Every state in the country has different permits to enforce the Environmental Protection Agency (EPA) Clean Water Act (CWA). Several states even have specific permits assigned to industry sectors. In California, for instance, the Industrial General Permit (IGP) is issued by the State Water Resource Control Board (SWRCB) and covers most manufacturing, materials handling and recycling facilities. Additionally, areas in California’s Santa Ana Watershed have specific requirements for scrap metal recyclers.

In several recent discussions, the SWRCB has indicated that future IGP inspections will be more detailed. In particular, the handling of miscellaneous, nonstormwater liquids, as well as handling and controlling exposure to stormwater by the metals themselves, were noted as critical areas of emphasis.

In California, the IGP requires permit registration documents, required sample data and compliance documents to be reported through a public system. Therefore, it is critical that uploaded documents accurately reflect the standard operating procedures on the permitted facility. It’s also important that facilities maintain clean and managed facilities.

Litigation pressures

Using tools like Google Earth or Bing, environmental organizations (e.g., Heal the Bay, Coast Keeper, Surf Rider and others) are able to virtually “visit” multiple facilities from the comfort of their desktops. Examples of this type of “inspection” now abound in legal briefings. The image above is an example of photographs that could be used in legal briefings to support a case against improper stormwater management of a facility in Southern California. Images like this are freely available on the internet.

The 60-day notice of intent to sue in this instance included photos similar to the photo above to demonstrate how the site “failed to develop and/or implement best management practices (BMPs) that achieve compliance with best available technology economically achievable and best conventional pollutant control technology (BAT/BCT).”

The filing specifically states, among other issues, that:

• “Photographs show a lack of adequate BMPs at the facility, including large piles of scrap with no covering or containment.”
• “The facility is paved and littered with debris and stained from stormwater pollutants, including oil.”
• “Sources of pollutants at the … facility are numerous, including but not limited to: scrap metal ferrous and nonferrous outdoor storage areas, scrap metal, miscellaneous machinery, obsolete equipment and used appliances, piles of turnings and cuttings; and on-site material handling equipment and forklifts. Pollutants associated with the … facility include but are not limited to: toxic metals, such as copper, iron, zinc, lead, cadmium and aluminum; petroleum products, including oil, fuel, grease, transmission fluids, brake fluids, hydraulic oil and diesel fuel; chemical admixtures, battery fluids, refrigerator and other appliance fluids, acids and solvents; total suspended solids and pH-affecting substances; and fugitive and other dust, dirt and debris.”

Although several statements provided in the suit were largely conjecture, such conjecture has proven to be effective, resulting in large fines and settlements, some exceeding $100,000.

Cost-benefit analysis

When selecting appropriate stormwater controls for a facility, owners and operators should conduct a cost-benefit analysis. For example, for the small site mentioned previously, it may make more sense to build a 25- to 30-foot tall roof for the site rather than to invest in lifetime operations and maintenance costs for implementing stormwater treatment controls for a suite of chemical constituents (metals, oils, solvents, sediments, oxygen-demanding organic species, etc.). To treat toxicants, a treatment train of appropriate treatment control unit operations and processes must be appropriately designed, installed and maintained as documented in previous studies developed for the EPA.

An appropriately sized, multiple-barrier treatment control system likely would contain trash control, sedimentation and a filter system with a series of ion exchange media followed by sorption media. These combined systems likely would cost $50,000 to $100,000 and would create an annual maintenance fee of $10,000 to $30,000. The price does not linearly correlate with property size, but costs increase as facilities get larger with larger quantities of stormwater requiring treatment.

Collecting all runoff water in large tanks to be hauled off-site to a liquids waste receiving location may be another alternative.

With the California IGP, a facility moves up in compliance level from one year to the next if it continues to exceed allowable levels. After a first year of exceedances, the facility must have a qualified industrial stormwater pollution prevention plan (SWPPP) practitioner, or Qualified Industrial Storm Water Practitioner (QISP), develop a plan for addressing the issues. QISP certification requires more than 40-hours of online training provided by the state and an eight-hour in-person training, along with two exams. This plan may include structural and nonstructural (e.g., operational) BMPs.

Following a second year of exceedances, the facility becomes a Level 2 facility and then must have a professional engineer design structural treatment controls to address the issue or provide a justifiable cost-benefit assessment if the capital improvements to meet the numeric levels cannot be implemented within the next year. In either case, a plan must be developed for meeting levels in the future.

