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        Todd A. Houts/Peter C. Ashbrook
            (see Peter C. Ashbrook for paper)
             Chemical Safety Section
   Division of Environmental Health and Safety
    University of Illinois at Urbana-Champaign
"Waste Minimization Options for the Laboratory Worker"

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Biographical Statement
Todd A. Houts and Peter C. Ashbrook have jointly been responsible for the chemical waste
management program at the University of Illinois at Urbana-Champaign for over 10 years.
Information about this program can be found at http://www.ehs.uiuc.edu/~chem/. They write a
column on laboratory waste minimization for Chemical Health & Safety magazine. Mr.
Ashbrook is coeditor of the book, Pollution Prevention and Waste Minimization in Laboratories,
published by CRC/Lewis Publishers.

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               Mary Jakeway




                 Whirlpool
"Air Emissions Reductions in the Painting Process "

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                          BIOGRAPHICAL BACKGROUND

                                MARY K. JAKEWAY
Mary Jakeway holds a BS in Microbiology, MS in Environmental Chemistry from Civil
Engineering, and an MBA from Ohio State University  Mary worked as an Environmental
Specialist at Franklin County Engineers tracking federally funded projects and recording
comments from public hearings on bridge and highway projects. Mary then worked as a
Wastewater Chemist with the City of Columbus, Ohio, Sewers and Drains Division  The City was
establishing a central laboratory and Mary was part of the initial design and  equipment and
method selection/standardization.  Mary then served as the Supervising Chemist for the Jackson
Pike WWTP to oversee laboratory operations, complete EPA reporting, and advise plant
operations.  For one year Mary served as the Operations and Maintenance Training Coordinator
as a $400 million upgrade was  installed for one of the City's two wastewater treatment plants
For five years Mary was the Industrial Pretreatment Coordinator for the City, establishing the
program. For the past eight years Mary has served as the Environmental Engineering Supervisor
for the Whirlpool Marion Division.  This includes responsibility for all aspects of the
environmental issues.

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       Whirlpool Corporation
          Marion Division
      1300 Marion-Agosta Road
        Marion, Ohio 43302
      Contact: MaryJakeway
Supervisor, Environmental Engineering
           740-383-7607

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SUMMARY   1995                                              |

Whirlpool CorporatiM, Marion Division, is a, dryer mamficturcr with 24bo employee*.
Plant personnel have undergone extensive review* of existing paint systems to respond to
the 1990 Clean Air Act and the economy of officiant production. For the) Division base
year of 198* Hazardous Air Pollutant* (HAPs) wean* 1,684,714 pounds.

Cooperation of the paint vendor and the manufacturing disciplines of environmental,
facility, sod "futures" engineering for product and process resulted in research and actions
which h*v* peadfty decreased our emissions levels. A switch to "high-sctida* prim was
completed m 1991, -which mgnrrkaintly reduced VQC etmswons per year 1145,000
pounds/year). In July, 1991, our Sow-cost paint was replaced by an e-cc at system
which farther reduced VOC enoapons by 230,000 pounda/year.  These cWiges reflect
change of 60% for the targeted chemicals for the 33/50 initiative from IS 88 levels and are
consistent with out commitment to the 33/50.TJSEP A Pollution Prcvcntij HI Initiative.

Beginning in 1993 research was initiated to determine the feasibility of d sctrocoat paint u
a finish, coat for external dryer parts.  Eleetrocoat paint has never been TO ed M a CWs A
finish for csEterior appliance panj. Currently etectrocoat is being used in many industries
as a primerfbr topcoat paint, or u a paint for non-visible para It is bei ig used in a very
few induitrie» M & One Coot paint for non-orhical applications. If Whirl xsol u suooessful
we can efiminate one of our Wet Pant syrtems, then^y gaming:

o  Reduced Labor Costs.

O  Rofhifari volafffl^ "rgimfc RftAiflaunda reJe«ed to ih^t atmosphere

o  Elinunation of solid and Bquid wart* from that «yatem

o  Increased potential production CftpfthiBtie* ftom our paint system*.

B«nch testing wu cbitducted in 1993 and a fiitt scale trial ha* been completed to date with
encouraging results and the decition to proceed fix request* for capital  fiuufing required
to complete plant rearrangement to begin tn-pl*nt use. Because of the oomplexity of
moves and the necessity to maintain the existing operation this win be ijtong procwa,
slated to require «. roinnnuin of two years for completion.              !

In May, 1994, the "smaH color" paint syaero was eliminated reailting uj a further
 reduction of 19,000 poundVyear,

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                                    1998
                                SUMMARY
The Marion DM$h>n of Whirlpool Corporation has been committed » Ohio Prevention
Past abac* inception. Prior to thUprognto Wbir^xiJ ^ aoautrftted to ito liJSEPA
33/50 button* and bad practiced. active waste flrfnumattjau for many years,
Success in the 33/50 initiative was achieved primarily with, a switch ftam low solids print
to high solids toad H™??*^ ny Application to
roller application at a cost of 580,000 followed by die cleaning and implerneritatioa of the
synthetic. Total cost savings are projected at $375.000 per year snd actual srUno
dooomented to date have been $30,000 per morih atoea Januarv, 1998.  Appro>
55% of the ywitch is complete as of May 1. Favorable pollution prevention bjenefits have
Included le» material usage and elnnmga'on of ahatardom coostrtuant.  The mi list was
expanded to iacJudc chlotmated liydrocarbcms in 1996 aadonr volume ww n tch that the
drawing compound represented over 25,000 pounds for 1996 reporting fiom the
chlorinated panifgna.  The aynlhetio hibe fa water-based instead of petnrfeumf based and
therefore less waste oil fiotn treatment or clean-in? operarioan is generated. lit 1997
54000 gallon* of waste oil was transported to Heritage fitf recyck aa number 4 dicsd.
This will be dunmated at full switch-over. In 1997 we captured 90,451 pounlds of oil
debris waste (7,538 pounds/month). This has reduced to 4,250 pound* per moatfe to date
and is abo snticipBted to virtually disappear

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History                                                      ,

As fc chatter member of Ohio Prevention Ftret (1995) the Whirlpool Marion Division, has
made great strides toward achievement of the commitment firom the Division
     gEBMnt to the target goals at

             80% reduction in VOC'a;
             70% reduction in 33/50 chemicala;
             50% reduction in general trash;
             70% reductioa in hazardous waste;
             35% reduction in WWTP sludge;
             80% reduction In TRI chemicals.
Stretch goals beyond these coramitmeota mctwted 50% reduction in cardboard baaed on
1991 and 20% reductioa in water usage based 
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constituents have decuqwed tha VOC and TRI content. Hazank
wifh hnpternentation of axylene recovery still in 1990 followed by poDnHoa prevention
due to reduced color changes which decreased the need fbrxyicnc, as patl of the one-coat
change. Hazar&ras waste TTO reduced 70% from 1995 to 1997 due to tit is process
change (23,796 kgfrear change during this time period). These goals hsv^e been achieved
with a 25"% increase ta production levels from 19S7 through 1997.

PROJECT DESCRIPTION - 1997 Fociu

1996 was the first year that chlorinated hydrocarbons were identified as TRI chemicals.
For fhe Motion Division our use of a fwJWoosd drawing compound with this constituent
put us over 3w threshold reporting level of 25,000 pounds/year. This fcdar, coupled with
many other variables including industrial hygiene concerns, housekeeping, and coat,
helped to drive a project team which investigated switching from the trusted standard of
many years'  nse to a synthetic lubricant. One major goal was to standardize both the
method of application and the chemical used throughout the press room.  It was crucial to
the group to  include hourly personnel who worked in the affected area as (members of the
team.

Savings are calculated baaed on usage and cost/gallon plus miscellaneous coats including
absorbent floor dry and gloves phg scrap costs plus enviroigneatal ooBte feor 1997 when
traditional lobe wu used versus: costs to dale as the transition is made thrbugh the press
room. To obtain more uniform coating and prevent 'unflmrtrinl hygiene concerns from
misting, roll applicators have been installed at a cost of $30,000, With SOjtt of the switch
in place savings are greater than $30,QOO/month. Material savings represent pollution
prereatioa similar to ice savings seen irom one-coat e-coat because significantly  less
material is required, and the material does not have a TRI constituent, not does it
represent a wastewater treatment concern.  Savings beyond material cost ibmvc  been
achieved with improved housekeeping leading to less use of floor dry and thus lower
disposal costs, less glove usage since (he material does not saturate the gjcwe, and lower
treatment costs because the material is not a petroleum based product. Bfclowisthc
analysis of solely the environmental impact from this project to date.

1997 efforts resulted in a redaction of TRI chemicals of 184,765 pounds from  1996.

                  Benefits
A striking h«gfi»: ia the elimination of 25,000 pounds/year of chlorinated hydrocarbons
fajrt the TRI H*L TWa represents 3% of our 1997 reporting. The impacj on the
waatswater treatment area is appro*imaTeri by awftchdng from the preWot drawing
oompoand to a synthetic which will not require an acid break for treatment. The acid
-------
savings tabbed OP an average of 1200 gaflini^monthat «oo«t of $i.j5igallon. That:
will oat Iflcely b« an oil layer *mc* only * small amount of mffl oil is on the steel, and
     U a decraBedvohunc to be processed. TbccxgankxieaouuKBob) wDlincr
and may require to use of polymer to clarify the affluent prior to discharging it to the
City of Marion for secondary
Prom an. unrelated change, the pH can be decreased from 10.2 S.U. to lower the lime
usage. TWawfll probably not be below 9.0 S.U. dne to (te aoh&fllty ofjztac.  Provided
this docs not raise zinc levels above 1 ,600 ue/U the time usa^U projected to go down
20H, which saves $3^00/year and primarily afibcbi ihxlge geatcation, estimated to
decrease 25%» or 250 tons/year. At $32Aon, this is $8,000 md avoids ijg trips at $160
each or $2,8*0.

ANNUAL SAVINGS DUE SOLELY TO ENVIRONMENTAL ISSUES
                                                           i
(Actual 1997 Heritage coat for waste oil jrecycle was $21,425) + (Floor dry purchased was
$4740)+ (Oil debrij disposed ad a drum waste coat of $10.000) + (decreased lime
£3^00) + (decreased acid $1 6,560) - Propoeed saving of S56,165
               VS
(Increased cost of BOO surcharge at $8,000) + (polymer cost of $10,800) - $18,800
TOTAL SAVINGS =
WwteOH
WOO
Swrckwrjt
                                      AtidOM
            LittUCoit
Sludge
Haofiag/Dnpo
9x6000 fBJ»
            SMOAna
14,400 gpltx
2S% reduction
34,000 ph
                                     50,000 Ibs X
                         230 tons xS32/
mtSMCXVtrip
SI WOO
199T
$21435
             12MW-
                                     $Q.07/Tb
                                     53,500
                         ton-tR.000
                         I*orlpaxl60
                         £2^*0.
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HEALTH AND SAFETY BENEFITS

We have seen elimination of the we of floor dry abaci-beat in our rew parts warehouse
       bk waste fe any ranairang                   Previously vfe had been
collecting 1be oil and floor dry waste and sending ft to fod blending feciiitie* such as
Heritage or Safety Kleen. Our generation tale had i cached 40 drums eviny quarter, which
vtraaa coat of $125+ per dram or $3000/quarter. This wastestream has Decreased by one-
batfat 4u point and will he eliminated with ftiU switch-over.

dove usage is decreasing drastically and hourly employees have been involved with the
team to asairt in fteevahation and switching presses to             Comments have
been favorable, An Operational Excellence Program has been initiated k Whirlpool
wherem engineers art trained on quantitative metlKKlK, d«ign of ajqwanjoento, etc. Tbw
lobe dwnge h44 been pursued as an OPEX project This has given the pmject disdpline
and has assisted in tracking cm a monthly bask fi» the crosf-funcdonaJ areas impacted.
With 55% Of Ihe prc9» room switched gradually since January, 1998, through April 30,
] 99*, easts have decreased from 151,000 to $45,900 for the corresponding trntefr*">" in
1997 *jr glove purchase and cteautne and floor dry. Tht* cofrcspondsi tO » penny per writ
saving at this point

RoQer application of the drawing compound is farvorabte b^cawo misting is eliminated.
This decreases industrial hygiene (employe* health) issues. Standardization of the raUors
thrcTughout the prea snra is beneficial for repairs. The roll appUcation allows a much
more even distribution which decreases lulre waste.  The water-based syjotbetie is far
more pre&table for employee handling and cootBist

One other poaafHUty la being pursued which may allow elimination of a procruction
washer. Because of the lack of oil in the synthetic compound this appcats fcasabk,

MANAGEMENT COMMITMENT

As stated in the histajy scctkitt, liw MarJoa Drvision management team has endorsed The
commitment to the Ohio Prevention First program which 4fHmfep establishment of
targeted goals and adoption, of a general policy to cofltb&allyaeatchfbfipothitkm
prevention ohetnatives for chemical uae and waste generation.
-------
One pioguut -which has been ongoing since 1992 is the annual Quality Awards
celebration. Projects are submitted by the developing team for judging at the Division
leveL Depending on the nting received, the prajMt may qualify fcrsufainiittltoibc
        i level for competition wtflt other JiTiakju projects. This project has received a
"gold" level at the Division (highest possible) and wttl be me only Marian Division
project in contention at the corporate level. Prizes, baaed on rating received, ate given to
Manx member* of winning projects.  Examples of prize* at the Division Jevd include logo
jacket*, $100 savings bonds, shirts, sweatshirts. The 1998 auhrmttal of fee project la
attached as Appendix B.

The Division &&> offers * "pttuamancc share" program in which amount* are identified
and a base year established. As miprovementB ate made •winch lower expenditures in
specific accounts, reduce electrical us*, improve quality,  or reduce scragj the savings per
unit against the base year are calculated and payouts are made 1o all employees on t
quarterly basis.  Within this program is a cost improvement program whjkh allows all
employees to submit suggestions and be eligible for quarterly prizes which hove included
grand prizes of ruling mowet^ vacation^ bnfoequc grills, etc. Suggestions can be as
major as the lube unprovement or as small as «n individual or department change.
Payouts for 1997 were ova $1000 per person (plant population is 2500)1

TRANSFERABILITY

Wimin Whirlpool transfembility of information U adiicved throueh the DPEX program
which uses a Lotos Notes database program to track project savings and! coats. This
program Is available to all divisions for review.

The environmental nngnwiry corporate environmental manager and director, and
international environmental director hold an annual conference for exchange of this sort
of information.  The conference wa* held this year in Tula* and this ptoject was presented
as & "Best Management Practice" tor the corporation.

Whirlpool has been a charter member of Ohio Prevention First and ihe Clyde Division
received an sward earlier in the program.  Whirlpool staff ace commitfM to sharing
information gained fcom this project with other industries through the amnual data
summarks compiled for the State and through qonfercnces/workshopa as requested

ECONOMIC BENEFITS

This project has been pursued for over  18 oaonl^ from conception to mrplcmeotation and
the implementation wQl be a 9 monlfa procesB. Dies most be cleaned prior to any switch
so the ntmtemeotation has been one press at a time. Roll applicators have had to to
-------
 aptatizrttrt ft oostof $80,0   « talk t^ayst^
                                                    Tnddagjoo a monthly
basis tadicaiet mines gf $30.000 per mondi0vmoa^ttan$itionalpljiBse. Eventual
savings with full phcfla-m are antkJptfed to be $375,000/year.
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      VOC SUMMARY
                           (LBS)
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1776312
1544699
1509824
11161SCJ
1194116
715294
502325
517840
742099
646868
557590
69.2% reduction from
1987 to 1997 with 25%
increase In production
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  WHIRLPOOL CORPORATION MARION DIVISION



TOXIC RELEASE INVENTORY CHEMICALS SUMMARY
Year
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
Pounds Released
2,134,616
*
1,787,269
1,765,708
1,296,612
981,260
692,341
509,441
496,341
667,700
69&00
510,000
             % REDUCTION
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WHIRLPOOL CORPORATION MARION DIVISION



        313 LISTED CHEMICALS



           33/50 INITIATIVE
Ydar
1988
1989
1930
1991
1992
1993
1994
1995
1996
1S97
Pounds Released
861,796
840,714
683,621
424,730
173,600
202,000
112,000
161,000
125,000
93,000
       89.2% REDUCTION
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                Keith O. Legg




             Rowan Catalyst, Inc.
"Metal Finishing P2 by Chrome Plating Replacement"
-------
Keith 0. Legg                           BIOSKETCH                         November, 1998

Keith Legg is President of Rowan Catalyst, Inc., a company that has been carrying out market analysis,
technology evaluation, and technology development for commercial and government clients since 1990.
He has been involved in coatings and surface modification for more than 20 years, and is internationally
known for his work in clean coating technology.  He has been heavily involved in chrome plating clean-up
and replacement for a number of years, carrying out projects and analyses for EPA, DARPA, and
commercial clients.  He is the technical lead for HCAT, the primary DoD effort to replace chrome plating in
Defense Department depots and vendors in the US and Canada, and is currently evaluating technologies
for internal diameter chrome replacement.
-------
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              Joseph Leonhardt




          Leonhardt Plating Company
"Innovative Water Conservation at Leonhardt Plating"
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BIOGRAPHY

Joseph Leonhardt CEF is the environmental manager for Leonhardt Plating Company an
electroplating  company  in  Cincinnati.      He  has many  responsibilities  including
environmental, safety, quality and personal manager. He authored a pollution prevention
paper that won Leonhardt Plating the Ohio Governors' Award for Pollution Prevention in
1997.  He was spoken to various groups and conferences concerning the p2 activities at
Leonhardt Plating. He is the current President of the Cincinnati Branch of the American
Electroplaters and Surface Finishers,  and he is  the Events  Director for the SUR/FIN
convention in Cincinnati hi 1999.
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                   Innovative Water Conservation
                                 Summary

Founded in 1950, the Leonhardt Plating Company is a family owned and operated
electroplating job-shop in Cincinnati.  The company provides a variety of metal finishing
services, including Polishing, Buffing, Electroless Nickel Plating, Nickel and Chrome
Electroplating and Electropolishing of Stainless Steel in a 20,000 square foot shop.
Leonhardt Plating is committed to total quality control and promotes continuous
improvement at all levels including environmental.

Over a five year period, through an innovative, continuous  program of water and raw
material conservation, Leonhardt Plating  has  dramatically reduced its water usage and
embarked on a permanent pollution prevention program.

As a result of concentrated efforts  at Leonhardt Plating reduced  water usage from
approximately 23,000 gallons a  day  in 1993, to 3,000 gallons a day currently.  This
resulted in savings of $5,000 annually on our water bill.

In addition to the savings on our water bill, we were  able to  change our permit with the
Cincinnati Metropolitan Sewer District from continuous flow to a batch discharge.  This
resulted in an annual cost savings of $10,000 in discharge monitoring fees.

In June of 1993, we  began  brainstorming sessions  aimed  at reducing wastewater by
making the plating process more efficient.  Changes included installation of water tuners,
reduction in the number  of rinse tanks, use of  counterflow  rinses, redesign of the hot
water rinse, repiping of wastewater collection,  and downsizing of rinse tanks.
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                         Narrative Description

 In 1993, the first duty the operator performed each morning was to turn on all the water
 within the plant.  All rinses continued to flow all day until quitting time and the operator
 would close the main valve as the last duty of the day.  Water savers had been installed
 on all the rinse tanks in an attempt to reduce water usage.  However, the water savers
 became clogged and ultimately failed.   The operators eventually drilled  these water
 savers out to allow for more flow into  the rinse tanks.

 Another attempt to conserve water was posting a sign above the main  valve reminding
 operators to close the valve during breaks and lunch.  This was not successful in reducing
 water usage.

 We  were using water  hi  three different systems.   The  first  was bath  make-up and
 replacement for evaporation loss in the plating tanks and their closed looped rinse tanks.
 This water runs through a deionized exchange cylinder to remove impurities.

 The  deionized water is piped throughout the shop to  fill plating tanks and rinses. All the
 plating rinses are closed looped, and piped through a heavy metal exchange  cylinder.
 None of the deionized water is discharged into the sewer.

 The  second area of water usage was the cleaning  stage  of the plating process.  We
 focused our  attention  on this area because it  accounted  for  over 95  percent of our
 discharged wastewater.

 The  last source of water usage was used in a continuous flow hot water rinse following
 the chrome rinse tank.  This water was discharged into the sewer as wastewater.

 The  wastewater from the cleaning rinses discharged from the  tanks and spilled  into a
 trough that ran under the plating area.  The trough was funneled into  a sump that was
 pumped to a holding tank. The wastewater settled in  the holding tank and discharged into
 the sewer.


 Description of Waste Reduction Techniques

 Installation of Water Timer

A water timer and solenoid valve was installed to deliver a fixed quantity of water to each
 rinse  tank.   We purchased a lawn sprinkler water tuner and solenoid valves at a local
home improvement  store.  Instead of  watering the grass, our converted lawn  sprinkler
 system feeds water to our rinse tanks.

The water lines are now piped to a central location connecting the feed for each cleaning
line.   A solenoid valve is installed at the beginning of each line, and wired to the water
timer.
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The water timer allows  us  to control the amount of water to each of our five plating
rinses.  The amount of water needed is dependent of the size and quantity of parts run,
and the times  that the parts  are run.  We found that more water is needed before breaks
and lunch breaks.  Less water is needed for small flat parts.  Any line can be turned off or
on per water required.

Counterflow Rinses
We  decided  that  the  soak  rinse  was the dirtiest and needed the most  water.   The
electroclean and acid rinse wastewater were fairly clean.  We decided to reuse this water
by collecting it and pumping it back to the soak rinse.

The wastewater from the electroclean and acid rinses overflow into a sump barrel that is
pumped back  to be reused  in the soak rinse.  This achieves our objectives of reusing
fairly clean water and also doubled the amount of flow for our dirtiest rinse tank without
using fresh city water.

Redesign Hot Water Rinse

A flowing hot water rinse  followed  the closed looped Chrome  rinse tanks.  The final
Chrome rinse was piped into a holding tank and pumped through a heavy metal exchange
cylinder that removed  the heavy metals in the water and before  sending it back to the
final Chrome  rinse.  We decided  to combine the chrome rinse water into the final hot
water rinse.

We repiped the  final Chrome rinse through the heavy metal exchange  cylinder and into
the hot water heater.  The water is heated and runs into the final rinse and overflows to
the supply source for the earlier Chrome rinse. This is a closed looped process and none
of the final rinse is discharged into the sewer.

Repipe of Wastewater Collection

Another major improvement was the piping of the wastewater directly to the collection
sump for  each line.   Now  if  the  pH is running high or low,  we can easily test the
wastewater discharge of  each plating line to  determine where the problem is  occurring
and correct it.

Rinse Tank Updated
We looked at  each rinse tank to determine its size and condition.  Most  of these rinse
tanks were steel and needed  to be repaired.  The replacement of tanks are polypropylene
or fiberglass tanks.

The new tank size was important because the  larger the volume of water, the more water
was needed to  keep a fresh clean tank.  The tank size was judged by the smallest possible
size that parts could still run. All new tanks are fitted with weirs to capture any solids or
oils that floated on top of the water.
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A save rinse after the chrome tank was converted to a spray rinse.   The chrome is
collected in the tank  and added back to the  chrome plating tank.  This is saving us 200
pounds in the cost of chrome.

Reduction  in Number of Rinse Tanks

After scrutinizing the rinse tank layout, we decided that two rinses following the acid
tank were not necessary. We removed one rinse with no noticeable change in the quality
of rinsing.  This eliminated three flowing rinses and saved $3,000 in water cost annually.

Environmental  Benefits


The  reduction  hi  wastewater  has allowed Leonhardt Plating  to  change  its  current
continuous  wastewater discharge  permit to a  single daily batch tank discharge.   By
capturing all wastewater in a batch tank, Leonhardt Plating  can avoid a potential spill
discharge into the sewer.  A daily record log of pH, temperature, volume, start and stop
time of each discharge, and name of operator is maintained.

Batch discharge has caused us to operate more efficiently by reducing our operating and
monitoring costs.  We have used these cost savings to improve recycling and reduction of
our wastewater.  Batch discharges also benefits MSD as a result of decreased paperwork,
inspector's  time, and  wear and tear on MSD  equipment.

Leonhardt Plating has made a commitment not to generate any more wastewater.  In 1995
and 1998 we installed a new electropolish process that is completely closed looped from
the sewer.  All  the rinsewater is piped through a heavy metal exchange cylinder and
reused hi the process.


Economic Benefits

Over the last five  years, business has  doubled.  This proves that pollution prevention
worked for Leonhardt Plating as our costs decreased and sales increased.

We anticipate an immediate cost saving of  $10,000 as a result of decreased discharge
monitoring fees.  In  addition,  we will also experience a cost saving hi the amount of
water we buy and raw materials we purchase.

The  long term  cost savings will boost the  company's growth potential  and long-term
survival. We have reduced the company's liability and improved the company's image
as one that  is more socially and environmental responsible. It has helped keep and attract
environmentally  conscious  customers.   We  are  providing  the  legacy of a  cleaner
environment for future generation.
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                   Tim C. Lindsey

    Illinois Waste Management and Research Center
"Proven Methods for Promoting the Adoption ofP2 Innovations:
                 Case Study Examples"
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                              Timothy C. Lindsey
      Tim Lindsey has been Manager of the Illinois Waste Management and Research
Center (WMRC) Pollution Prevention Program since 1994.  He supervises a  staff of
15 engineers and scientists that perform research on innovative pollution prevention
technologiesnd provide  technical  assistance  to  industries  regarding  pollution
prevention  strategies.   Dr. Lindsey  began working  for the  center in  1991 as  a
Research Engineer working directly with  industry personnel to define methods for
reducing both the volume and toxicity of the wastes that they generate. Tim was
previously employed at  one of the nation's largest energy processing  facilities for
Exxon.  He was with Exxon for a total of six years and served as an Environmental
Engineer, Safety Coordinator and  Proje Manager.  Prior to his work with  Exxon,  he
was   employed   as an  environmental  consultant  for  five  years  supervising
contaminated site investigation and remediation projects.  Tim   received  his  B.S.
(1979) and M.S.  (1980) in Environmental Science from Southern Illinois University
and his Ph.D. (1998) in Environmental Planning at the University of Illinois.
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            Daniel Marks




      Progressive Recovery, Inc.
"Innovations In Solvent Recycling Systems"
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                       Dan Marx




Screenprinting & Graphic Imaging Association International
          "Screen Printing P2: An Emerging Vision "
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Biography:

Dan Marx, senior associate, government affairs, has been with Screenprinting and
Graphic Imaging Association International since 1991. Focusing primarily on safety and
environmental issues, he has created many of the Association's training and compliance
programs, and has written on safety and the environment for a number of different
industry publications. His numerous articles for the Association's monthly, the Tabloid,
and other association publications, as well as his industry speaking engagements, provide
him valuable forums from which to address important safety and environmental
compliance issues of the day.
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Screen Printing P2: An Emerging Vision
Introduction

For more than six years (starting 1992), the Screenprinting and Graphic Imaging
Association International (SGIA) has been involved in an extensive P2 effort, mainly
through its involvement in the US EPA's Design for the Environment Printing Project.
Throughout this period, SGIA staff has learned a great deal about P2 methods and
practices being developed by printers, as well as industry suppliers and materials
manufacturers. Emerging from this experience is a new vision - a better way for the
screen printing industry - an identification of environmentally preferable alternatives at
every step of the screen printing process.

This article, utilizing numerous pollution prevention case studies, presents real-world
examples of P2 successes, while at the same time presenting a start-to-finish tour of the
screen printing process. While examples given will certainly not represent "one-size-fits-
all" solutions to this highly diverse industry (products range from T-shirts to signs;
surfboards to printed circuit boards), they do present universal strategies - diving boards
of thought - for the minimization of waste and the prevention of pollution.

The Traditional Process in a Nutshell

Art/Image Preparation

Traditional "pre-press" image preparation includes the creation of film positives through
the use of photographic developing processes. This photographic process is quickly
becoming an activity of the past in many operations. Alternatives  to this traditional
process are discussed later in this article.

Screen Preparation

The creation of a printing screen begins with a wood or steel frame over which mesh,
(commonly monofilament polyester) is stretched to a high tension, then attached. The
mesh is then coated with a photosensitive emulsion. Once this emulsion has dried, a film
positive is placed on the screen, which is then exposed to intense light. After exposure, a
rinse of the screen mesh displaces any areas where the emulsion was not exposed to light,
thus creating a "negative image." The screen is then ready to go to press.

Printing/Ink Use
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In the actual print process, ink is forced through the screen mesh onto the substrate (print
surface) by virtue of hydraulic pressure initiated by the action of a flexible rubber or
synthetic blade known as a squeegee. Ink is deposited in areas where the stencil allows
ink to pass. The printed substrate is then conveyed either by hand or mechanically onto a
conveyor transport system, which conveys the print through a drying unit. In textile
printing, a light-tack spray adhesive is periodically applied to the printing platen, in order
to prevent the fabric substrate from moving or distorting during printing.

Inks commonly used in screen printing are traditional solvent-based inks and ultra-violet-
curable (UV) inks, both utilized in the industrial and graphic areas of the industry. The
screen-printed-textiles area of the industry commonly uses plastisol inks. Water-based
inks are found in both areas of the industry, though they offer little environmental benefit
when compared to more preferred alternatives.

Screen  Reclamation

During  the process of screen reclamation, the stencil that was applied to the screen in
order to define the printed image is removed, so that the screen may be reused. Within the
reclamation process, all excess ink is removed from the screen for reuse. At this point,
any remaining ink residue is then removed from the screen, using either water-soluble ink
degradents or solvents. Next, the screen is degreased using a mild detergent. A stencil-
removing chemical is then applied.  After the stencil remover has dissolved the stencil, the
stencil is then removed using a pressure-washer. After this step, if any emulsion is still
left in the screen, a caustic "haze remover" is used to eliminate the remaining emulsion.
The screen is then ready to be reused.

Alternative Methods

The information outlined below presents some of the many ways progressive screen
printers are preventing pollution in their operations. Before any of these methods or
techniques is discussed, however, it is important to discuss exactly from where change in
our industry is emanating. Many of the developments you will read about below were not
originally intended to bring about a positive environmental benefit. In many of cases,
they were designed to either improve quality or reduce costs. Some changes were even
driven by the protection of employee health. These myriad motivations for change are in
keeping with an ongoing theme constantly outlined by SGIA: safety, the environment,
and good business production practices are very often interrelated. Using a chemical safer
for your employees, for instance, can have an undeniable effect on a company's
environmental impact.

Art/Image Preparation

Recent changes in art and image preparation have been driven primarily by the
introduction of digital and computer technologies. Design software has easily dovetailed
with digital output devices designed to produce film positives quickly, easily, and without
the use of photographic chemicals. These devices run the gamut of digital technology,
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ranging from small-format output from a standard computer laser printer onto translucent
vellum; large-format thermal setting of images onto transparent film; direct-to-screen
devices that inject the image directly into the screen mesh. Benefits of these types of
devices include the reduction or complete elimination of photographic chemicals, and
greater control of printing variables.

