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TABLE OF CONTENTS
Page
Part I: Pollution Prevention for Resource Protection 1
Part II: True Tales of Technical Assistance 21
Part III: Policy Considerations 61
Part IV: Appendices 78
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The Mernmack Project was funded by a grant by the U.S. EPA's Industrial Pollution Prevention
Projec (IP3) and earned out by the Massachusetts Office of Technical Assistance for ToxLs Us"
Reduction and the New Hampshire Department of Environmental Services
Project personnel:
U.S. EPA, Washington D.C.: Jim Lund
U.S. EPA Region I: Bart Hague, Anthony DePalma, Joseph Canzano
MA OTA: Richard Reibstein, Cynthia Barakatt, George Frantz, Ken Soltys, John Flynn, Marina
Gayle, Julie Bolton, Anne Reynolds, William McGowan, William Griffin, Lori Thayer
NH DES: Chris Simmers, Stephanie D'Agostino, Paul Lockwood, Vince Perelli
Authors: Richard Reibstein, Stephanie D'Agostino, Cynthia Barakatt
Editors: Barbara Kelley, George Frantz, Chris Simmers, OTA and NHDES staff.
Thanks are due to the publicly-owned sewage treatment officials in the Merrimack Watershed
the Massachusetts Department of Environmental Protection, the Toxics Use Reduction Institute
at the University of Massachusetts at Lowell, and the many companies who worked cooperatively
with agency personnel in a joint effort to reduce pollution at the source.
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THE MERRIMACK PROJECT
A cooperative effort of
The United States Environmental Protection Agency
The Commonwealth of Massachusetts
The State of New Hampshire
MAY 1995
Parti
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THE MERRIMACK PROJECT:
Pollution Prevention for Resource Protection
Introduction
The Merrimack River Industrial Pollution Prevention Project (Merrimack Project), is one element
of the multi-faceted Merrimack River Initiative to restore, protect and enhance the water qualitv
of the river, and is also part of EPA's Industrial Pollution Prevention Project (IP3) which seeks
to incorporate pollution prevention into the national effluent guidelines development process and
to promote a pollution prevention ethic in business.
Through a $120,000 grant each to Massachusetts and New Hampshire, the IP3 program helped
finance pollution prevention assistance programs by both states, specifically in the Merrimack
River Watershed.
As a result of the technical assistance programs, eight companies in the Merrimack River
^ra^ eliminated more than 700,000 pounds of pollutants, and 12 companies reported savings
ol M.I million. An additional two companies reported eliminating 1 million pounds of pollution
on their own, and an additional six companies reported annual savings of $750 000 More than
one hundred people from the business commmunity joined a government-sponsored Business
Environmental Network, originally formed for the Merrimack region, but now incorporated as
the Northeast Business Environmental Network (NBEN) in order to open membership to a wider
population. NBEN members meet regularly to review environmental requirements and pollution
prevention opportunities, and hold public events to educate all businesses. The mission statement
of the network explicitly affirms the union of environmental and economic interests NBEN has
been awarded three grants that affirm its value as a model of a nonpartisan forum: one from the
Massachusetts Manufacturing Partnership, to provide administrative support; and two from EPA
New England's Merrimack River Initiative, to establish an electronic P2 and environmental
requirement information network, and to conduct a business/government dialogue on Regulator
Improvement Opportunities (RIO - see appendix for proceedings of the first meeting).
These successes are the result of collaboration between business, government and non-profit
organizations, and between various sectors of government - most importantly, between two states
The project shows that the preventive approach can directly enhance economic viability.
The joint work by the two states and the EPA demonstrates that jurisdictional divisions do not
prevent cooperative work to protect regional resources. It is also an example of an application
of the watershed approach. The project introduced the watershed concept to many businesses that
are now incorporating it into their approach to environmental responsibility "
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The Merrimack River Watershed
The Merrimack River watershed encompasses 5,010 square miles including the mainstem and its
many tributaries. The headwaters of the Merrimack River start in the White Mountains of New
Hampshire and flow 180 miles to empty into the Atlantic Ocean at Newburyport, Massachusetts.
The watershed represents approximately 33 percent of the land area in New Hampshire,
approximately 15 percent of the land area in Massachusetts, and includes all or portions of 200
communities. The Merrimack runs through remote National Forest areas, rural towns, urban
areas, and is a resource of great regional significance. It provides drinking water for more than
300,000 people and is also used for recreation, fish and wildlife habitat, irrigation, waste
assimilation, power production and scenic enjoyment. It is one of the major "veins" of the New
England region. The lower Merrimack region, which includes much of southern New Hampshire
and portions of northeastern Massachusetts, is highly industrialized.
The Merrimack River was once considered one of the nation's dirtiest waterways. Contamination
from raw sewage and untreated industrial waste rendered the river unusable for fishing, drinking
or recreation. In the past 20 years many of the most obvious pollution sources have been
addressed. The Merrimack can now be used for fishing and boating, and much of the river is
used, after treatment, for drinking water.
Background
When EPA's IP3 awarded the grants to Massachusetts and New Hampshire in 1991, both states
had already adopted pollution prevention as an overall priority, and in both states small programs
to promote pollution prevention had already had some success. Massachusetts had passed a
Toxics Use Reduction Act (TURA) and established within the Executive Office of Environmental
Affairs the Office of Technical Assistance for Toxics Use Reduction (OTA), a nonregulatory
office with a legislative mandate to provide confidentiality to the businesses to which it provides
assistance. New Hampshire had established the NH Pollution Prevention Program (NHPPP)
within the Waste Management Division of the Department of Environmental Services.
Both programs had already been visiting businesses, reviewing the processes which result in
wastewater discharges, air emissions, waste shipments, or other pollution, and recommending
opportunities for preventing the identified problems. Both programs had already begun to build
up information on new technologies for pollution prevention and to share the information by
holding workshops and conferences, by making presentations at public events, and by
publications, particularly case studies. Both programs offered their assistance with no charge to
the user, and on a confidential basis.
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Summary of Results
Since the project began, use of technical assistance services has increased as a result of many
factors, including more than 100 public events to explain pollution prevention practices, and the
institution of referrals from enforcement agencies. For example, the Massachusetts program
performed 21 visits in 1991 and 162 visits in 1993. By the end of 1994 OTA had made more
than 450 visits. The increase suggests that the provision of technical assistance for pollution
prevention is useful to businesses.
Sixty-two companies in the Merrimack watershed have been visited, and data has been gathered
concerning 49 companies. Data was obtained from some of these companies on pounds of toxic
materials eliminated and money saved. (See Table of Results on page 57.)
Pounds Eliminated
Many companies did not perform assessments of pollutants eliminated by pollution prevention,
but some did.
Ten companies reported pounds of toxic materials eliminated, totalling 1.72 million
pounds. Eight of those companies accomplished pollution prevention in connection with
state technical assistance, eliminating 717,000 pounds.
Money Saved
Eighteen facilities reported annual savings of $1.85 million that are already accruing.
This is an average savings of $102,610 per company.
In determining how much was attributable to state assistance, only those companies were counted
where the state was a significant causative factor in P2 implementation.
Twelve companies that could be characterized as having acted at the inspiration or with
the significant help of the state reported savings of $1.1 million.
These estimates are very conservative. If a company reported "thousands" or "hundreds of
thousands" of dollars saved, we have totalled only $1,000 or $100,000 respectively. Very few
companies performed an assessment of total costs and benefits. Typically, the data refers only
to reduced purchase or waste disposal costs, and in the majority of reports does not reflect other
savings, such as permit fees avoided, gains in efficiency, reduced liability, reduced penalties,
reduced compliance or safety costs, etc. We have not used net present value, expected savings^
or the value of avoided enforcement action, nor have we assessed the cumulative effect of annual
savings over a period of years. The following figures represent, as closely as we could
determine, savings after payback of any project investment.
Some of the companies have had active programs for several years and have been accruing
savings from pollution prevention for some time. Savings from pollutants that have been
eliminated recur annually, therefore the worth of these projects will continuously increase over
time. It should also be noted that certain materials, such as ozone depleting chemicals, have been
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steadily rising in cost, a factor which over time accelerates the increase in the value of any
program that has eliminated or reduced the use of the material. (Note Company #2 in the Table
of Results).
P2 Implementation Rate
Out of 46 companies that were provided with pollution prevention information and are still in
business, 30 accomplished significant P2 in that they changed their processes or materials, came
into compliance, saved significant money, eliminated a sizeable amount of pollution, or
established a strong ongoing program. Four companies had minor accomplishments. We had
insufficient data for 8 companies, and included in that category companies that claimed to be
reviewing our recommendations but had nothing as yet to report. When our attempts to follow
up resulted in a lack of returned phone calls, and the company had not seemed appreciative of
the recommendations made, we counted these as not accomplishing any P2.
The true performance rate can be captured only by stating a range. If we assume the 8
companies for which we obtained insufficient data to show P2 accomplishments have in fact
accomplished no pollution prevention, and do not count minor P2 accomplishments, we have a
65% rate of substantial P2 performance. If we count the minor P2 accomplishments we have a
rate of 74%. If we assume that the eight unknowns did undertake P2, and count the minor
accomplishments, we have a rate of 91%. The P2 performance rate is within the range 65 -
91%.
It is interesting to note that out of 11 companies that had already accomplished P2 on their own
before being visited by a technical assistance program, 7 agreed to share information with other
companies.
In order to obtain a picture of the effectiveness of the assistance programs, we examined the rate
of implementation among those that had not already performed P2 on their own - 35 companies.
A true recommendation implementation rate, which would assess the use of each specific
recommendation made by state technical assistance staff, could not be obtained. It is reasonable
to give state technical assistance credit for influencing 66% - 23 companies - to accomplish P2.
If we do not count the four companies that accomplished only minor P2, we have a rate of 54%.
This 54 - 66% range illustrates the low end, because it assumes that none of the unknowns
performed P2. If we assume that they did, we have a range of 77 - 89%. Therefore the
percentage of companies accomplishing substantial P2 as a result of technical assistance is
within the range 54 - 77%. The percentage of companies implementing technical assistance
program recommendations and accomplishing some P2 is within the range 66- 89%.
Unqualified accomplishments
Some of the companies achieved P2 but did not produce data on money saved or pounds
eliminated. These companies included:
A machine shop that ceased wastewater discharges with vacuum distillation
A manufacturer that reduced water use 87%, drummed waste 40%
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A semiconductor company that is investigating a closed loop process
Four electronic components manufacturers that eliminated TCA
Two facilities that eliminated nuisance odors
Several companies improved compliance, for example by establishing proper hazardous waste
storage practices, and some companies established ongoing pollution prevention programs.
It must be recognized that at the beginning of the project NH staff had a difficult time convincing
companies that it was safe to consult with them. Companies often expressed wariness due to the
location of the technical assistance program within the state's regulatory agency The fact that
New Hampshire's technical assistance personnel convinced 14 companies to let them come on
site was therefore a substantial accomplishment. New Hampshire's follow-up resulted in a vast
majority of companies that worked with the NHPPP stating that they were very pleased with the
service given to them and that they would not hesitate to call on the program again or
recommend the program to other businesses.
Other accomplishments of the project include:
The two states jointly performed technical assistance on a number of visits.
The two states jointly conducted a series of industry specific workshops.
The two states together held two major conferences: an outdoor (under a tent)
Environmental Overview conference on a bluff overlooking the Merrimack River and a
Clean Air Act conference in Lowell (both also sponsored by the Merrimack Business
Environmental Network).
New Hampshire established a clearinghouse of information on new technologies pollution
prevention products and vendors, fact sheets, and case studies and made it available to
business and industry. New Hampshire provided written technical information to several
hundred Merrimack Valley companies.
New Hampshire held a Solvents Bazaar in Manchester, at which 55 companies had the
opportunity to bring parts needing cleaning to be cleaned by alternative products- a
Pollution Prevention conference in 1993, attended by 45 Merrimack Valley companies-
and a Pollution Prevention conference in 1994, attended by 58 Merrimack Vallev
companies. J
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The Business Environmental Network: forming a lasting commitment to P2. and improving
relations between government and industry.
As part of the Merrimack project, OTA and NHDES formed a Merrimack Business
Environmental Network (MBEN), an ongoing forum of businesses committed to pollution
prevention, to environmental compliance, to interacting with government agencies, and to mutual
self-help. In the first year of the project, OTA and NHPPP sponsored P2 conferences for local
businesses. After the formation of MBEN, public events were conducted with the joint
sponsorship of MBEN members. This increased attendance at these events, and the identification
of pollution prevention as good business practice, not just government policy.
Presentations included AT&T engineers explaining how they substituted a food-grade material
for ozone depleting cleaners, how a large dry-cleaning establishment (Anton's) adopted low-
polluting dry-cleaning technologies, how a stain manufacturer (Cabot's) adopted efficient liquid
transfer and storage practices and low-waste pipe cleaning, and several other company stories of
how pollution prevention had benefitted the bottom line. This was the culmination of a project
goal of finding the "stars" who had already accomplished pollution prevention, and persuading
them to share their stories. See attached article.
MBEN generated a good deal of interest in other regions, who sent in requests for information
on how to create similar organizations. To enable the network to reach a larger audience, OTA
incorporated the network as the Northeast Business Environmental Network in September, 1994.
The enthusiastic participation of businesses in MBEN, now NBEN, accomplishes the project's
basic purpose: to form a continuing, collaborative, working commitment to pollution prevention
by relevant parties. It was made possible by work performed in three distinct parts:
1. Working with public sewage treatment facilities
2. Working with businesses
3. Coordination of technical assistance and regulatory programs.
The work performed by the Merrimack Project in each of these three areas is described in the
next 12 pages of this report.
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Working With Sewage Treatment Facilities
New Hampshire and Massachusetts began their Merrimack project work by meeting with sewage
treatment officials and discussing problem areas.
NH focused its work on the Franklin treatment facility because it is owned and operated by the
state, and on the Nashua facility because it has a large base of industrial users.
OTA met with the five major mainstem Publicly Owned Treatment Works (POTWs) in
Massachusetts. OTA had already worked with POTWs through an organization called the
Massachusetts Pretreatment Forum, a self-help group of pretreatment coordinators from across
the state. (This work had already introduced OTA to some of the POTW officials and was the
foundation on which the Merrimack Project was developed).
The facility personnel in both states, commenting that most industries that discharge to their
plants did not have any significant compliance problems, identified (1) non-regulated sources of
pollution such as nonpoint sources, households and small businesses; and (2) unpermitted
dischargers as problems that are largely unaddressed. Nashua staff reported problems with fats,
oil and grease (FOG), and MA staff also heard about FOG when visiting Newburyport, where
there are a lot of restaurants in town and there had been a series of costly incidents of grease
buildup. In particular, grease in the treatment system was causing the growth of odorous bacteria,
which led to a lot of complaints.
At a 1994 follow-up meeting with Massachusetts pretreatment coordinators, there was universal
concern about pollutants from water supply facilities. Two major concerns were cited:
Businesses complaining to POTWs about having to treat incoming water to meet discharge
limits.
Use by water supply facilities of zinc-containing chemicals for pH adjustment, leading to
high levels of zinc in incoming water.
Although there was a high degree of interest by treatment staff in addressing pollution from
sources other than the significant industrial users, the Merrimack Project maintained a focus on
industrial sources while attempting to address their concerns to some degree. Analyses of permit
lists and business directories were performed to determine the industrial categories appropriate
for targetting in each area. POTWs helped select topics of concern.
Public workshops were then organized in the POTW communities. Massachusetts and New
Hampshire staff worked together and companies from both states amended. With the Greater
Lawrence Sanitary District, the two states conducted a workshop on pollution prevention for
electroplating companies. With Haverhill, the two states conducted a workshop on pollution
prevention in machine shop operations. With Lowell, and with the Toxics Use Reduction
Institute at the University of Massachusetts at Lowell, OTA and NH conducted a workshop on
pollution prevention for the printed circuit board industry. With Amesbury, OTA conducted a
workshop on water conservation. With Newburyport, OTA conducted two workshops on
reduction of fats, oils and grease from restaurants.
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Results
Officials at all of the above named POTWs enthusiastically lent space, support, and time to the
conduct of public educational activities. They all saw the holding of public events intended to
disseminate P2 information as furthering their mission of protecting water resources. All POTW
officials involved in the project supported the concept of assistance to the regulated public.
Several POTW officials commented that they valued their ability to create and maintain ongoing
relationships with the companies under their authority. They expressed a wish to help their
neighbors survive economically as well as comply with environmental requirements. The POTW
officials valued the opportunity to increase public understanding of the place of the POTW in
their community, and particularly the fact that increased expenses or savings at the POTW would
affect the entire community.
Some of the POTWs have continued the practice of holding public events to educate their
dischargers, and requests have come in from other POTWs in the state to conduct similar events.
The Lowell, Greater Lawrence, Newburyport and Haverhill facilities have continued the practice
of conducting public events.
Training
A significant outcome of the meetings with treatment facilities staff were the partnerships that
were established and/or strengthened. As a result of the newly created partnerships, DBS staff
were asked to provide a pollution prevention training session at the Franklin treatment plant's
annual workshop for industrial users. Similarly, Rick Seymour, the Nashua Pretreatment
Coordinator, arranged for DBS pollution prevention staff to provide a half-day training session
for the NH Association of Pretreatment Coordinators. Both sessions were well attended and
considered to be very successful.
OTA in the spring of 1992 conducted P2 training for POTW officials in Massachusetts, New
Hampshire, and Maine, through the New England Interstate Environmental Training Center. This
training consisted of explanation of the basic concepts of P2, a discussion of the Massachusetts
Blackstone project, which pioneered cross media enforcement and referrals for technical
assistance, and a participatory "P2 training exercise", where officials brainstormed process change
responses to identified pollution problems.
Referrals
POTW officials began referring companies for technical assistance. Greater Lawrence Sanitary
District responded vigorously, even going out on site visits with OTA and NH. Since 1991, the
other POTWs have also referred companies to OTA (the origin of each request is not always a
matter of easy determination) - about one half of company visits originated from POTW referrals.
(There are often a number of events which stimulate a company to seek technical assistance.
These included attendance at a workshop, telephone assistance, reading an article by or about the
program, word of mouth from a company that has received useful help, or encouragement by
DEP or DBS inspectors, as well as the POTW, to call).
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Innovations
The Project discovered that Louis Vallee of the Newburyport facility has been able to obtain,
simply by request, information on chemical purchases from certain facilities. The requirement
that chemicals brought on site be reported to the facility has been written into certain permits.
When told of this, other treatment facility staff commented that he could not ask for this
information because it was not required by law, and companies would challenge it in court.
The Greater Lawrence Sanitary District's 1993 Annual Report notes that it has now added
pollution prevention questions to its full inspection forms. (Other POTWs have stated they will
not ask for any information that the company does not have to provide. There have been many
comments made during the Project concerning political pressures on POTWs, constricting what
they may do).
NHDES is currently working on a project which involves development of a model sewer use
ordinance which incorporates pollution prevention. As part of a review team led by the DBS
Industrial Pretreatment Coordinator, the Merrimack Project coordinator will comment on the draft
ordinance and other documents developed under this project. The model ordinance will be a
useful tool for communities in the Merrimack watershed as well as other areas seeking to enhance
pollution prevention efforts at the local level.
Improved relations with sister agencies
At the beginning of this project, it was clear that there were several contentious issues between
Massachusetts POTW officials and the DEP, and there was a distinct lack of communication
between them. Credit for improving this relationship is due to proactive efforts on both sides;
the POTWs have actively sought to address the outstanding issues, and DEP has responded by
detailing officials to meet with the treatment facilities. Project work must also be considered to
have played a role in linking the authorities. Improved relationships between industrial
pretreatment coordinators at the New Hampshire plants and NHDES have also markedly
improved as a result of the project.
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Working With Businesses
The Business Environmental Network
The series of workshops with POTWs consisted largely of presentations by businesses in the area
that had already accomplished pollution elimination by preventive measures. Because so many
businesses were willing to share information with each, OTA and NH decided to establish an
ongoing organization dedicated to technology and environmental information transfer. This
organization was the Merrimack Business Environmental Network, which has now become the
Northeast Business Environmental Network, with a Merrimack Watershed chapter. One of the
purposes of the organization was to change the focus of the delivery of pollution prevention
information, so that it would come from business, not just government.
MBEN conducted monthly meetings for its members, at most of which there have been
presentations or discussions of environmental requirements and P2. MBEN, with OTA and NH,
sponsored two major regional conferences, both of which garnered attendance of about 100.
There were about 30 committed, active members of MBEN from the business community, who
came regularly to all MBEN meetings, and more than 80 registered as members, who came
principally to MBEN conferences. Members signed the mission statement, which reads as
follows:
The Merrimack Business Environmental Network is a coalition of businesses,
agencies and associations which is committed to a shared concern for the Merrimack
Valley, its rivers, and the Valley's quality of life. This Association has made a long-term
commitment to seek and implement solutions to promote pollution prevention through
improved management and technology, while enhancing the economic viability of the
business community.
In order to emphasize the connection with the resource to be protected, MBEN's first conference
was held at Maudslay State Park in Newburyport, MA on a bluff overlooking a broad expanse
of the river. The conference consisted of presentations by government officials concerning
regulatory requirements and breakout sessions for company case studies of P2. MBEN members
explained how they had reduced waste, air pollution, water discharges, and increased worker
safety, profitability, and quality. The conference was a visible demonstration by area businesses
to area businesses of the viability of P2, and was thus different from the first series of POTW-
sponsored workshops, which although also effective and also incorporating business presenters,
were more readily identifiable as government agency product.
The second MBEN conference consisted largely of information to assist businesses in compliance
with the Clean Air Act, and the majority of the presenters were from government. The topic and
approach was the decision of MBEN members, and the conference demonstrated that TAPs and
BENs can serve as conduits for regulatory information. Evaluation forms indicated that attendees
found the conferences to be highly useful.
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Publicity about the MBEN conferences led to calls from other watersheds and states, a mention
in Pollution Engineering and an invitation to write about MBEN for the Pollution Prevention
Review. (See attached article).
OTA has been asked by Salem Sound 2000 and the Nashua River Watershed Association to assist
with the formation of similar groups. In response to the interest by parties outside of the
watershed, MBEN has voted to change its name to Northeast Business Environmental Network,
Merrimack Chapter. Bylaws for NBEN stressed the nonpartisan nature of the group and
prohibited it from engaging in political lobbying. NBEN has sponsored several conferences on
environmental compliance and pollution prevention, focusing in 1994 on the Clean Air Act and
emergency response, and in 1995 on providing opportunities for businesses and government to
work together on regulatory improvement.
With EPA's Merrimack River Initiative funding, NBEN held a half-day discussion on Regulatory
Improvement Opportunities. Seven thousand businesses from Massachusetts and New Hampshire
were invited in a letter co-signed by EPA New England Administrator John De Villars,
Massachusetts Secretary of the Environment Trudy Coxe, New Hampshire Department of
Environmental Services Commissioner Robert Varney, and Massachusetts Department of
Environmental Protection Acting Commissioner Tom Powers. NBEN chair Gabriel Paci, CEO
of Raffi & Swanson, a Wilmington, MA coatings manufacturer, explained to 100 attendees that
the purpose of RIO was to enhance discussion, not vent frustration. He urged those participating
to work to understand each other's point of view: the missions of and constraints on government
employees, and the costs and practical effects of requirements on businesses. Breakout sessions
facilitated by NBEN, and employees of EPA and UMass Lowell's Toxics Use Reduction Institute
were also run on established ground rules of mutual respect and constructive discussion. Quite
positive evaluations of the event affirmed the value of NBEN's nonpartisan approach both to
those who came to complain and those who came to defend.
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Coordination With Regulatory Programs
Both Massachusetts and New Hampshire provided an understanding of pollution prevention
concepts and activities to pretreatment coordinators at sewage treatment facilities, and to other
environmental officials, and increased the coordination between technical assistance and
enforcement.
Both states have included efforts (which are ongoing) to identify opportunities and barriers to
incorporating pollution prevention into the work of regulatory agencies, and have used the project
as a pilot to test new initiatives.
New Hampshire does not have a toxics use reduction law, nor mandatory facility P2 planning.
The absence of this incentive, and the associated revenues, has made for significant differences
in the focus of the two programs. New Hampshire's approach focused on using existing
resources. New Hampshire took the fact that technical assistance came out of a regulatory
program, and the opportunity to do the Merrimack Project to enhance efforts to incorporate P2
into the way business is done. New Hampshire established a Multi-media Pollution Prevention
Task Force as a forum for discussion on how to incorporate prevention into a regulatory agency.
OTA adopted the strategy of establishing training exchanges and referrals with DEP. At the same
time, DEP has made waste prevention a top priority and has reorganized to reflect this. The
agency now makes multi-media inspections, and its FIRST program (Facility Inspections to
Reduce the Source of Toxics) is only one of many program innovations that are an expression
of the agency's commitment to the priority of toxics use reduction.
Massachusetts
Introductory Training
OTA has introduced the concepts both of technical assistance and of pollution prevention to
enforcement officials of many agencies. The office has assisted with P2 training for EPA
inspectors and managers, for DEP inspectors and managers, for POTW pretreatment coordinators,
for board of health agents, and for audiences made up of regulatory officials of various kinds and
authorities.
When technical assistance for pollution prevention was first presented to enforcement officials,
some had adverse reactions. One reaction was to assume that resources would be diverted from
enforcement to technical assistance, or that enforcement would somehow be diminished. OTA
attempted to counter this assumption by contending that nothing about the establishment of
technical assistance necessitates either result, and by affirming that enforcement is the most
important reason for companies to seek and utilize technical assistance, and do P2.
Another adverse reaction was that the touting of prevention could seem to mean a denigration of
control. OTA attempted to counter this unintended effect by pointing out that although the
hierarchy meant prevention should be exercised first and foremost, it must be recognized that
when it is not implemented, recycling, treatment, or other management of wastes already
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generated is still preferable to other alternatives. It has been necessary to affirm on many
occasions that pollution reduction is a desirable activity, even if it is not prevention.
Enforcement staff were also concerned that if inspectors made suggestions concerning pollution
prevention activities, that companies would interpret these suggestions as commands. Comments
that inspectors did not understand industrial processes well enough to make competent
recommendations were also frequently heard.
OTA's recommendations were that inspectors could refer companies to a technical assistance
agency for specific help, while talking about pollution prevention in general, to indicate the
priority the agency places on the approach. OTA also recommended that inspectors can adopt
the strategy of asking questions in lieu of making commands, because asking questions:
* is a non-directive method of illuminating P2 opportunities and pointing a company
in the right direction, or discovering worthwhile avenues of investigation
* denotes respect for the regulated company and can enhance the relationship
between the company and the regulator.
Most importantly, dialogue concerning process educates the inspector, which can only improve
regulatory practices.
The relationship of enforcement and technical assistance
In its presentations and in many meetings with enforcement officials to work out policy
concerning the interaction of enforcement and technical assistance, OTA has stressed two points:
* confidentiality must be assured or companies will not feel safe consulting with a
government agency
* continued strong enforcement is of paramount importance, because it is a major
motivator for doing P2, or for seeking technical assistance.
Another important point of discussion has concerned the tailoring of enforcement strategies to
encourage prevention, such as waivers, extra time, penalty mitigation, or targetting. OTA
strongly supports the use of these measures. Staff have frequently worked with companies facing
short time-frames to address violations. Conventional end-of-the pipe control equipment is
readily available: to supplant the control strategy with a preventive technique may only be
possible if the company has the time for investigation and trial.
However, OTA has frequently expressed the opinion that flexibility should only be awarded based
on actual activities, investigations, or trial undertaken or attempted by a company, on need
demonstrablv related to P2 opportunities, and information must be obtained from the company
by the enforcement agency.
OTA has asked that enforcement officials not soften their stance based on the mere fact that
technical assistance has been sought or provided. This has become an important issue for OTA
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because staff have been made aware that some companies have received reduced scrutiny from
some inspectors simply because they are adopting a posture of seeking technical assistance or
investigating P2. Some inspectors have asked OTA for information on the company's progress,
and OTA has had to point out that absent consent from the company it is bound by law not to
provide that information, and some inspectors have expressed frustration with OTA as a result.
Continuous discussion of this has to some extent addressed this frustration, but it is clear that an
express policy as underlined above is necessary in order to avoid this problem.
Coordinated work with regulatory officials
Work with DEP has evolved from training to mutual exchange. OTA has been meeting with the
Northeast Region of DEP as part of DEP's FIRST (Facility Inspections to Reduce the Source of
Toxics) program to expand the Blackstone model of cross media inspections and technical
assistance referrals. OTA has delivered a series of seminars, and DEP conducts cross training
for OTA on DEP's regulations. OTA has long emphasized to its staff the importance of being
up to date on regulations.
The seminars have covered:
* P2 in general
* cleaning alternatives to solvents
* alternative finishing systems (low or no VOC painting and coatings such as powder
coatings, electrodeposition, and efficient paint transfer systems such as high volume,
low pressure spray)
* an overview of the problems posed for those planning P2 activities by restrictive
military specifications
* printing
* the requirements of TURA and form S reporting.
The OTA team has attended semimonthly inspection review meetings at DEP and has been asked
to comment at these meetings on how to recognize P2 opportunities and how to suggest them
during visits.
DEP now sends copies of all Notices of Noncompliance to OTA, and included in these notices
is language encouraging the recipient to contact OTA for help. Inspectors often recommend
OTA's services to companies. (See attachment).
Other Projects
Massachusetts has received an EPA grant to establish a permanent household hazardous waste
collection site in the Merrimack Region. As a result of months of exploration and discussion,
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OTA and the city of Haverhill have signed a contract to establish a permanent collection site for
used oil. Haverhill's POTW is part of the emergency response team, which identified the need
for the site in order to address a large number of annual responses to abandoned containers of
used oil.
Massachusetts has also received a grant to develop a self-audit checklist designed to promote P2
concepts. A draft version is attached.
New Hampshire
The P2 Task Force
In May of 1992 NHDES created a Pollution Prevention Task Force to serve as a forum to discuss
ways to incorporate pollution prevention directly into the daily workings of the relevant
regulatory and non-regulatory programs. The Task Force is made up of representatives from each
of the department's four Divisions; Air Resources, Water Resources, Waste Management, and
Water Supply and Pollution Control, as well as the Commissioner's Office. The Merrimack
Project Coordinator provides staff support to the Pollution Prevention Task Force.
The Task Force developed and adopted a statement of purpose and objectives:
Statement of Purpose
"To direct, coordinate, and promote strategies which prevent pollution of air, land, and
water. Such strategies include, but are not limited to: toxics use reduction, waste
reduction, and best management practices to conserve natural resources and protect human
health and the environment."
The Task Force also developed a common definition of pollution prevention, a statement of goals,
and a pollution prevention strategy to serve as a foundation for ongoing and future pollution
prevention initiatives. The definition and goals statement were adopted as agency policy by the
DBS Senior Management Team (See attachment).
Examination of regulatory activities
The Task Force developed model language incorporating pollution prevention into DBS Letters
of Deficiency (LOD) (see attachment). LODs are the mildest form of enforcement letter and are
sent out after an inspector has visited a site and noted minor violations. The Task force
undertook a survey to determine which types of LODs would be most appropriate for inclusion
of the new language: for example, the language would not be appropriate for letters regarding
failed septic systems, but would be appropriate for RCRA, Industrial Pretreatment, and Air LODs.
More intensive scrutiny in the coming months will be given to including pollution prevention in
permitting, and identifying appropriate targets for multi-media permitting and inspections.
Flexibility in Media Grants
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Early in 1993 the Task Force began working with DBS Assistant Commissioner John
Dabuliewicz to identify pollution prevention projects to incorporate into the department's ongoing
federal grants. Three projects were identified and subsequently approved by EPA. Two of the
projects were media specific (waste and water), and one was a multi-media effort.
In the water area DES staff initiated a flexibility project which involved piloting a new approach
to solving water quality problems. Instead of full compliance inspections for all major
dischargers, those facilities which have good compliance records are subject to much less
intensive inspections, which frees up staff time to deal with known water quality problems. These
water quality problems are being traced to their source(s) and then dealt with using a technical
assistance/pollution prevention approach.
The Hazardous Waste Compliance Program (HWCP) has also initiated a new type of inspection
known as a "partial inspection". This project involves targeting Small Quantity Generators
(SQGs) which have never been inspected. Instead of a full compliance inspection these SQGs
receive a partial inspection which involves a review of the physical conditions of the plant only.
Inspectors distribute pollution prevention literature and refer the plant personnel to the DES
Pollution Prevention Program for technical assistance. Prior to instituting this project the
Hazardous Waste Inspectors received a 1/2 day pollution prevention training session.
Two multi-media flexibility initiatives are being carried out by the Pollution Prevention Task
Force:
Regulatory barriers. This work involves identifying barriers or disincentives to pollution
prevention which exist in the department, and developing methods to address them.
Targeting. This work involves compiling information on compliance and technical
assistance efforts from air, water and waste programs, such as listings of "problematic"
industry types, processes, and chemicals; sensitive resource areas; and densely populated
geographic areas where there may be a particularly acute public health risk. The
inaccessibility and format of existing data on environmental quality and facilities has thus
far inhibited this effort. Researching how and where the media programs currently target
their efforts is an important part of identifying the best opportunities for protection of the
environment and public health.
Providing Pollution Prevention Technical Assistance
Currently, the NHPPP is the department's primary multi-media technical assistance program. The
Task Force is considering several models for integrating pollution prevention technical assistance
into a regulatory agency. Some of the models to be considered are outlined below:
- inspectors doing referrals: involves regulatory inspectors entering a facility, noting
opportunities for pollution prevention, and referring the facility to pollution prevention
staff;
- "super-inspector": involves regulatory inspectors who are trained in pollution prevention
technical assistance;
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- building pollution prevention into the compliance schedule: when a regulatory inspection
takes place and violations are noted, pollution prevention activities can be incorporated
directly into the compliance schedule;
- compliance audit: involves staff who visit a facility, note compliance problems and
opportunities for pollution prevention, and give the facility a period of time to incorporate
P2 measures into processes and procedures before an official regulatory inspection is
done.
It should be noted that a combination of one or more of the above models may also provide an
appropriate structure for providing technical assistance.
Staff Training Initiative
During implementation of the Merrimack Project it became evident to the Task Force that in
order to advance pollution prevention much work needs to be done in the areas of training,
education, and outreach. Institutionalizing a preventive approach in the Department is dependent
upon the cooperation and commitment of all DES employees. Such commitment can be fostered
through appropriate training activities.
The Task Force has recently initiated a Pollution Prevention Orientation Program for the
Department. A three hour introductory session on pollution prevention will be offered to all DES
staff, including clerical support staff, field/technical staff, laboratory staff, and administrators.
The purpose of the training will be to introduce staff to pollution prevention concepts; provide
updates on Task Force initiatives; and provide opportunities for staff to incorporate prevention
into their daily activities.
To date, there have been two pilot training sessions, one for RCRA inspectors, and the other for
senior management. Feedback on the sessions has been very positive. Training sessions will be
scheduled for all other staff when the Strategy is completed.
Biomonitoring Component
A unique aspect of the New Hampshire portion of the Merrimack Project was the biomonitoring
component. The science of biomonitoring focuses on measuring the health of an ecosystem by
sampling the type and abundance of certain "indicator" species which are present. In this case
macroinvertebrates (aquatic insects, worms, clams, etc.) were used. The purpose of biomonitoring
is to provide information on the actual conditions in the river which have developed over a period
of time. Ambient water quality sampling will give a "snap-shot" picture of water quality, but
biomonitoring can give a better evaluation of the actual impact that a discharge or other pollution
source(s) may have on an ecosystem over time. By initiating a biomonitoring program
information may be gathered on the condition of the river which will allow a comparison of
conditions before and after the implementation of pollution prevention activities.
In setting up the biomonitoring effort, project staff consulted with staff from the DES Biology
Bureau, and staff and volunteers from the Merrimack River Watershed Council (MRWC). The
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MWRC has a well-developed citizens monitoring program, and resources have been combined
in a joint effort.
Project staff are currently working with Biology Bureau staff to develop a biomonitoring plan for
the Merrimack which will be implemented this year, beginning with spring sampling events. It
is expected that the data that is gathered will be useful in measuring changes in the ecosystem
at a later date, due to the implementation of pollution prevention efforts.
Other Projects
NHDES has received an EPA grant to establish the state's first permanent household hazardous
waste (HHW) collection facility. The facility will be sited in the City of Nashua, one of the
largest cities in the Merrimack Valley, and will also involve setting up regulatory protocol for
accepting hazardous waste from small quantity generators (SQGs). The HHW Collection Center
will be available to the residents of Nashua and several surrounding communities. A pollution
prevention educational component is included as part of this project.
Through a grant from the U.S. EPA, NHPPP staff and other DES staff are working with the
University of New Hampshire, Chemical Engineering Program to develop an inter-disciplinary
pollution prevention curriculum. The goal of this project is to better prepare students to deal with
waste management and pollution issues when they enter the workforce. As part of the project,
graduate students from UNH will develop case studies which focus on New Hampshire facilities
which have successfully implemented specific pollution prevention activities.
Both states are working with the North East Waste Management Officials' Association to promote
pollution prevention activities by automobile service, repair, and maintenance facilities. New
Hampshire is organizing several workshops for auto-related businesses with the NH Automobile
Dealer's Association (NHADA) for May of 1994. The workshops will focus on multi-media
pollution prevention and environmental compliance.
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THE MERRIMACK PROJECT
TRUE TALES OF TECHNICAL ASSISTANCE
DESCRIPTIONS OF ON-SITE VISITS AND RESULTS
As of MAY 1994
Part II
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TRUE TALES OF TECHNICAL ASSISTANCE
Descriptions of Work Performed with Merrimack Companies
The following detailed descriptions of technical assistance provided to companies in the
Merrimack River watershed by the Massachusetts Office of Technical Assistance (OTA) and the
New Hampshire Department of Environmental Services are here presented in order to illustrate:
* the kinds of problems companies have and what they seek assistance for
* pollution prevention opportunities that are found in the field
* the kinds of recommendations that are made
* the kinds of activities companies actually do after receiving assistance.
It is hoped that these examples will be of assistance to anyone wishing to understand in detail
how a pollution prevention technical assistance program actually works.
As of April 1994, OTA and NH have made site visits at 62 companies in the region; 47
companies are discussed here. Two additional case studies are appended.
OTA delivers all of its services under a legislative requirement of confidentiality. NHDES also
promises confidentiality. The following descriptions of technical assistance work do not identify
the company or describe the company product sufficiently to allow identification. In some cases,
confidentiality has been waived. The technical assistance was provided by OTA's Northeast
Team, consisting of Team Leader Ken Soltys and engineers Marina Gayle and John Flynn. Some
case work was performed by previous OTA staffer Anne Reynolds, OTA's technical chief Bill
McGowan, and OTA's assistant director Rick Reibstein. The NHDES site visits were performed
or supervised by Paul Lockwood, Vince Perelli, and Stephanie D'Agostino.
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MASSACHUSETTS COMPANIES
Company #1 is a job shop performing stamping and deep drawing of metal parts. They recently
moved to the area, and determined to start out with a cleaner operation. The company was
referred to OTA by the Greater Lawrence Sanitary District.
Before it contacted OTA, the company had decided that when it moved it would convert from
using trichloroethylene (TCE) to an aqueous-based cleanser in its process lines, and close the loop
to reuse wastewater. It sought OTA's help specifically in how to accomplish closed-loop
operations, the type of equipment they would need and where to buy it.
After a site visit that included a walkthrough of the firm's processes, the OTA team presented
a number of cleaning options, and assisted the company in comparing and evaluating each option.
The company chose the Bowden aqueous degreasing system, which is essentially an industrial
soap and water washing machine.
In dealing with wastewater, OTA recommended that a simple filtration unit could be fabricated
which could be connected to the effluent from the vibratory tumbler as needed. The unit could
be a portable cart-mounted pump and bag filter, with a small holding tank. If cart-mounted, the
unit could also be connected to the sander, obviating the need to use the sump/cyclonic
filter/settling tank currently in use. OTA also noted that deburring and polishing operations were
creating an explosive dust hazard, and recommended wet grinding - however the company cited
difficulties with such an equipment switch. Therefore OTA recommended wet scrubbing of
exhaust air, and detailed the information necessary for accurate sizing of such equipment - air
flow, fan motor horsepower, duct size and length, anticipated particulate loading, particle size,
and hours of operation. OTA also provided information on wet scrubber equipment.
OTA further recommended the installation of closed loop cooling water systems on spot welders
and compression molding machines, which have small cooling water needs. A simple recirculator
with cooling coils and fan was all that OTA felt was necessary. OTA also recommended an
oil/water separator specifically designed for the condensate from air compressors, citing estimates
that there was one 250 standard cubic feet per minute compressor in use, and that historically
such compressors produce about 25 drums of oily wastewater per year, at an estimated cost of
$80 per drum.
In addition, the firm took OTA's suggestion to install an evaporation system, eliminating the need
for dumping an acid neutralizing bath, requiring constant monitoring, to the POTW. The
monitoring would have cost approximately $2,500/year.
Results: This company reports no initial cost savings in switching to a closed-loop system. The
firm's engineering manager says the cost of running the aqueous system is about 20 percent
higher than the TCE degreasing system because a greater amount of detergent is needed to
achieve the same quality of cleaning. However, the firm no longer buys or uses TCE and does
not have spent TCE to dispose of.
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The engineering manager says OTA was extremely helpful in laying out the closed-loop system
and especially in helping him understand which federal, state and local regulations applied to his
firm. "You really need a technical assistance group like OTA to decipher the laws," he said.
"The hardest part is figuring out what is applicable to your business. I would have had a real hard
time figuring it out on my own."
Company #2 is a manufacturer of microwave components and semiconductors used in wireless
communications and the aerospace industry. Since its initial meetings with OTA, this firm has
incorporated pollution prevention into its corporate culture, has saved $8.6 million to date and
has eliminated the purchase and use of 81 tons of toxic chemicals. (These figures differ from
those quoted in the table of results: these figures include pounds reduced at company facilities
outside of Massachusetts. The dollar savings is a company estimate of the net present value of
their program, which is so high partly due to the rapidly rising cost of freon and TCA. In order
to maintain a conservative method of estimation of the value of savings under the Merrimack
Project, we only looked at the value in one year of one year's savings).
One of the firm's manufacturing division chiefs was investigating cleaning alternatives to freon
and TCA when he learned of an OTA event called the "Solvents Bazaar", held in Worcester in
1990. The Solvents Bazaar was, to our knowledge, the first event of its kind. Manufacturers and
vendors of alternative cleaning systems demonstrated their equipment for about 100 attendees,
who brought dirty parts from their factories, so that they could see whether or not the alternatives
worked. The firm's division chief sent a representative, and was so impressed that he called
OTA to request a site visit.
The company was in the process of evaluating the effects of freon and TCA cleaning on wire
bonding, component attachments, soldering. Any metallization has an oxide that starts to build
immediately, and thus effective cleaning is essential to good manufacturing of circuitry. The
original intent of the program was to find supplemental cleaning; it was not expected that
replacement cleaning would be found. There was a sense that the program should investigate
ozone friendly cleaners, but the program was not focused on environmental issues.
The division chief credits OTA's visits with "enlightening" the company to the concept of
cleaning alternatives, the number of alternatives being developed, and the possibilities for success.
