&EPA
                        United States
                        Environmental Protection
                        Agency
                        Research and Development
                                   Risk Reduction
                                   Engineering Laboratory
                                   Cincinnati, OH 45268
                                   EPA/600/S-92/040  Oct. 1992
ENVIRONMENTAL
RESEARCH  BRIEF
                     Waste Reduction Activities and Options for a
                 Manufacturer of Paints Primariiy for Metai Finishing

                                 Patrick Eyraud and Daniel J. Watts*
Abstract
The U.S. Environmental Protection Agency (EPA) funded a
project with the New Jersey Department of Environmental
Protection and Energy (NJDEPE) to assist in conducting waste
minimization assessments at 30 small- to medium-sized busi-
nesses in the state of New Jersey. One of the sites selected
was a facility that produces paints primarily intended for metal
finishing. A site visit was made in 1990 during which several
opportunities for waste  minimization  were identified. These
opportunities include improved solvent  handling techniques,
reuse of some solvent washing wastes, and changes in equip-
ment washing techniques. Implementation of the identified waste
minimization opportunities was not part of the program. Percent
waste reduction, net annual savings, implementation costs and
payback periods were estimated.

This Research Brief was developed by the Principal Investiga-
tors and EPA's Risk Reduction Engineering Laboratory in Cin-
cinnati,  OH, to announce key findings of this completed as-
sessment.

Introduction
The environmental issues facing industry today have expanded
considerably beyond traditional  concerns. Wastewater, air
emissions, potential soil and groundwater contamination, solid
waste disposal, and employee health and safety have become
increasingly important concerns.  The  management and dis-
posal of hazardous substances, including both process-related
wastes and residues from waste treatment, receive significant
attention because of regulation and economics.
 * New Jersey Institute of Technology, Newark, NJ 07102
                        As environmental issues have become more complex, the
                        strategies for waste management and control have become
                        more systematic and integrated. The positive role of waste
                        minimization and pollution preventbn within industrial operations
                        at each stage of product life is recognized throughout the
                        world. An ideal goal is to manufacture products while generat-
                        ing the least amount of waste possible.

                        The Hazardous Waste Advisement  Program (HWAP) of the
                        Division of Hazardous Waste Management, NJDEPE, is pursu-
                        ing the  goals of waste minimization awareness and program
                        implementation in the state. HWAP, with the help of an EPA
                        grant from the Risk Reduction Engineering Laboratory, con-
                        ducted an Assessment of Reduction  and Recycling Opportuni-
                        ties for Hazardous Waste (ARROW) project. ARROW was
                        designed to  assess waste minimization potential across a
                        broad range of New Jersey industries. The project targeted 30
                        sites to perform waste minimization assessments following the
                        approach outlined in EPA's  Waste Minimization Opportunity
                        Assessment Manual (EPA/625/7-88/003).  Under contract to
                        NJDEPE, the Hazardous Substance Management Research
                        Center at the New Jersey Institute of Technology (NJIT) assisted
                        in conducting the assessments. This research brief presents
                        an assessment of a manufacturer of paints primarily for metal
                        finishing (1  of the 30 assessments  performed), and provides
                        recommendations for waste minimization options resulting from
                        the assessment.


                         Methodology of Assessments
                        The assessment process was coordinated by a team of techni-
                        cal staff from NJIT with experience in process operations,
                         basic chemistry, and environmental  concerns and needs. Be-
                        cause the EPA waste minimization  manual is designed to be
                         primarily applied by the inhouse staff of the facility, the degree

                                                $& Printed on Recycled Paper

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 of involvement of the NJIT team varied according to the ease
 with which the facility staff could apply the manual. In  some
 cases,  NJITs  role was to provide advice.  In  others, NJIT
 conducted essentially the entire evaluation.

 The goal of the project was to encourage participation  in  the
 assessment process by management and staff at the facility.
 To do this, the participants were encouraged to proceed through
 the organizational steps outlined in the manual. These steps
 can be summarized as follows:

   • Obtaining corporate commitment to a waste minimization
    initiative
   • Organizing a task force or similar group to  carry out  the
    assessment
   • Developing a policy statement regarding waste minimiza-
    tion for issuance by corporate management
   • Establishing tentative waste reduction goals to be achieved
    by the program
   • Identifying waste-generating sites and processes
   • Conducting a detailed site inspection
   • Developing a list of options  which  may lead to the waste
    reduction goal
   • Formally analyzing the feasibility of the various options
   • Measuring the effectiveness of the options and continuing
    the assessment.

