&EPA
United States
Environmental Protection
Agency
Risk Reduction Engineering Laboratory
Center for Environmental Research Information
Cincinnati. Ohio 45268
EPAX625/7-90-004
February 1990
Technology Transfer
Guides to Pollution
Prevention
The Pesticide
Formulating Industry
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EPA/625/7-90/004
February 1990
GUIDES TO POLLUTION PREVENTION
The Pesticide Formulating Industry
RISK REDUCTION ENGINEERING LABORATORY
.. AND ' ...
CENTER FOR ENVIRONMENTAL RESEARCH INFORMATION
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
Printed on Recycled Paper
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NOTICE
This report has been subjected to the U. S. Environmental Protection Agency's peer and administrative review and
approved for publication. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
This document is intended as advisory guidance only to pesticide formulators in developing approaches for pollution
prevention. Compliance with environmental and occupational safety and health laws is the responsibility of each
individual business and is not the focus of this document.
Worksheets are provided for conducting waste minimization assessments of pesticide formulating facilities. Users are
encouraged to duplicate portions of this publication as needed to implement a waste minimization program.
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FOREWORD
Pesticide formulating facilities generate wastes during such operations as decontamination of mixing and storage of
equipment, housekeeping, and laboratory testing for quality assurance. The wastes generated are: containers with
leftover raw materials; pesticide dust and scrubber water from air pollution control equipment; volatile organic
compounds; off-specification products and laboratory analysis wastes; spills; waste sands or clays; waste rinse water and
solvent; laundry waste water; and stormwater runoff contaminated with pesticides.
Reducing the generation of these wastes at the source, or recycling the wastes on or off site, will benefit pesticide
manufacturers by reducing raw materials needs, reducing disposal costs, and lowering the liabilities associated with
hazardous waste disposal. This guide provides an overview of the pesticide formulating processes and operations that
generate waste and presents options for minimizing waste generation through source reduction and recycling.
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ACKNOWLEDGMENTS
This guide is based in pan on waste minimization assessments conducted by Environmental Science and Engineering
(ESE) for the California Depaitemnt of Health Services (DHS). Contributors to these assessments include: David Leu,
Benjamin Fries,' Kim Wilhelm, and Jan Radimsky of the Alternative Technology Section of DHS. Much of the
information in this guide that provides a national perspective on the issues of waste genteration and minimization for
pesticide formulators was provided originally to the U. S. Environmental Protection Agency by Versar, Inc. and Jacobs
Engineering Group, Inc. in Waste Minimization-Issues and Options, Volumell, report no. PB87-114369(1986). Jacobs
Engineering Group, Inc. edited and developed this version of the waste minimization assessment guide, under
subcontract to Radian Corporation (USEPA contract 68-02-4286). Lisa M. Brown of the U. S. Environmental Protection
Agency, Office of Research and Development, Risk Reduction Engineering Laboratory, was the project officer
responsible for the preparation and reyiew of this document. David A. Lewis of the Agricultural Chemical Group, FMC
Corporation also served as a reviewer.
IV
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CONTENTS
SECTION
Notice
Foreword L
Acknowledgments
1. Introduction , -
2. Pesticide Formulating Industry Profile
3. Waste Minimization Options for Pesticide Formulators
4. Guidelines For Using The Waste Minimization Assessment Worksheets .
Appendix A:
Pesticide Formulating Facility Assessments: Case Studies of Plants A, B and C,
Appendix B:
Where to Get Help: Further Information on Pollution Prevention
PAGE
ii
iii
iv
1
5
11
16
30
50
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SECTION 1
INTRODUCTION
This guide is designed to provide pesticide formula-
tors with waste minimization options appropriate for this
industry. It also provides worksheets designed to be used
for a waste minimization assessment of a pesticide formu-
lating facility, to be used in developing an understanding of
the facility's waste generating processes and to suggest
ways to reduce the waste.
The guide should be used by pesticide formulating
companies, particularly their plant operators and environ-
mental engineers. Others who may find this document
useful are regulatory agency representatives and consult-
ants. *
The worksheets and the list of waste minimization
options for pesticide formulating were developed through
assessments of three pesticide formulating firms commis-
sioned by the California Department of Health Services
(Calif. DHS, 1987). The three firms' facility operations,
manufacturing processes, and waste generation and man-
agement practices were surveyed, and their existing and
potential waste minimization options were characterized.
Economic analyses were performed on selected options.
Waste minimization is a policy specifically mandated
by the U.S. Congress in the 1984 Hazardous and Solid
Wastes Amendments to the Resource Conservation and
Recovery Act (RCRA). As the federal agency responsible
for writing regulations under RCRA, the U.S. Environ-
mental Protection Agency (EPA) has an interest in ensur-
ing that new methods and approaches are developed for
minimizing hazardous waste and that such information is
made available to the industries concerned. This guide is
one of the approaches EPA is using to provide industry-
specific information about hazardous waste minimization.
The options and procedures outlined can also be used in
efforts to minimize other wastes generated in a facility.
EPA has also developed a general manual for waste
minimization in industry. Th&WasteMinimizationOppor-
tunity Assessment Manual (USEPA1988) tells how to con-
duct a waste minimization assessment and develop options
for reducing hazardous waste generation at a facility. It
explains the management strategies needed to incorporate
waste minimization into company policies and structure,
how to establish a company-wide waste minimization
program, conduct assessments, implement options, and
make the program an on-going one. The elements of waste
minimization assessment are explained in the Overview,
next section.
In the following chapters of this manual you will find:
A profile of the pesticide formulating industry and
the processes used by the industry (Section Two);
Waste minimization options for pesticide
formulating firms (Section Three);
Waste minimization assessment guidelines and
worksheets (Section Four)
An Appendix, containing:
- Case studies of waste generation and waste
minimization practices of pesticide formulating
firms;
- Where to get help: Additional sources of informa-
tion.
Overview of Waste Minimization
Assessment
In the working definition used by EPA, waste minimi-
zation consists of source reduction and recycling. Of the
two approaches, source reduction is usually considered
preferable to recycling from an environmental perspective.
Treatment of hazardous waste is considered an approach to
waste minimization by some states but not by others, and
thus is not addressed in this guide.
A Waste Minimization Opportunity Assessment
(WMOA), sometimes called a waste minimization audit, is
a systematic procedure for identifying ways to reduce or
eliminate waste. The steps involved in conducting a waste
minimization assessment are outlined in Figure 1 and
. presented in more detail in the paragraphs below. Briefly,
the assessment consists of a careful review of a plant's op-
erations and waste streams and the selection of specific
areas to assess. After a particular waste stream or area is
established as the WMOA focus, a number of options with
the potential to minimize-waste are developed and screened.
The technical and economic feasibility of the selected
options are then evaluated. Finally, the most promising
options are selected for implementation.
To determine whether a WMOA would be useful in
your circumstances, you should first read this section
l
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Figure 1. The Waste Minimization Assessment Procedure
The Recognized Need to Minimize Waste
PLANNING AND ORGANIZATION
1 Get management commitment
1 Set overall assessment program goals
1 Organize assessment program task force
Assessment Organization &
Commitment to Proceed
ASSESSMENT PHASE
> Collect process and facility data
»Prioritize and select assessment targets
> Select people for assessment teams
> Review data and inspect site
Generate options
> Screen and select options for further study
Select New Assessment
Targets and Reevaluate
Previous Options
Assessment Report of
Selected Options
FEASIBILITY ANALYSIS PHASE
> Technical evaluation
> Economic evaluation
Select options for Implementation
Final Report, Including
Recommended Options
IMPLEMENTATION
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Repeat the Process
Successfully Implemented
Waste Minimization Projects
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describing the aims and essentials of the WMOA process.
For more detailed information on conducting a WMOA,
consult the Waste Minimization Opportunity Assessment
Manual.
The four phases of a waste minimization opportunity
assessment are:
Planning and organization
Assessment phase
Feasibility analysis phase
Implementation
PLANNING AND ORGANIZATION
Essential elements of planning and organization for a
waste minimization program are: getting management
commitment for the program; setting waste minimization
goals; and organizing an assessment program task force.
Assessment Phase
The assessment phase involves a number of steps:
Collect process and facility data
Prioritize and select assessment targets
Select assessment team
Review data and inspect site
Generate options
Screen and select options for feasibility study
Collect process and facility data. The waste streams
at a facility should be identified and characterized. Infor-
mation about waste streams may be available on hazardous
waste manifests, National Pollutant Discharge Elimina-
tion System (NPDES) reports, routine sampling programs
and other sources.
Developing a basic understanding of the processes
that generate waste at a facility is essential to the WMOA
process. Flow diagrams should be prepared to identify the
quantity, types and rates of waste generating processes.
Also, preparing material balances for various processes
can be useful in tracking various process components and
identifying losses or emissions that may have been unac-
counted for previously.
Prioritize and select assessment targets. Ideally, all
waste streams in a facility should be evaluated for potential
waste minimization opportunities. With limited resources,
however, a plant manager may need to concentrate waste
minimization efforts in a specific area. Such considera-
tions as quantity of waste, hazardous properties of the
waste, regulations, safety of employees, economics, and
other characteristics need to be evaluated in selecting a
target stream.
Select assessment team. The team should include
people with direct responsibility and knowledge of the
particular waste stream or area of the plant. Operators of
equipment and the person who sweeps the floor should be
included, for example.
Review data and inspect site. The assessment team
evaluates process data in advance of the inspection. The in-
spection should follow the target process from the point
where raw materials enter the facility to the points where
products and wastes leave. The team should identify the
suspected sources of waste. This may include the produc-
tion process; maintenance operations; and storage areas for
raw materials, finished product, and work in progress. The
inspection may result in the formation of preliminary
conclusions about waste minimization opportunities. Full
confirmation of these conclusions may require additional
data collection, analysis, and/or site visits.
Generate options. The objective of this step is to
generate a comprehensive set of waste minimization op-
tions for further consideration. Since technical and eco-
nomic concerns will be considered in the later feasibility
step, no options are ruled out at this time. Information from
the site inspection, as well as trade associations, govern-
ment agencies, technical and trade reports, equipment
vendors, consultants, and plant engineers and operators
may serve as sources of ideas for waste minimization
options.
Both source reduction and recycling options should be
considered. Source reduction may be accomplished
through:
Good operating practices
Technology changes
Input material changes
Product changes
Recycling includes:
Use and reuse of waste
Reclamation
Screen and select options for further study. This
screening process is intended to select the most promising
options for full technical and economic feasibility study.
Through either an informal review or a quantitative deci-
sion-making process, options that appear marginal, im-
practical or inferior are eliminated from consideration.
FEASIBILITY ANALYSIS
An option must be shown to be technically and eco-
nomically feasible in order to merit serious consideration
for adoption at a facility. A technical evaluation deter-
mines whether a proposed option will work in a specific ap-
plication. Both process and equipment changes need to be
assessed for their overall effects on waste quantity and
product quality.
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An economic evaluation is carried out using standard
measuresofprofitability.suchaspaybackperiod.returnon
investment, and net present value. As in any project, the
cost elements of a waste minimization project can be
broken down into capital costs and economic costs. Sav-
ings and changes in revenue also need to be considered.
IMPLEMENTATION
An option that passes both technical and economic
feasibility reviews should then be implemented at a facil-
ity. It is then up to the WMOA team, with management
support, to continue the process of tracking wastes and
identifying opportunities for waste minimization, thrbugh-
outa facility and by way of periodic reassessments. Either
such ongoing reassessments or an initial investigation of
waste minimization opportunities can be conducted using
this manual.
References
California DHS. 1987. Waste Audit Study: Pesticide
Formulating Industry. Report prepared by
Environmental Science and Engineering, Inc.,
Sacramento, Calif, for the Alternative Technology
Section, Toxic Substances (Control Division, California
Dept. of Health Services. November 1987.
USEPA. 1988. Waste Minimization Opportunity
Assessment Manual. Hazardous Waste Engineering
Research Laboratory, Cincinnati, Ohio., EPA/625/7-
88/003.
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SECTION2
PESTICIDE FORMULATING INDUSTRY PROFILE
Industry Description
As defined by Standard Industrial Classification (SIC)
2879, the pesticide formulating industry includes compa-
nies which formulate and prepare agricultural pest control
chemicals or pesticides. This includes insecticides, herbi-
cides, and fungicides. These products are formulated from
pesticide concentrates manufactured elsewhere and are
distributed to farmers in ready-to-use form.
The industry is comprised of roughly 330 establish-
ments nationwide. Approximately 59% of the establish-
ments are located in 10 states, although no one state
accounts for a major share of the industry. Most of the
establishments are located near the agricultural areas which
make use of the products.
Products and Their Uses
The agricultural chemicals industry (SIC 2879) pro-
duces pesticides and other agricultural chemicals not else-
where classified, such as soil conditioners. In the U.S.,
over 600 different pesticides are produced (Kryeger 1983).
Most pesticides can be classified as either insecticides,
herbicides, or fungicides, although many other minor clas-
sifications exist Table 1 lists the production of the major
classes of pesticides. Each division is subdivided to
chemical type.
The product formulations that were included in the
waste minimization assessments of this Guide were agri-
cultural, industrial, and household pesticide formulations.
These include insecticides, herbicides, and rodenticides.
Excluded from the study were preservatives, disinfectants,
and cleaning agents.
There are three types of pesticide formulations; sol-
vent-based, water-based, and solid-based.' In solvent-
based formulations, the solvent serves as the carrier solu-
tion for the pesticide ingredient. A solvent-water emulsion
may also be Used as the carrier. Typical solvents are light
aromatics such as xylene, chlorinated organics such as
1,1,1-trichloroethane, and mineral spirits. As with sol-
vent-based formulations, water serves as the carrier solu-
tion for the active pesticide ingredient in the water-based
formulations. Other water-based formulations are in the
form of suspensions or emulsions. The sol vent-and water-
based formulations are applied directly in liquid form or
propelled as an aerosol.
There are many types of dry-based pesticide formula-
tions prepared by blending solid active ingredients with
inert solids such as clay and sand. Some dry formulations
are prepared by absorbing liquid active ingredients with
solid carrier materials. S ome common dry-based formula-
tions are dusts, wettable powders, granules, treated seed,
and bait pellets and cubes.
TABLE 1.1982 PESTICIDE PRODUCTION IN THE
U.S.
Product
Insecticidal formulations
Inorganic compounds
Organic compounds
Chlorinated hydrocarbons
Carbamates
Organophosphates
Biological (botanical, bacterial)
Other organics
Herbicide formulations
Inorganic compounds'4
Organic compounds
Phenoxy
Metal organic
Triazine
Urea, amide, benzoic, other organics
Fungicide formulations
Inorganic compounds'14
Organic compounds
Other pesticidal formulations
Fumigants
Defoliants and desiccants
All other")
Quantity Produced
(tons per year)
54,300
206,750
18,900
78,400
73,150
11,250
25,050
N/A
541,750
101,400
9,450
97,250
1 333,150
N/A
56,250
17,450
3,500
N/A
wpata not available.
Source: 1982 Census of Manufacturers (USDC 1985).
