Pollution Prevention
Educational Resource Compendium:
Chemical
Engineering
Am *eor. M «lfl».11lS
313-7M.1412 • fiuc 313-OM-am • 6-mt nppeCwuWLidM
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Pollution Prevention Educational Resource Cornpe'
Goal Statement and Summary: ,
O Copyright 1995 by the Regents ofihe Uhawstry ofMidagn.
Eduoiors nay/reefy reproduce these materials for imgral«vam
'strategleefori
ittablleh a naional network of poiuflon prevention edu
In addeon to develoolng i
ntat probiemK and We may eleo update the NPPC We
9U0)
rtMarcn, ttw NPPC atao offara an Intwnahlp program
•tonal •dutttton and training, and confenncM.
pretoe-
gopher (gopherjnre.umleh.edu) end anonymous FTP
(flpjnreoxnleh.edu). Pleeae contact m If you have commanta
about our onene reeourcea or euggeettons for pubectzing our
•ducasonal matailale through ihe tntemet Thank you!
May 1988
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Pollution Prevention and
Chemical Engineering
Mjkrxxju. pciijTION »«svwncK COPPER fo« mocfl HXICATIO«
Pollution Prevention and
Chemical Engineering Resource List
The following Educational Tools and Reference Materials are
available to faculty who are incorporating pollution prevention
concepts and tools into their courses. We hope attempted to make this
list as comprehensive as possible; please contact us if you can identify
gaps and assist us in filling them with quality educational materials.
This list includes resources available through the NPPC (&);the U.S,
Environmental Protection Agency Pollution Prevention Information
Clearinghouse, Washington, DC, 202^260-1023 or ppic@epamail.epa.gov
(*B*); and the Center for Environmental Research Information,
Cincinnati, Ohio, 523-569-7562 ($). An asterisk (•) indicates materials
described in this compendium's annotated bibliography..
Educational Tools
Annotated Bibliography
Wright, Jason, and Gregory Keoteian, Annotated
Bibliography of Chemical Engineering-Related
Pollution Prevention Sources. NPPC, 1994.
Annotates more than 100 sources that address
pollution prevention from the chemical engineering
perspective. &
Case Studies
Naser.Samer. Gregory VKeoteiari, and LeviT.
Thompson, Jr. Design oft CFC-Free, Energy-
Efficient Relrigtotor. NPPC, 1993. This case
challenges stixttp to use a non-ozone-depleting
refrigerant andwipv* the energy efficiency of a
household reffijgpbr, A
Other Educational Tools
Hanion, Deborah, and Julie Bartenstein. Teaching
Those Humans to Learn: Creative Approaches to
Pollution Prevention Training, Washington: U.S. EPA,
August 1992. *B» .
Massachusetts Toxics Use Reduction Program.
Curriculum for Toxics Use Reduction Planners,
Second Edition. Lowell, MA: The Toxics Use Reduc-
tion Institute, University of Massachusetts Lowell,
1991. $40. To order, call TURI at508-934-3275. *
Problem Seta
Allen, David T., Nandkumar Bakshani, and Kirsten
Sinclair RossekJt. Pollution Prevention: Homework
and Design Problems for Engineering Curricula.
New York: American Institute of Chemical Engineers,
American Institute for Pollution Prevention, and Cen-
ter for Waste Reduction Technologies, 1992.155
pp. $35. To order, call AlChE Customer Service at
1-800-242-4363.* _
Welker, J. Reed, and Charles Springer. Safety,
Health, and Loss Prevention in Chemical Processes:
Problems for Undergraduate Curricula. American
Institute of Chemical Engineers, 1990.479 pp.
To order, call AlChE Customer Service at
1-800-242-4363. V
Syllabi and Curricula
Budd, William. ESMRP 490/499 & ES/RP 59QG99:
Introduction to Pollution Prevention. Washington
State University, March 1993. A
Counce, R. M. C/i £ 581: Industrial Pollution
Prevention. University of Tennessee. 1992. * A
Denny, Dale. Chemical Engineering 593-O:
" Waste Reduction in Industry. North Carolina State
University, March 1991. * A
Design for Recycling Team. Teaching Environmen-
tally Responsible Design, Shirley f. Fteischmann,
ed., Grand Valley State University, 22 October 1992. *
Naiiowi Pollution Pwvmtton C«m« (or Higlwf Education • Univtroay of Michigan
Dana BuHdlng. 430 Et*t Univtrsrty. Ann Artor Ml 48109-111S
Phone: 313.764.1412 • Fax: 313.936.2195 • E-mail: nppcOumich.cou
May IM rapreducad
fraaly for non^omnwrcial
•ducational puipoaas.
t • 1
OCMMM995
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Ocfiand, Oiane. C^PE 5533: Hazardous Waste
Process:rg Engineering III. University of Minnescta-
Duluth, September 1988.
EncKson. Larry. ChE 650: Hazardous Waste
Engineering Seminar. Kansas Stale University, 1992.
Fleischman, Marvin. ChE 694: Waste Reduction,
Treatment, & Disposal. University of Louisville, Fall
1992. * A
. ENVE 534: Industrial Waste Management
University of Louisville, March 1991 and 1992. * A
. Pollution Prevention, Waste Treatment, and
Disposal. University o? Louisville, Spring 1994. ^
Hutzler, Neil J. Educating Engineers for the Environ-
ment. Michigan Technological University, 1992. *
_: . CE 490: Environmental Fundamentals for
Engineers. June 1992.
Kidd, David. Industrial Waste Reduction: A Three- •
Credit University Curriculum for Environmental
Engineering. Alaska Health Project, Anchorage, AK,
October 1991. A
Kummler, Ralph H.. James McMinicking, and Robert
W. Powitz. A Problem on Hazardous Waste Man-
agement. Wayne State University, Sept 1989. *
Minet, Ronald G. ChE 486: Design of Environmen-
tally Benign Chemical Process Plants, University of
Southern California, Winter 1995. A
Overcash, Michael, and Christine S, Grant. CHE
598 O: Advances in Pollution Prevention: Environ-
mental Management for the Future. North Carolina
State University, Spring 1993. &
Pojasek, Robert B. CE-194J: Pollution Prevention.
Tufts University, March 1993.- A
von Brauh. Margrit. ES 40*504 & ENGR 599:
Engineering Risk Aammtnt for Hazardous Waste
Evaluations. Univ««BB*Waho, March 1992.
.' . ES4
Management. Ui
Video
Amoco Corporation, Second Victory at YorMown.
Documents the cooperative project between Amoco
and the EPA to explore pollution reduction at a
petroleum refinery. The results of the project have
important implications for both engineering and _
business. 1993. 30 minutes, $14. A
California Department of Toxic Substances Control.
Waste Minimization: for Inspectors ($15, video
#1500) and Why Waste? Waste Management for
Today's Business ($15, video #1501); both include
free supplementary materials. To order, call DTSC
at 916-322-3670.
McDonald's-EDF Environmental Task Force. 1993.
16 minutes, $14. A
3M Corporation. 3M and the Environment: An Indi-
vidual Effort. Eight minutes. To borrow the video,
call 3M at 612-778-4791.
U.S. Environmental Protection Agency. Beyond
Bussiness as Usual: Meeting the Challenge of Haz-
ardous Waste. 28 minutes. To obtain a copy, call
Mary Ann Welch, Region VIII Office of Environmen-
tal Education (303-294-1123) and arrange to sendin
a blank tape.
Reference Materials
v,607: Hazardous Waste ^
of Idaho, October 1990.
Westermann-Ctark, Geraid B. Incorporation of Pollu-
tion Prevention Content into Undergraduate Courses
in Chemical Engineering. University of Florida, 1992. •
Books
— General Pollution Prevention —
Forester, William S., and John H. Skinner. Waste
Minimization and Clean Technology Waste
Management Strategies for the Future. San Diego:
Academic Press, 1992. *
Freeman, Harry M. Hazardous Waste Minimization.
New York: McGraw-Hill, 1990. •
Hirschhom, Joel S., and Kirsten U. Oldenburg.
Prosperity Without Pollution: The Prevention
Strategy for Industry and Consumers. New York: ,
Van Nostrand Reinhold, 1991.
Martin, William F., John M. Lippitt, and Timothy G.
Prothero. Hazardous Waste Handbook for Health
'" and Safety. Boston: Butterworths Publishing, 1987.
Naar, Jon. Design fora Uvable Planet. New York:
Harper and Row, 1990.
2 • FUsourca List
October 1995
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Pollution Prevention and
Chemical Engineering
Pollution Prevention Applications
to Chemical Engineering
Prepared by Jeff Handt
Over the last two decades, this country's energy policy
shifted from a desire to lessen its dependence on foreign
oil to a more practical interest in efficient use of energy,
regardless of its source. This change reflects an unlikely
convergence of altruistic concerns with bottom-line,
'business-minded thinking: in the global,economy,
companies will seek to wed technological progress
with sustainable development which is loosely defined
as "development that meets current needs without
compromising future resources." It may be realized
through the emerging ethic of pollution prevention
(P2>. This mindset seeks to eliminate environmental
problems before they develop by considering ecological
impacts during the earliest stages of product design.
Because the focus of pollution control shifts up the .
process line from the end to the front, this approach is
also known as source reduction. •
If justified concerns for the planet's well-being are not
incentive enough, P2 is being strongly driven by eco-
nomic forces. The U.S. Department of Commerce esti-
mates that the domestic market for "greener" goods
and services amount* to $50-60 billion annually.
And other regionttftbe global economy have already
caught on. DennBlp'tnd The Netherlands, for example,
have undertaken (intensive studies to apply life cycle
accounting to consumer and commercial products.
The German government has taken what is probably
the most aggressive policy, as evidenced by its recent
requirement that retailers accept all product packaging
returned by customers. While it would be premature
to judge the success of this effort, the legislation has
certainly had seismic effects on consumer and corpo-
rate behavior across the Continent. Process modifica-
tions have also put German auto manufacturers in a -
position to accept retired car bodies.
In a notable departure from traditional environmental
policy, which is characterized by punitive measures
and mountains of legislation, the United States is
gravitating toward P2 almost but of common sense.
After the cornerstone Pollution Prevention Act of 1990,
the United States EPA issued a series of policy state-
ments that tended to encourage the conversion, rather
than dictate it through the old "command and control"
tack. Significantly, the government as a whole-is also-
leading by example. Among other programs, federal
agencies have converted to exclusive use of high
recycled content paper.
This new effort to reduce pollution at the source
presents a profound challenge for chemical engineers.
They may find improvement to existing systems can be
marginal without financially risky overhaul/and that
design of new systems will involve unfamiliar consider-
ations and tradeoffs. But, as always, they will be in a
situation of unique responsibility. While a convincing
case can also be made for the' civil engineer's role, .
chemical engineers, involved in product and process
design in the politically sensitive and physically
dangerous realm of chemicals, have a greater impact
on our surroundings than most other engineers. They
can thus have a dramatic positive effect on the global
environment. Any chemical engineering curriculum
that ignores this relationship is doing a disservice to
the profession and the public.
The accompanying "Pollution Prevention and Chemical
Engineering Resource List" serves to address this need.
It inventories educational tools arid reference materials
by media type and subtopic The Problem Sets category
includes a collection of 21 problems that cover life
cycle analyses, unit operations design, P2 economics,
and other subjects developed at UCLA by David" Allen,
National Pollution Prevention Canter for Higher Education • University of Michigan
Dana Building. 430 East University. Ann Arbor Ml 48109-1115 .
Phone: 313.764.1412 • Fax: 313.936.2195 • E-mail: nppeOumien.edu
May be reproduced
freely, (or non-commercial
educational purposes.
Introduction • 1
. Octooer 1994
-------
Nandkumar Baksham, and Kirsten Sinclair Rosselot.
The Case Studies listing include Franklin Associates'
ser.es on consumer-product packaging, as-well as a
document produced through the Center on the design
of a CFC-free refrigerator. There are too many Books'
and Journal Articles to single out any particular titles
for special mention; this situation is encouraging ex-
cept for efforts to organize and condense this material.
The potential ramifications of P2 for chemical engineers
are widespread. Successful waste reduction programs
have been incorporated in metal fabrication, electronics,
textiles, petroleum fuel products, chemical products,
printing and publishing, and many other businesses.
The Reports section cites the EPA's Guides to Pollution
Prevention in 12 different industries.
Once the primary target of regulations, fines, and
public scorn, the chemical industry now has an
opportunity to be a champion of P2. The Chemical
Manufacturer's Association (CMA) responded in 1988
with "Responsible Care: A Public Commitment" This
program embraced a set of operating guidelines that
the CMA's 185 member companies are obliged to
follow. These tenets include communicating with
employees and the public, coordinating emergency
response plans with local officials, ensuring worker
health and safety, and safely transporting materials
outside the plant's fence line. P2 has been identified
as a key practice to implement these guidelines. Any
CMA company that fails to pursue this agenda will
lose its membership. The message "Responsible Care"
sends is that cutting corners with respect to ecological
criteria will reduce future profitability, either directly
on the ledger or through bad public relations.
Some chemical companies reached this .conclusion
years ago, and their ability to clean up their processes
will also draw others to P2. While a number of promi-
nent manufacturers have instituted very successful
waste reduction programs, two will be mentioned here.
3M's "Pollution Prevention Pays" is often credited as a
pioneering effort. Instituted in 1975, this program has
carried out 3,000 projects, cutting the company's re-
leases and ite energy consumption by half, saving $530
million. The Report* and Video sections have more
information on 3M'» work in this area. Dow Chemical
Company began its active "Waste Reduction Always
Pays" (WRAP) program in 1986. In 1990, it launched
53 P2 projects whose savings exceeded the investment
after only one year. More on WRAP can be 'found in
the Case Studies section.
The "Resource List," by no means exhaustive, is
intended to help faculty incorporate P2 concepts into
their courses. Many of the materials are synopsized
in the accompanying "Annotated Bibliography of
Chemical Engineering Related Pollution Prevention
Sources." Suggestions for additional entries are
encouraged and comments are welcome.
Original produced on Harnrnermill Unity DP,
a 50% post-consumer/50% pre-consumer recycled paper
made from de-inked old newspapers and magazines.
Th« National i liiWn Wi • wrtlon Cantar
for Highar
University o4
430 East Ui
Ann Arbor,.... _
. Phone: 313-7S4i14» • ,
• Fkx: 313-936-2195
• E-mail: nppcflumicti.edu
The mission of the NPPC is to promote sustainabled*T'°.l?m£!,t
by educating students, faculty, and professionals about pollution
prevention; create educational materiaU; provide tools and
strategies for addressing relevant environmental problems: and
establish a national network of pollution prevention educators.
In addition'to developing educational materialsand conducting
research, the NPPC also offers an internship program, profes-
sional education and training, and epnferencas.
•^•^^•^^•^^~^—
Your Input l»W*leom»! ' •
We are very interested in your feedback onthesei««•**
Pleas* take a moment to offer your comments and communicate
memto us. Also contact us if you wish to receive a dements
list order any of our materials, collaborate on or review NPPC
resourees^r be listed in our 0/recfo/y of Pollution Preverton
in Hightr Educftion.
W»'r» Going Online! '
The NPPC provides information on its.programs and educational
materials through the Internets Worldwide Web; our URL ,s:
http://iiifww.anm.umicri.edu/nppc/ „,„„„«„.
Please contact us if you have comments about our ont.ne
resources or suggestions for publicizing our educational
materials through the Internet Thank you!
Introduction • 2
Octooer 199*
-------
NPPC Resources Tne NPPC produces and distributes all of these
resources; in many cases, the NPPC has also developed them. All appear
in the,Resource List (see previous section).. ,
D Annotated Bibliography of Chemical Engineering-Related
Pollution Prevention Sources. Describes 120 of the publications
cited in the Resource List
D A Chemical Engineer's Guide to Environmental Law and
Regulation. This 100-page guide is designed to give chemical
engineers a general overview of the field of environmental law.
" Main sections discuss (1) specific reasons for chemical engineers
to understand environmental laws and regulations; (2) the roles
of legislatures, administrative agencies, and courte; (3) the inter-
action of environmental laws at. federal, state, and local levels;
and (4) relevant provisions of nine federal acts: the Toxic Sub-
stances Control Act; the Federal Insecticide, Rodenticide, and
Fungicide 'Act; the Occupational Safety and Health Act; the
- Qeah Air Act the Clean Water Act; the Resource Conservation
and Recovery Act the Comprehensive Environmental Response,
Compensation, and Liability Act; the Emergency Planning and
Community Righfrto-know Act; & the Pollution Prevention Act
D Course Syllabi. A collection of syllabi from university courses
- involving pollution prevention and chemical engineering.
Authors: William Budd (Washington State); Pete Counce
(Tennessee); Marvin Fleischman (Louisville); Neil Hutzler
(Michigan Tech); David Kidd (Alaska-Anchorage); Dale Denny,
Michael Overcash and Christine S. Grant (North Carolina
State); Robert Pojasek (Tufts); and Margrit von Braun (Idaho).
a Open-Ended Problem: T3«»ign of a CFOFree, Energy-Efficient
Refrigerator." this 145-page case challenges students to design
a household refrigerator mat uses a non-ozone-depleting re-
frigerant and also is energy-efficient Teaching aides include
short discussions of issues related to the evolution of the refrig-
erator and the subsequent environmental threat A proposed
• design solution leads from thermodynamic calculations to a
choice of refrigerants mat when combined with the refrigerator's
specifications, will meet the design requirements. Appendices
include refrigerant manufacturers' data and output from a
thermodynamic calculation computer program.
D Open-EndedProblem: "Determining Mass Balances in Fprd-
Wixom's Phosphate Coating System." This assignment pro-
vides students in a chemical engineering materials balance
course with exposure to actual processes. Student groups are
-asked to develop a flowchart for a'planf s phosphate coating
system and suggest reconfigurations that would minimize the
amount of waste generated. The major source of information
is a multimedia tour of the Phosphate Coating System of Ford
Motor Company's Wixom Assembly Plant This tour, on
CD-ROM, includes video clips from the actual system,- a short
description of each of the system's 12 stages, and supplementary
explanations; students can explore the system at their own pace
and in any order they wish. ,. '_ .
; ~ : " '. ~ May 1995
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Jt*
D Ca*s Study; "Case AJ McDonald's Environmental Strategy,*
"Case Bl: The Clamshell Controversy,* "Case Bfc McDonald's
Decision," and "Case C Sustaining McDonald's Environmen-
tal Success." Cases A and B focus on the work of a Joint Task
Force developed by McDonald's Corporation and the Environ-
mental Defense Fund, whose members addressed McDonald's
solid waste strategy and the question of whether to replace
polystyrene packaging with paperwrap. Case C examines the
company's reaction to public concern about the sustainability of
beef. Includes a teaching note as well as notes on life cycle
analysis and solid waste issues.
Q Cue Study: 'Agent Regeneration and Hazardous Wart*
Minimization.* This- 12-page case analyzes IBM's search for
innovative solutions to a complex operational/ environmental
problem in a chemical etching process. Decision analysis of the
' alternatives is central to the case. Includes a teaching note.
D CaneStady: "Degreaser Replacement at Ford Motor Company's
Climate Control Division,* This case analyzes Ford's pilot
study of aqueous degreaser units as an alternative to trichloro-
ethytene (TCE). Includes discussion questions and problem stfs.
D Video: "McDonald's/EDFEnvironmental task Force.* This}
16-minute video is an accompaniment to the written case study.
The principals involved are Robert Langert, McDonald's Cor-
poration director of environmental affairs, and Jackie Prince?
Environmental Defense Fund.staff scientist; they present their
different perspectives on me joint project Issues discussed
include reasons for and reservations about participating;
organizational goals of the project results, and advice for
others thinking of pursuing similar projects.
D Video: "Second Victory at Yorktown.* This 31-minute video
examines the joint Amoco/EPA cooperative project that ad-
dressed the reduction of pollution from a petroleum refinery.
As background, it explains pollution prevention, risk analysis,
and decision-making; it then goes on to describe the expectation*
• and concerns of each of the participants and, finally, the results
oftheproject This inaterial is suited for surrey courses on en-
vironmental issues, chemical and industrial engineering classes,
and business classes on operations management and business .
law (voluntary vs. mandatory programs), this video is intended
for students, faculty, business managers, and engineers.
•*
*
M«y1»5
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^A^ Pollution Prevention and
«** Chemical Engineering
Table of Contents
Explanation of Compendium Content*
Introductory Material*
D Overview of Environmental Problems
P Pollution Prevention Concepts and Principles
D Pollution Prevention Applications to ChemicaJ. Engineering
Pollution Prevention and Chemical Engineering Resource U«t
• NPPC Resource* . ' ' . '
D Annotated Bibliography of Chemical Engineering-Related
Pollution Prevention Sources
O A Chemical Engineer's Guide to
Environmental Law and Regulation
D Course Syllabi
D Open-Ended Problem: ."Design of a^CFC-Free, Energy-Efficient
Refrigerator"
D Open-Ended Problem: 'TJetermining Mass Balances in
Ford-Wixom's Phosphate Coating System"
D Case Study: "Case A:. McDonald's Environmental Strategy,"
"Case Bi: The Clamshell Controversy," "Case B2: McDonald's
Decision," and "Case C Sustaining McDonald's Environmental
Success" (includes teaching notes)
D Case Study: "Agent Regeneration and
Hazardous Waste Minimization"
D Case Study: "Degreaser Replacement at Ford Motor
Company's Climate Control Division"
D Video:. "McDonald's/EDFEnvironmental Task Force"
D Video: "Second Victory at Yorktown"
May 1995
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Pollution Prevention and
Chemical Engineering
. aO—TVX fGYOmOH CSXTtB FO« MOHffIEDOCAT1OH
is'
<£•
Explanation of Compendium Contents
• Introductory Materials
D Overview of Environmental Problems. Each chapter highlights
a major area of environmental concern: energy use, global
change, resource depletion, land use and development, waste,
air quality, water quality and quantity, ecological health, and
human health. Includes definitions of concepts and terms, cur-
rent data and research findings on the state of me environment,
tabtes, figures, and guidance on obtaining more information.
This document is designed to help faculty in all disciplines pre-
pare course materials and lectures. For people who may not
have extensive knowledge of environmental issues, it provides
background information; for those already familiar with environ-
mental problems, it is a convenient, concise source of current
data. The formal allows individual topic areas to be easily re-
produced for distribution to students; all figures and tables anr
provided in a'full-page format suitable for overhead projection.
D Pollution Prevention Concepts and Principles. This shorter
paper introduces the concepts, terminology, objectives, and -
scope of pollution prevention. If discusses how government
and tHe private sector an currently perceiving and implement-
ing pollution prevention and describes the barriers and benefits
encountered in implementing pollution prevention activities.
D Pollution Prevention Applications to Chemical Engineering.
Chemical engineers have a critical role in pollution prevention.
This brief introduction justifies pollution prevention strategies
on 4he bases of "altruistic concerns [as well as] bottom line,
business-minded thinking' and highlights educational resources
to assist faculty in incorporating key poiiution prevention con-
cepts into their courses.
• Polhitton Prevention and Chemical Engineering Resource List
This is a list of all relevant resources known to me NPPC, including
the materials we produce and/or distribute. The Educational Tools.
section lists one annotated bibliography, two case studies, two books,
two problem set collections, 19 syllabi and curricula, and six videos.
The Reference Materials section lists 30 books, 45 reports/guides,
91 articles, seven case studies, three government offices, three orga-
- nizations, and 50 faculty involved in pollution prevention education.
Under each publication type, entries are listed within Ijie following
categories: "General Pollution Prevention," "Process Design," "Health
and Safety," "Ethics," "Case Examples," "Life Cycle Assessment and
Design," "Managerial Strategies,''and "Education." Most of the
materials are commonly found in college libraries or bookstores; for
those that aren't, the list includes information on obtaining mem.
May 1996
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Emergency Response - Spills, Accidents
Modeling•
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Handouts , '
Aoril 8 sitte visit to GE - .Dishwasher Manufacturing &
Assembly & Wastewater Treatment Plant
April 15 • • Brains'torming: Pollution Prevention Assessment at
General Electric
April 18 Field Trip: Outer Loop Landfill - Waste Management,
Inc.- Voluntary
April' 22 Pollution Prevention Concepts
Remediation - Science vs. Risk Based
Risk Assessment, Coburn-Forster-Kane Equation for
Ambient CO Standards, Toxicity
Text, pp 19-24, Questions 1,3
Text, pp 93-95 • • .
April 26 ' Tour of Morris .Forman WWTP, Louisville-Jefferson
County Metropolitan Sewer District'
, May 6 , Final Exam ' ,
Environmental Issues and Priorities
Environmental Management at a Major chemical Manufacturer
Environmental .Liabilities and Crimes
Regulations and Regulatory Issues - RCRA, TSCA, CERCLA, SARA 313
(Toxics Release inventory)/ Clean Air Act
Toxicology
Underground Storage Tanks
Air Pollution in Jefferson county
Industrial Wmstewater Pretreatment
Toxic Sub»lteces Control Act
Hazardous WWfte Transportation & Disposal
•Environmental Audits for Land Acquisition
Hazardous Waste Characterization
Pollution Prevention
Municipal Solid waste Disposal - incineration, Landfilling
Waste Treatment Methodology
-------
Product Stewardship., Process Ha.zards Management,. •
CMA Responsible Care Program, Chemical Capital
Spending for Pollution Abatement Equipment,
Site Remediation,, SuperFund - pp391-394, 396, 401-
402-, : 404-4-06 (Seyour, IN)', 420-424, Ch 14.. #1,4. •
Superfund Problems -•CEN, Chemecology ' •
Mar il " ,• Sheldon, . McCpl-lum, DuPont, Louisville - Site
•- "• Remediation • . . " . • ,
. . Videos: "Beyond Business as Usual" (waste mgmt.)
- " ' ' . "The Toxics Release Inventory: - Meeting the
, ' Challenge"
1 ..'".Let's Clean-Up Ame'rica" '- 'Marine Shale
..•''-_ Processors - •. '• ' '/,
- - .. ' • Handouts on "all 3 videos.'
" Mid term • ;"'..; . - /
Mar 18 ' _- • .Spring Break ' ' , .
Mar 25 - In the News-"Christians Lack Proper Reverence for
Nature" - Environmental Stewardship .
Air Pollution - Definitions of Primary & Secondary
, Standards , '
Hazardous Waste Characterization
News Article - "Compromise reached on Cleanup .Bill"
- Clean up Standards & Lists for hazardous materials
.spills .
Hazardous waste generator report - GE Appliance park
Handout, Text: RCRA, pp73-78, pp 88-98,
Appendices B, C,. D
Questions: Ch4 - 4, 5; Ch5 - 1 to 4
s ..... • -
Pollution Prevention - , "
Video: "Less is More: Pollution Prevention is Good
Business", EPA, 23:13 - Handout --;..'
. . N«ws Artiple - Seriate Bill 29,6-Hazardous Waste
Reduction
Handout: Types of Information Needed for Waste
Minimization Assessment
Text: Ch 6 , .
Questions: Ch 6 *• 1, 2, 5, 6 '.' •• -: . .
April 1 Pollution Prevention, Pre-Site Visit Orientation,,
Sandy Kmiec; General Electric. Appliance Park, "GE
Appliances Dishwasher Operations., Applicarice Park
Building 3" - Handout
• ' • General Concepts of Pollution Prevention - Examples
, '• " from WMAC Assessments. ' •' ' •
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Handout, Text: pp. 426-428, Ch7 -Chemical',
Physical, & Chemical Treatment
. ' BOD & TSS Surcharges
Water Consumption, Effluent Disch-arge, & Rates,
• In-Plant Consumption, Reuse, & Evaporation • .. .
Waste Management Concepts - Dilute & Disperse,
Concentrate & Confine
In the News - Lack of State Regulations Concerning ^
Hazardous Waste Spills - No more stringent than, . >
Clean to Background or Non-Detectable Concentrations J
Comparative Risk Assessment of Environmental >
Problems - EPA Science Advisory Board .Study _
(Handout) '
Risk - Ch2r 2-#s 1-3 .
Feb 26 In the News - Burning of Toxic Waste, .Trash to Steam
Plant
"Environmental .Liability", Rick Greenberg, Attorney
- Handouts, Chs.3.-6,
More on "Environmental Issues in General" - Property
Transactions, Waste Oils, Air Emissions, Pollution
Prevention, Life Cycle Assessment, Product
Stewardship '
' Municipal Waste Water Treatment, Louisville
Metropolitan Sewer District,, Morris Foreman WWTP,
Primary - Secondary (Oxygen Activated Sludge)
Treatment & Sludge Handling
Mar 4 "Air Pollution Issues in Louisville - Urban -Air Shed
Model for VOCS & NOx, Clean Air Act, MACT, SO2.
Offsets, Air Permits, George Abrahim, Law
Environmental, Louisville - Handouts: List of High
Risk Pollutants (HAPs); NOX Control, A Double
Hitter: Ozone and Acid Rain Control
, Interrelationships between various regulations
'"dealing with hazardous materials - Life Cycle of a
Chemical-TSCA, CERCLA, RCRA, CAA, CWA, HMTA,
OSHA, etc. - Handout .
In the News - Alternatives to Hazardous Waste
incineration; Louisville Garbage to Steam Plant;
CFCs - Global Warming, HCFCs .
Additional issues/Concerns - Hazardous Waste
Transport
Environmental Issues (cont.) - Industry Concerns:
-------
. '• - - ' • - ' • ' ENVE 534 SPRING 1992
INDUSTRIAL WASTE MANAGEMENT
jan. .15 introductions & Organization
; ' overview of Environmental. Activities in a Chemical
plant: Movie, "The Need to Know", CMA - Handout .
: Environmental' "crimes: Video, »The_ Burial Ground"
(Hazardous waste, dumping) - Handout ,..- .
•• . -. ' Text: Ch 1, Questions 1,6 . '
Jan 22 . "overview of. ' Environmental Regulations", Dave
Fetter, Law Environmental . . _
Handouts; Text, Chs: 3 , 4 ; Ch 3 - 2 , 3 , 4 .
Tears: An inspectors' Guide" '
'Toxicology - video: Carcinogens, Anticarcinogens,
and Risk Assessment"/ Bruce Ames
pp 6^8, 47, 65, ,93-95 /
' Ch5 -#5, 6 " ' ' ..
Council
;
, 250, 254-255., 256, 261, 263, .267-
268, Handout, Ch 9- #s 3,5,7,
ch 5' -{thru p 96) -*s;l-6 •
DOT, 1990 Emergency Response Guadebook
-Tcu* Standards, Use of . MSDS -. Naptha as • an
BAT, BOAT, MACT, Risk Based
Council on Economic Competetiveness
Superfund - NPL -Lees' Lane Landfill -
..-mrh^trial Wastewater Pre-Treatment & Disposal to
•poh 19 ino-USuriax waa>u«Bw»*•<=•»• __*. «_+.(-!/-.H<=" John
teD< a r>nTw - OCPSF-Standards & Treatment Methods> , oonn
wefl Rhone-Poulenc (Biox, ChemOx Air Stripping
Steam Stripping, Hyroxide Precipitation)
-------
Pollution Prevention and
Chemical Engineering
Industrial Waste Management
'Marvin Fltischman
ENVE 534,1391
University of Louisville
Nwon- Poison Pr^wdon CM.Jdr W Wj-ft; jjj**** °' MChi9"n
Dan* Buldino. 430 EMt Univ«ftity. Ann Artior Ml 44109-1115
Phon«: 313.784.1412 • F«: 313.9365195
-------
9. Davic H. Siadle.' Salts Workshop
Sandier Saks Institute, Inc. .
Gre«asprii!g Valley Road
Stevenson, Maryland 21153
10. Pollution Prevention Pays - Instruction Manual
North Carolina Pollution Prevention Pays Program
3825 Barren Drive * -
Third .Floor , - • • .
Ralejgh, NC 276Q9 ' ,
.. . .
The course development and presentation was sponsored by .
' North Carolina Department of Waste Reduction
3825 Barrett Drive
• • ' Third Floor •
Raleigh, North Carolina 27609 < > . •
Gary Hunt, Director
• (919)5714100 ,
f
'
-------
There ^ bc.'oc^onai short quizzes on assisned materials. Tte.' wfli b. a final «anunadon:
Grade. Breakout:
20%
Class Presentations
Homework
'To* . 100*
Reference Materials:
L Waste Minimization Opportunity Assessment Manual - EPA/62S/7-S8/003
2. Waste Minimization Resource Manual - 1989
Chemical Manufacturers Association
2501 M Street, N.W. . •
Washington, DC 20037
(202)8871100
3. Waste Minimization: Manufacturers' Strategies for Success - 1989
National Association of Manufacturers
Publications Coordinator
1331 Pennsylvania Avenue, N.W.
Washington, DC 20004-1703
4. Pollution Prevention Benefits Manual
Dr. Ronald T. McHugh
US Environmental Protection Agency
Office of Solid Waste
Washington, DC 20460
5. Statistical Analysis for Decision Making - Morris Hamburg
Harcourt Brace Jovtnovica Publishers
757 Third Avenue .
New York, NY 10017
US Environmental Protection Agency
Office of Health and Environmental AssiriTmntt
Washington DC, 20460
7. Health Assessment Documentor Polychlorinated Dibenzo^Dk-ms - EPA/600/8*4/014F
US Environmental Protection Agency
Office of Health and Environmental Assessment
Washington, DC 20460 ' .
8. Scientific American - September 1989
-------
Reports ... -
— General Pollution Prevention —
Chemical Education for PuCiic Understanding
Program, 1989 Annual Report. September 1989. -
Chemical Manufacturers Association. Pollution P're- .
ver.tion Resource Manual. Washington: CMA, 1991.
250- pp. 575 f550 for CMA members).To order, .
caii202-887-.1253. *
BindceuteLMark A. "Chrysler Corporation: Perspec-
tives on Pollution Prevention." Presented at Pollution
Prevention: The Importance of Collaborative Efforts,
• Wooas Hole, MA, 1 June 1992.
Tracking,. Toxic Substances at Industrial Facilities: .
• Engineering 'Mass Balance Versus Materials • '.
•Accounting. Washington: National Academy Press,
July-1990. -'..'. • ' '
U.S. Environmental Protection Agency, Office of
Prevention, Pesticides and Toxic Substances'. 1993
Reference Guide to Pollution Prevention Resources.
(EPA/742/B-93-001) Washington: U.S. EPA, Febru-
ary 1993. «B* .
, Office of Research and Development.
Guides to Pollution Prevention. Washington:
.U.S. EPA. .
, - The Printed Circuit Board Manufacturing Industry.
(EPA/625/7-90/002) 1990.*
- The Pesticide Formulating Industry.
(EPA/625/7-90/004) 1990.*
- The Paint Manufacturing Industry.
(EPA/625/7-90/005) 1990. *
- The Fabricated Metal Industry.
(EPA/625/7-90/006) 1990. * _ - • • .
- The Commercial Printing Industry.
, (E'PA/625/7-90/008j 1990.,* '.
- Selected Hospital Waste Streams:
(EPA/625/7-90/009) 1990. *
• - Research and Educational Institutions.
(EPA/625/7-90/010) 1990.*
- .The Photoprocessing Industry.
(EPA/625/7-91/012) 1991.* .';
• - The Auto Repair Industry.
(EPA/625/7-91/Ot3). 1991.* ' •
. ' - Fiberglass'Reinforced and-Composiie Plastics.
(EPA/625/7-91/0-14) 1991.* - .•• '.
-'Marine Maintenance and Repair. . ,
iEPA,625;7-31 015) 1991.'"*
- The Automotive Refintshing Industry.
(EPA/625/7-91/016) 1991.* _ • ' .
..- The Pharmaceutical Industry:
(EPA/625/7-91/017) 1991. * ;
Waste Reduction: A Cooperative Search for Solu-
'tions, Volume-1: Conference, summary. The Center
for Environmental Management, Tufts University,
National Academy of Sciences Conference Center.
Woods Hole, MA, 15 June 1988. Medford, MA:
CEM, Tufts University, 1988. * '
— Design (General) — .
'Design for Recycling Team. Teaching 'Environmen-
tally Responsible-Design. Shirley T. Fleishmann,
ed., Grand Valley State University, 22 Octobe.r 19.92.
Garrett, Roger L. "Pollution Prevention in'Chemical
- 'Synthetic'Design." Reprints'of Papers. Presented at
the 204th ACS National Meeting (23-28 August) 32,
no. 2 (1992): 251-253.
Overby, C. "Design for trie Entire Life Cycle: A
New Paradigm?" '1990 ASEE Annual Conference, .
552-563. -....-- ,
U S. Congress, Office of Technology Assessment.
Green Products by Design: (#052-003-01303-7)
Washington: U.S. Government Printing Office, 1992.
Available for $6.50 from GPO: 202-512-1800 (fax: .
202-512-2250)-* . ' -
U.S. 'Environmental Protection Agency, Office of
Research and Development. Facility Poltution :
Prevention Guide. (EPA/600/B-92/088) Cincinnati:
Center for Environmental Research Information,
May 1992. * '.-."'"
:—. Office of Research and Development.
.Stratospheric Ozone Protection: Complying With the.
Refrigerant Recycling flu/e-(EPA/430/F-93/010).
Stratospheric Ozone Protection Division, U.S. EPA,
Washington, D.C., June 1993. Available free of
charge from the Stratospheric Ozone Information
Hotline, 800-296-1996.
— Process Design—T
Hersh, H. N. Energy and Materials Flows in the
Production of Pulp and Paper. Chicago: Argonne
•' National Lab/ -
4 • Resource Ust
October 1995 •
-------
-'s.V-rr-'^ew Y:rx: Van Ncs;rara Re 73-30 7 WA C. 1991.
— Process Design —
Breen. Joseph J., and Michael J. Dellarco. Pollution
Prevention in Industrial Processes: The Role of
' Process Analytical Chemistry. Washington: Amen-
can Chemical Society, 1992. *
Conway, R. A.. John H. Frick, David J. Warner,
Calton C. Wiles, and E. Joseph Duckett. Waste •
• Minimization Practices.- Baltimore: ASTM, 1989.
Cralley, Lester V.,.and Lewis J.'Cralley. In-Plant
Practices for Job Related Health Hazards.Control,
Vol. I: Production Processes. New York: John
Wiley, 1989. * .
' . in-Plant Practices for Job Related Health
Hazards Control, Vol. II: Engineering Aspects.
New York: John Wiley, 1989. *
Higgins, Thomas. Hazardous Waste Minimization ^
Handbook. Chelsea, Ml: Lewis Publishers, 1989.
Overcash, Michael R. Techniques for Industrial Pol-
lution Prevention: A Compendium for Hazardous
and Non-Hazardous Waste Minimization. Chelsea,
Ml: Lewis Publishers, 1986. *
Sawyer, Donald T., and Arthur E. Martell. Industrial
Environmental Chemistry: Waste Minimization in In-
dustrial Processes and Remediation of Hazardous
' Waste. New York: Plenum Press, 1992. *
Tavlarides, Lawrence L. Process Modifications for
Industrial Pollution Source Reduction. Chelsea, Ml:
' Lewis Publishers, 1985. *
Teia A. S. Chemical Engineering and the
Environment. New York: Halsted Press, 1981.
U S EPA and ICF Consulting Associates Inc. '
•Solvent Waste Reduction. Park Ridge, NJ: Noyes
Data Corporation, 1990. •
— Managerial Strategies —
Conway, R. A., John H. Prick, David J. Warner, .
Calton C. Wiles, and E. Joseph Duckett. Waste
Minimization Practices. Baltimore: ASTM, 1989.
H gg -s. Thomas. Hazardous Waste M.r»r:;za: c*>
Har.cccc'x. Chelsea. Ml: Lewis Publishers. 13Q3.'
Overcash, Michael R. Techniques for tndustra! Pol-
lution Prevention: A Compendium for Hazardous ana
Non-Hazardous Waste Minimization. Chelsea. Ml:
Lewis Publishers, 1986.
Pojasek, Robert B. "Pollution Prevention Progress."
In Environmental Risk Management—A Desk Refer-
ence 503-519. Eric B. Rothenberg and Dean Jeffrey .
Telego, eds. Alexandria, VA: RTM Communications,
1991. . •' .
-^Health and Safety —
Asfahl C Ray. Industrial Safety and Health Manage-
ment. Englewood Cliffs, NJ: Prentice. Hall, 1990..*
Colvin, Raymond J. The Guide to Successful Safety
Programming. Chelsea, Ml: Lewis Publishers, 1992. * -
Growl Daniel A., and Joseph F. Louvar. Chemical
Process Safety: Fundamentals with Applications.
Englewood Cliffs, NJ: Prentice Hail, 1990. *
Lipton Sydney, and Jeremiah Lynch. Health Hazard
Control in the Chemical Process Industry. New York:
John Wiley, 1987.
Kavianian, H. R., and C. A. Wentz, Jr. Occupational
and Environmental Safety Engineering and Manage-
ment. New York: Van Nostrand Reinhold, 1990. *
Mayo Dana W., Ronald M. Pike, Samuel S. Butcher,
and Peter K. Trumper. Microscale Techniques for the
Organic Laboratory. New York: John Wiley, 1991. *
— Ethics —
Gunn, Alistair S., and Aarf-e P. Vesilind. Environ-
mental Ethics foe Engineers. Chelsea, Ml: Lewis
Publishers, 1987.' '
-*• Case Examples —
Breen, Joseph J., and Michael J. DeJlarco. Pollution
Prevention in Industrial Processes: The Role of
Process Analytical Chemistry, Washington: Ameri-
can Chemical Society, 1992. *
Dorfman, Mark H.! Warren R: Muir, and Catherine -G.
•Miller. Environmental Dividends: Cutting More
. Chemical Wastes. New York: INFORMI ii392.
. . Available for $75 (plus S3 S/H) from INFORMUnc
• 120 Wall Street, 16th Floor, New York, NY 10005
(phone: 212-361-2400) ..*•
-------
Was-"-•.:•- 3:a:e ''Jr^ersity Scc.a-. ard'Econcr-.ic •
Sc:e.~ces Researcn Center, Ir.ccrcora'jng Pcllut'-cn
P-svsr: :r. C:-n,cec:s .n Higher Education Curricula.
Fi,-;!rr.a-. WA, Washington State University, March
1991.* .'--•.
— Case Examples—
U.S. Environmental Protection Agency,-Office-
•of Research and Development, Risk Reduction
Engineering Laboratory (Springer, Johnny, Jr.).
Pollution Prevention Case Studies Compendium.
(EPA/600/R-92/046). Cincinnati: U.S. EPA; 1992. t
.Journal Articles .
— General Pollution Prevention —
Amato, Ivan. "The Slow Birth of Green Chemistry."
Science 259 (12 March 1993): 1538-1541.* . '
Atcheson, John, and David G. Stephan. The EPA's
Approach to Pollution-Prevention." Chemical Engi<- ,
' neering Progress 85 (June 1989):: 53-58. * . *',
Bakshani, Nandkumar, and David T. Allen. "In the
States: Pollution Prevention Education at Universities
in the United States." Pollution Prevention Review 3,
'• no. 1 (December 1992): 97-105.
Crahford, Bruce. "Federally Sponsored Waste Mini-
mization Research and Development for Hazardous
and Non-Hazardous Wastes." JAPCA 39, no. 1
(January 1989): 34. * ' -
Ember, Lois R. "Strategies for Reducing Pollution
at Source Are Gaining Ground." Chemical and Engi-
neering News 69, no. 27 (8 July 1991): 7-16. * .
Freeman, Harry, Teresa Harten, Johnny Springer,
• Paul Randall, Man/Ann Curran, and Kenneth Stone.
"Industrial Pollution Prevention: A Critical Review."
Air and Waste Management Association 42, no. 5
(1992): 618-656.* , ' • ' .
: Friedlander, Sheldon K. The Implications of Environ-
. mental Issues for Engineering, R&D, and Education."
• Chemical Engineering Progress 85 (November-
1989):-22-28. * " . -.,
:"Hazardous Waste Minimization : A Strategy for ,
Environmental Improvement." UAPCA 38, no. 1
• (January 1988): 59. *
Kirchne.r, Elisabeth, and David Rotman. "Cleaning
: -Up Processes: Taking the Next Step." Chemical
Weefr 150,'no. 23 (17 June 1992): 77. . ,
Oice^Eu'3'. Kirsten'u. and Jcei S. H.irschhcrn.
•The'Obstacles to Waste Reduction." Chemical
Engineering Progress 85 (June 1989): 31-35.,
McMurray, Scott. "Chemical Firms Find That It Pays -
to Reduce Pollution at Source." Wall Street Journal '
(11 June 1991 ):A1.* . , '
Pojasek, Robert B. "For Pollution Prevention:-Be
Descriptive Not Prescriptive.'" Chemical'Engineering
98 (September 1991): 136-139.'
Powers, Mary Buckner, Michael Lawsdn, and
Debra K. Rubin, "industry, Environment Harmonize
Through Pollution Prevention." ENR 224, no. 8
(12 July 1992): 28. '* " . ,
Rittmeyer, Robert, and Paula Cornelia. "Waste Mini- ,
mization/Pollution Prevention." Pollution Engineering
22.no. 4 (April 1990): 71-74. *
Tayer, Ann M. "Pollution Reduction." Chemical &•
Engineering News 70, no. 46 (1992): 22-52. * •
Thorpe, B. "Cutting Chemical Wastes." Process
Engineering 70, no. 4a (March -1989): 10.
• Tibbs, Hardin B. C. "Industrial Ecology: An Environ-
mental Agenda for Industry." Whole Earth Review^ .
77 (December 1992): 4-i9.
— Design (General) —
"EPA-Amoco Test Finds That Costly Rules Focus on
Wrong Part of Plant." Wall Street Journal (29 March
1993).
Berglund, R. L., and C. T. Lawson. "Preventing Pol-
lution in the CPI." Chemical Engineering Progress
98 (September 1991): 120-127. *
Berglund, R. L... and G. L. Snyder. "Minimize Waste
During Design." Hydrocarbon Processing 69 (April .
1990): 39-42. * . - .';.'.
' Hlierhari, Bette. "UN Environment Program Pushes '.
for Cleaner Production." Chemical and Engineering
.News 70, no. 48 (30 November 1992); 17-21. *
Overcash, Michael R'. "Hazardous Waste Reduction-
Measurement of Progress." Hazardous Waste &
'Hazardous Materials^, no. 3 (1988): 251-266.
Pojasek, Robert B.', and Lawrence J. Cali. "Measuring
Pollution Prevention Progress"." Pollution Prevention
Review, Spring (i991): 119-130. /
' 6 • Resource List
October 1995
-------
',',a:s'-E2S£Z -A :s—a: v-es .'- Sc.ve"t Cleaning.
Pa-- - = T s Varna!. The Cleveland Advanced
Mai'-fac'.-rrg P'C-gram, 11 Feoruary 1993. *
— Life Cycle Analysis and Design —
Keoiesan. Greg, and Dan Menerey. Life Cycle Design
Gjidance-Manual: Environmental Requirements and
the Product System. (EPA/600/R-92/226) Cincinnati:
U.S. EPA, Office of Research and Development, Risk
Reduction'Engineering Laboratory, January 1993. * *
• Society cf Environmental Toxicolo'gy and Chemistry
~e
Dang to Reduce'Hazardous Wastes. New YorK:
INFORM, Inc., 1985. Available for $47.50 (plus S3
S/H) from INFORM Inc., 120 Wall Street, 16th Floor.
New York, NY 10005 (phone: 212-361-2400).
3M Environmental Engineering and Pollution
Control Department. Ideas: A Compendium of 3P
Success Stories. 1990. Available by calling 3M at
612-778-4971.* - '.
U.S. Congress, Office of Technology-Assessment.
From Pollution tO'Prevention: A Progress Report on
Waste Reduction. (#PB87208062). Washington:
U,S. Government Printing Office, 1987. $19.50.
Available from National-Technical Informatipn
Service, Springfield., VA. 703-487-4650.
U.S. Environmental Protection Agency. Office of
Pollution Prevention and Toxics. Total Cost Assess-
ment: Accelerating Industrial Pollution Prevention
Through Innovative Project Financial Analysis —
With Applications to the Pulp and Paper Industry.
(EPA/741/R-92/002) Washington: U.S. EPA,
1992.
. Office of Research and Development.
Hazardous Waste Engineering Research Laboratory.
Waste Minimization Opportunity Assessment
Manual. (EPA/625/7-88/003) Cincinnati: U.S. EPA,
1988. $27. Available from National Technical Infor-
mation Service, Springfield, VA. 703-487-4650.
The University of Tennessee Center for Industrial
Services, Waste Reduction Assistance Program.
Was'te Reduction Assessment and Technology
Transfer: Training Manu'ai. Knoxville, TN: University-
of Tennessee, Center for Industrial Services, 1989.
(next revision due Spring 1995) $25. 615-532-8657.
White, Allen L., and Monica Becker. Total-Cost'
Assessment: Revisiting the Economics of Pollution
Prevention Investment. Presented at the Conference
on Pollution Prevention in the Chemical Process
Industries; Washington, D.C., 6 April 1992.
. — Education —
Massachusetts Toxics Use Reduction Program.
Curriculum for Toxics Use Reduction Planners,
Second Edition. Lowell, MA; The Toxics Use Reduc-
tion Institute. University of Massachusetts Lowell,
1991. $40. 508-934-3275. *
Resource List • 5
Oc'.oeer 1995
-------
Ressner. Alar, P., H. Dennis Spnggs, and Howard"J.
Kiee. "Apply Process lntegrati9n to Waste Minimiza-
tion." C^e'rr.ical Engineering Progress 89 (January
1993): 30-36. ••';.... . , .
-Smith, Robin, and Eric Petuia. "Waste Minimization
i"ri the Process Industries, Part I: The Problem.'
Chemical Engineer506 (31 October 1991):'24-25. •
. '. "Waste Minimization in the Process Indus-
tries, Part II: Reactors." Chemical Engineer 509/510
(12 December 1991): 17-23. *
-**-—. "Waste-Minimization in the Process Indus-
tries; Part III: Separation and Recycle Systems."
Chemical Engineer 513(13 February 1992): 24-28. *
. "Waste Minimization in the Process Indus-
tries, Part IV: Process Operations." Chemical Engi-' •
neer517 (9 April 1992): 21-2.3. * . , " •
. "Waste Minimization in the Process Indus-
tries, Part V: Utility Waste." Chemical Engineer 523
(16 July 1992): 32-35. *
3M. Think Prevention for Economic and Ecological •
Benefits." Chemical Marketing Reporter (10 Decem-
ber 1990): 13.
Toy, W. M. "Hazardous Waste Minimization: Part IX
Waste Minimization, in the Automotive Repair Indus-
try." JAPCA38, no. 11 (November") 988): 1422-1428.*:
— Life Cycle Analysis and Design —
Cohan, David, Kenneth R. Wapman, and Mary
McLeam. "Beyond Waste Minimization: Life-Cycle
Cost Management 'for Chemicals and Materials."
Pollution Prevention flewew2
-------
— Process Design —
AP -- , -5,. $~2 Gary J. Po-ve'S, "Risk Reduction
;'~Cce-s:'ra ^'cceaurss a^d Process Flowsheets."
/"Cusrra/ ar~ E~gi~eenr.g Chemistry Research 32,
no. 1 {January 1993): 82-90. *
Benforado. 0. M., G. Ridle Hoover, and M. D. Gores.-
"Pollution Prevention: One Firm's Experience."
Chemical Engineering 98 (September 1991): 130-
133 ^« — see Managerial Strategies)
Capaccio, Robert S., and Lisa F. Wiik. "Application
of Ion-Exchange Technology in Pollution Preven-
tion.' Metal Finishing 90, no. 11 .(November 1,992):
25-28.*
Chadha, NICK, and Charles S. Parmele. "Minimize
Emissions of Air Toxics via Process Changes."
Chemical Engineering Progress 89 (January 1993):
37-42.*
Chi, C. T., and J. C. Morgan. "Minimize Waste With
Carbon Balance." Chemical Engineering Progress
86 (November 1990): 77-79. *
Froecke, T. L. "Hazardous Waste .Minimization:
• Part II, Waste Minimization in the Electronic Prod-
ucts Industry." JAPCA 38, no. 3 (March 1988):
283-291. *
Gibson David. "Waste Minimization: Going to the
Source." Chemical Marketing Reporter (10 Decem-
ber 1990): 10-11. *
Hauserman, W. B. -Thermodynamics of Resource
Recycling." Journal'of Chemical Education 65
(1988): 1045-1047. *
Hollod, G. J., and R. F. McCartney. "Hazardous
Waste Minimization: Part I Waste Reduction in the
Chemical Industry—DuPont's Approach." JAPCA
38, no. 2 (February 1988): 174-179. *
Hunt, G. E. "Hazardous Waste Minimization: Part IV,
Waste Reduction in the Metal Finishing Industry."
JAPCA 38, no. 5 (May 1988): 672-680. *
Hunter, G. U.. and E. A. Kobylinski. "Waste Water."
Chemical Engineering 99, no. 6 (June 1992): 86-88.
Hunter, John S., and David M. Benforado. "Life
Cycle Approach to Effective Waste Minimization.
Hazardous Waste Minimization 37, no. 10 (1987):
' . 1206-1210!* ; . .
Jacobs, Richard A. "Design Your'Pro.cess for Waste
Minimization." Chemical Engineering Progress 86
(June 1991): 55-59. *
Karr.inski. J. A. "Hazardous Waste Minimization: ^
Part VII. Hazardous Waste Minimization Withir trie
Department of Defense." JAPCA 38, no. 8 (August-
1988): 1042-1050. * .
_ _ . "Hazardous Waste Minimization: Part Vllb,
Hazardous Waste Minirmzation Within the Department
of Defense." JAPCA 38, no. 9 (September 1988):
1174-1185.* . ' '
Katin, Robert A. "Minimize Waste at Operating
Plants." Chemical Engineering Progress 86
(July 1991): 39-41. '*
Ki-rchner, Elizabeth and David Rotman. "Cleaning
Up Processes: Taking the Next Step." Chemical
150, 'no. 23(17 June 1992): 77. * .
Krulik, G. A=, and N. V. Mandich. "Substitutions of
Non-Hazardous for Hazardous Process Chemicals
in the Printed Circuit Industry." Metal Finishing 90,
no.' 11' (November 1992).*
Labar, Gregg. "DuPont: Watching Its Waste."
Occupational Hazards (July 1 990) . *
Leeman, J. E. "Hazardous Waste Minimization:
Part V Waste Minimization in the Petroleum Industry."
JAPCA 38, no. 6 (June 1988): 814-822. *
Lewis, D. A. "Hazardous Waste Minimization: Part
VIII Waste Minimization in the Pesticide Industry."
JAPCA 38, no. 10 (October 1988): 1293-1296. *
Lorton, Gregory A. "Hazardous Waste Minimization:
Part III Waste Minimization in. the Paint and Allied
Products Industry." JAPCA3B, no. 4 (April 1988);
422-427.' '
Nelson, Kenneth E. "Reduce Waste, Increase
Profits." Chomtech2D, no. 9 (August 1990): 476. *
_ _ "Use These ideas to Cut Waste.".
Hydrocarbon Processing 69 (March 1990): 93-98. *
Oman, D. E. "Hazardous Waste Minimization:,
Part VI Waste Minimization, in the Foundry Indus-
try." JAPCA 3.8, no/7 (July 1988.): 932-40. * .
Petersen, H. J. Styhr, and Frode Sorensen. "A Process-
Based Method for Substitution of Hazardous Chemicals
and its Application to Metal Degreasing." Hazardous ^
Waste and Hazardous Materials^, no. 1 (1991): 69-83.
Rich Gerald. "Air Toxics: Prevention and Mitigation."
Pollution Engineering 2^, no. 6 (June 1989): 66-89.
-------
Networking/Informational Sources
— Other Resources —
Illinois Department of Energy and Natural Resources
Hazardous Waste Research and Information Center
'One East Hazelwood Drive
Champaign, 1L 61802 ,
217/333-8940 ' • • :
U.S. Environmental Protection Agency
Pollution Prevention Information Clearinghouse
Reference and Referral
401 M Street, SW (3404) '
Washington, DC 20460 . .•'...-.
202/260-1023 ' " • '
Pollution'Prevention Research Branch
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
26 West Martin Luther King.Drive
Cincinnati, OH 452681
513/569-7215
— Organizations —
American Institute for Pollution Prevention
University of Cincinnati
- Cincinnati, OH 45221-0071
513/556-3693 •
Contact:" Thomas Hauser, Exec. Director
. Center for Waste Reduction Technologies
American.Institute of Chemical Engineers
345 East 47th St.
New York, NY 10017 ; ;
212/705-7407
Chemical Manufacturers Association
. 2501 M Street, NW "•
Washington, DC 20037 "-. ,
' 202/887-1100 '
' — CpntriBHlor* to Education
inChMjical Engineering
and Poffiltion Prevention —
David Allen
Department of Chemical Engineering
University of California at Los Angeles.
553T Boeiter Hali .
• 405-HHgard Ave. .
Los Angeles, CA 90024
' - 310/206-0300 . . . •
E-mail: dallen@seas.ucla.edu
Stanie? Barnett.
University of Rhode Island
Chemical Engineering
205 Cawford Hall
Kingston, RI 02881
401/792-2443 ' .
James T. Cobb
Director, Energy Resource Program
.Chemical & Petroleum Engineering Program
University of Pittsburgh
1249 Benedum Hall
Pittsburgh, PA 15261
412/624-9641
Yoram Cohen •
' Department of Chemical Engineering
University-of California at .Los Angeles •
5531 Boeiter Hall
405 Hilgard'Ave. ' ......
Los Angeles, CA 90024 . .
' 213/825-8766 . . •
E-mail: yoram®seas.ucla.edu
Robert M. Counce
• Department of Chemical Engineering
University of Tennessee '
419 Dougherty Building
Knoxvilie.TN 3799^-2200
615/974-5318
E-mail: counce@utkux.utcautk.edu
Dale Denny
North Carolina State .University
8840 Wildwood Links
Raleigh, NC 27613-5412
919/782-8390 ' '
Diane Doriand • ,-.
Department of Chemical Engineering
University of Minnesota
231 Engineering Building
' 10 University Dr.
Duluth,MN 55812 . .
218/726-7-126
E-rnail: ddoriand@ua.d.umn.edu :
Robert M. Snick
' Chemical & Petroleum Engineering Program
' University of Pittsburgh '
1249 Benedum Hall
• Pittsburgh, PA 15261 „ '
412/624-9649
10 • Resource List
OctoBer1995 :
-------
= 'S'.S"'. C" = ';"2"^ " Cremca; £rg:resrrg
3':g-ess 55 Ma/ '391,: 55-52. *
/,- •«. A e~ _.. ar.s Monica BecKer. Total Cost
Assessrr.er:: Catalyzing Corporate Self-interest in
PC..U; on P-evention." New Solutions, Winter (1992):
3-i-39.
— Education —
Baksnam, Nandkumar. and David T. Allen. "In the
States: Pollution Prevention Education at Universities
in the United States." Pollution Prevention Review 3,
no. 1 iDecember. 1992): 97-105.
Corporate Conservation Council, National Wildlife
Federation. Gaining Ground: 'Environmental Education
in Business Schools. Final Report of the Curriculum
Development Project, National Wildlife Federation,
Washington, D.C., June 1992. Available free by
calling 202-797-6878.
Friedlander. Sheldon K. The Implications of Environ--
mental Issues for Engineering, R&D, and Education."
Chemical Engineering Progress 85 (November
1 989): 22-28. (* — see General Pollution Prevention)
Washington State Department of .Ecology, Social and
Economic Sciences Research Center, Washington
State University, and the Waste Reduction Institute
for Training and Applications Research. Incorporat-
ing Pollution Prevention Concepts in Higher Educa-
tion Curricula. 1991. Available for $30 from WRiTAR,
1313 Fitth Street SE, Suite 327, Minneapolis, MN
55414-4502 (phone: 812/379-5995).
Kummler, Ralph H., James H. McMicking, and
Robert W. Powitz. "A Program on Hazardous Waste
Management." Chemical Engineering Education
(September 1989): 222-26. *
Waste Reduction Institute for Training and Applica-
tions Research, and Minnesota Office of Waste
Management Pollution Prevention and Higher
Education Curricula: A Seminar for Post-Secondary
Educators of All Disciplines. University of Minnesota,
St. Paul, 9 December 1991. Available for $30 from
WRITAR. 1313 Fifth Street SE, Suite 327, Minnea-
polis, MN 55414-4502 (phone: 612/379-5995).
— Ethics —
Watters, James'C., and Dominic A. Zoeller. "Devel-
oping a Course in Chemical Engineering Ethics:
One Class1'Experiences." Chemical Engineering
Education (March 1991): 68-72.-
— Case Examples — • .
Drabkfn. M. The Waste Minimization Assessment: A
Useful Tool for the Reduction of Industrial Hazardous
Wastes." JAPCA 38, no. 12 (December 1988):
1530-1541.
Ember, Lois R. "Pollution Prevention at Chemical
Plants Benefits Environment at Low Cost." Chemical
and EngineeringNews7Q, no. 25 (22 June 1992): 18. * ..
Redman, John. "Pollution is Waste." The Chemical
Engineer, no. 461 (June 1989): 16. *
3M Corporation. Think Prevention for Economic and
Ecological Benefits." Chemical Marketing Reporter
'(10 December 1990): 13.
Case Studies
Arthur D. Little. Disposable. Versus Reusable Diapers:
Health, Environmental and Economic Comparisons.
Cambridge, MA: A.D. Little, 1990.- '
The Dow Chemical Company Environmental Quality
.Department. Waste Reduction Always Pays: Case
Study Summaries. Midland, Ml: The Dow Chemical
Company, 1989.
Franklin Associates. Characterization of Municipal
Solid Waste inth'e United States, 1960 to 2000
(Update 1988). Final report. Prairie Village, KS:
Franklin, 1988. Available for $25 from Franklin
Associates at 913-649-2225.
. Resource, and Environmental Profile Analysis
of Foam Polystyrene and Bleached Paperboard
Containers. Final report. Prairie Village, KS: Franklin,
1990. Available by calling the American Plastics
Council Hotline at 800-243-5790.
-. Resource and Environmental Profile Analysis
of Polyethylene and Unbleached Paper Grocery
Sacks. Prairie Village, KS: Franklin, 1990.
Available by calling the American Plastics Council
Hotline at 800-243-5790.
?. Resource and Environmental Profile Analysis
of High-Density Polyethylene and Bleached Paper-
board Gable Milk Containers. Prame Village, KS:
Franklin, 1991. Available by calling the American
Plastics Council" Hotline at 800-243-5790.
van Eijk, J., J. W. Nieuwenhufs, C. W. Post, and J. H.
de'Zeeuw. Reusable Versus Disposable: A Com-
parison of the Environmental Impact of Polystyrene,
Paper/Cardboard and Porcelain Crockery. House of
Ministry, Physical Planning and Environment;
Zoetermeer, The Netherlands, 1992.
Resource List • 9
Octooer 1995
-------
Vas;»cs Mancusiouthakis
Department of Che~ical Engineering',
University of California at Los.Angeles '
5531 Boeiter Hall .
405 Hilgard Ave. - . . ',
Los Angeles, CA 90024
James McMicking
Wayne State University •
Department of Chemical Engineering
Detroit, Ml 48202
313/577-3800 - • ' ' . .
James G. Meenahan
Wayne State University
Department of Chemical Engineering
8483 Goiflane Dr.
Commerce Township, Ml 48382
810/352-9080
Anil Menawat
Tuiane University •
Department of Chemical Engineering
New Orleans, LA 70118, -
504/865-5772 ,
Susan M. Montgomery
College of Engineering
3030 Dow Connector
University of Michigan .
Ann Arbor, Ml 48109-2136
313/936-1890
James Noble
Department of Chemical Engineering
Tufts University
4 Colby St. , -
Medford, MA 02155
.617/628-5000x2089
Michael Overcash
• Pollution Prevention Research Center
North Carolina Sta*t£**ersity
' Raleigh, NC 276 JJ fill*
919/515-2325
John W. Pados
P rofessor, Chemical Engineering
University of Tennessee
419 Dougherty Engineering Building
Knoxville.TN 37996-2200
615/974-6053
Robert- B. Pojasek"
Tufts University ,
c/o GEi Consultants
1021 Main Street
Winchester, MA 01890
617/721-4097
Vito Punzi. '
Department of Che'mical Engineering .
ViHahova University
800 Lancaster Ave.
Villanova, PA 19085
610/519-4946
Joseph Reynolds
Department of Chemical Engineering
Manhattan College
Bronx, NY 1047V
' 718/920-0187 • ,:
Ronald W.'Rousseaut
Director, Designing Tomorrow Today
Georgia Institute of-Technology '
School of Chemical Engineering
Atlanta, GA 30332-0100 -
404/894-2867
Christian Roy
, Department of Chemical Engineering
Universite Laval
Ste-Foy, P. Quebec, CANADA G1K 7P4
418/656-7406
E-mail: croy@gch.ulava!.ca
Dale F. Rudd
Department of Chemical Engineering
University of Wisconsin
Engineering Hall f 3006
1415 Johnson Drive
Madison, Wl 53706
608/262-1520
Henry Shaw
Department of Chemical Engineering
New Jersey Institute of Technology
University Heights
, 138 Warren Street
Newark, NJ 07102
201/596-2938 , .
E-mail: shaw@admin.njit.edu
12* Resource List
Octoeer 1995
-------
Ka-s=5 State -" '.e-s :y
Va—a::a.-:
-------
Original produced on Hammermill Unity DP,
a 50% post-consumer/50% pre-consumer recycled paper
made from de-inked old newspapers and magazines.
The National Pollution Prevention Center
for Higher Education
University of Michigan, Dana Building
430 East University Ave. . • , • .
Ann Arbor. Ml 48109-1115
.Phone:313-764-1412 v ' •
.Fax:313-936-2195 ' ,
«E-mail: nppc®umich.edu
-The mission of the; NPPC is to promote sustainable development
by educating students, faculty, and professionals about pollution
prevention; create educational .materials: provide tools and
strategies for addressing relevant environmental problems; and
establish a national network' of pollution prevention educators.
in addition to developing educational materialsand conducting
• research, the NPPC also offers an internship program, profes- .
sional-education,and training, and conferences.
Your Input is Welcome!
We are very interested in your feedback on these matenais. .
Please take a moment to offer your comments and communicate
them to us. Also contact us if you wish to receive a documents
list order, any of our materials, collaborate on or review NPPC
resources, or be listed in our Directory of Pollution Prevention
in Higher Education. • '
We're Going Online!
The NPPC provides information on its programs and educational
materials through the Internet's Worldwide Web; our URL is:
http://www.snre.umich.edu/nppey • .
' Please contact us it you have comments about our online
• resources or suggestions for publicizing our educational
materials through the Internet. Thank you!
14«Resource List
. Octooer 1995
-------
33". S"":~"uS5
C"s~~ ;a r°j'."sS'
vVa,-2 S:a:e Ur.vers/.y
5G5C A-;-c-y Wayne Cr:vs
Detroit. Ml -i3202
313.577-3771
D,l!p S.ngh
Department of Chemical Engineering
Youngstcwn State University
Youngs;:*vn, OH 44555
, 216,742-1737
Louts Theodore
Department of Chemical Engineering
Manhattan College
Bronx, NY 10471 .'
'718/920-0185
Lew f. Thompson Jr.
Chemical Engineering Department .
University of Michigan
3026 H. H. Dow Bldg.
Ann Arbor, Ml 48109-1115 -
313/936-2015
Dean Ulrichson
Department of Chemical Engineering
Iowa State University
Sweeney Hall
Ames, IA 50011
515/294-6944
E-mail: dlulrich@iastate.edu
Margrit von Braun
Department of Chemical Engineering/
Environmental Science Program
University of Idaho
Buchanan Enginneri.ng Lab 315
Moscow, ID 83844-1025
208/885-6113 .
E-mail: cdixonQcrow.csrv.uidaho.edu
jcr.r '//. Walkinshaw
Oect. of Chemical, Nuclear Engineering •
University of Massachusetts Loweil
One University Ave. - . '
Lowell, MA 0.1854
508/934-3171
James C. Walters
Department of Chemical Engineering
University of Louisville
Louisville, KY 40292
Bob Weber
Department of Chemical Engineering
Yale University
New Haven, CT- 60520
203/432-4376
Gerald B. Weste-rmann-Clark
Department of Chemical Engineering
University of Florida
300 Weil Hail
• Gainesville, FL'32611-2083 •
904/392-6000
Gregory Yawson
Chemical and Metallurgical Engineering
Wayne State University
Detroit, Ml 48202
313/577-3848 '
Resource Lst1 :3
OctoCar '995
-------
: r-Pa": s'3C.:ces'cr-jcc 3eiatea"Health •• -
Hazards Control'Voi. // - Engineering Aspects.
New Y«rx: John Wiley & Sons. 1989.
Deals specifically with cost-effectiveness of a health
hazard control program and how. to initiate such
programs .in an industrial setting. The authors discuss
the basic engineering concepts and unit operation
controls that constitute the foundation of a cost-.
effective program. Extensive use of charts and tables
reinforces key issues presented in the various chapters.
Sixteen chapters deal with a variety of. specific unit
operations; eleven chapters deal with basic concepts.
Higgins, Thomas. Hazardous Waste Minimization
Handbook. Chelsea, Ml: Lewis Publishers, 1989.
Includes two chapters on pollution prevention in
chemical engineering. The first discusses why ar com-
pany would initiate a waste minimization program,.
then addresses economics and methods. The second
outlines procedures, for successfully implementing
such a program. Specific processes discussed include: .'
machining/metalworking operations, solvent cleaning'
and degreasing, metal plating/surface .finishing, print-
ing and coating, and removal of paint and coatings.
Overcash, Michael R. Techniques for Industrial.
Pollution Prevention: A Compendium for Hazardous
and Non-Hazardous Waste Minimization. Chelsea,
Ml: Lewis Publishers, 1986.
An introduction,to waste minimization technology, its
relationship to waste management, and the implemen-
tation of programs and procedures. Also included is a
section from Clean Technologies of French,Industry, a
French document that provides case studies in the
industrial' fields of agriculture and food, construction,
materials, chemical manufacturing metallurgy, surface
treatment, textiles, tanneries, and wood products.
Sawyer, Donald T., and Arthur £. Martell. Industrial •
Environmental Chemistry: Waste Minimization in
Industrial Processes and Remediation of Hazardous
Waste. New York: Plenum Press, 1992.
Discusses how pollution prevention can be Implemented
in a process by evaluating the following equipment:
raw materials, reactors, heat exchangers, pumps,
furnaces, distillation columns, piping, and process
control. The role of catalysts in yields and reaction •
characteristics is related to pollution prevention. Also
discussed are ion exchange and membrane-based
separation processes. •
'. Tavfandes. Lawrence L. Process McGidcations for
Industrial Pollution Source Reduction. Chelsea. Ml:
Lewis Publishers, 1985.
Details potential changes, in manufacturing processes
to achieve source reduction. Eight industries are
evaluated: non-ferrous metals refining, electroplating,
coal conversion, specialty chemicals, iron and steel,
paper and pulp, primary aluminum, and phosphate
fertilizer. Discusses problems and solutions'. • • ' .
U.S. EPA and-ICF Consulting Associates, Inc.
Solvent Waste Reduction. Park Ridge, NJ: Noyes
Data Corporation, 1990. .
Discusses solvents and their use in industry along
with alternatives currently available. Waste reduction,
closed-loop recycling, separation techniques for solvent
recovery,-and on-site reuse and recycling are covered.
Health and Safety
Asfah.l, C. Ray. Industrial Safety and Health Mana'ge-
menf. Englewood Cliffs, NJ: Prentice Hall, 1990.
Discusses industrial health and safety issues. Includes
chapter summaries, visual information, and exercises
and questions. Topics'include: hazard avoidance, •
information systems for hazard communication,
issues surrounding buildings and facilities, health
and environmental control, hazardous material, fire
protection, and materials handling and storage.
Colvin, Raymond J. The Guide to Successful Safety •
Programming. Chelsea, Ml: Lewis Publishers, 1992.
Outlines steps in initiating a'successful safety program
and maintaining this success by preventing industrial •
accidents. The book opens with a discussion of the
fundamental steps that promote a successful safety
program, then discusses management's role in program
support, organization, and accident investigation •
procedures. The employees' role is then discussed in
relation to hazard identification, inspection, equipment,
practice, and planning. Concludes by addressing in-
house resources such as plant evaluations, written
safety policies, and safety checklists.
Crawl, Daniel A., and Joseph F. Louvar. Chemical
Process Safety: Fundamentals With Applications.
Englewood Cliffs, NJ: Prentice Hall, 1990.
Chapters include the following: introduction to health
and safety, toxicology, industrial hygiene, toxic release
Annotated Bibliography • 2
Oaoo«M994
-------
-' i ~ -'-,--• ; r a--1
C~-=- := Erg,ra€r:rg
Annotated Bibliography of
Chemical Engineering-Related
Pollution Prevention Sources
Prepared by Jason Wright • .
under the direction of Gregory A. Keoleian, Ph.D., Assistant .Research Scientist.
School of Natural Resources and Environment, University of Michigan
Books
General Pollution Prevention
Forester, William S., and John H. Skinner. Waste
Minimization and Clean Technology: Waste Manage-
ment Strategies for the Future. San Diego: Academic
Press, 1992.
Presents recent examples of industry efforts to promote
a cleaner environment. Lists specific examples and
international programs which include: low waste
technologies; economic aspects of waste minimization;
implementation of technology; legislation; programs in
China, Cuba, and France; research and development;
the U.S. EPA's pollution prevention program; and the
role of product design in waste minimization. Indus-
tries discussed include electroplating, pulp and paper,
chemical, oil and petroleum, and pharmaceutical.
Freeman, Harry M. Hazardous Waste Minimization. .
New York: McGraw-Hill, 1990.
Topics include: waste minimization in industry '—
economics, implementing programs, research and
development, and the importance of business planning;
waste minimization in the public sector — state and
local accomplishments and several cases involving
public waste minimization programs; and case studies
examples from General Dynamics, the Department of
Defense, the petroleum refinery industry, and others.'
Theodore, Louis, and Young C. McGuinn. Pollution
•Prevention. New York: Van Nostrand Reinhold, 1992.
From the introduction: "This is the only book dealing
with the technical and engineering aspects of pollution .
prevention that may be used as a text. This text-
reference book is intended primarily, for regulatory
personnel, practicing engineers and engineering/
science students and contains engineering methods
for source reduction and'the technical aspects-of PP in
general." The book is divided into four parts: process
and plant fundamentals, pollution prevention options,
pollution prevention applications, and case studies.
Also includes some discussion of industrial recycling
and treatment-methods.
Process Design
Breen, Joseph J., and Michael J. Dellarco. Pollution
Prevention in Industrial Processes: The Role of
Process Analytical Chemistry. Washington: American
Chemical Society, 1992.
A compilation of various papers from the 1992 ACS
symposium series. The first chapter discusses pollution
prevention as it applies to ethics, industrial approaches,
right-to-know legislation, and process analytical chemis-
try. The remaining sections present papers on pollution
prevention practices in specific chemical processes.
Cralley, Lester V., and Lewis J. Cralley. In-Plant
Practices for Job Related Health Hazards Control'
Vol. I - Production Processes. New York: John Wiley
& Sons, 1989.
Written by certified professionals with hands-on
experience in' industrial hygiene. Topics discussed
vary in detail from handling of specific chemicals to
production processes for an entire industry. Subjects'
include prevention, planning, equipment, and training.
National Pollution Prevention Center (or Higner Education • University of Micrtigan
Dana Building. 43O East University. Ann Amor Ml 43109-1115
Ptione- 313.764,1412 • Fax: 313.936.2195 • E-mail: nppc®umicn.«du
May Be reproduced
freely for non-commercial
educational purposes.
Annotated Bibliography • 1
October 1994
-------
Design (General)
U.S. Congress. Office of Technology Assessment. •
From Pollution to Prevention: A Progress Report on
Waste Reduction, .Washington:-U.S. Government
Printing Office, 1987.
' 'Defines waste reduction and how it applies to the
following government programs: the Hazardous and
Solid Waste Amendments (HSWA), the Comprehensive
Emergency Response, Compensation and Liability Act.
(CERCLA), and the Toxic Substances Control Act (TSCA).
The EPA's commitment to Dilution prevention is also
discussed. Topics include: how waste reduction .
• relates to competition; incentives and disincentives vs.
enhancements and obstacles; and a critical-review of
the OTA report, Serious Reduction of Hazardous Waste,
and the. corresponding EPA report. > ,
Process Design
Water-Based Alternatives to Solvent Cleaning,
Participant's Manual. Cleveland Advanced Manu-
facturing Program, 11 February 1993.
Includes presentations and supporting material from a
'teleconference that was downlinked to eight commu-
nity colleges throughout Michigan..
Life Cycle Design (LCD) and
Life Cycle Analysis (LCA)
Keoleian, Gregory A., and Dan Menerey. Life
Cycle Design Guidance Manual: Environmental
Requirements and the Product System, Cincinnati: -
U.S. EPA, Risk Reduction Engineering Laboratory .
(EPA/600/R-92/226), 1993. -
Provides a framework for incorporating environmental
requirements into product system design. Emphasizes
that all four components of a product system (product,
process, distribution, and management/information)
should be integrated in design and suggests that, when-
ever possible, design activities should encompass all
life cycle stages from raw material acquisition through
processing, manufacturing^ use/service, resource re-
covery, and disposal of all residuals. Matrices are
provided for developing and evaluating life cycle envi-
ronmental requirements, then coordinating these with
performance, cost, legal, and cultural requirements.
Strategies for reducing product systems' environmental
impacts are listed and discussed. Introduces life cycle
assessment fboth Inventory and impact analysis) as a
possible evaluation tool in design while also suggesting
alternative or more streamlined methods.
Society of Environmental Toxicology and Chemistry,
A Technical Framework for Life-Cycle Assessment.
SETAC Workshop, Smugglers Notch, VT, 18 August
1990. Pensacbla, FL: Society of Environmental
Toxicologists and Chemists Foundation for Environ-
mental Education, 1991.
.Detailed overview of the SETAC version of LCA,
which includes impact assessment and improvement
analysis, along with inventory analysis. Presented as
possible international consensus for future LCAs. An
international view of issues involved in LCA, not as
detailed regarding inventory analysis as EPA version.
. Guidelines for Life-Cycle Assessment:,A Code
of. Practice.. SETAC Workshop, Sesimbra, Portugal,
3 March 1993. Pensacola, FL: Society of EnvirorV.
mental Toxicology and Chemistry;-1993..
A briefer overview document updating current work
on standardizing LCA. Preserves three-part LCA
framework (inventory, impact, and improvement
.analysis) while addressing data quality, applications
and limitations, and future research needs. ;
Vigon, B. W., D. A. Tolle, B. W. Comary, H. C, Latham,
C. L. Harrison, T. L Boguski, R. G. Hunt, and J. D.
Sellers. Life Cycle Assessment: Inventory Guidelines
and Principles. Cincinnati: U.S.EPA, Risk Reduction
Engineering Laboratory (EPA 600/R-92/036), 1993.
Defines the inventory analysis procedure in life cycle
assessment; contains detailed guidelines for conducting
a life cycle inventory. Discusses system boundaries
and allocation between two systems. Suggests use of
flow diagrams and other tools for gathering inventory
and mentions applications and limitations. Compre-
hensive coverage of .inventory assessment in LCA.
Managerial Strategies
3M Environmental Engineering and Pollution Control
Department. Ideas: A Compendium of 3P Success
Stories. St. Paul: 3M, 1990:
Includes a general description of this program, how it
works, and who is involved. Discusses future plans
for the program and what 3M hopes to achieve.
