lights partner, the State sets a good example for other states around the country and corporations within California. Green Lights is proof that economic competitiveness and environmental protection can occur simultaneously.

Results to Date California’s 28 corporate partners include ARCO, Bank of America, Bechtel, Hewlett-Packard, Lockheed, Mattel, Ricoh Electronics, SAIC, Transamerica, and Western Digital. All five major electric utility companies in the State have signed on as Green Lights partners. Each of these utilities have rebate programs in place for lighting, which make energy-efficient lighting even more attractive.

Within California, we are currently in the process of installing energy efficient lighting throughout State buildings as per our commitment to the U.S. EPA. The Department of General Services is in charge of this process, while Cal/EPA works closely with the

9

Office of Energy Assessments regularly in order to facilitate installation. CalEPA has also met numerous times with the Sacramento Municipal Utility District, the Office of Energy Assessments, and the Office of Real Estate and Design Service to determine the best strategy to install Green Lights in State-leased facilities. This includes ensuring the availability of utility rebates, and correctly identifying and marketing the Green Lights Program to the major landlords of State-leased space.

To date, Califomia has upgraded 18.7 million square feet in State-owned facilities. This number represents 14.8 percent of the State’s total and a savings of 27,894,000 kwh per year. This kilowatt hour figure constitutes four percent of the State’s total energy bill. The State has also surveyed and funded an additional 8.1 million square feet of office space to be completed this year. To further the State’s efforts as a Green Lights partner, over eight million dollars in lighting upgrades for State facilities in Sacramento will be funded by energy efficiency revenue bonds administered by the Office of Energy Assessments and include over $2.85 million in lighting rebates to be given to the State from the Sacramento Municipal Utility District.

ISSUES CON FRONT1 N C POLLUTION PREVENTION PROGRAMS

Significant issues still need to be addressed by those advocating pollution prevention as the preferred waste management approach. The definition of pollution prevention is one such important issue. This section will discuss three other important issues: the barriers to pollution prevention; the measurement of pollution prevention (actual reductions in waste generated) and the evaluation of pollution prevention program success; and the issue of the transfer of pollutants from one environmental medium to another.

BARRIERS TO POLLUTION PREVENTION

The shift from end-of-pipe waste management and pollution control to waste minimization and pollution prevention is not without its obstacles. However, in some ways, the barriers to pollution prevention are similar to those of any other major change in business practices. The recognition of the hazards, liabilities, and costs associated with hazardous waste

generation is relatively new to the industrial community, and there are significant limitations on available financial resources, information, and technical capabilities. Pollution prevention can be further limited by institutional barriers due to the significant investment, both by regulators and industry, in end-of-pipe solutions to pollution. The four major types of barriers to pollution prevention are described below.

Financial barriers Generators may lack the available capital to implement costly equipment changes and process modifications. Some strategies require extensive research and experimentation, such as when input substitutions are considered. Accounting systems that hide the true costs of generating pollutants can serve as disincentives to implementing pollution prevention strategies. Companies should adopt a thorough waste management cost accounting system to assess the feasibility of pollution prevention for their facilities. Many significant opportunities to reduce pollution require little or no significant capital outlay or equipment changes. Improvements in housekeeping, procedural changes, and inventory modifications can reap significant benefits.

Informational barriers Companies generating pollutants may lack knowledge of pollution prevention methodologies and regulatory requirements, or lack the technical expertise to institute pollution prevention strategies. Govemmental pollution prevention programs should provide such information.

Technology barriers Technology limitations should not generally limit businesses from implementing pollution prevention strategies. In some cases, however, the lack of specially designed equipment and technical expertise can impede the changeover to practices that generate less waste or recycle what is generated. Govemmental programs that sponsor technology development, demonstration and commercialization can help ameliorate this barrier.

Institutional barriers Companies that emit pollutants sometimes are unable to devote attention to assessing their operations for pollution prevention opportunities because they are

10

putting so much energy, money and time into complying with existing regulations and keeping ahead of new regulations.

Lack of regulatory flexibility can be a problem. For example, small quantity hazardous waste generators are sometimes caught between the regulators and the recyclers. While regulations limit the amount of waste they can accumulate onsite, recyclers often require large quantities of waste to qualify for their services. Moreover, fluctuations in market values of virgin stock can cause unpredictable changes in the demand for recycled raw materials.

Other disincentives include extensive permitting requirements and restrictions on onsite treatment/purification of pollutants destined for recycling. Finally, in some cases, management is simply not willing to devote company resources without regulatory incentive^.^

MEASURING POLLUTION PREVENTION

Evaluating the success of implemented pollution prevention strategies is problematic. Existing data bases do not help us evaluate the results of pollution prevention. For one thing, simple volume/mass reduction does not necessarily represent a lessening in the hazard posed to the public and the environment, which is a key goal of governmental programs. Even though concentrating pollutants is not considered to be pollution prevention, the temptation still exists to view volume/mass reduction as a reduction in hazard. Such a simplistic view may be misleading.

The many variables surrounding the generation of waste and pollutants discharged to air and water make it difficult to successfully generalize over the disparate operations currently being conducted. Meaningful quantitative evaluations of pollution prevention activities can only be done on a process- specific basis, and even then sometimes only over a limited time span (because conditions may change). For example, a drop in the total tonnage of waste produced and pollutants emitted may be due to a drop in production, a change in products produced due to market conditions, or a recession, rather than industry’s or government’s efforts to reduce waste.

Quantitative analyses of implemented pollution prevention programs are most accurate when viewed

on an anecdotal basis; i.e., at a particular facility (or, more often, associated with a specific process). When evaluating such facilities, the following factors should be considered:

the type of business;

a description of waste- and pollutant-generating processes/procedures;

the mass of waste and pollutants generated by each process, before program implementation;

the mass of waste and pollutants generated by each process, after program implementation;

changes in toxicity and/or reduction in risk;

the impetus for establishing the program;

any assistance (technical or financial) received through governmental pollution prevention programs;

pollution prevention program implementation costs; and

a description of the annual savings (of both actual and avoided costs) realized through the implementation of the pollution prevention program. This economic analysis should also describe costs incurred by the program.

It is difficult (if not impossible) to accurately associate specific govemmental actions with specific business decisions that result in the minimization of waste and other pollutants. Other considerations may play a significant part in the acceptance of pollution prevention in industry. Liability issues, land disposal restrictions and other environmental incentives, production changes, market conditions, tax laws, and other factors make it impossible to make clear cause- effect connections between governmental programs and actual pollution prevention by industry.

Despite these difficulties, it is essential that governmental programs establish meaningful measures of program success. Governmental pollution prevention program evaluations should focus on the following:

How many businesses have requested technical assistance?

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MEDIA TRANSFER OF POLLUTANTS

The transfer of pollutants from one environmental medium to another, sometimes as the result of environmental regulations, has been occurring €or years. The laws and regulations themselves may sometimes compartmentalize the environment in such a way that regulators can satisfy their own regulatory requirements by increasing, consciously or inadvertently, pollution in other environmental media (see sidebar at left). In order to truly protect the public health, to truly protect the State’s waterways, and keep California’s air clean, environmental agencies must adopt a multimedia pollution prevention awareness.

Agencies promoting pollution prevention must be particularly sensitive to the issue of environmental transfer. If we are to successfully change from an economy that produces waste and other pollutants to a more efficient economy that eliminates or minimizes such pollutants, we must not fool ourselves into thinking we are minimizing the generation of pollutants when, in fact, we’re merely transferring them from one environmental medium to another. A sensitivity to media transfer issues has become an integral component of the national movement toward the implementation of pollution prevention.

CONCLUSION

Although barriers to pollution prevention implementation exist, numerous factors nevertheless push both industry and government in that direction. The high costs of complying with environmental regulations, the need to maintain a good public image, and the need to maximize efficiency all help

For govemment’s part, many factors contribute to its interest in promoting pollution prevention. Helping businesses comply with the law and increase their efficiency are primary motivators. Pollution prevention is also good for govemment’s public relations. The public’s concem with its exposure to hazardous substances, combined with the increasing lack of capacity for the disposal of hazardous wastes, has created a public opinion climate that demands new approaches to dealing with pollution.

This report illustrates the beneficial results of the pollution prevention programs currently in place in California. Although the report describes only a portion of the activities currently performed related to pollution prevention, it does represent most types of governmental pollution prevention programs.

NOTES

Pearce, Markandya, and Barbier, Blueprint for a Green Economy, Page 5, Earthscan Publications Ltd., London, 1989 Michael E. Porter, “The Competitive Advantage of Nations”, Harvard Business Review, March- April 1990. Pearce, et al., page 2 Pearce, et al., page 3 The discussion of barriers to source reduction is largely derived from “Waste Minimization for Hazardous Materials Inspectors: Module I”, Califomia Department of Toxic Substances Control, U.S. Environmental Protection Agency, and University Extension, University of Califomia,

move industry toward pollution prevention. Riverside, January 1991, pp. 67-69.

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CALIFORNIA’S HAZARDOUS WASTE MINIMIZATION PROGRAM

California’s hazardous waste minimization program is conducted primarily by the Department of Toxic Substances Control’s Alternative Technology Division, with the assistance of the Department’s regional offices. The program has evolved from one concentrating on recycling, land disposal restrictions and treatment to one promoting source reduction as the preferred alternative to generating hazardous waste. Recycling was first defined in California statute in 1972; by 1976 the Vectorand Waste Management Section of the Department (then Health Services) began promoting the recycling of industrial wastes. In 1980, the Department instituted one of the nation’s first land disposal restrictions program, banning the land disposal of liquid hazardous wastes in California. Since that time, the Division’s waste minimization program has grown dramatically and is now recognized as one of the most advanced in the nation.

THE WASTE MINIMIZATION PROGRAM

Waste minimization program elements developed and administered by the Division include:

the development of waste stream-specific studies to identify waste minimization opportunities for solvent, oil, metal-bearing and incinerable

hazardous waste streams. For each of these waste streams, the study:

1) identified industries generating such wastes, 2) identified specific processes generating such

wastes, 3) identified specific waste minimization

opportunities, and 4) presented this technical information to the

public via symposia;

studies of twenty-one industries (generally dominated by small- to medium-sized business), to evaluate waste minimization opportunities. Waste minimization assessment checklists are provided for industry’s use;

the development of specific waste minimization strategies/technologies. This includes studies of chlorinated solvents use, waste minimization in airports, the development of a waste minimization video, the development of a “no waste” laboratory manual for high schools and colleges, and other projects;

joint projects with the U.S. EPA, such as the Waste Reduction Innovative Technology Evaluation (WRITE) program, where the Department has been working to identify, evaluate and demonstrate innovative engineering

and scientific technologies developed by industry for minimizing hazardous waste generation;

the “Hazardous Waste Reduction Award”, to recognize outstanding industry waste minimization accomplishments;

the development and administration of waste minimization training for Departmental and other agency staff;

coordination and assistance to local govemments (detailed below);

technical assistance to the Department of Commerce for its Califomia Hazardous Waste Reduction Loan Program;

development of the hazardous waste research database;

ongoing publication of the “Califomia Waste Exchange-Newsletter/Catalog”, which contains information related to hazardous waste recycling, reuse and recovery. In addition, the catalog portion is divided into two categories: wastes wanted and wastes available. Interested persons can place a listing in either of these categories; listings are coded to protect confidentiality;

ongoing publication of the “Directory of Industrial Recyclers”, which assists generators in complying with recycling requirements and lists authorized recyclers of hazardous wastes; and

ongoing assistance to the regulated community in the interpretation of the complicated recycling laws and regulations.

THE DEPARTMENTS WORK WITH LOCAL GOVERNMENT PROGRAMS

The Department supports the ongoing work of three local government pollution prevention committees by attending regular meetings, updating the groups on new publications available from the Department, and giving presentations. The constituents of each group are described below.

The Califomia Conference of Directors of Environmental Health (CCDEH) formed a

subcommittee in 1988 to explore waste minimization issues and promote program implementation. This southem Califomia committee, now called the Southem California Pollution Prevention Committee, typically includes representatives from the counties of Ventura, San Bemardino, Santa Barbara, Orange, and San Diego; the City and County of Los Angeles; the cities of Santa Monica, Irvine, Anaheim and Pasadena; and the Orange County and Los Angeles County Sanitation Districts.

In 1989, the Bay Area Hazardous Waste Reduction Committee (BAHWRC) was formed. Those attending include representatives from the counties of San Francisco, Alameda, Contra Costa, Santa Clara and San Mateo; the Cities of Berkeley, Hayward, and Newark; the publicly owned treatment works (POTWs) of Palo Alto, Hayward, and Sunnyvale; the East Bay Municipal Utility District; the Bay Area Air Quality Management District; the Bay Area Regional Water Quality Control Board; and other agencies.

In June 1990 the Central Valley Hazardous Waste Minimization Committee was formed. This committee affords a unique opportunity to guide the development of pollution prevention programs within some of the more rural jurisdictions. Participants include representatives from the counties of Sacramento, Nevada, Sutter, El Dorado, Yolo, and San Joaquin; the City of West Sacramento; and the Sacramento Public Works Department.

To further communication and statewide consistency in the application of local pollution prevention programs, the Department sponsors a yearly conference for representatives from all three regional committees, as well as Department and U.S. EPA representatives. To date, two such conferences have been held. The conference proceedings include “action plans” focusing on specific issues, such as training, how to institutionalize pollution prevention programs, educational and technical outreach for small quantity generators, and tools for assessing the effectiveness of pollution prevention programs, among others.

Coordination of the implementation of these action plans is occurring with the help of a new organization, the Consortium of Califomia Pollution

Prevention Committees, jointly sponsored by the Department and the U.S. EPA. The consortium meets quarterly and, in addition to coordinating the activities of the regional groups, serves to provide a unified point of contact between local pollution prevention programs and the Cal/EPA.

Local governments are taking the lead in the area of interagency coordination in the field of pollution prevention. These activities provide a model for other agencies that wish to coordinate pollution prevention programs.

AB 4294 To further support local government waste minimization programs, the Department is currently implementing AB 4294, which amends the Hazardous Waste Reduction Grant Program to allocate funding specifically to local government waste minimization programs. Fundable activities include:

the identification of the most significant hazardous waste streams in the city or county, and the businesses that produce them; ~

education of governmental agencies, community and industry groups, and individual businesses conceming the concepts of hazardous waste reduction;

the dissemination of information on best demonstrated available hazardous waste reduction, recycling and treatment technologies to businesses through workshops and educational materials;

waste stream-specific and process-specific waste reduction audits of businesses in the city or county; and

innovative methods to bring waste reduction techniques and practices to the attention of businesses in the city or county, including the use of technical consulting services for businesses of small and medium size.

Seven local agencies were identified to receive funding under this program. Current fiscal difficulties have prevented the Department from funding all of these projects at this time.

COORDINATING STATE POLLUTION PREVENTION PROGRAMS

One of the Department’s and Cal/EPA’s pollution prevention goals for 1992-93 is to increase communication and coordination at the State level. Four State-level roundtables have been held to discuss pollution prevention issues. The focus was on identifying gaps, overlaps and conflicts between medium-specific environmental regulatory programs, as they relate to the implementation of pollution prevention programs.

NEW PROGRAMS: INCINERABLE HAZARDOUS WASTE AND SB 14

There are two important but relatively new programs currently being implemented by the Department, the Incinerable Hazardous Waste Minimization Project, and implementation of the Hazardous Waste Source Reduction and Management Review Act of 1989 (“SB 14”).

The Incinerable Hazardous Waste Minimization Project The Incinerable Hazardous Waste Minimization Project is a focused response to California’s lack of capacity for managing “incinerable” wastes, or wastes for which incineration is the recommended management method. This lack of capacity was identified in California’s 1989 Capacity Assurance Plan. By targeting incinerable wastes, the Department focuses on meeting the State’s capacity assurance obligations while at the same time addressing a waste stream that has a high degree of reduction potential.

Recognizing that the siting of commercial incinerators is a very difficult process, the Department has embarked on an ambitious pollution prevention program involving the State’s top generators of incinerable waste. This effort involves identifying and notifying these generators of the State’s interest, and helping them reduce their waste, with a statewide goal of a 50 percent reduction by the end of 1992.

The Department has offered to work with these companies to achieve their goals. Among the incentives offered by the Department are permitting assistance, technical assistance, news media support,

17

and regulatory assistance. Permitting assistance takes the form of granting priority to the permits submitted by these companies (although the Department will not necessarily guarantee approval of the permit). The Department has also offered to aid facilities trying to resolve problems with other regulatory agencies. The Department will not act as a “consultant”, but will help facilitate the process. Technical assistance is also available from the Department, if requested by the participating facilities. The Department encourages all project participants to take advantage of these benefits by entering into a voluntary agreement with the Department. Thirty-nine of the fifty-five identified generators have entered into a voluntary agreement

to assist the Department’s Incinerable Waste Minimization Project. Table 1 lists the voluntary participants.

Most of these facilities already have a waste minimization program in place, such as Chevron’s “Save Money and Reduce Toxics” (SMART) Program, and Dow’s “Waste Reduction Always Pays” (WRAP) Program. All 39 signatories of the voluntary agreement have made significant reductions in wastes manifested offsite for treatment and disposal. Preliminary data indicate that this public/private cooperative effort is succeeding, and may be used as a model for addressing other wastestreams or environmental problems.

I Chevron USA 3C & 5K Disp

I Taft McClellan AFB Sacramento

SMUD Corp Yard Sacramento

Alameda Naval Air Station Alameda

DOW Chemical Pittsburg

E.I. Dupont DeNemours Antioch

FMC Corp-Ordnance Plant San Jose

Memorex Santa Clara

Romic Chemical Co. E. Palo Alto

Avon Refinery Martinez

Chevron USA Coalinga Coalinga

NEC Electronics Roseville

Witco Corp-Golden Bear Oildale

Chevron USA Inc. Richmond

Dexter Corp. Hysol Div. Pittsburg

Evergreen Oil Inc. Newark

IBM Inc. San Jose

Raychem Corp. Menlo Park

Tandy Magnetic Santa Clara

AAD Distribution and Drycleaning Vemon

CA Industrial PDTS Santa Fe Springs

Chevron USA El Segundo

Lockheed CA Co.-Plant B 1 Burbank

Oil & Solvent Corp. Azusa

Rockwell Int’l Plant 42 Palmdale

Douglas Aircraft Co. Long Beach

Rohr Industries, Inc. Riverside

Shell Oil Carson

Texaco USA Refinery Wilmington

Chevron USA Santa Barbara

Gillette Co.-the SMMC Santa Monica

Northrop Corp. Hawthome

Pacific Coast Lac4 Ellis Los Angeles

Douglas Aircraft Co. Long Beach

Mobil Oil Corp. Torrance

Rohr Industries, Inc. Chula Vsta

Steelcase, Inc. Tustin

Union Oil of CA Wilmington (2 facilities)

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The Department estimates that the Incinerable Waste Project could potentially result in a reduction of approximately 10,000 tons per year of incinerable wastes, with a commensurate reduction in the need for incineration capacity. Preliminary results show that California has met its goal for this project. Current analysis shows that incinerable wastes have been reduced to 48 percent of that generated and manifested for treatment and disposal in 1987.

While the quantities of incinerable wastes generated from existing industries in Califomia represent only a portion of the total hazardous waste stream generated in the State, their impact upon capacity assurance and facility siting cannot be ignored. The Department feels that it has taken the first step toward addressing the capacity shortfalls.

SB 14 The second new program for the Division is the implementation of the Hazardous Waste Source Reduction and Management Review Act of 1989, (commonly referred to as “SB 14”). This Act requires that generators that produce more than 12,000 kilograms (1 3.2 tons) per year of hazardous waste or 12 kilograms (.01 tons) per year of extremely hazardous waste take a serious look at source reduction as the preferred method of managing waste. Under this Act, on or before September 1,199 1, and every four years thereafter, generators are required to prepare a “source reduction evaluation review and plan,” which identifies all major hazardous waste streams at the generator’s site. For each identified waste stream, the generator must evaluate potentially viable source reduction approaches.

In addition to the evaluation review and plan, generators are also required to prepare a “hazardous waste management performance report,” which assesses the effectiveness of hazardous waste management procedures previously implemented by the generator, including recycling and treatment activities.

Beginning September 15,1991, and every two years thereafter, the Department must select at least two industrial categories for review. The Department reviews the selected plans and reports to ensure that they have been properly prepared by the generators.

Waste segregation improves potential for recycling.

The Department review also determines whether a generator has implemented the source reduction measures it designated as feasible in its plan.

New responsibilities for the Department stemming from SB 14 include:

expanding its technical assistance and research program to help generators identify and evaluate source reduction options;

establishing a data base and information system to track categories of generators and viable source reduction measures and other waste management practices identified in the plans and reports;

taking appropriate enforcement action to assure plans are prepared and implemented properly;

providing full protection of information contained in the required documents that the generator determines is a trade secret; and

offering special assistance to small businesses captured by the law.

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Enactment of SB 14 has moved California away from the traditional “command and control” program where the State sets standards. Rather, this law leaves substantive measures up to the generator, with the Department merely verifying that the required reports have been properly prepared. Preliminary reviews of selected plans and reports indicate that California industry has responded with significant reductions in offsite shipments of hazardous waste.

Results from a recent survey show that nearly one out of every two generators that prepared a source reduction plan has profited by the process, and has realized greater than a ten percent reduction in hazardous waste generation. Additionally, nearly one out of every ten realized reductions greater than fifty percent in the first year alone.

CASE STUDIES IN HAZARDOUS WASTE MINIMIZATION

The case studies included in this chapter come from the Department’s Hazardous Waste Reduction Grant

Each successive step represents a position closer to the preferred destination, the market place. It is possible for a project to enter the program at Step I and move through the design Step I1 to construction and evaluation at Steps 111 and IV, respectively. For projects to continue through the funding stages, they must prove to be viable at each phase of development. Upon successful completion of the evaluation phase, a project is poised and ready to compete in a market where performance and costs for regulatory compliance are key factors.

The grant program has produced useful information on technologies for reducing hazardous waste generation within manufacturing processes, as well as technologies for recycling and treating hazardous waste to reduce its volume, toxicity or mobility. The technological information developed through this program will assist industries adjusting to a production environment where environmental regulatory compliance plays a key role in keeping California industry competitive in a world economy.

REDUCTION G R A N T P R O G R A M

This grant program was initiated to provide economic incentives that foster the development and transfer of hazardous waste minimization technologies from the laboratory into the market place. Since the Hazardous Waste Reduction, Recycling and Treatment Research and Demonstration Act of 1985 was passed, the grant program has provided funding for 136 projects. For fiscal year 91/92, the Division is funding 17 projects for a total of $1,120,798. Awards are made to California companies, individuals, trade associations and public agencies that propose to demonstrate new hazardous waste reduction technologies.

Grant awards are made at four levels of development:

Step I feasibility study, Step I1 project design, Step 111 construction, and Step IV evaluation.

The Hazardous Waste Reduction Grant Program funded the application and evaluation of a new computer software system to track hazardous materials and waste generation. The software was installed on one of the University of California campuses that has many labs, each with an extensive inventory of chemicals. The software also has the ability to document handling and disposal costs for hazardous wastes generated by each lab.

In the past, institutions such as universities or hospitals have had difficulty or have been unable to accurately measure or track hazardous materials use. This information is necessary to determine waste minimization opportunities and also to correctly evaluate economic feasibilities. The objectives of this project were to track hazardous materials use and waste generation at institutions with multiple labs and multiple generators, and to study the effects of true waste management costs being charged back to generators. In other words, the project goal was to

determine if waste minimization would be achieved by providing generators with accurate data.

Technology As developed, the software uses pull-down menus. The system is available in English and Spanish, and was developed by the Boar’s Head Group in Santa Barbara, California.

Inventory data from each chemistry lab was entered into the system. Data entry was done electronically in the labs by either scanning a bar code on each bottle of reagent or other material, or by entering it manually on a Grid pad (which recognizes handwriting and stores the information automatically). At the end of each day of data entry, the Grid pad was downloaded into the main system. This completely eliminated traditional data entry and its inherent problems (such as data entry errors and the length of time required to enter the data). To further ensure accurate data, the Grid pad and software were programmed to convert entries into consistent units.

The use of each material and its container was then tracked. As requests for waste pick-ups were received by the environmental health and safety staff, containers and residual materials (waste) data were again entered into the Grid pad and matched to the original container, material, and generator. At this point, recyclable wastes were separated and the nonrecyclable wastes were sent offsite for disposal.

The software tracks not only the amount of each waste sent for disposal, but the volume taken up by its container. For example, a liter bottle of reagent sent for disposal, but only one fifth full, still consumes a liter of space in the lab pack. It also contributes a contaminated one-liter bottle to the amount of waste needing disposal. The software automatically calculates the percentage of a lab pack that the contents or container represent (system option), so that when the university is billed by the transport and disposal company, the appropriate amount can be charged back to the actual generator.

The software has additional capabilities that contribute to better waste management and environmental compliance. This includes project management software to help the user monitor

progress and to schedule inspections, etc. It also produces time cards for all employees entering data (using the Grid pad) so those costs can be attributed to the proper lab.

Results The time needed for data entry was reduced by two thirds by using the Grid pad instead of conventional data gathering and data entry. Also, the information gained by calculating the proportional costs of hazardous waste disposal for individual generators and labs provided the basis for an immediate 100 percent (proportional) increase in charges to generators. Additional increases in charges will be phased in until generators are paying actual costs of disposing of their wastes. The system also allowed the University to reduce the time spent on preparing monthly business and materials use reports from two weeks to eight minutes per month.

Cost Analysis The cost of installing this software tracking system at the university was $95,000 (partially funded by the Department). A smaller institution would have a proportionately lower system cost. Including ongoing data entry, the cost of maintaining the system is estimated to be $9,000 per year. The cost reclaimed from generators when actual costs are billed is estimated to be $150,000 per year. The avoided costs of more efficient data entry (Grid pad and bar code scanning) are estimated to be $175,OoO per year. Additional, but as yet unquantified, avoided costs include the costs of doing regulatory reports, recharging reports, and project management tasks. The somewhat intangible benefit of having accurate and current data is also an important consideration. Based on these costs, the payback period for this system is approximately six months (based on labor savings alone).

Conclusion Once the true costs of waste handling and disposal were known to generators, two things happened:

1) the University charged much more of the waste management costs back to the labs where the wastes were generated, and

2) the University immediately began looking for ways to minimize its wastes.

21

The University has already initiated a hazardous materials/waste exchange and is continuing to identify and evaluate other options.

This project has demonstrated that it is practical to monitor and track hazardous materials use and waste generation in large, complex organizations. The potential for waste minimization is increased when generators have accurate data arid monetary incentives to change their practices. Since individuals are, by nature, creative and innovative, these talents can be directed toward reducing materials use and waste generation. Additionally, accurate tracking at individual institutions can feed into larger scale data systems and can be the basis for managing future materials use, waste generation, emergency response and policy development.

