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HomeMy WebLinkAboutMINUTES - 02091993 - EP.1 TO: BOARD OF SUPERVISORS FROM: ECONOMIC PROGRESS COMMITTEE DATE: FEBRUARY 9, 1993 SUBJECT: UPDATE ON ECONOMIC PROGRESS COMMITTEE ACTIONS SPECIFIC REQUEST(S)OR RECOMMENDATIONS)&BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: 1. ACCEPT the report from the Economic Progress Committee, and 2. DIRECT staff from GMEDA to continue meeting with Industrial Task Force representatives to identify issues and prepare for Economic Summit, and 3. DIRECT GMEDA staff. and CAO to select the optimum date for the Economic Summit. FISCAL IMPACT: Some contribution of staff time. BACKGROUND/REASONS FOR RECOMMENDATIONS: Last year, Supervisor Torlakson introduced the Contra Costa Works Plan. The initial proposal has evolved and expanded, however, its primary cornerstone remained unshaken -- the need for jobs, particularly from Contra Costa heavy industry. This issue was expanded in the Board's September 22, 1992 Resolution introduced by Supervisor Powers, "Encouraging Growth and Development in Contra Costa County." (continued on page 2) CONTINUED ON ATTACHMENT. YES SIGNATURE: _RECOMMENDATION OF COUNTY ADMINISTRATOR —RECOMMENDATION OF BOARD COMMITTEE APPROVE OTHER A N F BOARD a APPROVED AS RECOMMENDED X OTI-IER X See Addendum A for additional Board actions VOTE OF SUPERVISORS I HEREBY C.TERTIFY THAT TI ILS IS A TRUE AND CORRECT COPY OF AN ACTION TAKEN AND X UNANIMOUS(ABSENT ) ENTERED ON 111E MINUTES OF THE BOARD OF SUPERVISORS ON 1IIE DATE SHOWN. AYES: NOES: ATTESTED February 9 , 1993 ABSENT: ABSTAIN: PHIL BATCHELOR,CLERK OF THE BOARD OF SUPT�SORST CO 1 ADMINISIRAT]OR 0 { BY ,DEPU1'Y VA-dg econprog.bo Contact: Val Alcxeeff(646-1620) Cc: County Administrator County Counsel GMEDA Departments Economic Progress Committee February 9, 1993 Page 2 BACKGROUND/REASONS FOR RECOMMENDATIONS (continued): On January 12, 1993, a presentation was made by the Industry Task Force of the Contra Costa Council which reminded the County of some of the benefits that heavy industry can be counted upon: To provide high paying jobs To establish a large and constant tax base To create a strong multiplier for local for goods and services To contribute resources to the community To generate citizen interest and volunteer ethic in community affairs The Task Force outlined five actions: 1. Establish meetings between industry, business, and government. 2. Establish a working group to review existing regulations and make recommendations. 3. Request Board convene a task force representing industrial, labor, environmental, and community interests. 4. Set process to evaluate impact of regulations. 5. Send message to emphasize review of new regulations to determine if another agency is already responding to issue. On January 12, the Board directed staff to meet with industry to identify the concerns of industry, to set up a process to review regulations and fees, to consider strategies for retention and expansion of industry, to coordinate industrial issues with those of labor, environment, small businesses, and neighborhood groups, and to include industrial participation in an Economic Summit. As a follow up, staff from GMEDA met with a committee of the Contra Costa Council's Industry Task Force to discuss future efforts. Three subcommittees of the Council's Industry Task Force were identified: 1. To study issues common to the County and to industry 2. To work on a process to incorporate concerns of labor, environment, small business, and neighborhoods in the process of industrial growth 3. To participate in the upcoming Economic Summit Issues Formation J The Council's Industry Task Force subcommittees will follow a ninety-day Process to identify issues in common with the County. The County will respond to issues and a program involving labor, environment, small business, and neighborhoods groups will be created to resolve issues. Integration of Concerns with Affected Groups Staff will work through the Economic Summit process to identify groups, issues, and forums for resolution of issues. Economic Summit A. Date needs to beset. B. Issues need to be selected. C. An outreach effort needs to be make to include a broad identification of issues. D. A follow up process should be established. As those issues evolve, periodic updates will be provided by the Economic Progress i Committee. i ADDENDUM A TO FEBRUARY 9, 1993 BOARD ORDER REPORT FROM THE ECONOMIC PROGRESS COMMITTEE ADDITIONAL ACTIONS: 1. Chair and GMEDA staff to work with all Board members in setting individual District forums to assist in setting an agenda for the Economic Summit. 2. Chair to work with one other Board member as a subcommittee of the Economic Progress Committee to collate all information from District forums and committee meetings to set an agenda and define precise goals, speakers, etc. 3. Direct GMEDA staff to work on establishment of a broad-based County-sponsored Industry Task Force and provide the Economic Progress Committee with a recommendation regarding membership on such a Task Force within sixty days. 4. Direct GMEDA staff to develop a preferred form of the phrase "ContraCostaWORKS" that would be used consistently in the future. 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"It v mental compliance division of reduce the sources of copper and cost something. But we hop( the city's Public Works Depart- nickel that end up in the Bay, will be offset by savings from It will not be too ment. "It builds into itself a dispute- ducing water use and from ZU to SWcl„11ow� The result was that the Palo resolution process," Calonne ducing the cost of waste h ll Alto wastewater plant would said. "We all agreed that the en idling and disposal." have to reduce its copper and vironment is not getting any The proposal also calls ONTINUED FROM A-1 nickel levels by as much as 85 percent to comply with the new cleaner if we waste time in front continued public education p dtos,Los Altos Hills, East Palo regulations, Calonne said. of the regulatory board or the grams to reduce metal discha pito and Stanford University. courts." es from residents dump'.. City officials said there was no P The environmental groups cost-effective way to comply, A key part of the proposal is chemicals into the sewer or laimed the wastewater levels of Prompting the environmental- that cities would audit business- ing copper-based root killers. opper and nickel, which are ists to threaten a lawsuit to en- es and other institutions that re- The city would bear indin )xic to aquatic organisms,were force the new regulations. The lease the metals and determine costs for consultants to au. greatening the South Bay wet Proposed settlement ends more reasonably affordable ways the businesses and for public edu, aids ecosystem.The South Bay than a year of negotiations be- businesses could reduce their tion campaigns, Bobel sa retlands are particularly vul- tween the city and environmen- discharge levels. Much of the expenses•alrea :erable because there is little talists. The proposal defines afford- have been budgeted for t] idal flushing there. The environmentalists also able based on the prevailing in- year,he said. In April 1991, the California threatened to sue Sunnyvale terest rate with an assumed pay- Davila Circuits Inc. Genei egional Water Quality Control and San Jose, the locations of back of five years. Manager Bob Davila said t oard severely tightened waste- the South Bay's other two waste ater restrictions on copper and water treatment plants, over After a 20 month audit period, proposed settlement is a mi ckel. similar violations. Those cities the city then would adopt copper stone in the relationship I The board revised the copper are not involved in the proposed and nickel limits based upon the tween cities and businesses. settlement, Calonne said. maximum feasible reduction "Before it was cities again - -iit from 30 parts per billion to g 9 parts per billion and the nick- tinder the settlement terms, levels. businesses," Davila said. "No, limit from 24 parts per billion the environmentalists agree not "The bottom line to business- it's cities working with bu: 3.3 parts per billion,said Phil to sue the city for five years if es is that it will not be too hard nesses to stay in compliance." 14-4'!. CLEAN SAFE JOBS J The benefits of toxic pollution prevention and industrial efficiency to the communities of South San Francisco Bay. A preliminary report. CITIZENS FOR A BETTER ENVIRONMENT August 1992 Author Greg Karras, Director Clean Bays and Coastal Waters Program Cover Design Sandra Murray Research Guidance, Mike Belliveau, Executive Director , Editorial Support Alan Ramo, Legal Director and Analysis Nora Chorover, Staff Attorney Hannah Creighton, Development Associate Denny Larson, Campaign Coordinator Julia May, Director, Clean Air Program, Northern California Region Margaret Williams, Financial Director Michelle Ozen, Office Director, San Francisco Citizens for a Better Environment (CBE) is a statewide public interest organization that uses technical research, policy advocacy, legal action, grassroots organizing, and public education to prevent pollution hazards and achieve healthy, sustainable urban communities. 501 Second Street, Suite 305 122 Lincoln Blvd.,Suite 201 15 Shattuck Square • San Francisco,CA 94107 Venice,CA 90291 Berkeley, CA 94704 415/243-8373 310/450-5192 510/841-6163 CLEAN SAFE JOBS A CBE REPORT Acknowledgements This report was made possible by the assistance of many individuals and organizations who have contributed to Citizens for a Better Environment's San Francisco Bay Protection Campaign. We are deeply grateful for your support. The research, analysis, and production of this report were made possible by contributions from the Mary A. Crocker Trust, Compton Foundation, The Pew Charitable Trusts, The San Francisco Foundation, The Wallace Alexander Gerbode Foundation, Richard and Rhoda Goldman Fund, The Tides Foundation, The Gap Foundation, and REI. s Many talented people lent their time and expertise to help plan the analysis and answer key technical or economic questions. Special thanks to Dave Kerschner, Patricia Mulvey, Pamela D. Adams, Patrick Burt, John Rosenblum, Tom Adams, Lenny Seigel, and Rick Sawyer. Sandra Murray generously offered needed design advice, draft designs, and cover graphics. Much of the analysis was built directly and indirectly on the data management and programming work of Joanne Marlowe and Steven . Obrebski. This research was also made possible by the members of Citizens for a Better Environment. Thank you all! ii CLEAN SAFE JOBS A CBE REPORT CONTENTS Executive summary ... iv Introduction: Wildlife Refuge or industrial dump site? 1 • The environmental setting. ... 1 • Industrial sewer pollution is one of three key causes of severe ... 2 toxic pollution in the southern reach of San Francisco Bay. • Industrial pollution prevention for the toxic pollutants ... 4 copper and nickel: A case study in progress. Industrial waste, industrial efficiency, and industrial investment. ... 6 • A small proportion of the electronics industry causes most of the industrial copper and nickel pollution in the South Bay. ... 6 • Individual firms in polluting sectors reaped economic benefits through increased industrial efficiency that greatly reduced toxic waste releases to sewers. 8 • The costs and benefits of increased efficiency/reduced waste can be broadly estimated for industry and environment, and techniques exist to predict specific costs and pay backs for individual shops. ... 13 • Many wealthier firms can afford to, but have not, financed increased industrial efficiency/reduced waste improvements. ... 16 • Environmental investments that increase the industrial efficiency of smaller firms supplying local high tech "building blocks" will retain jobs and increase competitiveness. ... 18 A four-point technical and financial assistance proposal to prevent pollution and retain jobs in South San Francisco Bay. ... 21 Literature cited. ... 22 iii i CLEAN SAFE JOBS A CBE REPORT 16,000 >`"<> Three quarters of the waste of key : >>k Total pounds industrial materials poisoning San of industrial Francisco Bay can be eliminated by nickel (grey) economically favorable and improvements at the 100 industrial copper(black) facilities that waste the most copper released to 8,000 and nickel down the drain. (a) - Silicon Valley's biggest Future totals if proven waste reductions are done sewage plant ii :%i::;:.:.... m 1991 ::r K;..?»;:;:;;<::..•::: 0 100 200 300 Number of facilities adopting all feasible waste reductions Estimated number of jobs at the 100 industrial-facilities that would realize the greatest benefits through increased industrial efficiency and reduced process waste. (b) 40000 35000 30000 .. 25000 20000 15000 10000 5000 0 Electronics Other Printed circuits Q Metal finishingLA Semiconductors ® Other J (a) Based on waste reduction levels that have been demonstrated by industry and t San Jose/Santa Clara Water Pollution Control Dept. pretreatment records. (b) Based on published business information. Business information systems Inc., 1990; Database publishing Co., 1992; and Gale Research Inc., 1992. CLEAN SAFE JOBS A CBE REPORT Executive summary This preliminary investigation shows that investments in pollution prevention in Silicon Valley's electronics industry could help retain thousands of jobs, create more jobs, increase competitiveness, and significantly reduce the severe toxic pollution of San Francisco Bay. It reports on a case study in progress in Santa Clara County, California, where a small portion of the electronics industry is the biggest industrial cause of the ongoing poisoning of the San Francisco Bay National Wildlife Refuge. It demonstrates that the industry as a whole can cut these wastes by 75% to 90% through improved industrial efficiency that would save the polluting firms money. It pinpoints the failure to enforce environmental protection, and failure to invest in community industry, that now block these industrial efficiency/reduced waste improvements. The report sets forth a four-point technical assistance program that would, if implemented, prevent toxic pollution and retain local jobs: • 1. Fund pollution prevention audits and business plans that recommend the best process changes to eliminate waste water pollution at the source. • 2. Provide technical experts to help assure that the pollution prevention plans are successfully carried out. • 3. Help smaller firms finance their pollution prevention plans through loan guarantees, buy down of interest rates, or other actions. • 4. Ensure worker retraining and involvement in industrial efficiency/waste reduction improvements. This program can help most by cutting high levels of waste at fifty metal finishing and printed.,circuit board shops in ways that increase efficiency and help to retain the 5,000 jobs in these shops. Those most helped will be small and mid-sized businesses in key manufacturing sectors that play an important role in the economic health, competitiveness, and retention of wealthier parts of the electronics industry. With adequate environmental law enforcement, this "clean safe jobs" proposal could help stop severe losses of San Francisco Bay resources and Silicon Valley manufacturing jobs. California's private industry wasted 31.9 million pounds of toxic chemicals down the drain into publicly owned sewers in 1990, fully thirty-five percent more than their 23.6 million pounds in 1989. (Toxic Chemical Release Inventory, 1992) This waste disposal through public sewer systems costs our communities in lost resources, and sewage treatment plants cannot neutralize it. We need to stop subsidizing industrial waste, and start investing in industrial efficiency for our health, environment, and jobs. iv. The San Francisco Bay/Delta, its National Wildlife Refuge, and the area causing the largest effluent discharge south of Oakland and San Francisco. Oakland San Francisco ® San Francisco Bay National Wildlife Refuge ■ Collection area for the San Jose/Santa Clara Water Pollution Control Plant Introduction: Wildlife Refuge or Industrial Dump Site? • The environmental setting. The southern reach of the San Francisco Bay/Delta estuary stretches south from the San Francisco/Oakland Bay Bridge, and is also called San Francisco Bay, the Lower Bay, and the South Bay. Some of the physical features of the estuary are roughly mapped on the facing page. The southern reach receives only ten percent of total river flow into the estuary (Smith, 1987), but its catchment contains Silicon Valley, and the largest concentration of industrial waste discharges to public