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The Central Massachusetts Pollution Prevention Project

Summary Report

Prepared by:

The Office of Technical Assistance for Toxics Use Reduction Executive Office of Environmental Affairs

Commonwealth of Massachusetts 100 Cambridge Street, Room 2109

Boston, MA 02202

r$ Printed on Reqcled Paper

The Office of Technical Assistance

The Office of Technical Assistance for Toxics Use Reduction (OTA) is a nonregulatory state agency whose purpose is to assist Massachusetts industry in reducing or eliminating the use of toxic substances or the generation of toxic byproducts. The Office offers the following nonregulatory services at : free and confidential on-site assessments, conferences and workshops, financial analyses, and written information on toxics use reduction techniques and technologies. OTA was created by the state Toxics Use Reduction Act of 1989. The Act levies a fee on large quantity toxic chemical users, a portion of which funds OTA programs. OTA works in conjunction with the Toxics Use Reduction lnsttute and the Massachusetts Department of Environmental Protection. For more information about OTA, contact: Office of Technical Assistance, Executive Office of Environmental Affairs, Room 2109, 100 Cambridge Street, Boston, MA 02202 (617) 727-3260.

Acknowledgments

The Central-Mass project is indebted to the following project designers: Michael Brown, Lee Dane, Suzie Peck, Kathy Porter, Rick Reibstein and Nikki Roy. This document was written by Timothy J. Greiner for the Office of Technical Assistance. The following persons contributed editorial guidance: Barbara Kelley, Joe Paluui, Paul Richard, and Michael Frishman of OTA Lee Dillard of DEP; Lori Columbo of ECO; Sandra Wyman of Wyman and Associates; Nikki Roy of EDF; and Mitchell Kennedy of P2C.

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Disclaimer

Although the informa .... i in this document has been .,nded in part by the US. Environmental Protection Agency under grant agreement X815641-01, fi may not reflect the views of the EPA and no official endorsement should be inferred.

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The Cabal Massachuseb P d l u h Prevention Pmject

Table of Contents

Executive Summary

1. OTA's Beginnings

2. Interagency Coordination

3. Technical Assistance Services

4. Central-Mass Project Findings

5. Expanding the Focus: From Pilot to Program

Appendix 1

Appendix 2

Appendx 3

AppendB 4

Appendix 5

Appendx 6

Appendices

Central-Mass Project Budget

Memorandum of Understanding

Sample Site-Visit Report

Pre-vis# Questionnaire

Central-Mass Project Evaluation

Central-Mass Success Stories

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37

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15 Metals Recovery and Wastewater Reduction at Hi-Tech Gold Plating Corp. 15

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19 21

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Wastewater and Chemical Use Reduction at L&J of New England, Inc. Sotvent Use Reduction at Lampin Corporation Zinc Discharge Reduction at the Lowell Corporation Coolant Substitution at Presment Corporation

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Glossary of Agencies and Terms OTA Office of Technical Assistance, former Office of Safe Waste

Management, now removed from DEM by the Toxics Use Reduction Act of 1989 and made a free standing unit within the Massachusetts Executive Office of Environmental Affairs. Department of Environmental Management, a sister agency to DEP in the state Executive Office of Environmental Affairs, the agency which originally received the Central-Mass Project Grant from EPA, home to the Office of Safe Waste Management prior to the Toxics Use Reduction Act of 1989.

P O W Publicly Owned Treatment Works, in this report POTW refers to the Upper Blackstone Water Pollution Abatement District, the chief water pollution treatment works in the Upper Blackstone River Watershed. Department of Environmental Protection, the chief state environmental regulatoryagency with responsibility for air, waste, and water pollution from industrial manufacturers.

DEM

DEP

Toxics Use Reduction (TUR) In-plantpracticesthat reduce,avoid, oreliminatetheuseoftoxicmaterials or the generation of toxic byproducts so as to reduce risks to the health of workers, consumers, or the environment; achieved through input substitution, process redesign, product reformulation, process modernization, improved operation and maintenance, and/or in-process recycling; related terms included pollution prevention, waste reduction, and source reduction.

Central-Mass Project Athree-year EPAfunded technicalassistanceand regulatory-nonregulatory coordination project led by the Office of Technical Assistance (OTA); a joint initiativeof OTAand the MassachusettsDepartment of Environmental Protection; along with the Blackstone Project, a project that brought the state's regulatory and nonregulatory resources together to focus on preventing pollution.

A pilot project to develop and test source reduction biased facility-wide inspections, source reduction in enforcementprocedures, andcoordination withtechnical assistanceservices ledbythe Department of Environmental Protection (DEP); a joint initiative of DEP and the Massachusetts Office of Technical Assistance: along with the Central-Mass Project.

Blackstone Project

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Executive Summary A joint initiative of the Office of Technical Assistance for Toxics Use

Reduction and Department of Environmental Protection, the Central Massachusetts Pollution Prevention Project (Central-Mass), 1989-92, was designed to prevent industrial pollution through nonregulatory technical assistance, supported by a source reduction biased regulatory inspection and enforcement effort. The Central-Mass Project focused on expanding a small technical assistance program, developing effective technical services such as workshops and on-site consultations, and coordinating with local business associations and regulatory agencies. The project was funded by the US EPA through a $300,000 three year grant, supplemented with $233,000 from the Commonwealth of Massachusetts.

The Central-Mass Project was thus an experimental project, designed to Project Objectives achieve a number of objectives: expand a small, relatively new technical assistance program. coordinate efforts with (1) the Blackstone Pilot Project, a joint initiative between the Department of Environmental Protection (DEP) and Office of Technical Assistance (OTA) and (2) the Upper Blackstone Water Pollution Abatement District, the largest publicly owned treatment works (POTW) in the Upper Blackstone watershed. develop collaborative relationships with the local chamber of commerce, trade organizations, and planning agencies. provide four types of technical services to industry: telephone assistance, workshops, on-site consultations, and financial analyses.

The environmentally sensitive Upper Blackstone River watershed was chosen as the site for the OTA-lead Central-Mass Project and the parallel DEP-led Blackstone Project. OTA and DEP based this choice on two factors. First, the Blackstone watershed is home to many metal-intensive manufacturers, an industry in which OTA had previous experience. Second, the DEP Commissioner and Regional Director supported the Blackstone and Central-Mass Projects and contributed personnel to the effort.

The commitment of the regional director was especially important to the Blackstone Project, since it involved revamping decade-old inspection and enforcement procedures. More specifically, the Blackstone Project proposed for DEP to train inspectors from DEP's air, water, and hazardous waste programs and the local POW, to perform facility-wide inspections. "he facility-wide inspections were to examine the entire facility in a single visit, including a comprehensive look at all inputs, processes, and pollution

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The Central Massachusetts Pollution Prevention Project Exeah Summary

outputs. In addition to the facility-wide inspections, the Blackstone Project sought to incorporate source. reduction in regulatory enforcement actions, and refer firms to OTA’s technical assistance services.

Prior to the Central-Mass Project, OTA and DEP had not worked together in any coordinated manner, separated by seemingly different mandates and institutional constraints. OTA purposely avoided regulatory coordination, fearing that coordinating would undermine industry’s trust in the Office’s confidential services. Without this trust, industry would be unwilling to discuss its problems with OTA for fear of retribution. Because of concern over its nonregulatory reputation, OTA decided to name its project (The Central-Mass Project) differently from that of DEP’s (The Blackstone Pilot Project).

While OTA believed its decision to coordinate with DEP and the POTW presented considerable risk to its reputation, OTA saw several potential benefits. OTA felt coordination would avoid conflicts between its nonregulatory efforts and DEP and POTW regulatory programs. In addition, OTA wanted to increase participation in the Central-Mass Project via regulatory referrals, a process by which regulatory inspectors would recommend that firms call OTA for assistance. From DEP’s vantage point, OTA could provide source reduction training to the Blackstone Project. Overall, OTA and DEP thought their collaboration would be an effective way to address industrial pollution problems.

Interagency Coordination

Technical Assistance Services

The Central-Mass Project was designed to expand OTA’s small, relatively new technical assistance program. Taking a page from a previous project in Southeast Massachusetts, OTA set out to build strong alliances with the local Chamber of Commerce and area trade associations. These types of alliances had proven vital to gaining trust with industry. OTA also planned to improve upon and broaden its technical assistance services by refining its site-visit procedure and offering financial analyses to its industrial clients.

Over the three-year Project, OTA organized 14 workshops, drawing 900 attendees. The workshops, which business rated highest among OTA’s services, were. co-sponsored by the Worcester Area Chamber of Commerce, the local POTW, an Industrial Advisory Committee, and a local trade association. Workshop topics were technical (e.g. solvent substitution), managerial (e.g. total quality management), and regulatory (e.g. compliance with hazardous waste regulations) in nature.

methodology to improve its effectiveness. Such site visits were composed of

reduction opportunities, and periodic follow-up to track the firm’s toxics use reduction progress. OTA conducted 40 site-visits over the three year project, each requiring an average of 15 person-hours per site-visit, and numerous follow-up visits. As part of the site-visits and the workshops, the Office provided financial expertise to firms considering toxics use reduction

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Throughout the project, OTA experimented with its site-visit

a pre-visit questionnaire, facility tour, written reports outlining toxic~ use .-

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ExecuGve Summary The Cenbal Massachusetts Pollulon Prevenlion Project

modifications. This financial expertise included assessments of toxics use reduction proposals and training for small business lenders in the Central Massachusetts area.

At the completion of the project, OTA hired the Environmental Careers Organization (ECO), an independent consultant, to evaluate the Central- Mass Project. ECO telephone interviewed 110 companies to determine the. awareness of, usage of, and attitudes about OTA services and coordination with DEP and the local POW. ECO telephone interviewed 62 companies located within the Central-Mass Project area (Target Group), and 48 similar firms outside of the project area (Control Group). ECO also completed in depth personal interviews at 28 companies to evaluate the firm's toxics use reduction performance and collect additional data on OTA effectiveness. The following findings stem from ECOs independent evaluation and OTA's own post-project review'.

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Central-Mass Project Findings

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Finding 1:

Regulatory-nonregulatory coordination benefited all agencies and industries

The OTA, DEP, and POTW interagency effort was the first-ever attempt in the US. to comprehensively coordinate the activities of nonregulatory and regulatory environmental agencies. In a number of ways, the Central-Mass and Blackstone Projects demonstrated the effectiveness of bringing together nonregulatory technical assistance and source reduction biased regulatory inspections and enforcement. - The. DEP and local P O W referrals increased the utilization of OTA's

technical assistance services. Two-thirds of OTA's 40 site-visit requests were fully or partially attributable to referrals by regulatory

Interagency coordination was integd to DEP's efforts to integrate toxics use reduction (TUR) into the Blackstone Pilot Project. Formal training sessions and frequent interagency meetings helped DEP inspectors to recognize and communicate source reduction opportunities, and integrate source reduction into the agency's enforcement actions. Close coordination did not compromise the missions of OTA or DEP. The ECO study revealed that industry correctly perceived OTA as nonregulatory and DEP as regulatory. OTA was able to gain the trust of its industrial clients. From DEP's vantage point, promoting source reduction did not relieve firms of their compliance responsibilities; rather DEP promoted source reduction as the preferred method for 6rms to meet their regulatory obligations. The P O W found a free source of technical assistance for its fums in OTA; with DEP, the POTW augmented its enforcement powers. Rather than receiving conflicting messages from nonregulatory and

inspectors. *

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'Io addition toevaluating theCeotral-Mass Project, K O evaluatedthe toxics usereductioo measorement methods employed by Massachusetts f i s . For a summary of this research, see: w. Greioer et al. Hazardous Materials and Hazardous Waste. Summer 1994

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BOX ES-1

The Central-Mass and Blackstone Projects: Comprehensive Pollution Prevention

Thii is how a typical company came into contact with OTA and DEP services and used poilution prevention to both achieve and surpass its regulatory obligations.

Workshops Provide initial Contact: In January 1989, Bill Hill and his two-person environmental staff at

BayState, a 1,000 person metal-intensive manufacturer, attended workshopssponsored bythecentral-Mass Project. Mr. Hill had received notification of the Central-Mass Project workshop series through the Worcester Area Chamber of Commerce. At these workshops, Mr. Hill picked up written materials on pollution prevention, met environmental officials from other Worcester area firms, and spoke to several OTA engineers.

BayState Joins Advisory Committee: Mr. Hill accepted an OTA invitation to join the Central-Mass Project

Industrial Advisory Committee. a committee OTA created to develop relationships with the local business community and assess the c o ” M y ’ s technical assistance needs. OTA also offered to perform a source reduction assessment at the Baystate plant, but Mr. Hill declined. Unknown toOTA. Mr. Hilldidnottrust OTA’spledgeofconfidentiality. Mr. Hill thought any violations OTA saw during the site visit would find their way back to DEP.

BayState Receives a Blackstone inspection: In February 1990, inspectors from the DEP and the local P O W

performed a facility-wide, source reduction biased inspection. The Inspectors noted several violations, including an unpermitted wastewater discharge. Theinspectorsemphasizedthevalueof using source reduction to achieve compliance, handed out Central-Mass promotional literature, and “ m e n d e d that the firm use OTA’sfree and confidential services.

OTA Pollution Prevention Assessmenf: More confident that OTA’s services were indeed confidential, and

seeking to eppease the DEP, Mr. Hill invited OTA to perform a site visit. During the consultation, OTA identified opportunities to eliminate chlorofluorocarbon use and reduce acid, water, and zinc use in the firm’s zinc plating lines.

BayState implements a Company-wide Program: Inspired by the OTA visit, BayState performed a comprehensive

review of its manufacturing practices for source reduction opportunities. BayStatewasultimatelysuccessful insupssing compliance by reducing toxjcchemical useand eliminating entire wastestreams. These pollution prevention efforts save BayState an estimated $1 00,000 annually.

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The Central Massachusetts Pollub’on Prevention Project Exearbe Summaly

regulatory agencies, both agencies promoted source reduction to achieve compliance. In addition, companies out of compliance were referred to a source of free technical expertise.