Annotated Bibliograpny • 4
October 1994
-------
and dispersion models, tires'and explosions, designs
to «revent fires and explosions, introduction to reliefs
ard relief sizing, hazard identification, risk assessment,
accident ..-.vestigatioris, and case histories. The book
includes many visual aids (tables, charts, and graphs)
and examples'. Each chapter contains a suggested
reading list and a set of homework problems.
Kavianian, H. R., and C. A. Wentz, Jr. Occupational
and Environmental Safety Engineering and Manage-
ment. New York: Van Nostrand Reinhold, 1990.
From the preface: "Our primary purpose in writing
this book was to bring together all legal, engineering,
and scientific aspects of safety in a single, integrated
treatment. This textbook has been-written for students
at the college level in engineering and science.". The
book includes a series of exercises and questions at
the end of each chapter along with chapter summaries
and extensive visual information. Appendices include:
a list of extremely hazardous substances and their .
threshold planning quantities, known carcinogens,
and suspected carcinogens.
Mayo, Dana W.. Ronald M. Pike, Samuel S. Butcher,
and Peter K. Trumper. Microscale Techniques for the
'Organic Laboratory. New York: John Wiley & Sons,
Inc.. 1991.
Presents microscale techniques and procedures for
students (beginners or advanced). Sections include:
safety, introduction to microscale techniques and
equipment, determination of physical properties,
development of microscale techniques, introduction
to infrared spectroscopy, and introduction to nuclear
magnetic resonance spectroscopy. .
Ethics
Gunn, Alistair S., and Aame P. Vesilind. Environ-
mental Ethics for Engineers. Chelsea, Ml: Lewis
Publishers, 1987.
From the preface: "The purpose of the'first section
of this book is merely to enhance the knowledge of
professional and environmental ethics so that this
information may be used to obtain a fuller understand-
ing of the various articles which comprise the second
section. "The second section introduces significant
issues in the development of environmental ethics
and others dealing with controversial issues and
•professional approaches to ethics." .
Case Examples
Dorfman, Mark H., Warren R.'Muir, and Catherine G.
Miller. Environmental Dividends: Cutting More , •
Chemical Wastes. New York: INFORM, Inc., 1992.
Profile of pollution prevention case examples from 29
organic chemical facilities in California, New Jersey, .
and Ohio, following up the original 1985 study entitled
Cutting Chemical Wastes. Pollution prevention data for
all participants are summarized and presented in tables.
Reports
General Pollution Prevention
Chemical Manufacturers Association. Pollution '
Prevention Resource Manual. Washington: CMA,
1991. • •
Includes general information on initiating corporate
pollution prevention programs, then discusses: securing
managerial and organizational commitment; tracking
and measuring progress; evaluating impacts; setting
priorities, plans, and goals; analyzing processes .for
possible reductions; and developing alternatives and
implementation techniques. Includes prevention objec-
tives in research, facility design, processes, and products.
Waste Reduction: A Cooperative Search for Solu:
tions, Volume I: Conference Summary. The Center
for Environmental Management, Tufts University,
National Academy of Sciences Conference Center,
Woods Hole, MA, 15 June 1988. Medford, MA: GEM,
Tufts University, 1988.
Transcriptions of 19 waste reduction talks from EPA
officials, Canadian and provincial officials, industry
representatives, academic and non-profit groups, and.
others. Noteworthy is a talk (pp. 100-105) "by former
U.S. Representative Howard Wolpe, who was instru-
mental in passing the Pollution Prevention Act of 1990.
' Includes discussion group summaries on effective
technical assistance programs, and why and how to
measure waste reduction progress, along with an
appendix describing the Polaroid Toxic Use and Waste
Reduction Program.
Octooar 1994
-------
cuay. Sc=r..'--Cren.cal Firms Find That It Pays
to Reduce Pollution at Source.' Wall Street Journal
(11 Jure 1991'): A1. A6, ' -. . •
Discusse- the cherrucai industry's newfound enthusiasm
• for pollution prevention as a means to achieve indus-
trial efficiency and cut costs. Includes a brief historical
explanation and a number of short pollution prevention
case studies from major chemical companies.
Powers, Mary Buckner, Michael Lawson, and
Debra Kv Rubin. "Industry, Environment,Harmonize
Through -Pollution Prevention." ENR 224, no. 8
(12 July 1992): 28. , '
General article on pollution.prevention and how com- .
. panies are answering the call to be more responsible.
Discusses some chemical process modifications and
their positive effects, the importance of the Toxic Re- .
lease Inventory, new.legislation encouraging pollution
prevention in industrial practice, and the paper and
pulp industry's interest in recycling. Tables cover the
worst polluters and their releases plus many, companies
' with successful programs.
Rittmeyer, Robert, and Paula Cornelia. "Waste Mini*
mization/Pollution Prevention." Pollution Engineering
22. no. 4 (April 1990): 71-74.
Discusses the EP A's waste minimization priority hier-
archy in detail. Contrasts end-of-pipe technology with
prevention technology and states why the-two are
different yet both important. Obstacles to waste mini-
mization are discussed and some solutions presented.
Taver Ann M. "Pollution Reduction.* Chemical &
Engineering News 70, no. 46 (1992): 22-52.
Defines pollution prevention and states the importance
of the Toxics Release Inventory and'"33-50 " waste
reduction program. Topics also include life cycle
analysis and how to implement waste minimization.
General Design
plant configuration and information ana controls rr.av
irruring material use and safely monitoring processes,
AlscVdiscusses the importance of human.resources. •
research and development, and organization.
Berglund, R. L, and G. L. Snyder. "Minimize Waste
During Design." Hydrocarbon Processing 69 (April
1990): 39-42. ..
Identifies areas where waste minimization can be
applied, from the conception of a new process until the
unit begins production. Discusses the development or
a comprehensive mass balance for processes and a .
formal review of waste minimization opportunities;
General waste minimization possibilities are.then
' addressed and a specific case example included.
Hileman, Bette. "UN Environment Program Pushes
for Cleaner Production." Chemical and Engineering .
•News70, no. 48 (30 November 1992): 17-21.
Coverage of the United'Nations Environmental Pro-
gram (UNEP), which sponsors international conferences
on cleaner production. Describes programs in the ,
Netherlands, Poland, and China that foster the spread
"of cleaner production techniques. Mentions obstacles,
especially in less-developed countries.
Process Design '
Aelion, Vital, and Gary J. Powers. "Risk Reduction
of Operating Procedures and Process Flowsheets.,
" Industrial and Engineering Chemistry Research 32,
no. 1 (January 1993): 82-90.
Discusses use of fault tree analysis as a risk reduction
strategy. Proposes modifications in cherrucai operations
using process flowsheets and control system and opera-
!tion procedures. Discusses the importance of identifying
dominant causes of risk and then pursuing modification
to produce safer and more reliable processes. Illustrates
this strategy with an example of a pump system start-
up design and discusses the subsequent risk reduction
achieved.
Berqlund, R. L., and C. T. Lawson. "Preventing
Pollution in the CP\" .Chemical Engineering Progress
98 (September 1991): 120-127.
Discusses product design as it relates to pollution pre-
venhon, then introduces process design is in the context
of evaluating waste stream rates. Explores the role of.
Capaccio, Robert S., and Lisa F. Wilk. "Application of
Ion Exchange Technology in Pollution Prevention...
, Metal Finishing^, no. 11 (November 1992): 25-28.
Discusses how ion exchange works and the relevance
of "ion exchange technology to pollution prevention.
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Education
Massachusetts Toxics Use Reduction Program. Cur-
rcuiu/n far Toxics Use Reduction Planners, Second
'Edition Lowell. MA: The Toxics Use Reduction insti-
tute. University of Massachusetts Lowell, 1991.
Curriculum for training Toxics Use Reduction Planners,
as mandated by Massachusetts' 1989 Toxics Use Reduc-
tion Act From the introduction: "Designed to encourage
participants to re-examine conventional approaches to
production management and environmental protection.
The targeted audience are technically experienced
professionals and production managers/'
Washington State University Social and Economic
Sciences Research Center. Incorporating Pollution
Prevention Concepts in Higher Education Curricula. •
Pullman, WA: Washington State University, March
1991. • '
Collection of syllabi, problem sets, and other resources
compiled originally by the Waste Reduction Institute
for Training and Applications Research (WRTTAR) for
the State of Washington. Also includes results from
interviews with professors and descriptions of higher
education programs.
Journal Articles
General Pollution Prevention
Amato, Ivan. The Slow Birth of Green Chemistry."
Science 259 (12 March 1993): 1538-1541.'
Describes how academic attitudes regarding environ-
mental chemistry have changed from disregard to
increased enthusiasm. This interest in environmental
chemistry follows the shift in focus from pollution
control — not'particularly interesting to most academic
chemists — to pollution prevention, which has greater
possibilities for academic discovery.
Atcheson, John, and David G. Stephan. The
EPA's Approach to Pollution- Prevention." Chemical
Engineering ProgessQS (June 1989): 53-58.
Discusses the EPA's role in pollution prevention and
'what it is trying to do to encourage it as a permanent
strategy in industry and business. Introduces the EPA
hierarchy of waste minimization options: source re-
duction, recycling, treatment, and disposal. The goal •
of this hierarchy is to reduce all emissions, not just
those classifed as hazardous.
Cranford. Bruce. "Federally Sponsored Waste Mini-
mization Research and Development for Hazardous
and Non-Hazardous Wastes." JAPCA 39, No; 1
(January 1989): 34.
Describes 17 organizations within the federal govern-
ment that support research and development applicable
to waste minimization.
Ember, Lois R. "Strategies for Reducing Pollution
at Source Are Gaining Ground." Chemical and
Engineering News 69, no. 27 (8 July 1991): 7-16.
Discusses the importance of pollution prevention in
industry. Introduces the hierarchy of pollution prevention
and some key practices for successful implementation.
Freeman, Harry, Teresa Harten, Johnny Springer,
Paul Randall, Mary Ann Curran, and Kenneth Stone.
"Industrial Pollution Prevention: A Critical Review.".
Air and Waste (journal of the Air and Waste Manage-
ment Association) 42, no. 5 (1992): 618-656.
Review article of industrial pollution prevention with
many citations. Emphasizes that pollution must be
prevented closer to its point'of origin to avoid transfer
between media. Included are descriptions of the fol-
lowing pollution prevention programs and acts: Clean
Air Act; Pollution Prevention Act; U.S. EPA's pollution
prevention strategy; various industrial programs; and
various local, state, and federal programs. Other topics
include cost-effectiveness, incentives, and barriers to pol-
lution prevention, as well as the importance of product
design and life cycle analysis in pollution prevention.
, Friedlander, Sheldon K. The Implications of .
Environmental Issues for Engineering, R&D, and
Education." Chemical Engineering Progress 85 ' •
(November 1989): 22-28.
Addresses process economics and its importance in
evaluating costs for chronic emissions, waste disposal,
and process safety. Discusses life cycle analysis, the
design of environmentally compatible consumer prod-
ucts, and the importance of research and engineering •
education in pollution prevention.
"Hazardous Waste Minimization: A Strategy for
Environmental Improvement." JAPCA 38, no. 1
(January 1988): 59. • " • '
This article introduces the topic of waste minimization
and JAPCA's plans for a year-long series of articles on
the subject.
Annotated BiWiograpdy • 5
Octooer 1994
-------
•<-aj:a-::~-s Waste Minimization:,Pan Vllb.
^azarccus Waste Minimization Within,the Depart-.
men; cf Oe'en.se : j-APC-4 38. no. 9 (September.
1988), 117A-1185. - ,. - ,
Discusses hazardous waste minimization .techniques for
abrasive blast* media-, the minimization of shipboard
mercury wastes, and in-house solvent reclamation." •
Katin. Robert A. "Minimize Waste at Operating
Plants." Chemical Engineering Progress 86 (July .;
1991): 39-41.. • ' • .'
Outlines the following waste minimization and
management methods: inventory management, raw
material substitution, process design and operation,
volume reduction, recycling, and chemical-alteration.
' Kirchne'r. Elisabeth, and David Rotman. "Cleaning . .
Up Processes: Taking the Next Step." Chemical
' Week 150, no. 23 (17 June 1992): 77.
Introduces the tasks involved in discovering new
technology that will enable industries to achieve.
cleaner processes.
Krulik G. A., and N. V. Mandich. "Substitutions of
Non-Hazardous for. Hazardous Process Chemicals
in the Printed Circuit Industry." Metal Finishing 90,
no. 11 (November 1992): 49-51.
Discusses the use of sulfuric acid, chromic acid, and .
alkaline permanganate and their advantages and dis-
advantages in the printed circuit industry. This article
presents several options for chemical substitution
; through a specific example.
Leeman, J. E. "Hazardous Wast® Minimization:
Part V Waste Minimization in the Petroleum Indus-
try." JAPCA 38. no, 6 (June 1988): 814-822.
. Describes the petroleum industry and the types of
waste'it generates. Due to the nature of the product,
waste minimization techniques in the industry focus
on recycling/reuse. Several successful waste minimi-
zation projects are presented.
Lewis D.A "Hazardous Waste Minimization: ^
VIII Waste Minimization in the Pesticide Industry.
JAPCA38.nq.-10 (October 1988):. 1293-1296.
'Discusses current technology for waste minimization
in this industry and outlines technology on the horizon.
Lorton. Gregory'A. 'Hazardous Waste
Part; III Waste Minimization in the Paint and Allied
^'Products Industry." JAPCA 38, no. 4 (April 1988):
422-427. -.
Discusses different processes and identifies the waste
they generate. The article addresses the following
issues: minimizing equipment cleaning wastes, reduc-
ing cleaning wastes at the source, recycling or reusing
cleaning wastes, substituting cleaning materials, mini'
' mizing packaging wastes, and reducing air emissions. • -
Nelson, Kenneth E. "Reduce Waste', Increase
.' Profits.". Chemtech 20, no. 9 (August 1990): 476.
By taking an inventory at each step in a process, waste .
creation can be identified and modifications imple-
mented that lead" to a reduction or elimination of that
waste. Includes diagrams. , .
. -Use These' Ideas to Cut Waste." Hydrocarbon
Processing 69 (March 1990): 93-98. ;
' Provides a definition of waste, then discusses practical
ideas for reducing waste in the following areas: raw
materials, reactors, heat exchangers, distillation columns,
piping, process control, pumps, and furnaces.
- Oman, D.-E,"Hazardous Waste Minimization:
Part VI, .Waste Minimization in the Foundry Industry."
JAPCA 38, no. 7 (July 1988): 932-940, ..
Introduces the foundry industry and the common types
of waste it generates. Waste minimization techniques
that have proven useful in this industry are material
substitution and In-loop recycling. Two specific cases
of waste minimization techniques are discussed.
Petersen, H. J. Styhr, and Frode Sorensen. "A
Process^Based Method for Substitution of Hazardous.
Chemicals and its Application to Metal Degreasmg."
Hazardous Wast* and Hazardous Materials 8, no. 1
(1991): 69-83. -
Although this article addresses the specific topic of
metal degreasing, it provides a general overview of.
' chemical substitution and risk assessment/analysis.
Steps involved in the method discussed are: listing the
chemical products, obtaining information on composi- .
tion, developing data sheets, describing the process
involved, assessing the risk, and providing possibilities
for substitution.
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;-a2"a, Ncx. arc Zfa~es S. Farneie. -Mir-rrize
ETISS.C-S c; A.r 7;xics via Process Changes."
C*er",ca Engineering Progress 89 (January 1993):
37-42 • '
Discusses how emissions and their paths of release
are identified, Once an inventory is established, modi-
fications can then be introduced in the form of changes
in process chemistry design and operation. Also exam-
ined-are incentives that encourage the reduction of
toxic emissions.
Chi, C. T., and J. C. Morgan. "Minimize Waste With
Carbon Balance." Chemical Engineering Progress 86
(November 1990): 77-79.
Discusses importance of carbon balance in accounting
for losses and improving material efficiency; includes a
step-by-step example illustrating the usefulness of this
strategy,
Froecke, T. L. ''Hazardous Waste Minimization:
Part II, Waste Minimization in the Electronic Products
Industry." JAPCA 38, no. 3 (March 1988): 283-291.
Discusses production processes used in the industry,
including diagramming and its importance. The article
subdivides waste minimization into the following
areas and then addresses each: process housekeeping,
on-site reuse/recycle, volume reduction/toxics recycle,
procedure and equipment modifications, and material
substitutions.
Gibson, David. "Waste Minimization: Going to the
Source." Chemical Marketing Reporter (10 December
1990): 10-11. ' . • ,
A quick introduction-to full cost accounting and its ap-
plication to a successful pollution prevention program.
Mentions the following areas of pollution prevention:
process modifications, packaging and recycling as it
relates to.the product, and life cycle analysis.
Hauserman. W. B. Thermodynamics of Resource
Recycling." Journal of Chemical Education 65 (1988):
1045-1047. "
Evaluates the economic efficiency of a closed resource
cycle. Uses elementary definitions of overall .thermal
efficiency as a basis for economic analysis. Includes
value-entropy aluminum cycle. .
Hoiiod. G. J.. and R. F. McCartney! "Hazarsc^s
Waste Minimization: Part I, Waste Reduction ,n re.
Chemical Industry — DuPont's Aoproacn.." JAPCA
38, no. 2 (February 1988): 174-179.
Topics include targeting and tracking of wastes, the im-
portance of chemical engineering in waste minimization.
recycling (closed-loop), and process optimization.
Hunt, G. E. "Hazardous Waste Minimization: Part IV
Waste Reduction in the Metal Finishing Industry."
JAPCA 38, no. 5 (May 1988): 672-680.
Discusses production processes in this industry and
identifies common waste streams. Also presents com-
mon waste minimization techniques and an effective
management program. Recovery systems for solvents
are discussed and several mini-case studies presented.
Hunter, John's.,.and David M. Benforado. "Life Cycle
Approach to Effective Waste Minimization." Hazardous
Waste Minimization 37, no. 10 (1987):, 1206-1210.
Dicusses pollution prevention at the source through
product reformulation, process modification, and
equipment redesign; also covers on-site and off-site
reclamation and recycling.
Jacobs, Richard A. "Design Your Process for Waste
Minimization." Chemical Engineering Progress 86
(June 1991): 55-59.
Discusses the importance of process design in pollution
prevention: during product conception, designers can
identify wastes that will be produced. The article in-
troduces the role of laboratory research and process
conditions for optimum production; it then discusses
process development and mechanical design as they
apply to scale, from pilot plant to fully operational plant.
Kaminski, J. A. "Hazardous Waste Minimization:
Part VII, Hazardous Waste Minimization Within the
Department of Defense." JAPCA 38, no. 8 (August
1988): 1042-1050.
Discusses hazardous waste minimization techniques in
two specific areas: plating and'painting line modifica-
tions for large vehicle repair, and hazardous waste
minimization in explosives manufacturing.
Annoiawa Bibliograpny • ^
October 1994
-------
:or,viuc: an erncient LCA. is k too iate in the process
tor LCA results.to affect the final product Reviews
variety of LCA methods from U.S. and other countries.
Keoleis--. Gregory A. and Dan Meneney. "Sustain-
able Development by Design: Review of .Lite Cycle
Design and Related Approaches." Air & Waste 44
(May 1994): 545-668. , .
"This review presents the life cycle design framework
developed for the U.S. Environmental-Protection
Agency as a structure for dicussing the environmental
design-literature .... [The article includes] various
methods for specifying requirements, strategies for
reducing environmental burden, and environmental
evaluation tools are explored and critiqued."
Managerial Strategies
Benforado, D. M., G. Ridle Hoover, and M. .0. Gores. •
"Pollution Prevention: One Firm's Experience."
Chemical Engineering^ (September 1991): 130-133:
Discusses the initial organization of a work team and
a three-pronged strategy for pollution prevention in a
specialty chemical process-.This strategy includes eli-
minating/minimizing unwanted byproducts, recycling
used solvents, and recycling excess reactants. Also ad-
dresses establishing goals and process monitoring.
Doerr, William W. "Plan For the Future With Pollution
Prevention." Chemical.engineering Progress 89
.(January 1993): 24-29. .
Discusses first steps in developing pollution preven-
tion strategies such as Toxic Release Inventory (TRI)
reports and,the motivation they provide. Other topics
include how to analyze the problem involved, organize
data, and estimate costs. Specifically addresses the
technical and economic options available to chemical
processing industries.
Drabkin, M. The Waste Minimization Assessment: A
Useful Tool for the Reduction of Industrial Hazardous
Wastes." JAPCA 38, no. 12 (December 1988): 1530-
1541. '
Discusses how to initiate a hazardous waste assess- •
ment, its importance in waste minimization, how to
use this tool efficiently, and its implementation. Also
included is an extensive.case example that progresses
through each step introduced in the article.
Dracxin. Marvin. Can Fromm, ana Harry M. F'eeman.
"Development of Options for Minimizing Hazardous
Waste Generation." Environmental Progress 7, no. 3
(Atlgust 1.988):.167-174. ' .
Discusses three subjects: waste minimization programs,
source reduction, and recycling (pollution prevention
only). The section on source reduction discusses mate-
rials, technology, and procedures. Included are tables on
waste minimization program elements, recommended .
audit procedures, and-a general list of information
sources for audit data. Diagrams include elements of
• source reduction and elements of recycling/reuse.
Goldner, Howard J. "Waste Minimization' Starts at
the top." Research & Development (September ;
1991): 48-52. / '
Discusses the role of management in pollution preven-
tion, current programs in industry and their success,
alternatives to current methods, and several separation
techniques. .
Hanson, David J. "Pollution Prevention Becoming
Watchword for Government, Industry." Chemical and ,'
Engineering News 70, no. 1 (6 January 1992): 21.
Lists which groups are undertaking pollution preyen- -
tion programs and discusses relevant legislation encour-
aging pollution prevention: Groups mentioned include
the Chemical Manufacturers Association, the American
Petroleum Institute, and Dow Chemical. Legislation
mentioned includes the Pollution Prevention Act, the
Clean Air Act, and the Toxic Substance Control Act.
Labar, Gregg.. "OuPont: Watching Its Waste."
Occupational Hazards (July 1990).
Discusses several approaches DuPont has taken to
reduce its waste production. These include process
modification, material substitution, and common sense.
Newton, Jim. "Setting Up a Waste Minimization
Program." Pollution Engineering 22, no. 4 (April
1990): 75-80.
Outlines key elements leading to the success of a waste
minimization program. Topics include: planning and
organization, data collection, waste streams prioritiza- ;
tion, waste minimization alternatives, and feasibility
analysis. Also offered are: a flow diagram of the waste
assessment procedure, tables presenting the necessary
facility information and typical causes of waste genera-
tion, and a checklist on waste minimization.
Annotated Bibliograpny«10
: Ocwu«f 199*
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Ric" 3e^aiG A. 'Air Toxics: Prevention and Mitigation."
Pc-furcr Ergmeenng 21. no. 6 (June 1989): 66-89.
DISC-SMS tne following industrial pollution prevention
topics r.Tes of releases and their possible prevention
' .table), possible hazards in process (table), and process
and plant design considerations. Different ways to
measure prevention progress are also discussed.
Rossiter, Aian P., H. Dennis Spriggs, and Howard J.
Klee "Apply Process Integration to Waste Minimiza-
tion.' Chemical Engineering Progress 89 (January
1993): 30-36.
Proposes a systematic method for identifying process
modification's that minimize waste generation through:
selection of process mode, input/output stream dia- .
. grams, recycle structure, separation systems, product
drying, energy systems, equipment, and pipework.
Smith. Robin, and Eric Petula. "Waste Minimization
in the Process Industries, Part I: The Problem.
Chemical Engineer 506 (31 October 1991): 24-25.
Discusses waste minimization'in the process/utility
area. Presents sources of process/utility waste and
successful strategies for waste audits. Also included
is a case study using mathematical modeling.
-Waste Minimization in the Process Industries
Part II: Reactors." Chemical Engineer 509/510 (12
. Minimization in the Process Industries.
Part IV: Process Operations." Chemical Engineer
517 (9 April 1992): 21-23.
Discusses generation and minimization of waste in
continuous and batch systems. Continuous process
waste generation focuses on start-up/shutdown times,
product change-over, cleaning, and tank filling. Batch
process waste minimization includes efficient use of
tanks, pumps, and valves. A case-study of a.batch
chlorination process is presented.
. -waste Minimization in the Process Industries,
Part V: Utility Waste." Chemical Engineer 523 (16
July 1992): 32-35. ,
Discusses the following topics as they relate to utilities:
•the importance of improving process energy efficiency,
how combined heat and power (CHP) works, impor-
tance of fuel choice, how to reduce SOx and NOx
emissions, and how to improve heating system and
cooling system utility. Coffee concentrate production
is presented as a case study.
Toy W. M. "Hazardous Waste Minimization: Part IX,
Waste Minimization in the Automotive Repair Indus-
try." JAPCA 38. no. 11 (November 1988): 1422-1428.
Introduces the automotive repair industry and identifies
• its common waste problems. Discusses the importance
of solvent recovery and how it can be implemented.
conversion and reactor concentration and how they ef-
fect the final product Waste reduction resulting from
impurities and subsequent loss of catalyst is discussed.
A batch reaction/distillation case study isincluded.
-Waste Minimization in the Process Industries.
Part 111: Separation and Recycle Systems." Chemical
'Engineer 513 (13 February 1992): 24-28.
Discusses the importance of closed loop recycling
through two different procedures — recycling waste
streams directly and feed purification. Subjects include
precipitation, evaporation, and other alternatives, along
with purge streams and their importance to recycling.
Curran, Mary Ann. "Broad-Sased Environmental Life
Cycle Assessment." Environmental Science and
Technology 27, no. 3 (1993): 430-436.
Overview of LCA. Discusses the importance of LCA
in evaluating pollution prevention programs. Topics
include: product stages, defining system boundaries,
the difficulty of financing an LCA, LCA methodologies,
and life cycle impact analysis.
Keoleian. Gregory A. The Application of Life Cycle. •
Assessment to Design." Journal of Cleaner Produc-
tion 1. no. 3-4(1994): 143-149. .
Discusses the role of LCAs in life cycle design. The
main limitation to using LCAs in design is the inverse
relationship between the information needed for an.
LCA and when that information is generated in design:
By the time a design has become fixed enough to
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5 ?;•-••*•"-=- --arserack ;nciud'es humerous short
Nazis'. >'e.!.J. Educating Engineers fonhe Environ-
ment M\c'r\\gan Technological University, 1992. '
Tentative syllabus of a course to be taught at MTU..
Topics include risk analysis, life cycle analysis, material/
energy balances, and several case studies.. .
Kummler, Ralph H., James H. McMicking, and
Robert W. Powitz.-A Program on Hazardous Waste
Management. Wayne State University, Sept. 1989.
Requirements for a major in hazardous waste manage-:
ment, a division of chemical engineering, at Wayne
State University.' - .
von Braun, Margrit. ES475/575 & Engr 607: Haz-
ardous Waste Management Syllabus. University of
Idaho, October, 1990.
This course examines the management of hazardous
wastes in the U.S. Introduces legislation and regula-
tion and discusses waste site characterization, risk
assessment, and waste minimization: '
Westermann-Clark, Gerald B. Incorporation of~P2. •
• Content Into Undergraduate Courses in Chemical
Engineering. University of Florida, 1992.
Lays out plan to incorporate pollution prevention in
undergraduate curricula at the University of Florida,
Problem Sets
Allen, David T., Nandkumar Bakshani, and Kirsten S.
Rosselot. Pollution Prevention: Homework & Design
Problems, for Engineering. Curricula. New York:
American Institute of Chemical Engineers, Center for
Waste Reduction Technologies, .and the American .
Institute for Pollution Prevention; 1992.
.A set of 22 problems divided into six.categories: life .
cycle analysis, identifying and prioritizing pollutants
from industrial sites', selecting environmentally compat-
ible materials, design of unit operations for minimizing'
waste,-economics of pollution prevention, and process
flowsheeting for waste minimization. The intro also .
divides the problems according to other topical areas.
Each problem includes background material, a problem
statement, questions for discussion, further reading,
and solutions as well as'background information about
industrial processes and common P2 issues.;
Welker, J. Re.ed,.and Charles Springer. Safety,
Health, and.Loss'Prevention in Chemical Processes:.
Problems for Undergraduate Curricula. American
Institute of Chemical Engineers,':1990. '
Homework problems addressing safety and heahh
topics in chemical engineering. Includes problem
matrix that categorizes problems into subject matter
cross-referenced against the class in which it would be
taught Problems list topic, concept, necessary back-
ground information, equations, variable definitions,
and a problem statement. ,
Original produced on Hammermill Unity DP,
a 50% p'ost-consumer/50% pre-consumer recycled paper
made from de-inked old newspapers and'magazines.
The National Pollution Prevention Canter
for, Higher Education , .
. University of Michigan, Dana Building .
430 East University Av».
Ann Arbor, Mt 48109-1115
.Phone:313-764-1412
• Fax: 313-936-2195 - .
• E-mait: nppc9umich.edu • ,
The mission of the NPPC is to promote sustainable development
by educating students, faculty, and professionals about pollution
. prevention; create educational materials; provide tools and .
strategies for addressing relevant environmental problems; and
establish'a national network of pollution prevention educators.
In addition to developing educational materialsand conducting
research, the NPPC also offers an internship program, profes-
.sional education and training, and conferences.-
Your Input is Welcome!
We are very interested in your feedback on these materials/
Please take a moment to offer your comments and communicate
them to us. Also contact us if you wish to receive a documents
list order any of our materials, collaborate on or review NPPC
resources, or be listed in our Directory of Pollution Prevention
in Higher Education. ,
We're Going Online! . •
The NPPC provides information on its programs and educational
materials through the Internet's Worldwide Web; our URL is:
http-J/www.snf«.urnich.«du/n(Spe/
' Please contact us if you have comments about our online .
resources or suggestions for publicizing our educational
•materials through the Internet. Thank you!
Annotated Bibliograpny • 12
Oc'.oOer 1994
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Pice, Steven C, 'Reducing Wastes From R&D
Fac:i't:es," Chemical Engineering 95.(October 1988):
85-38, • _ •
Discloses strategies for reducing wastes in research
and development facilities. These strategies include: •
using containers responsibly, creating an internal
material exchange, allocating costs for waste disposal,
conducting environment reviews, and tracking wastes.
Rittmeyer. Robert W. "Prepare an Effective Pollution
Prevention Program." Chemical Engineering
Progress 86 (May 1991): 56-62.
Discusses procedures for involving employees and
management, and how to set goals, establish schedules,
and assess waste streams. 'Other topics include the
importance of brainstorming and how to track and
measure progress.
Education
Kummler, Ralph H., James H. McMicking, and
Robert W. Powitz. "A Program on Hazardous Waste
Management." Chemical Engineering Education
(September 1989): 222-226.
Review of Wayne State University's education pro-
gram in hazardous waste management. Included are
program requirements, faculty, and descriptions of
courses offered.
Walters. James C., and Dominic A. Zoeller.
"Developing a Course in Chemical Engineering
Ethics: One Class' Experiences." Chemical
Engineering Education (March 1991): 68-72.
Short description of a stand-alone ethics course for
' chemical engineering students. Provides useful infor-
.mation on the design of any ethics course, as related to
P2. Compares stand-alone vs. integrated approaches;
discusses the content and format of such a class and
when in one's academic career it should be taken. Also
• includes he observations of both a professor who
taught the course and a student who attended.
Case Examples
Ember, Lois R. "Pollution Prevention at Chemical
Plants Benefits Environment at Low Cost.* Chemical
and Engineering News 70. no. 25 (22 June 1992): 18.
Article on source reduction including a case study of
27 facilities. Shows cost-effectiveness of P2 programs.
Redman, John. "Pollution is Waste." The Chemcal
Engineer, no. 461 (June 1989): 16.
Discusses several industrial waste minimization
programs (Dow, Dupont. 3M, Monsanto), and their re-
sults. Case examples are included oh a Dow Chemical
ethylene glycol process, Polaroid's dye-making process,
and Monsanto's adipic acid manufacturing process.
These examples include schematic drawings of the
processes and a discussion of process modification and
material substitution. A table of waste reduction tech-
niques is also included, courtesy of the EPA.
Syllabi and Curricula
Counce. Peter. Ch E581: Industrial Pollution
Prevention, University .of Tennessee, 1992.
Short course outline. . .
' ' !
Denny, Dale. Chemical Engineering 598-O: Waste
Reduction in Industry. North Carolina State University,
March 1991.
Brief syllabus for a graduate level course covering the
social, legal, and engineering aspects of waste reduction.
Design for Recycling Team. Teaching Environmen-
tally Responsible Design. Shirley T. Fleischmann,
ed., Grand Valley State University, 22 October 1992.
Original and copied materials comprising a coursepack
and problem sets for an undergraduate engineering
design class. Creeds, codes, and ethical mission state-
ments are presented in essays on ethics for engineers.
Secondary materials are discussed in the Designing for
Recovery and Reuse of Materials section. The Paper vs.
Polystyrene cups issue is' included in a module for
EGR 360 Thermodynamics. Materials on a paper-making
classroom project are also included along with a Design
for Disassembly freshman.curriculum unit.
Fleischman Marvin. ENVE 534: Industrial Waste
Management. University of Louisville, March 1991..
Brief course outline, aimed at environmental engineers
but is broad enough for other students. Most of the
second half of the course covers pollution prevention/
waste minimization topics.
Fleischman Marvin. ChE 694: Waste Reduction, ,
Treatment, & Disposal. University of Louisville, 1992.
Syllabus for graduate level introductqry course that
incorporates videos, case studies, guest speakers, and
Octooer 1994
-------
Original produced on HanunernuU UrutyOT,
a 50% poS^nsumer/50% pr^onsumer
taadefcom de-inked old newspapers and
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„•. ;r ?revention and
>,err,ica.l Engineering
Course Syllabi
Introduction to Pollution Prevention
William Budd, Washington State University
Industrial Pollution Prevention
• Robert Counce, The University of Tennessee
Waste Reduction in Industry
Dale Denny, North Carolina State University
Industrial-Waste Management • •
Marvin Reischman,-University of Louisville
Waste Reduction, Treatment, and Disposal
: Marvin Reischman, University of Louisville
P2. Waste Treatment, and Disposal
Marvin Reischman, University of Louisville
Industrial Waste Reduction
David Kidd, University of Alaska - Anchorage
Design of Environmentally Benign Chemical Process Plants
Ronald G. Minet, University of Southern California
Advances in Polution Prevention:
Environmental Management for the Future
Michael Overcas'h and Christine S. Grant,
North.Carolina State University . .
Pollution Prevention . •
Robert Pojasek, Tufts' University
I Hazardous Waste Management
Margrit von Braun, University of Idaho
I Engineering Risk Assessment for Hazardous Waste .Evaluations
Margrit von Braun, University of Idaho
Nat-cna. Pollution Prevents Canter for H.gher Educat.on Un.versity of MicMgar,
Dana Bunding, 430 East Umvursily. Ann ArborMI^8l09-illS
Phoi.; 313.T64.U12 • Fax: 313.936.2T95 • E-mail:
May De reproduced
freely for non-commarcial
educational purposes.
Pollution Prevention Syilaoi • 1
.Oc;ooen995
-------
'^n- reduction- to
.Pcliution Prevention
ES/R? 490 (1 credit)' + ''ES/RP 499 (2 credits)
SS/RP 590 (2 credits) + ES/RP 600
-------
jA^ -os-: or Prevention and
**• ChemicarEngineering
Introduction to Pollution Prevention
William Budd
ES/RP 490/590 & 499/600, Spring 1993
Washington State University
National Pollution Prevention Canter lor Higher Education • University ot Micfiigan
Oana Building. 430 East University. Ann Arbor Ml 48109-1115
Phone: 313.764.1412-Fax: 313.936.2195
SyllaBus. 3uoa
August '994
-------
:ex.-. f = r the c-lass will be *-' ' T ;.?r. - -~°y—,; ;•" 3 flT.r.ir.-
•-..^...=ll fcr chapter-1T3-307 WAC, Washington Reduction,
_ .
^e-J-'-g "and Litse-r Control Program, Publication #9-1-2. Copies
will"be'made available to students id the first.laboratory period.
A syllabus of other reading materials'.will-be developed as
necessary during-lecture:'periods. . ••
3
-------
There will be two hcurs of lecture and three hours ,of field
analysis.'laboratory per week.
'Evaluation will be based on various laboratory assignments, and
laboratory (-1) and class (1) examinations.
Graduate students will additionally be required to develop a
research paper on a pollution prevention topic approved by the
instructor. The initial list of .topics include, but are not *
restricted to: ' .
1. Analysis of potential waste reduction/opportunities in- the
automotive repair industry. This would- entail researching
the different waste reduction strategies, analyzing how
effective it would be for a shop to implement, cost
effectiveness, and what should be a'reasonable-and
achievable goal for reduction.
2. Economic analysis of waste reduction techniques for the •
• automotive repair industry. Much of the waste reduction
information has been developed for larger shops. Waste
reduction savings at smaller shops may not'be significant
enough'to,provide incentives to reduce, especially if there
are capital costs required to implement waste reduction.
This-project will quantify, the real cost of .implementing
' common waste reduction techniques, including training,
capital costs, capabilities of new equipment, and •
productivity. Once costs are quantified, a model will be
developed for comparing'costs and benefits to answer
•questions concerning fiscal impacts and payback times.
3. Development of an assessment tool, for small businesses.
. Many techniques have been developed for -larger industries
•but prove to'be ineffective when applied to smaller
businesses. - •
' 2
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eb 10 •
:urr5n- Issues .in ?2 ' ( c'c r/ - j <3udd)_ ' -• ' „ ,
F_c~ " """i-sl P'rcduct 3eveloprr.er.~
. Development; of -New Unit Operations • •
• ?2 Training and- Education - •','
Pollution Prevention in Washington:" An overview-
Feb 15 •• ^reassessment review: • Developing, and using a facility/
history ' . •
Feb 11 P2 and Management: Building'bridges for cooperation •
Feb 22' Toxic' materials and hazardous waste: Inventory and
analysis ...... • -•.'•.
•Feb 2-4 • Toxic materials -and hazardous'waste: .Seeking
.alternatives; •..'..-, . .. .
Mar 1 Air emission assessment •..
Mar 3 - -Water .use and discharges
Mar 8 Energy: Problems'and analysis (Hinman) -
Mar 10. Energy: Evaluation and response (Hinman)' -' . .
Mar 15 ' SPRING. BREAK ' ' - '•';/
Mar''17. SPRING BREAK . . . ;
'Mar 22 Pollution prevention planning:'. Understanding .the'
Washington process . , . '
' Mar 24 Pollution prevention planning: Understanding the. '
Washington process, (con-'t)
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Week
an 11 introduction: Terminology and Benefits cf P2 (3udd)
Jan 13 Federal Pollution Prevention Programs (Sudd)
Pollution Prevention Act 1990 •
Clean Air Act Amendments 1990
EPA' Pollution Prevention Strategy .
•EPA ?2 Research Program • •
Jan 13 Federal Pollution Prevention Programs • (con' t) .
(Budd) •'-•••...
33/50 'Program
EPA Green Lights Program
Other federal programs: DOD, ..... DOE, U.S.
Postal Service
Jan 20 State and local P2 -Programs (Budd)
Jan 25 . State and local P2 Programs (con't) (Budd)
Jan 27 industrial P2 Programs (Budd)
Feb 1 " Current Issues in P2 (Budd) •
• ' Clean Technologies. • . •
Measuring P2 .'•-.•
Cost. Effectiveness
Incentives' to 'Encourage P2
Barriers to P2
' Feb 3 Current issues in P2 (con't) (Budd) -
Lrf.e Cycle Analysis (LCA).
• • ' Management and Business • .
Product Design • . •
.4
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Mult i-rr.edia strategies: 'Ana-lysis and the development cr
alternatives. •- ' ....
Mar '31- • • Economics and;P2: Evaluative models; building the case
for pollution'prevention (Sudd)/. - .
Apr "5 Economics and P2:^ Evaluative' models; building the' case
• for pollution .prevention (DOE'Speaker)
Apr 7 pollution prevention planning: 'An.assessment ofscase .
studies ; . . ' , . - .
Apr 12- pollution'prevention planning:._ An assessment of case
' . studies . • / . " " •
Apr-14 'Field trip: ^Whitman County • ' • ' :' ,; ;.,-;, • •
'Apr 19 Review and assessment of site visit • . ' .
Apr'21 Field trip: Nelson Irrigation (Walla-Walla)
Apr 26 . Review and assessment of site visit
Apr 28 . Conspectus
-------
V,"ee.<
Introduction to Pollution rrever.ticr.
Laboratory Sessic'r.s
Project/Topic
'jan n3 Introduction to environmental management .at WSU;
environmental health and safety considerations
(Hagihara) '
'jar. 20 Waste management game; analysis and review ,
Jan 27 WSU site visit; preliminary assessment •
Feb 3 Continue with PA , •
Feb 10 Building systems models/team development of a flow mode:
for WSU operation' ' •
Feb 17 Evaluation of'toxic materials usage and hazardous waste
Feb 24 " Evaluation of toxic materials usage and hazardous waste
Mar 3 'Evaluation of air emissions problems '
MarlO Assessment of. water use.and discharges .
Mar 17 SPRING BREAK
•Mar "24 Energy auditing
' Mar 31 • Economic evaluation and P2 • •
Apr '7 P2 Plan Development .
Apr 14 Whitman County Irrigation field trip . ^ ' .
Apr 21 Nelson Irrigation field trip ;
'Apr 28 . Laboratory EXAM . . ' • ' - '
-------
Industrial PolJucion Prevention (3 semester hours credit)
Chemical Engineering 58 1 '
Engineering Science and Mechanics 581 •
Environmental Engineering 581 " . . " •
Coordinators: R. M. Counce and R. J. Jendrucko ''./-'
Description: Principles and practical aspects of industrial pollution
prevention. Regulatory environment, pollution prevention strategies,
economic analysis, life cycle assessment, process safety, case study:
analysis of alternative waste management technologies.
Goals: The goal, of this course is to incorporate pollution prevention
into a typical approach to the .analysis and design -of .industrial • .
processes. The course focuses.on topics such as environmental rules
and regulations, opportunities and approaches to pollution .
prevention, analytical tools such ais flow sheeting, economics, life
cycle analysis and risk assessment and culminates in a relevant
pollution prevention project. Numerous case studies. and examples
are presents in the course and speakers from industry and
regulatory agencies are frequently utilized. " -
Textbook: Hazardous W^tfr Management (McGraw-Hill) by C. A. Wentz,
New York 0 989). .
Supplemental Materials:
Reduc-tirm Assessment -arid Technology -Transfer (WRATT) . ,
pq Manual (2nd Ed) (University. of Tennessee Center for
Industrial Services) by Cam Metcaif (Editor-m-Chief), Knoxville
(1989). ... . .
Pollution Prevyition: Hpriff WQrk an^ Pesian Pr^blemg for Engineering
Curricula, (Center for Waste Reduction Technologies, American ^
Instituteof Chemical Engineers) by D. f . Allen, N. Bakshjani and K, S.
Rosselot,,- New York (1992).
-------
Pollution Prevention and
Chemical Engineering
i s-a »<3~e.
Industrial Pollution Prevention
R. M. Counce and R.-J. Jendrucko . .
Chemifflf Engineering 581/Engineering Science and Mechanics sol I
Environmental Engineering 581: University of Tennessee •
-------
Prerequisites: . ' • ' . • . • ,'
; l-.j graduate standing in engineering; (2) consent of Instructor
Topics: ., ,--•.', - . • . .
,1. Introduction . , „
2. Environmental Legislation
3. Environmental Legislation-TSCA, RCRA, CERCLA& SARA .
4. Hazardous Waste Characterization
5. Approaches to Pollution Prevention
6. Assessment of Pollution Prevention Opportunities
7. Life Cycle Assessment
8 Process Flow-Sheeting and Waste Tracking
9. Process Selection and Design for Pollution Prevention
10, Cost Estimating and Project Evaluation '
1^. Risk Assessment ,
12. Case Study in Pollution .Prevention :
1J. Selected Topics in Pollution Prevention •
Computer Usage: Several homework assignments and case study are
sufficiently detailed :so that computer usage is of obvious advantage.
Laboratory Projects: No lab is associated with this course;
Estimate ABET Category Content: .
Engineering Science: 1.5 Credits or 50%
1.5 Credits of 50%
Prepared by: R. M. Counce Date: October 30, 1994
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1
1
1
I
V
1
I
1
1
1
1
'"'
1
1
1
1
1
1
1
I
Instructor. Dale Denny
Schedule: '• -
Stek.
January 14
. January 21
January 28
February 4 .
February 11
February 18 '
• February 25
March 4
March 11 . . .
March 18
' March 25
April 1
Aprils-
April 15,
,4 j^£'i'~ 'v '"• "' ' -
• April 2
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-' -~ 5rever.tion ana
r.efr.icai Engineering
Waste Reduction in Industry
Dale Denny
Chemical Engineering 598-O, Spnng 1991
North Carolina State University
' National Pollution Prevention C«nt»r lor High«r Education • University ol M.cnigan
Dana Building, 430 East University, Ann Aroof Ml 48109-1115
Pnon«:313.76*.l4l2' Fax: 313.938.2195 '
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PC.iutscn Prevention; and
Chemical Engineering
Waste Reduction, Treatment, and Disposal
Marvin Fleischman
ChE 694, Fall 1992 •
University of Louisville
, Naa,na Poliuuon Prev^non O.m.r.or W B^gon; ^*
Dana Building. 430 East UmvefSity. Ann Artor Ml 46109-n is
Phone: 313.764.1412 • Fax: 313.936.2195
Syiaous: F-.eiscnman-2
August i »9*
-------
File: Course.92 - :
WASTE REDUCTION, TREATMENT, AND DISPOSAL
Fall 1992 - ^ -->-=> ^''^ ^ '.,-,-,
Text: Freeman, H., "Hazardous Waste Minimization, McGraw-Hill; 1993
USEPA, "Ur.derstar.dir.a the Small Quantity Generator: Hazardous
Waste'Rules", EPA/530-SW-86-019, Sept. 1986
8/25 Introduction
Vid-eo: Beyond Business as Usual
Reading:' Ch 1 - Waste Minimization as a Waste .Management
Strategy in the United States; Ch 2 - Potential for Waste
Reduction; Handouts
8/27 Hazardous waste characterization, Priority pollutants
Pretreatment standards.for discharge to POTW
Video: Less-is Better: Pollution Prevention Pays
Good Housekeeping, Segregation/ Management Issues
Definition of Waste, Preferred Waste Management Hierarchy
'Handouts ' ' '
Reading:*Ch3. Waste Reduction Techniques & Technologies;
Handout ' • • • _ •
9/1 Dave Fetter, Law Environmental, ' "Overview of
Environmental Regulations", Handout
9/3 Went over Assignment on "Beyond Business as Usual"
Definitions and implications of Pollution Prevention, and
Product Life Cycle Analysis •
_• MB ^ • ^ « «• — «• •• ^ •» •• ™» ^ ^ ^ "• ^ "» ^ ^^^•• — ^•"••••"^^•» •• ^^^^^^^^^ —• ^ *• "* ^ ™* —" ^ ^ ^ ^ "** ^ ™ ^
9/8 In the News: EPA 33/50 Program, Burning'used tires at a
cement kiln-Thermal Processes, PCB ban & cleanup,
Plastics recycling guide, Burying power plant flyash in
coal suppliers landfill- Product Stewardship, GM -Parts
strike & impact on car manufacture-inventory control,
just in time tradeoff
Reasons for P2, Benefits arid Tradeoffs
9/-11 Guest Speaker: Jerry Rockey, . Heritage Environmental
Services, "Off-Site Waste , Reuse, Conditioning.,
Reclamation, Recycling, Treatment and Disposal" - Handout
.Reading:. Ch.3, Handout •''..'
.Assignment: In the News
9/15 In the News: "The Recycling Bottleneck", Time Mag.,
9/14/92,. pp 52-54 " ' „ •
'"Residents Lash Out at Hazardous Waste Storage at Kosmos
(Cement Kiln) . . ' . ' •
Synergies between Safety/Health & P2, Off-Site .vs, On-
'-•Site Solvent. Recycling
Overview:.Waste Reduction Techniques/Technology
, •'• Reading: Ch3. • . •
9/17 in the News: Acidic & Caustic Cleaning Fumes from
-------
Kpersion TanX£lClntl°pnain\ Formulation, • Reduction . of
aragout-Losses from Rinsing common, household
:p2 i a^l" ^n t^anuyfa=turir.g; Problem,
Plating Rinsewater ... •
T« *->>« K*»WS- us not immune to financial i
9/22 "."a.HT^;.» to Economic & Industrial
Tokyo; - Limits to Economic^ indusria irabilicy;
increasing product durability ?value over
recylability, emphasis on function «
^ianingSEmisiSf-"icroUave destruction SOX . Npx- in
power-plant stack gases . , ,-
'
t
' Minimization "f.3M Co., 8:50
.
Video: "Down to Earth", Marine. Shale Pro^..ors - Thermal
Treatment/Recycling in a Rotary Kiln .- Handout
waste fuel) - . ^amon+. . viin be allowed to • burn
to LGE flue gas scrubber) ; .
""
-------
C-r.cIct, Earl -/Reduction Credits, 33/50 Program
Field Trip: "Power Plant Air Pollution Controls - Sulfur
Dioxide Scrubbers", Tour of LGE Scrubber^Systems, at cane
Run Plant (lime & dual alkali), Mark Schnutt,
8802
Assignment:
Handouts: FGD
Alternatives, ~~...-
Lime Scrubbing & Dual Alkali Processes
o/
ssssss
guid.s for videos I reading
Sulfate by Plating Bath Rinsewater
to mine • •
casa Study: Recovery of Nickel Plating Rlnsewaters by
C.old Evaporation
10/15 case Study: Nickel recovery by reverse osmosis
" ' over ^3 assignment ^,an«.^ative
srm - Part II (take home) - quantitative^
- Minimization
industry; Oi 5 - waste Minmization Assessments.
-------
In*' the News:: Firr. -hit: witn biggest ' waste.--cj.-ear.
Miscarraiges linked to two widely usea
I •'"• ~ VJ I
EN] ,
orcorace Environmental::• Policies - Quaker. Oats
Waste Minimization Assessment Procedures - Preliminary to
Site Visit'- Definition of wastes - . '. .- .
Handouts: Steps in Waste .Min .Assessment - •
Types of Information-Needed' . •; \
" • '• Waste Reduction Procedure
10/27 Engelhard Assessment:,Pre-site visit, * _
• Annual Hazardous Waste Generator Report Review <
Handout: Codes .for Hazardous Waste Generator Reports
10/29 Assessment:. Pre-site .visit . _ • ; • -
, . • ' - process/Product Description -.Organic Pigments ,
' Mike'Campbell - Engelhard...Employee, Class Student •
; ' . ,_- ; ; ; _ —. ; ' + ' '-
11/3 "Election Day.- No Class _. - . -
11/5 Legislative Authorities Affecting the Life Cycle of 'a,
- . ' chemical .. . • . ' ' . _. „„„,.
Class Project': Organic Pigment Process, Cadmium Pigmsnt
Process, Wastewater Pretreatment Plant - Mike Campbell,
Stephanie Ellis, Engelhard, Students
-------
. ... -.-~e- visit - Cad-iun Salvage Plant, ,Wastewater
-~e=-r.ent Plane, Cadmium Pigment. Plant, Organic Pig-er.ts
x, -2 Students went over site visit & brain stormed.
11/17 "Wastes: To'surii or Not-to Burn", CEP, July 1992,
pp 53-58 ,'.'..«.
" Additional discussion on site visit
11/19 -DuPonf -Louisville 'Waste Minimization Program, '
Lisa Moyles, DuPont, Pollution Prevention Program, 569-
2525
11/24 in" th°e News' ChemTcal firm- to pay $125,000 fine for
soill, Dumps at coal mines go largely unregulated
. Kxics Release Inventory Reporting: Defining, waste delays
toxics inventory form, C&EN,, June 8, 1992, pp 22-23
ClasT Project: Formation of student teams - Cadmium,
Organics .
11/26 Thanksgiving . J__
•12/1 in"the"News":""parkham Helps Auto Shops turn hazardous
Waste into Profits (advertisement) 1QQ1
SARA 313 Reports: Engelhard 1991 TRI Report for 1991 -
cadmium Compounds/ New Form R Reporting Requirements for
Pollution Prevention, Determining- a Production or
Activity Index
12/3 State &,Federal Regulatory Arena -Concerning Pollution
.Prevention pollut,on 'prevention.' Information
. clearinghouse (.PIES) Demonstration
"~- B~or^m^TiVlTro7"of~Contaminated Soils & G-roundwater, Jerry
12/8 ' McCandless, The Evergreen Group, Louisville, KY
12/10 EollutionSprevention in'Chemically Reactive Systems
CMAS' Responsible Care Program
SSft rep?r?s submitted - Organic Pigments Manufacture,
Cadmium Pigments Manufacture
12/17 Srrfl^poreturned prior to class ' with suggested
correction,-additions, modifications
Student Presentations of Reports .p-^i
Revised reports submitted .- After classroom final , . ,
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Pollution Prevention and
Chemical Engineering
Pollution Prevention, Waste Treatment,
and Disposal
Marvin Fleischman
.•'Spring 1994 •'.
University of Louisville
_^— Syllabus: Fieisc"rpar'-3
.Nauonal Polluuon Prevents Center (or Higner Educanon.. Un.vari.ty of Micmgan . -. . .0etoDer:995
Dana Building. 430-Easj University. Ann Aroor Ml 48109-1115 .
Phone: 31.3.764.1412 -Fax: 313.936.2195 • • . • :
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Pollution Prevention, Treatment, and Disposal
Spring/
e.g., Time, Newsweek, etc
_9
vih • -
marines, '
Waste Minimization"
Oesign
1991
at Paint and Coatings
'295, Elsevier, 19 9 2^
summary of Topics Covered
Research
preventi=n. benefits, tradeoffs.
2SSSS, Hierarchy (Product ,
- =i=l= analysi,, Industrial
ecology, Sustainable development •. ...
Pi information Resources/Data B aj«J .
Pollution Prevention Regulatory^rameworK
> Re^latory-Approaches/Definitions_ .regulations .
Prlvention
+
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. requirements 4 Permits , .
- Was.e characteristics, Lists '
'"-I'-strial Wastewater pretreatment for discharge to POTW_
F"'ar.t water balances, water conservation and reuse, quality
surcharges, and lost product value _
Ccnnercial waste management services - Heritage
Thermal processes - Cement Kiln
' Pollution prevention tedhniques, technologies, approaches &
' exampleT- Product & Process, from design thru manufacturing
Waste Reduction Measurements
Prioritizing pollution prevention options •
Pollution Prevention Assessment Process
. class assessment project (Courtalds Coatings)
Total Quality Management
Corporate and Trade Group Environmental and Pollution
' Prevent-on Programs - Elements of a Waste Minimization Program
Additional Topics Covered in Previous semesters
Pollution Prevention in Chemically Reactive Systems
. Flue gas desulfurization . .'• •
Field Trips
SSSxSTSStSS; •^li.1&i"ill.. KY - Part of class project
Simulation Exercise
Fun Factory ' - .
Problem Assignments
(Other assignments shown on detailed course schedule)
. Paint transfer efficiency, waste generation,& materials savings
. Estimating Hazardous Waste Constituents for Sewered Waste
Notification Form (Minnesota)
Reducing POTW surcharges (Biochemical Oxygen Demand.)
Recovery of Nickel Sulfate from Plating Bath Rinsewater and Water
conservation (Parts 9 & 10 as take home quiz)
. Evaporative Recovery of Copper from- plating rinse waters, water
reuse, and reduction of wastewater treatment plant costs
. Burning hazardous wastes in a cement kiln, Integrating cement
kiln-coal burning power plant (to be graded as exam).
Prioritizing pollution prevention options
' . Form R Production Activity ratio .
. Waste ratio
Class Assessment Project
recorts and
In class coverage ot wwiuyanj = =»»»**-.— «*• - -
"Process, Product, Waste and .Emissions Overview of Plant",
Presented by environmental manager of plant
lllll brainstorming session (slides taken on plant visit and
-------
.-'-'-• — • " C ' a S 3 ) i ... • . "
J":«s-';--ns^ar.d-answer session with plant environmental manager
! Students allowed to- communicate directly with plant manager .
'. student rewrite of draft reports ; . ; _ .• '
•'ri-a1 report and group presentations, in class ••'..,' ,
.(Soae students did a/waste prioriti.zation on report similar to -
AICHE problem) , . ' ; ' ... '
'•• ' other .
Outside speakers - Heritage Environmental Services, Kosmos Cement .
'.Plant, Law Environmental, General Electric Appliance .Park,
• Industrial Engineering faculty member • '' ,
Video'tapes - "Beyond Business as-Usual" .(Waste Management
'-Hierarchy,- Hazardous Waste Treatment-& Waste Minimization;
Safety-Kleen Video Network, "Parts Cleaner Services" and "New
castle Drum Shredder"; "Down to Earth" (Marine Shale Processors),-
' Source Reduction Now; "Less is More: Pollution Prevention is Good
Business"; "Waste Minimization:.Introduction"; "Waste
Minimization Assessment Procedures; 3M and the- Environment-, .An .
Individual' Effort" ' ,- - ' . - . •
Detailed Course^Schedule
Jan. 11 . - Introduction, - Organization, Student, introductions,
Course Overview .
introduction to waste Management Approaches
Video; Beyond Business as Usual (Waste Management,
Hierarchy, Hazardous Waste Treatment & Waste , -
Minimization) • M . ,/,eo
Assignment; Handout on video - Hand, in on I/IB?
Handouts; Kentucky Partners . newsletter; Course
description and outline; Tentative syllabus; Acronyms,
Abbreviations, and Such; Glossary; Summaries of
Environmental Laws Administered by the EPA; Clean Air
Programs , .
In the News; Not just polyester, recycled polyester is
Other; ^N^d for' course; . Overhead of _ cartoon on
conflicts between industry - and enyironmental .
regulations, Administrator Browner; Pollution Prevention
is Becoming EPA's Guiding Principle; Examples; 2 sided
copying of handouts (increased labor);-Printing-on clean
'•• " • side of scrap computer paper & then copying or faxing
wrong side; Super market - knotted plastic bag for^fruits
and vegetables hinders reuse .of bag, not taking a bag for
one item; Paunch washer/scalder - Rakvere (60C water to
sewer, steam loss- energy &. water, water and manure^on
floor, poor condition of equipment; Before and after -
' ' Engelhard pigments &.Japanese rock-garden -
.Jan.- 13 Went, "over "Beyond- Business as Usual" assignment
Assignment; Analysis of recent news article _
• ' :' Assignment; Waste definitions, Waste Management
Hierarchy, 'Definitions (Chi, EPA Manual)
•-Jan. 18 No Class - Snow Day . ' • ....
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Jan.
^^
compliance (FGD pollution control, Command & Control vs.
« P2 opportunities OS,
^ef ilSition - Multimedia, Hazardous and non-
hazardous wastes and releases
Material inputs not incorporated into final
Pr°duSrecovered raw materials, . Unrecovered
products, Useful Byproducts Impurities in raw
' materials (% conversion, yield,, paint transfer
efficiency), Spent process material, cleaning
waste, Packaging & container wastes
. intrinsic Extrinsic, Variable, * *«•* W"_S»
, Manufacturing definition of waste - Lost product,
rework, Non value added material, e.g., •
. importance of above in Identifying PPOs - Wa|te
audit
s Painf transfer efficiency , waste
generation, & materials savings problem
Jan.
Hiararc.y, Definitions, and
DiSti|isk°nSr*duction, Pollution prevention, Waste
' Minimization i Source reduction, Recycling,
?reatment, "' Disposal, Hazardous & non-hazardous
waste, Multimedia focus
. Pollution Prevention Act of 1990
' ! Environmentally friendly design of P^ducts. . _
Exhibit: (Dissassembly, recyclability
Removable plastic spout - from brandy bottle,
Plastic deodorant dispenser
Feb. 1
S°S2Sefit./ Tradeoff., Limitations, S Barriers
-------
(Examples from assessments) ' . . _ , ,
. Avoided or .reduced materials, costs '•.--.
. Reduced waste management costs : .
. Less ..regulatory burden
. . Risk reduction ' . -'
. -Avoided or reduced pollution.reduction/control
. equipment ' , .
• . Intangible benefits '* • • • •
" . Full cost, accounting & payback
. Interactions with energy - Synergisms- & tradeoffs
. Interactions, with safety & health
. Wastes as raw materials
. Tradeoffs -'Cost, Labor, Product - . •
Quality/Specifications, Customer Acceptance,
'_'.-' Functionality vs. Cosmetics • • '"*..*. *. • ' ,
'. Other barriers - Economic, Regulatory, Institutional
" - Reading,: EPA Guide, Chi., Ch. 2, Developing a Pollution '
Prevention Program, pp 2.3-26 ' .• : '• ••
Feb. 3 Jerry Racgue, Heritage Enviro'nmental. Services; Inc.,,
473-0638, "Commercial waste management services" -
• Reuse, Recycling,-. ' .Fuels Program, Treatment,
. ' incineration, t / .
Landfill, Parts .Washer Service - Hazardous, non-
hazardous waste definitions
Handotit: Company literature • . .
Assignment: Weekly'news abstract ,.,.
•Feb. 8 John Gonzalez, Louisville-Jefferson County Metropolitan
Sewer District, "POTW Industrial Waste Pretreatment.
Program"(540-6913)
Assignments: Industrial Wastewater Pretreatment,
Estimating Hazardous Waste Constituents for Sewered
Waste Notification Form (Minnesota), Recovery of Nickel
sulfate from Plating Bath Rinsewater and Water
Conservation (Parts 9 & 10 as take home quiz)
Feb. 10 Assignment: Weekly, news abstract . ;, • -. .
in the Neva: "Overhaul of water law proposed", "Auto
repairers want equal air pollution rules" . .
' ' other barriers (cont.)- Economic, Regulatory,
Institutional (Examples: Lesco solvent recovery, Ichikoh
- paint wastes & hydroclone as a waste min. opportunity)
Commercial waste management services (cont.)
Recycling & liability, Hazardous waste derived from &
mixture rules, Relationship between. BTU content, metals,
water, chlorine content & pumpability, and .cost of
disposal in a thermal.program, and degree of
' solvent recovery vs. cost of still bottoms
* disposal/ Use of MSDS for parts washer solvent
and checking for SARA 313, Clean Air Act, and
other listings - .
•'.-.''• video: Safety-Kleen Video Network, "Parts cleaner
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Hazardous Waste Lists and Characteristics
case Study, Examples - Water, Wastewater
: Priority P°llu'
handouts).: Priority P°llu^?' f^dlrds water quality
based) «*£ ':Si£, SBaasfsarf oV wWater Sewage
surcharges, reuse, separate
sewer meters) \ _ ustrial wastewater
platlng
' Bath Rinsewater Problem (Parts 9 &
Feb. 17 xn^tri.1 «^s,»r?~*s
"k?iiS ^ilweLn "Ira* « , Pretraatment Program,
SSSSS; p«ve«inon as part ^/-tre^ment progj.
wastewater. treatment plant costs
22 Steve Tucker, Law Environmental (588-5840, 588-5800),
ha/aSfus vas/rt solid product mad.)
Handout: For video
• ' 4.-,« Moaciires Plant Water Balance &
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Marcr. ^ x-r.c.-. ever Hi : p2-a
-ing rir,sew.ater &Cu placing rinse water
..
evaporation problems . •
v = r--h 3 Evaporative iewwvcxj •— - -ai-aia- from
..ar-— .1 j • i. x *-*f , pm-TivpTv or metais ironi
i C-\l ri J.) i i\ss*-*1-'» *— j-1 '
\\.^, <--"-// r>,-siit.= i-*f mot-al bearino
reverse osmosis - Reuse of. metai oearmy
••••'
Management); • . •-. . • . . _ •„_-, -iution
Reading: EPA Manual; Ch.2 - Developing a pollution
; Prevention Program, Ch- 5 - Maintaining the .
Pollution Prevention. Program , ,
M^r-rh 8 -Plant tour: Kosmos Cement Kiln, Louisville, KY , .
March .8 Plan\gsi nt {to be graded as exam, wo^meintP^^n'
Burning 'hazardous wastes in ,a cement kiln,
. -' - integrating- cement kiln-coal burning-• power plant -.
' '• . ' (Ref. Nemerow, industrial Waste Treatment)
Handouts: From Kosmo.s • "
March 10 went:over Ni recovery from^rinse Water assignment/quiz
Fun Factory Simulation exercise ,
March 15 Spring Break
. March 17 " !' ' . • . '. •.•"'. ' -
««<*22 ^le^^c:i Wi^r^»t^
ErSuii; °^ ^S* P^-n^on ^grams and
- assessments ,,Less is More. pollution; Prevention is
Good Business" (EPA)r "Waste Minimization:
introduction" (Ca. Dept. Toxic Substances,
•'16-10?- "Waste . Minimization Assessment
- Procedures (10:18, Ca. Dept. Toxic Substances
.. ,, Handouts: On videos ^ -"10.91 ch 3 -
Readings Assessment process - PP . 18-21, cn-J
" ... Developing a . P2- _ Program, Ch. 5 -, Maintaining
A?signmeSt!rpriSritizinggpollutionPrevention.Options -
AIPP' •.'._. . ' ' . '- • ', ';'
March 24 Cement kiln assignment due
Preassessment Methodology/Class Prpject
-• . . ' 'Report format - , •
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Certificate of Registration for Hazardous -Waste
Management . • . . '
General POTW Discharge Permit
Air Emissions .Inventory Statement, Certification
of Data Accuracy , :'
Operating Permit (Air)
TRI, Waste Generator Report, Assessment
Process
Handouts: Portions of above permits for assessment
project company, Report format, .Assessment
procedures
Assignment: Questions on EPA Facility Pollution
4 Prevention Guide, Ch2 - Developing a Pollution
Prevention Plan, Ch. 3 - •Developing and
Implementing Pollution Prevention Projects,
Ch. 6- Economic Analysis of Pollution
•prevention Projects
March 29 Preassessment/Class Project,
Brent Fryrear, Manager,'Environmental Health & Safety,
Courtalds Coatings, "Process,•Product, Waste & Emissions
. Overview of Plant l"
March 31 AICHE problem on prioritizing P2 options due (teams)
Went over cement kiln assignment(graded)
Review of previous speaker's talk
1993 Hazardous Waste Generator Report for assessment-
plant .
Formed assessment project teams
Handouts:' For each group, sample report, waste gen.
report & form Rs for plant
Assignments(graded): Hazardous waste generator report,
Form R Production Activity ratio .
April 5 Plant visit '
April 7 Assessment Process, 5 step procedure
' Discussion of plant visit, Views slide," Brainstorm,
What we saw, Identify WM opportunities, Identify .
questions and additional information needed
Submit questions to Brent
Handouts:. Notes from plant reps, class presentation,
•'instructor's review of prior plant information,
Instructor's writeup of plant visit notes
April 12 Total Quality Management and ISO 9000, S. Alexander,
Dept., of Industrial Engineering, University of
Louisville
Handouts
Reading: CnS - Maintaining the Pollution Prevention
Program
Assignment t Parallels between TQM and ISO9.000, and
Pollution Prevention programs
Assignment: Waste Ratio .
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•> —• — a
::r.-.--e Lisruss :.--' rf plant'visit and- T-ssti:
i-svsrs' - Bre'r.f-Fryrear '',.'. ' • ' •
Stu.der.ts FAX questions, to Brent t ^ • ^ f
Paul- HosaV .General Electric' Appliance Par<, .«£.s
Corporate. Pollution -prevention Program".
Handouts: '; •"''• ' . . , . ,, " .
. - : . Assignment: EPA -Manual,- Ch.5 - Maintaining the
. . pollution'Prevention'Program .
3M video:; 3M and tna Environment, An individual Etrort
(13:10) - Handout'
2i Assessment Project:- 'identification, brainstorm, -and
.evaluation of waste minimization opportunities. •
25 Draft assessment reports due ..- . -,.^, ."_--'
Legislative Authorities Affecting the Life Cycle of a
Chemical - TSCA, HMTA, CAA, CWA, RCRA, SWDA ,
' Regulatory Concepts: command &-Control, Incentives,,
Technology Based standards, Categorical Standards,
Emissions Standards, Ambient Quality Standards ' . .
Went- over Assignment on Ch.2 - Developing • a Pollution
'.•Prevention Plan ' ; ••:..'
3M Environmental Policy and .P2 Program •, ,.
SA Responsible Care Program and' Pollution Prevention
Code
interrelationships vith Pollution
Prevention and waste Minimization, i Examples
Toxics "Use Reduction _ .
Life Cycle Analysis. '.
. Industrial Ecology • . ;
Sustainable Development . - .
April 28 Last Class • . . •;
Course Evaluations __,_,, „, +.'
WMAC Assessment Report; at C.ourtalds Plant
Draft reports (reviewed) returned
May5 Final Assessment Reports Due • _ /„^rfa«•^..n*ld^
Group presentations of assessment reports (videotaped)
(aome students di4 a waste prioritization on report similar to
AICHE problem) ^ . . ,ae!_ '
Slides taken on plant visit, and shown in class
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• ENTDUSTIUAL WASTE REDUCTION
^ . i
1 Introduction, Waste Problem and Waste Reduction
2 Regulations, RCRA • ;
3 Regulations; CERCLA, SARA, TSCA, MARPOL, OSKA, KKTA
4 Field Trip to Landfill/Transfer Station •
5 Waste Reduction Approaches .
6- ' waste Reduction Assessments ' . • • • - :
7 Worker Safety and Health _._... \ . ' . ^ .
8 Mid Term, Papers Due • • . , :
9 Process Technologies • •
10 used Oil Regulations, oil Waste Reduction Technology . ,
11 Solvents and Coatings •
12 Rinsing Systems and Chemical Reaction-Regeneration ..
13 setting Up Waste Reduction Programs
14 presentations, Paper Due .- • -
15 . Final" Exam . . ' • .
Appendix • . • • ,
Selected Handouts' ' - . . ' •
' Publications Order Form
" . Readers Response Form
. •
• • •
••'.'•• u "''.'••.".'• i
' •
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CS-DUSTRLAL.' WASTE REDUCTION
' '
. -o'ri-- •— -ivies' ty course curriculum
r •• - r-so— <~r'SC— - . -"•— J — -3 -- •*
A w"~~~for er.Ylrsnaer.tal engineering .;
..• .
(course .Content •- _ , ow -of was-e" reduction concepts
This course serves as- an c./e v course covers waste
•••- and-;a=3li=^ior.s in Alaska and -^^ ^f technologies.; waste
radudtior. .concepts, audi ,, P-|;^ , use a-nd' di sp0sal; worker
.
- -ngth, for
.
; -.- three ..-graduate credirs. , - . ••-.-.•.-.-..".
1. , . . HOW to 'u^e-tliis- c^ricuiujricinauy produced in 1989. It does • not
- - - v
«on3 , ^ may no l^^^ iximfl^ »Ould be
cplicarions. F.or'this «»»"?' "?esses or students interested in
^^^rttSfon^snr^^ntact^rwaste reduction or pollut.jn
^e^enfion organizations in their. area.-
-
I. • Reading ' . ,"
II. instructor References
III. Objectives._ ;
IV. Class Activities
V. Homework •
Acknowledgements ,' . _ ^ _ f , t_: curriculum was .provided in
support -for development of tft-i c^ nAlaska Health •.Proiect
oart under a cooperative agreeBjnx c« Alaska .Department of
and the Pollution ^yd.d b?tti Source Reduction Recycling
ded b ta
.
and the Pollution ^jy;jViSd.d b?tti Source Reduction Recycling
Environmental Conversation funded by ta the u>s. Environmental
Technical Assistance Grant .(SRRTA^trom^^^^^ , Addit al
"*
ec .^^
Protection .Agency °f£ice. 0°fchf ^I"* stewart Mott Foundation. Dr
sn» a ""
-------
_ r-
•» aTT\ <**
d
?ro-
Reduction
•iofeer 1991
•horage
.a"-""
^ *T-5
• ^ ^* "* *
~
15 e
TV
•p.®
ies?
Syiiacus '
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I
I
I
1
bj ec-ives
'Describe the r.acr.itude and dangers of the waste/toxics problem
.I-r,~the*co'untry and state today, and ^describe the roie of waste
'reduction in'solving-the problem. -. .- -.,.
List and -describe the regulations governing . toxics use and '
disposal. ' • ' '.'.-' • .. '• / t • •
Describe the waste reduction hierarchy, -and'-list and explain
the advantages of waste reduction.:', ,;'.,' • .:
Describe the, steps .used' in ...conducting ' a 'waste reduction
assessment of a facility. , : , • -
Describe generic methods of'reducing wastes in" facilities, and
apply" those methods to specific examples. • .
0. Describe the basic'principals of'protecting workers 'from"toxic..
exposures, . and • describe .. the- relationship' between these
I principals and waste reduction. '• ' '
': ' '• - 7. Describe the. basic principles of process engineering, .'and
I apply t.icse principles in making calculations for specific
technologies. ' ' .••-'"'
1 • ' -' ' -8. Apply 'the-v .waste reduction, principles of product . life
' . extension, substitution, increasing efficiency> and in-plant
recycling' to oil manag'ement, -solvent usage, .coatings
'. ' ' manufacture /and application, rinsing,-- and- .chemical
I • reaction-regeneration.
: " 9. Describe the 'steps involved .in setting up .corporate and
(' governmental waste reduction programs. Describe both the
essential- elements'of these programs and. potential problems'
•, •' , ' • •; that must'be overcome. . • . . .
^The overall score for the course will be -.based on the
following:
Homework: 30%'-
Project:-, 30%
Exams: .' 40%
Proj-ect / . ' \ " "' '-^ i.'-
A technical p'aper is .required. The paper can either be a
.research paper'on some 'aspect of. hazardous, waste management or
waste minimization; --or it can be a .waste audit report of a
facility. The paper should be 8-10 pages, double spaced.
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I
I '""••'• •
Text ' ' -
|'ft's;t=^?si-r~ i;r. .-.sssssr.er.t ar.c Technclccv'Transfer Training Manua"
:,-.: I-., V?_i.77 Manual; ' University of Tennessee, Center for
Inr_--rial Services-, 19S9 '
• Supplemental Text
Hazardous waste Mini-i;ati;n, Harry Freeman., McGraw-Hill Publishing
Ccr.pany, New York, IS 90
^ Eandouts -"•,'' •, •
Profiting frsa Waste Reduction In- Your Small Busi-ne.ss. David
•Wiggleswcrth, Alaska Health Project,1938
Cisccsal Directory for 'Small Quantities of Hazardous Waste, Jim
Sweeney, Municipality of Anchorage, Solid Waste Services, 1989
_ • Vr.d^arstanding the Snail Quantity Generator Hazardous waste Rules.
M • A Handbook fcr Small Business, -EPA ~~'. L.
A Manual for the- Household Hazardous Materials Audit. Kristine
Benson, Alaska Center for the Environment, 1987 -
" videos and Slides . ' '• •
Hazardous Waste Reduction Potions-for Oregon' Businesses. Oregon
•Department of Environmental Quality. •
Less, is More: Pollution Prevention is Good Business. EPA
Challenge to • Innovation; Pollution Prevention bv Waste-
Minimization. 3M Corporation •
• • Pollution Prevention Pavs. 3M Corporation '
m 'Waste Reduction and Waste Management Slides, Alaska Health Project
The Song of the Canary. 16mm filar
I References , . •
Hazardous Waste Management. Charles Wentz, McGraw Hill Publishing,
1S89 . ' *'
Hazardous Waste Small Quantity Generator Workbook. Intereg'Group,
Inc., Chicago IL 60646 - .
The Lav-roan's Guide to the-Toxic Substances Control- Act. EPA
tP.rc'f it—from Pollution Prevention. Pollution ' Probe foundation,
Toronto, Canada - - ,
" ' Used Oil: Disposal Potions. Management Practices,' and Potential
•Liability, 2nd Edition, Government Institutes, Inc. 40 CFR, Parts
190 to 399
Alaska Job'Hazard Recognition Program. Alaska Health Project
_ ," Artist Beware. Michael McCann, Watson-Guptill Publications, New
| , York, 1979 • ' • •
Used oil; Disposal Potions, Management Practices, and Potential
L.iabil;ty, 2nd Ed-., Nolan/Harris/Cayanaugh, Government Institutes
I Inc., 1939
Used Oil Management in'Alaska. Alaska Health Project, .1989
Waste .Reduction Audit Reports. Alaska'Health Project (order form
included in Appendik) •
I . Iv •
I - ' . .
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F DISPOSAL OF HAZARDOUS, WASTES --
THE'RESOURCE CONSERVATION AND RECOVERY ACT ,*0
1. Identification/Listing of Hazardous Wastes.! \<- -.•*-;.
2. Generator Requirements-.,..... ••<•• -•••- "•".
1 3. Transporter Requirements. ; • <
4. Treatment/Storage, Disposal Requirements.................. • -- 6o .
' •' ' • •' • ' '' 68
5. Enforcement '; :-•.— •. -;' ••"" '•'". .'•'"
G CLEANUP OF ABANDONED AND,IN ACTIVE HAZARDOUS WASTE SITES -
' 'THE COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION,
. AND LIABILITY ACT — - ; • - -' 70
'• ' -72
1. EPA Response Authority..... • .— • '• • ; •""
' • : • . '','.''' - •' • 74
' '2. PRP Liability :—..— >•••• - — ...—• •-••-
3.' Private Party Cleanups..... • • •• • ' ' '
4'. Defenses .••.•••• ••••• ; " ......-,.•••••
" ' ' 78
'. 5. Release! Reporting.'....,...:.—.-- \....:.,...... - • •
• • • - , " • • : 79-
6. Enforcement ;••• •"•
H RESPONDING TO CHEMICAL EMERGENCIES-
THE EMERGENCY PLANNING AND. COMMUNITY RIGHT-TO-KNOW ACT.. SO
'-"„...-' • ..-. 80
1. Emergency Planning • —. • ;••;'.'
2. The Toxic Release Inventory (TRI) ,-..—. - ,.,..,.—.—-..-• 81
- • , - ' • • " • - -• 83
3. Enforcement : — '
LA PROACTIVE APPROACH TO REDUCING ENVIRONMENTAL BURDEN -
THE POLLUTION PREVENTION ACT .— — ; ••••••••• 84-
CONCLUSION: POLLUTION PREVENTION - IT'S THE BEST POLICY.
.87
.90
APPENDIX A- AN INTRODUCTION TO THE LEGAL CITATION SYSTEM.—-
" ' ' ' • 00
FEDERAL STATUTES.!..;— -- .....,..-.—-- -...-..--;
/ STATE STATUTES -<— • •' '•" ..,-..-.....- •
' FEDERAL REGULATIONS , — -• • ; : -...91
, . - • ». - •• . -.-,... ' 91
STATE REGULATIONS : : - • -; ' "'.':•
• ' " ' '91
FEDERAL CASE LAW —• — " '" :""
STATE CASE LAW .—.: - ••- "V '.
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p ^RT.; v - \IN E FEDERAL ENVIRONMENTAL STATUTES THAT
EVER1 CHEMICAL ENGINEER.SHOULD KNOW....,........:...,.' -. . •- •• :S
A. VrlE.\L\NXTACTLHEOFCHENnCAL5CBSTANCES"; - '
7riE> TOXIC SUBSTANCES CONTROL ACT . ,.,-.,: ••• ?9
' l. Existing Chemicals Testing.:...... ,..'....: :••••"• •'•' •.........: .*....29
'2. New Chemical Review , ;••'••••. : •••30
•3. TSCA's Regulatory Controls.'.. :.'—••• ;••••• ..;.....-,.........•-..••...-•....,31 ...
