United States             Center for Environmental      Office of Solid Waste
Environmental Protection      Research Information        and Emergency Respon
Agency

technology Transfer        ~March'l988               gERI-88~6i



Solvent Waste Reduction


Alternatives Seminar
Speaker Papers

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    Session I
Regulatory Issues

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Land and Liquid Disposal Bans

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 LAND DISPOSAL RESTRICTIONS SUMMARY

              VOLUME 1

        SOLVENTS AND DIOXINS
           Submitted  to:

       Office  of Solid Waste
U.S. Environmental  Protection Agency
           Washington, DC
              May 1987

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                           CONTENTS


                                                            Page

1.   Introduction                                             1


2.   Treatment Standards (Section  268.40)                      7

    How Are the Treatment  Standards Established?              7

    What Is the Best Demonstrated Available                   8
    Technology (BOAT)?

    Setting the Treatment  Standards                         10

    What Is the TCLP?                                       10


3.   Variances and Extensions                                11

    Variance from the Treatment Standard  (Section 268.44)    11

    Two-Year National Capacity Variance (Section 268.30)     12

    Case-by-Case Extensions (Section 268.5)                  13

    "No Migration" Petitions (Section 268.6)                 15

    Rulemaking Procedures                                     15


4.   Treatment in Surface Impoundment Exemption               17
    (Section 268.4)


5.   Prohibition on Dilution (Section 268.3)                   19


6.   Storage Prohibition (Section 268.50)                      21


7.   Permit Program                                           25

    Interim Status Facilities                                25

    Permitted Facilities  (Section  270.42)                    25

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                     CONTENTS (continued)



 8.   Testing  and  Recordkeeping  (Section 268.7)               27

     Generator  Responsibilities                              27

     Treatment  Facility  Responsibilities                     28

     Land Disposal Facility  Responsibilities                 29


 9.   Treatment  Standards for Solvents  (Section  268.41)       31

     What Solvent Wastes Are Covered Under  the  F001-F005     31
     Listing? (Section 268.31)

     Basis for  the Solvent Treatment Standards               31

     Effective  Date of Solvent  Land Disposal  '               32
     Restrictions (Section 268.30)


10.   Treatment  Standards for Dioxins  (Section 268.41)        35

     Effective  Date of Dioxin Land Disposal                 35
     Restrictions (Section 268.31)
Appendix A  Information Requirements for a Petition
            for a Variance From the Treatment Standard

Appendix B  Information Requirements for a Petition
            for a Case-by-Case Extension

Appendix C  Information Requirements for a Petition
            for a "No Migration" Exemption

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                       1.  INTRODUCTION
    The Hazardous and Solid Waste Amendments (HSWA)  to the
Resource Conservation and Recovery Act (RCRA)  were enacted on
November 8, 1984.  Among other things, these far-reaching
amendments require EPA to evaluate all hazardous wastes
according to a strict schedule to determine whether  land
disposal of these wastes is protective of human health and the
environment.  For wastes that are restricted from land
disposal, the amendments require EPA to set levels or methods
of treatment which substantially diminish a waste's toxicity or
reduce the likelihood that a waste's hazardous constituents
will migrate.  Beyond specified dates, restricted wastes which
do not meet the treatment standards (or are otherwise exempt as
discussed in this booklet) are prohibited from land disposal
(see Table 1).  According to HSWA, if EPA fails to set
treatment standards for a particular waste by specified
deadlines, that waste is automatically prohibited from land
disposal.  These so-called "hammer provisions" provide the
impetus for EPA to keep to the strict schedule.

    On November 7, 1986, EPA promulgated the first phase of  the
land disposal restrictions.  In the November 7, 1986 final
rule, EPA established the framework for implementing the land
disposal restrictions program.  EPA also established specific
treatment standards and effective dates for the first  category
of wastes subject to the restrictions, F001-F005 spent solvent
wastes, and F020-F023 and F026-F028 dioxin-containing  wastes.
This booklet summarizes the November  7, 1986 rulemaking  and
describes the key regulatory  requirements pertaining to
treatment standards, variances, and extensions.  The booklet
also outlines the new responsibilities of generators,  treatment
facilities, and  disposal  facilities under the  rule.  Finally,
it provides an overview of  the specific  treatment standards

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                            TABLE 1

            SCHEDULE FOR LAND DISPOSAL PROHIBITIONS
November 8, 1986
July 8, 1987
August 8, 1988
November 8, 1988
June 8, 1989


May 8, 1990
Within 6 months of
listing or  identification
(these wastes are not  subject
to  the automatic land  disposal
prohibition)
Dioxin-containing wastes
(F020, F021,  F022, F023,
F026, F027,  F028)

Spent solvents (F001, F002,
F003, F004,  F005)

California list wastes
(Liquid hazardous wastes
containing:  free cyanides,
PCBs, and certain metals at
or above specified
concentration levels, and
those liquid hazardous wastes
having a pH of less than or
equal to 2.0.  Also, both
liquid and non-liquid
hazardous wastes containing
halogenated organic compounds
at or above specified
concentration levels.)

At least one-third of all
listed hazardous wastes

Wastes disposed  of in
injection wells

Contaminated soil and debris
from CERCLA Section  104 or
106  response actions and RCRA
corrective actions

At least two-thirds  of  all
listed hazardous wastes

All  remaining listed
hazardous wastes

All  characteristic hazardous
wastes

Newly  listed wastes

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for solvent- and dioxin-containing  wastes,  the first  wastes
that EPA has evaluated for the land disposal  restrictions.   The
booklet is geared to individuals who are familiar with EPA's
hazardous waste regulatory program.  While  it presents a
summary of the land disposal restrictions program, it is not
intended to be a comprehensive review of all  regulatory issues
associated with the November 7 rulemaking.   For further
information, contact the RCRA/Superfund Hotline at (800)
424-9346 (toll free) or (202)  382-3000 in the Washington,  D.C.
metropolitan area.

    In the final rule, EPA defined  land disposal to include,
but not be limited to, any placement of hazardous waste in:

    •  Landfills.
    •  Surface impoundments.
    •  Waste piles.
    •  Injection wells.
    •  Land treatment facilities.
    •  Salt domes or salt bed formations.
    •  Underground mines or caves.
    •  Concrete vaults or bunkers.

    The land disposal restrictions rule covers hazardous wastes
placed in  land disposal units after the effective dates of  the
prohibitions.  Wastes disposed  of  before November 7,  1986 do
not have to be removed from land disposal for  treatment.
However, if wastes are removed  from land disposal, the  wastes
must meet  the applicable  treatment standards  before  subsequent
new placement in or on the  land, or they must  be  the  subject of
a  variance  or extension as  discussed  in  this  booklet.
Contaminated soil  and debris  from  CERCLA Section  104  and 106
response actions  and  RCRA corrective  actions  are  not  subject to

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the land disposal restrictions  rule  until  November  8,  1988.   In
addition, wastes disposed of in underground  injection  wells  are
not subject to the land disposal restrictions  until August  8,
1988.

    Wastes which are placed into storage prior to the  effective
date are not subject to the restrictions on  storage.  However,
once taken out of storage, these wastes must meet the
applicable treatment standards prior to land disposal, or they
must be the subject of a variance or extension as discussed in
this booklet.

    Wastes may be treated in surface impoundments that meet
minimum technological requirements provided that (among other
things discussed in this booklet) treatment residuals which do
not meet the treatment standards are removed within one year of
placement of the waste in the  impoundment.

    Both interim status  and permitted  facilities are  subject to
the land disposal restrictions  rule  (these  restrictions
supersede 40 CFR 270.4(a) which currently provides  that
compliance with a RCRA permit  constitutes compliance  with
Subtitle C).  However, small quantity  generators of less than
100 kg/month of hazardous waste  (or  less  than 1  kg/month of
acute hazardous waste) are  not  subject  to the restrictions.

    The November 7, 1986, final  rule outlines the Agency's
approach to  implementing the congressionally  mandated
restrictions on  land disposal  of hazardous  waste.   The  rule
includes:

     •   Procedures for  setting  treatment standards.
     •   Procedures for  obtaining variances from  the  treatment
        standards.

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•  Procedures for granting nationwide variances from the
   effective dates of the land disposal restrictions due to
   insufficient alternative treatment capacity.

•  Procedures for obtaining extensions to the effective
   dates of the land disposal restrictions on a
   case-by-case basis.

•  Procedures for petitioning to obtain a variance from the
   land disposal restrictions based on a finding that there
   will be no migration of hazardous constituents from the
   disposal unit or injection zone for as long as the
   wastes remain hazardous.

•  Provisions for allowing restricted wastes to be treated
   in surface impoundments.

•  Provisions for prohibiting dilution as a substitute for
   adequate treatment to achieve the treatment standards.

•  Provisions for prohibiting the storage of restricted
   hazardous wastes.

•  Provisions for modifying permits.

•  Requirements  for testing and recordkeeping.

«  Specific treatment standards for certain dioxin- and
   spent solvent-containing wastes.

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           2.  TREATMENT STANDARDS (SECTION 268.40)
    HSWA prohibits land disposal of restricted  wastes  unless
EPA determines that continued land disposal  is  protective  of
human health and the environment,  or unless  the applicable
treatment standards have been met.  HSWA requires EPA  to set
levels or methods of treatment which substantially diminish the
toxicity of a waste or substantially reduce  the likelihood that
hazardous constituents will migrate from a waste.  These levels
or methods, referred to as treatment standards, must minimize
short- and long-term threats to human health and the
environment.  After the effective dates of the prohibitions,
hazardous wastes that do not comply with the treatment
standards are prohibited from being placed in land disposal
units unless:
    •  EPA has approved a petition demonstrating that hazardous
       constituents will not migrate from the land disposal
       unit for as long as the wastes remain hazardous.
    •  EPA has granted an extension to the effective date of
       the prohibition.

How Are the Treatment Standards Established?
    To establish treatment standards, EPA identifies wastes
with similar characteristics (i.e., similar physical and
chemical properties).  EPA then categori.zes these similar
wastes into broad "waste treatability groups" and subgroups.
The treatability groups take into account differences in the
types and effectiveness of treatment for those particular
wastes.  Treatability groups may be formed by grouping wastes
by industries or manufacturing processes which generate wastes
with similar treatability characteristics.  EPA then evaluates
identified technologies used to treat the wastes to determine
the best demonstrated available technology (BOAT) for each
waste treatability group.

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What  Is  the Best Demonstrated Available Technology (BOAT)?

    BOAT  is the best available method of treatment demonstrated
to  be achievable for each waste treatability group.  To
establish  BOAT for  a particular waste treatability group, EPA
first collects and  analyzes data on existing treatment
technologies  for that waste group that are demonstrated by
full-scale operation.   EPA will not consider pilot- and
bench-scale operations  in identifying "demonstrated" treatment
technologies.

    Once  EPA  has identified "demonstrated" technologies,  the
Agency then determines  whether these technologies may be
considered "available,"  as based on three criteria:

    •  The technology must be  commercially available.
    •  The technology must present  less  risk  to  human health
        and the environment than  land disposal  of the untreated
        waste.
    •  The technology must provide  substantial treatment.

    Technologies considered  in setting  BDAT must be  found to  be
commercially  available  (i.e.,  either  the technology  itself,  or
the services  of  the technology,  may be  purchased).   A
proprietary  or patented treatment  technology  must be able to  be
purchased from  the proprietor.  If  it  cannot  be purchased,  the
.technology is considered unavailable  and the  treatment  standard
will  be based on  the next best technology that is available.

    EPA then  compares  the risks  to human health and  the
 environment  associated  with  treatment  of the  wastes  by the
 demonstrated  technologies to the risks associated with the land
 disposal of  untreated  wastes.   Based  on this  comparative risk
 assessment,  those  treatment  technologies that present greater
 risks than land  disposal of  the  untreated wastes will be

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considered unavailable,  and will be excluded as  a basis  for
establishing treatment standards.

    If all demonstrated treatment technologies present greater
risks than land disposal for a particular waste, EPA will not
set a treatment standard for that waste.   Therefore, the
restricted waste will be prohibited from land disposal (unless
it is the subject of an approved "no migration"  petition) until
a new or improved technology emerges that does not pose a
greater risk than land disposal.

    EPA will not consider treatment technologies that are
prohibited under RCRA Section 3004(n) because of the potential
for air emissions of hazardous constituents as available for
purposes of establishing treatment standards.

    Also, to be considered an available  technology, the
technology must provide substantial treatment,  that is,  it must
substantially diminish the toxicity of the waste or reduce the
likelihood of migration of the waste's hazardous constituents.
This excludes technologies that would provide treatment  only
for the sake of treatment without  providing substantial
reduction in risk to human health  and the environment.

    Once  the demonstrated available treatment technologies are
identified, EPA then evaluates  performance  data  on  these
technologies to determine  if  the data are representative of
well-designed and well-operated  systems.  Only  data from
well-designed and well-operated  systems  will  be  considered in
setting BOAT.  These performance data are then  analyzed  to
determine the best  demonstrated  available technology.

    When  treatment  data are  available for several  different
technologies, EPA is  using  a  statistical method known as
analysis  of 'variance  to determine  the level  of  performance  that

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represents BOAT.   EPA is also using a process  variability
factor in setting BDAT which takes into account  normal
variability in well-designed and well-operated treatment
processes.

Setting the Treatment Standards

    Once BDAT is  identified, EPA then establishes the treatment
standards as either a specific technology (or  group of
technologies) or  as a performance level (i.e., the
concentration level of hazardous constituents  in a waste  or
extract of the waste that is representative of treatment  by
BDAT; for the November 7, 1986 rule covering solvents and
dioxins, this is  expressed as a concentration  level of
hazardous constituents in an extract of the waste developed by
using the Toxicity Characteristic Leaching Procedure [TCLP]).
Wherever possible, EPA will attempt to set concentration-based
performance standards since they will provide  the most
flexibility to the regulated community.  Treatment technologies
that are not used in setting treatment standards may still be
used to comply with treatment standards expressed as
performance levels.

What Is the TCLP?
    The TCLP is an analytical method used to determine whether
the concentrations of hazardous constituents in a waste extract
or an extract of the treatment residual meet the applicable
treatment standards.  EPA promulgated the TCLP for use only in
the solvents and dioxins final rule, and only when treatment
standards are expressed as concentration levels of hazardous
constituents in an extract.  EPA may revise the TCLP at some
future date based on public comments received on the June 13,
1986 Organic Toxicity Characteristic proposed rule (51 FR
21648) .

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                 3.  VARIANCES AND EXTENSIONS
    Under certain conditions,  EPA may grant  a  variance  from the
treatment standard,  an extension to the effective date  of  the
land disposal prohibition,  or  an exemption from the prohibition
for a specific waste at a specific site.   In the November  7,
1986 rulemaking, EPA established four types  of variances and
extensions:

    •  Variance from the treatment standard.
    •  Two-year national capacity variance.
    •  Case-by-case extension.
    •  "No migration" petition.

Variance from the Treatment Standard (Section 268.44)

    EPA established the variance from the treatment standard to
account for wastes that are significantly different from the
wastes evaluated by EPA in setting treatment standards and,
therefore, cannot be treated to meet the applicable treatment
standard; for example, exotic wastes, wastes formed by
inadvertent mixing, and wastes that require the use of
technologies different from those used to set the treatment
standard.  If a petitioner can successfully demonstrate that a
waste is significantly different from the wastes in its
treatability group such that it cannot meet the treatment
standard, EPA will grant a variance from the treatment standard
for that particular waste.  In granting a variance, EPA will
establish a new treatability group for that waste  (and all
similar wastes), and set a new treatment standard.

    For EPA to grant a variance, the petitioner must not only
successfully demonstrate that the waste is significantly

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different from the wastes evaluated by  EPA  in  setting  the
treatment standards,  but also demonstrate  that the  waste cannot
meet the treatment standard.   The petitioner must  show (by
actual treatment attempts that fail,  or by  extensive analyses
of the waste)  that treatment  of the waste  by well-designed  and
well-operated technologies is unsuccessful  in  meeting  the
specified levels, or  that the waste cannot  be  treated  by the
specified technology.

    Anyone submitting a petition for a  variance from  the
treatment standard must certify that all information  in the
petition (see Appendix A) is  true, accurate,  and complete.   In
addition, they must comply with all applicable hazardous  waste
management regulations during the petition evaluation  process.

    In considering variance petitions,  EPA first will  compare
the physical and chemical characteristics  of  the petitioner's
waste with the physical and chemical characteristics  of the
wastes evaluated by the Agency in setting  the treatment
standard.  This comparison will enable EPA to reexamine its
treatment standard for the waste.  EPA will then determine
whether the petitioner's treatment system (if any) is well
designed and well operated, and whether the system reflects
treatment by BOAT (although the restricted wastes are not
required to be treated by BDAT).

Two-Year National Capacity Variance  (Section  268.30)

    Certain wastes may continue to be  land disposed without
treatment for up  to  two years past the statutory effective
dates of the restrictions rule if  EPA  determines that adequate
treatment capacity is  not available  on a nationwide basis.  In
determining the  need  for a national  capacity  variance, EPA will
consider, on a nationwide basis,  both  the capacity of
alternative treatment  technologies and the quantity of

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restricted waste generated.   If sufficient  waste  treatment
capacity is available,  the restriction  on  land  disposal  of  that
waste goes into effect  on the statutory deadline.   If  there is
a significant shortage  of national capacity to  treat  all the
restricted waste, EPA may set an alternative effective date
based on the earliest date on which adequate treatment capacity
becomes available.

    In determining available capacity,  EPA will consider both
permitted and interim status on-line facilities.   EPA will  also
consider planned facilities and capacity extensions that will
be on-line by the effective date of a land disposal
prohibition.  On-line facilities will include on-site and
off-site facilities, as well as stationary and mobile
facilities.  EPA will not consider underground injection in its
capacity determinations until  the Agency has determined whether
such injection is fully protective of human health and  the
environment.

    EPA will compare available treatment capacity nationwide to
the quantities of the restricted waste generated annually
nationwide.  Available capacity will include:

    •  Commercially available  capacity.
    •  Private facility capacity which cap be used to manage
       additional waste generated by that  facility.
    •  Private facility capacity which can be used to manage
       wastes generated by  other  facilities  (i.e., can  act  as a
       commercial facility).

Case-by-Case Extensions  (Section  268.5)

    In cases where  alternative treatment or  disposal  capacity
cannot reasonably be made available by the  effective  date  of
the land disposal prohibitions,  interested  parties may  petition
EPA for an  extension of  the effective  date  on a case-by-case

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basis.  EPA may grant a case-by-case  extension  of  up  to  one
year.  This extension is renewable only once.

    To be considered for a case-by-case extension,  a  petitioner
must demonstrate a good faith effort  to locate  and  contract
with hazardous waste treatment,  recovery,  or  disposal
facilities nationwide to manage  the waste.  A petitioner must
also demonstrate that he has entered  into  a binding contract to
construct or otherwise provide adequate treatment,  recovery,
disposal capacity sufficient to  manage the entire  volume of
wastes.  In addition, a petitioner must demonstrate that, due
to circumstances beyond his control,  alternative treatment,
recovery, or disposal capacity cannot reasonably be made
available by the effective date.

    Anyone submitting a petition for a case-by-case extension
must certify that all information in the petition  (see Appendix
B) is true, accurate, and complete.  In addition,   they must
comply with all applicable hazardous waste management
regulations during the petition evaluation process.

     If wastes  that receive an extension to the effective date
(either a 2-year national variance or a case-by-case extension)
are  to be placed in  or on the land, then they must be placed in
a facility that is in compliance with the minimum  technological
requirements.  These  requirements, including a double liner,
leachate collection  system,  and ground-water monitoring  system,
apply to new units,  replacement units, or lateral  expansions of
existing landfills or  surface impoundments at existing
facilities.  Wastes  receiving an  extension may also  be  place'd
in  such  facilities that meet  other alternative operating
practices, design  features,  or  siting  characteristics
determined by  the  EPA  Administrator  to be  equally  protective of
human  health and  the environment.

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"No Migration" Petitions (Section 268.6)

    EPA will consider allowing land disposal  of  restricted
wastes if a petitioner can demonstrate,  to a  reasonable  degree
of certainty, that such disposal will not allow  migration of
hazardous constituents from the disposal  unit or injection  zone
for as long as the wastes remain hazardous.   In  general, a
successful "no migration" petition (see Appendix C for petition
requirements) will allow only land disposal of a specific waste
at a specific unit.

    EPA believes that there will be very few instances when "no
migration" demonstrations can be successfully made.  However,
candidates for a successful petition include cases where wastes
containing relatively immobile hazardous constituents are
placed in monofills located in arid climates with no
ground-water recharge.  Other candidates for "no migration"
petitions are cases where a small amount of compatible waste is
placed in a massive and stable geological formation such as a
salt dome.

Rulemaking Procedures

    All variances and extensions are rulemaking procedures.
Variances f.rom the treatment standard, case-by-case extensions,
and "no migration" exemptions are petition processes  (the
two-year national capacity variance is solely an EPA
determination).  EPA will publish its tentative determination
on a petition in the Federal Register.  After a 30-day comment
period, EPA will publish its final decision in the Federal
Register.

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4.  TREATMENT IN SURFACE IMPOUNDMENT EXEMPTION (SECTION 268.4)
    EPA will allow hazardous  wastes  to  be  treated  in  surface

impoundments under the following  conditions:


    •  Treatment residuals  not  meeting  the treatment  standards
       can remain in a surface  impoundment for  up  to  one  year.
       Beyond that time period,  the  treatment  residuals  that  do
       not meet the treatment standards must  be removed  and
       treated to meet the  treatment standards  before being
       disposed, and may not  be placed  into another  surface
       impoundment (treatment residuals that  do meet  the
       treatment standards  may  remain in the  surface
       impoundment).  In cases  where the volume of liquid
       wastes annually flowing  through  an  impoundment (or
       series of impoundments)  is greater  than  the capacity of
       the impoundment, this  flow-through  may constitute  annual
       removal of the supernatant for the  purposes of this
       requirement (this will not, however, constitute removal
       of any sludge residues requiring annual  removal).

    •  The surface impoundment  must  meet minimum technological
       requirements including a double  liner,  leachate
       collection system, and ground-water monitoring system, or

    •  The surface impoundment  must  meet other  alternative
       operating practices, design features,  or siting
       characteristics determined by the EPA Administrator to
       be equally protective  of human health and the
       environment.

A surface impoundment may receive a  waiver from the double
liner and leachate collection system requirements if EPA
determines that  it meets certain other  conditions, including:


    •  It has at  least one liner that  is not leaking; it is
       located  more than one-quarter mile  from an underground
       drinking  water source; and it is in compliance with the
       applicable  ground-water monitoring  requirements of RCRA
       Section  3005.

       or

    •  It is  located, designed, and operated so as to ensure
       that  no  hazardous constituents  will migrate to ground
       water  or  surface  water  in  the future.

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    Owners or operators seeking an exemption for treatment in
surface impoundments must certify to the EPA Regional
Administrator that the impoundment meets the minimum
technological requirements (or is exempt as discussed above),
and must submit a copy of the facility's waste analysis plan.

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          5.   PROHIBITION ON DILUTION (SECTION 258.3)
    The land disposal restrictions rule prohibits the dilution
of restricted wastes as a substitute for adequate treatment to
meet the treatment standards.   This provision"ensures that no
individual circumvents the intent of EPA's concentration-based
regulations by simply adding material to wastes that do not
meet the treatment standards,  rather than treating the wastes.

    Dilution as a necessary part of the waste treatment process
is allowed under the final rule.  For example, the addition of
an acidic or basic reagent to a waste in a neutralization pond
does not merely dilute the waste into a larger volume of waste;
rather, the addition of the reagent is a necessary part of the
process of chemically altering the waste so as to render it
less hazardous.

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            6.  STORAGE PROHIBITION (SECTION 268.50)
    Under the land disposal restrictions rule,  storage  of
restricted wastes is prohibited except where storage is solely
for the purpose of accumulating sufficient quantities of wastes
to facilitate proper treatment, recovery, or disposal.
Treatment, storage, and disposal facilities may store
restricted wastes for as long as needed, provided that  such
storage is solely for this purpose.  However, if the facility
stores a restricted waste for more than one year, it bears the
burden of proof, in the event of an enforcement action, that
the storage was solely for this purpose  (there is no
notification requirement for storage of more than one year).
For storage of less than one year, EPA bears the burden of
proof that such storage was not for the sole purpose of
accumulating sufficient quantities of wastes to facilitate
proper treatment, recovery, or disposal.  This prohibition on
storage does not apply to wastes which meet the treatment
standard, wastes which have been granted an extension to the
effective date, and wastes which are the subject of a "no
migration" exemption.

    For generators without a RCRA  permit or interim status, the
rules governing storage  (Section 262.34) have not changed under
the land disposal restrictions rule.  Large quantity generators
may store restricted hazardous wastes on-site for 90 days or
less without a permit or interim status.  Small quantity
generators of  100  to 1,000 kg  of hazardous  wastes per month may
accumulate wastes  for up to 180 days, or  270 days if the waste
must be transported  200  miles  or more to  a  treatment, storage,
or disposal  facility.   (The EPA Regional  Administrator  may
grant a 30-day extension to these  storage  limits on  a
case-by-case basis.)  The  land disposal  restrictions now  impose
the additional requirement that such  storage must be solely  for
the purpose  of accumulating sufficient  quantities of waste  to
facilitate proper  treatment,  recovery,  or  disposal.

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    As prior to the land disposal  restrictions,  all  generator
storage must comply with the applicable  standards  of RCRA  Part
265, including contingency planning,  preparedness  and
prevention, and personnel training.   In  addition,  generators
must store their wastes in containers or tanks  that  are clearly
marked with the words "Hazardous Waste"  and with the date  on
which the tanks or containers enter  storage.  All  container
markings must be clearly visible for  inspection.

    If compliance with the land disposal restrictions requires
storage beyond 90 days (or 180 days  for  small quantity
generator waste), generators must obtain RCRA interim status  or
a RCRA permit.  For a generator to qualify for  interim status,
the wastes must have been placed into storage in tanks or
containers before the effective date of  the restrictions.   A
generator must also demonstrate that the additional  storage
time is necessary to comply with the land disposal
restrictions.  Generators who need to obtain interim status
must submit a Part A application to EPA  by the earlier of  two
deadlines:
    •  Six months after publication of regulations which first
       require the facility to comply with RCRA Part 265.
    •  Thirty days after the date the facility first becomes
       subject to the Part 265 standards.  This is the most
       likely deadline for most generators since a generator
       first becomes subject to the permitting requirements
       when the accumulation time limit is exceeded.

Interim status granted under these conditions will apply only
to those restricted wastes identified in the Part A application,
    Generators who obtain interim status are subject to the
applicable RCRA Part 265 standards.  EPA can take corrective
action against these generators pursuant to Section 3008(h)  for
failure to comply with these standards.  EPA can also  require
the generator to submit a Part B permit application.

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    The rules governing storage at transfer facilities (Section
263.12) have not changed under the land disposal restrictions.
Transporters may store restricted wastes at a transfer facility
for up to 10 days without a permit or interim status.

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                      7.  PERMIT PROGRAM
Interim Status Facilities

    Under RCRA, treatment  facilities  operating  under  interim
status may make certain changes to their  operations which
enable them to handle new  wastes.   These  changes  include:

    •  Accepting new wastes.
    •  Increasing design capacity  (if the facilities  can
       demonstate to EPA that there is a  lack of  available
       capacity).
    •  Changing treatment, storage or disposal  processes as
       necessary to comply with state or  local  laws.

    To accept new wastes,  interim  status  facilities  must, revise
their Part A permit applications.   To increase  the design
capacity or change a treatment, storage,  or disposal  process,
an interim status facility must obtain prior approval from
EPA.  RCRA limits these changes to facility alterations and
expansions that do not exceed 50 percent  of the capital cost of
a comparable new facility.

    In a notice published in the Federal  Register on December
11, 1986, EPA proposed to give interim status treatment and
storage facilities more flexibility in managing wastes
restricted from land disposal.  EPA proposed to allow these
interim status  facilities to expand their operations by more
than 50 percent in order to treat or store restricted wastes in
tanks or containers.

Permitted FaciXities (Section  270.42)

    Prior to  the November 7, 1986  land disposal restrictions
rule, permitted treatment facilities did not have the same

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flexibility to make waste management  changes  as  interim status
facilities.  In the November 7th rulemaking,  EPA made some
changes (Section 270.42)  which will allow permitted facilities
to treat restricted wastes more promptly and  to  increase the
availability of treatment capacity.  A permitted facility may
now treat restricted wastes not identified in the permit if the
treatment is such that the treatment  residual meets the
applicable treatment standards.  In addition, permitted
facilities may treat new wastes as long as such  treatment does
not pose substantially different risks from the  risks
associated with wastes included in the permit.  These changes
require an EPA-approved minor permit modification.

    EPA proposed in the December 11,  1986 notice to give
permitted treatment and storage facilities more flexibility in
managing wastes restricted from land disposal.  EPA proposed to
allow these permitted facilities, through the minor permit
modification process, to change their operations so as to treat
or store restricted wastes in tanks or containers.  The
proposed rule would allow only  those changes needed to comply
with the land disposal restrictions rule.  These permitted
facilities would be required  to submit a major modification
request, which EPA would process at a later date, and  to  comply
with all applicable requirements of the RCRA Part 264  standards.

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         8.   TESTING AND RECORDKEEPING  (SECTION  268.7)
    The testing and recordkeeping  requirements  of  the  land
disposal restrictions rule reflect EPA's  philosophy  of tracking
wastes from generation to ultimate disposal.  All  restricted
wastes, whether treated and disposed on-site, or sent  off-site
to a RCRA treatment or disposal facility  or  to  a non-RCRA
recycling facility (although recycling facilities  may  be exempt
from RCRA regulation, the wastes they receive and  the  resulting
residues are regulated by RCRA and subject to the  land disposal
restrictions), are subject to some testing and  recordkeeping
requirements.  Generators, treatment facilities,  and land
disposal facilities each have specific responsibilities under
the land disposal restrictions rule; however,  the  land disposal
facility bears the ultimate responsibility for  ensuring that
only wastes meeting the treatment  standards (or wastes that are
subject to an exemption or variance) are  land  disposed.

Generator Responsibilities

    The generator is responsible for testing his waste or an
extract of his waste (developed by using  the TCLP),  or using
knowledge of his waste, to determine if his waste  is restricted
from land disposal.  If the generator determines that he is
managing a restricted waste, he is responsible  for determining
whether his waste meets the applicable treatment standard.  The
generator can also make this determination based either on
knowledge of the waste, or by  testing the waste or waste
extract  (developed by using the TCLP).  If the generator has
used knowledge of his waste (whether it is sent to a  treatment
facility or a disposal facility)  to determine  the applicable
treatment standard, or to  determine if the applicable standard
has been met without treatment, he must maintain records  (at
the location where the waste is generated) of  all supporting
data used to make the determination.  As prior to the land
disposal restrictions, the generator must also conduct  a waste

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analysis if there is any reason to  believe  that  the  waste
composition or the generating process  has changed; he  cannot
rely on his knowledge of the waste  in  such  cases.

    If the waste meets the treatment standard,  the generator
may transport the waste directly to the disposal facility,
providing a notice with the following  information:

    •  The EPA Hazardous Waste Number(s).
    •  The applicable treatment standard(s).
    •  The manifest number associated  with  the waste shipment.
    •  The waste analysis data (if available).

The generator must also provide a certification which states
that the waste delivered to the disposal facility meets the
treatment standard, and that the information included in the
notice is true, accurate, and complete.  If EPA has granted an
extension to the effective date for a particular waste, it is
the generator's responsibility to notify the land disposal
facility.

    For restricted wastes that do not meet  the  treatment
standard, the generator must send a notice  with each shipment
to  the treatment facility.  The generator must  determine the
appropriate  treatment standard based -on waste analysis data,
knowledge of  the waste, or both.

    Generators who  treat and/or dispose of  restricted waste
on-site must  also comply with  the recordkeeping requirements  of
treatment and/or disposal facilities  (except  for the manifest
number).

Treatment Facility  Responsibilities

    Treatment  facilities are  responsible for  treating
restricted wastes  to  the  levels specified  by  the applicable

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treatment standards,  or  by the  specified  technology(ies).   A
treatment facility also  is responsible  for:

    •  Keeping a copy of the notice and any  available  waste
       analysis data  provided by the generator  in  the  treatment
       facility's operating record.
    •  Testing the treatment residual using  the TCLP (according
       to the frequency  established in  the facility's  waste
       analysis plan) to determine whether it  meets  the  waste
       extract concentration level.
    •  Conducting a waste analysis if there  is  any reason  to
       believe that the  waste composition or the treatment
       process has changed.

    Where treatment residuals meet the treatment standards, the
treatment facility, like the generator  who ships waste directly
to a disposal facility,  must submit a notice and certification
to the disposal facility.  The certification must state that
the treatment standards  have been met in accordance with the
prohibition on dilution, and that the information is true,
accurate, and complete.

    Where treatment residuals do not meet the treatment
standards and the facility ships the residuals off-site to
another treatment facility for further treatment, the notice
requirements are the same as for the original generator sending
the wastes to the treatment facility.

Land Disposal Facility Responsibilities

    Land disposal facilities are responsible for ensuring  that
only wastes meeting  the treatment  standards (or wastes that  are
subject  to an exemption or variance) are  land disposed.   In
addition, land disposal facilities must document that the  waste
has been treated  in  accordance with  the applicable  EPA
treatment standards.  The  results  of any  waste analyses must  be
placed in the  land disposal  facility's operating record,  along
with a copy of all certifications  and  notices.

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     9.  TREATMENT STANDARDS FOR SOLVENTS  (SECTION  268.41)
What Solvent Wastes Are Covered Under the F001-F005 Listing?
(Section 268.31)

    Only solvent constituents listed in Table CCWE (Table 2 in
this booklet), when used to solubilize (dissolve)  or mobilize
other constituents, are considered spent solvents  under the
land disposal restrictions rule.  A solvent is considered
"spent" when it has been used and is no longer fit for use
without being regenerated, reclaimed, or otherwise
reprocessed.  Examples of spent solvents include solvents that
are used as degreasers, cleaners, fabric scourers, diluents,
extractants, and reaction and synthesis media.  Manufacturing
process wastes containing F001-F005 solvent constituents are
not spent solvents where the solvent constituents are reactants
and not carriers (solvents) in the process.

Basis for the Solvent Treatment Standards

    EPA identified nine treatment technologies that are
demonstrated and commercially available for F001-F005 spent
solvents.  Using data that represented only well-designed and
well-operated systems, EPA calculated average performance
values for each specific waste treated with a particular
technology.  Where one technology performed better than others,
EPA based the treatment standard on the best technology.  If
several technologies performed equally well, EPA averaged the
performance values and multiplied the average value by a
variability factor to derive the treatment standard.  The
variability factor was calculated in  to account for
fluctuations  inherent  in the normal process of well-designed
and well-operated  treatment systems.

    EPA established three separate  treatability groups for
spent solvent wastes:

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    •  Wastewaters (defined for the purposes  of Table  CCWE  as
       solvent-water  mixtures containing less than or  equal to
       1 percent total organic carbon [TOC] by weight).

    •  Methylene chloride-containing wastewaters containing
       less than or equal to 1 percent TOC  generated from
       pharmaceutical plants.

    •  All other spent solvent wastes, including wastewaters
       containing greater than 1 percent TOC, solvent-
       containing solids, solvent-containing  sludges,  and
       solvent-contaminated soils.

    Of the nine demonstrated treatment technologies, the

following four technologies formed  the basis  for the solvent
treatment standards:
    •  Steam stripping.

    •  Biological treatment.

    •  Activated carbon treatment.

    •  Incineration.


The solvent treatment standards are set as concentration levels

based on the above technologies; EPA is not requiring that

these specific technologies be used to meet the treatment

standards.  Table 2 lists the spent solvent treatment standards
expressed as concentrations in the treatment residual extract.


Effective Date of Solvent Land Disposal Restrictions (Section
268.30)

    The following spent solvent wastes (F001-F005) have been

granted the maximum two-year national variance.  Effective

November 8, 1988, these wastes are prohibited from disposal.


    •  Wastes generated by  small quantity generators of 100 to
       1,000 kg/month  of hazardous wastes.

    •  Wastes resulting from CERCLA response actions and RCRA
       corrective actions.

    •  Solvent-water mixtures,  solvent-containing sludges or
       solids, and  solvent-contaminated soil containing less
       than one  percent total F001-F005 solvent constituents.

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                           TABLE  2

                 SOLVENT TREATMENT STANDARDS3

                          TABLE CCWE
CONSTITUENTS OF
F001-F005
SPENT SOLVENT WASTES
Acetone
n-Butyl Alcohol
Carbon disulfide
Carbon tetrachloride
Chlorobenzene
Cresols (cresylic acid)
Cyclohexanone
1 ,2-Di Chlorobenzene
Ethyl acetate
Ethylbenzene
Ethyl ether
Isobutanol
Methanol
Methylene chloride
EXTRACT CONCENTRATIONS
WASTEWATER
0.05
5.00
1.05
0.05
0.15
2.82
0.125
0.65
0.05
0.05
0.05
5,00
0.25
0.20b
(mg/1)
OTHER
0.59
5.00
4.81
0.96
0.05
0.75
0.75
0.125
0.75
0.053
0.75
5.00
0.75
0.96
     aFor determining the applicable treatment standard,
wastewaters are defined as solvent-water mixtures containing
less than or equal to 1 percent total organic carbon.

     bTreatment standard for wastewaters generated from
pharmaceutical plants is 12.7 mg/1.

