Clean and Simple: EPA ‘Model Shop Program’

When the California Department of Toxic Substances Control saw the data on the state’s plating industry and hazardous waste, it knew it had to do something.

While there are only about 900 chrome plating shops left in California that conduct electro-plating -- including shops where electro-plating is a primary and secondary activity – the industry sector was the second highest hazardous waste generator in California, producing nearly 70,000 tons of hazardous waste per year. Only the petroleum refining industry produced more hazardous waste in the state.

Enter the DTSC’s ‘Metal Finishing Model Shop Program,’ a unique voluntary pollution prevention program designed to help a metal finishing business run a cleaner and safer shop.

The program assists metal finishing businesses in identifying possible sources of pollution in their plants, and to develop ways to reduce the hazardous waste. The goals are to help finishers:

Eliminate or reduce waste generation.
Conserve energy and water.
Reduce operating costs.
Increase compliance with environmental regulations.
Improve employee health and safety.
Be environmentally responsible.
Receive recognition for their pollution prevention efforts.

Two California shops have completed the program, and both say the process has made them a better operation.

“We have always had a very clean, efficient shop,” says Bryan Leiker, director of marketing and sales at K&L Anodizing, a Burbank metal finishing company started by his grandfather in n1950.

“Going through the Model Shop program has been a good experience for K&L and its employees. We are proud to have been the first Model Shop, and we know our customers value that we keep such a clean and environmentally-friendly facility,” says Leiker, who also serves as vice president of the Metal Finishing Association of Southern California.

The program was started in southern California by the Cal/EPA Department of Toxic Substances Control, the Metal Finishing Association of Southern California, and the communities of Los Angeles, Burbank, Orange County and Los Angeles County.

The program has since expanded to northern California and is sponsored by DTSC, the Metal Finishing Association of Northern California and state and local environmental regulatory agencies.

To be eligible to participate for the program, a finishing business must be free of any pending enforcement action from any local or state agency, fulfilled all terms of any prior enforcement actions taken against the business, and undergone corrective action and is in good standing with their consent agreement.

Shops that participate in the program can receive at no cost:

An on-site pollution prevention assessment with recommendations on how to improve pollution prevention efforts.
Compliance assistance with pretreatment discharge requirements and help understanding hazardous waste generator requirements.
Training in pollution prevention and hazardous waste management for employees.
Opportunity to apply for the ‘Metal Plating Facility Loan Guarantee Program’ offered by the state to obtain a loan guarantee to upgrade, replace or purchase new equipment to implement pollution prevention measures.

Jan Phillips, K&L’s general manager, says the Model Shop program has been cost-effective for them in addition to providing continual environmental compliance.

“We feel we exceed the industry standards, and we are always ready for any inspection such as the EPA, the AQMD, DTSC and all other local agencies,” she says. “Having a clean and safe working environment is among our highest priorities.”

A company which is currently under a pending enforcement may participate on a case by case basis as a condition of a settlement agreement, says Evelina Rayas, a Senior Hazardous Substances Scientist with the DTSC.

The DTSC conducts a review of the application for completeness and researches the compliance history of the business. The DTSC also coordinates internally with its various programs, as well as externally with the various local agencies, such as the U.S. EPA, sanitation districts, and others.

Rayas says the DTSC then schedules a site visit to meet with the business and assist them in the completion of the P2 self assessment. They provide P2 recommendations and discusses with the businesses any observations or concerns.

DTSC then provides training to the finishing business and its employees before an assessment team comes in to verify that the business has meet the criteria established by the program, and that it is in compliance with all regulations. A business must score at least 150 out of a possible 200 points to be certified.

Finishers that meet the criteria and pass the assessment will be recognized by the DTSC and the local communities and organizations for their achievements, including a ceremony at city halls, regional boards and in the local media.

Sheffield Platers in San Diego also went through the Model Shop program, and says that not only has it reduced the amount of time they now spend monitoring environmental issues, the company employees feel better about having a ‘green’ workplace.

“As president and environmental officer, I spend 30% of my valuable time managing environmental and safety issues,” says Dale Watkins of Sheffield Platers. “Why ? Because the nature of metal finishing businesses require a substantial commitment from the ownership to comply with the myriad of overlapping regulations.”

