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Sidney Innerebner, Ph.D., P.E, CWP Indigo Water Group

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1 Sidney Innerebner, Ph.D., P.E, CWP Indigo Water Group Sidney@IndigoWaterGroup.com Sewerpro@comcast.net

2 Our Goals Tonight Clean Water Act Clean Water Act Federal Pretreatment Program Federal Pretreatment Program Pollution Prevention Programs Pollution Prevention Programs Industry Examples Industry Examples 2

3 Introduction   Clean Water Act was passed by Congress in 1972 to restore and maintain the integrity of the nation’s waters.   Only 40 years ago – in my lifetime!   The Act establishes regulations for commercial and industrial process wastewaters.   Made it illegal to discharge to waters of the United States without a permit   Direct versus Indirect Dischargers 3

4 Two Classes of Dischargers Direct Dischargers Direct Dischargers Discharge to surface water Discharge to surface water National Pollution Discharge Elimination System National Pollution Discharge Elimination System Permit issued by State or EPA Permit issued by State or EPA Indirect Dischargers Indirect Dischargers Discharge to collection system Discharge to collection system National Pretreatment Program National Pretreatment Program Permit Issued by POTW Permit Issued by POTW 4

5 Wastewater Basics POTWs collect wastewater and transport via a collection system to the wastewater treatment plant. POTWs collect wastewater and transport via a collection system to the wastewater treatment plant. Treatment processes to remove harmful organisms and other pollutants Treatment processes to remove harmful organisms and other pollutants Designed to treat typical residential wastewater and biodegradable commercial / industrial wastewater (conventional pollutants) Designed to treat typical residential wastewater and biodegradable commercial / industrial wastewater (conventional pollutants) Municipal POTWs are not designed to treat toxic pollutants. Municipal POTWs are not designed to treat toxic pollutants. 5

6 What’s in a Name? POTW – Publically Owned Treatment Works POTW – Publically Owned Treatment Works WWTP – Wastewater Treatment Plant WWTP – Wastewater Treatment Plant WWTF – Wastewater Treatment Facility WWTF – Wastewater Treatment Facility WWRF – Wastewater Reclamation Facility WWRF – Wastewater Reclamation Facility WRRF – New as of January 2013 – Water Resource Reclamation Facility WRRF – New as of January 2013 – Water Resource Reclamation Facility 6

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8 Wastewater Treatment Plants have Three Types of Capacity Hydraulic Capacity Hydraulic Capacity Organic Load (BOD5) and Suspended Solids Capacity or Biological Treatment Capacity Organic Load (BOD5) and Suspended Solids Capacity or Biological Treatment Capacity Solids Handling Capacity Solids Handling Capacity Each type of capacity must be protected and not exceeded for the WWTP to function Each type of capacity must be protected and not exceeded for the WWTP to function 8

9 Treatment Capacity Utilized by Domestic and Industry Many industries discharge their wastewaters, with or without pretreatment, into sewers Many industries discharge their wastewaters, with or without pretreatment, into sewers Non-regulated industries and light commercial activities often get lumped in with domestic wastewater sources Non-regulated industries and light commercial activities often get lumped in with domestic wastewater sources Schools Schools Day Camps Day Camps Restaurants Restaurants Churches Churches Offices Offices 9

10 POTWs have a fixed capacity to handle POTWs have a fixed capacity to handle Unexpected increases in industrial loads Unexpected increases in industrial loads Population growth Population growth Stormwater flows (I&I) Stormwater flows (I&I) POTWs must meet tighter effluent limits POTWs must meet tighter effluent limits Ammonia, Nitrate, and Phosphorus Ammonia, Nitrate, and Phosphorus Metals Metals Can limit loads accepted (local limits) Can limit loads accepted (local limits) Sometimes dilution is the solution – it’s amazing what 45 inches of rain a year will do for your discharge limits! Sometimes dilution is the solution – it’s amazing what 45 inches of rain a year will do for your discharge limits! Wind River Ranch Wind River Ranch Town of Meeker Town of Meeker 10