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TABLE 2 (CONT.)
CONSTITUENTS OF
F001-F005
SPENT SOLVENT WASTES
Methyl ethyl ketone
Methyl isobutyl ketone
Nitrobenzene
Pyridine
Tetrachloroethylene
Toluene
1, 1,1-Trichloroethane
l,l,2-Trichloro-l,2,2-tr
Trichloroethylene
Trichlorof luorome thane
Xylene
EXTRACT CONCENTRATIONS (mg/1)
WASTEWATER
0.05
0.05
0.66
1.12
0.079
1.12
1.05
if luoroethane 1.05
0.062
0.05
0.05
OTHER
0.75
0.33
0.125
0.33
0.05
0.33
0.41
0.96
0.091
0.96
0.15

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     10.   TREATMENT  STANDARDS  FOR  DIOXINS  (SECTION  268.41)
    The treatment standards for  dioxin-containing  wastes  F020,
F021, F022,  F023, F026,  F027,  and F028  are  based on
incineration to 99.9999  percent  destruction and  removal
efficiency.   The standards require treatment to  a  level  below
the routinely achievable detection limit  of 1 ppb  (using  Method
8280 in SW-846) in the waste extract for  the specific isomers
of tetra-, penta-, and hexachlorodibenzo-p-dioxins and
-dibenzofurans listed in Table CCWE.  The treatment  standards
for the chlorophenols also require treatment to  a  level  below
the routinely achievable detection limit  in the  waste extract
as listed in Table CCWE.

    Table 3 shows the dioxin-containing waste treatment
standards expressed as concentrations in  the treatment residual
extract.

Effective Date of Dioxin Land Disposal Restrictions
(Section 268.31)

    EPA has determined that there is a lack of treatment
capacity nationwide to handle dioxin wastes, therefore EPA has
granted the maximum two-year national variance to the effective
date of the dioxin land disposal restrictions to allow time  for
the regulated community to develop the necessary capacity.
Effective November 8, 1988, the F020-F023 and F026-F028
dioxin-containing wastes are prohibited from land disposal.

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                            TABLE 3

                  DIOXIN TREATMENT STANDARDS

                          TABLE  CCWE
F020-F023 AND F026-F028
DIOXIN-CONTAINING WASTES
   EXTRACT
CONCENTRATIONS
HxCDD - All Hexachlorodibenzo-p-dioxins

HxCDF - All Hexachlorodibenzofurans

PeCDD - All Pentachlorodibenzo-p-dioxins

PeCDF - All Pentachlorodibenzofurans

TCDD - All Tetrachlorodibenzo-p-dioxins

TCDF - All Tetrachlorodibenzofurans

2,4,5-Tr i chlorophe nol

2,4,6-Trichlorophenol

2,3,4,6-Tetrachlorophenol

Pentachlorophenol
   < 1 ppb

   < 1 ppb

   < 1 ppb

   < 1 ppb

   < 1 ppb

   < 1 ppb

   < 0.05 ppm

   < 0.05 ppm

   < 0.10 ppm

   < 0.01 ppm
ppb = ug/1
ppm = mg/1
 0503K

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                Appendix A

 Information Requirements for a Petition
for a Variance From the Treatment  Standard

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                          Appendix A

            Information Requirements  for  a Petition
           for a Variance From the Treatment Standard
A petition from the treatment standard must include the
following information:


    •  The petitioner's name and address.

    •  The name, address, phone number, and EPA identification
       number of the generating facility and of the facility
       contact person.

    •  A description of the waste generating processes and feed
       materials.

    •  A detailed description of the petitioner's waste
       (including data and information on the physical and
       chemical characteristics of the waste) that EPA can use
       to compare the,petitioner ' s waste to the wastes
       considered by EPA in developing BDAT.

    •  If the waste has been treated, a description of the
       treatment system, including the process design,
       operating conditions, and an explanation of why the
       treatment standards cannot be achieved using the
       treatment system, or an explanation of why the specified
       treatment technology is inappropriate for the
       petitioner's waste.

    •  If the waste has not been treated, an explanation of why
       the petitioner believes the waste will react to
       treatment differently from the wastes evaluated by EPA
       in developing  the treatment standard.

    •  A description  of any alternative.treatment systems
       examined by  the petitioner, and, as appropriate, the
       concentrations in the treatment  residual  (using the
       TCLP)  that can be achieved by  applying such treatment  to
       the waste.

    •  The dates of the  sampling and  testing.

    •  A description  of  the  methodologies  and  equipment used  to
       obtain representative samples.

    •  A description  of  the  sample handling  and  preparation
       techniques.

    •  A description  of  the  tests performed  (including results)

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                 Appendix B

Information Requirements for a Petition for a
Case-by-Case Extension  to the Effective Date

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                          Appendix B

         Information Requirements for  a Petition for  a
         Case-by-Case Extension  to the Effective Date


A case-by-case petition must include  the following  information:

    •  A demonstration that a good faith effort has been made
       to locate and contract with hazardous waste  treatment,
       recovery, or disposal facilities nationwide  to handle
       the waste.

    •  A demonstration that the petitioner has entered into a
       binding contract to construct  or otherwise provide
       adequate treatment, recovery,  or disposal capacity for
       the waste.

    •  A demonstration that, due to circumstances beyond the
       petitioner's control, alternative treatment, recovery,
       or disposal capacity cannot reasonably be made available
       by the effective date of  the land disposal restriction.

    •  A demonstration that the  capacity being constructed or
       otherwise provided will be sufficient to manage the
       waste.

    «  A detailed schedule for obtaining all necessary
       operating and construction permits and an outline of  how
       and when alternative capacity will be available.

    •  A demonstration that arrangements have been made  for
       adequate capacity  to manage the waste during  the
       extension.  This demonstration must  include an
       identification and description of all waste management
       sites.

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                 Appendix C

Information Requirements for a Petition for a
           "No Migration" Exemption

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                          Appendix C

         Information Requirements for  a Petition for  a
                    "No Migration" Exemption
A "no migration" petition must include the following

information:
    •  The identification and a full characterization of the
       specific waste, including a comprehensive chemical and
       physical characterization.

    •  The identification and a comprehensive characterization
       of the disposal unit, including background air, soil,
       and water quality.

    •  A demonstration that all waste and environmental
       sampling, test, and analysis data are accurate and
       reproducible.

    •  A demonstration that EPA-approved sampling, testing, and
       estimation techniques were used.

    •  A demonstration that all simulation models for the
       specific waste and disposal site conditions were
       calibrated, and that the models were verified by actual
       measurements.

    •  Analyses performed to identify and quantify any aspects
       that could contribute significantly to uncertainty
       regarding the  suitability of the site, including the
       potential for  damage from earthquakes, floods, severe
       storms, droughts, or other natural phenomena.

    •  A quality assurance and quality control plan that
       addresses all  aspects of the "no migration"
       demonstration.

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    Title III of SARA
Community Right-to-Know

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TITLE III FACT  SHEET
 EMERGENCY PLANNING AND
 COMMUNITY RIGHT-TO-KNOW
                                                                       EPA
U.S. Environmental Protection Agency
INTRODUCTION

On October 17,1986, the
"Superfund Amendments and
Reauthorization Act of 1986"
(SARA) was enacted into law.  One
part of the new SARA provisions is
Title HI:  the Emergency Planning
and Community Right-to-Know
Act of 1986.  Title HI establishes
requirements for Federal, State, and
local governments and industry
regarding emergency planning and
'community right-to-know'
reporting on hazardous and toxic
chemicals. This legislation builds
upon EPA's Chemical Emergency
Preparedness Program (CEPP) and
numerous State and local programs
aimed at helping communities to bet-
ter meet their responsibilities in
regard to potential chemical emer-
gencies. The community right-to-
know provisions of Title HI will
help to increase the public's knowl-
edge and access to information on
the presence of hazardous chemi-
cals in their communities and
releases of these chemicals into the
environment.

Title III has four major sections:
emergency planning (§301 -
§303), emergency notification
(§304), community right-to-know
reporting requirements (§311,
312), and toxic chemical release
reporting - emissions inventory
(§313).
§301-303:  Emergency
      Planning:

The emergency planning sections
are designed to develop State and
local governments' emergency
                             response and preparedness capa-
                             bilities through better coordination
                             and planning, especially within the
                             local community.

                             Title III requires that the Governor
                             of each State designate a State emer-
                             gency response commission by
                             April 17,1987. If a State commis-
                             sion is not designated, the Gover-
                             nor will operate as the commission
                             until the Governor makes such des-
                             ignation. While existing State
                             organizations can be designated as
                             the State emergency response com-
                             mission, the commission can have
                             broad-based representation.  Public
                             agencies and departments con-
                             cerned with issues relating to the
                             environment, natural resources,
                             emergency services, public health,
                             occupational safety, and transporta-
                             tion all have important roles in Title
                             III activities. Various public and
                             private sector groups and associa-
                             tions with interest and exper-
                             tise in Tide III issues also can be
                             included in the State commission.

                             The State commission must desig-
                             nate local emergency planning dis-
                             tricts by July 17,1987, and appoint
                             local emergency planning commit-
                             tees within one month after a dis-
                             trict is designated. The State com-
                             mission is responsible for supervis-
                             ing and coordinating the activities
                             of the local emergency planning
                             committees, for establishing proce-
                             dures for receiving and processing
                             public requests for information col-
                             lected under other sections of Title
                             III, and for reviewing local emer-
                             gency plans.

                             This local emergency planning com-
                             mittee must include elected State
                                              1
and local officials, police, fire, civil
defense, public health profes-
sionals, environmental, hospital,
and transportation officials as well
as representatives of facilities sub-
ject to the emergency planning
requirements, community groups,
and the media.  No later than Sep-
tember 17,1987, facilities subject
to the emergency planning require-
ments must designate a representa-
tive to participate in the planning
process. The local committee  must
establish rules,  give public notice of
its activities and establish proce-
dures for handling public requests
for information.

The local committee's primary
responsibility will be to develop an
emergency response plan by Octo-
ber 17,1988. In developing this
plan, the local committee will  evalu-
ate available resources for preparing
for and responding to a potential
chemical accident. The plan must
include:

• Identification of facilities and
  extremely hazardous substances
  transportation routes

• Emergency response procedures,
  on-site and off-site

• Designation of a community coor-
  dinator and facility coordinator(s)
  to implement the plan

• Emergency notification proce-
  dures

• Methods for determining the
  occurrence of a release and the
  probable affected area and
  population

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Key Dates to Remember

November 17,1986
November 17,1986


January 27,1987



March 17.1987



April 17.1987


May 17,1987
June 1.1987
July 17.1987
August 17.1987
(or 30 days after
designation of dis-
tricts, whichever is
sooner)

September 17.1987
(or 30 days after
committee is formed,
whichever is earlier)

October 17,1987
March 1,1988
(and annually there-
after)

April 17.1988
(Continued on page 5)
EPA published List of Extremely Hazardous
Substances and Planning Threshold Quantities
in Federal Register (§302,303,304)

EPA initiates comprehensive review of
emergency systems (§305(b))

Format for Emergency Inventory Forms and
reporting requirements published in Federal
Register (§311,312)

National Response Team publishes guidance for
preparation and implementation of emergency
plans (§303(f))

State governors appoint State emergency
response commissions (§301 (a))

Facilities subject to Section 302 planning
requirements notify State emergency
response commission (§302(c))

Interim report on emergency system review due
to Congress (§305(b))

EPA publishes toxic chemical release
(i.e., emissions inventory) form (§313(g))
State emergency response commission
designates emergency planning districts
(§301 (b))

State emergency response commission appoints
 members of local emergency planning
committees (§301 (c))
Facility notifies local planning committee of
selection of a facility representative
(§303(d)(1))
 MSDS or list of MSDS chemicals submitted to
 State commission, local committee and local
fire department (§311 (d))

Facilities submit their emergency
 inventory forms to State commission, local
committee and local fire department (§312(a)(2))

 Rnal Report on emergency systems study due
 to Congress (§305(b))
• Description of community and
  industry emergency equipment
  and facilities and the identity of
  persons responsible for them

• Evacuation plans

• Description and schedules of a
  training program for emergency
  response personnel

• Methods and schedules for exer-
  cising emergency response plans.

In order to assist the local commit-
tees in preparing and reviewing
plans, Congress required the
National Response Team (NRT),
composed of 14 Federal agencies
with emergency response responsi-
bilities, to publish guidance on
emergency response planning.
This guidance, the Hazardous Mate-
rials Emergency Planning Guide,
will be published  by the NRT and
incorporates emergency planning
aspects of the CEPP Interim Guid-
ance. It also replaces the Federal
Emergency Management Agency's
Planning Guide and Checklist for
Hazardous Materials Contingency
Plans (popularly know as FEMA-
 10). See Federal Register dated
 12/2/86.

The emergency response plan must
be reviewed by the State commis-
sion as well as annually by the
local committee.  The Regional
Response Teams, composed of the
Federal Regional officials and State
representatives, may review the
plans and provide assistance to the
local committees  upon request.

Those planning activities of the
local committees  and facilities
should be focused on, but not lim-
ited to, the 402 extremely hazard-
ous substances published in the
November 17,1986, Federal Regis-
ter. The list included the threshold
planning quantities for each sub-
stance.  EPA can  revise the list and
threshold planning quantities based
on the toxicity, reactivity, volatil-
ity, dispersability, combustability,
 or flammability of a substance.   I

 Any  facility that produces, uses, or
 stores any of the listed chemicals in

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a quantity greater than its threshold
planning quantity is subject to the
emergency planning requirements.
In addition, the State commission
or the Governor can designate
  >ditional facilities, after public
  mment, to be subject to these
requirements. By May 17,1987,
covered facilities must notify the
State commission that they are sub-
ject to these requirements. If a facil-
ity begins to produce, use, or store
any of the extremely hazardous sub-
stances in threshold quantity
amounts, it must notify the State
commission within 60 days.

Each State commission must notify
EPA of all facilities subject to the
emergency planning requirements,
including facilities designated by
the State commission or the
Governor.

§304:  Emergency
       Notification

Facilities must immediately notify
the local emergency planning com-
mittee and the State emergency
response commission if there is a
    Ease of a listed hazardous sub-
    ce that exceeds the reportable
    ntity for that substance.  Sub-
stances subject to this requirement
are substances on the list of 402
extremely hazardous substances as
published in Federal Register on
11/17/86 and substances subject to
the emergency notification require-
ments under CERCLA Section
103(a).

The initial notification can be by tele-
phone, radio, or in person. Emer-
gency notification requirements
involving transportation incidents
can be satisfied by dialing 911, or
in the absence of a 911 emergency
number, calling the operator.

This emergency notification needs
to include:

• The chemical name
    n indication of whether the sub-
    ance is extremely hazardous
• An estimate of the quantity
  released into the environment
• The time and duration of the
  release

• The medium into which the
  release occurred

• Any known or anticipated acute
  or chronic health risks associated
  with the emergency, and where
  appropriate, advice regarding med-
  ical attention necessary for
  exposed individuals

• Proper precautions, such as evacu-
  ation

• Name and telephone number of
  contact person.

Section 304 also requires the fol-
low-up written emergency notice
after the release.  The follow-up
notice or notices shall:

• Update information included in
  the initial notice, and

• Provide information on:

  - Actual response actions
   taken

  - Any known or anticipated data
   or chronic health risks associ-
   ated with  the release

  - Advice regarding medical atten-
   tion necessary for exposed indi-
   viduals.

Until State commissions and local
committees are formed, releases
should be reported to appropriate
State and local officials.

§311-312:  Community Right-
       to-Know Reporting
       Requirements

There are two "community right-to-
know" reporting requirements
which apply primarily to manufac-
turers and importers. Section
311 requires that facilities which
must prepare  or have available mate-
rial safety data sheets (MSDS)
under the Occupational Safety and
Health Administration (OSHA) reg-
ulations to submit either copies of
its MSDS or a list of MSDS chemi-
cals  to:
• The local emergency planning
  committee

• The State emergency response
  commission

• The local fire department.

If the facility owner or operator
chooses to submit a list of MSDS
chemicals, the list must include the
chemical name or common name of
each substance and any hazardous
component as provided on the
MSDS. This list must be organized
in categories of health and physical
hazards as set forth in OSHA regu-
lations unless modified by EPA.

If a list is submitted, the facility
must submit the MSDS for any
chemical on the list upon the
request of the local planning com-
mittee.  Under Section 311,  EPA
may establish threshold quantities
for hazardous chemicals below
which no facility must report.

The initial submission of the
MSDSs or list is required no later
than October 17,1987, or 3 months
after the facility is required to pre-
pare or have available an MSDS
under OSHA regulations. A
revised MSDS must be provided to
 update MSDS which were
originally submitted if significant
 new information regarding a chemi-
cal is discovered.

The reporting requirement of Sec-
 tion 312 involves submission of
 an emergency and hazardous chemi-
 cal inventor}' form to the local emer-
 gency planning committee, the State
emergency response commission
 and the local fire department. The
 hazardous chemicals covered by
Section 312 are the same for
which facilities are required to sub-
mit MSDS or the list for Section
311.

 Under Section 312, EPA may
 also establish threshold quantities
 for hazardous chemicals  below
 which no facility must be subject to
 this requirement.

The inventory form incorporates a
 two-tier approach.  Under Tier I,

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facilities must submit the following
aggregate information for each appli-
cable OSHA category of health and
physical hazard:

• An estimate (in ranges) of the
  maximum amount of chemicals
  for each category present at the
  facility at any time during the pre-
  ceding calendar year

• An estimate (in ranges) of the
  average daily amount of chemi-
  cals in each category

• The general location of hazardous
  chemicals in each category.

Upon request of a local  committee,
State commission or local fire
department, the facility  must pro-
vide the following Tier  II informa-
tion for each substance subject to
the request:

• The chemical name or the com-
  mon name as indicated on the
  MSDS

• An estimate (in ranges) of the
  maximum amount of the  chemical
  present at any time during the pre-
  ceding calendar year

• A brief description of the manner
  of storage of the chemical

• The location of the chemical at the
  facility

• An indication of whether the
  owner elects to withold location
  information from disclosure to
  the public.

The public  may also request Tier II
information from the State  commis-
sion and the local committee. The
information submitted by facilities
under Sections 311 and 312
must generally be made available to
the public by local and State govern-
ments during normal working
hours.

EPA published a uniform format
for the inventory forms on  January
27,1987. Tier I information shall
be submitted on or before March 1,
1988, and annually thereafter on
March 1.

§313:  Toxic Chemical
       Release Reporting

Section 313 of Title III requires
EPA to establish an inventory of
toxic chemical emissions from cer-
tain facilities. Facilities subject to
this reporting requirement are
required to complete a toxic chemi-
cal release form for specified chemi-
cals. The form must be submitted
to EPA and those State officials des-
ignated by the Governor, on or
before July 1,1988, and annually
thereafter on July 1, reflecting
releases during each preceding cal-
endar year.

The purpose of this reporting
requirement is to inform govern-
ment officials and the public  about
releases of toxic chemicals in the
environment. It will also assist in
research and the development of reg-
ulations, guidelines, and standards.

The reporting requirement applies
to owners and operators of facilities
that have 10 or more full-time
employees, that are in Standard
Industries Classification Codes 20
through 39 (i.e., manufacturing
facilities) and that manufactured,
processed or otherwise used a listed
toxic chemical in excess of speci-
fied threshold quantities.

Facilities using listed toxic chemi-
cals in quantities over 10,000
pounds in a calendar year are
required to submit toxic chemical
release forms by July 1 of the
following year. Facilities manufac- /
turing or processing any of these
chemicals in excess of 75,000
pounds in 1987 must report by July
1,1988.  Facilities manufacruring
or processing in excess of 50,000
pounds in 1988 must report by July
1,1989; thereafter, facilities manu-
facturing or processing more than
25,000 pounds in a year are
required to submit the form.  EPA
can revise these threshold quantities
and covered SIC categories.
The list of toxic chemicals subject
to reporting consists initially of
chemicals listed for similar
reporting purposes by the States of
New Jersey and Maryland. There
are over 300 chemicals and
categories on these lists.  EPA can
modify this combined list. In add-
ing a chemical to the combined
Maryland and New Jersey lists,
EPA must consider the following
factors:

• Is the substance known to cause
  cancer or serious reproductive or
  neurological disorders, genetic
  mutations, or other chronic health
  effects?

• Can the substance cause signifi-
  cant adverse acute health effects
  outside the facility as a result of
  continuous or frequently recur-
  ring releases?

• Can the substance cause an
  adverse effect on the environment
  because of its toxicity, persist-
  ence, or tendency to
  bioaccumulate?

Chemicals can be deleted if there
insufficient evidence to establish
any of these factors. State gove-
nors may petition the Administ-
to add or delete a chemical fror
list for any of the above  reason
Any person may petition for tv
first two reasons.

Through early consultation with
States or EPA Regions, petitioners
can avoid duplicating previous peti-
tions and be assisted in locating
sources of data already collected or
the problem of concern to support
their petitions. EPA will conduct
information searches on chemicals
contained in a petition, focusing on
the effects the petitioners believes
warrant addition or deletion.

EPA is required to publi •'. a format
for the Toxic Chemical    ^ase
form by June 1,1987. 1
following information ir . t be
included:

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• The name, location and type of
  business

• Whether the chemical is manufac-
  tured, processed, or otherwise
  used and the general categories of
  use of the chemical

• An estimate (in ranges) of the
  maximum amounts of the toxic
  chemical present at the facility at
  any time during the preceding
  year

• Waste treatment/disposal methods
  and efficiency of methods for
  each wastestream

• Quantity of the chemical entering
  each environmental medium
  annually

• A certification by a senior official
  that the report is complete and
  accurate.

EPA must establish and maintain a
national toxic chemical inventory
based on the data submitted. This
information must be computer  acces-
sible on a national database.

In addition to the requirements for
the emissions inventory in Section
313, EPA will arrange for a mass
balance study to be carried out by
the National Academy of Sciences
using information collected from
States that conduct a mass balance-
oriented annual quantity toxic chemi-
cal release program.  Mass balance
           is the accounting of the total quan-
           tity of substances brought into a
           facility versus the amount that is
           shipped out. The difference is an
           indication of the amount released
           into the environment. A report of
           this study must be submitted by
           EPA to Congress no later than Octo-
           ber 17,1991.

           The purpose of this study is to
           assess the value of obtaining mass
           balance information to determine
           the accuracy of information on toxic
           chemical releases. Also, the study
           will assess the value of using the
           information for determining the
           waste reduction efficiency and for
           evaluating toxic chemical manage-
           ment practices at categories of
           facilities. In addition, the study
           must determine the implications of
           mass balance information collected
           on a national scale including for use
           as part of a national annual quantity
           toxic chemical release program.

           Other Title III Provisions

           Section 322 of Title III addresses
           trade secrets and applies to emer-
           gency planning, community right-to-
           know, and toxic chemical release
           reporting. Any  person may withold
           the specific chemical identify of a
           hazardous chemical for specific rea-
           sons.  Even if the chemical identity
           is withheld, the generic class or cate-
           gory of the chemical must be pro-
           vided. The withholder must show
           each of the following:
    Key Dates to Remember
    (Continued from page 2)
    July 1.1988
    (and annually there-
    after)

    October 17,1988
    June 30,1991
    October 17,1991
Covered facilities submit initial toxic
chemical forms to EPA and designated State
officials (§313(a))

Local emergency planning committees
complete preparation of an emergency plan
(§303(a))

Comptroller general report to Congress on
toxic chemical release information collection,
use and availability (§313(k))

EPA report to Congress on Mass Balance Study
(§313(1))
• The information has not been dis-
  closed to any other person other
  than a member of the local plan-
  ning committee, a government
  official, an employee of such per-
  son or someone bound by a confi-
  dentiality agreement, that meas-
  ures have been taken to protect
  the confidentiality, and that the
  withholder intends to continue to
  take such measures

• The information is not required to
  be disclosed to the public under
  any other Federal or State law

• The information is likely to cause
  substantial harm to the competi-
  tive position of the person

• The chemical identity is not read-
  ily discoverable through reverse
  engineering.

However, even if chemical identity
information can be legally withheld
from the public, Section  323 pro-
vides for disclosure under certain
circumstances to  health profes-
 sionals who need the information
 for diagnostic purposes or from
local health officials who need the
 information for assessment
 activities. In these cases, the per-
 son receiving the information must
 be willing to sign a confidentiality
 agreement with the facility.

 Information claimed as trade secret
 and substantiation for that claim
 must be submitted to EPA. This
 includes information that otherwise
 would be submitted only to State or
 local officials, such as the emer-
 gency and hazardous material inven-
 tory (§312). People may chal-
 lenge trade  secret claims by
 petitioning EPA, which must then
 review the claim and rule on its
 validity.

 EPA must publish regulations
 governing trade secret claims. The
 regulations  will cover the process
 for submission of claims, petitions
 for disclosure and a review process
 for these petitions.

 Secton 305 of Title III authorizes
 the Federal  Emergency Manage-
 ment Agency to provide $5 million

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                                Summary for Chemical Lists for Title III
LIST
Section
           Purpose
List of Extremely
Hazardous Substances
(FR 11/17/86)
[402 substances]
§302: Emergency
      Planning
§304: Emergency
      Notification
Substances requiring      §304:
notification under Section
103(a)ofCERCLA
[717 substances]

Hazardous Chemicals     §304:
considered physical or
health hazards            §311:
under OSHA's
Hazard Communication   §312:
Standard
[This is a performance
standard, mere is no
specific list of chemicals]
Toxic Chemicals         §313:
identified as of concern by
States of New Jersey and
Maryland
[329 chemicals/chemical
categories]
      Emergency
      Notification
      Emergency
      Notification
      Material Safety
      Data Sheets
      Emergency
      Inventory
      Toxic Chemical
      Release Reporting
Facilities with more than established planning
quantities of these substances must notify the State
commission

Initial Focus for preparation of emergency plans by
local emergency planning committees

Certain releases of these substances trigger Section
304 notification to State commission and local
committees

Certain releases of these substances trigger Section
notification to State commission and local
committees as well as Section 103(a) requirement
for National Response Center notification

Identifies facilities subject to emergency
notification requirements

MSDS or list of MSDS chemicals
provided by covered facilities to State
commission, local committee,
and local fire department

Covered facilities provide site-specific
information on chemicals to State
commission, local committees and
local fire departments

These chemicals are reported on an
emissions inventory to inform government
officials and the public about releases of
toxic chemicals in the environment.

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for each of fiscal years 1987,1988,
1989, and 1990 for training grants
to support State and local govern-
ments. These training grants are
designed to improve emergency
planning, preparedness, mitigation,
response, and recovery capabilities.
Such programs must provide spe-
cial emphasis to hazardous chemical
emergencies. The training grants
may not exceed 80 percent of the
cost of any such programs. The
remaining 20 percent must come
from non-Federal sources.

Under Section 305, EPA is
required to review emergency sys-
tems for monitoring, detecting,  and
preventing releases of extremely
hazardous substances at representa-
tive facilities that produce, use,  or
store these substances. EPA will
report interim findings to Congress
no later than May 17,1987 and
issue a final report of findings and
recommendations to Congress by
April  17,1988.
The report must include EPA's find-
ings regarding each of the
following:

• Status of current technological
  capabilities to (1) monitor, detect,
  and prevent significant releases of
  extremely hazardous substances;
  (2) determine the magnitude and
  direction of the hazard posed by
  each release; (3) identify specific
  substances; (4) provide data on
  specific chemical composition of
  such releases; and (5) determine
  relative concentration of the con-
  stituent substances.

• Status of public emergency alert
  devices or systems for effective
  public warning of accidental
  releases of extremely hazardous
  substances into any media.

• The technical and economic feasi-
  bility of establishing,
  maintaining, and operating  alert
  systems for detecting releases.
The report must also include EPA's
recommendations for:

• Initiatives to support development
  of new or improved technologies
  or systems that would assist the
  timely monitoring, detection, and
  prevention of releases of
  extremely hazardous substances.

• Improving devices or systems for
  effectively alerting the public in
  the event of an accidental release.
For more information on Title III and
EPA's Chemical Emergency Prepared-
ness Program, contact the CEPP
Hotline:

1-800-535-0202
(in Washington. D.C. (202) 479-2449)

Hours: 8:30 am - 4:30 pm (EST),
Monday-Friday

This Is NOT an emergency
number
                                 Title III - Major Information Flow Requirements
     Guidance/
     Assistance
    (§303 & §305)
                                                    Emergency
                                                  Response Plan
                               Designated
                              State Official
                     Emergency
                     Notification
                       (§304)
              Toxic Chemical
               Release Form
                  (§313)
                                                Emergency
                                                 Planning
                                               (§301 -6303)
                                 MSDS or
                                   LIST
                                  (§311)
                                                                                  Emergency
                                                                                   Inventory
                                                                                    !§312)
                 FACILITIES
            BUB oovziunuitT nurnio ornci  1W7 - 713-872 - U02/UIO

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Liability Issues for Source Reduction,
      Recycle, and Treatment

         Robert A. Wyman

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                      TABLE OF CONTENTS

I.  INTRODUCTION 	     1

II.  HSWA:  WASTE TREATMENT AND MINIMIZATION REQUIRE-
     MENTS 	     2

     A.  LAND DISPOSAL BAN   	     2

          1.  Disposal prohibitions  	     2

          2.  Timetable for compliance 	     2

          3.  Exemptions and variances 	     3

          4.  Storage prohibitions 	     4

          5.  Treatment standards  	     5

          6.  Testing and recordkeeping requirements . .     5

               a.  Generator requirements  	     6

               b.  Treatment facility requirements ...     7

               c.  Land disposal facility requirements .     7

          7.  Generator liability for non-compliance
               with land disposal restrictions  	    7

     B.  WASTE MINIMIZATION  	    8

          1.  Statutory requirements 	    8

          2.  Description of waste minimization
               activities   	    9

          3.  Generator liability for non-compliance
               with waste minimization requirements   . .    10

III.   COMPLYING WITH WASTE TREATMENT AND MINIMIZATION
     REQUIREMENTS:  GENERATOR OPTIONS AND THE "LIABILITY
     HIER-ARCHY"	    11

     A.  OPTION ONE:  SOURCE REDUCTION 	    12

          1.  Liability considerations 	    12

          2.  Other considerations  	    12

     B.  OPTION TWO:  RECYCLING AND RESOURCE RECOVERY  .    13

          1.  Liability considerations 	    14

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     2.  Other considerations 	   15

C.  OPTION THREE:  TREATMENT AND LAND DISPOSAL  . .   15

     1.  Liability considerations 	   16

          a.  Statutory liability 	   16

               (1)  RCRA	   16

               (2)  CERCLA	   17

          b.  Common law liability	   18

          c.  Recommendations	   19

     2.  Other considerations 	   20

          a.  Obtaining an exemption or variance
               from the land disposal restrictions    20

          b.  Off-site treatment and disposal:
               capacity limitations 	   21

          c.  On-site treatment and disposal:
               permitting difficulties  	   23

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I.  INTRODUCTION

          This country spends more than 70 billion dollars
each year on environmental protection and compliance.   A
large part of this expenditure has been directed towards the
proper management and disposal of hazardous wastes as
specified in the Resource Conservation and Recovery Act of
1976 (RCRA) (42 U.S.C. § 6901 et sea.). and the Comprehensive
Environmental Response, Compensation and Liability Act of
1980 (CERCLA)  (42 U.S.C. § 9601 e± seq.).

          The Office of Technology Assessment (O.T.A.)
estimates that industry today produces at least 575 million
tons of hazardous wastes per year.  Furthermore, EPA has
concluded that many parts of the country lack or will soon
lack adequate treatment and disposal capacity to deal with
the volume of hazardous waste generated. Even where there is
sufficient treatment and disposal capacity, the treatment or
disposal methods have failed to eliminate, or even reduce to
acceptable levels, the risk of an unintentional release.  At
the same time, industry has sought ways to reduce
liabilities associated with hazardous substance handling and
disposal.  These trends have motivated federal and state
legislatures to focus attention towards waste reduction
strategies such as recycling and source reduction and away
from "end-of-the-pipe" solutions such as the permitting of
new landfills and waste treatment, storage and disposal  (TSD)
facilities.

          By amending RCRA in 1984, Congress established
hazardous waste reduction as a national priority.  See 42
U.S.C. §6902(b).  These amendments, known as The Hazardous
and Solid Waste Amendments of 1984  (HSWA), impose substantial
new legal responsibilities on hazardous waste generators,
treaters, and disposers.  HSWA creates a presumption  against
land-based disposal by requiring that hazardous waste
generators voluntarily institute in-house waste minimization
programs, meet pre-disposal treatment  standards for certain
hazardous wastes, and equip new landfills and other waste
disposal facilities with additional technological controls
prior to receiving wastes.

          This paper addresses the  legal  incentives that
HSWA and related EPA regulations create  to reduce hazardous
waste production.  Specific land disposal and waste minimiza-
tion requirements of HSWA are described,  followed by  a
discussion of three compliance options  currently available to
hazardous waste generators:   source reduction,  recycling  and
resource recovery, and treatment and  land disposal.   Each
option is  analyzed in terms of the  liability risks and/or
protections it provides, as well as other general short  and
long-term  considerations that a generator should take into
account before selecting a particular option.

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II.   HSWA;  WASTE TREATMENT AND MINIMIZATION REQUIREMEHTS

      A.   LAND  DISPOSAL  BAN

           1.   Disposal  prohibitions

                 HSWA mandates that the continued land disposal
of untreated hazardous  wastes beyond specified dates is
prohibited1 unless EPA  determines that the prohibition is
not  necessary  in order  to protect human health and the
environment for as long as the waste remains hazardous.  RCRA
§§ 3004  (d),(e),(g);  42 U.S.C. §6924(d),(e),(g) .   In
addition,  HSWA requires EPA to identify levels or  methods  of
treatment,  if  any, that substantially diminish the toxicity
or migration potential  of a waste and minimize threats to
human health and the  environment.  Wastes treated  in
accordance with standards set under this  section are not
subject  to  the prohibition and may be land disposed.  RCRA
§3004(m).2
            The disposal restrictions apply prospectively to persons
            who generate or transport hazardous waste and to owners
            and operators of hazardous waste treatment, storage, and
                     facilities, including both interim status and
            permitted facilities.  51 Fed. Reg. 40638  (Nov. 7,
            1986), to be codified at 40 C.F.R. §268.1.  "Land
            disposal" is defined to include placement  in a landfill,
            surface impcundment, waste pile, injection well, land
            treatment facility, salt dome formation, salt bed
            formation, underground mine or cave, concrete vault or
            bunker intended for disposal purposes,  or  placement in
            or on land by means of open detonation and open burning
            where the residues continue to exhibit one or more
            characteristics of hazardous waste.  51 Fed. Reg. 40638
             (Nov. 7, 1986), to be codified at 40 C.F.R. § 268. 2(a).
             Determinations regarding injection well and surface
             iiqpoundment disposal are treated differently.  Under
             RCRA §3004(f), EPA is to review deep well injection
             methods for liquid hazardous wastes, solvents, and
             dioxins by August 1988.  Under RCRA §3005(j), wastes
             treated in surface inpcundments are exempted from the
             land disposal restrictions if  the impoundments meet the
             minimum technological requirements of RCRA §3004(0)
             (with limited exceptions) and  the treatment residues
             which are hazardous are removed for subsequent manage-
             ment within one year of the entry of the waste into the
             surface impoundment..

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               HSWA sets  forth  a  detailed timeline for EPA
determination of treatment  standards.   If the Agency fails to
meet a statutory deadline,  further land disposal of the
affected group of wastes  is automatically prohibited or
conditionally prohibited  under  a  hammer provision.  EPA was
required to set treatment standards for F001-F005 solvents
and dioxin wastes by November 8,  1986,  and for "California
List" wastes by July 8, 1987.   The Agency has completed both
sets of standards.  51  Fed.  Reg.  40642  (Nov.  7,  1986), to be
codified at 40 C.F.R. §268  Subpart D;  52 Fed. Reg. 25760
(July 8, 1987), to be codified  at 40 C.F.R.  §268.4.  Further-
more, the Agency must review and set standards for the first
one-third of its remaining  listed wastes by August 8, 1988;
the second one-third by June 8, 1989;  and the last one-third
by May 8, 1990.   (For a schedule  of specific listed wastes to
be evaluated, see 40 CFR  Subpart  B, §268.10-.13).

          3.  Exemptions  and variances

               A generator  (or  any interested person) may
petition that a certain waste be  exempted from the land
disposal restrictions.  The petitioner must demonstrate, to a
reasonable degree of certainty, that there will be no
migration of hazardous  constituents from the land disposal
unit or injection zone  (including air emissions)  for as long
as the waste remains hazardous.  RCRA §§3004(d)(1),  (e)(1),
and  (g)(5).

                In addition  to an exemption, three types of
variances are available under the statute: (1) variance based
on lack of national  capacity;  (2) variance from the treatment
standard; and  (3) case-by-case extensions.

                First,  EPA can grant a national variance of up
to two years if the  Agency  determines there  is a  nationwide
lack of capacity  to  treat specific wastes.   Because EPA has
determined that the  land  disposal restrictions will create a
national shortage of wastewater treatment and incineration
capacity, the Agency has  granted such a variance  for  (1)
small quantity  generators of 100-1000 kilograms of non-acute
hazardous waste per  month or less than one kilogram of  acute
hazardous waste per  month,   (2)  solvent wastes generated by
response or  corrective actions taken under CERCLA or  RCRA,
and  (3) dilute  F001-F005  solvent wastes containing less than
1% total organic  constituents.3  As a result, these
            The variance granted by EPA for dilute solvent wastes is
            currently being challenged by the Hazardous Waste Treatment
            Council (HWTC)  and other groups (HWTC v. EPA. CADC No. 86-
            1657).   These groups claim that EPA's interpretation of the
            variance provisions, which allows exempted wastes to be
            disposed of in  RCRA - approved facilities, will allow these

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subgroups do not have to comply with treatment standards
until November 8, 1988 provided that their wastes are managed
in facilities that are in compliance with  the requirements of
RCRA §3004(o) (Landfills or other hazardous waste facilities
receiving permits after November 8, 1984,  must contain double
liner with leachate collection and  leak detection systems and
groundwater monitors).   51 Fed. Reg.  40579 (November 7,
1986), to be codified at 40 C.F.R.  §268.30.

