1. The National Metal Finishers Strategic Goals Program (SGP) formerly the Common Sense Initiative, CSI The Strategic Goals Program for Metal Finishers: New Strategies for Success Winston-Salem, N.C. Dec. 12, 2000 Julie Woosley N.C. Division of Pollution Prevention and Environmental Assistance (DPPEA)

2. Common Sense Initiative Joint EPA/industry/stakeholders (1993) Industry sector focus Six industry sectors selected Metal Finishing - Most developed initiative Seeking 80 percent participation by 2002 1998: Strategic Goals Program (SGP)

3. Federal Categorical Regulation Consistent nationwide Apply to six metal finishing operations Most Common 1. Electroplating 2. Coating (phosphating, chromating) Sample for seven metals and CN once per six months Many frustrating aspects MP&M (Metal Products and Machinery) Effluent Guidelines will change current regulations Metal Finishing Regulations (40 CFR Part 433)

4. Strategic Goals Program Reinvent Environmental Protection - Seeking a more flexible, cost effective and environmentally effective approach to regulations tailored to the needs of both industries and stakeholders. 1. Smarter 2. Cheaper 3. Cleaner Environmental Regulation

5. Means Municipality signs up as participant Local industries sign up as participants and commit to series of goals Municipalities offer regulatory flexibility or other incentives to industries for progress toward goals State provides supporting role

6. CSI / SGP Goals Cleaner Cheaper Smarter Environmental Performance

7. “Cleaner” - Reduction in hazardous emissions & exposure 90% reduction in organic TRI emissions 50% reduction in metal releases to air & water 50% reduction in land disposal of hazardous sludges Reduction in human exposure to toxics (indoor and ambient) Goals:

8. “Cheaper” - Increased economic payback and decreased environmental costs - 50% reduction in cost of unnecessary permitting, reporting and monitoring - Fewer long-term liabilities - Economic benefit from more efficient (cleaner, smarter) system Goals:

9. “Smarter” - Improved resource utilization 98% utilization of metal on product 50% reduction in water purchased (1992) 25% reduction in facility-wide energy use Goals:

10. Benefits of SGP Industry Operational flexibility Less resource-intensive regulations Technical assistance Improved public image Opportunity to change regulatory system POTW Reduced pollutant loading Implement more efficient permitting system Improved relations with industries Opportunity to change regulatory system

11. North Carolina’s Action Plan  Outreach Technical assistance - DPPEA Compliance assistance - DPPEA Meet with IU’s - Julie  Positive recognition of participants  Pretreatment analysis and support - DWQ  Increased enforcement of “rogue” firms – DWQ / EPA  Energy assessment – DPPEA / NCSU  Utility bill insert – DPPEA  EMS Workshops – EMS and Government Jan. 31, 2001: 8 a.m. – noon, Gastonia, N.C.

12. SGP Current Status Statesville - 13 platers – 6 participating - incentives granted for progress on goals Raleigh - 10 platers – 6 participating – 4 new! - incentives granted for progress on goals Charlotte -19 platers – 2 participating - mentoring and public recognition program Gastonia -? Platers – 2 participating  16 North Carolina participants; 448 total nationwide

13. Industry Incentives Proposed Reduced monitoring frequency City Reduced metals monitoringCity Eliminate metals monitoringEPA Reduced monitoring costsCity No Charge BDL City Volume of dischargeEPA PhosphatersEPA Reduced enforcementCity Technical/regulatory assistance (DPPEA)State Public RecognitionCity/State MentoringCity

14. Observations to Date EPA – Limited assistance - On-line Toolbox, Contacts Emphasis on continual improvement  EMS Recruit more metal platers – 80% goal – that’s YOU! Great opportunity for reduced pollutant discharges and less resource-intensive regulations Improved relationship b/w POTW’s and IU’s Problems identifying incentives to offer – input? Worksheets due! – 1992 baseline is flexible

15. New Information for SGP Participants: EPA MP&M Guidelines: Metal Products and Machinery Effluent – due out October 2000 TRI (Toxics Release Inventory) data - nitrates reporting Energy conservation Calculation/worksheet training Incentive identification and assistance?  Workshop TODAY

16. TRI Reporting of Nitrates

17. The Emergency Planning and Community Right to Know Act (EPCRA, Title III of SARA, the Superfund Amendments Reauthorization Act, 1986) Section 313: Release Reporting Requirements, Toxic Chemical Release Inventory Rule, 1988. Purpose: To inform government officials and the public about releases of toxic chemicals into the environment: air, water and land.

18. TRI Reporting of Nitrates See EPA publication, 745-R-99-008: TOXICS RELEASE INVENTORY List of Toxic Chemicals within the Water Dissociable Nitrate Compounds Category and Guidance for Reporting www.epa.gov/tri  Metal finishers that use nitric acid may be creating nitrates that have to be reported!

19. Who Must Report SIC Codes 2000-3900 (manufacturing) A facility with 10 or more full-time employees A facility that manufactures, imports, processes or otherwise uses any of the toxic chemicals listed on the EPCRA section 313 list in amounts greater than the “threshold” quantities - nitric acid and dissociable nitrate compounds (must report BOTH!)

20. Thresholds  If a facility manufactures, imports or processes any of the listed toxic chemicals (includes “coincidental manufacture”): - 25,000 pounds/toxic chemical or category over the calendar year If a facility otherwise uses any of the listed chemicals: - 10,000 pounds/toxic chemical or category over the calendar year

21. Small Business Compliance Policy  Pardon Mechanism for Small Businesses(<100 employees)  Allows business to state they were not aware of the requirement and will now comply. EPA will eliminate or reduce civil penalties if the business:  Discovers the violation voluntarily  Discloses the violation fully and in writing to EPA or state within 21 calendar days  Corrects the violation with the shortest practicable period of time

22. More TRI Information Reports due July 1 each year Civil penalties up to $27,500 a day EPA Region IV Contact for TRI: Stacy Bouma, (404) 562-9192  EPCRA Section 313 TRI and contact for Charlotte, NC TRI Workshop, April 30 – May 1, 2001: Ezequiel Velez, (404) 562-9191 TRI Hotline: 1-800-424-9346 TRI Website: http://www.epa.gov/trihttp://www.epa.gov/tri

23. For More P2 or SGP Information: DPPEA offers free onsite SGP assistance P2 resources online for metal finishers: www.p2pays.org/indsector.htm www.p2pays.org/indsector.htm Online assistance for SGP available at: http://www.strategicgoals.org/http://www.strategicgoals.org/ and http://www.epa.gov/sustainableindustry/metfin.htm  State SGP Contact: Julie Woosley, N.C. DPPEA (919) 715-6527 or 800-763-0136 Julie.Woosley@ncmail.net