United States
                           Environmental Protection
                           Agency
       Office of Water
       (WH-547)
EPA 832-F-93-006
September 1993
      4>EPA        Pollution  Prevention
                            Opportunity Checklists
  Case  Studies
PROGRAM DESCRIPTION
     The Industrial Waste Section of the County Sanitation
Districts of Los Angeles is responsible for implementing and
enforcing both local limits and federal pretreatment regulations.
The Industrial Waste Section has developed a series of 12
checklists for identifying pollution prevention (PP)
opportunities. Eleven checklists are industry-specific and
describe specific PP opportunities relevant to each industry. A
general checklist covers PP program elements that apply to a
broad industrial spectrum. The PP opportunities for the 11
industries fall into several categories, such as good operating
practices, material substitution, process modification, and
product reformulation. Inspectors, permit engineers, and
indirect dischargers use the checklists to encourage adoption of
PP techniques.  The Industrial Waste Section designed the
checklists to present information on pollution prevention
opportunities in a concise and easy to read format.  With the
help of the Industrial Waste Section, one metal manufacturing
shop reduced chromium concentrations in its wastewater by 86
percent.

PROGRAM OBJECTIVE
     The Districts' objective is to make the checklists an
integral part of their overall PP program, which has been in
existence since the Spring of 1989.

1.   Inspectors  use the checklists during visits to industrial
    facilities to identify PP opportunities.

2.   Permit engineers use the checklists during evaluation of
    discharge permit applications to ensure that facilities have
    considered PP opportunities.

3.   The Districts'personnel use the checklists as outreach
    material for industries to increase awareness of PP
    opportunities and to transfer PP information.

PROGRAM  ACCOMPLISHMENTS
     The Districts'first program accomplishment was the
development of industry-specific PP opportunity checklists for
11 industries:
1.  Oil and Gas Extraction
2.  Petroleum Refining
3.  Printing
4.  Metal Fabrication
5.  Metal Finishing
6.  Dry Cleaning
7.  Radiator Repair
8.  Photoprocessing
9.  Chemical Manufacturing
10. Printed Circuit Board Manufacturing
11. Chemical Formulating - Pesticides, Chemicals and
   Paints

     The checklists are written in a simple format that
identifies the actions a facility can take to reduce its waste or to
prevent pollution and explains why the identified actions should
work. A twelfth checklist, which is generic, is used to assess
facility awareness of PP and asks about tfie existence of other
related activities.
     The industry-specific checklists start by identifying the
key source(s) of waste generation for the specific industry as
well as the priority waste stream(s).  The checklists next list
opportunities in each  of several general PP categories (e.g.,
good operating practices, material substitution, process
modification, and product reformulation) and briefly describe
how to implement particular techniques. In short, the checklists
suggest what to do and how to do it
     The checklists have been a key component of the three-
stage development of the Districts' PP program.

Stage 1: Staff Education
     The first step was to educate and train inspectors and
permit engineers. Industrial Waste Section personnel developed
a basic training course that focuses on specific PP concepts and
regulations as well as their application to a variety of industries.
Instructors explain the purpose of the checklists. The Industrial
Waste Section provides additional training sessions in order for
staff to remain aware of regulatory trends and pertinent
legislation. The Industrial Waste Section also encourages staff
to attend outside training courses and technical sessions on
source reduction technologies.
                           ^^ Primed on Recycled Paper

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Staye 2: Outreach to Industry
     The checklists function as an outreach and educational
tool. The Industrial Waste Section sends checklists to
permittees upon request; to date, they have mailed over 200
checklists. Personnel from the Industrial Waste Section also
distribute the checklists at conventions and trade shows.
       : Permitting Requirements
     The Industrial Waste Section maintains over 9,000
industrial permits for discharge to the Districts' systems - each
permit applicant must perform a PP/waste minimization
assessment. Those industries not already subject to federal
waste minimization program certification requirements or state
source reduction reporting or planning requirements can meet
the PP requirements of the Districts' industrial permit by
completing the general PP program checklist
FOR MORE INFORMATION
     To receive a copy of the checklists or an update, on
the PP program, contact Theresa Dodge at (310) 699-7411
extension 2456; FAX (310) 692-5103 or write to:

        Project Engineer for Pollution Prevention
              Industrial Waste Section,
    County Sanitation Districts of Los Angeles County
                  P.O. Box 4998
          ' Whittier, California 90607-4998
For additional information about the MWPP Program, contact the U.S. EPA Office of Wastewater Enforcement and\
Compliance, (202) 260-5856.

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