sewers in the estuary. (CBE, 1989) Reduced water circulation in the southern reach that is caused by river water diversions from the Delta further worsens the locally-caused pollution here. (Flegal et al., 1991; Luoma et al., 1985; Davis et al., 1991; and Belliveau and Grove, 1987) The map also shows the approximate location of the San Francisco Bay National Wildlife Refuge in the southern reach. The officially designated "beneficial uses" of water in the Bay's southern reach include navigation, recreation in and on the water, commercial and sport fishing, wildlife habitat, preservation of rare and endangered species, fish migration, shellfish harvesting, and estuarine habitat. (San Francisco Bay Basin Plan, 1987) In addition to the Refuge, the southern reach of the Bay is part of a "National Priority Estuary" under Section 320 of the Federal Clean Water Act. It is an important stopover for birds migrating along the Pacific Flyway. It includes the largest harbor seal haul-out and pupping area in the Bay, and part of one of the Bay's last remaining commercial fisheries, trawling for bay shrimp. Unfortunately, a number of negative impacts including pollution, wetlands destruction, and water diversions have greatly reduced the abundance of many populations of Bay species in recent years. Several species are threatened with extinction. At least one endangered bird species, the California Clapper Rail, depends on the southern reach for its survival. (Herbold et al., 1992; Lonzarich et al., in press) _ Finally, the map outlines the areas of Santa Clara County that discharge wastes to the Bay through the San Jose/Santa Clara sewage system. This collection, treatment, and discharge system is owned by the cities of San Jose and Santa Clara and services three quarters of Silicon Valley's industrial waste water discharges (CBE, 1989), and accepts wastes from water supply and other services for more than a million people who live in its collection area (Dept. of Finance, 1989). Despite advanced treatment of degradable pollutants, the San Jose/Santa Clara plant causes the largest release of non-degradable toxic pollutants in the SouthrBay. I I I CLEAN SAFE JOBS A CBE REPORT c • Industrial sewer pollution is one of three key causes of severe toxic pollution in the southern reach of San Francisco Bay. Sewage plant effluents and urban storm runoff are the major sources of copper, nickel, mercury, selenium, and other toxic pollutants in the South Bay, according to the U.S. Environmental Protection Agency and the California Water Resources Control Board. (EPA, 1990; and SWRCB, 1990) Sewage effluents and local runoff pollution cause elevated concentrations of copper, nickel, cadmium, and other pollutants throughout the southern reach of the Bay. (Flegal et al., 1991) The pollutant concentration gradients extend to approximately the San Francisco/Oakland Bay Bridge, with the greatest concentrations near the effluent discharges from Santa Clara County, the heart of California's industrialized Silicon Valley. (Ibid.) There are three major known causes of this toxic pollution of sewage and storm runoff: manufacturing and "commercial" industrial facilities; the water supply industry's pesticide use and corrosion of its piping; and transportation system pollution of urban storm runoff. In the past, discharger representatives insisted that industrial pollution was small compared to other causes, but that may be changing. Discharger estimates of copper and nickel discharges to the San Jose/Santa Clara plant are shown on the facing page. (EOA Inc., 1991) As can be seen, the dischargers now agree that industry and water supply are the two largest causes of these pollutants in sewage effluents. CBE believes that the discharger "maximum water supply" estimates shown here still overestimate the amount of water supply pollution by about three times, and thus down play the relative importance of industrial pollution. (CLEAN South Bay, 1992) Nevertheless, even these discharger estimates show they will need to reduce industrial sewer pollution as well as water supply pollution to best halt sewage poisoning of the Bay. Most of the pounds of those toxics that can be adequately traced in South Bay runoff come from gasoline,combustion, engine emissions, vehicle leaks and wear, and the washing of these emissions from streets and other surfaces by storm runoff. Industrial runoff pollution is significant, but causes less total pounds of toxics to enter local runoff than transportation. (CBE, 1991) In dry years, local runoff pollution causes a significant portion of the total toxic discharge, but more copper, nickel, and other pollutants enter the South Bay from sewage plants than runoff. (Woodward-Clyde, 1990) Some studies predict runoff pollution will exceed sewage plant pollution in wetter rainfall years (Ibid.), but these predictions are questionable because pollutant concentrations were not measured in wet-year runoff, and may be reduced when there is ten times more runoff or more. (SWRCB, 1990) 2 Discharger consultant estimates of the causes of copper and nickel releases through the San Jose/Santa Clara sewage treatment plant (by relative mass). Copper (maximum water supply estimate) Other potential sources (unidentified) Regulated industry Regulated commercial industry Household products and wastes /Water supply & corrosion Copper (minimum water supply estimate) Water supply & corrosion `'° j/ Household products and wastes Regulated commercial industry h Ot ar potential sources (unidentified) �< >«`I' >l>>: Regulated industry Infiltration and septage Nickel (maximum water supply estimate) Other potential sources (unidentified) Infiltration and septage j/ Water supply & corrosion Regulated industry ;:.. <<V:r Household products and wastes Regulated commercial industry Nickel (minimum water supply estimate) Other potential sources (unidentified) Water supply & corrosion Household products and wastes ` � Regulated commercial industry .. < 1 v> Infiltration and septage Regulated industry Source: EOA Inc., 1991. Investigation of Un-permitted sources of nickel and copper in Santa Clara/San Jose WPCP Influent. Prepared for: City of San Jose. See Table 2. 3 I i CLEAN SAFE JOBS A CBE REPORT The EPA and State Board have found that toxic pollution threatens or impairs beneficial uses of water in South San Francisco Bay, in violation of the requirements of the Federal Clean Water Act. (EPA, 1990; SWRCB, 1990) Overwhelming evidence points to a severe toxic pollution problem. Concentrations of copper, nickel, and six other toxic chemicals in South Bay waters violated EPA criteria for the protection of aquatic life. (SWRCB, 1990) State Health Warnings say "no one should eat more than four meals a month of any striped bass" or "more than 4 oz. ... of greater scaup meat" from the area because of elevated mercury and selenium levels in these food resources. (Cal. Fishing Reg.; and Cal. Hunting Reg.) Further: "Women who are pregnant or may soon become pregnant, nursing mothers," and children should not eat any of these fish or ducks from the Bay. (Ibid.) South Bay selenium levels in ducks "were similar to those in livers of dabbling ducks in the nearby San Joaquin Valley where reproduction was impaired severely." (Ohlendorf et al., 1986) "Mercury concentrations in [California Clapper Rail eggs were] ... similar to levels associated with reproductive effects..." (Lonzarich et al., in press) The blood of Bay harbor seals contains copper and selenium at concentrations significantly greater than those of seals from other waters. (Kopec et al., 1991) Cadmium and copper were linked to a disease epidemic that led to a crash in the South Bay shrimp fishery in 1985. (SWRCB, 1990) South Bay shellfish that accumulated copper, silver, and cadmium to extremely elevated concentrations in their tissues were negatively impacted by toxicity. (SWRCB, 1990) This is important because "grazing by benthic invertebrates may limit phytoplankton biomass in South Bay. If so, damage to the benthic community through an increase in contaminant stress could have widespread impacts on the entire biological community of the Bay." (Luoma and Cloern, 1982) Indeed, copper and other toxics reach levels that may explain the elimination of dinoflagellate plants from the South Bay ecosystem. (Kuwabara et al., 1989) For more details of toxics threats see SWRCB, 1990; and CBE, 1992. • Industrial pollution prevention for the toxic pollutants copper and nickel: A case study in progress. This study explores a win-win solution to the conflict over whether San Francisco Bay will be a healthy ecosystem or a toxic dump site. It addresses the San Jose/Santa Clara discharge because it is the biggest source of pollution, as shown on the facing page. It explores acceptable solutions to ongoing pollution violations for the toxic pollutants copper and nickel. (also shown) Despite its environmental policies in other areas, San Jose has failed to enforce industrial clean up (EPA, 1991), and has sued the State of California to weaken toxics standards for the Bay (San Jose v. State Water Resources Control Board), citing fears of economic harm and job losses. To address these concerns, the study focuses on the economic effects of industrial pollution prevention. 4 CLEAN SAFE JOBS A CBE REPORT Pie charts comparing the proportion of nickel and copper discharged to San Francisco Bay by South Bay sewage treatment plants. Nickel mass emissions Copper mass emissions Palo Alto Sunnyvale 160 Ib/yr Sunnyvale 180 Ib/yr 310lb/yr Palo Alto b/ 680 I r :{,Y.{i,{.-v:L'%.:r{i. :4>i::Vi•,»:r:{{i:n''•ii::)^' >.'•:C t:Y!'•::ii::!tiS:: r.. '":2:;XTw:A�%i.Y\i':�iitij£}:4 N:•ij::::i�.i' :::;C+:i:';'.v'�:?::�i;i:i:::0{ji:yy ::j:?:i' :.v::::•.Jn:vn:••:>.:v..v.v:::• San Jose/Santa Clara San Jose/Santa Clara 2,990 1 Ib/Y10 lb/yr 2 I Y Scattergram plot of San Jose/Santa Clara effluent measurements showing nickel concentrations that violate the plant's 8.3 ug/I effluent limit and copper concentrations that violate the 2.9 ugA limit. 20 Nickel: • ,Copper: o • 15 Vertical axis: • • • • • ' •• •• • o • • • • • • San Jose/Santa Clara 10 effluent concentration � a • • + 090 0 0© 0 �• ®0 0 0 mom • •• 0 0 9CODO 00 4D in micrograms per o 0® ® 00 • 0 00 0 000 ® • liter (ug/1). 5 0 0 • o• 00. 000 00 ®• o CM am 0 Weekly measurements from April 1991 through June 1992. Source: All data from discharger self monitoring reports to the California Regional Water Quality Control Board, Oakland, Calif. Pie charts based on approximately 150 weekly effluent measures from January through June 1992. Scattergram shows approximately 180 weekly measures from April 1991 through June 1992. Effluent limits from NPDES permit CA0037842. 5 I CLEAN SAFE .JOBS A CBE REPORT Industrial waste, industrial efficiency, and industrial investment. • A small portion of the electronics industry causes most of the industrial copper and nickel pollution in the South Bay. The stacked bar charts on the facing page show the contributions of each monitored industrial facility and the total release of industrial copper and nickel to the San Jose/Santa Clara sewage treatment plant. Each bar starts with the largest discharge at the bottom of the stack, followed by the next largest, and so on. The first baron the left of each chart shows the subtotal for the ten largest industrial discharges. The middle bars show the subtotal for the fifty largest industrial discharges. The bars on the far right show the total discharges from approximately 350 industrial facilities -- the total number monitored and regulated under this plant's pretreatment programa Copper and nickel are shown separately because the biggest dischargers of one pollutant are sometimes, but not always, the biggest dischargers of the other pollutant. These measurements show that.a large proportion of industrial sewer pollution comes from only a few industrial facilities. The ten industrial facilities that released the most pounds of copper caused nearly half of all copper discharges from all 350 facilities. The ten biggest nickel discharges also caused nearly half of all 350 nickel discharges. The fifty biggest discharges of copper caused 85% of total industrial copper; the fifty biggest nickel discharges caused 84% of total industrial nickel. For both copper and nickel, less than 15% of the firms caused more than 80% of industrial sewer pollution. Further, these trends appear consistent among different toxic chemicals, different areas, and different years. Most of the industrial chromium, copper, lead, nickel, silver, and zinc wastes released to Santa Clara County sewers in 1987 and 1988, and released.to Los Angeles sewers in 1988 and 1989, also came from less than ten percent of industry. (CBE, 1990) For readers familiar with the Toxic Chemical Release Inventory (TRI) database required by federal Superfund legislation, it is important to note that these estimates are based on a different database that is more reliable for measuring industrial toxic metals releases to sewage treatment than the TRI database. The data presented here are from pollutant and flow measurements of each individual facility's effluent discharge connection to the public sewer system that are collected for all industry regulated by the "pretreatment program"of the federal Clean Water Act. (San Jose, 1992) In contrast to the very limited industry self-estimates typical of the TRI, this database includes measurements of more industrial facilities,and each pollutant measurement is based on standardized chemical analyses that are reliable enough for use in-enforcement of pretreatment standards intended to restrict pollutant discharges. In general, these data support very accurate estimates of copper and nickel releases and trends for groups of facilities. The data and methods of analysis are discussed further in CBE (1990). 6 CLEAN SAFE JOBS A CBE REPORT For the toxic pollutants copper and nickel, a small proportion of industry (only 50 of 350 facilities) causes more than eighty percent of the industrial pollution of San Jose/Santa Clara effluent. 12000 Copper: (8,690 lb/yr) (10,180 Ib/yr) .. 10000 8000 (4,960 lb/yr) 6000 4000 2000 Biggest 10 discharges Biggest 50 discharges All 350 6000 Nickel: (5,24o Ib yr (4,390 lb/yr) 5000 4000 (2,560 Ib/yr) 3000 .2000 >> 1000 0 Biggest 10 discharges Biggest 50 discharges All 350 Source: All data from "pretreatment program" measurements of pollutant chemistry and flow at individual industrial facility connections to public sewers. City of San Jose, March 25, 1992. Also see CBE, 1989; and CBE, 1990. Analysis by CBE. 7 I CLEAN SAFE JOBS A CBE REPORT Most of the big dischargers that cause more than 80% of industrial copper and nickel pollution are in Silicon Valley's electronics industry. The pie charts on the facing page show the breakdowns: For copper, almost half the fifty biggest dischargers manufacture printed circuit boards, more than 20% are Silicon Valley metal platers and finishers (metal finishers), and 20% manufacture semiconductors. For nickel, more than a third of the fifty biggest dischargers are metal finishers, more than a third make semiconductors, and 15% make printed circuit boards. The smaller "other" category includes diverse activities such as paperboard production, industrial laundering, and medical industries. This industry profile has important implications for our environment and economy. The concentration of toxic waste releases in a smaller number.of industrial firms means that larger cuts in toxic pollution can be made through fewer actions. The. concentration of waste in three electronics sectors indicates the efficiency of key local manufacturing sectors might be significantly strengthened by actions that reduce this waste. Several lines of evidence suggest increased industrial efficiency in printed circuit board manufacture and metal finishing might be of particular importance to the local economy. More than half the biggest copper and nickel dischargers are in these sectors. These sectors may also.be impacted most by a given amount of waste because, as discussed below, more printed circuit board and metal finishing firms are small or mid sized businesses when compared to semiconductor firms. These .types of firms are also more likely to have difficulty attracting investments for capital improvements than semiconductor manufacturers. (Judd et al., 1987) They are further characterized by relatively high fixed costs and deep boom-bust cycles. (Ibid.; and Center for Neighborhood Technology, 1990) Finally, these sectors provide local production of essential "building blocks" upon which the computer and communications industries depend. (Judd et