- Finding 2:

The Central-Mass Project significantly influenced firms to institute TUR changes

Quantifying the Central-Mass Project’s effectiveness in terms of the level of toxics use reduction is problematic, chiefly because such an assessment assumes OTA interaction caused (or conversely, impeded) toxics use reduction. Nevertheless, an examination of toxics use reduction measures can serve as an indicator of the Central-Mass Project’s effect. The ECO study found that:

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* 87 percent of the firms that used Central-Mass services (workshops and/or site-visits) did toxics use reduction, as opposed to only 39 percent of firms that used no Central-Mass services. There was a higher overall percentage of pounds of chemical use reduced inside than outside the Central-Mass project area. The Target Group mean and median percent reductions per chemical were 65 percent and 76 percent respectively. Twenty firms that received OTA assistance eliminated 1,249,143 pounds of chemical use through toxics use reduction modifications. The mean and median reductions per chemical were 44,612 pounds and 8,321 pounds respectively.

These qualitative and quantitative results prove that nonregulatory technical assistance programs, such as the Central-Mass Project, have a measurable effect in preventing industrial pollution.

Finding 3:

TUR projects had a beneficial financial impact

OTA found that firms that implemented toxics use reduction changes generally realized positive financial results.

For the 28 companies interviewed in depth, the primary reason for choosing to make a toxics use reduction change, versus no change or a pollution control change, was cost reduction. At seven firms, OTA documented a combined annual cost reduction of $248,000, or an average annual cost savings of more than $35,000 per company.

Finding 4 Federal funding aided the Central-Mass Project in several ways. - Guaranteed funding shielded the project from the priorities of more established programs that emphasize pollution control over pollution prevention. The agreement enabled OTA to experiment with regulatory coordination methods and protocols for conducting on-site visits. EPA provided prudent grant oversight, keeping in frequent informal contact but requiring only semiannual written updates and sparing OTA from excessive reporting requirements.

Federal funding and oversight played a key role in program and policy innovation

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The Central Massachusetk Pollulion Prevenlion Project Execu&e Summary

Finding 5: Overall, ECO found that OTA’s clients perceive OTA as professional, trustworthy, responsive, and enthusiastic.

Industry found Central- Mass services needed and useful hut with room for

OTA clients rated workshops most highly for overall effectiveness, followed closely by on-site consultations, printed materials, and telephone assistance.

improvement * Only 16 of 110 firms could think of any additional services OTA could provide.

OTA should improve its marketing efforts. For example, several firms were not notified of workshops, others attended workshops but did not know they were OTA sponsored. Industry felt OTA’s staff should have more technical expertise and experience in the firm’s industry; firms wanted specific solutions to their specific problems.

However, OTA’s clients identified several areas for improvement.

Expanding From Pilot

the Focus: to

Because of the success of the Central-Mass Project, OTA is extending the Central-Mass model to provide technical assistance state-wide. This includes replicating the regulatory coordination, business community collaboration, workshops, and site-visit methodology. With the passage of the Massachusetts Toxics Use Reduction Act of 1989, OTA received funding to expand its staff from five to over 30 employees. During this expansion, OTA hired more experienced engineers and scientists and extended the Office’s programs to all major industrial sectors in the Commonwealth.

In its expansion, OTA believed that the Central-Mass Project experience would shorten the time and effort needed to establish projects in new geographic areas and industrial sectors. But the creation of programs in new parts of the state has taken longer than anticipated. OTA found that it needs to devote considerable time to building networks with the business community. Developing relationships with DEP and POTWs has also taken longer than expected, since years of interagency mistrust were not completely vanquished with the successes of the Central-Mass and Blackstone Projects.

As OTA moves beyond the Central-Mass Project, it continues to refine its methods to increase its effectiveness. OTA engineers and scientists now hand-deliver site-visit reports to firms and ask for a verbal commitment to implement promising toxics use reduction changes. The Office recently began demonstration projects with businesses, working with firms to implement toxics use reduction modifications. These and other changes are designed to build on the results of the Central Massachusetts Pollution Prevention Project, and to enhance OTA’s ability to foster environmentally responsible manufacturing in Massachusetts.

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1. OTA’s Beginnings The Commonwealth of Massachusetts began to experiment with source

reduction projects and policies in 1983. From 1983 through 1989, the Commonwealth administered a succession of programs that increasingly brought pollution prevention to bear on the problem of industrial pollution. The Central-Mass Project, and the related Blackstone Project, culminated this progression by expanding the Commonwealth’s technical assistance program and coordinating it with regulatory source reduction efforts.

Under the aegis of the Department of Environmental Management (DEM), the Commonwealth of Massachusetts began its source reduction program in 1983. Early efforts focused on workshops, case studies, annual conferences, and industry-specific analysis of source reduction opportunities. The source reduction program, staffed by 1.5 full time employees, was a subset of DEMs waste management efforts, that included solid waste disposal, facility siting, and household hazardous waste management.

In 1986, DEM initiated its first technical assistance pilot project in response to the increasing generation of hazardous waste, water, and air pollution, and the lack of adequate disposal and treatment facilities to manage these wastes. The Southeast Jewelry Platers Project (Southeast Project) consisted of detailed source reduction assessments of 21 jewelry manufacturers and 18 technology transfer workshops. The private-public partnerships DEM made with a regional planning agency, local chamber of commerce, and an Industrial Advisory Committee comprised of representatives from Southeastern Massachusetts frms were integral to the project. The Southeast Project ended abrupfly in 1989 when the state legislature cut its funding.

The Southeast Project illustrated to the Commonwealth the value of source reduction as a superior means of waste management over recycling, treatment, and disposal. The project also demonstrated a need among industrial generators for source reduction knowledge, and industry’s willingness to participate in a government-sponsored effort.

Expansion of the Commonwealth’s Nonregulatory Source Reduction Program

Funding .- In 1988, OTA applied to the EPA Office of Pollution Prevention for

funding for Central-Mass Project, and was awarded a $288,909 grant’. OTA

*EPA originally awarded a grant to the Massachusetts’ Department of Environmental Management Office of Safe Waste Management. Shortly thereafter. the Massachusetts’s Legislature created the Office of Technical Assistance (OTA). Subsequently, all grant responsibilities and personnel were eausferred from the Department of Environmental Management to OTA.

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The Central Massachusetts Pollulon Prevention Project 1. OTAs Beginnings

BOX 1-1

The Blackstone Project Ajointinitiativeof DEPandOTA, the BlackstoneProject wasatwo- year project with four chief objectives: (1 )develop and test models for facility-wide inspections, including air, water, waste, and Right- to-Know regulatory programs, (2) test and evaluate enforcement models to encourage source reduction as the primary means of achieving compliance, (3) test the effectiveness of a pilot project approach fordeveloping public policy, and (4) coordinate regulatory actions with OTA's nonregulatory technical assistance program (Central-Mass Project). Designed concurrently and with similar aims in mind, thecentral-Mass and Blackstone Projects represented the first attempt in the United States to closely coordinate nonregulatory technical assistance and regulatory inspection and compliance programs.

and DEP supplemented the EPA grant with $233,000 over the three year period. DEM used a portion of the EPA grant to support the DEP-led Blackstone Project, supplying the salary of a member of Blackstone inspection team (Box 1-1 above). The remainder of the funding paid salaries for one and-a-half employees and student interns, and miscellaneous expenses. Appendix 1 contains the Central-Mass Project budget.

Several other organizations contributed to the Project's funding. In collaboration with the Northeast Waste Management Officials' Association (NEWMOA), OTA won a $4O,OOO grant from the Hazardous Substance Research Center at the New Jersey Institute of Technology to investigate methods for performing cost and financial analysis of toxics use reduction projects. Also, the Worcester Area Chamber of Commerce and the local POTW (Upper Blackstone Water Pollution Abatement District) contributed money and labor to the Central-Mass workshop series, paying for workshop announcements, mailings, site rental, and refreshments and registering participants. These additional funding sources helped OTA expand the scope and depth of the Central-Mass Project.

OTA intended the project to build on previous efforts and be experimental in nature. In the grant application, OTA proposed to: Proposed Effort

1. Expand the Commonwealth's some reduction program by providing - technical assistance in the form of on-site assessments, workshops, and printed materials.

local publicly owned treatment works ( P O W ) . This coordination extended to the DEP-lead Blackstone Project, a pilot project that sought to incorporate source reduction and cross media coordination into the agency's inspections and enforcement. Develop a financial feasibility model to allow company managers to

2. Coordinate with the Department of Environmental Protection, and the .-

3.

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The Cenbal Massachusetts Pdluh Prevenh Project 1. OTA's Beginnings

determine the cost-effectiveness of source reduction and recycling alternatives. Share information and coordinate with other state pollution prevention programs in New England.

4.

The most innovative aspect of the proposed effort was the plan to coordinate the Central-Mass nonregulatory technical assistance work with that of the DEP-lead Blackstone project. Following the example of the Southeast Project, DEM and DEP decided to focus the two inter-related pilot projects on one industry sector - metal-using industries - in Central Massachusetts and centered around the Upper Blackstone River Watershed. These metal-intensive manufacturers tend to be smaller businesses - 65 percent have fewer than 50 employees and less than $10 million in annual revenue. DEM and DEP targeted these metal-intensive industries and chose the Central Massachusetts area for the following reasons:

. DEM's staff had expertise in metal-intensive source reduction methods, developed in the previous Southeast Jewelry Platers Project.

. The DEP Regional Director in Central Massachusetts was willing to host the Blackstone Project.

. Metal-intensive manufacturers were geographically concentrated in the target area, important not only because such concentration reduced travel, but also because of their regional economic importance.

. The environmentally sensitive Blackstone River was the ultimate receiving body for much of the waste from area metal-intensive manufacturers.

In July 1989, at the inception of the Central-Mass Project, OTA faced three chief obstacles. First, outside of the jewelry industry in Southeast Massachusetts, industry was completely unaware of OTA's existence. Second, source reduction and the related concepts of pollution prevention and toxics use reduction, were new to industry and government. Third, few experts in the field existed, whether in the consulting community, among equipment vendors, or in federal, state or local regulatory agencies. Fourth, OTA and DEP had not previously worked together in any coordinated manner. This last point became a central focus of the early efforts by OTA and DEP as the two agencies sought to improve their coordination.

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The Central Massachusetts Pdlubn Prevenh Pmjwl

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The Central Massachusetts Pollulon Prevention Project

2. Interagency Coordination In order to coordinate the Central-Mass and Blackstone Projects, OTA

and DEP had to overcome significant institutional harriers. In the Southeast Jewelry Platers Project, for example, OTA feared that working with DEP would compromise the trust they were developing with local industry. At DEP, many personnel saw no benefit to coordinating with OTA, having a full agenda of permitting, inspection, and enforcement activities.


’Ihrough a series of meetings over a six month period, OTA and DEP met to discuss how to coordinate their efforts. The product of these discussions was a Memorandum of Understanding assuring OTA that it could maintain its confidentiality with industry, yet provide key resources to DEP’s effort to integrate source reduction into its inspection and enforcement programs. A copy of the Memorandum is in Appendix 2.

In developing the Memorandum of Understanding, DEP and OTA resolved a number of issues, the most difficult of which was whether OTA would report regulatory violations seen during site visits. Some at DEP wanted OTA to report such violations while OTA sought to keep all site- visit information confidential. Ultimately, OTA and DEP agreed that OTA would report only egregious violations, those that posed an imminent threat to public health, worker safety, or the environment. OTA and DEP came to agree that OTA’s job was technical assistance, and that confidentiality was critical to a such an effort. During the 40 site-visits OTA conducted during the three-year Project, OTA did not see a single egregious violation.

A second issue arose when Blackstone inspectors wanted OTA staff members to be present for a discussion of inspection results. The inspectors wanted OTA to provide them with source reduction ideas to include in enforcement documents. Although the Office wanted to be helpful in this regard, OTA decided that being present during enforcement-related meetings could imperil its nonregulatory status. As a result, OTA did not attend inspection debriefing meetings, offering instead to provide source reduction ideas to inspectors as long as the identity of the firm was kept confidential. -

Shortly after completing the Memorandum, OTA realized that the agreement to send DEP copies of regulatory referral site-visit reports

nonregulatory technical assistance program. But to businesses, sending DEP a copy of the site-visit report contradicted the notion of a confidential program. OTA felt this contradiction was especially problematic, since usually it’s only after the third or fourth visit that firms trust OTA enough to understand that sending DEP a site-visit report was not a means for DEP to

contained an inherent contradiction. In their referrals, DEP promoted OTA’s ____

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The Cenlral MassachuseaS Pollution Prevenh Project 2. Interagency Coordinalion

BOX 2-1 ~ _ _ _ ~

Key Points of the Memorandum of Understanding

. DEP would make verbal and written referrals to OTAs technical assistance services when conducting inspections.

. OTAgavefirms, referred tothecentral-Mass projectby DEP, priority technical assistance.

. OTA trained DEPinspectors to recognize pollution prevention opportunities during inspections.

. OTA assisted DEP inspectors in devising the facility-wide Blackstone inspection protocol.

. OTAagreed to send DEP copies of site-visit reports when the visit was the result of a regulatory referral, such as when a DEP inspector verbally recommended that a firm call OTA.

BOX 2-2 ____ ~

Key Steps to Interagency Coordination . Regulatory and nonregulatory upper and mid-level man-

agement commitment is essential; there is no substitute for leadership. Approach coordination with a “blank slate”, leaving room for creativity and experimentation. For implementation purposes, start small by coordinating with a limited group in asingle geographic area, while working out coordination issues.

. Prepareforproblems bydevelopingalistof possibleproblems and discussing them before they happen. For example:

Whathappensifaninspectorfinds a compliance violation that is the resultofa recommendation by the nonregulatory technical assistance group? Should the technical assistance group provide copies of site-visit assessment reports to the regulatory agency when a firm comes under consent order? Should a firm be required, as part of a consent order, to work with the technical assistance group? Should the technical assistance group agree to attend a meeting between a firm and a regulatory agency?

