A PRACTICAL GUIDE
TO
POLLUTION PREVENTION PLANNING
FOR THE IRON AND STEEL INDUSTRIES
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A pollution prevention program is dynamic. Like an
enqine that needs tinkering and attention, your program
win need periodic review and updating as new options
are developed or identified. Any cost savings associated
with a particular option will go unaccounted if an
evaluation is not performed.
There is only one final message to convey once you have
completed your first successful waste reduction project.
LET OTHERS KNOW OF YOUR SUCCESS
and then tell them again. As stated in Step i, portion
prevention requires some in-house marketing. BE
TO DO IT!
POLLUTION PREVENTION PAYS
3-21
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Such a final report is necessary. It helps to focus
subsequent pollution prevention efforts and will be useful
as a record of what aspects of the mill have been
examined for pollution prevention opportunities.
The assessment teams should consider report review a
top priority before the report is issued in final form.
Managers and other experienced people in the production
units that will be affected by the proposed projects
should be asked to review the report. Their review will
help to ensure that the projects proposed are well-
defined and feasible from their perspectives. While they
probably were involved in the site reviews and other
early efforts of the task force, they may spot
inaccuracies or misunderstandings on the part of the
assessment teams that were not apparent before.
STEP 5: IMPLEMENT THE POLLUTION
PREVENTION PROGRAM
Implementation of waste reduction options that your
audit team has determined are feasible and which
management has approved is a turning point in the
assessment process. Here you can put into practice
those recommendations that make the most economical
and technical .sense into practice. The process of
implementation involves four steps:
1. Justify the Project Using all Collected
Technical and Economic Data
2. Obtain Funding " - .'
3. Install Equipment/Implement Procedure
4. Evaluate Performance
If vou adhere "to this model, recommended waste
reduction options will be easier to implement because
the appropriate data will be available to property evaluate
the project and to ultimately judge its effectiveness.
WRITE A FINAL
ASSESSMENT REPORT!
STEPS
3-19
55
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Cost competitive issues make cost a primary concern for
iron and steel. Therefore, implement low-cost, low-tech
waste reduction options first. Generally, these options
can be put in place almost immediately. Their effect can
be'readily seen. Move on to more capital-intensive
options after careful evaluation. Examples of low-cost
options which do not require major capital investments
and have an immediate payback include:
Good housekeeping to prevent waste through
spills.
Use of quality resealable containers to prevent loss
from spills and evaporation.
Rigid inventory control to insures that you use only
what material you need.
Segregation of wastes to enhance recycling (for
example, keep solvents out of used oil) or
segregate waste streams as previously noted for
EAF's.
Employee education about waste reduction and
hazardous materials control.
Locating another business to use your waste as-a
recycled material.
Evaluate your success by formally reviewing your waste
reduction efforts. It is important to document your
waste reduction efforts and keep track of-costs of
various options (raw material consumption, waste
generation decreases, etc.). This information will be
useful when evaluating the success of your program.
Efforts to reduce waste at the source go against the
grain of traditional pollution control practice, which
emphasizes "end-of-the-pipe" or "top-of-the-stack
control. It may take time for employees to get used to
this new way of thinking. Pollution prevention options,
even low-tech ones, should be implemented carefully,
building consensus among workers and management to
generate support for the changes. Moreover,^options
may result in procedural changes within the mill, which
may require an orientation period.
3-20
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Missouri
Missouri Environmental Improvement and Energy
Resources Authority
P.O. Box 744
325 Jefferson SL
Jefferson City, MO 65102
(314) 75M919
Waste Management Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
(314) 751-3176
Moo tana
Department of Health and Environmental Sciences
Room A-206
Cogswell Building
Helena. MT 59620
(406)444-3454,
Solid and Hazardous Waste Bureau
Department of Health and Environmental Sciences
Cogswell Building
' Room B-201
Helena, MT 59620
(406) 444-2821
Nebraska
Hazardous Waste Section . .
Nebraska Department of Environmental
Control
P.O. Box 98922
Lincoln. NE 68509-8922
(402)471-2186
Nevada
Nevada Small Business Development Center -
Technical Assistance Program
Business Environmental Program
College of Business Administration, MS032
University of Nevada Reno
Reno, NV 89557-0100
(702) 784-1717
(800) 882-3233 (Nevada only)
State Energy Conservation Program
Office of Community Services
Nevada Energy Program
Capital Compisx
400 W. King
Carson City, NV 89710
(702)687-4990
New Hampshire
New Hampshire Department of
Environmental Services
Waste Management Division
Planning Bureau
6 Hazen Drive r ~
Concord NH 03301-6509
(603) 271-2901 - -
(603) 271-2902
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609)292-1026
Hazardous Waste Advisement Program
New Jersey Department of Environmental
Protection & Energy
401 East State Street
Trenton, NJ 08625
(609)777-0518
New Jersey Institute of Technology
Hazardous Substance Management Research
Center
Advanced Technology Center Building
323 Martin Luther King Jr. Boulevard
University Heights
Newark. NJ 07102
(201)596-5864
New Mexico
Economic Development Department
Bataan Memorial Building
State Capitol Complex
Santa Fe. NM 87503
(505) 827-0380
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^ - , - * - ^ ,v ,
POLLUTION PBEVENTJO^PLAHMIMM
' j. » A ! ,
" '% s% s f v
"<. -.OA * ^'^ ^ ^.y >
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FOREWORD
Until recently, businesses and industries throughout the United States did not
generally concern themselves with the concept of preventing, reducing, or minimizing
the generation of industrial pollutants. It was a widely accepted notion that the
generation of unusable material in large quantities was, in some cases, an inevitable
part of doing business. When regulations required it, companies installed some
mechanical device on the end of a pipe or stack, or paid to have the unusable matenal
buried or burned.
Significant progress has been made by the iron and steel industry overttl;eJast several
decades for improving environmental conditions through the implementation of end-of-
?he pipe, torof-the-stack, and land ban regulations. The pollution control laws with
their associated pollution control equipment and EPA enforcement, were aimed at
specific media (air, land, and water). Such laws have limitations, however.
In 1990 the United States Congress established "pollution prevention" as a top
priorHv by passing the Pollution Prevention Act of 1990. This act cuts across the
fo meTmedte divisions of air, land, and water and declares that a broad-based ook at
STol un generation is necessary. By taking this preventive approach,.ndustwand
fndh/iduals can minimize air pollution, solid and hazardous wastes, waste water
d,scha"ges, reduce the consumption of valuable resources, such as energy and water,
lower their potential liability, and save money.
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NOTICE
This manual was produced by engineers at Blasland, Bouck and Lee, under a
rooDeTative drant from the U.S. Environmental Protection Agency (EPA) to the
Sersi S ^ofSnnati, Department of Civil and Environmental Engineering It has
been subiect to review by staff from EPA Region V, a steering comm.ttee of member
companies of ?he Am.rte.ri Iron and Steel Institute (AISI). and others Rev, , does
not signify that the contents necessarily reflect the views and policies of the EPA, nor
^es the mention of any specific products constitute recommendat.on or endorsement
of such a product. . .
Thk manual supplements a Conference held October 1 4-1 5, 1 992, in Chicago, Illinois.
ThLTonferenc^ I Sted Pollution Prevention for the Iron and Steel Industry, ^ssco-
^nr^^eEPy AISI, and the American Institute for Pollution Prevent.on
^rThe aim of the conference was to provide an opportunity for individuals from
ndustrv federal and state government, non-profit organizations, and consultmg f . ms
£S w?ntoSSi.n on technical and po.icy issues related to po.lut.on prevents
for the iron and steel industry. . .
preparation of a pollution prevention plan.
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ACKNOWLEDGEMENTS
Documents are never prepared without the aid of a great many md.v.duals many of
whom do-not receive credit on the title page. This manual is no except.on Numerous
individuals have contributed to the revision and update of this document frorTvall over
he country; some through direct conversation, some through the contnbut.ons of
their written works on pollution prevention, and others simply by the.r helpfulness and
support of this project.
Specific thanks go to the organizers and backers of this conference:
Linda Glass ; Robert Tol pa Jennifer Beese Karen Martin
^PA Quarters EPA Region V EPA Region V EPA Region V
Bruce Steiner Gary Allie, Tom Mauser
.AISI AISI University of
Cincinnati ,
Additional thanks go to members of a Steering Committee, formed to assist in this
effort:
Barbara Bachman Anthony Spinola
Bethlehem Steel USX
JohriHeintz Lawrence Szuhay ' ^
National Steel LTV Steel
A great number of phone calls were made to solicit speakers for ^*"»^*
obtain current pollution prevention information for the iron and steel ndust y. Th.s
manual and the conference would not have been completed without the help of.
. Tom Hauser, Department of Civil and Environmental Engineering, at the
UnLrsfty of Cincinnati, who served as the director of the cooperat.ve grant
DavidEfhomas of the Hazardous Waste Research and
provided us with many contacts for speakers and case study 'nta*;
The people at the Waste Reduction Institute for Trainmg Appl.cat.on Research
(WRltAR), especially Terry Foecke, Al Innes, and Bob .Styles.
Employees of U.S. EPA's Pollution Prevention Staff, Theresa Marten at RREL
ff^RD IPA Cincinnati, Everett Moten at the 33/50 program, and numerous
others whose names have escaped us at the moment.
Peter Wieczorowski at the Steel Manufacturers Assoaat.o^ _.
Speakers at the Pollution Prevention Conference for the Iron & Steel Industry
IV
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ABSTRACT
Blasland Bouck & Lee developed this Practical Guide to Pollution Prevention Planning
for individuals from the iron and steel industry who are interested in pollution
prevention. Its aim is to provide an overview of just what pollution prevention is, and
provide specific ideas for pollution prevention planning within the industry.
The guide presents a six step approach to undertake pollution prevention planning.
The steps describe specific and detailed tasks such as how to. obtain company-wide
support, how to organize a pollution prevention task force, how to undertake the
necessary audits and assessments, and how to implement the developed plan.
Reference materials and useful worksheets are provided in the Appendices.
The support for the development of this guide was provided by the U.S.
Environmental Protection Agency under a cooperative grant to the Department of Civil
and Environmental Engineering. University of Cincinnati.
in
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who volunteered to participate and share valuable pollution prevention
information.
Special thanks go to Elizabeth Starling and Billie Smith, in our office, for their help
with word processing, page layout, production of this manual and associated
computer aids.
In addition, much of the outline for this manual came from the use of valuable
guidance documents, especially:
Facility Pollution Prevention Guide, released by EPA in May 1992.
Profiting from Waste Reduction in Your Small Business, David
Wigglesworth, Alaska Health Project, 1988.
Industrial Processes for Pollution Prevention and Waste Minimization,
C.R. Newman, A.E. Rimer, 1991.
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A PRACTICAL GUIDE TO POLLUTION PREVENTION
TABLE OF CONTENTS
NOTICE ......... .............. .................. V ...... . '
FOREWORD ............................... ....... ' ' ........
ABSTRACT ........ . ..................... .................... "
ACKNOWLEDGEMENTS ....................................... IV
CHAPTER 1 POLLUTION PREVENTION
What Pollution Prevention Is ......... ................. _J-J
What Pollution Prevention Is Not .................... ......... -°
What You Can Do ......... . . . . .............
What This Manual Is All About ...... ................... '1'°
CHAPTER 2 HOW TO DEVELOP A POLLUTION PREVENTION PROGRAM
The First Steps . .'.' .............. ...... ...... '. " ........ 2-1
Step 1: Recognize the Need for Pollution Prevention ............... . **
t Step 2: Write a Pollution Prevention Program Plan ..... . ........ 2-1 0
CHAPTER 3 ELEMENTS OF A POLLUTION PREVENTION PROGRAM
Step 3: Conduct a Pollution Prevention Assessment ...... ....... 3-1
Step 4: Decide What Steps to Take ... ..................... 3'5
Step 5: Implement the Pollution Prevention Program ...... ...... J-ia
CHAPTER 4 MEASURE PROGRESS & MAINTAIN POLLUTION PREVENTION
PROGRAM .. ...... ..... .........
CHAPTER 5 ECONOMIC ANALYSIS . ...... '. :' ...... .............. 5'1
CHAPTER 6 GET THE WORD OUT
APPENDICES
Appendix A: Implementation Worksheets
Appendix B: Policy Form .,»*-
Appendix C: s'ta'te. Pollution Prevention Programs and Activities
VI
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Increased efficient use of raw materials, energy, water,
and other resources is one method of implementing
pollution prevention. Conservation of natural resources,
is another method.
Source Reduction
Product Chang**
Design for Less
Environmental Impact
Increase Product Life
Prpc*** Chang**
Input Material Change*
i
Material Purification
Substitution of Less Toxic
Materials
Technology Chang**
Layout Change*
Increased Automation
Improved Operating
Conditions
Improved Equipment
New Technology
Improved Operating Practlc**
Operating and Maintenance
Procedure*
Management Practice*
Stream Segregation
Material Handling
Improvement*
Production Scheduling
Inventory Control
Training
Waste Segregation
Figure 1.1 Typical Source Reduction Example*
(Adapted from EPA Facilities Pollution Prevention Guide, May 1992)
The United States Environmental Protection Agency
(EPA), pursuant to the "Pollution Prevention Act of
1990H and the "Pollution Prevention Strategy",
established a comprehensive definition as outlined in a
May 28, 1992 letter to all EPA personnel from Deputy
Administrator, F. Henry Habicht H.
Under Section 66Q2(b) of the Pollution Prevention
Act of 1990, Congress established a national policy
that:
EPA Deputy
Administrator Henry
Habicht II outlined the
official definition of
Pollution Prevention in
May 1992.
1-2
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CHAPTER 1
POLLUTION PREVENTION
What Is Pollution Prevention?
f
Despite years of implementing "end-of-the-pipe"
solutions and stringently regulating hazardous material
disposal, substantial amounts of pollution are still being
released into the environment. A new approach to
environmental protection is necessary in order to
maintain and improve the environment and our quality of
life. This new approach will require industries to assess
their production processes, to evaluate their purchasing
decisions, and to improve their maintenance practices.
Simply put, industries need to find new ways to prevent
pollution at the source.
The concept of pollution prevention is very important in
today's society. Industries are concerned with the
increasing cost of raw materials. Stringent
environmental control laws and regulations are restricting
the way some businesses operate. Potential financial
and criminal liability associated with disposal of waste
materials increasingly concern industry executives. In
addition, consumers dislike of industrial pollution and
their strong influence on profit has caused industry
officials to analyze their production processes. Pressure
from foreign competition has also required that
companies become very cost conscious. All of these
examples should make one realize that pollution
prevention planning can be beneficial. As we shall see,
this may be particularly true for the iron and steel
industry as it seeks to improve its competitive edge.
What exactly is pollution prevention, you may ask?
Many different definitions of pollution prevention have
been developed by numerous individuals and
organizations over the last several years. Pollution
prevention, often referred to as source reduction,
includes practices that maximize the reduction or
elimination of the generation of pollution. Figure 1.1
illustrates several examples of source reduction.
THE NEW APPROACH
TO MANAGEMENT OF
POLLUTANTS--
POLLUTION
PREVENTION
1-1
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The term includes: equipment or
technology modifications, process or
procedure modifications, reformulation or
redesign of products, substitution of raw
materials, and improvements in
, housekeeping, maintenance, training, or
inventory control.
Under the Pollution Prevention Act,
recycling, energy recovery, treatment, and
disposal are not included within the
definition of pollution prevention. Some
practices commonly described as "in-
process recycling" may qualify as pollution
prevention. Recycling that is conducted in
an environmentally sound manner shares
many of the advantages of preventionit
can reduce the need for treatment or
-disposal, and conserve energy and
resources.
[While not directly related to the iron and steel industry,
we thought it might be interesting for you to also see
EPA'spollution prevention definition as it applies toother
sectors, which was part of Mr. Habicht's letter. (Ed.)]
Pollution prevention approaches can be
" applied to all pollution-generating activity,
including those found in the
energy,agficulture, Federal, consumer, as
well as industrial sectors. The impairment
of wetlands, ground water sources, and
other critical resources constitutes
pollution, and prevention practices may be
essential, for preserving these resources.