               Second, a generator  may request a variance
from the treatment standard if the  waste produced is a unique
waste that cannot be treated  to the levels specified as the
treatment standard because, for example, the waste does not
fit into one of the Best Demonstrated  Available Technology
(BOAT) treatability groups.   51 Fed. Reg.  40605 (November 7,
1986).

               Third, the Agency will  consider granting indi-
vidual extensions of up to two years  if the applicant can
demonstrate:  (1) that a good-faith effort has been made to
locate and contract with alternative  technologies nationwide;
(2) that a binding contract has been  entered into to con-
struct or otherwise provide alternative treatment, recovery,
or disposal capacity that cannot reasonably be made available
by the applicable effective date due  to circumstances beyond
the applicant's control.  In  demonstrating that capacity
cannot reasonably be made available,  the applicant may  show
that it is not feasible to provide such capacity because of
technical and practical difficulties;  and  (3) that the
capacity will be sufficient to manage all of the waste
covered by the application.   In  addition,  an applicant  must
provide a detailed schedule  for  providing capacity and
document locations with adequate  capacity to manage its
wastes during the extension.  Any  landfill or surface
impoundment receiving waste during the extension must comply
with the technology requirements of RCRA §3004(o).  51  Fed.
Reg. 40639,  (Nov. 7,  1986),  to be  codified at 40 C.F.R.
§268.5.

               In the event  that an extension is granted,  an
applicant is exempted  from  the  disposal restrictions  for  the
length of the extension,  including the conditional storage
prohibitions discussed  below.

          4.  Storage prohibitions
           wastes to be disposed of in old units that do not have to
           meet the minimum technological requirements under RCRA
           §3004(0) for new facilities.  Plaintiffs contend that such an
           interpretation will penalize companies that have made big
           investments to comply with the minimum technological require-
           ments and are currently able to accept the exempted wastes.

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               The Agency has set forth three different time
limits for the storage of restricted wastes.   First,  facility
owners and operators may store restricted wastes as needed to
accumulate sufficient quantities necessary for proper
recovery, treatment, or disposal.  If storage exceeds one
year, however, the burden of proof is on the owner/operator
to show that such storage is necessary.  Second, transporters
of restricted wastes are subject to a ten-day storage limit.
Third, generators who store restricted wastes in excess of
the accumulation time limits set forth in 40 CFR 262.34 must
obtain interim status and eventually a permit.  51 Fed. Reg.
40642-43 (Nov. 7, 1986), to be codified at 40 C.F.R. §268.50.
For large quantity generators, the applicable time limit is
90 days; small quantity generators can store wastes for 180
or 270 days depending on transportation distances.

          5.  Treatment standards

               Congress has required EPA to use a Best
Demonstrated Available Technology  (BDAT) framework to
establish treatment standards for restricted wastes.  HSWA
specifies that BDAT may be expressed as either a performance
standard or a method.of treatment.  The Agency has expressed
a preference for concentration-based performance standards  to
ensure that the technology is properly operated and to allow
those regulated the greatest degree of flexibility possible.
51 Fed. Reg. 40580  (November 7,  1986).  In order to determine
whether a waste requires treatment and whether applicable
treatment standards have been met, the Toxicity Characte-
ristic Leaching Procedure  (TCLP) must be used.

               - Treatment standards for F001-F005 spent
                 solvents

               EPA determined final BDAT treatment standards
for spent solvents on November 7,  1986.  51 Fed. Reg.  40607
(November 7,  1986).  The standards are expressed as con-
centrations in the treatment residual  extract, and therefore
allow use of  any technology that can meet the standard.  The
technologies  utilized by EPA in  setting the standards  were
stream stripping, biological treatment, carbon adsorption and
incineration.  51 Fed. Reg. 40610  (November 7,  1986).
Dilution is specifically prohibited as a substitute for
treatment.  51 Fed. Reg. 40639  (Nov. 7, 1986), to be codified
at 40 C.F.R.  §268.3.

               Industries most affected by the  solvent wastes
standards include those where solvents are used as  reactant
carriers, for surface preparation,  for degreasing,  or  as a
base  for paint and  ink.

          6.  Testing and  recordkeepina requirements

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                Although the Agency has  acknowledged that the
ultimate responsibility for proper disposal of restricted
wastes lies with the land disposal facilities, it has imposed
substantial waste analysis, notice and  recordkeeping require-
ments on generators and treatment facilities as well.

                a.  Generator requirements

                The generator must first test its hazardous
wastes either by using the Toxicity  Characteristic Leaching
Procedure  or  by relying on its knowledge of the waste to
determine  if  the waste is restricted from land disposal.  51
Fed. Reg.  40641 (Nov. 7, 1986), to be codified at 40 C.F.R.
§268.7(a).

                If the waste is restricted,  the generator must
notify the treatment or recycling facility in writing at the
time of shipment of the appropriate  treatment standard  for
the waste, the EPA Hazardous Waste Number,  the manifest
number associated with the shipment  of  waste, and any
available  waste analysis data.  The  treatment or recycling
facility  (or  the generator itself if it is also the TSD
facility)  must keep a record of the  notice.  51 Fed. Reg.
40641  (Nov. 7, 1986), to be codified at 40 C.F.R.
§268.7(a)(1).

                A generator who determines that the waste can
be land disposed without treatment must submit to the
disposal  facility a certification statement4 and a notice
which contains the EPA Hazardous Waste  Number, the manifest
number, the applicable treatment standard(s), and any
available  waste analysis data.  Generators disposing on-site
must keep  the same information in the operating record. The
above requirements apply to all generators dealing with
restricted wastes, whether they are  land disposing the  wastes
or merely  recycling or reusing them.  51 Fed. Reg. 40641
       4    The certification must be signed by an authorized
            representative and must state the following:

       I certify under penalty of law that I personally have
       examined and am familiar with the waste through analysis
       and testing or through knowledge of the waste to support
       this certification that the waste complies with the
       treatment standards specified in 40 CFR Part 268 Subpart
       D.  I believe that the information I submitted is true,
       accurate and complete. I am aware that there are sig-
       nificant penalties for submitting a false certification,
       including the possibility of a fine and imprisonment.
       51 Fed. Reg. 40641 (Nov. 7, 1986), to be codified at 40
       C.F.R. §268.7(a)(2)(ii).

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(Nov. 7,  1986),  to be codified  at 40 C.F.R. §268.7(a)(2) and
(3).

                b.  Treatment  facility requirements

                The treatment  facility is responsible for
treating  the waste in accordance with the applicable treat-
ment standard,  and must test  waste residues under its waste
analysis  plan and certify5  its  results to the disposal
facility.   The same requirements would apply to a recycling
facility  disposing of hazardous waste residues.   If further
treatment is required such  that the waste must  be shipped to
another treatment or recycling  facility, the treatment or
recycling facility initiating shipment is subject to the
notice requirements applicable  to generators.   51 Fed. Reg.
40641  (Nov. 7,  1986), to  be codified at 40 C.F.R. § 268.7(b).

                c.  Land disposal facility requirements

                In addition  to maintaining all  notices,
certifications and waste  data in its operating records, a
land disposal facility must have a testing procedure for
ensuring  that the wastes  received conform to the certifica-
tions made by generators  and treatment facilities and are  in
compliance with the applicable  treatment standards.  51 Fed.
Reg. 40641 (Nov. 7, 1986),  to be codified at 40 C.F.R.
§268.7(c).

           7.  Generator liability for non-compliance with
               land disposal restrictions

                A generator  could be held liable for non-
compliance with land disposal restrictions  in  at least  two
            The certification must be signed by the treater or his
            authorized representative and must state the following:

            I certify under penalty of law that I have
            personally examined and am familiar with the
            treatment technology and operation of the treatment
            process used to support this certification and
            that, based on my inquiry of those individuals
            immediately responsible for obtaining this
            information, I believe that the treatment process
            has been operated and maintained properly so as to
            achieve the treatment standards of the specified
            technology without dilution of the prohibited
            waste.  I am aware that there are significant
            penalties for submitting a false certification
            including the possibility of fine and imprisonment.
            51 Fed. Reg. 40641 (Nov. 7, 1986), to be codified
            at 40 C.F.R. §268.7(b)(2)(i).

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ways.  First, if a -venerator's hazardous wastes were not
being treated propt. ly and therefore exceeding treatment
standard levels at  .lie time of disposal, EPA could track the
wastes back to the generator through the manifest system and
impose penalties of up to $25,000 per day for non-compliance
with RCRA requirements.  RCRA §3008(a)(3); 42 U.S.C.
§6928(a)(3).  Such a result could occur even if the generator
were to send its wastes to a recycler and the recycler failed
to treat the wastes properly prior to disposal.  As a
practical matter, however, EPA may choose to institute
enforcement proceedings against the non-complying TSD
facility before trying to locate the responsible generator.

               Second, a generator could be held criminally
liable under RCRA §3008(d)(3) if, in sending its wastes
directly to a land disposal facility, the generator fails  to
certify or falsely certifies under 40 CFR §268.7 that the
wastes can be land disposed without further treatment.

     B.  WASTE MINIMIZATION

          1.  statutory requirements

               HSWA mandates that as of September 1, 1985,
generators6 are required to certify on hazardous waste
manifests and on-site treatment, storage, and disposal permit
applications that  (1) the generator has a program in place to
reduce the volume or quantity and toxicity of hazardous
wastes to the degree determined by the generator to be
economically practicable; and  (2) that the waste management
methods used by the generator minimize present and  future
threats to human health and the environment.  RCRA  §3002;  42
U.S.C.  §6922.  EPA has revised the Uniform Hazardous Waste
Manifest Form to include a supplemental statement in Item  16
containing the required certification.  50 Fed. Reg. 28733
(July 15, 1985).   In addition, generators must report  to EPA
at least biannually on the results of efforts undertaken
during  the year to minimize wastes.  RCRA §3005, 42 U.S.C.
§6925.

               EPA is  currently drafting waste minimization
reporting forms to be  completed by all  generators that exceed
small quantity levels  (1000 kg or more  of hazardous waste  per
month or accumulated at any time; more  than  1  kg of acute
hazardous waste per month or  accumulated  at  any time;  or more
than 100 kg  of spill cleanup  material contaminated  with acute
hazardous waste accumulated at any time).   It  should be noted
that generators must comply with state  in  lieu of  federal
reporting requir'Tients if the state  has been authorized to
            EPA has exempted certain small quantity generators from
            the certification requirements. 50 Fed. Reg. 28733
            (July 15, 1985).

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administer a RCRA program.  The reporting forms must be
completed by March 1, 1988, and no information may be
withheld on the basis of confidentiality.

          2.  Description of waste minimization activities

               In its October 1986 Report to Congress, EPA
broadly defines waste minimization as:

               "The reduction, to the extent feasible, of
hazardous waste that is generated or subsequently treated,
stored, or disposed of.  It includes any source reduction or
recycling activity undertaken by a generator that results in
either (1) the reduction of total volume or quantity of
hazardous waste or (2) the reduction of toxicity of hazardous
waste, or both, so long as such reduction is consistent with
the goal of minimizing present and future threats to human
health and the environment."

See Report to Congress on Minimization of Hazardous Waste.
Office of Solid Waste, October 1986, p. 6.  Included  in the
definition of waste minimization is the concept of waste
treatment, encompassing technologies such as incineration,
chemical detoxification, and biological treatments.   Report
at pp. iii-iv.  In addition, EPA has indicated that in
certain circumstances waste concentration and expansion
techniques, or even volume reduction alone, may be beneficial
waste minimization practices if they enhance protection of
the environment.   (pp. iv, 13-14).

               Although EPA has defined waste minimization
practices broadly to  include source reduction, recycling, and
treatment techniques,  its  preferred waste management  hierar-
chy, in descending order,  is as follows  (pp. 5-6):

                (1)  Waste  reduction:  Reducing the  amount of
          waste at the source through changes  in  industrial
          processes,  including some types of treatment
          processes,  process modifications, feedstock
          substitutions or improvements  in  feedstock  purity,
          various housekeeping and management  practices,
          increases  in the efficiency of machinery, and
          recycling within a process;

                (2)  Waste separation  and concentration:
          Isolating wastes from mixtures in which they occur;

                (3)   Waste exchange:   Transferring wastes
          through  clearinghouses  so that they  can be  recycled
          in  industrial processes;

                (4)   Energy/material recovery:   Revising and
          recycling  wastes for the  original or some other

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          purpose,  such as for materials recovery or energy
          production;

               (5)   Incineration/treatment:  Destroying,
          detoxifying and neutralizing wastes into less
          harmful substances; and

               (6)   Secure land disposal:  Depositing wastes
          on land using volume reduction, encapsulation,
          leachate containment, monitoring, and controlled
          air and surface/substance water releases.

          3.  Generator liability for non-compliance vith.
              waste minimization requirements

               Although the HSWA waste minimization provi-
sions require several certifications from the generator,
legislative reports make it clear that these provisions are
solely intended to encourage generators to voluntarily
institute waste reduction programs on the basis of economic
practicability.  As such, the amendments require only that
generators make a good faith effort to reduce wastes in light
of individual circumstances; judgments made by generators are
not subject to external regulatory action, nor do they create
civil or criminal liabilities.  See, e.g.. Senate Environment
and Public Works Committee Report No. 284, 98th Cong., 1st
Sess. 66 (1983).  Thus, from an enforcement perspective, EPA
will be concerned primarily with compliance with the certifi-
cation signatory requirements.  50 Fed. Reg. 28734  (July 15,
1985).

               Waste minimization programs are strictly
voluntary at this point, but legal responsibilities for
generators could change in the near future.  Although EPA
recommended in its October 1986 report that the consideration
of mandatory programs, including performance standards  and
required management practices, be deferred until additional
data on hazardous waste generation and management  could be
gathered and analyzed, the Agency has committed to report
back to Congress in  December of 1990 on  the desirability and
feasibility of a prescriptive  approach.  Furthermore, EPA has
stated that if mandatory  controls are needed in the interim,
it will institute them under the authority that currently
exists under such provisions as Section  6  of the Toxic
Substances Control Act  (TSCA).  Report at  pp.  xxiii,  77.
EPA's short-term strategy includes:   (1) publication  of non-
binding guidelines to generators on what constitutes
acceptable waste minimization  practices;  (2) provision  of
technical and  informational  assistance  to  generators;7  and
 (3)  encouragement of voluntary waste minimization  concepts
            Two senate bills (S.1331 and S.1429) have been intro-
            duced in order to provide such assistance.

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within the review  of  new chemicals under TSCA Section  5.
Report at pp. xxiii-iv.   EPA could also recommend legislative
amendments to Congress as part of the next RCRA reauthoriza-
tion expected in 1988,  such as (1) prohibiting consideration
of certain types of waste management practices as waste
minimization  (e.g., those practices that result in  adverse
cross-media pollution transfers) ; (2) providing formal
guidance as to  what may be certified as waste minimization;
and (3) requiring  written support from generators who  certify
that there is no economically practical alternative to waste
management practices  of which the Agency has not approved.
Report at pp. xxiv-xxv.8

                If  EPA-recommended waste reduction techniques
are to become mandatory in the future, those companies that
invest in such  techniques at an early stage will find  the
transition easier. Therefore, as a practical matter,  there
is a substantial  incentive even under this voluntary program
for generators  to  conduct waste audits and implement programs
now.  Generators may  seek EPA clarification on waste mini-
mization practices by letter to the Agency.  Report at p. 67.

                A  final liability  consideration under the
waste minimization requirements deals with possible suits
against generators by persons alleging injury  from  improper
exposure to wastes produced by the generator.   If the
defendant generator has not instituted waste reduction
measures in  its plant, but the majority of its  industry has
(either voluntarily or by law) , such non-compliance could
conceivably be  used against the generator as evidence  of
negligence.   (See Section Ill.C.l.(b) for further discussion
of generator  liability under common  law.)

III.  COMPLYING WITH WASTE TREATMENT AND MINIMIZATION
                GENERATOR OPTIONS  AND THE  "LIABILITY HIER-
ARCHY*

           Several management options  exist for a generator
required to dispose of wastes  in  accordance with the HSWA
land disposal and waste minimization  requirements, including:
 (1)  reducing waste at the source;  (2)  on-site recycling and
resource recovery; (3) off -site recycling and resource
        8    Other groups are in strong support of such recommenda-
            tions.  See, for example, OTA Report, From Pollution to
            Prevention?  A Progress Report on Waste Reduction.  June
            1987; Biden, A New Direction for Environmental Policy;
            Hazardous Wfr^te Prevention. Not Disposal. 17 ELR 10400,
            10402, (October 1987).  In addition,  some states are
            considering mandatory reductions.  For example, a bill
            pending in Massachusetts would require companies to
            reduce their total inventory of hazardous wastes by 15
            percent each year.  18 Envt. Rptr. 1588  (10-23-87).

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recovery;  (4) on-site treatment and disposal of wastes  (or
obtaining a variance from  the  land disposal restrictions and
disposing of wastes untreated); or (5)  off-site treatment and
disposal of wastes  (or  obtaining a variance from the land
disposal restrictions and  disposing of wastes untreated).
This section discusses  these options in order of increasing
potential generator liability,  and will highlight short and
long-term considerations important for generators intending
to use a specific option or combination of options.

     A.  OPTION ONE:  SOURCE REDUCTION

          As discussed  previously, EPA has defined source
reduction as any action that reduces the amount of waste
exiting from a process.  (EPA  Report at p.7)  Source reduc-
tion techniques include process modifications, feedstock
substitutions or improvements  in feedstock purity, various
housekeeping and management practices, and increases in
machinery efficiency.

           1.  Liability considerations

               Because  source  reduction is in effect a  "waste
avoidance" technique  that  utilizes in-house practices to
reduce waste generation, there is very little, if any,
liability  risk associated  with this option  (assuming proper
management and no  leaks or spills within the facility).9
Coupled with potentially huge economic savings for a company,
the reduced  liability aspects of source reduction can make it
an attractive compliance option for generators.  However,
most products cannot  be manufactured without producing  some
hazardous  wastes;  therefore source reduction techniques will
usually have to be combined with other compliance options
such as recycling  or  treatment.

           2.  Other considerations

               Other  factors may present practical  limita-
tions to source  reduction and  prevent a company  from fully
utilizing  this option.   Such factors  include  lack  of suffi-
cient capital to  institute process changes, technical
barriers such as  lack of suitable engineering  information,
and regulatory barriers such as the possibility  that the
            Of course, any company that uses hazardous substances
            must continue to comply with applicable provisions of
            federal and state law governing the use of hazardous
            substances, including, inter alia, the reporting and
            notification requirements of Title HI of the Superfund
            Amendments and Reauthorization Act of 1986 (SARA) and
            the Hazard Comnunication Standard (HCS) of the Occupa-
            tional Safety and Health Act (OSHA), and similar
            statutory provisions.

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installation of new equipment will be considered "treatment"
under RCRA and require  a  treatment, storage, and disposal
facility  (TSDF) permit  (EPA Report at pp. x-xii).10

     B.  OPTION TWO:  RECYCLING AND RESOURCE RECOVERY

          A material  is "recycled" if it is used, reused,  or
reclaimed.  40 CFR §261.l(b)(7).   A material is "used or
reused" if it is  either employed as an ingredient in an
industrial process to make a product or employed in a
particular function or  application as an effective substitute
for a commercial  product.  40 CFR §261.l(c)(5).  A material
is "reclaimed" if it  is processed to recover a usable product
or if it  is regenerated,  such as regeneration of spent
solvents.  40 CFR §261.l(c)(4).

          Some recycled materials are considered "solid
wastes" under RCRA §  6903(27) and therefore are subject to
RCRA regulation.  The residues resulting from these recycled
materials are also regulated under RCRA unless they are
formally  delisted under 40 C.F.R. § 260.22.  50 Fed. Reg.  619
(Jan. 4,  1985).

          EPA determines whether a recycled material is  a
RCRA solid waste  by  examining the nature of the material  and
of the recycling  activity involved.  The Agency has  identi-
fied five categories  of "secondary materials," which include
spent materials,  sludges, byproducts, commercial chemical
products  and scrap metal.  According to EPA these secondary
materials are RCRA  solid waste when they are disposed  of;
burned for energy recovery or used to produce  a  fuel;
reclaimed; or accumulated speculatively.   50 Fed. Reg.  618-
19, 664  (Jan. 4,  1985).

          Secondary  materials are  not, however,  considered
RCRA solid waste  if  they are:  (1) used or reused as
ingredients or  feedstocks in production processes without
first being reclaimed;  (2) used or reused  as effective sub-
stitutes  for commercial products;  or  (3) returned to the
original  primary  production process  in which they were
       10   Regulatory barriers in other contexts are also not
            uncommon.  In some air pollution control districts, for
            example, even process changes resulting in a net
            reduction in air emissions may still trigger new source
            review,  including the requirements for purchasing
            offsets and the installation of Best Available Control
            Technology.  See, e.g.. South Coast Air Quality
            Management District Regulation XIII.

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generated without  first being  reclaimed  ("closed-loop"
exception).11  40  CFR § 261.2(e).

           Thus, EPA draws a distinction between wastes  that
are discarded and  ultimately recycled and those that are
recycled on-site in a continuous or ongoing  manufacturing
process.  The former EPA considers as RCRA solid wastes; the
latter are not solid wastes and therefore not regulated under
RCRA.

           1.  Liability considerations

                Because some secondary materials and all waste
residues are still considered  by EPA to be hazardous and
regulated under RCRA Subtitle  C unless they  meet the delist-
ing criteria of 40 CFR § 260.22, a generator who recycles its
wastes is subject  to the same  type (though perhaps not  the
same degree) of liability risks as a generator who treats and
land disposes of its wastes without first recycling.12   (See
discussion in Section III.C.I  below).  Thus, a generator
recycling and disposing on-site must be  concerned about
liability resulting from improper disposal of the residue.
For a  generator recycling and  disposing  off-site, liability
could  result under common law, RCRA, or  CERCLA if the
transporter, recycler, or disposal facility  mishandles  the
        11   In the recent decision of American Mining Congress v.
            EPA,  the D.C. Appellate Court ruled that materials used
            or reused in an ongoing manufacturing or industrial
            process are not subject to RCRA's jurisdiction, even if
            these materials are reclaimed first. 26 ERC 1345
            (July 31, 1987). The court explained that these
            materials are not within RCRA's jurisdiction because
            "they have not yet become part of the waste disposal
            problem:  rather, they are destined for beneficial reuse
            or recycling in a continuous process by the generating
            industry itself."  Id. at 1352.

            EPA's interpretation of the court's opinion and its
            proposed amendments to rules affected by the opinion are
            fHsnisfleri at 53 Fed. Reg. 519  (January 8, 1988).

        12   In most circumstances, recycling will have a liability
            advantage over treatment and disposal because the
            residue resulting from recycling will be lower in volume
            than unrecycled waste.  Furthermore, the residue  may be
            less hazardous than its waste predecessor and therefore
            easier to delist, or could be  in a form that is easier
            to dispose of and more resistant to leaching.  In other
            situations, however, a recycling or treatment process
            could concentrate the hazardous constituents of a waste,
            making the waste more toxic and difficult to dispose of.

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waste in a way that results in an unauthorized release of the
waste into the environment.

               Furthermore, courts have made it clear that a
generator must monitor the activities of future possessors of
its wastes, including recyclers, in order to minimize the
risk of liability.  This is true whether ownership of the
waste is transferred from the generator to the transporter,
recycler, or disposal company (U.S. v. Wade. 577 F. Supp.
1326 (E.D.Pa. 1983)), or the transaction between generator
and recycler is characterized as a "sale" of commercial goods
rather than an "arrangement" for disposal under CERCLA
§107(a)(3).  U.S. v. A & F Materials. 582 F. Supp. 842, 845
(S.D. 111. 1984)  (spent caustic solution sold by generator to
the highest bidder); U.S. v. Ward. 618 F.Supp. 884, 895
(E.D.N.C. 1985)  (sale of PCB's by generator to a trans-
porter) ; N.Y. v. General Electric Co.. 592 F. Supp. 291, 297
(N.D. N.Y. 1984)  (generator sold used transformer oil to a
dragway to be used as dragway owner saw fit).  See general
discussion on generator liability in Section III.C.I below.

          2.  Other considerations

               In addition to liability considerations, a
generator may be  required to obtain permits in order to
recycle, an often costly and time-consuming process.   (See
discussion on permitting difficulties in Section III.
C.2.(c) below).   A generator shipping wastes off-site to be
recycled must comply with the applicable requirements of
40 C.F.R. Parts  262 and 263 and the notification require-
ments of RCRA §  3010.  40 C.F.R. § 261.6(b).  Generators
recycling on-site (as well as any owner or  operator of a
recycling  facility) must also comply with all applicable
requirements of  40 C.F.R. Sections 265.71 and 265.72 and
RCRA § 3010 notification requirements.  If  the recyclable
materials are stored prior to recycling, all applicable
provisions at 40  C.F.R. Parts 264  (subparts A-L),  265
 (subparts A-L),  266, 270,  and 124  and RCRA  § 3010  notifica-
tion requirements must be  followed.   40 C.F.R.  § 261.6(c)(l)
and  (2).

                Furthermore, logistical considerations  may
prevent  a  generator  from recycling wastes.   For  example, even
 if the waste  is  technically recyclable,  it  may  be  difficult
to accumulate sufficient quantities  on-site to make the
process  economically attractive, or  it may  be  difficult  to
synchronize generator and  recycler needs.
      C.   OPTION THREE:   TREATMENT AND LAND DISPOSAL

           A third option available to a hazardous waste
 generator is to treat the waste to meet RCRA §  3004 treatment
 standards and then dispose of the residual waste in a RCRA

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permitted landfill or other disposal  facility (or obtain a
variance from the land disposal  restrictions  and dispose of
the waste untreated).  If the waste volume and/or toxicity
has not been reduced through any intermediate processing
techniques prior to treatment and disposal (i.e., the waste
is shipped directly  from its point of generation to the TSD
facility.) , this disposal method  can be the most expensive and
liability - prone option.13  Generators who are responsible
for the disposal of hazardous wastes  or waste residues must
therefore make efforts to minimize RCRA,  CERCLA, and common
law liability risks.  Some of these protective steps will be
discussed during the presentation.

          1.  Liability considerations

               a.  Statutory liability

                     (1)  RCRA

               Under RCRA §7003, codified at  42 U.S.C. §6973,
the government is authorized to  initiate injunctive action or
issue remedial orders when past  or present handling, storage,
treatment, transportation or disposal of any  solid or
hazardous waste may  present an imminent and substantial
endangerment to health or the environment.

               The HSWA 1984 amendments to this section make
it clear that past and present generators who have con-
tributed to the site are among those  potentially liable.
Similarly, courts have interpreted  §7003 to apply retro-
actively to past and present generators, and  where the injury
occurring is indivisible, to impose joint and several
liability.  In addition, liability  can be strictly imposed
without fault or negligence on the  part of the generator; to
establish a prima facie ca  3 of  liability, the government
need only show:   (1) that  ae conditions at the site present
an imminent and substantial endangerment}  (2) that the
endangerment stems  from the handling, storage, treatment,
transportation, or disposal of any  solid or hazardous waste;
and  (3) that the defendant has contributed or is contributing
to such handling, storage, treatment, transportation, or
disposal.  See, e.g., U.S. v. Northeastern Pharmaceutical and
Chemical Co.. 810 F.2d 726  (8th  Cir.  1986); U.S. v. Bliss.
667 F. Supp. 1298  (E.D. Mo.  1987);  U.S. v. Conservation
Chemical Co.r 619 F. Supp.  162   (W.D.  Mo. 1985).  Thus, a non-
       13  This would obviously not be the case if the generator
           could delist its waste after treatment and dispose of it
           under RCRA Subtitle D.  Then direct treatment and
                   could be an attractive option from both an
            economic and liability standpoint.  RCRA delisting may
            not protect the generator from CERCLA liability,
            however.

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negligent generator could be held strictly and  solely liable
under RCRA §7003 for releases or spills caused  by  its
transporter or treatment and disposal  facility.

               In addition, RCRA §3008(d), codified at 42
U.S.C. §6928, imposes criminal penalties upon any  person who
knowingly transports or causes to be transported or knowingly
treats, stores or disposes of any RCRA hazardous waste
without a permit or in non-compliance  with the  manifest
system.  Violation of this section  can result in fines of up
to $50,000 per day of violation or  imprisonment of up to 2-5
years.  In one case where a generator  was found guilty of
knowingly shipping wastes to an unlicensed recycling
facility, the court concluded that  knowledge does  not require
certainty, and that a defendant acts knowingly  if  he
willfully fails to determine the permit  status  of  the
facility.  U.S. v. Haves International Corp.. 786  F.2d 1499,
1504  (llth Cir. 1986)  (citing Bovce Motor Lines v. U.S.. 342
U.S.  337  (1952)).

                     (2)  CERCLA

               Generators can also  be  held  liable for
corrective action and response costs under  CERCLA Sections
106 and 107.  42 U.S.C.  §§9606-07.  Section  106 allows the
government, through the  use of administrative orders and
judicial  relief, to abate an  "imminent and  substantial"
threat to the public health which  results  from an actual or
threatened release of a  hazardous  substance.  CERCLA §107
allows the government to recover  response  costs for cleanup
of wastes from four classes of defendants:   current owners of
a disposal site, past owners  of  a  disposal  site, generators
who arrange  for disposal at a  site, and transporters of waste
to a  site from which the waste  is  released or is threatened
to be released.

               Courts have  interpreted these provisions of
CERCLA broadly, and have determined that liability under them
is strict, joint and several.   Furthermore,  the proof of
causation needed to  impose  liability  is minimal.-1-4  See,
e.g., U.S. v. Wade.  577  F.  Supp.  1326  (E.D.Pa.  1983); U.S. v.
Price. 577 F. Supp.  1103 (D.  N.J.  1983); U.S. v. Chem-Dvne
Corp.. 572 F. Supp.  802  (S.D.  Ohio 1983);  U.S.  V.
Northeastern  Pharmaceutical  and  Chemical Co.. 810 F.2d  726
 (8th  Cir. 1986) ; U.S. v. A&F  Materials Co..  Inc.. 578 F.
Supp.  1249  (S.D. 111.  1984);  U.S.  v.  Conservation Chemical
Co..  619  F.  Supp.  162  (W.D. Mo.  1985).  Once the requisite
       14   Congress affirmed the courts' interpretation of CERCLA
            in the legislative history to the Superfund Amendments
            and Reauthorization Act of 1986 (SARA).  See, e.g.,  H.R.
            Rep. No. 253,  99th Cong., 1st Sess., pt. 3 at 15  (1985)
            (Judiciary Ccratiittee).

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nexis is established, the burden of proof is on the defendant
to show that it meets one of the affirmative defenses set out
in CERCLA § 107(b).

               The government therefore is not required to
"fingerprint" a generator's waste (i.e., prove that that
particular generator's waste caused the damage), but need
only show that the generator: (1) disposed of its hazardous
substances (2) at a facility which now contains hazardous
substances of the sort disposed of by the generator and
(3) there is a release of that or some other type of hazar-
dous substance (4) which causes the incurrence of response
costs.  Wade at 1333.  See also Violet v. Picillo. No. 83-
0787P, slip op. (D.R.I. Nov. 10, 1986); U.S. v. Miami Drum
Services. Inc.. No.  85-0038, slip op. (S.D. Fla. Dec. 12,
1986).  Because CERCLA §107(a)(3) only requires that the
generator "arrange for" disposal "at any facility owned or
operated by another party" from which there is a release,
many courts have rejected the notion that a generator must
have chosen the site at which its wastes are actually
disposed in order to incur liability.  See Wade at 1333 n.3;
Picillo at 8; Conservation Chemical Co. at 234; U.S. v. Ward.
618 F. Supp. 884, 895  (E.D. N.C. 1985).  Thus, a nonnegligent
generator can be held  liable under CERCLA §§106 and 107 for
releases caused by the actions of its transporter or
treatment and disposal facility  (even if it is not a facility
that the generator selected).

          Furthermore, because the person arranging for
disposal is not required under CERCLA to actually own or
possess the hazardous  waste or the facility from which it is
removed for disposal,  courts have interpreted the term
"person" to include  both the generator  corporation and
individual employees of the generator corporation.  Thus,
those persons that actively exercise control over the place
and manner of disposal can  be potentially liable under the
statute.  See U.S. v.Northeastern Pharmaceutical & Chemical
Co.. 579 F. Supp. 823, 847  (W.D. Mo. 1984), aff'd. 810 F.  2d
726  (8th Cir. 1986)  (vice president and immediate supervisor
of the facility,  as  well as president of the facility, held
liable); U.S. v.  Bliss.  667  F.  Supp. 1298  (E.D. Mo.  1987)
 (waste broker held liable); Jersey City Redevelopment Author-
ity v. PPG Industries. 655  F. Supp.  1257  (D.N.J.  1987)
 (defendant company within the scope  of  CERCLA  §107 when  it
arranged to sell  mud from  its property  as  fill,  even though
company was unaware  that the mud was contaminated with
hazardous  chromium).15

                     b.  Common  law liability
        15   The New Jersey court did note that lack of knowledge
            could possibly be an affirmative defense.

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                    A plaintiff bringing suit against a
generator for injury resulting from improper management or
disposal of hazardous wastes could base the claim on five
possible common law theories:  negligence,  trespass,
nuisance, strict liability, and vicarious liability.  See J.
DiBenedetto, Generator Liability Under the Common Law and
Federal and State Statutes. 39 Bus. Law. 611 (1984).  Because
of the difficulties of proving causation under negligence,
the limitation of trespass solely to injuries to land, and
the burden of establishing the equities in one's favor under
nuisance law, a plaintiff is most likely to be successful
under theories of either strict or vicarious liability.

                    Under strict liability, a generator could
be held liable on the ground that it is making a "non-natural"
use of its land (the Rylands approach) or on the ground that
it is engaging in an "abnormally dangerous" activity  (the
Restatement approach).  Courts that have held generators
liable under a strict liability theory have analogized to
strict products liability and have justified it on the basis
that the generator economically benefits from the activity
and therefore should bear the costs of injury.  See, e.g.,
Citv of Bridaeton v. British Petroleum Oil. Inc.. 369 A.2d 49
(N.J. Super. Ct. Law Div. 1976), State of New Jersey Dep't of
Environmental Protection v. Ventron Corp.. 463 A.2d 893  (N.J.
1983).  Before a successful claim can be made under strict
liability, however, the plaintiff must show that the
generator's activity is inherently or abnormally dangerous
and prove a causal connection between the generator's
activity and the harm incurred.  DiBenedetto at 621.

                    Under a vicarious liability theory,  a
plaintiff could claim that the generator should be held
liable for  improper management of wastes by its transporter
or disposal facility because the generator arranged for  the
disposal.  The plaintiff would have to prove however, that
the work contracted for between the generator and the
transporter or disposal facility is inherently or intrin-
sically dangerous or likely to result in a nuisance or a
trespass.   DiBenedetto at  622.

               c.  Recommendations

          Because a generator  faces continuing liability
risks  for hazardous waste  releases, it  should attempt to
minimize these risks when  dealing with  transporters,
recylers, and treatment, storage and  disposal  (TSD)
facilities.  Some practical  suggestions  follow.

          First, generators  should exercise due care  in
selecting a transporter, recycler  or  TSD facility.   In
choosing a  transporter, the  generator should verify permits,
licenses and equipment and require the  transporter  to post a
security or performance bond.  In  choosing a recycler or TSD

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facility, the generator should be satisfied that the facility
has the capacity to handle its waste,  has the proper state
and federal permits, is in good standing with the appropriate
environmental agencies, and has sufficient insurance cover-
age.  A generator may also want to conduct an on-site
evaluation of the plant and talk with other customers about
their experiences.  See R.T. Murphy,  Generator Responsibil-
ities in Selecting Treatment. Storage, and Disposal Services.
39 BUS. Law 309 (1983).

          Second, a generator should monitor its wastes.
With respect to transporters, a generator should make sure
that it receives a manifest copy to ensure that the waste has
reached the proper disposal facility.   In addition, some
companies periodically follow their transporter's vehicle to
make certain that the waste is actually delivered to the
proper destination.  Murphy at 313.  With respect to a
recycler or TSD facility, monitoring means ensuring that
permits and insurance coverage are current, and verifying
that wastes are treated to meet the land disposal treatment
standards prior to disposal.

          Finally, generators should protect themselves
through indemnity agreements with transporters, recyclers or
TSD facilities.  Any contract for transport, treatment or
disposal should precisely state that the indemnitor  (trans-
porter, recycler or TSD facility) will indemnify the genera-
tor against liability resulting from strict liability or the
indemnitor's negligent actions, or from failure to comply
with statutes, ordinances, regulations (including treatment
standards), or permit conditions.  In accepting an indemnity,
of course, the generator should investigate the indemnitor's
financial resources, to ensure that the indemnity is of
value.  In addition, the generator should consider a contract
provision requiring the transporter or facility to carry
environmental impairment insurance for the protection of both
parties  (waiving subrogation) and naming the generator as an
additional insured party.  See C.F. Lettow and J.T.  Byam,
Generator - Disposer  Indemnity Agreements. 39 Bus. Law. 315
(1983) .

          2.  Other considerations

               a.  Obtaining an exemption or variance from
                   the land  disposal  restrictions

               A generator could apply for an exemption or
variance  from the  land disposal treatment standards  (see
discussion under  section II.A.(3)  above) and continue to
dispose  of its wastes untreated.   In  order to obtain an
exemption, a generator must  demonstrate to a reasonable
degree of certainty that no  hazardous constituents will
migrate  from the  disposal unit.   Initially EPA  proposed that
the applicant need only  show that  any migration from the

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disposal site would be at concentrations that did not pose a
threat to human health and the environment.   The Agency
changed its position in promulgating its final rule,  however,
and now requires a showing of no migration whatsoever.  The
Agency has acknowledged that the new "no migration" standard
is more stringent, and it expects relatively few cases in
which the demonstration will be made.  51 Fed. Reg. 40578
(November 7, 1986).