4. Information Gathering......: ' .......:.......,. ^2
• . 5.: Enforcement •••• '• > •. ;•••;
B. THE MANUFACTURE/USE OF PESTICIDES -
' THE FEDERAL INSECTICIDE, FUNGICIDE;.AND RODENTICIDE ACT 34
.1. Registration Requirements.: ••-, •-. ••-'..•••• • ^ •
' '•. • • • .2. Labeling • :-_••. •..':•-•••••• -. •••-. • : ^
O *T
3. Reregistration -...'.;.... • ....-.•...: ;..—••• '
4. Protection of Trade Secrets.. ••• ,...,.,..37,
- • 38
3. Enforcement.... ••• • • ••
C. THE REGULATION OF CHEMICALS IN THE.WORKPLACE - '. .
' THE OCCUPATIONAL SAFETY AND HEALTH ACT.......'. .........39
1. Workplace Health and Safety Standards :..' ; 39
2. Hazard Communication Standard.. •••'•••' • ; *
3. Recordkeeping/Inspection Requirements..... -..-'•• -—•;-• ; 41 ,
4. Enforcement......'....-.-. :••••• •• '••; : ' '"
D. AIR POLLUTANT EMISSIONS - . .
THE'CLEAN AIR ACT.... : • • '•••- • —' '43'
, i. State Implementation Plans........ • • .• ••••••; .•• • **
2. New .Source Performance Standards (NSPS)..:..----v • —- ^
' ' . • ' 47-
3. New Source Review •••• ' ;••— •
.'4. Hazardous Air Pollutants.. r • .; - "*
5. Permits.fof Existing Sources '. • •-.- • .....—• •••
• 6. Enforcement ..., ;•••• • ••• ••-,-
, E. WATER POLLUTANT DISCHARGES- ' .•
THE CLEAN WATER ACT., '» :,,'•• '•-•- •; • '•-- :"" ^
... 1. The Control of Point Sources..,. ,- •- • • •
2. Dredge and Fill Permits.......... •:••. :--"- ; D_
"3,-Discharge of Oil/Hazardous Substances •-.... ,....v...:....;.......- 58
' • . ' ' •' ' - ' ' ' ..59
• . ' 4. Enforcement ••••; : ••-.-•••••,•.
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TABLE OF CONTENTS
INTRODUCTION: THE BIRTH OF THE CHEMICAL AGE AND THE GROWTH OF
ENVIRONMENTAL LAW : 1
PART I - WHY CHEMICAL ENGINEERS SHOULD UNDERSTAND
THE HELD OF ENVIRONMENTAL LAW: 3
A.. ENVIRONMENTAL LAWS REQUIRE CHEMICAL ENGINEERS TO PERFORM
AFFIRMATIVE DUTIES AND, IF THOSE AFFIRMATIVE DUTIES ARE NOT
DISCHARGED, THEY AND THEIR EMPLOYERS MAY'BE HELD CIVILLY
AND/OR CRIMINALLY LIABLE ...'.. ..3
B. CHEMICAL ENGINEERS WHO UNDERSTAND THE ENVIRONMENTAL
LAW HELD WILL BE ABLE TO LOBBY FOR MORE EFFECTIVE "
' ENVIRONMENTAL LAWS AND REGULATIONS IN THE FUTURE- : '.......7
• C. CHEMICAL ENGINEERS MUST COMMUNICATE .WITH • •
ENVIRONMENTAL LAW PROFESSIONALS.. ....'. :......'..- "... 8
PART II-SOURCES OF ENVIRONMENTAL LAW:
LEGISLATURES, ADMINISTRATIVE AGENCIES, AND COURTS 9
A. LEGISLATURES .' '. .' .'...I..'. .10
B. ADMINISTRATIVE AGENCIES ...10
C. COURTS :..... , ... '. ......... 12
1. Role in Determining Coverage of Environmental Statutes 12
2. Role in Reviewing Administrative Rules and Decisions 13
' 3. Role in Developing the Common Law System :.. 17
PART III - THE LAYERS OF ENVIRONMENTAL LAW:
HOW THEY INTERACT TO FORM A TANGLED WEB OF REGULATION 21
v .
A. THE DOCTRINE OF PREEMPTION '. ..,..23
B. THE DORMANT COMMERCE CLAUSE :.: .- 25
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: ; . - . ABSTRACT. .-'•.."
This praocum is designed to provide'chemical engineers'with a general .
overview, of the field of environmental 'law':" .If is structured in four parts.' ;
Part I discusses specific reasons why chemical engineers should understand
environmental laws and regulations. Part H explains, the roles of the three
categories of governmental actors who define the field of environmental law:
legislatures, administrative agencies,, and'courts. Part m discusses how the •
environmental law that emerges from these actors operating at the federal,
state, and local levels interacts, and Part IV outlines the relevant statutory
provisions of nine federal environmental statutes. The statutes that will be
discussed in Part IV include the Toxic Substances Control Act; the Federal
Insecticide, Rodenticide-, and Fungicide Act; the Occupational Safety and . •
. Health. Act; the Clean Air.Act; the Clean Water Act; the Resource .
Conservation and Recovery Act; the Comprehensive Environmental . _
Response, Compensation, and Liability Act; the Emergency Planning and -
..Community Right-to-Know Act; and the Pollution Prevention Act.
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Original produced on Hammermill Unity DP,
a 50% post-consumer/50% pre-consumer recycled paper
made from de-inked old newspapers and magazines.
The National Pollution Prevention Center
for Higher Education
University o< Michigan, Dana Building ' . -
' 430 East University Av«'.
Ann Arbor, Ml 48109-1115 . i • ,
. Phone: 313-764-141,2 , •
.Fax:313-936-2195 . . ,••'_•'•
•'• E-mail: nppc@umich.edu. • '•
The mission of the NPPC is to promote sustainable development
by educating students, faculty, and professionals about pollution
prevention: create educational materials; provide tools/and
strategies for addressing relevant environmental problems; and .
' establish a national network of, pollution prevention educators.
In addition to developing educational materialsand conducting
research,.the NPPC also offers anjnternship program, profes-.
sional education and training, and conferences.
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, -t::n Prevention and
Ciiemical Engineering
A Chemical Engineer's Guide to
Environmental Law and Regulation
By Holly Lynch
Practtcum submitted in partial fulfillment of the requirements for the'
'degree of Master of Science^ School of Natural Resources and Environment.
University of Michigan, December 1994.
Practicum Committee: Assists^ Research Scientist Gregory A. Kioieian..
Professor Jonathan W. Bulkley.and Professor Robert H. Abrams.
'National Pollution Prevention Center lor Higner Education • University of Micnigan
Oana Buiiamg, 430 East University. Ann Aroor Ml 48'109-1115
pione: 313.764 1412 • Fax: 313.936,2195 • E-mail: npocaumicruJdu
May Be reproduced
freely for non-commercial
educational purposes.
Environmental Law i
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•-.6C-''5C' V, 3™ L. 31 • ' . • '•'.'' •
=•?-• •="3-i: Assessment Suicance for Superr^r.c:, -/cl-. I ana I!, Mar en : 353
Note1. ~r.s ic'cumer,: ,,s in..the Ui library government documents arc .r :,-,e,
'N'Eil ;icrary. I: may"be xeroxed; .it is not copyrighted. If you prefer; xerox
ccp;es will oe for sale at KJnko's in Moscow, at cost, approx. $30.00 and at
; IFGHE'. • (It costs $48 from NT1S). - • '.-'/- '" ' ' ' -
Computer Facilities.:' v . - - . • , /• '
Access to a DOS-based .(fully IBM compatible) personal computer for .
• modelling and risk, analyses using software-packages on fate and transport;
Access ,to"TYMNET-, • TELENET.'--InfoNet or CompuServe networks for using •"
. • EPA on-line data bases, • '- • , . .
Computer software and;on-line accounts will be provided. ' • ' -•'
• • Although no computer language experience is specifically required, some-
computer experience is desirable. The ability to.use.LOTUS 1-2-3,or a similar
. spreadsheet program-will aiso be helpful. , " '.-..'
Course Requirements and Grading: . ~- ,
••'.-'.'-. • : : '•'.-.. : . G- '••'• UG-" '
•; . G • . UG Video Viceo
Chemical Toxicity Review ..••--.'•• - . .. • ;
Presentation' , . . 10* • . • • 10**, r
Paper . ' 10 : 10 10 ,10' ,'
Case Study Critical Review • . ' • .
Paper ' • . - 10 ' '', . • 10 ' '
• Risk Assessment'Team Prefect < 30 30 > 30 " . 30 •-
Midterm Exam ; ': , 20 • 30 . • ;20 30-
Final Exam . • 20,' 30 20 30
G * Gr««u4tt ' - . UG *
. •»re»«nt»tion» will b« mdc't'a the el MS and wi
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= ~'CA cccif :; 3'rar.c ^azarccLS'/vas:es
Hvc-ccarccrs
c'rgarccxygen ccrr.counds
G'garcnr.rogen compounds
Organcnaiide compounds
Organcsulfur compounds
Organophosphorus compounds
RGB's, dioxins, asbestos
G. Medical Wastes
Biomedical wastes
Infectious wastes
111. SUPERFUND RISK ASSESSMENT
A. Hazard Identification .
, Data collection
Site characterization .
B. Exposure Assessment
Pathways identification
Fate and transport parameters & assessments
Intake estimations . •
Historical considerations
•>
C. Toxicrty Assessment (Using EPA on-line databases)
Toxicrty values for non-carcinogens •
Toxicity values for carcinogens
D. Risk Characterization '
Quantifying risks
• Combining risks
Uncertainty assessments
' Explaining risk
Site- specific considerations
E. Radiation Risk Assessment •
Principles of radiation protection .
Key differences from chemical assessments
-------
Cc-rse C-t
Over/iew cf numan' health evaluations ,' '
. 8as:c concebts in defining risk "
II. ; • BIOCHEMISTRY, CHEMISTRY, AND- TOXICOLOGY OF 'HAZARDOUS
MATERIALS ,
* f • ' • ' • . ' •
A. Basic Concepts of Biochemistry and Toxicology
, . -Cell- ^unctions and defense mechanisms- .. • . . • •.
., . Dose Response relationships •;.-;• . .
, • Non-carcinoge'nic. responses ' ' . '
Caranogenesis •• .: . • ' ...'••' ''..:'• .
Teratogenesis', Mutagenesis ."•••.-. . '
Toxicrty testing, -' • ' . • . ' . •
B. Chemical Hazards and Classification ' •• ' , - - • • '• .'
. . •..--• Properties of hazardous substances,
Chemical Classes . ••••..,-. .
Hazardous materials classifications
C. Chemistry of Inorganic Hazardous Wastes " • • '
Elements • . ' ' • . " • ' '.
Inorganic compounds ' • • .
Organometallic compounds . "
D. Toxicology of Inorganic Hazardous Wastes
Elements ' ". ;" ... : , -
" - Inorganic compounds .
Organometallic compounds .
•E. Chemistry of Organic Hazardous Wastes •
. Hydrocarbons .
Organooxygen compounds
: Qrganonltrogen compounds . "
' Qrganohalide compounds ' ' „ , / ,
• ', , Organosulfur compounds
,, • . ' Organophosphorus. compounds
PCB's, dioxins, asbestos ' . " ' ,''"••'-.'•
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^ • Spring 1991
* Engineering Risk Assessment for Hazardous Waste Evaluations
ES 404/504 (Ul)
I ENGR 599 (ISU)
I Instructor: Margrit vcn Braun
Chemical Engineering Department
g University of Idaho • ' . •
, FAX: 208-885-7462
I Phone: 208-885-7838
Meeting Times: MWF.7;30-S:2G.a.m.
Course Description: ' , • .
ft The cleanup of hazardous waste sites is largely driven
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.-.-t.or, -reveniion and
Chemical engineering
Engineering Risk Assessment for
Hazardous Waste Evaluations
Margrit von Braun
ES 404/504 £r EN'GRS99, Spring 1991
University of Idaho
fin Prevent Cimer lor H.gnsr bdu^nan ...yn.v^ty.o. M,=n,gan
. .
Dana Budding. *30 East: Unw yg.Ann Af
Pnone: 313.764,1412-Fax: 313.936.Z195 _
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: Tsxi; Effects
: . Tcxi: Responses
R-:.5ic Assessment' .
1. Exposure Mechanisms
'
2. S?;-:iM and RAG • • . '
Historical Exposures
:-• Case Studies
6. Data. Sources, Resources, References on toxicology and Risk
Assessment
Vasce Reduction
L. Overview of Waste Minimization
2. aenefits/Incentives/Sarriars/Cost. • •
3. Basic Elements of Waste Minimization
4, Implementation of Waste Minimization Program
5. Waste Minimization Assessments
5. Applications - Success Stories ; •
7. Resources & 'References on Waste Minimization
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•PLaase -s_::=i: ill hcsevo'rk ar.d exa^.s ta~ Marg-ri; ->sr. .Sra.ur. . ' iepartser. : c;
:'-a = :c al _-:r.g-.-aerir.g, Ur.iversir/ of liaho, Kssccy. :~ S23-2 This- v_i;
ensure rap-.d gradir.g ar.d re sum. of • your work. Also, include zhe STJ ; "
'::ur.5e Ho , C'i: -applicable) 'as well/ as the' 'University Course No. on all
— sever k and exams. You may Fax :aaterial-s to' save'' time . ' .
The e'xaas will primarily be. take-home "projects". ' .Closed -bo'ok portions '
of exaas say also be' given. Reading, ass ignaenss will be 'aiade chroughou:
che course . • • ' • • "''_ • • . ' ' ; .
Class Attendance: 'Students are .responsible for all material covered in
' ' ' 'class ..'-',''. . . ', •
. ' " . Graduate • . Undergraduate
Grading Polisv: ' Homework ' ' - ' 10% • .'-.'• 10%' . :
' --• . ' , . Two Exams . 40% •• ..-••' 40% '
Final Exam 25%.' ' ' •-..•" •' . - . 35% . '
•.-..'• Paper : . 25% - . . - - 15%' . - ' ' •
Course Outline: . • '.
A. Introduction . . •' -. '•-,.
. .. 1. Hazardous Waste Problem •: .
a. Scope ., ..' • ,
b. Historical Perspective
3. Environmental Legislation
1.. Media, Specific .Laws (CWA, CAA.. SDWA)
2.. Hazardous tfasce Laws (TSCA, RC8A/HSVA.
CZRCLA/SASA) . .
37 State Responsibilities . .• . _
• 4. £?A Structure and Organization.
C, ' RCRA Process .' ' i
1.. Definitions of Haz*rdotis Waste . '.
.2. Generator and T.SD Requirements
3.. Land Ban Issues ' -•
4. Resources and References .. ' ' . '
D. Superfund Process , .,.-. .. •
1. Sice Ranking' . -. . .
. ' . 2. RI/FS to. ROD . ' . ,
3. Community Right Co' Know '. .
. .4-. Toxic "Release 'Inventory • . -
5. Case Studies- :,. • ' '
6. Resources and References
£.. Environmental/Media Consideracions. . ,
1. Characterization and. Sampling .
, 2.. Focus on Specific Contaminants •
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J
I
ST-IAS'-S __
I for live, aicrowava. video and N.J students)
«~a ^—l T_.i~ - » ' ' v
•- -au-s. So- ES' 475/575 (TIL) • *"'• ?°"7" So:- -3 791'S
..*rs..._« » — • 6Q7 (1SU) .
* ' ^.->c« -Ltle: Hazardous Waste Management
- ' ......,.a,. Hargrit von Braun. Chemical Engineering Depc/
9 -S ----- **" university of Idaho, Moscow, ID 83843
' ' cAY ' 208 -885- '7462 ' ' •
t •_-. ^'^« H»u«: WTb»r 2:00 p.U. '- ":00 f ... «n* b,
....... ,.„.,....,... «..^ °n C^.^:' Wnmr 7:30-8:55 a... F.cific Ti..
. • •
^ired; ' Selected Reading, Materials (Instructor Packet)
: Standard Handbook of Hazardous Waste
D.sposalf Harry H. Freeman. McGraw Hi
' Avariety of additional course. notes will be supplied by the
instructor. .. . . , ' '
- • — g.flui.itM: Junior. S.nior or Graduate standing in engineering o
1 ' "7 '*--" scienc«. Appli«d Statistics. .
™ >-
i
Course
Honootk: ' ' To
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CE-:--I Pollution Prevention
Instniccor Dr. Roben B. Ppjasek
"'Spring 199 3
COURSE DESCRIPTION
menting techniques to reduce these losses at the source.
study and make recommendations for implementation.
-
review of the program.
COURSE SCHEDULE
INTRODUCTION TO POLLUTION PREVENTION
1 January 25, 1993
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.r.cer.:;'--i ic'tr.e -•'.'_-. rressures that have beer; brought to bear to induce facilities to place these practices in
r.ue No attempt 'A:;; be made to examine specific pollution prevention legislation or regu-
2. February 1. 1993 MANUFACTURING AND MANAGEMENT- ;
Emphasis in this course is placed on pollution prevention in' manufacturing. All
manufacturing categories have commonalities which, when recognized, allow the pollution
prevention praccioner to apply the concepts described in the previous section without regard
to the type of firm. Besides examining manufacturing, the manner in which manufacturing
is managed is a key to the successful implementation of pollution prevention. Analogous
management programs-(such as total quality management, just-in-time, and computer inte-
grated manufacturing) will be discusr-d ilcn'g with a model for manufacturing for competi-
tive advantage". . . : r
3. February 8, 1993 CORPORATE POLLUTION PREVENTION PROGRAMS
One of the term papers will have the student explore how companies plan, operate.
and sustain pollution prevention programs. • An important key to a successful program is die
recognition of the corporate culture. At various levels in the firm, this culture can vary
somewhat depending on whether one looks at the corporate organization, business units/
divisions, facilities or departments in the facilities. There is also the issue of the impact of
suppliers and customers in formulating a workable program to enhance competitiveness of
the operation. Analogous programs such as total predictive maintenance will be examined
to see how lessons learned will be applicable to pollution prevention programs.
4. February 17,1993 MAPPING A.MANUFACTURING PROCESS OR OPERATION
(Wednesday)
Mapping is utilized to help develop a picture of the process or operation being
examined. Resolving the differences between the way different people see the process and
• what is actually happening is a valuable activity. A variety of mapping and other visuali-
zation techniques will be evaluated along with analogies to road.maps and electrical schema-
tic diagrams. Using process flow diagrams to help understand process functionality is at the
heart of the descriptive approach to pollution prevention assessments. A variety of exercises
will be utilized to develop suitable map preparation skills.
5. February 22, 1993 CONDUCTING A FACILITY ASSESSMENT
To conduct a successful pollution prevention assessment one must learn to become
a good EXPLORER. Utilizing-prescriptive tools (i.e., checklists, worksheets, and question-
naires) for conducting assessments.have many problems associated with them. Process flow
diagrams-and materials accounting must be an important component of the assessment. .The1
difference -between materials accounting and materials balances will be explained. It is
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"r:~::^7:, Vry''VV^7:'..t^^t'oceraions'must' be identified and incorporated :.r.:o ^e'
s^s.'.-—--,•••-".• •~-^^t-'."1'-, F '• - ,. • • . -.„..'•
assessment. -'--.'-... .-•••.. • -., • • , . •
6. March 1. 1993 ,, . ,-IDEA TOOL BOX
' Total' auaiitv management aikother managementprograms employ a number of tools
".operations. • .•',•-. ' . ' . • . .
"'7. ' March 8, 1993 •-•\ANALYZINGINFORMATldN . .- ' ...'
An ARTIST takes information gathered from the assessment and dra^s picture^ wh
'8. March 15, 1993 ' THE FEASIBILITY STUDY . ,
•rnnrfuctin* the feasibility study is like being a JUDGE. Considering the specifics in
implementation program.
__ ___ •-' -SP?TTjrt BREAK
that are often considered in a pollution prevention feasibility study,
9 March 29 1993 OPERATING PRACtiCES/MATERIALS SUBSTTnJTION
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___ _ ,_ -i^'ed' -escs' '^ere ccad^c^c. Demacer.a.izr-or. •.$ oro:r.e: ::....
su = sV.:u::"iri that will be covered. TERM PAPER ON COMPANY P2 PROGRAM
TECHNQLOGY/RECYCLE-REUSE-RECOVER
DUE.
10. \zr.\ 5. 1993
Tec^olo^' can ranae from equipment modification and process' automation to quan-
P™ leaps in"the=manner in which an item is manufactured. Industrial ecology-is a term
u7e"d to examine the concept of recycling. There is often an overlap between recycling and
"eatrSnt ^acl of these considerations occupy alower status on the waste ^nagement
Shy covered in the first class. Sham recycling and'off-srte operations will be examined
along with the practice of waste exchange.
11. .- April 12, 1993
IMPLEMENTATION
Implementing the primary alternative selected in the feasibility study is often like
td W^IOR. Instead of fighting, to get something implemented, teamwork.
Sgradon and a good feasibility study should help .facilitate project and program
implementation. ' ;
12. April 19, 1993
'No Class
This break will provide an opportunity to complete the pollution prevention projects
which are DUE at the next class.
13. April 26, 1993
DESIGN FOR X
It is always preferable to design pollution prevention into new processes and
SsLdforthefoUowingtenns: «vi««^«^2^2^
^^ i
o an old wnchIs taken on new meaning by including «J^£J^-
operations from the extraction of the raw materials to the ultuna^disposmon of ^e final
14. May 3,-1993
COURSE WRAP-UP
Each of the important lessons learned about the manufacture of paints, adtesives and
coatings will be utilized to design the coatings manufacturing facility of the future.
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COURSE INFORMATION
Seat of the Pants" bv
Oeck
AdditionalTeadrng material will be handed out each ** fa class along with the home.
work assignments. . ... -.-'•. '•
information/ • ' .' ' ...
student as a result of the class discussion, . '. •
Each student will receive a letter grade based on .the following componen^:
1 Pollution Prevention Project-Term Paper = '40%'
Group Report = 25% of grade
Individual Report = 75% of grade
2 Critical Review of Corporate Program = 30%
Group Report = 33% of grade
Individual Report = 67% of grade
3 ..Homework: Approx. six assignments = 20%
4. Classroom Participation « 10%
Each ''dm will taHn prompUy at 6:30 p.m. on *. da«s indicated
above and will end at 9 p.m.
01890 (617) 721-4097 (voice ^ mail). His fax number is (617) 721,4073.
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;,-: or, Prevention and
Cremica! Engineering
Hazardous Waste Management
Margrit von Braun
ES 475/575 i* Engr 607, October 1990
University of Idaho
Naoona Pedunen Pr.v.nt,on ewitf 'or H,gn.r Eouoinon . unwmiiy oi M.enigan
Sana Bu.Sd.ng, 430 East un.v«r»,ty. Ann Aroor Mf 48109-mS -
P«on»: 313.764.1*12- Fax: 313.93C.219S
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• . .-. -CHE5^U: 5
' :- y.,^-;. 0^r:a
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• •_•••. : - :r or.rai Management '•:-.
' CHE f1^ O: Spring-11'
p, ,-,_, r, - ~r M .--- 0-.e:^i- Dr Chn<::,ne 0"
k ...^ .„ .e.^; :.- j-,e for c'.iei-.ucaj en,gvnee;s and non-:-bem
c-feic?n;cr.'. of strategics for pollution pr.cvcnhan
pc!.::es, reguianon in addition to case studies to
poi'.ucior. prcver.Lon.
Course Objectives: '
CHC 5>5 0 focuses on the design of Andus-tnal processes
ci'c-mcal vtaMe producaon. T>»e first pan of iJic course will de
oreanization of current pollution prevention ettom, Vve
I'j'sreaw the important aspects of these ettorts. The secoi
descube .-urrent research efforts in the ai'ea of wa«e mmmiiza
The third portion of the course will cover- product lite cycle ,
L'jese ideas to the design of more, efficient processes, The
mwesscs and improvement of existing processes w.H.t
WelManager In addition, uhere w,ill Lxr speakers fiom i
problems associated *iih pollution prevention.
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and.
ChemicaJ Engineering
Advances in Pollution Prevention:
Environmental Management for the Future
Michael Overcash and Christine S. Grant - • ..
' CHE 598'O, Spring 1993 .
, .Vortit Carolina 'State University' ' ' •'.
National Pollution Prav«ntion Cenwr for Hignsr Education • Univefsity of Michigan . - - • .- • •• ,1 • 5cloDer .994
DanaBuilding, 430 East University. Ann Amor Ml 48109-1115 : ' .
P.none: 313.764.1412-Fax: 313.936.2195 ' '.''..' . . • . •. • • .:-
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"ChE--iS6 Handouts- ••
• Portion Prevention: Engineering Design at Macro. Meso and Microscales-.
D.T. Allen, page 251-323.; ' V" • . ;: ' ' ; ' -
Life Cycle Design Guidance Manual. , _'•
-EPA Jan. 1993; G. A,Kesleian , ; •
EPAV600/Rr92/226 -Contact EPA, Cincinnau, OH 45268
• ' '
3. Facility Pollution Prevention Guide '•
EPA/600/R-92/088 ' '
513-569-7562-R&D
'
-. : •. • •- . • ,. • .
.^°LJfe Cycle Assessment; Inventory Guidelines and Principles, February »95
' • A EPA/'600/R-92/245
'pollution Prevention for Chemical Processes,
David Allen and Kirsten Rosselot. ,,-•
.Hazardous Waste Research and Information Center
One East Hazelwood Drive ,
Champaign, Illinois 6.1820 . • •
August 1994 .-
" t • Other References
1. New book by Alien - to be published in 1995. as yet untitled.
2..-. Application of Hazard Evolution Techniques to the Design of Potentially Hazardous
Industrial Chemical Processes. , , . . -
'•..-' H. R. Koyianian,« aL, Gal ^te,. Long.Beach, March 1992. : :
3. • Sustainable Development by Design. , . '
Review of Life Cycle Design and Related Approvals.
G. Keplean and p. Menery. ' - •• .
Air and Waste, Vol. 44, May 1994,645-688 . ' ; . ,
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.he nazcps proceciire will reviewed and there will be some use of computational ah a
on PC —DiTiins.' . ' " , ' • . - •
The overall design will • be reviewed from an economic point of view. Is the
environmentally benign plant more expensive and less economic than the standard plant or when
all things are taken into consideration is the economically benign design the most economical?
Week 15: ' ' .. .
Will be taken up with the review and finalization of the prepared process plant desisn in
the form of a report to be given to the department. These are specific references available
including books and articles and the overall results of the study sho'uld be an u'nderstanding'on the
pan of the student of the way in which, a plant can be, designed which is efficient, economic, and
compatible with the environment to maximum extent that is feasible .and by here we mean, by
feasible, within the reasonable limits of cost and efficiency that will still allow the plant to operate
'in a successful manner.
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- -— -- -r.ocec^=s to-minimize effluents. After the potential ernuents_ha%'e- oeen ident-ec;
, _..ew "f'Vdesien should be undertaken to see if some of these effluents can be minimized or -
••^I^^n For example in case a plant is producing a byproduct material because of impurities
in ^'feedstock, consideration should be given to using a more pure feedstock and thus minimize
orod-'ction of that particular byproduct unless the byproduct has an economic value. Sometimes it •
?s possible'to reduce effluents by providing internal recycles within the plant. Either gases, -
liauids or- solids can be recycled within the plant in order to reduce as many, effluents as possible.
Mother practice that can be investigated, is to determine the most efficient processes that can be _
us-d within the economic constraints of the process. A process which has a conversion, eve of
90% and a selectivity of 85% should be compared with another one that has a conversion leveot
•95% a^d a selectivity of, say 80% to see which one provides the best utilization of feedstock and
minimizes the production of unwanted effluent. • - ._ • . •
Week 6: ' ' •• . . ' .. ' • .' - : • ' - .' '
' Minimizing energy requirements. One of the major influences an' operating plant has.on-;
the envtonrSn is due tfthe quantity of energy that must be consumed or disposed of, A-revtcw
of theSm of the plant taking into consideration second law thermodynamic considerations can
' sometimesDeduce or pinpoint those areas utilizing-or requiring the greatest consumption o
enWThe heat recovery systemcan be subjected to pinch analysis to make certain that the most •
Sve use of cenain that the most effective use is being made of the energy which is input-to ,
theTlanl Some modification of'the organization of the heat exchange circuits frequently results ,n
sigmficant.savings in-overall energy requirements. ' , . .
' The study should include alternate process strategies making use of heat pumps, extensive
, waste heat recovery, and utilizing wasteTstreams within the facility in order to provide a basis for
' the unit to operate in as efficient a manner as possible. .^ . .
Week?- 11:/ . , •".' ' " • ' "•' "-•'-.'..
Detailed design of a'selected: process plant using advanced environmentally efficient
systems. A specific project will be selected to be carried out by student .groups.uangI taowj-
cou^e WU take at.least 40%.of the total time involved, but will account for at least 60% of the
overall grade. . - .• •
'• Week 12: . • / . V ' ' * " , • .. •
,^^^±riff^^^^t^S
arise if the pLtJere operated in an improper manner or if the plant-should, for one reason
'or another, fail. ' '. • •"•-.' -'..'•
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1 . ChE 486
Some Additional Notes
Week.l:
Dunn'" the first week 'we wiU discuss basic environmental considerations for process
plants Included in these discussions will be those things which are needed for proper siting, cue
trials that are required to prepare a suitable environmental impact statement some knowledge
S S tions whic'h will be required for guidance from the federal, state and local aufcormes;
a^d if addition we. will, discuss how process plants and the environment in which the process plant
has been placed behave as a closed system.
Week 2:
Sources of pollution hazards and nuisance as well as neighborhood problems chat must be
considered in process plant design will be discussed. Of course one of the major things to worry
about ^ wast'e materials that would be coming out of the facility which might in some manner
emer the surrounding air, groundwater, wastewater, and solid waste disposal requirements.^
Sting should take place early on in the design of the plant and in us first material balance
consideration. •
Once a suitable block diagram for the plant has been settled, a quick review should be
made of the potential hazards and safety requirements for the unit. This would mean some kind of
pTelirnlnary nn through of the steps involved in the process and those areas where conceivably a
hazard or a safety problem could occur.
We must also review the particular environment where the plant might be located. It is
clear that if the plant is going to be located inside of an exist*ng chemical or^petroleum facikty. the
situation is significantly-different than the case where the plant would be located on what is
' co^onlv cS a ^sroots base" where there is no infrastructure or where the local ex1Sung
infrastructure may not be designed for the presence of a chemical operating facility.
Weeks 3 and 4:
The basic design procedure which wili be followed is similar to that used for the ordinary
plant design course. The first step would be to prepare an overall material balance using he
principles of stoichiometry and other requirements to make certain that we take into consuieration
PaU of the feedstocks and the products which would be coming from, the facilitj^ One a ba*c
stoichiometry has been made, overall material, block diagrams and energy balances can be
' prepLred Se doing this the specific sources of effluents which would be generated by. this plant
can be identified and listed.
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2.5' AnpLicaDoa 'Of. ar.alys;'s.'-'syszerhs. Microscopies, rcesoscopic ar.i
nucrcscepic pollution'systems analysis
3.0' Review of Basic Design Procedure for Process Plants •
3.1 'Overall Material Balances. . .. •'"'.''
3.2 Basic Stoichiometry . • .• •_
3.3, Overall Energy Balances , " . .
3.4 Specific Sources Of Effluent-Problems ' • • •
4.0 Design Procedures To,Minimize Effluents '
4,1 Internal Recycles ; . ,'.";.. •
.4.2 Use Of Most Efficient Processes ; • , ..'.-..-
4.3 Selection Of Raw Materials . . . - •
5.0 Minimizing Energy Requirements ..'.'•• . " •" . .'".'.
. ' 5.1 Second Law Of Thermodynamics Considerations ,
52 ' Pinch Analysis For Heat Recovery . . , ;' ; • . . ..., .-
5.3 Alternate Processing Strategy tlsing Heat Pumps, Waste Heat Recover/,. :
, ..' Internal Use Of Waste Streams, ' • . .:, ,. ' '
Design Of A Selected Process Plant Using Advanced,Environmentally Efficient _
' '. Systems. The'design-project will be carried out by student, groups using-
preselected industrial processes to .arrive ar improvements in •-overall _;•
. . environmental impact, this pan of the course will count for 60% of the overall
- .- 'grade. '.'';' ' • . ,-
12 , . 11.0 Analysis Of The Chemical Process Plant To Elimi-nate Potential Hazards ,
From Improper Operation Or Equipment Failure.
13 12.0 Study of Hazops Procedure Including The Use Of Computational Analysis-
„ On PC Programs . . ' . • •
14' • 13.0 Economic Aspects Of Environmental Benign Design : .
15 ' 14.0 Review And Penalization Of The Prepared Process Plant Design
16 ' 15.0 Final Exam. .'.•... ••-._-. . ' •; .
Textbook: Plant Design and Economics by Peters and Timmerhaus. .
•'•.".. '• -Selected publications of AIChE including Hazard Operations Analysis, Design of
Pressure Safety Systems. ' , - , . '
' - ' Conceptual Design of ChemicalProcess by J. M. Douglas; , .
... .' Specific Handouts for Federal, State and Local Regulation of Effluent Control.
Final Grade: Project:^60%, Homework and OccasjonarQuizzes: 10%, Final Exam: 30%. '
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(.'hE-4S6 - Design of Environmentally Benign
Chemical Process Plants
Course Svllabus
Ins—jctor. Dr. Ronald G. Minet, Adjunct Professor
William Onstot, Teaching Assistant
Ir.rroduction: " ' .
The Chemical Engineering curriculum includes a Capstone Design class, Chemical
En=nneein°- 480 which reviews the various components of chemical engineering and combines
them itTa final design problem illustrating the application of various specialties to a realistic case
which includes material and energy balances, equipment design and selection, capital ar.a
operating costs, economic considerations and optimization studies. . '
In the environment climate existing in the world today, the chemical engineer, involved-in
process plant design must include detailed analysis of pollution control, effluent handling and
hazard potential in the context of completing the design. Thus, the ChE 486 course describes a
design course for chemical engineering seniors or graduate 'students which will equip them to
beco'me professional chemical engineers with the disciplines necessary to design ar.
environmentally benign process plant. . -
Prerequisites for this course include knowledge of chemical process design, physical-arid
organic chemistry, unit operations and economic analysis.
Texts used will include handouts from EPA and other sources and the texts used for ChE-
•480. • . .. . : '
WEEK and TOPICS . •
1 1.0 • Basic EnvironmentalConsiderations For Process Plants
1.1 Proper Siting ' ,
1.2 Environmental Impact Statement
1.3 Appropriate Regulations: Federal, State, Local
1.4 ' Process Plants And Environment As A System
• 1.5 ' Life Cycle, Industrial, Ecology,.Waste Audits-and Emission Control
2 2.0' • Sources Of Pollution, Hazard, Nuisance And Neighborhood Problems In
• . Process Plant Designs .
• • 2.1 " ' Air, Water'And Solid Wastes ,,
2.2 Hazards And Safety •
2.3 Compatibility With Natural Environments
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••,.: :~. -'=;.ert;.on and-
Chemical Engineering
Design of Environmentally Benign
Chemical Process Plants
Ronald G. MLnet
'A'inrsr 1995 .
University of'Southem California
' National Portion Prevention Canter for Higner Education • university o( Michigan'
Oara Bu.i3:-g. *30 East Univers,;y. Ann ArB,ar Ml 48109-1115 ,
P-.one- 313 "64.!412- Fax: 313.936.2195 . . . '.
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;.\7rvOpLCTION: THE BIRTH OF f HE'CHEMICAL AGE AND THE1 . ;
'GROWTH OF. ENVIRONMENTAL LAW
'•Erv.rcrmentai law emerged as a formal field of legal study .in the 1972s.
3efcre then, the field'was limited, for the most'part,1 to common law causes',
of'action.2 Over the last 20 years, .however, the environmental law field3' .
has-burgeoned in response to the "chemical age" and the recognition that- •
chem'cai releases' into the. environment can pose a threat to the public's health'
and safety,4 ' / ' •
Currently, the environmental law field consists of approximately 20 major
federal statutes,3 hundreds of state statutes and local ordinances, thousarids of
• V Environmental statutes existed prior to the 1970s (e.g.,:'the 1899 Refuse Act),- however, the ' .
statutes were,-for the most part, antf-litter ordinances that contained..little, if any, "teeth" in •
terms of enforcement. ' . • ., .' . ' . . '
: A cause.of action is an occurrence of facts for which the legal system provides redress. Common
law causes-of action will be discussed in depth'in Part ID however, as an introductory matter, ,
.common law is made by judges as opposed-to legislatures or administrative .agencies.
3 The term "environmental law field" refers to the'system o'f statutes, regulations, guideline's,
and judicial determinations1 that are used to protect the environment'and the 'public's health •
and safety. T. Sullivan, Basics of'Environmental Law, in Environmental-Law,,Handbook 1 (12t£
Ed. 1993)! . ' ' ' \ . . - . , :, • ' •
4 For example, in 1980, the Comprehensive Environmental Response, Compensation and
Liability Act '(CERCLA) was enacted to clean up abandoned and inactive hazardous waste sites
in the aftermath of Love Canal - a waste site located in upstate New York that resulted from a
company's improper disposal of chemical wastes. The Emergency Planning and Community . •
RighMo^Know Act (EPCRTKA or EPCRA) was passed in 1986 to respond to a 1984 incident in •
' .Bhopal, India that killed 2200 people and injured many more when a Union Carbide facility
released methyl isocyanate into the atmosphere.
5 The major federal environmental law statutes are: the Federal Insecticide, Fungicide, and
Rodenticide Act, 7 U.S.C.A. §§ 136 t«rJ36y (West 1980 & Supp. 1994); the Multiple-Use
Sustained-Yield Act, 16 U.S.C.A. §§ 528 to 531 (West 1985); the Toxic Substances Control Act, 15
U.S.C.A. §§ 2601 to 2671 (West 1982 & Supp. 1994);.the Coastal Zone Management Act, 16
U.S.C.A. §§1451 to. 1464 (West 1985 & Supp. 1994); the Endangered Species Act, 16 U.S.C.A.
§51531 to 1544 (West 1985 & Supp. 1994); the Surface Mining Control and Reclamation Act, 30
" U-S.C.A. §§1201,1202/1211,1221 to 1230a, 1'231 to 1243,1251 to 1279,1281,1291 to 1309,1311 to
1316 1321 to 1328 (West 1986 & Supp. 1994); the Federal Water Pollution Control Act "The
Clean Water Act"), 33 U.S.C.A. §§1251 to 1387 (West 1986 & Supp. 1994); the Marine
Protection, Research, and Sanctuaries Act, 33 U.S.C.A. §§ 1401 to 1445 (West 1986 & Supp. . '
" 1994); the Oil Pollution Act, 33 U.S.C.A. §§ 2701 to 2761 (West Supp. 1994); the. Public Health
Service Act ("the Safe Drinking Water Act"), 42'U.S.C.A. §§ 300f to 300J-26 (West 1991); the .-
National Environmental Policy Act, 42 U.S.CA, §§ 4321 to 4370b (West 1977 It.Supp. 1994);
The Solid Waste Disposal Act (including the Resource Conservation and Recovery. Act), 42
U.S.C.A. §§ 6901 to 6992k (West 1983 & Supp. 1994); the Clean Air Act, 42 U.S.C.A. §§ 7401 to
7671q (West 1983 & Supp. 1994); the Comprehensive Environmental Response, Compensation,
• and Liability Act, 42 U.S.C.A. §§ 9601 to 9675 (West 1983 & Supp. 1994); the Emergency. ^
Planning and Community Right-to-Know Act, 42 U.S.C.A. §§11001 to 11050 (West Supp, 1994);
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:?--::. ar- ^:^:= :c^u.a::ons,~ and ir-r.urr.erable federal and scare court case;
,-rd -j-rr.r.iitra::-. e ad;udica-;:or.s. Together, these pieces compose a complex
ir- ;.r,:u;:r,g web of regulation that anyone who works with chemicals, .
rr.cst r.Jtabiy chemical engineers, should understand. . , -
This guide is designed to provide chemical engineers with a general
overview of the field of environmental law. .It is structured in four parts*
Part I discusses specific reasons why chemical engineers should understand
environmental laws and regulations. Part II explains the roles of the three
categories of governmental actors who define the field of environmental law:
legislatures, administrative agencies, and courts. Part HI discusses how the
environmental law that'emerges from these actors-operatir • at the federal-
state, and local levels interacts, and Part IV outline's the relevant statutory
provisions of nine federal environmental statutes.
The statutes that will be discussed in Part TV include, the'Toxic'Substance '
Control Act; the Federal Insecticide, Rodenticide, and Fungicide Act; the •
Occupational Safety and Health Act; the Clean Air Act; the Clean Water Act;
the Resource Conservation and Recovery Act; the Comprehensive
Environmental Response, Compensation, and Liability Act; the Emergency
Planning and Community Right-to-Know Act; and the Pollution Prevention
Act. These statutes are the most important federal statutes for chemical
engineers to understand because they represent the core of .the federal scheme
that regulates the manufacture, use, storage, discharge and disposal of
chemicals into all environmental media — air, water, and land.
This guide's primary focus is at .the federal level and; in particular, on
federal environmental statutes.' This federal focus is valuable because the
federal laws have national scope and, often, serve as models for state
environmental statutes. However, when reading Part IV, remember that
state statutes and local ordinances, federal and state-regulations, and federal '•
and state case law also contribute to the environmental law field.
the Pollution Prevention Act, 42 U.S.C.A. §§.13101 to'l3109 (West Supp. 1994); the Federal
Land Policy and Management Act, 43 U.S.CA.'§§ 1701 to 1784 (West 1986 '& Supp. 1994); and ',
the Occupational Safety and Health Act, 29 U.S.C.A. •§ 651 to 678, (West 1985).
0 Federal regulations are compiled annually and published in the Code of Federal Regulation
(CFR). Currently, the CFR contains over 196 paperback-volumes containing more than 122,096
pages. The CFR contains 60 million words - 70 times as many as the Bible and 60 times as many
as the complete works of William Shakespeare! B. Schwartz, Administrative Law, §4.3, at'
•16S (3rd Ed. 1991). '
' -2'
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rA-T.; „ is K^i CHEMICAL ENGINEERS SHOULD UNDERSTAND THE
FIELD OF ENVIRONMENTAL LAW • "' •' '
' Chemical engineers should understand the field of environmental law? '.
;'~ three'reasons: >1) environmental laws require chemical engineers to ,
perform affirmative duties and, if those duties are not performed, chemical
engineers and the firms for which they'work may be held' civilly and/or . . •
criminally liable; (2). understanding how environmental laws and regulations -
are enacted, promulgated, and structured will allow chemical engineers'tq%
lobby for more effective laws and regulations in the future; and (3) in their
increasingly regulated work environment, chemical engineers must
communicate with'environmental law. professionals and knowledge of
environmental laws and regulations, will facilitate such communication. .
A. ENVIRONMENTAL LAWS REQUIRE CHEMICAL ENGINEERS TO
PERFORM AFFIRMATIVE DUTIES AND, IF THOSE AFFIRMATIVE
DUTIES ARE NOT DISCHARGED, THEY AND THEIR EMPLOYERS
MAY BE HELD CIVILLY AND/OR CRIMINALLY LIABLE
. ' . • ' / ,,.
Environmental statutes require regulated entities to perform affirmative
duties and chemical engineers may be the individuals who are responsible for
performing those duties for their employers. For example, the Clean Water
Act, requires any entity that discharges pollutants from a point source7 into
the navigable waters! of the United States to. apply for! a national pollutant .
discharge elimination system (NPDES) permit.8 In many firms, chemical
engineers are. the persons who are responsible for securing such permits.
'. The common law system of environmental law also establishes affirma-
• tive duties with which chemical engineers must comply.. For example,-the
' common law requires individuals to act reasonably when acting in ways that
7 A point source is defined as "any discernible, confined and discrete conveyance, including but
not Luted to any pipe, ditch, channel, tunnel, conduit, well, discrete .fissure, container, rolling
stock, concentrated animal feeding operation, or vessel or other floating™.*
,
pollutants are or may be discharged." The term- "does r^t^S?^ I cTsi362(14)
discharges and return flows from irrigated agriculture." CWA §502(14), 33 U.S.C.A. §1362(14)
(WestSupp: 1994). '.•..' . ; • - • '' '
? CWA §40i 33 U.S.CA. §1342 (West 1986 & Supp. 1994),
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.._ . ____ •:.--:« [; ur '..- dividual 4ce5 "oc dc: reasonably and, his or r.er
--..-., •- •- e acr.cr.s cause another person harm, a common law action of
-c- --^-ce ' mav be cursued by the injured party. Chemical engineers, _
therefore must act- reasonably when performing their professional duties.
[f a chemical engineer does not perform the affirmative duties, that are ,
mandated by environmental statutes and the common law, the chemical
engineer and his/her employer may be found civilly or criminally liable9 in.
a court of law.10 Actions may be brought by injured parties,11 government
officials, or private citizens12 in certain cases. For example, an unpermitted
discharge of ppllutants from a point source into- the navigable waters of the
United States or an exceedance ofanNTDES permit limit both constitute '
violations of the Clean Water Act. Similarly, if a chemical engineer does ;
not act reasonably (e.g., if he acts carelessly) and his action causes damage to
• another person or to his/her property, the chemical engineer may be liable
1 for a common law violation.
Violations of environmental statutes and the' common law trigger a
variety of civil actions. For example, the CWA empowers the administrative
agency that implements the Act13 to issue an order requiring a violator to
cdmpiy with the Act14 or to commence a civil action in a federal district court
are the negative consequences of failing to comply with laws-and regulations.
» range from "traffic ticket"-tvpe administrative fines to crirrunal prosecutions.
l2SL and Enforcement, in Environmental Law Handbook, supra note 3, at 42.
' 0 Acuons are brought in civil court by the harmed party (the "plaintiff"). Cml actions award
mane a^ damages and sometimes provide nonrnonetary remedies, such as injunctions - judicial
Sder latTroh bi^e p^rty that is allegedly harming the plaintiff (the "defendant") from
^SiTftShaim. Civil i remedies seek to restore the plaintiff to a pre-damage condition
SS med "compensatory" damages. Actions are brought in criminal court by the prosecutor
S * Sor dSSc^wLreV criml occurred. Criminal remedies seek to purush the criminal
actor or deter further criminal action and usually consist of monetary fines or , ail time^
» Plaintiffs usually have to prove that they have suffered some physical mjury to their
person opro^Vb«fore they can bring a legal action; however, some actions can be brought
even S noPphy7S injury has occurred* The violation of a statute is. often actionable even if no
often contain "citizen suit" j
P8A? Spleme^ung agency can be either the United States Environmental Protection Agency
or rs'a^environmentll agency in states that have authorized state programs. See CWA
P(tA 33 V 5 C A S1342(b) (West 1986 It Supp. 1994). • '
eLordefs are termed administrative "compliance orders." The determination of whether
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•--•-;:::-";: -.'AT. a .racuitV.." - - SirruLariv. if ..a person is harmed by a chemical
er sneer's unreasonable.-actions ;:.£., negligence), the person can-file a
--men law suit against the chemical engineer seeking money Damages in
a state court l°
The Clean Water Act also allows criminal penalties to be imposed, in .
addition .to- civil penalties, in certain cases.17 Similarly, the common- law.
system allows- punitive .damages18 to. be -awarded in certain- civil cases (e.g., in
.trespass, nuisance, and toxic tort actions) if the facts suggest that the defendant.
acted with wilful misconduct (e.g., an intent, to cause the plaintiff harm) or -
with recklessness (e.g., a disregard for-human life).19 Criminal penalties and
punitive -damages, are intended, io deter non-compliance and.punish .
defendants'who act knowing'that the! action will, or is likely to, harm others.
Corporate- officers may be held civilly and criminally .liable under :
environmental statutes and 'common law causes of action for their own .
individual acts (e.g., if they dump toxins or order others to do,.so in violation,
of a statute or if they breach a duty that is imposed by the common law, such
as the duty to act reasonably) or for the actions of others that take place within
their area of corporate responsibility. For example, i£ a-violation occurs from
an activity over which a corporate officer has managerial control, the officer
may be held liable for failing to discover and correct the violation or for
failing to provide adequate supervision that would have prevented it.
a violation has occurred is.made by the agency - not by a court. To counter any bias, most - • • ,
< administrative remedies are .renewable in a court.of law. Judicial review of administrative
actions will be discussed in Part II. • . .
13 CWA §309, 33 U.S.C.AJ,§ 1319 (West 1986 & Supp. 1994). ,; -
16 The common law system is a state-based system of law. Each state has a "different common . .
law system, consisting of different cases and different precedent (prior judicial decisions). As a
result the facts that give rise to a nuisance action under one state's common law may not be
sufficient to constitute a nuisance action under another state's common law. Federal courts do not •
have jurisdiction to hear common law claims unless a federal question is raised. Federal ,
questions 'include cases between states (e.*., New Ybrk v. Connecticut), constitutional questions
(e.g., interpretation of the First Amendment), and casea that arise from questions of federal law
• (e.g., interpretation of federal statutes).
17 See Section IV for the enforcement provisions of the Clean Water Act.
18 Punitive damages do not serve a compensatory purpose («.e,they are not intended tarestore
a plaintiff to a pre-damage condition). Rather, they are intended to punish the defendant.
19 These common law actions are termed "intentional torts." The plaintiff does not have to
prove, however/that the defendant had a subjective 'intent to harm the plaintiff in order to
win at trial. • • ' •••' ••.","•'••'
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T'.'r :.~~ :r .JT.V ;Vi:e~ also holds employers liable ror the actions-of •'
AT. ••. eri 'A'r.er. the employees are acting within the scope of their err.pley-
r-e-- ---.i .; termed "vicarious" liability.--' For example, if a chemical
engineer is found to have acted negligently while performing his work
duties, his employer will automatically be found negligent and liable for any •
harm that the employee's 'negligence may have caused. Liability, is imposed
on the employer even if the employer can show that it acted reasonably.21
Vicarious liability usually results in the employer being sued because the
employer often has "deeper pockets"22 than the employee. If a plaintiff wins
at trial and an employer is forced to pay the plaintiff's damages due to an
employee's actions, the employer has'a right to sue the employee for
indemnity (i.e., to sue the employee'for reimbursement of the cost of the
plaintiff's award); however, since the employee usually has limited assets, .
the employer's indemnity right is often meaningless. ' • •
Failure to know what the law requires is not a defense in an
environmental enforcement action. Understanding what the law requires
will enable chemical engineers to attain and maintain environmental
compliance and, as one commentator has noted, "aggressive compliance is
the most effective protection."23
Chemical engineers are also expected to comply with ethical duties that are
outlined in the'1977 version of the Canons of Ethics of the Engineers' Council
for Professional Development. A Fundamental Canon is that engineers .
"should hold paramount the safety, health, and welfare of the public in the
20 Vicarious liability, also termed respondent superior, was based on the master-servant
relationship where the master controlled the servant's actions. In such cases, it made sense to
hold the'master responsible if the servant acted in ways that harmed others.
21 Because'the defendant is liable regardless of his or her individual fault, this liability is
termed "strict" liability. Vicarious liability is also joint and several. Joint and several
liability is a legal construct that imposes liability on two or more individuals for the same
injurv' It is used in cases where it is'extremely difficult to apportion liability among many
potential defendants. Under joint and several liability, one defendant may be held liable for
the entire costs of a legal action even though he/she may not have been responsible for the
entire harm. The premise is that, in imposing joint liability upon several defendants, the
defendants, who are presumed to have more information than the plaintiff, will come forward
with information that will prove which actor is truly at fault. Joint and several liability a
used to impose liability under some environmental statutes, most notably CERCLA (see, infra).
2- "Deep pockets" is a term that is informally used to describe a defendant who is financially
•sound - and, therefore, able to pay a damage award. ,
23 T. Sullivan, supra note 3,' at 40.
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er'- .:_r~i~:-a. ^r.v .requirements is consistent vvich that canon, • • -.
A'.:rou^;h the breach of an ethical duty does not give rise to a cause of
- ---en that can be enforced by the courts (unlike violations of environmental •
statutes or the common law), the engineering profession is in the process of
establishing1 a'single code of ethics that will guide individual action and
provide a basis for developing detailed'guidelines for enforcement, by the ;
profession.^ ^ : . • • _ - • • • " • • • . . ••.",.-.
B. CHEMICAL ENGINEERS WHO UNDERSTAND THE
ENVIRONMENTAL LAW FIELD WILL BE ABLE TO
. LOBBY FOR.MORE EFFECTIVE ENVIRONMENTAL LAWS ,
AND REGULATIONS IN THE FUTURE. -.
Regulated entities'have traditionally perceived industrial'growth and a
clean environment as incompatible because compliance.with environmental
. laws and regulations is often costly.26 Their strategy, therefore, was to
challenge environmental regulations in court arid block environmental -
laws from being enacted. . .
Recently, however^ regulated entities have realized that environmental
laws and regulations are inevitable. Instead of trying to block their enactment
and promulgation, regulated entities have begun to work with regulatory
agencies to ensure that the most cost-effective and workable environmental
laws and regulations are enacted and promulgated.27 •
24 E. Slowter and A. Oldenquist, One Code of Ethics for All Engineers, in Chemical Engineering
, Progress 24-30 (January 1981). ... , .
25w. .. : . •. . ;" - * '• .w.' •. • , -'•
"•26 The majority, of federal environmental laws set pollution discharge limits in specific
environmental media and encourage companies to meet those limits through waste treatment.
Traditionally, treatment and the subsequent disposal of-waste by-products have increased
companies' operating costs, thereby, reducing-corporate profits. According to the Chemical
Manufacturers, Association, the chemical industry has spent nearly S12 billion on pollution •
abatement and control since 1973. Chemical Manufacturers Association, U.S. Chenucal Industry
Statistical Handbook 3-4 (1990). . • . \
27 Traditionally, regulations were developed by -the EPA of state environmental agencies;
however, once'they were final/the regulations were often challenged in court by «gulated
' entities, resulting in delay, lost resources, and often ineffective regulations. Lately, the E?A
has solicited comments from regulated entities early in the regulatory process, enabling the
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C.-r~.:^. rrc.rcrr; are in a unique position to help craft more effective
„_._ , r~er.tal law; ar.i regulations.. Chemical engineers can educate
--v.-:r~er.:al roiicv makers about the best solutions in terms of pollution ;
control and waste minimization. 'For example, chemical engineers are often
the ^ersons who design, and operate the chemical processes that generate .
pollution. As a result, they are familiar with how the processes can be
modified to control and/or minimize the pollution that is generated.
In addition, most environmental statutes, such as the Clean Water Act
and the Clean'Air Act, contain technology-based control mechanisms to
achieve their goals. Chemical engineers have the technical expertise to
determine whether the technologies on which these controls are based are
cost-effective and/or feasible. Before chemical engineers-can influence the
development of environmental laws and regulations, however, they must , -
understand the basic structure of the environmental law'field. .
C CHEMICAL ENGINEERS MUST COMMUNICATE WITH
ENVIRONMENTAL LAW PROFESSIONALS
Finally, chemical engineers need to understand the field of environmental
law because their work and workplaces are increasingly subject to environ- ,
.mental mandates. Communication with environmental law professionals,
therefore, is crucial to the operation of the facilities that chemical engineers
design, build, operate, and manage. . .
Chemical engineers need to communicate with'federal and.state'
environmental agencies regarding permit applications and requirements;
enforcement officials and' environmental attorneys regarding possible
violations'and enforcement proceedings; the public regarding plant
operations and possible public health'risks; and private sector, companies,
such as environmental consultants, regarding matters such as environmental
cleanups and audits. A basic understanding of the environmental law field
has become a de facto job requirement for the modern-day chemical engineer.
entities that will be affected by the regulation to voice their concerns early on. This process is
called a regulation negotiation ("reg-neg"). The benefits of the reg-neg process include fewer. ..
court challenges because regulated entities often have their concerns resolved and better
regulations because regulated entities are involved in their development.
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- - •-'; .-o:=r.ci5-o: er.vircnrnentarla^vs an'd their regularo'ry-:e'cu.::=,..er :i'
•'"• •" 'j'~o• heir1 .chemical engineers'understand why .environmental .
::rr-;;a-:;ce'is so costly for their employers. Hopefully/ this a Bareness wul
encourage.them" to act prdactively when designing chemical processes and
ooeranons so that less pollution will be generated in the future - resulting in
cost savings for their employers and' a cleaner environment. . _
PART II - SOURCES OF ENVIRONMENTAL LAW:
LEGISLATURES, ADMINISTRATIVE AGENCIES, AND COURTS
Three types of .-governmental actors define the field of environmental-law:
' tegislatures,>administrative agencies, and courts. Each governmental actor
plays a specific role in the development of environmental law, - ' .
The-United States Constitution delegates each governmental actor specific.
powers and requires them' to exercise those powers separately from each
other.23 It has been stated that, "[A]s a general rule inherent in the American
constitutional system, . .'the legislature cannot exercise either executive or _
.judicial power; the executive cannot exercise either legislative or judicial ^ •
power; the judiciary cannot exercise, either executive or legislative power,"29
Administrative agencies seem to challenge this'"separation of powers"
doctrine because they have the power to promulgate regulations that have
the force of law (e.g., a legislative power) and they also have the power to
decide disputes that arise within their jurisdiction^! areas (e.g.. a judicial
power). They do not violate the separation.** powers doctrine, however,
because their legislative and judicial powers are subordinate to the powers
that are delegated to legislatures and courts by their respective constitutions.
In addition, there are mechanisms, such as judicial .review,30 that "check"
agency exercises of legislative and judicial power.
28 State constitutions are modeled on the U.S. Constitution-and, likewise, delegate respective
• powers to their executive, legislative,'and judicial branches. •_
* » B. Schwartz, supra note 6, §2.1, at 43, quoting Springs v.' Philippine Islands, 277 US. 139,
201 (1928). . • • '."v- ' . .•
30 fudicial review is the basic remedy against illegal administrative action. A person •
aggrieved by an agency decision or other act may challenge its legality through the judicial
' svstem where courts determine whether the'agency acted within its statutory grant of
authority. B. Schwartz, supra note 6, §8.1, at 470, This will be discussed in more detail infra.
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A. LEGISLATURES
r- -"-e federal svstem, the United States Constitution has empowered the
Ur,::ed States Congress to enact federal laws; in the state system, each state
constitution or charter has empowered its state legislature to enact state laws.
The state legislatures, in rum, empower Local governing bodies, such as city.
councils, to pass ordinances that protect the health and safety of their
residents concerning areas like trash collection or zoning.31
When drafting laws, legislators, can use specific or vague language •
depending upon the amount of flexibility that they want to build into the
statutory provision." For example, when drafting a statutory provision.con-
cerning'enforcement, legislators often use"specific language because it enables
them to spell out exactly what is prohibited by the statute and the sanctions -
that will result from any violation. However, when drafting statutory '
provisions concerning issues that are within an administrative agency's^
particular area of expertise, legislators customarily use vague language.32
Legislators use vague language when drafting statutory provisions for
specific reasons. Often, legislators do not have the time to .think about the
particulars of a specific statute's implementation or they do not have expertise
to determine how the statute should be implemented. Sometimes, legislators
want to avoid making politically unpopular choices. Vague drafting allows
legislators to give administrative agencies the flexibility they need to
implement the statute while enabling legislators to avoid any political heat
that may be associated with a statute's implementation.
B. ADMINISTRATIVE AGENCIES
Administrative agencies are responsible for implementing of environ-
mental statutes. Agencies can be created by each branch of government;33
31 These local powers are termed "police powers." • .
32 A ratable exception occurred during the Reagan Administration Specific•mandateswere
included in many environmental statutes enacted during that time because the EPA was fading
to reeulate effectively. • ' • • ,,. .
33 Courts can establish "special masters", legislatures can establish investigatory offices such
as the Congressional Budget Qffice, and chief executives (e.g., theResident) carJ "tabhsh^
councils, sudt as the Council.of Economic Advisors, by executive order In 1970 P es^ N*on.
established the United States Environmental Protection Agency (EPA) in order to consolidate
' federal programs for controlling air and water pollution, radiation, pesticides, and solid waste.
10
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•'--.,_•:• i^-,r.;:ra:;ve cowers.'are derived entirely, from their enabling legis.aricr.
\d~;nii:-a.:;ve agencies carrot exercise,more power than that -which rr.ey
---> ae'.e^ated. The issue of legislative delegation t;o an administrative agency
ar.d whether that delegation was proper or whether that delegation was
exceeded by the agency often provide the basis 'for a challenge to an
administrative agency action.34 '. . _ ; '
Agencies :give meaning to vague statutory provisions through a. procedure
known as rule making. Rule making consists bf.publishing proposed regula-
tions in'the FpHpral Register,35 providing aivo'pportuftity for \the public .to
comment-on the proposed regulations; and. publishing final regulations in ' ,
: fhp'FprlpraJ Register which, .when effective, have the force of law. Because ;
' administrative rules'affect the rights and-obligations of regulated, entities, their '
1 promulgation is one of the most important tasks- of administrative agencies.
For example, the EPA promulgated a rule in 19.92 that clarified> provision .
in CERCLA that exempts "secured creditors" from liability'for cleanup costs
' when they foreclose oh a borrower's contaminated property.36 In promulgating
this rule, EPA interpreted CERCLA's liability provisions and concluded that;
Congress did not intend certain classes of lenders to be included in Its liability
scheme. This rule changed parties'existing rights and obligations under
' CERCLA and created law just as CERCLA did when it was initially enacted.
Administrative agencies also have the authority to decide disputes that
arise from exercises of their administrative powers. For example, if a state
- .environmental agency denies a regulated entity's application, for an NPDES
permit,37 the entity has the right to appeal the denial to an administrative
' law judge.38 Administrative law judges work for administrative agencies and
they act exactly like judges. They hear testimony, examine evidence, and
apply legal standards to factual scenarios, in order to make determinations
that settle disputes. ; - •-•.--•.'
34 This will be discussed infra. • . •' '
35 TheEfidsraLEsgislfiT is the official publication.^ which rules-and regulations,
which are promulgated by federal administrative agencies, are published.
36 This rule was later invalidated. See, infra.
37' State agencies are generally the primary permitting and enforcing authorities for
environmental statutes. . > .
>38 Administrative law' judges are- also called "adjudicators."
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C, COL ^. • ? •
J --; :•:•= t.-.e third :v-e c-f sovernrnentai actor that defines the field of ' - ,
„ ---T-^r.ral .a'A' Courts are responsible for resolving formal disputes
• a-ors parties. Disputes can arise in a variety of ways.. For example, when
one individual harms the person or property of another, the harmed
individual may demand compensation in'a court of law. Similarly, when a
person or entity violates a statute that was enacted to protect the public,; the
public rr.ay demand retribution.
When resolving specific disputes, courts examine the facts at issue and
determine whether the law provides injured parties with a remedy. In
making their determinations, judges are. guided by statutes;,administrative-.
•rules, and the determinations of judges who have-ruled in.prior similar cases
("precedents")-. Judges use precedents to guide their application of general
legal rules to the specific facts of each case. Their determination in each case .
is called the "holding," . '' , ' •
1. Role in Determining Coverage of Environmental Statutes
Disputes can arise over, the coverage of an •environmental statute. For
example, a regulated entity can argue that it is not subject to a specific
statutory provision. If an administrative agency tries to force the entity to
'comply,' the entity can bring a lawsuit to conclusively determine whether it is
subject to the provision.
Judges decide these, disputes by determining what the legislators intended
when they drafted the provision (termed its "statutory intent"). First, they
• examine the plain language of the provision. If the language is clear, the case
is usually decided on that basis. However, judges often look at other clues in
.order to'determine the legislators' intent. Possible clues include the statute's
legislative history (e.g., the recorded history of the statute's enactment - from
drafting through enactment) and the overall effect of the statutory provision.
They also look at similar provisions, which may be contained in other
statutes, to determine how similar language has been interpreted by the courts.
For example, in an early CEkCLA case, the defendant argued that Congress
' did not intend CERCLA to be applied retroactively (i.e., that Congress did not
intend CERCLA to hold parties liable for actions that were legal at the time
they occurred). In rejecting the defendant's argument, the United States
12
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i:e<-.:: eArressIy provide for retroactiv-ty, it-is manifestly clear that Cor.gres:
vr.:er,'ded CERCLA to: have retroactive effect. The language used in the key .
Lxb-il-.rv provision refers to actions and conditions in the past tense. Further,
the statutory scheme is overwhelmingly remedial and retroactive.'"39 In this
case;, the "plain'language"'of--.the provisions and' the overall statutory scheme
determined how the court interpreted the provision at issue.. >
; Disputes'can also arise over the constitutionality of environmental '
statutes. For example,-.when CERCLA-was enacted, its. retroactive application
was challenged as an unconstitutional denial of due process of law.40; In
ruling that CERCLA.was constitutional the'U.nited States Court of Appeals ,.
.for the Eighth Circuit examined prior case law on due process and stated the'
general rule: "Due'process is. satisfied 'simply'by showing that the retroactive
application of the legislation is itself justified by a rational legislative , .
purpose.'"41 ^The court then looked at the facts at issue - in this .case, the legi-
slative purpose of CERCLA. It wrote, "Cleaning up inactive and abandoned-
hazardous waste disposal sites is a legitimate legislative purpose, and ,
Congress acted in a rational manner in imposing liability for the cost of - -
cleaning up such sites upon those parties who created and "profited from the
sites arid upon the chemical industry as a whole."42 Its holding that '
CERCLA's retroactive liability does hot violate due process, therefore, was ,
consistent with the general rule and the facts of the case. . •
2. Role in Reviewing Administrative Rules and Decisions
As mentioned above, administrative agencies develop 'and promulgate
regulations in order to implement environmental statutes. Those
regulations can be legally challenged by aggrieved parties in two ways:
(1) substantively and (2) procedurally. . .".--'. •
Pharmacf»Kral fe.Chemiral Co..-InC., 810 F.2d 726, 732-733
(8th Cir. 1986) (cites omitted)- , "' . _ '
40 Due process is required by the 5th Amendment of the United States Constitution. The Fifth
Amendment of the United States Constitution states: No person shall be...depnved othfe,
liberty or property, without due process of law...." U.S.C.A. Const. Amend, 5 (West 1987).
41 TTnifarf States v.. Nnr*h».«t»m
Cir. 1986), ~»-± P™*" RpnpfH <"'^^^ v * A' C'rav
42W.'at734. !. ' - ' • ' •'.'-
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- ---.-; ,-.•. a re'ular.c r. car. be attacked or. the grounds that tr.e agercy .
u.r. -;• rave the rower to'develop ar.-d promulgate the regulation -this'is '•
.£ --: ,r. u.':^ ;-;rei ' challenge! or it can be attacked on the grounds that
t.-.e rule was improperly promulgated (e.g., the rule was within the agency's
delegated powers but it was not developed in accordance with the
recuirernents or the Administrative'Procedure Act). In both cases, the'
remedy rs invalidation of the''rule.43 •
Judges determine ultra vires challenges by examining whether the power
that was conferred upon the agency included the power to promulgate the
challenged regulation. As a'general rule, judges generously construe agency
authority. Nevertheless, courts take ultra vires challenges, seriously because
ultra "ires acts represent unlawful agency intrusions into the domain of
legislatures, thereby! violating the separation of powers doctrine.
°In a recent ultra vires challenge, the United States Court of Appeals for the
D.C. Circuit vacated the EPA rule mentioned supra that protected lenders
' from CERCLA liability.44 The court ruled that Congress had not empowered
EPA to determine the reach of CERCLA'sliability scheme, It wrote, "[I]t
cannot be argued that Congress intended EPA ... to have authority to•:
define liability for a class of potential defendants. Congress ., . has designated
the courts and not EPA as the adjudicator .of the scope of CERCLA liability."45
Because EPA had acted beyond its statutorily delegated powers,, the court
invalidated the rule.
Regulations can also be challenged in court on procedural grounds.
Federal administrative agencies must follow specific procedures, set forth in
the Administrative Procedure Act (APA),46 when promulgating-regulations.
For example, the APA requires all federal agencies to publish a notice of a
. proposed rule making in the Federal Register prior to promulgating a rule
that will affect the rights of private parties. In addition, federal agencies must
give the public an opportunity to comment on the proposed rule. If the
• 43 Invalidation results in the judge "vacating" the rule and "remanding" it back to the agency.
However, upon remand, the agency .can promulgate the rule in a proper and, therefore, legal
manner. '
44 K-pllgy v. Environmental Protection Agency. 15 F.3d 1100 (D.C. Cir. 1994).
45 Id at 1107-08.
46 5 U S C. 551 et seq (West 1977 & Supp. 1994). the Administrative Procedure Act (APA) sets
forth rules that agencies must follow when implementing their administrative duties. Most
states have used the APA as a model when drafting state administrative procedure acts.
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— - -. - - p - • '
'"r-'.^V :^re\a~rle, the. D.C.- Circuit Court or Appeals'invalidated the
'rrixrure1' rule'47 because the agency had failed to provide affected '' ...
rar.ties with notice of the proposed rule making.48 The court ruled that the
mixture rule was ihvalidly adopted and, therefore, had been ineffective since •
the. dat'e'of its'promulgation.- . ..•-..-• •• ' '.-••'
A party'who is aggrieved by a final agency determination is entitled to have
that determination reviewed In a court of law. This is termed judicial review.
"For example; if.a regulated entity has its application for a Clean Water Act
XPDES permit denied,by a-state environmental agency, the entity has the'right
to have the' agency's decision reviewed in a court of law to ensure that'the .
denial' was proper. Before an aggrieved parry can bring ah action for judicial' :
review, however,, a number of'requirements must first.be met
'. First, a-party must have the right to seek judicial redress in a court of law.
This is.termed "standing,*'•' The doctrine of standing ensures that only parties.
who have a genuine interest in the case can bring a legal action for judicial •
relief. --Standing conserves judicial resources and precludes frivolous claims.'
' The APA grants standing to'persons who have suffered legal wrong
because of agency action, or who'have been adversely affected or aggrieved by..
an'agency action within the meaning of a relevant statute.49 Environmental
statutes can also provide .standing to certain individuals, such as through
citizen suit .provisions. In'general, the standing requirement is mef if the
plaintiff has suffered an "injury in fact." Injury'in fact is a legal term that .
. means that the plaintiff. has suffered some definable-harm-that is different
from the harm suffered by the public at large, • - - •
In addition, parties must "exhaust" their administrative remedies before. .
they can bring an action'for judicial review. The doctrine of exhaustion
requires parties to argue their case to an administrative law judge before a
court can exercise jurisdiction over the case., the doctrine.of exhaustion helps
conserve judicial resources but, more importantly, it allows administrative
47 The "mixture" rule required listed hazardous wastes to be regulated under the Resource
Conservation and Recovery Act as hazardous wastes even when they were mixed with large .
quantities of nonhazardous wastes. • . , • ' .
« ShPirbil Co. y Environmental Pm^tinn Agency. 950 F.2d 741 (D.C. Or. 1991). .
49 5 U.S.CA. §702.(West 1977). ; ' ' . ...'•_','
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^....i. -.^rute; ccr.cemir.g rf.arters tr.a: are
:uiar areas or expertise. " . '•
'_. -::= ::o net cake :udic:a! review actions lightly. Judges are often
rei-crar.: :o substitute their judgement for that of agencies because agencies
are considered to be the "experts" on administrative matters. In addition,
overturning agency decisions is politically sensitive because.administrative
agencies represent the executive branch which has been entrusted by the
legislative branch to implement its enactments. Judicial decisions that '
overturn agency actions, therefore, potentially threaten the separation of
powers doctrine. The general rule, therefore; is judicial deference to
administrative agency decisions, which reduces the likelihood that courts
will overturn agency decisions.50 •
For example, the Oregon Supreme.Court recently upheld a state environ-
mental commission's refusal to certify, a hydroelectric facility because the
facility would violate a state water temperature standard designed to protect
trout.-1 The court ruled- that the commission acted within its discretion in
rejecting the project based on the temperature standard even though the
commission found that the.project would not, on the whole, harm the trout
population. . . ,
The City of Klamath Falls had argued that the state had to find that a
temperature change would harm the trout population before rejecting the
project based on the temperature standard. The city also argued that the state
had the discretion under the regulation not to invoke the temperature stan-
dard where the change would not harm the fish-. Finally, it'argued that the
commission did not provide a rational explanation-for applying the
temperature standard to the project.
3 Courts limit their review of .administrative agency actions in two ways: through their scope
of review and their standard of review. The scope of review determines the amount of factual
material that the court will review when making its determination. Normally, a reviewing
court restricts its scope of review to the existing factual record (i.e., the evidence and testimony
presented in the administrative forum) and makes a determination as to whether the agency's
decision was proper given those facts. The standard of review determines the level of legal
scrutiny the reviewing court will apply when reviewing an' agency action. The "arbitrary and
capricious" standard is the most common. Under this standard, a reviewing court must determine
whether an agency action was based on a consideration of relevant factors or whether there has
been a clear error in judgment. It is very difficult to overturn an. agency action using this standard
because the standard is one of reasonableness and, in making their determination, courts
generally presume that the agency action was reasonable. B'. Schwartz, supra note 6, §4.4, at 172
S- CitV Of Klamath Falls v. Environmental Quality Commission. 870 P;2d 825 (1994).
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rtrat:'.-= ;:nd:n^ ..The.court found that the state, did not need to show in
;'r. defender, t harm to the trout population because' temperature changes 'over /,
the trrescnbed limits were per s^2 violations''of state water quality standards:
Tne court also found 'that the commission had the discretion to do more than
the bare minimum requirement and err on the side of overprotecting the . -
fish. Further, the court found that, the agency's order'provided a rational basis'
tor-application of the standard because the commission was certain-that •
temperature changes would occur;- • '. ; •-"; / .
" This case illustrates how. courts defer to administrative determinations
in judicial review actions. .As long as the agency's decis.ioh is reasoned and
within-the statute, it Will be fairly difficult to overturn on review. .
3. Role in Developing the Common Law System '
Courts are also responsible for deciding- common law cases. The common
law system is composed entirely o'f case law (as opposed to statutory proyi- •'
• sions).33''Each state'has its own common law system,54 consisting of decisions •
that are based upon the judicial determinations of previous cases (the prior -
determinations are called "precedents"). Judges use'precedent to guide their
decision making. A judge can make a decision that is inconsistent with-the '
precedents of a given jurisdiction; however, they do so rarely because a
sudden shift threatens public expectations about what is/and is not legal.
- The common law is organized around specific topics. Cases that deal with
similar factual situations are grouped together. For example, a category of
common law actions is called-"torts." Torts are causes of action that provide a
legal remedy .to persons who are injured by other individuals' breaches of
generalized legal duties'(e.g., the duty to act reasonably). The categorization of
•common law actions has facilitated,the development of legal principles that •
52 Per se violations consist of .violations of statutes that were enacted to protect the public's ,
health, arid safety. Per se violations are actionable even if no harm to persons or property occurs.
53 As one commentator has noted, "[T.]he common law is not the result of legislative enactment,
Rather its authority is derived solely from usages and customs which have been recognized,
affirmed, and enforced by. the courts through judicial decisions."- T. Sullivan, supra note 3, at 6.
54 Except Louisiana which has a legal system that is grounded in civil law. Civil lay* is
' derived from the French legal system, whereas common law's roots are English in origin. There
is also a federal system of common law; however, it does not significantly affect the areas of
law covered by this guide. .
17.
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n
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--. :r.c :.: rr.rr.cn law, the .piaint-if-f rr.ust also allege ;that hie or she was aa^age^-
3-d :hac :he defendant's breach caused the'damage: The plaintiffs attorney
-u-:; -rove'to a judge Or a jurypl- that'all of the relevant facts alleged in the
ccrn£laint occurred (or likely occurred) in order to win at trial.62 ^ - ' _
In order to defeat the plaintiff's claim, the defendant's attorney must prove
that, the alleged, farts did not occur or, if they did, they,do not provide, an action-
able claim. For example, the defendant may have a defense63 lathe plaintiff's
• cause of action which .could prevent the plaintiff from'winning "at 'trial-.
Lawyers research case law and use their precedents to convince the judge
or jury'fo. rule in their favor. To illustrate -how judges use precedents to
decide common.law ^^//^ciHor-Rnnnnpr v. Atlantic Cement Company,64 ;
'one of the common law's .most famous nuisance decisions-.. In Boomer6-" the
plaintiffs alleged that the defendant's operation of its cement plant, which :
discharged dust onto their property, was a. nuisance (i.e., that it unreasonably
interfered with the quiet ehjoymen-f of their land and, thereby, caused them
harm). 'The trial court66 had found that, based on the facts of'the case and .
New York, law, the defendant's operation was a nuisance. • _
: . .The issue on appeal was the remedy which should.be awarded. The
•plaintiffs wanted a permanent .injunction (i.e., they wanted'the-court to order
the'defendant to shut its plant down); however, the trial court had refused to
61 Parties choose whether they want their case argued before a judge or a jury. If they choose a
judge,'the judge determines issues.of fact and law. If they choose a jury, the jury determines
issues'of fact and the judge determines issues of law: • '.'...- . -
62 In civil and criminal cases, attorneys must meeta "burden of proof." In most civil actions, the
attorney must prove that the alleged facts 'occurred "by a preponderance or the evidence. In
criminal cases, the prosecutor must grove that the defendant caused the crime beyond a
reasonable doubt." . . «,._,-•<:„' '
63 Defenses include procedural defenses which allege that the plaintiff did not follow
procedures required by .the court system and substantive defenses .which attack the legal ,
sufficiency o* toe-plaintiff s claim. A substantive defense to a trespass action would be .the •
defendant's ownership of the'land' that the plaintiff alleges is being invaded.
64 B^mrt. pt ai. v: ^rfr C^*r« Company. 257 N.£.2d 870 (197Q). ' J ' '. ; .
•65 Once a case is cited in its entirety, subsequent references to the case are made by citing only
the name of the party that brought the action. , • f ,,.„.'
66 -r^ trial court ^ me first <:ourt that hears a case. In New York, toe trial- court is called the
Court of Special Term.- The highest court in New York State is caUed the New York Court of
Appeals. The second highest court is called" the Supreme Court, Appellate Division. This B
. contrary to the system of most states that call their highest court the- "supreme court and the
second highest court the "appellate" court. . - ''_.'•
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_•:;-: a rrrrr. .-=.-: .r,:ur.c::c-n and its decision had been'affirmed by the
5_rr=—e C_'ur:. Appellate Division. • , . • •
T.-c1 \e-.v Yo:.A Boomer, supra note 64, at 873.
'" Id. at 874.
70
69 Id.
Each state has its own common law system and courts within each state are bound only by the
precedent made by the higher courts of that state.
20
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.-: Craved rr^rr. :r.e served precedent-c: New 'IJ:N >,•-
dewrrnmation;'however, B.corr.er is unusual because
-,-u::s 'are loarr.e :o stray from settled precedent. Precedent represents years j
o::en decades; of'settled case law. .As a result, precedent .allows people to ,
predict'how the common law will govern their actions. This may explain
why the-Bp_ojnej; court-tried :to ground its decision on precedent from, other.
jurisdictions.- Reasoned departures ffonv'precedent (e.g., what;the fioprngr
court tried to do although there is.some dispute whether its reasoning was
sound), however, give the xommori. la wits; dynamism, allowing it to respond
to a changing society. . • * • / - •
It is important -for chemical engineers to understand the common law
system because it has-as- much of .a regulatory impact as environmental
' statutes and regulations. For example, a company can be incompliance with;
statutory and regulatory requirements but still be the subject of a common
law cause of action'because compliance does not conclusively.prove that' a
company-is operating nori-negligently, or that its effluent does not.constitute'
a nuisance. ' •' - •. _ - ' •
PART III - THE LAYERS OF ENVIRONMENTAL LAW: .
HOW THEY INTERACT TO CREATE A TANGLED WEB OF REGULATION
The categories of actors that define the field of environmental law consist
of many members. "Legislatures," for example, include the United States
Congress, the fifty state legislatures, and innumerable local governing bodies.