Roughly 75% of all insecticides and herbicides, and
66% of all pesticides, are used on agricultural cropland.
The remainder are used in private homes and gardens and
on commercial and industrial property (Dillon 1981). The
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majority of pesticides are used on only a few major crops.
Currently, cotton, corn, and apples receive 67% of all
insecticides used in agriculture. Corn and soybeans re-
ceive 60% of the herbicides used, and 84% of the fungi-
cides are applied to fruits and vegetables. Only 48% of the
total U.S. cropland is treated with pesticides (Dahlston
1983).
Raw Materials
Pesticide formulation converts highly concentrated
pesticide active ingredients into convenient-to-use prod-
ucts at application concentrations packaged for the end-
user. As listed below, input raw materials include the
pesticide concentrates from pesticide manufacturing plants
as well as diluents and other chemical additives used in the
formulating process:
Active Agents
Organic/inorganic pesticides: insecticides, herbicides,
fungicides, other
Formulations and preparation materials
Dry formulations:
organic flours, sulfur, silicon oxide, lime, gypsum,
talc, pyrophyllite, bentonites, kaolins, attapulgite,
volcanic ash
Liquid formulations:
Solvents: xylenes, kerosenes, methyl isobutyl
ketone, amyl acetate, chlorinated solvents
Propellants: Carbon dioxide, nitrogen
Others: wetting and dispersing agents, masking
agents, deodorants, emulsifiers
Process Description
There are two major steps in the production of pesti-
cides for agricultural use. The first step is the manufactur-
ing of the pesticide concentrate from basic chemical feed-
stocks including petrochemicals, inorganic acids, gases
such as chlorine, and other chemicals. This produces the
pesticide, but not in a form which is ready for use. The
second major step, which is the focus of this report, is the
formulation and preparation of the pesticide for final use.
Block flow diagrams of the steps involved in formulating
liquid-based and dry-based pesticide products are pre-
sented in Figures 2 and 3 respectively.
The processes used to formulate pesticides generally
consist of blending operations where the active ingredients
are mixed with the inert ingredients previously mentioned.
Also, particle size reduction operations such as milling and
coating operations for granule and treated seed production
are used. Generally, chemical reactions do not occur.
Conventional blending equipment is used for pesti-
cide formulation. This equipment includes tanks equipped
with mixers for liquid formulations and blending mills for
solid formulations. Ancillary equipment includes storage
tanks, rotary kilns for curing solid formulations, pumps,
hoppers, and conveyors. Mixing tank capacities generally
vary from less than 100 gallons to several thousand gallons
for liquid formulations. Solids blending mill capacities are
usually on the order of several hundred pounds to three
tons.
Packaging of the pesticides formulations most com-
monly occurs at the same plant where the formulating is
performed. This avoids the cost of -transporting the high
volume, dilute formulations. Packaging generally in-
volves pouring liquid formulations into 55-gallon drums or
glass bottles for distribution. For solid formulations, the
material is usually gravity fed from hoppers into drums or
paper bags for distribution.
Waste Description
In order to present a meaningful discussion of source
reduction techniques that are applicable to the pesticide
formulating industry, the sources of waste generation in
this industrial segment must first be described. Pesticide
formulating generally involves the blending of concen-
trated active pesticide ingredients with inert diluents, and
the actual formulation process typically does not generate
wastes. However, related non-formulating activities do
generate hazardous wastes. These include decontamina-
tion of mixing and storage equipment, housekeeping op-
erations, and laboratory testing for quality assurance. The
wastes and their process origins are listed in Table 2.
Decontamination of liquid pesticide mixing and stor-
age equipment generates pesticide-contaminated waste-
water or solvent, depending upon whether the equipment is
used to formulate water or solvent-based pesticides. De-
contamination of the blending equipment is performed for
the same reasons as for the liquid pesticide formulating
equipment. The decontamination is commonly performed
using high pressure water hoses equipped with spray
nozzles, portable steam generators, or by running a batch
of solvent through the formulating equipment Floor
washing is typically performed using water hoses equipped
with spray nozzles. It may also involve the use of mops and
squeegees.
Reuseable active ingredient containers, such as 55-
gallon drums, are often decontaminated by triple rinsing.
They then can be sold or given to commercial recycling
firms. The decontamination is usually performed using a
high pressure water hose equipped with a spray nozzle or
a portable steam jenny.
Another source of liquid waste, unique to the packag-
ing of aerosol pesticides, is the hot water bath. This is
required by the U.S. Department of Transportation to
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Table 2. Pesticide Formulating Process Wastes
No. Waste Description Process Origin
1.
2.
3.
4.
5.
6.
7.
8.
Leftover raw
materials containers.
Pesticide dust from
air pollution .equipment
Scrubber water from
air pollution equipment
Volatile organic
compounds.
Off-specification
products and laboratory
analysis wastes.
Spills.
Waste sands or clays.
Waste rinse water.
Unloading of
materials into
blending tanks.
Unloading of dry pesticides
into blending tanks.
Unloading of dry pesticides
into blending tanks.
Air emissions from
storage tanks and open
processing equipment.
Formulating and
testing.
Composition
Bags, fiber drums, steel
drums with small amounts
of residual raw material.
Pesticide dust,
inert carrier dust
Pesticide-contaminated
wastewater and solvents.
Waste pesticide formulations.
Waste pesticide formulations.
Pesticide-contaminated sands or clays
Pesticide-contaminatedwastewater.
Accidental discharge.
Equipment cleaning.
Equipment cleaning, area
washdown, hot water bath
for leak checking.
Equipment cleaning.
Laundering of protective
clothing.
Pesticide spillage and
fallout of pesticide dust in
open process areas.
Pesticide-contaminated solvents.1
Pesticide-contaminated wastewaters.
Waste solvent.
Laundry waste water.
Pesticide-contaminated wastewaters.
Stormwater runoff.
'RCRA Codes F002 and F003.
check for leaking cans (49B CFR Part 178). Each filled
aerosol can is immersed in the bath where bubbles can be
seen if a container has not been sealed. Water from the hot
water baths js discharged routinely to prevent turbidity.
Decontamination of the solid-based pesticide blend-
ing mills generates solid diluent contaminated with pesti-
cides. The diluent typically consists of clay for dust mills
and sand for granule mills.
Decontamination is performed in between batches of
different types of formulations to prevent cross contamina-
tion of the subsequent batch. Decontamination is also
performed prior to taking the equipment out of service for
maintenance.
Most dust/granule blending mills are equipped with
vacuum systems to collect fugitive dust, this provides for
worker safety, for control of product loss, and for house-
keeping in the process area. Some vacuum systems are
dedicated to certain mills to facilitate reuse of the dust.
Other systems are used to collect dust from a number of
areas,
Conventional process technology unit operations are
commonly used to treat wastewater from pesticide and
related industries. Table 3 below presents a list of the unit
operations commonly used to treat pesticide industry
wastewaters. However, this list does not include all the
applicable treatment unit operations for the many varied
waste streams in the pestticide formulating industry. An
appropriate combination of unit operations can remove or
destroy pesticides and other toxic pollutants to levels
which allow reuse of the treated wastewater, discharge to
publicly owned treatment works (POTW), or direct dis-
charge to surface waters.
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Table 3. Unit Operations for Treatment of Pesticide
Formulating Wastewaters
Filtration
Precipitation
Incineration
Coagulation/flocculation
Oil/water separation
Biological treatment
Flotation
Activated carbon adsorption
Evaporation
Hydrolysis
Stabilization
Chemical oxidation
Equalization
Resin adsorption
Decantation
Steam/air stripping
Source: ESE and TRW, 1983.
References
Atkins, P.R., 1972. The pesticide manufacturing industry-
currentwastetreatmentanddisposalpractices.'Texas
University, EPA-12020-FYE-01/72. Washington,
D.C.: U.S. Environmental Protection Agency.
Dahlston, D.L. 1983. Pesticides in an era of IPM.
Environment. 25(10):45-54.
Dillon.AP.ed. 1981. Pesticidedisposalanddetoxiftcation
processes and techniques. New Jersey: NoyesData
Corp.
Environmental Science & Engineering, Inc., and TRW
1983. Task2 InterimRepon - Wastewater Treatment
Technology Evaluation and Application Study.
Prepared for U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina.
Environmental Science & Engineering, Inc.,
Gainesville, Florida and TRW, Research Triangle
Park, North Carolina.
Gruber, G.I., 1975. Assessment of industrial hazardous.
waste practices, organic chemicals, pesticides and
explosives industries. TRW Systems Group. EPA-
530-SW-l 18c. Washington, D.C.: U.S.Environmental
Protection Agency.
Hui|singh,D., L.Martin and H.Hilge. 1985. Provenprofit
front-pollution prevention. Washington, D.C.: The
Institute for Local Self-reliance.
Kryeger,R.,ed. 1983. Treatment and disposal of pesticide
wastes. In: ACS Symposium Series 259.
LWVM, 1985. Leagueof Women Voters of Massachusetts.
Waste reduction, The untold story. Conference at the
National Academy of Sciences, Conference Center on
June 19-21. Woods Hole, Mass.: Conferencematerials.
Metcalf, R.L., 1981. Insect control technology. In Kirk-
Othmer Encyclopedia of Chemical Technology. 3rd
ed.,Vo. 13. New York, NY.: Wiley.
National Agricultural Chemicals Association. 198 la.
Mimeograph: "Good warehousing practices for
agricultural chemicals" and"Good workplace practices
for the handling and storage of pesticides."
Parsons, T.B., 1977. Industrial process profiles for
environmental use. Chapter 8: pesticide industry.
Radian Corp. EPA-600-2-77-0234. Research Triangle
Park, N.C.: U.S. Environmental Protection Agency.
USDC. 1985. U.S. Department of Commerce, Bureau of
the Census. Agricultural Chemicals. In: 1982 Census
of Manufacturers. MC& 1-1-2886. Washington, D.C.:
U.S. Government Printing Office.
USEPA. 1976. U.S. Environmental Protection Agency,
OfficeofWaterandWasteManagement Development
document for final effluent limitation guidelines for
the pesticide chemical manufacturing industry.
EPA-440-l-73-060d. Washington, D.C.: U.S.
Environmental Protection Agency.
Versar, Inc. and Jacobs Engineering Group Inc. 1986.
Waste MinimizationIssues and Options, Volume
III. PB87-114377. Prepared for U.S. Environmental
Protection Agency, Washington, D.C.
10
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SECTION 3
WASTE MINIMIZATION OPTIONS FOR PESTICIDE FORMULATORS
. This section discusses recommended waste minimi-
zation methods forpesticide formulating operations. These
methods come from accounts published in the open litera-
ture and through industry contacts. The primary waste
streams associated with pesticide formulation are listed in
Table 4 along with recommended control methods. In
order of occurrence at a facility, the waste streams are
equipmentcleaningwastes; spills and area washdowns; off
spec product; empty bags and drums; air emissions and
wastes from air emission control equipment; wastewater
associated with laundering protective clothing; water used
for aerosol leak testing, and stormwater runoff.
Waste Minimizations Options
The waste minimization methods listed in Table 4 can
be classified generally as source reduction, which can be
achieved through material substitution, process or equip-
ment modification, or better operating practices; or as
recycling. Source reduction through product substitution
is not an easily implemented procedure. This is because of
the high level of effort and cost associated with registering
a new pesticide with EPA as required by the Federal
Insecticide, Fungicide, and Rodenticide Act (FEFRA).
Registration of a new pesticide is required before it may be
bought, solid, distributed, or otherwise handled. Pesticide
registration involves the development and submission of a
health and ecological risk database to EPA for review.
Consequently, the waste minimization assessments of
pesticide formulating firms focused on source reduction
that relies on good operating practices and process modi-
fications.
Better operating practices are procedural or institu-
tional policies that result in a reduction of waste. They
include:
Waste stream segregation
Personnel practices
- Management initiatives
- Employee training
- Employee incentives
Procedural measures
- Documentation
- Material handling and storage
- Material tracking and inventory control
- Scheduling
Many of these measures are used in industry to pro-
mote operational efficiency. In addition, they can often be
implemented at little or no cost to the facility. When one
considers the effects of reduced waste, increased effi-
ciency, and little or no implementation cost, good operat-
ing practices usually provide a very high return on invest-
ment.
EQUIPMENT CLEANING WASTES
One of the most concentrated waste produced at pes-
ticide formulation plants results from the cleaning of
process equipment. As noted earlier, a typical formulation
plant produces a variety of different pesticides, all on a
batch basis. Between batches, the mixing tanks and all
other equipment exposed to the pesticide must be cleaned
to avoid contamination between different products.
If powders or other "dry" pesticides are formulated,
then cleaning is accomplished using a dry, inert material,
such as clay or sand. These inert materials are passed
through the system where they pick up traces of pesticide
dusts. Many facilities save this flush material and use it in
the next production run of the same product.
In the formulating of liquid solvent-based pesticides,
cleaning is normally performed by rinsing or flushing the
equipment with the same type of solvent used in the
formulation followedbya"bail-out1'andrinse using water.
Waste solvents are usually saved and reused in the next
batch of similar product while the wastewater is disposed
of as hazardous waste. For water-based pesticide formu-
lations, only water is employed for cleaning. The follow-
ing waste reduction methods are noted:
Maximize production runs. Production runs of a given
formulation should be scheduled together so as to reduce
the need for equipment cleaning between batches. Consid-
eration should also be given to the potential for scheduling
families of products in sequence; while some cleanup is
still needed beween batches, it can be minimized.
Store and reuse cleaning wastes. Based on the results
of several audits performed at pesticide formulators (Calif.
DHS 1987,USEPA 1976) many facilities collect cleaning
dusts and solvents for reuse as make-up in the next compat-
ible formulation. Rinse water has also been saved and
reused when the facility produces water-based formula-
tions.
11
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Table 4. Waste Minimization Methods for the Pesticide Formulating Industry
Waste Stream
Equipment Cleaning Wastes
Spills and Area Washdowns
Off-Specification Products
Containers
Air Emissions
Miscellaneous Wastewater Streams
Waste Minimization Methods
Maximize production runs.
Store and reuse cleaning wastes:
Use of wiper blades and squeegees.
Use of low volume high efficiency
cleaning.
Use of plastic or foam "pigs".
Use of dedicated vacuum system.
Use of dry cleaning methods.
Use of recycled water for initial
cleanup.
Actively involved supervision.
Strict quality control and automation.
Reformulation of off-spec batches.
Return containers to supplier.
Triple rinse containers.
Drums with liners versus plastic
drums or bags.
Solid waste segregation.
Control bulk storage air emissions.
Dedicated dust collection system.
Automatic enclosed cut-in hoppers.
Pave high spillage areas.
Wastewater treatment*
This method can only be viewed as waste minimization if it allows the continued use of spent cleaning
solutions.
If it is not practical to use the waste rinse water as
make-up during a later formulation, it can be reused as
rinse water. In those instances where more than one rinse
is needed to clean the equipment, the first rinse can be
performed using old rinse water from a previous formula-
tion. This rinse will remove the bulk of the pesticide
residue from the equipment, then a second rinse with fresh
water can be used to complete the cleaning.