Compliance options

This scenario creates quite a dilemma for facility owners. What should an operation do to comply with regulations and avoid costly legal fees and fines?

Using tools like Google Earth or Bing, environmental organizations (e.g., Heal the Bay, Coast Keeper, Surf Rider and others) are able to virtually “visit” multiple facilities from the comfort of their desktops.

Operators have several options:

• Do nothing (which is not recommended). You could try to fly under the radar and hope that you aren’t fined or sued. The costs of doing this are:

1. $0 (if you’re very lucky);
2. up to $10,000 per day (if the regional board decides to apply the full penalties allowed); or
3. $10,000 to $100,000 (or more if you are sued).

• Build a roof to cover your facility. Hire an engineer to design the structure, get a building permit and cover your facility so rainwater does not enter your industrial work areas. This apporach often is the best alternative for small yards.

1. Costs for roofing vary by robustness in design. Simple tarp-style covers may suffice in some cases, pre-engineered hangar-style fabric covers are available and brick and mortar walls and roofing can be used. It is best not to use a galvanized roof as they can leach zinc and other heavy metals.
2. Compliance costs are only $200 per year for a No Exposure Certification once there is no exposure to stormwater.

• Collect all the stormwater from your facility in storage tanks/vaults to be hauled off-site by a disposal company. This option is limited by on-site spatial constraints for the storage tanks (above or below ground) and by the costs of the storage facilities.
• Collect stormwater and treat it to meet the standards listed in the IGP. This option is limited by spatial constraints, capital costs for new facilities and on-going operations and maintenance costs for the treatment controls (may include routine vault sediment/debris removal or replacement of filter media). Larger facilities should strongly consider this method as it may also provide long-term cost advantages.

The recommended alternatives all come with additional costs; but, with proper planning, most facilities can find a way to avoid fines and lawsuits. Implementing one of these alternatives also lets an operation reposition itself as a safe, clean and respected industry leader that values the environment and does its part for the community and the economy.

The author is with SCS Engineers, San Diego. He can be reached by email at cjones@scsengineers.com.

Founded in 1912 by H. Berger, who collected scrap using a horse and wagon, Berger Recycling, based in Pawtucket, Rhode Island, has grown into a full-service recycling firm. Today, Berger Recycling operates a modern, automated facility and provides turnkey solutions for collecting and purchasing recyclables in Rhode Island, Massachusetts and Connecticut. The company specializes in scrap metal, paper, electronics, plastic, insulated wire, batteries, textiles and new paper rolls.

Berger Recycling is still owned and operated by the third and fourth generations of the Berger family. The company has been recognized as the United States Small Business Administration Family Owned Business of the Year for the Rhode Island and New England region.

Berger Recycling first partnered with M&G Materials Handling Co. in 2005 when it was time to purchase new material handling equipment for its operation.

Headquartered in East Providence, Rhode Island, M&G Materials Handling Co. supplies material handling equipment to the southern New England area. Established in 1966, M&G Materials Handling serves customers in Pawtucket, Cranston, Woonsocket and Warwick, Rhode Island, and in Taunton, New Bedford, Attleboro, Brockton and Rehoboth, Massachusetts.

Challenge

As a scrap metal and recovered paper facility, Berger Recycling suffered from two material handling issues that resulted in extended periods of downtime. The first problem was that the dust created by scrap paper interfered with the transmissions of the company’s lift trucks. The second issue was brake contamination. Berger Recycling’s scrap, corrugated and paper products are strapped together with baling wire. The baling wire can slip off of the product and, if left on the ground, can become wrapped around lift truck axles and shear brake lines.

Aware that its lift trucks weren’t performing to its requirements, Berger Recycling reached out to Ken MacDonald at M&G Materials Handling for assistance when shopping for new lift trucks for its operation.

Solution

After meeting with Berger Recycling and assessing the company’s lift truck needs, M&G Materials Handling paired the recycling company with 6,000-pound-capacity Yale Veracitor GP060VX lift trucks.

“The sealed bearings and wet disc brakes on the Veracitor eliminated our issue of baling wire damaging or shearing the braking system,” says Adam Sinel, vice president of operations, Berger Recycling. “I am also proud to say that our Veracitor has never overheated.