These practices may include conservation
techniques and changes in management
practices to prevent harm to sensitive
ecosystems. Pollution prevention does hot
include practices that create new risks of
concern.
Some "in-process
recycling" may
qualify as pollution
prevention.
1-4
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pollution should be prevented or
reduced at the source whenever
feasible;
pollution that cannot be prevented
should be recycled in an
environmentally safe manner whenever
feasible;
pollution that cannot be prevented or
recycled should be treated in an
environmentally safe manner whenever
feasible; and .
disposal or other release into the
environment should be employed only
as a last resort and should be
conducted in an environmentally safe
manner.
Pollution prevention means "source
reduction," as defined under the Pollution
Prevention Act, ancf other practices that
reduce or eliminate the creation of
pollutants through:
-increased efficiency in the use of raw
materials, energy, water, or other
resources, or .
-protection of natural resources by
conservation.
The Pollution Prevention Act defines
"source reduction" to mean any practice
which:
* ' -reduces the amount of any hazardous
substance, pollutant, or contaminant
entering any waste stream or otherwise
released into the environment (including
fugitive emissions) prior to recycling,
treatment, or disposal; and
-reduces the hazards to public health
and the environment associated with
the release of such substances,
pollutants, or contaminants.
HIERARCHY OF
PREFERRED
POLLUTION
PREVENTION
OPTIONS:
Source Reduction
Recycling
Treatment
Disposal
f
1-3
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Pollution prevention, source reduction, or any other
terms that may apply is basically nothing more than a
common sense approach to managing resources. No
matter what the term, the philosophy is the same:.
reduce the quantity of waste at, or close to, its source.
After all, wastes can be thought of as out-of-place
resources. This philosophy makes good business sense.
Management of pollutants has most often been viewed
as a bottom line issue, a cost incurred after everything
else is paid for. When viewed as a cost associated with
a particular product ,or production line, these costs can
more adequately be identified and reduced, and thus are
less of a drain on a company's financial resources. To
put this in perspective, you might/ in round numbers,
consider how much your operation actually spends on
pollution management. ,
Wasted Raw Materials
Watted Energy
Pollution Control Equipment Costs (for Air, Water.
Solid Wastes)
Debt Service for Capital Equipment
Wastewater Treatment/Air Pollution Control Process
Operating Costs . .
Hazardous Waste Transportation and Disposal Costs
Environmental Management Costs
TOTAL
$
$_
$_
Man th»n you thin*
When considering even one individual process, when
each of the blanks above are filled with an estimate of
pollution control costs and the total is computed, the
results can be quite surprising. This is particularly true
in the iron and steel industry, as we shall see in Chapter
6 Case Studies. Pollution prevention helps to focus on
putting misplaced resources back where they belong;
towards more profitable production rather than down the
drain or into the atmosphere.
For an individual process,
when each line is filled
in, the results can be
quite surprising.
1-6
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In the agricultural sector,
prevention approaches include:
pollution
-reducing the use of water and chemical
inputs;
adoption of less, environmentally harmful
pesticides or cultivation of crop strains with
natural resistance to pests; and
protection of sensitive areas.
In the energy sector, pollution prevention
can reduce environmental damages from
extraction, processing, transport, and
combustion of fuels. Pollution prevention
approaches include:
-increasing efficiency in energy use;
--substituting environmentally benign fuel
sources; and
-design changes that reduce the demand
for energy.
What Pollution Prevention Is Not
As Ed Wailer of the Office of Pollution Prevention (OPP)
indicated in an interview with Water Environment and
Technology, hierarchical policy makes a clear distinction
between pollution prevention and measures that are
applied after wastes are generated. He noted that the
official EPA definition of pollution prevention does not
include any practice that "alters the physical, chemical,
or biological characteristic or the volume of a hazardous
substance, pollutant or contaminant. Thus, off-site
recycling, waste treatment, concentration, or dilution of
waste streams, and the transfer of pollutants from one
environmental medium to another are not considered
pollution prevention measures because they are actions
taken after wastes have been generated.
Environmentally sound recycling is preferred over other
treatment options and disposal should be used only as a
last resort.
Recycling energy
recovery, treatment and
disposal are not
pollution prevention.
1-5
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While it is important to list all'of these groups within a
company who impact on pollution prevention, it is
important that we do not lose sight of the fact that a
.company is made up of individual workers. Pollution
prevention can not happen if individuals do not take the
initiative to make something happen.
When developing a pollution prevention plan, a multi-
disciplinary task force should be assembled that includes
individuals from any group or department in the company
that has a role in the generation of pollution or an
interest in the outcome of the pollution prevention
program. This pollution prevention task force typically is
responsible for:
Obtaining a commitment and a statement of policy from corporate
management
Establishing overall pollution prevention goals (measurable)
. . Prioritizing the wastestreams. facility areas or functional areas for
* assessment .
« Selecting assessment teams .
.. Conducting (or supervising) a pollution prevention assessment
. Conducting (or monitoring) technical and economic feasibility analyses
of favorable option*
Selecting and justifying feasible options for implementation
. Obtaining funding and establishing a schedule for implementation
. Establishing a system to measure progress towards pollution
prevention goals
Monitoring (and/or directing) implementation progress
Communicating pollution prevention success throughout the
organization
What this Manual Is All About
The successful implementation of a pollution prevention
program should result in a consistent .set of procedures
for projects ranging from waste materials man?gement
and overall waste reduction to the implementation of
Responsibilities of a
Pollution Prevention
Task Force
1-8
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What You Can Do
A pollution prevention program affects a variety of
manufacturing and management groups within a
company. In fact, almost everyone within an
organization can, in- some measure, impact the
generation of pollution:
Upper Management sets a corporate pollution
prevention philosophy
Engineering designs the process operations
/
Operations runs the process
Maintenance keeps the equipment in good repair
Material Control determines and organizes material
resources
Purchasing purchases materials
Receiving accepts/rejects production materials
Warehousing stores and distributes production
materials
Facilities Management provides the appropriate
production environment
Quality control ensures customer satisfaction
Accounting watches the bottom line
« Human Resources provides a trained work force
Health and Safety assures a safe work place
Research and Development develops new products
and ideas . .
Legal reads and interprets regulations
Environmental Management picks up the pieces
ALL EMPLOYEES OF
THE CORPORATION
SHOULD BE INVOLVED
IN POLLUTION
PREVENTION
1-7
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The overall goals of the manual are to help the reader to:
Promote .the understanding of pollution prevention concepts
Understand regulatory requirements for pollution prevention
Recognize that pollution prevention, whan applied correctly, will result in a
positive economic impact on the manufacturing process
Understand the multidisciplinary and multi-media nature of pollution
prevention
Understand and be able to identify areas amenable to pollution prevention
Understand and. be able to develop and evaluate specific options for
pollution prevention .
Be able to develop and implement a plan for pollution prevention
This manual is organized in chapters:
CHAPTER 2 describes HOW to DEVELOP A POLLUTION
PREVENTION PROGRAM;
CHAPTER 3 lists the ELEMENTS OF A POLLUTION
PREVENTION PROGRAM; ,
CHAPTER 4 discusses methods to MEASURE PROGRESS
AND MAINTAIN POLLUTION PREVENTION Programs;
CHAPTER 5 discusses the ECONOMIC ANALYSES of a
pollution prevention program; and,
CHAPTER 6 provides CASE STUDY examples.
The APPENDICES provide information on implementation
materials, additional references, an overview of existing
industrial and state waste minimization programs, a
description of the Pollution Prevention Information
Exchange System (PIES), the EPA Source Reduction
Review Project and other relevant background materials.
HOW IS THIS MANUAL
ORGANIZED?
1-10
-------
manaaement programs. To meet this goal, this manual
^as been written9 as an aid in the development of a,
facility-specific pollution prevention plan that can be
Wlted. 55* modifications, to your mill. Inherent in this
plan and set of procedures are protocols for identify ng
and evaluating options 'for pollution prevention figure
1-2 illustrates the development of a workplace waste
reduction program in a simple, easy to understand
format.
WORKPLACE WASTE REDUCTION INITIATIVE
Start Procaa*
DoaaaJnfarCortlnuoua
Dnpowaf Bnployaaa
g«^»^S^«"
Form «Warta Radueten
Ta
CommunicaM Pariormane* to
5matava««andShafahoM«f»
DothaObvkiuB
Warta Haducten Opticrn
T
lmp!«m«nt Action Ran
0«Miop Action Ran far
Samibto SoJutocw-
This manual supplements and complements the Iron and
Steel Conference held in Chicago, October 14, i&,
f992 Members of the industry, and those who serve ,t
consultants, vendors, etc.), a-*^*/^?^
experiences of others in the industry who have applied
£nu ion prevention in their facilities. This manua seeks
?o provide basic information and na9em*n<
needed to initiate or formalize a process and fa
specific pollution prevention program.
1-9
-------
These steps can easily be modified to fit the needs of
each individual mill and/or process. Steps 1 and 2
address the concept of how to develop a pollution
prevention plan and are addressed in this chapter. Steps
3 through 5 deal with the elements of a pollution
prevention plan and are presented in Chapter 3. Chapter
6 covers Step 6, getting the word out on your pollution
prevention success stories. These steps have been
adapted from the EPA Facility Pollution Prevention Guide,
May 1992. Figure 2.1 illustrates an overview of the six
step process.
In order to begin the ambitious task of developing a
pollution prevention program, one must first understand
the way in which a facility works. Intuitively, it is clear
that the industrial processes must be understood before
they can be evaluated for pollution prevention
opportunities/However, unless management, research
and tievelopment, purchasing, and shipping, for example,
are included in a facility assessment, many opportunities
for pollution prevention/activities may be otherwise
overlooked.
It does not matter from where the first rumblings of a
pollution prevention program come. Lower leve
managers, process employees, or individuals at the
executive level can all act as a catalyst. It is, however
important to secure company-wide support to implement
a successful pollution prevention program. Once it has
been established that the development of a pollution
prevention program is worthwhile, the commitment to
begin such a project should be conveyed through a
formal policy statement that establishes the framework
for communicating, to the entire mill, the need and
benefits of a pollution prevention program.
POLLUTION
PREVENTION IDEAS
CAN START
ANYWHERE IN A
COMPANY
2-2
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CHAPTER 2
HOW TO DEVELOP A
POLLUTION PREVENTION PROGRAM
The First Steps
Successful pollution prevention has a well-conceived
planning process as its foundation. The planning process
is comprehensive and continual, affecting most
functional areas of a company. However, it also
qenerally has much in common with the planning for
other aspects of the business. The following ideas
present the basic steps necessary to undertake pollution
prevention planning.
The Basic Steps of
Pollution Prevention Planning
Steo 1- Recognize the Need for Pollution Prevention
Step i. ?ec°9tab|jsn the ponution Prevention Program
Organize a Pollution Prevention Program
Conduct a Preliminary Assessment
Steo 2- Write a Pollution Prevention Program Plan
step *.. vv> LDevel0p p0nution Prevention Plan Goals and
Objectives
Identify Potential Obstacles
Define Individual Roles
Develop schedule
Conduct a Pollution Prevention Assessment
Decide What Steps to Take
Define Pollution Prevention Options
Perform Feasibility Analysis
Write an Assessment Report
Implement the Pollution Prevention Program
Get the Word Out
Measure Progress .
Maintain Pollution Prevention Program
2-1
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Getting Started
STEP 1: RECOGNIZE THE NEED FOR POLLUTION
PREVENTION
ESTABLISH THE POLLUTION PREVENTION PROGRAM
The best place to begin your involvement with pollution
prevention planning is by educating individuals in your
organization, especially those in management, about just
what pollution prevention is and how company pol.c.es
concerning pollution prevention can be Developed.
These steps will lead to the establishment of a pollution
prevention program. In order to convince individuals^
management, or those who hold ultimate fiscal authority
£at pollution prevention should be a goal of the
corporation, successful marketing of the f neff *
pollution prevention is necessary. The following can
serve as an outline to help begin the marketing effort.
Pollution Prevention Saves Money and Energy
Pollution prevention can result in reduced costs.
When less pollution is produced, less storage space is
required, less pretreatment is necessary, fewer
transportation and disposal costs are incurred, and
less paperwork for regulatory tracking is necessary.
More efficient manufacturing operations results in the
use of fewer raw materials and less, energy required to
produce steeL
Pollution Prevention Reduces Potential Liability
If less pollution is produced, there will be less
transported to treatment and disposal facilities w£,ch
may result" in a decrease in the potential liability
associated with future the site clean-up. In addition,
it reduces the potential for the facility to be out of
compliance with local, state and federal environmental
laws Also, by decreasing pollution output, facilities
can typically increase the health and safety of their
Workforce and the surrounding community-
STEP 1
ESTABLISH THE
PROGRAM
Pollution Prevention saves
money and energy
Pollution Prevention
reduces potential liability
\
Pollution Prevention
enhances image
Pollution Prevention
reduces toxics
2-4
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FIGURE 2.1 POLLUTION PREVENTION PROGRAM OVERVIEW
(Adapted from EPA Facilities Pollution Prevention Guide)
E«tabli«h the Pollution Prevention Program
Executive Leva) Decision
Policy Statement
Consensus Building
Organize Program
Name Task Force
State Goals
Do Preliminary Assessment
Collect Data
Review Sites
Establish Priorities
Write Program Plan
Define Individual Roles
Define Objectives
Identify Potential Obstacles
Develop Schedule
Do Detailed Assessment
Name Assessment Team(s)
Review Data and Site(s)
Organize and Document Information
Define Pollution Prevention Options
Propose Options
Screan Options
Do Feasibility Analyse*
Technical
Environmental
Economic
Write Assessment Report
Implement the Plan
Select Projects
Obtain Funding
Install
Measure Progrese
« Acquire Data
Analyze Results
Maintain Pollution Prevention Program
2-3
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Employees' commitment to Pollution Prevention can be encouraged by:
Helping define company goals and objectives.
Reviewing processes and operations to determine where and how toxic
substances are used and hazardous wastes are generated.
Recommending'ways to eliminate or reduce waste production at the
source.
owui ww« . , . i i
Designing or modify forms and records to monitor materials used and
waste.
Finding ways to involve suppliers and customers.
Thinking of ways to acknowledge and reward employee contributions to
the pollution prevention effort.
Adapted from EPA Federal Pollution Prevention Guide
ORGANIZE A POLLUTION PREVENTION PROGRAM
The'next step in developing a plan is to organize the
staff that will make up the pollution prevention team. It
is important to select a multi-disciplinary team from
throughout the mill. Obtain a copy of the facility
organization chart to select the individuals who might
participate on the team. It is important to seek upper
management participation and to ask for and utilize those -
who might volunteer in this effort.
Careful selection of staff who will participate in such an
effort will pay dividends later in the process. In
particular, their attitude towards the effort will have a
direct impact on the eventual success of the effort. The
team may include personnel from:
Accounting
Engineering
Environmental Management
Facilities Management
Health and-Safety
Human Resources
Legal
Maintenance
Material Control
Operations
Purchasing
Quality Control
Research and Development
Receiving
Upper Management
Warehousing
All individuals who are invited or volunteer to assist with
the development of a pollution, prevention plan should
SELECT A
MULTIDISCIPL1NARY
POLLUTION
PREVENTION TEAM
2-6
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Pollution Prevention Enhances the Corporate Image
Citizens are much more aware of industrial pollution
output, due to increased public awareness and
community Right-to-Know laws. Citizens are looking
for the industry to reduce the amount of toxic, and
other wastes or emmissions. By implementing and
publicizing pollution prevention activities, the iron and
steel industry can improve their standing with the
regulatory community and with citizens.
Pollution Prevention Reduces Toxic Discharges
Awareness of the dangers associated with hazardous
materials has increased the research into alternatives
to such materials. Substitutes exist for many of the
toxic chemicals in use today in a typical mill.
1 Pollution prevention assessments can identify these
hazardous materials and reduce their use within the
process operations.