Through OTA, the firm learned about work being done at IPC, a printed circuit board trade
association. As a result of this contact, the division chief developed an Ozone Depleting
Substance (ODS) elimination program that incorporated IPC testing recommendations. The
company's program included ionographic testing to determine the amount of ionic residue left
on a part; chromatography organic residue determination to detect amounts of organic residue and
identify particular contaminants; Surface Insulation Resistance, to indicate the electrical
performance of a cleaned part; and SEM Auger Surface Analysis, which is electron beam surface
probing to characterize the elements of part surface layers. This regime of careful testing was
used on a number of identified cleaning alternatives, and provided a careful measure of cleaning
effectiveness.
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An alcohol and water based material with some surfactants and saponifiers, manufactured by
Kyzen Corp., was eventually selected. Other materials based on oil and terpenes turned out to
be more effective cleaners (of solder flux residue) than the freon and TCA base lines. However,
Kyzen far out-distanced all other candidates in this company's program. According to the
company representative, Kyzen's cleaner has virtually no flammability problem, which is unique
to alcohol-based preparations. It was explained to OTA that the material has a flash point so
close to boiling point that the material doesn't ignite, but boils instead.
The ODS elimination program has been a success, and is seen as greatly enhancing reliability as
well as meeting environmental goals. The success of this program, and the 33/50 program, the
new Clean Air Act Amendments, and the state's Toxics Use Reduction Act, has led to a much
greater emphasis at this company on environmental issues. The division chief moved from
manufacturing to become the corporate head of environment. He has instituted a full-scale
planning program, based on the process outlined in the state's Toxics Use Reduction Act. This
program evaluates each process line at each of t he company's facilities in terms of tracking
materials in and waste out.
The program is seen as an effort to improve both manufacturing yield and environmental
performance, and is called "Process Parameter Optimization" (similar to language used by OTA
for several years, but independently arrived at by this firm). The materials accounting system
has proved successful at generating accurate information about process steps, about points at
which materials become waste, about opportunities for pollution prevention at each process step,
and information useful for comparing alternatives and prioritizing projects. The division chief has
required the program to be followed at the company's facilities in other states, even though they
are not under the jurisdiction of the Toxics Use Reduction Act. The division chief organized a
company-wide conference on Design for the Environment, and has proved to be a key member
in the formation of the Merrimack Business Environmental Network (described elsewhere in this
report). Through the Network, he has acted as a resource for many local businesses on
compliance with the CAAA requirements for labelling products made with CFCs.
OTA recommendations made to this company at the first series of meetings also concerned
investigation of "no clean" options, and as a result the company has installed some Nitrogen and
Hydrogen atmosphere soldering, which is fluxless (there is no oxidation of the metallic parts
without oxygen in the atmosphere), eliminating the need for flux cleaning. Other
recommendations concerning fluxless solders have not yet panned out, but the company has an
aggressive program of investigation and evaluation.
The division chief credits OTA as being a "tremendous asset" in getting his firm started down
this road.
OTA also recommended rearranging work stations for centralized batch cleaning, which is
currently under design consideration. Because not every degreaser has as yet been eliminated,
(although all TCA will be), OTA's recommendations for increasing the freeboard cooling have
been implemented.
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The division chief has been a speaker at OTA/DEP workshops for TURA reporters, giving the
message that careful evaluation of materials use, pollution generation, and alternative options has
greatly benefitted the bottom line of his company, and that the law is requiring activities that are
just good business.
Results: The firm has set targets for reducing the use of chemicals identified in EPA's 33/50
program. The targets were set using 1988, when 154,000 Ibs. of these chemicals were used, as
a base year.
To date, a reduction of 49,000 Ibs. of the 17 chemicals on the 33/50 list has been achieved. The
target for 1998 is a 123,000 Ib. reduction.
In addition, the firm has achieved 90 percent of its ODS elimination program. That means to
date, the firm has reduced use of freon/TCA by about 127,500 Ibs. The company expects to
completely eliminate the use of all ODSs by the end of 1995.
Through its pollution prevention efforts, the firm has reaped additional benefits, including the
ability to begin notifying its customers that all products are manufactured without the use of
ODSs, which is expected to lead to increased sales; elimination of the concerns of employees who
were working with hazardous chemicals; and reduced toxics use reporting and compliance
requirements.
The division chief says more technical assistance programs similar to OTA would help P2 efforts,
and that such assistance programs should emphasize the cost-effectiveness of P2 strategies. He
also believes P2 programs should include a mechanism to tie customer acceptance of products
into the general concept.
Company #3 is an electroplater, referred to OTA by EPA counsel because the company had
substantial violations. The EPA attorney knew of OTA's services because she and OTA
representatives have participated in EPA Region I meetings of a group known as the Pollution
Prevention Task Force (headed by P2 coordinators Mark Mahoney and Abby Swaine). This
company's case is an example of how important enforcement programs are to deal with
companies that do not take the initiative to properly address environmental issues.
OTA met with the company on a number of occasions, and supplied information to the
company's consultant. The company's chemist attended the Merrimack Project workshops on
printed circuit boards, water conservation, and electroplating.
OTA noted evidence of extensive spilling of plating chemicals on the shop floor, and
recommended drain boards and changing the layout to avoid dripping of parts. OTA noted a lack
of controls on some hazardous wastes and materials, and recommended a materials control
system, which would institute chronological ordering of incoming material, refusal of materials
in damaged containers, and inventory control cards to log amounts of withdrawal, dates and
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initials of individuals. The OTA team also advised the company to contact scrap chemical
dealers.
Further, OTA recommended improved rinsing to conserve plating chemicals and water The
company officials indicated that they were familiar with all of these ideas, but after extensive
discussion it was apparent that the idea of a dead rinse was in fact new to them ( Dead rinse
involves rinsing in still water, allowing the rinsed-off metals to accumulate, and using this as
makeup for the evaporating plating bath to save on input of metals and drastically reduce metal
discharge.) OTA provided information on non-cyanide zinc plating (Isobrite), the supplier of
which (Alhed-Kelite), will share disposal costs with the customer, and will take back spent nickel
and chrome solutions.
OTA also pointed out that false bottoms on the plating tanks would allow for tank cleaning
without dumping the entire bath. These bottoms can be constructed of screens with a nominal
200 mesh size.
OTA advised that the company could use recirculating bag filters to extend the life of plating
baths, and provided a sketch of what such a system would look like. Team members pointed out
that above the baths were rusted, dirty overhead pipes, which were potential sources of
contamination to the baths. Pipe insulation would address this as well as providing for enerev
savings. 6J
OTA also discussed metal recovery systems with this company, but did not provide extensive
information because at this point the company had not proceeded with any previous suggestions
Thus, this case illustrates an important point about the delivery of technical assistance At some
point a technical assistance team has to evaluate the reception of their work, and consider how
best their resources are to be devoted. It did appear that the company was not seriously
evaluating OTA's advice. Because the team was receiving numerous requests for assistance from
other companies, work with this company was curtailed.
This situation also raises an important point concerning the relationship of enforcement and
technical assistance. If a company calls OTA because they are recommended to do so by an
enforcing agent, care must be taken by the enforcement agency not to assume that the company
is thus implementing pollution prevention. It may not have been the case with this particular
company, but its example suggests that a company may use contact with OTA to project the
appearance of pursuing P2. If an enforcement agency wishes to give some leeway to companies
that pursue P2 as a strategy for addressing violations, that agency should request evidence of such
work directly from the company. If a company is seeking an advantage based on a claim of
working with a technical assistance agency, it seems reasonable to ask what recommendations had
been received, and what progress has been made. OTA is bound by confidentiality, and thus it
is improper for the enforcing agency to refer to OTA and then expect to call this office and find
out what is happening with the company. We do recommend to companies that have had
violations that they volunteer information to the enforcement agency concerning their
implementation of P2.
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Results: A follow-up phone call made in March 1994 determined that in fact the company had,
contrary to our assessment, taken many of the recommendations seriously and addressed some
of our concerns. Most of the pollution prevention measures the company adopted were related
to improved housekeeping practices, although some changes were made in rinsing techniques and
monitoring on the process lines. The company president says that by installing filtering systems
and dead rinses as suggested by OTA, the firm reduced chemical use — cyanide, in particular -
- by 5 to 10 percent.
The president says those same changes have resulted in "tremendous savings" in the firm's waste
treatment costs: the company now spends approximately $1,000 a day on waste treatment, a
savings of roughly $50 per day ~ or $13,000 annually — compared to before P2 strategies were
adopted.
The company plans in the future to install a water reclamation and reuse system that will reduce
water use by approximately one-third, from 15,000 gallons per day to under 10,000 gallons per
day. The firm's president says a 10,000 gallon tank is in place, but the company lacks the capital
to complete the system at this time. He repeatedly referred to a lack of capital and EPA fines
the firm is paying off as the reason for not implementing other P2 suggestions made by OTA.
Company #4, a consumer product manufacturer, was referred by the Greater Lawrence Sanitary
District (GLSD). OTA went to the site for a general meeting, and did not have a full scale
walkthrough. OTA went with John O'Hare of GLSD. This company was having problems
meeting limits on Fats, Oils, and Grease (FOG), and in releases of surfactants, which were a
concern for GLSD because of foaming in its effluent. The problems of this company raise some
important questions concerning the current protocol for measurements of FOG. Freon is used in
the Mbas test, and OTA conjectured that it might dissolve organic components other than grease,
which leads to a false reading of high FOG, actually due to nongrease chemicals.
The company has reduced its water use 87 percent through examination of flushing (line
cleaning) techniques. Instead of cleaning with water, they now use compressed nitrogen to push
dedicated absorbents called "pipe pigs" through each line. They have also achieved a 40 percent
reduction in drummed waste by replacing flat bottom tanks with tanks that have conical bottoms.
The cone-bottom tanks provide for more efficient draining, and when the tanks are cleaned, there
is much less residue to clean. OTA suggested rinsewaters for batch makeup, and using a small
still to reclaim alcohol.
Results: OTA's discussions with the company have led to its active participation in and support
of the Merrimack Business Environmental Network. This company has accomplished a great deal
on its own, and OTA has suggested publicizing these accomplishments. However, the company
is very reluctant to pursue this course at this time, claiming that touting its environmental
achievements will leave it open to criticism from environmental activists who will not be satisfied
with the company's claims.
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Company #5 is an adhesives manufacturer referred to OTA in 1992 by the local board of health
as a result of nuisance complaints received from neighbors concerning odors. OTA found that
one of the coating lines could be linked to an existing thermal oxidizer with sufficient capacity
to handle its vapors, but recommended consideration of a solvent vapor recovery system using
a nitrogen strip process, which would allow reuse of the solvents in cleaning or other operations.
OTA noted that the coating station could be enclosed, in order to capture fugitive emissions, and
that discharges from mixers could be also be enclosed by connection to portable containers by
using flexible braided stainless steel hoses and quick disconnect couplings.
The company had arranged to install activated carbon filters on exhaust ducts from other mixers,
but OTA noted that the kind the company was planning to use would have a relatively small
capacity and would need to be changed frequently. OTA pointed out that the contractor, who
had agreed to regenerate the filters, would have to handle them as hazardous waste.
In addition to the odor issues, OTA noted that the company should limit its acceptance of sample
chemicals, and obtain agreements from vendors that they would take back any unused samples.
OTA also discovered that a still in use at the facility was configured so that the end of the
distillate discharge tube was higher than the condenser outlet (the exit port for the distillate).
This meant that distilled liquids would run back into the boiling chamber to be reboiled, or could
block the discharge tube, causing dangerous pressure buildups.
Results: The company fixed the improper distillation system, and did hook up to the carbon
filtration unit some areas of the process that had been uncontrolled, leading to a distinct
improvement in odors. The company did obtain agreements from its vendors to take back unused
samples, and no longer accepts delivery of unsolicited samples. The company was very attentive
to hazardous waste requirements concerning the used carbon filters. OTA staff observed no odors
of any kind during its last visit in the spring of 1992. Since this time, OTA has hired a new staff
member who happens to live within 100 yards of the facility. He affirms that the problem was
substantial and states that there has been no problem for a long period.
The firm also implemented OTA's other suggestions, including the installation of new duct work
connecting to the firm's existing thermal oxidizer and enclosure of the coating stations. The
company's general manager credits OTA with helping the firm to solve a chronic odor problem.
By the time the firm contacted OTA, it was two years into a VOC emissions abatement program
it developed with the help of a private consulting firm stemming from a consent order from the
Massachusetts DEP. Since 1990, the company has spent more than $325,000 on pollution control
and reduction efforts, including installation of the thermal oxidizer, reformulation of adhesives,
and reduction in the use of toluene. By the time the VOC abatement program is complete, the
company's emissions are expected to go below 13 tons/year, down from more than 130 tons/year
before the program began.
The general manager says because of the large capital expense involved, it is difficult to quantify
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any cost savings related to the program. However, preliminary calculations indicate approximately
10 cents is saved in terms of compliance costs and savings in chemical purchases for every $ 1
spent in capital costs. "The payback is not outstanding," he says. Installation of the thermal
oxidizer provides some savings by reducing the company's use of natural gas by burning VOCs.
Reformulation of adhesives and toluene reduction have resulted in savings of $10,000 and $5,000
a year, respectively.
The general manager says an additional benefit is a better working atmosphere for employees
who now experience less exposure to solvents.
The general manager also says he believes regulatory programs would work better if those writing
the regulations had a better understanding of what the practical application of regulations are for
specific industries. "Industry is not opposed to pollution control regulations or to reducing
pollution, but we don't feel like whoever is writing the regulations always know what they are
talking about," he says. "It seems like decisions (about regulations) are made in a vacuum."
This case is another example of the need for a pollution prevention technical assistance agency
to understand conventional control technologies, as well as pollution prevention techniques. The
company had an existing system, and although OTA pitched a solvent recovery system, the
company was more interested in maximizing utilization of what it had. Because OTA did not
take the position that they would work exclusively on prevention, and did provide assistance in
optimizing the existing system, the company was able to improve its odor situation. It may be
surmised that OTA's practice of providing general assistance did increase the credibility of its
recommendations overall.
Company #6 is Babco Textron, which machines specialty metal parts for the aerospace industry.
The company came to the Haverhill workshop for machine shops, and heard a presentation by
General Electric on their new, safer coolant (Blazocut), which this company also used. However,
General Electric was recycling their coolant and this company was not. After their visit, OTA
staff recommended several changes to Babco's cooling system.
Staff pointed out that the existing cotton filters would support bacterial growth - and
polypropylene filters would not. Also, the cartridge filters being used, once spent, were taking
up considerable space, whereas bag filters (less expensive to buy) are collapsible. The company
was already buying bag filters for an aqueous degreaser system, and these could be used on the
coolant. Most importantly, Babco had on site an ultrafiltration system, used for treating effluent
water from stone tumblers; this could be used to recycle the coolant. However, OTA pointed out
that this was just one feasible method for recycling the coolant, and recommended the company
contact GE. Babco was subsequently invited to the GE Lynn plant to review the their coolant
recycling system. A variation of this system, incorporating phase separation coalescers, was
installed. Ultimately, the ultrafiltration unit was used for recycling the water from the stone
tumblers, which had been discharged. The company has agreed to share this information with
other companies.
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It is worth nothing that the environmental manager at this company was responsible for materials
management, and this apparently had resulted in a very effective materials management program,
reducing the amount of overstocked chemicals, and cutting the variety of chemicals used from
500 to 162. A computerized inventory, which is used to approve chemical purchases, is linked
to MSDS's and tracks usage.
Results: Babco had installed an aqueous cleaning system using Blue Gold cleaner (sodium
hydroxide based), and ultrasonic agitation, which replaced a TCA degreaser. The company did
agree to act as a referral source for other companies considering such a system, and has been
willing to demonstrate it, allowing other companies to bring their dirty parts to their facility for
cleaning. Babco's Mike Cowell also agreed to present at the September, 1992 33/50 EPA
conference in Framingham.
Babco had a Zyglo nondestructive testing system, which uses florescent dye to detect flaws. The
system uses air atomizers for spraying and a garden hose for rinsing. OTA recommended that
Babco use high volume low pressure (HVLP) spray guns to apply the Zyglo, that the air
atomizers be used for spray rinsing, and that the rinsate be run through the ultrafiltration unit for
dewatering. These recommendations were implemented.
The company has since relied on OTA for help in obtaining clarifications with DEP regulations,
and is currently working with OTA on refinements to its chemical management system.
This company is in Danvers, and not in the Merrimack River system. However, it is included
here because work with the company began with their participation in a Merrimack Project
workshop, and the firm has provided information and demonstrations to a number of Merrimack
companies with which OTA has worked.
Company #7 is in Salem, outside of the Merrimack watershed. However, it is discussed here
briefly because OTA persuaded the company to run trials of the Venturi Systems Hydrovac
technology, which is an inexpensive method for superaerating water. OTA's research at the very
beginning of the Merrimack Project led to the discovery of Venturi Aeration, a tiny two-person
company from southern New Hampshire. OTA visited a site where Venturi was digesting
restaurant grease, using the Hydrovac to provide oxygenation to grease-eating microbes. The site
was digesting grease that would otherwise go to landfills, or be disguised in septage hauls, and
the company was meeting FOG limits in its discharge. This information was presented at the
Merrimack Project workshop for Newburyport on Fats, Oils and Grease from restaurants.
OTA also visited a site in Pelham, NH where Venturi was stripping VOCs from groundwater,
and showing nondetectables in their monitoring. OTA was interested in the innovative uses to
which the Hydrovac technology could be put, and recommended at company #7 that the
technology be tried for aerating grease-laden water before treatment in order to turn sulfides to
sulfates, bacterially digest FOGs, stimulate aerobic bacteria to control anaerobic bacteria, and get
the best settling and separation in the mixing tank.
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Results: The company agreed to a trial, but the system did not perform to the company's
expectations. Venturi Aeration felt the pump became fouled with suspended solids, that chrome
present in large quantities was consuming available oxygen, and that the sulfide conversion to
sulfates was also consuming available oxygen. OTA observed that the wastewaters were much
improved, but the company felt that because they were not restored enough for reuse, it would
not use the system. Recommendations for improving trials were not implemented, and the
company has not tried the system since that time (October, 1992).
OTA experience with Venturi Aeration, however, convinced staff that there was potential for new
applications of this inexpensive superaeration device, and that the company was innovative and
eager to experiment. OTA has assisted the company in preparing financial information, and in
introducing it to new business opportunities where the new technology might be applied or
recognized. OTA recommended trials of the Hydrovac for odor control at the Greater Lawrence
Sanitary System; these were successful, and large scale systems have been put in place. (See
attached case study).
This case illustrates the danger of inflated expectations. Although initial discussions with the
company included the possibility that the Hydrovac might render the wastewater suitable for
reuse, OTA expected that if it did not, there would still be an advantage in enhancing the
treatment system in place. In fact, by reducing sulfides and increasing chromium conversion, this
seems to have taken place. But the company regarded the trial as a failure because it did not lead
to complete water recovery.
OTA is still working with Venturi Aeration, which is now also marketing a vacuum filtration
system. This was demonstrated recently at company #7, and the system did clean a large
percentage of wastewater, rendering it reusable. However, the concentrated filtrate, run back
through the system, did not clean up. It will be interesting to see if this trial comes to be
regarded as a partial success or as a failure.
Company #8 is a metal parts manufacturer which contacted OTA after being notified by the
Lowell treatment facility that they were exceeding aluminum discharge limits of 2 mg/L. OTA
found technical violations with hazardous waste laws, and emphasized the legal risks the company
was taking. The treasurer of the company, who assigned himself as environmental coordinator,
was attentive to these remarks, and made OTA aware of some actions that he subsequently took
to address improper storage.
OTA recommended that a bath no longer used should be eliminated from the cleaning line, and
that the available space be used for dead rinses immediately following caustic cleaning and acid
baths. OTA also suggested spray rinsing of parts over the process tanks, and designing racking
to maximize drainage.
Results: The company did remove the old bath and installed dead rinses, installed bag filters to
extend the life of the chemical baths, and also improved their self-monitoring by using a less
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expensive aluminum testing method that OTA told them about - a Hach DR 100 Colorimeter
(OTA also mentioned that similar test kits could be obtained from LaMotte Chemical - we always
try to avoid recommending just one supplier, and preferably recommend three). It is our
understanding that these actions resolved the zinc problem.
After implementing OTA's recommendations, the company's aluminum discharge now averages
1.6 to 1.0 mg/L, reduced from the 2.2 to 2.6 mg/L it averaged before the changes. The company
president says the effort was made solely for regulatory compliance and says "very little"
pollution is being prevented. Because of the changes, he estimated the company saves 10
percent, or $500 annually, on its water bill.
This company serves as an example of that population which is primarily interested in compliance
at lowest cost, which needs to have regulatory limitations as a requirement or it is questionable
as to how much they would undertake on their own. The company aslo serves as an example of
how difficult it can be to get some people to recognize indirect or intangible cost savings. This
company had savings from: the space that was opened up to other uses after the dead rinse was
removed; the extension of the chemical bath life, (which results in less frequent dumping and
reduced purchases); and the fact that the POTW was no longer notifying them of violations
(worth at least the value of the fine they would have had to pay if they had not rectified the
problem, without considering the cost of legal representation or engineering consultation if the
problem had continued). None of these were noted by the company, nor did the company
consider the amount of pollution prevented to be significant. However, if we take a conservative
estimate of annual flow at this company of 1,875,000 gallons (based on information provided by
the company), convert it to 7,265,625 liters, and then multiply it by 1.1 milligrams for the
amount reduced per liter (the previous average of 2.4 minus the current average of 1.3), and we
have 7,992,187.5 milligrams, which equals 7,992.2 grams, which equals 17.6 pounds. Perhaps
today this is not a significant amount of pollution, but ten years of such savings would mean
nearly 200 pounds of metal not entering the waterway, and if just ten other companies did the
same thing it would mean a ton of pollution avoided, by implementation of very simple measures.
Company #9 is Alternate Circuit Technology, which came into contact with OTA as a result of
its environmental engineering manager, David Unger, taking the class for TURA planners at the
Toxics Use Reduction Institute (TURI) at the University of Massachusetts at Lowell. TURA
requires toxics use reduction plans by large quantity toxics users: these plans have to be signed
by certified TUR planners.
ACT pursued a federal grant to finance installation of an ion-exchange, reverse osmosis (RO)
system for recovering metals and reducing water discharge from plating operations. Under this
system, rinse waters go to a 25 gallon per minute RO system, recovering all rinsewater except
about 2 gallons, which is discharged.
In addition, ACT followed OTA's suggestion for reclamation of etch material, saving the
company from disposing of 40,000 gallons of bulk etch annually. ACT purchased an acid
reclamation unit that had been the subject of a presentation by Digital Equipment Corporation
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at the Printed Circuit Board workshop sponsored by OTA, the Toxics Use Reduction Institute,
NHDES, and the Lowell POTW and held at the University of Massachusetts at Lowell.
Results: David Unger says the firm has not quantified exact savings realized from use of the RO
system, but says since it has been in use, there have been "no upsets" in the system operations,
and ACT controls and monitors its water quality. He said the discharges to the POTW have been
cut by 2 million gallons in the first six months of use of the RO system, which should
dramatically reduce the $12,000 annually the firm pays in sewer fees. In addition, because of
the etch recycling, ACT save $7,200 annually in disposal costs.
David Unger said he believes hazardous waste generators greatly benefit from easy access to a
non-regulatory agency that can walk through the plant and keep information about what they find
confidential. "Most people don't know or just forget about compliance details," he says. "No one
can afford the fines. And it doesn't do any good to put companies out of business."
Company # 10 is a contract spray painter which contacted OTA after hearing about us at a
seminar (not an OTA seminar). OTA conducted a joint walkthrough with the NHDES personnel.
The team observed an excess of left-over paint, and recommended purchases of reduced
quantities. The team also recommended buying base paint and mixing colors as needed, rather
than buying colored preparations.
The team also pointed out a number of actions advisable for better compliance with air and
hazardous waste regulations. The team suggested that when the company had overstocked paints,
it could offer a discount for their use. The team provided information on respirators for use by
employees, and recommended and provided information on operator training in the use of
protective devices and in proper spray painting techniques. The team discussed improvements to
paint gun cleaning operations that would reduce the amounts of solvents used, the use of a
dedicated cleaning station, and the use of a waste exchange for left-over paints.
Almost one year later, the company was urged to call OTA by DEP after receiving an inspection.
DEP told the company that OTA could assist with the calculation of VOC emissions. DEP knew
of this OTA capability because OTA engineer John Flynn presented to DEP air personnel a
computer program he developed for making such calculations, and DEP had made an assessment
that the program was useful. (OTA is working on refining this program).
OTA assisted the company in understanding how solvent density, formula weights, and other data
are used in calculating VOC emissions. Review of MSDS sheets from suppliers revealed
inadequacies, and up-to-date information was obtained. The company has implemented OTA's
method of measuring VOC emissions and tracking them by computer.
OTA made many of the same recommendations that had been discussed previously: reducing
VOC emissions by employing a gun cleaning station, improving worker training, and
investigating electrostatic painting methods (which dramatically increase paint transfer efficiency).
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OTA provided information on alternatives to the company's methylene chloride phosphating
operations, which are another source of VOCs at the plant, noting that aqueous based
cleaning/phosphating systems may require a drying step before paint application. OTA sent notes
from a teleconference on painting, held in 1992, for which OTA arranged several downlink sites
throughout the state.
Results: This company has taken full advantage of OTA's compliance assistance service: OTA
basically prepared their air source registrations for them, bringing them mto compliance. In a
recent follow-up phone call, the company reports that it has implemented the good housekeeping
and improved purchasing practices OTA recommended and has assigned a staff member to
monitor hazardous waste storage and handling. A company manager estimates the firm saves
$5,000 a year by reduced purchase of thinner, and now purchases higher quality paints,
generating less waste and reducing employee exposure to hazardous materials.
Company # 11 is Brush Wellman Inc., a manufacturer of electrical components, which contacted
OTA after receiving a multimedia inspection, jointly conducted by DEP and the Newburyport
POTW. On the initial visit, this team found minor hazardous waste violations, and recommended
the company make use of available technical assistance services.
OTA found the company had a very clean and well run operation, and had already virtually
eliminated TCA and dramatically reduced use of Freon. One problem was that the aqueous
cleaning now in place did create a problem with water spotting on gold plated parts after a final
rinsing with deionized water (there had been no spotting with Freon drying). The company was
using a rinsing aid called Cerematek. OTA suggested that the spin drying operation could be
supplemented or substituted with mild tumbling in a octagonal barrel tumbler filled with ground
corn cobs. This should eliminate the spotting and the need for the Cerematek chemical additions.
It was pointed out that the corn cob tumbling would likely burnish the gold, and that the
company should evaluate whether or not that was desirable to their customers. They were
referred to another company, which had agreed to discuss their experience with corn cob
tumbling.
The company had already extended the life of their baths by changing filters more frequently and
reducing evaporation by using floating plastic balls on the bath surfaces, and has pursued OTA's
advice to further increase bath life by careful monitoring of pH and constant constituent
adjustments to maintain the optimal bath operating parameters.
OTA found that the regulatory violations at the company were the result of confusion concerning
requirements, and obtained clarification of the issues, which consisted of dating and satellite
storage. The company had extensive air monitoring on site, and appeared to be committed to
both compliance and preventive activities.
Results: Jean Borgard, Plating Supervisor, credits OTA with helping BW reduce its use of
hydrochloric acid nearly 40 percent (from 26,000 Ibs/yr to 16,000 Ibs/yr), saving the company
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roughly $35,000 a year in purchasing costs, plus associated savings in reduced wastewater
discharges.
In addition, the firm is investigating new cleaning and drying options identified by OTA that will
allow the elimination of the use of Freon 113. According to Borgard, BW expects to stop using
Freon by July 1994, saving an additional $40,000 or so annually in chemical purchase and waste
hauling and disposal costs.
Borgard said OTA provided information on good housekeeping practices regarding the storage
and shipment of hazardous waste, keeping the firm in compliance and preventing the possibility
of fines for violations.
The plating supervisor said the most helpful service OTA provided was giving BW the
opportunity to "benchmark" or compare its operations with other firms and see how others had
successfully reduced the use of toxics. "They helped us develop a good environmental policy for
the company and the community."
Company #12 machines aluminum parts, and learned of OTA's services by attending the
Machine Shop Workshop in Haverhill. The company needed help with hazardous waste
compliance, and selenium discharges. The company's discharges were uncomfortably close to
a new limit (0.2ppm) set by the Amesbury POTW. The company did not know where the
aluminum was coming from.
OTA had bath samples analyzed by a laboratory, which is a service OTA provides when
necessary to identify P2 options. These tests indicated two sites at which selenium was present
in significant amounts, the major source being a chemical used for chromate conversion.
OTA recommended the company use a local laundry equipped to handle oily rags, instead of
disposing of wipes. The team suggested that using recirculating filters for the acid and caustic
process baths would not only keep them clean and extend their life, but also provide movement
of the solution, thus increasing their efficiency. (In-tank filters for acid baths would not require
expensive out-of-tank teflon construction). The team advised that evaporative losses could be
reduced by using tank lids and closing them during periods of non-use, and provided information
on floating media covers, (such as that used by company #11). Dead rinse tanks (with filters)
also were recommended, which could be used as make-up for the preceding evaporative baths,
and could be replenished by overflow from other running rinses. OTA pointed out that spent acid
or alkaline solutions could be used for pH adjustment in wastewater treatment, and that heated
baths could be insulated.
OTA explained reactive rinsing: that the same tank could be used for rinsing parts from both
acidic and alkaline baths, and that alkaline rinsewater could be reused to rinse parts from the acid
cleaning, and that this method saves water and affords some neutralization, saving on the addition
of treatment chemicals down the line.
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Methods for maintaining bath chemistry were also discussed, and the company was given
information about monitoring equipment, including a hand-held fast titrater, and inexpensive
resistivity sensors for measuring the level of dissolved chemicals. The sensors can be preset for
desired levels and can activate horns or lights for warning operators that rinsewaters need to be
drained. This method replaces the calendrical method of replacing bath and rinse waters, (where
dumping occurs at a set interval), with a method that only sends waters to treatment when
necessary.
Results: The team surmised that the company had not implemented many of the elementary
prevention techniques summarized above because there is no chemist on staff. The company was
also hampered in its progress on these matters by the departure of the person with whom OTA
worked. In addition, the company was planning to move, and thus was reluctant to invest in any
changes or new equipment. OTA has recently reestablished contact with the company. The
company has plans to switch from TCA, an ozone depleter, to TCE. OTA visited the facility to
explain the problems and liabilities inherent in using TCE. In the course of this visit, OTA
recommended consulting with Babco Textron to observe their ultrasonic aqueous cleaning system,
and employed a sniffer to evaluate emissions from their degreaser. There were no significant
readings when the degreaser cover was closed, but when it was open there were observable
emissions.
At this company, as well as others, OTA observed less than optimal choices being made to
eliminate ODSs (Ozone Depleting Substances) in order to avoid the new Clean Air Act
requirements for CFC labelling. OTA has observed a number of companies with plans to switch
from TCA to TCE. This is ironic because so much effort has been expended attempting to
convince companies to abandon the use of TCE and other chlorinated solvents that result in
hazardous waste generation, Superfund cleanups, VOC emissions, occupational exposures, and
organic contamination of water. It is noteworthy that the EPA's Significant New Alternatives
Program does list TCE as a potential substitute for ODS cleaners. OTA is now spending
significant energy to convince companies to continue to explore safer ODS alternatives.
The company is also one of many that calls on OTA primarily when it needs assistance with
compliance, and which needs considerable hand-holding in order to implement process changes.
This case illustrates the principle that companies are less likely to institute process changes when
they do not fully understand the process they are using.
Company #13 is a manufacturer of semiconductor devices. John O'Hare of Greater Lawrence
Sanitary District suggested that because they have a low flow operation, they might be able to
go to a zero water discharge system, and suggested they contact OTA.
OTA discovered that the facility is a very small quantity generator of hazardous waste with no
knowledge of the applicable regulations. OTA supplied them with the appropriate information,
and also recommended they contact suppliers of ion exchange equipment. In addition, we
recommended trials of NMP, hexane, and citrus-based cleaners for removing paraffins. The
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company did contact vendors and obtain prices.
This company's case illustrates the regulatory confusion regarding zero water discharge systems.
The POTW has asked OTA to clarify this matter, and OTA has requested clarification from DEP.
DEP met with OTA in 1991 and decided eventually to consider the matter on a case-by-case
basis. A consensus has recently developed that case by case resolution is insufficient, because
companies need clarification before they proceed with capital investments. DEP has reconvened
a committee to devise solutions to the "closed loop closed door" problem. OTA is playing a
significant part in this effort, defining technologies for zero water discharge, and proposing policy
and regulatory solutions.
Briefly described, the problem with zero waste water technologies is that if a company closes the
loop and begins treating or recycling hazardous waste (which they typically do), they may be
considered "treating without a license" - a violation of part B Treatment, Storage and Disposal
Facility license regulations under RCRA.
This is because it is possible for regulatory authorities to interpret their situation as no longer
having the potential to affect the facility that receives wastewater - the POTW or receiving water
- and thus no longer being adequately regulated by another program - the Clean Water Act.
Although Sylvia Lowrance in 1989 proposed in a letter that a possible answer to this quandary
is for Clean Water Act authorities to issue zero discharge permits, many pretreatment officials
have commented to OTA that they are too busy regulating facilities that do discharge to them,
to have to worry about facilities that have sealed their drains and discharge nothing.
GLSD has, however, recognized the benefits of zero water discharge facilities, and has issued
"zero discharge" permits. The legal value of these has not been tested.
Please see attached description of the "closed loop closed door" and other opportunities for
regulatory improvement.
Company #14 is an electroplating company under new ownership and involved in establishing
a new site for operations. Their previous site had significant violations, and DEP had
recommended they give us a call.
Several team members participated in the site visit, presenting a fairly complete set of general
recommendations on good plating operations. Then the team took a look at the plant where the
operation was to be set up, and pointed out the floor was not protected from absorbing spills, and
that ventilation needed to be improved.
At a second visit, the team observed that the tanks were two to three times larger than necessary,
and recommended the use of simple steel mesh in-tank filtration, evaporation reduction by use
of covers or floating media, and the installation of automatic chemical addition systems for the
chemical baths. OTA recommended using bag filters instead of cartridge filters to save money,
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reduce waste volume, and gain filtration efficiency.
The company asked for more information, although its primary concern seemed to be obtaining
financing for its required contribution to a Superfund cleanup site.
Results: Follow up with this company was not as prompt as it could have been; five months
passed before a second letter of recommendations was issued. This letter recommended recovery
of pure copper and etchants using the Sigma Innovation etchant regeneration system, successfully
used by Digital Equipment Co. in Puerto Rico, about which a presentation had been made at the
Merrimack Project's Spring 1992 Lowell workshop for Printed Circuit Board manufacturers.
Other information concerned countercurrent and dead rinses; drip boards; using deionized water
for rinsing; tank covers; and using local precious metal recyclers for photowastes, scrap board
trim, and possibly for metal dusts, filters, resins, and solutions.
Company #15 is an industrial laundry that called OTA after a visit from DEP, and a referral by
Lou Vallee of the Newburyport POTW. The company was near flow limits and was interested
in water conservation. In response to OTA's Previsit Questionnaire the company commented that
"one finds oneself facing more and more compliance issues. Thus, when the DEP visited our
plant, I asked 'where does one go for help?'"
OTA suggested trying the Hydrovac technology to reduce biological oxygen demand (BOD) in
the final effluent, by recirculating the contents of the holding tanks and coupling the superaeration
with microbial treatment. The team also suggested reusing final rinse waters for wash water
makeup, by constructing a holding tank and using a heater and pumps. OTA mentioned that
detergency can be enhanced by use of softened, or deionized water, and suggested that new
ozonation techniques can replace or reduce the amount of detergent chemicals necessary for
washing. The company was informed that Highland Laundry of Holyoke was willing to provide
a demonstration of their working system. (See attached patent). OTA also discussed use of a
chemical dispensing system, to eliminate overuse and spillage.
Results: As a result of the visit, OTA investigated the potential for substituting citric acid for
sulfuric acid, used to neutralize alkaline wash waters before discharge. Neutralization titrations
were conducted to compare sulfuric and citric acid strengths. Sulfuric was about 1.52 times as
strong. This translated to an approximate cost for citric acid of $12 per 1000 gallons of
wastewater compared to $1.73 for sulfuric. Even though sulfuric is covered under TURA, and
the company has to pay a fee for its use, the switch to citric acid did not seem to be economically
justified.
The contact person at this company was subsequently laid off, and OTA is not aware of
implementation of any of the recommendations, but there has been no recent follow up to this
company.
Company #16 is the Frank C. Meyer company, a print shop. (See attached case study.) Because
of its pollution prevention efforts, this company eliminated the generation of 10 drums of
hazardous waste per week, saving $92,000 annually, and installed a wastewater reclamation and
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reuse system, saving an additional $46,800 per year.
The company initially contacted OTA at the recommendation of the Greater Lawrence Sanitary
District, and asked us to help them determine if their tank and machine washing solutions were
suitable for drain disposal. OTA obtained information from GLSD on their effluents and
compared it to ink analyses submitted by the company's vendors. It was apparent that the source
of zinc, copper and lead loadings was the inks themselves, and OTA recommended that since the
inks were likely to be insoluble in water, filtration, starting with a five micron bag, would
probably solve the problem. OTA recommended techniques for preventing contamination of
wash water with ink waste.
After only one month, the company had already instituted new press clean-up procedures which
reduced the amount of solids in wash water more than half, and had successfully used press wash
water in the make up of black ink. The company had already mounted a small bag filter and
pump - OTA recommended increasing its size. By lowering the pH of their wastewater, the
company was now precipitating inks. The wastewater was now suitable for discharge.
This case demonstrates that some companies can be inspired to do pollution prevention simply
by introduction to the concepts. These companies benefit greatly from the provision of technical
assistance.
Company #17 is a manufacturer of electronic components, referred to OTA by John O'Hare of
GLSD. The company had just moved to the GLSD area. Process effluent contained lead,
selenium, and tellurium, which was being drummed and shipped. OTA learned that the company
had spent considerable money on a lead treatment system that did not work.
OTA noted that the company was using TCA, informed them of upcoming Clean Air Act
requirements for labeling, and recommended several alternatives. The company did switch to N-
methyl-2-pyrrolidone, and reports that it doesn't work as well, but is acceptable. The firm also
reports no cost savings at the time of the switch, but noted the costs of TCA was rising rapidly,
so they would be saving money over time.
OTA's recommendations focussed on various methods for recycling water, with zero water
discharge as the goal. Many of these systems involve evaporation, and OTA typically
recommends that companies consider enclosed evaporation, as that may be considered under the
state's hazardous waste regulations as "treatment that is integral to the manufacturing process"
and thus needing no permits or licenses. (OTA has identified an inconsistency in DEP rulings
on this issue, with some officials recognizing end of pipe enclosed evaporation systems as
integral, and some officials stating that it does not qualify because it is end of pipe and not
necessary for producing the product.) OTA noted that if the company chose an atmospheric
evaporator, it might by accident be driven to dryness, and in that case it would be possible to
drive lead and selenium compounds into the atmosphere.
The company did express enthusiasm with the idea of cold vaporization, which is a technique for
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enclosed evaporation. Enclosed evaporation techniques recover water, rather than driving it into
the air. Cold vaporization operates by pulling a vacuum, which enables the water to evaporate
at room temperature. The company was concerned with a lack of available funds to purchase
such a system.
A company representative said he appreciates non-regulatory assistance offered by OTA and sees
a need for expansion of such technical assistance programs, particularly for small businesses. He
said smaller firms like his -- which doesn't have a full time environmental compliance officer --
could use help in developing hazardous materials safety programs, including employee training.
He said hazardous waste handling and management has become a "regulatory nightmare" and
called on the state and federal governments to write regulations in simplified language "so you
don't need a lawyer to understand what applies to your industry."
Company #18 is a manufacturer of air filtration and conditioning systems, which came into
contact with OTA as a result of receiving a Notice of Noncompliance (NON) from DEP for
improper disposal of oily rags.
OTA noted significant VOC emissions from painting operations, and the use of a contact cement
containing TCA, which would require CFC labelling. OTA discussed using low VOC paints, and
pointed out that the supplier of their paints, Sherwin Williams, was offering high solid (low
VOC) versions of the same paints in use at the plant.
Results: OTA followed up several times with this company, and determined that no actions were
being taken. OTA then took the unusual step of writing to the president of the company to
inform him of the opportunities we had discovered. There has been no response.
Company #19, a manufacturer of plastic components, was referred to OTA by DEP inspector
Joe Dowling. OTA observed that the facility was very clean and operations appeared to be well
run, and complimented the company on this.
The company had selected an aqueous cleaning system to replace TCA, and was having trouble
obtaining financing.
VOC emissions from cleaning paint guns was one concern, and information on gun washing
systems was provided. In-house distillation or off-site recycling of the spent solvent was
discussed. OTA provided information on worker training in spray painting, and HVLP spray
guns. There was a possibility that electrostatic coating could be used with the plastic parts, but
this would mean that a conductive material would have to be applied first. OTA also described
the use of "plural component" spray equipment, which mixes paints as needed in the gun: this
avoids the batch mixing of paints, which usually results in mixtures left over. This system allows
reduced inventories as well as wastes. OTA also provided information on spray booth filters and
a computer controlled matching and blending system.
The highest potential for VOC reductions was by switching from VOC based paints to waterbased
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systems. The company representative told OTA that it was the first time that consideration had
been raised, and it was of interest because the company had received letters from customers
asking what they intended to do about the Montreal Protocols.
OTA investigated whether some solid waste generated by the process could be used in bituminous
concrete as a filler. OTA did propose to the state highway department that the polyurethane
material be evaluated for this use.
Some months later, OTA followed up with further recommendations, which focused on "color
management" - scheduling light color applications before dark, and dedicating various spray
booths for application of particular colors, to reduce the need for line cleaning.
The company wrote OTA a letter thanking the team for their "excellent work" and expressing
appreciation for the existence of an agency that one can turn to for "help vs. fines".
The company's operations manager (OM) said OTA was extremely helpful in clarifying issues
of labelling, handling, and storage of hazardous waste.
Results: In a March 1992 phone call, the OM said the firm has installed an aqueous based
washing system and as a result has reduced its purchase and use of TCA by 85 percent, from 14
tons annually to approximately 2 tons. He estimated savings in the range of $60,000 a year in
purchase, reporting fees, and waste handling and disposal. The firm has been unable to convert
to 100 percent aqueous cleaning because certain parts require a molding agent that doesn't wash
off with water and detergent. The company is continuing to investigate alternative molding
agents.
In addition, the company has found an in-mold painting process that allows the elimination of
post-mold painting, priming and degreasing. Although the one-coat in-mold paint is a relatively
high emitter of VOCs, the firm has found that the reduction in VOCs from the elimination of the
post-mold processes more than offsets the emissions from the paint. Only a few parts are
currently painted in the new process, but many more are scheduled to be added in the next
several months. The operations manager estimates that when the majority of parts are painted
through the in-mold process, the company will save 30 percent of the cost of its entire
manufacturing process.
The operations manager expressed frustration in working with the state regulatory agency whom
he says was initially unresponsive in the firm's attempts to reclassify its generator status after
reducing its VOC emissions. The reclassification apparently has not occurred and he has been
advised to pay the fees as a large quantity generator (LQG). He said he was "tired of hearing
about how overburdened they are and how they don't have any money. It's just an excuse."
Company #20 makes plastic foam. The company agreed to a visit after receiving a letter from
OTA stating that we had reviewed TRI data and noticed that they had experienced an increase
in releases, and would they like a visit to help achieve reductions? This was followed up by a
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phone call.
