Hazardous waste reduction audit
workshop prceedings
-------
.
Hazardous Waste
Reduction Audit Workshop
co-sponsored by
New Jersey Department of Environmental Protection
and
United States Environmental Protection Agency
*
November 17, 1987
Proceedings
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50272-101
REPORT DOCUMENTATION » REP°RT N° 2
PAGE 101-006 A_
4. Title and Subtitle
Hazardous Waste Reduction Audit Workshop: Proceedings
| 3 Recipient's Accession No
7 Author(s)
9. Performing Organization Name and Address
New Jersey Department of Environmental Protection
Division of Hazardous Waste Management
Hazardous Waste Advisement Program
401 East State Street
Trenton, NJ
12. Sponsoring Organization Name and Address
U.S. Environmental Protection Agency
Hazardous Waste Engineering Research Laboratory
Cincinnati, Ohio
I 5 Report Date
!__ November^ 17, 1987
! 6.
8 Performing Organization Rept No
t
1 10 Proiect/Task/Work Unit No
I
; 11 Contract(C) or Granl(G) No
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' (C)
(G)
13. Type of Report & Period Covered
14
15. Supplementary Notes
This document is included in the Pollution Prevention Information Clearinghouse, operated
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Westpark Drive, McLean, Virginia 22102.
16. Abstract (Limit 200 words)
This document contans abstracts, summaries, and some transcripts of presentations by
industry and government experts at a Hazardous Reduction Audit Workshop.
17. Document Analysis a Descriptors
pollution prevention, waste reduction, workshop
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DISCLAIMER
The statements and conclusions of this report are those of the presenters
and not necessarily those of the State of New Jersey. The mention of
commercial products, their source, or their use in connection with material
reported herein is not to be construed either as actual or implied
endorsement of such products.
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HAZARDOUS WASTE REDUCTION AUDIT WORKSHOP
Presented by
New Jersey Department of Environmental Protection
Division of Hazardous Waste Management
Hazardous Waste Advisement Program
401 East State Street
Trenton, New Jersey
and
United States Environmental Protection Agency
Hazardous Waste Engineering Research Laboratory
Cincinnati, Ohio
ii
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Table of Contents
Page
1. Abstracts and Outlines iv
2. Introduction to Environmental Auditing 1
Lawrence B. Cahill
Vice President, Hart Environmental Management
3. Development and Application of a Waste Minimization 10
Audit Procedure at Industrial and DOD Installations
Mr. Harry M. Freeman
Hazardous Waste Engineering Research Laboratory
U.S. Environmental Protection Agency
Dr. Marvin Drabkin
Versar Inc.
Mr. Carl Fromm
Jacobs Engineering Group, Inc.
4. The Environmental Audit: Shield or Sword 54
Edward A. Hogan, Esq.
and
Lisa Murtha, Esq.
Porzlo, Bromberg and Newman
5. Waste Minimization: An Update 75
Harry Freeman
Research Program Manager
U.S. Environmental Protection Agency
6. Overview of the Multi-Option Model: A Computerized Waste
Reduction Information and Advisory System 78
Frank M. Brookfield
Data Management Specialist
Illinois Department of Energy and Natural Resources
7. Hazardous Waste Minimization at Olin Corporation 84
R. E. Mooshegian
Environmental Coordinator
Olin Corporation
m
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Page
8. Waste Reduction at the Campbell Soup Company 102
Ted Blrchmeier
Area Manager
Campbell Soup Company
9. A Waste Audit Workshop for the Vehicle Maintenance Industry 104
Robert H. Salvesen, Ph.D.
S&D Engineering Services, Inc.
10. Waste Minimization Program at Union Carbide 124
Ronald Burstein, P. E., CHMM
Staff Environmental Engineer
Union Carbide Corporation
11. Union Carbide's Emission Reduction Program 139
Gary M. Whipple
Assistant Director
Union Carbide Corporation
12. Minimization of Hazardous Wastewater by Process Design 148
James B. Dunson, Jr.
Principal Consultant
E. I. Dupont De Nemours & Co., Inc.
13. Waste Reduction at a Paint Plant, an OE Approach 156
R. A. Mead
Coordinator, Environmental Affairs
E. I. Du Pont de Nemours and Company
14. Waste Reduction in the Paint Application Industry 164
Herbert S. Skovronek, Ph.D.
Environmental Services
15. The R&D Sector: Optimizing Waste Minimization Practices 173
Elizabeth A. Holland
Senior Research Chemist
Lever Research, Inc.
16. Waste Reduction in the R&D Industry 181
Steven C. Rice, P.E.
BASF Corporation
17. Zero Discharge, Zero Pollution, and Source Reduction 191
Robert H. Elliott, Jr.
President
Zerpol Corporation
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Page
18. A Waste Reduction Audit Workshop for the Metal Plating 198
& Finishing Industry
Robert H. Salvesen, Ph.D.
S&D Engineering Services, Inc.
19. Hazardous Waste Reduction Audit of Pioneer Metal
Finishing, Inc. 212
Harry DeSoi
Pioneer Metal Finishing, Inc.
20. A Waste Audit/Reduction Program for the Printing Industry 217
Richard A. Goldbach
Environmental Coordinator
United States Printing Ink Corporation
21. Hybrid Membrane Systems in Waste Management 223
William F. Weber
E. I. Du Pont De Nemours & Co. (Inc.)
22. Waste Classification and Tracking - A Tool for Waste 251
Minimization
Richard A. Dennis
Manager, Environmental Affairs
American Cyanamid Company
23- Hazardous Waste Reduction Auditing 257
M. Lewis, P.E.
and
A. J. Sederis
Hoffman-La Roche, Inc.
24. Waste Reduction In Printing Ink Manufacturing 264
and Printing
Paul Volpe
Technical Coordinator
NAPIM
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n
Lever
Lever Research and Development Center
45 River Road
Edgewater New Jersey 07020
(201)943-7100
Lever tage fit $40222
THE R&O SECTOR: OPTIMIZING WASTE MINIMIZATION PRACTICES
Abstract:
Waste minimization in the research and development sector must be
implemented in accordance with the premise upon which R & 0 is built;
innovation and creativity. In a manufacturing situation, processes may
be streamlined which maximize waste reduction. R & D however, may only
optimize, or make the most effective use of waste minimization through
creative implementation of a unique and facility-specific program. A
variety of practices and procedures currently used in the R&O industry
shall be reviewed for practical application purposes.
IV
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WASTE REDUCTION IN THE R&D INDUSTRY
The R&D Industry is a significant contributor to the economic base in New
Jersey and is growing both in magnitude and in importance. Along with this
growth has come the realization that hazardous waste management for R&O
organizations presents unique challenges and problems not encountered by
manufacturing facilities, primarily due to the variability and diversity of
R&D activities and types of waste generated. This paper presents approaches
which are proving to be successful for R&D facilities and describes a
technique whereby environmental audits of new experimental units can be
conducted during the project's design phase, prior to construction and
operation. In addition, common difficulties encountered with the tracking and
reporting of R&D industry waste reduction efforts are discussed. A future
challenge which could perhaps provide the most significant long term reduction
in industrial hazardous waste generation 1s suggested.
Steven C. Rice, P.E.
Corporate Ecology
BASF Corporation
November, 1987
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THE USEPA WASTE MINIMIZATION RESEAKCH PROGRAM
Harry Freeman
Hazardous Waste Engineering Research Laboratory
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
Abstract
In an October 1986 Report to Congress on the Minimization of Hazardous
Waste, the USEPA identified several technical barriers to the adoption of
waste minimization in the country. As part of its program to encouraye waste
minimization, the Agency has initiated several research programs to provide
information to reduce the technical barriers. The program which includes
demonstration at large and small generator sites, waste minimization audits,
cooperative projects with other state and federal agencies, and long term
research is the subject of this presentation. The author outlines present
and proposed programs and discusses the overall direction of the Agency's
research program to support and encourage waste minimization.