Goodcommunication between agencies will head-off unantici- pated disputes and facilitate quick resolution of diff icult issues.

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The CenbaJ Massachusetts Pollulion PrevenCon Project 2. Interagency Cmrdinalion

find regulatory violations, but rather to help DEP learn how OTA identifies source reduction opportunities. OTA did not adhere to this aspect of the Memorandum, and only sent DEP site-visit reports when the companies themselves agreed. While the Memorandum was never modified, the Massachusetts Toxics Use Reduction Act later supported this policy,

DEP, except in cases of imminent threat to the environment or public health or with the permission of the company (Box 2-1 facing page).

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stipulating that OTA was not to provide such confidential information to -

In August 1989, OTA met with representatives of the regional POTW (the Upper Blackstone Water Pollution Abatement District) to explain OTA's nonregulatory program and explore collaboration. At the meeting, the P O W made a verbal agreement to refer firms to OTA; OTA agreed to provide technical assistance services to these POTW dischargers. Shortly thereafter, the POTW suggested to the Lowell Corporation, a ratchet manufacturer out of compliance with its water discharge permit, that it call OTA for help. OTA suggested source reduction methods to bring Lowell Corporation into compliance. OTA's suggestions were adopted and saved the company $26,000 annually. The POTW's experience with Lowell Corporation prompted it to refer more firms to OTA. OTA's work with the P O W demonstrated that OTA could form cooperative relationships with regional POWs, that this cooperation could greatly benefit OTA's program, and that collaboration was possible without a formalized Memorandum of Understanding (Box 2-2 facing page).

In November 1989, the POTW joined the Blackstone Project. As is often the case with POTWs, the Worcester POTW operated independently from DEP, despite the fact that the two agencies inspected many of the same facilities, and that changes required by one agency could place a firm out-of- compliance with another agency's regulatory program. With detailed knowledge of the local business community's industrial wastewater discharges, the POTW was a valuable resource in DEP's facility-wide inspection effort.

POTW Collaboration

Historically, DEP's inspectors did not promote pollution prevention during inspections in any systematic way. As part of the Blackstone Project, OTA trained DEP and POTW inspectors to recognize and communicate source reduction opportunities to businesses and also helped DEP develop methcds for incorporating source reduction into enforcement documents. During the first six months of the Blackstone Project, OTA held three training sessions for DEP personnel.

In addition to the three training sessions (Box 2-3 following page), Blackstone inspectors anended 11 Central-Mass Project workshops. All told, Blackstone inspectors received some 40 hours of source reduction training during the two-year Blackstone Project. Along with their formal training, Blackstone inspectors benefited from the learning afforded by OTN DEP biweekly meetings. OTA's participation in these staff meetings was essential to the ability of DEP and the POTW staff to learn to identify source reduction opportunities. OTA benefited equally from the training sessions

DEP Training

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The Central Maspaehuwtb Pdlution Prevention PW 2. Interagency Coordinalion

OX 2-3

Source Reduction Training for Blackstone Inspectors

Date Title Objectives

Multimedia inspections media and facility-wide inspections; & Industry's Response

Source Reduction To increase inspectors' familiarity Techniques for with source reduction options for Metal-Intensive metal-based industries. industries

Source Reduction Workshop reduction; review low-cosvtech metal

To discuss how industry views single

from industry's perspective, how could an inspector promote source reduction?

To introduce DEP personnel to management science issues in source

finishing source reduction methods.

BOX 2-4

Innovations in State and Local Government Award

In 1991, the Ford Foundation and the Harvard University Kennedy School of Government presented the Blackstone Project with an Innovations in State and Local Government Award that included a $100,000 prize. The Ford Foundation, a private philanthropic institution, recognized the Commonwealth for developing and test- ing a facility-wide inspection protocol, using a preventive approach to regulatory compliance, and providing nonregulatory, source reduction biased technical assistance. The Foundation deter- mined that the Blackstone Project's facility-wide inspections and interagency coordination not only enhanced protection of the environment, but also was preferred by industry over traditional single-media inspections.

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The Central Massachusetts PolluCon Prevention Project 2. Interagency Coordinalion

and biweekly meetings, learning DEP's permitting, inspection, and enforcement procedures, procedures on which OTA's industrial clients frequently sought guidance.

for the facility-wide inspections they were to conduct. Historically, DEP's

and the regional POW, operated in relative isolation. Inspectors developed expertise only in their own program, despite the fact each inspected many of the same facilities, and that regulatory requirements of one agency could effect the regulatory programs of another. The Blackstone inspectors received cross-training to enable them to conduct inspections of facilities in minor source categories in all media programs. The inspectors also learned to screen facilities not registered with DEP programs to ensure they were in compliance with or exempt from regulations for those media. The facility- wide inspections examined compliance in all media, documented chemical use, diagrammed all production processes, and noted source reduction opportunities.

DEP provided its own training to Blackstone inspectors to prepare them -

three divisions - air quality, hazardous waste, and industrial wastewater - -

-

~

The close coordination between OTA, DEP, and the local P O W in the Coordination Results

Central-Mass and Blackstone Projects yielded results that surpassed the expectations of the project designers. The projects demonstrated that pollution prevention can he encouraged though source reduction biased inspections, enforcement, and nonregulatory technical assistance. The DEP and OTA efforts received national attention when the agencies were presented with a Ford Foundation Award for Innovation in State Government (Box 2 4 opposite).

At the start of the project, DEP's air, water, and waste groups, the POTW, and OTA had each operated autonomously. Through the lengthy meetings, training sessions, and field work, they had formed a collective team and begun the process of institutionalizing intergroup and interagency coordination. The Blackstone Project staff believe that their pilot was successful in its setting; focused on a limited number of facilities (97 firms), in one of DEP's four regional offices, and with a highly motivated team. The facility-wide inspection protocol they developed proved to be more effective than single-media inspections for detecting illegal or unregistered waste streams, revealing more instances of non-compliance, more closely regulating minor sources, and encouraging facilities to prevent rather than control pollution.

19

The Cenbal Mapsachwtb Pdlution Prevention Project

20

The Cenbal Magsachusetls Pollulion Prevenlon Project

3. Technical Assistance Services With the Central-Mass Project, OTA planned to build upon the

experience gained during a prior three year technical assistance project, the Southeast Jewelry Platers Project. In southeastern Massachusetts, OTA worked closely with and gained the respect of the regional planning agency and local Chamber of Commerce. These organizations provided OTA with local support for its source reduction pilot project.

Despite the reputation the Office gained running the Southeastern Project Developing Business- Community Relationships

from 1986-1989, the Central Massachusetts business community did not know of OTA at the inception of the Central-Mass Project. To begin building alliances with the business community, OTA contacted the Worcester Area Chamber of Commerce. OTA found the Chamber initially unresponsive, reflecting the general distrust of government environmental agencies by the business community. In fact, before the Chamber would agree to co-sponsor any Central-Mass workshops, the Chamber gave OTA the names of 13 business leaders in the Worcester area, telling OTA that if they could gain their support, the Chamber would consider co-sponsoring a single workshop. OTA visited each of the 13 business leaders, explained the Office’s services, and invited them to an introductory meeting at the Chamber of Commerce.

agreed to form a Project Industrial Advisory Committee. Their strong support persuaded the Chamber to co-sponsor the project workshop series. The Chamber and the Advisory Committee proved crucial to the early success of the project, helping OTA staff to define the technical assistance needs of the local business community, networking Project staff with business leaders, providing OTA with a mailing list of its metal-intensive manufacturer members, and securing a reasonably priced, centrally located facility to hold the workshop series (Box 3-1 following page).

This introductory meeting was an unqualified success. The invitees

Telephone Assistance

?he telephone was the most frequent point of contact between a company and the Central-Mass Project. Telephone calls typically covered a range of topics, such as die substitutes for aluminum aircraft fuel control tubes, regulatory requirements when using ethyl acetate, or tips on beginning an environmental program for a gas utility company. OTA found that distributing such information was a vital service to small business operators, who typically have limited time and money to spend learning about toxics use reduction methods or regulatory requirements.

21

The Cenbal Massachusetts P d l u h Prevention Project 3. Technical Assistance Sewices

BOX 3-1

Getting a Project Off to a Quick Start Focus technical assistance on a subset of industries, prefer- ably one for which toxics use reduction techniques are well known. Coordinate workshops with regional business organizations; they can give a program terrific access to the business community. When expanding into a new geographic area or industry, take advantage of the good reputation earned in other areas by using references and written letters of recommendation. At the first Central-Mass Project workshop, a company president who had worked with OTA in the Southeast Jew- elry Platers Project detailed how his firm instituted OTA- recommended source reduction changes that saves his company over $100,000 annually. Developing success stories of local business efforts will add credibility to the program. For example, the Worcester Telegram and Gazette published OTAs first success story on the Lowell Corporation. This success, which occurred in the second month of the project, brought the firm into regulatory compliance, and saves them $26,000 annually.

BOX 3-2

Central-Mass Workshops and Conferences Date Workshop Topic Attendance

1/18/90 Managing Manufacturing to Cut Waste and Save Money 32 3/15/90 Coolant Substitution 41

6/27/90 Silver Recovery Forum 50 10/4/90 Help Yourself (Part I): Toxics Use Reduction Audits 36

1 1/20/90 Something for Everybody (Water Conservation and Management) 30 2/28/9 Toxics Use Reduction Practices for Metal Finishers 78

4/18/91 Toxics Use Reduction Reporting Explained 96 5/30/91 The Way It Goes (Review of Regulatory Requirements) 17

11/06/91 In Living Color (Teleconference) 30 11/19/91 Solvents Bazaar 288 3/18/92 Cost Savings Through Toxics Use Reduction 36

5/3/90 Source Reduction in Metal Finishing Processes 49

10/17/90 Help Yourself (Part 11): Toxics Use Reduction Audits 35

6/31/92 Total Quality Environmental Management 75

22

The Central Massachusetts Pollution Prevention Project 3. Technical Assistanca Sewices

Workshops The Central-Mass workshop series, co-sponsored by the Worcester Area Chamber of Commerce and later by the Upper Blackstone Water Pollution Abatement District (local POW), were an effective m e w for getting toxics use reduction information out to the project’s broad constituency. OTA ran 14 workshops over the three year grant, attended by a total of 900 people

According to an independent evaluation, companies rated the Central- Mass workshops the highest among OTA’s services. First and foremost, the workshops provided a forum for business professionals to get the latest information on toxics use reduction techniques and technologies for their industry. The most popular OTA workshop was the Solvents Bazaar, where firms saw alternatives to ozone-depleting chemicals in action3 (Box 3-3 following page). In addition, the Central-Mass workshops provided the opportunity for professionals from different firms to network with one- another, to talk about common problems and share the insights from their own experiences. Finally, the Central-Mass workshops provided business with a neutral territory to get to know OTA staff, a necessary requirement for many business managers reluctant to invite a state agency into their plant (Box 3-4 following page).

-

(Box 3-2 facing page). -

-

During the Central-Mass Project, OTA experimented with different models for performing on-site consultations to increase their effectiveness. On-Site Consultations

. . Based upon its own evaluation, OTA modified its consultation process, ending up with a site-visit protocol and report writing format it felt best served its industrial clients.

Srudenr h e m s Perform Sire Visits: In the Southeast Jewelry Platers Project, OTA used student interns to perform source reduction assessments at facilities. These assessments included detailed flow diagrams of the facility’s manufacturing processes and written source reduction recommendations. The interns provided OTA with an economical source of labor to perform its visits, an important consideration given the lean budget of the Office at the time. However, OTA ceased using interns to perform site visits for a number of reasons. First, student interns lacked credibility with industry, because of their limited experience. Second, the extensive intern training program had to be repeated too frequently, as incoming interns replaced outgoing ones. Third, the use of interns failed to institutionalize source reduction expertise into the Office. Finally, OTA could not establish an ongoing relationship with its industrial clients with interns that changed from year-to-year. Volunteer Consultants: On several consultations, OTA used volunteer consultants who accompanied OTA on visits and prepared written synopses of their observations. While some of the consultants were well qualified,

Early On-Site Consultations

_-

)For a comprehensive review of the Solvents Bazaar, see: Mitchell L. Kennedy. The Solvents Bazaar - A Cooperative Effori beween Government and Industry. Epllutipn

Winter 1992-93. Executive Enterprises Publications Co.. Inc. NY. NY. Vol. 3, No.1,

23

The Cenbal Mawad~uaetk P d l u h Prevention Project 3. Technical Assistance Services

BOX 3-3

The Solvents Bazaar TheSolvents Bazaarwasthemostsuccessful ofthe 14Central-Mass workshops. Its

goal was to provide industry with a practical, hands-on environment in which to see altemative cleaning methods in operation. OTA invited vendors of solvent substitution equipment to set-up full-sized demonstration units in the Worcester Centrum. This equipment included ultrasonic, alcohol, immersion, spray, rotary, and power washers. For a $100 fee, OTA supplied vendors with water, electrical hook-up, and spill response services. The Office arranged for a certified waste hauler to make independent waste disposal agreements with the vendors. OTA invited industry to bring dirty parts to the Bazaar to clean in the demonstration units, and charged a $20 per firm attendance fee.

OTA organized the Bazaar to provide the smaller and medium size firms, that often have limited resources to devote to technology evaluation, the opportunity to see many different types of cleaning alternatives in action. Response from vendors was initially negative. Many equipment manufacturers tried to skirt an OTA requirement that to participate in the Bazaar, vendors had to set-up a working model of their equipment. The day of the Bazaar, twenty vendors set-upcleaning equipment, demonstrating25 different cleaning technologies. Afterwards, the vendors were more enthusiastic, having made numerous potential sales contacts during the full-day event.

Response from industrywas overwhelminglypositive. Firms preferred bringing parts to the Bazaar, where they could watch them being cleaned, as opposed to the typical process fortesting cleaning methods that requires mailing parts to a vendor. When firms mail parts to a vendor, they cannot see the equipment in action nor verify the vendors cleaning method. The Bazaar also gave OTA the opportunity to showcase the cleaning methods it had been recommending to industry during site-visits. Nearly 300 New England businesses attended the Bazaar, with more than 100 bringing parts to clean. Several other technical assistance programs, in states such as Connecticut, California, and New Hampshire, have replicated the Solvents Bazaar.