               Alternatively, a generator could obtain a
variance from the land disposal restrictions by showing that
it has entered into a binding contract to construct or
otherwise provide alternative capacity that cannot reasonably
be made available by the applicable restriction date due to
circumstances beyond the generator's control.  Such a solu-
tion is temporary, however, as an extension cannot be granted
beyond two years.  Furthermore, treatment, storage and
disposal facilities may be reluctant to accept wastes
purported to be exempt from the treatment standards because
they cannot easily verify that such is the case.  A final
consideration in obtaining a variance from EPA is that state
law may impose more stringent treatment standards or even
prohibit variances altogether based on regional capacity
determinations.

               b.  Off-site treatment and disposal: capacity
                   limitations

          A generator treating and disposing  of wastes off-
site will have to consider short-term and perhaps even
permanent treatment capacity shortages that have resulted
from implementation of the land disposal restrictions and
siting and permitting difficulties encountered by new
facilities.  Such shortages, along with more  stringent design
and construction  standards for RCRA-approved  landfills, are
likely to drive up the costs of treatment and disposal
significantly. 16

          EPA has already  identified shortages of treatment
capacity for solvent and dioxin wastes.  For  solvents, the
Agency estimates  a shortfall of approximately 378 million
gallons per year  for wastewater treatment capacity and 42.7
million gallons per year for incineration.   51 Fed. Reg.
40614  (November 7, 1986).  The Agency concluded that  there
are currently four wastewater treatment  facilities and twelve
      16    EPA estimates  that  these  new  requirements  have
           already pushed the  price  of land  disposal  from $10-
           $15 per metric ton  in  the early 1970's  to  $240 per
           metric  ton.  EPA Report at 15.

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commercial incinerator facilities available to accept solvent
wastes.  14.17

          Whether capacity shortages will continue into the
future depends upon how quickly the marketplace can install
more capacity to respond to the land disposal restrictions
and at what cost.  Two significant market impediments to the
siting of new facilities are public opposition to the
construction of new waste sites and the financial liability
requirements applicants must meet in order to secure a TSDF
permit.  Public concern about the risks posed by hazardous
wastes creates a "not in my community" syndrome, and leads to
opposition against local transportation and disposal of the
wastes.  Typically such resistance is extremely difficult to
overcome.

          Furthermore, assuming that a facility receives
construction approval, a TSDF operator must comply with
extensive RCRA permit requirements such as groundwater
monitoring, minimum technological construction requirements,
preparedness and prevention requirements, recordkeeping and
reporting requirements, and post-closure monitoring require-
ments. The permit process is costly and usually takes several
years to complete.  Applicants are also subject to the
corrective action provisions of RCRA §3004(u) and (v), which
require corrective action for all releases of hazardous waste
constituents from any unit at a TSD facility seeking a permit
regardless of when the release occurred.

          Finally, a TSDF applicant must demonstrate finan-
cial responsibility for bodily injury and property damage
arising from both sudden accidental and nonsudden accidental
occurrences.  This requirement can be satisfied through
either liability insurance, corporate guarantee or a combina-
tion of the two.  RCRA §3004(a)(6) and 3005(e)(2); 40 C.F.R.
§264.147(a) and  (b).  EPA has concluded that units at over
1,000 of 1,551 land disposal facilities have lost RCRA
interim status because of their inability to certify compli-
ance with these  financial responsibility requirements.  EPA
Report at 23.  In fact unavailability of adequate insurance
coverage is the  primary reason that TSDF owners and operators
are unable to comply.  Because insurers consider pollution-
related risks to be so high, they have decreased the types of
insurance available to TSDF owners and operators while
      17   One  recent development that may help to  alleviate
          capacity problems  is the new mobile treatment  unit
           ("MTU") permit  program, which  is  expected  to be
          finalized by  EPA in early  1988.   52 Fed. Reg.  20914
           (June  3, 1987).  An MTU permit would allow
          commercial companies to treat  wastes at  the
          generator's site rather than requiring transport of
          the  wastes to a treatment  facility.

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substantially raising the costs of obtaining insurance.
Policy premiums have increased 50 to 300 percent, and many
companies have difficulty obtaining coverage at all.  Cover-
age for environmental claims (at least for those based on
sudden and accidental releases) was previously available to
TSDF owners and operators to protect themselves in part from
third party and government claims.  However, such coverage is
now generally unavailable.  EPA Report at 22-23.

          The above factors— public opposition to new TSD
facilities, costly and time-consuming permit requirements,
and difficulties in obtaining adequate liability insurance —
will combine to further prolong the treatment and disposal
capacity shortage that hazardous waste generators are
currently experiencing.

               c.  On-site treatment and disposal:
                   permitting difficulties

          A generator may consider on-site treatment and
disposal of wastes for the following reasons:  (1) to limit
transportation and disposal costs; (2) to reduce the risk of
incurring cleanup costs under RCRA or CERCLA for a hazardous
waste release; and (3) to assure  future treatment and
disposal capacity.  While on-site treatment and disposal may
be an economically feasible alternative, a generator applying
for an on-site permit will face the same difficulties  as
commercial TSDF applicants, including public opposition and
substantial permitting and financial responsibility require-
ments .

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    Session II
Source Reduction

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Equipment Cleaning




   Carl Fromm

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          MINIMIZATION OF PROCESS EQUIPMENT CLEANING WASTE
                                      by

                                Carl H. Fromm
                               Srinivas Budaraju
                              Susanne A. Cordery
                          Jacobs Engineering Group Inc.
                          HTM Division
                          251 South Lake Avenue
                          Pasadena, California 91101
ABSTRACT

The  waste associated  with  cleaning of process equipment  is probably a significant
contributor to the total waste volume generated by industry.  This paper addresses the
following aspects related to equipment cleaning waste generation:

     o    Review of reasons for cleaning process equipment
     o    Reduction of cleaning frequency
     o    Reduction of quantity and toxicity of cleaning waste
     o    Costs associated with cleaning

Equipment cleaning techniques, media, and their applications are reviewed.  Reduction
of cleaning  frequency  is addressed in terms of inhibition of fouling through proper
equipment design  and operation, maximization  of equipment dedication,   proper
production scheduling,  and avoidance of unnecessary cleaning.  When cleaning has to
be performed,  the quantity  and toxicity of resulting waste  can be  minimized by
reducing clingage,  amount of cleaning solution, choice  of less toxic cleaning solution,
cleaning solution reuse,  and other approaches.  Application examples are given to
illustrate  each approach.

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INTRODUCTION

The current costs of waste disposal and  treatment, regulatory pressure, and concerns
about legal liabilities have been forcing  U.S. industries to scrutinize their  hazardous
waste  generation  practices i/.   A primary objective  of  these  efforts has been  to
minimize waste generation, i.e. to reduce the quantity and toxicity of the waste.

Of the many  industrial waste-generating operations, process equipment cleaning (PEC)
is  nearly  universal in its application, as  it is practiced  in  all segments  of  manu-
facturing  industry.   PEC is  of particular  importance for discrete processes such as
batch reactions, compounding, surface coating operations, etc.  This is because the
cleaning frequency for discrete processes is generally much higher than for continuous
processes.   However, this   does  not mean  that  cleanup wastes  from  continuous
processes  can be ignored. Disposal of sludges from cleaning of heat exchanger  fouling
deposits, for  example, is often of concern to the operators  of  petroleum refining,
petrochemical and chemical process facilities.

The intent of this paper is to review basic waste minimization strategies applicable to
cleaning operations.   The intent is  to provide a structured classification of  such
strategies presented in the form  of a prototype checklist which can be used  to help
focus and  plan a concerted attack on waste.

WHY EQUFMENT IS CLEANED

Equipment cleaning  is a maintenance function typically performed  for the following
reasons:

           to restore  or maintain the  operating efficiency  of  equipment, e.g., to
           restore  adequate  heat transfer  rate  and  low  pressure  drop in  heat
           exchangers.
           to avoid  or limit  product contamination, e.g., when a paint mix  tank needs
           to be cleaned between batches of varying paint formulations.
           to minimize corrosion and  extend equipment lifetime.
           to allow for inspection and repair of equipment.
           to improve appearance (exterior surfaces only).

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The  need for  cleaning 13 a direct consequence of deposits  formed on the surfaces
exposed to the process environment.  Some of the major routes and origins of deposit
formation  are summarized  in  Table 1  along with  descriptions and some examples.
Understanding how  and why the deposits  are formed  is a critical first  step in  any
waste minimization effort.  It is  an especially important aspect for equipment  and
process  designers, because the need  for equipment  cleaning can often be reduced or
eliminated through design modifications  at minimal expense during the design stage.

A common sense approach to minimizing waste  from equipment cleaning operations is
to pose and answer the following sequence  of questions:

           why is the deposit present?
           how  can  cleaning  be  curtailed or avoided  (i.e.,  cleaning  frequency
           reduced)?
           when  cleaning  is  necessary,  which cleaning method  and medium  will
           generate the least amount of least toxic waste?

Sections below address major aspects related to the last two questions.

REDUCTION OF CLEANING FREQUENCY

Generally, the need for cleaning  can be  reduced   or  avoided altogether  by   the
application of the following measures:

           inhibition of fouling or deposit formation rate.
           maximizing dedication of process equipment  to  a single formulation  or
           function.
           proper production campaign scheduling.
           avoidance of unnecessary cleaning.

Inhibition of fouling is of particular importance in  heat transfer applications where it
can be accomplished through a variety of  means, including use of smooth heat transfer
surfaces, lower film temperatures, increased turbulence, control of fouling precursors
and proper choice of exchanger type.

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             TABLE 1.  TYPICAL ROUTES AND ORIGINS OF DEPOSIT

                     FORMATION IN PROCESS EQUIPMENT
             Route/Origin
             Description
Crystallization
Sedimentation
Chemical reactions and polymerization
High temperature coking
Corrosion
Bacterial growth (biofouling)
Clingage
(of importance to solvent
cleaning applications)
Major problem in evaporators and
crystalizers (e.g. very frequent in
food processing).

Major problem in petroleum refinery
crude unit desalters and oil storage
tanks.  Also present in cooling tower
basins.

Buildup on the internal reactor sur-
faces are often encountered (e.g. allyl
chloride synthesis). Also of importance
in crude oil storage tanks.

Carbonaceous material depositing on
walls of furance tubes (e.g. furnace
for ethylene chloride pyrolysis).

Common problem in heat exchangers in
chemicals and allied products industry.

Major problem on cooling-water-side
of heat exchangers in electric power
production.

Residual coat of process liquid left
after drainage; major problem in
reactors and  mixers in the paint
manufacturing industry and generally
in all high-viscosity liquid transfer
operations.

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The use of smooth heat exchanger  surfaces  results in  lowering the adhesion of the
deposit or its precursor to  the surface.  Application of electropolished stainless steel
tubes  in a forced  circulation evaporator  used in black liquor service in  a paper mill
resulted in a dramatic reduction of  cleaning  frequency  from once a week to once a
year 2/.   Smooth  non-stick surfaces  can also be  provided by  Teflon (a registered
trademark of  E.I.  Dupont  de  Nemours <5e Co.).  Teflon  heat  exchanger  designs are
commercially  available,  as are  designs  utilizing Teflon  coated  steel.  In  a separate
application,  condensers  using Teflon-coated  tubes have  been shown  to  drastically
reduce fouling and resist  corrosion  while maintaining high  thermal efficiency.  The
higher cost of  material was weighed against reduced energy cost to show  a 69 percent
return on  investment in  the first year before tax 21/.  if reduced cleaning costs were
to be  added, the ROI would have been higher.

The rate of  heat exchanger fouling in a given service is dependent upon fluid velocity
and,  quite often,  on  film  temperature.  Film  temperature  controls the speed  of
chemical  reactions which  result in deposit-forming  compounds while fluid velocity
    ~ols the shear  rate at the fluid-deposit interface.

      ,  lowering the  temperature  of the heating  medium  and increasing the fluid
vt.    ty (e.g. by recirculation) can produce a desired reduction of the fouling rate.  An
economic  trade-off analysis between the  increase in pumping cost and the decrease in
the cost of cleaning and other possible  savings appears  warranted in investigations
relating the degree  of oversizing to cleaning waste generation.  A general review of
thermal  and  hydrodynamic  aspects  of  heat  exchanger fouling  was  provided  by
Knudsen !/.

Control of  deposit  precursors is often  an obvious  practical  consideration.   Proper
maintenance of cooling  water quality in open circulating  systems is of paramount
importance to water-side heat exchanger fouling. Control of hardness, pH, corrosivity
and   biofouling  tendency  is  accomplished   through  careful  monitoring  of   water
quality !£/.   In particular, biocides added in treatment must  propagate the entire
cooling  fluid  path in order to  be  deposited and  function at  all  locations  in  the
exchanger; and  acid  feed  equipment to maintain the pH in the non-scaling range of
6 to 7 must be reliable or else rapid scaling or corrosion problems occur !'.

The choice  of heat  exchanger type can  influence  cleaning  frequency.  For example,
spiral plate  exchangers are often specified over  other designs in fermentation  plants,

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owing  to the  ease of  solid  resuspension,  absence  of pockets, and non-plugging
characteristics.  Rod baffle design provides more  effective shell-side turbulence at
lower  pressure  drop compared  to  a more conventional segmented  baffle design.
Therefore, the rod baffle design can be expected to exhibit superior shell-side fouling
characteristics.

Slowing down the rate of deposit formation is not limited to heat exchangers, but also
is  important for other  types  of equipment.   For  example, crude  oil's exposure to
atmospheric oxygen can cause formation of gums and  resins during long  exposure
periods inside storage tanks. The use of floating roof tanks or inert gas blanketing has
been  suggested  as  a way  to  reduce tank  deposit  buildup ^/.   Similarly, in paint
manufacturing, exposure to air  causes  formation  of solid films  that adhere strongly to
the internal surface of  the  mixers.  This can be avoided by using closed storage and
transfer systems, as evidenced  by experience at  Ford Motor Company.  At Ford, the
paint storage and  transfer system was enclosed  and  redesigned for full recirculation
resulting in less  frequent and easier cleanups and an improvement of paint quality •>/.
Other  applications  of  fouling  inhibition include coating of  reactor  internals with
special chemicals to prevent scale formation.  These practices have  been  used  in the
suspension polymerization process for polyvinyl  chloride £/.

Maximizing  dedication   of  process  equipment  to  a  single  process function  or
formulation  will reduce  cleaning frequency, as  the frequency of switching to different
formulations will diminish.  Maximum dedication means either converting from a batch
to a continuous process or using the equipment intermittently just for  one formulation.

Historically, the changeover from batch or cyclic  to continuous  operations has been
common in the chemical industry, owing to increased product demand, increased labor
costs and technological progress.  The advantages of the continuous process over batch
include the  ease of automation and control (which minimizes  human error leading to
inferior product quality) and lower labor requirements.

The choice between the continuous or batch mode is governed  primarily by production
volume and related trade-offs between capital and operating  costs. The batch process
is  advantageous in situations where production  volumes are small and product diversity
large.  Batch processes have  proven advantageous even  for certain  large  volume

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products, such as, neoprene rubber and phenolic resins, where continuous alternatives
were developed but failed to find wide application L§/.

Dedicating a piece of equipment  to a single  formulation in the  batch  process means
that the  equipment  remains  dormant between  individual  production  campaigns.
Cleaning after each  campaign  can be  avoided  provided  that materials  left in the
equipment  do not  deteriorate  with time  or  corrode  the  internals.  Also, the cost
penalties associated with equipment under-utilization must be outweighed by cleaning
costs incurred when the equipment is used with more than one formulation.

Proper  production  scheduling is a commonly invoked method to decrease cleaning
frequency.   Equipment utilization strategies  and the resulting  production schedules
should  be derived through optimization  analysis, where the objective is to meet the
desired production goals  with  due consideration of  such constraints  as available
equipment, cost  of turnaround, labor  availability, storage, etc.  Meeting production
goals is to  be accomplished with minimum  cost, which  includes  minimization of
cleaning frequency. A general review of optimum strategy formulation was given by
Peters and Timmerhaus 2'.

However, in a typical situation  a formal optimization analysis  is not  used  often.
Rather, a common-sense approach to production scheduling is used based on trial-and-
error preparation of production bar-charts.  To reduce cleaning  waste,  it is generally
desirable to schedule  long campaign runs, as opposed to short and more frequent runs.
Production schedulers  now must  be  aware of the current waste  disposal costs, an
aspect that previously could have been ignored.

Avoidance  of unnecessary cleaning should be one of the goals of waste minimization
audits.   At  times, equipment  cleaning is  performed routinely  with  little  or no
consideration of  the  rationale  for the  cleaning  activity.  An actual case is  known
where  a ball mill was used periodically  to wet-grind a certain powder.  The ball mill
with corrosion-proof internals was totally dedicated to the  same formulation, a stable
mixture of inorganic  powders.  Yet, the ball  mill was cleaned after each use  for no
apparent reason.   Upon questioning, the only  justification provided was  that the other
non-dedicated ball mills at the facility were cleaned after every use.

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REDUCTION OF QUANTITY AND TOXICITY OF CLEANUP WASTE

When cleaning has to be performed, it should be performed effectively with minimal
generation of waste.  Typical  considerations include the choice of cleaning medium,
cleaning technique and waste disposal  option. A brief overview of these choices (with
the exception of waste disposal), is provided in the following paragraphs.

A  distinction can be made  between  chemical  and mechanical cleaning.   Chemical
cleaning requires  the  use of substances such  as  those  shown in Table 2 which  are
employed to  chemically attack the deposits and render them either solvent or water-
soluble.  The basic reaction types  include oxidation, reduction, chelation or conversion
of insoluble oxides into soluble salts. Cleaning formulations also include surfactants to
lower  surface  tension  of  solution to allow for faster  penetration  and  breakup of
deposits.

Physical or mechanical cleaning relies on breaking the adhesion  of the deposit to a
surface using mechanical devices,  such as scrapers, squeegees, rags, drag lines, "pigs",
lances  or  through  the use of  high velocity water  jets  (hydroblasting).    Often
mechanical and chemical  cleaning are combined, e.g., when high velocity jets  are
employed with caustic solutions to attack deposits in paint mix tanks.

According  to  a  classification  developed  by Loucks 12',  six  separate  cleaning
techniques are distinguished:

           fill-and-empty technique
           circulation technique
           "flow over" technique  .
           gas propel technique
           process simulation technique
           onstream cleaning technique

In the "fill-and-empty" technique, a  process vessel is isolated from  other equipment
and  filled  with an  appropriate cleaning solution.  The  solution  can be  heated  and
agitated and, after a period  of 4 to 8 hours it is drained.  Rinse-water or diluted alkali
or acid  solutions are  then  used to  remove   residual cleaning  chemical.   Drained
chemicals and subsequent rinses  are either reused,  treated, recycled or land-filled

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                        TABLE 2. SOME CHEMICAL CLEANING COMPOUNDS AND THEIR USAGE
     Cleaning Compound
      Chemical Action
           Usage
         Remarks
Hydrochloric Acid


Sulfuric Acid


Nitric Acid


Hydrofluoric Acid


Sulfamic Acid


Citric Acid



Caustic Soda, Soda Ash




Ammonia
Ethylene Diamine
Tetra-Acetate (EOTA)
Dissolves most water scales
and corrosion products

Dissolves most corrosion
products

Same as HC1
Dissolves silicate deposits
Dissolves calcium salts
Dissolves iron oxides
Dissolves oil and grease
Forms soluble complexes with
copper ions

Dissolves water scales at
alkaline pH's
Used on boilers, heat
exchangers, pipelines, etc.

Limited use
Used for stainless steel
and aluminum

Used as an additive to HC1
(as ammonium bifluoride)

Used as an additive to HC1
Used mostly to clean boilers;
frequently with added ammonia
and oxidizers

Used to remove oil and grease
before acid cleaning and to
neutralize the acid after
cleaning

Used to remove copper from
large boilers
Corrosive to steel; tempera-
tures must be below 175 F

Cannot remove water
scales

Cannot be used for copper
and ferrous alloys

Very dangerous to handle
Easy to handle; soluble
calcium salts

Not good for water scale
removal
Dangerous to handle
Needs to be handled
carefully
Used for cleaning water systems Expensive
without shutdown
Source: References (10), (20).

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depending  on  their  composition  and the  availability  of disposal  options  at  the
particular site. The method uses large quantities of chemicals and requires substantial
downtime.  It is typically applicable to small vessels, tanks or heat exchangers.

In the "circulation" technique, the vessel is filled with cleaning solution to an overflow
and allowed to stand for a short time period,  after which the solution is circulated
with an auxiliary pump.  Fresh make-up solution can be pumped in if used solution is
withdrawn.  In boilers, nitrogen gas is  used to provide agitation  for more effective
scale removal.

The "flow  over"  technique  consists of spraying the solution onto the surface.  It is
applicable  to  large  tanks  where cleaning  by filling  or recirculation would  require
excessive  quantities  of cleaning  solution.   Extra safety  precautions are  usually
necessary.

The "gas propel" technique utilizes cleaning agents that  are not  overly corrosive at
higher temperatures when steam is  used to propel  them  through  the  system.  This
technique  is  useful  for  pipelines,  where  inhibited  organic acids or  chelants  are
entrained into a flow of steam which carries the liquid drops and solids debris  through
hydraulic obstacles of the system.

The "process simulation"  technique is applied to equipment that is easily fouled and
where  spare parallel  units are provided.  Fouled equipment  is cleaned  by  simulated
process operation, where the  equipment is  isolated, drained of process fluid and filled
with the cleaning solution  using process pumps and controls  to  maintain flow  and
temperature.   An example is removal  of  iron  oxide and copper  deposits  from high
pressure steam generators using aramoniated EDTA solution.

The "onstream cleaning" technique is probably the most preferable method, as it relies
on  process fluid to do  the  cleaning  during  normal operation.   Often  auxiliary
mechanical devices are used  along with additives, such as EDTA or acids to  promote
deposit removal. This technique is used for cleaning reactor  jackets, gas compression
station engines, heat exchangers,  and other equipment.  In-service cleaning  of large
circulating cooling water systems is  often  done through intermittent pH swing to the
acid  side  of  neutral  and  back  again.   Among  many mechanical  devices  used in
conjunction with onstream cleaning,  one could mention  ram valves for rodding out

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plugged nozzles  and moveable heat exchanger tube inserts  propelled by  reversing
process fluid il/. In a separate example, the use of fluidized beds of inert solids (e.g.,
sand) was found useful in heat transfer  applications characterized by extreme fouling,
such as heat recovery from geothermal brines.  Solid  particles constantly abrade the
deposit away from the heat transfer surface, maintaining high transfer rates.

The choice of cleaning method and media, apart  from cost, should also be based  on the
following environmental considerations:

           minimize the amount of cleaning solution used;
           choose the medium ultimately resulting in the least  toxic waste;
           determine ahead of  time how the  cleaning waste is going to be disposed of.

The  use of  chemical  cleaning  (e.g.,  with mineral  or  organic  acids)  results  in
appreciable quantities of hazardous  cleaning wastes which need to be treated prior to
disposal.  As appropriate treatment  facilities are not available onsite  in  every case,
mechanical cleaning  and onstream cleaning appear preferable to chemical cleaning.
According  to information obtained from various cleaning  contractors, these  factors
are gaining recognition as the  recent trend has been more toward hydroblasting and
onstream cleaning and away from chemical cleaning.  This was  attributed to  the rising
costs of waste disposal and treatment.

When chemical cleaning is unavoidable, the  least toxic medium should be chosen; for
example, an alkaline  cleaner would be  preferable over a halogenated  solvent.   How-
ever, if the toxicity of the "soil" to be  removed is the controlling factor, the cleaning
agent with a higher potential for recovery and reuse should be used.

An attractive  alternative  to  those cleaning  methods  that  require  disassembly  of
equipment for cleaning, is a clean-in-place  (CIP) system.  The system  is composed of
tanks, heat  exchangers, filters, pumps,  piping and  instrumentation  permanently
installed as  an  auxiliary  system designed to  circulate a controlled inventory  of
cleaning solution through isolated process  equipment often using spray  manifolds or
liquid jet  nozzles inside production  vessels.  The CIP systems  generally reduce  the
usage  of  cleaning  medium.  They are especially  effective when coupled  with high
velocity automated jet  manifolds  and staged  counter-current rinsing; an  80 to  90
percent reduction  in aqueous waste  was  achieved by paint  manufacturers after

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installing high pressure spray nozzles for tank rinsing !£/.  CIP systems are popular in
food, pharmaceutical and paint industries; however they are utilized less frequently in
the chemical processing industry I2/.

Reuse  of cleaning solutions is common in CIP  systems. In general, reuse of cleaning
solutions is highly desirable, especially if  they  can be utilized as part of formulation.
For  example, a  considerable reduction  in  reactor  cleanup  waste was achieved  by
Borden Chemical  where a  two-step rinse  sequence was  applied  to  a batch kettle
arrangement used for phenolic resin synthesis.   The first rinse used a small amount of
water generating a concentrated stream which could be recycled to the process.  The
second  full  volume rinse  generated wastewater with a much lower content of toxic
material than a previously used single rinse method M'.  Other examples include reuse
of rinsewater from latex tank  cleaning as part of latex formulation  in  the paint
industry II' and use of warm oil for flushing the deposits out from crude oil storage
tanks in an oil refinery, followed by solids separation in the slop oil  system I£'.

The preceding sections were concerned with reduction of cleaning  frequency and with
the choice of the  least waste-intensive cleaning methodology. There is a related, but
independent  aspect  of cleaning waste reduction,  i.e., reduction of  clingage.    As
explained  previously, clingage is the amount of process material left inside  the vessel
or other equipment after draining. In operations involving  viscous fluids, such as paint
manufacturing and resin compounding, clingage is an important consideration as it not
only results in waste which is expensive to dispose of, but also represents a direct loss
of product or raw material.

To reduce clingage, the following measures should be considered:

           provision of adequate drainage time;
           use of low-adherence surfaces, e.g.,  fluorocarbon or electropolished steel;
           use of mechanical wall wipers  (dual shaft mixers);
           use of manual wipers or squeegees;
           choice of  square cylindrical  or spherical  geometry to minimize wetted
           surface;
           rotation of agitator after batch dumping to reduce clingage  on the blade.

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All of the above measures are self-explanatory and do not require elaboration. Most
are practiced extensively  throughout industry.  The use of tank linings as a means of
reducing adherence  and  preventing corrosion has been  addressed by Zolin 1Z/  and
Kays !§'. The use of dual shaft mixers with slow scraper blades wiping the walls  and
the bottom of mixing tanks is common in applications involving viscous liquids I2/.

COST OF CLEANING

The cost of cleaning can be viewed as being composed of the following elements:

     Direct Costs
           equipment assembly/disassembly
           cleaning chemicals and supplies
           waste treatment and disposal
           cleaning labor  and supervision
           cleaning equipment depreciation
           utility costs

     Indirect Costs
           planning and scheduling
           cost of lost production
           cost of lost raw materials inventory
           inspection and testing
           process equipment deterioration

Often  equipment cleaning is  performed  by outside contractors  with  specialized
equipment who assume  the responsibility for hauling away the waste and for disposing
of it properly.

Costs of cleaning vary widely  depending  upon  the  medium, method  and application.
Recent inquiries into the cost of cleaning of heat exchangers established the following
compilation of relative  heat exchanger cleaning costs using contracted service:

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                       Method                    Relative Cost
                Hydroblasting                         1.0
                Rodding                              4 to 5
                Chemical Cleaning:
                  Without waste disposal             0.3 to 3
                  With waste disposal                2.1 to 4

In many cases the cost of cleaning (taken as direct cost only) is lumped together with
other maintenance costs.  As a result, plant management may not have good visibility
of the actual costs of cleaning, which may impede management's support for waste
minimization  efforts.   Often, when  plant  management  learns  of the  true cost
dimension, action to lower cleaning costs is quickly initiated.

SUMMARY

As mentioned in the introduction, the intent of this paper is to  provide a brief review
of techniques, approaches and strategies for minimizing equipment  cleaning waste and
to provide  a classification  scheme that  may  serve  as  an  initial  guide  to those
interested  in waste  minimization.   Such a  classification or  summary is  provided  in
Table 3.   This serves as a prototype checklist for addressing all waste minimization
issues in a logical sequence.

The  subject  of equipment cleaning is  quite diverse as  the function  is performed  in
virtually every industry.  Generalizations presented in this paper  must  be translated
into  site-specific and exacting requirements in any waste minimization effort.

ACKNOWLEDGEMENTS

The  authors wish to express their gratitude  to the  U.S.  Environmental Protection
Agency, Office of Solid Waste, for their support in developing a substantial portion  of
the material presented in  this paper.

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TABLE 3. WASTE MINIMIZATION OF EQUIPMENT
CLEANING WASTE - SUMMARY OF APPROACHES

           WHY IS DEPOSIT PRESENT?                    |
       REDUCE CLEANING FREQUENCY
 1.    Inhibition of fouling rate
           smooth heat transfer surfaces
           lower film temperature/higher turbulence
           control of fouling precursors
           choice of heat exchanger type
 2.    Maximize process equipment dedication
           conversion from batch to continuous operation
           dedication to single composition
 3.    Proper production scheduling
 4.    Avoidance of unnecessary cleaning
 REDUCE QUANTITY AND TOXICITY OF WASTE
 1.    Minimize amount of cleaning solution
           high pressure nozzles
           flow-over technique
           on-stream cleaning
           use of CIP systems with staged or counter-current
           rinsing
           reuse of cleaning solution
 2.    Minimize toxicity of spent cleaning solutions
           clingage reduction
           mechanical (hydroblasting) over chemical cleaning

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REFERENCES

1.   League of Women Voters of Massachusetts, Waste Reduction;  The Untold Story,
     Conference held June 19-21, 1985 at National Academy of Sciences Conference
     Center, Woods Hole, Massachusetts.

2.   Uddeholrn  Corporation  (Sweden),  Technical  brochure  on  Tubec  Tubes  and
     communications with Avesta Stainless Inc., Totowa, New Jersey

3.   Knudsen,  J.G.,  Fouling  of Heat  Exchangers;   Are We Solving  the Problem?,
     Chem. Eng. Progress, Feb. 1984, pp. 63-69.

4.   Jacobs Engineering Group Inc., Alternatives for Hazardous Waste  Management
     Practices in the Petroleum Refining Industry, EPA-530-SW-172C, Washington,
     D.C., U.S. Environmental Protection Agency, 1979.

5.   Colleta, V., Powers, J., Chem Proc. 44(4):20-1, 1981.

6.   Cameron, J.B.,  Lundeen, A.J.,  McCulley, Jr. J.H., Hydroc. Proc., 59(3):39-50,
     1980.

7.   Euleco S.P.A., Euleco Continuous Process:  Technical Bulletin, 1975.

8.   Shell International Research Inc., Brit. Patent No. 136, 189; issued Dec. 11, 1968.

9.   Peters, M.E.,  Timmerhaus, K.D.,  Plant  Design  &  Economics  for  Chemical
     Engineers, 3rd Edition, McGraw Hill Book Co., 1980.

10.   Loucks, C.M., Boosting Capacities with Chemicals, Chem. Eng. (deskbook issue),
     80(5):79-84, 1973.

11.   Water Services of America, Inc., Superscrubber Technical Bulletin, 1985.

12.   U.S. Environmental Protection Agency,  Office of Water & Waste Management;
     Development Document  for Proposed Effluent  Guidelines, New  Source  Per-
     formance Standards and Pretreatment  Standards for the Paint Formulating,
     Paint Source Category. EPA-440-1-79-0496, Washington, D.C.,  1979.

13.   Hyde,  J.M.,   New   Development   in  CIP  Practices,  Chem.  Eng. Progress
     81(1):39-41, 1985.

14.   Huisingh, D., et. al., Proven Profit  from Pollution Prevention,  The Institute for
     Local Self-Reliance, Washington, O.C., 1985.

15.   Riley,  J.E.,  Development Document for  Effluent Limitation  Guidelines, New
     Source Performance Standards  for the Tire and Synthetic Segment of the Rubber
     Processing Industry, Point Source Category, EPA-440-1-74-013A, U.S. Environ-
     mental Protection Agency, 1974.

16.   Barnett,  J.W., Better Ways to Clean Crude Storage Tanks and Desalters, Hydroc.
     Proc. 60(l):82-86, 1980.

17.   Zolin, B.I., Chem. Proc. 47(9):63-5, 1984.

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REFERENCES (Continued)
18.  Kays, W.B., Construction of  Lining for Reservoirs, Tanks  & Pollution Control
     Facilities. Wiley, New York, 1979.

19.  Myers Mixing Company: private communication, 1985.

20.  Betz Laboratories Inc.,  Handbook of  Industrial Water Conditioning, 8th  Ed.,
     Trevose, Pennsylvania 1980.

21.  Paschke, L.F., Condensing Heat Exchangers Save Heat, Chem. Eng. Progress, pp.
     70-74, July 1984.

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Parts Cleaning




Ed Rodzewich

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                   SOURCE REDUCTION - PARTS CLEANING








                                                Edward A.  Rodzewich








Introduction









      The  ultimate  goal  for any  metal  finishing  operation  is  to




produce a quality product which meets or exceeds the standards of




the industry.  Parts which are to be painted must be cleaned very




thoroughly  and  undergo  a  processing   sequence   to   prepare the




surface  for   painting.    Phosphating   is  the  usual  method  for




producing a  conversion coating  on steel  and  galvanized  surfaces.




Chromating is used for aluminum.




      As part  of an  integral process operation,  the  cleaning step




or  sequence   is  the  most   important   because  all   of  the  other




processing steps are dependent  on the quality  of cleaning.   Even




the use of the most modern state of the art conversion coating or




the best  paint system will  result  in  a lower  than  desired  level




of quality,  if the cleanliness of the surface is inadequate.




      For  some time now,  solvents  have  been  widely  used  to clean




surfaces, either by themselves or in combination with alkaline or




acidic builders and surfactants.  The most  commonly used  solvents




for parts  cleaning  are  the aromatic  or  aliphatic   hydrocarbons,




ketones,   esters,   butyl   cellosolve   or   carbitol   and   various




halogenated  solvents  as  methylene  chloride or  perchloroethylene.




However,  with  the   increased  number   of  regulations   governing




solvent  emissions  and  air  quality,  the  chemical  suppliers who

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provide  cleaning  compounds  are  shifting  away  from  the  use   of




solvents  completely  or  are  formulating  products  with  reduced




solvent levels.




      Parts being  designed by  engineers today  make use  of  a wide




variety of metals, plastic and rubber components.  In some cases,




solvents can soften plastic or cause swelling of rubber resulting




in a reduced application effectiveness.  Where  it  is not possible




to clean  the part without using  solvent,  changes  in the  manufac-




turing  procedure  may  be  recommended  to   localize  the  use  of




solvent  to  one  specific  area  where good  solvent  control  tech-




niques can be used.




      The  automotive,  industry  is  so  wide  and  diverse  that  its




needs are  representative  of  all industries,  in  one  way or  anoth-




er.   Thousands of parts from  hundreds of jobshops  and subcontrac-




tors  produce  according  to their specifications.  As  a  result  of




their  huge  buying  power,   they  are able  to  exert  considerable




influence on  their suppliers  to use  safe  and effective  chemicals




which  are  environmentally  safe.   Their  use   of  the task  force




including  all of  their  suppliers has resulted in  many new  prod-




ucts, particularly in the area of  solvent reduction.




      Since this  industry makes  use of  a wide  variety of  cleaning




techniques, it will be highlighted.   It  is  to be understood that,




with  minor modifications  at  best,  the  products  and  applications




they use to control and manage solvent usage is  applicable to  all




industries.

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Cleaning Concept




      It is a well  established fact that parts  cleaning  is  one of




the largest operations that use solvents.  Is it really necessary




to  continue to  use  such  large  quantities  of  solvent   or  is  it




merely  a  convenience?  What  is  trying to be accomplished?   There




are  degrees of  cleanliness  required  and the  degree  of cleaning




needed is dependent on the need at the time.




      The most comprehensive  definition  of a clean  surface  is one




which  is  free  of   all   physical   and  chemical  contamination,  is




compatible  with  subsequent  treatments  and  results  in.  a quality




product.  The  subsequent  treatments may  include  simple  inspection




for  maintenance  and  repair,  application of  conversion  coatings




and  paint  or  electroplating  of metals  such as  zinc or  chromium.




This is a definition of an ultraclean  surface condition.




      In  many  cases,  an  ultraclean   surface  may not  be desirable




and may lead to unwanted problems such as in-plant rusting during




storage  or  fabrication.    A  single   part  may  be  cleaned   two  or




three  times in  the  course of  the  assembly process primarily for




inspection  and  maintenance purposes.   This  type  of  cleaning  is




called  in-process cleaning and this will be examined next.









In-Process Cleaning




      The starting point  for many parts  is a coil of metal such as




cold  rolled  steel,   hot  dip  galvanized, electrogalvanized  steel




and  aluminum.   The  parts  are  stamped  or  formed  in   a   central




stamping  plant  and  are  subsequently  packed  in  large bins and




shipped by rail or  truck  to  the  assembly  plants.   Typical  parts

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include  frames,  leaf  springs,  hoods,   fenders,  grills,  bumpers,




hinges, etc.




      In  the  plant,  the automobile  is  assembled  in steps.  During




this phase  many oils  and  greases are  applied to  the  parts,   they




are  sanded,  spot  welded and  in  general  there  is a  lot  of  han-




dling.    Several  times during this assembly  operation,   the  partly




assembled  unit must  be cleaned to  remove  the  large  quantity  of




soil adhering in order to perform a quality inspection.