Some screen printers have also found an environmental advantage by using a color digital
output device to create proofs for client review. This activity can be used to finalize art
and design concerns before the press is set up. Design changes after press set up would
require the reclamation and re-exposure of any screen involved.

Screen Preparation

The major environmental opportunity relating to screen preparation is to prepare screens
carefully at all points in the process. Substandard screen preparation work can lead to lost
time, lost money and the needless waste of significant amounts of chemical product. To
provide an example, screens that are improperly prepared and improperly exposed may
lead to unfavorable print quality. This means the job must be set up again. First, the
screens must be reclaimed, requiring the use of one or more reclamation chemicals. Next,
if the screens were either underexposed or overexposed, they may require the use of even
more chemicals. This situation is a prime example of quality directly effecting
environmental impact.

A secondary, but interesting environmental opportunity in screen reclamation relates to
the type of screen frame used. Attaching screen mesh to traditional rigid wood or steel
frames requires the use of aggressive adhesives. They also require replacement  of mesh
when, over time or due to excessive use, it loses tension. Attaching mesh to retensionable
frames, however, requires no adhesive, and the expensive mesh can be re-tightened
without replacement.

Printing/Ink Use

The main environmental opportunity relating to ink choice is the substitution of UV-
curable ink for traditional solvent based ink. UV ink, like plastisol ink on the textile side
of the industry, is 100% solid, containing no volatile organic compound (VOC), therefore
highly minimizing air emissions. It  is "cured" rather than "dried." UV ink does  have its
limitations, however, and can not be used for certain applications. As UV ink continues
to develop, however, may of these limitations may vanish. The switchover to UV ink can
also be expensive, requiring the installation of a specific curing unit.

In textile screen printing operations, a number or companies are finding less expensive,
less pollutive ways of applying platen adhesive than the traditional "spray can' method.
Some of these options include the use of water-based adhesives or large rolls of material
similar to double-sided tape.
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Yet another opportunity to prevent waste, and thus pollution in the printing/ink use area,
is the institution of detailed ink management guidelines and strategies. These methods
can include careful ink inventory control, mixing only as much ink as is needed for the
job, detailed ink mixing records, and the prompt use or blending of excess ink.

Instituting a shop rag policy can drastically reduce certain wastes that may or may not
require disposal as hazardous waste. One screen printer experienced success by simply
instituting a policy that rags be used as many times as possible before disposal. To
provide a simple figure, using rags five times instead of once reduces rag volume by
eighty percent. A basic rag management policy can be simple to create, easy to
implement, effective in waste reduction.

Screen Reclamation

Screen reclamation, the process in which the stencil is removed from the screen so the
screen can be reused, is the area of the screen printing process where the most
environmental progress has been made. The main reason for this reality is that this area is
where the industry's "nastiest" chemicals are/were used. For this reason, screen
reclamation was the primary focus of the Design for the Environment Screen Printing
Project.

The use of chemicals other than those considered "traditional" is gradually becoming
commonplace within the screen printing industry, some companies have found interesting
and surprising results from their use of alternative chemical systems: a safer workplace,
better performance, less product used, improvements on the bottom line. Printers
investigating alternative reclamation chemicals have also found, however, that switching
chemicals is not as easy as buying a new jug of product. Challenges  associated with new
chemicals can include finding the right product among many, and achieving employee
buy-in on the use of the new product.

Whether a company is using either traditional or alternative solvents in screen
reclamation, the use of a "closed-loop" solvent application system is an easy way to
ensure that cleaning solvents are used not just once, but over and over until they are no
longer useful. Some companies now distill their spent solvent for even further reuse.

Another common alternative in screen reclamation is the use of high-pressure water
systems to aid in reclaiming. Using this type of system, a chemical is applied to "soften"
the emulsion. The rest of the process is done by the water (often in excess of 1000 psi),
which literally blasts the emulsion out of the screen. In many cases, these systems are
linked with filtration units that claim any particulate matter from the water. Though these
systems can require a significant initial investment, companies using these systems have
found they  are safer for employees, use less chemical product, and make screen mesh last
longer, due mainly to the fact that the mesh is not repeatedly exposed to caustic chemical
products.
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In a recent development, one screen printer has created a holding tank to capture used
rinse water from his company's screen preparation area. This "gray water" is then used
with the company's high-pressure reclamation system. The main advantage in this
situation is the reuse of water.

Even in situations where a company decides to continue using "traditional" screen
reclamation solvent systems, opportunities for increased environmental performance do
exist by way of modified work practices. For instance, one company found that sending
screens to the reclamation process immediately after the press run made the screens
easier to reclaim, requiring less effort, less chemical product, and less need for the use of
caustic haze removers. Relating to haze removers, one company instituted a policy that
haze remover be used only where the screen is stained, rather than on the whole expanse
of the screen mesh. The benefits from these simple work process changes are equally
simple to understand: improved worker safety, improved environmental performance, a
positive effect on quality and the bottom line.

Applying New Methods

As was mentioned in the introduction to this article, not all the methods outlined above
can apply to all screen printing companies. For instance, a screen reclamation chemical
that performs exceptionally when used in conjunction with plastisol ink may work
horribly with UV or solvent-based ink. The methods outlined above can, however, be
used by all screen printers as valuable strategies for future environmental management
efforts. Another example: UV screen printing ink is used on T-shirts.

Last, this article should in no way be considered complete. Pollution prevention methods,
along with the technologies around which they orbit,  are in constant flux. This article
should be viewed as the first incarnation of an ever-developing body of knowledge.
-End-
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                   Joe Mattson

          Industrial Towel & Uniform, Inc.
"New Solvent Recovery Technology for Launderable Printer
                      Wipers"
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     NEW SOLVENT RECOVERY TECHNOLOGY FOR
           LAUNDERABLE PRINTER WIPERS
 WHY LAUNDERABLE PRINTER WIPERS?


 *  LAUNDRY, NOT WASTE


     The U.S. EPA has determined that contaminated wipers generated as a
result of normal operations which are sent to commercial industrial laundries
and subsequently reused are not discarded; therefore, they are not solid wastes
subject to regulation under RCRA.  Wipers that will be sent to a laundry or are
laundered by the generator and satisfy the RCRA exclusion specified in 40 CFR
261.4(a)(l) and (2) are not subject to RCRA accumulation requirements.


 *  COST

    Head to head cost comparisons prove that launderable wipers cost less than
disposables.  In the case of printer wipers where compliant disposal may require
handling as a hazardous waste launderable wipers cost significantly less.


WHAT IS UNIQUE ABOUT ITU'S SOLVENT RECOVERY
PROCESS?


*  What methods of solvent removal are available?


- Air  Drying, not a CAAA compliant option.
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- wringing, required additional treatment prior to reuse. Creates
    often hazardous, waste stream.

- centrifugal extraction, requires additional treatment also. Creates
  additional, often hazardous, wastestream.

-  microwave technology, a time consuming process, 2-3 hours.

-  infrared technology, unproven, slow and time consuming.


or ITU's Solvent Recovery Process.


- efficient, controlled, high % solvent recovery

- solvent is recovered for beneficial reuse

- no additional treatment of the solvent is required

- flow monitoring to record the volume of solvent recovered which can be
reported back to the generator of the soiled wipers for their chemical mass
balance calculations
(overhead, attached, detailing ITU's Solvent Recovery process)
*   WHAT IMPACTS ARE THE IMPENDING EFFLUENT
LIMIT GUIDELINES AND STANDARDS FOR INDUSTRIAL
LAUNDRIES GOING  TO HAVE ON  THE INDUSTRIAL
LAUNDRY INDUSTRY?
     START TREATING:  those industrial laundries without wastewater pre-
treatment may choose to install equipment which enables them to treat to the new
standards, (about $1.5 million)


     UPDATE TREATMENT SYSTEM:  those industrial laundries with "just
enough to get by " today will have to update their pre-treatment systems, (about
$250,000 for upgrade)
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     A VOID THE NEED TO TREAT: industrial laundries with no system now
may decide not to invest in pretreatment. They may choose to sell their business
or outsource a portion of their cleaning to another industrial launderer.

     DRY CLEAN:  Industrial laundries will try dry cleaning wipers to avoid
wastewater  discharge problems, a process which results in product quality
unacceptable by industry standards.

     Disposable Wipers  are an alternative for the end user, but should be
evaluated in light of product cost, handling, storage, RCRA, CERCLA and total
risk.
* A FEW INDUSTRIAL LAUNDRIES, ABOUT 13%f HAVE
WASTEWATER PRETREATMENT CAPABLE OF MEETING
THE NEW CATEGORICAL STANDARDS.  ITU is one of the
13% capable of meeting the categorical standards.

A comparison of pretreatment standards:
Pollutant parameter        CP-Daily Max.  (mg/L)

         Laundries (new)   Electroplaters     Metal finish

Copper       0.24              4.5           3.38
Lead         0.27              0.6             .069
Zinc         0.61              4.2           2.61
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ITU's  SOLVENT RECOVERY  PROCESS  EQUIPMENT
LEASE OPTION.    Our estimated return for leasing and
operation  of the  solvent recovery equipment  based  on an
average of 5000 wipers per week.

1) value of the recovered solvent                 $8,632
an average of 4.15 gallons/100 pound load (ITU actual).
4,316 gallons/year @ $2.00/gallon

2) reduced reportable air emissions               $ 534
4,316 gallons/year x 7.5 Ibs/gal = 32,370 Ibs/yr
32,370 Ibs/yr = 16.19 tons/yr @ $33/ton = $534/yr

3) not having to purchase and operate alternative  $8,000
equipment, ie: centrifuge.                   to   $12,000

4) elimination of the cost of hazardous waste      $156,000
disposal of at least 3 drums/week at a minimum
of $200/drum.

5) Improved  health and safety in your plant,       $?????
reduced fumes, less fire potential, less OSHA risk,  $5,000+
improved fire inspection results.
                                 at least       $  9,166
                             but as much as    $182,166
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 66214    Federal Register / Vol. 62. No. 242 /  Wednesday.  December  17.  1997  /  Proposed Rules

 year, it will no longer be excluded from
 the standards.

 §441.21  Pretreatment Standards for
 Existing Sources (PSES).
   Pursuant to the CWA section
 307(b)(l). indirect dischargers are
 required to comply with pretreatment
 standards for existing sources by three
 years of [the effective date of the final
 rule]. For purposes of this part, indirect
 dischargers must comply with this part
 by three years after [the date of
 publication of the final rule).

 § 441.22  Pretreatment Standards for New
 Sources (PSNS).
   Except as provided in 40 CFR 403.7.
 any new source subject to this part that
 introduces pollutants into a publicly
 owned treatment works must comply
 with 40 CFR part 403 and achieve as
 pretreatment standards for new sources
 (PSNS) the same standards as those
 specified in §441.21 for existing sources
 (PSES).

       TABLE 1 TO PART 441—
      PRETREATMENT STANDARDS
     Pollutant parameter
Bis (2-Ethylhexyl) Phthalate
Ethylbenzene 	
Naphthalene
                            CP—Daily
                            maximum
                              (mg/L)
                                  0.13
                                  1.64
                                  0.23
Tetrachloroethene	         1.71
Toluene 	'        2.76
m-Xylene	 <        1.33
o&p-Xylene 	         0.95
Copper 	         0.24
Lead 	         0.27
Zinc 	 :        0.61
SGT-HEM1  	        27.5

  1 Monthly average  limitation for  SGT-HEM
under CP option is 15.4 mg/L.

[FR Doc. 97-30240 Filed 12-16-97; 8:45 am)
BILLING CODE 6S60-5O-P
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                 Dan T. McGrath




Great Cities Institute, University of Illinois at Chicago
    "An Empirical Evaluation of the Adoption ofP2"
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                       BIOGRAPHICAL SKETCH
Daniel T. McGrath
Professional Positions:
Research Professor, Great Cities Institute, University of Illinois at Chicago and
Coastal Economic Development Specialist with the Illinois-Indiana Sea Grant Program (1998 -
present).
Research Economist, The Energy Resources Center, University of Illinois at Chicago (1996-
1998).
Research Associate, The Great Cities Institute, University of Illinois at Chicago (1994-1996).
Research Associate, The Center for Urban Economic Development, University of Illinois at
Chicago (1992-1994).
Assistant Economic Analyst, Argonne National Laboratory Technology and Environmental
Policy Section, Argonne, Illinois (1991-1992).

Education:
Ph.D. 1996, Public Policy Analysis/Economics, University of Illinois at Chicago.
M.A.I 993, University  of Illinois at Chicago, Economics.
M.B.A..1986, University of Notre Dame, Finance and Management.
B.S./B.A.1983, University of Notre Dame, Mechanical Engineering/History.

Awards and Honors:
1985 Notre Dame/Clark  MBA Scholarship
1992, 1993, 1994 University of Illinois/FMC Corporation Fellowship Winner
1993 UIC/Geldard Academic Award for outstanding graduate student in economics

Publications Related to the Proposed Project:
McGrath, D.T. 1998. Urban industrial land redevelopment and contamination risk. Journal of
    Urban Economics, (in review)
McGrath, D.T. 1997. Lean and green:  an empirical evaluation of firm pollution prevention
    adoption. Report submitted to the Chicago Manufacturing Center.
McGrath, D.T. 1996. A REMI model evaluation of the contribution of the Chicago
    airport system to the  Chicago metropolitan regional economy. Report prepared for the
    City of Chicago Department of Aviation through UIC's Great Cities Institute.
McGrath, D.T. 1994. An analysis of impacts to the State of Illinois regional economy related to
    proposed water pollution rules, R92-8. Prepared as Testimony before the Illinois Pollution
    Control Board. Center for Urban Economic Development (March).

Professional Activities:
Membership: American Economics Association, Midwest Economics Association, Illinois
Economics Association.

Collaborators: Wim Wiewel, John McDonald, Joe Persky, Davis Jenkins,  Daniel McMillen,
Bonnie Lindstrom, Bernard Engel, Jonathon Harbor

Graduate Advisors:
Dr. John McDonald, Department of Economic, University of Illinois at Chicago
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I. Introduction




       One of the more prominent issues currently being debated within the Pollution Prevention




(P2) community is why firms are reluctant to adopt a pollution prevention opportunity despite




clear cost savings by doing so. A recent example of this was Dow Chemical's reluctance to




adopt a program that eliminated a half million pounds of waste that saved $1 million (Greer &




Van Loben Sels,  1997). Why would it not take advantage of this opportunity?  The main reason




given was fundamentally economic - that the P2 project could not compete with other more




financially attractive capital allocation opportunities within Dow.




       The P2 community seems fairly silent on the fact that adopting preventing pollution




practices that fundamentally change the  way a firm accomplishes its production has profound




economic consequences for many stakeholders within a local economy—both positive and




negative. In a recent study modeling the economic impacts of P2 on New Jersey's regional




economy (Robinson, 1996), not only did firms' cost savings have a net positive effect on the




State's output, employment, and personal income, but one of the direct effects of P2 was that the




chemical industry lost substantial income as a result of lower chemical use.  However, these




negative effects of P2 adoption are similar to those that occur for any broadly adopted process




innovation.




       The national P2 community has  been recommended to direct its research towards the




development of a stronger understanding of the fundamental economics behind pollution




prevention adoption. In his keynote speech at the April 1997 National Pollution Prevention




Roundtable Conference, New England Regional EPA Director, John DeVillars, indicated that the




adoption of P2 was linked with the economic situtation facing a firm.  He went on to say that the




P2 community has not clearly identified measures that help firms achieve economic and
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environmental success.  Mr. DeVillars' call for the incorporation of more rigorous, formal




economic analysis in P2 research was echoed by a number of speakers at the NPPR Conference,




the most notable being the Hon. Jackie Aloisi de Larderel of the United Nations Environmental




Program. Her recommendation to the U.S. P2 Community was that a greater fundamental




economic understanding of P2 be developed, which she noted is the direction that P2 is moving




in Europe and that is consistent with the recommendation of the President's Council for




Sustainable Development.




       The general thrust of P2 adoption explanations developed by the US P2 research




community are primarily organizational and managerial in nature.  When confronted with the




apparent failure to achieve broad technological adoption within US firms, prominent P2




researchers have responded with discussions of failures of vision, inadequacies of leadership,




bureaucratic inertia, and subversive co-opting of the true definition of P2 (Hirschhorn, 1997).




These qualitative perspectives may be an accurate and important commentary on management in




US firms and how that impacts how firms conduct business, direct capital investments, and seek




to achieve the environmental compliance mandated by federal and state law. However, this




discussion does not assist in developing an understanding of the fundamental economics behind




pollution prevention. Until now there has been little focused discussion or empirical analysis of




P2 as process innovation - the changing of a production process to achieve improved production




and/or lower costs. Most studies on the determinants of P2 adoption have been anecdotal or




based on incomplete survey research analysis. The purpose of this paper is to begin this




discussion—to restate the problem of P2 adoption in a way whereby the economics of process




innovation might provide some insight to its adoption by firms.
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       In addition to the development of a process innovation framework for P2 adoption, this




report presents the results of cross-sectional analysis utilizing this framework to identify the firm




and industry specific factors contributing to P2 adoption from an investigation of data provided




by the Industrial Technology Institute's (ITI) Benchmarking Database.  Following is a broad




review of literature discussing process innovation. Next is a section describing the ITI




Benchmarking Database used in this analysis. The final section is a discussion of the empirical




results and their implications for public policy.







II. Literature Review




       The topic of pollution prevention as distinct from pollution abatement or control has yet




to be discussed  in any substantial way in the economics literature, though its absence has been




recognized and  commented on (Helfand, 1992; Robinson, 1996). Applied P2  literature




discusses a number of reasons why firms might not be willing to adopt P2 opportunities despite




their clear cost savings. The general view in this body of literature is that the primary limitation




to P2 adoption are organizational/managerial in nature: firm managers and/or decision makers




lack or are unwilling to acquire the necessary information to make a full assessment of the




potential associated  cost savings (Bierma & Waterstratt, 1995;  Bartlett, et. al,  1995).




       The first article specifically addressing the economics of pollution prevention as defined




and understood  by the P2 community is Helfand (1992). In this article, Helfand presents results




and policy implications from a standard profit-maximizing firm model using two inputs: a




polluting input (for which reduction would constitute pollution prevention) and an  abating input




(pollution control technology), both of which are assumed to be productive inputs.  The




applicability of this model to the P2 issue is that it explores the various outcome measures
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(output, profits, and pollution emissions) resulting from the application of four different public




policies, one of which requires firms to limit their use of the pollution input below a certain




level—i.e. source reduction.  Helfand's  primary contribution is that, given a unchanging




production function, economic theory shows that mandating source reduction will achieve




optimal pollution abatement levels, but it will also result in lower economic performance of the




firm.  That is, profits will be lower than in the case where the firm is left to decide how it is to




achieve required abatement performance standard.




       In Helfand's  static model, profits can only increase if the firm changes its technology. If




pollution is costly to  a firm, there is an incentive for the firm to pursue process innovations to




reduce those costs (and pollution) in the same way that firms try to reduce other normal operating




expenses. This kind of change can only be represented in Helfand's model as a change in the




firm's production function; however, this is outside the scope of her paper.  Although not




addressing process innovation in her model per se, Helfand does recognize the fact that




understanding P2 as a process of technical innovation and diffusion is an important idea that has




yet to be addressed in the literature.




       Helfand's paper views the question of why a firm might be unwilling to capitalize on  a




clear cost-saving P2 opportunity in more general terms - what limits a firm's adoption of any




kind of process innovation, since there are fundamental economic reasons for not adopting




technologies instantly? The speed at which process innovations are adopted can depend on the




level of cost savings achieved, the cost of the investment, the level of uncertainty associated with




the new process, interest rates, capital constraints, and industry demand. Additionally, acquiring




new process technology can involve major human capital investments, worker and manager
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retraining,  and often represents a direct challenge to the inertia of a bureaucracy that may be




already meeting its stakeholder expectations.




       There is a large body of literature investigating the question of innovation and its role in




the process of technological change.  The standard text outlining the theory and empirical




literature relating to technological change is Stoneman (1983).  Generally, technological change




is understood as a three step process. 1) Invention—the creation of a new process or product




usually patented;  2) Innovation—the first commercialized application of a new invention; and 3)




Diffusion—the process by which an innovation spreads across the market and is adopted by




competing firms.  With regard to process innovation, theory suggests that new processes are




more likely to yield greater cost reductions (Stoneman, 1983, p. 264). Thus, innovation and




diffusion of new technology is more likely to occur when it saves on a production factor input




that has a higher share in total costs than when it has a smaller share, and those factors




determining the magnitude of these costs for a firm—such as the firm's output level, the factor




input prices, and interest rates, are the same factors that signal innovation of new technology. A




classic example is the tremendous innovative response in the U.S. following the Arab oil




embargo of 1973.




       Another excellent summary discussion of innovation is Tisdell (1995a). In this article,




Tisdell outlines the economics of process innovation and discusses some general limitations on




diffusion. Generally, competition among firms is viewed as an important determinant of R&D




activity and, as  such, an important determinant of innovation. Firms are in competition to gain




market share by developing and innovating new cost-saving processes, and this competitive




process determines winners and losers, leaders and laggards. Tisdell identifies six important
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economic factors that current economic theory shows to be significant determinants of

innovation1:

       1.  The greater the initial size of the market, the greater likelihood of innovation by firms
       in the market.

       2.  The greater the expected growth rate of a market, the higher the likelihood of
       innovation by firms in the market

       3.  The higher the discount rate on capital investments, the lower the likelihood of
       innovation.

       4.  The longer the firm's planning horizon, the greater the incentive to innovate

       5.  The higher the marginal productivity of the firm at reducing its unit costs of
       production the greater the likelihood of innovation by that firm.

       6.  The more inelastic the demand for a firm's product, the greater the likelihood of
       innovation2
II.A. Innovation in Pollution Control

       There are a number of papers investigating innovation in pollution abatement

technology, most of which are focused on the impact of different public policies on the rate of

abatement technology change.  Magat (1978) presents one of the first theoretical examinations of

the impacts of differing environmental policy regimes—in this case an effluent tax versus a fixed

effluent standard—on inducing advancement in abatement technology.  Polluting firms react to

both these policies by reducing the levels of production and/or changing their production process

to one that is less polluting per unit of output. Environmental policy also affects the firm's

investment decisions  concerning the extent and type of innovations that are developed and
' The factors identified refer to their effects on R&D expenditures. The assumption here is that the higher the R&D
expenditure by a firm, the higher the rate of innovation.  The six factors are identified from an investigation of the
innovation possibility frontier model developed by Dasgupta & Stiglitz (1980).
2 When a firm has faces inelastic demand for its product, this means that large price changes for its product result is
generally small changes in the quantity demanded. In this situation, given a relatively stable market, the firm is
more likely to be a cost minimizer—seeking ways to reduce its costs of production.
                                                                                           7
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diffused. As a result, it also affects the rate (the amount of innovation over time) and direction




(advancing production technology vs. abatement technology) of technical advance, as measured




by the ratio of R&D expenditures to total expenditures. Magat's results demonstrate that there




are two important differences between these two policies. First, over time an effluent tax can be




shown to increase the amount of effluent produced for most firms, whereas an effluent standard




ensures a fixed effluent path with advancing technology. Second, and of most relevance here,




the model implies that if labor substitutability is difficult, a constant effluent standard promotes




an increase in the rate of advance in abatement technology whereas an effluent tax leads to a




decline in the rate of abatement technology advancement.




       Milliman & Prince (1989), however, support a different conclusion. These authors




examine the incentives to promote pollution abatement technology change under five different




regulatory approaches: emission standards, emission subsidies, emission taxes, free marketable




permits, and auctioned marketable permits. Their model investigates the dynamics of diffusion




of technology and how these five policy approaches affect these dynamics. The authors conclude




that emission taxes and auctioned permits provide the highest incentives to promote innovation




and diffusion of abatement technology and are comparatively higher that the other three policy




regimes.




       Downing and White (1989), in theoretical analysis of the impact of various institutional




arrangement on pollution control innovation, provide a simple framework for discussing the




economic constraints to process innovation in pollution prevention. Applying this model, if one




assumes that the environmental policy is one of command and control (the current regulatory




approach in the U.S.), then the firm will pursue innovation up to the point where it meets its




environmental compliance requirements. Emission standards for a given firm are depicted as a
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fixed emission requirement (line AC in figure 1). In figure 1, the marginal cost of reducing




emissions for the firm is curve MC. If the regulating body is pursuing social efficiency in




pollution control and knows the marginal social benefit of reducing emissions, depicted as fixed




benefit P, in figure 1, then the regulating body should set the emission control level at the point




of social optimum. This is point A— the point where marginal benefit equals marginal cost.




       Assuming that a firm is in compliance and is operating at point A on its marginal




abatement cost curve, any technology that reduces the marginal cost of abatement, line MC' in




figure 1, will provide the private economic benefit to the firm (area OAB). However, the firm




will have no incentive to adopt the new technology and operate at point B unless the present




value of the net benefits, OAB, exceeds the cost of investment in the new technology, X.  Also




note that there is no incentive for the firm to operate at the new social optimum, point D on the




new marginal cost curve, MC', unless the governing body responds to the new technology




opportunity by imposing a new, more stringent standard, line DE on figure 1. The only incentive




to produce at point D is if the additional costs imposed by acquiring the new abatement




technology (area CBDE) and the initial investment, X, (not represented on the graph) are less




than the current abatement costs, area OAB.




                                       Figure 1
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                                                              MC'
                        O                   50%   C       E    100%
                               Percent Reduction of Emissions

       Downing and White's simple model presents very clearly that incentives to adopt cost

saving innovations in pollution control in the presence of a fixed abatement standard are

fundamentally economic, and the likelihood of adoption of a new process innovation that reduces

pollution is a function of the net present value of the cost savings achieved by adopting the

innovation—that is the present value of the cost savings achieved by adopting the new process

less the cost of the investment, X.

                           Prob(P2 Adoption) =/( NPV).

       Fixed abatement standards provide no incentive for firms to adopt cost saving

opportunities above those that bring the firm into compliance,  Thus, the economic determinants

of pollution prevention adoption are those factors determining the net present value of the

pollution prevention opportunity.  Also, for any firm, if the reduction in marginal costs resulting

from adopting a new  technology is not well defined or is uncertain, the likelihood of adoption by

the firm is reduced even further.


II.B. Economic Competence
                                                                                      10
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       As mentioned previously, the P2 literature discusses many valid non-economic reasons




why firms may be unwilling to adopt P2 opportunities, with most of those reasons centering




around the managerial ability of the firm's decision makers. If a firm lacks the ability to




accurately assess cost savings in pollution abatement, this increases the uncertainty for the firm




to accurately assess a net present value for any pollution prevention opportunity.  This notion is




not inconsistent with the idea of "economic competence" expressed in the evolutionary




economics literature (see Tisdell, 1995b), which state that innovation requires not only the




generation of a new cost-saving idea, but economic actors must have the capability to take




advantage of the innovation.  Carlsson and Stankiewicz (1991) posit that a firm's economic




competence—the ability to perceive opportunities and adjust its performance accordingly—is an




important determinant of the innovation process and a determinant of which innovations will




survive in a competitive market. It is important to emphasize that the notion of economic




competence—an idea similar to "entrepreneurial capital"—is a very difficult measure to specify;




though the implication is clear - firms with greater economic competence are more likely to




adopt pollution prevention opportunities. A number of researchers have provided evidence that




larger firms are more likely to adopt newer, more  capital-intensive technologies (Kelley and




Brooks, 1991; Dunne, 1994).  The argument is that larger firms have and can maintain a higher




stock of human capital and are thus more capable  of recognizing and capitalizing on an cost-




saving opportunity.  Thus, larger firms tend to be  more likely than smaller firms to adopt a




pollution prevention opportunity.




       In a theoretical article, Teece (1994) posits that a firm's organizational structure (formal




and informal structures and hierarchies within the firm), as well as the network of external




linkages they possess have a direct affect on the firm's innovation activity. However, pollution
                                                                                       11
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prevention opportunities cross over both of his innovation classifications—"autonomous"




innovations which fit well into the existing structure and "systemic" innovations that present




more direct challenges to the existing firm structure. It is not clear if any specific firm structure




emerges as being the most conducive to P2 adoption, but the thrust of Teece's view is clear.




Innovation can be significantly determined by firm structure and encouraging P2 must take into




account the broad and complex nature of the organizational structure of small and large firms.




This view of organizational structure and external linkage  as a critical factor in facilitating P2




adoption is very consistent with much of the discussion in the P2 literature. Specifically, Bierma




and Waterstraat (1995), in a survey investigation of P2 adoption among metal fabricators, find




information linkages —particularly supplier-firm linkages—to be a critical factor in successful




P2 adoption in the metal fabrication industry.




       Doms. et. al. (1995) in a paper identifying the determinants of firm exits from an




industry, postulate that the exploitation of advanced technologies by a firm may be proxy for




unobserved managerial ability.  If firms with superior management are best able to fully exploit




advanced production techniques, then plants with superior management would be more likely to




adopt pollution prevention opportunities.  Antonelli (1993) suggests that capital investment in




advanced technology correlates positively with increased productivity. Thus, firms with higher




managerial ability or "economic competence" might be more likely to exhibit higher rates of




productivity. If economic competence is a fundamental determinant of a firm's adoption of a




pollution prevention opportunity, as is suggested in the P2 literature, then a positive relationship




between P2 adoption and firm productivity would exist.




       However, one must keep in mind that the adoption of a P2 opportunity, or any new




technology that reduces a firm's costs, might by itself contribute to a firm's increase in






                                                                                       12
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productivity.  Myers and Nakamura (1980) explore the impact of fixed time schedules for




pollution abatement on firm productivity.  The authors develop a dynamic model whereby a firm




manager has a range of choices regarding input proportions and output levels until the investment




in production equipment is made.  Thereafter, the firm's plant and equipment are fixed for their




useful life. The implications of this model are that the imposition of pollution abatement




requirements lead to accelerated obsolescence of existing plant and equipment, creating a short-




term increase in labor productivity for the  firm.




       In sum, a firm's adoption of a process innovation that reduces pollution control costs, i.e.




a pollution prevention opportunity, is a function of the net present value of the savings achieved




by the adoption of an innovation. However, without the ability to directly observe a measure of




this net present value for a firm, as discussed above, a number of researchers have identified a




collection of industry-specific and firm-specific characteristics that might signal the magnitude




of this value and, as such, signal the adoption of an innovation.  With respect to industry-




specific characteristics, process innovation is hypothesized to be correlated with the size and




expected growth rate of the industry's market (Tisdell, 1995).  With respect to firm-specific




factors, those characteristics that increase the scale of the net present value of any cost-saving




opportunity are hypothesized to correlate with  firm P2 adoption. Larger firms are more likely to




adopt newer technology and process innovations (Dunne, 1994). More capital intensive firms




are likely to have lower capital costs and are more likely to replace capital with newer, more




modern plant and equipment (Doms et. al. 1995), while firms with a higher share of toxic




disposal costs to total costs are more likely to have an incentive to reduce those costs with new




process innovation (Stoneman, 1983).
                                                                                       13
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       Aside from these strictly economic factors, firms with greater managerial ability or




"economic competence" have a higher likelihood of identifying and responding to cost-saving




opportunities and, it is hypothesized, that some measure of a firm's initial productivity might be




a good proxy for this unobserved variable (Doms, et. al, 1995).