"Administrative agencies" consist of federal, state,'and local agencies, such as
the Environmental Protection. Agency, and, for each of the 50 states, their
- state and local counterparts. "Courts" include the United States Supreme
Court,-the fourteen:United States courts of appeals, ninety-four United States
district courts, fifty state supreme courts, and many state appellate and lower
courts. - ' • .-'..._'•
these actors all create environmental law and the law that they create,
whether in statute, regulation, or case law form, can.interact in one of four
.ways.. The laws can have no effect on each other, the laws can complement
, each other, the laws can require the same thing or, the laws can conflict.
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-,._. . -,- ,:_-s:- - -.'.-here environment! Law; have no effect on each
,.'_, \ ._e ^er.era'. rule. As mentioned earlier, the United States Constitution •
alT.--!"-'--ri:::u::cr.s delegate specific powers to their respective legislatures,
j'-l"-"i-ra::ve agencies, and courts- Because these actors have the power to act
^^Z^-urisdictional areas, the-law that they create usually does not impact
ie~law made by the other actors. An example is the state'common law action . .
of nuisance and the federal Clean Water Act. Regulated entities can and must
comply with each law's mandates.
Environmental laws can also act cooperatively to effect some mutual
purpose Federal statutes-often allow state agencies to administer and enforce
re-ulatory programs that effect the federal-statutes'' purposes and goals. For.
' example 'the Clean Water'Act allows states, in certain cases, to implement the
national pollutant discharge elimination'system (NPDES) permit program ^
which regulates the discharge of pollutants into the nation's surface waters."
If states do not assume an .NPDES permit program or if they assume a
program, but implement it ineffectively, EPA can reassert its authority over ,
the program. In these cases, compliance with both the federal and the state
laws is possible and necessary to give effect to their common purpose.
Environmental laws can also impose identical requirements. For
example, many states have "mini-Superfund" laws that are modeled on
CERCLA Both the federal and the state laws impose liability on certain
entities, called potentially responsible parties or "PRPs", for the clean up of
abandoned and inactive .hazardous waste sites. Cleanup actions can be
brought under the state or the federal statute; however,'these law* .an
provide problems in terms of enforcement because of their duplicate
mandates. . • • ...
' Finally, environmental laws can conflict, making simultaneous compliance
with the laws impossible or burdensome. Conflicting laws can emerge at the
same level (e.g., between a state court and a state administrative agency) or it
can occur at different levels (e.g., between a state legislature and a federal
legislature). In both cases, conflicts usually occur because both actors have .
. jurisdiction (or contend they do) to act concerning the same regulatory area.
' When environmental laws conflict, one of the laws must be invalidated.
The determination as to which law remains valid is governed by legal
71 CWA §402(b), 33 U.S.C.A. §1342(b) (West 1986).
22
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,. .-e ^rr.e/.evei .'c.c , between laws created by state 'administrative agencies
'•---d -rate courts "areofiterv resolved'.using the dqctriries of exhaustion and
•uncial deference to agency.determinations." Rules have also evolved to
'settle conflicts between laws that emerge at different levels, such as;at the\
federal and state levels. '• , ' • .' .'••..
A. THE DOCTRINE OF PREEMPTION ,
The relations between federal and state actors are governed by the
Supremacy Clause and the state'powers clause of the United States
Constitution-. The.Supremacy Clause ensures that in any area where-the • '
- federal government has been accorded national; powers/ its regulatory ^ '_
authority can be exercised .to preempt concurrent state-regulatory efforts.73 • :
•The federal government is empowered to act only-in specific areas, .
however. Those powers concern the regulation :of interstate and foreign
commerce (although federal exercises of such authority .are broadly
construed). In areas that have.not been delegated to the federal government/
the states have unfettered authority to regulate - a point that is clearly ,
expressed by the Tenth Amendment.74 , .
Courts use the Supremacy Clause and the Tenth Amendment to resolve
conflicts between federal and state laws. Their goal is to balance the
competing doctrines of federal supremacy and state -authority. For example,
" when, initially determining whether a conflict exists, courts presume that
concurrent state and federal laws, are valid. However, if further inquiry
suggests that a conflict does' exist, courts must determine whether the federal
government has been accorded national powers over the specific area of '.
. regulation. If they find that it has, courts must rule that the federal regulation
72 These legal doctrines were discussed in Part IL '.
73 The supremacy clause states, "This Constitution, and the Laws.of the United States which
shall be made in Pursuance thereof; an'd all Treaties made, or which shall be made, under the
.authority of the United States, shall be the supreme Law of the Land; and the Judges » every
State shall- be bound thereby; any Thing in the Constitution .or Laws of any State.to the
Contrary notwithstanding." U.S.C.A. Const. Art. 6 (West 1987). ,
74 The Tenth Amendment states, "The,powers not delegated to the United States by the
Constitution,- nor prohibited by it to the States; are reserved to the States respectwely, or to
the people." U.S.C.A. Const. Amend. 10 (West 198.7). . ...
23
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;_f=:ic.ies the state' or local '.aw. However. U courts rir.d that
:ou:ts must invalidate the federal regulation-and, in such cases, the
<:i:e :r .ocal law remains valid.
Vv'rcr. reviewing a law that is challenged on preemption grounds, courts "
determine whether the law contains an express or implied congressional_
:n:eru to supersede state or local authority. To do- this, they examine the
challenged statutory provision- in order to find evidence of express
congressional intent and they examine the scope and range of the statutory
scheme in order to find evidence of implied congressional intent/3
In cases where courts cannot find an express or an implied preemptive
intent the Supremacy Clause still requires that,; where a state or local law is
incompatible with a federal law (e.g., if dual compliance with both regulations
is impossible or would contravene each other's policy), .the state or local law
must be invalidated. However, as mentioned earlier, courts begin any
preemption challenge with a strong presumption against preemption and
' they uphold concurrent state or local authority unless they find that Congress
has expressed a clear intent to displace state or local authority in a particular .
regulatory field. The doctrine of preemption can be illustrated by a Federal
Insecticide, Fungicide, Rodenticide Act'(FIFRA) case - Wisconsin Public
Tntervenor v. Mortier.76 In Mortier. a chemical applicator challenged a local
pesticide ordinance on preemption grounds. FIFRA contains an express
•statement that allows "states" to regulate pesticide applications more
stringently than the federal government. The applicant argued that the
express authorization of siaifi power to regulate applicators more stringently
than FIFRA precluded local governments from doing the same.
The Supreme Court rejected'the applicant's challenge, finding that FIFRA
did not- contain express or,implied language that its provisions were intended
to supersede local authority. Because the Court also found that it was not
"5 Regarding implied congressional intent to preempt, the United States Supreme Court has
written- "Absent explicit pre-emptive language. Congress' intent to supersede state law in a
' given area mav nonetheless be implicit if a scheme of federal regulation is 'so pervasive as to
make reasonable the inference that Congress left no room for the States to supplement it if the
Act of Congress...touch[es] a field in which the federal interest is so dominant that the federa
' svstem will be assumed to preclude enforcement of state laws on the same subject, or if the goals
•sought to be obtained'' and the 'obligations imposed' reveal a purpose to preclude state
• authority." Wi.mn.in Public Tn*™"™- v- Mortier. 501 U.S. 597, 605 (1991), quoting
^n>* PP' Elevator Corp.. 331 U.S. 218, 230 (1947).
76 501 U.S. 597 (1991) ' • ' ' .
24
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e" "Ve aw;
iG.al;,- the Cou:^ ruled char-FIFRA ~.i- ".C-
,Bi THE DORMANT COMMERCE CLAUSE
When the United States Constitution was drafted, the -states voluntarily .
ceded certain powers: to the federal government. One of "these powers was *
the power to regulate 'interstate and international commerce. The states
'surrendered that power to the -federal government because it was vital to a
strong national economy. Absent the Commerce Clause, states feared that
they would isolate themselves and' not trade with each other, resulting in
•"economic, b'alkanization. ".'.-' . • '•"• '' • ''.."_
the Commerce Clause grants Congress the power "to regulate Commerce
with foreign Nations, and among the several States, and. with the Jndian
Tribes."73 The clause is termed the ''dormant" Commerce Clause because, '
although it is stated as ah affirmative grant of legislative authority (e.g.,
Congress has the power "to regulate"), courts have interpreted the clause to _
impliedly prohibit states arid local governments from acting in ways that • ~
-excessively interfere with interstate and international commerce/9 .„
• When determining' whether a law is valid despite its interference with
interstate commerce (just because a state action interferes with interstate
commerce, it does not automatically violate the Commerce Clause),. courts
apply one of two tests.. When a law regulates even-handedly. ('•*•, when it ,
applies equally to. items of commerce regardless of their origin), courts apply a
test of lesser scrutiny. : Under this test, called the '-Pike ,.test,"?° a law will be .
upheld if it furthers a legitimate state interest unless the burden on -interstate
commerce is clearly excessive in relation to its putative local benefits. The
Supreme Court wrote! in Pike. "[T]he extent of the burden that will be
771 This phrase, which is often used by courts when justifying invalidation of laws and
. regulations that violate the commerce clause, was first stated in H,P-tfood &5nm. Inc. v.'Pu
Mond. 336 U.S. 525 (1949): . ,
78 U.S.C.A. Const. Art. I, §8, cl. 3 (West 1987). '
7? Although the dormant commerce clause prevents states from acting in ways that mterfere
with interstate commerce. Congress can enact legislation that gives states such power.
30 The "Pike test" was established by the Supreme Court in PiVfy, Bruce Qiurch. Inc., 397 u-s-
137(1970). ... ••'•'., . -•"";•' .'----..• : ••'.'
25
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'c-"=- ••••••• -'•' course derend or. the nature of the Local, interest involved,
, ._ v,he:r.er it could be promoted as well with a lesser impact on
Laws that discriminate against interstate commerce as a means of
responding to local concerns or that are motivated solely by a desire to protect
local industries from out-qf-state competition (e.g., a law that requires raw
materials 'to be processed in-state),32 are strictly scrutinized by the courts. Such
laws are automatically ("per se") invalid, except in'a narrow class of-cases in
which the sta;te or political subdivision can demonstrate that the law serves a
legitimate governmental public purpose that cannot be served by other
nondiscriminatory means.83 This test, hpwever, is very difficult to meet.
A. recent Supreme Court case illustrates the use of these two tests. In
rfc-ACarbonp I"r v- Tow^nf rlarkstnwn. N.Y..84 a town ordinance was- •
challenged as a violation of the Commerce Clause. The ordinance required
all solid waste to be processed at a designated transfer station before leaving
the municipality. The Court in a 6-3 decision held that the ordinance was
unconstitutional because the ordinance precluded competitors of the
• designated facility, including out-of-state firms, from accessing the local
waste processing market.
Justice Kennedy, writing for the majority,85 used the per se discriminatory
test in striking down the flow control ordinance as a violation of the
Commerce Clause. He wrote, "[T]he flow control ordinance discriminates, for
it allows only the favored operator to process waste that is within the limits of
32 ~y^PHnadglrKiavM»wTerSev. 437 U.S. 617 (1978) where the U.S. Supreme
that a New Jersey iw tha7 prohibited the importation of solid waste violated the ,
Cause because, on its face, it prevented out-of-state interests from palpating «
Maine ban on the import of baitf ish was upheld by .the Supreme Court even.
tan^ dearly benefitted the local baitfish industry, because the Court found that
had mother Jay to prevent the spread of parasites and the adulteration of its natwe
fish species. Maine v.. Tavlor. 477 U.S. 131 (1986).
85 US Su?^TcSu^tdecisions are decided by -a majority vote of its nine Justices. One Justice is
assumed Kfc TofTuthoring an opinion, which is then circulated among the other Justices If.
~^^
disagree with the majority opinion's ruling.
26
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--_- ..r ","• Ir. :;r.c.:r.z :r.". :he ordinance d:i ~c: meg: :r,e r. a ::.:•••• c^vr:...?
v -he re- =<: test, Justice,Kennedy wrote, "[CjLarkstown has any number, or • -
n;nd:ior:m:natorv alternatives "for-addressing the health and'enviifonmer.tai
Problems Alleged'to justify-the ordinance . . . The, most obvious would be
uniform.safety regulations'enacted without the object to discriminate."57 ' ,
Justice O'Connor joined the Court, in a concurring opinion, writing
separately because she found that .the ordinance, rather than being per se
"discriminatory wa5 even-handed in its application (e.g., she found that it did
not discriminate on the basis'of geographic origin), ^applying the.Eike. test,
she found that the ordinance's burden on interstate commerce was excessive •
'. in relation to the local benefits conferred and, as a result, she also found that
" • r 88 • ' •
. the ordinance was unconstitutional. • • ...
Justice Souter, who-wrote the dissenting opinion in C ^ A Carbqhe, stated'
that the Clarkstbwn-ofdinance did not violate -the Commerce Clause because
its burden fell "entirely on Clar.kstown residents."89 He wrote: / , - -
There is, in short, no evidence "that Local Law 9 causes discrimination
against out-of-town, processors, because there is no evidences the record that
' such processors have lost business as a result of it. Instead, we know only t^t
the ordinance causes the local residents to pay more for trash disposal .
"services • -But local burdens are not the focus of the dormant Commerce
Clause, and this imposition is in any event readily justified by the ordinance's
legitimate benefits in reliable and sanitary trash processing.90
•86 C & A Carbbne, supra note 84, at 1682. , • • '
M ste'wrote3' "The local Merest U proper disposal of waste is obviously sigruficant. But this .
• 1690 (cite-omitted) (O'Connor,;J-, concurring). -
89 Id- at 1700 (Souter, J., dissenting). -
" ' ' ' '
• 27
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PART IV -NINE FEDERAL ENVIRONMENTAL STATUTES THAT
E\'ER\ CHEMICAL ENGINEER SHOULD KNOW
This section will outline the regulatory provisions of nine1 federal
environmental statutes that regulate chemicals throughout their life cycle
»!.
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.?. o.
V THE,SlANUFACTURE OF CHEMICAL SUBSTANCES—
THE TOXIC SUBSTANCES CONTROL ACT . . ' ;
The Toxic Substances Control Act"- (TSCA) was enacted on October 11,
Incidents like -the conta-rriination of the Hudson River by .
• ooiychlorinated biphenyls' and the contamination of milk cows by
polybrominated biphenyls in Michigan had illustrated the need for a federal
system of toxic substance contr-ol that could assess the risks of chemicals prior
to' their introduction into commerce.
TSCA requires the EPA to screen new chemicals and certain existing
chemicals in order to assess their risks and make sure that their use does not'
pose unnecessary risks to human health or the environment.92 When the . •
EPA finds that a chemical poses;an "unreasonable risk" to human health or.
the .environment, TSCA'authorizes EPA to take regulatory action. When
EPA regulates a chemical, however, TSCA requires EPA to balance the • .-.
economic and social benefits pf/a chemical against its purported risks.
1; Existing Chemicals Testing
Section 4 requires'manufacturers, importers, and processors of TSCA- ;
regulated chemical substances93 to submit data to EPA on existing chemicals
when the manufacture,-processing, distribution, use, or disposal of the
chemical "may present an unreasonable risk of-injury to health or the
environment"; or'when the chemical is or will be produced in .very large
volumes and there is the potential for a substantial quantity to be released
into the environment "or there is a substantial or significant risk of human
,91-15 U.S.C.A. §2601 et set). (West 1982
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-
CA requires EPA to issue an administrative rule requiring
•c<- : ^v.itir,; data are< insufficient to resolve the question of safety.^
T'-e Lr.terasencv Testing Committee is respons.ible for determining which
exisrirg chemical substances will undergo TSCA testing.96 If a chemical
substance is listed on the Interagency Testing;Commiftee's priority list, §8's
resorting requirements are triggered. Section 8 requires manufacturers to sub-
mit production and exposure data and health and safety studies to the EPA.97
All data must be submitted within 90 days of the chemical substance's listing.
2. New Chemical Review
Section 5 requires manufacturers, importers, and processors to notify EPA
at least 90 days prior to producing or introducing a new chemical substance
into United States commerce:98 This is done through" a premanufacture_. .
notice ("PMN") which must contain information regarding the identity of the
chemical, categories of intended use, amounts intended to' be manufactured,
number of persons who will be exposed to the chemical and the manner or. ,
method of disposal. It must also include data relating to the chemical's effects
on human health and the environment.99 Section's requires the .EPA to
evaluate the new chemical product's potential risk within 90 days of the PMN
submission.100 EPA must assess the potential risks associated with the
94 TSCA §4, 15 U.S.CA. §2603 (West 1982). ' . ;
95 M •
96 Everv six months, the Interagency Testing Committee recommends candidate chemicals to
S :X §2603?) (West 1982) and S Landfair, Tax* Substances Control Act, m Environmental
Law Handbook,.supru note 3,' at 373.
97 TSCA §8, 15 U.S.CA. §2607 (West 1982).
W^ttSLflftflOO new°cheemic" substances have been reviewed through the PMN process.
lOo'^JMsTrjis!? A '§2604 (West 1982). EPA may extend the period for an additional 90
%Z£££%S^^
30
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•- --c .r-:;\—-ay^n ccr.::a:r.ed'-L-. :he. PMX-.as well as on other data that is . •
^erera^v ava:l.ib'.e. '•:..•''• ' . • :- •,
[: ;he EPA deterrrdF.es that the manufacture, processing, distribution/
use, or disposal of the new chemical substance presents or will present an
unreasonable risk to human health or the environment, it must promulgate
requirements to control such "risk.101 EPA may issue a rule limiting or _ _ . ,
conditioning the manufacture of the substance or a, proposed order-totally
banning its manufacture: If data are inadequate to make an informed
determination about whether a.chemical product's risks are reasonable, . V
EPA is authorized to issue, a proposed order prohibiting or limiting the. ' :..
manufacture, processing, distribution in commerce, use,' or disposal of that
• chemical product.102. "" • ' '•;-.. /
3. TSCA's Regulatory Controls , .
When EPA determines that a new' or existing chemical substance presents.
an unreasonable risk to the publichealth or environment,103 EPA has several '
regulatory options to control its risk. The EPA's tools include total bans; limits
on the amount.of the chemical substance that can'be produced, imported, or~-
distributed; arid requirements that the chemical substance bear a warning label.
at the point of sale.104 EPA is required, however, to adopt the least burden-
some regulatory approach when 'controlling unreasonable risks.105 This
means that EPA must-utilize the approach that reduces the chemical product's
risks to a reasonable level given its purported,social and economic benefits.
davs of commencing manufacture/ processing/importation of the chemical substance the '
regulated entity must file a Notice of Commencement (NOC) with EPA, triggering the
. chemical's inclusion on the TSCA Inventory and making it an "existing" chemical. . ._ - •
101TSCA§6,15U.S.CA.;§2605(Westl982). -
102 TSCA §5(e)(l)(A)(i), 15 U-S-CAi §2604(e)(l)(A)(i) (West 1982).- EPA must first show that .
such manufacture, processing, etc. may present an unreasonable risk or that the chemical .s pro-
. duced in substantial quantities and the potential for environmental release is great. The pur-
pose of this provision is to limit manufacture, distribution, use, disposal of a chemical pending
the development of sufficient data for EPA to make a reasoned determination of its risk.
103 In determining whether a risk is "unreasonable," EPA must conduct a risk assessment. EPA
has regulated only six substances under this rule since TSCA's enactment -asbestos (which was
later overturned), polychlorinated biphenyls, chlorofluorocarbons, dioxins, hexavalent
chromium, and certain metal-working fluids. S., Landfair, supra note 96, at 384.
' -104 These tools are authorized by TSCA §6,15 U.S.C.A. §2605 (West 1982).
• 105 r^ocpn iVnf Fitting v Frwirnnmental Pr"t°^ih" Agency. 947 F.2d 1201 (5th Or. 1991).
31
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4. Information Gathering '
,f-=::. '-." i requires EPA to develop and-maintain an inventory of all •
v.~crr.:a. substances manufactured or processed for commercial purposes-in
:he L'rired States.'"-0 To aid in the inventory's development, TSCA requires
rrurufacturers, importers, and processors to report information to the
relevant state or federal agency concerning their chemical production/use
and any possible adverse effects to human health and the environment'that
such production/use may pose.107 Manufacturers, importers, and processors
must also maintain records of incidents involving adverse reactions to health
or to the environment alleged to have been .caused by their chemical
product.108 ' - "':'•'
. 5. Enforcement
Section 11 authorizes EPA to conduct inspections and' require regulated
entities to disclose documents for the purpose of determining TSCA
compliance.109 It also allows the EPA to inspect any establishment where
chemical substances or mixtures are manufactured, processed, stored, or held
before or after distribution in commerce and any conveyance being used to
transport such substances. All items are eligible for inspection including
records, files, papers, processes, controls, and facilities, as long as they bear
some relationship to TSCA compliance. In addition, §ll(c) authorizes EPA to
require the disclosure of materials (including the testimony of witnesses) if ,
the EPA deems such disclosure is necessary to determine TSCA
compliance.110 ...
106 TSCA §8, 15 U.S.C.A. §2607 (West 1982). This list is known as the" "TSCA Inventory." The
first'version of this inventory contained approximately 55,000 chemicals. All chemicals that
are not on this inventory are "new".and subject, therefore, to Section 5's premanufacture
notification requirements. ' .
107 TSCA gg(a)/ 15 U.S.C.A. §2607(a) (West 1982). Regulations are at. 40 C.F.R. §717 (1993).
Examples of the information that must-be provided include the chemical identity, name, and
molecular structure; the categories or proposed categories of use; the total amount of the
substance manufactured or processed for each category of use; a description of the by-products
resulting from manufacture, processing, use, or disposal; data concerning the chemical's
environmental and health effects'; and exposure information.
'10S TSCA §8(c), 15 U.S.C.A. §2607(c) (West 1982). Records concerning employees must be
maintained for 30 years; all other records must be maintained for 5 years. TSCA's reporting
and recordkeeping requirements, are found at 40 C.F.R. §704 (1993). • • . '
109 TSCA §11, 15 U.S.C.A. §2610 (West 1982 & Supp. 1994).' . •
110 TSCA §ll(c), 15 U.S.C.A. §2610(c) (West 1982).
32'
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-••.-.. :i:e=.'.:r.e. EPA uses-a'civil penalty policy -to determine jhe amount c: •• .
_e_^;:.!. -•-;,;. ..v/i'be irhposed. The policy; allows EPA .to.consider the violator's
-u^abiacv, compliance history, financial position, and "other matters" as
>;u5tice. requires when; determining the amount of penalty.112 EPA may also
seize -products in cases where a civil penalty is insufficient to protect public .
health or the environment.113 • "Knowing or willful" violations of .TSCA are
punishable as-crimes that .carry up to 1 year imprisonment and up to $25,000 •
per day of violation.1'14 To prove thatji. violation was "knowing" or
"willful/' some form'of knowledge that a violation occurred must be proven;
however, specific knowledge that a TSCA requirement was violated may not '
be necessary if'the substance is so dangerous-that the-alleged Violator should
have known-that the;substance was regulated.113 ,
TSCA, like most federal environmental statutes,.contains a citizen suit •-•
provision.116' Any significantly affected person can bring a civil action against
. any person alleged jo be in violation of TSCA. The provision also allows ,-
suits against the EPA Administrator for failing to implement a non-
discretionary TSCA duty.117 However, before a citizens' suit action can be ^
brought, the plaintiff must provide the-alleged violator, and the EPA
Administrator with a't least 60-days notice. In addition, if the EPA has
commenced an action against the alleged v iolator, a suit is precluded.
U1TSCA§16,15 U.S.C.A. §2615 (West 1982 & Supp. 1994). . -
112 There are actually two civil penalty policies - one governing §5 violations and the other
governing §8, §12, and §13 violations. The TSCA §5 penalty policy-prescribes administrative
penSoVnoncompliLce with TSCA §5(e) or §5(f). orders and requirements («•*>.&*« *>•
submit a PMN). The TSCA §8; §12, and §13 penalty policy goveiM-reportag and record^eping-
requirements and import/export notification violations. Both pohpes aUow the EPA to reduce
penalties by up to 80% for gbod behavior (e.g., cooperation). S.Landfair, supra note 96, at 393.
& See TSCA §§7 and 17(b), 15 U.S.C.A. §§2606, and 2616(b) (West 1982 & Supp. 1994). Lnder
§7 EPA may conduct an "imminent hazard" seizure absent a TSCA violation.
114 TSCA §'l6(b), 15 U.S.C.A. §2615(b) (West 1982 & Supp. 1994).
115 S. Landfair, suprd-note 96, at 395, n. 147.
116 See TSCA §20,15 U.S.C.A. §2619 (West 1982 & Supp. 1994).
117 id. "''.•'•--., . ' ' • .'-.:.
33
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B. THE MANUFACTURE'USE OF PESTICIDES -- THE'FEDERAL
INSECTICIDE FUNGICIDE AND RODENTTCIDE ACT
The Federal Insecticide Fungicide and Rodenticide Act iFIFRA) was origi-
nally enacted 'In 1947113 -- well before the 1962 publication.of Rachel Carson's •
book Silent Spring, which raised public' awareness* of the environmental risks
of pesticides. FIFRA has been amended several times - most notably in 1972.
The 1972 amendments changed existing law by strengthening its enforce-
ment provisions, shifting its emphasis from labelling and efficacy to protecting
health and the environment,'providing greater regulatory flexibility in control-
ling-dangerous pesticides, extending the scope of federal'law to.cover intrastate
registrations, and streamlining, the administrative appeals process.119.
1. Registration Requirements
Pesticides (i.e., insecticides, fungicides, and rodenticides) are chemical and
biological products that are designed to kill, repel, or control pests and' the .
very qualities that make them effective as pesticides may result in their
environmental risks. FIFRA requires pesticides to be registered with the EPA
' before they are distributed or sold in the United States.120 FIFRA's registration
requirements are designed to review pesticides for toxic effects and to
authorize regulatory action if such effects are found.
Section 3 of FIFRA sets forth registration requirements.121 EPA's decision
to register a pesticide is based on data submitted by the manufacturer in its
118 Pub L No. 92-516, 61 Sfat. 190 (1947). It is codified, as amended, at 7 U.S.C.A. §§136 to
136v (West 1980 & Supp. 1994) and-its regulations are found at 40 C.F.R. §§162-180 (1993).
119
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•e -:j dev.eic::.;--3 The'd'ata must srreci'fv'-the crops and insects
r
•,s-'r,:^h the rest;c:;ie rr.ay he;appiied and :each use must be'supported by;
research data on safety and efficacy.1'14 The -EPA is responsible for analyzing ' .-
the data to determine whether the pesticide has any. unreasonable adverse
effects on human 'health or' the environment within the constraints of the
pesticide's intended uses. -.. , ... •','''
The EPA must approve a registration if the pesticide's composition is such
as to warrant its proposed'claim; its labeling and other materials submitted
with its registration'application comply with FIFRA; it will perform its .. .
intended function without unreasonable adverse effects on the environment;
and "when, used in accordance'with-widespread and,commonly recognized
practice, it will no,t generally cause unreasonable adverse effects on the
.environment.12-- ' , . ' -:. . .
• • 'The term "unreasonable'adverse effects on the environment" Is defined .
in §2;(bb) as ". . . any unreasonable risk to man or .the environment, taking
'into account the economic, social,'and environmental costs and benefits of .
the use of any pesticide."126 'If a pesticide's risks outweigh its benefits, ,=•.."
therefore, its registration may be denied. .Before registration can be denied, .-
however, the manufacturer must be notified of the bases for EPA's •
determination and must be given art opportunity to correct the problem.127
Registrations are valid for five years after which they automatically expire
. unless a reregi'stration petition is received by the EPA, . ,
Section 6 of FIFRA; authorizes' EPA to suspend, cancel, or restrict the use of
a. pesticide if it is found, at any time, to pose unreasonable adverse effects or
122 Registrations are valid for 5 years after which they automatically expire unless.
manufacturers petition for renewal which requires the submission of additional data.
123 Prospective manufacturers are required to submit a registration application, a proposed ^
Label, a statement of all claims to be made for-the pesticide, directions for its use, a confidential
•statement of its formula, and a description of the tests on which its claims are based. E. Elliott
' and E. Thomas, swpra note 92, §17.2CB)(2), at 1290. • '''_••*'
• 124 If the manufacturer needs to "accumulate information necessary to register a pesticide under
Section 3," FIFRA provides for .the issuance of experimental use permits. FIFRA §5, 7 U.S.C. .
§136c (West 1980 & Supp. 1994). Regulations concerning such permits are set forth at 40'CF.R.
§172(1993). •".•• . / ", " ; .,''•.-
123 M. Miller, supra note 119, at 417.
126 FIFRA §2(b)(bj, 7 U.S.C.A. §136(bb) (West Supp. 1994). .. ' '-
127 E: Elliott and E. -Thomas, supra note 92; §17.2(B)(2); at 1291, ". • -. ". :
35.
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__. -a-^.-^s to :-e er.viror.rr.er.:,'--- .Cancellation or suspension '•
•_ -i --i can be a-realed bv a registrant.'•- If EPA needs additional data to
•r.i:r:a:r. registration and that' data-are not submitted, EPA may suspend _the
product's registration. Also, failure to pay FIFRA's registration maintenance
fee is cause for cancellation. • .
Pesticides are registered for general or restricted use.130 Restricted pesticides
are those that EPA has judged to be more dangerous to the applicator or to the
environment. FIFRA requires that registered pesticides be applied only under
the instructions and control of a certified applicator.131 Interestingly enough,
however, FIFRA does not require the certified applicator to be present at the. '
time of application. Certified applicators are certified through state programs
which must be approved by the EPA.132 Certification is designed to ensure that
certified applicators are competent'in terms of handling registered pesticides.1"
2. Labeling
FIFRA also requires all registered pesticides to be labeled in a manner that
specifies approved uses and restrictions.134 The label must specify the
pesticide's active ingredients, instructions on the pesticide's use for specified
,,133
l-s FIFRA §6, 7 U.S.C.A. §136d (West 1980 &' Supp. 1994).
l-9 A cancellation order initiates review of a substance suspected of posing a "substantial
question of safety" to man or the environment. A cancellation order is final if not challenged
within 30 davs. A suspension order immediately bans the production and distribution of a
pesticide It'is mandated only when a pesticide constitutes an "imminent hazard . to human
health or the environment. Upon receipt of a suspension notice, a manufacturer may request an
expedited hearing within 5 days. If no hearing is requested, the.suspension order a effective
unmediatelv. An emergency suspension.!* also authorized under FIFRA. An emergency _
exemption halts abuses, sales, and distribution of a pesucide immediately without a hearing.
Cancellation and suspension orders have generally provided that banned pesbodes may be
used until supplies are exhausted.. Emergency suspensions, however, require the immediate
cessation of sale, use, and distribution.
' 13° FIFRA §3{d), 7 U.S.C.A. §136a(d) (West 1980 & Supp. 1994).
131 Id See. FIFRA §ll(a)-(c), 7 U.S.C.A. §136i(a)-(c)'(West 1994) for certification
requirements. Regulations are found at 40 CF.R §171 (1993). There are several categories of
•pesticide applicators, including private applicators and commercial applicators. Commercial
applicators use or supervise the application of pesticides on property that is not owned by
them. Farmers who apply pesticides to their own land and their employees do not need to be
certified to apply registered pesticides on their land.
132 FIFRA §ll(a)(2), 7 U.S.C.A. §136i(a)(2) (West 1994).
133 The 1975 amendments, however, relaxed the requirements for certification and EPA can no
longer require the examination of applicants. _ w,wt,s ,,., ..
134,, FIFRA §§2(PHq) and 12j(a)(l)(F), 7 U.S.C.A §§136(p)-(q) and; 6,(a)(l)(F) (West
1980 & Supp. 1994). For regulations pertaining to labeling, see, 40 C.F.R. §136 (1WJ).
36
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- 7- .„.-i ;.-•. .:~::3t:o"i or, hc:.v or'-T.er: :: ~ay re use- ••';' <_.jT.^-:-rr.:;-:,.-;-_
•- jr.i are'ic5-:^r.ed to ensure efficacy Butavoid adverse effect en. aa;acent an--
"-j:ure'':rcc>i. nonrarget species and "fee environment, and to minimize •
arrlicacion exposure, It.is a violation-of FIFRA to use a pesticide in a manner '
that is inconsistent with .its label instructions/36 " , .' . •., •:•
3. Reregistration
FIFRA requires EPA to "reregister" older-pesticides -that never underwent
•• EPA's current registration process and, therefore, never underwent a
determination as to whether their use presents unreasonable adverse
environmental risks.137. The'task of reregistering older, pesticides is . .; /
enormous because.approximately 35,000 pesticides were in use prior to :
' enactment of the'1972 amendments which required review of a-pesticide's -..
environmental risks.138 To accelerate the ^registration process, Congress :
imposed a, lO^year reregistration schedule' on the EPA in 1988. ., '.
4. Protection of Trade Secrets
A controversial issue that has arisen concerning FIFRA's implementation
is its treatment of trade secrets'.. Registration data that are submitted by ~ -
manufacturers often contain information regarding a pesticide's active
ingredients and chemical composition, which, if disclosed to a competitor,
might result in the registrant's loss of market share. Section 10 provides that
trade secrets may not'be released, but if the Administrator proposes to release
them, she must provide notice to the company so .that they may file an action
in a United States.district court to determine whether such release is
warranted.139 In, 1978, Congress amended §10 to limit trade secret protection
to. formulas arid manufacturing processes, thus leaving open the possibility
.. that hazard and efficacy data maybe released. . .
135 FIFRA §2(q)(2), 7.U-S.C.A. §136(q)(2) (West 1980 & Supn. 1994). .' -e M„
136 Id. FIFRA's regulations regarding data submissions are found at 40 C.F.R. §158 (1W3).
137 FIFRA'§4,7 U.S.CA. §136a-l (West Supp. 1994). . - •
,138. Although the 1947 version of FIFRA contained a registration process, environmental risks
were not addressed. - . •
139 FIFRA.§10, 7 U.S.CA. §136h (West 1980 & Supp. 1994).
37
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5. Enforcement
5cc::jr. 12' makes it unlawful to distribute or sell to any persons
unregistered pesticides, registered pesticides that are adulterated or misbranded,
and registered pesticides whose claims or compositions are different from, those
disclosed during registration.140 In addition, it is a violation of FIFRA to
detach, aher, deface, or destroy any labeling required by FIFRA or to not comply
with FIFRA's recordkeeping, reporting and-entry/inspection requirements.141
FIFRA also makes it unlawful to "make available for use, or to use, any
registered pesticide classified for restricted use .for some or all purposes other
than'in accordance with" FIFRA and its regulations.142 False data submissions
and registration statements also constitute FIFRA violations.143 .-
Section 26 grants states the primary authority for enforcing FIFRA;
however, state programs must be substantially equivalent ;to the, federal
program in terms of implementation and enforcement.144 EPA remains the
primary enforcement authority in states that do not develop a state program
and, in cases where state programs are not adequately enforced, EPA may
rescind the state's enforcement authority.145
Any violation of FIFRA is punishable by a civil fine of up to $5,000.146
Knowing violations of FIFRA registration requirements may be punishable
by a criminal fine of up to $50,000 and up to. 1 year imprisonment.147
Fraudulent data disclosures are punishable by up to $10,000 or up to three •
years imprisonment.148
140
142
144
143
146
,147
143
FIFRA §12, 7 U.S.C.A. §136j (West 1980 & Supp. 1994).
Id. . •-.'•'•'
FIFRA §12(a)(2)(F), 7 U.S.C.A. §136j(a)(2)(F) (West 1980 & Supp. 1994).
FIFRA §12(a)(2)(M), 7 U.S.C.A. §136j(a)(2)(M) (West 1980 & Supp. 1994).
FIFRA §26, 7 U.S.C.A. §136w-l (West 1980 & Supp. 1994).
FIFRA §27, 7 U.S.C.A. §136w-2 (West 1980 & Supp. 1994).
FIFRA §14(a), 7 U.S.C.A. §i361(a) (West 1980).
FIFRA §14(b), 7 U.S.C.A. §1361(b) (West .1980 & Supp. 1994). • .
FIFRA §14(b)(3), 7 U.S.C.A. §1361(b)(3) (West 1980).
38
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•. C. TH,E REGULATION OF CHEMICALS IN THE WORKPLACE -
THE OCCUPATIONAL SAFETY AND HEALTH ACT
.The Occupational Safety-and Health Act ("OSH Act") was enacted on
December 29, 1970.u9 The federal agency that'is responsible, for the OSH Act's
implementation,.is the Occupational Safety and,Health Administration
("OSHA"). The OSH Act's goal is to assure'safe and healthful working
conditions.for every working man and,woman in the Nation.150 To that end,
the Act'has been successful. It has been estimated'that the incident rate (as -
-defined by the number of'fatalities per 10,000 workers) has dropped 'from :' .
approximately 2.1 to 0.8, meaning that the absolute number of. workplace •
incidents has fallen since 1970 even though' the" working population has - .
doubled.131;',. ,.''', ' '. " '•/ ; •"". * ...'
.' The OSH Act .applies to most private.sector employers/152 however,
facilities that employ 10 or.fewer employees, and certain employment.
sectors153 are exempt from the majority of-the Act's regulatory provisions.
1. Workplace Health and Safety Standards r
, The OSH Act requires OSHA to set workplace standards-that are designed
to provide all workers with'a.safe and healthy work environment.133 the
standards include health standards, which protect workers from exposure to
harmful substances by 'limiting the amount to which workers may be exposed
(e;g:, hazardous substances) and safety standards, which protect workers from
154
149 Pub L No 91-596, 84 Stat..1590 (1970). As amended, it is codified at 29 U.S.C. §651 to 678
(West 1985) and its regulations are found at 40 C.F.R. §§ 1910,1915,1918, and 1926 (1993). .
150 The Occupational Health and Safety Act §2(b), 29,U:S.C.A. §651(b) (West 1985). .-
151 D. Sarvadi, Occupational Safety and-Health Act, in Environmental Law Handbook, supra.
note 3, at 483. " ' '•• V '.-.-... - ,,. ,
152 It has been estimated that more than 6 million facilities and over 90 million employees are
covered by the OSH Act. W. at 484. ' ' , ,
15"3 Excluded sectors mclude certain segments of the transportation industry which are covered
by Department of Transportation regulations, the.mining industry which is regulated by the;
Mine Safety and Health Administration, and the atomic energy industry which is subject to
Nuclear Regulatory Agency standards. . • '-;._.
154 SmaU employers are not exempt from QSHA's complaint and accident investigation
and S^
39
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r;->?,^. rz- ,-^~ =_; , faulty equipment .•-'" These standards rr.ay take a
•. a.-.c:v -: rcrrr.s. including exposure limits, labeling requirements, protective
eju.r~.ent requirements, and monitoring requirements.-57 Section 5 , •
requires employers to comply with these standards.153
When issuing a standard, OSHA must show that a "significant health' risk"
exists from the potentially regulated subs.tance.139 When determining a
substance's risk, OSHA looks at the acute or immediate health effects, chronic
or long-term health effects, and the carcinogenicity'of the substance. Standards
can be set on a generic basis (e.g., all air contaminants) or.on a specific basis
<£?,£,, vinyl chloride). Any person may petition for promulgation of a standard
or the Secretary may act on his/her own .initiative or .on the recommendation
of the National Institute fpr Occupational Safety and Health (NIOSH)-.
2. Hazard Communication Standard
*' * s '
The OSH Act's Hazard Communication Standard ("HCS") is "designed to
reduce the incidence of .chemically-related occupational illnesses and injuries
among employees in the manufacturing sector."160 The HCS establishes
uniform hazard communication requirements for manufacturers and
importers. For example, the OSH Act requires chemical manufacturers and
importers to assess the hazards of the chemicals they manufacture and
import.. This data, termed "hazard assessment data," must cover physical as
well as health hazards.
136 OSHA regulations pertaining to chemicals can be found at 29 C.F.R. §1910 (1993). The
regulations set specific limits on chemical exposures and conditions on chemical usage. Unlike
safety standards, OSHA does not need apply a cost-benefit analysis to a health standard
before "its promulgation. OSHA needs to show only that a substantial risk exists, the proposed
standard is technically feasible, and compliance with the standard will not bankrupt the
industry. Safety standards, however, are subject to a cost-benefit analysis. OSHA must
determine that the standards produce measurable benefits in mitigation workers' risks of injury
and that the costs of achieving them do not threaten the economic viability of the covered
industry. D. Sarvadi, supra note 151, at 488.
l3/ The objective is for the standard to reduce to acceptable levels the risk of injury or illness of
exposed employees. Id. at 489. , • , '
15° The Occupational Health and Safety Act §5, 29 U.S.C.A. §654 (West 1985). Temporary and
permanent variances may be obtained if .employers can establish that they are'unable to
comply with specific standards in the requisite amount of time or that their practices and
facilities provide equivalent protection. Id. at 490.
159 The Occupational Health and Safety Act §6, 29 U.S.C.A. §655 (West 1985).
^° D. Sarvadi, supra note 151, at 517. . .
40
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— :;-•_:'ac'ture:5 ar,d irnco-rters to provide purchasers with a material sarer."
d'3:Ji sheet ;M5D"S">.f0T each chemical they sell. The MSDS states the id-entity
_-: -the chemical, the physical and chemical characteristics of the chemical, .and
.the health hazards of.the chemical.. Employers-must-keep a copy of-the MSDS
in the workplace for each chemical'substance used.
Manufacturers and importers must also inform their workers of ;the ..
hazards that are associated with the- chemicals they manufacture and import.
They are .also required to. train their employees in the handling of such
substances. Manufacturers/importers, and distributors of hazardous
chemicals are also required" to label eadvchemical when it leaves their control
according to OSH Act requirements, . . '.' . '".
' <-. Employers .are required'to'disseminate information to-their-employees •
regarding all hazardous chemicals to which they may be exposed: They must
develop a written hazard communication plan, including a list of^all ..•..'
hazardous substances used in the workplace and a' plan for informing all
employees of those substances'hazards through education or training. :
Employers must also ensure that chemicals in their workplace are labeled _
•according fcrOSHA specifications and that MSDS for all hazardous chemicals7
used in the workplace are available to their employees. - ' -.
3. Recordkeeping/Inspection Requirements
The OSH Act also requires employers to maintain, -annual records of their
employees' work-related deaths,-injuries and illnesses and to report.such
incidents to OSHA periodically.161 Serious injuries or deaths-must be
reported to OSHA immediately. Employers must'also maintain records of
employee exposures to potentially toxic materials or harmful physical agents
for at least 30 years.16* In addition to maintaining records of employee
incidents of death", injury, illness, or exposure, employers must also maintain
records of their efforts to comply with the OSH.Act (e.g., company safety
policies, company inspection -reports, and training records)-.163 •
161 The Occupational Health and Safety Act §8, 29 U.S.C.A. §657 (West 1985). Mmor injuries.
however, are excluded. D. Sarvadi, supra note 151, at 499. - ' - „„
162.The.Occupational Health and Safety Act §8, 29 U.S.C.A. §657 (West 1985). See, 29 C.F.R.
1910.2Q(d)(l)(u) (1993) for regulations regarding exposure reports. .
' ''"• '
41
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—.'.. --H \j: r: ••• i.ie.= for the ir.srectior. of.covered facilities.-7"'
- __ ,_:e farerv ar.d Health Officers are authorized to enter covered
.,-. '-._! i: reasonable rimes; however, employers may refuse entry to any
•--re;:c: 'A'ho lacks a search warrant. Inspection may be triggered by an '
err.koyee complaint or they may be part of a general'inspection, schedule. ^As . _
part of an OSH Act inspection, the inspector may review all of the injury-arid
illness logs that employers are required to maintain.' The investigation may
also review fire'and emergency plans, company safety protocols, and safety
committee minutes.163 ' - ,
The OSH Act authorizes states to.develop and implement workplace safety
programs that are equivalent to the federal program; however, all state plans
' must obtain OSHA approval!166 States may promulgate their own standards
or they may adopt the federally-set,standards. - . .
4. Enforcement • ' '
After OSHA inspections have been conducted, a closing conference
generally occurs at which the inspector and the, employer and employee
representatives discuss the violations that were found. Based on the inspection
and closing conference, OSHA may. issue citations to alleged violators.167
Citations must be issued within six months of an OSHA inspection and
citations must "describe with particularity the nature of the violation."168
Employers are required to post the citation at each location of violation or in
a prominent place for all employees to see for at least three .days:169.
I" See. The Occupational Health and Safety Act §8, 29 U.S.C.A. §657 (West 1985).
165 D Sarvadi, supra note 151, at 492. , .
166 As of 1991,23 states and U.S.. territories had OSHA-approved P~S»«» «£«* ^
emclovees and 2 states had programs that covered only public-employees. I! OSHA approval
Tnot obtained, OSHA retams ultimate regulatory authority for workplace health ui safety m.
those states. If OSHA approval is obtained, the state assumes authonty for the
implementation and enforcement of its occupational health and safety program. Id. at 485
'16'Citations mav allege violations of specific OSHA standards or they may allege violations
of the 'General Duty Clause" ("GDC"). If a standard exists to reduce the risks of * particular-
hazard and that standard has been met, use of the GDC is not available unless the employer
knows that the standard is insufficiently protective. .Before an employer can be cited for a
Son of to GDC, OSHA must find a danger Ithat threatens physical harm to employees.
16'8 The Occupational Health and Safety Act §9, 29 U.S.CA. §658 (West 1985).
169 D. Sarvadi, supra note 151, at 495.
42
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v-:a:::r.i" = re -those which do, nbt'present a hazard to''employee healch or, - .,.
• ^aretv Serious violations, involve those that present'a real potential of'- _
e-rriovee harm. Penalties of-57,000 may be imposed for serious violations,.- -
Furthermore, willful or repeated violations of the OSH Act1 carry penalties of
up to 5/0,000 per violation.171'• : .' ' -' . •
D. AIR POLLUTANT EMISSIONS-THE CLEAN AIR ACT.
The Clean Air Act (CAA)172 was enacted to prevent and control air dis-
-charges of substances.that may harm public health and the environment.1'3 •
Regulated sources include mobile sources (e.g., automobiles, trucks, and
airplanes)174 as well as stationary sources, (e.g., power plants and factories).
The CAA achieves its goals by requiring all new and existing sources of air ' -
pollution to comply with source-specific emission limits "that are designed to
meet health-based,:ambient air175 quality standards. The CAA also addresses
specific air pollution problems-, such as hazardous aifjpollutants, acid rain, ,
and stratospheric ozone depletion. :
The Clean Air Act has been amended eight times. The most significant _
amendments occurred in 1977 and 1990. The 1977 Amendments "fine-tune'd"
the law and added new provisions designed to ensure that clean air 'areas '
™ .The Occupational Health and Safety Act §17, 29 U.S.C.A. §666 (West 1985 & Supp. 1.994).
171 Id- • ' "" • :
172 The legislation known as the Clean Air Act was actually the Clean Air Act Amendments of
1970 (Pub L. No. 91-604,84.Stat. 1713) which amended the 1955 Air Pollution Act. .The 195a act
had oracticallv no regulatory provisions and, instead, relied entirely ori voluntary state efforts
^S^&S^^^-t? Act is codified at 42 U.S.C §7401 et «, (West 1983 fc
^Releases into the air are the primary source of toxic chemicals in the environment. It has .
been estimated that they account for approximatelyseventy percent of anchemicais
discharged into the environment. E. Elliott and E. Thomas, supra note 92, §17.2(B)(1), at 1277.
174 Mobile sources are.the primary source of carbon monoxide emissions in urban areas. They
also contribute one-half of volatile organic compound and nitrous oxide emissions - both of .
which contribute to the formation of smog. -. - ., •
l75 Ambient air refers to the background air, not the ak that is emitted from a pomt source,
such as a smokestack.. Ambient.air standards-allow, some pollunon to be assimilated mto one
invkonmenf while ensuring that the surrounding air is protective of public health and safety
A^bTenTS^ty^andards are also called "media-quality" standards because they are set
•^sedonSelmountof poUudon that is deemed acceptable for discharge into specie _
' environmental media. Tltey differ from technology-based standards which-are se b^ed on the
level of pollution control deemed attainable given available technology. E. Elliott and E.
Thomas, supra note 92, §17:i(B)(3), at 1267, .'
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-.-. ;'_.- r:: re Ji.r::e-'ar.d r.e-.v po!;u::cr. sources -would have to. meet stringer.:'
•crrr.ca: irar.dards The 1990'Arnen'drr.ents significantly.revised the hazard-
ous a:r pollution regulatory.program;'-"6 established a market-based emissions
allcv.-ar.ee and trading program for sulphur dioxide177 and a program for the
phaseout of ozone, depleting substances;178 established a clean-fuel vehicle -
program, created a market for reformulated and alternative fuels, and
required strict tailpipe emission standards in the most-polluted areas;179and
instituted a comprehensive state-run operating permit program that consoli-
dates all CAA requirements that apply to a given source of pollution.130
1. State Implementation Plans : .
States have the-primary responsibility for achieving ade.quate air quality
under the Clean Air Act.181 Sections 107 and 110 require each state to develop
state implementation plans (SIPs)182 that outline how it intends to achieve
national ambient air quality standards (NAAQS).183 '
' The Amendments switched to a primary reliance on technology-based regulations rather >
than health-based regulations that had been difficult to implement.
"' The program is designed to curtail acid rain precipitation which occurs when pollutants,
primarily sulphur dioxide, combine with water vapor, and later fall to the earth in an acidic
form, acidifying waterways and damaging ecosystems. To reduce sulphur dioxide emissions, the
program assigns annual allowances (an allowance is defined as an authorization to emit one ton
of sulphur dioxide) to sulphur dioxide emission sources, primarily coal-burrung power plants.
Sources are not allowed to exceed their allocated allowances; however, they can acquire
additional allowances from other plants or through auction-like sales held by the EPA. This
program reduces the amount of sulphur dioxide emitted each year by limiting the total number
of allowances available, the goal is to halve sulphur dioxide emissions by the year 2000.
1/8 Beginning in 1991, it is unlawful for any person to produce any Class 1 substance (e.g.,
chlorofluorocarbons, haloiis, carbon tetrachloride,'and methyl chloroform) in an annual
quantity greater than certain percentages specified in a table set forth in the statute.
Exceptions are made for essential uses, such as medical devices that use the substance. The
CAA also requires the complete phaseout of the use and production of Class II substances, (e.g.,
hydrochlorofluorocarbons) by the year 2030. .
1/9 The amendments established a'classification system'for areas that have not achieved air
quality standards and require the most polluted areas to institute strict controls, such as
stringent automobile emission standards. ' .
1 fl/1
The 1990 Amendments are designed to cut toxic air pollution and mptor vehicle emissions by
at least 90 percent and to reduce 56 billion tons of air pollutants annually. .Their implementation
is expected to cost $25 billion. Part of .mat cost is a 5-year S2SO million program for retraining
and unemployment benefits for workers displaced by the requirements of the CAA. M. Worobek,
Toxic Substances Control Guide 108 (2nd Ed. 1992).
181 CAA §107, 42 U.S.C.A. §7407 (West 1983 & Supp. 1994).
182 A state implementation plan describes the methods that the state will use to meet air
quality standards that it sets'for the state. . ' '
183 CAA §§107 and 110, 42 U.S.CA. §§7407 and 7410 (West 1983 and Supp. 1994). State
44
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• '•', •• '-. ^f -ire ra:-.or,:'A-:oe irar.'dards! ie: ~v E?A, t.-'i: esrab^i-r, a-ris-..^.- -' - ••'
-•a.-.dard' ^ air -ua^irv across the nation.. They are" set.at level's that protec:.,
-u-'.:: heavth and the ipublic. welfare.'-'Health protective standards are termed '
--•.rriarv"'S.:AAQS.'34 .The welfare protective standards'are termed ^
':secondary" .NAAQS!185 Under the CAA, adverse;effects on public welfare
include effects on soil, water, crops, vegetation,-and wildlife. Because- • .'
secondary NAAQS are designed to prevent" a broader set of.environmental
harms, they are more stringent than primary NAAQS. .However, their
attainment has taken a "backseat" to the attainment/of primary NAAQS due,
to political opposition. - •'..•".-.'- '.'-.-.'
NAAQS have been established for six criteria pollutants - sulphur
dioxide, nitrogen dioxide, particulate matter,186 carbon'monoxide, ozone,1*7
and lead, the NAAQS are implemented through source-specific emission
limitations established by state SIPs. The stringency of. the limitations is ''
dependent upon whether the'sources, are located in a NAAQS attainment or
nonattainment area,188 • '-.''. .• .. • '.
implementation plans use emission inventories and computer models to determine whether air
quality violations will occur. If the data show that exceedances will occur, the state must -=• -
impose controls on existing'sources. States must revise SIPs and keep, them up-to-date and if a-.
new or revised NAAQS is promulgated, states must revise their SIPs within 3 years. See F.
Brownell, 'Clean Air Act, in Environmental Law Handbook, supra note 3, at 121-123.
154 NAAQS are found at 40 CF.R: §50 (1993).
- 18S Id. ' ' . - - ,
186 Particulates are suspended pieces of matter, such as soot, that discharged by air pollution
•sources When inhaled, particulates enter the lung and may cause lung damage or respiratory
problems. Particulate matter that is larger than 10 microns in diameter is regulated under.the
187 Ozone is not a specific pollutant. It is the byrproduct of two specific air pollutants -
volatile organic compounds (VOGs) and carbon monoxide, .these two p.oQutant combine in the '
' presence of sunlight in the troposphere to create ozone which is popularly known as smog.
'88 Areas hot meeting the NAAQS are called "nonattainment" areas. NAAQS are established.
using relatively objective criteria. As a result, they are uniform throughout the nation whereas,
each state's SIP is tailor-made to achieve NAAQS compliance, given the quality of the
airshed; each state's needs, and the technological capabilities of its polluters. For example,
states may allow higher emissions of pollutants in relatively clean air areas or may prohibit
the construction of new stationary sources in areas that have air pollution levels close to the
. NAAQS the 1990 'CAA Amendments require increasingly more stringent emission limitations
' in areas that do not attain the NAAQS. For example, ozone nonattainment areas are classified
' as marginal, moderate, serious, severe, or'extreme. .Although areas classified as extreme ozone
nonattainment areas have 20 years to attain the ozone NAAQS and marginal areas have only
three years, extreme areas must implement more stringent control measures, such as work-
. related vehicle trip reduction programs, than the measures required to be taken in marginal
• non-attainment areas. . • '."'-..- . . :
45
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•. :s ar. example of ''cooperative federalism." Bv .
?:^:_:s :.-,e re-era, government is responsible'for ensuring that the CAA'will
r~ :rrp.=men:ed. but states that .wish to implement the act can assume.primary
responsibility for regulating local polluting activities. Under the Clean Air Act,
:h:s means that EPA establishes NAAQS, reviews state-authored SIPs to ensure
that they will achieve the NAAQS,189 and may take over a state-program if the
state fails to act or acts ineffectively when implementing its SIP.190 '
2. NTew Source Performance Standards (NSPS)
N'ew sources and significant modifications of existing industrial sources191
are subject to more stringent levels of air. pollution control than existing '
sources. The rationale is that as new and modified sources begin operation,
,:hey can adopt the best pollution control technologies whereas existing
sources may have difficulty retrofitting their facilities to include new air
pollution control devices. •
Section 111 of the Clean Air Act requires the EPA to identify categories of
new and modified sources that significantly contribute to air pollution and set
new source performance standards (NSPS) for these sources.192 NSPS reflect
the "degree of emission reduction achievable" through technology that EPA
determines has been "adequately demonstrated" to be the best, taking into
consideration "non-air quality health and environmental impact and energy
requirements."193 Each standard is specific to a given industry and sets the
emission limit that any new plant in that industrial category must meet.
If the EPA finds that a state implementation plan is "substantially inadequate " the
administrator must notify the state and" establish a reasonable deadline for its revision 'CAA
§UO{kH5), 42 U.S.C.A. §7410(k)(S) (West Supp. 1994). ' ' ' •
The state is required to enforce the control standards set forth in SIPs. However, if the state
fails to develop a SIP or enforce a. SIP, the federal government can take over. The federal
government "takes over" by establishing a federal implementation plan (FIP) - the federal
equivalent of a SIP. Prior to assuming a state program, however, the.EPA can impose penalties
on the state for failing to develop an adequate SIP. Penalties include denial of federal
highway funds and the requirement of emission offsets for sources seeking new source permits
Regulations, codified at 40 CF.R. §60.15 (1993), determine when the reconstruction of an
existing facility is so extensive that it triggers NSPS requirements. '
• •CAA §1U' ^ U-SfA- §7411'
-------
•.r.~T- re :;.•= • i; :re rr.;r.:rr.u~ '.eve. _: cor.::^-"; :-;a; carvce :=-•-;-.:= i .'At-'
vr.e'--. or rr-'-'-'-ed sources through the new source revi'ew program. -Because ^
rr.ev a;Y nation-wide standards, NSPS. a'fe intended,to.establish a level• piav';r.g .
•'••^ d throughout the. country and discourage plants from moving to states
•-»*—* O • ''..'* - ' • ' ,
thar have less stringent pollution control law's. ..--..
3. New Source Review
New" sources of air pollution and significant modifications193 of existing
sources are subject to preconstruction review and permitting (New-Source
Review): The New Source Review program .applies to the six criteria
pollutants Tegulated by the NAAQS. The program is usually "implemented
bv -state'environmental'agencies and'the conditions contained in the permits
that they issue depend upon whether the new or modified source is located nv
an."NAAQS attainment or nonattainment area'. Sources located in attainment
areas are subject to the prevention of significant .deterioration (PSD) program
and-sources located 'ft nonattainment .areas are subject to the CAA no'n-
attainment .(NA) program. The emissions limitations required by these
two programs must-be at least as stringent as NSPS. . .' .;;
The PSD program is designed to prevent'deterioration of clean air areas .?,.
that comply with NAAQS. The PSD program 'applies to new. sources that,
have-the potential to emit over 250 tons per year (tpy) of a regulated pollutant
.or over 100 tpy of a regulated pollutant if the source: falls within one of 28
listed source categories. In a PSD" area, before a new source is constructed or ,
before an existing source is modified, the owner or operator must obtain a
permit. To receive a permit under: the PSD program, the; owner/operator
must establish that :(1) the source will comply with ambient air quality levels
designed to prevent deterioration of the current ambient air quality (i.e.; the
source can not degrade the quality of the existing ambient air beyond that
194 The NSPS, like other technology-based standards/ are performance'standards that
prescribe the numerical level of control that must be achieved. Although the NSPS are
derived from considering the control levels achieved by the"best...adequately demonstrated"
technologies, they.are not specification'standards that require the use of a particular control
technology. . '.-.'... • .
195 In general, physical changes or operational changes of an existing plant that increase
emissions above the levels defined as major would be considered "major modifications" that
- trigger NSR. However; routine repair or maintenance would not. E. Elliott and E. Thomas,
supra note 92, §17.2(B)(1), at 1278.
47
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..." •- - :-, ,;•••.=- :rr:--'r ' T5D increments"./-" and ;2>,the source w';ll utilize.
._„ -„,- avai.able centre; technology," I'corr.moniy referred to as "B.ACT V"
•vr e.u-r regulated pollutant193 that it will emit in significant amounts.
The nbnattainment program (NA) applies in areas that are violating the
N'AAQS. It is designed to bring nonattainment areas into attainment. Like
the'PSD, its application to new and modified sources is triggered by emission
amounts, 'it applies to sources that have the potential to emit as little as 100
tpy of a nonattainment pollutant depending upon'the classification of .the area
in'which it will be constructed or modified. For example, in areas that are
classified as extreme ozone nonattainment areas,199 new or modified sources
having the potential to emit as little as 10 rpy of ozone precursors.(volatile .
organic compounds and nitrous oxides) must receive a'nonattainment permit
before construction and operation may commence.200 -
The PSD and nonattainment programs are administered'on a.pollutant-by-
pollutant basis and areas that are in attainment for some regulated pollutants
may not be in attainment for others. Asa result, new or modified sources may
have to obtain both PSD and nonattainment permits and sources located in a
• "clean" or PSD area may have to meet more stringent requirements if their
1961A source in a PSD area must conduct continuous onsite air quality monitoring for one year
prior to its operation in order to determine the effect that its emissions may have on the air
quality. The monitoring data are used to establish a PSD baseline which is then used to
determine the incremental increase in pollution that will be allowed in the area. E. Elliott
and E. Thomas, supra note 92, §17.2(B)(1), at 1281. .
197 BACT is defined as "the maximum degree of [emission] reduction-achievable, taking into
accost economy/energy, and environmental factors. CAA §169(3), 42 U.S.CA. §7479(3) (West
Tupp 1994° B^T mufTbe at least as stringent as any NSPS applicable to the source category.
Bv statute, BACT determinations may take into account a broader array °"f'°* *^^*
(which will be discussed infra in relation to the NA-program), however, EPA has begun to take .
1 '^down' approach when promulgating MACT standards beginning with the most stnngent
controls available and ruling out less stringent controls only if they are not achievable in terms
of the statutory factors. Id. at 1280. .
193 Traditionally, the CAA was interpreted to require BACT for both criteria pollutants as
well as hazardous air pollutants. However, the 1990 Amendments explicitly state that
substances listed under the new air toxics program are not subject to the PSD program and,
therefore, not subject to BACT. «•„„„».
• l99 As of 1992 Los Angeles was the only area classified as an "extreme' ozone nonattainment
area. Nonattamment of ozone is likely to be the most significant NA consideration for ..
chemical plants that discharge volatile organic compounds - a precursor or ozone. E. Elliott .
and E.Thomas, supra note 92, §17.2(B)(1), at 1279.
• =00 It is recommended that new and modified sources in NA areas begin the penrut application.
' process at least one year prior to construction of the source since the permitting authority has up
to one year to issue the permit. Id. at 1281. •
48
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:cr.:r-.bu:e.J3 "a- violation .of-the NAA'QS ;.r.;r = a:r;. : •
N'onattainWent permits also must include-a' requirement that new or •;• • -
T.c-iified sources will meet a techno logy-based emission standard-that, is
based on-the "lowest .achievable emissions rate" (known as "LAER"}/ LAER
is based on "the most stringent emissions limitation" contained-in any SIP or
'that has been"achieyed; in practice" by the same or similar source category, ;
whichever is most stringent.202 : " ': / . .
• 'in addition, a new or modified source must obtain offsets (i.e.,'reductions •
in emissions of the same pollutant) at a greater than 1-1 ratio before com-.
• mencihg operation.203 Offsets ensure that new sources will not increase the;
amount of air pollution in the area and, over time; that the, nonattainment
area will move toward attainment. The 1990 Amendments require/in more .-_
severe nonattainment areas, higher offset ratios. For example, in extreme
ozone nonattainment areas, the offset ratio'is 1.5 to l.Q.20* In addition, the
dwner/ operator'.must certify that all of its other sources are in compliance or
are scheduled to comply with all applicable.air quality requirements and that
the benefits-of the proposed new or modified source outweigh,its
environmental and social costs.205 • "•
4. Hazardous Air Pollutants
' Section 112 of the CAA requires EPA to establish national technology-based
emissions-standards for hazardous air pollutants.206 Hazardous air pollutants
. 2Q1 Id. at 1278. -.- ' , ••'',' -.•-.' •''•"'••,•'
202 CAA §171 42 U.S.C.A. §7501(3) (West 1983). In ozone nonattainment areas, new and
modified source must install "California technology" since'the extreme ozone problems in
that state have resulted in the development of state-of-the-art technology. Id. at 1279. •
203 "CAA §173(c)- 42 U.S.CA. §7503(c) (West Supp. 1994). The offsets can be procured through
i other facilities or they can come from within the same facility' (e.g., by installing additional
controls on existing production lines or by shutting ^them down). The offset must be of the same
pollutant however.
504 CAA §182, 42 U.S.C.A. §7511(e)(l) (West Supp. 1994). ,
205 CAA §173(a), 42 U.S.C.A. §7503 (West Supp. 1994). . . . , •
206 These standards are termed NESHAPs - National Emission Standards for Hazardous Air
Pollutants, Prior to the 1990 Amendments, -hazardous air pollutants were regulated through
' harm-based standards. The standards were'.to be set at a level that in the judgment of the EPA
was adequate to protect the public health..:with an ample margin of safety, CAA §112(b).(U
(B) 42 USC A §7412(b)(l)(B) (West 1983). In light of the difficulty EPA experienced when
' attempting to set such standards (standards had been established for only eight hazardous air -
pollutants), Congress replaced the health-based mandate with a technology-based one in .the
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T', -:.-.;..v -cr'ired as co'.lutants, ctner cr.an criteria poi.uta:
e\r i-re to which 'may reasonably be anticipated to result in an increase in
m:r:il:r.' c: an increase in serious irreversible, or incapacitating reversible/
-.ilr.ess. '--" However, that definition was 'replaced in the 1990 Amendments by
'a list of 159 pollutants that Congress statutorily determined were hazardous.208
Any stationary source that emits more that 10 tpy.of any listed hazardous
air pollutant or ,25 rpy of any combination of listed hazardous air pollutants is
considered a major source and is subject to §112. In addition, a source may be
subject to hazardous air pollutant regulation under an "area source" program,
which EPA must develop within five years of the 1990 Amendments' •
enactment.209 ..' . .
EPA is required to publish a list of major source and area source categories .
and a draft schedule for promulgation of emission standards for each source.
category.210 Tor each source category, EPA is required to promulgate standards
that require installation of technology that will result in the "maximum
degree of reduction" that EPA determines is "achievable" (these are termed
1990 Amendments. See, CAA §112(d), 42 U.S.C.A. §7412(d) (West Supp. 1994). Nevertheless, ,
even though these standards are now technology-based, Congress provided for a second phase
of regulatory control to ensure that the standards are sufficiently protective. Id. For known or
suspected carcinogens, further control may be required if the new technology-based standard,
known as MACT (see, infra), does not reduce lifetime risk to a level of less than one in one
million. The health-based inquiry would occur no later than eight years after promulgation
of the MACT standard.
207 CAA §112(a)(l), 42 U.S.C.A. §7412(a)(l) (West 1983),
208 See CAA §112, 42 U.S.C.A. §7412(b) (West Supp. 1994). The rationale behind the list
was to reduce delay in EPA's identification of hazardous air pollutants which, prior to the
amendments, had proceeded very slowly oh a pollutant-by-pollutant basis. The statute
provides for delisting substances if the EPA can show that "there-is adequate data' to
determine that a substance "may not reasonably be anticipated to cause adverse effects to
human health or adverse environmental effects." EPA can also add substances to the list.
E. Elliott and E. Thomas, supra note 92, §17.2(B)(1), at 1282.
209 Area sources are categories of small sources, such as dry cleaners, that the EPA determines
present a threat of adverse effects to human health or the environment. See CAA §112(c)(3),
42 U.S.CA. §7412(c)(3) (West Supp. 1994). .
210 The amendments require the EPA to develop technology-based MACT (maximum
achievable control technology) standards on a tight statutory schedule. EPA must establish
MACT standards for 41 source categories within 2 years of enactment, 25% of total source
categories within 4 years, and additional 25% of the sources within 7 years, and all sources
within 10 years. MACT standards become applicable to all and new existing sources three years
after oromulgation. If the deadlines are not met, a statutory "hammer" is triggered winch ^
requires "states to develop emission limits when permitting facilities.that are "equivalent to
• the stringent MACT-standards established in the New Source Review programs. E. Elliott and
E. Thomas, supra note 92, §17.2(B)(1), at 1283-1284. ,
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- , . „ - ..-... , . \ f ,
-.•.-.IT V;.r..i.::d5 •':o: " ~a\.~u~ ijA^a^e ocnrrCi tecrlr.J .-J-^.- •. "" ----^- .
~:i.--a:^i —use.-provide an ample rnaigin.ol safety :o_protect the mos-c sensitive.
' *-div;duat5.:-: . If an existing source can demonstrate that it has achieved or ,
-,%•;;•; achieve a reduction of 90 percent -of hazardous air pollution emissions
before promulgation of MACT standards, it may be eligible for a six-year
extension "of its MACT compliance deadline.213 ' '• - . ":
The 1990 Amendments also established a. program to address and investi-
gate accidental releases of toxic chemicals. The program requires the" EPA to
list-100 substances that pose the greatest risk-of death or serious injury in the
event of release and requires owners and operators of facilities handling such
substances to take risk, management measures that are necessary-to prevent '•'
the substances'Accidental release.214 In addition, the program creates, a
, Chemical Safety and Hazard Investigation Board which is authorized to- • .'.
conduct a broad range-of investigatory, research and advisory functions, '^ '
including promulgating regulations for accidental release reporting:21^ • <• ;
5. Permits for Existing Sources
The 1990 Amendments require states to develop and implement an
operating permit program for existing, air pollution sources. The program •=•
is intended to consolidate in a single document all federal and state .
regulations that pertain to each source in order to facilitate compliance and
enforcement.216. Under this program, sources must submit a:permit
application to, the permitting authority within one year after the permit
211 CAA §112(d)(3), 42 U.S.CA. §7412(d)(3) (West Supp. 1994). MACT standards are
designed to provide for emission reduction of approximately 95%. Under the MACT standard
development process, EPA looks at a group of facilities that are similar, such as industrial
boilers and bases-the MACT standard on the emissions that are achieved in practice by the
least^mitting 12 percent of existing sources. In setting a MACT standard, EPA.is required to
consider the emissions, of all hazardous air pollutants as opposed to regulating emissions on a
pollutant-by-pollutant basis; however, EPA can consider factors such as the cost of achieving
such emission reduction and any non-air quality health and environmental impacts and energy
requirements. Id. at 1284-1285. •, -• , , r •
21* The amendments also require the. EPA to assess the residual health risk remaining after .
MACT controb have been implemented. This review is scheduled to occur after the year 2000.
CAA §112(f), 42 U.S.C.A. §74l2(f) (West Supp. 1994). ,
213 See CAA §112(i)(5), 42 U.S.C.A. §7412(i)(5) (West Supp. 1994). .., '
214 CAA §112(r)(l), 42 U.S.C.A. §7412(r)(l). (West Supp. 1994).
.,215 CAA §112(r){6), 42 U.S.C.A. §7412(r)(6) (West Supp. 1994).. , ,=
216 F. Brownell, supra note 183, at 140. ' .
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;::'e:tivc ::" The application must include a cornptiar.ee
l',r :^:;J-,:n^ ro-A- the source plans to comply with all applicable. federal and
i:a:e 4.:' roliurior. requirements.--'3
\Vi:hir. sixty days of receipt, the permitting authority must determine •
whether an application is complete. Unless the permitting authority requests
additional information or notifies the applicant that the application is
deficient, the application is. deemed complete. .Within 18 months, the
permitting authority must take final action on the, application.219
Permits must contain all of a source's air emission obligations and each-
source is required to report periodically on its compliance with permit.
conditions. Permit amendments are required if certain operational changes
occur that result in emission increases; however, the law provides for states
to include operational flexibility into their permit programs, enabling sources
to make minor adjustments that do not significantly increase their air
emissions without undergoing permit revision procedures. •
6. Enforcement
Violations of the Clean Air Act are subject to both civil and criminal
penalties.220 Civil penalties can consist of injunctions or monetary fines of
up to 525,000 per day of violation. The CAA imposes criminal liability on
"any person" who knowingly violates the statute and "persons" can include
corporations and partnerships in addition to individuals who directly cause
violations. The 1990 Amendments increased the fine for knowing violations
to 5250,000 per day and up to 5 years imprisonment.. Corporations' may be
fined up to 5500,000 per violation. Repeat offenders may face doubled fines.
217 ^n interim/ partial, or "full permit program is effective upon approval by EPA. If the state
fails to develop knd implement a permit program, EPA must establish a prograrn which ,
S^ffi^pon^idga^n. See; CAA $902(1), 42 U.S.CA. §7661a(i) (West Supp.
1 ^ste CAA §503(b), 42 U.S.C.A. §7661b(b) (West Supp. 1994). Section 504(0 of the CAA
provides ^at compliance with the permit shall be deemed ^ compliance v-th apphcable
provisions of the Act if the permit includes applicable requirements or d the perrrutting
Tthoritv deem, that such requirements, are not ^^^^^
in the permit. This is called the "permit shield." CAA. §504(f), 42 U.S.C.A.
Supp. 1994).
CAA §503(0, 42 U.S.C.A. §7661b(c) (West Supp. 1994). For permit requirements,
see 40 C.F.R. §70.6(c) (1993). ,«,,,'•
220 CAA §113(b)-(c), 42 U.S.CA. §7413(b)-(c) (West Supp. 1994).
52
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' '.'.-..-:.:-r.i rcr which criminal perVa^ies may be-sought include're^ri- .
see-:r.; v;c;a,t:oAS and .failure to pay permit fees. Further; "knowing" ;
releases of any hazardous au pollutant or "extremely hazardous substance"
which place another person in "imminent danger of death,or serious bodily ' •
injury" are subject to fines of up to 5250,000 per day and up to 15 years . . •
imprisonment. Corporations may be fmed up'to-$1 million. Actual know-.'
'ledge that 'individuals may be harmed must be proven for tfiese fines to be
imposed; however, "negligent"-(i.e., careless) releases that place other ..
individuals in "imminent danger of death or serious bodily injury" are
punishable by fines of up to $100,000 (corporations may be fined up to
$200,000) and imprisonment for up to one year. ' • •
The 1990 Amendments authorized the EPA to bring administrative
enforcement actions against violators.221 Such-violations are subject to ' -
$200',000 ,'fines. The fines can be higher if the EPAand the Department of •
Justice agree that a more severe penalty is warranted. The Amendments also
established a "field citation": program for minor violations'which allows EPA
officials to issue fines of up to $5,000 per day of violation: .' . ' '
The Amendments also authorize citizen suits, seeking civil penalties, .
against; persons (including the EPA Administrator) who allegedly violate the
CAA's requirements.222 Any money that is obtained through citizen suits is
deposited into a fund that helps finance EPA's enforcement efforts. Plaintiffs
must provide^the EPA, the state, and the .alleged violator with notice of their
intent to bring a citizen's suit 60-days prior to commencing such action and,
if the federal or state has already commenced an action, a citizen's suit is
•precluded. . .
221 CAA S113(d) 42 U.S.C.A. §7413(d) (West Supp. 1994). In an administrative enforcement
action, the EPA must 'first-notify the violator of the alleged violation. The alleged violator ,
has 30 days to request an adjudicatory hearing. , - .
222 CAA S304 42 U S C.A. §7604 (West 1983 & Supp 1994). Prior to the Amendments, although
citizens had a'right to bring an action against EPA for failing to enforce -tr**ct or gainst a
particular source^ violations, their only remedy was an order requiring EPA to enforce the act
or an order forcing the source to comply. .
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E. WATER POLLUTANT DISCHARGES'-- THE CLEAN WATER ACT
T>- Clean Water Act was enacted into law on October IS, 1972.:23
Alrhc u.-r :he law was not the'first federal statute regulating discharges of
rcllu:an:5 tr.to the nation's surface waters;224 it was the first statute that
authorized a comprehensive federal water pollution control system that
was designed to reduce such discharges.225
The stated objective of the Clean Water Act is "to restore and maintain
the chemical, physical, and biological integrity of the Nation's waters."226
To that end, its goals are: (1) to eliminate all discharges of pollution into the
nation's waterways (the" "zero discharge" goal), and (2) to make the nation's
waterways suitable'for fishing, swimming/and recreation (the "fishable and
swimmable"" goal).227 Although the statutorily set deadlines for achieving
both goals have passed and the goals have not been met,223,^ Clean Water .
Act is still considered to be a success largely because industrial discharges into
the nation's waterways-have dramatically decreased since its enactment.
The Clean Water Act has two basic components: the National Pollutant
Discharge Elimination System permit program and the Publicly Owned
• ' 2">9
Treatment Works construction program.4"-
223 Pub L No 92-500, 86 Stat. 896 (1972), codified at 33 U.S.C.A. §§ 1251. ft seq. (West 1986 &
SUDD 1994). Its regulations are found at 40 CF.R. §§100-140, §§400-470.(1994). The Act is cited
as 'the Federal Water Pollution Control Act however, it is commonly referred to as the Clean
Water Act. , '
224 The Refuse Act of 1899"was the first. 33 U.S.C.A. §407 (1986). The Refuse Act was largely
an anti-litter statute that was-enacted to keep navigable waterways free of debris in the
interests of commerce, ft was a precursor to the CWA in that it prohibited all discharges into
navigable waters unless a'permit was obtained from the Army Corps of Engineers.
225 «N;avigabie waters" are defined by the statute as "the waters of the United States
including the territorial seas." CWA §502(7), 33 U.S.C. §1362(7). Although -courts have
interpreted the phrase "navigable waters" broadly (wetlands, drainage ditches, mosquito
canals, and intermittent streams have been determined to be navigable waters), the statute
does not extend to underground water sources - unless they are hydrologically connected to
surface waters. Such sources are subject to the regulation provided by the Safe Drinking Water
Act which will not be discussed, in this Guide.
226 CWA §101, 33 U.S.CA. §1251 (West Supp. 1994).
227 CWA §101(a)(lM2), 33 U.S.C.A: §1251(a)(l)-(2) (West 1986). ' •
223 The "zero discharge" goal was scheduled to be met by 1985 and the "fishable and swim-
mable" goal was scheduled to be met by July 1,1983. Statutory goals are not legal mandates, .
however; but they do illustrate how Congress intended the act to be implemented and are
Important in statutory interpretation. . „-»—,., v
-^This program originally provided grants to Publicly Owned Treatment Works (POTWs) so
' that they could upgrade from primary to secondary treatment. Federal grants were available •
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r
1. The Control of Point Sources ' ~, ;
, The Clean Water Act's success is directly tied to the National Pollution
Discharge Elimination System (NPDES),which requires point sources .to obtain
permits before discharging pollutants into navigable waters.23-0 The statute
classifies water pollution sources as point sources or nonpoint sources. A
ppint source is defined as "any discernible, confined and discrete conveyance'. .
. from, which pollutants are or may be discharged."231 An example of a point
source'is a discharge pipe.. "Point sources" are further divided into municipal
point sources (also known as "publicly owned treatment works" or "POTWs")
"and industrial point 'sources. - '.. - ' . ' . • '
The Clean Water Act defines a pollutant as "dredged spoil, solid waste,
incinerator residue, sewage, garbage, sewage sludge, munitions, chemical
wastes, biological materials; radioactive materials, heat, wrecked or discarded
equipment, rock, sand, cellar dirt and industrial, municipal, and agricultural
waste discharged into water,"232 Unpermitted discharges constitute .
violations of the. act and are subject to civil and criminal penalties. . , ',
Like the Clean Air Act, the Clean Water Act represents a federal-state
regulatory partnership. The federal government promulgates national stan^
dards (e.g., effluent guidelines) but the states are given considerable flexibility"
in achieving those standards through EPA-approved state permit programs.233
for as much as 55% of total project costs. Grants, having no repayment obligation, were
generally available for as much as 55% of the costs. 'The 1987 amendments converted the grant
program into a revolving loan program that enables municipalities to obtain low interest loans
which must be repaid. , • •„„„„. . •• i
230 See CWA §402 33 U.S.C.A. §1342 (West 1986 & Supp. 1994). More than 65,000 industrial
and municipal point source dischargers must obtain NPDES permits. Dischargers are required
to submit applications at least 180 days before their discharges are scheduled to begin that
contain information about the point source and its expected pollutant discharges. See 40 CF.R.
