Cal/EPA Environmental Management System Project Report to the Legislature: Seventh Quarterly Update October through May 2001

Environmental Performance Improvements

The ability of an EMS to increase public health and environmental protection over those protections provided through the current regulatory system is demonstrated in two ways. First, by evaluating indicators of environmental performance, such as improved compliance with environmental regulation, reduced generation of hazardous waste or reduced use of electricity prior to EMS adoption and after EMS adoption, improvements in public health and environmental protection can be quantified. Secondly, improvements in public health and environmental protection can be qualitatively described by evaluating the system of environmental management employed by an organization.

Findings

• Pilot project participants
  (1) improved compliance with environmental regulations through their EMSs,
  (2) further reduced environmental risks through improvements in regulated activities,
       including generation and handling of hazardous wastes, water and air emissions,
       and worker health and safety, and
  (3) reduced environmental burden through improvements in unregulated areas,
       including energy use, solid waste management, water use, and transportation
       impacts.

• Reductions in environmental burdens had multi-media benefits

• For those pilot participants that track and report EMS costs and benefits, ongoing benefits outweigh the initial cost.

Compliance
Pilot participants have demonstrated improved compliance as a result of implementation of EMSs. Improved compliance is demonstrated by the reduced number of citations issued by regulatory agencies as well as by improved awareness of regulatory requirements.

History of Improvement

Artistic Plating's compliance record has improved between their baseline and the update period. Artistic was not cited for any violations after their 1997 baseline through their year 2000 update data, while they had been cited for seven violations in the 1996-97 baseline period. In order to ensure compliance, copper discharges to the local wastewater treatment plant were reevaluated through their EMS process and reduced by monitoring the wastewater treatment process more closely and fine-tuning the pre-treatment process. It appears that the compliance improvement was in large part due to the systematic focus on compliance responsibilities afforded by the EMS, which included a complete compilation of all legal responsibilities, the communication of these responsibilities to all employees, and the creation of an effective compliance management system.

Significant improvements in environmental regulatory compliance have been derived from the EMS at Lockheed Martin Aeronautics Company in Palmdale (LM Aero-Palmdale). Since 1993, one notice of violation and four non-compliance events occurred. No violations have occurred since 1998.

Improved Awareness of Requirements

By using a corporate Environmental, Safety and Health (ESH) web site, LM Aero-Palmdale employees are able to keep apprised of legal and other requirements. Updated weekly, web site content includes regulatory information, guidance modules, best practices, training documents, energy saving information, and industry standards. The web site receives over 1600 hits per day. LM Aero-Palmdale staff also maintain a Master Reports List that identifies all environmental reports, the responsible agency, employee responsibility for the report and the due date. This facilitates tracking of all environmental reporting requirements.

Federal, State, and local regulatory requirements for Central Marin Sanitation Agency (CMSA) are quite extensive. Before performing the gap analysis and regulatory review required by the ISO 14001 Standard, CMSA had no central library of regulatory requirements and no document control system in place to manage the most current requirements and reporting procedures. Now CMSA has both a comprehensive library where the latest documents are housed as well as procedures for monitoring and reporting to regulators.

Regulated Areas

Pilot project participants demonstrated improvements in regulated areas as a result of their EMSs. Improvements include systematic management and reduction of toxic releases and hazardous waste, wastewater, air emissions, and worker health and safety problems. In many cases, performance improvements made went significantly beyond that required by law.

Management of Toxic Releases and Hazardous Waste

LM Aero-Palmdale has reduced production-related hazardous waste disposal by 82% (or by 1,174 tons) since 1992. Toxic chemical releases, reportable under the Superfund Amendment and Reauthorization Act (SARA), have decreased 91% (or by approximately 100,000 pounds) since 1991. LM Aero has been below the reporting threshold since 1996.

Between 1992 and 2000, total hazardous waste (production and non-production related) was reduced 91% at LM Aero-Palmdale. Prior to establishing their EMS in 1991, they generated 3,692 tons of hazardous waste compared to 448 tons in 1998. While between four and five hundred hazardous materials were used to support predecessor aircraft, the Joint Strike Fighter concept demonstrator aircraft uses fifty-four hazardous materials. All of these reductions represent environmental aspects that were determined to be significant by LM Aero-Palmdale. (Cal/EPA also found these aspects significant). Performance targets for each of these environmental aspects were established. On the basis of these findings, and the fact that performance enhancements went beyond that required by any permit, regulation, or order, it appears the reason for the improvement was the EMS and the process it represents.