Recommendations Government agencies responsible for implementing pollution prevention and technology transfer should make information on the availability of this type of software known to generators, possibly demonstrating its use in other settings.

Background In Califomia, there are over 3,700 dry cleaning operations. The majority of these dry cleaners use perchloroethylene (perc). Using onsite distillation units, dry cleaners distill their used solvent and generate a liquid waste product that contains over 40 percent residual perc. Commercial treatment facilities can recover a large portion of this residual perc using specialized distillation techniques. However, after distillation, small amounts of organic impurities, generated from the normal dry cleaning process, cause reclaimed perc to have an unpleasant odor. These impurities render the reclaimed solvent unusable to California’s largest consumer of perc-the dry cleaner. Currently the dry cleaner must pay to have this spent solvent removed at a cost of approximately $4.00 per gallon. This spent solvent is usually reclaimed to a lower grade purity than virgin perc and is resold to various operations as a solvent for metal surface cleaning. Unusable portions of spent perc may require incineration. Technichem’s objective was to develop a process to allow reclaimed perc of sufficient purity to be reused by dry cleaners.

Technology

Technichem Inc. designed and developed a process to purify perchloroethlyene (perc) to a level that would allow direct reuse by the dry cleaning industry. Reclaimed perc currently has a quality sufficient for use as a solvent in lower grade cleaning operations but not for actual reuse in dry cleaning.

This project had three main objectives:

. to establish operating parameters and design specifications for a commercial scale processing unit,

. to obtain bids on major equipment, and

. to obtain necessary permits for construction and operation of the system.

In an earlier study, Technichem researched advanced separation techniques to restore reclaimed perc to its original purity. Results of that study revealed that a combination batch fractional distillation and solid adsorption treatment could economically purify the contaminated perc to near virgin quality. At this purity level, it becomes a viable substitute for virgin dry cleaning solvent (see Figure 1). Bench scale units purified the reclaimed perc to 99.95+ percent purity, while recovering 95 percent of the available perc from the reclaimed solvent.

The process generates waste in the form of spent silica gel and liquid still bottoms. The still bottoms contain the separated hydrocarbon contaminants,

22

and can be used as a supplemental fuel for cement kilns. In order to reduce disposal in cement kilns, Technichem’s treatment system reduces the perc content in the still bottoms by increasing reboiler heat at the end of the distillation. As demonstrated in bench scale testing, the increased heat produced still bottoms with less than seven percent perc (by weight) and enabled almost all of the available perc to be recovered. However, as with all batch distillations, product purity decreases as a function of solvent recovery (i.e., as more perc is recovered, the reboiler becomes more contaminated, and the corresponding distillate becomes more contaminated). In the bench scale unit, the final perc fractions were unusable because of high concentrations of hydrocarbons. Consequently, in the third stage, the last perc fractions are isolated and temporarily stored. The perc is re-distilled with the next batch.

Economic Evaluation Treatment costs for a 450-gallon batch unit were estimated at 75 cents per gallon. Technichem estimates that a capital equipment investment of approximately $145,000 is necessary for a 450 gallon unit. Assuming one batch per day, nineteen working days per month, approximately 390 gallons of product per batch and a value of $3.50 per gallon for the purified perc, Technichem estimates a payback period of only eight months. Technichem concludes that the combination recovery system is both technically feasible and cost effective. (See sidebar page 24.)

Conclusions Dry cleaners are the largest users of perc in California. In fact, excluding exports and use by large chemical manufacturers in chlorofluorocarbon production (CFC-113), dry cleaning accounts for

FIGURE 1

COMBINATION DISTILLATION/ADSORPTION TREATMENT P ROC E 55

Batch Fractional Solid Adsorption 1- Distillation Unit 7 7

Contaminated PCE

Treatment I

InitiaK&-Boilina Fraction I Silica Gel

Filtration Unit Diaphragm Pump

23

over 80 percent of the perc consumed in the State. This fact emphasizes the need to develop a technology to encourage closed-loop recycling of perc in the dry cleaning industry.

The typical dry cleaner generates an average of nine gallons of liquid waste per month from distillation bottoms. In California, this results in almost 400,000 gallons of liquid waste generated each year. This liquid, often with 40 to 50 percent residual perc, annually results in over 180,000 gallons of perc that is not being recycled to its primary user. Development of a recovery method to properly purify the solvent would allow the recycling of over 2.4 million pounds of perc each year to its original users. The recycling loop would be complete. It is Technichem’s intent to continue on to the construction and operational phase of this project so that this recycling opportunity may be realized.

literature review with directed research utilizing an investigation optimization technique called fractional

The printed circuit board manufacturing process is comprised of nearly 80 steps. One major production step involves stripping solder from copper circuits by chemical means. Most solder strippers contain highly toxic fluorides and/or fluoborates, which are difficult to remove from wastewaters. To eliminate this source of toxic materials from printed circuit board wastewater, Applied Electroless Concepts (AEC) undertook the development of strippers without using toxic ingredients.

In addition to the primary goal of developing strippers free of fluoride and boron, AEC sought the development of strippers that would meet or exceed a wide range of commercially useful parameters. To do this, AEC integrated the results of a detailed

develop alternatives. However, increasingly restrictive environmental regulations involving land disposal and sewer discharges are forcing the printed circuit board industry to find and use less hazardous process ingredients. AEC’s principle investigator, Gerald Krulik, has an extensive background in the fields of printed circuit board production and waste treatment, and knew of no theoretical reason why commercially acceptable strippers could not be formulated without fluorides or fluoborates. He undertook this project, which involved the development and evaluation of alternative solder strippers at the laboratory scale. Large-scale commercial evaluation was not in the scope of this project; this evaluation is currefitly underway in a Step I1 (design) project. Preliminary results indicate interest from potential licensees.

24

FIGURE 2 SIMPLIFIED PORBAIX D I A G R A M FOR COPPER

I 1 I

- - -

- 2 1 0 1 2 3 4 5 2 9 I I I 1 I I I 2.2

20

1.8

1.6

1.4

1.6

1 "E A

-1.2

-1.4

-1.6

0.4 On6 1

-1.2

-1.4

-1.6

- - -

I I I I I , I S I

Corrosion

I I I I I I I -1.8 I

i 7 '"8 9 10 11 12

-1.8

\ 4 4.2 -' j 4 . 4

Strategy Description The project methodology consisted of several phases. The first was an extensive literature review of tin and lead chemistry, metal complexation behavior, patents on solder stripping and solder plating, solder plating chemistry, solder metallurgy, and commercial stripper technical literature. This information was combined with a review of Porbaix diagrams (see Figure 2) used to systematize electrochemical/pH behavior of the essential elements. Information on possible oxidants and their behavior towards each of the targeted metals was also collected and collated.

The experimental methodology focused on wide ranging screening experiments to narrow the range of

possible formulations for detailed work. Acid and alkaline formulations were extensively tested; near neutral formulations were tested less extensively (see Figure 3) for a summary of the first series of acid screening work). The best materials and approaches were then tested in more detailed and focused work. The results from each round of testing provided the input for the Fractional Factorial mathematical algorithms. These algorithms rank each experimental variable in terms of absolute response. The resulting responses are used to predict better values for each variable. These values are the basis for improved formulations. This procedure is continued until an optimized formulation is obtained. For each starting mixture of ingredients, an optimized solution is obtained.

25

FIGURE 3

S U M M A R Y O F ACID SCREENING WORK

ACID (SERIES 1)

I N no strip I = immersion line only P = partial strip F essentially full strip

FIGURE 4

SOLDER STRIP AND COPPER ETCH R A T E S

26

FIGURE 5

BATH LIFE OF TWO OPTIMIZED BATHS

nr = no reading

The tested formulations were evaluated based on the following parameters:

e

e

e

e

e

e

e

e

e

e

e

e

e

e

e

solution temperature, fume generation, rate of solder strip, number of process steps, capacity (maximum volume of solder per unit volume of stripper), rate of copper attack, visible solution characteristics, ease of rinsing, agitation requirements, ease of waste treatment, variation in strip rate over bath life, tin redeposition on the copper, ease of operation, stability of the solution, and shelf life.

Several of the optimized formulations met most of the minimum requirements for a commercially acceptable stripper.

For the first and second series of tests (screening tests), the Fractional Factorial variables were represented by constituent concentrations. For the second series, the formulations were based on the better formulations from the first round with the addition of complexing agents and stripping accelerators (non-oxidant type). From the results of the second series of tests, advanced optimization work was done. These formulations were based on the best formulations from the second series; however, instead of representing the Fractional Factorial variables with concentrations of single ingredients, one of these variables was represented by the best formulation. Then, varying combinations of this formulation and additional oxidants were tested. This resulted in a series of formulations termed K1. Taking this approach one more step

27

using the best K1 formulations resulted in the K2 series of formulations.

Results The best formulations are chemically stable and have stripping times of one to five minutes at room temperature for a standard solder thickness. The etch rate of the underlying copper is as low as 117 times less than the solder strip rate (see Figure 4). No immersion tin deposits form on the exposed copper and no residual film is left. The solutions rinse easily and completely from the surface, which has a slightly matte finish and can be immediately dried, plated, or otherwise processed.

schedules, increase shelf life, and develop better waste treatment and possible recycle methods. From this further work, a revised economic analysis should be performed. Some of this work has been completed, but results are not Yet available-

I A cost analysis was performed for four of the best formulations. The price of the strippers is estimated to be $10 to $35 per gallon, depending on the stripper and the price markup. These four strippers have a capacity of 30 to 40 square feet (at standard thickness) of solder per gallon (see Figure 5) . Therefore, stripper costs are predicted to be 0.3 to 0.7 cents per square inch. This range of costs per area stripped is comparable to existing commercial solder strippers. Most importantly, the formulations are biodegradable organics, and the rest of the components are nontoxic, and some are beneficial to waste treatment organisms. Overall, the best formulations appear to be more commercially attractive than most or all existing commercial solder strippers. Patents are pending on at least one of the formulations.

Limited production testing of one formulation showed favorable yet unoptimized results. At least two of the new formulations (patents pending) will be extensively tested in printed circuit board production. At least one company has expressed serious interest in manufacturing at least one formulation. The very low rate of copper attack will be attractive to high technology, very fine line circuit applications. These formulations can also be used to remove tin deposits and the thicker molten solder deposits.

Recommendations Further work needs to be done using actual production printed circuit boards to define possible problems, optimize bath life and replenishment

Introduction Foundries usually generate hazardous waste in the form of used casting sand that is contaminated with metals (from the metal castings) and organic compounds (from the sand binder(s). Typically, this sand is treated to immobilize leachable contaminants before disposal in a hazardous waste landfill. This project involves the reconditioning and reuse of most of the waste sand.

Foundry Process Many metal parts (e.g., sprinkler heads, pipe fittings, faucets, etc.) involved in everyday use are made from metal castings. Basic metal casting operations typically include pattern making, molding, core making, melting, pouring, cleaning, initial heat treatment, prefinishing and finishing, and sometimes a final heat treatment. The majority of hazardous wastes generated by the metal casting industry are from foundry operations.

A pattern is a specially-made model of the component to be produced, and is used for making the casting molds. Sand is placed around the pattern and is either rammed to the desired hardness for clay-bonded sands, or chemically hardened after light machine compaction for chemically-bonded sands. The molds are produced in halves in order to facilitate the pattern removal. When the halves are reassembled, a pattern-shaped cavity remains inside the mold.

Internal passageways within a casting are formed by using cores. Cores are made of sand and binder that

~

__

3 0

are sufficiently hard and strong to be inserted into a mold. Analogous to molds, core boxes are used for producing cores.

Casting production begins by melting the metal. Molten metal is poured into the mold cavity, where it solidifies in the space defined by the mold and cores. After removing the mold, the castings are usually finished by grinding, polishing and/or heat treatment.

Molding sand usually consists of four major materials: sand (85-90 percent), clay, carbonaceous material (such as crushed walnut shells), and water. Clay binds the sand, the carbonaceous material provides several functions (including oxidation protection for the metal), and water activates the clay for binding. Core sands are usually composed of

sand and a small amount of a resin binder, which partially decomposes upon heating by the molten metal. The lumps of sand and decomposed binder are often crushed and added to the mold sand to be reused.

Typically, much of the sand is reused; however, new sand and one or more of the other aforementioned materials are added to maintain the properties of the molds and the quality of the castings. This means some of the used sand must be removed from the process. This sand may be hazardous as determined by CCR Title 22, Article 1 1, and/oi 40 CFR Part 261. If this sand is a hazardous waste, and is destined for land disposal, it must meet federal or State treatment standards (depending on federal or State classification) prior to disposal.

FIGURE 6 S Y S T E M SCHEMATIC FOR FOUNDRY SAND

RECLAMATION S Y S T E M

1. 2. 3. 4. 5. 6. 7. 8.

Feed Hopper Tube Feeder Ball Mill Vibratory Feeder Bucket Elevator Magnetic Separator Vibratory Screener Bucket Elevator

13 20

9. Furnace Surge Bin 10. Furnace Screw Feeder 11. Bucket Elevator 12. High-Temp Rotary

Air Lock 13. Thermo-Scrubber 14. Recuperator 15. Particle Classifier

16. Sand Coder 17. Bucket Elevator 18. Post Scrubber Surge Bin 19. Post Scrubber 20. Pneumatic Transport 21. Reclaimed Sand Bins 22. Fabric Filter Baghouse 23. Baghouse Fan

31

Grant Project Description Fresno Valves & Castings (FVC) was awarded a Hazardous Waste Reduction Grant for the purchase and installation of a system that reclaims approximately 90 percent of the sand previously disposed. This system removes both organic (resin -and carbonaceous material) and inorganic (metals and clay) constituents from the sand, and also controls the size distribution of the reclaimed sand.

The process involves several steps. First, the spent mold and core sands are processed through a ball mill to remove larger metal fragments and reduce the sand to smaller, uniform particles. The sand is then passed through a magnetic separator to remove ferrous particles, and an air flotation separator to remove nonferrous metallic particles.

Next, the sand is conveyed into the preheat (top) bed of a three-bed fluidized furnace, a unit specially designed and constructed for the reconditioning of spent foundry sands. The preheated sand is gravity fed into the calcining bed. At approximately 1,600 degrees F, the resins are combusted, and the clay and remaining metallic particles are calcined (oxidized to a fine powder). The oxidized particles generated in this system are vacuum conveyed to, and collected in, a cloth-filter baghouse. The sand is cooled in a third bed, then scrubbed to remove any remaining oxides. The reconditioned sand is then stored, ready for use as mold or core sand make-up.

Waste Disposal This system has eliminated the disposal of ail of FVC’s spent sand (about 1,200 tons/year, including treatment additives) to a Class I landfill (or by using another costly method) and reduced the purchase of virgin sand by about 800 tons/year. There is, however, an increase in atmospheric emissions. Emission limits for the reclamation system are set in a permit from the Fresno County Air Pollution Control District. The system is in full compliance with these limits, and the particulate emission rate is far below the allowable limits.

The particles collected in the baghouse comprise about ten percent of the sand processed. These particles are shipped, along with the removed metals, to a primary smelter for use as a fluxing agent in its refining operation.

Figure 6 shows a schematic of the reclamation system. The system cost approximately $700,000 as installed, of which about $285,000 was State-funded. Although this is a large capital expenditure, the annual operating costs of FVC’s previous treatment and disposal method were projected at $362,00O/year more (and increasing) than the reconditioning system operating costs. Therefore, the reclamation system will pay for itself in less than two years.

Background On December 20, 1988, the Department and Texaco Refining and Marketing, Ing. (Texaco) entered into a Consent Agreement and Order (Order) for the purpose of settling an administrative complaint filed against Texaco by the Department on December 16, 1988.

The Order was unique because:

the $8.95 million penalty was the largest ever agreed to in California, and

for the first time, a significant portion of the penalty, $3.95 million, was to be used as environmental credits to perform an audit for the purposes of reducing the generation of hazardous waste and other environmental pollutants, and to implement the recommendations of the audit.

The goal of the project was to implement hazardous waste minimization measures as partial credit towards civil penalties. These measures were to focus on source reduction opportunities, as opposed to management techniques, thereby forcing Texaco to explore the often difficult-to-implement areas of materials substitution, process modification, recycling, etc. The surrounding community would

32

benefit because the penalties are used to reduce emissions, discharges, and wastes generated by the facility.

Strategy The strategy developed was to encourage a prompt and “nonlitigious” settlement by allowing Texaco to investigate and implement waste minimization measures as partial credit for monetary penalties. A key aspect of the strategy was the evaluation of environmental pollutants other than hazardous waste (i.e., water discharges and air emissions) for source reduction. Other important aspects designed to ensure timely compliance included review/approval of timeframes for plans and reports, implementation deadlines, and cost accounting specifications. One strategic component intended to ensure a comprehensive investigation was the inclusion of a mass balance.

The audit procedure consisted of

1.

2.

3.

4.

5.

6.

7.

Project Initiation. Identify key personnel, assign authority and responsibility for tasks, and develop information processing procedures;

Preliminary Evaluation and Data Collection. Review existing data to identify data gaps; .

Identify Sources, Wastes, and Amounts. Analyze existing records and reports, interview technical, operating, and maintenance personnel, and conduct field surveys for air, wastewater, and solid and semi-solid wastes;

Develop Products List. Use as input to mass balance;

Develop Feedstock List. Use as input to mass balance;

Develop Mass Balance. Define metering accuracy and time base, then perform iterations of calculating, reviewing, and adjusting volumes until the balance closes to the required accuracy; and

Identify and Evaluate Potential Source Reduction Techniques.

Actual source reduction measures were to be implemented as part of the settlement, based on findings from the audit. The source reduction measures and associated cost credits were subject to Department approval.

Results The audit identified several types, sources, and quantities of hazardous waste and other environmental pollutants, air emissions, and water discharges, that could be reduced. All pollutants were ranked as candidates for pollution prevention on the basis of the following equally weighted criteria:

1) volume or quantity,

2) toxicity,

3) impact of existing or developing land disposal restrictions, and

4) availability/feasibility of applying pollution prevention techniques.

One significant pollutant that was identified as a potential candidate for pollution prevention was sulfur emissions to air and wastewater. Oily sludges were identified as a significant candidate for hazardous waste minimization implementation.

33

Sulfur was considered significant because it was the single largest category of waste emissions. Furthermore, technology is readily available for modifying their existing recovery unit, and for a more efficient tail gas treatment unit so that both air emissions and the amount of ammonium thiosulfate discharged to the wastewater treatment plant is reduced. Also, the additional 2.3 million pounds of sulfur potentially recovered per year could be sold, and this large waste volume reduction would lower facility permitting fees. The projected cost of installing the more efficient tail gas treatment process was $5.8 million.

Oily sludges were considered significant because there were two viable possibilities for waste minimization: modifying the crude oil desalter with a more efficient oily water treatment system, and recycling the recovered oil and sludges into the delayed coker unit. Together, these modifications could potentially reduce oily emulsion discharges to the facility’s wastewater treatment system by over 50 percent, thereby significantly reducing the amount of oily sludges. The projected cost of these modifications was $250,000.

Other pollutants identified as potential candidates for pollution prevention included contaminated soil, empty containers, spent catalysts, heat exchanger bundle cleaning sludge and leaded gasoline tank bottoms, wastewater filters, and metal shot from heater tube cleanings. All of these wastes were sent offsite for disposal in 1988. These wastes were not considered prime candidates for waste minimization under the Order because of a variety of factors such as low volume generation, previously implemented measures, low costbenefit ratios, and regulatory barriers. However, Texaco has continued to investigate the feasibility of implementing some of these measures outside of the Consent Agreement.

Conclusions The settlement strategy was successful. The total amount of time between filing the complaint and signing the Order was only five days, although informal negotiations required five weeks. This is a remarkably short time for a settlement of this size ($8.9 million). Furthermore, the audit revealed at least three measures for which pollution prevention and waste minimization would be cost-effective for Texaco: replacement of the sulfur recovery unit,

modification of the oily water treatment unit at the crude oil desalter, and recycling of recovered slop oil to the delayed coker unit. Texaco eventually decided to spend nearly $10 million more than the required $4 million for implementation, because a second tail gas treatment unit was determined by the Kem County Air Quality Management District, during the California Environmental Quality Act (CEQA) review process, to be necessary for backup, and because of economy of scale considerations.

Some of the other candidates were also implemented; however, these were not counted towards the monetary commitment required by the Order because the sulfur and oily waste reduction measures alone exceeded the required amount. Implementation was delayed nearly one and a half years due to engineering design delays and unforeseen permitting requirements of other agencies.

~

Initially, the inclusion of a mass balance was a key strategy to ensure that the audit was comprehensive and the results confirmable. However, the mass balance strategy was later determined to be unnecessary because the estimated waste volumes could not be confirmed since the through-put volumes were orders of magnitude larger than the waste volumes. In other words, the errors in accuracy were larger than the waste volumes to be measured. The mass balance closed to 0.03 percent, well within the required amount of 0.1. percent. However, much of the data used in the mass balance was calculated rather than actually measured, so some uncertainty remains with regards to the overall closure accuracy.

The results of the mass balance showed that discharges to air through heaters, boilers, and intemal combustion engines were the single largest volume, followed by discharges to air through cooling water towers, and then wastewater injection. The mass balance was useful as a tool to ensure that ~

attention was focused on each process/wastestream. ~~

Recommendations The Department, as well as other departments within CalEPA, should continue to place pollution prevention conditions in Consent Agreements and Orders on a case-by-case basis. Cooperation and coordination between regulatory agencies will be

-

34

necessary to make this approach effective. Factors such as pollution prevention potential, compliance history, applicability of Senate Bill 14 (Hazardous Waste Source Reduction and Management Review Act of 1989) requirements, amount of penalty, and staff time should be considered.

In this case, using a mass balance was not productive; however, a mass balance may be productive in a case where the waste volumes are on the same scale as the through-put volumes and where measurements are more readily available. In general, experience has shown that mass balances are too time-consuming because of difficulties in measuring and calculating mass flow rates. This, with the accuracy concerns mentioned above, discourages the use of mass balances as a waste minimization tool at this time,

The Department should work with companies to prioritize implementation options based on waste minimization potential and cross-media effects. Thus, source reduction options would be most desirable; however, recycling options may be easier for companies to implement and should also be considered.

California Environmental Quality Act compliance should be included in estimating implementation costs and timefiames.

The Department is already including waste minimization conditions in some hazardous waste facility permits, and will continue to consider using waste minimization conditions in other actions such as closures and site mitigation.

THE WASTE REDUCTION INNOVATIVE TECHNOLOGY EVALUATION (WRITE) PROGRAM

In conjunction with the U.S. EPA Waste Reduction Innovative Technology Evaluation (WRITE) Project, the Department has been working to identify, evaluate and demonstrate innovative engineering and scientific technologies for minimizing hazardous waste generation.

In November, 1989, the Hewlett-Packard Sunnyvale Printed Circuit Facility (HP) installed an Advanced Reverse Osmosis System (AROS) on a double counterflow rinse tank system following its 1,300 gallon Watts nickel plating tank. The contents of this particular bath are difficult and expensive to treat and dispose of due to its low nickel concentration and hazardous nature. The AROS, manufactured by Water Technologies, Inc. of Minneapolis, Mn., incorporates membrane materials and system components specially adapted to plating environments, resulting in a reconcentration of dilute plating solutions to at or near bath strength and clean rinsewater. Both the plating solution and rinsewater can be reused onsite.

The goal of this project was to determine if the AROS could be operated to reclaim and reuse Watts nickel bath and rinsewater and to reduce the generation of hazardous plating sludge generated from the existing wastewater precipitation system.

Advanced Reversed Osmosis System with computer operator.

35

The study objectives were to technically and economically evaluate the AROS in terms of system performance, parts quality, quality of the recycled bath and rinsewater, and to compare these results with the costs for water pretreatment (for rinsewater) and the existing wastewater treatment systems and disposal.

This project was funded through the Department's AB 685 Grant Program, and was also included in the Ca1iforniaKJ.S. EPA Waste Reduction Innovative Technology Evaluation (WRITE) Program.

Background The HP facility in Sunnyvale, CA., is a mid-sized, highly automated in-house producer of circuit boards for personal computers and instruments. The 12-year-old automated rack nickel plating line on which the AROS was installed contains plating, etching, and activating tanks and stations. Each tank has an intervening rinse to clean boards before the next process. The Watts nickel bath contains approximately 1,300 gallons of plating solution. The counterflow rinse consists of two 450-gallon tanks.

Advanced Reverse Osmosis System (AROS). Water Technologies, Inc. has adapted reverse osmosis for

use in plating and corrosive applications to achieve concentrations of 2,000 to 10,000 to 1 with single membranes. The AROS can reconcentrate dilute solutions to at or near bath strength, without additional concentration technology. Membrane materials and systems have been specially adapted to plating environments. Corrosion- and heat-resistant plastics and stainless steel components give the system a longer lifetime for a wide variety of plating rinses and baths, unlike a standard reverse osmosis unit. Custom designed sensors and controls manage the membranes in terms of concentration, times of exposure, and pressures that can vary depending on solution concentrate and membrane type. These variations are controlled by specialized software.

~

The uniqueness of the AROS is in its ability to clean plating rinses and reconcentrate the plating solution to at or near bath strength. The schematic in Figure 7 shows the AROS recovery and recycle system. The permeate or cleaned water is returned to plating rinses, in this case rinse tank #2, while the concentrated Watts nickel solution is held in the AROS' internal storage tank for further passes through the membrane, until the desired concentration is achieved. After this occurs the concentrate is pumped to plating tank #l. The recovered

Top view. Advanced Reverse Osmosis System.

36

FIGURE 7 SCHEMATIC D I A G R A M O F THE

A D V A N C E D REVERSE O S M O S I S S Y S T E M (AROS)

concentrate for the HP plating line was kept at less than 50 percent to prevent precipitation of component chemicals in the AROS. Normally, the dilute/ dirty rinsewater is batch-treated using precipitation methods at the onsite wastewater treatment plant with the sludge disposed as a hazardous waste, or shipped to a reclaimer.

The AROS is considered innovative because of the internal microprocessors, specialized membrane, and membrane control strategy. The microprocessor controls the operating parameters for each new flow of concentrate through the membrane. Pressure and process times are tightly controlled to achieve long membrane lifetimes and very high concentrations of dilute metal salts, which in this case are nickel salts. These microprocessors and other system operating components are remotely monitored and controlled

through a modem. This allows for rapid diagnosis and service response away from the site. This feature was used regularly during the project to gather operating data, to monitor the system, and to make any changes in process control procedures.

