vvEPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/625/R-93/006
October 1993
Guides to Pollution
Prevention
Municipal Pretreatment
Programs
-------
-------
EPA/625/R-93/006
October 1993
Guides to Pollution Prevention:
Municipal Pretreatment Programs
U.S. Environmental Protection Agency
Office of Research and Development
Center for Environmental Research Information
Cincinnati, Ohio
Printed on Recycled Paper
-------
Notice
The information in this document has been funded wholly or in part by the U.S. Environmental Protection Agency
(EPA). This document has been reviewed in accordance with the Agency's peer and administrative review policies
and approved for publication. Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
-------
Acknowledgments
This guide is the product of the efforts of many individuals. Gratitude goes to each person involved in the ,
preparation and review of this guide.
Authors
Lynn Knight and David Loughran, Eastern Research Group, Inc., Lexington, MA, and Daniel Murray, U.S. EPA,
Office of Research and Development, Center for Environmental Research Information were the principal authors
of this guide.
Technical Contributors
The following individuals provided invaluable technical assistance during the development of this guide:
Cathy Allen, U.S. EPA, Region V, Chicago, IL
Deborah Hanlon, U.S. EPA, Office of Research and Development, Washington, DC
William Fahey, Massachusetts Water Resources Authority, Boston, MA
Eric Renda, Massachusetts Water Resources Authority, Boston, MA
Timothy Tuominen, Western Lake Superior Sanitary District, Duluth, MN r
A.R. Rubin, North Carolina Cooperative Extension Service, North Carolina State University, Raleigh, NC
Peter Scott, Linn-Benton Community College, Science and Industry Division, Albany, OR
Foster Gray, Ithaca Area Wastewater Treatment Plant, Ithaca, NY
Adriana Renescu, County Sanitation Districts of Orange County, Fountain Valley, CA
Guy Aydlett, Hampton Roads Sanitation District, Virginia Beach, VA
Sam Hadeed, Association of Metropolitan Sewerage Agencies, Technical Services and Regulatory Affairs,
Washington, DC
Philip Lo, County Sanitation Districts of Los Angeles County, Whittier, CA
Matt Chadsey, Palo Alto Regional Water Quality Control Plant
Rick Riebstein, Massachusetts Department of Environmental Protection, Office of Technical Assistance
Paul Richard, Massachusetts Department of Environmental Protection, Office of Technical Assistance
Peer Reviewers
The following individuals peer reviewed this guide:
H. Douglas Williams, U.S. EPA, Office of Research and Development, Center for Environmental Research
Information, Cincinnati, OH
Garry Howell, U.S. EPA, Office of Research and Development, Risk Reduction Engineering Laboratory,
Cincinnati, OH
Johnny Springer, Jr., Office of Research and Development, Risk Reduction Engineering Laboratory, Cincinnati, OH
in
-------
Editorial Reviewers and Document Production
John Bergin and David Cheda of Eastern Research Group, Inc., Lexington, MA, provided editorial review and
produced this Handbook.
Technical Direction and Coordination
Daniel Murray, U.S. EPA, Office of Research and Development, Center for Environmental Research Information,
Cincinnati, OH, coordinated the preparation of this guide and provided technical direction throughout its
development.
IV
-------
Contents
Page
Chapter 1 Introduction 1
Chapter 2 Overview of Pollution Prevention Concepts 4
2.1 Source Reduction 4
2.1.1 Good Operating Practices , 4
2.1.2 Technology Changes 6
2.1.3 Input Material Substitutions 6
2.1.4 Product Changes . 7
2.2 Recycling 7
Chapter 3 Targeting Pollution Prevention Efforts... . 9
3.1 Identifying Pollutants of Concern 9
3.2 Identifying Users of Concern 11
3.2.1 Industrial Users 11
3.2.2 Commercial Users 12
3.2.3 Domestic Users ... 14
3.3 Prioritizing Users of Concern 14
3.4 Utilizing Pollution Prevention Resources 14
Chapter 4 Promoting Pollution Prevention Among Regulated and Unregulated Sewer Users 19
4.1 Inspections 19
4.1.1 Preinspection Activities 19
4.1.2 Inspection Procedures 24
4.1.3 Postinspection Followup 27
4.1.4 Multimedia Inspections 27
4.2 Encouraging Pollution Prevention Through Regulatory Activities 28
4.2.1 Issuing User Permits 28
4.2.2 Responding to User Noncompliance 31
-------
Contents (continued)
Page
4.3 Community Education and Outreach... 31
4.3.1 Sponsoring Workshops and Training 32
4.3.2 Convening Local Pollution Prevention Forums 32
4.3.3 Publicly Recognizing Pollution Prevention Achievements 33
4.3.4 Compiling and Distributing Pollution Prevention Information 33
4.3.5 Publicizing Household Hazardous Waste Collection Programs and
Industrial Waste Exchanges 34
Chapter 5 References 35
Appendix A Pollution Prevention Resources 37
Appendix B Pollution Prevention Summaries on Specific Industries 49
Automotive-Related Industry 50
Commercial Printing 53
Fabricated Metal Products 56
Industrial and Commercial Laundries 61
Paint Manufacturing 63
Pesticide Formulation . 66
Pharmaceuticals Manufacturing 69
Photoprocessing 72
Printed Circuit Board Manufacturing 75
Selected Hospital Waste Streams 79
vi
-------
List of Tables
Table
Page
3-1 Commercial Establishments and Their Potentially Hazardous Discharges 12
3-2 Consumer Products and Their Potentially Toxic or Hazardous Constituents . . . 15
3-3 States with Existing or Proposed Pollution Prevention Technical Assistance and
Facility Planning and Reporting Requirements 18
4-1 Sample Materials Accounting List for a Photoprocessing Example 22
4-2 Sample Pollution Prevention List for Photoprocessing Example 25
B-1 Wastes Generated from Automotive Shops 50
B-2 Wastewater Generated by Printing Processes .....' 53
B-3 Metal Fabrication Processes: Cleaning, Stripping, and Painting . . . 56
B-4 Metal Fabrication Processes: Machining, Surface Treatment and Plating . 57
B-5 Aqueous/Liquid Wastes from Metal Parts and Stripping 58
B-6 Aqueous/Liquid Wastes from Electroplating and Other Surface Treatment Processes 59
B-7 Aqueous/Liquid Wastes from Paint Manufacturing 63
B-8 Aqueous/Liquid Wastes from Pesticide Formulation 66
B-9 Aqueous/Liquid Waste from Pharmaceuticals Manufacturing 69
B-10 Aqueous Wastes Generated from Photoprocessing 72
B-11 Nine Stages in Printed Circuit Board Manufacturing 75
B-12 Waste Streams Generated from Circuit Board Manufacturing Processes 76
B-13 Drag-Out Reduction Techniques 77
B-14 Rinsing Techniques 77
B-15 Selected Waste Streams from Hospitals 80
VII
-------
List of Figures
Figure
2-1
3-1
3-2
3-3
4-1
4-2
4-3
4-4
4-5
4-6
Page
Pollution prevention .5
Sample POTW pollution prevention policy statement ................ - 10
Setting pollution prevention priorities . . . . . 11
Example of a commercial facility survey form -. , 13
Using onsite inspection to promote the benefits of pollution prevention 20
Sample flow diagram of photoprocessihg Operation 22
Tracking the silver material balance in a color photoprocessing operation . 23
Comparing silver input and output in a photoprocessing operation 24
Hypothetical waste stream concentrations before and after pollution prevention 31
Example of compliance schedule that incorporates pollution prevention . 32
viii
-------
Chapter1
Introduction
With the enactment of the Pollution Prevention Act of
1990, Congress formally established pollution
prevention as a national objective, placing it ahead of
waste recycling, treatment, and disposal in the
hierarchy of environmental management methods. The
Act directs the U.S. Environmental Protection Agency
(EPA) to integrate pollution prevention concepts fully
into all its regulatory programs. A preventive approach
to environmental protection can lead to improvements
in environmental quality and economic efficiency by
reducing harmful pollutants at the source through
cost-effective changes in production, operation, and raw
material use. This approach changes the focus from
managing waste after it is generated to eliminating or
minimizing the problem before it occurs.
EPA defines pollution prevention as waste reduction
prior to recycling, treatment, or disposal. Recycling
conducted within a process, such as closed loop
rinsewater recycling, is also considered pollution
prevention. Waste recycling, which takes place outside
the process, is not considered pollution prevention,
although when conducted in an environmentally safe
manner it achieves the same goal as pollution
prevention by reducing the need for treatment and
disposal.
Pretreatment personnel at publicly owned treatment
works (POTWs) can broaden their approach to meeting
the goals of the National Pretreatment Program by
encouraging pollution prevention measures among
sewer users. This guide is designed to assist POTW
personnel in formulating strategies for promoting
pollution prevention as another tool for meeting the
goals of municipal pretreatment programs. The main
objective is to help pretreatment program personnel
educate industrial users about the benefits of pollution
prevention and encourage them to assess and
implement pollution prevention in their own operations.
Pollution prevention can assist industries in meeting
sewer discharge limits and protecting POTW worker
health and safety.
This guide provides an overview of pollution prevention
concepts (Chapter 2), presents a way to identify and
prioritize industries as candidates for pollution
prevention (Chapter 3), and outlines a broadly
applicable approach to integrating pollution prevention
concepts into existing pretreatment programs (Chapter
4). Appendix A contains a comprehensive list of pollution
prevention resources. Appendix B is a collection of
summaries that identify pollution prevention opportunities
in industries of particular concern to POTWs.
Why should POTWs encourage pollution
prevention?
POTWs are the recipients of a large portion of the
nation's industrial wastewater, receiving discharges
from an estimated 30,000 significant industrial users.
These industrial users discharge the full spectrum of
heavy metals, volatile organics, and other contaminants
that can degrade environmental quality and pose health
and safety risks to POTW workers. Even if there were
full compliance with categorical pretreatment standards,
EPA estimates that categorical industrial users would
continue to discharge 14 million pounds of toxic metals
and 51 million pounds of toxic organic pollutants to
POTWs each year (U.S. EPA, 1991c). Small industrial
users, commercial establishments, domestic sources,
and storm water also contribute to the waste load
received by POTWs.
Personnel at POTWs have many opportunities to
encourage industries to adopt pollution prevention
measures. More than any other public authority, POTW
pretreatment program personnel maintain close contact
with local sewer dischargers and have an
understanding of their specific industrial process
operations and waste streams. Through requiring spill
prevention plans and toxic organic management plans
(TOMPs) and including best management practice
(BMP) conditions in permits, POTWs are already
involved in promoting pollution prevention. By further
integrating pollution prevention concepts into existing
pretreatment program activities, POTW personnel can
help industrial and commercial facilities identify pollution
prevention opportunities, encourage them to assess
these opportunities in greater detail, and, in general,
heighten their awareness of pollution prevention as
another means of meeting their permit requirements.
-------
Pollution prevention offers substantial benefits to
POTWs. By further reducing the quantity and toxicity of
user discharges, pollution prevention can help POTWs:
Meet federal and state environmental quality
standards, including sludge disposal requirements,
current or future toxic air emission requirements, and
National Pollutant Discharge Elimination System
(NPDES) permit requirements.
Reduce the transfer of influent contaminants from
one environmental medium (e.g., wastewater) to
others (e.g., land, surface and ground water, and air).
Increase POTW worker safety and reduce collection
system hazards from toxic or hazardous gases.
Further reduce the occurrences of interference and
pass-through.
Reduce expensive sludge management costs.
Reduce the impacts from dischargers that might view
sewers as the answer to their own waste
management problems.
Maintain pollutant loads at levels that will satisfy
increasing demands for sewer system services from
industrial, commercial, and domestic sectors.
How does a POTW promote the benefits
of pollution prevention to businesses?
Industrial and commercial facilities also can benefit from
pollution prevention. In many cases, pollution
prevention might be the least expensive means of
reducing unacceptable toxic discharges. Pretreatment
personnel can point out the benefits of pollution
prevention to their sewer users. Through pollution
prevention, companies can:
Reduce waste monitoring, treatment, and disposal
costs.
Reduce raw-material use, feed stock purchases, and
manufacturing costs.
Reduce operation and maintenance costs.
Increase productivity and reduce off-specification
products.
Reduce regulatory compliance costs.
Reduce hazards to employees through exposure to
chemicals.
Reduce costs of environmental impairment insurance.
Improve public image and employee morale.
Reduce potential liability associated with toxic waste.
What are some of the impediments to
promoting pollution prevention among
sewer dischargers?
In implementing the General Pretreatment Regulations,
POTWs should have authority to promote pollution
prevention in a number of capacities, such as requiring
spill control plans and TOMPs. To incorporate pollution
prevention planning or other pollution prevention
requirements into permitting and enforcement actions,
however, POTWs might need to expand their authority.
During inspections, POTW personnel can encourage
industrial users to conduct pollution prevention
assessments or consider specific types of measures,
but it is not advisable to recommend or approve specific
measures. By recommending a particular pollution
prevention measure, POTW personnel may lead the
facility to believe that implementing that measure will
guarantee compliance. (See Section 4.1.2.3 for a
discussion of issues related to giving pollution
prevention advice.)
POTWs might also encounter the following
impediments:
Businesses might have assessed and implemented
low-cost pollution prevention techniques already as
general operating efficiency and cost-control
measures. Furthering pollution prevention might
involve unfamiliar techniques that require a more
intensive evaluation and more capital. Companies
might be skeptical of the potential benefits or might
be unwilling or unable to invest the necessary funds.
Businesses may have a predisposition to control
technologies because these are familiar and
traditional ways of dealing with waste problems; or a
firm might have recently made substantial
investments in treatment technologies. In these
cases, pretreatment personnel can educate business
personnel about how pollution prevention alternatives
can increase removal efficiencies and reduce
operating and maintenance costs of existing
treatment systems.
POTWs might have difficulty persuading municipal
officials that activities promoting pollution prevention
are integral to meeting the goals of the local
pretreatment program and that funding for pollution
prevention initiatives is needed to meet these goals.
Training resources and additional support will
enhance greatly the ability of the POTW to effectively
promote pollution prevention among its users.
-------
What are the key elements to successful
integration of pollution prevention into
pretreatment programs?
As POTWs begin to incorporate the concepts of
pollution prevention into municipal pretreatment
programs, success will depend on a few key elements.
Each POTW will face unique challenges, both internally
and externally, as it moves to integrate pollution
prevention into its daily program activities. Regardless
of the uniqueness of the challenges faced by each
POTW, key elements for succeeding will likely be
consistent for all POTWs.
POTWs will increase the chances of successful and,
more importantly, effective use of pollution prevention
concepts by keeping in mind the following:
Seek to integrate pollution prevention into existing
program activities, rather than viewing the adoption
of pollution prevention concepts as an additional
program requirement. In this manner, pollution
prevention will be incorporated into the program in
an efficient manner.
While every effort should be made by POTWs to
integrate pollution prevention into ongoing
pretreatment program activities, additional time and
resources will be needed to modify existing
pretreatment program activities and provide
assistance and direction to industrial and commercial
sewer users. At first, POTW personnel can slowly
phase in changes to existing activities. This approach
requires minimal new resources and will allow the
pollution prevention mindset to take hold through an
evolutionary process. POTW pollution prevention
efforts may be eligible for grants available at the
federal and state level. POTWs should contact their
EPA regional office and state pollution prevention
programs (see Appendix A) for information on
available grants.
Define goals and measure success in small,
attainable increments. This is especially important
during the initial stages of adopting pollution
prevention concepts. This can be best accomplished,
as described later, with short-term, narrowly focused
efforts that can illustrate the benefits of pollution
prevention and build support for a more broadly
applied program. Guidance has been developed to
assist in measuring the success of pollution
prevention efforts (U.S. EPA, 1989).
Provide a wide range of incentives to industrial and
commercial sewer users to adopt pollution prevention
as part of their environmental control programs.
These incentives should cover the wide range of
options and use the authorities available to the
POTW. Public recognition programs that use some
type of "green industry" moniker can be used. In
addition, the POTW can use enforcement discretion,
which is inherent in a pretreatment program, to
provide incentives to pursue pollution prevention
projects. Regardless of the nature of the incentives
used, they can be effective tools for persuading
sewer users to investigate pollution prevention
measures.
-------
Chapter 2
Overview of Pollution Prevention Concepts
Pollution prevention encompasses both source
reduction and in-process recycling. The Pollution
Prevention Act of 1990 defines source reduction as any
practice that reduces the amount of any hazardous
substance, pollutant, or contaminant entering any waste
stream (including fugitive emissions) prior to recycling,
treatment, or disposal, and that reduces the hazards to
public health and the environment associated with the
release of such substances, pollutants, or
contaminants. The Act declares that governments,
businesses and industries, and individuals should
prevent or reduce pollution at its source wherever
feasible. Where source reduction cannot be achieved,
the Act advocates that responsible parties reuse and
recycle to reduce the quantity of hazardous waste
requiring treatment. If there are no feasible pollution
prevention alternatives, environmentally sound
treatment should be applied with disposal used only as
a last resort. Techniques that merely transfer
contaminants from one medium to another without a net
reduction in the quantity and toxicity of hazardous
constituents do not meet the definition of pollution
prevention. This chapter describes and gives examples
of the various pollution prevention measures
encompassed in source reduction and recycling.
Pollution prevention techniques related to specific
industries are described in Appendix B.
2.1 Source Reduction
Source reduction lessens or eliminates the quantity of
hazardous and toxic wastes generated and the expense
and environmental impacts associated with managing
these wastes. In addition, source reduction usually
results in significant cost savings realized from raw
material conservation. Source reduction encompasses
good operating practices, technology changes, input
material substitutions, and product changes (see Figure
2-1).
2.1.1 Good Operating Practices
In general, industries can realize a high return from a
minimal investment by implementing good operating
practices. Good operating practices are procedural,
administrative, and institutional measures, which
include improving inventory control, preventing
accidental spills, segregating waste streams, and
scheduling production runs that maximize production
and minimize waste. Getting management to commit to
pollution prevention is a first step toward instituting an
effective source reduction program. This commitment
might be demonstrated by a written policy statement
circulated to company employees and posted in visible
locations and by encouraging employees to adopt the
principles of pollution prevention. Demonstrating
management's dedication to pollution prevention and its
importance to company operations can galvanize the
work force and help employees view pollution
prevention as a priority in their everyday work activities.
Other management and personnel practices, such as
employee training, incentives, and bonuses, also can
encourage employees to reduce waste.
Maintaining an orderly inventory system and proper
storage conditions can greatly reduce material waste
from deterioration, inefficient use, and spills. For
example, an inventory system that employs a
"first-in/first-out" management method and keeps a 1-
or 2-month supply of materials is less likely to result in
material disposal because of product expiration.
Implementing a materials tracking system that tracks
material use by individual employees or work groups
allows managers to identify individuals or production
teams with above-average materials use. Using
tight-fitting lids and spill-proof containers with spigots,
minimizing traffic, and employing proper environmental
controls in storage areas also will extend material
supplies and prevent spills. Frequent inventory
inspections will result in early detection of leaks and
spills.
Other good housekeeping practices include containing
and reusing materials dripped from parts as they are
transferred during a process and providing funnels or
other equipment that avoids spills when transferring
materials. Regularly scheduled preventative
maintenance reduces the occurrence of malfunctions
and leaks, which will reduce the volume of wastes
discharged to the sewers. Modifying production
schedules to minimize required equipment changeovers
will reduce the quantity of wastes generated by
-------
Figure 2-1. Pollution prevention.
equipment cleaning. Segregating hazardous and
nonhazardous waste streams avoids making the entire
waste stream hazardous and reduces the volume of
waste requiring treatment or costly disposal. Also,
maintaining separate waste streams can enhance the
industry's ability to reuse or reclaim waste materials. For
example, by not mixing two different spent solvents, the
purity of the waste materials is maintained, making
recycling easier.
Another action, often overlooked, is examining the
cleaning products (e.g., cleaners, degreasers, and floor
finishes) used by a company to determine whether they
are contributing to the toxic loadings in wastewater
when discharged through sink and floor drains.
Cleaning products with toxic constituents can be
replaced with substitutes that do not contain harmful
elements. A good housekeeping program should
include a review of the cleaning products used in house.
Many companies use good operating practices as a first
step toward reducing toxic materials use; for example:
A large consumer product company in California
adopted a corporate, policy to minimize hazardous
waste generation. To implement the policy, the company
created quality circles made up of employees from each
area that generated hazardous waste within the plant.
With their considerable knowledge of particular'
manufacturing and administrative procedures, these
quality circles were able to suggest a number of
institutional changes, such as the adoption of proper
maintenance procedures. The teams supervised the
implementation of these procedures in their own
production areas. The use of proper maintenance
procedures alone led to a 75 percent reduction in
hazardous and nonhazardous waste generation (U.S.
EPA, 1988).
-------
2.1.2 Technology Changes
Technology changes can range from minor
modifications to existing processes, to major
investments in new manufacturing equipment.
Technology changes involve changes in any of the
following areas:
Production processes.
Equipment, layout, or piping.
Use of automation.
Process operating conditions, such as flow rates,,
temperatures, pressures, and residence times.
Production processes can be modified to eliminate the
need to change over equipment if a unit can be
dedicated to one process. Mechanical methods can be
used in lieu of solvent use for cleaning and stripping
parts. Various process changes can be implemented to
reduce drag-out of process solutions, including
adjusting the speed of withdrawal of the part from the
process solution, allowing more time for the part to drip,
and positioning the part to maximize runoff of the
solution.
Many companies have experimented with technology
changes to prevent pollution. Here are just a few
examples:
Hill Air Force Base, in Ogden, Utah, strips paints from
Its aircraft with plastic bead "sand blasting," rather than
using more traditional toxic solvents. The Air Force base
can use the plastic beads over and over. In 1986, the
Air Force base estimated that, for each plane,
mechanical stripping saved 302 person hours, $5,076
in raw materials, $935 in disposal costs, $1,485 in
wastewater treatment costs, and $104 in energy costs
(Sherry, 1988b).
In July 1989, Ford Motor Company in Plymouth,
Michigan, implemented a cyanide-free, no-rinse
chromate coating process for its aluminum parts. The
previous chromate coating process produced 14,000 to
17,000 gallons of wastewater per day, which was sent
to the plant's pretreatment facility. The pretreatment
process produced waste sludge containing between 0.1
to 0.5 percent total cyanide, which exceeds allowable
limits for disposal in landfills. The no-rinse system
produces only 3,000 gallons of wastewater per day, has
eliminated all forms of cyanide from the process and
wastewater sludge, and achieves superior coating
application results. Ford has realized savings in
reduced pretreatment costs and elimination of cyanide-
contaminated sludge disposal costs. Ford has since
implemented the no-rinse system in three other plants
(U.S. EPA, 1991a).
New Dimensions Plating, Inc., in Hutchinson,
Minnesota, electroplates a variety of metals with
chromium, copper, and nickel. Although New
Dimensions was meeting current pretreatment
regulations, the facility decided to investigate drag-out
reduction techniques in order to reduce pretreatment
costs. To reduce chromium drag-out, New Dimensions
constructed drip bars to allow for greater drip time. The
facility also constructed several evaporators to reduce
the volume of water in the plating and stagnant rinse
tanks to allow all of the spray rinse solution and some
of the rinsewater to be returned to the rinse tank each
day. Recovered drag-out solutions pass through an
electropurification module to remove contaminants
before returning to the original plating bath. As a result
of the new plating system, chromium drag-out has been
reduced from 7 pounds per day to 1 pound per day. New
Dimensions has benefitted from reduced chromium
content in pretreatment sludge and savings of $7,000
annually in reduced chromium and treatment chemical
purchases (MPCA and WLSSD, 1992).
2.1.3 Input Material Substitutions
This technique involves replacing the input material that
contains a problem pollutant with a different material
that performs the same function without generating a
toxic or hazardous waste. Input material substitutions
reduce or eliminate the problem pollutants that enter the
production process. Input modifications that avoid the
generation of problem wastes during production also fall
under this source reduction category. Process changes
might sometimes be required to accommodate input
material changes. Examples of input material
substitution include:
United Piece Dye Works of Edenton, North Carolina,
met stringent effluent discharge limits on phosphorus by
making chemical substitutions in the production process
rather than building expensive treatment systems. The
company conducted a detailed evaluation of production
processes, process chemistry, and the chemicals used
to identify sources of phosphorus. It then made process
modifications to reduce use of phosphate chemicals by
substituting chemicals not containing phosphate. For
example, the use of hexametaphosphate was reduced
and the use of phosphoric acid was eliminated. These
chemical substitutions reduced the level of phosphorus
in the company's wastewater from 7.7mg/l to less than
1 mg/l. This reduction was achieved without any capital
expenditures for phosphorus removal (PPIC, 1992).
IBM's Research Triangle Park plant in Durham, North
Carolina, established an active program to reduce the
generation of waste through material substitutions and
process modifications. IBM eliminated the discharge of
wastewater containing toxic biocides by using ozone
rather than biocides to control algae and bacterial
growth in cooling towers. This substitution has
eliminated the presence of toxic biocide concentrations
6
-------
in the plant's wastewater and hence reduced IBM's
pretreatment costs. IBM estimates it saves $120,000
per year in sludge dewatering costs alone (PPIC, 1992).
In an effort to reduce chrome concentrations in
wastewater, Granite State Leathers modified its leather
tanning process to accommodate a new tanning agent,
which contains roughly two-thirds less chromic oxide
than the previous tanning agent. In addition, the need
for chrome retanning has been eliminated because
chrome retention in the first tanning wash is 10 times
better. The concentration of chromic oxide in the
wastewaters has been reduced from about 10 ppm to
less than 1 ppm. Granite State estimates it saves
between $40,000 and $50,000 per year in avoided
wastewater treatment costs (PPIC, 1992).
Garnkonst Metalworkihg Company in Landskrona,
Sweden, implemented material substitutions in one
process to make possible a material substitution in
another process. Garnkonst replaced mineral oil-based
metalworking fluids with a vegetable oil-based
substitute. This substitution allowed the facility to
substitute an alkaline detergent solution in place of toxic
trichloroethylene and mineral solvents for parts
degreasing. The substitutions have reduced
trichloroethylene and mineral solvent concentrations in
air and wastewater dramatically. The switch to
vegetable-based oil from mineral oil saves $5,000 per
year in material costs and the company saves $59,000
annually in avoided trichlorethylene waste-management
costs (PPIC, 1992).
2.1.4 Product Changes
A final source reduction technique consists of product
modifications. By altering the product in such a way that
the problem pollutant is no longer required in the
production process, businesses can eliminate
generating the problem waste. Product modifications
also can reduce environmental releases of problem
pollutants related to the use of a particular product.
Product change generally falls into one of three
categories: product substitution (e.g., an entirely new
product); changes in product composition (e.g., minor
modification to an existing product); and product
conservation (e.g., increasing the working life of an
existing product). Examples of product changes include:
The paint manufacturing industry has taken steps to
reformulate its products to reduce hazardous
constituents. Paint manufacturers have continued to
improve water-based paints and find applications for
them that were previously dominated by solvent-based
paints. Water-based paints do not contain toxic or
flammable solvents that contribute to the potential
hazards of solvent-based paints. The use of
water-based paints eliminates discharge to sewers of
volatile organics in rinsewater from production-line
cleaning operations. In addition, volatile organics are
not released to the atmosphere by water-based paints
(U.S. EPA, 1988).
In 1988, at its Waltham, Massachusetts, plant, Polaroid
began manufacturing batteries without mercury, these
batteries are imbedded into film packs. Although
eliminating the mercury in the batteries reduces slightly
the voltage and the shelf life of the batteries, these
changes in product attributes do not affect product
performance. Polaroid originally made this change to
the product at other plants in response to regulations in
another country that forced them to remove the mercury.
At the Waltham plant, mercury in the wastewater from
the battery manufacturing process has been eliminated
(MWRA, 1992).
2.2 Recycling
Recycling options involve the reuse and reclamation of
spent input materials, such as solvents, detergents,
inks, and other chemicals (see Figure 2-1). Reuse
substitutes spent input materials for new input materials
in the manufacturing process. Reclamation, on the other
hand, recovers valuable material from spent input
materials for incorporation in some other process or
product. Recycling can be integrated within the process
through a closed loop system or can be conducted
separately, using centralized onsite waste recycling
systems or commercial materials recyclers. Waste
reprocessed or reclaimed can be used on site or sold
or given to other businesses for use in their operations.
Some states maintain networks to facilitate waste
exchanges (see Appendix A). The following examples
illustrate recycling initiatives:
Mao/a Milkandlce Cream Company in New Bern, North
Carolina, recovers ice cream and milk products for
reuse in ice cream products and animal feed. Initial
reuse activities in 1986 prevented the loss of over
17,000 pounds of milk and decreased 5-day
biochemical oxygen demand (BODS) by 17,000 pounds
over a 4-month period. Soon after Maola began
recovering milk and ice cream wastes, the City of New
Bern's treatment plant showed a 14.7 percent reduction
in BOD5 and a 22.8 percent decrease in suspended
solids. The recovery and reuse program also has
translated into reduced chemical usage, less sludge
accumulation, and reduced power requirements for the
New Bern treatment plant. In 1988, Maola estimated it
saved $24,000 per month in wastewater treatment costs
and recovered product. Upon full implementation of the
reuse and recovery program, Maola hopes to recover
as much as 2,410 gallons per day of ice cream
ingredient valued at $480,000 annually (PPIC, 1992).
Kinnear Door/Wayne-Dalton Corporation in Centralia,
Washington, mills, joins, and glues wood parts for
-------
building products. The primary waste stream of the
wood processing plant is wastewater containing glue
wash-down. The company analyzed a number of
different options to properly dispose of the wastewater,
including pretreatment in settling ponds and ultimate
treatment at the local POTW. The company estimated
the cost to dispose of the 2,500 gallons of wastewater
generated each month would have totaled $10,000
annually. Employees at the plant, however, determined
that the glue wash-down water could be reused in glue
formulation. This discovery eliminated the need for
constructing a costly pretreatment system and sending
a potentially toxic effluent to the local POTW (U.S. EPA,
1991a).
