CLEARWATERS: Pollution prevention applies to wastewater treatment

Lessons learned from Erie County

by K.N. Irvine, T.R. Hersey, Jr., M.C. Rossi, J. Caruso, and J.E. Jordan

Over the past decade, pollution prevention (P2) has become an important means of improving environmental quality. Implementation of P2 approaches has been supported through federal legislation (for example, the Pollution Prevention Act, 1990, Title VI of PL 101-508). By 1995 nearly half of the states had programs that either required or encouraged industrial facilities to prepare P2 plans. Experience has shown, however, that education and outreach are more conducive to acceptance of a program—especially by small industries—than is legislative mandate.

Erie County's Department of Environment and Planning, Office of Pollution Prevention (ECOPP) has developed several nonregulatory P2 outreach programs. Information about our successes and shortcomings may encourage more aggressive P2 implementation and help agencies and businesses to navigate potential pitfalls in developing P2 programs.

P2 clearly is multi-media and considers solid waste, liquid waste, and atmospheric discharges, and ECOPP has developed its programs accordingly. For readers of CLEARWATERS, however, we focus on protection of water quality.

What is P2?

The Pollution Prevention Act, 1990, identified a hierarchy of actions for handling waste in decreasing order of preference:

Under the USEPA definition only methods that eliminate or reduce pollution before it is created are considered P2 measures (option #1).

P2 involves substantial reduction in the use or production of hazardous materials, particularly through modification of production processes and material substitution.

Technology or process changes that reduce the generation of waste often can improve process efficiency, profitability, working conditions, and employee morale. Operating improvements and modifications in the way materials are handled and the way employees do their jobs can reduce the quantity of waste generated, improve housekeeping, and avoid accidental spills and other issues that can cause detrimental environmental effects.

Moreover, P2 measures may enhance public perception of a particular business as being a good corporate citizen. Finally, development of P2 plans at a facility can be an integral part of planning for ISO 14001 certification. The ISO certification potentially leads to improved business opportunities.

P2 and water quality legislation

In Erie County two pieces of federal legislation are pertinent to P2 and water quality:

First, located in the Great Lakes Basin, Erie County falls under the purview of the Great Lakes Critical Programs Act of 1990, a subsection of the Clean Water Act. These acts require USEPA to establish guidance on minimum water quality standards, anti-degradation policies, and implementation procedures for the Great Lakes System. The Great Lakes States are required to revise their water quality management programs and standards consistent with this guidance. The guidance specifically promotes the use of P2.

Second, USEPA issued the Federal Combined Sewer Overflow Control Policy (1994, 40 CFR Part 122) to establish a consistent national approach for controlling discharges from combined sewer overflows through more effective implementation of the NPDES program. This policy set nine minimum controls, and implementation of these controls should be among the first steps that municipalities take to reduce CSO effects.

P2 is one of the nine minimum controls. P2 should reduce contaminants entering a combined-sewer system and thereby reduce the effects of CSOs on receiving water. Possible P2 measures include improved street sweeping methods, public education programs, solid waste collection, product substitution, and water conservation.

P2 in Erie County

Since it was created in 1990, ECOPP has successfully developed many nonregulatory P2 projects to provide information and technical assistance on implementing economically feasible environmental management strategies.

Important to the successful delivery of these programs is the effective partnering that ECOPP coordinates. By linking personnel from agencies at the local, county, state, and federal level with partners from the private sector, universities, and the public, ECOPP draws from a large pool of local expertise. Two ECOPP programs are summarized here. They best illustrate the benefits of P2, as well as some of the challenges faced in implementing these programs.

A third relevant P2 program, mercury reduction, was outlined in the Fall 2000 issue of CLEARWATERS.

1. Small business P2 program

ECOPP's initial P2 efforts focused on assisting small- and medium-sized businesses with identifying ways to reduce and/or eliminate wastes and the associated management costs. At the time, over 4000 such businesses in Erie County discharged pollutants. Although many required discharge permits, a significant number were not in compliance and contributed to the overall pollution problem. Since state and federal agencies typically target large-quantity waste generators and often lack the resources to review small industries, the ECOPP Small Business P2 Program filled a void. It provided confidential nonregulatory P2 and environmental compliance information to small- and medium-sized businesses at no charge. This advice included:

Newsletters

ECOPP's Small Business P2 Program used industry-specific newsletters to update the targeted businesses on P2 strategies, waste minimization techniques, and matters concerning environmental compliance. The quarterly newsletters, entitled “Pollution Solutions,” had a mailing list of over 4000 companies and specifically targeted metal manufacturing and electroplating, vehicle maintenance repair operations, printing and photography, educational and vocational settings, and dry cleaners. The newsletters also were used to inform businesses of ECOPP's services such as workshops, on-site P2 and waste reduction assessments, and the confidential nonregulatory environmental compliance assistance provided at no charge.

