Cal/EPA Environmental Management System Project
Meeting Summary: Southern California Working Group
September 21, 2000 Anaheim, California

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A new phase of the California EMS Project has begun. Regional Working Group meetings are being organized to facilitate a dialogue between pilot project participants and stakeholders regarding facility EMS design and implementation. Pilot facilities are sharing information on EMS implementation, providing a facility tour, answering questions, and receiving feedback. Over twenty representatives from government agencies, other pilot companies and interested businesses, academia and public interest groups were in attendance at each of the September meetings of the Regional Working Groups. The Southern California Working Group met at Artistic Plating Company in Anaheim. The meeting highlighted the pollution prevention and compliance successes that have resulted from the implementation of their EMS.

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

• Introduction
• Background
• Unique EMS Characteristics
• Strategic Goals Program Goals
• EMS Overview
• Costs and Benefits

I. Introduction

Artistic Plating provided Southern California Working Group members with a tour of their facility operations and an overview of the EMS implementation progress on September 21, 2000. Artistic Plating is a medium-sized, 125 employee, metal finishing facility in Anaheim, California. The facility performs copper, nickel, brass, and chrome electroplating. Artistic specializes in electroplating zinc die-cast parts and aluminum wheels for commercial customers.

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II. Background

Artistic Plating has volunteered to test an EMS template developed by U.S. EPA as part of the Merit Partnership Metal Finishing EMS Template (MFEMS) project. The Merit Partnership for Pollution Prevention (Merit) is a cooperative venture of the public and private sectors whose mission is to develop and promote pollution prevention practices and technologies that both protect the environment and contribute to economic growth. Merit is conducting a series of pilot projects to evaluate the environmental and economic results of ISO 14001-based EMSs in various industries. (ISO 14001 is the voluntary, global standard for Environmental Management Systems.)

Cal/EPA is working together with U.S. EPA and the Metal Finishing Association of Southern California (MFASC) to test a template that small- to medium-sized metal finishing companies can use in developing and implementing an EMS that is based on ISO 14001. The MFEMS Template is intended to provide a simplified and industry-specific template that can form the basis for a company’s EMS, and that could, when implemented, serve as an initial step towards ISO 14001 certification.

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III. Unique EMS Characteristics

Unique aspects of this project include

• development of an industry-specific EMS template,
• focus on small and medium sized enterprises and how EMSs might help them,
• involvement with the industry association, and
• demonstration of a joint U.S. EPA and Cal/EPA pilot project.

Nine metal finishing companies, including Artistic, recently completed a series of workshops learning to develop and implement an MFEMS at their facilities. U.S. EPA sponsored these workshops for interested members of the Southern California Metal Finishing Strategic Goals Program (Strategic Goals Program). The Strategic Goals Program is a voluntary, multi-stakeholder program aimed at improving environmental performance, exceeding compliance, and reducing business and environmental costs at metal finishing facilities. At its core is a set of environmental performance goals for metal finishers and a set of "enabling actions" other stakeholders will undertake to help metal finishers achieve the goals. Members of the Strategic Goals Program include U.S. EPA, Cal/EPA, local regulatory agencies (i.e. water and air), metal finishing companies, the Metal Finishing Association of Southern California, academics, and non-governmental organizations.

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IV. Strategic Goals Program Goals

Improved Resource Utilization

• 98% metals utilization
• 50% reduction in water use
• 25% reduction in energy use

Reduced Hazardous Emissions

• 90% reduction in organic TRI emissions
• 50% reduction in metals emissions
• 50% reduction in hazardous sludge disposal
• Substantial reduction in sludge generation
• Reduced worker and community exposure

Increased Economic Payback & Decreased Compliance Costs

• Achieve long-term economic benefits
• 50% reduction in unnecessary costs through burden reduction with no loss in environmental performance

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V. EMS Overview

The materials Artistic shared included their environmental policy statement, the list of environmental aspects and impacts, their objectives and targets, and the costs and benefits of environmental improvements. The top five environmental aspects and impacts are perchloroethylene vapors from degreasing operations, chrome-containing wastewater from chrome plating, cyanide-containing wastewater from cyanide plating, liquid chlorine from cyanide wastewater reduction processes and nitric acid from stripping operations.

The top five objectives and targets identified are as follows:

1. Eliminate perchloroethylene usage in parts cleaning.
2. Reduce hexavalent chromium discharge to the wastewater treatment plant.
3. Decrease cyanide in wastewater discharge.
4. Reduce liquid chlorine usage.
5. Reduce nitric acid use.