Many industries conserve water in areas of the country
where fresh water is in short supply or where local
regulations limit the quantity of effluent discharged to
POTWs. Industries employing recycling to achieve water
conservation might increase effluent concentrations
risking noncompliance with concentration-based effluent
limits. To encourage water conservation, some POTWs
have implemented mass-based limits that allow a
certain mass of toxic discharges over a specified period
of time. With mass-based, as opposed to
concentration-based, limits, businesses can conserve
water while maintaining compliance with discharge
requirements. Section 4.2.1.3 discusses the use of
mass-based limits.
In summary, this chapter describes several pollution
prevention approaches and presents the experiences of
several industrial and commercial facilities that have
successfully applied pollution prevention methods. By
communicating the benefits of pollution prevention to
owners and operators of industrial and commercial
facilities, POTW personnel can motivate facility
personnel to seek pollution prevention technical
information and assistance. The next chapter outlines a
strategy POTW personnel can use to effectively focus
efforts to promote pollution prevention at industries and
commercial businesses to maximize the beneficial
effects on receiving water quality, POTW performance,
and worker health and safety.
-------
Chapters
Targeting Pollution Prevention Efforts
POTW personnel can promote pollution prevention by
integrating new concepts and approaches with existing
activities. By making industries aware of the advantages
of pollution prevention, POTW personnel will start to
shift their thinking from treatment and cross-media
pollution transfer to multimedia pollution prevention.
The benefits of pollution prevention to pretreatment
programs is twofold: (1) to assist in addressing current
and anticipated compliance problems, and (2) generally
to try to encourage opportunities to reduce toxic
loadings to the sewers. The first step a POTW should
take is to develop a policy statement that affirms the
POTWs commitment to promoting pollution prevention
in all its capacities (see Figure 3-1). Then POTWs
should target their pollution prevention efforts on
problem contaminants and identify the industrial,
commercial, or domestic sources of concern. A
relatively small-scale effort focused on one problem
contaminant provides a well-defined goal for an initial
effort. The experience gained from a small-scale effort
can provide the foundation for future expanded pollution
prevention efforts. This chapter outlines the preliminary
steps POTWs should take to set priorities that maximize
the usefulness of pollution prevention efforts (see
Figure 3-2). These steps are to (1) identify pollutants of
concern (see Section 3.1), (2) identify users that are
sources of problem pollutants (see Section 3.2), and (3)
prioritize sewer users that could reduce the discharge
of problem pollutants through pollution prevention (see
Section 3.3).
Pretreatment personnel should consult with other local,
state, and federal agencies (e.g., local board of health,
local planning and fire departments, state agencies
governing pollution and hazardous waste management,
and EPA regional offices) before embarking on a
full-scale effort (see Section 3.4). This will ensure that
they:
Keep pollution prevention goals consistent with other
applicable regulations and programs.
Avoid unnecessary duplication of effort.
Share information.
Coordinate dealings with users.
Fully utilize local, state, and regional technical and
financial resources.
This chapter also reviews the types of resources
available from federal, state, and local agencies that
can assist with POTW efforts to promote pollution
prevention. ,
3.1 Identifying Pollutants of Concern
Pollution prevention provides users with another tool to
comply with local limits developed to prevent or
remediate problems at the POTW related to specific
pollutants in wastewater discharges. Problems related
to specific contaminants can be divided into three broad
categories:
Environmental permit and disposal requirements
- NPDES permit limits
Clean Air Act permit standards
- Sludge disposal requirements.
POTW worker safety concerns.
POTW operational problems (e.g., an industrial
pollutant adversely affects the microorganism
population at the plant).
Most often, POTWs target a specific contaminant for
pollution prevention because of problems in achieving
compliance with their current NPDES permit, or
because they anticipate problems in meeting future
NPDES permit limits. In general, NPDES requirements
will become more restrictive in the future as standards
for sewage sludge use and disposal and ambient
sediment quality are established, and ambient water
quality criteria become more restrictive. Pretreatment
coordinators can consider pollution prevention options
first when drafting a strategy for achieving compliance
with increasingly stringent discharge levels.
For example, investigators in southern Massachusetts
believed that elevated levels of copper in surface water
and sediments posed unreasonable risks to human
health and the environment locally. This finding caused
EPA to issue a copper discharge limit of 9 parts per
billion (ppb) to the Fall River POTW. Fall River, in turn,
9
-------
POTW RESOLUTION FOR DEVELOPING A POLLUTION PREVENTION PROGRAM TO
REDUCE INDUSTRIAL POLLUTANT DISCHARGES TO THE SEWERS
WHEREAS pollution prevention includes reducing the use of toxic substances, reducing the generation of toxic wasfe-at the source,
and recycling toxic waste; and t ' ><"-,
WHEREAS pollution prevention strategies can substantially reduce toxic pollutant loads to the sewers, without transferring those
same pollutants to the air or land; and . -
WHEREAS pollution prevention saves businesses money by increasing productivity while reducing treatment and disposal costs,
sewer fees, long-term liability, and chemical feedstock costs; and,
WHEREAS the industrial and commercial pollutants currently discharged to POTWs can work their way into the environment
through receiving water pass-through, sludge disposal, air evaporation, and collection system leaks, causing potential environmental -
problems; and f ,
WHEREAS future regulatory pressures and economic growth are likely to increase significantly the current industrial pollutant
load to the sewers; and , _
WHEREAS, due to increasingly stringent state and federal laws, POTWs in the future will have to limit significantly the toxic
pollutants in their sludge, receiving water, and air emissions; ~ ~. " ~
NOW THEREFORE BE IT RESOLVED that the '" '- (name of the POTW) establishes a pollution
prevention program to assist area businesses in reducing their toxic pollutant discharges to the sewers; and
BE IT FURTHER RESOLVED that the (lead dept or division) develops and implements Jftis pollution
prevention program; and ' , , -
BE IT FURTHER RESOLVED that, in developing this program, the ' (leasf dept or division):
Identifies specific industrial dischargers and water-borne pollutants for priority attention;
Sets percentage reduction goals for those water-borne toxic pollutants identified as a priority;
Confers with other local agencies that regulate the same industries; aad ,,
Evaluates the feasibility of each of the following program options: educational outreach, technical assistance, and
regulations; and
] (lead dept or division) submits, a proposed work program to
BE IT FURTHER RESOLVED that the
this Board by (date) that identifies we pollution prevention activities selected for implementation, along with a
timetable and required financial support; and, - ",;,.-'
BE IT FURTHER RESOLVED that the.
. (lead dept. or legal division) recommends to 'this Board by
(date) any changes to the existing sewer use ordinance necessary to implement the pollution prevention program, as
proposed.
Source: Adapted from Sherry, 1988b.
Figure 3-1. Sample POTW pollution prevention policy statement
had to tighten its pretreatment standards for copper.
Most of the local textile mills indicated that they could
not afford copper treatment systems and would have to
shut down, thus threatening the local economy. In
response, the Fall River POTW aggressively pursued
pollution prevention opportunities with the affected
textile mills to reduce copper discharges without
necessitating enormous capital outlays. Many
approaches were evaluated:
Lowering the speed of cloth movement through the
dye baths.
Being attentive to additives that keep copper in
solution.
Educating textile buyers to accept products with low-
or no-copper dyes.
Educating dyers on the shop floor as to which dyes
are copper free.
Controlling pH, temperature, salt concentrations, and
fixatives to increase dye efficiency.
Replacing part of a metalized dye with nonmetalized
dyes.
Avoiding use of copper sulfate after treatments.
Avoiding floor spillage.
Copper loadings entering the Fall River POTW have
fallen as a result of these measures; however, additional
10
-------
Figure 3-2. Setting pollution prevention priorities.
actions will be necessary to achieve full compliance with
the limit.
In another example, the Western Lake Superior
Sanitary District (WLSSD) anticipated that it would not
meet its future NPDES permit level for mercury. After
determining that major industrial facilities do not
significantly contribute to mercury loadings, WLSSD
focused its mercury abatement efforts on unpermitted
commercial establishments and residential users.
Investigators determined that discharges from dental
offices and laboratories, as well as mercury-containing
products in solid waste from commercial and residential
sources constituted significant sources of mercury. The
local solid waste incinerator's control system uses water
to "scrub" volatilized mercury from air emissions. This
scrubber water is discharged to the POTW. The WLSSD
formed working groups representing dentists and
laboratories, two groups of sewer users believed to be
collectively significant generators of mercury waste. The
purpose of the working groups is to identify means of
reducing mercury discharges through use of BMPs and
other measures. Also, a local advisory group is
exploring the possibility of implementing a thermostat
collection program for local construction and demolition
companies to reduce this source of mercury in solid
waste that is incinerated. The details of the WLSSD
program are presented in Section 4.3.2.
3.2 Identifying Users of Concern
Once a POTW has targeted a particular contaminant for
pollution prevention, the POTW must determine which
industrial, commercial, and domestic sources discharge
the contaminant. It might not be obvious which
dischargers are the major sources of the contaminant,
especially if the chemical is an integral part of many
different industrial and commercial processes, or if it is
used primarily by unpermitted users about which the
POJW has little information. In ongoing local limit
evaluations, pretreatment personnel perform influent
toxic-loading studies that can identify significant
differences in the influent loadings of toxic pollutants
and the known industrial/commercial/domestic loadings
to the sewer system. Where there is a significant
difference, the POTW will need to resurvey industrial or
commercial groups to identify the previously unknown
additional sources of toxic pollutants.
3.2.1 Industrial Users
The POTW should have a wealth of information on its
categorical and other significant industrial users from
recent inspections, existing and past permits, and the
POTW's pretreatment program industrial waste
surveys. Under the General Pretreatment Regulations,
POTWs also should have been notified about the types
and volumes of hazardous wastes generated and
disposed of by their users (40 CFR 403.12[p]).
Determining which significant industrial users discharge
the contaminant of concern should be a relatively simple
matter since POTWs routinely collect and receive data
on these industrial users. In the Fall River case (see
Section 3.1), the pretreatment personnel immediately
recognized that its permitted textile mills used copper
dyes and hence were likely significant contributors of
copper to the POTW.
To help locate new or unknown dischargers,
pretreatment personnel generally contact local and
state agencies to cross-reference records on water
users, new utility connections, and building permits.
Observation of changes in local businesses while out in
the field also provides information about new users.
11
-------
3.2.2 Commercial Users
Many POTWs .have discovered that commercial
dischargers account for a large percentage of the toxic
pollutants in a POTW's influent. As the pretreatment
program achieves lower levels of toxic pollutants in
industrial discharges, commercial and domestic
sources will account for a larger percentage of the
POTWs total toxic influent load. EPA estimates that 15
percent of all priority pollutants currently entering
POTWs originate in commercial and unpermitted small
industrial facilities. EPA further estimates that
commercial and domestic establishments might
eventually account for as much as two-thirds of the toxic
metals discharged to POTWs nationwide (GAO, 1991).
While the concentration of pollutants in nonindustrial
effluent might be relatively low compared to that in
industrial effluent, the volume of nonindustrial effluent is
approximately six times larger than the volume from
industrial sources at most POTWs (GAO, 1991).
Unfortunately, POTWs often have little information
about their commercial dischargers since they do not
actively inspect them and might not have included them
in the initial waste survey. As a first step, the POTWs
could develop a comprehensive list of commercial
processes that generate the contaminant in question
and what types of commercial establishments employ
those processes. For example, if mercury is a particular
problem, likely commercial contributors could include
dental offices and laboratories. Table 3-1 lists common
commercial establishments and the types of pollutants
they typically produce.
To define further which commercial establishments
produce and discharge the contaminant of concern, the
POTWs could survey commercial establishments in the
POTW service area that are likely to be discharging that
contaminant. Cross-referencing records of businesses
with other agencies will help identify previously
unknown or new commercial users to include in the
survey. The survey will refine the list of potential
commercial contributors, estimate average discharge
concentrations and flows from each facility, and provide
information about the pollution prevention measures the
facilities already employ. A well-defined survey
instrument will yield enough data on which to base
further actions and assess the potential usefulness
of pollution prevention in those commercial
establishments. The survey instrument need not be
particularly lengthy or complicated. Figure 3-3 is the
form used by the Palo Alto, California, POTW in its silver
reduction program.
The Palo Alto POTW's Silver Reduction Pilot Program
is an excellent example of using pollution prevention to
drastically reduce commercial discharges of a specific
contaminant. This POTW discharges to South San
Francisco Bay (South Bay), which, over many decades,
has become severely polluted by heavy metals. The
Palo Alto POTW received permission from the Regional
Water Quality Board to conduct a source reduction pilot
program targeted at silver, a particular problem in South
Bay. At the outset of the program, the Palo Alto POTW
discharge concentrations of silver were more than 3.5
times the proposed South Bay limits, and silver
concentrations in South Bay clams were many times
higher than levels observed in other areas of the Bay.
Initial sampling and mass balance audits conducted by
the Palo Alto POTW revealed that small businesses
contributed up to 70 percent of the POTW's influent
silver loading, regulated industries contributed 25
Table 3-1. Commercial Establishments and Their Potential Discharges of Concern (adapted from U.S. EPA, 1991d)
Type of Facility Discharges of Concern
Automotive repair and service
Car washes
Truck cleaners
Dry cleaners
Laundries
Hospitals
Photoprocessors
Laboratories
Dental offices
Chemical oxygen demand, heavy metals, solvents, paints, surfactants, oil, and grease
Chemical oxygen demand, zinc, lead, and copper
Chemical oxygen demand, total dissolved solids, cyanide, phosphate, phenol, zinc, aluminum,
chromium, lead, and copper
Total dissolved solids, chemical oxygen demand, phosphate, butyl cellosolve, N-butyl benzene
sulfonamide, perchloroethylene, iron, zinc, and copper
Chemical oxygen demand, ethyl toluene, n-propyl alcohol, isopropyl alcohol, toluene, m-xylene,
p-xylene, ethylbenzene, bis(2-ethylhexyl)phthalate, iron, lead,-zinc, copper, chromium, phosphate, and
sulfide
Total dissolved solids, chemical oxygen demand, phosphate, surfactants, formaldehyde, phenol,
fluoride, lead, iron, barium, copper, mercury, silver, and zinc
Chemical oxygen demand, ammonia, cyanide, sulfur, phosphates, silver, arsenic, chromium, phenol,
and bromide
Chemical oxygen demand, mercury, silver, and toxic organics
Copper, zinc, silver, and mercury
12
-------
s^ffi?^
' '
' YES?
^TO^O^#*fe'5NO >'"',
5> DOES
- ~X-, - .
SES^^ :,>
TELEPHONE:''..; . ' "^-..,;"-
--; --, r, - - ,, -, ; -'-*; ,-. -.
"" Source:" City of Palo "Alto, 1992^ ';/:";r'v'^t '"^X% "'"-"-' "£ '/-' . -
Xtl';--!;--^".-°I:^...'-w' '\,T /iri'v"V'? '^ - :-'H
Figure 3-3. Example of a commercial facility survey form.
13
-------
percent, and residential users contributed 5 percent.
POTW personnel already had a solid understanding of
the nature of the industrial silver discharges and
concluded that commercial dischargers deserved their
focus. They surveyed 650 businesses in the service
area suspected of processing photographic materials,
X-rays, and photographic films and negativesthe
principal silver-producing commercial processes. More
than 50 percent of the establishments that returned the
survey indicated that they produced silver-bearing
photographic wastes. The affirmative responses
were received from many small graphic artists,
photoprocessors, printers/publishers, medical facilities,
and dental offices. About 80 percent of these facilities
indicated that they produced less than 5 gallons per day
of silver-bearing photoprocessing .wastes. The survey
data provided the basis for calculating local limits for
commercial photoprocessors and for requiring
photoprocessors to implement a variety of pollution
prevention measures (see case study in Section
4.2.1.2).
3.2.3 Domestic Users
Households regularly discharge many problem wastes
and products, such as used oil, drain cleaners,
detergents, paint and paint thinners, and solvents,
directly to household drains and storm drains. EPA
estimates that households contribute approximately 15
percent of all priority pollutants discharged to the
nation's POTWs (GAO, 1991). As with commercial
establishments, EPA expects that household sources
will account for a larger share of priority pollutant
discharges to POTWs as industrial sources come under
stricter regulation. Studies have shown that households
account for the majority of total discharges for some
pollutants (GAO, 1991). Table 3-2 lists consumer
products and the problem pollutants they contain.
In the early 1980s, Seattle initiated a program to control
domestic sources of toxics in wastewater entering its
POTWs. Studies indicated that up to 64 percent of the
arsenic in Seattle's sewage sludge comes from
households. As much as 40 percent of the arsenic from
domestic sources originates in common household
powdered laundry detergents, dishwashing soap, and
bleach.
Metro, Seattle's POTW authority, created an independent
committee of local environmental and citizen groups and
personnel from local and state wastewater, solid waste,
and health agencies.. The committee developed rating
criteria that focused on the near-term toxicity, long-term
toxfeity, flammability/reactivity, and environmental hazards
associated with commercial products. Based on the
product's evaluation under each of these categories, the
committee assigned the product a color ranging from
green, representing the least risk to the environment, to
black, indicating the greatest risk. A product's overall
rating is based on the least favorable rating it gets in
any given category. As of late 1991, the committee had
rated more than 250 products and disseminated fact
sheets containing these rankings to local retailers and
consumers (GAO, 1991).
3.3 Prioritizing Users of Concern
Generally, pretreatment personnel will want to focus on
the industrial, commercial, or domestic source
contributing the largest share of a given contaminant of
concern to the POTW influent. Once the primary
sources have been established, they can be prioritized
based on secondary considerations:
Selection of model facility. Certain industries or
commercial groups might be willing to undertake
pollution prevention programs as a model for other
dischargers. This could provide excellent publicity for
all parties while achieving the desired reductions in
toxic discharges at a potentially lower cost than
pursuing strictly a treatment solution.
Ease of implementation. Pollution prevention
opportunities might be more obvious and readily
implemented in certain industries. For example,
BMPs, which are easily implemented generally, might
achieve greater source reduction in some industries,
while other industries might need to make more
radical process or product changes to achieve a
similar level of pollution prevention. Targeting the
pollution prevention program at industries that could
achieve large reductions from simple pollution
prevention measures will provide greater assurance
of success, provide valuable experience for
approaching more difficult industries, and impose a
lesser burden on the POTW and the industry.
Current compliance status. Industries currently out of
compliance with pretreatment standards might be
excellent candidates for pollution prevention. In many
cases, pollution prevention can be incorporated into
enforcement agreements. For example, the POTW
could consider a company's willingness to implement
pollution prevention measures when establishing
penalties and developing compliance schedules (see
Section 4.2.2).
3.4 Utilizing Pollution Prevention
Resources
Pretreatment personnel should consult and coordinate
with the appropriate federal, state, and local agencies
prior to embarking on a niajor pollution prevention
initiative. Environmental managers for every medium
have begun to explore the potential benefits of pollution
prevention. A coordinated effort with other federal, state,
and local programs could lessen substantially the
14
-------
Table 3-2. Consumer Products and Their Potentially Toxic or Hazardous Constituents (adapted from URI, 1988)
Product Toxic or Hazardous Constituents
Antifreeze (gasoline or coolant systems)
Automatic transmission fluid
Battery acid (electrolyte)
Degreasers for driveways and garages
Degreasers for engines and metal
Engine and radiator flushes
Hydraulic fluid (brake fluid)
Motor oils and. waste oils
Gasoline and jet fuel
Diesel fuel, kerosene, #2 heating oil
Grease, lubricants
Rustproofers
Carwash detergents
Car waxes and polishes
Asphalt and roofing tar
Paints, varnishes, stains, dyes,
Paint and lacquer thinner -
Paint and varnish removers, deglossers
Paintbrush cleaners
Floor and furniture strippers, polishes, and waxes
Metal polishes
Laundry soil and stain removers
Spot removers and dry-cleaning fluid
Other solvents
Rock salt
Refrigerants
Bug and tar removers
Household cleansers, oven cleaners
Drain cleaners
Toilet cleaners
Cesspool cleaners
Disinfectants
Pesticides (all types)
Photochemicals
Printing ink
Wood preservatives
Swimming pool chlorine
Lye or caustic soda
Jewelry cleaners
Methanol, ethylene glycol
Petroleum distillates, xylene
Sulfuric acid
Petroleum solvents, alcohols, glycol ether
Chlorinated hydrocarbons, toluene, phenols, dichloroperchloroethylene
Petroleum solvents, ketones, butanol, glycol ether
Hydrocarbons, fluorocarbons
Hydrocarbons
Hydrocarbons
Hydrocarbons
Hydrocarbons
Phenols, heavy metals
Alkyl benzene sulfonates
Petroleum distillates, hydrocarbons, heavy metals
Hydrocarbons .
Heavy metals, toluene
Heavy metals
Methylene chloride, toluene, acetone, xylene, ethanol, benzene, methanol
Hydrocarbons, toluene, acetone, methanol, glycol ethers, methyl ethyl ketones
Xylene, heavy metals
Petroleum distillates, isopropanol, petroleum naphtha
Petroleum distillates, tetrachloroethylene
Hydrocarbons, benzene, trichloroethylene, 1,1,1-frichloroethane
Acetone, benzene
Sodium chloride
1,1,2-trichloro-1,2,2-trifluoroethane
Xylene, petroleum distillates
Xylenols, glycol ethers, isopropanol
1,1,1-trichloroethane, inorganic acids
Xylene, sulfonates, chlorinated phenols
Xylene, sulfonates, chlorinated phenols
Cresol, xylenols, phenols
Naphthalene, phosphorus, xylene, chloroform, heavy metals, chlorinated
hydrocarbons ;
Phenols, sodium sulfite, silver halide, potassium bromide, thiocyanate, ferricyanide,
dichromate bleaches, phosphate, ammonium compounds
Heavy metals, phenol-formaldehyde
Pentachlorophenols
Sodium hypochlorite
Sodium hydroxide
Sodium cyanide ,
15
-------
financial burden and avoid unnecessary duplication of
effort among environmental and public health agencies.
In addition, a coordinated effort might be met with less
confusion and animosity on the part of targeted
industries.
With a statutory mandate to incorporate pollution
prevention into all federal environmental programs, EPA
has established the Office of Pollution Prevention and
Toxics (OPPT) and the Pollution Prevention Information
Clearinghouse (PPIC). PPIC functions as a national
depository for technical, policy, programmatic,
legislative, and financial information on pollution
prevention. The PPIC hotline and on-line computerized
data base, the Pollution Prevention Information
Exchange System (PIES), contain a wealth of readily
accessible information on pollution prevention. EPA's
Risk Reduction Engineering Laboratory and the Center
for Environmental Research Information (CERI), both in
Cincinnati, Ohio, also are excellent sources of technical
information. Many EPA offices (including OPPT) issue
special grants to state and local entities interested in
implementing a pollution prevention program. Appendix
A provides more information about these and other
federal pollution prevention resources.
Also, federal, state, and local organizations sponsor
pollution prevention training sessions and workshops.
Workshops focus on pollution prevention in general or
specific opportunities within certain industries. Often
they are open to both industry and regulators and
provide an excellent forum for POTW pretreatment
personnel to receive input from their users in an informal
setting. Personnel can contact the state pollution
prevention or hazardous waste office for information
about pollution prevention training opportunities in the
local area. Pollution prevention conference and training
information also can be obtained on line from the PIES.
Many states have an active pollution prevention
program that can provide technical assistance to
POTWs and industrial and commercial users that wish
to leam more about pollution prevention in general or
need specific technical pollution prevention advice (see
Table 3-3). State programs most often include one or
more of the following elements:
Pollution prevention or toxics use reduction goals.
States establish goals to reduce toxic discharges in
the state by some specified percentage. These goals
serve as targets against which to measure progress.
Industry reporting. Chemical manufacturers and
users file annual reports detailing chemical use and
existing inventories.
Industry planning. Hazardous waste generators
assess their facilities for pollution prevention
opportunities and file a detailed pollution prevention
plan with the state. In many states these plans are
available to state officials and the general public.
Technical assistance. Programs provide hands-on
technical assistance to firms and state facilities
seeking to implement pollution prevention measures
and technologies.
Research and development. Some states fund
university-based pollution prevention institutes to
engage in research, establish pilot and demonstration
projects, conduct training, and act as pollution
prevention clearinghouses.
Grants. Programs provide pollution prevention grants
to localities, state facilities, and firms interested in
demonstrating innovative pollution prevention
technologies and regulatory programs.
Training. Many state agencies hold workshops and
provide training materials on industry-specific
pollution prevention technologies.
Various states have been extremely active in assisting
POTWs with pollution prevention programs. In
California, North Carolina, Minnesota, Connecticut, and
Massachusetts, for example, state technical assistance
and general programmatic support have been
instrumental in helping industrial dischargers achieve
significant pollution prevention goals. POTWs in
Massachusetts often refer their industrial and
commercial dischargers to the Office of Technical
Assistance (OTA), created with the passage of
Massachusetts' Toxics Use Reduction Act (TURA). OTA
serves as a technical pollution prevention clearinghouse
and often takes part in actual POTW inspections at the
request of both the POTW and industry. OTA also has
been active in sponsoring pollution prevention
workshops and providing pollution prevention training
for state and local environmental compliance
inspectors.
Minnesota's Technical Assistance Program (MnTAP)
offers pollution prevention assistance to Minnesota's
smaller industries. One of the more innovative aspects
of MnTAP is its internship program, which pays a salary
to an appropriately qualified engineering student to work
with a company in implementing a pollution prevention
program or in identifying and assessing a specific
pollution prevention technology. As part of its mission,
MnTAP also provides technical assistance and training
and participates in multimedia inspections.
Many states now require industrial facilities to submit
detailed pollution prevention reporting and planning
data. For example, Tennessee requires facilities that
generate more than 220 pounds of hazardous waste per,
year to submit pollution prevention plans by 1994. The
plans must include:
16
-------
A policy statement of management's commitment to
pollution prevention.
the plan, including numeric
Specific goals of
performance goals.
Technically and economically practical pollution
prevention options and a schedule for their
implementation.
An accounting of hazardous waste management
costs.
A description of pollution prevention training
programs for employees.
A rationale for stated performance goals.
POTW officials could use this type of information to
prepare for site visits and learn more about
industry-specific waste streams and pollution
prevention opportunities. Some facility data are
considered proprietary, and, depending on state laws,
POTW personnel might have access to this information.
Table 3-3 shows the states that have either enacted or
proposed pollution prevention laws that require
hazardous waste generator reporting and pollution
prevention planning.
Cooperative ventures between POTWs and state and
local solid waste, air, and water agencies are becoming
more and more common. The state and federal focus
on multimedia'transfers has led to a greater integration
of specific envirbrimental media programs. Some states
now operate multimedia inspection programs in which
a team of inspectors from the principal environmental
program offices examines an industrial facility for
compliance but also with a heightened awareness of
multimedia transfers and pollution prevention. Section
4.1.4 discusses multimedia inspections. Teaming up
with local public health officials, drinking water
treatment personnel, or solid waste management
personnel to promote pollution prevention in the
community also might be advisable in some cases.
Please refer to Appendix A for a list of federal, state, and
local pollution prevention resources.
In summary, to protect against the pass-through of toxic
pollutants to receiving waters and to maintain proper
treatment plant performance, POTW personnel identify
and prioritize pollutants and sewer users for control.
Pollution prevention methods have been shown to be
the most cost-effective and environmentally sound
means of controlling waste management problems. This
chapter presents an approach for focusing POTW
pollution prevention efforts. The following chapter
explains ways pretreatment personnel can encourage
indirect dischargers to adopt pollution prevention
measures. POTW personnel can accomplish this by
integrating pollution prevention concepts into ongoing
program activities. .
17
-------
Table 3-3. States with Existing or Proposed Pollution Prevention Technical Assistance and Facility Planning and Reporting
Requirements (WRITAR, 1992; PPIC, 1992)
State
Existing Technical
Assistance Programs
Existing Facility
Planning and
Reporting
Requirements
Proposed Technical
. Assistance Programs*
Proposed Facility
Planning and
Reporting
Requirements*
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
Ohio
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Vermont
Virginia
Washington
WestVjrginla
Wisconsin
Wyoming
Note: A list of telephone numbers and addresses of state pollution prevention contacts is supplied in Appendix A.
* Proposed as of March 1992.
18
-------
Chapter 4
Promoting Pollution Prevention Among Regulated and Unregulated Sewer Users
Once a POTW has identified problem contaminants and
prioritized industrial, commercial, and domestic users
accordingly, it can focus on how pollution prevention
can be incorporated into inspection, permitting, and
enforcement activities as a full or partial solution to
identified problems. This chapter explores several
options for incorporating pollution prevention into
existing inspection (Section 4.1) and regulatory
activities (Section 4.2). In addition, Section 4.3 suggests
some ways a POTW can publicize pollution prevention
through public outreach, workshops, forums, user
awards programs, and domestic hazardous waste
collection programs. Some of these activities are more
resource intensive than others, and those that are most
appropriate for a given POTW will depend on the types
of sources and contaminants the POTW wishes to
target and the POTW's available staff and financial
resources. In many cases, it might be best to begin with
a simple activity and use the experience gained to
launch more complex pollution prevention efforts in the
future.
4.1 Inspections
One of the most effective ways to identify and promote
.pollution prevention is to explore opportunities during
routine facility inspections. Because a POTW's staff
usually has a close relationship with local industry and
commercial establishments, they are in a unique
position to educate businesses on the advantages of
pollution prevention. POTW personnel that routinely
visit industries can heighten a business' awareness of
pollution prevention and promote it as a viable
alternative to more traditional treatment technologies or
more costly disposal.
Incorporating pollution prevention into existing POTW
inspections is not a substitute for performing a pollution
prevention audit. States may sponsor multimedia audit
programs or industries and commercial businesses can
conduct their own audits to explore pollution prevention
options that affect all facility waste streams. Either way,
a pollution prevention audit involves a comprehensive
evaluation of a facility's processes and operations. This
section presents guidance on how to identify areas in
industrial and commercial processes, during routine
POTW inspections, where facility owners and operators
could further evaluate the potential for applying pollution
prevention measures.