BOX 3-4

Tips on Running A Workshop Program Run workshops through a local business organization such as the Chamber of Commerce. The organization may provide their mailing list and/or an endorsement. Askfirmstopayanominal fee percompany. OTAs Industrial Advisory Committee suggested a $20/company fee, stating that they would be less inclined to attend a free workshops than one with a nominal fee. The per-company fee allows firms to bring as many company employees as they wish. Workshops are typically half-day to accommodate business people, beginning at 8:30 AM and ending before noon. Ask the Industrial Advisory Committee to recommend sites for workshops. They will know places favored by the business community with parking and easy access. Coffee and donuts or danish greatly enhances workshop events and encourages interaction between attendees.

.

.

24

The Central Massachusetts Pollulon Prevention Project 3. Technical histance Services ~~

OTA found that managing the consultants required a lot of time, and that many of the reports were of dubious quality. Exrensive Site-Visit Reports: For four industrial clients, OTA prepared 20 page, comprehensive site-visit reports. These reports overwhelmed the clients since most clients wanted short, easy to read reports that prioritized a few toxics use reduction opportunities. Visits Without Site-Visit Reports: In some cases, OTA visited fKms and provided only verbal source reduction recommendations. This method was helpful in cases where OTA wanted to establish initial contact and explain its mission, a mission that was unfamiliar to most businesses at the time. However, without written site-visit reports, OTA could not provide thoroughly researched recommendations. While verbal recommendations at the end of a consultation were sometimes insightful, they could often be general and superficial in nature.

-

-

-

Developing an On-Site Protocol

In consultation with other state technical assistance programs, OTA developed a protocol for its on-site consultations. A typical consultation began with a firm requesting OTA’s assistance. On the day of the visit, one or two staff persons traveled to the facility. In an opening meeting, OTA met with one or more plant employee to discuss the purpose of the visit. Next OTA toured the plant, starting at the receiving dock, going through the chemical storage area, onto the production floor, and ending with the waste storage area and shipping dock. During the weeks following the consultation, staff members prepared a written report of toxics use reduction recommendations, a sample of which is located in Appendix 3. OTA modeled its site-visit reports on those of the Minnesota and North Carolina state technical assistance programs. When writing reports, which were typically three pages in length, staff members drew from their own experience, the experience of colleagues, and the extensive technical materials found in OTA’s library. Following the visit, OTA remained in contact with the company, calling periodically to provide additional assistance, document their progress, or discuss setbacks (Box 3-5 following page).

Shortly into the Central-Mass project, OTA modified the protocol in three important ways. First, OTA restructured the opening meeting by requesting the attendance of senior management, production, finance and accounting, maintenance, and environmental engineering positions often held by one or two persons in small, owner-operated companies. Although all representatives from these areas rarely attended the opening meeting, having some of these players present improved the chance that the firm would buy into toxics use reduction.

Second, OTA added a closing meeting to each site-visit, reassembling the same individuals present in the opening meeting, to discuss findings from the tour and to map out future steps. OTA found it useful for upper management to hear the results of the facility tour, and to be apprised of the next step in the consultation process (Box 3-6 following page).

Third, OTA developed a pre-consultation questionnaire for firms to fill out prior to the site visit. The questionnaire, which is mailed to the f rm a few weeks prior to the visit, provides OTA with background information on

-

___

25

The Cenbal Massachusetts Pollution Prevention Project 3. Technical Assistance Services

BOX 3-5

Consultation Timetable 1. Company contacts OTA,

OTA sends pre-visit questionnaire

2. OTA reviews completed questionnaire and schedules a visit

3. On-site consultation

4. Research, draft, and send toxics use reduction recommendation letter

5. Periodic phone calls and, if warranted, follow-up visit

- 4 weeks

- 2 weeks

day of visit + 3 weeks

periodically

BOX 3-6

Site Visit Tips . Use well-trained staff for performing on-site consultations. The technical expertise

of the staff greatly influences a firm's toxics use reduction implementation rate. The ECO study found that what firms want most from consultations is specific solutions to their specific problems. Be flexible when conducting site-visits. It may be necessary to follow the client's agenda during the visit. This typically occurs when the company is unfamiliar with the program, and wants to get to know it better before revealing sensitive information. The company should demonstrate a minimal level of management commitment before receiving a consultation. This commitment should include responding to the pre-visit questionnaire and upper management participation during the site visit. Without management commitment, there is little guarantee that pollution prevention recommendations will be implemented. Do not use consultants to perform on-site consultations. Technical assistance staff should perform this essential service. In addition to institutionalizing expertise, OTAs use of full-time employees provided valuable information on regulatory barriers to pollution prevention that were subsequently the focus of OTA/DEP/ POTW policy discussions. Set site-visit expectations appropriately, working with the company contact to determine whether to tackle the tough problems first, orsimplerones that may build support in the firm for more difficult toxics use reduction projects later.

.

26

The Cenbal Massachusetts PolluSon Prevention Pmjea 3. Technical Assistance Sewices

BOX 3-7

Technical Assistance Tracking Database Facility Information:

Facility Name Contactrritle Telephone Number Mailing address Zip Code Type of Assistance (e.9. site visit or workshop)

Lead person on facility Status (activehot active) Who referred firm to OTA Date@) of Contact SIC Code

Information for Each Material or Chemical: Chemical identity Reductions Achieved Description of recommendations Type of technique employed (e.9. input substitution) CosVSavings Information

chemical use, production information, and prior toxics use reduction projects. The questionnaire takes roughly 45 minutes to fill out, helps OTA prepare for the visit, and demonstrates a minimal commitment on the part of the company to working with OTA. This commitment is important since OTA has no authority to force a firm to implement its toxics use reduction recommendations. Appendix 4 has a copy of the pre-visit questionnaire.

Mid-way through the project, OTA developed a software program to track the progress of firms that received technical services. In designing the tracking database, OTA examined the data it collected, how it might be organized, and what types of reports the Office would want to generate.

For each consultation, OTA tracked the type of services provided, production changes made, and the magnitude of chemical reductions. The pre-visit questionnaire collected general facility information, and more detailed chemical data was gathered during and after consultations (Box 3-7 above).

The database was intended to be used to generate a variety of reports based on geographic area, cost savings, and chemical reductions. However, OTA found that financial and chemical reduction information was difficult to collect, since fums rarely prepare reports on the monetary and chemical changes from toxics use reduction projects. Even with investigative work, OTA was frequently unable to collect accurate information. While OTA

Tracking Progress

21

The Central Massachuset$ Pollution Preventim Pmjea 3. Technical Assistance Sewices

found the tracking system useful from the point of recording which firms received what assistance, it did not provide an evaluation of OTA's effectiveness.

- Companies need assistance not only in devising and implementing toxics

use reduction initiatives, but also in conducting realistic financial assessments of toxics use reduction proposals. In the EPA grant proposal, OTA pledged to develop and test a method for completing such assessments". As part of the site-visits and the workshops, the Office provided financial expertise to firms considering toxics use reductions modifications. This included financial assessments of toxics use reduction proposals, and two workshops for manufacturers and lenders on toxics use reduction finance. OTA and the Northeast Waste Management Officials Association (NEWMOA) developed several case studies, and trained technical assistance staff on financial analysis fundamentals.

OTA and NEWMOA found that under traditional accounting practices, many of the significant bottom-line savings in regulatory fees, treatment and disposal costs, and other indirect materials and labor costs, were charged to company overhead accounts and often ignored in financial analysis. Case studies at several manufacturers showed how a more refined technique of financial analysis, one that attributes more costs to specific processes, is more suitable for assessing the bottom-line impact of toxics use reduction projectss. In the process of preparing case studies and experimenting with providing financial analysis services, the Office recognized the need to establish a full-time financial analyses position and the utility of training its engineers and scientists to discuss toxics use reduction in not only technical terms, but financial nomenclature as well.

Financial Services

-

'OTA performed the study with the help of additional funding from the Hazardous ___ Substance Research Center at the New Jersey Institute of Technology and in conjunction with the Northeast Waste Management Officials Association.

d. The Northeast Waste Management Officials' Association and The Massachusetts Office of Technical Assistance. 1992.

'For a summary of fmancial analysis methods and case studies. see: . . . .

28

The Central Massachusetts Pollution Prevention Pmjecl

4. Central-Mass Project Findings 'IMs section presents the five chief findings of the Central-Mass Project. These findings stem from OTA's own post-project review and ECO's evaluation which consisted of:

A telephone survey of 293 companies to determine if firms made toxics use reduction changes; to determine awareness and usage of, and attitudes about, OTA services; and to measure attitudes regarding nonregulatory-regulatory coordination. ECO completed interviews with 110 firms; 183 frms did not meet screening criteria, refused to participate in the study, or could not be contacted. Personal interviews at 28 firms to measure toxics use reduction results and to obtain more detailed data concerning OTA effectiveness.

ECO sampled two groups of companies in the study, a Target and a Control Group. The Target Group was defined by industry (metal-intensive) and geography (located within the 19 cities and towns in the Upper Blackstone River watershed). The Control Group also consisted of metal- intensive fums, but these fums were spread geographically across Massachusetts, outside of the Upper Blackstone River watershed. The vast majority of Control Group firms had no previous OTA exposure. The Control Group enabled ECO to compare toxic use reduction activity and performance, awareness, and usage of OTA services, and attitudes about regulatory coordination inside and outside the Central-Mass Project area. Appendix 5 summarizes the ECO study research design, data collection, and analysis methodology. Many of the quantitative findings found in th is and subsequent sections stem from ECO's evaluation.

Finding 1:

Regulatory-nonregulatory coordination benefited all agencies and industries

The Central-Mass and Blackstone Projects demonstrated that environmental agencies can enhance their effectiveness and increase the likelihood of successful toxics use reduction by teaming together. The success of the projects prompted OTA and DEP to extend their collaboration state-wide. The approach yielded four chief benefits: 1. Regulatory referrals increased use of technical assistance services. -

Coordination encouraged firms to utilize OTA's pollution prevention services. Two-thirds of OTA site visits were at least partially the result of a regulatory referral (Box 4-1 following page). 2. Nonregulatory program crucial to integrating TUR into regulatory program

In the opinion of Blackstone inspectors, interagency coordination with OTA enhanced the activities of DEP and the local POW. OTA provided

29

The Cabal Msssachusetb P d l u h Prevenh Projed 4. Canbal-Mas Project Findings

BOX 4-1

I Reaulatorv Referrals I

OTA Outreach Alone 13

POTW Referrals 12

Blackstone Project Referrals (DEP and POTW) Multi-Agency Referrals IOTA. DEP and/or P O W

10

5

. I Regulatory 0 Nonregulatory Don't Know

30

The Cenlral Massachusetts Pollution Prevention Project 4. Cenbal-Mass Project Findings

valuable additions to the Blackstone inspection protocol. OTA’s input and the industry-specific pollution prevention training provided by OTA was essential to the success of the Blackstone Project6. The training enabled DEP inspectors to spot source reduction opportunities, communicate their benefits, and where appropriate, integrate source reduction into the agency’s

3. Close coordination did not compromise the mission of either agency: Despite concern that coordination might compromise the nonregulatory

status of OTA and the regulatory status of DEP and the Worcester POTW, the coordination did not compromise the mission or perception of any agency. As Box 4-2 on the facing page shows, when respondents were read a list of agencies and asked to tell whether that agency was regulatory or nonregulatory, over 80 percent of firms in the Central-Mass Project area were aware that OTA was a nonregulatory agency. Contrary to DEP expectations that the promotion of source reduction by a regulator would soften its image a$ an enforcement authority, nearly all companies interviewed saw DEP as a regulatory agency. By promoting source reduction, DEP did not relieve firms from their compliance responsibilities, rather DEP promoted source reduction as a primary method for firms to meet their regulatory obligations.

Moreover, in the opinion of the Central-Mass and Blackstone Project teams, the partnership between OTA and DEP enhanced DEP’s regulatory activities, encouraged industry use of OTA’s expertise, and did not compromise the mission or good reputation of either department. 4. Industry benefited from nonregulatory-regulatory coordination.

find cost-effective solutions to their manufacturing andor regulatory problems. These referrals were especially helpful to small, owner-operated firms with limited financial and technical resources. Second, rather than receiving conflicting messages from nonregulatory and regulatory agencies, OTA, DEP and the POTW consistently promoted source reduction as the preferred method of maintaining compliance as opposed to disparate compliance methcds such as media-specific pollution control. Third, the Blackstone facility-wide inspection reduced staff-related costs during DEP inspections and identified specific source reduction opportunities for the company’s benefit (Box 4-3 following page).

-

enforcement actions. -

First, the POTW and DEP referrals of OTA’s services helped industry

Finding 2:

The Central-Mass Project Significantly Influenced Firms to Institute TUR

The ECO study examined the toxics use reduction accomplishments of firms that worked with OTA and compared those accomplishments to firms that did not work with OTA’. ECO found that: -

a significantly higher percentage of companies in the Target Group did toxics use reduction than in the Control Group.

Changes * 87 percent of the firms that attended Central-Mass workshops andor -

6FY90Reporl on rhe Blackrtone Projecr. The Massachusetts Department of Environ- mental Protection and the Massachusetts Department of Environmental Management. 1990.

’In evaluating the Central-Mass Project, ECO used the Massachusetu Toxics Use Reduction Act of 1989 defmition for toxics use reduction. This definition cites six toxics use reduction methods: input substitution, process redesign, product reformulation. process modernization, improved operation and maintenance, andbr in-process recycling.

