POLLUTION PREVENTION
AND
WASTE MINIMIZATION
OPPORTUNITIES
FOR THE
MINING INDUSTRY
Prepared for:
HAZARDOUS WASTE MINIMIZATION PROGRAM
HAZARDOUS WASTE MANAGEMENT DIVISION
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Region VZZT
Prepared by:
FRONT RANGE COMMUNITY COLLEGE
HAZARDOUS MATERIALS PROGRAM
3645 West 112th Avenue
Westminster, Colorado 80030
October 1, 1993
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 BACKGROUND 1
1.2 OBJECTIVES 1
2iO WASTE MINIMIZATION 2
2.1 BACKGROUND 2
2.2 WASTE MINIMIZATION TECHNIQUES 3
2.2.1 INVENTORY CONTROLS 3
2.2.2 IMPROVED HOUSEKEEPING 4
2.2.3 PRODUCTION/PROCESS MODIFICATIONS 4
2,2.4 PRODUCT SUBSTITUTION 4
2.2.5 WASTE SEGREGATION 5
2.2.6. NEW USES 5
2 .3 WASTE MINIMIZATION ASSESSMENTS . 5
2.3.1 PLANNING AND ORGANIZATION 5
2.3.2 ASSESSMENT PHASE . 5
2.3.3 FEASIBILITY ANALYSIS * 8
2.3.4 IMPLEMENTATION 9
3.0 MINING WASTE "PROFILE 10
3 .1 WASTE WATER 11
3.1.1 WASTE WATER GENERATION 11
3.1.2 WASTE WATER TREATMENT 11
3.2 SPENT PARTS CLEANING SOLVENTS 12
3.2.1 PARTS CLEANING WITH SOLVENTS 12
3.2.2 CONTACT SOLVENTS * 12
3.2.3 WIPE DOWN OR FIELD SOLVENTS 12
3.3 LUBRICATION GREASES 13
3.3.1 MOBILE VEHICLES 13
3.3.2 SHOVELS AND DRAGLINES * 14
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Page
3.4 SPENT VEHICLE FLUIDS AND ACCESSORIES 17
3.4.1 USED OIL 17
3.4.2 WASTE FILTERS 17
3.4.3 TRANSMISSION AND HYDRAULIC FLUIDS 18
3.4.4 ANTIFREEZE 18
3.4.5 BATTERIES 18
3.4.6 FREON 18
3.5 SHOP AND VEHICLE CLEAN-UP WASTE 18
3.6 SOLID WASTES 20
3.6.1 SCRAP METAL 20
3.6.2 TIRES 20
3.6.3 SHOVEL AND DRAGLINE CABLE 20
3.6.4 RAGS 20
3.6.5 PAPER 20
3.6.6 WOODEN SPOOLS 20
3.7 PAINTS, PAINT STRIPPERS AND THINNERS 21
3.7.1 PAINTS '. 21
3.7.2 PAINT STRIPPERS AND THINNERS 21
4.0 WASTE MINIMIZATION OPTIONS 23
4 .1 WASTE WATER 23
4.1.1 WASTE MINIMIZATION DURING FLOOR WASHING .. 23
4.1.2 WASTE WATER REUSE 24
4.2 SPENT PARTS CLEANING SOLVENTS 24
4.2.1 PRODUCT SUBSTITUTION . 24
4.2.2 TECHNOLOGY SUBSTITUTION 25
4.2.3 RECYCLING AND REUSE 26
4.2.4 STAGED CLEANING 26
4.2.5 QUALITY STANDARDS 26
4.2.6 ON-SITE DISTILLATION 26
4.2.7 PRODUCT CONSOLIDATION 26
4.2.8 WORK PRACTICES 26
4.3 LUBRICATION GREASES 27
4.3.1 MOBILE VEHICLES 27
4.3.2 SHOVELS AND DRAGLINES . . ... . 27
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Page
4.4 SPENT VEHICLE FLUIDS AND ACCESSORIES 30
4.4.1 USED OIL 30
4.4.2 WASTE FILTERS 32
4.4.3 TRANSMISSION AND HYDRAULIC FLUIDS 33
4.4.4 ANTIFREEZE 34
4.4.5 BATTERIES 34
4.4.6 FREON , 34
4.5 SHOP AND VEHICLE CLEAN-UP WASTE 34
4.6 SOLID WASTES 35
3.6.1 SCRAP METAL 35
3.6.2 TIRES 35
3.6.3 SHOVEL AND DRAGLINE CABLE 36
3.6.4 RAGS 36
3.6.5 PAPER 36
3.6.6 WOODEN SPOOLS 36
4.7 PAINTS 37
4.7.1 PAINTS : 37
4.7.2 PAINT STRIPPERS AND THINNERS 39
5.0 SUMMARY AND CONCLUSIONS 40
6.0 WASTE MINIMIZATION ASSESSMENT WORKSHEETS 41
APPENDICES
APPENDIX A WASTE CLASSIFICATION AND HANDLING FORM
APPENDIX B MSHA "GENERIC PETITION" FOR USED OIL AS A
BLASTING AGENT
APPENDIX C PREDICTIVE MAINTENANCE LABORATORY ANALYSES
APPENDIX D ADDITIONAL WASTE MINIMIZATION ARTICLES
APPENDIX E CASE STUDIES
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ACKNOWLEDGEMENTS
This guide is based in part on pollution prevention and waste
minimization assessments conducted by the Front Range Community
College's Hazardous Materials Management Program (HAZMAT) at mining
operations in Wyoming and large fleet maintenance operations in
Colorado. Contributors to these assessments included: Richard
Earth, David Boon, Kim Lewis, and Robin Wright. .
Marie B. Zanowick, Manager of the Hazardous Waste Minimization
Program, Hazardous Waste Management Division, U.S. EPA Region VIII
served as the project manager and pollution prevention technical
expert for the P2 and Waste Minimization Opportunities for the
Mining Industry project.
In addition, Ms. Zanowick and Mr. Jim Kiefer, Environmental
Scientist, Region VIII EPA both provided input into P2 and waste
minimization assessments and technical review during, the manuscript
preparation.
The FRCC HAZMAT Program and the USEPA Region VIII would also like
to express their sincere gratitude to the mining operations that
provided invaluable input into this project: ARCO - 'Black Thunder
Mine, AMAX Belle Ayr Mine, Jim Bridger Mine, Dave Johnston Mine,
Mobil Caballo Rojo Mine and the Wyoming Mining Association.
NOTE:
State regulations may preclude the use of some of the
recommendations listed in this guidance document. For
instance, used oil is considered a hazardous waste in some
states and needs to be handled according to hazardous waste
regulations.
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1.0 INTRODUCTION
1.1 BACKGROUND
Each year mining operations use thousands of gallons of solvents
and generate millions of gallons of used oil, greases, and
lubricants during routine maintenance and repair of heavy
equipment. There are opportunities to reduce the amount of waste
generated through source reduction, product substitution, equipment
and/or process modifications, better management,
inventory/purchasing control practices and recycling.
This guide is designed to provide the surface mining operations
with pollution prevention (P2) and waste minimization options
appropriate for their industry. It also provides worksheets
designed to be used for a waste minimization assessment of a
surface mining operation, to develop an understanding of the waste
generation processes and to suggest ways that the waste may be
reduced.
This guide is designed primarily for use by operators of surface
mines with vehicle maintenance shops. Others who may find this
document useful are operators of vehicle fleets, regulatory agency
representatives and consultants. The guide is conveniently divided
into the following sections:
• Overview of Waste Minimization (Section 2.0);
• Waste Generation from Surface Mines (Section 3.0);
• Waste Minimization Options for the Surface Mining
Industry (Section 4.0);
• Summary and Conclusions (Section 5.0);
• Waste Minimization Assessment Worksheets (Section 6.0).
1.2 OBJECTIVES
This guide, which includes worksheets and a list of P2 and waste
minimization options, was developed through assessments of surface
coal mines in Wyoming and selected fleet maintenance facilities
located throughout Colorado. The firms' operations, waste
generation, and management practices were surveyed. In addition,
their existing and potential waste minimization options were
characterized. Additional information was developed from a
nationwide literature search and review.
The long term objective in producing this guide is to utilize this
information in assisting the mines in protecting the environment by
reducing their hazardous waste generator status.
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2.0 OVERVIEW OF WASTE MINIMIZATION
2.1 BACKGROUND
Waste minimization means the reduction, to the extent feasible, of
waste that is generated prior to treatment, storage and/or
disposal.
In 1984, Congress passed-the Hazardous and Solid Waste Amendments
(HSWA) to the Resource Conservation and Recovery Act (RCRA) which
specifically states:
The Congress hereby declares it to be the national policy
of the United States, wherever feasible, the generation
of hazardous waste is to be reduced or eliminated as
expeditiously as possible. Waste that is nevertheless
generated should be treated, stored, or disposed of as to
minimize the present and future threat to human health
and the environment.
In addition, the HSWA of 1984 requires every hazardous waste
generator to certify that he or she has a program in place to
minimize waste generation. The certification statement is found on
the Uniform Hazardous Waste Manifest. The certification-statement
is:
If J am a large-quantity generator, I certify that I have;
a program in place to reduce the volume and toxicity of'
waste generated to the degree I have determined to be
economically practicable and that I have selected the
practicable method of treatment, storage, or disposal
currently available to me which minimizes the present and
future threat to human health and the environment, or, if
I am a small-quantity generator, I have made a good-faith
effort to minimize my waste generation and select the
best waste management.
Waste minimization requires a dedicated commitment, careful
planning, creative problem solving, changed attitudes and sometimes
capital investments. However, the payoffs for this commitment can
be significant and include: reduced liability; more efficient use
of natural resources; reduced treatment and disposal costs; lower
environmental impacts; reduced regulatory involvement including
reduced fines and penalties; monetary savings; a safer work
environment and increased public relations.
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2.2 WASTE MINIMIZATION TECHNIQUES
Pollution prevention and waste minimization techniques, as defined
by the EPA can be broken down into two major categories: Source
reduction and recycling. It should be pointed out that waste
minimization does not include such processes as inc±nera-cio«i-r -
treatment, storage or disposal. Source reduction and recycling
should always be considered before treatment and/or disposal.
Source Reduction includes inventory control, improved housekeeping,
production/process modifications, product substitution or
reformulation, waste segregation and new uses.
Recycling includes the use or reuse of the material as an effective
substitute for a commercial product or as an ingredient or
feedstock in a process. It includes the reclamation of useful
constituents fractions within a waste materials or the removal of
contaminants from a waste to allow it to be reused.
2.2.1 Inventory Controls
In the past, the basic purchasing consideration for chemicals was
cost with ' little or no attention given to the expenses and
liability incurred during disposal. As a result, chemicals were
often purchased in large quantities. In addition, various brands
were purchased to take advantage of sales. This created hazardous
waste disposal problems that may be solved by some of the following
suggestions.
• Require supervisor approval prior to purchasing hazardous
chemicals. This forces workers to think twice before
requesting that a hazardous chemical be purchased and it
makes management aware of when and the volume of
chemicals being added to the inventory.
• Keep the inventory of hazardous chemicals to a minimum.
This will assist in container rotation and reduced
shelf-life problems. In addition, when less product is
available, workers generally use less.
• Reduce the number of brands or products used for the same
purpose. While everyone has a favorite brand, numerous
brands of the same product increase shelf-life problems.
• Purchase only what will be used within a short period of
time. Manufacturing facilities call this "just-in-time"
(JIT) purchasing.
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• Use of a simple labeling code, such as an orange sticker,
to identify chemicals that contain hazardous
constituents. Train individuals who are using these
chemicals to recognize the code and the proper handling
and disposal techniques. • .
A strict purchasing and inventory control program will prevent the
generation of hazardous waste due to poor product management.
Examples from mines include: Restricting the purchase of terne
plated filters, screening materials that contain trichloroethylene
(TCE) prior to purchase, and restricting the access of employees to
storage areas.
2.2.2 Improved Housekeeping
Good housekeeping can solve a variety of hazardous waste generation
problems. In addition, housekeeping changes can be implemented
quickly and with little cost. Sloppy housekeeping, which includes
leaks from tanks, pumps and valves and release of product onto the
floor, can dramatically increase the volume of hazardous waste.
Other practices such as tank overfills, lack of drip boards, and
chronic spills and leaks add to the hazardous waste stream. Not
only is valuable product lost but the volume of waste generated
increases due to the materials (rags, floor dry and water) used
during cleanup. Other housekeeping problems involve improper
storage practices, inefficient production startup and shutdown,
scheduling problems and poorly calibrated control devices.
Examples from mines include: Utilizing drip pans, improving liquid
transfer techniques, and reducing water usage during floor cleaning
by using spot washing.
2.2.3 Production/Process Modifications
Outdated equipment and traditional production methods can generate
large volumes of hazardous waste. Although the capital investment
to purchase new equipment or modify existing equipment can be high,
the investment payback is usually significant when compared to
disposal and liability costs.
Examples from mines include: Filtering solvents for extended
reuse, switching to industrial parts washers, and utilizing
predictive maintenance programs.
2.2.4 Product Substitution/Reformulation
Substituting a non-hazardous chemical for a hazardous one has
obvious benefits for waste minimization, environmental protection
and worker health and safety. Many products are being reformulated
by chemical manufacturers due to increased pressure being placed on
them by industry.
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»
Examples from mines include: Switching to water based parts
cleaners and using reformulated greases which contain no TCE for
shovel/dragline lubricants.
2.2.5 Waste Segregation
Many wastes are.actually mixtures of hazardous and nonhazardous
waste, such as chlorinated solvents and used oil. When this
happens, regulatory definitions may place the entire waste stream
in the hazardous waste category. By segregating key constituents,
generators can save substantial amounts of money on waste disposal.
Waste segregation can also assist in recycling. An unsegregated
waste stream may be too costly to recycle because of the large
component of nonrecyclable waste.
Examples from mines include: Segregating hazardous waste solvent
coated rags from nonsolvent rags, segregating different types of
paint waste, and segregating recyclable solid waste materials.
2.2.6 New Uses
When a waste material can be reused as in recycling or when a "new
use" can be found for the materials several advantages occur.
Disposal costs are reduced or eliminated and raw material purchase
costs are also reduced. Operations are encouraged to seek out new
and environmentally sound uses for waste materials which were
previously treated and/or disposed. Some assistance can be found
with the expanding waste exchange programs being established across
the United States.
Examples from mines include: utilizing used oil for energy
recovery on-site with used oil furnaces, using used oil as a crude
lubricant for dragline ropes, and possibly using used oil as a
mixture with fuel oil for a~"blasting agent.
2.3 WASTE MINIMIZATION ASSESSMENTS
The EPA has developed a general manual for waste minimization for
industry* The Waste Minimization Opportunity Assessment Manual
(USEPA 1988) and the revised Pollution Prevention Facility Manual
(USEPA 1992) tell how to conduct a P2 and waste minimization
assessment and develop options for reducing hazardous waste
generation. It explains the management strategies needed to
incorporate waste minimization into company policies and structure,
how to establish a company-wide P2 and waste minimization program,
conduct assessments, implementation options, and make the program
an on-going component of the facility operation.
The Waste Minimization Opportunity Assessment (WMOA) is a
systematic procedure for identifying ways to reduce or eliminate
waste. The four phases of a waste minimization assessment are:
(1) planning and organization, (2) assessment, (3) feasibility
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analysis, and (4) implementation. The steps involved in conducting
a waste minimization assessment are illustrated in Figure 1.
Briefly the assessment consists -of a careful review of a plant's
operations and waste streams and the selection of specific areas to
assess. After a particular waste stream or area is established as
the WMOA focus, a number of options with the potential to minimize
waste are developed and screened. The technical and economic
feasibility of the selected options are then evaluated. Finally,
the most promising options are selected for implementation.
2.3.1 Planning and Organization
Essential elements of planning and organization for waste
minimization are: getting top level management commitment; setting
waste minimization goals; and organizing an assessment task force.
2.3.2 Assessment Phase
The assessment phase involves a number of steps:
Collect process and facility data;
Prioritize and select assessment targets;
Select assessment teams;
Review data and inspect the site;
Generate options;
. Screen and select options for feasibility study.
Collect process and facility data - The waste streams at a facility
should be identified and characterized. Information about the
waste streams may be available on hazardous waste manifests,
National Pollution discharge elimination system (NPDES) reports,
routine sampling programs and other sources.
Developing a basic understanding of the processes that generate
waste at a facility is essential to the .WMOA process. Block
diagrams can prepared to identify the quantity, types and rates of
waste generating processes. Also, preparing overall material
balances for the facility can be useful in tracking various waste
streams components and identifying losses or emissions that may
have been unaccounted for previously.
Prioritize and select assessment targets - Ideally, all waste
streams in a facility should be evaluated for potential waste
minimization opportunities. With limited resources, however, a
plant manager may need to concentrate waste minimization efforts in
a specific area. Such considerations as quantity of waste,
hazardous properties of the waste, regulations, safety of
employees, economics, and 'other characteristics need to be
evaluated in selecting a target waste stream.
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FIGURE 1
The Recognized Need to Minimize Waste
PLANNING AND ORGANIZATION PHASE
• Get management commitment
• Set overall assessment program goals
• Organize assessment program task force
I
Assessment Organization A
Commitment to Proceed
\
ASSESSMENT PHASE
Collect process and site data
Prioritize and select assessment targets
Select people for assessment teams
Review data and inspect site
Generate options
Screen and select options for further study
Select New Assessment
Targets and Reevaluate
Previous Options
Assessment Report of
Selected Options
FEASIBILITY ANALYSIS PHASE
• Technical evaluation
• Economic evaluation
• Selected options for implementation
Final Report. Including
Recommended Options
IMPLEMENTATION PHASE
Justify projects and obtain funding
Installation (equipment)
Implementation (procedure)
Evaluate performance
Repeat the Process
Successfully Implemented
Waste Minimization Projects
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Select assessment team - The assessment team should include people
with direct responsibility and knowledge of the particular waste
streaim or area of the facility.