Demonstration Project Procedures and Results. Evaluation of the AROS over the seven month study period involved the analysis of the reclaimed plating solutions and the rinsewater. The major areas of concern regarding quality and performance included 1) rinse quality, 2) parts quality, 3) contents of the recovered plating chemicals and their suitability for reuse or batch treatment, 4) water use reduction, including down time when the AROS would automatically bypass using deionized water, and 5) AROS reliability.

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The testing program included continuous monitoring (every fifteen seconds) of flow volume, conductivity, and pH at various monitoring points in the system. Streams monitored included the deionized water make-up line, emergency bypass line, the concentrate return line, and the permeate return line. Plating bath #1 was also sampled and analyzed weekly for nickel, Nikal PC-3 (a proprietary chemical), boric acid, chloride, and the ductility of a thin nickel sheet. Water use reduction was measured by the amount of deionized water not used throughout the testing period as compared with previous usage. Finally, system reliability was measured by compar- ing operating versus ‘down’ time due to mechanical and operational failures.

Results Technical. Overall, AROS performed satisfactorily during the seven months of operation. During this time the AROS recovered over 2,460 gallons of Watts nickel bath at 40 to 50 percent of bath strength from the recycling of 190,200 gallons of rinsewater, while using less than 3 1,000 gallons of water. Half of this recovered bath, i.e., 1,230 gallons, was reused in the plating tanks and the other half batch treated and disposed. No plated parts were rejected during this study period using the recycled nickel concentrate.

The AROS unit installed at HP had the capacity to treat and recover up to four gallons per hour of Watts nickel bath dragout from the operational plating line. During this testing phase, the AROS unit operated at less than ten percent of its design capacity; i.e., treating and recovering 0.2-0.3 gallons per hour. Only half of the recovered nickel plating bath concentrate was used to prevent plating out of nickel onto components in the AROS, due to the long holding time caused by HP’s manufacturing schedule.

Water use reduction in the plating operation was outstanding. Water usage of the plating line before the introduction of the AROS was 300 gallons per hour (gph) for one or more eight hour shift. This resulted in water consumption of 2,400 gallons over an eight hour shift for rinsing parts and treatment in the wastewater treatment facility. Water usage during the seven month test averaged less than six

gph or 48 gallons per eight hour shift. Over 750,000 gallons of water were saved for the 16.6 hours per day the unit was operated during the seven month test period. (The unit was usually operated eight hours per day.) If the AROS unit was used at full operating capacity for a year, i.e., four gallons per hour, 425,000 gallons of rinsewater would be saved per eight hour shift per plating line. This translates to a 2.6 ton reduction in sludge generation for this volume of rinsewater that would otherwise have to be treated at the wastewater treatment plant.

The AROS unit demonstrated excellent reliability during most of the test period. During the period February 28 to June 29,1990, the system was operational 3,594 hours and experienced only 20 hours of down time. However, mechanical failures experienced in July and August, 1990 caused over 200 hours of down time. Water Technology, Inc. reports that design improvements have been implemented to reduce these mechanical problems.

Economics. Savings occurred in four areas and included 1) water and sewer costs, 2) chemicals for precipitation, 3) disposal costs, 4) deionized water costs, and 5) recovered Watts nickel plating bath costs. The AROS saved 2,357 gallons of water previously used per eight hour shift and also provided a rinsewater quality approximately equal to the previous practice of using deionized water. At three eight hour shifts per day for a year, HP could save 1,275,000 gallons of water (i.e., three eight- hour shifts times 425,000 gallons) with an estimated savings of $21,165 for the water, sewer, chemical, disposal, and deionized water costs. Recovering and reusing 85 percent of the Watts nickel bath (around 1,260 gallons annually at a 0.3 gph recovery rate) would provide a savings of $5,335. The total savings by using the AROS unit for this demonstration were estimated to be $26,520. If the AROS was used at its design capacity for dragout recovery of Watts nickel of four gph instead of the demonstration rate of 0.2 to 0.3 gph, the recovery and reuse of the nickel dragout at the standard 85 percent recovery level would provide projected savings estimated at $72,250 during 4,250 hours of use in a year.

An HP cost evaluation of the demonstration showed an estimated net annual savings of approximately $17,000/year through the use of the AROS unit. This

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compares to a capital expenditure of approximately $75,000 and includes $62,600 for the unit, installation, and training costs. The payback period was estimated to be four and one-half years, with an intemal rate of retum of approximately 23 percent.

However, the AROS unit at HP was operated at less than ten percent capacity, around 0.2 to 0.3 gph, instead of four gph of dragout recovery, resulting in a lower volume of recovered plating bath solution and rinse water. The economic benefits would have been more favorable if the Watts nickel plating process lines had been operating for longer periods of time and treating more rinsewater. A payback of less than one year would have been realized if the AROS had operated near capacity.

Conclusions Overall, HP was pleased with the operating results of the AROS. Unfortunately, the Watts nickel plating line and the AROS were operating below full capacity, so the economic benefits appear lower than compared to a fully operational system. Throughout the project, HP experienced no loss of plating quality when the reclaimed plating bath and rinsewater were introduced into the system.

The volume of rinsewater used and treated in the plating process were reduced by 750,000 gallons over the study period. The water conserved over a year was estimated to be 1.25 million gallons. Cost savings were realized from reduced water usage, reduced wastewater treatment, less sludge disposal, and from the recovered Watts nickel plating bath solution.

The transferability of the AROS to other industries that use the Watts nickel plating process for the manufacture of bolts/fasteners, plumbing fixtures, or printed circuit boards is excellent. AROS systems are operating on rinsebath recovery for other plating baths-copper cyanide, zinc cyanide, brass cyanide, zinc hydroxide, nickel sulfomate, and others. The barrier to wider application of the AROS may be its capital cost. The investment in capital equipment with a payback of more than one or two years may be difficult for small job and captive shops with variable revenue streams.

Purpose. The Mayor’s Award of Excellence honors and recognizes City of Los Angeles departments, bureaus, and/or divisions that have exhibited outstanding commitment to the environment through innovative hazardous waste minimization practices that prevent release of pollutants to the air, to surface waters and ground waters, or to the land. The recipients of the award receive public recognition and serve as models for other Los Angeles City departments.

Judging criteria. A panel of judges chosen by the Mayor reviews applications, selects finalists, and determines recipients of the Mayor’s award. The judges evaluate applications based on criteria that include the amount of waste reduction achieved, documented cost savings, innovative pollution prevention technologies, applicability range, environmental benefits and management commitment.

The selection procedure includes an initial screening of applicants, presentations by semifinalists, and final selection of award recipient(s). Site visits are sometimes included in the final selection process.

Department of General ServicedBuilding Maintenance-Conversion to Water-Based Paints The Department of General Services Building Maintenance Division phased out its use of solvent- and lacquer-based paints and thinners. General Services wanted to comply with South Coast Air Quality Management District regulations, reduce disposal costs, and prevent employee health risks.

The department substituted the hazardous products with water-based paints and acquired high volume, low pressure spray guns. Research and testing of replacement products took about four months.

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The material substitution resulted in a 95 percent reduction of hazardous waste generated. A 65 percent transfer efficiency of spray mist was accomplished with the purchase of the high volume, low pressure spray guns.

Hazardous waste disposal costs have dropped to a minimal amount, because paint and lacquer thinners are no longer disposed, at a savings of $450 per 55 gallon drum. The project’s payback period was immediate.

General Services’ Maintenance Division also researched and tested a new carpet product that has a tackifer on the carpet backing. This new system allowed the department to eliminate the use of carpet adhesive. Complaints from building occupants about fumes from carpet adhesive are no longer a problem, the workers no longer are exposed to the fumes, and there are now no VOC’s emitted. This system saved the department $48,000 the first year in material purchases alone. The biggest benefit is that labor savings in installation and preparation was increased by two to three hundred percent.

Hazardous Waste Minimization Program at the Hyperion Wastewater Treatment Plant Goals, Approach and Changes Made. The hazardous waste minimization program at the City of Los Angeles’ Hyperion Treatment Plant (HTP) is a direct result of the plant’s longtime commitment to preserving the environment through effective hazardous waste management.

The Hyperion treatment plant, with capacity to treat 420 million gallons per day of wastewater, is the largest of four plants operated by the Bureau of Sanitation of the City of Los Angeles. The plant is currently undergoing major modernization and upgrading, which will enable the plant to perform full secondary treatment processes.

The goals of HTP’s program are to achieve pollution prevention and cost savings to the City, by means of waste reduction: elimination of hazardous waste, reuse, and recycling. The following are some of the approaches in achieving the above goals. The focus is not on the wastewater the facility processes, but on the wastes associated with running the plant.

A Hyperion Hazardous Waste Task Force Committee was formed, with participation of all sections of the plant that generate hazardous waste. The Task Force meets on a monthly basis to discuss issues and activities related to hazardous waste management. Hazardous waste handling, accumulation, storage and disposal and reduction procedures were developed and implemented through this committee.

A hazardous waste tracking system was developed for the plant to determine the type and quantity of wastes being generated by each section of the plant. A hazardous waste generating rate and pattem, by waste types, was determined for each section and for the entire plant. This has laid the groundwork for a recordkeeping system that has identified possible areas of waste reduction.

Onsite hazardous waste accumulation and storage practices were examined to ensure effective waste reduction. Nine satellite storage areas and one central storage area were established. Proper labeling requirements are enforced, and weekly inspection of all storage areas are conducted to ensure regulatory compliance. Each satellite area is supervised by a designated hazardous waste coordinator, who represents the section in the Task Force Committee.

Hazardous waste disposal practices were evaluated to determine possible areas for waste reuse and recycling. Solvents and lab wastes are recycled offsite using the services of a city contractor, Containerized Chemical, Inc. Waste oils are recycled by Express Oil, Inc. For the first time in HTP’s history, a program to reuse and recycle used empty drums has been established.

In order to prevent future problems, two underground tanks were removed in late 1989 and an additional five underground tanks were removed in 199 1. Similarly, all PCB transformers have been removed. Asbestos materials removal from buildings in the plant was completed in 1990.

~

~

Project Results and Estimates of Waste Reductions. The majority of the previously mentioned efforts were undertaken between 1989 and 1990. Below are some estimates of reductions that have been achieved as a result of these efforts (see Table 2 for a tabular summary of quantities reduced.)

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Description

Total Tonnage of Hazardous Waste I 2,566 117 I 95% I

Quantity % Reduction 1989 1990 (increase)

Tonnage of Landfilled Hazardous Waste

Tonnage of Recycled Hazardous Waste

NA I o 25 I Cubic Yards of Reclaimed Ferric Chloride Cont. Soils

~ ~~~

2,526 43 98%

40 74 (85%)

No. Drums of Anti-Foam Chemicals Reused

Gallons of Used Oil Recycled

NA

9,602 16,758 (75%)

No. Empty Drums Recycled 163 576 (253%)

I 27 No. Empty Drums Returned to Chevron for DeDosit

0 20 No. Drums of Hazardous Waste Exchanged with other Sections

78 I NA

(1 89%)

No. Drums of Polymeric and Chemical Samples Rejected and Returned to Supplier

0 10 NA

I 25 No. Drums of Hazardous Waste Generated by Contractors 76% 1

I I I

Most of HTP’s hazardous wastes (2,526 out of 2,566 tons) landfilled in 1989 are no longer landfilled. By 1990, only about 37 percent (43 out of 117 tons) of HTP’s total projected waste streams were landfilled. This represents a 98 percent reduction in landfilled waste in 1990 from 1989. The remaining percentage have either been reused, recycled, or completely eliminated, Le., not generated.

The plant has always recycled its waste oils through licensed recyclers or reclaimers, and it is important to note that this is accomplished at no cost to the City. The City administers a contract with reclaimers, who pay $0.05 to the City for each gallon recycled through them. It is estimated that 16,758 gallons of waste oil were recycled in 1990.

A program to reuse and recycle used and empty drums was started in late 1989. These drums formerly were crushed and disposed as hazardous waste. During the first half of 1990,276 drums were reused or recycled. It is estimated that over 576 drums were reused or recycled in 1990. All of the drums were reused or recycled through the Rosecoperage Company. An additional 78 used and empty Chevron drums were recycled or reused in 1990, through Chevron’s El Segundo Facility, compared to 27 drums in 1989.

An ongoing inventory of materials exceeding shelf life and off-specification materials is conducted for the various sections of the plant. To avoid disposing these materials as hazardous waste, the inventory data are made available to other sections of the plant

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that may have a need for the materials. This communication occurs during the plant’s monthly Hazardous Waste Task Force Committee meetings. Approximately 20 drums of ion-resins, anti-foam chemicals, anti-bacteria soaps, etc. were reused in this fashion.

The plant laboratories are encouraged to accept only the amount of chemical samples that are necessary for their operations, thus eliminating unusable samples. In addition, the plant laboratories have recovered some usable mercury from their waste streams. Similarly, process engineers are required to determine the amount of polymers needed for testing and evaluation, and accept only that amount from the bidders who submit samples for evaluation. The laboratories’ and the process engineers’ efforts are estimated to have eliminated ten to twenty drums of samples that would otherwise be disposed as hazardous waste.

Contractors working at Hyperion have in the past generated substantial amounts of hazardous waste during material handling, storage and construction activities. However, due to increased coordination with the contractors, only six drums of hazardous waste are estimated to have been generated by contractors in 1990, compared to 25 drums in 1989, a decrease of 76 percent.

Currently, two projects are underway that further improve hazardous waste/materials management at Hyperion. First is the design of a new central storage facility to accommodate the present and future generated wastes. Second, Hyperion is preparing a Best Management Practices Plan for the handling and storage of hazardous materials and wastes.

Economic Benefit. Overall, a total cost savings of $273,562 is being projected for the Hyperion plant, which represents a 64 percent reduction in costs to the City. See Table 3 for a summary of economic benefits.

The reduction in the quantity of landfilled wastes generated by the Hyperion plant represents a five percent (or $9,050) savings in disposal costs (shipping and tipping fees) for 1990. This savings is achieved despite additional costs of $42.50 per hour spent in traveling to Utah to dispose of the waste, a

direct result of the temporary closure of the Casmalia Resources Landfill, where the wastes formerly were disposed. Had it not been for this additional hauling expense, the reduction in landfilled wastes would have translated to a nine percent ($16,606) savings to the City.

A side benefit of the reduced amount of landfilled wastes is that less taxes are assessed to the City. In 1989, a sum of $233,613 was paid out by the plant as Superfund, disposal and generator taxes. The 1990 hazardous waste taxes were projected to be $4,006. This results in a savings of 98.8 percent, or $229,606 for 1990.

It is estimated that $325 is saved by the City for each cubic yard of reclaimed ferric chloride-contaminated soils. This amounts to a total savings of $8,125 for the 25 cubic yards that have been reclaimed. It costs the City approximately $450 (including taxes, shipping and tipping fees) to dispose of one drum of waste at the USPCI hazardous waste landfill in Utah. This represents a total savings of $2,700 for the six drums of anti-foam chemicals reused onsite. It is important to note that these are one-time costs savings; contaminated soils are nonroutine waste streams.

Approximately 500 of the estimated 576 used and empty drums will be reused or recycled, yielding $3.00 each to the City, for a total of $1,500. In addition, the anticipated recycle and reuse of 78 empty Chevron drums will yield $1,560 to the City, compared to $540 in 1989.

The 20 drums of hazardous waste that are expected to be exchanged with the other sections of the plant will save approximately $9,000. The ten drums’ reduction in polymer and chemical samples due to waste minimization efforts by the plant’s laboratories and process procedures are expected to save approximately $4,500 this year. The 76 percent reduction that is expected in contractor-generated hazardous waste will amount to a savings of approximately $8,550 this year.

Management Commitment. One of the reasons for the successful implementation of Hyperion’s hazardous waste minimization program is the long term commitment and support of the management of

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Description

1 Hazardous Waste Disposal Costs by I (1 83,~ 84) I (1 74,~ 34) I Containerized Chemicals

Benefit (Cost) % Reduction (increase) 1989 1990

5% I

Hazardous Waste Taxes (233,613) I

(4,006) 98%

0 8,125 NA Ferric Chloride Contaminated Soil Disposal :

I Anti-Foam Chemical Reuse I 0 I 2,700 I NA I - ~ ~~ ~

Empty Drums Recycled 489 1,500 (207%)

Deposit on Chevron Drums 540 1,560 (1 89%)

0 9,000 NA Cost Savings by Exchanging Hazardous Waste with Other Sections

Cost Savings by Reducing the Quantity 0 4,500 NA of Polymeric and Chemical Samples

Contractor Generated Waste Disposal

Total:

(1 1,250) (2,700) 76%

(427,018) (1 53,455) 64%

the Bureau of Sanitation (which operates Hyperion). Management designated a Safety and Hazardous Waste Coordinator, and was also responsible for the formation of the Hazardous Waste Task Force Committee.

Projected Savings: $273,562 -

HTP management approved the development and implementation of the plant’s hazardous waste accumulation, storage and transportation procedures. Maintenance management provides the program with resources for in-house tracking and transportation of hazardous waste. Bureau of Sanitation and HTP management approved and constructed a central hazardous waste storage area for the plant. Most importantly, management is in full support of the day-to-day operation of the program.

Conclusion. A projected grand total of $273,562, representing a 64 percent reduction in waste

management costs, will be saved by the City as a direct result of the Hyperion Hazardous Waste Minimization Program. The Program is paying for itself, while at the same time recycling, reusing, eliminating and reducing generated hazardous waste, as well as enhancing human health and the environment.

Department of General ServicedFleet Serviced CFC-12 Recycling Municipal governments should anticipate environmental problems by initiating innovative solutions at the local level. The City of Los Angeles’ Department of General Services’ CFC recycling project was honored with the Outstanding Achievement Award for “anticipating globally, and innovating locally.”

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The release of chlorofluorocarbons (CFCs) into the atmosphere contributes to the deterioration of the stratospheric ozone layer, which shields life on earth from hazardous ultraviolet radiation. The Montreal Protocol, a 1987 international agreement, called for a 50 percent reduction in the production of CFCs by 1998. To anticipate this CFC phaseout, in early 1989 the City of Los Angeles, under a Mayor’s directive, called for the installation of CFC- 12 recycling equipment in all municipal fleet repair facilities. The city’s vehicle fleets use CFC-12 in air conditioning units. These gases were previously released into the atmosphere during servicing.

The City’s Department of General Services had anticipated the implications of the pending CFC regulations regarding its fleet operations. While the City Council’s Environmental Quality and Waste Management Committee requested a study of the problem, General Services began to research alternative procedures for maintaining the air conditioning systems. Before 1989 ended, General Services decided to purchase 25 Murray A.T.C. 5000 refrigerant recovery systems. These units capture, clean, and recharge CFC-12 into the vehicles’ air conditioning systems.

The award judging committee did not select General Services’ CFC recycling project merely for the procurement of the Murray systems in 1989. The committee admired the equipment modifications developed by the department’s fleet personnel, modifications that actually improved the system’s efficiency. In early 1990, General Services personnel cooperated with the manufacturer to debug the machines (the first generation of these systems), by using city vehicles for extensive testing.

Fleet personnel observed that the original equipment released measurable CFC- 12 into the atmosphere when the equipment was disconnected from the air conditioning systems. General Services made recommendations to prevent these incidental releases. The manufacturer responded to the department’s request by modifying the machine connections. These changes enable the system to capture virtually all gases from city vehicles with no losses to the atmosphere.

In addition, to capture particulate matter that may not have separated in the initial processing, a master wet drier was installed. General Services made further modifications to apply the recovery units to city helicopters and construction equipment. In order for the modified recycling equipment to be acceptable for city functions, the department obtained the approvals from both the Underwriters Laboratories and the U.S. EPA. In addition, Fleet Services also produced a training tape for the use of the recycling equipment. The film is applicable to the needs of other City departments.

General Services estimates that 3,000 pounds of CFC-12 will be reclaimed and recycled from 1,500 cars, 100 trucks, six helicopters, and 50 pieces of construction equipment. The recovery system also captures approximately 500 ounces of contaminated refrigerant oil, which formerly precipitated to the ground.

The machines protect city employees by preventing the formation of poisonous phosgene gas, which occurs when released CFC-12 is exposed to a running engine’s heat. The system, taking 30 minutes to service a vehicle, functions automatically, enabling the service mechanics to perform other repairs.

As the CFC phaseout continues during the 1990’s, the cost of purchasing CFC-12 will escalate. Currently, CFC-12 costs about $4.00 per pound. Because the new systems recover approximately 3,000 pounds of CFCs annually, General Services estimates that the City will save at least $12,000 per year by not having to purchase virgin CFC-12, at a cost of $150 per 30-pound bottle. Each Murray unit costs $5,175. The payback period is estimated to be between one and a half to two years.

Lower costs of helicopter and construction equipment maintenance will produce even more City savings. The prices of proposed CFC substitutes and their compatible air conditioning systems will be expensive. However, according to Murray, the A.T.C. 5000 will be upgraded to accommodate new refrigerants or future automotive systems.

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REDUCING DISCHARGES OF POLLUTANTS TO WATER

The State Water Resources Control Board (State Water Board) and the nine Regional Water Quality Control Boards (regional boards) have fostered pollution prevention through pretreatment programs for industrial dischargers, and the implementation of best management practices for nonpoint source pollution. The main focus of water quality programs in California has traditionally been treatment, first with the construction of waste water treatment plants, and then with the implementation of the industrial pretreatment program. Recently, there has been a movement toward preventing the generation of pollutants as a mechanism to reduce the necessity for additional treatment capacity.

Point pollution sources are typically industrial facilities and wastewater treatment plants. These sources are perhaps easier to regulate, since they are more easily identified and are subject to National Pollution Discharge Elimination System (NPDES)., permits, which can include waste minimization program development and implementation requirements. For instance, in the south San Francisco Bay Area, NPDES Waste Discharge Requirements have included such requirements. The waste minimization programs, mandated by such requirements, of three local publicly owned treatment works are described in this chapter.

Other point sources include underground and above ground tanks. Pollution from leaking tanks is controlled through the imposition of technical and operational requirements (including monitoring). Storm water, although seemingly a nonpoint pollutant source, is considered a point source and is subject to permitting requirements, as described later in this chapter. These permit requirements include pollution prevention planning requirements. The State’s nonpoint sources pollution prevention techniques are more problematic, and are described later in this chapter.

POINT SOURCE PROGRAMS

THE SOUTH BAY PILOT PROJECT

(This description of the South Bay Pilot Project is taken in large part from a report by the U.S. EPA, Region IX, entitled “The South Bay Pilot Project: Pollution Prevention Efforts in the South San Francisco Bay Area”.)

The South Bay Pilot Project is an innovative approach to reducing water pollution. With the cooperative efforts of federal-and State environmental agencies, three publicly owned treatment works (POTWs), the Palo Alto Regional Water Quality Control Plant, the San Jose/Santa

45

Clara Water Pollution Control Plant, and the Sunnyvale Water Pollution Control Plant, complied with strict discharge requirements through identifying and implementing pollution prevention measures.

In the late 1980’s, 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 portion of the Bay was of such concern that it was included in the U.S. EPA’s list of California’s impacted waters. As the State had been delegated the responsibility to determine how the Bay’s water quality could be improved, the California Regional Water Quality Control Board, San Francisco Bay Region attempted to solve the problem by addressing the quality of the POTWs’ influent.

Through amended discharge permits, the Bay Area Regional Board 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 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).

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 percent 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).

2. 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 supply were reduced.

The Bay Area Regional Board and the U.S. EPA reviewed the source identification and waste minimization studies. The Bay Area Regional Board modified the POTWs’ discharge permits, and then required that the POTWs implement additional pretreatment and waste minimization measures, 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,

46

provide public education,

submit progress reports.

The POTWs took steps to meet the more stringent permit requirements through various means. They now:

keep the other POTWs updated on progress, and

measure wastewater flows of over 37 percent 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;

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 facilities;

conduct workshops in their communities to increase the public’s knowledge of waste generation; and

develop options for reducing pollution.

Measuring Success To evaluate the success of the South Bay Project, the U.S. 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 dragout 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.

Barriers 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 onsite technical assistance; and

4. some regulations limit the pollution prevention options available to industry.

Results and Recommendations 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, the Santa Clara Valley Water District conducted research to reduce zinc in the water supply and has now found a successful method. Many companies in the POTWs’ 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 toward 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 Project:

1. Water quality standards should be more fully utilized to provide the impetus for pollution prevention initiatives.

2. All POTWs can benefit from pollution prevention and should consider implementing programs.

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media approach so that total waste generation is minimized.

3.

4.

5.

6.

7.

POTWs should examine mass-based limits as a way to minimize water use and to set precise discharge limits (see sidebar above). 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).

POTWs and industries should have access to nonregulatory assistance.

To have successful pollution prevention programs, company management must be willing to commit the necessary resources.

Small businesses should be given economic incentives to encourage them to implement pollution prevention measures.

Source reduction and recycling offer the best means of insuring overall reductions in waste. Pollution prevention efforts must take a cross-

8. It should be emphasized to industry that pollution prevention measures often offer long term savings to companies.

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 will help 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. Descriptions of the three POTW programs are detailed below.

PAL0 ALTOS WASTE MI N IMlZATl ON PROGRAM

As a condition of being allowed to discharge its treated effluent into the Bay, Palo Alto’s NPDES permit required that the treatment plant reduce the toxicity of its discharges. The permit conditions required that the plant 1) determine whether all significant and controllable sources of pollutants had been identified and were regulated under its pretreatment program, 2) identify feasible waste minimization measure that would reduce or eliminate sources of the toxic substances in its influent, and 3) investigate additional treatment technologies to apply at the sewage treatment plant.

Additionally, the plant conducted a survey of several cities that had adopted local limits to reduce heavy

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metals loads or had implemented industrial, commercial, and domestic source reduction programs. On the basis of the survey results, Palo Alto concluded that it should 1) continue and expand local limits for nonindustrial facilities, such as photoprocessors and vehicle service facilities; 2) develop a toxic pollution source reduction program with cities and agencies throughout the Bay Area; and 3) sponsor workshops, develop and distribute information to the public on source reduction techniques, and encourage the development and use of less toxic products and processes.

As part of the South Bay Pilot Program, Palo Alto initially focused on reducing silver discharges because levels detected in its effluent were significantly above expected permit limits and because of concerns about silver’s effect on clam reproduction in the South San Francisco Bay. Although the plant’s treatment processes had been removing about 85 percent of the silver entering the plant, Palo Alto was required to meet new discharge limits placed on its permit under the NPDES Program in April 1991. To do so, Palo Alto would need to install additional treatment equipment or reduce levels of silver entering the plant, before treatment, by 75 percent. According to a Palo Alto study on installing additional treatment equipment, the costs of construction, increased energy requirements, and the disposal of 2.5 million gallons per day of toxic byproducts (generated by treatment) would add at least $20 million per year to the plant’s current annual operating costs-tripling current sewage use rates. Source reduction, plant officials concluded, was clearly the preferable option.