Artistic Plating's top five environmental aspects and impacts are:

• perchloroethylene vapors from degreasing operations,
• chromium-containing wastewater from chrome plating,
• cyanide-containing wastewater from cyanide plating,
• liquid chlorine from cyanide wastewater reduction processes, and
• nitric acid from stripping operations.

A significant change by Artistic Plating was the elimination of perchlorethylene and replacement with an ultrasonic aqueous immersion cleaning tank for parts cleaning. This yielded a decreased public exposure risk, decreased risk to workers and decreased worker compensation insurance premiums, decreased medical and biological monitoring, decreased lab analysis and disposal costs, decreased air sampling costs, and decreased air quality district emission fees.

Artistic has reduced total chromium discharge to a level 50% lower than the permitted limit through several source reduction actions. Specifically, a new drip board was installed to reduce drag out (loss of chemicals from a plating tank), workers received drag out reduction training, and anodes were repositioned to achieve comparable plating at a lower chromium concentration.

The target to reduce Artistic's cyanide discharge concentration to a level 50% lower than the permitted limit has been achieved through source reduction actions, improved treatment and waste treatment. A third-stage cyanide treatment unit was added, workers received drag out reduction training, and the pH of the cyanide baths was lowered which improved cyanide treatment. Moreover, increased analytical monitoring was implemented on a bi-weekly basis to fine-tune the cyanide reduction pretreatment process. Finally, a cyanide-based nickel strip was eliminated from cyanide plating operations allowing for a 50% reduction in the amount of liquid chlorine usage.

In 2001, nitric acid usage has declined by 62% from the use of alternative chemicals that Artistic is testing. The target to reduce nitric acid use by 95% is in process. Material substitution alternatives are under investigation. Communication with chemical supply companies is ongoing in the search for more environmentally-benign chemicals.

All of these environmental aspects of the metal plating operations at Artistic were identified as significant in the EMS process. As a result, performance targets were set, a management system was established, and enhanced performance was achieved. As with other pilots, several of the performance enhancements went beyond legal requirements, suggesting the reason for the achievement is the EMS, and the process it established.

San Diego Metropolitan Wastewater Department, Operations and Maintenance Division has reduced the inventory of miscellaneous chemicals (cleaners, degreasers, lubricants, etc.) by 33%. Process optimization efforts have resulted in the Metro Biosolids Center reducing their cationic polymer use by 23%.

Wastewater
Artistic has reduced sludge volume indirectly by the installation of conductivity sensors in the rinsing tanks. Drag out techniques have been put into practice, enforced more strictly, and the overall operation of wastewater processes are monitored more consistently. Moreover, two additional wastewater treatment operators were added to this operation. Copper discharges to the sewage treatment plant were reduced by monitoring the wastewater treatment process more closely; fine tuning the pre-treatment process; and monitoring the wastewater discharge twice daily, using spectrophotometry equipment. Efforts to reduce process water use through source reduction and in-process recycling are ongoing.

Wastewater volume had increased in 1999 because a new wheel line requiring more water had been added to Artistic's production process. Conductivity sensors were added to all rinsing tanks. With the installation of this new equipment, Artistic realized a 72% decrease in wastewater produced in the wheel line, from12,960 gallons to 4000 gallons per day.

Air Emissions

Since 1990, volatile organic compounds have been reduced 80% at LM Aero-Palmdale. Volatile organic compounds were reduced from 256,000 lbs. in 1990 to 41,000 lbs. in 1998. Emissions of ozone depleting chemicals have been reduced from 403,000 lbs. in 1988 to zero in 1995.

Artistic's elimination of perchloroethylene as described above also resulted in a benefit to air quality.

Worker Health and Safety

Worker safety and health problems, indicated by "Days Away Case Rate," have been reduced by 66% since 1995 at LM Aero-Palmdale. They are 75% below the industry average.

Artistic's elimination of perchloroethylene as described above resulted in reduced risk to worker health and safety.

Unregulated Areas
Pilot project participants demonstrated improvements in unregulated, yet important areas as a result of their EMSs. Improvements include systematic management and reductions in energy use, solid waste disposal, water use, and employee transportation impacts.

Energy

While energy use is unregulated by government environmental agencies, it is monitored by organizations to achieve cost savings and environmental benefits.

