Performance-Based Standards and Best Management Practice Programs

Best Management Practices (BMPs) are an effective discharge control mechanism for the photo imaging industry. The photo industry is somewhat unique in that it is composed of large numbers of businesses and health care facilities that discharge small volumes of effluents. The combined discharges to a publicly owned treatment works (POTW) from a large number of small dischargers can contribute as much loading of specific pollutants as some significant industrial users (SIU). When faced with regulating these dischargers using numerical pretreatment limits, a POTW is faced with an administrative problem.A BMP-based program can offer an improved management approach to this situation. These non- numeric technology-based standards are more acceptable to small facilities. Small facilities generally do not have staff dedicated to environmental issues and maintaining compliance. To achieve greater compliance, requirements have to be simplified and standardized. BMPs can also benefit POTWs by reducing the administrative burdens. Dischargers can be required to submit simple reports and therefore document compliance to the city, rather than the city conducting an inspection. The potential increased acceptance translates into better overall compliance rates and environmental benefits through reductions in loading to the POTW. BMPs can be easily applied across a wide range of dischargers to avoid the headaches associated with permitting a large number of small facilities.The Code of Management Practice for Silver Dischargers (CMP) was jointly developed by The Silver Council and the Association of Metropolitan Sewerage Agencies (AMSA). It is an industry-wide performance-based standard for users of silver-based imaging materials. The program establishes categories based on the volume of flow. Each category has volume based recovery goals which are based on best available silver recovery technology. Compliance is based on meeting that goal plus reporting requirements.In 1997, EPA provided a matching fund grant to AMSA (working with the Silver Council) to implement and study the effectiveness of the CMP in five cities across the United States. One of the primary goals of the study was to verify that the CMP can provide environmental benefits while minimizing the economic impact of pretreatment activities on both the discharger and the POTW.The study documents that the CMP does result in economic savings for a POTW when compared to instituting individual permit programs. The study also documents environmental benefits as reaching 60 percent reductions in their silver loading to the treatment plants.Administrative hurdles continue to exist within the regulatory community. Until recently, regulatory guidance has been unclear as to the acceptability of BMPs when used in place of local limits. Without clear direction from EPA headquarters, regional and state water quality staff are hesitant to approve the use of BMPs in place of numerical limits. Recent efforts to streamline pretreatment regulations show promise, but progress in adopting such changes has slowed due to staffing issues.