After determining how much silver could be discharged into the city’s sewer while still meeting future permit limits, Palo Alto lowered pretreatment discharge limits for industrial facilities in September 1990 to 0.25 mg/l. At the same time, the plant also imposed special local limits on photographic materials processors, many of which had not been regulated in the past. The city also adopted silver ‘

reduction ordinance requirements that regulated all dischargers of photoprocessing silver to the sewer, from the smallest dentist offices to the largest photoprocessing facilities.

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The ordinance allows silver dischargers to either 1) treat spent fixer solution onsite to remove nearly all of the silver before discharging into the sewer, or 2) deliver spent solutions to a silver reclaimer. The sewer ordinance carries enforcement provisions under which the City can impose fines of up to $6,000 per day for noncompliance. The treatment plant’s goal, however, is to encourage compliance with the ordinance by helping the regulated community. The plant has held several workshops to explain the ordinance and its importance to the affected community. Small business compliance with the ordinance is the key to the program’s success.

In addition to its efforts to reduce silver contributions (loadings) in the sewers from industrial and commercial facilities, the plant is also targeting domestic silver sources. The plant has developed educational pamphlets that encourage home hobbyists to take spent solutions to household hazardous waste collection sites rather than dispose of them in a sink.

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September 1991 was the effective date of Palo Alto’s silver ordinance requiring photoprocessing and x-ray facilities to cease the discharge of untreated spent fixer and similar solutions to the sewer. Thanks to many cooperative businesses and institutions, the maximum silver concentration discharged to the Bay was reduced from 14 parts per billion in 1989 to 2.4 parts per billion in 199 1-more than an eighty percent reduction (see Figure 8). This progress is especially gratifying because the silver concentration in clams found near the outfall has also steadily declined during this period (Figure 9). Nevertheless, further reduction is still needed to consistently meet the 2.3 parts per billion limit.

THE 5AN JOJE/SANTA CLARA WASTE MINIMIZATION PROGRAM

The San Jose/Santa Clara Water Pollution Control Plant has completed its required studies to identify pollutant sources and opportunities for pretreatment program improvements and waste minimization. NPDES permit amendments required that:

The discharger shall implement a pilot waste minimization program aimed at specific metals of concem (copper, lead and zinc) in their discharge. The waste minimization program shall consist of public education efforts and a pilot waste minimization program for radiator repair shops, auto parts cleaning shops, and any other groups the pretreatment program identifies as important target sources.

The plant also implemented a public education program aimed at reducing the amount of metals discharged to the sewer. These efforts include outreach to the communities, and efforts to identify and educate small quantity generators via seminars and workshops on waste minimization opportunities for specific types of discharge.

As a result of this pilot program, three general categories of industries were required to submit waste minimization plans: 1) permitted industries in violation of local limits, 2) permitted industries that are major dischargers of

metals, and 3) all new permitted industries discharging metals of concern. Significant metals violators comprised only two percent of the permitted industries in 1989. Industries were targeted industries based on the findings that approximately the top 25 percent of the permitted dischargers contribute 85 percent of the industrial flow and 73 percent of the industrial metals loadings to the publicly owned treatment works.

Waste minimization case studies from industries discharging to the San Jose/Santa Clara Water Pollution Control Plant are included at the end of this chapter.

SUNN WAL E‘S WASTE MI N IMI ZATl ON PROG RAM

As part of the South Bay Pilot Project, a Regional Board Order required that the City of Sunnyvale implement a pilot waste minimization program to reduce the discharge of copper, nickel, and lead to the sanitary sewer system. The program includes both public education and the preparation of waste minimization plans by industrial dischargers. Sunnyvale’s program also incorporates the public education and industrial discharger components of the Nonpoint Source Control Program (discussed later in this chapter).

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Education Program ,

Public Education. As part of its educational program, Quarterly Reports, bumper stickers, and other materials are distributed to the public. These and other materials on nonpoint source pollution and other water quality and conservation issues have been distributed at public events and through mailings. In addition, Water Pollution Control Plant personnel participate in school, county, and city events. Participation in events ranges from presentations and displays on pretreatment, waste minimization, nonpoint source pollution, wastewater treatment, and potable water supplies.

Other public education program elements include stenciling storm drain inlets, giving presentations, implementing an environmental awards program, and establishing a technical library. At this library, industry and the general public will have access to reference material on topics such as waste minimization, pretreatment, and nonpoint source pollution.

Identification and Education of Small Quantity Generators. Water Pollution Control Plant staff educate small quantity generators of hazardous waste through mailings, by establishing a mentor program, and through inspections/facility visits.

Technical Assistance. Technical assistance is provided to major industries by notifying them of educational opportunities through mailings and by conducting inspections.

Cooperation With Other Agencies. The Water Pollution Control Plant is actively involved with the Santa Clara County Hazardous Waste Management Program, the Santa Clara Valley Nonpoint Source Control Program, the San Jose Waste Minimization Committee, the South Bay Pollution Prevention Group, the Bay Area Hazardous Waste Minimization Committee, and the Regional Water Quality Control Board’s Waste Minimization Group. In addition to attending meetings, educational materials prepared by these groups are reviewed and shared.

Waste Minimization Plans The majority of copper, nickel, and lead discharged to the sanitary sewer from industrial process wastewater originates from the electroplating and metal finishigg

industries. Therefore, these industries have been targeted to prepare pilot waste minimization plans. While waste minimization has always been a part of the Pretreatment Program, preparation of waste minimization plans allows documentation of existing and proposed waste minimization measures and incorporation of nonpoint source pollution controls.

Pretreatment staff selected three targeted industries to prepare pilot waste minimization plans, primarily based on facility size: Hewlett-Packard (described later in this chapter), Precision Circuit Masters, and Lockheed Missiles & Space Company. Hewlett- Packard is a medium-sized metal finishing facility with limited local pretreatment violations in the past. Precision Circuit Masters, a small electroplating facility, typifies the majority of targeted industries in the city in terms of staff and financial resources. Lockheed is an exceptionally large facility with a variety of discharges.

The waste minimization plans include:

1) a list of toxic pollutants discharged and associated plant processes,

2) a mass balance showing the mass loading of each pollutant through the plant,

3) an evaluation of waste minimization alternatives, and

4) proposed waste minimization measures, including a schedule for implementation.

Water Pollution Control Plant staff have reviewed and approved each plan.

Sunnyvale’s program has been very successful, particularly in reaching the smaller businesses that can most benefit from pollution prevention technical assistance. These businesses have been very cooperative in implementing this program.

COUNTY SANITATION DISTRICTS OF ORANGE COUNTY’S WASTE MINIMIZATION PROGRAM

The County Sanitation Districts of Orange County (Districts) is a governmental agency that provides for the wastewater treatment needs for over two million people in 23 cities and unincorporated areas of Orange County. The Districts presently treat over

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225 million gallons per day of residential, commercial and industrial wastewater at two regional wastewater treatment plants that discharge to the ocean.

Recognizing the need to control the quality and quantity of wastewaters discharged to the sewer system, the Districts’ Boards of Directors adopted the first ordinance regulating the use of the sewerage system in February 1954. In 1970, the Districts’ Industrial Waste Division (now called the Source Control Division) was formally established to issue permits, set flow and quality limits, and monitor industrial discharges to the sewer system. The program was formally approved by the U.S. EPA in January 1984. At the same time, the Districts implemented a waste minimization policy for industrial dischargers.

Waste Minimization Program Waste minimization efforts undertaken in 1984 were designed to control and reduce the quantity of toxic materials discharged by permittees to the Districts’ sewer system, and to prevent dilution. To achieve these objectives, the Districts adopted mass emission rates for each permitted industrial discharger to bring about wastewater reduction and water conservation, and to prevent companies from achieving compliance by dilution. To determine a company’s compliance status, the Districts used the analytical results of samples collected at the industrial facility and the company’s average water usage to calculate mass emissions, and these rates were compared to permit limits. As part of this initial effort and the enforcement of mass emission rate limits, permittees were required to install flow restrictors or control valves to regulate and limit the flow of wastewater to the sewer. Permittees’ facilities were inspected and checked for water conservation control equipment at least annually.

Additionally, through permitting and enforcement activities, the Districts promoted the implementation of good housekeeping practices and the installation of waste minimization equipment, which included the implementation of waste segregation strategies and the installation of dragout tanks, spray rinses, and flow restrictors. These practices reduced the volume of waste generated and offered an economic

incentive in the form of lower pretreatment and sewer user charges.

In September 1989, as part of the revisions to the Districts’ Wastewater Discharge Regulations (Ordinance), provisions were incorporated that established waste minimization requirements. In essence, these provisions require all users to provide waste minimization plans to conserve water, investigate product substitution, provide inventory control, implement educational activities, and investigate any other steps needed to minimize waste. This policy is in keeping with the U.S. EPA’s January 1989 Pollution Prevention Policy Statement, which calls for state and local governments to play a primary role in encouraging the implementation of waste minimization and environmentally sound recycling practices.

In concert with the changes to the Ordinance, the Districts presently have adopted a two-tiered approach to cultivate industrial waste minimization practices. The first tier continues to utilize enforcement requirements as a primary method to implement pollution prevention. Waste minimization requirements are incorporated into enforcement actions taken against noncompliant industries through the issuance of written enforcement orders and compliance schedules. As part of the action, companies are required to conduct waste minimization assessments and implement any methods found to be economically feasible, to ensure long term compliance. Descriptions of proven waste minimization techniques, their applications and benefits, and a waste minimization checklist are provided to industries to assist them in their evaluations. In addition, industries are required to prepare written operating procedures and provide operator training. As part of this approach, a Districts engineer is sent to the company to review the industry’s manufacturing process, assess waste minimization opportunities, and answer any questions about the checklist and Districts’ requirements for waste minimization. The Districts have also participated in technical outreach efforts for the industrial community through sponsorship and participation in workshops on pollution prevention.

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As part of the second tier of the program, which has just been initiated, an extensive effort will be undertaken to “market” pollution prevention and champion the incorporation of pollution prevention “ideals” into each discharger’s way of doing business. The Districts are promoting, through informational and technical outreach, the concept of a “winning strategy” in waste management that has pollution prevention as the preferred alternative to all other pollution control methods. The goal is to create a partnership with industry.

For the second tier of the program, the scope will be expanded to consider cross-media and nonindustrial pollution prevention options. The first step of this process will consist of an extensive source survey to determine the level of pollution prevention currently achieved by industry, accompanied by an extensive educational and informational campaign. Small industrial sources and commercial dischargers will be made part of the pollution prevention effort at a later time through an incentives program and educational outreach.

Program Results Since the program began, approximately 95 percent of all the metal finishers and other federally regulated industries have installed flow restrictors or control valves to reduce water usage, or have implemented various waste minimization measures to reduce the volume of hazardous waste and wastewater discharged to the Districts’ sewerage system.

As a result of the waste minimization program, in concert with other source control actions, significant environmental improvements have been achieved. Over the past five years, the total heavy metals present in the Districts’ raw sewage has been reduced approximately 50 percent (see Figure lo), with greater reductions achieved for specific constituents. For example, cadmium has been reduced by 90 percent, chromium by 86 percent, copper by 62 percent, lead by 82 percent, and zinc by 74 percent.

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In recognition of these achievements, the U.S. EPA awarded to the Districts its Administrator's Pollution Prevention award for 1992. Case studies from the County Sanitation Districts of Orange County's waste minimization program are included at the end of this chapter.

pollutants released to the waters of the basin by major municipal and industrial dischargers. While emphasizing source reduction, it also includes improved waste management and expanded pretreatment programs.

The San Francisco Bay Region source reduction/ THE CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD, SAN FRANCISCO BAY REGION'S BASIN PLAN

The 1991 Water Quality Control Plan for the San Francisco Bay Basin (Basin Plan), adopted by the Regional Water Quality Control Board, San Francisco Bay Region (Bay Area Regional Board) in December of 199 1 and subject to approval by the State Water Board in 1992, broadens the South Bay POTW approach by applying certain waste minimization requirements to all dischargers in the Bay Area Regional Board's jurisdiction. The text below is adapted from Chapter IV, Implementation Plan, of the proposed Basin Plan. As of this writing, this plan has been submitted to the State Water Board for approval.

Policy Statement Source reduction and waste minimization is an important component of the Mass Emissions Strategy recommended in the State Water Resources Control Board's Pollutant Policy Document for the San Francisco Bay-Delta. The Mass Emissions Strategy requires that the regional boards develop limitations on the mass emissions of toxic pollutants to reduce the overall quantity of toxic emissions into the Region's watersheds. The Bay Area Regional Board supports reducing toxic discharges through more efficient use, conservation, recycling, reuse, and waste reduction. The source reduction and waste minimization program is a pollution prevention measure designed to eliminate the discharge of toxic wastes from manufacturing processes, commercial

waste minimization program is a two-tiered program consisting of a targeted and a general program. The program focuses on indirect discharges that are 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, water, and land disposal.

Targeted Waste Minimization Program The targeted waste minimization program consists of two components. First, pollutants and areas of concern in the Bay will be identified, where numerical and narrative water quality objectives are exceeded and beneficial uses are impaired or threatened. Identification will be based on analysis of available data and data from regional and local monitoring programs conducted by the Bay Area Regional Board and other entities. Second, in those areas identified as having objectives exceeded or waters impaired, point source dischargers will be identified and required to participate in a targeted waste minimization program. This step may necessitate further monitoring of water, sediment and biota by POTWs and direct dischargers at or 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 to develop and implement a waste minimization program that is targeted toward reducing the identified pollutants of concern.

"rogrum. The POTW source iinimization program should

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. Source reduction and waste minimization as applied here are focused specifically on reducing the quantity of toxic

1) Determination of contributions of target metal and organic pollutants discharged to the POTW from (a) regulated industrial users, (b) commercial facilities, (c) water supplies, and (d) domestic sewage.

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2) Enhancement of existing pretreatment programs through improved inspection, monitoring, enforcement, and information management. This would include a program of waste minimization audits for selected groups of significant industrial users.

3) Identification and regulation of previously unregulated industrial users and commercial facilities that discharge the pollutants of concern to the POTW. POTWs should prioritize currently unregulated categories of industries and develop technical assistance programs for local industries.

4) Public education and outreach, including household Hazardous waste collection programs, information on toxics disposal for POTW customers, and presentations to industrial, commercial, and residential dischargers.

5) Development of monitoring or other evaluation measures to gauge and document the effectiveness of the program.

The South Bay programs discussed above are examples of current targeted waste minimization programs.

Direct Industrial Discharger Targeted Program. As with POTWs, priority direct dischargers will be identified from existing monitoring information on water quality of surface water bodies in the Region. Direct dischargers may be required to conduct further monitoring. Those identified as contributing to water quality impairment will be required to carry out a waste minimization program. The program should reduce the pollutants of concern to meet the water quality objectives of the Basin Plan. Programs will include all applicable elements of the POTW programs listed above. The program will also include investigation of upstream sources of pollutants of concem.

The POTW and industrial targeted program may require other options, such as performance-based effluent concentration limits 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 in coordination with the development and

implementation of other tasks of the Mass Emissions Strategy.

General Waste Minimization Program All major dischargers not required to implement targeted programs will be mandated to conduct a general program within their jurisdiction. In the first phase of the general program, all major industrial dischargers and POTWs that 1) are not included in the targeted program, 2) have an approved pretreatment program, and 3) have an average dry weather discharge greater than 10 MGD will be required to prepare a plan for a general waste minimization/source reduction program and submit it for Bay Area Regional Board approval. Voluntary programs that have been developed to date will be given credit in the general program.

POTW General Program. The general program for a POTW should contain all applicable elements from the targeted program (elements 2-5). The general program is designed to be more flexible and allow the individual POTWs to develop and direct waste minimization efforts according to local needs. General programs should include the following elements:

1) Review of pretreatment programs for identification of opportunities to expand and enhance the program. This includes opportunities for incorporating waste reduction goals into inspections, enforcement, and permitting.

2) Waste minimization audits for industrial users on a priority determined by the POTW. Criteria for prioritization should include discharge of pollutants of concern, volume of flow, industrial user compliance, and opportunities for waste reduction. Audits can be performed by the POTW or Industrial User.

3) Public outreach, including education programs, advertisement in the local media, waste hauling programs, and household waste programs.

4) Program expansion, by developing a plan for increased regulation for at least two existing or additional categories of sources that contribute pollutants of concern to the POTW influent.

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Examples of additional source categories are waste oil disposal, household products, car and truck washing operations, medical and dental facilities, paint and related product disposal, dry cleaning facilities, and photofinishing facilities.

5 ) Coordination with other programs involved in recycling, reuse, and source reduction of toxic chemicals. This includes programs involving urban runoff, air toxics, hazardous waste, and land disposal. This might include developing programs for joint inspections and sharing in enforcement activities.

6) A monitoring program specifically designed to measure the effectiveness of waste minimization activities in reducing toxic loads to the receiving watershed, air, or land via sludge disposal.

Direct Industrial Discharger General Program. The direct industrial discharger source reduction/ waste minimization program must be in compliance with the Hazardous Waste Source Reduction and Management Review Act of 1989 (SB 14) waste minimization program requirements, as well as be in compliance with NPDES permit effluent limitations.

The direct discharger source reduction/waste minimization program plans must include detailed descriptions of tasks and time schedules to investigate and implement various elements of waste minimization techniques. These techniques should include material substitution, process modifications, water conservation, onsite and offsite recycling, and good housekeeping practices.

STORM WATER PERMIT PROGRAM

The 1987 amendments to the federal Clean Water Act established a framework for regulating municipal and industrial storm water discharges under the National Pollutant Discharge Elimination System program. In November of 1990, the U.S. EPA published final regulations that establish application requirements for storm water permits. These regulations require specific categories of industrial facilities, which discharge storm water associated with industrial activity (industrial storm water), to obtain an NPDES permit. Facilities that discharge industrial storm water either directly to surface waters or indirectly,

through municipal separate storm sewers, must be covered by a permit.

The California State Water Board has elected to issue a statewide general permit that applies to all industrial discharges covered by the EPA regulations (except construction activities, which will be covered under a separately issued permit). The permit generally requires dischargers to:

eliminate non-storm water discharges (including illicit connections) to storm water systems;

develop and implement a storm water pollution prevention plan, and;

perform monitoring of discharges to storm water systems.

Storm Water Pollution Prevention Plans The general permit requires that facilities covered under the permit develop and implement Storm Water Pollution Prevention Plans. These plans emphasize storm water best management practices (BMPs). The plan has two major objectives:

1) to help identify the sources of pollution that affect the quality of industrial storm water discharges, and

2) to describe and ensure the implementation of practices to reduce pollutants in industrial storm water discharges.

Required elements of a plan are:

1) source identification, 2) practices to reduce pollutants, 3) an assessment of potential pollution sources, 4) a materials inventory, 5 ) a preventive maintenance program, 6) spill prevention and response procedures, 7) general storm water management practices, 8) employee training, 9) facility inspection,

10) record keeping, and 11) elimination of unpermitted nonstorm water

discharges to the industrial storm water system. These discharges can contribute a

significant pollutant load to receiving waters, and include such things as illicit connections (i.e., floor drains), improper dumping, spills, or leakage from storage tanks or transfer areas.

NONPOINT SOURCE POL LUTl 0 N P R EVE NTI ON

For many years the primary focus of water pollution control in California was on the readily identifiable sources of pollution amenable to treatment by existing technology. However, nonpoint pollutant sources also pose a serious threat to water quality in California. While point sources of pollution exist throughout California, they do not currently represent the most serious threat to water quality, largely because point sources are more easily identified and controlled. Nonpoint sources are a major cause of water pollution in California, according to the State Water Board’s 1988 Water Quality Assessment Report and 1988 Nonpoint Problem Inventory for S u ~ a c e Waters.

Nonpoint source pollution is generally defined as pollution that is diffuse and/or not subject to regulation under the federal National Pollutant Discharge Elimination System. As distinguished from point sources of pollution such as discharges from industrial facilities and wastewater treatment plants, nonpoint source pollution occurs over extensive areas and from many diffuse sources. As water from rainfall, snowmelt, irrigation, or human activities moves over the land surface, it picks up and cargies away natural and manmade pollutants, eventually depositing them into lakes, rivers, wetlands, coastal waters, and underground aquifers. Nonpoint source pollution is usually associated with agriculture, silviculture, mining, construction, urban stormwater runoff, and even household activities. Pollution from these sources can take many forms, some of which are described below:

Agriculture: Fertilizers contained in irrigation runoff and drainage may end up in rivers, lakes and bays, and stimulate the growth of algae. Herbicides in these waters may accumulate in the food chain and have long-term effects on the environment and public health. Excess irrigation water that percolates beyond the root zone of the

crop is elevated in salinity. This drainage water, if not removed by subsurface drains, may increase the salinity of underlying freshwater aquifers. Other pollutants carried in drainage water may include naturally-occurring salts and toxic trace elements such as selenium, as well as bacteria and nutrients from livestock and animal wastes. Uncontrolled grazing also contributes sediment and animal wastes to rivers and streams.

Silviculture: Improper logging practices, including inadequate erosion control, careless construction methods, and poor maintenance of logging roads results in increased erosion: Eroded sediment may be deposited in streams and reservoirs where it can smother fish spawning areas.

Mining: Water that seeps or drains through mine deposits often picks up iron and sulphur compounds, becoming highly acidic and toxic to the environment. This acid mine drainage can also leach out heavy metals contained in the mine deposits. When this acid mine drainage enters surface waters, it can cause massive fish kills and sterilize streams and rivers. Pollution can also occur from the leaching of oxidized minerals and radioactive materials found in tailings piles or slurry ponds. Pollutants such as mercury can accumulate through the food chain and become a threat to aquatic life, wildlife, and human health.

Construction: Tons of soil, refuse, and chemicals wash from construction sites each year. These substances damage aquatic habitats and recreational areas by blanketing lakes, rivers, and bays with layers of mud and toxic sediments.

Urban Stomwater Runof: Soil, lawn and garden chemicals, pet wastes, and highway contaminants (oil and fuel, de-icing salts, rubber deposits from tires, etc.) travel via storm drains to pollute nearby rivers, lakes and bays, or percolate through soils into ground water.

Household and Automotive Care: Oil, grease, gasoline, paints, solvents, and other household chemicals carelessly dumped on streets and in storm sewers end up in surface waters, harming aquatic life and degrading water supplies.

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Percolation from failing septic tanks is a major contributor to ground water contamination in some areas.

Control of Nonpoint Source Pollution Control of pollution from such diverse sources is problematic. Due to its very nature, it is often difficult to identify the source of the pollution and the responsible party. Even when they can be identified, implementation of corrective measures can be difficult. Treatment by conventional methods is often impractical and expensive, so prevention of pollution is generally the most effective means of control. Prevention of pollution from these nonpoint sources is a major emphasis of State Water Board programs, through the development and implementation of best management practices (BMPs). The preferred approach is cooperative, with voluntary implementation of BMPs.

Best management practices are defined in federal statute as methods, measures or practices selected by an agency to meet its nonpoint source control needs. BMPs include, but are not limited to, structural and nonstructural controls, and operation and maintenance procedures. BMPs can be applied before, during, and after pollution-producing activities to reduce or eliminate the introduction of pollutants into receiving waters. There is no prescribed set of BMPs for every category of nonpoint source pollution. Each case is unique, and requires the considered selection of a set of practices appropriate under the circumstances.

Some examples of BMPs that may be used to reduce nonpoint source pollution associated with agricultural irrigation are:

Conversion from a low-efficiency method of water application to a high-efficiency method, such as from furrow irrigation to drip irrigation. Numerous other structural options are available to improve efficiency and reduce erosion;

The use of irrigation scheduling techniques to more closely match the timing and amount of irrigations to the actual need of the crop. This will reduce deep percolation, conserve water, and improve water quality;

The installation of an irrigation retum flow system to reduce runoff and conserve water; and

Land forming to enable surface systems to operate more uniformly and at non-erosive velocities.

Some BMPs that may be considered for nonpoint source pollution related to forest practices include:

Appropriate design of access roads to minimize erosion. This includes slopes, culverts, retaining walls, etc;

Revegetation of disturbed areas and replanting of harvested trees;

Use of buffer strips along water courses to reduce erosion and runoff; and

Selective harvesting.

Numerous other BMPs can be identified for the other categories of nonpoint source pollution.

THE ROLE O F THE STATE WATER RESOURCES CONTROL BOARD IN N O N P O I N T SOURCE POLLUTION PREVENTION

Legal and Institutional Framework The Porter-Cologne Water Quality Control Act establishes a comprehensive water quality control program for Califomia. This program is administered by the State Water Board and the nine regional boards. The principal means of implementing water quality controls is through issuance of Waste Discharge Requirements (WDRs), which may be issued for both point and nonpoint source discharges affecting both surface and ground waters, including discharges to land. While WDRs may specify water quality standards to be met by the discharger, they may also require structural and nonstructural improvements for pollution prevention.

Many public agencies have existing nonpoint source- related authorities and programs. In terms of functional relationships these agencies have either land management authority or technical or financial assistance capabilities. The State Water Board and regional boards seek agreements with these agencies that will result in implementation of BMPs and targeting of technical and financial resources to high priority nonpoint source problems.

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Program Objective and Management Approach The primary objective of the Nonpoint Source Program is to measurably improve water quality and/or implementation of best management practices. A number of secondary objectives have been adopted that support this primary objective.

convert its zinc cyanide plating baths to alkaline zinc solutions. Additional efforts toward source reduction and water conservation have resulted in less pollutants discharged into the sanitary sewer and less use of water and treatment chemicals.

The three general management approaches used by the State Water Board and the regional boards to achieve program objectives are:

1. Voluntary implementation of BMPs;

2. Enforcement of BMPs; and

3. Effluent requirements.

Regional boards generally refrain from imposing effluent requirements on dischargers that are implementing BMPs in accordance with a formal action by the State Water Board or regional board. It is generally up to the regional boards to decide which management option(s) to use to address particular problems.

WASTE MINIMIZATION CASE STUDIES

The following case studies illustrate industry’s response to some of the programs currently being implemented by the publicly owned treatment works and sanitation districts described in this chapter. Note that while some of these are driven by the water regulatory program, there are clear multimedia benefits.

Monorail on top of the plating tanks for transportation of parts from tank to tank.

Background The initial reason for the waste minimization program was to remove cyanide from CEPCO’s processes. Cyanide can be difficult to treat, and can lead to problems maintaining compliance with federal, State and local regulations. Continuing efforts were conducted when economic benefits were realized. Costs for treatment and disposal of plating wastes have been greatly reduced.

occurred and work could not be done at CEPCO. Indeed, problems did occur in adjusting to the more “difficult to plate” alkaline zinc solutions. Full conversion to the alkaline zinc solutions took 16 months of experimentation.