On-site evaluations

The on-site P2 and waste reduction evaluations were effective for distributing site-specific technical information and increasing industry awareness of the incentives associated with P2. ECOPP promoted specific P2 strategies as a means not only to achieve compliance but also to relieve existing regulatory burdens.

Since ECOPP primarily served small- and medium-sized businesses, the majority of on-site evaluations entailed a staff member meeting with the owner or manager of a business. The visit generally consisted of discussion of environmental compliance issues and P2 options, followed by a tour of the facility. A detailed recommendation letter, which outlined P2 and waste reduction strategies, was sent to the facility following the evaluation and a follow-up telephone survey was used to track implementation of the recommendations and thereby assess the effect of the program at the facility.

Workshops and presentations

At the onset of the ECOPP Small Business P2 Program, industry-specific workshops focused on providing information regarding pertinent regulatory requirements, the general philosophy of P2, ECOPP services, and industry-specific P2 options. Based on feedback from participants, process-specific training and information on how to conduct site-specific P2 audits was incorporated into the program by means of teleconference opportunities and additional workshops. As the focus of ECOPP's workshops and presentations became more specific, the effectiveness of the program to deliver information that addressed industry's needs increased.

Meetings of trade organizations presented an additional opportunity for ECOPP to reach its target audience. The meetings provided an ideal forum for discussing industry-specific issues. In addition to the information ECOPP presented, the members of the organizations were encouraged to explain how they managed specific wastestreams and successfully implemented process modifications.

Lessons learned

Although the Small Business P2 Program did not specifically target water quality issues, it enabled ECOPP to establish sound P2 assessment principles and approaches to deal with industry that would subsequently be used in P2 water quality programs. It became clear that industry groups were at different levels of the environmental compliance-P2 learning curve.

ECOPP learned to assess industries individually to determine how best to address specific needs.

For example, the printing industry generally seemed to understand environmental compliance requirements. Most of the printers ECOPP worked with had investigated or implemented waste reduction or P2 strategies and were effectively managing their wastes. The vehicle maintenance industry, on the other hand, was less sophisticated. Some vehicle maintenance facility operators were making a conscientious attempt to comply with requirements and minimize waste; many others claimed it was not economically feasible to manage their wastes properly when their competitors provided services at lower costs because they were not incurring P2 and waste management expenses. In this instance, ECOPP tailored its recommendations to help the companies be more competitive by including strategies to reduce their waste management costs.

How was ECOPP able to furnish useful advice? In 1985, USEPA promulgated a series of regulations governing Small Quantity Generators (SQGs). Associated with those regulations were studies identifying typical industries that would be affected: printers, metal finishers, dry cleaners, vehicle maintenance operations, and, construction. In response, ECOPP developed an environmental compliance program to provide the targeted industries with technical assistance and training opportunities. Using the Standard Industrial Classification (SIC) codes for these industries, ECOPP identified more than 5000 businesses in Erie County.

Adoption of source reduction techniques was not a feasible recommendation for many of the facilities ECOPP staff visited. In those cases, recommendations focused on mechanisms to advance waste management practices up the P2 hierarchy. ECOPP promotes the P2 hierarchy as a set of incremental steps that gradually direct industry toward source reduction.

A follow-up telephone survey found that project participants believed the site visits were the most valuable component of the program. The majority of the companies that participated in the on-site evaluations had previously received program newsletters and/or attended ECOPP workshops and presentations. Although the information provided through the newsletters and workshops sparked an interest, little implementation took place before an on-site review. The on-site evaluations provided an opportunity to discuss specific P2 and waste reduction options as they were observed in the facility.

Housekeeping and recordkeeping recommendations produced the most notable benefits in the Small Business P2 Program because they required no significant capital investment to implement. ECOPP provided companies with tracking forms and storage guidelines to help them manage their wastes properly. Where cost-effective source reduction opportunities were not possible, markets for recyclable wastes were identified.