Once management recognizes and supports the need for
pollution prevention, a clear corporate commitment
needs to be conveyed to all employees. A written policy
statement should be prepared, which clearly outlines.
why the company is implementing a pollution prevention
plan, what will be done to implement the plan, who will
implement the plan, and asking for each ind.v.dual s
support of the program. Samples of policy statements
are included in the Appendix.
Employees will feel committed to pollution prevention
when they are encouraged to participate in the
development of a plan as illustrated below:
2-5
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Pollution Prevention Preliminary
Assessment Check List
I Division: .
Data completed: _____ :
Person completing form: -j
INSTRUCTIONS:
Check the appropriate answer for each question. ..
ttNTmVansS the company business plans are promoting pollut,on'
'Ato means that the company business plans are not promoting po lubon prevenbon.
Not surT means that thecompany needs to further evaluate the plan ,n that area _
^-^^^^^^^^^^^^"^"'^^^^^^^^^^ _ -
I A. OPERATIONS PUN EVALUATION
YES
11. Are workers and management developing a plan to promote waste reduction in
your company? .
2. Are business procedures designed to promote source reduction? -
3. Is the company recycling every waste that.it can? ,
| 4. Does the company know the quantity of waste (liquid, solid, gaseous)
produced by each process?
| 5. Is the company shop kept dean and orderly to reduce the chance of spills and
increase efficiency? -
Does the company have a recycling.program for computer, ledger, and mixed
paper?
I 7. Has the company determined that air emission waste produced in the plant
can or cannot be recycled? .
8. Are process wastes segregated to enhance recovery of raw materials?
-9 Do workers know which process reduction produces waste?
10'. Does the company operations plan indude periodic waste reduction audits?
11 , Does your company maintain MSDSs to evaluate raw mat<*** Prior to
' purchase to ensure you are using the least toxic matenal possible?
12. is Inventory stock limited to prevent possible spills and to avoid over
purchasing and other waste?
13. Does the company request pre-purchase information on the waste generating
potential for new equipment?
14.
waste? r 1 r i
, 15. Does the company attempt to exchange wastes that cannot be reduced at the U [1
source?
116 Can fire suppression systems handle a major emergency involving the
hazardous matenal used and waste produced?
117. Are storage areas designed to minimize earthquake damage, control spills,
and other mishaps? .
18.. Are altworkers trained about what to do in the event of a hazardous materials
incident? n r Y
L19. Does company policy.promote employee training and deve.opment in the area [] 11
of waste reduction?
NO NOT
SURE
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n
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-------
have an understanding of, and an interest in, pollution
prevention. They should want to participate, since a
motivated and knowledgeable team is very important to
the,success of pollution prevention plan implementation.
Once the entire team is selected, one individual should
be selected from among this group to act as team leader.
A leader is necessary to provide the guidance to keep the
team and the planning process moving on track. The
leader should have both the influence and authority to
insure that pollution prevention is adopted by the
corporation. Other individuals should be appointed to
serve as leaders of specific tasks during the development
of the pollution prevention plan, according to their skills
and interests. For example, a manager from the electric
arc furnace operation might be selected to conduct a
waste audit while the purchasing department
representative might be responsible for organizing an
evaluation of possible alternatives for hazardous
materials substitution.
i
CONDUCT A PRELIMINARY ASSESSMENT
Once the pollution prevention team has been selected, .it
Is valuable to sit down and assess the facility in terms of
pollution prevention opportunities. The following
Pollution Prevention Preliminary Assessment Check List
can be distributed to different divisions within your mill
to begin a preliminary assessment. The answers may
well prove useful in preparing the goals and objectives
for your pollution prevention plan. It will also assist the
pollution prevention team to review already available
data and establish ways to assess that data. It is a start
and can be adapted to your mill by adding additional
questions at the end of each section. [This form is
included in Word Perfect 5.1 format on the enclosed
computer disk for your use and modification, ed.J.
In this first phase of data collection, the objective is to
get an overview.o.f the processes and operation areas
where pollution prevention can best be applied. Another
useful form is worksheet 2, Site Description, included in
the Appendix. Data collection just for the sake of
accumulating data is not very useful. In fact, much of
SELECT A TEAM
LEADER WITH A
STRONG INTEREST IN
POLLUTION
PREVENTION
THE OBJECTIVE OF
THE FIRST PHASE OF
DATA COLLECTION IS
TO OBTAIN AN
OVERVIEW
2-7
-------
the data may already be available as part of your
response to existing regulatory requirements. A multi-
media approach, including air, water, and solid waste ..
Emissions and releases is most effect.ve. Sources of
information to consider includeregulatory'report, from
the National Pollutant Discharge Ehm.nat.on System
(NPDES), SARA Title 111 reports or the Toxic Release
nventories (TRI). The new Form R, used to track these
releases (SARA Title III, Section 313^ ^quires the
reoorting of pollution prevention efforts. bteei
combes which have volunteered to participate ,n
EPA's 33/50 program have accumulated data which may
be valuable.
STEP 2: WRITE A POLLUTION PREVENTION PROGRAM
PLAN
DEVELOP POLLUTION PREVENTION PLAN GOALS AND
OBJECTIVES
With the answers to the above questions in hand, the
next step is to establish goals and objectives to defme
the long term direction for the pollution prevention
nrofl am These goals and objectives will serve as a
S to get the project started and help evaluate the
^gVess over an extended time period By mitiaHy
establishing a set of realistic goals and object.ye; the
team has a place to turn if the project gets off track.
by which to -measure progress. Most
settingup pollution prevention planning goals,
need to be achievable, challenging, and flex.We.^ Over
Srhe, a facility's focus may change, and econom.cs that
on?e were unfavorable may become^promismg. Goals
should be periodically reviewed and adjusted to keep the
program up to date as lessons are learned.
ALREADY
AVAILABLE DATA
NPDES Reporting
TRI Reporting
33/50 Reporting
>.
STEP 2
2-10
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B.
1.
2,
3.
4.,
RECORD-KEEPING PLAN EVALUATION
Are records maintained on the amount of raw material used per process to [ ]
monitor process efficiency?
Are logs maintained on the types and the quantities of waste produced so that [ ]
specific wastes can be targeted for waste reduction?
Are MSDSs or equivalent information used to help identify possible hazardous [ ]
waste stream?
Does the company have written plans and procedures to document plant [ ]
operation procedures and waste reduction policies?
[]
[]
ti
C. FINANCIAL PLAN EVALUATION
1. Are waste generation and disposal costs included in profit and loss
statements?
2. Have waste generation costs been determined for each process in the
business?
If yes, do you charge the costs directly to the process?
[]
n
n
3,
D.
1.
2.
3.
n
MARKET PLAN EVALUATION'
Do you and your workers recognize the importance of proper materials
management and wastes/emmisions reduction?
Do your marketing strategies incorporate a positive public image related to the
reduction of emmisions?
Do you publicize your company's efforts to reduce the.production of all
environmental emmissions?
[]
U
[]
[]
[]
Adapted from Profiting from Waste Reduction in Your Small Business. David Wiggtesworth, Alaska
Health Project 1988 ________^=__
u
-------
with the generation arid treatment of waste
materials, Because innovative pollution prevention
programs can result in the elimination of entire waste
streams, costly control equipment would, not be
necessary. However, companies may have already
installed the equipment, or the equipment may be
required by law. The EPA is attempting to change
this. As mandated in the Pollution Prevention Act of
1990 the Agency is implementing the Source
Reduction Review Program (SRRP). This program,
outlined in the enclosed pamphlet, has as its goal to
foster the following:
The use of source reduction measures is the
primary means of achieving compliance.
initially, the project focus is to ensure that
source reduction measures and multi-media
issues are considered during the development
' of air, water, and hazardous waste standards
affecting certain industrial categories. For the
long term, the project aims to provide a
model for the regulatory development process
throughout EPA.
Institutional
Companies may not fully implement pollution
prevention strategies, due to corporate reluctance to
change production processes for fear of degrading
product quality or quantity. More often than not
their accounting practices do, not h.ghl.ght the need
for pollution prevention. In addition, companies do
not typically promote their successes with pollution
prevention projects due to competition from other
firms Because pollution prevention is
multid'iscipJinary by nature, traditional organizational
structures often do not accomodate plans and
activities that cut over a variety of departments.
Both industry and government need to re-examine how
each looks at pollution generation and pollution
prevention. The EPA has moved towards helping industry
Overcome many of these barriers. They have def.ned
much of what is and is not classified as pollut.on
OVERCOME BARRIERS
TO PROMOTE
POLLUTION
PREVENTION
2-12
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IDENTIFY POSSIBLE OBSTACLES
While pollution prevention is a relatively simple concept,
and sometimes may be easy to implement, many times
there are barriers which impede the success of such a
plan. Barriers can be' economic, technical, regulatory,
and very often institutional. Examples of each may
include:
Economic
Financial constraints may prohibit a company from
making the investments necessary to. implement a
pollution prevention plan. The company simply may
not have the capital required to upgrade inefficient
processes or have the staff to discover the different
options. For example, when faced with the decision
to make changes to rolling mill operations to improve
product quality or reduce pollution, product quality
will win every time. A means of permitting the
pollution prevention project to "compete"
economically with product improvement is the
challenge when : capital dollars available for
investment are scarce. One means of pursuing this
is through total cost accounting, which assures that
all waste generation costs for all environmental
media have been determined for each process and
that those costs are charged directly to the process.
Technical
Pollution prevention plans do not often consist of
equipment that companies can purchase, take out of
a box, read the instructions, and install. Limited
flexibility in process inputs, lack of space within a
facility to incorporate new recovery equipment, or
sirnply lack of information and assistance in
conducting a pollution prevention audit can all be
difficult obstacles to overcome.
Regulatory
Government regulations have typically taken an end-
of-the-pipe or top-of-the-stack approach in dealing
OBSTACLES TO
POLLUTION
PREVENTION
Economic
Technical
Regulations
Institutional
2-11
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Specify use of non-hazardous materials for new
facility'construction, when possible.
Specify use of non-hazardous materials for
production processes, when possible.
' Meet with suppliers on a regular basis to discuss
product substitution for hazardous materials.
Design chemical storage areas with appropriate
containment and with no connections to any dram.
(. '
Decrease water flowrates where possible by using
techniques such as:
- Water reuse by processes requiring lower quality
water;
- Use of spent process waters as heat transfer
media;
- Wastewater reuse-for feedstock makeup water;
- Compatible wastewater used ;for process
equipment cleanup;
- Pump seal water used for rinse makeup water;
and
- . Use of treated wastewater for makeup, water
where possible.
Properly segregate wastewaters that significantly
differ in composition or concentration.
.' Provide adequate spill containment structures that
will route any spill directly to a waste treatment
system or to a segregated containment area to lessen
the possibility for widespread contamination.
r
2-14
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prevention. They"have established an Office of Pollution
Prevention, which, among other work tools, serves as a
repository for documentation of pollution prevention
projects, and undertakes their own research into several
areas of pollution prevention. Industry needs to
capitalize on the opportunity to explore various options
for pollution prevention activities rather than be forced to
accept a required technology under pollution control
laws. Both the EPA and industry need to continue to
work together, however, to reduce or eliminate these
barriers. In Region V, this conference serves as one step
in reducing the barriers to pollution prevention.
DEFINE INDIVIDUAL ROLES
Once the company is committed to the notion of
pollution prevention, the organization of a program to
identify and develop pollution prevention opportunities
will-be built upon the foundation provided by the firm s
functional organization. Each functional group within the
organization must be called upon to contribute to the
overall goal of effective pollution prevention. Roles for
each functional group are outlined below.
Management's role in pollution prevention is to decide to
establish a pollution prevention program and upper
management should:
convey the commitment to pbllution prevention to all
employees through a formal policy statement.
.. provide resources and support to the pollution
program
Engineering's role in pollution prevention is site and
process specific. Engineering staff should:
Consider waste minimization in each step of product
and process design and coordinate product design
with process engineering.
: Document materials used in each step of the
process.
FUNCTIONAL
GROUPS THAT
IMPACT ON THE
MILL'S POLLUTION
PREVENTION
PROGRAM
Management
Engineering
Manufacturing
Maintenance
Materials Control
t Purchasing
r Receiving
Warehousing
Facilities
Management
Accounting
Human
Resources
Research 8T
Development
Legal
Environmental
Management
2-13
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Evaluate equipment maintenance procedures to
insure that equipment functions at peak efficiency.
. Assure that all valves and pipes are leak free.
Assure that all sources of fugitive emmissions are
eliminated or reduced.
Material Control designs pollution reducing materials into
the process. This function should:
Project accurate chemical use
maintain a minimum inventory.
requirements to
Establish a minimum/maximum chemical inventory
(not to exceed some pre-determined level at any one
time in inventory).
Purchasing's function is to procure the raw materials and
equipment necessary to run the mill. Some possible tips
for this function include:
Use as few chemical suppliers as possible to achieve
better prices and to ensure that suppliers are familiar
with your requirements
Purchase a chemical only if it has been approved for
purchase by your Environmental Management group
and if a Material Safety Datasheet (MSDS) has been
received and reviewed.
Ensure that chemical container size is consistent with
normal chemical use; chemicals should be purchased
in as large a container as practical in order to
minimize the number of containers requiring disposal,
but not so large as to prohibit the complete emptying
. of the container.
Arrange for chemical deliveries on a just-in-time basis
. in order to minimize on-site storage requirements.
Use a local chemical supplier if possible.
Require chemical suppliers to accept any shipment
rejected for any reason and accept for return, even at
2-16
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Make sure that the mill's spill prevention plan is up to
' date and reviewed regularly.
Investigate and evaluate the economics of barcoding
techniques to track chemical materials from entry
into the mill to their use and ultimate disposal.
Operations (Manufacturing) role is to make the product
but reduce waste emissions to the lowest possible level.
Pollution prevention staff should:
Segregate waste streams.
Use equipment properly and efficiently.
Report any defective equipment.
* Ensure adequate spill prevention and containment in
production/chemical use area.
Replace chemical solutions on a regular schedule, but
only as required by the contamination resent.
Use trained personnel for chemical transfer
operations.
If possible, automate chemical supply to production
line to ensure chemical conservation and accurate
chemical dosage.
. Monitor chemical use per unit of production and
establish an acceptable range for usage.
Maintain contact with the environmental
management group.
Maintenance keeps the mill and equipment in good repair
to assure optimum performance for mechanically based
pollution prevention options. Staff should:
Insure that all water use is minimized with proper
valving and spray nozzles.
2-15
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approved chemical list from the appropriate authority.
Have a well developed and documented hazardous
chemical spill response plan to minimize
contamination in the event of a chemical spill.
Warehousing has the responsibility to. store 'and
distribute production materials, spare parts, etc. They
should:
. Store chemicals properly or move to use_ area
immediately upon receipt, to lessen the potential for
spills.
Plug any drains to sanitary storm or process sewers-
leading from storage area, or assure that bulk storage
areas are properly designed.
Store chemicals in original '-leak-free, properly
identified containers only.
. Minimize available storage areas to -discourage
unnecessary storage.
Store chemicals in the same place consistently and
away from other materials.
Maintain, inventory information in the storage area.
Maintain maximum/minimum quantities for inventory
and post values.
Ensure that all materials received are properly
labelled.
Not dispense any chemicals in the chemical storage
. area. ','
. Conduct a chemical product inventory every month
and compare .with manifest.
Return unused chemicals to the supplier or to a
proper chemical storage site.
2-18
-------
some cost, any unused or unusable chemical.
> Require chemical suppliers to propose nonhazardous
substitute chemicals for engineering evaluation.
» Notify receiving personnel when a chemical has been
purchased and when delivery is expected, providing
information concerning container size, weight,
MSDS, and any special information.
Negotiate for waste disposal services from the
chemical supplier, as a condition for purchase.
Arrange for use of returnable chemical containers as
a condition of purchase.
Monitor receipt, of and disbursement of, chemicals
by use of a log.
Do not choose a waste disposal firm or waste
transporter based on cost alone; seek advice or
direction from a knowledgeable source. Choice of
such a firm is better left to Environmental
Management with Purchasing performing the price
negotiation.