The company was switching from Freon 12 as a blowing agent to methylene chloride, which also
provides necessary cooling because the polyurethane reaction is exothermic. OTA recommended
using vacuum tables for cooling, which would reduce the need for methylene chloride. Another
approach would be to enclose the foaming area in a vacuum chamber. OTA also mentioned
increasing the silicone surfactant concentration as a strategy for increasing foam "openness" and
thus improve the cooling, reducing the need for methylene chloride. OTA also suggested
reducing the amount of toluene diisocyanate to achieve a reaction which would generate less heat.
Results: The company did not like these recommendations, and has not pursued further work
with OTA. They are TURA filers, and thus are required to develop TUR plans, which require
consideration of TUR options.
Company #21, an electroplating company, called OTA when they heard that DEP was
concentrating on their local area. They were also referred by Newburyport POTW, and also
knew of OTA because they had attended the TURI course for TUR planners. OTA helped the
company with various compliance issues, such as identification of characteristic wastes, labelling
requirements, air registrations, and eye protection under OSHA. Plastic coated racks were
dissolving in acid baths, and OTA recommended using epoxy coated racks. The shop was well
managed and OTA did not find many ways to improve the process. The company expressed
appreciation for the help.
Unfortunately, a fire destroyed the plant and the company has gone out of business.
Company #22 is an electroplating shop strongly urged to call us by Lou Vallee of the
Newburyport POTW. This company presented OTA with a problem: dangerous conditions were
discovered at the site, and the question was, were they dangerous enough to warrant reporting to
DEP? The language of TURA says that imminent threats must be reported.
OTA decided to take the following tack: to discuss with the company the fact that we were
considering whether or not to report them, and that we would not report them if the dangerous
conditions were immediately addressed. The company did address the dangers, and OTA then
made weekly visits to the company for a period of a month, with frequent follow up in the
months thereafter. OTA conducted training for the company employees, during which it was
made clear to them that they could ask OSHA for an inspection if they felt they were working
under dangerous conditions at any time in the future. The company owner agreed to this training
and allowed us to talk to the employees and solicit information from them, absenting himself
from the office while we met with them.
The dangerous conditions consisted of a sump located below the raw material storage area floor.
The opening to the sump was accessible to any liquid chemical spill, and OTA felt that if acids
were spilled, they could react with cyanide salts. We did not feel this was an imminent danger
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requiring reporting, but it was a dangerous condition. The company diked the opening.
Another situation consisted of an open top drum of chromic acid which could have been knocked
over into a cyanide rinse collection sump. This drum was removed from the area.
A third situation was the storage of sodium metabisulphate next to the chromic acid tank - mixed
together, these can yield hydrogen sulfide. This was immediately remedied.
OTA also pointed out an air pack which was blocked from easy access and had no label showing
it had been recently checked. This was remedied.
OTA explained that the company's hazardous waste storage practices were not according to the
regulations, and these were put in order.
Other recommendations consisted of installing drain boards, countercurrent rinsing, dead rinses,
recirculating particulate filters on both process and rinse tanks, use of ultrasonic agitation on
cleaning tanks, regular maintenance of process tank chemistries, and monitoring of the tanks, such
as by resistivity meters.
On a later visit, the company complained that their conductivity measurement systems were
corroding, and staff recommended equipment that would not corrode. OTA consulted with the
manufacturer of the cleaner the company was using, and recommended the proper temperature
for its use, and reported that the manufacturer asserted it would work much better with agitation,
but not aeration (would cause foaming). OTA recommended noncyanide nickel stripping, and
looking into alternatives to cadmium and chromium as well, citing the Sanchem Inc. (Chicago)
nonchromate aluminum sealant which has been demonstrated to pass corrosion testing.
In its meeting with employees, OTA heard a lot of complaints about indoor air quality. It turned
out that the company had once used adequate ventilation, but had removed the system after
receiving complaints from neighbors. OTA pointed out in a letter to the president that this
merely transferred the problem to his employees, and that they were unanimous in their concern.
We strongly suggested restoring ventilation, and adding controls, and pursuing methods of
eliminating the problem at the source. We also pointed out that there were no emergency
procedures in place, and the employees knew nothing about emergency response; we included
recommendations about implementing these measures.
At the employee meeting, it was mentioned that several years ago the company had engaged in
weekly meetings at which plant operations were discussed with all employees. We suggested that
these meetings be reinstituted, and that the items for discussion should be whatever chemicals
were causing a problem for the wastewater treatment operators, the amounts and types of
hazardous wastes generated and the reasons why, and the levels of contaminants in the air.
At last contact, the company had installed some drip boards and had erected a partition between
an acid and a cyanide tank, but had not pursued any of the other suggestions to our knowledge.
The ventilation problems seemed to be as before.
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The company president claimed that there were no indoor air problems at his plant because
OSHA had given him a clean bill of health. We asked when that was, and it seemed to have
been several years ago, perhaps as long ago as the early 1980s. By telling employees that they
could complain to OSHA if they felt unsafe, we were risking opening ourselves to charges of not
adhering to our mission of providing assistance. We felt, however, that the company president
was too relaxed concerning the hazards at his plant, and that we could not report what were not
technically imminent hazards, but long-term hazards. This case illustrates the need for a vigorous
OSHA program and a healthy respect by certain small, but high hazard industries for the
imminence of an OSHA visit.
Company #23 is a precision machine and stamping operation, referred to OTA by Lou Vallee
of Newburyport, who also stated to the company that DEP was planning to make inspections in
the area.
The company had an open floor trench connected to the sewer, in the same room in which
degreasing was occurring. OTA recommended diking the trench and removing the degreasing
operations. Both were done.
OTA recommended replacement of TCA, citing semiaqueous and aqueous options. OTA
recommended consulting with clients on how clean parts had to be. One process suggested was
to wash in a hot aqueous solution, with ultrasonic agitation, to be followed by a still rinse in
ultrasonically agitated hot tap water, and if staining is a problem, to use cascaded rinses in hot
or cold deionized water, followed by hot air drying.
OTA noted that although the soapy water discharge from a tumbler did not show heavy metals
in analyses, that it did present a total suspended solids problem; therefore the use of a recycling
system was advisable. The system would route the discharge to a settling tank, with overflow
pumped through a particulate filter and then a small ultrafilter, with the reject from the ultrafilter
being collected and filtered on a second pass when feasible. OTA cited such a system in use at
Babco Textron, which uses the soap from the ultrafiltration backwash as a supplemental lubricant,
and mentioned that this company would be amenable to receiving a technology transfer visit.
OTA also recommended adding some degreasing agent to the tumbling operation so that some
cleaning and deburring operations could be consolidated, which would eliminate a separate
cleaning step.
Results: The company had been planning to switch from TCA to TCE, but OTA cited liability
issues surrounding the use of this chlorinated solvent. The company investigated aqueous
systems, but did end up switching to TCE. A company manager said they have experimented
with aqueous systems and other "safe solvents" including citrus, but have consistently had
problems with the time it takes for parts to dry. He said they tried ultrasonic aqueous cleaning,
but found that it was not acceptable because it cleaned a smaller percentage of parts per batch
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than TCE. He said the firm is continuing to experiment with alternative cleaning and drying
methods, but is not expecting to eliminate the use of TCE anytime soon.
The manager said OTA was very helpful in providing information about proper storage and
management of hazardous wastes and the company has implemented OTA's suggestions in that
regard.
The manager expressed concern over increasingly stringent wastewater discharge limits. He said
currently the company does not pretreat its wastewater. He said he fears tighter restrictions which
would require the firm to institute pretreatment, something that he said would be "very costly."
Company #24 is IMI Inc., a printed circuit board manufacturer. OTA's visit resulted from a cold
call made to the company following up on a letter stating that we had been notified by DEP that
the company had received a notice of noncompliance for hazardous waste storage violations.
Noting what seemed like an unnecessarily complicated process, OTA went over the
manufacturing steps with the process supervisor in great detail. The supervisor stated that when
the company had problems they would often add a corrective step, rather than change the process
at the source of the problem. These steps tended to stay in use long after they were necessary.
After the visit, the company contacted the McDermid company, a supplier of chemicals of higher
quality than what the company had been using, and a vendor that offers technical support.
McDermid went through the company's process line and made recommendations which resulted
in the removal of a substantial number of steps - a line that had 50 steps now has approximately
half that.
The supervisor was concerned about water use, and stated that the Myron water control was
calling for more water than was necessary. OTA called Myron and recommended that the probes
be located where the buildup of dissolved solids would be sensed, and that the conductivity
settings be higher than the average conductivity of tap water to allow a reasonable buildup.
OTA also recommended switching to deionized water rinsing for final rinses, drip boards, and
the use of dead rinses to replace continuous flow rinses. Some dead rinses could be preceded by
spray rinses - the combination should be effective for cleaning inside holes.
The company found that operators were unilaterally making changes in the Myron control
settings, and have corrected this - leading to a cutting in half of water use.
OTA noted a large quantity of spent etch, and recommended a Sigma Innovation regeneration
system (presented by Digital at the Lowell Printed Circuit Board workshop). The company tells
OTA it is now "seriously considering" etch recycling equipment.
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OTA recommended filtering oxide baths to prolong their life, and the company is also
considering this. OTA recommended continuous filtering of an electroless copper bath, and the
company has installed this. OTA noted flaking from the ceiling was contaminating a number of
baths, and the company states it is currently upgrading the ceiling and is using covers on the
baths at night and on weekends.
A referral to John Lott at Dupont concerning spent film material resulted in advice concerning
a new type of film and reduced usage of film, which the company has implemented; resulting in
reduced spent film disposal.
Results: According to Ron Zangari, in charge of IMFs waste treatment operations, OTA helped
IMI in its search for ways to eliminate the use of TCE. The company stopped using TCE in June
1993, eliminating the purchase and use of nearly 8,000 Ibs. at a cost of roughly $4,000 per year
plus the associated disposal costs. The firm found that by making changes in other parts of its
process lines, it could eliminate the need for cleaning the boards with TCE, which also meant the
elimination of a 15-minute step in its production process and improved working conditions for
employees. "Nobody wants to work around a chemical with such a bad history," Zangari said.
By implementing water conservation measures, such as monitoring rinses and turning them off
when not in use, IMI has realized savings in water use and costs. Five years ago, the firm used
220 gallons per square foot of circuit board manufactured; today use is down to 80 gallons per
square foot. Zangari said the next step is closing the loop with a full-scale water recycling
system, but he doesn't expect that to happen soon. He said the company is rapidly growing and
has other priorities for capital expenditures.
If IMI's search for a method of etch regeneration proves successful, the firm's status would
change from a large quantity generator (LQG) to a small quantity generator (SQG). The company
already recovers copper from the spent etch.
Zangari believes that the extensive paperwork, filing procedures, and fees involved in recycling
hazardous waste provides a disincentive for many companies. "It is easier to manifest the waste
and ship it off than to apply for recycling permits. The forms and filings and fees make it very
complicated -- there must be ways around that. They (government regulatory agencies) should
make recycling a more attractive alternative."
Company #25 is a furniture manufacturer, contacted by OTA after OTA received a copy of an
NON that the company had received from DEP concerning fugitive emissions, discharge of boiler
blowdown, and hazardous waste storage violations.
This company was investigating conversion from solvent based seal and finish coatings to water
based versions. In case the conversion did not work, OTA recommended installing cooling coils
on the freeboard above the liquid level in the dip tanks, and collecting the condensate. OTA
suggested tank covers and lids with foot pedal actuated closure mechanisms, and enclosing the
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application areas and directing emissions to a solvent recovery system. OTA suggested that
product use could be reduced by spraying stain instead of dipping, or by using vacuum staining
on unassembled parts. Staff pointed out that drip boards could be used on the stain process to
return excess stain to the dip tank. The company was provided a copy of a Tufts University
Capstone Project report on P2 for wood finishing.
When presenting its recommendations, OTA commented on two matters that seemed to annoy
the company representatives. One was the fact that within minutes of coming into the staining
area, OTA staff started to cough. This fact, along with the quantity of VOC emissions and the
fact that some of the solvent constituents in the stain are defined as hazardous air pollutants,
supported the suggestion for installing vapor control or recovery technology.
The second matter consisted of whether or not the company had to file reports under TURA.
There is a difference in TURA-defmed thresholds for reporting on chemicals that are processed,
or "otherwise used". The company was using over the threshold for otherwise used of toluene
and xylene, but was claiming that these chemicals are processed, not otherwise used. OTA cited
TRI guidance to the effect that the company's use of these chemicals was not in the processing
category, but in the otherwise used category, and thus they were required to file under TURA.
The company replied that they had discussed the matter with a DEP official and had been told
otherwise. OTA informed them that if the DEP official had given them incorrect information,
that would not relieve them of the responsibility to report.
OTA also recommended that the company contact OSHA to make use of their consultation
program, citing the fact that employees were working around open tank operations.
OTA also offered help in calculating VOC emissions, citing its new computer program.
Results: The company did not appear to appreciate being told that everything was not okay, and
did not appear to believe OTA concerning their responsibility to file under TURA. If the
company has implemented any of OTA's suggestions, we are not aware of it.
Company # 26 is a manufacturer of electronic products. OTA observed a clean and well run
operation. The company had replaced TCA with an aqueous cleaner, and because it was
experiencing a residue on product, there was consideration of switching to TCE. OTA
recommended expending the effort to find a cure for the film residue. OTA recommended
heating the cleaning solution, adding ultrasonic agitation, and rinsing with deionized water.
Methanol drying was recommended if there were staining. OTA also noted that rinse waters
could be reduced by the use of flow controllers with conductivity probes.
Results: OTA has not conducted follow up to discover whether or not these suggestions were
implemented.
Company #27 is a machinery manufacturer that received a Notice of Noncompliance from DEP
for incomplete air registrations and lack of hazardous waste storage signage. The company called
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OTA, and the team assisted with compliance issues.
OTA found that condensate from a steam cleaning process was going to treatment, and
recommended that an ultrafiltration or vacuum evaporation system be considered for removing
dirt and oil from the water, which could then be reused in the boiler. It was mentioned that the
UF approach would require maintenance because membrane modules need to be cleaned with
sponges and detergent on a regular basis.
The company had obtained the services of a consulting engineer, who recommended a system that
OTA felt was complex, expensive, and had questionable reliability. The company did order the
vacuum evaporation system that was one of the options OTA suggested.
The company noted complaints from customers concerning paint surfaces that had badly rusted
upon delivery. OTA recommended various approaches: examining surface cleanliness before
paint application, applying a primer, applying a baked coating, and using a paint containing rust
inhibitors.
Company #28 is a manufacturer of electronic components that received an NON from DEP and
agreed to a visit from OTA after a cold call from us.
The company was disposing of solvent laden rags in the dumpster, and OTA recommended using
a laundry equipped to clean such rags. The company decided to eliminate TCA and replace it
with an aqueous cleaning process. OTA had recently learned that DOD, EPA, and an Industry
Ad Hoc Solvents Working Group had reviewed various cleaning materials, and recommended
certain cleaning substitutes. OTA pointed out that the company would have less trouble
conforming to DOD requirements if the replacement they chose was one of the ones that this
group recommended. The company decided not to go with a cleaner they had been considering
which was not on the list, and in May, 1993 decided to use the Alpha Metals (Jersey City, New
Jersey) saponifier.
OTA recommended using enclosed equipment to reduce emissions from cleaning of spray guns.
The last followup by OTA, in October 1993, indicated that the company was not going to go
ahead with the Alpha Metals cleaner, and had not yet looked into the rag cleaning suggestion.
Company #29 is Cabot Stains, a manufacturer of wood stains, both oil/solvent-based and acrylic.
The company opened its plant in Newburyport in 1985, with several built-in, state-of-the-art
pollution prevention measures such as a pitched floor for spill containment, a nitrogen blanketing
system, and a closed-loop, two-hose delivery system to prevent the release of VOCs during tank
(solvent) loading and unloading. Interestingly, the company did not do a cost/benefit analysis
before including these measures in their construction plan; the firm assumed these measures
would prevent problems and save money in the long run, and worked with a designer/contractor
familiar with the painting industry to design the plant. Although there are no firm numbers
available, manufacturing manager John Gihlstorf estimates the company spent an additional $1
million in construction costs to achieve pollution prevention and spill prevention measures.
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Although the plant was extremely clean and well-run, OTA staff did find additional opportunities
for pollution prevention, including switching from paper bags to fiber containers lined with
reusable plastic for zinc oxide storage and use, and the installation of spill mats and/or drain
closures in the dry loading dock areas.
Since it moved to its new plant, the company has reduced its fugitive VOC emissions to 13 tons -
- estimated to be one-tenth of the emissions at its former plant in Chelsea, Massachusetts, which
had been constructed in 1908. John Gihlstorf says the pollution prevention program has been
worth at least $197,000 per year, and that aggregate savings over the years the new plant has
been in operation would be in the millions.
Company #30 is an autobody repair and painting operation which contacted OTA after receiving
a notice of non-compliance from DEP. There were many opportunities for source reduction and
detailed financial information showing a very favorable return on investment for solvent recovery
equipment (95 percent after 2 years, 239 percent after five years) was given to the firm by OTA's
financial analyst. In addition, several recommendations were made for improved housekeeping
methods that would help solve the company's compliance problems which included open drums,
lack of labels on hazardous waste containers, and floor drains leading to the ground. There has
been no follow up with this company as yet.
Company #31 is not a private company but a publicly-owned sewage treatment facility, the
Greater Lawrence Sanitary District. See attached case study.
Company #32, a producer of tags and labels, learned about OTA's services from the
Massachusetts DEP. Although it used perchlorethylene in its plating process, the company did
not have a compliance problem; the environmental manager sought OTA's help in general waste
disposal and environmental improvement issues.
After consulting with OTA technical staff, the firm eliminated perc and switched to a non-toxic
cleanser called "Solvit" that also is less expensive than perc. The new cleanser costs half of the
price of perc ($6/gallon as opposed to $12/gallon for perc) and the firm uses less than half as
much (estimated 2,000 Ibs/yr as opposed to 5,000 Ibs/yr of perc). Thus, the company saves
roughly $3,000 a year in chemical costs alone, and has eliminated use of a VOC.
The environmental manager says he sees great benefit in preventing exposure of employees to
perc. Although the firm's use of perc was within regulatory guidelines, he knew "perc was bad."
"We basically (switched from perc) for the health and safety of our employees. It's just nicer not
to have to deal with it." Among other benefits, the firm no longer has to buy special safety
gloves at $40 a pair that were issued to employees working with perc, he says.
The environmental manager credits OTA with helping him properly dispose of aging chemicals
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that had been stored in his plant in addition to steering him toward the non-toxic cleaner. He also
said OTA helped him understand his responsibilities as a small quantity generator (SQG) and
verified that he was correctly disposing of waste ink.
"OTA was very knowledgeable, and if they didn't have the information on something they knew
where to get it. I needed help and they were able to give it to me."
Company #33 is Runtal North America Inc., a manufacturer of radiators for residential and
commercial use. Deepak Peshori, operations manager, said he sought OTA's assistance for
general operations review "to be proactive rather than reactive" on environmental operations and
compliance.
Peshori said his company followed OTA's suggestion to install conductivity meters in the rinse
system, allowing recirculation of the rinse water and reducing the amount of discharge. This
system also allows for automated monitoring of pH and addition of hydrochloric acid (HC1),
eliminating the need for a person to monitor the system and add the acid. He estimated the firm
now saves between $10,000 and $15,000 a year in the purchase and disposal of HC1.
Peshori said the company's 1995 budget will include money to pay for suggestions that OTA
made for improving painting operations, including the mixing of paints in-house and the
installation of a spray paint gun washing system to reduce VOCs. He said the firm is working
with suppliers to find a high solid paint that allows more coverage with less paint, reducing VOC
pollutants. He estimates capital expenses involved to be up to $60,000.
Note:
As a result of the formation of the Merrimack Business Environmental Network and its activities,
attendees at meetings and conferences have many of the above stories and the stories of other
companies, notably, how AT&T and Raytheon replaced freon cleaning with biologically derived
materials (see attached news article), and how Hadco utilized the ROMAR process for removal
of heavy metals from chelated solutions. (See attachment).
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NEW HAMPSHIRE COMPANIES
A majority of the facilities have either implemented or are planning to implement
recommendations received from the NHPPP. Very few of the companies that had implemented
recommendations actually attempted to measure the amount of pollution reduced or money saved
from implementation.
Another finding is that the vast majority of companies that worked with the NHPPP stated that
they were very pleased with the service given to them and that they would not hesitate to call on
the program again or recommend the program to other businesses.
It is also important to note that the New Hampshire Pollution Prevention Program has responded
to a number of referrals from POTW officials in the Merrimack Watershed, and direct requests
for assistance. These referrals and requests resulted in appropriate information packets being
compiled and sent by NHPPP staff.
#1. A PLATING JOB SHOP
This facility provides plating of copper, nickel, and electroless nickel and chrome on various
metal parts furnished by others. Upon visiting the site, NHPPP staff found that the facility
already employed the following pollution prevention technologies: closed loop & ion exchange,
counter-current rinsing, water reuse, cyanide-free electroless copper, filter press, and evaporation'
NHPPP staff made some recommendations for minor improvements, but for the most part the
facility was generating very little waste. Due to the exemplary nature of its operations the
NHPPP approached the company to serve as a training site for the Program's retired engineers.
The company agreed and was subsequently used for that purpose.
#2. AN ALUMINUM FOUNDRY
This medium sized facility produces investment castings primarily made of aluminum, brass, and
magnesium. Approximately 220 people are employed at the facility which operates 3 shifts, 5
days per week. The facility operates on a job shop basis as a result of the repeat work that
developed over a long period of time. NHPPP staff and engineers visited the site and reviewed
the principal operations and waste streams. The NHPPP staff found that the facility had an active
program to reduce process wastes, but that opportunities existed for reducing/eliminating CFC's
through alternative mold release practices. Other potential waste reduction opportunities included
the areas of: water reuse, heat recovery, casting waste. Follow-up contact with the facility
indicated that they had implemented some minor changes, but felt that they lacked financial
resources and time to implement the more complex projects.
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#3. AN ALUMINUM HEAT SINK ANODIZER/FABRICATOR
This company was visited by NHPPP staff and retired engineers as part of the training program
for the engineers. The facility purchases and processes aluminum extruded stock. In addition to
an extensive machining operation, a substantial portion of the operations involve anodizing and
chromating processes. The facility generates 15 unique waste streams as part of its operations.
The NHPPP team found that the facility already employed several waste reduction measures such
as counter-current rinsing, rack drainage intervals, precisely controlled robotic operations and the
use of water-based coolants on a number of machines. NHPPP team members identified
additional areas for potential waste reduction including: replacing the current degreasing operation
with an aqueous-based system; separating hazardous and non-hazardous liquid waste streams;
eliminating or reducing the need for large quantities of speedi-dri through employee training and
use of re-useable absorbents; and converting the machining operations to water-based coolants.
Preliminary follow-up indicated that the company will be implementing the recommendations of
the NHPPP by replacing a perchlorethylene vapor degreaser with an aqueous wash system, and
will be reducing the use of clay absorbents through drip pans and good operating practices. They
are also researching process modifications in their anodizing operation. Subsequent follow-up
indicated that the facility would be attempting to measure actual reductions in waste sometime
in the near future.
#4. A PRINTED CIRCUIT BOARD MANUFACTURER
This company is a small custom printed circuit board job shop employing a staff of 25. The
facility specializes in hard-layer, multi-sided printed circuit boards. The main waste generating
processes consist of electroplating, electroless plating, etching, and wastewater treatment. The
company already employs a number of pollution prevention techniques which include
counter-current rinsing, proper tank layout, bath monitoring, etc. The company also has a large
ultrafiltration unit in conjunction with standard wastewater treatment. The NHPPP identified
pollution prevention opportunities in the areas of: drag-out reduction, wastewater segregation,
water reuse, and metals recovery. Follow-up indicated that the company had implemented some
of the NHPPP's recommendations, reduced it's water usage by 1/3, and was still working on
implementing some of the more complex recommendations.
#5. A POTATO CHIP MANUFACTURER
Based upon a referral from the Greater Lawrence Sanitary District the NHPPP team visited this
small manufacturer of potato chips. The company was purported to have an oil/grease violation
and was being surcharged for BOD and TSS. Lab analysis indicated that the type and source
of the oil/grease was potato starch and would not be a problem for GLSD. Because of the lab
results and the cooperation exhibited by the company in working with both EPA and the NHPPP
(a report was drafted to address the discharge problem), the company was removed from the
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GLSD regulatory system.
#6. AN ELECTRONICS PRODUCT DISPOSITION CENTER
This facility is the site of an extensive demanufacturing operation which was developed to ensure
regulatory compliance, and compliance with corporate "green" philosophies. The site visit by the
NHPPP team was primarily conducted to observe this company's impressive inventory
management system and the product distribution, disassembly, and disposal protocol. Program
elements included vendor takeback, Design for the Environment, packaging waste reduction,
and ODC elimination.
#7. A CIRCUIT BOARD ASSEMBLER
This company employs 35 people and manufactures small circuit board assemblies and
electronically controlled components such as valve actuators. Work at the facility is done on a
contractual basis, and the company does not manufacture either the circuit boards or components
used in the assembly process. NHPPP staff found that the major area of concern was reduction
of air emissions from the wave solder area. Emissions of concern were generated by the use of
CFC-113, ethyl alcohol, and methyl alcohol. With information provided by the NHPPP, the
company opted to research the feasibility of eliminating its freon degreasing unit. Follow-up
indicates that the company is still conducting research and has not yet implemented the NHPPP's
recommendations due to the complex nature of the processes at the plant.
#8. A SAPPHIRE PRODUCTS MANUFACTURER
This facility employs 95 people and specializes in advanced sapphire crystal technology. Through
the use of a patented crystal growth process the company grows sapphire tubes, rods, ribbons,
fibers and 3-dimensional shapes. On-site finishing capabilities include machining, grinding, and
polishing. These finishing processes generate the majority of the waste. The NHPPP was called
in to determine pollution prevention opportunities for the sapphire grinding operation. Follow-up
indicates that the grinding operation has been sub-contracted off-site. The company also
implemented a used oil recycling program and on-site solvent recovery, and has little waste
additional waste. Limited opportunities may exist with alternative machining and degreasing
techniques.
#9. A MICRO-CIRCUIT BOARD MANUFACTURER
The NHPPP visited this site based upon a referral from the Greater Lawrence Sanitary District
(GLSD). The small micro-circuit board manufacturer had relocated and was subject to GLSD
jurisdiction as a categorical industry, regardless of its extremely deminimus etching discharge
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(gold, TiW, TaN, Nickel-Chrome). The NHPPP was called in to work with the company to
determine closed-loop possibilities. During the site visit the NHPPP team discovered that the
actual process wastewater was substantially lower than the 30-50 gallons per week indicated on
the GLSD's Industrial Waste Survey. The discharge rate actually took into account all water
discharges including sanitary, non-contact cooling, and process wastewater. The NHPPP suggested
that the company test and measure the actual amount of the process wastewater discharge in order
to better characterize the problem, and consider close-looping the discharge. Follow-up indicated
that the company has gone to a close-loop discharge and is no longer subject to GLSD regulation.
#10. A PRINTING OPERATION
This company is a large contract printer which employs approximately 300 people on a 3-shift
basis. Operations normally run 5 days per week and perform both sheet and web-fed, off-set
lithographic printing. The NHPPP team visited the site and found that the company had already
implemented several pollution prevention initiatives including ink reuse and recycling, silver
recovery, water conservation, use of soy-based inks, and alternative plate-making processes. The
company was primarily interested in reducing the VOC, solvent, and rag wastes associated with
the "blanket wash" operation. The NHPPP provided information and recommendations on solvent
alternatives, solvent conservation, and reduction in solvent-soaked rags. It seems that production
quality and efficiency is not acceptable when the available solvent substitutes are used, and that
more research needs to be done on an industry wide basis. Follow-up indicates that the company
has implemented some recommendations, (they purchased a centrifuge for rags), but that they are
still researching solvent alternatives.
#11. AN ELECTRICAL WIRE MANUFACTURER
This company manufactures medium to high voltage power and aerial cables. The NHPPP was
contacted primarily to look at the cable degreasing process. Raw aluminum cable is delivered on
large spools for coating and finishing. When the manufacturer draws the aluminum through the
dies to create the proper thickness, the aluminum is first coated with an oil-based lubricant to
facilitate the drawing. This oil layer, although thin, must be removed in order to insure proper
bonding of the plastic and rubber coatings which are applied. In the past degreasing of the cable
feed stock was accomplished by using solvents. The company did switch from a solvent to a
continuous feed sodium hydroxide bath with ultrasonic agitation. There were some problems with
this process because it slows the cable feed rate, and sodium hydroxide is hazardous (due to high
pH), although it is not an ozone depleter. Follow-up indicates that the company is still researching
alternatives to the sodium hydroxide process.
#12. A MANUFACTURER OF PRECISION MOLDED PARTS
This company is a small job shop which produces precision molded rubber and rubber/metal
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bonded parts and employs 45 people. The company was referred to the NHPPP after a routine
inspection by the DBS Winnepesauke River Basin Bureau Industrial Pretreatment Coordinator
(Franklin WWTF). The inspector found that opportunities existed for pollution prevention. The
waste generating process starts with the creation of metal washers which are produced from cold
rolled steel fed into a stamping machine while lubricant is applied. Vapor degreasing with
solvents is used to clean some parts, while others are treated using iron phosphate. Spray
adhesives which generate air emissions and hazardous filters are also used in the process.
Following the site visit the NHPPP issued a report to the company which contained many
pollution prevention recommendations. At this time the company is reviewing the report, which
will be finalized after the review and comment period is completed.
#13. A MANUFACTURER OF WIRE RESISTORS
This company produces wire wound resistors for the electronics industry. The NHPPP was
contacted primarily to review the resistor cleaning process using sodium hydroxide. Problems
with the process included: at the end of its useful life, the cleaning solution exceeds the TCLP
limit for lead, requiring that it be handled as a hazardous waste; and a small number of parts
exhibit poor adhesion of the labeling inks. The NHPPP visited the site, and completed a report
which was forwarded to the company. The report contained four potential solutions to the
cleaning problem which ranged from elimination of the need to clean through a change in
manufacturing process through improvements to the existing cleaning process. At this time the
company is still considering whether to implement any of the recommendations contained in the
report.
#14. AN ARMY NATIONAL GUARD FACILITY
This facility's main function is the maintenance and servicing of helicopters and fixed-wing
aircraft. Other services provided at the facility include a small print shop which provides printed
material for all NH National Guard facilities, and support and maintenance for various motor
vehicles and pieces of equipment. Services are provided by a staff of 225 military and civilian
personnel. In 1992 the facility manifested over 19,000 pounds of hazardous waste, including oil,
diesel fuel, antifreeze, solvents, paints, gasoline, and grease. The NHPPP was contacted by the
Army National Guard's Environmental Specialist to assist in waste minimization efforts that had
been initiated at the facility. NHPPP staff visited the site and developed pollution prevention
recommendations for each of the identified waste streams and issued a report. Follow-up indicated
that the ANG has organized a Task Force to work on implementation of the recommendations.
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TABLE OF RESULTS
The following table sets forth data that was obtained by telephone survey, team interview and
file revtew. The compan.es reported on various aspects of their projects, some reporting ^i±
from avo,ded waste d.sposal, and some including estimations of related avings such as reducfd
purchase costs and less time spent on regulatory compliance. Most of the figures below Ire on y
™
Unspecified numbers are pounds. ND means No Data.
Massachusetts Companies
Facility
1. Metal
Stamper
2. Electronic
Components
3. Plater
4. Consumer
Products
5. Adhesives
6. Metal
(Babco)
7. Tanner
8. Metal
Action Taken
A. Aqueous subst.
for TCE B. acid
dumping elim.
A. 127,500 TCA/freon
B. 49,000 33/50 chems
Chem use reduced
Results
Comments
A. Purch. cost decreased OTA "ext. helpful"
Safety increased Avoided monitoring
B. $2,500
A. $810,900
$13,000
treatment costs
Water use down 87% ND supplied
40% less drummed waste
by using conical tanks
A. Odor elimination
B. Reformulation
reduced toluene
A. Ultrasonic subst.
for TCA B. Coolant,
testing chems elim.
Performed trial of
new techn application
(Venturi)
A. Alum, disch. down
B. New monitoring
A. Nuisance av
B. $15,000
A. $16,300
Water not restored
sufficiently for
reuse
A. Co. now in
compliance. B. $500
Co. calculates NPV
$5.8 million. OTA
credited with
project start
Mitigating several
thousand dollar fine
Reluctant to
publicize
Bd Health referral
B. Co. cites
worker safety
A. Pur & dsp. costs
ND. Adopting
Chem tracking
Co. wd not follow
up though OTA felt
problem resolvable
Co. downplays P2,
cites compl. as
motivation
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Facility
Action Taken
Results
Comments
9. Circuit
Board (Altern.
Circuit Tech.)
19. Plastics
20. Plastic
21. Plater
22. Plater
A. 320,000 etch
B. 2 million gallons
water saved, metal
recovery, other
A. $7,200
B. Several $1,000
expected
A. Dsp costs
TURI grant helped
10. Painter
11. Electronic
Components
(Brush Wellman)
12. Machine
Shop
13. Semiconduc.
14. Plater
15. Industrial
Laundry
16. Printer
(FC Meyer)
17. Electronic
Components
18. Air Systems
Thinner purch. down
A. TCA/freon elim.
B. Bath life extension
HC1 down 40%, 10,000
Unknown sources
Al and Se
Co. considering
closed loop
Co. setting up
Near flow limits
A. Had elim. 279.5
tons VOCs B. 160,000
ink wastewater
NMP (ODS) subst.
for TCA
Regulatory referall
$5,000
ND
B. $35,000
OTA analysis
identified sources
OTA sought reg.
clarification
Rec made
Rec made
A. ND on savings
B. $46,800 avoided
dsp csts (down 35%)
ND on savings
Rec made
VOC compl sav
not estimated
A. Further elim.
expected to save
$40,000
ND on implem.
Co. moved
DEP working on
Zero Discharge
Permit
ND on implem.
ND on implem.
A. Maj. air permit avoided
B. Water use down
Appreciative of
OTA
No response -
letter to CEO
A. Had elim. 12 tons
TCA (down 85%)
B. New paint process
reduced VOCs
Blowing agent tox
Visit in advance of
potential inspection
Hazards identified
POTW referral key
A. $60,000
B. Mfg costs down
30% - $250,000
Rec made
Rec made
Some safety, P2
measures implem.
Did not like rec
Facility burned
down
Not imm. haz but
illus. need for
enforcement
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Facility
23. Metal
stamper
24. Circuit
Board
(IMI)
Action Taken
Results
Compliance & P2 Rec made
Improved HW storage
25. Furniture
26. Electronic
Components
27. Machine
Shop
28. Electronic
Components
A. Cut process steps
50% B. TCE down
8,0000 C. 64% less
water D. Recovering
acids
P2 info requested
Had elim. TCA
Residue problem TCE
Time & labor sav
B. $4,000+
Rec. made on
compliance
Comments
Co. investigating
A. ND on $
B. Worker safety cited
C. Considering
closed loop process
D. Cites reg. barrier
to recycling (paperwork)
Co. did not
appreciate noting
deficiencies
Co. considering OTA discour. TCE
ND on implement.
Compliance, closed loop Closed loop
recommendations implemented
Had elim. TCA
OTA rec on subst.
ND on savings
Co. enthusiastic
Decided to use
other product
29. Coating Mfr A. Had elim. VOCs 117 A. $197,000
(Cabot) tons 90% down B. B. Rec implemen.
Minor improvem. rec
Co shared info
at MBEN conf
30. Auto
31. Sewage
Treatment
(GLSD)
32. Graphics
33. Radiators
(Runtal)
Printer
(Ameri craft)
Computer
(Tristar)
Rec. solv. recovery
17,292 potassium
permanganate
Elim. perc
Chem disposal
Monitoring rinse $10,000
conductiv., pH, other
Financial analysis
w/ OTA help
ND on implem.
$24,036 purchase
costs avoided
$3,000
purchase
costs avoided
Had el VOC 88% $85,736
nonalcohol fountain
solution
200,000 Sulfuric elim. $200,000
Ended calendar dumping
Process monitoring
Allowed greater
septage intake
worth >$ 100,000
Cites worker safety
Valued OTA help
Working on rec.
Co. proactive in
seeking help
Co. included est.
$35,000 from effic.
and permit cst avoided
Purchase, dsp costs down
Significant use reduction
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New Hampshire Companies
Facility
Plating Job Shop
Aluminum Foundry
Aluminum Works
Printed Circuit
Board
Potato Chips
Electronics
Circuit Board
Sapphire Products
Micro-circuit
Board
Printer
Electrical Wire
Molded Parts
Wire Resistors
Military
Action Taken Results
Had closed loop Became training site
Some
implementation
Implementing
aqueous wash,
other process
modifications
Comments
Co. cited financial
resources and time
constraints
Co. is measuring
waste reduction
Had program; rec
altern. mold release,
water reuse, heat
recovery, other
rec. aqueous, waste
stream segregation,
water-based coolant
Had good rinsing,
ultrafiltration; rec
drag-out reduction
wastewater segregation
water reuse, metal
recovery
Oil and grease Analysis showed Company no longer
grease was starch facing enforcement
Implementation: Ongoing program
water use
reduced 33%
Vendor takeback site Use as example
CFCs and VOCs Researching freon
elimination
Ongoing
Rec made
Used oil recycling,
solvent recovery
Rec. closed loop Company implemented
Had soy inks, ink reuse Some implement.;
water conservation bought centrifuge
innov. processes; rec.
solvent alternatives
Switch to NaOH from Still working
solvents has problems
Ongoing
Spray adhesives
Lead in cleaner
Vehicle, paint wastes
Reviewing rec.
Rec. made
Rec. made
Referred by inspector
Reviewing
Task force organized
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THE MERRIMACK PROJECT
POLICY CONSIDERATIONS
Part III
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POLICY RECOMMENDATIONS - New Hampshire
The following recommendations are based on experience gained through implementing the
Merrimack River Industrial Pollution Prevention Project.
1. Provide increased grant flexibility. In order to institutionalize pollution prevention,
state regulatory agencies need to have increased flexibility in the ongoing media grant
programs. Recently, there have been positive steps in this direction, and EPA should
continue to work with the states to encourage new and innovative pollution prevention
projects through the grant flexibility process.
2. Re-evaluate measures of success. Many of the regulatory programs within the
Department of Environmental Services are federally supported, and success of those
programs is measured by counting "beans" such as the number of inspections performed
or enforcement actions taken. It is the opinion of NHDES that in order for pollution
prevention to succeed, emphasis needs to be placed on re-evaluating the measures of
success, so that they focus more on compliance and pollution reduction. This will require
a willingness by EPA to restructure the bean counting process, perhaps by allowing
counting of things like actual reductions in pollution and technical assistance visits.
3. Use the established POTW-industry relationship to promote P2. Oftentimes a POTW
Pretreatment Coordinator already has an established working relationship with the
industries that he/she regulates. This relationship provides an excellent opportunity to
further the goals of pollution prevention. In most instances the IPP Coordinator has both
the economic and environmental needs of the community in mind. Industries that are
under regulation know that the municipality would like to see them remain as viable
enterprises. In the case of pretreatment industries, they are probably more likely to listen
to recommendations by the local IPP that they deal with regularly, than some state or
federal regulator.
4. Identify and work to eliminate regulatory barriers/disincentives to P2. Within many
state and federal agencies, especially regulatory agencies, there are numerous existing
barriers and disincentives to the implementation of pollution prevention. Some potential
sources of barriers include: existing state or EPA statutes and regulations; state or federal
policies or procedures; and institutional practices, attitudes or behaviors which have
developed without critical evaluation. In order to implement P2 to the fullest extent
possible, EPA and the states should continue efforts to identify existing barriers within
the regulatory environment and work to resolve those barriers as appropriate.
5. Address targeting & information issues. In attempting to target industries for the
Merrimack Project, NH project staff had a difficult time accessing and interpreting water
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quality data, as well as information on individual facilities. This was especially true when
trying to cross reference information, such as TRI reporters and NPDES dischargers Such
cross referencing had to be done manually with lists on hardcopy. To make targeting of
technical assistance and pollution prevention efforts more effective, EPA and the states
should work toward more comprehensive, "user- friendly" databases. NHDES is currently
in the process of inventorying all existing data and information management systems
within the department, and developing specifications for a centralized, multi-media
system, which will contain certain key attributes. Programs and divisions within DES will
still maintain their databases, however, the centralized system will provide "whole facility-
information which managers can use to target assistance and compliance efforts.
6 Compliance assistance. Experience gained through the Merrimack Project indicates
that compliance issues are an important part of technical assistance. Many small and
medium sized companies want to comply with environmental laws, but need some heb
in wading through the regulations. EPA and the states should consider developing
programs for their technical assistance staff which include regulatory compliance training
Outreach efforts that combine regulatory and pollution prevention information are the
most effective way to facilitate compliance with environmental laws.
7 Continue to encourage and support multi-media efforts. EPA and several states have
begun to work on multi-media permitting and inspection projects. NHDES will likelv do
so in the near future This process can prove to be much more effective and efficient than
the more traditional single media approach, when focused on the appropriate facilities
EPA should continue to work with the states to facilitate multi-media pilot projects Such
efforts hinge upon grant flexibility issues and revising measures of success.
*. Continue to encourage and support geographic initiatives. Pollution and natural
resources do not respect political boundaries. Watershed-based projects such as the
Mernmack Project and the Merrimack River Initiative provide an ideal opportunity for
all the constituents within a geographic area to transcend political boundaries and rally
C encoura8ed and supported
9 Encourage and support new and innovative partnerships. Through the Merrimack
Project some new and unique partnerships were formed between state and private entities
The Merrimack Business Environmental Network (MBEN) and the NHDES Merrimack
River biomomtoring project are two examples. Efforts such as these are a very effective
way to maximize resources and promote pollution prevention. EPA should work with the
states to create and foster more partnerships between government and private entities
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CONCLUSIONS
This project has been essential in helping the New Hampshire Department of
Environmental Services jumpstart the process of institutionalizing pollution prevention. Through
this project the department has been able to experiment with different approaches and frame the
questions which need to be addressed. The project has also provided an forum to identify
opportunities and barriers in implementing pollution prevention in a regulatory agency.
Working collaboratively with staff from the MA Office of Technical Assistance has been
a very satisfying and rewarding experience. This project has proven that agencies from two
different states can work together to accomplish common goals and objectives, even though their
program structures and regulatory status may be different. Likewise, working with EPA staff on
the Merrimack Project has been very beneficial. EPA staff provided flexibility as well as
guidance, both of which were greatly appreciated. Establishing new relationships and forming
innovative partnerships is what this project was all about. It seems almost certain that the
relationships that have been established will continue well beyond the life of the Merrimack
Project, and extend into many other projects and activities.
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POLICY RECOMMENDATIONS - Massachusetts
The Merrimack Project has resulted in the formation of working relationships between private
companies, POTWs, state enforcement officials, local officials, and trade and commercial
associations, and an increased emphasis by all of the above on pollution prevention. An integral
part of these relationships has been an ongoing discussion concerning suggestions for policy
initiatives, changes, and reviews. It is common to speak of changing the corporate culture that
emphasizes business as usual in order to reorient towards prevention. A corresponding culture
change in government operations is also necessary. Carol Browner's recent pollution prevention
policy declarations are dramatic examples of what can happen. In June, 1993, Browner issued
a Pollution Prevention Policy Statement which said in part: "We must not hesitate to seek
changes in federal environmental law that will encourage investment in source reduction."