Review data and inspect the site - The assessment team evaluates
process data in advance of the inspection. The inspection should
follow the target process from the point where raw materials enter
the facility to the points where products and waste leave. The
team should identify the suspected sources of waste. This may
include the maintenance operations and areas for storage of raw
materials and finished product and for work in progress. The
inspection may result in the formation of preliminary conclusions
about waste minimization opportunities. Full confirmation of these
conclusions may require additional data collection, analysis,
and/or site visits.
Generate options - The objective of this step is to generate a
comprehensive set of waste minimization options for further
consideration. Since technical and economic concerns will be
considered in the later feasibility stage, no options are ruled out
at this time. Information from the site inspection, as well as
trade associations, government agencies, technical and trade
reports, equipment vendors, consultants, plant engineers and
operators may serve as sources of ideas for waste minimization
options. • .
Source reduction and recycling options should be considered first.
Source reduction may be accomplished through good operating
practices, technology changes, and input material changes.
Recycling includes the use and reuse of the waste stream and
reclamation.
Screen and select options for feasibility study - The screening
process is intended to select the most promising options for full
technical and economic feasibility analysis. Through either an
informal review or a quantitative decision making process, options
that appear marginal, impractical or inferior are eliminated from
consideration.
2.3.3 Feasibility Analysis
A waste minimization option must be shown to be both technically
and economically feasible in order to merit serious consideration
for implementation. A technical evaluation determines whether a
proposed option will work in a specific application. Typical
technical evaluation criteria include worker health and safety,
maintenance of product quality, space availability, compatibility
with existing operations, labor requirements, installation
procedures and system maintenance. In addition, both process and
equipment changes need to be assessed for their overall effects on
waste generation and product quality.
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An economic evaluation is carried out using standard measures of
profitability, such as payback period, return on investment, and
net present value. Capital investment criteria include such costs
as site development, permitting costs, contractors' fees, start-up
time, and training. Operating costs and savings must also be
analyzed and may include reduction in waste management and disposal
costs, material cost savings, insurance and liability savings,
changes in utility costs, and changes in operation and maintenance.
While profitability is important in deciding whether or not to
implement an option, compliance with existing and future
environmental regulations may be even more important. A company
operating in violation of environmental regulations can face fines,
lawsuits, civil and criminal penalties and even closure.
Therefore, decisions should not be based on short-term
profitability alone.
2.3.4 Implementation
An option that passes both technical and economic feasibility
analyses should then be implemented. It is then up to the
assessment team, with management support, to continue the process
of'tracking waste streams and identifying additional opportunities
for waste minimization throughout a facility.
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3.0 SURFACE MINING WASTE PROFILE
The major waste streams generated by the mining industry are in
conjunction with their heavy equipment use and maintenance
operations. Primary consideration was given to waste streams that
met the following criteria:
• Hazardous waste;
• Waste which poses a significant risk to human health
and/or the environment;
• Waste generated and/or released in high volumes;
• Waste that has a high cost associated with treatment,
storage and/or disposal;
The most common waste streams generated by mines during heavy
equipment operations that meet the above criteria include:
• Waste Water - This waste is generated by the washing of
vehicles prior to maintenance, washing shop floors, and
water-based parts washers.
• Spent Parts Cleaning Solvents - These typically include
chlorinated or hazardous substances containing solvents
from equipment and parts cleaning, and aerosol sprays.
• Lubrication Greases - Two broad categories of lubricants
are used: grease for mobile vehicles and those for the
relatively stationary shovels and draglines.
• Spent Vehicle Fluids and Accessories - These waste
streams include anti-freeze, engine oil and lubricants,
transmission fluids, hydraulic fluids, refrigerants,
filters and batteries.
• Shop and Vehicle Clean-up Waste - These include waste
such as aqueous floor and vehicle cleaning solutions, oil
adsorbents, floor dry type materials for minor spills and
dirty rags.
• Solid Waste - These include rejected metal parts, old
tires, broken hoses and belts, empty containers, filters
and paper waste.
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3.1 WASTE WATER
3.1.1 Waste Water Generation
Washing vehicles prior to maintenance, washing the shop floor, and
water-based parts washers are the dominant generators of waste
water.
Vehicles are washed prior to maintenance in a separate wash bay and
light vehicles are washed as needed for appearance. The vehicle
washing waste stream consists of hot water, detergents, grease,
oil, and solids, especially road dirt. Most facilities use a high
pressure water spray to facilitate the cleaning process.
Floors are washed with cold water and usually a cleaner. A variety
of floor cleaners are used, usually a non-hazardous high pH liquid.
Water is often applied via a high pressure unit.
Water-based parts washers are used at many facilities. Parts
washers use water, detergent (usually a biodegradable type), and
sometimes a surfactant. Most washers have an oil skimmer and a
sediment trap.
Total amount of waste water from vehicle maintenance areas is
unknown, but solids generated from washing may exceed several
hundred yards per year at some mining operations. Both solids and
liquids are usually analyzed on an annual basis for hazardous
constituents. The waste water and associated solids are typically
non-hazardous. However, samples should be taken on a point source
basis so a particular waste stream that might generate a hazardous
waste is identified prior to mixing with a non-hazardous waste,
which may result in the entire waste stream becoming a hazardous
waste.
3.1.2 Waste Water Treatment
Pretreatment of waste water varies but usually includes traps that
catch solids. The traps are cleaned out on a periodic basis either
through a contracted vacuum service that disposes of the waste off
site or through mining personnel where the solids are scooped out
and landfilled on site. A method that 'is less common is to treat
the waste water solids by land farming prior to landfilling.
Some facilities have an oil skimmer as part of the waste water sump
system. The skimmed oil may be recovered for fuel blending. A
variety of oil skimming systems are used. A pneumatic system
allows sediments to settle out before it turns on, and this may
decrease the need for pump maintenance. All waste water is
eventually retained in some type of pond where it evaporates or is
reused as discussed in Section 4.1.2 (Waste Minimization Options).
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3.2 SOLVENTS AND SPENT FARTS CLEANING
A variety of solvents (or degreasers) are used throughout the
vehicle maintenance program. The largest volume of solvent is used
for parts cleaning. The waste solvents from parts cleaning often
represent the largest source of hazardous waste from a mining
operation. Relatively small quantities of solvents are used for
cleaning electrical contacts, small engine parts, and related uses.
A third solvent waste stream is generated when these chemicals are
used for general purpose surface cleaning (wipe down or field
solvents), especially on draglines. Solvents associated with
painting are addressed .in Section 3.7 (Paints/Strippers and
Thinners).
3.2.1 Parts Cleaning with Solvents
Parts cleaners are dominated by a sink type device that dispenses
solvent from a faucet and collects the spent solvent in a drum
beneath the sink. Parts cleaners may have filtering units that
remove grease and solids and allows for product reuse. When the
filters are spent they must be tested to determine if they are
hazardous waste even if the solvent was a non-hazardous material.
In some cases the solvents supplier picks up the filters for proper
disposal. ' The solvents used in parts cleaners ranges from the
typical hazardous chlorinated solvents to non-hazardous solvents
with a citric base. Mining operations can easily generate from
10,000 to 30,000 pounds of hazardous waste from solvent parts
washers each year.
Various types of "dip" tanks are used for cleaning large
components, such as engine blocks. The tank solvent is usually
methylene chloride -or sodium hydroxide. Both products are
considered hazardous waste. Tanks may contain as much as 600
gallons of solvent which requires replacement every few years,
depending on use.
3.2.2 Contact Solvents
Numerous contact cleaners, usually in aerosol form, are used for
cleaning electrical components, small parts, carburetors, etc.
Some of these contain chlorinated hydrocarbons, especially when the
cleaned surface must be product or residue free. Standard
procedures call for the aerosol'solvents to be completely used, the
container depressurized, and the carcass thrown into the trash.
Mining operations can use over 20,000 cans of non-chlorinated
aerosol solvents per year.
3.2.3 Wipe Down (Field) Solvents
Wipe down solvents are used for general purpose cleaning of
surfaces that are dirty due to grease and other lubricating fluids.
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A variety of products are used, such as a non-chlorinated petroleum
naphtha which contains ethyl benzene, xylene, aromatic, and mineral
spirits. Hazardous solvents are often used as wipe down because
the solvent quickly volatilizes and the only waste product is the
contaminated rag. However, concerns about worker safety are
forcing mining operations to look at less toxic alternatives.
Large mines use over 10,000 gallons of field solvents per year.
3.3 LUBRICATION GREASES
A variety of lubricating greases are used throughout the vehicle
maintenance operations. In some cases it is difficult to
distinguish between grease and oil. Although oils are viewed as
low viscosity and greases as high viscosity, there are no
definitive lines separating the two types of lubricants.
Therefore, some of the lubricants discussed below, especially for
draglines and shovels, may be closer to oils than greases.
Waste disposal problems for greases are not related to the basic
hydrocarbon. nature of the lubricants but to the additives that
distinguish one product from another. Thousands of additives are
used, and some of them are classified as hazardous under RCRA.
Two broad categories of such lubricants can be distinguished:
grease lubricants for'mobile vehicles ranging from light duty vans
to 240 ton haul trucks, and grease lubricants for the relatively
immobile shovels and draglines.
3.3.1 Mobile Vehicles
Relatively large quantities of grease are used during routine
vehicle maintenance, especially for haul trucks. Haul trucks range
in size from 100 to 240 tons, with the latter size being the most
common. It is estimated that the average haul truck requires from
350 to 400 pounds of grease per year. Greases for these vehicles
generally are dominated by extreme pressure formulas and are
classified as non-hazardous when it arrives as a virgin product.
No waste streams were identified specific to mobile vehicle
greases. Small quantities of waste grease enter the shop's waste
water when vehicles are washed prior to maintenance. Minor amounts
of waste grease are also generated when lubricated parts are
removed for repair or replacement. The grease associated with
these parts is scraped, wiped, or washed off with solvents or hot
water. Additional grease is lost during normal vehicle use due to
evaporation of the more volatile compounds in the lubricant,
although evaporation accounts for less than 5 % of the grease loss.
It appears that most (over 90%) of the vehicle grease is lost
through normal leakage while the vehicle is in motion. Some of
this leakage is due to shear stress that changes the molecular
weight of the grease and allows it to run out of the bearings and
other contact surfaces.
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3.3.2 Shovels and Draglines
Shovel and dragline lubricants can be classified into four loose
and somewhat overlapping categories:
• Open gear compounds;
• Extreme pressure (sometimes called general purpose)
greases;
• Wire rope lubricants; and
• Cam and slide lubricants.
Open Gear Compounds
Open gear compounds are used on any kind of flat surface contact
between two components where the motion is relatively slow. This
type of lubricant is most commonly used on the large open gear and
pinion sets. Swing rack, rollers, cam frame, propel bushings, open
gear sets, and the center pin also use open gear compounds. A
given machine uses from less than 4,000 to over 60,000 pounds of
open gear compounds per year, depending on the size of the machine.
The areas in which open gear compounds are used consist of high
stress contacts that require a viscous, additive-laden, petroleum^
based lubricant. Therefore, most open gear compounds are asphaltic.'
(heavy black oils with a high viscosity) in nature and required a
fast drying solvent, such as trichlorethylene (TCE) as a "carrier"
which makes the grease more pumpable. In addition, the TCE
additive allows the grease to form a thin, uniform, and fast drying
coat on the wear surfaces. Recently, paste type lubricants were
manufactured that had less tendency to run under high temperatures
but still required a chlorinated solvent to make them pumpable,
especially in cold weather. These types of open gear compounds are
commonly used at surface mining operations.
Some dragline operations use lubricants where the hazardous
solvents have been replaced by biodegradable solvents that pass
current TCLP tests. Such lubricants supposedly provide improved
water resistance and equipment protection over a wide range of
operating temperatures. Petroleum resins and oils dominate these
lubricants with minor constituents that include lubricating solids,
additives, and biodegradable components. Although such greases are
not classified as hazardous waste, they tend to cost more, they are
runnier because of slower evaporation of the biodegradable solvent,
and they tend to be messy and require more cleanup time.
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As the above-mentioned greases degrade with use, they may ball up,
form a paste, or for the less viscose types accumulate on the side
and bottom of cases. Routine maintenance removes this grease.
Approximately 50% of the open gear compounds are recovered for
disposal as either a hazardous or non-hazardous waste, depending on
the constituents. .
Extreme Pressure Greases
Extreme pressure (EP) lubricants are used in all anti-friction
bearings and higher speed applications. It consists of an oil base
compound, a thickener system (often lithium or calcium soaps), and
additives that were dominated by lead (up to 35% of the lubricant
by weight). The lead is now being replaced with antimony, bismuth,
boron, and other products. These lubricants can withstand normal
operating temperatures, and are pumpable, water resistant, and
mechanically stable.
Following application, the EP lubricants weep out of the bearings
and other lubricating points. Therefore, less than 5% of EP
greases are recovered, usually during cleaning operations that
utilize rags to remove released lubricants. Annual use of EP
lubricants ranges from less than 2000 to approximately 3000 pounds
per machine.
Wire Rope Lubricants
Both hazardous and non-hazardous wire rope lubricants are used at
surface mining operations. These products lubricate the running
wire ropes connected to the bucket. For the most part, these
lubricants are dispersed throughout the length of the rope and
cannot be recovered. Some lubricants are designed to have good
penetrating qualities that lubricate the inner strands to minimize
corrosion and wear. Other lubricants are of high viscosity and are
formulated to stay on the outside of the rope to minimize dirt
entry. Both products consist of petroleum hydrocarbons and extreme
pressure additives.
Wire rope lubricants are applied manually by the operator. Hoist
and drag ropes require more lubricant, often about 55 gallons per
day, than the dump ropes that may only require a few gallons of
lubricant per day. Use varies considerably and can range from
approximately 5000' to over 30,000 pounds per year per machine.
Some operators are of the philosophy that liberal use of wire rope
lubricants cleans off the rope and increases rope life. Other
operators contend that liberal oiling encourages dust collection by
the rope.
Essentially all of the wire rope lubricant is lost during normal
dragline or shovel operation. Recovery of spent lubricant would be
limited to inside the machine and would account for less than 5% of
the wire rope lubricant.
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Cam and Slide Lubricants'
Cam and slide units require grease with every movement. The
previous described non-hazardous open gear compounds with EP
additives are commonly used, with some important exceptions.
Some draglines use a propel system known as a Monigham cam. This
has 21 large metal cage in which an eccentric cam rolls around and
lifts the machine when walking. This cam is extremely difficult to
lubricate and usually requires a lubricant heavily fortified with
heavy metals such as copper flakes, zinc, graphite, and others.
These lubricants are semi-solid with retention characteristics that
allow the lubricant to remain intact on surfaces to protect against
metal to metal contact under the combined rolling and sliding
friction dynamics of the cam mechanism. At the present time all
Monigham Cam lubricants contain from 5 to 25% chlorinated solvents
as a diluent. Several lubricant manufacturers are in the process
of developing non-hazardous cam lubes, however none have been
thoroughly tested. Other additives may include lithium, nitrogen,
sulfur, and phosphorus. This lubricant tends to harden and sluff
off in solid chunks and must be disposed of as a hazardous waste.
Annual use of cam and slide lubricants ranges from 800 to over
6,000 pounds per machine, with approximately 80% of this grease
being recovered for disposal.
The second exception involves a different propel system that
consists of a shoe hung from either side of the machine by a crank
arm in which the sliding surfaces are immersed in a bath of semi-
liquid lubricants that can be considered a thick oil or a runny
grease. The lubricant is a petroleum hydrocarbon plus unspecified
additives that may contain antimony, molybdenum, and phosphorus.
This product does not contain solvents and is not a RCRA hazardous
waste. Estimated annual use of this lubricating fluid ranges from
less than 10,000 to 30,000 pounds per year per machine depending on
how far the machine is walked and the operating grade.
Approximately 80 to 90% of the lubricant is recoverable for waste
disposal.
Other Lubricants
A variety of other contact surfaces on shovels and draglines are
lubricated with some combination of the above compounds. For
example, shovels that use a track system for movement require a
variety of open gear compounds, closed gear oil, arid EP lubricants,
some of which may have hazardous constituents. Often this variety
of lubricants is replaced by a single multi-purpose grease.
Estimated use of track system lubricants is 3000 pounds per year
per machine. Some of this can be recovered, especially the
lubricants within the crawler gear case that contains from 100 to
200 gallons of lubricants. Other greases, such as those that
accumulate within the crawler frame, are sloughed off in a soft or
semi-solid form and can be scraped up and recovered for disposal.
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3.4 SPENT VEHICLE FLUIDS AMD ACCESSORIES
Spent vehicle fluids and accessory waste streams include greases,
engine oil, filters, transmission and hydraulic fluids,
refrigerants, and batteries. Waste greases were covered in Section
3.3 (Lubrication Greases).
3.4.1 Used Oil
Oil systems perform two important functions. They lubricate moving
parts and aid in cooling of the engine by reducing friction and
removing some heat 'from the cylinders. Used oils are by far the
largest component of the spent vehicle fluid waste stream.
The amount of oil used depends on the vehicle type, size and the
type of maintenance program. Used oil volumes typically range from
approximately 20,000 gallons to over 70,000 gallons each year. The
used oil is drained from the vehicles into satellite storage
containers and then transferred into larger above or below ground
storage tanks. Currently, the most common disposal practice at
mining operations is off-site recycling through vendors for
supplemental fuel programs.
3.4.2 .Waste Filters
Filters are utilized to remove particulates (debris) from the fuel,
lubrication, or control (transmission and hydraulic) systems of
vehicles. To increase the life of many filters and to provide for;
corrosion resistance, some manufacturers plate filters with a lead
and tin coating on the internal surface. These type of filters are
termed terne plated filters. Filters without the internal plating
are called nonterne plated filters.