Company programs that implemented the recommendations and, as a result, achieved quantifiable economic benefits and reduced or prevented waste generation were summarized in case studies. ECOPP staff used these accounts to demonstrate successful real-life examples to other industries and as a means to measure the pollution prevented and cost-savings realized.

Thirty-nine CSOs discharge to the Buffalo River and its tributary, lower Cazenovia Creek.

2. Buffalo River CSO P2 project

Redevelopment of the Buffalo River Corridor and Buffalo Harbor is an integral component of City and County master plans for revitalizing Buffalo's waterfront. Erie County, through funds made available from a 1993 Congressional appropriation, has developed three habitat restoration sites and small pocket parks along the Buffalo River to increase waterfront access and replace degraded wildlife habitat. Studies show that CSOs may be one of several sources of contaminants to the river.

To protect the habitat restoration and newly developed park sites, CSO discharges had to be addressed. The Buffalo Sewer Authority (BSA) calibrated and applied the Storm Water Management Model to its combined sewer system over 10 years ago to help to identify remediation options and upgrade the system to increase carrying capacity and reduce overflow events. More recently, BSA has begun to develop a long-term control plan for the system in response to USEPA's CSO control policy.

The service area for the BSA includes more than 830 mi of sewer lines, 75% having been laid before 1940. Because the system is old and includes many CSO discharge points, conventional remediation methods may be costly. The intent of the Buffalo River CSO P2 Project was to assess the implementation of a P2 assistance program at industrial, institutional, and retail establishments as an innovative approach to reduce and/or eliminate the discharge of pollutants to the river during CSO events. The Babcock Street sewershed was selected as the target area for this project because of its manageable size, diversity of industrial and commercial facilities, and availability of data from past studies.

Informational mailing

The first step in disseminating P2 information was to inventory targeted establishments. A GIS was used to catalog the name, address, and SIC code of candidate industries, and 113 were identified and mapped. Each was sent an informational pamphlet describing P2 in general and the Buffalo River project in particular (Table 1).

Table 1. Summary of establishment types in Babcock St. sewershed.

Establishment type	% of total*
Industrial manufacturing	7
Food production/packaging	18
Auto/transportation	21
Printing	9
Metal working	12
Wholesale/retail trade	14
Other trades and services	19

*Total examined = 113.

On-site P2 evaluations

Of the 113 establishments, 52 were selected for site visits by ECOPP and BSA personnel. The visits included meeting with the designated contact person for the establishment in which ECOPP and BSA explained the intent of the program. A standard questionnaire was administered to obtain information regarding facility operations, waste disposal practices, and awareness of P2 principles. The entire facility, including grounds, was inspected to investigate nonpoint pollution sources that might contribute to the combined sewer system during storm events.

Recommendations included materials substitution—such as the use of biodegradable parts-cleaning solvents, changing machinery coolants to reduce work place exposure to higher metals levels, changes in system processes, improved site maintenance to reduce particulate and contaminant washoff during storms, mercury switch recycling/exchange; paper and wood recycling.

ECOPP and BSA personnel gave operators of each facility recommendations while on-site. These were followed by a detailed written report that summarized the site visit findings and outlined recommended P2 strategies.

At the conclusion of the 2-year project, ECOPP followed-up by surveying twenty-five facilities by phone. The goal was to assess industry's perception of the program and evaluate the effect of the P2 recommendations (Table 2). Based on the response, it appears that the program positively affected business philosophy and operations regarding P2 practices and also heightened general awareness of P2 opportunities.

Table 2. Buffalo River Project, results of telephone survey

Facility action	%
Implemented one or more P2 recommendation	82
Acted on verbal recommendations made during site visit before receiving written report	56
Anticipate implementing other waste reduction/P2 measures in future	89
Felt their understanding of P2 principles was enhanced by the program	94
Rated the P2 information and services provided as “good” or “excellent”	94
Had favorable perception of goals and methods of P2 project	100

P2 workshop for vehicle fleet service and maintenance sector

A P2 workshop was organized for the largest general sector of the sewershed, vehicle fleet service and maintenance. This group included vehicle repair shops, collision shops, vehicle dismantlers, salvage yards, parts suppliers, and companies that service their own fleets. Presentations on the Buffalo River project in general as well as on sector-specific issues were made by the project partners—including representatives from NYSDEC. Presentations also were made by representatives of facilities located in the sewershed that had already implemented P2 measures.