31

The Central Msssachuse~ Pdlubn Prevanbn Projed 4. Central-Mass Project Findings

BOX 4-3

Summary of Nonregulatory-Regulatory Coordination Benefits

OTA BENEFITS DEPand POTW referrals resulted in 27 firms contacting OTA for on-site consultations. DEP sends OTA copies of facility-wide inspection reports. OTAusedthereports, which recordchemical use,diagrammed all production processes, and noted source reduction opportunities, to prepare for site-visits to firms referred by DEP. OTA inculcates the much larger regulatory agency with pollution prevention practices and policies. OTA leams about regulatory permitting, inspection, and enforcement activities, knowledge that is important to OTAs industrial clients.

DEP meets the objective of introducing source reduction into theagency's activitiesviaOTA training and informal interaction. In the first year of the Blackstone Project, DEP inspectors identified specificsource reduction opportunities at 1 6 facilities. DEP incorporated source reduction into numerous enforcement actions; in three cases, DEP required firms to evaluate source reduction strategies, all three consequently made source reduction modifications to attain compliance. DEP wasable toaddress water-relatedcompliance issues by coordinating inspections with the POTW.

.

DEP BENEFITS

.

. P O W BENEFITS

- POTWinspeciorsreceivetraining onsourcereductionmethods for attaining compliance. The POW, which lacked a strong enforcement program, gained from the added enforcement power of DEP. Coordination with OTA provides the POTW with a free, confidential source of technical assistance to recommend to its industrial dischargers. ThePOWleamedaboutairandwaste regulatoryprograms, knowledge that helped POTW personnel to improve inspection and enforcement activities.

Companies receiving regulatory enforcement were referred to a source of free technical expertise. Ratherthan receiving conflicting messages from nonregulatory and regulatory agencies, companies received a consistent message promotingsource reduction as the preferred method of maintaining compliance.

INDUSTRY . ,

32

The h b a l MasSachuseKs Pollution Prevention P@ci 4. Central-Mass Project Findings

BOX 4-4

Firm did TUR 0 NO TUR No OTA Services Used (N = 79)

received on-site consultations did toxics use reduction, compared to only 39 percent of firms that did not use Central-Mass services (Box 4 4 above). Over half of the companies that interacted with OTA at workshops or during site visits said the interaction influenced them to make pollution prevention or toxics use reduction changes*. Although the number of cases is small, ECO found that firms that attended Central-Mass workshops and/or had a site visit were significantly more likely to do toxics use reduction than those using no Central-Mass services. Similarly, firms that used OTA services and had a Blackstone inspection, were significantly more likely to do toxics use reduction9 (Box 4-5 following page).

In addition to qualitative measures of the effectiveness of the Central- Mass Project, the ECO study revealed quantitative measures of the project's success. From interviews with 20 f m s that participated in the Project, ECO examined use of all TURA listed substances and documented overall 73 percent - or 1.25 million pounds of - toxics use reduction. These reductions (Box 4-6 following page) show the effect that reduced use of toxic materials can have on all sectors of the environment. The mean (average) reduction for all companies was 65 percent and the median (the middle company on the list) was 76 percent; the mean reduction in chemical use was 44,612 pounds and the median 8,321 pounds. The reductions were achieved in four chemical c1asses:'solvents. such as 1,1,1 trichlomthane; acids, such as hydrochloric; metals, such as chromium or zinc; and miscellaneous chemicals, such as potassium ferricyanide or ammonium persulfate.

*

-

-

The 1.25 million pounds of chemical reductions only partially account ___

I320 believes the survey underestimated the number of firms saying that OTA interaction influenced them to make TUR changes, primarily because ECO was often unable to interview the person at the facility who had attended Central-Mass workshops and/or accompanied OTA on their site visit.

'Statistical tests (non-paramebic chi-squared) of the data showed that OTA had a significant impact on TLJR implementation. The tests were significant to the 99.99% level.

33

The Cenbal Massachusetls Pollution Prevention Proiect 4. Central-Mass Project Findings

BOX 4-6

BOX 4-5

TUR Performance vs Agency Interaction - , , ~ ,

Agency Interacctton N R N o N R Central-Mass visitfworkshop 85% 15% DEP/POTW Inspection (11) (2) Central-Mass visitlworkshoD 92% 8% No DEP/POTW Inspection (12) (1)

No Central-Mass visitlworkshop DEP/POlWlnspection :L 1 No Central-Mass visitlworkshop 39% 60% No DEP/POTW Inspection

TUR Reductions (18 companies, 24 chemicals)

Media In product

Air waste

Water waste

Miscellaneous

0 Hazwaste

Pounds Reduced 47,400 Ibs

526,434 Ibs

490,511 Ibs

3,097 Ibs

171,736 Ibs

34

The Central Massachuseb PdluSon Prevention Project 4. Central-Mass Project Findings

BOX 4-7

I Reason Chemical was Targeted for TUR (From in-depth interviews, 28 companies, N= 93 responses)

Cost reduction

Comply w/ regulations

Worker heakhkafety Management policy

Competitive pressure

TOM caused TUR

Environmental concerns

Negative public relations

Liabiliiy concerns Production problem

Future supply concern

Other I 15 20 25 30 35

(prcenf Of responses) 0 5 10

for the reductions of Central-Mass Project participants. Additional reductions quantified in the ECO study and by OTA staff members include:

Water conservation projects at 11 firms, saving a combined 675 million gallons per year, or 2 million gallons per day. ECO found that firms that did not do water conservation projects were firms that used little or no water in their processes. Oil conservation at six firms by switching from non-recyclable sulfur based oils to recyclable, water soluble coolant or by replacing metalworking machines. Reductions by more than 30 other companies that used OTA services but for which ECO was unable to perfom personal interviews. Many of these firms made substantial reductions in chemicals such as chlorofluorocarbons, cyanide, 1.1.1 trichloroethane, and zinc. Case studies of five of these firms are located in Appendix 6 of this report.

-

-

-

Finding 3: For the most part, fn" that implemented toxics use reduction changes realized positive financial results. Indepth interviews with 28 companies

change, versus no change or a pollution control change, was cost reductionlo; other motivating factors such as compliance with regulations or worker health and safety were significantly less important (Box 4-7 above).

of their toxics use reduction projects. But, on a case-by-case basis, OTA was able to collect cost reduction information. At seven fKms, OTA documented

Projects Had a showed that the primary reason a firm chose to make a toxics use reduction - Financial Impact

__ Ironically, OTA found that most firms do not track the financial results

'OFor each completed TUR project, fms were asked for the reason(s) the chemical was targeted for TUR.

35

The Cenbal Massachusetts PolluSon Prevention Project 4. Cenlral-Mass Project Findings

a combined annual cost reduction of $248,000, or an average annual cost savings of more than $35,000 per company. These cost savings represent a significant improvement in internal cash flow for the mostly small and medium sized owner-operated businesses with which OTA typically works.

Finding 4: Federal funding of the Central-Mass Project played a significant role in its success. The project was innovative at its inception, for no other federal,

Federal funding and oversight state, or local government had attempted such a multi-agency, source played a key role in program and reduction biased effort. Such an effort would have faced internal barriers to policy innovation funding from the agencies' budgets, since other, more established programs

had greater political power over the budget process. In addition, the increasingly tight state budget constraints of the late 1980's meant that new projects, such as the Central-Mass project, would have been cut if federal funds had not been available. The three year grant, which guaranteed funding for the project's duration, freed it from a yearly budget battle.

project, the grant agreement also allowed considerable flexibility in implementation. More specifically, OTA was not burdened by excessive grant reporting requirements, nor with zealous oversight, leaving the project engineers with the flexibility to experiment with technical assistance services and coordination models.

-

Not only did the EPA grant allow Massachusetts to design an innovative

Finding 5:

Industry found central- mass services needed and useful but with room for improvement

Overall, ECO found that OTA's clients perceive OTA as professional,

Of OTA services, clients rated workshops most highly for overall effectiveness, followed closely by on-site consultations, printed materials, and telephone assistance. Most companies believed OTA was providing the right services, only 16 of 110 firms could think of any additional services OTA could provide, the most frequently mentioned of which was help filling out forms required by the state Toxics Use Reduction Act. OTA was much better known in the Target Group (61.3 percent knew of OTA) than the Control Group (31.3 percent knew of OTA), indicating that OTA is known better in areas where it focuses. Many companies liked the pollution prevention changes OTA recommended, since many of these recommendations resulted in significant cost savings.

trustworthy, responsive, and enthusiastic.

*

-

OTA's clients identified four key areas for OTA improvement. First, - OTA needs to improve its marketing capability. One firm thought the Central-Mass workshop series was run by the workshop site's landlord. Second, industry felt that OTA's staff should have more technical expertise and experience. Third, fums would like to see more consistent follow-up after site visits. Finally, OTA's clients wanted more specific information for their specific problems. In addition to these areas for improvement, firms expressed desire for assistance in meeting regulatory requirements, identifying substitute chemicals, and networking with other professionals.

-

36

The Central Massachusetts Pollulon Prevenson Project

5. Expanding the Focus: From Pilot to Program

With the passage of the Massachusetts Toxics Use Reduction Act, OTA has grown from a five person office to over 30 staff members, with an budget exceeding $1.4 million. OTA is currently the largest technical assistance program in the nation. As OTA has added staff, it has expanded across the state, identifying and contacting local resources such as Chambers of Commerce, Regional Planning Agencies, trade and professional organizations, and various civic groups. OTA has also identified firms willing to serve on regional advisory committees and to facilitate the Office's introduction to the business community.

Because of the success of the Blackstone and Central-Mass Projects, DEP and OTA are expanding many of the regulatory and nonregulatory methcds developed in the two pilots Commonwealth-wide. DEP is introducing facility-wide inspection procedures in all of its regional offices. Known as Waste Prevention FIRST (Facility-wide Inspections to Reduce Sources of Toxics), DEP inspectors have received training in all media programs, toxics use reduction methods, and source reduction biased enforcement. In the process, DEP negotiated with EPA to receive credit for incorporating source reduction into inspections and for inspecting minor pollution sources.

Broadening the of Expertise

In the Central-Mass Project, OTA's pollution prevention efforts were centered on the metal intensive industries. During the recent expansion, the Office has aimed to broaden its expertise so as to encompass the full range of industries in the Commonwealth. OTA now provides assistance to companies in such diverse industries as fiber optics, electronics, coating, fiuniture manufacturing, textiles, food processing, printing, photoprocessing, and paint manufacturing. The Office has also established a full-time financial analyst position, to help firms evaluate the economic implications of toxics use reduction projects.

In expanding the organization, OTA has increased the experience of the staff. The ECO study showed that while most companies who have worked with OTA believe that the Office offers useful and needed services, some companies report a measure of dissatisfaction with the youth and inexperience of the Cenrral-Mass Project staff. OTA has made a concerted effort to address this concern by hiring more experienced engineers; over half of the staff now has extensive industry experience.

Range

31

The Cenbal Massachuselts Pollueon Prevention Project 5. Expanding the Focus: From Pilot to Program

The greatly expanded staff continues to provide many of the same technical assistance services offered in the Central-Mass Project. OTA has

Continuing to Learn initiated a few new changes to the program, including hand-delivering site- visit reports rather than mailing them to the firm. In hand-delivering the reports, OTA looks to elicit verbal commitment from the firm to implement

firms. In the demonstration projects, OTA gets involved in the hands-on planning and implementation of production-line changes. OTA views its technical assistance services dynamically. Pollution prevention is a rapidly changing field and OTA must adjust its services as new technology evolves, the business climate changes, and regulations at all levels of government affect the production choices of industry.

has taken longer than anticipated. The Office had expected its successful experience in Central Massachusetts to result in a shorter start-up time as the program expanded to other regions. However, OTA has found that in spite of the greater awareness of pollution prevention at both the federal and state level, it requires time and diligence to build cooperative relationships with the business community. OTA found that it cannot skip basic organizing steps, such as identifying local resources and spending six to nine months in the field demonstrating the Office’s value to local businesses.

OTA and DEP have also spent considerable effort replicating their interagency cooperation to areas outside of Central Massachusetts. The coordination developed in the Blackstone and Central-Mass Projects was largely the result of insulating the projects from many in DEP who thought they would fail. But due to this insulation, many in DEP did not see the value of interagency coordination and source reduction biased inspections and enforcement. As a result, DEP and OTA were faced with institutional resistance that they did not have to contend with during the pilot project.

The efforts of OTA and DEP have paid off. All five of OTA’s regional programs have now established cooperative links with regulatory agencies -whether Federal, state, or local - that are active in their area. The close ties between DEP and OTA have brought a large number of new referrals, greatly multiplying the number of firms reached by OTA’s technical services. Ideally, OTA would like everyone doing health, safety, or environmental compliance inspections to be familiar with OTA and its services, and to know that the Commonwealth of Massachusetts considers toxics use reduction to be the. preferred approach to environmental protection.

~

OTA’s recommendations. OTA has also begun demonstration projects with -

-

OTA’s expansion out of Central Massachusetts to new parts of the state

38

, Thecentral Maasachusetls Polluson PrevenSon Project

Appendix 1

Appendix 2

Appendix 3

Appendix 4

Appendix 5

Appendix 6

Appendices

Central-Mass Project Budget


Sample Site-Visit Report

Pre-visit Questionnaire

Central-Mass Project Evaluation

Central-Mass Success Stories

1

2

5

9

12

15 Metals Recovery and Wastewater Reduction at Hi-Tech Gold Plating Cop. Wastewater and Chemical Use Reduction at L&J of New England, Inc.

15 17 19 21 23

Solvent Use Reduction at Lampin Corporation Zinc Discharge Reduction at the Lowell Corporation Coolant Substitution at Presment Corporation

The hbal Masachusetts PolluGon Prevention Pmjecl

Appendix 1: Central-Mass Project Budget

Federal Funding Item OTA Salary and Expenses DEP Inspector/ Recycling

Travel Otber (lap top computer, misc.

Coordinator

expenses)

Total EPA Funding Funds Not Spent Total EPA Grant

State Match Item OTA Source Reduction Program

Manager Salary (part-time) OTA Additional Match OTA Interns (Salary) DEP Blackstone Inspection

Coordinator Salary

Total State Match

Total Project Costs

X!ad yearz 57,823 51,417 19,831 55,892

1.500. 2,000 4,655 1,895

83,809 1 1 1,204

.