VI
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ABSTRACT PRESENTATION
Waste Minimization Audit Case Studies at Various
Industrial Facilities
The EPA Office of Research and Development, Hazardous Waste
Engineering Research Laboratory (EPA/ORD/HWERL), Cincinnati, Ohio, has
supported an ongoing two year effort to promote the use of waste
minimization audits (WMAs) at industrial facilities, in order to
demonstrate the use of a WMA protocol developed for this purpose. The
incentive for this program derives from the EPA Report -to Congress which
emphasized the need for Hazardous Waste Minimization and underscored
EPA's role in th-s effort.
WMA effort has included the performance of six audits at four
facilities in 1986, covering four generic hazardous wastes (corrosives,
heavy metals, solvents, and cyanides). The 1987 effort includes four
audits at four facilities and covers specific K and F wastes on the
EPA/ORO/HWERL highest priority list. The current studies are directed
towards minimization of listed wastes K071, K106, K048-K052, F002, F004,
and F006.
This presentation will present a brief review of the WMA protocol and
summaries of the audits developed to date.
vii
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HAZARDOUS WASTE MINIMIZATION AUDITS
FOR THE ORGANIC CHEMICAL INDUSTRY
Sam N. Popowcer, P.E.
Senior Engineer
8CM Engineers
Trenton, NJ
and
Plymouth Meeting, PA
I. Overview of Hazardous Wastes from the Organic Chemical Industry
A. Production of Organic Chemicals
B. Hazardous Waste Production
1. Air Emissions
2. Wastewater
3. Solid Wastes
II. Hazardous Waste Audits
A. Types of Audits
B. Questions Addressed (why, how, and what to do)
C. Considerations in Developing Audits
for Organic Chemical Facilities
III. Options for Hazardous Waste Minimization
A. Source Control
1. Raw Material
2. Technology
3. Elimination of product line
B. Process Changes
C. Operational Changes
0. Good Housekeeping Practices
E. Equipment Changes
F. Product Reformulation
G. Chemical Substitution
IV. Case Studies
vi
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ZERO DISCHARGE, ZERO POLLUTION,
AND SOURCE REDUCTION
Robert H. Elliott, Jr.
President of ZERPOL CORPORATION
Hacfield. Pa. 19440
Abstract
Zero discharge is cementing over the drain and recycling all
the water to accomplish end-of-pipe pollution abatement. Zero
pollution is collecting the three separations from the system -
namely metals, organics, and salts - and making sure that these
wastes are destroyed or made non-hazardous permanently. Source
reduction or in-line recovery of metals should be carried out on-
ly if it is economically feasible. In most cases the cost of the
recovered metal must be less than the market price.
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Waste Classification and Tracking
A Tool for Waste Minimization
Presented by
Richard A. Dennis
Manager, Environmental Affairs
Chemical Group
American Cyanamid Company
Wayne, New Jersey
Abstract
American Cyanamid Company is aggressively pursuing waste minimization with
the aid of a computerized waste classification and tracking system. The
first step is a complete plant waste audit. After all wastes from each
manufacturing process have been Identified and characterized, they are
systematically classified and entered into a computerized data base.
Quantatlve waste generation and disposal data are periodically entered for
each waste. The system generates a wide variety of reports which permit us
to target specific wastes and processes for minimization efforts and to
monitor the effectiveness of completed minimization projects.
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ABSTRACT
TECHNIQUES AND APPLICATION OF ULTRA FILTRATION AND
REVERSE OSMOSIS IN WASTE MINIMIZATION
William F. Weber
Du Pont Separation Systems
E. I. du Pont De Nemours & Company, Inc.
Advances over the last 20 years have led to the economical use of
cross flow membrane technology in treatment of various liquid
processes/effluent streams.
Of special interest due to recent environmental regulations has
been the emphasis placed on the use of this innovative separation
technology towards waste reduction.
The presentation will outline the theory behind membrane
separations and then will discuss our approach to the practical
application of this technology to real world industrial waste
reduct ion applications.
An excellent article covering the fundamentals of membrane
separation processes was presented in the June 11, 1984 issue of
Chemical Engineering and is attached as a reference.
Du Pont Separation Systems, a division of the Du Pont Company,
has accessed the corporation's technical capabilities to develop and
deliver hybrid membrane systems which are based on ultra filtration or
reverse osmosis. We have been approached on a wide variety of
applications, but most of our experience is in the following areas:
1) Metal Finishing Industry
Plating Rinse Water Recovery
Cu+ CN~ - Copper cyanide
Zn2+ CU+ CN~ - Brass cyanide
Zn2+ CN~ - Zinc cyanide
Ni2+ - Watts nickel
Cr6+ - Chrome
Alkaline Degreaser Recovery
Plating Waste Treatment
Pretreatment of mixed and/or chelated plating
streams to insolubilize heavy metals for
removal by membrane filtration.
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2) Textile Industry
Concentration or Purification of dilute organic waste
streams
Finishing Oils
Dyes
Sizing Agents
3) Chemical Processing Industry
Concentration or Purification of dilute organic waste
streams
Dispersants
Emulsified oils
Polish scrubber effluent streams
Product recovery of intermediates
Product enhancement and purification
Some specifics on our involvement in several of these
applications is given in the attached reprint of a related
presentation at the Membrane Planning conference in November, 1986.
xii
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Introduction to Environmental Auditing
Presented by
Lawrence B. Cahill
Vice President
Hart Environmental Management
Cherry Hill, New Jersey
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INTRODUCTION TO ENVIRONMENTAL AUDITING*
Lawrence B. Cahill
Vice President
Roy F. Weston, Inc.
l. Environmental regulations are increasing
Environmental (health and safety) audits have become a common
technique used be regulated entities to assure management that
its facilities are operating consistent with all applicable rules
and regulations. Audits have become all the more important as
the volume of Federal and state regulations has virtually explod-
ed in the past few years. As demonstrated by Exhibit l on the
following page, Federal environmental regulations have grown by
almost 50% since 1981. This growth is complicated by a variety
of state initiatives in the areas of air toxics and community
right-to-know. Companies in Wisconsin, California, and New
Jersey, in particular, find themselves in states that rank 1,2,
and 3 respectively, out of 50 with regard to regulatory stringen-
cy.
2. Enforcement is also increasing at the same time
2.1 The U.S. Environmental Protection Agency (USEPA) has
reemphasized its enforcement role and has moved toward
a policy of taking enforcement action against corporate
officials as well as their companies. A record 342
enforcement cases were referred by USEPA to the Depart-
ment of Justice in the government's Fiscal Year 1986
(ending September 30, 1986). This represented a 25%
increase over the previous year. This Federal and
comparable state activity resulted in some interesting
actions:
In October 1986 the president of a Wisconsin
printing company was sentenced to 10 days in jail,
a $10,000 fine, and was ordered to place a newspa-
per ad warning the community not to commit envi-
ronmental crimes.
Parts of this paper are taken from a book written and edited
by the author, Environmental Audits, 5th Edition published
by Government Institutes, Inc.
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EXHIBIT 1
Growth of Federal Environmental Regulations
(Title 40 of the Code of Federal Regulations)
ISM
IMl
t4tr4
l Hw .
. IklOTMMSlHM
. tOUO
. »«JTlClO5
I '» 10 l> U U M It
Ranking State Environmental Programs
Alaska 42
Hawaii 41
Sourer FRFE
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On September 12, 1986 U.S. Federal Court imposed a
prison sentence of one year against the manager of
a food processing plant owned by a Fortune 100
company for violations of the Clean Water Act.
The company also paid $700,000 in fines, trust
funds, and surety bonds.
The owner and former officers of a bankrupt
company were sued by the State of New York on
December 12, 1986 for $5 million in damages for
alleged groundwater contamination at the plant
site.