5122 21 (1994) Based on this information, the permitting agency determines the levels of
effluent discharges that will be allowed. Permit applications are subject to public review and
comment. See, CF.R. §122.1 (1994). ' . •-• •
231 CWA §502(14), 33 U.S.C.A. §1362(14) (West Supp. 1994);. Under the Clean Water Act,
any source of pollution that does not meet the definition of a point source is termed, a "nonpoint
source " For example, agricultural runoff is a nonpoint source because it does not enter navigable
waters through a discrete conveyance, It is' very difficult to regulate nonpoint sources because
' they are not susceptible to traditional forms of regulation. As a result, the CWA has not been
successful at controlling nonpoint source pollution which represents the greatest remaining
contributor to water quality degradation. , •
232 CWA §502(6), 33. U.S.C.A. §1362(6) (West 1986). Courts have broadly construed the term
to include virtually all waste material. , . •
• " 233 A state can administer a NPDES permit program if the program meets federal standards.
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If a stare does not implement and enforce its program in .accordance with
OVA requirements; however, the EPA can take over the state program.
'NTDE5 permits contain effluent limitations234 with which-the regulated ,
eotnt source must comply. Effluent limitations can mandate the adoption of
specific control technologies (e.g., the installation of specific pollution control
equipment) or compliance with numerical limits that specify the amount of
discharge that is permitted on a pollution-specific basis (the amounts are
based on units of production, with a maximum daily allowance and a
, monthly limit).235 , . •
When drafting effluent limitations for an NPDES permit, the permitting
authority (which is the state in most cases) uses effluent guidelines that have
been set'the EPA and water quality standards that have been set by the state.
Effluent guidelines determine the minimum level of effluent limitation that
will be required of all dischargers within a particular source category. These
guidelines are determined for categories of industrial dischargers by examin-
ing the levels of control that can be achieved through the use of various
levels of technology.236 • '
State water quality standards are based on the quality of the receiving
waterbody. The standards designate the waters' intended uses (e.g., recrea-
tional or industrial) and the conditions that are necessary to continue those
uses. The water quality standards that are established must be maintained
and uses that would degrade the quality of a designated waterbody are
prohibited, except under strict conditions.237
As of August 1992', 38 states and territories had approved NPDES programs. Stat^issued
•NPDES permits are'subject to EPA review and may not be issued if EPA objects within 90 days.
234 Effluent limitations are defined as "any restriction established by a State or the
Administrator on quantities, rates, and concentrations^ chemical, physical, biological and
other constituents which are discharged from point sources" into navigable waters. CWA
§502(11), 33 U.S.C.A. §1362(11) (West 1986). . '
-33.Traditionally, only conventional pollutants were regulated (e.g., biochemical oxygen
' demand (BOD), suspended solids); however, permits now regulate toxic pollutants due to
provisions contained in the 1987 Amendments.
236 See 40 C F R §§400-471 (1993 & 1994) for EPA's effluent guidelines. Effluent guidelines are •
periodically reviewed and updated as.technology improves and economic.feasibilitychanges.
Over time they require regulated entities to achieve higher and higher levels of pollution
•control. Point sources may obtain variances from their requirements. One way a-perrruttee can
obtain a variance is by showing that the-guideline should not apply.to its facility because of
factors that are fundamentally different from those considered when the guideline was issued. -
23"See, 40 C.F.R. §131-(1994).
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-' E:':":uent- limitations, therefore,, are tailored'to Account'for both the'industrial •
classification of the point source arid..the. water.quality- of the receiving water- .-
body. • An effluent limitation may be more stringent than the EPA-set effluent,
guideline if the water quality of the receiving waterbody warrants a stricter ...
Standard. Permits must be reviewed and reauthorized every five years;238 even
during their effective period, they are subject to revocation or modification.239 '
NPDES permits also establish monitoring and reporting requirements.240
Permit holders, must collect data, monitor .their discharges; and keep records
of the pollutant levels of their effluent. Permit holders are required to submit
those records to'the-administrative agency that issued their NPDES permit so
the agency can verify that the permit limits are riot being exceeded. Permits
• also allow the permitting agency to enter the premises of the discharger at any
reasonable'time to inspect records .and to take test samples to'determine ; • . -;.
compliance-with the CWA.241
Industrial sources;that discharge into sewers '(and, therefore, indirectly '
'-into surface waters through POTWs)'do not need to-obtain an NPDES permit;
however> they, must comply with pretreatment standards that are promul-
gated by the EPA.242 Such sources are called "indirect dischargers."243 , - _ »
Pretreatment standards require indirect dischargers to treat their waste "'
prior to discharge in order to,remove the'worst or the most toxic pollutants,
preventing the "pass; through"244 of pollutants into receiving waterways
238 In order to reissue an NPDES permit, the permittee must establish that the point source can
comply with more stringent criteria if they have been promulgated since the permit was
originally issued. The permit renewal application must be submitted 180 days before
expiration of the existing permit. ••'
23§ See, 40 CF.R. §122.46 (1994). * '
, 24° CWA §308,33 U.S.C.A. §1318 (West 1986 & Supp. 1994). For regulations pertaining to
monitoring and reporting requirements, see. 40 CF.R. §122.48 (1994).
241 The data required by NPDES are subject to public disclosure and may result in
'commencement of a citizens'enforcement suit. , .
242 CWA §307, 33 U.S.C.A. §1317 (West 1986 & Supp. 1994). They also may have to obtain
permits from state and local authorities.
$43 It has been estimated that approximately 15,000 companies discharge their wastes into
local sewer systems and, therefore, indirectly into navigable waters through PQTWs.
M. Worobek, supra note 180, at 170. . ' nfv~>,~'
244 "Pass through" occurs when POTWs are unable to neutralize pollutants. Many POTWs are
unable to treat certain industrial Wastes. These wastes, if not pretreated, travel through the ^
PQTW untreated and could disrupt operation of the plant-by destroying or blocking the POTWs
mode of treatment As a result, certain wastes are prohibited from being discharged into
POTWs. See, 40 CF.R. §403.5 (1994). ,
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•A--cr. cou.d degrade water quality or into sewage sludge'which could-increase
d-.-ccsa: costs. They also eliminate any competitive advantage that indirect
dischargers may have over direct dischargers.24-
rrecreatment standards are promulgated by EPA and reflect the best .
available control technology ("BAT").246 Pretreatment standards are designed
to result in the same level of'treatment that is achieved by direct-dischargers.
Point sources can obtain removal credits that allow for some relaxation in
applicable pretrearment standards. Removal credits are based on the receiving
POTW's demonstrated capability to consistently remove a particular pollutant
through treatment.247 Pretreatment standards are usually written into
effluent guidelines which are enforced through the POTW's NPDES permit; .
however, the permitting authority can also enforce pretreatment.
requirements directly.
2. Dredge and Fill Permits ' ' .
The United States Army Corp of Engineers has primary responsibility for
implementing section 404 which requires dischargers to obtain permits before
discharging dredged or fill materials into navigable waters, including
•wetlands.248 The Corp of Engineers is authorized to bring enforcement actions
to collect civil fines of up to $25,000 per day and to compel violators to restore
filled areas.249
3. Discharge of Oil/Hazardous Substances
Section 311 prohibits the discharge of-oil or hazardous substances into
navigable" waters and provides mechanisms for the clean up of oil and.
245 Without pretreatment standards, direct dischargers would be at an unfair disadvantage
vis-a-vis indLrect dischargers because the CWA requires direct dischargers to pay for the costs
of treatine-pollutants contained in their effluent.
m They are based on treatment results that are achieved when the best available control
mwaee into account the fact that a POTW may be able to treat indirect
discharger's pollutants effectively. As a result, they enableJndirKectpd^ar8" £ *^d
treating effluent that will be effectively treated once it reaches the POTW. }. Arbuckle,
• supra note 9, at 178. . • . ..
2« CWA S404 33 U S C A. §1344 (West 1986 & Supp. 1994). EPA has veto power over all
dredge andfiU permits issued by the United States Army Corp of Engineers. Certain types
of activities are exempted from §404. They include certain farming, ranching, and forestry
'
ractices.
58
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ra^ardous substance' spills, and- other -releases. :5° Any, person m charge or A
• vessel-or facility must notify the National Response Center, which is run by "
'the Coast G'uard, and state officials whenever .a designated -substance is spilled
. "in certain quantities.231. Any'persori who"fails-to notify officials under this •
provision is subject to 5 years imprisonment. Section 311 also created an
emergency fund, like that of Superfund,252 which can be used to pay for the
cost of cleaning up oil and hazardous substance discharges into navigable .
waters. Discharges of oil or hazardous substances.into the environment are
punishable by civil penalties of up to $250,000 and responsible parties are also
liable for .cleanup costs; . ' . '. . ' -;-'-•"
4. Enforcement
The EPA may- issue a compliance order or bring.a civil suit in a United--
States district court against persons who violate'the terms of an NPDES or a
dredge and fill permit. The 1987 amendments increased civil penalties from
$10,000 per day of Violation to $25,000 per day.2?3 The amendments also
outlined a number of factors that courts cari weigh when determining civil .
fines.254 They include the seriousness of the violation, the economic benefit
that resulted from the violation, and the facility's history of violations.. Civij
actions may also seek injunctive relief (e.g., shutting down the facility and,, *
thereby, restraining or abating illegal discharges).
Criminal penalties are also authorized under the Act.255 Negligent (i.e.,
' careless) violations of the Act may be punished by up to $25,000 per day of
violation, by 1 year imprisonment, or both. Second violations may result in
a.fine of $50,000 per day of violation or 2 years imprisonment.; "Knowing"
violations (i.e., acts that were' done with-the'knowledge that they violated the
CWA), are punished still more severely (up to $50,000 per day of violation
and up to 3 years imprisonment; second violations are punished by;up to
250 CWA §311, 33 U.S.CA. §1321 (West 1986 St Supp. 1994). ;
251 EPA has designated approximately 300 substances as hazardous when spilled or
discharged arid has established a "reportable quantity" for many of these substances.
, See, 40 CF.R. §§109-117 (1994). - - - " . . -•
252 The "Superfund" is a pool of money, created by a tax on petrochemical feedstocks, used to
clean up abandoned and inactive hazardous waste sites under the Comprehensive Ehvkonmen,
ta!Response, Compensation, and Liability Act (CERCLA). CERCLA will be d^cussed m/r*.
253 CWA §309, 33 U.S.C.A. §1319 (West 1986 & Supp. 1994). •
:. 254w. ••-.. .- •'-. ••'• - • • .- :-:'•••':".•.
•-.25sM. . \ • , .. . • •. . - v:.- • : .
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51 • -.::: re: ,Uv aha up to 6 years imprisonment). "Knowing endangerment"
v-c;a:'.;r.i, vvn:ch occur when a -person acts with the intent to violate the Act
L~Tw~;n the knowledge that the action will subject others to the risk of
sencus'bodily injury .or death, can be punished with the maximum $250,000
fine or up to' 15 years imprisonment (again, second violations can result in
doubled penalties). Under this" provision, an organization can be fined up to
S1,GCO,QOO.-S6 Violations that 'involve false reports or illegal monitoring are
subject to a 510,000 fine and up to two years imprisonment.
Enforcement actions can be brought by the federal government, the states,
or in certain cases, citizens.257 Citizens may bring a citizen suit in a U. S. district
court against persons who violate prescribed effluent limitations or against the
EPA administrator for failing to implement a nondiscretionary CWA duty.
Before a citizen suit can be brought,, however, 60-days notice must be given to .
the federal or state agency responsible for implementation of the act.
F. DISPOSAL OF HAZARDOUS WASTES -
THE RESOURCE CONSERVATION AND RECOVERY ACT
The Resource Conservation and Recovery, Act (RCRA)258was enacted in
1976 to control the land disposal of solid wastes, encourage recycling, and
promote the development of alternative energy sources that use solid waste
as a feedstock. The term "solid waste" is a misnomer in terms of RCRA since
RCRA regulates liquid and gaseous wastes that technically are not "solid."
RCRA regulates the land disposal of discarded materials,260 including both
256 CWA §309, 33 U.S.CA. §1319 (West Supp. 1994).
* .
Supp 1994) ROWS regulations are found at 40 C.F.R. §5240-271 (1993). RCRA actually
amended I tie Solid WasK Disposal Ac, (SWDA); however. IB v««d» nB w«e y
comprehensive, the resulting set of laws is commonly called RCRA although the SWDA
/ocuses on disca,ded mate^. As , result
accumulated speculatively. E. Elliott and E. Thomas, supra note 92, §17.2(C)(1), at 1311.
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hazardous "and nonhazardous solid waste. RCRA's Subtitle 'C-61 provisions .
regarding the management and "disposal o'f hazardous solid waste, however,
have become the'statute's ..key. provisions.,, . ' ''
. RCRA was significantly amended by the Hazardous and Solid Waste
Amendments of 1984 (HSWA). The Amendments placed a number of
restrictions on waste disposal facilities in order to reduce the land disposal.
of hazardous wastes.262. They also added a new Subtitle - Subtitle I,;which
regulates underground storage tanks, containing hazardous substances or
petroleum!263 Most importantly, HSWA imposed a number of deadlines
on EPA that forced the agency to implement RCRA's provisions (these are
termed "hammer" provisions). If EPA missed the statutorily set deadlines,
very restrictive disposal provisions automatically went into effect.264
RCRA requires hazardous waste to be treated, stored, and disposed of so. as
to minimize the present and future threat to human health and the environ-
ment.265 RCRA's Subtitle C sets forth the regulatory provisions with which
261 RCRA. contains 10 subtitles. Subtitle A contains general provisions (e.g., definitions).
Subtitle B establishes the EPA Administrator's duties. Subtitle D concerns municipal solid
waste. Subtitles E-F concern the development of recycling markets. Subtitle G contains .=..
miscellaneous provisions. Subtitle H lists research, development, demonstration, and
information programs. Subtitle I regulates underground storage -tanks. Subtitle J authorizes a
demonstration medical waste tracking program. Non-hazardous,solid waste is regulated under
Subtitle D. Its regulations apply primarily to state and municipal solid waste facilities.
262 The most famous restriction was the "land ban" which prohibits the disposal of bulk or _
non-containerized hazardous liquid wastes in landfills and severely restricts the disposal of
containerized hazardous liquids. Under the "land ban," hazardous wastes can be land disposed
only if they meet certain treatment standards or if they are placed in a land disposal unit from
which they will not migrate. The Amendments also established minimum technological
standards that require, for example/ double liners in landfills and leachate collection systems.
Due to HSWA regulatory!requirements, the cost of hazardous waste disposal has skyrocketed.
It has been predicted that HSWA's land disposal requirements wilT compel, chemical
manufacturers to either 'treat all hazardous secondary materials immediately consistent with
treatment standards or reintroduce the material into the production process. E. Elliott and
E. Thomas, supra note 92, §17.2(C)(1), at 1318. .
263 RCRA §§9001-9001h,,42 U.S.CA. '§§6991-6991h (West Supp. 1994). .
264. For example, the "land ban" was scheduled to go into effect in May 1990 unless the EPA
could promulgate regulations that were designed to protect the public health and environment
from the land disposal of such hazardous wastes. EPA succeeded in meeting these stringent
deadlines. . '
265 RCRA states: "The Congress hereby declares it to be the national policy of the United
States that, whenever feasible, the generation of hazardous waste is to be reduced or
eliminated as expeditiously as possible." Waste that is nonetheless generated should be
treated stored, or disposed of so as to minimize the present arid future threat to human health
and the environment." RCRA §1002(b),' 42 U.S;C.A. §6902(b) (West Supp. 1994).
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.^e , -: r;j2ardous waste, transporters of hazardous waste, and owners
!le!a"^~4 hazardous waste treatment, storage and disposal facilities must
^!.°_.?,'"RCRA represents a comprehensive "cradle-to-grave" regulatory -
!.Y.'k(p ,',at >,acks hazardous wastes from their generation to their disposal to
ensure that they do not' pose a threat to public health or the environment
throughout their life cycle.
1. Identification/Listing of Hazardous Wastes
Section 3001** requires EPA to promulgate regulations, providing for the
identification and listing of hazardous wastes. EPA has implemented this.
provision by establishing three hazardous waste lists. The first list contains ^
approximately 500 wastes from non-specific sources (e.g., specific chemicals).
The second list identifies hazardous wastes from specific sources (e.g., wastes
from petroleum refining).268 The third list contains commercial chemical .
products which, when discarded or spilled, must be treated as hazardous
wastes 269 In addition, if wastes exhibit hazardous wastes "characteristics -
such as inability,27' corrosivity,27' reactivity,27* or EP toxiciry,27' they are
considered to be hazardous wastes.
In addition to the listed and characteristic hazardous wastes, a mixture of a
hazardous waste and a solid waste is considered a hazardous wastes unless its
generator can prove that it should be exempt (this is termed the "mixture
rule).274 Similarly, a waste that is generated during the treatment, storage, or
266 RCRA §3001, 42 U.S.C.A. §6921 (West 1983 &Supp. 1994). . .
267 40 C.F.R. §261.31 (1993). .'..'•
268 40 C.F.R. §261.32 (1993). . • •
269 40 C F R 5261.33 (1993). .
270 -inability'' is defined as posing/a fire hazard during routine management _
271 »Srrosivity"'is defined as having the potential to corrbxle standard containers or to .
- dissolve toxi^IJ^^^^S^ to explode under normal management
• to Identify w^es that are likely to leach hazardous concentrations of specific toxic
constituents into groundwater under mismanagement conditions .
274 jn r F R S261 3(a)(2) (1993). Exemptions are provided in three cases. (1) rf the listed
product resulting in minimal losses during manufacturing operations.
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ji.sc-csa: or a hazardous waste is also-a hazardous waste unless it is exempted,
.uhi's is'termed the-"derived-from" rule).275 'in 1991, these two rules were ^
. .invalidated by the United States Circuit Court Jor the District'of Columbia27*
because the EPA had promulgated the rules without sufficient public notice .
and comment- Shortly thereafter, EPA repromulgated the rules on an
. interim basis:277 - • , ' , ... ... ' . . ' •
Certain1 wastes are exempt from Subtitle C's requirements. They include.
household waste; agricultural wastes that are returned to the ground as
fertilizer; and wastes from the extraction, benefication, and processing of 'ores
and minerals, including coal.278 In addition, if generators can prove that
their wastes do not contain the hazardous constituents that resulted in the
waste's initial listing or any other constituents that would cause the waste to
be hazardous, their wastes can be delisted.279 Also, hazardous waste , . _
generators that''generate less than 100 kilograms-per .month280 are not subject .
to Subtitle C's regulatory provisions.281 Recyclable materials that otherwise . :
meet RCRA's hazardous waste definitions are fully regulated under RCRA
unless'they fall within certain narrow exceptions that trigger less stringent
regulation.282 - - - ' \
275 40 C F R. §261 3(b) (1993). If the waste is derived from a listed waste, exemption is
provided by delisting. If the waste is derived from a characteristic waste, exemption is
provided if the waste does not exhibit i hazardous characteristic.
276 eft,.]') fijlVo v: EPA. 950 F.2d 741 (D.C'Cir. 1991). .
277 57 Fed. Reg. 7628 (1992). " ' :
278 See, 40 C.F.R. §261.4(b) (1993). , ' .
279 RCRA §3001(f), 42 U5.G.A. §6921(f) (West Supp.,1994). Chemical manufacturers may
petition for delisting of their waste;.however, delisting occurs only on a facility-specific basis..
The EPA must act on a petition for delisting within two years. ^
280 Orieinally, the exemption covered generators who produced less.thanl,000 kg per month.
AlthouKese generators are technically exempt, RCRA still requires them to meet certain
minimum standards. See, 40 CF.R. §261.5 (1993). ,
281 HSWA lowered the threshold exemption amount to 100 kg/month; however,HSWA also
established less restrictive rules for generators who generate between 100 and 1,000 kg per
month. For example, they may accumulate up to 6,000 kg of hazardous waste on-site for up to
ISOdavs without a Mrmit. If the waste must be shipped over 200 miles, the waste may be
So, uf °cSSfSg.• In addition, they are relieved from^CRA's full manifest provisions
andbenefitfromreducedemergencyplannirigrequirements. These generators are termed smaU
quantity generators." S«, 40 C.F.R. §261.5, §262.34(dHO (1993).
282 See, 40 C.F.R. §261.6(a)-261.6(d) (1993). . .
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I. Generator Requirements . •
"CAA i generator requirements are set forth in §30G2.:S3 EPA has defined
a -er.eraror"' as "any person, by site, whose act or process produces hazardous
waste identified or listed in Part 261 of this chapter or whose act first causes
hazardous waste to become subject to regulation."284 When a generator
determines that its solid waste is hazardous, the generator must obtain an
EPA identification number within 90 days of generating the waste.285 RCRA
also requires generators to properly prepare the waste for transportation off-
site and to use appropriate labels and shipping containers.286 Generators
must also maintain records concerning the amount of waste that,they
generate and file biennial reports with-EPA that specify where their waste
was sent for disposal.287 . ,
the generator is also responsible for preparing a Uniform Hazardous'
Waste Manifest, which is a shipping form that must accompany the waste at
all times.288 Generators must ensure that their hazardous, waste reaches its
designated disposal site.by examining the manifest copy that is returned to the
generator when the waste reaches the disposal site. If the manifest is not sent
back or is sent back in an untimely manner, generators must file an
"exception report" with EPA or the state.289
283 RCRA §3002, 42 U.S.C.A. §6922 (West Supp. 1994). Regulations are found at 40 C.F.R.
S5262.10 et seq. (1993). . ;
234 40 C.F.R. §260.10 (19.93).
285 RCRA §3010(a), 42 U.S.C.A. §6930(a) (West Supp. 1994), 40 C.F.R. §262 (1993).
286 40 C.F.R. §262.30-262.34 (1993). • _
287 Or with the authorized state if .RCRA is implemented by a state agency. See, 40 C.F.K.
§§262.40-262.44 (1993). ' . ' ' jj '' ' j
288 The manifest must contain the following information: the generator s name, address, and
' EPA "identification number; the names and EPA identification numbers of all transporters
(generators must use transporters that have an EPA identification number); the disposal .
facility's name address, and EPA identification number (generators must use facilities that
have in EPA identification number); a description of the waste'from *ei DOT hazardous
materials table; the quantity of the waste and the number and type of shipping containers, the
generator's signature certifying that the waste has been labeled marked, and packaged m
fccordance wtth EPA and DOT regulations; and a certification that the volume of waste has
been minimized and that the planned method of treatment, storage, and/or disposal minimizes
the present and future threat to human health and the environment (this was designed to •
rncourag^ generators to reduce the amount of pollution that they generate). Generators must .
keep copies of their manifests for three years. 40 C.F."R. §262.40 (1993).
239 40 CF.-R. §262.42' (1993).. ' ._ • •
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'3. Transporter Requirements ' - . .
Section 3003 sets forth RCRA's transportation requirements.290, EPA
-.defines a transporter as any person engaged in the off-site 'transportation of.
.hazardous waste by air;-rail; highway./or water.291 Transporters-must comply
with EPA and Department .of Transportation (DOT) regulations, governing
the shipment of hazardous .materials.292 Transporters are also responsible for'
cleaning up .'any spills or discharges that may occur during the transport of
hazardous wastes.293 . -
Like generators, RCRA requires transporters to get an EPA identification
'number and to use the Uniform Hazardous Waste Manifest system. When a
transporter picks up hazardous waste from a generator, the transporter and
.the generator must sign and date the'hazardous waste manifest.294 The ,
generator then keeps one copy and-the transporter'keeps .the others: The
transporter must keep the manifest copies with the hazardous waste at all
times Whenever the waste-is transferred to a transporter or disposal facility,
the transferee and the transferor must both sign and date .the manifest. The
transferor keeps one copy and the other copies, remain with the transferee.
Transporters must keep their manifest copies for three years. _
4. Treatment, Storage, Disposal Requirements
Section 3004 sets forth RCRA's requirements for treatment, storage, and
disposal facilities (TSDFs).295 Facilities that accept hazardous wastes for ,
treatment, storage, or disposal are considered treatment, storage, and disposal
facilities under RCRA. Treatment is defined as "any method, technique, or
process ... designed to change the physical, chemical/or biological character
290 RCRA §3003, 42 U.S.CA. §6923 (West 1983 & Supp. 1994). regulations are found at 40
C.F.R. §§263.10 et seq. (1993).- , .
291 40 C.F.R. §260,10 (1993). ' .
292 DOT standards were promulgated under the Hazardous Materials Transportation Act 49
U.S.C.X §§1801, et seq. (West 1976 & Supp. 1994). Regulations are found at 40 C.F.R. §§171-
179(1993>. ' .
293 40 C.F.R. §263.30 (1993).
29* Waste that travels by rail or by bulk m water does not need to be accompanied by a
manifest. However, if transport occurs by -any other means (even'if some portion is by rail or by
bulk in water), the manifest system must be utilized. See, 40 C.F.R. §§263.20(e)-(g), 263.22(b>
' '•'"'
29= RCRA §3004, 42 U.S.C.A. §6924 (West Supp. 1994). Regulations can be found at 40 C.F.R.
§§264-267 (1993), . - ' '• , . ...
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n or anv hazardous waste so as to neutralize such waste or as to
render'such waste nonhazardous, safer for transport, amenable for recovery,
arr enable for storage, or - reduced-in volume. ":v°
A 'storage facility" is defined as a facility where hazardous wastes are.held
for a temporary period, at the end'of which, the hazardous waste is treated,
disposed of, or stored elsewhere.297 A "disposal facility" is one where hazardous
waste is intentionally placed into or onto any land or water, and where waste is
intended to remain'indefinitely.298 Generators who store hazardous wastes
on-site for mere than 90 days299(or transporters who store hazardous waste in
approved containers for more than ten days) or generators who treat or dispose
of their own wastes themselves, are considered. TSDFs under RCRA.300 .
TSDFs301 'must comply witrTa number of requirements that are designed
to protect human health and the environment.302 Initially, they must obtain
an identification number303 and a storage-facility permit from EPA.304
There are two types of RCRA permitted facilities: interim status facilities
and facilities that hold final RCRA permits. Interim status allows TSDFs to
296 RCRA §1004(34), 42 U.S.C.A.-§6903(34) (West 1983). See. also 40 C.F.R. §260.10 (1993).
297 40 C.F.R. §260.10 (1993).
298 Id.
299 Storage must comply with 40 C.F.R. §262.34 (1993). •• .
300 Generators may accumulate hazardous substances in-site without obtaining a RCRA storage
permit in two cases: (1) generators can accumulate up to 55 gallons of hazardous wastes at or
near the point of generation if the waste is properly marked and maintained; and (2) generators
are allowed to store hazardous waste on-site prior to shipment for a period of 90 days if certain
standards are met: 40 C.F.R. §262-34(a) (1993). Transporters are allowed to store_hazardous
wastes for up to ten days without having to obtain a RCRA permit. 40 CF.R. §263.12 (1993).
301 RCRA does not apply to certain facilities that technically may meet the definition of a
TSDF. They include facilities that dispose of hazardous waste by underground injection
pursuant to the Safe Drinking Water Act, publicly owned treatment works that are regulated
bv the Clean Water Act, and facilities that meet the definition of a "totally enclosed
treatment facility." See, 40 C.F.R, §264.1 and §265.1(c) (1993).
. 302 Most of these requirements pertain to the facility's design, construction, and operation. For
example, operators must install a security system, prepare and implement an inspection plan,
ensure that facility personnel are adequately trained, install emergency response equipment,
prepare emergency response plans, and file biennial reports concerning the facility s waste
' management activities. D. Case, Resource Conservation and Recovery Act; in Environmental
Law Handbook, supra note 3, at 78-81.
303 40 C.F.R. §265.11, §264.11 (1993). . , , • •
304 Or from a state agency if RCRA is implemented, through a state program. States are
encouraged to assume EPA's hazardous waste program. Section 3006 allows states to administer
and enforce a program that is equivalent to the federal program (states canadopt more _
stringent requirements). 42 U.S.C.A. §6926 (West 1983 & Supp. 1994). Virtually all of the
states are assisting EPA implement RCRA in some form,
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operate prior to the issuance of final RCRA permits.305 Facilities that are
eligible for interim status must have been in existence on November 19, 1980,
or on the date of any statutory or regulatory change, that made them subject to
RCRA. In addition,, they must have, notified EPA of their hazardous waste -
management activities' and filed a Part A application.?06 Interim status facili-
ties obtain a final facility permit by filing Part B of .their RCRA application.307 '
. After a complete RCRA application (consisting of Parts A and B) is filed,
EPA (or the relevant state) must process the'application. Permit applications ,,
are subject to public notice and comment requirements. Once issued, permits
are effective for ten years but subject to review every five years.
TSDFs must also comply With the Uniform Hazardous Waste Manifest
system. The owner or operator of the facility must sign, date and return a •
' copy of'the'manifest to the transporter and to the generator within 30 days of •
receiving hazardous waste, the TSDF owner or operator must also inspect
the waste to ensure that the manifest, information is correct. If there are
discrepancies, the owner or operator must report them/to the EPA within
15 days. The facility must keep its manifest copies for at least .three years.
The TSDF operator ;must also keep records of the type, quantity, and °rig^
of the waste that is disposed olatcthe site as well as records concerning the
methods of waste treatment, storage and/or disposal. All of these records are
subject to EPA inspection.308 In addition, the operator must monitor the
facility to ensure that the methods of waste treatment, storage, and/or
disposal remain protective of the public health and the environment.
RCRA also requires disposal facilities to have written closure309 and post-
closure plans that prescribe what will happen to the facility when it no longer
305 A new facility or an existing facility that failed to obtain interim status must obtain a ,
final RCRA permit before commencing construction. . '.;..•
' 306 The permit application consists of two parts. Part A must be completed for a faculty to
obtain interim status. Part A requires information such as a description of the treatment
processes, the facility design and the types of waste to be treated.
307 RCRA. §3005(c), 42 U.S.C.A. §6925(a) (West Supp. 1994). Part B of the permit is more
- detailed and requires specific information such waste analysis procedures, inspection schedules,
and closure and post-closure plans (closure will be discussed infra).
^Or the state under a state authorized program. Inspection occurs at least once every two
years. Facilities that are operated by the federal, state or local governments are required to be
Lpected annually. Section 3007 authorizes EPA to enter and inspect sites for comphance tc,
collect samples of wastes, and to examine and copy records relating to the wastes. 42 U.S.C.A.
§6927 (West 1983 & Supp. 1994). . ., • ,
309 Closure is the formal process of closing a waste disposal facility.
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ao:er:s waste. Post-closure plans must provide for groundwater monitoring
and other maintenance activities to guard against future environmental
harm. The closure and post-closure plans must be submitted to the EPA
within ISO days of the expected closure date and the post-closure plan must
provide for protection of the site 30 years after closure. The costs of closure
and post-closure must be guaranteed by the owner or operator of the facility.310
TSDFs must also take corrective action (even beyond their facility, borders
if necessary to protect human health and the environment)311 if hazardous
wastes are released from their facility.312. RCRA permits contain schedules of
compliance for corrective action and 'assurances of financial responsibility for
completing such action.
( 5. Enforcement • •-....
Section 3008 authorizes EPA to utilize a variety of enforcement actions, ,
including administrative compliance orders and civil and criminal penalties,
to enforce Subtitle C313 Failure to comply with Subtitle C or EPA compliance
orders carries a civil penalty of up to $25,000 for each day of violation. A
violation may also result in the suspension or revocation of RCRA permits.
In addition, RCRA imposes a criminal penalty of up to $50,000 per day of
violation and/or 2 years imprisonment.314 Monetary fines.-and jail time
may be doubled for repeat offenders.
When a person violates Subtitle C, knowing that the violation places
another individual in imminent danger of death or serious bodily injury
("knowing endangerment"), RCRA authorizes the imposition of up to
310 Assurances must be made in, one of the following ways: (1) establishing a guarantee, (2)
posting a surety bond, (3) arranging a letter of credit, (4) obtaining insurance, or (5) meeting a
financial test. See. 40 C.F.R. §§265-.140-.151, 264.140-.151 (1993).
311 This requirement does not apply if the operator can not obtain permission to .undertake the
corrective action from the property owner. E. Elliott and E. Thomas, supra note 92, §17.2(C)(4),
312 Section 3004(u)-(v), 42 U.S.C.A. §6924(u)-(v) (West Supp. 1994). RCRA corrective actions
have much in common with CERCLA cleanup actions (see infra).
313 42 U.S.C.A. §6928 (West 1983 & Supp. 1994).-Compliance orders are administrative orders
that the -agency can use to force regulated entities to implement specific actions.
314 in a recent case, the U.S. Court of Appeals for the Seventh Circuit ruled that the federal •
government was not required to prove that a defendant knew that a RCRA permit was required
-to store spent ferric chloride before the'defendant could be found criminally liable on
unpermitted storage charges. U.S. V, Wagner, 29 F.3d 264 (7th Cir. 1994). Under this court s
reasoning, knowledge of a RCRA' permit requirement is not a necessary element which must be -
proven in a RCRA prosecution case.
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S:5/:OI per-dav;iiyrridnetary fines and/or up to 15 years'.imprisonment.-;- .,
Organizations can be fined up to $1,000,000>.316 ' , . ;.' ' .
Section 7003 authorizes'the EPA Administrator to bring ah action against'
.any person who ha's contributed to or who is contributing to the handling,
storage, treatment, transportation, or disposalof any solid'waste or hazardous
waste that may present an imminent and substantial endangerment to health
or -trie environment.317 Under this section, the.EPA Administrator can order
such person to restrain'from "such handling, storage, .treatment, transporta-
tion, or disposal, to order such person to take such other action as may be
necessary or both."318 EPA has used its §7003 authority to order persons to
clean up dangerous releases of hazardous materials.319 Violations of §7003 .
orders are punishable by fines of up to $5,000 per' day.32° ,'
• RCRA also contains a citizen suit provision that allows any person to
bring a civil action against persons alleged to be in violation of'RCRA or •
. against the EPA Administrator for failing to perform a nondiscretionary
RCRA duty (e.g., enforcing-the Act).321 The 1984 Amendments significantly
increased RCRA's citizen suit provision by authorizing actions .against any
person, including any past or present generator, past or present transporter, or
past or present owner of a TSDF who "has contributed or who is contributing
to the past or present handling, storage, treatment, transportation, or disposal
of any solid or hazardous waste which may present ah imminent and
substantial endangerment to health or the environment."322 A citizen action
is precluded, however, in .cases where the EPA or the state has taken action
regarding the site under RCRA or Superfund. m addition, the person
315 RCRA §3008(ej, 42 U.S.CA. §6927(6) (West Supp. 1994). . '
~316W. '-, ,- ' .--• . ' '. ••:•.....• ' ,
317'RCRA 7003,42 U5.CA. §6973 (West 1983 & Supp. 1994). An action must/be brought in .
a United States Distent Court. •
• 318w. • - "- . "'••'... "'•-.' :.' " : ':•'-• •' •
319 In effect, §7003 acts like a mini-Superfund provision. It imposes strict liability (e.g.,
liability regardless of fault) on persons who have contributed in the past or who are presently
contributing to conditions that threaten public health or the .environment Most actions are
brought under CERCLA, however, because CERCLA contains mechanisms that relate to
recoupment and allocation of cleanup costs among potentially responsible parties. CERCLA
also contains cleanup standards and provides for a wider variety of recoverable costs {e.g.,
natural resource damages). See, infra.
" 32° RCRA §7003(b), 42 U.S.C.A. §6973(b) (West 1983). , ,
321 RCRA §7002, 42 U.S.C.A. §6972 (West 1983 & Supp. 1994). ,
'• '
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_ , ,. j __:,.. —e the .EPA, :he state, andaikgefd^eiarcr.* a: .t-ait .
,.,,-.- -j ---- :0 the commencement or any citizen suit.
G THE CLEANUP OF ABANDONED AND INACTIVE HAZARDOUS
WASTE SITES - THE COMPREHENSIVE ENVIRONMENTAL
RESPONSE, COMPENSATION, AND LIABILITY ACT
The Comprehensive Environmental Response, Compensation, and
Liability Act, commonly known as CERCLA, was enacted in 1980 to protect
the public and the environment from the uncontrolled dumping of
hazardous waste and abandoned hazardous waste sites.323 The toxic
contamination of Love Canal in' upstate New York by an industrial facility
and the resulting evacuation of hundreds of families from the area - had -
convinced Congress that a system was needed to identify and cleanup
contaminated wastes sites that resulted from' past, unregulated releases of
hazardous pollutants into the environment.325 •
CERCLA established a S1.6 billion326 Hazardous Substances Trust Fund
(commonly known as the "Superfund") to ensure that funding would be
available to finance the cleanup of the, most contaminated sites.327 Although
CERCLA authorizes the EPA to force parties that were responsible for releases
of hazardous substances to finance and conduct cleanups,328 such parties are
not always identifiable or they may be unwitting or unable to finance cleanup
actions. Often, the parties that were responsible for disposing of wastes are no
323 Pub L No. 96-510, 94 Stat. 2767, codified at 42 U.S.C.A. §§9601-9675 (West 1983 &iSupp.
1994) The aw was amended in 1986 by the Superfund Amendments and Reauthoruat:on Act
disposed years before, contaminated their properties. _ •
325 CERCLA is different from other environmental statutes,-such as the C ean Water Act, the
Clean Air" Act and the Resource Conservation, and Recovery Act that regulate pollutant
Xarges * to *e environment CERCLA's main.purpo* is to clean up r™J"tSL
another S5.1 billion when it reauthorized Superfund through 1995.
& -nl fond consists of taxes imposed'on petroleum and chemical feedstocks and imported
.~^£^
E Thomas, supra note 92, §172(0(4), at1335.
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lu'r--er' ar^r.d, 'They may have gone ;out of business, gone bankrupt, or Been •
taken over by other entities. Likewise, 'duo to. poor recordkeeping and the -
passage of time, it may be impossible to identify all of.the parties responsible
for releases. In such -cases, the Superfund finances the cleanups.329
' - When CERCLA was enacted, the number of contaminated, waste sites was
'•'• expected,to be small. As a result, CERCLA was intended'to be a temporary.
program. It soon become apparent, however, that the number of potential
CERCLA sites was,.in fact, growing. By mid-1994, there were 1,232 facilities,
including 150 Federal facilities, on the National Priorities List (NFL.)330 ••Fifty-
four additional facilities had been proposed for NFL listing and were awaiting
a final EPA determination. According to the EPA, an additional 340 to 370
facilities are expected "to be added to the NPL between October 1,1994, and
' •' September -30, 1999.331 The task of cleaning up jfresent and future Superfund
sites is expected to cost tens of billions of dollars332 and may take-decades.333
The Superfund Amendments and Reauthorization Act of 1986 (SARA).
added provisions that extended and expanded the' taxes that finance the
Superfund and authorized an appropriation of $8.5 billion through December
31,1991. 'in addition, SARA required EPA to use "applicable or relevant and
appropriate requirements" (ARARs) of other environmental laws when " '
designing remedies at CERCLA sites. SARA also added a preference for
permanent cleanup and treatment remedies as opposed to containment
329 EPA is authorized to finance cleanups and enforcement actions using Superfund momes.
The fund is also used to pay for private party cleanups in certain cases. See, CERCLA §111,42
U.S.G.A. §9611 (West 1983 & Supp. 1994). • .
330 The National Priority List, otherwise known as the "NPL," 5s EPA's ranking of hazardous
waste sites that are eligible for cleanup using the Superfund. To rank sites, the EPA
established the Hazardous Ranking System (HRS) which, for each site, scores factors such as
the quality and nature of hazardous wastes present, the likekhood of contamination, and the
- proximity o* the site to population and sensitive natural environments. EPA is required to_
update the NPL at least once a year. Even if a site is not listed on the NPL; it may be eligible
for a short-term removal action. It also may be the subject of a cleanup actions under state
"mim-Superfund" statutes. H.R. Rep. No. 582,, 103rd Cong., 2nd Sess. 75 (1994).
331 id . • •-•'-.. • •- -.•••'••'
332 The cost of cleaning up hazardous waste sites is enormous. EPA has estimated that the
average cost for a Superfund cleanup is between $25 and $30 mM on per site andthatthercpst
of cleaning up the sites currently on the NPL will exceed $40 billion. H.R. Rep. No,. 35,103rd
Cong., 1st Sess. 5. (1993). . ,' . j«.
333Since the Superfund program began, only 49 sites have been .cleaned up and removed from
"the NPL. The Congressional Budget office estimates that 15 years or more utreated from
discovery to the completion of cleanup at the average Superfund site. Id. at 23-26 (1993).
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rerrei:=s:-'~- -nd established new mechanisms that are designed to facilitate
ic-lcrr.er.rs-with hable parties and, thereby, hasten cleanups.333
1. EPA Response Authority
CERCLA provides EPA with the authority to initiate cleanup actions at
abandoned hazardous waste sites. This'authority (termed EPA's "response
authority") .is triggered by the release336 or threatened release337 of a hazardous
substance338 from a vessel or a facility into the environment.339 EPA can
respond to a release or threatened release of a hazardous substance in two
Jj4 SARA requires EPA to choose remedies that will neutralize the waste as opposed, to
preventing its migration from me site. SARA's preference for treatment has been very
controversial because treatment remedies are usually much more expensive than containment
remedies. Also, in some cases, treatment of'the waste is technologically infeasible. This
provision is expected to be modified when CERCLA is reauthorized by Congress.
333 CERCLA reform is expected to occur in the 104th Congress. Legislative proposals that were
offered but failed to pass the 103rd Congress would have hastened cleanups and achieved them
at lower cost, reduced litigation over insurance coverage and cleanup liability, and improved
state and community participation in Superfund cleanups.
336 A "release" is defined as any situation that leads to a hazardous substance being freed from
its normal container, such as through "spilling, leaking, pumping, pouring, emitting, emptying,
discharging, injecting, escaping, leaking, dumping, or disposing into the environment
CERCLA §101(22), 42 U.S.C.A. §9601(22) (West Supp. 1994). Certain releases that are
regulated under other laws, such as workplace related releases that are covered by the
Occupational Safety and Health Act and emissions from the exhaust of motor vehicles that
are covered by the Clean Air Act, are not covered by CERCLA.
A "substantial threat of release" is not defined in the statute; however courts have
interpreted the term broadly. For example, abandoned and corroding tanks have been deemed
examples'of threatened releases. New York v. Shore Realty Corp.. 759 F.2d 1032,1045 (2d Cir.
1985), United States-v. Northemaire Plating Co.. 670 F.Supp. 742, 747 (W.D. Mich. 1987).
The statute defines "hazardous substance" by referencing other environmental statutes. For
example, "hazardous substance" includes hazardous wastes, as defined by RCRA; hazardous
, substances as defined by the Clean Water Act; and hazardous air pollutants,- as defined by the,
Clean Air Act. CERCLA §101(14), 42 U.S.C.A. §9601(14) (West Supp. 1994). To facilitate
identification, EPA has listed CERCLA hazardous substances at 40 C.F.R. §302 (1994).
Petroleum and most nuclear materials are expressly excluded from CERCLA; however,
petroleum products that are specifically designated as hazardous substances under the Solid
Waste Disposal Act, the Clean Water Act, or the-Toxic Substances Control Act are covered bv
CERCLA. .
339 "Vessel" is defined as "every description of watercraft or other artificial contrivance used,
or capable of being used, as a means of transportation on water." CERCLA §101(28), 42 U.S.C.A.
§9601(28) (West Supp. 1994). "Facility" is defined as "any building, structure, installation,
equipment, pipe or pipeline-well, pit, pond, lagoon, impoundment, ditch, landfill, storage
container, motor vehicle, rolling craft, or aircraft, or...any site or area where a hazardous •
substance has been deposited, stored, disposed or, or placed, or otherwise come to be located;
but does not include any consumer product in consumer use or any vessel." CERCLA §101(9) 42
U.S.C.A. §9601(9) (West Supp. 1994).
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., ; . ,•> . ?.:;:.'the government can -conduct a ihor:-terrrt removal action at ary
i::e that requires emergency action. .Removal actions are designed to reduce
•-mediate threats'to the public health or welfare and' the environment.j4; For
examrle, the EPA can'remove barrels of. waste if the condition of the barrels
presents an imminent risk of explosion. Second, the government can-conduct.-
a long-term remedial action; however, such actions can occur only at NFL ,
sites_342- urilike removal actions, remedial actions'are designed to permanently
• effect the cleanup34'3 of contaminated site's.344" Implementation of a, remedial
action may occur years after a CERCLA site is identified and listed on the NPL.343
34P CERC-A §104(a)(i), 42 U.S.C.A. §9604(a)(l) (West Supp. 1994). CERCLA- requires EPA
response actions to follow strict statutory guidelines. The primary guidance document is the
National Contingency Plan, also known as the/'NCP" which is found at 40 C.F.R. §300 (1993).
The NCP sets forth procedures which must be followed by the government and private parties ,
when conducting cleanups.: The NCP establishes methods and criteria for determining the
appropriate extent of response (e.g., removal or remedial action) and outlines the procedures -
that musl be-followed. The EPA is the lead agency ;for all response actions except for spills that
occur in coastal areas and inland waterways where the Coast Guard assumes responsibility.
341 A removal action must be capable of being completed within one year and it must not cost' .
more than 52 million. There are exceptions, however., that include situations where continued
action is necessary to.respond to an emergency, situations where there is an immediate risk to
public health pr the environment, situations where the action is part,of a larger approved .
remedial action, and situations where continuation of the removal is consistent with the
remedial action to be taken. CERCLA §104(0(1), 42 U.S.C.A. §9604(0(1) (West Supp. 1994).
342 The NPL was designed to ensure that the most serious sites are cleaned up first. By
restricting remediation actions to NPL sites, this provision is designed to ensure the Superfund
is used only for the cleanup of the most contaminated sites. • ' . -
343 The level of cleanup that will be achieved at a contaminated site is one of the most .
contentious issues that arises under CERCLA. Many argue that certain sites should not be >
cleaned up to pristine conditions - particularly those that will always be used for industrial
purposes Ironically, the 1986 Amendments made cleanups more expensive because they ,
expressed a preference for treatment versus containment remedies at Superfund sites and
treatment is usually disproportionately costly. In addition, the current statute requires that all
cleanups meet "all legally'applicable or relevant and appropriate" requirements of other.
fedSl or state envirlnmenS laws. CERCLA §121, 42 U.S.C.A. §9621 (West Supp. 1994). .
These requirements have resulted in very costly and conservative cleanups and are likely to be
the future subject of CERCLA reform. - ..-.--
344 An example of a remedial action is the'installation and operation of a groundwater "pump
and treat" system or a soil incinerator. • •.'.'• .
345 When a potential Superfund site is. discovered, a preliminary assessment (PA) is conducted,
• consisting of a brief review of available site information to determine whether the site poses
sufficient risk to warrant further action.' After the preliminary assessment (PA) is conducted,
the EPA can initiate a site inspection (SI) or drop the site from further review. The.SI consists
of more detailed data collection than the PA, such as soil and water sampling. If the site poses
a sufficient threat to human health or the environment (which is determined by ranking the
site according to the Hazard Ranking System), the site is added to .the National Priorities List
(NPL) Once listed, the EPA can perform a remedial investigation (RI) which assesses the -
presence of contaminants on the site and their risks.. After the RI is conducted, EPA conducts a
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Z. P£P Liability- '
V.-er a release cr threatened'release of a hazardous substance from a
vesse. or facility results in the incurrence of response costs346 (either by the
• EPA or by private parties), CERCLA authorizes an action for cost recovery for
persons who have incurred response costs.347 Liability for response costs and
natural resource damages348 can be imposed on four categories of parties: (1)
current owners or operators of a facility at which hazardous substances were
disposed;349 (2) past owners or operators of a facility at which hazardous
feasibility study (FS) which identifies and evaluates alternative methods of remediating the
contamination at the site. When the RI and FS are completed, EPA issues a Record of Decision
(ROD) that sets forth EPA's chosen remedy. Before, the remedy selection is final, however, a
«ublic comment period occurs. Thereafter, EPA prepares a comprehensive remedial design (RD)
plan and proceeds to implement the remedial action (RA). The final step is NPL delis ting. The
entire process, from identification to delisting, can take up to 15 years. H.R. Rep. No. 35, 103rd
Cong. 1st Sess. 23-26 (1993). " . '„ .
346 "Response costs" include any costs associated with a "removal" or "remedial" action
incurred by the United States government or tribal government and any other necessary costs
of response incurred by any other person consistent .with the NCP; damages for injury to,
destruction of, or loss of natural resources; and the cost of any health assessment of health
effects. Interest on these costs is also recoverable. CERCLA §107, .42 U.S.C.A. §9607 (West
Supp 1994).' The courts are split as to whether private parties' attorney's fees are recoverable; •
however, they have held that EPA's enforcement costs are recoverable. Courts have also found
that EPA's indirect (e.g., administrative and oversight) costs are also recoverable. United •
Stan* v. Hardaee. 733 F. Supp. 1424, 1438-1439 (W.D. Okl. 1989); Unitfd States V, R.W, Meyer.
Ins,, 389 F.2d 1497,1503 (6th Cir. 1989). To be recoverable, however, response costs must be
"consistent" with the National Contingency Plan (NCP) in private action for costs.
347 CERCLA §107, 42 U.S.C.A. §9607 (West Supp. 1994).
348 Liability includes damages for injury to, destruction of, or loss of natural resources including
the reasonable costs of assessing such injury, destruction, or loss" resulting from a release of
hazardous substances into the environment. CERCLA. §107(a)(4)(C), 42 U.S.C.A. •
. S9607(a)(4)(C) (West Supp. 1994). . .
349 This is termed "current owner/operator" liability. A current owner or operator of a Super-
fund site is liable regardless of whether it had any involvement in the handling, disposal, or
, treatment of hazardous substances. There are a few exemptions to this "owner/operator"
liability. For example, state or local governments are not liable if they acquired ownership or
control of the site involuntarily through bankruptcy, tax delinquency, abandonment, or other '•
circumstances where the government involuntarily acquires title, by virtue of its function as
sovereign. See. CERCLA §101(20)(D), 42 U.S.C.A. §9601(20)(D) (West Supp. 1994). In .addition,
liability does not extend to persons, who, without participating in me management of a vessel
or facility holds'indicia of ownership primarily to protect his or her security interest-in the
vessel or facility. See CERCLA §101(20)(A), 42 U.S.C.A.. §9601(20)(A) (West Supp. 1994).
Courts have found lessees liable as "owners." TTnited. States v. South Carolina Recycling and,
Disposal Inc.. 653 F. Supp. 984,1003 (D.S:C. 1984). Courts have also found corporate Officials to
be "operators" in cases where they actively participated in their companies' waste manage-
ment and ^cp^i-^iviHPc '-MPW York v. Shore Realty Corp,, 759 F.2d 1032 (2d Cir. 1984).
Courts have also "pierced the corporate shield" and held parent corporations liable for the •
• actions of their subsidiaries in cases where the parent corporation exercised control over the .
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-J -* « — „ i-J '
-^.-.-ur:^ '.sere -i persons,"including generators,
;.;: tr.c' diiposal ar.d treatment'of hazardous waste at any facility;"1 and .'4) ' . •
trar.srorters, o-r those who arranged for the transport of hazardous waste ..to a
;,c..;.tv :-;:_,. Courts,hav'e interpreted CERCLA's liability provisions liberally in
order to ensure that CERCLA's cleanup objectives are achieved.353
' The liability of these parties, termed '"potentially responsible parties" or
"PRPs,". is strict (i.e., liability can be imposed'regardless'of fault or negligence),
.joint and several (i.e., one party'can be held liable for the actions of others
when the harm is indivisible)354 and retroactive (i.e., parties can be held liable
'. "for actions that predated CERCLA's .enactment). .The EPA does not have to .
prove that a particular PRP's waste caused the release or threatened release '
in order for that PRP'to be held liab'le. -EPA only has to show that there'are - .
• hazardous substances'present at the site-that are "iflce" those associated with "
the PRP's waste management/disposal activities'.
subsidiaries' waste management and disposal activities. United State? y. Kaiser-Roth ' •
Corporation. 910 F.2d 24 (1st Cir. 1990). . ' . . • - •
350 This is termed "past owner/opera tor" liability. "Disposal" was originally interpreted,
bv courts to mean active disposal during the'past owner's/operator's period of ownership/
' operation. A recent court has interpreted the term "disposal" however to mean passive .= .-
disposal which theoretically extends past liability to all parties who owned or operated the
site from the initial act of disposal if the facts suggest that the hazardous substances were
passively disposed (e.g., leaching) over that period of time. See -Nnmd Tnc, V- William E,
^nnppr'fe Sons Co.. 966 F.2d 837 (4th Cir. 1992). •
331 This is termed "generator" or "arranger" liability. At most Superfund sites, "generators" and
- "arrangers" form the largest PRP group ; their liability depends on whether they made arrange-
ments for the disposal of hazardous substances or whether they owned or possessed hazardous
substances that were disposed of at the site. Courts have-interpreted this liability broadly and
have imposed liability in cases where there has been a relationship between two or more
entities that results in the handling or disposal of a waste containing a hazardous substance.
One court held that to be liable, the party does not need to know that disposal of the hazardous
' substance would result. ™™Ha Pnwer & T.mht v. AHi.s-ChalmersCprP., 89.3 F.2d 1313 (llth Cir.
1990) In addition, "constructive possession" (i.e., not actual possession but the. ability to in- • . •
fluence where the hazardous waste is disposed of) may be sufficient for liability to be triggered.
332 This is termed "transporter" liability. 'Typically, these parties are commercial waste.
haulers. To be liable, the transporter must have selected the disposal or treatment site.
333"R. Lee., Comprehensive Environmental Response, Compensation, and Liability Act, in.
Environmental Law Handbook, supra note 3, at 286. p >; • . ; ._
354 CERCLA's joint and several liability stems from the extreme difficulty associated with
' apportioning liability among numerous, contributors. CERCLA sites can have upwards of 500 •
PRPs - each of whom may have sent similar hazardous materials to the site. The idea is that
by imposing joint and several liability on the PRPs, the PRPs will bear the burden of coming
forward with information which will exculpate them (if such information is available) or.
with information that will identify other PRPs. If the waste is not commingled and each PRPs
' portion can be allocated accordingly, joint and several liability will not be imposed. •
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CEIsCLA s '.i-ibilitY .scheme and its minimal, standard of causation have
r---l:ed in the EPA suing a few PRPs at major Super fund sites for the entire
:;-: .-•: cleanup. Those PRPs, in turn, then sue other, usually smaller, PRPs
for contribution:355 Some PRPs have complained that CERCLA's liability
scheme is unconstitutional; however, courts have repeatedly upheld , .
CERCLA as constitutional.356
After a site is listed on the NPL, EPA identifies PRPs that it can link to .
the site357 and sends, them a "PRP letter," notifying them of 'their potential
CERCLA liability. CERCLA imposes two types of liability on these parties
depending upon whether a site cleanup is'conducted by the government or by
PRPs. If the cleanup is conducted by,trie government, PRPs are liable to the
government for their share of its response costs.358. If the site has not yet been
cleaned up, PRPs can be ordered to effect the-actual cleanup of the site.309
3. Private Party Cleanups
In lieu of using the Superfund to cleanup sites, CERCLA also provides
EPA with the authority to compel private parties to perform response action
when releases or threatened release of-hazardous substances present an
imminent and substantial endangerment to the public health or welfare or
the environment.360 Before SARA, EPA did not use its §106 authority very
355 Contribution actions seek to impose liability on other parties who the person who has been
held liable for the costs of cleanup alleges are also responsible. Large industrial PRPs have used
this provision to sue small PRPs, such as pizza shops and girl scout trciops, solely on the basis that
thev sent municipal solid waste to the hazardous waste site (they technically are. "generators").
This has been very controversial. During the 103rd Congress, the Senate and the House intro-
duced bills that would have provided "de micromis" generators (defined as parties that generate
or transport less than 100 pounds or 55 gallons of materials containing hazardous substances unless
such materials contribute significantly to the response costs at the site) with a statutory
exemption from Superfund liability; however, CERCLA reform bills did not pass Congress.
' 336 See e.g.. Tlni^ States v. Monsanto Co.. 858 F.2d 160 (4th Or. 1988), cert, denied, 490 U.S.
1106 U989); Upi*«* States v- NEP'ACCO. 810 F.2d 726 (8th Cir.'.1986), cert, denied, 484 U.S. 848
'(1987).
357 EPA conducts a "PRP search" which reviews documents associated with the site's
operation. For example, many Superfund sites are old landfills and the waste records from
haulers that sent waste to the landfill often provide crucial identifying information.
358 CERCLA §107, 42 U.S.C.A. §9607 (West Supp. 1994). ' ' • .
359 CERCLA §106, 42 U.S.C.A. §9606 (West 1983 & Supp. 1994).
360 CERCLA §106, 42 U.S.C.A. §9606 (West 1983 & Supp. 1994). This provision has been inter-
preted to provide an equivalent cause.of action as.§107. However, there are some differences
' between §106 and §107. Section 106 provides for equitable relief (e.g., it authorizes EPA to issue
a-umlateral administrative order to compel a private party to undertake a response action)
whereas §107 does not. Also §106 provides only for the abatement of an imminent and
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;::er A-e^fARA,'however, EPA began to routinely use §i:6 to rorce pr;va:e
•parr.es :o conduct the .site cleanups. This new policy, termed "enforcement:
r'.rst/'""' is achieved by ordering PRPs to cleanup the site, through adminis-
trative or judicial actions. ,These cleanups, termed "private party cleanups/' .
have conserved the Superfund and have ensured that the.Fund is only used .
af sites where.PRPs cannot be identified or found:' In addition, private party
cleanups are usually Ifaster and more efficient than government cleanups,
The private party cleanup order has been called "EPA's most potent en*-.
forcement tool 'andV powerful settlement incentive."362 A failure to comply
with a ;§106 order triggers substantial penalties ($25,000 per day)363 and §106 :
orders are not .immediately eligible for judicial review 364- As a result, parties
who are issued a §106 order have little choice but to comply. CERCLA does
allow private parties, who comply .with §106 orders, to sue other parties for- .
contribution and to file a claim against the Superfund for reimbursement of
compliance costs; however, a party, can recover from the fund only if it can;
prove, that it is not a valid PRP" at. the site, ;•••
4. Defenses .
CERCLA contains defenses that PRPs may use to escape its liability 7 -
. scheme.365 They include: (1) an act of God, (2) an act of war, or (3) ah act or
omission of a third party if the PRP exercised due care and took precautions
against' foreseeable acts of the third party.366 These defenses are rarely used
substantial hazard whereas §107 provides for cost«covery of sums expended in a full cleanup
of a site. In practice, §106 has effected the same types of cleanups as §107.
361 R. Lee, supra note 353, at 288. • , .
362 Id at 299 • '
damages; equal to three times the amount of costs incurred as a result of the party s
TT • °. . ~ . , i i-- : — «j -rv> 9imi<4 rmnitive damaees. a party must
fanocompwm te order, can also.be imposed. To
show that it had "sufficient cause" to not comply with the §106 order Courts mterpret suffi-
denTcause" strictly. Parties must prove they had atreasonable,objectively grounded belief
'• thaV mU was not a liable party or that it had a defense; (2) it was a de mimmis contributor,
S) the^r^ t^au^valid; (4) financial, technica^orBother^F™^* lts .
compliance; or (5) the response action ordered was not cost-effective. Id. at 301-302.
3<* Ltion 113(h) provides that "no Federal court shaU have jurisdiction...to. review any order
issueTunSer^Son [106].-." 42 U.S.CA. §961300 (West Supp. 1994). When the EPA seeks-to
enforce its order, the order becomes subject to judicial review. -
365 CERCLA §107(b), 42 U.S.CA. §9607(b) (West 1983). . '•
366 The third party must be someone other than an employee, agent, or party with whom the
PRP tad a contractual arrangement such as through leases employment contract, waste
' hauUng contracts, and real estate sales. Typically, the third party is someone who acts in a
way that could not have been prevented, such as a vandal. ,.
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because they are valid only in extrao.rdinary cases. The third party defense, in
"articular, has been narrowly construed by the courts.
SARA added a new defense, termed' the "innocent landowner" defense.
Under this defense, the owner or operator of a Superfund site can escape7 .
liability if the .owner or operator can establish that it did not know or have
reason to know that any hazardous substance had been disposed of at the site
at the time of purchase. To meet this burden of proof, an owner or operator
must prove that he or she made "all appropriate inquiry into the previous
ownership and uses of-the property consistent with good commercial or
customary practice. . . ."367 . • .
5. Release Reporting , .
CERCLA also requires parties to notify the EPA whenever "there has been a
release of a hazardous substance that is equal to or greater than the reportable
quantity for that substance.368 EPA has promulgated regulations listing the
reportable quantities of various hazardous substances.369 Failing to report
releases of hazardous substances can result in civil and criminal penalties.370
The maximum criminal penalty is three years in prison for a first conviction
and five years for a subsequent conviction. Civil penalties amounting to
more than $25,000 per day may also be imposed. Certain releases which are
exempted from CERCLA's reporting requirements include federally permitted
releases, releases pursuant to FIFRA, releases regulated under RCRA, and
continuous releases .from a facility that has already notified the National
Response Center of such releases.37*
367 CERCLA §101(35), 42 U.S.C.A. §9601(35) (West Supp. 1994). Environmental audits,
required prior to the transfer of real estate in some states, are often used to establish the
innocent landowner defense. An environmental audit is usually conducted by an environmental
'consultant who examines the property (both the-structures and the land) and reviews land
records'for evidence of past w'aste disposal. The innocent landowner defense is no available to
owners/operators who fail to disclose any knowledge they have obtained of on-site waste
disposal activities acquired during his or her period of ownership /possession.
/368' CERCLA §103(a), 42 U.S.C.A. §9603(a) (West 1983). .
369 See, 40 C.F.R. §302 (1993).'
370 CERCLA §103, 42 U.S.C.A.'.§9603 (West 1983 & Supp. 1994).
371 CERCLA §103(a), 42 U.S.C.A. §9603(a) (West 1983). ,
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6. Enforcement _ ... v • • ' - .
Ln addition to-'authorizing actions-for cleanup and for response costs,
CERCLA also;contains a "citizen suit" provision.that permits private citizens
to initiate a civil action against' parties that violate CERCLA (including the
EPA Administrator for failing'to perform nondiscretionary CERGLA duties,,.
such as enforcing CERCLA's provisions).372 Before a citizen suit can be
brought, however, the citizen must notify the EPA and'.the,alleged violator at
least 60 days prior to bringing the action. In addition, if the government has
already brought a prosecution action against the alleged violator, no citizens'
suit may commence. .. •'..--"
Because CERCLA issues have been heavily litigated and the case law is
-well established, most CERCLA cases end''in a -negotiated settlement between
PRPs and the EPA.373 -SARA added Section 122 that'established procedures to.
encourage settlements with PRPs.374 The consent decrees that end judicial •
actions and the consent order's that end' administrative actions usually
contain covenants not-to sue. These covenants provide settling PRPs with
some finality as to future CERCLA. liability at the site; however, consent
decrees and consent orders also often contain "reopeners" that allow ~'
subsequent suits, to be filed against the settling PRPs if information is
disclosed at a later date that shows that .the chosen remedy is nO longer "
protective of the environment.375
372 CERCLA §310, 42 U.S.CA. §9659. (West Supp. 1994). ' .
373' CERCLA authorizes settlement agreements under which PRPs are required to undertake .
necessary response actions at a site. See CERCLA §122,42 U.S.C.A. §9622 (West Supp. 1994).
374 For example, §122(g) added a section on de minimis settlements that encourages EPA to
reach a final settlement witivde minimis parties (parties who contributed only small amounts
of low-toxicity waste to the site) "'as promptly as possible." 42 U.S.C.A. §9622(g) (West Supp.
1994). ' : "- •
375 One commentator has written: "From EPA's perspective, settlement is .preferable because it
conserves Superfund monies as well as EPA's limited resources. Settlements also free EPA's '
personnel to work on other cleanups. From the perspective of PRPs, settlement is often, preferred
because it permits :them to exercise greater control over the selection and implementation of.
remedial actions, presumably minimizing costs. PRPs also often prefer settlement to avoid the
tremendous costs of litigating a CERCLA case." R. Lee, supra note 353, at, 312.
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H RESPONDING TO CHEMICAL EMERGENCIES -
THE EMERGENCY PLANNING AND COMMUNITY
RIGHT-TO-KNOW ACT
In 1984 a Union Carbide facility released methyl isocyanate into the
atmosphere in'Bhopal, India, killing more than 2550 people and permanently
disabling some 50,000 more. The Bhopal'incident highlighted the potential
for accidental chemical releases in the United-States and illustrated .the need
for emergency planning to deal with such releases should they occur. .The
Bhopal incident alsb made communities, located near industrial plants, eager
to know what substances the plants were emitting. , ' .
Title III of the Superfund Amendments and Reauthorization Act (SARA),
contained a separate law known as the Emergency Planning, and. Community
Rieht-to-Know Act (EPCRTKA or EPCRA).376 EPCRA does two togs: (1) it
requires states to create local emergency units that must establish plans for
responding to chemical emergencies and (2) it requires the EPA to develop a
national inventory of releases of toxic chemicals from manufacturing
facilities which is subject to public disclosure. •
1. Emergency Planning
Section 301 requires each state to create a State Emergency Response
Commission (SERC), designate emergency planning districts,, and establish
local emergency planning committees (LEPCs) in each-district377 The local
committees are required to work with local facilities that produce, use, or
store extremely "hazardous substances378 to develop response procedures,
evacuation plans, and training programs in preparation for a chemical
emergency.379 The SERC is responsible for reviewing all local plans
developed by LEPCs to determine whether they comply with'EPCRA,
376 EPCRA is codified at 42 U.-S.C.A. 11001-11050 (West Supp. 1994). '
377 EPCRA §301, 42 U.S.C.A. §11001 (West Supp. 1994).
§11003 (West Supp. 1994).
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.- '*<: _-::c r.-<:: requires, facilities that,store, extremely hazardous suosrances ..
,T. amounts greater than the threshold planning'qua-ntit>- to notify the SERCJ.
when, the facility is subject to EPCRA's .emergency planning, requirements.^
T-'ev must also designate-a representative who will participate, with the LEPC
to-prepare emergency response plans for the facility. Facilities, are also ' .
required to provide the LEPC with any.information that the, LEPC deems-is
• necessary to develop or implement an emergency plan. , .. . '~
' Section 304 requires covered facilities to immediately report3** any release
(other than-a federally permitted release)382 of.-a listed hazardous substance
in an amount that exceeds the threshold amount*" to the.SERC of the state
that is likely to be affected by the release, to the LEPC for the district where the
" release occurred, and to the National Response Center if the substance is a
' CERCLA-listed hazardous substance. Initial notification may be made by
phone radio, or in: person; however, Section 304 requires the facility to
provide a written follow-up emergency notice as soon as possible after.the
release385 EPCRA also requires'facilities to file a'one-time follow-up report
within 30 days of the'one-year anniversary of the initial written: notification
with the appropriate.EPA regional office. . • ±-
2. The Toxic Release Inventory (TRI) ,
EPCRA' contains provisions that are designed to provide information
to the general public concerning chemicals to which they may be exposed.
Section 311 requires owner and operators of facilities, that are subject to
OSHA's Hazard Communication Standard regulations to submit copies of
380 cprT, A gW- 49 U S C A §11002 (West Supp. 1994). Notification was required by May 17,
.
amount that is equal to or above the EPA-set threshold amount)
381 See; 40 C.F.R §355.40(b)(2) (1994) for the required contents of such nouce.
wt • i = *,«> c,,Wp<-t to reduced reporting requirements. See, 40 C.F.R..93Ui.s
(199C4rrreTe^Tange: ^^±SS«* & rLase'is considered a "new" release
but is subject to.reduced reporting requirements. , R ' ,
pounds. • . , .---.,- - ..'•
- ^85 See, 40 C.F.R. §355.40 (1994). . . . • '
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:-e-- Nigeria;' Safety Data Sheets or a list of hazardous substances that they
hara'.e I'o the 5ERC the LEPC, or the local fire department.386. New facilities
'mus: ccrr.piy with Section 311 within three months of becoming subject to
EPCRA's provisions. ' '.
Section 312 of EPCRA requires-owner and operators of covered facilities to
submit an- emergency and hazardous chemical inventory form to the SERC,
the LEPC, and the local fire department.387 Section 312 reporting takes two.
forms. Tier One reporting covers general health and physical hazard
information. Tier Two reporting outlines health and physical hazards on a
chemical-specific basis.388 Tier One reports are required to be filed on March
1st of the first year after which a covered facility becomes subject to EPCRA's
reporting requirements and annually thereafter. Tier Two reporting usually
occurs upon request by an interested party; however, some facilities prefer to
file Tier Two reports in lieu of Tier One reports.389 . • •
TRI reporting requirements are set forth in Section 313 of EPCRA.39-0
Section 313 requires manufacturers with more than 10 employees who either
use more than 10,000 pounds or manufacture or process .more than 25,000
pounds of one of the listed chemicals or categories of chemicals391 to report
annually to EPA and the state on the maximum amount of chemical present
at the location during the previous year, the treatment or disposal methods
used, and the amount released392 to the environment or transferred off-site
386 EPCRA §311, 42 U.S.C.A. §11021 (West Supp. 1994).
387 EPCRA §312, 42 U.S.C.A. §11022 (West Supp. 1994). • '
388 EPCRA does provide covered facilities with some trade secret protection. The specific _
cheriiodidentity of a covered chemical can be claimed as a trade secret « submissions to EPA;
however Sosure may be required to health' professionals if the information is required for
•* W'
*e puo of diagnosis/treatment to assess exposures, or in c**s of >^ •"£**?£
HalbleS, Emerge^ Panning and Community Right-to-Know Act, ui Environmental Law
Handbook, supra note 3, 'at 477.
389 U. at 465. ' '• ' " '
390 EPCRA §313, 42 U.S.C.A. §11023 (West Supp. 1994).
391 More thari 320 chemicals are covered. . .
39* Routine and accidental releases, in addition to permitted releases, are covered. • • ;
393 Releases to POTWs and other treatment, storage, and/or disposal facilities are included as
well as releases to the air, water, and land. . . ' .
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::r ::ea.:-~er.: ar.d- or disposal^4; Covered "facilities-mus: use .the L.he:..ica'i
Release inventory Reporting Form (Form. R).••>•'"•" .
" The "data that-are obtained through'EPCRA's reporting requirements are.
compiled in the Toxic Release Inventory, also known as "TRI," which is a
computerized database main'tained and published each year by .EPA.396
Covered facilities must maintain the records, supporting their' TRI
submissions, for at least.three years from the date the report was filed.
These records are subject to EPA inspection and verification. :
The TRI has been widely used by citizens, environmentalists, states, and
industry, as an environmental "scorecard" and the public disclosure of . .
facilities' toxic chemical.release-and transfer, information has resulted in
many facilities voluntarily reducing their releases and off-site transfers.397.
In 199,0, EPA implemented the "33/.50 Program" which requests companies to
voluntarily reduce their toxic chemical releases and off-site transfers by- 33%
by 1992 and 50%'by 1995. As of October 1992, more than 977 companies had •
committed to the program', pledging-an emission reduction-of nearly 350
million pounds. •• .- '.-.''''.
3. Enforcement •_._•-•
EPCRA authorizes the imposition of administrative,,civjl> and criminal
penalties for violations of its provisions.398 -Actions for enforcement can..be •'
394 Section 313 applies to facilities that are in Standard Industrial Classification (SIC)
Codes 20 through 39; that have ten or more full-time employees; and that manufacture, import,
process; or otherwise use a listed toxic chemical in excess of threshold quantities. Certain uses
of listed toxic chemicals are exempt, such as (1) use as a structural component of a facility, - .
(2) use of products for routine janitorial or maintenance services, (3) personal uses by employees,
(4) use of toxic products in.connectidn with motor vehicle, maintenance, and (5) use of toxic
materials contained in intake-water or intake air. Also, if the processing or use of similar.
articles results in less than 0.5 pounds of. a .listed toxic chemicals per year, the releases are
exempt. W. Halbleib, supra note 388, at 468-469.
395 The information required by Form R includes the name, location, 'and principal business
activities at the facilities; off-site locations to which listed waste has been transferred; the
quantity of listed chemicals entering each environmental medium annually; information on • -
' source reduction and pollution prevention activities undertaken at the facility during the
preceding year; and a certification that.the report is complete and accurate.
396 The TRI is available through EPA; however, the public may obtain specific .information
about facilities'or releases by submitting a request in writing to EPA.
397 In response to TRI, nine major petrochemical manufacturers made' public commitments
- to reduce their emissions of selected toxics into the environment by almost 83 percent by
December 1993. • E. Elliptt and'E. Thomas, supra note 92, §17.1(B)(3), at. 1270..
398 EPCRA §325, 42-U.S.CA, §11045 (West Supp. 1994).
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'--.••.. •-.-: =:• rne.EPA. SERCs, LEPCs. and private citizens. EPCRA enforcement
•5 ceneraliy done at the state level; however, violations of'Section 313 are
«u"-"e<" "O fe-ieral enforcement. •
" Section 325 allows the EPA Administrator to order owners and operators
of covered facilities to comply with Sections 302 and 303's emergency
Planning requirements.399 Violations are punishable by civil penalties of up
to S^ COG per day. Violations of Section 304's emergency notifications may be
punched more severely. Any person who knowingly and willfully fails to
provide notice of reportable releases can be fined up to $25,000 or imprisoned
for up to two years or both.400 Second violations may be subject to a fine of
up to 550,000 or 5 years imprisonment. Violations of §311 are subject to
510,000 fines per day of violation; violations of §§312 and 313 are subject to '
fines of up to $25,000 per day of violation.401 .
I A PROACTIVE APPROACH TO REDUCING ENVIRONMENTAL
BURDEN-THE POLLUTION PREVENTION ACT
On October 27,1990,'Congress passed the Pollution Prevention Act,402
establishing pollution prevention403 as the nation's primary pollution
control strategy. Prior to its enactment, the control of pollution after its
generation had been the main focus of federal and state environmental
statutes. The emergence of pollution' prevention reflected a growing
awareness on the part of environmental policy makers that controlling
399 H.
400
EPCRA §325(b), 42 UiS.CA. §11045(b) (West Supp. 1994).
401 Id. ' " ' ' '
W e Pollution Prevention Act. 42 U.S.C.A. §§13101 et seq. (WesfSupp. 1994).
• materials handling. Id. . '
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-, - ..••.'•..r.'.i-Ter'its generation .was no longer elective.4'-4 • v-,-.;....
'Traditional methods of- pollution control had proved" ^effective because
:ne:r rocus on regulating chemical pleases into'specific environmental''media
•failed to reduce the total amount of pollution, that was entering the
environment through all environmental media -- land, water,'and air. For
example, the Clean Water" Act regulates pollutant discharges into-the nation's ,
navigable waters; the Clean'Air Act regulates discharges into the nation's air, •
and the Resource Conservation arid Reauthorization Act regulates pollutant .
discharges into the nation's land.; Each environmental statute focuses on :
•'cleaning up a specific environmental'medium; however, in doing so, they.-
neglect the fact that in cleaning up one environmental medium, waste is
often shifted to another for -ultimate disposal.405 , , ,
; The goal-of the Pollution Prevention Act. is to shift the nations waste
strategy, from the control of waste-after its generation to the reduction of waste -
,at its source. 'The premise is that, by reducing waste generation at its source,
the Act will reduce the need for the waste's treatment and subsequent .
disposal, resulting in'less waste entering the environment through all
, environmental media. .
The Act establishes a hierarchy of waste strategies with pollution - ~ -
prevention as the highest priority. The Act states that: (1) pollution should be
prevented or reduced at the source whenever feasible, (2) pollution that
cannot be prevented or reduced should be recycled, (3) pollution that cannot be
prevented or reduced or recycled should be treated/and (4) disposal or other
releases into the environment should be employed.only as a last resort.406
The Pollution Prevention Act, however, is not an action-forcing statute in
that it does not require industrial facilitiesto adopt pollution prevention.
Rather, its provisions are designed to educate facilities about-the
404 Data had shown that, despite more than twenty years of regulation, the volume and
Prevention Act, 17 Colum. J. Envtl. L. 153,156(1992). . ;
405 FTr example, traditional air pollution control devices, such as scrubbers, remove pollufcnts
'' from ieTSrJam. This practice ensures that air pollution is controlled but it increases me
poLion tSat enSs the environment because the removed pollutants are usually deposed of m
Srenvlonmental medium. As a result, traditional environmental pohcy.does•£»«£«
S'total .amount of pollution entering the environment through aU media. It merely shifts it
around. • , ' • --.» ' •
• 406 PPA §6602(b), 42 U.S.G.A. §13101(b) (West Supp, 1994). .--._.
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er.v.::r,~er,:al and economic benefits of pollution prevention in the hope
tru: education will be sufficient to encourage its widespread adoption.
To that end, the Act required EPA to set up a Pollution Prevention Office, •
independent of its media-specific programs, to develop and implement a
strategy to promote source reduction. In addition, it authorized a grant -
program to encourage the development of state source reduction technical
assistance programs and it created a Pollution PreventionInformation
Clearinghouse to compile information on source reduction and make it
available to the public. .
' The only mandatory provision contained in the Pollution Prevention Act
is §7; which requires owners and operators of facilities that are required to-file
a Form R under SARA Title III to .report to the EPA information regarding
the source reduction and recycling activities that the facility has undertaken
during the previous year.407 This information is>then made available to the
public through EPA's Pollution Prevention Information Clearinghouse.
Like EPCRA's TRI data, §7 has been effective at triggering some companies'
voluntary adoption of pollution prevention. Rather than explaining to the
public why they generate and dispose of such large quantities of toxic
chemicals; these companies have chosen to adopt pollution prevention in -
order to reduce the amount of waste-they generate and, therefore, treat or '
transfer* off-site for disposal. ' -
By reducing the generation of pollution, pollution prevention reduces the
need for pollution's treatment and subsequent disposal. It; thereby, protects
the environment because less waste enters the environment through all
media -- air, water/and land. However, pollution prevention also produces
economic benefits for industrial facilities. By reducing-their generation of .
' pollution, industrial facilities can enjoy lower waste disposal costs, decreased
environmental liabilities, and more efficient manufacturing operations.
• 40~ PPA §7 42 U S C A. §13106 (West Supp. 1994). Section 7 requires owners and operators to
provide information on source reduction and recycling activities with each annual toxic
.chemical release inventory report. The information required to be reported mdudes: (1) the
amount of each listed chemical entering the waste stream before recycling, treatment, or •
disposal, and the percentage change from the previous year;.(2) the'amount recycled, the -
percentage change from theprevious year, and the recycling process used; (3) the amount
Seated on-s'te of off-site and the percentage change from the previous year; (4) specific source
' reduction practices used by the facility; (5) techniques used to identify source reduction
opportunities; and (6) the amount released because of accidents or other one-time releases.
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• ..-..- jr.ArrV ;, 1991; more than one-hair" of the states haa enactea p.Giruncn
r.:ever.::cn laws which varied widely Some'.state laws require1 industry- to
deveicr facility-wide pollution prevention plans,408 Other states simply
require facilities to declar£ that pollution prevention is their preferred
method for dealing with hazardous waste.409 , .,- • -. -
CONCLUSION: POLLUTION PREVENTION-IT'S THE BEST POLICY
'The present.system of environmental law and regulation is complex,
costly, and fraught with potential liability -civil and, -more frighteningly,
criminal. The system's complexity stems from the fact that environmental '
regulation can emerge on federal, state, and local levels .and often those
regulations.conflict. In'addition, statutory mandates and environmental
regulations may be.ambiguous or they may have been improperly promul-.
gated. The, uncertainty over the validity and meaning of environmental, •
mandates often results in" litigation between the-regulated community and .
regulatory agencies., ' • "• : ,' :- , •, .
Although litigation can settle conflicts over the-validity and meaning of
'.environmental laws and regulations; the inevitable price of litigation is delay.
Delay can benefit regulatees who want to postpone their compliance with f -
regulatory requirements for financial reasons.' However, prolonged litigation'
can also delay cleanup actions410 and produce;further environmental ...
damage, resulting in more expensive cleanups in the long-run.
