903R89001
Hazardous Waste
Minimization Manual
for Small Quantity Generators
First Edition—April 1987
Revised Edition—October 1989
Prepared by
Center for Hazardous Materials Research
University of Pittsburgh Applied Research Center
320 William Pitt Way
Pittsburgh, Pennsylvania 15238
(412)826-5320
Toll-free Hazardous Materials Hotline 800-334-CHMR
A Subsidiary of the University of Pittsburgh Trust
1989 ••CHMR
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ACKNOWLEDGEMENTS
The Center for Hazardous Materials Research (CHMR) of the
University of Pittsburgh gratefully acknowledges the financial
support received which allowed preparation of this manual.
The first edition was prepared as part of a grant from the U.S.
Environmental Protection Agency, Region III, while support to
prepare the revised edition was provided by the Westinghouse
Electric Corporation Foundation.
• CHMR
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DISCLAIMER
This manual has been prepared to provide general information and
guidance on waste minimization practices and suggested compli-
ance requirements under the Resource Conservation and Recov-
ery Act (RCRA) and other related state and Federal acts.
Reasonable good faith efforts have been made to assure that the
information provided herein is accurate as of the date of publica-
tion. However, there is no guarantee, express or implied, that the
use of this manual will satisfy all regulatory requirements derived
from these Acts and required by the agencies involved.
The userof this manual understands that the Center for Hazardous
Materials Research (CHMR) and any and all affiliates, disclaim any
and all liability and responsibility whatsoever in connection with any
personal loss, injury including death, property loss ordamage, pen-
alty imposed upon, or violation to, by, or in respect of any person
or property, however caused, involving any matter covered in this
manual.
This manual should be used with the understanding that neither
CHMR, nor any of its affiliates, is engaged in rendering legal
counsel. If legal advice or other expert assistance is required for
a particular question or matter, the services of a competent
professional person should be sought.
Neither CHMR, its affiliates, representatives, or employees as-
sume any responsibility for errors and/or omissions from this man-
ual.
1989
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CONTRIBUTORS TO THE MANUAL
Individuals responsible for important contributions to the
research, preparation, and production of this manual include:
Roger L Price, P.E., Principal Author
Dr. Edgar Berkey, Project Director
Vicky Brind'Amour
Seth Beckerman
Gary R. Boyle
Walter J. Burlack
Samuel Creeger
Beth Furst
Margaret Johnston
William J. McKinney
Steven T. Ostheim
Stephen W. Paff
Diane Ragan
Scott Raymond
Sandra K. Raymond
Howard V. Worley III
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
i REGION III
841 Chestnut Building
Philadelphia, Pennsylvania 19107
Dr. Edgar Berkey
Executive Vice President
CENTER FOR HAZARDOUS
MATERIALS RESEARCH
University of Pittsburgh
Applied Research Center
320 William Pitt Way
Pittsburgh, PA 15238
Dear Ed:
It gives me great pleasure to inform you that The Center for
Hazardous Materials Research is a winner of the 1988 EPA's Center
for Environmental Learning Award. The hazardous waste minimization
manual that The Center for Hazardous Materials Research (CHMR) developed
for small quantity generators deserves to be recognized for the
improvements which will result from its use throughout the Commonwealth,
Region III, and hopefully the nation.
EPA's Center for Environmental Learning (CEL) was established
in the fall of 1986 to improve the public's understanding of current
and emerging policy issues and to increase opportunities for the
public to communicate with the Agency.
Of the 74 nominations submitted in 1988, the Awards Committee
believed the manual CHMR developed exemplifies the reason for the
establishment of this Award. The distribution of 1,000 copies of
the manual, the inclusion of its step-by-step process in seminars,
and the continued use of the manual by businesses and CHMR's hotline
speaks to the on-going and long term value of your efforts.
The Awards Committee felt the leadership role that CHMR
has undertaken in the area of hazardous materials research constitutes
a significant contribution to environmental education in the six
States in Region III. I commend you for your accomplishments and wish
you success in your future work.
James M. Self
Regional Administrator
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GLOSSARY
BOAT best demonstrated available technology
BDC business development corporation
BOD biological oxygen demand
CCP commercial chemical products
CERCLA Comprehensive Environmental Response,
Compensation, and Liability Act
CHMR Center for Hazardous Materials Research
CRS central recovery system
DOD Department of Defense
DOT Department of Transportation
EDA Economic Development Administration
EP extraction procedure
EPCRA Emergency Planning and Community Right-to-
Know Act
FHA Farmer's Home Administration
HOC halogenated organic compounds
HSWA Hazardous and Solid Waste Amendments
IPM integrated pest management
LEPC local emergency response commission
MCI manufacturing chemical intermediates
MSDS Material Safety Data Sheet
NA North American
NPDES National Pollution Discharge Elimination System
NPV net present valve
OPPE Office of Policy, Planning, and Evaluation (U.S. EPA)
OSHA Occupational Safety and Health Administration
PBP payback period
POTW publicly owned treatment work
PA DER Pennsylvania Department of Environmental Resources
PENNTAP Pennsylvania Technical Assistance Program
RCRA Resource Conservation and Recovery Act
SARA Superfund Amendments and Reauthorization Act
SBA Small Business Administration
SBIC small business investment company
SERC state emergency response commission
SIC Standard Industrial Classification
SQG small quantity generator
TPQ threshold planning quantity
TSCA Toxic Substances Control Act
UN United Nations
U.S. EPA United States Environmental Protection Agency
UST underground storage tank
1989
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CONTENTS
1.0
1.1
1.2
1.3
1.4
1.5
INTRODUCTION
Why Is Waste Minimization Important?
The New National Waste Management Strategy —
Begin with Waste Minimization
How to Use this Manual
The Difference Between U.S. EPA and State
Environmental Regulatory Agencies
Definitions of Some Important Terms
1-1
1-1
1-3
1-5
1-6
1-8
2.0 ADVANTAGES OF WASTE MINIMIZATION 2-1
2.1 Overview 2-1
2.2 Economic Incentives: Specific Cases 2-1
2.2.1 Direct Profits from Environmental Compliance 2-1
2.2.2 Reduced Costs Through Better Management
and Efficiency 2-2
2.2.3 Reduced Treatment, Transportation,
and Disposal Costs 2-4
2.2.4 Income Derived Through Sale or Reuse of Waste 2-6
2.2.5 Reduced Costs for Waste Water Treatment 2-7
2.2.6 Lower Risks for Spills, Accidents,
and Emergencies 2-7
2.2.7 Lower Long-Term Liability and Insurance Costs 2-8
2.3 Regulatory Incentives 2-9
2.4 Improved Public Image 2-10
3.0 RCRA REGULATIONS FOR SMALL
QUANTITY GENERATORS 3-1
3.1 Introduction 3-1
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3.2
3.3
3.4
3.5
3.5.1
3.5.2
3.5.3
3.5.4
3.5.5
3.6
3.6.1
3.6.2
3.6.3
3.6.4
3.6.5
3.6.6
3.6.7
3.7
3.7.1
3.7.2
What Is a Small Quantity Generator (SQG)?
Types of Businesses Most Likely to Produce
Small Quantities of Hazardous Wastes
Regulatory Requirements for Small Quantity Generators
Exemptions
On-Line Recycling
On-Site Reclaiming Preceded by Waste
Accumulation and Storage
Off-Site Reclaiming
Used Oil
Other Recyclable Materials
Commonly Asked Questions About Hazardous Waste
and Compliance
Is My Waste Hazardous?
Are Any Hazardous Wastes Exempted from the
Hazardous Waste Management Requirements
How Do I Determine How Much Hazardous
Waste I Generate?
Should I Include Empty Containers?
How Much Waste Must My Business Produce to Be
Regulated Under the New RCRA Requirements?
What Must I Do if I Am Regulated Under the
New RCRA Requirements
Should I Notify EPA When I Revise Any of My
Hazardous Waste Management Activities?
Commonly Asked Questions About On-Site Storage of
Hazardous Wastes
May I Accumulate Hazardous Wastes at the Point
of Generation in "Satellite" Accumulation Areas?
May I Store My Hazardous Wastes at My Facility
and for How Long?
3-1
3-1
3-2
3-3
3-4
3-5
3-5
3-5
3-8
3-9
3-9
3-11
3-13
3-13
3-13
3-15
3-15
3-16
3-16
3-16
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3.7.3 How Should I Store Hazardous Wastes at My Facility? 3-17
3.7.4 How Should I Prevent Accidents and
Plan for Emergencies? 3-19
3.7.5 Can I Store Hazardous Wastes in
Underground Storage Tanks (USTs)? 3-21
3.8 Commonly Asked Questions About Packaging,
Labeling, and Shipping Wastes Off-Site 3-22
3.8.1 How Do I Ship Hazardous Wastes Off My Premises? 3-22
3.8.2 How Should I Label My Waste Containers
for Shipment Off-Site? 3-24
3.8.3 How Do I Determine the DOT Description? 3-27
3.8.4 How Should I Package My Hazardous Wastes
for Shipment Off-Site? 3-27
3.8.5 What Is a Hazardous Waste Manifest? 3-30
3.8.6 Are There Any Exemptions to the
Manifesting Requirement? 3-33
3.8.7 What Should I Do if the Signed Manifest Is Not
Returned to Me by the Designated Facility? 3-33
3.9 Commonly Asked Questions About Recordkeeping and
Other Management Requirements 3-36
3.9.1 What Are My Recordkeeping and
Reporting Requirements? 3-36
3.9.2 May I Treat or Dispose of My Wastes at
My Facility Rather than Ship Them Off-Site? 3-38
3.9.3 What Should I Do If I Have Determined that
My Wastes Are Non-Hazardous? 3-39
3.10 Where to Call for Additional Assistance 3-39
Pennsylvania edition only
3.11 RCRA Regulations for SQGs in Pennsylvania 3-41
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IV
3.11.1 RCRA Regulatory Requirements for Conditionally
Exempt SQGs in Pennsylvania 3-41
3.11.2 On-Site Storage Time and Quantity Limitations
in Pennsylvania 3-43
3.11.3 Additional Requirements for the PA DER Manifest Form 3-45
3.11.4 Pennsylvania "Permit-by-Rule" 3-46
4.0 LAND DISPOSAL, SARA TITLE III, AND
UNDERGROUND STORAGE TANKS 4-1
4.1 Land Disposal Bans 4-1
4.1.1 Hazardous Wastes Containing Solvents and Dioxin 4-1
4.1.2 RCRA-Listed California-Listed Wastes 4-3
4.1.3 450 RCRA-Listed Hazardous Wastes 4-4
4.2 SARA Title III 4-5
4.2.1 Background 4-5
4.2.2 Emergency Planning and Notification, Community
Right-to-Know, and Toxic Chemical Release Reporting 4-5
4.2.3 Other Title III Provisions 4-9
4.2.4 SARA Title III—Key Dates to Remember 4-10
4.2.5 Emergency Planning, Right-to-Know, and
Waste Minimization 4-11
4.3 Underground Storage Tanks (USTs) 4-12
4.3.1 Financial Requirements 4-13
4.3.2 Technical Requirements—New Tanks 4-13
4.3.3 Technical Requirements—Existing Tanks 4-15
4.3.4 Response to Leaks 4-17
4.3.5 Closing USTs 4-18
4.3.6 Reporting and Recordkeeping Requirements 4-19
© 1989 HUH CHMR
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4.4 Where to Call for Additional Assistance with
Questions and Concerns Regarding Land Disposal
Bans, SARA Title III, or USTs 4-20
5.0 APPROACHES TO WASTE MINIMIZATION 5-1
5.1 Introduction 5-1
5.2 Developing Management Initiatives 5-2
5.2.1 Overview 5-2
5.2.2 Problem-Solving Through Employee Participation 5-3
5.3 Performing a Waste Audit 5-7
5.4 Improving Housekeeping 5-8
5.4.1 Waste Segregation 5-9
5.4.2 Improved Labeling 5-9
5.5 Substituting Materials 5-10
5.6 Technology Modifications 5-10
5.6.1 Process Modifications 5-11
5.6.2 Equipment Modifications 5-11
5.6.3 Process Automation 5-12
5.6.4 Changes in Operation Settings 5-12
5.6.5 Water Conservation 5-12
5.6.6 Energy Conservation 5-13
5.7 Recycling and Reuse 5-13
5.8 Participating Waste Exchanges 5-14
6.0 HOW TO CONDUCT A WASTE AUDIT 6-1
6.1 Introduction 6-1
6.2 Select the Audit Team 6-2
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6.3 Pre-lnspection Review 6-3
6.3.1 Audit Team Briefing on General Waste
Minimization Opportunities 6-3
6.3.2 Collect and Review Background Information
of the Facility 6-4
6.3.3 Identify and Characterize All Waste Streams 6-5
6.3.4 Request Additional Information 6-5
6.3.5 Prepare Checklist for Plant Inspection 6-6
6.4 Visit the Plant 6-7
6.5 Identify and List Plant-Specific Waste
Minimization Opportunities 6-7
6.6 Screen and Set Priorities for Waste
Minimization Actions 6-8
6.7 Examine Feasibility of Implementing
Recommended Waste Reduction Options 6-9
6.7.1 Overview 6-9
6.7.2 Technical Feasibility 6-9
6.7.3 Economic Feasibility 6-10
6.8 Evaluate Progress and Success of Waste
Minimization Process 6-15
6.9 Conclusions 6-16
7.0 GENERAL WASTE MINIMIZATION
PRACTICES 7-1
7.1 Good Operating Practices 7-1
7.1.1 Introduction 7-1
7.1.2 Good Operating Practices for Waste Minimization 7-2
7.2 Metal Parts Cleaning 7-9
7.2.1 Waste Description 7-10
© 1989 m^ CHMR
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7.2.2
7.2.3
7.3
7.3.1
7.3.2
7.3.3
7.4
7.4.1
7.4.2
8.0
8.1
8.1.1
8.1.2
8.1.3
8.1.4
8.2
8.2.1
8.2.2
8.2.3
8.2.4
8.2.5
8.3
8.3.1
8.3.2
8.3.3
Good Operating Practices for Waste Minimization
Specific Waste Minimization Practices
Paint Application
Waste Description
Good Operating Practices for Waste Minimization
Specific Waste Minimization Practices
Process Equipment Cleaning
Waste Description
Specific Waste Minimization Practices
INDUSTRY-SPECIFIC WASTE
MINIMIZATION PRACTICES
Vehicle Maintenance
Industry Description
Sources of Waste
Good Operating Practices for Waste Minimization
Specific Waste Minimization Practices
Fabricated Metal Manufacturing and Metal Finishing
Industry Process Description
Sources of Waste
Good Operating Practices for Waste Minimization
Waste Minimization Practices — Metal Manufacturing
Waste Minimization Practices — Metal Finishing
Electroplating
Industry Process Description
Sources of Waste
Good Operating Practices for Waste Minimization
7-10
7-13
7-13
7-13
7-13
7-13
7-17
7-17
7-17
8-1
8-2
8-2
8-2
8-3
8-4
8-6
8-6
8-7
8-7
8-8
8-11
8-19
8-19
8-19
8-20
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8.3.4 Specific Waste Minimization Practices 8-22
8.4 Printed Circuit Board Manufacturing 8-30
8.4.1 Industry Process Description 8-30
8.4.2 Sources of Waste 8-31
8.4.3 Good Operating Practices for Waste Minimization 8-32
8.4.4 Specific Waste Minimization Practices 8-32
8.4.5 Product Substitution Options 8-38
8.5 Laundry and Dry Cleaning 8-38
8.5.1 Industry Description 8-38
8.5.2 Sources of Waste 8-38
8.5.3 Good Operating Practices for Waste Minimization 8-39
8.5.4 Specific Waste Minimization Practices 8-40
8.6 Printing 8-43
8.6.1 Industry Process Description 8-43
8.6.2 Sources of Waste 8-43
8.6.3 Good Operating Practices for Waste Minimization 8-44
8.6.4 Specific Waste Minimization Practices 8-44
8.7 Photography 8-51
8.7.1 Sources of Waste 8-51
8.7.2 Good Operating Practices for Waste Minimization 8-51
8.7.3 Specific Waste Minimization Practices 8-51
8.8 Construction 8-55
8.8.1 Industry Process Description 8-55
8.8.2 Sources of Waste 8-56
8.8.3 Good Operating Practices for Waste Minimization 8-57
8.8.4 Specific Waste Minimization Practices 8-57
8.9 Educational and Vocational Shops 8-59
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8.9.1 Industry Process Description 8-59
8.9.2 Sources of Waste 8-59
8.9.3 Good Operating Practices for Waste Minimization 8-60
8.9.4 Specific Waste Minimization Practices 8-61
8.10 Analytical and Clinical Laboratories 8-63
8.10.1 Industry Process Description 8-63
8.10.2 Sources of Waste 8-64
8.10.3 Good Operating Practices for Waste Minimization 8-65
8.10.4 Specific Waste Minimization Practices 8-66
8.11 Pesticides 8-71
8.11.1 Industry Process Description 8-71
8.11.2 Sources of Waste 8-71
8.11.3 Good Operating Practices for Waste Minimization 8-71
8.11.4 Specific Waste Minimization Practices 8-72
9.0 WASTE-SPECIFIC MINIMIZATION
PRACTICES 9-1
9.1 Solvents 9-1
9.1.1 Source of Solvent Wastes 9-1
9.1.2 Solvent Recycling Technologies 9-1
9.1.3 On-Site Recycling Equipment 9-2
9.1.4 Solvent Loss Minimization Practices 9-3
9.2 Halogenated Organic (Non-Solvent) Wastes 9-5
9.2.1 Source of Halogenated Organic Wastes 9-5
9.2.2 Non-Solvent Recycling Technologies 9-5
9.2.3 Halogenated Organic Waste Minimization Practices 9-6
9.3 Metal Wastes 9-7
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9.3.1 Source of Metal Wastes 9-7
9.3.2 Metal Recovery from Waste Rinse Water 9-7
9.3.3 Metal Waste Recovery Technologies 9-8
9.4 Corrosive Wastes 9-10
9.4.1 Source of Corrosive Wastes 9-10
9.4.2 Corrosive Waste Recycling Technologies 9-11
9.5 Cyanide and Reactive Wastes 9-12
9.5.1 Source of Cyanide and Reactive Wastes 9-12
9.5.2 Cyanide Waste Recycling Practices 9-12
9.5.3 Reactive Waste Recycling Practices 9-13
9.6 Oils 9-14
9.6.1 Source of Oil Wastes 9-14
9.6.2 Off-Site Collection Centers 9-14
9.6.3 Oil Recycling Technologies 9-14
9.6.4 Oil Loss Minimization Practices 9-16
9.7 Sludges 9-16
9.7.1 Sources of Sludge 9-16
9.7.2 Sludge Minimization Practices in Storage Tank Cleaning 9-16
9.7.3 Sludge Minimization Practices in Utility Production 9-17
9.8 Off-Site Recycling and Recovery Centers 9-18
10.0 FINANCING A WASTE REDUCTION
PROGRAM 10-1
10.1 Types of Assistance 10-1
10.2 Private Funding of Waste Minimization Programs 10-1
10.2.1 Business Development Corporations 10-3
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10.2.2 Venture Capital 10-3
1 0.3 Government-Assisted Funding of a Waste
Minimization Program 10-4
10.3.1 Federal Assistance 10-4
10.3.2 State Assistance 10-6
10.4 Directories of State Contacts 10-8
1 0.4.1 National Directory of the National Association of
Business Development Corporations 10-8
1 0.4.2 State Agency Contacts for Pollution Control Financing 1 0-1 1
Pennsylvania edition only
10.5 State Assistance in Pennsylvania 10-15
10.5.1 Technical Assistance 10-15
10.5.2 Loans 10-17
10.5.3 Grants 10-19
11.0 SOURCES FOR INFORMATION
ON WASTE MINIMIZATION 11-1
11.1 CHMR's Program for SQG Assistance 11-1
1 1 .2 Other State Technical Assistance Programs 1 1 -2
1 1 .2.1 Waste Minimization and Treatment 11-2
1 1 .2.2 Underground Storage Tank (UST) Program Offices 1 1 -6
1 1 .3 Important Telephone and Hotline Numbers 1 1 -8
11.4 Other Useful Resources 11-11
11.4.1 Mailing Lists 11-11
11.4.2 Equipment Buyers' Guides 11-12
1 1 .4.3 Directories of Commercial Hazardous Waste Recovery
Treatment, and Disposal Facilities 11-13
11.5 Waste Exchanges 11-13
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1 1 .5.1 Northeast Industrial Waste Exchange (NIWE) 11-13
11.5.2 Other Waste Exchanges 11-14
1 1 .6 Waste Reduction/Recovery Equipment 11-17
11.6.1 Chemical Substitutes 11-18
11.6.2 Solvent Recovery Equipment 11-19
1 1 .6.3 Coolant Recovery Equipment 1 1 -21
1 1 .6.4 On-Site Hydraulic Oil Recycling 1 1 -21
11.6.5 Metal Recovery Equipment 11-21
1 1 .7 Other References 1 1 -23
Pennsylvania edition only
11.8 Pennsylvania Resources 11-27
1 1 .8.1 CHMR's Program for SQG Assistance in Pennsylvania 1 1 -27
11.8.2 Important Telephone Numbers 11-30
1 1 .8.3 Names and Addresses of Resource Organizations 1 1 -32
12.0 APPENDICES 12-1
1 2.1 List of Wastes Specifically Excluded from the
Definition of a RCRA Solid Waste or a RCRA
Hazardous Waste 1 2-1
1 2.2 EPA's Lists of Hazardous Wastes 1 2-3
1 2.3 Definitions of Ignitability, Corrosivity, and Reactivity 1 2-1 5
1 2.4 Maximum Concentrations of Contaminants for
Characteristics of EP Toxicity 1 2-1 7
1 2.5 EPA Hazardous Waste Numbers for Waste Streams
Commonly Generated by SQGs 1 2-1 9
1 2.6 Counting Your Hazardous Waste 1 2-23
Pennsylvania edition only
12.7 Counting Your Hazardous Waste in Pennsylvania 12-25
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CHAPTEI
1.0 INTRODUCTION
1.1 Why Is Waste Minimization Important?
The proper management of hazardous materials and waste is one
of the biggest issues facing all Americans. Virtually every industrial
and manufacturing process involves hazardous materials or pro-
duces hazardous waste. From an economic standpoint, the
management of hazardous materials may lead to spiraling costs
that can drastically affect any organization and its ability to com-
pete in the market place. There is also the issue of protecting public
health and the environment.
Why is hazardous waste minimization so important?
• Waste minimization is very important because business is
facing a crisis in the handling, transportation, and disposal
of hazardous wastes.
• Nationally, the number of hazardous waste disposal
facilities has substantially decreased.
• Regulators are restricting the use of landfills.
• Transportation and disposal costs are rising.
• Substantial long-term liability is associated with handling
and disposal of hazardous waste.
Why minimize? Initially, many companies implemented waste
reduction options because of new pollution regulations and the
rising cost or unavailability of landfills. However, nearly all these
companies later realized other, more important benefits, includ-
ing:
• lower operating costs from the substitution of less
expensive raw materials;
1989 HHCHMR
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1-2
• lower energy costs through the use of newer, more efficient
equipment;
• improved product quality;
• increased safety from reduced employee exposure to
hazardous materials; and
• improved public image—the less waste you produce, the
less your business is viewed as a contributor to
environmental problems.
Thousands, even millions, of dollars are being saved, not just in
disposal costs, but in reduced expenditures on energy, fuel, water,
and raw materials. In other words, waste reduction is economically
as well as ecologically sound. It's simply good business.
Numerous case studies indicate that the sound management of
resources results in simultaneous economic and ecological bene-
fits regardless of the size of an organization. These case studies
show that:
• waste reductions can range from 20 to 98 percent,
• payback periods for waste minimization investments
typically range from immediate to 5 years, and
• firms which handle fewer hazardous materials reduce
hazards to their workers and the environment—and
experience fewer long-term liability and victim
compensation claims.
The Minnesota Mining and Manufacturing Corporation (3M) has
been a leader in implementing what they call their Pollution Pre-
ventionPays program. In the first 9 years of the 3P program, 1,200
employee suggestions were approved, and together they helped
the company save $192 million. At the same time, 3M estimates
1989 ••• CHMR
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1-3
that they have shrunk their level of potential hazardous waste
discharge by 50 percent, and plans to cut its current levels by an-
other 50 percent during the next 5 years.
1.2 The New National Waste Management Strategy-
Begin with Waste Minimization
Over the past two decades, Americans have developed an in-
creased awareness of the harmful effects to human health and the
environment from uncontrolled releases of pollutants and hazard-
ous substances. Initially this led to a national waste management
strategy which emphasized control and cleanup of pollution by
hazardous substances after they are generated and no longer
serve a productive function. Usually, hazardous industrial wastes
are not destroyed by pollution control methods. Rather, they are
put into the land, water, or air where they disperse and migrate.
Now the nation is turning its attention to preventing hazardous
waste problems by cutting down on the generation of hazardous
waste at its source. The following national policy on waste
reduction was included in the Resource Conservation and Recov-
ery Act, as amended by the U.S. Congress in November 1984:
The Congress hereby declares it to be the national policy of the United
States that, wherever feasible, the generation of hazardous waste is to
be reduced or eliminated as expeditiously as possible. Waste neverthe-
less generated should be treated, stored, or disposed of so as to minimize
the present and future threat to human health and the environment.
As a result, a new recommended strategy for waste management
has evolved. This new strategy includes waste minimization as the
first important step to be considered in the overall approach to
waste management. In summary, the following new hierarchy for
waste management decision-making is developing as the new
national policy for waste management.
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• First, consider source reduction options—any activity that
reduces or eliminates the generation of a hazardous waste
within a process.
• Next, consider recycling. This is the use, reuse, or
reclamation of a waste either on- or off-site after it is
generated by a particular process.
• Next, consider beneficially using waste for energy
recovery. Some specific wastes can be beneficially
used as a fuel under carefully controlled conditions to
recover their energy value.
• Next, consider treatment to reduce the toxicity of
hazardous waste.
• Finally, and only as a last resort, consider land disposal.
This new national strategy on waste management is further em-
phasized by the following Generator's Certification statement
included on the Uniform Hazardous Waste Manifest, which must
be signed by all hazardous waste generators who ship hazardous
wastes off-site for treatment, storage, or disposal.
If I am a large quantity generator, I certify that I have a program in
place to reduce the volume and toxicity of waste generated to the degree
I have determined to be economically practicable and that I have
selected the practicable method of treatment, storage, or disposal
currently available to me which minimizes the present and future threat
to human health and the environment, OR, if I am a small quantity
generator, I have made a good faith effort to minimize my waste genera-
tion and select the best waste management method that is available to
me and that I can afford.
On August 4, 1988, the United States Environmental Protection
Agency (U.S. EPA) established a Pollution Prevention Office re-
porting directly to the Assistant Administrator for the Office of
Policy, Planning, and Evaluation (OPPE).
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1-5
The Pollution Prevention Office will be service oriented. Its func-
tions include: stimulating public awareness through outreach ac-
tivities; assisting other EPA offices in their programs; coordinating
outreach to the states and supporting development of state pro-
grams; establishing a strategy for collecting, analyzing, and dis-
seminating data; identifying research needs; creating incentives
and identifying barriers to pollution prevention; and developing
general policies and strategies pertaining to source reduction.
In addition, U.S. EPAcreated an Agency-wide Pollution Prevention
Advisory Committee comprised of office directors and senior re-
gional managers. It will be co-chaired by the Assistant Administra-
tor for OPPE and one of the committee members.
Finally, U.S. EPA's Office of Research and Development created
a Waste Minimization Branch within the newly created Waste Mini-
mization Destruction and Disposal Research Division in its Cincin-
nati, Ohio Research Laboratory.
1.3 How to Use this Manual
This manual has been prepared to provide businesses with prac-
tical information on how to approach and implement a hazardous
waste minimization program. The intended audience for this
manual is comprised of owners, managers, and responsible offi-
cials of businesses and organizations that are small quantity
generators (SQGs) of hazardous waste. Answers are provided to
commonly asked questions such as these:
• What are the advantages of waste minimization?
• How does waste minimization relate to the worker and
community Right-to-Know laws?
• How do I get started on a waste minimization program?
• How do I conduct a waste audit?
• What specific waste minimization practices can I use?
1989 BHCHMR
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• How can I finance my waste minimization program?
• How can I get more help on waste minimization and on my
hazardous waste problems?
The illustration on the next page explains how to use this manual
to obtain the information you need.
1.4 The Difference Between U.S. EPA and
State Environmental Regulatory Agencies
The United States Environmental Protection Agency (U.S. EPA) is
the Federal agency responsible for enforcing the Federal environ-
mental laws such as the Resource Conservation and Recovery Act
(RCRA) and the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), otherwise known as
Superfund.
The state environmental regulatory agencies are responsible for
enforcing the state environmental laws such as a state's solid
waste management act. Under such state acts, the state environ-
mental regulatory agency has RCRA regulations similar to those of
the U.S. EPA.
In many states, the state agency has been delegated the respon-
sibility to administer the Federal RCRA program under U.S. EPA
oversight. This means that:
• most RCRA permits are issued by the state agency,
• most RCRA notifications and reports must be sent to the
state agency, and
• most RCRA inspections are performed by state agency
personnel.
'1989 •HCHMR
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How to Use This Manual
If Your Question Is...
Refer to
Why is waste minimization
important ?
'm not convinced...
ffcw can I benefit from waste
minimization
I'm confused about I?£RA
do I comply ?
WhM about
cfncr environmental regulations
imy input my tw5inc?s.'
Ok, I'm convinced.
How do I approach waste minimization ?
What wt my options?
are some specific practices
for my business f
\-
I gef help financing
my program?
Who can I call for help?
CHAPTER 1.0 INTRODUCTION
CHAPTER 2.0 ADVANTAGES OF WASTE
MINIMIZATION
CHAPTER 3.0 RCRA REGULATIONS FOR
SQGs
CHAPTER 4.0 LAND DISPOSAL BANS, SARA
TITLE III, AND UNDERGROUND
STORAGE TANKS
CHAPTER 5.0 WASTE MINMIZATION
APPROACHES
CHAPTER 6.0 HOW TO CONDUCT A
WASTE AUDIT
CHAPTER 7.0 GENERAL WASTE
MINIMIZATION PRACTICES
CHAPTER 8.0 INDUSTRY-SPECIFIC WASTE
MINIMIZATION PRACTICES
CHAPTER 9.0 WASTE-SPECIFIC
MINIMIZATION PRACTICES
CHAPTER 10.0 FINANCING WASTE
REDUCTION
CHAPTER 11.0 SOURCES FOR MORE
INFORMATION
i 1989
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State regulatory requirements must be at least as stringent as the
Federal requirements (exceptions sometimes occur when a Fed-
eral regulation was recently changed and made more stringent,
and the state regulation has not yet been revised to keep up with
the Federal standards). You have to comply with the most stringent
requirements whether they are Federal or state. In any case, the
U.S. EPA retains primary responsibility for:
• research and development,
• education and training,
• technology transfer,
• policy and regulation developments in response to revisions
of the Federal laws, and
• oversight of state programs where the states have been
delegated authority to administer the Federal RCRA
program.
1.5 Definitions of Some Important Terms
Before proceeding, you should become familiar with the following
definitions.
Waste minimization means the reduction, to the extent feasible,
of hazardous waste that is generated or subsequently treated,
stored, or disposed. It includes any source reduction or recycling
activity undertaken by a generator that results in either (1) the
reduction of total volume or quantity of hazardous waste, or (2) the
reduction of toxicity of hazardous waste, or both, so long as the
reduction is consistent with the goal of minimizing present and
future threats to human health and the environment.
Source reduction refers to the reduction or elimination of waste
generation at the source, usually within a process. Source reduc-
' 1989 •• CHMR
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WHAT IS
HAZARDOUS
WASTE
tion measures can include so me types of treatment processes, but
they also include process modifications, feedstock substitutions or
improvements in feed-stock purity, various housekeeping and
management practices, increases in the efficiency of machinery,
and even recycling within a process. Source reduction implies any
action that reduces the amount of waste exiting from a process.
Recycling refers to the use or reuse of a waste as an effective
substitute for a commercial product, or as an ingredient or feed-
stock in an industrial process. It also refers to the reclamation of
useful constituent fractions within a waste material — or removal
of contaminants from a waste to allow it to be reused. Recycling
refers to the use, reuse, or reclamation of a waste, either on- or
off-site, after it is generated by a particular process.
RCRA solid waste has been defined by RCRA as any discarded
material not specifically excluded by the Act. A discarded material
is any material (solid, liquid, orcontained gas) which is abandoned
(disposed, burned, or incinerated), recycled, or considered inher-
ently waste-like. Because it is difficult to devise a definition that dis-
tinguishes between product-like and waste-like sludges and by-
products, U.S. EPA will evaluate these materials individually when
they are recycled to determine if the RCRA rules apply.
Hazardous waste is defined by RCRA as a solid waste (including
liquids and gases) which may:
• cause or significantly contribute to an increase in mortality
or in serious illness, or
• pose a substantial hazard to human health or the
environment when improperly managed.
The definition of hazardous wastes can be found in Title 40 of the
U.S. Code of Federal Regulations (CFR) Section 261.3. By defi-
nition, wastes are hazardous if they are (1) listed (specifically
named) or (2) if they exhibit any of four hazardous waste charac-
teristics (ignitability, corrosivity, reactivity, or extraction procedure
© 1989
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[EP] toxicity). Mixtures of a solid waste and a listed hazardous
waste are also considered hazardous.
Listed hazardous waste is defined as any waste which appears
on any one of the following three lists of hazardous wastes con-
tained in RCRA:
• the F lists of hazardous wastes from non-specific sources
(e.g., waste water treatment sludges from electroplating
operations),
• the K list of hazardous wastes from specific sources (e.g.,
bottom sediment sludge from the treatment of waste waters
from wood preserving),
• the U and P lists of discarded commercial chemical
products, including products that do not meet precise
manufacturing specifications, their containers, and spill
residues.
- The products on the U list are called toxic wastes
(e.g., vinyl chloride).
- Those on the P list are called acute hazardous wastes
(e.g., cyanides).
© 1989 j^H CHMR
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Characteristic hazardous waste is a waste which may not ap-
pear on one of the U.S. EPA lists, but is considered hazardous if it
has one or more of four characteristics:
• Ign liability
• Corrosivity
• Reactivity
• EP (Extraction
Procedure) Toxicity
For further details, see
Section 3.6.1 and the Appendices
[gullibility
Cortosivity
Acutely hazardous waste has been defined by the U.S. EPA as
waste so dangerous in small amounts that it is regulated the same
way as large amounts of other hazardous wastes. Acutely hazard-
ous wastes, forexample, may be generated from certain pesticides
ordioxin-containing wastes. Those wastes included on the P list
of hazardous wastes have been identified as acutely hazardous
wastes.
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CHAPTER
2.0 ADVANTAGESOF WASTE MINIMIZATION
2.1 Overview
The many incentives for waste minimization, although interrelated,
fall into three categories:
• Economic — money can be saved, or a profit made.
• Regulatory — fewer compliance requirements with reduced
waste.
• Good public image — by showing concern for the
environment, the safety and health of workers, and the
surrounding community.
Many business owners and operators see a close relationship
between the increasing waste management costs for industry and
rising health and environmental concern by society. The resulting
economic pressures are encouraging industry to be more efficient
in the management of its waste, including its toxic and hazardous
substances.
Numerous case studies indicate that the sound management of
resources results in simultaneous economic and ecological bene-
fits regardless of the size of an organization.
Thousands, even millions, of dollars are being saved, not just in
reduced disposal costs, but in reduced expenditures on energy,
fuel, water, and raw materials. If less waste is produced, there is
less potential for damage to the environment. Consequently,
waste reduction is sound economically as well as ecologically. It's
simply good business.
2.2 Economic Incentives: Specific Cases
2.2.1 Direct Profits from Environmental Compliance
In 1979, the U.S. EPA told a metal finishing company that if they did
not comply with water quality standards within 2 years, the Agency
would close the plant. For 40 years prior to the U.S. EPA notice,
®1989 HMCHMR
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the company had been discharging its waste stream, containing
high concentrations of nickel, zinc, and cyanide, into a nearby
marsh. The company implemented a waste minimization program
in order to achieve environmental compliance.
Specifically, this firm replaced its old, single-pass waste treatment
system with a batch treatment system, keeping all of the waste in
on-site holding tanks until the liquid waste could be treated.
Not only did this company come into environmental compliance,
but it also turned a considerable profit. The company now:
• saves an average of 11,500 gallons of water per day,
• saves $58,460 annually in waste disposal costs,
• saves $29,400 annually in pollution control equipment costs,
• saves $10,200 annually in personnel and maintenance
costs, and
• avoids the legal liability associated with hazardous waste
disposal in a landfill.
This example is just one of the many waste minimization success
stories. The following pages will identify some further incentives for
developing and implementing a waste minimization program.
2.2.2 Reduced Costs Through Better Management and Efficiency
The less a firm wastes, the more efficient its operation. Your total
operating costs can be significantly reduced by minimizing your
waste generation. In addition, many companies have experienced
improved production capacity and product quality, as well as
savings in expenditures for utilities and raw materials. Reduced
costs can be accomplished through better management and a
more efficient use of raw materials. Here are some examples.
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The Hamilton Beach Division of Scovill, Inc. manufactures
small electric appliances. Scovill tested a water-soluble
synthetic cleaner as a possible substitute for the 1,1,1-
trichloroethane organic solvent degreaser at one of its
plants. The cleaner is manufactured by the Cincinnati
Milacron Company of Cincinnati, Ohio. They found the
cleaner suitable for some of their applications, and have
been able to reduce their 1,1,1- trichloroethane use by 30
percent. The Scovill plant reports a $12,000 annual savings
from this substitution.
ITT Telecom reduced the quantity of waste solvents they
generate by replacing a solvent based, photo resist
system with an aqueous-based system. Previously,
organic solvents such as 1,1,1-trichloroethane and
methylene chloride were used to develop and strip the
photo resist from the circuit board. The aqueous-based
system uses water-miscible solvents from the glycol-
ether family. The new system reduces hazardous waste
generation and also improves product quality while
reducing production time.
A fiberglass coating company which generated waste
acetone during process equipment cleanup now has 70 per-
cent of that acetone recovered by off-site recycling. The re-
cycled acetone costs 10 percent less than virgin acetone, thus
reducing the cost of production. In addition, waste disposal
costs have been eliminated, saving the company thousands of
dollars annually.
The Stanadyne Company undertook a comprehensive and
systematic review of their electroplating processes in order
to reduce or eliminate waste generation. Their efforts have
resulted in a broad spectrum of activities which have saved
the firm money and minimized pollution—a total waste
reduction of 46 percent has been realized. Some of these
activities included:
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- A sulfuric/peroxide bright dip was substituted for a
chromic acid bright dip for cleaning brass and copper
parts which have been brazed together. This substitu-
tion reduced overall sludge production.
- The concentrations of chemicals used in the cyanide, copper
and chrome plating baths were reduced. By running the
potassium cyanide concentration at 2.5 instead of
3.5 ounces per gallon, the cyanide dragout concentration
has been reduced by 28 percent, without any adverse
effect on plating quality. In the chrome baths, the chromic
acid levels are maintained at about 29 instead of 32 ounces
per gallon. This 9 percent reduction results in savings due to
reduced raw material requirements.
- A rack to minimize dragout was redesigned.
- A simple dragout recovery system was installed on the
nickel plating machine for zinc die-castings. Less than
$1,000 was invested for a storage tank. This system saves
the firm $4,200 worth of nickel per year, and reduces the
generation of nickel sludge by 9,500 pounds per year.
- Items to be electroplated are inspected to eliminate
defective parts before they enter the plating process.
Since plating a defective part creates the same amount
of waste as plating a good one, the elimination of
defective parts from the plating operation results in
direct waste reduction.
2.2.3 Reduced Treatment, Transportation, and Disposal Costs
A successful waste minimization program can help your business
reduce the amount of money it spends on treating, transporting,
and disposing of hazardous wastes. The combination of new laws
and regulations, and the increasing cost of liability insurance, have
caused a dramatic increase in the cost of hazardous waste
management. With increasing disposal costs, waste minimization
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is providing an economical alternative to the treatment, transpor-
tation, and disposal of hazardous wastes.
• The Rexham Corporation facility in Greensboro, North
Carolina, is involved in the manufacture and printing of spe-
cialized product labels. Rexham installed a Cardinal distil-
lation unit to reclaim n-propyl alcohol from their waste
solvent for a total installed cost of $16,000. The distilla-
tion unit recovers 85 percent of the solventinthe waste stream,
resulting in a savings of $15,000 per year in virgin solvent
costs, and in a $22,800 savings in hazardous waste dis-
posal costs.
• The Daly-Herring Company manufactures pesticides and
generates pesticide dust from two major production sys-
tems. The firm replaced the single baghouse with two
separate vacuum-air-baghouse systems specific to the two
production lines at a total cost of $9,600. The collected
materials are no longer contaminated by alternate waste
streams, and each is recycled back to the process where it
was generated. They have eliminated over $9,000 in
annual disposal costs, and estimate that the recovered
material is worth more than $2,000 per year.
• The Emerson Electric Company's waste management pro-
gram reduced raw material costs by $642,000 per year,
water costs by $2,200 per year and waste disposal costs by
$52,700 per year through process modifications and mate-
rial recovery. This program has increased productivity,
reduced operating costs, and minimized waste generation
rates. Some examples follow.
- An automated electroplating system has reduced proc-
ess chemical usage by 25 percent, process batch dumps by
20 percent, and waste water treatment costs by 25 percent.
- The replacement of a solvent-based painting system
with a water-based electrostatic immersion painting
system has reduced waste solvent and waste paint
solids generation by over 95 percent.
1989 HHCHMR
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2.2.4 Income Derived Through Sale or Reuse of Waste
It is sometimes said that one company's waste is another's re-
source. This is often true, as the various waste exchanges through-
out the country have proven. Prof its can be realized when firms sell
their wastes as by-products to other firms which can use them as
raw materials. Additionally, many wastes can be reused, some-
times as fuels (as in the case of waste solvents), or as recycled raw
materials within the process itself.
• An office furniture manufacturer now saves $100 per week
in solvent costs by reusing about 85 percent of its waste lacquer
thinner. The company invested in a small solvent recovery
unit, which paid for itself in about 1 year. The other 15 percent
of the waste lacquer thinner which is not suitable for reuse is
used as fuel. The waste is burned in the plant's wood-chip
fueled boiler. This has eliminated their hazardous waste
disposal costs.
• A manufacturer of small electric appliances requires 1,1,1-
trichloroethane solvent to degrease metal stampings. Sol-
vent wastes are collected in 55-gallon drums; the drums are
housed in a storage building designed to contain spills.
Ashland Chemical Company was contracted to recycle the
waste by distilling the 1,1,1-trichloroethane. Substituting
the recycled solvent for the virgin product has reduced their
overall raw material costs at one plant by $5,320 per year.
This plant also eliminated all of its previous waste disposal
costs, estimated to be about $3,000 per year.
• At a label printing company, waste toluene from printing
press cleanup has been eliminated by segregating the
solvent according to the color and type of ink cleaned from
the press. Each segregated batch of toluene is then reused
for thinning the same color ink.
1989 ••• CHMR
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2.2.5 Reduced Costs for Waste Water Treatment
The cost of meeting waste water treatment standards can be
extremely high. Increasingly stringent pretreatment and effluent
limitations are forcing many industries to install costly waste water
treatment facilities. Both capital and operating expenses forthese
facilities are escalating rapidly. By judiciously minimizing their
waste, many companies can significantly reduce this expense.
• In order to meet environmental standards, a textile dye and
finishing plant reduced its phosphorus discharge by reevalu-
ating its production process. Rather than build expensive
waste treatment systems to remove phosphorus, the com-
pany instead modified its existing processes and substiti-
tuted non-phosphorus-containing chemicals. Such chemi-
cals as hexametaphosphate and phosphoric acid were
eliminated from the production process. As a result, the
phosphorus discharge levels were reduced without any
capital expenditures for waste water treatment to remove
phosphorus.
• A film developing unit at 3M's Electronics Products Divi-
sion was discharging waste water contaminated with
1,1,1 -trichloroethane. In order to recycle the solvent and
to remain in compliance with process waste water dis-
charge regulations, 3M installed a decanter system that
provides gravity separation of the solvent from the water.
The decanter system cost $4,000, including installation,
and has saved the company $12,000 in its first year by
reducing the amount of new solvent and makeup water
required for the developing unit.
2.2.6 Lower Risks for Spills, Accidents, and Emergencies
The use of hazardous materials, and the generation, handling, and
management of hazardous waste entails a certain amount of risk.
Hazardous substance spills, accidents, and emergencies can cost
small businesses thousands of dollars. These risks can be
1989
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reduced with the proper management of the hazardous materials
used, and the minimization of those which are wasted.
• A dye company was able to improve its safety program
by appointing a committee made up of safety, medical,
legal, and technical experts from within the company.
This committee screened all chemicals used at the plant,
as well as those used in the development of new prod-
ucts on the basis of their relative safety in use, fire poten-
tial, and hazard to the environment. This management
tool has saved the company countless man-hours in
reduced accidents and spill clean up costs.
2.2.7 Lower Long-Term Liability and Insurance Costs
According to RCRA, a hazardous waste generator is responsible
for its waste from "cradle to grave." In other words, once you
generate a waste, you are legally responsible for it forever. In
addition, Federal and state laws have established the precedent
that generators of hazardous waste are at least partially respon-
sible for the cleanup of wastes which have leaked from disposal
sites containing their waste. This kind of financial responsibility can
potentially cost small quantity hazardous waste generators sub-
stantial sums of money.
This responsibility translates into what many insurance experts
now call the "liability crisis." The liability insurance premiums for
firms producing hazardous waste have increased by hundreds of
percent in the last 5 years due largely to the increase in law suits
against hazardous waste generators involved in accidental spills
and leaking disposal sites.
One possible way to eliminate or reduce this expense is to
eliminate or reduce the cause of the liability—the generation of
hazardous waste. By minimizing the hazardous waste you gener-
ate, you can reduce your long-term liability.
• A diesel engine manufacturer initiated a program which
ensures that all products entering the plant are screened by
a review committee. This committee attempts to reduce the
' 1989 ••• CHMR
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number of hazardous materials entering the plant, and thus
reduce the amount which leaves the plant as waste. As a
result, this firm has reduced the cost of complying with en-
vironmental and worker safety regulations, as well as waste
management, long-term health care, and liability costs.
• Vulcan Automotive Equipment Ltd. remanufactures used
automotive engines. The cleaning process was modified by
replacing the inorganic caustic cleanser with a high-velocity
"aluminum shot" system. The new system has improved the
overall appearance of the business and has substantially
reduced health hazards to the workers. All by-products of
the new process are recycled. Total cost of the system was
approximately $80,000 and an estimated annual savings of
$40,000 is expected. The new aluminum shot system in-
creases productivity and improves the final product.
2.3 Regulatory Incentives
New Federal laws and regulations limit waste management alter-
natives by eliminating or greatly restricting land-based disposal.
As a result, generators of hazardous waste will be forced to
examine other waste management alternatives, including waste
minimization.
In addition to the outright ban of certain disposal options and
increasing costs of all waste disposal, the amount of managerial
work required to comply with environmental regulations can be-
come extremely expensive to small business. By minimizing the
generation of hazardous waste, these compliance requirements
can be reduced as well.
• A specialized printing firm is involved in the production of
product labels. The company has already installed a
distillation unit which recovers 85 percent of the solvent in the
waste stream, and they are now planning to add another unit
to recover the remaining 15 percent. The residue resulting
from the second distillation unit should be non-hazardous
waste that can be sent to a sanitary landfill. The new unit is
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especially appealing because it will allow the plant to
become declassified as a hazardous waste generator.
2.4 Improved Public Image
While the strongest incentives for reducing waste generation are
undoubtedly economic and regulatory, many companies are set-
ting up waste minimization programs out of sensitivity to public
concern over toxic chemicals. This type of corporate good citizen-
ship is perceived to have long-term benefits, such as good relations
between plants and local communities, as well as between compa-
nies and the general public.
In addition to reducing costs and increasing profits, an efficient
hazardous waste minimization program can:
• improve safety;
• reduce the amount of wastes for disposal, consequently
reducing environmental impacts on the community; and
• reduce the number of hazardous materials used in the
workplace.
These three factors add up to one important business tool—an
improved public image. Hazardous waste is a controversial topic,
and most communities are vehemently opposed to the disposal of
hazardous wastes in their localities. By reducing the amount of
hazardous waste you generate, you can show the public and your
potential customers that you are making an effort to curtail the
pollution of our land and ground water.
The public always looks favorably upon companies with good
safety records. In addition, a safe working environment will tend to
attract more new employees than a less-safe job site. Since a
waste minimization program can lead to improved on-the-job
safety, such an improvement can only help to attract new employ-
ees and improve public relations.
PUBLIC
PARTICIPATION
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Finally, with the inception of the Federal Emergency Planning and
Community Right-to-Know Act of 1986 (SARA Title III), there are
established requirements regarding emergency planning and
"community right-to-know" reporting on hazardous andtoxicchemi-
cals. The community right-to-know provisions will help to increase
the public's knowledge and access to information on the presence
of hazardous chemicals in theircommunities and releases of these
chemicals into the environment.
The general public, in particular, is usually uneasy with the pres-
ence of hazardous chemicals in their neighborhoods. A reduction
in the use of hazardous chemicals can improve a company's
relationship with its community neighbors.
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CHAPTER
3.0 RCRA REGULATIONS FOR
SMALL QUANTITY GENERATORS
3.1 Introduction
This chapter is designed to help businesses determine if they are
small quantity generators of hazardous waste. In addition, proper
storage, shipment, treatment, and disposal procedures are dis-
cussed.
3.2 What Is a Small Quantity Generator (SQG)?
In 1976, Congress passed the Resource Conservation and Recov-
ery Act (RCRA), which directed the U.S. Environmental Protection
Agency (U.S. EPA) to develop and implement a program to protect
human health and the environment from improper hazardous
waste management practices.
U.S. EPA first focused on large companies which generate the
greatest portion of hazardous waste. Establishments producing
less than 1,000 kilograms (2,200 pounds) of hazardous waste in a
calendar month, known as small quantity generators (SQGs), were
exempted from most of the hazardous waste regulations published
by U.S. EPA in May 1980.
In November 1984, the Hazardous and Solid Waste Amendments
(HSWA) to RCRA were signed into law. With these amendments,
Congress directed the U.S. EPA to establish new requirements
that would bring small quantity generators who generate less than
1,000 kilograms (kg) of hazardous waste in a calendar month into
the regulatory system. U.S. EPA issued final regulations for these
small quantity generators on March 24,1986. Most of the require-
ments became effective September 22, 1986.
3.3 Types of Businesses Most Likely to Produce
Small Quantities of Hazardous Wastes
Types of businesses most likely to produce small quantities of
hazardous wastes include:
• vehicle maintenance firms,
@1989 HHCHMR
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• metal manufacturers and metal finishers (including electro-
plating and printed circuit boards),
• construction companies,
• printing companies,
• photographic processors, and
• laundries and dry cleaners.
Other businesses affected by the SQG RCRA regulations include
educational and vocational shops, analytical and clinical laborato-
ries, and pesticide applicators. The most common hazardous
wastes produced by SQGs are:
Typical types
of hazardous waste
Acids/bases
Ignitable wastes
Solvents
Pesticides
Spent plating wastes
Ink sludges
Reactives
Lead acid batteries
Dry cleaning residues
Examples
Various acids, ammonium hydroxide,
sodium hydroxide
Acetone, n-butyl alcohol, ethyl ether,
methyl alcohol, xylene
Perchloroethylene, isopropyl or ethyl
alcohol, trichloroethylene
Aldicarb, aldrin, DDT, dieldrin
Cyanide, heavy metals, solvents
Ink sludges with chromium or lead
Hypochlorites, sulfides
Lead dross, spent acid
Spent filter cartridges, solvent
distillation residues
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3.4 Regulatory Requirements for Small Quantity
Generators
In March 1986, the Federal regulations for hazardous waste
management were modified to bring businesses that generate
small amounts of hazardous waste into the regulatory system. The
1986 rules set new requirements for those generators that gener-
ate less than 1,000 kilograms (about 2,200 Ib) of hazardous waste
in a calendar month.
According to the Federal regulations, there are two categories of
SQGs:
• generators of no more than 100 kg/mo—known as "condi-
tionally exempt small quantity generators," and
• generators of between 100 and 1,000 kg/mo—known as
"non-exempt small quantity generators."
Table 3-1 provides a brief summary of the regulatory requirements
for these two categories of SQGs.
The following sections provide answers to some commonly asked
questions concerning the RCRA regulations for SQGs such as
"How do I determine how much hazardous waste I generate?"
"What is my generator category?" and "How do I comply with the
various RCRA requirements?"
3.5 Exemptions
Federal and state regulations provide some specific exemptions
from the hazardous waste management requirements for certain
wastes. These exemptions can be very important because they
usually provide the flexibility necessary to encourage waste recy-
cling.
1989 IMCHMR
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Table 3-1. RCRA Regulatory Requirements for Small
Quantity Generators.
Requirement
Less than 100-1,000
100 kg/mo kg/mo
Determine quantity of
hazardous waste generated
Obtain EPA I.D. number
Observe accumulation time
or quantity limits
Observe storage facility
criteria
Prepare and plan for
accidents or emergencies
Properly label and package
shipments
Ship wastes with a manifest
Use a licensed transporter
Ship to an approved treatment,
storage, or disposal facility
Keep records
Required Required
Required
Required Required
Required
Required
Required
Required
Required
Required Required
Required
3.5.1 On-Line Recycling
Hazardous wastes which are reclaimed continuously on site with-
out storing the waste priorto reclamation (e.g., continuous, on-line
recycling of certain solvents) are exempt from all hazardous waste
management requirements. However, any residue removed from
the reclaiming equipment must be handled according to all the
requirements set forth in this manual.
© 1989
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3-5
3.5.2 On-Site Reclaiming Preceded by Waste Accumulation
and Storage
Hazardous wastes which are reclaimed on site but which are also
accumulated for any period of time before reclaiming (e.g., batch
recovery of spent solvents in a solvent distillation unit) are subject
to the following hazardous waste management requirements.
• The hazardous wastes being reclaimed must be included in
the calculation to determine how much hazardous waste is
generated (see Section 3.6.3).
• The hazardous wastes being reclaimed must be handled
according to the "storage facility criteria" described in Sec-
tion 3.7.3.
• The reclaiming process itself is not subject to any hazardous
waste management requirements and does not need a
permit.
• Any residue removed from the reclaiming process is a haz-
ardous waste and must be handled according to all the re-
quirements set forth in this manual (except that the residue
need not be included in the calculation to determine quantity
of hazardous waste generated because it was already
counted in the hazardous waste fed into the reclaiming proc-
ess).
3.5.3 Off-Site Reclaiming
If hazardous wastes are shipped off-site to a com mercial reclaimer,
such hazardous wastes are subject to all of the hazardous waste
management requirements set forth in this manual. However,
under certain special conditions (fully described in Section 3.8.5),
these wastes may be exempt from the requirements to ship such
wastes with a manifest.
1989 —•CHMR
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3.5.4 Used Oil
Used oil is a common waste stream and an important potential
source of resource conservation. However, it is also potentially
harmful to human health and the environment if it is disposed of
improperly.
Typically, used crankcase oil from vehicles fueled by leaded
gasoline would meet the toxicity definition due to the presence of
heavy metal contaminants. Lubricants and coolants may also pick
up toxic contaminants, depending on the equipment and materials
they contact during use. Finally, reported past practices of blending
hazardous wastes—such as spent solvents—with used oil have
further increased concern over the potential harmful effects from
the improper management of used oil.
For these reasons, the current U.S. EPA regulations on used oil
include:
• U.S. EPA has issued special requirements for used oil
burned for energy recovery in boilers and industrial
furnaces. Such used oil is termed "used oil fuel" and
includes any fuel produced from used oil by processing,
blending, or other treatment.
• U.S. EPA initially decided not to list used oil intended for
recycling as a hazardous waste. However, this decision was
rejected by the courts on October 7,1988, and U.S. EPA
is reconsidering its regulation and will issue management
standards for recycled oil in the future.
• U.S. EPA has not yet determined whether to regulate used
oil bound for disposal as a hazardous waste. However,
because serious environmental problems result from
improper disposal of used oil, EPA intends to regulate these
activities under RCRA or through an approach combining
RCRA and the Toxic Substances Control Act (TSCA).
SQGs who generate used oil must therefore determine whether
their used oil is to be:
CHMR
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• burned for energy recovery,
• recycled, or
• discarded.
Guidelines for Used Oil Fuel Burned for Energy Recovery
Generators and marketers of used oil fuel must comply with the
following guidelines.
• Do not mix other hazardous wastes—such as spent sol-
vents—with used oil fuel. Such mixtures are regulated as
hazardous wastes and subject to special requirements for
burning hazardous wastes for energy recovery. Used oil
containing more than 1,000 ppm of total halogens is pre-
sumed to be a hazardous waste.
• Used oil fuel exceeding any of the specifications below is
subject to the requirements for an "off-specification" used
fuel oil.