II.C. The Model and Hypothesis




        This paper hypothesizes that the above-mentioned industry-specific and firm-specific




characteristics identify underlying differences in a firm's capability and incentive to identify and




reduce costs, given a hypothetical cost-saving opportunity. The empirical technique to test this




hypothesis is a probit regression of the discrete dependent variable, P2 ADOPT, which takes on




the value of one if a firm adopts a pollution prevention opportunity and zero if it does not, and is




generally of the form:










       Prob(P2ADOPT) = /(industry-specific characteristics, firm-specific characteristics,





                            firm managerial capability)




       Prob(P2ADOPT) = /( market size,  firm market share, industry, firm size,





       capital-labor ratio, toxic-waste cost share, initial firm productivity at time of innovation,




       vector of other variables which determine firm economic competence)









       If a measure of the firm's initial productivity is a significant determinant of P2 adoption,




then this lends support to the view that managerial capability is a limiting factor. Also, if other




industry-specific and firm-specific variables are statistically significant in addition to initial total
                                                                                       14
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factor productivity, then it is possible to separate the impact of the economic determinants of P2

adoption from the vector of factors used as a proxy to measure managerial ability.



III. Description of Data

       The dataset for this study is micro-level data of firm characteristics produced by the

Performance Benchmarking Service at the Industrial Technology Institute (ITI) in Ann Arbor,

Michigan. The dataset consists of 1,662 manufacturing companies nationwide. These are

typically smaller firms with sales of over a million dollars. The information is provided to ITI

directly from the firm through questionnaires that were administered to these firms in 1996.

From these questionnaires, data on firm background, general business, design and

manufacturing, scheduling and delivery, workforce and quality assurance were gathered, under

condition of anonymity.

       Of main interest in our study on pollution prevention adoption by U.S. manufacturing

companies, are the pollution prevention variables within the 1996 questionnaire:

       1. Does the firm use or dispose of hazardous or toxic material through its production
       process?
       2. Has the  firm tracked the use and disposal of these hazardous materials?
       3. Has it re-engineered its product(s) or manufacturing in order to reduce toxic material?
       4. Does it have information on the dollar amount of disposal costs of these hazardous
       materials?

       Most of the variables in the dataset can be categorized in 2 separate values - current value

in 1996 and value from 2 years earlier (1994). This enables short-term comparisons of these

variables.  The total number of records that had complete data to investigate the relationship

between P2 adoption and the variables identified was 312 records. Complete data for all

variables is required in a probit analysis (see Appendix 1 for a discussion of the probit analysis),
                                                                                      15
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and missing data was the only reason for the exclusion of a record. Of these total 312 firms, all




require the use or disposal of toxic waste. With respect to the most important P2 question—




whether the firm had changed their product formulation or production process to achieve a




reduction in toxic use or byproduct—205 firms responded yes and 107 firms responded no.









IILA. Discussion of Variables in Probit Model




       The dependent variable in the probit model is P2ADOPT, a dummy variable taking on the




value of 1 if the firm reports a change in its production process or product formulation to




facilitate the reduction of toxics use or byproduct and 0 if not. There are ten independent




variables included in the probit model.  The first seven of the independent variables listed here




are firm-specific characteristics at beginning of two-year time period.  These variables will be




tested separately to produce a "predictive" P2 adoption model to identify those initial




characteristics that signal P2 adoption during the 2-year period. Also, depending on the model




specification,  industry dummy variables will be included in the model to control for industry




effects.  However, not all industries are represented in the dataset.  Where industry dummy




variables are included, the variable INDSALES will be excluded, as there may be a strong




correlation between INDSALES and the industry dummy variables.




The definitions of these variables are  as follows:




1.  TRACKU94 - Dummy variable which takes on the value of 1 if the firm reported tracking its




use and disposal of toxic material in 1994.  If not, the value is 0.




2.  HAZRAT94 - The ratio of the firms reported total hazardous or toxic waste disposal and




treatment costs in 1994 to the firm's total reported material, parts, services, and utility costs.




3. VAPE94 - The firm's calculated value added per employee in  1994.






                                                                                     16
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4. CLRATIO - The firm's capital/labor ratio. This variable is calculated as the firm's reported

replacement value of its machinery divided by the firm's total payroll in 1994.

5. EMPCODE - This variable identifies the firm size as measured by the number of employees.

EMPCODE takes on the value of 1 if the firm has 50 employees or less. It takes on the value of

2 if the number of employees is between 51 and 100.  It takes on the value of 3 if the number of

employees is between 101 and 500, and it takes on the value of 4 if the number of employees is

between 501 and 1000.

6. MKTSHR - This variable identifies the firms market share which is calculated as 1994 firm

sales divided by 1994 value of industry shipments.

7. INDSALES - The total value of 1994 firm industry shipments from the 1995 Annual Survey

of Manufacturers (US Department of Commerce, 1995).

       The next three variables are qualitative firm performance variables at the end of the two-

year period. These variables have been chosen to signal those firms that may be better managed.

These variables are:

8. TRACKU96 - A dummy variable essentially identical to TRACKU94; however it identifies if

the firm reports tracking in 1996—at the end of the two-year period.

9. MODEOUIP - A dummy variable which takes on the value of 1 if the firm reports that it had

purchased new equipment or upgraded its equipment within the 2-year period, else the value is 0.

10. ISO9000 - A dummy variable which takes on the value of 1 if the firm reports that is had

received ISO 9000 certification3 during the 2-year period.
3 ISO 9000 is a series of quality standards (published by the International Organization for Standardization -ISO)
which define a framework of minimum requirements for the implementation of quality systems to be used in
contractual situations identical to the EN series of standards (EN 29000) and other national series. The ISO 9000
standards have been adopted worldwide as suitable criteria for assessment and registration of companies by
independent accredited third-party organizations.
                                                                                      17
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       The last two variables are quantitative performance variables which have been chosen to

measure firm productivity and cost-reduction performance at the end of the two-year period.

These are:

11. DELHAZCR - The change in total real hazardous waste disposal and treatment costs in

1994$ over the two-year time period.

12. DELRVAPE - The change in real value added per employee in 1994$ over the two-year

time period.

       Separating these firms into two groups, some interesting statistics emerge.  On average,

P2 adopting firms when compared to non-adopters are:

       1.  more likely to track their use and disposal of toxic materials
       2.  have higher hazardous waste disposal costs and a higher share of hazardous waste
          disposal costs to total costs.
       3. higher sales and larger number of employees.
       4. lower hazardous waste disposal cost growth.
       5. higher capital/labor ratio.
       6. slightly lower measures of initial labor productivity.
       7. higher total industry sales
       8. larger market share.

       The general statistics of a number of variables for these 312 firm records which have been

divided into P2 Adopters and Non-Adopters is presented in Table 1.
                                                                                    18
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Table 1 - Descriptive Statistics
Total Sample
N=312
Variable
TRACKU96
TRACKU94
DELHAZCR
HAZRAT94
EMPCODE
CLRATIO
MKTSHARE
INDSALES
ISO9000
MODEQUIP
VAPE94
DELRVAPE
Mean
0.885
0.795
$998
0.0043
2.387
1.450
0.0032
$19,522
0.035
0.721
$ 65,830
$ 3,938
Std. Dev
0.320
0.404
$ 24,322
0.011
0.666
1.749
0.0095
$26,800
0.184
0.449
$ 33,830
$ 15,522
P2 Adopters
N=205
Mean
0.907
0.810
$954
0.0056
2.493
1.630
0.0039
$21,825
0.049
0.771
$ 64,973
$4,925
Std. Dev
0.291
0.394
$29,751
0.013
0.661
2.059
0.0114
$29,510
0.216
0.421
$ 33,382
$15,108
Non-Adopters
N = 107
Mean
0.841
0.766
$1,083
0.0021
2.186
1.106
0.0018
$15,108
0.009
0.626
$67,472
$ 2,049
Std. Dev
0.367
0.425
$ 5,680
0.003
0.631
0.793
0.0035
$ 20,035
0.097
0.486
$ 34,771
$16,191
IV. Empirical Results

       In this section, patterns of pollution prevention adoption and firm characteristics,

qualitative outcomes which signal firm performance, and productivity measures focusing on the

role of a firm's hazardous waste cost ratio in predicting pollution prevention adoption are

examined.  As discussed above, the approach is to estimate a set of pollution prevention adoption

equations using a probit model.

       Table 2 reports the results from the probit P2ADOPT regressions using the 317 plant

observations from the ITI data. All the three equations include controls for industry effects by

including dummy variables based on ITI's 25 industry classifications4. The probit results from

all the 21 industry group dummy variables are not included in Table 2; however, those industry

groups for which the results are significant are included.   Standard errors are in parenthesis.

Variables with a double asterisk identify the variable as being significant at the 5% confidence
4 Three industry groups were not represented in the data. Also, industry group 6, metal forming and fabrication,
was selected as the reference category as it was the most represented industry in the dataset. Thus, the dummy
variable for industry group 6 was excluded from the probit analysis.
                                                                                          19
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level. Variables with a single asterisk identify variables that are significant at the 10%




confidence level.




       The first column identifies the results of Model  1, which includes basic firm




characteristics at the beginning of the two-year time period (which is the year 1994) in the data.




This equation is essentially the "predictive" P2 adoption model, that identifies those firm




characteristics reflective of the firm's cost structure and managerial performance that  best




predict a firm's adoption of pollution prevention measures. The probit results of Model 1




indicate that larger, more capital-intensive firms with high hazardous waste costs as a share of




total costs have the highest likelihood of P2 adoption. Firm size, as identified by the number of




employees (EMPCODE), the firms capital-labor ratio (CLRATIO), and the firms initial




hazardous waste cost ratio are all significant determinants of a firm's P2 adoption while the signs




of the coefficients are consistent with expectation. These three variables were selected as




indicators of a firm's cost structure, since actual cost-savings from a firm's P2 adoption is




unknown. Whether or not a firm was initially tracking its hazardous material usage




(TRACKU94) is significant.  However, a firm's initial productivity, as measured by the firm's




value added per worker (VAPE94), is significant. However, surprisingly, its sign is negative.
                                                                                      20
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Table  2
Pro bit  Model:   Dependent Variable is  P2ADOPT
Variable

Intercept
TRACKU94
1 if the firm tracked its use
and disposal of hazardous
material in '94, 0 otherwise
HAZRAT94
Ratio of hazardous waste
disposal costs to firm total
costs
VAPE94
Value added per employee in
1994
CLRATIO
firm Capital/Labor R atio
EMPCODE
1 if employees < 50,
2 if 50 < employees < 100, 3
if 100 < employees < 500, 4 if
500 < employees < 1000
MKTSHARE
Firm Market Snare in 1994
INDSALES
Total value of firm's industry
shipm ents in 1 994
TRACKU96
1 if the firm tracked its use
and disposal of hazardous
material in '96. 0 otherwise
MODEQUIP
1 if the firm purchased new
equipment or upgraded its
equipment Between 1994 and
1996, 0 otherwise
ISO9000
1 if the firm had received
IS09000 certification between
1994 and 1996, 0 otherwise
DELRVAPE
Change in real value added
per employee in 1994$ over
2-year period
DELHA2CR
Change in real hazardouse
waste disposal costs
Significant Industry Group
INDGRP8
Heat Treating, Coating, &
Plating
INDGRP12
Computer, Communications, &
Electronics Parts
INDGRP14
Automotive and Heavy Trucks
Log Liklihood
Likhhood Ratio Index
Model 1
N = 312
-0.568*
(0.352)
0.051
(0.203)
40.941**
(17.077)
-4.623 E-6*
(2.49 E-6)
0.123*
(0.070)
0.321**
(0.141)
25.219
(19.445)
6.958 E-6*
(3.661 E-6)





Variables



-180.114
0.116
Model 2
N = 312
-0.9896**
(0.4210)
-0.034
(.228)
37.610*
(21.338)
-2.343 E-6
(2.78 E-6)
0.148*
(0.086)
0.445**
(0.136)









1.256**
(0.606)

-171.382
0.146
Model 3
N = 312
-1.717"
(0.519)
-0.462
(0.299)
40.027*
(22.333)
-3.691 E-6
(2.90 E-6)
0.139*
(0.084)
0.314**
(0.145)


1 279**
(0.454)
0.374*
(0.195)
0.977*
(0 572)



1.216*
(0 634)
1.240**
(0.621)
0.680*
(0.400)
-163.454
0.185
Model 4
N = 312
-1.824**
(0.529)
-0.449
(0.301)
43.196*
(22.702)
-3.119 E-6
(2.98 E-6)
0.136*
(0.084)
0.324**
(0.146)


1.276**
(0 458)
0.374*
(0.198)
0.900
(0.573)
1.11 E-5*
(6.07 E-6)
-4.98 E-6
(5.58 E-6)

1.245**
(0 630)
1.352**
(0 629)
0 696*
(0.405)
-161.370
0.196
Note  Probit models 2, 3, and 4 include 21 Industry Group control variables  Only significant industry groups are shown
The liklihood ratio index measures goodness-of-fit analogous to Rmeasure in OLS Regression models (Greene 1990)
Standard Errors are presented in parentheses  * signals significance at 10% level  " signals significance at 5% level
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As previously discussed, these latter two variables were chosen as signals of a firm's




performance, i.e. testing whether better-run, more productive firms might be more likely adopt a




pollution prevention opportunity.  The data show the opposite.  It appears that firms with lower




initial economic performance are the one's more likely to adopt a P2 opportunity. This result




might be indicative of firms that utilize environmental cost savings as ways to stay competitive




in the market and do so only when productivity is low compared to peer firms.  Also, consistent




with theory, the size of the industry, INDSALES, as measured by the magnitude of industry




sales, is a significant determinant of P2 adoption. The larger the industry market in terms of




sales, the more likely the firm is to adopt P2. However, the firm's market share, MKTSHARE,




is not significant.




       Model 2 is similar to Model 1; however, specific industry dummy variables were




included to control for industry effects. Because of this, the industry variables, INDSALES and




MKTSHARE, were removed.5  The results of Model 2 are generally consistent with those of




Model 1; however, the measure of initial firm productivity (VAPE94) is no longer significant,




though its sign remains the same. Additionally, firms in Industry 12 (computer/electronics




manufacturers) appear significantly more likely to adopt P2 opportunities compared with all




other industry groups. Thus, without knowing any other performance/quality outcomes from the




317 firms in the dataset, consistent with innovation theory, those initial firm characteristics




indicative of high hazardous waste disposal costs, rather than those initial firm characteristics




indicative of better firm management performance, are strongest indicators of P2 adoption.




       The third column identifies probit results for Model 3, which adds additional qualitative




performance outcomes to the original predictive model, Model 2.  Specifically, whether or not




the firm modernized its plant and equipment over the 2-year period (MODEQUIP), whether the
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firm reported tracking it hazardous material usage at the end of the 2-year period (TRACKU96),




and whether or not the firm obtained ISO 9000 certification during the 2-year period (ISO9000).




These variables were chosen to signal those firms that may have more progressive management




teams. The results of Model 3 indicate that all three of these variable are significant.  With




regard to the TRACKU96, this result support the assertion that requiring hazardous material




tracking improves the chances of a firm adopting a P2 opportunity. It is important to emphasize




that the inclusion of these qualitative outcome variables  in Model 3 increase the significance of




the firm's hazardous waste cost ratio versus that in Model 2, thereby strengthening the view that,




although it may be the case that more progressive management exhibit a higher likelihood of P2




adoption, it is still the firm's cost structure that is the most important component in predicting




process innovation. Lastly, in Model 3 a significant positive correlation of industry groups 8, 12,




and 14 (coating & plating, computer/electronics manufacturers, and automotive/heavy truck




manufacturers) and P2 adoption is exhibited.




      The fourth column identifies probit results of Model 4 which adds to Model 3 two




quantitative performance variables, the change in real hazardous waste costs (DELHAZCR) and




the change in real value added per employee (DELRVAPE). These variables were added to test




whether P2 adoption is correlated with measurable quantitative improvements in the firm's




performance while maintaining significance of variables identified as significant in Models 2 and




3. The variable DELHAZCR is not significant.  This result should not be interpreted as that P2




adoption did not achieve cost reductions for these firms, as it could be the case that the adoption




of a P2 opportunity slowed a rapid growing cost for the firm. Unfortunately, there is no




statistical evidence that, among this group of firms, P2 adoption is correlated with measurable




reductions in a firm's total real hazardous waste disposal costs. The significance of the change in






5 MKTSHARE was not significant when included in Models 2, 3, and 4.                                23
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real value added per worker, DELRVAPE, however, provides evidence that P2 adoption is

correlated with improved firm labor productivity as measured in changes of real value added per

worker. It is important to emphasize here that one cannot infer the direction of causality between

these two variables. This result is consistent with the theoretical result identified by Myers and

Nakamura (1980) that shows adoption of a process innovation can result in a short-run

improvement in labor productivity. It is not clear whether P2 adoption is the cause of these

improvements in productivity or whether the better-run, more productive firms are the ones

more likely to adopt P2. A separate analysis of a regression model with a measure of the firm

productivity gains as the explanatory variable would be required to provide a more systematic

answer to this question. However, the preservation of the significance of the predictive and

qualitative outcome variables is encouraging evidence that supports the assertion that P2

adoption improves firm financial performance. Additionally, the significance of industry groups

8, 12, and 14 is preserved. Industry group 3, printing, is almost significant.  Model 4 is able to

accurately predict P2 adoption 46% and P2 non-adoption only 7% of the time, for a total of 53%

predictive accuracy. The predictive power of this model would be much greater had a variable

identifying the specific cost savings for each P2 opportunity been available.

       The primary contribution of these results are that they identify robust variables that are

correlated with P2 adoption, and that these relationships are consistent with expectations and

economic theory concerning process innovation. The variable with the most explanatory power

is the firm's initial hazardous waste cost ratio (HAZRAT94) which accounts for about 4% of the

models total 20% explanatory power6. The firm's  number of employees (EMPCODE) has the
6 The overall explanatory power of Model 4 is about 20%, which is very good for a probit model. The log liklihood
ratio index, a measure for a probit model that is similar to the R2 statistic for a ordinary least squares regression
model, is 0.196 for Model 4.
                                                                                       24
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second-most explanatory power, accounting for 3%.  The addition of the industry group variables




contributes 7.5%.




       Looking more closely at the difference in labor productivity between the two groups of




data, firms that adopted P2 within the 2-year period show, on average, an increase in real value




added per employee $4,900 (25.6% greater than the average).  Firms that did not adopt P2,




exhibited increases in real value added per employee on the order of $2,000 (44.4% below the




average and 59.2% below P2 adopters). This is a significant difference. However, from the




probit model, the marginal relationship between changes in real value added per employee and




P2 adoption is slight. The predicted increase in the probability of P2 adoption from the non-




adopter DELVAPE mean of $2,000 to the adopter mean of $4,900 is an increase of only 1.6%.




Thus, the contribution of this variable to the model's explanatory power is relatively low.




       Figure 2 shows the relationship between the probability of P2 adoption as predicted by




Model 4 at the mean value for all the variables. The probability of P2 adoption at a hazardous




waste disposal cost of zero—analogous to eliminating the variable from the model—produces an




average probability of about 70%.  This is mostly determined from the fact that P2 adopting




firms are a majority in the dataset.  Nonetheless, the probability of P2 adoption approaches 90%




at a cost ratio of about 2.2%.  Converting this percentage to a dollar value, on average, this 2.2%




represents approximately $164,000 in hazardous waste costs or about $1,200 dollars per




employee for an average firm of 140  employees.  However, the relationship of P2 adoption and




the firm's initial hazardous waste cost ratio is much more pronounced for small firms (50




employees or under). This relationship is also presented in Figure 2. The model predicts  that for




a firm to have a 90% probability of P2 adoption the cost ratio needs to approach 3.2%. In the




dataset of 312 observations, there are 25 firms that represent this categorization, four of which





                                                                                     25
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reported being P2 adopters. This ratio represents for this group, on average, only about $21,600

in hazardous waste costs. However, on a per employee basis, this figure represents about $ 1,660

per employee for an average small firm of about 13 employees. Thus, the model predicts that the

incentive threshold to adopt P2 is much higher for small firms than for the average firm when

viewed on a per employee basis.
                      Probability of P2 Adoption as a function of Firm's
                             1994 Hazardous Waste Cost Ratio
                                                                         -Average Firm
                                                                         . Small Firm
              o . o - o-~  o-
                           o
                               o  o  o  p     o  o
                             Hazard. Waste Cost Ratio
                                                       ex  o
V. Conclusion


       The results of an empirical analysis of firms that reported adopting and not adopting P2


opportunities show that large, more capital intensive firms with high hazardous waste cost are


more likely to be P2 adopters. The variable that is the most significant determinant of P2


adoption is an economic variable:  the share of the firm's hazardous waste costs to its total costs.


On average,  firms with a hazardous waste cost ratio of 2.2% or higher have probabilities of P2


adoption 90% or greater.  However, the results also provide evidence that there are qualitative
                                                                                      26
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differences among firms that signal P2 adoption. Firms that have purchased new or upgraded




their production equipment, or have obtained ISO 9000 Certification are more likely to adopt P2.




This is loose evidence to support the view that perhaps more progressive, better managed firms




and those whose managers have a higher level of education are more likely to be P2 adopters.




Additionally, analysis of the predictive model provides a scale for possible financial  incentives to




facilitate the adoption of pollution prevention opportunities by smaller firms. The results of the




probit model predict that small firms that have hazardous waste cost ratios on the order of 3.2%,




or on average about $1,660 per employee are 90% likely to adopt a P2 opportunity.




       A second important result is that there is evidence showing a positive relationship




between P2 adoption and increases in  firm labor productivity. It must however be emphasized




that, at least at this point, the direction of causality is uncertain.  After controlling for those firm




characteristics that identify higher firm hazardous waste disposal costs and that might signal




better, more progressive management, real increases value added per employee is a significant




determinant of the probability of P2 adoption. Within the dataset of 312 firms, P2-adopting firms




have increases in labor productivity well over double those firms that reported not adopting P2.




       In the majority of reports within  the P2 literature identifying P2 barriers in small firms,




the primary barrier generally is identified as the firm's measurement of its true hazardous waste




costs. The results of this study support this view. Increasing a firm's capability to accurately




assess its true environmental costs will likely increase the firm's adoption of P2, if the institution




of better environmental accounting increases the firms environmental cost to total cost ratio.




There is an awareness among P2 practitioners that more accurate accounting of environmental




costs may not be enough to bring a firm to adopt P2. Better environmental accounting will not
                                                                                      27
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ensure that a given project will be profitable or provide enough cost savings to pass a firm's




innovation cost threshold.




       In addition to encouraging better environmental accounting within the industrial




community, P2 practitioners should investigate the importance of firms obtaining the




appropriate market signals with regard to their environmental waste costs. It is generally




accepted that the market costs of hazardous waste to a firm is less than the true cost that the




hazardous waste imposes on society and on ecosystems. If the market price the firm faced in




hazardous waste disposal more closely reflected the true societal cost, the proper innovation




response by firms would be more swift. There is strong support for the view that a firm's




innovation response is driven primarily by the cost structure it faces. The P2 community should




investigate its role as not only one of promoting policies that encourage process innovation




through better environmental accounting and management education, but also one of the




promotion of financial and economic policies that provide incentives for firms to innovate.




       This research is also the first empirical study to identify evidence of a direct relationship




between P2 adoption and increases in firm labor productivity.  As such, it provides some support




for the view that developing policies that create economic incentives for P2 innovation might, in




addition to accomplishing the environmental goals sought by the P2 community, produce




improvements in firm productivity. This will in the long-run help to make US industry more




globally competitive. Certainly more research needs to be done to clarify how P2 adoption might




improve firm productivity, and clear evidence of this connection would provide convincing




justification for the development of financial/economic incentives and instruments to facilitate




P2 adoption in the U.S.
                                                                                      28
-------
Bibliography

1.  Antonelli, C, 1993, Investment, Productivity Growth and Key-Technologies: The Case of
   Advanced Telecommunications, Manchester School of Economics and Social Studies, 61(4),
   pp.3 86-97, Dec.( 1993).
2.  Barbera, A.J. and V.D. McConnell, 1990, The Impact of Environmental Regulations on
   Industry Productivity: Direct and Indirect Effects, Journal of Environmental Economics and
   Management (TEEM). 18. pp.50-65.
3.  Bartlett, K.L., Lester, R.R., Pojasek, R.B., (1995) Prioritizing P2 Opportunities with
   Activity-Based Costing, Pollution Prevention Review, 5(4), pp. 17-26.
4.  Bierma, T., and Waterstraat, F., 1995, Promoting P2 among Small Metal Products
   Fabricators, Pollution Prevention Review, 5(4), pp.27-39.
5.  Dasgupta, P. and Stiglitz, J. 1980, Industrial Structure and the Nature of Innovative Activity,
   The Economic Journal, 99, pp. 569-596.
6.  Doms, M.E., T. Dunne, and M.J. Roberts, 1995, The Role of Technology Use in the Survival
   and Growth of Manufacturing Plants, International Journal of Industrial Organization, 13(4),
   pp.523-42.
7.  Dunne, T., 1994, Plant Age and Technology Usage in U.S. Manufacturing Industries, Rand
   Journal of Economics, 25, pp. 488-499.
8.  Downing, P.B. and L.J.White, 1986, Innovation in Pollution Control, JEEM, 13, pp. 18-29.
9.  Helfand, G.E., 1992, The Simple Economics of Pollution Prevention, Toxic Substances
   Journal, 12(1), pp.1-11.
10. Hischhorn, J.S., 1997, Why the Pollution Prevention Revolution Failed—And Why it
   Ultimately Will Succeed, Pollution Prevention Review, (Winter) pp. 11-31.
11. Greer, L. and Van Loben Sels, C.,  1997, When Pollution Prevention Meets the Bottom Line,
   American Chemical Society website, http://pubs.acs.org/hotartcl/est/97/sept/when.html.
12. Kelley, M.R. and H. Brooks, 1991, External Learning Opportunity and the Diffusion of
   Process Innovations to Small Firms, Technological Forecasting and Social Change, 39, 103-
   125.
13. Magat, W.J., 1978, Pollution Control and Technological Advance: A Dynamic Model of the
   F/>w,JEEM,5,pp.l-25.
14. Meyers, J.G.T. and L. Nakamura, 1980, Energy and Pollution Effects on Productivity: A
.   Putty-Clay Approach, NBER, pp.463-506.
15. Milliman, S.R. and R. Prince, 1989, Firm Incentives to Promote Technological Change in
   Pollution Control, JEEM, 17, pp.247-65, (1989).
16. Robinson, K., 1996, Modeling the Economic Impacts of Pollution Prevention in New
   Jersey's Chemical Industry, Business Strategy and the Environment, 6, pp.  1-12.
                                                                                     29
-------
17.  Stoneman, P. 1983. The Economic Analysis of Technological Change, Oxford University
   Press.
18.  Tisdell, C., 1995a, Mainstream Analysis of Innovation: Neoclassical and New Industrial
   Economics, Economic Approaches to Innovation, ed. S. Dowrick, Aldershot, UK:  Edward
   Elgar Publishers.
19.  Tisdell, C., 1995b, Evolutionary Economics and Research and Development, Economic
   Approaches to Innovation, ed. S. Dowrick, Aldershot, UK:  Edward Elgar Publishers.
                                                                                   30
-------
         Marcia Mia




U.S. EPA, Office of Compliance
      "P2 in Rulemaking"
-------
Marcia Mia has been employed as a chemical engineer with the Environmental Protection
Agency for eight years.  She is currently with the Chemical Industry Branch of the Office of
Compliance where she specializes in air issues relating to the chemical industry.  Before joining
EPA, Marcia worked as an environmental engineer and a process engineer in the cutting tool and
electronics industry, respectively.  Marcia has her BS in chemical engineering from Clemson
University and her MBA from the Babcock School of Management, Wake Forest University.
-------
       Pollution Prevention in
           Rulemaking

                MarciaMa
             Office of Compliance
                 US EPA
                                                P2intiiePhRMAMact
                                            Existing sources only
  Tanks
  Process Vents
  Wastewater streams
  Equipment leaks
             Option 1

Production - Indexed Consumption of
HAP reduced by 75% of baseline
Production-Indexed Consumption of
              HAP

 Kg of HAP consumed/kg of HAP
            produced
             Option 2
50% Reduction in production-indexed
      HAP consumption factor
                +
Additional amount of add-on controls
 to achieve overall HAP reduction of
         75% from baseline
                                                Additional Restrictions
   Any reductions in HAP that also reduce
   VOC must have a equivalent reduction in
   the production-indexed VOC consumption
   factor
-------
    Additional Restrictions
Any reduction in production-indexed HAP
achieved by reducing a HAP that is not a
VOC cannot cause an increase in the
production-indexed VOC consumption
factor
    Additional Restrictions

O/O that PRODUCE HAPs may also
qualify for the P2 option, provided the HAP
emissions GENERATED at the PMPU are
reduced to the levels required by the rule.
  Baseline Production-Index

Based on consumption and production
values averaged over the time period from
start-up of the process until present
              • OR
The first 3 years of operation
         • whichever is less
 P2 Demonstration Summary

To be submitted with Precompliance
Notification Report
 Minimum P2 Demonstration
  Requirement (63.1257(f))
Description of methodologies and forms
used to measure and record daily
consumption of HAP compounds
Descriptions of methodologies and forms
used to measure and record daily production
of products included in the standard
 Minimum P2 Demonstration
    Summary Requirements
Supporting documentation for the previous
descriptions including operator logs sheets
and copies of daily, monthly and annual
inventories of materials and products
-------
 Calculation of Annual Factor
     Continuous Processes
Calculated for every 30 days for the 12
month period preceding the 30th day (30-
day rolling average)
Demonstration of Compliance

Annual kg/kg factor is equal to or less than
50% of the baseline factor
Yearly reduction kg HAP/yr associated with
add-on controls is equal to or greater than
mass of HAP calculated using equation 52
Demonstration that criteria are met
accomplished through description of control
device and material streams entering and
leaving control device
 Calculation of Annual Factor
           Batch Basis
Every 10 batches for the 12-month period
preceding the 1 Oth batch (10-batch rolling
average).
OR
Every 5 batches if the number of batches
less than 10 for the 12-month period
preceding the 10th batch and every year if
the number of batches is less than 5 for the
12 months preceding the 5th batch."   "
Demonstration of Compliance

Annual reduction achieved by add-on
controls quantified
-------
                   Eric  Olander




          EPI Electrochemical Products Inc.
"Alkaline Non-Cyanide Plating, Silver & Copper Processes"
-------
         BIO for Eric Olander
EPI, nine years, Sales & Vice President



Present member of AESF



Past President Milwaukee AESF branch
-------
ALKALINE NON-CYANIDE PLATING
      COPPER & SILVER
         PROCESSES
-------
      Plating of silver has been utilized for jewelry, electronics, and other functional  uses for
many years.  The traditional complexing/chelating agent for silver plating has been potassium
cyanide.