al., 1987) • Individual firms in polluting sectors reaped economic benefits through increased industrial efficiency that greatly reduced toxic waste releases to sewers. Toxic sewer releases from printed circuit board making and metal finishing firms .can be cut by more than 90%. In more than one hundred cases around the world, facilities drastically cut or eliminated2 waste water releases of copper or nickel from at least one process by improving the efficiency of their manufacturing. The engineering solutions that achieved these improvements are relatively straightforward, and these results can be generally achieved by other firms in these industries. However, site-specific planning, design, and 2 While these techniques can reduce 90% to 99% of toxic releases, entropy.will cause some release of any chemical still in use. This also applies to the term 'closed loop.' 8 CLEAN SAFE JOBS ACBE REPORT Breakdowns of the fifty biggest industrial dischargers of copper and nickel by to the San Jose/Santa Clara sewage treatment plant by industrial sector. These dischargers cause 85% of industrial copper pollution, and 84% of industrial nickel pollution from the plant. copper other semiconductors printed circuit boards metal finishing nickel other printed circuit boards semiconductors metal finishing Source: All data from the most recent San Jose Department of Water Pollution Control records. (Pollution ranking based on 1991-92 data.) Analysis by CBE. 9 CLEAN SAFE JOBS A CBE REPORT investment are needed before these proven, generally feasible solutions can be properly applied to individual industrial facilities. Metal finishing and printed circuit board making processes use water and other chemicals in a series of tanks, as shown on the facing page. In the process bath, metals are either deposited on the surface of the parts (often using electricity to attract metals to the surface), or removed (often using acids or caustics to etch copper away). The processed parts are immersed in the rinse bath(s) to remove impurities. The most important solutions to these sectors' pollution problems attack process efficiency problems at the points circled on the diagram. Use of raw materials less toxic than copper eliminated copper releases to the sewer at twenty-six Silicon Valley facilities. (CBE, 1989) Changing process chemistry or temperature can reduce the amounts of toxic by-products created. (Shannon, 1991; Judd et al., 1987; Rosenblum Engineering, 1991; and Cal EPA, 1992) Filtration of the process bath removes impurities that can interfere with product quality and allows longer use of the bath, reducing waste of copper, nickel, and other process chemicals. (Shannon, 1991) Before rinsing, processed parts should be fully drained into the process bath to save raw materials and reduce waste. (Foecke, 1989) Spray rinses and splash boards greatly aid in the reduction of this "drag out." (Ibid.; Shannon, 1991; and Judd et al., 1987) For further rinsing some shops use multi-tank counterflow rinses (Shannon, 1991) that can increase rinse efficiency tenfold. (Foecke,,1989) Conductivity-sensors and flow regulation further reduce water waste. (Shannon, 1991; Cal EPA, 1992) Using many of the above solutions, Acteron Corporation, a high tech plating company in Redwood City, California with about 40 employees, cut its water use by two-thirds and cut nickel releases to the public sewer by approximately 90%. (Shannon, 1991; Burt, per. com., 1992) Closed loop recycling -- putting water and metal back into the process instead of down the drain -- is more cost-effective after the above actions reduce the volume and number of impurities in the mixtures to be recycled. By supplying water purer than tap water, it further improves process efficiency and product quality. (Foecke, 1989; and Judd et al., 1987) Three printed circuit board facilities used ion exchange and electrowinning to recycle water in-process and sell copper sheets to other industries. (Hulbert and Fleet, 1989; and Crane, 1989) Three metal finishers used evaporation and/or distillation to essentially close the loop and return chromium and nickel to the same processes. (Civil Engineering.ASCE, 1982; Foss, 1989; and Wavrock, 1989) A circuit board firm, a metal plater, and 150 other facilities used reverse osmosis to return nickel and copper for processing. (Rich and von Kuster, 1989; and Cartright, 1984) These solutions reduced water use by an estimated 80% to 90%, recaptured significant 10 CLEAN SAFE JOBS A CBE REPORT Conceptual . diagram of improved efficiency/reduced waste for a printed circuit board or metal plating/finishing process (not an exhaustive review of options). municipal water input of process 2.c supply chemicals �� I movement of processed parts O1.a �� � --- 2.f process bath 2d rinse baths WE Q clean water "1E : 2e 02e return to rinse used Z e water metal and E- recovered metals to rocess water 3.a recovery 4.a 3.b 1. TOIOCS USE REDUCTION. 1.a Substitute a nontoxic or less toxic chemical. 1.b Change the process to create less toxic byproducts. Y. WASTE REDUCTION. 2.a Filter the process bath to extend bath Igo and Increase product quality. 2.b Maximize the drip of process liquid back Into the process bath. 2.c Use spray rinses to reduce the amount of contaminated rinse water. 2.d Position tanks and splash boards to reduce drips and splashes down the drain. 2.e Use multi-tank countercurrent rinsing to Improve rinse efficiency. 2.f Use conductivity sensors to better regulate process and water inputs. 8. RECYCLING AND REUSE (Segregate streams and separate the reduced volume of spent process and rinse with osmosis, evaporation, distillation, ion exchange and/or electrowinning.) 8.a Close the loop: reuse purified water and metals In the same process. 8b Transport the metal for reuse in a different industrial process and recycle the water In the same process. 4. DISPOSAL (Separate some toxlc chemicals from waste water and dispose of wastes In a hazardous waste landfill, municipal sewage sludge, and S.F. Bay — avoid this option.) 4.a Reduced waste techniques are still partly effective since most conventional J treatment systems are equally or more efficient at smaller throughputs. I i i CLEAN SAFE JOBS A CBE REPORT amounts of metals, and reduced metal waste by an estimated 90% or more. (Judd et al., 1987; Cal EPA, 1992; Hulbert and Fleet, 1989; Crane, 1989; Wavrock, 1989; Rich and Kuster, 1989; and Foss, 1989) These waste reduction efforts saved these firms money. Acteron estimates water, sewer, and .deionized water saved them more than $2,000 per month. (Burt, per. com., 1992) Closing the loop at another metal finishing shop saved an estimated $2,000 to $3,000 per month. (Foss, 1989) A U.S. Navy electroplating facility in Florida found closed loop recycling was cheaper than treatment. (Civil Engineering ASCE, 1982) The closed loop system at Aeroscientific Corporation in Anaheim, California appeared to cost the same as conventional waste treatment and disposal in 1987,and was projected to save money as the cost of sludge disposal to landfills increases. (TRSI, 1990) Other estimates of cost savings can be expressed in terms of how long it takes to start making money on the firm's initial investment. Cray Research anticipated a two-year pay back for the closed loop copper recovery system at its printed circuit board facility. (Rich and von Kuster, 1989) A one year pay back was estimated for a copper recovery system for a plating facility. (Ibid.) Closed loop recycling of about 150 various nickel baths took an average of a year and a half to pay back for the firms. (Cartright, 1984) Reverse osmosis and recycling of nickel rinse and bath water was estimated to pay back in about ten months. (Rich and von Kuster, 1989) In Italy a distillation system that cut up to 95% of nickel waste from a plating shop was reported to pay back in less than three months. (Wavrock, 1989) Water savings alone are estimated to pay back within five years for metal finishers making extensive use of new rinse methods. (JRB, 1982) Cal EPA projects one year pay back periods for a sequence of measures to attain 90% reductions in metals discharges from metal finishers. (Cal EPA, 1992) According to the National Association of Metal Finishers Waste Minimization Committee, firms that reduce waste may realize cost benefits through improved quality control, lower chemical cost, lower inventory, less storage area, better product quality, lower water bills, lower sewer bills, lower material usage and chemical storage for waste treatment, lower hazardous waste disposal and liability costs, improved company standing in the community, and other benefits. (Cal EPA, 1992) These economic benefits may become even more important as raw. materials and waste disposal costs increase (Judd et al., 1987), and more hands-on experience is gained in smaller shops. For example, several printed circuit board and metal finishing firms use low-cost, "home-made" ion exchange and electrowinning to recycle metals and water (Ibid.; and Cal EPA, 1992). The California Environmental Protection Agency believes that these solutions may be achievable for less than $10,000 per shop. 12 CLEAN SAFE JOBS A CBE REPORT Ironically, the economic significance of these improvements in efficiency may be one reason why they have been a well-kept secret in a competitive industry. Cal EPA writes: l "Within the last ten years, metal finishers have made substantial expenditures for waste treatment equipment. Competitive companies were eager for all other companies to incur this cost so that no one would have a competitive advantage. ... [Mlany basic process techniques and equipment improvements are being developed that provide substantial cost savings through energy efficient waste reduction technologies and-strategies. Several of these techniques and improvements are low cost and easy to implement. ... However, as mentioned earlier, there is little incentive for the sharing of this technology within the industry." (Cal EPA, 1992. pages 11 and 12) Those who most clearly recognize the direct relationship between increasing industrial efficiency and decreasing industrial waste will be most competitive. • The costs and benefits of increased efficiency/reduced waste can be broadly estimated for industry and environment, and techniques exist to predict specific costs and pay backs for individual' shops. ti INDUSTRIAL COSTS AND BENEFITS Adequate data are available to suggest reduced waste solutions are affordable for the industry overall. This is true despite accounting practices that hide the costs of industrial waste (TRSI, 1990; and OTA, 1986), and important differences between individual facilities. The table below summarizes nine estimates of the capital costs of 90%'0 waste reductions ranging from approximately $10,000 per facility to $ 1.3 million per facility, and several estimates that these investments will pay back within three months to five years. (See Table for literature cited) The 100 companies causing the biggest copper and nickel discharges have total annual revenues of more than $ 2 billion, and at least some of these firms already spend an estimated one percent to four percent of revenues on waste management. According to this crude, simplified cost analysis, when spread over a seven year financing period, these capital improvements cost less than one percent of revenue, cost less than present waste practices, and begin making money in three months to five years. ENVIRONMENTAL BENEFITS In South San Francisco Bay, reductions in the pounds of copper and ' nickel wastes that industry puts into sewers are one crucial measurement of the 13 CLEAN SAFE JOBS A CBE REPORT environmental benefits of these industrial actions.3 The graph on the facing page shows the present total industrial copper and nickel discharge to the San Jose/Santa Clara sewage treatment plant on the left, and the deep cuts in this pollution that can be achieved by increased efficiency/reduced waste actions. The downward curve of reduced pollution is calculated by projecting that each industrial facility, starting with the biggest discharger, will reduce the number of pounds of copper and/or nickel it puts in the sewer by an average of 90%, using the proven, cost-effective solutions described in this report. This calculation shows that deep pollution cuts can be made quickly. A 90% cut in the biggest twenty discharges could cut total copper and nickel to nearly 8,000 pounds per year. In other words, immediate action by the biggest 5% of industrial polluters would quickly cut more than 40% of total industrial pollution. Similarly, if the 100 biggest dischargers make the 90% metal waste reductions discussed in this report, total industrial copper and nickel pollution will be cut by 75%. If all 350 monitored industrial dischargers take these 90% waste reduction actions, their total discharge will, of course, be cut by 90%. POLLUTION PREVENTION AUDITS Unfortunately, there is too much variation in the initial costs shown on the facing page for firms to act with confidence based on the experience of other firms without first assessing their individual situations. Site-specific differences in process chemistry, limited floor space (Foecke, 1989), and the potential availability of new floor space as firms streamline operations or specialize (Burt, per. com., 1992) may drastically affect cost and pay back figures for an individual facility. This long-recognized need to explore such in-plant factors at specific facilities led to the development of pollution prevention audit techniques (OTA, 1986) that are now well demonstrated. (See eg., CBE, 1989; Kennedy/Jenks Consultants, 1991; and Rosenblum Environmental Engineering, 1991) The basic audit technique pinpoints the causes of waste in a specific shop, evaluates solutions like those discussed above, and provides specific cost, engineering, and cost-savings analysis to improve processes and operations, attract financing for capital improvements, and involve workers in waste reduction. In recent years a consensus has emerged in the Bay area.. Industry and citizen groups now agree that these pollution prevention audit techniques should be applied. At the San Francisco Bay Estuary Conference convened under the Clean Water Act, industry, government and citizen groups agreed that industry should be required to perform pollution prevention audits. (San Francisco Estuary Project, 1992) 3 These actions would also reduce toxic pollution of municipal sewage sludge, increase options for sludge recycling, and reduce other environmental emissions and exposures as less toxic materials are transported, handled, and processed, among other environmental benefits. 14 CLEAN SAFE ,LOBS A CBE REPORT A simplified analysis suggests that capital for industrial efficiency should cost industry less than managing waste. Min. estimate Max. Capital cost of 90% waste reduction (b) $ 10,000 $ 1,300,000 Annual cost of seven year no-interest loan 1,430 186,000 Annual cost of these loans for 100 firms 143,000 18,600,000 Total revenues for biggest 100 dischargers (c) 2,168,000,000 Not available Annual cost of loans as a % of revenue 0.005% 0.9 % (d) Present waste mgt. cost as a % of revenues (e) 1 % 4 % When waste savings pay for investments (t) 3 months 5 years 16,000 :< > "> Three quarters of the waste of key Total pounds ` „> industrial materials poisoning San A of industrial Francisco Bay can be eliminated by "{ nickel (grey) '> economically favorable and - : improvements at the 100 industrial copper(black) �'��`����� 8,000 facilities that waste the most copper released to and nickel down the drain. (a) Silicon Valley's >:... biggest Future totals if proven waste reductions are done sewage plant in 119�1 0 100 200 300 Number of facilities adopting all feasible waste reductions (b) TRSI, 1990; Cal EPA, 1992; Wavrock, 1989; Crane, 1989; and Judd et al., 1987. (c) Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992. Actual totals include data for only 75 of 100 companies. (d) Based on minimum revenue and maximum capital cost. 1 (e) Judd et al., 1987. Based on a printed circuit board manufacturing survey. (f) Rich and von Kuster, 1989; Cartright, 1984; Wavrock, 1989; JRB, 1982; and Cal EPA, 1992. (a) Based on waste reduction levels that have been demonstrated by industry, and San Jose/Santa Clara Water Pollution Control Department pretreatment records. 