As of November 1986, the owner of a graphics
company in New Jersey faced charges that could
bring him more than 14 years in prison for alleg-
edly dumping only 30 gallons of nitric acid on his
property.
In December 1986, two Pennsylvania chemical
company's officers were sentenced to two years in
jail (all but 30 days and six months suspended), a
$10,000 fine, two years probation, and 200 hours
of community service for RCRA violations.
3. The meaning of liability
Thus, management has much to protect and can ill-afford facing
major liabilities caused by improper environmental, health and
safety management. And these liabilities are real as is evi-
denced by Exhibit 2 on the following page. Three major companies
in the years 1983, 1984, and 1985 suffered severe shocks to their
stock prices due to environmental incidents in each of these
years. And this occurred again in 1986 when Sandoz experienced
the "Bhopal on the Rhine" spill in November of that year. In the
two weeks following that incident, Sandoz stock fell 17% on the
Zurich exchange, representing a short-term $300 million loss to
shareholders.
4. This has led to changes in the way U.S. industry conducts
its business.
The rising Federal oversight is further complicated by some
totally new and potentially onerous Federal and State initiates
(e.g., Community right-to-know), increased competition from
overseas, and a continued emphasis for U.S. industry managers to
do "more with less." As a consequence, one can only wonder if
"fail-safe" compliance management is possible; yet the increased
-------
EXHIBIT 2
U
i -
?0
\~fX. ^ on
Co- ,.-T C
ISM
iaas
TOO Mill.on
T.rm Sto0 Co-
n-%
C '.' in
' t lost*
-------
consequences of non-compliance suggest that it is virtually
mandatory. Hence, corporate managers must exercise "due dili-
gence" in meeting present and anticipated environmental require-
ments to protect both their companies and themselves.
5. Emerging Corporate Strategies
5.1 Companies of all sizes are reorganizing, establishing
or consolidating EH&S programs and designating corpo-
rate officers.
5.2 Policy and Procedure documents are surfacing, address-
ing:
Incident response reporting
Regulatory agency inspections
Environmental recordkeeping
Audit/assessment programs
5.3 Access to special environmental legal counsel and
experts is being sought.
5.4 Audit programs, in particular, are being initiated in
all types of industries, including: basic
manufacturing health care, banks, and real estate.
6. Audit Program Development
Like most anything in life, audit programs can be characterized
by both advantages and disadvantages, the latter coming princi-
pally in the form of costs to the organization. On the positive
side, audits result in a number of significant benefits, includ-
ing:
Better compliance
Fewer surprises
Fewer fines and suites
Better public image with the community and regulators
Potential cost savings
Increased information transfer
Yet, as will be discussed in more detail in other chapters in
this book, these benefits can be offset by some real and poten-
tial costs:
The commitment of resources to run the program
Temporary disruption of plant operations
Increased ammunition for regulators
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Increased liability where one is unable to respond to
audit recommendations involving significant capital
expenditures.
Notwithstanding these drawbacks, most firms when faced with
question, "Audit program, yes or no?, have opted to undertake a
program. The general theory is that in this day of increased
litigation and possible criminal suits, it is better to know your
liabilities than to remain oblivious to them. As was stated by
former U.S. EPA General Counsel: "Management ignorance is no
defense!"
7. Other Initiatives
Audit program findings and concerns over liability have changed
the way U.S. industry is doing business. Some of the more
interesting environmental trends include:
8. Clean Air
8.1 Stringent VOC-control standards have resulted in more
sophisticated end-of-pipe treatment (increased inciner-
ation) and rethinking of product lines (e.g.,
solvent-based vs. water-based coatings).
8.2 Industry is more likely to locate in attainment areas.
8.3 Companies are bartering of emissions credits as part of
emissions banking programs.
9. Clean Water Act
9.1 Mor« inside/rooved storage of hazardous materials is
being built to minimize contaminated stormwater runoff.
9.2 Elaborate locked/diking systems for outside storage are
being installed.
9.3 Because of tighter municipal standards, there is an
increased need for pretreatment systems putting compa-
nies in the wastewater treatment business.
9.4 Companies are abandoning old buildings or sealing floor
drains to minimize discharges to sanitary/storm sewers.
9.5 SPCC plans are sometimes needed for even small facili-
ties.
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10. The Resource Conservation and Recovery Act
10.1 "Joint and several" and "strict" liability has created
a dilemma; go off-site, lose control but no permitting
hassles; stay on-site, gain control but pick-up permit-
ting hassles.
10.2 At a minimum, for off-site disposal, generators audit
facilities and follow trucks; think of the business as
extending to disposal; everybody is a "deep pocket".
10.3 There is a great incentive and requirement (on waste
manifests) for material substitution and waste
minimization; are chlorinated solvents worth it? Land
disposal restrictions are having a major impact.
10.4 There is a great increase in costs of disposal making
bottom-line; the increase is from technology-forcing
regulations and off-site capacity problems.
10.5 Underground storage tanks are now being removed but
will they be replaced with above ground tanks that will
present fire and explosion problems?
10.6 Secondary containment of hazardous waste lines and
tanks are requiring ripping-up of existing process
systems.
10.7 Used oil give-away programs are no longer possible.
11. Superfund
11.1 Even the smallest companies are becoming PRP's requir-
ing increased legal assistance.
11.2 Spill reporting protocols need to be in place.
11.3 OSHA and Title III are requiring increased disclosure
to local communities on raw materials, products, and
wastes; materials balances may even be required. This
is a real sleeper; it could cause disclosure of sensi-
tive information and a general intrusion into how
industry conducts its affairs.
12. Property Transfers
12.1 States such as New Jersey and Connecticut require
certification on "clean" before any property is trans-
ferred (including changes in leases).
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12.2 Banks are becoming more concerned so lenders may
require certification as well before any property
transfers.
12.3 Current trend is "buyer beware" except that SARA
provides protection if buyer conducted "due diligence"
assessment.
13. Toxic Torts and Product Safety
13.1 Examples abound:
Johns-Manville (Asbestos)
The Chemical Industry (Agent Orange)
Hooker (Love Canal)
13.2 Some attorney's believe this to be the wave of the
future.
13.3 Compile your MSDS's for raw materials, products; know
your TSCA rules; keep informed on new health data.
14. The Lessons to be Learned
14.1 Know your materials and know your exposures; think of
your facility as extending out to your suppliers,
customers, neighbors, and waste handlers.
14.2 Understand the regulations as best you can; use your
trade associations.
14.3 Look hard at material substitution, waste minimization
and treatment vs. disposal; do an audit of your facili-
ty (ies).
14.4 And lastly, understand your personal liabilities.
Does company have clear policies on EH&S (e.g.,
reporting releases)?
Does someone have responsibility and authority for
carrying out policies?
Is communication open?
Are there procedures at plant level (e.g., dispos-
al contractors)?
Will the company defend you if you're charged with
a criminal offense or if an individual fine is
-------
levied (e.g., Ciba-Geigy at Toms River or Nabisco
in Washington)?
14.5 It's not as frightening as it seems however. The key
phrase is "due diligence". If that can be demonstrated
then, most of the time, equitable solutions to problems
can be negotiated.
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Development and Application of a Waste Minimization
Audit Procedure at Industrial and DOD Installations
Presented by
Dr. Marvin Drabkin
Versar Inc.
Springfield, Virginia
Coauthored by:
Harry M. Freeman
Hazardous Waste Engineering Research Laboratory
U. S. Environmental Protection Agency
Cincinnati, Ohio
and
Carl Fromm
Jacobs Engineering Group, Inc.