Use of wiper blades and squeegees. After a mix tank
has been drained, someresidual formulation remains cling-
ing to the walk. To remove this clingage and to reduce the
subsequentlevel of cleaning solvent/water contamination,
mechanical wipers can be employed. For facilities where
tanks are wiped with rags, use of wipers would reduce or
eliminate waste rags. Use of wipers and squeegees usually
requires manual labor; hence, the extent of waste reduction
depends on the operator. Since the benefits will be offset
by increased labor, mechanization/automation should be
considered. Mixers designed with automatic wall scrapers
are available (Weismantel and Guggilam 1985). These
mixers can be used With any cylindrical mix tank (flat or
conical bottom). . ;
Use of low-volume high efficiency cleaning systems.
High pressure spray nozzles can be used in place of the
standard rinsing hoses. According to astudy of equipment
cleaning in the paint industry (USEPA 1979), water con-
sumption can be cut by 80-90% when high pressure rinsing
systems are used. Other types of low-volume high effi-
ciency cleaning systems include water knifes and portable
steam cleaners. Steam cleaners are a viable alternative to
12
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the "boil-out" procedure whereby a tank is filled with water
and then heated to effect cleaning.
Use of a plastic or foam "pig" to clean lines. Many
industries use "pigs" (fluid propelled pipe inserts) to clean
piping. The "pig" is forced through the pipe from the
mixing tank to the filling machine hopper. The "pig"
pushes ahead paint left clinging to the walls of the pipe.
This, in turn, increases yield and reduces the subsequent
degree of pipe cleaning required. Inert gas is used to propel
the "pig" and minimize drying of paint inside the pipe. The
equipment (launcher and catcher) must be carefully de-
signed so as to prevent spills, sprays, and potential injuries,
and the piping runs must be free of obstructions so that the
"pig" does not become stuck or lost in the system.
Self-draining piping design. Proper piping design in
any liquid processing operation should be self draining and
free of pockets.
SPILLS AND AREA WASHDOWNS
The cleanup of spills and area washdowns often con-
tributes significantly to the total waste volume produced at
formulation plants. Spills are caused by the accidental
discharge of pesticides during transfer operations or from
equipment failures such as leaks. Area washdowns with
water hoses are performed routinely at some formulation
plants, and are necessary in the event of contamination of
the working area (USEPA 1976). Waste reduction meth-
ods available for these wastes include:
Use of recycled water for initial cleanup.
Use of impervious coatings on floors.
Use of dedicated vacuum system. For facilities pro-
ducing dry formulations, spilled powders are usually
cleanedup by vacuuming. The vacuum system employed
ties in to the facility's main dust collection system where
all collected dusts and powders are removed from the air
stream by a baghouse. Recovered dust cannot be reused
due to cross contamination and the material must be
disposed of as hazardous waste. If a dedicated vacuum
system were available for collecting spilled material, most
(if not all) of the recovered material could be returned
directly to the process for use.
Use of dry cleanup methods for liquid spills. Rather
than cleaning spills with water and producing a hazardous
waste, many formulating plants use dry absorbents for spill
cleanups. This greatly decreases the waste volume associ-
ated with the cleanup. In addition, floor sweeping, mop-
ping and use of squeegees can collect spills for product
reformulation. Such practice was reportedly performed by
Chevron Chemical Co. to reduce their waste generation
volume (LWVM1985) and has been mentioned in several
recent studies (Calif. DHS 1987 and USEPA 1976).
OFF-SPECIFICATION PRODUCTS
Off-specification batches of pesticide formulations
are produced as a result of poor process control and
operation. Ideally, this waste source could be eliminated
totally by making use of the following source control
techniques:
Strict quality control and process automation. The
formulation of pesticides is a relatively simple process.
Nevertheless, process automation and control during for-
mulation ensures repeatable high quality products and
avoids generation of off-spec batches due to operator error.
Reformulation of off-specification batches. If a batch
of off-specification pesticide is produced, it should be
reformulated to an acceptable quality rather than discarded
as a waste.
CONTAINERS
Pesticide ingredient containers can be cleaned for
reuse or nonhazardous waste disposal. The,se include 30-
and 55-gallon drums. Many pesticide formulating plants
use the uncleaned empty drums to store and dispose of
other hazardous wastes such as pesticide contaminated
dusts and empty paper bags and cartons. Generally, the
following options exist for minimizing container waste:
Return containers to the pesticide supplier for refill-
ing with the same pesticide. While this option can be very
effective and economical, few suppliers will accept used
drums from formulators. Instead of drums, formulators
should investigate the feasibility of receiving raw materi-
als in returnable bulk containers. In the paint industry,
where users of the formulation often return the empty
container to the forrnulator for cleaning and disposal, use
of recyclable "Tote bins" is becoming more common
(Calif. DHS 1987). The forrnulator is able to clean the con-
tainer, use the cleaning waste in the formulation, and fill the
container with a new batch that goes back to the user. FMC
Corp. in Fresno, CA has developed a reusable container
called "U-Tum" for their pesticide formulations (Lewis
1988). This stainless steel container is equipped for use in
"closed" use systems and is sealed to preclude contamina-
tion both before and after use. Pesticide formulators
should investigate the feasibility of requesting these deliv-
ery methods from their raw material suppliers.
Triple rinse and 1) dispose of drums as non-hazard-
ous; 2) sell drums to a scrap dealer or recycling firm
(approved by the Department of Transportation) for re-
conditioning; or 3) recondition drums on-site. Triple rins-
ing of the drums is usually performed using a water spray
or more effectively with steam. The volume of wastewater
generated by the triple rinsing typically varies from about
10 to 20 gallons per drum.
13
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Following triple rinsing, the drums are subject to
firing to about 1200°C, sandblasting, and repainting.
(Reconditioned drums may be reused for the same chemi-
cal class of pesticides previously contained and if recondi-
tioned by a DOT-approved facility. However, there are ho
regulations covering reconditioning of smaller (1- to 2-
gallon) containers, so this is not at present permitted.). By
regulation (40 CFR 162.10), reconditioned containers
may not be used to contain food, animal feed, beverages,
drugs, or cosmetics. ,
The feasibility of recycling usedpesticide drums varies
from plant to plant based on site-specific conditions. The
following factors will influence drum recycling feasibility:
~ cost of transporting and disposing of drums at a
Class I landfill;
cost of triple rinsing, transporting, and disposing of
drums at a Class HI landfill, including treatment/
disposal cost of rinse water;
income to be realized by sale of triple-rinsed drums
to scrap dealer or drum recycling firm;
and potential savings that may be realized by on-site
reconditioning, and reuse or sale of reconditioned
drums.
Use of drums with plastic liners in place of plastic
drums or paper bags.
The use of plastic drums presents many difficult
disposal problems. It is reported (Lewis 1988) that triple
rinsing is often ineffective at removing traces of pesticide
from the container. The plastic may absorb the pesticide
and will always be hazardous. Another problem is that
plastic drums have a "memory;" they retain their shape
when crushed. This creates a large volume low bulk
wastestream that is very expensive to dispose of. One way
to reduce the volume of waste is to use drums lined with a
disposable liner that can be removed when the drum is
empty. Disposal of the plastic liner would be much easier
than disposing of the drum and it eliminates the need for
drum cleaning.
Solid waste segregation. The most effective way of -
reducing hazardous waste associated with bags and pack-
ages (or any other waste stream) is to segregate the hazard-
ous materials from the non-hazardous materials. Eco-
nomic benefits include reduced disposal costs and the
potential sale of non-hazardous scrap paper to a recycler..
Empty packages that contain hazardous materials should
be placed into plastic bags (so as to reduce personnel
exposure and eliminate dusting) and should be stored in a
special container to await collection.
AIR EMISSIONS AND WASTES FROM AIR
EMISSION CONTROL EQUIPMENT
The two major types of air emissions that occur in the
pesticide formulating process are volatile organic com-
pounds and pesticide dusts. Volatile organics may be
emitted from the bulk storage of solvents and from their use
in open tanks during formulation. Dusts generated during
handling, grinding, and other formulation operations are a
potential waste source. It is common practice to install dust
collection equipment, such as hoods served by a baghouse
filter, on all dust-generating operations. Some potentially
effective waste reduction methods include:
Control bulk storage air emissions. Many methods are
available for reducing the amount of emissions resulting
from fixed roof storage tanks. Some of these methods
include use of conservation vents, conversion to floating
roof, use of nitrogen blanketing to suppress emissions and
reduce material oxidation, use of refrigerated condensers,
use of lean-oil or carbon absorbers, or use of vapor equili-
bration lines. When dealing with volatile materials, em-
ploymentof one or more of these methods can result in cost
savings to the facility by reducing raw material losses and
improve compliance with local air quality requirements.
Dedicated dust collection systems. At Daly-Herring
Co., in Kinston, N.C., dust streams from several different
production areas were handled by a single baghouse. Since
all of the streams were mixed, none of the waste could be
recycled to the process that generated them. By installing
separate dedicated baghouses for each production line, all
of the collected pesticide dust could be recycled (Huisingh
and Martin 1985).
At FMC Corp. in Fresno, CA., common dust collec-
tors were used by multiple production systems. Due to the
cross contamination of materials, recycling was impos-
sible. To promote recycling, thecompany compartmental-
ized the dust collectors with each compartment serving a
single source. All collected materials are analyzed for
cross contamination and if none exists, they are reused in
the succeeding product batch. Other work involved the
installation of self-contained dust collectors at each inlet
hopper dump station so that captured dust can be returned
to the system (Lewis 1988). Similar work was discussed in
the facility audits (Calif. DHS 1987).
Use of automatic enclosed cut-in hoppers. The man-
ual opening and emptying of pesticide dust containers
leads to the generation of dust which must be collected.
One way to reduce the amount of dust generated is by use
of an enclosed cut-in hopper which allows the bags to be
opened and emptied while avoiding the release of dust.
14
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MISCELLANEOUS WASTE STREAMS
Waste streams included in this section include waste-
water associated with laundering of protective clothing,
water used for aerosol leak testing, stormwater runoff and
laboratory wastes. Control measures include:
Wastewater reuse after treatment.
Paving of high spillage areas. For facilities located
outdoors, paving can be an effective means of reducing
rainwater contamination by allowing therecovery of spilled
materials.
Proper purchasing of chemicals and reagents for lab
use. Purchase quantities of specialty items that are seldon
used in the smallest available amount. This helps to reduce
waste by insuring that the material will more likely be
consumed before its shelf life expires. Purchasing agents
should factor in the cost of disposal before deciding to
purchase items in large quantities just because the per unit
purchase price is less.
Use of micro-scale glassware. Many tests can be
redesigned to utilize micro-scale glassware so as to reduce
the generation of waste. Micro-scale testing volumes to
range from 1 to 10 ml as compared to conventional
testing which may employ 50 to 100 ml.
References
Calif. DHS. 1987- Waste audit study: Pesticide formulating
industry. Report to California Department of Health
Services, Alternative Technology Section. Prepared
by Environmental Science and Engineering, Inc.
Sacramento, Calif. November 1987.
Huisingh, D., L. Martin and H. Hilge. 1985. Proven profit
from pollution prevention. Washington, D.C.: The
Institute for Local Self-Reliahce.
Lewis, D.A. 1988. Waste minimization in the pesticide
formulation industry. Draft report by FMC
Corporation, Fresno, Calif. August 1988. 20 pp.
USEPA. 1979. U.S. Environmental Protection Agency,
OfficeofWaterandWaste Management. Development
documentforproposedeffluent guidelines, new source
performance standards, and pretreatment standard
for the paint formulation point source category. EPA-
440-1-79-0496. Washington, D.C.: U.S.
Environmenal Protection Agency.
USEPA. 1976.' U.S. Environmental Protection Agency,
- OfficeofWaterandWaste Management. Development
document for final effluent limitation guidelines for
the pesticide chemical manufacturing industry. EPA-
440-1-73-060d. Washington, D.C.: U.S.
Environmental Protection Agency.
LWVM. 1985. LeagueofWomenVotersofMassachusetts.
Waste reduction, the untold story. Conference, Woods
. Hole, Mass., June 19-21,1985. Conference materials..
Weismantel,G.,andS.Guggilam. 1984. Mixing and size
reduction (a chemical engineering special advertising
section). Chem. Eng. 92(13):71-109.
. 15
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SECTION 4
GUIDELINES FOR USING THE
WASTE MINIMIZATION ASSESSMENT WORKSHEETS
Waste minimization assessments were conducted at
several pesticide formulating plants. The assessments
were used to develop the waste minimization worksheets
that are provided in the following section.
A comprehensive waste minimization assessment
includes a planning and organizational step, an assessment
step that includes gathering background data and informa-
tion, a feasibility study on specific waste minimization
options, and an implementation phase.
The worksheets provided in this section are intended
to assist pesticide formulating firms in systematically
evaluating waste generating processes and in identifying
waste minimization opportunities. These worksheets in-
clude only the waste minimization assessment phase of the
procedure described in theEPA Manual/or Waste Minimi-
zation Opportunity Assessments. For a full description of
waste minimization assessment procedures, refer to the
EPA Manual.
Table 5 lists the worksheets that are provided in this
section.
Table 5. List of Waste Minimization Assessment Worksheets
Number Title
1. Waste Sources
2. Waste Minimization:
Material Handling
3. Waste Minimization:
Material Handling
4. Waste Minimization:
Material Handling
5. Option Generation:
Material Handling
6. Waste Minimization:
Material Substitution/
Dry Blending Operations
7. Waste Minimization:
Liquid Blending Operations
8. Option Generation:
Material Substitution/
Blending Operations
9. Waste Minimization:
Filtering and Filling
10. Option Generation:
Filtering and Filling
11. Waste Minimization:
Good Operating Practices
12. Option Generation:
Good Operating Practices
13. Waste Minimization:
Reuse and Recovery .,
Description
Typical wastes generated at pesticide formulating plants.
Questionnaire on general material handling
techniques.
Questionnaire on procedures used for bulk liquid
handling.
Questionnaire on procedures used for handling
drums, containers and packages.
Waste minimization options for material handling
operations.
Questionnaire on material substitution and dry
blending operations.
Questionnaire on liquid blending operations.
Waste minimization options for material
substitution and modification of blending
operations.
Questionnaire on filtering and filling.
Waste minimization options for filtering and filling.
Questionnaire on use of good operating
practices.
Waste minimization options that are good
operating practices.
Questionnaire on opportunities for reuse and
recovery of wastes.
16
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Firm Waste Minimization Assessment Prepared By
Site , Checked By
Date prof NO Sheet of Page of
<~ET WASTE SOURCES
Waste Source: Material Handling
Off-spec materials . ,
Obsolete raw materials
Obsolete products
Spills & leaks (liquids)
Spills (powders)
Empty container cleaning
Container disposal (metal) '
Container disposal (paper) , ,
Pipeline/tank drainage
Laboratory wastes
Evaporative losses
Other
' . ' ' ' i
Waste Source: Process Operations
Tank cleaning
Container cleaning , ,
Mill cleaning
Mixer cleaning
Filling equipment cleaning
Baghouse fines ,
Laundry wastewater
Aerosol container water bath
Stormwater runoff
Contaminated cooling tower blowdown
Other
-
Significance at Plant
Low
Medium
High
17
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Firm
Site
Date
Wast* Minimization Assessment
Proj..No.