Pollution prevention can be incorporated into POTW
facility inspections. By asking investigative questions,
disseminating basic pollution prevention information,
and offering sources of further technical assistance,
POTW personnel can point out pollution prevention
opportunities that are mutually beneficial to both parties.
This section describes an approach that incorporates
pollution prevention into preinspection activities
(Section 4.1.1), the inspection itself (Section 4.1.2), and
postinspection followup (Section 4.1.3). Figure 4-1
depicts how pollution prevention concepts can be
integrated into the three stages of performing facility
inspections. Section 4.1.4 discusses the usefulness
of multimedia inspections in identifying and promoting
pollution prevention.
4.1.1 Preinspection Activities
Preinspection activities can be divided into three
categories: (1) initial data gathering efforts, (2)
identifying specific areas in the process that would
benefit most from pollution prevention measures, and
(3) assembling information on pollution prevention
techniques that seem to be applicable to the facility to
be inspected based on the preinspection analysis.
4.1.1.1 Gathering Facility-Specific Data
With a solid understanding of many industrial processes,
the types of inputs they require, and the waste streams
they generate, POTW personnel can help identify
potential problem areas and initiate discussions with
facility personnel about implementing pollution
prevention measures. Much of the required information
and data are readily available at the POTW. For
example, POTW personnel collect process information
and waste stream monitoring data on significant
industrial users to develop permits arid prepare for
traditional user inspections. In addition, the revised
General Pretreatment Regulations require dischargers
to report to wastewater authorities the types and
quantities of certified hazardous chemicals they
19
-------
OQQQ
Data gathering on
facility activities
Preinspection
Creating & evaluating
a process-flow diagram
Collecting information on
applicable pollution
prevention measures from
EPA & state technical
assistance programs
What leads to
the generation
of this waste?
What prevents
you from using an
alternative input
material?
1
During inspection, consider
pollution prevention solutions
Ask open-ended questions about
potential applicability of pollution
prevention techniques
Onsite Inspection
For further
information
call...
1
Supply available
information
on applicable pollution
prevention techniques
Postinspection
Refer to sources of
additional information on
pollution prevention
3
Postinspection
followup
Figure 4-1. Using onslte inspection to promote the benefits of pollution prevention.
20
-------
generate and discharge to the sewer (40 CFR
403.12[p]). With a full picture of the process and the
materials used, POTW personnel can better understand
how and why a given waste stream is generated and
what types of pollution prevention measures would
effectively reduce pollutant loads to the sewers. The
more POTW personnel know, the more focused the
inspection will be.
POTWs interested in inspecting unpermitted industries
and commercial facilities might have greater difficulty
obtaining current, facility-specific process data. Options
in such cases include:
Reviewing industrial waste survey data.
Contacting other federal, state, and local environmental
and public health program offices that might have
collected facility-specific information.
Requesting process data and information directly from
the facility (under the pretreatment program, POTWs
have the authority to collect facility-specific information
from any discharger).
In addition, POTW personnel can gather information
about the process in question from general sources,
such as EPA guidance documents and other technical
manuals. POTW personnel also can contact the PPIC,
state technical assistance offices, and trade groups to
find out more about specific industrial and commercial
processes and applicable pollution prevention
techniques (see Appendix A for a listing of information
sources).
For permitted facilities, POTW personnel should review
information relating to the facility's compliance history.
Compliance data can help POTW personnel focus
preinspection information-gathering efforts on pollution
prevention options that address the facility's greatest
compliance problems. For example, if POTW personnel
know that the facility is having or has had problems
meeting pretreatment standards for copper, they can
make a special effort to investigate pollution prevention
measures that have succeeded in reducing copper
discharges in similar facilities. POTW personnel also
should be aware of any impending pretreatment
standards or POTW restrictions that will either require
more stringent discharge limits for a particular
contaminant or address a previously unregulated
contaminant that the facility in question currently
discharges. With this knowledge, POTW personnel can
advise facilities to start thinking about pollution
prevention as a means of meeting future discharge
limits.
Knowledge of the facility's present or past pollution
prevention activities can help POTW personnel target
other areas of the facility that could potentially use
improvements. POTW personnel also will have a better
understanding of how much facility operators already
know about pollution prevention and the types of
information the facility might find useful. Acknowledging
the facility's current pollution prevention
accomplishments can help set the tone for a positive
discussion of additional measures the facility could take.
Facilities might have already submitted to state
agencies waste minimization plans that POTW
personnel can review to obtain relevant information for
their inspection. Table 3-3 lists states that currently
require such plans. State laws vary as to the level of
confidentiality accorded waste minimization plans.
4.1.1.2 Identifying Areas That Would Benefit
from Pollution Prevention Measures
Drawing on the information gathered from the sources
discussed, the following four-step approach will assist
in identifying areas of the facility's process where
pollution prevention measures could reduce toxic
loadings to the sewers:
1. Construct a simple process-flow diagram of the op-
eration. Show all inputs and outputs to the process,
including raw materials inputs, product outputs, ma-
terial recovery, and waste streams.
2. Perform a materials balance assessment to identify
significant material losses occurring in the process.
3. Evaluate the sources of identified losses.
4. Identify areas other than process areas, such as
storage areas or garages, where losses typically
occur.
As the first step, POTW personnel can develop a flow
diagram that depicts the sequence and function of all
the unit processes and the materials going into and
coming out of each unit. This diagram will help POTW
personnel define the operation and form the basis for
tracking the materials as they go through the process
and ultimately end up in the product, recovered
materials, or the waste stream. POTW personnel can
verify the accuracy of the process-flow diagrams during
the inspection. Figure 4-2 is an example of a
process-flow diagram for a photoprocessing operation.
(This photoprocessing example will be used to illustrate
the application of the four steps outlined above).
The next step is to account for the majority of the
material flows into and out of the process. Based on the
process flow diagram, POTW personnel can track the
pollutant of concern from its point of origin in the raw
material inputs to the resulting products and waste
streams. It is helpful to make a list of all input and output
materials. For the photoprocessing example, Table 4-1
itemizes the material inputs and outputs and identifies
areas where losses are occurring and wastes are
generated. Using raw materials purchasing records,
21
-------
cold hot
water water
developer
replenisher
fixer
replenisher
film
or -
paper
Developing
^
Fixing '
Rinsing
^ developed
~ tllm or paper
developer
to sewer
fixer
rinsewater
to sewer
electricity
1
resin
Electrolytic
Cell
1
^
Holding
Tank
^-
Ion
Exchange
Column
recovered
sliver
recovered de-silvered
silver waste fixer
to sewer
Figure 4-2. Sample flow diagram of photoprocessing operation.
Table 4-1. Sample Materials Accounting List for a
Photoprocessing Example
Material Inputs
Material Outputs
Losses/Wastes
Photographic Rim
Photographic
Paper
Developer
Replenisher
Fixer Replenisher
Stabilizer
Iron
Cold Water
Hot Water
Developed Rim
and Paper
Recovered Silver
Waste Developer
De-silvered Waste
Fixer
Waste Rinsewater
waste stream monitoring and flow data, and product
data, POTW personnel can quantify the mass of
materials going through the process. For the
photoprocessing example, the tracking of silver mass is
illustrated in Figure 4-3. This is similar to, but not as
rigorous as, an engineering mass balance exercise. The
mass of input materials should approximate the
combined mass of materials output in the product,
recovered materials, and the waste streams. Although
the mass balance will be unequal due to the variability
in waste stream sampling and flow data and errors in
estimating input and output masses, it should be within
an acceptable margin of error. The acceptable margin
of error varies with the known precision and accuracy
of information used to estimate the material mass at
each stage. A substantial difference between materials
input and output from the process indicates losses of
materials that should be investigated. Figure 4-4
illustrates a material balance calculation tracking the
mass of silver going into and out of the photoprocessing
example. In this example, the material balance was not
exact, but was judged to be within an acceptable margin
of error.
22
-------
Silver from
Color Film
and Paper
700 rolls/day
^
Silver in
Spent
Developer
rcsr
SAMPLE
2 ppm
260 gal/day
1
To Sewer
Silver in
Spent Fixer
after
Electrolytic
Cell
Measured
Silver
Recovered
from
Electrolytic
Cell
/
\
^
To Recla
Silver Me
. Silver in
Spent Fixer
after Ion
Exchange
TEST
SAMPLE
20 ppm
6.0 gal/day
.Measured
Silver
Recovered
from Ion
Exchange
To Sewer
^
^
To Reclaimed
med
irket
Figure 4-3. Tracking the silver material balance in a color photoprocessing operation.
Losses can occur during the process for several
reasons. They can be related to inefficiencies in the
production process itself, maintenance procedures,
inventory controls, or internal management of waste
residuals. POTW personnel can speculate about the
sources of losses before the inspection; however, at the
inspection, through observing operations and
questioning facility personnel, POTW personnel will be
better able to draw more informed conclusions
regarding the source of and possible pollution
prevention solutions to the materials losses.
In addition to the process areas, POTW personnel
should investigate the existence of storage areas,
pumping stations, laboratories, boiler areas, garages,
pollution control equipment, and power generating
facilities. These are areas that should be observed
during the inspection to determine whether good
operating practices are being applied to prevent or
minimize the discharge of pollutants to the POTW,
especially through floor drains, and whether further
improvements in existing practices or other pollution
prevention options might be appropriate. In addition,
based on knowledge of the industry, POTW personnel
can identify any periodic maintenance activities, such
as equipment or tank cleaning, boiler blow down, and
motor fluid changes, that can periodically generate
significant waste streams potentially discharged to the
sewer. Improving operating practices for these activities
should be encouraged and applying specific pollution
prevention measures may also be appropriate.
4.1.1.3 Assembling Information on Applicable
Pollution Prevention Techniques
Once a preliminary assessment of materials losses is
conducted, POTW personnel should compile a "laundry
list" of possible pollution prevention alternatives that
would reduce or eliminate losses. Investigators should
focus on collecting as much information as possible
about the pollution prevention opportunities available for
the industry under investigation. The information can be
used for the purpose of educating facility owners and
operators about the usefulness of pollution prevention
measures, supplying available documents and other
materials on pollution prevention, and encouraging
facility owners to conduct their own pollution prevention
assessment of all potentially feasible options. The final
decision about the applicability of any pollution
prevention measure will be made by the facility based
on economic, technical, and feasibility factors.
Many federal, state, local, and private sources provide
excellent summaries of known pollution prevention
techniques implemented by specific industrial and
commercial groups. These sources are listed in
Appendix A. To start, POTW personnel should refer to
the industry-specific pollution prevention summaries
compiled in Appendix B.
POTW personnel also should assemble relevant case
study information. Facility owners might be more likely
to investigate seriously a pollution prevention technique
if they know that a similar facility has realized a savings
using the same method. PIES is an on-line source for
case study material catalogued by type of pollution
23
-------
INPUT
0.2625 Ib/day'
Notes:
1. 700 rolls film/day x 0.3 sq ft/roll x 0.00125 Ib silver/sq ft.
2. 2 ppm x 260 gal/day x 8.34 Ib/mgal x 0.000001.
3. 20 ppm x 6.0 gal/day x 8.34 Ib/mgal x 0.000001.
4. Measured silver recovered from process.
Figure 4-4. Comparing silver input and output in a photoprocessing operation.
Wastewater
Rinsewater2
0.00434 Ib/day
Spent Developer
0.00434 Ib/day2
Spent fixer3
0.001 Ib/day
Total 0.00968
Ib/day
Recovered
Silver
Electrolytic Cell
0.1875 Ib/day4
Ion Exchange
0.01875 Ib/day4
Total 0.20625
Ib/day
TOTAL OUTPUT
0.2359 Ib/day
prevention technique, industrial process, and industry
group (see Appendix A for information on how to access
PIES). State and federal pollution prevention technical
assistance offices also can help POTW personnel with
specific pollution prevention questions or information
requests. Many of these technical offices sponsor
pollution prevention workshops for industry and state
personnel interested in learning about pollution
prevention opportunities in a given industry.
Table 4-2 lists some potential pollution prevention
measures identified for the photoprocessing example
illustrated in this chapter. The options are organized
according to the major waste streams from the
developing and fixing steps and the rinsing unit. There
are also some general facility options listed.
4.1.2 Inspection Procedures
The inspection provides an opportunity for pretreatment
personnel to view facility operations and encourage
pollution prevention to the fullest extent. One of the
goals of the inspection is to leave an industrial user with
a good idea of which areas of the facility can potentially
employ pollution prevention measures to help achieve
compliance with discharge limits and reduce toxic
loadings to the sewer. These goals can be
accomplished by (1) setting the appropriate tone, (2)
making observations and asking the right questions, (3)
giving appropriate advice, and (4) highlighting pollution
prevention in the exit meeting.
4.1.2.1 Setting the Appropriate Tone
Most routine facility inspections begin with a meeting.
At this time, POTW personnel can inform facility
personnel that the POTW is promoting pollution
prevention as a means of reducing toxic discharges to
the sewers and achieving long-term compliance with
pretreatment standards. Topics to cover in the opening
meeting include:
What pollution prevention is and why it is important
to the POTW. POTW personnel could emphasize
how the facility might benefit from increased source
reduction and recycling.
Current and potential future user compliance
problems based on existing and anticipated POTW
compliance needs and how pollution prevention could
help address these problems.
The types of pollution prevention measures the
facility has already adopted and what sort of
24
-------
Table 4-2. Sample Pollution Prevention List for Photoprocessing Example
Process/Process Step Opportunity Option
Developing and fixing steps
Reduce chemical use (to reduce
chemical loading to POTW)
Rinsing
General facility
Reduce water use (to reduce water
use, water heating, and silver
discharge to POTW)
Good operating practices
1. Adjust replenishment rates.
2. Install silver recovery fixer recirculator.
3. Use squeegees to minimize chemical carryover from
developer and fixer.
4. Evaluate recycling fixer.
5. Monitor silver recovery units to ensure maximum
operating efficiency.
6. Use low silver-containing rapid access (RA) chemicals.
7. Route fixer overflow drains to silver recovery.
8. Segregate high and low silver-bearing streams to
enhance silver recovery.
9. Check storage areas daily for spills. Chemical storage
area could be diked and absorbent pillows could be
made available to contain spills.
1. Install water recirculator.
2. Evaluate recycling rinsewater, including recovering silver.
3. Check storage areas daily for spills. Chemical storage
area could be diked and absorbent pillows could be
made available to contain spills.
1. First-in/first-out inventory control.
2. Inventory inspection for leaks and spills.
3. Use lids or other means to minimize chemical contact
with air.
successes and problems the facility has had with
those measures.
The objective of identifying some additional pollution
prevention measures that the facility could consider
and encouraging the facility to adopt pollution-
prevention measures wherever feasible.
4.1.2.2 Identifying Pollution Prevention
Opportunities Through Observation and
Asking the Right Questions
During the inspection, POTW personnel should look for
pollution prevention opportunities by examining current
administrative, operating, maintenance, and storage
practices. POTW personnel can observe the flow of the
facility's process, following the train of events that leads
to the disposal of contaminants to the sewer and
verifying the accuracy of the process flow diagram
constructed prior to the inspection. If user or POTW
compliance issues were identified prior to the
inspection, reducing the sources of problem
contaminants very likely will be the primary focus of the
inspection. If the materials balance calculations
indicated substantial losses of certain materials,
identifying the sources of these losses and reducing
them very likely will be another major focus of the
inspection.
Beyond the process itself, controlling spills and leaks,
modifying poorly designed storage facilities, improving
the efficiency of outdated and poorly maintained
machinery, and other pollution prevention opportunities
falling under the general category of good operating
practices can be observed. These types of opportunities
will generally be easier to identify than process-related
opportunities because they are somewhat generic to all
businesses.
The key to getting facility owners and operators thinking
about pollution prevention and how it might work in their
facility is to ask open-ended questions about why they
use a certain process or input, or why some current
practice could or could not be changed. POTW
personnel should formulate open-ended questions that
solicit thoughtful answers and stimulate further
discussion. Ultimately, such discussions might lead to
the discovery of a feasible pollution prevention
opportunity. Open-ended questions prompt users to
think about why they have chosen a given process or
input and what prevents them from changing to another
process or input. Close-ended, or "yes/no," questions
tend to be more accusatory and solicit one-word
answers that can effectively end the discussion and
might close a potentially promising pollution prevention
angle entirely (Greiner and Richard, 1992).
Examples of both types of questions follows:
Open-ended Questions
* What is the company's policy with regard to pollution
prevention?
How are employees trained to perform their jobs?
What makes this input so valuable? What limits you
from using an alternative?
What leads to the generation of this discharge?
How could the facility try to recover and purify some
of its solvents?
25
-------
What would happen if you converted to counter-
current rinsing?
Close-ended Questions
Is management committed to pursuing pollution
prevention? Does the company have a written
pollution prevention policy statement?
Can you use a different manufacturing process?
Have you experimented with other inputs?
Do you have to use this degreaser?
POTW personnel can use the results of their process-
flow analysis as a basis for their questions. In addition,
published pollution prevention information (see
Appendix A) and the industry-specific pollution
prevention summaries in Appendix B can help formulate
pollution prevention questions that touch on the facility's
major operations. Published pollution prevention
checklists can be helpful guides; however, POTW
personnel should not be overly reliant on checklists
since no single checklist can account for the variations
In standard processes and operating practices that
Investigators will encounter in the field. Checklists are
generally designed to provide a convenient pollution
prevention outline.
4.1.2.3 Giving Advice and Making
Recommendations
POTW personnel must be careful about giving pollution
prevention advice. In general, investigators should
refrain from specifying products or suggesting that if the
firm implements a certain pollution prevention measure,
it will achieve compliance with pretreatment standards.
POTW personnel should give limited, basic advice in an
informal manner and provide examples of other
companies that have experimented with a given
pollution prevention measure. Here are some examples
of how and how not to give pollution prevention advice:
Recommended Approach
"Drag-out in plating operations is a serious problem
for many circuit board manufacturers. Many
manufacturers have experimented with lowering the
viscosity of their plating baths, which reduces the
volume of excess plating material that clings to the
circuit board. Others have changed the orientation of
the plated part and increased the time they allow for
plated parts to drain before rinsing. Another circuit
board manufacturing facility I have visited claims that
these and other measures have reduced drag-out
and increased the life of their plating baths
considerably. Here's the number of the state technical
assistance office; I'm sure they can tell you more
about these and other drag-out reduction
techniques."
"I was over at another facility the other day and
noticed that they use countercurrent rinsing arid have
installed a rinsewater recycling unit. This has cut their
water consumption by over 30 percent, lowered their
water and sewer bills, and helped reduce the amount
of silver discharged to our POTW. Perhaps you could
call the people at the state technical assistance office
for more information. It could save you some money
and help us meet our NPDES permit limit for silver."
Approach Not Recommended
"Your silver discharges are quite high and might
exceed new pretreatment standards. The ACME
Silver Recovery Unit is a great buy. Many local
photoprocessors currently use one and make a great
return on the recovered silver. You should probably
get one."
"I attended this pollution prevention workshop for
commercial printers a couple of months ago. ACME,
Inc., was advertising this new soy-based ink that
apparently is just as effective as traditional
petroleum-based inks and is entirely biodegradable
and nontoxic. Because of your current compliance
problems, I would advise you to switch to these new
inks."
This does not mean that POTW personnel should refer
all questions to a technical assistance office and refrain
from discussing a pollution prevention technology
altogether. POTW personnel should simply avoid
leaving the impression that they are endorsing a given
product, service, or technique and that adopting specific
pollution prevention measures will somehow ensure
compliance. Ultimately, the facility will need to conduct
a detailed cost-benefit analysis to determine whether a
given pollution prevention measure is a viable option for
reducing the generation of problem pollutants.
POTW personnel should be careful about revealing the
identity of firms that have implemented pollution
prevention measures that seem applicable to other
similar facilities. Some of this information might be
considered confidential; therefore, POTW personnel
should check with facility managers before giving out
company names for illustration purposes.
4.1.2.4 Exit Meeting
As part of the usual exit meeting, POTW personnel can
summarize preliminary findings with respect to
compliance and pollution prevention and receive the
facility's initial response to those findings and any
comments they might have about the inspection
process. At this meeting, POTW personnel might wish
to disseminate any applicable published pollution
prevention information (e.g., EPA or state
industry-specific pollution prevention handbooks, fact
sheets, summaries from Appendix B) and inform owners
26
-------
and operators of state technical assistance offices and
other pollution prevention resources such as PPIC and
the PIES on-line service. It should be clear that POTW
personnel are not making recommendations about
specific measures to implement but rather summarizing
applicable information based on what was observed
during the inspection.
4.7.3 Postinspection Followup
As part of the normal inspection report, the investigator
should include observations about pollution prevention
measures for the facility to consider and put forward
more detailed information about measures that seem
particularly promising and suggest some additional
contacts and references for more information. POTW
personnel also might wish to contact the facility after an
appropriate amount of time to see if the facility has given
any further consideration to the identified pollution
prevention opportunities and to discover what problems
or successes, if any, the company has had. This
information could be very useful in future inspections.
4.1.4 Multimedia Inspections
As emphasized earlier, pollution prevention using
source reduction and recycling is an environmental
management method that can help avoid cross-media
transfers of environmental contaminants. Multimedia
inspections can greatly improve the ability of
environmental regulators to recognize cross-media
transfers at particular industrial and commercial
facilities and identify pollution prevention measures to
mitigate such transfers. For example, an onsite
wastewater pretreatment system could transfer volatile
organics from an open mixing tank to the air.
Conversely, air pollution technologies using wet
scrubbers to cleanse air emissions of toxic compounds
could transfer contaminants to the facility's wastewater.
Coordination among local hazardous and solid waste,
air, water, and POTW officials through multimedia
inspections can often uncover complicated cross-media
transfers.
Multimedia inspection programs are generally initiated
at the state level, since they require planning and
coordination among state and local agencies. In most
cases, POTWs will not have the resources to initiate
such an inspection program. POTWs can help start a
multimedia inspection program, however, by contacting
the appropriate regional, state, and local offices to
garner support for the concept and suggest the
formation of a planning group. POTW personnel should
have a strong say in how the inspection program will
operate, since they inspect more facilities than most
other state and local agencies.
A number of states have initiated multimedia inspection
pilot programs. Members of Massachusetts' highly
successful multimedia inspection program, the
"Blackstone Project," have inspected. hundreds of
industrial facilities. Industries generally approve of the
program, since it reduces the number of inspections
they must accommodate each year and often offers
sound technical pollution prevention advice that saves
them money. Massachusetts' POTWs play an integral
role in the ongoing program.
The Western Lake Superior Sanitary District (WLSSD),
mentioned in Chapter 3, participates in the Lake
Superior Partnership Compliance Assistance Program
(CAP) in conjunction with the Minnesota Pollution
Control Agency (MPCA), EPA, and industry. To begin
with, CAP visited 15 companies discharging to the
WLSSD POTW for voluntary multimedia compliance
inspections that promoted pollution prevention and the
mitigation of cross-media transfers. While the
inspections evaluated companies for compliance with
existing permits, CAP hoped to form a strong
partnership with permitted facilities to strengthen
industry's ability to maintain long-term compliance with
state and federal environmental regulations through
pollution prevention.
Each inspection begins with a preinspection
conference, during which CAP inspectors (including air,
water, and hazardous waste officials, and the WLSSD
POTW staff) brief facility personnel about the inspection
process, the pollution prevention focus, and technical
assistance and address any concerns industry staff
might have about the inspection. WLSSD also requests
that the facility submit a list of pollution prevention
activities that the company has either explored or fully
implemented prior to the inspection. This helps the
inspectors identify and research pollution prevention
opportunities that the company has not yet considered
and about which the facility might have limited
information.
The CAP inspections generally last a full day and are
conducted in a manner similar to single-media
inspections. Because inspectors represent all
environmental media, however, the inspections are
more likely to recognize cross-media transfers of
environmental contaminants and the need for pollution
prevention measures rather than more traditional
environmental control technologies. Conflicting answers
among various media regulators are resolved
immediately, thereby enhancing mutual trust between
industry and environmental regulators. The inspections
conclude with an exit interview where inspectors
comment on the facility's current conditions and areas
that need improvement. Inspectors also indicate where
pollution prevention opportunities might exist and
suggest sources of further information. The inspection
team submits formal written comments and
27
-------
recommendations to the company about which pollution
prevention opportunities seem worthy of further study.
Overall, CAP has achieved an unprecedented level of
cooperation among industry, state environmental
regulators, and local POTW personnel and has greatly
enhanced the prospects for meaningful pollution
prevention in the WLSSD area.
4.2 Encouraging Pollution Prevention
Through Regulatory Activities
POTW personnel can encourage pollution prevention
through existing regulatory activities. These activities
include developing and issuing user permits (see
Section 4.2.1) and responding to user noncompliance
(see Section 4.2.2).
4.2.1 Issuing User Permits
POTWs have authority to require users to meet discharge
limits and other requirements to prevent pass-through of
toxic contaminants and disruptions of normal wastewater
treatment operations. In general, setting local limits
covering a wide range of contaminants and industrial and
commercial sources provides a strong incentive for
implementing pollution prevention measures. The cost of
treatment generally rises with the stringency of local limits;
as this occurs, pollution prevention becomes a more
desirable means to assist industrial and commercial users
in meeting local limits.
POTWs with the appropriate authority, usually
established in sewer use ordinances, can use the
permitting process as an effective mechanism for
instituting pollution prevention as a local requirement for
industrial and commercial users. This section discusses
three permitting strategies that either directly require
facilities to adopt certain pollution prevention practices
or create incentive structures that indirectly promote
pollution prevention. These approaches are:
Requiring pollution prevention plans and
implementation of BMPs (Section 4.2.1.1).
Controlling discharges from small industrial and
commercial users (Section 4.2.1.2).
Employing mass-based local limits (Section 4.2.1.3).
4.2.1.1 Requiring Pollution Prevention Plans and
Implementation of Applicable BMPs
POTW pretreatment personnel can heighten interest in
and awareness of pollution prevention as a means of
meeting pretreatment standards by requiring industrial
and commercial users to develop and submit pollution
prevention plans as part of the permitting process. As
stated earlier, POTWs may need to amend or enact
sewer use ordinances to provide them with the authority
to require submission of pollution prevention plans.
Pollution prevention plans contain detailed and
systematic assessments of a facility's ability to reduce
the volume and toxicity of discharges through pollution
prevention activities. A pollution prevention assessment
or audit conducted by facility owners and operators can
be the single most effective means for identifying
technically and economically feasible pollution
prevention opportunities capable of achieving long-term
reductions in the generation of toxic waste streams.
Many industrial users are already subject to pollution
prevention planning requirements. For example, under
the current federal pretreatment regulations, some
industrial users are required to develop and implement
TOMPs and spill prevention plans, which address some
types of pollution prevention measures. As part of toxics
use reduction legislation, a number of states require
certain generators of hazardous wastes to submit
pollution prevention or waste minimization plans (see
Table 3-3). Also, some Resource Conservation and
Recovery Act (RCRA) provisions require certain
hazardous waste generators to conduct pollution
prevention or waste minimization planning.
Pretreatment personnel should contact appropriate
state and local agencies to determine whether any of
the POTWs users have filed pollution prevention plans
to meet existing federal or state requirements.
If users have not already developed pollution prevention
plans that address the waste streams destined for the
sewers, a local pretreatment program should consider
exploring the possibility of incorporating a pollution
prevention planning provision into the permitting
process. Such a provision could require that a facility
interested in renewing an existing permit or obtaining a
new permit must submit a detailed pollution prevention
plan. Pollution prevention plans should consist of the
following elements:
A process-flow diagram showing where toxic
constituents enter and exit the manufacturing
process.
An estimate of the amount of regulated waste
generated by each process.
An assessment of current and past pollution
prevention activities, including an estimate of the
reduction in amount and toxicity of regulated waste
achieved by the identified actions.
A review of pollution prevention opportunities
applicable to the facility's operations.
Identification of technically and economically feasible
pollution prevention opportunities, including an
assessment of the cost, benefits, and cross-media
impacts of the identified opportunities.
An implementation timetable.
28
-------
POTW personnel can assist their industrial and
commercial dischargers in developing pollution
prevention plans by pointing out pollution prevention
opportunities during inspections, coordinating meetings
between state technical assistance personnel and
facility owners and operators, and providing published
materials such as EPA's Waste Minimization
Opportunity Assessment Manual, Software and User
Manual for the Strategic Waste Minimization Initiative
(SWAMI computer program), and Facility Pollution
Prevention Guide (see Appendix A for full references).
New or expanding facilities or those with existing
compliance problems are the most likely to benefit from
pollution prevention planning. Facilities conducting
pollution prevention audits prior to the construction or
modification of a facility might find it more feasible to
incorporate innovative process and building designs
that reduce toxic waste discharges than a more
established facility that has already invested in more
traditional manufacturing and treatment equipment.
Facilities that have failed to meet discharge limits with
traditional treatment technologies might be more
inclined to invest in pollution prevention planning than
a facility that successfully meets pretreatment
standards. Of course, any facility is likely to benefit from
pollution prevention planning and should be
encouraged to do so.
For many years, the Suffolk County, New York, POTW
has required its users to identify waste minimization
methods when applying for a discharge permit.
Engineering reports submitted with permit applications
must contain a section outlining the types of pollution
prevention actions the facility has considered, along
with the outcome of those evaluations. POTW
personnel review the pollution prevention statements
. and suggest additional pollution prevention actions the
facility might consider. The POTW reports that, in some
cases, pollution prevention plans have identified source
reduction opportunities that reduced the toxic
discharges of users to levels where a permit was no
longer necessary.
POTWs also can require their dischargers to adopt
BMPs such as inventory controls, employee training,
and basic maintenance and inspection activities (see
Section 2.1.1). BMPs generally can be implemented at
little or no cost and often can achieve significant
reductions in toxic discharges. Most industries have
implemented some level of BMPs in an effort to run
more efficient operations. Small industrial and
commercial facilities, however, may not be aware of
these simple steps to cleaner, more efficient operations
and could benefit from the POTWs guidance. The most
direct means for achieving widespread implementation
of BMPs is to require pollution prevention planning as
a precondition for obtaining or renewing a discharge
permit.