In addition, the-cost of complying with environmental laws and
regulations is skyrocketing as new regulations are promulgated. The EPA
has estimated that, by the year 2000, over $155 billion (in 1996 dollars) or
approximately 2.7 percent of the Gross National Product will be spent
408 As of April 1992 industrial facilities, are required to develop pollution prevention plans in
Arizona California, Georgia, Louisiana, Maine, Massachusetts, Minnesota, Mississippi, New
:£Sy?Ne^o£6rego^^ See, WRTTAR, State '
Legislation Relating to Pollution Prevention (April 1992).
4°* Alaska Colorado, Connecticut, Delaware, Florida, .Illinois, Indiana, Iowa, Kentucky,
North Carolina, Rhode Island, and Wisconsin have all enacted pollution prevention laws;
•' however' these states do not require facilities to develop pollution prevention plans, Rathe?,
they encourage facilities to adopt pollution prevention by providing technical assistance and
^The perfect example of needless delay occurs in the Superfund program. Trie average site
takes approximately 10 years from discovery to delisting from the NPL;however, only 3 of
. ' those 10 years are spent actually cleaning up the site. E. Elliott and E. Thomas, supra note 92,
§17.5'(B), at 1348.- . ' ' ' •
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ar.r.uailv on environmental, compliance.411 A tremendous amount of
rr.cr.ey will be spent,on environmental lawyers who will.be hired by
reflated entities and government agencies to litigate and enforce the
system's complex requirements. Federal and state regulatory agencies are also
increasingly using their enforcement authority to impose criminal and civil
liability on individuals as well as on companies.412 Virtually all' of the major
federal environmental statutes contain enforcement mechanisms and
provide for some form of criminal liability.413 In such a hostile regulatory
environment., regulated entities are advised to make good-faith efforts to
comply with state and federal environmental requirements. Self-reporting
and cooperating with governmental officials, may reduce the chance that
harsh penalties will be imposed at trial.414
The environmental law system's complexities, costs, and liabilities have
triggered the development of corporate strategies designed, to. reduce-the
regulatory requirements to which regulated facilities are subject. One of those
strategies is pollution prevention. By reducing a facility's generation and, .
therefore, release of pollutants into the environment, pollution prevention
can simplify the facility's compliance duties and reduce its environmental
liabilities. . " ,
Another strategy is implementation of a corporate compliance program
that is designed to determine whether a facility is in compliance with
environmental law and regulations.415 The main tool that companies use
412 In 1982, the United States Department of Justice formed an "Environmental
that oreseoites environmental offenses. As of October 1983, that unit had indicted 704
£d KlduTand IS Corporations, convicted 476 individuals and 240 corporations and received
SS^SSSlSSfin.. In addition, more than 404 years ^^^ sentenced
consisting of over 206 years of actual confinement. J. Arbuckle, supra note 9, at 57.
413 /j at 47 '
414 For example, EPA recently proposed about $2.9 million in fines ; .gainst 39 chemical
companies for reporting violations under the Inventory Update Rule of TSCA. .The total
reS 50% reductions for companies that reported even though they had n^sed the
epTrtmg deadline. EPA Propel $2.9 Million in TSCA Fines; Self-Reporters Get 50%
Reduction, Environmental Policy Alert (BNA) 24 (July 6, 1994).
' «S Sere is a growing trend to provide companies that perform environmental audits wi*
from environmental enforcement actions. The premise is .that companies that
environmental audits, disclose violation to government agencies,
^untary environmenta aus, sco
and act promptly to correctthe violations should enjoy some immunity. Compaq ; Say EPA .
•'Enforcement Policy Collides with -Voluntary Audit Program, Environmental Reporter (BNA)
416-417 Gune 24, 1994).
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.. -^-c;—.r,j ';crr."'.iance 'is 'th'e. environmental audit. An .er,v:rcr...e..._:. ,
audits a comprehensive Accounting.of material ;and waste flows through a .
facility" focusing en,specific industrial processes in order to ensure that all by-
products of the process are captured, treated, disposed of, or re-used'. : '
Environmental audits enable'facilities to account for their waste flows'and
ensure that they are properly managed, simplifyihg. their compliance- duties
and reducing their environmental liabilities. . ; _
The purpose of this guide has been to introduce chemical, engineers to. the
field of environmental law. .The field,-however, is constantly changing. As a
. result, this guide should be used as a reference to the structure and scope of
environmental laws and regulations. It should not be used to guide
compliance. For specific compliance questions, readers are advised to consult
the relevant federal or state environmental agencies. ;
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APPENDIX A - AN INTRODUCTION TO THE LEGAL CITATION SYSTEM
[ have used the uniform system of legal citation, which is used in legal
wnting, 'throughout this guide. The rules of the citation system can be found
in A rn. form Sv^m of Citation, which is available at any bookstore that
carries law books. • •
FEDERAL STATUTES
The basic citation form for United States environmental statutes contains
a citation to the United States Code -- a series of volumes (consisting of what
are called "Titles") in which every .federal statute is codified after it is enacted.
Many environmental statutes are found in Title 42 of the United States Code
(U S C ) which covers matters concerning public health and welfare. As a
result, their citation usually begins with "42 U.S.C." or "42 U.S.C.A "
"US.C.A." is an abbreviation for "United States Code Annotated. "«6
After the "42 U.S.C" or "42 U.S.C.A.'", the citation will list a section symbol
and a section number^*, "42 U.S.C.A. §7401") «7 The section number tells
the reader where to find the specific provision within the cited title. For
example, if a statute is cited as "42 U.S.C.A. §7401", the citation indicates that
the specific statutory provision can be found in Title 42 of the United Stated
Code Annotated at section 7401. If the citation contains two section symbols
and then a range of sections numbers, the citation indicates that the
referenced provisions consist of a series of statutory provisions (e.g., 42
U S C A §§ 9601-9675)-418 The year that appears on the spine of the volume,
the year that appears on the title page, or the latest copyright year (in that
«6 Tne United States Code Annotated is an unofficial versioh of the United State Code _that
^Statutes are often discussed in their uncodified form. For example, a reference may refer to
iw*S WCERClS ™ "SKff " "§107" is the section number that designated the statutory
-
U&CA. 59601 « ** 'which tells th, reader that U>e statute begms a.
9601 and follows thereafter. ', •
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r^,-j:;^: -reference! .follows.'the section'numbers,and :s 'enc.osea -:r, -- . .
~ a ren theses-. When referencing statutes, keep in, mind that a .'single-Title can
er.corr.pass a number of volumes'of the United States Code.
. ' STATE STATUTES - , ".-.-. •
' State statutes are codified in a different series' of volumes. For example,
Michigan statutes can be found in a series of volumes known as Michigan '
Compiled Laws Annotated.' These volumes are cited as "Mich. Comp. Laws
Ann." As with federal statutes, the citation will be followed by a section
number and the publication date of the volume. Each state has a different
..citation system, so refer to A Uniform System of Citation for the proper form
for each state. ' . . , . . .
FEDERAL REGULATIONS ;\
The basic citation form for federal regulations is a citation to the Code of •
Federal Regulations, which is abbreviated as "C.F,R." For example, the
citation for a Clean Water Act Effluent Limitation Guidelines is 40 C.F.R.
§405.53 (1980). Like statutes, the citation contains a title number/a section
number, and the date of the volume. This means that-the cited regulations-.
can be found in Title:40 of the C.F.R. at section 405.53. Like statutes, C.F.R.
titles can encompass a number of volumes. .
STATE REGULATIONS
State administrative.regulations are found in the state's respective
administrative compilation. For Michigan, state environmental regulations.
are found in Michigan Administrative Code, which is cited as "Mich. Admin.
Code." The citation isystem that is used (in terms of title number, section
number, and date of: the volume) are the same as in the federal system.
FEDERAL CASE LAW ;
" -Federal judicial decisions (cases), are published in federal case law reporters.
For example, all federal Supreme Court cases are found in either the official.
reporter.- United States Reports, which is cited as "United-States" or the
unofficial reporter (published privately) -Supreme Court Reporter, which is
cited as "S.Ct". All federal appellate co.urt cases are found in the Federal
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Re-rter, wh.:r. is cited as either "F.", "F.2d", or "F.3d".419 All federal district
court cases are found in the Federal Supplement, which is cited as.'T.Supp.".
For example, the citation: T'nited State* v. Northeastern Pharmaceutical
A- rhprrvlcai Co.. 810 F.2d 726 (8th Cir. 1986), tells the reader (1) the name of
the case (the name of the entity who brought the case is listed first followed by
a "v" which denotes "versus" then the name of the party .that is defending '
the case), (2) the volume of the federal reporter in which it is found - here,
volume 810 of the second series of the Federal Reporter, (3) the page number
where the case begins - page 726, (4) the court that decided the case if the
reporter covers the cases of multiple courts - the Federal Court of Appeals for
the Eighth Circuit, and (5) the year 'that the case was decided - 1986.
STATE CASE LAW
State judicial decisions (cases) ,are published in many different reporters.
For example,'Michigan's Supreme Court reporter, Michigan Reports, is. cited
as "Mich." The reporter that contains Michigan appellate court .cases,
Michigan Appeals Reports, is cited as "Mich.App." The reporter that contains
Michigan Court of Claims (the courts of the first level of adjudication in
Michigan), Michigan Court of Claims Report, is cited as "Mich. Ct. Cl." In
addition, Michigan case law can be found in the North Western Reporter,
which is art unofficial reporter of case law from several states including
Michigan. It is cited as "N.W" or "N.W.2d" if the more recent series is used.
"419 The "2d" and "3d" refer to the second and third series of volumes respectively.
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Pollution Prevention, and
Chemical Engineering
Open-Ended Problem: The Design of a
CFC-Free, Energy-Efficient Refrigerator
Samer F. Naser, Postdoctoral Research Fellow ••
: Chemical Engineering-Department, University of Michigan .
Gregory A. Keoleian, Assistant Research Scientist.
School of Natural Resources and Environment, and Manager,
' ,\'ppc, University of Michigan . ' , .'
Levi T."-Thompson, Jr., Associate Professor
U-M Chemical Engineering Department; University ot Michigan
Edited by Jeffrey Handt \ : ' '
N'PPC University of Michigan ' . •
May Be reproduced
freely 'or non-commercial
educational purposes.
Open-Ended P'ODiem
August '.994
-------
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;'--:':-".'Prevention in
hemical- Engineering
-
Open-Ended Problem: The Design of
a CFC-Free,Energy Efficient Refrigerator
TABLE OF CONTENTS
INTRODUCTION & SUGGESTED USE
SECTION I
' Interoffice Memo (December 2, 1992) ... ........ ....... ......... - 5
Interoffice Memo (December 9, 1992) ....-.* .................... 6
Technical Data Sheet, .......... ...-- ...... -•• ......... •••-.- ............ -s
References..... ............ . ......... • ..... — ..... • ..... • -------- "- .............. 9
SECTION II .
A Brief History of Refrigeration....-:....- ............ ........... 11
Refrigerator Features: A Consumer Perspective ........ 12
The Ozone Depletion Problem ............. ....................... 13
. Global Warming and the Refrigerator ..... ....; ...... -~ ...... 16
Choosing a Refrigerant — ...... ............ * ........ •• ........ *• ...... l7'
Factors Which Influence Energy Consumption ..... .....20
Life Cycle Design ... ..................... •• ...... • .......... -.....-• ....... 21
References ............ ...... ............... ------ •••- ..... • ........... •••- ...... 23
SECTION II
Introduction .. — ..»...-..-. ...... • ......... •• .............. • ................. 2S
. Alternate Refrigerants to be Considered ....... .,.......:.... 25
Refrigeration Cycle Components.;. ------- »...-• ............... 2S
Refrigeration Cycle Calculations .... — . ------ •- ........ -•• 27
. Results/Discussion
of Refrigeration Cycle Calculations ..... ...»-- ...... ........ 27
Refrigeration Load — . ....... .................. -------------- .........29
Heat Exchanger Areas — ...... ........... — - — ...... • ...... -.-29
Energy Consumption ...... ------------------ r ................ — ....... ^°
References...— ....... -••• ..... ........-..,••-— — ••••• ............ ••- 35
APPENDICES
Appendix A_
Appendix B........
Appendix DJ.....r-«.--. — ........ ------ -— ....... - ........... ""
'_ ' : - O—in tnflid Proft'*'"' 1
Natcn* Pollution Pr.vnaonC.n»rtorHigh.rEdue.Uoo.Un.v.r*»o«Mieft-Qin ..**"•'_. Apr* 199*-
D»n«Buiiamg,430EutUnivtrirty,AnnArt)orMI4ai09-1ll5 • , _
Phbnt 313.764.1412-F«x: 313.936.2195 •E-miil:npp«jmieh.«du ' . , •
' ' ' '
-------
List of Acronyms
ARI Air Conditioning and Refrigeration Institute.
ASHRAE American Society of Heating,
Refrigerating, and Air Conditioning Engineers
AV Adjusted Volumt
CFC Chlorofluorocarbcn
COP Coefficient of Performance
DSM Demand-Side Management
HER Energy Efficiency Rating
CWP Global Warming Potential
HCTC Hydxochlorofluorocarbon •
HFC Hydrofluorccarbon
OOP Ozone-Depleting Potential
PAG Polyalkyiene glycols
RE Refrigeration Effect
SERF Super-Efficient Refrigerator Program
PROBLEM INTRODUCTION
AND SUGGESTED USE
. The discovery that chJorofluorocarbons (CFCs), widely
used as refrigerants, are causing ozone depletion, and
the increasing energy efficiency awareness brought
about in part by the, Green House Effect (caused
mainly by the burning of fossil fuels) necessitates a
significantly different approach to the design of a
refrigerator. This case study will address these
important and current topics as well as the more
traditional topics involved in the design of a refrigera-
tion system. The following is an outline of the three
'sections in this case study.
SECTION I: Problem Statement
The recently announced "Golden Carrot Program" to
develop a super-efficient refrigerator will be used as
the problem statement' The Super Efficient Refrigera-
tor Program, Inc. (SERF), a consortium of over thirteen
electric utilities, has announced a bonus of $30 million
to be awarded to the manufacturer that develops and
markets by 1995, a CFC-free refrigerator that is"25-50%'
more efficient than the 1993 federal efficiency stan-
dard. The bonus would be paid per refrigerator sold,
at $50 per 100 KWh/year energy savings over the 1993
federal standard. A benefit of using this context to
pose the design problem is the introduction of the
concept of Demand-Side Management (DSM).
The problem is posed in the form of two memos. The
first introduces the regulatory pressure driving the
conversion to the CFC-fre&s-ergy efficient refrigera-
tor. Manufacturer-supplied ^formation in Appendix
A may be used to supplement this memo. The second
memo provides design specifications which can be
used by the students to begin work on the problem.
Material from Appendix IB may be given to the
students at the discretion of the instructor.
SECTION II: Teaching Aids
These are summaries of topics which are either directly
related to the design project .or beyond the scope of this
design but also very important in that they provide
either a background for the design or a future direc-
tion. These may be given before the design project is
started or as it progresses. The following is a brief
description of these teaching aids:
National Pollution Prevention Center. University of Michigan
Open-ended Proomn • 2
April 199*
-------
A =P,E= HISTORY OF,REFRIGERATION
A rrr.e: i'-LTvey o: refrigeration cechr.oiogy from snow
use .r ar.c~.er.; a-mes to .the current phaseout of CFCs.
REFRIGERATOR FEATURES ''
A Consumer Perspective: a survey of design features
that consumers are usually most concerned with:
reliability, appearance, noise, access, smells, initial
cost, operating cost, defrost system,.temperature ,
uniformity, safety, environmental impact, etc. ,
THE OZONE DEPLETION PROBLEM
The problem and how it was discovered. Mechanism
of ozone depletion by CFCs. Ozone Depletion Poten-
tial (OOP) of current and prospective refrigerants.
• _ * ., '
GLOBAL WARMING •
AND THE REFRIGERATOR
The Green House Effect,and .gases contributing to it.
Global Warming Potential (GWP) of current and
prospective refrigerants. Energy consumption and its
relation to the green house gases. . .
CHOOSING A REFRIGERANT
Criteria that help determine which refrigerant may be
used: safety, thennodynamic efficiency, compatibility
with compressor oil and material of construction, OOP,
GWP, cost, availability, etc. Some potentially good
choices for a refrigerant.
FACTORS WHICH INFLUENCE THE ENERGY
CONSUMPTION OF A REFRIGERATOR
Insulation and gaskets, CFC-free insulation, refrigera-
tion cycle .used, electrical components.
I
LIFE CYCLE DESIGN
Introduction to the concept of life cycle analysis as
taking a literally global perspective when evaluating a.
production process. The material in Appendix C,
which gives more details on the subject, may be given
to the students. •
SECTION ill: Design Problem Solution,
This section places more emphasis on compar.r.g
different alternatives and' showing their advantages.
and disadvantages "rather than concentrating on a,..
single .design., An attempt was made'to keep the focus"
"on energy efficiency and CFC replacement as it affects
energy efficiency. Graphs which can be'easily used to
consider a multitude of options are indud'ed in this
section. Hopefully they will give the instructor and the
student insights into thejnterplay of the enviror.men- .
tal and design issues.
Op«n-«nded Prooiem • 3
' . • . • April 199*
-------
Op«n-«n
-------
Section I:
Problem Statement
Ann Arb'or, Michigan • ; .."..•
INTEROFFICE MEMO - . ... •
- - " '_.,'.' t - •,. „ - ' , ,
!/- • ', "*- •, " '"
DATE:' • December 2,. 1992 '.,.'..--'• ' ' .'. , .
TO: J, Jones • ... .' . ' -.. ••
Senior Research Engineer ' '.-''. ..''•... '- . • . .,',':
FROM: S. Nase.r . ._,-_ .''.'•.•' ' . . ' . . . -."-.'.'
Manager, Project Development • , . • . .
.RE: Design of a now •nergy afficiant CFC-fr«« refrigerator. - _ .
As you know the mounting evidence that Chlprotluorocarbons (CFCs) ar. causing Stratospheric ozone depletion has
increased the pressure to discontinue their use. This drive to phase out.CFCsis consisient with both our corporate
policy - we have to take care of our planet - and external demands from regulatory and public interest groups. As o< • .
July 1992 venting of CFCs to th« atmosphere is illegal.' Pressure is also increasing to not even consider what we had
counted on as short term substitutes (because of their tower ozone depletion potential) to CFCs:
Hydrochlorofluorocarbons (HCFCs). Ihave enclosed some information furnished to us by two of our suppliers, Du Pont
and ICI Americas, on the regulations regarding CFCs and HCFCs.
The recent Copenhagen meeting held in November1992 to revise.the Montreal protoort has accelerated the phaseout
of CFCs and brought the schedule lor this chang* more in accord with th. deadline President Bush announced m ^
February of 1992 forth. U.S. CFC production must drop to 25% of 1986 levels by January 1994 and. is to be stopped
completely by January 1996. Aceording to the Air-Conditioning and Refrigeration Institute (ARI), current world con- _
sumption is already, below 50% d 1986 levels.' As for HCFCs. they are to be complet0ly phased out by th. year 2030.
Based on these d.v.topm.nts and our .m«rging pollution pr.vention policy. manag.m.nt has decxled that the
• domestic refrigerator that w. manufactur. is not to us. or contain any CFCs or HCFCs.
I would lik. you and your team to investigate alternative refrigerants for use in our product. Management is considering
participating in an incentive program which takes the form of a competition for a $30 million prize. The goal, a to design
and buitd the most energy efficient. CFC-fre. domestic refrigerator on the market.' I will provide you wrth more,deta,led
-' information as soon as a decision is made. :.
Op«n-!tnd«d Prpoiem • 5
April ,199*
-------
Frirld Whirl Corporation
Ann Arbor, Michigan ' . ..
; ' .INTEROFFICE MEMO
DATE; Decembers, 1992 .
TO: J.Jones , .
Senior Research Engineer '
FROM: S. Naser
"cTu^n^c. eid D8mand.SWa-Manag9mant Th« panicularinitiatrv i, design^ to encourage the
Svelopment and immadiat. production of an energy sup-r-.Hici.nt. CFC-fr.« domMc r.fngerator.
ready by April 1993 and. if awardid the contract, start sh.pp.ng unrts as aariy as 1994.
features:
Op«n-«n«t
-------
y C - T 9 ' , - " " . • ' - , ' . t '
. ' Freezer: .' ,'. 5.0ft3 '' ' '- ' •• • .-~ - . , . '
Fresh Food- Seeton:-"' j 13.0ft3. .' ; - •.
. Norn ai Operation Design Conditions: • '. , '
• Freezer Temperature: ~ '5?F ' . __ - ^ .
- Fresh. Food Temperature: 38 "F
.Ambient Temperature': 90 'F ^ . ; ' .
Pull Down Time: ; . 2 minutes • •' . .
down Tim* is defined as ». tim** MM ro coo/ the airinsid* 0th. r^^or from *»**« to ti*s,9n
The est.mate given hers is basad on litaratur, values (or arfmptycsDmet.
The refrigerator.must be able to operate satisfactorily at th» foltewing extreme conditions: , ••' _ ;
' • Freezer Temperature: 0, °F . ' . • ' .• ' -
Fresh Food Temperature: 37 °F, - . ,, , •• '• .
Th.se wmett^nTaTe*^ nfrigeratoK Irom different manufacturers.
The federal standard referred to above is the. Department of Energy (DOE) level 4 energy efficiency .standard; which
Snn'ng n 1s93 requires new refrigerators with automate defrost to have the following max,mum energy consump- ,
tion: ; . > • ••'.'.• • • '.-••' ' '' ^:. . -
KWh/year- 329 1- 11.8 xAV . ^ •-."••
'where the Adjusted Volume (AV) is defined as: . - . .
,'- AV. volume of fresh food compartmont -t- 1 . 63 x volume of freezer
These standards are bas*d on DOE simulations' for refrigerators which utilize batter insulation and more efficient _
compressors than are conventionally used. ; ^r , . • , , '
I have anached some technical data from our labs and some materials furnished by our supplier which I believe w,ll be
"YOU ThoSdeterrnin. what =h.ng.» - need to maKe in our refrigerator «™*™"^**™
. abovl without using CFCs or HCFC,, and produc. t r.frig.ra.or with an energy effoency that can make our cbmpany
comp^miv.inthe-Ck)'ld«nCarnrt-com^and«tiilb«comm.faallyv.abl«. . ,
Op«ri-«n«t
-------
TECHNICAL DATA SHEET
Nomenclature
• .- = internal heat transfer coeffiaent in Btu/hr-ft2-0?
• U = overall heat transfer coefficient in Bru/hr-ft^F •
• m = mass fiow rate of refrigerant in ib/hr
• C = heat capacity of refrigerant in Btu/tt>-°F
• (i = viscosity of refrigerant in Ib/ft-hr
• k = 'thermal conductivity of refrigerant in •
Btu/ft-hr-°F ,
Compressor
• clearance space = 5% of total volume
• compressor isentropic efficiency = 70%
• compressor motor efficiency = 80%
• volumetric efficiency (excluding losses due to
clearance volume) = 90%
• speed = 60 revolutions/second
Evaporator
• h, = 515.2 (
• U« l/((0.98/h,) + 0.092)
• fan power = 10 watt
CONDENSER
• h= 592.5 {
• fan power =» 14 watt
OESUPERHEAT PART OF CONDENSER
- 0.079)
Interchanger
•U=40
• 14 "F superheating
DATA ON CURRENT REFRIGERATOR .
• uses R-12 as refrigerant . . •
• fresh food section insulation is 1.5 inches of R-i 1
blown urethane foam
• freezer insulation is 1.85 inches of R-ll blown
urethane foam '
1 (
• depth: 22.1 inches, width: 26.5 inches, height: 53
inches
Anti-sweat Heater
• on 30% of the time
• power = 19 watt.
Cabinet Heat Gains .
• internal heat transfer coefficient = 1.6 Btu/hr-fF-'F
based on inside area
• external heat'transfer coefficient = 1.47 Btu/hr-fr-=F
based on outside area
• freezer gasket heat transfer coefficient = 0.0055 Btu/
hr-in-'F
• fresh food section gaskefheat transfer coefficient =
0.0014 Btu/hr-in-°F
'• gasket heat transfer coefficients are based on gasket
length .
• ignore comer effects
• freezer and fresh food section are separated by 3 -
inches of insulation
• assume no heat transfer occurs across the insulation .
Pressure Drops
• ignore pressure drops due to flow
• assume isenthalpic expansion in.the-expansion valve
r'OSie— • s
Apr- •99''
-------
REFERENCES '
•!?.= -srrv A wa;:s EPA Guidear.es on CFCs.'.'-
l -992.
= Editors ?*%e: Heating/Piping; Air Conditwnwg journal,
January '.993.
> "A S3C-million Super-efficient Refrigerator."
rW, July 1992. .;.'''
« Federal Register, Rules and Regulations-November
17, 1989, pp. 47935 ,47938. , :
s Scjterund, A. J.'.and J. Coriano. "Stumbling Blocks to
Energy Efficiency and CFC Phase-out." Appliance .
-Man u we . turer, April 1992. . •'.'.'
' Environmental Protection Agency/ Multiple Path-
ways to Super-efficient 'Refrigerators. DRAFT, Febru-
ary 1992. •.'.-.. . :
' "Refngerators: A Comprehensive Guide to the Big_
White Box." Consumers Report, July 1992, pp. 456-465.
• Department of Energy - Technical Support Document
DOE/CE-0277.- 1989, Chapter 3.
-------
Op«n-«nd«a P'ooie™ • ' 0
Aom 199«
-------
s_,"-- :,:-.-; .-•...-.--?':.'.,;•"•;.. 3y u",e end p: the
r-retser." .T2r.rj_-v e.ecs-.crv was 'sei'r.g used :o power .
rerr.;:sT2-;:r.—.acr-ir.ery -The .first automatic house-
he.- :=rr. zsraTcr. us:r,2 sulfur dioxide, debuted :n
'.9'.§. 3v '.*3C chioiofiuoroca."bor,s (CFCs) had been
proposed ar.d demonstrated. Since then, CFCs have
repiacec ill other refrigerants in vapor compression
cyce-b,a'sed machines.. ,t ' -
REFRIGERATOR FEATURES:
A CONSUMER PERSPECTIVE
Refrigerator Types :
The most popular type of refrigerator has the freezer
occupying the top section (top moun'ted freezer). This
type of refrigerator is available with the widest . •
selection of capacities, styles, and features. It generally
costs less to operate than'other types of refrigerators
with .similar features and capacities. Its claimed
capacity comes closest to matching its actual capacity.
The eye-level freezer makes things in it easy to reach
' while making vegetables and other items' normally
stored in the bottom shelves'harder to reach. This type
of refrigerator has wide shelves which makes things
easy to reach in general.
The second most popular refrigerator is the side-by-
side type, in which the.freezer is located vertically,
beside and along the fresh food compartment .It is
slightly more expensive to run than,the top freezer
. models. Its freezer is larger than comparable top or
bottom freezer models. Easy access js distributed .
between the freezer and fresh food section. Shelves are
narrower, however, making things harder to reach.
~ The least popular refrigerator type has the freezer
occupying the bottom part of the refrigerator. Bottom
freezer models of this type are not available in as wide
a selection and features as the other two models. This
type of refrigerator is most likely more expensive to
• buy and to operate. The fresh food section is easier to
reach while the freezer is not A necessary pulj-out
basket.in the freezer reduces its capacity.
A Refrigerator's Important Features
TEMPERATURE BALANCE
A refrigerator should be able to maintain a freezer '. •
temperature of anywhere' between 0-5 °F and a fresh
food cosr.parrmenr'terr.perar-j'e •:: " to 5s
-------
Section 11:
Teaching Aids
A BRIEF HISTORY OF REFRIGERATION '
People discovered the value of cold environments in
preserving foods very early in history. The-inhabitants
of Crete were aware of this in 2000 B.C. It is said that
Alexander the Great had his soldiers served snow-
cooled dr.nks in the hot summers of Petra from the
winter snow stored in trenches covered with branches.
Manv anaent civilizations where snow was not
abundant used day pottery, which allows some stored
water to permeate the surface and evaporate, cooling
the water inside. In areas where snow was available, it
was stored for the warmer seasons or transported to
warmer areas where it could be of more value. An ice
transport industry flourished in the nineteenth century,
taking natural ice from North America to the West
Indici, Europe. India, and Australia. Ice from Norway
was also transported to the warmer southern parts of
Europe. The use of natural ice or snow was comple-
mented by the addition of various salts known since
antiquity (table salt, salt peter, etc) which lower the
freezing temperature of water to a degree that depends
on the salt and its concentration. This practice com-
bined with various natural insulating materials
allowed temperatures below 32 «F (0 ^ to be achieved
and maintained. . .
The birth of mechanical refrigeration occurred in the
middle of the eighteenth century when W.Cullen
demonstrated the making of ice by the evaporation of
• ethyl ether when its pressure was mechanically
reduced. In 1810, Sir John Lesley used the first sulfunc
acid-water pair absorption refrigeration cycle to .
produce- ice. In 1834, J. Perkins patented the first vapor
compression machine. He described his invention:
"What I claim is an arrangement whereby I am enabled
'to use volatile fluids for the purpose of producing the
cooling or freezing of fluids, and yet at the same time
constantly condensing such volatile fluids, and
bringing them again and again into operation -wishpu.:
waste." It does not seem that Perkins followed
through on his invention.
Next-came the air cycle '(expansion and compression
only with no evaporation and condensation) refrigera-
tion machine, invented by J. Gome in 1845. Since me
refrigerant used was air, it did not need to be m_a
closed cycle; thus the cold air was injected into «ne
enclosure to be cooled'. By 1860 F. Carre was selling•
500-pound-a-day ammonia water absorption rerr.gera-
tion machines. Interestingly, the source of energy ;o;
these machines was not mechanical but heat from
firewood, coal, or gas, The refrigerant, ammonia, goes
through the same steps it would in a vapor compres-
sion cycle except that there is no compressor. The
ammonia vapor is condensed under elevated pressure
in a condenser which rejects heat to the atmosphere,
and then the liquefied ammonia is expanded through a
capillary tube into the evaporator where it absorbs
heat, producing the refrigeration effect and becoming a
gas. The ammonia gas is then mixed with water where
it is absorbed and rejects its heat of solution. The
. ammonia-rich solution is.pumped to the generator,
where'a high temperature heat input causes the
ammonia to desorb under elevated pressure. This hign
pressure ammonia gas goes to the condenser and
repeats the cycle, while the weak ammonia solution i*
returned to the absorber and repeats its cycle.
The first commercial application of .the vapor compres-
sion cycle occurred in the middle of the nineteenth
century and was pioneered by A. Twining and J.
Harrison, who used ethyl'ether as the refrigerant.
Since then, various refrigerants were used:; car>on
dioxide (T. Lowe, 1866), ammonia (D. Boyle, 1872), and
-------
r.~? —.c-^r.'r^-z evvder.ce'Or, the •
r^DTer.ral .lesrr.ictive afreet of releasing CFCs into'the
a—osrre.-e ar.'fi .T.creasu-vz'public pressure'resulted ir,;.-•
a sar. cr :re use of'CFGs as propellants m aerosol
oroducs e.g. spray cans) by the U.S. and some other
governments. This resulted, in the elimination (in ' -
theorv) of- one of the major sources of CFCs in the .
atmosphere. The problem lay dormant with many
countries continuing to use CFCs in'aerosols and other
applications. By 1985, annual worldwide CFC prcduc-
.• don was nsing by We* In' 1986,23% of all CFCs
produced were being used as refrigerants, 28% as
propellants, 26% for foam insulation blowing, and 21%
as solvents for cleaning applications.
. The increased use of CFCs led to the 1985 Vienna
Convention, which called on participants to formulate
a plan for action to determine the danger CFCs posed-
to the atmosphere and means of dealing with that
..threat. Unfortunately, an outcome which reflected the
lack of urgency and ignorance of the enormity of the - •
problem prevailed on that occasion.' That same year, a
team of British scientists published data which showed
that an ozone hole had been developing over Antarc-
tica since 1980. Their findings were confirmed by' • ,
others. This discovery brought a sense of urgency to
- deal with the problem. . - ' . •
With the effects of CFCs on the ozone layer estab-
lished, unprecedented international action started to
take place. In 1987 the Montreal Protocol w,as signed
by most of the world's industrialized countries. This t
agreement called for a freeze on the production and
consumption of CFCs starting in 1989, and a gradual
phaseout to end in the year 2000 with the total elimina-
tion of CFCs. In the U.S., the new dean Air Act of .
1990 mandated sharper cuts in CFC production but
maintained the total phaseout date of the year 2000. In
February of 1992, President Bush moved up the total
phaseout date for the U.S. to the end of 1995. In
November of 1992, die Copenhagen Revision of the
Montreal Protocol brought the world phaseout sched-
ule in line With that of the U.S.4 The U.S. Environmen-
tal Protection Agency (EPA) is formulating regulations
and certification procedures *.* for the recovery and
recycle of CFCs since venting of Ozone-depleting .
compounds became illegal at the start of July 1992
(violations carry fines of up to $25,000 a day7)- Several
companies are already advertising.CFC Banks and
recycle programs in anticipation of a CFC
"crunch."1-''1'-" - : - .
. How could these r-.ar,-cr.ade cotr po-j-r.as .-.ave ;u;.- j • _
profound effect on :the amospher'e? 'A~r>y aoes- : :re ,
ozone layer replenish itself? How does the ozor.e '-a;, e: .
deal with chlqnne released from natural sources sue-
as sea water and. volcanoes?, Tne concentration of
ozone in the stratosphere is controlled by a photo-
chemical steady state in -which the ultraviolet radiation
produces ozone, which is consumed by various other
reactions resulting in a constant steady state ozone .. ;
concentration.12 The introduction of chlorine into the
stratosphere causes this steady state to shift to a lower
ozone concentration dependent 6n how mudy chlorine
is present. -Since a chlorine atom is not consumed.;n
any of these reactions, it.can destroy an estimated
' 100^)00 ozone molecules. It also means that there is a
.cumulative'effect as more chlorine-from.-CFCs enters
the stratosphere to:add to that which is already
present. The atmospheric -life of CFCs ranges from 60-'
'500 years, which means that many CFCs released-will
eventually'find their way to the stratosphere.'-3. Chlo-
rine from natural sources such-as volcanoes never
reaches the stratosphere12 because of its affinity for
water. This affinity causes it to dissolve and eventu-
ally fail as rain. CFCs act as a Trojan Horse by allow-
ing chlorine to enter the stratosphere before it becomes
active. . ' "' -
Alternatives to CFCs
As replacements for CFCs, another class of haloginated
compounds which is less harmful to the ozone layer,
hydrochlorofluorocarbons (HCFCs), has been pro- -
posed as a short term solution. HCFCs have an
atmospheric life of 2-20 years as opposed to the 60-500
years of CFCs. It appears, however, that both industry •
and government are moving to bypass HCFCs and use
.alternatives to CFCs which have no effect on the ozone
layer. This is evidenced in the recent Copenhagen
Revision to the Montreal Protocol. These revisions
have put in place binding restrictions on HCFCs which
will cap their consumption beginning in 1996.» the
reported level of use at that time plus 3% of the CFC
use level.4 A complete phaseout is mandated by the ;
year 2030. Countries not complying will have trade
sanctions imposed on them. The outlook for eliminat-..
ing CFCs is good: worldwide CFC output has dropped
from 1.13 million 'metric tons in 1986 down to 680
thousand metric tons in 1991.' Industry has already
introduced compounds which.haveno effect on the
ozone layer and is investing and committing to finding
and using alternatives to CFCs.14 •» •
-------
"A "-.it ,; :re ,~rc.-ar :e ;:' v.e fc'.iow.r.g fearures ;:v
'•:•_• iS'-sion '.a puror.a&e a refrigerator?" UG = "Very
"
""Not irr;
inir.a- cos:
better seals
storage space / interior volume
width of available kitchen space
energy efficiency
mobility
interior volume
movable shelves
operating cost
hesght of available kitchen space
depth of available kitchen space
Response
9.2.
9.1
9.0
8.8
8.7
.8.7
8.6
8.5 '
8.4 '
8.4
8.4
freezer location (top, bottom, or side) , 8.4
doesn't break easily .8.4
sturdier doors .8.2
easier to clean underneath
easier to clean seals
deep door shelves
type of shelves
kick plate is secure
environmental impact
freezer room
larger crispers
makes more ice
control's odors • • .
changeable color panels
ice/water servict
bottom freezer
makes different shaped ice
8.1
8.0
8.0
7.8
7.7
7.4
6.9
6.7
5.4
5.4
4.4
4.2
3.0
1.9
THE OZONE DEPLETION PROBLEM
Today's computer images of the ozone hole c •. =r •
Antarctica dnve home the reality of the problerr. which
was suspected, in theory, twenty years ago. Ln 1974
two chemists. Dr. F. Sherwood Rowland and Dr. Mar.o
Molina, theorized that chlorofluorocarbons (CFCs)
could be destroying the stratospheric ozone and thus •
depleting the earth's protective shield against ultravio-
let radiation from the sun. Ozone is' made up of three
' oxygen atoms. It is formed in the stratosphere by the
sun's radiation, which breaks up an oxygen molecule
into its two constituent atoms.' These atoms, being
•very reactive, immediately react with oxygen mol-
ecules to form ozone. Ozone absorbs ultraviolet
radiation in the wavelength range of 290-320 nan.om-
eters. This radiation is harmful not only to earth's
surface life, but also its aquatic life. It could cause skin
cancer in humans, retard plant growth, and harm r.ear-
surface marine life.. To understand the Rowland-
Molina theory, which is still valid today, we need to
take a closer look at CFCs.
CFCs are simple compounds which contain onl£.. •
chlorine, fluorine, and carbon atoms. Another related
family of compounds is hydrochlorofluorocarbons
(HCFCs), which contains hydrogen in addinon to the
ozone-destroying atom chlorine. HCFCs are not as
damaging to the ozone layer as CFCs are. Two of the
most commonly used CFCs are R-11 which has the
structure CCljF, and R-12 whose structure is CCljFr
Currently, R-ll is used in air conditioning and indus-
trial chillers while R-12 is used' in domestic and
industrial refrigeration. CFCs are very stable, non-
toxic, non-corrosive, and nonflammable compounds
with excellent thermodynamic properties, all reasons
for their widespread use in refrigeration, air condition-
ing, insulation material manufacture, and as propel;
lants in some countries. Their stability dose to the
earth's surface Cower atmosphere) is in part to blame
for their troublesome nature. CFCs diffuse to the
. upper atmosphere (the stratosphere, 15-10 kilometers
above the earth's surface), where exposure to the
strong levels of radiation present in the stratosphere
causes these normally stable compounds to break up
and release reactive chlorine-atoms. The chlorine acts
as a catalyst which, in its reaction-regeneration cycle,
both destroys an ozone molecule by taking its third
oxygen, and prevents one from forming by reacting
with atomic oxygen. At the end of this process, the
chlorine atom is ready to repeat the cyde again and
again.
Op«fl-«nd«3
• '3
l '994
-------
GLOBAL WARMING ' • -.
AND THE REFRIGERATOR ;
•j-.g r=::-. jerarcr contributes to global wanning.in two
wa vs. First ,t is-an eiecrncty consumer, thus a major
• oart of the energy- it consumes comes indirectly; from
fossil fuels. Fossil fuel combustion generates carbon
dioxide, which-.is'the primary gas causing the green-
house: effect and global warming.' The second cdnfri-
.butiori of the refrigerator to global warming is due td
chiorofluorocarbons (CFCs) used as refrigerants,'and -
hydrochlorofluorpcarbons'CHCFCslj used as blowing
agents in the manufacture of foams'for insulation.
Refrigeration applications in general consume about
one fifth of tfte total electricity .generated in the U.S. In
1988 this was 603 billion Kilowatt-hours, 23.4% of the
total electricity generated.1'. Refrigerators and freezers
consumed .6.9%, air conditioners and heat pumps
' 10.2%, and commercial and industrial refrigeration
.6.3%. To reduce global warming, energy.consumption
. of refrigerators must be reduced. This'can be achieved .
by increasing the mechanical thermodynamic effi-
ciency of the refrigeration system, and,by using more
and /or better insulation. .The U.S. government is .
moving aggressively in this area. The new 1993 energy
standards for refrigerators require 30% more efficiency
than the 1990 standard.20 A study by the Department
of Energy (DOE)2t •=. estimates that by the year 2010 the
1.993 standards, if not amended, will result in less than
a 2% decrease each in the emissions Of carbon dioxide,
sulfur dioxide, and nitrogen dioxide.
Even though CFC and HCFC emissions are small ' :
compared to those of carbon dioxide, their chemical
properties make them orders of magnitude more
efficient in absorbing infrared radiation and thus
•"contributing to the greenhouse effect In addition,
CFCs absorb infrared radiation in a range of wave-
. lengths where carbon dioxide and water do not absorb,
thus compounding the problem;lf The impending
phaseout of CFCs and the introduction of replacements
which are less energy efficient introduces an interest-
ing dilemma. By replacing a CFC refrigerant with one
which has no greenhouse effect but is less efficient, you
• would increase the energy consumption of a refrigera-
tor and thus increase the amount Of carbon dioxide
produced as a result of burning more fossil fuel to
supply the increased energy demand. It.isthus
important not to compromise energy efficiency when
switching over to the new generation of refrigerants.
The :oilov.-,r.§ '.:5t •.iluscates the C'.jci. '-Virrurg
Poter.nal iC-WP) of different refrsgerar.ts re.ar.ve ::
that of carbon dioxide:n .
Table 2.
Global Warming Potential of Various Refrigerants
Compound
Carbon dioxide
R-ll
R-12 . .,
R-ll* -
R-114 ' • •'• •
•'13300 • •'-.
R-22". '
R-123
R-134a .
R-l52a
R-290
R-717 ' ;
R-500
2,700
R-S02
7^00 .
Formula GWP-
co
CCI^FCCIF,
CClFjCCIF,
CHC1F2
CHCljCF,
CF,CH,F
1
1300
,3,700
.1,900
6,400
.510.
28
".'400 _
,46" '-
0
0
azeotrope:
73.8% R-12
26.2%'R-152a
azeotrope:
51.2%R-115
48.8% R-22
^'Source Epstein, G. ]. and S. P. Manwell. "Environmen-
tal Tradeoffs between CFCs and Alternative Refnger-
16
. Asm 1994
-------
--.» ^'SJ :: rer.a.-s-er,: ccrr.pour.ds :hat industry has
•'oc-'i^c ":r'.s r.vdrof.uorocarbons rHFCs). Because
'._ev —-a;r ro ch'.onrse atoms, these compounds have
r.o s:'is~ i" -"-e ozone layer. They have many simiian-
~es re C?Gs but also several differences. Other
Lerra-ve refrigerants outside of the fluorocarbon
• ram'-y have beer, largely ignored; some postulate, the
reason being industry's desire to sell patentable
chemicals. One such alternative is propane. Work in
England and Germany on refrigerators which use
propane"-17 •" indicates the feasibility of using this
substitute, whose only problem is flammabtlity.
Developers claim, however, that the amounts used in a
demesne refrigerator are so small '.or. tr.e oraer :: -Tii
is presen: in two disposable cigarette iig.-.ters, as :o
preclude the nsk of explosion.
To compare refrigerants with respect to their effect on
the ozone layer, a numeric parameter has been devel-
oped which incorporates: a molecule's potential to
participate in the ozone depletion process, is atmo-
spheric life span, and the time horuoh considered for
future ozone depletion.13 This parameter, normalized
with respect to R-ll, is called the Ozone Depletion
Potential (OOP) of a compound. As this parameter is
still evolving, there will be some inconsistency in
• reported values. The following are some ODPs for
various refrigerants:111* .
Table 1. Environmental Effects of Various Refrigerants
Refrigerant Formula OOP
R-ll
R-12
R-13
R-113
R-114
R-115
R-21
R-22
R-123
R-142b
R-12S
R-134a
R-143a
•R-152a
R-290
R-717
R-500
R-502
CChF
CC12F2
CC1F3
CC12FCGIF2
CC1F2COF2
CC1F2CF3 v
CHC12F
CHCIF2
CHC12CF3
CH3CC1F2
'CHF2CF3
CF3CH2F
CH3CF3
CH3CHF2
CH3CH2CH3
NH3
azeocrope: .
73.8% R- 12
262% R-152a
azeocrope:
5U% R-115
48.8% R-22 .
1.00
0.99
0.45
0.83
0.71
0.38
0.04
0.05
0.02
0.06
0.00
0.00
0.00
0.00
0.00
0.00
0.74
022
Est Atmospheric
Life Span (jears)
59
122
7
98
244
539
7
is
2
-------
Pressure urcp due to the flow of the refrigerant, . •"
although net very significant, is related to the viscosity
and density of the refrigerant. High density and low'
vascosity reduce the piping pressure drop due to flow
for a particular refrigerant. A refrigerant's transport
properties, as well 'as its thermodynamic properties,
are influenced by the type of compressor lubricating
oil used.24 Since the domestic refrigerator uses her-
metically sealed compressors, part, of the oil (which is .
• totally miscible with the refrigerant) circulates with the
refrigerant. This oil-refrigerant solution has markedly
different properties from just a pure refrigerant, the
compressor lubricating oil is, therefore, an important
part of the refrigeration process and is discussed
below.
Compatibility with Compressor Oi,i
In a hermetic reciprocating compressor, the oil serves
several purposes:
1. lubricating moving parts in the compressor.7
2. providing a seal of the gas between the suction and
discharge sides. / ,
3. removing heat from the bearings and crankcase.
4. reducing noise generated by the moving parts.
The oil in a hermetic compressor must possess, in
addition to the required lubrication performance at the
operating temperatures, the following characteristics:
1. electrical insulation. •
2. reusability with refrigerant, particularly at the low
temperatures encountered in the evaporator, where
immiscibility will cause reduced heat transfer and poor
oil return to the compressor.
,3. chemical stability, to last the expected lifetime of the
sealed system and withstand the range of operating
temperatures encountered.
An important parameter used to characterize a
lubricant's miscibility with the refrigerant is the Lower
Critical Solution Temperature, defined as the tempera-
ture below which immiscibiliry occurs.
Environmental Impact
With the discovery of the danger CFCs pose to the
ozone layer and the ensuing public awareness and •
government regulations, the environmental impact of
using a particular refrigerant has become of para-
mount importance. The contribution of'a refrigerant
to global warming, although not regulated yet, is also
becoming an important issue. Table 3 shows current
and prospective refrigerants and their Ozone Deple- •
tion Potential (OOP), and Global Warming Potential
(GWP). - „ • •
Table 3. Environmental impact parameters'of
various refrigerants; , ,
Refrigerant Compound class OOP , W7
R-ll
R-12
R-13
R-I13
R-114
R-115
R-21
R-22
R-123
R-142b
R-125
R-134a
R-143a
R-152a
R-290
R-717
R-500 '
R-502
CFC
CFG
-CFC
CFC
CFC
CFC
HCFC
HCFC
'HCFC
HCFC
HFC
. HFC
HFC
HFC
hydrocarbon
ammonia
azeotrope:
73.8% R-12
26.2% R-152a
azeotrope:
51.2% R-115
48.8% R-22
1,00
0.99
0.45
0.83.
0.71
0.38
0.04
0.05
0.02
0.06
'o.oo
0.00
0.00
0,00
0.00 ..
0.00
, 0.74
0.22
' 1,300
3,700
•}•
, 1,900
*,400
' 13300.-
7
510
28
7
? •
•400
?
46
O1
0
2,700
7,300
Op«n-«nd«d Problem • 18
April 1994
-------
CHOOSING A REFRIGERANT
THERMODYNAMICS
Most current refrigeration systems use the vapor
compression cycle which in its most ideal state can be
thought of as a reversed Camot engine. Work is input-
to the system via the compressor, producing a net
effect of pumping heat from a low temperature to a
higher temperature. How well a refrigeration cycle
operates depends, among other things, on the thermo-
dynarmc properties of the working fluid, the refriger-
ant. The thermodynamic properties of the refrigerant
must also be compatible with the operating tempera-
ture range. Thus the freezing point of the refrigerant
must be well below the operating temperature of the-
evaporator at the working evaporator pressure;
otherwise the refrigerant could freeze in the evapora-
tor. Similarly, the operating pressure in the condenser
should be below the critical pressure of the refrigerant,
otherwise no condensation will occur.
From an energy efficiency point of view, the most
important thermodynamic measure of a refrigerant is
its Coefficient Of Performance (COP), which is defined
as follows:
• Net refrigeration effect of cyde
COP- — '—~~
Work input to refrigeration cyde
The COP provides a measure of how much work needs
to be supplied to the system to achieve a given refrig-
eration effect. Thus the higher the COP of a refrigerant
for a given application (the temperature extrema of the
cyde), the more energy efficient it is. For a reversed'
Camot engine, a purely theoretical concept, the COP is
independent of the refrigerant and depends only on
the temperatures between which the cyde operates. It
can mathematically be derived from the above defini-
tion of the COP and is:
efficiency of a refrigeration cycle. Using a re'fngerant
with a higher latent heat, for example, means that less
of the refrigerant needs to be used to remove a certain
quantity of heat A refrigerant which operates with a
large pressure difference between the condenser and
the evaporator (high compression ratio) causes the
efficiency of the compressor to be lower and its exit
temperature to be higher, both undesirable operating
features. Reciprocating positive displacement com-
pressors (the type used in the domestic refrigerator)
have a space between the piston head and the casing to
prevent damage to the piston head in the-compression
stroke. This space is called the Clearance Volume and
is usually 4-15% of the total volume. The Clearance
" Volume contains refrigerant gas which expands and
contracts with every stroke of the piston, which results
in a lowering of the actual volume of the refrigerant
that is compressed. A quantity which measures this .
inefficiency is the compressor Clearance Volumetric
Efficiency (Nn) which is defined as follows:23
1 • Clearance Volume fraction x
inlet gas density
outlet gas density
COP-
(reversed Camot)
Low temperature of cyde
Difference between
temperature extrema of cyde.
This is an idealized measure which serves to define the
maximum attainable performance for a given refrigera-
tion application no matter what type of process or
working fluid is used. . '. '
In practice, "other thermodynamic properties come into
' play which affect the design and consequently the
As can be seen from the above expression, the higher
the inlet to outlet density ratio (or in terms cf pressure,
the higher the compression ratio), the lower the
Clearance volumetric Efficiency. Other factors which
contribute to lowering the Total Volumetric Efficiency
(actual volume of gas/volume swept by piston) of a
compressor are: leakage losses past the piston and
valves, throttling in the valves, absorption of the gas in
the lubricating.oil, and h'sat exchange losses from the.
compressor.
Transport Properties
A major departure from the ideality of a reversed
Camot cyde is that the refrigerant has to exchange
heat with the surroundings. This requires a finite
temperature difference across which heat transfer can
occur. The refrigerant flows through pipes, heat
exchangers, and expansion valves, all of which pro-
duce a pressure drop. The heat transfer in the heat
exchangers ties a refrigerant's performance to its heat
transfer characteristics: heat capacity, thermal conduc-
tivity, density and viscosity. Higher values for heat
capacity, thermal conductivity, and density, and lower
values for viscosity result in improved heat transfer.
Op«n
April 1994
-------
_ _,__ .. .A - Dfre oc'or :ar. be'cierected at concentrations
of ^ess :har. 23 P?^-11. Exposure to concentrations of
:,rOC ppm for more than half an hour could be lethal.23
R-7;r \s flammable; its explosive limits in air are from
:6-25*0 by voiurne.30 Ignition would require a high
temperature such as an open flame.0
FACTORS WHICH INFLUENCE THE
ENERGY CONSUMPTION
OF A REFRIGERATOR
Insulation
A refrigerator's,main function is to keep an enclosed .
' space at a temperature which is below its surround-
ings. If a perfect insulator was available, then once the
desired .low temperature was reached, no energy:
would need to be expended to keep the contents at
their low temperature. Unfortunately, there is no
perfect insulator, and the refrigerator must be reason-
• ably priced and have a door. .The presence of a door.
necessitates having some seal, which is usually a
gasket. A gasket provides less than ideal insulation
and thus, even though it has a small exposed area,
accounts for 10-20% of the cabinef s total heat gain." A
possible solution: the use of a double gasket which
would improve insulation and reduce moisture,
reducing the need for the anti-sweat heater and
' consequently producing more energy savings.
Insulation currently used for refrigerators has a
thermal resistivity of R7 per inch (i.e., a thermal
conductivity of 1/7 Btu-in«di/hr-ftJ-eF) and is made of
urethane foam which is blown using CFC R-ll. With
. the pending ban of CFCs, alternative blowing agents
are being considered, namely R-141b and R-123, both
HCFCs." The foam blown using these HCFCs has an
insulating value that is approximately 7% less than
that blown with R:ll. The fact that HCFCs are also
ozone depleting, contribute to global warming, and are
to be eventually phased out hailed to the consider-
ation of carbon dioxide as a blowing agent. Foam
made using carbon dioxide has an insulating value
which is approximately 16% lower than that made
, using R-lll*
An emerging technology mayprovide the answer to
the quest for a CFC-free, energy efficient insulator.
This technology relies on vacuum panels which use
various filler materials (powder, aerogel, fiberglass) for
support* The most developed ;of these is the powder
filled vacuum insulation panels. The powder t-r.ey ,
contain is.precipitated,silica. Aerogei: vacuum insular
tion panels contain silica glass with a porosity of 90-
95%.* There are several disadvantages-to Busing these
insulation panels: they are difficult to install in the
mass production of the refrigerator, expensive, and
considerably heavy. Table 4 provides a rough comr.
parison between the various insulating materials.
Table 4. Insulating parameters of various materials.
Material cost per •
Relative , volume
(Ib/ff) unit
Urethane foam with
"0,16
R-ll as blowing agent
Urethane foam with carbon
0.4
dioxide as blowing agent
Fiberglass
0.04 '
Vacuum insulation
1 '
(powder, 7.6 torr)
Vacuum insulation
2
, (aerogel 76 torr)
Rvalue Density
, per inch
4
25
20-30
'•1.7
1.5-,
12
Source Feldman, K. Thomas Jr. "Advanced Insula-
tions for Refrigerated Shipping Containers." ASHRAE
Journal, February 1993.
Refrigeration .Cycle Design
Domestic refrigerators currently use the vapor com-
pression cycle and operate with one evaporator
removing heat from the freezer,,and a condenser .
rejecting heat to the atmosphere. The theoretical
efficiency of the cycle can be improved if heat is
removed from a higher temperature and/or rejected to
•a lower temperature (the ideal reversed; Carnot cycle).
Op«n-«nd9d ProWem • 20
April 1994
-------
Source- Essrein. G. J. and S. P Manwell. "Environmen-
^"j^a - e^'ffs between CFCs and Alternaave Refriger-
ants." ASKR-4E Journal, January 1992. ,
Note that OOP is used to calculate the increased taxes
on ozor.e aepletmg chemicals. Progressively higher
taxes and restrictions are being placed on CFCs and
HCFCs. Venting of ozone depleting chemicals is
currently illegal in the U.S. With current regulations
CFCs wi'il be banned by 1996, and HCFCs by 2030.
Current Alternatives
R-12(DICHLORODIFLUOROMETHANE) •
Is the refrigerant currently used in the domestic
refrigerator. It has good thermodynamic and transport
properties, is non-toxic, nonflammable, and chemically •
stable. It is, however, a CFC and one of the most .
harmful to the ozone layer. It has one of the highest
GWPs of the refrigerants listed. It will be completely
phased out by the end of 1995.
R-134A (TETRAFLUOROETHANE):
'is the leading contender to replace R-12. It has a
similar (slightly lower) thermodynamic performance to
R-12. It has a zero ozone depletion potential and a
small global warming potential. It is nonflammable
and very stable. Tests on its toxidty are still under-
way, but they seem to indicate low* -or no toxidty.2*
The major problem with R-134a has been its incompat-
ibility with mineral oils used in current refrigeration
equipment.17 R-134a has a low solubility in mineral
oils and as a result "drops our in the evaporator and
causes compressor oil starvation. A substitute class of
oils, polyalk" ylene glycols (PAGs), which have good
' miscibility with R-134a, has fallen out of favor because
of its high moisture absorption tendency, its somewhat
low electrical resistivity, and its tendency to decom-
pose at high temperatures (about 390'F).a Currently,
polyol esters seem to offer the solution: they are
'miscible with R-134*, they are less hygroscopic than .
PAGs, and they decompose at high temperatures only
• in. the presence of steel. R-134a seems, to be on its way.
to replacing R-12. Ford Motor Company recently
announced that Taurus cars are now being built with
air conditioners which use R-134a."
R-290 (PROPANE) .
This is the refrigerant that is being supported by
environmentalists. Thermodynamically, it is equiva-
lent to R-12 and even superior in some aspects. The
problem with propane is that it is flammable. Propo-
nents of using R-290 maintain that because its refrig-
eration effect per pound is more than twice that of R-
12, only half the mass of R-12 is required if propane is
used. -Developers of propane-based refrigerators17-'
claim the amount of propane is so small that it would .
need to leak into a space as small as the refrigerator
itself for the gas to explode (R-290 explosive limits in
air'are, 2.3-7.3 % by volume30). They .add that modem
systems are so well built that the possibility of leakage
is virtually non-existent. The major barrier to the
. development of propane-based refrigerators seems to
be regulatory. In England, for example/standard
BS4434 bans hydrocarbons in domestic refrigerators, a
restriction Greenpeace,is lobbying to eliminate." In the
U.S. several gallons of propane can be legally trans-
ported and kept indoors. But once the propanejs in a
fixed installation such as the refrigerator, even when it
is in such a small quantity, it is subject to the safety
rules of a large facility.11
R-152A (DIFLUOROETHANE)
if
Has been used so-far as one of two components in the
azeotrope R-500. Its investigation and use had been
encouraged at one time by the EPA because it has a
lower Global Warming Potential than R-.134a." Its
thermodynamic performance is slightly better than R-
I34a and it is compatible with the mineral-based
lubricants.51 A major impediment to using R-152a is its
flammability: its explosive limits in air are 5.1-17.1%
by volume.30
R-717 (AMMOHIA)
Has been used mainly as a refrigerant in industrial
• applications. It is a good refrigerant in many respects.
It has a very high refrigeration effect per pound, its
heat transfer properties permit use of smaller heat
exchangers, and its high critical temperature and low
freezing point make it suitable for a wide range of
applications. It is readily available and inexpensive.
R-717, however, reacts with the copper and aluminum
tubing used in currentrefrigerators, thus requiring the
use of more expensive and less conducting iron.31'
Ammonia also requires a high compression ratio which
results in a high compressor temperature. R-717 is an
ProBitm •19
Aoril "99*
-------
•c..o-Aed i.-d -desigr. for ease of assembly/disassembly ,
:ns-ares that most-, of the refrigerator, is recoveFabie.
The abovs demonstrates a growing.trend, further
aJor.g in Europe than the U.S., which attempts to look
at a process or product design through a total systems
approach which is not confined to the immediate
perimeter of the process or product Essential to such
an approach is total cost assessment, which incorpo-
rates-hidden, liability, and often ignored envuronmen-
tal-.costs into the accounting procedure.40'" Such a
procedure will eventually become standard as the
movement grows to make manufacturers responsible
for their products "from the cradle !to the grave."
" New laws enacted recently in Germany require
manufacturers to take back their products. The
German automobile manufacturer BMW has a pro-
gram in place whereby.its customers can return their
old automobiles for recycling. BMW is designing its
automobiles to enhance readability by using such
simple techniques as color coding and parts labeling, ,
and'such complex techniques as redesign to use
compatible materials. An approach such as this not
only reduces the waste stream that eventually must be
disposed of, but also slows resource depletion.
Basic to accepting life cycle design is the understand-
ing that the Earth's resources are finite. There is a
limited quantity of raw materials, a limited quantity of
energy, and limited disposal space (land, water, air).
Processing of raw materials requires energy corner-
-sioh, which produces pollution. The iiraita'eons of
recycling necessitate waste disposal.. Such disposal
requires space in landfills or poisons the air and water;
and consumes energy. Thus the'need for pollution • •
prevention at the source to avoid the generation of the
waste in the first place. Once waste is generated it will
eventually end up in one form or another in either the
air, water, or land. Waste treatment, which usually'
shifts waste from one medium to the other (e.g.
' incineration reduces solid waste but increases air
pollution) does not solve the problem.
In order for life cycle design to work, it must be
implemented very early in the life of a process or
product and not done as an afterthought A systematic
approach which keeps in mind the limited resources of
the planet (raw materials, energy, disposal space), and
the fact that ultimately regulations and public pressure
will protect these limited resources must be, followed
to a void'increased financial and public relations costs.
In design there is no magic recipe*, tradeoffs must be
s made between capital expenditures, operating costs,
regulations, customer preferences, etc What life cycle
design practices attempt to do is' insure that environ-
mental liabilities and benefits are accounted for.. In
many cases this results in dividends not only t» the
environment, but also to the manufacturer. •
Recommended Reading .
Keoleian, Gregory A. and Dan Menerey. Life Cycle
Design Guidance-Manual: Environmental Requirements
and the Product System. Cincinnati, OH! U.S. Environ-
mental Protection Agency, Risk Reduction Engineering
Lab. (EPA600/R-92/226) US EPA, 1993.
ProW«m • 22
•' Apfti'1994
-------
Since tr.ese temperatures are determined in part by a
~adec~~ between the evaporator and condenser heat
«-harge area and the temperature difference between
•hewc'ic-s nuid aild the freezer °r freSh food'scctlon'
rmprovements in the design of these heat exchangers
would allow a reduction in the driving temperature
difference, and thus a better cycle efficiency. Another
' possible refrigerator design modification which would
exploit this principle is the use of a dual cyde: one
cycle for the freezer and another with higher efficiency
for the fresh food section. Such a design could employ
separate refrigerants for each cyde and consequently a
separate compressor, evaporator, and condenser for
each cycle. Alternatively, a single compressor and
refrigerant could be used, with separate evaporators
for the1 freezer and, at a higher operating temperature,
the fresh food section. The two evaporators would
operate at different pressures. A recent theoretical
study which evaluated the dual cyde design with
different refrigerants predicts energy savings of up to.
23%.» A complete analysis of these options can be
found elsewhere.14
A refrigeration cyde which preceded the vapor
compression cyde in practical application is the.
absorption cyde. The first commercial machines,
developed by F. Carre in 1850, used ammonia and
water as the absorption pair. Interestingly, the source
of energy for these machines was not mechanical but
thermal, from firewood, coal, or gas. In a typical
absorption refrigeration cyde, the refrigerant, ammo-
nia for example, goes through the same steps it would
if it were in a vapor compression cyde except that
there is no compressor. The ammonia vapor is con-
densed under elevated pressure in a condenser which
rejects heat to the atmosphere; this liquefied ammonia
is expanded through a valve into the evaporator where
it absorbs heat, producing the refrigeration effect and
becoming a gas. The ammonia gas is then mixed with
wto»r, where it is absorbed and rejects its heat of
solution. The ammonia rich solution-is pumped to the
generator where a.high temperature, heat input causes
the ammonia to desorb under elevated pressure. This
high pressure ammonia'gas goes to the condenser and
repeats the cyde. The weak ammonia solution returns
to\he absorber and repeats its cyde.. The energy input
to the cyde occurs in the generator in the form of heat
input rather than work as is the case in the vapor
' compression cyde. This provides a degree of flexibil-
ity: first of all, "low quality" energy can.be used;
' second, the energy can be supplied directly from the
fuel without having to go through several mtermec;a:e
steps such as electricity generation and mechanical
compression as is the case in'the vapor compression
cycle. Currently, the only widespread use of the
absorption cyde is in Japanese air conditioners and in
mini-bars in hotel rooms.14 The absence of a compres-
sor makes possible the quiet operation required of the
second application.
Individual Component Efficiencies
The efficiencies of the individual electric devices that a
refrigerator contains also influence its energy con- _
. sumption. The major consumer is the compressor and
its driving motor. A'standard rating number used to
describe the efficiency of a compressor is the Energy'
Efficiency Rating (HER), which is defined as follows:
:EER<
Refrigeration effect achievable
by compressor in Btu/hr •
Power input to the compressor in Watts
Note that the definition of EER shows a depenSence
on the refrigeration effect, which depends on the
refrigerant used in the cyde and the operating tern-
peratures of the cyde. Compressors rated between 4.0
EER and 4.5 EER have been available for some time.
Recently compressors rated from 4.5 EER to 5.5 EER
have become available.J1JI
-Minor electrical components such as the condenser
and evaporator fans are another potential area of
improvement. Currently, low cost, low efficiency
(10%) motors are generally used.1 The potential exists
for using induction motors (30% efficiency) or small
DC motors (65% efficiency). Another possible technpl-
ogy to improve efficiency is Variable-Speed dnve,
which could increase motor efficiency by 10-15%.
LIFE CYCLE DESIGN
At a recent exhibition in Europe a prototype refrigera-
tor named "Green Frost" was demonstrated." The •
entire cabinet, including external structural parts and
insulation, is made of polystyrene. The insulahon is
made from expandable CFC-free polystyrene which is
foamed into the cabinet. The use of a single material in
most of the refrigerator makes recyding not only
possible buf also profitable. Modular design is
-------
u 'rr.er.c'.v Rerr.zerar.or,, a Return to Basics?" Process
g, June \992. ' '•.':' '_'.;•
14 Department or Energy. Chapter 3' in Technical
'Suppcrt Docum^nHDOE/CE-0277), 1989.
15 Feidman, K. Thomas Jr. "Advanced 'insulations for'
Refrigerated Shipping Containers." ASHRAE Journal,
February 1993.
* Jancsurak, Joe. "Tomorrow's Insulation Solution?"
Appliance Manufacturer, Jiine 1992.
r Bare, Jane C. "Simulation Results of Single Refriger-
ants for Use in a Dual-circuit Refrigerator -Freezer." .
Journal of the Air and Waste Management Association, Vol.
42, No.- 2, February 1992. ' .
M Manufacturer's Data, "R-12 Highest Efficiency - ,
Hermetic Refrigeration Compressors. Low Back
Pressure Applications." Cullman> AL: AMERICOLD-
White Consolidated Industries, Inc., 1993.
" "Green Frost: A Recyclable Refrigerator."
Manufacturer, April 1992. • . .
40 U.S Environmental Protection Agency. "Pollution
' Prevention Benefits Manual." Washingto,n,-DC: Office
of Policy, Planning, and Evaluation. Office of Solid
Waste. US EPA, 1989.
41 White, L,M. Becker, and J. Goldstein. "Total Cost
Assessment: Accelerating Industrial Pollution Preven-
tion through Innovative Project Financial Analysis."
Washington, DC: U.S. Environmental Protection
Agency, Office of Pollution Prevention and Toxics; US
EPA,.1992. _ .
roW»m • 24
April 1994 .
-------
REFERENCES
"Refr.zerators: A Comprehensive Guide to'the Big^
White Box" Consumers Report, July 1992, pp. 45^46=.
» Environmental Protection Agency, Multiple Path-
ways to Super-efficient Refrigerators, DRAFT, Febru-
ary 1992. . ' •
s Our Ozone Shield, Reports to the Nation. Boulder,
CO: UCAR Office for Interdisciplinary Earth Studies.
No 2.1992.
4 "Montreal Protocol Revised in Copenhagen."
ASHRAE Journal, February 1993.
« "EPA Proposes CFC/HCFC Recovery Regulations."
ASHRAE Journal, January 1993.
• "Industry Awaits EPA Guidelines on CFCs."
ASHRAE Journal, July 1992.
7 Ziffer, F.E. "Managing Refrigerants in a CFC-free
Era." Plant Engineering, 3 September 1992.
»Zurer, Pamela S. "Industry; Consumers Prepare for
Compliance with Pending CFC Ban." Chemical and
Engineering News, 22 June 1992.
«Personal communication with National Refrigerants,
Inc., Philadelphia, PA.
» McCain, C. "Refrigerant Reclamation Protects HVAC
Equipment Investment." ASHRAE Journal, April 1991.
" Manz, K.W. "How to Handle Multiple Refrigerants
in Recovery and Recycling Equipment" ASHRAE
Journal, April 1991.
" Rowland, F. Sherwood. The CFC Controversy:
Issues and Answers."-ASHRAE Journal, December .
1992.
» Epstein, G.J. and S.P. ManweU. "Environmental
Tradeoffs Between CFCs and Alternative Refriger-
ants." ASHRAE Journal, January 1992.
'«"Industry Backs Bush on CFC-ban Speedup."
Appliance Manufacturer, April 1992.
, 1S CFC Forum, Heating/Piping!Air Conditioning Journal,
January 1992..
'* MacKenzie, Debora. "Cheaper Alternatives for
CFCs." New Scientist, 30 June 1992.
'•" "German Industry Freezes out Green Fndge." N'«-'
Scientist, 22 August 1992. :
"'Kramer, D. "Why Not Propane?" ASHRAE journal,
June 1991.
" Moore, Taylor. "Refrigerants for an Ozone-safe
World." EPRI Journal, July/August 1992. ..
s Federal Register, Rules and Regulations. 17 No-
vember 1989, pp. 47935 - 47938.
n Department of Energy, Environmental Assessment
Document DOE/EA-0372,1988.
22 Federal Register, Rules and Regulations. 24 October
1990, pp. 42845-42848. ' .
a Koelet, P. C Industrial Refrigeration, Principles,
Design, and Applications. New York, NY: MacMillan,
1992.
24 "Refrigeration Systems and Applications," Chapter
8 in ASHRAE Handbook, Inch-Pound Edition. Atlanta,
GA:.American Society of Heating, Refrigerating and
Air-Conditioning Engineers, 1990. f"
a Stone, R. "Warm Reception for Substitute Coolant."
Science, voL 256,3 April 1992.
* Manufacturer's Data, "The Toxicology of KLEA-
134a." Wilmington, DEICI Americas, Inc., 199.3.
* Con, S., T. W. Deklera, and A. L. Savage. "Retrofit-
tirig Large Refrigeration Systems with R-134a."
ASHRAE Journal, February 1993.
» Sanvordepker, K. S. "Durability of R-134a.Com-
pressors: The Role of the Lubricant." ASHRAE
Journal, February 1991.
*»
-------
Section ill:
The Design
INTRODUCTION
-This design addresses two major issues: the'first is the
replacement of R-I2, the refrigerant-that has been used
in ail domestic refrigerators to date, with a refrigerant
that is not ozone depleting. From the literature survey
summarized in the teaching aids, R-134a seems to be
the refrigerant of choice for most of the industry. This,
however, does not and should not preclude the
possibility of choosing other refrigerants since a great
many factors influence this choice. The second issue
this design addresses is energy efficiency. The decid-
ing factors in this issue are insulation, thennodynamic
penormance of the refrigerant, and, the efficiency of the
various power-consuming devices that make up the
refrigerator such as the compressor; and the evapora-
tor and condenser fans. In this study, we will focus on
insulation and on the thennodynamic performance of
the refrigerant. , '
ALTERNATIVE REFRIGERANTS
TO BE CONSIDERED
We will evaluate R-12 as-a base case. R-134a will be
evaluated since it seems to be the leading candidate to
replace R-12. Other refrigerants which pose undesir-
'•able properties that are unrelated to their thennody-
namic performance will also be evaluated. These are
R-290, R-717, and R-l52a. Finally, two patented
azeotropes — AZ-20'and AZ-501 — which are not
intended for the operating range of the domestic
refrigerator will be evaluated to provide insight into
the reasons for their unsuitability.
REFRIGERATION CYCLE COMPONENTS
Figure 1 illustrates the main components of the '-
refrigeration cycle in the refrigerator. Cool gas from
the evaporator (stream 1) which is close to the freezer
temperature is superheated by warm liquid (stream 4),
dose'to ambieftt temperature, from .the condenser.
This superheating is necessary to insure that..no liquid
refrigerant is carried over to the compressor. The
superheated gas (stream 25 pressure is brought up to
the condensing pressure by the compressor. As the
result of compression,'the gas (stream 3) is super-
heated even further. In the condenser,, this gas is first,
desuperheated and 'then condensed to a saturated
liquid (stream 4) by rejecting heat to the outside air.
The saturated liquid goes through the interchanger ••
.' where -it is subcooled (stream 5). The expansion valve
drops the pressure of the liquid to the evaporator
pressure (stream 6). In the evaporator the liquid
evaporates by absorbing heat from the inside of the
refrigerator (the freezer). The saturated refrigerant
(stream 1) leaves the evaporator and repeats the cycle.
Vtlvt
• !•*!*•«•»•
OMMndta ProW«m; 25
, . April 1894
-------
L- Figure 2, ire vapor compression cycle described
a?ove .s shown on an Enthalpy-Pressure Diagram.
Tre cyc.e shown ignores pressure drops due to the
f.cw a: '-he refrigerant through piping and heat
exchangers. It also assumes isentropic (constant
entropy> compression in the compressor. The num-
bered points on the diagram refer to the numbered
streams in Figure 1. Point 1 represents the saturated
vapor leaving the evaporator. This vapor is super-
heated in the interchanger to point 2, thus going from
the saturated vapor temperature at the evaporator
pressure to the temperature given by the constant
temperature line on the diagram. The gas is com-
pressed isentropically along the constant entropy line
up to the condenser pressure. The temperature of this
superheated gas can be found from the constant
temperature line at point 3. The condenser brings the •
temperature of the gas down to the saturation tem-
perature at the condenser pressure. This is the point;
where the upper isobar intersects the saturated vapor
curve. The saturated vapor then condenses at constant
temperature to a saturated liquid at point 4. This
liquid is subcooled in the interchanger from point 4 to
point 5. Since-the heat gained in going from point 1 to
point 2 is the same heat quantity rejected in going from
point 4 to point 5, and since the flow rate is the same
(closed system), the length of the segment from point 1
to point 2 is equal to the length of the segment from
point 4 to point 5. The expansion valve drops the
pressure isenthalpically from point 5 to point 6. Tha
line from point 6 to point 1 represents the enthalpy
increase of the refrigerant in the evaporator as the
saturated liquid is evaporated.
CO
1.
I
.i
2
Q_
Enthalpy, Btu/lb
Figure 2. An Enthalpy-Pressure Diagram illustrating the refrigeration
cycle shown inFigure 1. Isentropic compression and zero piping
pressure drops are assumed.
Op«n-«ndM Problem • 26
April 1994
-------
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Op4n-»nd«l Proelem • 28
• .• April 1994
-------
REFRIGERATION CYCLE
CALCULATIONS
Based on the design conditions given, the evaporator
temperature (T.) will be set at -4°F. This provides a
temperature difference of 9«F between the required •
freezer design temperature of 5°F and the evaporator
temperature. It also allows for operation at the
extreme freezer design temperature of 0«F. The
ambient design temperature is 90'F with the extreme
eoing to 110'F. A condenser temperature CT4) of 115 F
is selected. In the interchanges a superheating of the
saturated vapor (stream 2) of 14°F is assumed. Two
methods to calculate the performance of the cycle for
different refrigerants are used. The first is a graphical
technique which is based on the Enthalpy Pressure
Diagram of a refrigerant (a comprehensive collection of
• diagrams for various refrigerants can be found in the
ASHRAE Handbook1). The second utilizes tables of
saturated refrigerant liquid and vapor properties, and
an expression for the specific heat of the refrigerant.
Both techniques are explained through the sample
calculations in Appendix D.
RESULTS AND DISCUSSION
OF REFRIGERATION
CYCLE CALCULATIONS
Figure 3 combines the cycles of the various refrigerants
on a single diagram. Looking at the different cydes
' two of R-irs virtues immediately become apparent. It
has the lowest compression ratio and operating pres-
sure range of all the refrigerants considered. Note how
R,717, ammonia, operates at the highest pressure range
. "and has the largest compression enthalpy change,
which leads to a high compressor exit temperature.
Table 5 shows various performance criteria for die
candidate refrigerants. The first parameter, the Coeffi-
cient of Performance (COP), is given for therequired
" design conditic^. As can be seen, oiuyR-»Ohas^
equivalent (1%. higher) performance to R-12. R-152a is
. the next highest, with AZ-20 and AZ-50 having the
lowest COP. R-134a's COP is about 7% lower fcan that
of R-12. which translates into a lower energy efficiency.
, • t ' i ' ' '
Table 5- Performance properties of candidate
refrigerants.
Refrigerant
E£
R-12
R-134a
R-290
R-717
R-l52a
AZ-20'
AZ-50
3
2.8
3.03
2.76-
2.95
2.6
2.54 -
45
55
106
448
94
72
44
16.2
13.1
23.4
28.4 '
14.3
40.4 •
25.5
150
140
140
340
169
220
148
Source: ASHRAE Handbook, Inch-Pound' Edition.
Atlanta, GA: American Society of Heating, Refrigerat-
ing and Air-Conditioning Engineers. 1989.
Key: COP - Coefficient of Performance; T '
RE = Refrigeration Effect; RE, x N, = Product of
Volumetric Refrigeration Effect and Volumetric
Efficiency; T,« Compressor Discharge Temperature
The Refrigeration Effect (RE) is the amount of heat
removed by a unit mass of refrigerant. Conversely, it
determines the mass of refrigerant needed to remove a
given quantity of heat. R-717 has the highest RE. It is
ten times that of R-12, which means only one tenth the
-mas$*of R-717 is needed to achieve the same refrigera-
tion effect as that of R-ll' A more important quantity
is the Volumetric Refrigeration Effect (RE,) combined
with the compressor Volumetric Efficiency (NT). .These
two quantities determine the size of the compressor
that should be used. The product of RE,, the refrigera-
tion effect per unit volume, and N,, the ratio of the
actual volume of gas pumped by the compressor to the
compressor displacement, determines the refrigeration
effect a given compressor will produce with different
refrigerants. Thus, the higher RE, x N. is for a given
refrigerant, the smaller the compressor displacement
and the compressor itself will be. Table 5 also_com-
pares the various refrigerants on this basis. AZ-20 has
me highest RE, x N,, 2.5 times that of R-12; thus the
compLor needed would be 40% smaller than that.for
R-12 R-134a would need a compressor with a dis-
placement US times that of R-12. R-290 oritt.Bother
kand would require a compressor that is 70% smaller
than that for R-12. Another factor that needs to be
-------
Table 6. neat transfer parameters for candidate refrigerants -
Refrigerant
Mass flow rate
•(lb/hr)
Internal Heat
Transfer Coeff. (h)
.(BTU/hr-ft2-0!7)
, Overall Heat'7.0
Transfer Coeff. (U)
(BTU/hr-f:2-°F) .-
Temperature
Difference (°F)
Heat flow rate (Q)
(BTU/hr) .
Heat Exchange
Area (ft2)
R-12.
14.96
1456
1496
13.6 .
848
641
1.1
124 '
70.7
35
25
9.0
89.8
805
670
.364
2.58
636
R-134a
12.21
12.21
1221
13.8
845
755
7.4
10.7
25
.25
9.0
9.1.9
817
670
.520
2.61
635
R-290
6.32
632
632
15.4
961
657
3.7
124
;o.7
25
25
9.0
91.4
800
670
.490
246
636
R-717
1.496
1.496
1.496
4.5
572
412 .
• 5.8
12.4
70.6
225- •
'25
9.0
223.9
688
670
280
2.22
7.00^
R-152a
7.1
7.1
9.1
672
487
124
-10.6
54
25
9,0
112.0
78$
670
.360-
242
7.00
Source: ASHRAEfMo* Inch-Pound Edition. Atlanta, GA: American Society of Heating, Refrigerating and
Air-Conditioning Engineers. 1989. .
Key: desuperheater (regular), condenser (bold), and operator (Italics)
ENERGY CONSUMPTION
The energy tonsximptfpn of tKe refrigerator is com^
,.-.,-• - • ;::'«'2£&5Ms . . .. • i
prised of: ' •'. --
". ' ' "^-i:^iis3^PS ;' ' •'
i. the electrical energy input ta the compressor to
drive the refrigeration cyde and remove heat from the
interior of the refrigerator. This heat is gained by
conduction through the walls and gaskets of the
refrigerator, and is also generated internally by the
anti-sweatheater.