Prepared By
Checked By .
Sheet of Page of
WORKSHEET
WASTE MINIMIZATION:
Material Handling
A. GENERAL HANDLING TECHNIQUES
Are all raw materials tested for quality before being accepted from suppliers?
Describe safeguards to prevent the use of materials that may generate off-spec product:.
3 yes
lino
Is obsolete raw material returned to the supplier?
Is inventory used in first-in first-out order?
Is the inventory system computerized?
Does the current inventory control system adequately prevent waste generation?
P yes
Dyes
3 yes
iU yes
3 no
I] no
Uno
What information does the system track?.
Is there a formal personnel training program on raw material handling, spill prevention, U yes H no
proper storage techniques, and waste handling procedures?
Does the program include information on the safe handling of the types of drums, containers D yes H no
and packages received?
How often is training given and by whom?
Is dust generated in the storage area during the handling of raw materials?
If yes, is there a dedicated dust recovery system in place?
Are methods employed to suppress dust or capture and recycle dust?
Explain:
P yes
Pyes
P yes
HI no
ZIno
Gno
18
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Firm
Site
Date
Waste Minimization Assessment
Proj. No.
Prepared By
Checked By
Sheet of Page of
WORKSHEET
WASTE MINIMIZATION:
Material Handling
B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdown/alarms D Secondary containment D
Flow totalizers with cutoff D Other D
Describe the system: ; '. '.
Are air emissions from solvent storage tanks controlled by means of:
Conservation vents D Absorber/Condenser D
Nitrogen blanketing D Other vapor loss control system CD
Describe the system:
Are all storage tanks routinely monitored for leaks? !f yes, describe procedure and monitoring frequency for above-
ground/vaulted tanks: __!
Underground tanks:.
How are the liquids in these tanks dispensed to the users? (i.e., in small containers or hard piped.)_
What measures are employed to prevent the spillage of liquids being dispensed?.
Are pipes cleaned regularly? Also discuss the way pipes are cleaned and how the resulting waste is handled:
When a spill of liquid occurs in the facility, what cleanup methods are employed (e.g., wet or dry)? Also discuss the
way in which the resulting wastes are handled:
Would different cleaning methods allow for direct reuse or recycling of the waste? (explain):.
19
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Firm
lite
Date
Wast* Minimization Assessment
Proj. No.
Prepared By
Checked By '
Sheet __ of __ Page of
WORKSHEET
WASTE MINIMIZATION:
Material Substitution
Blending Operations
A. MATERIAL SUBSTITUTION
Are any of the formulation and preparation materials used in the pesticides considered
hazardous (e.g., chlorinated solvents)?
If so, can other non-hazardous materials substitute for the hazardous materials?
Describe results of any substitution attemptsL.
Dyes
3 yes
3 no
ID no
B. DRY BLENDING
Are dust suppression/collection systems employed during dry pesticide formulation? CD yes "I no
Is this dust collected and recycled or reused? CD yes U no
Would the installation of a dedicated baghouse or other type of dust collection system
allow for reuse? - CD yes 3 no
Explain how dusts are handled and the potential for reuse: .
Are the sand and clay diluents that are used to flush the granule and dust mills collected,
tested for reuse potential and re-used to flush the mills? CD yes
Describe results of attempts to reuse diluents:
Describe the results of attempts to use smaller volumes of diluent, in repeated flushing.:.
Dno
Is diluent flushing done on a once-through basis between batches of pesticides? Dyes CD no
Has repeated diluent flushing with a smaller volume of diluent been attempted, to reduce
overall diluent use? Dyes CD no
22
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Firm Wast* Minimization Assessment p
Site ' C
Date pmj NQ S
WORKSHEET WASTE MINIMIZATION:
7 Blending Operations
C. LIQUID BLENDING
What methods are used to clean mixing tanks?:
Solvent-Based Water-Based
Dry Clean-up (rags) G G
Sand/Dust Cleaning G G
Solvent Cleaning Q G -
Water Cleaning Q G
Caustic Cleaning G ' Q .
Solvent Rinse Q G
Water Rinse Q G
Explain how these wastes are handled and the potential tor their reuse-
reparedBy
hacked By
heet of Page of
To reduce the generation of waste, has the facility attempted to: G yes U no
Employ vapor recovery systems to reduce solvent air emissions? G yes I] no
Equip tanks with wipers to reduce clingage? G yes m no
Employ pressure washers to reduce cleaning solution usage? G yes 3 no
Reuse cleaning solutions for primary cleaning or as part of a compatible formulation ? G yes HI no
Equip hoses with spray nozzles to reduce water used for floor washing? G yes HI no
Collect and reuse rinse water? G yes G no
Drain or pig lines between blending equipment rather than flush with solvent or water? G yes U no
Dedicate equipment to reduce the need for cleaning? G yes D no
Use some of the solvent or water that should be added to the formulation to clean the
preceding equipment before adding to the mix tank? G yes ~D no
Segregate wastes so that their reuse potential is increased? . . . G yes G no
Discuss the results of methods employed or attempted:
23
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Firm Waste Minimization Assessment Prepared By
Si'ft Proc Unrt/Opnr
Checked Bv
Data pr0j NO Sheet of Paoe of
WORKSHEET OPTION GENERATION:
o Material Substitution
w Blending Operations
Meeting format (e.g., bralnstormlng, nominal group technique
Meeting Coordinator
.
Meeting Participants
Suggested Waste Minimization Options
A. Substitution/Reformulation Techniques
Solvent Substitution
Product Reformulation
Other Raw Material Substitution
B. Dry Blending
Dust Suppression/Collection
Dedicate Baghouse
Use Less Cleaning Media
Test for Reuse Potential
C. Liquid Blondlng
Vapor Recovery
Tank Wipers '
Pressure Washers
Reuse Cleaning Solutions
Spray Nozzles on Hoses
Mops and Squeegees
Reuse Rinsewaler
Pig or Drain Lines
Dedicate Equipment
Clean with Part of Batch
Segregate Wastes for Reuse
Currently
Done Y/N?
Rationale/Remarks on Option
, 24
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Firm Waste Mlnlmlzat
Site
Date .,. ... Proj. No,
WORKSHEET WASJE M,N
9 Filtering
Ion Assessment Prepared By
Checked By
Sheet of Page of
IMIZATION:
& Filling
FILTERING & FILLING
Is the dust generated during the packaging of dry formulations collected? D yes G no
If yes, can the material be recycled/reused? G yes G no
Diswjsa-
Are any of the filter units dedicated to a particular product 1
Would increased dedication reduce the heed for filter replat
Has the facility attempted to replace disposable cartridge f
bags or metal mesh?
What type of reusable filter was tried and what were the res
ine? G yes G no
;ement or cleaning? 3 yes G no
tiers with reusable filters such as
G yes G no
nits-
How are the wastes from spent filter cartridges or reusable
filter cleaning handled?
Are any of the filling units dedicated to a particular product 1
Would increased dedication reduce the need for cleaning?
Describe the filling unit cleaning procedures and how clean!
ine? D yes G no
G yes G no
ng wastes are handled
25
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Firm Waste Minimization Assessment Preoared Bv
Site prft£ Unit/Dper
Checked Bv
nato Pmj NO Sheet of Page of
WORKSHEET OPTION GENERATION:
1 0 Filtering & Filling
", '.
Meeting format (e.g., bralnstorming, nominal group technique;
Meeting Coordinator
. '
flAoeflpg participants
Suggested Waste Minimization Options
Filtering & Filling Techniques
Dedicate Filter Units
Use Wire Screen Filters
Use Bags, Not Cartridges
Reuse Filter Bags
Dedicate Filling Units
Currently
Done Y/N?
Rationale/Remarks on Option
26
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Firm
Site
Date
Wast* Minimization Assessment
Proj. No.
Prepared By
Checked By ,:
Sheet of '___ Page of
WORKSHEET
11
WASTE MINIMIZATION:
Good Operating Practices
A. PRODUCTION SCHEDULING TECHNIQUES
Is the production schedule varied to decrease waste generation? (For example, do you attempt to increase size of
production runs and minimize cleaning by accumulating orders or production for inventory?)
Describe: ; !
Does the production include sequential formulations that do not require cleaning between batches?
If yes, indicate results: .
Are there any other attempts at eliminating cleanup steps between subsequent batches? If yes, results:
B. AVOIDING OFF-SPEC PRODUCTS
Is the batch formulation attempted in the lab before large scale production? G yes G no.
Are laboratory QA/QC procedures performed on a regular basis? G yes Z3 no.
C. GOOD OPERATING PRACTICES
Are plant material balances routinely performed? G yes G no
Are they performed for each material of concern (e.g. solvent) separately? G yes G no
Are records kept of individual wastes with their sources of origin and eventual disposal? G yes G no
(This can aid in pinpointing large waste streams and focus reuse efforts.)
Are the operators provided with detailed operating manuals or instruction sets? G yes G no
Are all operator job functions well defined? G yes Gno
Are regularly scheduled training programs offered to operators? G yes G no
Are there employee incentive programs related to waste minimization? G yes G no
Does the facility have an established waste minimization program in place? G yes G no
If yes, is a specific person assigned to oversee the success of the program? G yes G no
Discuss goals of the program and results: ,
Has a waste minimization assessment been performed at the facility in the past? If yes, discuss:.
27
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Firm Waste Minimization AsMumaht preoarad Bv
Site Proc. Unrt/Oper.
Checked Bv
Date Proj. No. Sheet of Page of
WORKSHEET OPTION GENERATION:
I *£ Good Operating Practices
Moating format (e.g., bralnstormlng, nominal group technique
Meeting Coordinator
»
Meeting Participants
Suggested Waste Minimization Options
A. Production Scheduling Techniques
Increase Size of Production Run
Sequential Formulating
Avoid Unnecessary Cleaning
Maximize Equipment Dedication
B. Avoiding Off-Spec Products
Test Batch Formulation in Lab
Regular QA'QC
C. Good Operating Practices
Perform Material Balances
Keep Records of Waste Sources & Disposition
Waste/Materials Documentation
Provide Operating Manuals/Instructions
Employee Training
Increased Supervision
Provide Employed Incentives
Increase Plant Sanitation
Establish Waste Minimization Policy
Set Goals for Source Reduction
Set Goals for Recycling
Conduct Annual Assessments
Currently
DoneY/N?
Rationale/Remarks on Option
',-..'
28
,
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Firm Waste Minimization Assessment
Site
Date Prnj Wn
WORKSHEET WASTE MINIMIZATION:
1 0 Reuse and Recovery
Prepared By
Checked Bv
Sheet of Page
A. SEGREGATION
Segregation of wastes reduces the amount of unknown material in waste and improves
prospects for reuse & recovery.
Are different solvent wastes due to equipment clean-up segregated? n yes
Are aqueous wastes from equipment clean-up segregated from solvent wastes? Q yes
Are spent alkaline solutions segregated from the rinse water streams? O yes
If no, explain:
of
Dno
Dno
Dno
B. ON-SITE RECOVERY
On-site recovery of solvents by distillation is economically feasible for as little as 8 gallons
of solvent waste per day.
Has on-site distillation of the spent solvent ever been attempted? n yes
If yes, is distillation still being performed? Q yes
If no. explain:
Dno
D no
C. CONSOLIDATION/REUSE
Are many different solvents are used for cleaning? QJ ves
If too many small-volume solvent waste streams are generated to justify on-site distillation,
can the solvent used for equipment cleaning be standardized? n yes
Is spent cleaning solvent reused? Q yes
Are there any attempts at making the rinse solvent part of a batch formulation (rework)? n yes
Are any attempts made to blend various waste streams to produce marketable products? n yes
Are spills collected and reworked? Q yes
Describe which measures were successful:
D no
a no
O no
Ono
ano
Dno
Is your solvent waste segregated from other wastes? G yes
Has off-site reuse of wastes through Waste Exchange services been considered? Dyes
Or reuse through commercial brokerage firms? O yes
If yes, results:
D no
D no
Dno
29
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APPENDIX A
PESTICIDE FORMULATING FACILITY ASSESSMENTS
CASE STUDIES OF PLANTS A, B AND C
CASE STUDIES OF PESTICIDE FORMULATING
FACILITIES
In 1986 the California Department of Health Services
commissioned a waste minimization study (DHS 1987) of
three pesticide formulating plants. The objectives of the
waste minimization assessments were to:
Gathersite-specificinformationconcermngthegen-
eration, handling, storage, treatment, and disposal
of hazardous waste;
* Evaluation existing waste reduction practices;
Develop recommendations for waste reduction
through source control, treatment, and recycling
techniques; and
Assess costs/benefits of existing and recommended
waste reduction techniques.
In addition, the results of the waste assessments were
used to prepare waste minimization assessment work-
sheets to be completed by other pesticide formulators in a
self-audit process.
The first steps in conducting the assessments were the
selection of the pesticide formulating plants, and contact-
ing the plants to solicit voluntary participation in the audit
study. Plant selection emphasized small businesses which
generally lack the financial and/or internal technical re-
sources to perform a waste reduction audit. One relatively
large plant was also selected for study because itoffered the
opportunity to evaluate a wide variety of pesticide formu-
lating operations, as well as a number of in-place waste re-
duction measures. A total of three plants was audited.
This Appendix section presents both the results of the
assessments of the plants here identified as A, B and C and
the potentially useful waste minimization options identi-
fied through the assessments. Also included are the prac-
tices already in use at the plants that have successfully
reduced waste generation from past levels.
During each of the plant audits, the audit team ob-
served pesticide formulating operations; inspected waste
management facilities; interviewed the plant manager,
environmental compliance personnel, and operations super-
visors; and reviewed and copied records pertinent to waste
generation and management. The audits were performed
by one or two engineers over a 1 - to 3 -day period depending
on the size and complexity of the formulating and waste
management operations.
30
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PLANT A WASTE MINIMIZATION ASSESSMENT
Assessment Phase: Process and Facility
Data
PlantAwasauditedonSeptember24,1986. Theaudit
consisted of a review and copying of plant records, a plant
inspection tour and an interview with the Plant Manager.
During the audit, sources of hazardous waste generation
were identified, and methods of hazardous waste handling
and disposal were reviewed. In addition, existing waste
minimization techniques were evaluated.
Facility Description
Plant A mainly formulates granule and dust fertilizers,
but also formulates three herbicide/fertilizer mixtures in
granule/dust form. These mixtures are commonly referred
to as weed and feed products. The three herbicides used in
formulating these three products are:
1. Liquid Trimec
2. Trimec dust, and
3. Dimethyl - T dust.
Raw Material Management/Process Description
The liquid Trimec is injected into a vermiculite/gran-
ule fertilizer mixture, and the Trimec and Dimethyl-T dusts
are mixed with various formulations of granule and dust
fertilizers. The weed and feed formulation is performed in
one mixer which has a capacity equivalent to 500 pounds
(Ib) of product The granule/dust fertilizer and herbicide
dust are loaded into the top of the mixer through a port, and
the mixer is equipped with an internal mixing bar which
rotates to provide the required mixing action. The mixing
bar is constructed of steel pipe, and is also used to convey
liquid Trimec through ports in the mixing bar into the
fertilizer contained in the mixing tank. Mixing procedures
for each weed and feed formulation are described in the fol-
lowing sections.