Pasadena, California
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DEVELOPMENT AND APPLICATION OF A WASTE MINIMIZATION
AUDIT PROCEDURE AT INDUSTRIAL AND 000 INSTALLATIONS
Mr. Harry M. Freeman
Hazardous Waste Engineering Research Laboratory
U.S. Environmental Protection Agency
Cincinnati, Ohio
Dr. Marvin Drabkin
Versar Inc.
Springfield, Virginia
Mr. Carl Fromm
Jacobs Engineering Group/, Inc
Pasadena, California
Abstract
The USEPA is encouraging hazardous waste generators to develop
programs to reduce the generation of hazardous waste. To encourage such
programs the Agency's Hazardous Waste Engineering Research Laboratory is
supporting the development and evaluation of a model hazardous waste
minimization audit (WMA) procedure. The procedure has been tested in a
number of industrial and 000 facilities during 1986 and 1987. In this
paper the authors describe the WMA procedure and report on the results of
four case studies selected from a total of ten such studies carried out
to date to test the auditing procedure.
For presentation at the Hazardous Waste Reduction Audit Workshop,
co-sponsored by the New Jersey Department of Environmental Protection and
the USEPA, Whippany, New Jersey, November 17, 1987.
10
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INTRODUCTION
Structured programs designed to reduce the cost and improve energy
efficiency, environmental effects, safety or other aspects of an
industrial undertaking are not a new concept. During World War II, the
General Electric Corporation developed standardized procurement
procedures for reducing product cost without sacrificing functionality.
Later, similar procedures were developed and applied to reduce the costs
of design and construction projects. This activity, known as value
management, value engineering, or value analysis, is currently well
established as a government requirement. In fact, it was mandated by the
U.S.EPA for construction projects involving wastewater treatment plants;
a subsequent study of 156 treatment plants showed that cost reduction
programs saved $95 million, for a 12 to 1 return on investment (1).
Waste Minimization (WM) is a value management activity with a primary
objective to reduce the quantity and/or toxicity of production wastes in
a manner consistent with the goals of protecting human health and
environment. Unlike environmental audit programs, a WM program does not
seek to determine or improve the regulatory compliance status of a
facility. Rather, it is primarily oriented toward producing a set of
effective measures to reduce waste generation.
Table 1 presents a breakdown of WM program elements. In the context
of an overall WM program, the waste auditing process (composed of
pre-audit, audit and post-audit, phases) follows the program initiation/
planning phase. During this initiation/planning phase, the commitment of
top management to reduce waste generation must be first established.
This is often done with a formal directive signed by the chief executive
officer of the firm or an administrator of a government organization.
The organizational commitment to start a WM program is often associated
with a goal-setting process. In this regard, DuPont has adopted an
annual 5 percent waste reduction goal (2).
A WM program can be organized in a typical pyramid structure, with
command and monitoring functions centered at the organization's top
management level and implementation responsibility totally delegated to
individual plants. An independent expert task force (reporting to top
management) can be formed to assist individual plants with setting up and
executing their own WM programs.
At the individual plant level, the WM program can follow the scheme
successfully used at Union Carbide for energy conservation efforts. At
Union Carbide plants, a plant program coordinator is appointed and
supported by a committee. The coordinator then selects and oversees
individuals in each department who are responsible for devising and/or
carrying out WM activities in their department (3).
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The program planning phase should include selection of audit team(s)
to carry out the next program phase. The audit team leader should have a
strong technical background, demonstrated problem solving ability, and,
preferably, experience associated with the relevant process(es).
Additionally, the leader should possess strong management and
communication skills and should be free of previous association with the
plant to avoid bias. Such individuals can be independent consultants or
qualified personnel from other plants.
The organization should be prepared to provide the audit team with
access to a wide range of people inside and outside of the firm. This
approach was affirmed as a result of a study conducted during a recent
internal workshop of a major U.S. corporation (4). The teams employed in
carrying out the four audits summarized in this paper were composed
entirely of employees of outside consulting/engineering firms.
The waste auditing process described in detail in the next part of
the paper, provides the key input to the implementation phase of the
program, i.e., recommendations on which WM measures are to be based.
Following completion of the implementation phase, ongoing production
monitoring is conducted in order to ascertain the waste reduction
effectiveness of the changes made.
THE WASTE MINIMIZATION AUDITING CROCEDURE
As shown in Table 1, waste minimization audits are a central part of
a WM program. The auditing process is subdivided into pre-audit, audit,
and post-audit phases. The recommended sequence of steps is shown in
Table 2. The following sections detail each of the eight sequential
steps of the recommended waste minimization audit (WMA) procedure shown
in Table 2.
Preparation for the Audit
The objective of this activity is to gain background information
about the facility to be audited. Preparation should include examination
of literature references related to the activities performed at the
facility such as EPA background documents on the industries involved,
plant permit applications and other relevant documents pertaining to
waste discharge at the industrial facilities of interest. The result of
proper preparation should be a well-defined needs list (as shown in
Table 3), inspection agenda, or a checklist detailing what is to be
accomplished, what questions or issues need to be resolved, and what
information needs to be gathered.
Host Site Pre-Audit Site Visit
The purpose of this meeting is for the audit team to become familiar
with plant operations and with plant personnel. Initial contacts with
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plant personnel should include solicitation of their views on the focus
and function of the audit. This will help to identify waste streams of
concern to the facility. The information needs defined in the previous
step would be discussed here and hopefully filled. A guided tour of the
facility should be taken.
At this initial visit, the ground work for a successful working
relationship with facility personnel must be laid. The importance of a
cooperative attitude and active involvement by host facility personnel to
the success of the audit process must be stressed. The initial point of
contact at the facility (Plant Manager, Environmental Coordinator, etc.)
must be enlisted a a "Product Champion" for the program before the audit
commences. He/she must be encouraged to relay the message of cooperation
and involvement to others at the facility.
Waste Stream Selection
The criteria used for selecting a waste stream should include at a
minimum:
- Composition
- Quantity
- Degree of hazard (toxicity, flammability, corrosivity)
- Method and cost of disposal
- Potential for minimization and recycle
- Compliance status
Waste stream selection terminates the pre-audit stage of the
procedure. At this point, it is recommended that a written description
of the facility, process, or operation and of waste streams be
developed. The description should encompass:
Facility location and size.
Description of operations or processes of concern, including
diagrams necessary to detail the pertinent aspects of waste
generation.
Waste stream(s) description centering on sources and current
methods of management; this information should be supplemented
with summaries of generation rates, compositions, disposal costs
and raw material costs. The rationale for waste selection should
also be provided.
Host Site Waste Minimization Audit Visit
With the needed understanding of the proce. ^d focus in place, the
audit inspection can now be conducted. Typica r-he inspection will
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focus on the select aspects of the operation identified through the
pre-audit activities. The governing objective is to evolve a fuller
understanding of principal and secondary causes of waste generation and
to cover the items missed in the pre-audit stage.
The audit inspection is the ultimate step in the information
gathering process. The following guidelines are suggested:
1. Have an agenda ready -- this should cover all points that still
require clarification following the pre-audit work.
2. Plan on inspections of the various process operations of interest
at different times during the production shift for continuous
processes such as acid pickling, in order to observe possible
fluctuations in normally steady state operations. Expect to
monitor operations over a period of one to two days.
3. Obtain permission to interview the operators, eight-hour shift
supervisors and foremen directly. Listen attentively, and do not
hesitate to question more than one person if the answer is not
forthcoming. Try to assess the operators' and their supervisors'
awareness of waste generation aspects of the operation. Note
their familiarity (or the lack thereof) with the impacts their
operation may have on other operations.
4. Obtain permission to photograph the facility. Photographs are
especially valuable in the absence of plan layout drawings. Many
details can be captured in photographs that otherwise could well
be forgotten or inaccurately recalled at a later date.
5. Observe the "housekeeping" aspect of the operation. Check for
signs of spills or leaks. Ask to visit the maintenance shop and
inquire about their problems in maintaining the equipment
leak-free. Assess the overall cleanliness and order of the site.