In an effort to reduce metal and organic contamination
in South San Francisco Bay, the Palo Alto POTW
recently passed an ordinance requiring BMPs for
automotive-related industries (i.e., facilities that repair
automobiles, trucks, buses, airplanes, boats, etc.; or
that perform services such as parts cleaning, body
work, vehicle washing, fuel dispensing, or radiator,
muffler, or transmission repair). Palo Alto offered these
facilities the option of either sealing floor drains and
implementing BMPs or installing treatment systems and
meeting local limits. Palo Alto drafted the ordinance with
the belief that automotive facilities can virtually eliminate
toxic waste discharges by implementing inexpensive
BMPs, thereby eliminating the need to apply for permits
and install costly treatment systems.
The ordinance stipulates that automotive facilities meet
the following requirements:
No person shall directly or indirectly dispose of
vehicle fluids, hazardous materials, or rinsewater to
storm drains.
Spilled rinsewater,* hazardous waste, and vehicle
fluids must immediately be cleaned up.
Vehicle fluid removal must take place where spilled
fluid will be in an area of secondary containment.
No person shall leave unattended drip pans or other
open containers containing vehicle fluids.
Vehicle service areas shall be cleaned using methods
that ensure that no materials are discharged to
sanitary or storm drains except in accordance with
pretreatment standards. Facilities that use the
following three-step process for cleaning floors will
not require a permit:
1. Clean up spills with rags or other absorbent
materials.
2. Sweep floor using dry absorbent materials.
3. Discharge dirty water from mopping floors to the
sanitary sewer via a toilet or sink.
Spill prevention and cleanup equipment and
absorbent materials shall be kept on hand at all
times.
Owners and operators shall ensure that all
employees are trained regarding BMPs upon hiring
and annually thereafter.
The Palo Alto POTW took several steps to ensure that
automotive facilities were aware of the new ordinance
and that facilities had access to technical assistance
prior to the effective date of the ordinance. For example,
they distributed a handbook describing automotive
29
-------
facility BMPs that reduce toxic waste discharges (Santa
Clara Valley, 1991). If requested by the user, POTW
personnel were available to go to the facility to answer
questions about the new ordinance and give guidance
on the implementation of BMPs. Palo Alto awarded
public recognition to automotive facilities that achieved
full compliance with pretreatment standards through
use of BMPs and other pollution prevention methods by
October 1,1992.
Palo Alto plans to develop similar ordinances in the near
future emphasizing BMPs for laboratories, machine
shops, and cooling towers.
4.2.1.2 Controlling Discharges from Small
Industrial and Commercial Users
Commercial and small industrial dischargers, such as
laundries, dental offices, laboratories, hospitals, printing
and publishing operations, photoprocessing facilities,
wood refinishers, and motor vehicle operations, are
sometimes not required to obtain discharge permits.
These facilities, however, may represent a significant
portion of the total loading of a toxic pollutant entering
a POTW. In this situation, a POTW could benefit greatly
from imposing local limits on and promoting pollution
prevention at commercial and small industrial users. In
some cases, a sewer use ordinance alone can provide
the necessary control over small industrial and
commercial users; however, an ordinance does not
allow a POTW to set user-specific requirements that
can be incorporated into individual discharge permits.
The Palo Alto POTW has been very active in permitting
commercial dischargers. Elevated levels of silver in
South San Francisco Bay led the Palo Alto POTW to
investigate which of its commercial and industrial users
contributed to silver loadings to the POTW (see Section
3.2.2). Based on industrial effluent data and commercial
facility survey data, Palo Alto determined that
photoprocessors accounted for up to 70 percent of the
total silver loadings entering the plant.
In response to this investigation, the Palo Alto POTW
decided to impose local commercial and industrial silver
limits designed to achieve a POTW effluent NPDES limit
of 2.3 u.g/1. Along with the new local limits, permitted
facilities must also comply with various pollution
prevention provisions designed to reduce the use and
discharge of silver. For example, affected industrial
facilities must now conduct studies identifying pollution
prevention opportunities for reducing silver discharges
as part of the permitting process. Through onsite
inspections and workshops, Palo Alto encourages
photoprocessors and industrial generators of silver
wastes to adopt pollution prevention methods wherever
practicable to achieve compliance with local limits.
The program has been immensely successful. The
average silver concentration of POTW effluent has
decreased by about 75 percent in the 2 years since local
limits were imposed and is now well below the NPDES
permit limit of 2.3 u,g/l. Palo Alto estimates the cost of
the source reduction project to the POTW at about $320
per pound of silver. This is extremely cost effective when
compared to the $2,700 per pound cost Palo Alto
estimated for an end-of-the-pipe reverse osmosis
treatment unit at the POTW.
4.2.1.3 Mass-based Limits
Currently, most POTWs issue pretreatment permits
specifying the allowable concentrations of certain
contaminants in wastewater discharged to sanitary
sewers. Concentration limits are generally expressed in
mg/l and are averaged over some specified period of
time to allow for normal fluctuations in production.
Mass-based limits, an alternative approach, provide
dischargers with a specific quantity of a given
contaminant (usually expressed as pounds per day) that
they can discharge over a specified period of time. The
mass discharge rate of a contaminant can be calculated
by knowing the flow rate of the waste stream and its
average concentration. For example, a waste stream of
10,000 gallons per day, averaging 2.5 mg/l of copper,
translates into 0.21 pounds of copper per day:
10,000 gal/day x 3.785 I/gal x 2.5 mg/l x 1 lb/453,600 mg
= 0.21 Ib/day
There are many institutional impediments to applying
mass-based limits to industrial users. EPA provides
guidance on the use of mass-based limits in its 1987
Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under
the Pretreatment Program.
In terms of pollution prevention, mass-based limits offer
an alternative to the more traditional concentration-based
limits. Eliminating one part of a waste stream through
pollution prevention or reducing water consumption
might cause a facility to increase pollutant
concentrations, even though the total mass of the
pollutant does not increase and might even decrease.
For example, in Figure 4-5, a hypothetical facility must
comply with a discharge limit of 0.161 mg/l copper. The
facility has two waste streams that combine before
discharge to the POTW: waste stream A discharges
132,100 gal/day containing 0.066 mg/l copper and
waste stream B discharges 158,520 gal/day containing
0.228 mg/l copper. Through pollution prevention, the
facility eliminates waste stream A entirely and thus has
achieved a reduction in the total mass of copper
discharged (from 0.37 Ib/day to 0.30 Ib/day); however,
the facility now finds itself exceeding its
concentration-based limit. An alternative mass-based
30
-------
Before Pollution Prevention
290,620 gal/day x
0.154 mg/l Cu =
0.37 Ib Cu/day
After Pollution Prevention
WASTE STREAM A
0 gal/day
0.0 mg/l Cu
158,520 gal/day x
0.228 mg/l Cu =
0.30 Ib Cu/day
Figure 4-5. Hypothetical waste stream concentrations before and after pollution prevention.
limit of 0.39 Ib/day would have provided the same level
of protection and allowed for the increase in
concentration due to the reduction in flow.1
To monitor facilities accurately for compliance with
mass-based limits, POTWs must have reliable data on
industrial flow along with the concentrations of
pollutants in the wastewater. While reliable
concentration data are relatively easy to collect,
accurate flow data may be more difficult to obtain. In
some cases, flow meters may have to be installed.
4.2J2 Responding to User Noncompliance
POTWs can encourage pollution prevention by taking
full advantage of their authority to deal with users in
noncompliance with pretreatment requirements. As part
of the normal program activities of issuing permits and
conducting inspections, POTWs can encourage
pollution prevention, but they cannot require specific
measures beyond those considered BMPs. In response
1 Mass-based limit calculated based on facility flow and current dis-
charge limit of 0.161 mg/l copper: 0.161 mg/l copper x 290,620
gal/day x 8.34 Ib/million gal x 0.000001 = 0.39 Ib/day copper.
to user noncompliance, however, a POTW can require
specific pollution prevention measures as part of a
mutually agreed upon compliance schedule with the
user.
In requiring the development of a corrective action plan,
POTWs can require facilities in noncompliance to
conduct pollution prevention planning, to identify
cost-effective pollution prevention measures, and to
develop an implementation schedule with interim and
final milestones. The implementation schedule can then
be incorporated into a binding compliance schedule.
The user in noncompliance can be required to evaluate
pollution prevention options, but should be allowed the
flexibility to develop a corrective action plan that
includes the most effective mix of pollution prevention
measures and traditional treatment options. An example
of a compliance schedule that includes pollution
prevention and recycling requirements is provided in
Figure 4-6.
4.3 Community Education and Outreach
POTWs can play a central role in communicating the
need for greater pollution prevention in businesses and
31
-------
COMPLIANCE SCHEDULE FOR USER IN NONCOMPLIANCE WITH PERMIT LIMITS
A. By July 1,1992 ~ ,
The user shall submit a preliminary report oa corrective action measures to be taken to maintain consistent compliance with permit
conditions. At a minimum, the report shall include: <, "
A detailed process-flow diagram that identifies and characterizes the input of raw materials, the "outflow of prdducts, and
the generation of wastes. ">'" '
Any steps taken to reduce the concentrations and/or mass of regulated pollutants in the user's discharge to.the sewer.
Preliminary findings of corrective action planning, including me identification of any pollution prevention, recycle/reuse,
and treatment measures that are being considered for implementation, ' /
B. By August 15,1992 ,----'", ,
The user shall submit to the POTW a corrective action plan for its discharge to the sewer system. The* plan shall present an
implementation schedule that outlines the steps to be taken to bring the user's discharge into consistent compliance with permit'
conditions by December 31,1992. In developing the corrective action plan, the user shall evaluate and identify, for implementation,
aU cost-effective pollution prevention measures. Once developed, and if deemed technically sound by the POTW, the impfeinentation
schedule shall be incorporated into this compliance schedule. - ,
Figure 4*6. Example of compliance schedule that incorporates pollution prevention.
the community by educating and directing people to
sources of further information. In many cases, simply
being made aware of the benefits of pollution prevention
techniques is all that is needed to prompt businesses to
pursue these options. Pollution prevention education
and outreach activities are relatively inexpensive and
simple to implement and capable of yielding reductions
In toxic discharges to a POTW.
Many POTWs have either initiated or participated in
education and outreach programs that stress pollution
prevention. POTW pretreatment program personnel
may want to collaborate with other state and local
agencies to develop outreach programs of this nature.
In many cases, programs of this sort may already exist
In the POTWs region, in which case the POTW may
want to join in the effort by providing input and support
from the wastewater sector. Consider the following
education and outreach alternatives.
4.3.1 Sponsoring Workshops and Training
Workshops and training are excellent. means for
conveying detailed pollution prevention information and
can provide opportunities for all parties to discuss
pollution prevention in an informal atmosphere.
Workshops and training can address pollution
prevention in general or can focus on pollution
prevention in a specific industry. These might also
include exercises in how to identify pollution prevention
opportunities and perform cost-effectiveness analyses.
Some of these events link industry personnel with
companies that manufacture and design recycling and
waste minimizing equipment.
A number of POTWs in Massachusetts, including
Haverhill and the Massachusetts Water Resources
Authority, have sponsored workshops in conjunction
with the OTA. These workshops have been designed for
both POTW and industry personnel and have covered
pollution prevention in general as well as targeted
specific industries such as machine shops,
photoprocessing operations, and laboratories. A recent
OTA conference on reducing the use of solvents
included a trade show of solvent recyclers and
manufacturers of nontoxic solvent substitutes allowing
solvent users to obtain firsthand information about
solvent recycling and source reduction.
4.3.2 Convening Local Pollution Prevention
Forums
A pollution prevention forum might be composed of
individuals from diverse groups of interested parties,
such as POTWs, regulators, and local businesses, that
want to explore the potential for various regulatory and
nonregulatory pollution prevention initiatives to achieve
reductions in toxic discharges and solve specific
environmental problems.
WLSSD was instrumental in obtaining state and federal
support for Minnesota's Lake Superior Partnership
(LSP) advisory group, which consults with WLSSD and
the MPCAon regulatory and nonregulatory initiatives to
promote pollution prevention among industries
discharging to the Western Lake Superior watershed.
The LSP advisory group consists of representatives
from industry, commerce, state and local governments,
environmental groups, academia, and other interested
citizens. The group's function is twofold: (1) to provide
feedback to the MPCA and WLSSD regarding pollution
prevention initiatives and (2) to serve as a vehicle for
the transfer of pollution prevention and other relevant
information among its various members. The group
32
-------
explores issues of mutual interest to its members and
makes recommendations about possible pollution
prevention programs. The full LSP advisory group
meets on a quarterly basis. Members involved in
specific projects meet more frequently. ,
Part of the impetus for the formation of the LSP advisory
group was to address mercury contamination in
Western Lake Superior. The WLSSD POTW anticipated
that it would not meet its future NPDES permit level for
mercury without reducing influent mercury loadings to
the POTW. WLSSD believed that various unpermitted
commercial and domestic sources were contributing to
the bulk of the POTW's mercury loadings. WLSSD
determined that dental offices, laboratories, mercury
thermostats, batteries, and fluorescent light bulbs were
the principal sources of mercury contamination.
Mercury in municipal solid waste is transferred to the
scrubber water from the municipal solid waste
incinerator, which in turn is discharged to the POTW.
With the help of the LSP advisory group, WLSSD
formed two workihg'groups: the Dental Mercury Work
Group, with representatives of the Northeast Dental
Society, and the Laboratory Mercury Work Group, with
local laboratory staff. WLSSD hopes that the working
groups will identify means by which dentists and
laboratories can significantly reduce their mercury
discharges through implementation of BMPs and other
pollution prevention measures and thus avoid the need
to directly permit these establishments in the future. In
addition, the advisory group has explored the possibility
of forming a mercury thermostat collection program for
(ocal construction/demolition companies and is
investigating the impact of fluorescent light disposal on
mercury levels in the POTW's effluent.
4.3.3 Publicly Recognizing Pollution
Prevention Achievements
Recognizing pollution prevention achievements among
the POTW's dischargers through an award and public
announcement provides an incentive for users to
voluntarily reduce toxic discharges, improves public
relations, and demonstrates the POTW's commitment
to furthering pollution prevention in the community.
The Maine Wastewater Control Association (MWCA),
which represents pretreatment POTWs in Maine,
awards the MWCA Pretreatment Excellence Award
each year to the industrial facility that best
demonstrates its commitment to reducing toxic
discharges. MWCA judges facilities according to the
following criteria:
Wastewater pretreatment processes used by the
facility.
The percentage of the facility's process water being
recycled.
The percentage of the facility's waste residual
material (i.e., sludge) being reused.
Availability of adequately trained staff and financial
resources.
Innovative ideas the facility has used to reduce
pollutants in its wastewater.
The facility's system(s) for effectively recording and
tracking compliance monitoring data.
The types of spill control procedures/devices (e.g.,
secondary containment) the facility employs to
prevent accidental chemical spills from entering the
sewer system.
Ability of the facility to stay abreast of modifications
to applicable environmental laws.
The environmental and/or economical benefits or
successes derived from implementing pollution
prevention methods.
As part of its effort to control toxic discharges from
automobile-related facilities (see Section 4.2.1.1), Palo
Alto instituted the Clean Bay Business Award. Palo Alto
publicly recognized automobile facilities in compliance
with the new discharge ordinances prior to the required
date of October 1, 1992, with the Clean Bay Business
Award. Palo Alto hopes that consumers will be
predisposed toward businesses that have won the
award.
4.3.4 Compiling and Distributing Pollution
Prevention Information
POTWs can educate industrial, commercial, and
domestic users with a range of existing pollution
prevention publications from technical documents on
specific pollution prevention techniques, to more
general pamphlets on BMPs or household hazardous
waste management. POTWs also can develop their
own materials that address specific concerns in their
communities. Many POTWs are active in supplying
information resources; here are just a few examples:
The POTW in Melbourne, Florida, obtains pollution
prevention documents from the PIES (see Appendix
A for more information on PIES) and distributes them
at inspections. The Melbourne POTW has also-
created its own posters and bumper stickers
designed to "spread the word" on pollution prevention
throughout the community.
In addition to distributing pollution prevention
information during inspections and periodic mailings
to targeted audiences, the Orange County Sanitation
District in California operates a pollution prevention
library available to its industrial dischargers.
33
-------
The Louisville and Jefferson County Metropolitan
Sewer District (MSD) in Kentucky publishes its own
newsletter entitled Stream Line. MSD distributes the
newsletter to all of its industrial dischargers and
covers pollution prevention as well as other issues
pertinent to pretreatment and the POTW.
The City of Vacaville, California, distributes two
hazardous waste minimization booklets (the
California Waste Exchange's Directory of Industrial
Recyclers and Waste Minimization: Environmental
Quality with Economic Benefits) to wastewater
dischargers as a routine part of pretreatment
inspections (Sherry, 1988a).
The Palo Alto Regional Water Quality Control Plant
provides guidance on how to improve compliance
with pretreatment standards using simple BMPs.
4.3.5 Publicizing Household Hazardous
Waste Collection Programs and
Industrial Waste Exchanges
Household hazardous waste collection programs have
been highly successful in preventing the indiscriminate
disposal of hazardous waste by domestic sources.
Industrial waste exchanges, which help match industrial
waste from one facility with other facilities that can use
that waste in another process, have been successful in
promoting greater industrial waste reuse. (Appendix A
lists a few existing waste exchanges.) While a POTW
may not have the resources to form such programs
itself, it can inform its domestic, commercial, and
industrial dischargers of the availability of such
programs. POTWs also can work cooperatively with
other agencies to develop and maintain household
hazardous waste collection 'programs and industrial
waste exchanges. The Louisville and Jefferson County
MSD, for example, helps several local agencies
publicize and staff the local household hazardous waste
collection days.
34
-------
Chapters
References
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
City of Palo Alto. 1992. Silver Reduction Pilot Program;
Palo Alto Regional Water Quality Control Plant. Palo
Alto, CA.
Greiner, T.J., and P.H. Richard. 1992. Facility inspections:
obstacles and opportunities. Unpublished.
MPCAand WLSSD. 1992. Minnesota Pollution Control
Agency and Western Lake Superior Sanitary District.
Lake Superior Partnership; Compliance Assistance
Program: a multimedia and pollution prevention
inspection program. October 1, 1991 through April
30, 1992. Semiannual progress report to U.S.
Environmental Protection Agency.
MWRA. 1992. Massachusetts Water Resources
Authority. Telephone conversation between Eric
Renda, MWRA, and Lynn Knight, Eastern Research
Group, Inc. November 11.
PPIC. 1992. Pollution Prevention Information
Clearinghouse. PPIC data base. Falls Church, VA.
Santa Clara Valley Nonpoint Source Pollution Control
Program. 1991. Best management practices for
automotive-related industries. San Jose, CA.
Sherry, S. 1988a. Minimizing hazardous wastes:
regulatory options for local governments.
Sacramento, CA: Local Government Commission.
Sherry, S. 1988b. Reducing industrial toxic wastes and
discharges: the role of POTWs. Sacramento, CA:
Local Government Commission.
URI. 1988. University of Rhode Island, Department of
Natural Sciences. Natural resource facts: household
hazardous waste. Factsheet 88-3. Providence, Rl:
URI.
U.S. EPA. 1992. U.S. Environmental Protection Agency.
Facility pollution prevention guide. Washington, DC:
Office of Research and Development.
EPA/600/R-92/088. NTIS PB92-213206.
U.S. EPA. 1991 a. U.S. Environmental Protection
Agency. Interim policy on the inclusion of pollution
prevention and recycling in enforcement settlements.
Memo from James A. Strock, Assistant Administrator,
Washington, DC.
U.S. EPA. 1991b. U.S. Environmental Protection
Agency. Environmental research brief: waste
minimization assessment for a manufacturer of
printed circuit boards. Cincinnati, OH: Risk Reduction
Engineering Laboratory. EPA/600/S-92/008. NTIS
PB92-196344.
U.S. EPA. 1991c. U.S. Environmental Protection
Agency. Achievements in source reduction and
recycling for ten industries in the United States.
Washington, DC: Office of Research and
Development. EPA/600/2-91/051. NTIS PB92-13747.
U.S. EPA. 1991d. U.S. Environmental Protection
Agency. Supplemental manual on the development
and implementation of local discharge limits under
the pretreatment program. 21W-4002. Washington,
DC: Office of Water.
U.S. EPA. 1991e. U.S. Environmental Protection
Agency. Report to Congress on the National
Pretreatment Program. Washington, DC: Office of
Wastewater Enforcement and Compliance.
U.S. EPA. 1989. U.S. Environmental Protection Agency.
Pollution prevention benefits manual: vol. 1 the
manual, phase 2. NTIS PB93-164101. Washington,
DC: Office of Solid Waste. October.
35
-------
U.S. EPA. 1988. U.S. Environmental Protection Agency.
Waste minimization opportunity assessment manual.
Cincinnati, OH: Hazardous Waste Engineering
Research Laboratory, Center for Environmental
Research Information. EPA/625/7-88/003. NTIS
PB92-216985.
U.S. GAO. 1991. U.S. General Accounting Office.
Water pollution: nonindustrial wastewater pollution
can be better managed. Washington, DC.
WRITAR. 1992. Waste Reduction Institute for Training
and Applications Research, Inc. Survey and
summaries: state legislation relating to pollution
prevention. Minneapolis, MN: WRITAR.
36
-------
Appendix A
Pollution Prevention Resources
Many federal, state, and local agencies have years of
experience with the technical and organizational
aspects of pollution prevention. POTWs will find these
resources invaluable as they initiate or expand pollution
prevention in their existing operations. This chapter lists
pollution prevention contacts at the federal and state
levels and highlights some of the many currently
available publications addressing pollution prevention.
Federal Technical Assistance Resources
Pollution Prevention Information
Clearinghouse (PPIC)/Pollution Prevention
Information Exchange (PIES) Network
PPIC provides technical, policy, programmatic,
legislative, and financial information relevant to pollution
prevention. Through a computer network and
experienced technical personnel, PPIC can assist
POTWs and other interested parties in establishing
pollution prevention programs; compiling general and
industry-specific pollution prevention information;
locating and ordering documents; and identifying grant
and project funding, pertinent legislation, and upcoming
pollution prevention conferences, workshops, and
trainings.
The electronic PIES network provides access to a wide
range of pollution prevention-related information,
including case studies, bibliographies, pertinent state
and federal pollution prevention legislation, calendar of
events, directory of experts, and topical miniexchanges.
PIES also features an on-line document ordering
system.
To learn more about PPIC services and how to hook up
to the PIES network, phone:
PPIC Technical Assistance Phone: 703-821-4800
(9 a.m. to 5 p.m., EST, Mon. through Fri.), or Fax:
703-442-0584
Pollution Prevention Information Exchange System
(PIES): 703-506-1025
RCRA/Superfund Hotline: 800-424-9346
Small Business Ombudsman Hotline: 800-368-5888
Or write:
Pollution Prevention Information Clearinghouse (PPIC)
c/o SAIC
7600-A Leesburg Drive
Falls Church, VA 22043
U.S. EPA Offices
U.S. EPA Office of Solid Waste
Waste Management Division (OS-320W)
401 M Street, SW.
Washington, DC 20460
703-308-8402
U.S. EPA Office of Solid Waste and Emergency Response
(OS-100)
401 M Street, SW.
Washington, DC 20460
703-821-4789
U.S. EPA Office of Pollution Prevention and Toxics
(TS-792)
401 M Street, SW.
Washington, DC 20460
202-260-3810
U.S. EPA Office of Air and Radiation (ANR-443)
401 M Street, SW.
Washington, DC 20460
202-260-7400
U.S. EPA Office of Water (WH-556)
401 M Street, SW.
Washington, DC 20460
202-260-5700
U.S. EPA Office of Research and Development
Center for Environmental Research Information
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562
U.S. EPA Office of Research and Development
Risk Reduction Engineering Laboratory
Pollution Prevention Research Branch
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7529
37
-------
U.S. EPA Regional Offices
Region 1 (CT, MA, ME, NH, Rl, VT)
John F. Kennedy Federal Building
One Congress Street
Boston, MA 02203
617-565-3420
Region 2 (NJ, NY, PR, VI)
Jacob K. Javits Federal Building
26 Federal Plaza
New York, NY 10278
212-264-2657
Region 3 (DC, DE, MD, PA, VA, WV)
841 Chestnut Building
Philadelphia, PA 19107
215-597-9800
Region 4 (AL, FL, GA, KY, MS, NC, SC, TN)
345 Courtland Street, NE.
Atlanta, GA 30365
404-347-4727
Region 5 (IL, IN, OH, Ml, MN, Wl)
77 West Jackson Blvd.
Chicago, IL 60604
312-353-2000
Region 6 (AR, LA, OK, NM, TX)
First Interstate Bank
Tower at Fountain Place
445 Ross Avenue, Suite 1200
Dallas, TX 75202
214-655-6444
Region 7 (IA, KS, MO, NE)
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7000
Region 8 (CO, MT, ND, SD, UT, WY)
999 18th Street, Suite 500
Denver, CO 80202-2405
303-293-1603
Region 9 (Amer. Samoa, AZ, CA, NMI, Guam, HI, NV)
75 Hawthorne Street
San Francisco, CA94105
415-744-1305
Region 10 (AK, ID, OR, WA)
1200 Sixth Avenue
Seattle, WA 98101
206-553-4973
State Pollution Prevention Contacts
Alabama
Alabama Department of Environmental Management
1751 Dickinson Drive
Montgomery, AL 36130
205-260-2777
Alaska
Pollution Prevention Office
Alaska Department of Environmental Conservation
3601 C Street, Suite 1334
Anchorage, AK 99503
907-563-6529
Arizona
Pollution Prevention Unit
Arizona Department of Environmental Quality
2005 North Central Avenue
Phoenix, AZ 85004
602-207-4233
Arkansas
Hazardous Waste Division
Arkansas Department of Pollution Prevention and Ecology
P.O. Box 8913
Little Rock, AR 72219-8913
501-570-2861
California
California Environmental Protection Agency
555 Capitol Mall, Suite 235
Sacramento, CA 95814
916-445-3846
Department of Toxic Substances Control
Office of Pollution Prevention and Technology
Development
400 P Street
P.O. Box 806
Sacramento, CA 95812-0806
916-322-3670
Colorado
Colorado Department of Health
HMWMD-B2
4300 Cherry Creek Drive South
Denver, CO 80222
303-692-3309
Department of Mechanical Engineering
Colorado State University
Fort Collins, CO 80523
303-491-5317
38
-------
Connecticut
Illinois
Connecticut Technical Assistance Program
(CONNTAP)
Connecticut Hazardous Waste Management Service
900 Asylum Avenue
Suite 360
Hartford, CT 06105-1904
203-241-0777
Delaware
Pollution Prevention Program
Department of Natural Resources and Environmental
Control
P.O. Box 1401
Kings Highway
Dover, DE 19903
302-739-5071/3822
Florida
Pollution Prevention Coordinators
Waste Reduction Assistance Program
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-0300
Georgia
Municipal Permitting Program
Environmental Protection Division
Georgia Department of Natural Resources
4244 International Parkway, Suite 110
Atlanta, GA 30334
404-656-4988
Hawaii
State of Hawaii Department of Health
Solid and Hazardous Waste Branch
Five Waterfront Plaza, Suite 250
500 Ala Moana Boulevard
Honolulu, HI 96813
808-586-4226
Idaho
Division of Environmental Quality
Idaho Department of Health and Welfare
1410 North Hilton Street
Boise, ID 83706-1290
208-334-5879
Office of Pollution Prevention
Illinois Environmental Protection Agency
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
217-782-8700
Illinois Hazardous Waste Research and Information
Center
One East Hazelwood Drive
Champaign, IL 61820
217-333-8940
Indiana
Office of Pollution Prevention and Technical
Assistance
Indiana Department of Environmental Management
105 South Meridian Street
P.O. Box6015
Indianapolis, IN 46206-6015
317-232-8172
Iowa
Iowa Waste Reduction Center
University of Northern Iowa
Cedar Falls, IA 50614-0185
319-273-2079
Kansas
Bureau of Waste Management
Kansas Department of Health and Environment
Forbes Field, Building 740
Topeka, KS 66620-0001
913-296-1603
Hazardous Waste Engineering Extension Program
Ward Hall
Manhattan, KS 66506-2508
913-532-6026
Center for Environmental Education and Training
Kansas University
P.O. Box 25936
Overland Park, KS 66225-5936
913-864-3284
Kentucky
KY PARTNERSState Waste Reduction Center
Ernst Hall, Room 312
University of Louisville
Louisville, KY 40292
502-588-7260
(Inside KY: 1-800-334-8635 X7260)
39
-------
Louisiana
Louisiana Department of Environmental Quality
P.O. Box 82663
Baton Rouge, LA 70884-2263
504-765-0720
Maine
Office of Pollution Prevention
Department of Environmental Protection
State House Station #17
Augusta, ME 04333
207-287-4152
Department of Environmental Protection
State House Station #17
Augusta, ME 04333
207-287-7767
Maryland
Office of Strategic Planning and Policy Coordination
Maryland Department of the Environment
2500 Broening Highway
Baltimore, MD 21224
410-631-3114
Massachusetts
Office of Technical Assistance for Toxic Use Reduction
Executive Office of Environmental Affairs
100 Cambridge Street, Room 2109
Boston, MA 02202
617-727-3260
Toxics Use Reduction Institute
University of Lowell
1 University Avenue
Lowell, MA 01854
508-934-3275
Michigan
Office of Waste Reduction Services
Michigan Department of Commerce and Natural
Resources
P.O. Box 30004
116 West Allegan Street
Lansing, Ml 48909-7504
517-335-1178
(Inside Ml: 1-800-662-9278, Waste Reduction
Clearinghouse)
Minnesota
Environmental Assessment Office
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
612-296-8643
Minnesota Technical Assistance Program
School of Public Health
Division of Environmental and Occupational Health
University of Minnesota
1313 5th Street, SE., Suite 207
Minneapolis, MN 55414
612-627-4646
Mississippi
Mississippi Technical Assistance Program and
Mississippi Solid Waste Reduction Assistance
P.O. Drawer CN
Mississippi State, MS 39762
601-325-8454
Waste Reduction/Waste Minimization Program
Mississippi Department of Environmental Quality
P.O. Box 10385
Jackson, MS 39289-0385
601-961-5171
Missouri
Hazardous Waste Program
Division of Environmental Quality
Missouri Department of Natural Resources
205 Jefferson Street
P.O. Box 176
Jefferson City, MO 65102
314-751-3176
Montana
Solid and Hazardous Waste Bureau
Montana Department of Health and Environmental
Services
Cogswell Building
Helena, MT 59620
406-444-2821
Nebraska
Hazardous Waste Section
Nebraska Department of Environmental Quality
1200 N Street, Suite 400
P.O. Box 98922
Lincoln, NE 68509-8922
402-471-4217
40
-------
Nevada
North Carolina
Business Environmental Program
Nevada Small Business Development Center
University of Nevada - Reno
Reno, NV 89557-0100
702-784-1717
New Hampshire
WasteCap Program
New Hampshire Business and Industry Association
122 N. Main .Street
Concord, NH 03301
603-224-5388
New Hampshire Pollution Prevention Program
New Hampshire Department of Environmental
Services
6 Hazen Drive
Concord, NH 03301
603-271-2901
New Jersey
Office of Pollution Prevention
New Jersey Department of Environmental Protection
and Energy
CN-423
401 East State Street, Floor 2
Trenton, NJ 08625
609-777-0518
New Mexico
Municipal Water Pollution Prevention Program
New Mexico Environment Department
1190 St. Francis Drive
P.O. Box26110
Santa Fe, NM 87502
505-827-0152
New York
Pollution Prevention Unit
New York State Department of Environmental
Conservation
50 Wolf Road, Room 538
Albany, NY 12233-8010
518-457-7267
Erie County Office of Pollution Prevention
95 Franklin Street, Room 1077
Buffalo, NY 14202
716-858-6370
Pollution Prevention Program
Office of Waste Reduction
North Carolina Department of Environment, Health,
and Natural Resources
P.O. Box 27687
Raleigh, NC 27611-7687
919-571-4100
North Dakota
Environmental Health Section
Division of Waste Management
North Dakota Department of Health
and Consolidated Laboratories
P.O. Box 5520
1200 Missouri Avenue, Room 201
Bismarck, ND 58502-5520
701-221-5150
Ohio
Center for Applied Environmental Technologies
Institute of Advanced Manufacturing Sciences
1111 Edison Drive
Cincinnati, OH 45216-2265
513-948-2050
Pollution Prevention Section
Division of Hazardous Waste Management
Ohio Environmental Protection Agency
P.O. Box 1049
1800 Watermark Drive
Columbus, OH 43266-0149
614-644-3469
Ohio's Thomas Edison Program
Ohio Department of Development
77 South High Street, 25th Floor
Columbus, OH 43215
614-466-3887
Oklahoma
Customer Assistance Division
Oklahoma Department of Environmental Quality
1000 Northeast 10th Street
Oklahoma City, OK 73117-1299
405-271-7047
Environmental Health Administration, 0200
Oklahoma Department of Environmental Quality
1000 North East 10th Street
Oklahoma City, OK 73117-1299
405-271-7047
41
-------
Oregon
Hazardous Waste Reduction and Technical
Assistance Program
Hazardous and Solid Waste Division
Oregon Department of Environmental Quality
811 SW. Sixth Avenue
Portland, OR 97204
503-229-5913
Pennsylvania
Division of Waste Minimization and Planning
Pennsylvania Department of Environmental
Resources
P.O. Box 8472
Harrisburg, PA 17105-8472
717-787-7382
Center for Hazardous Materials Research
University of Pittsburgh Applied Research Center
320 William Pitt Way
Pittsburgh, PA 15238
412-826-5320
PENNTAP
110 Barbara Building 2
810 North University Drive
University Park, PA 16802
814-865-0427
Rhode Island
Pollution Prevention Section
Office of Environmental Coordination
Rhode Island Department of Environmental
Management
83 Park Street
Providence, Rl 02903
401-277-3434
South Carolina
Continuing Engineering Education
Clemson University
P.O. Drawer 1607
Clemson, SC 29633
803-656-3308
South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
803-734-5360
South Dakota
Office of Waste Management
Division of Environmental Regulations
South Dakota Department of Environment
and Natural Resources
319 S. Coteau
c/o 500 E. Capitol Avenue
Pierre, SD 57501
605-773-4217
Division of Environmental Regulations
South Dakota Department of Environment and
Natural Resources
Joe Foss Building
523 E. Capitol Avenue
Pierre, SD 57501-3181
605-773-3153
Tennessee
Waste Reduction Assistance Program
Center for Industrial Services
University of Tennessee
226 Capitol Boulevard Building, Suite 606
Nashville, TN 37219-1804
615-242-4816
Texas
Office of Pollution Prevention and Conservation
Texas Water Commission
P.O. Box 13087
Austin, TX 78711-3087
512-475-2187.