Liquid Trimec
Liquid Trimec is received at the plant as a raw material
in 55-gallon (gal) steel drums. During formulations with
the liquid Trimec, a drum of the Trimec is placed adjacent
to the mixing tank. After the granule/dust fertilizer has
been loaded into the mixer, the Trimec is pumped from the
drum into the tank through the mixing bar. For each 500-
Ibbatch of weedandfeedproduct,2quartsofliquidTrimec
are added and mixing is performed for 15 minutes.
After mixing, the product is transferred through a
hopper in the bottom of the mixing tank into a transfer box
located underneath the mixing tank. The transfer box is
then transported by a forklift to the packaging hopper
where the product is loaded into the hopper. The product
is then gravity fed from the hopper into 16-lb paper bags for
storage in an onsite warehouse and ultimate distribution.
On an average annual basis, two to three drums of the liquid
Trimec are used in weed and feed formulation.
Trimec Dust
The Trimec dust is received at the plant in 24-lb paper
bags as a raw material. In formulating Trimec dust prod-
ucts, one 24-lb bag of the Trimec dust is added for each
500-lb batch of weed and feed product. The Trimec dust is
added to the mixer through the same top loading port that
is used to load the fertilizer into the mixer. Following a 15-
minute mixing time, the product is transferred to the
packaging hopper and packaged the same as the liquid
Trimec formulations. On an average annual basis, ap-
proximately 7,200 Ib of Trimec dust are used in weed and
feed formulations.
Dimethyl-T Dust
The Dimethyl-T dust is received at the plant in 24-lb
plastic-lined cardboard cartons as a raw material. Six Ib of
the Dimethyl-T dust are weighed out on a scale located
adjacent to the mixing tank, and added to the fertilizer in the
tank through the top loading port. Mixing of the Dimethyl-
T dust and the fertilizer is performed for 20 minutes.
Transfer of the formulated product from the mixer and
packaging of the Dimethyl-T products is the same as that
for the Trimec dust products. On an average annual basis,
approximately 1,800 Ib of Dimethyl-T dust are used in
weed and feed formulations.
WASTE GENERATION, HANDLING, AND
DISPOSAL
There are four sources of hazardous waste generation
at Plant A:
Dust collected from the product transfer and pack-
aging areas;
Empty dust product bags and cartons;
Empty drums of liquid Trimec; and
Wastewater generated by the annual steam cleaning
of the mixing tank.
31
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Information relative to the generation, handling, and
disposal of each of these wastes is described in the follow-
ing sections.
Vacuum System Dust
A vacuum system, which is dedicated to the herbicide
mixing line, collects dust generated in two areas of this
mixing line. The first area is above the transfer box which
is used to transport the formulated product from the mixing
tank to the packaging hopper. When the formulated
product is released from the mixing tank through the
hopper into the transfer box, dust is generated as the
product falls into the transfer box. A flexible vacuum hose
connected to the vacuum system is manually held over the
transfer box to collect the dust generated during product
transfer.
The second dust collection area is located at the
bottom of the packaging hopper. In this area, two vacuum
system intake lines are mounted along the side of the
bottom of the packaging hopper just above the packaging
conveyor belt. These intake lines collect dust generated as
product is released from the packaging hopper into bags on
the conveyor belt
The dust collected from above the transfer box and
underneath the packaging hopper is directed to a 55-gal
collection drum located outside of the building in a totally
enclosed steel housing. This dust is reused in subsequent
formulations of weed and feed product. The quantity of
dust that is collected on an average annual basis is roughly
10 drums. This dust quantity is only a rough estimate
because the vacuum system has been in place for less than
a year, and a long-term database of dust quantity data does
not exist to allow a more accurate estimate.
Empty Dust Product Containers
The empty paper bags and cartons of the Trimec dust
and Dimcthyl-T dust are collected in a steel 55-gal drum.
The containers are manually compacted in the drums to
optimize the number of bags per drum. An average of
approximately five drums of empty product bags are gen-
erated annually, and the drums are hauled by a licensed
hazardous waste transporter to an approved offsite hazard-
ous waste disposal facility.
Empty Drums
When a drum of liquid Trimec is totally consumed in
the formulating process, the empty drum is used to collect
empty dust product containers as described above.
Wastewater
Wastewater is generated by the periodic steam clean-
ing of the mixing tank and internal mixing rod with a
portable steam jenny. This cleaning operation, which is
usually performed once per year, generates approximately
20 gal of wastewater. This wastewater is collected in a
dedicated 55-gal drum and injected into subsequent prod-
uct formulations of Dimethyl-T dust product
AUDIT FINDINGS AND RECOMMENDATIONS
The. current methods of waste management at Plant A
are successful in minimizing the quantity of hazardous
waste requiring disposal. As described earlier, the dust
collected in the vacuum system and the wastewater gener-
ated by steam cleaning of the mixing tank are reused in
subsequent product formulations. Because of the addi-
tional operational requirement to collect and inject the
wastewater into product formulations at a controlled rate,
minimization of the volume of wastewater generated is an
inherent component of the waste management process.
The only hazardous waste that requires disposal is the
drums of compacted empty product containers. As de-
scribed earlier, the product containers are manually com-
pacted in the drums. It is recommended that consideration
be given to mechanical compaction to reduce the number
of drums for disposal. A reduction from the annual average
of five drums to four drums is conceivable if mechanical
compaction were utilized. A compaction device for use by
a forklift could be manufactured for a cost of about $300.
At present, PlantAincursacostof$70 per drum for trans-
portation and disposal at an approved 'hazardous waste
disposal facility. Therefore, the period of return on the
investment on the mechanical compaction device would be
between 4 and 5 years.
In addition to the recommendation presented above, a
general recommendation to improve the plant's environ-
mental management of the herbicide mixing operation was
also developed. At present,the flooring in the herbicide
mixing area consists of compacted native soil. Any fugi-
tive dust from the formulation process that has deposited
on the ground is subject to migration outside the building
on the tires of the forklift and on employees shoes. The
paving of this area would allow collection of the dust with
the vacuum system for reuse in subsequent product formu-
lations, and minimize the amount of dust migration outside
of the building. The paving of this area would cost
approximately $2,000.
32
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PLANT B WASTE MINIMIZATION ASSESSMENT
Assessment Phase: Process and Facility
Data
Plant B was audited by the consulting firm on Septem-
ber 24, 1986. The audit consisted of a plant inspection tour
and an interview with the Plant Manager. During the audit,
sources of hazardous waste handling and disposal were
reviewed.
FACILITY DESCRIPTION
Plant B is mainly engaged in the formulation and dis-
tribution of fertilizer, but it also formulates a small quantity
of liquid pesticides. The pesticides formulated are primar-
ily insecticides consisting of malathion and diazinon in a
xylene carrier solution. On an average annual basis,
approximately 400 gallons of pesticide is formulated.
RAW MATERIAL MANAGEMENT/PROCESS
DESCRIPTION
The mixing of the active ingredients with the xylene is
performed in a 40-gallon (gal) stainless steel mixing tank
equipped with a portable mixing propeller. The active in-
gredients and the xylene are received at the plant in 55-gal
drums, and are added to the mixing tank by using a pump.
Following mixing, the mixing tank is raised by a forklift,
and the formulated product is drained through a spigot on
the side of the tank into a 55-gal drum. The drum is then
transported to the packaging area where the pesticide is
pumped into 8-ounce bottles for distribution.
WASTE GENERATION, HANDLING, AND
DISPOSAL
The only sources of hazardous waste generation at
Plant B relating to the pesticide formulating operation are
rags used to wipe down the 40-gal mixing tank and small
spills following formulation of each batch. An estimated
10 to 20 pounds (Ibs) of pesticide contaminated rags are
generated annually. The rags are disposed of in the
dumpster and ultimately in a sanitary landfill.
AUDIT FINDINGS AND RECOMMENDATIONS
The pesticide-contaminated rags generated by clean-
ing the mixing tank and small infrequent spills are possibly
classified as a hazardous waste, depending primarily on the
quantity of pesticide in the rags. Sampling and analysis of
the rags to determine the content of pesticide and carrier
solvent in the rags would be required to determine if their
content exceeds the hazardous waste criteria set forth in
Article 11, Title 22, California Administrative Code.
If the rags are determined to be a classified hazardous
waste, they should not be disposed of in a sanitary landfill.
One alternative is to collect the rags in a 55-gal drum for
ultimate disposal at an approved hazardous waste disposal
facility. If the rags are not accumulated longer than 90 days
prior to disposal, then a hazardous waste storage facility
permit will not be required. However, the drum must be
stored and transported in accordance with the requirements
for generators of hazardous waste (Article 6, Title 22,
California Administrative Code). If Plant B generates less
than 100 kilograms (kg) during any calendar month, the
90-day accumulation time limit identified above would
begin when the amount of pesticide-contaminated rags
reached 100 kg. At a maximum generation rate of approxi-
mately 20 Ibs or 9 kg of rags per year, the rags could be
accumulated up to 11 years before the small quantity
exclusion limit of 100 kg would be exceeded. Assuming
that up to 220 Ib of contaminated rags could be placed in a
55-gal drum, only one drum would be required to store the
rags over the 11-year period. However, because of the
future landfill disposal ban of hazardous wastes and the
potential risk associated with possible spontaneous com-
bustion of the rags due to solvent carrier solution content,
disposal of the rags on a more frequent basis would be
prudent. Additionally, the above 100 kg limitation is
reduced to 1 kg for waste classified as extremely hazard-
ous. The current disposal cost for one drum is approxi-
mately $70.
As the costs for hazardous waste disposal increase, an
alternative method of cleaning the pesticide mixing tank
that generates a reusable product may be considered. An
example of such an alternative is the use of a small pressure
washer to apply carrier solution and a squeegee to clean the
tank, with collection of the resulting spent solution for
reuse in subsequent formulations. This alternative also
includes the placement of a shallow stainless steel pan
underneath the mixing tank to catch any small spills which
may occur during formulation or transfer operations. The
pan should be slightly elevated and equipped with aspigot,
so spills could be collected for reuse in pesticide formula-
tion.
The capital and additional operating costs to imple-
ment this alternative are estimated to be approximately
$200 and $150 per year, respectively.
These costs estimates are based on the following as-
sumptions:
Capital cost of catchment pan and portable
pressure washer = $200.
Additional operational requirement of 10 labor
hours per year for tank cleaning.
Labor rate of $15 per hour.
33
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PLANT C WASTE MINIMIZATION ASSESSMENT
Introduction
Plant C was audited by a team of two consulting
engineers on September 3 and 4,1986. The 2-day effort
included review and copying of records, plant inspection
tours, and interviews with plant personnel. Special atten-
tion was given to the plant's hazardous waste generation
sources; handling, treatment, and disposal methods; and
existing and proposed hazardous waste minimization tech-
niques. Waste minimization techniques potentially appli-
cable to the plant, and to pesticide formulators and repack-
agers in general, were identified. The potential economic
benefits of the hazardous waste minimization techniques
were identified.
PLANT DESCRIPTION
The plant consists of two areas, a 12.5-acre developed
area encompassing the production and office areas, and a
5-acre undeveloped tract. The plant was constructed in
1930, primarily for sulfur grinding. The operations at that
time consisted of a single Raymond mill. Since then, the
plant has grown to include two Raymond mills, five dust
mills, three granular mills, and a variety of liquid pesticide
formulation operations. The plant was renovated, in 1980,
with addition of process equipment from a closed plant,
new buildings to house equipment, and paving of much of
the remaining undeveloped production area.
The production area currently consists of 16 large
buildings, a percolation pond, several bulk product and
waste storage areas, and pallet and drum storage areas. The
balance of the production area is open pavement
In the developed area of the plant, stormwater runoff
from the office and parking lot areas, which total approxi-
maiely2acres,drains to thepercolationpond. Runoff from
the process and storage areas, which total approximately
10.5 acres, drains to centrally located sumps for collection
and storage as hazardous waste. Stormwater runoff from
the 5-acre undeveloped area of the plant is contained onsite
in the natural drainage system.
RAW MATERIALS AND PRODUCTS
Because theplantis apesticideformulator andrepack-
ager, raw materials are limited to bulk technical-grade
pesticides, diluents, various additives, and sulfur. Techni-
cal-grade pesticides include concentrated or pure pesti-
cides in liquid, powder, and granular forms. Diluents
include water, solvents, oils, sands, and clays.
Some bulk pesticides are shipped to the plant for re-
packaging into smaller containers. Dust mill 2A and the
paraquat packagingmill are examples of dedicated repack-
aging process areas. Technical-grade materials are typi-
cally received by truck. The materials are distributed for
processing, which involves mixing with diluents and pack-
aging as finished product.
The plant can currently formulate over 600 different
registered formulations. In 1986, the plant produced 2.1
million gallons of liquid pesticides and more than 40
million pounds of dry pesticides.
Approximately 60 percent of production results from
contracts for custom and specialty formulations for outside
clients. The remaining 40 percent of products produced in-
cludes a full line of proprietary insecticides, herbicides,
fungicides, and rodenticides.
PROCESS DESCRIPTIONS
The plant consists of four main process areas: the
sulfur, dust, granular, and liquids areas. Finished product
is stored in the main warehouse for eventual distribution.
Sulfur Formulation Process
The sulfur process is the largest volume dry material,
continuous production process area at the plant. In 1986
the sulfur process produced 22.5 million pounds of fin-
ished product.
The sulfur process begins with the unloading of bulk
crude sulfur from trucks into a belowground hopper. A
screw conveyor moves material on an elevator system to
one of six large sulfur storage silos. Upon demand, crude
sulfur is moved by screw conveyor to a small ribbon mixer.
The mixer is used for the addition of resins and magnesium
conditioners to prevent static charges. After mixing, the
crude sulfur is conveyed to a holding bin in the mill
building. As detailed in Figures A-l and A-2, the sulfur is
then milled in one of two Raymond mills and cycloned to
another holding bin before being conveyed to a bagging
machine.
34
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Dust from the milling process is drawn off the cyclone
system and collected for eventual recycle. Natural-gas-
fired boilers generate carbon dioxide for inert gas blanket-
ing of the milling process to reduce the chance of fire.
Continuous monitoring systems monitor and record oxy-
gen content throughout the process equipment and build-
ings.
A secondary operation in the sulfur process area is the
sulfur x-mill. Figure A-3 presents a schematic diagram of
the sulfur x-mill. The x-mill blends sulfur and bentonite
under heat to form an insoluble sulfur product. Sulfur from
the Raymond mills is blended with bentonite from a cut-in
hopper. The material is elevated to a holding bin and then
conveyed through a series of sterilizers. After sterilization,
the material is crushed, passed through shaker screens, and
packaged in bags.
Both sulfur and x-mill product are bagged, placed on
pallets, and shipped to a warehouse for eventual distribu-
tion.