California Electroplating Company (CEPCO) is a plating shop located in San Jose. Waste minimization at CEPCO has been an ongoing project since late 1988, when product substitution was used to

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Parts are rinsed above the tanks.

TechnologyIStrategy After full conversion to alkaline zinc plating was achieved, attention was directed toward source control. Special lips were constructed around the inside of the plating and coating process tanks to prevent loss of solutions during agitation of parts. An additional benefit of this design was full retention of plating solutions during the earthquake of October 1989. To minimize plating dragout from entering the wastestream, a monorail was installed over the plating line. The monorail allows parts to be held over the plating and coating tanks for extended periods of time, thus returning dragout to the plating tank.

Whenever a heated process tank is used, a spray rinse is conducted directly over the tank. Not only does this reduce pollutant levels entering the wastestream, but water use is also reduced, because makeup water is provided in the process. By rinsing parts over the heated tanks, the associated rinse tanks can be removed from the process, thus eliminating sources of water use and decreasing the burden on the waste treatment system. The above modifications and procedures have a combined effect of reducing the amount of wastewater generated and treated.

replaced with treatment system effluent without causing any loss of product quality. It was also found that by plumbing the caustic rinse discharge into the acid cleaning rinse tank, neutralization would occur, thus reducing the burden on the treatment system. In addition, this procedure eliminated the need for a caustic dip as an intermediate step between the acid cleaning and zinc plating processes.

Finally, one very important consideration in waste minimization is the product rejection rate. The number of parts that fail acceptance by the vendor can be greatly reduced by careful monitoring of all plating processes. This in tum reduces the total number of parts requiring rework and the waste associated with rework.

After all possible methods of waste minimization were implemented, attention was focused on sludge volume. Sludge volume was reduced as a result of the waste minimization program, but further volume reduction was achieved by drying the sludge.

Cost analysis Cost-related benefits were realized in the decreased volume of sludge generated and shipped offsite for disposal. The reduced water use achieves the conservation of a natural resource, in addition to cost benefits. Average daily water use has decreased from 12,000 gallons in early 1988 to 6,200 gallons in late 1991.

The amount of sludge and debris shipped offsite has been reduced as follows (debris resulted from work on replacing copper nickel tin plating lines, which also resulted in a reduction in sludge generated):

To further reduce the amount of water and chemicals used in process and treatment, methods of utilizing the treatment system effluent in process rinses was evaluated. It was found that the rinse waters used after caustic cleaning and chromating could be

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Tandem Computers, in Silicon Valley, operates a research laboratory, which develops new product technologies for computer chips. For the past eight years, the laboratory has conducted a pollution prevention strategy, under the leadership of Tandem’s Environment & Safety Department and lab managers. Reducing the generation of hazardous waste at the source (minimization of chemical use) is the standard approach, due to cost considerations, lab efficiency, and an understanding of current and impending regulations.

Background One of Tandem’s primary objectives was to design the lab so as to handle changing chemistries. The design included a chemical mix room, waste storage room, an oversized air scrubber system, a two-stage wastewater neutralization system, and segregated drains for hydrofluoric acid and solvents to vaulted waste storage tanks.

Pollution prevention was a major goal of senior management from the beginning. Compliance with environmental regulations, and especially worker safety, were included in all bottom-line decisions. As a result, high quality engineering practices were always considered in the regular discussions between safety personnel, lab engineers, and facility personnel on a routine basis. The laboratory efforts constitute a pollution prevention “strategy”, rather than a specific technology. This is illustrated by the Waste Minimization Measures Checklist (Figure 1 l), which was submitted to the Santa Clara Water Pollution Control Plant.

Biweekly meetings are held to discuss lab issues, and to plan ahead regarding changing regulatory requirements. Tandem’s emergency response team also includes lab workers; lab issues are also included in training.

Limitations included securing funding for purchase and installation of modem technology equipment needed to accomplish quality chemistry controls. This was overcome by a methodical process of defining needs, researching costs, prioritizing, and then inclusion into a long term budget process. By open communication with the Water Pollution Control Plant and the local air district, planning is facilitated, so that monies are available as needed.

The result has been a smoothly running lab, without the interruptions of system upsets and the resultant “catch-up” mentality. Tandem was able to cut development times in half for the new product efforts that were supported by the lab. This produced outstanding competitive advantage in the marketing of Tandem’s products, resulting in sales growth from $.8B in 1986 to $1.9B in 1990.

Technology Strategy and Implementation Tandem’s semiconductor laboratory has been in limited operation since 1984. The nature of its business is currently changing from developing computer chips to developing chip interconnection packages. As a result, the use of CFC solvent degreasing and etching with hydrofluoric acid (HF) has been discontinued. HE is used for glass cleaning once every two to three months (five gallons each time).

Waste minimization is accomplished through 1) material substitution, 2) process modification, and 3) good housekeeping.

1. Material substitution. The lab has discontinued the use of CFC solvent as a degreasing agent. This resulted from an engineering effort to find a replacement for CFC’s as cleaners. A water soluble substitute is now in use, in a new cleaning machine (capital cost: $137K).

The plating process development sinks have been successful, so the number has increased from two to five, while chemistries have been modified to increase efficiency. This supports the industry’s new product development efforts in high density interconnections. Procedures have been modified to prevent dragout.

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2. Process modification . Lab procedures have been established to guarantee slow workpiece removal to allow plating solutions to drain into the bath, before rinsing. The new sinks were designed with automatic agitators installed. Tandem has always segregated its plating sink wastes, generating approximately 30 gallons of metal-bearing waste in 1990.

3. Good housekeeping. This is standard practice in Tandem’s laboratory. The engineers who work there keep it clean and organized at all times, preventing spills of metal-bearing solutions to the sanitary sewer.

Waste minimization altematives were considered in the original lab establishment. Written chemical

handling procedures are followed. These keep metal-bearitig rinsates to a minimum. Recent sampling showed 0.00 124 pounds per day of copper in the rinsate, on average.

In addition, the following strategies/procedures have been integrated into lab practices:

Mineral acid etching sinks are pH-monitored regularly, to extend the useful life of the etchant. Product quality measurements also dictate sink change-out.

Hydrofluoric acid use was reduced through the installation of recycling baths. As lab practices matured, Tandem’s 2% waste HF generation was reduced to only 500 gallons per year.

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Temperature controls and pH measurement are used on plating baths to maintain purity and extend the use-time of the chemicals before disposal.

Self-monitoring requirements of Tandem’s Water Pollution Control Plant produce data, which are used by facilities to control chemistries. On one occasion, a slightly elevated fluoride sample indicated that one operator needed training regarding HF disposal procedures.

Wastewater reuse was implemented in late 1987. The system was modified in 1991 due to some problems with algae (subsequently controlled), and due to reduced flows from the lab.

At Advanced Micro Devices (AMD), a Sunnyvale- based manufacturer of semiconductor devices, fluoride wastewaters from the Santa Clara fabrication area were segregated from other corrosive wastewaters and treated separately. This enabled AMD to lower its fluoride concentration in wastewaters discharged by an order of magnitude from peak levels. The remaining fluoride concentration is attributed to low concentration sources, carryover from rinsing after concentrated baths, and exhaust fume scrubbers.

Background AMD’s goal in implementing this pollution prevention strategy was to bring its plant into compliance by meeting the discharge limit (10 ppm fluoride), and to reduce the toxicity of the discharge. Limiting the project was the fact that AMD had already implemented a water conservation program and had successfully reduced water use by forty percent. Reducing water use had a net effect of concentrating all wastewater contaminants, including fluoride.

An additional limitation was insufficient knowledge of the sources of fluoride in the effluent, so the sources had to be characterized. At approximately 20 ppm fluoride, AMD experienced diminishing returns in implementing new measures.

A feasibility study was conducted and a compliance schedule was proposed and implemented by AMD. Additional meetings were held to “fine tune” the measures taken after completing the installation of the fluoride segregation system. No problems of residual fluoride levels were anticipated due to the implemented pollution prevention measures.

Technology/Strategy Description Fluoride wastewaters are generated from hydrofluoric acid and ammonium fluoride/ hydrofluoric acid (buffered oxide etch or BOE) solutions used in sinks or baths in the manufacturing of semiconductor devices. Drains from sinks and other equipment using fluoride solutions were plumbed to a separate accumulation tank. Accumu- lated wastes are treated by adding water-soluble calcium chloride to the solution and precipitating calcium fluoride. The pH is adjusted and the precipitate separated using a filter press before the treated waters are discharged. The calcium fluoride precipitate is sent to an industrial landfill.

Source reduction measures were also implemented to reduce the amount of fluoride wastewaters generated. Source reduction measures included:

Automatic valves divert fluoride rinses.

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Covers prevent fluoride fumes from reaching the fume scrubbers.

installing high pressure spray nozzles,

installing automatic valves to divert initial fluoride rinses to the fluoride drain and water rinses to the acid neutralization system (ANS),

installing covers to prevent fluoride fumes from reaching the fume scrubbers, which discharge to the ANS,

installing air aspirators to reduce wastewater volume, and

installing a vertical tube wash, which recycles HF internally.

Strategy Implementation Demonstration chronology. The segregation of known fluoride solutions from other wastewaters was completed in January, 199 1. Over the next six months, a series of meetings was held between AMD manufacturing management, facilities, and environmental engineering to identify additional measures to be taken to consistently meet the discharge limit. Additional consultations were made by the industrial waste inspector and outside consultants.

additional sources. AMD purchased a fluoride ion-selective probe and took additional composite and grab samples as required to identify fugitive sources. This additional sampling resulted in the identification of the fume scrubber aqueous effluent as a source of fluoride in the parts-per-million range. Sampling was conducted at the point of discharge from the ANS.

Sample results. Results showed a significant decrease when segregation was instituted, followed by a gradual decrease as additional measures were taken.

Cost analysis. Because this is a new measure, a cost return (payback period) has not been calculated. Savings were realized as a result of treating fluoride wastewaters while still concentrated, rather than treating all of the wastewater for fluoride.

Conclusions It was found that the 10 ppm standard could not be met without controlling fluoride transfer from the aqueous phase to the gaseous phase, although the gaseous phase fluoride was reliquefied by the fume scrubbers. The necessity for the reduction of fluoride catalyzed the formation of interdepartmental review teams, which have also been used by the generator in other waste minimization and source reduction efforts, such as those required by SB 14.

Sampling procedures. After segregating known fluoride sources, AMD conducted one week of continuous fluoride monitoring to help identify

High pressure spray nozzles and low volume rinse sink.

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The Hewlett-Packard (HP) Sunnyvale facility can produce up to 650,000 square feet of fine line, multilayer circuit boards a year. This modem, medium-sized facility has a wastewater treatment system that handles an average of 180,000 gallons a day. The pollutants of concern generated by this facility are copper lead, and nickel.2 HP began a company-wide waste reduction program in the 1980’s in response to increasing costs and corporate liability associated with hazardous waste disposal. The Sunnyvale HP facility focuses on both waste reduction and improved management of waste that is produced.

The Waste Minimization Program The facility’s waste minimization effort encom- passed the following areas: material decontamination, reduction and recycling in plating operations, and sludge reduction. Each is discussed below.

Material Decontamination. At HP Sunnyvale, the most straightforward improvement in waste minimization is in the handling of containers and pipes. The bags and plastic containers in which chemicals are shipped to the facility, as well as polyvinyl chloride piping used in process, have chemical residues after they have been emptied or used. All of this waste must be sent to landfill.

HP found that residues can be removed from these materials by shooting a jet of hot water at them and soaking them in water. The water used in removing the residues is then sent to the wastewater treatment system, where the contaminants are removed and sent offsite for recycling and resource recovery. The contaminants being removed from the containers are the same as those that are involved in the manufacturing process, so the treatment system is specifically designed to treat container

decontamination wastewater? The volume of water used to decontaminate the containers is less than 500 gallons a day, as compared to a total wastewater flow of 180,OOO gallons a day. Thus, the decontamination waste stream constitutes less than 0.3 percent of the flow going to treatment, a volume that has no significant impact on the treatment system.

Removing these residues cut the generation of solid waste substantially. Although no dollar figure was arrived at, the savings were more than worth the trouble.

Plating Line Consolidation: Reduce and Recycle. HP reduced the nickel used in the plating process by reducing the number of plating lines. Originally, there were two plating lines, with each line having two nickel plating baths. Consolidating the two nickel plating lines into one more than halved the amount of sludge generated in treating wastewater from the nickel plating process, from twenty-nine tons in 1987 to fourteen tons in 1990.

Nickel plating line consolidation was accomplished by making the process more efficient, allowing one line to produce the same amount of circuit boards as two did previously. The steps of the line reduction process were:

1.

2.

3.

4.

The amount of time the line was in production was increased by running the line during the swing shift in addition to the day shift.

Maintenance was scheduled to be done in off time (graveyard shift), whereas previously one line was shut down for maintenance while the other ran.

The new control system was able to select the specific pattern of bath immersion required for different board production processes. Previously, when bath sequences needed to be changed, the production flow had to be interrupted.

Increased bath quality monitoring and maintenance allowed increased production flow without jeopardizing product quality.

By eliminating one plating line, the company saved $1 10,OOO a year.

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Sludge Reduction. In 1985, HP began to look at ways of reducing the amount of sludge produced while removing metals from water. Because removing more pollutants from the wastewater to meet increasingly strict standards will result in the production of greater amounts of sludge, the goal was to reduce sludge generation while removing greater amounts of pollutants from the wastewater.

Initially, new chemicals for removing metals from wastewater were tested. Although the new chemicals removed more metals from the water per unit of sludge produced, they were not as reliable for meeting the wastewater standards. The treated wastewater had concentrations of metals five times higher than is allowable for discharge. The reason the standards were not being met was that metals were not combining with the treatment chemicals and sinking during the initial stages of treatment."

Because different parts of the manufacturing process have varying loads of metals in their wastewater. HP found that by segregating these waste streams and treating them differently, wastewater treatment was improved. By segregating waste streams containing varying metal loads and treating them specifically, HP reduced the amount of sludge produced while still meeting the strict wastewater discharge standards.

Although it is difficult to predict how much money can be saved by applying waste minimization techniques to a particular facility, HP Sunnyvale's waste minimization efforts saved more than $100,000 a year through treatment improvement and $1 10,OOO through plating line consolidation, as well as reduced corporate liability for these processes and others.

N O T E S

For further information regarding this case study, contact Jean Stephenson at Executive Enterprises Publication Company, 22 West 21st St., New York, NY 10010-6904, (212) 645-7880. For additional discussion of HP's waste minimization program, see Crook, S. and Burquist, L. 1991 Wastewater Minimization Audit, Hewlett-Packard Co., 974 E. Arques Ave., Sunnyvale, CA. If these contaminants are determined to be hazardous, a permit would be required under permit-by-rule/tiered permitting. Barratt, D., Brooks, D., Burquist, J. and Stennick, R., VenMet Solution Reduction of Solid Waste at Hewlett-Packard, Sunnyvale; Proc. of the Purdue Univ. Industrial Waste Conference, 1991.

The result of HP Sunnyvale's sludge minimization program was a 65 percent reduction in sludge production and a $l00,OOO annual savings in hazardous waste management costs.

These three case studies: The Bottom Line. The goals of HP Sunnyvale's waste minimization program were to reduce the amount of solid waste sent to landfill, reduce the amount of metals used to plate boards, and recycle the metals used to plate boards. The challenges were to maintain product quality and remain in compliance with wastewater discharge limits for metals while meeting these goals. HP Sunnyvale solved these problems by making manufacturing process changes, recycling metals both onsite and offsite, and segregating waste streams. The segregated waste streams were treated using innovative techniques for metals removal.

illustrate distinctive waste management practices for three different industrial plants varying in type of work and size;

demonstrate the technical and economic feasibility of implementing waste minimization techniques at each site; and

demonstrate the availability and utility of waste minimization options for similar industrial facilities.

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This facility blends and fills aerosol containers with a variety of janitorial (industrial and household) chemical cleaning products. The production process is done on a batch basis, with each formulation consisting of a specific blend of water, organic solverits, and anhydrous compounds. The organic solvents used in the products are methylene chloride, 1,l -dichloroethene, and 1 , 1 , 1 -trichloroethane. Alcohols and glycol ethers are also used.

The main features of the operation prior to implementation of waste minimization techniques are summarized below:

Original Blending and Aerosol Container Filling Process The organic chemicals, stored in two tanks, were taken to five mix tanks, where products were mixed in batches. Following mixing, the content was pumped to an aerosol line for filling into containers. The full containers were taken to a “gassing room” where propellant was injected into the cans. Following this process, the pressurized containers were taken to a hot water bath where the cans were leak tested.

Wastewater was generated primarily by the formulation process, during batching and rinsing of the mix tanks. There were very few wastewater releases from the fdling process. However, there was a potential for waste to be generated in the hot water bath leak testing procedure conducted for the aerosol cans. Material that leaked remained in the bath, which overflowed to the waste discharge system. Wastewater discharges from the facility ranged from 800 gallons per day to 3,600 gallons per day, depending on the level of production. Wastewater was passed through a clarifier prior to discharge to the sewer.

As a result of the company’s wastewater discharge violations, it was directed to assess and resolve its noncompliance problem. In response to the probation orders, the company completed an evaluation of its industrial process and identified three waste management options:

Option 1: Install an end-of-pipe pretreatment system without implementing waste minimization techniques.

Option 2: Install and implement waste minimization techniques such as process changes, operational modifications, partial recycle and reuse of wastes, and installation of a small pretreatment system for the remaining contaminated wastewater.

Option 3: Install and implement waste minimization techniques to modify the manufacturing processes and operational practices, thereby creating a closed loop system, which would result in 100% recycling and reuse of materials and wastewater.

After a technical and economic evaluation of these options, the company concluded that the third option was the most cost effective, and elected to implement it. The key features implemented at the facility, which include modifications of operational and housekeeping procedures, are listed as follows.

All water phases of the product formulation are batched in the same tank. By designating a tank for the water-based phases, no washouts are required between batches.

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Leftover batches are saved for the next batch.

If a formula group batch change is required in a tank, deionized water is used for tank washout. The rinse/washout is recycled.

Washouts and leftover active ingredients are saved for the next batch.

The schedule for batching and formulation has been developed to rotate compatible products to maximize the reuse of leftover washouts and active ingredients.

The implementation of these waste minimization measures resulted in zero discharge to the sewer. In addition, by implementing operational changes that involved relatively low first time costs, the company has realized savings in the operational costs of running the plant.

Advantages of the Company's Selection In addition to the environmental benefits of the option selected, the selected waste minimization strategy also afforded the company some compelling economic advantages, which are highlighted below:

Avoided onsite capital costs (for a pretreatment system) of approximately $100,000 and operational and maintenance costs of $25,000 annually.

Eliminated compliance costs for permits, monitoring and enforcement of approximately $5,000 annually.

Reduced production costs through recycling and reuse of materials and better management and efficiency.

Eliminated use of sewerage system cost of approximately $1 ,OOO annually.

This company strips the paint off large parts of old automobiles. Parts are cleaned in hot caustic solutions and stripped with muriatic and phosphoric acid. After the cleaning and stripping processes, the parts are rinsed.


Original Strippingcleaning Process Before pollution prevention measures were implemented, the paint stripping at this facility was done in a 9,500-gallon tank that held a caustic solution heated to 110-120'F. The car parts were submerged in the tank and drip dried over trenches. An additional spray rinse was performed in a separate area. The facility also had a tank containing a 20 percent solution of muriatic acid that was used to remove oil, dirt, or oxide on metal parts as needed. The parts that had been pickled in acid were rinsed in the same spray area that was used for rinsing the parts dipped in caustic. After stripping and cleaning, parts were phosphatized by immersion in a bath of 15 percent phosphoric acid. This last step of surface

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treatment was to provide a good surface for paint bonding. Caustic cleaning was the main operation taking place at this facility, while muriatic acid and phosphoric acid treatment was intermittent.

None of the tanks at the facility were contained; all drippings and spills were wasted to the sewer. Spent caustic and acid solutions were discharged to the trenches, where they neutralized each other, and the accumulated solids were removed from trenches manually. The rinses contained chromium and zinc, and on occasion high levels of lead from paints. Wastewater discharges from the facility ranged from 3,000 to 7,000 gallons per day; no treatment was provided prior to discharge.

As a result of the company’s heavy metals discharge violations, the company was directed to assess and resolve the noncompliance problem. The cause of the noncompliance was attributed to the lack of an effective waste management program to reduce the level of contaminants in the rinse wastewater discharged to the sewer system.

To resolve the problem on a long-term basis, the company was required to conduct an industrial waste survey and implement a waste minimization plan under the provisions of a Probation Order. The company was notified that if compliance would not be achieved through implementation of waste minimization techniques, it would be required to install a pretreatment system to remove the heavy metals in the waste streams.

This company completed the evaluation of its industrial process and identified two waste management options:

Option 1: Install an end-of-pipe pretreatment system to treat approximately 5,000 gpd of wastewater for heavy metals, without implementing waste minimization techniques.

Option 2: Install and implement waste minimization techniques to modify the manufacturing processes and operation practices, as follows:

1) a 6,000 gallon static rinse tank added as an intermediary rinsing step before spray

rinsing. Spray rinsing would be performed only if needed after rinse in the static tank. The spent rinse water is recirculated to the hot caustic tank to make up for spent caustic solution; and

contain tank and capture drippings and spills. Recycle to the solution tanks.

After conducting an economic evaluation of these two options, the company concluded that the second option was the most cost effective, and elected to implement it.

Advantages of the Company’s Selection In addition to the environmental benefits of the option selected, it also provided the company the following economic benefits:

Avoided onsite capital costs of approximately $30,000 (for a pretreatment system) and operational and maintenance costs (for waste pretreatment) of $7,000 annually.

Eliminated transportation and disposal costs for offsite wastes.

Reduced compliance costs for permits, monitoring and enforcement of approximately $2,000 annually.

Lowered risk of spills, accidents, and emergencies.


Reduced use of sewerage system.

This tomato processing company operates two facilities at one location: a cannery, which fills cans of ketchup, formulated sauces, beans and salsa; and a can manufacturing facility that makes cans from pre- painted and lacquered steel sheets.

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original Process The preparation of ketchup, salsa, and other tomato products first requires the processing of tomatoes into hot, broken pulp that serves as the raw ingredient for the tomato products. The graded tomatoes are received at truck stations, dumped mechanically and washed free of soil and debris. The dumping into water cushions the fall, softens the mud adhering to the fruit, and depending on the length of the flumes, provides rinsing and soaking. “Fluming” occurs at several points in the process and transfers the tomatoes between processing stations in the plant.

Following unloading and “dumping”, the tomatoes are hand sorted, peeled, stewed, cooked and mixed, then canned. All of these processes involve considerable amounts of water and waste. For instance, fluming consists of sluicing the tomatoes with water to points of delivery. This step in the processing of the tomatoes was estimated to contribute up to 30% of the BOD and wastewater. Also, the peeling process involves steaming the tomatoes to 2W0, then rinsing in cold water, which causes the peel to “explode” off the pulp. This process was estimated to contribute about 33% of the BOD and wastewater. Also, unpeeled tomatoes were disposed as waste, which added to the BOD content.

Can making involves cutting, bending and welding into cylinders. Welder non-contact cooling water is recirculated through a chiller. The cooling system is a closed system; therefore, it does not have continuous blowdown and make-up. The entire circulating water volume is changed twice a year and sent to the sewer. Can washing and filling consumed and discharged large volumes of water. The facility jet-sprayed inverted cans. Wash water was mixed with plant washdown from food processing areas.

The facility has extremely variable operations that result in waste discharges ranging from four million gallons per day (MGD) to 0.5 MGD. The biological oxygen demand (BOD) in the waste ranges from 40,OOO-60,000 pounds per day to 4,000 pounds per day. Due to the seasonal nature of the operation, most of the BOD and flow is discharged June through September. At peak loading, this facility’s discharge represented approximately 10% of the entire Districts’ BOD discharge to the ocean.


The company was informed of the Districts’ BOD policy and the need to implement a waste management plan and/or install pretreatment equipment to meet the BOD limits of 10,000 pounds per day over a 30-day period and 15,000 pounds per day as a daily maximum. Based on these limits, the company was required to reduce its BOD loadings by approximately 25,000 to 45,000 pounds per day in order to resolve the noncompliance problem.

The company evaluated the effectiveness and economic feasibility of different waste management options, and selected three possible options:

Option 1 : Install a biological pretreatment system, without implementing waste minimization techniques, to treat over four MGD and remove up to 4,500 pounds BOD per day. The cost of this pretreatment system was estimated to be $8-10 million.

Option 2: Install and implement waste minimization techniques such as process changes, operational modifications, and install a smaller pretreatment system for the remaining contaminated wastewater.

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Option 3: Install and implement waste minimization equipment exclusively, as follows:

1) Studies conducted during the waste minimization evaluation indicated that the tomato peeling process is a major contributor to BOD loading and wastewater. The comphy has evaluated the use of a European tomato peeling system that uses vacuum to “explode” the peel off the tomato instead of cold water rinsing. The use of vacuum results in the virtual elimination of the cold water rinsing step that uses high quantities of water. This technology has been installed at other facilities and has resulted in a 25% reduction in OD.

2) The tomato unloading and conveyance system (fluming) was also determined to be one of the major contributors to wastewater volume. Modifications of the fluming process are expected to reduce waste. Some difficulties were encountered because of space availability at the site. However, new high capacity solids separation equipment is being evaluated at another plant and will be installed at this plant if proven successful in reducing BOD loading.

3) Tomatoes that remain unpeeled or partially peeled in the peeling step will be transported to another facility instead of being dumped to waste. Also, part of the processing of the tomato pulp base will be performed at other facilities that are closer to the fields where the tomatoes are being harvested.

4) Waste minimization opportunities applied to the tomato stewing process, sorting, washing, and conveyance (such as rinsewater recycling and improved housekeeping) were implemented. (This resulted in an approximate 30% reduction in water usage.)

After an economic evaluation of the above three options, the company selected Option 3 as the most cost effective and practical option.

Advantages of the Company’s Selection The company realized the following benefits due to its implementation of waste minimization strategies:

Avoided onsite capital and operation waste treatment costs of about $2 million.

Reduced transportation and disposal costs for offsite wastes.

Reduced compliance costs for permits, monitoring and enforcement.

Lowered risk of spills, accidents, and emergencies.


Cost savings of approximately $1 million due to reduced use of sewerage system.

