SEPA United States Solid Waste EPA 530-F-97-021 Environmental Protection and Emergency Response August 1997 Agency (5306W) Waste Minimization: Reduction in Combustible Waste FMC Corporation Eliminaf I Ifeed to IIIHIHHrUfilMMiilmSfraii elief fra Section 313 - •-.•-.- -.- -:..> empltpes who work iir the \ 11154*i IAII1 Liftl I Ki! 1111H iilor ii lap " What is FMC Corporation? FMC's Naval Systems Division is a defense contractor in Minneapolis, Minnesota. Their work revolves primarily around the design and production of military equipment. Before implementing their waste minimization programs, FMC generated about 8,250 gallons of spent 1,1,1,- trichloroethane (TCA) annuaUy. FMC used this sol- vent for a variety of common clean- ing applications including over- hauled valve housings, large metal parts prior to painting, electrical components, dewaxing of metal prior to plating, and a variety of maintenance uses. Various grades of spent solvent were being generat- ed. Final disposal of these solvents typically required incineration. What Did They Accomplish? In 1989, FMC implemented an in-house recycling program that allowed 142 of the 150 drums of spent solvent generated annually to be recycled at the facility. Then, in 1991, FMC topped that by eliminat- ing the use of TCA altogether, and, therefore, the need to incinerate spent solvents. Environmental Achievements The recycling system was only in operation for one year before FMC eliminated TCA. While it was running, the recycling system's capacity was approximately 150 drums of solvent for that year. Helen Addies, Environmental Engineer, points out that this amount might have increased over time to a higher annual average, had the system been used longer. Since 1991, when TCA was elim- inated, there has been a company- wide change in attitude; currently, FMC disposes of wastes only when there is no alternative use for the waste. They are constantly in search of ways to divert flow away from the waste stream and reduce waste volume. To this end, FMC now places HazMat codes on various chemicals in an effort to track their use and ultimate destination, with the goal of eliminating as much waste as possible, either through minimization or recycling. In addition to its efforts to reduce TCA, FMC has actively pur- sued several other waste minimiza- tion opportunities. For instance: • FMC has reduced its use of chemicals targeted by EPA's 33/50 program, such as methyl ethyl ketone ------- Waste IVHnimiziiion: FMC CorporSfiQh , • EMC is always looking for sub- stitutes. Working with the mil- itary makes this difficult, since there are often stringent speci- fications that preclude the use of substitute materials or process changes. As a result, FMC has emphasized reusing materials. For example, FMC reuses foundry sand generated on-site. In 1995, they sold about 78,000 Ibs. to an asphalt company, which earned FMC an EPA WasteWi$e leadership award. There have also been many less- tangible benefits. For instance, FMC has improved its community and public relations through the receipt of numerous pollution prevention awards. Regulatory Relief Due to its efforts, FMC earned relief from Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313 reporting requirements in 1995, resulting in less data collection, recordkeeping and reporting. In addition, FMC eliminated TCAuse well ahead of the phase-out schedule established by the Clean Air Act (CAA) Amendments. The Implementation Process FMC's environmental depart- ment designed the original recycling system and the method for eliminat- ing TCA with input from several other areas within the company. This was a team effort including both engineers and people who actually worked with TCA. Ms. Addies notes: "Quite a few of our people were ardent environmental- ists, which helped quite a bit." Workers did need some training, first to run the recycling system, and then to adjust to working without TCA. The recycling project took about six months from conception to implementation. FMC phased out TCA entirely within three years (two years after implementing the recy- cling system). Installation initially affected production, but the prob- lems were quickly solved. Quality was not affected. To monitor the success of the recycling system, FMC utilized chemical tracking and cost- accounting systems. These systems were already in place, although FMC purchased software upgrades to improve accuracy. Economics: Costs and Payback FMC funded these projects inter- nally, and there was no competition from other projects at the time. Retrofitting the vapor degreaser into a solvent recycling center represent- ed the primary initial cost of $14,800. Ms. Addies estimated operating costs of the recycling center to be approximately $15,000 during that year. As a payback for their efforts, FMC realized a return on their investment in the recycling system in 3 to 4 months. Later, elimination of TCA resulted in significant sav- ings in time and disposal and pur- chasing costs. It also facilitated CAA compliance, as TCA is on the list of chemicals to be phased out. Ms. Addies estimates total savings resulting from TCA elimination to be approximately $100,000. Hurdles No significant hurdles presented themselves when FMC implemented these measures. A few management and labor issues arose; however, they were quickly resolved. Words to the Wise Ms. Addies passes on one piece of advice to those thinking of imple- menting waste minimization and pollution prevention at their own facilities: "Draw on the experience of employees who work in the area, (they) know if something will work, or will have valuable input." She added that employees often have considerable outside knowl- edge that could be useful for project development and implementation. WASTE MINIMIZATION NATIONAL PLAN For more information about the Waste Minimization National Plan, call (800) 424-9346 or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize FkiucingToxKsinOurnata'slJMste ------- |