Municipal Pollution Prevention Programs

1
Chapter 13

• Municipal Pollution Prevention Programs

2
Introduction

• Many industries discharge their wastewaters, with
  or without pretreatment, into sewers servicing
  Publicly Owned Treatment Works (POTWs)
• POTWs are increasingly experiencing system
  overloads

3
Solutions

• Expand the POTW facility to meet the increased
  demand
• Initiate an industrial pretreatment program to
  reduce the strength of the waste
• Institute a pollution prevention program

4
Regulatory Basis for P2 Programs

• 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
• stated that reduction or elimination of hazardous
  wastes should take priority over waste management
  after generation

5
Regulatory Basis for P2 Programs(cont.)

• Emergeny Planning and Community Right-to-Know Act
  (EPCRA) requires industry to provide information
  to the public concerning the presence and release
  of toxic and hazardous chemicals
• EPCRA is a reporting requirement, not a P2 law,
  but it does drive P2 because of the publicity it
  generates relative to an industrys environmental
  policies

6
Regulatory Basis for P2 Programs(cont.)

• Clean Water Act contains provisions requiring the
  use of Best Management Practices (BMP)
• P2 is inherently a BMP and are required to get a
  NPDES permit

7
Regulatory Basis for P2 Programs(cont.)

• Pollution Prevention Act of 1990 is the chief
  legislation concerning P2
• does not mandate P2, but requires industry to
  establish a P2 plan
• establishes source reduction as the preferred
  means of environmental management
• requires industry to annually report their P2 and
  recycling practices

8
Regional Initiatives

• Example Great Lakes Water Quality Initiative
• agreement between U.S. And Canada to prohibit
  discharge of toxic substances in toxic amounts
  and to eliminate discharge of persistent toxic
  substances into the Great Lakes Basin

9
Source Control andPretreatment Permits

• All POTWs with gt 5 MGD flow that receive toxic
  discharges must have industrial pretreatment
  standards
• Shifts burden of handling toxic materials back to
  the generators
• P2 philosophy should be incorporated into the
  pretreatment requirements
• require spill control programs and toxic organic
  management plans

10
Benefits of Including P2 inPretreatment Programs

• Can assist in addressing current and anticipated
  compliance problems
• use to encourage opportunities to reduce toxic
  loadings to sewers

11
Types of POTW AdministeredP2 Programs

• Voluntary programs
• Regulatory and enforcement programs
• Market-based programs

12
Voluntary Programs

• Most P2 programs have been voluntary
• 33/50 Program
• reduce the emissions of 17 of the most toxic
  chemicals by 33 by 1992 and by 50 by 1995
• very successful
• Voluntary programs should emphasize
• a non-regulatory manner in promoting P2
• address non-regulated (small) industries that
  dont have mandatory requirements

13
Types of Voluntary Programs

• Educational outreach and technical assistance
• demonstrate successful P2 projects
• assist industry to identify environmental and
  economic benefits of P2
• provide technical resources
• award successful companies
• Voluntary reduction programs
• alternative to pretreatment and monitoring

14
Problems with Voluntary Programs

• merely providing information and training may not
  be sufficient, especially for smaller industries
• non-participants may gain an unfair competitive
  economic advantage
• technical assistance program may pose liability
  issues to the POTW
• contradictory enforcement v/s assistance roles
  for POTW

15
Regulatory and Enforcement Programs

• Modified sewer use ordinances
• require P2 plans to get a sewer use permit
• set new local discharge limits
• control discharges from small non-regulated
  industrial and commercial users
• e.g., hospitals, universities, dental offices,
  photoprocessors, filling stations, etc.
• employ mass-based, rather than concentration-
  based, limits

16
Programs for Non-compliant Industries

• Under normal sewer use ordinances, POTWs can
  mandate P2, but cannot require specific measures
  beyond BMPs
• Under modified sewer use ordinances, though, the
  POTW can require specific pollution control
  measures as part of the compliance schedule
• POTW can also initiate Supplemental Environmental
  Projects (SEP)

17
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
• reduces the fine that must be paid
• provides extra environmental benefits to the
  public

18
Problems with MandatoryP2 Programs

• Puts POTW in an adversarial role
• Industry, not the POTW, knows best how to
  integrate P2 into its business strategies
• Mass-based limits do not easily allow for
  increases in production

19
Market-Based Programs andP2 Incentives

• P2 grants and subsidized P2 loans
• Outcome-based tax credits
• Marketable wastewater permits

20
Measuring P2 Progress

• P2 progress needs to be measured
• so industries can show their success
• so POTW can gauge the benefits of the P2 program
• so the public knows what industry is doing to
  minimize emissions
• The metric currently used is usually Form R of
  the Toxic Release Inventory (EPCRA requirement)

21
Industrial Users Desires forP2 Programs
(In descending order of interest)

• 1. Educational outreach/ technical assistance
• 2. Waste minimization audits
• 3. Voluntary reduction
• 4. Supplemental environmental projects
• 5. Marketable waste permits

• 6. New permitting classes and limits
• 7. Demonstration projects
• 8. Mass-based limits
• 9. Required P2 plans
• 10. New local limits
• 11. Require reasonable control measures

22
Recommended MunicipalP2 Program Flowchart