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REDUCING AIR EMISSIONS

In the context of California’s air pollution control programs, pollution prevention can generally be defined as the reduction in, avoidance, or elimination of the use of processes, products, fuels, and related activities that result in the release of air contaminants deemed detrimental to public health and the environment. “Add-on” controls reduce or control gaseous emissions at the point of release to the atmosphere, rather than change the process by which emissions are generated. On the other hand, pollution prevention aims to reduce the generation of air contaminants through substantial changes in critical parts of a process or product manufacture or use. This can be brought about by changes in the raw materials used, product design, production processes and energy requirements, product recovery, housekeeping practices, and commuter/ consumer attitudes.

Pollution prevention for stationary sources can be achieved through changes in product design or manufacturing processes within an industrial plant, product reformulation or substitution, changes in raw materials or feedstocks, operational housekeeping improvements, product recovery, or fuel recircula- tion methods, any of which are an integral part of the production process or cycle.

Pollution prevention as applied to mobile sources can be achieved through strategies designed to result in

less polluting fuels (reformulated gas or alternative fuels), reduce the need for vehicle trips in areas adversely affected by motor vehicle-related pollution, or produce motor vehicle innovations that are inherently nonpolluting (such as electric vehicles).

Pollution prevention can occur through process changes brought on by regulation requirements, and also can be stimulated by monetary and educational incentives. This chapter discusses pollution prevention approaches in regulatory requirements, incentives, growth management, and cross-media program efforts, and gives example “case studies” for air pollution minimization.

POLLUTION PREVENTION THROUGH REGULATORY REQUl REMENTS

California’s air pollution regulation development occurs at the State and local levels. At the State level, the Air Resources Board (ARB) develops and enforces mobile source regulations such as the recently adopted regulations for low emission vehicles (LEV), clean fuels and reformulated gasoline, and consumer-related area sources such as regulations for consumer products. With respect to stationary sources, the ARB develops regulations for the minimum required control of toxic air

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contaminants and guidelines for the control of criteria pollutants. Local programs, in turn, develop equivalent or more stringent measures and enforce criteria and air toxic contaminant regulations for stationary sources.

Traditionally, regulations for stationary sources are nonprescriptive, allowing industry the most flexibility to meet specific emission standards. Consistent with the intent of both federal and State clean air legislation, many regulatory requirements have resulted in the use of pollution prevention approaches, such as the reduction or avoidance of pollution-generating activities or products.

STATIONARY SOURCE REGULATIONS ATTHE LOCAL LEVEL

Under State law, the local air pollution control districts have the primary authority for the control of stationary sources. Typical examples of pollution prevention strategies at stationary sources that have resulted from the regulatory process include:

product reformulation: products that use solvent- based coating solutions are reformulated to use water-based solutions;

process modifications: rather than spraying an acidic, toxic solution to clean electrical components, the procedure is replaced with a new, less polluting process (e.g., using rotating brushes to scrub the material down);

equipment redesign: changes in the manufacturing process are made to reduce the amount of solvent needed to keep equipment clean or avoid contamination; and

housekeeping: proper training and more frequent maintenance procedures are included in regulations to minimize releases of air contaminants from leaks or malfunctioning equipment.

STATIONARY SOURCE REGULATIONS ATTHE STATE LEVEL

CALIFORNIA’S AIRTOXICS PROGRAM

California’s air toxics program is a two-phase process that separates risk assessment and risk management in the identification and control of toxic air contaminants. This program has significantly reduced toxic air emissions and is committed to the concept of pollution prevention. Each phase of this program presents opportunities for pollution prevention.

To identify a compound as a toxic air contaminant, the ARB utilizes human risk information developed by Cal/EPA’s Office of Health Hazard Assessment and exposure data collected by the ARB. This identification process is an act which, by itself, has proven to be an effective pollution prevention action. Once a compound is formally identified, industry is put on notice that it may soon be regulated. There are documented cases where industry has voluntarily reduced its use or production of an identified toxic air contaminant prior to action by the ARB, thereby preventing toxic emissions and avoiding regulation.

In developing regulations, the ARB looks at a variety of methods for control, including source reduction and substitution of less toxic alternatives, as required by the legislation implementing this program. To date, four of six control measures have incorporated pollution prevention principles. For example:

To comply with the technology-forcing chrome plating regulation, many platers will have to use both a change in their plating process and sophisticated emissions control equipment to meet the low emission levels needed to protect public health.

The regulation for serpentine roads does not allow the use of serpentine rock with greater than five percent asbestos-a clear example of preventing emissions in the first place.

The regulation for cooling towers prohibits the use of hexavalent chromium in the circulating water.

In all, over 1,500 facilities in the State are affected by these four toxics regulations that require some pollution prevention actions.

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Until recently, little data were available to assess the amounts, types and health effects of toxic chemicals released into the air and the potential risk to the exposed population. The Air Toxics “Hot Spots” Information and Assessment Act of 1987 mandated the implementation of a program to collect and evaluate information concerning the amounts, exposures, and short- and long-term health effects of hazardous substances regularly released to the atmosphere from specific sources.

The “Hot Spots” program collects emission data, identifies facilities having localized impact, ascertains health risks, and provides notification to the public. To date, over 3,000 facilities in the first phase of the program have submitted inventories and it is estimated that the “Hot Spots’’ Act will ultimately reach over 25,000 facilities.

Facilities prepare comprehensive emission inventories of listed toxic substances that are released into the air. The list of substances is updated periodically as needed, and currently includes over 700 substances. The information is compiled by the ARB, where the data are maintained in a statewide air toxics emissions data system. Facilities are required to update their inventories biannually.

The “Hot Spots” Act provides substantial benefits by identifying and locating sources of toxic emissions and providing exposure and risk analyses. This information directly supports California’s air toxics program by providing an inventory for use in focusing the direction and development of the control measures themselves. Again, it is interesting to note that a number of facilities in the State have voluntarily reduced their emissions in light of California’s “Hot Spots” and air toxics programs.

M O T O R VEHICLE-RELATED MEASURES

With regard to pollution prevention approaches for mobile source-related air pollution, several strategies have been adopted at both the State and local level that result in significant emissions reductions:

Transportation control measures (TCMs) These strategies are designed to reduce vehicle miles traveled and trips, and increase vehicle occupancy. These goals are achieved by developing attractive and convenient altematives

to single occupancy vehicle use. Examples of TCMs include ridesharing programs, transportation infrastructure improvements such as adding bicycle and high occupancy vehicle lanes, and expansion of public transportation.

Indirect source review programs Indirect sources are facilities that attract or generate motor vehicle activity, e.g., commercial areas or shopping malls, entertainment venues, tourist attractions, or residential developments. California clean air legislation and regulations require indirect sources to mitigate their impact where necessary to attain the State’s clean air standards. To this end, local governments and regulatory agencies require at the design phase of such proposed projects the incorporation of features that will reduce the need for vehicle trips to and from the source. Such features can include improved transit access, mixed uses of the land to enable workers to live in closer proximity to proposed employment and retail centers, and aggressive public information and marketing efforts to educate the public on the availability of the more attractive and convenient altematives that the source provides to single occupancy auto use.

Mobile source regulations The State is responsible for controlling emissions from the operation of motor vehicles in California. Rather than mandating the use of specific technology or the reliance on a specific fuel, the ARB’S motor vehicle standards specify the allowable grams of pollution per mile driven. In other words, the regulations focus on the reductions needed rather than on the manner by which they’re achieved. In September 1990, the ARB adopted a new set of “ultra clean” cars/fuels regulations, based on the key tenets of the pollution prevention approach. The new standards will require manufacturers to phase in production of cars that are 5034% less polluting than 1993 Califomia models, between 1994 and 2003. The key to meeting the standards will be the cooperation of the auto and fuels industry in the design of motor vehicles and fuels that can best meet the more stringent standards, while guaranteeing to the American public that driveability, quality and cost will not be adversely affected.

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Another form of pollution prevention that can reduce emissions of both toxic and criteria air pollutants is to require cleaner-burning fuels. The ARB has implemented a program that will result in the introduction of cleaner gasoline and diesel fuel, as well as alternative fuels for vehicles.

The “ultimate fuel” is one that results in zero emissions, thereby eliminating the need for any add-on controls to reduce automotive exhaust or evaporative emissions. Beginning in 1998, the ARB will require that 2% of new vehicles sold be “zero emission vehicles”, or ZEVs. These ZEVs will likely be electrically powered by batteries that are charged by electricity from power plants. Alternative ZEVs would be powered by solar energy, fuel cells, and hydrogen. The goal of the ARB’s clean fuels program is the use of technology-forcing emissions standards that will encourage auto manufacturers and fuel suppliers to meet the requirements through increased reliance on ZEVs.

CONSUMER PRODUCTS

The ARB has the responsibility and authority for controlling air pollution from consumer products. The ARB has adopted regulations reducing smog- forming components found in various consumer products. Such regulations are patterned in a pollution prevention approach and will result in the redesign or reformulation of hundreds of consumer products to achieve the tighter VOC content limits required under the rules.

INCENTIVES APPROACHES TO POLLUTION PREVENTION

Whereas most pollution prevention strategies are geared toward making technological and design “fixes” throughout the production and use cycle, all involve some form of behavioral changes, even at the point of manufacture, from the routine way of doing business. The issue that will need to be addressed in establishing pollution prevention goals and policies is whether such changes can be facilitated through a range of incentives that include technical guidance, fee-based deterrents, market-based incentives, or educational assistance.

TECHNICAL CUI DANCE

The ARB, working in conjunction with local districts, has published numerous documents describing the

latest state-of-the-art control technologies affecting controls of various categories of sources. Many of these guidance documents offer technological fixes (many of which could be considered as pollution prevention) for existing processes that are less efficient and higher polluting. Overall cost estimates for these new technologies are included within the technical reports.

The ARB’s Compliance Assistance Program takes an educational approach, targeting at those working in specific polluting industries. The program is based on the idea that most sources will comply if they understand the rules affecting them. The program encourages, through the use of easy-to-understand informational handbooks, increased source self- inspection and self-regulation to lower emissions. The handbooks are targeted for the industry labor force, with more detailed technical inspection manuals available to industry environmentalhafety and compliance managers. As a result of this program, emissions that otherwise may have been released are avoided altogether.

The ARB has also developed regulations that motivated manufacturers to produce greater quantities of lower polluting products that were less costly to manufacture. For one example, the ARB incorporated manufacturing cost considerations into the control strategy by limiting the manufacture of higher polluting products to smaller container sizes that were more costly to produce.

MARKET-BASED INCENTIVES

The ARB and the South Coast Air Quality Management District are actively considering several approaches that would facilitate the attainment of clean air standards through measures that regulated sources would find economically advantageous to implement. One proposal under consideration that applies pollution prevention approaches is the concept of the declining value or phase down permit. Under such an approach, the State or local district would work with a regulated source with multiple emissions points in developing a pollution reduction program that would phase down total emissions over time. The regulating agency would establish the interim and final emissions cap for the source; the source would be responsible for determining the manner in which the reductions would be achieved by the target dates. This phase down approach

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would provide the flexibility needed to provide for reductions using technologies or other mechanisms available to the source that makes the most economic sense to that facility. This approach is especially applicable to those categories of sources where the resources necessary for the regulating agency to administer and enforce a command and control approach are not available or feasible. Such may be the case with the two categories the ARB is considering for the phase down approach-airports and railroad operations.

Issues related to the concept of the phase down approach include which sources to include in such a program, how to quantify or credit reductions, whether and how to use “reduction ratios” so as to encourage greater and expedited reductions of pollutants that are of a higher environmental risk, and development of “safety valves” to expand or tighten the permit system without penalizing sources already in the system.

PUBLIC E D U C A T I O N

The ARB engages in various public education activities oriented toward pollution prevention. These have included speaker presentations, production of literature, video tapes and displays for various forums, and participation with other groups in producing materials and curricula. In the past, these efforts were mostly directed toward increasing public awareness of the severity of the air pollution problem in Califomia. More recently, these efforts have expanded to informing the public about its role in causing and preventing pollution. Through these efforts, Califomians are learning that they can play a significant part in preventing pollution through personal or group choices in a range of issues from transportation to personal care products.

GROWTH M A N A G E M E N T AND ENERGY CONSUMPTION

California’s population is expected to grow by ten to fifteen million people by the year 2010, a 33 to 50 percent increase over the next two decades. Without a significant improvement in all areas of pollution control, this population growth will gradually erode the benefits of adopted control measures. The greater vehicle use, area source growth, and

economic expansion that accompanies population growth could result in a cumulative increase in emissions, despite reductions from individual sources. Therefore, a pollution prevention approach is needed to complement the current control program to ensure that the effects of growth do not “offset” current emission reductions. A pollution prevention approach to growth management requires the incorporation of air pollution considerations in the earliest stages of land use plan development and design of transportation systems.

Current State and federal laws (Califomia and federal Clean Air Acts, Califomia Environmental Quality Act, etc.) require that local governments attempt to coordinate land use plans with the regional transportation and quality plans. Until recently, coordination has been essentially voluntary. The 1990 revision of the federal Clean Air Act strengthened the requirements for findings of conformity as a precondition for federal funds for transportation projects. Similarly, the California Clean Air Act requires coordinated development of regional transportation and air quality plans. In keeping with these more stringent requirements, the ARB has increased its efforts to offer appropriate plan development assistance to local agencies and to augment its plan review capability to determine that realistic plans are indeed prepared. The planning, modeling, and analytical tools needed to tightly link air quality, land use, and transportation are still in their infancy. The ARB, through its research program and through cooperation with Caltrans and other public agencies, is working to advance the “state of the art” in transportation and air quality modeling in order to facilitate more sophisticated planning in future years.

Population growth will also place additional demands on the State’s energy resources. Total energy use could increase by as much as 45 percent. At present, more than 90 percent of the State’s energy is derived from fossil fuel combustion, a major contributor to air pollution. Prevention of increased air pollution from energy production and use will require a sustained commitment to reducing fossil fuel consumption and accelerating efforts to attain new efficiencies in the production and consumption of energy.

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CROSS-MEDIA PROGRAM EFFORTS

Consistent with its recognition of multimedia pollutant transfer issues, the ARB has participated with its sister State and local environmental agencies in several pollution prevention projects that are geared to achieve comprehensive environmental results and avoid intermedia transfer.

SOLID WASTE AND A I R INTERFACE

As a result of state-mandated testing of solid waste landfills, the ARB and local districts developed a suggested control measure requiring installation of landfill gas collection and control systems at solid waste landfills to minimize potentially harmful releases of toxic compounds and methane gas at and around the site. In another related area, the ARB is working with the Integrated Solid Waste Manage- ment Board to develop new policies and programs that encourage reclamation and reuse of large recyclable containers to avoid incineration where not necessary.

HAZARDOUS WASTE AND A I R INTERFACE

The ARB and local districts work with the Department of Toxic Substances Control to ensure that all applicable and relevant air requirements are considered in the cleanup remedies that are selected for Superfund sites.

Because the use, treatment and disposal of hazardous materials can result in air emissions, the ARB, local districts, and the Department have shared responsibilities to minimize the potential for adverse air quality impacts from these activities. Meeting on a continuous basis, the air and hazardous waste control agencies work together to accomplish several environmental goals. These activities have included site-specific meetings to facilitate the permitting of environmentally acceptable projects, joint testing of site contamination and discharge points, the preparation of guidelines and procedures to be used in the preparation and review of risk assessments, review of air impacts of remedial actions for site cleanups, and coordination of inspections and enforcement actions.

STATE A I R BOARD CHROME PLATING POLLUTION PREVENTION DEMONSTRATION PROJECT

In February 1988, the Air Resources Board adopted an airbome toxics control measure (ATCM) to control emissions of hexavalent chromium from chrome plating and chromic acid anodizing operations. The ATCM contains both an interim requirement (95 percent control or 0.15 mg/amp-hr in 18 months) and a technology-forcing requirement (99.8 percent control, or 0.006 mg/amp-hr in 48 months) for platers that emit more than ten pounds of hexavalent chromium per year.

In response to this technology-forcing requirement, the Metal Finishing Association of Southern Califomia offered to carry out an eighteen month demonstration project and requested ARB testing support. The ARB accepted this proposal and directed staff to participate in the project. The following is a summary of the project results. It concludes that the stringent requirement of the control measure was consistently met during the project at shops believed to be typical of those that are subject to the ATCM requirement.

The project objective was to ascertain the achieveability of the two compliance options available to large plating facilities (those emitting over ten pounds per year of hexavalent chromium): a mass-based emissions limit of an 0.006 mdamp-hour OJ a 99.8 percent emission reduction requirement. A focus of this project was on the achievement of the 0.006 mdamp-hour limit by reducing emissions both at the plating tank using process modifications, and using an “on the roof’ conventional control device. The use of process modifications as a mechanism to reduce emissions at the source (the tank surface) prior to controlling stack emissions is more effective at reducing emissions than the exclusive use of add- on control devices. The ARB emphasized the pollution prevention approach because it believed it would result in the lowest emissions possible, consequently resulting in the greatest benefit to public health. This emphasis meant that the test results were focused on the achieveability of the 0.006 mghnp-hour limit over the achievability of the alternative requirement of 99.8 percent control.

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Sampling Location Electronic Chrome Electrolyzing 91 28 Dice Road Santa Fe Springs Los Angeles

1947 Hopper Ave. Chromal Plating 1748 Workman St. Los Angeles

Process Modifications Used During Testing

Sampling Dates

Chromal Plating 1748 Workman St. Los Angeles

Control Equipment Manufacturer

Operating Principle

Pilot or Full-Scale

Monsanto CM&E

Fiber Bed Mist Reduced Flow, Eliminator, Brownian Filtration Diffusion

Pilot Full Scale

I c. Polyballs Plus Mist Supressant

Tri-Mer

Wet Packed Scrubber, Flow Accelerator

Full Scale

I d. None of a, b, or c I

CECO

Inertial Impaction Brownian Diffusion

Pilot

Three types of control devices were tested: two Brownian motion/inertial impaction collection devices; a reduced exhaust-flow/filtration device; and a flow acceleration/filtration device. Two of these devices were full scale, and two were pilot scale. Those units selected for testing, host site test facilities, and the process modifications used during ARB-conducted testing, are shown in Table 4.

a. Polyballs Only

b. Agitation Air Only

The process modifications evaluated for this project included the elimination of air agitation and the use of floating polyballs and anti-mist additives. Figure 12 shows a typical hard chrome plating tank. Changes in four process parameters were evaluated for their chrome emission reduction potential: freeboard height (distance between the plating solution and the top of the tank), elimination of the use of compressed air for plating tank agitation (typically used to prevent thermal stratification of the

January 23-27 January 30-Feb 3 February 14-17

March 7

March 8-9

plating bath), the use of floating polyballs on the tank surface, and the use of anti-mist plating bath additive.

February 21 -24

March 10

Floating polyballs are polypropylene spheres (in this case about one inch in diameter), which float on the surface of the plating bath. They can be used in single or multiple layers and are typically used to retain heat in the plating bath, in addition to minimizing worker exposure to hexavalent chromium-containing mists by capturing and containing these mists in the tank. Anti-mist bath additives are also used to reduce mist formation and are of three types: surface tension reducers, foaming blanket, or a combination of bath surface tension reducer and foaming blanket. Plating bath additives can be used by hard platers but are more commonly used by decorative platers.

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AC current - F

Rectifier

+I

FIGURE 12

P L A T I N G TANK PROCESS P A R A M E T E R S THAT MAY AFFECT E M I S S I O N S

Emissions collected

generated during plating

Results Preliminary testing showed that using plating bath additives and floating polyballs resulted in lower emissions. Reductions of 85-96 percent were found relative to baseline (no polyballs and no bath additives) conditions.' The greatest emission . reductions were found (over 95 percent) when agitation air was eliminated and both polyballs and anti-mist bath additives were used together.

The test results are summarized in Tables 5 and 6. Of a total of fourteen tests conducted for this project, twelve, shown in Table 5, incorporated process modifications. The two tests shown in Table 6 did not. Test results show that all fourteen tests were in compliance with the ATCM by meeting one or the other requirements of the ATCM.

In some cases, both alternative requirements were met. The twelve tests that incorporated process modifications met the 0.006 mg/amp-hour requirement. Of these, five also met the 99.8 percent control requirement. The two tests of control device performance without process modifications, shown in Table 6, met the 99.8 percent control requirement.

All tanks incorporating process modifications and having a control device met the 0.006 mg/amp-hour limit, and some had emission rates that were much lower (0.001 mg/amp-hour). The combination of process modifications and a control device yielded lower emissions than did a control device only approach.

When both process modifications and a control device were used, low emission rates (less than 0.006) were achieved. In some cases, the control device efficiency was below 99.8 percent. This suggests that it may be difficult for some facilities to achieve both the 0.006 mg/amp-hour emission limit - and the 99.8 percent control (across a device). The ATCM does not require that both standards be met.

_-

Table 7 shows a comparison between emissions for the CECO and Tri-Mer devices, which were tested on tank exhausts both with and without process modifications. Table 6 shows that control device- only emissions were further reduced by approximately 50 percent when both process modifications and a control device were used.

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Control Device # of Tests Range

mglAmp-hr

Hexavalent Chromium Emissions

mglAmp-hr

Monsanto 3

C M & E 2

Tri-Mer 2

CECO 3

Tri-Mer 2

0.001 1-0.001 7

0.0040-0.0049

0.0002-0.001 4

0.0028-0.0035

0.0005-0.001 0

0.001

0.004

0.001

0.003

0.001

Note: Measured emissions are the result of both process modifications at the tank and a control device. All tests were run with polyballs and, for the first two devices listed, with no air agitation. The last of the Tri-Mer tests listed also included an anti-mist additive.

Control Device # of Tests

Hexavalent Chromium Emissions,

mglAmp-hr

Removal Efficiency,

Percent

CECO

Tri-Mer

0.008

0.001 8

99.9

99.9

Discussion A major focus of this project was to ascertain the role of process modifications upon emissions. The attainment of low mdamp-hour mass emissions and high percent removal efficiencies are competing goals. High removal efficiencies are easier to obtain if the process itself results in high concentrations of hexavalent chromium in the exhaust stack. The mass of hexavalent chromium emitted by the plating process on an mg/amp-hour basis tended to be lower when process modifications were used on the plating

tanks. Consequently, a reduction of the hexavalent chromium emitted at the tank surface was emphasized over leaving the mass of hexavalent chromium emitted by the tank relatively high and achieving very high removal efficiencies across a control device.

When testing a control device that is attached to a tank employing process modifications (floating polyballs on the surface and no air agitation), the inlet loading (mass of hexavalent chromium per

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Control Device

Tri-Mer

CECO

Were Process Modif icat ions

Used?

YES

NO

YES

NO

Control Device Inlet, Hex Chrome

mglAmp-hr mglhr ug ldscf

0.689 528 4.73

2.67 2930 22.93

0.523 194 7.99

8.4 721 30.56

FIGURE 13 EMISSIONS AFTER CONTROL

(mglAmp-Hr)

0.008 0.008

Mass Limit mpliance Line\

0.006

Tri-Mer Control Device CECO Control Device

With Process Modifications Without Process Modifications Compliance Zone

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volume of exhaust air) to the control device is typically lower than without process modification. Since the inlet loading is lower and the mean particle diameter probably smaller, control devices of the type tested would be expected to remove a lower percentage of the pollutant than in a case where the inlet loading is higher. This phenomenon could cause a control device to exhibit less than optimum removal efficiency and yet result in low emission rates. This explains why some control devices were able to meet the mass limit but not the altemative removal efficiency requirement.

Conclusion Pollution prevention is receiving growing emphasis as a means of environmental protection. This cooperative industry-government project has shown that the use of simple modifications to the hard chrome plating process significantly reduces

emissions of hexavalent chromium from this industry. Furthermore, the use of a systems approach-process modification and end-of-pipe stack controls--results in very low emission rates, hence minimizing the potential adverse impact of emissions on public health.

REFERENCES

Pacific Environmental Services. Report to the Metal Finishing Association of Southem California. Evaluation of the Impact of Selected Process Conditions on Hexavalent Chromium Emissions from Hard Chrome Plating Tanks. February 10,1989, pp. 7-16. US. P A . Status Briefing for the National Air Pollution Techniques Advisory Committee. Chromium Electroplating and Chromic Acid Anodizing, NESHAP. January 29-3 1, 1 99 1, pp 1-5.

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__

FIGURE 14

AVERAGE SYSTEM EMISSIONS

0.0°8 1 Compliance Line - CM&E Tri-Mer CECO

Process Modifications and Control Device

Compliance Zone

FIGURE 15

CONTROL EQUIPMENT PERFORMANCE (wlo Process Modifications)

Compliance Line -, 100 99.8

99

CECO 98

Tri-Mer Control Device

Compliance Zone

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T H E CLEAN A I R COATINGS TECHNOLOGIES PROGRAM

Because of the serious air pollution problems in the southern California area, the South Coast Air Quality Management District (a regional regulatory agency) implements what is possibly the most extensive air ’

emissions regulatory program in the nation. This program has provided incentives for individuals, businesses, cities, and whole communities to find alternatives for substances and processes that have been targeted for regulation by the District because of their negative impact on air quality. Southern Californians have demonstrated tremendous creativity, determination, and commitment to finding better ways of doing things. Attainment of the District’s air quality goals has had a mixed, yet profound, impact on the lives of those who reside, work, and invest in southern California.

Southern California Edison, as a component of this community, has a work force and customer base comprised of local residents. This company is sensitive about the harmful effects caused by the uncontrolled release of pollutants and contaminants in the air, and is especially concerned about the gradual erosion of certain segments of its customer base. Some say that many manufacturers and commercial businesses, especially those involved with coatings and printing, have decided not to expand in California (or move out of state) because of the ever-changing, more restrictive air quality regulations. Each time a business moves or closes, Edison loses a valuable customer. Each time an expansion is delayed, job opportunities are lost.

Most businesses would rather not relocate. The cost and risk of relocation is high. Regardless of location, there will be problems to face. Edison feels that there are alternatives to relocation. Most current air quality compliance problems can be

resolved with new technologies. In an attempt to retain its commercial and industrial customer base and improve the quality of the environment, Edison has taken a proactive approach to the problem, and has developed a series of innovative electrotechnology programs. The first is the Clean Air Coatings Program.

The Clean Air Coatings Program is directed at retaining Edison’s customers in the wood finishing, metal coating, automotive refinishing, and printing and converting industries whose current coating and curing processes do not comply with existing or projected air emission regulations. In order to avoid severe penalties imposed by the South Coast Air Quality Management District, these customers have three options: 1) changing to compliant coating and curing systems, 2) leaving the area, or 3) closing their businesses. Edison’s goal, and reason for the program, is to keep these customers in business and in Edison’s service territory. This is being accomplished through education, and the demonstration of coating and curing systems that do comply with air emission regulations, while improving product quality, increasing production, and reducing costs.

The program is implemented by a staff of trained energy services representatives who call upon and make presentations to qualified customers. Interested customers then come to Edison’s Customer Technology Application Center (CTAC) to demonstrate and test these technologies on their own products. Using state-of-the-art equipment and expertise provided by Edison, customers can experiment with powder, high solids, waterborne, and ultraviolet and infrared curing technologies.

