United States
                         Environmental Protection
                         Agency
            Risk Reduction
            Engineering Laboratory
            Cincinnati, OH 45268
                         Research and Development
            EPA/600/S-92/052   October 1992
                         ENVIRONMENTAL
                         RESEARCH   BRIEF
           Waste Reduction Activities and Options for a Manufacturer of
                Fire Retardant Plastic Pellets and Hot Melt Adhesives

                                    Hanna 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 fire retardant plastic pellets
and hot melt adhesives.  The  manufacturing process for the
plastic pellets uses a batch procedure in mixers where resins
are combined with  flame retardants  and other additives. The
mix is albwed to solidify and formed into pellets. The hot melt
adhesive is produced by extruding a polymer with the necessary
additives followed by washing and palletizing. A site visit was
made in 1990 during which several opportunities for waste
minimization were identified. Options identified included changes
in sequencing of production, modifications of wastewater treat-
ment practices, changes in hydraulic oil use and reuse practices.
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 dis-
posal of hazardous substances, including both process-related
wastes and residues from waste treatment, receive significant
attention because of regulation and economics.

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) as-
sisted  in  conducting the  assessments. This research brief
presents an assessment of the manufacturing of fire retardant
plastic pellets and hot melt adhesives (1 of the 30 assess-
ments performed) and provides recommendations for waste
minimization options resulting from the assessment.
* New Jersey Institute of Technology, Newark, NJ 07102
                                                                             Printed on Recycled Paper

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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 in-house staff of the facility, the degree
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 £ 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.

No sampling or laboratory analysis was undertaken as part of
these assessments.


Facility Background
The facility is a manufacturer of plastic  pellets with fire retardant
properties.  The  pellets are typically used for  wire and cable
coating and insulation. The facility also manufactures hot melt
adhesives used primarily for metal-metal bonding.

The facility  is located in a rural area  and employs about 120
people. In addition to the equipment used directly for production,
there are tanks used for  wastewater treatment and a  pond
where non-hazardous water is piped.


Manufacturing Processes
The production of the plastic formulation for the wire insulation
pellets takes place in a Banbury mixer. Powdered polyethylene
resins and various combinations of additives  including bromi-
nated fire retardants, fillers, and colorants  such as antimony
oxide and carbon  black  are  metered in  and mixed.   The
resulting composition is spread onto a conveyor for hardening
and then mechanically chopped into pellets.

The hot melt adhesive process requires combining and melting
polypropylene,  acrylic acid, and  an organic peroxide in an
extruder.  The specific organic peroxide used changes depend-
ing upon  the desired performance characteristics of the final
product.   The mixed melt is extruded  onto a ventilated  con-
veyor and transported to a slurry washing station. The washed
product is palletized and dried before packaging as the finished
product.


Existing Waste Management Activities
The company  has already instituted some environmental prac-
tices designed to encourage reuse of materials and to minimize
worker risk. Their willingness to participate in this study indicates
the interest of the management of the facility in strengthening
their pollution prevention  activities.  The two  major product
lines are substantially different in their manufacturing steps; the
waste management practices and requirements for the two
therefore  differ.

The plastic pellet process  utilizes a low hazard material and is
essentially a mixing process with little or no potential for  emis-
sions. There is a potential for dust emission during the mixing
step. This is addressed using hydraulic oil  dust seals at each
end of  the  mixer rotor.  This  oil,  contaminated with mixture
ingredients, drips into 5-gal containers.  When these containers
are.filled  the  accumulated oil  is emptied  into a 55-gal  drum
where the heavier materials settle to form a sludge. Periodically,
the oil is pumped out for recycling  and the sludge is mixed with
clay and  landfilled.   Approximately 3200  gal  of waste oil and
200 drums of sludge are generated each  year.  In addition,
water from  housekeeping operations and  from cleaning the
mixers is collected in sumps and pumped to tanks to  allow
skimming of oil for recycling.  The  oil-free water, about 50,000
gal/day is pumped to the pond onsite.

