To the managers of the New York City Industrial Pretreatment Program (IPP) the SGP appeared unlikely to deliver any benefit. Why? For years the New York City Department of Environmental Protection (NYCDEP) had hoped to shift its program from regulation of significant industrial uses to other environmental problems, especially diffuse sources of toxicants of concern—such as PCBs, mercury, polyaromatic hydrocarbons, and volatile organic compounds - and other environmental quality of life issues—such as the illegal disposal of grease and oils. SGP appeared to require significantly more environmental management, seemingly with little environmental gain for the City. In New York City, the metal finishing industry accounts for less than 1% of the metals found in the raw sewage. In fact, all regulated industry account for only 1.2% (34 of 2947 lb/day) of the metals influent to the City's fourteen plants; this small fraction is a direct result of the IPP program. (The remaining 96% of metals in sewage is largely from corrosion of residential and commercial plumbing.) The New York City Department of Environmental Protection (NYCDEP) was able to mold the SGP to meet municipal objectives and benefit the environment, too.

The success of the IPP in New York City is no accident. Considerable resources have been devoted to IPP including a staff of seventy-two along with the necessary support vehicles and equipment. Since 1987, the IPP program has been responsible for a 95% reduction in metals from the discharges of regulated industry to POTWs. The City's rationale for participating in the SGP was the expectation that the program could help the City to shift resources from IPP to the environmental and quality of life problem areas of concern. The traditional IPP regulates fewer than a thousand enterprises; these other areas of concern, however, involve about thirty thousand additional commercial establishments.

Obstacles to New York's participation

At one of the first SGP stakeholder meetings, New York made its case that it had to have the flexibility to shift its resources. The multi-agency stakeholder group is composed of USEPA, NYSDEC, POTWs (NYC, Syracuse, and Rochester), several metal finishers, and the companies' associations. To implement some of the SGP benefits and the changes needed to shift resources, New York had to change the IPP. Initially, many stakeholders were skeptical of the City's motives and of NYCDEP's ability to get approval for changes to our "mandatory" program.

After many difficult stops and starts, New York City gained conceptual approval from the stakeholders group. The chief obstacle was the perception that the City's program could not be legally changed. The breakthrough came when the group decided to review each relevant item. The items were categorized as follows:

CWA requirement
USEPA regulation
Local law or an approved program element.

Eventually, the group agreed that many of the City's objectives could be legally accomplished and could be incorporated into a new USEPA-approved Enforcement Response Plan (ERP). With this determination in hand, New York City decided to remain in SGP. (It should be noted that upon the implementation of the currently proposed federal IPP Streamlining Initiative, further steps can be made advancing the SGP goals.)

Figure 1. Typical plating operation for small jeweler

Another obstacle to New York City's participation turned out to be the large number of small jewelers in NYC. These mom-and-pop shops account for more than 180 of 250 metal finishers and are found throughout the jewelry district of Manhattan. Most of these small jewelers are actually "backrooms" to retail jewelers stores. Often they are doing touch up work on rings after the stone is set. Figure 1 shows a typical plating operation; Figure 2 shows a typical treatment process. The small jewelers plate with precious metals (platinum, silver, and gold) and have very little process effluent, most less than 100 gal/day. Collectively, these small jewelers—together - account for less than 1 lb of the 2947 lb/day total influent metals to the City's POTWs. After a recent statistical analysis, NYCDEP determined that these small jewelers had discharged no more than they were discharging before the IPP regulations. The larger (true) platers, however, had reduced their metals' discharges by 95% after IPP controls were installed. These numbers are no surprise when you consider that waste from small jewelers is largely silver and gold and that re-cycling companies pay to recover these precious metals from their sludge.

Figure 2. Typical treatment system for small jeweler (settling drums)

Rationalizing dischargers

Given the circumstances, NYCDEP determined that small jewelers could not benefit from SGP; in fact, many stakeholders felt that small jewelers would be a drain on SGP program resources. NYCDEP then proposed an across-the-board approach for all jewelers by reducing self-sampling requirements (frequency and parameters) to federal minimums.

This resulted in savings for each firm of approximately $1000 annually. POTW inspection and monitoring requirements would also be reduced to the Federal minimum, and a soft-landing enforcement plan was developed. Thus, NYCDEP relies on "notices of noncompliance," with the exception of chronic noncompliance, which can result in monetary fines. It is NYCDEP's opinion that no municipal resources should be expended on such firms. This position, however, will require a regulatory change by USEPA and is beyond the role of SGP; this change may be addressed in the USEPA Streamlining Initiative.

New York City proceeded to amend its ERP concerning both small jewelers and traditional platers involved in SGP in line with its rationale about the relative importance of the discharges. Within a relatively short time—perhaps record time - USEPA approved New York's modified ERP. New York City may now implement the small jewelers initiative across the board and all aspects of the benefits that an individual metal finisher can receive as they achieve the SGP goals. For those firms who move up the performance ladder, NYCDEP intends to reduce self-monitoring costs and to rely on notices-of-noncompliance. Monetary fines will be limited to those with chronic violations.

Outcome

As a result of the small jeweler initiative and other efficiency steps, NYCDEP has already begun to shift limited resources to new priorities. A new unit was created to inspect and monitor restaurants, for example, a major task in New York with more than nineteen thousand restaurants to inspect. To date, one thousand have been inspected for grease interceptors.

The remaining challenge is to get metal finishers to sign-up and participate in SGP. At the NYCDEP's October 19, 2000 kickoff meeting, participation in the program increased to eighteen firms. The first technical workshop was held November 13, 2000 and was attended by twenty-two firms. In an attempt to ease the application process, NYCDEP is teaming with the local utility, Con Ed, to provide 1992 baseline data so that small firms don't have to dig out records from storeroom and basements.

New York City was originally skeptical about SGP. Now, having overcome a few initial stumbling blocks, true gains are being realized. The City is only at the beginning of SGP, and as more firms sign up and climb the performance ladder, greater gains should be seen. It is NYCDEP's hope that metal platers will decide that SGP makes economic and environmental sense, and they will participate fully.
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Phil Heckler, PE is Deputy Director (Environmental Affairs) and Robert LaGrotta, PE, Esq., is Division Chief of Pollution Prevention in the Bureau of Wastewater Treatment of the New York City Department of Environmental Protection.

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