CTAC’s one hundred seat facility is used to present Clean Air Coatings information to groups of customers, trade associations, industry, and other utilities about regulatory issues and innovations in technology. Authorities in the field of coating and delivery systems are routinely brought in from across the nation and from other countries to present information about the availability, advantages and limitations of environmentally friendly inks, coatings, adhesives, and curing systems.

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In addition, interactive video terminals are located throughout the facility. Their purpose is to display various interactive video programs, including one on ultraviolet curable coating systems. This technology combines the audiovisual capabilities of television with the random-access capability of computers. By touching menu items on the screen, CTAC visitors choose electrotechnology topics they wish to learn about, as well as the level of detail they wish to explore. In addition to explanations of how the technology works, the visitor can find out about its benefits, financial implications on typical operations, and view testimonials from users of the technology.

The specific menu and direct access of this system enable Edison customers and employees to get the precise, customized information they want in the least amount of time.

In the inaugural year of the Clean Air Coatings Program, nearly 10,000 commercial and industrial customers were identified. Over 1,000 customers, representing all four industry groups, were contacted. Another 1,000 individuals attended technical seminars, workshops, and conferences. Over 65 corporate customer projects were submitted to CTAC for evaluation and demonstration of various technology transfer applications.

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Alternative solutions, using compliant technologies, were found and recommended to 40% of the Clean Air Coatings corporate customers. Some examples of. successful transfer technology applications achieved at CTAC, and recommended to customers, are described below.

This company makes signal warning systems for railroad grade crossings. When managers of its southern California electronic components plant heard about ultraviolet (UV) curing technology, they were immediately interested. The company now saves an estimated $18,000 a year in protective coating costs, both tangible and intangible, compared with the water-based, air-dried coating used before. Safetran cut coating and curing time from 24 hours to two minutes by switching to UV, thus eliminating a major bottleneck in its assembly operation. Safetran kept air emissions to acceptable levels while increasing production, thus complying with South Coast Air Quality Management District air quality standards, and can now profitably remain in southern California.

Safetran implemented UV curing to replace a water- based urethane coating it had adopted two years previously in order to comply with South Coast’s stringent air emission standards for volatile organic compounds (VOCs). Even with reduced VOCs, the water-based coating brought only marginal air quality compliance for two reasons:

The varnish replaced by the water-based coating still had to be used to make repairs on existing boards, because the water-based coating was incompatible.

The water-based coating had to be applied on new boards in high volume to be effective. Two- thirds of the coating material evaporated uselessly into the air.

In addition, 24 hours of drying time were required before the completed boards were ready for testing, thus creating an obstacle to “just-in-time’’

production. The “just-in-time” production philosophy eliminates inventories as much as possible, thus reducing cost, by adjusting production rates to the number of outstanding orders. The goal is to get just enough product out the door, just in time to be shipped.

When Safetran managers decided to increase production, they realized that VOC levels would again be excessive, and they made a decision to adopt UV curing. They worked with the clean air coatings specialists at CTAC to find the best combination of UV curing device, coating material and application process.

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This manufacturer of specialized trucks and utility beds was under pressure to reduce the amount of VOCs that were being emitted through its spray painting operations. After trying a variety of primers and top coats without success, a CTAC representative suggested another alternative to the company, one that had previously been demonstrated at CTAC. High solids coatings are formulated so

that more solids (paints), and less solvents, which are the source of VOCs, are present in the mixture.

Using a high solids coating proved to be the answer for U.S. Coachworks. Not only did the changeover solve the emissions problem, but it significantly reduced the amount of coating required to cover each cab and chassis. This savings in material cost also represented a savings in labor costs. The applicators are now able to finish the cabs and chassis faster, thereby positioning the company for increased capacity.

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In addition to publishing a major newspaper, the Los Angeles Times also manufactures and coats its own newspaper racks. When its management contacted representatives of the Clean Air Coatings Program, its concerns were centered on two basic areas. First, there was a need to comply with air quality regulations governing the emission of VOCs and solid waste from spray coating operations. Second, the company wanted to reinforce its position as a leader in the business community for proactive environmental management.

After several discussions with Edison’s applications specialists at CTAC about the Times’ current coating operations, the alternative that were open to them, and after witnessing the results achieved from powder coating and infrared curing, the Times made a decision to convert its solvent-based coating operation to powder and infrared. This operational change will enable the Times to achieve compliance with air quality regulations, meet conservation goals, and maintain its positive public image.

In an attempt to comply with more restrictive air quality regulations promulgated by the Santa Barbara Air Pollution Control District, this manufacturer of heavy gauge housings for telephone equipment turned to Edison’s Clean Air Coatings Program for assistance.

Working with program representatives, the customer agreed to have some of its products tested at CTAC, using infrared to cure the powder coat. Based on the results achieved, the company purchased a large powder coating system to replace its traditional solvent-based wet coating operation.

Hendry Telephone Products is presently testing cure time and quality using infrared equipment loaned to it by an equipment manufacturer, and by Edison. During this period, the customer will also have the opportunity to consider the economic advantages offered by infrared technology.

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When Chino-based West Coast Samples, Inc., a manufacturer of swatch and sample books for the textile industry, learned that ultraviolet (UV) technology could be used in its silk screen printing process, the management installed a UV system to replace one of its conventional solvent-based printing lines.

Other major sample-book manufacturers in southem California, faced by similar constraints @e., increasingly stringent air quality regulations), chose far different courses. One downsized. One left the state and another left the country for perceived “greener pastures” south of the border. A fourth stopped operating entirely.

“In this day and age, you have to be environmentally safe to stay in business,” says Larry Barrios, president. “A lot of companies try to avoid the issue by relocating, but sooner or later, it catches up with you or you get tripped by other problems.” Barrios stood his ground and confronted the Southem California Air Quality Management District’s Graphic Arts Rule 1130 head on.

Process Description. Barrios and his late partner founded the company in 1972 as a full-service sample house. Their strategy was to provide quick order turnaround by maintaining complete control over the processes involved in sample book construction.

Employees begin by unfurling rolls of carpet and fabric. They cut the hundreds of feet of material into sample-sized pieces, then collate the colors and finish the sides of the swatches. In another part of the plant, employees print the book covers and backing pages with color codes and names. Finally, all the pieces come together for assembly and the product is shipped to U.S. textile manufacturers for distribution among the nation’s furniture and department stores, as well as to textile makers in Australia, Denmark and Italy.

Book runs range from 2,500 to 15,000 copies and can contain more than 100 different swatches. Each day, West Coast Samples has nearly 50 separate “editions” in the works.

The old silk screen system emitted excessive emissions of VOCs. It used inks that contained high amounts of solvents that emitted VOCs into the air when freshly printed pages passed through the line and were dried.

The UV system, by contrast, produces no noticeable VOC emissions, because UV inks contain no solvents. These inks are 100 percent solids. Ink is silk screened onto the substrate and then cured, or hardened, when the pages pass under the purple glow of the UV photo initiator. By installing a UV silk screen printing system, West Coast Samples replaced the environmental weak link in its production chain.

Plant design. When West Coast Samples was planning its move to Chino from La Puente, where the company was founded, it designed the new plant with a number of other innovative resource management mechanisms. For example, motion sensors turn off lights in empty rooms, timers

An oven that allows rotation of objects within an infrared curing zone provides a pollution-free method of reaching high temperatures for drying/curing.

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schedule equipment start-ups to preclude electrical spiking and photo cells turn on water faucets in the rest rooms. An extractor in the darkroom removes residual silver from hazardous developing chemicals, thereby enabling the company to recover a portion of the cost of its disposal operation. A filtering apparatus in the plant separates polyvinyl chloride glue from the waste water, which allows it to reuse a measurable amount of what used to be waste glue.

Results. seminar, West Coast Samples installed its first UV system. West Coast Samples learned that UV printing has been a proven technology for over two decades, and is becoming more popular as environmental awareness and regulation increases. Over 10,000 printers in the United States use it regularly to print everyday items such as cereal boxes, credit cards, gift bags food containers and coffee cups at fast food outlets. UV inks are superior to solvent-based inks because they produce a higher quality product while being easier and cleaner to use.

Three months after attending Edison’s

“We increased our productivity by two-thirds and that has allowed us to take on new customers and outdistance our competition,” Barrios says. “There’s no question about it. Everyone says UV is better to work with.” In fact, UV has made such a profound impression on their operation that Barrios has ordered another unit to replace their second silk screen printing line. Barrios estimates that the payback on the capital investment of each UV unit can be achieved within two years.

Switching to UV has allowed West Coast Samples to dramatically increase its line speeds. Line speed, using the old system, was 25 feet per minute. With the new UV system, line speed has increased to 60 feet per minute. Similar efficiencies will be achieved on the second line once it is installed.

West Coast Samples also discovered that UV inks are easier and safer to work with. Solvent-based inks

tend to dry on the printing screen, causing downtime while employees cleaned the screens and wiped the squeegees. UV inks remain in a fluid state until they come in contact with UV lamps. Also, the employees operating the UV silk screen line no longer handle solvents, thereby reducing their exposure to toxic materials. Barrios projects another considerable costs savings (the exact amount has yet to be determined), in that solvent purchases have been virtually eliminated. In addition, the life expectancy of squeegees should be greatly enhanced, since they are no longer subjected to solvent formulations.

West Coast Samples believes that, overall, UV inks are competitively priced. Although on a per gallon basis, UV inks can cost nearly four times more than solvent-based inks, they provide up to eight times more coverage than their VOC-laden counterparts.

Barrios capitalized on these advantages by enlarging other work stations along the production line. Thus, he expanded his entire company. When West Coast Samples left its 36,000 square foot La Puente quarters, it brought 90 employees to its new 63,000 square foot headquarters in Chino. Within a year of the move and UV installation, the payroll has increased to 175 employees. More hiring is planned as West Coast Samples positions itself for increased capacity.

CONCLUI ION

Edison’s Clean Air Coatings Program has many more success stories of customers accepting and changing to compliant technologies. This program demonstrates the advantages of changing to environmentally friendly inks, coatings, adhesives, and curing technologies. Because technology and customer needs are always changing, the Clean Air Coatings Program will continue to evolve and improve as emerging technologies are evaluated to meet customers’ current and future needs.

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WASTE MINIMIZATION IN SOLID WASTE

W i t h the passage of landmark state legislation in 1989 and 1990, waste management policymaking has changed dramatically. A dramatic shift away from reliance on landfill disposal of waste and toward source reduction, recycling, and composting began. The new California Integrated Waste Management Board was established to coordinate the implementation of these new waste management priorities. The Board is composed of representatives of both the legislative and executive branches of State government, a cooperative partnership to develop a forward-looking solid waste management system.

An estimated 50 million tons, or 55 percent, of California’s solid waste stream comes from residential sources; 22.5 million tons, or 45 percent, is produced by commercial sources. The distribution of this waste stream closely parallels that of the population. Nearly one half of California’s population resides in Los Angeles, Orange, and San Diego counties. Over half of the waste generated statewide comes from this three-county area.

The size of California’s waste stream will continue to grow as the population increases. Between 1980 and 1990, California grew by more than six million persons-an average of 609,188 new residents yearly. With a projected state population of 36.3

million residents in the year 2000, California’s waste generation will reach 60.4 million tons if present generation rates continue.

Most of the waste generated-close to 87 percent- is currently disposed in landfills. Recycling, by recent estimates, diverts about 11 percent of this waste from landfills. Within the next decade, many communities will experience severe solid waste disposal problems. Growth in population is contrasted with decreasing landfill capacity. Over a dozen counties could run out of landfill capacity in less than five years; at least another dozen by the year 2000. There is an urgent need to implement new methods of diverting waste from landfills.

M I S S I O N O F T H E I N T E G R A T E D W A S T E M A N A G E M E N T BOARD

The California Integrated Waste Management Board (Board), the designated lead agency for managing solid waste in California, has a variety of statewide responsibilities. These include:

1) the pursuit of waste diversion goals required by the Integrated Waste Management Act (Chapter 1095, Statutes of 1989, Sher);

2) protection of the public health and the environment from potentially damaging effects of

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solid waste management through regulation of solid waste facilities;

3) assistance to local agencies in developing waste management plans that outline strategies to achieve 50% diversion of solid waste from landfills by the year 2000,

4) research and development of improved waste management technologies; and

5 ) encouragement of markets to reuse recyclable materials diverted from landfills.

The following principles outline the mission statement for the Board:

1) Protect the public and the environment from any deleterious effects of the management of solid waste in California by establishing a State regulatory framework that addresses public health and environmental concerns but which also provides adequate flexibility to local govemments.

2) Promote the implementation of a waste management hierarchy that emphasizes source reduction, recycling and composting by providing State leadership, guidance and assistance to local agencies in developing local plans and programs that are consistent with State standards and goals.

3) Foster the development and enhancement of markets for recyclable materials collected through successful waste diversion programs.

4) Develop a proactive waste management policy focusing on research and development activities to identify new and innovative technologies as well as the early identification and mitigation of environmental impacts associated with existing technologies and processes.

5) Focus attention on progress toward achieving the mandated goals of the laws regarding integrated waste management.

6) Coordinate State and local activities toward achievement of these overall goals.

T H E B U S I N E S S A S S I S T A N C E T E A M

An example of the proactive stance the Board is taking to accomplish its goals is the Business Assistance Team. Its mission is to divert solid waste from landfills by providing business and industry with information and assistance to remove impediments and provide incentives for effective commercial waste management. The Business Assistance Team encourages the commercial/ industrial sector to implement resource recovery based on the strategy: Reduce, Reuse, Recycle, and Buy Recycled.

The Business Assistance team has developed the following goals:

1 ) Overcome impediments to source reduction, reuse, recycling and recyclables market development;

2) Exchange and disseminate information about effective waste management to the commercial/ industrial sector;

3) Facilitate networking and interagency coordination; and

4) Provide direct assistance to the commercial industrial sector.

Specific activities related to the Business Assessment Team’s goals include a California Materials Exchange Program, technical assistance for plastics diversion due to the complex nature and diversity of this waste stream, facilitation of large scale waste diversion and ongoing educational presentations and exhibits at business conferences.

C A L M A X , T H E B O A R D S M A T E R I A L S E X C H A N G E PROGRAM

CALMAX is a free service to businesses provided by the Board. It is a reuse program designed to help businesses find markets for materials they have traditionally discarded. The goal of CALMAX is to conserve energy, resources, and landfill space by helping businesses and organizations find alternatives to the disposal of valuable materials or wastes. Over ten years ago, resource managers in this country and Canada recognized that valuable materials were being discarded. To encourage the

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conservation of these resources, information networks were created to facilitate the reuse of material that had been considered waste. These information networks were called “waste exchanges” and were located in the heavily industrialized areas of the midwest and on the east coast. The purpose of the networks was to inform people of the materials businesses were discarding as well as what materials businesses needed.

Astute business managers have always recognized that the surpluses and byproducts of their operations may be of value to another business. However, as industrial processes have become more diverse and complex, it has become increasingly more difficult to know what kinds of waste are being generated and where they are being generated. Consequently, most business managers concentrate on production and profits. Very little attention is given to finding uses for the byproducts ro wastes. They are typically thrown away and end up in a landfill.

The basic concept of a materials exchange is extremely simple-ne business’s waste or surplus can be a resource for another business. Although many materials can be recycled, that is, changing its character to make another product (for instance, turning Styrofoam into park benches), a waste exchange attempts to find a use for the material without any change in the character of the material (i.e., finding someone who can use Styrofoam peanuts for packing material). The benefits of reuse over recycling are that 1) resources are not used in transforming materials into intermediate materials, and 2) there are no residual processing wastes generated. Additionally, because a materials exchange is an information network, it can also help find markets for materials that can not be reused by can be recycled.

CALMAX benefits California’s businesses and communities in the following ways:

0 New markets for excess materials will be encouraged and facilitated;

0 Disposal costs are reduced;

0 Economic development will be promoted by helping start-up businesses find free or inexpensive materials;

Environmental enhancement will occur as resources and landfill space are conserved by finding the use of materials is maximized;

Cities and counties will benefit from increased resource diversion as they prepare to meet California’s 50% waste diversion goal; and

Community improvement will occur as schools, art groups, and nonprofit organizations discover the wealth of free or inexpensive materials available to them.

LARGE SCALE DIVERSION FACILITATION

Waste paper represents a large percentage of the State’s solid waste stream. Every home and office in the State and the nation takes in and generates paper. The written word has historically been the most popular form of communication. Computers and copy machines have made people’s ability to generate paper easier than it has ever been. The medium of communication generates a waste management problem of dynamic proportions.

Paper comes in many grades. Examples include computer, white ledger, colored, newsprint, and mixed waste paper. The presently available paper processors are few, making cost recovery for collection and transportation difficult. Often, the only paper grades that can be economically recovered are computer and white ledger paper. The value of these paper grades has also decreased in the last year, making even these materials infeasible for diversion.

Waste paper offers a significant diversion challenge. The Business Assistance Team has been working to facilitate an increased diversion of all paper grades. One successful program has occurred in Red Bluff, with the surrounding communities. Cooperation between State offices, local government recycling coordinators, a nonprofit organization and a molded fiber products manufacturer is successfully accom- plishing diversion of most paper grades in this region.

The State offices and the communities’ curbside collection programs provide the paper. The recycling coordinators are responsible for the overall coordination of collection and transportation. A nonprofit organization that provides training and jobs

95

for developmentally disabled citizens collects, bales and transports the paper to the manufacturer. The manufacturer has the ability to process 4,000 tons of paper per month. The revenue from paper sales is high enough to make the operation cost effective.

The Business Assistance Team will document this interaction to educate other businesses about discovering how they can divert paper in their communities. The computer technology of tomorrow may change the way people communicate. But today, paper will continue to be a focus for diversion efforts.

RECYCLING M A R K E T PEVELOPMENT

While the Business Assistance Team is busy organizing the supply of secondary materials, the Board’s Recycling Market Development Zones program works on recycling business development to increase the demand for materials and add value to them.

A Recycling Market Development Zone is a place where “things happen” to add value to recycled materials. Zones are geographic areas that attract manufacturers of recycled products because of incentives provided by the community and local govemment and the availability of low cost feedstock. The idea behind a zone is the creation of a local consumer/processor or manufacturer to use recycled feedstock.

Development of a zone stabilizes demand for secondary materials, creates jobs for the local community and increases the value of materials with each step. Local governments, private industry and communities interested in encouraging economic development locally all play a role in zone development.

Today, waste materials are principally flowing one way into the ground from all sources: residential, industrial, and commercial. Landfills are not static systems. They are quite dynamic, generating toxic gases and other pollutants that can contaminate soil,

ground and surface water. In other words, they are environmental hazards.

With a market development zone, recyclable materials are directed to material recovery facilities that wash, sort and bale materials. These materials can then be shipped to a feedstock material processor. This company then sells its feedstock to recycled product manufacturers. As these companies grow, they create more jobs and provide more revenue for the local community.

As the business community generates more feedstock and the local communities provide incentives, additional manufacturers will be attracted into the zone. The public sector and non-profit organizations can also take advantage of the zone by locating recyclables drop-off centers, used oil collectors, or household hazardous waste collection centers in the zone.

By the first quarter of 1992, there will be eight of these recycling market development zones littered throughout the State. These zones will provide industries with incentives to manufacture goods made from secondary materials, formerly called waste.

Creating a demand for secondary materials is not only important for landfill diversion, it is also important for California’s economy. As this State and others compete in a farther-reaching world market, more efficient uses of our existing virgin and secondary resources must be found to remain competitive. Additionally, Califomia is paying a cost in environmental degradation that cannot be quantified, as minerals are mined, timber is cut and oil is extracted. And this cost increases as raw materials become ever scarcer. Califomia has an opportunity to discover the wealth it is currently discarding in its landfills. The Integrated Waste Management Board’s programs will assist in tapping this source to maximize resource use and landfill capacity.

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California Environmental Protection Agency

Department of Toxic Substances Control APPENDIX A

P.O. Box 806 Sacramento, CA 9581 2-0806

(91 6) 322-3670

Region1 - Sacramento Department of Toxic Substances Control 10151 Croydon Way, Suite 3 Sacramento, CA 95827 (916) 255-3545

Region1 - Fresno (Surveillance & Enforcement

and Site Mitigation only) Department of Toxic Substances Control 1515 Toll House Road Clovis, CA 93612 (209) 297-3901

(510) 540-2122

San Bemardino

Region3 - Burbank

1405 North San Fernando Blvd. Burbank, CA 91504 (8 18) 567-3000

245 West Broadway, Suite 350 Long Beach, CA 90802 (310) 590-4868

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APPENDIX B -~ ~

California Department of Toxic Substances Control Technology Clearinghouse December, 1992 ~

All reports are available at no cost to businesses, individuals, and govemment agencies throughout Califontia. Videos are appropriately priced. Current and obsolete publications are available as references at the Califmia Department of Toxic Substances Control (DTSC) Library and at any California library included in the Library Distribution Act.

I _I

HAZARDOUS WASTE SOURCE REDUCTION AND MANAGEMENT REVIEW ACT (SB14bZ’he preferred approach to waste minimization is source reduction. Source reduction is any activity that prevents or reduces the generation of hazardous waste: it does not mean reducing the volume or toxicity of an already generated waste.

Order # Title

001

002

Guidance Manual for the Hazardous Waste Source Reduction and Management Review Act of 198-B 14 (Includes Appendices) (1991, 159 pp.) SB 14 requires examination of current hazardous waste generating processes for hazardous waste minimization opportunities and creation of a plan to implement workable alternatives. Generators of hazardous waste in excess of amounts specified in the Act must prepare a Source Reduction Evaluation Review and Plan and a Hazardous Waste Management Performance Report by September 1,1991, and every four years thereafter.

SB14 Update (1991,5 pp.) Informs readers of the latest events that affect the implementation of the Hazardous Waste Source Reduction and Management Review Act of 1989. This issue announces the fmal regulations that complement the law, the SIC codes that DTSC is using to call in plans, the role of enforcement in the implementation of the program, the status of pretreated waste water as a major waste stream, and updates to the Appendices of the Guidance Manual.

WASTE MANAGEMENT FACT SHEETS-Specific in formution on handling, transport, storage, treatment, and/or disposal.

Order # Title

100

$9101

102

*lo3

Asbestos Handling, Transport, and Disposal (1990,7 pp.) The regulation of asbestos waste in California including waste classification, analytical methods, handling, transport, licensing, fees, and taxes.

PCB Handling, Treatment, and Disposal

PCB regulations in California along with additional material on PCB classification, handling, treatment, disposal, and the differences between State and U.S. EPA PCB regulations.

(1992,6 PP.)

Handling and Transport of Spent Lead-Acid Storage Batteries ( 199 1,5 pp.) Discusses special provisions developed by the Department to encourage the recycling of spent lead-acid batteries including storage, transport, and handling.

Used Oil: Handling, Storage, and Trans- port for Recycling (1992,8 pp.)

$9104

Discusses Califomia regulations on handling, storage, and transport of used oil for recycling: it’s easier, less costly, and more environmentally desirable than disposal options.

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Used Oil Filters: Handling, Storage, and Transport for Recycling (1992,4 pp.) Both the expense of managing and disposing of used oil filters as hazardous waste and testing them to see if they are hazardous can be avoided if they are recycled in accordance with these California requirements.

$9105 Lighting Wastes (1992,2 pp.) Discusses storage, transportation, recycling, and disposal of spent fluorescent light tubes and high intensity discharge lamps.

WASTE MINIMIZATION FACT SHEETS-A summury of waste minimization methods for specifi industries.

Order # Title

200

201 202 203

205 206 207 208 209

210

$9204

WASTE

Waste Minimization Can Work for You

A summary of general hazardous waste minimization definitions and techniques for businesses.

(1992,4 PP.)

Aerospace Industry (1992,4 pp.) Automotive Paint Shops (1992,4 pp.) Automotive Repair Shops (1989,4 pp.) Building Construction (1992,4 pp.) Commercial Printing Industry (1992,4 pp.) Metal Finishers ( 199 1,4 pp.) Paint Formulators (1992,4 pp.) Pesticide Formulating Industry (1992,4 pp.) Printed Circuit Board Manufacturers

Decorative Plating with Trivalent Chrome (1992,4 PP.)

(1992,6 PP.)

AUDIT STUDIES-Fullscaleassessments of speeifi industries that show where waste minimization methods can be most eflective.

Order # Title ~

300 301 Automotive Repairs (1987,69 pp.) 302 303 304

305 Fabricated Metal Products Industry

306 Fiberglass-Reinforced and Composite

Automotive Paint Shops (1987,99 pp.)

Building Construction Industry (1990,108 pp.) Commercial Printing Industry (1989,137 pp.) Drug Manufacturing and Processing Industry (1989,224 pp.)

(1989, 188 pp.)

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Plastic Products (1989, 164 pp.) 101

APPENDIX B WASTE AUDIT STUDIES (continued)

307

308

309

310

311

312

313 314 316

317

318

319

General Medical and Surgical Hospitals (1988, 182 pp.) Gold, Silver, Platinum, and Other Precious Metals Product and Reclamation (1990, 198 pp.) Marineyards for Maintenance and Repair (1989, 156 pp.) Mechanical Equipment Repair Shops (Includes Addendum) (1990,87 pp.) Metal Finishing Industry (Includes Project Summary) (1988,236 pp.) Nonagricultural Pesticide Application Industry (1991, 116pp.) Paint Manufacturing Industry (1989, 130 pp.) Pesticide Formulating Industry (1987,160 pp.) Printed Circuit Board Manufacturers (1989,234 pp.) Research and Educational Institutions (1988, 144 pp.) Stone, Clay, Glass, and Concrete Products Industries ( 199 1, 120 pp.) Thermal Metal Working Industry (1990, 195 pp.)

HAZARDOUS WASTE MINIMIZATION CHECK- LIST AND ASSESSMENT MANUALS-Assessment manuals developed to aid manufacturers in evaluating their shops for waste minimization opporhmities.

Order # Title

400 402 403 Paint Formulators (1991,40 pp.) 404 Pesticide Formulators (1990,20 pp.) 405 Printed Circuit Board Manufacturers

(1991,31 pp.) Auto Paint Shops (1992, 12 pp.)

Automotive Repair Shops (1988,47 pp.) Metal Finishing Industry ( 199 1,30 pp.)

$9406 $9407 Building Construction (1992,28 pp.)

FURTHER WASTE MINIMIZATION INFORMATION

Order # Title

500

$9501

502

101

Aerospace Waste Minimization Project-Fmal Report (1987,133 pp.) A feasibility study was conducted to identify and evaluate waste minimization technologies applicable to the aerospace and electronics industries. Eight wastestream categories were targeted for the application of waste minimization technologies and altemative management strategies.