Contaminant/property Allowable level
Flash point 100°F, minimum
Arsenic 5 ppm, maximum
Cadmium 2 ppm, maximum
Chromium 10 ppm, maximum
Lead 100 ppm, maximum
Total halogens 4,000 ppm, maximum
(e.g..chlorine)
Off-specification used oil fuel may be sold to industrial
burners only.
Persons who market off-specification used oil fuel must
notify EPA of their activities and include in that notification
copies of the burner's certificate of compliance. Any off-
specification used oil fuel that is shipped must be invoiced.
>198d HHCHMR
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3-8
• Blending of off-specification used oil fuel to meet specifica-
tions is permitted as long as blenders notify EPA of their
activities and keep copies of analyses or other information
used to determine that the fuel meets specifications.
• On-specification used oil fuel may be sold to anyone. Most
marketers of used oil fuel (e.g., persons who collect used oil
from generators and produce used oil fuel from these used
oils, and persons who collect and distribute used oil fuel to
burners) must have an analysis performed to show that the
allowable levels given in the previous table are not ex-
ceeded. Such marketers must keep records of that analy-
sis, as well as the date, quantity, and name of the facility
receiving their shipments of on-specification used oil. These
records must be kept for 3 years. (Note: Generators and
collectors who transport used oil are not marketers unless
they market the used oil directly to a person who burns it for
energy recovery.)
May Used Oil Be Used for Road Oiling?
Applying used oil to unpaved roadways for either dust control or
surface stabilization is considered unacceptable practice by some
state agencies. In those states, only used oil which has been re-
refined to remove or reduce contaminants may be used for these
purposes, provided it meets Federal and state department of
transportation specifications.
3.5.5 Other Recyclable Materials
The "recyclable materials" exempted from all Federal hazardous
waste regulations are:
• scrap metal,
• industrial ethyl alcohol that is reclaimed, and
• spent lead-acid batteries and used batteries (or used bat-
tery cells) that are reclaimed. (However, batteries bound for
disposal are subject to all hazardous waste management
regulations.)
CHMR
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3.6 Commonly Asked Questions About Hazardous
Waste and Compliance
3.6.1 Is My Waste Hazardous?
You may not be certain that your particular wastes are hazardous.
This determination can be made by pursuing the following steps
(see also Figure 3-1):
Step 1: Check to See if Your Waste Is Specifically Excluded
from the Definition of a RCRA Solid Waste or a
RCRA Hazardous Waste.
Your waste may not be regulated under RCRA. Certain specific
wastes such as fly ash waste, flue gas emission control waste,
certain spent sulfuric acid waste, cement kiln dust waste, and
drilling fluids are specifically excluded from the definition of a
RCRA solid waste or RCRA hazardous waste. A complete list of
such wastes which are specifically excluded under RCRA is
provided in Appendix 12.1.
Step 2: Check to See if Your Waste Is Included on U.S.
EPA's Specific Lists of Hazardous Wastes Found
in 40 CFR Part 261.
These lists are provided in Appendix 12.2 of this manual and
include:
• the F list of hazardous wastes from non-specific sources
(for example, spent halogenated solvents used in degreas-
ing such as trichloroethylene—40 CFR 261.31);
• the K list of hazardous wastes from specific sources (for
example, waste water treatment sludge from the production
of iron blue pigments—40 CFR 261.32);
• discarded Commercial Chemical Products or Manufactur-
ing Chemical Intermediates (CCP/MCI), off-specification
CCP/MCI, container or inner liner used to hold a CCP/MCI,
01989 HHCHMR
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3-10
or any residue resulting from the cleanup of a spill of a CCP/
MCI listed in either (40 CFR 261.33);
- the P list of acutely hazardous substances such as
nickel cyanide ortetraethyl lead; or
- the U list of toxic substances such as benzene or
mercury.
The P and U lists are intended primarily for large-scale producers
and users of chemical products. However, smaller operations may
also generate this type of waste if they use pure grade chemical
products. If your waste is a commercial chemical product (or a
manufacturing chemical intermediate) that appears on the P or U
lists, then it is a hazardous waste.
In a comment to this portion of the regulations (see 40 CFR 261.33
provided in Appendix 12.2), the U.S. EPA explains that the term
"commercial chemical product or manufacturing chemical interme-
diate" refers to a material which is the pure grade of the chemical
or all formulations in which the chemical "is the sole active ingredi-
ent." Some wastes, such as manufacturing process wastes,
merely contain some quantities of a chemical appearing on the P
or U list. If this is the case, check the F and K lists. If your waste
is described on these lists, then it is a hazardous waste. Otherwise,
check Steps 3 and 4 that follow.
STEP 3: Check to See if Your Waste Is Ignitable, Corrosive,
or Reactive
If you cannot find your waste described in the lists of hazardous
wastes given in Step 2, check the container labels and Material
Safety Data Sheets (MSDSs) for information on the nature of the
chemicals used in the waste. You can also contact the manufac-
turer or distributor who should have more details on the chemicals
contained in their products. Characteristics such as flash point,
reactions when mixed with other substances, explosive tempera-
ture, and disposal information can often be obtained from these
information sources. Use this information to determine whether or
©1989 •MCHMR
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3-11
not the waste meets the definition of corrosivity, ignitability, or
reactivity contained in the regulations and included in Appendix
12.3. If your waste does meet one of these characteristics, it is
hazardous. If you are still unsure that your waste meets one of
these characteristics, you can submit it to a testing laboratory for
this determination.
Step 4: Check to See if Your Waste Is EP Toxic
If you cannot find your waste in the lists, and it does not meet the
definition of either corrosivity, ignitability, or reactivity, you must
ensure that it is not toxic. Contaminants that make wastes toxic are
listed in the regulations (40 CFR 261.24) and are included in
Appendix 12.4. If your waste could contain one of these contamin-
ants, you will need the services of a testing laboratory to determine
the degree of toxicity of your wastes. Talk to your hauler, trade
association, state regulatory agency, disposal site owner, or other
businesses for names of reliable laboratories, or use the sources
of help listed in Chapter 11 of this manual. Your waste will be tested
according to accepted procedures, and you will be notified of the
toxicity of your wastes.
Figure 3-1 will help you determine if your waste is hazardous.
3.6.2 Are Any Hazardous Wastes Exempted from the
Hazardous Waste Management Requirements?
Federal and state regulations provide some specific exemptions
from the hazardous waste management requirements for certain
wastes. These exemptions can be very important because they
usually provide the flexibility necessary to encourage waste recy-
cling. Such exemptions may include:
• hazardous waste which is reclaimed,
• used oil,
• other recyclable materials such as lead-acid batteries, and
• hazardous waste treated in a "totally enclosed treatment fa-
cility," "elementary neutralization unit," or a "waste water
treatment unit."
@1989 IHCHMR
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YES
IS THE WASTE EXCLUDED FROM
THE RCRA DEFINITION OF
SOLID OR HAZARDOUS WASTES
NO
IS MY WASTE DESCRIBED IN ONE
OF THE FOLLOWING LISTS
- NON-SPECIFIC SOURCE "F"
- SPECIFIC SOURCE *K-
- ACUTELY TOXIC COMMERCIAL
PRODUCT"P"
- TOXIC COMMERCIAL PRODUCT "LI-
•>• YES
IS IT 1GNITABLE?
-> YES
NO
IS IT CORROSIVE?
NO
IS IT REACTIVE?
YES
I
YES
NO
IS IT EP-TOXIC?
YES
NO
NOT-HAZARDOUS WASTE
HAZARDOUS WASTE
Figure 3-1. Flow chart to determine if a
waste is hazardous
> 1989
CHMR
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3.6.3 How Do I Determine How Much Hazardous Waste I Generate?
To determine how much hazardous waste you generate (which is
used to determine your generator category), you must add the
weights of all the hazardous wastes your business generates in a
month. Appendix 1 2.6 summarizes the kinds of wastes you must
count to determine your generator status.
3.6.4 Should I Include Empty Containers?
Any hazardous waste remaining in an empty container is not
subject to regulation when the container is empty according to the
following definitions.
• A container which has held a liquid or a solid is empty if all
wastes have been removed that can be removed using the
practices commonly employed to remove materials from
that type of container — e.g., pouring, pumping, and aspirat-
ing — and no more than 1 inch of residue remains on the
bottom of the container.
• A container that has held a compressed gas is empty when
the pressure in the container approaches atmospheric.
• A container that has held waste identified as "acute hazard-
ous" waste (the P list — see Section 3.6.1 and Appendix
12.2) is empty when the container has been triple rinsed
using a solvent capable of removing that waste.
3.6.5 How Much Waste Must My Business Produce to Be
Regulated Under the New RCRA Requirements?
Key: 1 drum = about 200 kg = about 440 Ib = about 55 gal
According to the Federal regulations there are three categories of
hazardous waste generators.
• Generators of no more than 1 00 kg/mo— If you generate no
more than 1 00 kg (about 220 Ib or 25 gal) of hazardous
waste and no more than 1 kg (about 2 Ib) of acutely
1989
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3-14
hazardous waste in any calendar month, you are a "condi-
tionally exempt, small quantity generator" and the Federal
hazardous waste laws require you to:
- identify all hazardous waste you generate, and
- send this waste to a hazardous waste facility or a facility
approved by the state for industrial or municipal wastes.
100-1,000 kg/mo generators—If you generate more than
100 and less than 1,000 kg (between 220 and 2,200 Ib, or
about 25 to under 300 gal) of hazardous waste and no more
than 1 kg of acutely hazardous waste in any month, you are
a "non-exempt, small quantity generator" and the Federal
hazardous waste laws require you to:
- get a U.S. EPA I.D. number;
- comply with storage time, quantity, and handling re-
quirements;
- prepare for accidents and emergencies;
- ship your wastes using a licensed hauler after your
wastes have been properly prepared for shipping and
you have prepared a hazardous waste manifest, and
- ensure that your wastes are treated, stored, or disposed
of in a licensed hazardous waste management facility.
Generators of 1,000 kg/mo or more—If you generate 1,000
kg (about 2,200 Ib or 300 gal) or more of hazardous waste,
or more than 1 kg of acutely hazardous waste in any month,
you are a "large quantity generator" and the Federal regu-
lations require you to:
- comply with all applicable hazardous waste manage-
ment rules.
Less than
1 000 Kg/Mo
Hazardous Waste
1 Kg/Mo Acutely
Hazardous
Waste
V7
Less than
100 Kg/Mo
Hazardous Waste
1 Kg/Mo Acutely
Hazardous
Waste
i 1989
CHMR
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3.6.6 What Must I Do if I Am Regulated Under the
New RCRA Requirements?
If you have determined that you produce hazardous wastes, you
must:
• get a U.S. EPA I.D. number— an application form 8700-12
must be submitted to the U.S. EPA; and
• properly treat and/or dispose of your wastes on your prem-
ises only if you are permitted, licensed, or registered to
treat, store, or dispose of hazardous wastes (see Section
3.9.2);
or
periodically ship your wastes off your premises for treat-
ment or disposal. Effective September 22, 1986, small
quantity generators who send their wastes off site for
storage, treatment, or disposal must ensure that the hazard-
ous waste management facility has a RCRA permit or is
authorized under RCRA to manage hazardous waste. You
can determine this by contacting either your environmental
regulatory agency or by calling the CHMR Hotline at (800)
334-CHMR.
A concise summary of specific RCRA requirements for SQGs is
provided in Section 3.4.
3.6.7 Should I Notify EPA When I Revise Any of My
Hazardous Waste Management Activities?
Even though you may already have an EPA I.D. number, a revised
"Notification of Hazardous Waste Activity" form must be submitted
if:
• your generator category changes (e.g., from small quantity
generator to large quantity generator),
• you install hazardous waste recycling equipment or other-
wise begin to recycle hazardous waste on site (only required
by some states),
CHMR
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• you begin to market "off-specification used oil fuel" (see
Section 3.5.4), or
• you generate new or different hazardous wastes other than
those identified in the latest submittal.
3.7 Commonly Asked Questions About On-Site
Storage of Hazardous Wastes
3.7.1 May I Accumulate Hazardous Wastes at the Point of
Generation in "Satellite" Accumulation Areas?
You may accumulate as much as 55 gallons of hazardous waste
or 1 quart of acutely hazardous waste in containers at or near any
point of generation where wastes initially accumulate (referred to
as "satellite" accumulation areas) which is under the control of the
operator of the process generating the waste. You must use ap-
propriate containers as described in Section 3.8.4.
You must transfer the full containers from these "satellite" accumu-
lation areas to the central facility accumulation area within 3 days
after you have accumulated as much as 55 gallons of hazardous
waste or 1 quart of acutely hazardous waste.
The 180-day (or 270-day) accumulation time limits set forth in
Section 3.7.2 do not apply to wastes accumulated in such
"satellite" areas until these wastes are transferred to the central
facility accumulation area.
3.7.2 May I Store My Hazardous Wastes at My Facility
and for How Long?
According to the Federal regulations, you are allowed to accumu-
late and store hazardous wastes at a central facility accumulation/
storage area on your site subject to certain limitations. If you
exceed the following time or quantity limits, you will be considered
a storage facility and you must obtain a RCRA storage permit and
meet all of the RCRA storage requirements.
-------
3-77
JULY
JUNE
MAY
1
90 DAYS
Generators of No More than 100 kg/mo
There are no Federal time limits for storage of wastes as long as
you never accumulate 1,000 kg. If you accumulate 1,000 kg, you
will then be treated the same as the 100-1,000 kg group except that
the 180-day clock starts after you reach 1,000 kg. To avoid addi-
tional requirements, do not accumlate more than 1,000 kg on
site.
Generators of 100-1,000 kg/mo
You must remove your wastes within 180 days after you begin
accumulating wastes. The 180-day clock starts when the first
waste goes into storage in the central facility accumulation/storage
area. (See Section 3.7.1 for accumulation time allowances for
"satellite" accumulation areas.) You must never accumulate more
than 6,000 kg.
If you must transport wastes more than 200 miles, the 180-day
clock becomes a 270-day clock under Federal regulations. Also
under Federal regulations, you are allowed to petition for a 30-day
extension if conditions beyond your control force you to hold
wastes beyond the allowed time limits.
Generators of 1,000 kg/mo or More
You must properly ship, treat, or dispose of your wastes within 90
days after you begin accumulating the waste in storage. The 90-
day clock begins when the first waste goes into storage in the
central facility accumulation/storage area. (See Section 3.7.1 for
accumulation time allowances for "satellite" accumulation areas.)
However, the Federal regulations allow you to petition for an ex-
tension if circumstances beyond your control force you to store
wastes past the 90-day deadline.
3.7.3 How Should I Store Hazardous Wastes at My Facility?
As hazardous wastes can cause serious harm to humans and the
environment, extreme care must be exercised in their handling. Be
sure that any containers holding hazardous wastes:
© 1989
CHMR
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3-18
• are in good condition, hold the proper volume, and do not
leak;
• are compatible with the waste to be contained in them (i.e.,
will not react with the waste and will not be corroded by the
waste);
• are only opened to add or to remove waste and are stored
in such a manner as to avoid leakage;
• are washed completely before storage and do not contain
residue which may react with the waste;
• are kept separated from containers which hold other haz-
ardous wastes which could cause dangerous chemical re-
actions; and
• comply with the requirements in Section 3.8.4 for containers
used to accumulate wastes which are then used to ship
those wastes off site.
Storage areas should have these features:
• a base capable of containing leaks, spills, and accumulated
rainfall until these are detected and removed;
• methods to remove leaks from the storage area; and
• adequate containment capacity to hold a spill amounting to
the volume of the largest container, or 10 percent of the total
volume of all containers, whichever is greater.
In addition to the foregoing guidelines for storage containers and
design of storage areas, the following operational guidelines
should be followed.
• Mark each container with the date accumulation begins,
and label each container with the words, "Hazardous Waste."
© 1989 ••• CHMR
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• If wastes are being segregated, clearly mark each container
to identify the waste which is to be stored in that container.
• If waste oil is also accumulated on site, clearly mark the
waste oil accumulation tank and post a sign prohibiting
mixing of hazardous wastes in the waste oil.
• If possible, accumulation containers should be kept within a
locked area permitting access only by authorized personnel.
Wastes discarded in these containers should also be
recorded.
• Inspect the storage site weekly for leaks and container
deterioration.
• Containers which hold ignitable or reactive wastes must be
stored at least 50 feet from the property line of the facility.
• Prepare for and prevent accidents.
• Plan for emergencies.
3.7.4 How Should I Prevent Accidents and Plan for Emergencies?
Hazardous waste generators are required to ensure that the facility
takes the precautions necessary to prevent any accidental release
to the environment and provides procedures to respond to any
accidents or emergencies that may occur.
Contingency Plans and Emergency Procedures
As a minimum, the following contingency plans and emergency
procedures must be included.
• Designate someone as the primary Emergency Coordinator.
One or two back-up Coordinators should also be
designated. These individuals must be familiar with the
requirements and be on site (or on call) at all times.
1989 ••CHMR
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3-20
• Next to the telephone, post the:
- names and telephone numbers of the Emergency
Coordinators,
- location of fire extinguishers and spill control equipment,
and
- phone number of the fire department or instructions for
activating the emergency response communication or
alarm system.
• Ensure and document that all employees are trained and
thoroughly familiar with proper waste handling and emer-
gency procedures.
Facility Description
Each Contingency Plan should contain information regarding
preparedness, prevention, and contingency at each facility includ-
ing:
• a review of the types of hazards present;
• the exact locations of hazardous waste generating opera-
tions within the facility;
• the locations of hazardous waste storage areas;
• the methods of waste storage;
• any emergency equipment available at the facility and its
location;
• the locations of entrances, exits, stairways, elevators, etc.;
and
• an approximation of the number of employees on site during
regular work hours and non-business hours.
'1989 ••CHMR
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Emergency Coordinator Responsibilities
The Emergency Coordinator or his designee must respond to any
emergencies. The applicable responses follow.
• In the event of a fire, call the fire department and attempt to
extinguish it using a fire extinguisher.
• In the event of a spill, contain the flow of hazardous waste
to the extent possible. As soon as practicable, clean up the
hazardous waste and any contaminated materials or soil.
• In the event of a fire, explosion, or other release which could
threaten human health outside the facility or when the gen-
erator has knowledge that a spill has reached surface water,
the generator must immediately notify the National Response
Center using the 24-hourtoll free number (800) 424-8802. The
report to the National Response Center must include the:
- name, address, and U.S. EPA I.D. number of the gen-
erator;
- date, time, and type of incident (e.g., spill or fire);
- quantity and type of hazardous waste involved in the
incident;
- extent of injuries, if any; and
- estimated quantity and disposition of recovered mater-
ials, if any.
It is important to avoid potential risks in this area. If you have a
serious emergency and you must call your local fire department, or
you have a spill that extends outside your plant or that could reach
surface waters, immediately call the National Response Cen-
ter, (800) 424-8802, and give them the information they re-
quest. You will be advised if the call was not necessary. However,
anyone who is required to call—and does not—is subject to a
$10,000 fine, a year imprisonment, or both.
i1QQQ
1989 ^H CHMR
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3.7.5 Can I Store Hazardous Wastes in Underground
Storage Tanks (USTs)?
On July 14,1986, the U.S. EPA substantially revised the hazard-
ous waste management requirementsfortankscontaining hazard-
ous wastes (40 CFR Part 264, Subpart J -Tank Systems...see 51
FR 25470, July 14, 1986).
With a few exceptions, all UST systems containing hazardous
wastes must eventually be equipped with secondary containment.
These revised regulations also specify that all hazardous waste
tank systems without secondary containment must comply with the
following until such time as secondary containment is provided:
• Provide for controls to prevent spills.
• Provide overfill protection.
• Annually inspect cathodic protection system.
• Perform a tank integrity leak test annually.
In September 1988, the U.S. EPA published new regulations for
storage of hazardous substances (petroleum products and certain
hazardous commercial chemical products, not waste) in USTs.
The rule calls fortougher new requirements fortanks installed after
December 1988 and for a phased-in system of leak detection, leak
prevention, and corrosion protection for existing tanks based on
age.
For more information on the new UST regulations for storage of
hazardous substances see Chapter 4.0
3.8 Commonly Asked Questions About Packaging,
Labeling, and Shipping Wastes Off-Site
3.8.1 How Do I Ship Hazardous Wastes Off My Premises?
Under current Federal law, you should proceed as follows.
1989 t^m CHMR
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3-23
TRANSPORTER 1. Contact a company in the business of accepting hazardous
wastes for treatment or disposal. The company's facility must
be authorized by U.S. EPA or the state to manage hazardous
wastes. Be certain the facility knows the type of hazardous
wastes you have and is authorized to take them. Otherwise, the
wastes could be returned to you.
2. Contact a hauler to transport your hazardous wastes to the
treatment or disposal facility you have chosen. Be certain the
hauler knows the type of hazardous wastes you have and can
transport them safely—small quantity generators are required
to offer hazardous wastes to U.S. EPA-identified hazardous
waste haulers only. These haulers must meet certain require-
ments specified in the regulations.
In some states, haulers who operate within the state are
regulated by and are required to have a license from the state
regulatory agency.
You can request your hauler to document or otherwise provide
evidence that they have a U.S. EPA identification number, and
where applicable, a state license, and are operating within the
limits of the regulations.
3. Prepare your waste for shipment. Properly package and label
your wastes and prepare the manifest form (see following
sections).
4. Transport your hazardous wastes to a landfill orothertreatment
or disposal facility that is permitted, licensed, or registered by
the state or U.S. EPA to accept those kinds of wastes.
If you need assistance in finding a hauler, authorized landfill, or
commercial facility in your area, call the CHMR Hotline, (800) 334-
CHMR, or contact your state environmental regulatory agency, the
National Solid Waste Management Association, (202) 659-4613,
the Governmental Refuse Collection and Disposal Association at
(301) 585-2898, or your own trade association.
1989 HBCHMR
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3-24
Under RCRA, shipments of some hazardous wastes (primarily
used/dead automobile batteries) are exempted from most require-
ments if they are being sent to a recycling or reclamation establish-
ment (see Section 3.5.5.).
3.8.2 How Should I Label My Waste Containers
for Shipment Off-Site?
Federal and most state hazardous waste regulations include many
requirements for specific labeling of hazardous wastes which are
shipped off-site.
All containers used to store hazardous wastes or which may be
used to ship hazardous wastes off-site must exhibit the "Hazardous
Waste" label shown in Figure 3-2. All containers must be labeled
to show:
• accumulation start date,
• facility's EPA I.D. number,
• manifest document number (Section 3.8.5),
• proper DOT shipping name of the substance,
• UN (United Nations) or NA (North American) number
for the substance, and
• the EPA waste I.D. number for the substance.
All information must be completed with waterproof ink. All contain-
ers must also be labeled with the required DOT warning label (see
Figure 3-3) to indicate the nature of the contents, such as "flam-
mable" or "poison."
1989 mim CHMR
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3-25
ZZZZZZZZZZZZZZZZZZZZZZZZZ
HAZARDOUS
WASTE
FEDERAL LAW PROHIBITS IMPROPER DISPOSAL
IF FOUND, CONTACT THE NEAREST POLICE, OR
PUBLIC SAFETY AUTHORITY, OR THE
U.S. ENVIRONMENTAL PROTECTION AGENCY
PROPER D.O.T.
SHIPPING NAME_
_UN OR NA#_
GENERATOR INFORMATION:
NAME
ADDRESS
CITY
EPA
ID NO
ACCUMULATION
START DATE
STATE
EPA
WASTE NO
MANIFEST
DOCUMENT NO._
_ZIP_
HANDLE WITH CARE!
CONTAINS HAZARDOUS OR TOXIC WASTES
STYLE WM-t
zzzzzzzzzzzzzzzzzzzzzzzzz
Figure 3-2. Hazardous waste label.
©1989
CHMR
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Hazardous Materials Warning Labels
DOMESTIC LABELING
General Guidelines on Use of Labels
iCFR Tills 49 Transports!
• Labels illustrated above are normally for domestic •
shipments However some air carriers may require
the use of International Civil Aviation Organization
(ICAO) labels
• Domestic Warning Labels may display UN Class
Number Division Number (and Compatibility Group
for Explosives only ) Sec I72407{gj
' Any person who offers a t
transportation MUST label 'r
(Sec I72400(at|
izardous iiaienal for
i package il required
rts 100-177)
) when required must be pnnted on or affixed
to the surface of the package near the proper ship-
pmg name [Sec 172406(3)]
• When two or moie different labels are required
display them next to each other [Sec 172406(0]
• Labels may be affued to packages (even when not
required by regulations) provided each label
represents a hazard ol the material m the package
[Sec 1724011
• The Hazardous Materials Tables Sec 172101 and
172 102 identify the proper label(s) for rhe hazardous
snals listed
UN Class Numbers
Class 1—Explosives
Class 2—Gases (compressed liquified or
dissolved under pressure)
Class 3—Flammable liquids
Class 4—Flammable solids Of substances
Class 5—Oxidizing substances
Division 5 1 Oxidizing substances or
agents
Division 5 2 Organic peroxides
Class 6—Poisonous ai>d infectious substances
Class 7—Radioactive substances
Class 8—Corrosives
Class 9— Miscellaneous dangerous substances
INTERNATIONAL LABELING
EXAMPLES OF INTERNATIONAL LABELS
ail when used Internationally may be i
inguage of the country of origin
EXAMPLES OF EXPLOSIVE LABELS
• The NUMERICAL DESIGNATION represents the
CLASS or DIVISION
• ALPHABETICAL DESIGNATION represents the
COMPATIBILITY GROUP (for Explosives Only)
• DIVISION NUMBERS and COMPATIBILITY
GROUP combinations can result in over 30 dif-
ferent Explosives ' labels (see IMOG CooWfCAO)
• International Civil Aviation Organization (ICAOl Technical Insm.
lions lor the Safe Transport of Dangerous Goods by air [Air]
• International Maritime Organization (IMO) Dangerous Goods
Code (Water)
• 'Transportation of Dangerous Goods Regulations
ot Transport Canada [All Modes]
U S Department of Transpof tation
Research and Special Programs
Administration
Washington DC 20590
• 1989
ICHMR
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3.8.3 How Do I Determine the DOT Description?
The DOT description includes the proper shipping name, the
hazard class, and the United Nations (UN) or North American (NA)
identification number required for shipping hazardous materials
(including hazardous wastes). This information is found in the
Hazardous Materials Table of the Department of Transportation
regulations (49 CFR Section 172.101).
If you are not familiar with these requirements, you can obtain
information and assistance from the U.S. Department of Transpor-
tation (DOT) Materials Transport Bureau, your state transportation
department, your trade association or by calling the CHMR Haz-
ardous Materials Hotline, (800) 334-CHMR.
3.8.4 How Should I Package My Hazardous Wastes for
Shipment Off-Site?
Hazardous wastes must only be offered for transport in packages
that comply with DOT requirements for containers used to ship
hazardous wastes. The DOT requirements are designed to
prevent leaks or other releases of hazardous materials during
transport.
Typical Packaging Acceptable for Shipping
Most Hazardous Wastes
Typically, the following packaging is acceptable for most hazard-
ous wastes shipped from SQGs.
• Acid or caustic wastes. If the waste is an acid or a caustic,
the following DOT specification drums are acceptable:
- DOT Specification "34" polystyrene drums.
- DOT Specification "37P" steel drum with polyethylene
liners.
1989
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- DOT Specification "6D" or 37M" non-reusable cylindrical
steel overpacks with inside DOT Specification "2S,"
"2SL," or "2U" polyethylene packaging.
- DOT Specification "21P" fiber drum overpack with inside
DOT Specification "2S," "2SL," or "2U" polyethylene
packaging.
• Flammable and other wastes. If the waste is not an acid or
a caustic, usually a 55-gallon steel drum meeting DOT
Specifications "5," "5A," "5B," "5C," "17C," or "17E" is
acceptable. For liquid wastes, use a non-removable head
drum with a maximum 2.3-inch opening.
For any hazardous wastes requiring packaging to meet DOT
specifications other than those listed above, you should contact
your state's Department of Transportation or the CHMR Hazard-
ous Materials Hotline—(800) 334-CHMR.
Containers that are designed by the manufacturer to meet DOT
specifications are marked with the applicable specification num-
ber. For example, you may see the specification "17E" stamped on
certain 55-gallon drums. In determining whether a container is
marked according to DOT specifications, you may accept the
manufacturer's certification, specification, or exemption marking.
Packaging Small Items for Shipment Off-Site (Lab Packs)
Drums which have been filled with "small items" are commonly
referred to by the hazardous waste disposal industry as "lab
packs." A few hazardous waste management contractors will
handle lab packs for processing and disposal which would elimi-
nate the need for SQGs to open, empty, and accumulate the
contents of such "small items" in segregated containers on site.
The specific packaging, handling, and disposal approaches vary
depending on the contractor. Some contractors require that the
contractor personnel actually come onto your site to package the
small items into lab packs for shipment. Disposal options range
© 1989 •• CHMR
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3-29
from facilities which incinerate or bury the entire lab pack, to facili-
ties which "depackage" the lab pack and further process its
contents.
In general, lab packs must be packaged as follows:
• Outside packaging must be a DOT specification "removable
head" metal or fiber drum.
• Each outside packaging may only contain one hazard class
(e.g., ignitable or corrosive), and the drum construction
materials must be chemically compatible with the materials
being packaged.
• Inside packaging must be either glass packaging not ex-
ceeding 1 gallon or metal or plastic packaging not exceed-
ing 5 gallons.
• Inside packaging of liquid must be surrounded by compat-
ible absorbent material capable of absorbing the total liquid
contents.
The specific packaging requirements for your lab packs should be
reviewed with your lab pack disposal contractor.
Reuse of Containers
Generally, the regulations authorize one-time use of the product
container for shipping the waste. Reuse of containers (e.g., drums
used to ship products—such as solvents or lubricating oils, which
have been emptied of those raw materials, and which are now
available to be used for accumulating and shipping wastes) is
allowed so long as the containers are:
• acceptable DOT specification drums for the waste to be
shipped;
• in good condition and free of rust, damage, or leaks;
• do not contain any incompatible residues; and
1989
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• do not carry any old marking labels that incorrectly
identify the contents.
While it may be convenient to reuse containers, you should be very
careful to avoid putting materials in a container that may react in
undesirable or unknown ways with the material that was previously
in the container. Reuse of containers that have not been thor-
oughly cleaned can result in combining incompatible wastes to
produce toxic vapors or explosions as well as waste mixtures that
are even more dangerous than the individual substances.
3.8.5 What Is a Hazardous Waste Manifest?
The hazardous waste manifest form must be completed before
transporting hazardous waste off-site. This form becomes a
written record of the disposal of your hazardous waste. For
treatment, storage, or disposal within a state, the state's manifest
form must be used. For shipments outside the state, the receiving
state's form or the U.S. EPA Uniform Hazardous Waste Manifest
must be used.
Small quantity generators (SQGs) are now required to fully com-
plete the manifest and keep a file of manifest copies that are signed
and returned to the SQG by the storage, treatment, or disposal
facility. These copies must be kept on file for 3 years.
Contact your state environmental regulatory agency or your Re-
gional U.S. EPA office for additional copies of the manifest. You
may also purchase copies of the manifest from some commercial
printers, orobtain copies from some treatment, storage, ordisposal
facilities.
How to Complete a U.S. EPA Manifest Form
Sections of the U.S. EPA Uniform Hazardous Waste Manifest form
(see Figures 3-4 and 3-5) that must be completed include the
following.
CHMR
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Item 1 — EPA Identification Number. Enter your EPA I.D.
number in the space provided (see Figure 3-4).
Item 1 also asks for a five-digit manifest document number.
You should use a consecutive numbering system in which
the first shipment from the facility in 1989, for example, is
assigned the manifest document number "89001," the second
shipment is assigned the number "89002," etc.
Item 2 — Page 1 of . Indicate the total number of original
pages (not carbon copies) you are using. For example, the
first page (EPA Form 8700-22) plus the number of Continu-
ation Sheets (EPA Form 8700-22A, see Figure 3-5) if any.
Items 3 and 4 — Generator's Name and Mailing Address.
Enter the name, mailing address, and telephone number of
the generator. The address should be the location that will
manage the returned manifest forms.
Items 5 through 8 — Transporters' Names and U.S. EPA
I.D. Numbers. Enter the name and U.S. EPA I.D. number
of the transporter in Items 5 and 6. If the waste will be
transferred to a second transporter during shipment, the
same information for the second transporter must be pro-
vided in Items 7 and 8. If more than two transporters are
used, enter each additional transporter's company name
and U.S. EPA I.D. number in Items 24-27 on the Continu-
ation Sheets (EPA Form 8700-22A, see Figure 3-5). Each
continuation sheet has space to record two additional trans-
porters.
Items 9 and 10 — Designated Facility Name and Ad-
dress. Enter the company name, address, and U.S. EPA
I.D. number of the facility designated to receive the waste
listed on the manifest. The address must be the site
address, which may differ from the facility's mailing address.
1989 1MCHMR
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Item 11 — Department of Transportation (DOT) Descrip-
tion of the Waste, Including the Shipping Name, Hazard
Classification, and Identification Number. Enter (1) the
proper DOT shipping name of the substance, (2) the DOT
hazard class, and (3) the UN or NA identification number for
the substance (see Section 3.8.3.).
Note: If additional space is needed for waste descriptions,
enter these additional descriptions in Item 28 on EPA Form
8700-22A (see Figure 3-5).
Item 12 — Number and Type of Containers. Enter the
number of containers for each waste and the appropriate
abbreviation for the type of container:
DM = Metal drums, barrels, kegs
DF = Fiberboard or plastic drums, barrels, kegs
DW = Wooden drums, barrels, kegs
TP = Portable tanks
TT = Cargo tanks (tank trucks)
TC = Tank cars
DT = Dump trucks
CM = Metal boxes, cartons, cases
CF = Fiberboard or plastic boxes, cartons, cases
CW = Wooden boxes, cartons, cases
CY = Cylinders
BA = Burlap, cloth, paper, or plastic bags
Items 13 and 14 — Quantity of Waste Being Transported.
Enter the total quantity and unit of measurement (gallons,
pounds, or cubic feet) of waste described on each line.
Enter the appropriate abbreviation:
G = Gallons (liquids only)
P = Pounds
T = Tons (2,000 Ib )
Y = Cubic yards
L = Liters (liquids only)
K = Kilograms
M = Metric tons (1,000 kg)
N = Cubic meters
'1989 •••CHMR
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• Item I — U.S. EPA Hazardous Waste I.D. Number. You
must enter the U.S. EPA Hazardous Waste I.D. number for
each waste listed under Item 11.
• Item 16 —Generator's Certification. The authorized
representative of the SQG is required to sign the manifest.
If a transportation mode other than highway is used, the word
"highway" should be lined out and the appropriate mode (rail,
water.or air) inserted in the space below. If another mode in
3.8.6 addition to the highway mode is used, enter the appropriate
additional mode (e.g., rail) in the space below.
Are There Any Exemptions to the Manifesting Requirement?
In some cases, spent materials can be regenerated, recycled, or
reclaimed for reuse (e.g., lead acid batteries, solvents). SQGs are
not required to prepare a manifest when using the service of a
reclaimer provided:
• the waste is being reclaimed under a contract,
• the contract specifies that either the SQG or the reclaimer
retain ownership of the material,
• the type of waste and frequency of service are specified,
• the service owns the vehicle used to transport the waste
and regenerated material, and
• the SQG keeps a copy of its contract with the reclaiming
service for at least 5 years after the contract terminates or
expires.
3.8.7 What Should I Do if the Signed Manifest Is Not Returned to Me
by the Designated Facility?
If you do not receive a signed copy from the designated waste
facility within 35 days, you must determine why by contacting either
the transporter or destination facility.
1989 HHCHMR
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Please print or type (Form designed tot use on eliie (1?-P'ich) typewrite')
Fomi Approved OMB No 2050-0039 Expire t, 9 JO 38
U UNIFORM HAZARDOUS 1 Genera(0's us EPA ID No Man-fest DOC^-I-NO
WASTE MANIFEST I
3 Generator's Name ana Mailing Address
4 Generator's Phone { )
5 Transporter 1 Company Name 6 US EPA ID Numse-
I
7 Iran
poner 2 Company Name B US EPA ID N^mLie-
1
9 Designated Faci!it> Name and Site Adoress 10 US EPA ID N^-icf
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No
J. Additional Descriptions for Materials Listed Above
2 Page 1 Informauon m tie shaded areas
. is not required by Federal law
A State Manifest Document Number
B State Generators ID
C State Transporter's ID
D Transporter's Phone
E State Transporter's ID
F Transporter's Phone
G State Facility's ID
H Facility s Phone
ner$ 13 ,4 1
To'.a' Jin Waste No
Type Quail -y wi vo'
i
1
K Handling Codes for Wastes Listed Above
15 Special Handling Instructions and Additional Information
proper shipping name and are classified packed markea and labeled and are ir al' respects m proper condition tor transpon b> high*a>
Printed/Typed Name Signature Month Day Year
1r 1 1
17 Trar
sporter 1 Acknowledgement ol Receipt of Materials
Printed/Typed Name Signature Month Day Year
I I
18 Trar
spoler 2 Acknowledgement ol Receipt o( Materials
Pnnted/Tvped Name Sionature Month Day year
I I I
19 Discrepancy Indication Space
20 Fac
ity Owner or Operator Cert lication of receipt of hazardous materials covered bv this manifes except as noted in Item 19
Printed/Typed Name Signature Monrfi Day Yea'
I I I
EPA Form 8700 22 iRev 9 86) Previous editions a-e obsoieie
Figure 3-4. U.S. EPA Uniform Hazardous Manifest form.
) 1989
CHMR
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GENERATOR STANDARDS
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(Appindn. Form I7M-5JAJ
Figure 3-5. U.S. EPA Uniform Hazardous Manifest form
(page 2).
) 1989
CHMR
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Remember that just because the hazardous waste has been
shipped off-site and it is no longer in your possession, your liability
has not ended. You are potentially liable under Superfund for any
mismanagement of your hazardous waste. The manifest will help
you to track the waste during shipment and be certain it arrives at
the proper destination.
3.9 Commonly Asked Questions About Recordkeeping
and Other Management Requirements
3.9.1 What Are My Recordkeeping and Reporting Requirements?
The Federal regulations set forth specific recordkeeping and
reporting requirements associated with managing your hazardous
waste.
Recordkeeping
Maintaining records of how you handle the hazardous waste
generated from your business is a very important part of achieving
compliance. Good recordkeeping is helpful to avoid problems with
the regulatory agencies and to minimize future cleanup liabilities.
SQGs who are judged out of compliance may spend a lot of time
and money dealing with enforcement actions and paying fines—
which may also result in bad publicity. The best way to prevent this
from happening is by making an honest effort to maintain compli-
ance with the regulations and to keep records that are sufficient to
prove to agency officials that you are operating in compliance.
When agency enforcement personnel conduct inspections, one of
the first things they will ask to see is your "hazardous waste file."
This is because documents such as acknowledgment copies of
hazardous waste shipping manifests provide strong indications of
your efforts to comply.
CHMR
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If you do not have such a file, or if your papers are unorganized, the
inspector will immediately receive a bad impression of your opera-
tion and be suspicious about how carefully you are handling your
responsibilities. It is also very difficult for you to monitor your own
compliance without a good record of the on-going operations.
Good recordkeeping cannot be overemphasized. The following
minimum recordkeeping is required by most regulations.
• Keep records of any test results, waste analyses, or other
determinations made to identify if wastes generated from
your facilities are hazardous.
• Prepare a monthly summary of wastes generated which
substantiates your generator category. This summary should
indicate the final disposition of the wastes, particularly
those not manifested (i.e., hazardous wastes discharged to
a Publicly Owned Treatment Work (POTW), reclaimed on site,
or reclaimed through a contract with an off-site reclaimer).
• Keep on-site waste accumulation records, including the
date accumulation began and the quantity accumulated to
date.
• Record "in-house" facility inspections, including deficien-
cies noted and when such deficiencies were resolved.
• Keep records of employee training.
• Keep on file the generator's copy of the manifest and the
copies returned from the destination facility.
• Maintain copies of contracts with reclaiming services.
Reporting
Small quantity generators are exempted from all Federal and state
reporting requirements except those "Spill and Leak" reporting
requirements described in Section 3.7.4.
• CHMR
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3-38
3.9.2 May I Treat or Dispose of My Wastes at My Facility Rather than
Ship Them Off-Site?
You may treat or dispose of your hazardous wastes at your own
plant only if you are permitted or registered to treat or dispose of
hazardous wastes, with a few exceptions.
You are exempt from the permitting requirements if you:
• legitimately use, recycle, or reclaim your hazardous wastes
(see Section 3.5) (However, you are still subject to the
regulatory notification and reporting requirements);
• neutralize corrosive hazardous wastes in an "elementary
neutralization unit" such as a tank, container, or transport
vehicle—not a surface impoundment;
• treat hazardous wastes in a "totally enclosed treatment
facility"—which is defined as a facility for the treatment of
hazardous waste which is directly connected to an industrial
production process and which is constructed and operated
in a manner which prevents the release of any hazardous
constituent into the environment during treatment; and
• treat hazardous wastes in a National Pollution Charge Elimina-
tion System (NPDES)-regulated "waste water treatment
unit"—some states have special requirements for waste
water treatment units treating hazardous wastes, and some re
siduals generated by these units may be hazardous.
If you already are treating or disposing of your wastes at your
facility, then you should contact your state environmental regula-
tory agency or call the CHMR Hotline at (800) 334-CHMR to
determine if additional requirements have been issued recently to
be sure you are still permitted, licensed, or registered to manage
your hazardous wastes at your facility.
'1989 •MCHMR
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3.9.3 What Should I Do if I Have Determined that My Wastes Are
Non-Hazardous?
Because you have determined that your wastes are not defined by
U.S. EPA as a "Hazardous Waste," does not mean that your waste
does not contain some hazardous chemicals orthat your wastes do
not have the potential to cause harm to human health or the
environment if improperly treated, stored, or disposed.
You should still take steps to ensure that you are complying with all
applicable Federal and state requirements for disposal of non-
hazardous wastes, and you should make all reasonable efforts to
ensure that your non-hazardous wastes are handled in a way that
prevents uncontrolled release to the environment and the potential
future liabilities associated with such release.
3.10 Where to Call for Additional Assistance
For more information and assistance in complying with the RCRA
regulations, you can call CHMR's toll-free Hazardous Materials
Hotline at (800) 334-CHMR or the regional office of your state
environmental regulatory agency. See Chapter 11 of this manual
for more information and telephone numbers of these and other
helpful organizations.
1989 HCHMR
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3.11 RCRA Regulations for SQGs in Pennsylvania
State regulatory requirements must be at least as stringent as
Federal requirements (exceptions sometimes occur when a Fed-
eral regulation was recently changed and made more stringent and
the state regulation has not yet been revised to keep up with the
Federal standards). You must comply with the most stringent
requirements whether they are Federal or state.
Pennsylvania is currently considering whether to adopt the U.S.
EPA regulations for small quantity generators (SQGs). In the
meantime, the U.S. EPA regulations are more stringent and should
be followed—with the important exception of the requirements de-
scribed in the following sections.
Table 3-2 provides a brief summary of the regulatory requirements
for SQGs in Pennsylvania.
3.11.1 RCRA Regulatory Requirements for Conditionally Exempt
SQGs in Pennsylvania
According to the Federal regulations, conditionally exempt SQGs
(generators of no more than 100 kg/mo) must sendtheirhazardous
waste to a hazardous waste facility, or to a facility approved by the
State for industrial or municipal wastes (see Section 3.6.5).
However, facilities in Pennsylvania approved by the Pennsylvania
Department of Environmental Resources (PA DER) for industrial or
municipal wastes (e.g., sanitary or residual waste landfills) are not
approved to receive any hazardous wastes. Therefore condition-
ally exempt SQGs in Pennsylvania must ship their wastes to a
hazardous waste management facility in Pennsylvania (with an
EPA I.D. number) or to an out-of-state hazardous, industrial, or
municipal waste facility approved to receive hazardous wastes.
Also, most commercial hazardous waste transporters and treat-
ment, storage, or disposal facilities in Pennsylvania will not accept
any hazardous wastes without an accompanying manifest. There-
fore, as a practical matter, "conditionally exempt, small quantity
generators" in Pennsylvania should get a U.S. EPA I.D. number
and accompany their hazardous waste shipments with a manifest.
©1989 •MCHMR
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3-42
Table 3-2. RCRA regulatory requirements
for small quantity generators in Pennsylvania
Requirement
Determine quantity of
hazardous waste generated
Obtain EPA I.D. number
Observe accumulation time
time orquantitiy limits
Observe storage facility
criteria
Prepare/plan for
accidents/emergencies
Properly label and package
shipments
Ship wastes with a manifest
Use a licensed transporter
Ship to an approved
treatment storage
or disposal facility
Keep records
Produce
less than
100 kg/mo
Required
Required
Required
Required
Produce
100-1,000 kg/mo
Required
Required
Required
Required
Required
Required
Required
Required
Required
Required
* Not required by regulation but in practice necessary for most
businesses in Pennsylvania (see Section 3.11.1)
) 1989
CHMR
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3.11.2 On-Site Storage Time and Quantity Limitations in
Pennsylvania
According to both Federal and Pennsylvania regulations, you are
allowed to accumulate hazardous wastes on your site subject to
certain limitations. The Federal regulations were recently amended,
which has made the Federal regulations more stringent in some
cases and the state regulations more stringent in others. However,
in all cases, comply with the most stringent of the two regulations.
Currently, the following limitations apply to hazardous waste gen-
erators in Pennsylvania. If you exceed these time orquantity limits,
you will be considered a storage facility and you must obtain a
RCRA storage permit and meet all of the RCRA storage require-
ments.
Generators of 1,000 kg/mo or more
Both the Pennsylvania and Federal requirements are the same for
generators of 1,000 kg/mo or more. You must properly dispose of
your wastes within 90 days after you begin accumulating the waste
in storage. The 90-day clock begins when the first waste goes into
the storage container (except at "satellite" accumulation areas—
see Section 3.7.1) under both Federal and Pennsylvania regula-
tions. However, the Federal regulations allow you to petition for an
extension if circumstances beyond your control force you to store
wastes past the 90-day deadline.
Generators of 100-1,000 kg/mo
Pennsylvania 100-1,000 kg/mo generators must remove their
requirements wastes within 90 days after they accumulate
1,000 kg. The 90-day clock starts after you
reach 1,000 kg.
Federal You must remove your wastes within 180 days
requirements after you begin accumulating wastes. The
180-day clock starts when the first waste goes in
the storage container (except at "satellite" accu-
®1989 ••CHMR
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3-44
mulation areas—see Section 3.7.1). You must
never accumulate more than 6,000 kg.
If you must transport wastes more than 200
miles, the 180-day clock becomes a 270-day
clock under Federal regulations. Also under
Federal regulations, you are allowed to petition
for a 30-day extension if conditions beyond your
control force you to hold wastes beyond the
allowed limits.
Therefore Whether the Pennsylvnia or Federal regulation
is more stringent depends on whether you
accumulate 1,000 kg before or after 90 days
(180 days if you must ship more than 200 miles)
from the time the first waste goes into the
storage container.
The Pennsylvania regulation is more stringent if
you accumulate 1,000 kg in less than 90 days.
For example, suppose it takes you 80 days to
accumulate 1,000 kg from the day the first waste
goes into storage. Pennsylvania requires you to
remove the waste within 80 plus 90, or 170 days,
which is less than the Federal allowance of
180 days.
The Federal regulation is more stringent if it
takes you more than 90 days to accumulate
1,000kg. Forexample,supposeittakesyou 100
days to accumulate 1,000 kg from the day the
first waste goes into storage. Pennsylvania re
quires you to get rid of the waste within 100 plus
90, or 190 days, which is more than the Federal
allowance of 180 days.
CHMR
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3-45
Generators Of No More Than 100 kg/mo
Pennsylvania
requirements
Federal
requirements
Therefore
Generators of no more than 100 kg/mo are
treated the same as 100-1,000 kg/mo genera-
tors. You must remove your wastes within 90
days after you accumulate 1,000 kg. The
90-day clock starts when you reach 1,000 kg.
There are no Federal time limits for storage
of wastes as long as you never accumulate
1,000 kg. If you accumulate 1,000 kg, you will
then be treated the same as the 100-1,000 kg
group except that the 180-day clock starts after
you reach 1,000 kg.
As long as you never accumulate 1,000 kg, you
are not subject to any time clock under either
Pennsylvania or Federal regulations. It is, there
fore, strongly recommended that generators in
this category remove their wastes before they
accumulate 1,000 kg.
If you accumulate 1,000 kg, the PA DER time
clock is more stringent, and you must now re-
move your wastes within 90 days. However, you
will also be subject to all of U.S. EPA's various
requirements for the 100-1,000 kg generator
category.
3.11.3 Additional Requirements for The PA DER Manifest Form
In addition to those items discussed in Section 3.8.5, facilities using
the PA DER Uniform Hazardous Waste Manifest form (see Figure
3-3) must also complete the following sections.
• Item J — Physical State and Hazard Code. Enter the
physical state of each waste and the hazard code or codes
that correspond to the hazardous waste number:
© 1989
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3-46
Physical state Hazard code
S = solid I = ignitable
L = liquid C = corrosive
SL = sludge R = reactive
G = gas E = EP toxic
H = acute hazardous
T = toxic
• Item K — Handling Codes. Handling codes for wastes are
not required for Pennsylvania generators but may be re-
quired for some interstate shipments. You should use the
U.S. EPA Uniform Manifest Form or the receiving state's
manifest for interstate shipments, and you can omit Item K
unless it is required by the receiving state.
3.11.4 Pennsylvania "Permit by Rule"
In Pennsylvania, the owner or operator of an elementary neutrali-
zation unit or a waste water treatment orpretreatment facility may
be eligible for a Hazardous Waste Management "Permit by Rule"
if all of the following criteria are met:
• The facility is located upon lands owned by the hazardous
waste generator and the only waste treated is generated on
site.
• It is not a surface impoundment.
• It has an NPDES permit, if required, and complies with the
conditions of that permit.
or
It is a pretreatment facility and it discharges into a permitted
Publicly Owned Treatment Work (POTW).
1989 ••CHMR
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It complies with various requirements of hazardous waste
treatment, storage, and disposal facilities such as: I.D.
number; security; inspection; preparedness, prevention,
and contingency procedures; operating record; and design
requirements for hazardous waste chemical, biological, or
physical treatment units.
The owner of such facilities has notified the agency of the
on-site hazardous waste treatment activities.
The regulations essentially say that all such facilities which are
operated in accordance with the requirements listed above auto-
matically have a hazardous waste management permit from the
agency—otherwise known as a "permit by rule"—and a separate
application is not required.
1989 •• CHMR
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3-48
PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES
Bureau of Waste Management
P O Box 6550
Harnsburg PA 17105-8550
OMB No 7050-003*
Elplrri 9 30.91
A
G
E
N
E
R
A
T
0
R
I
••
UNIFORM HAZARDOUS 1 Generator* US EPA ID No ooSESfio
WASTE MANIFEST | |
3 Generator* Name and Mailing Address
4 Generator * Phone ( )
5 Transporter. 1 Company Name t US EPA ID Numbei
7 Transporter 2 Company Name B US EPA ID Number
1
1 ' 1
12 Conlai
P I g P PP g NO
ti
J Additional Description! tor Malenals Listed Above (include physical stale and hazard code)
Lab Pack Physical Slate Lab Pack Phywcal Slat*
. U 1 1 « U 1 1
b U 1 1 - U 1 1
2 Page 1 Information in the thMted areas
ol t* not required by Federal law
but it required by Stale law
A Slate Manltmt Document Number
PAC 1208782
B. Sale Gen. ID
C. SUU Tram ID
PA-AH | |
D. Transporter** Phone ( )
E Slate Tram ID
PA-AH | |
F. Transporter's Phone ( )
G. State Faculty's ID
H. Facility's Phone ( )
'"„, 0:±,, !& ""i"°
I i
i i
1
i i
K Handling Codes for Wastes Listed Above
a c.
b 4
15 Special Handling Instructions and Additional Information
, . ,-,„„,,„•, „-,„,, •„.,; n,. ,».,, ,,„„,„.,.,„,.,«,„, ,-„ ..™™ ,„, ,„.,.,„„. ...I, „.,.,,,,. ,c „ r.o-, ,..„ ,n,..^..,-,c »„,,-.
Printed Typed Name Signature MOUTH DA'T ite,K
\ I 1
Punted TypeO Name Signature MONTH DA* *tAt)
Printed Typed Name Signatme MONTH DAY YEAK
1 1 1
19 Discrepancy Indication Space
20 facility Owner or Operator Certification of receipt of hazardous material* covered by this mamlesl except •$ noted in Mem 19
I I I
EPA Form 8700-22 (Rev 9 B8>
Figure 3-6. Pennsylvania Hazardous Waste Manifest form
)1989
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CHAPTER
4.0 LAND DISPOSAL, SARA TITLE III, AND
UNDERGROUND STORAGE TANKS
4.1 Land Disposal Bans
In 1984, Congress enacted the Hazardous and Solid Waste
Amendments (HSWA) to the Resource Conservation and Recov-
ery Act (RCRA) restricting land disposal of hazardous waste unless
properly containerized or treated. The act schedules a phased-in
"land disposal ban" on hazardous waste pending establishment of
specific treatment standards for the identified waste by 1990.
Wastes subject to the land disposal ban fall into three target
groups:
1. Hazardous wastes containing solvents and dioxin.
2. RCRA-listed California-List wastes:
• Liquid forms of hazardous wastes that contain specific
metals, free cyanides, or PCBs
• Liquid acid wastes, equal to or below pH 2
• Hazardous wastes that contain halogenated organics
3. 450 RCRA-listed hazardous wastes:
• first-third
• second-third
• final-third
These regulations affect all land-based disposal including landfills,
surface impoundments, waste piles, injection wells, underground
mines or caves, and concrete vaults or bunkers.
4.1.1 Hazardous Wastes Containing Solvents and Dioxin
The first phase prohibiting the disposal of specific types of waste
was adopted in 1986. It banned the disposal of a select group of
wastes containing spent solvents (U.S. EPA Hazardous Waste
Numbers F001, F002, F003, F004, and F005) and dioxin (F020,
F021, F026, F027, and F028). Refer to Appendix 12.2 for further
1989 HBCHMR
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information concerning the F series of EPA hazardous wastes.
In order to dispose of the indicated wastes, U.S. EPA has estab-
lished certain concentration requirements for disposal and has
designated the best demonstrated available technologies (BDATs)
to meet the requirements.
Wastes containing solvents must meet the following concen-
tration requirements.
• Waste water containing solvents may contain between 0.05
and 12.7 milligrams per liter depending on the specific
solvent.
• Wastes (not waste water) containing solvents may contain
between 0.05 and 5.0 milligrams per liter depending on the
specific solvent.
If the waste exceeds any of these concentrations, then it must be
treated before disposal on land. The BDATs for solvent treatment
before disposal are:
• incineration,
• biological treatment,
• steam stripping, or
• activated carbon adsorption.
U.S. EPA has mandated the following requirements for land
disposal of wastes containing dioxin.
• Wastes which contain dioxin must contain less than one part
per billion of the dioxin.
• The BOAT for dioxin treatment is incineration.
1989 MM CHMR
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4.1 .2 RCRA-Listed California-List Wastes
The second phase prohibiting the disposal of "California-list"
wastes was adopted in 1 987. It banned the disposal of a select
group of wastes containing cyanides, certain metals, halogenated
organic compounds, PCBs, and low-pH wastes.
For disposal on land, wastes must meet the following require-
ments.
• Free cyanide concentrations in liquid hazardous wastes
cannot exceed 1 ,000 mg/l (milligrams per liter).
• Liquid hazardous wastes containing elemental metals or
metal compounds cannot exceed the following concentra-
tions:
- Arsenic and arsenicals, 500 mg/l
- Cadmium and its compounds, 100 mg/l
- Chromium VI and its compounds, 500 mg/l
- Lead and its compounds, 500 mg/l
- Mercury and its compounds, 20 mg/l
- Nickel and its compounds, 134 mg/l
- Selenium and its compounds, 100 mg/l
- Thallium and its compounds, 130 mg/l
• Liquid waste must have a pH greater than 2.0.
• PCB concentrations in liquid hazardous wastes cannot
exceed 50 ppm.
• The concentration of halogenated organic compounds
(HOCs) cannot exceed 1 ,000 mg/kg.
U.S. EPA has determined that incineration is the appropriate
treatment standard for the category of wastes classified as HOC-
and PCB-contaminated wastes. No required treatment standards
for the remaining California-list wastes have been established;
however, applicable technologies generally capable of meeting the
statutory prohibition levels are discussed in the final rule.
1989
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4-4
4.1.3 450 RCRA-Listed Hazardous Wastes
The remaining phase of land disposal bans restricts the disposal of
all 450 RCRA-listed hazardous wastes (see Appendix 12.2 for
RCRA-listed waste streams). The rule is being implemented in
thirds, and the ban on the first-third was established in August
1988.
To date, treatment standards have been established for 39 hazard-
ous waste streams; however, treatment standards for 14 other
hazardous waste streams covered underthe first-third rule remain
to be established. Also, 107 P list and U list wastes (small volume
discarded commercial chemical products and spill residues, re-
spectively—see Appendix 12.2) identified in the first-third rule do
not have treatment standards established. Treatment is required,
however, if the technology is available.