6. Assess the level of coordination of environmental activities
between various departments.
It is of benefit during the planning and conduct of the audit
inspection itself to mentally "walk the line" from what is understood to
be the source of waste generation to the point of waste exit and
disposal. The audit inspection must result in a clear understanding of
waste generation causes, treatment and disposal.
Generation of WM Options
The next step is to generate a comprehensive set of WM options. Such
activity may take a form of a "brainstorming" session involving audit
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team members or may involve separate efforts by individual members. A
combination of these approaches was found to be of value during the
audits reported on in this study. In this stage of the audit process, it
is important to generate as large a number of options as possible. The
WM measures currently in place in the audited facility should also be
listed. This knowledge often leads to formulation of additional options
and provides a valuable insight for the subsequent option evaluation steo.
Options generation should generally follow the hierarchy in which
most of the effort would focus on source reduction, with the alternative
being recycling/reuse. If no options are available in these two areas,
then treatment options would be considered. Such a hierarchy of effort
stems from the environmental desirability of source reduction over
recycling and of recycling over treatment. Current EPA-proposed
definitions of waste minimization and of key waste minimization terms are
given in Figure 1. A generalized guide map to various source reduction
elements is given in Figure 2. A generalized approach to the
recycle/reuse UM approach is shown in Figure 3. For discussion of the
terms and examples illustrating each element, the reader is referred to
the EPA support document for the 1986 Report to Congress on Waste
Minimization (5).
To generate options, it is often necessary to examine the technical
literature. Options can also be formulated through discussion with
manufacturers of equipment or suppliers of process input materials.
The result of the WM options generation step should be a list on
which each option is identified, together with a brief description of the
rationale for 1isting.
Preliminary Evaluation and Rating of Options
Each of the options postulated in the preceding step must undergo a
preliminary engineering evaluation and rating. The objective of this
evaluation is to weed out the measures that do not merit additional
consideration and to rank the remaining measures relative to their
overall desirability.
The evaluation should include, at a minimum, consideration of the
following aspects:
Waste reduction effectiveness (i.e., reduction of waste quantity
and/or toxicity)
Extent of current use in the facility
Industrial precedent
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Technical soundness
Cost (preliminary capital and operating cost evaluation)
Effect on product quality
Effect on plant operations
Implementation period
Resources availability and requirement
The preliminary evaluation of selected options would consist of the
following steps carried out by the audit team:
(a) Development of a written rationale for each proposed option
including a clear description of the operating principle,
estimates of waste minimization measured in pounds of waste and
in pounds of waste per unit production, estimates of potential
resource recovery measured in pounds of waste component
recyclable to the process or salable as a recovered material,
perceived advantages and disadvantages, simplified schematics of
the proposed material flow, material balance calculations,
"order of magnitude" cost estimates, references relating to
prior applications and other relevant documentation pertaining
to the idea.
(b) Qualitative rating of each option in three categories: waste
reduction effectiveness, extent of current use, and future
application potential. The ratings are to be done on a scale of
0 to 10 by a proponent -- then reviewed by the audit team leader.
It is expected that some options may receive ratings low enough to
warrant their withdrawal. The team leader may call a review meeting to
submit the ratings to a collective discussion or vote.
The product of this effort should be a table in which preliminary
ratings are summarized for each option addressing a particular waste
stream or source along with the written documentation developed in the
phase of the audit effort. Table 4 is a sample table illustrating the
approach used to develop such a summary table.
Presentation and Joint Review of Options with Plant Personnel
Following the technical and economic evaluation of the selected
options by the audit team, these options are prepared in the form of a
Preliminary Audit Report to be submitted to appropriate plant personnel.
Each option in the Preliminary Audit Report should be well described in
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terms of the technical rationale and projected "order of magnitude" cost
estimates. Cost estimates are of particular importance to plant
personnel who have to deal with tight operating budgets and need to have
some idea of the cost of implementing a seemingly attractive option. In
this regard, calculation of "payback period" will provide a quick
indication of the economic viability of the proposed option. Cost
estimates are also of importance to the options that belong to the
category of good operating practices. Availability of preliminary cost
data along with the presentation of this category of option circumvents
quick dismissal of these options as "trivial" by a technology-oriented
plant engineer.
The plant personnel are asked to review the Preliminary Audit Report
and independently rate each proposed option, revise them based on their
assessment, and come up with any additional options that they see as
applicable.
The review process culminates in the joint meeting where the audit
team presents the proposed options one by one. Presentation ideally
includes detailed discussion of rationale and reasons for selected
ratings. The plant engineers then present their critique or comment.
The discussion should conclude with a revised rating which would be
acceptable to both sides. If such conclusion cannot be reached, a
further course of action must be well outlined.
The objective of the meeting is to obtain an agreement on the ratings
of various proposed options -- these ratings are analyzed and used to
rank all of the options with the aim of selecting those that warrant
further evaluation by the plant. It also may happen that the plant
personnel may come up with new options or that such options may result
from the joint discussion.
As a result of the meeting, all appropriate revisions of the options
presented in the Preliminary Audit Report are made in preparation for
issuing a Final Audit Report.
Final Audit Report
The Final Audit Report should contain, at a minimum, the following
sections:
1. Facility and process description.
2. Description of waste stream(s) origin, composition, and quantities,
3. Detailed description of all waste minimization options considered
including simplified schematics of revised process flows (if
appropriate) and lists of any new process equipment required.
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4. Detailed evaluation of technical feasibility and potential
benefits of all waste minimization options considered, together
with their preliminary economics (capital and operating costs,
estimated pay back period), and final rankings (based on audit
team findings and host plant engineers' evaluations).
5. Recommendations including any research and development efforts
needed to further evaluate the recommended options.
WASTE AUDITING - SOME DO'S AND DON'TS
Some of the most important lessons learned in the initial audits
relate to the human element of the audit process, i.e., to the
interaction between the audit team and the host facility personnel.
Obviously, it is vital that host facility personnel become and remain
active participants through the audit process. Some nontechnical skills
of the audit team personnel, and particularly of the audit team leader,
were found to be extremely valuable here.
The audit team leader must be an effective and aggressive
communicator as well as a technical expert, because this individual must
serve as a facilitator for the audit team and host facility personnel
alike. A reserved and low key attitude and behavioral style by the audit
team could lead to a passive or disinterested stance by the host facility
personnel.
The pre-audit activities, particularly the pre-audit site visits,
were found to be extremely important in facilitating the audit process.
when the audit team spent a little more time getting to know the host
facility staff and the functioning of the organization (as in the
pre-audit site visit), the audit process moved more smoothly. The audit
team found it easier and faster to acquire needed data, because the
members knew the operation and the people a little better, and the level
of cooperation by plant staff was Improved.
The experience gained in these audits also led to a modification of
the audit method. The modified approach requires host facility personnel
to independently develop ratings for each of the waste reduction options
under consideration. The audit team's ratings for the options and the
host facility's independent ratings can then be reviewed and reconciled
in a group session. The initial approach of having the host facility
personnel merely review and discuss the audit team's ratings following
the presentation of the option ratings resulted in relatively casual,
uninvolved behavior by the host facility staff.
In summary, a WMA (and a WM program as a whole) requires that audit
team members exhibit effective communications and human interaction
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skills, as well as technical insight and engineering ability. A
successful WM audit program thus requires success in both technical and
human relations areas.
CASE STUDIES
The EPA/Office of Research and Development/Hazardous Waste
Environmental Research Laboratory, Cincinnati, Ohio (HWERL) has supported
ten projects to date in which the WMA procedure have been used. Table 5
identifies these projects.