      Cyanide is utilized in bronze, cadmium, copper, gold, silver,  and zinc plating.   It is a
workhorse for the plating industry.

      Waste minimization, through EPA Common Sense  Initiative (CSI),  is asking all metal
finishers  how they can finish their parts through alternative processes that eliminate  cyanide,
generate less  hazardous  waste, recycle rinse water,  recycle sludge,  and lower energy
consumption.

      In the plating industry, zinc alternatives  (acid zinc and alkaline zinc) have worked in place
of cyanide  zinc for the last 20 years and proprietary  alkaline  non-cyanide copper has been
utilized in the last seven  years. Companies that only have copper cyanide can switch to these
alkaline non-cyanide copper baths, thereby eliminating cyanide from their facility resulting in
enjoying  the advantages  of eliminating cyanide. The challenges for some metal finishers is that
they have cyanide copper  and other cyanide processes  such as brass, cadmium, and silver.
Until acceptable alternatives for brass, cadmium, and silver are developed, metal finishers will
continue using cyanide.

      Recently, a new alkaline non-cyanide silver bath  began production at four beta sites last
February. All of the beta sites are working with excellent results and the companies now have
working production baths.

         Progress Report Findings on New Alkaline Non-Cyanide Silver versus Cyanide

      Eliminates the need for a silver strike tank; plates directly to substrate - saves space and
      process time.
      Adhesion is superior to cyanide silver.
      Plates faster than  cyanide silver.
      Present formulation is bright eliminating separate brightener additive resulting in an
      organic-free silver plate.
      Color is brilliant white.
      Cost is equivalent in running cyanide process.
      Better throwing power.
-------
                   New Process versus Existing NorvCvanide Copper Process

      More cost effective because it plates out of silver anodes rather than solution.
      Anodes do not polarize - excellent anode corrosion.
      Plates faster than other processes.
      Easy to maintain with single maintenance addition.
      Superior color to competitive processes.
      E-Brite 50/50 has not required a carbon treatment of any bath. Other existing non-
      cyanide systems utilize more organics that require carbon treatments every 3-6 months.
                                    Bath Parameters

                                        Rack            Range            Barrel
E-Brite 50/50 concentration by volume     50%          40 - 60%             50%
Silver metal oz/gallon                      2.0           1.5-2.5              2.0
pH                                       9.0           8.5-9.5              9.0
Temperature                             68°F          60 - 75°F               68
Cathode Current Density            5-20 ASF                         5-10 ASF
Anode Current Density             2-10 ASF                         2-10 ASF
Agitation                              air agitation of anode, plus cathode rod agitation
                                 Equipment & Operation

Anode                                                               Pure Silver
Anode/Cathode Ratio                                                         2:1
Filtration                              Continuous filtration with 2 micron carbon filter
Tank                                              All plastics (polypropylene) tanks
                                    Plating Additives

E-Brite 50/50:                          liquid bath concentrate and silver replenisher
E-Brite 50/51:                            liquid concentrate of electrolyte replenisher
E-Brite 50/52:                                                     anode corroder
E-Brite 50/55:                                         pH adjusting salts (increase)
-------
                                   Bath Maintenance
pH meter
Silver metal titration
Electrolyte analysis by EPI - amp/hour basis
                                   Plating Procedures

Substrate:             Steel, copper strike in alkaline non-cyanide copper is necessary


                                      Post Rinsing

      Silver d ragout
      Rinse
      10-20%sulfuricacid
      Rinse
      Chrome tarnish inhibitor - B.P.A. electrolytic
      Triazole compound - E-Tec 529
      Warm rinse
      Dry

Now the silver and copper platers have a method to eliminate cyanide from their facility with the
recent development of an alkaline non-cyanide silver that works as well or better than cyanide.


                        On-going Test at Rockwell (Allen-Bradlev)

      Hardness Brinnel                                          100-110
      Electrical Resistivity                            Under study at this time
      Purity SME Analysis
                                                              % bv weight
                   Silver Ag                                         99.99
-------
   SM6
    Society of
   Manufacturing
    Engineers
     1997
© ALL RIGHTS RESERVED
                                                               FC97-199
                      Copper Plating
                      author
                      ERIC OLANDER
                      Vice President
                      Electrochemical Products, Inc.
                      New Berlin, Wisconsin
                      abstract
                      Copper plating is the building block process for metal finishing in many industries.
                      This paper includes details of four different copper plating processes with empha-
                      sis on the newest technology—alkaline non cyanide copper. Also included are
                      details of plating aluminum and how the newest copper process alkaline non-
                      cyanide copper gives the plater of aluminum the opportunity to plate aluminum sub-
                      strates without using cyanide.
                      conference
                      FINISHING '97
                      May 19-22,1997
                      Rosemont, Illinois
                      terms
                      Plating
                      Electroplating
                      Aluminum
                      Aluminum Coating
       Society of Manufacturing Engineers
One SME Drive • P.O. Box 930 • Dearborn, Ml 48121
             Phone (313) 271-1500
-------
                                      FC97-199
INTRODUCTION

      Copper plating processes are being used as the first step in many plating applications,
from truck bumpers to printed circuit boards.  Today you will find four types of copper plating -
acid copper, alkaline non-cyanide copper, alkaline cyanide copper and  electroless  copper.
The acid copper process is used for printed  circuit boards and decorative applications. This
process is microthrowing meaning that it levels. The alkaline non-cyanide copper process is
new to  the  industry and is  used to replace cyanide copper for environmental reasons.
Cyanide copper, a work horse for the plating  industry, is used as a strike plate, heat treat stop
off, and EMI  shielding. Cyanide copper cleans the substrate being plated  and has the largest
operating window and is the easiest to use. The alkaline non-cyanide copper and the  cyanide
copper are macro throwing, meaning it will not level.  Electroless copper is an autocatalytic
immersion copper process that is utilized in plating on  plastics and printed circuit boards.  In
the search for environmentally friendly processes and the pressure to reduce cyanide, we will
focus on the  newest copper plating technology - alkaline non-cyanide copper process.

      Alkaline non-cyanide copper processes include:  copper pyrophosphate chemistries
and proprietary copper chemistries. Pyrophosphate chemistry is used today, but with some
limitations because of adhesion factors and break-down product called orthophosphate.  The
orthophosphate is formed from the hydrolis  of the pyrophosphate  into orthophosphate (see
equation 1 below).

                  P2O7"*  +  H2O -»  2HPO4'2
-------
                                      FC97-199-3
undertaken and achievements accomplished during the reporting period to reduce the volume
and toxicity of the waste generated.  By eliminating cyanide copper,  a generator can show
good faith in meeting this regulation's requirements even though he may still be doing cyanide
silver, cyanide gold or cyanide brass plating.

      It has been difficult to replace cyanide in alkaline copper plating baths because of the
need for a high metal compound concentration while maintaining a low metal ion concentration
in the bath.  The high metal compound concentration furnishes  a  reservoir  for the copper
throughout the solution and also stops polarization of the anodes  as they are dissolved.  On
the other  hand, a low  metal  ion concentration is required to produce small  crystals at the
cathode to produce a bright plate. A low metal ion concentration also increases coverage and
throwing power. A high metal compound concentration with a low copper ion concentration in
a bath is accomplished with a common anion such as sulfate with  suifuric acid and copper
sulfate in an acid  copper plating bath, and with cyanide in alkaline baths with copper cyanide
and sodium cyanide. With cyanide  as a common anion in the bath, the bath can contain an
excess of cyanide to control  anode corrosion and cathode efficiency. In addition, cyanide
breaks down into relatively harmless by-products of ammonia and carbonate, which  are not
detrimental to the  operation of the bath. That is, the carbonates are not really detrimental until
they reach a concentration  of 16 ounces or more per gallon of the bath.   In searching for a
common anion to replace cyanide as a complexer it has been an important consideration to
find a common anion which does not break  down into undesirable by-products and at the
same time does not have a negative effect on present waste treatment operations. Therefore,
strong chelators such as EDTA and NTA cannot be used.

      A non-cyanide alkaline copper plating bath has been developed and is being used in
heavy production  for over 6 years with excellent success.  The bath  will plate directly on  iron
and steel,  brass and copper, zincated aluminum, diecast zinc, stainless steel and white metal
castings in both rack and barrel operations.  The process  consists of a  liquid concentrate
which contains the  copper and all  the chemistry required in  the  process.   The liquid
concentrate is used at a volume of 40 to 60% in D.I. or soft water to charge the bath  initially.
Thereafter, only one primary addition agent, the electrolyte, is used to maintain the bath as the
copper is  dissolved from the anodes.  In addition, there is  a high current density booster
additive.  A bath charged at 40% by volume will have a copper concentration of 1 ounce per
gallon.  The bath can  be operated very successfully at this level of  copper, but there are
instances  where a faster plating speed is desired in which the anodes are dissolved until a
concentration of 1.5 to 2 ounces per gallon of copper is reached. It is very important that the
electrolyte additive be added  on a daily basis while the copper anodes are being dissolved.
Once the preferred level  of copper is determined for a particular installation, the anode area
and anode current density required to maintain the optimum copper concentration in the bath
are determined.

      The pH of the bath is monitored and will increase as the bath is used. When the pH
exceeds 10, it is reduced by adding dilute suifuric acid. The bath has  proven to be easy to use
and maintain with  only the copper metal and pH being monitored.
-------
                                      FC97-199-5
      A review of the benefits of a non-cyanide alkaline copper plating bath would include:

   Eliminates the inherent dangers of cyanide in the workplace and improves employee health
   and safety.
   Eliminates the concern for catastrophic accidental acidification of cyanide.
   No carbonates to be treated
   No carbonate sludge containing cyanide to be treated or waste hauled.
   No cyanide in F006 sludges.
   No danger of cyanide if a fire occurs in a plant.
   Reduces waste treatment costs for destroying cyanide.
   Eliminates the use of hazardous chlorine and sodium hypochlorite to treat cyanide
   Accidental drag-in of non-cyanide alkaline copper plating solution poses no toxic problems
   with the subsequent acid copper solutions.
   Reduces fire and liability insurance premiums.
   Easily installed in existing plating lines.
   One bath serves as both a strike and plate bath.
BATH CONTAMINANTS

Organic Contamination - remove with batch carbon treatment.  Sometimes hydrogen peroxide
is added to remove the organics.

Iron - Can absorb up to 2000 ppm iron. Remove the iron through high current density dummy
plating.

Lead - Can absorb up to  50 ppm of lead. Remove with high current density dummy plating.

Calcium -  Will destroy  the copper - complexor bond  and more complexing product is
necessary. Switching to  Dl or softened water alleviates this problem.

Chrome - Up to 10-15 ppm limit. Chrome reducer does work, but use sparingly.

      One of the applications of plating alkaline non-cyanide copper is plating onto zincated
aluminum  surface with this  copper process.  A typical  plating process for aluminum can
include  approximately seventeen steps - cleaning  to  copper plating.   Plating  aluminum
requires more  steps than other substrates such as steel, brass and zinc diecast.  The main
reason for more steps is that copper cannot be directly plated onto aluminum.   It  needs the
proper pre-plate cycle to be successful.  To determine the pre-plate  process, the aluminum
alloy, type of aluminum - casting or extrusion, and existing condition of aluminum - stamping,
polished/buff, or machined must be known before the pre-plate  cycle  can be determined.  In
the past steps 9 and 13 utilized  a cyanide base zincate  with a cyanide copper plate.  With
alkaline non-cyanide processes available,  metal finishers can now use non-cyanide zincates
-------
                                      FC97-199-7
creating an entire non-cyanide process for aluminum.  With recent development of new non-
cyanide zincates, they meet or exceed cyanide base zincates in performance.

      Another application for the non-cyanide process is the replacement of stannate process
for aluminum and the cyanide bronze.   The non-cyanide zincate  will directly replace the
stannate process.  The typical stannate process is  an  immersion alkaline tin  process   -
sometimes electroplated tin.  The non-cyanide zincate process costs less to use versus the
stannate process because of its ease of use, and wider operation window and cost of zinc
versus tin.

      The zincate process utilized to ASTM B-253-68 (1) will  meet the service condition
specifications adhesion  and corrosion  of the SAE  J207  (2) specification.   The  stannate
process is losing favor to the zincate process with the need  to  eliminate cyanide since the
typical stannate process uses a cyanide bronze process.  Some  experimental work on using
the immersion  tin with the  alkaline non-cyanide  process   is  being  investigated.  The
manufacturers (platers) of aluminum  bus bar are investigating alternatives to the  stannate
process.  Included in the alternatives is zincated aluminum with the alkaline non-cyanide
copper process.
CONCLUSIONS

Platers of aluminum have a new environmentally friendly process for plating aluminum without
the use of any cyanide zincate or cyanide copper plate.  The key to the process is the alkaline
non-cyanide copper.  The  proprietory alkaline non-cyanide copper process has better throw
than the cyanide process, low copper metal concentration, more stable chemistry than copper
pyrophosphate chemistry, and reduces waste treatment costs eliminating chlorine/bleach from
the waste treatment area.
-------
           Lee Paddock




Minnesota Attorney General's Office
 "Valuing Environmental Performance "
-------
                            LeRoy C. (Lee) Paddock
LeRoy C. (Lee) Paddock is Director of Environmental Policy and Manager of the Agriculture
and Natural Resources Division for the Attorney General of Minnesota.  Lee is also a member of
the Executive Committtee for the Attorney General's Office.  As Director of Environmental
Policy he is responsible for environmental legislation, development of new environmental
enforcement programs, liaison work with U.S. EPA on enforcement issues and advising the
Attorney General on environmental policy.  A significant emphasis of his work has been finding
cooperative solutions to environmental problems. Lee also manages a 23 person Division that
represents the Minnesota Department of Agriculture and the Minnesota Department of Natural
Resources.

Lee joined the Minnesota Attorney General's Office in 1978. He served as Senior Environmental
Counsel for the National Association of Attorneys General in 1985 and 1986.  In addition to his
other responsibilities, Lee is a participant in the Aspen Institute's series on The Environment in
the 21st Century, was a Liaison Member of the Eco-Efficiency Task Force of the President's
Council on Sustainable Development, participated in the work of the Enterprise for the
Environment Dialogue, serves on the Board of Directors of the Minnesota Environmental
Initiative and on the Advisory Board for the University of Minnesota's Center for Environment
and Health Policy.

Lee is a 1977 graduate of the University of Iowa Law School and served as a law clerk for Judge
Donald Lay of the U.S. Eighth Circuit Court of Appeals.
-------
                      Lynn Persson

Bureau of Cooperative Environmental Assistance, Wisconsin
                          DNR
       "Wisconsin rs Innovative Environmental Initiatives "
-------
                  Wayne Pferdehirt

   Printers' National Environmental Assistance Center
                      (PNEAC)
"The Printers' National Environmental Assistance Center: Your
       Partner in Compliance and Waste Prevention "
-------
Bio: Wayne P. Pferdehirt, P.E., AICP
Mr. Pferdehirt is Co-Director of the Printers' National Environmental Assistance Center
(PNEAC). PNEAC assists printers and organizations that help printers, by providing easy access
to current, practical accurate information and resources that can guide environmental compliance
and waste prevention efforts by printers.

Mr. Pferdehirt participates in PNEAC through the University of Wisconsin's Solid & Hazardous
Waste Education Center (SHWEC), where he helps Wisconsin businesses and local governments
improve financial and environmental performance through the application of cost-effective waste
prevention strategies.  Mr. Pferdehirt is also a Program Director in the University of
Wisconsin-Madison's Department of Engineering Professional Development, where he leads
professional development courses in environmental management systems, ISO 14000, "green"
product design and the design of solid waste facilities. Wayne received his B.S. in civil
engineering from Carnegie-Mellon University, and his M.S. from Northwestern University.
Wayne is a member of GATF, NAPL and IAPHC.
-------
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-------
               Roger Price/Robert P. Briggs
                 (see Robert P. Briggs for paper)
                        STV Inc.
"An Employee Driven Waste Minimization P2 Study at a Specialty
                     Chemicals Plant"
-------
                                Roger L. Price
Roger L. Price, P.E. is a Senior Environmental Engineer with STV Incorporated.  He received
his Bachelor'9 Degree in Civil/Environmental Engineering from Cornell University in 1975 and
his Master's Degree in Sanitary Engineering from The Pennsylvania State University in 1977.
Mr. Price has over 20 years of diversified environmental experience in a broad range of
industrial, commercial and governmental projects. His experience includes preparing and
auditing environmental management systems and environmental compliance programs. Mr.
Pnce has prepared and conducted over 170 professional training sessions on pollution
prevention, spill prevention and response preparedness, environmental management systems and
regulatory compliance. In 1992, Mr. Price was appointed to serve on an Advisory Committee for
the President's Commission on Environmental Quality, Pollution Prevention Model
Demonstration Project.
-------
              N. Rajagopalan




Illinois Waste Management & Research Center
  "Putting the Squeeze on Metal Working Fluids"
-------
Biography: N. Rajagopalan

Dr. Rajagopalan is currently responsible for oversight of the pollution prevention technology development
and demonstration activities of the Illinois Waste Management & Research Center. He has several years
of experience in process development and project management in the food, chemical, and metal finishing
industries. His research interests include novel separation processes with particular emphasis on
membrane based separations. He is the recipient of numerous grants from both industries and public
agencies and has several peer reviewed technical publications.
-------
            WMRC Pollution Prevention Program
        Putting The Squeeze On
          Metalworking Fluids

              Kishore Rajagopalan
           Waste Management & Research Center
       Machine Tool Agile Manufacturing Research Institute
              Metalworking Fluids
  Fluids that facilitate metal shaping processes
           Waste Management & Research Center
      Machine Tool Agile Manufacturing Research Institute
                  Benefits
Functional
Cooling   ^^
Lubrication
Chip Removal
  Performance
Extend Tool Life
Control Surface Finish
Dimensional Control
Reduced Power
Consumption
           Waste Management & Research Center
      Machine Tool Agile Manufactunng Research Institute
-------
                Metalworking Fluid Types
   Soluble Oils  Semi-synthetic fluids    Synthetic fluids
               Waste Management & Research Center
          Machine Tool Agile Manufactunng Research Institute
                   Degradation Of A Coolant
Dilution water/ Evaporation
(Increases TDS)
 Machine tool leaks
 (extraneous oils)
Metal Fines
(Metal contamination)
                                Microbial contamination
                                Bacterial/Fungal Contamination
              Waste Management & Research Center
          Machine Tool Agile Manufacturing Research Institute

           Economic & Environmental Issues
              Waste Management & Research Center
         Machine Tool Agile Manufacturing Research Institute
-------
                  Cost Of Ownership
German Automotive Industry Survey
   Lubricant cost >••> Tool Cost '
             Waste Management & Research Center
         Machine Tool Agile Manufacturing Research Institute
                       Disposal
   •  High Oil & Grease
   •  BOD

   •  Synthetics/Semi-synthetics hard to treat

   US discharge volume ~l-2 billion gallons/yr
   Metal Products & Machinery Rule (proposed)
             Waste Management & Research Center
        Machine Tool Agile Manufacturing Research Institute
                   Health & Safety
      Bacterial contamination
       - respiratory diseases (e.g., HP)
       - contact dermatitis
      Biocides
       - lexicological problems
      Mists
       •flOSH IW1 CfBm. to I
             Waste Management & Research Center
        Machine Tool Agile Manufacture^ Research Institute
-------
                Research Goals
        WMRC-MTAMRI Partnership
 Reduce volumes of metalworking fluids
 discharged
  - through improved recycling methods
 Address health & safety issues
  - alternative microbial control
  - (reduce/eliminate) biocides
         Waste Management & Research Center
     Machine Tool Agile Manufactunng Research Institute
     Crossflow-microfiltration concept
I
               High BOD coolant for reuse
              ^^^^^^^^^  Particulate/Bactena
           I  ) ^^^^^^^^^^^^^T
Microfilter   *  T
                            High BOD/
                            10% of ongtnal volume
         Waste Management & Research Center
    Machine Tool Agile Manufactunng Research Institute
       Case Study-Particulate Removal
              Recycling Gnnding Fluid
 Manufacture of Aluminum Discs
  - Highly polished surface
  - Large volumes of coolant used
  - High BOD
         Waste Management & Research Center
    Machine Tool Agile Manufactunng Research Institute
-------
                 Grinding Process
                                       I
            Waste Management & Research Center
        Machine Tool Agile Manufacturing Research Institute
                       Effluent
Use Volume
                            "»      Effluent BOD
            Waste Management & Research Center
        Machine Tool Agile Manufacturing Research Institute   »HS&
                  Problem Solving
     Process Substitution
     - Substitute coolant
     -Reduced BOD 71%
     - Estimated BOD (mg/L) -1724
     Recycling through microfiltration
     - Volume reduction -80%
     - BOD reduction -50%
            Waste Management & Research Center
        Machine Tool Agile Manufacturing Research Institute
-------
              Product Useability
Coarse Grinding
   - Re-used directly up to 3 cycles
   - 1% fortification required after 3 cycles
Fine Grinding
   - Needed fortification
         Waste Management & Research Center
     Machine Tool Agile Manufacturing Research Institute
           Projected Cost-Benefits
 Coolant Savings- 260,000 US S
 - Through substitution/recycling
 Annual Equipment Operating Costs
 - 85,000 US $
 Equipment Capital Costs
 - $ 300,000
         Waste Management & Research Center
    Machine Tool Agile Manufacturing Research Institute
   Other Coolants/ Microbial Control
        Waste Management & Research Center
    Machine Tool Agile Manufacturing Research Institute
-------
               Critical Data Gaps
  Microbial Issues
   - types, growth rates, acceptable levels,
     endotoxins
  Metalworking fluids
   - components, physical characteristics.chemistry,
     functionality, contaminant levels/tolerance
  Microfilters
   - optimal surface, pore size, operation mode

          Waste Management  & Research Center
      Machine Tool Agile Manufactunng Research Institute
                 Current Status
Microfiltration as a means of extending coolant
life is very promising
   - paniculate control relatively easy
   - microbial control- promising/critical gaps remain-
     on-going research
   - synthetic coolants easiest to microfilter
   - semi-synthetics & soluble oils more challenging
   - additional research required to map boundaries of
     applicability
           Waste Management & Research Center
      Machine Tool Agile Manufactunng Research Institute
               On-Going Research
 M\VF Characterization

Functional properties
Chemistry            ^
Contamination rates
Contaminant characterization
 Recv cling Technology
 Development Evaluation

   Engineering
K-  Effectiveness
   Residuals
   Economics
           Waste Management & Research Center
      Machine Tool Agile Manufactunng Research Institute
-------
         Acknowledgements


           Dr. Veera Boddu
           Ms. Teresa Chow
           Mr. Steve Skerlos
     Waste Management & Research Center
Machine Tool Agile Manufactunng Research Institute
-------
      Paul M. Randall/Dr. W. J. van Ooij

 U.S. EPA, National Risk Managment Research
      Laboratory/University of Cincinnati
"Evaluation ofSilanes to Replace Chromates in Metal
         Pretreatment Prior to Painting"
-------
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   G.E. Medical Systems, NB-913
"Recycling & P2 at G.E. Medical Systems"
-------
       RECYCLING and POLLUTION PREVENTION
                                    at
                                 GEMS

                        Dennis M.Hussey, CIH,CHMM (1)
                        Paul E. Neumffler, NREP,CEA (2)
                            JJ.Rao, PE,CHMM (3)

General Electric Medical Systems (GEMS) is headquartered in Waukesha, Wisconsin
for its international business in  medical diagnostic equipment.  Several of GEMS
manufacturing/service facilities  are located in the greater Milwaukee area.  GEMS
manufactures, installs and services  a  wide range of medical diagnostic equipment
such as CT Scanners (CT), Magnetic Resonance Imaging systems (MR), mobile X-
Ray equipment (X-Ray), Ultrasound equipment (US), Positron Emission Tomography
equipment (PET) and special cameras. GEMS is also the largest manufacturer of X-
Ray tubes  at  its  Milwaukee plant on Electric Avenue. The X-Ray targets are
manufactured in Cleveland, Ohio (Target plant) and the magnets for the MR systems
are manufactured in Florence, South Carolina ( Florence plant). The targets and the
magnets are then shipped to the manufacturing plants  in the Milwaukee area. The
repair of major equipment is carried out at the Trout facility (Trout), the digital boards
used in the  electronic controls are  repaired at another facility (DBR).. All of the
GEMS  manufacturing is covered under the Standard Industrial Code # 3788.

GEMS  is unique in the  medical diagnostic equipment business having established
eight years ago a product take-back and recycling program for the old diagnostic
equipment replaced in the field by GEMS.  The recycling program offers return of any
obsolete component or an entire diagnostic system to the Recycling Center (RC) in
Milwaukee, even if it is not  an original GEMS equipment, from the field by GEMS
service personnel for all the customers. The equipment received at  the RC is then
individually  reviewed and disassembled manually to separate the components into
three broad  streams. These three groups  are the salvageable parts for reuse, the
recyclable parts  through third  party recyclers  and the disposable  parts.   The
salvageable parts are then tested and  verified for reuse in the exchange pool/parts
service  program.    The  Recycling operations  are  classified under the standard
Industrial Code # 5093

Presented at the USEPA Region V Waste Minimization /P2 Conference, December 14-16,1998
1: D.M.Hussey, Manager - Global Environment, Health and Dafety, GEMS
2: P.E.Neumiller, Manager- Recycling Center, GEMS
3: J.J.Rao, Manager- RCRA Compliance/Pollution Prevention, GEMS

EPA.RV.W.minP2Dec.98.doc  Ems
-------
GEMS has an Environment, Heath and Safety (EHS) management system for all of its
facilities and the service personnel who operate in the field. These efforts are further
supported and guided by General Electric's (GE)  Corporate Environmental Programs
(CEP)  headquartered in Fairfield, Connecticut.  As a result of this Environmental
Management System ( EMS) Recycling and Pollution Prevention (PP) efforts are part
of the  on  going  activities to reduce pollution and  seek  continuous advancements
towards Sustainable Development through a multitude of efforts. The EHS group at
GEMS is responsible for managing the progress  and to maintain the momentum to
meet the changing needs in the environmental arena.   A  summary of the  past
programs,  a brief description of the  present efforts and a glimpse of the future are
discussed here to portray the ongoing Recycling and Pollution Prevention (R & PP )
programs at GEMS.

The implementation of the R & PP is accomplished through the EMS by a group of
trained environmental professionals with the assistance of pertinent outside support
services as well as professionals. The training  and continuous education of these
individuals is certainly  the  key factor in  the  management of the programs  in
conjunction with the measurements of the  various performance parameters on  a
regular basis. The  regulatory  required training  of other non-  environmental
professionals and a system to incorporate their input is the other essential element that
has been recognized as the key to overall success in such environmental work. The
foundation for GEMS R& PP programs may be summarized to consist of:
       *      Education and training
       *      EHS Measurements
       *      Forum for environmental communications
       *      Management and review of the results

The EMS  provides the  impetus to start and implement environmental  programs to
promote recycling and achieve pollution prevention at each facility. These programs
are, therefore, operationalized at the each of the sites by customizing the site specific
issues relating to the programs introduced. The site specific programs that have been
successfully implemented and being carried out are:
             *     POWER (Pollution, Waste, Emission Reduction)
             *     EPA's 33/50 (33% reduction by 1992  & 50 % reduction by
                   1995 of any of the seventeen groups of chemicals) program
             *     Pulse / Power( GEMS environmental audit programs)
             *     Chemical Management program
             *     Pollution Prevention Plan
             *     An EHS council at each manufacturing facility
             *     Design for Environment and integration of EHS with
                   design and manufacturing methodology
             *     Scorecard / Trotter Matrix (GEMS  measurement/rating
                   program)

It  is important to note that these programs at each of the manufacturing or repair
facilities were established in harmony with the design engineering, manufacturing and
-------
service operations with changing/growing trends in the diagnostic business.  As such
the entire process of Recycling and Pollution Prevention must be viewed as a part of a
dynamic system which calls for flexible response due to changing circumstances and
environmental regulations.  This shall, perhaps, be more evident as the steps involved
and the chronological events are described.

Recycling at GEMS:

The recycling  operation  was started  in February  1989 as  part  of the Service
Operations to replace a less formal" Salvage" operations at the Electric Avenue plant.
These initial  operations involved disposing the used oils for burning without detailed
scrutiny of the process or the results and sale of the old equipment to salvage dealers
with no control on the final disposition of the parts as they sometimes ended  in the
hands of third party vendors. This was partly due to limited industrial or commercial
recyclers  offering recycling services or salvage value for recoverable materials,
minimal regulations to restrict the generators/transporters/waste  handlers in the
disposal  of  industrial wastes. There  were  limited  sources of state  or federal
information bureaus that provided technical guidance in such matters on a structured
basis. The formal establishment of the Recycling  Center helped to analyze the used
equipment being returned  for disposal in a more technical manner and persistent
efforts to improve the salvage value led to better  management of these wastes. One
such example  was  the GEMS practice at Electric avenue plant of mixing  metal
turnings/chips into one lugger box costing over $8 /ton for disposal.  An experiment
on one shift with the help of an interested supervisor led to segregation of these waste
metals and ability of the RC management to negotiate a salvage value  for the  waste
metallic  waste  streams.  The salvage value ranged from about $0.35 to $6.50 per
pound to yield a net income  of about $100,000 annually. Further analysis of the
incoming waste equipment streams through concentrated efforts led to the realization
that with the  investment of manual labor at the RC many of the complex equipment
could be  disassembled into valuable salvage  components like copper from wires,
silicon   chips   from   the  computers,     precious  metals   from   electronic
components/printed circuit boards, recyclable plastics from equipment covers, glass
from ancillary control components and disposable batteries used as power back-up or
alternate power sources etc. The additional investment made  in the employment of
personnel strictly dedicated to disassembly  and  segregation of wastes by  their
disposal  destination  created a substantial increase in the salvage revenues.  In the
meanwhile the service business appreciated the ease and convenience of returning the
diagnostic equipment replaced in the field to a known and fixed destination through
reliable transportation services managed by the RC personnel. Another  benefit has
been a better control of the quality  and  security issues in servicing  the GEMS
equipment.  GEMS does provide used diagnostic equipment to customers by using
salvaged parts.  A method to separate those parts that passed the preliminary checks
as  reusable  parts  are  then  shipped to  the relevant  facility for  testing  and
manufacturing.  This yielded further encouragement to product recycling efforts at
the RC.  As  a result of the progress made an arrangement  was made to establish
-------
another recycling  program  that  involved  the return of  defective or  unusable
manufacturing components considered as waste items at the various manufacturing
facilities.  Since there are five major facilities  in the Milwaukee area the return of
manufacturing waste streams was augmented by establishment of a shuttle service by
Ace Worldwide Van Lines (Ace) for pick up of such wastes on a daily basis. The
result was a steady and rapid increase in the weight/volume of materials recycled
through the RC with expanded efforts  on  all fronts  to better manage  the  waste
generation, its segregation and the condition in which they were shipped.