For wastes and waste streams where no treatment standards have
been established, landfilling is still a disposal option as long as
state-of-the-art landfills are used. Where no treatment standards
have been established, a "soft-hammer" clause in the rule auto-
matically requires land disposal bans for all first-third listed wastes
by 1990.
The remaining two-thirds of RCRA-listed hazardous wastes are to
have treatment standards and final rules established in 1989
(second-third) and 1990 (final-third), with complete implementa-
tion of the disposal ban by 1992.
Generators of any amount of hazardous waste are being forced to
examine waste management alternatives to land disposal. Now is
the time to minimize, reuse, or recycle wastes or to use non-
hazardous substitution chemicals in your process. Land disposal
bans will only become more restrictive and costly for businesses,
so conscientious decisions must be made and implemented to
reduce hazardous waste generation.
' 1989 •• CHMR
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4-5
4.2 SARA Title III
On October 17, 1986, the Superfund Amendments and Reau-
thorization Act (SARA) was signed into law. Title III of SARA is also
known as the Emergency Planning and Community Right-to-Know
Act (EPCRA). Asthe name implies, EPCRAhastwo majorthemes:
emergency planning and community right-to-know. This section
discusses the various aspects of compliance with Title III of SARA,
details major sections of SARA, and discusses what facilities are
subject to the various requirements. A list of key deadlines is also
provided.
4.2.1 Background
Many small businesses may be subject to provisions of SARA Title
III based on the types and amounts of chemicals present on-site.
This Federal legislation, prompted by the Bhopal incident in 1984,
requires (1) industry to provide information concerning hazardous
substances used, and (2) local governments and communities to
plan for hazardous materials emergencies.
Title III establishes requirements for Federal, state, and local
governments, and industry for emergency planning and commu-
nity right-to-know reporting on hazardous chemicals. The program
is designed to help protect communities from potential chemical
emergencies.
4.2.2 Emergency Planning and Notification, Community Right-to-
Know, and Toxic Chemical Release Reporting
Title III has four major parts: emergency planning, emergency
notification, community right-to-know, and toxic chemical release
reporting.
Emergency Planning (Sections 301, 302, and 303)
The emergency planning sections are designed to develop govern-
ment emergency preparedness capabilities through increased
coordination and planning on the state and local level.
1989
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4-6
Section 301 establishes two planning levels within each state—a
state emergency response commission (SERC) and local emer-
gency planning districts governed by a local emergency planning
committee (LEPC).
Facilities which are subject to emergency planning requirements
under Section 302 include those with listed extremely hazardous
chemicals on-site in a quantity equal to or greater than the
established threshold planning quantity (TPQ). These facilities are
to notify the SE RC and LEPC that they are subject to the provisions
of EPCRA.
Section 303 also requires local emergency planning commissions
to submit emergency response plans to the SERC. The plan must
include identification of facilities and transportation routes for ex-
tremely hazardous substances, emergency response procedures,
community and facility coordinators, emergency notification proce-
dures, release detection, emergency equipment available, evacu-
ation plans, training programs, and methods and schedules for
exercising emergency response plans.
Emergency Notification (Section 304)
Emergency notification is an essential element of EPCRA emer-
gency planning. Facilities that have an unplanned release of any
listed extremely hazardous substance orCERCLA Section 103(a)
chemical exceeding the reportable quantity must notify the LEPC
and SERC immediately.
Written follow-up is also required under this section. Information
provided during the emergency notification should be reported,
updating it with additional information such as actions taken to
respond to and contain the release, known and anticipated health
effects, medical advice, etc.
Community Right-to-Know Reporting (Sections 311 and 312)
The Community Right-to-Know provisions of SARA Title III are
intended to increase the public's knowledge and access to informa-
tion regarding the presence of hazardous chemicals in the commu-
nity and releases of these chemicals into the environment.
1989 •MCHMR
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4-7
Community
Right-To-Know
According to Section 311, facilities that must prepare or have
available MSDSs under the Occupational Safety and Health Act
(OSHA) hazard communication regulations must submit copies of
MSDSs or a list of MSDSs to the local emergency planning and
state emergency response commissions and the local fire depart-
ment.
If significant new information about a chemical is discovered, or if
new hazardous chemicals become present at a facility in quantities
above the established threshold levels, appropriate agencies must
be notified.
Section 312 requires submission of emergency and hazardous
chemical inventory forms by facilitiestothe LEPC, SERC, and local
fire department. These forms provide information on the types,
amounts, and locations of hazardous chemicals at a facility.
Inventory forms for Section 312 reporting are divided into Tier I and
Tier II forms. Under Tier I, facilities must provide the following in-
formation for each applicable OSHA category of health and physi-
cal hazard:
• an estimate of the maximum amount of chemicals in each
category present at the facility at any time during the
preceding calendar year,
• an estimate of the average daily amount of chemicals in
each category, and
• the general location of hazardous chemicals in each
category.
Upon request of the SERC, LEPC, or local fire department, the
facility must provide Tier II information foreach covered substance
including:
• the chemical name or common name on the MSDS,
• an estimate of the maximum amount of chemical present at
any time during the preceding calendar year,
'1989
CHMR
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4-8
• a brief description of the chemical storage methods,
• the location of the chemical at the facility, and
• an indication of whether the owner elects to withhold infor-
mation from disclosure to the public.
U.S. EPA published a uniform format forthe inventory forms. Since
many state emergency response commissions have additional
requirements or have incorporated Federal contents into their own
forms, Tier I and Tier II forms should be obtained from the state
agencies.
Toxic Chemical Release Reporting (Section 313)
Section 313 of EPCRA requires facilities to submit Toxic Chemical
Release Forms (Form R) for specified chemicals. Owners and
operators of certain facilities that process, manufacture, or other-
wise use a listed toxic chemical in amounts exceeding threshold
quantities must report emissions of such chemicals on an annual
basis.
This reporting covers releases from normal business operations. It
must also include emergency releases as well as information on
off-site shipment of wastes containing listed toxic chemicals. The
purpose of this requirement is to inform government officials and
the public about releases of toxic chemicals from a facility into the
environment.
The forms must be submitted to U.S. EPA and designated state
officials on or before July 1,1988, and annually thereafter on July
1, reflecting releases during each preceding calendar year.
Section 313 applies to owners and operators of facilities that meet
all three of the following requirements.
• The facility has ten or more full-time employees.
1989 •• CHMR
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4-9
• The facility is included in Standard Industrial Classification
codes 20 through 39.
• The facility manufactures, processes, or uses a listed toxic
chemical in the course of a calendar year in excess of
specified threshold quantities.
The list of toxic chemicals subject to Section 313 reporting consists
of acutely toxic chemicals listed on the Maryland-New Jersey lists.
There are over 300 chemicals and categories on these lists.
A complete Form R must be submitted for each toxic chemical
manufactured, processed, or otherwise used at each covered
facility. These forms must be sent to the U.S. EPA and state-
designated agencies. U.S. EPA must establish and maintain a
national toxic chemical inventory based on the data submitted. The
public must have access to this information.
4.2.3 Other Title III Provisions
Public Availability of Plans, Data Sheets, Forms, and Fo I low-
Up Emergency Notices (Section 324)
Information, such as emergency plans, MSDSs, hazardous chemi-
cal lists, inventory forms, toxic chemical release forms, and follow-
up emergency notices must be made available to the public under
Section 324 of EPCRA.
Each local emergency planning commission is required to publish
an annual notice in a local newspaper stating that emergency
plans, inventory forms, etc., were submitted and are available for
review.
Enforcement (Section 325)
There are civil, administrative, and criminal penalties ranging from
$10,000 to $75,000 per violation or per day for failure to comply.
11989
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4-10
Citizen Suits (Section 326)
Citizens or state/local governments may sue an owner or operator
of a facility for failure to submit various forms and notices required
under EPCRA.
4.2.4 SARA Title III—Key Dates to Remember
Deadlines for Industrial Facilities
May 17,1987
May 22,1987
Septembers, 1987
October 17,1987
March 1,1988
July 1,1988
September 24,1988
Any facility subject to Section 302 plan-
ning requirements must have notified the
SERC that it is covered by SARA.
A facility must have notified the state
commission of emergency releases.
A facility must have notified the local
emergency planning committee of the
name of the designated facility rep-
resentative.
A manufacturing facility should have sub-
mitted MSDSs or list of MSDS chemicals
on-site in quantities greater than initial
thresholds to SERC, LEPC, and the local
fire department.
A manufacturing facility must submit haz-
ardous chemical inventory forms to the
SERC, LEPC, and local fire department.
Revisions are due annually.
A covered facility must submit toxic
chemical release forms to U.S. EPA and
designated state officials. Revisions
are due annually.
A non-manufacturing facility covered under
the new OSHA expansion as of June 24,
1988, should have submitted MSDSs or
list chemicals present in quantities over
the first-year threshold to the SERC,
LEPC, and local fire department.
'1989
CHMR
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March 1,1989 A facility subject to the OSHA Hazard
Communication Standard should have
submitted emergency inventory forms to
the SERC, LEPC, and local fire depart-
ment.
October 17,1989 A manufacturing facility should have sub-
mitted MSDSs or list chemicals exceeding
the final threshold quantities to the SERC,
LEPC, and local fire department.
Deadlines for Local and State Agencies
April 17,1987 State governors must have appointed State
Emergency Response Commissions
(SERCs).
July 17,1987 SERC must have designated local emer-
gency planning districts
August 17,1987 SERC must have appointed members of
local emergency planning committees
(LEPCs)
October 17,1988 Local emergency planning committees
must have completed preparation of an
emergency plan (review annually there-
after)
4.2.5 Emergency Planning, Right-to-Know, and Waste
Minimization
An important first step in any waste minimization program is to
complete an inventory of all hazardous substances in the workplace.
Since the EPCRA requires such an inventory, an employer can
take steps toward right-to-know compliance—and simultaneously
initiate a waste minimization program.
While conducting an inventory, an employer may find hazardous
substances which are no longer used, which are used in excessive
quantities, or which are replaceable by less hazardous or non-
hazardous alternatives.
1989 HHCHMR
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By listing the environmental hazards emitted, discharged, or dis-
posed from your business, you are starting a "waste audit." The
waste audit is an important primary step in any waste minimization
program. You can, by conducting a waste audit:
• begin to realize exactly where your business is wasting ma-
terials;
• recognize specific areas of substance emission or dis-
charge where you can contain, recycle, or reuse some of
your waste—saving on raw material costs; and
• realize savings in decreased waste treatment and disposal
costs.
The waste reduction audit is a systematic and periodic survey of
company operations designed to identify areas of potential waste
reduction. More detai led guidance on how to conduct a waste audit
is provided in Chapter 6 of this manual.
4.3 Underground Storage Tanks (USTs)
Under Subtitle I of the Resource Conservation and Recovery Act
(RCRA), U.S. EPA has issued regulations for underground storage
tanks (USTs). The regulations include financial, technical, and
reporting requirements for owners and operators of USTs. These
regulations took effect on December 23, 1988.
A tank is an underground storage tank if it meets these two criteria.
1. Ten percent or more of the tank volume (including the volume
of associated piping) is below ground.
2. The tank is used to manage "regulated substances." These
substances include petroleum-based compounds and hazard-
ous chemicals listed by U.S. EPA.
> 1989
ICHMR
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Underground tanks containing hazardous wastes are regulated
under the hazardous waste tank regulations (see Section 3.7.5),
which are generally stricter than the UST regulations dealing with
hazardous substances.
The regulations pertain to both owners and operators of under-
ground storage tanks. If a tank is located on leased property, the
U.S. EPA may hold both the landowner and leasee responsible for
the tank.
4.3.1 Financial Requirements
The U.S. EPA requires UST tank owners/operators to demon-
strate "financial responsibility" for their USTs. They have set
minimum monetary requirements for insurance or the ability to
make direct payment for tank cleanups.
The amount of coverage required for marketing firms varies
between $1 million and $2 million depending on the number of
tanks you own. If you own between 1 and 100 tanks, you are
required to demonstrate ability to pay $1 million for cleanup costs.
Some small non-petroleum marketing firms may only be required
to obtain a half million dollars in coverage. Coverage fortanks may
be provided by an insurance policy, by state approved or funded
methods, or by the owner or operator if they can demonstrate that
their net worth is at least ten times the amount of coverage
required. Because many firms expressed difficulty in finding
insurance, U.S. EPA decided to phase in the financial require-
ments between January 1989 and October 1990. Firms with 12 or
less petroleum USTs are not required to demonstrate financial
responsibility until October 26, 1990.
4.3.2 Technical Requirements — New Tanks
Corrosion Protection
New tanks (built after December 1988) are required to have
corrosion protection, which can consist of any one of:
1989 HHCHMR
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• coated and cathodically protected steel,
• fiberglass construction, or
• steel clad with fiberglass construction.
Spill/Overflow Protection
Newtanks are requiredto have spill/overfill protection consisting of
catchment basins and either ball float valves, automatic shutoff
devices, or overfill alarms.
Leak Detection
New tanks are also required to have a leak detection system in
place. This can consist of either monthly monitoring, or monthly
inventory control along with tank tightness testing every 5 years.
Monthly monitoring includes either:
• automatic tank gauging,
• vapor monitoring,
• interstitial monitoring,
• groundwater monitoring, or
• other approved methods.
Monthly inventory control must be accompanied by tank tightness
testing every 5 years. It can only be done until the tank is 10 years
old, at which time one of the monthly monitoring methods must be
instituted.
Piping Requirements
The piping on new tanks must meet certain requirements—it must
be made of either coated and cathodically protected steel or
fiberglass. It must also be monitored by a leak detection system.
Special Requirements for Hazardous Chemical Tanks
Finally, secondary containment and interstitial monitoring are
required for all new USTs containing hazardous chemicals (not
petroleum product tanks). Secondary containment may include:
either vault, outer tank, or lining the excavation with an appropri-
1989 ••HCHMR
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4-15
ate liner. The interstitial monitoring system must be able to detect
leaks in the confined space between the tank and the secondary
containment.
4.3.3 Technical Requirements—Existing Tanks
The general intent of the regulations covering existing tanks is to
force them to comply with the new tank regulations within 10 years
or less.
Corrosion Protection
All existing tanks and associated piping must have a corrosion
protection system in place by December 1998. The corrosion
protection requirements include a choice from one of these five
alternatives:
• coated and cathodically protected steel,
• fiberglass tank construction,
• steel tank clad with fiberglass,
• cathodic protection system, or
• interior lining.
Spill/Overfill Protection
The spill/overfill protection systems required of existing tanks are
identical to those required for new tanks. They must be in place by
December 1998.
Leak Detection
The leak detection requirements for existing tanks include either:
• monthly monitoring as described for new tanks, or
• monthly inventory control plus tank tightness testing. Tight-
ness testing is required annually or once every 5 years, de-
pending on the tank.
The regulatory requirements are summarized in Figure 4-1.
1989 BHHCHMR
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EXISTING
UST
I
DOES TANK HAVE:
Spill / Overfill
and
Corrosion Protection?
NO
YES
Monthly Inventory Control
and
Annual Tank Tightness
Testing
Monthly Inventory Control
and
Tank Tightness Testing
every 5 years
I
Before December 1998
Upgrade with
Spill / Overfill
and
Corrosion Protection 1
I
By 1998
Monthly Inventory Control
and
Tank Tightness Testing
every 5 years
By 10 years after
upgrade
Monthly
Monitoring 2
1 Upgrading tanks includes internal inspection for tanks more than 10 years old, and tight-
ness testing for younger tanks. The corrosion protection system may be installed only if
the tank passes the inspection & tests.
2 Tank owners may use monthly monitoring instead of other leak detection systems at
any time. Tank "upgrading" requirements will still be in place even if monthly monitoring
is used.
Figure 4-1. Leak detection requirements for existing USTs.
1989
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Leak detection systems are required on existing tanks between
December 1989 and December 1993, depending on the age of the
tanks.
Date tank Date leak detection required
installed for tanks and suction piping
Before 1965 December 1989
1965-1969 December 1990
1970-1974 December 1991
1975-1979 December 1992
1980-1988 December 1993
For tanks with pressurized piping, leak detection systems for the
piping are required by December 1990.
Piping Requirements
Piping on existing tanks is required to be cathodically protected by
1998. The piping must also be monitored monthly or tested every
3 years.
Special Requirements for Hazardous Chemical Tanks
Secondary containment and interstitial monitoring is required by
1998 for all existing USTs containing hazardous chemicals (not
petroleum products).
4.3.4 Response to Leaks
Signs of a leak from an underground storage tank include warnings
from monitoring equipment, sustained losses of inventory, unex-
plained vapors near the tank or in neighboring basements, discol-
ored soil, or signs of vegetative distress.
If you suspect a spill or leak, notify your state UST office, and then
confirm the leak by checking equipment, re-checking inventories,
looking for environmental evidence of distress, etc. If the spill or
leak is confirmed, then you must:
1939
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4-18
take immediate action to contain and stop the release;
report the confirmed leak to your state LIST office within 24
hours for a hazardous chemical release of any quantity, or
a petroleum leak of over 25 gallons;
remove immediate threats such as explosion or fire haz-
ards;
determine the extent of contamination and recover any
spillage possible;
report progress to the state agency within 20 days; and
determine the extent of damage to the environment and
develop a plan for remediation within 45 days.
There are strict standards for tank and piping repairs, and follow-
up testing requirements. You may also be required to perform
additional remediation or testing.
4.3.5 Closing USTs
USTs may be closed temporarily or permanently. Tanks not used
for 3 to 12 months must be temporarily closed. All lines (except
vent lines) to temporarily closed USTs must be capped, corrosion
protection systems must be maintained, and leak detection sys-
tems must be operated unless the temporarily closed tank is
empty. To permanently close a tank, the owner/operator must:
• notify the state or Federal agency 30 days prior to tank
closure;
• sample soil, vapor, or groundwater adjacent to tank to de-
termine whether or not the tank leaked (if it did, the owner/
operator must take corrective action as described previ-
ously); and
1989 HHCHMR
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empty and clean the tank (then either remove the UST
from the ground or fill it with sand).
These requirements took effect December 1988. For tanks closed
prior to that date, inform the agency of the location, the date it was
closed, its former contents, type of construction, any remediation
required, and closure procedures. Government agencies reserve
the right to require testing to ensure that the tank did not leak.
4.3.6 Reporting and Recordkeeping Requirements
Reporting Requirements
When the tank is installed (or immediately if it has not already been
done) the owner/operator of a UST must complete a notification
form available from the state. Thirty days before the tank is
removed, notify the state of the intent to remove it.
If you suspect a leak or spill, notify your regulatory agency imme-
diately and follow the various notification requirements described
in Section 4.3.4.
Recordkeeping Requirements
You must keep records of leak detection performance and up-
keep—including at least one full year of monitoring results. Keep
records of inspections performed by corrosion experts and records
of tank repairs or upgrades. Finally, you must keep site testing
records for 3 years after the UST is permanently closed.
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4.4 Where to Call for Additional Assistance Regarding
Land Disposal Bans, SARA Title III, or USTs
For more information and assistance regarding land disposal bans
or compliance with SARA Title III and underground storage tank
requirements, call the toll-free CHMR Hazardous Materials Hotline
at (800) 334-CHMR.
CHMR also has available comprehensive information packets
which provide many more details on how to comply with the SARA
TITLE III and UST requirements.
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CHAPTEP
5.0 APPROACHESTO WASTE MINIMIZATION
Up to this point, you have been introduced to the importance of
waste mini mization to the small quantity generator, the advantages
of waste minimization, and how complying with various environ-
mental regulatory requirements can be an important first step in
minimizing your hazardous waste.
Forthe next four chapters, you will be shown the actual approaches
and techniques of waste minimization, illustrated in a format easily
used in the workplace.
5.1 Introduction
Approaches to waste minimization are primarily low-cost, low-risk
alternatives to hazardous waste disposal. Most of the approaches
do not require a great deal of sophisticated technology and can be
relatively inexpensive. In short, waste minimization approaches
are:
technically feasible,
• economically viable, and
ecologically beneficial.
In general, any waste minimization program should include or
consider:
management initiatives,
waste audits,
improved housekeeping,
materials substitution,
redesigning equipment,
recycling and reuse, and
waste exchange.
The following sections will introduce you to these various ap-
proaches to waste minimization. By becoming familiar with these
general approaches, you will be better prepared to understand the
next three chapters, which describe how to actually implement a
waste minimization program.
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5.2 Developing Management Initiatives
The commitment to waste minimization must come from the top—
the management of a business or organization. Management
initiatives are vital to the success of any waste minimization efforts,
and like the waste audit, should be considered as a preliminary step
in your waste minimization program.
5.2.1 Overview
Two management actions are crucial to a successful waste mini-
mization program:
• Communication: Management must make all employees
aware of the waste minimization effort.
• Incentives: Just as incentives are used to boost employee
productivity, management should provide incentives for the
development of useful waste minimization ideas.
Although a waste minimization commitment should begin with
management, the employees are often able to suggest improve-
ments in the day-to-day operations of the business. To utilize this
important resource, many businesses give their employees incen-
tives such as:
• recognition awards for outstanding waste minimization
projects, as well as for resource and energy conservation
projects; and
• financial awards for innovative approaches to waste
minimization.
These incentives can take any form suitable to the company and
the employees. Indeed, the incentives offered by a company with
approximately 200 employees may differ greatly from a company
with 5 employees. Regardless of the form of the incentives,
employees should realize part of the benefits of their waste
minimization ideas.
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The new management initiatives should foster the following ele-
ments of waste minimization success:
• increased awareness and attention to hazardous
chemicals,
• motivation to change old work patterns,
• knowledge of options for change,
• willingness to innovate and change,
• willingness to provide resources to implement changes, and
• willingness to learn from changes.
Another important management tool in the waste minimization
process is employee training. Although training can be presented
in many ways, training programs should include:
• occupational and plant safety;
• company regulatory compliance requirements;
• a statement of the company's waste minimization plan
(including incentives for waste minimization ideas and an in-
troduction to why waste minimization is important); and
• Material Safety Data Sheets (MSDSs) and other information
that comply with the requirements of worker and community
right-to-know laws.
5.2.2 Problem-Solving Through Employee Participation
This section outlines a problem-solving process that can be used
to gain employee commitment to and active responsibility for the
goals of your company. It is a method that can be directly applied
to developing a hazardous waste minimization program.
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This method:
• applies some of the most effective approaches in business
and industry,
• has been used extensively world wide,
• has been shown to increase productivity as well as decrease
operational costs,
• utilizes employee participation realizing that their involve-
ment will directly affect the ultimate operation of your
company, and
• can be used as an innovative training technique which gains
and holds your employees' attention.
This process is known as Problem Solving Through Employee
Participation and consists of five steps. They are:
• state purpose or goal,
• identify problems in the work area,
• list ways to solve the problems identified,
• develop an action plan, and
• follow up.
The key to the success of this problem-solving method is the
willingness of management to allow employee participation in the
process. This is normally done through group meetings. In order
to properly prepare for this, a manager or trainer must:
• state the purpose for conducting the meeting,
• clarify in advance what problems must be solved (waste
audit information can be used when applying this method
to waste minimization),
• plan the meeting so that time is well used and employee time
away from work stations is minimized, and
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• organize employees into groups of no more than 2 to 15
individuals.
Following is an outline showing the key ingredients for conducting
an employee problem-solving meeting.
A. State the purpose of the meeting.
1. Example—"To minimize waste generated in the work area."
B. Briefly outline what will happen in the meeting.
1. Review the order of the meeting.
2. Participant roles.
a. Leader (generally manager, supervisor, or trainer):
• conducts meeting,
• encourages participation,
• allows individual choice,
• gives equal opportunity, and
• sets example, listens.
b. Scribe/Reporter:
• notes statements as spoken, and
• does not editorialize until team critiques list.
c. Members in attendance take responsibility to participate
and to encourage others.
3. Use audio/visual aids if possible.
C. Method
1. Brainstorming (give each group member an opportunity to
contribute to solving the problem).
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a. Proceed around the group until each member is satisfied
that the list includes all of their concerns/ideas.
b. If a group member has no concerns or ideas, they
indicate this by saying "pass."
2. Critique/review your list (combine items on list, clarify, gain
consensus).
a. Incorporate statements that are much the same.
b. Get agreement on wording.
3. Develop an action plan.
a. State a goal (this could be the same as one stated at
the beginning of the meeting).
b. Define action to be taken (example: provide
individual containers for different waste types).
c. Determine a time frame for action to be taken.
d. Assign responsibilities (who, what to do, when,
where, how often).
e. Write down action plan and post or distribute to
employees (this can be done by the leader after the
meeting).
4. Close meeting.
a. Recognize member contributions.
b. Reinforce the purpose of the meeting (e.g., remind
employees to be conscientious about minimizing
waste in their work areas).
c. Review action plan and follow-up procedures.
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D. Conduct follow-up to the meeting.
1. This can be done in the work area or in another meeting.
2. Review goals with people responsible for carrying out
assignments.
3. Have responsible people give a progress report on their
assignments.
a. Determine progress made toward achieving goals.
b. Define any problems encountered by employees in
pursuing goals.
4. Reinforce the positive aspects of performance toward
achieving goals.
5. Make any changes or adjustments necessary to further
pursue goals.
6. Determine what additional training or instruction is needed
to achieve goals.
7. Record additional assignments and changes that have
been made to the action plan, and post or distribute to
employees.
5.3 Performing a Waste Audit
The waste audit is the most basic of all of the approaches to waste
minimization. However, it is important to keep in mind that the
waste audit is a preliminary step—it is an essential precursor to the
other waste minimization approaches. A waste audit alone will not
minimize your waste, but it will get you started.
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The waste audit tracks your hazardous waste by monitoring all of
the waste which is produced at your place of business to learn
where it was generated. You can determine where hazardous
materials are used and where raw materials are being wasted. As
a result, you may discover that you are purchasing much more of
a raw material than your business can use in a given time, or you
may discover areas of waste production that you did not recognize
before the audit.
The waste audit can be divided into six steps:
1. Identify hazardous substances in waste or emissions.
2. Identify the sources of these substances.
3. Set priorities for various waste reduction actions to be
taken.
4. Analyze some technically and economically feasible ap-
proaches to waste minimization.
5. Make an economic comparison of waste minimization
and waste management options.
6. Evaluate the results.
The waste reduction audit is a systematic and periodic survey of a
company's operations and is designed to identify areas of poten-
tial waste reduction. More detailed guidance on conducting a
waste audit is provided in Chapter 6.
5.4 Improving Housekeeping
Improved housekeeping, or "good operating practice," is the sim-
plest waste minimization practice. Improved housekeeping relies
on using common sense and is often the most effective first step
toward waste reduction.
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Good housekeeping practices involve the procedural or organiza-
tional aspects of a manufacturing process and include elements
such as:
• inventory control,
• waste stream segregation,
• material handling improvements,
• scheduling improvements,
• spill and leak prevention, and
• preventive maintenance.
Good housekeeping is good operating practice which can be
applied industry-wide. A detailed discussion of good operating
practices is provided in Section 7.1.
5.4.1 Waste Segregation
One relatively simple housekeeping method is waste segregation.
In many cases, segregation of wastes allows for certain wastes to
be recycled or reused, as illustrated in the following examples.
• In a business using both chlorinated and non-chlorinated
solvents, these waste types should be kept separate. This
enables you to identify precisely which wastes can be
recycled.
• In a business which plates metal parts and generates
plating wastes, such as cyanide and heavy metals, the parts
can be pre-screened for defects. In this way, the company
plates only those parts fit for sale, uses less plating solution,
and generates less waste.
• At a printing company, waste toluene from printing press
cleanup can be eliminated by segregating this solvent ac-
cording to the color and type of ink cleaned from the press.
Each segregated batch of toluene can be reused for thin-
ning the same color ink.
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5.4.2 Improved Labeling
Improved labeling allows employees to know precisely what a
container or pipeline holds, and guards against accidental spills
and unnecessary usage—both a waste of materials. All sub-
stances used in the workplace should be properly labeled. In
addition, all wastes, once segregated, should be labeled as well.
This procedure helps to ensure safe handling of wastes, and can
point out containers of waste which have the potential for recycle,
reuse, or even resale.
5.5 Substituting Materials
Upon completion of a waste audit, you may identify specific
materials within your business which are producing hazardous
waste. If this is the case, it may be possible to find a substitute
material which is less hazardous. Although material substitution is
only applicable in certain situations, it can prove to be an efficient
hazardous waste minimization approach.
• A painting business uses a hydrocarbon solvent (toluene)
for daily cleanup of hydrocarbon-based paint. By switching
to water-based paint, water can be substituted for toluene
for cleanup.
• Water-soluble cleaning agents can often replace organic
solvents or degreasers. One company did this and suc-
cessfully reduced its 1,1,1-trichloroethane use by 30 percent,
resulting in a $12,000 annual savings.
5.6 Technology Modifications
In many instances, technological modifications or material substi-
tutions are also very effective in minimizing wastes. Some products
can be manufactured by two or more distinct processes, and one
process may produce less hazardous waste than the other.
Modifying equipment within a given process is another way to
reduce waste generation.
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Technological modifications can be generally categorized as:
• process modifications,
• equipment modifications,
• process automation,
• changes in operation settings,
• water conservation, or
• energy conservation.
5.6.1 Process Modifications
Production processes may be responsible for the production of
hazardous waste. Old or inefficient processes could be sources of
hazardous waste. By changing to a newer, more efficient process,
a company could decrease the amount of waste it generates. In
addition, many companies can experience improved production
capacity and product quality and realize savings in expenditures for
utilities and raw materials.
• In printed circuit board manufacturing, the use of screen
printing for image transfer instead of photolithography elim-
inates the use of developers.
• By replacing a solvent-based painting system with a water-
based electrostatic immersion painting system, the Emer-
son Electric Company has reduced waste solvent and paint
solids generation by over 95 percent.
Process modifications often entail subsequent equipment modifi-
cations.
5.6.2 Equipment Modifications
Equipment modifications accomplish waste reduction by reducing
or eliminating equipment-related inefficiency. An equipment
modification leaves the production process intact and unchanged,
because it modifies only the equipment which comprises the
process.
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A simple dragout recovery system was installed by the
Stanadyne Company on a nickel plating machine. Less
than $1,000 was invested for a dragout recovery tank, which
saved the firm $4,200 worth of nickel per year and reduced
nickel sludge generation by 9,500 pounds per year.
5.6.3 Process Automation
Process automation involves the use of automatic devices to assist
or replace employees. Automation can include monitoring and
subsequently adjusting process parameters by computer or me-
chanically handling hazardous substances. Waste minimization is
accomplished by reducing the probability of employee error (which
can lead to spills or off-spec products) and by increasing product
yields through the optimum use of raw materials.
5.6.4 Changes in Operation Settings
Often the generation of hazardous waste may not be the fault of the
equipment. Instead, the fault may lie in the way the equipment is
set to operate. These are often the most easy and inexpensive
equipment changes.
• Many spraying processes operating at decreased pres-
sures have less overspray and subsequently less waste.
• In formulating their cyanide copper plating baths, the
Stanadyne Company determined that lower chemical con-
centrations can be used. By running the potassium cyanide
concentration at 2.5 ounces per gallon, instead of 3.5
ounces, the cyanide dragout concentration was reduced by
28 percent—without any adverse effect on plating quality.
Most equipment has optimum settings at which it operates most
efficiently. By determining the optimum settings for certain para-
meters (such as optimum temperature and pressure), less waste
is generated as a by-product.
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5.6.5 Water Conservation
Although not as significant as other approaches, water conserva-
tion can have an effect on minimizing hazardous waste generation.
• By reducing the amount of water used for washing some
organic chemical products, companies can lower the amount
of waste water which must be pretreated before disposal.
5.6.6 Energy Conservation
Energy conservation minimizes the waste associated with the
treatment of raw water, cooling water blowdown, and boiler blow-
down. In addition, lower energy usage means a reduction in the
generation of ash and other wastes associated with combustion.
Energy conservation can be accomplished through a series of heat
exchangers within the production process.
5.7 Recycling and Reuse
Recycling and reuse of hazardous wastes can be a very economi-
cal undertaking. Many companies have discovered that the cost of
installing on-site recycling equipment can be quickly recovered
and future profits gained by savings in waste management and raw
material costs.
• A pesticide manufacturer generated pesticide dust from two
major production systems. The firm replaced the single
baghouse with two separate vacuum-air-baghouse sys-
tems specific to the two production lines for $9,600. The
collected material was recycled to the process where it was
generated. The firm has eliminated over $9,000 in annual
disposal costs, and estimates that the recovered material is
worth more than $2,000 per year.
• The Rexham Corporation facility in Greensboro, North
Carolina installed a distillation unit to reclaim n-propyl
alcohol from their waste solvent for a total installed cost of
$16,000. The distillation unit recovers 85 percent of the solvent
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in the waste stream, resulting in a savings of $15,000 per year
in virgin solvent costs—and in a $22,800 savings in hazard-
ous waste disposal costs.
In addition, there are many off-site recyclers who will take a
company's waste, recycle it, and sellthe refined product backto the
company at a price significantly less than the cost of virgin material.
Additionally, that company will not have to incur waste disposal
costs.
• The Hamilton Beach Division of Scovill, Inc. operation
requires 1,1,1-trichloroethane solvent to degrease metal
stampings. Ashland Chemical Company was contracted to
recycle the waste by distilling 1,1,1-trichloroethane. Substi-
tuting the recycled solvent for the virgin product has reduced
Hamilton Beach's overall raw material costs by $5,320 per
year. Scovill also eliminated all of their previous waste
disposal costs, estimated to be about $3,000 per year.
The array of reuse options is too extensive for detailed discussion
here. Numerous recovery technologies are presented in Chapters
7, 8, and 9.
5.8 Participating in Waste Exchanges
Waste exchanges are networks of businesses which attempt to find
markets for the wastes they generate. Remember that hazardous
waste to one business can be a valuable resource to another. The
exchange attempts to match the waste from one business with the
raw material requirements of another business. Small businesses
can also find excellent recycling opportunities through such organi-
zations. Often a "buyer" company is able to purchase, recycle, and
subsequently reuse another's waste. In this way, the buyer is able
to save on raw material costs, and the hazardous waste generator
is able to market a new product as opposed to disposing a
hazardous by-product.
For more information on waste exchanges, see Section 11.5.
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CHAPTEI
6.0 HOW TO CONDUCT A WASTE AUDIT
A waste audit can be extremely useful in diagnosing how a facility
can reduce or recycle wastes, and it is an essential first step in any
waste minimization program. The waste reduction audit is a
systematic and periodic survey of a company's operations and is
designed to identify areas of potential waste reduction. This
section describes how to conduct a waste audit.
6.1 Introduction
Some of the purposes of a waste minimization audit include:
• reducing waste disposal costs,
• reducing production costs,
• reducing or eliminating future liability,
• enhancing environmental awareness of all
company personnel,
• complying with hazardous waste regulations,
• demonstrating concern for the environment, and
• demonstrating concern for worker/community health and
safety.
Specific waste audit procedures should be tailored to suit your
facility or company. However, a number of factors should be
addressed by any waste audit, including:
• selecting an audit team,
• identifying waste streams and flow rates,
• identifying waste generation problems,
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• formulating a range of solutions for each of these problems,
• initial screening of these potential solutions,
• discussing options with plant personnel,
• ranking the most reasonable options, and
• examining the feasibility of implementing the recommended
options.
Waste audits are intended to identify and recommend options for
potential areas of waste reduction and are an essential first step.
Implementation and evaluation of progress must follow before the
benefits of any waste minimization program will be realized.
6.2 Select the Audit Team
The first task is to select an audit team. The specific makeup and
number of members will depend on the size, complexity, and
resources of a company. In a small business, the audit "team" may
be limited to one or two individuals responsible for facility opera-
tions. Ideally, the team should include people who are knowledge
about the following topics:
• facilities, environmental, and process engineering;
• safety and health;
• product assurance/quality assurance;
• purchasing;
• legal;
• finance; and
• other facilities within the company.
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Outside consultants should be used to supplement in-house capa-
bilities.
Some of these topics may seem inappropriate to a waste audit
team. However, after closer examination, their relevance be-
comes more obvious. For example, product assurance is needed
to help reduce rejects. Financial information is often required to
determine the basis upon which to calculate return on investment.
Although a waste minimization commitment should begin with
management, operating employees are quite often qualified to
suggest improvements in the day-to-day operations of a business.
Employee participation on the waste audit team should be consid-
ered. Employee involvement in the waste minimization process
through incentive programs, training, and problem-solving is dis-
cussed in detail in Section 5.2.
A crucial element in the success of a waste audit is the
recognition of the audit's value by management. There is
greater probability that waste reduction innovations will be incorpo-
rated into plant operations if an audit has been initiated by manage-
ment.
6.3 Pre-lnspection Review
6.3.1 Audit Team Briefing on General Waste Minimization
Opportunities
Before the plant visit, the audit team should be briefed on general
waste minimization opportunities. These should include minimiza-
tion practices which generally apply to any waste stream, as well
as those which have been identified to reduce particular waste
types in similar industries.
The purpose of the briefing is to educate the audit team on waste
minimization opportunities they can be trying to identify during the
audit. The briefing should include discussions of waste minimiza-
tion opportunities in:
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• administrative control of materials;
• housekeeping, handling (including waste segregation), and
storage;
• raw material substitution;
• recycle or reuse of waste streams;
• modification of process, equipment, or operation;
• potential for redesign of process; and
• phase out production.
General information sources of waste-specific, industry-wide, and
industry-specific waste minimization practices (such as this man-
ual) can be used for the audit team briefing.
6.3.2 Collect and Review Background Information of the Facility
Any available and useful background information should be col-
lected and reviewed by the audit team after the team has been
selected but before the on-site plant visit. Such information may
include:
• company policies on waste minimization;
• process flow diagrams and facility layout;
• chemical analysis of waste streams and waste discharges;
• operating manuals;
• purchasing records;
• waste manifests, annual reports, and other RCRA information;
• environmental regulations;
• contracts with waste management firms;
• RCRA permits;
• regulatory violations;
• results of previous audits;
• description of existing waste minimization program; and
• product information, MSDSs.
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It may also be appropriate to combine the waste audit process with
the process of compiling the information required to comply with
the various worker and community right-to-know laws if such
information is not yet compiled.
6.3.3 Identify and Characterize All Waste Streams
Once the audit team has met and reviewed all background informa-
tion, it must assemble a listing of the facility's waste streams. This
should be done before the plant visit and then verified or revised
during the visit. Waste streams to consider include discharges
such as:
• waste water discharges,
• stack emissions,
• fugitive emissions (e.g., tank evaporation losses), and
• solid wastes.
Each waste stream should then be fully characterized. This should
first be attempted based on background information, then revised
during the plant visit. Some of the points which should be reviewed
on each waste stream include determining:
actual point of generation,
any handling and/or mixing,
if the waste is hazardous or non-hazardous,
other physical and chemical characteristics,
quantities—including variations, and
current costs of waste management.
6.3.4 Request Additional Information
The primary purpose of the "pre-inspection review" phase of the
waste audit process is to be better prepared for the site visit by
becoming familiar with all available background information. At
this point in the audit process, it may be possible to identify
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"information gaps" such as missing characterization of identified
waste streams. To the extent possible, such additional information
should be requested and reviewed before the site visit.
6.3.5 Prepare Checklist for Plant Inspection
A checklist should now be prepared which is specific for the plant
to be inspected and which will help guide the audit team through the
plant visit. To summarize, the checklist should include:
• full characterization of all waste streams and generation
points—to be verified;
• all waste minimization practices including housekeeping
which the pre-inspection review identified as already
in place—to be verified and evaluated;
• proposed waste reduction options identified during the pre-
inspection review—to be verified; and
• other general waste minimization opportunities to
identify, including:
- administrative control of materials;
- housekeeping, handling (including waste segregation),
and storage;
- raw material substitution;
- recycle or reuse of waste streams;
- modification of process, equipment, or operation;
- potentials for redesign of process; and
- phase-out production.
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6.4 Visit the Plant
You are now ready to visit the plant. Throughout the visit, the team
members should use the inspection checklist and ask questions
related to the specific focus of the items discussed previously and
look for specific opportunities to enhance waste minimization.
Much of the pre-inspection background information should be
verified and any additional waste streams identified and character-
ized. Any new information gaps should be identified and the
additional information gathered.
6.5 Identify and List Plant-Specific Waste
Minimization Opportunities
Throughout the audit process, each team member should identify
and note potential waste minimization practices they believe can
be applied to the audited facility.
After the facility visit, the audit team should list all the possible
opportunities to enhance waste minimization options. An effective
method is the brainstorming process, where each team member
presents his or her list of waste minimization options. These lists
can be combined to form a master list. The list may include several
options for a single waste stream or process. At this time, it is not
necessary to consider in detail the technical or economic feasibility
of any option. The development of this list should be based on the
broad range of waste minimization opportunities discussed in
Section 6.3.1 and presented throughout this manual. These
include:
• improved housekeeping,
• material substitutions,
• technology modifications,
• recycling and reuse,
• participation in waste exchanges, and
• detoxification.
These basic waste minimization approaches (see Chapter 5)
should begin to become part of the thought and evaluation proc-
esses of all team members as they look to identify specific waste
minimization opportunities.
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6.6 Screen and Set Priorities for Waste
Minimization Actions
Now that a complete range of potential waste minimization options
has been proposed, it is useful to screen these options to determine
which should be studied more thoroughly. After some thought and
discussion, but without going into much detail, it will become
obvious that some options should be deleted from further consid-
eration.
The audit team should now set some initial priorities for waste
minimization actions. In setting priorities, the team should con-
sider:
• the existing regulations affecting particular wastes—for ex-
ample, when the government bans or restricts the disposal
of certain wastes (see Section 4.1), your business may
have no choice but to minimize that waste;
• the adverse health and environmental effects of the waste;
and
• the ease and expense of implementing a waste minimiza-
tion practice for the waste.
Setting initial priorities does not require detailed cost/ effectiveness
analysis. Some waste minimization options are obviously easier
and less expensive to implement than others.
Consider the potential disadvantages of any waste minimization
actions. Evaluate any new wastes you may generate and consider
the possible difficulties you may encounter when attempting to
dispose of these new wastes.
The results of the first screening and ranking of waste minimization
actions should then be discussed with plant personnel and com-
pany management, if appropriate. Final rankings of the most
reasonable options should then be developed in light of these
discussions and additional evaluation.
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6.7 Examine Feasibility of Implementing
Recommended Waste Reduction Options
Following the final ranking, it will be necessary to examine the
feasibility of implementing the recommended waste reduction
options.
6.7.1 Overview
Depending on the particular structure of your waste audit proce-
dures and the makeup of the audit team, this implementation step
will probably go beyond what is generally considered to be part of
the waste audit. The waste minimization program must now begin
to involve management decision making and, in some cases, an
engineering or feasibility study.
The feasibility of some of the more simple, low-cost waste minimi-
zation practices—such as improved housekeeping and waste seg-
regation—can be easily determined. Such practices are usually
readily approved and implemented.
Other recommended waste minimization practices which involve
more capital costs, such as technology modifications or equipment
for recycling and reuse, will require a more detailed technical and
economic analysis to determine feasibility.
6.7.2 Technical Feasibility
Some waste minimization practices involving technical modifica-
tions will require a more detailed evaluation of feasibility. Some
issues to considerwhen making this technical assessment include:
• effects on process production capacity,
• effects on product quality,
• physical plant limitations (e.g., space limits),
• specific equipment requirements and options,
• effects on maintenance requirements,
• utility requirements,
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• creating new by-products,
• physical and chemical properties of material or wastes, and
• potential health, environmental, or safety impacts.
Consideration of these and other technical issues will help you
select the best and most appropriate option to achieve a specific
reduction goal. On the other hand, atechnical feasibility evaluation
may determine that certain waste minimization goals are not
possible at your facility.
6.7.3 Economic Feasibility
When choosing a waste minimization program, a key question is,
"How profitable is this alternative with respect to others?" To
answer this question, a method for evaluating the economic
feasibility of mutually exclusive projects is required. Two common
methods used for pollution control or waste minimization projects
are:
• payback period (PBP), and
• net present value (NPV).
Regardless of the method chosen, the first step in evaluating a
waste reduction project is to estimate the total costs and future
savings expected from the proposed project.
Estimating Costs of a Minimization Project
The total costs of a proposed waste minimization project should
include both the initial capital outlays, such as:
• land,
• buildings, and
• equipment;
plus ongoing expected annual expenses, such as:
• supplies, • utilities, and
• spare parts, • labor.
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The ongoing expected annual expenses should be limited to those
additional expenses associated with the proposed project. For
example, additional labor to operate new equipment should be
included. Any additional maintenance in the facility's production
process caused by a proposed modification should also be in-
cluded. On the other hand, any reduction in labor or maintenance
on the production line would be a savings as discussed in the
following section.
Estimating Savings from a Minimization Project
For estimating future savings from waste reduction projects, con-
sideration should be given to both anticipated profits, if any, and
reduction in future costs. These may include:
• reduced waste transportation and disposal costs;
• reduced waste storage and handling costs;
• reduced on-site pre-disposal treatment costs;
• income derived through sale or reuse of waste;
• reduced production costs;
• reduced raw material purchases;
• utility savings, including fuel and water;
• reduced personnel and maintenance costs;
• reduced or avoided state fees and taxes;
• permit cost savings;
• reduced reporting and/or manifesting costs;
• pollution liability insurance savings;
• reduced costs of emergency preparation;
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• reduced costs of health and safety protection requirements;
and
• avoided fines and cleanup costs.
Admittedly, some future savings will be difficult to quantify, such as
avoided future cleanup costs or avoided disposal taxes not cur-
rently assessed. Such savings can be omitted orconservative best
estimates used which will result in a conservatively low total
savings estimate.
Payback Period (PBP) Method
The payback period is defined as the minimum length of time
required to recover the modification cost in the form of cash flows
to the project, based on total income minus all costs except
depreciation.
The formula for quickly estimating the payback period is:
PBP =
capital cost of project
avg. annual savings + avg. annual depreciation
For example, a business installs a piece of equipment that gener-
ates $50,000 peryear in cost savings and depreciation. If the total
cost of the equipment was $100,000, then the payback period is
2 years.
Many companies use the payback periods of competing projects
as the sole tool of comparison. This method is not completely
reliable. The payback period only measures a project's liquidity.
A project with a longer payback period can be more profitable in the
long run. So while the payback period is an important feature of a
project, it is not a measure of feasibility.
Net Present Value (NPV) Method
The most common method for measuring economic feasibility is
the discounted cash flow, or net present value method. This
method discounts projected cash flows into the present, thus taking
into account inflation and the time value of money. If the NPV is
1989 I^HCHMR
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greater than zero, the project is profitable. The NPV of different
projects can then be compared, and the one with the highest value
is the most profitable.
The net present value of a project can be calculated by adding
together:
Savings - Costs (t)
(1+MARR)'
for every year (t) of the project's life, where:
Savings - Cost (t) = the total estimated savings (anticipated
revenues plus reduced future costs—see
Section 6.7.3) from the proposed project
minus the total estimated cost (capital out-
lay for t=0 plus operating costs, see Section
6.7.3) of the proposed project for year t.
MARR = the minimum attractive rate of return, defined
as the average cost of capital for the firm.
The following simplified example illustrates the use of the net
present value method to evaluate project feasibility:
NPV method example: A company buys a solvent recovery
system.
• The total capital outlay for the system is $7,500.
• The total ongoing average annual operating costs will be
$500 per year.
• The system will last for 5 years, then be discarded as scrap.
• The total estimated average annual savings will be
$2,800 per year in avoided waste disposal and reduced raw
material costs.
• The company's MARR is 10 percent (or 0.10).
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The net present value of the proposed project is then calculated as:
Savings Costs Savings minus Savings-Costs(t)
Year (t) (t) Costs(t) (UMARR)m
$ (7500)
2090
1900
1730
1570
1430
0
1
2
3
4
5
$ 0
2800
2800
2800
2800
2800
$7500
500
500
500
500
500
$(7500)
2300
2300
2300
2300
2300
Total project NPV = $1220
Therefore, the total profit from this project, accounting for inflation,
would be $1,220. The initial cost is felt immediately and is not
affected by discounting. Each following year the profits must be
discounted.
The numbers in the last column are calculated by the formula given
atthe beginning of this section. Forexample, in the fourth year, the
year's savings minus the year's costs are divided by one plus the
MARR raised to the fourth power, or
Savings- Costs (year 4) _ 2300
(1+MARR)4 ~ (1.1)4
The total NPV for years 0 through 5 are added together, resulting
in a total project NPV of $1,220. Any other project's NPV would be
calculated in the same way, and the result compared to the $1,220.
A larger NPV would imply greater profitability. Always implicit in
this comparison is the "do nothing" alternative. If all NPV's are less
than zero, the least negative is the best, but is still not economically
profitable. In that situation, if profits were the only consideration,
then the best alternative would be to "do nothing."
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6.8 Evaluate Progress and Success of Waste
Minimization Efforts
To plan future waste minimization efforts, companies must estab-
lish a means of documenting and evaluating current and past
waste minimization programs. Such an analysis should consider:
• how waste minimization efforts have affected:
- composition of wastes;
- amount of waste;
- cost of waste management;
- production capacity and product quality;
- production costs including raw materials;
- utilities and maintenance costs;
- environmental compliance;
- health and safety exposure of workers and community;
- environmental, health, and safety liability; and
• the program's actual costs and savings compared with
initial program estimates.
In order to perform such an analysis, the following information
should be collected:
• composition, amounts, and handling of all waste streams
before and after the initiation of the waste minimization
effort;
• waste minimization costs and savings, including unex-
pected costs, inconveniences, and unforeseen benefits; and
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initial technical and economic analyses to compare with
actual performance of the program.
6.9 Conclusions
The waste audit is a critically important first step toward waste
minimization. Performing a thorough waste audit will result in the
selection of economically feasible waste reduction options. To
perform such an audit will require a good working understanding of
the waste minimization approaches and practices discussed
throughout this manual. However, in order to gain the benefits of
waste minimization, the best recommendations of your program
must be implemented.
In addition, it is important to charge all costs associated with waste
management to the production processes which are affected.
Although this step may seem obvious, many companies treat their
waste management costs as separate budget items. By charging
waste costs directly to the processes which generate them, com-
panies can determine where waste can be reduced in a cost
effective manner. Previous decisions might be reconsidered once
it is realized that the cost of managing that waste directly influ-
ences the cost of production.
Finally, the waste audit process should be ongoing and repeated
periodically. Production processes change. The costs of waste
management increase every year. New technologies and waste
minimization practices are developing rapidly. Repeated waste
audits will identify new waste reduction options previously missed
or considered too costly. Waste minimization should become an
ongoing part of doing business.
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7.0 General Waste Minimization Practices
7.0 General Waste Minimization Practices
This chapter reviews some general routines of good operation and
some specific waste minimization practices for certain processes
commonly used by many industries: metal parts cleaning, process
equipment cleaning, and paint application.
7.1 Good Operating Practices
7.1.1 Introduction
A procedural or policy change in a plant orfacility can be agood first
step in a waste minimization program. The objective of good
operating practice is to reduce accidental and material losses while
maintaining or increasing productivity. Good practice can range
from a change in management approach to modifications in waste
handling procedures. Proper procedures and policies on waste
minimization must be a part of the overall operating plan.
Good operating practice for waste minimization is defined as a
procedure or institutional policy within a company or organization
which results in reduction of hazardous waste generation. Good
operating practice relates primarily to the human aspect of produc-
tion (organizational structure, housekeeping improvements, initia-
tives, operations planning, and control), as opposed to changes in
technology or materials.
Some areas which might easily lend themselves to changes in
operating practices are:
Material handling improvements. Change material handling
procedures to reduce the amount of waste.
Management initiatives. Revise operational supervisory struc-
ture (or schedules) or any managerial procedures and incentives
in order to reduce waste.
Employee training. Increase employee awareness of operating
practices that reduce waste generation.
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Scheduling improvements. Develop tighter, more accurate
scheduling and plant area communications to reduce waste and
coordinate handling.
Spill and leak prevention. Change existing procedures to reduce
waste resulting from cleanup of spills or leaks.
Preventive maintenance. Develop maintenance procedures
designed to reduce equipment breakdown, inefficiency, or process
fluid leakage.
Corrective maintenance. Make corrective efforts, such as reset-
ting control valves or adjusting process temperatures, to increase
efficiency and prevent raw material loss through waste streams.
Material/waste tracking or inventory control. Improve the track-
ing of a material's location, quality, age, and use; and altering
purchased lot sizes to result in less waste.
Communication documentation. Develop procedural guide-
lines or material information which results in less waste.
Waste stream segregation. Take measures to isolate waste
streams according to (1) toxicity, (2) type of contaminant, and/or (3)
physical form, which reduces the amount of waste.
The above elements of good operating procedures are good
housekeeping practices that can be implemented in one form or
another by most businesses. They can result in tighter manage-
ment of an operation, more efficiency, and higher productivity.
7.1.2 Good Operating Practices for Waste Minimization
Management Programs
Management initiative programs have arisen as an answer to
higher disposal costs and environmental concerns. Several ap-
proaches, such as waste audits and safety training courses, have
already been discussed in this manual.
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A strong management commitment is necessary to make these
programs work, and they must be implemented from the top down.
Starting with a waste audit and identifying the areas in which
improvement is needed.
• The 3M Corporation "Pollution Prevention Pays" Program
has eliminated the generation of approximately 103,000
tons of sludge and solid waste annually for the last 11 years.
Cumulative savings are estimated at $248 million.
Programs less complex than 3M's, such as the following basic
pollution awareness program, are also effective.
• Borden Chemical Company of Fremont, California, imple-
mented a program which consisted of process reviews by
management and training programs for employees. These
steps resulted in a 93 percent reduction in the organics entering
the company's water treatment system. Often, employee input
will be encouraged by creating an incentive program to
reward waste minimization ideas which are implemented.
Procedural Measures
Prepare operating manuals. Documentation of each process
which generates hazardous waste ensures that all jobs are well
defined and uncertainty is reduced. A detailed manual or set of
operating instructions can increase safety and efficiency. Such a
manual should include:
• detailed description of normal operating procedures,
• listing of process operating conditions and controls,
• listing of effluent and emission discharge levels,
• description of the overall process and where individual
jobs fit in,
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• identification of safety hazards and how to deal with them,
and
• an outline of emergency procedures.
Procedural guidelines can be helpful in reducing waste generation
during maintenance or emergency shutdowns. Written operating
procedures and guidelines also reduce the likelihood of producing
unacceptable products which must be discarded.
Keep Material Safety Data Sheets (MSDSs). The Occupational
Safety and Health Administration (OSHA) requires MSDSs for all
hazardous materials. These sheets contain the manufacturer's
information regarding:
chemical, physical, and toxicological properties of the
substance; and
proper handling and storage procedures.
Although introduced as a safety measure, the MSDSs can help
reduce waste generation. For example, following the procedures
on the data sheets can reduce the probability of accidental contact
between two hazardous materials which may contaminate both. In
the event of a spill, these data sheets can be referenced to
determine the best method for cleanup. More specifically, some
helpful information that can be gained from the MSDS includes:
• boiling point
• vapor pressure
flash point
specific gravity
An important piece of information is the boiling point of a sub-
stance. You can use the boiling point temperature given on the
MSDS to avoid the evaporation of solvents such as paint thinners
and degreasers. When a solvent evaporates, its vapors are lost
into the air. Losing a solvent through evaporation costs just as
much as using the solvent. You can often tell if a solvent is
evaporating by the smell of vapors described on the MSDS. These
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vapors are just another form of the solvent—but aform that is being
wasted into the air. Also, these vapors often pose a fire hazard and
expose workers directly to the chemical.
Solvents with low boiling points will evaporate more easily than
solvents with high boiling points. Therefore, solvents with low
boiling points should be kept:
• in a cool storage area,
• away from open flames,
• away from sunlight or artificial light, and
• with the lid tightly closed.
By employing these simple precautions, you can save money by
not wasting your solvent through evaporation.
The flash point temperature is another useful piece of information.
The flash point is the temperature at which vapors of a substance
will burst into flame, or "flash" when exposed to an open flame.
When you know the flash point of a substance, you can provide
proper storage facilities and designate places where it is used as
no smoking areas.
By familiarizing yourself with the flash point, you can provide a safer
working environment by lowering the risk of accidental fires. This
is not only good safety, but it can also lower insurance costs.
In the case of fires, knowing the specific gravity of a substance can
help in choosing the proper fire extinguisher. The specific gravity
is the measure of the density of a material relative to water. The
specific gravity of water is 1. Thus, if a liquid has a specific gravity
less than 1, that substance is "lighter than water." Therefore, if such
a liquid were burning, any water applied to the fire would sink below
the flames, allowing the fire to continue. In fact, water can often
spread fires this way — as in the case of burning hydrocarbons
(e.g., gasoline). An extinguishing agent with a specific gravity less
than 1, such as carbon dioxide, would not sink and would conse-
quently smother the flames.
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Knowing proper firefighting procedures can save money in insur-
ance costs and materials which would not have been lost had the
proper extinguisher been used.