X!ad yearz 19,290 4.216

11.932' 0

0 15,000 33,800 35,152

65,022 54,368

148,831 165,572

u i L 3 mal 72,870 182,765 14,831 90.560

1,500 5,000 0 5,895

89,207 284,220

4,689 288,909

uaL3 Tptal

0 23,506

64,251' 16,183 13,000 28,000 36,452 105,404

113,703 233,093

202,910 522,002

'Additional OTA staff worked part-time on the Project during the fmst year, including tbeTechnical Review Section Chief, the Small Quantity Generators Program Manager, and the Public Participation Section Chief.

Environmental C m Organization (ECO).

1

'Contract amount for the Central-Mass Project evaluation performed by the

The Cenbal Massachusetls Pdluh Prevenh Project

Appendix 2: Memorandum of Understanding

MEMORANDUM OF UNDERSTANDING

between

Department of Environmental Management and

Department of Environmental Protection

IhTRODUCTION

This memorandum of understanding (MOU) outlines the roles and responsibilities of the Massachusetts Department of Environmental Management (DEM) and the Massachusetts Department of Environmental Protection (DEP) in a joint project in Central Massachusetts. This project will specifically promote reductions in the use of toxic materials and hazardous emissions, provide technical assistance coordinated with regulatory inspections, promote reductions in cross-media transfers of pollution, and promote information sharing with federal and state agencies.

This %/LOCI, specifjing the activities associated with ;he DEM Central Massachusetts Source Reduction Project and the DEP Blackstone River Project, is divided into three areas: joint responsibilities, DEP responsibilities, and DEM responsibilities. This MOU does not create nor convey rights or authorities to any person(s) other than the signatories of this MOU.

JOIhT RESPONSIBILITIES

1.

2.

3.

4.

5.

Each agency agrees to abide by the provisions of this MOU. Questions about interpretations or implementation of the MOU will be resolved through discussions by the Commissioners' designees or, if needed, by the Commissioners themselves.

All statutory responsibilities assigned to each agency remain intact. In particular, DEP is solely responsible for enforcing the laws and regulations under the authority granted to it.

DEM and DEP agree to work cooperatively and to promote source reduction, waste prevention, pollution prevention, and toxia use reduction. -

Each agency will prepare a semiannual report, the first due November 1, 1989. Each subsequent report will be due on the 15th of the month for every six month interval thereafter. DEM will include each semiannual DEP report in its semiannual report to EPA under the terms of its grant for the Central Massachusetts Source Reduction Project.

Representatives of each Department (specified members of the project team) agree to meet weekly regarding activities in the project.

-

The Central Massaehuset$ Pollution PrevenCon Project Appendb 2: Memorandum of Understanding

6. DEM and DEP will conduct a joint training program for appropriate staff including identifying potential source reduction opportunities and technologies.

External communications with industry, public officials, citizens, and media are the responsibility of each agency individually. Each agency will keep the other informed of external communications.

The agencies will cooperate in the development of a list of all firms in the geographic area defined for the project subject to the activities of either agency wtnin tne terms or tnis MUU.

The DEM Commissioner's designee is the Director of the Office of Safe Waste Management. The DEP Commissioner's designee is the Assistant Commissioner for Waste Prevention.

7.

8.

9.

DEP RESPONSIBILITIES

1. DEP will conduct multi-media inspections of industrial firms in the geographic area defined for the project.

_. 7 If, as a result of an inspection, violations a re identified, DEP will:

a. Take appropriate enforcement action(s).

b. Describe violations at the weekly compliance meeting with DEM staff to identify potential source reduction opportunities that enhance compliance.

If source reduction opportunities appear to be available, DEP will notify the violator through a statement encouraging the firm to explore using source reduction to come into compliance, a statement (but not a requirement) that DEM is available for technical assistance, and a notation that a copy of the notice will be sent to DEM.

DEP will provide a copy of noncompliance correspondence to DEM.

c.

d.

If, as a result of an inspection, no violation is alleged, DEP will:

a.

3.

Make the inspection report available to DEM at its request.

b. Discuss the inspection at the weekly compliance briefing and make note - of any source reduction opportunities identified during the course of the inspection or at the compliance briefing.

3

The Cenbal Massachusetts Pollution Prevenlion Pmject Appendk 2: Memorandum of Understanding

c. If source reduction opportunities are available, DEP will send a letter to the firm, noting potential reduction opportunities and describing the availability of technical assistance from DEM.

~

DEM RESPONSIBILITIES -

1. DEM will provide source reduction technical assistance to industrial firms in the geographic area defined for the project.

DEM will accept referrals from DEP beginning the date of the signing of this

Highest priority for technical assistance will be given to firms that contact DEM as a result of an enforcement action from a regulatory agency. Second highest priority will be given to firms that are in compliance but contact DEM as a result of a letter from a regulatory agency. Lower priority will be given to all others.

DEM will help review cases of noncompliance and inspection reports for source reduction potential at the weekly briefings.

At the weekly meeting! DEM will, at DEP request give a source reduction update on firms receivlng technical assistance as a result of a DEP referral.

A copy cf a DEM report t~ each fin referred for technical assistance by DEP will G!: given to BEP concurrently with distribution to the client.

-

2. & g i c c i i i C u b .

3.

4.

5.

6.

This MOU is in effect from the date of signing by the Commissioners of DEM and DEP to June 30, 1990. It may be extended for any period deemed necessary by mutual agreement.

icha d E. Kendall Commissioner Commissioner

Department of Environmental Department of Environmental Management Protection

/t$dr fJa

The central MaaSachuseUs Pollution Prevenlion Pmied

Appendix 3: Sample Site-Visit Report

Office of Technical Assistance August 20,1990

Company Representative Chief of Environmental Programs

Central-Mass Client Worcester, MA 01613

Dear Environmental Manager,

interesting and were impressed by your manufacturing operations. For the purposes of this letter, we have grouped recommendations into six sections. We are interested in working with you on these or any other areas to improve plant efficiencies and reduce waste generation.

WATER USE AND CONSERVATION

With this letter, we’ve enclosed information on conducting a water audit. Conducting an audit is the accepted way of determining exactly where water is used in the plant and where a reduction effort will generate the greatest savings. The audit materials include three items: a Water Audit Handbook, a Client Profile (basically a water audit form) and a Sample Water Audit Report. The Handbook describes how to identify reduction opportunities by measuring and mapping water use, evaluating data and generating recommendations. The Client Profile is a form for collecting the data. The Sample Report was produced using the Handbook and the Profile and is an example of the types of recommendations an audit generates. We’ve found that if a company decides to make water conservation a priority, and engages the enthusiasm of supervisors and employees alike, then ideas to reduce use, improve operations and save money are likely to appear. One of the areas you pointed out is the use of once through non-contact steam cooling water. Installing a chiller or cooling tower would significantly reduce water use in this operation.

During the tour, we reviewed two water intensive operations: the Acid Inspection Process and the Zy-Glo Inspection Process. There are opportunities in both processes to reduce water use and decrease waste generation. These techniques are listed below. 1. Filtration:

sediments that contaminate it. In-tank fdters also provide agitation to the tank to mix the solution and improve its performance. a s e tilters are effective on soap tanks since they remove soap suds that float on the tank surface and cling to workpieces. Reducing the foam on the surface reduces the drag in of soap into the next (rinse) tank. Reducing soap dragout may allow you to reduce water use in subsequent tanks. One of the good features of in-tank filters is that they operate in the tank and cannot spill due to a break or leak in the line. These filters could be used in other process tanks on the Zy-Glo and acid lines to extend the life of the baths. 2. Rinsing:

This letter is a follow up on my visit to your facility. We found your tour extremely

Installing in-tank filters will extend the life of your soap solutions by removing particles and

There are several ways to minimize water use in rinse tanks. They include aerating tanks to

5

The Cenbal MasMehuselb Pollution Prevention Pmjed Appendix 3: Sample Site-Visit Report

increase rinsing efficiency, counter-current rinsing, spray rinsing and reactive rinsing. Aeration im-proves mixing in the rinse tank and will allow you to reduce water use. We have enclosed several articles that describe the effect of aeration on rinsing. In particular, the article entitled Water Conser-vation rinsing efficiency.

Another water conservation technique is counter-current rinsing. If possible, rinses following every operation should be double counter-current rinses. Converting two flowing rinses to a double counter-current rinse will reduce water use by 90 percent. The enclosed article

, details how a counter- entitled 3 current set-up reduces water use.

Spray or fog rinsing reduces water use. Spray rinses work well above any heated tanks. For example, on soap tanks, the spray reduces soap dragout into the rinse tanks. The spray rinsewater makes up for e v a p t i v e losses off the heated tank. The volume of spray water used should equal the amount of water added to the tank to make up for evaporative and dragout losses. We’ve included literature on fog spray nozzles and a paper on how to properly apply the technique to your process. (Pages 707-709 of R&& by Pinkerton and Graham.) You may be able to apply this technique on any heared tank.

rinses following an alkaline soap tank Reactive rinsing is described on p. 68 of the enclosed article, Where possible, all cleanedacid rinses should be connected this way. 3. Drain Boards:

Installing a small drain b o d between process tanks will (1) reduce dragout and (2) reduce floor spills. Drain boards are one of the simplest ways to keep solution where it belongs, in its process tank. ’Ihe use of drain boards is outlined on page 70 in the enclosed article, &I&

4. Dragout:

of water needed to rinse the workpieces. Lkagout reduction techniques include decreasing the withdrawal speed of parts from the tank and increasing the drip time over the process tank before indexing to the next location. Racking parts so that they drain more readily reduces dragout; the best way to rack parts is with cupped surfaces upside-down and with the smallest horizontal geometry hanging down. Increasing the temperature at which you run your bath will reduce the solution’s viscosity, allowing the part to drain faster. Increasing the operating temperature increases evaporation and will allow you to return more dragout solution to the process tank 5. Improve House-keeping: One of the least costly but most eficient ways to reduce waste generation is to examine housekeeping procedures in your facility. Fixing leaking tanks, reducing spills, improving storage and handling procedures and adjusting schedules are changes that can be easily made with little capital investment and yield significant savings. WASTE TREATMENT

?here may be opportunities for cost reductions in parts of the waste treatment process. You may be able to manage your waste acid in a less costly fashion by purifying the acid and reusing it. We have enclosed several articles on acid purification and reuse. We recommend looking at the cost of your current operation, including acid purchase, waste disposal, quality control and labor, to determine if a different acid management technique would be economical. In order for

Rinse Ta&l&&~ details how aeration improves

. .

Reactive rinsing is a rinsing design where the rinse that follows an acid tank is fed into the

[email protected] for Source Reduction of Wastc;s from -.

n of W p

By reducing dragout from process tanks you will reduce raw chemical costs and the volume

6

The Central Massachusetts Pollution Prevenlion Project Appndix 3: Sample Sitevisit Report

us to do a more thorough literature search on acid reuse, we would need more specific information on your process (e& acids used, materials etched and waste laboratory analysis). If working on this issue interests you, please give us a call.

Your firm could reduce costs in the waste treatment process by segregating the oily wastewater sludges from the F006 sludges. Segregating the wastes will reduce your annual disposal costs since oily wastes are much less costly to dispose of than F006 wastes. You could purchase another filter press just for F006 waste or segregate one waste into a decanting tank, draw water off the top, and ship the sludge. By examining what fraction of your waste is F006, you can estimate the savings you'll incur by segregating it out and managing it separately. CHEMICAL AND WASTE STORAGE AREA

compliance checklist for your storage areas. Even though you are a Large Quantity Generator, the Manual is a good guide for you to use as you walk around your plant and inspect different storage areas. In the chemical storage area for example, some drums were outside of the containment area. Others were not properly labeled. Perhaps access to the storage area should be limited by locking it off using a gate; only trained personnel would be allowed to use the area. You also might consider building a shed in the waste storage area. This would keep rain water out of the barrels and limit spills and leaks. Limiting access to this area would also help keep it clean and orderly. FORGING LUBRICANT

Based upon the condition of the floor around the forging area, it appears that the lubricant is over sprayed during the forging operation. Overspray on the floor is cleaned up with speedy-dry and manifested off-site. Since it is a manual operation, each operator probably applies the lubricants somewhat differently, causing different amounts of overspy and possibly affecting the repeatability and therefore the quality of the forging operation. Automating the lubricant delivery system could solve these problems by limiting spray to where it is needed in the amount it is needed. We have included information on spray nozzles that could be part of a controlled application system.

COOLANT MAINTENANCE

Some of your machine tools run on oil or without coolants. These machining operations, grinding and cutting may be suited to water based coolants. The true cost of machining with straight oils or no oil at all should be thoroughly examined to see if water based coolants could be instituted. These costs include tool replacement rates, tool downtime, coolant replacement rates, the number of off spec or rejected parts and worker health I work environment concerns. One reliable indicator of tool and machine performance is chip color. Bluish, black chips come from a machine tool operation generating excessive heat. This heat not only discolors the chips, but causes unnecessary wear on the tool piece and additionally hardens the work surface of the product. Temperatures needed to discolor the chip are high enough to cause oil to burn, creating excessive smoke in the shop.

Traditionally straight oils were used for lack of adequate alternatives., Due to new advances in emulsion technology, straight oils may be replaced with emulsions containing high pressure additives and lubricity packages. Water-based coolants can be as much as 35 percent less expensive than straight oils. In a situation where large quantities of coolant are being replaced, this can amount to a significant savings. Additionally, Massachusetts considers oil a hazardous waste, which increases disposal costs and environmental liability. Switching to an emulsion coolant would eliminate oil mist and smoke, improving operating conditions across the shop floor. Many facilities have been able to increase their speeds and feeds after converting to a water-based coolant. This is due primarily to the better heat transfer properties and lower

We have included a copy of DEP's Small Quantity Generator Manual for you to use as a

The Central MassachuseS Pollubm Prevenh Project Appendix 3: Sample Sitevisit Report

viscosity of the water based coolants. Increased production rates equates to greater savings in machine and labor time. A water based coolant would not load up the parts cleaning system as quickly as straight oils would. With less oil to be removed, cleaner life and efficiency would improve. ’Ihe longer a cleaner can be used the less it has to be replaced and disposed of. Changing to water based emulsions could reduce the company’s environmental liability. Decreasing the quantity of oil on site reduces the possibility of a spill, and decreases costs involved in clean up of a spill or leakage. We have included a fact sheet on coolant use in this package of information.