Most operations are aware of the difference between terne plated
and .non-terne plated filters. Many of the vendors in the past
marketed the terne plated filters with a life-time warranty. The
problem associated with terne plated filters is the high levels of.
lead and tin. These constituents make the filters unsuitable for
land disposal. The filters, if not recycled, must be tested and if
failure of TCLP occurs they must be handled as hazardous waste.
Most operations are discontinuing the purchase of terne plated
filters or are insuring that filters are recycled as scrap metal.
A general breakdown of the types of filters utilized at a mining
operation for a one year period is as follows:
60% diesel oil;
• 20% diesel fuel;
• 10% diesel transmission;
• 5% diesel .hydraulic;
5% gas engine oil, fuel and transmission filters.
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The actual number of filters used or the volume of waste filters
generated on an annual basis is undetermined at most operations.
3.4.3 Transmission and Hydraulic Fluids
Vehicle preventative maintenance programs typically call for a
change of oil, transmission and hydraulic fluids at predetermined
periods (i.e., after 250 hours of operation). Most operations do
not segregate out the transmission and hydraulic fluids. These
vehicle fluids are mixed with the used oil that is generated on
site,, However, the volumes may be significant since the larger
haul trucks can use over 150 gallons.
3.4.4 Antifreeze
Most vehicles contain a engine coolant which is most commonly an
ethylene glycol antifreeze. The engine coolant may be regulated as
a hazardous waste because it contains ethylene glycol and
detectable concentrations of benzene, toluene, lead, zinc, arsenic,
mercury and copper which accumulate from the cooling system.
Most operations estimate that they use between 2,000 and 8,000
gallons of antifreeze (ethylene glycol) each year. Some
operations have switched to propylene glycol, which is less toxic
than ethylene glycol. . .
3.4.5 Batteries
Spent batteries are generated by the light and heavy duty trucks at
mining operations. Larger mines can generate in excess of 300
spent batteries per year. On a weight basis, spent lead batteries
can be one of the larger categories of hazardous waste generated
at a fleet maintenance operation. However, recyclers typically pay
for battery recycling. Most operations return their vehicle
batteries to the vendor for recycling. However, waste can be
generated from broken batteries and from spilled battery acid which
is added to batteries on an as needed basis.
3.4.6 Freon
The Clean Air Act Amendments of 1990 require that the freon from
the vehicles' air conditioning system is captured and recycled.
All operations currently utilize certified employees or vendors to
perform this service.
3.5 SHOP AMD VEHICLE CLEAN-UP WASTE
Most mining operations utilize a form of floor dry to absorb minor
spills and leaks in the maintenance areas. The volumes of waste
generated are unknown. Most mines take precautions to avoid any
hazardous materials from being spilled, therefore most of the floor
dry is not a hazardous waste.
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Most mines use a clay type of absorbent material to clean up
spilled fluids in the shop areas. The procedures for the spent
floor dry varies between mines and ranges from disposal at on-site
or off-site landfills. Any floor dry used to absorb a hazardous
materials such as spilled solvents must be treated and disposed of
as a hazardous waste.
There are three types of sorbents currently available: natural,
mineral, and synthetic. Natural and mineral sorbents are
considered absorbents because the liquid penetrates their fibers.
Natural and mineral sorbents are typically disposed of in
landfills, but some states have banned disposal of saturated
sorbents in landfills due to the leaching problems associated with
the material. Synthetic sorbents are considered adsorbents because
the liquid does not penetrate into the fibers. '
Natural sorbents includes materials such as cotton, peat, sawdust,
and corncobs. These sorbents have widespread use due to their low
cost and most are usually disposed of in a landfill. Certain types
of natural sorbents also have the advantage of being able to be
incinerated for energy recovery if they meet RCRA standards,
including being lightweight, liquefiable and having a BTU content
of at least 5000 BTU's per pound.
Mineral sorbents include vermiculites such as clay pellets and are
also widely used due to their low initial cost and ease of
disposal, usually in a landfill.
Synthetic sorbents made from polypropylene and polyurethane are
becoming increasing popular because of their high absorbency and
the fact that certain types can be wrung out and reused and the
recovered fluids recycled or burned for energy recovery. This can
cut down on the disposal costs, offsetting the higher cost of the
synthetic sorbents. Synthetic fibers come in different types such
as socks, rolls, and pads. Some can be wrung out and reused more
than 15 times.
3.6 SOLID WASTES
3.6.1 Scrap Metal
Mines generate various types of scrap metal in unknown.quantities.
The scrap metal includes broken parts, cuttings from machine shops,
and aluminum cans.
3.6.2 Tires
Mining operations generate light vehicle tires and large tires from
haul and shovel trucks. Mines can generate over 300 light vehicle
tires and over 80 large tires per year.
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Disposing of tires is becoming increasingly difficult as some
states enact bans on landfilling tires. Landfilled tires are also
possible health hazards as they are breeding grounds for
mosquitoes, which may carry diseases.
Most of the light vehicle tires are taken back by vendors for
retreading. In some cases the mines landfill the light vehicle
tires. Mines also use smaller tires for "cable trees" and survey
markers.
The larger haul truck and scraper tires are typically given away to
ranchers and farmers. The ranchers utilize them for water troughs,
wind breaks, shelter breaks, salt troughs, etc. Most mines have no
trouble getting rid of large tires. However, some mines will not
give their tires away due to the potential liability from injuries.
These mines landfill their tires.
3.6.3 Shovel and Dragline Cable
The draglines and shovels utilize a variety of ropes (steel cable)
for hoisting, dragging and releasing the digging bucket. These
"ropes" range in thickness of 2.5" for shovels to over 3.25" and
weigh up to 40 pounds per linear foot of cable.
The'amount of.rope utilized in any given year varies among mines.
The length varies from 10,000 to 25,000 yards of rope per year per
machine. Mines typically backfill the "ropes" or landfill them on-
site.
3.6.4 Rags
Hags are needed in maintenance facilities for parts cleaning and
drying and for cleaning small drips or spills. Mining operations
typically use disposable rags for minor cleaning. Mines typically
segregate solvent rags • from other types. Solvent rags are
typically drummed, tested for TCLP, and handled accordingly. If
utilized for general cleanup without solvents, they are placed in
a dumpster for disposal at an off-site or on-site landfill.
3.6.5 Paper
Paper is either discarded in dumpsters or recycled from computer
printer areas. However, most paper at mines is disposed of at
either on-site or off-site landfills.
3.6.6 Wooden Spools
Wooden spools from cable and dragline/shovel ropes are typically
broken down and have a variety of uses on site or are landfilled.
Some mines have arranged with their wire or cable rope vendors for
the vendor to take the wooden spools back.
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3.7 FAINTS, STRIPPERS AMD THINNERS
3.7.1 Paints
Paint is used for a variety of operations including the touch-up of
trucks .and mining equipment, parts coating/ and facility
maintenance. The painting of large equipment is typically
contracted to off-site vendors.
Different types of paints are used depending on the required task.
Acrylic lacquer, acrylic enamel, synthetic enamel, catalyzed
acrylic enamel, color/clean polyurethane, and primers may be used
to touch up trucks and mining equipment. Powder coatings and high.
temperature paints may be used to coat engine parts. Latex (water-
based) paints, oil-based paints, lacquers and enamels may be used
for facility maintenance.
Some paints are considered hazardous due to heavy metals they may
contain including arsenic, lead, cadmium, chromium and zinc.
Certain types of paints may contain hazardous solvents. Some
paints, primers, lacquers and enamels may also be flammable.
Waste streams from painting operations include leftover paint,
paint sludge, primer waste, paint containers, spent
solvents/thinners due to paint removal and cleaning of painting
equipment, and air emissions of volatile organic compounds (VOC's).
The most common methods for disposal of paint and paint associated
waste steams at most mining operations include: off-site fuel
blending for flammable hazardous waste materials, puncture
(atmospheric pressure) of aerosol cans with collection of waste
paint, segregation of water-based latex paints from solvent/oil
based paints, land disposal and/or recycling of metal paint
containers and aerosol cans.
3.7.2 Strippers and Thinners
Paint strippers are used to remove the paint and primer from trucks
and mining equipment in preparation for repainting. Paint thinners
are also used for washing painting equipment and thinning viscous
paint.
Different types of paint strippers are used depending on the
required task. Highly caustic paint strippers are commonly used
for stripping the lacquers and enamels used on trucks and mining
equipment. Paint strippers and thinners used for facility
maintenance may vary from toxic to more "environmentally friendly"
products.
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Some paint strippers and thinners are considered hazardous due to
their flammability and their chemical constituents (xylene,
nethylene chloride). Paint strippers used to strip enamels and
lacquers from vehicles are often ammonia-based and highly caustic.
Waste streams from paint stripping operations may include paint
sludge, primer waste, paint stripper/thinner containers, spent
solvents/thinners due to paint removal and cleaning of paint
equipment and air emission of VOC's.
The most common disposal method for these types of wastes include:
disposal at licensed hazardous waste landfills, recycling off-site
(through vendors) of the solvents, and fuel blending for the
flammable wastes.
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4.0 WASTE MINIMIZATION OPTIONS
Using the criteria outlined above in Section 2.1, the following
waste stream prioritization is warranted:
• Chlorinated or hazardous waste solvents;
• Dragline and shovel greases;
• Used oils, hydraulic and transmission fluids;
• Solid waste.
Efforts should be targeted to reduce and/or eliminate these waste
streams. Several excellent examples have been initiated at several
mining operations. Waste minimization options for mining
operations are outlined in the following section.
4.1 WASTE WATER
4.1.1 Waste Minimization During Floor Washing
Frequency of washing floors, the largest generator of waste water
at some facilities, varies from daily to once a month and less.
The need for regular washing of the shop floor is debatable.
Floors are washed for the following purposes:
• Dirt, oil, and other fluids can create a slippery floor
that is a safety hazard;
• Shop floors should be relatively clean to facilitate
equipment use and to prevent any transfer of dirt from
parts into the vehicle; .
«
• A relatively clean floor promotes a good working
environment and makes an indirect statement about
quality.
Cleaning a floor with water may not be necessary to accomplish the
above objectives. Waterless floor cleaning will likely achieve the
objectives if the following steps are followed:
Thorough washing of vehicles prior to maintenance and/or
repair;
Use of portable containers to catch fluids as they are
drained from vehicles or as they drip from components
under repair;
Use of absorbents to catch any inadvertent fluid spills;
and
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Thorough sweeping of the floor immediately after a
vehicle leaves the shop.
Most of these steps are currently implemented on a routine basis.
However, after sweeping the floor many facilities then wash the
floor. This step is rarely necessary and simply increases the
volume of waste generated. Conscientious implementation .of
waterless cleaning should almost eliminate the need for washing a
floor with water.
\
Spot, washing with a mop may accomplish the same objectives and
will generate a minimal amount of liquid waste as compared to
washing the entire floor. The shop area floor drains can also be
covered with rubber mats to discourage unnecessary washing and to
prevent unauthorized dumping into the drains. Another option is a
mobile floor washer that recycles the fluids as it washes the
floor.
Some facilities do not scrub their shop floor with water. Floor
dry is used to absorb spills and the area is swept on a daily
basis. Other operations mop the floor about twice a month with
very little waste water generated.
4.1.2 Waste Water Reuse
Prior to reuse, waste streams must be separated from the waste
water. Solids are allowed to settle out in traps of some type.
Used oil is skimmed from the water surface. One effective
technique uses a sump to pump the oil from a collection point. The
pump does not turn on until the used oil depth reaches 18 inches,
then the pump kicks in and pumps down to 9 inches of oil. This
eliminates any water in the used oil. The used oil can then be
burned on site for heat recovery or transported off-site for fuel
blending.
The impounded waste water can be used effectively for dust
suppression. Most mining operations have had no problems in
reusing the water in this manner.
4.2 SPENT PARTS GLEAMING SOLVENTS
4.2.1 Product Substitution
Product substitution is the most promising method to reduce the
large contribution of solvents to the hazardous waste stream.
Numerous substitute products exist and surface coal mine vehicle
maintenance facilities are quickly changing to non-hazardous
solvents. However, product substitution is not without problems.
Some of these problems are summarized as follows:
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Some substitute products leave a residue on the cleaned
part. The requirement for complete and rapid
volatilization of a solvent has prevented some mines from
using non-hazardous solvents for cleaning sensitive
parts, such as electrical contacts. For example, solvent
residue on electrical components can cause f lashover that
may result in a fire. Solvent residue within a dragline
means that a cleaned surface will remain slippery for
longer than normal.
Some non-hazardous solvents have a strong odor, usually
a citrus smell, that is offensive to some workers.
Some users of non-chlorinated solvents claim that it
takes twice as much solvent to clean a part as compared
to chlorinated solvents.
Suppliers that recycle solvents have a difficult time
preventing hazardous solvents from being mixed with the
recycled waste stream. For example, one major company
supplies a "non-hazardous" recycled solvent to mines, yet
this product contains approximately 0.5 percent TCE.
This chlorinated solvent is not part of the original
formulation and appears to come from users dumping TCE
into the recycling container.
Some mines have experimental programs to evaluate solvents. Only
one solvent is used at a time and those using the solvents keep
notes on the results. This allows systematic evaluation of
solvents one at a time.
4.2.2 Technology Substitution
Industrial parts washers provide a promising alternative to solvent
cleaners. These washers clean parts using hot water and a
surfactant and/or detergent. Most units have an oil-water
separator, filters, and sludge collectors. Washers come in various
sizes, with the large size capable of handling most parts typically
cleaned during vehicle maintenance. The water from the hot water
parts washers is recycled within the unit. Many mining operations
are using these washers on an experimental basis. At this time,
all mines contacted during this study were satisfied with the
results and plan on buying more units.
Large oven-type devices are available that bake off greases and
other residues on vehicle parts, especially the large parts such as
engine blocks. Although limited to components that will not be
damaged by heat, thermal treatment has potential, especially since
no waste is generated.
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4.2.3 Recycling and Reuse
Fitting parts washers with recycling pumps and filters can reduce
solvent waste generation by 50% or more. The spent filters are
considered hazardous waste and need to be managed accordingly.
Newer parts washers that use citrus based solvents do not require
solvent removal. A system of filters keeps the solvent usable,
regardless of its age. Additional solvent is added to replace
product lost through evaporation and dragout.
4.2.4 Staged Cleaning
Cleaning can be done in stages to minimize the use of hazardous
solvents. For example, a non-hazardous solvent can be used for
basic cleaning and the chlorinated solvent used only to remove the
residue from the non-hazardous solvent left on the part. This
works well when it is important that no residue remains on the
part.
4.2.5 Quality Standards
Quality standards for cleaning non-electrical parts are generally
lacking, except for the philosophy that -most parts require
precision cleaning. Over-cleaning is not' necessary and simply
increases the use of solvents and the generation of waste products.
Cleaning standards should be set for all parts, and the part'
cleaned to meet that standard.
4.2.6 On-Site Distillation
Small distillation units are commercially available and offer the
possibility of on-site recycling of spent solvents.
4.2.7 Product Consolidation
Minimizing the different types of solvents used at a facility will
promote recycling by maintaining waste stream integrity. As
previously mentioned, TCE is a contaminant in a recycled solvent
that is not formulated with TCE. By minimizing solvent types such
contamination can be.prevented.
4.2.8 Work Practices
Certain work practices can minimize solvent use. Examples are as
follows:
If solvent is first sprayed on a rag and then the rag
used to clean a part, less solvent is used than if
applied directly to the part;
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Cleaning operations can be consolidated to minimize vapor
loss, additionally, all solvents should be covered when
not in use;
For dip tanks, increasing the drain time for parts
reduces drag-out loss;
Do not cross contaminate solvents;
Use dirty solvents' for initial cleaning and clean solvent
for the final cleaning;
4.3 LUBRICATION GREASES
4.3.1 Mobile Vehicles
Lubricating greases for mobile vehicles at mining operations are
not usually an identifiable and quantifiable waste stream. It
appears that the best opportunities for waste minimization focus on
good maintenance and sealed units that minimize the loss of greases
during vehicle operation. High performance synthetic oils that
have longer molecular chains and retain their molecular structure
under wear may also minimize.loss.
4.3.2 Shovels and Draglines
Most mines recognize the large volume of waste grease that is
generated by shovels and draglines and are making efforts to reduce
waste generation, especially the generation of hazardous wastes.
At the present time, product substitution appears to be the common
approach to hazardous waste minimization.
Open Gear Compound
Most mining operations have moved away from TCE additives in open
gear compounds, which makes them a hazardous waste, to
biodegradable additives. Once the switch is made to a non-
hazardous grease, it takes an average of 12 to 24 months to purge
the system of the hazardous grease, and during the purging process
hazardous waste is generated. A thorough cleaning of the various
types of open gears immediately prior to changing to non-hazardous
compounds may decrease the purge time. Another waste minimization
technique during purging is to separate the different lubricants
rather than placing all lubricants in the same container. In this
manner the non-hazardous grease is kept separate from the hazardous
greases.
When removing the hardened grease during maintenance, the grease is
placed in plastic bags and then into 55 gallon steel drums at most
mines. However, the plastic bags often clog the blending machinery
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at disposal facilities during fuel blending. Disposal companies
will soon supply a reinforced paper bag that will either partially
dissolve following placement in a steel drum or will break up
during the agitation that is part of the fuel blending process.
Most mining operations ship both their hazardous and non-hazardous
greases off-site for disposal, usually for energy recovery as
boiler fuel. Some mines dispose of their non-hazardous greases in
landfills located on the mine site. Although such disposal may be
legal under landfill permits, landfilling of greases is not
recommended as a desirable method of waste grease disposal.
It appears that for hazardous greases, pressure from the mining
industry can be an important factor in the development of
substitute, non-hazardous products. Vigorous opposition to the
hazardous solvent . additives in open gear compounds and other
machine greases is important in convincing suppliers to invest the
funds necessary for non-hazardous substitutes.