In 1986 these audits focused on four generic hazardous wastes:
corrosives, heavy metals, spent solvents and cyanides. In 1987, the
audits focused on some of the listed F and K wastes in the EPA/ORD list
of top priority wastes. In this paper we have summarized the results of
four projects carried out at the following facilities:
a) Speciality steelmaking complex (corrosive waste)
b) Ceramic capacitor manufacturer (solvent waste)
c) Mercury cell chloral kali plant (K071 waste)
d) 000 installation (F002, F004 and F006 waste)
Corrosive waste
The corrosive waste stream that was the subject of this WMA was
pickling waste (RCRA #K062) generated by a stainless steel pickling
facility in an electric arc furnace (EAF) steelmaking complex in the
East. The waste stream results from a process in which annealed
stainless steel is treated in a Kojene bath at 800 F (427 C) followed by
a nitric-hydrofluoric acid pickle. The process produces a highly
alkaline Kolene rinse water and an acidic combined spent pickle liquor
and rinse water stream from the HF/HN03 pickling operation. Figure 4
presents a block flow diagram of the operation.
During the audit phase of this study, process and waste treatment
operations were intensively studied by the audit team. The use of
various potential source reduction and recycling options was reviewed
with plant personnel. The plant already recycles part of the spent acid
mixture to the pickling line, thus reducing fresh acid use. Based on the
audit team's evaluation and discussions with plant personnel, there did
not appear to be any other significant source reduction options available.
With respect to recycling options, the present neutralization
treatment of the combined pickling line wastewater stream (K062)
generates a mixed sludge for which there is essentially no potential for
reuse. The audit team determined that the raw waste, however, does
contain a constituent (fluoride ion) that could be converted into a
useful product-calcium fluoride (fluorspar). The EAF facility at this
Kolene is a mixture of molten sodium and potassium hydroxides.
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steelmaking complex presently purchases about 1,000 tons per year (907
metric tons per year) of fluorspar for use as a furnace flux material in
the steelmaking process. Current cost for metallurgical grade fluorspar
(approximately 80 percent calcium fluoride) for flux use is S100 per ton
($110 per metric ton) at the plant. The audit team proposed a waste
minimization option for recovery of calcium fluoride wherein the combined
wastewater stream at pH 2 (excluding the treated Kolene waste) is treated
with slaked lime at a controlled rate so that pH 2.5 is not exceeded.
Calcium fluoride will precipitate selectively, and at this pH, fluoride
solubility data indicate that a level of 65 ppm dissolved fluoride will
be achieved. With about 1,100 ppm dissolved fluoride in the raw
wastewater, approximately 95 percent of the fluoride will precipitate.
This is equivalent to about 1,300 tons per year (1,179 metric tons per
year) of calcium fluoride potentially recoverable (based on 330 days per
year operation), which more than equals the annual consumption of calcium
fluoride (fluorspar flux) in the EAF operation. Hydroxides of iron,
nickel, and chromium are all highly soluble at pH values below 3.0 and
thus would not be expected to co-precipitate with the calcium fluoride.
The combined spent pickle liquor and rinse water discharge would be
treated in the same waste acid neutralization system now used to generate
the neutralized non-hazardous solids discharged off-site and NPOES
effluent to the outfall. However, the neutralization would be done in
series in two stages, thereby effecting the recovery of a reasonably pure
calcium fluoride in the first stage. After the first stage of
neutralization, the presently treated Kolene waste would be combined with
the partially neutralized waste pickle liquor/rinse water stream. The
combined stream would then be neutralized and discharged to the outfall.
Figure 5 is a block flow diagram of the proposed fluorspar recovery
process.
If this option were to be put into operation, not only would the
generation rate of sludge from K062 treatment be reduced (resulting in a
saving in off-site sludge disposal costs), but a substantial potential
savings in chemical purchases could be made. A preliminary economic
analysis of this option (summarized in Table 6) confirmed these points.
Offsite disposal cost of the sludge resulting from K062 neutralization
could be reduced about 30 percent and potential overall savings resulting
from option implementation were estimated as $168,000 annually (including
$100,000 savings in purchased fluorspar, and $68,000 savings in the cost
of offsite sludge disposal). Following a review of the audit team
analysis, plant personnel agreed that this was a worthwhile option and
planned to give serious consideration to implementation of this option.
Solvent Waste
The facility chosen for the solvent waste WMA is a major manufacturer
of multilayer ceramic capacitors used primarily by the telecommunications
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and military electronic industries. Production operations are performed
in two separate buildings located within close proximity to each other.
Ceramic materials are formulated in an annex building and then
transferred to the Main Facility where the capacitors are formed.
Various finishing operations are performed at both building.
Major operations are depicted schematically in the block flow diagram
(Figure 6).
The solvent wastes are generated mainly by various equipment cleaning
operations:
ball mill cleaning and off-spec slurry disposal;
cleaning of the transfer pots;
off-spec slurry disposal, cleaning and flushing of the slurry
application system;
general cleaning;
still bottoms from the on-site TCA still.
The solvents used for cleaning include 1,1,1-trichlorethane (TCA),
RM-513 (a proprietary solvent), and isopropyl alcohol (IPA).
Each main solvent cleaning operation was scrutinized by the audit
team so as to develop a list of options that would reduce or eliminate
waste generation at the source. The focus was mainly on recycling of
spent cleaning solvent; such an approach was deemed as the most effective
short-term option. The long-term solutions (e.g., development of
non-solvent formulations) could not be meaningfully addressed in this
study.
Following discussion with facility personnel several of the recycling
options developed by the audit team were selected for further
investigation based on their high potential for waste reduction, the
options evaluated in detail were:
Ball Mill and Slurry Application Wastes: Segregate and recycle
RM-513 based off-spec slurry.
Ball Mill, Transfer Pots, and Slurry Application Wastes:
Segregate, standardize, and recycle cleaning solvents.
Slurry Application Wastes: Segregata and recycle RM-513
flushing solvent.
Slurry Application Wastes: Convert application system filters
to bag/wire mesh type.
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. General Cleaning Wastes: Segregate and recycle isopropyl
alcohol waste.
TCA Primary Recovery Wastes: Install secondary recovery
system.
Figure 7 partially depicts a proposed scheme for segregation and
recycle of cleaning solvents based on the options indicated. Table 7
summarizes the results of the economic feasibility analysis performed for
each of these options.
Many of the options discussed above rely on the use of a small batch
still for solvent recovery. Since the still operates in a batch mode,
all of these waste streams can be separately processed in the same unit.
By dividing the capital cost for one system by the savings resulting from
implementation of the four options indicated in Table 7, the overall
payback period is calculated at 0.9 years, as opposed to periods ranging
from 2.2 to 4.8 years for each option individually. By implementation of
the above-mentioned measures in this mode, the facility can reduce
solvent waste generation by 54 percent (5,810 gallons per year) at an
estimated annual savings of 530,190. In summary, the economic and
technical feasibility for on-site reclamation of cleaning solvent is
demonstrated. The plant personnel have concurred with this analysis and
are proceeding to install the type of still descriced in the audit.
Listed Waste K071
Listed waste K071 is generated by mercury cell chloralkali plants.
These plants produce chlorine, with sodium hydroxide (NaOH) and potassium
hydroxide (KOH) as co-products depending on whether sodium chloride
(NaCl) or potassium chloride (KC1) brines are used as feed to the
electrolytic cells used in the process. The two listed K wastes
generated by this industry are defined in 40CFR 261.32 as follows:
K071: Brine purification muds from the mercury cell process in
chlorine production, where separately prepurified brine is not used
K106: Wastewater treatment sludge from the mercury cell process
in chlorine production.
This case study presents the results of the WMA on K071 waste.
