&EPA
                         United States
                         Environmental Protection
                         Agency
                         Research and Development
                                     Risk Reduction
                                     Engineering Laboratory
                                     Cincinnati, OH 45268
                                     EPA/600/S-92/055   October 1992
ENVIRONMENTAL
RESEARCH   BRIEF
           Waste Reduction Activities and Options for a Manufacturer of
                         Fine Chemicals Using Batch Processes

                                   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 as-
sessments at 30 small- to medium-sized businesses in the Sjtate of
New Jersey. One of the sites selected was a manufacturer of fine
chemicals using batch processes. A site visit was made in 1990
during  which several opportunities for waste minimization were
identified. Options identified for waste reduction included initiation of
solvent recycling or reconditioning for reuse and  modifying the
chemical reaction conditions to improve product quality and reduce
the amount of reprocessing which has been necessary. Implemen-
tation of the identified waste minimization opportunities was not part
of the program.  Percent waste reduction, net annual savings, imple-
mentation costs and payback periods were estimated.

This Research  Brief was developed by the Principal Investigators
and EPA's Risk Reduction Engineering Laboratory in Cincinnati,
OH, to  announce key findings of this completed assessment.


Introduction
The environmental issues facing industry today have expanded
considerably beyond traditional  concerns. Wastewater, air emis-
sions, 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 regu-
lation and economics.

As environmental issues have become more complex, the strategies
for waste management and control have become more systematic
* New Jersey Institute of Technology, Newark, NJ 07102
                         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 generating the least amount of waste possible.

                         The Hazardous Waste Advisement Program (HWAP) of the Divi-
                         sion of Hazardous Waste Management, NJDEPE, is pursuing 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, conducted an Assessment of
                         Reduction and Recycling Opportunities for Hazardous Waste (AR-
                         ROW) 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 Op-
                         portunity 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 as-
                         sessment of the manufacturing of fine chemicals using batch pro-
                         cesses (1 of the 30 assessments performed) and provides recom-
                         mendations for waste minimization options resulting from the as-
                         sessment.


                         Methodology of Assessments
                         The assessment process was coordinated by a team of technical
                         staff from NJIT with experience in process operations, basic chem-
                         istry, and environmental  concerns and needs. Because the EPA
                         waste minimization manual is designed to be primarily applied by
                         the inhouse 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.
                                                                               Printed on Recycled Paper

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 The goaJ 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 folbws:

   •  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 techni-
 cal staff within the company and a need to develop an agenda for
 technical action before corporate commitment 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 compli-
 cations  developed, the team offered  assistance  in the technical
 review,  inspections, and option development.

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


 Facility Background
 The  facility is an integrated chemical production installation which is
 part  of the manufacturing capability of a large chemical production
 company. The facility which participated in this  study houses pilot
 plant activities for fine chemicals and  for chemical intermediates
 under investigation by the company. In addition, some manufactur-
 ing of  products,  particularly  bw volume products occurs at  this
 facility. The facility also hosts research activities, packaging operatbns,
 and Quality Assurance laboratory activities. The site is approximately
 50 years old, although  most of the buildings are significantly newer.
 The  equipment in use varies from brand new to over 30 years in
 age.


 Manufacturing  Processes
 Although many independent operatbns take place at this installa-
tbn,  it was decided to  focus this initial effort on  one of the smaller
 manufacturing operatbns. Such a focus was expected to provide
the technical and operating management of the facility an illustratbn
of the assessment process and provide the informatbn necessary to
plan  a larger scale assessment process for the entire facility. It was
 desirable, therefore, to select a discrete process which could be
 thoroughly analyzed and whbh held potential for measurable and
 significant pollutbn preventbn opportunities.

 The process investigated uses  relatively uncomplicated chemistry
 requiring formatbn of a coordinatbn-type  complex between an
 organb amine and a volatile habgen-containing solvent. The com-
 plexatbn is carried out in the presence of a small amount of an
 alcohol co-solvent. The individual components are synthesized either
 offsite or in an area separate from the complexation equipment and
 process. The process involved is a relatively simple three component
 mixing and complexatbn reaction whbh albws for  an in-depth
 analysis of waste streams and consideration of alternatives.

 Typical steps  in the  manufacturing process  include the folbwing
 activities:

   •  A concentrated solution of the organic amine in an alcohol
     solvent is slowly added to  a large volume of vigorously
     agitated halogen-containing solvent.
   •  As a result of the mixing,  a  portion of the resulting amine/
     solvent complex precipitates.
   •  The product yield is increased by distilling off a portion of
     the halogen-containing solvent in order to induce crystalli-
     zation of  the product complex.
   •  The product is recovered by filtration by vacuum.
   •  Recovered solvent  is sent offsite for  recycling.