Receiving's responsibility is to accept appropriate
production materials. The receiving staff should:
Receive only those chemicals that have been ordered
and only those meeting the specifications detailed on
the purchase order, such as container size, etc.
Receive only those chemicals for which there exists
an MSDS and a company authorization to purchase.
Never receive
containers.
damaged or leaking chemical
Document receipt of all chemicals immediately,
including transporter information, etc.
Maintain copies of all MSDS and the approved
chemicals list; request periodic updates of the
f
2-17
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Accounting's function in pollution prevention cannot be
overemphasized. In fact, adopting accounting standards
which fairly represent pollution prevention projects can
often be the single most important criteria for accepting
or'rejecting a proposed pollution prevention project.
Accounting should:
Assign costs for waste disposal to the area of
operation which generates the waste budget control.
Monitor and report all costs associated with
hazardous and nonhazardous waste activities,
Establish an acceptable return on investment for
waste minimization capital projects to evaluate costs
associated with potential liabilities due to hazardous
waste activities.
investigate insurance carrier considerations due to
activities associated with handling hazardous waste.,
Human Resources provides a trained work force to
implement the adopted pollution prevention plan.
Train all employees in the concepts of pollution
prevention. ' .
Encourage all staff to suggest pollution prevention
projects.
Develop an employee incentive program to foster
employee involvement.
.. Minimize the number of personnel involved in
hazardous materiaf handling
Ensure adequate and routine training of hazardous
material handlers and proper use of personal
protective equipment
Research and Development is involved with the
development of new products or new production
methods. Their involvement in the pollution prevention
2-20
-------
For the issuance of chemicals, the following may apply:
Dedicate a person(s) to issue chemicals
Issue chemicals to approved personnel only
Document all chemical issuancesv
Update existing inventory
Rotate stock
Facilities Management role is to assure thtat proper
utilities are available to run the facility and that water
conservation and energy efficient processes are used
wherever possible. The facilities management, staff
should:
Implement a water reuse program.
' Assist in segregating various waste streams.
Minimize the use of water conditioning chemicals or
use nontoxic/nonhazardous corrosion inhibitors and
bactericides.
Develop and adhere to a preventive maintenance
program for all units requiring replacement of
potentially hazardous materials.
Maintain inventories and use rates of lubricating oils,
etc., consistent with a preventive maintenance
program.
* Use degreasing solvents, where possible, that are
recyclable by the original supplier.
. Minimize the amount of waste oils stored on site.
. Use nonhazardous cleaners and degreasers where
possible.
. Use industrial cleaning services for rags, uniforms,
etc.
2-19
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ESTABLISH PRIORITIES AND DEVELOP SCHEDULE
Assigning priorities to processes, operations, and
materials as noted below,, will focus the remainder of
the pollution prevention plan development effort. When
priorities are'set at this stage, they w.H gu-de the
selection of possible projects .for the detailed
assessments. Criteria may be targeted beeed on the
volume of waste produced or the cost of disposal
Regulatory concerns such as the RCRA land d.sposal
restrictions or SARA Title 313 chemicals may also gu.de
prioritization.
Typical considerations ., prioritizing waste streams
-------
planning process is vital. Research and Development
staff should:
* Consider pollution generation . and pollution
prevention when undertaking development of a new
or refinement of an existing processes.
Devote resources to evaluating alternative methods
for steel making processes; e.g. consider the
research on dezincing galvanized steel currently
underway by numerous organizations.
Legal can be involved in the pollution prevention planning
effort as well. The legal staff can:
- Use their knowledge of environmental regulations
and requirements to help identify areas where
pollution prevention activities can save money by
reducing corporate liability.
Environmental Management generally has been left to
"pick up the pieces" and deal what is left over. Now,
with the advent of pollution prevention programs, they
are more" involved, providing support and resources and
sometimes leading the pollution prevention effort.
Prepare an environmental impact statement with the
assistance of engineering for each product and
process to ensure use of non-hazardous materials
whenever possible.
Conduct the hazardous material management and
reduction program plant-wide.
Perform regular environmental compliance audits.
Review hazardous materials data from Form R and
evaluate for pollution prevention opportunities.
Maintain contact with operations.
f
I
2-21
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In conducting a detailed assessment of your facility, it is
necessary to:
Select assessment teams;
Review .data and sites; and
Organize and.document data.
SELECT ASSESSMENT TEAMS
A detailed assessment focuses on each operational area
from materials handling, to operation of the furnaces, to
the rolling mills and beyond. Assessment teams are
developed, assigned to each identified area of operation,
and given the responsibility to gather and develop data
and. plans for later evaluation. The first task step in this
process is to recruit members of the pollution prevention
task force.
Using several teams presents some logistical problems,
but spreads the work load among more staff members,
most of whom will probably not have a lot of time to
devote to this effort.. The team leader will typically be
an individual with experience and hopefully some
pollution prevention experience. Teams are normally
composed of three to five members. A typical team for
a rolling mill operation might include the team leader
(environmental engineer), the rolling mift supervisor, a
maintenance engineer, the lead foreman and a shift
leader.
. In addition to a candidate's qualifications based on their
expertise, it is also important that they have an interest
and commitment to making the pollution prevention
program work. Creative thinking is critical.
REVIEW DATA AND SITE{S)
In the preliminary assessment, data that was readily
available-from NPDES or SARA Title III reports was
collected and reviewed. In this more detailed phase,
additional data sources will be identified and in some
cases sampling may be undertaken. Site review
3-2
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CHAPTERS
ELEMENTS OF A POLLUTION PREVENTION PROGRAM
In simple terms, a pollution prevention program is the
application and integration of proven engineering,
operation, and management techniques oriented toward
the goal of improving process operating efficiency to the
degree that wastes are minimized, first at the source and
then by a variety of other techniques as noted in the
definition of pollution prevention. in Chapter 1. This
chapter describes the basic steps that need to be taken
to develop" a pollution prevention program.
For example, an effective pollution prevention program
for hazardous wastes will address all issues surrounding
the specification, purchase, inventory, storage, issuance,
and communication of all chemical materials used in
production, maintenance, and general facility operations.
The goal of minimizing hazardous wastes is to apply
effectively, and efficiently the basics of sound
engineering and management to reduce this use. Similar
examples can be developed for many other procedures.
This chapter outlines how to do it.
STEP 3: CONDUCT A POLLUTION PREVENTION
ASSESSMENT
While -a pollution prevention assessment could be a
simple walk-through survey of the mill to visually identify
opportunities for waste reduction, it should be a more
technical process which involves waste stream sampling
and engineering analysis. The assessment can focus on
only one waste stream and process, or it can become an
extensive mill-wide analysis. Whichever approach is
taken, it is important to understand the basics of process
operations before beginning the assessment. While the
pollution prevention audit may uncover compliance
issues, one purpose of this audit is to understand and
identify pollution prevention opportunities.
3-1
-------
ORGANIZE AND DOCUMENT DATA
It is important to walk through your facility to observe
manufacturing operations. By conducting a walk-
through, the audit team will be able to verify the
information obtained earlier, as well as collect additional
information, and get a clear profile of the waste
generating processes and operations in the business. A
walk-through will also provide the audit team a chance
to objectively look at their facility. The use of
"videotapes and pictures is particularly recommended.
In the more detailed audit, you will want to collect
additional data. Check with appropriate mill offices for
information which may be available to help your audit
team complete this task. They include:
Accounting Information
Annual records
Available lab analyses
Emissions inventories
Employee interviews
Environmental compliance audits
Equipment specification
Form R reports for SARA Title III
Inventory records
MSDSs
Operating manuals
Operating logs
Past inspection reports
Permits
Product composition sheets
Purchasing records
Shipping papers
Vendor information
Waste manifests
The following is a list presenting a range of waste types
that may be associated with integrated iron and steel
making processes. The intent of this list is to provide the
audit team with clues on what form your pollution may
take. They include:
Air emissions (point source and fugitive)
Hazardous wastes {reactive, ignitable, corrosive,
toxic, radioactive)
Heat and/or energy loss
Maintenance and cleanup waste »
. Obsolete, out-dated stock
Solid wastes (paper, boxes, trash)
Spills and container leaks
Spoiled production runs
System leaks (pipes, joints, etc.)
3-4
-------
guidelines are noted in Table 3.1. Table 3.2 illustrates
questions you might want to ask as the site review is
conducted. .
TABLE 3.1 SITE REVIEW GUIDELINES
Prepare an agenda in advance that covers all points that still require clarification. Prov.de staff
contacts in the area being assessed with the agenda several days before the site inspection.
Schedule the Inspection to coincide with the particular operation that is of interest.
Monitor the operation at different times during all shifts, and if needed, during all three shifts,
especially when waste generation is highly dependent on human .nvolvement.
the operators, shift supervisors, and work leaders in the assessed area. Discuss the
aspects of the operation. Note their familiarity with the impacts their operation
of interest. Kctures are valuable in the .
drawingTMany details can be captured in pictures that otherw.se could be forgotten or
SETS. *£££&£% of the operation. Check for signs of spills or .eak, Visit the
main^nance shop and ask about problems in keeping the equipment operatma-effiaently. Assess
^
SniSv. controls, such as cost accounting procedures, material purchasing
procedures, and waste collection procedures. . .
.pt.cl irom:
Offe?" W«t.
lU5IoinititutFfef
F.b. 1991.
ining and Application. Haiwc
Guid. to Pollution
no«ot«
QUESTIONS TO ASK DURING A. SITE REVIEW
SS-S-S-SSSSSSISS^^
What is the composition of the waste streams and emissions generated?
What is their quantity?
From which production processes or treatment system do these waste
streams and emissions originate? ^..^^no?
Which waste materials and emissions fall under env.ronmental regulations?
What raw materials and input materials in the production process generate
these waste streams and emissions?
How much of a specific raw or input material is found in each waste
WhaTouantity of materials are lost in the form of volatile emissions?
How efficient is the production process and the various steps of that
AreCany?unnecessary waste materials or emissions produced by mixing
mateSs-which could otherwise be reused with other waste matena.s?
Which good housekeeping practices are already in force in the company to
limit the generation of waste materials? ««,»?
What process controls are already in use to improve process eff.c,ency?
\dapted from
acility Pollution Prevention
f
3-3
-------
Later in the process you will record the possible options
you have selected on the Options Description Form
(Worksheet 8 included in the Appendix). This will be
used to describe the option and make an assessment of
its feasibility. Independent thinking, as well as
brainstorming by team members, will encourage the
most productive development of options. This requires
effort on your part to do research, discuss among the
team and seek out additional information from
knowledgeable individuals and groups.
DATA SOURCES
There are many sources of possible options that you may
want to consider. These include state information, EPA
Region V sources and some information from local
governments. Most notable for its possible potential is
the Pollution Prevention Information Exchange System
(PIES) maintained by the EPA. The system basically
includes:
PIES
Pollution Prevention Database
- Case Studies and References
- Corporate Program
Summaries
- Directory of Contacts
- Federal & State Program
- Summaries
- Global Climatic Change
Databases
- International Calendar
Bulletins
Mini Exchange
Online Library
Message Center
The PIES system can be accessed by personal computer
and a modem. Additional current information regarding
OTHER SOURCES OF
OPTIONS
AMERICAN IRON
AND STEEL
INSTITURE
Published Literature
-Technical
Magazines
- Trade Journals
- Government
Reports
Other Companies
Consultants
3-6
-------
Water treatment byproducts
Waste water
Wastewater sludge
Finally the following list from the Johnston Works of
Bethlehem Steel illustrates all of the material that is
currently (1992) being recycled. This list provides some
excellent suggestions for possible pollution prevention
activities at your mill.
RECYCLING
OPPORTUNITIES
FROM JOHNSTON
WORKS OF
BETHLEHEM STEEL
YOU MIGHT
ADOPT
ELECTRIC ARC FURNACE DUST
LEADED STEEL BAGHOUSE DUST
WOOD PALLETS
LEAD-ACID BATTERIES
MATERIALS HANDLING SYSTEM
DUST
SOLVENTS
GREASE
46" MILL SCALE
WASTE OIL
TIRES
MILL SCALE
OFFICE PAPER
GLASS
ALUMINUM CANS
SLAG
STEEL SCRAP (INCLUDING EMPTY
DRUMS)
COPPER WIRE & TUBING
BRASS FITTINGS, VALVES, TUBES, ETC.
STAINLESS STEEL
PIT BOTTOM MATERIAL
FORK TRUCK TIRES
ALUMINUM DROSS
LADLE FURNACE BAGHOUSE DUST
VACUUM FILTER CAKE
GRAPHITE SCRAP
GRINDER SWARF
STEP 4: DECIDE WHAT STEPS TO TAKE
DEFINE POLLUTION PREVENTION OPTIONS
Once all the data is collected and organized, and process
diagrams have been developed, waste reduction options
can be identified for your mill. This is the opportunity for
the audit team(s) to be creative. The audit team should
consider a comprehensive list of pollution prevention
opportunities, no matter how unworkable or costly they
may initially seem. When generating options, rt is
important to focus on measures that reduce waste at the
source or promote on-site recycling. Failure to reduce
the volume of wastes produced in the mill defeats the
ultimate goal of waste reduction efforts. You may be
tempted by waste treatment alternatives. However,
such methods are not considered waste reduction as
thev do not eliminate waste within the process, as
previously noted in the EPA pollution prevention
definition discussed in Chapter I.
STEP 4
DON'T BE TEMPTED BY
WASTE TREATMENT
ALTERNATIVES - THEY
ARE NOT POLLUTION
PREVENTION
3-5
3 A'
-------
CREATE A PROCESS DESCRIPTION
DEVELOP PROCESS FLOW CHART
DEVELOP ORGANIZATION/ RESPONSIBILITY
CHART
Process Flow Charts can be developed for virtually any
process by following a few simple rules:
Include all process operations
Include all utilities
Include a representation of all inputs and outputs
Include material- and energy-balance information
Number each process flow stream
A complete process operation flow chart must include all
process steps necessary to transform raw materials into
a finished product and other process steps required for
waste treatment and utilities management. Some typical
steps might include the coking operation, conversion or
rolling processes.
Each process step can be simply viewed as:
Raw Materials
Process
Operation
Finished Product
Wastes
Figure 3.1 represents a complete typical process
operation flow chart. The various streams identified
represent the pathways that materials travel through a
process. Materials and chemicals are consumed or
transformed by the process, can be used by the process
or can exit the process unaltered. Worksheet 3, Process
Information, in the Appendix can assist in documenting
general process information. Worksheet 4,
FORMS
Worksheet 3
PROCESS INFORMATION
3-8
-------
this system including access phone numbers, etc. is
included in the-Appendix.
Although the outline and data sheets provided by EPA
are helpful, it is important that the assessment team
leader thoroughly understand both the organization and
the manufacturing operations to fully capitalize on the
pollution prevention opportunities vailable.
DEFINING THE PROCESS
In order to describe possible options, it is valuable to
construct a process flow sheet for each manufacturing
process when beginning a pollution prevention
assessment. Such a flow sheet will help identify the key
processes associated with your mill. Material inputs to
each step, maintenance operations, and waste outputs
should be identified. From the data collected m.Step 3,
wastes and other pollution releases can be considered
process losses.
Although 100 percent efficiency from a process is
probably not possible, a conceptual diagram of each
process can help maximize process efficiency. Inputs can
be lost through a variety of circumstances. Non-
standard raw materials represent a loss of inputs. More
standard losses include air emissions, wastewater
production, solid waste generation, chemical spills or
leaks, and accidents. Typically, once the process is fully
described, potential losses can be identified and tracked
more easily.
One approach of particular usefulness in preparing an
audit is to examine the. total plant operation by viewing
the entire operation as a "black box" with total inputs
(raw materials) and outputs (finished products and
wastes). More detailed analyses then would consist of
constructing additional "black boxes" for each step
outlined in the ovearall process diagram. In using the
"black box" analogy, the search for emission outputs and
consequently for pollution prevention options begins with
examination of all inputs that could possibly become
wastes.