Pollution Prevention in Caliiornia-An Overview of California's Pollution Prevention Programs (Sixth Biennial) (1992,110 pp.) The sixth biennial report to the California State Legislature. An overview of California's multimedia pollution prevention programs at the State and local government levels. Indusw pollution prevention case studies show how business responds to the pressure to reduce wastes.

Disposal of Heavy Metal Waste Sludges in Ceramic Products (1990,103 pp.)

503

504

505

H 5 0 6

w 5 0 7

508

509

510

51 1

A laboratory-scale test to determine the feasibility of incorporating heavy metal sludges into manufacturing ceramic products. The process can be economical and is technically sound.

Economic Incentives for the Reduction of Hazardous Wastes-Final Report (Includes Appendices) (1985,90 pp.) Addresses economic incentives for reducing the amount and toxicity of hazardous waste generated in California. The economic incentive mechanisms studied were grants, loan guarantees, interest subsidies, State-issued loans, tax credits, and depreciation deduction.

Pollution Prevention Technologies at General Dynamics-Pomona, Caliiornia (199 1,9 pp.) A variety of waste minimization technologies were technically and economically evaluated at an aerospace facility. Technologies range from computerized printed circuit board plating to solvent distillation.

Hazardous Waste Minimization Bibliography (1991,76 pp.) References are organized in four sections: (1) general hazardous waste minimization topics, (2) industry-specific, (3) material- specific, and (4) available abstracts from the previous three sections. All references are listed in alphabetical order by title.

Incinerable Hazardous Waste Minimization Project Fact Sheet (1992,8 pp.) Provides an interim update for the project using 1990 data taken from the manifest system.

Hazardous Waste Reduction: A Step-by-step Guidebook for California Cities (1992,180 pp.) Outlines the essential elements of a successful city run, multimedia waste minimization program. It is designed to walk the user through the steps the city can take to implement and reduce hazardous materials use and hazardous waste typically generated by city operations.

Incinerable Waste Minimiition Workshops Proceedings (1991,25 1 pp.)

_ _

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A compilation of the papers presented at two workshops held in January 1991. b a s covered include: regulations, source reduction, recycling strategies and opportunities, altemative technologies for petroleum refineries, electronics industry, aerospace industry, and chemical and paint manufacturers.

Low Cost Ways to Promote Hazardous Waste Minimization: A Resource Guide for Local Governments (Includes Resource Appendix B) (1988,102 pp.) Explains why and how to set up an educational outreach program. Provides complete resource listings for 28 lowcost activites. Model resolution, useful tables, and informative appendices are included.

No-Waste Lab Manual for Educational Institutions(1991,115pp.) A laboratory manual for introductory chemistry courses incorporating procedures that produce little or no toxic waste. This is accomplished by the use of consecutive chemical reactions so that the production of one reaction is used as the starting material for the next.

Metal Waste Management Alternatives1989 Symposium P" gs (1989, 252 pp.) Contains papers delivered at two symposia in September 1989. The papers discuss metal waste disposal restrictions and alternatives to disposal such as waste prevention and current recycling technologies.

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FURTHER WASTE MINIMIZATION INFORMATION (continued)

512

513

514

515

516

517

518

519

520

Minimizing Hazardous Wastes: Regulatory Options for Local Governments (1989,94 pp.) Describes regulatory framework that can be used to promote. hazardous waste minimization at the local level in California. Explores the mle of direct requirements, indirect regulatory inducements, and positive incentives. Model resolution and useful appendices included.

Reducing California’s Metal-Bearing Waste Streams (1989, 174 pp.) Analyzes alternatives to land disposal of California’s hazardous metal waste streams and focuses on methods that prevent waste generation. Source reduction, recycling, and treatment strategies are examined.

Reducing Industrial and Commercial Toxic Air Emissions by Minimizing Wast-The Role of Air Districts (1990, 120 pp.) Designed to assist Air Pollution Districts in reducing toxic air emissions and explains how waste minimization results in lower toxic air emissions.

Reducing Industrial Toxic Wastes and Discharges: The Role of POTWs (1988, 101 pp.) Explains importance of POTW (Publicly Owned Treatment Works) involvement in hazardous waste minimization. Provides educational and technical assistance and regulatory options for reducing hazardous pollutants. Model resolution and useful appendices are included.

Reduction of Solvent Wastes in the Electronics Industry (1988, 85 pp.) Hewlett Packard’s San Jose facility was used as a model to study the techniques required to reduce the volume and type of organic solvent wastes in the electronics industry. Up to a 70% reduction in organic solvent waste volume at the facility could be realized, thus saving the company up to $414,000 per year in disposal and chemical purchase costs.

Waste Minimization for Hazardous Materials Inspectors: Introductory Text with Self-Testing Exercises (Module l), Assessment Procedures (Module 11, Unit l), and Metal Finishing Industry (Module III) (1991, 182 pp.) Module 1 is written for use by both experienced and novice hazardous materials inspectors who wish to leam more about hazardous waste minimization. Module 11 provides basic information in conducting a self-assessment, and Module I11 focuses on some of the viable waste minimization alternatives for certain metal finishing operations. (Videotape also available-See Order #1500)

Waste Minimization Assessment Procedures: For the Generator (Module II, Unit 2) (199 1,8 1 pp.) Provides the hazardous waste. generator with procedures for conducting a self-assessment and introduces the provisions of Senate Bill 14, the Hazardous Waste Source Reduction and Management Review Act of 1989.

Pollution Prevention Assessment of the Office of the State Printer (1991,42 pp.) Provides the findings of a pollution prevention assessment of the State Printing Plant and can serve as a waste minimization guideline for printers in California.

Waste Minimization Opportunities for Selected City of Los Angeles Hazardous Waste Generating Operations (1990, 143 pp.)

521

522

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APPENDIX B Summarizes a joint effort between the City of Los Angeles and the DTSC to identify and evaluate waste minimization opportunities for selected city operations.

Waste Minimization: Small Quantity Generators at Los Angeles International Airport (1990,49 pp.) Summarizes the results of a study that involved visits to five representative small-quantity generators and targeted waste minimization of used oil and jet fuel, cleaning operations, and paint stripping.

Waste Reduction Strategies for the Printed Circuit Board Industry (1987, 115 pp.) An assessment of the feasibility of achieving significant reductions of hazardous waste generated by the printed circuit hoard industry. -

Final Report-Source Reduction and Technical Assistance Program (1992,40 pp.) Describes the effort to develop a program to train a city’s planning and building inspection staff to recognize industries that will generate hazardous waste so they can refer businesses to a technical assistance program. The project had mixed success and contains valuable recommendations for other agencies considering similar programs.

RESOURCE RECOVERY-Znformation on the use, reuse, or reclamation of hazardous constituents.

Order # Title

600

601

602

604

606

California Waste Exchange Directory (updated annually) (1992,28 pp.)

California Waste ExchangeA Newsletter/ Catalog (updated annually) (1992,49 pp.)

Listing of commercial recyclers.

Listing of hazardous wastes and materials both wanted and available.

California’s Compilation of Hazardous Waste Recycling Laws (1992, 17 pp.) Lists excefpts from the California Hazardous Waste Control Law specific to recycling in California. Laws specific to the recycling of used oil are not included.

Guide to Oil Waste Management Alternatives for Used Oil, Oily Wastewater, Oily Sludge, and Other Wastes Resulting from the Use of Oil Products-Final Report (1988,220 pp.) Presents the results of a study of oil waste management alternatives. Includes regulations, established and emerging technologies, current practices, economics and environmental impacts of oil waste management.

Guide to Solvent Waste Reduction Alternatives- Final Report (1986,222 pp.) Practical waste management alternatives to land disposal that have potential for reducing the amount and/or toxicity of solvent waste generated.

WASTE EVALUATION-Evaluations of waste to determine whether they are hazardous based on interpretive guidance of Federal and California criteria.

Order # Title

__

700 Regulation of Ethylene Glycol Wastes in Califor- nia: A Regulatory Interpretation (1991,27 pp.) Provides the Department’s interpretation of existing statutory and regulatory authority as it pertains to ethylene glycol.

103

APPENDIX B

TREATMENT STANDARDS-Treatment standards established by the US . EPA pursuant to the Resource Conservation and Recovery Act (RCRA) will be adopted by the Department for RCRA wastes. The Department is developing treatment standards for Non-RCRA wastes. The following treatment standards reports are available:

Order # Title

800

801

802

803

804

805

806

808

809

810

812

813

814

815

Proposed Treatment Standards for Metal Containing Aqueous Wastes (1988,312 pp.) A Proposed Treatment Standard for Non-RCRA Aqueous and Liquid Organic Waste Vol. I & I1 (1990,73 pp.) Treatment Standards for Asbestos-Containing Wastes (1990,62 pp.) Treatment Levels for Auto Shredder Wastes (1989,

Treatment Standards for Foundry Sand (1989, 101 pp.) Treatment Standards for Non-RCRA Fly Ash, Bottom Ash, Retort Ash, Baghouse Waste, and Gas Scrubber Waste (1990,131 pp.) Landfill Criteria for Nonliquid Hazardous Waste (1988, 109 pp.) Treatment Standards for Non-RCRA Organic Containing Petroleum Hazardous Wastes (1992,220 pp.) Development of Treatment Standards for Non-RCRA Solvent Waste (1989,99 pp.) Treatment Standards for PCB Wastes (1988, 142 pp.) Implementation of SB 2093, Chapter 1417, Statues of 1988, Health and Safety Residuals Repository (1990,82 pp.) Proposed Treatment Standards #or Solid Wastes with Metals (1989, 195 pp.) Treatment Standards for Solids with Organics (1991,63 pp.) Treatment Standards for Liquid Redox Waste (1990,98 pp.)

88 PP.1

LAND DISPOSAL INFORMATION

Order # Title

850

851

852

104

Land Disposal Restrictions Bulletin (April 1990, September 1990, and March 1991,12 pp.) An update on Califomia’s Treatment Standards and Land Disposal Restrictions.

Cleanup Wastes Under RCRA/Non-RCRA (1991, 174 pp.)

A guidance document on Federal and State land disposal restrictions for wastes generated from site remediation, corrective action, or other types of cleanup activities.

Land Disposal Restrictions Handbook (1992,101 pp.) Provides an overview of the Land Disposal Restrictions (LDRs) for hazardous waste. It serves as a guide to the requirements and treatment standards associated with these restrictions and contains general information about the variances and exemptions available under this program.

853 Guidance Manual: Petitioning for Treatability Variance (1991,173 pp.) A treatability variance can be issued if the hazardous waste cannot be treated to meet treatment standards due to technical reasons. This document outlines essential information that must be included in the variance application.

HAZARDOUS WASTE DATA AND _ _ INFORMATION ANALYSIS

Order ## Title

900

901

902

California’s Exports and Imports of Hazardous Waste-1986 to 1988 (1990,162 pp.) Looks at California’s interstate and intemational shipments of hazardous waste from 1986-1988. Intemational shipments are focused mainly on maquiladora waste (waste from American companies operating in Mexico).

California’s NonRecurrent Hazardous Waste Reports (1990,148 pp.)

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One hundred seventy-six sites for nonrecurrent hazardous waste are described through a variety of narration, data tables, and graphs to illustrate methods used by the DTSC to manage this source of hazardous waste. The historical and current status data were utilized to project future quantities of nonrecurrent hazardous waste generated and treated over the next 20 years.

Commercial Hazardous Waste Facilities for Recycling, Treatment, and Disposal (1992, 122 pp.) Directory to assist Califomia hazardous waste generators, industry, and the general public in assessing the current recycling, treatment, and land disposal options available in Califomia and other states. The directory offers suggestions for locating commercial recyclingJtreatmenVdisposa1 facilities.

PLANNING-Evaluations of waste generators, facilities, and futureaeeds.

Order # Title

1000 Capacity Assurance Plan for Hazardous Waste Management (1989,126 pp.) Outlines the program that California will follow to meet its integrated hazardous waste management needs in accordance with the Federal government’s requirements under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Status Report on Hazardous Waste Management in California - A Draft Report (Includes Appendices) (1989, 150 pp.) Summarizes the quantities of hazardous waste generated in California industry, government, and households for the year 1987. A large fraction of this waste was recycled. Future projections for the year 1995 show that adequate capacity is expected to exist in each hazardous waste management category except incineration. Appendix includes excerpts from statutes and regulations.

1001 ‘

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- GRANTS-Findings of AB 685 Grant Projects. Grants are awarded to develop new and innovative technologies.

Order # Title

1101 California Hazardous Waste Reduction Grant Program-Grant Application manual (Updated Annually) (1991,16 pp.)

P & h % a w Lw

APPENDIX B

GRANTS (continued)

Provides information on how to submit a properly prepared application to the Califomia Hazardous Waste Reduction Grant Program that is managed by Pollution Prevention, Public and Regulatory Assistance.

1154 Hazardous Waste Reduction Technology Research Development, and Demonstration Grant Program Description Brochure (1990, 1 p.) Briefly describes the Grant Program.

Hazardous Waste Reduction Program Abstracts 1155 (1985-1991) (94 pp.) A compilation of the abstracts from the Hazardous Waste Reduction Grant projects completed since 1985. Over 125 projects have received funding totaling over $7 million. The compiled abstracts serve to transfer technology awareness to industry, consultants, regulators, and the public.

ALTERNATIVE TECHNOLOGY-New and innovative alternative technologies.

Order # Title

1200

1201

1202

1203

1204

Application of the Polysilicate Technology to Heavy Metal Wastestreams (1987,33 pp.) The polysilicate treatment technology has been applied to a variety of waste streams containing heavy metals. It differs from conventional forms of solidification/fixation/stabilization by forming a metal metasilicate as a by-product. It is still semi- empirical in nature and requires further research.

Final Report on CCBA (Coordinate Chemical Bonding Project) Phase III (1988,24 pp.) The goal of this successful project was to demonstrate that when mixing industrial sludges containing metal ions with highly absorptive clay, in proper proportions and at elevated temperatures, the metal ions will fuse into the clay’s silica structure and render the resulting material nonhazardous.

Alternative Technologies for the Minimization of Hazardous Waste-Fifth Biennial Report (1990, 140 pp.) The fifth biennial report to the Califomia State Legislature on activities relating to innovative hazardous waste minimization, recycling, and treatment technologies.

Fourth Biennial Report-Economic Implications of Waste Reduction, Recycling, Treatment and Disposal of Hazardous Wastes (July 1988, 126 pp.) The fourth biennial report to the Califomia State Legislature on the costbenefit of reducing hazardous waste in industry. Cost comparisons of site mitigation activities, industry waste minimization, and future liabilities of hazardous waste disposal are discussed.

Laboratory Scale Tests of the Circulating Bed Combustion of Spent Potlinen-Final Report (Includes Project Summary) (1988,76 pp.) Spent potliner (SPL) is a solid waste by-product of aluminum smelters that contains soluble species of cyanides and fluorides. The circulating bed combustor process treats SPL reducing both cyanide and leachable fluoride levels by specialized thermal treatment processes.

1205

1206

1207

1208

1209

1210

1211

1212

Staff Report on Implementation of SB 509 (Hazardous Waste Incineration and Treatment) (1987, 112 pp.) A support document for promulgating regulations associated with hazardous waste incineration. The report established criteria used for determining whether wastes will require incineration based on volatile organic content, heating values of the waste, and treatment capacity.

Third Biennial Report-Alternative Technology for Recyling and Treatment of Hazardous Wastes (1986,186 pp.) The third biennial report to the Califomia State Legislature. It is a guide for hazardous waste generators seeking altemative waste management techniques and serves as a resource for the public and policy makers in govemment and industry. The technologies and economics described are critical considerations for the formulation of California’s hazardous waste management policy.

UV/Hydrogen Peroxide Treatment for Destruction of Pesticide Laden Waste- Final Report (Includes Project Summary) (1987,30 pp.) This system has been reported to be effective in degrading organic contaminants in water by a chemical oxidation process. The study focuses on the destruction of low level, aqueous pesticide wastes.

UV/Ozone Treatment of Pesticides and Groundwaters (1988,36 pp.) A discussion of a demonstration project using the Ultrox Ultraviolet light enhanced oxidation technique for a variety of organic contaminants including pesticides, halogenated compounds, phenols, benzene, and other aromatics.

Composting for Treatment of Pesticide Rinseates-Final Report (Includes Project Summary) (1988,63 pp.) This study tests the viability of aerobic composting as a treatment option for low level pesticide wastes previously stored in evaporation ponds or in a landfill.

Chlorinated Solvent Recovery from Groundwater Using Contaminated Ambersorb XE-340 Carbonaceous Resin Adsorbent-Final Report (Includes Project Summary) (1991,7 pp.) Presents findings and conclusions of using Ambersorb XE-340 carbonaceous resin adsorbent to remove 1,1, I-trichloroethane (TCA) and trichloroethylene (TCE) from groundwater.

Reclamation of Waste Foundry Sands: Fresno Valves and Castings, Inc. Waste San Reclamation Project (1992,4 pp.) Describes a project involving the reconditioning and reuse of most of the waste sand.

Demonstration Using Kerr McGhee Chemical Corporation Boiler Fly Ash as a Feedstock in the Manufacturing of Southwestern Portland Cement. This project determined that the use of Kerr McGhee fly ash as an ingredient in the manufacture of Portland cement resulted in a cement product that effectively stabilized hazardous levels of nickel and vanadium present in the ash ingredient.

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APPENDIX B

REMEDIAL TECHNOLOGY DEMONSTRATION REPORTS-Zndependent technical evaluations of new, innovative, hazardous waste remedial technologies. Reports include details ofbench-, plot-, orfull-scale demonstration projects. The findings result in a Department conclusion regarding the project feasibility and provide the technical basis for any future permits for commercial operation.

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Above-Ground Bioremediation of Biphenyl and Diphenyl Oxide Contaminated Soil (1991,s pp.) Two pilot-scale demonstrations were conducted to evaluate the effectiveness of above-ground bioremediation of soil contaminated with a mixture of biphenyl and diphenyl oxide. The tests demonstrated that the addition of water and nutrients, and the tilling of the soil reduced the concentrations of the contaminants by about 50-60 percent with or without the addition of exogenous bacteria.

AquaDetodSVE Integrated System for Groundwater and Soil Contaminated with Volatile Organic Compounds in Burbank, California ( 199 1,22 pp.) An evaluation of the AquaDetox/Soil Vapor Extraction (SVE) Integrated System developed by AWD Technologies, Inc. The evaluation included calculating the contaminant removal efficiencies of the AquaDetox and SVE systems separately. The AquaDetox system removed 99.87 percent of the volatile organic compounds from the contaminated groundwater. The SVE system removed 99.65 percent of the volatile organic compounds from the air that was vacuum extracted from the contaminated soil.

Bench-Scale Demonstration of a Metal stabilization Process for a Site in Commerce, California4ilicate Technology Corporation (1990,8 pp.) Bench-scale tests were conducted to evaluate the effectiveness of Silicate Technology Corporation’s process to stabilize soluble metals in lead contaminated soil from a hazardous waste site. The treated soils showed significant reductions in soluble lead concentrations.

Biological Remediation of a Fuel Contami- nated Soil Site in Carson, California-Protek Environmental, Inc. (1990,7 pp.) Diesel fuel-contaminated soil was biologically treated above ground in treatment cells. Total petroleum hydrocarbons were reduced from 1084 m&g to 2 m&g in 90 days in the treatment cells. Similar removal occurred in the control cell.

Bioremediation of Used Oil-Contaminated Soil at Two Caltrans Maintenance Yards-Groundwater Technology Corporation (1990,lO pp.) &vides results for full-scale bioremediation at two sites. At one site, a single pile was treated with an aqueous nutrient solution and passive aeration. At the second site, one pile was treated with an aqueous nutrient solution and active aeration while a second pile was used as a control. All piles showed some removal of hydrocarbons.

Chemical Reduction of Hexavalent Chromium Contaminated Soils for a Site in Bakersfield, California ( 199 1,6 pp.) Full-scale tests were conducted to determine the effectiveness of a chemical reduction process to treat hexavalent chromium- contaminated soils. The process was successful at reducing the concentration levels of hexavalent chromium by an average of 95.8 percent.

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Hydrogen Peroxidelcatalyst Oxidation Process from a Gasoline Contaminated Site in Fullerton, California-Ensotech, Inc. (1990,20 pp.) Full-scale field tests were conducted to evaluate the effectiveness of Ensotech, Inc.’s hydrogen peroxide/catalyst process to treat soil contaminated with gasoline from a leaking underground fuel tank. Test results show significant reductions in gasoline concentrations in soil but no significant difference between the Ensotech process and the control. ~

Metal Stabilization Process for Municipal Waste- To-Energy Ash-Lassen College (1990,15 pp.) A three-part demonstration was conducted to evaluate the effectivness of a sodium silicatdcement-based process used to stabilize heavy metal contaminated fly and bottom ash generated by a municipal solid waste-to-energy cogeneration facility. Results show the process has the potential to reduce soluble heavy metal concentration to below the California regulatory limits.

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Portland Cement Stabilization Process for Lead- Contaminated Soil (1991,7 pp.) Six cubic-foot batches of lead-contaminated soil were treated with differing ratios of Portland Cement. Average soluble lead concentrations were significantly reduced.

Silicate Stabilization Process for Heavy Metal Contaminated Soil at the Tamco Steel Site- Solids Treatment Systems, Inc. (1990,7 pp.) A full-scale demonstration of a silicate stabilization process was conducted. Soil contaminated with lead, zinc, and cadmium were treated by the Trezek or Lopat process. All leachable metal concentrations were reduced to below their respective hazardous waste thresholds.

Soil Cleanup System for a Diesel Contaminated Site in Kingvale, California-Earth Purification Engineering, Inc. (1990,15 pp.) Full-scale field tests were conducted to determine the effectivensss of Earth Purification Engineering Inc.’s Soil Cleanup System to treat diesel fuel contaminated soil and to estimate the level of stack air emissions from the treatment. The system was successful at removing the diesel contamination from the soil, but did not achieve good destruction of the diesel in the stack gases.

Soil Detoxification Utilizing an Existing Aggregate Drier-South Coast Asphalt Products company (199093 PP.) Simple feasibility tests using an existing rotary drier at an asphalt batch plant were coordinated in 1986. Results of the demonstration indicated high gasoline removal but poor combustion of the gasoline vaporized from the soil.

Soil Washing Technology for Low Volatility Petroleum Hydrocarbons-Verl’s Construction Company ( 1990,6 pp.) A full-scale field demonstration of a portable soil washing system owned and operated by Verl’s Construction Company was conducted at the Peterson Tractor site in San Leandro, California. Removal efficiencies of oil and grease as high as 71% were measured during a single pass through the washer.

A Stabilization Process for Soils Contaminated with Metals and Petroleum Hydracarbons- BendGabbita Consulting Services (1990, 10 pp.)

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Bench-scale demonstration tests evaluated the effectiveness of a stabilization process to treat lead and petroleum hydrocarbons in a soil matrix. The ability of the process to stabilize total petroleum hydrocarbons could not be confirmed.

REMEDIAL TECHNOLOGY DEMONSTRATION REPORTS (continued)

1315 Sulfide Stabilization Technology for Copper- Contaminated Soil-Toxco Incorporated (1990,7 pp.) Copper-contaminated soil was treated with a sulfide precipitation process that created reactive sulfides at levels that classified the treated soil as a RCRA waste. The pH was above the hazardous waste threshold of 12.5.

1316 Thermal Treatment of Hydraulic Fluid Contaminated Soil ( 199 1, 12 pp.) Tests were conducted to determine the effectiveness of U.S. Waste Thermal F’rcEessing’s Mobile Thermal Processor, Model 100, to treat hydraulic fluidcontaminated soil and to measure the level of stack air emissions from the treatment. The Model 100 successfully removed hydraulic fluid from the soil and achieved good destruction and removal of the contaminants from the stack gases.

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1317 Thermal Treatment of Petroleum Hydrocarbon- Contaminated Soil (1991,42 pp.)

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APPENDIX B A demonstration of Ogden Environmental Services’ Circulating Bed Combustor for the remediation of soil contaminated with fuel oil #6 was conducted. Total petroleum hydrocarbons in the treated soil (bed and fly ash) were below or slightly above the EPA Method 418.1 detection limit of 5 parts per million.

Thermal Treatment Process for a Diesei- Contaminated Site in San Diego, California (1991, 14 pp.) A full-scale field test was conducted to determine the effectiveness of Earth Purification Engineering, Inc.’s Soil Cleanup System to treat diesel fuel-contaminated soil. The system successfully removed the diesel contamination from the soil to below the established cleanup level of 1,OOO m e g .

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Thermal Treatment Process for Fuel Contaminated Soil-U.S. Waste Thermal Processing (1990,30 pp.) Tests were conducted to determine the effectiveness of a mobile thermal processing unit to treat petroleum fuel contaminated soil. The tests were successfully performed on synthetically prepared gasoline and diesel contaminated soil.

Print your name and address on shipping label. This information is also used to enter your name on our mailing list. If ordering videos, write a check or money order to the Department of Toxic Substances Control and send your order form in an envelope to: Department of Toxic Substances Control, Pollution Prevention, Public and Regulatory Assistance Program, Technology Clearinghouse, P.O. Box 806, Sacramento, Califomia 95812-0806. If you have any questions, please call us at (916) 322-3670.

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107

APPENDIX B

OTHER REMEDIAL TECHNOLOGY INFORMATION

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Remedial Technology Applications Matrix for Soils and Sludges (1991,16 pp.) The Remedial Technology Applications Matrix was developed to identify treatment technologies applicable to treating contaminated soils and sludges that should be considered for hazardous waste site cleanup.

Site Cleanup Treatment Technologies (1992,82 pp.) Designed to provide “Superfund” site managers, engineers, and planners with current information on the capability and availability of treatment systems to remediate hazardous waste sites. The summary information was obtained from the responses to the 1991 Solicitation of Interest (SOI) as part of the Remedial Technology Assessment Program (RTAP). The responses are from treatment technology developers and vendors who have, or are in the process of, developing treatment systems applicable to site remediation.

VIDEOS

SOURCE REDUCTION

Order # Title Price

1400 Hazardous Waste Minimization: Planning for Success ( 199 1,

An interactive videoconference on SB 14: The Hazardous Waste Source Reduction and Management Act of 1989.

3 hours, 2 tapes) ................................................ 25.00 ._ __

- WASTE MINIMIZATION

Order ## Title Price

1500 Waste Minimization for Inspectors (Videotape of a slide show) (1991, 44 minutes) ............................................ 15.00 A three-section videotape of a slide show that provides a basic introduction to waste minimization and assessment procedures, and an excellent overview of waste minimization processes involved in metal cleaning, metal finishing, and printed circuit board manufacturing.

92 82789

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