      Cleaning  is   accomplished  using  one   or   two   stage   spray




washers.   Until only  recently,  the most  commonly  used cleaning




compositions  consisted  of  petroleum  fractions  and  emulsifiers




mixed  with water.   These  cleaning   compositions  were  capable  of




removing  only  90-95%  of  the  soils and  left the  surface with a




thin film of solvent that was capable of providing some degree of




temporary  rust  inhibiting   properties.   The  cleaning  baths  were




prepared by adding between  10 and 20%  by  volume  of the  petroleum




fraction  concentrate.   Cleaning  baths  were drained and  recharged




frequently, on  the average  of once  a week,  depending on  the  soil




loading.




      Despite  the  existence of  exhaust  fans located  at  the  en-




trance  and  exit  ends  of   the  spray  washer, solvent   fumes  were




present  in the  immediate  where  the personnel were  working.    The




concentration of solvent odor was enhanced by  solvent evaporation




from the film  remaining on  the  units exiting  the  washer.   Skin




contact  with  the solvent film  was  inevitable as  the assembly  and




sanding  operations continued.

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Oleum Deck




      After  the  unit  has  been assembled,  it  is  conveyed  to  the




phosphating  stage for  final  cleaning,  phosphating  and  painting.




As  the unit  enters this  area, it  passes through  the oleum  deck




where  it  is  sprayed  completely by means  of  a  horseshoe harness




using  V-jet  or  fan type  nozzles.   Usually,  four  to six  people.




equipped with soft brushes  and/or hand  pads  routinely  scrub  all




of  the  surfaces they can reach.   Sometimes they reach inside  the




units.




      The cleaning compounds used for this application are similar




to those used for in-process cleaning.   However,  since  the degree




of  cleaning required for  phosphating is considerably higher,  the




cleaner  concentration   is  also used  at  a higher  level, probably




closer to 20% by volume.  Buckets  are available  for  hand  cleaning




of  heavily  soiled  areas   and   contain   the  solvent  at  a  1:1




concentration.   The odor, at  times,  was intense and cases of  eye




and  skin irritation  was frequent despite  the   use of  protective




gloves, clothing and solvent masks.









                                RESOLUTION









      The   in-process  and  oleum   deck  were  among  the  very  first




solvent  problem  areas  to  be  addressed.    As  the  industry  moved




from    predominantly    steel     surface    to    a   predominantly




electrogalvanized  surface,  new problems associated with  cleaning




these  surfaces  became  apparent and  which  were  not  present  with




solvent  cleaning.   Electrogalvanized  surfaces   are   more   active

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than  steel.   The   initial   alkaline  cleaners  were   capable   of




forming  white  stains  which  were  readily seen  through  the phos-




phate  coating  and   subsequent  painting.   The  appearance  of   the




paint film resembled a mapping texture and required sanding after




the prime,  to correct.   At times, the alkaline  cleaners formed  a




pinpoint  white  spot,  slightly  raised  from  the  surface.   These




areas increased in size during phosphate and were responsible for




some cratering and protrusions through the paint film.   This also




required  sanding  to correct  before  top  coat application.   These




stains  were surface  analyzed using  SEM  and EDAX  techniques   and




found to be comprised of zinc oxides.




      Eventually, it was found that a relatively neutral to mildly




alkaline  cleaner  operating  in  the  pH range  between  7.5  and  9.5




could provide  the  desired degree of cleaning  for  these applica-




tions.   Oftentimes, a  slight amount  of water  soluble  inhibitors




find use.   They  do  nothing to aid in the removal of the  soil  but




they  are capable of  eliminating the  staining  problem and  impart




some  temporary  in-plant   rust  protection.   Neutral cleaners   are




now  widely  used,   displacing the  solvent  based  cleaners.   They




have been proven to be safe to handle by line personnel, they are




solvent  free  and  therefore are  free  of  odor,  they  are  easily




waste  treated  and   they   required  no  equipment  or manufacturing




changes.   Solvent  reduction for  these applications   as  a  direct




result  of  the use  of  neutral  type  cleaners are  in  the order of




thousands of gallons of pure solvent per year, per plant.

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Cleaners Before Phosphating




      The degree of cleaning  effected by  in-process  cleaning does




not  reach  the  levels  which  is  required  for  phosphating.   There-




fore,  subsequent  to the  in-process  and  oleum deck  cleaning,  the




parts  must  be  processed  through either one  or  two  additional




cleaning  steps.    The  requirements  of  a clean  surface  which  is




needed  for   phosphating   are:   water   break   free   surface  after




cleaning,  a  surface free  of  oxide and  oil  polymerization stains




and  a  low  surface   carbon  content.    The   surface  carbon   is  a




measure of organic carbonaceous soils such as lubricants, rolling




oils and  inorganic carbon.   It  does not measure  alloyed  carbon.




The  measurement  of the  surface carbon  is a  laboratory procedure




based  on coulometric  measurements involving  pyrolytic  oxidation




techniques.   The  surface carbon content must  be  below  0.4 milli-




grams  per  square  foot if  a  high quality phosphate  coating is  to




be  achieved.   Higher  values  of surface  carbon can  lead  to  phos-




phate   coatings   that  posses   marginal  adhesion   and  corrosion




protection.




      Excellent  cleaning,  which meets  all of the requirements  for




phosphating,  is achieved  using  hot  cleaners  operating  at about




150-160°F.   The  cleaning  sequence  could be  spray,  spray-dip  or




immersion.   In  recent years,  a  considerable need  developed  for




low  temperature cleaners because of the high cost of  energy.




       Initially,  low  temperature  cleaning  was  made  possible  by




solvent additions to conventional  cleaners.   The  results achieved




were satisfactory.   Solvents  such as  kerosene, mineral spirits or




butyl  cellosolve were  found suitable.   Cleaning temperatures were

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reduced  from  150°F  to  100-110°F with  no  sacrifice  in  quality.




However, solvent  usage necessitated  better control  of  the  rinse




stages  to  prevent  solvent carry  over.    Knock-off  risers  at  the




exit  of  the cleaning  and rinse  stages  helped  to  control solvent




carry-over.  These emulsion type  cleaners  are in use today  but in




view  of the  EPA and  OSHA  interests  in  minimizing  solvent  emis-




sions, their use is destined to be short lived.




      The average solvent content in these cleaners vary between 5




and  10%  by  weight  of  the  concentrate.   For  a   10,000   gallon




cleaner  tank  operating  at   a nominal   3 oz/gallon,  the  solvent




content  is  at least  187  pounds.   Cleaners are  dumped  frequently




and  recharged  every  two  to  three  weeks.   Over a  period  of  one




year, this amounts to over 3000 Ibs. of solvent per cleaning tank




that  must  be  waste  treated.   This  value is  minimal because  the




calculations did not  include  the normal  replenishment of  cleaner




which takes place to maintain cleaner efficiency.




      In the automotive industry, the newer generation phosphating




machines  are  being   constructed  with   tanks   in  the  90,000  to




100,000 gallon range.    The use of solvent  or emulsion  cleaning in




these large tanks would truly magnify the problem farther.




      Most,  if not  all,   of  these  solvent containing  cleaners  in




the automotive industry have been replaced or will be replaced by




low temperature  solvent free  cleaners.    This  direction  is  taking




place  primarily  due  to  the  strong  influence  of  local  and  state




regulations  governing  solvent emissions   and  very  conscientious




monitoring by the officials.

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      The development  of  efficient  low temperature  cleaners  was




performed in  concert with  the  steel  companies,  lubricant suppli-




ers  and  the  R&D staff  of  the automotive  companies.    Lubricants




and rolling oils were modified or changed completely to make them




more receptive  to cleaning.   Steel mills  modified their practice




and  control in  making the  metal  coils to  reduce  surface  carbon




contamination,  and  the chemical  suppliers  modified  the  cleaning




composition.   The  R&D  staff monitored  and evaluated  the  activi-




ties  of  the   suppliers   and   modified   cleaning   equipment   where




necessary.




      In  general,  the  low temperature  cleaners  are more  alkaline




and  equally  aggressive  where  compared  to  hot   cleaners.    They




differ in the  type  and variety of  surfactants and emulsifiers  to




provide low to no foaming characteristics.   Soil retention  in the




cleaner bath was found to be better, soil redeposition character-




istics  were  improved  primarily   because  of  the  lower  cleaning




temperatures and the variety of surfactants employed.




      Short  high  pressure  (1000  psig)  cleaning  zones  were  in-




stalled, in  some instances,  between the  oleum deck  and the  first




cleaner  stage.   The   high  pressure  was  capable  of  physically




removing  very tenacious soils  such  as  carbon and  loose  sealants




not removed earlier.




      Thermal  oil   separators   have been  installed  in conjunction




with  the first cleaning  stage.    This  works on  the  principle of




heat.   Periodically the oil laden cleaner  bath is  transferred to




a  large  tank  equipped with   a  heater.   As the cleaner  bath  is




heated,  the  oil  separates and   floats to  the  top  where  it  is

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collected  in  a  suitable  vessel.   The  oil  free  cleaner  bath  is




then piped  back to  the  cleaner stage.   This  technique increases




the bath life of the cleaner and decreases the frequency of dump.




This  procedure  is  not   successful  for   solvent   based   cleaners




because  the solvent  would be  effectively  removed with  the oils




and cause the cleaning efficiency to fall off.




      Ultrafiltration  has  also  been  attempted  to accomplish  the




same  purpose  as  thermal  oil separators  but  they have  not  been




readily  accepted by  industry due  to  high cost  and  high mainte-




nance, in comparison.




      Low  temperature  solvent free cleaners  of this type and some




of  the techniques  and  equipment  modifications  are presently  in




use in many spray and immersion cleaning tanks  in the automotive,




coil and fabricated metal  industries.









Acid Cleaning




      Parts  which  have  been stored  for  any  period   of  time  may




become  slightly oxidized  despite  being treated with a  protective




oil  film.   This  condition is  visible  on  steel parts  as a light




yellow  coloration  or  in  more  sever  cases,  red rust.   Galvanized




surfaces may  show  evidence of white  rusting.   Aluminum oxidation




appears as white to black  pitting.   Protective oils, at times and




under  favorable  conditions, can  oxidize and  in the process  react




with the metal  surface to  produce a hard, impervious varnish  type




film.   These   films,  oftentimes   called   polymerized   oil  spots,




resist  alkaline  cleaning  and  generally  lend  themselves  to acid




cleaning.   It is necessary to dissolve some of the metal to reach

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under the  polymeric film  which is  then lifted  from  the surface.




If  these  oxidation products   are   not   removed   completely,   poor




phosphating and paint quality will result.  These  oxidized areas,




if not removed will either prevent phosphating completely or will




allow  an  improperly  formed  or  marginal  coating  to  be  formed.




Adhesion of phosphate  coating  and therefore the  paint  film also,




will  be  inferior.   These  sites  will  be  prime  areas  for  paint




chipping and corrosion.




      Acid  cleaning is  the most  effective  method to  remove  this




surface  condition.   Fortunately,  these  conditions while  serious




are  generally  localized  in  small  areas  and  as  such,  should be




addressed on a case by case basis.   An operator,  using a  brush or




a  sponge soaked with  the  cleaner,  manually wipes  the  area  until




the contamination has  been removed.   A  light wiping with  a water




soaked  sponge removes  the excess cleaner  and stops  the cleaning




action.




      Phosphoric or citric  acid based  cleaners have found use  for




this application.   In  addition, surfactants and emulsifiers  along




with solvents such  as  alcohol or butyl cellosolve  are incorporat-




ed into  the mixture to aid  in  soil  removal and acid  penetration.




The  usage of  acid cleaning, per plant,  does not   approach that  of




alkaline cleaning.   They  are  usually  purchased  in  several  drum




lots  and placed in  the various areas where  inspection and  repair




work is  performed.   This  type of  cleaner is found  in  all automo-




tive  plants,  job shops everywhere and  even sold  over the  counter




in  automotive  retail  shops and  paint  stores.   Thus,  they  are  a




source  of  solvent  emission.    Solvent content  varies  but averages

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about  10%  by  weight of  the  concentrate.   A  single  650 Ib.  net




drum  would  contain  65  Ibs.  of  solvent.   Most  of these  products




are  found  being  used  in  areas  having  only  general  ventilation




which is very questionable and could be harmful.




      The  citric  acid  based  formulations  are   superior  to   the




phosphoric  acid   products   because  they  do   not  passivate  the




cleaned  area  and  any  residue  remaining  on  the  surface  after




cleaning  is   easily  removed   in  the   alkaline   cleaner   stage.




Phosphoric acid  products  can react with the metal  to form a  thin




phosphate conversion coating  that  will interfere with  subsequent




steps.   On  the other hand,  if  subsequent  phosphating will not  be




performed, this  thin film  does provide  a  base  for paint  bonding,




but not of a high quality.




      These  products have  been  reformulated  without  solvent.   In




the  place of  the  solvent,  a mixture  of high HLB  (hydrophilic,




lipophilic balance)  surfactants are used.   Surfactants having HLB




values  around  3  readily  solubilizes   the oily   deposits  on  the




surface  and  allows quick and  effective  action  of the  acid on the




oxidation  sites.    High  HLB  surfactants  (10  or  greater)  allow




rapid   soil   emulsification  and  makes  it  easier   to   rinse   the




reaction products  of  the  cleaning action and excess unused acid.




      Acid  cleaning  of this  nature,  while being of  a magnitude  of




use  lower than alkaline cleaning,  does have a place in industry.









Vapor Decreasing




      Vapor  degreasing  units basically are  devices   for  heating  a




volatile solvent.   By providing a simple cooling jacket above the

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liquid  solvent,  the  zone  between  the  liquid  and  the  cooling




jacket becomes  enriched with  solvent vapor.   The  freeboard  area




above the water cooling  jacket is equipped  with  condensing coils




to help  control any solvent emission into  the workplace.   Clean-




ing  takes  place by  the  hot vapors  condensing on  the  part.   This




vapor condensation  continues until  the  part reaches the  tempera-




ture  of   the  vapor.    The  commonly   used  solvents   are   1,1,1




trichloroethane, trichloroethylene, perchloroethylene and




methylene chloride.   Vapor  degreasing  is  used for  cleaning  many




surfaces  including  glass,  plastics,  combinations  of  metals  and




plastics provided  the solvent  does  not react  with any of  these




surfaces.   It  is  a very  effective  cleaning method  but  it is  not




capable  of   producing  a  chemically  clean   surface.   It has  some




limitations.   It  is not an  effective method for  removing heavily




pigmented soils, oftentimes leaving residues of the pigment which




resist  subsequent   removal.   Thin  sections  of metal  heat almost




instantly to the vapor  temperature  of  the solvent  and  little  to




no  soil  is  removed.    To  produce  a  truly clean  surface  to  the




degree required by phosphating or plating,  a subsequent alkaline




cleaning or  acid cleaning  step is required.




      Vapor  degreasing   units  have been replaced   or not  installed




in certain applications  and  in their  place  alkaline cleaners have




found increasing use.   Alkaline  cleaning is finding favor because




they  have  proven to be  more effective than  vapor degreasing,  for




the  application,   easier  to  use and control, more economical  to




handle and pose no  environmental  problems.

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      Typical examples where this  has  occurred  is  in  the manufac-




ture  of  aluminum  computer  discs  and  production  items  such  as




television tube grids or radio panels which contain a screen like




series of minute holes across the surface.




      The  computer  discs  are  highly  polished and mirror  like in




appearance.   It  is  important to  retain this appearance throughout




the manufacturing sequence.   This is  a  highly technical  applica-




tion   where   cleanliness   reigns  supreme.    Immersion   alkaline




cleaners based on builders such as complex phosphates, biodegrad-




able  free  rinsing   and  water  soluble  surfactants  together  with




specially  formulated  silicates  to  prevent  any  possible  metal




attack  are being used  for  this purpose.   Such  cleaners are  very




safe  to  use  from  a  personnel  viewpoint  and  required  minimal




control to continue remaining effective.




      Cleaning of television shadow  masks or  other similar shapes




which  contain  a series  of tiny holes  was  always considered  an




ideal  item  for  vapor  degreasing.   It  was  considered  to be  the




only  way,   cleaning  could  be  accomplished   inside  the  holes.




However,   it  was   determined   that  spray  alkaline  cleaning   was




superior  method for  this  application.   Highly sequestered  clean-




ers  free  from   silicates  or soda  ash  which  have  a  tendency to




precipitate hard water salts and very low  surface tension produc-




ing surfactants  are required.   After cleaning,  the  part  is  rinsed




with  a  final  de-ionized  water  rinse  and  dried in  a  low   heat




convection oven.




      This  approach  leaves  the surface chemically clean,  free of




cleaner residue  and free  of thin oily films  commonly found after

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vapor  degreasing.    Surfaces  thus   produced  are   suitable   for




phosphating, plating or other applications.




      Wherever parts  are cleaned and  painted,  there  are needs for




products related  to producing  a  quality  job  and which  are suit-




able for any discussion concerning solvents.  Paint stripping and




paint booth coatings merit an examination.








Paint Strippers




      In  every  job  shop  or  manufacturing  site  where  parts  are




cleaned  and   painted,   there  is  a   need  for  paint   strippers.




Methylene  chloride  is the most widely  used solvent  for removing




paint  from steel  and aluminum surfaces.   There  is  a  nationwide




research goal  to  find a viable substitute for methylene  chloride




as  a  paint  stripping   agent,  but  to  date,  none  has  been   found




despite many  claims being  made to that  end.   Methylene  chloride,




by  itself, is  not  too  effective as  a  paint  stripper.   It  needs




the  help  of  various  acidic  activators,  such  as  formic or acetic




acid,  to   be  truly  effective.   Formic  acid  is  far  and  away the




most effective activator available.    Inhibitors  are  added  to  the




mixture  in   order  to   protect  the   metal  surfaces  against  acid




attack  during the  stripping  process  and to  prevent  the  stripped




bare surface  from flash  rusting while  the parts are drying.




      Stripping tanks vary in  size from  several gallons  to several




hundred gallons.   The methylene chloride content averages 90-95%.




Because  of its  low  boiling  point  of  105°F,  the tanks  generally




are  fitted with  lids that  can be  mechanically raised  or  lowered




during  use,  to  prevent  evaporation   losses.    This  technique  to

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reduce evaporation losses is helpful but not truly effective.  At




times water seals are employed but these are seriously lacking in




their  capability  to prevent  evaporation  losses  and  in  addition,




its  use  serves to  decrease  the life  expectancy of  the  stripper




bath.   The  organic acid  activators  preferentially  migrate  from




the  solvent  layer  to  the  water  layer,  where they  are more  solu-




ble.   As  the migration progresses,  the  stripping  efficiency falls




off until its is no longer effective for the purpose intended.




      Seals are available commercially that have proven to be very




effective.   These seals consist  of  highly polar  components which




are  insoluble  in  methylene  chloride  but  are   soluble  in  water.




These seals, being  lighter  than methylene  chloride,  float  on  the




surface.   As the  stripped part  is being removed  from the  tank,  it




passes through  the  seal layer where the seal  layer displaces  the




methylene  chloride  solvent  leaving thin  film of  a water  soluble




components.  By incorporating a rust inhibitor in the seal layer,




flash  rusting  during  drying is eliminated.   Evaporation  losses,




using  these  seal layers  can be as high  as  40%.   There is  little




to   no  tendency  for  the  activators  to  migrate  into   the  layer




because they  are  more  soluble in  the methylene  chloride.   As are




result,  paint  stripping efficiency remains constant  for the  life




of  the bath.




       Products  have recently become available where  the methylene




chloride  content  has  been  reduced  by  60%.   Techniques  have  been




found  to  produce  a  stable  solutio  of  methylene  chloride  in an




aqueous   medium.    In  effect,   the methylene   chloride   molecule




becomes  surrounded by  water  molecules  resulting  in   an  in-situ

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type  water  seal.   This  approach  is  certainly  novel  and  it  is




tremendously  effective in  reducing  evaporation  losses.   It  has




been  found  that the activity  of the  acid activators  and inhibi-




tors  commonly  employed  are  enhanced  in  such  a  medium.    This




technique effectively minimizes evaporation losses and because of




the  lower usage  of methylene chloride, it  is  a  viable method for




source reduction of a powerful paint stripping solvent.








Booth Coating Compounds




      Booth  coating   compounds   are   removable   temporary  barrier




coatings  which  are applied  to  spray booth  walls,  gratings  and




floors  to   facilitate entrapment   and  disposal  of   accumulated




overspray paint.   In  addition they  serve to provide an  excellent




light reflecting surface which  is very beneficial in  application




of  paint  and  results  in  a  minimal  amount of  rejects.   The  white




dry flexible barrier coatings are considered the best type to use




because  they  afford  the   best   light reflection.    As   the  paint




overspray accumulates,  the  barrier  coating is  simply peeled  from




the  surface,  discarded  and  a  new  barrier  coating   is  applied




either by  brushing or  by means  of a  paint spray gun.   The  entire




sequence of peeling the coating  from the walls of the paint booth




and the application of a new film takes about one hour, depending




on  the size of the  booth.   Half  of  that time  is  used to allow the




coating to dry before  use.




      A   typical  white  booth   coating   compound  consists  of   an




acrylic  co-polymer  resin  dissolved  in  a  mixture  of  methylene




chloride,  xylene and  toluene  and pigmented with  titanium dioxide

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to form a stable  emulsion.   Small  amounts of  plasticizer is  used




to keep  the dry film flexible  and  pliable.   Approximately 50%  by




weight  of  these  compositions  consist  of  solvent which  escapes




during drying.   One  gallon  usually  is  capable  of covering  about




600  square  feet of   area  at  1-3 mils  thickness.   Each   gallon




contains  about  6-7  Ibs. of solvent.   Very  good  local  ventilation




is  required during  the application  process  and  spray  equipment




which  contains  any  aluminum  or  galvanized  steel parts  must  be




avoided because of the danger of hydrogen gas forming.  Stainless




steel  spray  equipment  is  an  absolute  requirement.    There  have




been   instances  reported  of   temporary   asphyxiation  resulting




because  of  inadequate  or  inoperative  ventilation.   Fortunately,




this   was   a  temporary  condition  and   the   personnel   recovered




completely after being removed to fresh air.




      Recently  high  solid  formulations  have  been developed  and




sold   commercially.   About  85%  by  weight represents  the  total




solids  content as  a  waterborne  copolymer  emulsion and titanium




dioxide pigment.  The remainder being water  and a small amount of




a  cellosolve type  solvent.   Average  VOC content of  commercially




available booth coating compounds of this type  is  0.2-0.3 Ibs  per




gallon.

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      These products perform equally to the solvent based products




but they posses several advantages over the solvent based materi-




als.




                             1.  non-flammable




                             2.  10-20% greater coverage




                             3.  no restriction as to construction of




                                spray guns




      The  high  solids  water  based  booth  coating  compounds   are




rapidly replacing the solvent based products and they are consid-




erably  safer  to  apply.    These products  are used  wherever  parts




are painted.









                                   Summary




      This short  review  attempts  to highlight the  use of  solvents




in  parts cleaning  and  to enumerate  the alternatives  to  solvent




cleaning of parts on a case by case perspective.




      Certain  areas such  as  paint strippers and temporary  barrier




booth  coating  compounds  which  are  indirectly  related  to  parts




cleaning  use  a considerable  amount of  solvent.   While  it has not




been  possible  to  eliminate  solvent   usage  in  these  products,




significant advances have  been made to significantly reduce  their




effective solvent content.

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    Session III
Reuse  and Recycle

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On-site Reuse and Recycle of
 Halogenated Waste Solvents

    E. Richard Randolph

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CONTENTS                                                PAGE
Introduction	3
Waste Reduction: Background	3
Trends in Chlorinated Solvents Use	5
Recycling Through Contract Reclamation	7
Recycling Through In-House Reclamation	8
Waste Reduction: Customer Assistance	12
Factors Influencing Solvent Consumption	13
Waste Disposal Issues	18
Conclusion: The Benefits of Waste Reduction	18
Appendix A	19
Appendix B	20
Appendix C	21

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                           INTRODUCTION

     Numerous examples have shown that waste-reduction programs
result in a cleaner environment, less worker exposure to
chemicals, and significant savings in fuel,  feedstock, and
environmental-control costs.
     The Dow Chemical Company has practiced  waste reduction —
and shared its expertise with customers — for more than two
decades.
     In order to illustrate some principles  of waste management,
this paper will describe internal and external efforts to reduce
waste from the use of specialty chlorinated  solvents — including
a description of in-house recycling — factors influencing
solvent consumption, and issues in solvent waste disposal.

                   WASTE REDUCTION; BACKGROUND

     Dow has practiced waste reduction since the 1960s, when
Chief Executive Officer Carl Gerstacker developed a pollution-
control plan that called for employee involvement and rewards for
achievement. He sought to improve yields, reduce waste, and find
ways to use waste.
     Significant dates in the regulatory and legislative history
of waste reduction include: 1976, when the Environmental
Protection Agency listed waste reduction at the top of a
preferred hierarchy for waste management; and 1984, when Congress
defined the desirability of waste reduction as a national policy.
     In 1987, Dow grouped the internal efforts that grew from
Gerstacker's plan under a program called WRAP — Waste Reduction
Always Pays.  (The service provided to chlorinated solvents users
is called the Waste Reduction Assistance Program. Details begin
on Page 12).
     The importance of a plan such as WRAP is that it is long-
term, and formalizes past, present, and future waste-reduction
efforts in order to track progress and chart a course  (see Fig.
1). Goals are to:
          o    Reduce waste in all media.
          o    Create a disposition toward waste reduction.
          o    Provide incentives to reduce waste.
          o    Recognize excellence in waste-reduction efforts.
          o    Save money  (including avoided costs).
          o    Lessen future liability.
     Waste reduction can be defined as:
          o    Any in-plant practice or process that  avoids,
               eliminates or reduces waste so as to  reduce
               environmental risk to any media.
          o    The treatment, reuse or recycling of  any material
               that  reduces the volume and/or toxicity of waste
               prior to final disposition.
     The Louisiana Operations Division — a large, diversified
manufacturing division — provides excellent examples of  success

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                  Fig.  1

           WRAP  Flow  Chart
Develop Historical Benchmark For Each Process
  Inventory All Losses  To  Air, Water, Land
           (Quantity t  Quality)
          Identify Source Of Losses
  Prioritize (Volume And Screening Method)
                 Set Goals
      Determine Cost Effective Actions
             Allocate Resources
             Implement Actions
    Document & Report Progress Routinely
      Communicate Internal fi External
         Plan For Future Reduction

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in waste reduction. In the past decade, hydrocarbon emissions
dropped 92% and chlorinated hydrocarbon discharges to water
dropped 98% while production increased from about 8 billion
pounds per year to 12 billion pounds per year.
     The division utilized techniques such as improving the
purity of raw materials, improving instrumentation, using on-
stream analyzers, using process analysis by statistical methods,
and improving maintenance.

                TRENDS IN  CHLORINATED SOLVENTS DSE

     Specialty chlorinated solvents include 1,1,1-
trichloroethane, trichloroethylene, methylene chloride, and
perchloroethylene. The diverse applications for  these products
include metal cleaning  (by means of cold cleaning and vapor
degreasing), dry cleaning, chemical processing,  and production of
fluorocarbons, aerosols, paint removers, adhe^ives,
coatings/inks, and blowing agents.
     The demand for metal-cleaning solvents far  outweighs the
demand for chlorinated solvents for any other application  (see
Fig. 2). It is more than twice the demand for dry cleaning
solvents and three times the demand for fluorocarbons production
solvents. Dry cleaning and fluorocarbons production are the
second and third largest applications for chlorinated solvents,
respectively.
     Metal-cleaning solvents represented 38.2% of the total
demand for chlorinated solvents in 1984 and 34.6% of the total  in
1987. Although demand for metal-cleaning solvents dropped 139
million pounds in those three years — a decline disproportionate
to the 194-million-pound drop in total demand — metal cleaning
still is the most significant application for these four
chlorinated solvents  in the United States.
      Conservation — and efforts to encourage more efficient use
of solvents — have contributed to both the decline in demand for
all virgin chlorinated solvents and the decline in use of virgin
chlorinated solvents  for metal-cleaning applications.

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                          Fig. 2
                 Applications/End Uses
          For Specialty  Chlorinated Solvents
BUU
700
600
500
400
300

100


-
—

••


754



0 "H
4^ C
H
O


344
208 186 M»
142 137
O\ OJ OJ O* OB (4
c c — ' fi -u M o
45 oc o «J-H CT co x:
SJ3 O 03 O OJ -U -«H > 4!
M
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             RECYCLING THROUGH CONTRACT RECLAMATION

     Many chlorinated solvents users hire companies with the
technology to reclaim solvents from waste sludges. The following
table illustrates the growth of contract reclamation.

                 CONTRACT RECLAMATION INCREASING

Year              Pounds reclaimed              % of all solvents
                   (in millions)                   users buying
                                               reclaimed solvents
1977                   69                           20-25
1982                  147
1986                  268                           75-80
1990                  310 (estimate)

     When recycled solvents enter the marketplace, the demand for
virgin solvents drops correspondingly. And, reclaimed solvents
come primarily from metal-cleaning applications.
     The quality of recovered solvents may vary for reasons
including stabilizer depletion and cross-contamination with other
solvents or compounds.
     Problems that can occur because of improperly stabilized
solvent include:
          o    Dilution of fresh solvent, which can shorten
               solvent life.
          o    Reduced acid acceptor content. This can decrease
               the margin of safety before an acid condition
               develops in cases of stress.
          o    Reduced metal stabilizer content, which decreases
               or eliminates protection from corrosion. Corrosion
               produces acid that degrades solvent and consumes
               acid acceptor.
          o    Excess stabilizer content, a potential
               flammability hazard.
          o    Improper stabilizer ratio, which reduces the
               effectiveness of metal stabilizers.
          o    Contaminated solvent. Such contaminants as
               aromatics in methylene chloride and 1,1,1-
               trichloroethane in trichloroethylene can cause
               reactions that result in an acid condition,
               especially in the presence of aluminum.
          o    Excess water. This shortens solvent life, causes
               greater vapor loss, and creates corrosion and/or
               spotting on the work.
     As Fig. 3 shows, the demand for virgin chlorinated solvents
was sluggish between  1971 and 1980, and has fallen since 1980.
That decline corresponds almost directly to the increase in total
pounds of reclaimed solvents on the market since  1980.

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                                Fig. 3
             U.S.  Demand For Chlorinated  Solvents
 2500
 2000
 1500
CQ
2
 1000
  500
                                                    Total Virgin
                                                    Virgin MC
                                               ........ Reclaim
                                   I
1971      1974
                        1977
1980
1984       1987
1990

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              RECYCLING THROUGH  IN-HOOSE RECLAMATION

     While the contract reclamation industry was growing,
chlorinated solvents users also were finding ways to recover
solvents in-house. In 1983, 52% of the customers that Dow  knew
were using chlorinated solvents, were recovering in-house.  That
figure was up to 64% in 1987.
     The use of in-house stills to recover solvent and
concentrate waste typically results in up to a 20% reduction in
solvent use. In-house solvent recovery is tantamount to source
reduction because it eliminates a need for virgin material.
     Distillation recovery equipment falls into three categories:
process stills, in-house solvent recovery equipment — including
units that are the same type of equipment as process stills, and
semiportable ministills — and thin-film evaporators. In
addition, the vapor degreaser can be used as a quasi-still by
means of the boil-down procedure (see Appendix A).
     Process stills are used in conjunction with vapor
degreasers. Dirty solvent from the sump of the degreaser is
pumped to the still for distillation, then returned to the
degreaser's offset clean solvent storage tank.
     A degreaser with a still does not have to be shut down and
cleaned to remove contaminants as often as a degreaser without a
still. Periodically, the still is opened and the sludge removed
while the degreaser continues operating. This process is called
continuous distillation and can produce a waste that is
approximately 25-50 percent solvent.
     Process stills are often steam-heated, but can also be
electrically heated or steam-fired. Their recovery rates are
expressed in gallons per hour, and typically run from 30-200 gph.
     About 62% of Dow's larger customers recovering solvents on-
site use process stills.
     In-house solvent recovery equipment offers a specialty
technique for minimizing solvent waste and eliminating the need
to send spent solvent to an outside reclaimer.
     To recover solvent, spent solvent is collected and stored
until enough accumulates to fill a still. The contaminated
solvent is pumped into the still, distilled, and recovered in
drums or storage tanks. This is called batch distillation and
removes 70-95% of the solvent in the waste.
     Larger units are the same type of equipment as process
stills, except that they are not necessarily used in conjunction
with vapor degreasers.
     Some newer, small-capacity units are electrically heated and
recover solvent over a long period, typically about eight hours.
Based on hundreds of calls on customers over the past four years,
Dow estimates only about 1-2% of customers  recovering solvents
on-site use these ministills.
     Thin-film evaporators are used for high-volume solvent
recovery. Their application  is primarily for continuous feed, and
capacities range from 50-500 gph. Solvent recovery is 90-95%.

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     Recovered solvent fits into one of these three categories:
          o    Clean solvent.
          o    Clean solvent with the measured addition of  acid
               acceptor.
          o    Clean solvent, analyzed for inhibitor content  and
               restabilized with both acid acceptor and metal
               stabilizers as required.
     The latter two categories usually are obtainable only
through contract reclaimers.
     The recovered solvents that are obtained from in-house
distillation usually can be used directly in the cold cleaning or
vapor degreasing process as a replacement for some virgin
solvents. However, because the quality of recycled solvent  can
vary, it should be monitored by analysis and used only as a blend
with virgin solvent.
     Fortunately, in-house distillation is not often subject to
cross-contamination, and blending with virgin solvents during
reuse should keep stabilizers within satisfactory limits.
     In some cases, however, it is necessary to restabilize
recycled solvents in-house when inhibitor depletion is excessive
and unavoidable. An example would be to add acid acceptor to
trichloroethylene that has been depleted by carbon adsorption
recovery. Some, not all, stabilizers are provided commercially in
a safe and effective manner.

     Depending on the equipment utilized and the nature of  the
production process, waste solvents and residues from in-house
distillation are sent out for further reclamation or disposal
(see Fig.4). As a broad rule of thumb, solvent wastes containing
up to 30% oil are forwarded to contract reclaimers. Solvent
wastes containing 30-90% oil are sent to fuel blenders through a
waste broker. Wastes with more than 90% oil are sent directly to
disposal via thermal destruction. (A discussion of waste disposal
issues starts on Page 18).
     Some chlorinated solvents users enhance solvent recovery
with steam sparging, stripping, or specialized collection systems
such as double distillation. Such techniques, practiced on large
quantities of waste, allow chlorinated solvents users to reduce
their waste production substantially and fall more in the realm
of waste management than waste reduction.
     The major incentive to practice solvent reclamation is to
save money. For the same reason, solvents users are insisting on
tighter machines, wasting less solvent, and looking for even more
ways to use solvent more efficiently.

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                       Fig.  4

                  Flow  Diagram
         Hazardous Waste  Disposition
                       Any
                    Generator
                    (Customer)
  In-House Recycling
Solvent
Sludge
                     Landfill
                   Incinerator
                  Fuel Blender
                    Reclaimer
          Sludge
                                        Permitted
                                        Hazardous
                                          Waste
                                         Hauler
                   Clean
                   Solvent

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              WASTE REDUCTION; CUSTOMER ASSISTANCE

      In 1976,  the Environmental  Protection Agency hired Dow to
conduct a study to support new source performance standards for
solvent metal-cleaning operations.
      Under that contract, K.S. Surprenant and D.W.  Richards
identified and  quantified emission  control techniques being
practiced at that time. They included use of covers, liquid
absorption, carbon adsorption, use  of refrigerated freeboard
chillers, refrigeration condensation, and good operating
techniques.
     The study  indicated that a large portion of the solvents
emitted to the  atmosphere and basically wasted resulted from
inefficient cold cleaning and vapor degreasing. Since there were
many techniques to improve efficiency and reduce waste during
these operations, the study reinforced the commitment to assist
solvents users.
     The effort became the Waste Reduction Assistance Program,
which has four  elements: field support services, product
stewardship, training and seminars, and literature.

     Field support services. In 1986, 44% of the calls made by
     chlorinated solvents technical service personnel related to
     waste reduction. In 1987, 53% involved waste reduction.
     Waste reduction-related field support services  include:
          o    Process troubleshooting, including visiting the
               plant to identify problems, as well as handling
               inquiries over the phone.
          o    Vapor degreaser inspections to determine if there
               are problems with the design or maintenance of the
               degreaser or associated equipment.
          o    Recommendations covering all phases of degreaser
               operation, including heat balance, water handling,
               and parts handling.
          o    Engineering consultations involving cleaning of
               metal and design of equipment.
          o    Waste- and emission-reduction recommendations.

     Product stewardship. Examples of product stewardship as  it
     relates to waste reduction are locating and monitoring vapor
     concentrations in the workplace and suggesting  ways to
     reduce them. Monitoring includes taking halide  meter
     readings and dosimeter readings, as well as conducting
     professional industrial hygiene surveys in  some cases.

     Training and seminars. Training is one of the most important
     facets of waste reduction. Topics include product
     application, maintenance, the theory of vapor cleaning,
     environmental and regulatory updates, and safety.  Programs
     can take place in groups or one on one and  are  available  to
     distributors of chlorinated solvents, distributors'
     customers, direct customers, and Dow's own  field personnel.

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     Literature. Waste reduction is covered in solvent Material
     Safety Data Sheets, Product Stewardship Manuals, application
     brochures, newsletters (see Appendix B) ,  and other
     publications.

     These four elements, practiced together,  constitute a
formidable solvent-management program that is  much stronger than
any one of them practiced alone.

             FACTORS INFLUENCING SOLVENT CONSUMPTION

     Most of the techniques for reducing waste during cold
cleaning and vapor degreasing are easy to follow and improve the
efficiency with which the operations use solvents. Every pound of
solvent conserved results in the equivalent pound of reduced
demand for virgin solvents and reduces the volume of solvents
requiring recycling or disposal.