CONSTRUCT A
PROCESS FLOW SHEET
FOR EACH
MANUFACTURING
OPERATION
3-7
Ate
-------
Missouri '.--
Missouri Environmental Improvement and Energy
Resources Authority
P.O. Box 744
325 Jefferson St. /
Jefferson City, MO 65102
(314)751-4919
Waste Management Program
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
(314)751-3176
Montana
Department of Health and Environmental Sciences
Room A-206
Cogswell Building
Helena, MT 59620
(406)444-3454
Solid and Hazardous Waste Bureau
Department of Health and Environmental Sciences
Cogswell Building
Room 8^201
Helena, MT 59620
(406)444-2821
Nebraska
Hazardous Waste Section
Nebraska Department of Environmental
Control
P.O. Box 98922
Lincoln. NE 68509-8922
' (402)471-2186
Nevada .
Nevada Small Business Development Center -
Technical Assistance Program
Business Environmental Program
College of Business Administration. MS032
University of Nevada Reno
Reno, NV 89557-0100
(702)784-1717
(800) 882-3233 (Nevada only)
State Energy Conservation Program
Office of Community Services
Nevada Energy Program
Capital Compiiix
400 W.King
Carson City, NV 89710
(702)687-4990
New Hampshire
New Hampshire Department of
Environmental Services
Waste Management Division
Planning Bureau*
6 Hazen Drive .
Concord NH 03301-6509
(603) 271-2901
(603)271-2902
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
. 28 West State Street . .
Trenton, NJ 08608
(609) 292-1459
(609)292-1026
Hazardous Waste Advisement Program
New Jersey Department of Environmental
Protection & Energy
401 East State Street
Trenton, NJ 08625
(609)777-0518
New Jersey Institute of" Technology
Hazardous Substance Management Research
Center
Advanced Technology Center Building
.323 Martin Luther King Jr. Boulevard
University Heights
Newark, NJ 07102
(201) 596-5864
New Mexico :
Economic Development Department
Bataan Memorial Building
State Capitol Complex
Santa Fe. NM 87503
(505)827-0380
-------
-------
Idaho ,
Division of. Environmental Quality
Department of Health and Welfare
1410 North Hilton Street
Boise, ID 83720-9000
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy & Natural
Resources . -
One E. Hazelwood Drive
. Champaign, IL 61820
(217)333-8940
Industrial Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Illinois Institute of Technology
3201 South Dearborn
Room 103 Alumni Memorial Hall
Chicago, IL 60616
(312)567-3535
Illinois Environmental Protection Agency
Office of Pollution Prevention.
2200 Churchill Road
P.O. Box 19276
Springfield. IL 62794-9276
(217)782-8700
Indiana
Environmental Management & Education Program
School of Civil Engineering
.Purdue University
2129 Civil Engineering Building
West Lafayette. IN 47907-1284
(317)494*5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317) 232-8172
Iowa
Iowa Department of Natural Resources
Wallace State Office Building
900 East Grand Avenue
DCS Moines. IA 50319-0034
(515) 28.1-5145
Iowa Waste Reduction Center
75BRC
University of Northern Iowa
Cedar Falls, IA 50614-0185
(800)422-3109
(319)273-2079
Iowa Waste Reduction Center ,
University of Norther Iowa
75 Biology Research Complex
Cedar Falls. IA 50614
(319)273-2079
Kansas
...,'"' \
Division of Environment
Department of Health and Environment
Forbes Field, Building 740
Topeka, KS 66620
(913)296-1535
Engineering Extension Program
Ward Hall 133
Kansas State University
Manhattan, KS 66506 .
(916)532-6026
Kentucky
Waste Minimization Assessment Center
Department of Chemical Engineering
University of Louisville
Louisville, KY 40292
(502) 588-6357
Kentucky Partners
Room 312 Ernst Hall
University of Louisville
Louisville, KY 40292 - '
(502) 588-7260 .
Louisiana
Department of Environmental Quality
Office of Solid, and Hazardous Waste .
P.O. Box 82178
Baton Rouge, LA 70884-2178
(504)765-0355
Alternate Technologies Research and Development
Office of the Secretary
Louisiana Department of Environmental Quality
P.O. Box 44066
Baton Rouge. LA 70804
(504)342-1254
-------
Maine
Michigan
Office of Pollution Prevention
Department of Environmental Protection
State House Station 17
Augusta, ME 04333
(207)289-2811
Office of Waste Reduction and Recycling
Maine Waste Management Agency
State House Station 154
Augusta, ME 04333
(207) 289-5300
Maryland
Hazardous and Solid Waste Management
Administration
Maryland Department of the Environment
2500 Broening Highway Building 40
Baltimore. MD 21224
(301)631-3315
Maryland Environment Service
2020:lndustrial Drive
Annapolis, MD 21401
(301)454-1941
Technical Extension Service
Engineering Research Center
University of Maryland
College Park, MD 20742
(301) 454-1941
Massachusetts
Executive Office of Environmental Affairs/
. Office of Technical Assistance
100 Cambridge Street, Room 1904
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental
Protection
1 Winter Street. 7th Floor
Boston, MA 02108
(617)292-5870
Massachusetts Department of Environmental
Protection
75 Grove Street
Worchester. MA 01606
(508) 792-7650
Resource Recovery Section
Department of Natural Resources
P.O. Box30241
Lansing, MI 48909
(517) 373-0540
Office of Waste Reduction Services
Michigan Departments of Commerce and Natural
Resources
P.O. Box 30004
Lansing, MI 48909
: (517)335-1178
Minnesota
Minnesota Pollution Control Agency ,
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155-3898
,(612)296-6300
Minnesota Technical Assistance Program
1313 5th Street S.E., Suite 207
Minneapolis, MN 55414
(612)627-1646
(800) 247-0015 (in Minnesota)
Minnesota Office of Waste Management
1350 Energy Lane
St. Paul. MN 55108
(612) 649-5741
Waste Reduction Institute for Training Application
Research, Inc. (WRITAR)
1313 5th Street. SJE.
Minneapolis. MN 55414
(612) 379-5995
Mississippi
Waste Reduction & Minimization Program
Bureau of Pollution Control
Department of Environmental Quality
P.O. Box 10385
Jackson. MS 39289-0385
(601)961-5171
Mississippi Technical Assistance Program
(MTSSTA?) and Mississippi Solid Waste
Reduction Assistance Program (MSWRAP)
P.O. Drawer CN
Mississippi State, MS 39762
(601) 325-8454
-------
Environmental institute for Waste Management
Studies
University of Alabama
Box870203
Tuscaloosa, AL 35487-0203
(205) 348-8403
Hazardous Material Management and Resource
Recovery Program (HAMMAR)
University of Alabama
Tuscaloosa, AL 35487-0203
(205)348-8401
FAX 348-9659
Retired Engineers Waste Reduction Program
P.O. Box 1010
Muscle Shoals, AL 35660
(205) 386-2807
Alaska
Alaska Health Project
Waste Reduction Assistance Program
1818 West Northern Lights, Suite 103
Anchorage, AK 99517
(907) 276-2864
Alaska Department of Environmental
- Conservation
Pollution Prevention Program
P.O. Box O
Juneau,AK 99811-1800
(907)465-2671
Arizona .
Arizona Department of Economic Planning and
Development
1645 West Jefferson St. ^
Phoenix, AZ 85007
(602) 255-5705
Arizona Department of Environmental Quality
. off-of Waste and Water Quality Management
2005 N. Central Ave, Room 304
Phoenix, AZ.85004
(602)257-2380
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock. AR 72201
(501)682-1121 ' .
Arkansas Department of Pollution Control
and Ecology n
Hazardous Waste Division - P.O. Box 891.5
Little Rock, AR 72219-8913
(501)570-2861
California ; .
Bay Area Hazardous Waste Reduction Committee
(BAHWRC) ,.
City of Berkeley Environmental Health
2180 Milvia, Room 309
Berkeley, CA 94708
(415) 644-6510
Cal-EPA ..-.-
Department of Toxic Substances Control
Alternative Technology Division
P.O. Box 806 .
Sacramento, CA 95812-0806
(916)324-1807 ":
California Conference of Directors of
Environmental Health - Subcommittee for
the Development of Hazardous Waste Programs
Ventura County Environmental Health
800 S. Victoria
Ventura, CA 93009
(805) 654-5039
California Environmental Business Resources
Assistance Center
100 South Anaheim Boulevard
Suite 125
Anaheim, CA 92805
(714)563-0135
(800)352-5225
Central Valley Hazardous Waste Minimization
Committee . .
Environmental Management Division
847.5 Jackson Road, Suite 230
Sacramento, CA 95826
(916)386-6160
Local Government Commission
909 12th Street .
#205
Sacramento, CA 95814
(916)448-1198'
Pollution Prevention Program cw;rec
San Diego County Department of Health Services,
P.O. Box 85261
San Diego. CA 92186-5261
(619) 338-2205.-2215 ,
-------
Colorado
Pollution Prevention Waste Reduction Program
Colorado Department of Health
4210 E. llth Ave.
Denver, CO 80220
(303)320-8333
Connecticut
Bureau of Waste Management
Connecticut Department of Environmental
Protection
18-20 Trinity Street
Hartford, CT 06106
(203) 566-8476
Connecticut Technical Assistance Program
900 Asylum Avenue. Suite 360
Hartford, CT 06105
(203)241-0777
Delaware
Pollution Prevention Program in Dept. of Natural
Resources & Environmental Control
89 Kings Highway
P.O. Box 1401
Dover, DE 19903
(302) 739-3822
District of Columbia
U.S. Department of Energy
Conservation and Renewable Energy
Office of Industrial Technologies
Office of Waste Reduction,
Waste Material Management Division
Bruce Cranford CE-222
Washington D.C. 20585
(202) 586-9496
Office of Recycling
D.C, Department of Public Works
2000 14th Street, NW, 8th Floor
Washington. D.C. 20009
(202)939-7116
Florida
Hazardous Waste Reduction Management
Waste Reduction Assistance Program
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee. FL 32399-24CIO
(904) 488-0300
Environmental Quality Corporation
259 Timberiane Road
Tallahassee, FL 32312-1542
(904) 386-7740
Wasie Reduction Assistance Program
Florida Dept. of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
(904) 488-0300
Georgia
Hazardous Waste Technical Assistance
Program
Georgia Institute of Technology
GTRI/ESTL
151 6th Street
O'Keefe Building, Room 143
Atlanta. GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
205 Butler Street S.E. Room 1154
Atlanta, GA 30334
(404) 656-2833
Guam
Solid and Hazardous Waste Management Program
Guam EPA
IT&E Harmon Plaza Complex. Unit D-107
130 Rojas Street
Harmon. GU 96911
(671)646-8863-5 .
Hawaii
Department of Planning and Economic Development
Financial Management and Assistance Branch
P.O. Box 2359
Honolulu. HI 96813
(808)548-4617
Hawaii Department of Health
Solid and Hazardous Waste Branch
Waste Minimization
5 Waterfront Plaza, Suite 250
500 Ala Moana Blvd
Honolulu, HI 96813
(808)586-4226
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POLLUTION PREVENTION RESOURCES
There are a number of organizations that can
assist you in developing and maintaining a pollu-
tion prevention program. This appendix lists
offices of the U.S. EPA, state agencies, and
assistance programs.
VS. ENVIRONMENTAL PROTECTION
AGENCY
Pollution Prevention Information
Clearinghouse
The PPIC is dedicated to reducing industrial
pollutants through technology transfer, education,
and public awareness. It provides technical,
policy, programmatic, legislative, and financial
information upon request.
The PPIC provides businesses and government
agencies with information to assist them in a
range of pollution prevention activities, such as:
. Establishing pollution prevention programs
. Learning about new technical options
arising from U.S. and foreign R&D
Locating and ordering documents
Identifying upcoming events . ,.
. Discovering grant and project funding
opportunities
Identifying pertinent legislation
Saving money by reducing waste
The PPIC disseminates this information
through a number of services. These include:
a telephone hotline .
a repository of publications, reports, and
industry-specific fact sheets
. an electronic infpnnation exchange network
. indexed bibliographies and abstracts of re-
ports, publications, and case studies
a calendar of conferences and seminars
. a directory of waste exchanges
. information packets and workshops.
The electronic network maintained by PPIC is
designated as PIES. It provides access to infor-
mation databases and can be used to place orders
for documents. The subsystems of PIES in-
clude: .
a message center
a publication reference database
a directory of experts
case studies
a calendar of events
program studies
legislation summaries
topical mini-exchanges.
This interactive system can deliver information
to the user through screen display, downloading.
and FAX. It is available to off-site computers
via modem 24 hours a day. For information on
linking to PIES, contact:
PIES Technical Assistance
Science Applications International Corp.
8400 Westpart Drive
McLean, VA 22102
(703)821-4800
The PPIC operates a telephone - hotline for
questions and requests for information. The hot-
line provides users who cannot access PIES elec-
tronically with access to its information and ser-
vices. '
For information on any of PPIC's services.
write to: ?PiCPtY* " 2-ufl )
Washington, D.C 20460
or call:
Myles E. Morse
Office of Environmental Engineering and
Technology Demonstration
(202)45^7161
or.
Pollution Prevention Office
-------
Other U.S. EPA offices that can provide pol-
lution prevention information include:
U.S. EPA Solid Waste Office
Waste Management Division
401 M Street SW
Washington. D.C. 20460
(703)308-8402 "
U.S. EPA Office of Pollution Prevention and
Toxics
401 M Street SW
Washington, D.C. 20460
(202) 260-3810
U.S. EPA Office of Air and Radiation
401 M Street SW
Washington. D.C. 20460
(202)260-7400
U.S. EPA Office of Water ,
. 401 M Street SW
Washington. D.C. 20460
(202) 260-5700
U.S. EPA Office of Research & Development
Center for Environmental Research Information
26 Martin Luther King Drive
Cincinnati. OH 45268
(513) 569-7562
U.S. EPA Risk Reduction Engineering Laboratory
26 Martin Luther King Drive
Cincinnati. OH 45268
(513) 569-7931
U.S. EPA Office of Solid Waste and
Emergency Response
[For questions regarding RCRA and Superfund
(CERCLA), call (800) 424-9346 or
(703)920-9810. To reach the Analytical
Hotline, call (703)-82M789.]
UJS. EPA Regional Offices:
Region 1 (VT,-NH. ME MA. CT. RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3420
Region 2 (NY. NJ. PR, VI)
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA, DC)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
Region 4 (KY, TN, NC, SC, GA, FL. AL, MS)
345 Courtland Street, NE ...
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MM, MI, EL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue, Suite 1200
Dallas, TX 75202
(214)655-6444 '
; Region 7 (NE, KS, MO, IA) ~
726 Minnesota Ave
Kansas City, KS 66101
(913)551-7050
Region 8 (Mf, ND, SD, WY. UT, CO)
999 18th Street
Denver, CO 80202-2405
(303)293-1603
Region 9 (CA, NV, AZ, HI. GU)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle. WA 98101
(206) 553-4973 ...
STATE LEVEL
The following lists agencies at the state or terri-
tory level as well as universities and other orga-
nizations that can provide assistance in the areas
of pollution prevention and treatment:
Alabama
Department of Environmental Management
1751 Congressman W.L. Dickenson Drive
Montgomery, AL 36130
(205)271-7939
-------
15-24.
Wang, J.C., M.T. Hepworth, and K.J. Reid. 1990- Recovering Zn, Pb, Cd, and Fe
from electric furnace dust." JO/W (April /SSOM2-45.
Wu, Li and Nickolas J. Themelis. 1392. "The flash reduction of electric arc
furnace dusts." JOM (January 1992): 35-39.
-------
-------
Bethlehem Steel Corporation. 1985. Electric arc furnace-Dust disposal, recycle &
recovery. Center for Metals Production Report No. 85-2. Mellon Institute, Carnegie-
Mellon University. Pittsburg, PA. 15213.
Brandes, Heiner R. and Helmuth Ester. 1992. "Gas cleaning and secondary
emissions control with energy recovery: Part l«Basic oxygen converters; Part II--
Electric arc furnaces". Iron and Steel Engineer 69(1)AQ-55.