Center for Hazardous and Toxic Waste Studies
Texas Tech University
P.O. Box 43121
Lubbock, TX 79409-3121
806-742-1413
Utah
Policy and Planning Section
Department of Environmental Quality
168 North 1950 West, Bldg. 2
Salt Lake City, UT 84114-4810
801-536-4477
Vermont
Agency of Natural Resources
Pollution Prevention Division
103 South Main Street, West Bldg.
Waterbury, VT 05671-0404
802-244-8702
42
-------
Virginia
Virginia Department of Environmental Quality
Monroe Building, 14th Floor
101 N. 14th Street
Richmond, VA 23219
804-371-8716
Washington
Toxics Reduction Center
Washington Department of Ecology
Waste Reduction, Recycling, and Litter Control
Program
P.O. Box 47600
Olympia, WA 98504-7600
206-438-7871
West Virginia
Generator Assistance Program
Waste Management Section
West Virginia Department of Environmental
Protection
1356 Hansford Street
Charleston, WV 25301
304-558-4000
Wisconsin
Office of Technical Services
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, Wl 53707-7921
608-267-9700
Hazardous Waste Minimization
Bureau of Solid and Hazardous Waste Management
Wisconsin Department of Natural Resources
101 South Webster Street
P.O. Box 7921
Madison, Wl 53707-7921
608-267-3763
Wyoming
Solid and Hazardous Waste Division
Wyoming Department of Environmental Quality
122 West 25th Street
Herschler Building
Cheyenne, WY 82002
307-777-7752
Published Pollution Prevention Materials
U.S. EPA
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Documents with an EPA document number that begins
with 530 are available from the Resource Conservation
and Recovery Act (RCRA) Hotline. The national toll-free
number is 800-424-9346 or, for the hearing impaired,
TDD 800-553-7672. In the Washington, DC, area, call
703-412-9810. Or write to:
RCRA Information Center
U.S. Environmental Protection Agency
Office of Solid Waste (OS-305)
401 M Street, SW.
Washington, DC 20460
Office of Research and Development. 1992. User's
Guide: Strategic Waste Minimization Initiative
(SWAMI) Version 2.0: A Software Tool to Aid in
Process Analysis for Pollution Prevention.
EPA/625/11-91/004.
Office of Research and Development. 1992. Facility
Pollution Prevention Guide. EPA/600/R-92/088.
NTIS PB92-213206.
Office of Research and Development. 1991.
Achievements in Source Reduction and Recycling for
Ten Industries in the United States.
EPA/600/2-91/051. NTIS PB92-137470.
Office of Research and Development. 1991. The
Environmental Challenges of the 1990s;
Proceedings of the International Conference
on Pollution Prevention: Clean Technologies and
Clean Products. EPA/600/9-90/039. NTIS
PB91-148387.
Office of Research and Development. 1991. Industrial
Pollution Prevention Opportunities for the 1990s.
EPA/600/8-91/052. NTIS PB91-220376.
43
-------
Office of Solid Waste and Emergency Response. 1990.
Waste Minimization: Environmental Quality with
Economic Benefits. 2nd ed. EPA/530/SW-90/044.
Office of Solid Waste and Emergency Response. 1986.
Waste MinimizationIssues and Options Vols. l-lll.
EPA/530/SW-86/041 through 7043.
Office of Solid Waste and Emergency Response. 1986.
Report to Congress: Waste Minimization Vols. I and
II. EPA/530/SW-86/033 and 7034.
Hazardous Waste Engineering Research Laboratory.
1988. Waste Minimization Opportunity Assessment
Manual. EPA/625/7-88/003. NTIS PB92-216985.
The Office of Research and Development (ORD)
has developed the following series of
industry-specific reports on pollution prevention:
Guides to Pollution Prevention: The Pesticide
Formulating Industry. EPA/625/7-90/004. NTIS
PB90-192790.
Guides to Pollution Prevention: The Paint
Manufacturing Industry. EPA/625/7-90/005. NTIS
PB90-256405.
Guides to Pollution Prevention: The Fabricated Metal
Products Industry. EPA/625/7-90/006. NTIS
PB91-110015.
Guides to Pollution Prevention: The Printed Circuit
Board Manufacturing Industry. EPA/625/7-90/007.
NTIS PB90-256413.
Guides to Pollution Prevention: The Commercial
Printing Industry. EPA/625/7-90/008. NTIS
PB91-110023.
Guides to Pollution Prevention: Selected Hospital
Waste Streams. EPA/625/7-90/009. NTIS
PB90-256421.
Guides to Pollution Prevention: Research and
Educational Institutions. EPA/625/7-90/010. NTIS
PB90-256439.
Guides to Pollution Prevention: The Photoprocessing
Industry. EPA/625/7-91/012. NTIS PB92-129121.
Guides to Pollution Prevention: The Automotive
Repair Industry. EPA/625/7-91/013. NTIS
PB91-227975.
Guides to Pollution Prevention: The
Fiberglass-Reinforced and Composite Plastics
Industry. EPA/625/7-91/014. NTIS PB91-227967.
Guides to Pollution Prevention: The Marine
Maintenance and Repair Industry. EPA/625/7-91/015.
NTIS PB91-228817.
Guides to Pollution Prevention: The Automotive
Refinishing Industry. EPA/625/7-91/016. NTIS
PB92-129139.
Guides to Pollution Prevention: The Pharmaceutical
Industry. EPA/625/7-91/017. NTIS PB92-100080.
In addition, ORD has developed research briefs
on specific pollution prevention topics:
Waste Reduction Activities and Options fora:
Printer of Legal Forms and Supplies.
EPA/600/S-92/003. NTIS PB92-217496.
Nuclear Powered Electric Generating Plant.
EPA/600/S-92/025. NTIS PB92-235654.
State DOT Maintenance Facility. EPA/600/S-92/026.
Local Board of Education in New Jersey.
EPA/600/S-92/027. NTIS PB92-238476.
Manufacturer of Finished Leather. EPA/600/S-92/039.
NTIS PB93-123115.
Manufacturer of Paints for Metal Finishing.
EPA/600/S-92/040. NTIS PB93-123143.
Manufacturer of Writing Instruments.
EPA/600/S-92/041. NTIS PB93-123131.
Manufacturer of Room Air Conditioning Units and
Humidifiers. EPA/600/S-92/042. NTIS PB93-123149.
Autobody Repair Facility. EPA/600/S-92/043. NTIS
PB93-123156.
Fabricator/Finisher of Steel Computer Parts.
EPA/600/S-92/044. NTIS PB93-123164.
Manufacturer of Artists' Supply Paints.
EPA/600/S-92/045. NTIS PB93-123172.
Manufacturer of Wire Stock for Metal Items.
EPA/600/S-92/046. NTIS PB93-123180.
Manufacturer of Commercial Refrigeration Units.
EPA/600/S-92/047. NTIS PB93-123198.
Transporter of Bulk Plastic Pellets.
EPA/600/S-92/048. NTIS PB93-123206.
Manufacturer of Electroplated Wire.
EPA/600/S-92/049. NTIS PB93-123214.
Manufacturer of Systems to Produce
Semiconductors. EPA/600/S-92/050. NTIS
PB93-123220.
Remanufacturer of Automobile Radiators.
EPA/600/S-92/051. NTIS PB93-123230.
Manufacturer of Fire Retardant Plastic Pellets and
Hot Melt Adhesives. EPA/600/S-92/052. NTIS
PB93-123248.
44
-------
Printing Plate Prep Section of Newspaper.
EPA/600/S-92/053. NTIS PB93-126563.
General Paints and Painting Supplies.
EPA/600/S-92/054. NTIS PB93-126316.
Manufacturer of Fine Chemicals Using Batch
Processes. EPA/600/S-92/055. NTIS PB93-126308.
Laminator of Paper and Cardboard Packages.
EPA/600/S-92/056. NTIS PB93-126290.
Manufacturer of Hardened Steel Gears.
EPA/600/S-92/057. NTIS PB93-126282.
Scrap Metal Recovery Facility. EPA/600/S-92/058.
NTIS PB93-126266.
Manufacturer of Electroplating Chemical Products.
EPA/600/S-92/059. NTIS PB93-126258.
Manufacturer of Plastic Containers by Injection
Molding. EPA/600/S-92/060. NTIS PB93-126241.
Fossil Fuel-Fired Electrical Generating Plant.
EPA/600/S-92/061. NTIS PB93-126233.
Manufacturer of Commercial Dry Cleaning
Equipment. EPA/600/S-92/062. NTIS PB93-126225.
Electrical Utility Transmission System Monitoring and
Maintenance Facility. EPA/600/S-92/063. NTIS
PB93-126639.
Manufacturer of Orthopedic Implants.
EPA/600/S-92/064. NTIS PB93-126217.
Waste Minimization Assessment fora
Manufacturer of:
Printed Plastic Bags. EPA/600/M-90/017. NTIS
PB91-179036.
Metal Parts Coating Plant. EPA/600/M-91/015. NTIS
PB91-234492.
Outdoor Illuminated Signs. EPA/600/M-91/016. NTIS
PB91-234500.
Rebuilt Railway Cars and Components.
EPA/600/M-91/017. NTIS PB91-234518.
Brazed Aluminum Oil Coolers. EPA/600/M-91/018.
NTIS PB91-234484.
HVAC Equipment. EPA/600/M-91/019. NTIS
PB91-234476.
Bumper Refinishing Plant. EPA/600/M-91/020. NTIS
PB91-234526.
Multilayered Printed Circuit Board Manufacture.
EPA/600/M-91/021. NTIS PB91-234534.
Printed Circuit Boards. EPA/600/M-91/022. NTIS
PB91-234542.
Paint Manufacturing Plant. EPA/600/M-91/023. NTIS
PB91-234559.
Compressed Air Equipment Components.
EPA/600/M-91/024. NTIS PB91-234567.
Aluminum Cans. EPA/600/M-91/025. NTIS
PB91-234575.
Refurbished Railcar Boarding Assemblies.
EPA/600/M-91/044. NTIS PB92-104348.
Prototype Printed Circuit Boards. EPA/600/M-91/045.
NTIS PB92-104355.
Speed Reduction Equipment. EPA/600/M-91/046.
NTIS PB92-104363.
Printed Labels. EPA/600/M-91/047. NTIS
PB92-104371.
Chemicals. ERA/600/S-92/004. NTIS PB92-203595.
A Dairy. EPA/600/S-92/005. NTIS PB92-217264.
Metal-Cutting Wheels and Components.
EPA/600/S-92/006. NTIS PB92-192145.
Auto AC Condensers and Evaporators.
EPA/600/S-92/007. NTIS PB92-188739.
Printed Circuit Board Manufacturer.
EPA/600/S-92/008. NTIS PB92-196344.
Components for Auto Air Conditioners.
EPA/600/S-92/009. NTIS PB92-217272.
Aluminum Extrusions. EPA/600/S-92/010. NTIS
PB92-192137.
Galvanized Steel Parts. EPA/600/S-92/011. NTIS
PB92-189695.
Commercial Ice Machines and Storage Bins.
EPA/600/S-92/012. NTIS PB92-196351.
Water Analysis Instrumentation. EPA/600/S-92/013.
NTIS PB92-217280.
Can Manufacturing Equipment. EPA/600/S-92/014.
NTIS PB92-196385.
Metal Bands/Clamps/Retainers/and Tooling.
EPA/600/S-92/015. NTIS PB92-188747.
Permanent-Magnet DC Electric Motors.
EPA/600/S-92/016. NTIS PB92-196369.
Military Furniture. EPA/600/S-92/017. NTIS
PB92-217256.
Aluminum Extrusions Manufacturer.
EPA/600/S-92/018. NTIS PB92-196393.
Metal-Plated Display Racks. EPA/600/S-92/019. NTIS
PB92-189703.
45
-------
Motor Vehicle Exterior Mirrors. EPA/600/S-92/020.
NTIS PB92-192806.
Sheet Metal Cabinets and Precision Parts.
EPA/600/S-92/021. NTIS PB92-196377.
Treated Wood Products. EPA/600/S-92/022. NTIS
PB92-196401.
Industrial Coatings. EPA/600/S-92/028. NTIS
PB93-123073.
Cutting and Welding Equipment. EPA/600/S-92/029.
NTIS PB93-123065.
Finished Metal Components. EPA/600/S-92/030.
NTIS PB93-123057.
Machined Parts. EPA/600/S-92/031. NTIS
PB93-123040.
Injection-Molded Car and Truck Mirrors.
EPA/600/S-92/032. NTIS PB93-123032.
Printed Circuit Boards. EPA/600/S-92/033. NTIS
PB93-126621.
Custom Molded Plastic Parts. EPA/600/S-92/034.
NTIS PB93-123024.
Sheet Metal Components. EPA/600/S-92/035. NTIS
PB93-123016.
Silicon-Controlled and Schottky Rectifiers.
EPA/600/S-92/036. NTIS PB93-123099.
Penny Blanks and Zinc Products. EPA/600/S-92/037.
NTIS PB93-123107.
State and Local Agencies
Brown, S., R. Kessler, and G. Lynch. 1989. Hazardous
Waste Management and Reduction: A Guide for
Small- and Medium-Sized Businesses. San Jose,
CA: City of San Jose.
California Environmental Protection Agency. 1991.
Waste Minimization Assessment Procedures: Module
11. Unit 1: Waste Minimization Assessment
Procedures for the Inspectors with Self-Testing
Exercises. Unit 2: Waste Minimization Assessment
Procedures for the Generator. Sacramento, CA: CA
EPA.
California Environmental Protection Agency. 1991.
Waste Minimization for the Metal Finishing Industry:
Module 111. Sacramento, CA: CA EPA.
California Environmental Protection Agency. 1991.
Waste Minimization for Hazardous Materials
Inspectors: Module 1. Sacramento, CA: CA EPA.
California Environmental Protection Agency. 1990.
Alternative Technologies for the Minimization of
Hazardous Waste. Sacramento, CA: CA EPA.
California Environmental Protection Agency. 1986.
Alternative Technology for Recycling and Treatment
of Hazardous Waste. 3rd Biennial Report.
Sacramento, CA: CA EPA.
California Environmental Protection Agency. 1986.
Guide to Solvent Waste Reduction Alternatives.
Sacramento, CA: CA EPA.
Center for Hazardous Materials Research. 1987.
Hazardous Waste Minimization Manual for Small
Quantity Generators in Pennsylvania. Pittsburgh, PA:
University of Pittsburgh.
Connecticut Technical Assistance Program. 1990. Waste
Minimization and Pollution Prevention: Self-Audit
ManualMetal Finishing. Hartford, CT: CT TAP.
Fromm, C.H. and M.S. Callahan. 1986. "Waste
Reduction Audit Procedure." Conference of the
Hazardous Materials Control Research Institute.
Atlanta, GA: Hazardous Materials Control Research
Institute.
Sherry, S. 1988. Low-Cost Ways to Promote Hazardous
Waste Minimization: A Resource Guide for Local
Governments. Sacramento, CA: Local Government
Commission.
Sherry S. 1988. Minimizing Hazardous Wastes:
Regulatory Options for Local Governments.
Sacramento, CA: Local Government Commission.
Sherry, S. 1988. Reducing Industrial Toxic Waste and
Discharges: The Role of POTWs. Sacramento, CA:
Local Government Commission.
Tennessee Waste Reduction Assistance Program.
1989. Writing a Waste Reduction Plan: Charting Your
Company's Course Towards Better Waste
Management, A How-To Book for Tennessee
Generators. Knoxville, TN: Tennessee Waste
Reduction Assistance Program.
Wigglesworth, D. 1986. Profiting from Waste
Reduction in Your Small Business. Anchorage, AK:
Alaska Health Project.
Waste Exchanges
National Materials Exchange Network
The National Materials Exchange Network (NMEN),
developed by Pacific Materials Exchange under an EPA
grant, is an electronic network of virtually all of the waste
exchanges in North America. Currently, the network has
over 5,000 listings of waste materials available and
46
-------
wanted. The system has 17 categories of wastes and
allows sorting by geographic area.
For more information, call Patrick Moctezuma at
509-325-0507, or write:
National Materials Exchange Network
1522 North Washington, Suite 202
Spokane, WA 99201-5424
For computer modem access, dial: 1-800-858-6625.
Local or Regional Waste Exchanges
Alberta Waste Materials Exchange
Provincial Building, #303A
4920-51 st
Red Deer, AB T4N 6K8
403-297-7505
AR Industrial Development Commission
#1 Capitol Mall
Little Rock, AR 72201
501-682-1370
Arizona Waste Exchange
4725 E. Sunrise Drive
Suite 215
Tucson, AZ 85718
602-299-7716
B.A.R.T.E.R.
2512 Delaware Street, S.E.
Minneapolis, MN 55414
612-627-6811
British Columbia Waste Exchange
102-1525 W. 8th Avenue
Vancouver, BC V6J 1T5
604-731-7222
Bureau of Solid Waste Management
P.O. Box 7921
Madison, Wl 53707
608-267-3763
California Waste Exchange
California Environmental Protection Agency
Department of Toxic Substance Control
Alternative Technology Division
P.O. Box 806
Sacramento, CA 95812-0806
916-322-4742
CALMAX
909 - 12th Street, Suite 205
Sacramento, CA 95814
916-255-2369
Canadian Chemical Exchange
P.O. Box 1135
Ste-Adele, ABJOR1LO
514-229-6511
Canadian Waste Materials Exchange
2395 Speakman Drive
Mississauga, ON L5K 1B3
416-822-4111
Department of Environmental Protection
18 Riley Road
Frankfort, KY 40601
502-564-6761
Great Lakes Regional Waste Exchange
470 Market Street, NW.
Grand Rapids, Ml 49503
616-451-8922
Hawaii Waste Exchange
Maui Recycling Group ;
P.O. Box 1048
Paia, HI 96779
808-579-9109
IMEX
17220th Avenue
Seattle, WA 98122
206-296-4899
Industrial Materials Exchange Service
P.O. Box 19276
2200 Churchill Road, #31
Springfield, IL 62794-9276
217-782-0450
Iowa Waste Reduction Center
75 BRC-University of Northern Iowa
Cedar Falls, IA 50614-0185
319-273-2079
Louisiana/Gulf Coast Waste Exchange
1419 CEBA
Baton Rouge, LA 70803
504-388-4594
Manitoba Waste Exchange
1329 Niakwa Road
Winnipeg, MB R2J 3T4
204-257-3891
Missouri Environmental Improvement Authority
325 Jefferson Street
Jefferson City, MO 65101
314-751-4919
MISSTAP
P.O. Drawer CN
Mississippi State, MS 39762
601-325-8454
MN Technical Assistance Program
1313 5th Street, Suite 307
Minneapolis, MN 55414
612-627-4555
47
-------
Montana Industrial Waste Exchange
Montana Chamber of Commerce
P.O. Box 1730
Helena, MT 59624
406-442-2405
Northeast Industrial Waste Exchange
90 Presidential Plaza, Suite 122
Syracuse, NY 13202
315-422-6572
OK Waste Exchange Program
P.O. Box 53551
Oklahoma City, OK 73152
405-271-5338
Ontario Waste Exchange
2395 Speakman Drive
Mississauga, ON L5K 1B3
416-822-4111
Pacific Materials Exchange
1522 N. Washington, Suite 202
Spokane, WA 99205
509-325-0551
Portland Chemical Consortium
P.O. Box 751
Portland, OR 97207-0751
503-725-3811
RENEW
Texas Water Commission
P.O. Box 13087
Austin, TX 78711-3087
512-463-7773
SEMREX
171 W. 3rd Street
Winona, MN 55987
507-457-6460
Southeast Waste Exchange
Urban Institute, UNCC Station
Charlotte, NC 28223
704-547-2307
Southern Waste Information Exchange
P.O. Box 960
Tallahassee, FL 32302
800-441-SWIX
48
-------
Appendix B
Pollution Prevention Summaries On Specific Industries
This chapter is a collection of summaries regarding the
processes, waste streams, and potential pollution
prevention opportunities for specific industries of
concern to PQTWs. The summaries contain a brief
description of the processes and waste streams
associated with the industry, along with a description of
pollution prevention measures that may be applicable.
Also, the summaries include a case study example, if
available, of a firm's experience with pollution
prevention efforts. Sources of further information are
provided at the end of each summary.
The summaries are formatted so that POTW personnel
can extract and copy specific summaries of interest for
their own use or for their users' information.
Summaries are provided for the following industries:
Automotive-Related Industry ........... 50
Commercial Printing 53
Fabricated Metal Products 56
Industrial and Commercial Laundries 61
Paint Manufacturing . 63
Pesticide Formulation 66
Pharmaceuticals Manufacturing . . 69
Photoprocessing 72
Printed Circuit Board Manufacturing ....... 75
Selected Hospital Waste Streams '. . 79
EPA/625/R-93/006
49
Guides to Pollution Prevention
-------
Pollution Prevention Summary:
Automotive-Related Industry
Process Description
The automotive-related industry includes facilities that
perform mechanical repairs, maintenance, collision and
body repair, and painting of automotive vehicles. The
industry includes commercial repair and body shops,
new car dealerships, fleet operators, and diesel engine
repair shops. As part of the general maintenance of
automobiles, these shops replace motor oil, coolants,
transmission fluid, and brake fluid. If improperly
disposed of, these materials can create problems for
POTWs. Automotive refinishing operations use
thinners, paints, fillers, and catalysts to prepare, prime,
and refinish automotive surfaces. During the course of
repairing and replacing automotive parts, a variety of
solvents, cleaners, and degreasers are used to clean
tools, equipment, and parts.
Waste Streams
Automotive shops are the leading small-quantity
generators of hazardous wastes based on both volumes
generated and the number of such operations. Table
B-1 provides a brief summary of the pollutants that may
be generated in automotive shops. The replacement
of automotive fluids represents the largest
waste-generating activity in the industry. These fluids
must be disposed of properly or recycled professionally,
since spills and mismanagement can lead to potential
discharges to sewer systems. Automotive shops utilize
various solvents for parts cleaning, paint thinning, and
degreasing, resulting in spent solvents and residuals.
Caustic floor cleaners and clarifiers are used to clean
shop floors. When the floors are washed with water,
these cleaners, along with particulate matter, such as
asbestos dust from brake shoes, body filler dust, and
metal filings, may wash down drains. Painting
operations also generate large volumes of liquid waste,
including thinners, unused paints, and residues. Other
waste streams include miscellaneous fluids, such as
hydraulic and lubricating fluids used in body repair
machinery and shop lifts. The hazardous liquids
generated in this industry are generally stored in drums
on site until they can be professionally disposed of or
recycled; however, when improperly managed, these
wastes can find their way down sinks, floor drains, and
storm sewers.
Pollution Prevention Options
Good Operating Practices
Numerous pollution prevention options are available to
automotive shop owners. Good operating practices
begin with the proper management of material
inventories. Inventories should ,be maintained on a
"first-in/first-out" basis. This avoids the need to dispose
of materials with expired shelf lives. Inventory controls,
Table B-1. Wastes Generated from Automotive Shops
Process Waste Material Composition
Auto maintenance
Shop cleanup
Parts cleaning
Auto refinishing
Motor oil
Transmission fluid
Engine coolant
Batteries
Brake fluid
Outdated supplies
Acid floor cleaners
Alkaline floor cleaner
Clarrfier sludge
Solvents
Aqueous cleaners
Paint waste
Oil and grease, heavy metals
Oil and grease, heavy metals
Ethylene glycol, lead, copper, zinc
Sulfuric acid, heavy metals
Chlorinated compounds, metals
Solvents, caustic cleaners, automotive fluids
Acids, heavy metals
Caustics, oil and grease, heavy metals
Oil and grease, heavy metals
Petroleum distillates, mineral spirits, naphtha, chlorinated compounds, oil and
grease, heavy metals
Acids and alkali, oil and grease, heavy metals, blended heavy oils, heavy
metals
Petroleum distillates, heavy metals
Guides to Pollution Prevention
50
EPA/625/R-93/006
-------
such as requiring employees to return empty fluid
containers before obtaining new supplies, can help
minimize the amount of supplies discarded
unnecessarily. Maintaining a computerized inventory
system can help minimize the quantity of hazardous
materials kept in storage arid help prevent expired shelf
lives. Inventories should be inspected periodically to
ensure that spills or leaks are not occurring. When
materials are purchased, the shop operator should
purchase materials that can be recycled (e.g., avoid
transmission and brake fluids that contain chlorinated
hydrocarbons if another type is satisfactory) and work
with suppliers that may offer collection and recycling
services.
Maintaining good operating practices or good
housekeeping measures also can prevent the discharge
of hazardous materials to the sewer system. Some
specific techniques include:
Provide employee training and incentives to increase
awareness of the need for and benefits of pollution
prevention.
Post signs at sinks and drains to prevent the improper
discharge of oils, solvents, and other fluids.
Use drip pans whenever there is a potential for fluids
to leak from vehicles. These pans should not be left
unattended. Instead, the fluids should be promptly
transferred to appropriate storage containers.
Store waste materials in a segregated area,
preferably within a bermed or diked enclosure.
Use self-closing faucets on material containers and
waste collection tanks.