2. electrical energy input to the evaporator and
condenser fans, and to. the antj-sv^eat heater.
According .to the 1993 DOE energy efficiency standard
for the size and type of refrigerator under consider-
atibn, the maximum allowable energy consumption is
578.6 KW-hour/year (see Appendix D). To determine
how best to meet this criterion with the insulation
materials available and the chosen candidate refriger-
ants, two useful figures have been prepared. Figure 4
(see Appendix D for calculations) shows the heat gain
of the refrigerator as a function of the fresh food
section insulation thickness f
-------
,-:.-i. -*-*•- :> '•"* — — "essor d;scr.arge rerr.peraF.ire
— ~*Q rue." a Discharge temperature couid degrade
'DC--, --e compressor valves'and _the lubricating oil. As
tr.ese ia:a show, most of the refrigerants'considered
have a reasonable Ty with the exception of R-717 (T, =
34C'F» ar.d to a lesser extent AZ-20 CT3 = 169"F).
REFRIGERATION LOAD .
Using the pull down time of 2 minutes given in the
problem statement, the refrigeration system has to be
able to reject 670 Btu/hour to the ambient air (see
Appendix D). At the extreme design conditions, the
puil down time will increase to 2.7 minutes, which is
acceptable. Based on this load, the mass flow rate of
each refrigerant can be calculated and is directly
proportional to its RE.
HEAT EXCHANGER AREAS
Using the expressions supplied in the problem state-
ment for the internal heat transfer coefficients (h) and
overall heat transfer coefficients (U) of the
desuperheater (desuperheat of the condenser), the
condenser, and the evaporator, the various heat
exchanger areas can be calculated (Appendix D). The
, results are shown in Table 6, in plain type for the
desuperheater. in bold type tor '-".e condenser, ira ..-
italics for the evaporator. The areas for the cor.cer.ser
and the evaporator do not vary much for the difrerer.t
refrigerants. The reason for this is that although the
internal heat transfer coefficients vary, they are ah
order of magnitude higher than the external heat
transfer coefficient, which depends only on the geom-
etry of the exchanger and its fan. The controlling
resistance is on the outside. Additionally, the tempera-
ture driving force and heat load in the evaporator is
the same for all the refrigerants, and the heat load in
the condenser does not vary much. In the
desuperheater, the internal heat transfer coefficients
are of the same order of magnitude as the external heat
transfer coefficient and thus their variation influences
the overall heat transfer coefficient. In the case of R-
717, the internal heat transfer coefficient becomes the
controlling resistance, it is interesting to note that ever
though R-717 has the lowest overall heat transfer .
coefficient and the highest heat transfer load in the
desuperheater, it had the smallest exchanger area
because of the large temperature difference driving
force caused by' the high compressor discharge tem-
perature.
Op«n-«nd«« ProWtm • 29
' Apfil 1994
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Op«n-«nd*d Proo'em -31
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ssatnpt.qi uoiwins.ui
-------
-------
'is shown for tne'different candidate refrigerants.
In the old refrigerator design which uses R-J1 blown ,
urethane foam with an insulation value of R7, the fresh
food s^cnon insulation thickness was 13 inches (1.85
inches for the freezer). From Figure 4, this corre- •
spends » a heat gain of 250 Btu/hour: Adding on the
' 19 5 Btu/hour generated internally by the ana-sweat -
heater gives a total of 269.5 Btu/hour that the refrig-
eration cycle must remove from the interior of the
refrigerator. Using this number and the line for R-12 in.
Figure 5 results in the energy consumption of bur old -
.- design:' 780 KW-hour/year. To meet the 1993 DOE
standard, the energy consumption must be dropped
26%, down to 578 KW-hour/year. If we were sail able
" to use R-12, the total heat the refrigerator is able to
reject using R-12 and the allowable energy consump-
tipn would be 200 Btu/hour (using Figure 6, which •
provides more detail of the lower end of Figure S).
Accounting for the anti-sweat heater (heat gain .
through insulation must be less than 180.5 Btu/hour)
and using Figure 4, we would need a 2.4 inch thick R7
. insulation in the fresh food section (2.9 inches m the
freezer by using Figure 7). If we were to use> R-134a,
we would need an R7 insulation thickness of 3.3 inches
in the fresh food section (3.4 inches in the freezer from
Figure 7). Since R-ll is a CFC, the foam made by using
it will no longer be available. An alternate blowing
agent under consideration is carbon dioxide. -It will,
however, provide a lower insulation value of R6 which
translates to a fresh food section insulation thickness of
3 8 inches and a freezer insulation thickness of 4.5
inches. One can calculate that this change would
reduce the fresh food section by. over one third, and toe
freezer volume by over a half.
These are, therefore, unacceptable and impramcai
insulation thicknesses. In the short term, use must b*
made of HCFC blown foams which are approximately
7% less effective than the CFC blown foams. An
alternative longer term solution would be the use of
vacuum insulation which provides insulating R values
of 20-30 Using an R25 insulator with R-134a would •
require a fresh food insulation thickness of 0.95 inches
(-1 2 inches in the freezer) to meet the 1993 DOE
standard. Using R-290 and the'allowable' energy
consumption dictated by,the, 1993 DOE standard, the
total heat the refrigerator is able to reject to the atmo-
sphere is 207 Btu/hour. Of that load, 193 Btu/hour is
generated by the anti-sweat heater, which leaves a
maximum load of 1875 Btu/hour that the insulation
must handle. Using the carbon dioxide blown foam
(R6), a fresh food insulation thickness of 2.6 inches (3.1
inches in the freezer) needs to.be used.
From the above analysis, .the most energy efficient
CFC-free refrigerator could be' realized by using R-290
and vacuum insulation. Assuming an R25 vacuum
insulation and the original design's fresh food section
insulation of 1.5 inches (1.85 inches for the freezer), the
heat gain through the insulation will be 110 Btu/hour.
The total refrigeration load (including anti-sweat.
heater) is therefore 129.5 Btu/hour. The refrigerator's
energy consumption using R-290 would be 380 Kwatt-
hour/year, 34% less than the 1993 DOE standard. If
regulatory barriers to using R-290 (propane) cannot be
overcome, men R-134a has to be used. WithR-134a,
the energy consumption would go up to 430 Kwatt-
hour/year, 26% less than the 1993 DOE standard. In.
conclusion, the key to an energy efficient refrigerator
which does net-use CFCs lies in developing insulation
.technology, , - .
•-'"?- ' •
REFERENCES
'> "Genetron-AZ-20, Technical Bulletin." Morristown,
NJ: Allied Signal — Fluprocarbons, 1993.
• '•«"C-enetron-AZ-50, Technical Bulletin." Morristown,
NJ: Allied Signal — Fluorocarbons, 1993.
' - • »"Fundamentals," Chapter 17 in ASHRAE Handbook,
Inch-Pound Edition. Atlanta, GA: American Society of
Hearing, Refrigeration and Air-Conditioning Engi-
neers. 198*.
-------
Op«n-*nd«l ProH«m • 36
^^ April 1994
-------
Appendices
APPENDIX A
Manufacturer-supplied information on regulations .
regarding,the phase out of chlorofluoro-carbons and
hydrochlorofiuorocarbons. '.
-------
The Revised Montreal Protocol
Copenhagen, November 1992
IGI Americas Inc.
ProW«
-------
The Revised
Montreal
Protocol
Copenhagen,
November 1992
The Montreal Protocol was reused and cons.uerac,> r.rtr.g....,.--_ ^
meeting .of the United Nations Environment Progranvon ^^ ~ ,
1992. The changes should come into force by January 1 ,994 Some
changes, affect the timetable for controls on the'CFCs. halonl U_ 1 • : - ^•
trichloroethane (methyl chloroform) and carbon tetrachlonde (CTO already .
in the Protocol; these are mandatory for all countries that are already Parties
to the Protocol. Other changes bring in new substances, such £the
hydrochloronuorocarbons (HCFCs), the hydrobromofluorocarbons HBFCs
and methyl bromide. At the meeting,-the Parties also passed an amendment
which limits the areas of application of the HCFCs.
1C welcomes this agreement which greatly strengthens;the London ..
Amendments of 1990. Although there are areas where '^uaTcounmes
should be able to go faster and further than the new timetables, we believe
thTswasthe most 'stringent agreement which could have achieved the support
of all the Parties. •;''•-'
All of these substances are to be phased out completely with.the exception
£ methyl bromide, but the timetables differ. The deuils are given below
t»hlM- dates refer to January 1 'of the year stated; all freezes and
are b^dtn 1986 £* for the CFCs and halons 1989 for (ger
e and 1,1,1-trichloroethane, and 1991 for methyl bromide HCFC
controls begin with, a consumption freeze in 1996. This is known as the
HCFC cap..,
Freeze
-20%
.50%
-75%
-100%
"Original
CFCs"1
*
1994
1996
"Other
CFCs"2
1993
1994
1996
Halons
*
"-' . Methyl
CTC "Chloroform
. 1993
1994
1995
1996
1994
1996
•The frewe for the original CFCs and Haldns is already in force.
' "Original CFCs" are those controlled in the 1987 Motoreal Protocol - CFCs 11, 12,
113, lUand 115 - • . ,
» -Other CFCs" are all fully halogenated I, 2 and 3 carbon CFCs, other, than the five
"original CFCs" . . -
Freeze1
-35%
-90%
-99.5%
.100%
HCFCs*
1996
2004
2010
2015
2020
2030
HBFCs
Methyl
Bromide
1995
1996
The HCFCs comroUed are all of the 1, 2 and 3 carbon compounds containing hydrogen.
chlorine and fluorine. . • - , ._
«poru; "pffoduoion" excludes material used as a feedstock)
f=w«m'39
AdfH 1994
-------
The Revised
Montreal
Protocol
Copenhagen,
November 1992
Destruction Technologies
F,ve diction techniques were approved for nt^uons
allowances may take place (probably not reclaamabte in the LS)
inoneration techniques and no overall minimum Percentage efficiency of
destruction was defined. Basic standards were suggested and a Code of Good.
Housekeeping was adopted.
Definition of Production: Inadvertent Production, etc.
The definition of "production" (i.e., reportable and subject to allowances)
was 'revised to exclude trace impurities generated during manufacture,
remaining after feedstock use or released during manufacturing processes.
Parties art urged to minimize these releases by vanous techniques.
Fluorochemicals
FOR FURTHER INFORMATION, CONTACT:
Dr. P.M. Dugard
ICI America* Inc.
Chemicals and Polymers Group
Fluorochemicals Business
Wilmington, DE 19897
Telephone: (302) 886-4344
l«m • 40
April 199*
-------
U.S. Regulatory Update
1592
The following s a concse overview of the. regulatory
actons IP tr* United States that are impacting me use of
cnoro'iuorbcarbcns (CFCs)', haions, m'etnyf chloroform,
and careen tetracntonde arid their alternatives. For more
detailed informaton, please contact Ou Pont on 1 -800-
441.-9442. ,.". , ; •
THE MONTREAL PROTOCOL
Following several years of negotiations, an international
agreement regulating tne production and use of CFCs,
haions, methyl chloroform, and carbon tetrachloride
entered into force in rrud 1989. Known as true Montreal
Protocol, this landmark agreement initially 'required a
production and consumption freeze. It currently cans for
a stepwis* reduction of CFCs,' haions. methyl chioro-.
form; and careen tetrachloride in developed countries
• that will result m a complete phaseout of production and
consumption by trie year 2000 (2005 for metfiyi cnioro-
form). Developing countries have been given an addi-
tional 10 years to complete the transition to new
technologies. , . •
Parties to the Protocol will be meeting in Copenhagen,
Denmark in November of 1992 ID renegotiate current
agreements. The revised Protocol Will likely result in
accelerated phaseout of CFCs, haions. methyl chloro-
form, and carbon tetrachtoride. 'and include a binding
resolution for HCFC phasabut
The Protocol Is a joint effort of governments, scientists,
industry, and environmental groups. Coordinated by the
United Nations Environment Programme (UNEP), it has
been ratified by about 80 sovereign nations, represent-
ing greater than 90 percent of the world's current CFC
consumption. . .
Trade sanctions will enter into force on January 1,1993
aga'^t those 'non-party* nations, that are not signa-
tories to the Protocol.
CLEAN AIR ACT
On November 15,1990. the new Clean Air Act (CAA)
was signed into law. This legislation includes a section
entitled Stratospheric Ozone Protection (True VI), which
contains extraordinarily comprehensive regulations for
the production and use of Class I compounds (CFCs,
haions. carbon tetrachloride. methyl chloroform), Class
II compounds (HCFCs). and HCFC/HFC substitutes.
These regulations, which will be phased in over the next
several years, will affect every industry that currently
uses chlorinated and Dominated substances that Im-
pact stratospheric ozone.
Tao/e f shows how the CAA has accelerated the phase-
out for Class I compounds in the United States versus
the current Montreal Protocol.
TABLE 1
Phaseout Schedules tor CFC Production
, Fnrtion * 1*8 Protection
1992
1993
1994
1995
1996
1997.
.1998
-1999
Euuw.yu
1110 i
Hortml
1.0
1.0
1.0
0.50
0.50
0.15
0.15
, 0.15
r* 4.45.
posibMue
Mentrul
1.0
1.0
0.25' .
0.25'
0
0
0 .
0
2.50
1MUJ.
Mr Ad. .
' ' O.SO
0.75
0.85
0.50
0.40
0.15
0.15
0.15
155
Eftirati
KEPA '
bfglfttom
0.50
0.50
0.40t
0.25
0
0
. 0
0
• 1.65-
* Rangt of prepoigi twt lwv« tenw tuppert m 0.20 e 0.30
tEPA tvgUabara rmafm** or tuMd 1902 Moor** Protocol.
The major provisions of the CAA include: ,
• Phaseout schedules _ ~
• Mandates for recycling, recovery of refrigerants in
auto air conditioning and stationary refrigeration
equipment
• Banson •nonessentiar products
• Dictates concerning safe alternatives
• Labeling tor containers of and products containing or
made with Class I or Class II compounds.
The regulations of the CAA are stringent but achiev-
able. Support of alternatives and cooperation by all
groups (industry, environmentalists, and regulators) is
necessary to meet these stringent requirements.
PHASEOUT SCHEDULES
The current Clean Air Act Amendments can tor a phase-
out of Class I substances by _January i, 2000. On
February 11.1992, President Bush called for an'accel-
eraton of the phaseout of Class I compounds to year-
end 1995, with limited exemptions for essential uses,
which have not yet been defined.
The EPA must implement this, as well as interim cuts, by
rulemaking. As of this printing, the rulemaking has not
been finalized, the exemptions have not been identified,
and interim cuts have not'been established.
The existing Clean Air Act phaseout and reductions
. (until rulemaking is final) are:
• CFCs and haions (Class l substances) will be phased
out in steps until total phaseout on January 1,2000
(TacVet).
Op«n-«nd«d Probi«m • 41
• Aocil 1994
-------
'- -erac-c-ee C-ass :' will unoergc
s 85 o«'cs'*: o'^on-CFC 'wcsscx use by
ja^-ao1 ' 1"5 ano eta oraseout by January 1.
2000 _ . , . .
• Mery cnioro»orm (Cass I) win undergo stepwise
p^aseout to 50 percent of 1989 levels by January 1,
1996 ano »ta' praseout By January 1, 2002.
• HCFCs (Class I! substances) art regulated as follows:
- Production frwen and use limited to refrigeration
equipment on January 1, 2015.
- Use m new refrigeration equipment s allowed until
January 1,2020.
- Only service of m-place refrigeration equipment-is
mowed after January 1, 2020, and a total HCFC
production ban becomes effective on January 1,
2030.
• EPA can accelerate phaseout schedules tor Class I
and II compounds if they deem it necessary for health
or environmental reasons, rf technology is feasible, or
if required by the Montreal Protocol. •
• EPA may grant (mall and limited exceptions for Class
I and Class II production for a few essential safety,
medical, or national security uses.
RECYCLING
• The ven&ng of CFC and HCFC refrigerants during
service, maintenance, repair, or disposal of appli-
ances and industrial process refrgeration is illegal as
Of July 1,1992.
MOBILE AIR CONDITIONING
• CFC and HCFC refrigerants tor mobile air conditioning
must be captured and recycled by certified personnel
after January 1,1932, There will be a one-year d*ay tor
persons servicing less than 100 ears per year. In
addition, sales of small cans (less than 30 fee) will be
restricted to certified personnel.
• HFCs, for mobjie air conditioning will nave the same
• regulations by November 12..1995.
NONESSENTiAL PRODUCTS
• CFCs will t* banned tor nonessential products, such
as party streamers,'noise horns and noncommercial
cleaning fluids, arid others identified in ruiemaking by
EPA, yet to be confirmed (aerosols, plastic packaging.
possibly hand-new fire extinguishers) by November
15.1992.
• Bans for HCFC use in aerosols and foams will begin
January 1.1994. Some safety and medical aerosol
products and foams used for insulation are exempted.
WARNING LABELS
• Warning labels must be used for Class I 'compounds
(CFCs. hatons, carbon tetracnloride, and methyl chlo-
roform) on all transport containers and all products
containing these substances by May 15,1993. Prod-
ucts made with these substances must also have
warning labels if suitable alternatives exist
aoeis "^st o« used >or HCFCS or.n trans-
port containers oy May IS. 1993 All orocjcs contain-
, mg or made witn these substances ma: hav« suru»«
alternatives must also nave tape's Dy January 1,2015
• Warning labels cannot be a liability defense
SAFE ALTERNATIVES
• The EPA will publish lists of safe alternatives tor Class
I and II substances and enact regulations mat will
maximize the use of safe alternatives m federal agen-
oes beginning November 15,1992.
• 'Alternatives tor Class I and II products .must reduce
nsk to hearth and the environment.
PREEMPTION
• State and local preemption-is very-limited, witn a two
year preemption over laws only governing appliance
design.
CFC/HALQN EXCISE TAXES
Tao/e 2 shows current tax rate tor compounds covered
by the Montreal Protocol.
TABLE 2
Baa* Tut, I/OOP pound, 1990-1992
Year
1990
1991
1992
frev.Ueted
Compounds
1J7
1.37
1.67
NewtyUittd
. Compound*
•1.37
1.37
. Arev.Ueied
Compounds
CFC-11
CFC-12
CFC-113
CFC-114
CFC-115
Haton121l'
Haton1301
Haton2402
OOP
1.0
1.0
O.I
1.0
0.8
3.0
10.0
6.0.
NewtyUMed
. Compounds OOP
Carbon tetrachlond* 1.1 .
Methyl chloroform 0.1
(1.1.mricriloroethaM)
CFC-13 •- - .0
CFC-111 .0
CFC-112 .0
CFC-211 . .0
CFC-212 -0
CFC-213 .0
CFC-2U 1.0
CFC-215 1.0
CFC-216 1.0
CFC-217 1.0
Preewrn -
April 1994
-------
IMPORTED PRODUCTS
'ax. VCCP pound, :1«'3-1W5
.Ail LJ«*d Compounds
EflKsrv*
-0«t«
,1 993
1994 i
1995 i
tO OP pound
3.35
4.35
Chloroform .>
; 2.11
I ' 4.35 -.
i 5.35
1
' •nngg»h*<» ire n r»ui««nfl teams
2 Thar* rt n*«4y ms*«m«o»d ruSuaH rtt» tor irwrfcal
' • wid-fT»»r»% (MOK) Ban a* «• tef »
$1 67OOP pound ter1»3 only B*MSU tor MDtssS1.67/pound
IBM
FLOOR STOCKS TAXES
The Floor Stock fax; which took effect January 1 , 1990,
is imposed on any company that has Class I compounds
for sale or for us* m further manufactunng. The tax rate
is the incremental difference between me tax from tne
previous year to tne current year-, and is applied » year-
end inventory. This tax is applied to amounts of 400 to
(181 kg) or greater per IRS employer identification
number, in many cases, it does not apply to mixtures or
to refrigerant used for service of the owner's systems.
Mixtures must contain me .ingredient as a contributor to
accomplishing the purpose. Exemptions also apply to
rigid fpam insulation, feedstock, recycled CFC$, hatons,
and final products (not for resale) except if the chemicals
are directly emitted.
For funner information, contact the IRS.
HALON AND RIGID FOAM TAXES
Effective January 1 . 1991 , a new tax was imposed on
Haton 1301, and CFC-11 and CFC-12 used for rigid
foam. This tax is assessed at approximately $025 per
pound through 1993. In 1994, normal base taxes apply.
Floor stocks rules apply. New exemption certificates
must be filed, if required. ' •
TO a
IRS list Tfiere are .three ca«ajiicon.m«trc<:s --s*o as
determine the tax rate tor these prsouas actual use
data.. IRS list or one percent of the product's vaiue- A
tie mriimus exemption is' possible tor some products
SUMMARY
The Montreal Protocol, the Clean Air Act. and new CFC/
halo n. taxes will all nave tremendous impact on compa-
nies producing and using these products. Although
some of the regulations may seem stnngem, -they pro-
vide us with ah -achievable plan. •
Du Pont * prepared to support customer efforts in
. meeting these new regulations. Tne Company has dedi-
cated resources to the safe and rapid introduction of
acceptable alternatives to CFC* and to the. retrofit of
existing CFC' equipment for their use. Du Pont has also
initiated recovery,, reclamation, and conservacon pro-
grams to further assist customers in meeting the pcovi- •
s«ns of these new regulations. • • .
•••'•'• TABLfi4 ; .
OeflnWooe:
Oee« I euto«t*nee* art thoM which lignKxarrtfy eauw or
contribute to harming th« ozont tay«r and hcv* tn, Ozon«
D*ptotbn Potential (OOP) greater than, or equal te . 0 2. Th*M
substanc**, which indud* ail som«r«. art Mparatjd ntp fv»
group*: -.'""".
Group T - CFC-11. 12. 113. 1 14. 115
Gioup B - Haten 1211. 1301. 2402
Group III - Other CFCs wkh one. two or thre* oiraon atoms
Group IV i Carbon tetrachtorid* .
Group V - Mtthyl ohteiotefm («c«ptm« 1,t^ »om«r)
Class n aub«ttfteea an the** which ara known, or may be
reasonably antepand. to caus* or centribut* to harmful
•fiecu on the ozon* layer. Th««t lubstancM indud* all
iaomers of HCFCa having on*, two or thr** carton- atoms,
PfOtsiem • 43
Aorii 1994
-------
Ou Pom Ciwnfcais
Cmtoow S*rvte* C«nttr, B-1S305
Wllmlngjon, OE 19898/U.S.A-
(302) 774-2099
Europe
Du Oom dc Nemours
Internavona, S A.
• 2 Che*"!" a> Pavilion
PO Box 50
CH-'218 It Grand-Saconnex
Geneva, Switzerland
• *: -22-717-5111
Canada
Ou Pom Canada, inc '
PO Box 2200. Streetsville
MiuiSMuga. Ontario
'L5M2H3
(416)821-3300
Mexico
Du Pont S.A. de C.V.
Homero 206
Col Chaputtepec Morales
C,P 11570 Mexico. O.F.
52-5-250-8000
South America
Ou Pont do Bresil S.A.
Ajameda lttpicuru.506
Ajphaville 06400 Birueri
Sio PaUo. Brazil
55-11 -421 -8509
Du Pont Argentina S A
Casilla Cprreo 1888
Correo Central
1000 Buenos Aires. Argentina
54-1-3114167
Pacific
Du Ppnt Australia
PO Box 930 ,
North Sydney, MSW 2060
Australia
61-2-923-6165 • . •
Jepen
Mitsui Du Pont Rupfochemicals
Comoany, Ltd.
Mitsm Seimei Buitding-
2-3, 1 •Chome Ohtemechi
Chryoda-
-------
TECHNICAL BULLETIN
lenetroir
134fl
Understanding Needs. Finding Solutions.
IliedSignal
Oo«n-«nd«4 Problem -46 ,
-------
APPENDIX B
Manufacturer supplied information on:
• Thermodynamic data 'for Genetron 134a. .
.Thenhodynamic data for Genetron AZ-20
•Thermodynamic" data for Genetron AZ-50
• .Physical Property data for KLEA 134a
•The toxicology of KLEA 134a
• Lubricants for R-134a ,
• Refrigerator compressors
-------
genetron 134a thdrmodynamic Table'--s
;-~Jifrr
*» •
:*. c.-
984'
99 11
9940
9970
9999
10058
10087
101 17
101 46'
1-01.75
102.04
102.33
102.62
102.91
103.19
103.48
103.76
104.05
104.33
104.62
104.90
1'05.18:
105.46
106.74
106.02
106.29
106.57
106.85
107.12
107.39
107.66
107.93
106.20
106.47
106.74
109.00
109.27
109.53
109.79
110.05
110.31
'110.57
110.82
.111.08
. 111.33
111.58
111.83
112.08
112.32
112.57
112.81
113.05
113.29
113.52
113.76
113.99
"114.22
114.44
114.67
. J-itroer
S. -
3 '. — ' £ ' "
C",59
01-2
3-85
' 0212
'0225
0238
O25'l
0264
0277
.0290
'.03C3 '.
'0316 '
0329
. 0342
0355
0368
-.0381
'0393
.0406
..0419
,0432
,0445
.0458
.0470
.0483
.0496:
.0509
.0521
.0534
.0547'
.0560
.0572
.0585
'.0598
.0610
.0623
0636
.0648
.0661
.0673
0686
.0698
.0711
- .0724
0736
0749
.0761
.0774-
0786
.0799
.0811
0824
.0836
.0849
.0861
.0873
.0886
r^ ' . ^
100 138.83 72713 3368 4423 . 70.66 ' '.-'489 0898
,102 14307 71924 3283 4494 70.17 115,11 - ,0911
-,04 -14742 71632 3181 4S.SS 6968 115.33 .0923
106 15186' 71338 3083 46.37 69.17 115.54 ,.0936
106 ',156.40 71040 2988 4709 68.66 115.75 094«
110 16104' ' 70.740 .2896 * 47.81 68.15 115.96 .,0961 .
112 ' 16579 70436 2807 48.54. 67.83 116.17, ,0973
114 ' 17064' 70.129 2722 4976 67.11 __ 116.37 .0986
116 ! 175.59 69,819 7639 50.00' 66-57 116.57 0998 ,
118 ' 18065 69506 '7559 50.73 66.03; 116.76 .101.1
120 185.82 69.189 7481 51.47 65.49 .116.98 1023
122 ' 19111 68868 7406 5271 64.94 117.15. .1036
124 ' 196JO 68.543 7333 52.96 ' 64.37 117.33 .1048
126. 202.00 68715 7263 53.71 63.80 117,51 ,061
128 207:62 67.882 7195 54.46 63.23 11769 .074
130 21336 67.545 7129 '5572 . 62.64 11786 1066
132 '21922 67.203 7065 55.98: 62;OS . 118.03 ,1099.
134 22519 66.857 7003 56.75 61.44 118.19 .1112
138 231 29 66508 .1942 57.52 .80.83 118.35 .1124
•'3 -wil *«1 .1884 58.30 .6071 "8.51 .1137
' 140 24386 ' 65.789 .1827 59.08 5958 '- 118.86 :11SO
m 25033 - 65.422 .1772 59.86 56.94 118.80' .1162.
' 144 25694 65050 .1719 60.65 5879 118.94 .1175
14«' i 26367 64.671 '..1667 -61.45 57.62 "9.07 .1188
48 27054 64786 .1616 8275 56.94 119.19 . .1201
150 • 27754 - 63896 .1567 63.06 5675 • 11941 .1214
152 284:87 63.498 ,1519 63.87 ' ' 55.55 119.42 .1227
M 291.95 63.090 .1473 64.70 54.88. 11952 .1240
3 299.37 62.676 .1428 8SJ2 54.10 119.68 .1253
-158 30693 62754 .1384 86.36 53.35 1.19.71 .1266
160 31*64 61.823 .1341 6770 52.56 119.78 .1272
genetron-134a Thermodynamic Formulas
r.*213.980*F^«S69.871p^ p. '31.9702 lbVcu.lt T»-1S.OB'F HWl -102.030
Vapor pressure correlated as:
J.
3tii-^C * *"•
2181
•2180
2159 *
2159
2158
2157 '
2156
2156
• 7155
2154
' 7153
7152
7151
7150 :
7150
7149
2148
2147
' 7145
7144
7143
7142
7141 '
2139
'2138
2137
. 7136
2133
7132
7130
7128
In(*L./p»»«) M + 1 + CT + DP-+ (^jrty in '(F-T): T Rankine
* "p ^^ ' i \ / /
A=22.98993635 i»-7243.87672 CHJ.013362956 0«0.692966£-OS £«.1995548 ,f-674.72S14
Liquid density correlated as: ^, . y-x •
T? Te
B,»51 . 1669816 0,»63.89996«7 0.-72.213814 O.M9.3004419
ft »31.9702477
Ideal gas heat capacity correlated a»:
r ' • f* .
Cs(Btu/1b. R) s Ci * Cj+ CjT+CsT**— S;T Rankine :
1 • - • . ^
C,»0.0012S57213 C,»0.000437428«4 C,«-0.1487126£-06 Ci*6.802105688.
Martih-Hou PVT Equation:
• ' ... . . PT . 4- A.-fBit-fde1 ' . .
'• , (""~"^/ («2 ' \V~m°l
'f (psia). » (cu.lt/1b.). 7(R),t,«T/r,
• H«0.10S180 • ,
• 6-0.006535126747
' J... lf«05474999906E»01
2 -4447445323 .002352000740 ' -131.4300642
3 . .08630632505 -.296165168f-04 3.856548532.
, 5 l!l«369059W5 °107907448£^7 - 000313783768
• ;' • ... ... . Apf]l
• 48
1994
-------
genetron* 134a
*"" • i * ™*f* T^* ^ 3f*S I
ger.eiron
™
g compound. ,s the
.era- 3« ~o.ce -o'-ec.ace CFC-12 in numerous air
co: J -on ng ar'c co^ng aooi.cat.ons. It rep,aces CFC-122 m
Siomob.lt «.r cond.t,on,ng. rM.dent.al. comm.rc-l.nd
,nc-ustral refr.gerat.on and m certain centnfugal chiller
of ers the Genetron*
program through .ts Genetron Wholesalers.
contractors and bu.lding owners have a safe.
means o< comply.ng with the Clean Air Act no-ventmg laws
enacted July 1. 1992. For more mformat.on, call your
Geneiron Wholesaler. For the name of the nearest Genetron
Wholesaler, call 1-800-522-6001.
Physical Properties;
cxstm it 1 nm.
l tempentur*
Cnt««l pmsurt. p«« •
Critical 0«n»ity. Ib7eu. ft.
U*|u.d g«. % volum* in air .- N00*
Oiom d«P<«tion pottntial °
Gr»«nhouM warming powntiU (•«timatt> 0,285
2140*F(101.1*C)
589.9
31.97
75.0 -
92.4 '
0.341
Comparatlvt Cycle Performance:
Eviporttor temperature a 20* P
Condenser temperature «110*F
Suction superheat3 30»F
Subcooling * 10* F
Compressor isentropic etticienqr» 00%
genetrw*
Comp'wsof ditchirgt wnptftturt, *F . . .
R*fn9«rtnt circuUtioo ptf ton. IbjTnin. . . .
Compr«**of. displK»m«flt p« ton. dm ...
Uttnt h«at at tvaporator lamp., Btu/lb. . . .
Nat m(ng«fation a«act Btu/lb
12^
21.0
136.4
4.23
188.1
2.90
3.80'
4.51
83.2
66.5
52.7
22 13«a
43.0 18J
226.3 146.4
4.17 4J6
227.0 178J
2.79 3M
2.78 3.00
2.82 4Jt
67.4 n.7
90.6 80
72.0 68.7
Flam, limit* maasurad unng ASTM E-681 with eMMHy ««ivata«J
knch«« match ignition >ourc« pw'ASHRAE Stand«nJ3«.
,'F)
-20
-18
-14
-10
-2
0
2
4
6
8
10
12
14
16
16
24
26
28
30
32
34
36
38
40
42
44
46
50
52
54
56
58
60 .
62
64
66
68
70
3|
76
78
80
62
84
86
88
90
92
94
96
98
.psm
12 95
13.53
14 36 •
15 09
15.87.
16S7
17.51
18.38
19.29
20.23
21.20
22.22
23-27
24.35
2548
26.65'
27.86
29.11
30.41
31.75
33.14
34.57
36.05
37.58
39.16
40.79
42.47
44.21
45.99
47.84
49.74
51.70
53.71
55.79
57.93
80.13
62.39
64.71
67.11
69.57
72.09
74.69
77.36
80.09
82.90
88.79
86.75
91.79
94.90
98.09
101.37
104.73
108.16
111.69
115.30
118.99
122.78
126.65
130.62
134.68
iiO/tt'1 i
86466
96260
36064
85 847
85.639
85.431
85.222
85012
84.801
84.689
84.377
84163
83.949
83.734
83.518
83.301
83.084
82.865
82.645
82.425
82.203
81.980
81.757
81.532
81306
81.079
80.851
80.622
80.392
80.160
79.928
79.694
79.458
79.222
78.984
78.745
78.504
78.262
78.019
77.774
77.527
77.279
77.030"
76.778
76.525
76.271
76.014
75.756
75.496
75.234
74.971
74.705
74.437
. 74.167
73.895
73.621
73.344
73.066
72.7S4
72.500
r,'- Bv
3*174
32SS1
3.1019
2.9574
28209
2.6919
2.5699
2.4646-
2.3464
2.2420 •
2.1440
2.0512
1.9632
1.8797
1.3004
1.7251
1.6536
16856
1.5210
1.4595
1 4010
1.3452
1-2922
1.2416
1.1934
1.1474
1.1035
1.0617
1.0217
9835
.9470
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8788
.8469
.8164
.7871
.7591
.7323
.7086
.6820
.6584
6357
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.5931
.5731
5538
5353
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.4530
4383
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.4108
.3975
.3849
.3728
.3610
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3lv^ u
571
630
688
747
8.06
3.65
9.24
9.83
10.43
11-03
11 83
12.23
12,84
13.44
14.05
14,66
15.27
15.89
16.60
17.12
17.74 •
18.36
18.99
19.61
20.24
20.87
21.50
22.14
22.77
23.41
34.06
24.69
25.34
25.98
26.63
27-28
2793
28.58
2974
29.90 .
30.56
3122
31.88
32.55
3372
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34.56
3574
35.91
36.59
37.27
37.96
38.65
39.33
40.03
40.72
41.42'
42.12
42.82
43.52
33 10
32 81 •
92,52
9220
91 93
91 64
91 34
91 04
90.74
• 9043
90.12
8981
89.49
39.18
88.86' .
38,63
38.21
87,87
8765
8771 ,
36,38.
36.64
86.19
85.85
85.50
86.15
84.79
8443
84.06
-83.71
-83.34 '
82.97
32.59
8272
81.84
81.46
81.07
80.69
80.29
79.89
79.49
79.09
78.69
78.27
7786
77.44
77,02
76.59
76.17
75.73
75.30
7485
74.40
73.96
73.49
73.04
72.57
72.10
71.62
71.15
-------
Al-20
A2-20 Therrn'odynarruc Tabie
A2-2C s a "c."-c23re- *%CB A •
Condcn4tr pmsuni, pciQ * • * 4*vJ
Compressor displacement
Liquid flow per ton.
cu inJmin. 795 73.2
Latent neat at evaporator
Net refrigeration affect,
Btu/lb •..• 74.2 67.8
502 121 M
88.7 106,7 132.9
282.7 345.4 429.7
2.88 2.97 3.01
158.3 143.4 222.8
3.40 3.06 3.41
4.61 5.74 1.92
:i.89 '1.82 1.16
113.6 149.6 60.6
60.8 564 131.3
43.4 3-1.8 104.3
8
10
14
• 16
18
20 .
22
24
26
28
30
32
34
36
38
40
42
44
46
48
50
52
54
56
SB
60
62
'64
68
88
70
72
74
76
78
80
. 82
84
88
88
90
92
94
96
98
42.20
• 44 11
4606
48.13
50.24
52.43 '
54 68
5702
5943
61.91
64,48
67.12
69.85
72.67
75.57
78.56
' 81.64
84.81
88.07
91.43
94.88
98.44
. 102.09
106.85
109.71
113.68
,117.78
121.94
12654
130.65
135.18
139.82
144.59
149.47
154.48
159.62
164.88
. 17058
175.80
181.46
193.19
19957
206.48
211.85
218.35
225.01
231.82
238.78
245.90
253.18
260.61
268.21,
275.98
283.91
- 292.01
308.73
317.38
326.16
•78.00.
'7778
7755
7732
7709 '
76.85
76.62
76.39
76.15
75.91 •
75.67
75.43
75.19
74.94
' 74.70
74.45 -
74.20
73.95 .
73.70
73.44 .
73.19
72.93
72.67 '
72.41
72.15
71.88
' 71.82
7145
71.07
70.80
70.53
7055
69.97
69.68
89.40
89,11
68.82
68.53
6853
67.93
67.83.
6733
6702
86.71
'66.39
66.08
65.75
65.43
65,10
64.77.
64.43
64.09
63.75
, 63.40
63.04
62.68
62.32
61.96
, 61 SI
61.19
1 4sas
. 1 3415
15873
12356 .
1.1864
1..13961
10949
•1.0523
1.0117
0.9729
0.9359
0.9006
0.8668
0.8345 "
0.8037
0.7742
0.7459
0.7189
0.6930
0.6682
0.6445
0.6217
6.5998
0.5789
0.5568
0.5395
• 0.5210 .
0.5032
0.4861
0.4687
0.4539
0.4387
0.4241
0.4101
0.3965
0.3835
0.3710
0.3589
0.3472
0.3360
0.3252
0.3147
0.3046
0.2949
05855
05765 •
0.2677
0.2592 .
0.2510
05431
' 0.2355
0.2281.
0.2209
0.2140
0.2073
0.2008
0.1945
0.1884
634.
696
763 -
8.28
8.33
9,59
10.25
10.91
11.57 .
12.23
12.90
13J7 •
14.25
14.92
15.60
16.28
16.96 .
17.65
18.34
19.03-
19.72
20.42
21.12
21.82
22.53
2354
23.96
24.67
25.39
26.11
26.84.
27.5? -
28.30
29.04
29.78
30.52
3157
32.03
32.79
33.55
34.32
35.09-
35.86
36.65
•37.43
38.22
39.02
3983
40.64
41.46
4257
43.10
43.94
44.78
45.63
, 46.49
47.36
4854
49.12
50.02
3tu/Bi
11475
11431
113.87
113.43
112.98
112^3
122.07
1.11.61
111.15
110.68 .
11050
109:7.1
10953
108.73
10853
107.73
10752
106.71
106.19
105.67
, 105.13
104^9
104.05
103 JO
102.94
10248
101.81
•10153
100.86
1.00.06
99.46
98.86
9854
97.83
97.00
96.83
95.72
95.07
94.41
93.74
93.06
92.38
91.68
90.98,
90.26
89.53
88.79
' 88.04
87.29
86.52
85.73
•84.93
84.13
83.30
82.47
81.61
80.74
79.86
78.96
•U.S. Patent »4,978.467 ••,-..
Azeotrop* consiiling 0« 60% HFC-32 and 40% HFC-125.
Pretiminar/ information based on estimated properties __
Flame limrtt measures using ASTM E-681 wrtft.atectncally activated,
kitcnen match ignition tource per ASHRAE Standard 34.
Oo*n-»na«d Prottwn • SO
April 1994
-------
TECHNICAL BULLETIN
~(Ss
... . ' »&
genefroir
AZ-20
Understanding Needs. Finding Solutions.
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-------
TECHNICAL BULLETIN
Js. ...
genetron
AI-50
Understanding Necda: Finding Solutions.
^IlledSignal
• 52
1904
-------
AZ-50
'-• ,c'-c-e:-a.-9
^TV- = i -=-•--. "--'*--*- a'- -S --irrsag-^at ^ iJ-Ct'OC.C ' .'.V^V.
- r'~-?~ -' --I-':: a-: -^-'-Oa. -mtiaiiy, t "as-- peer . ^
-es ~-ec •; 'er ace =-5C2 r -cw-je^oerata-re conmerr-ai _ja
'efr. ge-aticr acs-caiicrs sucn. as super-narKet freezer and -36'
i.spiay cases ' • ' . ' -32
"Ailie<3Sigr.ai o^ers the Genetro'r* Refnge'rant Reclama- .33 ,
Uon program tr.rough its'Genetron Wholesalers. Now, service -28 '
•contractors and ouiiding owners have a safe, cost-effective \^
means of complying with the Clean Air Act no-venting law .^
eriactec- July 1. 1992. For more iafprmation, call your -20
-Genetron Wholesaler. Fpr the name of the nearest Genetron ^J
Wholesaler, cail,l-800-522-o001. • • ' • - -u
-12
Physicai Properties: "-10,
Clwnical Fomuia • • • t • CHFjCFj/CH^Cfj
Saturated Liquid Density @ 80*F (tb-/cu. It) ... . -64.1
.,__ , -4 *L/mi^j-j-n-«tn*w^ AI A/^lina Point f8/lb) . * > • « 83.7 '
H*34t 0* V«pOniJll(wn ell pw*»i^ rrv»«»» \ww/-» • « • • —^
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Comparative Cycle Performance *
Evaporator temperature -25'F 2
" Condenser temperature: 100*F , 44
Return gas @ 65* F . - 46
Degrees subcooiing: 10*F - " , . 48
Compressor isentropic efficiency. .68%. .- 2
genttroei^4i;,«'-'--S *z-io • soa a •
Evaporator pr«Mur«;pii9i.-i.>.«ti:£(Ss 1U 12,1 7,4
'• ' r'~r- ' ''"" (WB • ' ' 91A 9 IflS 9
Compression ratio '.Y..^.^J5 -M- *•* . 9-52
Compressor discnarfle- ' .-- •
t«mB«f««uf« «F '. 24U . 268.7 352.3 .
r_-Lj«fjgi«nt of oarlmmarrt • , - ' 1.6C 1-67 1.68
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April 1994
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0.19*1
0.1991
0.1990
0.1989
0.196*
0.1967
0.1966
0.1985
0.1965
0.1964
0,1963
0.1962
0.19*1
AZ-50 Thermcdynamic Table ,;>-• -.+*
V»eo» £•
6."rsc»
•a's • s
'00
•02
104
'06
108
110
112
114
116
118
120
122
124
126
128
130
132
134
136
138
140
142
144
146
148
150
152
154
156
158
160
253.27
260 16
26720
27439
281 73
28922
29637
30468
312,65
•320.78
32909
33756
346.21
355.04
36406
373.25
382.64
392.22.
402.00
411,98
422.17
432.56
443.17
45400
465.06
476.33
487,84
499.58
511.58
523.81
536.31
60 41
6001
5961
59 19
58.77
5834
5790
5745
5699
56.52
56.03
5553
55.02
5449
53.94
53.37
52.78
52.17
51,53
50,86
50.15
4940
48.60
47.73
46.80
45.77
44,61
43.26
4162
39.42
35.06
0 1696
0 1643
0 1592
01542
01493
0 1446
0 1400
01355-
0 1311
' 0,1269
0.1227
0.1186
0.1147
0.1106
0.1070
0.1032
0.0996
0.0960
0.0924
0.0689
00654
0.0620
0.0786
0.0751
0.0716
0.0661
0.0644
0.0605
0.0563
0,0511
0.0423
4986
5062
51 40
52.18
52.97
53.77
5459
55.41
56,25-
5710
5797
56.86
59.77
60.69
61,65
62.62
63.63
64.87
65.75
66.87
68.06
6928
70.58
71.96
73.4S
75.07
76.87
78.93
81.40
6469
91.31
5407
S3 4«
5252
52-18
51 53.
5036
50.16
49 45
4872.
4797
4719
46.38
45.55
4469
43.78
42.85
4187
40.84
39.76
38.61
3739
36.10
347.1
33.20
31.55
29.72
27.64
26.22
22-25
18.20
9.93
'0393
!0438
10422
10436
10450
10463
104 75
10436
10497
105:07
105 16
105.24
105.32
105.38
105.43
105.47
106.50
105.51
105.51
105.48
106.44
•105.38
105,29
105.16
105.00
10479
104.51
104.15
103.65
102.89
101.24
0 'C'3
C -02'
0 10*0
0 1054
0'067
,0.1081
0.1095
0.1109
0,1123
0.1137
0,1152'
0-1166
0,1181
01197
0.1212
0.1229
0,1245
0,1262
0.1280
0.1298
0.1317
0,1337
01358
0.1380
0,1404
01429
0.1458
0.1491
0.1530
0.1583
0.168ft..
: '98C
C '9"3
3 19"
0 '976
0 '975
3,1973
01972
0.1971
0,1969
0,1967
0.1966
Q'964
01962
CM 960
0.1956
0.1965
0.1953
0,1960
0.1947
0.1944
0,1940
01937
01933
0.1928
0.1923
0.1917
' 01910
0.1902
0.1892
0.1877
0,1449
AZ-50 Thermodynamic Formulas
r,-160.340*F P. '538.454 p*u p.« 30.5897 Ib7ew.lt. 1»»-50.S48'F MWl-97.146
Experimental vapor pressure correlated as:
** * f t CT + OT» +' £Ii «n(F- T):
AXJ.3222381 1416-02 •«-0.7569295200£-H» C--0.3634a77222g-01'
0«0.2291 7674465-04 £«0 OOOOOOOOOOf-HX F^O.OOOOOOOOOOe-00
Experimental ideal gas heat capacity correlated as:
Cj (Btu/lb. R) * C, * Cjf ••»• C,P + C.-r> 4- CJ/T; r Rankine
e,-0.2728881 1925-01 C,«0.39875624615-(M C,»-0. 12983464525-08
C,'00000000000f-00
Experimental liquid density correlated as:
p (Ib7cu.tt.)
a, «0 5204001 8725-C2 Oj«0.327341 43375^2 O,*-C.21 180578865-02 04«0.22726871 435-02
p, «0.30589877435-«
. P (psia), v (eu.(t/lb.). T (R). 1
f-r/r,.
»*0.110468 ft«0.57993371865-02 K* 0.54749999066 -01
i
, ' 2
4
5
A, ' •<
-0.46639138435-01 0.26193472001-02-
0 202S098294E-OO -0.2053479471 £-03
-O.ii4gs4i44i6-0i 0.0000000000£-00
-0.17263108825-04 0.39791511566-07
C,
-0.1 0849586285-03
•0.35097899506-03 '
Op«n-«n«*d ProBicm < 54
April 1994
-------
TECHNICAL BULLETIN
genetron
®
123
Understanding Needs. Finding Solutions.
^IliedSignal
Apr* 1994
-------
'123
* 123 Thermodyn-amic Taoie
C c." orct-fii.oroet.nane!
•~=>S)r— 3~*,» '23 s a very cw-ozone-depleting corroound
•"-a: se'-.esas a 'ec'acerrent to CFC-1 1 m centrifugal cniilers.
A. °cS -"a. c^ers tre Geretron* Refrigerant Reclamation
;'cg'a"T:rr3i,gn ,ts Genetron Wholesalers. Now, service
corracto^ and Duilding owners have a safe, cost-effective
means'of complying with the Clean Air Act no-venting laws
anacted July 1, 1992. For more information, call your
Genetron vV^oiesaier For the name of the nearest Genetron
//hoiesaler, call 1-800-522-8001.
Physical Properties:
(Cp @ 86'F and 1 Atm. 8/lb *F)
(based on ASHRAE Standard 34 witn matcn ignition)
Comparative Cycle Performance
Evaporator temperature: 35* F
Condenser temperature: 10S*F
Degrees superheat @ evaporator. 0*F
Degrees subcooling: O'F
Compressor isentroptc efficiency. 7-.||jfer .^.. i
gnutra** T*-=* ^.--Z&m:. 11
Compressor dtscnmrg* ''
Refngtrtnt circulation p«r .
Compressor displacement •• '
Uquifl (low per ton. ' • ' •
. • Latent heat « evaporator
temp 8tu/lb '. 78-9 81'°
Net refngeration effect. '
r«mp. >
0
2
4
6
3
10
12
14
16
18
20 .
22
24
26
28
X
32
34
36
38
40
42
.44
46
46
50
52
54
56
58
60
62
64
66
68
70
72
74
76
78
80
82
84
86
88
90
92
• 94 .
96
98
100
.102
104
108
108
110
112
114
118
118 '
120
• ' i
2.00
2 '2
2.25'
2.38
2.52
' 2.66
2,82
2.97
3.14
3.31
3.50
3.69
3.88
4.09
4.31
453
4,77
5.01
5.26
5.53
5.80
6.09.
6.39
6.70
7.02
7.35
7.70
8.06
8.43
8.82
9.22
9.63
10.06
10.51
10.97 •
11.44.
11.94
12.44
12.97
13-52
14.08
14.68
15.28
15.87
16.51
17.17
17.85
18.55
19.27
20.01
20.77
21.58
22.37
23.20
24.08
24.94
25.85
26.78
27.74
28:72.
29.74
(ID.t'1
9771
97 54
9738
9722
9706
96,39
9672
96,56
9639
96,23
96.06
9590
95.73
95.56
95.40
95.23
95.06
94.90
94,73
94,56
94,39
9422
94.05
93.38.
93.71 '
93.54
93.37
93.20
93.03
92.86
92.69
92.31
92.34
92.17
'91.99
91.82
91.S5
91.47
91.30
91.12.
90.94'
90.77
90.59
. 90.41
90.24
90.06
89.68
89.70
89.52
89.34
89.16
88.96
88.79
88.61 '
88.43
3825
88.06
87.88
87.69
87.51
87.32
153382
15,0945
143033
13,5607
12.8634
12-2082
11.5923
11 0131
10.4679
9.9S45
94709
9.0150
8.5451
8.1794
77964 :
= 74347
7.0929
6.7697
6.4639
6.1746
5.9007
5:6412 •
5.3953
5,1622
4,9411
4.7312
4.5320 •
4.3429
4.1631
3.9922
3.8297
3.6752
3.5281
3.3880
3.2546
3.1275
3.0064
2.8906
2.7806
2.6755
2.5751
2.4793
2.3877
2.3002
• 2.2165
2.1366 .
2.0600
1,9668
1.9167
1.8496
1.7853
,1.7237
1.6647
1.6081
1.5538
1.5017
1.4518
1.4038
1.3577
' 1.3135
12710
S, ;si
3. '6
3 Si
900
9.43
9,35
10.27
10.70
11 13
11 56
11,99
12,42
12.35
13.28 '
13.72
14.15
1459
15.03
15.46 '
15.90
16.35
16.79.
1723
1758 '
18.12
18.57
,19.02
19.47 -•
19.92
20.37
20,82
21,28
21.73
22.19
22.64
23.10
23.56
24.02
24.49
24.95
25.41
2588
26.35
26.81
27.28
27.75
28.22
28.70
29.17
29.64
30.12
30.59
31.07
31.55
32.03
32.51
32.99
33.48
33.96
34.45
.34.93 '
35.42
3/S
79 '2
78,97
7334
73.70
78.55
7341
78.26
78.11
7797
7782
7768
7752
7738
77.22
7707
76.92 '
76.77.
76.61
76.45
76 JO
76.13
75.96
75.82
75.85
- 75.49
75J3
75.16
75.00
7483
74.66
7449
74,33
74.16
73.98
73.81
73.63
73.45 •
73^8
73.10
7191
72.74
•72.55
TiST
72.19
•7199
71.81
71.62
.71.43
71 .24
71,05
70.85
70.66
70.46
7027
7006
69:86
69.66
69.46
68-25
April 1994
-------
ftcex
:-_
3 ' tvl
•- J4'
iS '2
sa *c
IS 53
~&33-
39 25
39 54
-3932
90 10
90,39
90.67
90.96
91.24
91.53
91 81
92.10
' 92.38
92.67-
92.96
93.24
'•93,53
93.81
•94.10
9439
9467
9496
95.25
95.53-
95.82
96.11
96.68
96.97
9726
9754
9783
' 98.12
98.40
98.69
98.98
99.26
9955
.99.83
100.12'
100.41
100,98
101.26
101 55
101.83
102.12
102.40
102.69
102.97
103.26
103.54
103.82
104,11
104.39-
104.67
.. .*':
•W
• j;
JC-4
- 2'3
222
23'
- ' :.2ic
32*9
00258
"0.0267
00276 ,
0,0285
00294 •
0.0303
0.03-12-
0 0321 '
00330
,0,0339
00348
0.0356
0.0365
•0.0374
0,0383
0.0392
0.0401
0.0409
,0,0418
0.0427
0,0436
0.0445 '
0,0453
0.0471
0.0479
0.0488
0.0497
0.0505
A f\£* I
O.OS14
0.0523
0.0531
' 0.0540
0.0549
0.0557
0.0566
0.0574
0.0583
• 0.0600
'0.0609
0 0617
0.0626
0.0634
- 0.0643'
0.0651
"0.0659
0.0668
0.0676
0.0685
0.0693
0.0702-
0.0710
. '~ -
: ; ' : •
: • ;• •
Z. ' 3 ' C .
: '909
: -sea
.: '907
0 '90S
0 '904
0 1903 .
0.1903-
0.1902
0.1901
0.1900 - -.
0.1899
0.1899
0.1898
0.1897
, 0.1897
'0.1896
0.1896
0.1895
O.'l895 "
0.1895
0,1894 -
,0.1894
"0.1894,-
. 0.1'894
' .0.1894
0.1893
0.1893
0,1893
01 fiQ.')
. 1 B9O
0.1893.
; 0.1893
0.1893
0.1893"
0.1894
01 flQ4
.1894
0.1894
0.1894 '
0.1894 ,
0.1895
0.1895 . -
0.1895
0.1896
0.1896 -
. n UM7
U. IQV«
0.1807
0..1807
Q.,1800
0.1898
0.1898
0.1899
0.1900
0.1901
0.1901
0.1902
0.1903
•0.1903
. 0.1904
0.1906
r*^ *"^r* ;3t>*fr ?,"!? • 3.*;, "; ^7'
•22 JC '3 3" '3 ' 22C1 .3591 53 :£ ;
•2* 3'"84 J€ 34. 1 '909 3640' 5854
128 ,32.94 36:76 "'1531 36,89 6363
128 3406 36.57 1,1168 3738 68.42
130' 35-21 36,38 1 0818 37,88 '68.20
132 36*0 86.19 .1.0482 - 38.37 67.99
134, 37'61 86.00 10158 38.87 67.78'.,
136' '38.85 85.81 0.9847 - 39.36 87.57
138 ,40.13 85.61 0.9547 39.86 67.35
140 •- 41 44 35.42 0.9257 40.36 -67.12
142 42.78 85.23 0.8979 40.8* 66.90
144. 44,15 85.03 .'. 0.8710 41.36 66.68
146 45.56 34.84 0.8451 • 41.86 66,46 .
148 47,00 84.64 0.8201 42.37 66.23
150 48.47" 84.44 0.7960 42.87 66.01
152 49.98 84.25 0.7728 43.38 85.77 ,
154 51.53 84.06 0.7504 43.88 65.55
156' 53.11 - 83:SS 0.7287 ' 44.39 , 65.32- .
158 54.73 - 83.65 . 0.7078 44.90 65.08
180 56.38 83.45 0.6876 45.41 64.85
• • s •
* - . ** . - .
•54 9€ •:;-•«.
•^•^- : rr
',CS 52 ' - 0 "35
'0530 00743
10608 QC752
10636 OC'SO
10665 '00768'
106.93 0.0777
10721 - 0,0785
107 48 0.0793
1,07.78 -0.0802
108.04 - 0.0810
108.32 - 0.0818
108.60 0.0826
108.88 '0,0835
109.15, 0.0843
109.43 - ' 0.0851
109.71 ' 0.0859
109.98 0.0867
110.26 0.0876
SJ7. .
: -;c5
.C '9C6
C -9C7
C -9C8
0 -908
3 '909-.
0 '9'0'
0.1911
0.1912
0.1913
0.1914
0,1914
-O.<915
0.1916
0.1917
0.1918
0.1919
0.1920
0:1 921
0.1922
genetron* 123 Thermodynamic Formulas
r,*363.200*F F, "533,097 p*i» -p, *34.52S7 Ibycu.tt. T, =82.166
Experimental vapor pressure correlated as:
ln(P,_/psia) =-4 1 j + CT + DP + g (F~T) In
*^ ' /
•F MWl =152.930
(F-7); T Rankine
"
' :- •• . •AaO.aiaSISTaiaf'HDS »»-0.7580945477£*04 ~C=-0.1151736692£-01
Er*Q SS4l98324flf HD6 £*$ 0000000000f*00 ^*0 t*ffjf***f**x}£~fft~
Experimental ideal gas heat capacity correlated as:
CJ (Btu/lb. R) = C, •(• C27 -t- C372 + C473 +
C,=0.3627324125e-01 CV*0.2963321963£-03 C,3-
Experimental liquid density correlated as: .
4
- p(ibycu':ft)=pet2o,(i-rf)
0,«0.5473153(536£-C2 0,-0.6881690823£-02 0,^.92656226'
. pt «0.3452572608£*02
Estimated Martin-Hou coefficients used:
.'.•'•-•- p RT ^ A;+B,T+C,9(~I>
.-•'.- (*-*> * •h . A*-*)'.
. P (p«4«). v (cu.ft./lb.). T (R). Tr ~
*•
Cj/7; 7 Rankina
C.12229656025-06
1/3 '
rOC-02 04=0.6699838557£-02
IT,)
7/7e , '
; «»0.070173 *«0.5778313758£-02 K* 0.5474999905* 01 "
; . * A '
• 2 -0.3461 174842£-<)i ' 0.1482683303e-02
3 0.12710S7059e-00 -0.967S560464£-04
5 -0.77441 98272E-06 0.1325431541£-07 .
, . -; '.'-',
• / - '
-0.637578393S£H32
o!ooooooooooe*oo
,-0.126142800S£-03
'- ' . -,
J 1994
-------
For more information contact your AlliedSignal Ruorcarbon representative.
PRODUCT INFORMATION
AlliedSignal
Fluorocartaons
10T Columbia Road
Morristown, NJ 07962
800-631-S138
CUSTOMER SERVICE
HOW TO ORDER
To place anrorder from
anywhere in the conti-
nenul United States,
Hawaii and the Caribbean:
. Call 800-522-6001
Fax 800-458-9073
Outside these areas:
Call 201 -455-6300
Fax 201^*55-2763
In Canada:
Call 800-553-9749
Fax 800-553-9750
•no nhutf BUI m enMnwd mtneui auarany. vtmrify w ran*
^^S^SE^^-S «• '«»-:»~^2rtro* *
rimr mat mr wen UH « <>»• o< eriflt .Mr«j«.
Undenundinf Ne«d«. Finding Solution!.
^AlliedSignal
Op«v«nMd ProOMH" • 58
, April 1994
-------
RLE A® 134 a
Fact Sheet
KLEA® 134a Is
1,1,1, 2-Tetrafluoroethane CF3CH2F
I34a has been thoroughly tested in a v^de range of toxfcologscal
sudies The results have showrTthat KLEA I34a possesses extreme!; , :o*
oSuv and that it will be.at least as/safe in use as the/matenals that u ,
replaces. ICI recommends an occupational exposure h.mit of lOOOppm as
an 8 hour time- weighted average. For information on the properties and
Ife haSng of KlK 13^ please refer to the Material Safety Data Sheet
supplied with the product or available upon request. Further details of.
toxicity tests, and their results will also be given, if required.
The data presented here represents, a combination of measurements and
estimation ICI Chemicals & Polymers Limited does not guarantee ju
accuracy and reserves the right to update the information m future in the
light of the best available knowledge at the time..
The contents of this note are given in good faith but without any liability
attaching to ICI 'Chemicals & Polymers Limited and u is toe user s
feasibility to satisfy himself that the product -is entirely -suitable for his
purpose. Freedom from rights must not be assumed.
Physical Property Data
For KLEA® 134a*
PROPERTY. •••:-.
Molecular Weight
Boiling Point
Melting Point
Critical Temperature
Critical Pressure
Critical Density
(14.7 psia)
,
Acentric Factor
Trouton's Constant
Density (liquid) ... .. (70 F).
Density (sat vapor) at normal boiling point
Coeff . Vol. Therm. Exp. (liquid) .{40 F • M F)
Specific Heat (liquid) - 70 F)
Specific Heat (ideal gas) ™«c!
Latent Heat Vaporization -(79 f)-
Surface Tension
Thermal Conductivity (liquid) .
Thermal Conductivity (sat vapor)
Vapor Pressure
Viscosity, (liquid)
Viscosity (vapor)
Solubility in Water
(70°F)
(70°F)
(7Q'F)
(70°F)
.(70'F)
(68°F, 14.7 psia)
/UNITS
°F , -r
Of
psia
Ib/cu ft
Btu/lb.R
Ib/cu n
. -Ib/cu tt .
Btu/lb.R •
Btu/lb.R
Btu/lb
Btu/tt.h.R
Btu/n.h.R
psia
Ib/tth .
. lb/ft.n
' % wt
•
• VALUE
-102.03
- '-15.2
• -162 4 ,
2138 '
590 1 i
31.785 ;-
0 3256 '
.0.2098
76.255 !
0,3287 I
0.001605 !
.• 0.336 ',
0.197 '
'- 77.735
4-91 1E-5
" 0.05007
7.737E-03
: 85.43
0.531
0.0335
0.0773
'Properties specified for 99.98 wt % R-134a
Standard States
Enthalpy (-40T, liquid - 0 Btu/lb.)
Entropy (^OT, liquid - 0 Btu/lb.R)
property oflO C>«i«U& Polymer,
-------
The
Toxicology
-« °f
KLEA® 134a
-.; -ec.acs :r.e fu^> natcger.ated CFCs. ^ farr.'.;> of a-terr.au'.es .5 :<•-.§
marketed b> ICI under :he trade name of'KJ_EA»
THE TOXICOLOGY OF
KLEA* 134a
The.first of the new ICI compounds is KLEA* 134a which is a direct
replacement for CFC 12 in its major applications, especially air- .
conditioning and refrigeration. KLEA 134a also has potential as a
replacement for CFC 11 as an insulation foam blowing agent. HFC 134a
contains no chlorine and is thus ozone friendly. ,
The results of an extensive range of toxicity tests on KLEA 134a are now
available. These tests have included a balanced package of whole animal •
and in vitro mutagenicity "tests and acute, sub-chronic (90-day) and
developmental toxicity inhalation studies. The findings have been subjected
to a demanding review both by Id's own team of product safety specialists
and by the Program for Alternative Fluorocarbon Toxicity Testing (PAFTX
an industry consortium of which ICI is a founding member. -The results of
the studies sponsored by PAFT were made public at the International CFC
and Halon Alternatives Conference, Washington, D.C., September 29-
October 1, 1992 Based on the PAFT findings and the evaluation of Id's
own experts, it has been concluded that KLEA 134a displays extremely low
mammalian toxicity. A comparison of the lexicological properties of "CFC 12
and HFC 134a'prepared by PAFT is shpwn in the Appendix. US EPA. as
a preliminary announcement under the Safe Alternative Policy section of
the Clean Air Act Amendments of 1990, have stated that HFC 134a is
acceptable for refrigeration and air-conditioning applications.
Over many years of widespread use, CFC 12 has proven to be outstandingly
safe. Based on the lexicological evidence, KLEA 134a is expected to display
similarly favorable properties.
On the basis of the above analysis, ICI is able to recommend the use of
KLEA 134a in domestic, commercial and industrial refrigeration and
air-conditioning applications and in all non-medical uses currently under
consideration.
Mobile Air-Conditioning
The refrigerant is contained in equipment in the engine compartment, so
that even substantial leakage should not result in significant exposure to the
user in the passenger compartment. .Exposures which might occur would be
similar to those experienced for CFC 12. CFC 12 has a long-established
safety record in mobile air-conditioning and the toxicological data indicate
that this will continue to apply to KLEA I34a.
Refrigeration
For the commercial use of refrigeration equipment, the greatest possible
exposure to KLEA 134a would follow accidental or deliberate damage to the
enclosed system. A single short-lived exposure would occur. The results of
the toxicity tests lead to the expectation that this event would be no more
hazardous for KLEA..l34a than for even the safest refrigerant gas it will '
;;:' replace. "-' ' . .
Op«n~«nd«d Pi
Apr» V99*
-------
The
Toxicology
of
KLEA®134a
KJ_£ A. . 3-a -er.-.ieri.v. ':.-.irze T-e:~g •s.eisec:. -su.-u•-;•:•..i. •• - : - ; ;:-t ~«'
:c -.ne h:gr.esi co'cce;1-able exposure .e'.eis. The sncr.-..'.ec rr.a.x:.— -~ _ .
Concentration u-puid.'be little .or no greater than the le-.eis '.derailed '-> !Cl is
acceptable"tor long-term'occupational.exposures. With minimal ver\t:iation.
atmospheric concentrations would rapidly fall to low levels. • • -
Industrial Handling
During use of KLEA 134a in the process of manufacture of refrigeration or
air-conditioning equipment. IC1 recommends-an'occupational exposure limit
of 1,000 ppm as an eight-hour time-weighted average. This is the highest
exposure, limit set by regulatory authorities for any gas.* ;
Other Applications
The results of the toxicity tests indicate that KLEA 134a is acceptable for
all currently proposed non-medical applications including insulation foam
blowing. At this time, the specialized testing for use of KJLEA 134a in
medical aerosols is continuing. •
Conclusion
KLEA 134a has already been more extensively tested and evaluated than
many other chemicals currently in industrial use,- and it exhibits a very low .
level of toxicological activity. Based upon these favorable toxicblpgical
properties, it is expected that the safety in use of KLEA 134a will equal or
exceed that of GFC 12 which has an excellent record in air-conditioning and
refrigeration. ICTs product safety team, on the basis of-the extensive toxicity
data, recommends the use of KLEA 134a with an occupational exposure
limit of 1,000 ppm as an eight-hour time-weighted average. T •
•Full details for safe handlint of KLEA 134* are described in the Material Safety Data Sheet (MSDS)
supplied with the product. -
OMO trqut Pro««fn • 61
Apr* 1994
-------
The
Toxicology
of
KLEA® 134a
APPENDIX
HFC 134a • Comparison With CFC 12
HFC I34a ( 1 i 1 2-tetrafluoroethane.i is being studied as pan ot the P\FT* I
program sector, which began in December 1987. HFC i34a is similar to
CFC 12 in that it has low chemical reactivity and'a high degree of stability.
Both chemicals are gases. ' .
Boiling Point
' . . CFC 12 -29.8'C
HFC I34a -26.5'C
Acute Toxicity Studies ' ' :
• (short-term exposures to high concentrations, such as accidental
- leakages)
Both HFC I34a and CFC 12 are practically non-toxic by the inhalation
route. The 4-hour LC50 for HFC I34a is greater than 500 000 ppm. and for
CFC 12 it is '760,000 ppm. 'As with other halogenated hydrocarbons CF<_ ,.\2
and HFC I34a can. at high dose levels, sensitize the heart to adrenaline. For
CFC 12, the threshold level for cardiac sensitization is 50,000 ppm. while for
.HFC I34a it is 75,000 ppm:
" Genotoxicity Studies • $.,
(effects on genetic material; an early screen for possible carcinogenic
activity)
Both HFC I34a and CFC 12 are inactive in Ames assays and in in vitro
clastogenicity studies, both with and without metabolic activation. The
genotoxicity of CFC 12 and HFC I34a in vivo has been investigated m both
! rat cytogenetics study and in a mouse dominant lethal test at levels up to
50 000 ppm. Neither compound affected fertility or caused a mutageuc
effect. Recent work has also shown HFC I34a to be negative in an m ww
moSe mSonucleus assay and in a rat.liver unscheduled DNA synthesis
study. Thus, neither material has been shown to represent a significant
genotoxic hazard. .
Sub-Chronic Toxicity Studies . • .
(repeated exposure to determine any overall lexicological effect)
In sutxhronic inhalation toxicity studies, HFC I34a showed no significant
s?ra of Sty even at an exposure level of 50,000 ppm, the highest level
Si In a similar study with CFC 12, no. significant^ of toxicuy were
KraaVan exposure level of 10,000 ppm, also the highest leve tested In
addition, both compounds apparently undergo only minimal levels of
metabolism in rodents.
Developmental Toxicity (Teratology) Studies
' (assessment of the potential for causing birth defects)
Several teratology studies.have been conducted with HFC 134a. No
- Spmentaleffects were seen in inhalation studies ^"^ P
S« or rabbits at levels as high as 300,000 ppm and 40,000 ppm,
respectively CFC 12 has also been shown not to cause developmental effects
' in rats and rabbits at exposure levels up to 50,000 ppm.
Statement Rekued bfy PAFT November 1992 ~
-------
r-9nic i"
Carr-rio^r..--::;.. St.
The
Toxicology
of
KLEA® 134a
HFC I34a did not cause chrome tcxicuv nor-a•carc:ncgen:c.rsspqr.se .r. an
oral «udv when administered to groups of rats tor 1. vear at a uose;^e..ot
orai MUU, _ __ j ^ lifeume Obs«r.'ation. Data from a chrome
uv/w«i^.»«B«nicity study .is currently being evaluated. In this
exposed to levels of up to 50.000 ppm of HFC '134a tor 6
Trtr TV/—— "TVi» in-.lifr nha« of the Studv W3S
lor - yr
and
at 10,000 ppm exposures. The
•6 hourper day for 2 years. Again, no
evidence of carcinogenicity were se«n.
. signs of toxicny and no
program on HFC
is now complete with the exception of
memaustnal refrigeration and air
and fn S o^er currently proposed industrial
recommended normal hygiene prances are
have set an occupational, exposure limit for HFC 1 34a of
Ste^SSieiihted average). Some applications, such as medical
aerosols, will require further testing.
April 1994
-------
The
Toxicology
of
KLEA® 134a
FOR FURTHER INFORMATION,'CONTACT:
Fluorochemicals
ICI America* Inc.
Chemical* ind Polymer* Group
Fluorochemicals Business
Wilmington, DE 198S7
Telephone: (302) 8S6-4344
Op«n-«n•
-------
Tackle today's toughest retrofit with this
J twosome.
W? mate r/i£
We make the lubricant.
We make a system out
of Fofane* 124a.
• Now Elf'Atochem " .
makes sense out of retro-
fits. With the ihnoduction
of its new Planetelf * ACD
lubricants. Elf Atochem
converts'Forane 134a
refrigerant into a gas-
lubricant system adapt-
able to both H\'AC and
automotive use. •
-. The Planetelf ACD
polyolester lubricant is
specifically formulaed
for use with Forane"l34a
in chillers and refriger-
ation systems. Refrigerant
and lubricant together
become one unified
system, backed by the
worldwide capacity of Elf.
prime producer pf both
refrigerants and lubricants.
and the world's largest ,
producer of CFC
•alternatives.
Contact your Forane
wholesaler for more com-
plete details or call Elf
Atochem Customer Service
at 800-245-5858 .(Phila-
delphia. PA) and 800-835-
2916 CWichita. KS). . ;
eifatochem
ZOO
Of Anta Ncrt, Anna. toe. • Fk««ton«»l. -TH* P.tnm
PA 19102
-------
R-134a UPDATE
R-134a Lubrication Needs
Being Addressed by Industry
S.
net R-'.34i a not misobJe wrth the tracS-
sow. sinerai sus used u iubnonu tn R-12
svstems lew .uoncanu ire needed to ensure the
aSoency and Song term reliability of R-134i sys-
tems
* To Beet this need. lubricant suppliers have
Sew txo!onr4 and evaluating several classes of
1 synthetic usr.ca.-iu. format among *ruch are
potyaikaune glycots • PAGsi and poiyn.nun.
Polyafluline Qycols '
PAGs were the first dssi of syntnwe lubri-
cants to be considered for use with R :34a. Ai *
::iss wey snowed acceptable iufanecv nusabilitjr
*tui R-134i and were
commercially ivaiUbie
aunng the any stages of
R-!3-ta product aevewp-
Tvent. As a mauer of fact.
they wen the only chow
available u the automo-
bile industry for sating as
•.Hey developed their 134*
automotive air condition-
ing systems.
Bui according to Jim
Laveile, Alternative
Refrigerants Product
Manager at Elf Auxhein
North America, the
jidustrvs largest pro-
ducer of CFC aitemaom.
several pneral problemi
tiut with PAG*.
j appliance*. Another problem is that PAG* nay
j not be comptoble with residual R-12. other oJcri-
; used materials aad minenj ads. Tha metns that
PAGs couid oot be used u retrofit old tynem*
without deaaing out ail tm*mmf refrigerant
and oil 5m. '.All of which led the loducay » «• '
plore the i
The PAGi wUI
waur to quite high levels.
which can !ead to chemi-
cal breakdown made the
rethgeracon synem, This
is especi., a problem in linririnni where tht •
product is expected to IMC m«y jtm. sxh M m
Polyoiester Lubneaoa
Cxers sotve the problemi of PAG*.' They are
a different family of synthetic hibnonts. hereto-
fore used successfully u avisbon iubnonts...
Uvelle reports that Elf Auxhem. through its as-
ter eompuy, SI Lubneants. Kts dooe enensnc
testing of a pdyofota- lu-
bricant (at use with * '
R-134*. and that result* '
are very positive.. The Elf'
Atochem polyoiester lubn-
ant (which is being mar-
keted under the irand
name Baneielf ,>.CO)
offers a aohition to rJ»
problem of water abtorp-
bon aad chlorine compat-
ibility. LraUe says it ex-
hibits excellent chemical
^ability, good misability
with R-l&U. aad outstand-
ing lubncanng qualities.
In addition tat Plaaeuif
ACD polyoiejter lubmot
is compatible with most
mattnals ustd in I'efhgiii*
oon systems, and inhibas
W4WOO tht various parts
nstdt tht compressor.
In marketing Raneteif
ACD lubricants. ElfAto-
ehsa wiB target then ftr use in bread R-134a
reftgenocn/air eonditianinf appdcsoons in both
Results of PAFT Tbxidty Tests on R-134a Released
The Program lor Alternative Fluonxarbon
Toncty Testing > PAFTi noti&d tht EPA
on September 10.1992 of results from tht
Jong-urn tcucclccy testing of HFC 134*. Tht •
news is good. The tests confirmed the. low tabcty
of HFC 134a as a CFCalunaavc.
In virtually all studies on HFC 134a there
were no effects as a result of exposure to tht
. refrigerant. The only ucepoon was in the life-
time study whereat an otremthr high opoatst
level (50 ante current 1*^1^*™*"! exposure lio-
ns far HFC 134ai there was an increase in btnifn
tesoealar tumors m rats. This was seen at tht
very end of the study aad there was no effect on
lift expectancy. No such eflect was observed at
lower exposure levels. The URs apesar to iadi- •
catc that then are no neftnve ugpUcations u tht
use of HFC 134a in domejoc. cnmmernaj aad in-
duscnal refrtgenooh
An Understanding of
•R-134a Behavior-With
Refrigeration Oils
Rifngenooa rystenis contain iTuxwrti •' ai
'and relrigerinL The separation :mc *i
layen depends an several factors: cemoera' _•»
chemical nature a" the oil and refrigerant.....
relative eoocenmaon of the two eomponer*..
Geiarsfly. a domesoc refrigeration IT: . -a>
mccv« air eoodiooning. complete muaoiii'.
bet*«a oil and refrigerant is required tor '•
proving the ream of aJ to the compressor : >j^
the fiinrnnning of the installation: «voKtuu ^ru-
muianon of viscous oU in low temperature artt a
the msuJlaonn levaporator. expansion' vuve • -
and avoading <^jirf of asaiUry aibes.
The foUowmg chart summaries the ber-avior
of HFC 1JU with oils. HFC 134* demonstntes
very'poor'muobuity with the trtditwnal TOnerii
or lynthetx ous but aemonstrates excellent miso-
bdity with both PAG and poiyoiexter ous.
I" '.. : ' HfCl34a ;
Naprtftau Mreral Ois
Parafruc Mrwa Ofe
AJcyterasre Syntiett Ofe
Ois
Quart Packaging Avoids
Waste, Saves Costs
I I sen of ester lubncanu in R-l34a systems
\J lit finding that unused lubricant m opened
1-falloo containers becomes contaminated
quickly, as it absorbs water and mouture-bome
comamininu to the pouit where it cannot be
used. This has proven costly as well as waste/ul.;
Elf Audiem a packaging its PUneteif AGO re-
frigeraooa lubricants in 1-quart containers, and
marktosf *fadts a/ these quirts in 1-gallon car-
tons. Us* of the quart, where a quart, or iess. of
the-luoncant is required, prmrvu the integncy
of tht mnandtf of tht gallon, and nmfc** for a
more effiaeat purchase.
eiFatochem
ATO
Op«n-«nd*d ProBMm • 66
'- , Apf»'1Sf94
-------
^
V. *-•
f
f
An Introduction To
EMKAMTERL
Refrigeration Lubricants
Chemicals & Polymers
-------
Meeting
Tie Need
7;e y.:.r.:e=. Prrccc! his se; ome sca.es :cr ±s pease-cut :f CFCs. iCI has piavec ill Td
rcrir.e :c p;av a ieaang role in assisting the refrigeration and air-ccndiucs^g- _zd ^tnes
~ '-e n-a^s;:;cc to alternative refrigerants: .
As a result of Lois commitment, ICI has developed its range of Liikarate* RL refrigeration
iuir.cazts for use with CFC alternatives. Designed specifically to meet the rigorous perfor-
mance demands of the refrigeration industry, Einkarate RL refrigeration lubricants have
evolved with over five years of intimate collaborative research with mapr refrigeration •.
compressor and system manufacturers around the world.
ICI offers the global refrigeration industry world-scale production and distribution- of ap-
proved refrigerants, and lubricants fully complemented by a worldwide technical resource.
Ongoing research and technical service activities are supported regionally by dedicated
facilities in Europe, the United States and Japan. •
All experimental data contained in this literature'has been generated for Emkarate RL re-'
fngeration lubricants in combination with KLEA" 134a, the first commercially available alter-
native refrigerant intended as a replacement for CFC 12. Similar physical and performance
data will be generated for other alternative refrigerants as they become available.
ICI is fully committed and will continue to meet the needs of the refrigeration industry in
order to facilitate the transition from CFCs.
Typical Properties of Emkarate RL Refrigeration Lubricants v ;;-
Appncatioo Gade; -r
0 «rc o l
'
Qtrc
(CDC)
*/*
TMl
nnr
iu
>m -o
Q.1SS
taaam
IU
>• -M
u an
114
un
iw
>•
B.VS
Eabnt
m»
iu
un
n
>• 4
III
un
>• 4
EMI
iti
18
BUT*
UM
• E.13JI
IU
•41
m
B.DDH
Wiur cscmi d Emanit U. trinqviuot Umn I trpaflT •• Ou
It n23V T« araodi m Aim
Proa»m • €8
April 1994
-------
.. .
Vnergy :c^-^-?:icn aMcw* temperatures, maxuiises '.ubr.caticc a; elevated
and IB .some :ases enables users ro choose a lubncast of a lower .30 grafle.
Vucwity C«Bipaniot
Mineral Oil vs tmkarate RL Refrigeration Lubricants
40
60 80
TUBftllllllt •
100
Retrofit ^
Retrofitting
involve sgaificaiirdiia?t
HFC434a the system maaiwrt^sB|^
to most ^ however; i retrc^to »I34aiiffl^
aaure proper oil transport, stability, hibricatiott and heat transfer, Pjrformaiice. ^karate RL -
SXubrShave undergone significant laboratory ^eidreffi^c°K
many of the world's leading refrigeration system manufacturers. As a resul pf this.
Sence, Emkarate ft synthetic esters have ^^^S^nts :
and [performance characteristics in a wide array of systems. Additionally. ICI has
?a Se^of'guidelines for retrofitting to HFC-l34a, mcluding detailed lubn-
cast flushing procedures.
