vi-EPA
                         United States
                         Environmental Protection
                         Agency
                                   Risk Reduction
                                   Engineering Laboratory
                                   Cincinnati, OH 45268
                         Research and Development
                                   EPA/600/S-92/062   October 1992
ENVIRONMENTAL
                         RESEARCH   BRIEF
           Waste Reduction Activities and Options for a Manufacturer of
                          Commercial Dry Cleaning Equipment

                                   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 machinery used for commercial
dry cleaning operations. A site visit was  made in 1990 during
which several opportunities for waste minimization were identi-
fied. Options identified for waste reduction included improve-
ment of spray painting operations and recycling  opportunities
for wood scrap. In addition there is an  option mentioned to
encourage  the change of refrigerant to a non-CFC chemical.
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 atten-
tion 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, New Jersey De-
                        partment of Environmental Protection and Energy, NJDEPE, is
                        pursuing the goals of waste minimization awareness and pro-
                        gram 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 Oppor-
                        tunities 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 the manufacturing of machinery used for
                        commercial dry cleaning operations (1 of the 30 assessments
                        performed) and provides  recommendations for waste minimi-
                        zation 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.

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


Facility  Background
The facility is a  manufacturer of equipment for commercial dry
cleaning operations. The facility is responsible for the design
and  fabrication  of the  components  used  to construct the
equipment. The components are shipped off site for assembly
and for application of  the prime coating.  Then the assembled
units are transported to this facility where they are tested for
operational capability and the  final painting  is done.  Approxi-
mately 500 units are produced each year.

The facility is located in  an urban area and employs about 35
people.
Manufacturing Processes
The only production process which occurs at this facility is the
final painting of the dry cleaning equipment. The painting  is
carried out  in spray booths using a commercially available
high-solids,  solvent-based paint. The spray booths use fiber-
glass filters  to capture overspray.  The units 'are shipped into
the facility  in wooden packing  materials. These packaging
materials generate another waste stream.


Existing Waste Management Activities
There are only two waste streams  which are generated at this
facility. The  filters from the spray booth are made of fiberglass
and must be changed and disposed  of  at regular intervals
when air  flow becomes difficult because of clogging of the
filters. The facility uses about 1500 filters each year. The size
of the filters is 20"x20"x1". Although the filter system captures
solids, it does not have the ability to retain volatile organics
from the solvent. On average, the facility uses 6 gal of paint
each  day. The  filters  are sent  offsite for disposal. While it
appears that the waste stream from this portion of the activity
is the used  filters, the  waste stream is actually that portion  of
the paint  that does not adhere to the surface to  be coated.
Therefore, the waste  management activity and costs include
purchasing the filters and the disposal of the spent filters.

The other waste stream that  is generated at this facility is wood
scrap which results from the  packing materials used to ship the
units  to and from this  facility.  Presently, the facility produces
about 100-125  yd3 of such crating wood scrap annually. The
landfill disposal cost for this  material is about $2000/yr.


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. This particular
facility presents  an interesting  challenge in determining waste
minimization opportunities  since  the  potential  opportunities
present themselves in several ways and are instructive to other
types of companies.

At the level  of the operations at the facility itself, an evaluation
of improved painting  procedures and of alternative uses for
wood scrap, could have a favorable impact upon the quantity
of waste generated. At another level, a significant portion of the
production of the dry  cleaning units is accomplished offsite.
This portion of the production also includes a painting step.
While having the painting carried out elsewhere limits emissions
at this facility, the management should be encouraged to require
a waste reduction opportunities assessment to be carried out
at the offsite facility as well. Ideally, every production step for
any product should be designed  and operated to minimize
waste and emissions.

  Dry  cleaning  units  overall were  redesigned  to include the
capability to distill and  reuse the solvent in response to earlier
pollution  prevention concerns. This redesign involves both a
heating and cooling unit. The dry cleaners who purchase and
use this equipment have a desire to minimize use  and loss  of
the solvent,  perechloroethylene, used for dry cleaning applica-
tions.