“The Veracitor’s features are absolutely imperative to keeping our business up and running—and the fact that they come standard helps our bottom line,” he adds.

The lift truck’s sealed alternator eliminated dirt contamination that could cause damage, while its heavy-duty Combi-Cooler radiator prevented corrugated dust from entering the machine’s air system.

The vented hood on the GP060VX created less of a vacuum pull off the undercarriage, resulting in less paper and scrap contaminant draw and increasing the amount of clean air brought into the engine. The Veracitor also was equipped with a high-air intake and precleaner to reduce pulling in dirty or contaminated air. This feature is designed to help extend engine and filter life while increasing fuel economy, Yale says.

The Veracitor’s Techtronix transmission, with its Controlled Power reversal feature and smooth electronic inching, greatly reduced Berger Recycling’s tire costs. The standard Auto Deceleration System also helps extend brake life by automatically slowing the truck when the accelerator pedal is released, minimizing brake usage requirements and reducing overall brake maintenance costs, the manufacturer says.

“After utilizing various lift truck brands, we realize that these features help minimize tire spin, which increases their life span,” Sinel says. “The Veracitor has dummy-proofed itself by not allowing operators to throw the lift truck from forward to reverse—improving the lift truck’s overall longevity.”

Impact

Throughout their partnership with M&G Materials Handling, Berger Recycling has trimmed its operating costs.

“Since our partnership with M&G Materials Handling Co., our operating costs have been substantially reduced,” Sinel says. “We have not incurred the expenses that we did with other lift truck suppliers. For example, our previous lift truck went through three transmissions in a six-month period.

“I am confident that M&G Materials Handling Co. is looking out for the best interests of my company, associates and customers,” he states.

This feature was submitted by Yale Materials Handling Corp., Greenville, North Carolina. More information is available at www.yale.com.

Check valves and flashback arrestors are safety devices for protecting workers using oxyfuel cutting and welding equipment. A check valve is a device that is designed to prevent the unintentional backflow of gases. A flashback (flame) arrestor is a device that prevents the propagation of a flame upstream. Note that these devices reduce the volume of gases available at the tip/nozzle.

Nature of the hazard

Always be sure enough fuel is in both cylinders to complete the operation before starting a job. Reverse flow of a gas generally happens when one cylinder goes empty during operation, creating an imbalance of pressure in the system. A clogged or blocked tip also can cause a backflow. An extremely hazardous situation can develop when oxygen and fuel gases are mixed inside the hoses. Reverse flow check valves alone will not stop a flashback in the system. When conducting oxyfuel cutting and welding operations, operators can experience backfires or flashbacks.

A backfire is defined as the momentary recession of the flame into the torch, potentially causing a flashback or sustained backfire. It is usually signaled by a popping sound, after which the flame may either extinguish or reignite at the end of the tip. The user hears a “pop,” and the flame is extinguished. This can happen at high gas exit velocities at the nozzle/tip or if the nozzle/tip gets too close to the work piece. The flame may reignite automatically, or the use of an igniter may be necessary. This is not normally a safety concern and, in fact, many manufacturers induce backfires during design and production tests to ensure flame integrity of torches and tips.

A sustained backfire is defined as the recession of the flame into the torch body with continued burning characterized by an initial popping sound followed by a squealing or hissing sound, potentially burning through the torch body.

A flashback is defined as the recession of the flame through the torch and into the hose, regulator and/or cylinder, potentially causing an explosion. This is a potentially hazardous situation, particularly if the flame reaches the hoses where an explosion would result in rupture or separation of the hose. A flashback is generally caused by the reverse flow of gases upstream into the hoses or other equipment. This is usually the result of: 1) improper shutdown and/or startup procedures; 2) allowing cylinder pressures to become too low; or 3) a check valve that is not functioning properly.

As with any cutting or welding operation, workers need to be aware of their surroundings where work is performed. Always have approved fire extinguishers nearby and have all personnel trained in their proper use. Flashbacks can damage equipment and cause injury to nearby workers and equipment. Proper workplace precautions, such as barriers and other protections, should be used to minimize fire hazards and injury.