In some cases, draglines and shovels can be retrofitted with
lubricating systems that are less wasteful or do not require
hazardous lubricants. For example, swing cases can be retrofitted
to a gear oil spray and bath system (buck lubrication system) that
lubricates and cools the gear mesh. Oil requires changing only
once every 3 to 4 years, rather than the annual change on older
machines. Where there is potential to substantially reduce waste
generation by retrofitting, cost of retrofitting must be justified
on more factors than reduced waste disposal costs.
Good maintenance of the open gear components and other components
that require lubrication is essential in minimizing waste
generation for shovels and draglines. Poor maintenance for
lubrication systems can greatly increase the grease use, especially
with pressure injector systems that either leak or never fully shut
off. Record keeping is essential to detect such problems.
Extreme Pressure Greases
As previously mentioned, some EP greases contain lead. While
leaded EP greases are. being phased out at most mines, leaded
lubricants can be very difficult to purge and several years are
often required.
Wire Rope Lubricants
In theory, wire rope lubricants could be substantially reduced by
applying only what is needed for lubrication. However, there is
considerable debate as to how much is really needed, and until that
debate is resolved through research, some machine operators will
continue to use copious amounts of wire rope lubricants. Other
than the cost of this lubricant, there is little incentive for
waste minimization because the spent rope lubricant is not
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recovered. However, some mines steam clean the dragline booms on
an annual basis due to the accumulated wire rope lubricant that
creates a safety hazard for anyone on the boom.
With the exception of the pennant lines that do not move,
replacement of the standard wire rope on shovels with plastic
valley wire rope can greatly decrease the need for rope
lubrication. Although the plastic valley rope is more expensive,
it usually lasts longer than the standard rope.
It appears possible to utilize used oil as a wire rope lubricant.
If the acidity of the used oil is above 7.0 and if the oil is
filtered, it can be sprayed on the wire ropes. However, used oil
does not contain extreme pressure additives required for hoist
ropes. During experimental application at a mining operation, wire
rope life was not adversely affected by application of used oil,
especially when external lubrication, rather than internal, was the
goal. However, used oil must be carefully filtered to remove all
particles that could plug the lubrication system. In addition,
warranty requirements may preclude the use of used oil as a rope
lubricant at the present time.
Cam and Slide Lubricants
Substitution to a. non-hazardous lubricant has proven difficult,
especially in machines with the Monigham cam. During cold weather,
a replacement for the TCE additive that will give proper flow
characteristics has yet to be formulated. However, some mines not;
using the Monigham cam have made successful conversions to non-
hazardous cam and slide lubricants. Purging the hazardous
lubricants from the system often takes 12 months or longer.
Other Lubricants
As with other machine components, timely maintenance that includes
lubricant recovery regardless of where it occurs and how difficult
it is to dig out can substantially increase the lubricant recovery
rate. Replacement of worn parts and conversion to alternate
lubrication systems can significantly reduce waste generation.
29
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4.4 SPENT VEHICLE FLUIDS AMD ACCESSORIES
4.4.1 Used Oil
Large volumes of used oil, including hydraulic and transmission
fluids, are generated by the mines, ranging from 20,000 to 70,000
gallons per year. Due to the large volumes, several relevant
options are available for the management and waste minimization of
used oil. These options include:
On-site energy recovery;
Off-site energy recovery;
Used as a crude lubricant;
Reused as a blasting agent mixture;
On-Site Energy Recovery
Burning used oil in an on-site used oil furnace is an acceptable
management practice which reduces both disposal costs, long term
liability and also reduces heating costs. The used oil burners
must be rated at less than 500,000 British thermal units (BTU's)
per hour; the gasses from the burner must be vented to the
outdoors; and the heater is used only to burn used oil generated on
site or accepted directly from do-it-yourself oil changers.
The oil needs to meet on-rspecification used.oil requirements. The
burning of off-specification oil is acceptable provided the
provisions of 40 CFR 279, Part 279.23 and Subpart G, Part 279.61
are met. The on-specification used oil requirements are listed in
the following table.
en-Specification Used Oil
Flash Point 100 degrees Fahrenheit (minimum)
Arsenic -5 ppm (maximum)
Cadium 2 ppm (maximum)
Chromium • 10 ppm (maximum)
Lead 100 ppm (maximum)
Total Halogens 1000 ppm (maximum)
A level of halogens up to 4,000 ppm is allowed if it can be
proven that hazardous waste has not been mixed with the used
oil.
Off-specification used oil means that the oil exceeds one or more
of the specification for on-specification used oil unless the used
oil has been mixed with hazardous waste. Used oil that has been
mixed with hazardous waste is considered hazardous waste. Used oil
is considered to be of^specification unless there are laboratory
results or other documents to show it is either on-specification
used oil or hazardous waste.
30
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Used oil burners typically have a filtering stage. prior to the
burning stage. Solids filtered may exhibit RCRA toxicity or
ignitability characteristics and will need to be appropriately
handled.
The burners do have some air emissions. Hydrocarbon organics are
readily oxidized in most burners. However, particulate and
inorganic emissions may be a concern.' Used oil burners can easily
meet the Clean Air Act (CAA) requirements. Several used oil
burners offer both heating systems and hot water applications so
that year round energy recovery can be accomplished. During the
winter, the used oil can be used as a fuel for heat and during the
summer the system can be used to generate hot water for washing and
other applications. The capital costs for these systems are easily
offset by the savings on used oil shipments costs, raw fuels costs
and the reduced liabilities for off-site recycling.
Off-site Energy Recovery
Off-site energy recovery through fuel blending and supplemental
fuel programs is the most common method for used oil recycling
currently utilized by the mining industry.
Crude Lubrication
As mentioned earlier, it appears possible to utilize used oil as a
wire rope lubricant. If the acidity of the used oil is above 7.0
and the if- the oil is filtered, it can be sprayed on the wife
ropes. Wire rope life does not appear to be adversely affected by
application of used oil, especially when external lubrication,
rather than internal, was the goal. However, used oil must be
carefully filtered to remove all particulates that could plug the
lubrication system.
Blasting Agent
An excellent opportunity for waste minimization for used oil is to
reuse it as a blasting agent. However, to date the USEPA has not
approved this option.
The technology is available for replacing fuel oil with filtered
used oil (up to 50%) in producing the blasting agent ANFO. ANFO is
a mixture of ammonium nitrate and fuel oil (ANFO) and is utilized
by mining operations. Blasting engineering studies demonstrate
that a mixture of up to 80% used oil with the fuel oil does not
affect the blasting efficiency for large diameter holes.
The Mine Safety and Health Administration (MSHA) may allow the use
of used oil as a partial substitute for fuel oil in the ANFO
blasting agent provided a petition for modification allowing its
use is granted by MSHA. MSHA requirements may include:
31
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Only petroleum-based lubrication oil recycled from
equipment at the mine shall be used for the purpose of
blending with fuel oil in the creation of ANFO. The used
oil shall not contain any hazardous waste materials
including PCB's.
Used oil shall be recycled by filtering and then stored
in a storage tank 'and tested before use.
The filters used in the filtering system are usually 60
mesh and/or 100 mesh arranged in series.
Tests or analyses shall be checked for water and ethylehe
glycol.•
The blend of recycled oil and fuel oil (blended oil)
shall not exceed 50% (by volume) recycled oil.
The recycled oil shall be mixed continuously while being
blended with fuel oil.
The recycled oil and blended oil shall not be modified by
heating, adding additives (with the exception of fuel
oil), or in any other way that could change the relevant
properties of the recycled oil.
Certify compatibility with emulsion.
The used oil/fuel oil is mixed with ammonium nitrate at
the blast hole (not stored prior to use).
The MSHA has developed a "Generic Petition" which provides the more
salient information which must be addressed in a Petition for
Modification to use used oil in ANFO. The Petition for
Modification procedures are outlined in 30 CFR Part 44. The
"Generic Petition" from MSHA has been included as Appendix B.
4.4.2 Waste Filters
Most mines have stopped purchasing terne plated filters and are
currently phasing them out or have already gotten rid of all such
filters. One recycler of used filters requires the filters to be
crushed, another recycler will not accept crushed filters. Several
commercially available filter crushers are available. In addition,
several very effective filter crushers have been designed and built
from spare parts by the on-site maintenance personnel.
32
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The scrap metal recycling exemption under the Resource Conservation
and Recovery Act (RCRA) is applicable to used oil filters (scrap
metal) if they are going to be recycled. However, an undrained or
uncrushed oil filters may contain too much oil to qualify for the
scrap metal exemption. The filter may be shipped off-site for
crushing under the used oil exemption, providing the oil is
collected for recycling.
If the crushed or drained filter will be recycled, it is
unnecessary to determine whether it exhibits the TCLP toxicity
because the scrap metal exemption is applicable. It would also be
unnecessary to manifest these used oil filters. However, if the
filter will be disposed of, the generator must determine if it is
a hazardous waste.
There are various methods of gravity hot draining filters including
puncturing the filter and hot draining, hot draining arid crushing,
and dismantling and hot draining. "Hot drained" means that the
filter is drained at or near the engine operating temperature. The
length of draining necessary is not specified but 12 to 24 hours
appears to be sufficient to remove excess oil.
4.4.3 Transmission and Hydraulic Fluids
Transmission and hydraulic fluids are not typically segregated but
are blended with used oil. This mixture can then be recycled off-
s.ite, used for energy recovery in used oil furnaces or used as a
supplement to the fuel oil requirement for the ANFO blasting agent.
Most mining operations drain the oil, transmission and hydraulic
fluids on predetermined preventative maintenance schedules. For
instance, haul trucks may be scheduled to change their engine oil,
hydraulic and brake/steering fluids after 250 hours of use. A
large 240 ton haul truck has a 55 gallon capacity for oil, 23T)
gallons of hydraulic fluids and a 65 gallon capacity on the
brake/steering system. One mine has determined this is unnecessary
and has started a new procedure where they remove the fluid filter
it, analyze it for metals, viscosity and other critical parameters
to check for wear, and replace it in the units. This mine has not
drained these fluids from the vehicles for over one (1) year. This
procedure is termed "predictive maintenance", which greatly reduces
waste generation over the conventional "preventive maintenance"
procedures. Several commercial laboratories are available which
provide analytical services for "predictive maintenance" programs.
A Predictive Maintenance Laboratory Analyses Form is included in
Appendix C.
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4.4.4 Antifreeze
The recyclers typically utilize a fractional distillation unit as
opposed to a staged filter system. Most of the other mines utilize
off-site recyclers. Antifreeze can easily be recycled on-site with
filtration units and rust inhibitors additives.
Some mines have switched from ethylene glycol to propylene glycol,
which is less toxic and apparently can be burned at power plants.
4.4.. 5 Batteries
Most mining operations currently recycle their vehicle batteries
through existing vendors. Several other options for the
minimization of hazardous waste from the spillage of water
activated batteries include using sealed nonwater activated
batteries and/or gel filled batteries. Advantages of the sealed
batteries is that the battery can be placed in any orientation
within the equipment. This allows for greater flexibility in use.
In addition, sealed nonwater activated batteries do not emit
corrosive vapors and extend battery cable life. Some operations
have expressed concern over the gel batteries inability to hold a
"deep charge" while other contend that they can hold a "deep
charge".
4.4.6 Freon .
All operations are required to use certified mechanics to capture
and recycle refrigerants including freon.
4.5 SHOP AND VEHICLE CLEAN-UP WASTE
All mines utilize some form of floor dry to absorb minor spills and
leaks in the maintenance bays. The procedures for the spent floor
dry varies between mines and ranges from disposal at the on-site
landfill or disposal at off-site landfills.
To increase the useful life of the floor dry, a screening device
can be built which allows multiple applications of the absorbent to
insure it is utilized to its maximum potential. The used absorbent
is passed through a sieve that is placed over a container (i.e., a
used, clean.55 gallon drum). The material is allowed to dry in the
container prior to reuse. Generally the typical number of reuses
is estimated at between two and three applications. The absorbent
can then be disposed of in an appropriate manner. Care should also
be taken not to use more absorbent material than necessary.
Good housekeeping practices, such as changing leaky spigots or
valves and using extra care when changing vehicle fluids, are also
necessary to alleviate the need for the floor dry.
Another option utilized by a large fleet maintenance operation is
34
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to utilize used oil/grease absorbent as an additive with aggregate
by an asphalt plant to make new'paving material.
4.6 SOLID WASTES
4.6.1 Scrap Metal
Mines typically recycle scrap metal utilizing off-site vendors.
The scrap metal includes broken parts, cuttings from machine shops
and in some cases aluminum cans. However, additional materials
could be recycled as demonstrated by waste metal containers in
dumpsters.
4.6.2 Tires
Most of the light vehicle tires are taken back by vendors for
retreading although in some cases they are landfilled on-site.
Smaller tires can are also used for "cable trees" and aerial survey
markers.
The larger haul truck and scraper tires are typically returned to
the vendor and then given away to ranchers and farmers. The
ranchers utilize them for water troughs, wind breaks, shelter
breaks, salt troughs, etc. Most mines have no trouble getting rid
of large tires. However, some mines will not give tires away due
to potential liabilities from injury and landfills all • the used
tires generated at the mine.
Several new uses for old tires are currently being .evaluated.
Shredded tires are being used in construction projects to replace
conventional fill materials in some instances. Several examples of
where this material may be used is in road bed construction,
building constructions, and landscaping.
Shredded tires have also been incorporated into asphalt, almost
doubling the durability and lifetime of the road surface. Section
1038 of the Intermodal Surface Transportation Efficiency Act of
1991 requires states to incorporate scrap tire rubber into asphalt
used on federal highway projects by 1994. However, the cost of
this process is about twice as high as ordinary asphalt.
Shredded tires are also being used as a fuel for power plants and
cement kilns. Studies by several power plants have shown that
using shredded tires mixed with coal has actually decreased air
emissions for lead, particulate, and nitrogen oxides. The biggest
drawback to this technology is the cost of a machine to shred the
tires to a 1" X 1" size is approximately $50,000, making these
.options costly for a company simply looking to dispose of their old
tires.
35
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Using tires with extended mileage warranties is another means of
reducing waste through using fewer tires. One study of county
maintenance facilities showed that the down time and costs
necessary to change tires more than offset the cost of the
increased mileage tire.
4.6,,3 Shovel and Dragline Cable
As mentioned earlier, draglines and shovels utilize a variety of
ropes (steel cable) for the hoisting, dragging and release of the
digging bucket. These "ropes" range in thickness of 2.5" for
shovels to over 3.25" and weigh up to 40 pounds per linear foot.
Mines simply backfill the "ropes" into their backfill or on-site
landfill. The amount of rope utilized in any given year varies
among mines. The length varies from 10,000 to 25,000 yards of rope
per year per machine.
A valuable resource is being discarded and revenues could be
generated from recycling the metal ropes. Several attempts have
been made to try and recycle this material including rolling the
cable back up on spools and cutting it into smaller length for
transport. Most have met with failure; however, attempts are
continuing to find cost effective and rapid ways to cut the cables
so that recycling can be accomplished.
4.6., 4 Rags • •
Mines typically segregate solvent rags from other types. Solvent
rags; are typically drummed, tested for TCLP and handled
accordingly. If utilized for general cleanup without hazardous
solvents they are placed in a dumpster for off-site or on-site
landfilling.
Good housekeeping practices and judicious use of the towels seems
to be the best minimization options available at this time. A rag
laundry service, common to other fleet maintenance operations,
should be considered for reducing the amount of rags disposed and
the potential liability associated with solvent coated rags.
4.6.5 Paper
Some paper is recycled from computer printer areas. However, most
paper at mines is landfilled either on-site or off-site.
Additional paper and corrugated cardboard could be recycled with
little effort or up front costs.
4.6.6 Wooden Spools
Wooden spools are typically broken down and used for a variety of
uses on site or landfilled. Mines should negotiate with their wire
and cable rope vendors to take back the discarded wooden spools.
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4.7 PAINTS, STRIPPERS AMD THINKERS
4.7.1 Paints
A wide variety of options are available for the waste minimization
of paint, paint strippers and paint thinner (solvent) wastes.
These options include: inventory control, purchasing controls,
housekeeping practices, material segregation and waste exchange
Inventory Control - Rigid inventory control provides a very
effective means of source reduction at virtually no cost to the
operator. By limiting access to storage areas containing raw
materials, this forces the employee to stretch the use of raw
materials farther. This also allows the use of raw materials to be
more easily monitored.
Purchasing Control - If large quantities of materials are needed
then purchasing in bulk is warranted. However, if only minor
amounts are needed then smaller containers can be ordered.
Purchasing control also effects purchasing choices so it becomes
easier to of substitute less hazardous products.
Housekeeping Practices - Specific approaches to drum location,
materials transfer methods, leak collection, and drum transfer can
effectively limit product loss.
The potential for accidental spills and leaks is highest at the
point of transfer of thinners from bulk drum storage to process
equipment. Spigots or pumps should always be used to transfer
waste materials to storage containers. Material should never be
poured directly from drums to smaller containers.
Evaporation is a material loss that can be controlled through the
use of tight-fitting lids. The reduction of evaporation will
increase the amount of available material and result in lower
solvent purchase costs.
Mix Materials According to Need - Many operators mix fixed amounts
of materials and any materials not used for the job may be
classified as a hazardous waste and need to be disposed of
accordingly. Varying cup and can sizes could be an effective means
of source reduction in two important ways. It would limit over
mixing of paint to be used on a specific project, and decrease the
amount of solvent needed for equipment cleanup when doing spot
painting and small jobs.
Use High Transfer Efficiency Equipment - A standard piece of
equipment used to apply paint is an air spray gun. Typical
transfer efficiency is on the order of 20 to 40%. Many of the
newer spray application systems have transfer efficiencies of
greater than 65%. Since with lower efficiency more paint is
wasted, higher efficiency systems are being promoted for use.
37
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Better Operator Training - Transfer efficiency is also a function
of operator skill and training. Operators may be very skilled at
producing high quality finishes but poorly trained in the ways of
reducing paint usage. The proper adjustment of air pressure can
increase transfer efficiency by 30 to 60 percent.
Proper Cleaning Methods - In reducing solvent use, greater
attention should be paid to the methods employed in equipment
cleaning. The practice of filling the cup with solvent, stirring
until the paint dissolves, and then repeating the procedure as
needed should be discouraged.
Recycle Solvent - Spent solvent can be recycled both on-site and
off-site. Simple on-site recycling/reclamation can be accomplished
by gravity separation. Distillation units can be installed for
recycling solvents on-site. ^Spent materials can be shipped off-
site for recycling if volumes on-site are insufficient for on-site
recovery.
Switch to Water-Based Paints and Primers - Waterborne products
reduce VOC emissions. These type of paints and primers also reduce
the amount of hazardous waste due to the limited amount of solvent
in the paints. Other benefits include reduced personal health and
safety concerns due to the reduced solvent usage and the reduction
in hazardous waste from equipment cleanup.
Use High-Solids Paints - High solids paints are becoming more
readily available for surface refinishing. These products have the;
advantage of reducing VOC emission by up to 75%. However, an in-
line heater is required to reduce the viscosity of the high-solids
coatings.
Switch From Lacquer to Enamel-Based Paints - Lacquer paints may
contain 70 to 90% by volume solvent while enamels contain 55 to 75%
by volume solvent. The use of the enamel-based paints can result
in ei significant reduction of VOC emissions when compared to
lacquer based paints.
Consume Paint - All paint should be completely used up. This
applies to both paint cans and aerosol containers. Empty
containers should be drained and depressurized properly. A
hazardous waste determination must be carried out if the waste
containers are to be disposed. A better alternative is to recycle
the metal paint containers.
Waste Exchange - Excess paint and waste thinners can be listed in
waste exchange programs. Waste exchanges are clearinghouse
organizations that manage or arrange the transfer of waste between
companies/industries. Excess paint can be donated to low income
housing projects, orphanages, parks and recreation departments,
etc. This provides them with a needed raw product, reduces the
disposal costs for the company and improves public relations.
38
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Segregate Materials - Excess paint, stripping solvents and thihners
should be segregated in separate waste containers dependent on
waste type. Combining leftover paint into a solvent/thinner waste
container will further contaminate the quality of the
recyclable/reusable material. Waste segregation is an inexpensive
alternative to mixing waste and therefore, decreases disposal
costs.
4.7.2 Paint Strippers and Thinners
Many of the waste minimization techniques listed above are also
applicable to paint strippers and thinners. Several alternatives
to traditional solvent/chemical paint stripping are now available.
In addition,. gravity separation, distillation, and plastic media
blasting may also be applicable for some operations.
Gravity Separation - The least expensive method used on-site is
gravity separation. Gravity separation allows the paint solids and
sludge to settle to the bottom of the accumulating container while
the "cleaner" solvent and/or stripper remains on top. The "clean"
solvent/stripper can then be reused by removal from the top.
Distillation - For large quantity generators, on-site distillation
may prove to be a cost effective alternative. Distillation yields
higher grade thinner for reuse than gravity separation. Reclaimed
thinner may be used for washing parts and for formulating primers
and base coats.
Plastic Media Blasting - Plastic media blasting (PMB) utilizes the
concept of sand blasting with the substitution of a plastic for the
sand. Paint stripping by PMB is a promising alternative to solvent
stripping and is being widely utilized by the Department of Defense
for removing paint from aircraft. The spent plastic can be
separated from the paint chips and be recycled. The process does
produce a small amount of waste (dry paint) but solvents and rinse
water are completely eliminated.
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5.0 SUMMARY AMD CONCLUSIONS
Many options are available to the mining industry for minimizing
waste from equipment and fleet maintenance operations. Several of
the more common waste minimization techniques have been reviewed in
this document. However, many others are available with more being
continually developed.
Several mining operations have initiated innovative waste
minimization programs. Several of these include:
• Product Substitution - Switch from chlorinated or low
flash point (FP) solvents to higher FP solvents, citrus
based solvents, or industrial parts washers which utilize
hot water and biodegradable soap.
• Product Reformulation - Reformulation of the dragline and
shovel grease by several vendors has resulted in a non-
hazardous waste grease due to the elimination of the TCE
in these formulations. However, it will take
approximately one year to purge the "old" greases out of
the machinery.
• . Purchasing and Inventory controls - Several mines have
initiated strict purchasing and inventory controls to
eliminate unwanted materials on-site.
• Vendor Contract Negotiation - Several operations have
renegotiated their contracts with various vendors to
reduce the volume of waste left on mine site. These
include: drums, wooden spools, and solvent filter
systems on solvent rinse tanks.
• New Uses - One mine has taken the initiative to work
through the problems associated with utilizing used oil
as a substitute for the ANFO blasting mixture.
The mining industry and their suppliers need to focus on additional
options for product substitution, product reformulation, reuse and
recycling. The mining industry should continue to place pressure
on their vendors to provide waste minimization options and
nonhazardous products. In addition, renegotiating contracts to
reduce the amount of waste should be a high priority within the
mining industry.
Numerous relevant reference articles are available to mining and
fleet maintenance operations. A list which includes EPA Guidance
Documents and articles on waste minimization opportunities for
absorbents, antifreeze, batteries, filters, freon,
greases/lubricants, metals, oil, paint, plastic, paint stripping,
radiators, rags/shop towels, solvents, tires, and waste water are
included in Appendix D.
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6.0 WASTE MINIMIZATION ASSESSMENT WORKSHEETS
The worksheets provided in this section are intended to assist
mining operations is systematically evaluating waste generation
processes and in identifying waste minimization opportunities.
These worksheets include only the waste manumission assessment
phase of the procedure described in the Waste Minimization
Opportunity Assessments Manual. A comprehensive waste minimization
assessment includes a planning and organizational step, an
assessment step that includes gathering background data and
information, a feasibility study on specific waste minimization
options, and an implementation phase. A list of the Waste
Minimization Assessment Worksheets included in this document are
listed below.
41
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Firm Waste Minimization Assement
Site
Date Proj. No.
WORKSHEET
la WASTE SOURCES
Shop Clean-Up
Spills Sc leaks (non-hazardous)
Spills & leaks (hazardous)
Shop rags
Absorbents
Area wash water
Clarifier sludges
Scrap metal'
Container disposal (paper/plastic)
Pipeline/tank drainage
Evaporative losses
Other
Parts Cleaning
Spent solvent cleaner
Spent carburator cleaner
Spent brake cleaner
Evaporation losses
Leaks and spills (solvents)
Spent alkaline cleaner (Diptanks)
Leaks and spills (alkali)
Rinse water discharge (parts washers)
Sludges
Filter waste
Other
Prepared 1
Checked B
Pape
Jv
V
of
•
Significance at Mine
Cost
Vol.
Haz.
• •
-------
Finn . Waste Minimization Assessment
Site
Date Proj. No.
WORKSHEET .
ib WASTE SOURCES
Maintenance Shop Wastes
Motor oil
Oil filters
Gear and lube oils
Transmission fluid
Brake fluid
Other filters
Radiator coolant
Terne plated filters
Brakes (asbestos)
Radiators (lead)
Batteries (lead & acid)
Junk parts
Tires
Other
Mining Operation Wastes
Wooden spools
Dragline cable
Dragline greases
Field solvents
Prepared
Checked!
Pape
Bv
Jv
of
Significance at Mine
Cost
Volume
• •
• •
Haz.
-------
Firm
Site
Date •
WORKSHEET
. • 2a
A. DRUMS, CONTAINERS, Al
Are drums, packages and containers in
Describe handling procedures for dam<
Waste Minimization Assessment • Prepared By
Checked By
Project Number Page of
WASTE MINIMIZATION:
Material Handling
VD PACKAGES
spected for damage before being accepted? Yes No
leed items:
•
Is there a formal personnel training prc
proper storage techniques, and waste ti
How often is training given and by wh
>gratn on raw material handling, spill prevention
andling procedures? Yes No
om?
Is obsolete raw material returned to th<
fa inventory used in first-in first-out or
Are stored items protected from dama
Is the dispensing of raw materials sup*
Are users required to return empty cor
Do you maintain and enforce a dear p
Is the inventory system computerized?
Does the current inventory control syst
What information does -the system trac
; supplier? Yes No
der? ' Yes No '
;e, contamination, or exposure to rain, snow, sun and heat? Yes No
•rvised and controlled? Yes No
itainers before being issued new supplies? Yes No
olicy of using raw materials only for their intended use? Yes No
Yes No
em adequately prevent waste generation? Yes No
k?
'
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Firm
Site
Date
WORKSHEET
2b
Waste Minimization Assessment
Project Number
WASTE MINIMIZATION:
Material Handling
Prepared By
Checked By
Page of
B. BULK LIQUIDS HANDLING
What safeguards are in place to prevent spills and avoid ground contamination during the filling of storage tanks?
High level shutdown /alarm ___ Secondary containment ___
Flow totalizers with cutoff ___ Other __
Describe the system:
•
Are all storage tanks routinely monitored for leaks? If yes, describe procedure and monitoring frequency for above-
ground /vaulted tanks: •
•
• . .
Underground tanks:
•
How are the liquids in these tanks dispensed to the users? (i.e., in small containers 01
hard piped.)
What measures are employed to prevei
it the spillage of liquids being dispensed?
When a spill of liquid occurs in the fac
in which the resulting wastes are hand
ility, what cleanup methods are employed (e.g., wet or dry?) Also discuss the way
ed:
•
-------
Finn
Site
Date
.Waste Minimization Assessment
Project Number
Prepared By
Checked By
Page of
WORKSHEET MINIMIZATION OPTIONS:
, 3 Material Handling
Meeting Participants
Suggested Waste Minimization Options
A. Drums, Containers, and Packages
Raw Material Inspection
Proper Storage/Handling
Return Obsolete Material to Supplier
Minimize Inventory
Computerize Inventory
Formal Training
Waste Segregation
B. Bulk Liquids Handling
High Level Shutdown/Alarm
Flow Totalizers with Cutoff
Secondary Containment
Air Emission Control
Leak Monitoring
Currently Done Yes/No?
•
Rationale/Remarks or Options
• •
-------
Firm Waste Minimization Assessment
Site
Date Project Number
WORKSHEET WASTE MINIMIZATION:
4a Parts Cleaning
A. SOLVENTS
Do you. use parts cleaning solvent for uses other than cleaning parts?
Have you established guidelines as to when parts should be cleaned with solvents?
Do you use solvent sinks instead of pails or dunk buckets?
Are solvents sinks and/or buckets located near service bays?
Do you allow cleaned parts to drain inside the sink for a few minutes to minimize
dripping of residual solvent onto the shop floor?
Are you careful when immersing and removing parts from the solvent bath so as not
Do you keep all solvent sinks/buckets covered when not in use?
Do you lease your solvent sinks?
If yes, does your lease include solvent supply and spent solvent waste handling?
Have you installed filters on solvent sinks?
Prepared By
Checked By
Page of
Yes
Yes
Yes
Yes
Yes
to create splashes? Yes
Yes
Yes
Yes
Yes
If you own your solvent sinks, does a registered waste hauler collect your dirty solvent for
recycling or treatment? Yes
Does the current inventory control system adequately prevent waste generation?
Do you own on-site solvent recovery equipment such as a distillation unit?
If yes, how are the solvent residues handled
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
What other methods are you using to reduce solvent use/waste?
B. AQUEOUS CLEANERS
Do you use dry pre-deaning methods such as baking and/or wire brushing to reduce loading
on the aqueous cleaner? Yes
Have you switched from caustic-based cleaning solutions to detergent-based cleaners? Yes
Do you use drip trays on hot tanks to minimize the amount of cleaner dripped on the floor? Yes
No
No
No
-------
Firm
SiteJ
Date"
Waste Minimization Assessment
Project Number _________
Prepared By
Checked By _____
Page of
WORKSHEET
4b
WASTE MINIMIZATION:
Waste Handling
B. AQUEOUS CLEANERS (continued)
Are the hot tanks/jet spray washers located near the service bays?
Do you pre-rinse dirty engine parts in a tank of dirty cleaning solution so
as to reduce loading on the clean tank??
Do you routinely monitor solution composition and make adjustment accordingly?
Do you routinely remove sludge and solids from the tank?
Are sludge and solids screened out before they reach the waste sump?
Have you installed still rinses or converted free running rinses to still rinses? (Spent rinse
water cna be used as make-up to your cleaner bath if you use deminerali/ed water.)
Is your cleaning tank agitated?
If yes, do you use mechanical agitation instead of air agitation?
Do you lease your hot tank(s)/jet spray washer(s)?
Do you own your hot tanks/jet spray washer(s)?
Do you own on-site aqueous waste treatment equipment?
Does a hazardous waste hauler collect aqueous waste for recycling or treatment?
If not, how is your waste handled and disposed of?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
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Finn
Site
Date
Waste Minimization Assessment
Project Number
1 Prepared By
Checked By
Sheet of Pare of
WORKSHEET OPTION GENERATIONS:
5 Parts Cleaning
Meeting Format (e.g., brainstorming, nomii
Meeting Coordinator
lal group technique)
•
Meeting Participants
Suggested Waste Minimization Options
A. Solvents
Proper solvent use
Established guidelines
Use solvent sinks
Careful drainage
Cover tanks
Lease equipment/service
Recycle solvent
•
B. Aqueous Cleaners
Dry pre-cleaning
Use detergents
Drip trays
Pre-rinse parts
Monitor solution
Remove sludge and solids
Employ still rinse
Use demineralized water
Use mechanical agitation
Lease equipment
Currently Done Yes/No?
"
.
Rationale/Remarks or Option
v
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Finn.
Site_
Date"
Waste Minimization Assessment
Project Number
Prepared By ____
Checked By
Page of
WORKSHEET
6a
WASTE MINIMIZATION:
Waste Handling . •
ENGINE, LUBRICATING AND COOLING FLUIDS
Do you test fluid quality, including engine, lubricating and cooling fluids,
to determine when they should be changed?
When fluids must be drained either to test for wear or service a part, are
they stored in a clean container so they may be re-used?
Have you had experience using any longer lasting synthetic motor, lubricating
and cooling fluids?
If yes, please explain:
Yes No
Yes No
Yes No
Do you currently employ rigid inventory controls to minimize fluid use?
Describe: ,
Yes No
Are all waste fluids kept segregated?
If not, have you notified your waste hauler or recycler?
Have you ever had a load of waste fluid rejected by a hauler or recycler because of
cross contamination?
Please describe how you store and dispose of waste fluids (motor and lube oils,
greases, transmission fluids and spent anti-freezes). •
Yes No
Yes No
Yes No
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Firm
SiteJ
Date"
Waste Minimization Assessment
Project Number '
Prepared By
Checked By ____
Page ^^^_ of
WORKSHEET
6b
WASTE MINIMIZATION:
Waste Handling
PAINT APPLICATION (CONTINUED)
Could more rigid controls be implemented in your shop?_
Are paints mixed according to need? Is the volume of paint mixed based on the
surface area to be painted?
Have you tried high efficiency spray application equipment in your shop?
Did it reduce the amount of paint sprayed?
Did it affect finish quality?
Descri.be how you minimize overspray waste ____^^^_^^^__^^_^^__
Yes
Yes
Yes
Yes
No
No
No
No
C OTHER WASTES
Do you recycle your used batteries?
Are your used batteries stored in a warm, dry secure place?
Does a recycler or equipment leasing service collect your spent antifreeze?
Do you use a collection/recycling system to service air conditioning units?
Do you sell or give worn parts to a re-manufacturer?
Do you have any suggestions for reducing other wstes?
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
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Finn
Site
Date
Waste Minimization Assessment
Project Number
Prepared By
Checked By
Page of
WORKSHEET MINIMIZATION OPTIONS:
7 Waste Handling
Meeting Participants
Suggested Waste Minimization Options
A. Waste Oils and Coolants
Test fluid quality
Store fluids for reuse
Use longer lasting fluids'
Keep wastes segregated
Send to recyder
Predictive maintenance
Used as blasting agent
B. Paint Applications
Use rigid inventory controls
Mix smaller batches of paint
Use high-efficiency sprayer
Minimize overspray
C. OTHER WASTES
Drain filters and dispose properly
Recycle batteries
Collect/recycle refrigerant
Sell or give parts to re-manufacturer
Currently Done Yes/No?
•
. ' •
Rationale/Remarks on Option
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firm
SiteJ
Date
Waste Minimization Assessment
Project Number ___^______
Prepared By
Checked By
Page of
WORKSHEET
8
WASTE MINIMIZATION:
Material Substitution
A. ABRASIVE BLASTING
Is the blasting media used in the shop considered hazardous (e.g., lead shot)?
If so, can other lesser/non-hazardous materials be substituted? (e.g. plastic media)
Describe results of any substitution attempts:
Are dust suppression collection systems employed during abrasive blasting?
Is this dust collectected and recycled or reused??
Would the installation of a dust collection system allow for reuse?
Explain how blasting dusts are handled and the potential for reuse:
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
B.
CHEMICAL STRIPPING
Are any chemical stripping agents used in the shops considered hazardous
(e.g. chlorinated solvents)?
If so, can other non-hazardous materials substitute for the hazardous materials?
Yes
Yes
No
No
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Firm
Site
Date
Waste Minimization Assessment
Project Nurriber
Prepared By
Checked By
Page of
WORKSHEET MINIMIZATION OPTION:
9 Material Substitution
Meeting Participants
Suggested Waste Minimization Options
A. Paint Removal
Blasting media substitution
Substitute blasting for chemical stripping
Less hazardous strippers
B. Painting Operation
Use low VOC paints
Use less, toxic paints
Maximize use of water based paints
Currently Done Yes/No?
•
.
Rationale/ Remarks on Option
•
.
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Finn Waste Minimization Assessment
Site ' '
Date Project Number
WORKSHEET WASTE MINIMIZATION:
10 Good Operating Practices
Prepared By
Checked By
Page of
A. GOOD OPERATING PRACTICES .
Are plant material balances routinely performed? _ Yes
Are they performed for each material of concern (e.g. solvent) separately? Yes
Are records kept of individual wastes with their sources of origin and eventual disposal? Yes
Are the operators provided with detailed operating manuals or instruction sets? Yes
Are all operator job functions well defined? • Yes
Are regularly scheduled training programs offered to operators? Yes
Are the employee incentive programs related to waste minimization? Yes
Does the plant have an established waste minimization program in place? Yes
If yes, is a specific person assigned to oversee the success of the program? Yes
Discuss goals of the program and -results:
No
No
No
No
No
No
No
No
No
Has a waste minimization assessment been performed at this plant in the past? If ye
s. discuss:
B. HOUSEKEEPING •
•
Are dirty parts removed and placed on a drip pan instead of directly on the shop floor? Yes
•Are all work areas kept dean and heat? Yes
Do your workers wipe up small spills of fluid as soon as they occur? Yes
Do you have an award program for workers who keep their work areas dean
(i.e., prevent leaks and spills)? . Yes
Do you use a laundry service to dean your rags and uniforms? Yes
Do you use a biodegradable detergent for deaning shop floors? Yes
Have you tried using a steam deaner in place of chemical deaners? Yes
Do you discharge area washdown wastewater to a POTW or industrial sewer,
instead of to the storm drain? ' Yes
If not, how is this waste handled?
No
No
No
No
No
No
No
No
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Firm
Site
Date
Waste Minimization Assessment
Project Number •
Prepared By
Checked By
Page of
WORKSHEET MINIMIZATION OPTIONS:
11 Good Operating Practices
Meeting Participants
Suggested Waste Minimization Options
Perform Material Balances
Keep Records of Waste Sources &
Disposition
Waste/Materials Documentation
Provide Operating Manuals/Instructions
Employee Training
Increase Plant Sanitation'
Establish Waste Minimization Policy
Set Coals for Source Reduction
Conduct Annual Assessments
Use Drip Pans
Wipe up Spills (Cotton Rags, Paper
Towels)
Keep Bays Clean
Award Program
Use Laundry Service
Use Biodegradible Detergents
Use Steam Cleaners
Discharge to POTW/Industrial Sewer
Currently Done Yes/No?
Rationale/Remarks on Option
•
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APPENDIX A
WASTE CLASSIFICATION AND HANDLING FORM
WASTE CLASSIFICATION
Aerosol cans
Antifreeze (glycol)
Asbestos components
Empty containers
Equipment batteries
Equipment tires
Filters (engine oil)
Filters (gasoline)
Filters (terne plated)
Filters (other)
Floor dry - absorbent
Freon recycling (air conditioning)
Ignitable (flammable) liquids
Rags (hazardous)
Rags (other)
Scrap metal
Sludge - maintenance/lube bay
Sludge - wash bay
Solvent - combustible
Solvent - ignitable
Trash (miscellaneous)
Used grease (non-chlorinated)
Used grease (chlorinated)
Used oil
Used paint
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AEROSOL CANS
Regulation
Procedure
Storage
Label
Disposal
NOTE
Pressure and contents are hazardous
Review HSDS for hazardous ingredients
Separate by characteristics
Puncture cans - chemical specific
Drain fluid into lined DOT approved drums
Label drum "Hazardous Waste - Flammable"
Label drum "Hazardous Waste - Oxidizer"
Label drum "Hazardous Waste - ???"
Place drained, punctured cans in dumpster
TCLP drum residue and incinerate
NOT FOR USE WITH HERBICIDES OR PESTICIDES!
Regulation
Procedure
Storage
Label
Disposal
Records
NOTE
ANTIFREEZE (GLYCOL1
Used antifreeze may contain TCLP metals, sinks
into groundwater (Specific Gravity > 1)
Regulations are vague
Recycling encouraged
Accumulate quantity for TCLP testing
TCLP mandatory before you recycle
Store in used antifreeze tank
Label tank "Used Antifreeze"
Recycle if passing TCLP
Incinerate if failing TCLP
Maintain accumulation and recycling records
SLUDGE GENERATED DURING RECYCLING?
GLYCOL WILL BE REGULATED UNDER CLEAN AIR ACT
Regulations
Procedure
Storage
Label
Disposal
Records
NOTE
ASBESTOS COMPONENTS
Asbestos and PCB's are TSCA regulated wastes
Review MSDS for asbestos content/structure
Check old haul truck grid resisters
Wrap components in plastic bags
Place in a covered DOT approved drum
Label drum "Hazardous Waste"
Label drum "Non-Friable Asbestos"
Permitted Landfill Only!
Maintain accumulation and disposal records
FOLLOW TSCA DISPOSAL PROCEDURE!
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EMPTY CONTAINERS
Regulation
Procedure
Storage
Disposal
Records
NOTE
EPA allows burial of "empty" containers - inc.
barrels, cans, aerosols, and misc. containers
Maximize use of recyclable containers
Empty containers by commonly employed means, i.e.
turning upside down
If viscous material is present, may not contain
more than 1" in bottom of container.
Store recyclable containers in warehouse yard
Place nonrecyclable drums in solid waste cell
Return recyclable containers to vendor
Crush empty drums and bury in solid waste cell
Maintain recycling, disposal, and surveyed
location records
MAXIMIZE USE OF RECYCLABLE CONTAINERS
Regulation
Procedure
Storage
Label '
Disposal
Records
NOTE
EQUIPMENT BATTERIES
Used batteries are regulated as hazardous waste
if not exchanged or recycled
Return used battery to vendor
Store used batteries in warm, protected areas
Use exact wording "Wet battery returned for
regeneration or reclamation"
Obtain signed receipt from vendor-
Maintain records of battery transfer to vendor
AVOID USING WORDING "DISPOSAL1*
Regulation
Procedure
Storage
Label
Disposal
Records
NOTE
EQUIPMENT TIRES
State law mandates proper disposal or recycling
If onsite, in approved solid waste cell
State also allows stock troughs and personal
wind breaks only
Contact engineering for appropriate location
Accumulate for disposal - minimize solid waste
cell disposal
None
Bury or alternate use - determine postmine
surface restrictions
Maintain recycling and disposal records
AVOID OFFSITE DISPOSAL LIABILITY
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FILTERS (ENGINE OIL)
Regulation - EPA allows disposal of hot, gravity drained
engine oil filters
- Recycling is recommended disposal method
Procedure - Review MSDS for lead content/structure
- If filter is terne plated - recycle (see below)
- Hot gravity drain filter, then crush if
appropriate
Storage - Place in a covered DOT approved drum
Disposal - Recycle, landfill, or bury in solid waste cell
Records - Maintain recycling and disposal records
NOTE - ONLY ENGINE OIL FILTERS ARE EXEMPT
FILTERS (GASOLINE)
Regulation - Gasoline filters are hazardous waste and are not
recyclable
Procedure - Drain filter for 24 hours - do not crush
- Assume TCLP fails flammability/benzene
Storage - Place in a covered DOT approved drum
Label - Label drum "Hazardous Waste"
Disposal - Dispose of as hazardous waste (D001 & D018)
Records - Maintain accumulation and disposal records
NOTE - GASOLINE FILTERS ARE NOT RECYCLABLE
FILTERS (TERNE PLATED)
Regulation - Lead plated (terne) filters are recyclable
- If not recycled, they must be managed as
hazardous waste
- Coolant, lube, fuel, hydraulic, or air filters
Procedure - Manufacturer should identify potential filters
- Hot gravity drain filter and crush
Storage - Place in a covered, DOT approved drum
Label - Label drum "Used Oil Filters"
Disposal - Recycle through reputable facility
Records - Maintain recycling records
FILTERS (OTHER)
Regulation - Only non-terne engine oil filters are disposable
- Recycle all others filters, i.e. coolant,
hydraulic, diesel fuel, terne filters
Procedure - Hot gravity drain filter and crush (if
appropriate)
Storage - Place in a covered DOT approved drum
Label - Label drums "Used Oil Filters"
Disposal - Recycle
Records - Maintain recycling records
NOTE ' - ONLY ENGINE OIL FILTERS ARE EXEMPT
-------
FLOOR DRY - ABSORBENT
Regulation
Procedure
Label
Disposal
Records
NOTE
Regulation
Procedure
Labels
Storage
Disposal
Records
NOTE
Regulation
Procedure
Storage
Label
Disposal
Records
Regulation
Procedure
Storage
Labels
Disposal
Records
Contaminated material passing TCLP criteria
Contains non-hazardous solvents, oils, greases
If material fails TCLP or is used to clean up
hazardous materials, it must be managed as
hazardous waste
Separate from contaminated material
None required
Place land treatment area, TPH test, and aerate
When TPH acceptable, place in solid waste cell
Maintain test and treatment records
LAND TREATMENT PERMIT MAY BE REQUIRED
FRBON RECYCLING
Chlorofluorocarbons regulated under Clean Air Act
Only off road units are exempt
Mandatory ASE or MACS training
Specific requirements for recycling unit
Specified recovery units
None - recycle
Maintain training records/unit specifications
Certificate of Compliance
UNIT IN PLACE BY 1992, COMPLIANCE BY 1993
IGNITABLB (FLAMMABLE) LIQUIDS
RCRA Ignitable liquids (<140 °F) hazardous
Review MSDS for hazardous ingredients
TCLP for characteristics
Keep separate from non-flammable liquids
Place in a covered DOT approved drum
Label drum "Hazardous Waste - Flammable"
Dispose of as hazardous waste
Maintain accumulation and disposal records
RAGS (HAZARDOUS)
Contaminated rags may fail TCLP criteria or may
be listed hazardous waste
Flammable or chlorinated solvent residue
Review MSDS for contaminants
Separate from non-flammable rags
Separate from non-chlorinated rags
TCLP to determine hazardous characteristics
Place in a covered DOT approved drum
Label two drums "Hazardous Waste"
Label both drums "Flammable"
Label one drum "Chlorinated Solvent"
Hazardous waste facility
Maintain.accumulation and'disposal records
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RAGS (OTHER)
Regulation
Procedure
Labels
Disposal
Records
Regulation
Procedure
Labels
Disposal
Records
Regulation
Procedure
Storage
Label
Disposal
Records
MOTE
Application
Procedure
Storage
Label
Disposal
Records
NOTE
Contaminated rags passing TCLP criteria
Non-hazardous solvents, oils, greases
Review USDS for contaminants
Separate from contaminated rags
None required
Discard to dumpster or solid waste cell
Maintain solid waste cell disposal records
SCRAP METAL
Solid waste disposal
Collect for salvage or disposal
None required
Recycle for beneficial use
Discard to dumpster or solid waste cell
Maintain disposal and/or recycling records
SLUDGE - MAINTENANCE/LUBE BAY
Sludge from maintenance areas may contain
groundwater pollutants (antifreeze, oils)
Inspect vacuum truck for contamination
Vacuum sludge residue from waste oil separators
and floor drains
None
None required
Place land treatment area, TPH test, and aerate
Test until TPH acceptable and place in solid
waste cell
Maintain test.and treatment records
LAND TREATMENT PERMIT MAY BE REQUIRED
SLUDGES REQUIRE A HAZARDOUS WASTE DETERMINATION.
SLUDGES MAY FAIL A TCLP OR CONTAIN LISTED
SOLVENTS. IF SO, THEY MUST BE MANAGED AS
HAZARDOUS WASTE.
SLUDGE - WASH BAY
Sludge from equipment washdown may contain oil
Inspect vacuum truck for contamination
Vacuum sludge residue from sediment trap
None
None required
Periodically test for TPH content
If acceptable, discharge anywhere
If unacceptable, place in approved land treatment
area and aerate
Maintain test and treatment records
SEE NOTE ABOVE
-------
SOLVENT - COMBUSTIBLE
Regulation. - Untested solvents are assumed hazardous
Procedure - Review MSDS for hazardous ingredients
- TCLP for characteristics
- Passing - mix with used oil
- Failing - treat as hazardous waste
Storage - Place in a covered DOT approved drum
Label - Label drum "Hazardous Waste"
- Label drum with other TCLP characteristics
Disposal - Recycle through tolling agreement or dispose of
as hazardous waste (TCLP)
Records - Maintain accumulation and disposal records
SOLVENTS - IGNITABLB
Regulation - RCRA Ignitable liquids - flash point <140 °F are
hazardous waste
Procedure - Review MSDS for hazardous ingredients
- TCLP for characteristics
Storage - Place in a covered DOT approved drum
Label - Label drum "Hazardous Waste"
- Label drum with other TCLP characteristics
Disposal - Recycle through tolling agreement or dispose of
'as hazardous waste (TCLP)
Records - Maintain accumulation and disposal records
NOTE - REMEMBER, TO MINIMIZE SOLVENT USAGE, "SPRAY THE
RAG - NOT THE PART"
TRASH (MISCELLANEOUS)
Regulation - Solid waste disposal
Procedure - Separate from other listed waste
Storage - Place in dumpster or.drum
Label - none
Disposal - County landfill or solid waste cell
Records - Maintain accumulation and disposal records
NOTE - MAINTAIN WASTE CELL TO MINIMIZE LITTER
USED GREASE (NON-CHLORINATED)
Regulation - Non-flammable, non-chlorinated grease will be
regulated as "used oil"
Procedure - Review MSDS for hazardous ingredients
- Confirm with a Specification Oil Analysis
- Collect for energy recovery / no deris
- Separate by product
Storage - Place in a covered DOT approved drum
Label - Label "Used Oil"
Disposal - Use for energy recovery
-------
USED GREASE (CHLORINATED)
Regulation
Procedure
Storage
Label
Disposal
Records
Unmixed chlorinated grease may be regulated as
"off-specification used fuel oil"
Review MSDS for hazardous ingredients
Confirm with a Specification Oil analysis
Collect for energy recovery / no deris
Separate by product
Place in covered DOT approved drums
Label "Off-Specification Used Fuel Oil"
Ship as boiler fuel for energy recovery
Maintain accumulation and disposal records
Regulation
Procedure
Storage
Label
Disposal
Records
NOTE
USED OIL
Special regulations apply for used oil
Flashpoint > 100 °F, otherwise may be hazardous
waste
Must contain <1000 ppm total halogens, otherwise
may.be hazardous waste
If between 1000 ppm - 4000 ppm total halogens,
must be able to prove oil was not mixed with a
hazardous waste, otherwise hazardous waste
Review MSDS for hazardous ingredients
Periodically re-verify Specification Oil Analysis
Test
Pump directly into bulk storage tank(s)
Above ground waste oil tanks/drums
Label containers "Used Oil" or "Off-Specification
Used Oil Fuel"
Consume through used oil heaters
Ship to approved facility with licensed
transporter
Maintain consumption and recycling records
DO NOT REFER TO AS "WASTE OIL"
AVOID/MINIMIZE OFFSITE DISPOSAL TO REDUCE
LIABILITY
SPECIAL REGULATIONS APPLY FOR'OFF-SPECIFICATION
OIL
NEVER MIX WITH HAZARDOUS LIQUIDS
-------
USED PAINT
Regulation - Used paints may be RCRA regulated, including oil,
latex, and lead based paints
Procedure - Consume through beneficial use if possible
- Spray paint - use AEROSOL CAN DISPOSAL
- Review HSDS for hazardous ingredients
- TCLP for characteristics if necessary
Storage - Separate unused paint by characteristics and
store in DOT drums
Label - Latex based - "Non-Hazardous Waste"
- Lead based - "Hazardous Waste - Lead"
- Oil based - "Hazardous Waste -. Flammable"
Disposal * - Latex based - solidify and landfill
- Lead based - licensed industrial boiler
- Oil based - licensed industrial boiler
HOTS - REVIEW REGULATION FOR DISPOSAL
-------
APPENDIX B
GENERIC .PETITION
30 CFR 77.1304 (a)
30 CFR 56.6309 (b)
1. Only petroleum-based lubrication oil, which is recycled from
equipment at the Mine shall be used for the
purpose of blending with fuel oil in the creation of ANFO.
The oil shall not contain any hazardous waste material listed
in Subpart D, Title 40 Code of Federal Regulations 261.
Provisions shall be in place to ensure that the used oil is
not contaminated with PCB's.
2. The used oil shall be recycled by filtering and then storing
in a storage tank used exclusively for this purpose. The
contents of the storage tank shall, after testing and meeting
specifications as provided in item 4 below, be considered a
batch and no additional oil or other products, with the
exception of diesel fuel, shall be added until the contents of
the t'ank have been fully depleted.
3. Filters used in the filtering system shall be capable of
filtering particles down to at least 150 microns. These
filters shall be 'cleaned/replaced on a regularly scheduled
basis and whenever the filter becomes clogged to the extent
that a pressure differential of 50 psi exists across the
filter inlet and outlet. A bypass system should be designed
into the pump or piping network such that no used oil is
allowed to be transferred into the blend tank by passing
through a filter which has a pressure differential of 50 psi
or more across the filter inlet and outlet. Records,
including 'the dates, of all filter cleaning/replacing
activities shall be kept on the mine property and made
available to MSHA upon request for a period of at least three
years.
4. Tests of analyses shall be conducted on each storage tank of
• recycled oil after the entire contents of the storage tank are
thoroughly mixed and before blending with fuel oil to ensure
that the used oil meets the following specifications:
(1) Arsenic 5 ppm maximum
(2) Cadmium 2 ppm maximum
(3) Chromium 10 ppm maximum
(4) Lead. 100 ppm maximum
(5) Total Halogens 1,000 ppm maximum
(6) Flash point 100 F minimum
These specifications were derived from Table 1 in 40 CFR
279.11.
-------
Flash point shall be verified using an open cup ASTM test.
Any test result on the contents of the storage tank which is
outside these.specifications shall have the contents retested
immediately. Any two consecutive test results on the same
contents of a storage tank which is outside these
specifications shall be reported to MSHA, and the contents of
the storage tank shall not be blended with diesel fuel for use
in making ANFO unless prior authorization is obtained from
MSHA. The contents of the storage tank shall be considered a
batch of recycled oil after it is proven to be within these
specifications. Prior to filtering the oil in the storage
tank, the oil shall be considered "used oil".