Massachusetts recommendations for incorporating pollution prevention into the regulation of
wastewater discharges are set forth below.
1. Review categorical discharge limits wherever they are now set according to expectations
of what an industry can achieve, where those expectations have been measured in the past
by the observed performance of conventional treatment methods, and reset them according
to what known pollution prevention technologies and practices can economically achieve
Follow technological developments and afford opportunities for regulated entities to supply
cost information. Ratchet limits down when technologically and economically feasible
according to frequent reviews.
Rely on stringent water quality-based local limits to drive movement towards preventive
techniques, but consider a flexible approach which allows for compliance on condition that
a company pursues aggressive prevention and provides documentation of such a preventive
program with frequent updates. Require such updates as a condition for obtaining anv
waivers or flexibility for economic infeasibility. In states where there is a requirement for
F2 planning, these may be incorporated into orders.
The OTA's first program of delivering technical assistance was successful in large part because
the targetted community was facing a substantial tightening of limits on NPDES discharges The
pressure of regulation drives companies into the camp of the technical assistance programs A
certain sector does P2 because they are well informed and understand its value A larger sector
does P2 because they have to.
Effluent limits should be set according to what is technically achievable. But pollution
prevention opportunities may be very process or company specific. Some benchmarks can be
obtained by evaluating what is technologically achievable by implementation of known
technologies to prevent pollution or for recovery of materials, such as-
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Electrolytic recovery
Ion exchange
Reverse osmosis
Ultra and other forms of filtration
Enclosed evaporation
ROMAR process (see attachment)
Electrodialysis
In addition, companies have achieved substantial discharge reductions by implementing water
conservation, process monitoring and control of process parameters, drag-out capture, advanced
rinsing techniques such as cascade, reactive, fog, high-volume low pressure rinsing, and the use
of air knives and vacuums to remove contaminants before rinsing.
There are also material input substitution opportunities in many industries, due to rapidly
developing product reformulations to avoid pollution liabilities.
EPA could incorporate evaluation of what these known technologies can achieve to the process
of setting standards, and should frequently revisit the issue in order to capture rapid developments
in this field.
The Massachusetts Toxics Use Reduction Act gives the state the authority to set performance
standards for particular processes or industries. This is to be done upon a finding that most
companies performing a particular process step are able to do so with low effluent rates, and that
other companies performing the same step should be able to achieve the same low rate.
Companies are given the opportunity to demonstrate that they cannot achieve these rates due to
their special conditions or economic situation. (The burden is upon them to make such a
showing). This approach is more equitable than requiring that they meet a performance standard
that may not be pertinent to them, or close up shop.
OTA recommends that performance standards be flexible, taking into consideration the difference
in applicability of pollution prevention options that involve process changes. Such flexible
standards put the burden on a company to show that it cannot meet a standard and stay in
business; once a company does this, an interim limit less than the standard can be set for the
company, with the stipulation that the firm provide frequent progress reports demonstrating that
it is aggressively pursuing P2 opportunities. Such a system allows the regulatory agency to set
limits as tight as they need them to be for environmental protection, but avoids putting companies
out of business when they have demonstrated that they are making a real effort to achieve
compliance.
2. Assert the importance of equitable principles in the enforcement of environmental laws.
(This point refers not to "environmental equity" as the term "environmental justice" is
popularly used, but to ensuring that enforcement of environmental laws is perceived as fair
by the regulated community). Conduct a dialogue with the regulated community designed
to enhance the evolution of environmental requirements.
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The environmental agencies must retain the power to shut down businesses in order to protect
the environment but if this power is designed carefully so as to prevent its inappropriate
application it is less likely to be challenged, resisted, or eroded. If companies perceive the law
as reasonable, they will better accept it and focus their energies on compliance, rather than
fighting the law itself on a political stage. Companies perceive inflexibility, combined with the
power to shut down business, as unfair. There are many ways to address this problem, and many
different mechanisms that could be used to ensure that the use of the power to shut down
business is fair and that agency officials have and use appropriate flexibility in the use of all their
powers.
Companies frequently comment that enforcement is inequitable in that those known to the
agencies are visited repeatedly, whereas the agencies are not perceived to be sufficiently
aggressive in finding those who are gaining economic advantage by not spending money on
compliance. Whether or not this is true, agencies need to address a widespread perception.
Companies comment that rules are hard to find and understand, that agencies do not do enough
to inform of their existence, or make them easy to follow. Companies also find frustration in
unresolved inconsistencies concerning policy, and a wide variation in requirements and policies
between jurisdictions. ^
Another equitable issue is that the limit for any discharger can be lower than what comes into
their facility from municipal supplies. OTA frequently encounters business claims that the city
water they take in would not meet discharge limits. City officials and environmental regulators
typically respond to this problem by commenting that they are aware of the problem but there
is nothing they can do about it. Perhaps a waiver system could be developed for situations where
the violation is due to incoming water.
Continuous dialogue with the regulated community would seem to be the place to begin an effort
to address perceptions of inequity, if it is conducted as an attempt to address problems and not
manage perceptions. Enforcement agencies can commit to clarification of requirements and to
better notice communication, and uniformity of policy. Agencies can commit to ongoing
evaluation of how well their rules are working to accomplish their ends. Agencies can adopt a
strategy that admits the regulatory system is not perfect. (The Common Sense Initiative is a
welcome example). This must be done without relinquishment of authority. It is imperative that
environmental agencies engage in the business/government dialogue in furtherance not in
derogation of, agency missions.
The agency should anticipate issues and come to the table as well prepared as possible with
potential options and alternative solutions. If at a dialogue meeting industry representatives take
officials to task for delays in granting recycling permits, the agency should be prepared to
respond. If the agency has set up a task force to look at this or related problems, reporting of
this fact would be helpful. If the agency has determined ahead of time that it welcomes input
to this task force from outside of the agency, it would be able at that meeting to invite the
participation of those offering criticism.
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3. Establish technical assistance programs that integrate with enforcement in a manner that
does not compromise either. Expressly declare that EPA is adopting the new, proven tool
of technical assistance.
The consideration of the provision of technical assistance has led, in Region I EPA, to a vigorous
discussion of how such programs would relate to enforcement. Often, in these discussions, there
has been a mistaken assumption that technical assistance detracts from enforcement, or that
providing technical assistance means curtailing or interrupting enforcement activities. OTA
believes that enforcement should remain vigorous and visible, as it is a prime motivator for
companies to focus on pollution prevention and to seek out technical assistance.
However, when OTA has been perceived by the regulated community as exchanging onsite visit
information with the enforcement agency, there has often been a lack of trust, and a reduced rate
of use of OTA's services. In order to encourage companies to use its services, OTA has often
had to expressly counter the assumption that it provides information to enforcing agencies. The
Toxics Use Reduction Act requires that OTA keep the company-specific information from its
onsite visits confidential, and citing this provision has been invaluable in helping the program to
win trust and acceptance. OTA has worked state-wide with more than 400 companies since 1990,
which is a very high rate of utility. Other programs have cited the inability to provide an
assurance of confidentiality as a hindrance in gaining company cooperation.
EPA could declare that it is formally adopting technical assistance as a new tool. This tool is
a proven method of achieving environmental progress. EPA New England has established an
assistance team.
A separate, dedicated program is only one method of technical assistance delivery. OSHA's
Consultation program represents another tested method. This program consists of voluntary
requests for assistance, which are followed up by site visits to ensure that violations are rectified.
There is no penalty for violations at the first visit. There are potential variations on this theme.
(Please see attached article on models of interaction between technical assistance and
enforcement). In addition, there is the option of training inspectors to make P2 suggestions.
Inspectors must be careful not to phrase these suggestions in terms of a command. We
recommend that if this option is chosen, great emphasis be placed on the use of inquiry, rather
than provision of advice, to prompt pollution prevention awareness. Inspectors can be trained
to ask appropriate questions, such as "have you investigated methods of recovering those metals
from the waste stream, rather than precipitating them into a sludge", or "are you aware that there
is equipment for condensing vapors, which if it is appropriate and cost-effective in your process,
could obviate the need for a scrubber or thermal oxidation unit."
Enforcement personnel can also refer to technical assistance programs when they notice violations
or opportunities for P2; the TA program staff can train inspectors in how to spot these
opportunities. MA DEP now includes such referrals in its notices of noncompliance.
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The technical assistance tool demonstrably improves the relationship of the government to the
regulated community. Its very existence promotes the idea of cooperation and common endeavor,
which is relevant to addressing environmental problems because they affect everyone. The
assistance mode also promotes the better education of enforcing agencies, because government
personnel learn not only about the technical aspects of practices which are the source of pollution,
but they learn how regulations-work in practice from the perspective of the regulated entities'
Those receiving assistance are more likely to discuss problems in real terms, rather than couch
them in terms designed to protect them from liability. Thus information concerning how well
government programs are working flows from assistance programs and can benefit enforcement
programs. For example, OTA has learned that many companies are reluctant to cease water
discharges, because they might become subject to RCRA enforcement for treatment without a part
B license. This "closed loop closed door" problem was never confided to enforcement personnel,
but only to staff of the assistance program. Massachusetts DEP has formed a committee to
investigate what can be done to remove the obstacles to zero discharge water systems.
If enforcement agencies do attempt to establish technical assistance programs, they should be
permitted flexibility in EPA's basic grants program. Options under the grant agreement might
include offering credit for multimedia inspections, credit for educational activities, credit for
technical assistance, credit for research, and credit for taking the time for reorganization. Basic
grant compliance measurements that adhere to a number of enforcement actions should be
reviewed. It is possible to observe that each enforcement action is a failure, not a measure of
success. Success should be measured by rates of compliance, or reductions of pollution.
Basic grants should be provided for technical assistance programs without the current fifty percent
match provision. This approach was based on the idea that a state should be willing to commit
to the program. But technical assistance programs should be made an integral part of the
environmental effort, and this can happen if they are seen as necessary. If so, they deserve basic
grant funding, no match requirement, year after year; the same kind of funding as the basic media
programs. Only stable funding will produce healthy programs.
This grant money should not be provided only to the enforcement agencies. States should be
given the option to establish the technical assistance in other bodies, such as quasi-governmental
entities, as affiliated with universities, as affiliated with trade groups, or centered out of a
nonregulatory government agency. Notices to states of the availability of money for these
purposes should be given wide distribution.
4. Use enforcement activities which require and/or encourage P2 and/or P2 reporting.
Compliance orders should never simply order control technologies, but should do one of two
things instead: either require P2 investigations or provide optional methods for coming into
compliance. The Chicopee POTW has issued compliance schedules which have allowed
companies to select one of three options for coming into compliance: they can implement control
technologies, recycling, or prevention.
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Enforcement agencies can issue orders which require P2 investigation. The Fall River wastewater
treatment facility has tried this with some success. Textile finishers were required to investigate
P2 rather than to conduct treatability studies, as conventional orders require. The companies did
conduct P2 investigations and did accomplish substantial reductions. The levels that they had to
achieve were one third of previous copper discharges. The pollution prevention techniques they
employed did not get them to that level, but this should not obscure the fact that the P2
investigations were required and were pursued and did accomplish substantial reductions.
Enforcement personnel may ask for information concerning chemical purchases, in order to
establish better controls at the discharge site on material accounting and handling, and to avoid
undetected discharges. Although POTWs may not have the authority to require this information,
they may still request it. Louis Valle of the Newburyport POTW has requested that some
companies submit to him information concerning raw materials that they bring onsite. He had
no authority to require this, but requested it, and received it. He has since written this
requirement into permits, which now gives him the authority to require the information. A
company that receives this scrutiny is probably more likely to control each container of chemicals
received. Total mass loading information is also useful. Companies can be requested to calculate
their total mass loading and submit this information. If it were made public, it would perhaps
serve as a significant incentive for reduction.
Companies can be offered the mass loading alternative in order to encourage them to adopt water
conservation. If there is no treatment on site, and a company is relying on water volume to dilute
concentrations to acceptable limits, then water conservation is not a viable option for that
company, unless they take the extra steps of installing treatment or water recovery. But short of
that, a company has no incentive to reduce their water use when it gives them a favorable dilution
factor. In some situations, it may be useful to consider a mass loading measurement as an
alternative limit - if the new concentration does not adversely affect receiving waters.
A facility that drops below the flow limits that define it as a "Significant Industrial User" may
no longer be subject to local limits, unless the facility can establish that they may have an impact
on the ability of the facility to meet its limits or function properly, or the facility has a system
in place for "minor permits". Many have no such system, although some do. There is no
consistency in the Merrimack Region among facilities concerning how "minors" are regulated.
However, the facility can still impose a "monitoring only" permit, which enables them to maintain
scrutiny over operations, and reestablish limits if necessary. In this context, POTWs can ask for
total pounds of material discharged as well as concentration, and if the concentration is not a
practical concern, the point at which scrutiny is accelerated (further monitoring required, or
perhaps actions to redefine the source as an SIU) would be a mass-based number.
"Junior" or "minor" permit systems, bearing fees large enough to cover administrative costs,
would have the advantage of educating all dischargers concerning their responsibilities towards
their local resources. These may be monitoring only permits, or may be based on the notification
requirements of the Domestic Sewage Study regulations. But perhaps EPA should consider
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giving POTWs the authority to institute limits on dischargers that fall below the SIU level.
Some of these small sources are not small, but still fall below the established designation for SIU.
A total mass loading definition for SIU could bring some noncategorical companies into the SIU
designation if they are below the flow limit but do have high quantity discharges.
5. Address Nonpoint and Small Pollution Sources (Diffuse Sources), and establish a
program to analyse the constituents of consumer products.
EPA's 1986 Report to Congress on the Discharge of Hazardous Wastes to Publicly Owned
Treatment Works (EPA/530-SW-86-004) observed that once pretreatment standards are met, "the
domestic contribution of hazardous metal will increase from 8 to 63 percent of total metals
loadings." It is increasingly recognized that as regulations evolve concerning industrial
wastewater sources, the proportionate contribution of contaminants from other sources rises. A
1992 study for the Massachusetts Water Resources Authority (Evaluation and Estimation of Toxic
Pollutants, February 1992) estimates that residential wastewater accounts for "over 20 percent of
the estimated annual total system load for copper, lead, zinc, chloroform, and surfactants", as well
as some organic compounds and petroleum hydrocarbons. In addition, source water was shown
to contribute significant loadings of copper and chloroform, and tap water was found to have
"large percentages of total quantified copper, lead, and zinc." Urban runoff was estimated to
contribute "over ten percent of total quantified lead, and significant loadings of copper, zinc, and
bis(2-ethylhexyl)phthalate." The study recommended more complete sampling of these sources.
The City and County of San Francisco's Consumer Products Heavy Metals Inventory. (August,
1991) concluded that with the exception of silver, 20 to 88 percent of the city's total heavy
metals originate from residential sources." These studies are indications that the contribution to
contamination of our water resources from nonindustrial sources is currently significant.
To address these sources, we recommend greater scrutiny: monitoring, testing, and actions to
increase public recognition of responsibility for local resources. Establishment of regulations
concerning discharges should be made applicable to nonindustrial sources where they are not
now, but enforcement of residential sources must be carried out in a manner quite different from
that applied to industrial and commercial sources.
One strategy is to provide financial assistance to homes and communities making changes in
water delivery systems to meet new Safe Drinking Water Act requirements. This program could
focus first on schools. Another strategy is to ban or restrict certain products. An example is the
registration to market drain cleaners is required by the state of Connecticut for drain cleaners.
Drain cleaners containing chlorinated solvents are simply not registered. This is an inverse ban
method - establishing a requirement for allowing discharge, and then not granting the permission
to certain products. This is also not a direct enforcement program focussed on households, but
a method of keeping certain products out of the household.
We recommend a devotion of resources not just to putting requirements in place but also to
education and the provision of services for hazardous consumer product collection. This should
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begin with recyclable products, such as antifreeze, oil, paint, solvents, and photographic
chemicals. Recycling these products will reduce the cost of collection.
Household and small generator collection and recycling centers may be funded by assessing a fee
on manufacturers, who may opt out of program if they are willing to introduce take-back centers.
The fee may be coordinated with a red dot or red label informing the consumer that the product
is a hazardous waste upon disposal, and that there is an opportunity for recycling or collecting
this waste.
For the small pollution source, it is not sufficient to establish requirements, because choices for
proper management may not be cost effective. At the same time, policies should discourage use
of certain products as well as convenient collection and disposal. For large companies, it may
be sufficient to put in place restrictions that raise the cost of management and disposal, and
thereby act as disincentives on use and waste generation. However, for households and small
businesses, the option of entering the commercial hazardous waste management system is not
feasible, because of its high cost. Actions should be taken to encourage the establishment of low
cost and convenient management systems.
In early 1993, OTA submitted a grant proposal to EPA Region I for a consumer product
evaluation program. The proposal was to establish a testing program which would look for
certain toxic constituents in products that often go down the drain as a result of ordinary use.
(The term Household Hazardous Waste (HHW) is not adequate to describe residential
contribution. Suppose a homeowner paints his house: the paint and thinner left over in a can is
household hazardous waste, but the paint and thinner washed off the brushes in the bathroom sink
will never be collected in a community HHW program). The proposal was to offer the testing
to a select community, and to manufacturers who wished to demonstrate that their products were
environmentally friendly. EPA Region I counsel expressed concerns about this proposal, so it
was withdrawn. The concerns were that EPA cannot be involved in the endorsement of any
product. Our intention was to avoid endorsements, and simply to let the analytical facts speak
for themselves. We urge EPA to review this issue. We suggest that chemical analysis is
unobjectionable, and that the public needs to know what they should buy. There is a lot of
misinformation on the market concerning what is environmentally friendly. An analytical
program would rectify a lot of false green marketing and reward those companies that do provide
better products.
EPA should work with the Federal Trade Commission to develop truth in advertising guidelines
for environmental labelling. This need not wait until such time as a labelling program or law has
been developed. Policy intended to curb outright falsehoods and base claims upon some form
of analysis can be put into place short of passing a green label law. FTA declarations that false
advertising will be curtailed will have a chilling effect on such practices.
Increasing analysis of loadings from communities, residences, apartment buildings, and areas of
concentrated runoff would also provide the basis for better programs to address these sources, and
contribute to a raising of consciousness about the effect on resources of ordinary activities.
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6. Increase perception of the environmental receptor as a resource and as an amenity.
At the June, 1993 Merrimack Initiative conference "Solutions for the Future, Actions for the
Present many attendees cited in working sessions the need to provide the connection between
people s actions and the river itself - as well as other resources affected by their actions Part
of this .s education of the sort that explains to people that when they dump oil on the ground or
in a storm drain it pollutes their own immediate environment; or that if they are concerned with
economic growth ,n their town, they should be concerned with reducing flows and loadings to
the oca sewage treatment facility, or with reductions in nutrient loadings from septage or lawn
fertilization. But another part of this is related to one of the original environmental programs
now not as prominent as it once was: beautification.
Beautification parks, green buffer zoning, boat races, and programs designed to increase
appreciation of an amemty such as the Merrimack River, increase the likelihood that people will
voluntarily curtail actions that affect the resource they have come to enjoy. The Merrimack
Business Environmental Network conference was held on a bluff overlooking the river at
Maudslay State Park. This meant renting a tent, and endless complications related to holding a
conference m such an unusual place. There was, however, a tremendous positive reaction on me
part of the attendees to being in such a beautiful place, and there was much discussion about how
pretty the river ,s We provided the opportunity for a boat ride (paid for by attendees) up the
river after the conference. This did seem to provide a solid connection with the resource and
a focus for the activities of the group.
For some time, OTA considered a larger event, focussed not just on businesses, but including the
populations of towns by the river. There was much discussion of an environmental fair with folk
singing, environmental art and poetry contests, a trade show for environmentally friendly
products and an env.ronmental crafts show. There was discussion of arranging for tall shins to
sail up the river, and events in each town to draw people down to the river banks There was
discussion of promoting flower plantings and other beautification efforts all along the river.
These plans were dropped when there were some reactions at EPA to the concept of project
money being used for "a party". The plans were also dropped because the concept may have
been too grandiose and difficult to arrange. However, the concept of celebration of a resource
is important. If people have a strong attachment to a resource, they will act to defend it.
^Provide POTWs with the money to investigate the sources of discharges and nonpoint
pollution, and the resources and assistance to install improved capabilities for tracking
discharges up the pipe to the source. «"u"g
POTW operators have told OTA about problems they have had in the past with slug, sudden or
illegal discharges received at the plant. These problems sometimes require painstaking work in
sampling going up the pipe to each junction, and sometimes after months, when the insult is
repeated, finding the source. Sometimes these are companies or fly-by-night operations that are
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not in any phone book, commercial list, or the POTW's own records. Sometimes they are
nonpoint sources. Many times the source is not discovered.
Fast response to these incidents is necessary to enforce existing requirements and to avoid future
incidents. But the current process is costly and time consuming, and it is not clear if a POTW
is to devote time to this effort over time spent reinspecting known sources.
Better information regarding illegal discharges, companies manipulating self-monitoring, and
unidentified sources would have a significant preventive value.
Similarly, not much information yet exists on nonpoint sources. Are POTWs mandated to
develop this information? Do they have the resources to do so?
8. Regulatory agencies should reorganize to the extent that functional activities can be
coordinated with the goal of avoiding cross media transfers in permitting, inspections,
enforcement, and in all policy formation and statements.
DEP and EPA Region I both have experimented with multimedia inspections. Businesses are
interested in one-stop shopping for permits. These efforts are intended to reduce the complexity
and difficulty of environmental regulation, and to prevent cross-media transfers of pollution.
To follow this trend to its logical conclusion is to envision agencies organized by function -
permitting, inspection, enforcement, policy - rather than by environmental medium. The
difficulty with this proposal is that reorganizations can cause disruption, and it is possible to lose
some of the advantages of the current system. Thus what we are proposing is not an across the
board reorganization, but reorganizing just to the extent that cross-functional coordination is
possible.
Such an organization could perhaps contribute to more effective targetting of scofflaws, and better
knowledge of pollution sources: companies asking for a permit because of water discharges would
automatically be scrutinized for hazardous waste and air emissions as well.
9. Adopt a reformist posture concerning agency programs and policies.
As long as regulatory agencies concentrate on an adversarial posture, they may ignore issues
concerning their own need for improvement. This defensive posture is necessary in relation to
litigation. However, if agencies admit that their regulations need streamlining, that their delays
are a legitimate cause for concern to commercial entities, that their own requirements can
theoretically and sometimes actually be barriers to good environmental practice, and that their
own regulations often need clarification, then a process can begin whereby advice on reform can
be sought from the regulated population and other concerned parties, and progress can be made
in a cooperative context. Businesses are more likely to accept the policies of the enforcing
agencies if they have been consulted, have participated in the policy formation, and understand
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the logic of the various rulings and the premises, limitations, and mandates of the agency The
St^TnT'-T6 fr°m ab°Ve> °r age"Cy emP'°y^s will continue to feel bound by
loyalty to react defensively to any criticism.
T ^"^.^Pf"16"'8 to g°od environmental acts. One example is the fee necessary
MA for modification of an air or water permit. If the modification is one that is for reduction
of toxics, the fee ,s a barrier. Recycling regulations are very complex, and OTA has encountered
many compan.es confused about whether or not they need a permit for various reuse, re"
and recycling operat.ons. When presenting various options to companies in the course of OTA^s
assistance, many companies have reacted negatively when we have mentioned that a particular
recycling operation may need a permit. When we point out that the fee is small, they often cite
the paperwork and expected delay. Companies frequently comment that they are unwilling to ask
he enforcement agency for clarification of its regulations, because they fear they S open
themselves to enforcement actions. P
Discussed elsewhere in this report is the ROMAR process, which some companies are using to
remove heavy metals from wastewater. This process results in a sludge that is upwards o 80%
pure metal. It is sent off for refining, which replaces the landfilling of hydroxide slges
Because ,t is F006 waste, ,t must be managed as a hazardous waste. Is it not possible to further
encourage this kind of process by treating i, as a recovered material? There are other examp
of recovered matenals that must be treated as hazardous wastes, although they are
materials. These restrictions inhibit the use of waste exchanges.
Elsewhere in this report is a discussion of the "closed loop closed door", which results when a
company that has been treating wastewater implements complete water recovery and ceases
"
r^ ,^.dischf»« may "°< be exempt from RCRA as are discharges under
Clean Water Act permit, and thus the treatment of the wastewater is now arguably treating
without a par, B TSDF license. This, and uncertainty about the status and reguladon of
evaporators mcludmg enclosed evaporation systems, has had a chilling effect on over a dozen
companies known to OTA that had been considering zero water discharge technologies
(NOTE, this section was first written in 1994. Since then, "regulatory reform" has taken on the
used' h trePCa.p ^ NB,EN>S business/government drogue (sec Merrimack Report, part *
used the term "Regulatory Improvement Opportunities", not "reform").
10. Make water quality and discharge data as accessible as TRI data.
Sot? Scnhf'f'? "^ Wate^Uality and d^arge data to target sources of pollution.
We found it difficult to find, gather, and interpret the information. We believe that if we could
not adequately assess the data, the average concerned citizen also is unlikely to b able touse "he
information. Th.s ,s a lost opportunity to raise public consciousness about discharges IH
difficult to assess total loadings to a receptor, because this involves use of flow and concentration
information to derive mass. The sheer number of calculations, and the imprecision built into such
estimates, rule out having any data of this sort in an accurate form. This data also wide? varies
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from facility to facility and POTW to POTW, because every site has different requirements for
testing. The data is only for significant industrial users and categorical sources, which is only
a small percentage of the number of sources of pollution to a receptor. Data on organics is
lumped under Total Toxic Organics, or toxicity testing. It is not easy to assess the loadings of
particular organic constituents.
Monitoring data is public, but most use of this information appears to be either by commercial
entities or environmental organizations. This information could be made more accessible to the
general public - to neighbors and citizen groups. The TRI program has demonstrated how strong
a motivator public scrutiny can be. The water quality monitoring data exists and can also be used
in this manner.
Programs to encourage citizen monitoring, such as what New Hampshire's Merrimack Project is
implementing, and MA DEP's Bureau of Resource Protection is working on, would enhance the
involvement of local citizens in protection of their resources and would increase knowledge and
use of existing data.
11. Make regulatory system more uniform.
OTA occasionally receives calls from companies or consultants asking for a summary of the
POTW regulations or local limits which apply throughout the state. We are forced to reply that
to our knowledge no such summary exists. There are over 100 authorities in this state that have
their own rules, and in addition the state and the EPA also have jurisdiction. In one city, a
company can discharge a particular metal at 2 ppm, in another they have to meet 0.1. Most
people find this frustrating, even when they understand how such limits are set, and why they are
set according to the characteristics of each receiving system. However, it may be that greater
uniformity is possible. If there were greater uniformity, jurisdiction shopping would be reduced
and compliance would be enhanced, due to better understanding on the part of the regulated
population of just what is required. If increased uniformity is not achievable, then resources
should be provided to the states to gather the information on local limits in each district into one
document which would be accessible, or distributed (perhaps to chambers of commerce).
12. Encourage the formation of self-help groups for POTW personnel, and interaction with
other agencies.
OTA has been impressed by the formation of the Massachusett Pretreatment Forum, a forum for
discussion of POTWs, by and for POTW officials. This forum was founded by pretreatment
coordinators in a number of facilities, including the South Essex, Greater Lawrence, Haverhill,
and Upper Blackstone POTWs. It has served a very useful function in helping these officials stay
up to date with CWA requirements and with new technologies. It served as a very convenient
method for OTA to train these personnel in pollution prevention techniques and concepts, and
to gain cooperation with OTA for its projects, notably the Blackstone Project, the Merrimack
Project, and the Critical Parameters project. This group should be regarded as a model, and
resources should be provided for the continuance of the group, and the establishment of similar
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groups. The amount of money necessary is quite small. EPA recognition of the group would
also serve to encourage and reinforce its activities and mission, of increasing the effectiveness
and professionalism of its members. (For further information contact John O'Hare of the Greater
Lawrence Sanitary District, North Andover, MA).
One of the positive developments resulting from these various projects is the increase in
communications between DEP and the various POTWs. Many POTW officials have commented
that before this time, there was virtually no communication at all. There should be programs in
place, such as multimedia inspection programs that include POTWs, to ensure that POTW
officials are linked to other environmental agencies. Without such formal links, these agencies
may work at cross purposes; with them, the agencies may be able to be more effective
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THE MERRIMACK PROJECT
APPENDICES
Part IV
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The appendices to the Merrimack Project report are organized as follows:
New Hampshire attachments
Massachusetts papers
Observations on Accomplishing Pollution Prevention
P2 Self-audit checklist
Models of Interaction between Technical Assistance and Enforcement
Regulatory Improvement Issues (1992)
Proceedings, Regulatory Improvement Opportunities (May, 1995 Draft)
Merrimack Business Environmental Network
Northeast Business Environmental Network
Letters of Invitation to the Regulatory Improvement Opportunities (RIO) Forum
RIO Forum Attendees
Published Merrimack Project case studies
Relevant patents
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THE NEW HAMPSHIRE BIOMONITORING PROJECT
Please see companion report, Merrimack River Quality: The Effects of Franklin's WWTP on
Macroinvertebrate Communities.
The sampling sites for the biomonitoring project were in two areas: Franklin and Nashua. At
both areas sites above and below the wastewater treatment facilities were sampled. At the
Franklin sites the predominant method used was kick-net sampling, which is most appropriate for
shallow riverine areas with cobble bottoms. Artificial substrates were also used on an
experimental basis, but were not very successful because they fell apart.
Aside from the problems experienced with the artificial substrates, the Spring and Fall 1993
sampling events at the Franklin site were considered successful. Macroinvertebrates were
collected, and analyzed for numbers and types. A report on the biomonitoring project is
appended.
The Nashua sites presented some difficult problems because: (1) the river is much deeper and
cannot be waded; and (2) there is a significant amount of boat traffic. Due to the characteristics
of the river the decision was made to conduct sampling using artificial substrates, called multi-
plate samplers. Below the treatment plant outfall the samplers were secured to a bridge abutment
where they were suspended in the water column and left for 6 weeks to colonize. Above the
treatment plant they were secured to a pile of rubble which was the former site of a bridge
abutment.
Although sampling at the upstream Nashua site was fairly successful, problems were experienced
at the site below the outfall. The artificial samplers were vandalized sometime during the 5th
week of the 6-week sampling period. The samplers were lost, and it is unknown whether they
were actually removed or just cut loose. Unsuccessful attempts were made to find them by
dragging the bottom and scuba diving. Due to the difficulties experienced at this site the fall
sampling event was not conducted, and an alternative approach will be developed.
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NH Department of Environmental Services
LETTER OF DEFICIENCY - MODEL LANGUAGE
It is the goal of the Department of Environmental Services to promote the prevention of pollution
at the source as the preferred option for meeting established environmental quality goals. The
Department strives to ensure that pollution prevention options are considered first, followed by
recycling, treatment and disposal. I am requesting that the Department's Pollution Prevention
Coordinator contact you, if appropriate, to discuss possibilities for waste minimization or source
reduction at your facility. In the meantime, if you have any questions about pollution prevention
please feel free to contact the Pollution Prevention Coordinator at 271-6398.
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Final - August, 1993
New Hampshire Department of Environmental Services
POLLUTION PREVENTION DEFINITION
"Pollution prevention is the use of materials, processes, or practices that reduce or
eliminate the creation of pollutants or wastes at the source, or minimize their release to
the environment. It includes practices that reduce the use of hazardous materials, energy,
water or other resources. It also includes practices that protect natural resources and
human health through conservation, more efficient use, or effective release minimization."
Pollution Prevention is an approach that:
encompasses any pollutant;
encompasses all segments of society, including individuals, government,
business, industry, and agriculture;
avoids shifting pollution from one environmental media to another,
whenever appropriate;
includes improvements or modifications which bring a facility into
compliance with regulatory requirements, or reduce waste or emissions
beyond the regulatory requirements;
emphasizes source reduction or release minimization practices which
eliminate or reduce the amount, toxicitv. or impact of pollutants released
to the environment PRIOR to recycling, treatment or disposal;
GOAL
It is the goal of the Department to promote pollution prevention actions consistent with
the definition as the preferred option for meeting established environmental quality goals. We
recognize, however, that in some cases pollution prevention may not be feasible at this time. In
those cases the Department will strive to ensure that pollution prevention options are considered
first, followed by recycling, treatment, and disposal. Decisions that do not support efforts to
prevent pollution at the source of generation or release will be re-examined periodically in an
effort to continually strive toward our pollution prevention goal.
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New Hampshire Department of Environmental Services
Multi-media Pollution Prevention Task Force
MEMBERS
Office of the Commissioner: John Dabuliewicz
Gretchen Rule
Chris Simmers
Air Resources Division: Rudy Cartier
Richard Andrews
Waste Management Division: David Bowen
Paul Lockwood
Vincent Perelli
Water Supply and Pollution George Carlson
Control Division: Brad Foster
Sarah Pillsbury
Eric Williams
Water Resources Division: Katie Merriam
Assistant Commissioner
Enforcement Coordinator
Chief Environmental Planner/Chair
Small Business Assistance Program
Air Toxics, 33/50 Program
Hazardous Waste Compliance Program
NH Pollution Prevention Program
Haz. Waste Capacity Assurance Program
Industrial Pretreatment/NPDES
Municipal Water P2 Program
Groundwater Protection Bureau
Nonpoint Source Program
Wetlands Bureau
STAFF
Office of the Commissioner: Stephanie D'Agostino Pollution Prevention Coordinator
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MA OTA OBSERVATIONS ON ACCOMPLISHING POLLUTION PREVENTION
Process review
Pollution prevention is accomplished by process review. The basic tools are analysis of current
practice and potential alternatives. These are the same tools that are used for improving
operations from any standpoint, not just environmental. The outcome of a pollution prevention
program should be better informed operators and managers, better able to implement measures
to improve productivity and efficiency, as well as safety, health, or the environment. Pollution
prevention can easily be treated as an add-on, make-work activity, peripheral to the business of
making money. Emphasizing the essence of P2 as better understanding of process underlines its
relation to the business' core activities.
Motivation
P2 involves questioning assumptions and making changes. It sometimes involves investments of
time, energy, or money. It involves a certain element of chance, and sometimes people are on
the line if the project doesn't work. Therefore, many aspects of a P2 program can be threatening
to job or financial security. P2 seems to have been accomplished where companies were
influenced to use P2 to remove themselves from regulatory pressures, either because they were
under substantial pressure of fines or fees and control was not an easy option, or they saw the
value in the P2 approach as a response to such pressure. This point is brought out by the
substantial accomplishments of companies seeking to eliminate freons and VOCs as a result of
the Clean Air Act.
P2 was also accomplished when company officials happenned to be innovative people, who
recognized the possibilities in the P2 approach. These officials and companies are of the type
that really only need to be introduced to the approach and then are able to develop programs on
their own. One example is Jim Klecak of Americraft, who took a significant risk when he
committed to expenditures for a printing system using non-alcohol fountain solutions. (See
attached case study for a summary of his success). Another example is Ed Surette of M/A-Com,
who after getting started on P2 by OTA, has instituted process review and materials accounting
programs at company facilities across the country because of their value in building efficiency
and eliminating waste of all kinds.
There are those who need the combined effect of the push of regulations and the pull of technical
assistance. This does not seem to be in many cases because of a lack of civic or environmental
responsibility, but often because of the daily pressures of work, ignorance of P2, shortages of
resources, and the existence of internal barriers to change. Such barriers may be the resistance
of officials to questioning or change, or the commitment to a particular way of operating because
it was the result of a substantial investment of time. It may also be due to personal investments
in particular practices, and there may also be a hesitation to solicit or accept suggestions from
certain parties (such as the difficulty inherent in an environmental officer making process change
recommendations to a process engineer). Such considerations as how to suggest changes without
criticising existing practices or threatening "turf are very real when one attempts to implement
P2 at a facility.
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Having a government official who is nonthreatening ask questions and provide suggestions is very
useful in providing support to those in the company that would like to see change. It is also very
useful when there is no one in the company that is attempting to implement P2 changes.
Government technical assistance providers may ask questions that those familiar with practice
never ask, simply because they take current operations for granted. TAP programs visiting a
company provide a fresh point of view.
Questioning assumptions
By having someone with a fresh viewpoint walk through and review process steps, unnecessary
activities can be eliminated. (See company #24 in the "True Tales" section of this report).
Questioning assumptions about how a process best operates can lead to the resetting of optimal
operating parameters. Once parameters such as temperature, pressure, pH, specific gravity, or
concentration have been redetermined (they may exist from many years before, when different
equipment or materials were used, or may have been arbitrarily set in the first place), process
monitoring and controls can be used to extend the life of any chemical bath.
During one walkthrough, OTA staff asked company officials to explain a large container of about
10 gallons of oil. An official said that it was oil used to preserve a large housing shipped from
out of state. OTA asked what would happen to the oil and was told that it would be poured into
a sump. The next question was where does the sump lead, and it turned out it eventually led to
a water/oil separator that was turned off, and was a major reason that the company could no
longer discharge to the local POTW, but had to pay thousands of dollars each week to ship out
the water/oil combination. OTA asked why add to the problem by dumping the water in in the
first place, and pointed out that even if the separator were working, all the company would be
doing was using up energy to separate what didn't have to be combined. OTA then asked if the
oil was still useful for the same purpose, or was useful for any other purpose. The company
officials commented that they did not know, but had never considered this possibility. One
official remarked that he walked onto this floor every day for over ten years and had never
stopped to ask questions concerning this practice.
Unanticipated benefits
The technical assistance programs have often found many surprise benefits that feed off of each
other. For example, a company that does water conservation finds that it now has opportunities
to use electrolytic recovery of metals on a more concentrated waste stream. Or a company that
has recovered materials from its wastewater discovers that it may now reuse the water. Finally,
a company that is reusing its water may find that it is of a purer and more consistent quality than
the city water or pumped groundwater it formerly used.
Range of available options
The main task of technical assistance is to elucidate the range of options available. Staff must
also attempt to avoid recommending only one course of action. Quality and other restrictions on
the changes a company may make must always be kept in mind, however these considerations
cannot be allowed to prevent for all time the possibility of changes, but should be continuously
revisited. Even military specifications can be changed, and customers and clients can agree to
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modifications. Staff must attempt to anticipate potential adverse consequences of any
recommendation, understand the regulatory, financial, technical and social context of the
recommendations they make, and refrain from making categorical statements concerning
regulations or product quality.
Materials accounting
Convincing a company of the utility of materials accounting should be an important aim of any
program to promote pollution prevention. If material use and waste can be quantified a (rough
or precise) mass balance can be derived. This can contribute to the calculation of useful
productivity measures, which can help focus activities in the most economical as well as
environmental, manner.
According to one Merrimack project staff member, "Waste is an indicator of operating
inefficiency . Environmental problems are clues to opportunities for process improvements.
The Socratic Approach
Asking questions has been a recognized method of educating since Socrates popularized the
approach. Questions that can be asked about virtually any process include whether a company
is investigating alternatives, whether a company is inventorying or tracking its material use
whether a company tracks its pollution management costs and attributes them to their source and
whether a company uses available information about the health, safety and environmental impacts
of the materials they use. Whether or not a company sees P2 as an ongoing, continuous effort
is key to whether or not P2 will be achieved. Another key aspect is whether or not employees
are solicited for information. Does an environment exist at the site where suggestions are
encouraged, or rewarded? Is it even safe to make recommendations?
The following is a draft self-audit checklist.
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WHAT'S BEING DONE TO PREVENT POLLUTION?
Pollution Prevention is about avoiding: Occupational Exposures * Air and Water Pollution
* Hazardous Waste Shipments * Need for Treatment * Toxic Torts Superfund Liability
* Fines and Penalties * Risks of Spills or Accidents
It's now the law of the land. Is it practiced where you work? Ask the following questions.
1. IS THERE A PROGRAM IN PLACE?
It should be ongoing, not just a one-time event. It should have upper management support. It
should involve people from all different, relevant parts of the organization. It should involve
people on the line, and solicit ideas. It should give these people credit for their good ideas, and
it should have the power to MAKE THINGS HAPPEN.
2. IS IT SAFE TO ASK QUESTIONS, REEXAMINE ASSUMPTIONS?
The best way to discover pollution prevention opportunities is to take people unfamiliar with the
operation on a walk-through of the facility, to utilize their fresh and/or professional viewpoints.
What's needed is a process that questions things people take for granted. Steps should be taken
to ensure that this remains a positive experience for everyone - that people don't feel, and aren't,
threatened by the questions. If there is a team looking for pollution prevention opportunities!
does the team sit in a room or does it get out into the facility?
3. IS THERE WASTE ON THE SHELF?
Are there procedures to avoid excess purchases, unwanted deliveries which become unused
materials, shelf-life expirations and spoilage in storage? Does the control system flag and reduce
purchases of materials which become disposal or management problems? Does the system track
the costs of management and disposal of materials? Is there in place a system for tracking the
distribution and use of materials in the facility so that such use can be controlled and a match
(mass balance) of the quantity of each material coming in and its ultimate fate can be achieved?
4. DO PEOPLE KNOW WHAT POLLUTION COSTS?
Is there in place any method of cost tracking, which can attribute environmental, safety or health
costs to their sources, and is there any feedback mechanism of incentives or disincentives to
reduce those costs by changes in the source activities?
5. IS EACH ACTIVITY NECESSARY?
As time goes on, the reasons that process steps are instituted may have disappeared - but the step
is continued because it has become routine. Or, a cleaning step may be eliminated by eliminating
the soiling. The key is to ask why is something done, at each discrete step, and reevaluate the
reason.
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6. ARE MEASURES TAKEN TO EXTEND MATERIAL LIFE, OR FOR REUSE?
Are materials prematurely discarded? Can the process life of a material be extended by filtration,
oil separation, a protocol for addition of fresh materials, prevention of drag-in, reduction of
oxidation or bacterial degradation, periodic equipment cleanouts, or preventative maintenance?
Are chemicals dumped when they are spent, or according to a set time-frame? Is full advantage
taken of available technology for improving the efficiency of all processes? (Aeration,
turbulation, ultrasound, high pressure spray). Are the used materials useful on or off-site for any
purpose? Can they be rehabilitated?
7. WHAT ARE THE OPTIMAL OPERATING PARAMETERS?
Are operating parameters determined, monitored and controlled? (Flowmeters, level controls,
dispensing rates, concentration, temperature, times).
8. IS THERE TRAINING, AND IS IT LINKED TO OTHER ACTIVITIES?
Good housekeeping measures are low-cost, high-gain pollution prevention activities. To prevent
spills, leaks, evaporation, over-use of chemicals, bad batches, and mixing of things that shouldn't
be mixed, everyone must be involved. Is there a connection between this effort and any other
training, or incentives, for quality improvements, standard operations, water and energy
conservation, safety, and productivity?
9. IS THE LEARNING PROCESS CONTINUOUS?
Is there any process of evaluation of alternative materials, eqiupment or practices, or is change
regarded as overly risky or threatening? Is there any mechanism in place to keep up-to-date on
new technologies and practices for prevention, recycling, recovery, efficiency? Does the facility
have the latest information about the health, safety and environmental consequences of the use
of each material at the facility? Does the facility solicit information from available resources,
whether commercial, governmental, trade, professional, or literature?