• Consolidated Diesel of Whitakers, North Carolina, uses
material safety data sheets to screen all materials entering
their plant. Before the material is requisitioned, medical and
hazardous materials experts are required to approve it, ensur-
ing that the hazardous characteristics of the substance have
been researched and evaluated prior to its use. This reduces
hazardous waste generation by preventing the use of some
materials which require regulated disposal.
Labeling. Another form of documentation becoming popular is
labeling. Labels are clearly marked with information on contents,
storage, handling, spill procedures, and first aid for exposure. Bar
coded labels can link containers and materials to a computer
through all stages of container life. This improves the accuracy of
material tracking and inventory accounting. In addition, bar coded
labels allow material monitoring during use and prevent lost or
outdated materials at the plant site.
Material handling and storage. Proper material handling and
storage is an easy and economic procedure for the prevention of
waste generation. Losses from improperly handled materials can
be minimized without incurring large capital costs. Often a change
in procedure or organization is all that is necessary to realize the
reduction. The proper storage of hazardous materials includes:
• spacing rows of drums to allow for a visual inspection of
each container for corrosion and leaks;
• stacking containers no higher than recommended by the
manufacturer and in such a way as to minimize the chance
of tipping, tearing, puncturing, or breaking;
• refraining from stacking equipment against containers;
maintaining distance between different types of chemicals
to prevent cross-contamination and reactions;
HAZARDOUS TO
PROTECTION,.
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• providing adequate lighting in all areas where hazardous
substances are stored;
• insulating electrical circuitry and checking it frequently for
corrosion and potential sparking;
• keeping aisles clear of obstructions;
• maintaining a clear, even surface in areas traversed by
personnel and equipment;
• raising drums off the storage area floor to prevent corrosion
through concrete "sweating"; and
• curbing or diking around process storage tanks and waste
storage areas to contain leakage and prevent contamination.
The use of larger containers for chemical storage should be
considered. Alternatives to 55-gallon drums are polyethylene
containers enclosed in rigid wire mesh. These can be constructed
to hold up to six times the capacity of a 55-gallon drum, are
portable, reusable, and can be outfitted fortop or bottom discharge,
cleaning access, and locking.
Loss Prevention Practices
Loss prevention practices reduce the probability of a product
spilling. A long term, slow release spill is often difficult and time
consuming to find, and may be very costly in terms of product lost
and cleanup costs. Besides the economic concerns, spills are a
health and environmental hazard. Studies to implement preven-
tive and corrective maintenance, emergency response, and spill
prevention programs should be undertaken and the findings incor-
porated into the operating procedures for the plant.
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The probability of a spill can be decreased by:
• conducting hazard assessment studies during the design
and operation phases;
• using properly designed storage tanks and process vessels
only for their intended purposes;
• equipping containers with overflow alarms;
• testing the alarms periodically;
• maintaining the physical integrity of the containers over time;
• setting up administrative controls for all loading, unloading,
and transfer operations;
• installing sufficient secondary containment facilities;
• having a good valve layout;
• having interlock devices to stop flow to leaking sections;
• disallowing operators to bypass the interlock or to alter the
set points;
• isolating equipment or process lines that are not in service;
• documenting the spillages and related dollar values; and
• installing leak detection systems for storage tanks.
The design phase considerations of a maintenance program
include larger access doors, wider internal catwalks, accessible
components, hopper access doors, and duct cleanout and inspec-
tion hatches. Also, keep maintenance costs in mind when ordering
new equipment to reduce corrective maintenance costs in the
future. Preventive maintenance can save three to four times its
cost by reducing equipment breakdown and malfunction.
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Waste Stream Segregation
Hazardous waste sent off site for disposal is often a mixture of two
different wastes. Segregating materials and wastes can decrease
the volume of waste to be handled and disposed. For example,
liquid wastes can be isolated from non-hazardous materials, and
hazardous waste can be isolated according to the major contami-
nants. This results in less waste and easier disposal. Also,
recyclers and waste exchanges are more receptive to wastes that
are not contaminated with other substances. Waste stream
segregation is an easy and effective method for minimizing waste.
• ICI America, Inc. separates their hazardous and non-hazard-
ous wastes and chlorinated and nonchlorinated solvents. In
conjunction with a policy for returning unused chemicals to the
distribution center, these measures saved the company $37,000
in 1984. They were able to reduce the volume of their hazard-
ous waste from 100 drums in 1981 to 60 drums in 1984.
• Martin Marietta A'uminum of Torrance, California, reduced its
cleaning and waste-hauling costs by $50,000 per year by
filtering aluminum particles from soluble oils. The new
waste could be disposed of at a municipal, rather than a haz-
ardous waste, disposal site. Additionally, the oil removed by
the filter is reused, lowering oil purchasing and transporting
costs.
• Daly-Herring Company of Kingston, North Carolina, began
segregating their waste stream by altering their dust collection
equipment. Waste streams containing different organic chemi-
cals are collected separately and each is recycled to the
process from which it originated. The firm has eliminated over
$9,000 in annual disposal costs, and the recovered material is
worth an estimated $2,000 per year.
7.2 Metal Parts Cleaning
Metal parts cleaning is a common concern of many industries. This
section details some general routines of good operation and some
specific waste minimization practices for metal parts cleaning.
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7.2.1 Waste Description
The specific wastes associated with metal parts cleaning, along
with their sources, are listed in Section 7.2.3. The waste produced
is generally not dependent of the type of method; rather, it depends
on the cleaning material used and the type of soil removed.
7.2.2 Good Operating Practices for Waste Minimization
Good operating practices for waste minimization are defined as
procedural or institutional policies which result in a reduction of
waste, and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
A detailed discussion of good operating practices is provided in
Section 7.1.
7.2.3 Specific Waste Minimization Practices
Spent abrasives, solvents, acid and alkaline cleaning solutions,
and rinse water are the most common wastes from metal parts
cleaning. All but the solvent wastes are extremely diluted with
water. The most common waste minimization practices which can
be applied to these wastes include:
Waste stream Minimization practice
Abrasives Use water-based binders
Use liquid spray compositions
Control the water level in equipment
Solvent cleaners See Section 9.1
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Acid and alkaline Remove sludge frequently or
cleaners continuously.
Install lids on tanks.
Implement betteroperating practices.
Rinse waters Operate rack system properly.
Operate barrel system properly.
Operate rinse tanks properly.
Install water sprays on rinse tanks.
Install fog nozzles on heated tanks.
Use chemical rinsing.
Use deionized water for rinsing.
Each of these waste minimization practices, (except those for
solvent cleaners which are discussed in Section 9.1) are briefly
described in the following sections.
Abrasive Wastes
Abrasive wastes can be reduced by using waste minimization
practices such as:
Using water-based binders. Water-based or greaseless binders
should be used for polishing and buffing. These leave the wheel
clean and dry, while oil-based binders often cause it to burn,
necessitating an additional cleaning using an alkaline soak. Also,
greaseless compositions adhere to the wheel surface better to
increase wheel life.
Using liquid spray compositions. Most abrasives are applied
to the wheel in bar form, with the bar held against the wheel during
application. This often leads to the application of an incorrect
amount of abrasive. An automatic liquid spray system ensures that
the optimum amount of abrasive is always maintained on the
wheel. This reduces or eliminates:
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• wheel wear due to compound deficiency,
• compound waste due to over-application, and
• the requirement for subsequent cleaning (spray compounds
are usually water-based).
Controlling water level In the equipment. Ensuring that enough
water is used during the cleaning process decreases the rate of
attrition of the abrasive and decreases replacement frequency.
Similarly, if not enough water is used, items exiting the equipment
will be dirty.
Alkaline and Acid Cleaning Solutions
Methods for minimizing waste from alkaline and acid cleaners
include:
• removing sludge frequently, and
• improving operating practices.
• Waterloo Industries, Inc. of Waterloo, Iowa, installed a
separator unit designed to continuously remove sludge and
particulate matter from the alkaline bath. Since installation,
replacement chemical costs have decreased by 20 percent,
the time interval between dumping and total cleanout of the
system has increased from 4 to 13 weeks, and maintenance
has been reduced—a pump is the only moving part in the
cleaning process. This system can also be applied to
solvent cleaning operations.
Rinse Water
Conserving water is an effective way to cut operating and capital
costs. Reductions can be realized in the amount of water initially
needed and in the amount of cleaning solution dragout. A detailed
description of rinse water minimization practices is provided in
Section 8.3.4.
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7.3 Paint Application
Paint application is a common concern of many industries. This
section discusses some general routines of good operation, and
some specific waste minimization practices for paint application.
7.3.1 Waste Description
The specific wastes associated with paint application technologies
are listed in Section 7.3.3. The industry is extremely diverse, so the
quantity of each waste produced varies greatly from operation to
operation.
7.3.2 Good Operating Practices for Waste Minimization
Good operating practices for waste minimization start with proce-
dural or institutional policies which result in a reduction of waste,
and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be implemented in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
7.3.3 Specific Waste Minimization Practices
Wastes from parts cleaning, paint application, paint stripping, and
equipment cleaning are the most common hazardous wastes from
painting operations. The most common waste minimization prac-
tices which can be applied to these wastes are:
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Waste sream
Parts cleaning
Paint application
Paint stripping
Minimization practice
Equipment
cleaning wastes
See Section 7.2, Wastes
Use equipment with low overspray.
Implement better operating practices.
Implement proper painting techniques.
Implement proper cleaning techniques.
Use mechanical paint stripping system.
Use non-phenolic/non-acid stripper.
Implement better operating practices.
Use equipment with low over-spray.
Implement better operating practices.
Referto Section 7.2 for adiscussion of parts cleaning wastes, since
methods are specific to the process involved. A discussion of each
of the other wastes follows.
Most of the procedures outlined below fall under the category of
housekeeping procedures. Proper equipment operation, person-
nel training, and improved scheduling require minimal capital out-
lays and no additional equipment, only a company-wide commit-
ment to waste minimization.
Paint Application Wastes
Paint application wastes can be reduced by using waste minimiza-
tion practices such as:
Use equipment with low overspray. Most paint application
wastes are caused by eitheroverspray orthe paint not reaching the
target. The amount of overspray experienced is a function of the
design and operation of the system used. The efficiency of several
systems in avoiding overspray is listed below.
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System Efficiency(%)
Conventional air-atomized spray 30-60
Conventional pressure-atomized spray 65-70
Electrostatic air-atomized spray 65-85
Electrostatic centrifugal-atomized spray 85-95
Roller/flow coating machines 90-98
Electrocoating systems 90-99
implement better operating practices. These play a large role
here, since spray systems are often manually operated. Keeping
the air pressure low and the spray gun perpendicularto the surface
add several degrees of accuracy to the system by avoiding over-
spray. Proper training of operators and all who work with the
system promotes waste minimization.
The likelihood of producing a bad finish is reduced when applica-
tion equipment is operating properly. Therefore, preventive main-
tenance is extremely important. All parts should be cleaned, and if
necessary, lubricated regularly.
Paint Stripping Wastes
Paint stripping wastes are generated when a bad finish has been
produced and the coating must be removed to be reapplied. Many
paint stripping wastes are generated due to failure of part of the
system. Waste minimization methods are aimed at reducing the
number of poor quality products produced. Following are some of
these methods.
Inspect parts before painting. This will avoid painting potential
rejects. Be sure surfaces are clean, dry, and rust free.
Implement proper paint application techniques. This will avoid
unnecessary overspray.
Implement proper cleaning techniques. Efficiency is higher
when equipment is cleaned regularly.
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Use mechanical (cryogenic) paint stripping methods. Facili-
ties handling items made of soft metals which are inappropriate for
sandblasting or glass beadblasting have had great success with
plastic bead blasting. High pressure air is used to propel the plastic
beads against the paint surface, where they dislodge the paint. The
beads and paint are then recovered and separated, with the beads
being re-fed into the pressure gun. The dry waste, composed of the
paint and any beads broken down due to attrition, is then removed
for proper disposal. The U.S. Department of Defense estimates
that if all DOD facilities would install this system the cost would be
$13 million and the annual savings would be $100 million. The
waste produced would drop from 7 million gallons of paint stripper
waste and 100 million gallons of wash water to 500,000 pounds of
dry waste annually.
Use non-phenolic strippers. These were developed in response
to the need to reduce toxicity associated with phenol and acid
additives.
Locate solvent soak tanks away from paint curing ovens. This
will minimize the adverse effect of solvent on a painted surface or
item.
Equipment Cleaning Wastes
Equipment cleaning wastes can be reduced by using waste mini-
mization practices such as:
Use equipment with low overspray. By increasing the accuracy
of the paint application system, less spray will fall on the machinery.
Implement better operating practices. The amount of equip-
ment cleaning waste generated is directly related to the number of
times color or type changes are made. For this reason, scheduling
improvements have perhaps the largest effect on the volume of
equipment cleaning waste produced. By making large batches of
similarly produced items, instead of small batches of custom items,
the time between cleanings can be increased. Additionally, since
1989 mm CHMR
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the need for cleaning is based on the paint application process, all
measures described during the discussion of paint application
wastes apply here as well.
7.4 Process Equipment Cleaning
Process equipment cleaning is a common concern of many indus-
tries. This section details some general routines of good operation
and some specific waste minimization practices for process equip-
ment cleaning.
7.4.1 Waste Description
Wastes generated during the periodic cleaning of internal surfaces
of process equipment differ widely in composition and quantity
depending upon:
• type of deposit being cleaned,
• type of cleaning fluid,
• type of cleaning method,
• size of equipment being cleaned, and
• cleaning frequency.
7.4.2 Specific Waste Minimization Practices
There are two distinct approaches which can be taken to effect
a waste minimization program in process equipment cleaning.
These are:
• reducing the frequency of the cleanups, and
• reducing the quantity and/or toxicity of wastes.
1989 HHCHMR
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Here are the most common waste minimization practices.
Approach Minimization practice
Reduce cleaning Use proper plant and equipment design.
frequency Record cleaning costs as a separate
item.
Convert batch to continuous process.
Maximize dedication of equipment.
Avoid unnecessary cleaning.
Inhibit fouling deposit formation.
Reduce quantity Minimize residues.
and/or toxicity of Minimize the amount of cleaning of
cleanup wastes solution.
Carefully choose the cleaning medium
and plan cleaning solution reuse.
Reducing Cleanup Frequency
Reducing or eliminating the need for cleanup begins by identifying
the causes of undesirable deposit formation, followed by identify-
ing and implementing the following suggested means to prevent or
limit it.
Use proper plant and equipment design. The plant should be
designed to minimize the equipment surface exposed to the
process fluid. Undrainable pockets should be kept to a minimum.
Record the cleaning costs as a separate item. If cleanup costs
are not separated from other maintenance costs, proper analysis
of these costs and the relative worth of different alternatives cannot
be determined.
© 1989 ••• CHMR
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Convert from batch to continuous process. Continuous proc-
esses have many advantages over batch processes. These in-
clude:
• lower labor requirements,
• ease of automation and control,
• elimination of the need for manual material transfer opera-
tions which tend to have a high probability of a spill, and
• less cleanup waste since continuous processes are cleaned
at regular intervals while batch processes must be cleaned
before every batch of different materials.
Maximize dedication of process equipment. Producing large
quantities of a product at one time through proper scheduling can
decrease the cleaning frequency and the down time for a piece of
equipment. In many industries, manufacturers produce a year's
supply at one time.
Avoid unnecessary cleanup. If a piece of equipment is dedi-
cated, it should not stay on the same cleaning schedule as
undedicated equipment.
Inhibit fouling deposit formation. Fouling rates are usually at-
tributed to:
• crystallization,
• sedimentation,
• chemical reactions and polymerization,
• high temperature cooking,
• corrosion, or
• bacterial growth.
Fouling most closely associated with heat transfer will reduce the
overall efficiency of equipment while increasing the need for
cleaning. Fouling can be most easily inhibited by:
1989 •MCHMR
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• the use of smooth heat transfer surfaces,
• lower film temperatures or increased turbulence,
• control of steam composition,
• careful choice of heat exchanger type,
• prior removal of deposit precursors,
• the application of less corrosive and more thermally stable
heat transfer fluids, and
• better design or control of fired heaters.
In closed cooling water systems, the fouling rate can be inhibited
through proper water treatment, by using a lower number of
concentration cycles in the cooling tower, and by using make-up
water with low total solids content.
Reducing the Quantity and Toxicity of Cleanup Waste
When equipment must be cleaned, the cleanup should be per-
formed efficiently with the minimum production of additional haz-
ardous wastes.
Minimize residue. Since the ultimate amount of sludge produced
depends on the residue left after the process, minimizing the
residue will decrease the amount of waste produced. This can be
done by:
• providing adequate batch drainage time,
• using non-stick surfaces,
• using mechanical or manual wall wipers,
• using cylindrical tanks with height-to-diameter ratios close
to one (1) to minimize wetted surface,
CHMR
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• rotating agitator after batch dump, and
• maximizing batch size.
Minimize the amount of cleaning solution. Mechanical clean-
ing should be used over chemical cleaning whenever possible.
When chemical cleaning solutions are used, the four parameters
to control are time, temperature, concentration, and turbulence.
Less cleaning solution is necessary as these parameters are
increased. Cleaning solution used can be minimized by the use of:
high pressure spray nozzles,
"flow-over" techniques,
on-stream mechanical cleaning,
clean-in-place (CIP) system with staged rinses, and
additives such as defoamers, suspending agents,
emulsifiers, and wetting agents.
The elimination of cleaning solutions altogether is possible by
cleaning equipment with mechanical devices. One such device is
a system which uses steel brushes fitted inside heat exchanger
tubes which are propelled by process fluid and reversed periodi-
cally by a flow diverter.
Choose cleaning medium and plan cleaning solution reuse.
From a waste minimization standpoint, the preferred orderto select
a cleaning medium is (1) process fluid rather than water, and (2)
water rather than chemical solutions. By employing a simple
filtration to remove the solids, process-based cleaning solutions
can be reused as part of the formulation or process make-up
stream. Also, water and water-based cleaners are usually non-
toxic or at least less toxic than most chemical solutions.
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CHAPTER
8.0 INDUSTRY-SPECIFIC WASTE
MINIMIZATION PRACTICES
This chapter provides detailed information and examples of the
waste minimization practices which can be applied to specific
industrial categories. It illustrates how companies in 11 major
industries can economically minimize their wastes. Each of the fol-
lowing industries is examined individually so that you can refer to
the sections which best apply to your business.
Section 8.1
Section 8.2
Section 8.3
Section 8.4
Section 8.5
Section 8.6
Section 8.7
Section 8.8
Section 8.9
Section 8.10
Section 8. 11
Vehicle Maintenance
Fabricated Metal Manufacturing and
Metal Finishing
Electroplating
Printed Circuit Board Manufacturing
Dry Cleaning and Laundries
Printing
Photography
Construction
Educational and Vocational Shops
Analytical and Clinical Laboratories
Pesticides
The purpose of this chapter is to provide specific waste minimiza-
tion practices which are normally applied only to manufacturing
processes unique to the industry category described. Many
specific waste minimization practices can be applied to activities
(such as metal parts cleaning) which are common to several indus-
tries. Such minimization practices are described in detail in
Chapter 7. In addition, Chapter 7 provides information on good
operating practices which can also be applied to almost every
waste stream and in every industry.
Many industries also produce common waste types, such as sol-
vents, metal bearing sludges, and corrosive wastes. Useful waste
minimization practices and recycle/recovery options forsuch wastes
which are common to several industries are fully described in
Chapter 9.
1989
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8.1 Vehicle Maintenance
8.1.1 Industry Description
The vehicle maintenance industry includes a broad range of busi-
nesses. Typically included in this industry are businesses that
repairer maintain:
• cars,
• vans,
• trucks,
• heavy equipment, and/or
• farm equipment.
These businesses are generally involved in these maintenance or
repair activities:
• removing oil or grease;
• removing rust, dirt, or paint;
• repairing or rebuilding engines;
• refinishing or restoring vehicles;
• painting vehicle bodies; and/or
• replacing lead acid batteries.
8.1.2 Sources of Waste
Almost every aspect of vehicle maintenance operations involves
some form of hazardous waste. Some of the most common
include:
• rust removers — contain concentrated aqueous solutions;
• carburator cleaners — contain flammable or combustible
liquids;
• used rags — contain flammable or combustible solvents;
• paints — contain flammable or combustible thinners or
reducers; and
• auto and truck batteries — contain strong acids or alkalies
and lead.
©1989 mm CHMR
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Typical processes which generate hazardous wastes and their
associated wastes include:
Process/operation
Oil/grease removal
Engine parts/
equipment cleaning
Rust removal
Paint preparation
Painting
Spray booth, spray
guns, brush cleaning
Paint removal
Used lead acid
Waste generated
Ignitable waste, spent solvents, com-
bustible solids, waste acid/alkaline
solutions
Ignitable waste, spent solvents,
combustible solids, waste acid/alka-
line solutions
Waste acids, waste alkalies
Spent solvents, ignitable wastes, ignit-
able paint waste, paint wastes with
heavy metals
Ignitable paint wastes, spent solvents,
paint wastes with heavy metals, ignit-
able wastes
Ignitable paint wastes, heavy
metal paint wastes, spent solvents
Ignitable paint wastes, heavy metal
paint wastes, spent solvents
Used lead acid batteries, strong acid/
alkaline solutions
8.1.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as being procedural or
institutional policies which result in a reduction of waste and may
include:
)1989
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• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
8.1.4 Specific Waste Minimization Practices
The four main waste streams from the vehicle maintenance indus-
try include:
• work cleaning wastes,
• solvents,
paint wastes, and
oils.
All of the waste minimization practices which can be used by the
vehicle maintenance industry are similar to those which can be
used in many other industries and include:
Common
waste stream
Work cleaning
wastes
Paint wastes
Solvents
Oils
Primary process
waste description
Spent alkaline cleaning
solution, spent acid
cleaning solution
Ignitable paint wastes,
paint wastes with heavy
metals
Spent solvents from oil/
grease removal, paint
preparation, and paint
removal
Waste oils from oil
changes
Minimization
practice
See Section 7.2
See Section 7.3
See Section 9.1
See Section 9.6
' 1989
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A detailed discussion of the waste minimization practices for each
of these waste streams is provided in the other sections of this
manual.
Work Cleaning Wastes
Work cleaning wastes from vehicle maintenance shops are similar
to the cleaning wastes produced in many other manufacturing
processes. A detailed discussion of waste minimization practices
for cleaning wastes is provided in Section 7.2, Metal Parts Clean-
ing.
Paint Wastes
Paint wastes generated by vehicle maintenance shops are similar
to those generated in other industries. A detailed discussion of
waste minimization practices for paint wastes is described in
Section 7.3, Paint Application.
Spent Solvents
Spent solvents generated in vehicle maintenance shops are simi-
lar to those found in other industries. A detailed description of the
minimization of spent solvent wastes is found in Section 9.1,
Solvents.
Oils
There are several oil loss minimization practices and oil recycling
technologies that would be useful for minimizing waste oil. A
detailed discussion of waste minimization practices for waste oil is
provided in Section 9.6, Oils.
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8.2 Fabricated Metal Manufacturing and Finishing
8.2.1 Industry Process Description
Fabricated metal manufacturers and metal finishers utilize numer-
ous and varied industrial processes during the production of
fabricated metal products. Because of the large amount of waste
minimization information applicable to these processes, as well as
the fact that metal finishing operations are often performed inde-
pendently from the manufacturing process itself, this chapter will
be divided into industry-specific subsections—distinguishing metal
manufacturing from metal finishing activities.
Fabricated Metal Manufacturing
Fabricated metal manufacturers include those producing electrical
and non-electrical machinery, furniture, transportation equipment,
and other metal equipment and supplies for industrial, commercial,
and household use.
The processes used to manufacture metal products include, but
are not limited to:
• cutting • painting/enameling
• machining • welding
• grinding • buffing/polishing
• die sinking • cleaning/degreasing
Metal Finishing
The metal finishing industry consists of those firms involved in the
physical or chemical modification of metal surfaces to impart
particular characteristics to the material, e.g., reducing surface
reactivity; increasing corrosion resistance, strength, or conduc-
tance; or producing desired textures or colors.
The many different processes utilized by the industry are dictated
by the specifications of the product manufacturers and include:
• heat treating • electroless plating
• electroplating • chemical conversion coating
©1989 •MCHMR
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• anodizing • etching
• galvanizing • chemical milling/hardening
Surface treatment processes are generally batch operations which
include three basic steps: surface preparation/cleaning, surface
treatment, and rinsing or postfinishing operations.
8.2.2 Sources of Waste
Wastes generated by both the fabricated metal manufacturing and
metal finishing industries fall into eight major categories:
• spent solvents/solvent still bottoms,
• paint wastes with heavy metals,
• strong acid and alkaline wastes,
• other ignitable and reactive wastes,
• plating and stripping solutions,
• waste oils,
• heavy metal waste water sludges, and
• metal dusts, grindings, and cuttings.
Specific information relating wastes to sources (processes) is
shown in Tables 8-1 and 8-2.
8.2.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste and may include:
• personnel practices,
• procedural measures,
• waste stream segregation, and
• loss prevention practices.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
@198d ••CHMR
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8.2.4 Waste Minimization Practices—Metal Manufacturing
Table 8-1 outlines the major operations/processes involved in fab-
ricated metal manufacturing, the waste streams which result from
these operations, and the waste minimization practices which are
most applicable to them.
Waste minimization techniques for most of these waste streams
generally fall into one of three categories: process changes, better
operating practices, and material/product substitutions. Since
these are discussed in detail elsewhere in this manual (primarily in
Chapter 7), they will not be repeated here. However, the minimi-
zation practices suitable for metal machining and cutting wastes
are fairly specific to the manufacturing equipment used in this
industry and will be briefly discussed below.
Standardize oil types used on machining equipment. Use of
the same type of oil for as many operations as possible (e.g., ma-
chining, turning, lathing) will facilitate reuse/recycling activities by
eliminating the need for segregation of used oils which are re-
moved from equipment.
Use dedicated lines or improve equipment scheduling to
reduce waste oil generated. If different oils are required for work
with different metals, the amount of waste oil generated from
equipment cleanouts can be decreased by either dedicating par-
ticular equipment to use with a specific metal or adjusting the
scheduling of equipment use.
Reuse or recycle cutting, cooling, and lubricating oils. There
may be certain instances in which these oils can be continually
collected and reused until they are completely consumed without
ever being treated. For those requiring some filtration or other
reclamation technique priorto reuse, segregating the oil types may
decrease the amount of treatment necessary and increase the
quality of the recycled product.
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Table 8-1. Fabricated metal manufacturing wastes.
Process origin Waste stream Control methodology
Metal cutting/
machining
Waste oils
Grinding/buffing/
polishing
Heavy metal
wastes, dust, and
sludge
Spent solvents
Spent abrasives
Cleaning/
degreasing
Spent alkaline/
acid parts cleaners
Spent solvent
cleaners
• Standardize oil types
used on machining equip-
ment.
' Improve equipment
scheduling/establish
dedicated lines.
•Reuse or recycle cutting,
cooling, and lubricating oils.
•Substitute lime or borax
soap for lubricating oils.
• Centrifuge oil/scrap metal
mixtures.
Segregate scrap metal.
• See Cleaning/Degreasing
category below.
• Use water-based or grease-
less binders.
• Use an automatic liquid
spray system for application
of abrasive onto wheel.
• Ensure sufficient water use
during cleaning.
• See Section 7.2.2.
• Use deionized water to pre-
pare solutions.
• Remove sludge frquently/
continuously
•Install lids on tanks.
• Use water sprays/fog
nozzles.
• Implement better operating
practices.
• See Section 7.2.2.
•Install lids/silhouettes on
tanks.
• Increase freeboard space on
tanks.
> 1989
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Process origin
Table 8-1. (continued)
Waste stream Control methodology
Painting/
Enameling
Spent alkaline/
acid parts cleaners
Waste paint
Spent solvents/
strippers
Solvent vapors
•Install freeboard chillers on
tanks.
• Remove sludge from sol-
vent tanks frequently.
• Extend solvent life by pre-
cleaning parts by wiping,
using air blowers, or pre-
dipping in cold mineral spir-
its dip.
• Reclaim/recover solvent on-
or off-site.
• Substitute less hazardous
solvent degreasers (e.g.,
petroleum solvents instead
of chlorinated solvents) or
ajkali washes where pos-
sible.
•Slow speed of parts re-
moval from vapor zone.
• Rotate parts to allow con-
densed solvent drop-off.
• See Section 9.1.
• See above.
•Use equipment with low
overspray.
• Implement better operating
practices.
• See Section 7.3.2
• Substitute water based,
high solids, or powder coat-
ings for solvent-based
ones.
• Substitute bead for solvent
strippers.
• Implement better operating
practices.
• See Section 7.3.2.
• Use solvent recovery or in-
cineration to reduce VOC
emissions fromcure ovens.
• See Section 7.3.2.
1989
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Substituting lubricating oils with lime or borax soap. It may be
possible to use a hot lime bath or borax soap to replace the use of
lubricating oils as drawing agents in certain types of manufacturing
operations. This option would not only eliminate the waste oil
produced, but would also eliminate the degreasing process which
follows.
Centrifuging oil/scrap metal mixtures. If large amounts of oil/
scrap metal wastes are generated from the manufacturing proc-
ess, centrifuge equipment is available to extract most of the oil from
the mixture for eventual recycling. Sludge extractors, or "chip
wringers," separate the oil through a high speed spinning action,
then collect and filter it for reuse. The cost of such units ranges from
$11,000 to $23,000.
Segregation of scrap metal. Segregation of different metals may
increase both the market and price received for scrap metal
recovery.
8.2.5 Waste Minimization Practices—Metal Finishing
Some of the waste minimization options that are identified in Table
8-2 apply to the various processes used in the metal finishing
industry, and are discussed in more detail elsewhere in this
manual. A reference to the appropriate section is provided—either
Section 8.3, Electroplating or Section 8.4, Printed Circuit Board
Manufacturing. In fact, these two industries are actually parts of the
fabricated metal manufacturing and finishing category.
The remaining waste minimization practices are briefly discussed
below. Heat-treating wastes have been accorded their own sub-
section because there are several waste streams and minimiza-
tion options which are unique to the heat-treating process and
warrant specific mention. For purposes of this discussion, all other
metal finishing activities and processes produce wastes which can
be grouped into the general categories of spent bath solutions,
waste rinse water, filter wastes, spills and leaks, and stripping
wastes. There is a subsection provided for each.
®1989 MHCHMR
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Heat-Treating Wastes
Replace cyanide and barium salt baths with alternative treat-
ment methods. Some case-hardening methods that use cyanide
or barium can be replaced by other methods like heat treatment.
The choice of an appropriate substitute method will depend on the
type of steel being treated, the degree of hardness required, and
the end use of the manufactured product. Some alternative treat-
ment methods are discussed below.
• The gas phase carbonitriding process can be used with
steels containing chromium, molybdenum, or aluminum.
This process employs ammonia gas, which is heated to de-
composition, producing nascent nitrogen. The nitrogen
combines with carbon and diffuses into the metal surface.
The ammonia process is not quite as flexible in application
as cyaniding, however, and may not be suitable for jobs
requiring the simultaneous treatment of small batches with
different cycle times. It also requires a higher heating rate
than cyaniding.
• Carborizing techniques may also substitute for cyaniding.
Atmospheric carbon, or a carbonate/chloride carbon mixture
may be used to achieve the desired hardening effect.
• A developmental ion beam processing technique may provide
an effective alternative to heat-treating methods of case hard-
ening once it becomes suitable for commercial applications.
The method employs a high energy ion beam to implant ions in
the surface of the material to be treated.
Use more dilute process solutions. Typical cyaniding bath so-
lutions contain approximately 30 percent sodium cyanide, al-
though some facilities use 45, 75, and 92 percent solutions. For
those facilities, limiting cyanide content to the 30 percent range
would reduce the toxicity of any spent bath solutions generated.
Recycle oil quench baths by filtration. On-site filtering of metals
from quench bath oil would prolong the useful life of the baths and
reduce the amount of oil which must be sent for disposal.
1989 HMCHMR
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Replace solvent washes with alkali washes. Solvents used for
oil removal from treated parts could be replaced with alkali washes
which can achieve the same effect. This would eliminate the
complications involved with the management of spent solvent
degreasing solutions.
Extend life of alkali wash by removing oil layer. A skimmercan
remove the oil layer from the wash. The material collected is then
routed to an oil/water separator, where the oil is collected for
eventual reclamation and the water is sent for treatment with other
process waste waters.
Spent Bath Solutions
Metal/acid recovery from spent baths. There are several tech-
niques, in various stages of development, which will accomplish
the removal of metals or the recovery of acids from spent bath
solutions. These methods can reduce the hazardous nature of the
waste streams, thereby decreasing the amount of pretreatment
required and decreasing the amount of waste treatment residues
generated. Various technologies to recover metals and acids are
discussed in detail in Section 9.3, Metal Wastes and Section 9.4,
Corrosive Wastes.
Spray/brush items instead of immersing in process solutions.
The practical use of both spray and brush methods for applying
process solutions depends upon the type of operation and the
shape of the object being treated. However, their use wherever
possible will result in more efficient use of process solutions and
result in a reduction in the amount of waste solution generated.
Use alternative treatment techniques. There are three alterna-
tive treatment techniques briefly discussed below which have
various applications throughout the metal finishing industry. All of
them would result in the elimination of certain process solutions,
thereby reducing the amount of waste generated.
• Nickel, aluminum, and other metals have been applied to
substrates using vacuum evaporation methods. An electron
1989
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Table 8-2. Metal finishing wastes.
Process origin Waste stream Contol methodology
Heat-treating
Electroplating/
anodizing/
Metal finishing
(electroless
plating, chemical
etching, chemical
milling)
Spent cyanide
or barium salt
solution from salt
bath pot cleaning.
Quenching oils
and bath residues.
Spent solvent
degreasers.
Alkali wash wastes.
Quenching waste-
water treatment
sludges.
Cleaning solutions.
Spent plating
solutions/sludges.
Waste rinse waters.
Treatment wastes.
Spent bath
solutions
Waste rinse water
• Replace cyanide or barium
salt baths with alternate
treatment methods.
• Use more dilute process
solutions.
• Recycle oil quench baths by
filtration.
• Replace solvents with alkali
washes.
• Extend useful life of alkali
wash by removing oil.
• See Section 8.3.4.
• See Section 8.3.4 on
options for the electro-
plating industry.
• Extend bath life (Section
8.3.4).
• Recover metal/acid from
spent baths.
• Spray/brush items instead
of immerse.
•Use thinner foil for printed
circuit boards. (Section
8.4.4)
• Use alternative treatment
techniques.
• Use less toxic process sol-
utions. (Sections 8.3.4 and
8.2.5)
• Use more dilute process
solutions (Sections 8.3.4)
• Use better operating
practices.
• Reduce dragout of solution
from tank (Section 8.3.4)
• Employ effective rinsing
methods (Section 8.3.4)
•Use immiscible rinses.
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Process origin
Table 8.2 (continued)
Waste stream Contol methodology
Filter wastes
Spills and leaks
Stripping wastes
• Use no-rinse coatings.
• Reuse and recycle spent
rinse water (Sections 8.3.4
and 8.2.5).
• Replace hexavalent chrom-
ium with trivalent (Section
8.3.4).
• Use still rinsing technique
(Section 8.3.4)
• Reclaim metal from rinse
water wastes (Sections
8.3.4 and 9.3).
•Change rinse composition.
• Minimize process water
use.
• Use better operating
practices.
1 Reclaim metal from solid
waste (Sections 8.3.4
and 9.3).
• Effectively dewater solids
(Section 8.3.4).
• Use better operating
practices.
1 Use non-chrome etchants.
1 Reduce generation of off-
spec coating.
beam evaporates metals at low pressures, producing a metal
vapor which condenses onto the product to be coated. How-
ever, coating costs are high and thickness of the coating
applied is difficult to control.
Ion-plating methods can be substituted for electroplating of
chromium and cadmium onto steel. Depositing metals are
evaporated by high energy ion bombardment and condense
onto the steel surface. Although not common in the U.S., this
method is used extensively in Japan.
1989
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• Chemical vapor deposition is another alternative method of
coating application. Employing the same vaporizing/con-
densation principle as the two previous methods, this tech-
nique would be effective for most coating operations, although
its use is currently limited to the semiconductor industry.
Use of less-toxic solutions. One example of this method is the
substitution of polysiloxanes for water-soluble metal/cyanide com-
pounds in electroless copper plating. Polysiloxanes have been
found to function as effective stress relievers, and result in less
hazardous spent bath solutions. An example of these compounds
is SF-96, a silicon fluid manufactured by General Electric.
Use of better operating practices. The three methods men-
tioned below minimize waste bath solutions generated by prolong-
ing or extending the life of the process solutions used.
• Frequent monitoring of bath solution activity and regular re-
plenishment of reagents or stabilizers can increase process
solution life. Electroless copper plating baths can be effectively
stabilized with methanol or 2-mercaptobenzothiozole.
• Good control of solution temperature can also result in an
increase in bath life. This can be achieved by periodic
cleaning of cooling/heating coils, or switching to the use of
jacketed tanks instead of coils.
• Limiting the amount of time process solutions are in storage
prior to use will reduce the possibility that these solutions will
degenerate, thereby producing contaminants which shorten
bath life.
Waste Rinse Water
Use of immiscible rinses. For rinsing, the use of solvents immis-
cible in water would facilitate the recovery and reuse of the rinses.
This would eliminate the generation of waste rinse waters requiring
treatment. However, there are disadvantages to this option, such
as the potential for increased air emissions and the need to dispose
of solvent residues from on-site reclamation operations.
©1989 •MCHMR
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Use of no-rinse coatings. Chromate conversion coatings requir-
ing no subsequent rinsing have been developed for applications to
steel, galvanized steel, and aluminum. The method has been used
primarily for coil coating, but its application is not limited to that
industry. Disadvantages include the need for very efficient control
of the process due to the high speed of the operation, the high cost
and difficulties involved in conversion of existing facilities to this
type of process, and the lack of FDA approval for the use of no-rinse
coatings in food container or equipment applications.
Reuse and recycling of spent rinse water. The following sug-
gestions may substantially reduce the amount of waste process
waters sent for pretreatment, and correspondingly reduce the
amount of treatment residues generated.
• In the chromate process, the first rinse, which is highest in
chromic acid, can be recycled to the chromating tank. The last
rinse can be routed through an ion-exchange resin to remove
contaminants before reusing the water in the rinsing process.
Evaporators can achieve the same results. Concentrate from
the evaporator can be recycled to the coating bath, while the
vapor can be condensed and returned to the rinsing solutions.
• Techniques to recover metals from rinse water include:
- evaporation,
- reverse osmosis,
- ion exchange,
- electrolytic metal recovery, and
- electrodialysis.
Many companies have installed such systems to recover metals
from waste rinse water and have found the investment has paid for
itself in 1 to 5 years. Section 9.3.2 provides a detailed description
of these metal recovery techniques and provides some examples
of where they have been successful.
Change rinse composition. If possible, the composition of the
rinse solutions should be altered so that they are less hazardous.
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For example, the final rinse after a zinc-based phosphating bath is
usually a dilute chromic acid solution. The toxicity and environ-
mental controls associated with the presence of chromium in a
solution have prompted some companies to develop chrome- free
rinses.
Minimize process water use. Reusing waste rinse waters in
other operations would reduce the overall amount of waste water
generated. For example, fume scrubber water, cooling water, or
steam condensate may be used for this purpose if production
standards or economics allow.
Better operating practices. The segregation of waste rinse wa-
ters may facilitate reuse or recycling of them, and may ease any
metal reclamation efforts being employed.
Filter Wastes
There are two main sources of filter wastes generated from metal
finishing activities. Solid wastes in the form of metallic salts are
deposited onto solution filters, and metallic sludges are generated
during waste-water treatment operations such as pH adjustment
and clarification. Filter wastes are sometimes drained of water prior
to disposal or reclamation. Various metal recovery methods, as
well as sludge dewatering techniques, are discussed in Sections
8.3.4 and 9.3.
Spills and Leaks
Better operating practices. Discharges from tank overflows, fail-
ure of valve closures, and leaking gaskets and piping can be con-
trolled or eliminated by the installation of splash guards, drip
boards, float valves, alarm systems, or liquid level controllers. The
institution of certain good housekeeping practices can serve the
same purpose. Such measures include the periodic inspection of
process equipment and piping, and the periodic relining of tanks.
In addition, it is important to emphasize the subject of controlling
waste generation when employees undergo training.
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l<
Stripping Wastes
Use of non-chrome etchants. If compatible with the surface treat-
ment being applied, ferric chloride or ammonium persulfate solu-
tions should replace chromic or sulfuric acid etchants to reduce the
toxicity of any waste stripping solution generated.
Decrease generation of off-spec coatings that require strip-
ping. This can be accomplished primarily through the application
of better ope rating practices, paying particular attention to process
quality control measures, and employee training.
8.3 Electroplating
8.3.1 Industry Process Description
Electroplating is a process in which metal is coated with one or
more other metals by electrodeposition. Electrodeposition is
achieved by passing an electric current through a solution contain-
ing dissolved metal ions and the metal object to be plated. This
results in the deposition of the dissolved metal ions onto the surface
of the object.
An electroplating process generally calls for moving the object to
be coated (workpiece) through a series of baths arranged in a
carefully designed sequence. Typically, the sequence consists of
cleaning, rinsing, and a number of alternating electroplating and
rinsing steps. The workpiece can be carried on racks or in barrels.
8.3.2 Sources of Waste
From a waste minimization standpoint, the ten primary electroplat-
ing process wastes can be grouped to reflect only four different
process origins:
• work cleaning wastes,
• spent plating solutions/sludges,
• waste rinse water, and
• treatment wastes.
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Some or all of the ten waste types may be combined into a single
stream before treatment and disposal. A description of the ten
primary process wastes organized according to these four com-
mon process origins is provided later in this section in Table 8.3.
Contaminated rinse water accounts for a majority of waste pro-
duced. Rinse water is used to remove the drag-out from a
workpiece. Drag-out refers to the excess cleaning or plating
solution that adheres to the workpiece surface and is carried out of
the bath along with the workpiece. If the drag-out from one bath is
carried into the next bath it is referred to as "drag-in," and is
considered a contaminant in the later bath.
Spent cleaning and plating solutions are another waste source.
Cleaning solutions may be acidic or basic, and may contain
organics, and heavy metals. Some cleaning solutions may also
contain cyanide. Spent plating solutions contain high concentra-
tions of metals. These solutions are not regularly discarded but
may require purging if impurities build up.
The waste water produced in the electroplating process may
contain a variety of heavy metals and cyanide. The metals are
removed by adding lime or other precipitation agents. The result is
a dilute metal hydroxide sludge, which is thickened and then
disposed of in a landfill.
8.3.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
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Table 8.3. Electroplating industry waste streams and
minimization practices.
Common waste Primary process
streams waste descriptor! Minimization practice
Work cleaning
wastes
Spent plating
solutions
and sludges
Waste rinse
water
Spent alkaline
cleaning solution;
spent acid cleaning
solution; degreaser
sludges from sol-
vent cleaning;
solvent recycle
still bottoms.
Spent plating
solutions;
filter sludges from
electroplating.
Waste rinse
water
See Section 7.2.
• Increase plating solution
life.
• Use non-cyanide plating
solutions.
•Replace cadmium plating
with zinc.
• Replace hexayalent chro-
mium with trivalent.
• Return spent plating solu-
tion to manufacturer.
• Increase solution tempera-
ture.
• Use less concentrated plat-
ing solution.
•Withdraw workpiece slowly
from solution.
• Add wetting agents to
plating solution.
• Position workpiece properly
on rack.
• Recover drag-out of plating
solutions.
•Install multiple rinse tanks.
• Install fog nozzles and
sprays.
• Reuse rinse water elsewhere
in plant.
• Install still rinsing tanks.
• Install automatic flow con-
trols.
1 Use mechanical/air agitation
of bath.
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Common waste
streams
Treatment wastes
Table 8.3 (continued)
Primary process
waste descriptor! Minimization practice
Wastewater
treatment
sludge; vent
scrubber wastes;
ion-exchange
resin reagents
from process
water demineral-
ization.
• Use efficient precipitating
agents.
• Use trivalent instead of
hexavalent chromium.
• Install sludge dewatering
systems.
• Implement better operating
practices.
• Install metal recovery sys-
tems.
8.3.4 Specific Waste Minimization Practices
The most common waste minimization practices which can be
applied to the four main waste streams in the electroplating
industry are summarized in Table 8.3. Each of these waste
minimization practices for the electroplating industry is briefly de-
scribed in the following sections.
Work Cleaning Wastes
Work cleaning wastes from electroplating processes are similar to
the cleaning wastes produced in many other manufacturing pro-
cesses. A detailed discussion of waste minimization practices for
cleaning wastes is provided in Section 7.2, Metal Paris Cleaning.
Spent Plating Solutions and Sludges
Plating solutions are not discarded frequently, but do require
periodic replacement. Descriptions of minimization practices
available for reduction of spent plating waste follow.
Increase plating solution life. The lifetime of a plating solution is
limited by the accumulation of impurities and/or by depletion of
constituents due to drag-out. The build-up of impurities can be
limited by the following techniques:
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• Use purer anodes.
• Reduce drag-in by better rinsing.
• Use deionized or distilled water instead of tap water for
make-up.
• Regenerate plating solution through impurity removal by:
- more efficient filtering of a plating solution; and
- reducing the carbonate concentration in cyanide baths using
a technique developed by the U.S. Army (U.S. Patent
4,365,481), which involves freezing the carbonates out of
solution. A metal box containing dry ice and acetone is
immersed in the plating bath. Carbonates are precipitated
directly onto the outside metal surface of the box which is then
removed and the carbonates scraped off the box and dis-
carded as solid waste.
• Properly design and maintain rack. Corrosion and salt deposits
on the rack will contaminate plating solutions by chipping and
falling into the solution.
Replace cyanide plating solutions with cyanide-free solutions.
A cyanide-zinc solution was replaced with a non-cyanide, non-
chelated alkaline zinc solution. Other cyanide-free zinc solutions
along with cyanide-free pyrophosphate copper plating solutions
have been used. Such replacements often require upgrading of
the cleaning techniques used because non-cyanide replacements
may require a much more thoroughly cleaned surface to ensure
high quality plating. Military contracts often specify the use of
cyanide solutions, thereby preventing the use of non-cyanide
replacements.
Replace cadmium-based plating solutions with zinc solutions.
The use of cadmium has been replaced with zinc in many applica-
tions. Cadmium plating alternatives are discussed later in this
section.
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Replace hexavalent chromium with trivalent chromium. Tri-
valent chromium has been used in place of the more toxic hexa-
valent chromium, but it produces a lower quality surface.
Return spent plating solution to manufacturer. This requires
on-site segregation of solutions according to the metal in the
solution.
Waste Rinse Water
There are several methods available to reduce the amount and
toxicity of waste rinse water. These methods can be grouped into
two major techniques:
• Drag-out minimization. Reducing drag-out will result in a
decrease of the heavy metal content of the ultimate waste
(treatment sludge).
• Rinse water minimization. Decreasing water consumption
will decrease the volume of ordinary calcium and magnesium
sludge that results when using hard water. The amount of
heavy metal sludge produced remains the same. Therefore de-
creasing the amount of rinse water without reducing drag-out
may result in a smaller, but more highly toxic, volume of treat-
ment sludge.
Drag-Out Minimization
Minimizing the drag-out reduces the amount of rinse water needed.
Also, less of the plating solution metals leave the process, which
ultimately produces savings in raw materials and treatment/dis-
posal costs. The amount of drag-out depends on the:
• surface tension of the plating solution,
• viscosity of the plating solution,
• physical shape and surface area of the workpiece and rack, and
© 1989 HH CHMR
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• speed of workpiece withdrawal and drainage time.
Generally, drag-out minimization techniques include the following
practices.
Increase plating solution temperature. Increased temperature
lowers both the viscosity and surface tension of the solution. The
resulting higher evaporation rate may also inhibit the carbon
dioxide absorption rate, slowing down the carbonate formation in
cyanide solutions. Disadvantages include:
• formation of carbonate by cyanide breakdown at elevated
temperatures,
• higher energy costs,
• higher chance for contamination due to increased make-up
requirement, and
• more need for air pollution control due to higher evaporation
rate.
Lower the concentration of plating bath constituents. For ex-
ample, it has been found that acceptable chromium plating can be
obtained from baths containing only 25 to 50 grams per liter (g/l)
CrO3 compared to the traditional concentration of 250 g/l. Lowering
the concentration will result in:
• lower solution viscosity, and
• reduced rinsing requirement.
Reducing speed of workpiece withdrawal and allowing ample
drainage time:
• 30 seconds usually allows most drag-out to drain back to the
tank;
®1989 HHCHMR
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• while 10 seconds still permits good drag-out recovery in
applications where quick drying is a problem.
Use surfactants. Applied in small amounts, wetting agents can
lower a solution surface tension enough to reduce drag-out by up
to 50 percent. Only non-ionic wetting agents should be used. The
use of surfactants is sometimes limited, because they have an ad-
verse effect on the quality of the plate produced.
Properly position the workpiece on the plating rack. Proper
positioning of the workpiece on a rack will facilitate the dripping of
the drag-out back into the bath. This is best determined experimen-
tally, although the following guidelines were found effective.
• Orient the surface as close to vertical as possible.
• Situate the longer dimension of the workpiece horizontally.
• Position the workpiece with the lower edge tilted from the
horizontal so that the runoff is from a corner rather than an
entire edge.
Improve drag-out recovery. A drain board positioned between
a plating bath and rinse bath can capture the dripping solution and
route it back to the plating bath. Incorporating an empty drip tank
between the plating bath and the rinsing bath is another option.
Rinse Water Minimization
Rinse water minimization involves rinsing off the work-piece in the
most efficient manner, using the smallest volume of rinse water.
Traditionally, a workpiece would be immersed into a single rinsing
bath following a plating bath, and then it is moved to the next step
in the process. Several methods exist which use less rinse water
than the traditional method, while still adequately rinsing the
workpiece.
Multiple rinsing tanks. These can reduce rinse water require-
ments by 66 percent with possible theoretical reductions of over 90
percent reported. In a three-tank, counter-current series system:
© 1989 i^m CHMR
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The workpiece enters the first rinse tank, which has the most
contaminated rinse water. It is then moved to the second
tank, and then to the last, where it contacts fresh rinse water
before moving to the next step in the process.
Fresh rinse water enters only the last (third) rinsing tank. The
water then flows into the second tank, then into the first tank
from which it is routed to treatment or to the plating tank as
a make-up.
Fog nozzles and sprays. Spraying water droplets onto a work-
piece is more efficient than immersing a workpiece into a water
bath.
• Fog nozzles and sprays are highly effective on simple work
pieces, such as sheets.
• Fog nozzles and sprays are not effective on oddly shaped
objects, since spray cannot make direct contact with the entire
surface.
• Fog nozzles use water and air pressure to produce a fine mist
and can be used directly over a heated plating bath to rinse the
workpiece which allows for simultaneous rinsing and replenish-
ment of the evaporated losses from the tank.
• Fog nozzles are not used in barrel plating because of the odd
shape of the part.
Rinse water reuse. Rinse water picks up contaminants from the
workpiece that was rinsed. The same water can be used again in
a subsequent plating step if these contaminants do not interfere
with the quality of that step. For example, in a nickel plating
process, the same rinse water stream was used for the rinses
following the alkaline cleaning, acid dip, and nickel plating tanks.
Instead of having three different rinse streams, only one stream
was used, greatly reducing the overall rinse water requirements.
@1989
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Still rinsing. The workpiece is immersed in a still (no inflow or
outflow) rinse tank following the plating bath. The concentrations of
the plating bath constituents build up until they become sufficiently
high forthe rinse waterto be used to replenish the upstream plating
bath.
Automatic flow controls. Flow can be automatically controlled at
the lowest possible rinse rate to avoid variations associated with
water line pressure changes and manual control by the operator.
Rinse bath agitation. Agitating the rinsing bath mechanically or
with air increases the rinsing efficiency.
Treatment Wastes
In electroplating, toxic metal sludges result from the conventional
treatment processes used to remove metals from waste water.
The volume and toxicity of the sludge produced can be lowered by
reducing the metal content in the plating and rinse waste waters,
or by using different precipitating agents. Following are methods
available to accomplish this.
Use of different precipitating agents. Normally, hexavalent
chromium is treated with a reducing agent to trivalent chromium,
followed by precipitation with lime. In one instance, sodium
hydroxide was used in place of lime, which produced 1.98 Ib dry
solids/lb Cr(VI) compared to 2.24 Ib dry solids/lb Cr(VI) produced
by lime precipitation.
Use of Cr(lll) instead of Cr(VI) for plating. One operation re-
ported a 70 percent reduction in sludge production when trivalent
chromium was used for plating instead of hexavalent chromium.
This reduction occurred because the necessity to precipitate
gypsum was avoided. Gypsum is associated with the excess
sulfate ions that are normally added to reduce Cr(VI).
Waste Stream Segregation
• By isolating cyanide-containing waste streams from waste
streams containing iron orcomplexing agents, the forma-
©1989 ••ICHMR
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tion of cyanide complexes is avoided, and treatment made
much easier.
• Segregating waste water streams containing different metals
allows for metals recovery or reuse. For example, by treating
nickel plating waste water separately, a nickel sludge is pro-
duced which can be reused to produce fresh nickel plating
solution.
• In one instance, the scrubber waste from a chromium plating
bath was segregated and could then be returned to the bath.
This resulted in less waste and increased plating solution life.
Metal recovery techniques. Techniques to recover metals from
rinse water before treatment include:
• evaporation,
• reverse osmosis,
• ion exchange,
• electrolytic metal recovery, and
• electrodialysis.
Many companies have installed such systems to recover metals
from waste rinse water and have found the investment paid for itself
in 1 to 5 years. Section 9.3.2 provides a detailed description of
these metal recovery techniques and some examples of where
they have been successful.
Use of separate treatments. Use of separate treatments for each
solution results in a sludge that bears a single metal. The sludge
(metal hydroxide) can then be sold, e.g., to a chemical producer.
Product Substitution
Following are two possible product substitutions.
Cadmium plating alternatives. Products plated with cadmium
are highly resistant to corrosion on land and in marine environ-
ments. Roughly 40 percent of the total cadmium produced is used
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by the U.S. military. It may be possible in some instancesto replace
cadmium plating with other materials such as:
• zinc plating,
• titanium dioxide plating using vapor deposition, and
• aluminum plating using ion vapor deposition.
None of these coatings have exactly the same properties as
cadmium, but some may prove to be satisfactory substitutes
nonetheless.
Chromium plating alternatives. Substantial waste is produced
during chromium plating; therefore, eliminating any unnecessary
use is beneficial. For example, chromium-plated car bumpers can
be replaced by nickel-plated bumpers, although customer prefer-
ence for a shinier finish may play a major role.
8.4 Printed Circuit Board Manufacturing
8.4.1 Industry Process Description
Printed circuit board manufacturing involves imprinting metal cir-
cuitry onto a board composed of nonconductive material (e.g.,
glass, epoxy, or plastic) through a series of operations character-
istic of the particular production method used. The three principal
production methods used in their manufacture are:
conventional subtractive process,
fully additive process, and
semi-additive process.
The subtractive production method is currently the most predomi-
nant of the three types. It typically begins with a copper-clad
laminate board which is subjected to the following operations.
• Board preparation: curing, sanding, drilling, deburring.
• Electroless copper plating: scrubbing/cleaning, surface
activation etching, electroless plating catalyst application.
©1989 HBICHMR
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• Printing and masking:
- Panel plating: electroplating, etching, resist application.
- Pattern plating: resist application, printing/developing.
• Electroplating: cleaning/rinsing, tin/lead plating, light etch/
acid dip, stripping/rinsing, copper electroplating.
• Etching
The final stages of the subtractive process involve cleaning and
application of selective metallic coatings for solderability and/or
corrosion protection.
The additive method differs in that an unclad board is used initially.
The only areas of the board to be plated are those containing the
circuitry itself; all other areas are coated with plating resist, thus
eliminating the need to etch unwanted copper.
8.4.2 Sources of Waste
The waste streams resulting from the five major operations men-
tioned in the preceding section are listed in Table 8.4.
Airborne particulates generated during board preparations are
normally collected and separated using bag-house and cyclone
separators. The collected dusts are then removed for disposal at
landfills as solid wastes.
Acid vapors are collected and are neutralized prior to sewer
discharge or disposal, while organic vapors are collected and
condensed, drummed and land disposed, combusted, or reclaimed.
The majority of the liquid waste streams are subject to in-house
treatment prior to sewer discharge. Typical treatment systems
may consist of pH adjustment and metal precipitation, followed by
sludge removal and dewatering.
Spent organic solvents are most often reclaimed, either in-house
or at an off-site facility.
1989
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8.4.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste, and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
8.4.4 Specific Waste Minimization Practices
Table 8.4 outlines the major operations involved in the manufac-
ture of printed circuit boards, the waste streams which result from
these operations, and the waste minimization practices which are
most applicable to them.
The waste reduction measures listed in Table 8.4 generally fall into
the process change and material/product substitution category.
Each measure will be briefly discussed in the following sections.