The boiler and cooling tower are auxiliary operations
in the sulfur area. Slowdown from both units is pumped to
the bulk hazardous waste storage tank. Spilled or "wet"
sulfur is a mixture of sulfur and condensate from the inert
gas system. It is recycled to the head of the process.
Granular Formulation Process
By volume, the granular formulation operation is the
second-largest process at the plant. In 1986, 11 million
pounds of granular pesticides were produced as finished
product.
The granular process area includes three mills, T-3, T-
4, and T-5. Figures C.2-4 and C.2-5 detail the granular for-
mulation process. Mill T-3 differs from mills T-4 and T-
5 by the addition of a rotary dryer. Raw materials, includ-
ing technical-grade pesticides and clay and/or sand dilu-
ents, are loaded into cut-in hoppers and elevated to holding
bins. The materials are blended in rotary mixers while
being inoculated with liquid pesticides. The granular
material is formed during this mixing. After mixing, the
materials are screened in a shaker screen and packaged in
bags. Mill T-3 is equipped with a natural-gas-fired rotary
dryer, positioned after the second holding bin.
Products from all three mills are packaged, placed on
pallets which are covered with a plastic outer wrap, and
shipped to the warehouse for storage.
At the completion of a product formulation run, the
mills are flushed with diluent sand or clay to remove
residual pesticide.
All three granular mills have dedicated dust collec-
tors. Dust is collected from the various mill components
and recycled to the previous component. For example, dust
drawn from the mixer is recycled to the cut-in hopper. In
addition to the dedicated dust collection systems in the
granular mills, a central vacuum system also serves the
granular mill area, aswellasthedust formulating area. The
central vacuum system is used to collect product spills and
general fugitive dust emissions that occur in both the
granule and dust formulating buildings.
Dust Formulation Process
In 1985 the dust process formulated about ISpercent,
or 7 million pounds, of the total dry product formulated at
the plant. The dust area uses five dust mills and one
repackaging mill. Process flow diagrams for a dust mill
and repackager are included as Figures A-6 through A-9.
A typical dust mill begins with a cut-in hopper for loading
dry technical material and diluent clays. These materials
are conveyed to a holding bin before being loaded into a
ribbon mixer. Liquid additives may be injected during
mixing. After mixing, the materials are elevated to a
second holding bin before being packaged in the bagging
machine.
The repack mill shown in Figure A-10 involves only
a cut-in hopper, elevator, holding bin, and bag machine.
The repack mill does not blend materials. Itis used only for
repackaging products.
Product from all six mills is packaged, placed on
pallets, and shipped to the warehouse for distribution.
Each dust mill has a dedicated dust collector which
draws dust from the cut-in hopper and the bagging ma-
chine. As described in the preceding section, the central
vacuum system is used to collect spilled product and
general fugitive dust emissions in the dust mill area.
Liquids Formulation Process
The liquids processing area includes the sinox, two
main liquids, micronutrients and oils buildings. In 1986,
the liquids area formulated 1.7 million gallons of liquid
pesticides.
The sinox prtxess located in Building 48 houses two
process mills, the sinox mill and the paraquat repackaging
mill. Sinox mill processes are diagramed in Figures A-11
and A-12.
The sinox technical material is dinitrobutyl phenol. It
is stored in a closed bulk storage tank located over a large
sump adjacent to the building. The tank area is roofed.
Technical material and diluents are added to a mixer via a
barrel dump. They are mixed in a 2,500-gallon (gal) mixer
and pumped to one of two batch holding tanks for dis-
pensing and packaging. The diluents consist of water,
xylene, methanol, and diesel fuel. Paraquat is only repack-
aged in the sinox building. Vapors drawn off the mixer and
35
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Conditioner
A.
Dust
Collector
For
Recycle
(DC)
Bag Dump
Conditioner
v v
Mixer
Sulfur From Silo
Explosion
Vent(EV)
Holding
Bin
EV
Mil!
FIGURE A-1. FLOW DIAGRAM FOR RAYMOND MILL-1
Cyclone
EV
Holding
Bin
1
DC
Product
Packaging
Explosive
Vent (EV)
Sulfur
From
Silo
High
Mixer
Dust
Collector
For
Recycle
(DC)
1
1
DC
High
Bin
DC
Low
Mixer
DC
Conditioner
Bag
Dump
Low
Bin
EV
Holding
Bin
Cyclone
A
EV
Mill
Conditioner
00
Mixer
DC
Product
Packaging
FIGURE A-2 FLOW DIAGRAM FOR RAYMOND MILL-2
36
-------
Sulfur and
Bentonite
4
Ba(
b
Explosion '
Vent (EV)
A Dust
Collector
For
Recycle
(DC)
3 Dump
V
lixer
..... ,, k
Hole
* B
>
Sterili
Mix
Jing
n
4 DC
1
7OI*C/
er
1
Holding
Bin
>
Screen
>
A DC
T
Product
Packaging
FIGURE A-3. FLOW DIAGRAM FOR SULFUR X-MILL
Dust
Pesticide Collector
And For
Diluent Recycle
T (DC)
^ 1
Bag
Dump
V
4 Explosive
1 Vent(EV)
Holding
Bin
>
r
Mixer
F
>.
'esticide
i
Holding
Bin
T
5 -....V> DC
r t°C
Dryer
Screens
>
4 DC
1
Product
Papkaging
FIGURE A-4. FLOW DIAGRAM FOR GRANULE MILLT-3
37
-------
1
DC
DC
Pesti
And
Dilue
Dust
Collector
cide For
T Recycle
nt^ 1 (DC)
Bag
Dump
P<
Holding
Bin
ssticide
Jf ^
r \
Mixer
)C
Holding
Bin
^
A DC
r \
Product
Packaging
FIGURE A-5. FLOW DIAGRAM FOR GRANULE MILLT-4
Dust
A Explosion
1 Vent(EV)
I a
Collector
Pesticide For
And A Recycle
Diluent i (DC)
Bag
Dump
Holding
Bin
>
,!EV
Mixer
v
Mill :
^
, r
Holding
Bin
>
, tDC
Product
Packaging
FIGURE A-6. FLOW DIAGRAM FOR DUST MILL NOS. 1 AND 5
38
-------
4 Explosi
1 Vent(E
Dust
Collector
Pesticide For
And T Recycle
Diluent i (DC)
Bag
Dump
r >
Mixer
Pesticide
Jr ,
>
Mill
on
V)
v
Bin
^
A DC
' 1
Product
Packaging
FIGURE A-7. FLOW DIAGRAM FOR DUST MILL-NO. 2
A Explosion
1 Vent(EV)
Dust
Collector
Pesticide For
And f Recycle
Diluent i (DC)
Bag
Dump
>
Holding
Bin
AEV
1 >
r
Mixer
>
r
Mill
^
Holding
Bin
>
, tDO
Product
Packaging
FIGURE A-8. FLOW DIAGRAM FOR DUST MILL-NO. 3
39
-------
4 Explosion
| Vent(EV)
Dust
. h
Collector
Pesticide For
And f Recycle
Diluent i I(DC)
Bag
Dump
Holding
Bin
r,
f
Mixer
>
r
Mill
v
Holding
Bin
>
f
Product
Packaging
DC
FIGURE A-9. FLOW DIAGRAM FOR DUST MILL-NO. 4
Dust
Collector
Formulated A- vi
Pesticide JRecycle
^ I (DC)
Bag
Dump
Holding
Bin
DC
Product
Packaging
FIGURE A-10. FLOW DIAGRAM FOR DUST REPACK MILL (MILL NO. 2A)
40
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batch holding tanks for both the sinox and paraquat proc-
esses pass through activated carbon unit filters.
One of the two main liquids buildings contains four
liquid formulation mills. The liquid mill process is diagra-
med in Figure A-13. Technical materials and diluents are
loaded via a barrel dump station and gravity fed into the
mixer. The diluents consist of oils, solvents, and water.
After mixing, the pesticide is pumped to a holding tank for
dispensing and packaging. Pesticide vapors are drawn off
all portions of the liquids process and passed through an
activated carbon filter. The other main liquids building
was formerly used to formulate kelthane, but was being
renovated at the time of the audit to provide various liquid
formulating facilities similar to those described above and
depicted in Figure A-13. Likewise, the micronutrients
building was being renovated during the audit to provide
similar formulating processes.
The oils building contains the oil blending process. In
1986,200,000 gal of oil products were formulated at the
plant. Various oils are shipped to the plant in bulk and are
blended in a series of mixing tanks and packaged in smaller
containers, typically 30-gal drams. Dedicated integral
piping and tank draining practices prevent contamination
of subsequent batches. However, because of poor market
conditions, the oils operation was discontinued in Septem-
ber, after the onsite audit
Supplemental to the oil blending operation is a drum
or barrel washing/painting operation which is located
adjacent to the oils building. Figure'A-14 presents a
schematic diagram of the barrel washing/painting opera-
tion. Barrels are first manually washed with a high-
pressure hose to remove labels and excess oil. The barrels
are then cleaned in a barrel washer, dried, painted in a
water-curtain spray booth, and again dried. With the
discontinuation of the blending operation, the barrel wash-
ing/painting operation has also been discontinued.
Support operations at the plant include a uniform
laundry, steam cleaner, maintenance shop, quality control
laboratory, bulk storage areas, and warehouses. The steam
cleaner, which is portable, is mainly used for cleaning
formulating equipment prior to performing maintenance
on the equipment. It is also used to clean liquid mixing
tanks in-place between formulating operations.
Waste Generation, Handling, And Disposal
This chapter identifies the sources of hazardous waste
generation at the plant and describes the existing methods
for waste handling and disposal. This information is
presented by each major type of waste generated including
dust, dust/granule mill flushing diluents, other solid wastes,
and liquid wastes. Other solid wastes consist of empty
packaging materials, lab wastes, and activated carbon
filters.
The disposal costs for each of these wastes are also
presented.
DUST
Each dust and granular pesticide formulation mill is
equipped with a dedicated dust collection system. This
system draws fugitive dust generated by the various mill
components and recycles it to the previous component. For
example, dust drawn from the mixer is routed to the cut-in
hopper. Excess dust generated during the final phase of
batch formulation is collected in a hopper. This excess dust
is emptied from the hopper into a drum located underneath
the hopper in an enclosed housing. The drum is normally
a 30-gallon (gal) drum. The dust is sampled and analyzed
for technical material from the current batch as well as
technical material from the differing previous batch. If the
dust contains technical material from the current batch and
does not contain unacceptable amounts of the differing
technical material from the previous batch, then the dust is
held for recycling in subsequent formulations. However,
if the dust cannot be recycled within a practical time
because of product orders, then the dust is disposed of as
hazardous waste at an offsite approved hazardous waste
disposal facility. Likewise, non-recyclable dust is dis-
posed of as ahazardous waste atan offsite disposal facility.
In addition to the individual mill dust collection systems,
a central vacuum system serves both the granular and dust
formulation buildings. Vacuum ports for this system are
located near each dust and granular mill and dust collector
hopper. During product formulation, operators will attach
a hose to the port and vacuum dust and spilled product from
around the mill area. When individual mill dust collector
, hoppers are emptied, a vacuum hose is attached to the drum
housing under the hopper to draw off fugitive dust emis-
sions. Material collected in the central vacuum system is
emptied in the same manner as mill dust. Because the dust
collected by the central vacuum system contains a variety
of technical materials, recycling of the dust in subsequent
formulations is not feasible. Therefore, it is disposed of as
a hazardous waste at an offsite hazardous waste disposal
facility.
The drums of non-recyclable dust are first transferred
from the individual mill dust collectors and the central dust
collection system to the hazardous waste accumulation
area in the main warehouse. As a result of drum vibration
during transport and gravity settling of the dust, the dust
level drops in the drums. The drums are topped off with
additional waste dust in the drum accumulation area and
are then transported to an offsite ha zardous waste disposal
facility.
41
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Pesticide
and Diluent
Activated
Carbon Unit
(ACU)
ACU
Barrel
Dump
>
, t
Mixer
ACU
»*
Holding
Tank
\
A A
Product
Packaging
FIGURE A-11. FLOW DIAGRAM FOR SINOX PROCESS
Paraquat From
Tank Farm
l
Holding
Tank
Activated
Carbon Unit
(ACU)
Product
Packaging
FIGURE A-12. FLOW DIAGRAM FOR PARAQUAT REPACKAGING PROCESS
42
-------
Pesticide
and Diluent
1 1
Activated
Carbon Unit
(ACU)
Barrel
Dump
ACU
Mixer
1
ACU
Holding
Tank
ACU
Product
Packaging
FIGURE A-13. FLOW DIAGRAM FOR MAIN LIQUID PROCESS
Barrels
Barrel
Rinse
Water w£er
Input _ "
r Sump
Evaporation
To Atmosphere
r
Dryer
Painting
Booth
Dryer
T
Reconditioned
Barrels
FIGURE A-14. FLOW DIAGRAM FOR BARREL WASHING OPERATION
43
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DUST/GRANULE MILL FLUSHING DILUENTS
Sand and clay diluents are used to flush the granule
and dust mills, respectively, after a product formulation
run to remove residual pesticides. The diluent is collected
in drums and empty paper bags which previously con-
tained inert materials. The diluent is sampled and analyzed
in the same manner as that for dusts collected by the
vacuum systems. Likewise, the diluent is recycled or
disposed of in the same manner as the dust based on the
analytical results.
OTHER SOLID WASTES
Other solid wastes consist of emptied paper bags,
cartons, and steel drums; activated carbon filters from
ventilation systems; floor sweepings; and laboratory wastes.
The emptied paper bags and cartons and activated
carbon filters are collected daily from process areas and
compacted in a 40 cubic yard (cy) compactor. The com-
pacted wastes are hauled "piggy back" in the40-cy bins to
an off-site, approved hazardous waste disposal facility.
The bins typically contain between 12,000 and 15,000
pounds of bulk waste.
The 30- and 55-gal drums are reused for collecting
hazardous dusts and flushing diluents as described previ-
ously. Any drums which cannot be reused for collection of
hazardous wastes are cleaned at the steam cleaning pad and
are transported offsite to a drum recycling firm.
Spilledproductfloorsweepingsarecollected in drums
and disposed of as a hazardous waste. Likewise, laboratory
wastes are lab packed and disposed of as a hazardous
waste.
LIQUID WASTES
Liquid wastes consist of process wastewater, storm-
water runoff, and sanitary wastewater. A description of
each of these waste streams including a discussion of the
handling and disposal methods is presented in the follow-
ing sections.
Process Wastewater
Process wastewater consists of mill clean-out rinse
water, equipment washdown water, laundry wastewater,
floor wash water, boiler blowdown, cooling tower blow-
down, and steam cleaning pad wastewater. Process waste-
waters are generally routed to building floor drains and/or
centrally located sumps. They flow by gravity or are
pumped to the main wastewater sump. From there, the
wastewater is pumped to the above ground bulk liquid
hazardous waste storage tank. The tank has a capacity of
approximately 589,000 gal. The process wastewater is
periodically hauled by tanker trucks to an off-site hazard-
ous waste disposal facility.