10. DO PEOPLE REALLY CARE?
Is there an attitude in the organization that excellence in the areas of environmental, safety and
health issues is essential to the core activities of the organization, and that a program of
avoidance of adverse consequences is a method for improving organizational efficiency and
productivity? Or are all these things regarded as a nuisance, peripheral, and a drain on money
and time? Is your facility a good neighbor?
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Models of Interaction between Technical Assistance and Enforcement
Since the establishment and success of technical assistance programs to increase the adoption of
pollution prevention, regulatory agencies have considered incorporation of such activities into
day-to-day operations. A "White Paper" issued by EPA Region I dealt with questions raised by
this effort. The approach of the White Paper appeared to focus primarily on how enforcement
personnel should conduct technical assistance. Staff of dedicated technical assistance programs
responded with concern to the approach recommended by the White Paper, commenting that it
did not take a broad enough view of the potential utility of technical assistance and particularly
did not ensure confidentiality of technical assistance efforts, a key factor in gaining industry
acceptance. A consideration of several possible models of interaction between technical
assistance and enforcement efforts may be useful in making appropriate administrative decisions
concerning optimal programs to provide technical assistance.
Before considering various models, it is important to address a widely held concept that the
provision of technical assistance (TA) necessitates the suspension of enforcement or
disinvestment in enforcement. Administrators deciding to transfer resources from enforcement
to technical assistance may do so as a result of budgetary limits and policy priorities however
there is nothing inherent in the concept of technical assistance that requires the disinvestment in
enforcement. In fact, many TA personnel regard enforcement as a necessary driver for industry
participation in TA programs. The most widely cited model of interaction between TA and
enforcement, the Blackstone Project, did not result the suspension of enforcement activities as
concerns companies receiving technical assistance. Rather, the model of the Blackstone
recommends that enforcing officials consider allowing companies the flexibility to perform
pollution prevention, if necessary. TA personnel point out that such flexibility should not be
granted simply because a company has begun working with them, but upon a showing that time
is necessary for the pursuit of pollution prevention options. The Fall River MA POTW issued
an order to several textile companies in 1990 that required them to pursue pollution prevention
options, giving them extra time to comply with new copper discharge limits. This order provided
for regular reporting on milestones to demonstrate that such P2 option research was ongoing
Without such a showing, the companies were held to standard time limits for coming into
compliance. &
Some options for integrating TA into regulatory actions can be described briefly as follows:
1. Using enforcement to encourage and require the adoption of P2 techniques seeking P2
information in inspections, permits, providing guidance on P2, and establishing
enforcement policies and mechanisms to encourage P2.
2. Establishing a P2 auditor, who performs audits rather than inspections, but is part of the
enforcement agency. The level of confidentiality provided can vary from none to various
standards of seriousness. Audits and inspections for violations can be conducted in a
"two-step" fashion as in the first three of the following approaches:
a. The audit is followed by an enforcement inspection after a certain period of
time.
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b. A company receiving an inspection can request an audit after the inspection.
c. The auditor reinspects after a certain period of time and refers violations to
enforcement after the second visit.
d. Auditors are available on request.
e. Auditors make surprise visits.
f. Auditors visit as inspectors, but call ahead of time.
g. Auditors make cold calls offering their services.
h. The agency publicizes a highly visible program of enforcement in an area, and
recommends utilization of the auditors before the onset of the program.
3. Establishing a nonregulatory TA program. Many of the programs already established on
this model provide complete confidentiality except for imminent threats, in order to gain
the cooperation of the regulated community. Many of the options for interaction with
inspectors are the same as for the auditor, but some additional options should be
considered because of the confidentiality component. Dedicated TA P2 specialists cannot
be expected to report back on the companies they visit, so that if companies are to receive
flexibility or credit for P2, which information may be required so that the agency can
receive credit, then the companies must either waive confidentiality or report directly to
the enforcing agency.
Combinations of these models are also possible. A system can be devised that gives an inspector
the ability to recommend to a violating company that it may: request an audit, or a visit from a
nonregulatory program. Another option is to give enforcement personnel the option of ordering
the company to consult with P2 experts. Inspectors could have the option of ordering or
suggesting companies work with either auditors or assistance personnel, or perhaps with an
outside party.
Issues related to establishment of technical assistance in any of these modes include:
Accounting for agency activities (the "beans" issue).
Allowing for time to develop P2 recommendations and for companies to pursue P2.
Resources of the regulatory agency.
One of the primary issues when considering establishing technical assistance is what levels and/or
kinds of assistance are necessary to effectively increase the adoption of pollution prevention
activities. Many programs have found that more than just engineering technical assistance is
necessary to aid companies in actually performing pollution prevention. One important area is
financial help - assisting in the financial analysis of proposed P2 projects; obtaining loans or other
funding sources; working with financial sources to encourage the provision of funding;
developing loan guarantee, grants and loan programs; structuring tax credits, depreciation for
operating expenses, and other incentives. Another key area is addressing regulatory confusion,
ignorance of regulatory requirements, and occasionally, impediments to adoption of P2 activities.
Regarding regulatory confusion and ignorance, many programs have enhanced relations between
regulators and industry by providing forums for the discussion of regulatory requirements. Some
programs have also served to identify problems that companies have getting regulatory clearance
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to perform pollution prevention. If a closed-loop process which eliminates a water discharge is
technically "treating without a license" under RCRA, a company needs to know this and
regulatory agencies may wish to provide for such operations. Permit modifications may need to
be obtained, and companies may need help negotiating other paperwork or "bureaucratic"
requirements that may arise.
There are many ways to build P2 into enforcement actions, including:
Inspectors asking questions designed to elicit information and prompt thinking about
process change.
Requiring or requesting the submission in permit applications (or other opportunities when
communications are made to agencies) of process flow diagrams that include material
balances, showing where materials become wastes.
Requiring or requesting that companies research and report to the agency on process
changes, chemical substitutions, employee training, and other P2 actions and options.
These actions directly impact on the current agency accounting issue. Qualitative reporting to
the granting authority may have to replace, or explicate, some quantitative measures
Modification of the accounting process should be considered so that credit can be given to
agencies for evidence of compliance, which is different from getting credit for the number of
enforcement actions taken. If the work of technical assistance for pollution prevention is
successful, compliance rates will increase and the number of citations and enforcement actions
may drop off. Therefore, it may be necessary to credit the agency for various actions such as:
Issuance of orders which include P2 recommendations, require P2 investigation, require
or refer to P2 auditors or separate assistance personnel, or which have a multimedia
nature. These may be fewer in number because they will take longer to develop, but they
may be more substantive and perhaps more effective.
Company actions that go beyond compliance could be given credit under a reformed
accounting system.
The agency could receive some credit for public education.
The agency could receive some credit for referrals to technical assistance or P2 auditing
This could be conditioned upon actual work being performed and a showing of progress.
To summarize:
Maintain visible investment in enforcement.
Broaden measure of successful regulatory action. Give credit for multimedia P2
inspections, TA activities, public education.
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Consider all the options for technical assistance and promotion of P2: by inspectors; by
dedicated separate technical assistance staff providing confidentiality; and/or by auditors,
(more closely tied to enforcement).
Consider all the tools for working with these models: timing inspections and/or audits or
TA visits to follow, or vice-versa; requiring or suggesting contacts with auditors or
separate assistance staff; providing flexibility to do P2, upon a showing; providing
financial and regulatory assistance as well as technical.
In conclusion, it is important to consider all the models and options for integrating technical
assistance and enforcement while setting policy and designing programs to achieve this objective.
The White Paper did not make clear what model it was addressing, or even that there is more
than one model. Agreement on confidentiality and other policy issues could probably be reached
if the policy issues were tied to particular models of TA delivery.
Richard Reibstein
Office of Technical Assistance for Toxics Use Reduction
Massachusetts
November 30, 1992
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Memorandum
TO: Ed Kunce, Bob Bois
FROM: Rick Reibstein, Director of Policy, OTA
RE: Regulatory Improvement Issues
DATE: December 23, 1992
At your request, these are some of the issues we have identified in our work with industry.
Foremost on our list is when a company modifies its process to achieve toxics use reduction. It
may have to pay a fee for modification of the air or water permit. DEP bases its fee rates on
administrative costs. This practice conflicts with the policy of promoting process modifications
for TUR.
Second on our list is when a company goes to zero discharge. This arguably takes them out of
the Clean Water Act and puts them under RCRA, where there are restrictions concerning
treatment or recycling operations. Many companies are currently doing this and are consciously
taking the risk of being penalized for treating without a TSDF license. Some companies have
decided not to go closed loop for this reason. Some keep a discharge permit but discharge
nothing. It is not clear whether the wastewater receiving authority has the authority to permit in
this matter, because a shop with closed drains could not arguably affect that receiving authority's
operations.
Third on our list is the extreme confusion in the regulated community concerning recycling,
which serves as a disincentive both for recycling and for complying with the law. The same
situation exists as concerns evaporators and other dewatering operations, and virtually all material
reuse operations. No one seems to be clear about the function or meaning of the term "integral",
or when a material becomes a waste, or what materials require a recycling permit, or which
permit. The kind of clarity that DEP has provided concerning basic RCRA requirements in its
"Summary of Requirements for Small Quantity Generators of Hazardous Waste" is lacking in the
recycling area. This serves as an impediment. The body of this memo addresses itself primarily
to these matters.
Fourth on our list is the TUR waiver policy under TURA. This provides for flexibility in
compliance schedules, basically attempting to eliminate the situation where a company will slap
on a black box because it's quick and it is a proven process, in preference to trying more
innovative technologies or less tangible activities (such as good housekeeping or process
monitoring improvements). With no formal policy in place, the ability of companies to take
advantage of this is limited.
This memo is an attempt to present to you most of the issues that are presented to us. We did
not attempt to narrow things down to a few matters. The most important to us are the four cited
above. We appreciate your request for this information, and understand that it may not be easy
to simply change current practice or policy.
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Uncertainty and Confusion
Many of the issues described below may simply be a lack of understanding of the regulations on
our part. However, we report them because they reflect a widespread lack of understanding on
the part of industry. All of the questions cited herein have arisen not from our own
considerations but have been asked of us. These are the questions we have not been able to
answer. There is a good deal of uncertainty regarding:
What recycling of hazardous waste (HW) requires a permit.
What is integral HW recycling?
Can hazardous waste treatment systems be allowed when there is zero water discharge?
Is in-process hazardous waste recycling or treatment restricted?
When is a recycling material no longer a hazardous waste, but a useful material?
How may waste exchange be facilitated, when usable materials must be managed as
hazardous waste?
Is there no appropriate treatment we may allow under RCRA?
What protection from Superfund liability can be offered "arrangers for disposal"?
Is there the option of putting a recycling system in place at the same time as the
application for a permit?
Promotion of Recycling
The focus these days is on toxics use reduction, pollution prevention. As we make progress in
this regard, we should not forget recycling. Much effort has been spent in the past to make
toxics users aware that a material can still be useful even after it has been run through a process.
But many are totally confused about whether or not they need a permit, and we run into stills and
other recycling equipment that are not permitted. Many, told that there are recycling
opportunities and that a permit is not hard or costly to get, prefer not to seek one, often citing
an expected time delay. The regulations on recycling are difficult to follow, and requests for
clarification have usually resulted in a response that rulings will be made on a "case by case"
basis. It would be useful to know what are the principles used in making case by case rulings.
Is Recycling Included under Integral Treatment?
It seems that one can only recycle what is permitted under 310 CMR 30, or what is part of a
treatment process before permitted disposal to a sewage treatment plant. The regulations state
that integral treatment needs no permit, but it is not clear as to whether that includes recycling.
So, is it true that if you add a recovery operation to an integral treatment system, that you now
need a permit?
Must a useful material be considered a waste?
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Is it so that one can not ship a "hazardous waste" to someone else who will use it unless they are
a permitted recycling facility, a TSDF, or if they are out of state and they give a certification (a
process that I don't think anyone even knows about). As we understand it, one has to ship
recyclables with a licensed transporter. This basically makes waste exchange prohibitively
expensive. Is there a way to ship hazardous waste for recycling or reuse more cheaply?
The Romar process, recently patented, presents an interesting situation. This process can be used
instead of conventional treatment for removing heavy metals from wastewater. Instead of
creating a metal bearing sludge for landfilling, the process yields 90%-plus pure metal. It is not
pure enough to be reused on site by platers and others who need very pure metals in their
process. But it is purer than the ore sent to refiners. Thus, it is better than what is now shipped
to the refiners for smelting. But it is, apparently, a "waste from a plating process" and thus a
listed hazardous waste, and it seems may not be shipped to the refiner except with a manifest and
by a licensed transporter, which may be expensive enough to discourage people from doing this.
Most important, the refiner will probably not take a "hazardous waste". Can it be a material, and
not a waste?
Do recycling regulations and treatment restrictions apply to in-process activities?
There is much confusion now about in-process treatment and recycling of hazardous waste,
especially concerning mixtures of listed wastes. There seems no clarity concerning how to regard
activities that physically or chemically affect materials when the activity is part of the process.
It may be enclosed or not. Sometimes it seems that regulatory actions apply to in-process
activities, sometimes it seems they only apply to waste treatment after the process. We know of
people abandoning activities they have performed for years, which recover or remove materials
in the process, because they are worried that they will be hit for treating hazardous waste without
a license. This is happening with photoresists in printed circuit board manufacturing. One state
ruled that photoresist skins were a listed hazardous waste because they came from a plating
operation. EPA refused to rule on the matter, and photoresist manufacturers wrote to their
customers that they should now handle this waste as hazardous. Most have in-process filters to
remove the skins from wastewater. Because the companies did not wish to obtain hazardous
waste treatment authorization or hazardous waste recycling permits, they simply stopped removing
the skins from wastewater and now discharge it. In our visits, we frequently find that companies
do not know whether their in-process filtering of hazardous materials is recycling for which they
need a permit. Most assume that the permit is only necessary for something that is added on at
the end of the process.
Another example of the above is a query received just yesterday from a company that wishes to
install an electrowinning system. We are not sure if this is considered waste treatment, requiring
a licensed treatment operator to monitor it. We are not sure if there is a difference if the system
is placed on dragout tanks or rinse tanks. If the entire shop went to zero discharge, would the
system have to be permitted?
Sham recycling
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What if a company wants to remove a certain pollutant from their waste stream, but they cannot
remove it effectively enough to reuse it on site? What if they are only removing a small
percentage by weight of their waste? What if they have to pay for the material to be disposed
of or refined, however, doing the removal means that a great volume of waste is thereby rendered
nonhazardous? All of these are under a cloud as "sham recycling" and are in a gray area which
no one seems to understand, and yet all of these are environmentally beneficial.
The attempt by companies to get recycling permits for activities which are really treatment (and
thus they are labelled "sham recyclers") may not always be a matter of deviousness. These
companies sometimes wish to perform appropriate treatment and are simply trying to fit it into
a recycling scheme because there is no treatment allowed without a TSDF license, impossible for
most businesses to get.
The closed-loop closed door
If a company is treating hazardous wastes under a Clean Water Act permit and then closes the
loop, begins reusing water, and has no more water discharge, they are now arguably under RCRA
and are supposed to have the TSDF permit. If we wish to discourage companies from simply
slapping on evaporators, that is one thing. But we should not be discouraging companies from
doing many sophisticated water purification and material recovery and removal processes which
can greatly benefit our resource use and waste generation profile.
One of the first great success stories in the pollution prevention field in this state was the Robbins
Company, which managed to close its loop, recovering all the metals out of its wastewater. The
system uses in-line cyanide destruction (treatment), carbon adsorption (treatment), ion-exchange
(recycling?), electrowinning (recycling?), and evaporation (treatment?). Theoretically, this
company could be slammed for treating without a license, and Beverly Migliore, a Rhode Island
environmental official, has expressed frustration to this state, because companies in Rhode Island
wish to emulate Robbins but Rhode Island has a strict policy against evaporators - regarded as
treatment without a license.
Evaporators, etc.
We do not necessarily wish to encourage the use of atmospheric evaporators - and we recommend
enclosed, integral evaporation technologies - but we do think it is necessary to clarify what
RCRA does require concerning evaporators. A similar issue is the filter press, or the
neutralization tank - where are these authorized under the law? Many companies have them, but
neither they nor we are clear on where the law allows for their use.
To summarize:
If you add a recycling operation to an integral treatment system, you appear to have
additional regulatory requirements, although this is something that should be encouraged.
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If the recycling you add is not economically beneficial, are you engaging in sham
recycling?
If you change your process or treatment system so that a waste that was sent for
landfilling can now be sent for off-site recovery or exchange, it appears that you still have to ship
it as a hazardous waste, which means there is no savings in transportation or regulatory
compliance costs, and the recycling center (refiner) or other potential user of the material may
not be able to receive it.
If you pull something out of your process before the end of the process, must it be
integral, and if you are recovering the material, must it be permitted under recycling?
If you cease discharging wastewater because you are reusing it, is your treatment and/or
recycling prohibited under RCRA? (We have had a score of requests concerning this situation,
one from a sewage treatment facility which has granted half a dozen "zero discharge permits" to
cover such facilities).
In addition, there are these other, related issues.
Arranging for Disposal
Several organizations have abandoned plans to arrange for disposal of hazardous wastes generated
by their members because they have learned they become subject to liabilities under Superfund.
These include communities planning hazardous waste collections for small generators. These
include trade associations. Milk runs and dedicated collections are effective ways of reducing
waste costs and getting wastes taken care of properly. They are inhibited by Superfund-induced
trepidation. This may be a federal issue over which DEP has no control, but perhaps the state
could petition for a change.
Sewer-use connection permits
Another frequent source of frustration is the issue of sewer use connections, which is a largely
duplicative state-local activity. Many companies out of compliance are reluctant to apply for such
permits because they are afraid they will be fined for having been out of compliance. One
company reduced its discharges and lost its grandfathered status, thus having to pay the
connection fee, because it had "changed the character" of its discharge. If the company is in
compliance with its discharge limits, should it be penalized?
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Getting everyone into the system
Another major item is that DEP is restricted through grant agreements with EPA to reinspecting
the same facilities year after year. Businesses in compliance frequently complain that they are
spending money that businesses not in compliance are saving. We certainly understand the
relationship here between DEP and EPA, and are raising this issue because we here about it so
frequently out in the field.
Streamlining reporting requirements
Finally, it is important to note that the state has established under TURA a mechanism for
eliminating duplication of regulations. The TUR Administrative Council's job is to review where
reporting requirements can be streamlined. They also, in conjunction with relevant agencies, are
to review how existing policy, activities, and regulations and proposed regulations and laws may
be changed to promote toxics use reduction.
We certainly want to thank you for this opportunity to present these issues. We appreciate any
clarification or resolution that you may provide, which we will pass along.
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DRAFT
Proceedings of the Regulatory Improvement Opportunities Business/Government Dialogue
A project of: The Northeast Business Environmental Network/Merrimack River Initiative/EPA
New England/Massachusetts Office of Technical Assistance for Toxics Use Reduction
May 9, 1995
Regulatory Improvement Opportunities (RIO) is a project conducted by the Northeast Business
Environmental Network (NBEN) with funding from the Merrimack River Initiative (MRI), an
EPA-sponsored effort to promote innovation in the environmental area. NBEN, which holds
monthly discussion groups designed to keep its members informed about environmental
requirements and pollution prevention, and which provides opportunities for business, government
and environmental organizations to discuss these matters together, was awarded a grant of
$10,000 by the MRI to conduct a "Business/Government Dialogue" on improving environmental
programs. The Massachusetts Office of Technical Assistance for Toxics Use Reduction designed
the project for NBEN.
The first event was a half day of public discussion on April 27 on issues identified by invitees,
and facilitated by NBEN members, employees of EPA and the Toxics Use Reduction Institute
of the University of Massachusetts at Lowell. Seven thousand businesses in Massachusetts and
New Hampshire received an invitation to this event co-signed by the Massachusetts Secretary of
the Environment, the Commissioner of the New Hampshire Department of Environmental
Services, the Commissioner of the Massachusetts Department of Environmental Protection, and
the Administrator of EPA New England. There were approximately 100 attendees, mostly from
business, and some from government, and a minor turnout of "other". Several late registrants
were told there was no more room.
About twenty-five invitees submitted issues before the event, and these were provided to the
attendees in four categories. Four breakout sessions were held to cover each category. The intent
of these sessions was to clarify or elaborate on already identified issues and find potential
solutions, and to further identify issues worth addressing. Before the breakout sessions were held,
several presentations served to frame the discussion.
Representatives of the governmental agencies briefly discussed actions they are taking to improve
environmental regulatory programs, and to improve communications with the regulated
community. OTA and NBEN explained the ground rules for discussion.
The basic ground rule was that all parties should attempt to hear and understand each other's
points of view. This meant that on the one hand those criticizing environmental laws could learn
about the positions of and constraints on the government agencies, and on the other hand the
agencies had an opportunity to learn about the real world effects of their policies and programs.
The intent of the program was to increase mutual understanding, find areas of agreement if
possible, and do some constructive thinking. In this context, it was necessary to reframe certain
questions.
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For example, a presenter was asked "which breakout session should I go to to discuss eliminating
regulations?" The presenter asked if he could reword the question as pertaining to "obsolete or
unnecessary regulations", as that was a way to cast the discussion in such a way that agreement
might be reached, but the other way was more likely to create impediments to constructive
discussion. The questioner agreed and afterwards told the presenter he appreciated the
emendation.
A consensus did seem to emerge as a result of the preparation and explanation of the ground rule
of mutual respect, that attempts to improve regulations are more conducive to discussion and
follow up than wholesale attacks on regulations. The illustration used during the introductory
presentation concerned an issue wherein agency officials agreed with an aggrieved party, but were
unable to convince legislators to bring the matter to the floor of the legislature for amendment
because allowing the law in which the unjust rule was contained to come to the floor of the
legislature would abet an attempt to repeal the entire law. Several attendees commented that they
had never before considered this point.
RIO serves as a demonstration that much useful information concerning the optimal functioning
of environmental programs can be exchanged when a context of constructive discussion is
carefully established. Extremely positive feedback was received from the attendees concerning
the way in which the questions were framed and the facilitators acted to ensure all sides had a
chance to be heard. One government employee said it was painful to hear so many criticisms of
the government, but that it was good to hear them. Another was surprised that so many
businesspeople were readily able to understand the government's point of view. Many
businesspeople were pleased to hear about the innovative approaches the agencies are pursuing,
and were glad to have the opportunity to be heard.
This draft document will be provided to all attendees and other interested parties. Attendees will
be asked to provide comments, clarifications, and further ideas, and to participate in continuing
RIO in the form of working groups dedicated to the issues identified herein.
Please respond to: Rick Reibstein, Office of Technical Assistance for Toxics Use Reduction,
Room 2109, 100 Cambridge St., Boston, MA 02202, (617) 727-3260 x 688, fax (617) 727 3827.
How these proceedings are organized:
The breakout sessions were designed to elicit specificity concerning the issues cited, and ideas
for solutions. The following materials set forth the issues as preidentified by invitees, (a
substantial percentage reframed by OTA with the agreement of the proponent to be more specific
or constructive), and flip chart recordings of the discussions of these and related issues as they
occurred in the breakout sessions.
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Session on:
Authorizations (Where a license, permit, certification, or other form of authorization is necessary)
Issue #1: Too many continuing education contact hours required to maintain license. Example:
waste water treatment.
Who's Affected: Primarily: small companies, sole proprietors, managers who must take time
away from production in order to fulfill environmental requirements, people who only need to
do certain specific operations (for example: boiler operator) shouldn't have to learn wastewater
treatment inapplicable to their job.
How Affected: Unevenness of costs. Competitiveness with companies in other states who do
not have to take this time away from business. Money spent on the education. Paperwork
increased. Requirements not always linked to necessary expertise. Experience or equivalent
training elsewhere doesn't qualify - only sanctioned courses. No value added when boiler
operator keeps up with wastewater information not relevant to his/her job.
Origin or Purpose of Requirement:. Wastewater treatment technology and rules continuously
change and evolve. To do wastewater treatment effectively, must keep up to date.
Potential Solutions: Expand opportunities to qualify for contact hours. Reduce contact hours
somewhat to make more even with other states. State offer more free courses at more convenient
times. Expand recognition of experience as qualification. Establish appropriate certification
levels for specific wastewater pretreatment, such as boiler operators. Self-study option. Qualify
by examination.
General Comments. NOTE: DEP and TURA Administrative Council reviewing this issue,
looking at standardizing approvals and offering workshops with joint accreditations. Need more
information on original purpose of establishment of the requirement. RELATED ISSUES:
OSHA, Hazardous waste, TURA.
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DISCUSSION OF ISSUE #1:
30 contact hours first year; 10 every following year
- cost is couple hundred dollars/hour
No other state has same requirement
Problem for small companies; also for large companies trying to be competitive
• No validity to work experience
$150/2 years to maintain certification
Some of the courses are not directly contributing
Training only in mainstream technologies
No distinction between pretreatment operator and treatement operator regarding training
and certification
Should the requirement for ongoing training be eliminated? Is it a burden?
$600-$1000/first year training even if only for pH pretreatment operator
Is there a way to consolidate the process?
Course selection may not be appropriate for industry in NE
Grandfather license as long as there is no change in operation
College credits can be part of CEU for TURPs and wastewater treatment certification
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Issue #2: Full Treatment, Storage and Disposal Facility permit required for many operations
which should be encouraged.
Explanation: Appropriate on-site treatment, recycling of water by removing hazardous
constituents (if not covered by Clean Water Act permit).
Origin or Purpose of Requirement: Ensure hazardous waste treatment is sufficiently controlled
to ensure safety and prevent contamination of environment.
Potential Solutions: Establish minor treatment permit, preauthorizing standard activities and
establishing efficient process for notification and authorization of nonstandard. Encourage
innovative on-site treatment. Ensure prevention options are investigated before granting.
Establish hazardous wastewater recycling permit to cover recycling of water with hazardous waste
constituents.
Comment: Hazardous Waste Advisory Committee has recommended methods for encouraging
onsite treatment and recycling.
DISCUSSION OF ISSUE #2:
• Hazardous and solid waste recycling almost impossible to achieve
Classification of waste -- may not be imposed because it can change from waste to usable
material
• Heavy metals are not classified as oxides, free, bound, etc.
It is considered hazardous waste even if used as raw materials off site.
• Interpretation of laws and regulations varies.
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Issue #3: Full solid waste facility siting process required for beneficial recycling.
DISCUSSION OF ISSUE #3:
Siting process is a lengthy process -- subdivide the regulations to shorten process.
Waste of one is the raw material of others; regulate at the end point when the material
leaves the facility.
Recyclables are shipped to other states due to the difficult process of waste facility siting.
Solution suggestion: regulate materials that have value under the solid waste regulations.
Raw materials used by other manufacturing facility should not be considered waste.
Paperwork involved in shipping regulated waste requires hours of work
Off-site recycling is not considered the same as on-site.
• Permit by rule
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Issue #4: Permit modification fee may be required for pollution prevention activities when they
alter the conditions of a clean air act or clean water permit.
Explanation: Impediment to pollution prevention.
Origin or Purpose of Requirement: Fee covers administrative cost of processing.
Potential Solution: Establish fee waiver for pollution prevention.
Potential problem with potential solution: Income to cover administrative costs will be
insufficient. Administrative costs incurred by time needed to determine whether something
qualifies for the waiver.
DISCUSSION OF ISSUE #4
Duplication of effort and addition of cost when changing the oil in a boiler plant or
adding lubricating oil as an on-site recycling measure
Implemention of P2 before full process is complete
Get away from slowing down stages during regulatory review of permit applications
• Acknowledgement
• Performance-based permits
- Self-monitoring
- Third party monitoring
To replace modifications that don't gain environmental benefits
702 modifications - changes that are beneficial result in complete reexamination of the
facility
Experience of inspectors has to be improved, more professional knowledge of the industry
they inspect
• Inspectors deal with multimedia
Train businesses on regulation interpretation by the regulatory people
• Certify inspectors
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Issue #5: delays in getting permits.
Comment: DEP has cut permit processing time 25%. More aggressive goals have been set.
Committees established to review permit process.
DISCUSSION OF ISSUE #5:
Buying another facility to expand existing one requires a process the same as starting a
new company
• DEP encourages companies to come to pre-permitting conferences; shortens the review
time by half
Issue #6: Laboratory proficiency testing on a semi-annual basis imposes unnecessary costs on
laboratories, which are passed on to customers.
Potential Solution: Laboratories which consistently report satisfactory proficiency testing data
should only be required to participating in the testing program on an annual basis. Semi-annual
testing should be reserved for those laboraties which do not perform successfully in the
determination of one or more of the unknown analytes.
DISCUSSION OF ISSUE #6:
Laboratories' equipment and operator turnover is fast; by conducting semi-annual tests,
DEP can keep good records
Issue #7: Hard to get information on the status of an application for a permit or other
authorization.
Potential Solution: Establish a single point of contact person for each application.
Comment: DEP is planning implementation of an SPOC policy.
Issue #8: BACT can discourage use of innovative or new emissions reduction technologies.
Missed opportunities to perform research or implement small scale emissions improvements.
Examples: A. Switching to natural gas or other cleaner fuel from oil must go through BACT.
B. Refurbishing, upgrading an existing pollution control device must go through BACT.
Potential Solution: Exempt research projects and activities presumed to be better than current
operations.
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GENERAL COMMENTS IN THE SESSION ON AUTHORIZATIONS
If NOx emissions are closest to the limit of 50 tons, opting out is rejected
• No where to go before there is a facility regarding air, water, etc.
No willingness/flexibility to accept more valid model than the standard
Expansion of residential areas closer to older industrial areas leads to different
interpretation of the environmental laws by the communities -- how can we deal with this
State programs to guarantee loans associated with risky, innovative projects
If a facility is close to the threshold of 50 tons of NOx -- would their permit be rejected?
More input from different groups -- businesses, environmental groups, regulatory agencies
before enacting laws
Identify and help implement the changes
Laws in lay terms for better understanding of the businesses/users
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Session on:
Required Activities/Enforcement
Issue #9: Hideouts. Enforcement agency focus on companies they know about, sense that
companies unknown to the agencies not being found. Perception that agencies could use help
bringing small and noncompliant sources into system.
Who's Affected and How: Those already in basic compliance, those who self-identify.
Enforcement against those already in the system focuses on ever smaller infractions. Those who
self-identify are enforced against rather than encouraged to come forward. Those not in the
system continue to hide out. Those spending money on compliance at unfair disadvantage -
economic playing field not level.
Purpose of Requirement: Agencies are required to perform specific actions in their agreements
with the federal authorities. Revisits are required. Purpose is to assure accountability concerning
the expenditure by states of federal grants for these programs.
Potential Solutions: Agencies get credit from federal authorities for time spent on finding
companies not in the system. Agencies get assistance from businesses and industry experts on
how to find companies not in the system. Agencies establish policies favoring self-reporting.
Facilities in compliance over extended period of time may shift to self-audit and third party
certification system.
General Comments: Actual universe of fly-by-nighters, those not in system, still unknown.
Some survey techniques may have to be developed. Some businesses have stated it should be
easy to find outliers, and will supply agency with advice, but unwilling to tell on specific
companies.
DEP has received a demonstration grant from EPA to implement a new strategy for compliance
and enforcement that will decrease the current focus on already highly regulated entities.
Common Sense Initiative projects of DEP and EPA also have similar intent.
DISCUSSION OF ISSUE #9:
• Active discovery program; examine SARA data
• Better targeting mechanism
• Look at OSHA inspection mechanism
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Develop outreach/amnesty program (expand small business program)
Workable fact sheets (in plain English)
- distribute locally
Look at SARA for mismanagement
Annual inspections
- seen as unnecessary
Look at DEP policy to see why it takes so long to respond to a complaint
Educate and try to help
- also, have businesses educate agencies
Hospital/university affiliates
- set example of (illegible) relationship
507 program to other media
Use resources such as POTWs
Quick succinct info, on all aspects of compliance (DEP electronic guide)
Issue #10: Is the regulatory structure flexible enough to be tailored to evolving information about
proportional contribution to the overall load from specific sources?
Explanation: Problem of equity and efficiency arises when new information indicates that a
population that was a target of enforcement is not a substantial contributor. Enforcement targets
and limits should be adjusted.
Origin and Purpose of Regulation: To take action on the basis of information we have. To act
on those the agency has authority to act on.
Example of Potential Solution: Work with industry to develop information on sources and
solutions, and use compliance schedules to keep on schedule (Example: MWRA/Hospital mercury
working group MOU).
Comment: Common Sense Initiative of EPA and DEP has same focus.
DISCUSSION OF ISSUE #10:
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Look at cumulative effects
Flexibility on waivers
General rule with self-enforcement
Work with vendors — alternative products
Not enough education
Common sense approach not being applied (takes too long)
Advocating more MOU approach
Use discretion throughout structure
Incoming water quality
- look at community partnerships including water depts. with WTPs (water
treatment plants?)
Baseline and incremental increase
Look at non regulateds to get data on loading (education with industry partners)
Listed wastes — with remediation waste
- Delisting process is too formal and costly
- "Contained in" policy not enough or varied interpretations mixture and derived
from rules
- Use characteristics instead of listing
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Issue #11: Self-audit discouraged by fear information will be used against auditor.
Explanation: Self-audits without attorney supervision are not privileged. Auditors protect
themselves by not committing observations and facts to writing or by not conducting an audit or
a complete audit. Audits used by inspectors or in private suit discovery may be utilized in
argument that auditor was "willful" violator because had knowledge of problem and failed to
correct.
Why it is this way: Enforcement officials need to use whatever information they can find to
show willful neglect of a safety or environmental matter.
Potential solution: Establish audit privilege but qualify it so that it will not hinder the
prosecution of willful, serious or criminal violations.
Comment: Proposal currently before legislature goes too far in that it will enable violators to
gain immunity from enforcement simply by notifying DEP. Solution that is crafted must produce
a level playing field which will not provide this kind of an out to those who have gained an
economic advantage from avoiding compliance.
DISCUSSION OF ISSUE #11:
• Third party and adverse publicity
• Be careful about what is written
- Self-audits as form of defense
Privilege is needed, channelling through attorney hard for small business
• Incentives
Immunity vs. privilege (associated with lawyers)
• Third party verification
• Advantages
- Networking
- Benchmarking
- Resources
- Compliance is rewarded
• Issue is timely correction
- Find and fix debate
Audit Service Bureau (MN)
- Mitigated if corrected
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Issue #12: Under Clean Air Act, certain air sources may not be able to qualify for exemptions
because of past activities. (Known as "once in, always in", or "once major, always major").
Why it is this way: Because a company that once broke major thresholds may do so again. It
is necessary to continue to regulate strictly so that the company stays below thresholds.
Problem: Missed opportunity to encourage pollution prevention by reducing regulatory
requirements to reward further reductions.
Comment: EPA's Office of Air Quality Planning and Standards currently reviewing policy. DEP
currently reviewing this policy.
DISCUSSION OF ISSUE #12:
• RACT — Keeps you in the system
• 70-page form in '93 (restricted emissions status)
- DEP again in '94
Who is DEP contact?
Issue #13: Toxics Use Reduction Act applies to processors of materials for which there are no
reasonable substitutes, or materials which are not toxic in ordinary use. (Example: fabricators
of stainless steel, repackagers, preparers of standard photographic formulations).
Comments: Delisting through TURA's Science Advisory Board and Administrative Council may
be way to address this.
DISCUSSION OF ISSUE #13:
• Attempt to withdraw it is a barrier to amending it
• Increasing communication (expanding mailing list)
• Information not disseminated widely enough
• Delisting too slow (cumbersome process)
• Need to sort out issues
• Identify stakeholders
Form R for TURA chemicals (even though Fed. does not require it)
• Create one form
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"Money-back" guarantee system
NaOH issue back under TURA
- Look at Fed. experience
Fees double cost of process
- Look at fees and adjust to process
Issue #14: Discharge limits set at or near detection limits cause too many false positives,
resulting in unfair charges of noncompliance.
Comment: Ways exist to deal with false positives that do not involve raising limits.
DISCUSSION OF ISSUE #15:
• Charges based on concentration
• Threshold below which there would be no charge
• How sensitive is sample vs. MDL
Limits set unnecessarily low (Hg, Cr)
- (sludge concentration)
• Product is compared to 51 limits
• Toxicity limits
• Limits realistic — more communication
• Cost-benefit analysis
• Develop relationship with POTWs
• False positives
- Look at compliance history
- Tiered approach?
• Mass vs. concentration approach
- Material gets into water body
• Setting limits
- POTW unwilling to let industries negotiate limits with EPA
- Public hearings involved
- Works with checks and balances (e.g. Cu)
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Issue #15: How may the regulatory system assess comparative risks, costs, and benefits?
Potential Solution: Adopt process to quantify risks, costs, and benefits.
Comments: Difficulties in assessing unknowns, complexity of the issues, and inability of
environmental receptors and future generations to be adequately represented can create inequities
and inefficiencies. Cumbersome system for assessing these factors may become a barrier to
getting anything done. Process for assessing these factors must be efficient and fair to all parties
including those without a voice.
DISCUSSION OF ISSUE #15:
Set environmental priorities
During agency promulgation, open up discussion (upfront consideration in an efficient
manner of costs, and if a prima facie case can be made of undue costs relative to benefits
reconsideration allowed) '
- more negotiation
Mutual approach -- get stakeholders together
• Burden of proof on government
Prior to (at beginning of) process, get all groups involved together (including citizens'
groups)
Make decisions based on common ground
• Create partnerships
• Prevention-based
Provision in regulations
Remove focus on minutiae and reward successes
Issue #16: Encompassing hazardous waste definition inhibits waste exchange, some recycling and
I t^Llow*
Comment: Hazardous Waste Advisory Committee recommendations addressed this issue.
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Issue #17: Backflow prevention devices required where not needed.
Example: Fire sprinkler systems on buildings.
Origin or Purpose of Requirement: Necessary in industrial or other settings where pollutants
could enter piping system and infiltrate drinking water.
Comments: Argument that it is needed is not based on any study that sprinkler systems are
potential pollution sources, but based on extension through language of regulation. Sprinkler
systems are engineered so that backflows do not occur.
Potential Solution: Immediately investigate whether requirement is necessary. Use plumbing
codes and eliminate redundant environmental requirements for fire sprinkler systems.
Comment on larger context: Use as example for care in writing requirements.
Issue #18: Storage times for hazardous waste too rigid.
Explanation: Large quantity generator reduces waste but is still in LQG category and still must
ship every 90 days. Per unit cost of shipping waste has now gone up although company has
reduced waste. Impediment to waste reduction.
Comment: See HWAC recommendations.
Issue #19: Concentration-based discharge limits inhibit water conservation.
Potential solution: Use mass-based limits.
Potential problem with potential solution: Difficult to do.
Issue #20: Encourage alternatives to enforcement actions. Use inspections for education, not just
punishment.
GENERAL COMMENTS IN THE SESSION ON REQUIRED ACTIVITIES/ENFORCEMENT
• Enforcement and interpretation of gray areas; look at big picture
• Look at system ~ why are "micro" types of issues looked at
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Positive measures of success (offer suggestions for corrections)
Gov't agency reps, work in industry
Differentiate between minor and major non-compliers
- Definition of "significant noncompliance" is broad
What about a list of great compliers?
Look at measures of success (is bean counting behind focus on micro level)
Joint goal setting
Rank priorities — Big Picture
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Session on:
General/Practical Issues
GENERAL AND PRACTICAL BRAINSTORM
Eliminate unnecessary regulations
Cost benefit
Examine how regulations are made
Risk assessment methods need to be looked at again
Continuing Education - too many hours
TSDF status regulated for activities that should be encouraged
Improving existing regulations
Small business - impact of pollutants vs. cost of compliance
Better science into decision-making
Duplicative requirements caused by not looking broadly when writing
regulations and enforcing them. There is a need to look for duplication across
programs
Statewide storage of all radioactive waste
Market based approach (ie. CAA trading) should be used in other areas
• Agency and adjudicatory process is complex and costly
Future discussion - EPA/MWRA, Regulated pollutants and their sources
I. ELIMINATE UNNECESSARY REGULATIONS multivote result: 18
COST/BENEFIT
RULEMAKING
RISK ASSESSMENT
BETTER SCIENCE
IMPROVE EXISTING REGs
PRESENT REALITY
• Big Cost
• Common sense has been ignored
• Common sense and cost benefit are in direct conflict (because you can not
place dollar value on human life)
• Need to understand intent behind the law
• No documented harm (backflow prevention device on fire sprinklers - see
example on last page)
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• Current regulations eliminate possibility of innovative tech. (ie. definition of
hazardous waste)
• Regulators have no rewards for exercising judgement but are held accountable
for not following reg. to the letter.
• Regulating agency measured by # of enforcements
• who's measuring success?
• how to measure success?
• why not learn from duplicate studies (other states)?
POTENTIAL FIXES
• Quality assurance for regulation writing/review
• Govt should have to comply before anyone else
• More research - Cost benefit/risk analysis
• Better understanding of business by Government
• Open Government rulemaking process
• must be good faith
• equal representation
• Industry must commit to being more involved in rulemaking process
• Some discretion for inspectors
• Review basic intent regulations
• Max use of focus groups/industry, input prior to draft regulation / early
warning
II. AGENCIES NEED TO KNOW MORE ABOUT HOW A
MANUFACTURING/BUSINESS WORKS
multivote result: 17
PRESENT REALITY
• Fear prevents sharing info.
• Agencies know very little now about industrial processes
• Inspectors are mostly asking basic process questions during inspection
• There is a flow of personnel from government to industry but not the other way
• No specialists in agencies (industry specific specialties)
• Lots of innovative technologies not being shared
• Some government people think they are specialists; write reports that show
they aren't
• Industry needs to tell government what the problems are
POTENTIAL FIXES
• Agencies hire more people with industry experience
• Need industry specialists in agencies
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• Form for industry to communicate problems to government
• Move away from adversarial work/toward common goals
III. COORDINATED INFO SERVICE IS LACKING multivote result: 11
PRESENT REALITY
• There is no single source of information
• Calling in is difficult - different information given by different people - who to
call for spill? (2 or 3 different hotlines)
• Dread of voice mail system
• Agency budget cuts - people are cut - makes it (giving information) harder to
be responsive. (Agency) Information giving is one area that needs work
• Information to general public is lacking - public doesn't know EPCRA
information is available (especially people new to environmental work)
• There is not enough information for making informed judgements - what
information is there is very hard to find
• Big environmental push seems to have passed - public now less interested than
during 1990 Earth Day
POTENTIAL FIXES
• Need general information person as first contact in agency to guide to right
person (a generalist who is articulate and helpful)
• Industry has to get out, visit agencies, ask specific questions in person, not
much luck over phone.
• Re-inspire public about this new phase of environmental protection (cooperation
and pollution prevention)
• Go to a program like TURA first, industry can get some advise/help from their
public servants
• Getting information on-line (electronic)
IV. SMALL BUSINESS SOURCES, NON-POINT & RESIDENTIAL
multivote result: 12
EXAMPLE
• MWRA - Solvent limits on business less than household sources
PRESENT REALITY
• Impact of pollutants vs. cost of compliance for small business
• Always going back to point sources. Other sources may be more load
• Some limits to MWRA less than drinking water standards
• Household doesn't see themselves as polluters
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• Example: MWRA fines for pH, oil and grease (2 quarts over two years) even
though state knew they were working on a problem (with concentration based
limits)
• Punishment does not fit the crime
• Disproportionate emphasis on point sources
• We educate the public but beat industry over the head to get compliance
• Government is there to punish, not help (has OSHA helped anyone?)