15 CLEAN SAFE JOBS A CBE REPORT • Many wealthier firms can afford to, but have not, financed increased industrial efficiency/reduced waste improvements. Some of the biggest companies that are also big dischargers can clearly afford closed loop recycling in the short term, with cost savings in a few months or years. The pie chart on the facing page breaks down the 100 biggest copper and nickel dischargers by annual revenues based on economic data reported in standard references. (Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992) The chart shows that many of these companies have revenues in excess of $10 million per year. For these firms, even the maximum4 pollution prevention investments shown in the table above would cost less than two percent of revenues, a cost that is comparable with the lower end of the range of existing waste management costs reported by Judd et al. (1987). Many of these firms may be polluting only because of short-sighted economic analyses. For these firms, the failure of environmental law enforcement is an important factor discouraging investment in the environment and the economy. The U.S. Environmental Protection Agency has found that the City of San Jose is violating a second provision of the Clean Water Act (in addition to its violations of effluent limits and water quality standards as discussed in the introduction of this report) because the City has failed to adequately enforce the Clean Water Act "pretreatment program" requirements against industrial sewer dischargers. (EPA, 1991) San Jose has failed to impose proper "local limits" on individual industrial facilities, and instead allows too many of its dischargers to put too . many total pounds of copper, nickel, and other toxics into its public sewers. (CBE, 1989; and CBE, 1990) Lack of firm limits on pollution encourages business to ignore the waste that signals the need to improve industrial efficiency. Even if those firms that can afford to invest in pollution prevention are aware of the cost savings that are going down the drain, without proper environmental law enforcement, they have apparently chosen to delay these investments. Failures in environmental law enforcement are a major barrier to investments in efficiency upgrades that could strengthen the local economy and protect the Bay. 4 Since costs are almost certainly smaller than the maximum capital cost for smaller firms (Judd et al., 1987; and Cal EPA, 1992), many or most smaller firms may be able to afford increased efficiency and reduced waste improvements as well. The data in the table above show costs may be smaller than the maximum cost by two orders of magnitude, and positive pay backs may exceed costs quickly. 16 CLEAN SAFE JOBS A CBE REPORT Economic reports on 75 of the 100 companies with the biggest copper and nickel discharges show that roughly half of these companies have annual revenues greater than $ 10 million. $1 million - $5 million $10 million - > $100 million 000 $5 million - $10 million Source: Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992. Note that this breakdown is based on the most recent annual revenue or sales records that were found for 75 of the 100 companies: many of the 25 financial records that were not retrieved may be for small businesses. 17 CLEAN SAFE JOBS A CBE REPORT 7 • Environmental investments that increase the industrial efficiency of smaller firms supplying local high-tech "building blocks" will save jobs and increase competitiveness. A closer,look at the 100 high-waste facilities reveals a dramatic split between big business and small business. The pie charts on the facing page show .that two thirds of the printed circuit board firms and more than half the metal finishers report less than $10 million in annual revenues, but more than three quarters of the semiconductor firms report more than $10 million. None of the printed circuit board firms reported revenues in excess of $100 million, but 40% of the semiconductor and metal finishing firms did. None of the semiconductor firms reported revenues of less than $1 million, but nearly a quarter of the metal finishers did. In the printed circuit board and metal finishing industries, the market is split between "captive" shops owned by bigger companies and smaller independent "job" shops. (Judd et al., 1987) The full picture thus reveals a startling opportunity for environment and industry. As the biggest buyers of high tech "building blocks" manufactured by the printed circuit board and metal finishing firms (Ibid.), wealthycomputer and communications companies depend upon these smaller firms. Yet in spite of their importance to the business community, these smaller business sectors face a combination of stiff competition and small margins, and waste is particularly costly to them. Therefore, a program to increase industrial efficiency and reduce waste in smaller metal finishing and printed circuit boards firms could not only protect the environment, but significantly contribute to the economic health of Silicon Valley industry as a whole. Three factors interact to make the cost savings of pollution prevention most important to smaller printed circuit boards and metal finishing firms. First, saving the same ton of raw materials such as water and metals means more to a smaller firm with smaller revenues. Pollution prevention saved one such firm about $2,000 per month through water and sewer savings alone, an amount equal to 3% of revenues for nearly a quarter of the metal finishers on the chart, and equal to what these firms are estimated to spend on waste management according to Judd et al. (1987). Second, cutting the waste of raw materials improves margins to a greater extent for these firms because raw materials are a relatively large portion of their total costs. (Ibid.) Third, these large fixed costs combine with the boom-bust cycles of the printed circuit board and metal finishing industries to put the squeeze on smaller firms. (Ibid.; and Center for Neighborhood Technology, 1990) When sales drop, the printed circuit board industry's fixed costs (45%) and materials costs (40%) have drastic effects on small firms. Qudd et al., 1987) 18 Annual revenues for 75 of the 100 biggest copper and nickel dischargers show that small and mid-sized businesses with high-waste are concentrated in the printed circuit boards and metal finishing industries. Printed circuit boards < $1 million $1 - 5 million 25 - 100 million $5 - 10 million Metal finishers < $1 million > $100 million $1 - 5 million $10 - 25 million $5 ­10 million Semiconductors $1 - 5 million f $5 - 10 million > $100 million :: :: ::: >: $25 - 100 million ?" $10 - 25 million Source: Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992. Note that these breakdowns are based on financial records found for 75 of the 100 companies: many of the 25 financial records that were not retrieved may be for smaller businesses. r CLEAN SAFE JOBS A CBE REPORT Improved industrial efficiency will protect local jobs at these metal •finishing and printed circuit boards firms by reducing waste of costly raw materials and improving margins in these highly competitive industries. The high-waste printed circuit board and metal finishing shops assessed in this report employ about 5,000 people. (Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992) Yet the firms' labor costs are reported to be as low as 15% of total costs. (Judd et al., 1987.) These firms are further clustered advantageously near the major computer and communications buyers of their products. With all this going for them, there is no reason to let these jobs.go down the drain. As discussed above in this report, the capital improvements that could make deep cuts in water and metals waste at these high-waste metal finishing and printed circuit boards firms are affordable to Silicon Valley industry overall. In addition, savings from reduced materials costs, improved product quality, reduced waste management costs and the like should recoup these investments and start making firms money in a matter of months to five years. Further, the economic benefits to big business of healthy local high tech building block manufacturing should not be underestimated. For example, computer and communications firms buy about 65% of all printed circuit boards (Judd et al., .1987), and need new board designs integrated into their new products before these products can be marketed. Independent prototype shops, such as Trend Circuits in Fremont, California, clearly.play a local role in getting new high tech innovations to market quickly. These interdependent parts of Silicon Valley's electronics industry cannot afford to fail to work together, and cut waste for their own competitiveness. Retaining these manufacturing jobs would also avoid negative economic and social repercussions on the overall community. (Center for Neighborhood Technology, 1990) Cutting industrial toxic waste would help to protect • commercial and sport fishing jobs that depend upon a healthy San Francisco Bay, protect public health, and save declining species of aquatic life and wildlife. Additional jobs would be created in constructing the process improvements needed to maximize industrial efficiency. Investments to increase industrial efficiency and reduce toxic raw materials wastes in metal finishing and printed circuit board manufacturing firms are good investments overall. 20 CLEAN SAFE JOBS A CBE REPORT A four-point technical and financial assistance proposal to prevent pollution and retain jobs in South San Francisco Bay. We urgently need substantial reduction of toxic metal releases from the South Bay metal finishing and printed circuit board manufacturing industries to stop poisoning San Francisco Bay, improve the economy, and retain local manufacturing jobs. CBE recommends the following technical and financial assistance proposal for clean safe jobs in South San Francisco Bay: • 1. Fund pollution prevention audits and business plans that recommend the best process changes to eliminate waste water pollution at the source. Cities operating sewage treatment plants ("cities") should fund pollution prevention audits and business plans that recommend a sequence of pollution prevention and closed-loop recovery actions. These actions will help firms reduce copper and nickel releases to sewers and attain costs savings that provide positive pay back on investments. This service should be offered to all metal finishing and printed circuits board manufacturing firms that discharge process wastes to sewers with a focus on firms with larger copper and nickel mass discharges. • 2. Provide technical experts to help ensure that the pollution prevention business.plans are successfully carried out. The cities should fund technical experts agreed to by industry, government and the public to conduct the audits and develop pollution prevention business plans that attract the investments firms need to implement these recommendations and achieve these benefits. • 3. Help smaller firms finance their pollution prevention business plans through loan guarantees, buy down of interest rates, or other actions. The cities should establish and organize funding for a "loan guarantee pool" to provide firms that qualify with loan guaranties, interest rate buy-downs, rebates on water bills, and/or other assistance designed to provide low- or no-cost financing to implement the pollution prevention business plans. Firms that qualify must promise to stay in town or reimburse the community for the assistance. Firms in the top 20% of industrial copper or nickel mass dischargers will implement 90% cuts in these metals releases to qualify. • 4. Ensure worker retraining and involvement in industrial efficiency/waste reduction improvements. Firms receiving assistance will help assure successful pollution prevention and jobs retention by providing worker retraining and involvement in the development and operation of new practices. Please ask your Mayor and City Council and any professional organizations or trade associations that you belong to to endorse this proposal. Call CBE at 415/243-8373 to help us win jobs and environmental health in the South Bay. 21 j i CLEAN SAFE JOBS A CBE REPORT Literature cited. Belliveau and Grove, 1987. The Synergistic Environmental Impacts of Fresh Water Diversions and Toxic Pollution on South San Francisco Bay. Citizens for a Better Environment, San Francisco,CA. Burt,per.com., 1992. Patrick Burt,President,Acteron,Redwood City,CA. Per. com. with Greg Karras, Director, Clean Bays and Coastal Waters Program, Citizens for a Better Environment. April 1992 and August 17,1992. Business Information Systems Inc.,1990. Santa Clara County Commerce and Industry Directory 1990/1991. San Mateo,CA Cal Dept. of Finance, 1989. Population Estimates of California's Cities and Counties,January 1,' 1988 to January 1,1989. Cal EPA, 1992. Application for "National Industrial Competitiveness Through Environment, Energy,and Economics"Grant. Proposal 2:Cost Effective Methods of Waste Minimization for the Metal Finishing Industry. Submitted to the U.S. Department of Energy and Commerce,and the U.S. Environmental Protection Agency. California Fishing Regulations. State of California, Fish and Game Commission. California Hunting Regulations. Part III (Waterfowl). State of California, Fish and Game Commission. Cartright, 1984. An Update on Reverse Osmosis for Metal Finishing. in Plating and Surface Finishing, April 1984. Center for Neighborhood Technology,1990. Sustainable Manufacturing,Saving Jobs, Saving the Environment. by Valjean McLenighan. Center for Neighborhood Technology,2125 West North Avenue,Chicago,IL CBE,1989. Industrial Toxics Dischargers in South San Francisco Bay. A report by Citizens for a Better Environment,Report No.89682. CBE, 1990. Hidden Polluters of California's Coast. A Preliminary Analysis of Industrial'Toxic Releases into California's Coastal Environment Through Public Sewers. A report by Citizens for a Better Environment, Report No. 90-2. CBE,1991. Petroleum Transportation and Poison Runoff:Gasoline,Asphalt,and Other Petroleum Causes of Toxic.Storm Drain Pollution in South San Francisco Bay. July 1991. Citizens for a Better Environment,San Francisco,CA. CBE,1992. Comments on Behalf of Citizens for a Better Environment(CBE)before the Regional Water Quality Control Board, San Francisco Bay Region, regarding the Draft Final Report Prepared in May 1992 for the Board by S.R. Hansen&Associates,Concord,CA Entitled Development of Site Specific Criteria forCopper For San Francisco Bay. Submitted July 9, 1992. San Francisco,CA CH2M Hill, 1989. City of San Jose Pollutant Sources Evaluation (Provision 5B), San Jose/Santa Clara Water Pollution Control Plant, Permit Assistance Program. Submitted by San Jose to the regional Water Quality Control Board, San Francisco Bay Region.. 22 CLEAN SAFE JOBS A CBE REPORT Civil Engineering-ASCE, 1982. New Evaporation Process: Key to Zero Discharge for Electroplaters. August 1982. CLEAN South Bay, 1992. Request for Regional Water Quality Control Board Action Reducing Copper and Selenium Pollution of the South Bay from Water Supply Practices and Copper-based Biocides. June 4, 1992 petition by CLEAN South Bay,a coalition of environmental, fishing,and business organizations including Citizens for a Better Environment,requesting Regional Board Action,and supporting documentation and analysis. Oakland,CA. Crane, 1989. Recovery of Metals in Circuit Board and Metal Plating Manufacturing. in"Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Database Publishing Company, 1992. 