SEPA
                         United States
                         Environmental Protection
                         Agency
                         Research and Development
                                   Risk Reduction
                                   Engineering Laboratory
                                   Cincinnati, OH 45268
                                   EPA/600/S-92/042   Oct. 1992
ENVIRONMENTAL
RESEARCH   BRIEF
                     Waste Reduction Activities and Options for a
           Manufacturer of Room Air Conditioning Units and Humidifiers

                                  Hana Saqa 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 manufactures  room air conditioners and
humidifiers. A site visit was made in 1990 during which several
opportunities for waste minimization were identified.  These
opportunities include  more efficient  recovery of degreasing
solvents, movement to aqueous degreasing procedures, and
segregation and reuse of hydraulic and lubricating  fluids.
Implementation of the identified waste minimization opportuni-
ties 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 disposal
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 prevention 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 room air conditioner and humidifier manu-
                        facturer (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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 on the level  of  activity of the facility. All values should be
 considered in that context.

 H should  be noted that the economic savings of the minimiza-
 tion opportunity,  in most cases, results from the need for less
 raw material and from reduced present and future costs asso-
 ciated 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 independently and do  not  reflect duplication of
 savings that would  result when the opportunities are imple-
 mented  in  a package. Also,  no equipment depreciation is
 factored into the  calculations.

 The most beneficial option from the perspective of risk reduc-
 tion would be acceleration of the program to replace the final
 vapor decreasing unit with another aqueous based cleaner. It
 is recognized that there are some concerns about the space
 available  for such a substitute unit, as well as some concerns
 about the effect  of  the change  on  rate of production at the
 facility. It  should  be  recognized that  the vapor degreasing unit
 is being used because it is  effective and rapid as a cleaner.
 Substitute units often are somewhat  less efficient meaning that
 throughput  may  be  reduced. This is sometimes  a significant
 manufacturing concern. It is suggested that a manufacturing
 time/motion/layout study  be  carried out to address some of
 these concerns.

 In the meantime, while the solvent vapor degreaser is still in
 operation, it is likely that  a  portion  of the fugitive emissions
 result from the following: less than optimum cooling/condensa-
 tion of the vapor, the ventilation capture velocity may not be
 functioning adequately, or the water/trichloroethylene separator
                                      may not be operating as effectively as it should. Attention to
                                      these operational parameters may impact the amount of loss of
                                      the solvent.

                                      At present the leaked hydraulic  oil  is mixed with the other
                                      machining  and  lubricating  waste  oils and  hauled away as
                                      hazardous waste. Capture  of the leaked hydraulic oil is sug-
                                      gested. The material may be acceptable for  reuse if it  is not
                                      allowed to  become contaminated with other  materials.  If not
                                      reusable immediately, it may be possible to recondition it either
                                      mechanically onsite or by use of  a commercial reconditioning
                                      service.

                                      It is possible that some of the oil/grease from  the coil cleaning
                                      operation in alkaline aqueous media is not completely separated
                                      by the oil separator due to the formation of oil in  water emulsions.
                                      It is suggested that polymeric emulsion breakers  be tried in
                                      order to improve the performance of this  unit.  It should be
                                      realized that this option would not be  expected to result in any
                                      savings for the facility. Rather it would result, if effective, in a
                                      cleaner aqueous stream.

                                      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
Table 1.  Summary of Current Waste Generation
Waste Generated
Waste Oils
Wastewater
Source of Waste
Mixed hydraulic, lubricating
Discharged water from aaueous
Chlorinated Solvent/
Sludge

Spent Activated Carbon

Solvent Loss
degreasers

Spent solvent from degreasers


Filters from vapor degreaser

Fugitive emissions from degreaser
                                                            Annual Quantity
                                                              Generated
 40,000 gal

200,000 gal


  27,000 Ib


     120lb

  >2,000 Ib
                                                           Annual
                                                            Costs
$80,000

    $82


$12,800


   $350

>$1,300
                                                                            •&U.S. GOVERNMENT PRINTING OFFICE: 1994 - S50-067/MI63

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Table 2.  Summary of Waste Minimization Opportunities


                     Minimization Opportunity
Waste Stream
Reduced
Annual Waste Reduction      Net       Implementation      Payback
Quantity     Percent   Annual Savings       Cost          Years*
Waste Oils
Chlorinated Solvent/
Sludge, Spent Activa-
ted Carbon, Solvent
Loss
Solvent Loss
                     Collect and segregate hydraulic
                     oil leaks, check quality,
                     if acceptable, reuse, or purify
                     by filtration, centrifugation,
                     or use of outside, reconditioning
                     service

                     Complete change to aqueous alkaline
                     degreasing operation.
5000 gal
                                                                      12%
30,000 Ib
                                                                      100%
                     Improve mechanical performance of
                     the solvent capture system
                                                          600 Ib
                                                                      30%
$ 12,500
                                                                                                  $4,000
                                                                                                                 0.3
$14,050
$30,000
                                                                                                                 2.0
                          (It must be realized that this option will
                          increase the quantity of water sent to the
                          POTWand will increase the amount of waste
                          oil recovered from the oil separator.)

                           $400           $500           1.2
                          (This represents regular maintenance
                          which will be incurred annually,
                          therefore, any payback period based
                          on implementation costs, may be illusory.)
" Savings result from reduced raw materials and treatment and disposal costs when implementing each minimization opportunity independently.
   United States
   Environmental Protection Agency
   Center for Environmental Research Information
   Cincinnati, OH 45268

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