Watkins sits on the board of directors for the Industrial Environmental Association. Sheffield is a member of the Environmental Alliance program, and in the past decade the company has received recognition and many awards for their environmental achievements: the Earth Day award, Small Business of the Year Award, Family Business of the Year Award, certificate of recognition from Senator Barbara Boxer for environment achievements, certificate of recognition from Senator Steve Peace, a certificate of merit in recognition of ‘Outstanding Achievement in Industrial Waste Water Control and Pollution Prevention’ and a Proclamation from the Mayor of San Diego for their commitment to the environment.

Watkins said he signed up for the Model Shop program to help reduce the time he spent getting ready for the on-going inspections.

“My goal at Sheffield Platers is sustainable compliance of our environmental and safety compliance programs,” Watkins says. “My desired result is to have a family business sustaining environmental compliance for generations to come.”

The DTSC says the Model Shop Program uses P2 source reduction strategies to use materials that are less toxic and easier to manage. For example, the strategy includes using the least VOC-containing, longest lasting, most effective cleaning systems, as well as substituting least toxic and hazardous plating chemistries where possible, such as non-cyanide silver.

The program also tries to extend the life of process baths to the maximum extent possible in order to save resources such as water and energy. To do so, the DTSC suggests changes to equipment, such as using rinse tank sensors to minimize use of water, optimizing tank and equipment layout, and minimizing drag-out.

They also recommend optimizing production to help reduce or eliminate rejects and re-work since they often require 2-3 times the materials, waste, and energy to strip and reprocess.

With approximately 100 employees, K&L Anodizing completely modernized their entire shop several years ago after a fire in the plant. Leiker says one of the biggest challenges a company might have in going through the Model Shop program is getting buy-in from employees to get behind the process, but he says that was not a problem at his facility.

“One of the things about our employees is we have very few that haven’t been here 15 or more years,” he says. “We don’t have a lot of turnover at K&L, we are one big family and every employee plays an important role in making K&L Anodizing a model shop everyday.”

The DTSC says the best way to reduce pollution is preventive maintenance on process machinery and equipment. They suggest finishers check pumps and filters; schedule calibration of automated controls and monitors (for example, temperature, pH, conductivity); check racks, drip guards, rinsing equipment; routinely inspect process and waste tanks and piping for leaks, degradation, and corrosion; and to use an in-house system so everyone knows what has been done and needs to be done, and post it on a large board, clearly visible to everyone in the shop.

K&L’s Phillips says they have a team dedicated to maintenance of equipment and cleaning the facility on a daily basis.

The DTSC encourages plants to adopt a ‘dry floor policy,’ whereby clean-ups are done immediately so that everyone can see if an incident is occurring more quickly. Shops then work to eliminate waste from drag-out dripping, tank spillage and rinse overspray, thereby making leaks more detectable.

The DTSC also encourages finishers to follow the “Lean 6S” philosophy to maintaining a clean environment:

Sort: eliminate clutter, sort out what is not needed.
Set in Order: organize and label, set boundaries and limits.
Shine: clean everything and solve.
Safety: create a safe place to work.
Standardize: keep checklists and standards to maintain the first 3 Ss.
Sustain: maintain discipline through systems and a supportive culture.

Aside from pollution controls, the Model Shop program also looks at ways for finishers to reduce their amount of resources, such as water, waste and energy. Water usage can be reduced by working on drag-out issues, as well as using more effective rinsing operations. Doing so also eliminates the amount of sludge and sewer costs.

The DTSC even goes as far as encouraging the capture of storm water run-off for treatment for process water use, in addition to using ion exchangers and reverse osmosis to recycle water.

That is something K&L invested in and has seen big dividends, incorporating an ion exchange system and becoming a “zero discharge facility.” Before they discharged 25,000 gallons daily, but today that number is zero. K&L also installed additional skylights and energy-efficient lighting.

“The process still has its costs,” Phillips says. “It takes a committed team effort to keep it running efficiently.”

The program advises that shops conduct an energy audit, where they will often see that switching to a different type of light (or even natural light) will reduce consumption since lighting a facility typically takes up 20% of the overall energy costs.

Other ideas include replacing conventional motors with high efficiency motors at end of life, checking compressor hoses and pumps, considering the use of solar, and looking for rebates and incentives from utility companies that may cover part of installation costs.