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
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 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

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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
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