Clearwater, Scott W. and Joanne M. Scanlon. 1991. "Legal incentives for ;
minimizing waste." Environmental Progress 10(3): 169-174. .
Cyrus W. Rice Corporation. 1981. Development document for effluent limitations
guidelines and standards for the iron and steel manufacturing point source
category. Proposed. December 1980. EPA 440/1 80/024b. Six volumes.
Dighe, Shyam V., C. Keith Paulson, and Edward J. Lahqda. 1992. "Westinghouse
plasma-fired processes for treatment of industrial wastes." Iron and Steel Engineer
Galloway, S.M., M.J. Green, S.R. Balajee, and F.J. Nahlik. 1992. "Improvement in
furnace performance at Inland through models utilization and standardization of
operating practices." Iron & Steelmaker (I&SM) 19(1):29-35.
Geddis, R.R and R.V. Chalfant. 1991. "Clean Air Act Amendments of 1990:
impact on the steel industry. A series of articles under Column "Keeping Current
II." Iron and Steel Engineer 68(2-7).
" --'-.I ,
Geddis, R.R. and R.V. Chalfant. 1992. " Electric arc furnace shop air permit
issues." Iron and Steel Engineer 69(1), Jan 1992:60-63.
McAloon,T-P. 1991. "Direct Steelmaking set for Phase II." lron~and Steelmaker
(I&SM) 18(9): 40.
Osipenko, V.D. 1 987. Reducing heat losses with waste gases of electric arc
steelrriaking furnaces. Steel in the USSR. 17(2): 100-1 01.
Puhringer, O., H. Wiesinger, W.L. Kepplinger, B.H.P. Havenga, R. Hauk, and^F. -
Wallner. 1991. "Operational experience and potential of the Corex process . MPT
Metallurgical Plant and Technology 14(5): 30-41.
Steiner,. Bruce A.- 1 992. "Impact of 1 990 Clean Air Act Amendments on the iron
and steel industry." Iron and Steel Engineer 69(1 J:41-43.
Tarsitano t. 1 991 . "The reduction of lead in steel flue dust using a batch leaching
process." An Industrial Waste Diversion Program Report for Waste Management
Branch, Ontario Ministry of the Environment. ISBN 0-7729-8429-8.
-------
APPENDIX C
Iron and Steel Industry References compiled by:
' Waste Reduction Institute for Training & Applications Research (WRITAR)
Industry Background and Pollution Prevention Options
Center for Hazardous Materials Research (CHMR). 1990. Pollution Prevention:
Strategies for the Steel Industry. CHMR Fact Sheet. University of Pittsbury, PA.
Drabkin, Marvin and Edwin Rissmann. 1989. "Waste Minimization opportunities at
an electric arc furnaces steel plant producing specialty steels." Environmental
Progress 8(2): 88-96.
Nyrienda, R.L. "The processing of steelmaking.flue-dust: a review". Minerals
Engineering 4(7-11): 1003-1025.
Peters, Anthony T. 1989."/ro/7 and steel. Minerals Yearbook. U.S. Dept. of Bureau
of Mines. ,
Prabhu, Damodar U. and Paul F. Cillione. 1992. 1990 "Clean Air Act
Amendments: technical/economic impact on U.S. coke and steel making
operations". Iron and Steel Engineer 69(1): 33-40.
Williams, Roy E. 1975. Waste production and disposal in mining, milling, and
metallurgical industries. Miller Freeman Publications, Inc. Chapter 7.
, , ii1' ,,..' i ,
Wright, J.K., I.F. Taylor, and O.K. Philip. 1991. "A review of progress of the
development of new irdnmaking technologies". Minerals Engineering 4(7-11.): 983-
1001.
Agarwal, J.C. 1991. "Strategic considerations in direct steelmaking". Iron &
Steelmaker (l&'SM) 18(3):69-72. .
Anonymous. 1991. "Geneva Steel installs Q-BOPs". Iron and Steel Engineer
Aukrust, E. 1991. AISI direct steelmaking program annual technical report for year
ending 11/30/90. U.S. DOE. E 1.99:DOEID128471,
Baure, Karl-Heinz, Dillinger Huette, Heinz-Juergen Lehmkuehler, and Hugo
Schmauch. 1990. "Recycling of iron and steelworks wastes using the inmetco
direct reduction process". MPT Metallurgical Plant and Technology 13(4):74-87.
V
-------
APPENDIX B
POLICY STATEMENT EXAMPLE 1 - "(Your Company.Name) is committed to excellence and
leadership in protecting the environment. In keeping with this policy, our objective is to _
reduce waste and emissions. We strive to minimize adverse .mpact on the a,r, water, and
land through pollution, prevention and energy conservation. By successfully preventmg
pollution at its source, we can achieve cost savings, increase operational efficiencies, ..
improve the quality of our products and services, maintain a safe and healthy workplace for
our employees, and improve the environment. (Your Company Name) s environmental
guidelines include the following:
- Environmental protection is everyone's responsibility-It is valued and displays
commitment to (Your Company Name).
- We will commit to including pollution prevention and energy conservation in the
design of all new products and services.
- Preventing pollution by reducing and eliminating the generation of waste and
emissions at the scarce is a prime consideration in research, process-des.gn, and
plan operations. (Your Company Name) is committed to identifying and
implementing pollution prevention opportunities through encouraging and mvolv.ng
all employees.
- Technologies and methods which substitute nonhazardous materials and utilize
other source reduction approaches will be given top priority in addressing all
environmental issues.
- (Your Company Name) seeks to demonstrate its responsible corporate pitizenship by
adhering to all environmental regulations. We promote-cooperation and
coordination between industry, government, and the public toward the shared goal
of preventing pollution at its source."
POLICY STATEMENT EXAMPLE 2 - "At (Your Company Name), protecting the
environment is a high priority. We are pledged to eliminate or rec'«"* ««£££
substances and to minimize our use of energy and generation of all wastes, whenever
possible. Prevention of pollution at the source is the preferred altetiv.e- e". '
waste cannot be avoided, we are committed to recycling, treatment, and d.sposal ,n
ways that minimize undesirable effects on air, water, and land.
I (Adapted from: Waste Reduction Institute tor Training and Applications Research, Inc. _
' [WRITAfi]Su/veV and Summaries. 1991, and Minnesota Office of Waste- Management, Feb.
11991. Minnesota Guide to Pollution Prevention Planning)
-------
-------
₯\rm
Site
Date
WORKSHEET
:'
' i
Pollution Prevention '
Assessment Wofktb*«t» Prepared By
Checked By ,
Proj. No. Sheet of Pane !,,,_ 'of ,.;_,
OPTION DESCRIPTION j
.
" '
" ,
Waste Stream(s) Affected:
Input Material(s) Affected:
Product(s) Affected:
Indicate Type: D Source Reduction
Equipment-Related Change
. Personnel/Procedure-Related Change
Materials-Related Change
D Recycling/Reuse
. Onsite
Off site
Material reused for original purpose
[ Material used for a lower-quality purpose
: Material sold
Originally proposed by:
Reviewed by:
Approved for study?.
Reason for Acceptance or Rejection
.ye*
-------
PROFITABILITY
WORKSHEET
Capital Costs
Purchased Equipment
Materials
Installation
Utility Connections'
Engineering _
. Start-up and Training
Other Capital Costs
Total Capital Costs
Incremental Annual Operating Costs
Change in Disposal Costs
Change in Raw Material Costs
Change in Other Costs
Annual Net Operating Cost Savings
Total Capital Costs
Payback Period (in years) - Annua) Nft Operating Cost Savings
-------
Pollution Pr«v«ntlon
Assessment Worksheets
Prepared
Checked By
WORKSHEET
6
WASTE STREAM SUMMARY
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units
Components) of Concern
Cost of Disposal
Unit Cost ($ per;
Overall (per year)
Method of Management1
Relative
Wt. (W)
Priority Rating Criteria3
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
.Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Priority Rank
2. Rate each stream in each category on a scale from 0 (none) to 10
-------
Firm,
Site.
Date
PoBution Prevention
Assessment Worksheets
Proj. No.
Prepared By '
Checked By -...
Sheet. of Page of
WORKSHEET
7
OPTION GENERATION
Meeting format (e.g.. brainstorming. nominal group technique)
Meeting Coordinator
Meeting Participants
List Suggestion Options
Rationale/Remarks on Option
.(
.-I
*
-------
Date
Assessment Worksheets
Proj. No. ___
Prepared By . _i
Checked By _
Sheet of Page of
WORKSHEET
4
INPUT MATERIALS SUMMARY
Attribute
Name/ID
Source/Supplier
Component/Attribute .of Concern
Annual Consumption Rate
^M^BMMH -~
Overall
Component(s) of Concern
,
Purchase Price. $ pef\
____
Overall Annual Cost
Delivery Mode1
Shipping Container Size &Type*
Storage Mode3
Transfer Mode*
Empty Container Disposal Management8
Shelf Life
M^MMii^««
Supplier Would
accept expired material? (Y/N)
accept shinning containeri7 (Y/N)
__.^r^"""'
_ revise expiration date? (Y/N)
Substitute(s), if any
_
Alternate SupplieMs)
Description
Stream No.
Stream No.
Stream No.
Notes: 1.
, tank car, 100 bbl tank truck, truck, etc.
-------
Pollution Prevention
Assessment Worksheets
Prepared By
Checked By
Sheet of Pageof
PRODUCTS SUMMARY
WORKSHEET
5
Component/Attribute of Concern
Annual Production Rate
MHM^^BWWH
Overall
Component(s) of Concern
Annual Revenues, »
Shipping Mode
^"^^"^^
Shipping Container Size & Type
Onsite Storage Mode
mmH^mmmmmm^M^HmMMMMBMM*
Containers Returnable (Y/Nj
MMMHMMMHWM
Shelf Life
MWM^MXMMM
Rework Possible (Y/N)
Customer Would
_^-i
relax specification (Y/W
'
accept larger containers (Y/N)
-------
Firm
Site
Date
WORKSHEET
Street Address;
Cit
State/Zip Code:
Telephone; { . )
Major Products;
SIC Codes;
EPA Generator Number
Pollution Pr«v«ntJon
Worksheets
Proj. No.
Prepared By
Checked By.
Sheet . of_ Page of
SITE DESCRIPTION
Major Unit;
Product or Service;
Operations;
Facilities/Equipment Abe;
-------
Firm
Pollution Prevention
Allotment Worksheets
Prepared By
Checked By
Sheet of
PROCESS INFORMATION
WORKSHEET
Process Unit/Operation:
Operation Type:
Q Discrete
0 Other
D Continuous
Q Batch or Semi-Batch
Last I Used in this I Document
Revision! Report (Y/N)1 Number I Location
Current?
(Y/N1
Complete?
/N)
Process Flow Diagram
Material/Enerov Balance,
Desion
Row/Amount Measurements
Analyses/Assi
Stream
Equipment Specifications
and Instrument Diagrams
Work Flow Diagram
ardous Waste Manifests
Emission Inventories
Annual/Biennial Re
Environmental Audit Re
Permit/Permit^
sition Sheets
Product Com
MaterialSafe
:ion Schedules
-------
APPENDIX A
POLLUTION PREVENTION WORKSHEETS
Worksheet 1
Worksheet 2
Worksheet 3
Worksheet 4
Worksheet 5
Worksheet 6
Worksheet 7
Worksheet 8
Worksheets
Assessment Overview
Site Description
Process Information
Input Materials Summary
Products Summary
Waste Stream Summary
Option Generation
Option Description
Profitability
-------
Firm
iitB
Date
WORKSHEET
1
l"»-
I
Esubiihtl
.
Pollution Prevention
Assessment Workshtt«ts
Proj. No.
ASSESSMENT OVERVIEW
* Polutton Pnnwntloo Program
ExMUtiv* L«v«l Dtdiion
PoKey SUMIMM
. Con**n*u* iuiMna
Checked By _____
Sheet of P*0e of
"'
. |
, Org»nii« Pt»fle«m
NMTW Tuk Fere*
Sutt Go«l«
Oo PrtimiiuiV A«««MnMm
Collect D»t«
R«vi«w SUM
STEP1
Dtfin* IndivMuil Rate*
OtfiiM ObjtetivM
Idtmttv Pound- OfcruoU*
Sch«dut«
1
-«
Do D«t«B*4 AMMWIMM
N*nw AtM<«TMnt T«*m(«l
R«w»w 0*u end Sit«<«)
Otgwiu *nd OacuiTwiTt InfannMien
0«flM Patuthm PramntiM Opdam
Propew Option*
Serun Option*
Da F.Mfcfflty AnalyH*
T*chnic«l
Env<
-------
Numerous alternatives for pollution prevention and waste
minimization were suggested and considered by the ,
assessment team. At the time of this study, recycling of
the K061 .material as briquetted materials, or the sale of
sludge to zinc recyclers were not economically or
operationally feasible. The team next focused upon the
detoxification of the waste material. The proposed
stabilization procedure was expected to produce a non-
hazardous residue that could be land disposed at the
plant. This option resulted in the savings in disposal
costs, and eliminated the need to use hazardous waste
landfills. At the time of the study, the annual pre-tax
operating savings was estimated at $577,000 per year.
it must be noted, that in 1988, by re-evaluating the
pollution prevention plan, it was determined that AOD
baghouse dust (approximately TO per cent of the K061
waste) could be briquetted and subsequently blended
into the EAF feed. Also, by that time, the percentage of
zinc in the sludge was considered high enough to permit
recovery by a recycling facility. Currently, the facility
now recycles all of the K061 waste generated at the
plant.
In the stainless steel annealing and pickling operation line
for the processing of various stainless steels, the
generation of two corrosive waste streams (RCRA listed
wastes K062) occurred. Volumes of over 5,000 gallons
per week of spent hydrofluoric acid/nitric acid pickling
(HF/HNO3) were disposed of to the wastewater
treatment system. At the time of the assessment, the
facility was already recycling a portion of the spent
HF/HNO3 to the pickling tank. The team decided that
additional opportunities lay in recovering calcium fluoride
from the spent pickle acids and rinse water streams.
The option described would not only reduce the
generation of sludge from K062 treatment, but also save
money by reducing the amount of fluorspar that was
previously purchased.
At the time of the assessment, the cost of disposing of
the non-hazardous sludge was approximately $228,000
per year. The total investment cost for the proposed
calcium fluoride recovery system was approximately
$300,000. The operating cost for the new system was
6-7
-------
estimated at $46,000 per year. The savings due to
replacing the purchase of fluorspar totaled $100,000 per
year and the savings realized due to reduced off-site.
landfill disposal equalled $68,000 per year. Table 6.2
summarizes the costs, savings and payback period for
this project. Additional references documenting other
pollution prevention and waste minimization efforts are
presented in the Appendix.
Table 6.2 Cost Savings for Calcium Fluoride Recovery Scheme
(Adapted from Environmental Progress, Vol. 8, No. 2. May 1989, pp. 88-96)
CAPITAL INVESTMENTS
Total Capital Investment
OPERATIONAL COSTS
Total Annual Operating Costs
OPERATIONAL SAVINGS
' Savings due to Reduced Fluorspar Purchases
Savings due to Reduced Disposal Costs
ANNUAL OPERATING SAVINGS
NET YEARLY SAVINGS
Net Savings
Simple Payback
Period Required.
Annual operating savings
$ 168,000 - $46,000
$ 122,000 per year
$300,000
$ 46,000
$100,000
$ 68.000
$168,000
- Annual operating costs
$300,000/$ 122,000 per year
2.5 years
6-8
-------
The pollution prevention team was organized as a first
step. Individuals with backgrounds in chemical
engineering, physical chemistry, and metallurgy
comprised the main assessment team. The team then
began the process of developing the pollution prevention
plan by evaluating the total amount of steel produced
and total tonnage of air emissions generated in producing
EAF steels. Figure 6.1 is a schematic of the K061
wastes generation and treatment processes at the plant.
MAKEUP
WATER
1
RAW SOUP
acres!