A discussion of each individual source of process was-
tewater is presented in the following paragraphs.
Mill Clean-Out Rinse Water and Equipment
Washdown Water
The liquid formulation tanks and mixing equipment
are cleaned using the portable steam cleaner and water
hoses between formulations of different pesticides. In
addition, whenever a piece of equipment is removed from
service for maintenance, it is decontaminated using the
portable steam cleaner. Decontamination is performed
either inplace or at the steam cleaning pad prior to trans-
porting the equipment to the maintenance building. The
wastewater generated by these cleaning operations is col-
lected and directed to the bulk hazardous waste storage
tank.
Laundry Wastewater
The plant operates a laundry with two industrial grade
washers and dryers on site for the cleaning of process
employee overalls. The laundry wastewater is discharged
to a nearby above ground tank. From this tank the waste-
water is pumped to the bulk hazardous waste storage tank.
Floor Wash Water
To clean up spills in the liquids formulating buildings,
water hoses and the steam cleaner are used to wash down
the spills to floor drains which lead to sumps. From the
sumps, the wastewater is pumped to the bulk hazardous
waste storage tank.
Boiler and Cooling Tower Blowdown
Blowdown from the boiler and coolingtower is pumped
to the bulk hazardous waste storage tank. The cooling
tower blowdown is handled as a hazardous waste because
of the potential for fugitive pesticide dust emissions to
become entrained in the cooling tower water. Although the
boiler blowdown is very likely not a hazardous waste
stream, it is treated as such only because no other discharge
options are readily available. The on-site septic tank/
drainfield system reportedly does not have adequate ca-
pacity to accept the blowdown. In addition, plant person-
nel are reluctant to apply for a discharge permit because of
past difficulties experienced in the application for dis-
charge of treated process wastewater.
Steam Cleaning Pad Wastewater
Wastewater generated by the cleaning of drums and
other equipment at the steam cleaning pad is routed to the
bulk hazardous waste storage tank.
Stormwater Runoff
Of the 12.5-acre developed areaof theplant, stormwa-
ter runoff from the 2-acre plant parking lot drains to a
44
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percolation pond located near the main gate of the plant.
Stormwater runoff from the remaining 10.5-acre process
area is collected through the central sump system and
pumped to the bulk hazardous waste storage tank for
disposal as hazardous waste. The exception to this runoff
pattern is the runoff from the north side of the m aintenance
building roof. The roof downspouts discharge to gravel
splashpans in a grassy area adjacent to the building.
Sanitary Wastewater
Sanitary wastewater generated at the plant is dis-
charged to two on-site septic tank/drainfield systems. The
sanitary waste stream includes wastewater generated by
the employee shower. Employees engaged in formulating
operations are required to shower and change cotton over-
alls before lunch and shower again before leaving after
work. The number of employees engaged in formulating
operations ranges from approximately 60 to 120, depend-
ing on seasonal fluctuations in production.
WASTE QUANTITIES AND DISPOSAL COSTS
Quantities and disposal costs for the hazardous wastes
identified in the preceding sections are presented in this
section. The waste quantities are based on summary data
provided by the plant which consist of annual quantities of
solidandliquid wastes fortheperiodof 1981 through 1985.
In addition, best engineering judgement was applied to
estimate quantities of specific types of process wastes.
Table A-l presents the annual waste quantity summary
data by waste media. As shown in this table, the annual
quantity of solid waste generated has decreased from
2,080.8 tons in 1981 to 467 tons in 1985, a 78 percent
decrease. This reduction in solid waste generation resulted
from aggressive waste minimization efforts by the plant,
particularly relative to dust generation. Numerous equip-
ment modifications and procedural changes were imple-
mented to control the gen eration of hazardous dust.
Table A-l. Annual Waste Quantity Summary Data
Hazardous
Waste Media Waste Quantity (tons)
1981 1982 1983 1984 1985
Solid 2080.8 1001.2 747.4 526.0 467
Liquid1 3921.2 6444.2 15,259.8b 6024.9 7,000
Total 6002.0 7445.4 16,007.2 6550.9 7,467
* Includes Stormwater runoff from plant area.
b Includes 1,666 tons from pre-1982 storage.
Source: Plant C, 1985 and 1986.
Because considerable waste minimization had already
occurred relative to solid hazardous waste, and minimal
potential for further solid waste minimization was found to
exist at this plant, additional waste quantification efforts
focused on the liquid waste streams. Quantification of the
various liquid process waste streams was based primarily
on reported typical wastewater generation rates. In addi-
tion, best engineering judgement was used to estimate
waste quantities in the absence of available waste genera-
tion information. Table A-2 presents the estimated annual
volume of each process waste stream and Stormwater
runoff. As shown in Table A-2, almost 90 percent of the
total process wastewater volume consists of laundry was-
tewater. Each of the other process waste streams contrib-
utes less than 5 percent. On an average annual basis,
Stormwater runoff contributes about 75 percent of the total
liquid waste volume, and approximately 97 percent of the
total liquid waste volume consists of runoff and laundry
wastewater.
Table A-3 presents annual waste disposal costs, based
on 1984 waste quantities as this database was the most
recent and complete. However, 1986 unit disposal costs
were used to reflect more current overall costs. As shown
in Table A-3, the cost for disposing process wastewater
including Stormwater runoff is approximately 75 percent
of the total. The remaining 25 percent consists of solid
waste disposal costs.
Table A-2. Estimated Volume of Liquid Process
Waste Streams and Stormwater Runoff
Estimated Annual Volume
% of Total % of Total
Process Liquid
Waste Stream Gal Wastewater Waste
1.8
3.0
MillCleanout 11,000 2.2
rinsewater and
equipment
washdown water
Floor wash water 9,000
Steam cleaning 15,000
pad wastewater
Laundry 441,000 88.2
wastewater
Boiler and cooling 24,000 4.8 1.2
tower blowdown
Total Process 500,000 100.0 "2575
Wastewater
Stormwater 1,500,000 75.0
Runoff
Total liquid 2,000,000 100.0
Waste
Based on average annual rainfall of 10.52 inches per year
recorded at a nearby airport.
0.6
0.4
0.8
22.0
45
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Table A-3. Annual Waste Disposal Costs
% of
Waste Annual Waste UnitDisposal Annual Disposal Total
Type Quantity* Cost Cost Cost
Drummed 2,057 drums $65/drum $133,705 9A
Solids
Compacted 36 bins $5,400/b5n $194,400 13.7
Solids
Pallets 93 pallets $260/pallet $24,180 1.7
of
Solids*
Process 1,445,300 gal $0.72/gal $1,040,616 75.2
Waste
water6
TOTAL COST $1,392,901
1984 data.
"Palletized and plastic wrapped paper bags containing contami-
nated flushing diluents.
'Including stormwater runoff.
Source: Plant C, 1984; ESE, 1986
AUDIT FINDINGS AND RECOMMENDATIONS
This chapter presents the findings of the audit in terms
of hazardous waste minimization techniques recently im-
plemented by the plant Recommendations for further
waste reduction through source controls, recycling, and
treatment are also presented. Where information was
available, cost/benefit data are presented for the various
waste minimization techniques implemented by the plant.
EXISTING WASTE MINIMIZATION
TECHNIQUES
The most prominent waste minimization techniques
implemented at the plant are those which control the
generation of hazardous dusts in the formulation of dust
and granular pesticides. These techniques consist of the
installation of dedicated dust collection baghouses on each
dust/granule formulating mill; the installation of enclosed
cut-in hoppers, conveyors, elevators, mixers, and holding
tanks; the recycling of dust collected from each mill
component to the preceding component; and the reuse of
the dust collected in the baghouse hopper for subsequent
formulations to the maximum extent that is practically
feasible.
As described in the Waste Generation section, the sig-"
mfrcantreductiorrin the volume of solid hazardous waste
generated since 1981 is mainly attributable to the implem-
entation of these dust control techniques.
Other solid waste reduction techniques employed by
the plant consist of the use of returnable bulk diluent
containers; the installation of a compactor to reduce the
volume of bulky wastes such as emptied paper bags,
cardboard drums and spent activated carbon filters; and the
recycling of empty drums. The returnable bulk diluent
containers are used primarily for the sand and clay diluents
used in formulating dust and granular pesticides.
The compactor was installed mainly because the dis-
posal costs for the bins of bulk waste are based on a unit
volume basis rather than a unit weight basis, and waste
volume reduction would result in reduced disposal cost.
The compactor was installed in 1983 for a cost of approxi-
mately $60,000. The savings realized from the reduced
disposal costs offset the capital cost of the compactor in 4
months.
Any empty 55-gallon drum which previously con-
tained pesticide is either reused for collecting hazardous
waste, or washed and shipped to an offsite drum recycler.
As described previously, drums shipped to the offsite
recycler are first cleaned at the steam cleaning pad.
Wastereduction measures that have been implemented
relative to liquid process wastes include the use of portable
steam cleaners to clean mixing tanks rather than using the
batch-boil method; the use of spray nozzles on hoses used
for rinsing mixing and other process equipment, and floor
washing; and recycling of equipment rinse waster as dilu-
ent for subsequent formulations when practicable. The
reduction in liquid process wastes resulting from the im-
plementation of these techniques is not known as historical
waste volume data are not available for the specific liquid
waste streams.
Inspection of the liquid formulating areas indicated
that not all hoses used for equipment washdown and floor
washing were equipped with nozzles. Some were not even
equipped with threaded fittings for nozzles. Consequently,
further liquid waste volume reduction could be achieved
by installing nozzles on all hoses at the plant. A high
pressure water knife nozzle could significantly reduce the
liquid volume. This would generate a more cone entrated
wastewater that could be used in subsequent formulations.
A general observation of the waste minimization audit
was that past waste minimization efforts apparently fo-
cused more on the generation and disposal of solid wastes
than on liquid process waste generation and disposal. This
observation is based on the extent of capital improvements
of hazardous dust collection equipment compared to that
related to liquid waste minimization. In the absence of
historical waste volume data for specific liqui d waste
steams, it is not possible to further substantiate this obser-
vation by comparing the percentage reduction of liquid
waste streams versus solid waste streams.
Another significant audit finding is that many of the
higher strength liquid process wastes, such as equipment
rinse water, are generated in almost Negligible volumes
46
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compared to the volume of plant stormwater runoff that is
collected and handled as a hazardous waste. Conse-
quently, any reductions in process wastewaters that have
occurred through the implementation of waste minimiza-
tion measures are masked by the volume of stormwater
runoff that is commingled with the process wastewater.
According to plant personnel, past efforts to obtain a
discharge permit for the stormwater runoff have been un-
successful because of concern over pesticide levels in the
runoff. Consequently, the plant is currently conducting
treatability testing of activated carbon for pesticide re-
moval from process wastes, including the runoff.
RECOMMENDED WASTE SOURCE
REDUCTION TECHNIQUES
The recommendations presented below were devel-
oped for minimizing or eliminating hazardous waste at the
source of generation.
Liquid Waste Sources
1. Use mopping of floors in liquid pesticide formulat-
ing areas with dedicated mops and squeegees to minimize
the use of water hosing for floor washing. This practice
will minimize the volume of floor wash water generated.
2. Install spray nozzles on all hoses to increase equip-
ment rinsing efficiency thereby minimizing the volume of
spent rinse water. This recommendation could include the
use of a water-knife type spray nozzle equipped with a high
pressure booster pump. The resulting wastewater would be
more concentrated and could be used in subsequent formu-
lations. The use of wiper blades to physically wipe down
the inside of the mixing tanks could also be included as part
of this recommendation.
3. Collect and reuse equipment rinse water for repeti-
tive rinsing to minimize the volume of spent rinse water.
This recommendation would involve the installation of
rinse water holding tanks to facilitate its reuse, and possible
two stage rinsing using more contaminated rinse water for
the first stage of rinsing, and less contaminated rinse water
for the final rinse.
4. Install flow meters on process water lines in each
liquid pesticide formulating area to monitor water usage
and the effects of various waste minimization techniques
during trial implementation periods. Maintain a formal
waste minimization program requiring operators to rou-
tinely record meter readings and waste quantities, and
periodically review this data with management.
5. Use disposable coveralls, such as Tyvek suits, in-
stead of cotton overalls for personnel engaged in formulat-
ing operations to minimize laundry wastewater.
6. Collect and analyze samples of boiler and cooling
tower blowdowns to determine if these waste streams are
characteristic hazardous wastes. If nonhazardous, dispose
of by discharge to one of the septic tank/drainfield systems.
7. Monitor stormwater runoff flow and quality. This
monitoring may indicate that the runoff is uncontaminated
during the latter part of the wet season because of the con-
taminant flushing. If so, the runoff should be handled as a
nonhazardous waste during this time period. This will
require that the runoff control system be modified to allow
segregation of the runoff from process wastewater.
Solid Waste Sources
In the granule and dust mill flushing operation be-
tween batches, change from once through diluent flushing
to repetitive flushing with a smaller volume of diluent.
This recommendation may involve the installation of
dedicated holding tanks for the used diluents, and could
also include the use of two stage flushing. Furthermore, the
establishment of a formal waste minimization program to
periodically review waste generation by granule and d ust
mill operations should be considered.
RECOMMENDED WASTE RECYCLING
TECHNIQUES
The findings of the audit indicated that the plant is ef-
fectively recycling diluents used for decontaminating for-
mulating equipment between batches to the extent that is
practically feasible. This applies to clays and sand for dust/
granule formulations, and water and solvents for liquid
formulations. It was also determined that the plant is
currently conducting pilot-scale activated carbon treatabil-
ity studies for the combined process was tewater, including
plant runoff, to produce an effluent that could be reused in
the plant. It is recommended that these studies be contin-
ued and expanded as necessary to evaluate other applicable
treatment technologies to evaluate reuse of the effluent in
the plant. These studies should also be designed to support
the discharge of the effluent to surface water or to a
publicly-owned treatment works (POTW) should the sewer
system be extended near the plant in the future.
RECOMMENDED MANAGEMENT/EMPLOYEE
INITIATIVES
The recommendations presented below were devel-
oped for minimizing hazardous waste at the source through
management and employee initiatives.
1. Provide routine waste reduction training for operat-
ing employees.
2. Establish an incentive compensation system whereby
employees are rewarded for reducing waste generation, in
47
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proportion to the reduction in the company's waste man-
agement costs.
POTENTIAL ECONOMIC BENEFITS
The potential economic benefits of implementing the
recommended waste source reduction and recycling tech-
niques, described above were assessed by comparing the
annual implementation costs and the resulting annual
savings in waste disposal costs. The estimated implemen-
tation costs include the capital cost for any new equipment
or plant improvements, as well as the operation and main-
tenancecosts associated with the recommended technique.
The capital cost was annualized using an interest rate of 10
percent and a 30 year period. The annual implementation
costis the sum of the annualized capital cost and the annual
operation and maintenance costs.