11 Possible Solutions Expand the POTW facility to meet the increased demand - $$$$$ Expand the POTW facility to meet the increased demand - $$$$$ All Colorado discharge permits require All Colorado discharge permits require Planning for expansion at 80% of capacity Planning for expansion at 80% of capacity Must be under construction at 95% of capacity Must be under construction at 95% of capacity Exception is limited service area Exception is limited service area 11

12 Possible Solutions More expensive for smaller facilities due to economy of scale More expensive for smaller facilities due to economy of scale Wild Basin Lodge, 2000 gpd, $0.35 Million $175/gal Wild Basin Lodge, 2000 gpd, $0.35 Million $175/gal Wind River Ranch, 4000 gpd, $0.5 Million $125/gal Wind River Ranch, 4000 gpd, $0.5 Million $125/gal Brush, at 1.7 mgd, $16.2 Million $9.50/gal Brush, at 1.7 mgd, $16.2 Million $9.50/gal Carbondale, a t 1.5 mgd, $12.5 Million $8.33/gal Carbondale, a t 1.5 mgd, $12.5 Million $8.33/gal Clifton, at 4.0 mgd, $22.8 Million $5.70/gal Clifton, at 4.0 mgd, $22.8 Million $5.70/gal L/E WWTP, at 50 mgd, $75 Million $1.50/gal L/E WWTP, at 50 mgd, $75 Million $1.50/gal Funding????? Funding????? 12

13 Possible Solutions Water Conservation? Water Conservation? Initiate an industrial pretreatment program to reduce the strength of the waste Initiate an industrial pretreatment program to reduce the strength of the waste Sometimes municipalities and industry collaborate to build or expand a POTW Sometimes municipalities and industry collaborate to build or expand a POTW City of Brush, Colorado City of Brush, Colorado Town of Dinuba, California Town of Dinuba, California City of Allendale, Michigan City of Allendale, Michigan Institute a pollution prevention program Institute a pollution prevention program 13

14 Know the Difference! Federal Pretreatment Program Federal Pretreatment Program End-of-Pipe End-of-Pipe Required for WRRFs larger than 5 mgd Required for WRRFs larger than 5 mgd Pollution Prevention Pollution Prevention Moves back up the supply chain Moves back up the supply chain A good Pretreatment Program encourages P2 A good Pretreatment Program encourages P2 14

15 Clean Water Act Technology Based Limits (BMP) Technology Based Limits (BMP) Water Quality Standards Water Quality Standards Use Protection Use Protection Stream Standards Stream Standards Permits Required for All Dischargers; direct and indirect Permits Required for All Dischargers; direct and indirect Revolving Fund Construction Loan for Municipalities Revolving Fund Construction Loan for Municipalities 15

16 Pretreatment Program Components Industrial Waste Survey Industrial Waste Survey Permitting Permitting Inspections Inspections Sampling Sampling Reporting Reporting Data Management/Compliance Evaluations Data Management/Compliance Evaluations Enforcement Enforcement Other controls—BMPs, Sector Controls and Spill/Slug Control Other controls—BMPs, Sector Controls and Spill/Slug Control 16

17 The Big Picture: Why Enact Pretreatment? Prevent Prevent Interference Interference Corrosion Corrosion Explosions Explosions Worker Health and Safety Worker Health and Safety Biosolids Contamination Biosolids Contamination Pass Through Pass Through Industrial Users Contributing Toxic Pollutants to POTWs Industrial Users Contributing Toxic Pollutants to POTWs NPDES/CDPS Requirement NPDES/CDPS Requirement 17

18 Generator’s Responsibility: The purpose of the pretreatment program is to ensure that the Industrial User that generates the pollutants is responsible to manage the waste stream. The purpose of the pretreatment program is to ensure that the Industrial User that generates the pollutants is responsible to manage the waste stream. Do not pass the responsibility and liability onto the taxpayers – average sewer bill in Colorado Do not pass the responsibility and liability onto the taxpayers – average sewer bill in Colorado Internalizes the real cost of doing business Internalizes the real cost of doing business Tragedy of the Commons by Harding Tragedy of the Commons by Harding When everyone must absorb their real costs, it levels the playing field in the business world When everyone must absorb their real costs, it levels the playing field in the business world 18