LUXES,
fgRHOALLOYS _
ELECnCCARC
FURNACES
EAF VENT GAS
AMD PARTICULATE3
HOT
RAW
STEELS
ARGON/OXYGEN
FURNACC
VENT GAS
AND PARTICULATES
EAP SLUDGE (KOMI
TO TREATMENT AND
AL, 1OOOO TFf
70% 80UOS, 30% WATER
BAOHOUSEOUSr
COUBCTOH
EAF COST 0«8D
TO DISPOSAL
1000 TPV
FIGURE 6.1 SCHEMATIC OF KQ61 WASTE GENERATION AND TREATMENT PROCESSES
(Adapted from Environmental Progress, Vol. 8, No. 2. May 1989, pp.88-96)
In order to evaluate alternatives a detailed assessment of
the processes that generate and treat the K061 waste
was undertaken. The schematic of the EAF treatment
process traced the waste from the point of generation to
the discharge of the K061 treated waste and is
presented in Figure 6.2.
6-5
-------
TO ATM
tto
MMMX
vm
Man
i
mow*
mnouuw*
vao*
VI
OOMUUMT
<*»"" SSU
PUMTK BMTTO
TMOifW
alternatives.
'
^»>^.»..--
!
Amount present
pgramet.ec
Iron
Manganese
Silica (SiO2)
Aluminum
Calcium '
Chfomium(total)
Copper.
Nickel
Lead
Zinc
Magnesium
Cadmium
Barium
-------
Replacing single-pass wastewater systems with
closed-loop systems. This results in minimization
of chemical use in wastewater treatment and
reduced water use. ;
RECYCLING
t * - '
Numerous opportunities exist for recycling waste
materials generated in the iron and steel industry. The
industry already recycles scrap steel extensively as a raw
material. By-products produced in coke making
operations such as coke oven gas, coal tar, crude or
refined light oils, ammonium sulfate, anhydrous
ammonia, and naphthalenes, are also used as raw
materials for other industrial processes. Several other
materials should be considered as well:
Convert tar-decanter sludge and other tar-based
coke plant wastes into a fuel that is suitable for
open hearth and blast furnace.
.* Recycle or reuse oils and greases. Dewater and
recycle mill scale, and recharge slag into the
melting furnace. -
Recover zinc from electric arc furnace dust.
. Recover acids by removing dissolved iron salts
from spent acids. Employ thermal decomposition
for recovery of hydrochloric acid from spent
pickle liquor through crystallization.
' '
.- Employ the use of a spray roaster, a fluid bed, or
a sliding bed to separate hydrochloric acid from
iron oxide in spent pickle liquor.
Use a bipolar membrane/electrodialytic process to
separate acid from metal by-products in spent
N03-HF pickle liquor. .
Recover sulfuric acid using low temperature
separation of acid and metal crystals.
6-3
-------
Choose a waste management contractor, based
on their ability to recycle instead of dispose of
waste sludges, etc.
TREATMENT ALTERNATIVES
Sometimes process " modifications and materials
suSStSlons are just not possible while still mamta.nmg
a required product quality. Alternative methods of
treating wastes generated from the steel making process
can however, reduce the toxicity or volume ^wastes
generated. Examples of some alternat.ve methods are.
. In the ductile iron industry, use of thermal
destruction of calcium carbide desulf urization slag
by rotary kiln; or a chemical reaction between
slag and strong oxidizing agents such as
potassium permanganate and hydrogen peroxide,
, can reduce toxicity.
. Reduction of the leaching potential of toxic
metals through precipitation, adsorption,
chemical reduction or pH control.
SPECIALTY STEEL PLANT CASE STUDY
The following case study provides some ideas to
examine pollution prevention possibilities within your
Sam As was noted earlier, pollution prevention
encompasses not only hazardous wastes, but a so non-
hazardous solid waste streams, toxic a,r pollutants
Wastewater emissions and other by-products produced
during the steel-making process.
A waste reduction assessment conducted on a specialty
steel Plant by EPA, focused on pollution prevention
atenaives for two hazardous wastes streams
Generated First, the emission control dust and sludge
from Metric arc furnace (EAR stee.-making was
considered. Second, the waste pickle liquors and rinse
waters from the stainless and alloy steel str.p products
cleaning was analyzed.
6-4
-------
CHAPTER 6
CASE STUDY EXAMPLES
Pollution prevention has been underway for a number of
years. Many companies have already discovered its
numerous benefits. For example, Monsanto has pledged
(among other things) to reduce all toxic hazardous
releases and emissions, working toward an ultimate goal
of "zero effect". The 3M Company's "Pollution
Prevention Pays" Program is probably the most
publicized example of actual in-plant benefits of a
pollution prevention program. There are also pollution
prevention projects on-going within the steel industry
and the AIS1 is supporting a number of research projects
that ultimately will have an impact on pollution
prevention.
* ;
The steel-making process requires large amounts of raw
materials in its production process, probably more per
ton of finished product than for any other industry. A
myriad of pollutants, both hazardous and non-hazardous,
are generated by the different steel-making processes
currently in use. Existing environmental regulations
-provide incentives to reduce the quantity of pollution
generated, especially electric arc furnace dust and pickle
liquors, which are produced in large quantities.
The Center for Hazardous Materials Research, at the
University of Pittsburgh, has prepared a Fact Sheet on
Pollution Prevention Strategies for the Steel Industry.
The following section summarizes that document, and
identifies key areas where pollution prevention planning
can be applied to the steel industry.
IMPROVED OPERATING PROCEDURES
Good operating-procedures can produce reductions in
pollution output. Examples for the steel industry include:
Improve process control.
AISI IS SUPPORTING
RESEARCH THAT WILL
IMPACT POLLUTION
PREVENTION
POLLUTION
PREVENTION
EXAMPLES FOR THE
STEEL INDUSTRY
6-1
-------
Properly manage oil used for machinery
maintenance.
Choose a waste management contractor on the
basis of their compliance record.
MATERIALS SUBSTITUTION
Within the steel-making process the ability to make
substitutions of materials while still maintaining a high
quality product are limited. Several areas should be
considered, however, and include:
The use of steel scrap with low lead and
cadmium content as a raw material when
available.
The elimination of the generation of reactive
desulfurization slag generated in foundry work by
using a less hazardous material in place of
calcium carbide.
PROCESS MODIFICATION
Several new ideas have emerged in designing and
modifying process equipment used in the steel making
process. Designs not only reduce pollution output but
can also reduce maintenance costs and energy
consumption. Examples include:
A technology which uses an induction-heated
holding furnace following the electric arc furnace
to feed the metal in a pseudo-plastic state, to
multiple continuous casting machines.
Advantages include the elimination of structural
defects that may result from using the traditional
approach and better conditions for. near-net
shaping.
Switching to induction melting furnaces for grey
iron melting can reduce or eliminate the need for
air pollution control equipment.
POLLUTION
PREVENTION
EXAMPLES FOR
THE IRON AND
STEEL INDUSTRY
IMPROVED
OPERATING
PROCEDURES
MATERIALS
SUBSTITUTION
PROCESS
MODIFICATIONS
RECYCLING
TREATMENT
ALTERNATIVES
6-2
-------
EXPANDED TIME HORIZON
The benefits of many of the pollution prevention projects
may not be realized economically in the three- to five-
year time frame typically used for other projects. It is
important to think in terms of the longer, perhaps even
a 25-year time frame when hazardous impoundments are
closed and remediation projects begin. Pollution
prevention may well eliminate the' need for the
remediation project.
LONG-TERM FINANCIAL INDICATORS
Three commonly used financial indicators can be
selected to account for all the cash flow during the
project and the time value of money; the Net Present
Value (NPV) of an investment, the Internal Rate of
Return (IRR) and the Profitability Index (PI) can be
utilized. Discussions on their use are found in any
economic analysis text.
DIRECT ALLOCATION OF COSTS
Most mills do not allocate the cost of pollution to any
single department or process. In fact, it is often not until
a pollution prevention plan is begun that emissions
generated are associated with a specific department or
process. Three methods from the EPA Facilities Pollution
Prevention Guide are discussed: the simple pool concept,
multiple pool concept, and the service center concept.
The Single Pool Concept distributes the benefits and
costs of pollution prevention across all divisions,
products, and* services. . A general overhead or
administrative cost is included in all transactions to
account for these costs. Because the costs are riot
itemized, pollution prevention benefits are often not fully
recognized for their true benefits.
The Multiple Pool Concept links the cost of pollution
more closely with each responsible operation (melt shop,
rolling, pickling, annealing, etc.). This concept makes
DIRECT COST
ALLOCATION
Simple Pool Concept
Multiple Pool Concept
Service Center Concept
5-5
-------
each division accountable, but does not reach a
appropriate level that fully associates the costs and
benefits of pollution prevention activities.
The final concept presented is, the Service Center
Concept. This is a .much more detailed accounting
method directly linking the benefits and costs of
pollution prevention activities to those processes from
which the pollution emanates. Significant effort is
required under this method to accurately track each
product, contract, or job, and to associate the relevant
pollution prevention charges.
The accounting methods listed above are just examples
of how to accurately associate pollution costs and
pollution prevention benefits with individual processes.
This is a dynamic area of concern that has drawn the
attention of accounting firms, educational institutions
andtthe business community as a whole. It is expected
that significant advances will be made in this area in the
next two to five years and that accounting techniques
that reflects pollution prevention opportunities will
become commonplace.
5-6
-------
cost inventory, extended time horizon, use of long-term
financial indicators and direct allocation .of costs to
processes and products. The first three apply,to the
analysis of pre-implementation feasibility and the fourth
to post-implementation cost accounting. The following
summary, from the EPA Facilities Pollution Prevention
Guide, addresses the elements of TCA in detail; The
Facilities Pollution Prevention Guide cites several
references that provide additional detail on TCA. The
following sections of this chapter summarize the
important characteristics of TCA. In addition, TCA
includes not only direct costs typically included in most
project cost analyses, but also indirect costs, costs
related to liability and other less tangible benefits.
Indirect and liability costs can represent a large cost, if
ever assessed against a company. Therefore, proposed
pollution prevention projects can lead to a significant net
savings. However, the likelihood and magnitude of these
concepts are difficult to extrapolate from little, or no,
data.
EXPANDED COST INVENTORY
Direct costs, for most capital projects, are the only costs
being estimated when one evaluates a project.
Direct Costs include:
Capital Expenditures
- Buildings ,
- Equipment
- Utility Connections
- Equipment Installation
- Project Engineering
. Operation and Maintenance
Expenses/Revenues
'« Raw Materials
- Labor
- Waste Disposal
- Utilities
- Value of Recovered Materials
EXPANDED
INVENTORY
COST
Direct costs
Indirect Costs
Liability costs
Less tangible benefits
5-3
-------
In the case of pollution prevention projects, indirect
costs often are likely to represent significant net savings.
These costs must be estimated and allocated to their
source.
Indirect Costs include:
Hi,'1!! . ' ''',' ' " ...
Regulatory Compliance Costs'
- Permitting
- Reporting
- Monitoring
- Manifesting
Insurance
On-Site Waste Management
. on-Site Pollution Control Equipment Operation
Reduced liability which is often associated with pollution
prevention projects may provide significant short and
long term savings.
Liability Costs include:.
Penalties
Fines
Personal Injury
Property Damage . _
Natural Resources Damage Clean-up Costs
- Super Fund
- Corrective Action
As you would expect, pollution prevention projects often
deliver substantial benefits from an-improved product or
an enhanced company image.
Some of the less tangible benefits of pollution prevention
include:
Increased Sales
- Improved Product Quality
- Enhanced Company or Product Image
Reduced Health Maintenance Costs
Increased Productivity due to Improved
Employee Relations
Improved Relationships with Regulators
5-4
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CHAPTER 5
ECONOMIC ANALYSIS
Effective analysis of pollution prevention projects should
encompass a review of economic feasibility as well as a
determination of technical feasibility. Industrial capital
funds always have numerous competing interests. Plant
managers typically must choose between two or more
alternatives for limited funding. Pollution prevention
projects must fight for tight capital available for
investment along with the other facility projects, such as
process improvements for quality control, ongoing
maintenance, plant upgrade or expansion.
Unfortunately, conventional-accounting measures, such
, as cost-benefit analyses, are not always easily applied to
pollution prevention projects. For example, whereas it is
easy to calculate the cost of making process
modifications or installing new equipment, it is difficult
to associate a financial benefit to reduced liability or
improved public perception.
This is hot to say that one cannot determine the benefits
of pollution prevention projects. Several factors can be
realized and other benefits can be estimated. Some
direct costs that can be identified include:
Reduction or elimination in waste transportation
and disposal fees.
Reduction or elimination of environmental
compliance costs.
Elimination of-"the cost of installing required
pollution control equipment under the 1990
Clean Air Act Amendments.
- This may be a particularly important
factor as the Source Reduction Review
Project impacts the iron and steel
industry.
Pollution prevention
projects often do not
conform to traditional
economic analysis
POTENTIAL DIRECT
COSTS
Eliminate disposal
fees
E I i m i n a t e
compliance costs
Avoid capital
expenditures
Conserve raw
materials
5-1
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Conservation of raw materials.
Reduction in energy use.
Some benefits less easily' quantified but of major
significance include;
Enhancement of the Corporate Image.
Reduction in liability for future clean-up of
contaminated sites.
Elimination of the cost of installing future
required pollution control equipment.
The aim of business is profit. Basically, profits equal
JevenuTs minus expenses, in order to .ncrease the
profit, it is necessary to either increase revenues or
decrease expenses. Pollution prevention act.v.t.es can
hefp^ etther case. Pollution prevention activities can, in
some cases improve product output or quality, thereby
increasing the revenue side of the equation. More
"equenti?, however, pollution prevention activit.es work
o decrease expenses. The following list of costs, uW
be considered when appropr.at.ng costs,to
processes:
Insurance expenses
Depreciation expenses
Interest payments
Labor costs ' ' ,
Training expenses ........
Regulatory transaction costs (permit application
and renewals, etc.) .
These costs are relatively easy to estimate and calculate
However, these costs are not the only expenses that
^consideration. New accounting measures; arebeing
adooted to include mechanisms that consider less
Se benefits. In response to the need for new
revised) mechanisms for cost accounting, the EPA has
funded several studies using an econom.c analysis
Ivstem called the Total Cost Assessment (TCA)
methodology to undertake pollution prevents economic
aiyses Ihis method includes four elements: expanded
INDIRECT BENEFITS
Image
Reduced Future
Liability
Future Equipment
Costs
5-2
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TABLE 4.3 METHODS FOR MAINTAINING THE POLLUTION PREVENTION PROGRAM
(Adapted from EPA Facilities Pollution Prevention Guide)
Integrate pollution prevention into corporate planning:
- Assign pollution prevention accountability to the operating units where waste is
generated .
Track and report program status
- Conduct an annual program evaluation at the corporate level
Provide ongoing staff education programs: '
- Make pollution prevention awareness program a part of new employee orientation
Provide advanced training
Retrain supervisors and employees '
Maintain internal communication:
- Encourage two-way communication between employees and management
- Solicit employees' pollution prevention suggestions
Follow-up on suggestions t
Reward personnel for their success tn pollution prevention:
Cite accomplishments in performance reviews
- Recognize individual and group contributions .
- Grant material rewards .
- Consider pollution prevention a job responsibility subject to review
Provide public outreach and education about pollution prevention efforts:
- Submit pres$ releases on innovations to local media and to industry journals read by
prospective clients . .
- Arrange for employees to speak publicly about pollution prevention measures in
schools and civic organizations
4-5
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the product. It can be difficult to track the shift of a
pollutant from one medium to another or to determine
what new pollutants may be created by the new
procedure, but such qualifications should be documented
to the extent feasible.
MEASURING TOX1CITY
The toxicity of the waste should be evaluated. Reducing
the sheer volume of a given waste product while
increasing its per-unit toxicity is a treatment option, but
it is not pollution prevention!
It is important to establish a baseline. When a pollution
prevention option involves incremental changes to a well-
defined process, it is possible to derive a baseline from
historical performance. New facilities present a
challenge since there is no "baseline". Establishing a
baseline is further complicated by changes to existing
processes or equipment, and by new facilities that are
radically different from older plants for reasons other
than pollution prevention alone. In this case, the
measure of success may be the amount of pollution that
was never generated. Thus, a projected amount of
pollution may serve as a baseline.