A chip spinner could be well utilized with a water based coolant system or with the current straight oil system. Clean, dry, machined chips have a higher resale scrap value than “wet” chips. Spun chips are less likely to leak oil or coolant on the storage area or create a spill if the drum is knocked over. In many shops the chips are spun not only to recover valuable coolant but to decrease the shop’s environmental liability as well. Scrap dealers are becoming partial to “dry” chips for the same liability reasons. I’ve included a list of vendors that sell chip spinners and other metal working aids.

PARTS CLEANING We are sending you information on water based cleaners as a substitute for your kerosene/

naphtha process. As mentioned earlier, switching to an aqueous coolant will reduce oils loading on the cleaner, effectively extending the cleaning efficiency. Although you are considering the Sky Products line of cleaners we have enclosed a list of additional cleaner substitutes. It is important to choose a cleaner that is ‘self cleaning’ in that it rejects the soil it removes (is. oils float to the top for skimming, particulates sink to the bottom and are removed via in tank tiltration). A cleaner that chemically fails to reject soils will contaminate more readily and need to be dumped. We have also enclosed an article on converting your degreaser to an aqueous cleaning unit. We have more aqueous cleaning information in the office, please call if you are interested.

WASTE MINIMIZATION GUIDANCE DOCUMENTS We have included two waste minimization guidance documents. One, the EF’APurple

Manual, is a bulky but excellent guide to establishing a waste reduction program. The second is a copy of EPA’s idea of what a waste minimization plan should look like, copied from the fede.ral register. These tools should help you organize your response to DEP.

We enjoyed meeting you, John, and Brian. We are interested in establishing a continuing relationship with you. While the improvements suggested appear to be extensive, they are relatively simple and should be approached on a step by step basis. If you have any question on these materials, please give us d call.

Sincerely,

Timothy J. Greiner Joseph E. Paluzzi

8

The Cenbal Massachusetk PollusM1 Prevention Pmject

Appendix 4: Pre-visit Questionnaire

COMMONWEALTH OF MASSACHUSETTS

OFFICE OF TECHNICAL ASSISTANCE 100 Cambndge Street, Room 2109

Boston, MA 02202 (617) 727-3260

Company Name: Facility Address:

Mailing Address:

Telephone up- Ext:-

Company Contact: Title

Standard Industrial Code (SIC)

How did you leam of OTA? Number of Company Employees:

CONFIDENTIAL INFORMATION 1. Briefly describe the products you manufacture or the service your company provides. When available please enclose a company sales brochure.

2.

3.

What unit operationdproduction processes are performed at your facility?

What specific unit operation(s)/production process(s) would you like OTA to help you with?

9

The Cenbal Massachuset$ Pdlulion Prevenlion Project Appendix 4: Pre-Visit Quesb’onnaire ~ ~

4. Please list the chemicals and their annual usages involved in the processes listed in question three.

5. Are process flow diagrams available for each particular unit operationlproduction process?

6. Indicate your facility’s hazardous waste status: (Excluding waste oil.) Large Quantity Generator, greater than 2200 1bsJmonth Small Quantity Generator, less than 2200 Ibs./month Very Small Generator, less than 200 Ibs./month

Y N Y N Y N

7. Which three hazardous waste does your facility generate in the largest quantity? Amount generated Description

1.

annually

8. Does your facility generate the following waste oil? Hydraulic Y N Corrosionprotection Y N Quenching Y N Skimmed Oil Y N

Lubricating Y N Metal working Y N Transformer Y N

9. Is‘ your facility recycling or reusing any ofthe following; Acid - Solvent __ Oil- Water- Other- Is it recycled on site or off site? Quantity

10. Please indicate the appmximate daily amount of your facility’s waste water in each category:

Process Non-Contact Cooling Other Total Daily Water Usage

11. Indicate where your facility’s waste water is discharged: P u b l i c l y Owned Treatment Works 0 Name:

-River/StreaollBody of Water Name:

-Septic tank and leach field -Other

l o

The Cenbal Massachusetts Pollu~on Prevention Pmjeet Appendix 4: Pre-Visit Questionnaire

12. Are you subject to pretreatment categorical discharge limits?

13. Is your facility registered as an air source with the Massachusetts Department of Environmental Protection? -Y -N -UN -NA

14. List your facility's primary source of air emissions(s) and indicate what operatiodproduction processes are the source of generation What chemicals are responsible for the emissions?

15. Does your facility report to the US. Environmental Agency @PA) under EPCRA, or SARA Title 111, Section 313 (Form R), or Massachusetts DEP TURA Form S?

How many chemicals do you report?

16. Briefly explain your reasons for contacting the Office of Technical Assistance (OTA).

17. Has your facility begun to prepare a Toxic Use Reduction Plan? Would you like assistance from OTA in preparing one?

18. Name, title and telephone number of person completing the questionnaire.

u---

please feel free to attach any other information you think may be helpful in our working together.

This informntion is provided for the use of the Ofice of Technical Assistance only and is protected by the confidentiality provisions of the Toxic Use Reduction Act unless exempted as a matter of law or by waiver.

11

The Central Massadtusetfs Pollution Prevention Pro@

Appendix 5: Central-Mass Project Evaluation

Evaluation of the Central Massachusetts Pollution Prevention Project

At the conclusion of the Central-Mass Project, OTA issued a request for proposals to evaluate the project. Among the three submitted, OTA selected the most complete proposal submitted by the Environmental Careers Organ- ization (ECO). The ECO evaluation was conducted in three parts: Research Design, Data Collection, and Analysis and Repon. Following are brief descriptions of the ECO methcdology.

’

Research Design

ECO worked closely with OTA staff to clarify and set priorities among research objectives. ECO designed two survey mechanisms to achieve the project goals and objectives:

A telephone survey to learn if firms made toxics use reduction changes; to learn awareness of, usage of, and attitudes about OTA servjces. and to measure. attitudes regarding nonregulatory-regulatory coordination. Personal interviews to measure. toxics use reduction performance and to obtain more detailed data concerning OTA effectiveness.

ECO sampled two groups of companies referred to throughout this summary as “Target” and ‘Control”. The target group was defined by industry (metal-intensive) and geography (falls within the 19 cities and towns in the Central-Mass Project). Additionally, all companies had some level of interaction with one or more agencies involved in the Central-Mass Project. The control group was also comprised of metal-intensive industries, but all companies were from outside the Central-Mass Project region.

For the target group, ECO used lists provided by OTA, DEP, and the local POW. ECO screened the list and eliminated companies that were not metal-intensive manufacturing businesses, that had left the state, or had gone out of business. ECO used the entire list of 159 remaining companies as the sample and attempted to survey at least one person within each company. The purpose of surveying a control group was to compare toxics use reduction activity and performance, awareness and usage of OTA services, and attitudes about regulatory coordination, inside and outside the Central- Mass region. ECO derived the control group from the Directory of Massachusetts Manufacturers, by drawing a random sample of 134 companies from outside the Central-Mass region in the metal-intensive industries.

*

*

-

.-

ECO contacted 293 companies in the telephone survey, completing interviews with 110 fms; 183 firms did not meet screening criteria or refused to participate in the study. ECO completed telephone interviews

Data Collection

12

The Cenbal Massachmtb Pollulion Prevention Pmject Appendix 5 Central-Maas Project Evaluation

I Telebhone Survev Sample performance

I CompaniesonList I 159 I 134 I 293

Ineligible Companies

Eligible Companies

Complete Interviews of Eligible Companies Eligible Companies that Refused to Participate

36 (23%)

123 (77%) 62 (50%) 41 (33%)

41 (31 %)

93 (69%) 48 (52%) 34 (37%)

77 (26%)

21 6 (74%) 110 (51%) 75 (35%)

with 110 firms, 62 in the Target Group and 48 in the Control. The table above presents the telephone survey sample performance results.

Sample Performance: Telephone Survey ECO conducted personal interviews with a subset of the firms that com-

pleted the telephone survey. To set up personal interviews, ECO contacted firms that indicated in the telephone survey that they had made toxics use reduction modifications'. During a follow-up phone call, ECO confirmed whether the f m had actually done toxics use reduction, whether or not measurement data on the firm's toxics use reduction changes was available, and if the firm was willing to meet with ECO to review their measurement results. ECO placed special emphasis on persuading companies with OTA interaction to participate in a personal interview. Each interview took from one to three days to complete. The results of the ECO screening process and the personal interview methcdology ECO used to collect toxics use reduction performance information is presented below:

Sample Performance: Personal Interview 83 companies claimed to have done toxics use reduction in the telephone survey 56 companies, upon closer examination, had truly done toxics use reduction; the remaining 27 did other forms of waste management. 28 of the qualified companies were interviewed. Of the 28 not interviewed, 16 refused to participate, four were unable to schedule interviews, five interviews were only partially completed, and three firm did not have sufficient measurement data available.

ECO Personal Interview Methodology

-

1. Determine chemicals for which firm made toxics use reduction changes. -

'In evaluating lhe Central-Mass Project, ECO used be Massachusetts Toxics Use Reduction Act of 1989 definition for toxics use reduction. This definition includes six loxia use reduction melhods: input substitution. proccss redesign. product reformulation. pmccss modernization. improved operation and maintenance. andlor in-proccss recycling.

13

The cenbal Massachusetls PciluGwi Prevention Pmject Appendix 5: Cenbal-Mass Project Evalualion

I Interview Results by OTA Interaction Type I

Telephone 20 24 46

Personal 9 11 16 (Some firms had multiple interactions)

-

2. For each chemical, learn motivation factors for doing toxics use

3. Analyze production processes that use the chemical. 4. Review available chemical data for inputs and outputs, including

reduction.

EPCRA Form R and TURA Form S, purchase records, sales records, raw material inventory records, process logs, production records, and engineering estimates.

5. Assess the validity of the data. 6. Identify a normalizing factor where possible. 7. Perform material balances before and after toxics use reduction,

8. Determine the best measure of company toxics use reduction

9. Conduct further evaluation of OTA effectiveness, where applicable. The chart above specifies the type of OTA interaction of firms that

normalize these results if possible.

perfOrmanCe.

participated in the ECO study.

Upon completion of the interviews, ECO tabulated the results, ran frequencies on all questions, and ran measures of central tendency and cross tabulations. The toxics use reduction measurement data were entered into an Excel spreadsheet for evaluation. ECO assessed the measurement data for accuracy, and collected additional information when appropriate. Toxics use reduction measurement data was analyzed using linear regression. measures of central tendency, and aoss tabulation. ECO prepared and presented a draft report, and incorporated OTA and DEP comments in its final report.

Analysis Methodology

14

The Cenbal Mamachusetts Pollulion Prevention Pmiea

Appendix 6: Central-Mass Success Stories

Office of Technical Assisfanee Executive OMce of Environmental Affairs

I - Commonwealth of Massachusetts t-tuuu.,

Toxics Use Reduction Case Study ~ METALS RECOVERY AND WASTEWATER ~ REDUCTION AT HI-TECH GOLD PLATING COW.

~ SUMMARY

Hi-TccbGoldPlating Corporation installedanelectmlylicmetals recovery system. implementedcountwflow rinshg, andmade sexad otberminormodifications to its plating l i e s in order IO reduce i o useof toxic substances w h i l e ' " c i n g profits. These changes resulted in a dramatic cutback in water consumption. togelher with Si@mt mductions in discharges of metals and other wastewaler contaminants. Tbis mvinmmentally sound invtstmcnc paid f a itself in about one year.

BACKGROUND

Hi-Tech Gold is a nine-worker plating job-sbop located in Worccscer, Massachusetls Ihal makes preCiSion ~aapu te r mqment s . The manufactwing process includes two plating lines - one for copper. nickel and gold and the Mbcr for silver and tin. Before parts eoter either line, their surfaEes are cleaned in a picwing tank.

Befaeitbe~toexplonToxinUseReduaiw (TUR)opl"nities, Hi-Tecbusedmctalreclamationunits d y in lbe gold and silver @ a t (rinse) lanLs. Hi-Tech's wastewater contaminant conmeations w c n within the openting limits set by thelocal sewerautbority. but the fum was aware that shicmdischarge limitswcnbeing poposed. and that these more exacting limits would eventually require modifications in its plating lines, equipment, and/a work pnctices. 'Ibcse considerations prompted Hi-Tech to launch a ptuactive investigation OfpocessmodiIicatioosthaIwould~celbe wnaopacioosofm~sandotbermntamiaanuinits wastewater.

OTA CONSULTATION

Io January of 1990. Hi-Tech Vice Resident Jeny T h i u t o ~ attended a workshop spoosond by the state Offi i of Technical Assistance (OTA). At the workshop, Mr. Tbiboutot lcamed tha~ other plating companies si" to Hi-Tech had deueawj water oonsumplion and reduced the level of cootaminants in their Wastewater by improVine their rinsing and metals recovery systems. Aha tbe worksbop, he visited two such companies.

' Ibescex~sconvioccd~.~ lbibwtotthatthewayto~~formwesPing~~tdiscbargcl imitswap not through betler wastewater tnapnen~ but through Toxics Use Reduction -- chat is, thtwgh pmduction line changes that pnvent pollution by reducing the use of toxic substances and/or tbe generation of toxic byproduco. Hi-Tech aimed its reduction effurp at two key waaewater contaminants -- meals and solveni-bascd cleaners.

TOXICS USE REDUCTION MODIFICATIONS

Hi-Tccb chose to make two maja modifications to its plating lines. The fum added an electrolytic meals mved 'y systems to its wppe, nickel. leal and lio operations (Figure 1). and provided for munterflow W i g (I"ncircMon) inaU plating pocesses Figure2). To minimize costs, second-hand recovery units, tanks I

l l m Cenbsl Mamchuselb Pol luh Prevention Project Appendb: 6: CenbaCMass Suwess Stories

and other equipment were purchased and rejuvenated. Hi-Tech managed tomakenearly all of these mobificatioas' with in-house personnel.