Clean up leaks, drips, and other spills promptly,
preferably without the use of water. Use rags for small
spills, a damp mop for general cleanup, and dry
absorbent materials for larger spills. Clean up all
spills before they reach drains.
Reuse or recycle fluids wherever possible. For
instance, fluids used to flush cooling systems can
often be reused. Similarly, spent antifreeze and motor
oils can usually be recycled through the supplier or
a fluid recycling firm.
To prevent the discharge of particulate matter, such
as asbestos dust, metal filings, body filler, or dust
from abrasives, use a dry cleanup method to prevent
washing the materials down a drain.
Minimize Solvent Use
The use of solvents is prevalent in this industry.
Operators can take various low-cost steps to minimize
the quantities of solvents that are wasted or discarded.
The major approaches to limiting solvent waste include
the following:
Eliminate the need for solvents (e.g., determine
whether a particular part truly requires cleaning or at
least use a mechanical cleaning technique, such as
a wire brush, to limit the quantity of solvent needed).
Find aqueous-based or less-toxic alternatives (e.g.,
terpene cleaners can replace standard halogenated
solvents for many applications; alternative carburetor
cleaners are available as a substitute for 1,1,1-
trichloroethane [TCA]; detergent-based cleaners can
be substituted for more hazardous caustic-based
cleaners; use water-based solvents wherever
possible; avoid halogenated compounds,
petroleum-based cleaners, and cleaners with
phenols).
Minimize losses associated with solvent use (e.g.,
avoid disposing of solvents prematurely, utilize
employee training to prevent spills, operate solvent
sinks properly).
Segregate, recycle, recover, and reuse waste
solvents.
Efforts also can be taken to minimize the amount of
thinner and paint used in the refinishing process.
Ensuring that employees are properly trained at
applying automotive finishes can minimize waste
generation and reduce material costs. When cleaning
painting equipment, paint residues should be scraped
off mechanically before using solvents. Additionally,
Teflon-coated paint cups are available, which allow for
more effective manual cleaning and reduced solvent
usage.
Automotive shops can contract with outside companies
to recover spent fluids or invest in onsite recycling
equipment for both recovering solvents and reclaiming
antifreeze. Highly efficient parts washers and
degreasers that minimize solvent use also are available.
Oil and grease traps can be installed in storm and floor
drains to prevent discharge of oil and grease to the
sewer. These systems remove the bulk of floating oily
wastes. Shop operators can install roofs over fueling or
outdoor work areas to keep storm water away from
potentially contaminated surfaces. The downspout
should be routed directly to the storm drain to prevent
runoff from contacting surrounding areas.
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA/625/R-93/006
51
Guides to Pollution Prevention
-------
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
U.S. EPA. 1991. U.S. Environmental Protection Agency.
Guides to pollution prevention: The automotive repair
industry (EPA/625/7-91/013. NTIS PB91-227975.)
and The automotive refinishing industry
(EPA/625/7-91/016. NTIS PB92-129139.).
The Santa Clara Valley Nonpoint Source Pollution
Control Program, Best Management Practices for
Automotive-Related Industries, 5750 Almaden
Expressway, San Jose, CA, 95118, 408-265-2600
(phone), 408-266-0271 (fax).
Preventing Pollution in the Auto Repair Business. A
pollution prevention manual published under a
cooperative outreach program. Available from the
sources listed below:
American Automobile Association, Public Affairs
1050 Hingham Street
Rockland, MA 02370-1090
1-800-222-8252
Automotive Service Association
P.O. Box 529
Bedford, TX 76095-0929
817-283-6205
National Automobile Dealers Association, Regulatory
Affairs
8400 Westpark Drive
McClean, VA22102
703-821-7040
Guides to Pollution Prevention
52
EPA/625/R-93/006
-------
Pollution Prevention Summary:
Commercial Printing
Process Description
Commercial printing operations print and publish
newspapers, books, periodicals, and other materials. In
printing, ink impressions are transferred to a substrate,
such as paper, wood, fabric, plastic, glass, or metal.
There are many types of printing techniques available,
all of which follow four steps: (1) image processing, (2)
platemaking, (3) printing, and (4) finishing. In image
processing, the artwork or text copy is arranged and
photographed to produce transparencies. If the printing
is to be full color, color separations are made to provide
a single-color image for each color. The processes used
to develop the film with the image are similar to those
used to develop photographs; developers, fixers, and
rinses are used. Chemical reducers and intensifiers
may be used to change the image contrast on the film.
Plates that carry the image to be printed accept ink from
a roller and transfer the ink image to a rubber blanket,
which is then transferred to the paper or other substrate.
Plates can be produced using a variety of techniques.
Photomechanical processes produce plates using
light-sensitive coatings, such as diazo and
photopolymers, that create an etched image on the
plate after exposure to light and processing.
Lithographic printing plates also use coated plate
surfaces that, after photochemical processing, create
an image through ink-receptive and ink-resistant areas
on the plate. Gravure printing uses cylinders that are
machined or chemically etched and plated. Letterpress
and flexography relief plates use light-sensitive coatings
to capture the image and then acid solutions to etch
nonimage areas. Various organic and inorganic
chemicals and materials are used for plates, as coatings
on the plates, and for developing or plating the plates
or cylinders.
The final steps are printing and finishing. In printing, the
image is transferred to the substrate. Finishing involves
the final trimming, folding, collating, binding, laminating,
and embossing operations necessary to complete the
final product.
Waste Streams
Almost 98 percent of the total wastes generated by
commercial printers is waste paper. Wastewater
streams discharged to the sewers, which are the focus
of these summaries, include spent photoprocessing
chemicals that have significant biochemical oxygen
demand and silver concentrations. Platemaking
wastes, such as acids and alkalis used to clean or
develop the plates, must be pretreated before being
discharged to the sewer or must be stored in drums for
disposal. Fountain solutions, used in lithography, either
evaporate during use or remain on the product, and
therefore are not discharged to the sewer. Table B-2 lists
the wastewater generated from printing processes.
Table B-2. Wastewater Generated by Printing Processes
Process Description
Image processing Photographic chemicals, silver
(if not recovered)
Platemaking Acids, alkalis, solvents, plate coatings
(may contain dyes, photopolymers,
binders, resins, pigments, organic acids),
developers (may contain isopropanol,
gum arabic, lacquers, caustics), and
rinsewater
Printing Spent fountain solutions (may contain
chromium)
Pollution Prevention Options
Good Operating Practices
Commercial printers can apply general good operating
practices to prevent pollution, including waste stream
segregation, employee training, inventory control,
efficient production scheduling, and loss prevention
practices. Since many photoprocessing and
plate-developing chemicals are sensitive to temperature
and light, proper storage is essential to prevent spoilage
and to maximize the shelf life of these raw materials.
Inventory control, using the "first-in/first-out" system, will
reduce the possibility of expired chemicals requiring
disposal. Expired raw materials can be tested for
effectiveness before being discarded. Also, restricting'
traffic through storage areas reduces the likelihood of
contamination or spillage of stored materials.
Image Processing
Photographic materials that do not contain silver are
available. Diazo and vesicular films have been used for
many years. These films are made of a polyester base
coated with thermoplastic resin and a light-sensitive
diazonium salt. Diazo and vesicular films are slower to
EPA/625/R-93/006
53
Guides to Pollution Prevention
-------
develop than films containing silver. More recently,
photopolymer and electrostatic films, which do not
contain silver, have been used. Photopolymer films are
composed of carbon black instead of silver and are
processed in weak alkaline solution that is neutralized
before being discharged. Electrostatic films, which are
as fast as silver films and have high resolution, use an
electrostatic charge to make them light sensitive; then
a liquid toner is used to develop the image.
Photoprocessing wastes can be reduced by extending
the life of the fixing baths. This can be accomplished by
adding ammonium thiosulfate (which allows the
concentration of silver buildup in the bath to be
doubled), using an acid stop bath prior to the fixing bath,
and adding acetic acid to the fixing bath as needed to
keep the pH low.
In manual processing systems, squeegees can be used
to reduce the chemical carryover from one process bath
to the other. Countercurrent rinsing systems can replace
parallel tank systems and can reduce substantially the
wastewater generated. Countercurrent systems use
water from the previous rinsings for the initial
film-washing stage rather than fresh water. Fresh water
Is used only at the final rinse stage, after most of the
contamination has been already rinsed away.
Silver recovery techniques, including metallic
replacement and electrolytic recovery, can be used to
remove silver from spent developing and fixing
solutions. Electrolytic recovery units, which are widely
used, use a low-voltage current between a carbon
anode and stainless steel cathode to recover silver from
the spent solutions. Metallic replacement systems use
a cartridge containing steel wool in which an
oxidation-reduction reaction causes the iron in the wool
to replace the silver in solution. The silver settles to the
bottom of the cartridge as a sludge.
Plate Processing
Replacing metal etching or plating processes with
alternative processes can reduce the problems associated
with toxic wastes from these processes. Alternative
techniques include presensitized lithography, using
plastics or photopolymers, and hot metal printing. If
changing tine process is not feasible, a number of
measures can be taken to reduce the toxicity of
wastewater discharges. In addition to the pollution
prevention options discussed here, options related to
metal fabrication may apply to plate-processing
operations, particularly for gravure printing where the
cylinders are chrome plated. The waste solutions from
metal-etching or metal-plating operations and from
rinsing operations usually require treatment before
being discharged to the sewer. To reduce wastewater
generated by rinsing, Countercurrent rinse systems can
be employed. The pollutant concentrations in
wastewater from plating operations can be reduced by
minimizing drag-out from the plating tanks. Examples of
techniques to reduce drag-out include proper
positioning of the part on the draining rack, using drain
boards to collect drag-out and reuse it in the plating
tank, and raising the temperature of the plating bath to
reduce the surface tension of the solution.
Nontoxic developers and finishers are available that can
be substituted for the more traditional materials. Also,
presensitized plates that are water resistant until
exposed to light are available. Commercial printers can
review the product literature to ensure they are using
the most appropriate raw materials for their operation.
Pollution Prevention Successes
The Alaska Health Project conducted a waste
minimization audit at a printing company. In addition to
suggesting changing to an aqueous platemaking
process to reduce hazardous waste generation and
using water-based inks to eliminate spent solvent
generation, the auditors suggested installing silver
recovery to reduce silver concentrations in the
photographic wastewater generated. The capital costs
were estimated at $600 for a silver recovery unit with
an expected payback period of 2 years (PPIC, 1992).
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from: :
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Guides to Pollution Prevention
54
EPA/625/R-93/006
-------
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Guides to pollution prevention: the commercial
printing industry. EPA/625/7-90/008. NTIS
PB91-110023. Washington, DC: Office of Research
and Development.
U.S. EPA. 1986. U.S. Environmental Protection Agency.
Waste minimizationissues and options. Volume
Mil. EPA/530/SW-86/041 through /043. NTIS
PB87-114351.
EPA/625/R-93/006
55
Guides to Pollution Prevention
-------
Pollution Prevention Summary:
Fabricated Metal Products
Process Description
The fabricated metal industry encompasses a wide
variety of processes that machine, treat, coat, plate,
paint, and clean metal parts. These processes can
be broadly classified as (1) cleaning and stripping,
(2) painting and applying other nonmetallic coatings,
(3) machining, and (4) surface treatment and plating.
Cleaning and stripping of metal surfaces is
accomplished by using one or more of four types of
cleaning media: (1) solvents, (2) aqueous cleaners
(alkaline and acid), (3) abrasives, and (4) water. Table
B-3 describes variants of these major cleaning
processes. Cleaning processes are required as part of
all metal fabrication activities. Most metal fabrication
activities also involve the application of paint or some
other nonmetallic coating to provide a final finish
surface. Table B-3 also describes major methods used
for painting metals.
Machining involves the use of various cutting tools that
travel along the surface of the workpiece, shearing
away the metal ahead of it to create a piece of specified
dimensions. Table B-4 describes some major
metal-cutting processes. Metalworking fluids are
commonly applied to the workpiece and cutting tool for
cooling of materials, washing away metal shavings,
protecting the workpiece surface, and giving a good
final surface finish.
Tabla B-3. Metal Fabrication Processes: Cleaning, Stripping, and Painting
Process Description
Cleaning and Stripping
Solvents
Aqueous (alkaline and acid
cleaners)
Abrasive
Water
Paint Application
Spray gun
Containers
Dipping
Othor
Use of halogenated and nonhalogenated solvents to remove oil-based materials. Cold cleaning can be
accomplished by (1) wiping with solvent-soaked rags, (2) soaking in a solvent tank, (3) use of ultrasonic
units in tanks to increase cleaning action, and (4) use of a steam gun stripper for paint removal. Diphase
cleaning methods use a water bath followed by solvent spray. Vapor phase cleaning occurs in the vapor
zone above the liquid solvent.
Use of alkaline and acid solutions in soak tanks to displace oil, old plating and paint (alkaline), rust,
scale, and smut formed from electrocleaning. Constituents of alkaline cleaning solutions include builders
(sodium salts of phosphates, carbonates, silicate, and hydroxides); surfactants (detergents and soaps);
and other possible additives, such as antioxidants, stabilizers, and small amounts of solvents.
Constituents in acidic cleaning solutions may include mineral acids, organic acids, detergents, chelating
agents, and small amounts of solvents. Aqueous solutions also are used in electrocleaning (direct current
electrical cleaning with the workpiece attached to the cathode) and electropolishing (reverse current
cleaning in which workpiece is attached to the anode).
Use of abrasive cleaners, typically aluminum oxide or silicon carbide mixed with an oil- or water-based
binder, to remove rust, oxides, burrs, old plating, and paint. Cleaning action can be accomplished using a
buffing wheel, vibrating tank, tumbling barrel, or centrifugal barrel.
Most of the cleaning processes described above require a water wash, using a soak tank or spray unit,
before and after each operation.
Use of compressed air or high-pressure to atomize paint and produce a fan or circular cone spray
pattern. Electrostatic spray units, which are the most commonly used paint application method, create a
positive charge on atomized paint particles that are attracted to the metal surface, thus reducing
overspray.
Placement of a paint with a large number of small items in a container that is rotated until the correct
point of tackiness is reached, at which time the items are transferred to a wire basket. Tumbling,
barreling, and centrifuging are variants of this process.
Lowering and withdrawal of object into a tank with paint. Commonly used for cylindrical items.
Row coating involves the use of high-pressure sprays to flood the item to be painted and then draining off
excess paint. Roller coating operates by applying paint or coating material to a roller and transporting the
item past the roller using a conveyer belt. Curtain coating uses a vertical flow that separates two conveyer
belts. Items on the conveyor belt pass through the curtain to the conveyer belt on the other side without
coating the conveyer belt. Roller and curtain coating are usually used with relatively flat items.
Guides to Pollution Prevention
56
EPA/625/R-93/006
-------
Metal surface treatment and plating operations include
a large number of treatment processes that involve
modifying the workpiece surface properties to improve
corrosion or abrasion resistance, alter appearance, or
otherwise enhance the utility of the product. Table B-4
describes more than a dozen specific treating and
plating processes grouped in four major categories: (1)
electroplating, (2) chemical and electrochemical
conversion, (3) metallic coatings, and (4) case
hardening.
Waste Streams
Table B-5 identifies five aqueous or liquid waste streams
that may result from metal-cleaning and -stripping
operations. The most likely streams of concern to
POTWs are waste rinsewater and possibly
grease-contaminated water from use of abrasives,
which may ultimately be discharged into sewers. Spent
alkaline and acid cleaning solutions generally require
some treatment before they can be discharged.
Facilities with onsite wastewater treatment often mix
primary rinsewater and alkaline and acid cleaning
solutions before treatment. Waste solvents will
generally be handled as a hazardous waste.
Spent bath solutions from electroplating are high in toxic
heavy metals, such as cadmium and chromium, and
certain electroplating baths have high concentrations of
cyanide. Table B-6 identifies the chemical composition
of 10 common electroplating bath solutions and
provides information: on seven other types of
"metal-plating and -treating wastes. Quench oils and
vent scrubber wastes produce contaminated
wastewater that may be of concern if discharged to
POTWs. Spent electroplating and case-hardening bath
solutions, ion exchange reagents, filter and wastewater
treatment sludges all are likely to contain high
concentrations of toxic pollutants, and are usually
treated as hazardous wastes and not discharged to a
POTW. All machining and metal-plating and -treatment
activities also will generate waste streams from cleaning
and stripping, as described above. Accidental spills are
Table B-4. Metal Fabrication Processes: Machining, Surface Treatment and Plating
Process Description
Machining
Turning
Drilling
Reaming
Milling
Threading
Broaching
Other
Surface Treatment and Plating
Electroplating
Chemical and electrochemical
conversion
Metallic coatings
Case hardening
Use of a lathe to hold and rapidly spin a workpiece against a single-edge cutting tool.
Machines used for making holes. Also may be used for reaming.
Enlarging or finishing of existing holes using a drill or machine using multiple-edge cutting tools.
Use of multiple-edge cutters to fashion unusual or irregular shapes.
Cutting of threads for screws, nuts, and bolts.
Many-toothed cutting tool used to finish holes, of circular, square, or irregular shapes, or external
surfaces such as keyways.
Cutting and shaping, grinding, planing, polishing.
Placement of a workpiece in a solution containing metal ions and use of an electric current with the
workpiece as cathode to cause deposition of ions on the workpiece surface. Typical sequence
involves (1) cleaning and stripping, (2) one or more electroplating baths, and (3) rinsing steps
between and after each of the above operations.
Various bath treatment processes designed to deposit a coating on a metal surface for corrosion
protection or decoration. Specific treatments include (1) phosphating, to form a base of metal
phosphate crystals for final coatings (e.g., paints, lacquers); (2) chromating, to minimize rust
formation and improve paint adhesion; (3) anodizing, to develop a surface oxide film to enhance
corrosion resistance; and (4) passivation, to form protective films through immersion in an acid
solution. ,
Various processes to create a durable, corrosion-resistant protective layer of one metal over a core
metallic material that provides a load-bearing function. Major types of coatings include (1) diffusion
coatings, in which the base metal is brought into contact with the coating metal at elevated
temperatures allowing lattice interdiffusion of the two metals; (2), cladding, application using
mechanical techniques such as high-pressure welding or casting; (3) vapor deposition; and (4)
vacuum coating. Diffusion processes include hot dipping (immersion in molten metal bath),
cementation (high-temperature application of metallic powder), and spraying.
Various processes to produce a hard surface over a softer metal core. Treatments include (1)
carburizing, the diffusion of carbon into a steel surface at high temperatures; (2) nitriding, the
diffusion of nitrogen into a steel surface using a nitrogenous gas or liquid salt bath; (3)
carbonitriding and cyaniding, the diffusion of both carbon and nitrogen into a steel surface; and (4)
heating and quenching, hardening caused by rapid heating and cooling of the metal surface.
EPA/625/R-93/006
57
Guides to Pollution Prevention
-------
Tabfa B-5. Aqueous/Liquid Wastes from Metal Parts Cleaning and Stripping
Waste Description Process Origin
Composition
Waste rinsewater
Abrasives
Spent alkaline solutions
Spent acid solutions
Waste solvent
Equipment cleaning using water and/or caustic
solutions
Removal of rust, scale, polishing of metal
Descaling, removal of organic coatings
Removal of scale, smut (metal contaminants from
electrocleaning)
Cleaning of oily surfaces
Water contaminated with solvent residue, additives,
heavy metals from paint removal (lead, chromium)
Grease-contaminated water
Water contaminated with alkaline salts, additives,
organic material3
Water contaminated with acids, dissolved metal,
additives'5
Halogenated and nonhalogenated solvents,
oil-based contaminants0
* Commonly used chemicals in alkaline solutions include ammonium hydroxide, potassium hydroxide, and sodium hydroxide, ,
Commonly used chemicals in acid solutions include hydrobromic acid, hydrochloric acid, hydrofluoric acid, nitric acid, phosphoric acid, sulfuric
acid, perchloric acid, acetic acid.
0 Commonly used solvents include tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1 -trichloroethane, carbon tetrachloride, trichlo-
rotrilluoroethane, trichlorotrifluoromethane, toluene, methyl ethyl ketone, benzene, chloroform, o-dichlorobenzene, p-dichlorobenzene, ace-
tone, xylene, white spirits, kerosene, and butyl alcohol.
a potential concern if cleanup results in discharge of
concentrated or diluted waste streams into sewers.
Pollution Prevention Options
Pollution prevention techniques can be applied to
reduce waste streams in six areas: metal cleaning and
stripping, metal-plating process solutions, metal-plating
rinsewater, abrasives use, paint application, and
machining operations.
Metal-Cleaning and Stripping
Waste streams from aqueous cleaning solutions can be
reduced by extending the life of solutions through such
means as reducing evaporation losses by use of tank
lids, frequent sludge removal, filtration, and processing
of waste solutions for reuse, such as oil separation.
Substitution with less-toxic alternative aqueous cleaning
solutions may be feasible in some situations. Alternative
dry-cleaning and stripping methods, such as use of
abrasives, may reduce or eliminate the need for
aqueous cleaning solutions. Rinsewater from
metal-cleaning and -stripping operations can be
reduced in four ways: (1) reducing initial input
requirements, (2) reducing makeup requirements, (3)
extending the life of rinsewater, and (4) reusing
rinsewater. Makeup requirements can be reduced
through optimal parts handling (distributing parts on a
rack to allow good cleaning and to minimize pockets,
slowly removing parts from vapor zone, rotating parts to
allow condensed solvent drop-off) and improved
drainage (installing drainboards, drip guards, or drip
bars). Solution life can be extended by precleaning
parts, using air blowers, predipping parts in cold mineral
spirits, frequently removing sludge, and avoiding
cross-contamination of solutions.
Metal-Plating Process Solutions
Because metal-plating process solutions tend to be high
in toxic heavy metals, efforts to reduce the amount or
toxicity of waste solutions are important. There may be
opportunities to substitute processes that create lower
quantities or less-toxic waste streams. For example,
methods for metallic coatings, such as cladding,
diffusion coating, hot dipping, and cementation (see
Table B-4) do not require use of aqueous process
solutions. Also, chemical conversion methods generally
involve less-toxic process solutions. Materials
substitution to reduce the toxicity of process solutions
also may be possible. For example, trivalent chromium
is less toxic than hexavalent chromium. Noncyanide
bath solutions are available for copper and tin
electroplating. A variety of bath controls can be used to
extend the life of process solutions, and a number of
processes are available for recovering metals from
waste bath/process solutions. Bath controls include
installing bath filters, using deionized water for
makeup, keeping racks clean, and reducing
contamination by using high-quality raw materials in
anodes. Materials can be recovered through evaporation,
ion exchange, reverse osmosis, chromium electrodialysis,
or electrolytic recovery/electrowinning.
Metal-Plating Rinsewater
Opportunities for reducing rinse wastewaters fall into
three major categories: (1) drag-out reduction (reducing
contamination of rinsewater by process solution), (2)
improvement of rinsewater system design to reduce
makeup or extend life of rinses (rinse tank design,
multiple rinsing tanks, conductivity measurement to
control rinsewater flow, reactive rinsing, fog nozzles and
Guides to Pollution Prevention
58
EPA/625/R-93/006
-------
Table B-6. Aqueous/Liquid Wastes from Electroplating and Other Surface Treatment Processes
Waste Description Process Origin , Composition
Common Electroplating Bath Compositions ,
Spent bath solutions Brass and bronze ;
Cadmium cyanide
Cadmium fluoroborate
Copper cyanide
Copper fluoroborate
Acid copper sulfate
Copper
Fluoride-modified copper
cyanide
Chromium
, Chromium with fluoride
i- ' catalyst
Other Metal-Plating and Treatment Wastes
Quench oils and quench oil Case hardening
tank cleanup wastes
Spent salt bath (carburizing,
nitriding, cyaniding)
Vent scrubber wastes
Ion exchange reagents
Filter sludges
Wastewater treatment sludge
Spills and leaks
Other case hardening
Vent scrubbing
Demineralization of process
water
Plating and chemical
conversion
Wastewater treatment
Accidental discharge
Copper cyanide, zinc cyanide, sodium cyanide, sodium carbonate,
ammonia, Rochelle salt
Cadmium cyanide, cadmium oxide, sodium cyanide, sodium
hydroxide
Cadmium fluoroborate, fluoroboric acid, boric acid, ammonium
fluoroborate, licorice
Copper cyanide, sodium cyanide, sodium carbonate, sodium
hydroxide, Rochelle salt
Copper fluoroborate, fluoroboric acid
Copper sulfate, sulfuric acid
Copper pyrophosphate, pyrophosphate potassium hydroxide,
ammonia
Copper cyanide, potassium cyanide, potassium fluoride
Chromic acid, sulfuric acid
Chromic acid, sulfate, fluoride
Water contaminated with oils, metal fines, combustion products
Sodium/potassium cyanide and cyariate
Similar to spent bath solution composition (see above)
Brine, hydrochloric acid, sodium hydroxide
Silica, silicides, carbides, ash, plating bath constituents (see above)
Metal hydroxides, sulfides, carbonates
Water contaminated with process/rinse solutions
sprays, automatic flow controls, rinse bath agitation, use
of no-rinse coatings), and (3) reuse of contaminated
rinsewater (secondary rinse as primary rinse or
makeup; countercurrent rinsing; immiscible rinses; use
ion exchange, chromium electrodialysis, electrowinning
to recover metals so contaminated rinses can be
reused; use evaporation or reverse osmosis to
concentrate drag-out for reuse in plating bath).
Abrasives
Source reduction techniques can be applied, such as
use of greaseless or water-based binders, an automatic
liquid spray system for application of abrasive onto
wheel, synthetic abrasives, precleaning of workpiece,
and water-level control to ensure sufficient water during
cleaning. Reusable blast media can be used. Deburring
with organic, ceramic, or steel media may be replaced
with dry abrasive blasting.
Paint Application
Pollution prevention techniques related to paint
applications include process modifications (reducing
empty container wastes, drip reduction, bake oven
temperature, equipment maintenance), overspray
reduction (equipment modifications, operator training),
product substitution (solvent-based coatings with
water-based coatings, radiation [UV] cured coatings,
powder coatings), recycling/reuse of overspray,
container wastes, solvent paint mixtures, and recovery
(distillation, filtration).
Machining Operations
Pollution prevention options related to machining operations
include preventing metalworking fluid contamination (use of
demineralized water makeup; regular gasket, wiper, and
seal maintenance/replacement), use of high-quality
metalworking fluid, optimal fluid selection for particular
need, recycling of metalworking fluid, periodic or
EPA/625/R-93/006
59
Guides to Pollution Prevention
-------
continuous filtration of metalworking fluid, fluid
concentration control, material substitution (soluble
borates for soluble borate lubricants, synthetic fluids,
gas coolant), regular sump and machine cleaning,
standardizing oil types used on machining equipment,
improving equipment scheduling, and establishing
dedicated lines.
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Documents with an EPA document number that begins
with 530 are available from the Resource Conservation
and Recovery Act (RCRA) Hotline. The national toll-free
number is 800-424-9346 or, for the hearing impaired,
TDD 800-553-7672. In the Washington, DC, area, call
703-412-9810. Or write to:
RCRA Information Center
U.S. Environmental Protection Agency
Office of Solid Waste (OS-305)
401 M Street, SW.
Washington, DC 20460
U.S. EPA. 1987. U.S. Environmental Protection
Agency. Meeting hazardous waste requirements
for metal finishers. Seminar publication.
EPA/625/4-87/018. Cincinnati, OH: Center for
Environmental Research Information.
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Guides to pollution prevention: the fabricated
metal industry. Washington, DC: Office of
. Research and Development. EPA/625/7-90/006.
NTIS PB91-110015.
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Does your business produce hazardous waste?
Many small businesses do: metal manufacturing.
Washington, DC: Office of Solid Waste and
Emergency Response. EPA/530/SW-90/027N.
Guides to Pollution Prevention
60
EPA/625/R-93/006
-------
Pollution Prevention Summary:
Industrial and Commercial Laundries
Process Description
Industrial and commercial laundry services process
large volumes of industrial and commercial uniforms
and linens. Many of these businesses also operate
diaper services. Commercial laundering is a multistep
procedure involving sorting, prewashing, washing,
rinsing, drying, pressing, and redistributing. The wash
and rinse stages are of greatest concern to POTWs,
Conventional washing machines, which typically handle
between 300 to 700 pounds per load, are single-load
machines that can perform prewash, wash, and rinse
cycles. These machines generally use between 5 and
6 gallons of water per pound of laundry. Laundry
chemicals are either manually or automatically fed to
the machines during various wash and rinse cycles.
Some industrial and commercial laundries use tunnel
washers instead of conventional washers. Tunnel
washers are composed of various dedicated segments
that perform washing, rinsing, and drying. Washing is
accomplished largely through the action of chemical
additions rather than through agitation. Tunnel washers
consume far less water than conventional washers,
averaging between 1 and 1.25 gallons of water per
pound of laundry. Many tunnel washers are equipped
with countercurrent rinsing and rinsewater recycling
mechanisms.
Most industrial and commercial laundries employ heat
exchangers that preheat incoming makeup water with
the heat from the outgoing wastewater. Heat
exchangers can bring makeup water to within 4 degrees
Fahrenheit of wastewater temperature, which generally
varies between 90°F and 125°F. Launderers typically
use water heated to 140°F to 150°F for washing and
rinsing operations.
Waste Streams
Industrial and commercial laundries use a variety of
powder and liquid chemicals in the wash and rinse cycles,
including alkaline detergents, bacteriostats, chlorine
bleach, sour (phosphoric acid), and fabric softener. A
portion of these chemicals precipitate into
wastewaters. In addition, wastewaters often receive
contaminants from laundry articles such as oil and
grease, petroleum hydrocarbons, zinc, chromium,
copper, nickel, selenium, cadmium, lead, total
suspended solids (TSS), and BOD. Other commonly
found contaminants include ethyl toluene, n-propyl
alcohol, isopropyl alcohol, toluene, xylene, ethylbenzene,
bis(2-ethylhexyl)phthalate, phosphate, and sulfide. The
contaminants found in a given facility's wastewater will in
part depend upon the composition of the facility's
business. For example, diaper services often find elevated
levels of zinc in their wastewater due to the common use
of zinc oxide-based diaper rash creams. On the other
hand, a launderer who primarily serves automotive
maintenance facilities might experience elevated levels of
petrochemicals.