How to avoid the hazard

Operators can avoid backflows and flashbacks by following these suggestions:

• Equipment with integrated check valves and/or flashback arrestors is available.
• Check valves and/or flashback arrestors can be added to existing equipment. Properly maintained and operated systems are safe.
• Inspect the system before use, repairing or replacing defective or damaged parts.
• Have only qualified people make any needed repairs.
• Be sure enough gas is in both cylinders to complete the job.
• Follow the manufacturer’s recommended procedures for proper startup and shutdown of the equipment used.
• Don’t allow the tip to touch the work.

Flashback arrestors and check valves are not intended to replace proper practices for safe operation. They can provide an increased level of protection in addition to the manufacturer’s recommended operating procedures. Check valves and flashback arrestors should be installed at the location specified by the manufacturer. Manufacturers have begun incorporating flashback arrestors and check valves as a standard item with all of their torches sold.

“AWS Safety and Health Fact Sheet No. 28” (September 2013) is adapted with permission of the American Welding Society (AWS), Miami. Please visit www.aws.org/standards/page/safety-health for additional safety resources, including a free download of the American National Standards Institute (ANSI) “Z49.1:2012: Safety in Welding, Cutting and Allied Processes.”

Balayage. Law of color. Level system. Patch test. Did you recognize any of those terms? Presumably they seem foreign to you because they are used in the hair coloring industry.

That’s how many Americans feel when curbside recycling programs—and the terms used to describe them—are launched in their communities. Terms such as single stream and commingled and acronyms such as MRF (material recovery facility) and MSW (municipal solid waste) are tossed around like recyclables moving along a MRF’s conveyor belt.

Yet, a recent study revealed that just 11 percent of Americans recognize the term “single stream,” Keep America Beautiful’s Senior Vice President of Recycling Brenda Pulley told attendees at WasteExpo 2016, held in Las Vegas June 3-6. Keep America Beautiful is a Stamford, Connecticut-based national nonprofit that, among other goals, strives to inspire and educate people to take action to increase recycling.

“If you really want people to buy into this, don’t use a nebulous term as single stream,” Pulley said.

Recycling as routine

Most people in the recycling industry agree that recycling needs to become habit for Americans. Making recycling a routine activity among households is a target many across the supply chain—from retailers and brand owners to converters and recyclers—want to hit.

“Too many” large communities remain without curbside recycling programs or have opt-in service with low participation, says Cody Marshall, technical assistance lead for The Recycling Partnership, Falls Church, Virginia. The Recycling Partnership is a nonprofit with members who work together to make recycling stronger and to recover more materials for use in manufacturing. Since the start of 2015, The Recycling Partnership says it has helped to engender $21 million of new recycling infrastructure through grants and technical support, affecting more than 2 million households.

Marshall says too often residents automatically receive garbage service with a convenient container and an easy schedule, but they need to jump through special hoops to begin curbside recycling service.

“Understanding that recycling is a service and not a money-making venture for cities is the first step,” Marshall says. “It takes capital and a strong operations budget. If cities continue to look at curbside [recycling] as this ‘added expense’ and not as a part of their overall solid waste management solution, we will have a hard time improving curbside programs.”

He adds that establishing partnerships and maintaining meaningful relationships—including with cart vendors, MRFs and haulers—is key to encouraging recycling among residents. In addition, offering incentives for recycling and, in some cases, negative feedback helps to lessen contamination in recycling containers.

Communities across the country are testing various programs designed to increase recycling rates and participation.

Negative is necessary

“Folks are doing a lot of different things,” when it comes to curbside recycling programs, says Jason Hale, The Recycling Partnership’s communication director. Programs range from “dirty dozen” lists that simply highlight the top 12 items not to include in recycling containers to leaving personalized notes on carts.

These notes, tags or stickers can be positive, i.e., acknowledging good recycling behavior, or negative, such as pointing out incorrect material in the recycling cart. Hale says residents respond well to negative tags and notes at first, with the vast majority receiving just one warning before taking action to correct their behavior.

“When they get this personalized message, even if just one box is checked, it’s still fairly personal by saying, ‘We looked in your bin and saw a problem,’” he says.

Hale continues, “We want them to be able to recycle without thinking about it. That’s the idea: you boost their confidence, remove all the barriers to entry, and then it’s a matter of course. I brush my teeth. I put the container in the recycling. I make my kids breakfast.”

The trick, Hale says, is that negative reinforcement works only in the short term. For long-term behaviors to stick, people prefer the carrot—or positive reinforcement—over the stick.