AttbeMmePme,Hi-TechmadeanumbaofmneminorTURmodificationsloitsplatingLiaes:it~oved fiverinsevalvestoprevent wascefulovertlowsofrinsingtanks, itaddedacyanideoxidatim uniltoredufficyanide discharges to the sewer, it replaad tbe solvent-based cleaner trichloroethylene CrCE) with an aqueo~s-baSed metals cleaner. and it began to purcbast steel coated with a thinner layer of preservative oils and grease.

RESULTS

Reductloas Acblevrd: Hi-Tech's TUR efforts brought on a 75% reduction in wB(B wnsumptim. fm mugbly 8000 to 2000 gallons per day. Initial results indicate that the metals m v e y units an removing at 1 m t 35% of tbe metals that previously went down the drain and into the sewer system. In addition, Hi-Tecb reduced iIs discharges of cyaaide and of fa& oil. and grease (FOG) by more than 50%. The FOG improvements were apparmUy due to the new steel supply.

Eeoaomics: The up-front equipment and labor costs ran to approximalely $2900. Yearly savings 00 water a I o n e m o u n t t o a b o u t S . Srrapmetalsrecovercdbytheuewsystemanexpectedto~ginaboutSlOOper year. Andwhilethccostoftheaqu~scleanerishigherthanTCElOl.theffiwcleaaingbathhasb&ninslallcd in a m m efficient location, thus saving on time and labor costs. Based 00 tbese inilial fig- the iovfstmml will pay for itself in about a year. and register a net in- in profits the".

FIGURE I: %"JSyrtan @pi@:

Rinse Recirculation

Electmly~ic Recovery Unit

FIGURE 2: CountapaU!W&~ P I :

- A- WOrkDinctim

up Water

To SeweriFiiter

16

The Central Massachusetls Pollulon Prevenlon Pr@jecl Appendix 6: CentraCMass Success Stories

Office of Technical Assistance Executive Office of Environmental Affairs - -

I Commonwealth of Massachusetts , * M I * u L UWll

Pollution Prevention Case Study WASTEWATER AND CHEMICAL USE REDUCTION

AT L&J OF NEW ENGLAND, INC.

SUMMARY

W of New England installed five flow control devices and three filtration units in is elenrocoatiog opcrationsinordcrtooeon walerandreduce itsuseofcleaningcbemicals. Tbisenvironmmtally beneficial cbange paid f a itself within ten months and saved the company Sa,ooO per year themafter.

BACKGROUND

WofNewEnglandisa Wa~cstcr-basedc~npanyspecializingioelectromating(alsbniqnefapainting meralsurfaces). S i i t s k g i n n i n g in 1969. thecompanyhasuntinuallyexpandedoperations.andithasbccane ollc of the kges t e l ec t ” in the region. employing 45 workers. LBU also operates a small serecniog shop.

E~lingisachicvedbywbjcctingametalobjeet~apositivechargcwbileitissubmcrgcdinasolution of deionized water and negatively cbarged paint ions. Tbe charge dincmtial cauw the paint to bod to the mctpllicsurfaa. Woprratcsthrccdifferent~~sfas~1,mediumandlargepam. Tbefumusesauylic(watcr- b=d)paints.

Ilk? small-pam system consists of a series of six tanks and an ovabead oven. A eonveya rack positions metal f u ~ r r c s above tbe ’ te tanks. and thc tanks aw hydraulically raised and lowend 10 meal tbe pam as tbey move down the p Z Z l i n e . % metals pam go tbroua six pIocess step: (1) h t c d c b i n g batb. (2) tap watcr rinse, (3) deionized water rinse for op(imal charge differential, (4) paint bath, (5) excess paint rinsc. and (6) oven drying and baking.

Tbemid-sized system uses extrarinsing stepand abeatcd iron-phosphate treatmentbalb forimprovedpaint adhesioll. Thclargesystem(seeFigure 1). w b i c b b a n d l e s ~ r i n g Z 5 ~ b i c f e e t usesaconlinuouslymoving COnVeYOr and bigh-press~n S ~ Y S ra“ tban p o c e ~ ~ tanks.

OTA CONSULTATION

WViceResiden~DonaldandDuncan~ithwereawanthatsomeoftheirprocessesbadexecssive water flow and mat CeRain baths were using large quantities of cleaning solution due to the accumulation of grit oil and smfm residues.

AI u1 OTA wokshop in 1990. they learned of two simple technologies that addressed these eoncems. Tbe fimtisatilIraIiondevicetbatop” bysLimmingthesurfaccresiduef” waterandncirculatingtheclean water back to the tanks. The secood is a flowcwtrol device that unstsntly monitors the cleanliness of a bath and adds CLan water only as oeccssary.


W installed five flowcootrol devices and three fflh.li00 units. Fbw untrols were ins(alkd on two tap watQ rinses in thc mid-sized system and 011 three Iap-water sprays in the large system. Two fflm were installed

The Cenbd Massachusetts Pdlulion Prevenh P+ct Appendix 6: Cenbel-Mass Succsss Stories

on lhe initial cleaning tanks for the mid-sized and large systems. The other film is ponable and is used mmUy on the iron-phosphate tank in tbe mid-sized system.

RESULTS

RcdudiomAeh*vcd:LBuexpcnmcedamarlredredudiooin waterusage. lbcnewfilaatioosystemalso nsuW in dramatic cutbacks iu the fm's use of cleaning solution. Far less solution is needed to dun adequately and to remove the residue W builds up on the surface of rinse tanks.

EeMlomler: LBu repons tba the filmtion and tlowanlrol deviccs paid for themselves in lhe fmt ten monthsof opaalion. The fdterscost $2.227 and tbe flowcoomldewiccscost $2688, including iasrallirtioa. Afm deducting tbe annual operacing wst of the filters, LBu experienced annual savings of $1,225 in cleaning solution purcbsc ODSLE and $4,689 in water and sew@ bills. Tbup. after the ten-montb payback period. savings amounted to approximately S6,OOO per year. As a result, LBrJ's management is actively pursuing other opportunities For pouution pnvelltion.

18

The Central MassachusePs Pollubn Prevention Pmhd Appendb; 6: CenbaCMas Success Stories

OffKe of Technical Assistance Executive Office of Environmental Affairs @ Iutu,ma,l,* Commonwealth of Massachusetts

,*IYO*(ImlUWI,

Toxics Use Reduction Case Study SOLVENT USE REDUCTION AT LAMPIN

CORPORATION

SUMMARY

Lampin Corporation replaced its chlorofluorocarbon (CFC) degreasing operations with a hot water washing process. The new process successfully cleans 95% of their products on the fmtrun-through, while creating two-thirds less sludge than the old solvent-based process. The change, which has saved the firm approximately $6.000 per year in CFC purchase costs alone, paid for itself in a little more than one year.

BACKGROUND

Lampin Corporation is a small manufacturer of precision-machined pans and components located in Uxbridge. Massachusetts. Lampin uses a sulphur-based cutting oil in machining its parts. and this oil must be removed from the finished products. Originally, Lampin used trichloroethylene W E ) as adegreasing agent. The fm switched to CFCs because they are safer for workers. less toxic to the immediate environment, and just as effective in removing cutting Oils.

OTA CONSULTATION

Scott Rossiter, president of Lampin Corporation, attended a local metal finishing trade association meeting, where he heardrepresentativesof the office OfTechnical Assistance (OTA) speaking about the general idea of pollution prevention -- that is. the idea of reducing or eliminating potential pollutants at the source. in the production processes themselves. Rossiter thenattendedan OTA workshop dealing with the specific issue of solvent substitution. After thii workshop, Rossiter decided to implement changes that would eliminate his fm's use of CFCs - in part because of the detrimental effect of this chemical on the stratospheric ozone layer. and in part because the changes in question promised to save Lampin money.


In the spring of 1990, Lampin suspended its use of CFCs. The fm removed its CFC tank and installed two new tanks in its place -- one for hot-water washing and the other for rinsing (see

19

The Central Maasachusem Pollulion Prevention Pmject Appendix 6 CenbaCMass Succaas Stories

Direction

JI

20

Y

HOT WATER TANK e--

RINSE WATER TANK

The Cenbal Massaehusetls PolluSon Prevenfion P@ct Appendix 6: CenbaCMass Succsss Stories

Offze of Technical Assislance

Commonwealth of Massachusetts @ Executive Office of Environmental Affairs

I.ltu111 -t .I w y u s

Toxics Use Reduction Case Study ZINC DISCHARGE REDUCTION AT THE LOWELL

CORPORATION

SUMMARY

Tbc Lowell Corporatioosddcdadead-water h tanL, drip boards and adrain rack to it$ zinc phosphating hchadatominimizc io lmscs of zinc while permitting sane reuse of pbsphatiag solutia~. Tbe produ*iotl l i t l c ~ g e - - w b i c h w a s ~ ~ o u t a t a ~ ~ t i n ~ ~ ~ - ~ t z ~ d ~ e s b y ~ o ~ , ~ g i n g tkfmintolitlcwitb berl sew~autbaitydis&argeischargelimits. Thigcoviromneotallybeneficialc~geeffcetively saved tk Lowell c w o n aplaoximately S ~ O O O pa year.

BACKGROUND

Tbc Lowell Ccqwmtion is a 28-mpIoyee machine tool shop which manufactures specialty ratfbcts hrm e g t h blanks. l k firm was bapcd h Worcesmuntil luneof 1991. buthas sinarelocntedto West Boylstoo. Aspat of the production poass, pieces of h n a n treated with zinc pbosphatc to improvccorrosion nsistana. Beforc it began to cxplorc Toxics Use Rcdu*ioo (TUR) oppatunities. tbc Lowell Corpanuioll used a zinc pbospbUiog linc with (wo pbosphrciag tanLS, each followed by a Nnniog-Water rinsC taOk. (See Figurc 1)

TIE. r e g i d sewer authority, ~ n o w n as Uic upper B~~CLS~OOC POIIU~~IM Abatmrcllt District (UBWPAD). measlad zinc coocmlrations in Lowell's wastewalm at4.47 ppm - coasidaably above the 2.61 ppm zinc limit specltica in the canpany's discharge pcrmil. UBWPAD insrmcted Lowell to bring its zinc didurges into litlc

of-bw @ospbatiog would add SZ6,OOO per year to i o op'ating costs. Lowell officials decided to inwtigate OCULI modificatiom that would remove zinc from its wastewater.

OI cllmionte its zinc phosphnting p o ~ e g s ~ s and a t n r t out tk phosphating work. A b dCtCdOiOg tbnt Out-

OTA CONSULTATION

Tbc UBWAD rcfcmd Lowell Plant Maaagcr Richard Giou to the Massachusetts Office of Technical Assistaact (OTA) for help in reducing zinc discharges. OTA proposed thc installation of a dead-wata rinse tank .ftathcsccoodpbo@atiog t a n k i n ~ a n l l ' s p ~ W n g line. (SeeFigurc 1) OTA'spastexpaiencc witbs imi i changes iadiated that this technique would decrease zinc drag-out by approximately 50%. Additionally. OTA suggcsccd mrp boards and drain racks ou all rinse rnnlrs to funhcrrcduee zinc dlagmt (see Figurc 2).


The Lowell caporaton cboae to install tbc dud-water drag-out tank. The change was hardly eompkx - - tk new tank carriedamodcst price lag and took ooly ten minutes to install.

21

The Cenkal MaasachuseetLs Pollution Prevenlion Project Appendix 6: CenkaCMass Succass Stories

1. cleaaa 5. Rinse Tank 2. Rinse Tank 6. Phosphate 3. Activating Etch 7. Rinse Tank 4. paoapbarc 8. Water-Soluble Oil

22

The Cenbal Massachusetts Pollulon Prevenh Project Appendix 6 CentraCMass Success Stories

Office of Technical Assistance Executive Office of Environmental Affairs - -~

.I 1 Commonwealth of Massachusetts ,*-NUL UI.,

Pollution Prevention Case Study COOLANT SUBSTITUTION AT PRESMET

CORPORATION

SUMMARY

The Presmet Corporation substituted a synthetic coolant for the sulphurized oil that it had traditionally used as a coolant in its honing process. The environmentally beneficial switch cut thecompany'scoolantpurchasecosts bytwothuds. whilesimultaneouslyreducingthe fm'soily water discharges and sparing workers the health problems associated with sulphurized oils.

BACKGROUND

Presmet is a 250-worker manufacturer of automobile components located in Worcester. Massachusetts. Certain parts made by Presmet require honing to close tolerances. Prior to its fust contact with the Ofice of Technical Assistance (OTA). Presmet used a sulphurized oil to lubricate parts during honing. This meant that finished parts had to be washed in hot water in order to remove the oil. (See Figure 1.) The sewer discharges from the hot-water wash tank had exceeded the limits on Fats, Oils, and Greases (FOG) set by the regional sewer authority, the Upper Blackstone Water Pollution Abatement District (UBWPAD).

OTA CONSULTATION

In January of 1990, chemical engineer Alan Buckley and manufacturing development engineer Tom Donohue sought alternatives to the sulphurized oil in order to help lower Presmet's FOG effluents. Through a referral from the UBWPAD, Presmet learned of OTA and its workshops on pollution prevention techniques. Buckley and Donohue attended a workshop on metalworking fluids re-use and recycling, and this prompted them to try a synthetic coolant in their honing process.


Sice beginning to use the synthetic oil. Presmet has seen no change in the quality of parts, despite the large variety of precision work performed on the honing machines. At the same time, the pollution problems formerly caused by the oil carried off on the parts have been eliminated.

Presmet hasnoticed some additional benefits of synthetic coolant. The new lubricantcleans

23

The Cdnbal Massa~ussap Pollulion Prevenlion Pmject Appendv 6: CanbaCMass Success Stories

. JI

Processing

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