One such management focus  was to bring to  light the cost and efforts in disassembly
of the returned equipment with an  aim to  improve assembly  design features that
would make disassembly easier. The other aspect was the introduction of Design for
Environment (DfE)  concept to the  design  /manufacturing   engineers  to  avoid
environmentally unfriendly actors in the product to afford less expensive disposal
options as Resource Conservation, Recovery Act (RCRA)       promulgated   more
stringent regulations in the 1990s. These efforts to manage the recycling business in a
more  cost  effective  manner led to introspection of our products  by  the  design
engineers at the New Product Introduction (NPI) stage and consequently the creation
of a formal document that integrated Environment, Health and  Safety issues into a
document called Phase  Review Discipline (PRO). PRD  calls for a step by step
approach for launching new products with a system of checks and balances to avoid
the glitches suffered earlier in the recycling program. Some of the positive outcomes
have been:

*      Reduction in the number of fasteners used in equipment assembly
       (Result: Reduction in the direct manufacturing costs and the
       assembly time)
*      Reduction in the type  of fasteners used on a specific component/sub-assembly
       (Result: Reduction in the type of tools required to assemble
       /disassemble and thereby the associated costs)
*      Use of fasteners other than bolts and nuts where possible
       (Result: Reduction in the direct costs while improving
       manufacturing techniques)
*      A review of some of the key components used in the equipment
       and making the design environmentally more friendly.
       ( Result: Reduction in the amount of hazardous waste handled
       at the manufacturing as well as the recycling stage.)
*      Innovations in the shipping of our equipment to the customers using
       returnable/ reusable steel  dollies instead of disposable lumber/ large
       quantities     of packing materials etc.
       ( Result: The job of field personnel made easier who receive
       the new equipment in  a manner conducive to field installation
       and as the old equipment  is dismantled in stages from the
       customer site it is loaded onto to the returnable dollies for
       shipment back to the Milwaukee RC.  Most of the packaging
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       materials are returned from the installation sites back to the RC.
       Usually health care facilities do not lend themselves to easy
       removal of the old equipment with construction type activities
       that leave behind a debris to upset  the CLEAN ROOM image.
       Furthermore disposal of unused shipping materials can pose
       problems for the field personnel while installing large
       diagnostic equipment shipped in sections.)
*      The field returned equipment is conveniently unloaded, most of
       the times, from the dollies in a familiar pattern and the dollies
       returned to the manufacturing facilities for reuse.
       (Result: Save costs, space and labor associated with
       lumber/shipping skids etc. that would otherwise be incurred and
       the inefficiencies associated with preparing new shipping skids
       on a continuous basis and its disposal problem faced by the
       field personnel at the health care facilities.)

Apart from the  recycling of the diagnostic and ancillary  equipment the RC also
handles all the cans/bottles/plastics/computers and other such items disposed from the
various GEMS Milwaukee area sites with over 4,500 employees contributing  the
recyclable items.  Revenues from these operations and any usable computer items are
donated to charitable organizations. Such activities are sometimes coordinated with
the other GE businesses who seek such items for non-profit community organizations.
At CT facility the cardboard received in the incoming shipments is shredded by third
party vendor employing the physically challenged personnel and returned for reuse as
a cushioning material  instead of the more prevalent plastic  materials  that become
nuisance when computer/delicate electronic items are unpacked.

The  Target facility  recycles  its  production waste and  product waste  consisting
essentially of Tungsten and  Molybdenum through recyclers who  reuse it in the
manufacture of specialty steels. In 1995 more than 36 tons of these metallic wastes
were recycled. The wastes from the Magnet plant essentially consisting of permanent
magnets  are also recycled through special recyclers though the waste is minimal due
to the special controlled application of these super size magnets in the MR imaging
systems.

The  RC presently occupies about 35,000  Sq. Ft. facility leased in  the Ace Industrial
Park on College Avenue with more than fifteen Ace contract employees and less than
six GEMS employees who supervise the recycling operations with EHS training and
education. The  Ace trucking provides  the local  shuttle service to pick-up  non-
hazardous  materials for recycling  from the  local facilities and thereby making
recycling/proper disposal of many routine items very manageable for all the facilities
involved. This certainly  contributes to  pollution prevention and cleaner facilities
being maintained without each facility making individual attempts  to handle these
common issues.  The Ace service also facilitates the return of scrap from production
and repair operations carried out by GEMS parts vendors.  This provides another cost
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effective measure for disposal of solid wastes from the vendors who have been
prescreened to serve GEMS customers' needs.

The  RC  is now feeling the  constraints of space, the need to introduce technical
processes in the future to make recycling activities more amenable to automation and
special services  for the anticipated return of the existing products in service at the end
of their life or due to  their obsolescence in the next decade. This is particularly so in
view of the sophistication taking place in the recycling business and industry specific
specialists who cater to a narrow range of the recycling niche.

Pollution Prevention at GEMS:

Pollution Prevention has been a goal at GEMS with General Electric Company's
corporate policy 20.3 on Environment, Health and Safety :

       *     100% Compliance with regulations
       *     Zero Hazardous Products and Processes
       *     Zero Accidents and Injuries
       *     GEMS recognized as a Good Corporate Citizen
       *     Everyone involved in EHS

GEMS is committed  to EHS excellence as part of the aforementioned policy
goals for these reasons:

       *     It is the Right Thing To Do (Integrity)!
       *     The Law requires it!
       *     It is a commitment to our employees !
       *     It saves us money
       *     It is good management practice !
       •  Our  employees, neighbors and customers expect us to do it!

A brief introduction to the range of chemicals used  by GEMS  may be covered by
stating the chemicals  used without quantitative reference or an  explanation of their
application. The chemicals are:

Acids        -       Nitric,  Hydrochloric, Phosphoric and Sulfuric
Alcohols     -       Ethyl, Isopropyl, Methyl
Alkali        -       Sodium Hydroxide
Glycols      -       Ethylene/propylene
Metals       -       Steel/ Stainless  Steels, Molybdenum, Tungsten, Nickel,
                    Cadmium, Copper, Lead, Titanium, Silver,  Gold, several Rare
                    Earth metals/Oxides
Solvents     -       Acetone, Methylene Chloride
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Miscellaneous -      A variety of lubricants/oils, transformer oil, water treatment
                     chemicals, detergents /Aqueous Cleaners,epoxresins/hardeners,
                     contact cements and glues, Refrigerants for comfort cooling,
                     sodium carbonate and other common chemicals used in
                     cleaning and maintenance.

In the  environmental management  of  wastes it is certainly true that  what gets
measured is  likely  to get reviewed  and controlled.  GEMS has been  carrying out
internal audits of its entire EHS practices facility by facility on an annual basis since
1980.  The self-realization of the facts facing  GEMS waste generation  and disposal
has therefore been  very crucial to making improvements in the field  of Pollution
Prevention. GEMS   manufacturing  involves  the use of many diverse chemicals,
electronic components/computers and vendor  supplied sub-assemblies.  The initial
efforts were control  and command  of the  areas of manufacturing  generating the
wastes and avoiding  undue waste streams created due  to overflow, leaks, lack of
timely problem solving   and such recurring incidents. Once the frequency  of
recurrence and the number of such incidents at a given location were minimized the
focus shifted to solving the pollution problems on a more permanent basis. Such an
approach was based  on the Waste Pyramid principle of maximum benefit in the
pollution prevention strategy is derived from substitution of hazardous materials with
non-hazardous  materials. The next best alternative was to  find less toxic  or less
dangerous materials being substituted to reduce the risk and the severity  of the
environmental pollution. The next higher section of the waste pyramid called for
increased recycling efforts to maximize the life  span of the raw material and reduction
in the  use of non-renewable  resources involved.  The non-renewable resources
indirectly affected were fossil fuel used as  energy sources in converting such raw
materials from the native  form to the  industrially useful  form.  Such benefits  of
pollution prevention  are difficult to quantify, document and record  in  terms  of
tangible cost savings.

The less desirable option available when substitution and recycling are not feasible is
treatment of the waste prior to disposal through applicable permits and release within
compliance limits. GEMS has minimal treatment at any of its facilities and  has no
wastewater treatment plants, no on-site hazardous  waste  treatment and minimal
equipment for treatment of air emissions with only one facility covered under Title V
permit program in the entire U.S. The least favorable option in the waste pyramid is
disposal and this option is almost unavoidable to a certain extent. However the total
quantity  sent for  disposal  is tracked and is being minimized annually in spite  of
increased production and growth in the business.

The implementation of the waste pyramid strategy  combined with the review of audit
findings provided the  correct background to embrace an in-house GE program called
POWER as mentioned earlier. This program was introduced in 1989. Reduction in
emissions of Volatile Organic  Compounds used as solvents and  in wipe-clean
operations were achieved  along with a reduction  in  the  quantity of the  waste
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generated due to better  management,   simple tools  like issuing  smaller  solvent
containers  per use, tracking the usage by the department  and investigating any
practices that led to excessive use and other measures based on person to person
campaign by all  those who responded to the change in culture required at the time.
Many reductions were just accomplished through simple administrative controls and
revised procedures for approval and purchasing of such pollutants.  There were two
major  programs that  boosted the POWER philosophy.  The first one was  GE's
acceptance of Environmental Protection Agency's (EPA's) invitation to voluntary
reduction of 17 priority pollutants under the 33/50 program. GE's leadership by Jack
Welch called for 60% reduction by 1994 stretching the EPA goal for GE businesses to
meet.

The 33/50  program efforts led to elimination or  a major reduction  in the use of
solvents  like 1,1,1  Trichloroethylene and   Trichloroethane,  Methyl Ethyl  Ketone,
Methyl Isoburyl Ketone, Methylene Chloride,  use  of Lead as a counterweight metal
in mechanical design, any oils that contained minute amounts of Benzene or Toluene
or Xylene.  Freon 113 was eliminated under the POWER program.  The  reduction in
the use of the 33/50 list of solvents was  essentially accomplished by  substituting
aqueous cleaners and aqueous cleaners used with deionized water. This was specially
true with the purchase of new washers equipped with ultrasonic cleaning mechanism
to work with de-ionized water to improve the  effectiveness of the aqueous cleaners.
The installed cost of such washers were in excess of $100,000 to $250,000 depending
on the part and quality requirement  in a manufacturing process.    The  capital
investment had a good payback of less than one -two years due to elimination of the
hazardous waste  solvent disposal issue and the labor associated in managing the EHS
program guidelines.  This was endorsed by the design and production  engineering
personnel making it a standard practice in the  newer installations that followed. The
momentum was  thus not only maintained in  achieving the basic policy goals but
increasing the pace to strive for excellence as  the facility leaders welcomed the cost
reductions  and reduced  environmental  risks.  The maintenance  and production
personnel also welcomed the improved health  and safety aspects  of not dealing with
large quantities of toxic &/or flammable solvents.

The second boost  to  the  POWER program came  from the  implementation of
Chemical Management program in GEMS in 1993. This program involved a formal
procedure  to  purchase  any  chemical  by  anyone  from janitorial custodians to
experimental research  staff along with the bulk  users in production with signed
permission from the EHS manager. A list of approved chemical was created and is
maintained up  to date based on a close scrutiny of the application of the  chemical/its
environmental  rating in terms of safety/disposal issues and applying the POWER and
waste pyramid strategy.  The approval  was based  on the  chemical being used  in a
particular work area (zone) in limited quantities with engineering controls in place
prior to the purchase. A chemicalapproved for  one particular zone is not to be used in
any nearby  or distant  location unless  specifically pre-approved through identical
procedure.  This reduced the proliferation of  commonly  used solvents/  lubricants /
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oils/alcohols/cleaners etc. and provided a feedback on the consumption patterns by
the location.  This facilitated the control and efforts to reduce unauthorized or undue
usage to afford major  cost savings. The program was  instituted by bringing in a
chemical management  company from outside to serve GEMS  exclusively on a
contract basis with reduction in chemical costs and consumption tied to a performance
incentive for achieving positive results. The procedure now  tracks all  chemical
requests through a single channel no  matter who originates the chemical requests
from any of the facilities.   Any sudden shifts in the consumption patterns are now
easily traceable and quantifiable. This data helps EHS management to commend the
positive trends and pass the information to others as the BEST PRACTICE to create
similar success elsewhere  within GEMS.  Any negative trend is  investigated  and
resolved to control detrimental  effects  long before they  become unmanageable.
Chemical Management plan has provided excellent tool from the driver's seat to look
ahead and plan the response for adequate control of the raw materials that are likely to
become pollutants.

Each GEMS facility prepares a Pollution Prevention plan whose essential elements
are:

       *     Reiteration of the GE EHS policy
       *     Plant management support statement
       *     Name of the site PP coordinator
       *     Site specific goals for Reduction, Elimination and Recycling
       *     Previous year PP accomplishments
       *     PP team members for the site
       *     Tracking and measurements
       *     PP opportunity assessment
       *     PP technology transfer commitments

The PP is annually updated with the relevant statistics from the previous years duly
incorporated to provide a sense of accomplishment and motivation as EHS personnel
change in the course of time and continuity in all these programs is crucial to the
overall GEMS success.

It has been evident in the management of environmental systems  at any industrial
facility that just as regulators achieved very limited success with the command and
control  philosophy and methodology  to  assure  environmental  excellence,  the
industrial   successes  were  limited  if the  environmental  concept  was   not
operationalized through the work force. Either a single environmental professional or
a group of such personnel could not 'police' and achieve environmental  goals for the
entire facility. Training, education  and personal  involvement  of the general work
force is a vital ingredient for success.  GEMS has established and nurtured very
carefully the concept of EHS council  that has contributed  very significantly to the
success of  EMS. The EHS  council at each facility consists of the EHS professional,
the plant  manager  and a  group of  concerned  employees from all  ranks from
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production associates,  maintenance,  administrative/clerical  and  other  technical
persons in non-supervisory or  managerial positions and  with or without union
affiliations. This team of individuals essentially hold meetings from 1 to 4  times a
month dividing responsibilities/sharing goals to document, review,  discuss,  resolve
and initiate action to solve Environment, Health and Safety issues ranging from
accidents/injuries to spills and environmental compliance problems. The minutes of
the meeting are published for review by others and pending issues are  gradually
pushed for resolution or intervention by others to provide a continuous momentum for
achieving better results in preventing accidents, injuries, spills, pollutant releases and
waste generation.  Since the EHS council usually comprises of people with  diverse
backgrounds  and priorities there is little stagnation and  a  lot of fresh ideas to
motivate reaching  of EHS goals.  There are  both  simple and  formal methods to
recognize the success of these teams  at  any time of the  year  which provides
recognition and encouragement to the existing as well as new members. EHS  council
also provides a very cost effective tool to implement changes that are proposed,
planned and supported by the employee team.  Their success seems to be contagious
and provides an excellent return on the time invested away from the prescribed duties.
Once  again the benefits are difficult to quantify but the results are evident just as the
cool breeze brings relief from hot weather though it is invisible.

GEMS has guidance  documents for introduction of new products and these integrate
the EHS issues  in the development stages called Milestones. The document is called
Phase Review Discipline (PRD) handbook and the  process is termed New Product
Introduction (NPI).  EHS concerns are documented in the milestones  and  this
provides an excellent tool to integrate the environmental concerns of the future in the
new  products based  on the present knowledge of the existing  problems  &/or
anticipated regulatory changes. An EHS questionnaire has been developed to review
and control the introduction  of environmentally unfriendly  elements entering the
GEMS  product  lines  in  pre-finished/pre-tested  sub-assemblies  and  product
components purchased for direct use.

The PRD process is supported by  the EHS group which  provides Design for
Environment(DfE), Design for Disassembly(DfD) and Design for Assembly (DfA)
seminars.   The  RC  offers excellent real life  examples  of the  past mistakes, the
problems  encountered by the field engineers  after installation during repair  and
obstacles faced in cost effective disposal of certain components. One such item is the
fiberglass used in the protective/decorative cover used on many diagnostic equipment
that remains intact  in a health care  facility. These covers cannot be recycled through
black-top pavement contractors being in very limited in quantity  and in non-crushed
state.  Similarly  the thermoset plastics  are  difficult  to reuse.  These two  items  are,
therefore, landfilled even when they are hardly damaged from the day of purchase.

The concept of  sustainable development as the extension of DfE  motto is now being
reemphasized in light of the ISO 14000 development and the global nature of GEMS
business. The  environmental planning and management to continue the pro-active
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role and support  the business growth into a sustainable development phase is the
challenge that has been undertaken to meet the environmental demands of the future
and provide GEMS with a cost effective method to  enter the twenty-first century.
GEMS  has  established  and  continues  to  establish manufacturing  and  service
operations  abroad  on all the continents and  the other challenge  is to carry  these
successes to achieve an environmental standard that excels even where the standards
are less stringent and the vehicles  for Recycling and Pollution  Prevention efforts are
not available.

The EMS at GEMS has another measurement tool that maintains a constant vigil at
monthly progress called SCORECARD.  This is a system of providing a numerical
score  for each  line item of Environment, Health and Safety issues listed on  the
Scorecard by the site EHS  Specialist.  The score is a reflection of the  level of
satisfactory performance  in a variety of EHS issues  including compliance  and PP
issues. The Scorecard is presented to the facility manager/Business Team Leader for
the site for review and resolution. The Scorecard also enables each site to be rated on
a scale of 0-5 for the month,  with 5 for excellent EHS management and results.  A
one page comparison  summary of such a score on a 0-5 scale for each GEMS site is
called Trotter Matrix.  This matrix gives a one  glance comparison of general EHS
performance and this is transmitted to CEP for review in comparison with other GE
businesses. The monthly generation of such performance data  on compliance, spills,
accidents and injuries provides a very meaningful review of the indirect correlation
that exists  most of the times between Pollution  Prevention efforts and other EHS
measurements.  A trend can usually forewarn or indicate continued improvements in
the R  &  PP goals.   Such  measurements  are annually reviewed by the  Facility
Managers/ Business Team Leaders with the CEO of GEMS along with CEP personnel
in a "state of the EHS at the site" type of meeting called Session  E.  These formal
appraisals of the annual EHS audit findings and monthly scores on EHS performance
certainly keep  the focus on continued improvements in changing business  and
environmental factors.

The Pollution Prevention efforts have also been extended to maintenance of outdoor
areas in view of the Storm Water permitting program.  A concentrated  effort was
made in late 19947 early 1995 to form Storm Water Pollution Prevention Team at each
site, collect storm water samples on a voluntary basis.  Then site specific Storm Water
Pollution Prevention Plans ( SWPPPs) were developed at all the Wisconsin sites.  The
Wisconsin Department of Natural  Resources issued Tier n permits initially to these
sites according to the general storm water permit program and then after due scrutiny
of each site and additional revisions to some of the SWPPP issued  a lower permit
status.  These efforts led  to formal issuance  of a Storm Water Pollution Prevention
policy statement in GEMS to add another dimension to the PP efforts.
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The proof of the pudding certainly lies in the final results achieved rather the actions
performed  or intended  to be performed  in the field  of Recycling and Pollution
Prevention.  The data to follow has been compiled using the information available
from the major manufacturing sites and the RC.  It is not a comparison of success at
each site but a focus on the type of success achieved at each site hi the recent years.

The results achieved in GEMS may be summarized with the
following data:
                     RECYCLING CENTER

YEAR       TOTAL EQUIPMENT WASTE RECYCLED          REVENUE

1993                     7,086,486 Ibs.               More than SIM, < #2M

1994                     8,496,740 Ibs.              More than $2M, < S3M

1995                     10,049,724 Ibs.              More than $4 Million

1996                     11,500,000 Ibs.              Approx $4 Million

1997                     13,000,000 Ibs.             Approx. $4.5 million


                    POLLUTION PREVENTION
                               leading to
                   Hazardous Waste Reduction (Ibs.)

YEAR CT    X-RAY TROUT   EA      MR®, FLORENCE#   TARGET*
1990  4,838    -              -   -        -              69^45

1991  3,422 9,010  12,908   >900,000   16,150   +16,000   36,656

1992  2,700 6,562  11,925    833,143  4,525    +14,750   16,884

1993  2,476 1,467  9,969     339.178  9,600    +11,600   2,320

1994  2^44 2,869  6,885     307,596  12,000   +< 1,000  675

1995  2332 4,097  <  1,000   289,250   12,755    + < 750   0
            Solvent used in 1996         0         +00
1996  2,980 1,289  919       211,733   1,591     31,700*   1,116**

1997  1,203 907    775       153,439  638*      25,666*  733**
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@: The use of Methylene Chloride is shown here and its use was eliminated in November 1995.

#:  This shows the estimated combined usage of TCA, MIBK, Toluene and Methylene Chloride.

A:   This column shows the reduction in the use of 1,1,1 Trichloroethane.

*      Total Hazardous Waste
**     Waste Methanol

+      Quantity of Waste acetone, Waste Petroleum Naphtha & other flammable solid waste
        generated in the past years.
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                   Lee Sanders




     Honda Transmission Manufacturing (HTM)
"After the Party-The Real Value of ISO 14000 Certification "
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                 Ariel G. Schrodt

          Dover Industrial Chrome, Inc.
Elimination of Fume Emission in Hard Chromium Plating
     Through Use of A Perfluorinated Surfactant"
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Ariel G. Schrodt Biographical Information


Dr. Schrodt has been President and owner of Dover Industrial Chrome, Inc.
since 1976. acquiring TVJ Electroforming in 1989.  Before entering the
electroplating industry, Dr. Schrodt was employed primarily in the field of nuclear
radiation measurement instrumentation and radioisotope applications He
received his M S. degree in Inorganic Chemistry in 1949. and was then
employed  in the radioisotope laboratory of Eli Lilly & Co for two and a half years
before returning to his doctoral research  Dr. Schrodt received his Ph D in
Physical and Nuclear Chemistry from the University of Chicago in 1954. under
the direction of Dr. Willard F.  Libby. He then served as a  1st Lt. in the Army
Medical Service Corp. Department of Biophysics at the Walter Reed Army
Institute of Research until 1957.  From 1957 to 1963 he was employed by
Nuclear Chicago Corporation as Director of Detector Development and
Radiochemistry  In 1963 Dr  Schrodt founded Mitec Engineering Laboratories
which he owned and directed until 1973.  Dr. Schrodt also served as Scientific
Director of the Packard Instrument Co.  1964  until 1971  Dr. Schrodt served as
Executive  Vice President of Nuclear Systems, Inc.  1973 to 1975  He served as a
consultant to the Diagnostics Division of Abbott Laboratories 1975 to 1976
Dr Schrodt is a member of the American Chemical Society, the American
Physical Society, the American Electroplaters and Surface Finishers Society, the
American  Society for Metals,  the Chicago Metal Finishers Institute and the
Experimental Aircraft Association.  He is a pilot and a classical pianist.
Dr Schrodt has served as a Trustee of Kendall College in Evanston since 1960.
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Presentation by
Ariel G. Schrodt, Ph.D., President and Owner of Dover Industrial Chrome, Inc.

Elimination of Fume Emission in Hard Chromium Plating through use of a
Perfluorinated Surfactant

Dover Industrial Chrome, Inc., also know as Dover/TVJ, is a small electroplating
and electroforming business. The hard chromium plating facility was established
at the present location in 1945.  The TVJ electroforming business was acquired
and moved to the same location in 1989.  Dover specializes in hard chromium
plating of rollers and cylinders of small to medium size. TVJ electroforms objects
of art, components for industrial, medical and aerospace applications, and unique
devices for scientific research.  Current research and development activities
include plating of aluminum-manganese alloys from molten salts and
electroforming of microstructures in patterns generated by x-ray lithography.

The chrome plating facility has seven tanks, with volumes ranging from 400 to
2500 gallons, situated within a retention basin and vented through a common
underground tunnel. The tanks have exhaust slots along or around their top
edge, which open  to a plenum in turn connecting to the main tunnel. This tunnel
is vented through two connecting tunnels by two 25,000 cfm blowers, exhausting
through stacks on  the roof. The tanks have flat plate heat exchangers which are
employed in small volume loops to effectively isolate the tank coils from steam or
cold water sources, permitting recycling of steam and water.  There are seven
rectifiers with a total maximum output of 25,000 amps. Current chrome plating
operations are accomplished with about 15 million ampere hours per year.

Until the use of perflourinated surfactants was adopted, chrome fumes were
troublesome in a number of ways.  Air quality in the plant was acceptable to
OSHA, but still irritable. Air emissions were better than for plants with more
direct exhaust ducting - the underground tunnel system served to strip chromic
acid from the air stream - but we were generating a waste stream from the
accumulation  in the tunnels and blowers.  The blowers corroded and were short
lived. Plastic balls were tried as a tank cover but were troublesome and quickly
abandoned. Hydrocarbon surfactants were tried, but proved to be too short lived.
Even a totally enclosed, fume recycling system, such as had been patented in
Finland in the1970s was contemplated, but was deemed too difficult and too
expensive to establish for all of our tanks. Air baffles, positioned directly above
the cathode, were sometimes used to deflect the fumes towards the exhaust
slots; these did help to improve air quality in the plant.

It was in July 1989 that we  received information and technical data on
perfluorinated surfactants from Dr Cornelia Dorzbach-Lange of the Mobay
Corporation, a Bayer U.S.A. Inc. company.  Dr. Dorzbach-Lange also visited
Dover in 1989 to further acquaint us with their Fluorotensides FT 248 and FT248
R, which were being used successfully in hard chromium  plating operations in
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Europe. While not revealing the exact composition of these products, their
technical literature used sodium perfluouro-octane sulfonate as an example
representing this family of products.  The information supplied stated that to
minimize consumption, the surface tension of the bath should be maintained
below 30 dynes/cm, and that to acheive 99.9% elimination of chrome from the
hydrogen gas escaping, a level of 25 dynes/cm would be required. (Our recent
experience has indeed confirmed this).  In spite of the impressive results
obtained with use ot the Fluorotensides  by platers in Europe, and expertly
presented to us, we did not immediately choose to apply the surfactants at
Dover.

In the fall of 1993,  Atotech made a major promotion to the chrome plating
industry, for their Fumetrol (R) fume suppressants.  Some of the illustrations in
that promotional literature and references to German usage led me to the
conclusion that Atotech was marketing the Mobay (Bayer) products that I had
learned about four years earlier. By this time I was ready, accepting of the idea,
and totally convinced that the way to proceed was to keep the chrome in the
tanks and  not to let it escape and then have to clean it up somewhere else.
I immediately requested a sample quantity to try in just one tank . While the trial
sample quantity was insufficient to achieve the optimum surface tension in that
tank, the effective fume reduction was so dramatic, so readily observable without
use of instrumentation, with no detectable change in the chrome deposit quality,
that I immediately ordered Fumetrol 140 to place in all of the tanks.

Before making the additions to all of the tanks in January 1994, we invited
members of the Basic Industry Research Laboratory (BIRL) of Northwestern
University, who were participating in  a federally funded project on waste
minimization, to come to Dover to make observations of our use of Fumetrol 140.
BIRL personnel made measurements of surface tension and set up air samplers
with intakes only a few inches above the chrome plating solutions.
Measurements were made before and after initial surfactant additions. Surface
tension was measured by BIRL using a  ring tensiometer. From a limited number
of measurements, it was concluded that fume reduction of at least 98% resulted
when the surface tension was brought to a level of 28 dynes/cm.

Early in the use of the surfactants at Dover, the decision was made to maintain
surface tension at a level of 30 dynes/cm or less, in view of the recommendations
found in the Mobay literature. Stalagmometers, purchased initially for their
economy,  have been used for routine surface tension measurements, although
the lab at Dover is now equipped with a ring tensiometer, used as a check and
for comparisons.

With experience and reference to records for each tank, surfactant
additions can be made based on ampere hours of usage and an  experienced
operator can judge the need for surfactant additions by observing the tank
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surface characteristics, such as foam blanket distribution.  The cleanliness of a
white paper held just a few inches above the tank solution where the gas is rising
from the cathode is also a reliable way to demonstrate the efficacy and
sufficiency of the surfactant.

Except for a brief period in 1994, in which some pitting problems occurred in tank
# 2, primarily when plating chrome on nickel, we have had an entirely satisfactory
experience with our use of perfluorinated surfactants. Since this problem was
peculiar to only this one tank, it was believed due to some contaminant
inadvertently introduced, or to some impurities already in the tank being released
to float to the surface where they might cling to a part being introduced to the
tank. The problem was eliminated by removal of the solution surface layer and
cleaning of the tank walls.  BIRL made independent plating tests on a portion of
the solution and did not find any pitting problem.

It should be noted that in mid 1994 the use of flouride catalysts in all of the
hard chrome plating tanks was stopped so as to reduce the corrosion of lead
(6% antimony) anodes and the formation of lead chromate sludge waste.
All tanks are now maintained with 100:1  ratio of chromic acid to sulfate.

A report on the Dover experience with use of perfluorinated surfactants for
fume elimination was made in a paper presented to the fall meeting of the
American Chemical Society in 1995. Benefits experienced were outlined and
surfactant usage relative to ampere  hours of plating was illustrated.

With price increases by Atotech and the availability of other perfluorinated
surfactant compounds on the market, in 1995 we decided to evaluate
alternatives such as the Rin, Inc. /Accurate Engineering Laboratories offering of
Lo-Mist M/R.  Lo-Mist products are believed to be from the 3M family of Flourad
(TM) surfactants which includes FC-95 and FC-98, containing potassium
perfluoroalkyl sulfonates and FC-99, which contains amine perfluoro alkyl
sulfonates. After testing in our #3 tank with entirely satisfactory and equivalent
results, in 1996 we began using, and have continued to use, Lo-Mist M/R
exclusively in all of our tanks. With only minor variations due to tank surface area
and average current employed, maintenance of surface tension at a level of 30
dynes/cm typically requires addition of one gallon of Lo-Mist M/R per 750,000
ampere hours.

We have found that the use of the perflourinated surfactants does not place any
limit on the thickness of chromium that can be deposited, nor does it have any

effect upon hardness.  Important benefits to be noted are:
     *Elimination of a significant waste stream from ventilation tunnel and
blower clean out.
     *Greatly extended blower lifetime.
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      *Easier rinsing over the tanks with less water required.
      *A truly remarkable purity of air in the shop, such that visitors often
comment on it.

Some questions remain regarding the ultimate fate of the added surfactant.
Evaporation and electrolysis have been suggested.  Early research in Germany
showed no evidence of fluoride ion build up in the bath, but there may be some
breakdown of the surfactant molecules into volatile lower molecular weight
species.