POTENTIAL FIXES
• Example: auto emissions, commercial products industry is not helping to
identify and educate about these non-point sources
• More work on educating non-point sources
• MWRA/EPA need to communicate how point sources are targeted
• Educate public - what is wrong - statewide system for household hazardous
waste, oil, etc.
• Get everybody - do a better job with existing programs
• Need appeals court/board (what about cost? No lawyers)
V. GLOBAL IMPLICATIONS: HOW DO WE ADDRESS MAJOR
COMMUNITY/LOCAL ENVIRONMENTAL PROBLEMS?
multivote result: 6
PRESENT REALITY
• Bacteria change material into metabolites that are available to bugs - some
mimic estrogen this causes our trouble
• More work needs to be done to understand this
• Get people to understand what global problems are - consensus
• People need to feel some connection to global problems
• Need to bring broad problems to local level so people can realize their effects
on them - and their abilities to help
POTENTIAL FIXES
• Educate the public
• Shoot the "doomsdayers"
• Put problems into realistic explanations
• Pay careful attention to what is happening - recognize that it is different from
the past
• Find ways to stop bugs from converting materials to something that mimics
estrogen (Research)
VI. FEAR OF CONTACTING REGULATORY AGENCIES FOR INFO
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multivote result: 3
PRESENT REALITY
• Can be anonymous - so not always a problem to contact
• Some still not trusting of contacting agencies - need to test system
• Experience of calling agency only to be questioned about compliance status
causes fear
• Conflicting information - especially hard for new businesses
POTENTIAL FIXES
• Training of agency staff
• Improve customer service
• Open up lines of communication
• New England Environmental Assistance Team - EPA - patterned after OTA
(see handouts)
VII. MA ONLY
EXAMPLE
Fire sprinkler - back flow - Boston $22 million cost: $1000/inch
CLEAN WATER
• We all care about clean water
• Commercial property managers
• Back-flow prevention devices
• Reg - DEP - Clean Water Act: Have to look here for intent of regulatory
language
• Worked on Advisory committee and got some revisions
• But fire sprinklers
• already have plate in their product design. This was adequate. There
has not been one case of contamination due to back flow through fire
sprinklers.
• look back to CWA language "No Risk." This guided decision to
include fire sprinklers.
EXAMPLES
WWT permit based on potential risk now
Preidentified issues for General/Practical Session:
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Issue #21: Agencies need to know more about how manufacturing works. Businesses are
willing to help but cannot obtain assurance from agency that if they come out to facility on
educational visit, will not enforce against technical violation.
Who's affected and how. Businesses that want to help agency to shape its rules and
practices to optimally reflect business and industrial realities. Agencies that want to receive
this help are prevented from receiving it.
Purpose of requirement. Agencies have to address pollution in a consistent manner.
Potential Fix to system. Establish policy that visits for educational purposes will be
exception to the rule. Visiting inspectors may suspend enforcement role. Substantial
violations or threats to safety, health and environment will still be covered.
Alternative Approaches. Make visits to facilities in another state, exchange program with
inspectors from that state.
General Comments. Agency personnel have attempted to arrange these visits and have failed
to obtain permission to give assurances sufficient for company hosts. Need to clarify what is
sufficient assurance and if it may be obtainable.
Issue #22: Market based approach, e.g., allowance trading under Clean Air Act, should be
applied to other areas.
Issue #23: Central or coordinated information service lacking.
Example: Divergent answers to requests on EPCRA compliance information received from
EPCRA hotlines, local LEPC and others. Information seeker puzzled about who to contact
and what actions to take in event of a spill.
Potential Solution: Develop internal agency coordinating office for resolving conflicts.
Compile commonly asked questions. Empower office to resolve conflicts within agency.
Designate office as representative of agency in seeking to resolve conflicts with other
authorities.
Comment: DEP has established INFO Line and Regional Service Centers. Office of Business
Development also performs customer service for regulatory assistance. Boston Bar
Association permit streamlining committee recommends central office to address these
problems.
Issue #24: Fear of contacting regulatory agency for information.
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Example: Response to call to EPA for compliance information consisted of close questioning
pertaining to compliance status of the caller.
Issue #25: Define the method of biotransfer of metabolized pollutants into the environment.
Explanation: Metabolic form of many pollutants mimic estrogen.
Issue #26: Agency adjudicatory process using all the elements of a legal trial and an
administrative law judge costly to appellants of agency orders.
Potential solution: Provide a means of alternative dispute resolution. Allow consideration of
economic impact of agency orders.
Comment: Need to do this without establishing ability to endrun or delay enforcement
actions. Need to maintain incentives to encourage compliance and negotiation with regulatory
authorities.
Issue #27: How do we address major long-range or global environmental problems?
(Examples: erosion, population growth, climate change, loss of habitat, loss of cropland,
depletion of fishing stocks).
Potential Solution: Create sense that environmental regulatory system can work well, so that
it can do more, and a working consensus on the balances to be struck.
Issue #28: How to address contribution from small sources, nonpoint sources, and residential
sources?
Explanation: In many areas industrial or point sources are now overshadowed by small
sources. Authority in law does not cover such sources.
Comment: Solution must be politically acceptable. (Public will resist major inconveniences).
Example of Solution: Systems for convenient disposal of household hazardous waste.
Watershed-based approach currently being pioneered by EOEA/DEP and similar place-based
approach considered by EPA may afford opportunities to effectively address small sources.
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Session on:
Recordkeeping/Reporting
Issue #29: Reporting requirements complex and onerous.
Who's Affected and How: Companies reporting under CWA, EPRCA, RCRA, TURA, CAA,
TSCA, to fire marshall, localities, etc. would like easy guide to requirements, opportunity to '
consolidate when several reports are required because of one activity.
Potential Solution: Computerize all reporting requirements. Make electronic submission
feasible. Review purpose of each requirement and identify use of information. Make
information accessible. Eliminate requirements that have no identifiable utility. Provide
inspection checklists to regulated community.
Comment: Regulatory or legislative changes may be necessary to allow elimination of some
reporting requirements. EPA developing XI2 protocol for electronic reporting. TURA
Administrative Council and DEP looking at reporting streamlining. Toxics Use Reduction
Institute focus group on this issue. DEP seeking EPA funding for pilot study to develop a
consolidated reporting form that would encompass all federal and state reporting requirements.
See recommendations of Legal Committee asked by EOEA to address this issue.
DISCUSSION OF ISSUE #29:
Who is affected - regulated and regulators, public stakeholders, NGOs
Purpose of requirements?
PROBLEMS:
- Why apply them to everyone? e.g. non toxics use, broad chemistry categories
including metals, metals in alloys must be reported
- Why duplicate Form R on Form S
- different chemical lists (delisted by Feds why not automatically delisted
by state?
- Why so many different chemical lists? Consolidate into one.
- Why do all forms come out so late?
124
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- Why do changes in forms require changes in regs?
- Inconsistencies in reporting periods between media
- Too much time cuts down on P2 efforts
- Electronic reporting to date has glitches
- Need manifest for every state you ship waste to
- Generators writing landbans for TSDFs is useless
- duplicates waste profile
- different retention times
- Why can't you write on the back of Form Rs ~ waste of paper
- Numerous overlapping training requirements
- Speed up responses to petitions to delist; exempt certain industries, users
- Consolidate into one report/electronic
- Report all sampling done in a year on one annual report (except for non-
compliance instances)
- When writing regs, makes them easy to understand, flexible enough for reportng
methods
- Every report have a space for time it required
- Repeal (MA) RTK since it is not funded or used
- Analyze/review the reports/data usefulness
- Use ISO approach of management and practices
- Self certification system
- Do away with reporting - have companies keep own records and let agencies
come there to see them
- Consolidate training requirements
- Uniform national manifest with check off for landban
125
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Issue #30: Inform regulated community of changes in requirements.
Explanation: Current system of publishing in Mass or Federal register inadequate to
inform regulated population. Environmental managers have insufficient time to read all
that is required.
Potential Solution: Send out letter to all reporting entities concerning changes.
Comment: High cost of many mailings: must find funding.
DISCUSSION OF ISSUE #30:
PROBLEMS:
- Changes to phone #s
- Adding chemicals to lists
- Definitions in regs (e.g. USTs report had ASTs added)
- Fire marshall -- changes overspill
POTENTIAL SOLUTIONS:
- "What's New" section in all correspondence for the next year
- Give more time between notification and when it goes into effect
- Agency outreach to those newly affected
- Use other resources -- trade associations
- E-mail and fax back systems
- Industry specific list of all regs/reporting requirements with time lines
126
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Issue #31: Permittees seek assurance of accuracy of agency testing.
Potential solution: allow inspectee to take split effluent sample so that they can obtain an
independent analysis.
Comment: some inspectors will allow this, some won't.
DISCUSSION OF ISSUE #31:
PROBLEMS:
- Who does this effect?
- effluent — maybe only MWRA who won't allow this
- Limits near detection limits
- POTWs apply/interpret regs differently
POTENTIAL SOLUTIONS:
- Limits must be realistic, based on risk assessment and analytical capability
- Address issue with MWRA
Issue #32: Air registration sources have to file annually even if there are no changes in
their processes or emissions.
Who's Affected and Why: Paperwork for reporters increased, time spent with no value
added.
Why it is this way: To ensure that agencies have information on use of materials causing
emissions.
Potential solution: Simplify the reporting, establish "No change" notifications. Copy last
year's submission and change date at the top. (If it really is the same).
Comment: DEP developing policy on this issue. Decreases in emissions will result in
decrease in compliance fee. Annual reporting is opportunity to reduce fees if you have
reduced emissions.
127
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DISCUSSION OF ISSUE #32:
PROBLEMS:
- Who is effected -- major sources
- Comapnies that drop below major level must still file annually
- Why? Different states apply fed. requirements differently to calculate compliance
fees
POTENTIAL SOLUTIONS:
- Why report at all?
- Why differences between states? (e.g. NH)
- Why not use consolidated report we developed in #29 since so much of this data
is also on Forms R and S
- Why not just every three years?
- Revision to Mass. SIP?
Issue #33: Spill and release notifications, and emergency plans, are duplicative.
Explanation: Spills may have to be reported to DEP RCRA, DEP 21 E, LEPC, SERC
National Response Center, EPA. Emergency plans required by CWA, RCRA, EPCRA
may be redundant.
Who's Affected and How: Those making notifications may be penalized for failing to
notify one of the required recipients.
Potential Solution: Establish well-publicized 800 number which can mobilize all
necessary response actions and disseminate information to agencies as needed Clarify that
existing regulations allow consolidation of plans, if so. If not, change requirements to
spell out how consolidated plans may be acceptable.
128
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DISCUSSION OF ISSUE #33:
PROBLEMS:
- Who's affected?
- Who's notified? Fire dept, State EPC, LEPC, DEP, POTW, NRC, town Cons.
Comm. — too many people
- Fire prevention involved different agency
POTENTIAL SOLUTIONS:
- Consolidate notification to one agency, maybe DEP, to notify all others
- Consolidate chemical lists
- Have one contact person to help you with all spillplans similar to permitting
SUMMARY OF ISSUES:
- What is relevant to report?
- Who needs the information?
- How can it be usefully reported?
- How do we determine if the environment is healthy?
- emphasize env. health and monitoring vs. reporting
- Recordkeeping and reporting is defensive; how do we take on offensive approach
to doing P2, improving the environment?
- Once a firm has established credibility and demonstrated its recordkeeping
capabilites, no periodic state reporting should be required
- ISO, NRC, UL — Reward good performance; have a system to do it
129
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GENERAL COMMENTS FROM THE SESSION ON RECORDKEEPING/REPORTING
Major Issues
Takes too much time, especially for small companies (Issue #29);
- takes half the year
- no deminimis means you spend a lot of time on small quantities; where is
the benefit?
Consolidate reporting into the "Mother of All Reports" -- one report
What are they doing with all this data? (Issues #29, #32) -- DEP is proposing
moratorium
Report calculations for applications (Source Reg.) when you've just done
• Electronic reporting
- expand where you can do it
- problems: computer/printer supported glitches
Uniform national manifest
Landbans are repetitive (to have generators fill them for TSDFs)
Bring in OSHA on mutual issues (DOT is also involved)
130
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Facilitators of RIO breakout sessions received the following guidance.
KEEP IT CONSTRUCTIVE! GET TO SPECIFICS! ASK FOR EXAMPLES,
ILLUSTRATIONS!
Facilitators must let the breakout sessions go where the group wants to take them, but try
to use the established formats. Prelisted issues do NOT have to be used. The group can
make up its own.
About the scribes: Members of the audience who feel the scribes have not captured their
comments correctly should be encouraged to meet with the scribes afterwards to clarify.
Facilitators should emphasize that we will not address all existing problems or cover all
aspects of the problems or potential solutions. This is just the beginning of a
business/government dialogue. They should write their comments down and submit them
to NBEN, either using the form provided or at any other time. They should be
encouraged to join a working group. They may be reminded that the agencies have other
avenues for receiving comments - advisory committees and comment periods.
Questions to keep in mind during discussions. DON'T HOLD UP THE DISCUSSION
TO ANSWER ALL OF THESE.
Is it clear or precise enough?
Does it involve legislation, regulation, policy, interpretation, practice?
Have we correctly identified the authorities and stakeholders?
Can we eliminate an unintended or unnecessary adverse economic effect?
Can we eliminate a barrier to pollution prevention, recycling, innovative technology, or
other environmentally beneficial activity?
Are there obvious next steps? Quick fixes?
What are the pros and cons of the proposed solutions?
Is there consensus on any issue or aspect of an issue?
Do we need more information on something?
131
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Special Focus: Government-Industry Partnerships
How Companies in the Merrimack
Valley Built a P2 Self-Help Network
The recent growth of
nonregulatory technical
assistance programs has
created a window of
opportunity to expand
government-Industry
cooperation. Simulta-
neously, businesses are
supporting each other to
Improve environmental
performance. Recognizing
these trends, the Massa-
chusetts Office of Techni-
cal Assistance Invited
twenty manufacturers
based In the Merrimack
Valley region to form an
environmental self-help
networkfor business. The
Merrimack Business
Environmental Network,
started as an experiment
two years ago, has
evolved Into a successful
model of government.
Industry, and community
partnership.
Richard Reibstein, Cynthia Barakatt, and George Frantz
THE MASSACHUSETTS OFFICE of Technical Assistance for Toxics Use
Reduction (OTA), like government agencies in many states that
provide nonregulatory technical assistance, has had to work hard to
gain the trust of the business community.
When hazardous waste source reduction specialists from OTA
first offered free on-site consultations in 1986, there were few takers
from industry. The passage of the state's Toxics Use Reduction Act in
1989, which includes a strong guarantee of confidentiality to anyone
working with OTA, helped ease business fears that OTA staff were
really regulators in disguise. Still, even with more than one hundred
public events, many conferences, and repeated endorsements by
business and political leaders, many companies are not sure that
government can simultaneously enforce laws and offer useful advice.
Today, the number of businesses working with government agen-
cies to avoid pollution is growing. By the end of 1993, the Massachu-
setts OTA had provided assistance to more than 400 businesses and
industries across the state. OTA has also been a catalyst to help
improve the relationships that businesses have with each other. In
fact, a key factor driving the growth of nonregulatory technical
assistance in the state has been the willingness of companies to share
their pollution prevention (P2) strategies with peers.
Seeing the opportunity to further expand its technical assistance
efforts by tapping positive trends in business-to-business and govern-
ment-to-business cooperation, the OTA decided to try an experiment.
Typically, nonregulatory assistance is defined as government helping
business, but in this instance OTA proposed the creation of a nonpar-
tisan regional business networking organization in which companies,
rather than OTA, could take the lead in disseminating technical and
management support.
The group would be supported through a federal Environmental
Protection Agency (EPA) grant awarded to OTA for innovative pollu-
tion prevention strategies in the Merrimack River watershed region
in northeastern Massachusetts and southeastern New Hampshire.
The organization's primary purpose would be to serve as a self-help
resource for business, but members from the government assistance
Richard Reibstein is assistant director, Cynthia Barakatt is Merrimack project
coordinator, and George Frantz is a senior project manager for the Massachusetts
Office of Technical Assistance for Toxics Use Reduction.
Pollution Prevention Review I Spring 1994
Copyright @ 1994, John Wiley & Sons, Inc.
Reprinted by permission of John Wiley & Sons, Inc.
165
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Richard Relbstetn. Cynthia Barakatt, and George Frantz
...the MBEN agenda has
quickly broadened to
address industry's impact
on all media and,
importantly, economic
concerns.
programs and the environmental community would also be included.
In the fall of 1992, OTA asked twenty manufacturers based in the
Merrimack Valley region to join them in forming the Merrimack
Business Environmental Network (MBEN). The New Hampshire
Department of Environmental Services' pollution prevention section
and the Merrimack River Watershed Council (an interstate nonprofit
environmental group) were also invited to become members.
Nearly two years after the first meeting, MBEN has proved to be
a resounding success. It has attracted over seventy businesses of all
sizes and from many industries. Small metal-finishing companies,
international high-technology manufacturers with facilities in the
Merrimack Valley (AT&T, Hewlett-Packard, and Tri-Star), a chain of
dry cleaning stores, and a wood stain manufacturer are among the
network's members. Moreover, an ongoing dialogue outside of work-
shops and site visits has developed between businesspeople and
OTA's technical assistance specialists. And although MBEN main-
tains a strict pledge to refrain from any political activities, it has
become a recognized source of business views on local and regional
environmental issues and projects.
How MBEN Works
By consensus, the group first developed the following mission
statement:
The Merrimack Business Environmental Network is a coalition of
businesses, agencies and associations which is committed to a
shared concern for the Merrimack Valley, its rivers, and the Valley's
quality of life. This Association has made a long-term commitment
to seek and implement solutions to promote pollution prevention
through improved management and technology, while enhancing
the economic viability of the business community.
Initially, members focused on how they could better coordinate their
efforts to clean up and prevent industrial contamination of the
Merrimack Valley's river resources. But the MBEN agenda has
quickly broadened to address industry's impact on all media and,
importantly, economic concerns.
Corporate members rotate the responsibility of hosting monthly
meetings at their facilities. At these meetings, and additional MBEN-
sponsored workshops and seminars, business members exchange
ideas on compliance management, ways to achieve competitive ad-
vantage by getting ahead of the regulations, technical successes with
pollution prevention, and other information that will help them deal
with day-to-day business challenges.
For example, several MBEN companies were alerted to chloro-
fluorocarbon (CFC) labeling requirements when Ed Surette, environ-
mental engineering manager atM/A Com Inc., a microwave manufac-
turing firm in Lowell, brought it to their attention at a meeting.
Because of Surette's presentation, many members were well-pre-
166
Pollution Prevention Review / Spring 1994
-------
How Companies in the Merrimack Valley Built a P2 Self-Help Network
...industry attendees
seemed most responsive
to presentations given by
local companies.
pared weeks later when they began receiving letters from clients
wanting to know if they used ozone-depleting chemicals in their
manufacturingprocesses. Burette's presentation also motivated many
members to begin work on finding alternatives to CFC refrigerants,
scheduled to be phased out starting in 1995.
MBEN members also received a preview of the state's training in
toxics use reduction planning and were, thus, able to begin the process
ahead of schedule.
At another monthly meeting, James Klecak, manufacturing man-
ager at Americraft Carton, Inc., discussed his firm's use of a prototype
P2 system that reduces volatile organic compound (VOC) emissions
through reduced use of isopropyl alcohol in the printing process. By
using an alcohol substitute, Americraft Carton lowered its emissions
by several tons and saved thousands of dollars.
The group's first conference was held at a state park on the banks
of the Merrimack River. The conference attracted nearly one hundred
representatives from regional businesses who came to hear their
peers' views on the latest in proven P2 strategies and technologies.
Lee Wilmot, environmental manager at Hadco Corp., a New Hamp-
shire-based firm that manufactures printed circuit boards, gave a
presentation about a locally-developed (Beverly, Massachusetts) pat-
ented process that his firm uses to recover from 60 to 85 percent pure
copper from wastewater streams. The system saves copper by recy-
cling it and eliminates the generation of hazardous sludge from this
process.
In addition to attending presentations, conference participants
had the option of taking an evening boat ride on the river, a ride
specifically intended to remind them of the primary resource that
MBEN is interested in protecting.
Why a Business Network?
OTA identified two compelling reasons to start MBEN.
Business trusts business
One was the fact that, even though OTA was having some success
convincing businesses to listen to its recommendations concerning
pollution prevention, it was clear that companies trusted each other
more than a government office. At every OTA conference or workshop,
industry attendees seemed most responsive to presentations given by
local companies. If an OTA representative suggested a way to reduce
acid waste by switching from acid dipping to mechanical cleaning of
a metal surface, the idea might or might not be well-received. On the
other hand, when an employee of a company stood up and said, "This
works and this is how we did it," the audience was much more
receptive. Lee Dane, who provided source reduction consulting for the
state, called this the "Joe down the block syndrome." It has been
noticed time and time again.
To make the most of this "syndrome," OTA staff members have
Pollution Prevention Review I Spring 1994
167
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Richard Reibstetn, Cynthia Barakatt. and George Frantz
made a point of contributing to the organization as facilitators,
rather than leaders, of the group's activities. Staff members from
OTA organize and moderate the meetings, but it is MBEN members
who determine the agenda and make organizational decisions by
consensus.
Different from trade groups
The second factor was the absence of a business organization in
the area that was specifically created to bring together companies
from many industries with a mutual commitment to environmental
excellence and with no other purpose than to share their strategies.
There is an Environmental Business Council in the region that
promotes companies that make environmental products or provide
environmental services. By contrast, MBEN discourages members
from using its events to establish sales contacts. In fact, MBEN does
not allow vendors or consultants selling products or services to attend
meetings, except by invitation.
Although trade associations also typically serve companies in a
specific industry sector, the MBEN membership includes a full
spectrum of large and small manufacturers and service businesses.
In this way, MBEN can stick to its mission and its role as a
resource for any kind of company that is faced with environmental
requirements or has environmental consequences arising from its
activities.
Most significantly, MBEN differs from trade organizations, be-
cause it does not engage in lobbying or other political activities.
Although individual members may offer testimony or comment on
proposed regulations or legislation, the group as a whole can not.
Strict adherence to political neutrality has been particularly
critical to sustain the organization's emphasis on providing a nonpar-
tisan forum in which businesses can informally discuss issues of
environmental concern with other firms, government officials, and
environmental groups. OTA has made it clear that, if MBEN ever
crossed the line to influence the legislature or the public on a vote or
policy decision, OTA would be forced to withdraw as a member.
...MBEN differs from trade
organizations, because It
does not engage In
lobbying or other political
activities.
Measures of Success
Getting companies to attend and host monthly meetings and
support MBEN*s other activities is not easy. The spark that keeps
industry's attention in many cases is the kind of information MBEN
delivers.
Spotlight on industry
Because of contacts made through MBEN, business members
routinely call each other to ask about P2 techniques or check on the
reputation of vendors or products. They seem to particularly relish
the opportunity to show off what they have done—not only to prevent
pollution from manufacturing processes, but also to show the im-
168
Pollution Prevention Review / Spring 1994
-------
This informal, non-
threatening link between
regulators and the
regulated community is...
a major attraction of
MBEN.
How Companies In the Merrtmack Valley Built a P2 Self-Help Network
provements in process efficiency. Indeed, putting the spotlight on
what other companies are doing has proved to be exactly what
corporate members are looking for.
James Klecak of Americraft Carton recalls that, since his presen-
tation on alcohol substitutes to reduce VOCs in his firm's printing
process, a number of printers have visited Americraft's plant to see
how it works. "We feel we've played a role in helping other printers in
the area get involved in pollution prevention," says Klecak.
Performance yardstick
MBEN members have also noted that, by belonging to an alliance
of environmentally progressive companies, they can use fellow mem-
bers as yardsticks against which to measure themselves.
"When you get involved with a group of people who share a lot of
the same beliefs, it is easier to evaluate yourself," says Charles Anton,
vice president of Anton's Cleaners, a forty-store chain of dry cleaners.
"I think I am environmentally responsible, but until I share my ideas
and rub elbows with people who feel the same way, I won't know the
level I'm really at."
Informal bridge to regulators
OTA has reason to be pleased not only with the number of
businesses reached through this program, but also the improved
relations between business and government. Companies and the
state's twenty technical assistant specialists now routinely exchange
phone calls. In addition, OTA P2 specialists have become an informal
conduit of information between businesses and the state's regulators,
while respecting the TURA provision of business confidentiality.
New Hampshire has also seen benefits from the establishment of
MBEN. "It is definitely helping to break down the barriers," says
Chris Simmers of the New Hampshire Department of Environmental
Services commissioners office. "I believe that MBEN has led to
companies feeling more comfortable about contacting us with ques-
tions."
This informal, non-threatening link between regulators and the
regulated community is, for many businesses, a major attraction of
MBEN. Mark Chrisos, environmental manager for Raytheon's Mis-
sile Systems Division in Bedford, said that his previous contact with
government officials was only through regulatory inspections. "It is
great to be able to exchange information about regulatory issues in a
relaxed, casual atmosphere," says Chrisos.
Business links to environmental community
The membership of the Merrimack River Watershed Council has
also proved to be beneficial to businesses and the Council. The
Watershed Council has co-sponsored several technical workshops
with MBEN. At these events and regular meetings, companies are
reminded of environmentalists' concerns in protecting the river, and
Pollution Prevention Review / Spring 1994
169
-------
Richard Relbsteln, Cynthia Barakatt, and George Frantz
the Watershed Council gets to meet businesspeople with a strong
interest in seeing industrial pollution prevention efforts succeed in
the Merrimack River Valley.
A known source for business views
MBEN is becoming known throughout the region and the state.
The Massachusetts Executive Office of Environmental Affairs turned
to the network when it was looking for business participation in a
statewide watershed management conference last fall. And MBEN
recently agreed to accept two seats on the management committee of
the Merrimack River Initiative (MRI), a two-state, regional compre-
hensive watershed protection and planning effort led by EPA's Region
I office. This was after several unsuccessful tries by MRI to solicit
business input on the Initiative.
In addition, MBEN has caught the attention of environmental
groups and others interested in working with business on pollution
prevention issues. One Salem-based group interested in watershed
protection and management has attended MBEN meetings and met
with OTA to seek advice on how to set up a similar organization.
The Network's Future
Once the federal EPA grant ends in the fall of 1994, OTA staff
support will be curtailed. As a result, MBEN is in the process of
becoming an incorporated nonprofit organization to continue its work
as a nonpartisan networking organization. The group is expected to
derive much of its operating income from membership dues and fees
for workshops and seminars. In addition, MBEN plans to solicit grant
funding for special projects and is looking into the possibility of
finding a "partner" to share office space as well as administrative and
overhead costs. The group plans to hire a full-time staff person to
coordinate meetings, workshops, and conferences.
It remains to be seen how MBEN will fare after it incorporates.
There is no doubt, however, that what began as an experiment has
evolved into a working model for building a network of government
agencies, businesses, and environmentalists dedicated to protecting
the environment. +
170 Pollution Prevention Review I Spring 1994
-------
M B E N
Merrimack Business Environmental Network
c/o M/A COM, Inc.
1011 Pawtucket Blvd., Lowell, MA 01851
(MA) 617-727-3260 Ext. 631 • (NH) 603-271-3503
Gillette
CARTON, INC
Merrimack Valley Pollution Prevention Project
Dear Merrimack Valley Company:
August 25, 1993
Raytheon
H ^L Ideal Tape
MERRIMACK
RIVER
WATERSHED
COUNCIL
Merrimack River Initiative
AT&T
MBEN... Who We Are
We are members of the Merrimack Business Environmental Network (MBEN), and we
invite you to join with us. Our group is not for profit. It is composed of Merrimack
Region businesses, coming together to help each other understand how best to deal
with environmental regulations, and improve our environmental performance. The
network is not a money-making organization. The members share their experience,
their successes, their problems, and make use of available expertise.
The group has a relationship with government technical assistance agencies, and has
access to regulatory officials through these assistance offices. This gives us up-to-
date information on environmental developments and also a chance to make our
views known to those making the rules. The group is dedicated to both maintaining
and promoting the viability of businesses in our region, and protecting the resources
that make this area beautiful. Some of the members have saved money by taking
action to prevent pollution, rather than treating it after its creation, and are willing to
share this experience with others.
MBEN Mission Statement
The Merrimack Business Environmental Network (MBEN) is a coalition of
businesses, agencies and associations committed to a shared concern for the
Merrimack Valley, its rivers, and the Valley's quality of life. This Association
has made a long-term commitment to seek and implement solutions to
promote pollution prevention through improved management and technology,
while enhancing the economic viability of the business community.
Enclosures:
1.
2.
3.
4.
5.
MBEN Environmental Survey
Survey return envelope (c/o John Gihlstorf, Chairman)
MBEN Membership (or additional information) application
MValley Business Environmental Conference flyer
Conference Registration form (please copy for additional registrations)
-------
About the MBEN Survey
Enclosed is a survey that we have devised to give us a sense of the needs of Merrimack
region businesses, so that we can target our events to serve those needs. As you can see,
the survey is designed to be confidential if you so desire. We ask for a small amount
of generic information up front, so that we can know what kind of company you are, and then
if you want to join the group or register for our first conference (see announcement), you can
fill out the name and address information on the separate sheet and send it in.
Please do not take an inordinate amount of time filling out this survey, just do your
best. We have provided an envelope, with postage paid, so that sending it back is as easy
as possible.
A word of clarification is necessary to dispel any fears that this survey is a sneaky effort
by the government to get you into trouble. It is true that the Merrimack Business
Environmental Network was originally formed by the Massachusetts Office of Technical
Assistance for Toxics Use Reduction, and the New Hampshire Department of Environmental
Services Pollution Prevention Program, working together under a grant from the EPA.
Anyone who knows these offices, however, knows that they are not enforcement agencies -
they are specifically dedicated to helping businesses, and keep their information confidential.
From the beginning, the idea of the group has been that these government agencies do not
own or direct this work. The group belongs to the business members, and the members
make decisions on a participatory basis. The technical assistance agencies are just there to
help, and will continue to do so as long as the group maintains its dedication to the purpose
of environmental improvement.
Therefore, your name and the information in this survey will not be used for enforcement or
compliance purposes.
However, we will want to announce the summary of survey results (without any company
names) at our first conference on September 23, and publicize the results as part of our
membership drive. So please a take moment to fill out the survey, and consider joining
MBEN. At this time, there is no charge for membership.
Merrimack Business Environmental Network Survey August 1993 (Page -2-)
-------
Merrimack Business Environmental Network (MBEN) Survey
Confidentiality: Returning the survey will not target your firm for regulatory
enforcement actions!
Any information that you provide will be kept confidential regarding association with your company's
name. To ensure this promise, your name and address is requested on a separate sheet from the
rest of the survey questions. You may even choose to return the two forms under separate cover.
As for the information that you provide in the survey questions, we will compile this data to create a
summary "profile" of the business community in the Merrimack Valley. If you complete and return the
survey, you will receive a summary of the profile results.
Please complete the generic information below. If you are interested in participating in MBEN or
wish additional information, please complete the separate membership information sheet and return
either under separate cover or enclose with the attached survey.
TYPE OF BUSINESS and PRINCIPAL PRODUCT (please indicate SIC code if known)
NUMBER OF EMPLOYEES
CITY STATE ZIP
For completing and returning the survey, you will receive a summary of the profile results.
Thank you for taking the time and effort you took to complete the survey and support MBEN in its
objective of helping business with environmental compliance and economic viability.
Please return completed forms to:
John Gihlstorf, MBEN Survey Chairman
c/o Cabot Stains, inc.
100 Hale Street
Newburyport MA 01950
Merrimack Business Environmental Network Survey August 1993 (Page -3-)
-------
MERRIMACK BUSINESS ENVIRONMENTAL NETWORK SURVEY
Please circle or check the appropriate answer or clearly write in your answers to the questions
below, being as detailed as possible. All answers apply to the facility or facilities in the Merrimack
watershed area (see enclosed map and list of towns) under your control.
1. Do you need help "sorting out" environmental compliance issues?
YES NO UNSURE
2. How many people does your company employ at this facility?
0-10 11-50 51-100 101-250 251-500 501-1000 >1000
3. Do you have any staff dedicated to addressing environmental and health/safety (EHS) issues?
( ) One or more full-time ( ) One part-time ( ) NONE
4. Have you set aside money for environmental, health & safety (EHS) regulatory compliance?
YES NO
a. Are you aware of your cost of compliance? ( ) ( )
b. Would you be willing to indicate the range of your cost of compliance?
( )$1k-4k ( )$5k-10k ( )$ Hk-24k ( )$25k-50k ( )$50k(+)
c. Do you have a dedicated EHS budget? ( ) ( )
d. Does your present accounting system separate or
somehow track environmental costs? ( ) ( )
5. If you answered YES in question #4 above, how do you categorize the accounting of your
environmental costs - as:
( ) a. Capital Investment ( ) c. Overhead
( ) b. Production costs ( ) d. Environmental cleanup costs?
6. What percentage of annual total budget does this make up?
0-1% 1-3% 3-5% 5-10% >10%
Merrimack Business Environmental Network Survey August 1993 (Page -4-)
-------
7. Has your company made prior environmental expenditures in anticipation of upcoming
regulations (e.g. removal of underground storage tanks, on-site wastewater treatment, or switching
from CFCs to non-ozone depleting chemicals {non-ODCs})? YES NO
8. If yes in question 7, expenditures for what activities?
9. Do you have an active pollution prevention program? For example, have you reduced or
eliminated the use of a toxic chemical by substituting it with a safer material, or by using the
chemical more efficiently, or by redesigning a process or a product, or by other means? If so,
please explain. ^^
10. Do you believe that pollution prevention activities can save your company money?
By reducing potential fines or required fees? YES NO
By reducing waste disposal costs? YES NO
By reducing materials costs? YES NO
11. Which environmental areas would you like to understand or manage better?
Rate the items a-m below on a scale of 1 to 4, with:
1 = greatest importance to you 2 = important
3 = limited importance 4 = unimportant or doesn't apply
Rating Issue
a. New Clean Air Act
b. Refrigerants and CFC Labeling
c. Hazardous Waste Laws
d. Changes to Superfund Law
e. Toxic Chemical Use Reporting and Planning (SARA.TURA)
f. Volatile Organic Chemical Emissions
g. Clean Water Act
h. Stormwater Discharge Permits
i. NPDES permitting
j. Packaging Requirements
k. Recycling Opportunities
I. Health & safety issues for workers (OSHA regulations)
m. Other
12. Which environmental laws do you find especially difficult to meet compliance requirements or
find to cause inefficiency in your company's activities?
Merrimack Business Environmental Network Survey August 1993 (Page -6-)
-------
13. Are you involved in a group (eg, trade association) that helps keep you informed on
environmental issues?
YES NO Don't know what's available
14. Do you recycle any of the materials listed below? (circle)
water paper cardboard acids rubber solvents ink plastic
precious metal scrap metal wood scraps other
15. Have you ever used a waste exchange or other materials exchange program?
YES NO Don't know what it is
16. Would you find a materials and used equipment exchange listing useful (to list or obtain used
items or equipment)?
YES NO
17. Please use the space below to list any material you would like to recycle, or a particular
feedstock material you use that could be obtained as a waste from someone else.
18. Are there other factors that are preventing you from accomplishing more pollution prevention?
19. Are there other environmental problems that you think should be addressed?
20. How do you currently get information about environmental matters or new products or
processes that would help you avoid creating pollution? (Please check all that apply)
( ) Trade Magazines ( ) Trade Associations
( ) Newspapers ( ) TV or Radio news programs
( ) Vendors ( ) Government agencies (MA OTA or NH DES/P2)
( ) Friends in business ( ) Chamber of Commerce
21. Would you be willing to share information with other area businesses about environmental
information you have gathered or steps which you have taken to avoid creating pollution?
YES NO
Merrimack Business Environmental Network Survey August 1993 (Page -6-)
-------
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making the rules.
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region, and protecting the resources that m
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The Merrimack Business Environmental Net
is a coalition of businesses, agencies and a:
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solutions to promote pollution prevention
through improved management and technol
while enhancing the economic viability of th
business community.
MERRIMACK ENVIRONMENTAL
BUSINESS NETWORK (MBEN)
River Valley EnvironmentallBusiness Conference
September 23rd; Maudslay State Park
(near Newburyport, MA)
For area businesses concerned with:
1. Complying with environmental regulations
2. Increasing economic competitiveness
3. Improving the quality of life in the Merrimack
River (and tributaries) watershed areas
If you 're in business and having problems
understanding or implementing environmental policies
and practices in your company Join us for a different
type of conference by a different type of group.
MBEN's "River Valley EnvironmentallBusiness
Conference" will be a relaxed, inexpensive and
very informative look at what plans businesses
need to develop and implement in order to
comply with environmental regulations in the
90's. Since MBEN is an organization of busi-
ness partners, we view things from a business
perspective... simple, action-oriented, do-able.
The conference will be held in a beautiful park-
like setting (well protected by a large tent, in
case of rain) and in a relaxed (but professional)
atmosphere at Maudslay State Park, on a bluff
overlooking the Merrimack River. A delicious
catered picnic lunch is included with registration.
After the close of business, approximately 4:30 PM, we
have arranged for an optional 2-hour tour of the
Merrimack River aboard a tour boat out of
Newburyport. Cost of this is only $12 and can be
included with your conference registration. Relax
while you remind yourself exactly how beautiful and
important the River is to the region's quality of life.
-------
THE NORTHEAST BUSINESS ENVIRONMENTAL NETWORK
The Northeast Business Environmental Network, Inc. (NBEN) is a non-political forum for
businesses, government agencies, and environmental advocates who support environmental
excellence in business operations as a means of achieving a healthy economy. As a group, NBEN
members:
• participate in an on-going dialogue among business, government and environmental
advocate members on environmental issues
• share the latest information about pollution prevention and other technologies with
member companies of all sizes and product type
• hold monthly meetings as well as workshops and conferences on topics selected by
members
All those applying for membership are asked to review and sign NBEN's Statement of Purpose
as a condition of joining NBEN. The signed statement should be returned to Membership
Chairman Ed Surette with your dues payment. (See enclosed membership application)
NBEN has two classes of membership, Senior and Associate Members:
• Senior Members are companies whose operations have the potential to directly
impact the environment, such as product manufacturers. Non-regulatory government
agencies also are allowed in this membership category. Senior members may serve as
NBEN officers or executive committee members.
• Associate Members are other types of businesses, such as service companies and
consulting firms, as well as environmental organizations and regulatory government
agencies. Associate membership will be granted to potential marketers upon written
agreement that they will market their products and services only by invitation of the
Board of Directors.
All members receive discounts on registration for NBEN-sponsored workshops and conferences.
If you have any questions or would like additional information about the benefits of NBEN
membership, contact Ed Surette, NBEN Membership Chairman at M/A COM, 1011 Pawtucket
Blvd, Lowell, MA 01851. Ph: 508-442-4283 Fax: 508-442-4187.
-------
NORTHEAST BUSINESS ENVIRONMENTAL NETWORK INC.
Statement of Purpose
The purposes for which the corporation is formed are as follows:
a) To educate and assist organizations and businesses whose activities have the potential to
affect the environment in preventing pollution and avoiding damage to natural resources
in an effort to preserve and promote the environment and public health.
b) To support and encourage the adoption of environmentally safe practices through the
distribution of accurate and objective information including but not limited to:
1. environmental regulatory requirements
2. environmental health of local resources, and
3. current opportunities to protect and/or enhance natural resources.
c) To promote the conservation and protection of natural resources through presentation
of the latest technologies, practices and techniques for avoiding pollution and through
demonstration of cost-effective methods of complying with environmental requirements
and safeguarding local resources.
d) To encourage Members to form collaborative alliances with governmental agencies and
environmental organizations which will result in a greater awareness of potential
environmental problems and more efficient means of reaching solutions,
e) To engage generally in any activity which may lawfully be carried on by a corporation
which is organized under Chapter 180 of the General Laws of Massachusetts and which
is exempt from federal income taxation under sec. 501(c)(3) of the Internal Revenue
Code of 1986, as both may be in effect from time to time.
I have read the above Statement of Purpose and pledge that as a member of NBEN the company
or agency I represent will abide by these principles.
Signature: Date:
Title:
Company:
-------
NORTHEAST BUSINESS ENVIRONMENTAL NETWORK, INC.
Membership Form
NAME
TITLE
COMPANY
ADDRESS
CITY STATE ZIP_
TEL FAX
TYPE OF BUSINESS AND PRINCIPAL PRODUCT
SIC CODE No. of Employees
Membership dues: Please enclose a check for membership dues with the completed application
and signed Statement of Purpose. Annual dues per company are as follows:
SENIOR MEMBERS:
Fewer than 50 employees $90 101 to 499 employees $250
51 to 100 employees $125 500 or more employees $500
ASSOCIATE MEMBERS:
All for-profit companies regardless of size $500
Please send the completed form, signed copy of NBEN Statement of Purpose and a check for
membership dues to NBEN Treasurer William Lindsey, Environmental Affairs Manager Veryfme
Products Inc., 210 Littleton Road, P.O. Box 670, Westford, MA 01886-0670
-------
NORTHEAST BUSINESS ENVIRONMENTAL NETWORK INC
The purposes for which the corporation is formed are as follows:
a) To educate and assist organizations and businesses whose activities have the potential to
affect the environment in preventing pollution and avoiding damage to natural resources
in an effort to preserve and promote the environment and public health.
b) To support and encourage the adoption of environmentally safe practices through the
distribution of accurate and objective information including but not limited to:
1. environmental regulatory requirements
2. environmental health of local resources, and
3. current opportunities to protect and/or enhance natural resources.
c) To promote the conservation and protection of natural resources through presentation
of the latest technologies, practices and techniques for avoiding pollution and through
demonstration of cost-effective methods of complying with environmental requirements
and safeguarding local resources.
d) To encourage Members to form collaborative alliances with governmental agencies and
environmental organizations which will result in a greater awareness of potential
environmental problems and more efficient means of reaching solutions.
e) To engage generally in any activity which may lawfully be carried on by a corporation
which is organized under Chapter 180 of the General Laws of Massachusetts and which
is exempt from federal income taxation under sec. 501(c)(3) of the Internal Revenue
Code of 1986, as both may be in effect from time to time.
I have read the above Statement of Purpose and pledge that as a member of NBEN the company
or agency I represent will abide by these principles.
Signature: Date:
Title:
Company:
-------
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April 6, 1995
Dear interested citizen:
We, the chief officers of environmental agencies, invite you to participate in a unique
opportunity to share your ideas with us. The Northeast Business Environmental Network
is holding a brainstorming session on April 27 to generate ideas for Regulatory
Improvement Opportunities (RIO), and we hope you will respond to their invitation to
submit ideas. Some of you may also agree to participate in the RIO working group, which
will further develop the ideas generated by the brainstorming event.
Although we all feel there is no doubt that environmental requirements have preserved the
resources and protected the health of the public and the environment of this region, we
recognize that there are many ways in which the regulatory system can and should be
improved. We share in a belief that it is absolutely possible to reduce the economic impact
of regulations, while enhancing environmental protection at the same tune, and we are
committed to these twin aims.
Our agencies are doing many things to become more open to your advice, comment, and
queries. In the past few years, we have all moved to establish a greater emphasis on
assistance and cooperation. We think of RIO as just one event in a larger dialogue that we
envision as continuing as long as it is necessary. We hope you will participate with us in all
our future efforts to work together for environmental and economic progress. Thank you
for your interest.