The hot melt adhesive production process involves a scrubbing
process  for the  captured  air emissions produced  after the
extrusion step. The exhaust from  a hood is passed through a
water scrubber.  The contaminant  which is acrylic acid  is
retained by the water.  After about one week in the scrubber,
the  water is pH adjusted  and  sent to a storage tank.  Water
used in  product washing  is similarly treated  and sent to the
storage tank about once a week.  The accumulated wastewater
(about 7,000 gal/wk) is sent offsite for disposal at a cost  of
about $0.42/gal.  The level of acrylic acid is  about  1%.   This
process  also produces waste peroxide.  When product  types
are changed, the practice at the facility is to purge the peroxide
metering apparatus with the peroxide material  to be used  in the
next batch.  The collected purge material is then a  mixture of
organic peroxides. The quantity of this material varies depending
upon production rates, but about  1-2 quarts  is  produced with

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each purge. The mixture is accumulated in drums at the site.
Presently, the  facility is seeking an effective disposal practice
for this mixture  of  wastes.   The  manufacturer  recommends
disposal  by incineration, after  mixing with  oil to a level  of
peroxide no greater than 5% of the mixture.

The appearance of the facility shows that the management and
employees  recognize the  waste  reduction value of careful
movement of raw materials, good maintenance of equipment,
and spill  control and spill prevention activities.


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 and associated sav-
ings, and the implementation cost along with the payback time
are given  in  the table.   The  quantities of waste currently
generated at the facility and possible waste  reduction depend
on the level of activity of the facility.

ft 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
' Mention of trade names or commercial products does not constitute endorsement
 or recommendation for use.
                                       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.


                                       Regulatory Implications
                                       There are potential regulatory implications of pollution preven-
                                       tion initiatives at this facility.  Any changes in the scrubbing
                                       system may be impacted by the requirements of the air permit.
                                       If any permit conditions need to be changed then implementa-
                                       tion of pollution prevention concepts may be delayed.  The
                                       pond  at the facility which currently receives non-hazardous
                                       aqueous streams may be impacted  by changing water discharge
                                       regulations.  In that case additional operational changes may
                                       be  required to address new regulations.  The accumulation of
                                       mixed organic peroxides at the facility must be done in accor-
                                       dance with  RCRA and state regulations.   Overall, a facility
                                       such as this should encourage implementation of additional
                                       pollution prevention practices.

                                       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
   Source of Waste
Annual Quantity
  Generated
  Annual Waste
Management Costs
Waste Hydraulic Oil


Oil Sludges
Oil dust seals on Banbury
mixers

Process residues captured by
oil in the mixer
Acrylic Acid Contaminated Air scrubber from adhesive hood
Water                 and washing of product

Mixed Peroxides         Material used to purge raw material
                      metering system
    3200 gal


  200 drums


  364,000 gal
                                    20 drums
                                   (estimated)
  $1,600
  40,000
                                                           153,000
                          120,000
                          (based on estimated
                          incineration costs
                          as recommended by
                          manufacturer)
                                                                   &U.8. GOVERNMENT PRINTING OFFICE: 1994 - SSfr«i7/MllS

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Table 2.  Summary of Recommended Waste Minimization Opportunities
Waste Stream
Reduced
Minimization Opportunity
Annual Waste Reduction
Quantity         Percent
     Net      Implementation  Payback
Annual Savings      Cost       Years *
Waste OH           Filtration or centrifugation                    1600 gal
                   of oil allowing reuse

Wastewater         Evaluate scrubber water                  109,000 gal
Containing          and wash water to determine
Acrylic Add         which has the tower level of
                   acrylic acid. Use the one
                   with the lower level as the
                   makeup for the other. This will
                   reduce the total volume of water
                   used.

                   Removal of acrylic acid from                328,000 gal
                   water by ion exchange or reverse
                   osmosis allowing water reuse and
                   producing another type of waste stream
                   with higher levels of acrylic add.

Mixed Organic       Use air purge capability                    18 drums
Peroxides           designed into equipment.
                   Keep separate the air-purged
                   peroxides and use them in the
                   next batch. Some washing with
                   solvent such as hexane of critical
                   mechanical parts may be desired,
                   generating a much smaller waste
                   stream.
                                                            50       $3,200       $10,000
                                                            30       45,800
                                              200       immed.
                                                            90       67,000
                                                            90      110,000
                                            75,000
                                  1.1
                                              100       immed.
* Savings result from reduced raw material 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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