                          Cold cleaning

     Good operating practices are essential to curb solvent
consumption during cold cleaning — and they are mostly a matter
of common sense.
     To minimize evaporative losses:
          o    Use covers.
          o    Use a water layer on top of the solvent where
               acceptable.
          o    Use a coarse spray or solid stream of solvent
               instead of a fine spray.
          o    Control ventilation.
          o    Place wipe rags in a closed container and use them
               again wherever possible.
          o    Minimize open surface area.
          o    Use a deep tank with a high freeboard.
          o    Use specially designed containers with automatic
               lids and drains.
          o    Drain parts properly to capture as much of the
               solvent as possible.
          o    Don't use compressed air sprays to blow dry parts
               or to mix cleaning baths.
     To reclaim solvent:
          o    Capture and distill any waste.
          o    Dispose of sludges at the proper time to avoid
               stressing the solvent.

                         Vapor degreasing

     Reclamation of reusable solvent from waste sludges is
important, but only about 15-30% of the solvent used for metal
cleaning by vapor degreasing becomes waste. The other 70-85% is
eventually lost to evaporation  —after multiple uses in the
system — through inefficient operation and maintenance of the

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degreaser and associated equipment.  Techniques to reduce overall
emissions from a degreaser and to fine tune degreaser operation
conserve some of that 70-85%.
     Specific suggestions for minimizing solvent loss and
reducing the cost of using solvent during vapor degreasing fit
into seven general categories.

1.   Ensure proper degreaser operation.

          Leave the unit on to maintain the vapor level unless it
          won't be in use for long periods of time.

          Don't expose heating coils to vapor. This could result
          in a breakdown of the solvent and corrosion problems in
          the unit, in addition to loss of solvent.
          Provide proper maintenance. Remove visible corrosion
          and repair leaks. Repairing leaks alone can result in
          up to a 50% reduction in solvent loss.
          Use and maintain appropriate design and safety devices.
          These devices include solvent level controls and vapor,
          condenser water, and boiling sump thermostats.

2.   Maintain proper heat balance.

          Use the least amount of heat required to keep the
          solvent at a slow boil and to give adequate vapor
          production. High heat provides only rapid vapor
          recovery, not improved cleaning.

          Regulate the cooling level either by adjusting the
          temperature of the cooling water or by altering the
          flow rate of the cooling water. The vapor level should
          balance at the midpoint of the condensing coils; a
          fluctuating vapor level pumps the vapor-air mixture out
          of the unit,

3.   Minimize vapor diffusion.

          Reduce exhaust velocities to provide adequate
          protection of workers, yet not draw vapors out of the
          degreaser. Adjusting exhaust velocities can achieve up
          to a 50% reduction in solvent loss.

          Cover open-top degreasers, especially during idle
          times. This is the most significant solvent
          conservation method; it can  reduce solvent loss up to
          55%. Sliding covers do not cause turbulence when moved,
          unlike hinged covers.

          Extend the freeboard. Units with freeboard heights that
          are 40% of the width of the degreaser can use up to 40%
          more solvent than units with ratios of 75-100%.

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          Use cold traps — an upper  set  of very  cold  coils  that
          cool the air above the vapors.  Properly used,  cold
          traps provide a dense air blanket that  helps prevent
          vapor escape.

          Cover the water separator to prevent  any possible  vapor
          loss.

          Check the water jacket for  proper water flow and
          temperature on the outside  of the degreaser  to prevent
          migration of hot vapor up the side walls.

          Prevent drafts over the degreaser. Fans, air condition-
          ers, heaters, windows, doors, general plant  air
          movement, and equipment movement can  blow the  vapor-
          air mixture out of the degreaser. Locate the degreaser
          to minimize natural drafts  or use baffles to prevent
          upset of the vapors and achieve up to a 30%  reduction
          in solvent loss.
               Also, vapor control with lip vent  or hood exhaust
          may be too forceful, so reduce exhaust  velocity to the
          minimum level that provides proper vapor control  in the
          working area.
               Some semi-closed machine designs tend to  channel
          and reinforce air current  through the machine,
          especially if power-exhausted.  Rearranging air movement
          in the room helps to eliminate the wind-tunnel effect.


4.    Minimize water contamination.

          Avoid adding water. This is important to prevent
          depletion of stabilizers, which results in solvent
          decomposition and corrosion from acid formation by
          hydrolysis. Condenser coils, cold trap coils and  the
          water jacket can be too cold, resulting in condensation
          of atmospheric moisture. Also, wet parts can introduce
          water, particularly as a component of water-soluble
          cutting oils.

          Dewater the solvent. A water separator should be able
          to reduce dissolved water  in the solvent. Also, skim
          floating water off the top  of the solvent, since this
          represents excessive water  content. Water and solvent
          form an azeotrope at boiling temperatures. The
          azeotrope has a lower density than dry solvent vapors
          and is harder to contain.

          In  .all a separate water trough for refrigerated coils.
          Cold trap coils can build up a heavy dew. A separate
          discharge for this condensate is necessary to avoid
          introducing the water to the solvent at a common water

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          separator,  which reduces the water  separator's
          effectiveness and perhaps would overload its capacity.

5.   Establish proper workload handling.

          Ensure parts are up to temperature before removal.  The
          cleaning cycle isn't complete until the parts have
          reached the temperature of the vapor so that
          condensation has ceased. If condensation is still
          forming, solvent carryout will increase.

          When cleaning metal parts with spray, spray below the
          vapor zone. Spraying above the vapor zone generates a
          vapor-air mixture directly, which is immediately lost.
          Also, falling droplets of solvent disrupt vapor
          interface,  causing more vapor-air mixing. Spraying
          below the vapor zone can achieve up to a 5% reduction
          in solvent loss.

          Move the work slowly.  (See Appendix C for instructions
          on using the stop-and-go technique). Control the hoist
          speed to less than 11 feet per minute of vertical
          travel and ensure the proper conveyor speed.

          Don't overload the degreaser. Too large a mass of metal
          creates inefficient cleaning, excessive vapor drop,
          slow vapor recovery, and longer cleaning cycle,
          resulting in increased solvent consumption.

          Use properly sized baskets. Large baskets that fill the
          area of the degreaser opening create a piston action
          when entering and leaving. This forces vapor out, which
          creates more solvent-vapor-air mixing. The basket
          should have an area of less than 50% of the degreaser
          opening.

          Drain the parts. Solvent not allowed to drain properly
          from parts is lost immediately to evaporation outside
          the degreaser. Adjust the spacing in the baskets or the
          racks so drainage can occur.

6.   Avoid solvent carriers and solvent-absorbent materials.

          This includes such items as ropes, spacers, and wooden
          covers. Also, don't clean shop rags or gloves in the
          degreaser. Up to 5% savings in solvent are possible
          here.

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7.   Ensure proper solvent condition.

          Remove metal fines and parts, sludge, and oil buildup.

          Maintain inhibitor levels. Depletion of inhibitor
          levels could result in a catalytic breakdown of the
          solvent to form hydrochloric acid or metal chloride
          complexes, causing corrosion.

          Use the boil-down procedure. (See Appendix A.)

          Practice contract or in-house reclamation.

               Modifications to  existing degreasers

     To improve the efficiency with which a degreaser uses
solvent:
          o    Install automatic slide covers.
          o    Increase freeboard height.
          o    Install refrigerated freeboard chillers.
          o    Use carbon adsorption lip exhaust.
          o    Attach air refrigeration on the vent recycle.
          o    Install programmable transporters.

                          Case histories

     Below are two examples of how waste reduction benefited
chlorinated solvents users.
     One user consumed 500,000 pounds of trichloroethylene per
year in eight large cross-rod degreasers with process stills
attached. Waste from the stills was dumped into a storage tank
about every two days, then collected in drums for disposal. Waste
amounting to about 20 drums a month was collected from each
still.
     To minimize waste and reclaim more solvent, thus reducing
costs, the user now pumps the waste from each still into a
holding tank. About every two weeks, the waste is redistilled,
stirred,  and steam sparged to remove as much solvent as possible.
     This procedure reduces waste from 20 drums a month to five
drums a month and reduces virgin solvent consumption by 15 drums
a month.
     The second user has a 3 foot-by-5 foot, open-top vapor
degreaser to clean and finish parts from other companies.
Investigation of why the degreaser was cleaning poorly turned up
two problems.
     First, the cleaning basket was too large. It was acting as a
piston, pushing out vapors each time it was lowered into the
degreaser. This increased the vapor-collapse amount and shortened
the actual cleaning time.
     Second, the disk-like metal parts were stacked too closely
in the basket, resulting in inadequate cleaning and solvent
entrapment.

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     Reducing the size of the cleaning basket  and  stacking  parts
differently allowed the user to improve cleaning and reduce
solvent virgin consumption by up to 50%.

                      WASTE  DISPOSAL  ISSUES

     Even with the most efficient waste-reduction efforts,  waste
disposal still is necessary. That means environmentally sound
reclaimers, proper disposal, and fuel blending/burning — usually
in cement kilns or industrial furnaces — are  important.
     Many commercial reclaimers manage their wastes as fuel.  In
1981, 18% of the waste from commercial reclamation of chlorinated
solvents was managed as fuel. By 1986, the total was 49%. Some
experts would put today's figure at more than  90%. Disposing  of
this type of waste through fuel blending/burning has become even
more significant as restrictions on disposal in landfills have
increased.
     Burning wastes that have been blended into fuel in cement
kilns is particularly efficient. Not only are wastes used as
energy, but the chloride ions from chlorinated-solvents waste are
incorporated into the cement. Without fuel blending and
subsequent burning in cement kilns, there would be inadequate
commercial incineration capacity for the wastes that are being
generated in the United States today.

           CONCLUSION; THE BENEFITS OF WASTE REDDCTION

     Reducing waste from the use of chlorinated solvents for
metal cleaning means lower solvent costs and lower waste-disposal
costs. The improved efficiency that helps reduce waste also means
improved cleaning with no increase in solvent usage, another
savings.
     Dow hopes assisting chlorinated solvents users with waste
reduction will attract new customers, maintain existing
customers, reduce their liability exposure, and maintain the
viability of the solvents marketplace — all economic motives.
     Other significant reasons for practicing waste reduction —
to lower worker exposure to vapors, to  reduce solvent loss to the
environment, and to comply with health and environmental laws —
also have economic benefits.
     And the fact that so many reasons  relate to costs is
important. It gives credibility to the assertion that voluntary
waste reduction will work.
     Waste-reduction efforts and long-standing environmental and
product stewardship programs demonstrate a commitment to
protecting the environment. But waste reduction is just one part
of waste management. So safe, permanent waste management and
compliance with state and federal laws still are top priorities.
     Yet the bottom line really is that electing to take a
responsible approach to waste reduction makes good economic
sense. Waste Reduction Always Pays.

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                           APPENDIX A

           Procedure  for  boil down of a still/degr§aser

     When the temperature in the boiling  sump of the still
reaches 194 F (using trichloroethylene  as an example),
concentrate the sludge in the still.  Turn off the transfer pump
and close the gate valve in the dirty solvent line. Continue to
distill until the liquid level  reaches  the recommended minimum
level of two inches above the heating element(s).
     Turn off the heat in the boiling sump and allow the solvent
sludge to cool to 90 -100 F before draining. Drain the solvent
into a 55-gallon drum(s). Remove parts, metallic fines and chips,
or other insolubles by filtration or  decantation. Give particular
attention to the area under the heating elements.
     Close the drain valve. Open the gate valve in the solvent
line from the degrearr^r boiling sump to the still boiling sump.
Turn on the transfer  >ump.
     Once the liquid level reaches two  inches above the heating
element(s), turn on the heat. Add the necessary virgin solvent to
the clean dip of the degreaser  to properly maintain the needed
liquid levels in all chambers of the degreaser and still.
     Add the sludge solvent that was placed in the drum(s) back
into the still boiling sump at  the next boil down when the
solvent reaches the minimum level of two inches above the heating
coils.
     After the third or fourth boil down, send a sample from the
sludge drum to a laboratory for determination of nonvolatile
content. When the oil concentration reaches 60-70%, dispose of
the sludge material in compliance with regulations governing the
disposal of waste products. Thermal destruction through fuel
blending or incineration is recommended.

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                         APPENDIX B
       SOLVENT
     Specify Dow ... For Quality Solvents, Unmatched Technical Support
                                           Vol. 1, Number 6 • June 1987
Prolong Solvent and Equipment Life


By Controlling Water Contamination

 iVater in a degreaser can mean problems, employing a water separator. For water   Water scj
       ; in contact with boiling sol- separation, the condensed solvent/water  mimj
       ^   ^eo^uipment corro- mixture drops into a trough below the co(v>
               _have a denser coils and flows by gravu>
                   ^separator.
                        ater hasj



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                           APPENDIX C

                      Stop-and-go technique

     The following procedure was developed to reduce solvent
concentration in the ambient air near  the degreaser. It also will
reduce the solvent loss from a degreaser.
     Lower the work load into the vapor zone at a slow speed.
Otherwise, an excessive wave formation of the vapors will push an
unnecessary amount of the vapors out of the degreaser.
     The vapors will collapse as the work load enters the vapor
zone. Whenever the vapors have dropped two to four inches, stop
the load until the vapors stabilize or start to recover. At this
point, lower the load further until the vapors have dropped
another two to four inches.
     This stop-and-go method of entry prevents solvent vapors
from being pushed out of the degreaser by the plunger effect of
the work load. It allows maximum vapor recovery with shorter
cleaning cycles.
     Once the work load is covered by the vapors, it need not be
lowered further. Maximum area between the work load and the
boiling sump gives optimum vapor recovery. The work load should
never sit on top of the boiling sump.
     Remove the work load in increments of two to four inches
with pauses to allow the vapors to be entrapped in the freeboard
area.  This decreases vapor drag out.  Once the work load has
cleared the vapor zone, it should remain in the freeboard area
until all parts are dry and no solvent drips from the work load.

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  NOTICE: Dow believes the information and recommendations herein
to be accurate and reliable. However, since any assistance
furnished by Dow with reference to the proper use and disposal  of
its products is provided without charge, and since use conditions
and disposal are not within its control, Dow assumes no
obligation or liability for such assistance and does not
guarantee results from use of such products or other information
herein; no warranty, express or implied, is given nor is freedom
from any patent owned by Dow or others to be inferred.
Information herein concerning laws and regulations is based on
U.S. federal laws and regulations except where specific reference
is made to those of other jurisdictions. Since use conditions and
governmental regulations may differ from one location to another
and may change with time, it is the Buyer's responsibility to
determine whether Dow's products and services are appropriate for
Buyer's use, and to assure Buyer's workplace and disposal
practices are in compliance with laws, regulations, ordinances,
and other governmental enactments applicable in the
jurisdiction(s) having authority over Buyer's operations.

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On-Site Reuse and Recycle of
  Petroleum Waste Solvents

     Robert H. Salvesen

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                            ABSTRACT
In-plant reuse and recycle of solvents is an accepted practice
in many industries.  This paper reviews practices and equipment
which are appropriate for cleaners of parts and equipment.

Only non-halogenated solvents are discussed.  The major types of
solvents utilized are hydrocarbon (such as mineral spirits and
naphthas) and oxygenated (i.e., MEK, MIBK, Ethyl Acetate and
alcohols) materials.  By proper segregation, labelling and
management, essentially all solvents can be recycled.

Information is provided on the types of solvents which can be
recycled, equipment available, economic factors for
consideration and examples from industry on how recycling works.

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             IN-PLANT REUSE AND RECYCLE OF SOLVENTS

INTRODUCTION

Solvents used in most industrial operations serve as cleaning
agents or reaction media.  In most cases, the solvents are not
consumed but are contaminated by other substances.  The solvents
are disposed when the contaminant level exceeds certain criteria
limits.  These limits can vary widely depending upon the
particular process.  For example, for engine parts cleaning, the
solvent may contain up to 30-40% fuels, oils, water and solids
before it needs to be replaced.  In other cases, high purity is
required and contamination exceeding a few parts per million
signals a time to change solvents.  Thus, while the composition
of used solvents can vary considerably, the methods for reuse
and recycling are applicable to many process operations.

This paper deals with non-halogenated solvents used in parts and
equipment cleaning and will cover the following:

o  Types of solvents used

o  Generation and properties of used solvents

o  Options for reuse/recycling

o  Waste reduction practices and examples

TYPES OF SOLVENTS USED

Hydrocarbons

Hydrocarbon solvents used for parts and equipment cleaning may
be derived from petroleum, coal tar or natural sources.
Petroleum and coal tar products include the following:

o  Aliphatic Naphtha such as

    -  VM&P Naphtha
       Mineral Spirits (low and high flash)
                                                          \
o  Aromatic Naphtha

o  Toluene

o  Xylene

o  Isoparaffinic Solvents

The most common natural hydrocarbon solvent is turpentine.  Some
proprietary solvents may contain mixtures of some of the  above
along with lanolin (to reduce skin irritation), detergents  (for
water rinsing), colorants, perfumes and other additives.

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Paint Thinners

Paint thinners vary in composition to suit the specific paints
used.  These types of solvents can contain one or more of the
following hydrocarbon or oxygenated materials:

o  Petroleum or Coal Tar Naphtha

o  Isoparaffinic (odorless) Solvents

o  Toluene

o  Xylene

o  Ketones

    -  MEK (Methyl Ethyl Ketone)
    -  MIBK (Methyl Isobutyl Ketone)
       Others

o  Esters

       Ethyl Acetate
    -  Butyl Acetate

o  Alcohols

    -  Methyl
    -  Ethyl
       Isopropyl

o  Glycol Ethers

       Cellosolve  (Butyl, etc.)

Paint thinners are included because cleaning of parts and
equipment may often preceed painting and many of you might wish
to recycle thinners along with other solvents.

Other Materials

For the sake of completeness, mention should be made of other
organic and inorganic materials used for parts cleaning.  These
are heavy-duty cleaners and paint strippers, as noted below:

o  Organic Materials

These are generally mixtures of three or more of the following
solvents:

    -  Methylene Chloride
    -  Mineral Spirits
       Toluene and/or Xylene
       Ketones
       Esters

-------
      Alcohols
      Phenol or Cresols
      Glycol Ethers
   -  Wetting Agents

Suppliers produce proprietary mixtures which may also contain
surfactants, colorants, perfumes, etc.  Since the above are
mixtures, it is not common practice to recycle these materials
in-house, but there is no reason why large volume users could
not do so.  However, the recycled product should be reformulated
and thus the recycler must be knowledgeable in this technology.

o  Aqueous Systems

Acid and alkaline solutions have been used for heavy-duty
cleaning for many years.  Included in these categories are
organic amines, which are alkaline ammonium type compounds.
This paper will not cover recycle of these materials.

GENERATION AND PROPERTIES OF USED SOLVENTS

Generation Processes

Used solvent may be defined as any solvent contaminated with
other liquids and/or solids which render it unsuitable for its
intended purpose.  Cleaning solvents are generally used in
operations involving spraying, physical or vapor washing,
dipping, hand brushing, etc.  The major contaminants are fuels,
oil, grease, water, dirt, metals, paint and other substances,
depending upon the usage.

Cold Cleaning - The major non-vapor methods for cleaning parts
and equipment involve the following:

o  Wash Stations - in this operation, solvent is generally
   circulated by pump and the part washed continuously with a
   stream of liquid.  Dissolved materials accumulate in the
   solvent, and solids are often removed with screens or
   filters.

o  Spray Booth - solvent is aspirated from a container, mixed
   with air and impacts the part to be cleaned.  The sprayed
   solvent is collected and recirculated.  Soluble materials
   accumulate and solids are removed as noted above.  Organic
   vapors are generally carried out the exhaust and may or may
   not be collected and recycled.

o  Dip Tank - a large container of solvent is used for immersion
   of the part in solvent.  Mixers may be added to accelerate
   cleaning.  As above, soluble and insoluble materials
   accumulate.  Some solids may settle out.

o  Hand/Bucket Cleaning - this is the simplest operation, and
   commonly used by small operators.  Brushes or rags are often
   used to remove tough dirt.

-------
In all of the above processes, the solvent continuously degrades
in quality because of accumulation of both soluble and insoluble
materials.  The amounts of various soluble and insoluble
contaminants allowed to accumulate before changing solvent are a
function of process requirements.

Vapor Degreasing - In vapor degreasing, the parts to be cleaned
are suspended above the liquid and are cleansed by warm vapor
condensing on the component.  The condensed solvent and
contaminants are returned to a reservoir where water, dirt, oils
and other contaminants are collected.  Clean vapors are
continuously available to wash the parts.  Solvent is changed
only when contaminants and sludge build up enough to interfere
with vapor cleaning.  Many units have separate solvent
distillation equipment as an integral part of the system.  Other
speakers will discuss this technology in detail.

Properties of Used Solvents

Typical properties of used and virgin (or recycled) hydrocarbon
solvent (Mineral Spirits) are given in Table 1.  This example
would be typical of usage for cleaning gasoline engine parts.
The major contaminants are as indicated below.

o  Gasoline - this is indicated by the low flash point and low
   boiling (less than 320 F) compontents.  The used solvent may
   contain 10-20% of gasoline.

o  Water - water can be detected by various means.  In the
   example given, it might show up as a separate fraction during
   the distillation.  It would also be detected in the Water,
   Oil and Sediment Test.

o  Oil and Sediment - dissolved lube and other oils would be
   detected in this test as well as sediment.  By proper
   distillation, the contaminants can be removed and the
   reclaimed solvent will meet new or virgin product specifica-
   tions.

Other pure organic materials which might be used as cleaners
such as MEK,  Ethyl Acetate and others, might have similar
contaminants, and can be reclaimed to original specifications.

Paint thinners are a special case.  Since thinners are blended
products and formulated to meet specific volatility and
solubility requirements, their reclamation for use as paint
thinners is not generally recommended.  However, used paint
thinners are mainly generated from cleaning of brushes, spray
guns and other application equipment.  For these purposes,
product specifications are not usually of significance.

Thus, used paint thinners can readily be reclaimed either by
gravity settling, filtering, distillation or other means.
Reclaimed paint thinner is usually sastisfactory for cleaning
equipment, but is not recommended for thinning paints.

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                                  TABLE 1
             PROPERTIES OF  USED AND RECYCLED MINERAL SPIRITS
Test

Flash Point,TCC, F
Distillation, F
      IBP
      10%
      20%
      30%
      40%
      50%
      60%
      70%
      80%
      90%
      FBP
Residue
Chlorine Content
Water, Oil &
 Sediment, %
Appearance
Test Method

 ASTM-D-56
   11  D-86
 ASTM D-95
 Visual
   USED
  Solvent

<100-120

 150-330
 150-340
 170-340
 300-345
 320-350
 325-350
 330-370
 340-390
 350-400
 400-600
 Above 500
 30 Vol % (Max)
 2-20
 Brown/Black
 Reclaimed
  Solvent

102-110

315-330
320-340
                                325-350
                                330-365
                                350-400
                                2-5 Vol %
  Clear /White

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OPTIONS FOR REUSE AND RECYCLING

Consideration of options for reuse and recycling of solvents
should include segregation practices, substitutes and down-
grading, equipment requirements, costs and environmental
regulations.  These concerns are discussed below.

Increasing Reuse and Recyclability

Segregation - Segregation of solvents is one of the most
important management steps impacting on reuse and recyclability.
Past practices have often neglected segregation and changes are
sometimes difficult to implement.  What to segregate depends
upon what downstream operations will be used.  Generally,
solvents need to be strictly segregated by each individual type.
Mixing solvents often makes in-house recycling impossible.
Proper labelling and/or color coding and adequate containers for
collection of used solvents enhances segregation.

Substitutes - Replacement of one solvent for another is often
easier said than done, but it needs to be considered and can
lead to easier recycling.  Several examples follow.

If chlorinated solvents are used for cleaning electrical parts
and hydrocarbon solvents for machine parts, it may be
appropriate to use a hydrocarbon solvent for both to simplify
recycling.  While hydrocarbons are often used for both, some may
not prefer to use these solvents because they evaporate more
slowly and are flammable.

Ethyl Acetate is sometimes used for cleaning purposes.
Replacement with a hydrocarbon solvent can often provide similar
results and simplifies reclamation.

Proprietary hydrocarbon solvents often contain emulsifiers,
lanolin, colorants, odorants, etc., which may or may not be
essential to the cleaning process.  Recycling this type of
mixture reclaims only the hydrocarbon fraction.  Thus, the
recovered material is not the same as the proprietary solvent.
Reformulation of the solvent can be done by a knowledgeable
person, if desired.  The ingredients noted above may or may not
be essential, as noted below.

Emulsifiers - are used to aid in solvent penetration of
water-wet oil, grease or dirt.  The emulsifiers also enable the
solvent to be washed off with water.  If these properties are
not essential, emulsifiers are not needed.

Lanolin - is added to provide residual oil, thus reducing skin
irritation and dryness caused by contact with the solvent.  This
ingredient is not essential to the cleaning process and solvent
users should wear gloves or use a hand cream after contact.

Colorants, Odorants - and other ingredients are generally added
for product identification and customer acceptance.  While these

-------
factors can be of some importance, they are not essential for
cleaning purposes.

Aqueous Emulsion Systems -  have been offered as substitutes
for cleaning solvents and are claimed to be effective for
cleaning engine and electrical parts.  These systems may be
satisfactory for a number of applications.  However, there are
two major concerns.  One is that water-based systems may require
drying to eliminate residues.  A second problem is disposal of
the dirty water.  If significant quantities of oil, grease or
other organic materials are carried off in the water, some
treatment may be required prior to discharge.

Downgrading - In-plant reuse by downgrading is a common practice
where a number of cleaning operations are conducted.  Following
are several examples:

o  Cleaning of bearings often requires use of high purity,
   virgin solvent.  Since these bearings are relatively clean to
   start with, the used solvent from this operation can readily
   be downgraded for use in cleaning dirtier engine components.

o  Calibrating fluid used for fuel system components is often a
   special grade of mineral spirits.  After usage, this material
   can be downgraded for other solvent purposes.

Economics - The economics of solvent recycling is dependent upon
the following costs:

o  Solvent

o  Percent .of recoverable solvent

o  Collection and segregation

o  Equipment and installation

o  Operations

o  Quality Assurance/Quality Control

o  Disposal

A generalized cost estimate for solvent recovery and payback of
equipment costs is given in Figure 1 for solvents costing from
$l-ll/gallon.  It may be seen that both solvent costs and volume
have a significant impact on payback periods.  More detailed
cost studies are needed for specific cost/benefit analysis.

Processes and Equipment Us^d

There are a number of pro   ;ses utilizing equipment for
separating and recycling  ^ed solvents.  Most operations for
in-plant use are simple, but a wide range of options are

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                                                FIGURE  1
                           PLOTS  OF SOLVENT VOLUMES VS PAYBACK PERIOD (YEARS)
                                     FOR SOLVENTS OF DIFFERENT COSTS
                                                Halogenated)
                                                i.e. MeCl
1000
     4          5

YEARS TO PAYOFF INVESTMENT
                                                                                     8

-------
available, where appropriate.  These methods are discussed
briefly in this section and another paper covers this subject in
greater detail.

Gravity Separation - Simple settling of solids and water is
often practiced for reuse of solvents.  Paint thinners may be
reused many times if solids are allowed to settle.  The
supernatent liquid can be removed for cleaning purposes.
Centrifuges are also used to accelerate gravity separation.

Batch Stills - This type of equipment may be described as a
flash, pot or single-plate batch still.  The used solvent is
heated, vaporized and the vapors condensed into a ^eparat-
vessel.  Solids or high-boiling liquids remain in ihe pc   ;>r
distillation vessel as " residue.  Liquids boi?    up t   oout
400 F can be recovered.   ~,f mixe  liquids are i  1 they   .11 not
be separated unless the   nal be   ng point of   a solve r is
about 50-60 F below the  aitial .  .ling point c  the of jr
solvent.

There are numerous suppliers of this type of equipment.  Major
design variations include the following:

o  Size - from 5-500 gallon capacity

o  Heating

      Electrical
      Steam jacked
      Direct steam injection
      Heat transfer fluids

o  With or without vacuum attachment

o  Materials of construction

o  Clean out

      Bottom
   -  Side
      Top
      Lift-out trays
      Plastic bag liners

o  Controls

Costs range from $2-3,000 for 5-gallon units to well over
$100,000 for the largest stills.  These units are capable of
reclaiming solvents to purity standards meeting or exceeding new
product specifications.

Fractionation Units - For separation of solvent mixtures,
fractionated units may be required.  These are generally
custom-made and can be provided to meet almost any separation
requirement.  Size, efficiency and design can be varied to suit

-------
the needs.  Costs generally range from $30,000 and up.

Thin Film Evaporators - This type of unit is a variation of
flash stills in which a. thin film of the used material is
deposited on a rotating, hot metal surface.  The solvent is
flashed off, vaporized and either condensed or passed on to a
fractionating unit for separation of specific solvents.  These
units are very versatile and specially suited for viscous
liquids.  Costs range from about $30,000 and up.

Vapor Degreasers With/Without Recycle - For continuous cleaning
operations, and those desiring excellent solvent penetration,
vapor degreasers are often preferred.  Only the vapors contact
the parts and condensate is returned to a sump.  Some designs
have condensers around the sides of the vessel and others at the
top.  Fresh, clean solvent is continuously vaporized to clean
parts.  In systems without internal recycle the solvent can
become contaminated with components that vaporize with the
solvent to reduce cleaning effectiveness.  To avoid this, the
dirty solvent may be recycled in a separate unit where the
contaminants are removed.  Generally, vapor degreasers are
fairly large units containing from about 50 to several hundred
gallons of solvent.  Costs are also proportionately large
ranging from $100,000 and upwards.

Toll Recyclers - A variation of in-plant recycling can be
accomplished by toll recyclers.  While the solvent is not
recycled on-site, the solvent is replaced on-site.  Solvent wash
stations are often serviced by companies in this business.
Service charges may vary from 50-90% of new solvent costs.

HAZARDOUS WASTE REDUCTION PRACTICES AND EXAMPLES

Audit

Any waste reduction program should start with an audit.  This
can be a do-it-yourself activity or larger facilities may wish
to hire an outside consultant.  The basic components of a waste
audit are outlined in Table 2 and a format for actual use is
given in Table 3.  Audits should be conducted by personnel
familiar with the solvents used, process operations, handling,
treatment and disposal options.  Several illustrative examples
follow:

o  Poor Material Selection

      At a large shop, a decision was made to use a proprietary
      solvent when a less expensive non-proprietary solvent
      would have saved money and been easier to recycle.

      A salesman recommended replacement of a chlorinated
      solvent by an odorless paint thinner for engine parts
      cleaning.  The user did not realize that common mineral
      spirits would have done a better job and cost about 50%
      less.

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            TABLE 2



      WASTE AUDIT OUTLINE



Step 1 - Collect Information



o  Tabulate existing data



o  Mass balance assessment



o  Check completeness of data



Step 2 - Evaluate Waste Handling



o  Raw materials



o  Housekeeping



o  Costs



o  Sources



o  Practices of personnel involved



Step 3 - Management Alternatives



o  Approach for each waste



o  Employee requirements and training



o  Housekeeping improvements



o  Segregation



o  Capital investments



o  Reformulation



o  Reuse



o  Technical, economic and liability assessments



Step 4 - Review and Update



o  Assess progress



o  Track and assess changes in



      Raw materials



      Processes



      Products



      Technology



      Regulations

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                                  TABLE 3

             STANDARD WASTE AUDIT FORMAT - AUTOMOTIVE REPAIRS

o  Name and location of shop or business
o  Name of audit personnel
o  Date of audit
o  Type of Shop

       Automotive repair
       New car dealer
       Diesel repair
       Transmission repair
    -  Brake/muffler shop
       Radiator service
       Alignment
       Suspension/chassis
       Scheduled maintenance
       Quick lube changes
    -  Body/painting

o  Size of shop

       Vehicles serviced per week
    -  Number of service bays available

o  Services provided
o  Number of employees
o  Raw materials used
o  Raw material storage (complete for each item)

    -  Raw material (brand name/common name)
       Item number
       Volume in inventory
       Describe usage
       Describe disposal practice
       Describe storage facilities
        (i.e.) 55-gal drum
               Containers (volume)
               Above or underground tank,
               Covered/open
               Indoor/outdoor
               Secured

       Delivery system
        (i.e.) Gravity
               Funnel
               Pump

       Material control practices
        (i.e.) Stockroom attendant
               Access (limited/unlimited)
               Signout sheet

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                            TABLE 3 (Continued)

o  Material usage (describe for each type)

       Sink (size/description/location)
    -  Dip tank (size/description/location)
    -  Jet spray (size/description/location)
       Spray hood (size/description/location)

o  Waste material management

       Segregation practiced (if yes,  describe)
       If no segregation, describe practice
       Options available for segregation
       Storage facilities (describe)
       Disposal practices
        (i.e.) On-site recycling
               Serviced by equipment leasee/maintenance contractor
               Picked up by contractor
               Disposed in municipal solid waste
               Disposed to municipal sewer

       Disposal costs
        (i.e.) Oils
               Solvents
               Res idues/sludges
               Anti-freeze
               Aqueous materials
               Other

o  Material losses
o  Provide a schematic for waste management practices
o  Prioritized sites of significant waste generation
o  Waste management options
o  Source reduction options

       Material substitutions
       Process changes
       Housekeeping

o  Regulatory compliance evaluation and needs
o  Recommendations for improved management

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Selection of the Best Option

After completion of an environmental audit and consideration of
viable options, economics and applicable regulations, selection
of the best option should be relatively easy.  The major
management practices which need to be selected are discussed
below.

Segregation - Uncontrolled mixing of used solvents yields waste
slops with little or no economic value and little chance of
recycling.  In addition, because waste mixtures are often
designated as hazardous wastes, their disposal is becoming more
costly.  A summary of recommended options for a number of
solvents is given in Table 4.  Segregation by each individual
solvent is generally the best means of optimizing recovery and
minimizing costs.  Alternate options are usually less desirable
and not as cost effective.

o  Example

We have all seen or heard of locations with vast numbers of
drums of mixed solvents and other materials.  These were
accumulated because plant operators were not concerned about
disposal or were not willing to pay disposal costs.  My
experience has been that many plant managers believed these
drums contained valuable materials which should have been
marketable, but realistically, were not.

Many superfund sites were created because of improper management
and disposal.  With a minimum of segregation, many of these
waste drum fields could have been disposed to cement kiln
operators who had capabilities for burning a variety of
mixtures.

Collection - Adequately marked containers must be provided to
encourage and ensure proper collection and segregation.  Good
practice includes color coding, visible and legible labels, and
a manifest system.  Color coding can simplify identification and
is easy to implement.  Labels can be hung on walls, placed on
top of a container or stencilled on collection drums.  Labels
stencilled on both sides of a container work well, those only on
top can be obliterated by a spill.  A manifest should be used
even for internal recycling.  The generator should fill out a
manifest form,  attach it to the container, and have a copy sent
to the recipient and to a central control person.

Recycling - Recycling or reclamation of used solvents can be
accomplished with in-house equipment and facilities for almost
all pure solvents, but is generally not practical for some mixed
solvents.  This discussion covers solvents segregated and
collected after use as well as solvents recovered in vapor
recovery units.

Recyclable and Non-Recyclable Solvents - Solvents which can be
recycled readily are listed in Table 4.  These materials can

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                                                   TABLE
       SUMMARY OF SEGREGATION RECOMMENDATIONS FOR RECLAMATION AND DISPOSAL OF SOLVENTS
      SOLVENT
                    SEGREGATION GUIDELINES
Hydrocarbons
Calibrating Fluid

Coal Tar Naphtha
Dry Cleaning Solvent
- 100F Min.Flash Point
- 140F Min.  "     "
Naphtha, Aromatic
Thinner, Paint
Xylene
Agitene
Naphtha, Aliphatic
Toluene
   Preferred Option

Segregate and reclaim
for original use
                                                              Alternate Options
                        Mix and recL.jn
                        as a  general
                        cleaner or wash
                        solvent
                        DO NOT MIX
                        WITH ABOVE
                   Can mix with
                   chlorinated and
                   oxygenated solvents
                   for disposal to
                   selected cement kiln
                   operators
Halogenated
Methylene Chloride
Tetrachloroethane
1,1,1-Trichloroethane
Trichloroethylene
1,1,2-Trichloro-
1,1,2 trifluoroethane

Oxygenated
Acetone
Ethyl Acetate
Ethyl Alcohol
Isopropyl Alcohol
Methyl Alcohol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Segregate and reclaim
for original use
Segregate and reclaim
for original use
Mix and reclaim
as a general
cleaner or wash
solvent
-*
All chlorinated,
hydrocarbon and
oxygenated solvents
can be mixed and disposed
to selected cement kiln
operators
Can mix with all chlorinated and
hydrocarbon solvents for disposal
to selected cement kiln operators

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generally be recycled to meet original solvent specifications.

In addition to those noted above, paint thinners can also be
recycled.  Since most thinners are mixtures and lose volatile
solvents in use, the recycled solvent is not the same as virgin
material.  Thus, reclaimed thinner should not be used as a paint
thinner but can be used to clean paint equipment.

Typical non-recyclable solvents are noted below, along with
brief comments.

Carbon Removers and Paint Strippers

These mixtures are generally quite toxic since many contain
phenolic compounds and thus in-house recycling is not
recommended.

Proprietary Solvents

Many proprietary cleaning solvents contain additives (as noted
above) which are not recovered in distillation.  Therefore, the
recycled material is not the same as the original solvent.

Processes and Equipment Used - The major processes and equipment
used are discussed briefly below:

Gravity Separation - Used mainly for paint thinners.

Batch Stills - Many companies manufacture, sell and service
batch stills for in-house recycling of solvents.  A list of the
major suppliers is given in Table 5 along with some general data
on the types, ranges, features and costs of this equipment.

These units will not separate solvents and must be used for only
one solvent at a time.  They can be used for a variety of
solvents with cleaning between batches.

o  Examples

   NAVY-At the Naval Shipyard in Portsmouth, Va., a 15-gal/
      day batch still has been successfully used to recover
      mineral spirits and paint thinners.  Savings amount to
      about $15,000 per year and the equipment was paid off in
      less than six months*.