Sincerely,
-X
onn E
Jdlin DeVillars
Administrator
US EPA
New England
K^
y Coxe
Secretary
MA Executive
Office of
Env. Affairs
Tom Powers
Acting Commissioner
MA Dept. of
Environmental
Protection
Robert Vamey
Commissioner
NH Dept. of
Environmental
Services
-------
Northeast Business Environmental Network
April 6, 1995
To : Regulated Community
I am pleased to invite you to take part in a very important event. On the morning of Thursday,
April 27, we will come together in a brainstorming session to identify regulatory improvement'
opportunities (RIO). The meeting will be held at the Westford Regency, conveniently located at
exit 32 off Rte. 495 in Westford Massachusetts. Your participation will lead to the successful
identification of regulatory barriers to environmental, as well as economic, improvement.
Reinventing Regulations, Regulatory Reform, Regulatory Relief - these are all current terms
which describe the need for government at all levels to review all regulations and remove or
amend rules which present barriers to environmental excellence and regional economic growth.
We have a unique opportunity to have significant input into this process. The resulting
recommendations will be provided to the White House, Congress, EPA New England, the
Massachusetts Office of Environmental Affairs, Massachusetts DEP and New Hampshire DES.
NBEN is a nonpartisan organization of large and small regulated businesses, government
agencies and environmental advocates committed to economic growth and environmental
exceUence. We have been selected by EPA New England to conduct this forum as a component
of its reinvention initiatives.
The brainstorming sessions will begin with a review of previously identified issues. Your prior
written input of topics important to you will facilitate the forum discussion. We will then break
out into several groups to further explore individual's input and recommendations for solutions.
The stakeholders will then reconvene and each group will report on its progress.
We must have confirmation of your willingness to attend. Please send your name, business or
professional affiliation, address and telephone number to NBEN - RIO c/o Gabriel Paci, Raffi
and Swanson, Inc., 100 Eames Street, Wilmington MA 01887 or fax to 508-658-3366. '
You may submit topics for discussion to Rick Reibstein, Office of Technical Assistance, Room
2109, 100 Cambridge Street, Boston, MA 02202 (phone 617-727-3260 ext 688 or fax 617-727-
3827).
Please call me at 617-933-4200 if you have any question on this dialogue or on NBEN. I hope
you are able to join us in this important effort to improve the regulatory process.
Sincerely,
Gabriel Paci, Chairman
Northeast Business Environmental Network
President/CEO, Raffi and Swanson, Inc.
-------
The Rio Forum
William Aloisi
Erving Paper Mills, Inc.
Tom Armen
Envir onmenta 1 , Inc .
Kenneth Austin
General Scanning Inc.
solo Avram
CPF Incorporated
Paul E. Bagley
Atwood and Morrill Co., Inc.
cyntnia BaraKatt
MA OTA
Judy Barber
MA DEP - NERO
Donna Frazier Barnes
Hewlett-Packard Company
Richard Barry
M/A-Com
Kim Bensen
United Parcel Service
Eugene B. Benson, Esq.
Mass. Water Resources Authority
R.J. Berlandi
Art Berner
A. J. Associates
peter Biggins
W.F. Biggins Associates, Inc.
Mark Bornstein
OSRAM Sylvania
Francis B. Boucher
S.S.B. Realty, Inc.
Ronald B. Child
California Products Corporation
Mark Chrisos
Erving, MA
Wilmot, NH
Watertown, MA
Ayer, MA
Salem, MA
Boston, MA
Woburn, MA
Andover, MA
Lowell, MA
New York, NY
Boston, MA
Winchester, MA
Westford, MA
East Longmeadow, MA
Danvers, MA
Boston, MA
Cambridge, MA
Concord, MA
-------
The RIO Forum
Qlen J. Cohen
Sky Products Company
Peabody, MA
Fanet T. Cohen
>ky Products Company
Jary Conaty
jau Technologies
Peabody, MA
Acton, MA
toy B. Crane
jightolier
Wilmington, MA
:PF Incorporated
Jetty J. Diener
Environmental Business Council of New England
Ayer, MA
Boston, MA
lichard Doherty
lydro Environmental Technologies, Inc.
>avid Dub
>uncan Galvanizing
Acton, MA
Everett, MA
roltek, Div. of Sekisui America Corp.
"im Elsevier
Irving Paper Mills, Inc.
Lawrence, MA
IASCO
Cppstein
'rank V. Ferrara
'.wank, Inc.
ieverly Fischer
,lpha Industries
(ike Fiske
tunter, Inc.
ohn R. Frank
i. E. Mason Co.
•eborah Gallagher
[A DEP
Boston, MA
Attleboro, MA
Hyde Park, MA
Boston, MA
enetics Institute
'ony Gemmellaro
.Ipha Beta Technologies
Andover, MA
-------
The RIO Forum
Kristin Gentile
Voltek, Div. of Sekisui America Corp.
Doug Gillespie
Massachusetts Farm Bureau Federation, Inc.
Bob Gingras
Earth Tech
Louis Gitto
MA DEP
Sidney Goldstein
Lynn Plastics Corporation
Ralph Goodno
Merrimack River Watershed Assn.
Randall Goyette
Safety-Kleen Corp.
Wallace Hack
MA DEP
Janna Hadley
B. G. Wickberg Company, Inc.
Robert T. Hawes
Polaroid Corporation
George Hawkins
U.S. EPA, New England - RAA
Mark W. Haymes
Standard Uniform Services
Jack Healey
U.S. EPA, New England
Jody Hensley
Toxics Use Reduction Institute
Rick Hillman
D/E Corporation
Vernon C. Hipkiss
Pittsf ield WWTF
George Hrono
General Scanning, Inc.
Kira Jacobs
Lawrence, MA
Bedford, MA
Concord, MA
Boston, MA
Lynn , MA
Lawrence, MA
Marlboro, MA
Worcester, MA
North Quincy, MA
Waltham, MA
Boston, MA
Agawam, MA
Boston, MA
Lowell, MA
Leominster, MA
Pittsfield, NH
Watertown, MA
Amherst , NH
Environmental Science & Engineering
-------
The RIO Forum
Chris Jendras
U.S. EPA, New England
Carolyn Jenkins
NEIPWCC
Steve Jorjorian, Jr.
Advanced Plating
Barbara Kelley
MA OTA
Phil Kenney
Quincy Hospital
James Klecak
Americraft Carton Inc.
W. Ladroga
Neles-Jamesbury, Inc.
Susan Lanza
MA OTA
Bob Larsen
Larson Technologies
Cindy Lee
Safety-Kleen Corp.
Ira Leighton
U.S. EPA, New England - HEL-CAN6
Gregory Leonardos
Anat Lev
Maiden Mills Industries, Inc.
J. Alden Lincoln
Massimo Lombardo
ATC Diagnostics, Inc.
Steve Luz
Tweave Inc.
Frank Marino
Raytheon Company
Gina McCarthy
/
Wilmington, MA
Worcester, MA
Boston, MA
Quincy, MA
Lowell, MA
Worcester, MA
Boston, MA
Fremont, NH
Marlboro, MA
Boston, MA
Arlington, MA
Lawrence, MA
Boxford, MA
Framingham, MA
Norton, MA
Lexington, MA
Boston, MA
MA Executive Office of Enviornmental Affairs
-------
The RIO Forum
David F. McDermitt
Waste Management, Inc.
Dorothy McGlincy
New England Power Service Company
Hugh McLaughlin, PhD
Waste Min Incorporated
Kenneth W. Mi lender
Miller Engineering, Inc.
Jennifer Molin
Northeast EDM
Elaine Moore
Ogden Environmental
Jack Moriarty
Giltspur /Boston
Connie Morton
Maiden Mills Industries, Inc.
Tom Murphy
Pernix
John-Erik Nelson
Braintree Electric Light Dept.
Arieen O'Donnell
MA DEP
John P. O'Hare
Greater Lawrence Sanitary District
Gabriel Paci
Raffi and Swanson, Inc.
George Papadopoulos
U.S. EPA, New England
vince Perelli
NH DES
Peter A. Pignone
Micron Products, Inc.
Hugh Pilgrim
MA OTA
Robert Pond
Wakefield, MA
Westborough, MA
Groton, MA
Manchester, NH
Newburyport , MA
Westford, MA
Avon, MA
Lawrence, MA
Way land, MA
Braintree, MA
Boston, MA
North Andover, MA
Wilmington, MA
Boston, MA
Concord, NH
Fitchburg, MA
Boston, MA
South Attleboro, MA
-------
The RIO Forum
Rick Reibstein
MA OTA
Anne Reynolds
AT&T
Jeffery L. Rezin
D' Sullivan Corp.
Robert Rio
New England Power Company
Bill Roeder
Star Plating Company
Edmond N. Roux
Merrimac Paper Company, Inc.
Camille Sahely
C.G. Circuits, Inc.
Tod Schmikus
No. Central Mass. Chamber of Commerce
Robert J. Sculley
New Hampshire Motor Transport Assoc.
Stephen Sibinich
Wheelabrator Millbury Inc.
Leo Sicuranza
New England Electric
M. A. Sigal
Solutek Corporation
Chris Simmers
NH DES
Hal Smith
Rubic Properties
Gina Snyder
U.S. EPA, New England - RCA
David B. Spencer
wTe Corporation
Charles Storella
Dana-Farber Cancer Institute
Thomas A. Stuhlfire
Boston, MA
North Andover, MA
Winchester, VA
Salem, MA
New Bedford, MA
Lawrence, MA
Taunton, MA
Leominster, MA
Concord, NH
Millbury, MA
Westboro, MA
Boston, MA
Concord, NH
Danver, MA
Boston, MA
Bedford, MA
Boston, MA
Walpole, MA
NBS Associates
-------
The RIO Forum
Herbert Sturgis
Instron Corporation
Linda Swift
Corporate Environmental Engineering, Inc.
Canton, MA
Worcester, MA
Shepard Envelope Company
Worcester, MA
Kenneth A. Teal
NYNEX Information Resources Company
Karen Thomas
Toxics Use Reduction Institute
Middleton, MA
Lowell, MA
Richard Tuck
CPC Incorporated
Henry Veilleux
Business & Industry Association of NH
Winona Wall
Raytheon Company
Ralph Wilbur
Graphic Litho
Lee R. Wilmot
Hadco Corporation
Randolph, MA
Concord, NH
Bedford, MA
Lawrence, MA
Salem, NH
George Winton
Tau-tron
Westford, MA
-------
UlCUItVi CHHCi e(
jNVMONMiNUt AfMIM
Office of Technical Assistance
Executive Office of Environmental Affairs
Commonwealth of Massachusetts
ALCOHOL FREE FOUNTAIN SOLUTIONS
AT AMERICRAFT CARTON, INC.
Americraft Carton was using large quantities of isopropyl alcohol (IPA) in the fountain solution for the
offset printing presses used to print the paperboard cartons for its client's products — food, health and beauty
and children's products. Concern for the health and safety of its employees and the environmental concerns of
its clients required Americraft to change its process. Introduction of a $108,000 new fountain solution delivery
system has resulted in the elimination of IP A, cost savings that will yield full payback (in materials costs alone)
in less than two-and-one-half years, and a likely end to toxics use reporting.
BACKGROUND
Americraft Carton, Inc., in Lowell, Massachusetts, is a $30 million a year folding carton manufacturer and
printer. Health and safety issues and environmental concerns of Americraft clients—makers of health and beauty
products, children's toys and games, and food products — influenced Americraft's efforts to introduce less toxic
printing materials.
Until August 1991, Americraft mixed fountain solution for its presses in the traditional manner—a solution
of 15-25% isopropyl alcohol (IPA), tap water, and etch material was measured by hand into a drum and stirred
with a wooden paddle. Americraft received bulk deliveries of IPA every two to three weeks and up to six 55 gallon
drums of waste solution were generated monthly by the company's four sheetfed offset presses.
There are significant economic, health and safety, and environmental drawbacks to this method of
producing and using fountain solution. Inconsistency in the solution can cause press downtime; it increases labor
and material costs, and it can require disposal of inadequate, unused, or waste solution at a cost of more than $2
per gallon. Inhalation of alcohol-laden vapors present health and safety concerns for employees. And IPA, an
ozone producing volatile organic compound (VOC), increases the cost and complexity of air emission permitting
and reporting.
TUR PLANNING
Americraft Manufacturing Manager Jim Klecak knew that inconsistency in fountain solution formulation
as well as air emission concerns needed to be resolved. Jim moved quickly to research the available options and,
in April 1991, to purchase and install a Frisco Aquamix Central System at a cost of $ 108,000. News of the change
was initially received with some trepidation by management because of the expense. Now, because the system
has proven cost-effective and efficient, implementation of similar systems is underway at two other Americraft
plants, in Memphis, Tennessee, and St. Paul Minnesota. St. Paul utilizes a modified version of the mixing system
and is pleased with early results. In Memphis, "black-box" technology that irradiates the water forthe dampening
system, enables operation with plain water and fountain concentrate, completely eliminating IPA and its
100% post consumer recycled paper
-------
substitutes. In Lowell, when Jim began introducing no-IPA solution, he even had to prove to his pressmen that
high standard printing is possib.e without IPA - he locked the IPA storage area and installed a drum visible
through the storeroom window, labeled IPA but filled with water with a hose leading to the presses Ten days
later, Jim told the pressmen that the system was operating without IPA.
Amencraft installed the Prisco system and (because water quality could vary even from hour to hour)
reverse osmosis equipment to filter incoming water and automatically adjust pH andconductiv u,. These changes
made rt possible to use IPA substitutes, which are less tolerant to variations in water quality andparameters than
is IPA. The reverse osmosis filtration s^
a storage and distribution tank. Americraft first replaced IPA with Hi-Tech solution and Alkaless R, a fountain
concentrate with 20 percent monoglycol ether, a VOC. Release of VOCs was greatly reduced by using a closed
loop system, but introduction of the glycol ethers required reporting under SARA (Title III, section 313) and
TURA. Prisco Q-l 1, a new substitute introduced in April 1993, has nearly eliminated VOCs and will likelv end
the required reporting. '
ThePriscosystemisacIosedlooPrecyclingsystemconnectedtoaIlthepresses,whichcanreleasesolution
?P 7 JLS1 T ""I"*(8Pm)" RecharSin8 of the solution (made up of water obtained by reverse osmosis
IPA substitute, and used fountain solution) is computer-controlled to ensure that pH, temperature and
%%%?*% ^ PreCify maintained- From the P«**> *• ^iution goes to a return tank where it is chilled
and filtered to 25 microns (contaminants are ink, paper, dust, andpaperboard stock). The solution is then returned
to the mam system for filtermg to 10 microns and for farther chilling as well as solution recharging The chiller
is a holding tank with a 250 gallon capacity to ensure adequate quantities at all times.
RESULTS
_ . ««««,.«« used high volumes of IPA in the last fiill year before introduction of
ofO 11 fortheffi' Cnt °f IPA with Alkaless R. which contains 20 percent VOCs, and the substitution
concentrate Presulted in an 88
percent reduction in VOC emis-
sions from the operation.
Recirculation also eliminated
VOCs from the air in the plant
and the substitute had reduced
flammability as well (flashpoint
of 110 F versus 72). The system
ran for 11 months before spent
fountain solution required dis-
posal; waste solution was re-
duced 50 percent.
Installation of the Prisco
Supplies
Isopropyl (IPA)
Alkaless R
Fountain Solution,
Hi-Tech, Q-11
Total
Savings
8/90-7/91
'(old system)
$23,025
1,292
44,907
$69.224
8/91-7/92
(new system)
-0-
$5,816
23,188
29,004
$40,220
8/92-7/93
(Q-11, 8 months)
-0-
$17,146
10,986
28,132
$41,092
7/93 to 7/94*
(Q-11, full year)
-0-
$3,877
14,610
18,488
$50,736
NOTE: Total Materials Purchase Savings = $132,048 in three years. These calculations do not
include substantial additional savings estimated at about $35,000 per year from decreased
Aquamix Central System auto- [^^ *^£* Waste di^| c°s* fo'***fountain solution. ™<* fina"y.r>o, or substSy
matically and accurately mixes ^ as a result of ttie chemical substitutions and process changes.
fountain solution in a closed loop and has resulted in:
• The end of losses and costs associated with hand mixed solution
unacceptable solution that also sometimes caused press downtime;
™intinnRH?red 1°°^ ** ^ KmOVal ** "ltemal TQCyc{in& of the soluti™ and from converting from weekly
solution disposal and pan maintenance to an annual schedule, and
infof^
iH993ofPnSroQ.ii,whichcontainsOpercent VOCs will result in nearly complete elimination of VOCs.
the cost and disposal cost of
-------
Economics: Americraft invested $108,000 in the new equipment required to reduce the VOC emissions
from its offset printing operations. Payback resulting solely from the reduced cost for materials will occur about
30 months after introduction of the new system—there are substantial additional savings from increased press
efficiency, reduced wastes, and reduced and eliminated permit costs. Americraft has also found that alcohol
substitutes cause the need to maintain and/or replace rollers at a higher rate, but also require lower durometer
meaning they may last longer.
The cost of the alcohol replacement (Alkaless R) is 5 times greaterthan IPA; the cost of Q-11 is comparable
to that of the Hi Tech concentrate which it replaces. However, because of the improved efficiency of the mixing
system and the new chemistry, a reduction of about 75% in Alkaless R use is projected to occur this year
producing the savings (from materials costs alone) shown in the table above.
OTHER POLLUTION PREVENTION ACTIVITIES
Americraft has introduced other pollution prevention changes. Approximately 85 percent of its products
are made from recycledpaperboard. Printing on recycled board is technically more difficult, but the introduction
of a consistent fountain solution greatly facilitates printing on recycled material. Americraft also uses water-
based coatings, instead of UV-based coatings which may make paper non-recyclable; and Americraft recently
switched from petroleum-based ink to soy-based ink. Soy-based inks produce a higher quality print and result
in substantial further VOC reductions. Finally, Americraft is exploring ways in which to cleanse and recycle its
cloth filter bags to reduce its overall waste load and improve disposal methods of the filtered-out hazardous
material.
This Case Study is one of a series of such documents prepared by the Office of Technical Assistance for Toxics
Use Reduction (OTA), a branch of the Massachusetts Executive Office of Environmental Affairs whose mission
KtOMWtndwtryinreducingtheuseoftoxicchem^
01A s non-regulatory services are available at no charge to Massachusetts businesses and institutions that use
toxic chemicals. For further information about this or other case studies, or about OTA's technical services
contact: Office of Technical Assistance, ExecutiveOfficeoj'EnvironmentalAffairs, Suite2109,100Cambridge
Street, Boston, Massachusetts 02202, (617) 727-3260, Fax - (617) 727-3827. -cwi.4,
100% post consumer recycled paper
-------
Office of Technical Assistance
Executive Office of Environmental Affairs
Commonwealth of Massachusetts
jHVUONMiNUt AfMm
Toxics Use Reduction Case Study
WATER AND INK WASTE REDUCTION
AT EC. MEYER COMPANY
SUMMARY
F.C. Meyer Company, a Lawrence, Massachusetts cardboard box manufacturer and printer, has trained its employees
in "good housekeeping" practices and significantly reduced ink wastes and wastewater generated when cleaning the
printing presses. The improved washing practices include draining and scraping as much ink as possible before washing
and minimizing the amount of water used. Most of the ink wash water is now used to dilute concentrated virgin black ink.
The decrease in wash water and the reuse of ink wastewater have resulted in a 90 percent savings in waste disposal as well
as reduced costs for raw materials.
BACKGROUND
F.C. Meyer employs 200 people and has eight printing presses and operates three shifts a day, five days a week. The
company uses a flexographic printing process with rubber printing plates.
In 1989, F.C. Meyer switched from solvent-based inks to water-based inks, and reduced its VOC emissions from
280 tons per year to less than 1,000 pounds per year. Performance quality was unchanged and the regulatory workload was
reduced substantially. In 1992, F.C. Meyer began to seek further waste reduction opportunities and looked at the press
cleaning procedures. Presses must be cleaned every time the ink is changed. The bulk of the ink contained in the bins and
on other parts of the press is poured back into the ink container. The remaining ink was washed off with water-soaked rags
and the waste water was put in 55 gallon drums and, before the ink change, taken away by a hazardous waste contractor
at $ 100 per drum. Before implementation of the waste reduction program the company generated 10 drums of hazardous
waste a week, now it generates one to two drums a week of nonhazardous waste.
WASTE REDUCTION ACnVITIES
F.C. Meyer decided that reduction of the volume of water used in cleaning process could be achieved by training
workers to use the least amount of water possible. The new washing procedures include draining as much ink as possible
back into the containers and thorough scraping of excess ink off the press parts before any water is added, and then using
as little water as possible.
In addition to reducing the volume of wash water used, the company asked its supplier to deliver black ink with 10%
reduced water content. Wastewater is added to the black ink with no apparent effect on the color quality of the ink. The
wastewater can also be added to other colors, such as grey, in smaller amounts than when added to black ink.
RESULTS
Reductions Achieved: Modifying the press cleanup procedure reduced the solids in spent washwater from more
than 30 percent to 13 percent. The volume of water used also has decreased by 35 percent. Approximately one pint of water
is now used each time a press is washed.
By reusing most of the washwater, the amount of waste which had to be disposed has decreased from ten to one to
two 55-gallon drums per week.
Economics: The 55 gallon drums of waste cost approximately $100 each to dispose. Implementing the reuse of ink
wastewater has reduced the yearly cost of waste disposal from about $52,000 to $5,200.
This Case Study is one of a series of such documents prepared by the Office of Technical Assistance for Toxics Use
Reduction (OTA), a branch of the Massachusetts Executive Office of Environmental Affairs whose mission is to assist
industry in reducing the use of toxic chemicals and/or the generation of toxic manufacturing byproducts. OTA's non-
regulatory services are available at no charge to Massachusetts businesses and institutions that use toxic chemicals. For
Jurther information about this or other case studies, or about OTA's technical services, contact: Office of Technical
Assistance, Executive Office of Environmental Affairs, Suite 2109,100 Cambridge Street, Boston, Massachusetts
02202, (617) 727-3260, Fax - (617) 727-3827.
• C101-2, 8/93
100% post consumer recycled paper
-------
incunvi o»Hct oi
JXVUONMtNUi AfMI«S
Office of Technical Assistance
Executive Office of Environmental Affairs
Commonwealth of Massachusetts
Toxics Use Reduction Case Study
SEPTAGE RECEIVING FACILITY ELIMINATES ODORS
SUMMARY
The Greater Lawrence Sanitary District (GLSD) added an aeration system to its septage treatment tank and
eliminated the noxious odors that previously emanated during the treatment process. GLSD's payback on a
$77,000 investment came in less than four months and the facility can now accept septage up to the treatment
facility capacity of 100,000 gallons per day. The odorproblem prevented acceptance of more than 40,000 gallons
per day, even when large quantities of odor controlling chemicals were added.
BACKGROUND
The Greater Lawrence Sanitary District (GLSD) is a 52 million gallon per day, activated sludge wastewater
treatment plant that serves approximately 168,000 sewered residents. In addition to piped wastes from homes
and businesses, the GLSD provides septage disposal for communities throughout the Merrimack Valley and
southern New Hampshire. GLSD Process Control Engineer Richard Fuller found from operating experience that
if the septage receiving facility exceeded 40,000 gallons per day (gpd), especially during warm weather months
unacceptable odors escaped into the surrounding community. The odor control chemical, potassium permanga-
nate, for which GSLD was spending $2,000 a month, was effective up to a volume of 40,000 gpd. With a
Department of Environmental Protection approved septage receiving capability of 100,000 gp'd, the GLSD was
losmg up to $2,700 a day in septage revenue by observing its self-imposed limit.
TOXICS USE REDUCTION PLANNING
Wastewater treatment plants typically use mechanical stirrers or bubble difrusers to bubble air or oxygen
through the liquid waste as part of the treatment process, and this aggravates the release of hydrogen sulfide (H S)
principal cause of the noxious odors. The use of oxidation chemicals such as potassium permanganate and
hydrogen peroxide can successfully control odors, but only for limited quantities of waste In addition to the
added cost, these chemicals also pose risk of fires and explosions. Concentrated solutions of hydrogen peroxide
are also highly toxic and a strong irritant.
Economics dictated that GSLD find a way to treat daily septage volumes up to 100,000 gallons without
incurring increased chemical costs or generating excessive odors. Early in 1992, OTA recommended that GLSD
contact Gary Smith and Dr. James Maskasky of Venturi Aeration. In April 1992, GLSD conducted a pilot test
usmgaVentimHyaro-Vac^whichclearlydemonstratedtheimit'sabilitytooxygenatethesep^^
H2Sreleasepnortodischargetothetreatmem
septage continued as the septage moved through and over the primary clarifiers, where the atmospheric release
of H2S gas would have occured.
The GLSD was the first wastewater treatment plant in the country to install a Hydro-Vac as a means of
oxygenating and conditioning septage. On July 6,1992, the GLSD put into operation three Model A-500 Hydro-
100% post consumer recycled paper
-------
Vac,'s connected to two Model T4A3-B Gorman-Rupp, 25HP, self-priming, centrifugal pumps capable of
pumping 500 gpm each. GLSD personnel installed the system, which including all parts and labor, cost $77,000.
The Hydro-Vac. Wastewater Conditioner, a patented apparatus designed to inject atmospheric oxygen into
any liquid, works by pumping wastewater or septage through a high velocity nozzle into a low velocity mixing
chamber where the material is mixed with aspirated air and the solids reduced to macroscopic size releasing the
embedded grease and gas bubbles trapped within the organic solids. When enough oxygen is introduced too a
liquid to combine with all of the available hydrogen ions produced by the anaerobic digestive process no
hydrogen will be available to form H2S.
RESULTS
Reductions Achieved: Since installation of the Hydro-Vac^ GLSD has been able to increase its septage
receiving volume beyond 40,000 gpd without creating offensive odors. The operation of the Hydro-Vac
equipment has also eliminated the need for chemical conditioning to reduce the H2S odors In addition with
septage pumping capacity increased from 100 to 500 gpm, all septage receiving can be accomplished on the day
September ^^^ a"d laboratory Pe*onnel are available to handle and test the incoming septage. By
after 15 months of
operation, GLSD
had experienced no
mechanical orpro-
cess problems with
the new method of
handling septage.
Economics: The
original capital in-
vestment of $77,-
000 was paid back
by October 1992
(see table), less
than four months
after the installa-
tion was com-
pleted, because of the increased volume of septage received and the $2,000 per month savings on potassmrn
permanganate usage/The figures in parenthesis in the "Month" column of the table are the number of days h™
septage was received; the facility is open Monday through Friday. The "Monthly Capital Cost Remaming"
column shows that by December 1992, based on septage volumes greater than 40,000 gpd the GLSD
mcreased their septage revenue by $57,985 based on a charge of $0.045 per gallon of sepSge received
Hydro-Vac Installation Payback
Month Average Daily Septage Monthly Monthly Monthly
(1992) Septage in Excess of Revenue from Chemical Capital Cost
Jul (23)
Aug(21)
Sep(21)
Oct(21)
Nov (20)
Dec (22)
(gpd) 40,000 gpd Excess Septage Savings Remaining
57,467
56,552
66,188
70,669
66,598
51,714
17,467
16,552
26,188
30,669
26,598
11,714
$18,078
$15,642
$24,748
$28,982
$23,938
$11,597
$2,000
$2,000
$2,000
$2,000
$2,000
$2,000
($56,922)
($39,280)
($12,532)
+$18,450
+$44,388
+$57,985
the Office of Technical Assistance for Toxics Use
tednn 7 fl Tf t i****" PreP"-** by the Office of Technical Assistance for To
Reductton (OTA) a branch of the Massachusetts Executive Office of Environmental Affairs whose mission .asss
tndusvy ,n reducing the use of toxic chemicals and/or the generation of toxic manuring byprO~OTA™on
^^
^^^
-0101-4,10/93
-------
THE BOSTON GLOBE • MONDAY. MAY 9. 1994
An order of chips and orange juice
By Usha Lee MeFariing
COKTRIBLTISC REPORTER
NORTH ANDOVER - Here in
the wide, white aisles of AT&T's vast
microelectronics plant, robotic arms
stamp tiny resistoi-s. capacitors and
computer chips onto circuit boards.
Upstairs, machines sandwich layers
of conductors and wisps of insulation
onto thumbnail-sized computer mod-
ules.
On the high-tech assembly line,
technician Gregory P. Tashjian
opens a rinse tank for freshly built
circuit boards. The smell that wafts
out is decidedly out of place: the
scent is of oranges.
A new menu has found its way
into AT&T's Merrimack Valley
Works. Orange rinds, grapefruit
peels and cantaloupe flesh offer en-
gineers a natural alternative to sol-
vents, long used to make computer
chips, that were found to be destroy-
ing the ozone layer.
Once circuit boards are finished,
some must be rinsed to remove resi-
due. The insulation placed between
layers of conductors on stacked mod-
ules also must be rinsed away. For
years AT&T, like the rest of the in-
dustry, used solvents made of chlor-
ofluorocarbons, or CFCs, and chlor-
obydrocarbons, or CHCs.
"CFCs are excellent solvents be-
cause they evaporate,* said Tashjian.
"Hie problem is they evaporate into
the atmosphere and destroy the
ozone layer." This thin layer of mole-
cules of a form of oxygen, high in the
stratosphere, shields the Earth from
the most harmful of the sun's ultra-
violet rays.
In the United States the produc-
tion of CFCs will be phased out by
1996. But since the first day of 1993,
two years ahead of its own schedule,
AT&T has been quietly manufactur-
ing computer and communications
systems components without ozone-
depleting chemicals.
"In 1988, I would not have ex-
pected that we, or industry in gener-
al, could have gotten where we are
now," said A, F. Lazzaretti, the engi-
neer In charge of the plant's environ-
mental programs. "A lot of thinking
has changed since the 70s and early
80s."
AT&T's work has garnered the
applause of environmentalists. ul
don't think there's any way to be too
quick about getting rid of ozone-de-
pleting chemicals," said Rob Sargent
of the Massachusetts Public Interest
Research Group.
One new solvent is' a natural
chemical distilled from discarded or-
ange and grapefruit rinds. Another
is a chemical that is found naturally
in cantaloupes and grapes but is
cheaper to create synthetically,
which is also used as a flavoring for
soda and gum. Both are shipped to
AT&T by the barrel for use in rins-
ing machinery.
AT&T invested $25 million to rid
its operations of ozone-destroying
chemicals. The investment is paying
oft Because the fruit-derived sol-
vents do not evaporate quickly and
can be re-used, less are required:
Just 50 gallons a month are needed
for one process that used to require
400 gallons a week of ozone-deplet-
ing chemicals.
"And most of that would go up
the stack into the environment," said
Aaron Frank, the engineer who
oversaw the conversion that has
played a large role in AT&Ts dra-
matic reduction in total chemical
emissions.
Since 1987, the North Andover
plant has reduced emissions of ozone
depleting chemicals from 750 tons to
zero. Company-wide, AT&T has re-
duced the use of such chemicals by
75 percent Solvents account for 22
percent of the CFCs used nation-
wide.
Because the solvent is nontoxic
and biodegradable, small amounts
that escape into rinse water can be
treated in the plant's on-site
wastewater treatment system.
"I like the company," said state
Environmental Affairs Secretary
Trudy Coxe, "because they have
really been leaders in practing what
we preach - pollution prevention."
Coxe, who visited the AT&T1
plant on Earth Day, also -poised
AT&Ts other environmental p^o-
grams, which include requirmg* £11
suppliers to stop using packaging
made using CFCs and spending $£3
million to replace reflectors abota
fluorescent lamps, doubling the oiit-
put of a single light tube.
Recognizing that planning afid
developing cleaner technologies mfcy
be difficult for smaller companies,
AT&T has put aside competitive in-
terests in this case. "We're \vffling
-------
United States Patent
Guess
US005122279 A
[ii] Patent Number:
[45] Date of Patent:
5,122,279
Jun. 16, 1992
[54] FERROUS DITHIONTTE PROCESS AND
COMPOSITIONS FOR REMOVING
DISSOLVED HEAVY METALS FROM
WATER
[75] Inventor: Robert C. feata, Beverly, Mass.
[73] Aitignee:
Beverlv
^ Beverly,
3.216.790 11/1963
3.216,185 12/1965
3.770,630 11/1973
4.076,793 2/1978
4,137,910 4/1979
4.S99.177 7/19*6
4,691.162 1Q/I9S7
US9>447
Murib ................................. 423/513
Cyan ei al ..................... 423/515
Kimpernun ....................... 210/719
Tieihof ....................... 423/515
Titthof ............................... 423/515
Hiyathi et •) ................ 210/719
Cuilteult et *1 .................... 210/912
423/3|J
F211 ADD!NO-«JI» Primary Exomi*«^«/ EMm/wr-Neil M. McCtnhy
[22] Filed: Apr. S, 1991 Attorney. Agent, or tfmi—Paul J. Cook
[51] 1«.CI.' ............................ C02F l/i2{ C02F 1/70 I57] ABSTRACT
UA2 W/724' •' 2io/75r iib/PlZ-^ClM.2^?1 Mcavy meul ^^ "^ wilh ferrou» «J«hionne in acidic
75/723 ^W^A^M^ ^2/1 •?oeo*u-
llfl/wTrtt, ; «2 ' 423/]?5^75>? 4 ?» 72?' ^ ^J** ^ W*lCf Wh" chel'"n« ^ent> "e
72S 726 739 740 74J 252/188 22 P~»' lh*y "' dtteuv««» b> ^^'ng to the ferrous
' ' W> 74°* 741' 252/1M-22 wni. Ferrou. dithkmite, (FeS2O4) is either generated
Rtftrtaeai ClcW m-*iu> or ferrous ions and dithionite ions can be pro-
U.S. PATENT DOCUMENTS ^^ by olhcr melhods
1,479.542 1/1924 Hinchkind ........................... . 73/739 23 Ckiaa, No
-------
5,122,279
___^
FERROUS DITHION1TE PROCESS AND
COMPOSITIONS FOR REMOVING DISSOLVED
HEAVY METALS FROM WATER
BACKGROUND OF THE INVENTION
This invention relates to a process for effectively and
completely removing heavy meuh from aqueous solu-
lions with hydrosulfitc and iron. The present invention
lolutions ire very corrosive on ferrous alloys, particu-
larly on stainless steel materials
U.S Pat. No. 3.634.071 describes ihe use of sulfur
dioxide for reducing ferric ions contained in recircu-
lated ore leaching acid solutions. Some improvements
in the cementation of copper using metallic iron were
observed as relating to decreased oxidation of the iron
Md coPP«r meuls bv ferric ion*. No reference is made
ons w yrosutc an ron. e present nventon * dllh»0l»lc At lhe hl«h *«lfunc acid concentrations
is useful for treating metal ion containing waste waters 10 n™l "Js very unhkely lh*1 dithionnc ion could exist.
generated by industries such as metal plating, metal ^* Plleilt APP)'c«ion GB 125828 A. filed Jun. 16.
surface finishing or printed circuit manufacturing 19H d**10** • process for removing copper ion from
Prior to the present invention, methods for producing *°luuon by contacting Ine «>»««>« with steel wool
ferrous dithionite (iron hydrosulfite) have been ex- under COMT°ntd PH conditions. The copper cements
plored as a possible new way to make sodium hydrosul- 1S over lle Sta1*ec of the fued ^ of "cel WO01' conve«
fite Sodium hydrosulfite is manufactured by several
methods and several hundred million pounds are used
worldwide each year. It is mainly used for. 1) bleaching
woodpulp for newsprint. 2) reducing textile vat dyes, ,
and 3) reductive Icachmg of ferric oxide from kaolin 2
clays. All these major uses for hydrosulflte are for whit-
ening or enhancing the color stability of materials to
which it is applied. Most iron compounds are black or
dark colored thus discouraging the use of iron hydro. „
sulfue for any of these major applications of sodium *
hydrosulflte
U.S. Pat. No. 4.076,791 discloses improvements in
making iron hydrosulfitc and converting it to sod urn
hydrosulfite. More than 90% of the iron must be re- ™
moved and replaced by sodium in order to u^ the rl *
suiting solution for leachmg kaolin. A Urge^lume of
iron precipitate is produced which absorbs and wastes a
.
IT l?rdcvelop i[on;h€™«fy » con.
,fy, H t W"e !btnd°l!ed. ^.
?$ ^n »° $Ub,!l1Zc J^LUm
nc* Ptlem !T S!?29?97.1 a *°
d to decolorize
A rn B?]llMt Rcd
Adding some ferrous sulf.te to the
dithionue solution improve* the subility of the deco)-
n
mg ***** Imdl P°niOn of the Iron imo ^PP"' Thi$
P"**".*8 commercially undesirable due to 1) the un-
•«»"?n>«Uy low conversion of iron to copper, and 2)
•!«•>»«•« of ated WOoUand 3) the high l.bor cost for
the material. The recovered copper has a
recycling value due to the cost of processing
[£utred for ^P*™"1* « from to u* • «ron« chcmiwl «^
break$ lhc chc|ftnt. Io.hea mcu, ^ gnd fonm
«uble' insoluble compound or complex of the toxic
m^ht or 2) lo ^ .Tubsunce that exens a stronger
actriclion for lhe cnelam thjin doe$ lhe toxic meltl ^
ored wisiewaier sol ut.on There is no mention of any 43 to free the heavy meul 10 precipitate as an insoluble
interaction or involvement by heavy metals existing in hydroxide. Processes of both types are currently prac-
this pnor work relating ferrous ion to dithionite ion. ticed
Metallic iron has Jong been known to react directly Sodium sulfide is used to effectively precipitate
with certain other meuls that we dissolved in acidic heavy metals, hs sole advantage u the extremely low
aqueous solutions, The iron dissolves into the acidic » solubility of most heavy metal sulfides. Most are capa-
solution and the other dissolved metal deposit, a metal- We of existing in the presence of even the strongest
he layer on the surface of the iron. Referred to as metal- chelating agents. Undesirable aspects of using a sulfide
lie replacement or cementation, this characteristic of process include the extreme toxicity of hydrogen sulfide
metals has commonly been used in the commercial ex- g*,, which can be generated by contacting the sulfidn
traction of copper from ores and acid leaching of mine 55 with strong acids. Also, metaJ sulfide precipitates are
tailings. After some time, the surface of the iron is so Uimy and difficult to filter. Large quantities of floccu-
covered with the other metal that the iron becomes lants and filter aids are used, generating large volumes
Unf f?"VC ** **£•? IT y~ u. , <>f H^I* ««d corresponding high disposal costs.
U.S. Pat. No. 3,902,896 addresses this limitation and Sodium borohydride is a strong, water soluble reduc-
discloses the use of a soluble thiosulfate compound to 60 ing agent that has an advantage of producing a compact
aid the cementation of such metals as copper, silver, seai-metallic sludge. There are several reasons for its
gold, and platinum group metals from aqueous solu: not having broad acceptance for heavy metal removal
tions. The patent discloses that the cemented metal in waste-water treatment: 1) it is very expensive. 2)
Hake* ofT the ba&e meul. exposing fresh surfaces. Two precipitated meuh easily reoxidiie and redissolvc in the
properties of thiosulfate limit its utility for this purpose. 65 presence of dissolved ammonia. 3) dangerous concen-
In strong acid solutions, thiosulfate decomposes to sul- (ration* of potentially explosive hydrogen gas can accu-
fur dioxide and elemental sulfur, which is colloidal and mulate in the space above a reaction using sodium boro-
coats all surfaces it contacts. Also, dilute thiosulfste hydride, and 4) at times when pH is not controlled
-------
5,122,279
lo *•«*•*»• Commercial product* arc available a.
either a 1 J-14* buffered solution or as 85-95% pow-
der . However, sodium hydrosulf.te solutions are quite
unstable and have a very short shelf life. Storage tanks
need to be refrigerated and inert gas blanketed The
powdered products have an acrid odor and a dust that
i, extremely irritating to a worker's eyes and nose
Damp or wet powder can spontaneously ignite into
fltm"' crettil* • toxic mo^f wlfur ***** T»~
objectionable properties have prevented sodium hydro-
tuJfUe products from gaining any major share of usage
for heavy ^ ^^ Of»for ^Jevuen treatment
la general
It would be highly desirable to provide a simple,
A
give off toxic fumes of hydrogen sulftde gas,
dangerous to workers and sensitive equipment.
HI yfN*T " ? str?n« J**""11* chemicd capa-
bleofbreakmgametalionbondtochelams.Itisusedio
a limited extent for heavy metal removal, but like boro-
hydnde. lacks widespread acceptance. Partly because it
too » very expensive to use, and it too can generate
£2!^ £!££ hy?roien *", wh!? ?*?*•
™.t!^ ^L " P 5.,' I*' ffchemkal»
suspected of being carcinogenic. This has been a major
impedmtent to ,ts u>d«s«rul uae.
Several compounds have been uaed that form insolu.
ble meul complexes with heavy metal ions. All exert a e a smpe,
stronger attraction to the metaJ ion than the cbelants 13 non-haxardou. process for removing heavy meuls from
normally occurring with the metals in the wastewaters. aqueous solutions that would
IS!1^^ TT U °°e "? h ^^'"P0"- » ™ non-hazardous materials in a safe and simple
edly effects at complete removal of disaolved metal method that does not give off foul odors or toxic or
from the water Its drawback u tts generation of huge explosive gues or irriuting dust, and,
«^.!L 8C> WlUCh reUi!tt r W? WWCT "!nlcnl * 2) >ebtvt vefy *» level« " '«dual toxic heavy metal
and costs the user a severe penalty for disposing of same ions resulting in environmentally compliant wastewa-
as a hazardous waste. ter for discharge to the sewer, and.
«£!?.- *i? C0fn.pl"in« •*«" hts ^"^ widc- 3> «»«i« hazardous waste sludges requiring regu-
spread use. Known m the water treatment trade as l.ted transport and expensive disposal, and.
D.T.C., or as dimethyldithiocarbamate, it is fairly eflec- 23 4) produce dense, fast settling or easily filterable solids
^LC°S± y ^ TV?g lhC **Vy mCUl i0ni from Whh ^ meul concentration. suJble for
solution. However. D.T.C. is quite expensive and gen-
erates quite high volumes of sludges which are unusable
for current recycling methods. The precipitate is light
in density and difficuluo gravity settle, and it also gives 30
off a foul smelling odor.
The conventional wastewater treatment process, per-
haps most frequently used by the largest number of
industries, uses ferrous sulfate heptahydrate powder, prnce o
Ferrous ion is substituted at a controlled acidic PH of 35 ferrous ions. When a chelating agent is present in the
° IK if ^ l°*iC b£7 "if i01!! tkat "e iddic water' lhe ferrous ion* bind "> the ^^ com-
X C f *,fCm$. I?" uIOW$ hMVy P0"^ rePlacin* lhe h«v> metal ions previously
rendered insoluble as hydroxides which bonded, in the presence of dithionite ions. The reducible
are precipitated from an alkaline solution. heavy metals form metallic panicles that are suitable for
in the presence of strong chelants or free ammonia 40 economical recycling and reuse. The heavy metallic
dissolved m alkaline solutions, a large exccu of this panicles are recovered by gravity settling or filtering
source of ferrous ion is required. Normally, 5 to 10 from the acidic solution
ferrous ions are added for each copper ion being re- In one embodiment of this invention, the pH of the
moved from chelated wastewaters. In heavily chelated resulting solution can be raised to between 9 and 9 5 to
streams, « many as 25 to 30 ferrous ions per heavy 43 precipitate the remaining quantity of unbound ferrous
mettl ion may be required in order to prevent the che- ions and other unreducible heavy metals as insoluble
lants from dissolving the heavy metal hydroxide. The hydroxides
commercial ferrous sulfatehas seven waters of hydra- Ferrous dithionite is preferably generated in-situ by a
tion and is only about 20% iron by weight. In some reaction between metallic iron plnicles and bisulfite
over 100 pounds of ferrous sulfate powder is 50 ions in the acidic heavy metal solution. The sane result.