1992 California Manufacturers Register. Newport Beach, CA Davis et al., 1991. Status and Trends Report on Pollutants in the San Francisco Estuary. San Francisco Bay-Delta Aquatic Habitat Institute. Richmond, CA. EOA,Inc., 1991. Investigation of un-permitted sources of copper and nickel in San Jose/Santa Clara WPCP influent. Prepared for San Jose by EOA Inc.,1410 Jackson St.,Oakland,CA. EPA,Decision of the United States Environmental Protection Agency on Listings Under Section 3040) of the Clean Water Act Regarding the State of California. EPA Region LX. Decision issued September 28,1990. EPA, 1991. Pretreatment Performance Evaluation Report for the City of San Jose,. June 5, 1991. U.S. Environmental Protection Agency,Region LX. Foecke, 1989. Source Reduction Opportunities in the Plating Industry. in "Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Flegal et al., 1991. Dissolved Trace Element Cycles in the San Francisco Bay Estuary. Marine Chemistry 36: 329-363. Foss, 1989. Closed Loop Plating System for Waste Minimization. in"Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Gale Research Inc., 1992. Manufacturing USA: Industry Analyses, Statistics,and Leading Companies. Arsen J.Darnay,Ed. Detroit,MI Herbold et al.,1992. Status and Trends Report on Aquatic Resources in the San Francisco Estuary. Prepared under cooperative agreement#CE009515-01-1 with the U.S. Environmental Protection Agency. i I 23 i I CLEAN SAFE JOBS A CBE REPORT Hulbert and Fleet, 1989. Case Study of a Minimum Discharge, Heavy Metal Waste reduction System at Aeroscientific Corporation, Anaheim, California. in "Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Judd et al., 1987. Final Report,Waste Reduction Strategies for the Printed Circuit Board Industry. Alternative Technology Section, Department of Health Services, State of California. JRB, 1982. A Manual of New Waste Conservation and Reuse Methods for the Electroplating Industry. Prepared for:Environmental Protection Agency under EPA Contract No.68-01-6348. McLean,VA Kennedy/Jenks Consultants, 1991. Regional Water Quality Control Plant Waste Minimization Guidelines. Palo Alto,CA Kopec et al., 1991. Toxic Pollutant Residues and Health of San Francisco Bay Harbor Seals Phoca vitulina. Romberg Tiburon Center,San Francisco State University,Tiburon,CA.,University of California, Berkeley, and.San Francisco Bay Bird Observatory, Sausalito, CA. Poster presented at the ninth biennial conference on the biology of marine mammals,5-9 Dec. 1991,Chicago, Ill. Kuwabara et al., 1989. Trace Metal Associations in the Water Column of South San Francisco Bay, California. Estuarine Coastal and Shelf Science 28: 307-325. Lonzarich et al., in press. Trace Element and Organochlorine Levels in California Clapper Rail Eggs. .U.S. Fish and Wildlife Service, San Francisco Bay National Wildlife Refuge, Newark, CA. Luoma and Cloern, 1982. The Impact of Waste-water Discharge on Biological Communities in San Francisco Bay. In San Francisco Bay:Use and Protection.Eds.W.J.Kockelman,T.J.Conomos,and A.E. Leviton,pp 1137-1160. American Association for the Advancement of Science,San Francisco, CA. Luoma et al., 1985. Temporal Fluctuations of Silver,Copper,and Zinc in the Bivalve Mamma balthica at Five Stations in South San Francisco Bay. Hydrobiologia 129: 109-120. Ohlendorf et al., 1986. Selenium and heavy metals in San Francisco Bay diving ducks. Journal of Wildlife Management 500): 64-71. OTA, 1986. Serious Reduction of Hazardous Waste:for Pollution Prevention and Industrial Efficiency. U.S.Congress,Congressional,Office of Technology Assessment,OTA-ITE-317, Washington, D.C. Rich and von Kuster, 1989. Recovery of Rinse Water and Plating Bath from Process Rinses Using Advanced reverse Osmosis. in"Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Rosenblum Environmental Engineering, 1991. Waste Minimization Study for Plating Operations at the Microwave Power Products Department,Varian Associates Palo Alto, CA. October 1991. Rosenblum Associates,Sebastopol CA ( 24 CLEAN SAFE JOBS A CBE REPORT SWRCB, 1990. Order WQ 90-5 Regarding South San Francisco Bay, including Final Staff Technical Report. California Water Resources Control Board, Sacramento, CA. San Francisco Bay Basin Plan, 1987. Water Quality Control Plan for the San Francisco Bay Basin. May 1987. Regional Water Quality Control Board; San Francisco Bay Region, Oakland, CA San Francisco Estuary Project, 1992. Draft Comprehensive Characterization and Management Plan for the National Estuary Conference convened under the federal Clean Water Act for San Francisco Bay. Section 320. July 15, 1992 draft reflecting the consensus of the Project's Management Committee. San Jose v. State Water Resources Control Board, 1991. No. 366783(Superior Court of California, Sacramento County, filed May 10, 1991). San Jose,1992. Response to California Public Records Act Request by Citizens for a Better Environment. Industrial mass loading data for nickel and copper. March 25,1992 letter from D. Kent Dewell,Deputy City Manager,and enclosures. Shannon, 1991. Acteron and Waste Minimization. in Finishers' Management, Official.publication of the National Association of Metal Finishers. Jan 1991. Smith, 1987. A Review of Circulation and Mixing Studies of San Francisco Bay, California. US Geological Survey Circular 1015. US Geological Survey, Menlo Park,CA. Toxic Chemical Release Inventory, 1989. (United States Environmental Protection Agency and State of California Office of Environmental Affairs). A database of unverified industry self-reports required for certain industrial facilities and chemical releases by CERCLA (The federal Superfund Act). Toxic Chemical Release Inventory, 1990. (United States Environmental Protection Agency and State of California Office of Environmental Affairs). A database of unverified industry self-reports required for certain industrial facilities and chemical releases by CERCLA (The federal Superfund Act). TRSI, 1990. Performance Evaluation of a Non-Sludge, Heavy Metal Waste Reduction System at Aeroscientific Corporation, Anaheim, California. Toxic Recovery Systems International, Prepared for California Department of Health Services, Toxic Substances Control Division, Alternative Technology Section. April 1990. Project 87-T-0152. Wavrock, 1989. Waste Minimization of Hazardous Waste Solutions in the Electroplating and Precious Metals Industry Using the Final Treatment Distillation Unit. in "Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Woodward-Clyde Consultants, 1991. Santa Clara Valley Nonpoint Source Study. Volume I: Loads Assessment Report. Submitted to Santa Clara Valley Water District. 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'alo Alto's wastewater treatment plant,which also serves Mountain View,Los Altos,Los Altos Hills,East 'alo Alto and Stanford University, could have to reduce its copper and nickel levels by as much as 85 percent to :omply with new regulations. IBobel, manager of the environ- the city agrees to take steps to to swallow," Bobel said. "It ���11 mental compliance division of reduce the sources of copper and cost something. But we hop W It M not be too the city's Public Works Depart- nickel that end up in the Bay. will be offset by savings from ment. "It builds into itself a dispute- ducing water use and from aa ��1 said. "The result was that the Palo resolution process," 'Calonne ducing the cost of waste t ZarU t0 swallow Alto wastewater plant would p dung and disposal.." .have to reduce its copper and We all agreed that the en- p vu onment is not getting ONTINUEO FROM A-1 nickel levels by as much as 85 g any The proposal also calls percent to comply with the new cleaner if we waste time in front continued public education 1 altos,Los Altos Hills, East Palo regulations, Calonne said. of the regulatory board or the grams to reduce metal disch� Uto and Stanford University. y courts.' es from residents dump Cit off said there was no P The environmental groups cost-effective way to comply, A.-key part of the proposal is chemicals into the sewer or :laimed the wastewater levels of prompting the environmental- that cities would audit business- ing copper-based root killers popper and nickel, which are ists to threaten a lawsuit to en- es and other institutions that re- The city would bear indir oxic to aquatic organisms,were force the new regulations. The lease, the metals and determine costs for consultants to at: hreatening the South Bay %vet- proposed settlement ends more reasonably affordable ways the businesses and for public edi: ands ecosystem.The South Bay than a. year of negotiations be- businesses could reduce their tion campaigns, Bobel s. vetlands are particularly vul- tween the city and environmen- discharge levels. Much of the expenses'alre., ierable because there is little talists. The proposal defines afford- have been budgeted for t idal flushing there. The environmentalists also able based on the prevailing in- year,he said. In April 1991, the California threatened to sue Sunnyvale terest rate with an assumed pay- Davila Circuits Inc. Gene '.egional Water Quality Control and San Jose, the locations of back of five years. Manager Bob Davila.said loard severely tightened v:aste- the South Bay's other two waste After a 20 month audit period, proposed settlement is a m ater restrictions on copper and water treatment plants, over the city then would adopt copper, stone in the relationship i^kel. similar violations. Those cities and nickel limits based upon the tween cities and businesses. The board revised the copper are not involved in the proposed arts per billion to settlement, Calonne said. maximum feasible reduction -nit from 30 p p levels. "Before, it was cities agai; 9 parts per billion and the nick- Under the settlement terms, businesses," Davila said. "N( limit from 24 parts per billion the environmentalists agree not "The bottom line to business- it's cities working with bt. 8.3 parts per billion, said Phil to sue the city for five years if es is that it will not be too hard nesses to stay in compliance. ,t CLEAN SAFE JOBS The benefits of toxic pollution prevention and industrial efficiency to the communities of South San Francisco Bay. A preliminary report. CITIZENS FOR A BETTER ENVIRONMENT August 1992 Author Greg Karras, Director Clean Bays and Coastal Waters Program Cover Design Sandra Murray Research Guidance, Mike Belliveau, Executive Director Editorial Support Alan Ramo, Legal Director and Analysis Nora Chorover, Staff Attorney Hannah Creighton, Development Associate Denny Larson, Campaign Coordinator Julia May, Director, Clean Air Program, Northern California Region Margaret Williams, Financial Director Michelle Ozen, Office Director, San Francisco Citizens for a Better Environment (CBE) is a statewide public interest organization that uses technical research, policy advocacy, legal action, grassroots organizing, and public education to prevent pollution hazards and achieve healthy, sustainable urban communities. 501 Second Street, Suite 305 122 Lincoln Blvd.,Suite 201 15 Shattuck Square San Francisco,CA 94107 Venice,CA 90291 Berkeley, CA 94704 415/243-8373 310/450-5192 510/841-6163 I CLEAN SAFE JOBS A CBE REPORT Acknowledgements This report was made possible .by the assistance of many individuals and organizations who have contributed to Citizens for a Better Environment's San Francisco Bay Protection Campaign. We are deeply grateful for your support. The research, analysis, and production of this report were made possible by contributions from the Mary A. Crocker Trust, Compton Foundation, The Pew Charitable Trusts, The San Francisco Foundation, The Wallace Alexander Gerbode Foundation, Richard and Rhoda Goldman Fund, The Tides Foundation, The Gap Foundation, and REI. Many talented people lent their time and expertise to help plan the analysis and answer key technical or economic questions. Special thanks to Dave Kerschner, Patricia Mulvey, Pamela D. Adams, Patrick Burt, John Rosenblum, Tom Adams, Lenny Seigel, and Rick Sawyer. Sandra Murray generously offered needed design advice, draft designs, and cover graphics. Much of the analysis was built directly and indirectly on the data management and programming work of Joanne Marlowe and Steven Obrebski. This research was also made possible by the members of Citizens for a Better Environment. Thank you all! ii CLEAN SAFE JOBS A CBE REPORT CONTENTS Executive summary ... iv Introduction: Wildlife Refuge or industrial dump site? 1 • The environmental setting. ... 1 4� • Industrial sewer pollution is one of three key causes of severe 2 toxic pollution in the southern reach of San Francisco Bay. • Industrial pollution prevention for the toxic pollutants ... 4 copper and nickel: A case study in progress. Industrial waste, industrial efficiency, and industrial investment. ... 6 • A small proportion of the electronics industry causes most of the industrial copper and nickel pollution in the South Bay. ... 6 • Individual firms in polluting sectors reaped economic benefits through increased industrial efficiency that greatly reduced toxic waste releases to sewers. 8 • The costs and benefits of increased efficiency/reduced waste can be broadly estimated for industry and environment, and techniques exist to predict specific costs and pay backs for individual shops. ... 13 • Many wealthier firms can afford to, but have not, financed increased industrial efficiency/reduced waste improvements. ... 16 • Environmental investments that increase the industrial efficiency of smaller firms supplying local high tech "building . -blocks" will retain jobs and increase competitiveness. ... 18 - A four-point technical and financial assistance proposal to prevent pollution and retain jobs in South San Francisco Bay. ... 21 Literature cited. ... 22 Hi i CLEAN SAFE JOBS A CBE REPORT 16,000 Three quarters of the waste of key ti Total pounds v` industrial materials poisoning San >'<`> of industrial Francisco Bay can be eliminated by >:< nickel (grey) " economically favorable and improvements at the 100 industrial Y copper(black) facilities that waste the most copper released to '>. 8,000 and nickel down the drain. (a) Silicon Valley's biggest Future totals if proven waste reductions are done sewage plant in 1991 ::Y;::;::»:>:<:: < 0 100 200 300 Number of facilities adopting all feasible waste reductions Estimated number of jobs at the 100 industrial facilities that would realize the greatest benefits through increased industrial efficiency and reduced process waste. (b) 40000 » 35000 30000 250004'........ 20 000 15000 10000 5000 0 Electronics Other Printed circuits Metal finishingLaiSemiconductors ® Other (a) Based on waste reduction levels that have been demonstrated by industry and San Jose/Santa Clara Water Pollution Control Dept. pretreatment records. (b) Based on published business information. Business information systems Inc., 1990; Database publishing Co., 1992; and Gale Research Inc., 1992. CLEAN SAFE JOBS A CBE REPORT Executive summary This preliminary investigation shows that investments in pollution prevention in Silicon Valley's electronics industry could help retain thousands of jobs, create more jobs, increase competitiveness, and significantly reduce the severe toxic pollution of San Francisco Bay. It reports on a case study in progress in Santa Clara County, California, where a small portion of the electronics industry is the biggest industrial cause of the ongoing poisoning of the San Francisco Bay National Wildlife Refuge. It demonstrates that the industry as a whole can cut these wastes by 75% to 90% through improved- industrial efficiency that would save the polluting firms money. It pinpoints the failure to enforce environmental protection, and failure to invest in community industry, that now block these industrial efficiency/reduced waste improvements. The report sets forth a four-point technical assistance program that would, if implemented, prevent toxic pollution and retain local jobs: • 1. Fund pollution prevention audits and business plans that recommend the best process changes to eliminate waste water pollution at the source. • 2. Provide technical experts to help assure that the pollution prevention plans are successfully carried out. • 3. Help smaller firms finance their pollution prevention plans through loan guarantees, buy down of interest rates, or other actions. s • 4. Ensure worker retraining and involvement in industrial efficiency/waste reduction improvements. This program can help most by cutting high levels of waste at fifty metal finishing and printed circuit board shops in ways that increase efficiency and help to retain the 5,000 jobs in these shops. Those most helped will be small and mid-sized businesses in key manufacturing sectors that play an important role in the economic health, competitiveness, and retention of wealthier parts of the electronics industry. With adequate environmental law enforcement, this "clean safe jobs" proposal could help stop severe losses of San Francisco Bay resources and Silicon Valley manufacturing jobs. California's private industry wasted 31.9 million pounds of toxic chemicals down the drain into publicly owned sewers in 1990, fully thirty-five percent more than their 23.6 million pounds in 1989. (Toxic Chemical Release Inventory, 1992) This waste disposal through public sewer systems costs our communities in lost resources, and sewage treatment plants cannot neutralize it. We need to stop subsidizing industrial waste, and start investing in industrial efficiency for our health, environment, and jobs. j i iv i j The San Francisco Bay/Delta, its National Wildlife Refuge, and the area causing the largest effluent discharge south of Oakland and San Francisco. Oakland San Francisco ® San Francisco Bay National Wildlife Refuge ■ Collection area for the San Jose/Santa Clara Water Pollution Control Plant Introduction: Wildlife Refuge or Industrial Dump Site? • The environmental setting. The southern reach of the San Francisco Bay/Delta estuary stretches south