Cleaning/Surface Preparation
Wastes generated from the cleaning and surface preparation
operations of printed circuit board manufacture are similar to those
produced from other manufacturing operations involving metal
parts cleaning. A detailed discussion of the waste minimization
practices applicable to these processes is provided in Section 7.2,
Metal Parts Cleaning.
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Table 8.4. Printed circuit board waste streams and
minimization practices.
Process origin Waste stream Control methodology
Cleaning/surface
preparation
Catalyst
application/
electro less
plating
Pattern printing/
masking
Electroplating
Etching
Airborne particu-
lates; acid
fumes/organic vapors;
spent acid/alkaline
solution; spent hal-
ogenated solvents;
waste rinse water.
See Section 7.2.
Spent electroless
copper bath;
spent catalyst
solution; spent
acid solution;
waste rinse water.
Acid fumes/
organic vapors;
vinyl polymers;
spent resist
removal
solution; spent
acid solution;
waste rinse water.
Spent plating
bath; waste rinse
water.
Spent etchant;
waste rinse water.
• Use combined sensitization/
activation.
•Use lower concentration
plating bath.
• Use differential electroless
plating.
• Use weak/biodegradable
chelating agents.
• Use in-line metal recovery
techniques.
• Use computerized/auto-
mated control.
1 Use aqueous processable
resists.
1 Use screen print instead of
photolith.
'Use Asher dry resist re-
moval method.
• See Section 8.3.
• Use pattern instead of panel
plating.
•Use dry plasma etching
techniques.
• Use additive in place of
subtractive method.
• Use less-toxic etchants.
1 Use in-line metal recovery
techniques.
'Use thinner copper foil
for cladding.
© 1989
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Catalyst Application and Electroless Plating
Spent process solutions and rinse waters characterize the wastes
resulting from these operations. The following methods should
result in a decrease in the volume and/or increase in the treatability
of wastes generated.
Use a combined sensitization and activation solution to elimi-
nate one extra rinsing step. Although the activity of the catalyst
may be reduced by combination of these two steps, the reduction
of waste due to elimination of a rinse step should outweigh this dis-
advantage.
Use a less concentrated plating bath to reduce the degree of
subsequent rinsing required. Although no information has been
reported on the success of this technique, the approach has been
tried by some large companies in the electroplating industry.
Use differential plating instead of the conventional elec-
troless plating process. This technique needs more develop-
mental work before it can be applied commercially. However, the
principle involves controlling the concentration of stabilizers in the
plating bath, resulting in a rate of copper deposition in the "through
holes" three to five times faster than the rate of deposition on the
board surface. If the subtractive method of manufacture is used,
this technique would decrease the amount of copper which must be
etched away later.
Use weak or biodegradable chelating agents. When weak
chelating agents, such as hydroxy acids, are used in the elec-
troless plating bath, subsequent metal recovery operations will be
more effective due to an increase in the amount of metal which is
capable of being removed from solution.
Use in-line techniques for metal recovery. Strategic, in-line
placement of metal recovery units, such as ion exchange columns,
can serve to remove metals from spent plating baths and waste
rinse waters. When the ion exchange resin is regenerated, the
metals can be recovered and used to provide plating solutions
which can be recycled to the plating baths.
'1989 •MCHMR
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Use computerized/automated control systems. Computerized
process-control systems for board handling and process bath
monitoring can be used to prevent unexpected decomposition of
the plating bath solutions. However, due to high equipment cost
and the ongoing need for skilled operations and maintenance
personnel, only very large printed circuit board manufacturers find
this waste minimization option a practical one. Smaller manufac-
turers may find that automated board handling systems for the
plating operation have a much broader application.
Better operating practices. Although discussed generically in
Section 7.1, some waste reduction methods specifically applicable
to printed circuit board manufacturing are briefly detailed below.
• Inspect plating racks frequently for loose insulation. This
procedure will prevent excess drag-out of process so-
lutions.
• Distribute work load evenly. Dense loading may result in
localized instability of the process solution.
• Regularly strip copper from plating tank to prevent continu-
ous deposition of copper and palladium on the tank walls.
• Segregate chelated waste streams to prevent metal precipi-
tation problems during waste treatment.
Pattern Printing/Masking
Liquid waste streams generated from these processes include
spent chlorinated solvents, spent resist solutions, and waste rinse
waters. The organic solvents are generally gravity separated and
collected for disposal or recovery. Source reduction techniques
include:
Use a water-processible resist instead of a solvent-proces-
sible resist. The use of water-processible resists eliminates the
generation of toxic spent solvents by allowing the use of caustics
and carbonates as developers and strippers.
®1989 •HCHMR
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Use screen printing instead of photolithography. The use of
screen printing would eliminate the need for the developers used
in photolithography. Recent improvements to this technique have
enabled its use for the manufacture of printed circuit boards
requiring resolution down to 0.01 inch, although the majority of
manufacturers still use photolithography for circuitry finer than 12
mil lines and spaces.
Use the Asher dry photoresist removal method instead of
organic resist stripping solutions. More investigation is needed
into the applicability of this process to printed circuit board manu-
facturing. It is currently utilized by semiconductor manufacturers,
but resist layers in this industry are generally much thinner than
those utilized in printed circuit board manufacturing.
Electroplating
The waste streams generated in the electroplating process primar-
ily consist of waste rinse waters and spent plating solutions. On-
site treatment of these wastes usually consists of metal precipita-
tion by pH adjustment, neutralization, and possibly cyanide de-
struction, followed by sewer discharge of the treated effluent and
transport of the metal sludges off-site for metal recovery or dis-
posal. Source reduction techniques for the various types of elec-
troplating process wastes are detailed in Section 8.3; however, one
suggestion specific to the printed circuit board industry is dis-
cussed below.
Use pattern instead of panel plating. Switching to this technique
will reduce the amount of non-circuit copper which must be etched
away, thereby reducing the amount of waste generated from the
etching operations. However, customer specifications may not
allow this, particularly for products such as computer and micro-
wave printed circuit boards, where the circuitry requires highly
uniform copper thickness.
Etching
The etching process generates spent etchants and waste rinse
waters. The metals in these can be removed prior to sewer
©1989 HMCHMR
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discharge by adjusting the pH. The source reduction techniques
applicable to these waste streams are:
Use dry plasma etching techniques. Etching is achieved either
through a chemical method (utilizing reactive gaseous radicals) or
a physical method (using nonreactive ion bombardment). A radio
frequency source is used to ionize gaseous molecules, thereby
creating a plasma. More investigation is necessary regarding the
applicability of this technique to removal of the thick (1.4 mil) copper
layers used in printed circuit board manufacturing.
Use additive instead of subtractive method. Advantages to the
use of the additive method include lower manufacturing costs and
a decrease in the amount of waste generated, due to the elimina-
tion of the copper etching step. However, there are two factors to
be considered if a switch to the additive method is being consid-
ered: a water-processible resist may not be substituted for a
solvent-processible one; and the heavily complexed copper often
found in additive plating solutions may cause difficulties during
waste water treatment.
Use less toxic etchant. The use of non-chromium etching solu-
tions would reduce the toxicity of the wastes generated from this
process.
Use of in-line techniques for metal recovery. A technique re-
cently developed by Bend Research, Inc. would enable copper to
be recovered from etching solutions through the use of liquid mem-
branes.
Use thinner copper foil to clad the laminated board. Starting
the manufacturing process with boards covered with athinner layer
of copper will result in a reduction of the amount of copper which
must be etched, thereby reducing the amount of wastes generated
from the etching process.
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8.4.5 Product Substitution Options
Use of surface instead of through-hole insertion mounting in
printed circuit board packaging. Although relatively new, this
method of attaching packages to printed circuit boards can reduce
the size of printed circuit boards required for a given number of
packages from 40 to 65 percent, since it allows for closer contact
areas of chip leads. This size reduction would result in a corre-
sponding decrease in the amount of wastes generated from the
manufacturing process.
Use of injection molded boards. High-temperature, high-per-
formance thermoplastics can be injected under high pressure into
precision molds, and circuitry can then be applied using a semi-
additive or fully additive plating process such as fast-rate elec-
trodeposition (a technique developed by Battelle). As previously
mentioned in Section 8.4.4, use of the additive method would
eliminate the generation of spent toxic etchants.
8.5 Dry Cleaning and Laundries
8.5.1 Industry Description
The dry cleaning and laundry industry typically includes:
• retail dry cleaning stores,
• industrial and linen supply plants with dry cleaning operations,
• leather and fur cleaning plants,
• self-service laundromats with dry cleaning equipment, and
• other establishments with dry cleaning operations.
8.5.2 Sources of Waste
While not all of these facilities will produce hazardous wastes,
those using hazardous solvents are subject to regulation under
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RCRA. Some of the most common hazardous wastes from the dry
cleaning and laundry industry include:
• Wastes from perchloroethylene plants, which include:
- still residues from solvent distillation,
- spent filter cartridges, and
- cooked powder residue.
• Wastes from Valclene plants, which include:
- still residues from solvent distillation, and
- spent filter cartridges.
• Wastes from petroleum solvent plants, which include:
- still residues from solvent distillation.
8.5.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste and may include:
• personnel practices,
procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
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8.5.4 Specific Waste Minimization Practices
The most serious waste problem in the dry cleaning industry is
solvent loss. Waste minimization practices center around control-
ling solvent emissions and solvent wastes. The most common
practices are:
Waste stream Minimization practice
Solvent emissions Check for and fix leaks regularly.
Reduce solvent vapor loss.
Use dry-to-dry machines.
Use machines with monitors.
Solvent wastes See Section 9.1.
Each of these waste minimization practices from the dry cleaning
and laundry industry are briefly described in the following section.
Solvent Emissions
Total solvent emissions from dry cleaning facilities can vary greatly
with operational and maintenance procedures. A1980 study by the
U.S. Department of Health and Human Services, which examined
20 dry cleaners, concluded that gasket leaks, solvent retention in
garments, and poor ventilation were common problems. Also, no
correlation was found between plant size and solvent mileage.
There are several minimization practices available for reduction of
solvent loss.
Check for and fix leaks regularly. The leakage of sovents from
worn equipment and hosing can easily go unnoticed unless the op-
erator routinely checks for signs of solvent loss. Liquid leaks can
be identified by the presence of a brown residue left on the under-
side of the leak. The areas which should be checked regularly for
liquid leakage are:
• hose connections, couplings, and valve machines;
• door gasket and seating;
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• filter head gasket and seating;
• pumps and storage tanks;
• water separators;
• filter sludge recovery;
• cartridge filters;
• distillation unit;
• divertor valves; and
• saturated lint from lint basket.
Reduce solvent vapor loss. Some leaks may be caused by
certain operating practices which allow solvent vaporto escape un-
necessarily. Unless regular checks are made, the loss of solvent
vapor can go undetected for months. Plugging leaks and improv-
ing operating practices in the following ways will minimize volatile
emissions:
• Periodically replace the seals on the dryer deodorizing and
aeration valves.
• Repair holes in the air and exhaust ducts.
• Replace faulty gaskets on machine doors.
• Keep containers of solvent closed while not in use.
• Clean lint screens regularly to avoid clogging fans and con-
densers. The operation of the solvent recovery system is
impeded if the condensers are caked with lint.
• Open button traps and lint baskets only briefly as necessary
for cleaning, to avoid residual solvent losses.
• Size the garment load correctly relative to the size of the
equipment. Overloading results in incomplete solvent ex-
traction, while underloading increases the amount of sol-
vent loss per garment.
Many companies offer help in gaging solvent performance. PPG
Industries offers guidebooks on solvent management through
®1989
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good operating practices. Dow Chemical, a major producer of
perchloroethylene, provides a free computerized solvent analysis
service to help dry cleaners assess their solvent performance.
Use dry-to-dry machines. This combines washing and drying
functions in a single unit. Using these machines instead of transfer
machines requires less contact of the solvent by workers and less
loss of solvent into the work environment. Recently, "cold dry"
systems have been introduced. This additional feature allows for
the use of lower temperatures during the drying process, which
minimizes solvent loss and prolongs the life of the machine seals.
For example:
• Uni-Rent Ltd. bought a cleaning company in 1977 and im-
mediately upgraded the machines to dry-to-dry models.
They use about 300 gallons of perchloroethylene a month,
instead of the 700 gallons a month the old machines used.
Because the cost of perchloroethylene has more than tripled
since 1977, Uni-Rent estimates they have saved approximately
$50,000 per year.
Use machines with monitors. This allows forthe correct amount
of chemicals and soap to be added automatically, as well as the
drying time to be extended until the clothes are fully dried. In this
way, the amount of solvent vapor allowed into the plant by remov-
ing incompletely dried clothes is minimized. Spent cartridges can
be dried out in the machine to recover residual solvent before
disposal. American Permac Inc. of Hicksville, New York, is one of
the equipment manufacturers which has introduced a line of moni-
tored machines. American Permac boasts a solvent mileage of
30,000 to 50,000 pounds of fabric per drum of solvent with its new
line.
Solvent Wastes
Waste solvents can generally be reclaimed by installing on-site
distillation units, shipping waste solvent off-site to a solvent re-
claimer, or returning waste solvent to the solvent supplier. More
detailed information on waste minimization practices for solvents
is in Section 9.1.
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8.6
8.6.1
Printing
Industry Process Description
There are several commonly employed printing processes cur-
rently used by the graphic arts industry, including lithography, gra-
vure, flexography, letterpress, and screen printing. Of these, li-
thography, gravure, and flexography are the most widely utilized.
While the operational detai Is may vary between these various print-
ing processes, the basic steps involved are the same. These steps
include:
• image processing,
• plate or cylinder making,
• printing,
• drying, and
• finishing.
8.6.2 Sources of Waste
Lithography and flexography generally produce the following three
main types of waste:
• trash,
• process waste waters and,
• equipment cleaning wastes.
Table 8.5 provides more detail. While gravure printing generates
similar waste streams, the waste waters produced are actually
more akin to metal processing operations, and the sections of this
manual dealing with metal parts cleaning, electroplating, and metal
finishing operations (Sections 7.2, 8.3, and 8.2, respectively)
should be consulted for further information regarding this waste
type.
Trash is by far the largest waste stream produced by the printing
industry. Scrap paper generated is either recycled, incinerated, or
sent for disposal. Scrap photographic material is often sold for
metal recovery. Empty containers are typically discarded, but may
be recycled in some cases.
© 1989
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Waste waters may be subject to pretreatment for metal recovery or
neutralization prior to sewer discharge, or drummed for off-site
disposal if necessary.
Equipment cleaning waste handling depends on the types of inks
and solvents used. Cleaning rags are either incinerated or sent for
laundering or disposal. Any waste water-based inks are generally
discarded with other trash. Solvent-based inks and spent cleaning
solvents may be recycled, incinerated, or sent to a hazardous
waste treatment or disposal facility.
8.6.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste, and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
8.6.4 Specific Waste Minimization Practices
Table 8.5 outlines the major operations or processes involved in
printing, the waste streams which result from these operations, and
the waste minimization practices which are most applicable.
The following sections include suggestions on how wastes gener-
ated by the printing industry may be reduced in volume ortoxicity,
either by recycling, source reduction, or product substitution.
Trash
Recycle empty containers. Purchasing ink in bulk containers
which are returned to the supplierfor refilling will reduce the amount
1989 ••CHMR
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of trash generated, and cut down on the amount of cleaning time
needed to scrape ink residues from the inner walls of the container.
If returnable containers are not available from the supplier, it still
may be possible to reduce disposal of empties by sending them
either to container recyclers or reconditioners.
Recycle spoiled photographic film and paper. Sending used or
spoiled film and paper to silver reclaimers is already practiced by
much of the printing industry, with the exception of very small
operators and those located in areas not serviced by silver recy-
clers.
Table 8.5. Printing wastes.
Waste
stream
Trash
Process
origin
Image
processing
Plate
making
Printing
Composition
Empty con-
tainers, used
film packages,
out-dated
material.
Damaged plates,
developed film,
dated materials.
Test production,
bad printings,
empty ink
containers,
used blankets.
Control
methodology
• Recycle empty contain-
ers.
• Recycle spoiled
photographic film.
• Use electronic imaging,
laser plate making.
• Install web break
detectors.
• Monitor press per-
formance.
• User better operating
practices.
Wastewater
Finishing
Image
processing
Plate
making
Damaged prod-
ucts, scrap.
Photographic
chemicals, silver.
Acids, alkali,
solvents, plate
coatings, (may
contain dyes,
photopolymers,
binders, resins,
pigment, organic
Use silver-free films.
User water-developed
litho plates.
Electronic imaging/
laser print making.
Recover silver and
recycle chemicals.
Use counter-current
washing sequence.
Use squeegees.
acids), develop- • Use better operating
ers (may
practices.
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Waste
stream
Table 8.5. (continued)
Process Control
origin Composition Methodology
Equipment
cleaning
Printing
Printing
contain isoprop- •
anol, gum arable,
lacquers, caustics)
and rinse water.
Spent fountain
solutions (may
contain chromium)
Remove heavy metals
from wastewater.
up solvent
(halogenated and
non-halogenated),
rags
Lubricating oils, • Recycle waste ink and
waste ink, clean- solvent.
Use automatic cleaning
equipment.
Recover heating value
from waste.
Use automatic ink lev-
eler.
Use less toxic solvents.
Use better operating
practices.
Electronic imaging and laser platemaking. This technique
would allow text and photos to be edited on a video terminal and
color separations to be prepared electronically, thereby reducing
or eliminating some photographing, editing, re-shooting, and pho-
toprocessing steps (and wastes) involved in the printing process.
Install web break detectors. The Oxy-Dry Corp. manufactures a
non-contact electronic system which detects web breaks without
smearing or creasing the web, thereby reducing wastes from this
source.
Monitor press performance. Waste systems are currently on the
market which can monitor press performance. One such system
is the Pressdata 190, manufactured by Crosfield in Chicago,
Illinois.
Use careful storage practices. Careful attention to storage
specifications of photosensitive film and paper may greatly reduce
waste produced as a result of improper storage.
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Waste Water
Use silver-free films. Silver-free films are currently on the market
from several manufacturers. Substitution of silver-free films would
eliminate the need to send waste film to a metal reclaimer.
Use water-developed lithographic plates. Switching from chemi-
cal processing to water processing of lithographic plates and film
may eliminate certain waste waters which currently require pre-
treatment prior to sewer discharge. The 3M Corporation markets
a Hydrolith plate which requires only water to process aluminum
offset plates.
Electronic imaging and laser platemaking. Text and photos are
read by an electronic scanner, edited with a display monitor, and
non-silver plates are made using laser beams. However, this type
of system is currently impractical for small print shops due to the
great equipment expense involved.
Recover silver and recycle spent chemicals. Keeping individ-
ual process baths (developers, fixers, rinses) as uncontaminated
as possible facilitates silver recovery, whether it is accomplished
by metallic replacement, chemical precipitation, electrolytic recov-
ery, orthe like (for more details see below under Removal of Heavy
Metals from Waste Water). A wide variety of silver recovery equip-
ment is available, no matter what the size of the operation.
Technologies such as oxidation, electrolysis, and ion exchange
are also available to restore of developers and fixers.
Employ counter-current washing. Process solution contamina-
tion and water usage can be reduced by using counter-current
washing instead of parallel tank wash systems. In the counter-
current system, water from previous rinsings is used in the initial
film-washing stage. Fresh water enters only the final rinse tank,
instead of each wash tank along the way.
Use squeegees. By using squeegees to wipe off excess liquid in
a non-automated processing system, chemical carry-over from
one process bath to the next can typically be reduced 50 percent
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or more. Minimizing process bath contamination increases the
ease with which the bath can be recycled, prolongs bath life, and
reduces the amount of replenisher chemicals required.
Substitute iron-EDTA for ferrocyanide bleaches. Although
iron-EDTA is a slower acting bleach, it is less toxic and would
therefore eliminate costs associated with the treatment, incinera-
tion, or disposal of ferrocyanide bleaches.
Use "washless" processing systems. Use of these systems
could reduce waste water by 97 percent, although they are expen-
sive to install (approximately $45,000).
Employ better operating practices. Several suggestions for
minimizing waste through improvements in operating practices are
briefly described below.
• Frequent monitoring and accurate addition of replenisher
chemicals to process baths will reduce chemical waste.
• Pay attention to process chemicals which have short expiration
dates (shelf life).
• Reuse rinse water as long as possible.
• Prevent premature expiration of light-sensitive chemicals
by keeping them in the dark.
• Prolong the potency of oxidizable process baths by reducing
their exposure to air.
• Small-scale photo developers may use glass marbles to bring
the liquid levels of their process chemicals to the brim each time
the liquid is used. This extends the chemical's life by minimizing
the amount of oxygen with which it comes in contact.
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Remove heavy metals from waste water. Several methods are
available:
• Silver recovery may be enhanced by using two chemical
recovery cartridges in series. The second cartridge would also
serve to minimize silver breakthrough. Installing a cartridge
to polish the effluent of an electrolytic unit would significantly
reduce silver levels in sewer discharges .
• The efficiency of an electrolytic recovery unit for silver can be
significantly increased by adjusting the concentration of sulfite
in the silver-bearing wastes to 10 to 25 grams/liter and the pH
to 7.8. This will also serve to reduce sulfiding.
• Using a low current for the first plating of silver in an electrolytic
unit will minimize silver fin formation ("finning"), a condition
which limits the amount of recoverable silver from a particular
batch of process waste.
• Keeping concentrations of silver and iron low in the waste
streams will increase electrolytic efficiency. This can be ac-
complished by using a higher-than-normal fixer replenishment
rate in film processing.
• Hexavalent chromium can be reduced to the less toxic
trivalent form by lowering the pH to approximately 2 using a
strong mineral acid, then adding a strong solution of reducing
agent such as ferrous sulfate or sodium bisulfite. Heavy metals
will then precipitate out upon the addition of caustic soda
or lime.
Cleanup Solvents and Waste Ink
Recycle waste ink and cleanup solvent. Ink recovery machines
currently on the market in a number of sizes make on-site reclaim-
ing a viable option. It may also be possible to send waste inks back
to the manufacturer for conversion to black newspaper ink. Waste
solvents can be recovered on-site by simple batch distillation if
11989 •MCHMR
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sufficient quantities are generated to make this worthwhile. Profes-
sional solvent recyclers can also perform this task.
Use automatic cleaning equipment. Equipment of this type can
promote a more efficient use of cleaning solvent, although it is very
expensive to purchase and maintain.
Use an automatic ink leveler. Ink waste and spoilage around the
press can be prevented, and optimum inking conditions in the
fountain can be maintained by installing an automatic ink leveler in
the fountain.
Substitute less toxic solvents. It may be possible to substitute
less toxic solvents, such as hexane, for the highly toxic aromatic
solvents, such as toluene and benzene.
Use better operating practices. A variety of suggestions for mini-
mizing wastes by improving operating practices are described
below.
• Segregate spent solvent according to color and type of ink
contaminant, then reuse the collected wastes to thin future
batches of the same ink.
• Avoid drawing too much solvent from the container. Draw
only what is necessary to complete the cleaning task.
• Schedule jobs using light-colored inks before those requiring
darker ones since this may reduce the amount of equipment
cleaning required between color changes. Dedicated presses
for various colors of ink may also be feasible in some cases,
which would also result in fewer cleanups.
• Save all unused portions of ink for house colors or future
production runs.
• Use press wipes as long as possible before discarding, and
use dirty ones for the first pass, clean ones for the second
pass.
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8.7 Photography
8.7.1 Sources of Waste
I n
The primary wastes associated with the photography industry
include the spent fix solutions from the film development process.
Commercially available recycling equipment exists that makes it
possible to reuse spent developer, bleach, bleach-fix, and fix-proc-
essing solutions. Equipment is also available to recoverthe silver
present in the wash water after the fix bath.
8.7.2 Good Operating Practices for Waste Minimization
Good operating practices are procedural or institutional policies
which result in a reduction of waste and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1 .
8.7.3 Specific Waste Minimization Practices
The most common waste minimization practices which can be
applied to the three main waste streams in the photography
industry are:
Waste stream Minimization practice
Process bath wastes Metallic replacement
Chemical precipitation
Install metal recovery system
@198d
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Color developer wastes Metal recovery techniques
Countercurrent washing
Use of squeegees
Reduction of water consumption
Bleach, fix, Use of non-complexed bleach-
bleach-fix wastes es, ozone oxidation, electrolysis,
persulfate salts, and/or liquid
bromine.
Each of these waste minimization practices for the photography
industry are briefly described in the following sections.
Process Bath Wastes
Three major sources of recoverable silver in the photoprocessing
industry include:
• exhausted fixes and bleach-fix,
• film scraps and unexposed paper, and
• waste wash water following fixes and bleach-fixes.
While the recovery of silver from spent fix is very common, the
efficiency of silver recovery from spent fix varies greatly. Recovery
of silver from the other sources is not as common as recovery from
fix.
Metallic replacement. This occurs when a metal such as iron
contacts a solution containing dissolved ions of a less active metal
such as silver. The dissolved silver reacts with the iron and settles
out as a sludge.
Chemical precipitation. This may be done with a variety of differ-
ent products. Ventron Corporation, for example, manufactures a
product marketed as Vensil which may be used for the direct
recovery of silver from spent fix.
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Metal recovery systems. Technologies to recover metals from
rinse water before treatment include:
• evaporation,
• reverse osmosis,
• ion exchange,
• electrolytic metal recovery, and
• electrodialysis.
Many companies have installed such systems to recover metals
from waste rinse water and have found the investment has paid for
itself in 1 to 5 years. Section 9.3.2 provides a detailed description
of these metal recovery techniques and some examples showing
where they have been successful.
Color Developer Wastes
Although color developer recycling technologies have been avail-
able since the 1 950s, not until the last few years — with the rise in
organic chemical costs — have they become economically fea-
sible. Following are waste minimization practices for color devel-
oper wastes.
Counter-current washing. Water from previous rinsings is used
to contact the film at its most contaminated stage. Fresh water
enters the process at the final rinse stage, at which point much of
the contamination has already been rinsed off the film.
Use squeegees. Wipe excess liquid from the moving photo-
graphic material. By reducing chemical carry-over, the lifetime of
the process bath is prolonged, reducing the waste waterdischarge.
Reduce water consumption. Water consumption can be re-
duced by shutting off water while film processing is halted. Alter-
natively, a solenoid valve can be installed to automatically reduce
water flow when film processing stops. This "housekeeping" tech-
nique requires minimum capital outlay, yet the savings can be
dramatic. Eastman Kodak cut its consumption rate by 70 percent
over 8 years. They estimate their cumulative savings over those
8 years to be $273,000.
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Bleach, Fix, and Bleach-Fix Wastes
Historically, ferricyanide bleach has been used in color processing
to convert developed metallic silver and bromine to silver bromide
that may be removed by fixer in a subsequent process bath. During
this conversion, the ferricyanide is changed to ferrocyanide and
leaves the process as overflow.
In the past, ferrocyanide overflow from a processing machine was
allowed to pass untreated to the sewer. In recent years, however,
the regeneration of ferricyanide bleach has become feasible for
both economic and environmental reasons. In all cases, the
ferricyanide bleach regeneration process basically involves con-
verting (by oxidation) the non-active ferrocyanide in the overflow to
active ferricyanide. The following specific practices can be used to
minimize ferricyanide bleach waste.
Use ozone oxidation to regenerate spent ferricyanide bleach.
This process involves the production of ozone gas which functions
as the oxidizing agent to regenerate the spent ferricyanide bleach.
In this process, the dilute ferricyanide bleach found in rinse waters
must first be concentrated using ion-exchange columns before it
can be regenerated using ozone. CPAC (Leicester, New York)
provides a unit known as the OzPac which uses ozone to regener-
ate spent bleach. This method-can reduce the effluent ferrocya-
nide concentration by about 90%.
Use electrolysis to regenerate spent ferricyanide bleach or de-
silver the fix. An electrical current is applied to the ferrocyanide
overflow to convert the non-active ferrocyanide to active ferricya-
nide. The hydroxide by-product must then be removed and
hydrobromic acid added. Some laboratories use an in-line electro-
lytic system which continuously de-silvers the fix in the tank and
extends the life of the fix. Residual silver in the electrically de-
silvered fix can be recovered using a metallic replacement car-
tridge. With some processes, attempts to re-use as little as 50
percent of the de-silvered fix along with new fix have resulted in
serious stains on the sensitized product unless proper precautions
are taken (such as sulfiting the replenisher solution). CPAC
(Leicester, New York) manufactures an electrolytic silver recovery
1989 l^HCHMR
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unit for the closed loop de-silvering of fix which allows a 50 to 90
percent reduction in fix replenishment. The Nash Cell by Eastman
Kodak is a small piece of equipment which converts spent bleach
to active ferricyanide.
Use persulfate salts to regenerate spent ferricyanide bleach.
This is the most common regeneration practice in use today. Simi-
lar to the ozone process, persulfate serves as the oxidizing agent
to regenerate ferricyanide from the ferrocyanide overflow. The use
of persulfate salts is not as efficient as electrolysis and ozone
oxidation. After several regenerations, the bleach becomes satu-
rated with sulfate salts which reduces bleaching efficiency, fouls
piping and pumps, and may require elevating the concentration of
ferricyanide in an attempt to maintain adequate bleaching.
Use liquid bromine to regenerate spent ferricyanide bleach.
The use of liquid bromine to regenerate ferricyanide is very efficient
and provides the bromine ions required for bleaching. In this
process, bromine serves as the oxidizing agent to regenerate
ferricyanide from the ferrocyanide overflow.
Use iron-complexed bleaches to replace ferricyanide bleaches.
This is not a ferricyanide bleach regeneration process, but rather
a recommended material substitution that in some cases may be
used to replace ferricyanide bleaches in certain processes alto-
gether. The iron-complexed bleaches are less environmentally
harmful and more easily recovered.
8.8 Construction
8.8.1 Industry Process Description
The construction industry generates hazardous waste in these
" processes:
• plumbing, heating, air conditioning;
• prefabricated wood buildings;
• terazzo, tile, marble, mosaic wall or floor work;
• roofing, sheet metal work;
1989 HHCHMR
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• painting, decorating;
• mobile home construction;
• other floor work; and
• glass, glazing work.
8.8.2 Sources of Waste
From a waste minimization standpoint, the primary types of con-
struction wastes can be grouped as:
• spent solvents,
• strong acids or alkalies,
• paint wastes with heavy metals,
• ignitable paint wastes, and
• other ignitables.
Some or all of the wastes within a single group may be combined
before treatment and disposal. However, wastes of different types
should be segregated. A description of the major construction
wastes organized according to these five common areas is pro-
vided in Table 8.6.
Spent solvents come from many construction processes, including
painting, cleaning, air conditioner maintenance, fluxing, and de-
greasing. Solvents are often used to clean tools and paint spray
guns and brushes.
Strong acids and alkalies are another waste source. Acid and
alkaline solutions are used in cleaning, degreasing, and plumbing
operations.
Paint wastes are common to the construction industry and are
generated by painting and other paint-related processes such as
paint preparation and paint brush and spray gun cleaning. These
wastes can contain a variety of ignitable solvents and/or heavy
metals such as lead.
Other ignitable wastes such as epoxy resins and adhesives are
also sources of hazardous waste in the construction industry.
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8.8.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
8.8.4 Specific Waste Minimization Practices
The most common waste minimization practices applicable to the
five main waste streams in the construction industry are summa-
rized in Table 8-6.
Table 8.6. Construction industry waste streams and
minimization practices.
Common
waste streams
Spent
solvents
Strong acid/
alkaline
wastes
Paint wastes
Primary process
waste description
Spent solvents from •
parts cleaning; wood
cleaning; oil and grease
removal; paint removal
and preparation.
Rust removers;
lacquer, paint and
varnish removers;
cleaners and degreasers.
Paint wastes con- •
taining flammable
solvents or heavy
metals.
Minimization
practice
• See Section 9.1
See Section 9.4
See Section 7.3
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Table 8.6. (continued)
Common Primary process Minimization
waste streams waste description practice
Other Epoxy resins, Exercise care in
adhesives; paint and handling liquids.
ignitables, varnish Substitute water-
based paints; clean- based removers.
ers and degreasers. Recycle solvents.
Spent Solvents
Spent solvents generated in the construction industry are similarto
those found in other industries. A detailed description of the
minimization of spent solvent wastes is found in Section 9.1,
Solvents.
Strong Acids/Alkalies
Strong acid and alkaline wastes generated by the construction
industry are similar to those generated in other industries. A
detailed discussion of waste minimization practices for acids and
alkalies is described in Section 9.4, Corrosive Wastes.
Paint Wastes
Paint wastes generated by the construction industry are similarto
those generated in other industries. A detailed discussion of waste
minimization practices for paint wastes is described in Section 7.3,
Paint Application.
Other Ignitables
Ignitable wastes otherthan paint wastes can include epoxy resins,
adhesives, gasoline, and paint and varnish thinners. The most
common means of minimizing these wastes are:
• Exercise care in handling liquids. Hand pumps or dispens-
ers should be used to transfer liquids such as gasoline and
kerosene. This reduces the probability of spills as well as the
occupational hazards associated with siphoning hoses.
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Substitute water-based paints. In many applications,
water-based paints can be used instead of solvent-based
paints. This reduces the amount of volatile solvents used,
and subsequently reduces the amount of solvent wasted.
Recycle solvents. Small-scale solvent distillation units can
be purchased to recover solvents from paint wastes (brush and
sprayercleaning) and used cleaning solutions. See Section 9.1
for more details on recycling solvents.
Educational and Vocational Shops
Industry Process Description
Educational and vocational shops can be divided into four groups,
each of which generates hazardous wastes:
• automobile engine and body repair,
• metalworking,
• graphic arts, and
• woodworking.
8.9.2 Sources of Waste
From a waste minimization standpoint, the primary types of educa-
tional and vocational shop wastes can be grouped as:
• photographic wastes,
• spent solvents,
• waste ink with solvents,
• waste ink with heavy metals,
• ink sludge with chromium or lead,
• strong acids or alkalies,
• spent plating wastes,
• ignitable paint wastes, and
• paint wastes with heavy metals.
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Some or all of the wastes within a single group may be combined
before treatment and disposal. However, wastes of different types
should be segregated. A description of the major shop wastes
organized according to these nine common areas is provided in
Table 8.7. A brief discussion of each follows.
• Photographic wastes include the heavy metal solutions used in
photographic developing and carbon tetrachloride solutions.
• Spent solvents account for the majority of wastes produced.
Solvents are used in virtually all vocational and educational
shops—automobile engine and body repair, graphic arts,
metalworking, and woodworking. Solvents may be used for
cleaning tools, paint spray guns and brushes, and in photo-
graphic developing and wood finishing.
• Waste inks can contain either ignitable solvents or heavy
metals. Ink sludge usually contains lead or chromium. Each
of these wastes is typically generated by graphic arts shops.
• Strong acids and alkalies are another waste source. Acid and
alkaline solutions are used in rust removal, metal etching, and
are found in lead acid batteries.
• Spent plating solutions from graphic arts shops are another
source of waste which may contain high concentrations of
heavy metals.
• Paint wastes are common to automobile repair shops as well as
graphic arts shops. These wastes can contain a variety of
ignitable solvents and/or heavy metals such as lead.
8.9.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste and may include:
• personnel practices,
• procedural measures,
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• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
8.9.4 Specific Waste Minimization Practices
The most common waste minimization practices applicable to the
nine main waste streams in educational and vocational shops are
summarized in Table 8-7.
Table 8.7. Educational and vocational shops waste streams
and minimization practices
Common
waste streams
Photographic
wastes
Spent
solvents
Waste ink
Ink sludge
Strong acid/
alkaline
wastes
Primary process
waste description
Waste carbon
tetrachloride;
spent processing
solution containing
heavy metals.
Spent solvents
from parts cleaning;
wood cleaning; oil
and grease removal;
paint removal and
preparation.
Waste ink with
solvents or
heavy metals.
Ink sludge with
chromium or lead.
Rust removers;
lacquer, paint and
varnish removers.
Minimization
practice
See Section 8.7
See Section 9.2
See Section 9.1
See Section 8.6
See Section 8.6
See Section 9.7
See Section 9.4
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Common
waste streams
Spent plating
solutions
Paint wastes
Table8.7. (continued)
Primary process
waste description
Spent plating
solutions.
Paint wastes con-
taining flammable
solvents or heavy
metals.
Minimization
practice
See Section 8.3.4
See Section 7.3
Photographic Wastes
Photographic wastes generated in educational and vocational
shops are similar to the wastes produced in the photographic
industry. Detailed discussions of waste minimization practices for
such wastes are in Section 8.7, Photography, and Section 9.2,
Halogenated Organic (Non-Solvent) Wastes.
Spent Solvents
Spent solvents generated in educational and vocational shops are
similar to those found in other industries. A detailed description of
the minimization of spent solvent wastes is found in Section 9.1,
Solvents.
Waste Ink
Waste ink generated in educational and vocational shops is similar
to the waste ink produced in the printing industry. A detailed dis-
cussion of waste minimization practices in the printing industry is
found in Section 8.6, Printing.
Ink Sludge
ink sludges generated in educational and vocational shops are
similar to those generated in the printing industry. Waste minimi-
zation practices in the printing industry are described in Section
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8.6, Printing. In addition, a discussion of waste minimization for
sludges appears in Section 9.7, Sludges.
Strong Acids/Alkalies
Strong acid and alkaline wastes generated by educational and
vocational shops are similarto those generated in other industries.
Waste minimization practices for acids and alkalies are described
in Section 9.4, Corrosive Wastes.
Spent Plating Solutions
Plating solutions are not discarded frequently, but do require
periodic replacement. Minimization practices available for the
reduction of spent plating waste are described in detail in Section
8.3.4.
Paint Wastes
Paint wastes generated by educational and vocational shops are
similarto those generated in other industries. Waste minimization
practices for paint wastes are described in Section 7.3, Paint
Application.
8.10
8.10.1
Analytical and Clinical Laboratories
Industry Process Description
Analytical and clinical laboratories can operate any number of the
following departments, each generating quantities of hazardous
waste:.
pathology
radiology
nursing units
equipment repair
laundry
embalming
clinical/research
histology
autopsy
dialysis
maintenance
pharmacy
sterile processing
laboratories
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8.10.2 Sources of Waste
From a waste minimization standpoint, the primary types of analyti-
cal and clinical laboratory wastes can be grouped as:
• formaldehyde,
• photographic wastes,
• mercury,
• pesticides, insecticides,
• strong acids or alkalies,
• oxidizers,
• ignitable paint wastes,
• paint wastes with heavy metals,
• spent solvents,
• halogenated solvents,
• poisons, and
• unused chemical reagents.
Some or all of the wastes within a single group may be combined
before treatment and disposal. However, waste of different types
should be segregated. A description of the major laboratory
wastes organized according to these eleven common areas is
provided later in this section in Table 8.8.
Spent solvents account for a large portion of the wastes produced.
Solvents are used in cleaning laboratory glassware, extractions,
and other laboratory procedures. Solvents may also be used for
cleaning tools, paint spray guns and brushes, and in photographic
developing. Most laboratory sections generate some kind of waste
solvent. These wastes can include alcohols and halogenated
solvents (e.g., carbon tetrachloride).
Strong acids and alkalies are another waste source. Acid and
alkaline solutions are often used as chemical reagents in clinical
and research laboratories, or as cleaning agents by maintenance
departments.
Photographic wastes include the heavy metal solutions used in
photographic developing. These are usually generated by radiol-
ogy departments.
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Waste formaldehyde is generated by those laboratory depart-
ments conducting autopsies or involved in embalming.
Paint wastes are common in the maintenance areas of larger
laboratories. Paint wastes can contain a variety of heavy metals
such as lead or ignitable solvents. Care should be taken to
segregate these wastes as much as possible to facilitate efficient
waste management.
Waste mercury is generated by accidental thermometer breakage,
and in the equipment repair sections dealing with sphygmoma-
nometers.
Waste pesticides and insecticides are often produced when exter-
minators attempt to provide a pest-free laboratory.
Waste oxidizers are occasionally produced from the use of oxidiz-
ers such as silver nitrate. Such chemicals were common laboratory
reagents in the past.
Poisons such as phenol and mercuric chloride are often generated
by clinical and research labs.
8.10.3 Good Operating Practices for Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste, and may include:
• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste mini-
mization program. A detailed discussion of good operating prac-
tices is provided in Section 7.1.
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8.10.4 Specific Waste Minimization Practices
The most common waste minimization practices applicable to the
11 main waste streams in analytical and clinical labs are summa-
rized in Table 8.8. Each of these waste minimization practices is
briefly described in the following sections.
Photographic wastes
Photographic wastes generated in analytical and clinical laborato-
ries are similar to the wastes produced in the photographic indus-
try. A detailed discussion of waste minimization practices for such
waste is contained in Section 8.7, Photography.
Spent Solvents
Spent solvents generated in analytical and clinical laboratories are
similar to those found in other industries. A detailed description of
the minimization of spent solvent wastes is found in Section 9.1,
Solvents.
Formaldehyde
Waste formaldehyde generated in analytical and clinical laborato-
ries can be minimized by the following procedures, which are
applicable to all laboratory chemicals:
• Purchase only necessary quantities. By purchasing only
amounts required for proper laboratory operations, laborato-
ries can lessen the probability that chemicals will become too
old for testing and analytical purposes—eventually becoming
waste.
• Store efficiently. Properly stored chemicals have a much
lower probability of contamination, thus increasing theirchances
for use within the laboratory. Proper storage can include:
- storing chemicals in a well organized, central location;
- organizing chemicals by their age, using the older
chemicals first; and
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- maintaining a list of all unused chemicals for possible
waste exchange.
Mercury
Waste mercury must be handled with extreme care due to its high
level of toxicity. One way of avoiding the generation of waste
mercury is to avoid breaking thermometers and the unnecessary
repair of laboratory equipment that contains mercury. See Section
7.1, Good Operating Practices. In addition, the following can be
beneficial in the minimization of waste mercury:
• Purchase only necessary quantities. By purchasing only
amounts required for proper equipment repair, laboratories
can lessen the probability that mercury is wasted—in addition
to lessening the probability of excessive exposure.
Strong Acids/Alkalies
Strong acid and alkaline wastes generated by analytical and
clinical laboratories are similar to those generated in other indus-
tries. A detailed discussion of waste minimization practices for
acids and alkalies is described in Section 9.4, Corrosive Wastes.
In addition, care should be taken in the management of acids and
bases used as laboratory reagents as described in this section
under Used Chemical Reagents.
Pesticides and Insecticides
Pesticide and insecticide wastes generated by analytical and
clinical laboratories are similar to those generated in other indus-
tries. A detailed discussion of waste minimization practices for
pesticide and insecticide wastes is described in Section 8.11,
Pesticides.
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Table 8-8. Analytical and clinical laboratory waste streams
and minimization practices.
Common
waste streams
Photographic
wastes
Spent solvents
Formaldehyde
Mercury
Primary process
waste description
Spent processing solu-
tions containing heavy
metals.
Spent solvents from
glass cleaning; oil,
grease, and
paint removal.
Waste formaldehyde
from embalming,
autopsies.
Waste mercury from
Minimization practice
• See Section 8.7.
See Section 9.1
Purchase only neces-
sary quantities.
Store efficiently.
See Section 7.1
broken thermometers; • Take care in handling
waste from instrument thermometers.
repair. • Purchase only nec-
essary quantitites.
Strong acid/alkaline Rust removers; lacquer,
wastes
Pesticides and
insecticides
Paint wastes
Oxidizers
Halogenated
organics
paint, varnish
removers; laboratory
reagents.
Waste pesticides and
insecticides from main-
tenance and grounds
crews.
Paint wastes containing
flammable solvents or
heavy metals.
Waste oxidizing labor-
atory reagents such as
silver nitrate.
Spent halogenated
hydrocarbons such as
carbon tetrachloride.
See Section 9.4.
See Section 8.10.
See Section 8.11.
See Section 7.3.
See Section 8.10.
See Section 9.2.
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Common
waste streams
Used chemicals
Poisons
Table 8-8. (continued)
Minimization practice
Primary process
waste description
Waste laboratory
reagents.
Waste such as phenol
and mercuric chloride.
See Section 7.1.
Purchase only neces-
sary quantities.
Make chemical substi
tutions.
Store efficiently.
Purchase only neces-
sary quantities.
Make chemical substi-
tutions.
Paint Wastes
Paint wastes generated by analytical and clinical laboratories are
similarto those generated in other industries. A detailed discussion
of waste minimization practices for paint wastes is described in
Section 7.3, Paint Application.
Oxidizers
Waste oxidizers are generated by analytical and clinical laborato-
ries as waste laboratory reagents such as silver nitrate. A detailed
discussion of waste minimization practices for chemical reagents
is described in this section under Used Chemical Reagents.
Halogenated Organics
Halogenated organic wastes generated by analytical and clinical
laboratories are similar to those generated in other industries. A
detailed discussion of waste minimization practices for halogen-
ated hydrocarbons is described in Section 9.2, Halogenated Or-
ganic Wastes.
Used Chemical Reagents
Waste chemical reagents can be minimized by managing chem-
© 1989
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icals more efficiently (see Section 7.1, Good Operating Practices).
In addition, the following can be beneficial in the minimization of
waste chemical reagents:
• Purchase only necessary quantities. By purchasing only
amounts required for proper laboratory operations, laborato-
ries can lessen the probability that chemicals will become too
old for testing and analytical purposes—eventually becoming
waste.
• Make chemical substitutions. By replacing hazardous
laboratory reagents with less hazardous alternatives, the
level of hazard in a laboratory's waste can decrease.
• Store efficiently. Properly stored chemicals have a much
lower probability of contamination, thus increasing their
chances for use within the laboratory. Proper storage can
include:
- storing chemicals in a well organized, central location;
- organizing chemicals by their age, using the older chemicals
first; and
- maintaining a list of all unused chemicals for possible waste
exchange.
Poisons
Waste poisons such as phenol and mercuric chloride can be
minimized in much the same way as the minimization of other
chemical reagents.
• Purchase only necessary quantities. By purchasing only
amounts required for proper laboratory operations, laborato-
ries can lessen the probability that poisons will become too
old or even illegal for testing and analytical purposes—eventu-
ally becoming waste.
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8.11 Pesticides
8.11.1 Industry Process Description
Pesticide formulators prepare pesticide products from pesticide
concentrates, solvents, carriers, and other additives. Pesticide
applicators apply the pesticide to the treatment site.
Pesticides are most commonly formulated into wettable powders,
dusts, emulsions, granules, and aerosols. Although the processes
involved in producing these various formulations are different,
there are general operations common to all of them. These com-
mon operations include:
• mixing,
• dissolving,
• blending, and
• packaging.
Pesticide applicators purchase the pesticide products, usually di-
lute them with water or another diluting agent, and apply the
pesticide to the treatment site using special application equipment.
8.11.2 Sources of Waste
Waste containing pesticides and other hazardous materials are
produced as part of the pesticide formulation and application
processes. The waste is principally a result of cleaning equipment
between batches, cleanup of spills, and the production of off-
specification product. Other pesticide wastes include the empty
pesticide containers (e.g., packages or drums) and dust collected
in air pollution equipment. These wastes are further described in
Table 8-9.
8.11.3 Good Operating Practices For Waste Minimization
Good operating practices are defined as procedural or institutional
policies which result in a reduction of waste, and may include:
'1989
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• personnel practices,
• procedural measures,
• loss prevention practices, and
• waste stream segregation.
Good operating practice applies for every waste stream and is one
of the first methods which should be investigated in a waste
minimization program. A detailed discussion of good operating
practices is provided in Section 7.1.
8.11.4 Specific Waste Minimization Practices
Common waste minimization practices which can be applied in
pesticide formulation and application operations are summarized
in Table 8-9.
Each of these waste minimization practices are briefly described in
the following sections.
Rinse Water or Absorbent
A typical pesticide formulation plant produces different pesticides
using the batch process. Between batches, tanks and other
equipment must be cleaned to avoid contamination between the
various products. Also, applicators apply different pesticides using
the same equipment. This necessitates cleaning the equipment
between applications in addition to normal cleaning operations.
Equipment used in the formulation or application of liquid pesti-
cides are usually cleaned with water, while equipment used in the
formulation of "dry" pesticides (e.g., powders and granules) are
cleaned using a dry, inert material such as clay. Methods to reduce
rinse water or absorbent waste follow.
Store and reuse rinse water or absorbent. Rinse water or ab-
sorbent from equipment cleaning can be collected and stored for:
• reuse as make-up water, diluent, or carrier during the next
formulation of the same product;
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reuse as rinse water or absorbent in future equipment cleaning.
Where more than one rinse is needed to clean the equipment,
the first rinse can be performed using old rinse water. That rinse
will remove most of the residue, while fresh water can be used
for the second rinse.
Use high pressure spray nozzles. Use of high pressure rinsing
systems can reduce water consumption and rinse water produc-
tion by 80-90 percent.
Use dry absorbents for spill clean-up. This greatly reduces the
waste volume associated with spill clean-up in comparison to
washing down the area with water.
Sweep floor to collect spills for product reformulation. This
obvious practice has been successfully used to reduce "dry"
pesticide waste volume.
Off-Specification Products
Off-specification pesticide formulations or incorrectly prepared
pesticide spray mixtures are produced as a result of poor process
control and operation. This waste source can be reduced by using
the following methods.
Strict process control or automation. This technique helps
ensure that a high quality formulation or mixing process is repeat-
able and avoids aspects of operator error.
Reformulate off-specification batches. Instead of discarding
off-specification batches as waste, they should be reformulated to
bring them into product specification.
Packages and Drums
Emptied drums or packages used to store or transport pesticides
still contain a pesticide residue. Cleaning the drums to reuse them
internally produces pesticide waste. Disposal of drums treats them
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Table 8-9. Waste categories of pesticide formulations, and
applicators and minimization practices.
Waste category Source
Rinse water or
absorbent
Off-specification
products
Packages
and drums
Dust collected in
air pollution
equipment
Equipment
cleaning, spills
area washdown.
Poor process
control.
Pesticide residue
in drums.
Empty packages
or drums.
Dust generated
during handling,
grinding, and other
formulation
operations.
Minimization practice
• Storage and reuse of rinse
water or absorbent.
•Use of high pressure spray
nozzles.
• Useofdryabsorbentsforspill
cleanup.
•Floor sweeping to collect
spills for product reformula-
tion.
• Strict process control orauto-
mation.
• Reformulation of off-specifi
cation batches.
• Rinse drums using minimum
amount of water and reuse or
recondition them.
• Use refillable or returnable
bulk tote drums bins.
• Recycle dust into process
where it was generated.
as waste and can be a waste disposal problem. These two
recommendations can help you avoid or minimize these problems:
Rinse drums using a minimum amount of water. Triple rinsing
with the use of high pressure spray systems can significantly
reduce the production of pesticide rinse water.
Use refillable or returnable bulk tote bins. Containers that can
be refilled or returned to the supplier eliminates the need for their
disposal.
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Dust Collected in Air Pollution Equipment
Pesticide dust particles are produced during the grinding and
handling operations associated with the formulation of "dry" pesti-
cide formulations.
Recycle collected dust into process where it was generated.
Pesticide dust particles collected in dust collection equipment can
be reintroduced into the formulation process, thereby reducing
waste production.
Product Substitution
For some pesticide applicators who are also pesticide users (e.g.,
farmers and greenhouse operators), reducing the use of pesticides
can be a means of reducing pesticide waste. Integrated pest
management (IPM) is a pest control strategy that does not rely
solely on the use of man-made pesticides. Pest control methods
included in an IPM program follow.
Biological control. Pests can be controlled by introducing their
natural predators into the infested fields. Some natural predators
can be purchased from insectaries.
Genetic control. Crop species that are bred to resist certain dis-
eases or pests can be planted.
Cultural control. Pests may be controlled by selecting certain crop
rotation schedules, or by timing the planting and harvesting sched-
ule to avoid the pest, and through other agronomic measures.
Chemical control. Use of pesticides is also part of an IPM program
in which pesticides are used only when necessary to keep pest
populations below levels where they cause economic loss.
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CHAPTER
9.0 WASTE-SPECIFIC MINIMIZATION
PRACTICES
This chapter describes minimization practices for seven specific
wastes:
• solvents,
• halogenated organic (non-solvent) wastes,
• metal wastes,
• corrosive wastes,
• cyanide and reactive wastes,
• oils, and
• sludges.
i
In addition, information is given about off-site recycling and recov-
ery centers
9.1 Solvents
9.1.1 Source of Solvent Wastes
Solvent wastes are generated primarily by industrial operations
that include:
• painting and coating shops that use solvents to clean
equipment;
• metal-working and machine plating shops that use solvents
during degreasing; and
• surface cleaning processes in the electrical, electronics, and
printing industries.
9.1.2 Solvent Recycling Technologies
The main solvent recycling and minimization techniques are:
• Distillation. Separation techniques that rely on the boiling
point differences between the components of a liquid waste.
• Solids removal. Elimination of suspended particles to
reduce fouling.
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Emulsion or dispersion breaking. Separation of solvent
or oil droplets in water, or of water droplets in oil.
Dissolved and emulsified organics recovery. Organics
separation techniques that concentrate the organics so
they can be recovered.
Each of these operations may be performed singly or in sequence.
The recyclable product may be the solvent or the isolated contami-
nants, or both.
9.1.3 On-Site Recycling Equipment
Due to recent developments, small solvent recycling units are now
commercially available for businesses generating low volumes of
waste solvents. These simple heating and condensing systems
remove impurities from the solvent waste streams, returning the
solvent or the solvent blend to the process which generated it.
• A B/R Instrument Corporation solvent recovery system was
used by a laboratory at Toronto General Hospital. The distilla
tion unit cleaned xylene and chloroform to 100 percent purity
and isopropyl alcohol to 99.7 percent. The lab recovered
$180 per week of solvents which would otherwise have
required costly off-site disposal.
Some companies have been able to scale down their equipment
considerably since the equipment was first marketed.
• The Brighton Corporation introduced its first solvent recovery
system over 20 years ago. They now manufacture units
with capacities as small as 7.5 gallons of solvent treated
per hour.
• There are numerous manufacturers of solvent recovery
equipment in a variety of sizes. The smallest of these units
reclaims solvents having a boiling point of 160°C or less.
The waste solvent is reclaimed in 15-gallon batches,
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although clean solvent can be drawn off during operation.
Recovery levels range from 80 to 95 percent, depending on
the amount and type of contamination. Check one of the
equipment buyers' guides or other information source given
in Chapter 11 for a list of manufacturers of solvent recovery
equipment.
9.1.4 Solvent Loss Minimization Practices
Solvents are used most frequently in:
• the soak tank, and
• the vapor degreaser.
The vapor degreaser, because it produces considerable air pollu-
tion, has been studied in much greater detail with respect to
pollution control. However, the primary methods for reducing
waste are the same for both the degreaser and the soak tank. The
two most important goals are to minimize solvent vapor loss and
maintain solvent quality. The following methods were considered
the most successful in achieving these objectives
Install lids/silhouettes on tanks. All tanks should be covered
when not in use. Covers that can be used during the cleaning
process (known as "silhouette entries") are available and allow for
even greater reduction in vapor loss. All covers should be designed
to slide horizontally over the top of the tank, since this disturbs the
vapor zone less than hinged covers.
Increase the freeboard space on tanks. An increased freeboard
has been proven to decrease emissions. Early degreasers had a
freeboard equal to one-half the tank width. When the U.S. EPA in
the mid-1970s recommended a 75 percent freeboard, emissions
were decreased up to 46 percent. Increasing the freeboard to 100
percent can provide an additional 39 percent reduction when air
turbulence is present.
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Install freeboard chillers in addition to cooling jackets. A sec-
ond set of refrigerated coils is installed above the condenser coils.
These coils chill the air above the vapor zone and create a second
barrier to vapor loss. Reductions in solvent use of up to 60 percent
have been realized. However, water contamination of the solvent
can occur due to frost buildup on the coils, so special water
collection equipment is also necessary.
Implement better operating practices. Several housekeeping
measures can significantly affect the amount of solvent waste
produced.
• Separators should be cleaned and checked frequently to
avoid cross contamination of solvents or water which can
lead to acid formation. Also, parts should not enter the
degreaser while wet.
• Promptly remove sludge collected at the bottom of the tank.
This increases cleaning efficiency because contaminants
do not absorb solvent and dissolve into the solution. As
solvents are used, their ability to neutralize acids lessens.
While the common practice is to add new solvent to the aged
solvent, a more efficient method is to analyze the solvent
and add specific components. The expense of analysis will
be offset by the savings in solvent for tanks of approximately
500 gallons or more.
• Other waste reduction techniques, based on better
operating practices, include:
- standardizing the solvent used to allow for easier
recycling,
- consolidating cold cleaning operations into a centralized
vapor degreasing operation,
- locating cold cleaning tanks away from heat sources,
- controlling the amount of heat supplied to vapor
degreasers,
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avoiding spraying parts above the vapor zone or
cooling jacket, and
avoiding solvent vapor drag-out.
9.2 Halogenated Organic (Non-Solvent) Wastes
9.2.1 Source of Halogenated Organic Wastes
Non-solvent wastes are generated primarily by:
• the pesticide and fertilizer industry, which generates
chlorinated pesticide dust and rinse waters;
• miscellaneous repair services, which generate PCB-con-
taminated fluids (during the maintenance and repair of
electrical transformers) and contaminated specialty organic
cleaning fluids; and
• the lumber and wood products industry, which generates
chlorinated organic wastes from the manufacture of wood
preservatives and from application of pentachlorophenol to
lumber products.