 Existing Waste  Management Activities
 The company  has already recognized the advantages and benefits
 of identifying and implementing waste  reductbn and pollution pre-
 vention practices. The current procedure  which utilizes offsite recycling
 for the waste streams from the investigated process illustrates that
 recognition and commitment.


 Waste Minimization Opportunities
 For this facility, the initial use of the manual was carried out by the
 staff of the facility. The NJIT team partbipated in  identifbation of
 some of the optbns  for waste reduction. During the assessment
 process, the folbwing waste streams were identified:

   •  Liquid Solvent Stream
   •  Vapor Losses

 The liquid solvent waste stream results  from distillatbn of solvent to
 raise the product concentratbn to induce crystallization and from the
 recovery of the product by filtratbn. It has been generated at a rate
 of about 19,000 kg/yr. The waste stream has been managed by
 offsite recycling at an annual cost of about $12,000.

 The vapor loss stream results from atmospherb  bsses during the
 solvent transfer to a receiving vessel. A minor portion of the bss has
 been estimated to result from  leaking connections and escape
 during vessel openings.  More of the vapor  bss results from the
 vacuum filtratbn step which is used to recover the solid product. A
 portion of the volatile solvent is lost through the vacuum system and
 is not easily recovered. It is  estimated that about 1200 kg of the
 mixed solvents  are bst annually through these routes. The fraction
 which is captured is sent offsite for recycling  at  an annual  cost of
 about $500.

 The continuing  technical challenge is to reduce further the size of the
two waste streams resulting from the process. Technically, it may be
easier to reduce the amount of vapor bss by tighter vapor handling
practices. Because the volume of the liquid solvent stream is greater,

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there may be greater opportunities there for high percentage reduc-
tion.
to avoid scheduling production runs during times of the year when
ambient humidity would be expected to be high.
From the perspective of pollution  preventbn,  the  company may
desire to  look for options which  reduce emissbns to the atmo-
sphere, reduce the total amount of chemical usage,  encourage
onsite recycling  or reuse of  the  materials, or albw use  of less
hazardous substances in the manufacture and processing of the
product. However, it was decided that the performance requirements
for the product  precluded any changes in the chemistry of the
process until a detailed  product characterization and performance
evaluatbn  could  be carried out.  Therefore, any changes in the
actual substances used to manufacture the product could not  be
considered to be a viable initial  pollutbn preventbn  optbn.  Rather,
both  of the two  waste streams were considered  individually to
identify the reasons for the size  of the streams and possible modifi-
catbn of practices whbh had potential for their reductbn.

The liquid solvent stream presented the greatest challenge in terms
of volume. The relatively high cost of the solvents/reactants in the
process had prevbusly led to consideratbn of alternative ratios of
materials  in order to minimize  solvent use. The existing process
used the minimum volumes required in order to achieve the neces-
sary performance for the product.

The solvent waste stream is sent offsite for recycling because the
combinatbn of alcohol co-solvent with the halogen-containing solvent
presents some complicatbns with  the  distillatbn  process whbh
would normally  be used  for solvent  purifbatbn.  The  necessary
equipment to carry out this purifbatbn does not exist at the site and
the relatively small volume of this stream does not justify  investment
in such equipment at this time.  The required distillation  equipment
does exist at another company-owned site, however, so one of the
optbns identified is to  move this  process to another company
bcatbn in order to permit onsite  recovery, recycling and reuse of the
solvent.

An alternative to this optbn was also identified which would utilize a
two-step purifbatbn of the solvent system. The concept proposed
was to utilize an adsorbent for the alcohol component which, in a
packed bed medium, could selectively remove the  alcohol  leaving
the halogen-containing solvent in a more easily purified state allow-
ing distillatbn with existing equipment at the site. Alternatively, it may
be possible to reuse the halogen-containing solvent directly although
this would have to be verified by product quality and performance
testing. An  appropriate  chobe  of  alcohol adsorbent could albw
regeneratbn with  recovery and reuse of the alcohol. Such a proce-
dure would  be expected to reduce substantially the percentage of
this waste stream whbh needs to be sent for treatment.

Another alternative optbn addressed the  issue of reductbn of the
volume of  raw  materials used  in the process  itself. Although,  as
indbated prevbusly, it would not be possible to implement a new
process using smaller quantities  of the materials, examination of the
productbn  records  indbated  that about  10%  of the  batch  runs
represented reworking of batches whbh  failed quality  standards.
Stated another way, this  means  that a savings of 10% of the waste
stream could be realized by identifying and correcting the reasons
for the bebw standard quality of these batches. It was determined
that the product complex whbh is formed is sensitive to the presence
of water.  In fact, moisture can cause the  decomposition of the
complex. The presence  of high humidity  during the complexatbn
process was determined to be the primary cause of the 10% failure
rate. It was proposed, therefore, to provide a more controlled  tem-
perature/humidity  environment for the  manufacturing  process  to
eliminate the failures of these batches. An alternative suggestion was
The vapor bss waste stream presented some addrtbnal challenges.
As indbated prevbusly, two significant sources for such losses were
identified—fugitive emissbns and the  filtratbn step in the product
recovery phase of the process. These  two sources lead to sugges-
tbns of different types of optbns for reductbn of vapor bss.