Progress toward the top five objectives and targets is described below.

Perchloroethylene
Artistic discussed the progress made toward achieving objectives and targets. A significant change was the elimination of perchlorethylene usage and replacement with an ultrasonic aqueous immersion cleaning tank for parts cleaning. This yielded a decreased exposure risk, decreased air sampling costs, decreased risk to workers and decreased worker compensation insurance premiums, decreased medical and biological monitoring, decreased lab analysis and disposal costs, and decreased air quality district emission fees.

Hexavalent chromium
Artistic is working toward its target of decreasing hexavalent chromium discharge by 10% through several specific source reduction actions. Specifically, a new drip board was installed to reduce dragout, workers received dragout reduction training, and anodes were repositioned to achieve comparable plating at a lower chromium concentration.

Cyanide and liquid chlorine
The target to reduce cyanide discharge concentration to a level 50% lower than the permitted limit is progressing through source reduction actions, improved treatment and waste treatment. A third stage cyanide treatment unit was added, workers received dragout 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 significant reduction in the amount of liquid chlorine usage.

Nitric acid
The target to reduce nitric acid use by 95% is still in process. Material substitution alternatives are still under investigation. Nitric acid usage increased significantly due to introduction of a new plating line. Artistic installed a new aluminum plating line and one of the processes for plating aluminum requires dipping in a triacid solution made up of 70 percent nitric acid. Artistic believes that the target of reducing nitric use by 95% can be achieved in the next several months as many nitric acid substitute chemical technologies are becoming more available and yielding better results. Some of these newly developed technologies are presently being tested at Artistic. The actual results will be known in the time frame previously mentioned.

Progress toward other objectives and targets
Other objectives and targets include reductions in copper, sludge, and process water.

In order to ensure compliance, copper discharges to the local wastewater treatment plant were lowered by monitoring the wastewater treatment process more closely and fine-tuning the pre-treatment process.

Sludge volume has been indirectly reduced by the installation of conductivity sensors in the rinsing tanks. Dragout techniques have been put into practice and enforced more strictly. In addition, the overall wastewater process operations are monitored more consistently, and another operator was hired.

Efforts to reduce process water use through source reduction and in-process recycling are ongoing.

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VI. Costs and Benefits

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

Perchloroethylene
The estimated costs and benefits of eliminating perchloroethylene are as follows. The decreased air sampling costs saved $2,000 per year. Decreased medical and biological monitoring saved $1,500. The savings in the reduced need for testing and lab analysis is approximately $1,000 per year. Decreased disposal costs saved are $1,000 per year. The air quality management district factor emission fees saved $2,000 to $3,000 per year, based on quantity emitted. The value of decreased workers compensation insurance premiums cannot yet be determined, but the insurance company has committed to using a smaller factor in underwriting calculations.

Hexavalent chromium
Decreased chromium discharges to the local treatment plant ensured the elimination of potential discharge violations. Costs for increased water testing and lab analysis is $2,000 per year.

Cyanide and liquid chlorine
Cyanide discharges to the local treatment plant were decreased ensuring the elimination of potential discharge violations. Liquid chlorine usage was reduced, yielding $3,500 per month in cost savings. A reduction in other wastewater treatment materials saved $500 per month. Increased water testing and analysis costs an additional $4,500 per year. The addition of a third stage tank with mixer and controls cost $10,000.

Nitric acid
Nitric acid cost savings of $360 per day are realized through the reduction of plating rejects due to poor activation of substrate metal. Costs of nitric acid use come from treatment of the spent triacid (70% nitric acid) which totals $1,050 per week in additional costs. The added cost of caustic soda totals $450 per week.

Copper
Decreased copper discharges to the local treatment plant ensured the elimination of potential discharge violations. Costs for increased water testing and lab analysis is $2,000 per year.

Sludge
The decrease in sludge volume has meant 26,966 pounds less sludge generated per quarter. Saved disposal costs per quarter are $4,724. The reduced quantity of testing and lab analysis has led to $2,500 in savings. The hiring of an additional wastewater treatment operator costs $26,000 per year.

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Please contact Cal/EPA EMS Pilot Project Manager Tom Lanphar at (510) 540-3925, or by e-mail to tlanphar@dtsc.ca.gov, for more information about the Southern California Working Group.