Halogenated organic wastes include both liquid and solid waste
streams.
9.2.2 Non-Solvent Recycling Technologies
These are the main non-solvent recycling and minimization
practices:
• Use of waste as fuel. Halogenated organic wastes are
used as fuel in cement kilns. Energy in the form of heat
is recovered, as well as acid gas, which reacts with free
alkali in the cement to produce a low-alkali cement.
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• Baghouse filters. Pesticides and pesticide intermediates
are usually recycled on site. Baghouse filters are used to
collect dust and particulates generated by product drying or
blending.
Recycling opportunities are generally more restricted forthis class
of materials because:
• some of these wastes, especially those containing poly-
halogenated aromatics, may be contaminated with dioxins; and
• markets for some of the recycled products, such as carbon
tetrachloride, have been declining sharply in recent years.
9.2.3 Halogenated Organic Waste Minimization Practices
Solid waste is generated from the collection of dust in baghouses
during material handling, grinding, blending, and standardizing
operations. These waste minimization techniques are available:
Use wet instead of dry grinding. Then spray dry the output to
reduce the amount of dust emitted.
Increase the use of dust suppression techniques. Atomized
water sprays, enclosed weigh-transfer hoppers, or better care
during manual handling will all decrease dust emission.
Recycle baghouse fines. Baghouse emptying should be sched-
uled to encourage recycling.
Better operating practices. As always, closer attention to han-
dling, storing, and spill prevention will increase plant efficiency.
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9.3 Metal Wastes
9.3.1 Source of Metal Wastes
Metal wastes are generated primarily by these industrial applica-
tions:
• Electroplating, photofinishing, and printing commonly
produce process and rinse waters contaminated with silver,
nickel, zinc, tin, copper, chromium, lead, or cadmium.
• Equipment cleaning in the steel and metallurgy industries
generates aqueous solutions containing toxic metals and
oxides.
• Manufacture of leaded paint and gasoline generates
sludges containing metals.
9.3.2 Metal Recovery From Waste Rinse Waters
These technologies are available to recover metals from waste
rinse water before treatment:
Evaporation. Waste rinse water is evaporated by heating, leaving
behind a concentrated solution. The solution is concentrated until
its metals content is equal to that of the plating bath. This solution
is then reused. This method has been used frequently for chro-
mium recovery from rinse water.
• One plant was able to recover 8,000 pounds of chromium
per month—resulting in savings of $100,000 per year, with a
1-year return on investment.
Evaporation should be combined with multiple countercurrent
rinse tanks or spray/fog rinsing. Rinse water should be deonized
orsoftened priorto use in orderto prevent calcium and magnesium
salt buildup.
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Reverse osmosis. At high pressure, dilute waste is applied to a
membrane. This allows the water to pass through, but retains the
metals and other solutes. Thus, on one side of the membrane, a
concentrated metal solution is produced which can be returned to
the plating bath. On the other side of the membrane, water is
collected and can be reused as rinse water. Reverse osmosis uses
less energy than evaporation, but the characteristics of the mem-
branes available limit the type of waste streams that can be treated.
Only very dilute streams can be treated, and the solution must be
pre-filtered to extend membrane life.
Ion exchange. This involves passing a solution over an ion-
exchange resin which exchanges one of its own ions for a metal ion
in solution. Once a resin has reached its capacity, it must be
regenerated. This is accomplished using an acid or base depend-
ing on the resin. Another step may be necessary to remove the
metal from the acid or base so the metal can be used.
Electrolytic metal recovery. Metal ions in solution are plated
electrochemically onto a cathode surface within the solution.
When the cathode becomes fully coated with the metal, it is
removed from the solution and placed into a plating bath as an
anode, replenishing the bath with the metal. One advantage of this
method is that it recovers only the plati ng metal, not the impurities,
from the waste rinse water. This method is most efficient with
solutions of metal ions in concentrations greater than 100 mg/l
(milligrams per liter), and has been used to recover copper, tin,
gold, silver, cadmium, and other metals.
Electrodialysis. An electric current and selective membranes are
employed to separate the positive and negative ions from a
solution into two streams. While electrodialysis is used mainly to
concentrate dilute solutions of salts or metal ions, it has been used
to remove nickel, copper, cyanide, chromium, iron, and zinc from
waste rinse water.
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9.3.3 Metal Waste Recovery Technologies
These are the main metal waste recovery technologies:
Agglomeration. This is a process which gathers small particles
into larger particles, where the small particles can still be identified.
Because of their metallic contents, mill scale, sludges, and dusts
from various industries are agglomerated to be used in blast or
induction furnaces. Agglomeration avoids paniculate carryover
from furnaces.
Particulate and vapor recovery from gases. Metals are usually
recovered as fine particles. Cadmium dust generated from cad-
mium batteries or pigment plants can be recycled. More volatile
metals (such as mercury or lead) must be recovered from the vapor
phase.
Metal concentration process. There are several methods for
concentrating metals from a bulk solid or liquid into a sludge or
solution. Unit operations for concentrating metals include hydro-
metallurgical processing, solvent extraction, ion exchange, and
others. These processes have been developed either to recycle
the metals or to treat the bulk stream to render it non-hazardous.
• Vulcan Materials Inc. leaches contaminated brine muds
with sulfuric acid to convert the solids to non-hazardous
gypsum and recover the mercury.
• Nickel-plating solutions are reacted with soda ash to pre-
cipitate nickel carbonate, which then is collected and
reacted with sulfuric acid to generate an impure nickel-
sulfate solution. Adding small quantities of sodium sulfide
will precipitate iron salts as iron sulfide. The solution is next
separated from iron sulfide by filtration and evaporated to
recover pure nickel sulfate. Spent nickel catalysts, after
being dissolved with mineral acid, can be treated the same
way.
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Metals reduction techniques. Recover metal from rinse water
before treatment. Waste must be concentrated before application
of a reduction technique.
• In electrolytic recovery, metal ions migrate to the cathode
where they are reduced to their elemental form and are
plated out. See Section 9.3.2.
• A recently developed process involves addition of sodium
borohydrate to neutral or alkaline solutions of metals and
the precipitation of metals in their elemental form by reduc-
tion. After filtration, the metals can be sold directly to scrap
metal dealers.
9.4 Corrosive Wastes
Corrosive wastes are generated by industries that use acidic or
alkaline solutions in production or finishing processes.
9.4.1 Source of Corrosive Wastes
Some of the primary industries that generate corrosive wastes
include:
• metal-finishing industries, which produce corrosive wastes
during electroplating, etching and cleaning operations,
among others (spent alkaline cleaning solutions and
pickling solutions are the most frequently generated wastes);
• electrical and electronics industry, which generates
spent metal-bearing acid solutions from the cleaning of
scale from metals during the production of semiconductors,
and from etching of metal circuit boards; and
• textile mill industry, which generates spent sodium
hydroxide from mercerizing.
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9.4.2 Corrosive Waste Recycling Technologies
Corrosive wastes that are recycled include spent acids and alkalies
from chemical manufacture and petroleum refining processes —
and also the acid from spent pickle liquor. The following technolo-
gies are commonly used to recycle corrosive wastes.
Thermal decomposition. This process is used in the recovery of
su If uric acid from spent acid sludges to recover ferric chloride from
acidic titanium dioxide waste. Thermal decomposition is also used
to recover hydrochloric acid from spent pickling liquor or haloge-
nated organic residues.
Evaporation. Liquid waste is partially evaporated by heating,
leaving a concentrated solution. Both atmospheric and vacuum
evaporators are used to concentrate corrosive wastes. Evapora-
tion is applicable only to concentrated acids or bases with low
amounts of volatile organics.
• Spent acid containing 70 percent su If uric acid is generated
from the production of nitrobenzene by reacting benzene with
nitric acid in the presence of sulfuric acid. After removal of
organic impurities by stripping, the spent acid is concen-
trated by evaporation for reuse in the nitration process.
Crystallization. Corrosives are removed from a solution by cool-
ing. The resulting crystals are then separated from the solution by
a variety of methods.
Ion exchange. Ion-exchange resins can remove heavy metals
and cyanides from acid and base solutions. The purified solutions
can then be reused in the manufacturing process.
• A recent ion-exchange process developed by Eco-Tech Ltd.
of Canada purifies acid solutions by ion exchange without
producing a waste regenerant stream. The process uses a
resin that selectively removes acids and rejects metallic con
taminants. Metallic salts pass through the resin
bed and are collected. The bed is flushed with water to
displace the acid for reuse.
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9.5 Cyanide and Reactive Wastes
The category of cyanide and reactive wastes includes wastes with
cyanide constituents, sulfides, explosives, strong oxidizers and
reductants, and wastes that react violently with water.
9.5.1 Source of Cyanide and Reactive Wastes
Cyanide and reactive wastes are generated almost exclusively by
the metal finishing and processing industries. The primary appli-
cations in which they are generated include:
• cyanide baths used to keep soluble metals in solution so
they can be used in either electroplating or stripping solu-
tions; and
• spent process solutions, contaminated rinse waters, and
accidental spills.
Other industries which generate reactive wastes include those
involved in explosives and propellant manufacture.
9.5.2 Cyanide Waste Recycling Practices
Cyanide waste waters generated from precious metal benefi-
ciation are commonly recycled. Cyanides from other industries are
not presently recycled, since the low cost of fresh cyanides makes
it economically unfeasible. The waste is destroyed by chemical
oxidation before discharge to municipal treatment plants, since the
EPA banned land disposal of cyanides several years ago. These
practices can be used for recycling cyanide wastes.
Refrigeration/crystallization. This method recovers and re-
cycles cyanide from plating solutions that contain excess amounts
of sodium carbonate. This technique was patented by the Depart-
ment of Defense (DOD). Although it was thought to be promising,
widespread use is believed to be limited because of the formalities
involved in obtaining permission from the DOD to use the process.
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Evaporation. This involves the evaporation of water from waste,
leaving a concentrated solution behind.
Ion exchange. A resin is used that selectively absorbs acids and
rejects cyanides. The bed is then flushed with water to collect the
acid for reuse.
Membrane separation. This includes reverse osmosis and elec-
trodialysis (see Section 9.3.2).
9.5.3 Reactive Waste Recycling Practices
The primary barrier to recycling reactive wastes is a technical one.
In specialized applications of alkali metals such as lithium, recy-
cling purified wastes is impractical, since contamination with ox-
ides, dirt, oils, and many otherthings affects product quality. These
are available technologies for recycling reactive wastes:
Ammonium perchlorate separation by filtration and
evaporation. Research is under way at DOD facilities to examine
the feasibility of recovering reactive wastes. The proposed opera-
tion involves concentration of ammonium perchlorate solution to
12 percent, evaporation of the concentrated solution, and then sale
of recovered ammonium perchlorate to a contractor.
Separation of propellants constituents by solubilities. Re-
search is also underway at DOD facilities to separate and recover
propellents from rocket cases on the basis of differences in
solubility. Forexample, ammonium perchlorate and inorganics are
soluble in hot water. RDX (cyclotrimethylene base trinitroamine) is
insoluble in water—but soluble in acetone. HMX (cyclotetrameth-
ylene tetranitroamine) is insoluble in water and acetone, but
soluble in dimethyl sulfoxide (DMSO) and dimethyl forma- mide
(DMF). Recovery of HMX from acetone is possible by evaporation
of acetone. Removal of HMX from a DMSO or DMF solution can
be achieved by crystallization followed by liquid-solid separation.
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Sodium. Waste sodium is recovered from wastes from the Downs
Cell Process for sodium manufacture. The technology was dis-
cussed earlier (Section 9.3.3, Metal Reduction Techniques).
• Ventron, a manufacturer of sodium borohydride, accepts
sodium waste for reprocessing by this process to recover
sodium. About 600 tons/year of impure sodium waste are
returned for reprocessing.
9.6 Oils
9.6.1 Source of Oil Wastes
Oil wastes are generated primarily by:
• oil and grease removal in vehicle maintenance,
• cleanup operations in industries such as the paper industry,
and
• equipment repair operations.
9.6.2 Off-Site Collection Centers
There are many used oil collection sites in most states. Although
these centers were generally established forthe purpose of receiv-
ing used oil from households, some may be willing to accept used
oil from businesses. For a list of the centers nearest you, please
call your state's waste minimization technical assistance program
(see Chapter 11), state environmental regulatory agency, orCHMR's
toll-free Hazardous Materials Hotline, (800) 334-CHMR.
9.6.3 Oil Recycling Technologies
These are the main oil recycling and minimization practices:
Separation. An oil/water separator uses a series of vertical and
horizontal corrugated plates to force oil to the surface of the unit
©1989 BHICHMR
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where it is skimmed off. Oil droplets coalesce and rise to the
underside of the plates. Eventually the oil passes through weep
holes to the upper surface where it is collected by a skimmer. A
computer simulation program allows precise calibration of the
plates to maximize recovery from a specific waste stream.
Centrifugation. A centrifuge system decants the oil and removes
dirt and metal clippings from the slurry. Centrifuging oil slurries and
sludges allows for the sale of the water-free oil to power stations or
other industrial plants—or for reuse by the same plant.
Continuous flow electrochemical waste treatment processes.
These are custom designed for each application, so they can be
scaled down for use by small businesses. Biological oxygen
demand (BOD) and suspended solids are reduced. The process,
combining electrostatic and electrolytic principles with chemical pH
adjustments, reduces sludge production considerably.
Solvent extraction. Dimethylformamide (DMF) solvent extracts
PCBs from waste oils. By washing with water in the second stage,
solvent is separated and a PCB concentrate is left.
Dechlorination. Sodium compounds are used to dechlorinate
PCBs. A nonhalogenated organic compound and a sodium salt are
generated.
Each of these technologies has been used with good results.
• The Alfa-Laval centrifuge system, for example, has had
varied applications to reclaim oil: from the waste slurry of a
car manufacturer to the wash water of an industrial apparel
cleaning firm.
• The Iron and Steel Industrial Corporation Works installed a
mechanical skimming and chemical processing unit, recover
ing 40,000 liters of oil a month and saving $100,000 a year.
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9.6.4 Oil Loss Minimization Practices
Good operating practices, which can be implemented with little
cost, can have a large effect on the amount of oil waste produced.
These housekeeping practices can minimize oil waste:
Prevent spills. Using properly designed storage tanks and docu-
menting the dollar value of any spillage which does occur can
lessen the probability of a spill.
Install collection/drip pans. Placing pans under machinery and
lubricating operations will allow for the recovery of oils instead of
their disposal with absorbents or rags.
Launder oil-soaked rags. During laundering, oil can become
biodegradable.
Use rags and absorbents to their limit. Absorbents and rags are
often thrown out before their useful life is over. Use them to
capacity to reduce the volume of contaminated absorbents.
9.7 Sludges
9.7.1 Source of Sludges
Sludges are generated primarily by industrial applications such as:
• electroplating and other metal manufacturing operations,
• crude oil cleaning in the petroleum refining industry, and
• paint stripping activities.
9.7.2 Sludge Minimization Practices in Storage Tank Cleaning
Sludge buildup can greatly reduce the efficiency of an operation.
These waste minimization practices are available for reducing the
generation of sludge:
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Reduce lead in gasoline. The toxicity of tank sludges will be
lower.
Install storage tank agitators. This will prevent the deposit of
settling solids and hence reduce the need for cleaning.
Use corrosion resistant material. The use of a liner or construc-
tion materials which are more resistant to corrosion will reduce
sludge production.
Prevent the oxidation of crude oil. This prohibits the formation
of gums and resins. Oxidation can be minimized by providing a
nitrogen blanket over the surface or by using floating roofs.
Dry sludge to reduce disposal volume. The Truth Division of
Sealed Power, Inc., a manufacturer of door and window hardware,
installed a sludge drier. They experienced a 65 percent reduction
in the volume of metal hydroxide sludge. They estimate savings of
$18,200 a year in disposal costs.
9.7.3 Sludge Minimization Practices in Utility Production
Sludge that settles in a cooling tower basin is removed whenever
the cooling tower is out of operation. Here are some suggestions
to reduce sludge volume:
Install air coolers. This reduces the contamination of cooling
water with process fluid, as well as the volume of cooling water in
circulation.
Prevent leaks in the heat exchanger tube. Cross contamination
from the process side of heat transfer equipment is one of the
sources of sludge-creating materials. The use of seal welded tube
joints, or double tube sheets, will minimize process fluid leakage
into the cooling water, and vice versa.
Properly treat cooling tower water. Operators should refrain
from overtreatment to avoid excess buildup due to chemical
addition.
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9.8 Off-Site Recycling and Recovery Centers
For many small businesses, it may be impractical to install certain
recycling technologies described in previous sections of this chap-
ter. However, there are numerous commercial facilities nationwide
which operate hazardous waste recovery processes. For more
information on these facilities or other commercial hazardous
waste facilities in neighboring states, call your state's waste mini-
mization regulatory agency, or CHMR's toll-free Hazardous Mate-
rials Hotline, (800) 334-CHMR.
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10.0 Financing a Waste Reduction Program
Occasionally, small businesses may require assistance accumu-
lating the capital necessary to start a waste minimization program.
This chapter reviews financial assistance that is available from
private and public sources. Addresses and phone numbers are
provided for those interested in obtaining more information on
specific forms of funding.
10.1 Types of Assistance
There are several types of assistance available to a company
wishing to finance a waste minimization program. These options
fall into the two basic categories:
• private funding, and
• government-assisted funding.
While most people are aware of the resources available through
private funding, many are not aware of the many government
programs to assist business with waste reduction. Also, there
have been several cases of communities helping to raise money for
a local business if the project is seen to be in the public interest.
10.2 Private Funding of Waste Minimization Programs
The private resources available for funding a waste minimization
program are the same as those for any other business improve-
ment. A bank loan is one option. For a public corporation, the
issuance of stock is possible. Often banks are willing to grant a loan
to a local industry to keep the business competitive and to promote
a clean environment. A strong local industry will promote a
profitable future forthe bank. Also, the public relations benefits and
exposure which can be gained by funding environmental programs
are good for business. However, experience has shown that banks
are reluctant to loan money for pollution control (or waste minimi-
zation) projects that do not also increase the efficiency and produc-
tivity of the business.
CHAPTE]
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Two examples of innovative private funding for waste minimization
programs are presented below. These financing programs arose
from the compliance requirements of the 1977 Clean Water Act,
which threatened the electroplating industry.
• The U.S. EPA estimated that Minneapolis/St. Paul could
lose up to 20 percent of its electroplating industry if those
companies were forced to purchase conventional treatment
technology in order to meet the new standards. Consequently,
nearly all electroplaters faced a simultaneous need to im-
prove waste management.
The Metropolitan Council, the Twin Cities' regional planning or-
ganization, appointed ataskforce composed of members of the
trade associations and the regulatory agencies to coordinate
industry-wide compliance with the new waste water require-
ments. The study was funded by industry donations and agrant
from the Minnesota Economic Development Section. Upon
completion of the study, an industry-dominated corporation
was set up to finance and develop the proposed treatment
facility. In 1983 a site was purchased; in 1984 ion-exchange
technology was tested; and in 1985 applications were made for
the required permits and licenses. A pooled industrial bond
offering was prepared to finance the $6.5 million capital
investment.
• In New Jersey, The Master's Association of Metal Finishers
(MAMF) established a non-profit arm, the Research Foun-
dation, to examine the feasibility of a centralized treatment
facility for use by metropolitan New York-New Jersey
electroplaters. Ninety members of MAMF each paid $2,500,
and additional assistance was obtained through grants and
of other sources, including the the Port Authority of New
York and New Jersey, the New York City Office of Eco-
nomic Development, and the New York Community Trust. A
study determined that a conventional treatment system
would cost each company approximately $200,000 to pur-
chase and install at their own plants. On the other hand, it
was determined that the centralized system would save the
companies at least $14,000 a year compared to the costs of
operating their previous systems.
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Each participating shop was to install an ion-exchange re-
covery system. When the ion-exchange resins are full, they are
to be transported to the Central Recovery System (CRS),
where the metals will be removed and sold to industries which
can use them in the manufacturing process.
10.2.1 Business Development Corporations
One approach to private funding involves the use of business
development corporations (BDC). Through a BDC, financing is
provided in conjunction with another lending institution. BDCs are
private lenders who secure loans for businesses which would not
normally be approved for conventional financing. Therefore loans
must be evaluated by the BDC and the conventional institution, if
one is participating. Under this program, loans must be used to
purchase land or buildings, to rehabilitate or construct buildings,
and/or to purchase equipment, machinery, furniture, fixtures, and
pollution control equipment. Funds may also be used to make
leasehold improvements.
For additional information, contact the appropriate member of the
National Association of Business Development Corporations given
in Section 10.4.1.
10.2.2 Venture Capital
Venture capital financing involves direct investment of capital in a
business by a private group. The investment is generally struc-
tured to allow the group to convert their equity position into cash
or other liquid assets within a few years. There are private sources
of venture capital, as well as capital firms licensed by the Small
Business Administration (SBA), called the Small Business Invest-
ment Companies (SBIC). Your regional SBA office can refer you
to the SBIC in your area.
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10.3 Government-Assisted Funding of a Waste
Minimization Program
Federal and state governments have both addressed the issue of
financing waste minimization programs. Each has its own method
of determining eligibility and dispensing money. These are exam-
ined separately below.
10.3.1 Federal Assistance
To date, there are no specific financial assistance programs
geared toward waste minimization on the Federal level. The
Federal government makes a distinction between pollution control
and waste minimization. Waste minimization efforts are not eligible
for the pollution control programs the government runs. This
"realized waste" clause specifically requires that the assistance
funds be used to construct facilities to treat or store waste. Any
equipment or modification that reduces or eliminates the produc-
tion of waste is not eligible.
In fact, some pollution control facilities have lost some of their
incentives under the new tax laws. While they previously enjoyed
tax-exempt bond status, the new laws have transferred that status
to hazardous waste treatment facilities. RCRA prohibits issuance
of tax-free industrial bonds for funding equipment purchases or
modifications to bring a business into compliance with RCRA. Also
under RCRA, certain on-site waste recycling practices require a
"Part B" authorization from the U.S. EPA. Many industry leaders
feel this is an extreme disincentive because of the cost to achieve
compliance and to gain authorization.
Following is a list of organizations to contact for several of the
Federal loan programs which are candidates for waste minimiza-
tion financing. A brief description of the eligibility requirements is
also given.
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Small Business Administration (SBA)
Small Business Administration loan candidates for the following
two programs must be small businesses unable to obtain private
financing at reasonable rates and must be unable to qualify for
conventional long-term asset financing. Each program has its own
restrictions on the use of funds.
Business Loan Program (7A)
Office of Business Loans
Small Business Administration
1441 L Street, N.W.
Washington, DC 20416
(202) 653-6696
Section 503 Programs
Office of Economic Development
Small Business Administration
1441 L Street, N.W.
Washington, DC 20416
(202)653-6416
The SBA manages one program specifically to help businesses
meet pollution control or hazardous waste disposal regulations.
This program, the Pollution Control Financing Program, helps
businesses secure loans to cover capital costs incurred while
implementing a pollution control project. The address is:
Pollution Control Financing Guarantees
Pollution Control Financing Branch
Small Business Administration
4040 North Fairfax Drive
Arlington, VA 22203
(703) 235-2902
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EDA and FHA Loan Programs
Economic Development Administration (EDA) and Farmer's Home
Administration (FHA) loans may be used for business and indus-
trial construction; and the purchase and development of land,
easements, equipment, facilities, machinery, supplies or materi-
als; and working capital.
U.S. Department of Commerce
Economic Development Administration (EDA)
Room 7839
Washington, DC 20230
(202) 377-2621
FHA-Business and Industry Loan Guarantees
Farmer's Home Administration
Business and Industry Division, Room 5420
South 14th and Independence Avenue, S.W.
Washington, DC 20250
(202)475-4100
10.3.2 State Assistance
There is a wide variation in the type and number of assistance
programs at the state level which can assist businesses in financ-
ing waste minimization programs. Three main areas in which a
state may assist a business include:
• technical assistance,
• loans, and
• grants.
Each of these will be discussed briefly in the following sections.
© 1989 IHH CHMR
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Technical Assistance
Technical assistance and information dissemination are indirect
forms of financial assistance. This is especially valuable for smaller
businesses which lack the resources to research and develop their
own programs.
Typically, technical assistance programs are involved in three
areas:
• identification and collection of technical information useful
to local industries,
• preparation of appropriate informational material, and
• dissemination of information.
A list of state technical assistance programs is provided in Section
11.2.
Loans
In many states offering loan programs, most of the loans available
require applicants to meet three eligibility requirements similar to
the Federal ones. Applicants must be:
• small- to medium-sized businesses,
• unable to secure a loan through conventional financing sources
and not have the capital to finance the program on their
own, and
• classified in a standard industrial code classification that has a
high potential for waste minimization.
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Funding for such programs comes from a number of sources.
Some states, while not directly involved in financing programs, can
still direct small businesses to existing sources of financing on
Federal and local levels. In all cases, state development agencies
are an excellent reference. A list of state agency contacts is
provided in Section 10.4.2.
Grants
A few states offer grants to offset the installation and capital cost
of recycling equipment. The state agency contacts, or the appro-
priate organization within astate's environmental regulatory agency,
should be able to provide information on any such available grants.
For additional information, contact the appropriate member of the
National Association of Business Development Corporations given
in Section 10.4.1.
10.4 Directories of State Contacts
Two lists published by the U.S. EPA in Washington, D.C. are
potentially useful to small business owners: the national directory
of the National Association of Business Development Corpora-
tions, and the state agency contacts for pollution control financing.
10.4.1 National Directory of the National Association of Business
Development Corporations
Following is the national directory of the National Association of
Business Development Corporations.
© 1989 l^H CHMR
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National Directory
National Association of Business
Development Corporations
State
Director and Address
Phone Number
Arkansas
California
Florida
Georgia
I ova
Kansas
Kentucky
Maryland
Massachusetts
Missouri
Montana
George U. Eagen
First Arkansas Development Finance Corp.
910 Kane Bldg.
Little Rock, AR 72201 501-374-9247
Leslie Brewer
First California Business & Ind. Dev. Corp.
3901 MacArthur Blvd., Suite 101
Newport Beach, CA 92660 714-851-0655
Willlaa N. L. Hutchinson, Jr.
Provident Calbidco
160 Sansome St., Fifth Floor
San Francisco, CA 94104 415-393-0440
Sidney Moray
Governnent Funding - CalbldcD
9200 Sunset Blvd., Suite 702
Los Angeles, CA 90069 213-278-1236
John R. Neiswender
Statewide California Bus. & Ind. Dev. Corp.
4600 Campus Dr., Suite 21
Newport Beach, CA 92660 714-545-5333
Ray C. Barton
Industrial Development Corp, of Florida
801 North Magnolia Ave., Suite 218
Orlando, FL 32803 305-841-2640
David M. Johnson
The Business Dev. Corp. of Georgia, Inc.
558 South Omni International
Atlanta, GA 30303 404-577-5715
Don J. Albertson
Iowa Business Dev. Credit Corp.
901 Insurance Exchange Bldg.
Fifth & Grand Ave.
Des Moines, IA 50309 515-282-2164
George L. Doak
Kansas Dev. Credit Corp.
First National Bank Tower, Suite 1030
Topeka, KS 66603 913-235-3437
Jesse C. Dixon, Jr.
Business Dev. Corp. of Kentucky
382 Starks Bldg.
Louisville, KY 40202 502-584-3519
W. G. Brooks Thomas
Dev. Credit Corp. of Maryland
40 West Chesapeake Ave., Suite 211
P.O. Box 10629, Towson, MD 21204 301-828-4711
Fred F. Stockwell
Massachusetts Bus. Dev. Corp.
One Boston Place, Suite 925
Boston, MA 02108 617-723-7515
Richard V. Jeffrey
First Missouri Dev. Finance Corp.
1411 Southwest Blvd., Suite B
P.O. Drawer 1745
Jefferson City, MO 65101 314-635-0138
Richard L. Bourke
Dev. Credit Corp. of Montana
P.O. Box 916
Helena, MT 59601 406-442-3850
© 1989
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State
Director and Address
Phone Number
Nebraska
Nevada
New Hampshire
New York
North Dakota
Pennsylvania
Rhode Island
South Carolina
Washington
Wyoming
Janes H. Chllde
Business Dev. Corp. of Nebraska
1044 Stuart Bldg.
Lincoln, NE 68508 402-474-3855
David L. Buckman
Nevada Financial Dev. Corp.
1 East Liberty St., Suite 602
Reno, NV 89501 702-323-3033
Albert Hall, 111
New Hampshire Bus. Dev. Corp.
10 Fort Eddy Rd.
Concord, NH 03301 603-224-1432
Marshall R. Lustlg
New York Bus. Dev. Corp.
41 State St.
Albany, NY 12207 518-463-2268
W. C. Smith
North Dakota State Dev. Credit Corp.
Box 1212
Bismarck, ND 58502 701-223-2288
C. Drev Moyer
Pennsylvania Dev. Credit Corp.
One Commerce Center
2595 Interstate Dr., Suite 103
Harrlsburg, PA 17110 717-652-9434
Paul Mitchell
Southeastern Pennsylvania Dev. Fund
3 Penn Center Plaza, Suite 604
Philadelphia, PA 19102 215-568-4677
Joseph M. Dougherty
Western Pennsylvania Dev. Credit Corp.
534 Union Trust Bldg.
Pittsburgh, PA 15219 412-288-9206
Clifton A. Moore
Business Dev. Conpany of Rhode Island
Howard Bldg., 10 Dorrance St., Suite 330
Providence, RI 02903 401-351-3036
William V. Harvey
Business Dev. Corp. of South Carolina
P.O. Box 11606
Columbia, SC 29211 803-799-9825
V. Gibson Sears
Business Dev. Corp. of Eastern Washington
607 Mohawk Bldg.
Spokane, WA 99201 509-838-2731
Larry McDonald
Wyoming Ind. Dev. Corp.
145 South Durbin, P.O. Box 612
Casper, WY 82602 307-234-5351
© 1989
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10.4.2 State Agency Contacts for Pollution Control Financing
Following is a list of state agency contacts for pollution control
financing:
State Agency Contacts for
Pollution Control Financing
State
Agency and Address
Phone Number
Alabama
Alaska
Arirona
Arkansas
California
Colorado
Connect icut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Alabama Development Office, State Capitol,
135 South Union St., Montgomery, AL 36130 205-263-0048
Office of Enterprise, Pouch EE,
Juneau, AK 99811 907-465-2017
Zenlth5-5500
Arizona Department of Economic Planning and
Development, 1645 West Jefferson St.,
Phoenix, AZ 85007 602-255-5705
Arkansas Industrial Development Commission
1 State Capitol Mall, Little Rock, AR 72201 501-371-1151
Economic and Business Development Department
1030 13th St., Sacramento, CA 95814 916-322-1394
Division of Commerce and Development, 500
State Centennial Bldg. , Denver, CO 80203 303-866-2205
Connecticut Development Authority
217 Washington St., Hartford, CT 06106 203-522-3730
Delaware Department of Community Affairs &
Economic Development, 630 State College Rd. ,
Dover, DE 19901 302-736-4201
Division of Commercial Development
Florida Department of Commerce, 107 West
Galnes St., Tallahassee, FL 32304 904^487-0466
Georgia Department of Community Development
1400 North Omni Intern?tional,
Atlanta, GA 30301 404-881-4325
Department of Planning i Economic Development
Financial Management and Assistance Branch
P.O. Box 2359, Honolulu, HI 96813 808-548-4617
Division of Economic and Community Affairs
Room 108, Capitol Bldg. , Boise, ID 83720 208-334-3322
Illinois Department of Business and Econonic
Development, 222 South College,
Springfield, IL 62706 217-782-7500
Indiana Department of Commerce, Business &
Financial Service Division, 1 North Capitol,
Suite 700, Indianapolis, IN 46204 317-232-8800
Iowa Development Commission, Product
Development Corporation, 600 East Court
Ave., Suite A, Des Molnes, IA 50309 515-281-3619
Kansas Departnent of Economic Development
503 Kansas Ave., 6th fl., Topeka, KS 66603 913-296-3481
a 1989
CHMR
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State
Agency and Address
Phone Number
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
N'ew Ksirpshire
New Jersey
Kew y
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10-13
State
Agency and Address
Phone Number
South Carolina South Carolina State Development Board
P.O. Box 927, Columbia, SC 29202 803-758-3046
South Dakota Dept. of State Development
P.O. Box 6000, Pierre, SD 57501 800-843-8000
Tennessee Department of Economic and Community
Development, Andrew Jackson State Office
Bldg., 10 Fl. , Nashville, TN 37219 615-741-1888
Texas Texas Economic Development Authority
410 E. Fifth St., Austin, TX 78701 512^72-5059
Utah Utah Division of Economic Developnent
6150 State Office Bldg.,
Salt take City, UT 64114 801-533-5325
Vermont Economic Development Department, PdviUon
Office Bldg., Montpeller, \T 05602 802-826-3221
Virginia Small Business Coordinator, Governor's Office
Division of Industrial Development, 100U
Washington Blvd., Richmond, VA 23219 804-766-3791
Washington Department of Commerce and Economic
Development, Washington State Office of
Small Business, 101 General Administration
Bldg., AX-13, Olympia, WA 98504 206-753-5614
West Virginia Governor's Office of Economics and Community
Development, Bldg. G, Room B-517, Caplr.ol
Complex, Charleston, UV 25305 3C4-348-2234
Wisconsin State of Wisconsin Small Business Ombudsman
Wisconsin Department of Development
123 West Washington Ave., P.O. Box 7970,
Madison, WI 53707 608-266-0562
Wyoming Industrial Development Divlslo-i, Departcent
of Economic Planning ^nd Development,
Barrett Bldg. , Cheyenne, »'Y 82002 307-777-7285
'1989
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10.5 State Assistance in Pennsylvania
In Pennsylvania, assistance programs for businesses interested in
> financing waste minimization programs vary widely. Three main
areas in which Pennsylvania may assist a business include:
• technical assistance,
• loans, and
• grants.
Each of these will be discussed briefly in the following sections.
10.5.1 Technical Assistance
Technical assistance and information dissemination are indirect
forms of financial assistance. This is especially valuable for smaller
businesses which lack the resources to research and develop their
own programs.
Typically, technical assistance programs are involved in three
areas:
• identification and collection of technical information useful
to local industries,
• preparation of appropriate informational material, and
• dissemination of information.
The two technical assistance programs available in Pennsylvania
are the CHMR (Center for Hazardous Materials Research) pro-
gram and the PENNTAP (Pennsylvania Technical Assistance
Program) program. The CHMR program focuses exclusively on
solving hazardous waste problems, while the PENNTAP program
is a more general technical assistance program.
Waste minimization information available from the CHMR program
includes:
CHMR
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10-16
approaches to reducing production of hazardous or toxic
wastes;
suggestions for substituting less hazardous materials or
processes;
evaluation of waste streams to determine potential for treat-
ment, volume ortoxicity reduction, reuse, or recycling; and
techniques for recycling hazardous effluents and using
waste exchanges.
The address and toll-free telephone number for the CHMR pro-
gram are:
Center for Hazardous Materials Research (CHMR)
University of Pittsburgh Applied Research Center
320 William Pitt Way
Pittsburgh, PA 15238
(412)826-5320
(800) 334-CHMR (toll-free)
The Pennsylvania Technical Assistance Program (PENNTAP) is a
service organization which functions as the middleman in the
transfer of technical, scientific, and engineering data and informa-
tion. PENNTAP works to help firms in Pennsylvania solve techni-
cal problems in a way that will enhance the firm's ability to assume
a stronger competitive position, thereby improving local and state
economic development.
PENNTAP is not a consulting service, nor does it conduct re-
search. It assembles current information and presents it in under-
standable terms so the user is able to decide on the most practical
application.
The address and telephone number for the PENNTAP program
are:
1989 ••CHMR
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10-17
Pennsylvania Technical Assistance Program (PENNTAP)
Building #1114
University Park, PA 16802
(814)865-1914
10.5.2 Loans
As in most states offering loan programs, most of the loans
available in Pennsylvania require the business applicant to meet
three eligibility requirements similar to the Federal ones:
• small to medium size,
• unabletosecurealoanthroughconventional financing sources
and not have the capital to finance the program, and
• classified in a standard industrial code classification that has a
high potential for waste minmization.
Funding for such programs comes from a number of sources. The
Pennsylvania Bureau of Economic Assistance, for example, has
two programs under which a business may be able to gain financial
support.
• The Pennsylvania capital loan fund will finance the pur-
chase of any piece of equipment.
• A $345 million dollar revenue bond/mortgage program will
offer financial assistance to hazardous and solid waste
disposal programs with the stipulation that at least 25 percent
of the funds be spent on solid waste disposal.
Both are contingent upon the fact that the improvement will
increase employment in the area. For more information on these
programs, contact:
1989
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10-18
Bureau of Economic Assistance
Room 405
Forum Building
Harrisburg, PA 17120
(717)787-1909
Additionally, many of the Federal programs have local branches to
handle loans. For these local branches, Federal eligibility require-
ments apply.
Small Business Administration
Philadelphia District Office
Suite 400 East Lobby
1 BalaCynwyd, PA 19004
(215)596-5889
Small Business Administration
Pittsburgh District Office
906 Penn Avenue, 5th Floor
Pittsburgh, PA 15222
(412)644-2780
National Association of Business Development
Corporations
Western PA Development Credit Corp.
534 Union Trust Building
Pittsburgh, PA 15219
(412)288-9206
Attn: Joseph M. Dougherty
Allegheny County Department of Development
400 Fort Pitt Commons
445 Fort Pitt Boulevard
Pittsburgh, PA 15219
(412) 644-1010
Attn: Joseph Hohman
© 1989 •• CHMR
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10-19
Pennsylvania Development Credit Corporation
One Commerce Center
2595 Interstate Drive, Suite 103
Harrisburg, PA 17110
(717)652-9434
Southeastern Pennsylvania Development Fund
3 Penn Center Plaza, Suite 604
Philadelphia, PA 19102
(215)568-4677
Small Business Administration
Harrisburg District Office
100 Chestnut Street, Suite 309
Harrisburg, PA 17101
(717)782-3840
The Environmental Quality Board of the Pennsylvania Department
of Environmental Resources adopted the Pennsylvania Hazard-
ous Waste Facilities Plan on July 15,1986. Included in this plan is
a recommended program for granting loans, and possibly awards,
to businesses that wish to implement waste reduction programs.
While this program is still in the planning stages, it represents the
first potential future opportunity to secure state funds distributed
solely on the basis of minimizing waste.
10.5.3 Grants
Under the Hazardous Sites Cleanup Act, Act 108, which was
signed into Law in October 1988, facilities that install and operate
recycling equipment before April 15,1993, are eligible for a grant
of up to 25 percent of installation costs. The Act defines "recycling
equipment" as "machinery used exclusively to process and reclaim
hazardous waste materials into a raw product that is non-hazard-
ous and reusable, thereby reducing the total amount of hazardous
material produced at a particular location."
©1989 1MCHMR
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10-20
Additional information on this grant can be obtained from:
Pennsylvania Department of Environmental Resources
Office of Recycling and Waste Reduction
P. O. Box 2063, 8th Floor
Harrisburg, PA 17120
(717)787-1749
©1989 MBCHMR
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CHAPTER
SOURCES FOR INFORMATION ON
WASTE MINIMIZATION
Hi
11.0
This chapter contains information on organizations and sources
where small businesses can obtain useful information on hazard-
ous waste minimization. Also provided are important telephone
and Hotline numbers, as well as information on waste exchanges
and commercial hazardous waste recovery, treatment, and dis-
posal facilities.
11.1 CHMR's Program for SQG Assistance
The Center for Hazardous Materials Research (CHMR) operates
a comprehensive nationwide technical assistance program for
organizations and businesses handling small quantities of hazard-
ous materials. This program is intended to:
• help SQGs reduce their hazardous waste generation, and
• offer practical information on complying with applicable
environmental, health, and safety regulations.
Information is provided on:
• regulatory requirements,
• process modifications,
• substitution of less toxic materials, and
• available new equipment that can reduce hazardous
materials problems.
Important elements of CHMR's technical assistance program
include:
© 1989
CHMR
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11-2
11.2
11.2.1
• Hazardous Materials Hotline. This confidential, nation-
wide, toll-free Hazardous Materials Hotline, (800)334-CHMR,
is where callers can receive answers to a range of regula-
tory and technical questions, as well as information on haz
ardous waste transporters, and treatment,
storage, and disposal facilities.
• Quarterly Newsletter. CHMR publishes a quarterly news-
letter—The Minimizer—containing valuable waste minimi-
zation information for small businesses.
• CHMR Speakers Bureau. CHMR can provide speakers
on several important subjects to address trade associa-
tions, businesses, and other organizations.
• On-Site Consultations. CHMR performs on-site consul-
tation services for small and medium-sized businesses to
provide clients with a general assessment of their hazard-
ous waste management needs and compliance require-
ments, as well as identification of opportunities for minimiz-
ing hazardous waste generation. Services performed are
tailored to meet specific needs of the client. Fees for these
services are based on the size and scope of the project.
Other State Technical Assistance Programs
Waste Minimization and Treatment
The state programs which follow offer technical and/or financial
assistance in the areas of waste minimization and treatment for
other states throughout the nation.
'1989
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11-3
Alabama
Hazardous Material Management and Resource
Recovery Program
University of Alabama
P O. Box 6373
Tuscaloosa. AL 35-487-6373
(205) 348-8401
Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101
Anchorage, AK 99501
(907)276-2864
Arkansas
Arxar.sas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501)371-1370
California
Alternative Technology Section
Toxic Substances Control Division
California State Department of Health Services
714/744 P Street
Sacramento, CA 94234-7320
(916)324-1807
Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007
Connecticut Department ot Economic Development
210 Washington Street
HartfordCT06106
(203) 566-7196
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404) 894-3806
Georgia (continued)
Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Butler Street
Atlanta. CA 30334
(404) 656-2833
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
1808 Woodfield Drive
Savoy, IL61874
(217)333-8940
Illinois Waste Elimination Research C«nter
pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago. IL60616
(312)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-8172
Iowa
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Momes, IA 50319-0034
(515)281-8690
Center lor Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames. IA 50011
(515)294-3420
1989
CHMR
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11-4
Kansas
Bureau ol Waste Management
Department ol Health and Environment
Forbes Reid, Building 730
Topeka, KS 66620
(913)296-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental Protection Cabinet
18 Reilty Road
Frankfort, KY 40601
(502)564-6716
Louisiana
Department ol Environmental Quality
Office cl Solid and Hazardous Waste
P O Box 44307
Baton Rouge, LA 70804
(504)342-1354
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200A
Annapolis, MD 21401
(301)974-3432
Maryland Environmental Service
2C20 Industrial Dnvo
Annapolis. MD 21401
'201) 269-32S1
,£00) 492-9188 (in Maryland)
Massachusetts
Otlice of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202
(517)727-3260
Source Reduction Program
Massachusetts Department ol Environmental Quality
Engineering
1 Winter Street
Boston. MA 02108
(617)292-5982
Michigan
Resource Recovery Section
Department of Natural Resources
P O. Box 30028
Lansing, Ml 48909
(517)373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St Paul, MN 55155
(612)296-6300
Mlnntsota (contlnutd)
Minnesota Technical Assistance Program
W--40 Boynton Hearth Service
University o( Minnesota
Minneapolis. MN 55455
(612) 625-9677
(800) 247-0015 (in Minnesota)
Minnesota Waste Management Board
123 Thorson Center
7323 Rfty-Eighth Avenue North
Crystal, MN 55428
(612)536-0816
Missouri
State Environmental Improvement and Energy
Resources Agency
P.O Box 744
Jefferson City, MO 65102
(314)751-4919
New Jtrsey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609)292-1459
(609) 292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
Risk Reduction Unit
Of!'c8 of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
New York
New York State Environmental Facilities Corporation
50 Wolf Road
Albany. NY 12205
(518)457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and Community
Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919)733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh. NC 27611
(919)733-9020
i 1989
CHMR
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11-5
North Carotin* (contlnutd)
Technical Assistance Unit
Soiid and Hazardous Waste Management Branch
North Carolina Department of Human Resource*
P O. Box 2091
306 North Wilmington Street
Raleigh, NC 27603
(919)733-2178
Ohio
Division ol Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterUark Drive
Columbus, OH 43266-1049
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus. OH 43266-0330
(614)466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma Slate Department o( Health
P O. Box 53551
Oklahoma City, OK 73152
(405)271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland. OR 97204
;5D3) 229-5913
Pennsylvania
Pennsylvania Technical Assistance Program
501 F. Orv.s Keller Building
Universrty Park, PA 16802
(814)865-0427
Bureau of Waste Management
Pennsylvania Department of Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Hamsburg. PA 17120
(717)787-6239
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412)826-5320
Rhodt Island
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental Management
9 Hayes Street
Providence, Rl 02908-5003
(401)277-3434
(800) 253-2674 (in Rhode Island)
Rhodt Ifltnd (continued)
Center of Environmental Studies
Brown Universrty
P.O. Box 1943
135 Angell Street
Providence, RI 02912
(401 ) 863-3449
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville. TN 37996
(615)974-2456
Virginia
Ofl>ce of Policy and Planning
Virginia Department of Waste Management
1 1 th Floor, Monroe Building
101 North 14th Street
Richmond, VA 2321 9
(804) 225-2667
Washington
Hazardous Waste Section
Mail Stop PV-1 1
Washington Department of Ecology
Otympia, WA 98504-871 1
(206) 459-6322
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, Wl 53707
(608) 266-2699
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herschler Building, 4th Floor, West Wing
1 22 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
© 1989
CHMR
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11-6
11.2.2 Underground Storage Tank (UST) Program Offices
State UST Program Offices
AL AL Dept of Environmental Mgmt
Ground Water Secnon/Water Division
1751 Congressman W. Dickanun Dr.
Montgomery. AL 36130
205-271-7832
AK Dept of Environment!! Con«*rvitlon
P.O. Box 0
JunMu. AK 99811-1800
907-48S-26S3
AR AR Dept of Pollution Control 4 Eeot
P.O. Sax 9583
Uttl» Roc*. AH 72219
501-562-7444
AZ AZ Dept of Environmental Quality
Environmental Health Services
2005 N. Central
Phoenix. AZ 85OO4
602-257-6984
CA State Water Reeourcei Control Board
OUST
P.O. Box 944212
2014 T Street
Sacramento, CA 95814
916-322-3133
CO CO Dept. of Health
Waste Mgmt Division
Underground Tank Program
4210 East 11th Avenue
Denver, CO 80220
303-331-4864
CT Hazardous Matenab Mgmt Ural
Dept at Environmental Protection
State Office Budding
165 Capitol Avenue
Hartford, CT 06106
203-566-4630
DC Dept of Consumer and Regulatory
Affairs
Environmental Control Division
516HSIreetN.W.
Washington, D.C. 20001
202-783-3205
DE Division of Air and Waste Mgmt
Dept of Natural Resources &
Environmental Control
89 Kings Highway
Dover, DE 19903
302-323-4583
FL R. Dept of Environmental Regulation
Solid Waste Section
Twin Towers Office Building
2600 Blair Slone Road
Tallahassee, a 32399-2400
904-488-0300
GA GA Environmental Protection Division
3420 Norman Berry Drive
Hapeville, GA 30334
404-656-7404
Dept of Health
Hazardous Waste Program
P.O. Box 3378
645 Halekauwila Street
Honolulu, HI 96801-9984
808-548-8837
IA IA Dept of Natural Resources
Henry A. Wallace Building
900 East Grand
Dee Moinas, IA 50319
515-281-8779
ID ID Dept of Health & Welfare
Divtsen of Environmental Quality
450 W. State Street
Boise, ID 83720
208-334-5847
IL Office of Slate Tire Marshal
3150 Executive Park Drive
Springfield, IL 62703-4599
217-785-5878
IN Underground Storage Tank Program
IN Dept. of Environmental Mgmt
105 South Meridian Street
Indianapolis, IN 46225
317-243-5055
KS KS Dept of Health 1 Environment
Forbes Field, Building 740
Topeka,KS 66620
913-286-1594
'1989
CHMR
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11-7
KY Dept. of Environmental Protection
Hazardous Waste Branch
Fort Boom Plaza. Building »2
18 Rally Road
Frankfort, KY 40601
502-564-6716
LA LA Dept of Environmental Quality
P.O. Box 44274
625 North 4th Strut
Baton Rouge, LA 70804
504-342-7908
MA Dept of Public Safety
P.O. Box 490
Tewksbury, MA 01876
508-851-9813
ME Underground Tanks Program
Bureau of Oil & Hazardous Material
Contra*
Dept of Environmental Protection
Ray Bldg.- Station 17
Augusta. ME 04333
207-289-2651
MD MD Dept. of the Environment
Hazard & Solid Waste Mgmt i Admin.
OUST and LUST Division
2500 Broemng, Highway
Baltimore. MD 21224
301-631-3442
Ml Fire Marshall Division
Ml Dept. of State Police
7150 Hams Dnve
Lansing. Ml 48913
517-322-1935
800-MICHUST
MN Underground Storage Tank Program
MN Pollution Control Agency
520 West Lafayette Road
St Paul, MN 55155
612-296-7743
MO MO Oept. of Natural Resource*
P.O. Box 176
Jefferson City. MO 65102
314-751-7428
MS DepL of Natural Resources
Bureau orl Pollution Control
UST Section
P.O. Box 10385
Jackson, MS 39209
601-961-5171
MT Solid a Hazardous Waste Bureau
Dept. of Health i Environmental Set
Cogswell Bldg. - Room B-201
Helena, MT 59620
406-444-2821
NC D'rv of Environmental Mgmt
Ground-Water Operations Branch
Dept of Natural Resources and
Community Development
512 N. Salisbury, P O Box 27687
fialerah. NC 27611
919-733-3221
NO Division of Waste Mgmt
ND Dep<. of Health
1200 Missouri Avenue
Bismarck, ND 58502-5520
701-224-3498
NE NE State Fire Marshal
P.O Box 94677
Lincoln. NE 68509-4677
402-471-9465
NH Dept of Environmental Services
Water Supply & Pollution Control Div.
Hazen Drive, P O Box 95
Concord, NH 03301
603-271-3503
NJ Dept of Environmental Protection
Div. of Water Resources (CN-029)
Trenton, NJ 08625
609-984-3156
UST Section (Rm. N. 2150)
NM Environmental Improvement Div.
H. W. Bureau
1190SI. FranasDnve
Santa Fe, NM 87503
505-827-2894
NV Division of Environmental Protection
Dept of Conservation & Natural Res
Capitol Complex 201 S. Fall St
Carson City. NV 89710
702-885-5872
NY Bulk Storage Section, Drv. of Water
Dept of Environmental Conservation
50 Wolf Road, Room 326
Albany, NY 12233-O001
518-457-4351
State Fire Marshal's Offce
Dept. of Commerce
8895 E. Main Street
Reynoldsburg, OH 43068
614-864-5510
800-282-1927
OK OK Corporation Comm
Jim Thorpe Building
Oklahoma City, OK 73105
405-521-3107
OR Dept of Environmental Quality
811 SW Sixth Ave
Portland. OR 97204
503-229-5769
PA Dept of Environmental Resource*
Bureau of Water Quality Mgmt
Non-point Source & Storage Tank
Section
9th Floor Fulton Building
Hamsouro, PA 17120
717-787-8184
Div. of GW and FW Wetlands
Dept. of Environmental Management
291 Promenade St.
Providence. Rl 02903
401-277-2234
SC Ground-Water Protection Division
SC Dept ot Health & Environ. Control
2600 Bull Street
Columbia, SC 29201
803-734-5332
Office of Water Quality
Dept of Water & Natural Resources
Joe Foss Building, rm 217
Pierre. SD 57501-3181
605-773-3351
Division of Ground-Water Protection
TN Dept of Hearth & Environmental
150 9th Avenue, North
Nashville. TN 37219-5404
615-741-0690
UST Program
Texas Water Commission
P O Box 13087, Capital Station
Austin, TX 78711
512-463-8180
UT Bureau of Solid & Hazardous Waste
UT Dept. of Environmental Health
288 N. 1460 West
SaJI Lake City. UT 84116-0700
801-538-"'O
VA VA Water Control Board
2111 North Hamilton Street
P.O. Box11143
Richmond, VA 23230-1143
804-367-6350
VT Dept of Environmental Conservation
Waste Management Division
103 South Main St.
Waterbury, VT 05676
802-244-8702
WA WA Dept. of Ecology. M/S PV-11
Solid & Hazardous Waste Program
Orympa, WA 98504-8711
206-459-6272
Wl Dept of Industry. Labor and Human
Relations
PO Box7979
Madison, Wl 53707
608-266-7605
WV Division of Waste Management
WV Dept. of Natural Resources
1260 Greenbriar Street
Charleston, WV 23505
304-348-5935
WY Water Quality Divaon
Dept of Environmental Quality
Herschler Building, 4th Floor West
122 West 25!h Street
Cheyenne. WY 82002
307-777 "35
AS Environmental Quality Commiss
Office ot the Governor
American Samoan Government
Pago Pago. American Samoa 96799
684-633-2682
CSU GU Environmental Protection Agency
P O. Box 2999
Agana, Guam 96910
671-646-8863
NM DSnson of Environmental Quality
P.O. Box 1304
Commonwealth of Northern Manana
Islands
Sapan, CM 96950
607-234-6984
PR Water Quality Control Area
Environmental Quality Board
Commonwealth ot Puerto Rico
Santurce, Pueno Rico
809-725-84;0
VI Environmental Protection Division
Dept. of Planning and National
Resources
179 Altona and Welgunst
Charlotte Amlie, St. Thomas.
Virgin Islands 00802
809-774-3320
U S Environmental Protecoon Agency
Otfiot ot Underground Storage Tanks
Washington D C
11 '88
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11.3 Important Telephone and Hotline Numbers
There are a number of private and public organizations offering
technical assistance to businesses and the community via tele-
phone, often through toll-free hotlines. Such services can often
provide quick and easy answers to questions related to hazardous
materials. Below are telephone numbers for hotlines and informa-
tion services covering a variety of hazardous materials topics.
CHMR Hazardous Materials Hotline
Center for
Hazardous
Materials Research
Technical information
on hazardous materials
and Federal/state
regulations
(800) 334-CHMR
EPA Hotlines
EPA chemical
emergency pre-
paredness/SARA
Title III hotline
EPA RCRA/
CERCLA
hotline
For information on proper (800) 535-0202
procedures for handling
chemical emergencies
For help with hazardous
waste and/or Federal
Superfund-related
problems
(800) 424-9346
EPA small business
ombudsman
Safe drinking water
For help with environ- (800) 368-5888
mental problems specific
to small business
(800) 426-4791
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EPA Waste Reduction Programs/Research
Office of Research
and Development
Waste Minimization
Division, Cincinnati,
Ohio
Technical information
on waste reduction
(513)569-7529
(Harry Freeman)
Emergency Response
Bureau of Explosives Assistance for hazardous (202) 639-2222
Association of materials problems involv-
American Railroads ing railroads (operates
emergency number
24 hours per day.)
CHEMTREC
Chemical
Transporters
Emergency Center
Hazardous Materials
Newsletter Informa-
tion Line
Federal National
Response Center
Hazardous Spills
Hotline
To report major
chemical spills
Transportation of Hazardous Materials
Department of
Transporation
Hotline
(800) 424-9300
For response teams
(public or industrial)
requiring information
on tools, materials,
emergency planning, etc.
To report a chemical
spill on navigable
waterways
(802) 479-2307
(800) 424-8802
To receive assistance
on Federal hazardous
substance transporta-
tion regulations
(202) 366-4488
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Occupational Safety and Health
OSHA Hotline
Information on occupa-
tional exposure to
hazardous substances
(202) 523-8036
Pestcides and Toxic Substances Information
National Animal
Poison Control
Center, University
of Illinois (Staffs a
North American
response team.)
Texas Tech
University
Pesticide Hotline
For consultation in the
diagnosis and treatment
of suspected or actual
animal poisonings
Contact to reach the
National Pesticide
Telecommunication
Network, providing
health, toxicology,
and cleanup information
(217)333-3611
(800) 858-7378
TSCA Hotline
TSCA
For problems related
to toxic substances
(202)554-1404
Miscellaneous Hazardous Materials Information
Radon technical
assistance
For technical information (800) 23-RADON
on Radon (in PA)
CMA National For technical information
Chemical Resource on hazardous chemicals
Information Center
(800) 262-8200
Chemical Services Can put you in touch with (202) 395-7285
Information manufacturers of
Network chemicals in question
>1989
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Asbestos technical
information and
referral
For information on
handling asbestos
(202)554-1401
Household Hazardous Materials Information
Consumer Product
Safety Commission
Household Products
Disposal Council
For information on safety
of consumer goods
Information on
disposal of household
hazardous waste
(800) 638-2772
(202) 659-5535
Cancer Causing (Carcinogenic) Substance Information
(800) 422-6237
National Institute
of Health, Cancer
Information Service
For information on the
carcinogenic qualities
of certain chemicals
11.4 Other Useful Resources
Other useful resources such as certain mailing lists, equipment
source guides, and directories of facilities are available to help
businesses establish and implement their waste minimization
programs.