For example, the U.S. Post Office operates a large vehicle maintenance facility in the sewershed. Its representatives discussed construction of a storm water retention facility under their parking lot and measures that reduced their dumpster costs by half. The storm water facility was designed to smooth peak discharges to the sewer system.

Trade organization representatives, vendors of environment-friendly products, and recycling companies also participated and provided demonstrations at the workshop.

Industrial effluent and sewer sampling

Sampling provided baseline data on contaminant levels and quantified the effects that the P2 program had had on combined sewer water quality.

In the study, 152 samples were collected at seventeen sites. The samples typified sanitary (dry weather) sewer flow, wet weather (combined) sewer flow, waste streams of selected industries, and industrial facility waste streams at the point of discharge to the sewer system. In general, sample sites for the dry weather sewer flow were selected to provide data immediately upstream and downstream of major dischargers to the sewer system that could not be easily sampled on-site. Sampling was conducted throughout the project, 1997-1998. Sampling conducted in 1997 represented conditions before the P2 recommendations from the site visits could be implemented. Sampling in 1998 represented conditions after recommendations had been made.

Grab samples for analysis of thirty-nine volatile organic compounds (VOCs), total and dissolved phase metals, oil and grease, and total suspended solids were collected at most sites, but automated sampling systems also were installed at two sites. Wet weather sampling at Site 1 (located near the CSO and representing over 90% of the sewershed area) was initiated when flow depth reached a storm flow level (greater than 10 inches). As a result, some of the sampled wet weather flows would not have been great enough to generate an overflow to the Buffalo River, but this sampling approach maximized the number of "combined sewage" samples that could be analyzed during a short study period.

Site 2 was located within the overflow chamber to the Buffalo River. Wet weather samples there represented the quality of the combined sewage as it discharged to the river.

A public and private partnership, with both sides taking action, reduced adverse CSO effects. Note boom to segregate CSO floatables from the Buffalo River at the Babcock St. outfall.

For brevity, only findings that illustrate key points are reported here. During the course of the study, a major dishware manufacture implemented several changes to production methods, including installation of a new water clarification and reclamation system. The process changes led to a reduction in sludge generation from 8 million lb to 3 million lb. In 1997, dry weather grab samples were collected on three different days in the sewer system immediately downpipe of the dishware manufacture discharge point. These samples were collected before installation of the new water clarification and reclamation system. Dry weather grab samples were collected at the same point on two different days after the installation (Graph 1).

Graph 1. Mean total metals in sewer before and after process change at dishware manufacturer

Although the sample size was small, the mean level of metals was lower after installation of the reclamation system, and t-tests indicated that the reductions were significant (Table 3).

Table 3. Results of statistical t-tests on metals data

Metal	p
Chromium	0.06
Lead	0.17
Copper	0.16
Zinc	0.08

These results indicate that sampling in the sewer, at or near an industrial discharge point, can quantify improvements in discharge quality due to changes in operations.

Samples of liquid coolants were collected from the sumps of five metal-working machines at one of the targeted facilities. When spent, the coolants were discharged to the sewer system. Sampling was conducted to evaluate the effect associated with substituting a different coolant for that formerly used. The analytical results demonstrated that metals concentrations were lower for the substitute coolants in 68% of the collected samples.

Four dry weather grab samples were collected for metals analysis at automated sampling Site 1 in 1997, and four dry weather grab samples also were collected at this site in 1998. Unexpectedly, the mean levels for three of five metals increased (Cr, Cu, and Ni), although t-tests suggested that the change in the levels of chromium or copper was not significant (alpha=0.05). Data for nickel were not tested statistically because of the number of sample results that were below detection limit. Mean Pb levels remained the same between 1997 and 1998 while mean Zn levels declined, but the decline was not statistically significant (alpha=0.05).

The wet weather samples at this site were collected as flow-proportioned composites for each event. Sixteen events were sampled in each of 1997 and 1998. The mean metals levels in wet weather flow generally were higher than the mean levels in the dry weather flow (Graph 2). For brevity, only the 1998 results are shown in Graph 2.

Graph 2. Wet- and dry-weather averages

Student t-tests indicated that in both 1997 and 1998 the mean levels of chromium, lead, and zinc for wet weather samples were significantly higher (alpha=0.05) than the mean levels in dry-weather samples. The mean level of copper for wet-weather samples was significantly higher (alpha=0.05) than the mean for dry-weather samples in 1997, but the significance rose to 0.06 for the 1998 data. (Again, statistical testing was not done for nickel because of the number of below-detection results.)

Lessons learned

The primary objective of the Buffalo River CSO P2 Program was to determine whether a P2 assistance program targeting industrial and business activities in a specific sewershed could result in a measurable reduction in pollutant loads discharged through a combined sewer overflow. The results of the sampling effort, combined with the survey information collected from businesses participating in the program, suggest that P2 can measurably reduce pollutant loading and help protect water quality. Sampling at individual facilities successfully documented reductions in contaminant discharge to the combined sewer system.

These reductions, however, could not be detected in the dry-weather samples that represented the integrated flow from the entire sewershed. Similar problems in documenting the success of nonpoint source pollution programs have been identified by other researchers. It is possible that more frequent sampling over a longer time could be successful in quantifying contaminant reductions at the sewershed scale.

The sampling program failed to demonstrate conclusively—at the sewershed scale—that the P2 strategies would significantly reduce pollutant loading to the combined sewer system, yet it provided valuable information and insight that was used to focus P2 program services and to prioritize future efforts. For example, as a result of the first round of sampling conducted in 1997, on-site facility reviews were expanded to include a thorough assessment of potential nonpoint pollutant sources.

Contaminant levels in combined sewer overflows reflect the relative contribution from dry-weather and wet-weather flows. Metals levels for the Babcock St. sewershed were significantly greater for wet-weather samples. Furthermore, the relative mass loading of metals from the wet-weather flow would be much greater for a CSO event than the loading from the sanitary flow because of the greater flow volume. Given the significant pollution contributions to CSOs from wet-weather flow and storm water runoff, it would be prudent to pursue storm water quality and quantity management options.

For example, street sweeping is considered an appropriate P2 measure under USEPA's nine minimum controls. New generation street sweepers appear to have improved efficiency, as compared to 1970s-vintage sweepers, in removing particles and particle-bound metals from streets. Removal of downspouts connected directly to the sewer would reduce peak and total flow rates and could reduce metals loads if the runoff were routed to pervious areas. Closer attention should be paid to controlling and/or treating runoff from industrial properties, including erodible, pervious storage areas, graveled parking lots, and auto recycling yards. Runoff treatment systems or permeable pavements may be effective in improving the discharge from urban surfaces to the sewer system.

Conclusion

ECOPP has developed a highly successful P2 program over the past 10 years. This program works with small-and medium-sized business, schools, public institutions, and the public to increase understanding and implementation of P2 principles. Based on ECOPP's experience, the following components are important to a successful program:

The program is nonregulatory. Erie County provides advice and technical assistance about implementation of P2 principles. As such, business and institutions seem more willing to participate in the programs. Nonregulatory programs are perceived as less intrusive.

Partnerships are essential. In providing technical assistance, the development of partnerships with various levels of government, the private sector, and universities is essential to maximize the available pool of expertise.

Appropriate information dissemination is essential. Although newsletters, informational mailings, and workshops were useful in providing general information regarding P2 programs, site visits—particularly to individual businesses—were most successful in prompting adoption of P2 practices. Program participants felt that the specific recommendations made for an individual business were most helpful. This is particularly important because different business sectors have different levels of understanding regarding P2.

Be realistic about the P2 hierarchy. Sometimes source reduction or product substitution is infeasible. The goal in these cases should be to move the business up the P2 hierarchy to the extent possible.

Sampling in the urban environment can quantify success. Data about the quantity of reduction in pollution discharges at specific locations is critical information. Cumulative effects on sewer or water quality—at the sewershed scale—are more difficult to detect with the typical short-duration project. Improvements in storm water runoff management in the urban environment may prove most effective to reducing CSO effects.

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K.N. Irvine is with the Department of Geography and Planning, and Great Lakes Center SUNY, College at Buffalo. T.R. Hersey, Jr. and

M.C. Rossi (corresponding author) are with the Erie County Department of Environment and Planning Office of Pollution Prevention. J. Caruso and J.E. Jordan wrote as members of the Industrial Waste Section of the Buffalo Sewer Authority. Caruso is currently with URS Greiner Woodward Clyde.

Acknowledgement

This work was funded through the USEPA Pollution Prevention Incentives for States program, Grant No. NP992245-01-0. Thanks to Richard Diamond, Shannon Reczek, Lynn Romano, Dennis Torok, Jacob Napieralski, and Leah Hamilton for their assistance with the project.