Pollution Prevention Options
Good Operating Practices
Implementing certain BMPs can achieve significant
pollution prevention gains at low cost. These procedural
changes encompass the following areas:
Employee training
Management commitment
Inventory control
Scheduling improvements
Preventive maintenance
Spill and leak prevention
Segregation of rinsewater from other wastewater
Improving Chemical Handling
Poor manual handling of laundry chemicals can lead to
accidental spills or under- or overuse of chemicals.
Underuse of laundry chemicals might result in poorly
cleaned laundry articles that must then be cleaned
again. The overuse of laundry chemicals unnecessarily
increases the volume of chemicals disposed of without
realizing any additional benefits in terms of cleaner
laundry. Optimizing the quantity of laundry chemicals
used per load while minimizing the potential for
accidental spills can be achieved through enhanced
worker training, prepackaged laundry chemicals, or the
use of an automated laundry chemical feed system.
While laundries might incur up-front capital costs to
install an automated system, the savings in terms of
optimal chemical usage and possible reduction in labor
costs might pay for the system in the long run.
EPA/625/R-93/006
61
Guides to Pollution Prevention
-------
Changing Customer Practices
In many cases, contaminants borne by incoming
laundry precipitate into the laundry facility's wastewater,
causing the facility to violate pretreatment standards.
While some contaminants in laundry items might be
endemic to particular business or consumer practices
(e.g., mechanics will inevitably get oil and grease on
their uniforms), the laundry facility, in certain
circumstances, might be able to encourage its
customers to alter their practices to reduce the
presence of certain contaminants in laundry items. For
example, a diaper service might ask its customers to
substitute zinc oxide-based diaper rash creams with
zinc-free alternatives.
Substituting Laundry Chemicals with
Less-Toxic Alternatives
A number of less-toxic laundry cleaners are available,
such as vegetable-based, enzyme-based, and
nonchelating cleaners. Laundries should investigate
these alternative cleaners to see if they are appropriate
substitutes.
Although ozone is a highly toxic and hazardous
material, its use in laundering is considered safe and
can virtually eliminate use of other laundering
chemicals. Ozone is an effective disinfectant and
enhances the effectiveness of chlorine bleach. Leasing
or purchasing an ozonation system can be expensive,
but might pay for itself in terms of reduced chemical
usage and sewer loadings. The major drawbacks of
ozonation systems include the quality of cleaning
achieved by the system and the potential for worker
exposure. Also, because the waters used in an
ozone-based system recirculate, laundry contaminants
might become more concentrated than in conventional
systems. Ozonation cleaning systems have not been
used widely in this country and therefore their
performance has not been evaluated.
Rinsewater Recycling and Reuse
Rinsewater discharged from conventional washing
machines is generally of high enough quality to be
reused for prerinsing or prewashing operations. A
rinsewater reuse system requires segregating
rinsewater from other wastewaters and rerouting it back
to the initial stages of the washing process. Reusing
rinsewater can result in significant savings by reducing
the volume of wastewater discharged, thus reducing
sewer charges, and by reducing the volume of incoming
cold water that must be heated to the requisite washing
temperatures of 140°F to 150°F.
Tunnel washers with countercurrent rinsing and
rinsewater recycling mechanisms also can result in
reduced wastewater discharges. With countercurrent
rinsing, rinsewater flows countercurrent to the washing
operation so that the final rinse is with pure water while
preceding rinses use more contaminated water.
Launderers should be aware that reducing water
consumption without proportionately reducing process
contaminants might increase wastewater contaminant
concentrations, possibly resulting in discharges that
exceed concentration-based limits; however, increased
concentrations can improve wastewater treatment
efficiencies.
For Further Information
Institute of Industrial Laundries
1730 M Street, NW.
Suite 610
Washington, DC 20036
202-296-6744
Pollution Prevention Information Exchange System
(PIES)
c/oSAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
Guides to Pollution Prevention
62
EPA/625/R-93/006
-------
Pollution Prevention Summary:
Paint Manufacturing
Process Description
The major steps involved in the production of
solvent-based and water-based paint, the two main
products of the paint manufacturing industry, can be
broadly grouped into primary dispersion, in which
pigments and other materials are mixed and dispersed,
and let-down, in which final mixing, dilution, filtering, and
packaging occurs. Specific steps in grinding and mixing
operations during primary dispersion differ somewhat
between solvent-based and water-based paints, but
both processes commonly use mills, the design of which
varies depending on the types of pigments being
handled. Single, high-speed mixers that accomplish all
the grinding and mixing operations in a single step, thus
eliminating the need for a mill, are being increasingly
used by the industry.
Solvent-based paints involve the mixing of resins, dry
pigment, pigment extenders, solvents, and plasticizers
to create a paint base or concentrate. Let-down
operations begin with the addition of tints and thinners
to the paint base in an agitated mix tank until a proper
consistency is reached. Water-based paints are
prepared by first mixing water, ammonia, and a
dispersant followed by the addition of dry pigment and
pigment extenders. After mixing and grinding, the
material is transferred to an agitated mix tank at which
time the final ingredients are added in the following
order: (1) resin and plasticizers, (2) preservative and
antifoaming agent, (3) a polyvinyl acetate emulsion, and
(4) water added as a thinner.
Table B-7. Aqueous/Liquid Wastes from Paint Manufacturing
Waste Description Process Origin
Once a batch of solvent-based or water-based paints
reaches the desired consistency, it is filtered to remove
any nondispersed pigment and transferred to a loading
hopper, where the paint is poured into cans, labeled,
packed, and moved to storage.
Waste Streams
Table B-7 identifies six aqueous or liquid waste streams
that can result from paint manufacturing. The main
waste stream of concern to POTWs is contaminated
rinsewater that is discharged to sewers. Major
environmental concerns include solvent residue from
solvent-based paints, ammonia from water-based
paints, and dissolved heavy metals and other toxic
compounds from pigments of both paint types. Waste
solvents will generally be handled as a hazardous
waste. Accidental spills are a potential concern if
cleanup results in discharge of concentrated or diluted
waste streams into sewers. Similarly, paint sludges are
a concern only if any liquids associated with the sludge
are discharged to the sewer. Off-specification products
resulting from poor process control increase waste
loading to the extent that additional batches must be
processed that would not otherwise have been required.
The use of metal mesh filters in place of disposable filter
cartridges is an example of efforts at minimizing solid
waste that may result in increased wastewater flow,
because washing of the reusable filters results in
contaminated rinsewater.
Composition
Waste rinsewater
Waste solvent
Spills
Off-specification products
Paint sludge
Filter cartridges
Equipment cleaning using water and/or caustic
solutions
Equipment cleaning using solvent
Accidental discharge
Color matching (small scale) production, poor
process control
Equipment cleaning, sludges removed from
cleaning solution
Undispersed pigment
Low pH, solvent residue, heavy metals (lead,
chromium)
Solvents,3 oxygen demand
Paint (lead, chromium),1" solvents
Paint (lead, chromium)b
Supernatant wastewater contaminated with paint
pigments, solvents, caustic solutions
If metai mesh filters are used, contaminated
wastewater will be created by cleaning and reuse
aSome solvents used in paint manufacturing include methanol, methyl ethyl
isobutyrate.
About 27 percent of inorganic pigments used in the manufacture of paint are
ketone, toluene, lacquer thinner, mineral spirits, and isobutyl
lead and chrome compounds.
EPA/625/R-93/006
63
Guides to Pollution Prevention
-------
Pollution Prevention Options
The pollution prevention options for paint manufacturing
groups can be divided into four categories: (1) reduction
of cleaning frequency, (2) reduction in the amount of water
used for cleaning, (3) reuse of wastewater from previous
cleaning activities, and (4) spills and area wash-downs.
Reducing Cleaning Frequency
Less-frequent cleaning of equipment during primary
dispersion can be accomplished by modifying operating
procedures to reduce the number of passes through a
mill or by using high-speed mixers that eliminate
multiple passes entirely. Dedicating mixing tanks to a
single formulation, and increasing the length of
production runs when the same tank is used for different
formulations, will reduce the number of times equipment
must be cleaned during let-down. It also may be
possible to sequence paint batches from light to dark to
eliminate cleaning between batches. Dedicating filter
units to formulations can reduce the need for filter
replacement and cleaning.
Reducing Water Used for Cleaning
Immediate cleaning of equipment before paint is
allowed to dry reduces the need for caustic cleaning
solutions. Extending the life of cleaning solutions also
can reduce water requirements. For example, stable
alkaline cleaning formulations may be able to cut
solution replacement frequency in half. Reducing the
amount of clingage and residue to be removed from
mixing tanks will reduce both the degree of
contamination of rinsewater and the amount of water
required to complete the cleaning process. This can be
accomplished using methods such as wiper blades
(manual or mechanical), well-designed drains, and the
use of foams or "plastic pigs" to clean lines. Teflon lined
tanks reduce adhesion and improve drainage and may
be worth considering for small batch tanks that are
amenable to manual cleaning. Automatic wall scrapers
(as opposed to manual wipers or squeegees) may be
more cost effective for large tanks. The amount of
rinsewater can be further reduced by using low-volume,
high-efficiency cleaning equipment, such as steam
cleaners, and high-pressure spray nozzles on hoses.
Wastewater Reuse
Collection of solvent rinses (solvent-based paints) and
water washes (water-based paints) for use in the next
compatible batch of paint can substantially reduce the
amount of liquid waste that is produced from equipment
cleaning. For example, one operation reduced annual
waste solvent production from 25,000 gallons to 400
gallons by using solvent rinses for paint formulation.
Countercurrent rinsing reduces the volume of cleaning
waste by using a recycled "dirty" solution to initially
clean the tank, followed by a recycled "clean" solution
to rinse the "dirty" solution. It also may be possible to
extend the life of cleaning solutions by (1) sludge
dewatering, (2) providing adequate solids settling time
in spent rinse solutions, and (3) using de-emulsifiers in
rinsewater to promote emulsion breakdown and organic
phase separation. Cleaning wastes can be treated for
reuse on site (distillation to recover/regenerate
solvents) or off site (commercial recyclers) or may be
sold to another firm for use in its process (waste
exchange service).
Spills and Area Wash-Downs
Several possible options may be available for reducing
the amount of wastewater resulting from cleanup of
spills and area wash-downs. The use of dry absorbents
to soak up liquids will reduce the degree of
contamination of rinsewater, but will create a solid
waste. Dedicated mops and squeegees also can be
used to collect more concentrated wastes, reducing the
degree of contamination of rinsewater. The use of
recycled water for initial cleanup will reduce water use,
as will low-volume, high-efficiency cleaning equipment
such as high-pressure spray nozzles. The latter options
will produce a lower volume of wastewater but higher
concentrations of contaminants. (One operation actually
plugged existing floor drains to encourage dry cleanup
methods and discourage excessive use of water.)
Other Process Modifications
Other process modifications include substituting solvents
and other raw material with less-hazardous materials
(no-lead/chromate pigments, non-mercury-based
bactericides); reformulating to reduce process wastes and
cleaning requirements; minimizing evaporative losses;
avoiding off-specification products (quality testing of raw
materials, batch formulation in laboratory before
large-scale production, strict quality control, automated
processing systems, reformulation/blending of off-spec
batches); blending obsolete products/customer returns
into new products; blending/using waste streams to
produce marketable products.
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
Guides to Pollution Prevention
64
EPA/625/R-93/006
-------
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technjcal Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Documents with an EPA document number that begins
with 530 are available from the Resource Conservation
and Recovery Act (RCRA) Hotline. The national toll-free
number is 800-424-9346 or, for the hearing impaired,
TDD 800-553-7672. In the Washington, DC, area, call
703-412-9810. Or write to:
RCRA Information Center
U.S. Environmental Protection Agency
Office of Solid Waste (OS-305)
401 M Street, SW.
Washington, DC 20460
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Guides to pollution prevention: The paint
manufacturing industry. EPA/625/7-90/005. NTIS
PB90-256405. Washington, DC: Office of Research
and Development.
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Does your business produce hazardous waste?
Many small businesses do: formulators. Washington,
DC: Office of Solid Waste and Emergency Response.
EPA/530/SW-90/027P.
EPA/625/R-93/006
65
Guides to Pollution Prevention
-------
Pollution Prevention Summary:
Pesticide Formulation
Process Description
Pesticide formulation involves the mixing of highly
concentrated active ingredients with inert ingredients to
create liquid-based or solid-based pesticides suitable
for handling by mainly agricultural end users. The
process for liquid formulations is relatively simple,
involving the mixing of pesticide concentrate with
solvents, such as xylenes, kerosenes, methyl isobutyl
ketone, amyl acetate, or chlorinated solvents.
Propellants (carbon dioxide, nitrogen) and other
special-purpose ingredients, such as wetting- and
dispersing agents, masking agents, deodorants, and
emulsifiers, also may be added. The mixed product is
then filtered before being packaged in drums or glass
containers.
Dry pesticides are formulated by mixing the
concentrate with inert ingredients such as organic
flours, sulfur, silicon oxide, lime, gypsum, talc, or clay
minerals/materials (pyrophyllite, bentonite, kaolin,
attapulgite, volcanic ash). Various crushing, pulverizing,
grinding, and blending steps may be involved before
final packaging in drums or paper bags for distribution.
Waste Streams
Table B-8 identifies seven aqueous or liquid waste
streams associated with the formulation of pesticides. Dry
pesticides typically generate only pesticide-contaminated
wastewaters, whereas liquid pesticides generate
both pesticide-contaminated and solvent-contaminated
wastewaters. The main waste streams of concern to
POTWs are (1) contaminated rinsewater from cleaning
processing equipment, (2) laundry wastewater from
washing protective clothing, (3) scrubber water from air
pollution equipment used to control dusts associated
with dry formulation, and (4) contaminated storm-water
runoff from outdoor spills or deposition of dust from
open processing areas (if runoff enters the sewer
system). Major environmental concerns include the
toxicity of pesticide residues in the wastewater and
solvent residues from liquid formulations. Most waste
streams associated with pesticide formulation, including
waste solvents, are classified as hazardous and
consequently are not likely to be discharged to sewers
without treatment. Accidental spills are a potential
concern if cleanup results in discharge of concentrated
or dilute waste streams into sewers. Off-specification
products resulting from poor process controls increase
wastewater loading to the extent that additional batches
must be processed that would not otherwise have been
required.
Pollution Prevention Options
The fact that most waste streams resulting from
pesticide formulation are classified as hazardous
creates a strong incentive to minimize the quantity of all
waste streams, and it is fortunate that there are many
opportunities for accomplishing this. Most of these
opportunities fall into five general categories: (1)
process modifications, (2) reduction of cleaning
Table B-8. Aqueous/Liquid Wastes from Pesticide Formulation
Waste Description Process Origin
Composition
Waste rinsewater
Laundry wastewater
Scrubber water from air
pollution equipment
Storm-water runoff
Waste solvent
Spills
Off-specification products and
laboratory analysis wastes
Equipment cleaning, area wash-down, hot water
bath for leak checking
Washing of protective clothing
Unloading of dry pesticides into blending tanks
Pesticide spillage and fallout of pesticide dust in
open process areas
Equipment cleaning
Accidental discharge
Formulating and testing
Pesticide- and solvent-contaminated wastewater*
Pesticide-contaminated wastewater
Pesticide-contaminated wastewater and solvents
Pesticide-contaminated wastewater
Pesticide-contaminated solvents, oxygen demand
Waste pesticide formulations, waste solvents*
Waste pesticide formulations
' Commonly used solvents include methyl alcohol, ethyl alcohol, isopropyl alcohol, toluene, xylene, chloroform, carbon tetrachloride, benzene,
and tetrachloroethylene. Other solvents used in liquid pesticide formulations include kerosene, methyl isobutyl ketone, and amyl acetate.
Guides to Pollution Prevention
66
EPA/625/R-93/006
-------
frequency, (3) reduction in the amount of water used for
cleaning, (4) reuse of wastewater from previous
cleaning activities, and (5) spills and area wash-downs.
Process Modifications
Some process modifications to prevent pollution include
substituting solvents and other raw materials with
less-toxic materials; reformulating to reduce process
wastes and cleaning requirements; using solvent or
water used in formulation to clean the preceding
equipment before adding to the mix tank; avoiding
off-specification products (quality testing of raw
materials, batch formulation in laboratory before
large-scale production, strict quality control, automated
processing systems, reformulation of off-spec batches);
blending/using waste streams to produce marketable
products; and using microscale glassware to reduce
wastes from laboratory tests.
Reduction of Cleaning Frequency
The frequency with which equipment must be cleaned
can be reduced in several ways. Equipment dedicated
to a single formulation greatly reduces requirements for
cleaning. Increasing the length of production runs when
the same equipment is used for different formulations
also will reduce the number of times equipment must
be cleaned. In some situations, it also may be possible
to use sequential formulations that do not require
cleaning between batches.
Reduction in Water Used for Cleaning
A number of options are available for reducing water
used in cleaning. First, reducing the amount of residue
to be removed will both reduce the amount of
contamination of rinsewater and the amount of water
required to complete the cleaning process. This can be
accomplished using methods such as wiper blades
(manual or mechanical), well-designed drains, and the
use of foams or plastic pigs to clean lines. The amount
of rinsewater can be further reduced by using
low-volume, high-efficiency cleaning equipment, such
as steam cleaners, and high-pressure spray nozzles on
hoses. For example, use of steam cleaners instead of
batch-boil cleaning of mixing tanks will dramatically
reduce the amount of water used. If a formulation is
water-based, using the formulation water to clean
equipment before adding it to the mixing tank essentially
eliminates the production of wastewater.
Wastewater Reuse
Various possibilities exist for reusing wastewater during
pesticide formulation. Where multiple rinses are
required to clean equipment, the final rinse can be used
as a prerinse during the next cleaning cycle. It also may
be possible to store rinsewater and use it in subsequent
formulations. For example, the amount of rinsewater
from steam cleaning of equipment used for dry
formulations may be small enough to be injected into
the next batch. Similarly, waste rinsewater may be
suitable to dilute subsequent liquid formulations.
Cleaning wastes can be treated on site for reuse
(regeneration/recovery) or off site by a commercial
solvent recycler or sold to another firm for use in its
process (waste exchange service).
Spills and Area Wash-Downs
Several possible options may be available for reducing
the amount of wastewater resulting in cleanup of spills
and area wash-downs. The use of dry absorbents to
soak up liquids will reduce the degree of contamination
of rinsewater, but will create a solid waste. Dedicated
mops and squeegees also can be used to collect more
concentrated wastes, reducing the degree of
contamination of rinsewater. The use of recycled water
for initial cleanup will reduce water use, as will
low-volume, high-efficiency cleaning equipment such as
high-pressure spray nozzles. The latter options will
produce a lower volume of wastewater but higher
concentrations of contaminants. High-spill areas can be
paved for easier cleaning and spilled materials can be
recovered and used.
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA documents with a number that begins with 600 or
625 can be ordered from ERA'S Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Documents with an EPA document number that begins
with 530 are available from the Resource Conservation
and Recovery Act (RCRA) Hotline. The national toll-free
number is 800-424-9346 or, for the hearing impaired,
EPA/625/R-93/006
67
Guides to Pollution Prevention
-------
TDD 800-553-7672. In the Washington, DC, area, call
703-412-9810. Or write to:
RCRA information Center
U.S. Environmental Protection Agency
Office of Solid Waste (OS-305)
401 M Street, SW.
Washington, DC 20460
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Guides to pollution prevention: the pesticide formulating
industry. Washington, DC: Office of Research and
Development. EPA/625/7-90/004. NTIS
PB90-192790.
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Does your business produce hazardous waste?
Many small businesses do: formulators. Washington,
DC: Office of Solid Waste and Emergency Response.
EPA/530/SW-90/027P.
Guides to Pollution Prevention
68
EPA/625/R-93/006
-------
Pollution Prevention Summary:
Pharmaceuticals Manufacturing
Process Description
Production processes for the manufacture of
Pharmaceuticals can be broadly classified as those
involving (1) chemical synthesis, (2) fermentation, and
(3) natural product extraction (products from natural
materials such as roots, leaves, and animal glands).
Other major types of activity associated with
Pharmaceuticals include research and development
(R&D) in the fields of chemistry, microbiology, and
pharmacology, and formulation of dosage forms, such
as tablets, capsules, liquids, parenterals (injections),
and creams and ointments. R&D activities may result in
significant quantities of toxic aqueous and liquid wastes
being generated. Natural product extraction does not
generally produce wastewaters of major concern and is
not discussed here.
A complex array of batch-type processes and other
technologies are used for manufacturing Pharmaceuticals
and specific input materials, and processes will differ for
each individual product. Chemical synthesis is the most
commonly used method for production of drugs. A
typical manufacturing plant Will have one or more batch
reactor vessels and ancillary equipment for separation
and purification steps to make the desired end product.
Depending on the product, the process may involve a
relatively simple two-step reaction-separation sequence,
or require a complex sequence of separation and
purification steps. A wide variety of chemicals may be
used during chemical synthesis.
Fermentation, a batch process that is typically used to
produce steroids, vitamin B12, and antibiotics, involves
two major steps: (1) inoculum and seed preparation;
and (2) fermentation, where nutrients are provided as a
feedstock for microorganisms from the seed tank to
produce a fermenter broth containing the product of
interest. When fermentation is completed, the crude
product is recovered and purified.
Waste Streams
Table B-9 identifies nine aqueous or liquid waste
streams that may result from Pharmaceuticals
manufacturing. The pharmaceutical industry may
generate a number of waste streams of potential
concern to POTWs. Waste rinsewater and scrubber
water from air pollution equipment may be
contaminated with toxic inorganic and organic
chemicals, depending on the processes involved.
Solvent extraction and other extraction processes
create contaminated spent aqueous solutions that may
be of concern if discharged to a sewer. Spent
fermentation broth generally does not have toxic
contaminants, but typically has high biochemical and
Table B-9. Aqueous/Liquid Wastes from Pharmaceuticals Manufacturing
Waste Description Process Origin
Composition
Waste rinsewater
Scrubber water from air pollution
equipment
Spent aqueous solutions
Spent fermentation broth
Process liquors
Used chemical reagents
Spent solvents
Spills
Off-specification or outdated products
Equipment cleaning, extraction residues
Dust- or hazardous-waste-generating
processes
Solvent extraction processes
Fermentation processes
Organic synthesis
Research and development operations
Solvent extraction or wash practices
Accidental discharge from manufacturing
and laboratory operations
Manufacturing operations
Contaminated water
Contaminated water
Contaminated water*
Oxygen demand, suspended solids
Solvents,* oxygen demand, suspended solids,
high/low pH
Halogenated and non-halogenated solvents,
photographic chemicals, radionuclides, bases,
and oxidizers
Solvents,* oxygen demand
Miscellaneous chemicals of environmental
concern
Miscellaneous products
* Commonly used solvents include acetone, cyclohexane, methylene chloride, ethyl acetate, butyl acetate, methanol, ethanol, isopropanol,
butanol, methyl ethyl ketone, methyl isobutyl ketone, tetrahydrofuran. Other solvents may include benzene, chloroform, carbon tetrachloride,
phenol, toluene, and xylene. ,
EPA/625/R-93/006
69
Guides to Pollution Prevention
-------
chemical oxygen demand (BOD and COD) and total
suspended solids (TSS) levels. Process liquors from
synthesis processes typically have high BOD, COD,
and TSS, with pHs ranging from 1 to 11. Organic and
inorganic chemicals in the process liquors also may be
toxic. Used chemical reagents from pharmaceutical
research and development activities may involve a wide
range of chemicals of potential environmental concern.
Waste solvents will generally be handled as a
hazardous waste. Accidental spills are a potential
concern if cleanup results in discharge of concentrated
or diluted waste streams into sewers. Off-specification
products resulting from poor process controls increase
waste loading to the extent that additional batches must
be processed that would not otherwise have been
required.
Pollution Prevention Options
In general, stringent product specifications and the high
cost of gaining approval to manufacture new
pharmaceutical products limit the potential for waste
reduction compared to many other industries. However,
the great diversity of specific manufacturing processes
and the variety of aqueous and liquid waste streams
mean that a large number of pollution prevention
options are potentially suitable.
Focusing attention on opportunities to improve
management and operating practices is especially
important in pharmaceutical operations because these
can be accomplished without modifying existing
processes. Some opportunities may exist for material
substitution. For example, replacement of organic
solvents with water-based solvents for tablet-coating
operations and use of aqueous-based cleaning
solutions instead of solvent-based solutions have been
successful in reducing solvent waste streams in the
industry.
Opportunities for reducing wastewater from equipment-
cleaning operations will probably yield the greatest
benefits to POTWs. For example, when separate
alkaline and acid waste streams must be neutralized
before being discharged to a POTW, (1) mixing the two
may reduce the amount a new chemicals required to
neutralize the streams separately, and (2) precipitation
reactions may allow removal of dissolved constituents
in the waste before discharge.
Specific pollution prevention opportunities discussed
below are divided into three categories: (1) process
modifications, (2) equipment-cleaning wastes, and (3)
spills and area wash-downs.
Process Modifications
Process modifications that can prevent pollution include
substituting solvent and other raw material with less-
toxic materials; reformulating to reduce process wastes
and cleaning requirements; using solvent or water used
in formulation to clean the preceding equipment before
adding to the mix tank; avoiding off-specification
products (quality testing of raw materials, batch
formulation in laboratory before large-scale production,
strict quality control, automated processing systems,
reformulation of off-spec batches); blending/using
waste streams to produce marketable products; mixing
acid and alkaline waste solutions to reduce
requirements for neutralization reagents; and using
microscale glassware to reduce wastes from laboratory
tests.
Equipment-cleaning Wastes
Equipment cleaning procedures that prevent pollution
include maximizing production runs to reduce cleaning
frequency; using sequential formulations that do not
require cleaning between batches; dedicating
equipment to formulations to reduce the need for
cleaning; reducing clingage and residue to be cleaned
between batches (manual use of wiper blades,
squeegees, mops; mechanical wipers on mix tanks;
rework remainder into products; clean lines using
foam/plastic pigs instead of, or prior to, flushing with
solvent or water; self-draining piping design); using
low-volume, high-efficiency cleaning (new nozzle
heads/higher pump pressures on existing hoses;
high-pressure spray washers; steam cleaners);
substituting aqueous systems for solvents where
possible; collecting and reusing rinsewater and cleaning
wastes (final rinse as prerinse of next cleaning cycle,
reuse for primary cleaning, reuse as part of compatible
formulation); treating cleaning wastes for reuse
(regeneration/recovery of solvents by distillation);
reusing wastes off site (waste exchange services,
commercial brokerage firms); and standardizing
cleaning solvents.
Spills and Area Wash-Downs
Cleaning procedures for spills can be improved by using
dedicated vacuum system (powders), using dry cleanup
methods (dry absorbents), closing floor drains to
encourage dry cleanup methods and discourage
excessive water use, dedicating mops and squeegees
to reduce water hosing for floor washing, using recycled
water for initial cleanup, using high-pressure water knife
spray nozzles on hoses to reduce water used for floor
washing, paving areas where spills frequently occur,
and recovering and using spilled materials.
Guides to Pollution Prevention
70
EPA/625/R-93/006
-------
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
Documents with an EPA document number that begins
with 530 are available from the Resource Conservation
and Recovery Act (RCRA) Hotline. The national toll-free
number is 800-424-9346 or, for the hearing impaired,
TDD 800-553-7672. In the Washington, DC, area, call
703-412-9810. Or write to:
RCRA Information Center
U.S. Environmental Protection Agency
Office of Solid Waste (OS-305)
401 M Street, SW.
Washington, DC 20460
U.S. EPA. 1991. U.S. Environmental Protection Agency.
Guides to pollution prevention: the pharmaceutical
industry. Washington, DC: Office of Research
and Development. EPA/625/7-91/017. NTIS
PB92-100080.
U.S. EPA. 1990. U.S. Environmental Protection
Agency. Does your business produce hazardous
waste? Many small businesses do: formulators.
Washington, DC: Office of Solid Waste and
Emergency Response. EPA/530/SW-90/027P.
EPA/625/R-93/006
71
Guides to Pollution Prevention
-------
Pollution Prevention Summary:
Photoprocessing
Process Description
The photoprocessing industry consists of businesses
that develop and finish photographic film. While the
actual chemistry of photoprocessing is extremely
complex, the process itself is a relatively simple
procedure involving various stages in which film and
paper are submersed for prescribed periods in
developer, bleaches, stop baths/fixers, and stabilizers.
After each stage, the film or paper is thoroughly drained,
washed, rinsed, or dried, depending on the stage of
development and the type of film and processing.
Photoprocessing can be conducted manually for
low-volume processing or with automated systems. The
two systems differ primarily in the means used to
transfer film or paper through the sequence of solutions.
In recent years, color photoprocessing, with a 90 percent
share of the total photoprocessing market, has shifted toward
the use of small automated labs (i.e., 1 -hour processing) with
"washtess" or "plurnbingless" systems that do not use a
conventional wash cycle. Plurnbingless minilabs use a
proprietary chemical stabilizer in place of wash water. While
conventional minilabs discharge 20 to 25 gallons of effluent
per roll of film, these minilabs discharge less than 0.1 gallons
of effluent per roll Although plumbingless minilabs greatly
reduce the volume of effluent, the concentrations of
contaminants are likely to be quite high.
Waste Streams
Photoprocessing produces aqueous effluents
containing toxic constituents from the various solutions
listed in Table B-10. Chemical solutions are generally
combined with spent rinsewater as a single effluent
stream and discharged to an onsite treatment unit and
then to a POTW via the sewer. All aqueous effluents
contain silver, although in different forms and different
concentrations. Table B-10 lists photoprocessing waste
solutions generated.