11.4.1 Mailing Lists
Subject-specific mailing lists are available to help businesses keep
up to date with changes and information on specific regulatory and
waste reduction subjects. Some of these include:
"Information For Small Business"
Small Business Ombudsman
U.S. Environmental Protection Agency
401 M Street, SW(A-149C)
Washington, DC 20460
(800) 368-5888
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U.S. Environmental Protection Agency
Office of Underground Storage Tanks
Box 6044
Rockville, MD 20850
Center for Environmental Research Information (CERI)
Technology Transfer
U.S. Environmental Protection Agency
P.O. Box12505
Cincinnati, OH 45212
11.4.2 Equipment Buyers' Guides
Numerous equipment buyers' guides are available which provide
the names of manufacturers and vendors of equipment for waste
reduction and/or recycling. Subscriptions to equipment buyers'
guides are usually free. Some useful guides and subscriptions
include:
Pollution Equipment News
Rimbach Publishing Inc.
8650 Babcock Boulevard
Pittsburgh, PA 15237
(412) 364-5366
Water & Wastes Digest
Scranton Gillette Communications, Inc.
380 Northwest Highway
Des Plaines, IL 60016
(312)298-6622
Chemical Equipment
Gordon Publications, Inc.
Box 1952,
Dover, NJ 07801
(201)361-9060
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11.4.3 Directories of Commercial Hazardous Waste Recovery,
Treatment, and Disposal Facilities
There are several publications which provide comprehensive list-
ings of commercial hazardous waste recovery, treatment, and
disposal facilities.
Hazardous Waste Services Directory—
Transporters, Disposal Sites, Laboratories, Consultants,
and Specialized Services (Recyclers)
J. J. Keller & Associates, Inc.
145 West Wisconsin Avenue
P. O. Box 368
Neenah,WI 54957
(414)722-2848
1 (800) 558-5011
Hazardous Wastes Management Reference Directory
Rimbach Publishing Inc.
8650 Babcock Boulevard
Pittsburgh, PA 15237
(412) 364-5366
For more information call CHMR's toll-free Hazardous Materials
Hotline, (800) 334-CHMR, or your local state technical assistance
program listed in Section 11.2.
11.5 Waste Exchanges
11.5.1 Northeast Industrial Waste Exchange
The Northeast Industrial Waste Exchange (NIWE) is an informa-
tion clearinghouse. Established in 1981 by the Manufacturers As-
sociation of Central New York in cooperation with the Central New
York Regional Planning and Development Board, the non-profit
exchange is co-sponsored and partially funded by the New York
State Environmental Facilities Corporation, the Ohio Environ-
1989
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mental Protection Agency, and the U.S. Environmental Protection
Agency. NIWE's information is widely circulated but used primarily
in the northeastern United States.
Information is distributed in two ways—a Listings Catalog is
published quarterly, and a computerized waste materials listings
service is available. Each February, May, August, and November,
a list of "Materials Available" and "Materials Wanted" is printed and
distributed as widely as possible, with current circulation number-
ing 10,500. A company wishing to have information included in a
list may do so for $25 forthree issues. The information is also made
available on the computerized listings for the same period of time.
The computerized service is provided free of charge and is avail-
able to anyone having access to a microcomputer and modem.
The service is designed to allow immediate access to current
information.
For more information contact:
Northeast Industrial Waste Exchange
90 Presidential Plaza
Suite 122
Syracuse, NY 13202
(800) 237-2481
11.5.2 Other Waste Exchanges
Alberta Waste Materials Exchange
4th Floor, Terrace Plaza
4445 Calgary Trail South
Edmonton, Alberta
Canada T6H 5R7
(403) 450-5461
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California Waste Exchange
Department of Health Services
Toxic Substances Control Division
714 P Street
Sacramento, CA 95814
(916)324-1807
Canadian Inventory Exchange
900 Blondin
Ste-Adele, Quebec
Canada JOR 1LO
(514)229-6511
Canadian Waste Materials Exchange
Ontario Research Foundation
Sheridan Park Research Community
Mississauga, Ontario
Canada L5K 1B3
(416)822-4111
Enkarn Research Corporation
P. O. Box 590
Albany, NY 12202
(518)436-9684
Georgia Waste Exchange
c/o America Resource Recovery
P. O. Box 7178, Station A
Marietta, GA 30065
(404) 363-3022
Great Lakes Regional Waste Exchange
470 Market Street, SW, Suite 100-A
Grand Rapids, Ml 49503
(616)451-8992
Indiana Waste Exchange
P.O. Box 1220
Indianapolis, IN 46206
(317)634-2142
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Industrial Materials Exchange Service
2200 Churchill Road, IEPA/DLPC-24
Springfield, IL 62706
(217)782-0450
Industrial Waste Information Exchange
New Jersey Chamber of Commerce
5 Commerce Street
Newark, NJ 07102
(201)623-7070
Manitoba Waste Exchange
c/o Biomass Energy Institute, Inc.
1329 Niakwa Road
Winnipeg, Manitoba
Canada R2J 3T4
(204) 257-3891
Montana Industrial Waste Exchange
Montana Chamber of Commerce
P.O. Box 1730
Helena, MT 59624
(406) 442-2405
Northeast Industrial Waste Exchange
90 Presidential Plaza, Suite 122
Syracuse, NY 13202
(315)422-6572
Ontario Waste Exchange
Ontario Research Foundation
Sheridan Park Research Community
Mississauga, Ontario
Canada L5K 1B3
(416)822-4111
Resource Recovery of America
P. O. Box 75283
Tampa, FL 33675-0283
(813) 248-9000
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Southeast Waste Exchange
Urban Institute
UNCC Station
Charlotte, NC 28223
(704) 547-2307
Southern Waste Information Exchange
P. O. Box 6487
Tallahassee, FL 32313
(904)644-5516
Tennessee Waste Exchange
Tennessee Manufacturers and Taxpayers Association
226 Capitol Boulevard, Suite 800
Nashville, TN 37219
(615)256-5141
Wastelink, Division of Tencon Associates
P.O. Box 12
Cincinnati, OH 45174
(513)248-0012
Western Waste Exchange
ASU Center for Environmental Studies
Krause Hall
Tempe.AZ 85287
(602)965-1858
Zero Waste Systems
2928 Poplar Street
Oakland, CA 94608
(415)893-8261
11.6 Waste Reduction/Recovery Equipment
This section provides examples of equipment to help you reduce
your waste. The following is not a comprehensive list of all
waste reduction equipment suppliers and should not be
viewed as an endorsement by CHMR of the suppliers listed.
1989 MB CHMR
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Rather, it is provided to illustrate that many waste reduction oppor-
tunities and sources of waste reduction equipment are available.
CHMR in no way endorses any of the goods or services de-
scribed. CHMR also does not warrant that the information is
accurate or complete or that it constitutes a complete description
of all the goods and services of this type which are available.
CHMR welcomes receipt of information from equipment suppliers
for our information clearinghouse.
You are strongly encouraged to consult other sources, such
as your trade association, state technical assistance program
(Section 11.2), and equipment buyers' guides (section 11.4.2),
for a more comprehensive list of waste reduction equipment
suppliers.
11.6.1 Chemical Substitutes
An effective method to reduce hazardous waste is to substitute a
less hazardous chemical. There is no "magic" chemical which
works in all situations. However, CHMR recommends that you
contact chemical suppliers for a potential alternate which you can
test in your operations. A few examples of alternative sources are
listed here.
(Titan Chemicals natural solvent cleaners and degreasers)
Functional Quality Products
4503 Lebanon Church Road
Pittsburgh, PA 15122
(412)469-2241
(Simple Green non-toxic industrial cleaner and degreaser)
Sunshine Makers, Inc.
16771 Pacific Coast Highway
Sunset Beach, CA 90742
(213)592-2844
(800) 228-0709
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Chesterton Technical Products Divisions
Middlesex Industrial Park
Route 93
Stoneham.MA 02180
(617)438-7000
DuPont Co.
C&P Department, Chestnut Run-709
Wilmington, DE 19898
(302)999-3018
Research Chemicals Inc.
P. O. Box 1492
Fort Worth, TX 76101
(817)451-7565
Total Systems Technology Inc.
65 Terence Drive
Pittsburgh, PA 15236
(412)653-7690
(800) 245-4828
Other chemical suppliers are also listed in U.S. EPA's publication,
Evaluation of Alternatives to Toxic Organic Paint Strippers, U.S.
EPA WERL, Cincinnati, OH, September 1986, NTIS No. PB86-
219177.
11.6.2 Solvent Recovery Equipment
Numerous on-site solvent recovery units are available for pur-
chase, including from these companies:
Recyclene Products, Inc.
405 Eccles Avenue
South San Francisco, CA 94080
(415)589-9600
1989
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HOYT Corporation
Forge Road
Westport, MA 02790
(617)636-8811
Finish Engineering Company
921 Greengarden Road
Erie, PA 16501
(814)455-4478
Progressive Recovery, Inc.
1020 North Main Street
Columbia, IL 62236
(618)281-7196
Pittsburgh Spray Equipment Co.
3601 Library Road
Pittsburgh, PA 15234
(412)882-4550
Giant Distillation & Recovery Co.
900 N. Westwood Avenue
Toledo, OH 43607
(419)531-4600
Pope Scientific Inc.
N90 W14337 Commerce Drive
P. O. Box 495
Menomonee Falls, Wl 53051
(414)251-9300
In addition to on-site recovery units, some chemical suppliers will
take and recover solvents from your waste, and we encourage you
to also consider this option.
1989 I^HCHMR
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11.6.3 Coolant Recovery Equipment
Numerous on-site coolant recovery units (such as the following)
are available for purchase.
Sanborn/Donaldson Systems
25 Commercial Drive
Wrentham, MA 02093
(800) 343-3381
Environmental Management Technologies, Inc.
27766 Deya
Mission Viejo, CA 92692
(714)583-0512
11.6.4 On-Site Hydraulic Oil Recycling
On-site waste hydraulic oil recycling systems can reduce the fre-
quency of changing oil.
Harvard Filtration Systems
R. D. #2, Box 388
Eighty-Four, PA 15330
(412)225-3650
11.6.5 Metals Recovery Equipment
Numerous on-site metals recovery units such as these are avail-
able for purchase.
Hallmark Refining Corp.
1743 Cedardale Road
P.O. Box 1446
Mt. Vernon.WA 98273
(206) 428-5880
©1989
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Lancy International, Inc.
181 Thorn Hill Road
Warrendale, PA 15086
(412)772-0044
Ionics, Inc.
Separations Technology Division
65 Grove Street
Watertown, MA 02172
(617)926-2500
EcoTech Ltd.
925 Brock Road South
Pickering (Toronto), Ontario
Canada L1W2X9
(416)831-3400
The J. T. MacDermid Group
Wastesaver Corporation
P. O. Box 296
Plymouth, CT 06782
(203) 283-5858
Eastman Kodak Company (Silver Recovery)
Department 412-L
Rochester, NY 14650
(800) 242-2424
CPAC, Inc.
2364 Leicester Road
Leicester, NY 14481
(716)382-3223
BEWT Recovery Technologies Inc.
1380 Hopkins Street, Unit 11
Whitby, Ontario
Canada L1N2C3
(416)430-7666
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11.7 Other References
Some information provided in this manual was compiled from the
following publications on waste minimization. Individuals inter-
ested in more detailed information on waste minimization are
encouraged to review these references.
U.S. EPA. 1986. Report to Congress: Minimization of Hazardous
Waste. Volumes I and II. EPA/530-SW-86-033A. Office of Solid
Waste, U.S. Environmental Protection Agency. Washington, DC
(Available from NTIS: PB87-114336 & PB87-114344)
U.S. EPA. 1986. Waste Minimization Issues and Options. Vol-
umes I, II, and III. EPA/530-SW-86-041. Office of Solid Waste,
U.S. Environmental Protection Agency. Washington, DC (Avail-
able from NTIS: PB87-114351, PB87-114369 and PB87-114377)
Monica E. Campbell and William M. Glenn. Profit from Pollution
Prevention. Pollution Probe Foundation, 12 Madison Avenue,
Toronto, Ontario, Canada MRS 2S1,1982.
Donald Huisingh, Larry Martin, Helene Hilger, and Neil Seldman.
Proven Profits from Pollution Prevention. Institute for Local Self-
Reliance, 2425 18th Street, NW, Washington, DC 20009, 1985,
ISBN 0-912582-47-0.
Rosanne A. Field. Management Strategies and Technologies for
the Minimization of Chemical Wastes from Laboratories. Duke
University Medical Center, Division of Environmental Safety,
Durham, NC. September 1986 by the North Carolina Pollution
Prevention Pays Program.
U.S. Congress, Office of Technology Assessment. Serious Reduc-
tion of Hazardous Waste. For Pollution Prevention and Industrial
Efficiency, OTA-ITE-317 (Washington, DC: U.S. Government Print-
ing Office, September 1986).
1989 HBCHMR
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U.S. EPA. 1988. Waste Minimization Opportunity Assessment
Manual. EPA/625/7-88/003. Alternative Technologies Division,
Hazardous Waste Engineering Research Laboratory, U.S. Envi-
ronmental Protection Agency, Cincinnati, OH 45268.
Hahn, Wilfred J., and P. O. Werschulz. Evaluation of Alternatives
to Toxic Organic Paint Strippers. U.S. EPA, WERL, Cincinnati, OH.
EPA/600/S2-86/063.. September 1986. (Available from NTIS:
PB86-219177)
Kohl, J., J. Pearson, and P. Wright. Managing and Recycling
Solvents in the Furniture Industry. North Carolina State University,
Raleigh, 1986.
Lenckus, D. "Increasing Productivity." Finishing Wood and Wood
Products Magazine. Vol. 87, No. 4, May 1982, pp. 44-66.
Kohl, J., P. Moses, and B. Triplett. Managing and Recycling
Solvents: North Carolina Practices, Facilities, and Regulations.
North Carolina State University, Raleigh, 1984.
Durney, J. J. " How to Improve Your Paint Stripping." Product Fin-
ishing. December 1982, pp. 52-53.
Higgi ns, T. E. Industrial Process Modifications to Reduce Genera-
tion of Hazardous Waste at DOD Facilities'. Phase I Report. CH2M
Hill, Washington, DC, 1985.
"Cryogenic Paint Stripping." Product Finish. December 1982.
Mallarnee, W. M. "Paint and Varnish Removers." Kirk-Othmer
Encyclopedia of Chemical Technology. 3rd Edition, Volume 16,
pp. 762-767, 1981.
Sandberg, J. Final Report on the Internship Served at Gage Tool
Company. Minnesota Technical Assistance Program, Minnesota
Waste Management Board, Minnesota, 1985.
Powder Coatings Institute. Information brochure. Washington,
DC, 1983.
©1S89 •• CHMR
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11-25
Cole, G. E. "VOC Emission Reduction and Other Benefits Achieved
by Major Powder Coating Operations." Paper No. 84-38.1 pre-
sented at the Air Pollution Control Association. June 25, 1984.
California State Department of Health Services. Alternative Tech-
nology for Recycling and Treatment of Hazardous Waste. 3rd
Biennial Report. Sacramento, 1986.
California State Department of Health Services. Guide to Solvent
Waste Reduction Alternatives. October 1986, pp. 4-25 to 4-49.
Kenson, R. D. "Recovery and Reuse of Solvents from VOC Air
Emissions." Environmental Progress. August 1985, pp. 161-165
Durney, L. J., Editor. Electroplating Engineering Handbook. 4th
edition. Van Nostrand Reinhold, New York, 1984.
American Society of Testing Materials. Handbook of Vapor De-
greasing. Special Technical Publication 310-A, ASTM, Philadel-
phia, April 1976.
Smith, C. "Troubleshooting Vapor Degreasers." Product Finish.
November 1981.
Loucks, C. M. "Boosting Capacities with Chemicals." Chemical
Engineering Deskbook Issue. Vol. 80, No. 5, pp. 79-84, 1973.
3M Corporation. Ideas - A Compendium of3M Success Stories.
St. Paul, MN.
Fromm, C. H., S Budaraju, and S. A. Cordery. "Minimization of
Process Equipment Cleaning Waste." Conference Proceedings of
HAZTECH International, Denver, August 13- 15, 1986, pp. 291-
307.
Fromm, C. H., and M. S. Callahan. "Waste Reduction Audit Pro-
cedure." Conference Proceedings of the Hazardous Materials
Control Research Institute. Atlanta, 1986, pp. 427- 435.
1989
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11-26
North Carolina Pollution Prevention Pays Program. Environmental
Auditing. North Carolina Department of Environmental Health.
1985.
Baumer, R. A. "Making Environmental Audits." Chemical Engi-
neering. Vol. 89, No. 22, November 1,1982, P. 101.
Kletz, T. A. "Minimize Your Product Spillage." Hydrocarbon
Processing. Vol. 61, No. 3, 1982, p. 207.
Sarokin, D. "Reducing Hazardous Wastes at the Source: Case
Studies of Organic Chemical Plants in New Jersey." Paper pre-
sented at Source Reduction of Hazardous Waste Conference,
Rutgers University, August 22, 1985.
Singh, J. B., and R. M. Allen. "Establishing a Preventive Mainte-
nance Program." Plant Engineering. February 27, 1986, p. 46.
Rimberg, D. "Minimizing Maintenance Makes Money." Pollution
Engineering. Vol. 12, No. 3, December 1983, p. 46.
Parker, N. H. "Corrective Maintenance and Performance Optimi-
zation." Chemical Engineering. Vol. 91, No. 7, April 16,1984, p.
93.
Geltenan, E. "Keeping Chemical Records on Track." Chemical
Business. Vol. 6, No. 11, 1984, p. 47.
Hickman, W. E., and W. D. Moore. "Managing the Maintenance
Dollar." Chemical Engineering. Vol. 93, No. 7, April 24, 1986, p.
68.
© 1989
ICHMR
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11.8 Pennsylvania Resources
This section contains information on organizations and sources in
Pennsylvania ? Pennsylvania where small businesses can obtain useful informa-
tion on hazardous waste minimization.
11.8.1 CHMR's Program for SQG Assistance in Pennsylvania
The Center for Hazardous Materials Research (CHMR) operates
a comprehensive statewide technical assistance program in Penn-
sylvania for organizations and businesses handling small quanti-
ties of hazardous materials. This program is intended to:
• help SQGs reduce their hazardous waste generation, and
• offer practical information on complying with applicable en-
vironmental, health, and safety regulations.
Information is provided on:
• regulatory requirements,
• process modifications,
• substitution of less toxic material, and
• available new equipment that can reduce hazardous mate-
rials problems.
Hazardous Materials Hotline
Central to the technical assistance program is a confidential,
nationwide, toll-free Hazardous Materials Hotline, (800)334-CHMR,
where callers can receive answers to a range of regulatory and
technical questions, as well as information on hazardous waste
transporters, and treatment, storage, and disposal facilities.
The Hotline staff has developed an extensive information clearing-
house containing texts, periodicals, and papers on such topics as:
CHMR
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11-28
• waste minimization techniques,
• radiation,
• laws and regulations,
• risk assessment,
• standards and policy,
• pollution treatment,
• health and toxicology,
• case studies,
• emergency response,
• vendors and suppliers,
• TSD facilities, and
• reference information
Quarterly Newsletter—The Minimizer
CHMR publishes a quarterly newsletter—The Minimizer—con-
taining valuable waste minimization information for small busi-
nesses. Articles have covered:
• a synopsis of waste minimization practices for small busi-
nesses,
• right-to-know compliance,
• used oil recycling,
• waste minimization case studies,
• regulatory updates, and
• a calendar of events.
The Minimizer currently reaches 2,600 businesses, trade associa-
tions, and individuals interested in waste minimization. To begin
receiving The Minimizer, contact the Hazardous Materials Hotline
at (800) 334-CHMR and you will be placed on the mailing list.
CHMR
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11-29
CHMR Speakers Bureau
As part of the statewide hazardous materials technical assistance
program, CHMR can provide speakers on important subjects to
address trade associations, businesses, and other organizations.
A partial list of topics currently offered by CHMR include:
• small quantity hazardous waste generator regulations,
• hazardous waste minimization,
• community right-to-know and emergency response,
• protecting drinking water,
• pesticide waste management,
• management of underground storage tanks, and
• health and safety training.
For more information and to make arrangements for a CHMR
speakerforyourtrade association, business, ororganization, write
to CHMR at the above address, or call our Hazardous Materials
Hotline at (800) 334-CHMR.
On-Site Consultations
Another aspect of CHMR's technical assistance program is on-site
consultation services which are provided to small and medium-
sized businesses. CHMR makes one-day visits to businesses to
provide clients with ageneral assessment of their hazardous waste
management needs and compliance requirements, as well as
identification of opportunities for minimizing hazardous waste
generation.
CHMR provides a number of technical on-site consultation serv-
ices, including:
CO 1989
CHMR
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11-30
• identification and implementation of waste reduction oppor-
tunities;
• environmental compliance reviews (e.g., OSHA, RCRA,
SARA);
• independent, third-party environmental evaluations;
• risk assessments;
• facility permitting guidance;
• air, land, and water contamination investigations;
• environmental crisis evaluations;
• environmental liability investigations; and
• environmental property assessments.
Services performed are tailored to meet specific needs of the client.
Fees for these services are based on the size and scope of the
project.
11.8.2 Important Telephone Numbers
U.S. Environmental Protection Agency
U.S. EPA Region 3
Waste Management Branch (215) 597-0980
PA Department of Environmental Resources
Bureau of Solid Waste Management (717) 787-6239
Director's Office (717) 787-9870
Assistant Director's Office (717) 787-9871
Division of Facilities Management (717) 787-7381
or 787-1749
© 1989 J^m CHMR
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11-31
Division of Resource Recovery
and Planning (717)787-7382
Division of Emergency and
Remedial Response (717) 783-7816
Division of Compliance and Monitoring (717) 787-6239
Regional Offices
Meadville (814)724-8557
Pittsburgh (412)645-7100
Williamsport (717)327-3636
Harrisburg (717)657-4585
Wilkes-Barre (717)826-2511
Norristown (215)270-1900
PA Used Oil Recycling Information Center (717) 783-6004
Recycling Hotline (800) 346-4242
RADON technical assistance in PA (800) 23-RADON
PA Department of Labor and Industry
Right to Know Office (717) 783-2071
PA Department of Transportation
Motor Carrier Safety Division (717) 787-7444
PA State Police
State Fire Marshall
(Captain Joseph Robyak) (717) 783-5529
11989 mm CHMR
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11-32
11.8.3 Names and Addresses of Resource Organizations
Center for Hazardous Materials Research
University of Pittsburgh Applied Research Center
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Hazardous Materials Hotline: (800) 334-CHMR
Pennsylvania Environmental Council
225 South 15th Street - Suite 506
Lewis Tower Building
Philadelphia, PA 19102
(215)735-0966
U.S. EPA, Region III
Waste Management Branch
841 Chestnut Building (3HW30)
Philadelphia, PA 19107
(215)597-0980
PA Department of Environmental Resources (PA DER)
Bureau of Solid Waste Management
Third and Locust Streets
Fulton Bank Building - 8th Floor
Harrisburg, PA 17120
(717)787-9870
PA DER Regional Offices
PA DER Meadville Regional Office
1012 Water Street
Meadville, PA 16335
(814)724-8557
PA DER Pittsburgh Regional Office
4th Floor- Highland Building
121 South Highland Avenue
Pittsburgh, PA 15206
(412)645-7100
1989 •• CHMR
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11-33
PA DER Williamsport Regional Office
200 Pine Street
Williamsport, PA 17701
(717) 327-3636
PA DER Harrisburg Regional Office
1 Ararat Boulevard
Harrisburg, PA 17110
(717) 657-4585
PA DER Norristown Regional Office
1875 New Hope Street
Norristown, PA 19401
(215)270-1900
PA Department of Labor and Industry
Right to Know Office
Room 1404
Labor and Industry Building
7th and Forster Streets
Harrisburg, PA 17120
(717)783-2071
PennDOT
Motor Carrier Safety Division
Room 215
Transportation and Safety Building
Harrisburg, PA 17120
(717)787-7444
State Fire Marshall
PA State Police Fire Marshall's Bureau
1800 Elmerton Avenue
Harrisburg, PA 17110
(717)783-5529
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CHAPTER
12.0 APPENDICES
APPENDIX 12.1
List of Wastes Specifically Excluded from
the Definition of a RCRA Solid Waste
or a RCRA Hazardous Waste
' 1989
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12-2
The following wastes are excluded from the definition of a RCRA
solid waste:
• domestic sewage;
• any mixture of domestic sewage and other wastes treated
by POTWs;
• NPDES permitted industrial wastewater discharges (does
not exclude industrial wastewaters while they are being col-
lected, stored, or treated before discharge or sludges thereby
generated);
• irrigation return flows;
• source, special nuclear or by-product material as defined by
the Atomic Energy Act of 1954;
• certain materials subjected to in situ mining techniques;
• certain pulping liquors;
• spent sulfuric acid used to produce virgin sulfuric acid;
• secondary materials that are reclaimed and returned to the
original process or processes in which they were generated
where they are reused in the production process subject to
certain provisions.
The following solid wastes are excluded from the definition of a
RCRA hazardous waste:
• household waste;
• certain agricultural solid wastes returned to the soil as
fertilizers;
• mining overburden returned to the mine site;
• fly ash waste, bottom ash waste, slag waste, flue gas
emission control waste;
• drilling fluids and produced waste;
• some wastes which fail the test for EP toxicity because
chromium is present;
• solid waste from the extraction, beneficiation and process-
ing of ores;
• cement kiln dust waste;
• certain solid waste which consists of discarded wood or
wood products and which fails the test for EP toxicity.
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12-3
APPENDIX 12.2
EPA's Lists of Hazardous Wastes
Note: The following pages are taken from 40 CFR Part 261 as of
8/18/88. Since regulations are often changing, please check with
a regulatory agency to see if any changes have been made which
may apply to you.
1989
CHMR
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12-4
Subpart 0—Lists of Hazardous Wastes
[Interim final]
§261.30 General.
(a) A solid waste is a hazardous
waste if it is listed in this Subpart,
unless it has been excluded from this list
under § § 260.20 and 260.22.
(b) The Administrator will indicate his
basis for listing the classes or types of
wastes listed in this Subpart by
employing one or more of the following
Hazard Codes:
Ignitable Waste (i)
Con-osiva Waste (C)
Reactive Waste . . . . (R)
EP Toxic Waste (E)
Acute Hazardous Waste. (H)
Toxic Waste (T)
Appendix VII identifies the constituent
which caused the Administrator to list
the waste as an EP Toxic Waste (E) or
Toxic Waste (T) in §§ 261.31 and 261.32.
(c) Each hazardous wasts- listed in this
Subpart is assigned an EPA Hazardous
Waste Number which precedes the
name of the waste. This number must be
used in complying with the notification
requirements of Section 3010 of the Act
and certain recordkeeping and reporting
requirements under Parts 262 through
265, 268 and Part 270 of this Chapter.
[261.30(c) amended by 48 FR 14153,
April 1, 1983; 51 FR 40636, November 7,
1986]
(d) The following hazardous wastes list-
ed in §261.31 or §261.32 are subject to the
exclusion limits for acutely hazardous
wastes established in §261.5: EPA Haz-
ardous Wastes Nos. FO20, FO21, FO22,
FO23, FO26, and FO27.
[261.30(d) revised by 45 FR 74890,
November 12, 1980; 50 FR 1999, January
14, 1985]
[Sec. 261.30(d)]
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12-5
§261.31 Hazardous waste from nonspeci-
fic sources.
The following solid wastes are listed
hazardous wastes from non-specific
sources unless they are excluded under
§§260.20 and 260.22 and listed in Appen-
dix XI.
[261 31 introductory text added by 49 FR
37070. September 21, 1984]
Industry and EPA
hazardous waste No
Hazardous waste
Generic
F001 — • The following spent halogenated solvents used in degreasing tetrachloroettiylene. tnchloroethylene, methylene chloride. 1.1,1-
trichloroethane, carbon tetrachlonde, and chlorinated fluorocarbons, all spent solvent mixtures/Blends used in degreasing
containing, before use. a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those
solvents listed in F002, F004 and F005. and still bottoms from the recovery of these spent solvents and spent solvent mixtures CO
F002 The following spent halogenated solvents tetrachloroethylene, methylene chloride, tnchloroethylene, 1. 1, 1-tnchloroethane.
chlorobenzene, 1,1, 2-tnchloro-l. 2, 2-tnfluoroethane, orthodichlorobenzene. trichlorofluoromethane, and 1,1, 2-trichloroethane,
all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above
halogenated solvents or those listed in FOOL F004, or F005, and still bottoms from the recovery of these spent solvents and
spent solvent mixtures fH
F003 The following spent non-halogenated solvents xylene, acetone, ethyl acetate, ethyl Benzene ethyl ether, methyl isobutyl ketone. n-
butyl alcohol, cyclohexanone. and methanol. all spent solvent mixtures/blends containing, before use only the above spent non-
halogenated solvents, and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated
solvents, and, a total of ten percent or more (by volume) of one or more of those solvents listed in FOOi, F002. F004, and F005,
and still bottoms from the recovery of these spent solvents and spent solvent mixtures (!)"
F004 The following spent non-halogenated solvents cresols and cresylic acid, and nitrobenzene, all spent solvent mixtures/blends
containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those
solvents listed in F001, F002. and F005. and still bottoms from the recovery of these spent solvents and spent solvent mixtures CO
F0°5 The following spent non-halogenated solvents' toluene, methyl ethyl ketone. carbon disulfide. isobutanol. pyndme, benzene, 2-
ethoxyethanol, and 2-nitropropane, all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by
volume) of one or more of the above non-halogenated solvents or those solvents listed in FOOL F002, or F004, and still bottoms
from the recovery of these spent solvents and spent solvent mixtures ('• T
F006 Wastewater treatment sludges from electroplating operations except from the following processes (1) sultunc acid anodizmy o' aluminum. (T)
(2) tin plating on carbon steel. (3) zinc plating (segregated basis) on carbon sleel. (4) aluminum or zinc-aluminum plating on carbon steel
(5) cleaning/stripping associated with tin. zinc and aluminum plating on carbon steel, and (6) chemical etching and milling ol aluminum,
F01B Wastewater treatment sludoes from the c^^'^a'<-nnupr*ion eoatino_ of aluminum ... CD
FO07 Spent Cyanide plating bath solutions fioV electroplating operations (R, T)
F008 Plating sludges from the bottom of plating baths from electroplating operations where cyanides are used in the process (R. T)
FO09 Spent slipping and cleaning bath solutions from electroplating operations where cyanides are used in the process (R, T)
FOf 0 Quenching bath residues from on baths from metal heat treating operations where cyanides are used in the process {R. T)
FO11 Spent cyanide solutions from salt bath pot cleaning from metal heat treating operations (R, T)
F012 Quenching wastewater treatment sludges from meta heat treating operations where cyanides are used in the process (T)
FO24 Wastes, including, but not limited to. distillation residues, heavy ends. tars, and reactor cleanout wastes from the production of (T)
chlorinated aliphatic hydrocarbons, having carbon content from one to five, utilizing free radical catalyzed processes [This listing
does not include light ends, spent filters and filter aids, spent dessicants. wastewater. wastewater treatment sludges, spent
catalysts, and wastes listed in §261 32]
F020 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production or manufacturing use las a (H)
reactant. chemical intermediate, or component in a formulating process) ol tn- or tetrachlorophenol, or o( intermediates used to
produce their pesticide derivatives (This listing does not include wastes from the production of Hexachlorophena
from highly purified 2,4.5-tnchlorophenol)
FO21 Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production or manufacturing use (as a (H)
reactant. chemical intermediate, or component in a formulating process) of pentachlorophenol, or of intermediates used to
produce its derivatives
FO22 Wastes (except wastewater and spent carbon from hydrogen chlonde purification! from the manufactunng use (as a reactant, (H)
chemical intermediate, or component in a formulating process) of tetra-, penta-, or hexachlorobenzenes under
alkaline conditions
FO23 ... Wastes (except wastewater and spent carbon from hydrogen chlonde purification) from the production of materials on equipment (H)
previously used for me production or manufactunng use (as a reactant. chemical intermediate or component m a formulating
process) of tri- and tetrachlorophenols (This listing does not include wastes from equipment used only tor the production or use of
Hexachlorophene from highly purified 2.4,5-trichlorophenol)
FO26 .. Wastes (except wastewater and spent carbon from hydrogen chloride purification) from the production of materials on equipment (H)
previously used for the manufacturing use (as a reactant, chemical intermediate, or component in a formulating process)
of tetra-. penta-, or hexacniorobenzene under alkaline conditions
FO27 Discarded unused formulations containing tn-, tetra-. or pentachloropheno! or discarded unused formulation containing compounds (H)
derived from these chlorophenols (This listing does not include formulations containing Hexachlorophsne synthesized from
prepunfied 2,4,5-tnchloropheno! as the sole component}
FO28 Residues resulting from the incineration or thermal treatment of soil contaminated with EPA Hazardous Waste Nos F020 FO21 (T)
FO22. F023. FO26, and FO27
• (I, T) should be used to specify mixture containing
ignitable and toxic constituents
[261 31 amended by 45 FR 47833. July 16, 1980. revised by 45 FR 74890. November 12.1980, 46 FR 4617. January 16,1981. 46 FR
27476. May 20,1981,49 FR5312, February 10. 1984, 50 FR 661, January 4, 1985,50 FR 1999. January 14. 1985, 50 FR 53319, De-
cember 31, 1985. corrected by 51 FR 2702. January 21. 1986, amended by 51 FR 6541, February 25, 1986J
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12-6
§261.32 Hazardous waste from specific
sources.
The following solid wastes are listed
hazardous wastes from specific sources un-
less they are excluded under
§§260.20 and 260.22 and listed in Appen-
dix IX.
[261.32 introductory text added by 49 FR
37070. September 21, 1984]
industry and EPA na^aid
»aste No
Wood preservation KOCI
inorganic pigments.
K002
K003 .
K004
K005
K006
KOO'
K008
Organic chemicals
K009
K010
K011
K013
KOI4 .
KOI 5
K016
K017
K018
K019
K020
K021
K022
K023
K024
K093
K094
K02S
K026
K027
K028
K029
K095
K096
K030
K0«3
K103
K104
K085
K105.
K111
K112
K113
K114
K115
K116
K117
K118
K136
| Sonom sediment s'udge trom tne trealment of wastewaters Irorr, wood
, processes mat use creosote and/ or pentacnioropnenoi
Hazard
code
(T)
' Wastewater ''eatment siuoge from the production of cnrome yellow and orange (T)
| pigments !
, Wastewater treatment sludge from the production ot molybdate orange pigments | (T)
; Wastewate- treat.-nem siuOge from the production ol zinc yeilow pigments
I Wastewater treatment sludge irom tne production ol cnrome green pigments
i Wastewater trealment sludge trom the production ol cnrome oxide green pigments
I (anhydrous and nydrated)
1 Wastewater tredtrrien' sludge from the production ot iron blue pigments
! Oven residue trom tr-e production ol chrome oxide green pigments
i
i Distillation Dotloms trom tne production ot acetaldenyde trom ethylene
1 Distillation side cuts from the production ot acetaidehyde trom ethyiene
• Bonorn stream ttorr the y.astewaier stopper in me pioouction o) acryloniinie
i Bottom stream trom the acetonunie column in tne production of acrylonitnle
Bottoms trom the acetonitnle purification column in the production o* acrylonitnle
, Stilt bottoms from the distillation of benzyl chloride
I Heavy ends or distillation residues irom tne production ot canon tetrachlonde
' Heavy ends tstiti bottoms) from the purification column in the production of
i epicnioronydnn
! Heavy enos trom the Iractionation column in ethyl cMoride production
i Heavy ends trom the distillation of ethyiene dichloriOe in ethyiene dichlonde
production
Heavy ends from the distillation of vmyt chloride in vinyl chtonde monomer
production
Aqueous spent antimony catalyst waste from fluoromethanes production
Distillation bottom tars trom the production of phenol/acetone from Cumene
Distillation light ends from the production ot phthaiic anhydride from naphthalene
Distillation bottoms from the production of pfithalic anhydride from naphthalene
Distillation hgr; ends from the production o' pnthanc anhydride from onno-xy'ene
Distillation bottoms from the production ot phtnalic anhydride from ortho-xyiene
Distillation bottoms from the production ot nitrobenzene by the nitration of benzene
Stripping still tails trom me production ol metny elnyt pyndines
Centrifuge and distillation residues from toluene dusocyanate production
Spent catalyst from the hydrochlonnatof reactor in the production of 1.1,1-tnchlor-
oethane
Waste from the product steam Stripper in the production of 1,1,1-trichloroethane
Distillation bottoms trom the production of 1.1, \ -tnchloroethane .
Heavy ends from tne heavy ends column from the production of 1.1.l-tnchloroelh«
ane
Column bottoms or ^eavy ends from the combined production of tnchloroethyfene
and perchloroethylene
Distillation bottoms trom aniline production
Process residues from aniline extraction from the production of aniline
Combined wastewater streams generated 'rom nitrobenzene/aniline production
I Distillation or fractionation column bottoms from the production ot cnlorobenzene*
I Separated aqueous stream from the reactor product washing step in the production
| cl cnloroOenzenes
(T)
(T)
(T)
cn
it)
m
(T)
(R. T)
(R. T)
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12-7
Industry and EPA hazardous
waste No
Hazardous waste
Inorganic chemicals
K071 I Bnne purification m^ds i'om tne mercury eel1 process m cnlonne production wne'fc
I separately prepunfied br.ne is not used
K073 i Chionnatec tvdrocaroor waste from the cunficanon step ol tne diapnragr> cell
I process using graph.ie anodes m cnionne production
K106 I Wastewater treatment siudge trom the mercury cell process m cnlonne production
Pesticides
K031 By-product sails generated in the production of MSMA ana ca«Wy»c acia
K032 Wastewa:e* treatment s'^dge '-cm the prcducvon c' chiorca^e
K033 Wastewater anc scruo waie' trorr ire cmonnatior of cyciopentadiene m me
production cf cr.iorcane
K034 ' Filter solids from me Miration of nexacniorocyciopentaci'ene in the production o*
| chiordane
K097 ; Vacuum stripper Discharge 'ro1^ the chiordane cnio"naior in the production of
j chiordane
K035 , Wastewaier treatment sludges ijenerated in me prooucticn ol creosote
K036 ' Still bottoms iro-1 toluene reclamation dis; iianon r ire p-ca^c':on cf 3'sjifo'cr
K037 | Wastewaier treatment sludges 'rom tie proouctc' o' j-Sdiu;on
K038 | Wastewater from tne washing arc stripping cf pno-a'e production
K039 F.ner ca^e from me filtration ot diemyipnospnoroa>tnioi: ac>c ^ me production ol
phorate
K040 Wastewater treatment sludge from the production of phorate
K041 Wastewater treatment sludge from the production of toxaphene
K098 Untreated process wastewater from the production of toxaphene
K042 Heavy ends or distillation residues from the distillation of tetrachlorobenzene in the
production of 24,5-T
K043 2,6-Dichlorophenol waste from the production of 2,4-D
K099 Untreated wastewater from the production of 2 4-D
[K123 through !26 added by 51 FR
37728. October 24, 1986]
(T)
m
m
(T)
rn
m
K123
K124
K125
K126
Explosives
K044
K045
K046
K047
Petroleum refining
K048
K049 .
K050
K051
K052
Iron and steel
K061
K062
Secondary lead
K069 .
K100
Veterinary Pharmaceuticals
K084
K101
K102
Ink formulation K086
Coking
K060
K087
Process wastewater (including supernates, filtrates, and washwaters) from the produc-
tion of ethylenebisdithiocarbamic acid and its salt
Reactor vent scrubber water from the production of ethylenebisdrthiocarbamic acid
and its salts
Filtration evaporation, and centrifugation solids from the production of ethylenebisdith-
locaroamic acid and its salts
Baghouse dust and floor sweepings in milling and packaging operations from the
production or formulation of ethylenebisdithiocarbamic acid and its salts
Wastewater treatment sludges from the manufacturing and processing of explosives .
Spent carbon from the treatment of wastewater containing explosives
Wastewater treatment sludges from the manufacturing formulation and
loading of lead-based initiating compounds
Pink/red water from TNT operations
Dissolved air flotation (DAF) float from the petroleum refining industry . . .
Slop oil e1 sion solids from the petroleum refining industry
Heat exchanger bundle cleaning sludge from the petroleum refining industry
API separator sludge from the petroleum refining industry
Tank bottoms (leaded) from the petroleum refining industry
Emission control dust/sludge from the primary production of steel in
electric furnaces
Spent pickle liquor generated by steel finishing opera-
tions of facilities within the iron or steel industry (SIC Codes 331
and 332)
Emission control dust/sludge from secondary lead smelting
Waste leaching solution from acid leaching of emission control dust/
sludge from secondary lead smelting
Wastewaier treatment sludges generated during the production of veterinary
Pharmaceuticals from arsenic or organo-arsenic compounds
Distillation tar residues from the distillation of aniline-based compounds in
the production of veterinary Pharmaceuticals from arsenic or organo-
arsenic compounds
Residue from the use ot activated carbon for oecolonzation in the
production of veterinary Pharmaceuticals from arsenic of organo-arsenic
compounds
Solvent washes and sludges, caustic washes and sludges or water washes and
sludges from cleaning tubs and equipment used in the formulation of ink from
pigments driers, soaps, and stabilizers containing chromium and lead
Ammonia still lime sludge from coking operations
Decanter tank far sludge from coking operations
m
(C, T)
(T)
(T)
(R)
(R)
(T)
(R)
(T)
(T)
(T)
(T)
(T)
(T)
(C.T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(T)
(261 32 amended b> 45 FR 4783? Julv 16. 1980 45 FR "2039. October 30. 1980. revised b> 45
FR 74980. November 12. 1980. 46 FR 4617. Januarx 16 1981 46 FR 27476. May 20. 1981; 50
FR 42942, October 23, 1985, 51 FR 5330, Februan 13. 1986. 51 FR 19322, May 28, 1986;
corrected by 51 FR 33612, Sepiember 22, 1986. amended b\ 51 FR 37728. October 24. J986]
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12-8
§261.33 Discarded commercial chemical
products, off-specification species, con-
tainer residues, and spill residues
thereof.
[261 33 revised by 45 FR 78541, Novem-
ber 25, 1980]
The following materials or items are
hazardous wastes if and when they are
discarded or intended to be discarded
as described in § 261.2(a)(2)(i), when
they are mixed with waste oil or used
oil or other material and applied to
the land for dust suppression or road
treatment, when they are otherwise
applied to the land in lieu of their
original intended use or when they are
contained in products that are applied
to the land in lieu of their original in-
tended use, or when, in lieu of their
original intended use, they are pro-
duced for use as (or as a component
of) a fuel, distributed for use as a fuel,
or burned as a fuel.
[261 33 introductory text amended by 49
FR 37070, September 21. 1984; 50 FR
661, January 4, 1985; 50 FR 28742, July
15. 1985; 52 FR 21306, June 5, 1987]
(a) Any commercial chemical prod-
uct, or manufacturing chemical inter-
mediate having the generic name
listed in paragraph (e) or (f) of this
section.
(b) Any off-specification commercial
chemical product or manufacturing
chemical intermediate which, if it met
specifications, would have the generic
name listed in paragraph (e) or (f) of
this section.
(c) Any reissue remaining in a con-
tainer or in an inner liner removed
hum ,1 container that has held any
commercial chemical product or manu-
facturing chemical intermediate having
the generic name listed in paragraph
|e) of this section, unless the container
is empty as defined in §261 7fb)(3) of
this chapter
[Comment Unless the residue is being
beneficialk used or reused, or legitimately
rec\cled or reclaimed, or being accumulat-
ed, stored, transported or treated prior to
such use, re-use, recycling or reclamation,
EPA considers the residue to be intended
for discard, and thus, a hazardous waste
An example of legitimate re-use of the resi-
due would be where the residue remains in
the container and the container is used to
hold the same commercial chemical product
or manufacturing chermca! intermediate it
previously held An example of the discaid
of the residue would be where the drum is
sent to a drum reconriitioner \\ho recondi-
tions the drum but discards the residue ]
[261 33(c) revised by 45 FR 78541, No-
vember 25, 1980; 46 FR 27476, May 20.
1981; corrected by 52 FR 26012, July 10.
1987]
(d) Any residue or contaminated soil,
water or other debris resulting from
the cleanup of a spill into or on any
land or water of any commercial
chemical product or manufacturing
chemical intermediate having the ge-
neric name listed in paragraph (e) or
(f) of this section, or any residue or
contaminated soil, water or other
debris resulting from the cleanup of a
spill, into or on any land or water, of
any off-specification chemical product
and manufacturing chemical interme-
diate which, if it met specifications,
would have the generic name listed in
paragraph (e) or (f) of this section.
[.Comment: The phrase "commercial chemi-
cal product or manufacturing chemical in-
termediate having the generic name listed
in . ." refers to a chemical substance
which is manufactured or formulated for
commercial or manufacturing use which
consists of the commercially pure grade of
the chemical, any technical yiaues of the
chemical that are produced or marketed,
and all formulations in which the chemical
Is the sole active ingredient. It does not
refer to a material, such as a manufacturing
process waste, that contains any of the sub-
stances listed in paragraphs (e) or (f).
Where a manufacturing process waste is
deemed to be a hazardous waste because it
contains a substance listed in paragraphs (e)
or (f), such waste will be listed in either
§§ 261.31 or 261.32 or wi'l be identified as a
hazardous waste by the characteristics set
forth in Subpart C of this part.]
[261.33(d) amended by 46 FR 27476,
May 20, 1981]
(e) The commercial chemical prod-
ucts, manufacturing chemical interme-
diates or off-specification commercial
chemical products or manufacturing
chemical intermediates referred to in
paragraphs (a) through (d) of this sec-
tion, are identified as acute hazardous
wastes (H) and are subject to be the
small quantity exclusion defined in
§ 261.5(e).
[Comment: For the convenience of the regu-
lated community the primary hazardous
properties of these materials have been indi-
cated by the letters T (Toxicity), and R (Re-
activity). Absence of a letter indicates that
the compound only is listed for acute toxic-
ity.]
These wastes and their correspond-
ing EPA Hazardous Waste Numbers
are:
[261 33(e) amended by 46 FR 27476.
May 20. 1981; corrected ind revised by 51
FR"28297, Aucust 6. 1986, (e) table cor-
rected by 53 FR 13382. April 22. 1988;
amended by 53 FR 43883. October 31.
1988]
[Sec. 261 33(e)]
-------
12-9
Haz-
ardous
ND
P023
P002
P057
POJ-S
P002
P003
P070
P004
POOS
P006
PC07
PO'Jrt
P009
P119
P093
P010
P012
P011
PO! 1
PC1 2
P018
P036
POC4
POG7
P013
P024
P077
PC28
PO-12
P04G
P014
PQ01
PC28
P015
P017
PO'8
PC»5
P021
P021
P022
P035
P023
PC 24
POPS
P027
P029
P029
P030
P031
P033
P033
P034
P016
P036
P037
P038
P041
P040
P043
P004
P060
P037
P051
Chemical
abstracts No
107-20-0
591-08-2
640-19-7
62-74-8
591-08-2
107-02-. 5
116-06-3
•J09-00-2
107-18-6
20959-73-8
2763-96-4
504-24-5
131-74-8
7603-55-6
506-61-6
77/6-39-4
1327-53-3
1 .103 -28-2
1303 28-?
1127-53-3
6^2 42-2
b'j6-28-6
151 -"6-4
/5-55-S
542-62-1
106-47-8
100-01-6
100-44-7
51-13-4
122-09-8
108-98-5
1 81 81-2
100-44-7
74.iO-41-7
598-31-2
357-57-3
39196-18-4
692-01-8
592-01-8
75-15-0
75-44-5
107-23 0
106-47-8
5344-82-1
542-76-7
544-92-3
544-92-3
460-19-5
506-77-4
506-77-4
131-89-5
542-8S-1
696-28-6
60-57-1
692-42-2
311-45-5
297-97-2
55-91-4
309-00-2
465-73-6
60-57-1
' 72-20-8
Substante
Acetaldehydo, thio'O-
Acetamide, N-laminothioxo^ethyi)
Acetamide, 2-fluoro-
Acetic acid, fluoro-, sod.um salt
1-Acetyl-2-thiourea
Acrolem
A'aicarb
Aldnn
Allyl alcohol
Aluminum phosphide iR.1)
5-jArr.inometny')-3-isoxazolol
4-Aminopyridme
Ammonium picrate (R)
Ammonium vanadate
Argenlated-). bib(cyaoo-C)- potassiuni
Arsenic acid HjAsC,
Aisemc ox de As.O.
Arsenic oido Ab~O.
Arsenic pen'ovidt
Arsenic tnoxido
Arsire, diethyi-
Arsonous d'Chlondo p^-er.yi.
Azindine
Azindme, 2-me!hyl-
Barium cyanide
Benzenamme, '4-chicro-
Benzenam»ne, 4-nitto-
Bonzene. (ch'orOiTiethyi)-
1 2-Be"ver:ediol 4 ] 1-hyo'ro*)'-2 trr>unyl2~ino)othyl]-.
(R)-
Benzer.eethana'Time alpna alpfia-d'metfy!-
Benzenethiol
2H-1-Bc-nzopyran-2-ona, 4-hydroxy 3-(3-cxo-1 phenyl-
bot/l)-, & salts, *'ien present at concentrations
greater than 0 3J°
Benzyl chloride
Beryllium
Bromoacetono
Brucine
2-BManone, 3.3-oimethyi-i-(methyitnio)-
0-[methy!aiTiino}carboriyl! Oxime
Calcium cyanide
Calcium cyanide Cai,CN}?
Carbon disuifide
Carbonic dicnlorioe
Chloroacetaidehyde
p-Chioroanilme
1 -(o-ChiorophenylHhiourea
3-Chloropropionitnle
Copper cyanide
Copper cyanide Cu(CN)
Cyanides (soluble cyanide sarts). not otherwise spec-
ified
Cyanogen
Cyanogen chlor'de
Cyanogen chlonde (CN)CI
2-Cyclohexyl-4,6-dinitropheno!
Dichloromethyl ether
Dichlorophenyfarsme
Dieldrin
Diethylarsine
Diethyl-p-nitrophenyl phosphate
O.O-Diethyt O-pyrazmyl phosphorothioate
Dusopropylfluorophosphate (DFP)
1,4,5,8-Dimethanonaphthalene, 1, 2,3, 4,10. 10-hexa-
chloro-1.4,4a,5 8,8a,-hexahydro-,
(1 alpha, 4alpha,4abeta, 5a!pha,8alpha, Sabeta)-
1.4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa-
chloro-1,4,4a,5 8.8a-hexahydro-,
(1 alpha 4alpha,4abeta,5beta,8beta,8abeta).
2,7 3,6-Dimethanonaphth|2,3-b|oxirene, 3,4.5,6,9,9-
hexachloro-la,2,2a,3,6,6a,7,7a-octahydro-,
(iaaipha.2beta,2aalpha,3beta.6beta.6aa(pha,7beta,
7aalpha)-
2,7 3.6-Dimethanonaphth |2,3-b]oxirene, 3,4,5,6,9,9-
hexachlorc-1a.2.2a.3.6,6a,7,7a-octa hydro-,
(1aalpha,2beta,2abeta,3a'pha 6alpha 6abeta,7beta,
7aalpha)-, & metabolites
Haz-
ardous
P044
PC46
PC47
P043
P020
P08b
Pm
P039
PO-19
P050
P0b3
P051
F051
P042
P031
P101
P054
P097
P056
P057
POiS
Pi.'bf.
POM
P06?
P116
P-068
FOBS
PC63
P0f6
P060
PCO?
P092
POCb
F032
POfr:
P016
P112
PH8
P050
P059
P066
P068
P064
P0b9
P071
P072
P073
P073
P074
P074
P075
P076
P077
P078
P076
P078
P081
P082
P084
P085
P087
P087
P088
P089
P034
P048
P047
P020
P009
P092
P093
P094
P095
P096
P041
abstracts No
Substance
60-51-5
122-09-8
1 534-52-1
51-28-5
88-85-7
152-16-9
107-49-3
293-04-4
541-53-7
115-29-7
145-73-3
72-20-8
72-20-8
51-43-4
4cO-19-5
16752-77-5
107-12-0
151-56-4
52-85-7
7TS2-41-4
6-10-19-7
62-74-8
628-86-4
76-44-8
757-58-4
79-19-6
6C-34-4
74-90-3
74-90-8
7S03-51-2
465-73-S
2763-96-4
62-38-4
628-66-4
62-75-9
624-83-9
542-68-1
509-14-8
75-70-7
115-29 7
76-44-8
16752-77-5
60-34-4
624-83-9
75-8S-5
298-00-0
86-88-4
13463-39-3
13463-39-3
557-19-7
557-19-7
' 54-11-5
10102-43-9
100-01-6
10102-44-0
10102-43-9
10102-44-0
55-63-0
62-75-9
4549-40-0
152-16-9
20816-12-0
20816-12-0
145-73-3
56-38-2
131-89-5
51-28-5
' 534-52-1
88-85-7
131-74-8
62-38-4
103-85-5
298-02-2
75-44-5
7803-51-2
311-45-5
Environment Reporter
Dirrethoate
alpha,alpha-Din'ethylphenethylaniir.e
4,6-Dinrtto-o-cresol, & salts
2,4-Dmitrophenol
Dinoseb
Diphosphoramide, octamethyl-
Diphosphonc acid, teUaethyl ester
Disulfoton
Dith'ob'uret
Endosulfan
Enrfothall
Endnn
Endnn, & metabolites
Epmephrine
Ethanedinitnle
Ethammidothioic acid,
N-!'i(methylamino)carbonyl|oxy|-. methyl este'
Ethyl cyanide
Ethyleneimme
Fsmphur
Fluor'ne
Fluoroacetamida
Fluoroacetic acid, sodium sail
Fijlm.nic acid, mercury(2 ( ) salt (R.T)
Heptachlor
Hexaethyl tetraphosphate
Hydrazinccarbothioamide
Hydrazine, methyl
Hydrocyanic acid
Hyorogen cyanide
Hydrogen phosphide
Isodrm
3(2H)-lscxczolOPa, 5-(aminon',e'.hyl|-
Mercury (aci.'U!to-0)ph«r.yl-
Mercury (ulm.nate (R T)
Methanamme, N-methyl-N-nitroso-
Methane, 'socyanato-
Methane, oxybislchtoro-
Methane, tetran.tro- (R)
Methanethiol, trichloro-
6,9-Methano-2,4,3-benzodioxatriiepin, 6,7,8,9,10,10-
hexachloro-1,5,5a,6,9,9a-hexahydro-, 3-oxide
4,7-Meihano-1H-indene, 1,4.5 6,7,8,8-heptachloro-
3a.4,7,7a-tetrahydro-
Methomyl
Methyl hydrazme
Methyl isocyanate
2-Methyllactonrtnle
Methyl parathion
alpha-Naphthylthiourea
Nickel carbonyl
Nickel carbonyl Ni(CO)<, (T-4)-
Nickel cyanide
Nickel cynaide Ni(CNh
Nicotine, & salts
Nitric oxide
p-Nitroaniline
Nitrogen dioxide
Nitrogen oxide NO
Nitrogen oxide NOj
Nitroglycerine (R)
N-Nitrosodimethylamine
N-Nitrosomethylvinylamine
Octamethylpyrophosphoramide
Osmium oxide OsO,, (T-4)-
Osmium tetroxide
7-Oxabicycto!2 2 1 ]heptane-2,3-dicartoxylic aod
Parathion
Phenol, 2-cyclohexyl-4,6-dinitr>
Phenol, 2,4-dimtro-
Phenol, 2-methyl-4,6-dinitro-, & salts
Phenol, 2-(1-methylpropyl)-4,6-d
-------
12-10
Hai-
ardous
.-.astu
No
P039
P094
P044
P043
P089
P040
P097
PC7!
P110
P098
P098
P093
P070
P',01
P027
P069
P081
PC17
P102
P003
POOS
P067
P102
P008
P075
P114
F103
P104
P->G4
P105
P106
P106
P107
P107
P108
PC' 18
P108
P115
P1C9
P110
P111
P112
P062
P113
P113
P114
P115
F109
P045
P049
POM
P1-6
P026
P072
P093
P123
P118
P1I9
P120
PI 20
PU84
P001
P121
P121
P122
Chemical
abstracts f,o ' ii.islaoce
298-04-4 j Phospnorodithioc acid. O.O-diethyl
j S-|2-(ettiyfthio)ethyl| ester
2S8-02-2 i Phosphofodithioic acid, O.O-dietnyl
S-!(ethyithio)methyt| ester
60-51-5 Phosphorodithioic acid. O.O-dimethyl S-!2-(methyl-
amino)-2-oxoethyl] ester
55-91-4 Ptiosphorofluondic acid, bis(l-methylethyl) es'er
56-38-2 Phcsphorothioic acid, O,O-diethyt O-(4-n'tropheoyl)
ester
297-97-2 Pnosphorothioic acid. O,0-diethyt O-pyrazmyl ester
52-85-7 Phosphorothioic acid,
O j4-[(dimethy1amino)sjltonyl Jpheny!] O.O-dimethyl
i ester
Z<)
ester
78-00-2 Plumbane. tetraethyl-
151-50-8 Potassium cyanide
151-50-8 Potassium cyanide K(CN)
506-61-6 Potassium silver cyanide
116-06-3 ! Propanal. 2-methyl-2-(methylthio)-.