0r h P°und of C5!'^ « hi composition and beneficid effect, ci KM
Id-rating 60 to 80 by several routes or alternative materials. Adding both
, joiubie dithionite compound and a soluble ferrous
and reuse of the meuls
SUMMARY OF THE INVENTION
In accordance with the present invention, ferrous
dithionite is reacted with heavy metal ions in acidic
water in a novel process which requires and uses both
ferrous and dithionite ions. The dithionite ions reduce
the heavy metal ions to zero valence in the presence of
ferrous sulfate u dissolved into wastewater. it causes
acidity in the water. Each mok of iron introduced this
Such other sources of ditbJOBJte and
include, for example,
r
the iron and form ferrous hydroxide. There.
fore when large exoas amount, of ferrous sulfate hep-
' « SS f? " f0f
Higher hazardous waste
dissolved heavy metal ion. « an acidic
tion, dithionite and ferrous ions are equally
P^*'^ k-vy — * Aether generated
each is added to the reaction from
n
IM
" LWf0ftS' WVer *°luble Wdue-
cd , ^^ ™eUl T *? *ro V"
lance and produce a metallic precipitate that u resistant
bv lhi« inv«^« which i. reactive
T° produce ferrou» dithion«c ««d^ «c*d»c condition,.
Toe composition comprises a dense slurry of iron pani.
-------
5,122,279
clcs, hydrated crystals or an alkali meu) sulfitc and a
saturated alkaline aqueous solution of the alkali metal
sulfuc having a pH in the range of about 9 to 12. The
proportions of the iron particles, alkali metal sulfite and
alkaline water used to make up this composition are
such that 0. 1 or more moles of sulfite are present with
each mole of iron, and enough water is added to pro-
duce a pumpable fluid slurry. If less than sufficient
water is added, the mixture becomes solid. If too much
heavy metal recovery since it is difficuh 10 separate the
hydroxide from the precipitated heavy metal.
Metal ions generally have a more positive oxidation
potential when bonded to a chelate complex Upon
being dissociated from the chclant complexes by the
ferrous ion. the heavy metal ions have a more negative
oxidation potential and are therefore more reactive with
and more readily reduced by the dithionite ion. This
mutual and beneficial interaction between the ferrous
chelating agents are present.
The present invention permits the use of a reactor
vessel of suitable design which allows unreacted iron
water is added, then too much of the alkali metal sulfite 10 ion, the cheiated heavy meu) ion, and the dithionite ion
is dissolved in the liquid phase and the iron panicles will it important and useful in the present invention when
separate and settle on the bottom of the container. The
preferred volume of saturated solution of dissolved
alkali metal sulfite is having the liquid phase just suff>-
cient in volume to submerge the solids contained in the 1J particles to settle from the outflowing liquid and to be
slurry- returned to the agitating zone. The finely divided heavy
DESCRIPTION OF SPECIFIC EMBODIMENTS meul PtrticlCT Pr<*Juc«d in, lhe r^cuon are camcd
along with the outflowing liquid. By gravity settling
In accordance with the method of this invention, lni» stream, a thick slurry of the heavy meuls can be
ferrous dithionite is utilised to precipitate heavy metals 20 recovered. Filtering this slurry and drying the rccov-
from aqueous solutions. In a preferred method, iron erej ioljd$ produces i concentrated, highly metallic
particles and a bisulfite compound or suitable bisulfite
precurser are admixed with a slightly acidic aqueous
solution containing dissolved heavy metal ions. The
forni of malerial, suitable for recycling and reuse of the
metals.
The slightly acidic liquid obtained after removal of
metallic iron reacts with the bisulfite ions, producing 25 iron ^ heavy roeul pftrticles can be neutralized using
ferrous dithionite in the presence of the heavy metal . cauiiic compound to a pH in the range of 9 to 12. This
ions and in accordance with Equation I. precipitates the insoluble hydroxides of all remaining
• dissolved and unreduced heavy metals. The excess dis-
r •
F.
Under the slightly acidic condition provided, the * ^es with the other metals as ferrous hydroxide. While
dithionite ions react instantly with and reduce the heavy *" rec°very steP » * »dvantageou5. it ,s not essen-
metal ions present to zero valence metallic particles.
The dithionite ions are thus oxidized and become regen-
crated as reactive bisulfite ions, as shown by Equation 2. 35
U*i!° the PfOcess °f lh's inven!KLn . A ,
. re*cl'.on? ™ 8nown b> E<'uatlon 4 and
uon
43
(E<)u»(ion 2)
^
Therefore as shown by Equations 1 and 2 wherein
HM is a heavy metal, this reaction is self regenerating in
the bisulfite ion when the reactions are performed si-
multaneously and in-aiiu. This method provides a very
efficient utilization of the bisulfite ion or its suitable
precursor. The bisulfite^ithionite redox cycle pro-
motes the indirect reducing reaction between the metal-
lie iron and the heavy metal ions.
When chelating agents are present in the aqueous
solutions being treated the ferrous ions produced in
Equation 1 also arc beneficially utilized by bonding to
chelating agents [CA-] which were previously bound »
to heavy metal ions. This reaction is defined by Equi-
tion 3 as foUows.
(Eqiution 3) 55
The reaction defined by Equations 1, 2, and 3 are
effected at a pH between about 1 and ?, preferably
between about 3 and 6. A practical trade off between
faster reactions at lower pH values versus more efficient 60
use of reacunts at higher pH values is required which
may result in varying choices from solution to solution
being treated. The upper pH limit may also be governed
by the tendency to form insoluble metal hydroxides at
pH values approaching neutral between 5 and 7. The 65
higher the concentration of dissolved metals, the lower
the pH at which the insoluble hydroxides begin appear-
ing. It is desirable to avoid hydroxide formation prior to
- —F0(Otni
(£,-«/«« 4)
(£f «*•** Wlthrlh« Proces$ °[ lhls «veniion,
ferrou$ d«h'«>«"«» u»»'«d to reduce heavy meul »ons
toL meullic Pfnjcl« of "ld heavy meuls" ** l** lcnn
"h"Vy melal'1 a USe? h!r*in: " "J8*"1 ',meUl hJVing:
!) M Jton»5 /WCI*ht he*vier lh-n c*lcium« lhat *
I«-«ier lhan 40.08, and
2> lls compounds exhibit biological toxicity when
released into the environment.
Representative heavy metals include copper, nickel.
lin> lead' c**™""1' nwcury. chromium, zinc, manga-
"*• ^ver' «old- Ptoti"iun, palladium, and mixtures
thereof. .
As set forth herein, one precursor raw material
source of ferrous dithionite hereunder comprises the
novel composition of this invention reacting at an acidic
pH. However, it is to be understood that the process of
this invention using ferrous dithionite for removing
heavy metals from water can be utilized regardless of
the source or form of the ferrous dithionite, or bisulfite
used to react with the metallic iron particles, and re-
gardleu of the source or form of the metallic iron pani-
cles used.
For example, a solution of acidic sodium or potassium
bisulfite can be made up by dissolving in water to a
desired concentration, sodium or potassium metabisul-
fite. Likewise, sodium hydroxide or potassium hydrox-
ide solutions could be treated with liquid or gaseous
sulfur dioxide to produce a usable solution of alkali
metal bisulfite. Any or all of these ingredients can be
-------
5,122,279
' 8
added separately or in combination directly into the ntte, the reaction pH should be controlled within a
DCftVy fnClAI COflteUIUflfl AflilCOftU flOiUtlOffi tntn iayVtr*ti tK* ••••MA j*f ^W^*.* i *«. ^ ^ « • * k *. .
^^^^^^ ^^*****••* •**•*• *«wn miij wfuwn inc (Ulflc OI ftOOUt 1 tO V Drcicrftulv fetfftav«*^n ahrmt \ AnH A
"**/« ^'.k011 " d.l!Stly ?*** .« v, °"e P^'cu^^y preferable method of this invention
•u.« ^? "** \ !^?M dilh.lonlle iolutlon con* comprises feeding an excess of iron particles into a vig.
sists of ferrous ions and dithionite ions, each provided 5 orously agitated reactor. A slurry density of suspended
by separate means. The dithionite ions can be provided metallic iron as high as 100 grams per liter or higher can
from sodium hydroaulfite and the ferrous ions can be be produced to provide expansive reactive surface area
provided from ferrous sulfate. When both such materi- to the solution, and increasing the rates at which the
. Jfreu*dded- eith«p combined or separately, to an iron dissolving reactions occur. The bisulfite reagent or
acidic heavy metal solution, the desired results of the 10 suitable precursor is fed at a fixed ratio to the quantity
process of this invention occurs. of dissolved heavy metal contained in the feeding aque-
Similarly, when bisulfite tons are exposed to the re- ous solution. As either the flow or the concentration of
ducing influence of sodium borohydride under certain dissolved heavy metals may increase or decrease, the
conditions, dithionite ions are produced. When such feed rate of bisulfite component is varied proportion-
dithionite ions are admixed with ferrous ions from any " ately.
source and then such materials as result are admixed The process of this invention produces only a small
with heavy metal ions in acidic aqueous solution, the fraction of the amount of metal hydroxide, hazardous
process of this invention is obtained. waste sludge as compared to existing wastewater treat-
Alternately, when metallic tine is contacted with an mem technologies, particularly when compared against
aqueous solution containing dissolved bisulfite ions, » the conventional method for using ferrous sulfate,
such as occurs when sulfur dioxide is dissolved in water, which requires dissolving up to 25 times as much iron as
dithionite ions are produced. When such dithionite ions does this process. Conventional prior an methods of
are produced in the presence of heavy metal ions and either sealing or filtering or both are usable for remov-
ferrous ions in aqueous solution or added into such a ing the metal hydroxide sludge from the final wastewa-
solution containing both heavy metal and ferrous ions, 25 ter effluent produced by the process of this invention
the process of this invention is obtained. The following examples illustrate the present inven-
A novel reactant composition is provided by this «°" and are not intended to limit the same.
invention which is reactive to produce ferrous dithio- Four experiments were performed with spent electro-
nite under acidic conditions. The composition com- less copper bath having an initial pH of 9.2 (Examples 1
prises a dense slurry of iron panicles, hydrated crystal* w through 4), but then acidified to a pH of 4.0 with con-
of an alkali metal sulfite and a saturated alkaline aqueous centrated sulfuric acid and diluted with water to a final
solution of the alkali metal sulfite having a pH in the copper concentration of 100 Mg/L. In each tot. 1.00
range of about 9 to 12 as controlled by added alkali gram of grade 0 steel wool was insened into a 4.0 cm
meul hydroxides. length section of glass tubing with an inside diameter of
The proportions of the iron particles, alkali metal 35 1.0 cm, creating a fixed bed with a volume of 3.1416 cc.
sulfite and alkaline water used to make up this compost- An adjustable flow micro-metering pump was used to
tion are such that more than about 0.1 moles of sulfite feed exactly 10 liters of the prepared copper solution
are present with each mole of iron, and enough water is through the bed of steel wool at a flow of 2X mis per
added to produce a pumpable fluid slurry. If less than hour °ver a 50 hour period.
sufficient water is added, the mixture forms a hard solid. *0 Five other experiments were performed using atom-
If too much water is added, then more of the alkali «ed iron powder having panicle sizes in the nominal
metal sulfite is dissolved in the liquid phase and the iron «»ge between -100 mesh and + 300 mesh, and having
panicles will settle and pack in a layer on the bottom of * purity of greater than 99 percent iron,(Examples 5
the container. The preferred volume of saturated solu- through 9). A copper solution was made up from sev-
tion of dissolved alkali meul sulfite is having the liquid *' era! source solutions obtained from printed circuit pro-
phaae just sufficient in volume to cover the solids. cesses. This test solution contained portions of ammoni-
Whilc the size of the iron panicles is not critical to the «c*l eicham bath, cupric chloride etchant bath, electro-
present invention, it is desirable to use panicles of a size *«* copper plating bath, sulfuric acid-hydrogen perox-
between about -50 mesh and 4-300 mesh, preferably «*e etching bath, sodium penulfate etching bath, and
between about -100 mesh and +200 mesh Generally, » copper sulfate electroplating bath in the approximate
A A*10 r*tl° of iulfite to ""on is between about 0.1 and proportions to approximate typical waste and dispoaed
10.0. and preferably between about 0.5 and 4.0 for each of into a plant wastewater system. The final mixed aolu*
mole of iron. tion was diluted to 200 Mg/L copper and adjusted to
When this composition is added to an adequate vol- pH 3.
ume of sufficiently acidic water, bisulfite km is formed 35 The Anal example given comprises a test using the
from the sulfite ion by Equation 6; composition of this invention in a demonstration of one
method of this invention.
*)
EXAMPLE I
a^f«rTowdithkmiteian^theT«froffltotubitajiiially CO In the fint teat, the feed solution
""* *•• trtiCtot to •
wool with no
was
m^i«ti. i* u _ (wW^tW^lfite). The outflowing liquid was collected
metal in the su Ate is either sodium or and accumulated in a 5 gallon container. Over the per-
potaatium. a nominal exceasof sulfite can be desirable to iod of the test, some removal of copper was vuually
achieve optimum results. The optimum pH of a final « evident, a. the appearance of the enUrTstee) wo^ntai
reacuon mixture w, II depend upon the intended use for gradually turned ^nTshiny steel color 7eo£eV£T
£! J^. dlthl°°lte " •««"*• Wh« a-*"* ored fiber* At the end of thi te*. the cop,*rco^enTof
heavy metals are present to be reduced by the dithio. the 10 liters of collected effluent liquidTas tested by
-------
5,122,279
Atomic absorption (AA) spectrophotometry and con*
uined 72.0 Mg/L copper, indicating thai 28% of the
copper in ihc feed was collected on the steel wool.
EXAMPLE II
In another test, 3.00 grams of sodium metabisulfite
(NajSjOj) were added and dissolved into 10 liters of the
prepared copper feed solution of Example I. This modi-
fied feed solution was then fed at 200 mU per hour
through a new steel wool bed made the same way as in
Example I.
Within a few minutes after tuning the feed, a differ*
eoce was observed on the appearance of the steel wool
compared to the first experiment. Only the feed end
portion of the steel wool bed, approximately the first I
cm, showed any color effect of copper. As the run
proceeded, it was evident that rather than copper cov-
ered fibers of steel wool as obtained in the Ant test, a
compact layer of copper panicles was forming and
10
10
about another half hour, dense particles of copper were
visible in the stirring 10 liters of liquid. After settling for
one hour, a sample of supernatant liquid put through a
pS Fisher filter paper was tested and found to contain 38
Mg/L of dissolved copper.
The remaining steel wool fibers occupied only about
| of the tubular space and had nearly lost the fibrous
shape, becoming a more a mass of fine black panicles.
Upon removing the remaining iron solids from the glass
tube, rapid air oxidation took place, generating exother-
mic heat and rapidly forming rust-like material. This
example shows that by contacting the bisulfite with iron
prior to contacting copper produced a product capable
of precipitating copper.
EXAMPLE IV
The procedure followed in making up the bisulfite
containing copper solution fed to the test of Example II
above was conducted except in the absence of iron. An
being held together by the tightly packed steel wool 20 equal amount of bisulfite as used in the Example III test
fibers behaving as a filter. The shon length of the color- above was added into a 10 liter sample of the prepared
copper containing solution. Other than a slight darken-
ing of color toward a blue greenish tint, no visible reac-
tion or other change occurred. No solids were formed
ation zone revealed that an extremely fast reaction rate
was being observed.
After about 2 hours of operating this test, the effluent
from the bed was spot sampled and AA tested for cop- 25 and no removal of copper was effected by combining
per. finding only 0.02 Mg/L Cu in the effluent. This the bisulfite and dissolved copper in the same solution in
same result was repeated after 10 hours. 20 hours, and
30 hours of run time. At 40 hours, the effluent spot
sample contained 13 Mg/L of copper and only about i
30
cm of steel woo) remained.
The copper solids were packed up against this plug of
stee) wool in a mass occupying only about 0.4 cm of
length. The bottom cm of the tube was void of solids
and contained entering feed solution only. The run was
continued to the end of the 10 liters of feed, at which
time there was no evidence of fibrous material left from
the steel wool. There also was no magnetically respon-
sive material in the solids remaining in the tube. A com-
pact slug of copper solids about 0.5 cm long was left,
the absence of metallic iron particles.
EXAMPLE V
This test was conducted to determine the influence
exerted by chelating agents and ammonium ions in the
feed solution. One liter of the new 200 Mg/L mixed
copper solution was pH adjusted to 9.0 by adding so-
dium hydroxide with vigorous mixing, Copper hydrox-
ide solids were precipitated and after IS minutes of
mixing, a drop of commercial anionic polymer was
added to flocculate the precipitated solids. After set-
tling IS minutes, a liquid sample was withdrawn and put
through a Fisher P5 filter paper and analyzed for dis-
held in position by the cotton plug used to hold the steel 40 solved copper. A concentration of 136 Mg/L dissolved
wool in the end of the tube.
After the run was completed, the 10 liters of effluent
solution was stirred and sampled and AA analyzed,
indicating 11.1 Mg/L of dissolved copper. A rise of
about 1 unit was detected in the pH of this solution, 43
measured at 4.9 versus 4.0 for the feed.
EXAMPLE III
copper indicated that 68% of the copper m the feed was
effectively chelated or complexed.
EXAMPLE VI
This test was designed to measure the efficiency of
removing copper from the solution using the simple
cementation reaction with iron panicles in the absence
of bisulfite or dithionite. One liter of solution of Exam-
ple V was placed in a beaker and provided with an
Another lest was performed by feeding a bisulfite
solution in the absence of copper, prepared by dis- 30 overhead mixer. An equimolar quantity of iron panicles
solving 3 grams of sodium metabisulfite in water and weighing 0.176 grams was added to the solution and
diluting to 100 mis volume and adjusting its pH to 4.
This solution was fed in about 30 minutes at 200 mis per
hour through a new steel wool column made the same
aa in the prior tests. The effluent of the bed was directed 53
into a 10 liter quantity of the prepared copper contain-
ing solution of Example 1, with gentle stirring applied.
About fifteen minutes after staning, a change in the
copper solution was noted, changing to a greener color.
The darkening continued until about near the end of the 60 indicated an uneconomically low efficiency of about 1S
run, at which point the solution had turned almost black percent for the conversion of surface iron to copper by
and showed evidence of paniculate solids being formed
in suspension.
By the end of the 30 minute feeding cycle, discrete
copper colored solid panicles had formed in the 10 65
liters of liquid being treated. A further IX ml of flush-
ing water was passed through the remaining bed materi-
als and into the mixing solution. By the end of that time,
mixed for 1 hour. During that time, a coating of depos-
ited metallic copper could be observed forming on the
surface of the iron particles. After mixing for the 1 hour
period, a sample was withdrawn and filtered and ana-
lyzed, indicating that 174 Mg/L or 87% of copper was
still di&aolved. After mixing for a second hour, another
filtered sample indicated 170 Mg/L of copper still in the
solution, thus completing this experiment. This result
cementation in what is also an impractically slow reac-
tion.
EXAMPLE VII
This experiment was carried out using another one
liter sample of the subject feed solution of Example V.
1.0 gram of sodium metabisulfite was added with vigor-
-------
n 5,122,279
measured on the 15 mam, indicatu^ 19% ,0
remove of copper from the •oluriSt ""^"l M* 10 «* wlution The molir ratio of thii example is to pro-
XF- v uwKMuiion. v»d« two imrfes of sdfur for each mole of iron. More or
EXAMPLE VIII lets iron can be added in variations upon the example
In a ftxnher experiment of the method of Eiamole *r 'IT ***W* •fleeting the phyiical characteristics
VII, all conditions were kept the ume except thauwice IS ° ** ^P""*"- The intended purpose for this com-
as much iron powder was added. After 13 minutes of P01"10" » to P^vide in one feasible substance the nee-
mixing, a 10 ml sample was withdrawn and Filtered and «u*ry.fagredi«its for implementing the process of this
analyzed, obtaining a mult of 0,05 Mi/liter of dis» »ywtwn. by adding said composition into an acidic
solved copper A pH of 4.8 was measured on the re- l°lullon ******* he*vy »««*»«•
acted solution. A strong permanent magnet was Hsrrd 20 / An nfmmnl wh«re» »uch a composition was used
against the bottom of the beaker and then moved up the , lhif P0*?0* wtf canied out on a batch of 10 liters
side of the glass attracting the unreacted iron particles € feed ioluuon of E«*mple V, which contained a
which were observed to be black and not coated with a tOUl. of 200° millif r»m* of dissolved copper. A 45 gram
layer of deposited copper. portion of a well mixed slurry competition prepared in
TTYAWDT c TV 23 *ccord*nc« w*«*» ««« «bove procedure (calculated to
fcAAMPLE IX contain 3,54 grams of iron) was added directly to the 10
In this experiment, the resulting beaker of the experi- liter batch of feed hivil»« • preadjusted pH of 2.5. Vjg.
ment of Example VIII was settled for 15 minutes and orou$ a*luUon w«* provided for a IS minute reaction
the liquid portion was decanted off. leaving the solids in lio*
the bottom covered with a few milliliten of liquid. A 30 CopP** *>l»ds were produced and black, magnetic
new one liter portion of the subject feed solution was iron Ptrtlcle* werc observed in the find mixture. A
added to these contents and instantly, a new portion of "ample was filtered and analyzed and found to contain
1 gram of sodium metabisulfite was added and dissolved ° *5 M8/L of dissolved copper. After the solids settled
with vigorous mixing. After mixing 15 minutes, a sam- for 10 minutes, a one liter sample of clear liquid was
pie was filtered and analyzed, finding 39,2 Mg/L dis- 33 P^red into a beaker. Caustic soda was added to pH 9.0,
solved copper remaining in solution. No magnetic iron precipitating ferrous hydroxide and any other insoluble
was found remaining in the copper colored metallic he»vy metals. A filtered sample of the final alkaline
solids. The total copper removed in the two reactions topuA tested non-detectable for copper, indicating the
by the one charge of 0.352 grams of iron is 360.65 milli- dissolved copper concentration was below 0.02 Mg/1.
grams, which calculates as an efficiency in the use of the 40 ' clum:
iron at 90.16 percent. 1. The process for removing dissolved heavy metal
EXAMPLE X fr°m *" *^ueott$ »luiion containing said heavy metal
c*/\mri-e A wnich c^pri^ admixing said solution with a source
This example illustrates the formulation and use of of ferrous and dithionite ion in solution at a pH between
the reactam composition of this invention. As a pump- 43 «bout I and 7 to effect precipitation of said heavy metal
able slurry, hydrated sodium sulfite crystals and iron «"d recovering said precipitated heavy metal.
panicles are suspended in a saturated alkaline aqueous 2 The process of claim 1 wherein the pH is between
sodium sulfite solution. A preferable choice of starting about 3 and 6.
materials includes technical grade anhydrous sodium 3. The process of claim 1 wherein said ferrous ion is
•uinte crystals, atomized iron powder, sodium hydrox- 40 produced in aim from iron particles.
c .tlldiw!!!er ^ L * The process of claim 1 wherein said ferrous ion
Since sodium sulnt* u known to form a heptahydrate Kniroe is ferrous dithionite.
crymtal ui the presence of sufficient moisture, the proce- S. The process of claim 1 wherein said ferrous ion
dures used herein must take into account the propensity source is ferrous sulfate.
for the anhydrous sulfite to absorb and bond this water 55 « The process of claim 1 wherein said ferrous ton
T l?^?iU^ine mttli* ""* «»« composition comprise, an alkaline slurry of iron pan
lo hydrile lhe ***»
i0lulion of "«
<»«ssolve enough so- sulffte and an alkali metal hydroxide, having a PM be-
i r I!^***!/ "lttriled "^ tween about 9wAl2' wh««" th€ ~i" «tio of aaTd
. At 20% M>lubihty of sodium sulfite, this results in sulfite to iron conuined is between about 0.1 and 10
-------
13
5,122,279
14
9. The process of claim 1 wherein said dithionite ion
is produced in-situ by reacting bisulfite ion and iron
panicles.
10. The process of claim 1 wherein said dithionite ion
produced in-situ by reacting bisulfite ion and zinc parti-
cles.
11. The process of claim 1 wherein said dithionite ion
is produced in-situ by reacting bisulfite ion and alumi-
num panicles
IJ. The proceu of eWm 1 wherein uid diihioniie ion
^-u fcy ,^t ^fue ion .d «,ium
e. ...... . . ,. t. . .
13. The process of cla.rn 1 wherem sud dithionite ion
source is sodium hydrosulfitc.
14, The proceis of claim 1 wherein said dithionite ion
source is rinc hydrosulfhe.
15, The process of claim 1 wherein said dithionite ion
source is aluminum hydrosulfite.
16. The process of claim 1 wherein aaid heavy metal
is copper.
17. The process of claim 1 wherein said heavy metal
is « least one metal selected from the group consisting
of copper, tin. lead, nickel, chromium, cadmium, mer-
curv- silver, gold, platinum, and palladium.
w 'Thc process of claim 3 wherein said iron particles
are of a site between about - 10 mesh and + 300 mesh.
19 ™* ProceM of cliim 9 wherein wid *°urce of
bi^ri!ilon b *n alk'li mettl ™«*™»f"««
e Process °^ cl*|nj ' wherein &aid source of
b»»'««>" » « •"»" n»ttl
lo
22. The process of claim 9 wherein said source of
bUu,file ion b ,ulfur dioxide wilh m dkall mcu, hy.
J5 jroxidc '
23. The process of claim 1 wherein a ferrous contain-
fog solution is obtained after recovering said precipi-
tated heavy metal and raising the pH of said ferrous
containing solution to precipitate ferrous hydroxide and
20 recovering said ferrous hydroxide.
30
35
40
60
-------
United States Patent
Engei et al.
US005097556A
[ii] Patent Number: 5,097,556
[45] Date of Patent: Mar. 24, 1992
[54] LAUNDRY WASTE WATER TREATMENT
AND WASH PROCESS
[75] Inventors: Richard B. Engel. Ft. Pierce; John B.
Gallo, Port Si. Lucie; Donald H.
Bladen, Vero Beach; Virginia F.
Engei, Ft. Pierce, all of Fla.
[73] Assignee: O] Technologies. Inc., Ft. Pierce.
Fla.
[21] Appl. No.: 660,935
[22] Filed:
Feb. 26, 1991
[51] Int. Q.? D06F 39/08
[52] U.S. a 8/158; 68/13 R;
68/18 F; 68/207
[58] Field of Search 8/158; 68/13 R. 18 R.
68/18 F. 183. 207
[56] References Cited
U.S. PATENT DOCUMENTS
2.529.802 11/1950
3.065.620 11/1962
3.130.570 4/1964
3.194.628 7/1965
Glass 68/183
Houser 68/13 R
Rentzepis 68/13 R
Cannon 68/13 R X
Primary Examiner—Philip R. Coe
Attorney. Agent, or Firm—N. J. Aquilino
[57] ABSTRACT
A method and apparatus for washing laundry without
hot water and detergent using a closed loop ozonated
wash water system wherein wash water maintained in a
storage tank is ozonated by an ozone generator prior to
use in a washing machine. The spent wash water is
collected, filtered and reused thereby eliminating waste
water disposal problems and resulting m considerable
water and energy savings. The ozone generator in-
eludes a unique air now configuration to maximize
ozone generation resulting in a high efficiency washing
system.
19 Claims, 2 Drawing Sheets
17
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5,097,556
LAUNDRY WASTE WATER TREATMENT AND
WASH PROCESS
BACKGROUND OF THE INVENTION 5
The present invention relates to a laundry waste
water treatment and wash process and in particular to
such a process using only ozone as the cleaning and
disinfecting product.
Typically ozone is generated when oxygen. Oj, is I0
exposed to ultraviolet light or an electrical charge
which breaks it down to individual oxygen molecules.
Some of these recombine into ozone, 63. Ozone is the
tnatomic, allotropic form of oxygen O:- It is an unstable
gas with a pungent odor and it is normally produced in I5
low concentrations. The chemically active Oj then acts
as an oxidant to break down compounds it comes in
contact with.
When ozone is created by an ozonator, ajr is sub-
jected to an electnc discharge commonly known as a 20
corona which is produced by an electnc charge be-
tween parallel or concentric electrodes separated by a
dielectric to prevent a spark discharge. Normally a
blower forces air between the electrodes and when an
alternating potential from 6,000-30,000 volts, depend- 23
ing upon the thickness of the air space and the dielectric
material, is applied to the electrodes, the part of the
oxygen in the air is transformed into charged oxygen
atoms, ions, which conduct the electnc current. Some
of these ions recombine to form pre-atom molecules Oj 30
or ozone. Because the ozone is unstable, it is important
to remove the ozone as quickly as possible after it is
produced and normal ozonators provide a minimum air
velocity for sufficient operation to remove the ozone
from the electrodes. Increasing the frequency of the 35
power supply to the ozonator increases both the current
and the yield of ozone; however, very high frequencies
often require water cooling of the electrodes. Because
of its instability, the ozone must be generated at the
point of application and pnor an systems often do not 40
produce enough ozone for a particular application.
Since ozone is a powerful oxidant. it is well-known as
a stenlizmg and preserving agent as well as a chemical
oxidizing agent. Among the uses for ozone are the ster-
ilization and preservation of foods such as cheese, eggs, 45
meat, poultry, fruit and so forth. Using ozone as a food
preservation agent was known in the Republic of Ger-
many in the early 20th century. It is also well-known in
Australia to preserve meat using ozone in the mid-
1930's. Ozone is well-known in the purifying and clean- 50
ing of water for a variety of purposes including drink-
ing, bathing, cleaning and so forth.
Ozone also is used to control airborne organic*, bac-
tena and viruses by chemically reacting with them. This
makes ozone useful in health care applications as a dism- 53
fee tan t such as patient and operating rooms, physical
therapy rooms, laundry and disposal rooms, food ser-
vice industries, hotels, restaurants, livestock industries
among others.
The prior an has recognized the usefulness of ozone 60
with laundry washing processes. For example, Japanese
Patent No. 2,149,293 relates to a wet clothes washing
unit comprising a washing tank, a foaming device with
a nozzle for dispersion of bubble generation and an
ozone generator for feeding ozone containing air into 65
the nozzle. The ozone is ejected in the form of bubbles
through a porous plate which is transmitted to the wash
water and laundry which helps clean the laundry with-
out mechanical stirring to remove stains by a bleaching
action. Spanish Patent No. 2.006.978 relates to an ozone
generator for washing machines havtng an internal elec-
trode encapsulated in the glass tube and a coaxial metal
tube as an external electrode. Air is drawn by a pump
over the generator electrode and passed mio the wash
bath. Japanese Patent No. 86-218.645 descnbes an elec-
tnc washing machine with a built in bleaching function
which incorporates an ozone generator and air diffuser
pipe for blowing ozone into the washing machine to
bleach clothes without using a bleaching agent Belgian
Patent No. 899,577 discloses a washing machine which
agitates clothes with compressed air and ozone blown
into the washing chamber. German Patent No
3.232,057 discloses a washing machine with an ozone
generator to kill bacteria using an ozone atomizer spray
tnd feed channel which lead into the cleaning fluid
vessel and acts dunng the rinsing phase. Another Ger-
man Patent No. DE 3,007,670 descnbes a detergent
free laundering process of textiles using an aqueous
solution of bromide or bromic acid and ozone.
The present invention relates to a laundry waste
water and wash treatment process wherein water is
continually recycled and filtered in a washing machine
system using ozone as the primary disinfecting, cleaning
and bleaching agent. With this system, it is not neces-
sary to use conventional detergents and soaps which
make the water unusable except for an initial cleaning
process. The process contemplates recycling the waie~r.
both dunng the cleaning cycle and the nnse cycle.
without adverse effects to the washing process. Rather.
ozone washed laundry exhibits a high quality of cleanli-
ness and freedom from bacteria as well as providing an
aesthetically clean looking and smelling laundry prod-
uct.
In a preferred embodim«m, water is recycled from a
collection sump and is pumped to a storage tank where
it is stored until it is needed for a wash cycle. When a
wash cycle begins, the water is pumped from the stor-
age tank, through a filtered line into a holding tank. The
water is the holding tank is treated with ozone which is
entrained into the holding tank water as it is being
stored. The water in the holding tank is kept in a contin-
ual state of flow by being pumped from the tank bottom
through a filter and returned to ihe top of the tank.
When a wash cycle is activited, water is pumped di-
rectly to a washing machine or machines for use in a
conventional wash cycle. After the wash cycle is com-
plete, the water is drained into the sump and a rinse
cycle is initiated by pumping additional water from the
holding tank into the machines. With the present system
there is no need for the water to be heated thereby
enabling the fluid to be kept in a closed cycle system.
Additional water is periodically added to either the
storage tank or holding tank to compensate for the loss
of water in the system due to evaporation, spillage and
to replace the water removed by the wet laundry.
With the present system, using recycled water, water
savings is considerable. When used in commercial and
institutional locations, millions of gallons of water per
year can be saved. The problem of eliminating waste
water and the treatment of this water which in previous
systems would eventually find its way back into the
ecological water supply is eliminated. The ozonated
wash water eliminates the use of soap and other sour
and toxic chemicals and the resulting environmental
degradation caused thereby. Not least of all. the present
-------
5,097,556
system increases the capacity of the washing machines
in use, eliminates the use for hot water and generally
greatly reduces the cost of laundry operations.
Among the objects of the present invention are the
provision of an ozone laundry waste water treatment 5
and wash system which saves water, eliminates the need
for hot water, soap and chemicals and greatly reduces
the costs of operation of the various systems.
These and other objects will become apparent with
reference to the following drawings and specification. 10
DESCRIPTION OF THE DRAWINGS
FIG. 1 illustrates a closed loop laundry waste water
treatment and wash system in accordance with the pres-
ent invention. 15
FIG. 2 illustrates a corona discharge unit used in the
system of FIG. 1.
FIG. 3 illustrates a detail of the unit of FIG. 2.
FIG. 4 is a top plan view of an ozonator used with the
system of FIG. 1. 20
DESCRIPTION OF THE PREFERRED
EMBODIMENTS
Referring to the drawings, the laundry waste water
treatment and wash process includes a series of washing 25
machines 10 such as are found in a commercial laundry
institution, laundromat or similar establishment. Each
machine is capable of being operated independently of
the other and is supplied with water through a water
supply line 12 connected to a water holding tank 14 30
which pumps the wash water into the machines 10 using
a supply pump 13. The washing machines 10 are drained
into a sump 16 which collects the waste water for recy-
cling. After a wash cycle is completed, the water from
the sump 16 is pumped by a sump pump 15 or gravity 35
fed through a resupply line 17 to a storage tank 18
where it is collected. Prior to the initiation of a wash
cycle, the water from the storage tank 18 is fed by a
pump 19 through a filter 20 into the holding tank 14. A
supply of fresh water may also be added through line 22 40
from a source (not shown) through a suitable vaJve 23
to replace the water which is lost during the wash cycle
due to spillage, evaporation and the wetting of the laun-
dry being washed. The holding tank 14 is provided with
at least one and preferably a series of ozonators 24 45
which inject ozone into the water in the holding tank 14
at a controlled rate.
The ozone is entrained from the ozonators 24 through
an ozone supply line 32 by an ozone- pump 34 into the
holding tank 14 using a nozzle 36 which directs the 50
ozone against a routing impeller 38 attached to and
driven by a motor 40. The impeller 38 aids in thor-
oughly mixing the ozone within the water held in the
holding tank 14. It will be appreciated that the motor 40
may be a submersible type or may be located outside the 55
holding tank 14 with a suitable mechanical connection
to the impeller 38.
The water in the holding tank 14 is continuously
circulated using a recirculation pump 26 which pumps
water from the bottom of the holding tank 14, through 60
filters 28 and 30. and back into the top of the tank 14.
This recirculation of the water, continuously cleans the
water using the filters 28 and 30 and also creates a con-
tinuous agitation of the water in the holding tank which
further aids in mixing the ozone in the water being 65
stored in the holding tank 14.
Referring to FIGS. 2 and 3. the ozonators 24 are
formed of a plurality of corona discharge units 50. Each
unit includes an evacuated glass envelope 51 which is
generally cylindrical in shape having closed ends 52 and
54. The interior of the glass envelope 51 includes a
permanently fixed electrode 56 having conductive leads
58 which are connected to a high voltage transformer
(not shown) having a high voltage output, for example
10.000 volts. The interior of the envelope 51 is filled
with an inert gas such as argon or the like or a combina-
tion of such gases. The outside surface of the glass enve-
lope 51 is formed with a heiical nb 55 extending the
length of the envelope. The rib 55 ma be glass integrally
formed with the outside of the envelope or may be a
teflon wrap or other similar material adhered to the
outside of the envelope after it is made. The outer por-
tion of the corona discharge unit 50 is formed with a
metallic sleeve 57 closely fit to the helical nb 55 on the
outside of the glass envelope 51 forming an air tight seal
between the glass envelope 51 along the rib 55 and the
metaJlic sleeve 56. This creates a helical air flow path
from the top of the corona discharge unit 50 to the
bottom. When the high voltage is impressed across the
electrode 56. an electric field is produced which inter-
acts with the inert gas creating a corona charge on the
outside of the glass envelope 51. The corona charge
interacts with the oxygen in the air, breaking it down
into individual oxygen molecules O. Some of these
molecules recombine into the unstable O) form which is
ozone. Air flows across the outside of the envelope 51 in
the helical path formed between the envelope 51 and
the outer metaJlic sleeve 56. This aids in breaking down
the oxygen to ozone due to the increased time the air
remains across the surface of the charged envelope 51.
Preferably the air is either drawn by suction or pumped
from one end of the tube to the other to facilitate contin-
uous air flow and collection of the ozone.
FIG. 4 illustrates a typical ozonator 24 as seen in plan.
The ozonator 24 is formed with a series of corona dis-
charge units 51 placed lengthwise in an outer housing
60 to create multiple sources of ozone. Typically 6 to 10
corona discharge units 51 are used with each ozonator.
however, it will be appreciated that any number may be
provided depending upon the requirements of the sys-
tem. The housing 60 is provided with water cooled
tubes 62 which circulate water or other cooling fluid
within the ozonator to cool the corona discharge units.
Whereas FIG. 4 illustrates only a partially filled outer
housing, it will be appreciated that the housing is sized
to accommodate the number of corona discharge units
and water cooled tubes.
As can be seen from the schematic of the wash sys-
tem, a continuous, closed fluid flow loop is provided. In
a typical closed loop washing system, such as might be
found in an institution, commercial laundry or the like.
a senes of washing machines 10, each capable of wash-
ing a 125 pound load, are connected to a source of
ozonated water washing fluid held in the water holding
tank 14, capable of holding from 500 to IjOOO gallons of
ozonated water. The machines 10 typically are designed
to hold between 30 and 90 gallons of water for a given
wash cycle. The washing fluid in the holding tank 14 is
continuously circulated from the bottom of the tank to
the top of the tank using the recirculating pump 26
which pumps the washing fluid from the bottom of the
holding tank 14 through a series of filters 28 and 30 back
into the top of the tank 14. This, recirculation of the
water aids in cleaning the water with the filters and also
in mixing the ozone in the ozonated water washing
fluid. The pump may be continuously or intermittently
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5,097,556
In a typ,ca, system using the present invention, the
water ,s kept at room temperature and requires no soap
or detergent dunng the wishing process. Water from
the storage tank 18 is pumped through the filter 20 to
the holding tank 14. When a wash cycle is initiated, the
ozonated water is pumped to the machines for the wash
cycle. When the wash cycle « terminated, the used
and further
5. The method of claim 1 furthermclud.ng the step of
removing waste wash materials from sa.d wash w?ter
supply a? the end of the wash cycle
6. The method of claim 5 wherein 'said remove steo
is further defined as filtering sa!d wa? , w«r Top v
7. The method of claim 1 further mdudin h stS of
,s complete. Automatic level controls (not shown) such
as float switches or level sensors control the transfer of 15
water between the vanous storage and collecting areas.
The recycled water is properly filtered using state of the
5 S°
As indicated above the system loses water by evapo- 20
ration, spillage and splashing and through being earned
away by the laundry at the completion of a cycle. This
k>ss „ replaced from a standard supply source of cold
water. The replacement water represent only a small
fraction of the amount of water used in similar systems 25
where the use of soap, detergent and bleaches requires
the wash water be disposed of and replaced after each
use , It will be appreciated that modifications may be
made m the system and apparatus descnbed herein-
above m keeping within the scope of the pr«ent mven- 30
, A m..Krtj nf u , j ,
X. A method of washing laundry using a closed loop
wash water system comprising the steps of:
m meaT"8 * "^ °f ^ WatCf '" * ""* Sl°rage "
ozonating said wash water supply;
^0 md °Z°naled "^ WltCr SUP,Ply l° 3
washing means upon commencement of a wash
u- j! j -. , *°
washing said laundry in said washing means:
C°l^\^ ^f Tter SKPPl>, '" Vcollectin*
means at the end of the wash cycle; and
recirculaung said wash water supply from said col-
2 Tnrm8erhCQro;°c, iTT mCanS- 45
nf ^ H K " comPnsm8 the stcP
of storing aid wash water in a second storage means
pnor to delivery to said first storage means.
3. The method of claim 2 further including the step of
transferring the wash water from said second storage 50
l° thC imUaUOn
of said storage tank through a rirculatmg
back into said first storage means
9. The method of claim 8 wherein said step of rec.rcu-
l.tmg and mumg removes the wash w !er from the
bocf0m 4nd retU"1S the w«h w"« <° '"< top oTsl.d
first storage means.
10. The method of claim 7 further including the step
of filtering said supply of wash water to remove con
tammants therefrom ai it is being recfrculatrt
11. The method of claim iTunher^dudmlthe steps
of rinsing said laundry with a fresh supply of "wash
water at the end of the wash cycle^and co lectL "e
nnse water at the end of the rin* cycle insafdcollec,
ing means
12. The method of claim 1 further including the step
of replenishing the wash water lost dunng th ? walk n.
process 8 washm*
13' ^ method Of claim 1 where'n the oionating step
u furtner defined by generating a source of ozone and
entraining the ozone into the wash water within sa.d
first storage means
M< T1* mcthod of claim 13 fu«h" '"eluding the step
£d"3 tlHSS SSta %XZT ™
«. The method of cla,m 13 wherein the «ep of gener-
.ting the ozone further includes the steps p«smg I'r
over a h'8n voltage corona created by said generator m
a non-linear path generator m
16' ^ m««od of claim 15 wherein the non-iinear
path is defined as helical
17. The method of clum 16 wherein air is passed
"
i T f i -. v ,
4. The* method of claim 3 wherein said transferring
step includes pumping the wash water from said second
P«""P ^ «id hdical. non-linear path whereby the in-
creased air path permits a larger amount of oxygen to
break down and r«»mbine inTo ozone W
18. The method of claim I wherein said wash water is
maintained at ambient temperature.
19' ""* method of dmim 18 wher«" «id wash water
is free from additives defined by the group of soaps
detergents and bleaches.
55
60
65
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U.S. Patent Mar. 24, 1992 Sheet 1 of 2 5,097,556
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U.S. Patent Mar. 24, 1992 Sheet 2 of 2 5,097,556
in
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6
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in
CVJ
6
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