Pollution Prevention Options
Simple management practices, such as controlling
Inventories, using floating lids to prevent evaporation, and
Improving quality control for all processes have proven
effective in reducing photoprocessing wastes in many
establishments and require only a minimal investment. A
carefully designed inventory system that maintains a
1-month stock of materials and appropriate environmental
controls can prevent needless chemical disposal due to
expiration and damage during storage. Using floating
lids or other means to reduce air space in containers
will prevent evaporation and extend the life of process
chemicals. Other simple quality control measures, such
as inspecting inventory daily for spillage and leaks and
ensuring that process chemicals are mixed only in
quantities sufficient to meet realistic processing
volumes, also will result in significant waste reduction.
Some manual and automated photoprocessing systems
could install squeegees to wipe excess chemical solutions
from film and paper. This reduces chemical carryover from
one process bath to the next, thereby maintaining the
purity of individual process chemicals and enhancing their
"recyclability." Several types of squeegees are available,
including wiper blades, air squeegees, vacuum
squeegees, wringersling squeegees, and rotary-buffer
squeegees. Squeegees should not be used on
rack-and-tank, basket, or drum processors.
Material substitution is a less-viable alternative in most
photoprocessing operations. Alternative materials are
generally unavailable, more expensive, and do not
perform as well. Most operators use established chemical
packages with few options for substituting alternative
Table B-10. Aqueous Wastes Generated from
Photoprocessing
Solution
Composition
Prehardeners, hardeners,
and prebaths
Developers
Stop baths
Ferricyanide bleaches
Oichromate bleaches
Clearing baths
Fixing baths
Neutralizers
Stabilizers
Sound-track fixer or
redeveloper
Monobaths
Organic chemicals,
chromium compounds
Organic chemicals
Organic chemicals
Ferricyanide
Organic chemicals, chromium
compounds
Organic chemicals
Organic chemicals, silver,
thiocyanate, ammonium
compounds, sulfur compounds
Organic chemicals
Phosphate
Organic chemicals, ammonium
compounds
Organic chemicals
Note: In addition, photoprocessing solutions may be acidic or
alkaline.
Guides to Pollution Prevention
72
EPA/625/R-93/006
-------
materials. Photoprocessors, however, should encourage
photochemical manufacturers and suppliers to develop
processes that result in lower-volume and less-toxic wastes.
Silver Recovery
Many photoprocessing operations recover silver from
photoprocessing solutions and rinsewater for sale to
reclaimers. Fixer and bleach-fix will contain between 80 and
100 percent of the recoverable silver from photoprocessing
operations. Photoprocessors most commonly employ metal
replacement, electrolytic recovery, and chemical
precipitation to recover silver from fixer and bleach-fix. Other
methods, such as reverse osmosis (RO), ion exchange, and
evaporation are less common and more suitable for silver
recovery from rinsewaters and washwaters with low silver
concentrations. Metallic replacement and precipitation
require the least investment of silver recovery technologies.
Color Developer Regeneration
Color photoprocessors can regenerate color developer
and reduce replenisher purchases by about 50 percent.
One regeneration process uses an ion-exchange unit to
remove the excess development by-products from the
developer solution. Other available processes include
electrolytic, persulfate, and ozone regeneration; RO;
and precipitation.
Rinsewater Recycling
Photoprocessing requires many rinse cycles, which can
produce large volumes of rinsewater with low
concentrations of process chemicals. Commercial
rinsewater recycling systems that treat and restore
purity to rinsewater for further use are available. These
systems generally add a small amount of incoming
clean water to the recycled rinsewater and discharge an
equivalent amount following the fixer wash.
Countercurrent rinsing also can reduce rinsewater
discharge volume. In this process, rinsewater flows
countercurrent to the photoprocessing operation so that
the final rinse uses pure water and preceding rinses use
contaminated rinsewater. It is recommended that
photoprocessors employing countercurrent rinsing use
squeegees to reduce carryover of contaminants in each
rinse stage. Photoprocessors should be aware that
reducing water consumption is likely to increase
wastewater contaminant concentrations. While
increasing contaminant concentrations may exceed
concentration-based discharge limits, total pollutant
mass discharged will not increase. Also, increased
concentrations, if present, can improve wastewater
treatment efficiencies.
Evaporation
Evaporation of photoprocessing effluents coupled with
silver reclamation and rinsewater recycling also can
minimize waste discharges. Such a system evaporates
photoprocessing effluents and reclaims silver from the
resulting sludge. Complete systems condense and
recycle water vapor during wastewater evaporation.
This "zero discharge" system may require control
technologies to capture volatile organics from the
evaporating wastewaters. Contaminants may remain in
the condensed wastewater, potentially causing
problems for wastewater recycling in photoprocessing
operations. Evaporation systems generally have large
energy requirements.
Pollution Prevention Successes
PCA International, Inc., of Matthews, North Carolina,
recycles photographic processing waste (ultimately
discharged to the sewer) to recover silver and
regenerate spent fixer, developer, and bleach. Silver is
recovered using an electrolytic recovery unit with a
rotating electrode. PCA recovers 2,200 troy ounces of
96 percent pure silver per week from color negative film
fixer solutions and paper fixer solutions. PCA then
aerates de-silvered solutions and returns them to full
strength; 96 percent of the original solution is reused.
PCA regenerates color developer by ion exchange and
reuses 84 percent of the original solution. PCA also
recovers 90 percent of bleach solutions. PCA saves
over $1.1 million each year by recovering and reusing
spent solutions. In 1989, silver recovery added another
$800,000 to these savings (PPIC, 1992).
For Further Information
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
U.S. EPA. 1991. U.S. Environmental Protection Agency.
Guides to pollution prevention: the photoprocessing
industry. Washington, DC: Office of Research and
Development. EPA/625/7-91/012. NTIS PB92-129121.
EPA/625/R-93/006
73
Guides to Pollution Prevention
-------
National Association of Photographic
Manufacturers, Inc.
550 Mamaroneck Avenue
Harrison, NY 10528
914-698-7603
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
Guides to Pollution Prevention
74
EPA/625/R-93/006
-------
Pollution Prevention Summary:
Printed Circuit Board Manufacturing
Process Description
Most printed circuit board manufacturers employ a
series of sequentially ordered mechanical and chemical
processes that selectively deposit copper on a flat sheet
of nonconducting material to create a predetermined
circuit for a given application. A typical nine-stage
manufacturing process is described in Table B-11.
Waste Streams
Printed circuit board manufacturers produce a variety of
rinsewater waste streams generated after scrubbing,
plating, and etching operations (see Table B-12). These
rinsewaters can contain suspended solids, metals,
fluoride, phosphorus, cyanide, and chelating agents.
Low pH values often characterize these waste streams
due to acid cleaning operations. In addition, printed
circuit board manufacturers must control air emissions
from board preparation, acid cleaning, and vapor
degreasing. Manufacturers also must treat acid and
alkaline cleaning solutions and manage spent
chlorinated solvents either through disposal, in-house
recovery, or offsite reclamation.
Pollution Prevention Options
Good Operating Practices
Circuit board manufacturers can use a variety of best
management practices to achieve significant reductions
in toxic waste discharges at relatively low costs. An
important first step at any circuit board manufacturing
establishment is to procure management's commitment
to pollution prevention and provide employee training
and incentives. These management initiatives can
greatly increase employee awareness of pollution
prevention as a company goal. A carefully designed
inventory system that maintains a 1-month stock of
materials and appropriate environmental controls can
prevent needless chemical disposal due to expiration
and damage during storage. Other simple quality
control measures (e.g., inspecting inventory storage
areas daily for spillage and leaks; conducting
preventatiye maintenance; maintaining spill prevention
and emergency response plans; and ensuring that
process chemicals are mixed only in quantities sufficient
to meet realistic processing volumes) also will result in
significant waste reduction.
Table B-11. Nine Stages in
Manufacturing Stage
Printed Circuit Board Manufacturing
Description
Board preparation
Electroless copper plating
Dry film application
Electrolytic copper plating
Electrolytic tin plating
Etching and stripping
Gold tab plating
Solder application
Final processes
Laminated sheets of nonconducting material are cut to size, drilled by programmed high-speed drills, and
debarred at the holes and board edges.
A thin layer of copper is deposited by electroless plating on boards that are first cleaned and rinsed and
then coated with a catalyst for reducing copper.
Circuit pattern is applied by laminating a photosensitive polymer resist, developing with sodium carbonate,
and rinsing with water.
Electrolytic plating of copper occurs on the circuit design developed in the previous stages.
Tin is electrolytically plated over the copper to protect the circuit design from the alkaline etchant used to
strip away the plating resist.
Any copper not protected by the tin is etched away by an alkaline solution. An ammonium bifluoride
hydrogen peroxide solution removes the tin to complete the electronic circuitry on the board. Etched and
stripped board is then water-rinsed and dried.
To meet customer specifications, connectors are sometimes nickel- and gold-plated.
Solder is applied to portions of the boards not coated by an epoxy solder mask.
Finished boards are inspected, labeled, packaged, and stored.
EPA/625/R-93/006
75
Guides to Pollution Prevention
-------
Table B-12. Waste Streams Generated from Circuit Board Manufacturing Processes
Process Waste Stream
Composition
Cleaning/surface preparation
Catalyst application/electroless
plating
Pattern printing/masking
Electroplating
Etching
Airborne partioulates, acid fumes/organic vapors,
spent acid/alkaline solution, spent halogenated
solvents, waste rinsewater
Spent electroless copper bath, spent catalyst
solution, spent acid solution, waste rinsewater
Spent developing solution, spent resist removal ,
solution, spent acid solution, waste rinsewater
Spent plating bath, waste rinsewater
Spent etchant, waste rinsewater
Board materials, sanding materials, metals,
fluoride, acids, halogenated solvents, alkali
Acids, stannic oxide, palladium, complexed
metals, chelating agents
Vinyl polymers, chlorinated hydrocarbons,
organic solvents, alkali
Copper, nickel, tin, lead, gold, fluoride, cyanide,
sulfate
Ammonia, chromium, copper, iron, acids
Rinsing and Cleaning, Surface Preparation
Mechanical cleaning methods offer an alternative to
solvent-based techniques and generate less hazardous
waste. Abrasive blast cleaning uses plastic or ceramic
media to remove oxidation layers, old plating, paint, and
burrs. To prevent damage to the board, abrasive
cleaners must be harder than the layer to be stripped
but softer than the substrate.
Both cleaning agents and rinsewaters can be reused
and recycled. For example, copper sulfate can be
recovered from spent peroxide/sulfuric acid solution,
which is used as a mild etchant and for cleaning copper
and removing oxides prior to plating. The recovered
copper sulfate crystals can then be used in a copper
electroplating makeup bath. Ion exchange recycling
devices can regenerate spent acid baths for reuse.
Countercurrent cleaning arrangements also can reduce
cleaning solution consumption.
Closed loop rinsewater recycling can dramatically
decrease wastewater discharges. Effluent from a rinse
system that follows an acid bath can be reused as
influent water to a rinse system following an alkaline
cleaning bath. This system can actually improve the
efficiency of the rinse system following the alkaline bath.
Using acid-laden rinsewater accelerates the chemical
diffusion process in the alkaline rinse system since the
alkaline material at the interface between the drag-out
film and the surrounding water is reduced by the
neutralization reaction. In addition, the neutralization
reaction reduces the viscosity of the alkaline drag-out
film, thus improving rinse efficiency. Rinsewater reuse
opportunities exist in other areas as well, especially
where rinsing cycles do not require purified rinsewater.
After rinse solutions become too contaminated for use
in any rinse processes, they may be concentrated
through evaporation and returned to process baths as
makeup, providing they contain high enough
concentrations of process chemicals.
Pattern Printing and Masking
A number of alternatives to traditional developing
methods are available to reduce use of toxic developers
and solvents. For example, the use of aqueous
processable resist allows for the use of caustic and
carbonates as developer and stripper in place of
solvents necessary to develop and strip solvent
processable resist. Using screen-printing instead of
photolithography eliminates the need for developers.
While screen-printing has traditionally been used to
produce low-resolution circuit boards, several
companies have recently developed screen-printing
techniques that can provide higher degrees of
resolution.
Spent photoresist stripper can be recycled and reused
by decanting and filtering the solution into a clean tank.
This is feasible because the stripper usually becomes
ineffective as a result of residue buildup as opposed to
a decrease in the chemical strength of the stripper itself.
Reducing Drag-Out from Plating and
Process Baths
Reducing drag-out from plating baths will extend the
useful life of other plating baths as well as reduce metal
and chemical contamination of rinsewaters. Several
factors contribute to drag-out. These include workpiece
size and shape, as well as bath viscosity, chemical
concentration, surface tension, and temperature. Table
B-13 describes drag-out reduction techniques.
Improving Rinse Efficiency
Many techniques are available that can improve the
efficiency of a rinsing system, reduce toxic
contaminants in rinsewater, and reduce the volume of
rinsewater used. Table B-14 lists some of the more
common techniques.
Guides to Pollution Prevention
76
EPA/625/R-93/006
-------
Table B-13. Drag-Out Reduction Techniques
Drag-Out Technique Description
Minimize bath chemical
concentration
Increase bath operating temperature
Use wetting agents
Position workpiece properly on
plating rack
Withdraw boards slowly and allow
for ample drainage
Use drain boards
Use still or dead rinses
Use computerized control systems
Controls drag-out because: (1) reduces the quantity of chemicals and toxicity of any drag-out that
does occur, and (2) greater concentrations of some chemicals in a process solution increases
viscosity.
Lowers viscosity and surface tension of process solution.
Reduces surface tension of process solution.
Facilitates maximum drainage of drag-out back into process bath. Positioning guidelines include:
- Orient surface as close to vertical as possible.
- Orient with longer dimension of piece horizontal.
- Orient with lower edge tilted from the horizontal so that runoff is directed from the corner
rather than the entire edge.
The slower an item is removed from the process bath, the thinner the film on the workpiece
surface and the less the drag-out volume. It is recommended that workpieces drain for a
minimum of 10 seconds.
Capture process chemicals that drip from the workpiece as it is moved from one bath to another
and return it to the original bath.
Avoid need for a continuous flow of feed water. The chemical concentration of the rinse increases
over time to the point where it can be used to replenish the original bath or as makeup for future
batches.
Allows for monitoring of process bath conditions for viscosity and surface-tension increasing
factors and for controlling board withdrawal and drainage.
Table B-14. Rinsing Techniques
Rinsing Technique
Description
Closed circuit or countercurrent
rinsing
Spray rinsing and fog nozzles
Proper equipment design/operation
Conductivity probe or pH meter
Deionized water
Rinsewater flows countercurrent to the electroplating operation so that final rinse is with pure
water and preceding rinses with more contaminated water. The most contaminated rinsewater
can then be used to replenish the original process bath.
When the board is removed from the process bath, it is sprayed over the bath before it is rinsed
in immersion tanks. Much of the drag-out can be removed over the process bath in this manner.
Much less water is needed with a fog nozzle than with conventional spray nozzles.
Rinsewater use can be reduced with the proper monitoring and plumbing design. Various devices
are available to optimize rinsewater flow rates.
Conductivity probes or pH meters can be employed to control the flow of fresh water through
rinse systems. The probe/meter measures the level of dissolved solids or hydrogen ions in the
rinse solution. When this level reaches some preset minimum, the probe/meter activates a valve,
that shuts off the flow of fresh water.
Deionizing water removes natural contaminants from incoming Water and can improve rinse
efficiency and reduce sludge Volume in wastewater treatment systems.
Recovering Metal from Bath Rinses
Recovered metals can be used in two ways: (1)
recovered metal salts can be recirculated back into
process baths, and (2) recovered elemental metals can
be sold to a metals reclaimer. Metal recovery is made
much easier if rinse streams are segregated. Many
metal recovery techniques are available, including
evaporation, reverse osmosis, liquid membranes, ion
exchange, electrolytic recovery, electrodialysis, and high
surface area electrowinning/electrorefining. The method
deemed most appropriate will depend on the facility's
particular economic and technical circumstances.
Etching
Etching processes can result in high chemical
concentrations in rinsewater. Circuit board manufacturers
have achieved reductions in etchant wastes Using the
following techniques:
o Using thinner copper foil to clad laminated boards
reduces the amount of copper that must be etched
away to complete the desired circuit pattern.
« Pattern plating requires copper electroplating only the
holes and circuitry, whereas panel plating
electroplates the entire board* which increases the
amount of copper that must be subsequently etched
away.
EPA/625/R-93/006
77
Guides to Pollution Prevention
-------
Using the additive method as opposed to the
subtractive method to eliminate the need for copper
etching.
Using nonchrome etchants such as ferric chloride or
ammonium sulfide to reduce waste toxicity.
Recycling spent etchants.
Pollution Prevention Successes
Advanced Quick Circuits (AQC) of Melbourne, Florida,
implemented a number of pollution prevention actions
including process modifications, drag-out prevention
techniques, better work habits, and addition of an ion
exchange unit to recover metals from and reuse
rinsewater. Prior to taking these pollution prevention
steps, AQC produced over 300,000 gallons of
wastewater per day. Because of this large volume of
wastewater, the local POTW advised AQC that it would
either have to reduce its wastewater discharges by 20
percent or meet a much lower copper concentration limit
of 0.5 mg/1. After investigating various treatment
options, AQC decided on the above pollution prevention
actions. In a matter of months, AQC had reduced its
wastewater discharges to 114,000 gallons per day with
copper concentrations of only 0.088 mg/l (PPIC, 1992).
Teradyne Connection Systems of Nashua, New
Hampshire, has reduced toxic discharges dramatically
through pollution prevention. After, monitoring
compliance data from the waste treatment effluent with
respect to copper concentration, it became evident that
Teradyne's pretreatment system was incapable of
consistently meeting pretreatment standards for copper.
To reduce the hydraulic loading on the wastewater
treatment system, noncontact cooling water and
scrubbing water were eliminated by installing closed
loop systems. Equipment wash-downs also were
reduced 80 percent by installing automatic shutoffs on
the wash-down hoses and devising and implementing
strict water conservation specifications. In addition, to
reduce the water flow rate supplying the process
equipment, rinsing specifications were determined and
flow restrictors were installed. Electronic controls also
were installed to shut down the water flow to production
equipment when unattended. The facility also installed
an ion exchange/electrolytic system to recover metals
from one of the rinsewater systems.
As a result of these actions, process-water flow rates
were reduced approximately 40 percent. The flow rate
reduction was successful in increasing the effectiveness
of the treatment system, resulting in a copper removal
efficiency of 99 percent. Wastewater generation has
fallen from 346 gallons per minute (gpm) to 106 gpm.
At the same time the quantity of metal hydroxide sludge
generated at the facility has fallen from 410,000 Ib to
101,675 Ib annually (PPIC, 1992).
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/o SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Guides to pollution prevention: the printed circuit
board manufacturing industry. Washington, DC: Office
of Research and Development. EPA/625/7-90/007.
NTIS PB90-256413.
Guides to Pollution Prevention
78
EPA/625/R-93/006
-------
Pollution Prevention Summary:
Selected Hospital Waste Streams
Facility Description
Hospital facilities generate many varied waste streams
from unrelated processes that are ultimately discharged
to the sewer system. POTWs usually grant permission
to discharge noninfectious, nonhazardous wastes. A
general surgical hospital has the following types of
in-house departments: dialysis, pathology, histology,
analytical laboratory, clinical laboratory, respiratory
therapy, autopsy, radiology, housekeeping, engineering,
and facilities management. Many of these departments
produce toxic wastes that are discharged to sewers.
The dialysis department of a hospital can produce
substantial quantities of formaldehyde waste, which is
discharged to the sewer system. Formaldehyde is
generally purchased as a 37 percent formaldehyde in
water solution (formalin) for use in dialysis and is then
diluted with deionized water to obtain a formaldehyde
concentration of 2 to 4 percent. This is pumped into
dialysis machines to disinfect membranes, and the
effluent is discharged to the sewer. The pathology,
histology, laboratory, respiratory therapy, and autopsy
departments generate primarily solvent and
formaldehyde wastes. Solvents are used in tissue
processing, and formaldehyde is used to preserve
specimens that produce small amounts of waste
discharged directly to the sewer.
In general, most full-service hospitals 'have radiology
departments. The photographic developing solutions
used to produce X-rays consist of a fixer and a
developer. The remaining aqueous waste from the fixing
and developing solution used by the X-ray process and
discharged to the sewer after silver recovery consists of
approximately 1.4 percent glutaraldehyde, 0.3 percent
hydroquinone, 0.2 percent potassium hydroxide, and
trace amounts of silver. The housekeeping,
engineering, and facilities management departments of
any hospital will use oxidizers and caustics, usually in
small quantities for cleaning and maintenance.
Waste Streams
General surgical hospitals differ from industrial facilities
in that they produce relatively small volumes of wastes
while producing a wide range of waste streams. The
variety of waste generated is a result of the use of
potentially toxic and hazardous materials in hospital
facilities for numerous diagnostic and treatment
purposes, in addition to using the cleaning and
maintenance chemicals essential for maintaining a
sanitary environment.
Table B-15 lists hospital waste solutions, their source
within the facility, and their constituents.
Pollution Prevention Options
Better operating practices and simple management
practices consist of proven procedures, which can be
implemented at low cost, to reduce waste streams.
These procedures include improved management
oversight, tracking, and inventory control of potentially
toxic chemicals.
Better operating practices include keeping different
waste streams segregated. This ensures hazardous
waste will not contaminate nonhazardous waste,
recyclable waste will be kept separate from
nonrecyclable waste, and toxic chemical waste will be
segregated from infectious wastes. To achieve this
waste segregation, waste containers should be clearly
marked.
Good management and control practices include
centralizing purchasing and dispensing of chemicals;
monitoring chemical flows throughout the hospital from
receipt to disposal; improving inventory control by using
existing stock before ordering new chemicals and
ordering chemicals in limited quantities to prevent waste
due to expired materials; and implementing and
encouraging waste reduction throughout the entire
facility. If chemicals must be purchased in bulk, an
inexpensive way to minimize possible waste generation
due to bad batches is to demand that they be tested in
small quantities to ensure that large amounts of
imperfect chemicals will not require disposal. Recycling
also should be encouraged as much as possible.
Inexpensive waste reduction strategies for
formaldehyde waste include reducing the strength of
formaldehyde solutions, minimizing wastes from
cleaning of dialysis machines and RO units, and
investigating the possibility of reusing waste
formaldehyde in pathology and autopsy laboratories. To
reduce or eliminate solvent wastes, solvents may be
replaced by less-toxic cleaning agents. Photographic
chemical waste can be reduced by ensuring developer
and fixer tanks are adequately covered to reduce
evaporation and oxidation, by using squeegees to
EPA/625/R-93/006
79
Guides to Pollution Prevention
-------
Table B-15. Selected Waste Streams from Hospitals
Waste Description Source of Waste
Composition
Formaldehyde
Solvents
Photographic chemicals
Disinfecting cleaning
solutions
Laundry wastes
Radioactive wastes
Utility wastes
Maintenance wastes
Dialysis, pathology, autopsy
Respiratory therapy and pathology laboratories
X-ray
Scrubbing floors, other applications
Laundry
Clinical chemistry, nuclear medicine
Heating and cooling
Maintenance
Waste discharged to sewer contains between 4 and 10
percent formaldehyde
Alcohol, acetone, xylene, residual heavy metals
Fixer and developer solutions. Aqueous waste contains
glutaraldehyde, hydroquinone, silver, and potassium
hydroxide
Phenolic compounds, zinc, copper
Phosphorus-based detergents, chemicals
Radioactive isotopes
Boiler/cooling tower feedwater treatment residuals (resin
regeneration brine, spent resin), boiler/cooling tower
cleaning wastes
Oils, cleaning solvents, paint stripping wastes, leftover
paints, painting accessories, and incinerator residuals
reduce chemical carryover from one solution bath to the
next, and by recycling waste film and paper.
Another highly effective, low-cost approach to reducing
waste entering the sewer system is to conduct a
facility-wide analysis of all floor drains to determine if
they are necessary, and then seal drains deemed
unnecessary or drains where the potential for slug
loading is high. All necessary drains should be beveled
or bermed to prevent accidental spills from entering the
sewer system.
Silver Recovery
The wastewaters from photoprocessing contain silver
that can be recovered at a reasonable cost. Methods
for recovering silver include metallic replacement,
chemical precipitation, and electrolytic recovery. Silver
recovery equipment is available for even the smallest
generator. Metallic replacement is the most widely used
silver recovery process employed by hospital facilities
and is the least expensive of the available silver
recovery technologies. Recovered silver is worth
approximately 80 percent of its market value. One
advantage of using silver reclaimers on photoprocessors
at a hospital rather than having wastewater processed by
an outside company is that this eliminates the need for
onsite storage of chemical waste and so reduces the risk
of accidental spillage.
Choice of Clinical Chemistry Analyzer
Some clinical chemistry analyzers used in hospital
laboratories produce large quantities of liquid chemical
waste. This waste is usually diluted with large quantities
of water and then discharged to the sewer system.
However, clinical chemistry analyzers exist that produce
no toxic liquid chemical wastes and so eliminate these
discharges. This kind of chemistry analyzer uses
nontoxic liquid solutions, and the resulting chemical
waste may be disposed of at commercial biomedical
waste-handling facilities.
Install RO Water Supply Equipment
Formaldehyde waste is generated primarily through the
cleaning of dialysis equipment. The use of RO units
reduces the number of times dialysis equipment must
be cleaned and so reduces the resulting waste stream.
In addition, RO machines, although usually cleaned with
formalin, may be cleaned with hydrogen peroxide,
which is less persistent in the environment.
Recycling Solvents
Recovery of waste solvents may be feasible using
onsite distillation equipment. Separating different
chemical waste streams enhances the feasibility of
recycling solvents, because this allows the use of
less-expensive, simple batch distillation equipment
rather than fractional distillation equipment. Solvent
recycling systems are available that suit the specific
needs of hospitals. One such unit consists of a fractional
distillation system equipped with a microprocessor to
automatically distill, fractionate, and purify a solvent.
Pollution Prevention Successes
St. Mary's Regional Medical Center in South Portland,
Maine, has derived many environmental and economic
benefits from implementing a pollution prevention and
waste reduction policy. St. Mary's housekeeping
department adopted a new disinfecting floor tool, to
replace conventional wet mops, buckets, and wringers,
that produces virtually no waste. All of the cleaning
solutions prepared are used and there are no spent
Guides to Pollution Prevention
80
EPA/625/R-93/006
-------
solutions to discharge to the sewer system. The result
of using this cleaning device has been a 75 percent
reduction in chemical usage in the housekeeping
department, and an estimated savings in labor costs of
25 percent. Additionally, the cost and volume associated
with laundering the new floor tools is one fifth of that
associated with laundering conventional wet mops.
St. Mary's laundry department has relocated bulk
chemical storage to a section of the hospital with no
floor drains, to reduce slug loading potential, and has
switched chemical vendors, chemicals, and procedures
on chemical usage to help reduce pH levels in its
wastewater. These efforts have been successful given
that pH levels now average between 8.5 and 8.7,
whereas they had been consistently over 10.5. In
addition, this facility has changed its clinical chemistry
analyzer with a resultant 100 percent reduction in liquid
chemical waste discharged to the sanitary sewer
system. The original chemistry analyzer generated 20
gallons of liquid chemical waste on a weekly basis,
whereas the replacement does not generate any.
A 1988 study of a San Francisco Bay Area hospital
commissioned by the California Department of Health
Services (Calif. DHS, 1988) discovered the following
pollution prevention measures had been implemented
at that facility. Hazardous materials are procured in two
central areasthe materials management department
and the pharmacyand the hospital uses a
computerized inventory system to track the use and
disposal of these compounds throughout the hospital. A
product evaluation committee was established to review
product toxicity and investigate the potential for using
less-toxic substances in the hospital. The review
resulted in the substitution of disinfectants containing
glutaraldehyde with an alcohol compound formulated in
a nonflammable water mixture. The facility has
developed a unique approach for disposing of obsolete
or expired supplies. Any drugs that are unusable
because their potency limit is below that required by
U.S. law, but that still have a high degree of potency,
are shipped to Third World countries where such drugs
are scarce. Finally, laboratory waste quantities have
decreased due to recent automation of equipment and
reduction in the quantity of analytes and reagents used
for analysis. The laboratory also has taken steps to
completely eliminate highly toxic chemicals. These
steps include substituting xylene for benzene and
eliminating the use of ether completely.
For Further Information
Pollution Prevention Information Exchange System
(PIES)
c/6 SAIC
7600-A Leesburg Pike
Falls Church, VA 22043
703-821-4800
EPA documents with a number that begins with 600 or
625 can be ordered from EPA's Office of Research and
Development:
Center for Environmental Research Information
Document Distribution Section (G-72)
26 West Martin Luther King Drive
Cincinnati, OH 45268
513-569-7562 (phone)
513-569-7566 (fax)
When an NTIS number is cited in a reference, that
document is available from:
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
703-487-4650
U.S. EPA. 1990. U.S. Environmental Protection Agency.
Guides to pollution prevention: selected hospital
waste streams. Risk Reduction Engineering
Laboratory, Center for Environmental Research
Information. EPA/625/7-90/009. NTIS PB90-256421.
U.S. EPA. 1986. U.S. Environmental Protection Agency.
Report to Congress: waste minimization, vols. I and
II. EPA/530/SW-86/033 and /034. NTIS PB-87114328.
Washington, DC. Available from the National
Technical Information Service as a five-volume set.
U.S. EPA. 1986. U.S. Environmental Protection Agency.
Waste minimization: issues and options, vols. Mil.
EPA/530/SW-86/041 through 7043. NTIS PB-87114328.
Washington, DC. Available from the National
Technical Information Service as a five-volume set.
EPA/625/R-93/006 81
iVuS. GOVERNMENT PRINTING OFFICE: lift - 750-OO1/41018
Guides to Pollution Prevention
-------
-------
-------
-------
m
TO
10
w
to
«;?§ Q£[nc:.
°ti; Jill
^ O = ro
M 5 5? w
0>
o ca
CD
CD 3
0) O
_
"
111
I'!
» 8 s
R5*
85^
3 »S
CD g -^
-gl
9 a.
3|
g.S
ID O
9-O
S^
co X
5-m
fS
"n
if?
TJ
m
33
I
CO
-------
------- |