The frequency of testing and analyses for these specifications
may be reduced upon the adequate submittal of records to the
MSHA District Manager showing a demonstrated record of meeting
the specifications, and a written authorization from the MSHA
District Manager allowing the reduction in testing frequency.
5. The recycled oil shall be checked for water and ethylene
glycol prior to blending with diesel fuel. If significant
concentrations are obtained, they shall be drained from the
batch prior to blending.
High viscosity oils of 90W or above shall be restricted. to
less than 10 percent of the total quantity 'of recycled oil in
the storage tank.
6. The blend of recycled oil and diesel fuel (hereinafter called
blended oil) shall not exceed 50 percent (by volume) recycled
oil. An absorption test on the recycled oil shall be
performed prior to blending with fuel oil to determine the
proper mixing ratio.
7. The recycled oil shall be mixed continuously while being
blended with diesel fuel. Mixing shall ensure recirculation
of at least three times the total volume of diesel fuel and
recycled oil.
The blending date, blend mix ratio of diesel fuel to recycled
oil for each batch, and the quantity in gallons of each
ingredient in the blended oil batch shall be recorded. The
gallons of each grade of diesel fuel shall also be recorded.
These records shall be maintained at the mine property and
made available to MSHA upon request for at least three years.
8. The recycled oil and blended oil shall not be modified by
heating, adding additives (with the exception of diesel fuel),
or in any other way that could change the relevant properties
of the recycled oil.
9. The blended oil shall be remixed within .24 hours of beir *
drawn into any bulk mixing "vehicle. This remixing she
-------
recirculate at least 25 percent of the total volume of blended
oil remaining in the storage tank. Mixing procedures shall
ensure that two consecutive viscosity samples, taken at least
5 minutes apart, are within 10 percent of each other before
loading into the bulk mixing vehicle.
10. Each new batch of blended oil shall be tested for the
sensitivity of the blended oil and ammonium nitrate prills to
a No. 8 strength detonator prior to their loading in any
holes. For each new batch of blended oil, this test shall be
performed on at least 3 samples, each having minimum
dimensions of 3-3/8" in diameter and 6-3/8" long. Each
detonator shall be placed near the center of each sample.
Each sample container must be non-rigid, such as paper
products, to minimize confining effects upon initiation.
Records of whether or not each sample detonated shall be
maintained on the mine property and made available to MSHA
upon request for at least 3 years.
11. When low temperatures cause the blended oil to become too
viscous for proper absorption (at least 6 percent fuel by
weight) in the ammonium nitrate prills, use of the blended oil
shall be suspended. Viscosity tests and absorption tests at
various temperatures may be performed to obtain their
correlation with temperature. Once these correlations are
obtained, field viscosity tests of the blended oil, at
temperatures which are the same or below the temperature at
which the holes are to be loaded, can be performed to verify
proper absorption.
In the event proper absorption cannot be obtained as a result
of high viscosity, additional diesel fuel may be added to the
blended oil and thoroughly mixed. However, records of the
blend date, blend mix ratio, and quantity of each ingredient
as required by item 8 shall be maintained and made available
for inspection by MSHA for at least three years. Retesting
for sensitivity to a No. 8 blasting cap, as specified in item
10, shall not be required for this new blend.
12. The blended oil shall be transported and used in a closed
system which prevents skin contact, inhalation of vapors, and
ingestion of the ANFO products.
13. Blasting records for each shot employing the blended oil shall
be maintained and identified as a specific blended oil batch.
The records shall include the date(s) of loading and blasting,
weather conditions, type of initiation system(s), primer
type(s) and size(s) , size and depth of all borehole (s) , number
and location within the shot of all borehole (s) and all
misfires, quantities of ANFO used in the shot, and quantities
as well as type, of emulsions (heavy ANFO) employed in the
shot. The use of any plastic hole liners shall also be
recorded. These records shall be maintained on the mine
property and made available .to MSHA upon request for at least
-------
3 years.
14. Misfires which are reasonably suspected to have been caused by
the blended oil shall be reported to the MSHA District Manager
immediately.
15. Material Safety Data Sheets for the recycled oil and diesel
fuels shall be maintained on the mine property and made
available to MSHA upon request.
16. The oil blending facility shall not be put into operation
until an on-site inspection is conducted by MSHA and detailed
drawings of the entire used oil and blending facilities,
including product flow directions, are submitted and approved
by MSHA.
17. The prill/blended oil mixture shall not be used in blasting
operations underground or in confined spaces.
18. The prill/blended oil mixture shall be used only on the
Mine property. Mixing of the blended oil
and ammonium nitrate prill is intended for immediate use in
loading holes and is not allowed to be stored as a mixed
product.
.19. A lockout system shall be provided on the oil storage tank
facilities to prevent unauthorized tampering. Only properly
trained authorized personnel shall have keys to operate the,
lockout system.
20. Within 60 days after this Proposed Decision and Order becomes
final, the Petitioner shall submit proposed revisions for its
approved 30 CFR Part 48 training plan to the District Manager.
These proposed revisions shall include initial and "refresher
training regarding compliance with the conditions stated in
the Proposed Decision and Order.
-------
Customer Report
CUSIUMhH NUMUblt
UNIT NUMBER:
PHONE NUMBER:
RECEIVED DATE:
EQUIPMENT:
SENDER-
SAMPLE FROM:
PRODUCT:
' SAE:
SAMPLE DATE:
12/19/92
PHYSICAL TESTS .
*— ^5
C/} T™
5w
46
46
46
46
46
45
46
46
2
Oiu
1 Jj|
10 0. 0 NNN
10 0. O NNN
1O O. O NNN
10 O. 0 NNN
1O O. 0 .NNN
1O O. 0. NNN
1O O. 0 NNN
10 O. 0 NNN
WEAR METAL, PPM
i 5
g fc
5 8
*
0 1
O 0
\ ° *
0 1
0 1
0 1
o 6
0 1
o
s
2
2
2
2
1
2
1
2
1 0
1 0
1 0
0 O
0 0
1 0
0 0
0 0
1 °p
1 ^
3 5>Q.
0 1
0 1
0 2
0 1
0 2
0 1
0 1
0 2
j I
0 .0
0 0
1 0
1 0
O 0
0 0
•
1 0
1 0
ADDITIVES
1 1 3
si 3
03 0 0
6 0 3986
1 O 4362
2 O 4236
4 0 3968
4 0 3776
1 0 4526
1 0 3724
1 0 4353
AND OTHER METALS, PPM
MAGNESIUM
0
O
2
12
0
7 •
O
O
Q
> UJ
0 0
2 2
0 0
0 0
0 0
1 0
0 0
0 0
0 0
0 0
PHOSPHORUS
SILVER
896 0
968 0
916 0
838 0
777 0
96O 0
771 0
94O O
5 i
3 z
0 < ^
33 0 1101
32 O 1099
32 0 1055
31 0 1119
31 0 896
32 0 1127
28 0 858
30 O 1051
RECOMMENDATIONS (CURRENT SAMPLE ONLY)
8 NORMAL FOR THIS SAMPLE. REBAMPLE AT
L INTERVAL.
TEST
OIL
DATE HOURS ADDED
042892 0 0
060492 O O
O62592 O 0
080492 0 . O
-------
APPENDIX O
ADDITIONAL WASTE MINIMIZATION ARTICLES
ABSORBENTS
1. N. C. Baker, "Sorbents Mop More, Sop Faster," Environment Today,
September 1991.
2. "Waste Management Guidance for Oil Clean-Up," Minnesota Technical
Assistance Program, July 1991.
ANTIFREEZE
1. A. R. Gavaskar, R. F. Olfenbuttel, J. A. Jones, P. R. Webb,
"Automotive and Heavy-Duty Engine Coolant Recycling by Filtration,"
Risk Reduction Engineering Laboratory, Office of Research and
Development, U. S. Environmental Protection Agency, October 1992.
2. "Managing Used Antifreeze: A Guide for Businesses," Minnesota
Pollution Control Agency, March 1992.
3. "Ethylene Glycol Antifreeze - Waste Reduction Options."
f
4. "How to Successfully Recycle Your Ethylene Glycol Antifreeze/11
Centaur Equipment Management Corporation.
5. D. Neu, Maintaining Coolant Quality to Reduce Waste," Summary,
Minnesota Technical Assistance Program, Summer 1988.
6. "Prolonging Machine Coolant Life," Fact Sheet, Minnesota Technical
Assistance Program, June 1991. . .
7. "GM Approves Use of Recycled Coolants, Automotive News Service,
November 11, 1991.
8. J. German, "Hazardous Waste Minimization: Regional Transportation
District (RTD)," Recycling and Waste Minimization, Front Range
Community College, Term Project, Spring 1992.
BATTERIES '
1. E. Cole, "Recovering Lead from Lead-Acid Battery Waste," U. S. Bureau
of Mines, Pacific Northwest Laboratory for the U. S. Department of
Energy, Innovative Concepts Program 195240.
2. "Spent Lead-Acid Batteries," Minnesota Office of Waste Management,
September 1989.
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3. "Handling and Transport of Spent Lead-Acid Batteries for Recycling/"
California Department of Health Services, Toxic Substances Control
Program, Alternative Technology Division, April 1991.
4. "Transporting Spent Lead-Acid Batteries," Minnesota Pollution Control
Agency, February 1992.
FILTERS
1. J. L. Konefes, J. A. Olson, "Motor Vehicle Oil Filter Recycling
Demonstration Project," Iowa Waste Reduction Center, University of
Northern Iowa.
2. "Managing Used Oil Filters: A Summary of Requirements for Generators
of Used Oil Filters," Minnesota Pollution Control Agency, January
1992.
FREON
1. "Motor Vehicle Air Conditioning Service," Environmental Protection
Agency.
2. ' L. Weitzman, "Evaluation of Refrigerant from Mobile Air
Conditioners," Environmental Protection Agency, Air and Energy
Engineering Research Laboratory, June 1989.
GENERAL (articles covering more than one waste stream)
1. "Waste Audit Study: Automotive Repairs," Alternative Technology
Section, Toxic Substances Control Division, California Department of
Health Services, May 1987. '
2. "Waste Audit study: Mechanical Equipment Repair Shops," Alternative
Technology Division, Toxic Substances Control Program, California
Department of Health Services, May 1990.
3. "A Proposed Treatment Standard for Non-RCRA Aqueous and Liquid
Organic Hazardous Waste," Volume 1: Technical Background, California
State Department of Health Services, Toxic Substances Control
Program, April 1990.
4. "Hazardous Waste Minimization Manual for Pennsylvania's Vehicle
Maintenance Industry," Center for Hazardous Materials Research,
University of Pittsburgh Applied Research Center, October 1987.
5. "Guides to Pollution Prevention: The Automotive Refinishing
Industry," Environmental Protection Agency, Risk Reduction
Engineering Laboratory and Center for Environmental Research
Information, Office of Research and Development, October 1991.
-------
6. "Guides to Pollution Prevention: The Automotive Repair Industry,"
Environmental Protection Agency, Risk Reduction Engineering
Laboratory and Center for Environmental Research Information, Office
of Research and Development, October 1991.
7. M. Townsend, "Hazardous Waste Minimization: Automobile Dealership
Repair Facility," Recycling and Waste Minimization, Front Range
Community College, Term Project, Spring 1992.
8. R. L. Millette, L. L. Millette, "Hazardous Waste Minimization: City
of Louisville," Recycling and Waste Minimization, Front Range
Community College, Term Project, Spring 1992.
9. S. Simsiman, "Waste Assessment: Denver Public WorXs Fleet
Maintenance," Pollution Prevention & Waste Reduction Program,
Colorado Department of Health, June 1, 1992;
10. K. Lippoldt, "Hazardous Waste Minimization: Fender's Bender Fixer
Shop," Recycling and Waste Minimization, Front Range Community
College, Term Project, Spring 1992.
11. L. R. Kostic, "Hazardous Waste Minimization: Automotive Repair Shops
Comparison," Recycling and Waste Minimization, Front Range Community
College, Term Project, Summer 1992. ..
12. R. Meinzer, "Hazardous Waste Minimization: Rocky Mountain National
Park Vehicle Maintenance Facility," Recycling and Waste Minimization,
Front Range Community College, Term Project, Summer 1992.
13. "Pollution Prevention in Automotive Service: Tune Up Your Shop to
Reduce Waste and Simplify Compliance," Colorado Department of Health,
Automotive Service Association, Pollution Prevention Partnership,
Recom Applied Solutions, February 26, 1992.
14. "Hazardous Waste Minimization Workshop for the Automotive Recycling
Industry," Environmental Protection Agency: Region VII, Science
Applications International Corporation, May 30, 1992.
15. W. Wren, "Waste Minimization: Benchmark survey of County operated
Fleet Vehicle and Traffic Operation Maintenance Facilities Along the
Front Range," Graduate Study, November 1992.
16. "Hazardous Waste Management Advice for Automobile Dealers," Iowa
Waste Reduction Center, University of Northern Iowa, 1991.
17. "EPA Region VIII: south Dakota Waste Minimization in Compliance
Inspections," Environmental Protection Agency, PRC Environmental
Management Inc.
18. "Handbook for EPA Waste Minimization in Permitting Training Course:
Region VII," Environmental Protection Agency, Science Applications
International Corporation, August 1991.
-------
19. "Achievements in Source Reduction for Ten Industries in the United
States,*1 Environmental Protection Agency, Office of Research and
Development, Science Applications International Corporation,
September 1991.
20. "Engine Repair/Engine Rebuilding Industries: Waste Management and
Reduction," Hazardous Waste Fact Sheet for Minnesota Generators,
Small Quantity Generator Assistance Group.
21. "Auto Body Repair: Hazardous Waste Management and Reduction,"
Minnesota Technical Assistance Program, November 1988.
22. "Hazardous Waste Reduction Assessment Handbook: Automotive. Repair
Shops," California Department of Health Services, Toxic Substances
Control Division, Alternative Technology Section, October 1988.
23. "Hazardous Waste Reduction Checklist: Automotive Repair Shops,"
California Department of Health Services, Toxic Substances Control
Division, Alternative Technology Section, October 1988.
24. "Fact Sheet: Waste Minimization for Automotive Repair Shops," State
of California, Department of Toxic Substances Control, Alternative
Technology Division, May 1992.
25. "Pollution Prevention .Opportunities Specific to the Coal Mining
Industry," National Coal Association;
26. "Garage Owners: Handling of Hazardous and Solid Waste," Pollution
Prevention Tips, Pollution Prevention Program, Office of Waste
Reduction, North Carolina Department of Environment, Health, and
Natural Resources.
27. "Waste Reduction Options: Automobile Salvage Yards,: Pollution
Prevention Tips, Pollution Prevention Program, North Carolina
Department of Environment, Health, and Natural Resources.
28. "A Pollution Prevention Guide for Fleet Management," Delaware
Department of Natural Resources and Environmental Control.
29. "A Pollution Prevention Guide for Automotive Repair Shops," Delaware
Department of Natural Resources and Environmental Control, 1992. .
30. "Pollution Prevention and Waste Reduction Fact Sheet: Vehicle Repair
Shops," Colorado Department of Health, August 1991.
31. "Pollution Prevention and Waste Reduction - Lessons Learned in
Pollution Prevention: Case studies of Four Vehicle Repair
Operations," Colorado Department of Health, November 1992.
32. "Hazardous Waste Fact Sheet for Minnesota Generators: Vehicle
Maintenance/Equipment Repair," Minnesota Pollution Control Agency,
October 1986.
-------
33. "Hazardous Wastes from Motor Freight Terminals/ Railroad
Transportation," Environmental Protection Agency, 1990.
34. "Hazardous Waste from Vehicle Maintenance," Environmental Protection
Agency, 1990.
35. "Fact Sheet: Pollution Prevention opportunities for the Automotive
Recycling Industry," Environmental Protection Agency, Region VIII,
Hazardous Waste Management Division, Hazardous Waste Minimization
Program, May 1992.
36. S. Dharmavaram, J. B. Mount, B. A. Donahue, "Automated Economic
Analysis Model for Hazardous Waste Minimization," Journal of the Air
& Waste Management Association, 1990.
37. "Assessment of Recycling and Recovery Opportunities for Waste (ARROW)
at a State Department of Transportation Maintenance Facility,"
Environmental Protection Agency, EPA/RREL, Pollution Prevention
Research Branch. .
38. "The Anatomy of Your Car," Hazardous Waste Quarterly.
39. "Hazardous Waste Fact Sheet for Minnesota Generators: Acids/Bases,"
Minnesota Technical Assistance Program, December 1985.
40. C. J. Carpenter, "The Air Force Hazardous Waste Minimization
Program," Plating and Surface Finishing, April 1990.
41. R. A. Fredrickson, "Navy Hazardous Waste Minimization Overview,"
Pollution Prevention Programs, Naval Energy and Environmental Support
Activity.
42. L. P. Taylor, M. A. Gaughan, "Audit Report and Case study of
Automotive Dismantling . and Recycling Salvage Yards," Waste
Minimization Case Histories, Environmental Protection Agency, Science
Applications International Corporation, 1992.
43. "Waste Reduction is Good Business $ense," Alaska Health Project,
1987.
44. M. J. Miller, "Pollution Prevention in the Electric Utility
Industry," Pollution Prevention Review, Volume 2, Number 2, Spring
1992.
45. "Pollution Prevention: strategies for the Metal Finishing Industry,"
Center for Hazardous Materials Research (CHMR).
46. "Waste Minimization for the Metal Finishing Industry," University of
California, California Department of Toxic Substances Control
(Alternative Technology Division), Environmental Protection Agency,
May 1991.
-------
47. "Waste Minimization in Metal Farts Cleaning," Environmental
Protection Agency, Office of Solid Waste and Emergency Response,
August 1989.