On July 11, 1997, Scientific Control Laboratories of Chicago conducted tests on
the two Dover stacks that exhaust chromium emissions simultaneously.   Both
stacks, one cylindrical and the other rectangular, had been temporarily modified
in length to meet the criteria for an acceptable sampling point. The tests were
performed while plating was being done in six tanks with current applied at the
highest level appropriate for the work available in the shop for each tank. Total
ampere hours during the testing period amounted to 103,592., about 1.7 times
the average for normal working days. Surface tension in all baths was within the
range between 25 and 30 dynes/cm. Calculations from the test measurements
showed emission for the east stack at 0.0088, 0.0103 and 0.0261 mg/dscm, and
for the west stack at 0.0147, 0.0171, and 0.0170 mg/dscm, compared with the
emission limit for existing small sources of 0.03 mg/dscm.

With this result being accomplished with perfluorinated surfactants as the only
means of control, it is almost needless to say that Dover highly recommends the
use of perfluorinated surfactants in  hard chromium plating processes.
Notes: The correlation of surfactant usage with ampere hours will be shown in
view graphs at the presentation.
      A brief (3 min.) videotape showing typical tank surface appearance during
plating, rinsing over the tanks, and a white paper fume test, will be part of the
presentation.
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              Mary Setnicar




            U.S. EPA Region 5
"Partners for Environmental Voluntary Program "
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                           Mary Setnicar
               United States Environmental Protection Agency

Mary Setnicar has been with the US Environmental Protection Agency since 1985.
During that time, she has served in the Office of Policy, Planning and Evaluation in EPA
Headquarters; and here in Chicago in the Great Lakes National Program Office, and in
the Regional pesticides and toxic substances program. In her present capacity as the
chief of the Pollution Prevention and Program Initiatives Section, Mary manages the
Regional pollution prevention, municipal and industrial solid waste, medical waste, and
waste minimization programs. Before joining the EPA, Mary served 6 years on Capitol
Hill as a legislative assistant to a Member of Congress. Mary earned her Master's
degree in political science from the University of Chicago, and her BA from Marquette
University.
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PARTNERS FOR THE ENVIRONMENT
                                                               AIR QUALITY
T=
   oday nearly 7,000 businesses, trade associations, citizens
groups, state and local governments, and universities are
volunteering to improve environmental performance in a timely,
cost-effective way through an array of EPA parnertship
programs.  These efforts are not just good for the environment.
They make good business sense and prove that pollution
prevention pays—the total annual cost-savings from
participation in 1996 was $852 million

Based on the latest annual estimates, these efforts make  quite a
difference. In 1996, partners also'

- reduced over 5 million tons of solid waste.

- reduced more than 750 million pounds of toxic emissions.

- saved 199 trillion BTUs of energy

- conserved more than 1 billion gallons of water.

- prevented nearly 25 million metric tons of greenhouse gas
 emissions.

Known collectively as Partners for the Environment, these
programs complement traditional regulatory approaches to
environmental protection.  Partners set practical, meaningful
goals to improve and better protect the environment-from
conserving water and energy to reducing hazardous emissions,
waste, and pesticide risks.

To find out more, check the partnership programs of interest in
this brochure and mail it back to EPA. Or contact the programs
directly  On the Internet, go to .
AGRICULTURE

AgSTAR
Promotes cost-effective methods for reducing methane emissions
at dairy and swine operations through improved manure
management. 202-564-9041

Pesticide Environmental Stewardship
Promotes integrated pest management and reduces pesticide risk
in agricultural and nonagncultural settings
800-972-7717

Ruminant Livestock Efficiency
Reduces methane emissions from ruminant livestock operations
202-564-9043
Indoor Environments
Promotes simple, low-cost methods for reducing indoor air
quality nsks. 202-564-9733


ENERGY EFFICIENCY AND GLOBAL
CLIMATE CHANGE

Climate Wise
Reduces industrial greenhouse gas emissions and energy costs
through comprehensive pollution prevention and energy
efficiency programs. 202-260-4407

Coalbed Methane Outreach
Increases methane recovery at coal mines. 202-564-9168

Energy Star
Maximizes energy efficiency in commercial, industrial, and
residential settings by promoting new building and product
design and practices  888-STAR-YES (782-7937)

Landfill Methane Outreach
Reduces methane emissions from landfills by installing products
to capture gases and produce electricity, steam, or boiler fuel.
202-564-9768

Natural Gas STAR
Encourages natural gas industry to reduce leaks through cost-
effective best management practices. 202-260-9793

Transportation Partners
Assists communities in reducing reliance on single occupancy
vehicles and promoting more environmentally sound
transportation alternatives.  202-564-9793

State and Local Outreach
Reduces greenhouse gas emissions from states and local
communities by empowering officials with information and
technical assistance 202-260-4314

Voluntary Aluminum Industrial Partnership
Reduces perflouorocarbon gas emissions from aluminum
smelting  202-564-9044
                                                               POLLUTION PREVENTION

                                                               Design for the Environment
                                                               Helps businesses incorporate environmental considerations into
                                                               the design of products, processes, and technical and management
                                                               systems. 202-260-1714

                                                               Environmental Accounting
                                                               Increases business understanding of environmental costs and
-------
incorporation of these costs into routine operations.
202-260-3844

Green Chemistry
Promotes the design of chemical products and processes that
reduce or eliminate the use and generation of hazardous
substances 202-260-3960


REGULATORY INNOVATION

Common Sense Initiative
Develops sector-based environmental management strategies
tailored to the auto manufacturing; computers and electronics;
iron and steel metal finishing; petroleum refining; and printing
industries.  202-260-3413

Environmental Leadership
Recognizes and rewards facilities that demonstrate strong
environmental performance and commit to go beyond
compliance with existing requirements. 202-564-5081

Project XL
Allows companies to test alternative approaches that achieve
cleaner and cheaper environmental results than would be
realized under existing requirements. 202-260-4297
WATER CONSERVATION

WAVE
Promotes water efficiency in hotels, schools, universities, and
office buildings. 202-260-7288
WASTE MANAGEMENT

Waste Minimization National Plan
Reduces persistent, bioaccumulative, and toxic chemicals in
hazardous waste. 703-308-9402

WasteWise
Reduces business solid waste through prevention, reuse and
recycling. 703-308-7273
EPA'S REGIONAL PROGRAMS

In addition to the national programs described above, EPA's ten
regional offices have set up voluntary programs aimed at addressing
specific regional environmental priorities.

Region 1 (CT, ME, MA, NH, RI, VT)
CLEAN, Star Track, Partners for Change, Environmental Merit
Awards. 888-EPA-7341

Region 2 (NJ, NY, PR, VI) 212-637-3764

Region 3 (DE, DC, MD, PA, VA, WV)
Business Assistance Center, Chesapeake Bay Program, Green
Communities, Chemical Safety Audit Program, Voluntary
Initiative for Pollution Prevention.  800-438-2472

Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
Life Cycle Management, Southern Appalachian Mountains
Initiative, Urban Initiative for Sustainable Communities,
Chemical Safety Audits. 404-562-9610

Region 5 (IL, IN, MI, MN, OH, WI)
Beneficial Landscaping, Great Printers Protect, PCB
Phasedown, PCB  Used Oil, Clean Sweep, US Auto Project,
Waste Minimization Opportunity Assessments, Chlor-Alkali
Industry Mercury  Reduction Project. 312-353-4669

Region 6 (AR, LA, NM, OK, TX)
Streamline delisting process, P2 permitting pilot, Regional
Administrators Environmental Excellence Awards.
800-887-6063

Region 7 (IA, KS, MO, NE)
Pollution Prevention Awards for Environmental Excellence
800-233-0425

Region 8 (CO, MT, ND, SD, UT, WY)
Air Quality Initiative  through Western Governor's Association,
Environmental Technology Program, Children in their Earliest
Years, EMPACT, Mining, Urban Livability Initiative, Utah
2002 Olympics, American Heritage Rivers, Oil Pit Initiative
800-227-8917

Region 9 (AZ, CA, HI, NV, AS, GU)
Agriculture Initiative, Green Business Recognition Program,
Merit Partnership for Pollution Prevention, South Phoenix/Los
Angeles Metal Finishing Project. 415-744-2149

Region 10 (AK, ID, OR, WA)
The Evergreen Award honors leaders in the business community
who demonstrate  that pollution prevention is a sound business
practice. 206-553-4072
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Partners for the Environment
                 mmmm mmm  xj-zf^t*
          EPA's Partnership Programs
                                                                  A NEW WAY OF DOING BUSINESS
                                                          Through an array of partnarsNp programs callad Partneri for the
                                                        Enuronment, EPA Is damonslratlng thai voluntary commltiranli achiava
                                                               tlmaly and cost-affactiva anvtronmantal rasults.
   Benefits of Being a Partner
Why partner with EPA?
Partners for the Environment Makes a Real
               Difference        	\  _
                              _   I
* In 1997, our partnars rwJucad ^
 toxic emissions by 750
 million pounds;
                                                         • Blmlnat»d 7.6 million tons of
                                                          solid vnsta from antarlng our
                                                          landnils;
                                                         . Raducad graanhousa g«s
                                                          •missions by pravantlng 79
                                                          million matrlc tons of CO2
                                                          •missions.
                       •  These programs
                       don't just reduce
                       pollution they also
                       save energy.

                         Over 8,000
                       partners from every
                       major sector of the
                       economy, from
                       Fortune 500
                       companies to small
                       shop owners.
 Being  a  Partner Pays
                       Partners for the
                       Environment are good
                       for the environment
                       and makes good
                       business cents!!

                       Collectively Partners
                       saved 1.6 billion (up
                       from $852 million in
                       1996); and expect to
                       save $4.6 billion
                       annually by the year
                       2000.
-------
 Partnership  Programs
-» Reduce indoor air
  pollution & pesticide ri:
  - Indoor Environments
   Program
  - Pesticide Environmental;
   Stewardship Program
   (PESP)
  -» Conserve water and
   energy;
  - Water Alliances for
   Voluntary Efficiency
   Program (WAVE)
    Recognition for Achievements
                               —OSS,
    EPA's partnership programs has
      conducted or was present at
250 recognition events that was attended
        by 15,000 participants.
Technical Assistance Available
 The Partnership Programs has produced 65
  informational and technical partnership
  program documents, and more than 900
 media articles (Journals, Newspapers, etc.)
  Partners Measures of Success
        CLOSING
 Our success shows pollution
 prevention Is becoming a   /
 central consideration in me  f
 private sector's way of doing [
 business.          t
 Our partners are achieving
 measurable results more
 quickly and with lower
 voluntary efforts.

 Reduced environmental
 pollution and health risks
 through regulatory
 approaches.
     INTERNET ADDRESS
        CHECK US OUT ON THE INTERNET AT:
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      Linda Sharkey




       AERC/MTI
"Mercury in the Environment"
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Biography

Linda Sharkey is National Accounts Manager for Advanced Environmental Recycling Company (AERC), a
leader in the mercury recycling industry.  She has responsibility for the development, coordination and
implementation of lamp, battery and other mercury recycling programs for several Fortune 500 clients
nationally. Ms. Sharkey has been employed with AERC for more than five years.  She previously worked in
project management for an energy conservation company. Ms. Sharkey graduated from Kent State
University in 1989 with a BA in Journalism.
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                                Mercury in the Environment
Introduction

What do fluorescent lamps, sphygmomanometers,  thermostats, old paint and dental  amalgam have in
common? Mercury.

Mercury is a vital part of a great number of household and industrial products (Attachment I). While its
unusual characteristics have made it one of the most widely used applications, mercury's neurotoxicity and
its presence in the environment, have led to recent efforts to eliminate it from many applications.


Characteristic and Effects of Mercury

Mercury, also known as quicksilver, or Hg  (for hydrargyrum), is a metallic, silvery, heavy, toxic liquid at
room temperature.   For  years, mercury was  mined from the earth in the solid form as the ore cinnabar
(HgS), and was converted to metallic mercury by roasting or heating it in the presence of air or  lime.
Today, mercury is sourced domestically from secondary suppliers, with over 400 tons being produced and
sold back into the marketplace  annually,  according to the  US Geological Survey, Mineral Commodity
Summaries (1997).

Mercury's unique properties have made it useful worldwide, as evidenced by many different applications in
hospitals, schools, laboratories, industry and the home.  The quality most often employed is that  mercury is
the only metal which exists as a liquid at room temperature. It vaporizes at low temperatures (as low as 10
CF).  One of the most common applications for mercury is in lighting devices  such as  the  fluorescent or
mercury vapor lamp.  These devices contain a typical range of 10 mg to several grams of mercury per lamp,
depending on the type of lamp and the manufacturer.

Although useful in many applications, the toxicity of mercury  makes it necessary to keep it contained and
controlled from releases and spills.  Colorless and odorless, mercury vapor provides no exposure warning
properties.  Mercury is toxic by inhalation, ingestion and skin absorption with acute and chronic exposure
effects including central  nervous  system and kidney damage.  Acute exposure includes nausea, blurred
vision, painful breathing, excessive salivation and  pneumonitis, while chronic or longer  term exposure
 ncludes  memory disturbance, hypertension,  vision problems, hallucinations, tremors and  personality
changes.

Once mercury is released into the environment, it can be converted  by microorganisms into methylmercury.
Methylmercury bioaccumulates in the flesh of fish and can move up the food  chain. Bioaccumulation of
mercury within the aquatic food  chain has been well documented.  In  response to the risks posed  by
mercury, health advisors in more  than 35 states have warned the public about  consuming mercury-tainted
fish.
Waste Management Practices

Improper  disposal of  mercury-containing  devices and  contributes to the  levels of mercury  in  the
environment.  It has been assumed that the largest man-made sources of environmental mercury comes
form coal-burning  plants,  primary smelting, trash burning  and the landfilling of mercury-wastes  like
fluorescent tubes  and devices.  Mercury is  now viewed by government officials as "the acid rain of the
1990's" with global levels increasing two-to-three fold over the past century.

In response to the potential risks posed by mercury, various policies have been enacted by different levels
of government.
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Federally, elemental mercury, devices and compounds may be considered hazardous waste.  Disposal
options of these items is limited by EPA under the Resource Conservation Recovery Act to the treatment
and management options outlined in  40CFR 260-279.  Since it is possible for mercury to enter the
environment is waste is incinerated or landfilled, many municipal landfills have limited have acceptance of
mercury materials.  The incineration of solid wastes has been discouraged since mercury is not destroyed
when  heated.   In addition, OSHA and DOT have  established exposure limits and handling guidelines
because of mercury's toxic characteristic. DOT considers metallic mercury a corrosive hazard with mercury
salts also being considered poisonous.

The Universal Waste Rule, promulgated in May 1995, includes mercury thermometers among the wastes
that are "universally" generated and require proper disposal. If recycled, Universal Waste may be managed
under less burdensome record keeping and transportation requirements.

Many  states have adopted additional initiatives  to encourage the recycling of lamps, batteries and other
broadly used mercury containing devices.

New Jersey, Florida, and Wisconsin, to name  a few,  have facilitated the development of county lamp
collection programs. The Universal Waste Rule, once adopted at a state level, can be amended to include
other  mercury-bearing wastestreams.    In October, Region  V announced is  hoping to improve  the
awareness of small generators.  The partnership between the  EPA and private sector, is named " Cook
County Cleansweep ." The educational training program focuses on mercury and PCB pollution prevention.


Treatment Options

When any product containing mercury reaches the end of its useful life, every attempt should be made to
keep the mercury  out of the solid wastestream. A well established and growing mercury recycling industry
provides  opportunities for households, businesses  and industries to  recycle their spent devices.    In
addition,  many devices may be replaced with mercury-free alternatives.

Consumers should take their spent mercury-containing wastes to a household hazardous waste collection
site, if one is available in the area.  These sites may  be maintained continuously or periodically, depending
on the county. Homeowner should contact their local Office of Solid  Waste Management for details.  If a
government sponsored program is not available, the homeowner should check with the product supplier.
Some retail chains are offering take back programs for batteries, lamps and thermostats.

Industrial and commercial generators should contact their waste management company to discuss disposal
options. Technology and costs differ greatly.  When  considering outlets, the generator should look to work
with companies that maximize the quantity of recovered material  and  minimize their liability through the
utilization of best available technology and safe management practices.

AERC was formed in 1990 to respond to the  needs  of industry, commercial businesses, schools and
homeowners to safely manage and recycle mercury and to minimize widespread environmental releases.
AERC uses a series  of proprietary  separation, hydrometallurgical and retort technologies for the safe
removal and recovery of mercury in these wastes. All processes are designed and operated with stringent
safety and industrial hygiene requirements to eliminate emissions of mercury into the environment, thereby
reducing pollution while providing full  service recycling of this extremely toxic substance.

Since 1992, AERC has processed  over 6 million pounds of mercury containing devices and over 10 million
fluorescent lamps.  This has  resulted on over  13 million pounds of mercury waste being diverted from
landfills and incinerators.
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                                   Attachment I
                      Typical Products Containing Mercury
Thermometers                              Sphygmomanometers (Blood Pressure Gauges)

Analytical Lab Solutions and Compounds Mercury Salts

Alkaline Batteries (older types)                Athletic Shoes w/ Flashing Lights (Before 1997)

Non-electronic Thermostats                   Fluorescent Lamps

Mercury Vapor Lamps                        Neon Lamps

High Pressure Sodium Lamps                 Metal Halide Lamps

Circuit Board and Electronic Switches          Automotive Headlamps

Gas Flow Regulators                         Clothes / Curling Irons with Auto. Shut Off

Antibacterial Sprays / Ointments               Eye Tincture /  Some Contact Lens Disinfectants

Latex Paint Before 1990                       Some Oil Based Paint

Dental Amalgams                           Manometers

Barometers                                 Vacuum Gauges

Some Packaging Inks                        Chemistry Sets

Toys and Games (Older)                      Industrial Catalysts

Some  Switches in Sump Pumps, Chest Freezers,  Clothes Washers, Automotive Hood and Trunk
Lights

Mercuric Oxide Batteries (Can be Found in Some Children's Books and Watches)

Thermostat Probes Found in Some Gas Ranges, Ovens, Clothes Dryers, Water Heaters, Furnaces,
Space Heaters
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              James Sherman/Tom Barnett
                 (see Tom Barnett for paper)
                   Ispat Inland Inc.
"Magnetic Separator Usage in Steel Processing Alkali Cleaning
                  Solution Applications"
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                                Jim Sherman
Mr. Sherman is currently a Technical Consultant within the Central Engineering Dept. of
Ispat Inland Inc.  Jim has been in the engineering dept. for more than 30 years with
projects and project responsibilities ranging from design and engineering management for
installation of various sheet steel and bar product rolling mill facilities to design,
engineering management and installation of wastewater treatment plant operations. Mr.
Sherman was the individual primarily responsible for design, installation and
implementation of the alkali cleaning solution magnetic separator project being presented
at this conference.
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                      Jake Smith

                   Hennepin County
Dept. of Environmental Services, Environmental Protection
                       Division
  "Promoting P2 Activities for Hazardous Waste Generators in
                   Hennepin County"
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                                 BIOGRAPHY

                                   Jake Smith

Jake Smith is an Environmentalist in the Environmental Protection Division of Hennepin
County Department of Environmental Services. The Environmental Protection Division
regulates businesses that generate hazardous waste. Jake is currently the project manager
of a grant to promote pollution prevention activities for businesses that generate
hazardous waste. He is responsible for the division's generator outreach and training
program, and has worked as a hazardous waste inspector. His prior experience includes
15 years in the leather tanning, air pollution control, and dry cleaning industries, working
as both a research director and an environmental manager. Jake has a B.S. in Chemical
Engineering from the University of Massachusetts at Lowell and is a Certified Hazardous
Materials Manager.
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Promoting Pollution Prevention Activities for Hazardous Waste Generators in Hennepin
County

The Environmental Protection Division is responsible for enforcing the Minnesota
hazardous waste regulations for businesses in the county. All businesses generating
hazardous waste are licensed by the county and subject to periodic inspections by county
staff. The county licenses about 4500 businesses and inspects about 2300 businesses
annually.

The division has developed an extensive outreach program to ensure that businesses
generating hazardous waste are aware of the regulations and know what is required to be
in compliance. The outreach program consists of monthly training sessions, daily
telephone assistance, fact sheets, semi-annual mailings and a semi-annual newsletter.
During inspections staff is able to answer regulatory questions, provide information, and
ensure compliance.

In 1997 the division received a grant from the Minnesota Office of Environmental
Assistance to assess existing waste minimization efforts and pollution prevention
activities of businesses and to determine outreach activities that could be used to increase
awareness of pollution prevention opportunities. This presentation will  review assessment
results and present examples of outreach materials being developed to integrate pollution
prevention into existing county programs.
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        Sue Sommerfelt

  Iowa Waste Reduction Center
"Taking Automotive P2 on the Road:
     Mobile Outreach for P2"
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                  Biographical Information for Sue Sommerfelt

      Sue Sommerfelt is a Waste Reduction Specialist at the Iowa Waste Reduction
Center.  The center provides hands-on waste reduction and pollution prevention
assistance to Iowa's small businesses. She is also the coordinator of the Mobile
Outreach for Pollution Prevention (or MOPP) project where she travels extensively
throughout the U.S. and Iowa.  Sue has a bachelor of arts in Science: Environmental
Planning from the University of Northern Iowa and is currently studying for a Masters in
Public Policy.
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                         Taking Automotive P2 on the Road:
                       Mobile Outreach for Pollution Prevention

       The Mobile Outreach for Pollution Prevention (MOPP) is a 34-foot motor home
customized to exhibit commercially available equipment useful in waste reduction efforts. The
MOPP is geared toward waste streams commonly generated from the vehicle maintenance and
automobile body repair industry. The MOPP is based on a pilot project conducted in a five-
county area of Northeast Iowa in 1992 called "Solutions for Rural Waste Management." The
Iowa Waste Reduction Center, at the University of Northern Iowa, established the newest
demonstration unit in January, 1995.

       The pilot project gathered information on wastes generated by small businesses in the
area.  Automotive waste streams were identified as a focus for continuing efforts, from the
survey data. The final evaluation of the study area also revealed that recycling and reuse of
hazardous wastes increased by 74% and that the use of on-site, illegal incineration of wastes
decreased by over 50%.

       Since the pilot project,  the nine-step implementation plan for a mobile demonstration
unit has been refined by working with diverse groups of partners throughout the nation.  The
MOPP was initially funded through a grant from the Northwest Area Foundation. Current efforts
are sponsored through a cooperative agreement with the Environmental Protection Agency.
The MOP is currently touring its home state by working with partners at the county level. Out-
of-state demonstrations were  conducted in Georgia, Idaho, Kansas, Maryland, Minnesota,
Missouri, Nebraska,  Pennsylvania and Wyoming.

       The Idaho MOPP partnership was the most extensive demonstration tour to date. The
partners included state agencies, tribal governments, and educational institutions.  The MOPP
spent eight weeks touring the  state of Idaho, traveling 3,000 miles and visiting 34 communities.

       Minnesota and Nebraska each hosted a week-long tour.  The Minnesota partners
focused on one specific area,  the Lake Superior Basin. Nebraska chose to spread out, touring
across the entire state by placing an emphasis on the educational aspect of the demonstration
unit the first year. The demonstrations were hosted by community colleges with automotive
programs.  In the second year, the Nebraska Department of Environmental Quality partnered
with the Nebraska Public Power District and others. The two weeks of demonstrations were
hosted by the power plants in  conjunction with the  Keep America Beautiful affiliates throughout
the state.

       Each MOPP demonstration is conducted at a central site within a community.  Vehicle
maintenance,  automobile body shops  and metal manufacturers are invited to attend, usually
through direct mail and personal contact from the partnership members.

       Businesses attending are given a hands-on demonstration with antifreeze recycling
equipment, a solvent still, paint gun wash unit, spray painting techniques and alternative parts
washing options. At the demonstration a regulatory expert is available to discuss specific
requirements in a non-threatening environment. The MOPP also houses a display of waste
reduction manuals, regulatory summaries, and lists of vendors providing the recommended
service or equipment.
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         Christopher Start/Scott Wells

Energy, Environment, Health and Safety Services
  Michigan Manufacturing Technology Center
  "MEDS: A Technology Division Support Tool for
             Industrial Job Shops"
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                       Christopher L. Start
THE AUTHOR

Christopher L. Start is the MEDS Project Manager, and an Environmental Engineer with
MMTC's Energy, Environment,  Health & Safety Department, 2901 Hubbard Rd. P.O.
Box 1485, Ann Arbor, MI 48106-1485; Phone: (734) 769-4413; FAX: (734) 213-3408;
E-mail cstart@mmtc.org. He has a BA hi Biology from the Virginia Military Institute
(Lexington, VA),  and a MS hi Hazardous  Waste Management from Wayne State
University (Detroit, MI). He is a Certified Hazardous Materials Manager (CHMM), and
has taken ISO 9000 Certified Auditor Training. He has taken additional training hi
hazardous waste operations and emergency  response through  OSHA and the U.S.
Department of Transportation.
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             MEDS:
A Technology Decision Support Tool
     for Industrial Job Shops
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ABSTRACT

The  Manufacturing Efficiency Decision Support (MEDS) program  is a web-based decision
support tool  that  provides users with information on  the  performance,  cost, energy, and
environmental implications of alternative manufacturing technologies, so that  more realistic
comparisons and evaluations of technology options can be made.

The MEDS decision support tool is designed to improve decision-making by expanding the range
of alternatives considered.  Using "what  if?" analyses on  several essential variables such  as
budget constraints, MEDS provides objective  and detailed information on the costs and benefits
of technology alternatives.   The program  is designed  to work within a typical job-shop
environment. Designed for specific manufacturing industries, the tool will save the user time in
researching the multitude of possible manufacturing and pollution prevention solutions for small-
medium sized manufacturers in the following areas:

   •   Fabricated Metals (Plating, Coating, Stamping, Machining)
   •   Plastics
   •   Electronics and Computers
   •   Plant Utilities (Energy, Environmental  and Parts Washing Systems)

The  product is World Wide  Web-based  for ease of access  and  updating.  The MEDS tool
integrates energy,  environmental, and manufacturing aspects of a technology application.  The
MEDS tool provides the user with a good framework and an initial set of data  to begin with,
while more  in-depth information will be provided via links to  other established web  sites.
MEDS provides a user-friendly interface for novice as well as veteran Internet users to allow for
more efficient use of time.  Intended users include NIST/Manufacturing Extension Partnership
(MEP) centers' field agents, DOE  Industrial Assessment  Center  engineers,   P2 technical
assistance providers, as well as industry personnel and management.

MEDS allows the  user to focus on solutions that have the highest probability of success.  It does
this by providing five key information areas for each technology:

   •   Background Information (including a photo)
   •   Case Study
   •   Economic Feasibility
   •   Technical Feasibility
   •   Vendor Information

KEYWORDS

The MEDS web site is located at: http:\\meds.mmtc.org, or you can  use any of the  popular search
engines to locate the site on the World Wide Web.  The following are just a few of the keywords
that can be used:  "MEDS", "NIST-MEP", "Manufacturing Technology", "Energy Equipment",
and "Environmental Equipment".
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INTRODUCTION

The  World  Wide Web can  be an  excellent research  tool because  of the wide  range of
organizations that promote their ideas, missions, and products through web sites. Web content
has grown as the number of users has grown.  Nearly 100 million  people now search for
entertainment, commerce, and news.   A recent Business Week/Harris poll  found that 50% of
users conduct web research.   However, the majority of web content, especially manufacturing
related, is non-interactive or static text while the web's features allow much more interaction with
the user. A new web site called Manufacturing Efficiency Decision Support (MEDS) has been
developed to provide an interactive manufacturing technology assessment tool.

DISCUSSION

There are many valuable sites for manufacturers and manufacturing consultants.  For example,
The  Thomas  Register of American  Manufacturers, a  product, service, and vendor  listing
catalogue, has a web site which, in addition to providing information currently in the Thomas
Register book, also links to vendor sites. The Gas Research Institute's web site offers applied and
basic research reports, and gas industry and product news. Federal government agencies such as
the Environmental Protection  Agency, Department of Energy, and Department of Commerce, as
well as  State governments, have excellent  sites that provide regulatory information, technical
reviews, databases, current event information, and descriptions of government services. Many of
these sites have some interactive components such as keyword search engines, online discussion
groups,  and, in the vendor sites, forms to submit requests for product quotes.

In general, however, most manufacturing related web content is static. In other words,  a  user
visits the site, reads the material, perhaps prints it and then moves on to another site.  Contrast
this to other industries that take advantage of interactive web features and benefits such as two-
way  communication, immediate update of information, and inexpensive distribution of programs
and material.  A good example is the financial services industry, which has been revolutionized
by the web.  Online banking and trading is now readily available.

Manufacturers can benefit from web based tools that use more of the web's  features.  Industrial
Technology  Institute's MEDS  web  site  (http://meds.mmtc.org)  provides  traditional  static
information on the performance,  cost, energy, and  environmental  implications of alternative
manufacturing technologies.   It also has interactive components that  allow users to conduct
technical and economic "what if?" analyses with their facility's parameters.  MEDS is designed to
work within the realities of manufacturing,  which  include  partial  cost,  performance  and
technology information, as well as budget and time constraints.

Manufacturers frequently  face technology  feasibility  questions  such as  "Should  I  install
capacitors to eliminate my power factor charge?",  "Is there a good alternative to solvent based
metal parts cleaning systems?", and "Are there alternatives to chemical treatment of my cooling
tower water?" There are many different criteria on  which to base the decisions and there are
often several technically and economically feasible solutions.
-------
Let's say a plant manager faced the last question above:  "Are there  alternatives to chemical
treatment of my cooling tower water?"  Typically, the problem is segregated into separate issues
such as: What are the technical constraints in my facility?  What are the implementation costs,
savings, and payback periods for alternatives? What are the regulatory issues? What process
modifications will be required?  And, will the new system require extensive retraining of my
employees?

Traditionally, these questions are  answered by talking to  industry peers, hiring consultants,
researching the problem independently, and talking to vendors. However, each of these methods
has a downside.  Industry peers are not necessarily experts, and often base their recommendations
on their own facility's limited experience. Consultants can  be expensive if they have to invest
the time to evaluate the technology and to  understand the clients' individual requirements.
Researching the problem independently often requires large amounts of time that many small
manufacturers cannot afford, and vendors, although knowledgeable, are seldom objective in their
recommendations. Moreover, just deciding which of these  research methods to pursue can be
time consuming in itself.
MEDS replaces many of these initial technology evaluation steps by providing background
information and by enabling economic and technical "what if?"  scenarios.  The MEDS home
page is in Figure 1.

The MEDS  web site contains  a  large database of  information regarding  manufacturing
technologies. There are several ways to get to an individual technology.  First,  you can browse
the main graphical menu organized by industry sector operations.  Alternatively, you could  view
an alphabetical list of all technologies by using either the "Technology" or "Case Study"  pull-
down menus located at the top of the homepage.  And, finally, you could locate  technologies
containing  keywords using  the web site  any-word search  engine.  Selecting  the technology
"ultrasonic cleaning" from the main graphical menu, or the  technology pull-down  menu would
lead to the Technology Feasibility screen for ultrasonic cleaning (Figure 2).