   AIR FORCE-Robbins AFB has a number of different units for re-
      cycling over 50,000 gallons per year of various solvents.
      Total savings are reported to be over $600,000 per year.

*  This information was obtained from an article dated 11/5/84
   that appeared in the Virginia Pilot (a local Portsmouth, VA,
   newspaper).

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                                                   TABLE 5

                              SUPPLIERS OF SOLVENT RECYCLING EQUIPMENT SUITABLE
                            FOR ON-SITE RECLAMATION - SINGLE-PLATE PACKAGED STILLS
Supplier

Alternative Resource
Management
7134 S. Yale(Suite 400)
Tulsa, OK 74136
918-495-0535
         Solvent
Thruput  Capacity  Heating
G/Hr(l   Gallons   Options

1.5-100  5-100    Electric/
                  Steam
             Cooling  Explosion Cost  Solvent Types
             Options    Proof    $K   Designed for    Comments
             Refrig/
             Water
Yes
2.5-  All
100+
Atmospheric &
Vacuum Models
Available
Baron Blakeslee
2001 N. Janice Ave.
Melrose Park, II. 60160
312-450-3900
10-120   8-95     Electric/    Refrig/     No     5-8   Halogenated
                  Steam        Water
Branson Cleaning
Equip. Corp.
P. 0. Box 768
Shelton, Ct. 06484
203-796-0400
12-60   10-60     Electric/    Refrig/     No     4-10  Halogenated
                  Steam        Water
BR Instrument Corp.
P.O. Box 7
Pasadena, MD. 21122
301-647-2894
1-2      3-6      Electric     Water       Yes    9-12  All
                                                    For Lab
                                                    Operations
DCI International
1229 Country Club Rd.
Indianapolis, IN 46234
317-271-4001

Detrex Chemical Ind.Inc.
P. 0. Box 501
Detroit, Mi. 48232
313-358-5800

Disti Inc.
131 Prince St.
New York, N.Y. 10012
212-505-0611

Finnish Eng. Co.
(Extratec)
921 Greengarden Rd.
Erie, Pa. 16501-1591
814-455-4478
250      250
30-180  50-200
Dir. Steam   Water
Injection
Electric/    Water
Steam
Yes    N/A   All
2-70    10-50     Steam/
                  Hot Oil
             Water
15-380   5-50     Electric/    Water
                  Steam
                                           No
       5-10  Halogenated
                         Yes    8-54  All
                         Yes    5-80  All
                    For Removal of
                    Solvents from
                    Oils
                           Make a Wide
                           Range of ATM.
                           & VAC. Models

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                                                     TABLE 5(Continued)
Finishing Equip. Inc.
3640 Kenneber Dr.
St. Paul, Mn. 55722
612-452-1860
N/A*     N/A      Electric/    Water       No
                  Steam
                                         N/A   Halogenated
Giant Distillation &
Recovery Co.
3156 Bellevue Rd.
Toledo, OH 43606

Hoyt Corp.
Forge Rd.
Westport, MA. 02990
617-636-8811
1.5-     5-60     Electric/    Water       Yes
10                Oil
4-8      25-50    Oil
                      Water       No
                                         5-100 All
                                                    Atmospheric &
                                                    Vacuum Models
                                                    Available
                                N/A   Halogenated   Also Make Vapor
                                                    Recovery Units
Lenape Equipment Co.
P. 0. Box 285
Manasquan, N.J. 08736
201-681-2442
4-45     5-30     Electric     Refrig/     No
                               Water
                                         3-20  Halogenated
National Ultrasonic       N/A
Chicago, II. 60626        (2)
312-465-6780
          N/A
          N/A
               N/A
           N/A    N/A   Halogenated
Phillips Mfg. Co.
7334 N. Clark St.
Chicago, II. 60626
312-338-6200
5-125    15-125   Electric/
                  Steam
                       Water
                         No
                  7-15  Halogenated
Progressive Recovery Inc 5-35
1976 Congressional Dr.
St. Louis, Mo. 63146
314-567-7963
         5-25
         Hot Oil
                                Water
                                  Yes
                                8-30  All
Ramco Equip. Co.
32 Montgomery St.
Hillside, N.J. 07205
201-687-6700
25-200   30-135   Electric/
                  Steam
                       Water      No     7-20  Halogenated   Also Make
                                                             Custom Designs
Recyclene
1910 Trade Zone Blvd.
San Jose, Ca. 95131
408-945-8600
2-20
15-35
Electric/
Heated
Oil
Water
Yes
4-21  All
Vaco Solv Co.
P.O. Box 26147
Cincinnati, OH. 45226
513-321-9178
1.6-10   5-60
         Electric
             Air
           Yes
       10-3  All
                    No Cooling
                    Needed
Westinghouse Elec. Co.   15-30
Box 300
Sykesville, Md. 21784
301-795-2800
         18-50
         Electric
             Refrig/
             Water
           No
       7-10  Halogenated
*  N/A = No Available Data

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   INDUSTRIES-Many industries have successfully recovered
      solvents with in-house units, thereby saving valuable
      resources, and eliminating or drastically reducing
      disposal requirements.

Fractionation Units

Custom-made fractionation units can be obtained from companies
such as those noted in Table 6.

Thin Film Evaporators

To recover solvents from high viscosity fluids, thin film
evaporators or wiped surface evaporators are generally
recommended.  In some cases, these units may be followed by
fractional distillation units for better separation of solvents.
Suppliers of this type equipment are noted in Table 5-6.

o  Example

   NAVY-The Navy has been recovering Freon 113 at Portsmouth,
      Virginia Naval Shipyard for many years and saving $20,000-
      30,000 per year.

Vapor Degreasers With and Without Recycle

Vapor degreasers are usually large units which generally have a
freeboard area for condensing vapors above the vapor cleaning
section.  Some units contain internal solvent recycle systems,
thereby minimizing the need for cleanout.  Most vapor degreasers
utilize halogenated solvents.

Disposal - Disposal of sludge bottoms from most distillation
units is still necessary.  Experience has shown that for
solvents used in precision cleaning, only a small volume of fine
solids is obtained.  These solids can often be disposed as a
non-hazardous solid waste.  At the other extreme are sludges
from paint thinners.  These residues can be taken to dryness and
disposed as a hazardous waste.

Interesting exceptions are still bottoms from mineral spirits
used for engine cleaning.  The residues are mainly oils and can
often be blended in with waste oils for disposal.

In almost all cases where solvents are recycled, some residues
remain which have to be disposed as hazardous wastes.  Options
include land filling, incineration, encapsulation, blending with
asphalt and others.

CONCLUSIONS

In-plant recycle and reuse of solvents can be achieved for most
solvents.  The major concerns are:

   -  Quality and quantity of used solvents

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                                TABLE 6

     SUPPLIERS OF SOLVENT RECYCLING EQUIPMENT SUITABLE FOR ON-SITE
     RECLAMATION - CUSTOM BUILDERS OF FRACTIONAL DISTILLATION UNITS
       Supplier

Advanced Process Systems
10400 Linn Station Rd.
 Suite 310
Louisville, KY. 40223

Artisan Ind. Inc.
73 Pond Rd.
Waltham, Ma. 02154
617-893-6800

Chem-Pro Equip. Co.
27 Daniel Rd.
Fairfield, N.J. 07006
201-575-1924

pistillation Eng. Co.
'105 Dorsa Ave.
Livingston, N.J. 07039
201-992-9620

Ferguson Ind. Inc.
1900 West Northwest Hwy.
Dallas, Tx. 75220
214-556-0010

Finish Eng. Co.
921 Greengardens Blvd.
Erie, Pa. 16501
814-455-4478

Progressive Recovery Inc.
1976 Congressional Dr.
St. Louis, Mo. 63146
314-567-7963
Thruput
Gal/Hr
  (1)

 5-100
Type of Equipment Available

        Solvent
        Capacity   Explosion
        Gallons      Proof
 10-50
  5-50
  5-50
   N/A
   (2)
 5-50
 3-30
          5-100
          10-50
          10-50
          10-50
            N/A
          10-50
          10-50
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Price
 $K

20-50+
20-30+
20-30+
20-30+
20-30+
20-30+
20-40+
(1)  For the lowest volatility solvent
(2)  N/A = No data available

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                                     TABLE 7

                SUPPLIERS OF SOLVENT RECYCLING EQUIPMENT SUITABLE
                 FOR ON-SITE RECLAMATION - THIN-FILM EVAPORATORS
      Supplier

Alpha Laval Inc.
2115 Linwood Ave.
Ft. Lee, N.J. 07024
201-592-7800

Artisan Ind. Inc.
73 Pond St.
Waltham, Ma. 02154
617-893-6800

Brighton Corp.
11861 Mosteller Rd.
Cincinnati, Oh. 45241
513-771-2300

Luwa Corp.
P. 0. Box 16348
Charlotte, N. C. 28216
704-394-8341

Progressive Recov. Inc.
1976 Congressional Dr.
St. Louis, Mo. 63146
314-567-7963
          Solvent
 Thrput   Capacity  Heating
 Gal/Hr*  Gallons   Options

                    Hot Oil
   5-50      5-50   Steam/
                    Oil
7.5-200     5-200   Steam/
                    Hot Oil
50-1200     Cont.   Steam/
                    Hot Oil
 15-300    15-300   Steam/
                    Hot Oil
          Price
Cooling   Range
Options     $K

Refrig./     50+
Water
Water
Water
Water
Water
50-130
 18-43
25-50+
40-120
*  For the lowest volatility solvent

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      Segregation and handling practices

      Selection of recycling equipment

      Management practices

      Costs for operation and maintenance

After completion of an environmental audit and review of the
above, experience has shown that in-house recycling is often the
most cost-effective and environmentally-preferred option.

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Off-site Reclamation of All Solvents




         Brian R. Dawson

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           SOLVENT  WASTE REDUCTION ALTERNATIVE SEMINAR









            Commercial  (Off-Site) Solvent Peclaniaticr




                      by:   Brian P.  Dawson




                 Solvent Resource Recovery, Inc.




          (division of  Chemical  Waste Management, Inc.)
     Solvents are  an  important  part  of most  industrial




operations.   Almost ell  plants  use  solvents,  usually  for




cleaning,  degreasing,  painting,  paint stripping,  or extraction



purposes.   Therefore,  the  problem  of proper management of solvent




wastes  is  a widespread concern.   There are  several  disposal




methods available to solvent users,  but  in  most  cases  the most



environmentally sound  and  economical choice  is  not to dispose of




the solvent at all,  but  to  recycle it.








     Tf we briefly review  the  generally  accepted priority list of



hazardous  waste management,  we see that  first,  it is  incumbent




upon generators  of waste to institute a program to reduce  the




amount of  waste generated.  Second, after  the  amount  of  waste




generated  has been minimized,  recycling is considered the next




most  appropriate  alternative.   Third  on  most  lists  is



incineration,  and fourth  is  chemical  or biological  treatment to



render the waste  non-hazardous.   Landfills,  deep-well  injection

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and other  methods  fall  further down the list.








     /> s you  can  see,  recycling  is  ranked  very  high on  the



priority list of alternatives  for  hazardous  waste management.




This   is   because   it  accomplishes  two  very  important



objectives... one,  it further minimizes the  quantity of  waste to



be handled,  and  two,  it  conserves  precious natural  resources.



Waste min im i zat ion is accomplished  because the reclaimed solvent




becomes a  usable product,  no longer a waste.  Natural resource



conservation  is accomplished because  the  petrochemical  building



blocks necessary for virgin  manufacture are  not required, and the



utility  r equ i r ements  (such as electricity and steam)  to reclaim.



are a fraction  of  the requirement for  virgin manufacture.








     There are  many  types  of solvents  that are commonly recycled.



Host prevalent  are paint solvents.  Almost any  industrial process



involves painting, and requires  solvent for  application, cleaning



of paint masks, spray equipment,  and  line  flushing.    Even the



manufacture  of paint  requires solvents for cleaning of mixing



equipment, and  transfer lines.  The  solvents  generally used for



these purposes  are  various  mixtures of ketones (such as acetone,



methyl ethyl  ketone, and methyl  isobutyl  ketone), esters (such as




ethyl, acetate,   n-butyl acetate,  and isopropyl acetate), alcohols



(such  as  ethanol,  isopropanol,  and n-butanol),  and  aromatic



hydrocarbons  (such as toluene  and xylene).

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     In  the  metal  working  industry,  lubricating oils,  cutting



oils,  and greases  are  used  in  the processes, and must be removed



prior  to further work, such as plating  or  painting.  The solvents



used for this  type of  cleaning  include chlorinated hydrocarbons



and p etroleum  distillates such as  various  mineral  spirits,



toluene, and x
     In the  printing  industry,  solvents are  used  as  ink



additives,  and  also  for cleaning  of  rollers  and presses.



Commonly used are alcohols, esters,  and aromatic hydrocarbons, as



well as various mixtures thereof.








     The electronics  industry uses many  solvents for  cleaning,



stripping, defluxing,  and even  as  a  photo-resist developer for



printed circuit  boards.   Generally  used  are  chlorinated and



fluorinated hydrocarbons.







     There are also thousands of snail  commercial establishments,



such as  auto repair  garages,  auto  body  shops, and dry cleaners



using solvents such  as petroleuir,  hydrocarbons,  paint  thinners,



and perchloroethylene.








     Virtually  all  solvent  use applications  are physical in



nature - not  chemical.   In  other words, the chemical structure of



the sc  vent  is not  altered.  It is  merely contaminated,  so the



purpose  of  solvent  reclamation is  to  remove the  impurities,

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making the solvent  available  for  reuse.  The  reclamation process




also does not chemically alter  the  solvents,  therefore, there is




no  limit  to  the number of times a solvent may  be  recycled or



reused.








     Cn-site  reclamation, where practical,  is  generally  preferred



to off-site  reclamation, in order to avoid  the risk  and  liability



of  transportation.   If not  practical,  though,  due to  economic oc



cuality  limitations,  off-site reclamation should be  considered as



your next alternative.








     There are  two  basic types  of off-site  or  commercial  solvent



recycling  available.   Cne  is  custom  toll recycling,  where  the




generator's  spent solvents  are kept  segregated, and  batch



processed  separately  to  the  generator's  specification,  then



returned for  n-'use.  V'/hile  the  requirements vary  among  different




processors,  the minimum  batch  size  is generally  1,000-2,000



gallons, so this option is usually  limited  to larger  generators



of waste.








     The  batch  size  limitations are caused  by processing



equipment size,  economies  of  scale, and sometimes transportation




costs.








     The  processing equipment  is  engineered to  handle  large




volurres  of waste, and small  batches will not  "wet"  the system,

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causing a very  low  percentage  of  recovery.   If the distillation



system  is designed to circulate  50C gallons  through the  heat



exchanger,  a 1,000 gallon  batch  of waste processed can  yield a



rcaxirum of 50% recovery.   However, a  2,000 gallon batch can yield



75% recovery, a 3,000 gallon  batch can  yield 83% recovery,  a



4,OCO  gallon batch  can  yield  80%,  and so on.








     Economies  of  scale  realized from larger batch sizes come



from the charge  or  fill  time, heat up time, still bottoms pumping



time,  and cleanout  tiire.  Each  of these  steps  are  necessary for



all hatches, and  require approximately  the  same amount  of time



whether processing  1,000  gallons or  4,000  gallons.








     Transportation costs are often comparable, whether shipping



full truckloads  or  partial truckloads, so  the larger the quantity



shipped translates  to  a  lower .cost per gallon.








     If  the  above limitations  can be  overcome,  significant



benefits can  be realized.  The generator  can  be assured that  the



reclaimed solvent  returned  is not  contaminated with any solvent



foreign to his system,  since  the waste  is  kept  segregated through



all processing steps,  thereby simplifying  quality  assurance and



quality  control.   The  generator  is also dealing with a "known"



entity, i.e.  the solvent  returned  is coming  from  solvent waste



already used  in his operations.  This can  simplify  SAPA Title  III



and Kcrker Fight-to-Know concerns.

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     Economics  of  custorr  toll  recycling are governed by four key




factors.   The first  is  processing  cost.   Processing  costs not




only  entail  the usual  items  such  as  labor, utilities, and



equipment  i n ve s tme n t,  but  also  the administrative  costs



associated with  maintaining environmental  compliance.   Processing



costs are also  affected hy specifications  required.  The narrower



or tighter the specification for  the reclaimed  solvent, the



higher the cost,  especially if drying is required.   Second  is the



disposal  cost of  the still  bottom  residues,  or  otherwise



unrecovered  portions  of   the  waste  stream.    Third  is



transportation  cost.   Last, though  probably most  important, is




the percent recovery,  or  yield.   The higher  the  yield,  the  lower



the unit processing  cost,  the  lower  the disposal  cost,  and the



lower the unit  transportation cost.








     Generally,  after  all costs  are considered,  the reclaimed



solvent is returned  to  the generator  at  a price  similar  to or



slightly lower  than  virgin solvent  purchase.   Vvhile this  may not



seem to be very motivating, we must not forget  to  consider the



alternative - if the  spent  solvent is not  recycled,  it  must be



disposed,  and  disposal costs  are  very  high  these   days.



Therefore, recycling avoids  the  disposal  alternative,  and  makes




the natural resource  available for  reuse.








     The second fortr  of commercial  reclamation  is  known as  "open

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market"  recycling,  where the  spent  solvents  are  co-mingled  with



like or  similar wastes from many  generators,  and  processed  to



specification  for  resale and reuse in the marketplace  as refined




solvent.   This option  is  available to virtually all  generators  of



spent solvents,  as long as  the recycling  facility offers the



service  (some  companies  specialize  in only  custom toll



recycling),  and there  is  a  resale market for the refined product.



One other potential limitation involves  waste  segregation  -  if a



generator is using sevetal  different solvents in  different parts



of his operation,  and  co-mingles  the waste,  there is  a  strong



likelihood  that the  refined  solvent from that waste  may  not  be




suitable for resale, leaving disposal as the only alternative.








     Though  there  are  exceptions,  most  solvent  waste streams are



suitable  for   recovery.   Since  the recycler  will be  deriving




revenue  from   the  resale of  the  product,  the  benefit  to  the



generator can  be a lower disposal  cost.   Also,  the  generator can



be assured that his waste is being managed in an environmentally



acceptable  manner, with the  corresponding benefit of natural




resource conservation.








     The charges assessed for  the  management  of  spent  solvents



through  "open market"  recycling vary  with the relative  resale




value of the refined solvent.   The g   >ral  "rule of  thumb"  in the



ir  jstry is that refined solvents  se..  ing  for less  than  $0.20 per



pound are marketed at  8C% of virgin price, and those selling for

-------
more than  $0.20  per pound are marketed at 90% of virgin  price.



Since the  costs associated with  recycling have no relationship  to




market  price,  in  order  for  a  recycler to  make  a  profit on low




priced  reclaimed solvent, disposal  charges  must be assessed.



While  the charges will  vary depending  on quantity  and



transportation,  for most  non-chlorinated solvents the  disposal



price i.9 in the range of $50-$100  per  drum.








     Host  chlorinated solvents have a  higher  resale value, and



under certain  c i r curstances,  come generators are even  paid  for



their chlorinated waste.   Fore  frequently,  though, the charges



are in  the  range  of  free disposal  to  $50 per drum.








     The three key  factors affecting  the disposal cost  (other




than chlorinated  vs.  non-chlorinated)  are quantity,




transportation, and  character  of  the  impurities.    It takes



exactly the  same amount of time  to  process  the paperwork  and



p-erfornr. the analyses for one drun  as  for forty drums, so the  more



drun.s  shipped/received have  a  lower  unit processing cost.



Transportation  costs are affected  in  a similar  manner.   Perhaps



the  single most   key factor,  though,  is  the character  of  the




impurities.   If   water  is present,  in the waste,  it   too  then



becomes a  waste  that rrust be  properly managed, at high cost.



Solid,  or  "nop-pumpahle"  impurities are not  recoverable,  and  must



be properly disposed at high  cost.   Last,  foreign objects,  such



as rags, gloves,  nuts,  bolts,  filter  cartridges, pop cans, paper

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cups,  etc.  present  in  the waste must he  separated and properly



disposed  as  waste,  usually  by  incineration.   When  waste




minimization  techniques are being considered, care should  be




taken  to avoid some of these  impurities, as they add significant



cost to  the  processing of solvent  waste.








     Technologies exist  today to assure  high  quality reusable



solvent.   The  prevailing  method of  processing is distillation  or



vaporization.   All recyclers  use  the same basic  systems and



technology,   but   they apply  those systems  in a  highly-



individual i eed  manner.








     Many solvents  can  be  processed  into  a  reusable state  by



simple  vaporization.   This  is usually done in a pot still  or



thin-filir  evaporator.








     In  the pot  still,  the  spent  solvent  is  charged  to the



systen.,  then  heated  to  boiling by  steam  or  hot  oil  heat




exchangers.   The  heat  exchangers  can be  either  internal  or



external.   Cnce boiling,  th<=  solvent vapors exit the system to a



water cooled  heat  exchanger,  then cooled  to  a  clean solvent




liquid.   The  non-ve In t i It?  residue?, or still   bottoms,  are then



punced  to  storage  awaiting  final  disposal.  rith strict land




disposal  regulations in effect,  the  usual, most cost-efficient



disposal method is  through a  /.aste derived  fuel  program.  This  is



accon.pl ished  by blending  the  still  bottoms  to  a prearranged

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specification  for  consumption  as  a  fuel  in  a  cement  or



lightweight  aggregate  kiln.    This disposal  n.ethod  has  the



advantage  of assuring  comparable destruction ratio efficiencies




to an incinerator,  tut at sign i f irc-ntly lo\ver  cost.   Mso,  there




is sufficient capacity available  in  the rr.arket for this, disposal,




while corrr.iercial  incineration  capacity  is limited.








     Sin.ilar  to  pot  stills  in  reclamation technology are thin-



filrr or  wipe-filir  evaporators.   The  difference is that while in a



pot  still, the spent solvents  are  "cooked",  the  thin-filir



evaporator functions  by pur ping  the  waste into the top of the




unit, where it is then  spread in a thin layer  on  the  internal



surface  by rotating  wiper blades.   The  internal surface is heated



by a stearr or hot oil jacket.   Ey exposing the  solvent waste to



this heat  in a thin  Icyer,  the organic   solvents  are  flash



evaporated,  once again to a heat exchanger, to be condensed as



clean solvent liquid.   in these  systems,  the  non-volatile



residues  continuously  exit the bottom of   the evaporator, to be




handled  in the sarr.e iranner  as pot  still  bottoms.   The advantage



of the thin-filrr evaporator over the pot still is that the batch




size is  not  limited by  the  size  of  the pot, since the systerr. is



fed  frorr:  an external storage  tank,  and  operated  continuously.



£lso, sorre  non-volatile  residues  are  subject  to cherrical



breakdown   when "cocked",  which  can  cause odor or color problems



in the reclaimed  solvent.  Tf  thermal  breakdown  is  not a concern,



the pot  still has  the  advantage  of  giving higher  recovery yields.

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     Toth  pot.  still  and  thiri-filrr  evaporators  are  often  operated




under  vacuum,  to reduce  the  boiling  point  of the  solvent,  thus




reducing the arrount  of  energy  required, and  also  enabling  the



recovery of  sore  high boiling solvents.








     The disadvantage  of both  there  systems  is that they have no



separation capability,  other than  volatile organics frorr.  non-




volatile  organic?.   Tn other  words, all the volatile organic



solvents entering the  systems  will exit as product.  As long as




the solvent waste has  been  kept properly  segregated, and  the




recoverable  solvent  portion is  pure,  this  is  alright.    Uut if




volatile organic  impurities are  present  in  the  waste,  they  will



be present  in  the reclaimed  solvent.  This  iray  cause quality



problems,  so  to address the  situation,  some recyclers  have



installed  fractionating  columns.








     Fractional  distillation  is an extremely complex technology,



with several  different  types  of columns,  and a vast variety of



sizes anc configurations.   The  ircst common  types  of columns are




packed  columns  (usually  with  porcelain saddles), bubble  cap




columns, sieve  plate colurr.ns, and  valve  tray columns.  The taller



the column design,  the  pore trays, enablinc  rrore   separation or




clarification capability.    As  the  diameter of  the columns



increase,  more  throughput  capacity  is  obtained.

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     Thf underlying  principle  of  operation  of  all fractionating



columns is the same.   The  volatile  organics  are heated by steam



or hot oil by means of internal or external heat exchangers.   ?s




the solvent wastes reach the boiling point, the vapors enter  the




coluirn.  The  lower boiling  components  migrate  to  the top of  the



column, with  the  colurrn design  promoting  internal condensation of



higher boiling components,  with subsequent  migration  to the lower



part of the co.lumn.  As the lower boiling  vapors exit  the top of



the column, they  are  condensed to  a  liquid.   During the  initial



start  up  operation?  of  a  batch  run,  all  the condensed liquid



(clean  solvent)   is pumped back  into  the  top of the  column as



reflux,  further   promoting internal condensation and  migration.




i;hen equilibrium   is reached  in the system,  part of  the reflux



condensste is punped to  product  storage,  with the  remainder



continuing back to the column.  The  amount  returned  to  the column



compared to the amount pumped  as  product is  known  as  the reflux



ratio .








     i:hen  separating  solvents  with a narrow spread  between their



boiling points, the  reflux ratio  may he very  high  - as  much as




5:1.   This means that for every  six gallons boiled  out of the



system,  five  gallons  go   back,  with  one  gallon  of  product



produced .








     The  reflux   system,  enables  a  high  purity cut  of the lower



toiling solvent to be reclaimed.   As  the  lowest  boiling component

-------
is removed to clean product storage,  the next  highest boiling
component will migrate to the top of  the coluir.n.   No  fractional
distillation is  100% efficient,  so there v/ill be  a  small
intermediate cut of the mixturr of  the two  components,  taken  to
separate storage.   This n.ay be fed back to subsequent batches.


     After the intermediate cut, the next component is  removed  in
the same n.anner  as the first  cut,  maintaining  adequate  reflux  to
assure separation  from even higher  boiling  solvents.   The  batch
is thus continued  until all sought  after solvent  components  are
reclaimed.  The  unrecovered residues are then handled in the same
manner as those  from pot  stills or thin-film evaporators.
                                          •«*•

     Theoretically,  any  solvent mixture  can  be  separated  by-
fractional  distillation  if  the  equipment  design is adequate.
Practice!  considerations  of  operating  economics and  equipment
investment  generally  though,  limit  efficient separation  to
solvents having  a   boiling point spread of 2C°-30°  C.   It  «hould
be noted that, even this is an  improvement  over capabilities
available  in the   recycling  industry  from  twenty  years  ago.   By
variance of solvent waste feed  points, reflux  ratios,  and  use  of
vacuum,  a  great  deal  of flexibility  is  created to process many
different solvents previously  considered  either  uneconomical  or
impractical.  Quality  refined products  are being produced that
can  be  used in  almost  all phases of  industry,  including
pharmaceutical applications  to  manufacture drugs.

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     Subsequent  processing may  involve extraction,  filtering,


r es ta bi 1 i za t ion, or drying,,  depending on the  refined solvent


specificati en  requirements.   The most common  problem  associated


with refined solvent quality  is  excessive rr>oisture,  or water.


f'oisture ccntan>ination  may create corrosion  problems,  or coating


problems with  paint solvents,  or  hydrolytic breakdown  problems


with chlorinated  solvents.  Several  techniques  are  available  to


address these  problems.




     Since water forms  an azeotropic,  or  constant  boiling


mixture,  with  many solvents,  those recyclers  with fractionating

                    «*•
capability ray  use  distillation  techniques  for moisture removal.


Depending on the  azeotropic mixture, and the quantity of water  to


be  relieved, this  method can  be  very effective, though usually


ou i te cost-] y......




     Another option available  is  physical  or  nechanical removal.


This involves filtering  the refined solvent through an absorbing


or adsorbing dessicant,  and. there  are  several methods used.




     Anhydrous calcium  chloride is  sometimes  used  for   this


method,  and can  hi;- very effective for  re i* oval of trace  water


contamination.   For refined solvents  containing  less  than  0.5%


moisture contamination,  calcium chloride can dry  them down to 200


parts  per million.    Disadvantages  are  that  when spent,  the

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calciun! chloride cannot be  regenerated, creating  a  potential



disposal  problem,  and  there is  the  possibility of  free halogen



contamination  of the  refined solvent,  causing  a potential



corrosion  problem.








     Another  method  effective  for  trace water  contamination



removal is ion  exchange  resin.  This method uses  adsorption, with



the water  nolecules  attaching to  the  resin, and the subsequent



dry solvent passing  through.   It  has  repeatedly  demonstrated  the



ability to reduce moisture levels  from 0.2%-0.3%  down to less



than 100 parts per million,  and  has  the  advantage of  being able



to regenerate.   A disadvantage, though, is that this  method  is



not effective  on refined  solvents with  more  than  0.5% moisture



contamination.








     Probably  the b^st  available  technology today  for moisture



removal  is  the molocular  sieve  bed.   It functions by actually



trapping the water  molecules  in the interstices  of  the  molecular



sieve,  allowing the  dry  solvent to pass through.  This  method  has



the advantage  of being able to  handle  gross amounts of water



contamination  (drying  from 5% down to  less than  1%), as well  as



the trace moisture contaminated  solvents (drying  from 0.5% down



to less than 200 ppm).   It also can be regenerated  for  continued



use.








     From a technical  point of view,  any  solvent  can be reclaimed

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to a point where it can be reused.  The  only  limiting  factor  is




economics,  and  with disposal costs  escalating  so  rapidly,




recycling  is becoming  the  method  of choice for a wider range  of



solvents.   In seme  cases,  the  cost  for  disposal  is  higher than



the original cost of the virgin product,  and once a  material  is



disposed,  it is gone  forever,  with  a  corresponding  loss  of



precious natural  resources.








     Let's  look at what  happens  to  your solvent  during the



recycling  process   to  assure  quality.    First,  the  waste  is



collected, in either drums or  bulk tank  truck transport, and  sent



to  the  recycling  facility.   There,  the waste  is  analyzed  to



verify  that  the  contents agree with the  waste manifest.   Then the



waste is pumped to  hulk storage.   When enough  material has  been




accumulated  for  an  economical  run, the waste is processed  through



the distillation system.  The  resulting  refined  product  is  then




analyzed  again  to determine conformance with  established



specifications.   If further steps are required, such  as drying  or



restabilization,  the product is checked  again prior  to pumping  to




final  storage.   From  there,  the refined solvent is  packaged  to



customer order in  either drums or bulk  tanker, with  yet  another



quality  control check  before shipment.   The  still  bottoms are



also thoroughly analyzed  to measure confer nance with fuel



blending specifications.








     A   typical  recycling  facility  lab  is  equipped with gas

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chromatographs,  Karl-Fischer  titrimeters,  calorimeters,  atomic




absorption  spec t r opho t oire t e r s,  as well  as other  ancillary




equipment such as pH meters,  color testers, and specific gravity




measurement.








     The gas  chromatograph  is the  key  analytical tool  for quality



control in the recycling lab.  Various instruments are  available,




but a  well-equipped  lab  will have multiple capability - a unit




with a  thermal  conductivity  detector for  macro  analysis  of



solvent components, a  flame  ionization detector  for analysis of




rnicro (or  components in the  100  ppm  to 1,000 ppir  range), and an



electron capture detector for  even greater sensitivity  (to check



for trace PCP contamination,  for  instance).   The GC's  can also be




equipped with automatic  integrators,  automatic injection,  and




controlled by computer  to  increase analytical  reproducibility and




reliability.








     The  Karl-Fischer  titritr.eter  is used  to measure water



content.   Depending on  analytical technique,   the instrument may




be sensitive  down to less  than 50  ppm.








     Color testers  and  pH  meters  are  used for obvious purposes,



since color  is occasionally  a  quality  problem  for customers, and




r.U can affect corrosion properties of the refined  solvent.








     The  calorimeter is used to measure  DTU  content of the  still

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bottons,  with  subsequent wet  chemistry testing  for  halogen




content.   Both  of these parameters are key specifications for




waste derived  fuel prograirs.








     Another  key  parameter for  still bottoms blending into waste



derived fuels  is  heavy metal content, such as  lead,  zinc, chrome,




etc.   Typically, the  recycler will  use  atomic  absorption




spectrophotometry  to measure heavy metals.








     If refined  chlorinated  solvents are intended  for  reuse in



vapor  degreasing, stabilizer  content  is an important  quality



control parameter.   t-'hile  some  individual stabilizers can be



measured by gas  chromatograph, a better  method for  checking  total




stabilizer  content  is  through wet chemistry  titration of acid



acceptance.








     If the recycler  carefully  follows  all  the quality  control



steps, industry is  assured  of  receiving a quality  product,



appropriate for  almost any use.  In my experience,  there  are very



few applications where  refined  solvents  cannot  be  used.  While



there  are  perceptions in the market that refined  solvent is not



as good a? virgin solvent,   this is  very seldom  true.  Even some



of  the obvious  differences between  the two,  such  as  purity,



color, and odor very  seldom,  actually affect the  performance of



the solvent riurinc rf;'use.

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     By dealing  with a recycler  equipped  to  service even the




srr.all Generator,  the  economic  and  environmental  advantages of



recycling  can be  realized.   The  solvent  recycling  rrarket is




relatively  mature,  and well-established,  though  in  somewhat a




s t * t e  of  change  today.   While  some companies  have been in



business  for  as  long as 50  years,  and many for  as  long as 2C




years,  there  are  very   few new  entrants to  the  field.



Dramatically increased regulatory  and permitting  requirenents



make it very difficult to  stay  in  business,  let alone  make a new




entry.   Five  years ago, market  estimates  indicated  about 150




recyclers  in business in the United States.  Today, that  number



is less than 100,  and by  1992  is  projected  to  be  less  than 50.




The  trend  in the  market is towards  consolidation,  as larger




companies,  with  greater assets  and  resources,  absorb smaller



companies unable  to comply with the regulations.








     There  will  still  be plenty of capacity available,  though, as



there  is  no recycler of  which T  a it:  aware  that  is operating at




more than about  60% utilization.  Also, most of  the decrease  from




100 recyclers to 50 will  be  via consolidation,  i.e. they  will be



acquired,  and continue  to  operate,  rather  than  cease to  exist.



Therefore,  there  should  be  plenty  of  available opportunity for



generators to take advantage of off-site  recycling within  their



economic transportation  service area,  generally considered  to be




300-4CC IT lies.

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     r«?- have  looked at  both custom  toll recycling  and  "open

irarket" recycling  -  the  criteria  for  selecting  the  proper  irethor!

varies with  individual  needs.   A more important consideration,

though,  is  selection  of  the  proper  corrpany to  service  your

requirements.   Several key  factors should be pxamined.   Since the

hazardous  waste generator forever retains ultimate  liability for

the  waste,  and  IT. any  r. ore  of  us  are  now  subject  to  the

regulations,  this  has far reaching implications, and should weigh

heavily in decidinq  where to  have solvent waste recycled.




     The  refined solvent resold   in the marketplace  is considered

o troc'uct, and is  no longer subject  to the provisions  of  FCFA.

rut  since  no. solvent   waste i?  ?CC%  recoverable,  there  are

residues  which must  still be  properly managed  to minimize risk

and potential  liability.



                        i.
     In the  cast,  nany industrial  and governmental  waste

generators selected.:, their TSp faci 1 i ty  based upon impressive oral

and written assurances  and representations of proper procedures,

and  have  been "burned",  these   aip.su ranees  being no protection

against liability.  Then, most firms  began  requiring copies of

a n r or r i ate'  c-errrits   from,  these   facilities  being  used  or

considered for use.   Alas, this   has  proved no more  effective, as

most  Tucerfund  priority sites appear  to  have beer  properly

perritt.ed  durinc  t.f"? course  of their operation.  Cnce  again, no

crotec-tion fron. lialjilitv.

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     now,  then, since you as Generators retain ultimate liability


for'the'management of your  hazardous,  waste,  can  you  minimize  the


risks of damage  to  the  environment,  or to your  company's  asset?


and  reputation?   r.y the way,  it  IP  try  considered  opinion  that.


tho^o of you who  rray he categorized  as small generators need  to


assign as  iT'Uch  or rrore attention to this decision as  does General


Motors,  IBM,   Xerox,   and other corporate  giants.   As  an


illustration, at the Per] in and Farro  site in f'ichigan,  clean  up


costs of ?14 million were pair" by  F,7  generators.   General rotors'


share was  5?.4- million,  Dow Corning'? $1.2 million,  FL Industries


5129  thousand, Ford rotor Coni;any  $217 thousand,  Grand Trunk

                                                 ••
Railroad $144 thousand,  Monserto  $100 thousand.   These  costs,


having  been  published  in the newspaper,,  are  errbarrassing  to  the


coiTipan.i es' involved,  as  well as damaging to  profitability,  but


beyonc  t>at, there  will be no discernible adverse effect.  ..Each


considers  it an  expensive  lessor  ] ea r.ned, and  business  life


continues.   How Would  your  company react to  such a  penalty?   Cr


even one of  ?5  thousand, $10  thousand,  or $50 .thousand'?  In  some


cases,  I  daresay  that' your  businesses...your  whole  life  may


suffer severe consequences.                             .





     As a beginning  to  your decision  making  process,  I- strongly


urge you to  inspect  those facilities you  are using or considering


for use, at  least once/year.  No responsibly operated TSC site of


which  T an   aware  would refuse  such a visit.   £ny  that  would,

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       ire  el irrina tt?r;  rror consideration.
        'n inspecting  the site,  five  critical,  areas  should be
addr •; rseri :
     I.    Ovvner s/Cpera tor s of the Site




          	The financial  status  and  capabilities  should  be



               exairined.   Central Motors would  not  have had  to



               pay  ? 8./? rrillion  to clean  up  Eerlin  &  Farro,  if



               Deri in & Farro had not gone bankrupt.