 Not every facility was able to follow these  steps as presented.
 In each  case, however, the identification of waste-generating
 sites and processes, detailed site inspections, and development
 of options was carried out. Frequently, it was necessary for a
 high degree of involvement by NJIT to accomplish these steps.
 Two common reasons for needing outside participation were a
 shortage of technical  staff within the company and a need to
 develop  an agenda for technical action before corporate com-
 mitment  and policy statements could  be obtained.

 It was not a goal of the ARROW project to participate in  the
 feasibility analysis or  implementation  steps. However, NJIT
 offered to provide advice for feasibility analysis if requested.

 In each  case, the NJIT team  made  several site visits  to  the
 facility. Initially, visits  were made to  explain the EPA manual
 and to encourage the facility through the organizational stages.
 If delays and complications developed, the team offered assis-
 tance in  the technical review, inspections, and option develop-
 ment.


 The Paint Manufacturer
 The facility is a producer of paints, used primarily in the  metal
 finishing  industry including automobile refinishing applications.
 This business requires production of a large variety of colors
 and finish types, most in relatively small quantities. The specifi-
 cations of their customers allow a very narrow range of variation
 in color and appearance of the finished product. This severely
 limits the flexibility the company has in changing production
 processes.

 The production of the  various  types  of paints  is conceptually
 very simple. Required operations include mixing and blending
 (under carefully specified conditions) raw materials either pur-
 chased from vendors or shipped from other company sites.  No
 manufacturing of paint constituents takes place at this facility.
After formulation and blending, the paints are transferred to a
variety of containers for shipment to the customer. The pro-
cessing equipment is  cleaned prior to preparation of the next
batch. The cleaning operation typically includes multiple rinses
with solvent  in order to remove  the pigments and additives
remaining from the previous batch.

Paint production uses a solvent or liquid carrier to dissolve or
suspend the  components of the coating system.  This process
is a large user of solvents.  At present,  the preponderance of
the solvents  used in these applications are organic. However,
there is  a trend In  the  coatings industry toward water-based
products where customer demands and product performance
criteria are met. The technology for water-based  coatings has
not been sufficiently advanced to address all such demands
and performance requirements. Therefore, solvent-based paints
and coatings will be required for some time.

The company  has  already  instituted  a program of  pollution
prevention. This is perhaps  best  illustrated by the acquisition
and use of a large  capacity still which allows recovery and
reuse of the  solvents from the equipment washing operations.
Other  pollution prevention  efforts have been carried  out  in
conjunction with the corporate research and development group.
This lead to  the reduction or elimination of the use of heavy
metal-containing dyes and pigments in products  produced by
this facility.


Waste  Streams and Existing Waste
Management
This particular facility presents a challenge in describing waste
streams. The presence  of an operating  solvent recovery sys-
tem means  that the actual waste streams  sent  offsite are
relatively insignificant in terms of the total effluent from the
process  before the  solvent  distillation. Moreover, where there
is a significant level of air  emissions  to  be addressed, the
meaning of the term "treatment and disposal costs" has to be
strained to  include simple loss of the value of materials.

The major  RCRA waste from this facility  is the still bottoms
from the recovery/recycling/reuse of waste solvents from the
equipment washing  process. About 250 drums of this material
are produced annually from the facility and are sent offsite for
disposal. This quantity represents 10% to 20 % of the volume
of waste solvents which were sent for disposal  prior to the
installation of the distillation equipment.

Another waste  stream results from  quality control samples  of
finished batches which are retained at the facility for a period of
time for examination if customer problems or complaints come
in about specific batches of paint. After the retention period,
the samples are discarded as hazardous waste. Approximately
one quart size samples are  collected and retained. The typical
current practice is to recover the solvent from these retained
samples through the solvent recovery system. There was no
information available on the number of these samples gener-
ated and retained each year.

Another waste  stream identified was a waste oil stream from
equipment maintenance and repair. This stream averages 3 to
4 drums  per year and is sent offsite for recycling and recovery.

The greatest  pollution prevention challenge at this facility is not
RCRA-type waste streams.  Rather  it consists of stack emis-
sions and fugitive air emissions.  SARA  Title III reporting and
additional estimates indicated that approximately 200,000 Ib of
solvent are emitted to the  atmosphere  annually. The facility
intends to address this  situation  using  a pollution prevention
approach.