The technology menu bar across the top of the screen provides access to five separate sections for
each technology:  Background Information, Case Studies,  Economic Feasibility, Technology
Feasibility, and Vendor Information.  The Technology Feasibility page, an example  of MEDS1
interactive component, poses a series of questions to determine if the technology is appropriate
for a specific facility. The first several questions assess the status of the current parts cleaning
system. Two questions: "Are you currently cleaning your parts with a  non-aqueous method
involving harmful chemicals like TCE?" and "Are you cleaning small to medium parts (Parts
with a general size under 5 cu. ft.?" act as obvious kill questions. In other words, if either answer
is "no" this technology is not feasible in that  particular  circumstance.  In this screen, the
questions have been answered for a hypothetical situation.  A score of 100 has been provided
meaning that an ultrasonic cleaning system has a high probability of being technically feasible.

The Background Information section, which  is an example of a static component of MEDS,
includes a process description,  picture, required raw materials, equipment description, lists of
-------
advantages and disadvantages, and links to information sources. This section is designed so that
everyone, regardless of experience, can gain some new insight into the technology.

Selecting  Case  Studies  from the technology menu bar leads to a description  of how the
technology was used. Most of the MEDS technologies have been used by manufacturers, so case
studies are available to show how the technology was employed, what worked, and what needed
improvement.  For the technology Ozone Treatment of Cooling Tower Water the case study
describes how an ozone treatment system was chosen to replace a chemical treatment system for
four cooling towers with a 2,500-ton  capacity.   In  this example  the  surface water  quality
standards  in Florida changed, prohibiting cooling tower blow-down discharge to local surface
waters.  After the purchase and installation of a technology utilizing ozone treatment of cooling
tower water, acceptable surface water quality standards were met, and chemical and water usage
were drastically reduced along with  the permitting fees.  The ozone system had a payback of
approximately 2.5 years and a net present value of $799,705 over a 10-year life.

Next on the technology menu bar is the Economic Feasibility section, another interactive  screen,
which for  the technology Liquid Nitrogen Cooling of VOC's is shown in Figure 3.

The Economic feasibility section starts with Part A - Equipment Costs Rules of Thumb  which
gives the estimated per unit cost and the total cost of the technology.  Liquid nitrogen cooling
systems cost roughly $2,000 per SCFM up to 150 SCFM, and $1,000 per SCFM from 150-500
SCFM.  Thus a 50 SCFM unit would cost around $100,000, while a 250  SCFM unit would run
about $250,000.  The part B "Benefits" section describes the savings  that a liquid nitrogen
cooling system yields over the industry standard, which in this case is adsorption/incineration.
For example, the liquid nitrogen cooling system eliminates 40-80% of the operating costs, and
95% of the maintenance costs associated with an equivalent  capacity adsorption/incineration
system. Part C covers "Qualitative Benefits".  Next is a fill-in form used to calculate the savings
and payback period  in which users enter their existing VOC reduction operating costs, existing
VOC reduction equipment maintenance costs, and their existing flow rate of VOC contaminated
air. Once the Calculate Savings and Payback button is pushed, the annual savings in dollars, and
the estimated payback range in years is displayed.

Lastly, on the technology menu bar is the Vendor Information section. This button links to the
Thomas Register of American Manufacturers web site.  Suggested key words to search the
Register and the web for the technology are provided.

CONCLUSIONS

MEDS uses the web's static and interactive attributes to help manufacturers evaluate technologies
and identify technically and economically feasible solutions for problems.  MEDS assists with
the evaluation and selection of over 175 technologies in the following industry sectors: Plant
Utilities, Fabricated Metals, Plastics, and Electronics & Computers. Because MEDS is web-
based, it is open to public use by any relevant individuals such as manufacturing plant personnel,
consultants and academia.
-------
REFERENCES
      NIST-MEP:   The Department of Commerce's National  Institute of Standards and
      Technology (NET) is sponsoring MEDS, and will use the tool to assist  small and
      medium-sized  manufacturers  through  it's  78  member  nationwide  Manufacturing
      Extension Partnership (MEP) network. The web site, however, is also available to the
      public at: http://meds.mmtc.org.

      MMTC: MEDS was created and developed by the Michigan Manufacturing Technology
      Center (MMTC) formerly known  as  the Industrial Technology Institute (ITI) of Ann
      Arbor, Michigan.  MMTC has formed a team with more than 80 years experience in
      manufacturing and manufacturing consulting to create the web-based tool.
-------
      - mam untry roint
                      figure i
fagel of 1
Sponsored by:
Disclaimer
   BACK To:
    SEARCH
   FEEDBACK
     FAO
   PROJECT
 BACKGROUND
  EXTEKSKJN
  CREATED BY:
        "JUST
   manufacturing efficiency decision support
          Case Studies                  Technology List
Select an area below or go directly to a technology by using one of the listings above

 I	
                       plant utilities
                       electronics & computers
                      I fabricated metal products
                        plastics
                                                       - energy systems
                                                       - environmental systems
                                                       - parts washing
                                                       \- printed wiring boards
                                                         semiconductors & related devices
                                                         fabrication
                                                         surface preparation
                                                         finishing
                                                         ancillary equipment
                                                         decorating
                                                         molding
                                                         recycling
http://meds.mmtc.org
                                                                   10/19/98
-------
Ultrasonic Cleaning
Figure 2
Pagel of 1
             BACKGROUND   CASE   ECONOMIC  TECHNOLOGY    VENDOR
             INFORMATION STUDIES  FEASIBILITY  FEASIBILITY  INFORMATION
                          Technology Feasibility - Ultrasonic Cleaning
Question
Are you currently cleaning your parts with a non-aqueous
method involving harmful chemicals like TCE?
Are your workers currently exposed to a harmful
environment while handling these parts?
Are your workers spending more time on parts cleaning,
rather than other important operations?
Are you having trouble keeping the work environment
clean?
Are hazardous waste disposal costs expensive in your
area?
Are you cleaning large parts? (Parts with a general size
over 5 ft 3)
Are you cleaning "sound absorbing" parts? (Fabrics,
rubber, etc.)
Are you located in an area where pollution is a problem?
Score:
Technical Feasibility Rating:
Response
(Score
"r F^
ffYes
ff Yes
r No
F~
F—
r Yes j^ 	
ff Yes
r Yes
[30
1°
j-ioocT
«YNr r^
r No F
100
High Probability
Technical Feasibility Ratings
No Probability
Low Probability
Moderate Probability
High Probability
<1
1-40
41-80
>80
  Copyright ©1998 Industrial Technology Institute. All rights reserved.
http://meds.mmtc.org/plant_util/parts_washing/Ultrasonic%20Cleaning/_private/index.htm
                                               10/19/98
-------
Liquid Nitrogen Cooling
                                       Figure 3
                              Pagel of 1
            BACKGROUND   CASE  ECONOMIC  TECHNOLOGY    VENDOR
            INFORMATION  STUDIES FEASIBILITY  FEASIBILITY  INFORMATION
                      Economic Feasibility - Liquid Nitrogen Cooling

  A. Equipment Costs Rules of Thumb
  Typical Equipment Cost
                          Estimated cost per unit
                              $2,000/SCFM:
                              to 150 SCFM

                              $1000/SCFM:
                              150-500 SCFM
                                                Estimated Total Cost
$ 100,000 = 50 SCFM unit

$250,000 = 250 SCFM unit
  B. Benefits (Savings in Operating Costs)
Area of Savings
Operating Costs
Maintenance Costs
Annual Savings
(Relative to adsorption/incineration)
40-80% |
95% !
  C. Other Benefits
  Reduces VOC and ODS emissions. Longer compliance window. Does not
  contaminate the recovered VOCs. Good reliability due to the low number of
  moving parts. No secondary pollution (contaminated water or combustion
  products) created.	
  Enter the following data to calculate the simple payback range. No dollar signs ($) or commas
  allowed.
                                                      I
                                                      r
Existing Operating Costs ($/yr)

Existing Maintenance Costs: ($/yr)

Existing Flow Rate of VOC Contaminated Stream: (SCFM) |

       Calculate Savings and Payback	I          Reset
  Savings:

  Payback range
                                                    r
                                                           years
  If you have any comments, please feel free to let us know at meds@iti.org

  disclaimer

  Copyright ©1998 Industrial Technology Institute. All nghts reserved.
 http://meds.mmtc.org/plant_utiiyenvironment/airArOCs/condensing/Liquid%20Nitrogen%.../index.ht   10/19/98
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         John W. Sutherland




  Michigan Technological University
"Waste Reduction in Machining Processes"
-------
                                    BIOGRAPHY

                              John W. Sutherland, Ph.D.

John W. Sutherland joined Michigan Technological University (MTU) in 1991 and is a Professor,
Associate Chair, and Director of Graduate Studies in the Department of Mechanical Engineering -
Engineering Mechanics.  He received his B.S. and M.S. degrees in industrial engineering, and his
Ph.D. in mechanical engineering all from the University of Illinois at Urbana-Champaign.  Prior to
coming to MTU, he was Vice-President of a consulting firm specializing in manufacturing and
quality improvement. He held an adjunct faculty position at the University of Illinois from
1985-1991.   In his university positions he has taught courses in Manufacturing Processes,
Engineering for the Environment, Statistical Process Control, Statistical Design of Experiments, NC
Machining, and Environmentally Conscious Design and Manufacturing.  Dr. Sutherland has
presented short courses on Quality Improvement to such companies as Ford, Caterpillar, Borg
Warner, and Hyster. He has published over 100 technical papers in various journals and conference
proceedings,  and is  a co-author of the textbook:  Statistical Quality  Design and  Control:
Contemporary Concepts and Methods.

Professor Sutherland has served as the advisor of 27 M.S. students and 6 Ph.D. students, and is
currently advising 17 graduate students (9 M.S. and 8 Ph.D.). He is a member of the American
Society of Mechanical Engineers, the Society of Manufacturing Engineers, the Institute of Industrial
Engineers, the American Society for Quality, Tau Beta Pi, Alpha Pi Mu, Phi Kappa Phi, Pi Tau
Sigma, and Sigma Xi.  He is a member of the Board of Directors and the Scientific Committee of
the North American Manufacturing Research Institution, serves on the Executive Committee of
ASME Manufacturing Engineering Division, and was an associate technical editor for the ASME
Transactions - Journal of Engineering for Industry from 1993-97.  Professor Sutherland was one of
the recipients of the SME Outstanding Young Manufacturing Engineer Award in  1992, received the
MTU Distinguished Teaching Award in 1992, and was selected as Teacher of the Year for the
Department of ME-EMfor the 1992-93 and 1993-94 academic years. In 1995 he was the recipient
of a National Science Foundation Career Development Award. He was selected for a Presidential
Early Career Award for Scientists and Engineers in 1996.
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-------
                    Keith Trychta




             Argonne National Laboratory
"Waste Minimization andP2 at Argonne National Laboratory"
-------
                                 KEITH TRYCHTA

                                   BIOGRAPHY
Keith Trychta is currently an employee of Argonne National Laboratory/University of Chicago
as the Pollution Prevention Coordinator under Plant Facilities and Services-Waste Management
Operations. Mr. Trychta has a B.A. from Benedictine University and a Masters of Project
Management from Keller Graduate School of Management.  Mr. Trychta has worked in the Solid
Waste and Recycling field for over a decade. Prior to his tenure at Argonne National Laboratory
(ANL), he worked for the DuPage County (Illinois) Solid Waste Department in the development
and implementation of solid waste management programs and policies. While with Dupage
County, Mr. Trychta was trained and certified by the Illinois Environmental Protection Agency
as an Environmental Enforcement Officer.

Mr. Trychta is a Co-Chairman of the ANL-E Waste Minimization and Pollution Prevention
Advisory Committee. His current position at ANL allows him to put his past experience to use,
by developing and implementing waste minimization and pollution prevention initiatives and
programs across all areas of the Laboratory.
-------
ARGONNE NATIONAL LABORATORY-EAST
 Waste Minimization and Pollution Prevention Program
        at Argonne National Laboratory-East
-------
Description of Work

Argonne National Laboratory-East with more than 200 programs in basic and applied research is operated by the
University of Chicago as part of the U.S. Department of Energy's national laboratory system. Located near Chicago, IL,
Argonne employs more than 4,500 people. Argonne's mission is basic research and technology development to meet
national goals in energy technology, environmental quality, scientific leadership, and educational infrastructure. Through
the performance of these activities,  Argonne generates radioactive waste, mixed waste, hazardous waste, State-regulated
special waste, and sanitary waste on a routine and non-routine basis.

The closure of Argonne's sanitary landfill in  1992 triggered the start of a greater awareness of all the Laboratory's waste
streams leading to the dynamic evolution of the Waste Minimization and Pollution Prevention (WM&P2) Program. The
program's rapid growth during these years is attributed to the many pollution prevention projects initiated in the 1990s.
Many of these activities were initiated through "grass roots" efforts of individuals and groups at Argonne. These efforts,
coupled with the commitment of management, are what have contributed to the continuous growth and improvement of the
ANL-E WM&P2 program, and the resulting cultural change across the Laboratory.

For example, in 1992 Argonne  did not possess direct funding for the implementation of a formal WM&P2 program, an
organized work group, a formal WM&P2 strategy, or a program plan.  In 1997, Argonne has an established WM&P2
program,  and a WM&P2 Advisory Committee with broad representation from across the Laboratory. The WM&P2
Program, and Advisory Committee,  incorporates the use of a WM&P2 Strategic Plan, a 3-year Pollution Prevention Plan,
and an annual WM&P2 Implementation Work Plan. This infrastructure and these documents are used to build upon
ANL-E's  past successes in the WM&P2 arena, and identify new initiatives that will eliminate, or reduce, potential waste
or pollution  in the future.

As Argonne's WM&P2 Program has evolved, so too has the  recognition the program has received. Argonne has won
several awards for pollution prevention initiatives within the last five years, such as the 1994 Governor's Pollution
Prevention Award and a 1994 DOE Pollution Prevention Award for identifying and developing non-hazardous cleaning
materials and  procedures for metal  surfaces within the Advanced Photon Source facility. In 1996, Argonne was named
"STAR Partners" by the Illinois  EPA. The STAR  Partner Award gives special recognition to companies who participate in
the Illinois EPA's voluntary Partners in Pollution  Prevention and acts as mentors to further use the pollution prevention
techniques in other companies. In 1997and 1998, Argonne was awarded the Illinois Governor's Pollution Prevention
Certificate of Recognition in the category of continuous improvement.  Argonne is especially proud of the it's regional
reputation as leader in Pollution Prevention.  This reputation  is a result of Argonne's commitment to establishing, and
maintaining, WM&P2 partnerships and outreach initiatives over the  past several years.

As part of it's WM&P2 strategy, Argonne has placed focus and commitment on the 1999 DOE Pollution Prevention goals.
During the past several years Argonne has may great strides to attaining all of these goals.  It is Argonne's strategy to not
only achieve these goals, but to surpass them, while evolving to the optimum goal of environmental enhancement and
stewardship.
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                                                                                             CY97 DOE

                                       Low-Level Waste Generation                           Pollution
             ,nnnft	 Prevention Goal
             20000	^=^^=.	•	_.
                                                                                         Status

                                                                                         Goal 1. Reduce
             15000 —
                                                                                         by 50 % the
                                                                                         generation of
             10000	;	'	i      I	1     I	1      i	 radioactive
                                                                                         waste.
                             !     i      i      :           <      !     i      :
              5000
                        1993       1994       1995        1996       1997     1999 Goal


                                           I  I   Cubic Feet
CY97 Low-Level Radioactive Waste generation has continued the downward trend, and is approaching levels established
by the 1999 DOE Pollution Prevention Goals. Depletion of archived waste, in conjunction with the implementation of waste
minimization and pollution prevention (WM&P2) activities, will result in a 50% reduction in radioactive waste by December
31,1999.


Goal 2.  Reduce by 50 % the generation of radioactive mixed waste.
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                              Hazardous & Special Waste Generation
       6000

       5000
       2000

       1000
                 1993
1994
1995
1996
1997
1999 Goal
                                          Metric Tons
                                                                                   CY97 Mixed Waste
generation has continued the downward trend, and continues to maintain levels below the 1999 DOE Pollution Prevention
Goals established from the 1 993 baseline.
Goal 3.  Reduce by 50 % the generation of hazardous waste.
                                    Mixed Waste Generation
   6000

   5000
   1000

       0
               1993
1994
  1995
    1996
       1997
         1999 Goal
                                             Cubic Feet
                                                                                              CY97
                                                                                              hazardous
waste generation continues to maintain levels below the 1999 DOE Pollution Prevention Goals established from the 1993
baseline.  The hazardous waste goal will be achieved by successfully identifying and implementing alternative uses for the
State-regulated waste streams, i.e., sorbent, lime sludge, fly ash, coal fines, etc., and taking advantage of the Illinois
Environmental Protection Agencies (lEPA's) new special waste regulations, which allow the Laboratory to certify some
                                                   4
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State-regulated wastes as "non-special."
Goal 4.  Reduce by 33 % the generation of sanitary waste.
                          Argonne National Laboratory 1997 Sanitary Waste Recycling
                                                                            During CY97, ANL-E continued the
                                                                            downward trend of reducing the
                                                                            amount of routine sanitary waste
                                                                            towards the 1999 DOE Pollution
                                                                            Prevention Goals established from
                                                                            the 1993 baseline. The Laboratory
has developed and is implementing aggressive recycling programs that will be used to achieve this goal. Through the
continuous improvement of recycling programs and improved data management, ANL-E will achieve this goal.
   CY97 Recycled Material 62%
   CY97 Solid Waste 38%
                                    Routine Solid, Nonhazardous Waste Generation
ouuu
zouu
orirtrt ,
<£UUU

1500
1 nnn I '

500 ' j
r\ ' ' .
, 	 .

I

I i
! , i 	 1
; ' ,
                        1993
1994
1995
1996
1997
1999 Goal
                                            	I  Metric Tons
From 1994 through 1996, ANL-E has maintained generation levels that are below the 1999 goal.
Goal 5. Reduce
by 50% total
releases and off-
site transfers for
treatment and
disposal of toxic
chemicals.

Since 1993, ANL-E
has focused on
eliminating all
forms of toxic
releases under this
goal category.
Goal 6.  Recycle 33% of sanitary waste from all operations, including cleanup and stabilization activities.
-------
During CY97, the Laboratory has generated over 35.8 million pounds of sanitary waste and materials from all operations
(including clean up and stabilization activities). ANL-E was able to recycle (reuse) 22.1 million pounds of recycled
materials from these same activities. This amounts to a 63% level of recycling of sanitary waste from all Laboratory
operations.


Goal 7.  Affirmative Procurement: Increase procurement of EPA-designated, recycled products to 100%, except
where they are not commercially available competitively at a reasonable price or do not meet performance
standards.

ANL-E is working to achieve this goal through a combination of an Affirmative Procurement Awareness Program, the
development of an upgraded procurement tracking system (PARIS), and the development and execution of Laboratory-
wide recycled product procurement procedures.
                            1997 ANL-E WM&P2 Activities and Accomplishments

The following section contains brief examples and descriptions of specific ANL-E WM&P2 activities and accomplishments
for 1997. During FY1997, the ANL-E WM&P2 Program has estimated $800,000 in cost saving/avoidance, derived from
WM&P2 activities. A complete list of all 1997 ANL-E WM&P2 activities and accomplishments is available upon request.

Low-Level Radioactive Waste - D&D Activities -1997 Estimated Cost Savings/Avoidance = $91K
    Lead amounting to 207,230 pounds was free released from the Janus D&D Project (TD) and sent to the lead bank for
    recycling. The cost avoidance is estimated at $55,000.
•   The CP-5 D&D Project (TD) recycled 700 pounds of non-radioactive cadmium. Cost avoidance is estimated at
    $3,000.
    Fifteen thousand (15,000) pounds of scrap metal were free released and shipped for recycling from the CP-5 D&D
    Project (TD). Cost avoidance and revenues are estimated at $3,500.
    During the planning of the Building 310 Retention  Tank D&D Project (TD), a change in technical approach was taken
    that shortened the project duration by approximately five months. The new approach allowed for the excavation and
    recycling of tanks as whole units and resulted in a lower estimated project cost.  While this is not a realized cost
    avoidance, it does demonstrate the cost savings that can be realized when WM&P2 efficiencies are applied.
    Fifty-five thousand (55,000) pounds of free-released lead and lead-bearing metals were recycled  by TD within the CP-
    5 project. The recycled metals included large gamma shield assemblies, 21 plugs removed from the horizontal
    storage holes in E-wing, and many smaller steel and lead components. Cost avoidance is estimated at $27,500.

Radioactive Mixed Waste Activities -1997 Estimated Cost Savings/Avoidance = $78K
    During the fourth quarter of CY97, EMO-WM decontaminated 6,807 pounds of radioactively-contarninated lead,
-------
    thereby diverting this material from the mixed waste category. EMO-WM employed the use of the CC>2 cleaning unit.
    The cost avoidance is estimated at $19,687.
    During the fourth quarter of CY97, EMO-WM released 19,025 pounds of steel encased lead, thereby diverting this
    material from the mixed waste category. The cost avoidance is estimated at $56,250.
    Through the use of microwave equipment used to prepare samples for mercury, metals, and radiochemical
    determinations, the Analytical Chemistry Laboratories reduced mixed waste generation by 15L. Cost avoidance is
    estimated at $2,000.

Hazardous and State Regulated Waste Activities -1997 Estimated Cost Savings/Avoidance = $259K
    During CY97, hazardous waste labpacking efficiency increased by 43% through use of revised procedures and
    constant diligence.  EMO-WM estimates generated a planned cost savings of over $10,000 during CY97.
•   The ANL-E WM&P2 Program team (EMO) completed PPOA and implementation activities for the ANL Surplus
    Chemical Inventory  and Exchange Pilot Program. This project was designed to investigate the transfer of surplus
    chemicals to users around Argonne and to remove chemicals from the hazardous waste stream. Cost avoidance
    derived from the pilot study are estimated to be approximately $5,000.  This PPOA and Pilot study has resulted in the
    funding of a FY98 ROI Project to further develop the Chemical surplus program at ANL-E.
    Fifty-one (51) acetylene gas cylinders (48 from PFS-Site Services and 3 from WMO) shipped to Emergency Technical
    Services Corporation (ETSC), for recycling. Because the material will be recycled, it was shipped on a  Bill of Lading
    and not a waste manifest. WM had previously  made arrangements for a discounted cost of $100 per cylinder. Cost
    avoidance is estimated at $17,850.
    The disposal of 15 out-of-service criticality detectors was completed in the month of January. The detectors were
    disassembled, the check sources removed, and counting gases (boron trifluoride) absorbed into water.  The majority
    of the detectors' components were able to be free released.  Besides the check sources, only 15 small metal cylinders
    (now empty) were managed as low-level radioactive waste.  An outside contractor gave a  price quote of over $30,000
    to complete this same work. This project  resulted in cost avoidance of $28,655.
    During CY97 PFS-US generated 1,231 tons of coal fines from coal burning activities. PFS-US established a contract to
    sell the coal fines for recycling. The revenues generated from the sale of coal fines amounted to $31,700. The cost
    avoidance realized by avoiding the management and disposal of this special waste was $67,300. Total cost
    savings/avoidance $99,000.
    Seventy (70)  large capacitors were drained of dielectric fluid. Analytical results of the drained oil determined the
    capacitors to be free of PCB's.  The empty capacitors were recycled as metal scrap. Cost savings/avoidance
    estimated at $17,000.
    PFS-BM&C successfully performed the removal of CFC-11 (Class  I ozone depletor) from two chillers located in
    Building 201 and replaced it with HCFC-123 (Class II ozone depletor). The completion of this activity resulted in a cost
    avoidance to the Laboratory of approximately $15,400, and greatly reduces the potential of ozone depleting
    substances to the environment.
    During soil sampling and groundwater sampling, "waste" soils and groundwater are produced. A policy was written,
    and eventually accepted in the ANL ESH manual which establishes protocol to discard Investigation Derived Waste
    (IDW) when sampling. EMO used this policy to justify discarding an estimated 150 drums of soil and groundwater IDW.
    The cost avoidance realized by avoiding the management and disposal of this material was $5,000.
    The ANL-E Vehicle Maintenance facility's anti-freeze reclamation and recycling initiative has resulted in the capturing
    and recycling of over 90% of the anti-freeze used in ANL-E vehicles.  Costs savings/avoidance estimated at over
    $4,000.
    The ANL-E Vehicle Maintenance facility has established procedures to control the amount of vehicle refrigerant
    released into the atmosphere. Ninety-eight (98%) of all refrigerant was reclaimed from vehicle air conditioning systems
    this past year. This initiative has resulted in a cost avoidance, inventory reduction, and increased control of an ozone-
    depleting component.
    Argonne personnel have worked with Commonwealth Edison since January 1997 to establish a recycling outlet for the
    Laboratory's fly ash.  The contract should be completed in January 1998. This agreement  would reduce the
    Laboratory's fly ash  disposal costs by 50%, and divert large volumes of material from the Laboratory's waste stream.

Sanitary Waste & Recycling Activities -1997 Estimated Cost Savings/Avoidance = $266K
    During 1997, ANL-E diverted and recycled over 1.1 million pounds  of mixed office paper or, over 35% of the routine
    sanitary waste stream. Cost savings/avoidance estimated at $50,000.
    During 1997, the ANL-E scrap metal recycling  program, managed by OCF-PIM, recycled 254,920 pounds of scrap
    metal. Cost savings/ avoidance estimated at $60,000.
    During 1997, OCF-PIM implemented a pilot program that segregated 87,000 pounds of obsolete computer and

                                                     7
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   electronic equipment from the waste stream.  Cost savings/avoidance estimated at $18,500.
•  Argonne construction and demolition (C&D) projects recycled over 17 million pounds of material in 1997. The material
   recycled amounted to approximately 57% of the C&D waste stream. Diverting these materials from the waste stream,
   resulted in revenues and cost avoidance estimated at $120,000.

Research and Development Activities
•  Argonne is helping government agencies find ways to remediate sites contaminated with hazardous materials. A pilot
   program has shown that feeding molasses  to native bacteria in TNT-contaminated soil could be a simple and cost-
   effective alternative for cleanup project across the country.
   Argonne Researchers have found a way to make "green" paint and cleaning solvents marketable. New ethyl lactate-
   based solvents would take the place of trichloroethylene and methylene chloride solvents, which  are known
   environmental contaminants. The technology would cuts the cost of producing lactic acid and ethyl lactate-based
   solvents in half.
   Argonne's Center for Transportation Research is involved with testing currently available alternative-fuel vehicles
   (AFV's);  spurring the development of advanced vehicles powered by electricity,  alternative fuels or a combination of
   the two; and developing cleaner-burning engines. Argonne maintains the largest demonstration center in the AMFA
   Program. Data collection focuses on vehicle driveability, reliability, fuel-efficiency, but other operational characteristics
   are also  monitored, such as emissions and performance under varying weather conditions. Argonne has been able to
   partner with Northern Illinois Gas and other external partners to establish a Compressed Natural  Gas fueling facilities
   at, and adjacent to, the Laboratory. Additional information relating to this project is located on the World Wide Web at
   http://www.es.anl.gov/htmls/afvinfo.html.
•  Argonne researchers have developed an oxygen enrichment device that reduces particulate emissions almost 60 %
   while increasing power. This could be the link that can help diesel engines meet federal standards for particulate and
   smoke emissions set by the Clean Air Act. Argonne's work to improve diesel engine efficiency and emissions spans
   the range from the smallest diesel engines  to locomotives. Argonne researchers work with such companies as
   Mercury Marine,  Chrysler Corp., Ford Motor Co., and General Motors Co., as well as railroad associations and transit
   authorities.

Awareness, Outreach, Partnering and Technology Exchange -1997 Estimated Cost Savings/Avoidance = $103K
•  During 1997, the ANL-E WM&P2 Program funded four Micro-Chemistry Workshops.  The Workshops were attended
   by over 120 High School Chemistry Teachers from the Chicagoland area. The purpose of the workshops was to teach
   the chemistry teachers how to employ micro-chemistry techniques into their curriculum, thereby minimizing the
   amounts of waste generated in High School chemistry experiments and to promote the principals of waste
   minimization to their students.
   Argonne participated in an ongoing Hazardous Waste Benchmarking Exercise with Abbott Laboratories located in
   North Chicago, IL. The WM&P2 benchmarking exercise focuses on each facility's hazardous waste stream and is
   designed to identify "Best-in-Class" WM&P2  policies, strategies, and methods in the area of hazardous waste
   management.
   Argonne worked with the DuPage County to implement the DuPage County Solid Waste Department Waste Survey
   and Education Program waste audit. The program established a partnership between DuPage County and Argonne,
   and provided the  Laboratory with two free waste generation assessments. The data generated from the waste
   assessments was used to develop the Illinois Construction and Demolition Recycling Guidebook which was partially
   funded by the USEPA.
   Argonne organized, "America Recycles Day" activities in November.  The theme of the  National campaign is "Keep
    Recycling Working: Buy Recycled".  There were exhibits by Illinois Recycling Services, BT Office Products, and the
   WM&P2 Advisory Committee.  Argonne organized Earth Day activities in April. Participants included the DuPage
   County Forest Preserves, Resource Management Inc.,  Laidlaw Environmental Services and Commonwealth  Edison..
    Representatives from Argonne attended the DOE Pollution Prevention Conference XIII in August. The representatives
    presented an exhibit and two poster sessions.
    During 1997, ANL-E participated in the 6th season of the Commonwealth Edison Energy Cooperative. Under this
    program ANL-E voluntarily reduced electrical demand during specific time periods. ANL-E was able to reduce power
   consumption by 2,900 kW. This waste (energy) minimizing initiative earned the Laboratory $102,700 from
   Commonwealth Edison.
   Argonne and DOE-HQ conducted a training seminar  at ANL-E  titled "Pollution Prevention on the Internet".  The
   seminar helped attendees to better use the Internet to locate Pollution  Prevention related information.  Attendees
   included ANL-E, DOE, IEPA, the Illinois Waste Management Research Center,  Abbott Laboratories, Commonwealth
    Edison, etc.

                                                     8
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   Argonne and DOE volunteers participated in the Second Annual Argonne Cleanup walk on June 6th. The cleanup
   walk, sponsored by the WM&P2 Advisory Committee and the Argonne Club, with the DuPage County Forest
   Preserves.
   An Affordable Energy Home Center showcasing the benefits of energy-efficient housing recently opened its doors in
   Chicago's West Garfield Park. The center will offer public workshops on incorporating energy-efficient techniques into
   homes under construction. The center is sponsored by Argonne, Bethel New Life, the Chicago Department of Housing,
   ComEd, and DOE.
   Argonne ecologists are working on a project to preserve and restore on-site native habitat types, such as woodlands,
   wetlands and prairies and savannas, to protect native species and enhance the beauty of the ANL-E site. The re-
   establishment of native habitats at ANL-E is included in DOE and Argonne land management policies, which propose
   to manage land and facilities as valuable national resources.
   Argonne continued to perform developmental work on the ANL-E Waste Minimization  and Pollution Prevention
   (WM&P2) Homepage. The WM&P2 Homepage is intended to be linked into the existing ANL-E Homepage in FY98.
   During 1997, PFS-Vehicle Maintenance completed a WM&P2 manual that describes the WM&P2 activities employed
   within the Argonne Vehicle Maintenance Facility. The manual has been electronically  posted on the DOE EPIC site
   and  is used as a tool to share WM&P2 information with internal and external partners.