The mercury cell plant which acted as the host site in this case
study is located in the Southeast and has a name plate capacity of
138,000 metric tons of chlorine per year. The plant operates two
parallel production lines - one producing 310 metric tons per day of NaOH
and the other producing 246 metric tons per day of KOH. The plant
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generates approximately 5,000 tons per year of K071 waste
(mercury-bearing saturator insolubles and brine purification wastes) and
about 20 tons per year of K106 waste ( mercury-bearing wastewater treated
sludge). All of these wastes are currently sent offsite to a hazardous
waste landfill. Figures 8 and 9 are simplified schematics of the plant
and brine purification operations, respectively.
While K071 is a large-volume waste, the audit team determined that
the mercury level (typically in the 25 ppm range) was too low to permit
economic recovery and recycle of this pollutant thus ruling out
recycle/reuse as a WM option. Prepurification of the NaCl brine to
eliminate one of the main sources of this waste (the brine saturator
insolubles) proved to be an uneconomical source reduction option. A
total of seven source reduction options for this waste were considered by
the audit team. Six of these had to be ruled out because of unfavorable
economics and/or unproven technical feasibility of the process. The
seventh option (replacement of the mercury electrolytic cells with the
newer membrane cell technology - the industry's process of choice
currently) appeared to have an attractive payback period (approximately 2
years) primarily due to significantly more economical chlorine production
technology and to a much smaller extent, elimination of the K071
hazardous waste disposal problem. However, use of membrane cell
technology requires the plant to invest approximately S20 million for
installation of this option, making it unlikely to be considered
seriously at this time.
While K071 waste treatment is not considered a WM option, the audit
team determined that the plant has several technically viable treatment
options with reasonable payback periods available. One or more of these
options was the potential for detoxifying the K071 waste thus allowing it
to be delisted by EPA with the resulting non-hazardous waste being able
to be placed in a local sanitary landfill. The plant is studying these
alternatives at the present time. Figures 10 and 11 depict two treatment
options evaluated by the audit team which appear to be technically
feasible and have attractive payback periods (<3 years).
Table 8 summarizes all of the K071 waste reduction and treatment
options studied by the audit team. One source reduction option (highly
capital intensive) and two treatment options meet the criteria for
technical and economic feasibility (at the preliminary evaluation stage)
at this time. The plant is giving serious consideration to a significant
revision in the present K071 waste treatment and disposal operation (as
must all of the 14 mercury cell chloralkali plants faced with this
problem) due to the pending imposition of the EPA Best Demonstrated
Available Technology (BOAT) requirements for disposal in hazardous waste
landfills by the summer of 1988.
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Listed Wastes F002. FOQ4. and F006
A DOO installation in the South, a portion of whose facilities is
devoted to the rehabilitation of worn Army tanks was studied in a WMA for
the reduction of F002, F002, and F006 wastes. These listed F wastes are
partially defined in 40 CFK 261.32 as follows:
F002: Spent halogenated solvents including methylene chloride,
F004: Spent non-halogenated solvents including cresols and
cresylic and;
F006: Wastewater treatment sludges from electroplating
operations
Two areas of the 000 installation generate these wastes:
a) tank part paint stripping facilities using methylene chloride
solvent formulations (containing phenolic-type constituents to
enhance solvent action), generate F002 and F004 wastes.
b) cleaned tank part cadmium and chromium plating facilities
generate F006 waste.
Solvent wastes are generated in three buildings at the facility and
include:
. Approximately 20,000 gallons per year of spent solvent and about
60-55 gallon drums of paint sludge are generated in the paint
stripping operations and sent offsite for hazardous waste disposal.
Wastewater from stripped parts rinsing operations sent to the
onsite wastewater treatment plant (total amount unknown).
The audit team studied possible source reduction and recycle/reuse
options for these wastes. The focus was primarily on ways to prolong the
life of the paint stripping solvents as the most effective short-term
option. The long term waste reduction options, i.e., development of
non-solvent formulations and other paint removal techniques, could not be
meaningfully addressed in this study.
The most promising source reduction options for paint stripping
solvent waste reduction were:
Continuous centrifugation of the paint stripping solvent to
remove paint sludge as it is generated thus preventing buildup of
this sludge in the stripping tanks and significantly extending the
1ife of the solvent.
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As an alternative to continuous centrifugation of the solvent,
continuous 2-stage basket/cartridge filtration of the solvent to
prevent paint sludge buildup.
Based on successful implementation of either of these options, it was
assumed that^solvent life could be extended to one year prior to
replacement. Each of the six main paint stripping solvent tanks at
the facility would be equipped with either a solid-bowl type centrifuge
or a basket/cartridge type 2-stage filter. Table 9 summarizes the
results of the preliminary technical and economic feasibility study of
these two options. Annual waste solvent disposal cost would be cut in
half (approximately $50,000 per year savings) if either of these two
options were adopted with payback periods ranging from 0.5 to 0.7 year.
Electroplating operations at the 000 installation are conducted in
one building and include cadmium plating of miscellaneous cleaned and
remachined (where required) tank parts from cadmium/cyanide (Cd/CN)
solutions in either an automatic barrel plating line or a manual rack
plating line. Chromium (Cr) plating of appropriately prepared tank parts
is conducted in a rack plating line. Both plating operations are fairly
standardized. Simplified schematics of the three plating operations are
shown in Figures 12-14.
The facility has been experiencing significant problems in meeting
NPOES permit limitations for Cd and CN in the treaced wastewater
discharge. Thus, the audit team focused primarily on waste reduction
options which could reduce or eliminate Cd and CN levels in the raw waste
(principally rinsewaters from both Cd plating lines). Approximately
2,000 gallons per day of these wastewaters typically containing 20 mg/1
of Cd and 25 mg/1 CN are discharged from the electroplating facility.
About 35,000 gallons per day of Cr-bearing waste averaging 110 to 120
mg/1 Cr are also discharged from thii facility.
A study of the electroplating operations that generate F006 waste
(including discussions between the audit team and plant personnel), led
the audit team to develop a total of five MM options for Cd/CN
plating-related waste and two MM options for Cr plating-related waste.
These options include commercially demonstrated processing techniques
designed to minimize or eliminate Cd, Cr and CN levels in the rinsewater
wastes as well as reducing the amounts of wastewater, and are summarized
in Table 10. One proposed source reduction option: electrolytic reverse
imall scale test by trifuge vendor on a sample of spent
.jlvent heavily loads paint sludge, indicated that clear
solvent could be proai.. oy this technique.
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current destruction of CN (both simple and complexed) in the still rinse
tanks of the two Cd plating lines during the plant downtime period, is
currently being evaluated at the facility. One proposed recycle/reuse
option, recovery of Cd from these same still rinse tanks, has since been
implemented and appears to have resulted in the facility being able to
consistently meet Cd limU in their NPDES permit.
In summary, successful implementation of appropriate combinations of
these WMA options could result in the DOO installation being able to
achieve EPA delisting of the F006 wastewater treatment sludge. Payback
periods for the incremental investment involved range from 6 months to
1.9 years. Savings in the present F006 waste disposal costs could amount
to $120,000 annually if the F006 waste can be delisted.
CONCLUSIONS
The results of the four WMAs presented in this paper point to the
waste minimization audit procedure as being a useful tool for reducing
waste generation. It provides a structure that provides for in-depth
investigation while encouraging creativity. Hazardous waste generators
would be well advised to incorporate WMAs into their overall
environmental program since the results are not only good for the
environment but can contribute to substantial financial savings.
REFERENCES
1. Zimmerman and Hart. 1982. Value engineering, a practical approach
for owners, designers and contractors", Van Nostrand Reinhold Co.,
1982.
2. Government Institutes, Inc. Seminar on waste minimization. Los
Angeles, Calif., November 1986.
3. Williams. 1976. Organizing an energy conservation program. Chem.
Eno.. October 11, 1976, pp. 149-152.
4. Westinghouse Electric Corporation. Internal seminar on waste
minimization, November 1986.
5. USEPA. Waste minimization, issues and options. Volume 1,
EPA/530-SW-86-041. Washington, D.C.: U.S. Government Printing
Office, October 1986.