Recommendations 1 through 4 under Liquid Waste
Source reduction techniques were combined for the eco-
nomic benefit assessment because they are all closely
related and pertain to the reduction of equipment rinse
water and floor wash water. The estimated implementation
cost for these techniques is approximately $8,400 per year,
the majority of which is for the installation, operation, and
maintenance of spent rinse water collection systems to
facilitate repeat use of the rinse water. Based on a unit
disposal cost of $0.72/gallon, the implementation of these
techniques would have to result in a wastewater reduction
of almost 11,700 gallons per year to offset the implemen-
tation cost. This reduction represents approximately 60
pcrcentofthecurrent wastewater generation by equipment
rinsing and floor washing operations. The success of these
waste reduction techniques will mainly hinge on the effec-
tiveness of repetitive use of the spent equipment rinse
water, and consideration should be given to trial implem-
entation of this technique on one of the pesticide formulat-
ing operations. The trial implementation would involve
the installation of a temporary collection and storage
system for the spent rinse water for subsequent reuse. It
would also involve testing of repetitive use of the spent
rinse water to determine the number of rinse cycles that
could be used before the rinse water becomes too contami-
nated to allow effective rinsing.
Recommendation 5 under Liquid Waste Source re-
duction techniques involves theuseof disposable coveralls
such as Tyvek suits, rather than cotton coveralls, to
minimize the volume of laundry wastewater. Because the
disposable coveralls do not generally breathe as well as the
cotton coveralls, they would likely be too uncomfortable
during the warmer months of June through September.
However, the use of disposable coveralls during the remain
ing months would minimize the volume of laundry waste-
water. Assuming the use of 120 Tyveks per day for 165
days per year, the annual cost for the Tyveks would be
approximately $47,000. The disposal cost for the used
Tyveks as a hazardous waste would be about $12,000 per
year. In addition, the disposal cost for the laundry waste-
water generated during the months of June through Sep-
tember based on a unit disposal cost of $0.72/gallon would
b e approximately $106,000. Therefore, the total cost of
using disposable coveralls except during the four warmer
months of the year would be about $165,000. At present,
the annual disposal cost for the laundry wastewater is
approximately $318,000, based on a unit disposal cost of
$0.72/gallon. Consequently, the use of the disposable
coveralls as described above would result in an annual
savings of about $153,000. Although this recommendat
ion appears to be very economically beneficial, Plant C
should regularly evaluate the impact of the landfill ban
program which could eventually prohibit landfill disposal
of the contaminated Tyvek suits. In evaluating this recom-
mendation, Plant C should also consider the waste classi-
fication of the Tyvek suits. Characterization of the con-
taminated Tyveks should be performed, as recommended
for the pesticide-contaminated rags generated by Plant B,
to determine the waste classification arid appropriate waste
disposal method.
Recommendation 6 under Liquid Waste Source re-
duction techniques consists of the sampling andanalysis of
the boiler and cooling tower blowddwns to determine if
these waste streams are characteristic hazardous wastes.
At present, these waste streams, which combined amount
to 24,000 gallons per year, are disposed of as a hazardous
waste at an annual cost of approximately $17,000. The
collection and analysis of four samples of each of the two
waste streams are recommended to provide a representa-
tive database for the hazardous waste determination. The
estimated cost for collecting and analyzing eight samples
for pesticides analysis is approximately $8,000. If these
waste streams are found to be nonhazardous, then these
waste streams could possibly be discharged to one of the
existing septic tanks/drainileld systems. The installation
of plumbing required for directing these waste streams to
the septic tanks is estimated to be about $4,000 (annualized
cost of approximately $400 per year). Therefore, as
nonhazardous wastes, these waste streams could be dis-
posed of at a cost of about $400 per year, with a first year
sampling and analysis cost of $8,000. These costrepresent
a savings of $8,600 during the firstyear of implementation,
and an annual savings of over $16,000 per year thereafter.
Recommendation 7 under Liquid Waste Source re-
duction techniques involves monitoring of stormwater
runoff flow and quality throughout die wet season. The
purpose of this monitoring program is to determine if the
runoff is nonhazardous, which may be die case particularly
in the latter portion of the wet season: In order to develop
a meaningful cost estimate for monitoring the stormwater
48
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runoff, an analysis of the drainage systems would be
required. This analysis may indicate that numerous moni-
toring locations may be warranted to adequately investi-
gate the potential contaminant source areas in the drainage
systems. Even though the costs of such a monitoring
program may be considerable, it is possible that it could be
easily offset by the savings that may berealizedin theevent
that some of the runoff is determined to be nonhazardous.
Under the Solid Waste Source reduction techniques,
the use of repetitive diluent flushing of granule and dust
mills rather than once through flushing was recommended.
The repetitive flushing would be performed with a smaller
volume of diluent than that used for the once through
flushing to minimize the volume of spent diluent gener-
ated. A meaningful cost analysis of this recommended
technique is not possible until a limited amount of trial
implementation is performed. Trial implementation would
involve the collection and repeated reuse of the diluent to
determine the number of flushes that can be performed
before the diluent becomes too contaminated to allow
effective cleaning of the mill.
Process wastewater treatability studies are currently
being performed to evaluate reuse of the treated effluent as
process water. The recommendation of continuing and
possibly expanding these studies is based on the significant
economic benefit that could potentially be obtained con-
sidering the high cost of liquid waste disposal as a hazard-
ous waste. If not currently being considered, the segrega-
tion and treatment of the lower strength wastewaters,
particularly stormwater runoff, may also be a very eco-
nomically attractive option compared to the option of
treating the combined process waste streams. This is
supported by the large volume of stormwater runoff, which
averages about 1,500,000 gallons per year and represents
approximately 75 percent of the combined liquid waste
volume.
At present, about $ 1.4 million is spent each year for the
disposal of the process wastewater, including runoff, as a
hazardous waste. Completion of the treatability and asso-
ciated engineering feasibility studies will be required to
perform a meaningful economic analysis of the various
wastewater segregation/treatment/recycle options relative
to the current wastewater disposal practice.
The recommended management/employee initiatives
to minimize hazardous waste generation presented involve
the provision of waste reduction training and incentive
compensation programs for operating employees. The
cost of these programs will depend on the level of training
to be provided, and the type and magnitude of the incentive
compensation systems. Further evaluation of the em-
ployee training needs and overall compensation system at
Plant C, as well as the anticipated waste management
savings resulting from the implementation of these pro-
grams, is required to perform a meaningful cost/benefit
analysis of this recommendation. Nevertheless, it is rea-
sonable to assume mat some long term benefit would be
gained in the form of reduced waste management costs by
implementing these types of employee programs.
49
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APPENDIX B
WHERE TO GET HELP
FURTHER INFORMATION ON POLLUTION PREVENTION
Additional information on sourcereduction, reuse and
recycling approaches to pollution prevention is available
in EPA reports listed in this section, and through state pro-
grams (listed below) that offer technical and/or financial
assistance in the areas of pollution prevention and treat-
ment.
In addition, waste exchanges have been established in
some areas of the U.S. to put waste generators in contact
with potential users of the waste. Four waste exchanges are
listed below. Finally, EPA's regional offices are listed.
EPA REPORTS ON WASTE
MINIMIZATION
U.S. Environmental Protection Agency. "Waste
Minimization AuditReport:CaseStudiesof Corrosive
and Heavy Metal Waste Minimization Audit at a
Specialty Steel Manufacturing Complex." Executive
Summary.*
U.S. Environmental Protection Agency. "Waste
Minimization Audit Report: Case Studies of
Minimization of Solvent Waste for Parts Cleaningand
frornElectronic Capacitor Manufacturing Operation."
Executive Summary.*
U.S. Environmental Protection Agency. "Waste
Minimization Audit Report: Case Studies of
Minimization of Cyanide Wastes from Electroplating
Operations." Executive Summary.*
U.S. Environmental Protection Agency. Report to
Congress: Waste Minimization, Vols. I and II. EPA/
530-SW-86-033 and -034 (Washington, D.C.: U.S.
EPA, 1986).**
U.S. Environmental Protection Agency. Waste
Minimization - Issues and Options, Vols. I-in EPA/
530-SW-86-041 through -043. (Washington, B.C.:
U.S. EPA, 1986).**
* Executive Summary available from EPA,
WMDDRD, RREL, 26 West Martin Luther King Drive,
Cincinnati, OH, 45268; full report available from the
National Technical Information Service (NTIS), U.S.
Department of Commerce, Springfield, VA 22161.
** Available from the National Technical Information
Service as a five-volume set, NTIS No. PB-87-114-328.
WASTE REDUCTION TECHNICAL/
FINANCIAL ASSISTANCE PROGRAMS
The EPA's Office of Solid Waste and Emergency Re-
sponse has set up a telephone call-in service to answer
questions regarding RCRA and Superfund (CERCLA):
(800) 242-9346 (outside the District of Columbia)
(202) 382-3000 (in the District of Columbia)
The following states have programs that offer technical
and/or financial assistance in the areas of waste minimiza-
tion and treatment
Alabama
Hazardous Material Management and Resources Recov-
ery Program
University of Alabama
P.O. Box 6373 .
Tuscaloosa, AL 35487-6373
(205) 348-8401
Alaska
Alaska Health Project
Waste Reduction Assistance Program
431 West Seventh Avenue, Suite 101,
Anchorage, AK 99501
(907) 276-2864
Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall ,
Little Rock, AR 72201
(501) 371-1370
California
Alternative Technology Section
Toxic Substances Control Division
California State Department of Health Service
714/744 P Street
Sacramento, CA 94234-7320
(916)324-1807
Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT 06105
(203) 244-2007
50
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Connecticut Department of Economic Development
210 Washington Street
Hartford, CT 06106
(203)566-7196
Georgia
Hazardous Waste Technical Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404) 894-3806
Environmental Protection Division
Georgia Department of Natural Resources
Floyd Towers East, Suite 1154
205 Butler Street
Atlanta, GA 30334
(404)656-2833 ......
Illinois
Hazardous Waste Research and Information Center
Illinois Department of Energy of Energy and Natural
Resources
1808 Woodfield Drive
Savoy^ IL 61874
(217)333-8940
Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Building, Room 102
Illinois Institute of Technology
3200 South Federal Street
Chicago, IL 60616
(313)567-3535
Indiana
Environmental Management and Education Program
Young Graduate House, Room 120
Purdue University
West Lafayette, IN 47907
(317)494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-8172 - ... .
Iowa
Center for Industrial Research and Service
205 Engineering Annex
Iowa State University
Ames, IA 50011
(515)294-3420 ,
Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515) 281-8690
Kansas
Bureau of Waste Management
Department of Health and Environment
Forbes Field, Building 730
Topeka, KS 66620
(913) 269-1607
Kentucky
Division of Waste Management
Natural Resources and Environmental
Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716
Louisiana
Department of Environmental Quality
Office of Solid and Hazardous Waste
P.O. Box 44307
Baton Rouge, LA 70804
(504) 342-1354
Maryland
Maryland Hazardous Waste Facilities Siting Board
60 West Street, Suite 200 A
Annapolis, MD 21401
(301) 974-3432
Maryland Environmental Service
2020 Industrial Drive
Annapolis, MD 21401
(301) 269-3291
(800) 492-9188 (in Maryland)
Massachusetts
Office of Safe Waste Management
Department of Environmental Management
100 Cambridge Street, Room 1094
Boston, MA 02202
(617) 727-3260
Source Reduction Program
Massachusetts Department of Environmental Quality En-
gineering
I Winter Street
Boston, MA 02108
(617) 292-5982
51
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Michigan
Resource Recovery Section
Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-0540
Minnesota
Minnesota Pollution Control Agency
Solid and Hazardous Waste Division
520 Lafayette Road
St. Paul, MN 55155
(612)296-6300
Minnesota Technical Assistance Program
W-140 Boynton Health Service
University of Minnesota
Minneapolis, MN 55455
(612) 625-9677
(800) 247-0015 (in Minnesota)
Minnesota Waste Management Board
123 Thorson Center
7323 Fifty-Eighth Avenue North
Crystal, MN 55428
(612) 536-0816
Missouri
State Environmental Improvement and Energy
Resources Agency
P.O. Box 744
Jefferson City, MO 65102
(314) 751-4919
New Jersey
New Jersey Hazardous Waste Facilities Siting
Commission
Room 614
28 West State Street
Trenton, NJ 08608
(609) 292-1459
(609) 292-1026
Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental
Protection
401 East State Street
Trenton, NJ 08625
Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ 08625
New York
New York State Environmental Facilities
Corporation
50 Wolf Road
Albany, NY 12205
(518)457-3273
North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and
Community Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611
(919) 733-7015
Governor's Waste Management Board
325 North Salisbury Street
Raleigh, NC 27611
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Releigh,NC 27602
(919) 733-2178
Ohio
Division of Solid and Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 WaterMark Drive
Columbus, OH 43266-1049
(614)481-7200
Ohio Technology Transfer Organization
Suite 200
65 East State Street
Columbus, OH 43266-0330
(614)466-4286
Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK 73152
(405) 271-7353
Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913
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Pennsylvania
Pennsylvania Technical Assistance Program
501F. Orvis Keller Building
University Park, PA 16802
(814) 865-0427
Center of Hazardous Material Research
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
Bureau of Waste Management
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Fulton Building
3rd and Locust Streets
Harrisburg, PA 17120
(717) 787-6239
Rhode Island
Ocean State Cleanup and Recycling Program
Rhode Island Department of Environmental Management
9 Hayes Street
Providence, RI02908-5003
(401) 277-3434
(800) 253-2674 (in Rhode Island)
Center for Environmental Studies
Brown University
P.O. Box 1943
135 Angell Street
Providence, RI 02912
(401) 863-3449
Tennessee
Center for Industrial Services
102 Alumni Hall
University of Tennessee
Knoxville.TN 37996
(615) 974-2456
Virginia
Office of Policy and Planning
Virginia Department of Waste Management
11 th Floor, Monroe Building
101 North 14th Street
Richmond, VA 23219
(804) 225-2667
Washington
Hazardous Waste Section
Mail Stop PV-11
Washington Department of Ecology
Olympia, WA 98504-8711
(206) 459-6322
Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
101 South Webster Street
Madison, WI53707
(608)267-3763
Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Herchler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752
WASTE EXCHANGES
Northeast Industrial Exchange
90 Presidential Plaza, Syracuse, NY 13202
(315)422-6572
Southern Waste Information Exchange
P.O. Box 6487, Tallahassee, FL 32313
(904) 644-5516
Great Lake Regional Waste Exchange
470 Market Street, Grand Rapids, MI 49503
(616)451-8922
California Waste Exchange
Department of Health Services
Toxic Substances Control Division
Alternative Technology & Policy Development Section
714 P Street
Sacramento, CA 95814
(916) 324-1807
U.S. EPA REGIONAL OFFICES
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203
(617) 565-3715
Region 2 (NY, NJ)
26 Federal Plaza
New York, NY 10278
(212) 264-2525
Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-9800
53
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Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, NE
Atlanta, GA 30365
(404) 347-4727
Region 5 (WI, MM, MI, IL, IN, OH)
230 South Dearborn Street
Chicago, IL 60604
(312) 353-2000
Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX 75202
(214) 655-6444
Region 7 (ME, KS, MO, IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913)236-2800
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603
Region9(CA,NV,AZ,HI)
215 Fremont Street
San Francisco, CA 94105
(415) 974-8071
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206)442-5810
54
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