WM&P2 ROI Projects (1997)
•  The  ANL-E WM&P2 Program funded an ROI Project titled: Cyclotron Case Study on Opportunities to  Recycle Carbon
   Steel. Tie project was managed by TD, and focused on the recycling of carbon steel from the dismantlement of 60-in
   cyclotron. A PPOA was incorporated into the project. The project generated recommendations and identified risks
   and  benefits to implementing WM&P2 initiatives.
   The  ANL-E WM&P2 Program funded an ROI Project titled: WM through the use of alternative, less-hazardous solvents
   for radiochemical analyses. This project managed by (ACL/CMT) was able to identify alternative analytical procedures
   that  reduce the amount of mixed waste generated. If implemented, procedures derived from this project can generate
   substantial cost avoidance at ANL-E and the DOE complex.
•  The  ANL-E WM&P2 Program funded an ROI Project titled: P2 in the Analytical Laboratory Using Solid-Phase
   Extraction Methods. The project was managed by ER, and focused in minimizing primary and secondary waste
   generated from chemical laboratory operations.  The project was successful in developing new analytical methods that
   can be employed to reduce the large volume of laboratory hazardous waste currently generated across the DOE
   complex.
•  In the fall of 1997, the ANL-E WM&P2 Program funded an ROI  Project titled: Building 115 Shaker House Modification.
   This project will result in the more efficient management of coal, thereby reducing the amount of coal fines generated
   from the excessive movement of coal prior to burning.
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  David Ullrich




U.S. EPA Region 5
-------
                 Mark Waldrop

               BASF Corporation
'' A Process to Vacuum Vapor Degrease Metal Parts with
              N-Methal Pyrrolidone "
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                                    Mark Waldrop
I am a Market Development Specialist for BASF Corporation's Chemicals Division (3000 Continental
Drive North, Mt. Olive, NJ 07828).  I joined BASF in 1990 as an engineer in the Professional
Development program, holding positions in manufacturing, engineering, and technical service. From
1993 to present, I have worked in technical service for chemical intermediates, especially NMP. I hold
three U.S. patents, including one on cleaning polymer residues with NMP. I have a B.S. in Chemical
Engineering from Wayne State University in Detroit.
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Title of Paper: A Process to Vacuum Vapor Degrease Metal Parts with N-Methyl Pyrrolidone

Abstract

N-Methyl Pyrrolidone (NMP), used in a heated immersion cleaning process, is a good alternative to
traditional vapor degreasing solvents for most industrial degreasing applications.  However, two key
physical properties of NMP—its low vapor pressure and its flash point (196°F)—may make it inefficient
or less effective in certain cleaning jobs: the removal of high melt waxes and greases; cleaning parts
with deep blind holes or crevices; cleaning highly porous materials; and cleaning parts that require
completely dry surfaces (i.e., not even trace amounts of solvent) immediately after being cleaned.  This
paper describes how NMP was used in a vacuum vapor, or "airless", degreasing process to overcome
these physical property-based deficiencies.  The vacuum vapor degreasing process offers the added
benefits of almost no  solvent emissions to the air and easy recycling of the solvent.
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Introduction

The high solvent activity (Kauri Butanol Value 300) associated with the solvent N-Methyl Pyrrolidone (NMP).
especially at elevated temperatures, is reflected in the ability of NMP, or NMP/solvent Wends, to solvate many
different types of soils and greases/oils.

A basic process to accomplish metal cleaning with NMP involves three steps.

   a.)   A cleaning cycle: This step involves immersing the parts into a heated bath of NMP

   b.)   A rinsing cycle:  As with all immersion cleaning processes, the cleaning solvent/soil residue must be rinsed
        off of the part. This is accomplished with either a heated spray or an immersion cycle. The rinse solvent
        can be water, NMP or any other oxygenated solvent.

   c.)   And finally a drying cycle: Removal of the NMP from the surface of the parts is carried out most efficiently
        with a hot forced air current.

The basic immersion cleaning process described above is an adequate replacement method for most industrial
degreasing applications where vapor degreasing cleaning processes have been used in the past.

There are, however, some cleaning jobs that will not be accomplished effectively or efficiently with an NMP
immersion process. Some of the application areas where NMP immersion processes may be deficient, are:

        1.)     TJie removal of hioh melt waxes or greases:
               Vapor degreasing processes based upon solvents boiled at temperatures close to, or above the
               flash point temperature for NMP (91SC/196«F).

        2.)     Complex parts with many deep blind holes or crevices:
               Although tumbling of the parts during the drying process is a potential cure for this deficiency,
               there is  no guarantee that all the solvent will be removed. Also, some parts do not lend
               themselves to be physically tumbled during the cleaning process.

        3.)     Cleaning of porous  materials:
               Again, it may be hard for the NMP to adequately penetrate into a porous substrate, to remove a
               soil, at the recommended operating temperatures for an NMP based immersion process. Total
               removal of rinse solvent,  also, may not be guaranteed.

        4.)     Applications where totally drv surfaces with no residual oils or cleaning solvent can be present
               (even in trace amounts):
               NMP is a pure solvent which will evaporate from the surface of a substrate leaving no residue
               behind.  Water rinses, or  alcohol rinses, such as are used in NMP based integrated circuit wafer
               cleaning processes, are abided insurance that there is no residue.  However, what if the part
               cannot have contact with water, or due to the size of the part (very  large) a cleaning process using
               an alcohol rinse is not an economically viable option.

These four areas of cleaning, where efficient NMP immersion cleaning processes may be uneconomical or
impractical are all due to two basic physical properties of the  solvent, which cannot be changed.

        a.)     flash point and
        b.)     vapor pressure at atmospheric pressure

However, by introducing inerting agents into the atmosphere above the NMP, as well as by changing certain
conditions in the process, to allow for increasing the vapor pressure of NMP, these two physical property based
deficiencies of NMP cleaning processes can be overcome.

The work described in this paper was earned out in order that some guidelines might be established for such a
process that overcomes both the flash point deficiency and the vapor pressure deficiency, and  leads to an
efficient NMP based cleaning process for these specialty cleaning problems.
-------
DISCUSSION

A degreasing process, that will overcome both the flash point (Cleaning of High melt waxes) and vapor pressure
(100% guarantee of total dryness) deficiencies, is an inherted atmosphere vacuum cleaning system.  In an inhert
atmosphere the NMP can be safely heated to the high temperatures required to melt waxes/greases. Also, pulling
a vacuum on the system, after a cleaned part has been rinsed, will insure 100% removal of the NMP during the
drying process.

Such a process (Figure 1) could be configured in many different ways so the maximum efficiency of NMP's
solvating capacity, could be taken advantage of. (See Figure 1)


FIGURE 1:   NMP  VACUUM VAPOR CLEANING PROCESS
                                   Clean
                                Liquid NMP
                                Spray Rinse
                                         Hot
                                   NMP Vapor Rinse
   Immersion
      Into
    Hot NMP
     Liquid
Either
X
                   Either
                                                           /
                                                          /
                                                         /  Or
                       Vacuum Cleaning
                            Cycle
                            Vacuum
                            Rinsing
                                                                      Vacuum
                                                                       Drying
Immersion
   Into
 Hot NMP
  Vapors
                  /  Or
                                    Or
                                                   Combination of
                                                     Clean Liquid
                                                     NMP Spray
                                                        and
                                                     Vapor Rinse
The cleaning step can be accomplished by either immersing the parts into hot liquid NMP or by allowing the parts
to "hang" in heated air that is totally saturated with NMP.

The rinsing of the cleaned parts is accomplished by one of three different processes, a.) Hot clean NMP is
sprayed over the parts, or b.) NMP vapors condense onto the parts rinsing the part clean of NMP/oil residue from
the cleaning step or c.) a combination of both rinsing actions.

The common link, between the rinsing and cleaning steps, and the drying step, is that the total cycle is carried out
under a vacuum with a positive bleed of an inhert gas being applied to the air space of the system.

An additional feature of such a system, that should be mentioned is the extremely tow potential for emissions of
organic solvents, into the environment, during 'he cleaning process.  An NMP based immersion process system,
-------
operated at the recommended cleaning temperature, will normally have tow emissions of solvent to the air.
However, when the system air is totally enclosed and then pulled through a cold trap or over a cooling coil! before
exiting into the outside atmosphere, the organic solvent emissions are very tow to almost non-existent.

EXPERIMENTAL

Three different sets of experiments were carried out during the data gathering phase of this vacuum cleaning
work.

PHASE  1:   Definition of vacuum drying parameters required for NMP removal

PHASE 2:   Definition of base cleaning parameters

PHASE 3:   Actual cleaning tests

Although there are several companies that manufacture equipment for vacuum vapor cleaning, there had been
very little work done with NMP as the cleaning/rinsing solvent. So, before doing some actual cleaning of parts with
this type of process, it was necessary to establish some process parameters (dwell time, vacuum, temperature).

PHASE  1:   Definition of Vacuum Drying Parameters Required for NMP Removal

    a.)  To insure that the substrate surface was fully covered with NMP (and oil for the cleaning tests) a piece of
        sintered metal was used as the control substrate. The control part was

               A Sintered Metal Disc
               Weight:         16.1008 g
               Diameter:      38.17mm
               Thickness:    2.87 mm

    b.)  Drying tests were carried out using a vacuum oven as the drying instrument

PROCEDURE

    i.)   The control part was immersed into liquid NMP, at a set temperature, for 10 minutes time

    i.)  The part was removed from the NMP and then placed into the vacuum oven  (preset at the desired
        temperature)

    iv.)  The vacuum was applied to the oven and the rate of removal of  NMP, from the sintered metal control part.
        was measured by weight change (0.0001  ± 5g) over time.

    v.)  Drying data was recorded and the results are presented in graphs 1-4

General Results of Drying Tests:

    1.)  100% removal of the NMP from sintered metal is achievable when the temperature of the air in an
        evacuated chamber is kept above 709C.

    2.)  For quickest removal of NMP from metal parts, vacuum conditions as close to full vacuum are required.

    3.)  Total removal of NMP from the sintered metal was achieved even at weak vacuum conditions.

PHASE II:    Definition of base line cleaning/Rinsing process parameters

To simulate a cleaning chamber, such as one that would be found in a commercial vacuum cleaning unit, a double
walled glass resin flask was used.  This allowed for efficient control of the temperature of the liquid NMP as well as
of the temperature of the NMP vapors in the evacuated air space above the liquid. A diagram of the test apparatus
is shown in Figure 2
-------
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                            FIGURE 2
                 Vacuum Vapor  Degreasing Equipment
Vacuum Pump
                                                   Cleaning/Vacuum Vessel
           Dry Ics/Acetone Traps
-------
General Discussion of  Phase II tests:

    1.) The control part cleaned, was the same sintered metal disc used lor the drying studies

    2.) In a commercial unit, the parts will be cleaned, rinsed and dried in the same chamber. The process of
       opening and closing the resin flask (and re-stabilizing the temperature) is a time consuming process, so
       once the part was cleaned and rinsed in order to speed up the lab work, the part was dried in the same
       vacuum oven used for the drying trials.

    3.) The soil chosen, as a control and used to saturate the disc for all cleaning trials, was a 50/50 (by weight)
       blend of two heavy oils (Shell HVI-150 and Exxon Telura 323) that had a boiling point higher than NMPs.
       (After some discussion it was decided not to run trials with a light weight control oil. Most of these oils have
       boiling ranges that overlap the boiling point of NMP, and it was felt that a test run with such an oil would not
       be a true test of oil removal, as some of the light components could still be on the metal after the cleaning
       step. These residues would surely evaporate during the vacuum drying cycle.)

Procedure for Cleaning Trials:

    i.)    The control disc was immersed into the control oil blend.  The dwell time in the oil was 10 minutes,  the
         temperature of the oil bath was maintained at 70aC. (Dwell time and oil bath temperature remained the
         same tor all trials.)

    «.)   The disc was then wipe dried with a paper towel, to remove all gross amounts of surface oils.

    Hi.)   The control part was then immersed into the NMP bath (pre-set at a given temperature). The resin flask,
         bath was covered, and a slight vacuum applied. Dwell time in the liquid NMP was varied from trial to trial.
         The pre-set temperature of the NMP bath was also varied. During all tests involving the heating of NMP
         above 63°C, the reactor vessel had a Nitrogen bleed into the air space above the NMP. (Even while
         vacuum was applied.)

    iv.)   After the pre-determined dwell time was reached, the majority of the liquid NMP was drawn out of the
         resin flask allowing the disc (which was held by a rack device) to sit in the evacuated air space.

    v.)   A full vacuum was applied to the system, until small amounts of the NMP were pulled out of the resin
         flask.  The resin flask was then closed off, and the control part was let to rinse in the refluxing NMP
         vapors for 5 minutes.

    vi.)   The sintered metal was then removed from the resin flask, and placed into a pre-heated vacuum oven.
         Pull vacuum was applied, and the part was dried.

    vii.)  The sintered metal disc was considered totally cleaned and dried when the weight of the disc was i
         O.OOOSg  of the original dry/cleaned weight.

The data from the cleaning trials is reported here in Figure 3.
-------
 FIGURE 3:  CLEANING HEAVY OIL FROM SURFACE OF  SINTERED  METAL DISC
       Trial Process Conditions
                                         Results
       Resin Flask Temp 709C;
       Dwell Time in Liquid NMP: 5 minutes
       Rinse 709C Vapor; 5 minutes
       Dry Cyde; 7 minutes
       30 inch vacuum 70* C	
                                         TOTALLY CLEAN AND DRY
 2.
Resin Flask Temp709C;
Dwell time in liquid NMP: 3 minutes
Rinse 708C Vapor; 5 minutes;
Dry Cyde; 7 minutes
30 inch vacuum 70flC       	
                                                TOTALLY CLEAN AND DRY
       Resin Flask Temp859C;
       Dwell time in liquid NMP: 5 minutes
       Rinse 85*C Vapor; 5 minutes:
       Dry Cyde; 7 minutes
       30 inch vacuum 858C	
                                         TOTALLY CLEAN AND DRY
       Resin Flask TempSS'C;
       Dwell time in liquid NMP: 3 minutes
       Rinse 859C Vapor; 5 minutes;
       Dry Cycle; 7 minutes
       30 inch vacuum 85*C       	
                                         TOTALLY CLEAN AND DRY
       Resin Flask Temp1l09C;
       Dwell time in liquid NMP: 5 minutes
       Rinse 1109C Vapor; 5 minutes;
       Dry Cyde; 4 minutes
       30 inch vacuum 1009C
                                         TOTALLY CLEAN AND DRY
6.
Resin Flask Temp 1109C;
Dwell time in liquid NMP: 3 minutes
Rinse 1109C Vapor; 5 minutes;
Dry Cycle; 4 minutes
30 inch vacuum 1009C
                                                TOTALLY CLEAN AND DRY
GENERAL RESULTS OF CLEANING TESTS:

1.)     The trials run at 10O'C give some indication that total cycle times of 15 minutes are possible for small scale
       NMP vapor degreasing processes.
2.)     Full vacuum (or as close to full vacuum) condition was chosen for the drying cycle, because at all
       temperatures tested, the best drying results were obtained when a full vacuum was applied.
3.)     The results indicated that vacuum cleaning processes using liquid NMP and vaporized NMP, at
       temperatures as low as 709C, can produce clean substrates in efficient time frames.

PHASE III:  Cleaning of Parts

The proper deaning, rinsing and drying parameters were already established for an NMP vacuum vapor
degreasing process by the experiments carried out during Phase I and Phase II of the project.

During the final set of experiments, the total process knowledge was applied, and the test apparatus, shown in
Figure 2, was operated in the same manner that a commercial unit would be run. (Cleaning, rinsing, and drying
cydes take place in the same chamber; the parts remain stationary.)

GENERAL DISCUSSION OF PHASE III  TESTS:

1.)     Cleaning trials were carried out using (4) different test parts.
       a.)     Pieces of stainless steel mesh screen
              (32 mesh screen; 0.495 mm per square side)
       b.)     Glass capillary tubes
-------
               (a) 100 mm x 1.8 mm (OOyi .5 ID        (b) 10 microlrter size capillary tubes
       c.)      Cartoon steel bolts
               (0.5 in. fully threaded; 4 inches long)
       d.)      Brass cabinet handles; Zinc die cast cabinet handles
2.)     Parts a, b, and c were soiled with the same 50/50 oil blend (HVl-150/Telura 323) that was used for the
       cleaning trials.
3.)     Part d (brass cabinet handles) trials were run on non-soiled parts. The brass handles were production
       parts coated with an epoxy powder coating.  Part d trials were run, to demonstrate and observe, the
       potential, for an NMP immersion/vapor rinse process, to swell and remove the coating.  The established
       method for removing this type of powder coating, with NMP. is to immerse the part into an ultrasonic bath.
       The NMP softens the powder coating and then the ultrasonic energy is needed to "blast" the softened
       coating off of the substrate surface. We wanted to examine the potential for vapor "coatings removal".

PROCEDURE FOR  PARTS CLEANING  TRIALS:

    i.)  The part being cleaned was immersed into a control oil bath. Owed time in the oil was 10 minutes. The
       temperature of the oil bath was maintained at 70BC. (Both of these parameters remained constant for all
       parts cleaning trials.)

    i.) The part was then removed from the oil, shaken and wiped with a paper towel, in order to ensure gross
       amounts of oil were removed.

    iii.) The part was them immersed into the NMP bath (Temperature ore-set at 709C or 859C) for the trials. The
       resin flask bath was covered, and a slight vacuum was applied to the system.  The dwell time in the liquid
       NMP "as varied from trial to trial.

    iv.) After the prescribed dwell time was reached,  a majority of the liquid NMP was drawn out of the resin flask,
       allowing the part to sit in the evacuated air space.

    v.) A full vacuum was then applied to the system until small amounts of NMP were pulled out of the resin flask.
       The resin flask was then closed off. and the part was left to rinse in the refluxing NMP for 5 minutes, (all
       trials).

    vi.) The remainder of the liquid NMP was drawn our of the resin flask, and a ful vacuum was applied, for 7 • 10
       minutes, to dry the parts.

    vii.) Each part was weighed (to 0.0001 ± 5 grams) after the cleaning process/ drying process was complete.

The results  of the parts cleaning trials are set forth in  Figure 4.

FIGURE 4:   PARTS CLEANING TEST  RESULTS

       Parts  Cleaned       Process Conditions	             Results
1,
32 Mesh Screen
Resin Flask Temp: 70«C;
Dwe8 time in liquid NMP: 3 min.
Rinse 709C vapors: 5 minutes
Dry Cycle: 9 min. 30 inch vacuum
                                                              Part Totally Clean
                                                              and Dry	
     32 Mesh Screen
                     Resin Flask Temp: 709C;
                     Dwell time in liquid NMP: 5 min.
                     Rinse 709C vapors: 5 minutes
                     Dry Cycle: 10 min. 30 inch vacuum
                                                              Part Totally Clean
                                                              and Dry	
     32 Mesh Screen
                     Resin Flask Temp: 859C;
                     Dwell time in liquid NMP: 3 min.
                     Rinse 859C vapors: 5 minutes
                     Dry Cyde: 9 min. 30 inch vacuum
                                                              Part Totally Clean
                                                              and Dry	
     32 Mesh Screen
                     Resin Flask Temp: 859C;
                     Dwell time in liquid NMP: 5min.
                     Rinse 859C vapors: 5 minutes
                     Dry Cycle: 9 min. 30 inch vacuum
                                                              Part Totally Clean
                                                              and Dry	
-------
     Cartoon Steel Bolts
                      Resin Flask Temp: 709C;
                      Oweltimein liquid NMP: 3 min.
                      Rinse 70'C vapors: 5 minutes
                      Dry Cyde: 10 min. 30 inch vacuum
                                                              Parts Totally Clean
                                                              and Dry
     Cartoon Steel Bolts
                      Resin Flask Temp: 70BC;
                      DweBtimein fiquid NMP: 5 min.
                      Rinse 70*C vapors: 5 minutes
                      Dry Cycle: 10 min. 30 inch vacuum
                                                              Parts Totally Clean
                                                              and Dry	
     Cartoon Steel Bolts
                      Resin Flask Temp: 85'C;
                      DweBtimein liquid NMP: 3 min.
                      Rinse 85'C vapors: 5 minutes
                      Dry Cyde: 10 min. 30 inch vacuum
                                                              Parts Totally Clean
                                                              and Dry	
8.
Cartoon Steel Bolts
Resin Flask Temp: 859C;
Dweltimein liquid NMP: 5 min.
Rinse 85'C vapors: 5 minutes
Dry Cyde: 10 min.  30 inch vacuum
                                                              Parts TotaBy Clean
                                                              and Dry	
9.
Bundle of Mixed
10 microliter and
100mm capillary tubes
Resin Flask Temp: 70«C;
Dwell time in liquid NMP: 3 min.
Rinse 70*C vapors: 5 minutes
Dry Cycle: 10 min.  30 inch vacuum
                                                              Parts Totally Clean
                                                              and Dry	
10.
Bundle of Mixed
10 microliter and
100mm capillary tubes
Resin Flask Temp: 709C;
Dwell time in liquid NMP: 5 min.
Rinse 70»C vapors: 5 miutes
Dry Cycle: 10 min.  30 inch vacuum
                                                              Parts Totally Clean
                                                              and Dry	
11.
Bundle of Mixed
10 microliter and
100mm capillary tubes
Resin Flask Temp: 85"C;
Dwell time in  liquid NMP: 3 min.
Rinse 85'C vapors: 5 minutes
Dry Cycle: 7 min. 30 inch vacuum
                                                              Parts Totaiy Ctean
                                                              and Dry	
12.
Bundle of Mixed
10 microliter and
100mm capillary tubes
Resin Flask Temp: 85'C;
DweB time in  liquid NMP: 5 min.
Rinse 85'C vapors: 5 minutes
Dry Cycle: 7 min. 30 inch vacuum
                                                              Parts TotaBy Clean
                                                              and Dry	
13.
Brass and Steel Zinc
Die Cast Cabinet
Handles
Resin Flask Temp: 85aC;
Dwell time in  liquid NMP: 20*30 min.
Rinse 859C vapors: 10 minutes
No Dry
-At the 5 min mark of the cleaning
cycle (immersed in liquid NMP), the
powder coating bubbled, however,
without the ultrasonic force, the
coating was not lifted from 100% of
the surface.
- Rinsing in the vapors did not
remove any additional amounts of
coating	
14.
Brass and Steel Zinc
Die Cast Cabinet
Handles
Resin Flask Temp: 110»C;
Dwell time in  liquid NMP: 20-30 min.
Rinse 1109C vapors: 10 minutes
No Dry
-Again by the 5 minute mark of the
cleaning cycle, the powder coating
was bubbled out without ultrasonics
the coating could not be completely
lifted from the surface
•Rinsing in the vapors did not
remove any additional amounts
of coating	
GENERAL DISCUSSION OF  PARTS  CLEANING RESULTS  AND  CONCLUSION:

1.) The parts cleaning tests were run in a closed container, and the container was not opened until after each test
    was complete. Because of this, in order to insure that the parts would be totally dry, the maximum drying times
    for cleaning trials on the sintered metal disc were used. Actual drying cycles for smooth surfaced parts will
    most likely be shorter.

2.  Trials were not run at 11O'C, as it was assumed that since the parts were cleaned at 70*C and 85-C, that the
    only data to be gained by running trials at 110'C, would be to determine the minimum total cycle time.
-------
3.)  A general cleaning cycle of 3 -5 minutes is sufficient.

4.)  A general vapor rinsing cycle of 5 minutes is sufficient.

5.)  Before the capillary tubes were immersed into the 709C oil bath for "dirtying", oil was suctioned up into the
    tubes to insure that the total surface area of each tube had been exposed to the oil.

6.)  The use of hot NMP in a vacuum chamber did give rise to a more rapid penetration and bubbling of the powder
    coating (less than 5 minutes) than the normal process of immersion into an ultrasonic bath, however, without
    the ultrasonics present, the coating film was not totally removed from the metal.

Further work may be done with processes that combine both vacuum and ultrasonics, to develop the most
efficient powder coating removal processes.

FINAL   CONCLUSIONS:

It has been demonstrated that, a liquid (NMP) immersion/NMP vapor rinse/vacuum dry, cleaning process can be
employed to remove soils from hard surfaces. For a list of several companies that manufacture equipment capable
of vacuum vapor degreasing, see appendix B of this report. These companies are familiar with NMP.

SAFETY   CONSIDERATIONS:

In order to generate a sufficient concentration of NMP vapor, in the cleaning chamber, to insure that an
efficient/effective rinsing action occurs, the NMP may have to be  heated up to temperatures that are higher than
it's flash point.

It is not recomended that NMP, or any other solvent, be heated up to a temperature close to, or above, the flash
point of the solvent, in an oxygen rich atmosphere (i.e. air that we breathe).  All of the experiments discussed in
this paper, were carried out in Nitrogen rich atmospheres.

Also, please remember that NMP is a solvent, and like all other solvents. NMP will de-fat/de-oil the skin.  When
working with NMP be sure to wear proper NMP resistant butyl or neoprene rubber gtoves (apron if the job
demands).  When working with NMP, or any other solvent, goggles should be worn to protect the eyes from
accidental splashes.
-------
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REFERENCES

1.)  MASS Transfer Operations, Third Edition by Robert E. Treybal; 1987.  McGraw Hffl Book Company.
    pp. 660-681.

2.)  Unit Operations of Chemical Engineering, Fourth Edition by McCabel, Smith, and Harriott; 1985.  McGraw Hill
    Book Company,  pp. 940-942.

3.)  15th AESF/EPA Conference on Pollution Prevention and Control, Conference Proceedings. January 1994,
    Vacuum Vapor Degreasing System for Pollution Abatement; by M. Shenoy and D.J. Gray. SEREC
    Corporation, Providence, Rl.

APPENDIX B
Vacuum Vapor Degreaser  Manufacturers  Familiar with NMP

Durr Automation              Durr GmbH                  Tiyoda Manufacturing Co. Ltd.
10301 Enterprise Drive        FikJerstadt                  Industrial Equipment Division
Davisburg, Ml 48350           Muhlen Strasse  12           75-5 Imojiya Oaza Koshoku
                            D-70794                    387 Nagano Japan
Contact: Tim Kelly            FikJerstadt Germany           Contact: Mr. Masahio Tanaka
Phone:  (810)625-5400                                  Phone:  81-262-72-2381

SEREC Corporation                                      Tiyoda Manufacturing USA Inc.
P.O. Box 28129                                         1613 Lockness Place
335 Valley Street                                        Torrance, CA 90501
Providence, Rl 02908
Contact: Peter T. Gebhard III                              Contact: Mr. Ohkubo
Phone: (401)421-6080                                  Phone:  (310)539-5471
-------
                  William Wehrle

                 BASF Corporation
"Waste Minimization in the Agricultural Products Industry:
 Update on the Agricultural Container Research Council"
-------
                                    BIOGRAPHY

                                     Bill Wehrle

Bill Wehrle is currently Manager of Formulation and Packaging for BASF Corporation in
Research Triangle Park, North Carolina. He has held various manufacturing positions with
BASF for the past twenty-two years, mostly in the Agricultural Products Group.

Bill has been a member of the American Crop Protection Association's (ACPA) Packaging
Systems Round Table for the past nine years, and was one of the founding members of the
Agricultural Container Research Council (ACRC). The Council is a nonprofit, joint-venture
corporation formed in 1992 to establish a nationwide collection/recycling program for used
plastic containers, as well as conduct research on end uses for the resulting recycled plastic.

After first serving as ACRC's Finance Committee Chairman for nearly two years, Bill was
elected Chairman of the Board of Directors of ACRC in 1994.  As a result of his involvement in
the Agricultural Container Research Council, Wehrle was named recipient of the "Work Horse"
award from the ACPA in 1997. The prestigious award, established in 1990, is given annually to
the person or persons whose steady commitment to the industry, over time, has achieved a
milestone.
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          Scott Wells/Christopher Start
           (see Christopher Start for paper)
Energy, Environment, Health and Safety Services
  Michigan Manufacturing Technology Center
  "MEDS: A Technology Division Support Tool for
              IndustrialJob Shops"
-------
                             Scott Wells
THE PRESENTER

Scott Wells is an Energy  Engineer with the Energy, Environment, Health & Safety
Department, 2901 Hubbard Rd. P.O. Box 1485, Ann Arbor, MI 48106-1485;  Phone:
(734) 769-4514; FAX: (734) 213-3408; E-mail scw@mmtc.org. He has received a BSEE
in Electrical Engineering from the University of Missouri - Rolla and has completed
numerous computer science courses towards a computer science degree. At the MMTC,
Mr. Wells  has a specific focus on the Manufacturing Energy Analysis program.  Mr.
Wells is currently working  on the MEDS tool and is creating the project's website. Mr.
Wells has also been a member of the  project team for the Energy, Environmental, and
Manufacturing  Technology Access  Project  (a  Technology  Reinvestment  Project),
responsible for providing integrated energy, environment, and manufacturing approaches'
to small and medium sized  manufacturers. He has provided training to field agents in the
assessment process as well.
-------
         Scott Wells/Christopher Start
           (see Christopher Start for paper)
Energy, Environment, Health and Safety Services
  Michigan Manufacturing Technology Center
  "MEDS: A Technology Division Support Tool for
              Industrial Job Shops"
-------
                             Scott Wells
THE PRESENTER

Scott Wells  is an Energy  Engineer with the Energy, Environment, Health & Safety
Department,  2901 Hubbard Rd. P.O. Box 1485, Ann Arbor, MI 48106-1485; Phone:
(734) 769-4514; FAX: (734) 213-3408; E-mail scw@mmtc.org. He has received a BSEE
in Electrical Engineering from the University of Missouri - Rolla  and has completed
numerous computer science courses towards a computer science degree.  At the MMTC,
Mr. Wells has a specific focus on the Manufacturing Energy Analysis program.  Mr.
Wells is currently working on the MEDS tool and is creating the project's website. Mr.
Wells has  also been a member of the project team for the Energy, Environmental, and
Manufacturing Technology Access  Project (a Technology  Reinvestment  Project),
responsible for providing integrated energy, environment, and manufacturing approaches
to small and medium sized manufacturers.  He has provided training to field agents in the
assessment process as well.
-------
               Dave Wintz

              Indiana DEM
    Office of P2/Technical Assistance
"Indiana's Five Star Program for Dry Cleaners"
-------
Thomas W. Zosel
  3M Company
       ial promotion
-------
-------