If you would like more information on converting your CTC- 12- system. to HFC-134a. contact
IQ or Vuginia PIP at tht locations shown overleaf.
Oo«n «na«d PntMtn • 69
April t994
-------
izxir-e *L reL—era-c: .uir.caz'J =av oe "dere
'
fr:z: izy :ce cf '.CI s S«.e=
^a,_- ^.— — ..-,.- .— TJ aisc oe happy to assist
Customer SeiTice and ;•!=:"rusr^recarcluig.iese products. Special technical ass:istance ^ aisc
-::: '.ocaecarcuia tie wcr:a The ;ocai o£:e
~
Distribution E=
RL refrigeration lubncaats can be supplied in road tank, wagons or scn-retumarie
2GC k'~ net mild' steel drums. Smaller volumes are available from Id's authorized distributor
of L-akarate RL refrigeration lubncants, Virginia KMP. . .
[CI continues to develop lubncants for use .with alternative refrigerants and to meet ie
needs of the refrigeration industry. For information on these products, please contact ycur *
local Sales Office in the first instance.
^^•—^ Eakarate RL refrigeration lubricants are not classed as hazardous under international ^rans-
port regulations, Le.. UN, MO. RID, 'ADR and ICAO/IATA.
Classification - • , •
Emkarate RL refrigeration lubricants have high flash points. They are expected to-have a
very low systemic toxicity. Nevertheless, good industrial practices should be >osed waen han-
and Storage dling these oroducts. There should be good ventilation' of working areas, and contact with
the skin and eyes should be avoided by the use of protective gloves and goggles.
Any splashes in the eye(s) should be removed by washing with plenty of water; splashes on
the skin should be removed by washing with soap and water.
Emkarate RL refrigeration lubricants are hygroscopic and suitable precautions should^*
taken to prevent moisture absorption from the air.
Emkarate RL refrigeration lubricants may be stored in mild steel tanks or drums.
If this material is redistributed or reformulated for sale, details of the methods for safe han-
dling should be passed to all customers.
Information on toxicqlogy,
dated by Id This, infon
products and separately
'Eaqniries 'should b« dir'i
ICI Sales Offices
nmentat matters and safety in handling is continually up-
provided: iff Material .Safety Data- Sheets supplied with, the
for their own purposes..
1C! AfMrieu Inc.
(H«M Otfic«) W
OE 19897 USA
T«: (3021 886-3000
TMx: 4945649 IO Ul
Ftx: (302) 886-2972
.T«»: i«on
TMK 587461
Fix: (0642) 432444
Distributed by
Virginii KMP Co»p.
F«x: 1-80M77-8567
Virginia Refrigeration Ltd.
I2f8i*cttrtara Road
Soutnsu
Portsmouth
Hants POS 4NL UK
England
Trf 0705 756368
Ftx: 0706 294349
Virginia/KMP
-------
PQLYOL ESTER REFRIGERATION OIL
. - 'THE P R £ F E R R E D L U B, R I C A N T F O.R , C FC . , .; '.' ..
• -. •' HCFC'and HFC R E F R I G E R' A N. f • '
"••- • ••>•• A P P L ic AT--I.O.N s . •.••..-,
Mil!
• 71
Apr* 1994
-------
*n;cn provide
'.o
«A:on'itV=a.-~3f!heMoo.lEAL
^Esv'rsr.meria. Apartness Labncants)
firmly specifically aeveioped :o
Ibonc'ate -efngeration compressors and
system components *here HFCs are
used HFCs are ozone-fnendly. chiqnne-
free. non-CFC refrigerants *hich are
replacing CFCs in the world
refrigeration market. The performance
of Mobil EAL .Arctic 22 has been well
documented with HFCs in refrigeration
systems. It exhibits the desired
miscibihty at cntical temperatures, low
viscosity loss, as well as stability for
long system-life.
Mobil EAL Arctic 22 has also been
found to be completely compatible with
CFC refngerants as well as the new
Mobil
HCFC interim "blends." This allows the
lubncant to be used with virtually any
traditional refrigerant. This "backward
compatibility" and the superior lubricity
of Mobil EAL Arctic 22 makes it the
preferred lubncant for most applications.
Typical Characteristics
Physical characteristics listed in the
table below, are typical and may vary
slightly.
Advantages
Mobil EAL Arctic 22 will provide the
following benefits:
• Long lubncant life
• Outstanding prcter.von iga:ri;
compressor ••'•ear
• Higii system efficiency
• Excellent low-temperature fluidity
• .Excellent high-temperature stability
Health and Safety
Based on available lexicological
information, these products produce rvo
adverse -f-'ects on health *hen properly
handled ild used. No special precau-
tions art suggested beyond attention to
good personal hygiene, including laun-
denng oil-soaked clothing and washing
skin-contact areas with soap and water.
Matenal Safety Data Bulletins'are
available from Copeland Corporation by
calling l-513-*98-35S8.
• ASTM D 4172,20k| /1200 rpm /
60*C /1 h*. scir. di*., mm
• Copper Corrosion, ASTM D 130.24 hr
at lOO'C (212'F)
• Color. ASTM D 1500
• Water Content, ppm
0.72
1A
0.5
<100
1675 W?8p!ipbeU Rc«d_. Sidney. Ohio 45M5-066?
Op«ri-«no»a Prooicm • 72
April '9**
393-06
luutd !•*} C '°°'1 Cooe!iml.Con9on
-------
Castmi..
51V
Op«fi
A'flf* 1994
-------
Castroi have supplied compressor luoncants to the
refrigeration industry since the 1940's. The original
products, for use with ammonia and carbon dioxide
refrigerant gases, were mineral oils. With the advent of
chlorofluorocartons (CFC) refrigerants in the late 1940's,
naphthenic crude oils of low wax content were used to yield
low floe point oils. As compressor design evolved, increasing
the demands on the lubricant with higher discharge
temperatures and speeds, new synthetic lubricants were
introduced to the market place. During the 1970's Castroi
' introduced aikyi benzene and, in the 1980's, poryalphaolefin
lubricants into their product range under the Icematic
branding. ,
Since trie advent of new non-ozone depleting
hydroflubrocarbon (HFC) refrigerants, which are not
compatible with normal oils, Castrol's chemists and
engineers have been working to develop a new series of
HFC miscible lubricants. The development thrust has been in
close cooperation with leading compressor manufacturers
and refrigerant gas suppliers, primarily using the first
commercialised nonnaone <
Castroi are ideally placed to^orttrwfi
refrigeration industry. Castroi companies are located in
•39 countries worldwide and a distribution network is
in place in a further 100 counfries.
-------
• The Requirements for New Compressor Lubricants
Conventional compressor lubricants'are misciple wrtn.CFC and
.hyorocniprofluorocarton (HCFQ refrigerants but are immiscible
wrtfi tne non-ozone depleting HFC.alternatives. Use of a
coriventjona! immiscible lubricant in conjunction wrth HFC Rl34a
adversely affects the efficiency of the refrigeration unit Oil plugs
separate from the liquefied refrigerantwithin the condenser of the
system, impeding the flow and causing .spluttering as they pass
through the restrictor (capillary tube or expansion valve) into the
evaporator Once transferred to the evaporator of the system, the
immiscible oil settles at the bottom of the tubes causing further
impedance to the gas flow and reducing heat transfer efficiency.
In a severe case, lack of oil return to the compressor can promote
component wear and eventual failure through lubricant starvation.
ACT* '99*
-------
Product Technology
">e Castrol icematic SW senes of luDncants is based'on synthetic
poiyoi esters and formulated with additives. The poiyoi ester base
stocks are new components which have been specifically
synthesised by Castrol for the purpose of. compressor lubrication
in conjunction with HFC refrigerants. Poiyoi ester based lubricants
are the most stable wrttim the diverse ester family of products.
Aviation Gas Turbine Lubrication is one of the most severe
applications that any lubricant must endure. The poiyoi ester
based lubricants have to withstand fie temperature range of
below -40°C to above +25Q°C where all mineral oils and many
synthetic products would fail.
Castrol is a major supplier of synthetic aviation lubricants and has
drawn on this experience in developing the Castro* Icematic SW
range.
The Use of Additives
Castrol have formulated a tow treat ashless and highly effective
additive package into the icematic SW product range to provide
important performance benefits over non-formulated products.
These benefits include:
• No copper plating of compressor components
• Increased hydroiytic stability
• Reduced compressor wear
Typical Physical Properties and Compressor
Applications
Castrol Icematic SW refrigeration lubricants have excellent
physical properties. The viscosity index (the relationship between
the lubricant's viscosity at 40°C and 1008Q is typically above
100 which is significant^ higher than conventional naphthenic
mineral oils which are usually less than 20. This means that the
Op«n-*nM4 Pmowm • 76
Ayu '994
-------
ce'^aac SW -ubncants are thinner at !ow temperatures, reducing
compressor power consumption and improving oil return from me
evaporator,' Conversely, at nign operating temperatures tney
retain meir viscosity Better than naphfhemc oils, providing a t
strong boundary film lubrication to-ttie compressor, even under
the most arduous temperatures experienced during high ambient
temperature conditions. The lubricants have similar pour points
and considerably higher flash .points tfian comparable viscosity
naphtfiehic oils. •. '
I^MI^^^^^^^^^^^^^^^^^^ ! CASTHOLICEMATIC 1
1 • " METHOD s»i« swzz sum swa swim swiso swzzo |
TKT »«uu
lOnemaoe /scosrty. *0°C ieSO
. (OnematJcVscosity. 'OO-ClcSO
Cteefl Fiasn.Point l°Cl
Total ica numBer :mqKOH/g)
Kyflroiyt numoer imgi.- .
.
••
-•-^wl^^
, . ---^^^^"^i^prtGasc,; ^p^si^lF,,-,-,
ia^^its utilise new polyot ester basesttxjwfci''
„«, ,„„ ^.rSffiitty synthesised to provide excellent
miscibility with HFG R134a over a wide temperature range, ine
Ststew been tested >w^ many refrigerant gases andlound
.tobe miscittewrth most CFC, HCFC and HFC R134a.
-------
~~e ewer c.Tticaj solution temoerapjre .tre point-acove ivncn ail
sroooftons of oil and refrigerant are misciDiei for icemanc SW
'products witn HFC Rl34a are comparacie to, and in many cases
Setter man, rtaprrtfienic oils witii CFC R12.
HHFRIGEHWIT
icamaticSWlO
Icemanc SW 32
icamaticSWea
fcmatJcSWiOO
fcsmjflcSWISO
teemafle SW 220
UWER CRITICAL SOLUIHUI TEMPERATURE fC)
H12 RSB IBZ I
ORE CFC/HCFC HCFC
<-50
<-50
<-50
<-50
<-50
<-so
<-50
<-50
<-50
<-50
<-50
<-SO
<-SO
<-50.
<-50
<-SO
<-50
i-50
<-50
<-SQ
<-50
<-50
-39
<-50
-40
-33
•28
-22
<-SO
<-50
<-50
<-SO
rxjtJurtatte.fortterifn^efantwtiw used m
swaton due to floe formation afiove me miscibtlrty temptratw rt me oS «1
ntngennt nnxtun. ' • • . ,
CutnX Icanutic SW
% fcacnatfc SW in HFC 134a (w/w)
Op«n-«nd«d Pronwn • 78
, Aprl 1904
-------
•ea'.sc :o 95 :G ar.c :'-c;:ec ivT ;r/ger 30c: Tiini.'
-------
Thermal Stability _' .
7Ke Asnrae 97 sealed tube stacility test was developed to assess
ye trerrai stability of-refrigerant gas. The refrigeration industry
has adopted the test in a modified form to assess the stability of
ludncants wrtJi tfie new HFC refrigerants. Castrol icematic SW
lubricants have been extensively screened in this test in which
metal specimens typical of compressor construction have been
introduced, both in-house and'by compressor manufacturers. The
metal specimens suffer no degradation after the 2 week test at
1753C, in conjunction with a variety of refrigerants. The lubricant
retained its original colour and acidity levels at or slightly below,
that of the unused oil.
•Ashrae 97 Sealed Tube Stability Test 175°C/14 Day*
KTAL SFEC1MEN CONDITIOHI
CASTHOL ICEMATIC HBTnCHWMT Copper Sterf Uunmtum
SW68
SW68
'SW68
'HTCR1344
CFCR12
HCFCR22'
Sngm
Bnflffl
Bngm-
Bngm
Sngflt
Bngftt
dew
Ctafl
Clean
Hydroiytic Stability
The hydrolytic stability of any ester based lubricant is essential for
the long term durability of the refrigeration system! pardcularty as
relatively high water levels can be present within the working
unit"
The Icematic SW lubricants have been subjected to the TOST
thermal and oxidative stability test where an oil/water emulsion is
20) 300 400 500 600 TOO • MO 900 1,000
Hydrolylic Stability
tt Cattrol l
SW I
TOST ASTM 0943
100
Pnsewm • 80
April '994
-------
Pet Insulation Compatibility
PET insulation material « used in insulating me'motor winding of
compressors and is' in contact with bo%tlie;refngerant gas and
luoncant Tests have shown that, the Castrol toematic SYV^ ^
lubricants perform similarly to naphthente oils on PET elasticity
and tensile strength HFC R134a can reduce me elasticrty of PET
,nsuiation, The manufacturers are developing low oligomer
content variants to minimise this effect
TESTOIUBEFBIGEHAHT
(conditions: HlVlOOaiHniis)
, CFC12
HFC134I
Icematic SW 22
kamaticSW.22*HFC134a
SOVG32NaoMm»co»
145
138
"ia"
139
139
~^~—~
143
43.0
53.5
53.7
47.0
H^^B^^
51J
Wear Tests ;
Chlorinated additives have for many years been used toj provide
reduced wear on internal working components. Similarly,
chlorinated refrigerants have provided ^
properties in refrigeration compressors.
chlorine in nofl^one depletinfl
HFC refrigerants are indeed
thinning the lubricant whilst providing no wear protection.
The Castrol teematfc SW lubricants, tnante to their balanced
formulation of additives and base stock,
successfully
Irfe tests and in
the field.
-------
Falex • Rotating Pin on Loaded Vee Slocks
TEST OB. mrusnum SBZUHEUMO wan
m »-,««»(-,»
ISO vG 1 00 naonmcnic
Non-formulated ester
fcematx: SW 68
SOVG lOOnacWfwroc
Non- formulated esor
fcemancSW68
Non-formulated esw
lc«TWJcSW68
None
None
None
CFCR12
CFCR12
CFCR12
HPCR1344
HFCR1344
750
1,150
1,800 ',
900
1.400
2.300
1,500
2.400
30
16
2
6
4
<1
36
<1
FZG gear test results have been generated for centrifugal
compressor manufacturers where the gear box can share the
same lubricant as-the compressor.
FZG Gear Test Results
TEST OIL HULURE LOAD STAGE
tcematic SW 32
tematJcSW68
10-
. 12 •• .
Elastomers
Elastomer compatibility of the lubricant and refrigerant is critical
for open compressor systems. The shaft seal '0' ring should sweH
slightly under the effect of lubricant and refrigerant to ensure an
effective seal against the positive pressure within the compressor.
Should the seal suffer excessive shrinkage or swelling, leakage
will occur and the refrigerant charge will be lost from .the system.
Castrol recommends that only compressors fitted with Nitrite
Butadiene (NBR), Hydrogenated Nitrite Butadiene (HNBR) or
Neoprene rubbers be used with HFC R134a and toematicSW
lubricants. This is particularly important when converting an
existing CFC or HCFC system to HKfWl 34a, to ensure that the
shaft seal is compatible. If it is not a new one must be fitted.
Conversion of Existing CFC Refrigeration Plant to HFC
Refrigerants
With the impending phase out of CFC refrigerants, users have only
two options to adopt longer term alternative refrigerants:
1) Switch to HCFC R22 • ' ' '
2) Convert existing equipment to HFC refrigerants
Op«v«nd
-------
. T>ie
-------
tcemjoc SW ubrtcantt
Procadun"
Through repeat oil changes with Castro! Icematic SW J
mS oil contamination h reduced »J*JSS2SI
below >%. Residual mineral oil within the system will adjwjy
aflSuntt efficiency as miscibiiity of the oil modimnd R13tt at
low temperatures is reduced con^rnlingry accofd.ng to the
level of contamination. The Castrol Icematic SW senes has
excellent tow temperature miscibiiity with R134a and can
Se toTerateThigher tevel of contamination than competrtor
lubricants.
Cattrol ta«matic SW
SB
Miscibiltty of IctJiutte SW/
Naphttwnic mtoui« «W»
B134*
(10% Oil ta H134«)
Miscible Region
I"'
I'
•9
•30
-«
•SO
knmiscibfe Regiofi
Castrol teematic SW products have been
and have proved to be yiy compatible wrth
-------
c-ionnated refrigerants and solvents. No cooper piating problems
have oeen experienced with Castrol Icematic SW. We therefore ',
have no need to advise maximum-level, of contamination from
chlorinated residues. Indeed/systems can undergo me oil
changes now, as a preparation for conversion, and run with the
original R12 until such time as R134a becomes readily available
and similarly priced. This is expected to be in 1995.
Toxicity
The Castrol Icematic SW lubricants are listed on E1NECS and TSCA
registers and classified as being of no significant hazard. The
products are despatched with a Material Safety Data Sheet (MSOS),
which provides information on handling and what to do in case of
spillage.
Castrol Customer Service :
Castrol IcematJc SW lubricants can be ordered from any Castrol
company throughout the world. Representatives from your local
Castrol company will be happy to provide advice and assistance
relating to the Icematic SW series of refrigeration lubricants.
Castro* companies offer a full support package to customers,
including technical assistance and routine returned oil analysis.
Castrol is committed to serving the refrigeration industry with
the highest quality compfesspr lubricants in order to ease the
transition to environmentally 'friendly refrigerants. Cooperative
agreements are in place with several refrigerant gas
manufacturers, ensuring that Castrol remains at the forefront of
refrigeration lubricant technology, and linking the development of
new lubricants to new alternative refrigerants as they themselves
. are developed. These agreements enable Castrol to maintain an
overview of the research and new developments in refrigerants
across a wide cross-section of the chemical industry.
Distribution
Castrol companies will supply icematic SW products directly to
compressor manufacturers and designated distributors. The
senk»iector will haveaccess to the products through a variety
of sources; Castrol, OEMand refrigerant gas manufacturer
distribution networks, and larger independent wholesale
companies. -
Castrol Icematte SW lubricants can be supplied in bulk tankers,
55 gallon non-returnable mild steel drums, 5 gallon pails and
6 x 1 gallon cases. . '
I
-------
t. rosas:
-.a 33 :AT»
-.=x
t. r no 'is
•?.£* !•:••• i
lay^narc
'ycaa
It
"u3
-U
Olte
• SA
3CQ09
•a
T.
'
anas
SM29I
CASTROL INC.
Specialty Products Division
16715 Von Kannan Ave. Suite 230
livirie,.CA 92714-4918
Tel: 800/528-4823 FAX: 714/660-9374
April 19ft*
-------
AMERICOLD
R 12
(CFC)
HIGHEST EFFICIENCY
Hermetic Refrigeration Compressors
LOW BACK PRESSURE
APPLICATIONS
2340 SECOND AVENUE. N.W.
CULLMAN, ALABAMA 35055
FAX: (205) 739-0217 TEL: (205) 734-9160
-------
KLofl
LBSf
O1ERICOLD
?^K:i?:TT3:^H^^B
kxM ''or*0 or Ty«* OH CC/H 9UVHH KCJUJMB
100/SO 2*V«
SQ106-1 X 312 5.11. 8SO 184
,J'
SG107-1 X =• 361 5.92 768 194 .
O
SQ108-1 X ' £§ .401 847 867 218
•SG100-1 X
>SG111-1 X
.SG1 12-1 • X
S| ,427 8.99 943 238
|<3 500 8.19 1147 289
.= . .554 9.09, 1274 314
a Standard Rating Cand. > Conwrtwor 0* Camerwaer
WATT* AUM BTWWHH L«M 0* MiwnMon
U«S. ICO. M. CM.
127 1.20 5.12 FAN 23 10.43 8.25 20.95-
147 1.20 5.22 FAN 23 10.43 8.25 20.96
164 1.3S 5-28 FAN J 23 10,43 8_25 20.95
178 147 5.36 FAN . 23 10.43 8.25 20.95
1
213 1.88 5.39 FAN o 2* 1°'W 8-M 2V5>
'240 2.18 5.32 FAN 24 10.89 8.50 21.59
.SGn'3.1 x ,597 9.78 1373 34b 256 2.38 5.36 FAN 24 10.89 8.50 21.59
t Arto tvtiiabt* with 04l coder tub** • designated aa "200" eene* moat-.i .•. SSG106 become* SSG208.
:ompr»t*or can be uaed with ntfw PAN or STATIC CONDENSER. .
HLfJVM
mS
K3106-1 X
HQ107-1 X
4G108-1 X
4G108-1 X
^110-1 X
•K3111-1 X
:(Q112-1 X
•KH13-i ' X
SELRIILES SUPER HIGH BTK
f •• •
.277 4.50 ' 821 156
.312 5.11 709 173
5 .361 5.92 949 213
£|
|* .401 6.57 947 299
!| .473 8.99 1029 289
.500 9.19 1193 300
.584 9.09 1322 333
,597 9.79 1429 389
116 1.01 5.38 PAN. 23 10.43 8-25 20.96
131 1.18 5.40 FAN 23 10.43 8.25 20.96
154 1.33 540 PAN _ 23 10.43 8.25 20.96
. • *
180 1.43 543 PAN | 23 10.43 8-25 20.96
197 ' 1.70 841 PAN § 24 10.89. 8,50 21.59
219 1.90 5.58 PAN S 24 10.89 840 21.59
239 2.10 843 PAN 24 10.99 8.50 21.59
299 2.30 841 PAN 24 10.89 .8.50 21.59
» AUo available wtth oil eoe4er tufeee • Juijnoid ae "200" aeriea modea, i.e. HO106 becorne* HG206.
^xnpf»«or can be u**d with either PAN or STATIC CONOENSER.
A
Tub*S«t
"A"
"S1.1
' tE
VAiLAitf LINE CONNECTIONS — I.O.t
Suction Oaeherge Pteetm OMCooler
IM. hNI W. HM IN. UM M. MM
£59 6.58 -258 648 .258 648 .199t 4.79
.320 9.13 .194 4.93 .258 948 .196 4.98
xcept Tube Set "A" ON Cooier Dirneneion le O.O.
AA connection* are copper coated Meet.
, . ' '•
t STANOATO MATING CONOdlONS -
AU. IIOOCLS
Evaporating Refrigerant Temperature •10(CA23.3C
CoDdiWino Twi^Mfstw • * i^^^'a*^
Ambient Temperature • 90P/32C
UquM. Temperalure at Btpanaten 0«rfee 90f /32C
Suction Qaa Tempenttwe ' t&tSK>-
April 1994
-------
APPENDIX
3u~—.ary. Lift Cycle Design Guidance
nai' Zeouirements ind the Product System '
-------
Op«n-«nd»fl
April '994
-------
Project Summary
Life Cycle Design Manual;
Environmental Requirements
and the Product System
Gregory A. Keoleian and Dan Menerey
Tha U.S Environmental Protection
Agency's (EPA) Riak Reduction Engineer-
ing laboratory and the Uriiveriiry erf Michi-
gan are cccpanrtng in • pro|eet to reduce
environmental impacts and heatti rtek*..
through product system design. The re-
suiting frvrwworfc tar !He cycle doaJgri to
presented In L* Cyca» Oa*on Utnml:
Environmental flec.u//»m«ajfflL EnvlronmwiW r*qur»>
rmoti m lite eye* dMign w» shown to
minima* •ggragra rwouro* dapttton,
•rargy u«, WM* garantton, and
eaaantiel rtementa of the Iramaworfc. A
mulJHryar requiremerrtB matrtt e^proeoeed
to betenoi' anvlronrnentil, parforrnance,
eoat, eultursJ, and togai requiramantt. The
toltowfng deeign sffttegies tor pollution
prevention and resource cuuervsuon are
preeemed: product lito attneien, mate-
rial jHe axtension, maiavM ietectton, re-
duced ftwterial
menegemant, efficient .distnbution. and
inproved ousirveas mena.gemerrt .-wftcn
Jndudee intormetion provwwr). Eriviron-
mental anetysa tooie tor devwopng '••
quiremant* and svcluating design «rtsrr»-_
tivoa are outlined.
: Thai Pnftct Summary *aa
fVaH AMuesor) EngtrManno Labor>fory.
CtaaYia* OH, to anrcune»-K»y findings
of tf» .naaarch project tfmf* futty docu-
martad *i t Mptm rapert at
fltto CJB« ^o/act Aaport orWrng /nfomu-
Tha putpOM o< m« :ui _
Pmjtct * to promcta .«nvraim«ntal .rroac:
and naK raducbon through dasqn. Ths orei«c
con^iamanti tha EPA's Uft Cydf As«*s-
mant flfo/aef wrcrt «'dav«leang gucauras .
tor if* cyda invartory anaiyw. Tha frama-
woiK davolopad m the pn^ta gu«sw.s*sqr-
an to raeue* aggragxa impaea assocatge
with thar product* SuecaaafU • tow.tmoac:
daaigna muat aaw satafy •partormarca. csst.
culurai and lagai ertana. .
.• ' InvMDgation d tha dacgn JHanour* ana
intarviaw*. with 40 daaqn pre««scnais ccn-
trtouad to th* dowiopmant d a oacc [ran*-
work tor la cyda daaga Tha mterviawsWa
oonduoad to idarrty b*ma« ana tna r'cr-
maton and tools naaoad-a acniav* «rvircr-
manal cbjarivas. Ufa Cyc* Da«gn 3«mor-
stration Pto)ac» ara oamg ooneucto .#&
AT&T Bal Late and AViad Signal to tas; r*
A surhmary of • tha savari chaptare ccr.
• tsinad in L* Cyda Oasion Wanoac Environ-
Op«n-«na»d I
Apr* 1994
-------
-',3XCT
'•<— — cwrs.
Chapter 1. Introduction
Mca »rvrer,-erai r-c*3S •asut
^•sigr 3o&sJC'*3 *** aoe erg sefora ^arufac*
-±t y .it vw »rvtfonrnarsaJ crtana often
art -w jsraoemc ai Tie segrinng o< design
wr guoaanaa
rimar man praacnptiom. 0«ignar> shoutt
usa tha manual to davatop took bast auiad
B thaff spaufc profaeti.
Au&ence
=xf "safocoart r srocui sysw- aev«4-
con«rt -as ar rcotart -ow r say r aer>«v-
ng mcaa reducaor. ^n "aruu a snr-arty
uu^eted tor ra ;oiB s 'tn« >TIO« ogeaJ way *o ••cs.c* 'en
•nvronmarral moaca..^* irxor svrs-
cao b« oacompoaac nto 'our srr-a/v sf~-
product
pfocaaa
• manaoamant
T>» prodteteompenant sc."sats :' 2 -a-
tanate n (ra Vial produa arc -x ores ai.
tarma o< tnaaa maaraa 'TOT- aos. s'cr -c
thar utenata taa. Pnxaftsirgt.'ars-sr-s -a-
tanata and anargy ma imer"«c;ar» a-x: ' -ai
preduea. Ot«rtt«on oors«s st :asxa; -g
jyaama and tranacoftat»n ^twcrxs .asc •;
oontan,- prewct, and transoo* -.a-s '.'ar-
abonsfe<&>aa nciuc« ac- - s:-a-
aa'rvcae, frianeol
nat purchaarg^manwtjng,
and trajnrg and adusaaon*
mannoemant comoonam also aevtccs nor-
matan and conwyt I to otnars.
Tha prooaaa. Jaujtxffcr! and mar'aga^a^
' rferrnation oornpor»o» san &a »ur!-ar etas-
salad rsa tha tolowrq suDco
-------
Fugitive and unseated wrtuatt
r. 7?je product tffr ayd* *ywsm.
bacx on others. This emposattss ttw con-
tinual search for improved preduca.
U« cycia goa* an tocaud at tfw top to
inceaia trwir fundanwrtal imjo«*««- Uiv
l«ss tn«s« goals ar» •mbraeari by *» «rnjr»
.devwopm«nt. toam. tnj« !• cyd*
.
Management •xwts a 'major influtne* on
all: pnasas o( d«v«tapm«ft. Both concummt
dtsgn and total quality management prevcfe
moaaa.for life cyde de«gn. in addition, ap-
prepnate corporate poiicy, strategic planning.
•and measures of. success are. needed to
support aasxjn 'projects. ..••
Resesreh and development disoovw* new
approaches tor reduong enwonmentai Im-
pacm. The sttate ot the environment provide*
a oxtert for design, in Is cyde desqn,
current and future envirenmentai needs are
- translated rto appreprate designs.
A typical desqn project begins w* a needs
ansjysis. ften preeeeds ttvough tormulasng.'
.requiremena, conceptual design, preliminary
design, detailed design, and impiementaJipn.
During the needs anaJyw, trie purpose ana
' scope <* the project are defined, and custom-
ers are dearty identified.
Needs are fren^ expanded into a 'uil set ::
oesqn cmeratnat 'mdudes »nvironm«rTai -e-
quiremertt. Successful aesgns oaiancs sr-
yironrnentat pertermance. cost cultural, arc
legal requrements. Oe«gn. alternacves i-s
• proposed to meet these requirements, -s,
development teem cormnuous»y svaiua'.as ,a,-
temanves itmughout desqn. * stucws snw
ttiai requirements cannot oe.met or -easc--
-aoly modified, the proiea snou«3 sna. •
FtnsHy, designs' are impiemer.ao after --ai
approval and dosure by the 3ev»ocre-:
team. •' ',•.•'•••
April 1994
-------
tr*3
/C/HPW-3)
TMTI eeon*n»oon
at
Stftf at £ivirerm*ir . j
Hguni LJft eyti• rf«*gn precwj.
94
April 1994
-------
'Maragemert
Heeds
-ert a a /ui san- * *e cy3e:des^n. Ccoc-
•ate-enwcrr-entai pc«y must Se Tar«at*3
no- severe si ara s> -ave asgnftant effect
or crrxiuc arc excess desqn acovnxw. Cto-
«CCVM anc guidelines need to »••«•*••
'•isned. n anougn dead to provide useful'guri-
arca in aesijr season ma*jng.
,-h« progress at life eye* aesign programs
shouei.be monitored and assessed using
oeariy estaBiBned environmental and finan-
cial .measures. Appropnaw' measures :of suc-
cess an riecessary to rrecvate mdMduato'
• within envelopment -teams » pursue environ- •
mantai impact and healh "sX reductions,
Concurrent Design ....
Life cyde desqn * a bgcal extenscn of
concurrent manufacturing, a. procedure based
on' simultaneous desejn of procuajeaturea
and manufacturing processes., .In contrast to
projeca 'mat" BOOM aesgn group* from each
.omer; concurrent dasqn bring* parocpana
together m a single, team. By having aM actors
in the We cycle. paraapate m i project from
the outset, p'rebwrni thai d«v«tap b*w««n
diffwtnt dacpSr»« can b* raducad. EJficiant
wamwonx ato nduew dav«tepm«nt
lowars coaa; and can improv* qua«y.
Ufe Cyde QuaSty'
Environrhantal aspaets am dpaaJy
with quality m «a cycta daaign, Con^ianiw
who BoK bayond quck profits to locus on
ojsttxnars. muttdaaplinary taamworX. and
oopparatcn with supptiani provria a modal >
tor lifa cyeia daeiga Tha la cyflia frtiiw«rK
aiopands tha«a hcrtznn« to induda Jooatal
and anvnonmantal naao*. Ufa oyda daaign ;
may thus buW on totai quality manaoeflwnt.
or ba inccfponaad in a TQM program. In m
cycia das^n, tna anwirenmaot '• aiao saan m
a customar. Poluboh and otnar impacts am
quality dafacei mat mual ba raduead. UB=
•- mata succaaa dapanda on V*****™^
ronmantaJ quaUty whita saaatyrg ndoonai
eustomars and ampteyaaa, . . . '
• • '- •
- Team BuBdixj • ./
UB cyda daaign dapands on creaa dhn
plinaiy teams. Thaa»taajn» may incW« any
of tna following W» eyds^ partqpanit^ ac»
counting, advertising^ cunmunity, c^Dnwn,
."" distnbutxsn/packi^rifl, anvironmantaJ ra-
spuross staff, govanSnant ragulaMfsrtaiv
dards sotting orgartzalions. induawal dawgn-
ars. lawyarsi rnanagamant. markattio/salaa.
procac* daaqnan and anginaan, procum*
mant'purchasmg, production' worttars, ra*
- saareh and davatapmant staff, and sarvic*
personnel. Effactivaly coordinating thaaa
taams and balancing tna drvaraa intaraaa of
.. --.all paruaparra, prasaina a signficant
' Jang*- , . .
•or-cnanga sr
an opportuRSy tor na«* prcaua s
''"!>» first aw >n any prowa srooc » tiom-
fytng aiaomofs and *»»r na«ds. Avocmg
confuson b«tw«an '.rival or aonwnaraJ :da-
waa and aaual naads a a major
ot aa cyda doaqn,
Cixa sqnifcant naads hav« baan
fiad, ma proi«a's scopa can b« dafinad. Th«
artads choosing systam boundanas. charas-
tanang ana^ix matnods, and- •atapusfflng a
proiaa tima 8na and budgat in aadfflon, da-;,
vatopmant taamt should daoda whathanha
proiact w* tocus on rnprovmg an an^ig
product,- craaong tha naxt garwraoon modal.
or davr*png a naw product . '
In cnocamg an appropnaia systam bound-
ary tof daaign,, tha davatopmant taam must
inmatly consttar ma «ul 'fifa cycia. Mora ra-
stnaad sysum boundanaa rrjust be property
juaofiad. Biginntng w«h the moat comprehen-
sive. system, design and anaiysa can focus
• onthe: ' -
• fuilifecyde, • .•
• paitai'i'acycia^or .
• . . mdMdUii stages or aawtiae. . ...
- Choea ot ma ful la cyda systam w*
provria the greatest cpportunaiaa tor anwon-
mertal mpaa raducaon.
- Narrow* bounded systems may provide
.useful mute, '.but tna imitations must ba
recognized..** dearty staad. Sagas may
be omeed f they are static or not affected by
a naw design. In al casaa. das^ian wooung
on a more tatted scale should be aware at
potential upstream and downstream, impacts.
ComparaSve anarysie, also referred to as
benchmartung. » nacasaary to demonstrate
tnal a naw design or modfcafcn is an im*
prevement over oompatitiva or alemaiiva os-
Raqtsramanti define «• expected design
otscoma. Design alamativea are evsJuaad
•on now wed they meet raqu»emantt. vyhan-
ever poestie. reouiremariti should ba stead
expfody tt help tha design team nnstoe
needs Mo effective desqna.
Sucoassful development teams piece re-
qunmerra before deatjn: Rushing into de-
sign batorn objectives are defined often ra-
yr.asa» -.ay =« aco.-.~ng at ra sara • .-*
Limitations ,
. ijcx ot cata'and. rnooas 'or 29tar- r
it eye* moacs -nakas ana/yss irf'cx.l
o< moovann can aao 9e a.sro'cwn wv«i
fta.soooe of desqn a breadenwa 'rot- rat
poreon or me life cyde'cnntreiiae sy ndvc.ai
players to other'.pa/txapants. merest n -a
cyde dewcr can dwindle:-1 can se citfo-.t '=r
. one party to tafca acnona mat mainiy sara't
otr»m. • - ,'-.<•
Ctvpiar 4. Requirements .
Fomuatng (iouremenB a on« of re -cst
crtical aavioea ,m fife cyoe das«gn. A -van--
conceived sat of requirements trarsiatas
protect obiecDves nto adefined soiuoef .scaca_
for design.
In le cyde deagh, environmentai 'unc-
tibns are crtBal to overall system auaiity =ar
this reason, environmental -aquirers-ts
• shouid be developed'a me sarra tire as
penormance. coat cutural. and' 'agal caara.
Al reouirements must &e baapcad n su:-
caaafui dese^s. A product mat 'aia .n rs
marMplaca benefti no on*': '
Kft Buntnts
Requirementi 'define products m terms of
. tunaiDna. aanbutas, and constraints, Func-
abnadeecnbe what a susassful dea^n coes.
Functions should state vrtaft de«gn ooes.
not how i is aceompiehedr Artntiufts ara
further data* mat provda useful .dascnotcn
of functions. Constrara are condanns :fat
the design must meat to satisfy prqea goas.
Conatranti provida ima on functions Tat
restrict the design search n, manageable ar-
The tatowing phases of development are
not' significapUy atarad by la cyde des^n:
conceptual design, preliminary deegn. da-
tated design,: and implementaiion. Durmg
mesa phaaaa, the dexetepmant team synthe-
sizes vanous requirements into a coherent-
desgn. Because Ma cyde design * based on
Considerable research and analysa are
needed to develop proper requirements. Too .
. few requirements usuafy indicates tha 'me
design is ambiguous.
The level of detal e^rassad in reqwre-
mants depends on the type of .development
protect Prcpoaad requrements tor new prod-
ucts ara uaua»y leas detailed man those set
easting product.
Us* of Otqulnments Mrtrtx
A muMtyer requirements matrix proves
a systematic too) for tormulaiing a thoreugr
sat of anvironmerrat performance, cost. c.i-
- turaj, and legal requirements. A schematic at.
this multower mamx • shown m Figure 3.
A practical mamx shouid 'be tonr.eo sv
further subdividing me rows and .columns at
this conceptual maB«.Matreas allow oroouct
devetapment teams to. carefulty study me 'r-'
teidapendendea and intarscoora betwear ife
cyda rsquiramar«.,They also prcvde a sorr-
venient tod for bamifying conflicts satwaan
- requiiments^dclaflfyrg trade-offs rat rus,
-------
S«TT n;
r r* •'••arijej.
Ranking wd
Requirements
3arxrg ana *«a>rg '•qurenwts prc-
vtie 2**)gr«rs w* an jnc*«andng of the
tar** rwoftaree of varcoa :»aur*mena.
AT tiearnpe c< a -*erui rutfrannn scfleme
- Must 'eourtmerrts are conditions that
jncrcvemena and de«gn atematives
have B 'meet No deeqn aSematwe •
accactaeto unlees t satisfies al must
'•qufements.
• Wttt requremems are desirable traits-
' used to select best alemaoves from
preocsad" soiuterts that, meet musf
requirements. Wart requirements help
eesqnen seek the best solution, not just
:ne first alternative that satisfies
mandaBrycondtoon*. Theee ontenacan
pay a otjcal rote n oustpmer acceptance
and perceptions of quality.
. • Afxiuy funcnons are tow ranked in terms
of retanve importance and can iheretere
• be relegated B a w»n 1st Oesqrers
shotad be aware that these desires east
and oy B incorporate them in designs
when it can be done without
compromsjing moni cnbcai parameters.
Cosnrvws or dents should not expect
to find many ancillary requirements
included in the final deogn
Chapter 5. Design Stntogiea)
Effective strateg*s can only be i .
after proiect otnecnvee are defined byne-
qutrements. Deeding on a coursa d action .
before me destination • known can be an
mvtsoon B dissser. Strategws (tow from re-
qunmertts, not the reverse. ___
A successful strategy satisfies} Tha entire
set of desqn requrementa, thus promoting
rtegranon of environmentai requremena rto
dee$n. No strategy is exclusive. Meatejsvs*
opment protects should adopt'a ring* of
strsegas to satisfy requswnenm. For thai
reason, no srgte enMgy should be sxpsaad
B janafy al project reqursmerts.
The fotowng strssegies am oudned in the
manual: • • •
Predua system Vs eajeneton
-ranee. Soazai »ur<;ar«s
a_M T» sa^s aoN-rv iar
' d^eren »fl9ca .n sifl
• process contro*
•• CTiorowd orocHS la
• rv^nory 'control and matenal handling
Eflowt stanfxocn
packaqrg
roved ousneai manao«mert
office management
rfcrmaoon prowon
labeing
advening
ChtptBT 6. Environ
Tools
ntal Analysis
adaccaUe
refiabto
serveaabte _^
1 remanufacUrabia
reuaable
MMtrml Off Exmnuen
recyeSng
. A systemaw means of gathering and ana-
lyzing data n varying depths » needed from
Tit very oegmning of a development project •
ttirougn imptementaDon, in parncuiar, erwv
ronmental analysis a needed for
benchmarking and -the evaluation of design
aaemacvee.
Environmental aueesments are baaed on
• the teflowng two WUITI^J 144 ita:
• inveraory anaryw
• Impact anar/«a
An rvernory anaVse) identfea and quarm-
flee al inpu» and ou^oi tor a product sye-
tam. Information about mater* and energy
inputs and wmete (reaiduaO ouputa for every
sgnAaut step included in the system under
The purpose of impact aueesmert is B
•vmluate npaca and neXa aaacciateri w«h
the maMriaJ and energy transfers and tram-
formationa quantified in the inverwy anajy-
A full* 9fO» ssssaiiTisrt' may not be
essential .tar many design acavnsa. Scape
can vary from complst* quanoncatpn or at
nputs, outputs, and the* impacts B a simple
verbal description d inventories and impaca.
Boundaries for analysis may range frem the
ful Be cyde system B individual acBvibss
wilhr a Be cyde stage. The development
team should be able 10 justify reducng the
scope fa design B a partial IN cyde system.
The fotowrg facers related B ana*s»
shoutt also be considered when setting spe-
cific system boundaries: basis, temportl
boundanes (time scale), and spatial bound-
aries (fleograprse). In general, the ban for
analyse) should be equivalent use. The time
frame or conditions" under which data were
gathered should be dearty idernfisd. A data
collection period should be chosen that is
representative ot average system perfor-
inventory Analysis
The mverery annputs and oueuts
Atocsoon pKOtmt car. occur
-------
. -*s*
1
i
••«
HI 1|^1
proauet
• inoua
• Outsua
• Inpua
• Outputs
Cistntuoan
• inputs
• Outputs
• • inputs
i •• Outputs
' '
do*
.
. -.
,
nSTUtKSJ J^
S«/vic«.
,• ,
1
*""""<
Caecsn
r» 3.. Oonc»ptiuil rvquiniruria matrix.
wail as mo ecosystem pctemialty impacted.
Ssotagcal stress agems car be categorized
as cremcai (e.g., toxc chemetls rateesed to
tfte environment), physeai (e.g.. h»M* d«- •
afucaon mreugh egging), and bdogeal (in-
troducBon oil-ari »xocc spcews) agirts.
Human h«a«i nak ass««m«nt lpchjd«
hazart oomficaoon, nsk asscwwt. axpo- .
sur» 3as«sm«rt and nsk diaracttraanon. •
Human h«aflh and saitty nsk» caw afco b*
ass«s«d using models .mat «vaiua» pro-
cass system mliability.
Chapter 7. UftCyde Accounting
Traditjonai aocounwg pracw«« n««d to 6«
modifwd '-to mow tijfy rt«tact ths- Wat oa*i erf
potiuwc and rtsouiw dspHbon. Imprewd •
accounting p«*3ico on b* a ksy •tamvH in
faoiitaang «• cyd« dtsign. Acoounting m««>-
ods outlinsd in ttw ehapwr at* boad on tt»
total cost asssssfflsrt modti. ' '•
At pfM«Tt most cost «y*sn» uasd in
businus an» baud on finjnc«ri
reporting rashsr than .,
snviroomtntal cosm am vaialy jatnsrtd on
th« facility isvst ThM».eo«i-ara «dbsd.l&
ovsmoad and th«n auignsd B spscA: pred-
uca for managsflwnt puipein AJteca»n
.T.sttiods vaiy « acoufiey, bu tuttrf* advtross
-nay allow gatfwnng ot much mom accurate
* -
Ufa cyctodssign bsnsflts from an accurat*
astimats of cosa raotsd to aavatoping and:
using produea. Mawnai and fntrgy flow*
^ provtja a detailed template for assignng cos
•• ,to individual produea. Following the total co*J
assessment model, life cycle accounting adds,:
hdden, Uabity, and tes ang'tie costs to
those costs usualV'gaaisred. This, expanded
scope mttcnue tne range of acwmes included
in ie cycle design. Time scales are 'ate
expanded to include at future cosa and ben-
efits that rmght resui from desgn.
Usutl Costa
Ue cyde accounting ftat identfies tradi-
tjonai caprtal and opemng expenses and
-revenues 5ttden r«gula«xy cosa indude the IWow-
ng(th« is only a partial list):
protective
^
nocffcJiBn
rspcfwg .'
monitonnc/esting
record keeping
piarnngwudiesmodeiing
• monloring equJprnent
• preparedness and"
'
^ _ _
acUiionai technology
u dining .
inepeetons ' '
manrfeong
labeling '
'preparedness and B«o:ac: •» s
ecwpment '
dosure>post 'dosure caca
medical surveillance T ":,
insurance/speoai •Jonas
L&ttty Coots
Ljatoaty costs ndude fines due to *crc=--
pliance and future liabtWws tor -w^aciai ac-
tion, perspnel injury, and- property aarage.
Avcidng iabity through de*gn * .tne *«est •
course. Because estinatBTg potential envi-
ronmental lafcily costs • difficult, mesa costs
are often. underswed.
Less Tangfcte Goes
Many less tangfeie costs and benefits -ay
be related to usual costs, ntiden raguiaiory
eostt, and iaoibes. SsomaBng intangioias
such as corporate image or worker ^ora;» s
difficul. as « projecting improvements >n r-ar-
ket share or benefts denved from- improved
customer toyaty.
UilllWtOftt
The main difficulties in life cyde
' arise in estimating costs tor many
txgnat items and property aflocaang snose cess
to spec* productwrccssaest Laoffly ara
less tangWe costs are the most citfcu.t '.a
Some kjw-flipafl designs have srecacy
•not been implemented because lie cyce c=ss
were not accurately calculated.
-------
scr~-« ?» aocwrv
--sifaw ac ^a acxr^« c T— a.
are
sro
T« -3. E.-vrcr —
« sc=c*
5< assx-o; a i"**"- **' ong as costs *x
•»«*.?•=• 5ac«oor, arc or* *«•<••
'ui •«oort iwaa sicr-o«o r -ii
.^fe. 317570
Gregory A. ,<#cw*i *rrf 0«^ Mw\9rty in wrti
oon C*nf»r. Un;v»rs/!y a/ Micfiigafl, Ann After. Ml 44109-1 1 15
U»r/ Ann Curnn is £h« £P-* Prater O«(S»r /«• &*ow;.
7>« co/noMra '•port, «rotf«d *!j/« Cyd« Design Mtnu*l: En*x Otfictr c*nt» conttctod *t:
R'o* PfHicison £nqin»»rmg LtbGniory
U.S. Snwonm^mti Prof»coon Agency
CinctnnMO. OH 4S268 •
United Statts
Enviranm«ntai Protection Ag«ncy
Cantor for Environmtntal RM«areft Irtonnttion
Cincsnnatl, OH 45268
j-
OtfidaJ 8u«in«««
PtnaJty for Pnvat* UM
S300
BULK RATE
POSTAGE & FEES PAID
' EPA
PERMIT No. G-3S
April 1994
-------
APPENDIX D
•Sair.s.e rheraodyriamic calculations for R-12 using
pressures-enthalpy diagram • - . •
' «Saznpie calculations for Rrl34a using saturated
' property tables and'ideal gas heat .capacities
' •Calculation-of refrigerant mass flow.rate . •
• Calculation of internal heat transfer coefficients (h),
overall heat transfer coefficients (U), and heat ex-
changer areas . .
•Maximum allowable energy consumption under the
1993 DOE standard. •,'- '
• Calculation of total anual energy consumption of •
refrigerator as a function of the heat load. Used in
Figure 5 and Figure 6 "
-------
Sample thermodynamic calculations for R-12 using pressure-enthalpy diagram
se-- — ab'.es ai\d Pressure-Er.thalpy Diagram for R-121
on prooiem statement is the evaporator temperature.
uS.ngtaoies.forT,: .
«»>P, »2i.9psia
x=> h, - 77,2 Btu/lb - ' -
«>rhot (density)'- 1/1 .7507- 0.571 2 Ib/ft3 _••
•T - 115 'F based on problem statement is the condenser te'mperature.
using tables, for ,T4: .
««>P4«161.4psia •' .
«*> h, « 35.2 Btu/lb • •
•u 3F suoerneat of evaporator outlet based on problem statement: ;•
T^T^U.-4-f U.'» >T,'-10°F . ' . . •' ,-
no pressure drops «> P, « P, - 21 .9 psia
using diagram:
««> hj - 80 Btu/lb
• «>s,«0.175Btu/lb-'R
,
ideal gas law -> rho2 (density) » rtw, (T,/T^ - 0.5712 x (455.67/473.67)
«>rtioz«0.55lb/ttj
•superheat from" 1 to 2 is subcooling from 4 to 5:
h,-h4-(h,-h,)- 35.2 -(80 -77.2)
«>hs- 32.4 Btu/lb . .
from diagram at h, '.''•
.-.> Ts « 11 2 '»F (3 °F subcoding)
•isentropic compwssion from 2 to 3, using dagram:
«>TS.150«F
«»>h,« 95 Btu/lb. "
.«>rhoj(d«nsity)«3.5lbm1
isentropic compression «-> s, « s, - 0.175 Btu/lb-°R • - •
•work input by' compressor w « ryn:« 95 - 80 -> w « 15 Btu/lb
."•isenthalpic expansion — > h, * h5 - 32.4 Btu/lb
-------
. = : , =s-:s's:or- ="55 •= -. • n, * 77.2 • 32.4 ==> RE . = 4433t-.:o .''-..
•C25 = Coe^icer.t Of ?erforrrance = RE-'w«44.8/15 -=> COP = 3.0 • • - •
. compressor voiumemc efficiency (Nj is composed of a contribution (N.J due to the clearance volume (fc . 5% from the
prdoiem statemem) and a contribution (Nj;frpm'other factors (leakage, mrottliog, heat loss). , • .
' NM «.0.9 from problem statement.. • • . •
. ' N^.,1 -fc((moyrho,)-.l) {see Teaching Aids and **} . . , . .,
.. ">Na,.1 -0.05'((3:5/0.55) -1) ~>N;«0.73 .'..'-'• . ' --...'
•-•«> N,-Nwx N.« 0.73x0.9 WN,. 0.66 •••'-' . '...:...
•Volumetric Refrigeration Effect (REV) is based on the volume of refrigerant entenng the compressor l' • . •
==> RE,-RE xrho2«44.8.x 0.55 «> RE,»24.6 Btum3 , •
Sample calculations for R-134a using saturated property tables and ideal gas heat capacities ' ; ;
for. tables are the same as above, except for the calculation of the interchanger superheating and the' comores-
• ' the'expression for the ideal gas heat capacity;(C,3 supplied in Appendix 8. •. • ..
,
"c,» 0.001 255721 3 _ •
Cj = 0.00043742894 "
. GJ- -0.1487126 x '10* ,
c$« 6.8021 05688
m the superheat region:
Ah«J Cp(T)dT • :
As»l Cp(t)/T dT ;
>?,)'• «i> h,« h, + Ah (T,—>T8 ; ; ' .
Sj-s,.AS(T,->Ta) —>•;•.•,+ At (T,->T^
•To calculate T,. isseniropfe compression —>s, » s,
s - saturated, vapor entropy at saturation temperature (TJ » As (T4 — > T,) " " .
*e torn botn quantities on the left hand side of the equality and we know T4 and As(T), so we can can solve for T3.
•h,'» saturated vapor- enthalpy at T4^ Ah (T4— >T,), '
Op«n-«nd»
-------
wncn does tr.e calculators for R-i34a:
.
=2 -: :::4:*42i >4.
;j --: '.i i -.:«:.:• '-«•
T -4S» «7»
an t -int .Cpit, .51 .
31 !t* -ka^ »Cpi t » j'T. 5 I i
t: --« , 3.
•i -a 12:) ,
s: -101 i-,
tl -.5 J
t4 -us
,
:si -o 3«;.
r.to; -*. 3'2 3«s<
CS04VIP -1 0/0,2««1
. -nl-r.z,
»t -Bi-fvS;
COP -»!/«,'
rno2:-3 5'2'rnol.
tnaa -rno4v«p-(i«J».*7»t
-------
g s re oVjut'rcfr.tne'aDCve progranr. .
.,-.. - ;..... 5.-" ^r:^y -.ru.. •:.••-».i.-.. i. :. '-
2:2-s«iii3 - 5pc»jr4ji»4 •- - 'i4iv.2«cs3".a us9 si . t, .« IONI
«
si . t, .« IONIUM -
3»l 2 112 459«' ,,3 . 4*545 ^ 45961. ^ ^ •
'"' " "s;9S2"' ' ' "I«I25S9 22S»i91405 100 9113 13 =
S« 2 •.U92020S3S5U 4«S4503 1 ^ ...iiii"!"!--
"' " " "sjlJOSjT'' ' ""«ii«««ii£ •- S».2151il23 -
;3P '•- 2.904MJ7J2
•rna2 •• .«101«4iTH
rnoJ s- J.il«J*SJ'»
nuv :• .SUJ1UOS1
-------
Ca c- a: c- a: fe'-ge'art -rass f.cw rate
• -;- :5f~scn of aj!i Dowr, ~me, we r.eec to first calculate trie load trie refrigerator has to nandle,
• need properties of air: - .
C,^-0.25 Btulb-'F ' • ' ' .. ' ' '
mo;, - 0.081 IbAt5 • • ." ' - • .
• fresh food section: • }
refrigeration load needed - V of fresh food section x rho. x C^,'
-13x0.081 x 0.25-0.263 Btu^F •
AT«(90 • 38) - 52 • . . .
Load-0.253x52-13.7 Btu • .
• freezer: '. . ,
refrigeration load needed - Volume of freezer x rhoB x CtM
-5x0.081 x0.25-0.10125 Btu^F • • .
AT « (90 • 5) - 85
Load-0.10125x85« 8.61 Btu ' . ,
• tnus total heat load -13.7 + 8.61 -22.31 Btu
• Pull Down Time is 2 minutes
»«> pull down capacity » 22.31 Btu/2 minutes
»-> load refrigeration cyde must handle » 22.31 Btu/2 minutes
« 669.3 BTU/hr - 670 Btu/hr
• check for reasonable pull down timawnw operating at extreme design conditions:
Load - 0.263 (110 - 37)-t-0.10125 (110 • 0) » 30.34 Btu
Pull Down Time-30.34/670 « Oi045 hr« 2.7 minutes—> O.K. -.
• Cateulat« refrigfrant mass flow rate, e.g.R-12:
RE « Refrigtradcn Effect of R-12 « 44.8 Btu^b (from.above calculations)
-«> mdot«mass flow rate of R-12-Load/RE . .
«>mdot« 670/44.8.14.96 Ib/hr . - . ..''.''
Calculation of internal heat transfer coefficients (h), overall heat transfer coefficients (U), and heat exchanger .areas
April 1994
-------
-e.'o,,cw -;-^ua..a-JC-4 are
serfcr-ned 'or T>9 cvce uTi,r,-.g =1-12
ccnoei-ser - desuceneat pan: .'.'..
cccx from T,—> T4 . «> 150'3F —> 1.15 =F
T ' = 115* (150 -.1151/2 •» 132.5 °Fi
P^ - " -" " • - ;
>properties of R-
'.viscosity « n « 0.033 Ib/ft-hr - . ,•
' thermal conductivity « k i 0.0064 Btu/ft-hr-'R , - ; r • . .
heat capacity «Cp« 0.1 S8tu/ib-3R / ' '• . ,- •. , .
« •using supplied expression for the internal heat tfansfer coefficient of the desuperheat part' of the condenser (h
!x 10.3 (OJ5/:0.033j°4x (0'.OC€4r x 14.96 « 13.63 Btuyrir-ttJ-5F
condenser • condensation part: ; . -.--.. . ''...•'''' '"'.'.
condensation at constant T4xi 15 °F . . •• , - . , ^' , :•'•
«3>use average of -saturated gas and saturated lio^iid properties of 'R-t2 at T4:'
•• ' viscosity. * \i » 0.237 Ib/ft-hr ' : •- ' • . . -
: ' thermal conductivity » k - 0.0207 Btu/ft-hr-°R
heat capacity - Cp - 0.225 8tu/lb-°R ; ."'••• '. '
«> using supplied expression for the internal heat transfer coefficient of ttie condensation part of the condenser (h j:
he - 592.5 (0.225/0.237)0-' x (0.0207)Mx 14.96 « 847.57 Btu*r-ftJ-°F , _
evaporator: ' . ' ,' . '. . • . . ' ' . " : -
• .evaporation at constant T,.« -4. aF, ... .y , '
~MJM average of saturated ga» and saturated liquid properties of R-12 at Tt:«
viscosity » \i * 0.397 Ib/tt-fir -
••thermai conductivity- k. 0.0267 Btu/tt-nr-'R .
heat capacity- Cf « 0.181
.«> using supplied expression for the internal heat transfer coefficient of the.evaporator (hj:
h .5152 (0.1 81/0.397)'* x (0.0267)" x 14.96- 640.3 Btu/hr-ff-'F .
April 199*
-------
3 r.0~5l nea; -ars'=" ccs^erts >v "•, arc *„ calculated aaove. arfl re express.crs lcr re eve'*: -s=:
'.,-7-a'xe"J oer-.s -J , -j" anc - r.e rescec'e areas A^. A;, arc Aw can oe caic.,a;ea tor eacn ot tr.e oesv-perea: ra-
re xr.ce-ser, re xndenser. and re evaporator. This >s oone L;smg a Mapie program:5
aiaoi, -;•» 96.
adh -13 63.
hc.-UT 57.
hev -6*0 3,
T3«iSOO.
h3 -95 0:
t bt" n
-------
'• re c^ut 'ro-T re aocve program »s:.
zooc - '.•» 96 ' _
hdh - >3 63
he :. U-l 37 -
hex :- 6*0.3 . ,
T3 ;• 150.0 " '
h3 .•- 95.0 •
» hjv u uiiinitti vip..f.«BXh«lp)r « T4
lav ,-- J9.0 . , . , '
-1>4 ':- 35.2 . , '
R£ •- *4.l '- ' :
. Uiehi-- *0.0 .
h5 .•» 3X4
T5 :- 112 ' •
. Tl - •* '
T2 :- 10
T4 :• 115 •• .
I deiueeheii ptn of eondaucr
Udh :« 7.0374902S5
delT :- 35.0
Q :. 89.760
Adh :- .36**1562T7
•Condentauon
Ue :- 1Z49770J9*
den" .•- 2i . ,- -
Q :. I04.MS
Ac . 2J759I5739
rToul Condeiue tn*
A« :• Z940401347
iEvtpentec
U«y v 10.69169571
Q :- 670.2M
A«v :. 6.964590127
. » U03I1796I
Aich :- .00949S6I1I9S
-------
Max'".'" iswace e-ergy ccrsur.s-cr. jr.cer me 19S3 DCS stanaard.
. A* «Aa,-s:ea Voiume of our1.8 ft: refrigerator
AV«'3r 1 53x5. 21.15 ft3
• Aitcwaoie energy consumption in KWatt-hour/year is ' . ' . •
KWatt-houivyear« 329 + 11.8 x 21.15 - 578.6 • 578
Calculation of total anual energy consumption of refrigerator as a function of the heat toad. Used in Rgure 5 and Figure 6
• energy consumption as a function of load. Power consuming devices are:
' evaporator fan '«> 10 watt -
condenser fan—> 14 watt
anti sweat heater «> 19 watt (assume 30% running time)' ' ' _ _ _
compressor «> depends on refrigeration load, COP', total efficiency ...
• compressor power: (using R-12 as an example) ,
COP « 3,0 , -.--..
N,«O.SS ' • , . ' .
total effidency«Na • , '
N0 «isentropic efficiency (0.7) x motor efficiency (0.8) x N,
m 0.7 x 0.8 x 0.56 t
«0.37 , , • '
compressor power. Pm . (670/(COP x NJ) x (1 watt-hr/3.414 Btu)
«>P-BB-177 watt •
. compressor is ON only a'fraetion of'the time. This depends on the total heat that needs to be removed from the refrigerator
(TRL). ' • ; . :
• • ««> TftL « heat gain through insulation + anti-sweat heater contribution
anti-sweat heattf contribution « 0.3.x 19 watt-hr/hrx 3.414 Btu/watt-hr
• . 19.5 Btu/hr / . ' '
«>TRL-heat gain through insulation+ 19.5 .
«>fractjon of the time compressor (and fans also) is ON-FRT .
. «>FRT-TRL/670 • . "
Op«f>-tna«d Proottm • 108
April t99«
-------
--••> 3" a, ere-gy SX-S.T:-.C^ of a aev.ca .s tre 'radon of the tine it is ON muitia.ec sy is power -v^. ec.:> re
•-.-ce'^'-ol.'.s ' a*/'ear. wrier .s ;3'55 * 24! 3"50nours. ' ;- • • '• ,. .-•
. -«a rne-y Consumption = {FRTx(P^* 10 +U) * (0.3 x 1,9)},x 8760 ' , ' ,. ' ;.
in'wai-year; tor R-12 this simplifies to (201 x FRT + 5.85) x 8760, which is a linear dependence on the heat gain througn
the insulation. - .. "• . • - ,' • .... '.•'.'•.' • ' ; '
j .in general .teniis. the total energy consumption in'Kwatt/year is:. ' ' ..
'—>{FHT(P-I.+ 24)-+ 5.85)} 8.76* _ ' ' . ,
1 ,«>{FRT([350.45/(CQPxN,)]-+ 24) + 5.85)} 8.76 _ ' . -
me above srcws that energy consumption as a function of the heat gain has a parametric dependence on the GOP and N,
of the refrigerant used. ' ".. • „. ' .' .•'"•--
Hea gains by the fresh.food compartment-'and the freezer • . - , : •
. The following are me starting assumptions from problem statement: ' ,, .
,> total inside-height of refrigerator«H'« 53'inches •' • • -• . . - ' .. -
«> total inside width of refrigerator «W«26.5 inches . ; . ., •. - - -
«> total inside depth of refrigerator--0-22.1 inches . . • ' -•._ . _
«> outside heat .transfer coefficient» h,. 1.47 Btu/hr-nJ-'F
«> inside heat tr'ansfer coefficient» h;« 1.0 Btumr-na-°F . " "
.> gasket heat gain coefficient for freezer «hg,. 0.0055 Btu*Mn-«F .;
.> gasket heat gain coefficient for cabinet« hg » 0.0014 Btu/hr-in-'F
•' '»>noheat exchange between freezer and-fresh food section, 3 inch separation between the two.
• ^, ' -- . ' -' . ' .
• The following symbols are used below: '• .
X1: insulation thickness d fresh food section . .
X2: insulation thickness of freezer : ^. ' " •
.. AF,^ AF4: inside and outside areas of freezer section
A,, A.: Inside and outside areas of fresh food section "
QF: heat gain by freezer through insulation
.- Q: heat gain by fresh foodsection through insulitfion-. ' . .
VIF : freezer .insulation .volume
VI-.freshfood section insulation volume
QGF: heat gain by freezer througrt gasket
QG: heat gain of fresh food section through gasket
• The calculation 'of heat gains is a simple energy balance:
mposed of the outside convectiye heat transfer insulation
bSd on length rather than area. Rvalues for msufat.on
-Op-wnd-PrM-J.-^
are converted to thermal conductivity (k) by -I/Rvalue..
-------
; ,e- 2 .i-e •:' X' X: ~xst oe sucr xa: QF V,F=G,V ' ' . .
xj? -..s* :e ta.x.atsd T-aifnainrg a freezer vpiu.T.e of 5 (^
33.CX. 2: :"s 'or Rgure 4 arc Figure 7. •
. -^-e lowing is a Maple program5 mat was used to generate data for Rgurt 4 and Figure 7 based on me above conditions.'
• The following is me analytical and part of me numerical output of me above program:
'aTr:-85;
» Fr««i«r Calcs
r':-0-2' !X1-X2! ;
F:-l5«m'12) •' (O'H) ;
Ao:- (W-2-X1I • (B*2'X:i -2- (W-2-X1) • (H»X1) •
2M3->2'!?l!MH-X:i ;
UA:-1/ ( (I/ (no'Ao) I - (Xl/ (le'Ail ) » (I/ (fii'Xil ) ) ;
Q:-UA'aT; '
Qtoc:- 3F-C;
WTT:-WF-2'X2;
3FT:-OF-2'X2;
HET:-HF»X2;
WT:-+J-2'X1;
DT:-D»2'X1;
HT:-H*X1; . •
« Iniulatign Volim* diet.
VIF:- (2«wrr'HFT»2'OfT-HFTrDFT'WFT) «X2;
VI:-«'WHI*2*DT««r»OT.«WT)'Xl;
vm-yiF+vi;
*(X2-i,Q);
i4:-tuDi (X2iz,QMi> :
'i5:-iuM(X2-t,VIF); .
i7:-iuB»(X2-i,V!T);
aFp«nsco.;
print (1C, XI, i,z2, 13, 14, z5, z
vric'
Op«n-«nd«4 Proowrn -110
' April 199*
-------
: ,-sc. .6 ri-. -*
:j : -s.zs '<.--'-:
*!. t. i2/z3. t4; sS,z6, »') ;
*:;-.e'-s icerair-.j.: - ;
£> ;
i3:-sao»(X2-t.C) ;
'Ht-suas 1X2-1, OALi) :
i5:-»uo»(X2«i/v:r);
.,,,
wr:teto (terminal I ; . "
ws; • '
I R-15 Injuiation .
x:-1.0/ (144*15); ;
for XI from 0.5. by 0.5 co 4.0 so
.z:-solv«(ras>r»t2,X2) ;
i2:-»uB*(X2"t,OF);
.
i, QW.il ;
l5:-»uB»(X2-z,VTF);
,
i7:-«uB»(X2-t,VlT);
appcndto (autaacalS) ;
print (X, XI, z,z2,z3,z4.zS,
writtt-o(nrmir.al) ;
od; . .' . '
< R-20 Insulation .
£o.t XI frat'o.S.by O.S-to 4.0 do
i:«iolv«(r»tI-r»t2,»J) r --: ~ • • -•
t2:-iuB»OI2-«,QF); '
Z3 : »tufi* (X2-t , Q) •;
,
xS:««ai»;
i«:-mu6»(X2-^Vl);
i7:-tut>«(X2-t,VlT);
app«nato (outaata20) ;
print (*,X1, z, x2, *3, »4, IS, ««, z7) ;
»rit«to (terminal) ;
'' '
I R-25 Iniulatlon .
*:-1.0/(144«2S);
tor XI froi 0..-5 By 0.5 co 4.0 ao.
z:-*olv«(ratl-rat2,X2);
z2:-«uto»(X2-t,QF);
z3:-«ur»(-X3-t,q);
t4:-«uiM (X2-t,QMi! ;
Ii:-»ulM(X2-t,Viri;
z6:-*ue»(X2-z,VT);
z7:>*ufi* (X2-t, VIT) ;
' app«nai:9(out :
print (V.Xi; I. z2. z3, H, z5, z«, ?7) ;
-------
-.. .. .„.-- s 7€ i-ir.ca arc =an 3! tre -unercai ou^Jt of tre aoove program
0 :- 22.1
w :- 26.5
-.c :- .:'.::
.11 :- .306944444444
hgf :- .=055
ft C22.1 t 2 XI - 2 X2) * 11210 -™ ~
17'280
•
Afo :- (26.5 » -2 XU (22.1 » 2 XI) '
. 2 (26.5 * 2 XI) (•«« -~-77ST7nT«rr« 2 Xi - 2 X27
. 2 (22.1 • 2 XI, ,8640 ---— --— — ^p^JTj xl _ , ^ * "'
UW" :• ' . . _ ' • .'''•'
1 / (»7.9S»1I371
1 / ((26.5 + 2 XI) (22.1 * 2 XI)
- , 2 <».S * 2 XI, (I6« _^._^--~~-:T-xrn— -^ X2,
' •''',' 4. ¥2] )
* .2 (22.1 t 2 XI) IH40 .,-„.,. r „_ 2X2) ,„.! + 2 n - 2' Ul
/ k '
. ' • ' l
, U2C.S * 2 XI - 2 «) (22.1 * 2 XI - 2 X2) t 17210 -£-_-—-
144.0000000 .
1 / «26.S » 2 XI - 2 X2) (22.1 » 2 XI - 2 X2)
' , ' 1 ' - ' *
- •* 172i° •srrrsrnr * 1728° ~^~: * n - 2 x2~
-------
•1 ./. (91. 95918311 •• :
-; / ((26.5 » 2 )C) (22-1 '+ 2
• 2'.
(26.5 « 2 XI) '
1-
••• X2)
'(26.5 » 2 XI - 2 ttl ' (22.1 • .2 XI - 2 X2|.
(22.1 * 2 XI)
(8640
» X2) )
(26.5 ». 2 XI - 2 X2) .(22.1 - 2 XI -, 2 X21
((26.5-* 2 XI - 2 X2) (22.1 » 2 XI - 2 X2I _ '
"lT~Txl"~ X2 '
. 144.0000000 _ , .•'
. 1 / ((26.S r 2 XI .- 2 X2V (22.1 * 2 XI - 2 X2) • .
'. -1 '
1'
+ 172SO
* 17210 —
22.1 » 2 XI - 2 X2 26.5 * 2 a,- 2 X2
... x . '-
« Fr«sh Food s«ction Ctlei , ' '' . • ,'
M :- 544S.65 - USMV.O "-—-niTTximi:! * 2 XI - 2 X2)
Ao :• (26.5* 2X1) (22.1 + 2 XI)
» 2 (26.5 » 2 XI) (5dr - 8'640
.(26.S * 2 XI - 2 X2) (22.1 + 2 XI - 2 X2>
- .•-••' ' i - -
XI)
-•• S' -^—^"- T^ ^_r «a»=?^s»==3EKSB*— . -*• >- • ^" • -.• - Tj^ , , - j-
.^•™t^ ^.^T ^^^T"''" '• -^-i- '
i / ".{j^gissiiii^^if.*j:25^"t3Ks&i^"i'' ^ '-'*/'• viw-;"".'.
il^flj^^^^^U'iaBsSK^^;"^^^'^" •-^-"Si^lJu:;?'" :'^- '
^'^"r-A-^-w-
, - 2,^ , . . .
<2i.5 + 2 XI)
(SO - l«40
,_ ,. XI)
(26.5'.'+, 2 XI - 2 X21 (2J.1 » 2 XI - 2 X2)
» 2
(2J.1 » 2 XI)
(50 - l«40 -
(26.5 » 2 XI - 2 X2> (22.1 * 2 XI - 2 X2)
• a ' ;,
k (544S.«S - I3MOII.O
: » 144.0000000
r * 2 » - 2 X2.
-------
U6.5 - 2 XI - 2 X2! ;22.1 - 2 XI - 2 X2;
'I / (97.9591837: ' •'
1 / (126.5 » 2 «) (22.: - 2 XI!
« 2 •'
(26.5 <• 2 XI) . ' '
(50 - 8640 _-—-—--—-—---^ 2,x: . 2 X2)
* 2 ' '
(22.1 » .2 XI) '• - • .
(50 - 8640 r2~"^~2~X271~(22~"»"2"xT""~X2r * X"'
XI , '
* ' ~ . , 1 • . ' ___ .
K (5445.65 - 839808.0 "(~~~"xT"r2~~"22~~2~xl~~2 X2I
. 144.0000006
1
5445.65 -
2.1 * 2 XI - 2 X2)
»5
1 / (97.9S91S371
1 / ((26. 5 » 2 XI) (22. l' + 2 XI)
* 2
(26.5 * 2 XI)-
(1640
—. * X2)
(26.5 » 2 XI -"2 X2) (22.1 » 2 XI - 2 X2) •
tr '•'''"'
(22.1 » 2 Xl) • . •
— * X2))
U6Ts « 2 XI - 2 X2) (22.1 » 2 XI - 2 X2)
X2 ', ' ' '
' * • • ''
•/ ((26.5 » 2 XI - 2 X2) (22.1 » 2 XI - 2 X2)
'l
1'7280 -
22.1 » 2 XI - 2 X2
v 17280 '
26.5 » 2 XI - 2 X2
+'144.0000000
. " l / 1(26.5 » 2 n - 2 X2JJ22.1 » 2 n - 2 X2)
172*0
22.1 + 2 XI - 2 X2
.» 17210 -•
26.5 « 2 XI - 2 X2
-------
' •9T.9S9183"! '" • . ,
1 / -1(26.5 - 2 .XI) (22.'l • 2 )CI
*• 2 "
/ (26. 5 "• 2 XI!
"
• ______
,50 - 8640 ----s ^ ^ ^ _. 2
2
.(22.1 » 2 XI)
(50 .- 8640
,26.5 - 2 XI - 2 XZ) M22.1 » 2 XI - 2 «)
- n ' '
144.0060000
MTT :- 26.5 *,2 XI
OFT :• 22.1 * 2, *1
XI - 2 X2)
WT :- 26.5 * 2;Xl
DT :- 22.1 » 2 XI
t Iniui«ion Volu
VIF ':- • :
K26.S « 2 XI) (22.1 * 2 XI)
. »-«•,» * 2 XI)
-* X2)
VI :-
2«.S +'2' XI) (22.1.*"2
* 2 ' .;' '
.s * 2 ni
* 2'
(22.1 » 2 «>.. (50 -
» 2 XI - 2 X2> (22.1 + 2 XI - 2 X2)
— «• XI)
XI
-------
T.T . - '
:i.; - ; x:, :;.: • 2 x:.
.'• . 'ZS.5 • 2 XI - 2 X2i :22.; • 2 Xi - 2 X2 .
- • • . i ' ' • • '.' '
, i26."5 • 2 X: - 2 X2) 122.': - 2 XI - 2 X2)
X2 .
» ((26.5 » 2 XI) (22.1 • 2 X:i . . '
» 2
(2€.5 - 2 XI)
I
(SO - 8640
(26.5.- 2 XI - 2 X2> (22.1 . 2 XI - 2 X2)
* 2
(22.1 » 2 XI) .
(50 - 8640 • X' ) I
(26.5 » 2 XI -. 2 X2) (22.1 ? -2 XI - 2 X2)
»h«ac lost p«r cuslc -incn of in*ul*tion
ratl :- ...
»5 • ' .
!-• (97.95918371 .1
1 / (126.5 * 2 XI) '(22.1 t 2 XI).
* 2
(26.5 • 2 XI) -
(26.5 » 2 XI - 2 X2) (22.1 - 2 XI - 2 X2)
' » 2 '
(22.1 * 2 XI)
1
(22.1 + 2 XI - 2 X21
' • • . • 1 ' . •• 1
» 17280 ————— — » 17280
22.1 » 2 XI - 2 X2 26.5 » 2 XI - 2 X2
. / I(2«.S » 2 XI) (22.1 + 2 XI) ' ' ,
* 2 • . ' .
(26. S » 2 XI) ' •
.•'.'. 1 ' - '
, . (8640
(26.5 » 2 XI - 2 X2) (22.1 » 2 XI - 2 X2)
2 '
(22.1 » 2 XI)
,' 1
' Op«o-«r««d Proa«m -116
April 1994
-------
|2«:'5'. 2 XI - 2 X2) (22.1 * 2 XI - 2 X2)
52
1 / (97.95911371
" 1 / ((26.5:» 2 XI) 122.1 » 5 XI)
* 2 •
' (26.5'» 2 XI)
(50 - «640 -(2^s + j xi . 2 X2) <22.1~+ 2 XI - 2 X2?,
(22.1 + 2 XI)
' (50 - »«40
' (26.5 +;2 XI- 2 X2) (22-1 « 2 XI - 2'x2)
* XI) )
(5445-65 - I3MO..O
144.0000000
_ 2
5445.«5 - M9«Ot.O
. 1
(26.5 + 2 XI - 2 X2) (22.1 « 2 XI - 2 X2)
i ' ' •
I «2«.5 » 2 XI) (22.1 + 2 XI)
..' '+ 2 / ,
(28.5 + 2 XI)
., ••• 1
-------
Cf :- 9C
2S5 . 2 XI - 2 X2! 122.: - 2 XI - 2 X2!
- 1.1100 X2
JG :- 11.13140 - 1257.9940
(26.5 - 2 XI - 2 X2I (22.1 • 2 XI - 2 X2I
""" (26.5 , 2 XI - 2 X2) (22.1 » 2 XI - 2 X2>
• 1.1700 XI - 1.8700 X2
85 . _ ' , ' .'
' 1 / (97.95918371 '
1 / ((26.5 r 2 XI) (22.1 - .2 XI)
(26.5 * 2 XI)
• (»«40 -
X2I
(26.5 » 2 XI - 2 X2) (22.1 + 2 XI - 2 X2)
• 2
(22.1 » 2 XI)
1
,8640 ---- " ------------------------ » x21 '
(26.5 « 2 XI - 2 X2) (22.1 » 2 XI - 2 X2>
X2 ' '
1 *
/ ((26.5 * 2 XI - 2 X2) (22.1 * 2 XI - 2 X2)
17210"
22.1 * 2 XI - 2 X2 • 2«.S * 2 n - 2 X2
» 14*.000000«,' ;'• ' ^'' : ' ''
: 1 / <(2fr.S>* 2 XI -"?«) (22.1 » 2 XI - 2 X2)
.-"••' • t ' . • i: " .
1 , 172I'0; --— '• " " » 17210 -—-———-——
, ^ 22>1 » 2 XI - 2 X2 2«.S- » 2 «: - 2-X2
5? * , ' ' .'.'"'.•
1 / (97.95*11371 - '. '
1 /-((26.S r 2 XI) (22.1 » 2 XI) . '
+ 2
(2«.S « 2 XI)
Prooi«m • 118
April 199*
-------
(50 - 8640 —-
X2K-(22.1 - 2 XI - 2 «)
(22.1 » 2 XI)
,(50•- 8640
(2«.5 » 2 XI - 2 X2! (22.1 * 2 XI - 2 X2)
XI
XI) )
(5445.65- - 839«Oi.O -.----_— _
* U4..0000000
5445.65 - 8398011.0
i '
126.5 » 2 XI - 2 X2) (2-2.1 <• 2 XI - 2 X2)
1-
.6820.4160 -__-—-—
- 1.8700 XI - 1.8700 X2 ,
» R-4 :n*ul»tion . - , ,
it':- .001736111111 • • _ ...
z :- .6665792S42
.* .35.91590
12
13
t4
- 279.015693S
- 393.79*7232
- 720.3914991
- 1491.701M*
- 210S.3SS79T
^•""^"^^S^^iK^^Si^wf, "
i :- i.arwasii-' '^ "."- ^•v'ili^^^^"'^:'--. 'rf'r'i-.-JS
. ..„-., ,:-3Ss»sns-. •*, .CT»"-^E"«s->--:^?SS. -'- ".-..•• -j--jf^ -KS2S.
*a :- m.342«i7 ' ' , _r..^-;=~T;_...- ' ;^;,s^- ' /V-'-1;:^- .. '
13 :- 254.9102«22
14 :- 4I0.9S11HO
15 :- 3125.055392
t« :- 442i.l432i3
t7 :- 75S1.19»i7J
-------
, !,,:! 11, "Tl *f. .Wi'H, '
-ci^6iiuii, 1.3, i. 271043531. 179.342*211, 254. 0102622, «»o.9sii9so,
3125.555392, 442S. 143283, 7551.198S7S
t :- 1.869310500 ' ,
:2
t3
H
15
tt
t?
. 186.8892218
- 367.''500475
- 4970.647430
6974.622046
- 11945.26948
.301736111111, 1.5. l.MWWSOO. 133.1915083, 18S.8I92218, 3i7.700047S,
«97S.«4"'430, 6974.S2204S, 11945. J694«
Op«n-«nd«s Proottm • 120
. April.'994
------- |