Several applbatbns of modified engineering practbes were identified
for reductbn of  fugitive bsses. These included  improved control
over condenser temperature and reactbn temperature, use of cou-
plings and connectors with bw dead volume, regular inspectbn and
replacement when necessary of seals, valves, and pressure relief
devices. Modified practbes such as gravity-induced introductbn of
solvents rather than by pumping to reduce any pressure buildup in
the reactbn vessel were also suggested.

While it may be difficult to quantify the pollutbn preventbn impact of
optbns such as these, it  is clear that they have the potential for
reducing fugitive emission.

Addressing the issue of vapor bsses during the filtratbn process
required identifbatbn of different optbns. It was determined that the
bsses occurred because the relatively  bw-boiling  solvent vaporized
under  the vacuum filtratbn conditbns and was bst through the
vacuum system. The optbn identified to reduce such bsses was to
utilize existing equipment to carry out pressure filtratbns instead of
vacuum filtratbn. The same pressure drop across the fitter could be
achieved, but because the absolute pressure in the system was
higher, volatilization could be reduced substantially. Therefore, solvent
bss would be reduced.

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 minimizatbn  recom-
mended for the facility. The type of waste, the minimizatbn opportunity,
the possible  waste  reductbn and  associated  savings, and the
implementation cost abng with the payback time are given in the
table. The quantities of waste currently generated at the facility and
possible waste reductbn depend on the level of activity of the facility.

It should be noted that the economb  savings of the minimizatbn
opportunity,  in most cases, results from the need for  less  raw
material and from reduced present and future 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 minimizatbn opportunity indepen-
dently and do not reflect savings that would result when the oppor-
tunities are implemented in a package.


Regulatory  Implications
An important regulatory implication in this study is that although the
majority of the waste stream from this process  is recycled, it is sent
offsite for purifbatbn and  reuse. Therefore, the streams are classi-
fied as waste. Even though the company has  at a nearby site the
technbal capability to purify the material and return it to the original
process, regulatory barriers prevent the ready implementation of this
practice. The  regulatory issue is that because the two facilities are
considered  separately from a regulatory point of view, the material
would have to be sent from this  facility under a hazardous waste
manifest. Then  even after purifbatbn  it would still  be considered
hazardous waste unless the company went through a process to
have it  delisted. Even then, the company would be seen as using a
                                                                          •&U.S. GOVERNMENT PRINTING OFFICI'.: 1994 - 550-067/80180

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"hazardous waste" in the manufacture of its products. The company
is not willing to argue against this type of public perception.

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 Depart-

* Mention of trade names or commercial products does not constitute endorsement
 or recommendation for use.
                                            ment of Environmental Protection and Energy and the U.S. Environ-
                                            mental 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
Liquid Solvent Stream
Filtrate
Vapor Loss
Source of Waste
Solvent distillation
Filtration of solid product
Fugitive emissions
Annual Quantity
Generated
19,000 kg
1,200kg
variable — at least 1000 kg
Annual Waste
Management Costs
$12,000
500
500
 Tab!* 2.   Summary of Recommended Waste Minimization Opportunities
 Waste Stream
 Reduced
 Liquid Solvent
 Stream
 Vapor Loss
 Vapor Loss
 Fugitive Emissions
 Minimization Opportunity
Purify onsite for recycling by
straight distillation

Move process to other facility
where distillation equipment
already exists

Reduce frequency of product
rework by controlling ambient
humidity

Change from vacuum filtration
to pressure

Introduce various techniques
such as improved condenser and
reaction temperature control,
regular inspection for leaks,
and introduction of solvents
by gravity instead of pressure
Annual Waste Reduction
                               Net
Quantity
18,000 kg
18,000 kg
Percent
94
94
Annual Savings
$16,500
16,500
Cost
$120,000
200,000
Years '
7.3
12.1
 1900kg



 1,000kg


 800kg
                                                                            10
                                                                            84
80
                                                                                         1,750
                                                                                         500
             400
                          2,000
   0
existing

  500
                                                                                                                   1.1
                                                        1.2
' 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

  Official Business
  Penalty for Private Use
  $300
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  EPA/600/S-92/055

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