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 Summary of Waste Minimization Opportunities
 The  type of waste  currently generated by the  facility, the
 source of the waste, the quantity of the waste and the annual
 treatment and disposal costs are given in Table 1.

 Table 2 shows the opportunities for waste minimization recom-
 mended  for the facility. The type of  waste,  the minimization
 opportunity, the possible waste reduction, the net  annual sav-
 ings,  and the  implementation  cost  along with the  payback
 times are given in the table.  The quantities of waste currently
 generated  at the facility and the possible  waste  reduction
 depend on  the level of activity of the facility. All values should
 be considered in that context.

 It should be noted that the economic savings of the minimiza-
 tion opportunities in most cases result from the need for less
 raw material  and from  reduced costs associated  with  waste
 treatment and disposal. It should also be noted that the savings
 given for each opportunity reflect the savings  achievable when
 implementing each waste minimization  opportunity  indepen-
 dently, and do  not reflect duplication of savings  that  would
 result when the opportunities are implemented in  a  package.
 Also,  no equipment depreciation  is factored  into the calcula-
 tions.

 The decision to  add solvent distillation capabilities at the facility
 significantly reduced the volume of waste shipped from the site
 for treatment. It  did, however, engender a new waste stream at
 the site. These still bottoms present a particular challenge from
 a waste  reduction perspective: to minimize  the still  bottoms
 stream. Some possible options include: identification of benefi-
                                          cial uses for the still bottoms; recovery of valuable  materials
                                          from the bottoms; and change in operating practices to reduce
                                          the quantity and type of materials which  appear in the still
                                          bottoms.

                                          In the absence of specific information about the content of the
                                          still bottoms (which would be variable at best), it is not possible
                                          to suggest specific options regarding  beneficial uses for this
                                          material. Similarly, it is not possible to discuss specific options
                                          for recovery of valuable materials from  the  bottoms. These
                                          questions can  be effectively  addressed after data about the
                                          composition of the still bottoms is collected.

                                          In general, it is assumed that the materials in the still bottoms
                                          consist of residues which are contained in the solvents as they
                                          enter the facility, product residues from equipment rinsing and
                                          cleaning, and manufacturing residues from disposal of products
                                          or raw materials. Modification of  equipment rinsing and clean-
                                          ing practices to reduce the amount of solids in  the rinses would
                                          result in a decrease in the quantity of solids in  the still bottoms.

                                          One approach  which may accomplish some  of this  objective
                                          would  be to segregate  washings  from equipment  used for
                                          transfer of raw materials  from washings of equipment used for
                                          finished  batches. These washings would then  be distilled
                                          separately. Such segregation and  distillation  of raw material
                                          solutions should result in concentrated solutions of the raw
                                          materials which  could be used in production,  rather than as a
                                          component of still bottoms for disposal.

                                          The majority of the still bottoms result from washing of equip-
                                          ment from the finished batches of coatings. The best opportu-
 Table 1.  Summary of Current Waste Generation


 Waste Generated      Source of Waste

 Still Bottoms          Residue from solvent recovery
                      and recycling

 Waste Oil            Obtained from equipment maintenance
                      and repair

 VOC Emissions        Fugitive and stack emissions
                      of solvents used throughout
                      the facility
                                   Annual Quantity
                                      Generated
                                     250 drums
                                       4 drums
                                     200,000 Ib
                            Annual Waste
                          Management Costs
                                                               $65,000
                                                                 $130
                              $40,000
                       (This cost represents
                       the estimated value of
                       the solvents lost to the
                          atmosphere.)
 Table 2.  Summary of Waste Minimization Opportunities
 Waste Stream
 Reduced
Minimization Opportunity
Still Bottoms           Segregation and recovery of
                     concentrates from washings
                     of raw materials for reuse.