48. "Guides to Pollution Prevention:. The Fabricated Metal Products
Industry,11 Environmental Protection Agency, Office of Research and
Development, Risk Reduction Engineering Laboratory, July 1990.
GREASES/LUBRICANTS
1. K. R. Suttill, "Lubricants Key to Long Equipment Life," Coal, April
1989.
2. "Cutting Fluid Management in Small Machine Shop Operations," Iowa
Waste Reduction Center, University of Northern Iowa.
3. R. B. Pojasek, "Practical Pollution Prevention: Conserving Fluid Use
in Machining Operations," Pollution Prevention Review, Volume 2,
Number 3, Summer 1992.
•METALS AND METAL COMPOUNDS
1. "Treatment Levels for Auto Shredder Waste," State of California,
Department of Health Services, Toxic Substances Control Division,
Alternative Technology Section, June 1989.
2. "Staff Report on Proposed Treatment standards for Solid Wastes with
Metals," California State Department of Health Services, Toxic
Substances Control Program, December 1989.
OIL
1. T. N. Kalnes, K. J. Youtsey, R. B. James, and D. R. Hedden,
"Recycling Waste Lube oils for Profit (UOP Direct contact
Hydrogenation Process),1' Hazardous Waste & Hazardous Materials,
Volume 6, Number 1, 1989.
2. "Regulations for Blending Used Oils With Fuel Oil in the Creation of
ANFO," MSHA.
3. "Federal Register, Part III, Environmental Protection Agency, 40 CFR
Part 260 et al., Hazardous Waste Management System: Identification
and Listing of Hazardous Waste: Recycled Used Oil Management
Standards: Final Rule," September 10, 1992.
-------
4. E. E. Torres, "Oil Recycling Incentives Act strengthens Market Forces
for Used Oil Recycling," Environmental Waste Management Magazine,
June 1991.
5. "Notice of Potential Risk: Used Motor Oil," Environmental Protection
Agency Chemical Advisory, Office of Pesticides and Toxic Substances,
February 1984.
6. "Fact Sheet: Used Motor Oil," Minnesota Office of Waste Management,
May 1991.
7. "Managing Used Oil," Minnesota Pollution Control Agency, December
1991.
8. "Environmental Fact Sheet: No Hazardous Waste Listing for Used Oil
That Is Being Disposed," Environmental Protection Agency,
Environmental Fact Sheet, Solid Waste and Emergency Response, May
1992.
9. "EPA, Bowing to White House Pressure, Drops Plans to Regulate Used
Oil," Inside E.P.A. Weekly Report, February 28, 1992.
10. K. Young, "Non-hazardous Used Oil Listing Imminent, NORA Says," Waste
Tech News, Volume 4, Number 1, March 23, 1992.
11. "Used Oil Recycling," Environmental Protection Agency, Office of
Solid Waste, Waste Management Division, March 1988.
12. "EPA Concerns About the Used oil Recycling Systems," Environmental
Protection Agency Information Bulletin for Public Release.
13. M. L. Courtright, "Used Oil: Don't Dump It, Recycle It," Machine
Design, October 25, 1990.
14. "Old Oil: Sources and Uses," Machine Design.
15. W. Slakey, "Used Oil Greatest Source of Airborne Lead," Waste Tech
News, December 2, 1991.
16. "Regulation of Used Oil Burned for Energy Recovery," Environmental
Protection Agency, November 29, 1985.
17. "Burning Used Oil," Minnesota Pollution Control Agency, February
1992.
18. "Marketing Used Oil," Minnesota Pollution Control Agency, February
1992.
19. "Used oil Space Heaters," Minnesota Pollution Control Agency,
December 1991.
20. "Alternatives to Used Oil for Dust Suppression," Minnesota Pollution
Control Agency, December 1991.
-------
PAINT
1. "Padnting and Coating Pact Sheet,** Pollution Prevention, Department
of Environmental Quality, Solid Waste Management Program, September
1991.
2. "Waste Minimization for Paint Formulators/" California Department of
Health Services, Toxic Substances Control Program, Alternative
Technology Division, May 1992.
3. "Paints, and Coatings Application,** Department of Environmental
Conservation, New York State Waste Reduction Guidance Manual, March
1989.
4. "Paint: Waste Generation and Disposal,** General Information
(combined sources).
5. "Guides to Pollution Prevention: The Paint Manufacturing Industry,"
U.S. Environmental Protection Agency, Risk Reduction Engineering
Laboratory, Center for Environmental Research Information, June 1990.
6. "Management Options for Old Paint and Paint Related Materials,"
Minnesota Technical Assistance Program, April 1991.
•7. Generator Checklist for Identifying Waste Reduction Opportunities:
Coating and Painting Operations," Minnesota Technical Assistance
Program, January 1989.
8. "Auto Body Repair: Hazardous Waste Management and Reduction,"
Minnesota .Technical Assistance Program, August 1991.
9. "Household Hazardous Materials: Paint," Iowa Department of Natural
Resources.
10. "Hazardous Waste Fact Sheet for Minnesota Generators: Paints, Inks,
and Other Organic Residuals," Minnesota Technical Assistance Program.
11. "Powder Coating Materials," Powder Coating Institute, Technical
Brief, January 1986.
12. T. Schicktanz, "Hazardous Waste Minimization: A-l Paint Supply,"
Recycling and Waste Minimization, Front Range Community College, Term
Project, Spring 1992.
13. "Waste Audit Study: Automotive Paint Shops," Alternative Technology
Section, Toxic Substances Control Division, California Department of
Health Services, January 1987.
14. D. C. Kostic, "Hazardous Waste Minimization: Colorado Paint and Auto
Body," Recycling and Waste Minimization, Front Range Community
College, Term Project, Spring 1992.
-------
15. "Case. Study: Spray Nozzle selection Reduces Solvent Waste Volume
When Cleaning Paint Straining Equipment," Minnesota Technical
Assistance Program, June 1991.
16. "Case Study: Soak Step Reduces Solvent Waste From Cleaning Faint
Straining Equipment," Minnesota Technical Assistance Program, July
1991.
17. "Spray Fainting: The Search for the Right Answer," Pollution
Prevention Review, Volume 2, Number 2, Spring 1992.
18. H. Lannefors, J. Eneroth, "Reduction of Organic Solvent Emission from
Spray Fainting Booths," Metal Finishing, November 1990.
19. B. A. Graves, "Coatings for compliance," Products Finishing, July
1990.
20. "Waste Minimization Opportunity Assessment: A Truck Assembly Plant,"
Environmental Protection Agency, Risk Reduction Engineering
Laboratory, September 1991.
21. "Paint Disposal - The Right Way," A General Guide on the Disposal of
Latex and Solvent-based Paint Products, National Paint and Coatings
Association.
22. "Waste Audit Study: Faint Manufacturing industry," Toxic Substances
Control Program, California Department of Health Services, April
1987. . • ' '
23. R. D. Baker and J. L. Warren, "Management of Product Life Cycle to
Promote Pollution Prevention," Pollution Prevention Review, Volume 1,
Number 4, Autumn 1991.
24. M. Peterson, "Waste Reduction and Waste Management for a Mid-sized
Auto Body Shop," Minnesota Technical Assistance Program, Summer 1988.
25. "Waste Minimization for Formulators: Paint and Coatings
Formulation."
26. A. C. Walberg, "Transfer Efficiency," Electrostatic Consultants
Company, Paint Con '87, Spring 1987.
27. "The Efficient Utilization of Material in the Finishing Room,"
Devilbiss Educational Services,
PLASTIC
1. "RIM Auto Scrap Gets Recycled," Machine Design, February 6, 1992.
2. "Plastics Group Drives Auto Industry Toward Recycling," Machine
Design, May 7, 1992.
-------
PAINT STRIPPING
1. . "Paint Stripping,1* Department of Environmental Conservation, New York
. State Waste Reduction Guidance Manual, March 1989.
2. C. Quinnell, "Strip Ease: Removing Paint with Plastic Media
Blasting,** Hot Rod/ November 1991.
3. "Source Reduction and Recycling of Halogenated Solvents in Paint
. Stripping,** Technical Support Document, Source Reduction Research
Partnership, Metropolitan Water District of Southern California,
Environmental Defense Fund, 1990.
RADIATORS
1. "Waste Reduction Options: Radiator Service Firms," Pollution
Prevention Tips, Pollution Prevention Pays Program, North Carolina
Department of Natural Resources and Community Development, September
1986.
2. "Radiator Repair/Engine Rebuilding Industries: Waste Management and
Reduction," Hazardous Waste Fact Sheet for Minnesota Generators,
Minnesota Pollution Control Agency, March 1989. , '
«
3. A..Debele, "Metal Recovery As Synthetic Mineral Concentrates (From
Automotive Radiator Boil-Out Solutions)," Minnesota Office of Waste
Management, January 1990.
4. A. Debele, "A Reduction Method for Radiator Repair Waste:
Instruction to Handle Sludge from Ultrasonic Heated Radiator Boil-out
Tanks," Minnesota Office of Waste Management, January 1990.
RAGS/SHOP TOWELS
1. "Options for Shop Rags from Printers," Minnesota Technical Assistance
Program, University of Minnesota.
2. "Removing Solvent and Ink from Printer Shop Towels and Disposable
Wipes," Minnesota Technical Assistance Program, August 1991.
SOLVENTS
1. . "Source Reduction and Recycling of Halogenated Solvents: Lifecycle
Inventory and Tradeoff Analysis," Source Reduction Partnership,
Metropolitan Water District of Southern California, Environmental
Defense Fund.
-------
2. "Trichloroethylene and Stoddard Solvent Reduction Alternatives in a
Small Shop," Minnesota Technical Assistance Program, Summer Intern
Report (0. Taylor), Aero Precision Engineering Corporation, Summer
1989.
3. "Reducing Chlorinated Solvent Emissions From Three Vapor Degreasers,"
Minnesota Technical Assistance Program, Summer Intern Report (C.
Hymes), Alliant Techsystems Inc., Summer 1990.
4. "Reduction of Solvent Emissions from Vapor Degreasing," Minnesota
Technical Assistance Program, Summer Intern Report (P. Buresh),
Hutchinson Technology Inc.1, Summer 1989.
5. "The Reduction of Solvent Wastes in the Electronics Industry," State
of California, Department of Health Services, Toxic Substances
Control Division, Alternative Technology and Policy Development
Section, Waste Reduction Grant Program, June 1988.
6. "Deburring Operation Replaces Vapor Degreaser for Cleaning Metal
Parts," Minnesota Technical Assistance Program Quarterly Newsletter,
Volume 7, Number 3, Summer 1992.
7. "Hazardous Waste Fact Sheet for Minnesota Generators," Minnesota
Technical Assistance Program, October 1986.
8. * "Generator checklists for Identifying Waste Reduction Opportunities,"
Minnesota Technical Assistance Program, January 1989.
9. "Alternative Cleaning Technologies for Vapor Degreasing and Cold Dip
Processes/" Minnesota Technical Assistance Program.
10. "Reducing Solvent Emissions from Vapor Degreasers," Minnesota
Technical Assistance Program, July 1991.
11. "Selecting a Still for On-site Recycling," Minnesota Technical
Assistance Program, May 1991.
12. B. Carter, "Solvents - The Alternatives," Waste Reduction Resource
Center for the Southeast, August 1992.
13. J. Kohl, P. Moses, B. Triplett, "Managing and Reclycling Solvents,"
North Carolina Practices, Facilities, and Regulations, North Carolina
State University, December 1984.
14. "Parts Cleaning and Solvent Degreasing," Department of Environmental
Conservation, New York State Waste Reduction Guidance Manual, March
1989.
15. S. A. Walata III, R. M. Rehm, "Source Characterization and Control
Technology Assessment of Methylene Chloride Emissions from Eastman
Kodak Company, Rochester, NY," Environmental Protection Agency,
Project Summary, September 1989.
-------
16. "Guidelines for Waste Reduction and Recycling: Solvents," Hazardous
Waste Reduction Program of Oregon, Oregon Department of Environmental
Quality, August 1989.
17. "Aqueous Cleaning," CFC Alternatives, Environmental Program Office,
City of Irvine, California, February 1991.
18. "Semi-Aqueous Cleaning," CFC Alternatives, Environmental Program
Office, City of Irvine, California, July 1991.
19. "Guides to Pollution Prevention: The Commercial Printing Industry,"
Environmental Protection Agency, Office of Research and Development,
August 1990.
20. "Case Studies from the Pollution Prevention Information Clearinghouse
-------
31. "Solvent Waste Reduction Alternatives Symposia: Conference
Proceedings," California Department of Health Services, Santa Clara:
October 20-21, 1986; Los Angeles: October 23-24, 1986.
32. "Trichloroethylene Case Study," Serious Reduction of Hazardous Waste
for Pollution Prevention and Industrial Efficiency, Congress of the
United States, Office of Technology Assessment, September 1986.
33. H. Ladisch, Y. Yang, and C. M. Ladisch, "Recovery of Dilute Aqueous
Butanol and Other Alcohols by Adsorption on Lignin," United States
Department of Energy, Innovative Concepts Program.
34. L. Semprini, G. D. Hopkins, D. B. Janssen, H. Lang, P. V. Roberts,
and P. L. Mccarty, "Zn-Situ Bio trans format ion of Carbon Tetraehloride
Under Anozic Conditions," Environmental Protection Agency, March
1991.
35. M. Drabkin and P. Sylvestri, "Waste Minimization Audit Report: Case
Studies of Minimization of Solvent wastes and Electroplating Wastes
at a DOD Installation," Environmental Protection Agency, Hazardous
Waste Engineering Laboratory, March 1988.
36. G. E. Harris, "Solvent Recovery at Vandenberg Air Force Base,11
Environmental Protection Agency, September 1984.
37. "Waste Minimization in Metal Parts Cleaning," Environmental
Protection Agency, Office of Solid Waste and Emergency Response,
August 1989.
38. "Eliminate Chlorinated Solvents From Your Shop!," Vehicle Maintenance
Chemicals and Their Hazards, Common Automotive Chemicals and Their
Hazards.
39. "Source Reduction and Recycling of Halogenated Solvents in Parts
Cleaning," Source Reduction Research Partnership, Metropolitan Water
District of Southern California and the Environmental Defense Fund.
40. "Generic Waste Reduction Opportunities: Solvents," Serious Reduction
of Hazardous Waste for Pollution Prevention and Industrial
Efficiency, Congress of the United States, Office of Technology
Assessment, September 1986.
41. I. A. Jefcoat and M. D. Heil, "Assembling Systems to Optimize
Volatile Organic Compound Recovery," Pollution Prevention Review,
Volume 2, Number 2, Spring 1992.
42. M. Keyes, "Evaluation of Aqueous Cleaners to Replace TCA Degreasing:
Thermo King," Intern Summary, Minnesota Technical Assistance Program,
Summer 1991.
43. B. Butler, "Evaluation of Aqueous Cleaners to Replace TCA Degreasing:
Continental Machines, inc.," Intern Summary, Minnesota Technical
Assistance Program, Summer 1991.
-------
44. B. M. Winn, "Environmental and Economic Results of Five Waste
Minimization Case Histories," Waste Minimization Case Histories.
45. "Waste Minimization Audit Report: Case Studies of Minimization of
Solvent Waste from Parts Cleaning and from Electronic Capacitor
Manufacturing Operations/" Environmental Protection Agency, Hazardous
Waste Engineering Research Laboratory, November 1987.
46. S. I. Schwartz, W. B. Pratt, D. R. McCubbin, "On-Site Recycling of
Hazardous Waste Solvents/" J. Environmental Systems, Volume 20(1) 1-
21, 1990-1991.
47. M. Melody, "Boatmaker Finds Solvent Substitute, Cuts Emissions,
Costs/" Hazmat World, February 1992.
48. R. Helsel, E. Stine, T. Kovalcson, "Testing and Evaluation of Solvent
Recovery Techniques for Waste Minimization/" Recovery.
49. M. L. Kennedy, "The Solvents Bazaar - A Cooperative Effort Between
Government and Industry," Pollution Prevention Review, Volume 2,
Number 4, Winter 1992-1993.
50. P. Erdman, "Hazardous Waste Minimization: Regional Transportation
District (RTD)/" Recycling and Waste Minimization, Front Range
Community College, Term Project, Spring 1992.
51. H. Winslow, "Waste Minimization Workshops for Solvent and Thinner
Users: A Waste Minimization Guidebook," Colorado Association of
Commejrce and Industry, Center for Business Resources, 1990.
TIRES
1.- B. D. Bauman, "Scrap Tire Reuse Through Surface-Modification
Technology,", Air Products and Chemicals, Inc., Pacific Northwest
Laboratory for the U. S. Department of Energy, Innovative Concepts
Program.
2. "Tires Disappear," Machine Design, July 9, 1992.
3. D. Michelitsch, Burning Tires for Fuel and Tire Pyrolysis (Air
Implications)," Control Technology Center News, Volume 4, Number 1,
January 1992.
4. "TVA To Burn Tires in Fuel Test In Memphis," MSSWRAP (Mississippi
Solid Waste Reduction Assistance Program), Volume 3, Number 2, March
1992.
5. J. Marks, "Thermal Value Makes Tires a Decent Fuel for Utilities,"
Power Engineering, August 1991.
6. "More on Pyrolysis: other Crumby Scrap Rubber Alternatives,"
Environment Today, Volume 3, Number 1, January/February 1992.
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7. "Minnesota Waste Tire Program," Minnesota Pollution Control Agency
September 1992.
8.. "Shredded Tires as Lightweight Fill Material," Minnesota Waste Tin
Program, Minnesota Pollution Control Agency, September 1992.
WASTEWATBR
1. R. 6. Fink, "Equipment Cleaning Liquid Discharge Control,1
Proceedings of National Conference: • Minimization and Recycling o:
Industrial and Hazardous Waste '92, Arlington, VA, September 22-24
1992.
2. H. Gosman, "Hazardous Waste Minimization: Sandia Motor Works,'
Recycling and Waste Minimization, Front Range Community College, Ten
Project, Spring 1992.
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