DISCLAIMER
The work described in this paper was funded by the U.S. Environmental
Protection Agency. The contents do not necessarily reflect the views of
the Agency and no official endorsement should be inferred.
26
-------
Table 1. Waste Minimization Program Elements
Program phase
Job plan* phase
Elements
I. Initiation/
Planning
II. Pre-Audit
III. Audit
IV. Post-Audit
V. Implementation
Information
Creative
Judgment
Development
Recommendation
Secure commitment/authority
Establish goals
Establish organization
Preparation for the audit
Pre-audit inspection
Waste stream selection
Facility inspection
Generate comprehensive
set of WM options
Options evaluation
Selection of options
for feasibility
analysis
Technical and economic
feasibility analysis
Report preparation
Selection of options for
implementation
Design, procurement,
construction
Startup
Performance monitoring
* Term adopted from value management program.
27
-------
Table 2. Recommended Waste Minimization Audit Procedure
Program phase
Activities
Product
Pre-Audit
1. Preparation for the audit
2. Pre-audit meeting and
inspection
3. Waste stream selection
needs list/
inspection agenda
notes
process description
waste descripton
with rationale for
selection
Audit
4. Audit inspection
5. Generation of a compre-
hensive set of MM options
6. Options evaluation and
selection for feasibility
analysis
notes
list of proposed
options with written
rationale
list of selected
options
options ratings by
audit team and by
plant personnel
options interim
report
Post-Audit
7. Technical and economic
feasibility analysis
8. Final report preparation
study or budget
grade estimates of
capital and
operating costs;
profitabi1ity
analysis
final report with
recommendations
28
-------
j Waste ynimiiiiion id^its jenerj
List Of information Sources
Design srocess flaw diagrams
rieat ana material oalances
- production processes
- pollution contra! s/stems
Eauioinent list
'ipmg ina instruinenc aiagrains (P1I3)
Materials application diagrams
Plat ana elevation plans
General arrangement drawings
Piping layout drawings
Operation manuals, orocess descriptions
Permits and/or permit applications
Emission inventories
Hazardous waste manifests
Annual (or oiennial) reports
Waste assays
Operator data logs, oaten sheets
Materials purcnase orders
Environmental audit/rev tew reports
Production Schedules
Organization cnart
29
-------
Idble 4 SUMMARY OF SOURCE CON1ROL HUHODOlOuY FOR I HE A/6 POWDER fORHULAHON
PROCESS IUUS1RATION OF DEVElOFMENI OF OP1IONS RANKING
CO
O
Udbie
reclucl ion
Ujsif sonice
Ut lylimy opeial ion 1
2
3
UL I iji mil Uicidmcj 1
oinl uii loading 2
3
4
b
6
7
8
9
Oi y yi mil lodiliny 1
mid un loading 2
3
4
b
Control methodology effectiveness
Return empty containers
Use preweighed contdiners
Use drum covers
Oveid II
Use p lablic funnel/collar on unit
Use SUM 1 lei tiay&. manual operation
Mace days on rack. Mdlk-in oven
Use elevator table on rack, walk- in oven
Install loller conveyer under valve
Instdll fail-close valve on discharge
Pump slurry into trays ovei at oven
Reduce cleaning frequency
bypass dry grinding unit
Ovei a II
Use plastic funnel/collar on unit
Do not load while unit is operating
Inspect all seals regularly
Use di um covers
bypass dry grinding unit
Ovei nil
2
2
2
2 00
2
2
2
1
1
2
2
3
2
1 U9
2
3
2
i
4
i. CO
Extent of
current use
0
0
't
0 67
0
0
0
0
0
0
0
0
0
0 00
0
4
3
2
0
1 UO
Future
application > faction of
potent tal tola 1 waste
2
4
1
2 33 0 10
4
2
2
1
1
3
1
3
4
2 33 0 4b
4
0
2
3
4
2 60 U 4'j
GUI rent
reduct ion
index
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
00
00
2S
25
00
00
00
00
00
00
00
00
00
UO
00
/b
Jb
2b
00
/'j
f utuie
leduci tun
irido
0 2b
0 L.O
0 01,
0 bO
0 bO
0 25
0 2b
0 OL
0 06
0 38
0 13
0 bt.
0 bO
0 bb
0 bO
0 OU
0 Ob
0 19
0 UO
0 HO
A I I
A I I mrliioil:.
I 00
0 l\
-------
EaA/GRO «MA 3rojects Carr-ea Out to Date
J.MA Project
NO Phase Waste it ream Audited Host Site Oescnonon
le of Aucit
2 I
Heavy :ite:als
Corrosives
Eiectnc arc furnjce (EAF)
manufacturing of specialty
steels
EAF sta'nless steels
ooerat ion
Waste Minimization Audu Reoor:
Waste Minimization Auaits it Sen
of Corrosive and .-leavy Metal '«as:es
7 II
II
3 II
Solvents
Solvents
Cyanide
Cyanide
K071
(Brine purification
waste)
KL06
(Wastewater treatment
sludge)
<071
(Brine purification
water)
K106
(Vastewater treatment
sludge)
Naval aircraf; service
complex
Ceramic caoacitor
manufacturer
Naval aircraft service
comolex
Job plating snop
Mercury cell cnloralkali plant
(Plant No 1)
Mercury cell chloralkali plant
(Plant No I)
Mercury cell chloralkali plant
(Plant No 2)
Mercury cell chloralkali plant
(Plant No 2)
Waste Minimization Audit 3eoor*.
Case Studies of Minimization of Eoi/ent
Waste from Parts Cleaning and from
Electronic Capacitor Manufacturing
Operations
Waste Minimization Audit Report
Case Studies of Minimization of Cyan ice
Waste from Electroplating Operations
Waste Minimization Audit Report
Case .;udy of Minimization of <071 and
K106 .astes at Two Mercury Ceil
Chlo-ilkali Plants
Waste Minimization Audit 3eoor:
Case Study of Minimization of <071 and
KL06 wastes at T«o Mercury Cell
Chloralkali Plants
iO i!
F006
(cyanide plating
bath waste)
F002. -004
(solvent wastes)
(Petroleum refiner/
«astes)
Army tank rehabilitation
raci 1 ity
Army tank renaoi1itation
TiC'lit/
'etraleun refinery
Waste Minimization Auait Resort
Case Study of Minimization or rQ06 C/dn'Lie
Plating Satn Waste ana F002, .:00-i Solvent
Wastes at an Army Tank Renaoi1itat'on
Faci 1 ity
Waste Minimization Audit Reoor:
Case ituoy sf Minimization ar jn Oil
Refinery juifur Recovery Plant '«asts
ill reports are current I/ >n puo 1 cation
31
-------
"ao'e 6 Summary ar 3re i immar/ Ecmcmic reas.oiiit,
Study of Recycling Option fir Corrosive Waste
::em
Cast
Total capital cost far additional processing
facilities ana existing alant modifications
$300.000
Annual operating cost
J46.000//r
Savings due to reolacement of
purcnase fluorspar
J100.QOO//r
Savings due to lower cost of
off site >iaste disposal
Total potential savings
$163.000/yr
Estimated aayoack period
2 S years
Estimated internal rate of return
(based on an economic life of 5 years)
24 percent
32
-------
Solvent Waste WM Audit
TABLE 7 - ECONOMICS OF PROPOSED MM OPTIONS
Wasle Reduction Net Annual Capital Pay-back
Waste Source Minimisation Option Gallon/Year Percent Savings Costs Yeara
Ball Mills and Transfer (*) Segregate and Recycle RM-513 Wastes. 720 28.8 $6.040 $25.750 4.3
Pols Standardize Solvent Used and Recycle 2.150 86.0 $19.130 $25,750 1.3
Slurry Application Systems (*) