The First Annual Statewide Pollution Prevention Conference
How to Develop Effective BMPs
Kay Gervassi
Broward County P2 Program
June 1997
How to Develop Effective Best Management Practices
by Kay Gervasi
Historv of Broward Countv’s Environmental Repulatorv Proprams
Broward County’s first Pollution Control Board met in 1970. In 1977 the county adopted a Charter
Government, and the Pollution Control Board’s name was changed to the Environmental Quality Control
Board (EQCB). On November 6,1990, the voters of Broward County chose to transfer the responsibilities
of EQCB to the Board of County Commissioners and the agency was renamed the Office of Natural
Resource Protection (ONRP). In 1993 we became the Department of Natural Resource Protection.
Creation of Broward Countv’s Pollution Prevention Propram
The Pollution Prevention Section was established in 1992. At that time, the Hazardous Material and Solid
Waste Division was reorganized and renamed the Pollution Prevention and Remediation Programs Division.
It included the Pollution Prevention Section with three full time positions allocated to it. There were no
regulations promulgated to create the program.
DNRP is committed to excellence and leadership in implementing the pollution prevention concept into the
agency’s mainstream activities, such as inspections, permitting, and enforcement. Creation of DNRP’s P2
section is a non-regulatory approach for achieving regulatory compliance and preventing pollution in
Broward County.
What is a Best Manapement Practice (BMP)?
BMPs are specific procedures a business can follow to ensure operation efficiency and compliance with
environmental requirements. BMPs are developed for specific business types. Since the most appropriate
procedures evolve ftom on site-specific considerations, the BMPs have been developed to be a flexible tool
for i d e n t i h g procedures that can be implemented to address the needs of each individual facility. Best
Management Practices examine processes within an industry to identifj where waste is generated. This
examination may lead to process modifications to generate less pollution. In Broward County, BMPs have
been created by the Pollution Prevention Section (which is the only non-regulatory arm of Department of
Natural Resource Protection). As a result, an emphasis on pollution prevention has been included in each
BMP.
Whv Do We Need Best Manapement Practices?
Over the years, the agency’s role as regulator has resulted in an adversarial relationship with many segments
of the regulated community. BMPs were initiated in 1992 as a non-regulatory program to assist businesses.
DNRP also wanted to follow the trend toward voluntary cooperation. It was felt that we could do more at
the local level than the state or federal environmental agencies could and our agency was convinced that
BMPs would succeed because they make sense.
Advantam of Best Manapement Practices
The initial focus and purpose of the Pollution Prevention Section were a collaborative approach to regulatory
compliance and pollution prevention. BMPs are an effort to accomplish just that. The purpose of the BMP
is to foster a working relationship between the regulated community and DNRP as a regulator in achieving
regulatory compliance and in preventing pollution in Broward County. The BMP is intended to serve as an
instrumend compliance tool enabling the protection, preservation, and maintenance of Broward County’s
environmentalresources. The overall goal of BMPs is to facilitate compliance with applicable federal, state
How to Develop Effective Best Management Practices
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and local environmental regulations, minimize wastes, and foster a pollution prevention attitude within
facilities operating in Broward County.
BMPs have been created for industridcommercial categories of business that have been idenMed as
pollution risks. To date, five BMPs have been completed and one more is under development. DNRP
believes that our agency leads the nation in the creation of BMP documents. We intend to continue to create
BMPs for industries throughout Broward County.
Broward County Department of Natural Resource Protection attained many advantages by creating BMPs.
The most important advantage was the development of an improved relationship with industry. In most cases,
this led to increased mutual respect and trust. This resulted in increased cooperation, which led to improved
regulatory compliance. As the saying goes, you can indeed attract more flies with honey than with vinegar.
BMPs are honey compared to the vinegar-like regulatory inspections, warning notices and fines.
Other advantages included increased regulatory compliance, decreased waste generation, improved public
relations for Broward County, and a better understanding of industry and their needs.
Disadvantapes of Best Management Practices
Our experiencehas shown that industry participation in drafting BMPs is critical to success. In the five BMPs
created by Department of Natural Resource Protection to date, the most successful ones generated critical
industry interest, attendance at workshops and input in the process. One negative point to consider is that
most participants wdl be the “good guys.” That is, they represent the majority of the industry who is actively
trylns to comply with environmental regulations and prevent pollution. That other minority who refkses to
cooperate and who need the most he@ to get into compliance will not attend the BMP workshops nor
participate in the process. This minority group wdl not benefit fiom non-regulatory outreach and
unfortunately will require the vinegar (inspections, warning notices, and fines) instead of the honey.
Another negative aspect of creating BMPs is how time consuming it is create the document. A lot of effort
is required to obtain the technical expertise to understand an industry well enough to make technical
recommendations. Unless you possess that expertise, industry representatives will not take you seriously or
listen to your advice. Printing and distributing the documents can also be very expensive.
Process to Create Best Management Practices
The first BMP was created in 1992 for Marine F d t i e s . Historically, boat repair and maintenance activities
at marine facilities located in Broward County have been conducted outdoors on the waterfront. In many
cases,these practices have contributed to the &charge of wastes and contaminants to the surface and ground
waters of Broward County with subsequent environmental impacts. Wastes generated by boatyard activities
typically include such items as: abrasive grits, spent solvents, waste oils, washwater, paint overspray,
cleaning fluids, anti-corrosive compounds, paint chips and scrap metal.
The BMP program was initiated by involving interested parties, including individual representatives of the
industry and the Marine Industries Association of South Florida (the trade association which represents the
marine indust& in the development and implementation phases of the BMP.
The program began with the formation of a DNRP technical team to assess the environmental impacts
resulting fiom marine industry practices and to review marina operational practices. This team worked
How to Develop Effective Best Management Practices
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closely with industry representatives developing specific requirements and goals for incorporation into
everyday operational practices at all marinas.
These everyday practices which generate pollutants include such activities as painting, pressure washing,
hydroblasting, mechanical work on engines, hazardous material use and storage, bilge cleaning, welding,
grinding, waxing and cleaning. Specific guidelines were developed and incorporated w i h the BMP to
encourage the e m o n of hazardous material and wastewater discharges into the soils, waterways and air.
The DNRP technical team developed the first draft of the BMP with emphasis placed on encouraging
prevention and compliance rather than the more expensive altemative of clean up. This approach recognized
diversity due to site specific conditions and promoted proper waste disposal, reuse programs, pollution
prevention and waste minimization programs.
Working cooperatively with the industry representatives, DNRP incorporated their input and concerns into
a final BMP document and also agreed on an implementation schedule to enhance compliance with all
relevant provisions of Chapter 27 (the Natural Resource Section of the Broward County Code). This process
was &tated by conducting workshops and by initiating open discussion and communication regarding the
concerns of all parties affected by the BMP.
Case Study: Broward Countv's ExDeriences with Manna Best Management Practices
DNRP's staff visited all potential marina facilities and subsequently identified 46 marinas as candidates for
participation in this program. The criteria for participation in the BMP program included:
0
All recreational boat docking facilities with ten or more boat slips.
0
All boat storage facilities with ten or more storage spaces.
0
All commercial boat docking facilities.
The purpose of these visits was to establish communication, share technical information and to evaluate the
compliance status of each participating marina Based on the information collected during the individual
visits, a compliance schedule was established.
Each site was periodically reinspected. In addition, frequent communication (such as telephone calls)
between DNRP staff and facility representatives was maintained to insure that compliance with the BMP
could be achieved. Initially, there were several marinas that were not able to comply fully with the BMP
requirements in a timely manner. Twenty facilities were given an extended deadline to achieve compliance.
In the end, all 46 marinas attained full compliance with the BMPs.
Boatyard employees, independent contractors, and customers are now more educated as to the critical role
pollution prevention practices and the BIW play in protecting natural resources. All marinas that meet the
criteria for participation in the BMP are required by DNRP to operate in accordance with these practices.
Marina Best Manapement Practices Success Stories
Some examples of process modifications that were implemented by the marine industry in order to achieve
compliance with the BMP include the following:
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Installation of a catch basin or a pre-treatment system to collect and treat the rinseate generated by
pressure cleaning of boat hulls. This has significantly reduced the amounts of heavy metals, oil and
grease and other contaminants reaching the surface waters.
All spray painting is conducted over an impermeable surface with a boom available to contain any
overspray on surface waters. Overspray on water is removed immediately. This has helped reduce
contaminants from reachmg ground and surface waters.
Buildmg enclosures were constructed to contain sandblasting or sanding residues during bottom paint
removal activities. Overspray and dust from sanding operations have been a concem from
neighboring residences and businesses. This activity has helped reduce complaints and has allowed
boatyards to become better neighbors.
A written hurricane plan was prepared by each facility with copies provided to all vessel owners.
Manatee protection signs were posted withm the marinas.
All hazardous material transfer, dispensing and mixing activities are performed in a manner which
prevents any release to the environment. Such activities are now performed within a containment
area.
Petroleum and related products are stored in secure containers and withm a secondary containment
area.
Four Broward marinas were recogwed for outstanding environmental achevements on September 27,1996
in Chicago, Illinois at the Intemational Marine Trades Exhibit & Convention. Associated Marine
Technologies, Hall of Fame Marina, Harbour T o m e Marina and Summerfield Boat Works received Clean
Marinas-Clear Value certificates from Geofiey Grubbs, the Director of the Assessment and Watershed
Protection Division of the Environmental Protection Agency (EPA). These four Broward marinas are the
only marinas in the state of Florida to receive thls distinction.
The EPA bred Neil W. Ross of the Kingston, RI. -based firm Neil Ross Consultants to study marinas and
commercial boatyards to document a wide range of BMPs whch help to achieve clean boating waters and
provide benefits to marina business operations.
As a result of the BMP initiative, Associated Marina Technology, Harbour T o m e Marina and Summerfield
Boat Works all installed a catch basin to collect and properly treat hull pressure cleaning discharges.
Hall of Fame Marina and Harbour Tome Marina both installed pumpout facilities for their customers to use,
free-of-charge, to pump out their holding tanks.
All spray painting is conducted over an impermeable surface and a boom is available to contain any
overspray on surface waters. Overspray on water is removed immediately. Additionally, Summerfield
installed a paint shed to collect all overspray, which is then put through a misting system where the paint is
coagulated, separated and disposed.
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Associated Marine Technologies purchased equipment to replace their sand blasting. Now they use plastic
media in place of sand. The plastic is separated from the paint chips and reused. Instead of disposing of
hundreds of cubic yards of sand, they now only dispose of a few pounds of paint chips. This is an example
of pollution prevention at its best.
Overall, these and other innovative improvements in the operational practices at marine facilities have
signdicantly reduced the quantity of pollutants previously discharged to Broward County's waterways.
This BMP program has not only addressed and helped resolve many environmental issues at Broward County
marinas, it has also had a direct positive impact on the economic health of Broward County, represented by
the protection of the environmental resources that support tourism, water sports, recreational fishing and
diving. Clean water and a healthy ecosystem are the fundamental components for continued economic
viability of Broward County's marine industry.
Other Best Manapement Practices
Metal Finishing Facilities
The s'econd BMP was for Metal Finishing Facilities. Twenty-six (26) facilities in Broward County perform
metal fishing operations: seventeen (17) are electroplating or other surface finishing businesses, and nine
(9) are circuit board manufacturers. A confidential, non-regulatory site inspection of each facility was
performed in order to determine existing problems in achieving regulatory compliance and to identify the
pollution prevention opportunities specific to each operation.
A 44 page technical document "Pollution Prevention and BMPs for Metal Finishmg Facilities" (P2-BMP) was
developed. The draft P2-BMP was sent to all metal finishing facilities and other interested parties for
comments. Four (4) workshops were conducted between January and July 1994, with participation at each
meeting between 15 and 26 people. DNRP worked cooperatively with industry to finalize a document that
is both implementable and free of any undue technological or economic burdens.
At the July 14,1994 workshop, the P2-BMP was unanimously approved for implementation by DNRP and
representatives of the electroplating facilities, metal finishing industries, electronic companies, South Florida
Manutkturers Association, consulting firms, and Florida Department of Environmental Protection - Waste
Reduction Assistance Program.
Twenty-one (21) metal finkding kilities achieved compliance with environmental regulations and developed
their own P2 Program. It was agreed between DNRP and participating facilities that in order to protect trade
secrets, the P2 Program Plan would not be submitted to DNRP where it would become public record.
Consequently, the P2 Program Plan was reviewed for completeness at the site.
In general, each facility followed the recommended criteria contained in the P2-BMP to develop their P2
Program. An assessmentkurvey of production processes and waste streams was performed, selected targets
were established, options were selected for implementation with quantitative goals (as appropriate), and time
h n e s were established. Simple, low cost or no-cost altematives such as improved housekeeping, material
and waste handhg, preventive maintenance and employee training were implemented before more expensive
equipment or process modifications were evaluated. Feasibility of equipment and process changes were
based on technical and economic criteria. Some P2 Programs are divided into phases that will initially
require little investment while realizing a large return, followed by large investments with a smaller r e m .
How to Develop Effective Best Management Practices
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All targeted facilities are focusing on water conservation. It is expected that as much as 50% reduction in
actual water usage resulted. Widespread success in water conservation has also been achieved by using
simple techques that reduce drag-out losses and rinse water use.
These methods made substantial progress in reducing wastewater flow rates and sludge, which is hazardous
waste. Some facilities focused on energy conservation, estimating an annual cost reduction of up to 40%.
The total estimated annual savings to participating facilities, resulting from implementation of the P2
Program, is up to $670,000.
The P2 Program of some facilities far exceeded our expectations. The following examples illustrate what
some companies did:
J
Implementation of an "NO-CLEAN" technology in December 1994. The result was the elimination
of terpene usage (more than 4000 gal in 1994), one hazardous waste stream (terpene), three solid
waste streams (resin, charcoal, filters) and an approximately 70% reduction in the facility VOC
emission rate;
J
Eliminated glycol ethers use (Dec.'94) by implementing a water-based process. This P2 method
reduced VOC emissions and eliminated the need to report on the Toxic Chemical Release Form
(Form R), because glycol ethers are subject to SARA Title 111, Sec. 3 13;
J
Replaced electroless copper with direct metalization process (Oct., '94). This procedure eliminated
the use of cyanide copper and formaldehyde - extremely hazardous substances (302, CERCLA,
RCRA, 313) - and most chelated metals, which decrease the amount of sludge generated (hazardous
waste).
J
Implemented methods to reduce isopropanol air emissions by 30% by the end of 1995;
J
Reduced waste by recovering metals in process solutions and cleaning acids by electrowinning of
batch treatment. Future plans are to incorporate electrowinning for zinc metal recovery instead of
using the precipitation (waste) method;
J
Extended usage of Ion Exchange technology to produce deionized (DI) water for rinse and plating
solutions, recovered chemicals from rinse water, removed contaminants from plating baths, or
wastewater process to comply with stringent effluent limits;
J
Designed and implemented "closed loop" system for rinse water as a first step of long term zero
discharge of wastewater by some facilities. Already reduced water usage by as much as 300 to 1200
gaVday and plan to reduce the rate to 5000 gallday;
J
Recycled plant effluent wastewater through a reverse osmosis system to reuse water in process rinse
tanks. Project current water usage will be reduced by 50%; and
J
Reduced up to 75% of metal contaminated sludge quantity by improving the wastewater
pretreatment process and introducing filter-press and dryer technologies.
How to Develop Effective Best Management Practices
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Besides saving the company’s money and reducing its liability, some facilities will be able to reduce their
federal reporting requirements by changing from the fully regulated Generator to the Small Quantity
Generator category.
Automobile and Other Salvage Facilities
As a result of the dlscovery of significant soil and groundwater contamination at several salvage facilities in
Broward County, the DNRP Pollution Prevention & Remediation Programs Division implemented a salvage
facility initiative beginning in June 1994. The initiative had two phases. The first phase consisted of
inspecting all existing salvage facilities for compliance with Broward County Hazardous Material Code. The
second phase encompassed development of pollution prevention and best management practices (P2-BMP)
for salvage facilities operating in Broward Counly. The second phase consisted of the following components:
Interviews with inspectors;
Visits to salvage facilities;
Compilation of all federal, state and local laws and regulations applicable to hazardous material and
oil handling activities conducted by salvage facilities;
Development of P2-BMPs that go beyond compliance with existing regulatory requirements;
Preparation of a P2-BMP document for salvage facilities in Broward County;
Meetings with salvage facility operators to discuss DNRP’s P2-BMP project; and
Training for DNRP staff
Through the interviews with DNRP inspection staff and visits to salvage facilities it became clear that facility
operator knowledge of federal, state and local regulatory requirements was inadequate. This is not surprising
given how regulatory requirements have changed over the last several years. This insight, however, provided
the impetus for compiling all applicable regulatory requirements and providing training to salvage facility
operators. The compilation of regulatory requirements became a 36-page P2-BMP document. This
document also contains pollution prevention suggestions that go beyond regulatory requirements (referred
to here as best management practices) and an extensive set of appendices that provide examples, reference
guides, and contacts for more information on pollution prevention. It was meant to be a hands-on document
for salvage yard employees.
Once a dr& document was completed, DNRP pollution prevention staff held a series of four workshops for
salvage facility operators to (1) inform them of DNRP’s salvage facility initiative, (2) provide them with
training on regulatory requirements and suggested P2-BMPs7(3) solicit their suggestions on P2-BMPs that
make sense for their industry, and (4) develop a more cooperative relationship between them and DNRP
regulatory staff The workshops were held between December 1994 and September 1995. Between 17 and
24 salvage facility operators and other interested persons attended each workshop.
Judging from comments, the participants appreciated DNRP’s efforts to inform them of the regulatory
requirements and to provide a reference document that simply states current regulatory requirements. They
admitted that they had been confused on some regulatory issues. They expressed their pleasure with the
opportunity to interact with non-regulatory staff in workshops where facility operators could freely express
themselves without fear of exposing areas of non-compliance. They were also pleased that DNRP staff
solicited their comments.
Dry Cleaning Facilities
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Using grants from the Environmental Protection Agency (EPA), Florida’s Small Business Assistance
Program (SBAP) published the Complete Multi-Media Environmental Compliance Assistance Guidefor
Dry Cleaning Industry. This guide was developed based on Federal and State of Florida requirements
effective in 1994 and early 1995.
The DNRP developed a PZ-BMP document to include the local environmental requirements applicable to
all dry cleaning facilities operating in Broward County, which was added to Florida’s SBAP CompleteMultiMedia Environmental ComplianceAssistance Guide and distributed together in May 1996.
Lithographic Printing Facilities
In February 1997, DNRP created a PZ-BMP for lithographic printers. It contained two sections:
b
b
The first section provides a brief description of each Federal, State and local environmental
regulation affecting lithographic printers, followed by a self-audit checklist. These checklists are
designed to assist owners/operators in evaluating the level of compliance at their facility and to
correct discrepancies.
The second section of this document addresses pollution prevention opportunities for lithographic
printers to minimize further the generation of waste and potential release of hazardous material to
the environment. An overview of national pollution prevention programs is provided. The DNRP
recommends a Pollution Prevention Program be implemented by each facility. Recommended
criteria to develop a comprehensive Pollution Prevention Plan are included in this document. This
plan describes the actions to be taken at a facility to minimize generation of wastes at the source and
eliminate releases of hazardous materials to the environment. It also provides a schedule for
implementation, and a means for measuring progress toward pollution prevention goals.