from the San Francisco/Oakland Bay Bridge, and is also called San Francisco Bay, the Lower Bay, and the South Bay. Some of the physical features of the estuary are roughly mapped on the facing page. The southern reach receives only ten percent of total river flow into the estuary (Smith, 1987), but its catchment contains Silicon Valley, and the largest concentration of industrial waste discharges to public sewers in the estuary. (CBE, 1989) Reduced water circulation in the southern reach that is caused by river water diversions from the Delta further worsens the locally-caused pollution here. (Flegal et al., 1991; Luoma et al., 1985; Davis et al., 1991; and Belliveau and Grove, 1987) The map also shows the approximate location of the San Francisco Bay National Wildlife Refuge in the southern reach. The officially designated "beneficial uses" of water in the Bay's southern reach include navigation, recreation in and on the water, commercial and sport fishing, wildlife habitat, preservation of rare and endangered species, fish'migration, shellfish harvesting, and estuarine habitat. (San Francisco Bay Basin Plan, 1987) In addition to the Refuge, the southern reach'of the Bay is part of a "National Priority Estuary" under Section 320 of the Federal Clean Water Act. It is an important stopover for birds migrating along the Pacific Flyway. It includes the largest harbor seal haul-out and pupping area in the Bay, and part of one of the Bay's last remaining commercial fisheries, trawling for bay shrimp. Unfortunately, a number of negative impacts including pollution, wetlands destruction, and water diversions have greatly reduced the abundance of many populations of Bay species in recent years. Several species are threatened with extinction. At least one endangered bird species, the California Clapper Rail, depends on the southern reach for its survival. (Herbold et al., 1992; Lonzarich et al., in press). Finally, the map outlines the areas of Santa Clara County that discharge wastes to the Bay through the San Jose/Santa Clara sewage system. This collection, treatment, and discharge system is owned by the cities of San Jose and Santa Clara and services three quarters of Silicon Valley's industrial waste water discharges (CBE, 1989), and accepts wastes from water supply and other services for more than a million people who live in its collection area (Dept. of Finance, 1989). Despite advanced treatment of degradable pollutants, the San Jose/Santa Clara plant-causes the largest release of non-degradable toxic pollutants in the South Bay. I i I i CLEAN SAFE JOBS A CBE REPORT • Industrial sewer pollution is one of three key causes of severe toxic pollution in the southern reach of San Francisco Bay. Sewage plant effluents and urban storm runoff are the major sources of copper, nickel, mercury, selenium, and other toxic pollutants in the South Bay, according to the U.S. Environmental Protection Agency and the California Water Resources Control Board. (EPA, 1990; and SWRCB, 1990) Sewage effluents and local runoff pollution cause elevated concentrations of copper, nickel, cadmium, and other pollutants throughout the southern reach of the Bay. (Flegal et al., 1991) The pollutant concentration gradients extend to approximately the San Francisco/Oakland Bay Bridge, with the greatest concentrations near the effluent discharges from Santa Clara County, the heart of California's industrialized Silicon Valley. (Ibid.) There are three major known causes of this toxic pollution of sewage and storm runoff: manufacturing and "commercial" industrial facilities; the water supply industry's pesticide use and corrosion of its piping; and transportation system pollution of urban storm runoff. In the past,discharger representatives insisted that industrial pollution was small compared to other causes, but that may be changing. Discharger estimates of copper and nickel discharges to the San Jose/Santa Clara plant are shown on the facing page. (EOA Inc., 1991) As can be seen, the dischargers now agree that industry and water supply are the two largest causes of these pollutants in sewage effluents. CBE believes that the discharger "maximum water supply" estimates shown here still overestimate'the amount of water supply pollution by about three times, and thus down play the relative importance of industrial pollution. (CLEAN South Bay, 1992) Nevertheless, even these discharger estimates show they will need to reduce industrial sewer pollution as well as water supply pollution to best halt sewage poisoning of the Bay. Most of the pounds of those toxics that can be adequately traced in South Bay runoff come from gasoline combustion, engine emissions, vehicle leaks and wear, and the washing of these emissions from streets and other surfaces by storm runoff. Industrial runoff pollution is significant, but causes less total pounds of toxics to enter local runoff than transportation. (CBE, 1991) In dry years, local runoff pollution causes a significant portion of the total toxic discharge, but more copper, nickel, and other pollutants enter the South Bay from sewage plants than runoff. (Woodward-Clyde, 1990) Some studies predict runoff pollution will exceed sewage plant pollution in wetter rainfall years (Ibid.), but these predictions are questionable because pollutant . concentrations were not measured in wet-year runoff, and may be reduced when there is ten times more runoff or more. (SWRCB, 1990) 2 Discharger consultant estimates of'the causes of copper and nickel releases through the San Jose/Santa Clara sewage treatment plant (by relative mass). Copper (maximum water supply estimate) Other potential sources (unidentified) Regulated industry Regulated commercial industry Household products and wastes / /Water supply & corrosion Copper (minimum water supply estimate) .:_:,.. Water supply & corrosion Household products and wastes ::>><> ., a Regulated commercial industry :.:< Other potential sources (unidentified) r ;.,;:;;; " `::<= '> Re ulated industry 'V:':•i:4Y,.;::•i:is Infiltration and septage Nickel (maximum water supply estimate) Other potential sources (unidentified) Infiltration and septage , j/ Water supply & corrosion Regulated industry < > Household products and wastes Regulated commercial industry Nickel (minimum water supply estimate) Other potential sources (unidentified) Water supply & corrosion fK `Wy Household products and wastes Regulated commercial industry Infiltration and septE Regulated industry Source: EOA Inc., 1991. Investigation of Un-permitted sources of nickel and copper in Santa Clara/San Jose WPCP Influent. Prepared for: City of San Jose. See Table 2. 3 i CLEAN SAFE JOBS A CBE REPORT The EPA and State Board have found that toxic pollution threatens or impairs beneficial uses of water in South San Francisco Bay, in violation of the requirements of the Federal Clean Water Act. (EPA, 1990; SWRCB, 1990) Overwhelming evidence points to a severe toxic pollution problem. Concentrations of copper, nickel, and six other toxic chemicals in South Bay waters violated EPA criteria for the protection of aquatic life. (SWRCB, 1990) State Health Warnings say "no one should eat more than four meals a month of any striped bass" or "more than 4 oz. ... of greater scaup meat" from the area because of elevated mercury and selenium levels in these food resources. (Cal. Fishing Reg.; and Cal. Hunting Reg.) Further: "Women who are pregnant or may soon become pregnant, nursing mothers," and children should not eat any of these fish or ducks from the Bay. (Ibid.) South Bay selenium levels in ducks "were similar to those in livers of dabbling ducks in the nearby San Joaquin Valley where reproduction was impaired severely." (Ohlendorf et al., 1986) "Mercury concentrations in [California Clapper Rail eggs were] ... similar to levels associated with reproductive effects..." (Lonzarich et al., in press) The blood of Bay harbor seals contains copper and selenium at concentrations significantly greater than those of seals from other waters. (Kopec et al., 1991) Cadmium and copper were linked to a disease epidemic that led to a crash in the South Bay shrimp fishery in 1985. (SWRCB, 1990) South Bay shellfish that accumulated copper, silver, and cadmium to extremely elevated concentrations in their tissues were negatively impacted by toxicity. (SWRCB, 1990) This is important because "grazing by benthic invertebrates may limit phytoplankton biomass in South Bay. If so, damage to the benthic community through an increase in contaminant stress could have widespread impacts on the entire biological community of the Bay." (Luoma and Cloern, 1982) Indeed, copper and other toxics reach levels that may explain the elimination of dinoflagellate plants from the South Bay ecosystem. (Kuwabara et al., 1989) For more details of toxics threats see SWRCB, 1990; and CBE, 1992. • Industrial pollution prevention for the toxic pollutants copper and nickel: A case study in progress. This study explores a win-win solution to the conflict over whether San Francisco Bay will be a healthy ecosystem or a toxic dump site. It addresses the San Jose/Santa Clara discharge because it is the biggest source of pollution, as shown on the facing page. It explores acceptable solutions to ongoing pollution violations for the toxic pollutants copper and nickel. (also shown) Despite its environmental policies in other areas, San Jose has failed to enforce industrial clean up (EPA, 1991), and has sued the.State of California to weaken toxics standards for the Bay (San Jose v. State Water Resources Control Board), citing fears of economic harm and job losses. To address these concerns, the study focuses on the economic effects of industrial pollution prevention. 4 CLEAN SAFE JOBS A CBE REPORT Pie charts comparing the proportion of nickel and copper discharged to San Francisco Bay by South Bay sewage treatment plants. Nickel-mass emissions Copper mass emissions Palo Alto Sunnyvale 160 Ib/yr Sunnyvale 180 Ib/yr 310 lb/yr Palo Alto 680 Ib/yr :i•J.C:vC}:!'J'�?i?:v'-. 'JiiiC{i��!q.:ii•44 ::.+'\ +.•,•j �S�.j:�j::r:y�:;i !jryvyM1 v•'iv:;};r.n4vJh.. :;.ti::iti�?;}}.:v::v:v:•. v,:}}... '\:^:•' )::4i'3:i"K%:::4i' nib}':titiiw :Y. ?:s::.....:. nta Clara Jose/Santa Clara Jose Sa 11 lb/yr r 90 I 0 29 /b Y r 2 Scattergram plot of San Jose/Santa Clara effluent measurements showing nickel concentrations that violate the plant's 8.3 ug/I effluent limit and copper concentrations that violate the 2.9 ugA limit. 20 Nickel: • Copper: o 15 Vertical axis: • • • • • • 00000 o • • • .. • • ••• o .. • • • -San Jose/Santa Clara 10 effluent concentration � 40 • • M 000. 0 04D 0 ..• ®O 0 0 GMM • •• 0 0 •oaM 00 4D in micrograms per o 0® ® 00 • 0 00 0 000 ® • liter (ug/1). 5 0 0 • o• 00" 0 00 00 CMDO 99 89 egoo am 0 Weekly measurements from April 1991 through June 1992. Source: All data from discharger self monitoring reports to the California Regional Water Quality Control Board, Oakland, Calif. Pie charts based on approximately 150 weekly effluent measures from January through June 1992. Scattergram shows approximately 180 weekly measures from April 1991 through June 1992. Effluent limits from NPDES permit CA0037842. 5 CLEAN SAFE JOBS A CBE REPORT Industrial waste, industrial efficiency, and industrial investment. • A small portion of.the electronics industry causes most of the industrial copper and nickel pollution in the South Bay. The stacked bar charts on the facing page show the contributions of each monitored industrial facility and the total release of industrial copper and nickel to the San Jose/Santa Clara sewage treatment plant. Each bar starts with the largest discharge at the bottom of the stack, followed by the next largest, and so on. The first bar on the left of each chart shows the subtotal for the ten largest industrial discharges. The middle bars show the subtotal for the fifty largest industrial discharges. The bars on the far right show the total discharges from approximately 350 industrial facilities -- the total number monitored and regulated under this plant's pretreatment programa Copper and nickel are shown separately because the biggest dischargers of one pollutant are sometimes, but not always, the biggest dischargers of the other pollutant. These measurements show that a large proportion of industrial sewer pollution comes from only a few industrial facilities. The ten industrial facilities that released the most pounds of copper caused nearly half of all copper discharges from all 350 facilities. The ten biggest nickel discharges also caused nearly half of all 350 nickel discharges. The fifty biggest discharges of copper caused 85% of total industrial copper; the fifty biggest nickel discharges caused 84% of total industrial nickel— For both copper and nickel, less than 15% of the firms-caused more than 80% of industrial sewer pollution. Further, these trends appear consistent among different toxic chemicals, different areas, and different years. Most of the industrial chromium, copper, lead, nickel, silver, and zinc wastes released to Santa Clara County sewers in 1987 and 1988, and released to Los Angeles sewers in 1988 and 1989, also came from less than ten percent of industry. (CBE, 1990) For readers familiar with the Toxic Chemical Release Inventory (TRI) database required by federal Superfund legislation, it is important to note that these estimates are based on a different database that is more reliable for measuring industrial toxic metals releases to sewage treatment than the TRI database. The data presented here are from pollutant and flow measurements of each individual facility's effluent discharge connection to the public sewer system that are collected for all industry regulated by the "pretreatment program"of the federal Clean Water Act. (San Jose, . 1992) In contrast to the very limited industry self-estimates typical of the TRI, this database includes measurements of more industrial facilities,and each pollutant measurement is based on standardized chemical analyses that are reliable enough for use in enforcement of pretreatment standards intended to restrict pollutant discharges. In general, these data support very accurate estimates of copper and nickel releases and trends for groups of facilities. The data and methods of analysis are discussed further in CBE (1990). 6 CLEAN SAFE JOBS A CBE REPORT For the toxic pollutants copper and nickel, a small proportion of industry (only 50 of 350 facilities) causes more than eighty percent of the industrial pollution of San Jose/Santa Clara effluent. 12000 Copper: (8,690 Ib/yr) (10,180 Ib/yr) 10000 8000 (4,960 Ib/yr) 6000 4000- . 2000- .... 2000 0 Biggest 10 discharges Biggest 50 discharges All 350 6000 Nickel: (5,240 Ib yr (4,390 lb/yr) .5000 4000 '< (2,560 lb/yr) 3000 2000 1000 0V"�... LEW Biggest,10 discharges Biggest 50 discharges All 350 Source: All data from "pretreatment program" measurements of pollutant chemistry and flood at individual industrial facility connections to public sewers. City of San Jose, March 25, 1992. Also see CBE, 1989; and CBE, 1990. Analysis by CBE. 7 I i i i CLEAN SAFE JOBS A CBE REPORT Most of the big dischargers that cause more than 80% of industrial copper and nickel pollution are in Silicon Valley's electronics industry. The pie charts on the facing page show the breakdowns: For copper, almost half the fifty biggest dischargers manufacture printed circuit boards, more than 20% are Silicon Valley metal platers and finishers (metal finishers), and 20% manufacture semiconductors. For nickel, more than a third of the fifty biggest dischargersare metal finishers, more than a third make semiconductors, and 15% make printed circuit boards. The smaller "other" category includes diverse activities such as paperboard production, industrial laundering, and medical industries. This industry profile has important implications for our environment and economy. The concentration of toxic waste releases in a smaller number of industrial-firms means that larger cuts in toxic pollution can be made through fewer actions. The concentration of waste in three electronics sectors indicates the efficiency of key local manufacturing sectors might be significantly strengthened by actions that reduce this waste. Several lines of evidence suggest increased industrial efficiency in printed circuit board manufacture and metal finishing might be of particular importance to the local economy. More than half the biggest copper and nickel dischargers are in these sectors. These sectors may also be impacted most by a given amount of.waste because, as discussed below, more printed circuit board and metal finishing firms are small or mid sized businesses when compared to semiconductor firms. These types of firms are also more likely to have difficulty attracting investments for capital improvements than semiconductor manufacturers. (Judd et al., 1987) They.are further characterized by relatively high fixed costs and deep boom-bust cycles. (Ibid.; and Center for Neighborhood Technology, 1990) Finally, these sectors provide local production of essential "building blocks" upon which the computer and communications industries depend. (Judd et al., 1987) • Individual firms in polluting sectors reaped economic benefits through increased industrial efficiency that greatly reduced toxic waste releases to sewers. Toxic sewer releases from printed circuit board making and metal finishing firms can be cut by more than 90%. In more than one hundred cases around the world, facilities drastically cut or eliminated2 waste water releases of copper or nickel from at least one process by improving the efficiency of their manufacturing. The engineering solutions that achieved these improvements are relatively straightforward, and these results can be generally achieved by other firms in these industries. However, site-specific .planning, design, and 2 While these techniques can reduce 90% to 99% of toxic releases, entropy will cause some release of any chemical still in use. This also applies to the term "closed loop." 8 PORT CLEAN SAFE JOBS A CBE RE . Breakdowns of the fifty biggest industrial dischargers of copper and nickel by to the San Jose/Santa Clara sewage treatment plant by industrial sector. These dischargers cause 85% of industrial copper pollution, and 84% of industrial nickel pollution from the plant. copper other semiconductors printed circuit boards metal finishing nickel other printed circuit boards < <: semiconductors metal finishing Source: All data from the most recent San Jose Department of Water Pollution Control records. (Pollution ranking based on 1991-92 data.) Analysis by CBE. . 