Wastewater Effluent Requirements

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The primary waste management concern of many metal fabricators appears to be meeting wastewater effluent requirements for discharges to the local POTWs. Limitations on the chemical concentrations that can be discharged to sanitary sewers have increased the demands on the plant's industrial waste treatment system. In addition, the potential fines and other penalties associated with violating these discharge requirements have become more severe in the last few years. As a result, metal fabricators place a high priority on and commit significant resources to maintaining their industrial waste treatment systems. This emphasis on pretreatment requirements may cause waste reduction to be a relatively lower priority.

12.6 OTHER STATUTORY REQUIREMENTS

Other statutory requirements that have become a priority for metal fabricators are the Superfund Amendments and Reauthorization (SARA) emergency planning and community right-to-know regulations, as well as recently passed California citizens right-to-know legislation i.e., proposition 65. State law also requires local governments to implement hazardous material storage programs to regulate industry (Chapter 6.95, CHSC).

12.7 FINANCIAL IMPACTS ON METAL FABRICATORS

These regulatory programs may affect metal fabricators in two ways: (1) compliance with the local programs will often require capital investments to upgrade the plants and will require time for the plants to develop their permit applications and hazardous material management plans; and (2) since the local program's permit fees are based on the type and quantity of hazardous materials stored at a plant, decisions on source segregation and batch treatment of wastes and the storage and use of hazardous materials will be influenced by these local ordinances. The impact of item (1) may be a reduction in the capital and time metal fabricators are able to allocate to address waste reduction. On the other hand, because of the additional public scrutiny, there is added incentive to implement source reduction and recycling techniques that can reduce the quantities of hazardous materials present on site, and thus, the associated liabilities as well. Source reduction techniques which right-to-know legislation may encourage are material substitutions that replace hazardous chemicals with nonhazardous ones able to perform the same function (e.g. replacing solvents with detergents, or highly toxic hexavalent chromium plating baths with more benign trivalent ones). Item (2) above could also both discourage or encourage waste reduction. Segregation of materiaJs and batch treatment may require additional storage tanks. This could increase a business's storage permit fees and its exposure to liability costs due to spills or other releases. Alternatively, storage permit fees may encourage plants to reduce their material inventories and waste generation to minimize their permit costs.

In sum, because the cost of waste handling and disposal has increased in recent years, waste reduction has become, in general, far more attractive than it used to be for businesses. But because other waste management regulations impose enforceable regulatory requirements and fines for noncompliance, waste reduction often receives a lower priority in terms of scarce environmental management dollars than complying with these regulations. All plants investigated placed a high degree of importance on meeting wastewater effluent discharge requirements. A lower priority was given to meeting 90-day accumulation time requirements on hazardous waste storage.

12.8 REFERENCES

DHS. 1988. Waste Audit Study: Metal Finishing Industry. California Department of Health Services, Toxic Substances Control Division, Alternative Technology Section. Prepared by PRC Environmental Management Inc., San Francisco, CA.

CHSC

EDTA

EP-toxicity

NPDES

APPENDIX A LIST OF ACRONYMS

Anthraquinone disulfonic acid Centrifugal barrel finishing California Code of Regulations Chlorofluorocarbon Code of Federal Regulations California Health and Safety Code Chemical vapor deposition Diatomaceous earth

California Department of Health Services Deionized Electric arc furnace Ethylenediamine tetraacetic acid

Refers to toxicity derived using the Environmental Protection Agency's extraction procedures

United States Environmental Protection Agency

High Surface Area Electrowinning System

Ion exchange

Insoluble starch xanthate

Ion Vapor Deposition

Low Surface Area Electrowinning System

National Pollution Discharge Elimination System

Printed circuit

POTW Publicly-owned treatment works

RCRA Resource Conservation and Recovery Act

RO Reverse osmosis

SARA Superfund Amendments and Reauthorization

SIC Standard Industrial Classification

TSD facilities Treatment, storage, and disposal facilities

USC United States Code

USEPA United States Environmental Protection Agency

WM Waste minimization

APPENDIX B

Stil« of California—Hultn and vvalfara Ag«ncv Oapartmant of HMItn Sarvical

ORDER FORM FOR CALIFORNIA HAZARDOUS WASTE CONTROL LAWS AND REGULATIONS

Copies of hazardous wast« control laws and regulations administered by the California Department of Health Services may be ordered by completing the form below and mailing it with the applicable payment to:

Department of General Services, Publications Section

North Highlands, CA 95660

(916) 973-3700

The laws and regulations are not identical, so both are generally needed to obtain complete information.

The laws (Chapters 6.5 through 6.98, Division 20, California Health and Safety Code) were enacted by the Legislature. Recent history indicates that the laws change to some extent each year, usually effective January first. To keep up to date with the laws, reorder them each year, because no amendment service is available.

The regulations (Chapter 30, Division 4, Title 22, California Code of Regulations) were adopted by the Department of Health Services within the scope of the DHS' authority under the laws. The regulations may change at any time during the year according to specified administrative procedures. Therefore, continuous amendment service is available by subscription. The amendment service is useful only in conjunction with the complete regulations (i.e., Division 4, Title 22, CCR).

I. Please check all applicable boxes and complete all applicable blanks.

□ Please send me_copy (ies) of Item No. 7540-958-1016-6, Hazardous Waste S _

Control Law (Chapters 6.5 - 6.98, Division 20, Health and Safety Code), at $25.00 per copy, including postage, taxes, and handling costs.

□ Please send me_copy(ies) of the regulations (Division 4, Title 22, California j

Code of Regulations [CCR]) at $8.48 per copy, including postage, taxes, and handling costs.

(Item Number 0030-0224-7)

Please accept my-subscription(s) to the continuous amendment service for the regulations (Division 4, Title 22, CCR) at $12.00 per subscription per year, including postage and handling costs. The complete regulations must be ordered separately by checking the applicable box. (Item Number 22-04-001

Make check or money order for the total amount payable to: State of California.

TOTAL AMOUNT $

Please print or type your mailing address and telephone number below; then sign and date the form.

Name/Company Name___

Telephone Number -(In case we need to contact you about your order)

APPENDIX C

California Department of Health Services

Toxic Substances Control Program Regional Offices

Karta Ver Rmland Arvika

Region 1 — Sacramento . Toxic Substances Control Program 10151 Croydon Way Sacramento, CA 95827 (916) 855-7700

Region 2 — Berkeley Toxic Substances Control Program 700 Heinz Ave, Bldg. F Berkeley, CA 94710 (415)540-2122

Region 1 — Fresno (Surveillance and Enforcement _ and Site Mitigation only) Toxic Substances Control Program 5545 East Shields Avenue Fresno, CA 93727 (209)445-5938

Region 2 — Berkeley Toxic Substances Control Program 700 Heinz Ave, Bldg. F Berkeley, CA 94710 (415)540-2122

San Bernardino

Region 3 — Burbank Toxic Substances Control Program 1405 North San Fernando Blvd. Burbank, CA 91504 (818) 567-3000

SanOwgo

Region 4 — Long Beach Toxic Substances Control Program 245 West Broadway. Suite 350 Long Beach, CA 90802 (213) 590-4868

APPENDIX D

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