19 Who Must Have a PT Program? POTWs with POTWs with Combined design flow > 5 MGD AND Combined design flow > 5 MGD AND Receiving flow from SIUs, CIUs and/or Receiving flow from SIUs, CIUs and/or Receiving pollutants which pass through or interfere Receiving pollutants which pass through or interfere Approval Authority (EPA or State) may require program be developed, regardless. Approval Authority (EPA or State) may require program be developed, regardless. Defines categories of industrial users Defines categories of industrial users Hauled wastes have special rules Hauled wastes have special rules 19

20 Pretreatment Chain of Command 20

21 POTW Legal Authority [40 CFR § 403.8(f)(1)] u Deny or condition discharges u Require compliance u Control through permit or similar means u Require compliance schedules to comply u Inspect, survey, and monitor u Enforce u Comply with confidentiality requirements 21

22 Industrial Waste Survey Identify sources of indirect discharge--the introduction of pollutants into a POTW from any non- domestic source Identify sources of indirect discharge--the introduction of pollutants into a POTW from any non- domestic source Identify and locate all possible Industrial Users which might be subject to the POTW’s Pretreatment Program Identify and locate all possible Industrial Users which might be subject to the POTW’s Pretreatment Program Identify and locate all possible Significant Industrial Users which might be subject to your POTW’s Pretreatment Program Identify and locate all possible Significant Industrial Users which might be subject to your POTW’s Pretreatment Program 22

23 Classification of Industrial Users All Industrial Users Significant Industrial Users -Categorical -Non-categorical Non-Significant Users Sector Control ProgramNot Significant 23

24 Significant Industrial User Subject to Federal categorical standards Subject to Federal categorical standards Discharges 25,000 GPD or more of process wastewater Discharges 25,000 GPD or more of process wastewater Contributes 5 % or more of permitted hydraulic or organic capacity of the POTW treatment plant Contributes 5 % or more of permitted hydraulic or organic capacity of the POTW treatment plant Has a reasonable potential for adversely affecting the POTW or for violating any standard or requirements Has a reasonable potential for adversely affecting the POTW or for violating any standard or requirements 24

25 Categorical Industrial User Applicable to specific industry categories Applicable to specific industry categories Arose from 1976 EPA/NRDC agreement Arose from 1976 EPA/NRDC agreement Currently at 55 categories Currently at 55 categories (4 are being proposed) (4 are being proposed) Found in 40 CFR Parts 405- 471 Found in 40 CFR Parts 405- 471 Applicable to direct & indirect dischargers Applicable to direct & indirect dischargers 25

26 Categorical Industries Part 405 - Dairy Products Processing Part 406 - Grain Mills Part 407 - Canned and Preserved Fruits and Vegetables Processing Part 408 - Canned and Preserved Seafood Processing Part 409 - Sugar Processing Part 410 - Textile Mills Part 411 - Cement Manufacturing Part 412 - Feedlots Part 413 - Electroplating Part 414 - Organic Chemicals, Plastics and Synthetic Fibers Part 415 - Inorganic Chemical Manufacturing Part 417 - Soap and Detergent Manufacturing Part 418 - Fertilizer Manufacturing 26

27 Part 419 - Petroleum Refining Part 419 - Petroleum Refining Part 420 - Iron and Steel Manufacturing Part 420 - Iron and Steel Manufacturing Part 421 - Nonferrous Metals Manufacturing Part 421 - Nonferrous Metals Manufacturing Part 422 - Phosphate Manufacturing Part 422 - Phosphate Manufacturing Part 423 - Steam Electric Power Generating Part 423 - Steam Electric Power Generating Part 424 - Ferroalloy Manufacturing Part 424 - Ferroalloy Manufacturing Part 425 - Leather Tanning and Finishing Part 425 - Leather Tanning and Finishing Part 426 - Glass Manufacturing Part 426 - Glass Manufacturing Part 427 - Asbestos Manufacturing Part 427 - Asbestos Manufacturing Part 428 - Rubber Manufacturing Part 428 - Rubber Manufacturing Part 429 - Timber Products Processing Part 429 - Timber Products Processing Part 430 - Pulp, Paper and Paperboard Part 430 - Pulp, Paper and Paperboard Part 431 - The Builders’ Paper and Boardmills Part 431 - The Builders’ Paper and Boardmills 27