While this type of unit provides distinct pollution prevention
advantages  for the dry cleaners, it comes with a disadvantage.

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The cooling unit for the distillation capability uses CFC-502 as
a refrigerant. This material is recognized as an ozone-depleting
agent. While this is not  a pollution prevention  issue for this
facility per se, it does present a  potential problem for the
buyers of the units—the commercial dry cleaners. However,
the manufacturer of the units buys the refrigeration units from
another manufacturer.

While there is a general agreement that a different refrigerant
would be desirable,  it  is not clear  who has responsibility for
making  the first step to develop the technology to make the
change.  The refrigeration  equipment  manufacturer may say
that change is not possible until the producers of the refrigerants
can supply a non-ozone-depleting  refrigerant. While some al-
ternative refrigerants are now available, they require modifica-
tions of the cooling units to be effective. It is not clear at this
point  how far any of the companies involved in this technical
issue can go independently to address the concerns. It is also
not clear that effective technical alliances have been made to
encourage the desired  changes.

Similarly, a dry cleaning process which did not use perchloro-
ethylene or some  other  chlorinated solvent would also  be
desirable. The facility  manufacturing  the dry  cleaning  units
does  not have the technical resources to develop such a new
system. It is also not clear if  such technology can be devel-
oped.

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 gener-
ated at the facility and possible waste reduction depend on the
level of activity of the facility.
* Mention of trade names or commercial products does not constitute endorse-
 ment or recommendation for use.
    It 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 arid 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 savings that would
    result when the opportunities  are implemented in a  package.
    Also,  no equipment depreciation is factored  into the calcula-
    tions.


    Regulatory Implications
    The  potential  regulatory implications of pollution prevention
    initiatives at this facility will  affect  the manufacture  of this
    product  as well as its use  at dry cleaning shops. Changes in
    permitted levels of VOC emissions might have an impact  on
    the spray painting operation.  However, at 6 gal/day of paint,
    this is not a major emitter. The upcoming restrictions on the
    production and use of CFC's will have a significant impact  on
    dry cleaning units made by the facility which  may require a
    design change on the part of the facility as well as retrofitting of
    the units already in the field. Similarly, any regulatory restrictions
    on the  use of  perchlorethylene will necessitate substantial
    changes in the design and operation of such dry cleaning units.

    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
Contaminated Filters


Scrap Wood
                         Capture of overspray from
                         painting booth

                         Residue from wooden packing
                         crates
1,500 filters


100-125 yd3
                                                                                $17,000
                                                                                  2,000
                                                                             . GOVERNMENT PRINTING OFFICE: 1994 - 550-067/80176

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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 *
Contaminated         Reduce the quantity of overspray            750 filters        50
 Filters               in the painting operation.
                     A change to a high volume low
                     pressure spray gun has the potential
                     to improve transfer efficiency from
                     the usual 20% to 40% to 65% to 85%. This
                     means that more paint is on the unit
                     and less is in the filter. The
                     change will also reduce the emission
                     of VOC's by about 50% because the volume
                     of paint used is reduced.

                     Consider change from fiber glass            900 filters        60
                     filters to multi-layered chemically
                     treated paper filters. Such filters
                     are claimed to be 99% efficient as
                     contrasted to 92% efficiency for the
                     fiber glass filter. While the paper
                     filters are about twice as expensive
                     as the glass ones, they are claimed to
                     last about 2.5 times as long. This
                     extra use time has the potential to reduce
                     the volume of waste produced.

Scrap Lumber         Identify area companies which recycle        100-125yd3     100
                     scrap wood. The cost of disposal by
                     this route is substantially less.
                                                                    8500
                                                                     7000
                                                                     1500
                                            $5000
                                                                                                0.6
                                        This represents a simple
                                        change from one type of
                                        filter to another.  There is
                                        no real implementation
                                        costs. The cost savings are
                                        immediate and are estimated
                                        as a function of reduced
                                        disposal costs and higher
                                        purchase costs for the filters.
                                                                                                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

  Official Business
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