9 CLEAN SAFE JOBS A CBE REPORT investment are needed before these proven, generally feasible solutions can be properly applied to individual industrial facilities. Metal finishing and printed circuit board making processes use water and other chemicals in a series of tanks, as shown on the facing page. In the process bath, metals are either deposited on the surface of the parts (often using electricity to attract metals to the surface), or removed (often using acids or caustics to etch copper away). The processed parts are immersed in the rinse bath(s) to remove impurities. The most important solutions to these sectors' pollution problems attack process efficiency problems at the points circled on the diagram. Use of raw materials less toxic than copper eliminated copper releases to the sewer at twenty-six Silicon Valley facilities. (CBE, 1989) Changing process chemistry or temperature can reduce the amounts of toxic by-products created. (Shannon, 1991; Judd et al., 1987; Rosenblum Engineering, 1991; and Cal EPA, 1992) Filtration of the process bath removes impurities that can interfere with product quality and allows longer use of the bath, reducing waste of copper, nickel, and other process chemicals. (Shannon, 1991) Before rinsing, processed parts should be fully drained into the process bath to save raw materials and reduce waste. (Foecke, 1989) Spray rinses and splash boards greatly aid in the reduction of this "drag out." (Ibid.; Shannon, 1991; and Judd et al., 1987) For further rinsing some shops use multi-tank counterflow rinses (Shannon, 1991) that can increase rinse efficiency tenfold. (Foecke, 1989) Conductivity sensors and flow regulation further reduce water waste. (Shannon, 1991; Cal EPA, 1992) Using many of the above solutions, Acteron Corporation, a high tech plating company in Redwood City, California with about 40 employees, cut its water use by two-thirds and cut nickel releases to the public sewer by approximately 90%. (Shannon, 1991; Burt, per. com., 1992) Closed loop recycling -- putting water and metal back into the process instead of down the drain -- is more cost-effective after- the above actions reduce the volume and number of impurities in the mixtures to be recycled. By. supplying water purer than tap water, it further improves process efficiency and product quality. (Foecke, 1989; and Judd et al., 1987) Three printed circuit board facilities used ion exchange and electrowinning to recycle water in-process and sell copper sheets to other industries. (Hulbert and Fleet, 1989; and Crane, 1989) Three metal finishers used evaporation and/or distillation to essentially close the loop and return chromium and nickel to the same processes. (Civil Engineering ASCE, 1982; Foss, 1989; and Wavrock, 1989) A circuit board firm, a metal plater, and 150 other facilities used reverse osmosis to return nickel and copper for processing. (Rich and von Kuster, 1989; and Cartright, 1984) These solutions reduced water use by an estimated 80% to 90%, recaptured significant 10 CLEAN SAFE JOBS A CBE REPORT Conceptual diagram of improved efficiency/reduced waste for a printed circuit board or metal plating/finishing process (not an exhaustive review of options). municipal water input of process 2.c supply - chemicals �� movement of processed part 1.a 2.6 O 2:f process bath 2d rinse baths 1.b clean water 2.a 02e - ( 2et-(2ereturn to rinse used rinse water metal and k*4%.14- recovered metals to rocess water 3.a recovery 4.a 3.b 1. TOXICS USE REDUCTION. 1.8 Substitute a nontoxic or less toxic chemical. 1.b Change the process to create less toxic byproducts. 2. WASTE REDUCTION. 2.a Filter the process bath to extend bath lite and Increase product quality. 2.b Maximize the drip of process liquid back Into the process bath. 2.c Use spray rinses to reduce the amount of contaminated rinse water. 2.d Position tanks and splash boards to reduce drips and splashes down the drain. 2.e Use multi-tank countercurrent rinsing to Improve rinse efficiency. 21 Use conductivity sensors to better regulate process and water Inputs. S. RECYCUNG AND REUSE. (Segregate streams and separate the reduced volume of spent process and rinse with osmosis, evaporation, distillation, Ion exchange and/or electrowinning.) 8.a Close the loop: reuse purified water and metals In the same process. S.b Transport the metal top reuse In a different Industrial process and recycle the water In the same process. 4. DISPOSAL (Separate some toxic chemicals from waste water and dispose of wastes In a hazardous waste landfill, municipal sewage sludge, and S.F. Bay — avoid this option.) 4.a Reduced waste=techniques are still partly effective since most conventional treatment systems are equally or more efficient at smaller throughputs. 11 CLEAN SAFE JOBS A CBE REPORT amounts of metals, and reduced metal waste by an estimated 90% or more. (Judd et al., 1987; Cal EPA, 1992; Hulbert and Fleet, 1989; Crane, 1989; Wavrock, 1989; Rich and Kuster, 1989; and Foss, 1989) These waste reduction efforts saved these firms money. Acteron estimates water, sewer, and deionized water saved them more than $2,000 per month. (Burt, per. com., 1992) Closing the loop at another metal finishing shop saved an estimated $2,000 to $3,000 per month. (Foss,.1989) A U.S. Navy electroplating facility in Florida found closed loop recycling was cheaper,than treatment. (Civil Engineering ASCE, 1982) The closed loop system at Aeroscientific Corporation in Anaheim, California appeared to cost the same as conventional waste treatment and disposal in 1987, and was projected to save money as the cost of sludge disposal to landfills increases. (TRSI, 1990) Other estimates of cost savings can be expressed in terms of how long it takes to start making money on the firm's initial investment. Cray Research anticipated a two-year pay back for the closed loop copper recovery system at its printed circuit board facility. (Rich and von Kuster, 1989) A one year pay back was estimated for a copper recovery system for a plating facility. (Ibid.) Closed loop recycling of about 150 various nickel baths took an average of a year and a half to pay back for the firms. (Cartright, 1984) Reverse osmosis and recycling of nickel rinse and bath water was estimated to pay back in about ten months. (Rich and von Kuster, 1989) In Italy a distillation system that cut up to 95% of nickel waste from a plating shop was reported to pay back in less than three months. (Wavrock, 1989) Water savings alone are estimated to pay back within five years for metal finishers making extensive use of new rinse methods. (JRB, 1982) Cal EPA projects one year pay back periods for a sequence of measures to attain 90% reductions in metals discharges from metal finishers. (Cal EPA, 1992) According to the National Association of Metal Finishers Waste Minimization Committee, firms that reduce waste may realize cost benefits through improved quality control, lower chemical cost, lower inventory, less storage area; better product quality, lower water bills, lower sewer bills, lower material usage and chemical storage for waste treatment, lower hazardous waste disposal and liability costs, improved company standing in.the community, and other benefits. (Cal EPA, 1992) These economic benefits may become even more important as raw materials and waste disposal costs increase (Judd et al., 1987), and more hands-on experience is gained in smaller shops. For example, several printed circuit board and metal finishing firms use low-cost, "home-made" ion exchange and electrowinning to recycle metals and water (Ibid.; and Cal EPA, 1992). The California Environmental Protection Agency believes that these solutions may be achievable for less than $10,000 per shop. 12 CLEAN SAFE JOBS A CBE REPORT Ironically, the economic significance of these improvements in efficiency may be one reason why they have been a well-kept secret in a competitive industry. Cal EPA writes: "Within the last ten years, metal finishers have made substantial expenditures for waste treatment equipment. Competitive companies were eager for all other companies to incur this cost so that no one would have a competitive advantage. ... [M]any basic process techniques and equipment improvements are being developed-that provide substantial cost savings through energy efficient waste reduction technologies and strategies. Several of these techniques and improvements are low cost and easy to implement. ... However, as mentioned earlier, there is little incentive for the sharing of this technology within the industry." (Cal EPA, 1992. pages 11 and 12) Those who most clearly recognize the direct relationship between increasing industrial efficiency and decreasing industrial waste will be most competitive. • The costs and benefits of increased efficiency/reduced waste can be broadly estimated for industry and environment, and techniques exist to predict specific costs and pay backs for individual shops. INDUSTRIAL COSTS AND BENEFITS Adequate data are available to suggest reduced waste solutions are affordable for the industry overall. This is true despite accounting practices that hide the costs of industrial waste (TRSI, 1990; and OTA, 1986), and important differences between individual facilities. The table below summarizes nine estimates of the capital costs of 90% waste reductions ranging from approximately $10,000 per facility to $ 1.3 million per facility, and several estimates that these investments will pay back within three months to five years. (See Table for literature cited) The 100 companies causing the biggest copper and nickel discharges have total annual revenues of more than $ 2 billion, and at least some of these firms already spend an estimated one percent to four percent of revenues on waste management. According to this crude, simplified cost analysis, when spread over a seven year financing period, these capital improvements cost less than one percent of revenue, cost less than present waste practices, and begin making money in three months to five years. ENVIRONMENTAL BENEFITS In South San Francisco Bay, reductions in the pounds of copper and nickel wastes that industry puts into sewers are one crucial measurement of the 13 CLEAN SAFE JOBS A CBE REPORT environmental benefits of these industrial actions.3 The graph on the facing page shows the present total industrial copper and nickel discharge to the San Jose/Santa Clara sewage treatment plant on the left, and the deep cuts in this pollution that can be achieved by increased efficiency/reduced waste actions. The downward curve of reduced pollution is calculated by projecting that each industrial facility, starting with the biggest discharger, will reduce the number of pounds of copper and/or nickel it puts in the sewer by an average of 90%, using the proven, cost-effective solutions described in this report. This calculation shows that deep pollution cuts can be made quickly. A 90% cut in the biggest twenty discharges could cut total copper and nickel to nearly 8,000 pounds per year. In other words, immediate action by the biggest 5% of industrial polluters would quickly cut more than 40% of total industrial pollution. Similarly, if the 100 biggest:dischargers make the 90% metal waste reductions discussed in this report, total industrial copper and nickel pollution will be cut by 75%. If all 350 monitored industrial dischargers take these 90% waste reduction actions, their total discharge will, of course, be cut by 90%. POLLUTION PREVENTION AUDITS Unfortunately, there is too much variation in the initial costs shown on the facing page for firms to act with confidence based on the experience of other firms without first assessing their individual situations. Site-specific differences in process chemistry, limited floor space (Foecke, 1989), and the potential availability of new floor space as firms streamline operations or specialize (Burt, per. com., 1992) may drastically affect cost and pay back figures for an individual facility. This long-recognized need to explore such in-plant factors at specific facilities led to the development of pollution prevention audit techniques (OTA, 1986) that are now well demonstrated. (See eg., CBE, 1989; Kennedy/Jenks Consultants, 1991; and Rosenblum Environmental Engineering, 1991) The basic audit technique pinpoints the causes of waste in a specific shop, evaluates solutions like those discussed above, and provides specific cost, engineering, and cost-savings analysis to improve processes and operations, attract financing for capital improvements, and involve workers in waste reduction. In recent years a consensus has emerged in the Bay area. Industry and citizen groups now agree that these pollution prevention audit techniques should be applied. At the San Francisco Bay Estuary Conference convened under the Clean Water Act, industry, government and citizen groups agreed that industry should be required to perform pollution prevention audits. (San Francisco Estuary Project, 1992) 3 These actions would also reduce toxic pollution of municipal sewage sludge, increase options for sludge recycling, and reduce other environmental emissions and exposures as less toxic materials are transported, handled, and processed, among other environmental benefits. 14 CLEAN SAFE JOBS A CBE REPORT A simplified analysis suggests that capital for industrial efficiency should cost industry less than managing waste. Min. estimate Max. Capital cost of 90% waste reduction (b) $ 10,000 $ 1,300,000 Annual cost of seven year no-interest loan 1,430 1861000 Annual cost of these loans for 100 firms 143,000 18,600,000 Total revenues for biggest 100 dischargers (c) .2,168,000,000 Not available Annual cost of loans as a % of revenue 0.005% 0.9 % (d) Present waste mgt. cost as a % of revenues (e) 1 % 4 % When waste savings pay for investments (t) 3 months 5 years 16,000 Three quarters of the waste of key Total pounds .E industrial materials poisoning San >< of industrial Francisco Bay can be eliminated by nickel (grey) ''`' economically favorable and improvements at the 100 industrial copper(black) `'°`' s,000 facilities that waste the most copper released to and nickel down the drain. (a) Silicon Valley's biggest >< :::.}.. Future totals if proven waste reductions are done sewage plant in 1991 0 100 200 300 Number of facilities adopting all feasible waste reductions (b) TRSI, 1990; Cal EPA, 1992; Wavrock, 1989; Crane, 1989; and Judd et al., 1987. (c) Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992: Actual totals include data for only 75 of 100 companies. (d) Based on minimum revenue and maximum capital cost. (e) Judd et al., 1987. Based on a printed circuit board manufacturing survey. (f) Riche and von Kuster, 1989; Cartright, 1984; Wavrock, 1989; JRB, 1982; and Cal EPA, 1992. (a) Based on waste reduction levels that have been demonstrated by industry, and San Jose/Santa Clara Water Pollution Control Department pretreatment records. 