VehicleMaintenance Facilities
In an effort to tailor Pollution Prevention Section activities to the needs of our community, a new concept
was created in developing PZ-BMPs for the vehicle repair and maintenance industry. This new PZ-BMP
concept consists of developing an attractive handbook containing practical information to help small
businesses stay in compliance with environmental requirements and prevent pollution. Industry specific best
management practices and pollution prevention opportunities are provided that may be implemented by
small businesses to ensure environmentally sound operations. In addition to the handbook, specific DOs and
DON’TS posters are created which we recommend to be posted on shop walls for easy access of employees.
We consider this is an effective way to remind everyone about the best management practices of shop
operations.
The draR of “Pollution Prevention and Best Management Practices for Automotive Repair Shops Operating
in Broward County”was created in May 1997. The 22 posters with DOs and DON’TS on issues specific to
thisindustry have been created. The draft handbook is in the intemal review process. It is hoped that it will
be completed for the June Conference,
Summarv and Advice for Creatine Effective Best Management Practices
A few tips to help you create effective BMPs are listed below:
c
How to Develop Effective Best Management Practices
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I. Knowledge
a.
Gain a strong technical background on subject. Research the industry. What are their
processes? Use the world wide web. There are several excellent pollution prevention web
pages such as Enviro Sense, the National Pollution Prevention Roundtable and a multitude
of state and local sources. Read trade magazines and learn fiom facility managers when you
conduct inspections. Even though they are busy, you would be surprised how
accommodating they can be to tell you about their operation.
b.
Inspect as many facilities as you can. This will increase your knowledge and establish a
personal relationship with facility employees
C.
Don’t reinvent the wheel. Use information already out there. There is a multitude of
information already published and on the world wide web. Make contacts so you know
where and how to find the information.
11. Bridge Building
Request an RSVP for your workshops. It lends an air of importance to your workshop.
a
More people will attend, and you will have a better idea of how many participants to expect.
Involve industry associations. They can help get your message to the industry. They can also
b.
encourage their members to participate.
Provide refieshments at workshops. It is good for public relations and it makes participants
C.
feel good.
Meet when it’s convenient for industry. You will have better turnouts to workshops.
d.
Different industries have different needs.
Meet at least three times. It will take that many face to face meetings before they will trust
e.
you.
Be a cheerleader for their successes. Urge them to document their successes, and then brag
f
about them. This will reinforce the concept that you are to be trusted and are on their side.
Go to their meetings when possible. The more visible you are, the more cooperative they
g.
will be. Also conduct your workshop at their meetings when you have a captive audience.
It is difficult to get them to come to your regulatory office!
Don’t betray their trust. If you tell them you are non-regulatory, then you can’t issue
h.
warning notices or fine them for matters under discussion. Once you do, word will get
around and no one will ever trust you again.
Get other business leaders involved (attomeys, vendors, consultants).
1.
Issue press releases to tell the public what you are trying to do. Use press releases to be a
jcheerleader (see item f above).
Include industry experts on your agenda as speakers. Find someone who is respected by
k.
industry. That will help draw more people to your workshops and demonstrate your
willingness to work cooperatively.
III. Follow Through
Provide certificates of attendance. They are appreciated.
a.
Keep in contact with the industry. Generate a mailing list of the people you met. When
b.
events such as teleconferences come up, personally invite them.
Continue to be a cheerleader, long after the BMP is published. DNRP issued a press release
C.
in 1996 about marinas even though the BMP was completed in 1992.
How to Develop Effective Best Management Practices
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For additional information, please contact:
Kay Gervasi, Pollution Prevention Manager
Broward County Department of Natural Resource Protection
218 SW 1 Avenue
Ft Lauderdale, FL 33301
FAX: (953) 765-4804
telephone: (954) 519-1257
E-mail: [email protected]
or visit our world wide web site at: http://www.co.broward.fl.us/dnrp
Each BMP is on our web site under the Pollution Prevention & Remediation Programs Division, Pollution
Prevention Section.