I O-|(methylammo)carbonyl!oxime
107-12-0 j Propanenitnle
542-76-7 Propanenitnle, 3-chlo'O-
75-86-5 Propanenitnle, 2-hydroxy-2-melhyl
55-63-0 1,2,3-Propanetnol, trmitrate (R)
598-31-2 2-Propanone, 1-bromo-
107-19-7 Propargyl alcohol
1 07-02-8 2-Propenal
107-18-6 2-Propen-1-o!
75-55-8 1.2-Propylenimine
107-19-7 2-Propyn-1-ol
5C4-24-5 4-PyTidinamir>e
1 54-11-5 Pyndine, 3-(1-methyi-2-pyrrolidin/l)-. (S)-. & sails
12039-52-0 Selenious acid dithalhum(1 f) salt
630-10-4 ! Selenourea
506-64-9 i Silver cyanide
506-64-9 Silver cyanide Ag(CN)
25628-22-8 Sodium azide
1 43-33-9 Sodium cyanide
143-33-9 Sodium cyanide Na(CN)
1314-96-1 Strontium sulfKle
• [Removed b\ >3 !"R 43883, October ^i ]9sx]
'57-24-9 ,Strychnidin-10-one, & satts
357-57-3 Strycfimdin-10-one, 2,3-dirretno-7-
1 57-24-9 Strychane, 4 salts
7446-18-6 Sulfuric acid. dithalhum(1 -f ) salt
3689-24-5 Tetraethyldithiopyrophcsphate
i 78-00-2 Tetraetn/l lead
107-49-3 Tetraethyl pyrophosphate
509-14-8 Tetramtromethane (R)
757-58-4 Tetraphosphonc acid, hexaethyl ester
1314-32-5 Thailic oxide
1314-32-5 Thallium oxide TVO>
12039-52-0 Thallium(l) selenite
i 7446-18-6 Thallium(l) sullate
3689-24-5 Thiodiphosphonc acid, tetraethyl ester
39196-18-4 Thiofancx
S41-53-7 Thioimidodicarbomc diam.de [(HjN')C(S)i.NH
1 08-98-5 Thiophenol
79-19-6 Tmosemicarbazide
5344-82-1 Thiourea, (2-chlorophen/!)-
66-68-4 Thiourea, 1 -naphthalenyt-
1 03-85-5 Thiourea, phenyl-
80C 1-35-2 ' Toxaphene
75-70-7 Tnchioromethanethiol
7803-55-6 Vanadic acid, ammonium sat
1314-62-1 Vanadium oxide V-.O5
i 1314-62-1 Vanadium pentoxiae
' 4549-40-0 Vinylamine, N-methyl-N-nitroso-
1 81-61-2 Warfann, & salts, when present at concentrations
' greater than 0 3%
557-21-1 ' Zinc cyanide
I 557-21-1 Zinc cyanide Zn(CN),
I 1314-84-7 j Zinc phosphide Zn.,P:. wner present at concent/a-
[ I tions greater than 10% (R,T)
1 CAS Number given for parent compound only.
[Sec 261.33(e)]
-------
12-11
(() The commercial chemical products,
manufacturing chemical intermediates, or
o!T specification coiivvn-n ial chcm;c:l
products referred to in paragraphs (a)
through (d) of this section, are identified
as toxic wastes (T), unless otherwise desig-
nated and are subject to the small quanti-
t\ generator exclusion defined in
§261 5 (a) and (g)
(261 33(f) introductory paragraph
amended bv 51 FR 10174, March 24,
[Comment. For the convenience of the regu-
lated community, the primary hazardous
properties of these materials have been indi-
cated by the letters T (Toxicity), R (Reac-
tivity), I (Ignitability) and C (Corrosivity).
Absence of a letter indicates that the com-
pound is only listed for toxicity.l
These wastes and their correspond-
ing EPA Hazardous Waste Numbers
are:
|2(>13.'(l) amuided b\ 4<> IK 2"/4/ti
\1a> 10. I9K4, 50 I-R 1999, Januar> 14.
1985. 50 FR 42942. October 23, 1985,
corrected and revised b> 51 FR 28297,
August 6, 1986, (f) table corrected by 53
FR 13382, April 22, 1 °88: amended b\ 53
FR 43881, 43883. October 31. 1988]
Haz-
.ircous
t as'.e
No
UM.1
LIO:«
U187
uoor
U240
U112
U144
U2!4
see
F027
OOC2
U003
U004
U005
U006
'J007
U008
U009
U311
U0<2
U136
OCX
UO'5
UC10
Chemical
.ibbtrac's No
/5-C--0
."5-87-6
62 -4-2
53-9S-3
94-75-7
141--8-6
3CI-G4-2
563-68-8
93-76-5
67-64-1
75-05-8
98-86-2
53-96-3
75-36-5
79 -06-1
79-10-7
107-13-1
61-82-5
62-53-3
75-60-5
492-SO-8
115-C2-6
Substance
Act-aldehyde (I)
Ace'.aidehyde tnchlcro-
Aro;amide, N-M-ethoJcypheny1}-
Acetamide N-9H-Muoren-2-vl-
I
I
Acetic acid. (2 4-Oichlorophenoxyi- sa"s & es'e-s
Aceiic aod eihyl ester (I)
Acetic acid, lead(2 - ) salt
Acevc acid, lhalliumll -t. ) salt
Acetic acid (2 4 5-fichioropheno/y)-
Acetone (I)
Acetonitnie (!,T)
Acc'ophenone
2- Acet/lammofluof e^e
Acetyl chloride (C R T)
Acrylamide
Acrylic acid (I)
Ac'yionitnle
Arrvf/ole
Anilne (IJ)
ArSinic acid, dimetnyl-
Azasenne
I
i
I
Azifmo:2 .3' S.ilpvrro'oll^-almdoie^.^-dione 6
i ammo 8-U(amtnoca'bonyl)oxy]methyU
1.la,2,6.8a,8b-heiyl-
Haz-
ardous • C^emica!
•vaste ' abstracts Me
No
U222 636-21-5
U161 99-55-8
UQ19 j 71-43-2
U038 j 5" 0-1 5-6
UC30 ' 101-55-3
U035 305-03-3
U037 . 108-&0-7
U221 25376-45-8
U028 117-81-7
L'063 B4-74-2
U088 84-66-2
L'102 ; 131-11-3
'J107 117-84-0
U070 i 95-50-1
U071 541-73-1
U072 • 106-46-7
U060 72-54-8
UC17 , S8-67-3
U223 26471-62-5
U219 1330-20-7
U201 108-46-3
U127 118-74-1
UC56 110-82-7
U220 108-86-3
U105 : 121-14-2
UlCfi 1 606-20-2
UG55 j 98-82-8
Li169 ; 98-95-3
Ui83 . 606-93-5
U185 • 82-68-8
UC20 98-09-9
U02C ' 98-09-9
U207 i S5-94-3
U061 I 50-29-3
U247 72-43-5
0023 98-07-7
t 234 99-35-4
Sjbstance
Benzenamine, 2-methyl-, hydrochlonde
Benzenamine, 2-metnyi 5-n't;o-
Benzene (1 J)
Eenzeneacet'C acid, 4-chioro alpha-(4-chlorophcn/l)-
alpha-hydroxy-, ethyl ester
Benzene, t-bromo-4-pheno-y.
Benzenebutanoic acid 4-(bis(2-chlohceIhy|iamino|-
Benzene, chloro-
Benzenediarriine, ar-metnyl-
1,2-Benzenedicarboxytic acid, bis(2-ethyihe^y!) es'er
1 .2-Benzensdicarboxytic acid, dibutyl ester
1,2-Benzenedicarboxylic acid, diethyl estef
1,2-Benzenedicarboxylic acid, dimethyl ester
1,2-Benzenedicarboxylic acid, dioctyl esler
Benzene, 1,2-dichloro-
Benzene. LS-dichlj'O-
Benzene, 1 .4-dtchloro-
Benzene, 1,1'-(2,2-dich]oroethyhdene)bis(4 c.^ioro-
Beirene, (dichloromethyl)-
Benzer.e, 1,3-diisocyanatomethyl- (R.T)
Be"zene, dimethyl- (I T)
1,3-Benzenediol
Benzene, heicac.'itoro.
Benzene, hexahydro- (I)
Benzene, methyl-
Benzene, 1-nethyl-2,4-dinnro-
Benzens, 2-metPyl-1,3-d'n'!ro-
Benzene, (1-metly'e!hyl)- (1)
Benzene, nit'o-
Berzene, per,;achloro-
Benzene. pentacMo'onfo-
BenzenesuHonic acid Chionde (C.R)
Benzenesuilonyl chlonde (C.R)
Benzene. 1,2,4.5-tetrachloro-
Benzene, 1.1'-(2,2.2-tnchloroethylidene)bis|4-chioro-
Benzene, 1.1'-(2 2.2-tnchloroethylidene)bis!4- metK
oxy-
Benzone, (tnchloromethyl)-
Benzene. 1.3,5-tnmtro-
Benzenamine, •» 4'-methylenebis;2-chloro-
[Sec. 261.33(f)]
-------
12-12
Haz-
ardous
No
Cherrvcal
lhl-tr3C'S NO
Substance
U02'
U20S
U203
U141
U090
U064
U248
U022
U197
U023
U085
U021
U073
U091
U095
U225
U030
U128
U172
U031
U159
U160
UC53
U074
UM3
L'031
U135
U332
L'2'iS
LI 178
U097
U114
b'62
L'2'5
U033
U156
UC33
U211
UC34
U035
liOjfi
U026
LI037
UO^S
U039
U042
U044
U046
U047
U04S
92-87-5 |
81-07-2
94-59-7
120-58-1
94-58-6
189-55-9 '
'81-81-2
50-32-8
106-51-4 !
98-07-7
1464-53-5
92-87-5
91-94-1
119-90-4
119-93-7
75-25-2
101-55-3
87-68-3
924-16-3
71-36-3
78-93-3 j
1338-23-4
4170-30-3 S
13
2
764-4 1 -0
303-34-4
i
71-36-3 |
75-60-5
765-19-0 '
Et-79-6
615-53-2 I
79-44-7 ]
111-54-6
i
30,1-16-4
I
6533-73-9 i
353-50-4
-9-22-1 '
353-50-4 I
56-23-5
75-87-6
305-03-3 '
57-74-9
494-03-1
108-90-7
510-15-6
59-50-7
110-75-8
67-66-3
107-30-2
91-58-7
95-57-8
U049 : 3165 93-3
U032
UOSO
UC51
U052
U053
U055
U246
U197
U056
U129
UOS7
U130
U058
U240
U059
U060
U061
U062
U063
U054
13765-19-0
1
218-O1-9
319-77-3
4170-30-3
98-82-8
506-68-3
106-51-4
110-82-7
58-89-9
108-9-1-1
77-47-4
50-18-0
1 94-75-7
20833-81-3
72_5d-8
50-29-3
2303-16-4
53-70-3
189-55-9
Benztdine
1,2-Benzisothiazol-3(2H)-one, 1.1-dioxide, & salts
1,3-Benzodioxole, 5-(2-propenyl)-
1.3-Benzodioxole, 5-(1-propenyl)-
1,3-Benzodioxole, 5-propyl-
Benzo|rst]pentaphene
2H-1-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-1-phenyl-
butyl)-, & salts, when present at concentrations of
0 3% or tess
Benzo(a]pyrene
p-Benzoqumone
Benzotrichloride (C.R.T)
2.2'-Bioxirane
{1,1 '-Bipheny!J-4,4'-diarrMne
i1,V-Biphenyl]-4,4'-diamin€, 3,3'-aicWo'0-
[1,1'-Biphenyl|-4,4'-diarT«ne, 3,3'-dimethoxy-
(l,1'-Biphenyl)-4,4'-diannne, 3 3'-dimethyl-
Bromoform
4-Bromophenyl phenyl ether
1 3-Butadiene. 1,1,2,3,4,4-hexachioto-
1-Butanamme, N-butyl-N-mtroso-
1-Butanol (I)
2 Butanone (I.T)
2-Butanone, peroxide (R.T)
2-Bulenal
2-Butene, 1.4-dichloro- (I.T)
2-Butenoic acid. 2-methyl-. 7-[|2 3-dihyrtroxy-
2-(1-methoxyethyl)-3-methyl-1-oxobutoxy;methyl]-
2.3,5,7a-tetrahydio-1 H-pyrrolinn-1 -yl es;er,
|lS-|1alpha(Z),7(2S',3R'),7aalpria!l-
n-Butyl alcohol (I)
Cacodylic acid
Caicibm chromate
Carbamic acid, othyl ester
Carbamic acid, methylnitroso-, ethyl estor
Carbamic chloride, dimethyl-
Carbamodrthioic acid, 1,2-ethanediytbis-,
salts & esters
Carbamothioic acid, bts(l-mc-'hyiethyl)-, S-(2,3-di-
chloro-2-propenyl) ester
Carbonic acid, dithailium(l ,) salt
Carbonic difluonde
Carbonochlondic acid, mtthyl ester (I. D
Carbon ox-,1luonde (R.T)
Carbon tet/acnlonde
Chloral
Cnlorambucil
Chlordane, alpha & gamma iscrpets
Chtornaphazin
Chlofobenzene
Chloroben^ilate
p-Chioro-m-cresol
2-Chioroethyl vinyl eitier
Chlorotorm
Chioromethyl methyl ether
bela-Chloronaphthalene
o-Ch^orophenol
4-Chloro-o-toiu'dine, hydrochlor'Oe
Chromic acid H;CrO.. caiciu-n salt
Chryseria
Creosote
Cresol (Cresylic acid)
Cro'tonaWehyde
Cumene (I)
Cyanogen bromide (CN)Br
2,5-Cyc!ohexadiene-1,4-dione
Cyclohexane (I)
Cyclohexane. 1,2 3.4,5 6-hexacMoro-.
(!aipha,2alpha 3beta.4alpha.5alpha.6beu)-
Cyclohexanone (I)
1.3-Cyclopentadiene. 1 2.3.4 5 5-hexachloro-
Cyclophosphamide
2.4-D, salts & esters
Daunomycm
DDD
DDT
Diallate
Dibenzia.hianthraoene
Dibenzo|a,i)pyrene
Haz-
ardous
wnslo
No
U066
U069
U070
U071
U072
U073
U074
U075
U078
U079
U025
(j027
U024
U081
UQ62
U1£4
U065
U1CH
U028
U066
UOS7
U068
U089
UOSO
U091
U092
U093
U094
U095
U096
UOS7
U098
U099
11101
U1C2
U103
U105
U106
U107
U108
U109
U110
U111
U041
I uo:->
i U174
U'b5
UOb?
U076
U077
i UT31
' U024
U117
UQ25
U184
U208
| U209
U2-.8
U226
U227
U359
U173
U004
U043
U042
U078
U079
U210
U228
UH2
U113
U238
U117
U114
U067
U077
U359
U115
Chemical
abstracts No
96-12-8
84-74-2
95-50-1
541-73-1
1 06-46-7
91-94-1
764-41-0
75-71-8
75-35-4
156-60-5
111-44-4
108-60-1
111-91-1
120-83-2
87-65-0
542-75-6
1464-53-5
123-91-1
117-81-7
1615-80-1
3288-58-2
84-66-2
56-53-1
94-58-6
Substance
1 ,2-Ditx omo-3-chloropropane
Dibutyl phtnalate
o-Dichlorobenzene
m-Dichlorobenzene
p-Dichlo'obenzene
3,3'-Dichlorobenzidine
1,4-Dichloro-2-butene (I.T)
Dtchlorodiduoromethane
1,1-Dichloroethylene
1 ,2-Dichloroethylene
Dichloroethyl ether
Dichloro'sopropyl ether
Dichloromethoify ethane
2,4-Dichlo'ophenol
2,6-Dichiorophenol
1,3-Dichloropropene
1,2 3,4-Diepoxybutane (I,T)
1 ,4-Diethyleneoxida
Diethylhexyl phthalate
N,N'-Diethylhydrazine
O,O-Diethyl S-methyl dithiophosphate
Diethyl phthalate
Diethylstilbesterol
Dihydrosafrole
119-90-4 j 3,3'-Dimethoxybenzidine
124-40-3 Dimethylamine (I)
60-11-7 p-Dimethylammoazobenzene
57-97-6 7,12-Dimethyibenz[a;antNacene
119-93-7 3,3'-Dimethylbenzidine
80-15-9
79-44-7
57-14-7
540-73-8
105-67-9
131-11-3
77-78-1
121-14-2
606-20-2
117-E4-0
alpha.alpha-Dimethylbenzylhydroperoxiae (R)
Dimothyicarbamoyl chloride
1 , 1 -Dimethylhydrazine
1 ,2-Dimethylhycirazine
2,4-Dimethylpheno)
Dimethyl phttialate
Dimethyl suifate
2,4-DinrtrotolLiene
2.6-Dmitrotoluene
Di-n-octyl phthalate
123-91-1 | 1,4-Dioxane
122-66-7
142-84-7
1 ,2-Diphenylh/drazine
Dipropylamme (I)
621-64-7 Ci-n-propylnitrosamine
'. 05-S9-8 Epichlorohyd'in
75-07-0
Ethanal (I)
55-18-5 Ethanamme, N-ethyl-N-nitrosc-
S1-EO-5 1 ,2-Ethanediamine, N,N-dimethyl-N'.2-pyndmyl-N'-(2-
; thienylmethyl)-
'05-93-4 Ethane, 1,2-dibromo-
75-34-3 Ethane, 1,1-dichloro-
107-06-2 ' Ethane, 1 ,2-d
: 67-72-1 Ethane, hexachloro-
i 111-91-1 Ethane, l.1'-[methylenebis(oxy):bis!2-cr-.toro-
60-29-7 Ethane, 1,1'-oxybis-(l)
111-44-4 i Etl-,ane, 1,V-oxyt»s!2-chkxo-
76-01-7 Ethane, pentachloro-
: 630-20-6 Ethane, 1,1,1,2-tetrachloro-
79-34-5 Ethane, 1,1,2 2-tetrachloro-
62-55-5 Ethanethioamide
71-55-6 Ethane, 1,1,1-tnchlorc-
79-00-5 Ethane, 1,1,2-tnchloro-
: 110-80-5
! 1116-54-7
' 99-66-2
> 75-01-4
Ethanol. 2-ethoxy-
Ethario), 2,2'-
-------
12-13
Haz-
ardojs
waMe
ND
U116
L'076
U118
U119
U120
U122
U123
U124
U125
ii147
U213
U125
U124
U206
U2C6
U126
U163
\J127
U128
U130
U131
U132
U243
U133
UOB6
U098
U099
U109
U134
U134
U'35
UI35
U096
U'6
U137
U139
U190
U140
U141
LI142
U143
U1'.4
U146
U145
U146
U129
U163
U147
U148
U149
U150
U151
U152
U092
U029
U045
U046
U068
UOSO
U075
U138
U119
U211
U153
U225
U044
U121
U036
U154
U155
U1"2
U247
U154
U029
U166
1 Chemtcal
abstracts No
i
1"
1
P6-45-7
75-34-3
i 97-63-2
62-50-0
20S-44-0
50-OC-O
1 64-18-6
110-00-9
98-01-1
108-31-6
1C9-S9-9
; 98-01-1
110-00-9
18863-66-4
' 18-83-66-4
7E5-34-4
70-25-7
118-74-1
87-68-3
77-47-4
67-72-1
I 70-30-4
188B-71-7
302-01-2
1615-80-1
57-J4-7
540-73-8
122-66-7
7664-39-3
7C64-39-3
7783 -06-4
7~5J-C6- 4
6C-15-S
96-45-7
193-3;, -5
65-44-9
73-63-1
120-58-1
143-50-0
303-34-4
3CM Ot-2
1335-32-6
7446-27-7
1335-32-6
58-89-9
70-25-7
108-31-6
123-33-1
109-77-3
148-82-3
7439-97-6
126-98-7
124^)0-3
74-83-9
74-87-3
107-30-2
74-95-3
75-09-2
75-71-8
74-88-4
62-50-0
56-23-5
74-93-1
75-25-2
67-66-3
75-69-4
57-74-9
67-56-1
91-80-5
143-50-0
72-43-5
67-56-1
74-83-9
504 -60-9
Substance
Eth/lenethiourea
Ethylidene dichlonoe
Ethyl methacrylate
Ethyl methanesuHonate
Fljoranthene
Formaldehyde
Formic acid (C.T)
Furan (1)
, 2-Furancarboxaldehyde (1)
2.5-Furandione
Firan, tetrahydro-(l)
Furfural (1)
Furfuraii (1)
G.ucupyranose. 2-deoxy-2-(3-methyl-3-'iit'os>Ou'eido|
D-
D-G'ucose, 2-deoxy-2-!|(methylnitroscaminc)-
carbonyl)ammo]-
Giyodylaldehyde
Guanidine. N-methyl-fM -ortro-N-nitroso-
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyciopentadiene
He/achloroe thane
Hexschio'ophene
Hexachloropropene
Hydrazine (R.T)
Hydrazine, 1.2-diethyl-
Hydrazme. 1.1-dimethyl-
Hyd-azme. 1,2-dirnethyt-
Hydrazine, 1,2-diphenyt-
Hydrotluonc acid (C,T/
Hydrogen fluonde (C,T)
H,droqen sulf.de
Hyd'oysn SJlMe H,S
HyO'opmoxicie, 1-mcthyl-1-phenyiethy!- 'P.)
2-l"iidazolidmethione
'ncieno[1,2,3-cd)pyrene
[R<. mined by 53 FR43&81. October 3l,i9S&]
1 .3-lsobenzoluranfiKxne
Isobuiyl alcohol (I.T)
Isosalrole
Kepone
Lasiocarpme
Lc.Jd acetate
Lead, bis(acetoto-O)tetrahydroxyln-
Lead phosphate
Lead subacetate
Lirxlane
MNNG
Maleic anhydnde
Maleic hydrazide
Malononitnle
Melphalan
Mercury
Methacrylorwtnle (1, T)
Methanannne, N-methyl- (1)
Methane, br omo-
Methane. chkxo- (1, T)
Methane, chlofomethoxy-
Methano, ditxomo-
Methane, dichloro-
Methane, dtcWorodifluofO-
Methane, KxJo-
Methanesultoruc acxl, ethyl estei
Methane, tet/achlofO-
Methanethiol (1, T)
Methane, tnbromo-
Methane. trichloro-
Methane, tnchkxofluoro-
4,7-Methano-1H-indene, 1.2.4,5.6,7,8,8-octachtoro-
2,3,3a, 4, 7, 7a-hexahyd«'O-
Methanol (I)
M«thapynlene
1 ,3.4-Metheno-2H-cyclobuta|cd(perrtaten-2-one.
1.la,3,3a.4,5,5,5a.5b.6-d«cach»ofooc1any<}no-
Methoxycnkx
Methyl alcohol (1)
Methyl bromide
1-Methytoutadiene (1)
Haz-
ardous
No
U045
U156
U226
U157
U158
U068
U080
U159
U160
U138
U161
U162
U161
U164
U310
UOC9
U167
U168
U026
U165
U047
U166
U236
U166
U167
. U'68
. U217
U169
U170
U171
U172
U173
U174
L'1 76
U177
U178
U179
U180
U181
U193
U058
U115
U126
U041
U182
U183
U184
U185
See
F027
U161
U186
U187
UI68
U048
U039
U081
U082
U089
LM01
(Mf>2
U132
U170
See
F027
See
F027
See
F027
See
F027
U150
U145
UO87
Chemical
(
I
74-87-3
79-22-1
71-55-6
56-49-5
101-14-4
74-95-3
75-09-2
78-93-3
1338-23-4
74-88-4
108-10-1
80-62-6
108-10-1
56-04-2
50-07-7
20830-81-3
134-32-7
91-59-8
494-03-1
91-20-3
91-58-7
130-15-4
72-57-!
130-15-4
134-32-7
91-59-8
10102-45-1
98-95-3
100-02-7
79-46-9
924-16-3
1116-54-7
55-18-5
759-73-9
684-93-5
615-53-2
100-75-4
930-55-2
99-55-8
1120-71-4
50-18-0
75-21-8
765-34-4
1 06-89-8
123-63-7
608-93-5
76-01-7
82-68-8
67-86-5
108-10-1
504-60-9
62-44-2
103-95-2
95-57-8
59-50-7
120-83-2
87-65-0
56-53-1
105-67-9
13<9-77-3
70-30-4
100-02-7
87-86-5
58-90-2
95-95-4
88-06-2
148-82-3
7446-27-7
3268-58-2
fiance
Methyl cnonde (I.T)
Methyl chlorocarbonate (i T)
Methyl chloroform
3-Mettiylcnolanthrene
4,4'-Methylenebis(2-chloroanilir,e)
Methylene bromide
Methylena chloride
Methyl elhyt ketone (MEK) (I.T)
Methyl ethyl ketone pe-'oxide (R T)
Methyl iodide
Methyl isobutyl ketone dj
Methyl methacrylate (I.T)
4-Me:hyi-2-pentanone (t)
Methylthiojracil
Mitomvcn C
5,12-Napnthacenedione. S-a e:/ •( i ' 3'o.no-2.3.6-
tnd^cx-jJ-alpha-L-tyxo-hexODV^^osviyoxv 7 3 9,10-
tetrah)-dro-6,8.11-tnhydrox/-5 -i<.-f..-ic acid. 3 3 -,'3.3 -
dimethyl|1.1 -bipheny1]-4.4'-diyl)bis(azo)bib 5-
ammo-4-hydroxy I-, tetrasodram salt
1 ,4-Naphthoquinon9
alpha-Naphthylamme
beta-Naphthylamine
Nitric acid, ihallmmf! + ) sa't
Nitrobenzene (t.T)
p-Nitrophenol
2-Nitropropane (I.T)
N-Nitrosodi-n-butylamtne
N-Nitrosodiethanolamine
N-NiUosodieth^-lamine
N-Ni'.roso-N-ethyljrea
N-Nitroso-N-methyturea
N-Nrtroso-N-methylurethane
N-Nitrosopipendme
N ^itrosopyrrotidme
5-Nrtro-o-toluidine
1 ,2-Oxathiolane. 2.2-dioxide
2H- 1 ,3,2-Oxazaphosphom-2-arnine,
N,N-bis(2-chloroethyl)tetrahydro-. 2-oxide
Oxirane (l.T)
Oxiranecarboxyakfehyde
Oxirane, (chloromethyl)-
Paraldehyde
Pentachlorobenzene
Pentachloroethane
PentachlofOmtrobenrene (PCNB)
Pentachlorophenol
Pentanol. 4-mettry(-
1,3-Pentadiene (t)
Phenacetin
Phenol
Phenol. 2-chloro-
Phenol. 4-chloro-3-methyl-
Phenol. 2.4-dctikxo-
Phenol, 2,6-dichloro-
Phenol. 4,4 -(l.2-d*ethyl-l.2-ethenediy!)bis-. (El-
Phenol, 2.4-d>me!hy)-
Phenol, methyl-
Phenol, 2,2'-mettiytenebtsJ3,4,6-trich)oro-
Phenol, 4-mtro-
Phenol, pentacnkxo-
Phenol. 2 3,4.6-tetrachtoro-
Phenol. 2.4.5.tnchloro-
Phenol. 2.4,S-tnchlO'o-
L-Phenylalanine. 4-lbts(2-chloroethyt)amino|-
Phospnonc acid. tead<2 + ) salt (2 3)
Phosphorodflhioic acid, O.O-diethyt S-methyl ester
[Sec. 261.33(f)]
-------
12-14
Haz-
ardous
wnste
No
U1S9
U190
U191
U179
U192
U194
U111
U110
U066
U083
U149
U171
U027
U193
See
F027
U235
U140
U002
U007
U084
U243
U009
U152
U008
U113
U118
U162
U194
U083
U148
U196
U191
U237
U164
U180
U200
U201
U202
U203
U204
U204
U20S
U205
U015
See
F027
U206
U103
U189
Chemical
ab-Mncts No
1314-80-3
85-44-9
109-06-8
100-75-4
23950-58-5
107-10-8
621-64-7
142-84-7
96-12-8
78-87-5
109-77-3
79-46-9
108-60-1
1120-71-4
93-72-1
126-72-7
78-83-1
67-64-1
79-06-1
542-75-6
1888-71-7
107-13-1
126-98-7
79-10-7
140-88-5
97-63-2
80-62-6
107-10-8
78-87-5
123-33-1
110-66-1
109-06-8
66-75-1
5S-04-2
930-55-2
50-55-5
108-46-3
'81-07-2
94-59-7
7783-00-8
7783-00-8
7488-56-4
7488-56-4
115-02-6
93-72-1
18863-66-4
77-78-1
1314_fm_3
Substance
Phosphorus sulfide (R)
Phthalic anhydride
2-Picohne
Pipendine, 1-nitroso-
Pronamide
1-Propanamme (I.T)
1 -Propanamine, N-nitroso-N-propyl-
1 -Propanamine, N-propyl- (I)
Propane, 1 ,2-dibromo-3-cWoro-
Propane, 1,2-dichloro-
Propanedinitnle
Propane. 2-nitro- (I.T)
Propane. 2.2'-oxybis|2-chloro-
1,3-Propane sultone
Propanoic acid. 2-(2.4.5-tnchloropheno/y)-
1-Propanol. 2,3-d'bromo-. phosphate (3 1)
1-Propanol, 2-meihyl- (I.T)
2-Propanone (I)
2-Propenamide
1-Propene, 1.3-dichloro-
1-Propene. 1,1, 2.3,3. 3-hexachloro-
2-Propenenitnle
2-Propenenitnle, 2-methyl- (I.T)
2-Propenoic acid (I)
2-Propenoic acid, ethyl ester (1)
2-Propenoic acid, 2-methyl-, ethyl ester
2-Propeno'C acid, 2-methyl-. meihyl ester (I.T)
n-Propylamine (I.T)
Propylene dichloride
3,6-PyndoZinedione, 1,2-d'hydro-
Pyridins
Pyndine, 2-methyl-
2,4-(1 H.3H)-Pynmidinedior.e. 5-|biS(2-
chloroethyl)amino]-
4(1 H)-Pyrimidinone, 2.3-dihydro-6-me!hyl-2-ttwxo-
Pyrrolidine, 1-nitroso-
Reserpine
Resorcmol
Saccharm. & salts
Safrole
Selemous acid
Selenium dioxide
Selenium sulfide
Selenium sulfide SeS; (R.T)
L-Serine, diazoacetate (ester)
SJvex (2,4,5-TP)
Streptozotocin
Sulfunc acid, dimethyl ester
SuMur phosphide (R)
Haz-
ardous
waste
No
See
F027
U207
U208
U209
U210
See
F027
U213
U214
U215
U216
U216
U217
U218
U153
U244
U219
U244
U220
U221
U223
U328
U353
U222
U011
U227
U228
U121
See
F027
See
F027
U234
U182
U235
U236
U237
U176
U177
U043
4J248
1J239
U200
U249
Chemical
abstracts No
93-76-5
95-94-3
630-20-6
79-34-5
127-18-4
58-90-2
109-99-9
563-68-8
6533-73-9
7791-12-0
7791-12-0
10102-45-1
62-55-5
74-93-1
137-26-8
62-56-6
137-26-8
108-68-3
25376-45-8
26471-62-5
95-53-4
106-49-0
636-21-5
61-82-5
79-00-5
79-01-6
75-69-4
95-95-4
88-06-2
99-35-4
123-63-7
126-72-7
72-57-1
66-75-1
759-73-9
684-93-5
75-01-4
'81-81-2
1330-20-7
50-55-5
1314-64-7
Substance
2.4.5-T
1 .2,4.5-Tetrachlorobenzene
1 ,1 .1 .2-Tetrachloroethane
1 . 1 ,2,2-Tetrachloroethane
Tetrachloroethylene
2,3.4,6-TetrachlorophenoI
Tetrahydroluran (1)
Thallium(l) acetate
Thallium(l) carbonate
Thallium(l) chlonde
ThaMium chloride Tlcl
Thallium(l) nitrate
Thioacetamide
Thiomethanol (I.T)
Tr-noperoxydicarbomc diamide |(H::N)C(S)j;S;.
methyl-
Thiourea
Thiram
Toluene
Toluenediamir>e
Toluene diisocyanate (R,T)
o-Toluidine
p-Toluidme
o-Toluidme hydrochionde
1H-1.2.4-Tnazol-3-amine
1 , 1 .2-Tnchloroethane
Tnchloroethylene
Tnchloromonofluoromethane
2.4,5-Trichlorophenol
2.4,6-Trichlorophenol
1,3,5-Tnnrtrobenzene (R,T)
1,3,5-Trioxane. 2,4,6-tnmethyl-
Tris(2,3-*bromopropyl) phosphate
Trypan blue
Uractl mustard
Urea, N-ethyl-N-mtroso-
Urea, N-methyl-N-nrtroso-
Vinyl chtonde
tetra-
Warfarin. & salts, when present at concentrations ot
03% or less
Xylene (I)
Yohimban-16-carboxyhc acid. 11,17-dimethoxy-18-
| (3,4,5-tnmethoxyt>6fizoyl)oxy|-, methyl
(3beta. 1 6beta, 1 7alpha.l 8beta,20alpha)-
ester,
Zinc phosphide ZrijPs, when present at concentra-
tions of 10% or less
1 CAS Number given for parent compound only
(The reporting and recordkeepmg require-
ments contained in this section were ap-
proved by OMB under control number
2050-0047 )
[Added by 50 FR 28742, July 15, 1985]
[Sec. 261.33(1)]
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12-15
APPENDIX 12.3
Definitions of Ignitability,
Corrosivity, and Reactivity
Note: The following pages are taken from 40 CFR Part 261 as of
8/18/88. Since regulations are often changing, please check with
a regulatory agency to see if any changes have been made which
may apply to you.
© 1989
CHMR
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12-16
§ 261.21 Characteristic of Ignrtabflity.
(a) A solid waste exhibits the
characteristic of ignitability if a
representative sample of the waste has
any of the following properties:
(1) It is a liquid, other than an aqueous
solution containing less than 24 percent
alcohol by volume and has flash point
less than 60°C (140°F), as deter-
mined by a Pensky-Martens Closed Cup
Tester, using the test method specified
in ASTM Standard D-93-79 or 15-93-80
(incorporated by reference, see
§260.11), or a Setaflash Closed Cup
Tester, using the test method specified
in ASTM Standard D-3278-78 (incor-
porated by reference, see j260.ll),
or as determined by an equivalent test
method approved by the Administrator
under procedures set torth in §§260.20
and 260.21.
[261.21(ai(D amended by 46 FR 35247.
July 7, 1981]
(2) It is not a liquid and is capable,
under standard temperature and
pressure, of causing fire through friction,
absorption of moisture or spontaneous
chemical changes and, when ignited,
burns so vigorously and persistently that
is creates a hazard.
(3) It is an ignitable compressed gas as
defined in 49 CFR 173.300 and as
determined by the test methods
described in that regulation or
equivalent test methods approved by the
Administrator under §§ 260.20 and
260.21.
(4) It is an oxidizer as defined-in 49
CFR 173.151.
(b) A solid waste that exhibits the
characteristic of ignitability, but is not
listed as a hazardous waste in Subpart
D' has the EPA Hazardous Waste
Number of D001.
§ 261.22 Characteristic of corrosivity.
(a) A solid waste exhibits the
characteristic of corrosivity if a
representative sample of the waste has
either of the following properties:
[261.22(a)(D and (2) amended by 46
FR 35247. July 7, 1981]
(1) It is aqueous and has a pH less
than or equal to 2 or greater than or
equal to 12.5, as determined by a pH
meter using either an EPA test
method or an equivalent test method
approved by the Administrator under
the procedures set forth in §§260.20
and 260.21. The EPA test method for
pH is specified as Method 5.2 in "Test
Methods for the Evaluation of Solid
Waste, Physical/Chemical Methods"
(incorporated by reference, see
§ 260.11).
(2) It is a liquid and corrodes steel
(SAE 1020) at a rate greater than 6.35
mm (0.250 inch) per year at a test tem-
perature of 55°C (130°P) as determined
by the test method specified in NACE
(National Association of Corrosion En-
gineers) Standard TM-01-69 as stand-
ardized in "Test Methods for the Eval-
uation of Solid Waste, Physical/
Chemical Methods" (incorporated by
reference, see §260.11) or an equiva-
lent test method approved by the Ad-
ministrator under the procedures set
forth in §§ 260.20 and 260.21.
(b) A solid waste that exhibits the
characteristic of corrosivity, but is not
listed as a hazardous waste in Subpart
D, has the EPA Hazardous Waste
Number of D002.
§ 261.23 Characteristic of reactivity.
(a) A solid waste exhibits the
characteristic of reactivity if a
representative sample of the waste has
any of the following properties:
(1) It is normally unstable and readily
undergoes violent change without
detonating.
(2) It reacts violently with water.
(3) It forms potentially explosive
mixtures with water.
(4) When mixed with water, it
generates toxic gases, vapors or fumes
in a quantity sufficient to present a
danger to human health or the
environment.
(5) It is a cyanide or sulfide bearing
waste which, when exposed to pH
conditions between 2 and 12.5, can
generate toxic gases, vapors or fumes in
a quantity sufficient to present a danger
to human health or the environment.
(6) It is capable of detonation or
explosive reaction if it is subjected to a
strong initiating source or if heated
under confinement.
(7) It is readily capable of detonation
or explosive decomposition or reaction
at standard temperature and pressure.
(8) It is a forbidden explosive as
defined in 49 CFR 173.51, or a Class A
explosive as defined in 49 CFR 173.53 or
a Class B explosive as defined in 49 CFR
173.88.
(b) A solid waste that exhibits the
characteristic of reactivity, but is not
listed as a hazardous waste in Subpart
D. has the EPA Hazardous Waste
Number of D003.
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12-17
APPENDIX 12.4
Maximum Concentration of Contaminants for
Characteristics of EP Toxicity
Note: The following pages are taken from 40 CFR Part 261 as of
8/18/88. Since regulations are often changing, please check with
a regulatory agency to see if any changes have been made which
may apply to you.
Note: Proposed expansion of toxicity characteristic
On June 12,1986, EPA proposed expanding the toxicity character-
istic to include an additional 38 compounds and to add a new
testing procedure. The table below liststhese proposed additions.
Note that this table also includes the contaminants already regu-
lated in Section 261.24. If you generate one of these wastes check
with EPA or your state agency to see if these regulations have
become final.
© 1989
CHMR
-------
12-18
§261.24 Characteristic of EP Toxlcity.
(a) A solid waste exhibits the
characteristic of EP toxicity if, using the
test methods described in Appendix II
or equivalent methods approved by the
Administrator under the procedures set
forth in §§ 260.20 and 260.21, the extract
from a representative sample of the
waste contains any of the contaminants
listed in Table I at a concentration equal
to or greater than the respective value
given in that Table. Where the waste
contains less than 0.5 percent filterable
solids, the waste itself, after filtering, is
considered to be the extract for the
purposes of this section.
(b) A solid waste that exhibits the
characteristic of EP toxicity, but is not
listed as a hazardous waste in Subpart
D, has the EPA Hazardous Waste
Number specified in Table I which
corresponds to the toxic contaminant
causing it to be hazardous.
Table I.— Maximum Concentration of
Contaminant* for Characteristic of EP Toxicity
EPA Maximum
hazardous Contaminant concentration
waste (milligrams
number per liter)
D004
0005
D006
0007 .
D008
D009
0010.
0011
D012 .
0013 ....
D014 . .
0015 ..
0016 .
0017 . ...
Arsenic . . .
Banum .. .
Cadmium . .
Chromium
. Lead
. Mercury
.. .. Selenium
. . Sliver . . _
. Endnn (1.2.3.4, 10.10-
hexachkxo- 1 . 7-epoxy-
1,4,4a,5,6.7,8.8a-
octahydro- 1 ,4-endo, endo-
5.8-dimethano naphthalene
.. . Lmdana (1.2.3.4.5.6-
hexacnlorocyclohexane,
gamma isomer
. . Methoxycrtlor (1,1.1-
Tnchkxo-2.2-6is tp-
methcxyphenyllethane)
. Toxapnene (C,.H,.CI..
Technical cMonnated
campnene, 67-69 percent
chlonne)
2.4-0, (2.4-
Dtchkxopneooiyacetic
acid)
. . 2.4.5-TP Sirvex (2.4.5-
Trichlorophenoxypropionic
acrt)
50
100.0
10
50
5.0
02
1 0
50
002
0.4
100
05
100
1.0
NOTE: Proposed Expansion of Toxicity
Characteristic
On June 12, 1986, EPA proposed ex-
panding the toxicity characteristic to
include an additional 38 compounds and to
add a new testing procedure. The table
below lists these PROPOSED additions.
Note that this table also includes the
contaminants already regulated in Section
261.24. If you generate one of these
wastes check with EPA or your state
agency to see if these regulations have
become final.
Proposed Toxicity Characteristic
Contaminants and Regulatory Levels
TABLE 1: PROPOSED TOXICITY CHARACTERIS-
TIC CONTAMINANTS AND REGULATORY LEV-
ELS
/
HWNO \
/
0018
O004 . ..
O005 _ . -
0018
D020
0006
0021 ._
D022
0023
D024
D025
0007
0026
0027
D028 ..
0016
D029
D030
D031
O032 —
0033
D012
D034
O035 ._ _
D036
D037 —
0038
D008
0013
0009
DOM
0039
DO40
004 1 _.. .
D042
0043
0044
D010
D01 1
D045 . .
0046
O047
D048
D049 .. . .
D015
0050
0051
0052
D053
0054
D017
0055 . .. .
Contamnanu (
AcfykxntnM
Bistf-cttorcMthyl)
ether
Cadmum
Carbon cksufide
Cruoioane
Chiorooenzene _..
O-CreSOi
m-Qetol _
p-Qetol _
2.4-D
1 ,2-Dich*orot>en2ene
1 ,4-DtchJorooenzene
1 2-Otchkxoelhane
1.1-OichlOfoetnytene.
2.4-Omwololuene ..
Hepiachkx (and us
hydroxidel
HexacNorooenzene
Hexachkxoouta-
diene
HexacMoroetrtana ...
taobutanot „.
Lead ... . _
Methoxychtor
Methyiene chloride....
Methyl ethyl kelone
Nitrobenzene
Peniachlorophenol ...
Phenol
Pyncfcne
Sft*emifn .
Silver _
1112-
Tetracnkxoetnane.
1.1.2.2-
TetracNoroetnane.
Te&achtoroetrtylene .
2.3.4,6-
Teuacniorophenol.
Toluene
Toxaphen*.- _.
1.1.1-
Tnchloroethane
1.1.2-
Tncnkxoelhane.
TncnioroeUiylene
2.4 5-
Tricnkxopfwnol
. 2.4.6-
Tnchloropnenol
. 2.4.5-TP (Sitvex) ... .
Vinyl chloride
CASNO
107-13-1
7*40-38-2
7440-39-3
71-43-2
111-44-4
7440-43-8
75-15-0
56-23-5
S7-74-9
108-90-7
67-66-3
1333-82-0
95-48-7
1 08-39-4
106-44-5
94-75-7
95-5O-1
106-46-7
107-O6-2
75-35-«
121-14-2
72-20-*
76-44-2
11B-74-1
87-68-3
67-72-1
76-83-1
7439-92-1
58-69-8
7439-97-6
72-43-5
75-04-2
78-93-3
98-96-3
87-66-5
108-95-2
110-86-1
7782-49-2
744O-22-4
630-20-6
79-34-5
127-18-4
56-90-2
108-88-3
8001-35-2
71-55-6
78-00-5
79-01-6
95-95-4
88-06-2
93-76-5
75-01-4
Regula-
tory
leva*
(mo/l)
50
50
00
007
005
10
144
007
003
1 4
007
50
100
100
100
1 4
43
108
040
01
013
0003
0001
013
072
43
36
50
006
02
\ 4
86
72
013
36
144
50
1 0
b.O
100
1.3
0.1
1.5
144
007
30
1.2
007
5.8
030
0 14
005
Source: 51 FR 21652 (June 13, 1986).
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12-19
APPENDIX 12.5
EPA Hazardous Waste Numbers for Waste Streams
Commonly Generated by Small
Quantity Generators
• 1989
CHMR
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12-20
EPA HAZARDOUS WASTE NUMBERS FOR WASTE STREAMS
COMMONLY GENERATED BY SMALL QUANTITY GENERATORS
The industries and waste streams described
here do not provide a comprehensive list, but
rather serve as a guide to potential small quantity
generators in determining which of their wastes, if
any, are hazardous. Except for the pesticide and
wood preserving categories, this Appendix does
not include EPA Hazardous Waste Numbers for
commercial chemical products that are hazardous
when discarded unused. These chemicals and their
EPA Hazardous Waste Numbers are listed in Title
40 of the Code of Federal Regulations (40 CFR) in
Section 261.33.
Solvents:
Solvents, spent solvents, solvent mixtures, or
solvent still bottoms are often hazardous. This
includes solvents used in degreasing (identified as
F001) and paint brush cleaning and distillation
residues from reclamation. The following are some
commonly used hazardous solvents (also see ignit-
able wastes for other hazardous solvents, and 40
CFR 261.31 for most listed hazardous waste
solvents):
Benzene
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Cresols
Cresylic Acid
O-Dichlorobenzene
Ethanol
2-Ethoxyethanol
Ethylene Dichloride
Isobutanol
Isopropanol
Kerosene
Methyl Ethyl Ketone
Methylene Chloride
Naphtha
Nitrobenzene
2-Nitropropane
Petroleum Solvents
(Flashpoint less than 140°F)
Pyridine
1,1.1-Trichloroethane
1,1,2-Trichloroethane
F005
F005
F001
F002
F004
F004
F002
D001
F005
D001
F005
D001
D001
F005
F001
F002
D001
F004
F005
D001
F005
F001
F002
F002
Tetrachloroethylene
(Perchloroethylene)
Toluene
Trichloroethylene
Trichlorofluoromethane
Trichlorotrifluoroethane
(Valclene)
White Spirits
F001
F002
F005
F001
F002
F002
F002
D001
Acids/Bases:
Acids, bases, or mixtures having a pH less
than or equal to 2 or greater than or equal to 12.5.
are considered corrosive (for a complete descrip-
tion of corrosive wastes, see 40 CFR 261.22,
Characteristic of corrosivity). All corrosive
materials and solutions have the EPA Hazardous
Waste Number D002. The following are some of
the more commonly used corrosives:
Acetic Acid
Ammonium Hydroxide
Chromic Acid
Hydrobromic Acid
Hydrochloric Acid
Hydrofluoric Acid
Nitric Acid
Oleum
Perchloric Acid
Phosphoric Acid
Potassium Hydroxide
Sodium Hydroxide
Sulfuric Acid
Dry Cleaning
Filtration Residues:
Cooked powder residue (perchloroethylene
plants only), still residues, and spent cartridge fil-
ters containing perchloroethylene or valclene are
hazardous and have the EPA Hazardous Waste
Number F002.
Still residues containing petroleum solvents
with a flashpoint less than 140 F are considered
hazardous and have the EPA Hazardous Waste
Number D001.
Heavy Metals/Inorganics:
Heavy metals and other inorganic waste
materials exhibit the characteristic of EP Toxicity
and are considered hazardous if the extract from a
representative sample of the waste has any of the
specific constituent concentrations as shown in 40
* SOURCE: U.S. EPA Understanding the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small Business
-------
12-21
CFR261.24, Table 1. This may include dusts, solu-
tions, wastewater treatment sludges, paint wastes,
waste inks, and other such materials which contain
heavy metals/inorganics (note that wastewater
treatment sludges from electroplating operations
are identified as F006). The following are EP
Toxic:
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
D004
D005
D006
D007
D008
D009
D010
D011
Ignitable Wastes:
Ignitable wastes include any liquids that have
a flashpoint less than 140°F. any non-liquids that
are capable of causing a fire through friction,
absorption of moisture, or spontaneous chemical
change, or any ignitable compressed gas as de-
scribed in 49 CFR 173.300 (for a complete
description of ignitable wastes, see 40 CFR 261.21,
Characteristic of ignitability). Examples are spent
solvents (see also solvents), solvent still bottoms,
ignitable paint wastes (paint removers, brush
cleaners and stripping agents), epoxy resins and
adhesives (epoxies. rubber cements and marine
glues), and waste inks containing flammable sol-
vents. Unless otherwise specified, all ignitable
wastes have the EPA Hazardous Waste Number of
D001.
Some commonly used ignitable compounds
are:
Acetone F003
Benzene F005
n-Butyl Alcohol F003
Chlorobenzene F0021
Cyclohexanone F003
Ethyl Acetate F003
Ethylbenzene F003
Ethyl Ether F003
Ethylene Dichloride D001
'Chlorobenzene is listed by EPA as a hazardous waste due to
its toxicity and has been assigned EPA Hazardous Waste
Number F002. It has a flashpoint, however, of less than 140°F
and is therefore included here as an ignitable waste.
Methanol F003
Methyl Isobutyl Ketone F003
Petroleum Distillates D001
Xylene F003
Ink Sludges Containing
Chromium and Lead:
This includes solvent washes and sludges,
caustic washes and sludges, or water washes and
sludges from cleaning tubs and equipment used in
the formulation of ink from pigments, driers,
soaps, and stabilizers containing chromium and
lead. All ink sludges have the EPA Hazardous
Waste Number K086.
Lead-Add Batteries:
Used lead-acid batteries should be reported
on the notification form only if they are not re-
cycled. Used lead-acid batteries that are recycled
do not need to be counted in determining the
quantity of waste that you generate per month, nor
do they require a hazardous waste manifest when
shipped off your premises. (Note: Special require-
ments do apply if you recycle your batteries on
your own premises—see 40 CFR Part 266.)
Lead Dross D008
Spent Acids D002
Lead-Acid Batteries D008
Pesticides:
The pesticides listed below are hazardous.
Wastes marked with an asterisk (*) have been des-
ignated acutely hazardous. For a more complete
listing, see 40 CFR 261.32 and 261.33 for specific
listed pesticides, and other wastes, wastewaters,
sludges, and by-products from pesticide for-
mulators. (Note that while many of these
pesticides are no longer in common use, they are
included here for those cases where they may be
found in storage.)
*Aldicarb
*Aldrin
Amitrole
* Arsenic Pentoxide
* Arsenic Trioxide
Cacodylic Acid
Carbamic Acid, Methylnitroso-,
Ethyl Ester
Chlordane
P070
P004
U011
P011
P012
U136
U178
U036
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12-22
Pesticides (Continued):
* Copper Cyanides
1,2-Dibromo-3-chloropropane
1,2-Dichloropropane
1,3-Dichloropropene
2,4-Dichiorophenoxy Acetic Acid
DDT
*Dieldrin
Dimethylcarbamoyl Chloride
* Dinitrocresol
*Dinoseb
Disodium Monomethanearsenate
*Disulfoton
*Endosulfan
*Endrin
Ethylmercuric Chloride
* Famphur
*Heptachlor
Hexachlorobenzene
Kepone
Lindane
2-Methoxy Mercuric Chloride
Methoxychlor
* Methyl Parathion
Monosodium Methanearsenate
* Nicotine
* Parathion
Pentachloronitrobenzene
Pentachlorophenol
Phenylmercuric Acetate
*Phorate
* Strychnine
2,4,5-Trichlorophenoxy
Acetic Acid
2-(2,4,5-Trichlorophenoxy)-
Propionic Acid
* Thallium Sulfate
Thiram
*Toxaphene
Warfarin
P029
U066
U083
U084
U240
U061
P037
U097
P047
P020
D004
P039
P050
P051
D009
P097
P059
U127
U142
U129
D009
D014
P071
D004
P075
P089
U185
U242
D009
P094
P108
U232
U233
P115
U244
P123
U248
CFR 261.23, Characteristic of reactivity). Unless
otherwise specified, all reactive wastes have the
EPA Hazardous Waste Number D003. The follow-
ing materials are commonly considered to be
reactive:
Acetyl Chloride
Chromic Acid
Cyanides
Hypochlorites
Organic Peroxides
Perchlorates
Permanganates
Sulfides
Spent Plating and
Cyanide Wastes:
Spent plating v, astes contain cleaning solu-
tions and plating solutions with caustics, solvents,
heavy metals, and cyanides. Cyanide wastes may
also be generated from heat treatment operations,
pigment production, and manufacturing of anti-
caking agents. Plating wastes are generally
Hazardous Waste Numbers F006-F009, with F007-
F009 containing cyanide. Cyanide heat treating
wastes are generally Hazardous Waste Numbers
F010-F012. See 40 CFR 261.32 for a more com-
plete description of plating wastes.
Wood Preserving Agents:
The wastewater treatment sludges from
wastewater treatment operations are considered
hazardous (EPA Hazardous Waste Number
K001—bottom sediment sludges from the treat-
ment of wastewater processes that use creosote
and pentachlorophenol). In addition, unless other-
wise indicated, specific wood preserving
compounds are:
Chromated Copper Arsenate
Creosote
Pentachlorophenol
D004
U051
F027
Reactives:
Reactive wastes include reactive materials or
mixtures which are unstable, react violently with
or form explosive mixtures with water, generate
toxic gases or vapors when mixed with water (or
when exposed to pH conditions between 2 and
12.5 in the case of cyanide or sulfide bearing
wastes), or are capable of detonation or explosive
reaction when heated or subjected to shock (for a
complete description of reactive wastes, see 40
-------
12-23
APPENDIX 12.6
Counting Your Hazardous Waste
©1989
CHMR
-------
•\2-24
Do Count
Don't Count
You do count all quantities of
"Listed" and "Characteristic"
hazardous wastes as defined on
page 2 that you:
^ Accumulate on-site for
any period of time
prior to subsequent
management.
^ Package and transport
off-site.
^- Place directly in a regulated
on-site treatment or dis-
posal unit.
^- Generate as still bottoms or
sludges and remove from
product storage tanks.
You do not have to count wastes that:
^ Are specifically exempted from counting. Examples of these
exempted wastes are:
• spent lead-acid batteries that will be sent off-site for
reclamation.
• used oil that has not been mixed with hazardous waste.
^- May be left in the bottom of containers that have been com-
pletely emptied through conventional means, for example, by
pouring or pumping. Containers that held an acute hazardous
waste must be more thoroughly cleaned.
^ Are left as residue in the bottom of product storage tanks, if the
residue is not removed from the product tank.
^- You reclaim continuously on-site without storing the waste
prior to reclamation, such as dry cleaning solvents. (You do
have to count any residue removed from the machine as well as
spent cartridge filters.)
^- You manage in an elementary neutralization unit, a totally
enclosed treatment unit, or a wastewater treatment unit. An
elementary neutralization unit is a regulated tank, container, or
transport vehicle (including ships) which is designed to contain
and neutralize corrosive wastes.
^ Are discharged directly to a publicly-owned treatment works
(POTW) without being stored or accumulated first. This dis-
charge to a POTW must comply with the Clean Water Act.
POTWs are public utilities, usually owned by the city, county,
or state, that treat industrial and domestic sewage for disposal.
^- You have already counted once during the calendar month, and
treated on-site or reclaimed in some manner, and used again.
* SOURCE: U.S. EPA Understanding the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small
Business.Sept. 1986
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APPENDIX 12.7
Counting Your Hazardous Waste
in Pennsylvania
> 1989
CHMR
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Do Count
Don't Count
You do count all quantities of
"Listed" and "Characteristic" haz-
ardous wastes as defined on page 2
that you:
- accumulate on-site for any per-
iod of time prior to subsequent
management.
- package and transport off-site.
- place directly in a regulated
on-site treatment or disposal
unit.
- generate as still bottoms or
sludges and remove from product
storage tanks.
- manage in an elementary neu-
tralization unit, a totally en-
closed treatment unit, or a
wastewater treatment unit. An
elementary neutralization unit
is a regulated tank, container,
or transport vehicle (including
ships) which is designed to
contain and neutralize corro-
sive wastes.
- discharge directly to a public-
ly-owned treatment works (POTW)
without being stored or accumu-
lated first. This discharge to
a POTW must comply with the
Clean Water Act. POTWs are pub-
lic utilities, usually owned by
the city, county, or state,
that treat industrial and do-
mestic sewage for disposal.
You do not have to count wastes
that:
- are specifically exempted from
counting. Examples of these
exempted wastes are:
• spent lead-acid batteries
that will be sent off-site
for reclamation.
• used oil that has not been
mixed with hazardous waste.
- may be left in the bottom of
containers that have been com-
pletely emptied through conven-
tional means, for example, by
pouring or pumping. Containers
that held an acute hazardous
waste must be more thoroughly
cleaned.
- are left as residue in the bot-
tom of product storage tanks,
if the residue is not removed
from the product tank.
- you reclaim continuously onsite
without storing the waste prior
to reclamation, such as dry
cleaning solvents. (You do
have to count any residue re-
moved from the machine as well
as spent cartridge filters.)
- you have already counted once
during the calendar month, and
treated on-site or reclaimed in
some manner, and used again.
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