                     Reprocessing of retained samples

VOC Emissions        Develop and institute program of
                     leak detection and correction.
                     Reevaluate manufacturing processes
                     in light of pollution prevention
                     goal.
Annual Waste Reduction         Net       Implementation      Payback
Quantity        Percent   Annual Savings      Cost          Years*
                                 5 drums



                                 1 drum

                                 180,000 Ib
               2%



               0.5%

               90%
 $3,100



   $325

$36,000
  $1,000



      $0

$150,000
                                                (It should be recognized that a program
                                                such as tiiis is a multi-year effort
                                                so the total cost will not be incurred in
                                                any single year.)
0.3



immed

4.2
* Savings result from reduced raw material, and treatment and disposal costs when implementing each minimization opportunity independently.
                                                                     •&U.S. GOVERNMENT PRINTING OFFICE: 1994 - 550-067/80152

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nity for reduction of this component lies in scheduling of batches
in terms of colors and coating types. If appropriately sched-
uled, less rinsing may be required, particularly in moving from
lighter  colors to darker colors. On the other hand, it must be
recognized that this facility  has very tight specifications for
color reproducibility because many of their customers do color
matching. From a total pollution prevention perspective,  it may
be preferred to thoroughly rinse the equipment and collect the
resulting still bottoms rather than risk the  potential disposal of
an entire batch of paint.

For impact on emission reduction, attention should be  given to
the  sources  of the emissions and on the  potential options for
emission reduction. As indicated previously, more than 200,000
Ib of SARA 313  emissions  are reported annually from this
facility.  Approximately 70%  of this total amount represents
fugitive air emissions. The material emitted  in largest  quantity
is acetone, representing  about 50% of the fugitive air emis-
sions and about 48% of the total  emissions from the facility.

Before developing a slate of options for addressing this chal-
lenge,  the company examined the question  of how such large
losses  could have been accepted for so many years. All of the
manufacturing operations met the company standards for ma-
terial  use, therefore there was  no  reason to question the
quantity of materials purchased and the quantity which actually
went into the product.

Upon further questioning  about how the company manufactur-
ing  standards were determined, it was concluded that when the
product was first manufactured, careful records were kept and
maintained for the first three or  four batches.  These records
included information about materials used. Then with the addi-
tion of a slight  margin for error,  these quantities became the
manufacturing standard. This means that whatever procedures
were used in the past which may contribute, in this case, to
elevated levels of fugitive emissions are perpetuated  unless
new questions are raised by an "outside" process such as this
one.

The list of volatile  chemicals which  make  up the fugitive air
emissions consists of the solvents which are  used  in the
manufacture of the  coating products at the facility. In addition,
acetone is used  as a solvent for equipment  cleaning. This
provides two different avenues  to  be  explored  for pollution
prevention options. The  solvent  used in  direct production is
essentially fixed in terms of how much solvent must be in the
product shipped to the customers, therefore any reduction in
emissions from this  part of the operation must  result from
changes in losses from spills and leaks, incomplete transfers,
and evaporation.

Because much of the material flow in the facility is a mecha-
nized movement from large  storage tanks to production ves-
sels, there are opportunities for leaks at seals and connections.
A  high  priority option could be to  check the entire solvent
supply system for leaks. Based  upon experiences at other
facilities, particular attention  should  be given to seals and to
pumps. Regular inspection for  such  leaks should be a part of
the program.

There are also opportunities for evaporative losses when the
production vessels are being filled and operated. Certainly, air
displacement is necessary in the tanks to  allow proper filling.
The  ability to cap the  tanks  and use  of  a vapor recovery
system with a condenser could have a significant impact upon
evaporative losses. Depending  upon the quality of such con-
densate, it could be returned directly to the production vessel
resulting in an immediate reduction in total material used for
each batch. Alternatively, the recovered solvent could be sent
to  the distillation process for  purification prior to reuse.

Evaporative losses can also  occur during the filling operations
for the  containers which go to the consumers.  A contained
process for this filling operation to allow for solvent recovery by
condensation could be investigated. Alternatively, revised filling
procedures with smaller container openings to reduce evapo-
rative surfaces would reduce fugitive air emissions from this
source. Process engineering  and design efforts will be required
in  order to address these options.

This Research Brief summarizes a part of the work done under
cooperative Agreement No.  CR-815165 by the New Jersey
Institute  of Technology under  the  sponsorship of the New
Jersey  Department of Environmental Protection and  Energy
and the U.S. Environmental Protection Agency. The EPA Project
Officer was Mary  Ann Curran. She can be reached at:

         Pollution Prevention Research Branch
         Risk Reduction Engineering  Laboratory
         U.S. Environmental  Protection Agency
         Cincinnati, OH 45268
   United States
   Environmental Protection Agency
   Center for Environmental Research Information
   Cincinnati, OH 45268

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