The San Diego Metropolitan Wastewater Department, Operations and Maintenance Division estimates that the North City Water Reclamation Plant reduced its normalized electrical use by 10% for calendar year 2000. They estimate that Division-wide, they have exceeded their 5% reduction target. 

CMSA has prioritized objectives for reducing power consumption. One of the high priority objectives is the replacement of inefficient centrifuges for sludge drying with energy-efficient centrifuges.

Over the past several years, IBM has consistently met its energy conservation target, which is defined as an annual 4% reduction in consumption relative to what the consumption would have been in a given year without the conservation measures. One strategy used towards meeting the target involves the replacement of motors for production-related activities with high efficiency motors. IBM has met its energy conservation target of 4% for calendar year 2000.

Solid Waste

While a 50% solid waste disposal reduction is mandated for local government jurisdictions, businesses and industry are not regulated by this State law. Nevertheless, most pilot project participants have included increased recycling and/or decreased landfill disposal as an objective in their EMSs.

The IBM San Jose facility is on schedule to meet its current target to recycle 73% of its solid wastes, which exceeds IBM's corporate goal of 67%. The primary solid wastes that are recycled include scrap metals (41% of the total recycled materials), wood and landscape materials (18%), cardboard (14.6%), paper (9.7%), and construction materials (9.4%)

The Anheuser Busch, Fairfield, brewery achieves a 98.3% recycle rate of its wastes and byproducts.

Estimated landfill contributions were reduced 23% since 1999 for the San Diego Metropolitan Wastewater Department, Operations and Maintenance Division.

Water Use

Potable water use was reduced by 3% from 1999 and 33% from 1998, as reported by San Diego Metropolitan Wastewater Department, Operation and Maintenance Division.

Employee Transportation

CMSA's employee brainstorming activities generated multiple environmental impact-reducing activities. Employees suggested an alternative work schedule that would allow for 10-hour workdays covering only 4 days a week. The impact of this simple plan has reduced the number of commute trips 20% for operators and unexpectedly reduced the number of overtime hours.

IBM instituted programs to increase employee participation in commute alternatives that help to reduce congestion and improve air quality. Examples include providing each employee with a free pass to use public transportation as well as operating a shuttle service to the site from nearby transit stops and other local IBM locations. IBM measures the use of key elements of its Alternative Commute Program. For example, annual survey data show that employee participation in one of its programs (EcoPass) increased 52% from 1998 to 1999, and was used by approximately 24% of the site population.

Cost Savings
Hazardous waste disposal in 1991 cost LM Aero-Palmdale $1,421,000 compared to $375,000 in 1998.

For A-BI, the implementation of the EMS has led to decreases in energy costs, water and wastewater expenses, carbon dioxide costs, landfill disposal and transportation fees, hazardous waste disposal fees, and ammonia purchases. An indirect monetary benefit realized as a result of its EMS is the decreased insurance costs, environmental liability and workers compensation costs.

The costs and benefits realized from managing perchloroethylene, total chromium, cyanide, liquid chlorine, nitric acid, copper, and sludge are described below from estimates by Artistic Plating.

The elimination of perchloroethylene cost $130,000 in initial implementation and will save in the range of $9,500 to $10,500 per year in decreased air sampling costs, decreased medical and biological monitoring, savings in testing and lab analysis, decreased disposal costs, and reduced air quality factor emission fees. In addition, Artistic's insurance company intends to reduce workers compensation insurance premiums.

Discharges to the local treatment plant were reduced through increased water testing and lab analysis at a cost of $2,000 per year for total chromium, $4,500 per year for cyanide, and $2,000 per year for copper. A third stage tank with mixer and controls was added at a cost of $10,000.

Liquid chlorine usage was reduced, yielding $42,000 per year in savings. A reduction in other wastewater treatment materials saved $6,000 per year.

Nitric acid cost savings of $360 per day are realized through the reduction of plating rejects. Costs from nitric acid use in 2000 came from treatment of spent triacid (70% nitric acid) totaling $1,050 per week in additional costs, as well as $450 in added caustic soda costs per week. In 2001, nitric acid costs are being reduced by $750 per week through the testing of various substitutes.

Decreased sludge volume led to a savings of $18,896 per year in disposal costs, and $2,500 savings in reduced quantity of testing and lab analysis required. These savings justified the hiring of an additional treatment operator in April 2001 at $26,000 per year.

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