The most successful curbside programs combine outreach and education in addition to feedback, he says.

Hale suggests pairing awareness messaging along with behavior triggers (such as a refrigerator magnet detailing what is acceptable in curbside recycling bins) and feedback to residents (such as an “oops” tag on carts with unacceptable materials or a positive tag acknowledging when a resident recycles well).

Enforcement without education is frustrating and disenfranchising, he says.

Waste Management Inc. (WM), Houston, has created cart tags to thank residents for recycling right. WM also uses tags to remind residents what should go inside the recycling cart. When combined with other efforts, these tags have helped to decrease contamination levels, says Janette Micelli, corporate communications for WM.

In 2014 WM launched its “Recycle Often. Recycle Right.” campaign, a customizable research-based recycling education program that was developed based on national best practices and provides ready-to-use tools, resources and guides for any municipality, Micelli says.

In Elgin, Illinois, a historic river town 35 miles west of Chicago, a contamination reduction pilot program was initiated in late 2015 to address the area’s 40 percent contamination rate, says Micelli. Plastic bags and bagged recyclables, as in most cities across the U.S., topped the contamination list.

Micelli says a number of initiatives, both positive and negative, were used in Elgin, including customized letters sent via mail; enforcement tags left on contaminated carts; updates to community websites and social media pages; a promotional recycling video featuring the city’s mayor; a “no plastic bags” message on the city’s 331 recording; and promotions at community events. After eight weeks of tagging, a second audit was conducted, and contamination rates decreased by up to 20 percent.

During the second phase of the pilot program in Elgin, high repeat offenders were targeted, and carts were not serviced if contaminated, which resulted in more than 40 percent of these offenders cleaning up their carts after only one time of not being collected.

“It’s not a one-size-fits-all approach as those don’t tend to go too well, especially as you travel across different parts of the country,” Micelli says of Recycle Often. Recycle Right. “It’s about changing the language we’re using when we’re talking to our customers and getting back to basics with how you communicate with [residents].”

Positive pays off

Cart tagging has proved to be an effective strategy, says Javier Flaim, CEO of Recyclebank, the New York City-based operator of an incentive-based recycling program.

Flaim says Recyclebank is a strong advocate for cart tags, preferring to use a positive message whenever possible. “Instead of scolding residents, we have found that it can be more effective to give them a pat on the back for a job well done,” Flaim says.

On the other hand, Flaim also recognizes the need for negative feedback. When education and incentives alone are not enough to spur sustained behavior change, Flaim says penalties can then be used to close the gap.

“If cities continue to look at curbside [recycling] as this ‘added expense’ and not as a part of their overall solid waste management solution, we will have a hard time improving curbside programs.” – Cody Marshall, The Recycling Partnership

“We don’t like to employ negative reinforcement if we don’t have to, but we also realize that it is sometimes necessary for addressing certain costly problems, like recycling contamination,” he says.

For more than 12 years, Recyclebank has worked with municipalities, haulers and third-party providers to make recycling relevant, educational and impactful—enough to create lasting habits around recycling, Flaim says. In 2015, Recyclebank partnered with 300 U.S. communities with more than 3 million members who recycled a combined 1.6 billion pounds of material and earned $63 million in rewards. Recyclebank members earn points for recycling, participating in events and taking quizzes or pledges that can be redeemed for discounts or products.

“More than anything else, experience has taught us that our success is directly correlated to how well we collaborate with our municipal clients,” Flaim says.

He says leveraging data and insights is the most critical element to tailoring the Recyclebank platform to meet the unique needs of each municipality.

“Different residents require different levels of education” based on how much recycling knowledge they have, says Flaim. As a result, Recyclebank customizes content to drive desired behavior in each city, focusing on incentivizing residents to encourage recycling.

Over the years, he says, Recyclebank’s methods of communicating to residents have increased drastically, as technology and its program have evolved. Flaim says Recyclebank has a variety of channels, including mail, email, social media or in-person discussions at a community event, to reach every resident in a community. Connecting with residents through multiple platforms has proved worthwhile.

“We strongly believe people want to make a difference in their communities, but many often need a little nudge to take action,” says Flaim. “Rewards and incentives act as that often-needed nudge.”

The author is associate editor of Recycling Today and can be contacted via email at mworkman@gie.net.