28 Part 432 - Meat Products Part 432 - Meat Products Part 433 - Metal Finishing Part 433 - Metal Finishing Part 434 - Coal Mining Part 434 - Coal Mining Part 435 - Oil and Gas Extraction Part 435 - Oil and Gas Extraction Part 436 - Mineral and Mining Processing Part 436 - Mineral and Mining Processing Part 437-Centralized Waste Treatment Part 437-Centralized Waste Treatment Part 439 - Pharmaceutical Manufacturing Part 439 - Pharmaceutical Manufacturing Part 440 - Ore Mining and Dressing Part 440 - Ore Mining and Dressing Part 442- Transportation Equipment Cleaning Part 442- Transportation Equipment Cleaning Part 443 - Paving and Roofing Materials(Tars and Asphalt) Part 443 - Paving and Roofing Materials(Tars and Asphalt) Part 444-Hazardous Waste Combustors Part 444-Hazardous Waste Combustors Part 445-Landfills Part 445-Landfills Part 446 - Paint Formulating Part 446 - Paint Formulating Part 447 - Ink Formulating Part 447 - Ink Formulating Part 454 - Gum and Wood Chemicals Manufacturing Part 454 - Gum and Wood Chemicals Manufacturing Part 455 - Pesticide Chemicals Part 455 - Pesticide Chemicals 28

29 Part 458 - Carbon Black Manufacturing Part 459 - Photographic Processing Part 460 - Hospitals Part 461 - Battery Manufacturing Part 463 - Plastics Molding and Forming Part 464 - Metal Molding and Casting Part 465 - Coil Coating Part 457 - Explosives Manufacturing Part 466 - Porcelain Enameling Part 467 - Aluminum Forming Part 468 - Copper Forming Part 469 - Electrical and Electronic Components Part 471 - Nonferrous Metals Forming and Metal Powder The CWA(304(m)) requires that every two years EPA develop and publish plans for effluent guidelines, review, revision, development, and adoption. 29

30 Pretreatment Program is Based on “End-of Pipe” Standards Technology Based Limits Technology Based Limits Prohibited Discharges Prohibited Discharges Categorical Limits Categorical Limits Local Limits Local Limits Consensus between IU and POTW Consensus between IU and POTW Communities sometimes put up with a lot of abuse to retain jobs Communities sometimes put up with a lot of abuse to retain jobs 30

31 Prohibited Discharges Corrosive Corrosive Flammable Flammable Hazardous – D or F listed waste under RCRA Hazardous – D or F listed waste under RCRA Pass Through Pass Through Interfere with operation of POTW or sludge disposal Interfere with operation of POTW or sludge disposal 31

32 Pass Through and Interference The POTW has a fixed treatment capacity for flow and load The POTW has a fixed treatment capacity for flow and load Not just toxics interfere with operation Not just toxics interfere with operation Septic material Septic material Grease Grease Seemingly benign substances like salt Seemingly benign substances like salt Slug loading or “binge” treatment Slug loading or “binge” treatment Examples of Toxic Discharges Examples of Toxic Discharges Sulfides Sulfides Quaternary ammonia Quaternary ammonia Heavy metals Heavy metals Some organics Some organics 32

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34 34 The Bottom Line: If YOU are responsible for your company’s compliance, be SURE you know what is going down the drain.

35 Characteristics of Industrial Wastewaters High strength High strength Low nutrient to BOD ratios Low nutrient to BOD ratios Often high temperature Often high temperature Most flow occurs during shift change and/or cleaning processes (CIP) Most flow occurs during shift change and/or cleaning processes (CIP) May have weekly or seasonal variations May have weekly or seasonal variations LOTS of opportunities for prohibited discharges, pass through, and interference LOTS of opportunities for prohibited discharges, pass through, and interference 35

36 Brewery Wastewater BOD > 1200 mg/L BOD > 1200 mg/L HIGHLY variable HIGHLY variable Mostly soluble Mostly soluble Lots of VFAs Lots of VFAs Primaries remove 10-15% of influent BOD Primaries remove 10-15% of influent BOD Hops and Grains = TSS Hops and Grains = TSS Nutrient deficient Nutrient deficient 36

37 Brewery Wastewater TS can be very high TS can be very high TSS = 10 - 60 mg/L TSS = 10 - 60 mg/L BOD = 1,000 – 15,00 mg/L BOD = 1,000 – 15,00 mg/L Nitrogen = 30 -100 mg/L Nitrogen = 30 -100 mg/L Phosphorus = 10 – 30 mg/L Phosphorus = 10 – 30 mg/L Temperature = 30 o C Temperature = 30 o C 37

38 Dairy Wastewater BOD of whole milk = 100,000 mg/L BOD of whole milk = 100,000 mg/L Influent averages 900 – 5000 mg/L BOD Influent averages 900 – 5000 mg/L BOD High temperature ~35 o C from clean in place (CIP) process High temperature ~35 o C from clean in place (CIP) process Not usually nutrient limited Not usually nutrient limited High fat and grease High fat and grease DAFT often used as front end process DAFT often used as front end process 38

39 Dairy Wastewater TS can be very high TS can be very high TSS = 100 – 1,000 mg/L TSS = 100 – 1,000 mg/L BOD = 900 – 5,000 mg/L BOD = 900 – 5,000 mg/L Nitrogen = 6 -60 mg/L Nitrogen = 6 -60 mg/L Phosphorus = 10 – 100 mg/L Phosphorus = 10 – 100 mg/L Temperature = 30 o C Temperature = 30 o C 39

40 Petroleum Refinery WW Main influent compounds are ammonia, phenols, and sulfide Main influent compounds are ammonia, phenols, and sulfide Activated carbon sometimes added to adsorb organics Activated carbon sometimes added to adsorb organics May be P and/or micronutrient limited May be P and/or micronutrient limited High temperatures High temperatures 40

41 Petroleum Refinery WW BOD = 150 – 250 mg/L Phenol = 20 - 200 mg/L Oil = 100 – 300 mg/L Salts, chromium, and lead 41

42 Categorical Limits BACT for specific industry BACT for specific industry Establish national pollution control requirements Establish national pollution control requirements Organized by the industrial process used by the IU Organized by the industrial process used by the IU Categorical standards are applied to regulated wastewaters at the end-of-process or treatment Categorical standards are applied to regulated wastewaters at the end-of-process or treatment Can seem unfair to municipalities with tighter standards Can seem unfair to municipalities with tighter standards Phosphorus limits for CIU versus Municipal WRRF Industrial WRRF versus Municipal WWTP 42

43 Local Limits Protect the WRRF Protect the WRRF Protect the receiving waters Protect the receiving waters Improve biosolids disposal options Improve biosolids disposal options Protect WRRF personnel Protect WRRF personnel Examples Examples Grease – the number one cause of sanitary sewer overflows and blockages Grease – the number one cause of sanitary sewer overflows and blockages Copper at the Boulder WWTP Copper at the Boulder WWTP Copper at the Frisco WWTP Copper at the Frisco WWTP Sulfide at the Clifton WWTP Sulfide at the Clifton WWTP Hauled waste age at the Meeker WWTP Hauled waste age at the Meeker WWTP 43

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45 Local Limits Local limits are specific to the WRRF Local limits are specific to the WRRF WRRFs are required to assess and revise, if necessary, every five years WRRFs are required to assess and revise, if necessary, every five years Not industry-specific, apply to all users in the service area. Not industry-specific, apply to all users in the service area. Water Quality-based standards, may be enforced at the end-of-pipe Water Quality-based standards, may be enforced at the end-of-pipe Sometimes forces an industry to treat in excess of their categorical standards Sometimes forces an industry to treat in excess of their categorical standards 45

46 Types of Permit Limits Limits may be concentration based or mass based Limits may be concentration based or mass based Concentration based is good because accurate flow data can be hard to get Concentration based is good because accurate flow data can be hard to get Mass based loads (ppd) don’t always protect the treatment plant Mass based loads (ppd) don’t always protect the treatment plant Town of Dinuba, California Town of Dinuba, California WTP residuals discharge impacts wastewater plant WTP residuals discharge impacts wastewater plant Septage receiving Septage receiving 46

47 Finding Pounds per Day 47

48 Bad Actors in POTWs and Industry – Blame the Other Guy End of Pipe Limits cost money End of Pipe Limits cost money Industry attitude can be to get as close to the limit as possible (not typical) Industry attitude can be to get as close to the limit as possible (not typical) In some cases (really bad actors) industry may even plan to violate periodically (rare!) In some cases (really bad actors) industry may even plan to violate periodically (rare!) Corporate pays for infrastructure, local pays for operations, maintenance and fines Corporate pays for infrastructure, local pays for operations, maintenance and fines Corporate sets local up for failure Corporate sets local up for failure Creative sampling can hide a lot of problems Creative sampling can hide a lot of problems 48

49 Bad Actors in POTWs and Industry – Blame the Other Guy Operators at POTW often blame industry for all their problems, whether cause and effect can be shown or not Operators at POTW often blame industry for all their problems, whether cause and effect can be shown or not WTP Residuals Dump WTP Residuals Dump Turkey Plant and Municipal WWTP Turkey Plant and Municipal WWTP POTW levy fees for processing BOD, TSS, etc. POTW levy fees for processing BOD, TSS, etc. IU often feels unfairly penalized by POTW IU often feels unfairly penalized by POTW Sometimes, IU find that being a direct discharger is better Sometimes, IU find that being a direct discharger is better City of Fort Morgan has 4 direct IU dischargers City of Fort Morgan has 4 direct IU dischargers When Industry has control, they often do better When Industry has control, they often do better 49

50 Enforcement Civil Penalties or Fines Civil Penalties or Fines Sometimes Criminal Penalties Sometimes Criminal Penalties Supplemental Environmental Projects Supplemental Environmental Projects Violating industry and POTW agree to include commitments by industry to implement specific P2 activities in the settlement as partial relief for the original violations Violating industry and POTW agree to include commitments by industry to implement specific P2 activities in the settlement as partial relief for the original violations Reduces the fine that must be paid Reduces the fine that must be paid Provides “extra” environmental benefits to the public Provides “extra” environmental benefits to the public Gives regulator a way to channel funds outside of a budget cycle Gives regulator a way to channel funds outside of a budget cycle 50

51 Significant Noncompliance (will be published in largest local newspaper) Chronic violations Chronic violations Technical Review Criteria (TRC) violations Technical Review Criteria (TRC) violations Failure to meet, within 90 days, a compliance schedule milestone Failure to meet, within 90 days, a compliance schedule milestone Failure to submit a report within 30 days of the due date Failure to submit a report within 30 days of the due date 51

52 SNC (continued) Violation that causes pass-through or interference Violation that causes pass-through or interference Discharge that causes imminent endangerment Discharge that causes imminent endangerment Example: Elko, Nevada and that sweet smell Example: Elko, Nevada and that sweet smell Example: Corroded concrete pipe Example: Corroded concrete pipe Example: Hydrogen sulfide Example: Hydrogen sulfide Failure to accurately report noncompliance Failure to accurately report noncompliance Other violations that adversely affect the WRRF Pretreatment Program Other violations that adversely affect the WRRF Pretreatment Program 52

53 Enforcement Enforcement Response Plans Enforcement Response Plans Reflect WRRF’s responsibility to enforce pretreatment requirements & standards. Reflect WRRF’s responsibility to enforce pretreatment requirements & standards. Identify how the WRRF will investigate noncompliance. Identify how the WRRF will investigate noncompliance. Specifies officials responsible for each type of enforcement. Specifies officials responsible for each type of enforcement. Specifies types of and time frames for taking escalating enforcement for anticipated types of violations. Specifies types of and time frames for taking escalating enforcement for anticipated types of violations. 53

54 Informal vs. Formal Enforcement Informal Informal phone calls phone calls meetings meetings warning letter warning letter show cause notices/meetings show cause notices/meetings Formal Formal administrative orders administrative orders civil suites civil suites criminal suites criminal suites termination of service termination of service 54

55 Administrative vs. Civil vs. Criminal Enforcement Administrative - Authorized by Control Authority’s legal authority without involvement of a court. Administrative - Authorized by Control Authority’s legal authority without involvement of a court. Civil - Lawsuit filed in a civil court. Civil - Lawsuit filed in a civil court. Criminal - Prosecution for willful, negligent, knowing, and/or intentional violations. Criminal - Prosecution for willful, negligent, knowing, and/or intentional violations. 55

56 Administrative Penalties EPA – Up to $32,500 per violation/day EPA – Up to $32,500 per violation/day POTW enforces lesser penalties per violation/day POTW enforces lesser penalties per violation/day Penalties Warranted for: Penalties Warranted for: Significant Noncompliance Significant Noncompliance Repeated Instances of Noncompliance Repeated Instances of Noncompliance Failure to Respond to Informal Enforcement Failure to Respond to Informal Enforcement Discharges Causing Harm, Pass Through, and/or Interference Discharges Causing Harm, Pass Through, and/or Interference Unpermitted Discharges and Bypasses Unpermitted Discharges and Bypasses 56

57 Problems with PT Program Penalty Driven Penalty Driven Depends on Self-Monitoring Depends on Self-Monitoring Focuses discharger on end-of-pipe instead of factory floor Focuses discharger on end-of-pipe instead of factory floor Doesn’t minimize pollution at the source Doesn’t minimize pollution at the source May actually encourage more pollution by setting the “minimum” amount of treatment required May actually encourage more pollution by setting the “minimum” amount of treatment required Industry knows industry best Industry knows industry best 57

58 58 Change the conversation and the focus.

59 Regulatory Basis for Pollution Prevention - P2 - Programs Until recently, P2 has been an after-thought of environmental regulations Until recently, P2 has been an after-thought of environmental regulations Hazardous waste minimization first endorsed in 1984 RCRA reauthorization (HSWA) introduced P2 by stipulating that generators must have a P2 plan Hazardous waste minimization first endorsed in 1984 RCRA reauthorization (HSWA) introduced P2 by stipulating that generators must have a P2 plan Stated that reduction or elimination of hazardous wastes should take priority over waste management after generation Stated that reduction or elimination of hazardous wastes should take priority over waste management after generation 59

60 Pollution Prevention Act (P2) PPA enacted in 1990 PPA enacted in 1990 Focus is to Reduce, Recycle, Reuse at the source Focus is to Reduce, Recycle, Reuse at the source Some grant monies available Some grant monies available Largely non-regulatory approach – volunteer program Largely non-regulatory approach – volunteer program P2 is inherently a Best Management Practice (BMP) P2 is inherently a Best Management Practice (BMP) Savvy industries can improve operations and profit with a P2 plan Savvy industries can improve operations and profit with a P2 plan 60

61 P2 Act Goals Funding of state technical assistance programs Funding of state technical assistance programs Integration of P2 into EPA activities Integration of P2 into EPA activities Establishes a P2 information clearinghouse Establishes a P2 information clearinghouse Reporting on P2 activities as an addition to the Toxics Release Inventory Requirements Reporting on P2 activities as an addition to the Toxics Release Inventory Requirements Note: non-regulatory except reporting requirement Note: non-regulatory except reporting requirement 61

62 Voluntary Programs Most P2 programs have been voluntary Most P2 programs have been voluntary 33/50 Program – Very successful! 33/50 Program – Very successful! Reduced the emissions of 17 of the most toxic chemicals by 33% by 1992 and by 50% by 1995 Reduced the emissions of 17 of the most toxic chemicals by 33% by 1992 and by 50% by 1995 62

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64 Voluntary Programs Voluntary programs should emphasize Voluntary programs should emphasize A non-regulatory manner in promoting P2 A non-regulatory manner in promoting P2 Address non-regulated (small) industries that don’t have mandatory requirements Address non-regulated (small) industries that don’t have mandatory requirements Control Control Cost Savings Cost Savings That industry knows industry best That industry knows industry best 64

65 Types of Voluntary Programs Education outreach and technical assistance Education outreach and technical assistance Bill stuffers Bill stuffers Demonstration projects Demonstration projects WRRF offers amnesty for initial inspection / fix WRRF offers amnesty for initial inspection / fix Awards for successful companies Awards for successful companies MUST be presented as voluntary MUST be presented as voluntary 65

66 Problems with Voluntary Programs Providing information and training may not be sufficient, especially for smaller industries Providing information and training may not be sufficient, especially for smaller industries Not everyone has access to expert authority Not everyone has access to expert authority Non-participants may gain an unfair competitive economic advantage Non-participants may gain an unfair competitive economic advantage Great P2 results may be considered “proprietary” Great P2 results may be considered “proprietary” Industries and municipalities appreciate a fixed target for treatment goals Industries and municipalities appreciate a fixed target for treatment goals 66