15 j CLEAN SAFE JOBS A CBE REPORT • Many wealthier firms can afford to, but have not, financed increased industrial efficiency/reduced waste improvements. Some of the biggest companies that are also big dischargers can clearly . afford closed loop recycling in the short term, with cost savings in a few months or years. The pie chart on-the facing page breaks down the 100 biggest copper and nickel dischargers by annual revenues based on economic data reported in standard references. (Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992) The chart shows that many of these companies have revenues in excess of $10 million per year. For these firms, even the maximum4 pollution prevention investments shown in the table above would cost less than two percent of revenues, a cost that is comparable with the lower end of the range of existing waste management costs reported by Judd et al. (1987). Many of these firms may be polluting only because of short-sighted economic analyses. For these firms, the failure of environmental law enforcement is an important factor discouraging investment in the environment and the economy. . The U.S. Environmental Protection Agency has found that the City of San Jose is violating a second provision of the Clean Water Act (in addition to its violations of effluent limits and water quality standards as discussed in the introduction of this report) because the City has failed to adequately enforce the Clean Water Act "pretreatment program" requirements against industrial sewer dischargers. (EPA, 1991) San Jose has failed to impose proper "local limits" on individual industrial facilities, and instead allows too many of its dischargers to put too many total pounds of copper, nickel, and other toxics into its public sewers. (CBE, 1989; and CBE, 1990) Lack of firm limits on pollution encourages business to ignore the waste that signals the need to improve industrial efficiency. Even if those firms that can afford to invest in pollution prevention are aware of the cost savings that are going down the drain, without proper environmental law enforcement, they have apparently chosen to delay these investments. Failures in environmental law enforcement are a major barrier to investments in efficiency upgrades that could strengthen the local economy and protect the Bay. 4 Since costs are almost certainly smaller than the maximum capital cost for smaller firms (Judd et al., 1987; and Cal EPA, 1992), many or most smaller firms may be able to afford increased efficiency and reduced waste improvements as well. The data in the table above show costs may be smaller than the maximum cost by two orders of magnitude, and positive pay backs may exceed costs quickly. 16 CLEAN SAFE JOBS A CBE REPORT Economic reports on 75 of the 100 companies with the biggest copper and nickel discharges show that roughly half of these companies have annual revenues greater than $ 10 million. < $1 million - $5 million $10 million - > $100 million $5 million - $10 million Source: Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992. Note that this breakdown is based on the most recent annual revenue or sales records that were found for 75 of the 100 companies: many of the 25 financial records that were not retrieved may be for small businesses. 17 i CLEAN SAFE JOBS A CBE REPORT T • Environmental investments that increase the industrial efficiency of smaller firms supplying local high-tech "building blocks" will save jobs and increase competitiveness. A closer look at the 100 high-waste facilities reveals a dramatic split between big business and small business. The pie charts on the facing page show that two thirds of the printed circuit board firms and more than half the metal finishers report less than $10 million in annual revenues, but more than three quarters of the semiconductor firms report more than $10 million. None of the printed circuit board firms reported revenues in excess of $100 million, but 40% of the semiconductor and metal finishing firms. did. None of'the semiconductor firms reported revenues of less than $1 million, but nearly a quarter of the metal finishers did. In the printed circuit board and metal finishing industries, the market is split between "captive" shops owned by bigger companies and smaller independent "job" shops. (Judd et al., 1987) The full picture thus reveals a startling opportunity for environment and industry. As the biggest buyers of high tech "building blocks" manufactured by the printed circuit board and metal finishing firms (Ibid.),.wealthy computer and communications companies depend upon these smaller firms. Yet in spite of their importance to the business community, these smaller business sectors face a combination of stiff competition and small margins, and waste is particularly costly to them. Therefore, a program to increase industrial efficiency and reduce waste in smaller metal finishing and printed circuit boards firms could not only protect the environment, but significantly contribute to the economic health of Silicon Valley industry as a whole. Three factors interact to make the cost savings of pollution prevention most important to smaller printed circuit boards and metal finishing firms. First, saving the same ton of raw materials such as water and metals means more to a smaller firm with smaller revenues. Pollution prevention saved one such firm about $2,000 per month through water and sewer savings alone, an amount equal to 3% of revenues for nearly a quarter of the metal finishers on the chart, and equal to what these firms are estimated to spend on waste management according to Judd et al. (1987). Second, cutting the waste of raw materials improves margins to a greater extent for these firms because raw materials are a relatively large portion of their total costs. (Ibid.) Third, these large fixed costs combine with the boom-bust cycles of the printed circuit board and metal finishing industries to put the squeeze on smaller firms. (Ibid.; and Center for Neighborhood Technology, 1990) When sales drop, the printed circuit board industry's fixed costs (45%) and materials costs (40%) have drastic effects on small firms. (Judd et al., 1987) 18 Annual revenues for 75 of the 100 biggest copper and nickel dischargers show that small and mid-sized businesses with high-waste are concentrated in the printed circuit boards and metal finishing industries. Printed circuit boards < $1 million $1 - 5 million $25 - 100 million $5 - 10 million Metal finishers < $1 million > $100 million .:. :::<:> $1 - 5 million <. >:< $10 - 25 million $5 - 10 million Semiconductors $1 - 5 million > $100 million $5 - 10 million $10 25 million $25 - 100 million Source: Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992. Note that these breakdowns are based on financial records found for 75 of the 100 companies: many of the 25 financial records that were not retrieved may be for smaller businesses. CLEAN SAFE JOBS A CBE REPORT Improved industrial efficiency will protect local jobs at these metal finishing and printed circuit boards firms by reducing waste of costly raw materials and improving margins in these highly competitive industries. The high-waste printed circuit board and metal finishing shops assessed in this report- employ about 5,000 people. (Business Information Systems Inc., 1990; Database Publishing Co., 1992; and Gale Research Inc., 1992) Yet the firms' labor costs are reported to be as low as 15% of total costs. (Judd et al., 1987.) These firms are further clustered advantageously near the major computer and communications buyers of their products. With all this going for them, there is no reason to let these jobs go down the drain. As discussed above.in this report, the capital improvements that could make deep cuts in water and metals waste at these high-waste metal finishing and printed circuit boards firms are affordable to Silicon Valley industry overall. In addition, savings from reduced materials costs, improved product quality, reduced waste management costs and the like should recoup these investments and start making firms money in a matter of months to five years. Further, the economic benefits to big business of healthy local high tech building block manufacturing should not be underestimated. For example, computer and. communications firms buy about 65% of all printed circuit boards (Judd et al., 1987), and need new board designs integrated into their new products before these products can be marketed. Independent prototype shops, such as Trend Circuits in Fremont, California, clearly play a local role in getting new high tech innovations to market quickly. These interdependent parts of Silicon Valley's electronics industry cannot afford to fail to work together, and cut waste for their own competitiveness. Retaining these manufacturing jobs would also avoid negative economic and social repercussions on the overall community. (Center_ for Neighborhood Technology, 1990) Cutting industrial toxic waste would help to protect commercial and sport fishing jobs that depend upon a healthy San Francisco Bay, protect public health, and save declining species of aquatic life and wildlife. Additional jobs would be created in constructing the process improvements needed to maximize industrial efficiency. Investments to increase industrial efficiency and reduce toxic raw materials wastes in metal finishing and printed circuit board manufacturing firms are good investments overall. 20 CLEAN SAFE JOBS A CBE REPORT A four-point technical and financial assistance proposal to prevent pollution and retain jobs in South San Francisco Bay. We urgently need substantial reduction of toxic metal releases from the South Bay metal finishing and printed circuit board manufacturing industries to stop poisoning San Francisco Bay, improve the economy, and retain local manufacturing jobs. CBE recommends the following technical and financial assistance proposal for clean safe jobs in South San Francisco Bay: • 1. Fund pollution prevention audits and business plans that recommend the best process changes to eliminate waste water pollution at the source. Cities operating sewage treatment plants ("cities") should fund pollution prevention audits and business plans that recommend a sequence of pollution prevention and closed-loop recovery actions. These actions will help firms reduce copper and nickel releases to sewers and attain costs savings that provide positive pay back on investments. This service should be offered to all metal finishing and printed circuits board manufacturing firms that discharge process wastes to sewers with a focus on firms with larger copper and nickel mass discharges. • 2. Provide technical experts to help ensure that the pollution prevention business plans are successfully carried out. The cities should fund technical experts agreed to by industry, government and the public to conduct the audits and develop pollution prevention business plans that attract the investments firms need to implement these recommendations and achieve these.benefits. • 3. Help smaller firms finance their pollution prevention business plans through loan guarantees, buy down of interest rates, or other actions. The cities should .establish and organize funding for a "loan guarantee pool" to provide firms that qualify with loan guaranties, interest rate buy-downs, rebates on water bills, and/or other assistance designed to provide low- or no-cost financing to implement the pollution prevention business plans. Firms that qualify must promise to stay in town or reimburse the community for the assistance. Firms in the top 20% of industrial copper or nickel mass dischargers will implement 90% cuts in these metals releases to qualify. • 4. Ensure worker retraining and involvement in industrial efficiency/waste reduction improvements. Firms receiving assistance will help assure successful pollution prevention and jobs retention by providing worker retraining and involvement in the development and operation of new practices. Please ask your Mayor and City Council and any professional organizations or trade associations that you belong to to endorse this proposal. Call CBE at 415/243-8373 to help us win jobs and environmental health in the South Bay. 21 i CLEAN SAFE JOBS A CBE REPORT Literature cited. Belliveau and Grove, 1987. The Synergistic Environmental Impacts of Fresh Water Diversions and Toxic Pollution on South San Francisco Bay. Citizens for a Better Environment,San Francisco,CA. Burt,per.com., 1992. Patrick Burt,President,Acteron,Redwood City,CA. Per.com. with Greg Karras, Director, Clean Bays and Coastal Waters Program, Citizens for a Better Environment. April 1992 and August 17,1992. Business Information Systems Inc.,1990. Santa Clara County Commerce and Industry Directory 1990/1991. San Mateo,CA Cal Dept. of Finance, 1989. Population Estimates of California's Cities and Counties,January 1, 1988 to January 1, 1989. Cal EPA, 1992. Application for "National Industrial Competitiveness Through Environment, Energy,and Economics"Grant. Proposal 2:Cost Effective Methods of Waste Minimization for the Metal Finishing Industry. Submitted to the U.S. Department of Energy and Commerce, and the U.S. Environmental Protection Agency. California Fishing Regulations. State of California, Fish and Game Commission. California Hunting Regulations. Part III (Waterfowl). State of California, Fish and Game Commission. Cartright, 1984. An Update on Reverse Osmosis for Metal Finishing. in Plating and Surface Finishing, April 1984. Center for Neighborhood Technology,1990. Sustainable Manufacturing,Saving Jobs, Saving the Environment. by Valjean McLenighan. Center for Neighborhood Technology,2125 West North Avenue,Chicago, IL CBE, 1989. Industrial Toxics Dischargers in South San Francisco Bay. A report by Citizens for a Better Environment,Report No.89682. CBE, 1990. Hidden Polluters of California's Coast. A Preliminary Analysis of Industrial Toxic Releases into California's Coastal Environment Through Public Sewers. A report by Citizens for a Better Environment, Report No. 90-2. CBE, 1991. Petroleum Transportation and Poison Runoff:Gasoline,Asphalt,and Other Petroleum Causes of Toxic Storm Drain Pollution in South San Francisco Bay. July 1991. Citizens for a Better Environment,San Francisco,CA. CBE, 1992. Comments on Behalf of Citizens for a Better Environment(CBE)before the Regional Water Quality Control Board, San Francisco Bay Region, regarding the Draft Final Report Prepared in May 1992 for the Board by S.R. Hansen &Associates,Concord,CA Entitled Development of Site Specific Criteria for Copper For San Francisco Bay. Submitted July 9, 1992. San Francisco,CA CH2M Hill, 1989. City of San Jose Pollutant Sources Evaluation (Provision 5B),San Jose/Santa Clara Water Pollution Control Plant, Permit Assistance Program. Submitted by San Jose to the regional Water Quality Control Board, San Francisco Bay Region. 22 CLEAN SAFE JOBS A CBE REPORT Civil Engineering-ASCE, 1982. New Evaporation Process: Key to Zero Discharge for Electroplaters. August 1982. f CLEAN South Bay, 1992. Request for Regional Water Quality Control Board Action Reducing Copper and Selenium Pollution of the South Bay from Water Supply Practices and Copper-based Biocides. June 4, 1992 petition by CLEAN South Bay,a coalition of-environmental, fishing,and business organizations including Citizens for a Better Environment,requesting Regional Board Action,and supporting documentation and analysis. Oakland,CA. Crane, 1989. Recovery of Metals in Circuit Board and Metal Plating Manufacturing. in"Metal Waste Management Alternatives: Minimizing, Recycling, and Treating Hazardous Metal Wastes" Symposium Proceedings. California Department of Health Services,Toxic Substances Control Division, Alternative Technology Section. Database Publishing Company, 1992. 1992 California Manufacturers Register. Newport Beach,CA Davis et al., 1991. Status and Trends Report on Pollutants in the San Francisco Estuary. San Francisco Bay-Delta Aquatic Habitat Institute. Richmond, CA. ECA,Inc.,1991. Investigation of un-perntitted sources of copper and nickel in San Jose/Santa Clara WPCP influent. Prepared for San Jose by EOA Inc.,1410 Jackson St.,Oakland,CA. EPA,Decision of the United States Environmental Protection Agency ori Listings Under Section 3040) of the Clean Water Act Regarding the State of California. EPA Region IX. Decision issued September 28, 1990. EPA,1991. 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