          	/'re  the  transporters and ether T5T facilities used



               c" y  the site in question capable,  reputable,  and



               rel iar le?



          	Doe?,  the facility  have adequate  insurance



               coveraqe?  Environmental  Tirpairnent  Liability



               insurance  is very difficult to obtain today,  and




               is  very   costly.   Without adequate•  financial




               capability,  it  is the only  protection you  have



               frorr CFFCL^ costs.








     TT.   Tite Personnel



          	Is  the* staff qual i f ied .. . exper ienced?




          	Do  training programs  exist  to  assure  continuance



               of  qualified people operating the site?



          	r-'ow are  documents  and records  managed?   Poorly

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          raintained  recceds nay  indicate a  poorly-run



          faci1ity.








ITT.  Fite  Situation



     	Ts  the  facility  located in a  residential area,



          subject  to  the  inherent risks and complaints?



     	Ts  the site  located where  potential  spills  (ray



          endanger  nearby well water?  Vvhat types of wastes




          were handler1 that  iray pose  ultimate  risk?   Your




          liabilities  do  not end/begin at the point in time



          at  which  you ccrrn:ence business.   The  liabilities




          are potentially al1-inclu?ive.








TV.   Fegulatory  Coirplianco Status



     	Are the  necessary  permits  held?  Any doubts can be



          resolved by the appropriate regulatory agencies.



          Copies of  the pern.its  should  be  examined.




     	Vihat is  the  compliance history of the  site?   A



          concent  order or other  sign  of difficulty  does not



          necessarily rule  out  consideration  as any place




          rrore  than  eight  years  old  probably has  past




          practices  to correct,  but  compliance monitoring in



          such cases  should  be examined.








V.   Operations



     	Co  health  and safety practices appear  adequate?

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              TP ec u i p mp n t jropcrly maintained?



              .Is  there  secondary,  and  preferably  tertiary



              contai nment-. of solvent storaqe  and  handling areas?



              Ts there a spill control  plan?



              ,Ts there a contingency plan?



              ,Are there adequate warning and  security  signs?



              .Are there  internal  inspection  procedures?  Are



              they documented?   All  of  these are required  of a



              properly run facility.




              .Finally,  how are  the  unrecoverable residues



              handled?  Some residues are suitable  for cheir.ical-




              based  fuels programs,  such as in cement kilns.



              But  what happens  to those  residues not  sent for



              fuel?   Those  materials  should  be  sent  to an




              approved, permitted, commercial incinerator.
     Tn edcition,  every  recycler  is  burdened  with a water



disposal  problen .   P'ost incorring  wastes have  associated water



contamination  to be  removed.   Also,  water  is  the  most corr.rronly



used medium  to  clean out  process equipment to  prevent cross-



contamination.   Ke send these  waters  to  TuPont  in New  Jersey  for



biological  and  chemical  treatnert,  with  the  resulting effluent



being  not only  non-hazardous,  but meeting drinking water




standards.   These practices  assure  that the  portion of waste



brought in  that  is not  recovered as quality product, is destroyed



so as not  to  coire  back  to haunt  us or our customers.

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     If these five critical  areas  of  concern  have  been  adequately




add r essf IA,  you rev  rest  assurer  that  you have  done  your task



properly, and selected accordingly.








     Tn closing, let ire say that w^ile  recycling  can be  shown  to



be an  economical alternative to disposal,  our  options  have  deeper



significance.  \-'e should also  view recycling  as a  viable  rceans  to



conserve  increasingly finite  resources,  and to  preserve our



environment for our children and future  generations.  \\e  consider



ourselves part of the solution, not part of the probleiv,.

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Making the Most of Bottoms and Residuals
 From Oil Refining and Solvent Recycling

              Steve Miller

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            MAKING THE MOST OF BOTTOMS AND RESIDUALS
                                Steven F.  Miller,  Ph.D.,  P.E.
                                Dames fi Moore

     Historically most oil rerefining and  solvent  recovery
processes have focused on recovery of supernatants and "tops"
or distillates and consigned the bottoms and residuals to dis-
posal.  That approach often left the most  valuable molecules in
the discarded fraction which typically went to landfill.   The
land bans which began taking effect in November 1986 were
expected to increase solvent recycling.   Instead  they appear  to
have reduced solvent recycling.  This is because solvent
recyclers who had generally discarded their bottoms to landfill
have now discovered better economies in RCRA fuel  blending
programs than in recovery of tops plus incineration of bottoms.
The exceptions would include those few companies which had
captive incineration capacity.

     Actually, hallogenated solvents continued to be recycled
but disposal of the bottoms from the hallogenated solvent
distillation via RCRA fuels programs required use of unrecovered
nonhallogenated waste solvents as dilluents to achieve maximum
chloride, solids and viscosity requirements.  Thus recovery of
the nonhallogenated solvents was drastically curtailed.

     I am going to tell you about a successful waste minimiz-
ation program by an oil and solvent recycling company which
focused on the use and reuse of its bottom streams, making
possible vitually total recycle of an increasing number of
hazardous waste streams.  The benefit of total recycle is, of
course, reduced cost and reduced liability.  The key to the
program was to persistently look for ways to recycle the parts
of the streams which would otherwise become disposal problems.
Of particular interest here are distillation bottoms and resid-
uals.  What we will be discussing is not restricted technology
and similar approaches can be taken by other facilities if they
choose.

The Ekotek Experience

     Ekotek was originally a marketer of lubricating oils which
decided to produce its own lubricating oils.  The company
started collecting, rerefining and reselling used lubricating
oils in the early 1950's.  Ekotek elected to rerefine its oil  by
the Acid-Clay process which was popular at the time because it
produced a very high quality finished product.   Automotive
lubrication requirements were relatively simple in the 1950's
and the used motor oils contained few additives, thus the acid
process was relatively easy to operate.  During the 1960's, 70's
and 80's lube oil additive requirements increased significantly
which made the acid process more difficult to operate and
increased the quantity of waste produced.

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                                2  -

     The acid process, as depicted in Slide 1, consisted of
dehydration or heating of the waste oil to -e»ove water and
a light fuel fraction and to crack the dipe sant part of the
additive packages in the oil.  Then the oil was cooled and
treated with strong acid, typically of 98% H_SO. (sulfuric
acid), which sulfated and precipitated most components which
weren't stable lube oil molecules. Fifteen to twenty percent
of the liquid was drawn off the bottom as a heavy,  tarry "acid
sludge" waste.  This obnoxious waste which was high in lead and
sulfuric acid ,  which tended to escape as SO_ vapor, was
neutralized with limestone (CaCO ) prior to  landfill
disposal.   Many plants in the U.S. simply disposed of the acid
sludge in  landfills without neutralization.  Growing
environmental pressures in reaction to these disposal practices
caused many plants to close down.

     Following this acid treatment step, the supernatent lube
oil fraction was again heated, this time in the presence of an
activated  clay to remove color bodies.  The spent clay was then
separated  by filtration and disposed of in landfills.

     The water removed from the process was treated by a
lime/alum  in a reader/clarifier,  with the treated water sent to
the POTW,  and the resulting lime/alum sludge sent to landfill.

     All three landfilled materials presented potential longterm
environmental liabilities.  Attempts were made to recycle the
acid sludge by burning it at a sulfuric acid production plant
which normally produced H_SO  by burning sulfur.  Since the
material was approximately 30% sulfate and 70% burnable organic
compounds, this appeared attractive to company which owned the
acid plant.  However, in Ekotek's case, that approach involved
shipping the acid sludge about 1000 miles in a bulk truck which
was expensive and risked occasionally having great difficulty
emptying the truck.   In addition,  the heavy metal loading from
the acid sludge was a burden on the acid plant offgas scrubbing
system.  Actually, today we would be able to overcome these
difficulties, but that is another story.

     In 1982 a distillation/clay process, depicted  in Slide 2,
was developed and modeled to eliminate the acid sludge  waste
product.  Variations  of distillation processes have become the
most common waste oil rerefining processes today.   In place of
the acid sludge waste, a viscous,  high flash  (typically 550
F) bottoms product is produced which is useful as an asphalt  oil
"cut-back" or viscosity reducing agent.  Initially  Ekotek's
bottoms product, which it called  "asphalt  flux" went to Phillips
Petroleum for cutting back road asphalt at about the price of
the road asphalt itself.  Later, Ekotek's concern over  the  legal
definition of "putting bottoms on the ground"  resulted  in
selling all Ekotek asphalt flux to  refineries  to cutback  roofing
asphalt prior to air  blowing the asphalt to achieve  final
product qualities.

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                              - 3 -

Here it was noted that the "impurities" present in the used
•otor oils such as the polymer additives used to provide
•ultigrade viscousity (e.g.  10W30,  15N40)  contributed to final
roofing product quality and that the metals from additives and
from use (e.g. zinc and lead) catalyzed the air-blowing process,
thus increasing refinery thruput.  Ekotek's arrangement with its
main new refinery customer became a profitable gallon-for-galIon
trade of one gallon of asphalt flux for one gallon of virgin
lubricating oil also produced by that same customer.

     The lime/alum waste water process was replaced by polymer
addition.  Combinations of polymer types were used.  Both that
which separated by rising ("oil") and that which settled
("sludge") were recycled to the asphalt flux tower along with
the incoming used oil.

     That left only the spent clay waste,  containing oil and
color bodies but no significant metals, going as a "nonhazardous
industrial waste" to landfill.  Ekotek considered hydrotreating
the oil as a substitute for the clay finishing step, as this
would have eliminated potential future landfill liability, and
improved both yield and product quality, but the capital cost
exceeded what Ekotek could afford.  Ekotek therefore contracted
with a plant which burned coal and shale to make light weight
aggregate for cinderblock.  The plant burned the spent clay
(which was approximately 30% lube oil and carbon) in place of
coal.  The 70% clay "ash" was incorporated in the cinderblock
product.  This proved beneficial to both parties and thus the
last potential landfill liability was resolved.

     Now, as we examined what we had achieved via waste minimi-
zation we made other observations.  Along with waste oil we had
been picking up caustic cleaning wastes from the local drum re-
conditioners and processing those wastes along with the ordinary
used oil.  This stream was rich in paint polymer stripped from
the drum outsides by the caustic cleaning process.  Our bench
tests indicated that this waste stream had only positive effects
on the asphalt flux product which was itself already rich in
polymers as well as on the ductibility of the final roofing
product.  He therefore sought out other drum conditioners as
suppliers.  These drum conditioners were delighted to have an
alternative to California landfills.  He also expanded our
search for other polymeric bearing feedstocks which could be
made compatible with the asphalt flux.

     At this point, Ekotek's RCRA history is worth mentioning.
Ekotek had originally received Part A status as a generator and
treator of acid sludge, a characteristic waste.  Because used
oil is typically potentially contaminated by a variety of listed
solvents.

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                              _ 4 -

Ekotek expanded its Part A to include receiving and processing
of such oil.  Later it further expanded the Part A to include
permission to receive listed solvents for recycle or burning for
energy recovery in its industrial process heaters.  It also
received approval for caustic and acidic wastes which it used in
the processes.  It submitted for Part B status in July 1983 and
received the first Part B in Utah in July 1987.  It also
successfully maintained environmental insurance.

     Originally Ekotek had taken measures to minimize solvents
in its feedstocks, recognizing that the contaminated distillates
would make less desirable fuels.  Later, with the oil
distillation process operating well, the company began to
examine individual solvent waste streams for their compatibility
with the new process.  Solvent wastes typically contain
concentrated dissolved and suspended components and contaminants
accumulated in the solvent during use on its way to becoming a
waste.  These components vary with the application but can
include a range of polymers, resins, dirt, oils and greases,
etc.  The following approach became apparent:

     A polymer bearing solvent waste could be added to previous-
ly conditioned asphalt flux (550  F flash point, prestripped
of all light volatile matter) as depicted in Slide 3, the
solvent stripped overhead through a distillation system and the
polymer retained in the flux.  The extreme temperatures assured
no significantly measurable solvent would remain in the bottoms
product which was then equal or superior to the original flux
product.

     Not all solvent wastes are compatible with the flux, so
bench testing of candidate stream was the key to success.   In
addition, it was hard to model the high temperature operation at
the benchat first, and so initially several streams were
rejected which we were later able to make compatible.

     Recycling waste printing inks became a major activity  at
Ekotek.  Most oil based printing inks recycled directly as  if
they were used motor oil.  The solvent based ink systems were
more difficult but the majority were compatible with  the asphalt
flux product.

     Degreasing solvents containing oil and grease  (and a
relatively small quantity of dirt) were also flux compatible.
Similarly, drycleahing perc bottoms, rich in oils,  were also
compatible.  So were certain methylene chloride stripped paints
and a surprising vaiety of other waste streams.

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                              - 5 -

     I believe that the examples given here of utilization of
bottoms indicates a general direction which needs further
exploration towards the recovery of bottoms in valued product
stream.  If you have such stream in your plant or are a
recycling facility I encourage you to persist in finding hope
for your "liabilities" in a saleable product stream.  This is
often not east but more possible than most people realize.

     Since I left Ekotek and joined Dames fi Moore's San
Francisco office we have successfully applied similar
philosophies to develop hazardous waste pit cleanup and
hazardous waste management alternatives, including cleanup of a
number of pits previously thought to be non-recyclable.  I am
extremely optimistic about future developments.

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Session IV
Treatment

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Treatment - Solvent Wastestreams
       Robert H. Salvesen

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                            ABSTRACT
Treatment of used solvents is an option often selected as a
means of waste minimization or source reduction.

While the preferred treatment is recycling for the original use,
other technologies are available which enable solvents to be
used for other purposes.

This paper discusses the general types of solvents (excluding
halogenated materials) utilized by industry and commercially
available treatment technologies.

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INTRODUCTION

Solvents are used in many industries,  mainly for cleaning and as
reaction media.   Due to their generally high initial cost and
recent mandates  to minimize waste generation and disposal,  it is
prudent to consider how to maximize their recycle and reuse.   A
separate paper on recycle and reuse has been prepared for
presentation at  this symposium.

This paper will  discuss solvent treatment technologies
(excluding recycle), which can provide reuse and disposal
options.  The major topics to be covered are:

o  Description of solvents used by various industries

       Metal Cleaning
       Paints, Coatings, Inks
       Process
       Adhesives

o  Commercially available treatment technologies

       Downgrading/Waste Exchange
       Fuel use in Boilers, Cement & Asphalt Kilns
       Stripping
       Incineration
    -  Biodegradation
       Oxidation
       Encapsulation

Examples of all the above will also be provided.

Description of Solvents used by Various  Industries

This section will cover the major  solvents used  in  industry, but
is not intended as an all-inclusive discussion.

Metal Cleaning

Hydrocarbons, halogenated, oxygenated  and mixtures  of these
solvents are used for cleaning of  metals containing carbon,
oils, grease, dirt, etc., and for  paint  stripping.   Except for
the halogenated materials, these solvents are described  briefly
below:

o  Hydrocarbons

   Mineral  spirits, naphthas, toluene  and xylene are the most
   common types.

o  Oxygenated

   Ketones  (MEK, MIBK),  esters  (ethyl  or butyl  acetate),
   alcohols  (methyl, ethyl,  isopropyl),  glycol  ethers
    (ethylene  glycol), phenols and  cresols are the major
   types used.

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       Mixtures -  Ixtures of the above materials as well as
       chlorinated  olvents are used mainly for tough cleaning
       requirements and paint stripping.  Proprietary solvents
       often contain special additives such as emulsifiers,
       lanolin, colorants and odorants.

o   Paint, Coatings and Ink

    Paint, coating and ink industries, mainly utilize
    hydrocarbons and oxygenated solvents as vehicles and
    solvents.  The latter are also widely used for cleanup
    operations.

o  Process

   A wide variety of processes utilize a broad range of
   solvents as reaction media, for finishing and cleanup
   operations.  Several examples follow:

       Chemical reactions are often carried out in the presence
       of sovents such as toluene, xylene, MEK, etc.  These
       solvents are also used to clean up equipment.  Many
       processes already include solvent recycle.

       In the manufacture of Pharmaceuticals, for example,
       drugs encapsulated in gelatin often require a finishing
       step such as washing with a high-purity hydrocarbon
       solvent.

       Decaffination of coffee includes an extraction using
       high-purity hexane or heptane.  These solvents are
       recycled.

o  Adhesives

   For the manufacture and application of adhesives, solvents
   are essential.  Hydrocarbons as well as oxygenated solvents
   are used.  Generally low boiling, volatile solvents are
   desired.

Commercially Available Treatment Technololgies

o  Downgrading/Waste Exchange

   Downgrading  is  the term applied when a contaminated
   solvent is  utilized for another purpose within a  plant.
   Waste  exchange  is the  term used when a used solvent is sold
   or exchanged for credit or another  material in another plant
   or industry.  There are a  number  of community, industry,
   environmental and government  agencies  operating waste
   exchanges.

   Both  activities involve used  solvent which  can be employed
   in another  operation with  little  or no treatment.  Several
   examples  follow.

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    -  Precision bearings  need very high-purity  solvents
       for cleaning.   The  solvent  acquires  very  little
       contaminant in usage  and can be  downgraded  or
       exchanged for  other less demanding cleaning
       operations.

    -  A special grade of  mineral  spirits is  often used
       as a calibrating fluid for  pumps,  fuel nozzles,
       meters,  etc.   This  material can  readily be
       downgraded or  exchanged for cleaning purposes.
       The military and other industries  utilize large
       volumes  of this type of calibrating  fluid.

o  Fuel Use

       Boilers  in industry,  operating on  any types of
       fuel, can be adapted to burn waste solvents,
       provided certain requirements are  satisfied.
       Generally, boiler fuels require a  minimum flash
       point of about 135  F.  Thus, only  a  few solvents
       such as  high flash mineral spirits (minimum flash
       point of 140 F) are suitable.  The only treatment
       required is to blend the used solvent with what-
       ever existing liquid fuel is employed.  If gas or
       solid fuels are normally burned, a separate fuel
       handling system and appropriate burners would be
       required.

o  Cement Kilns

   Cement kilns consume a lot of fuel and operate at
   sufficiently high temperatures  (about 2100 C/3844 F) to
   decompose most organic compounds including halogenated
   solvents.  Studies by EPA have  indicated  that wet
   .kiln operators throughout the U. S. and Canada have
   successfully burned many types  of organic wastes.   Costs
   for disposal by this method may range from $0.10-0.50/gal,
   but this is usually much less than alternate treatment or
   disposal options.

o  Asphalt Kilns  - Almost any  low-cost liquid material can be
   burned in asphalt kilns  as  fuel.  However, since the
   ingredients are not alkaline like cement,  these kilns are not
   capable of handling halogentated solvents.

o  Stripping

   For example, mixtures  of organic solvents and  oils  can
   be  treated by  stripping  off  the solvent in order  to
   recover  both  fractions  for  use  as fuels or other  purposes.
   Several  examples  follow:

       Hydraulic  systems  are  often cleaned out  with  solvents
        such as  chlorinated  or  freon solvents.   By steam

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       stripping the solvent from the oil,  the solvent can
       be reclaimed and the oil burned as a fuel.

       Used anti-freeze is stripped of water and the remain-
       ing ethylene glycol burned as a fuel.

       Soils and other solids contaminated with volatile
       solvents can often be stripped by passage of air thru
       these media.  Depending upon the concentrations of
       solvents in the air, the exhaust stream may be vented,
       incinerated, or passed through an absorbent such as
       activated carbon.  The solvent can be regenerated from
       the latter by steam stripping.

o  Incineration

   Treatment and disposal of used solvents by incineration
   is often a last resort for low flash and mixed solvents.
   Except for incineration by cement or asphalt kilns as
   noted above, this method is generally quite costly due
   to high operating and emission control costs.  The major
   types of incinerators (along with brief comments on each)
   are discussed below.

       Vortex - This is a relatively simple unit and occupies
       little area for the throughput achieved.  A high-
       velocity air jet atomizes the feed and causes a spiral-
       flame effect.  This flame insures a long residence
       time which generally assures fairly high combustion
       efficiency.  Most operating problems are due to re-
       fractory failure due to inadequate temperature control
       caused by variations in feed quality or slagging.
       Erosion through impingment of materials on the internals
       is also a major problem.  Incineration of halogenated
       materials requires efficient gas treatment.

     -  Rotary Hearth - This type of unit is a slowly rotating,
       refractory-lined chamber.  The design is similar  to  a
       Vortex incinerator except that it is horizontal and
       rotates.  The advantage over a Vortex incinerator is
       that the Rotary hearth can handle solids.  Similar
       problems with linings occur.

     -  Rotary Kiln  - This  type unit can handle a wide variety
       of liquid and solid wastes.  Many units have an after-
       burner if the outlet temperature from the main chamber
       is expected  to  fall below 800  C.  Refractory linings
       and mechanical  stresses are  the major operating problems.

       Multiple Hearth  - This  is a  vertical type unit with
       grates  through  which the wastes move from top  to  bottom
       and burn in  successive  stages.  Liquid  and  semi-solid
       wastes may  be burned.   Rotating arms or  tines  move the
       wastes  around.   In  the  upper  stages, rising  hot
       combustion  gases  dry  the  incoming materials.   Lining

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      materials and mechanical stresses are the major problems
      in operation.

      Fluidized Bed - In this type unit, wastes to be burned
      may be liquid, semi-solid or solid.  The material is
      mixed into a fluidized granular bed of special sand
      (1-3 mm diameter) which is heated to combustion
      temperatures.  This method assures good mixing of the
      wastes and hot gases to provide complete combustion.
      Compressed, preheated air is the fluidizing agent.
      The fluidizing bed may contain special absorbents,
      i.e., limestone,  to react with combustion gases such
      as HC1, S02, etc., to reduce or eliminate effluent
      treatment requirements.  Generally, cyclones are
      required to remove entrained solids from the off-
      gases.  This type of unit is very flexible, but does
      have problems with linings, slagging in the fluidizer,
      and others depending upon the design and materials
      combusted.

      Circulating Bed  - This type unit  is an alternate  to
      fluid bed combustors and reportedly operates at higher
      velocites with fine sorbents to obtain a more  compact
      unit that is easier to feed.  Such units operate  at
      high combustion  efficiencies and  produce lower
      emissions using  less sorbent materials.  Generally,
      no off-gas  scrubber is required and heat recovery can
      be achieved  to produce steam, electricity,  hot water,
      or hot  air.  This unit is very  flexible and can burn
      gaseous,  liquid,  slurry  and  solid wastes,  but  has
      problems  similar to those noted above  for  fluid bed
      combusters.

      Fume  -  These  systems are used  to  burn  off  vapors  prior
      to emission  to  the  atmosphere where  recovery  is  not
      desired.   Incineration  facilities work best on air
      streams which  contain  solvents  at 25%  of  their lower
      explosive  limit  (l.e.l.).   The  minimum acceptable
      concentration  is 15% of  l.e.l.   (For  a typical solvent
      stream  with a  1% l.e.l.,  this  amounts  to  a 1500-2500 ppm
      concentration.)   At  25%  l.e.l.,  such equipment can
      provide a high calorific credit for  the  solvent burned.
       Incinerators are not  efficient  at low concentration
      effluents  from,  for  example,  a  spray booth.  Facilities
       such as paint  or coating bake  ovens,  where solvent vapor
       concentrations  are  high,  could  profitably utilize fume
       incinerators.

o  Biodegredation

   Biodegradation of  organic  materials is  a natural  process
   that  has been practiced on a broad range of substances.
   Bacteria and microorganisms  to decompose almost anything,
   can be found in nature.   Most  organisms  are ubiquitous,  but
   for commercial use in treatment and disposal of used wastes

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   such as  solvents,  it  is  necessary  to  define  the  rates  of
   decomposition  of  the  specific wastes  and  how to  maximize
   their rate  of  degradation  in the desired  environment.
   Extensive studies on  petroleum  products have shown  both
   land-t sed  and water-borne organizms  can  biodegrade these
   materials in as little as  1-6 months.  The decomposition
   products are humic acids which  generally  are beneficial to
   most soils.

   This treatment method has  potential for the  following
   solvents:

              Aliphatic  Hydrocarbons
              Ethers
              Alec  Is
              Glyc   'Epoxides
              Este
              Benze.
              Phenol-

   It must be  noted that biodegradation is  not  a panacea
   for all types  of solvents  or other wastes.   However, the
   potential  for  this method  has  not  been fully utilized
   and needs  extensive testing to define acceptable con-
   ditions for various substances.

o  Oxidation

   Oxidation by material organisms,  air, ozone, and other
   oxidizing agents, is commonly used for treatment of
   many sustances.  In recent years,  claims have been
   made for accelerating biodegradation of organics such
   as solvents by addition of peroxides, or other oxidizing
   agents.

o  Encapsulation

   An optional means of land disposal of wastes such  as
   paint sludges containing paint thinners, is by means of
   encapsulation.  Agents  such as fly ash, silica gel,
   epoxy resins,  glass and other vitreous materials can be
   used for encapsulation.   While these treatment methods
   are mainly used for sludges, some such materials can
   contain solvents.  Caution should be used in encapsulat-
   ing these materiasls since the solvents may become mobile
   over a period  of  time.

CONCLUSIONS

Used  solvents  from most industrial operations  can  be  treated  for
recycle, reuse or disposal.   Recycle  normally  involves practices
such  as  segregation  and redistillation  to produce  solvents
meeting  new product  specifications.   Other  treatment  methods
such  as  blending  for fuels,  stripping,  incineration,
biodegradation,  oxidation  and encapsulation are viable options

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for handling almost any type of used solvent.  Commercial
experience has proven the benefits of these treatment
technologies.

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Treatment - Aqueous Wastestreams




          David Pepson

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                   TREATMENT  OF  SPENT  SOLVENT WASTEWATERS
                      - FOCUS ON CHANGING ECONOMICS -
                                David  Pepson
                                Versar,  Inc.

                              I.   INTRODUCTION
    Treatment technologies that are commonly used to treat spent solvent
wastewaters are steam stripping, carbon adsorption, and biological
treatment.  These technologies have also been determined by EPA to
represent Best Demonstrated Available Technology (BOAT) for wastewaters
containing any of the 25 spent solvents that are defined under the
hazardous waste listings of F001 through F005.   All of these technologies
are demonstrated and there exists a considerable amount of information on
the waste characteristics that affect performance and therefore need to
be evaluated regarding technology selection and use.  One area of
treatment design that has not been examined to any great extent, however,
is whether past cost optimization studies are still valid in view of
changes in treatment requirements associated with the land disposal
regulations and other regulations (LDR) under the Hazardous and Solid
Waste Amendments of 1986.
    The principal purpose of this paper is to examine some of the new
cost elements associated with each of the technologies mentioned
previously, as well as, to provide some "food for thought" in designing

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new/modifying existing treatment systems.   This presentation,  while
providing some information on the operation and applications of these
technologies, will focus on the changing economics of wastewater
treatment and associated changes in the selection and sizing of these
technologies.  Following a discussion of each of these technologies,  I
have performed an example optimization analysis which shows the impact of
the land disposal restrictions rule on treatment economics.

                            II.   STEAM  STRIPPING
Description
    Because the term steam stripping is often used interchangeably with
batch distillation, an important first step in describing the operation
and application of this technology is to define the term "steam
stripping."  Steam stripping, as used here, and described in EPA's spent
solvent final rule of November 1986, refers to a type of distillation
technology that is used to treat wastewaters that contain low
concentrations of volatile organic compounds.  It is distinguished in two
significant ways from the technology of "batch distillation" which uses
steam to "strip" volatile compounds.  First, steam stripping is used  for
low concentration wastestreams, roughly less than one percent spent
solvent content, compared to batch distillation which generally is used
for wastes containing 50 to 90 percent spent solvents.  Secondly,  the
primary purpose of steam stripping is to comply with wastewater treatment

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standards; although the organics removed can be recovered and, therefore,
somewhat offset treatment costs.  For batch distillation, the primary
purpose is economic recovery of spent solvents.
Application
    As many of you know, a stream stripping unit consists of a boiler, a
stripping section, a condenser, and a collection tank.  The number of
equilibrium stages needed (either in the form of trays or packing) in the
stripping section depend on the particular waste to be treated.
    In practice, steam stripping is used by a number of manufacturing
facilities including those that manufacture agricultural intermediates or
Pharmaceuticals, where solvents are used as carrier solvents.  Some
commercial solvent recovery facilities use steam stripping where wastes
have significant concentrations of water.  Facilities also use steam
stripping to treat residuals from solvent extraction recovery processes.
    Steam stripping can be used to treat most of the F001-F005 spent'
solvent compounds.  It should be pointed out that EPA based BOAT on steam
stripping for only 12 of the 25 spent solvents; however, the rulemaking
record makes clear that for many of the compounds treatment data were not
available for steam stripping.  Regardless, steam stripping can be used,
provided the standards are achieved.  Waste parameters that affect the
selection of steam stripping are filterable solids, oil and grease, total
organic carbon, and other hazardous constituents that are minimally
volatile.

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Selection and Optimization Considerations
    For facilities that plan to use, or are using, steam stripping as a
treatment technology, there are a number of design and operating factors
that should be re-examined in light of the LDR and other regulations
under HSWA.
    First, and foremost, facilities need to examine the size of the steam
stripper.  Prior to the land disposal rule, many facilities would size
steam strippers for 90-95 percent removal and then use carbon as a
polishing step.  Under EPA's "derived from" rules, the spent carbon is
also a hazardous waste that will now require treatment prior to land
disposal.  As a consequence of the treatment costs associated with the
spent carbon, it may now be more cost effective to increase the size of
the steam stripper and either eliminate the carbon system or
significantly reduce the pollutant loading on the carbon system so that
disposal costs are significantly reduced.
    Another aspect to consider in the design of steam strippers is the
type of trays.  Some trays provide better contact and, therefore,
increased efficiency, but may be more difficult to clean and, as a
consequence,  generate larger quantities of material to dispose.  Again,
under EPA's "derived form" rule, the cleaning waste is also hazardous.
Along this same line, facilities may also want to consider pretreatment
with polishing filters to reduce fouling and associated cleaning costs.

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    EPA has also proposed regulations which govern air emissions from
stream strippers (as part of the Hazardous and Solid Waste Amendments of
1984, Section 3004).  As a consequence, facilities still in the planning
stages should investigate various optimization scenarios for the stripper
condenser.  For example, comparing the costs of chilled water versus the
use of carbon adsorption downstream from the condenser.  Another
possibility is a larger condenser instead of add-on carbon adsorption to
remove hazardous organic compounds.  It would also be prudent to consider
how you could modify the system if regulations were to become more
stringent.  Given the fact that many areas of the country are looking to
further reduce VOC air emissions, facilities may want to build systems
that can easily be modified.  For example, you may want to pipe the
system such that a second condenser could be easily retrofitted.
    A final point regarding the use of steam stripping is that many of
the facilities that use this technology will discharge the streams to
POTWs or surface waters covered by a NPDES permit.  As you probably know,
these discharges would not be subject to land disposal restrictions, but
rather the appropriate federal, state,  and local regulations.

                          III.  CARBON ADSORPTION
Description
    Carbon adsorption can be used to treat spent solvent wastewaters by
adsorbing the organic compounds onto specially prepared carbon granules.
As many of you know, activated carbon is derived from virtually any

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carbonaceous material including wood, coal,  coke,  and petroleum
residues.  The treatment system, itself,  is  quite  simple consisting of a
packed column in which the wastewater generally enters from the top and
discharges after the distribution plate.   This plate serves to minimize
the potential for channeling in the carbon bed.
    It is important to note that carbon can  be purchased with a range of
properties depending on the particular needs.   These properties include
surface area, pore size, particle size, hardness,  and iodine numbers.
The latter characteristic refers to a bench  scale  test where the amount
of iodine adsorbed is measured and used as an  indicator of adsorption for
low molecular weight organics.
Application
    Carbon adsorption can be used for a wide range of F001-F005 spent
solvent wastewaters.  EPA determined that carbon adsorption, alone or in
combination with other technologies, represents BOAT for 8 of the 25
F001-F005 compounds.  The waste parameters that should be considered in
selecting this technology are type and concentration of organic
compounds, filterable solids content, oil and  grease, and the type and
concentration of various metals present in the waste.
Selection and Optimization Considerations
    An important consideration regarding  whether to use carbon adsorption
is the regeneration and/or disposal of the carbon.  As noted earlier, the
spent carbon is considered a hazardous waste under EPA's "derived from"

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rule and facilities would therefore need to comply with RCRA provisions
and incur associated costs for storing, transporting, and disposing of
this material.
    As a result, an important new consideration in optimizing the size of
the beds is the number of times that the spent carbon has to be
transported.  It might be advantageous to increase the size of the beds
in order to minimize the number of times that the spent carbon has to be
transported as a hazardous waste.  Of course, these costs would need to
be compared with other offsetting costs including higher pumping costs
associated with the greater pressure drop across the larger bed.
    Another factor that plays an important role in cost optimization is
the type of carbon selected.   It may be possible to use a carbon that is
more expensive initially, but can be used for longer periods of time
before regeneration.
                         IV.   BIOLOGICAL TREATMENT
Description
    Biological treatment involves the use of naturally occurring,
acclimated, or generically altered microorganisms to degrade organic
contaminants in the wastewater.  Aerobic treatment is the most common,
wherein organic constituents  are converted by microorganisms to carbon
dioxide, water, and cell protein.  In the absence of oxygen (known as
anaerobic treatment), wastes  are converted to methane and carbon monoxide.

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                       V.   COST OPTIMIZATION EXAMPLE

    Below is a cost optimization example that compares treatment costs
for two systems prior to and after implementation of the land disposal
requirements.  While this  example uses a number of simplfying
assumptions, it, nevertheless, provides a good illustration of the
potential impact that the  land disposal rules can have on treatment
costs.  The particular wastestream being evaluated is one that contains
500 mg/1 of methylene chloride and trace amounts of other constituents
including filterable solids and oil and grease.  The technologies being
compared are stream stripping (10 tray column) in combination with carbon
adsorption and steam stripping alone, but with 50 equilbrium stages.  The
cost analysis has been simplified and includes only capital costs for the
various technologies and annual costs associated with disposal of the
spent carbon.  An actual cost analysis would be much more complex,
including such annual costs as regeneration of carbon prior to the need
for disposal (remember also, that any wastewater generated as part of
regenerating the carbon is also hazardous), disposal costs for
non-reuseable material from steam stripping, and costs for air emission
controls on the steam stripper.  It is important to point out that many
of these annual costs have been considered in past optimization studies.

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Application
    Biological treatment can be used for most of the F001-F005 spent
solvents.  EPA has determined that this technology, alone or in
combination with steam stripping or biological treatment, represents best
demonstrated available technology for 9 of the 25 F001-F005 spent
solvents.  Waste parameters that affect the selection of this technology
include filterable solids, oil and grease, the presence of toxic metals,
surfactants, and the presence of refractory organic compounds.
Selection and Optimization Considerations
    Biological treatment can result in the generation of solid residuals
that would be classified as hazardous under EPA's "derived from" rule.
Accordingly, facilities that plan to use this technology need to evaluate
costs associated with storage, transport, and disposal of these hazardous
residuals.  Facilities may also want to take a closer look at
technologies that have been developed more recently, such as wet air
oxidation to replace or enhance biological treatment.  Wet air oxidation
would likely be more energy intensive than biological treatment, for
example, but the fact that less residual material is generated may result
in an overall savings.  Additionally, biological treatment of certain
compounds can result in air emissions which the Agency is currently
studying with respect to the need for regulation.  A final point with
regard to the use of biological treatment is the fact that it may be
possible to delist the treated residuals.  If this is the case, then the
economics would not significantly change.

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    In this example,  the facility needs to reduce the concentration of
methylene chloride from 500 mg/1 to 0.5 mg/1  in order to comply with
federal wastewater treatment requirements.  It is assumed that the
10 tray column can reduce the methylene chloride content by 99% to 5 ppm
and that addition of the carbon system will achieve the 0.5 mg/1
standard.  -It is also assumed a the 50 tray steam stripper can achieve a
reduction of 99.9 percent and, therefore, achieve the treatment standard
alone without the need for carbon adsorption.   Prior to the LDR, one
could assume minimal  costs for land disposal;  however, today the treater
must include treatment costs for incineration  at an approved incinerator
prior to land disposal of the spent carbon.  The analysis assumes that
the carbon is regenerated once every seven days, and after the fifth
regeneration cycle it is no longer useful and  must be disposed as a
hazardous waste.  Disposal costs are S300/drum and transportation costs
are $500 per trip.
    As shown in Table 1 below, the inclusion of treatment costs due to
the LDRs reverses the treatment selection picture.  Without these costs,
the combination system (i.e., steam stripper plus carbon adsorption) is
$76,000 less than the 50 tray steam stripper;  with these increased
treatment and disposal costs converted to capital dollars, the steam
stripper is $212,000 less expensive than the combination system based on
a present-worth analysis.

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                                  Table  1.
                         Cost Optimization Summary
                                          Case I      Case II
       Steam stripping
          (10 trays)
             +                            $224,000    $512,000
       Carbon adsorption
       Steam stripping                    $300,000    $300,000
          (50 trays)
       Case  I:  Assumes minimal cost for disposal of spent carbon
       Case II:  Includes cost for incineration of spent carbon
                 prior to land disposal

                              VI.   CONCLUSIONS
    Effective treatment of spent solvent wastewaters can be accomplished
with a variety of individual technologies or technology trains.  With the
promulgation of the land disposal restriction rules and other regulations
being developed under the Hazardous and Solid Waste Amendments of 1986,
facilities may want to re-examine the economics of the wastewater
treatment technologies either planned or now being used.
    One important aspect of these recent regulations may well be that
past practices of including "polishing"^or "back/up" systems as part of
treatment trains is no longer cost effective.  Under today's
requirements, facilities may find improved control systems to be a better
alternative.  One possibility is continuous monitoring of the wastestream
and automatic diversion to holding tanks when the waste does not comply
with regulatory requirements.

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