67 Problems with Voluntary Programs Technical assistance program may pose liability issues to the WRRF Technical assistance program may pose liability issues to the WRRF Difficult to provide assistance when many industries consider their waste to be “proprietary” Difficult to provide assistance when many industries consider their waste to be “proprietary” Contradictory enforcement vs. assistance roles for WRRF Contradictory enforcement vs. assistance roles for WRRF WRRF becomes liable for providing legal advice WRRF becomes liable for providing legal advice 67

68 Market Forces are Better Than Peer Pressure Industrial Dischargers Respond to the Bottom Line Industrial Dischargers Respond to the Bottom Line Charge per pound or gallon Charge per pound or gallon Offer rebates for good behavior Offer rebates for good behavior Increase water price to encourage smart usage Increase water price to encourage smart usage Offer amnesty for trying process changes Offer amnesty for trying process changes Once P2 programs begin, many industries find they save money Once P2 programs begin, many industries find they save money Much more creative solutions when the goal, and not the methods, are specified Much more creative solutions when the goal, and not the methods, are specified 68

69 Rules of Thumb for Starting a P2 Program Is that really waste or is it product going down the drain? Is that really waste or is it product going down the drain? Train employees to recognize the difference Train employees to recognize the difference Examples Examples Brine solution recovery at a cheese processing plant Brine solution recovery at a cheese processing plant Leak in an orange juice line Leak in an orange juice line Employees washing “empty” vessels Employees washing “empty” vessels “Cow Water” “Cow Water” Sugar beet pulp at Western Sugar Sugar beet pulp at Western Sugar Spent chloroform in an organic laboratory Spent chloroform in an organic laboratory 69

70 If it’s already out, keep it out! Minor changes to floor practices can mean huge cost savings Minor changes to floor practices can mean huge cost savings Water brooms are a huge waste of water and source of pollution Water brooms are a huge waste of water and source of pollution Reese Foods and grease Reese Foods and grease Hoopston Foods and over spillage Hoopston Foods and over spillage Coors Brewing Company and hops / grains Coors Brewing Company and hops / grains 70

71 If it’s already out, keep it out! Segregate waste streams where possible Segregate waste streams where possible Mixed wastes are harder to treat almost always Mixed wastes are harder to treat almost always If they can be treated separately for less, do it! If they can be treated separately for less, do it! Know the difference between a barrel of wine and a barrel of waste? Know the difference between a barrel of wine and a barrel of waste? Examples of good segregation practices Examples of good segregation practices ConAgra Beef ConAgra Beef Rocky Flats Environmental Test Site Rocky Flats Environmental Test Site Coors Brewing Company Coors Brewing Company 71

72 Water Audits Often find hidden sources of pollutants Often find hidden sources of pollutants Overflowing tanks Overflowing tanks Sinks running when not needed Sinks running when not needed Inefficient equipment Inefficient equipment Lots of little leaks add up! Lots of little leaks add up! Multiple plants can be pitted against one another for greatest reductions Multiple plants can be pitted against one another for greatest reductions 72

73 Not Just for Industry Grease traps Grease traps Englewood’s Citizen Roundup Englewood’s Citizen Roundup Pollution warnings on storm sewers Pollution warnings on storm sewers Bill stuffers for service area Bill stuffers for service area 73

74 The Emerging Approach One goal of a PT or P2 Program is to make sure that pollutants are removed and not just transferred to another media One goal of a PT or P2 Program is to make sure that pollutants are removed and not just transferred to another media Canada is starting to look holistically Canada is starting to look holistically Does removing 1 mg/L of ammonia justify the pollution caused by the coal-fired power plant needed to generate the power required for its removal? Does removing 1 mg/L of ammonia justify the pollution caused by the coal-fired power plant needed to generate the power required for its removal? Europe has some cradle to grave liability for white goods Europe has some cradle to grave liability for white goods 74

75 Indigo Water Group 626 West Davies Way Littleton, Colorado 80120 http://www.indigowatergroup.com 303-489-9226


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