METHODS OF DATA ANALYSIS
Measuring pollution prevention progress is complex.
Using a single measure to summarize pollution prevention
will be applicable only in the simplest cases, if at all.
The characteristics of several approaches and their
advantages and disadvantages are outlined in Table 4.2.
Select the method or combination of methods that best
fits your data availability, facility characteristics, and
corporate goals.
4-3
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TABLE 4.2 METHODS OF DATA ANALYSIS
Semi Quantitative Process Description
- easy to prepare with less utility
Quantity of Waste Shipped of Site or Treated on Site
- shipping manifests and compliance reports provide dates
Quantity of Materials Received
- An imprecise measure because it does not account for process losses or conversions
Quantity of Waste Generated
- Look at both inputs and outputs to provide a more complete understanding
Process Analyses
- Often over looks facility level waste
Pollution Prevention Analysis
- More useful for production changes than for behavioral changes
Change in Amount of Toxic Constituents
- Obtained from SARA Title 313 Form R reporting
Changes in f oxicity
- Obtained by discharge -analysis
MAINTAIN THE POLLUTION PREVENTION PROGRAM
The task of maintaining a viable pollution prevention
program will be made easier with the establishment of a
pollution prevention awareness program. Such a
program is intended to promote employee involvement in
the prevention effort. The objectives of the pollution
prevention awareness program are to:
Raise awareness of environment-related activities
at the mill.
Inform employees of specific environmental
. issues.
Train employees .in their pollution prevention
responsibilities.
Recognise employees for pollution prevention
efforts.
Encourage employees to participate in pollution
prevention.
Publicize success stories.
A summary of methods for accomplishing this appears in
Table 4.3. Further detail may be found in.the EPA
Facilities Pollution Prevention Guide.
Publicize Success
GET THE WORD OUT!
4-4
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CHAPTER 4
MEASURE PROGRESS & MAINTAIN
POLLUTION PREVENTION PROGRAMS
STEP 6: GET THE WORD OUT
In order to assess the impact of a pollution prevention
program, measurement of progress against goals is
important. Review of the program's success and failures
can assist managers and foremen in determining which
pollution prevention goals at the facility and production
unit levels are being met and what the economic results
have been. The comparison identifies pollution
prevention techniques that work well and those that do
not. This information helps to guide future pollution
prevention assessment and implementation cycles.
/
Quantitative evaluations permit comparisons of one
project with another, and with similar projects from other
companies. You will need this knowledge to plan
enhancements of your current pollution prevention
program, to select technologies to transfer from other
operations, and to help identify new pollution prevention
options.
ACQUIRING DATA
To measure success, select what is to be measured
(e.g., waste volume or toxicity), measure that quantity,
and normalize the data as necessary to correct for
factors not related to the pollution prevention method
being reviewed. Table 4.1 illustrates a number of
potential data aources for your consideration.
STEPS
Quantitative evaluations
permit comparisons of a
variety of projects
4-1
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TABLE 4.1 POTENTIAL DATA SOURCES
(Adapted from EPA Facilities Pollution Prevention Guide)
Raw Material/Production Information:
Product composition and batch sheets
Material application diagrams
Material safety data sheets
Product and raw material inventory records
Operator data logs
Operating procedures
Production schedules
Process Information:
Process flow diagrams
Design and actual material and heat balances
for:
-production processes
-pollution control processes
Operating manuals and process descriptions
Equipment lists
Equipment specifications and data sheets
Piping and instrument diagrams .
Plot and elevation plens
Equipment layouts and logistips
Regulatory Information:
Waste shipment manifests
Emission inventories
Biennial hazardous waste reports
Waste, wastawater, and air emission*
analyses, including intermediate streams
Environmental audit reports
Permits and/or permit applications
Form R for SARA Title III Section 313
Accounting Informations
Waste handling, treatment, and disposal
costs
Water and sewer costs, including surcharges
Costs for nonhazardous waste disposal, such
as trash and scrap metal
Product, energy, and raw material cost*
Operating and maintenance costs
Department cost accounting report*
Other Information:
Environmental policy statement*
Standard procedures
Organization charts
After deciding what data should be tracked, you will
need to determine how to collect it and what
normalization may be required for each category of data.
The iron and steel industry already collects a
considerable volume of data for regulated waste
streams. However, there can be gaps and discrepancies
fn ?hTs data. For example, RCRA wastes are
characterized by waste type and total amount, but not
by individual components. Therefore, these data may
not be specific enough for your evaluation. In add.t on
accurate measuring devices may not be available for aU
waste streams (e.g., vaporous or fugitive emissions). In
such cases, your regulatory compliance reports will have
been based on estimates; comparing estimates from, one
period to another will not yield reliable percent-of-change
figures.
The pollution prevention option may also eliminate part
of the target material but may shift some of it to ano her
plant stream, to another environmental medium, or into
The iron and steel
industry collects a
significant amount of
data.
4-2
r?
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Capital Costs
- Purchased Process
Equipment
- Materials Cost
- Utilities Connection
- Site Preparation
- Installation
- Engineering
- Startup.
Operating Costs
- Utilities
- Permitting
- Handling
- Treatment
- Returns
- Disposal
Income
- Product Sales
- Recycling Income
Further detail on economic analyses of pollution
prevention projects are included in Chapter 4.
Option Ranking
Once the options have been technically and economically
analyzed, it is important to. prioritize each waste
reduction option in order to provide a direction for the
implementation program. When analyzing options there
are a number -of points you may want to consider:
Carefully evaluate technologies with no track
record.
Try to find case studies describing the application
of the option.to iron and steel.
3-17
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. Determine how much waste the option itself
produces and how much raw material it requires.
. Determine the annual operating and capital costs of
the option(s).
* Is the option easy to implement?
Don't exclude any option until it has been analyzed
completely.
High tech options are not always the best. Many mills
reduce waste through simple changes m busmess
procedures such as improved housekeep.ng and waste
segregation. Be sure the option does not s.mply ehift
waste to a different media (liquid to gas, for example) or
different part of your operation.
»ii , ' m, : '" ;. , , , '
Write'an Assessment Report
As one of the concluding activities of the pollution
prevention assessment, the task force must write en
assessment report that summarizes the results of the
pollution prevention assessment at the company leveL
Table 3.5 illustrates a typical report outline. The report
should provide a schedule for implementing Prevention
projects and be the basis for evaluating and maintaining
tPheJpoHution prevention program. It will also be> useto
secure internal funding for projects since most require
capital investment.
TABLE 3.5 TYPICAL POLLUTION PREVENTION
ASSESSMENT REPORT OUTLINE
(Adapted from the EPA Facilities Pollution Prevention
Guide)
Executive Summary
Pollution prevention potentials ,
Overall project economics rtut,inprt
Required resources and how they will be obta.ned
Pctimated time for implementation .
loSef performance measures to allow the pro.ect to be
evaluated after it is implemented
.^^^^^^g^^^^SSS^Sm^^^^^^^^
3-18
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the mill supervisor's and foreman's knowledge of
operating procedures, and experience with other
installations.
TABLE 3.4 TECHNICAL EVALUATION CRITERIA
FOR SCREENING POLLUTION PREVENTION
OPTIONS
.(Adapted from EPA Facility Pollution Prevention
Guide)
Will it reduce waste?
Is the system safe for mill workers?
Will product quality be improved or
maintained?
Is space available for installation of
equipment?
Are the new equipment, materials, or
procedures compatible with current
production operating procedures, work flow,
and production rates?
Will additional staff be required to implement
the option? ,
Will personnel with special expertise be
needed to operate or maintain the new
system?
Do utilities need to be installed to run the
equipment?
How long will production be stopped during
system installation?
Will the vendor provide acceptable service?
Will the system create other environmental
problems?
Environmental Evaluation
In. this step, the pollution prevention assessment team
must weigh the advantages and disadvantages of each
option with regard to the environment. Often the
environmental advantage is obvious: the toxicrty of a
waste stream will be reduced without generating a new
waste stream. Most housekeeping and direct efficiency
3-15
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improvements have this advantage.
More often, however, the environmental advantage is
not always so obvious. Any option which will involve a
product, process change or substitution of raw materials
should, therefore, be fully evaluated. For example, in an
EAF operation at the ARMCO Butler Works, ARMCO
reported that by segregating the various air emissions
waste streams, the baghouse dust from the
Argon/Oxygen Decarbonizing Furnace (AOD) was
briquetted off site and then blended into the EAF feed.
Previously, this waste had been sent to disposal. There
were no reported problems associated with this
"recycling".
Energy Evaluation
Energy consumption should also be considered. To
make a sound choice, the energy evaluation should
consider the entire life cycle of both the product and the
production process.
Economic Evaluation
Estimating the costs and benefits of some proposed
pollution prevention projects is straight forward, while
others prove to be complex. Cost calculations for each
option should be documented to help ensure that these
real accomplishments of your pollution prevention
program will not be overlooked when you measure the
program's progress.
If a project has no significant capital costs, its
profitability can be judged by whether or not it reduces
operating costs and/or prevents pollution. Installation of
water 'conservation controls and improvement of
operating practices, for example, probably will not
require extensive analysis before they are adopted.
Worksheet 9 Profitability (in the Appendix) can be used
to document this analysis.
Sources of income and costs to be considered include:
FORMS
Worksheet 9
Profitability
3-16
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In the screening phase, detailed cost/benefit analyses are
not necessary; rather, decisions by the team leader or
team members to consider a further economic analysis
of the option is sufficient. Table 3.3 lists questions that
might be relevant for screening options.
TABLE 3.3 TECHNICAL EVALUATION CRITERIA
FOR SCREENING POLLUTION PREVENTION
OPTIONS
(Adapted from EPA Facilities Pollution Prevention Guide)
Will it reduce waste?
Is the system safe for mill workers?
Will product quality be improved or
maintained?
Is space available for installation of equipment?
Are the new equipment, materials, or
procedures compatible with current production
operating procedures, work flow, and
production rates?.
Will additional staff be required to implement
options?
Will personnel with special expertise be needed
to operate or maintain the new system?
Do,utilities need to be installed to run the
equipment?
How long will production be stopped during
system installation?
Will the vendor provide acceptable service?
Will the system create other environmental
problems?
PERFORM A FEASIBILITY ANALYSIS
Once options have been identified for further evaluation,
the Option Description (Worksheet 8) and Profitability
(Worksheet 9) (see the Appendix) can be-utilized to
screen options. This process will assist you in
determining which options are technically,
environmentally, and economically feasible, and will also
assist you in prioritizing them for implementation.
FORMS
Worksheet 8
Option Description
3-13
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Technical Evaluation
The assessment team will perform a technical evaluation
to determine whether a proposed pollution prevention
option is likely to work in a specific application.
Technical evaluation for a given option may be relatively
quick or it may require extensive investigation. The list
in Table 3.4 suggests some criteria that could be used in
a technical evaluation. As you will note, some of these
are more detailed versions of questions asked during the
option screening phase.
AH groups in the mill that will be affected, directly if the
option is adopted should contribute to the technical
evaluation, including staff from process engineering,
production, maintenance, purchasing, etc. Customers
may also play a part in the decision and their
requirements need to be considered. Early contact with
these groups will assure consideration of their needs.
Because of economic and competitive forces in the iron
and steel industry, careful assessment of the impact of
pollution prevention options on product quality is very
important. Obviously, if the option degrades product
quality it will not be considered. Often, however, closer
calls on option viability must be made based on marginal
costs or small gains in technical efficiency.
For options requiring little or no significant capital
expenditures, the team can use a "fast-track' approach.
For example, procedural or housekeeping changes can
' often be implemented quickly, after the appropnate
review, approvals, and training have been accomplished.
New procedures for handling spent batteries or other
recyclable materials would fall in this category. (See the
earlier list of recycled material from the Bethlehem Steel
Johnston Works in this chapter.)
When installing new equipment, it is particularly
important to carefully assess the impact on the
production process. Equally important will be the
option's ability to function in the field in conditions
which are similar to your application. Venders' promises
of acceptability and compatibility must be tempered with
WHEN
EVALUATING AN
OPTION:
Talk to Mill Personnel
Your Customers
LOW COST/NO COST
OPTION MAY BE
UNDERTAKEN
IMMEDIATELY
3-14
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Raw materials, chemicals or maintenance materials, or
their transformation products can leave the process as:
Final Product
Contaminants in air streams
Constituents in wastewater
Hazardous waste solids or liquids
Concentrated waste chemicals
Non-hazardous wastes
Worksheet 5, Products Summary, can be found in the
Appendix and is used to assist in defining product
information.
Proper management and preparation for pollution
prevention activities, evaluation and implementation
requires that each stream identified in the generalized
process flow be fully characterized. For each waste
stream, the following information is required:
Flow rate
Chemical composition
Individual species concentrations
Stream pH
A sample Waste Stream Summary form Worksheet 6 is
provided in the Appendix.
Knowing which waste streams or potential waste
streams are generated, forms the foundation for a
pollution prevention program. It does not, however
provide the complete.picture. How the process currently
is managed and operated comprises a critical element of
the information necessary to develop an effective
pollution prevention program. Answers to question such
-as:
Who specifies chemical/materials?
Who negotiates their purchases?
Who manages the inventory?
Who is responsible for waste disposal?
can provide insight into materials management and any
potential impediments to pollution prevention that may
be caused by operations management.
FORMS
Worksheet 5
Product Summary
-*u
Worksheets
Waste Stream Summary
Characterize each
process stream
completely
3-1-1
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A tVDicai production process includes the interaction of
a number of other divisions within the corporation
besides manufacturers as illustrated below. The
functions of these groups have been prevousty
described (See Chapter 2). Be sure to consult them for
pollution prevention options
Receiving
Warehousing
Process Planning Support
- Manufacturing
Management
- Product Engineering
- Production Planning
- Materials Control
Physical Plant Support
- Maintenance
- Utilities
- HVAC
- Environmental Group
' - Waste Collection
Waste Disposal
Personnel Support
SCREEN OPTIONS
in this task, the audit team(s) decides which option(s) to
adopt. A fuU arid thorough technical and economic
evaluation is necessary. This effort requires particular
attention to a review of the technical feasibility and
particularly the collection of cost information. The
assessment of a project's feasibility ultimately rests with
the mill's ability to fund a project. Some options will be
found that have no cost or low cost and can be
implemented relatively easily (e.g. dust control on m II
oads to. reduce fugitive "emissions"). In others
equipment may be required to be installed to collect and
recycle a sludge.
OPTION
SCREENING
Technical
Energy
Environmental
Economic
3-12
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Raw Materials
Manufacturing Process
Air Pollutants
Air Pollution Control
Waste Water
Waste Chemicals
Waste Water
Treatment
Hazardous
Waste
Hazardous
Waste
Treatment
Non-hazardous
Waste
FIGURE 3.1 PROCESS FLOW SHEET
-------
Input Materials Summary,'defines materials used in the
process. .
Figure 3.2 represents how a generic diagram of materials
can be related to electric arc furnace (EAF) steel
production.
FORMS
Worksheet 4
Input Materials Summary
RECYCLE WATER
MAKEUP FROM VENTURI SCRUBBER
WATER SLURRY CLARIFICATION
RAW SCRAP
OXYGEN
LUXES
romo ALLOYS
ELECmCARC
FURNACES
- OXYGEN
ARGON
EAF VENT GAS
AND PAHTICULATES
HOT
RAW
STEELS
ARGON/OXYGEN
OECARBURBMa
FURNACE
VENTURI
SCRUB8MG
EAF SLUDGE (K061)
TO TREATMENT AND
DISPOSAL, 10,000 TPY
70% SOUOS, 30% WATER
FUGITIVE
EMBSONS
VENT GAS
ANO PARTtCULATES
BAGHOUSEOUST
COUECnON
EAF DUST (KM1)
TO DISPOSAL
1000TPY
Hiatmoaicn
10*
Figure 3.2 EAF Facility Flow Sheet from ARMCO Works
(Adapted from Environmental Progress, Vol. 8, No. 2. May 1989, pp. 88-96)
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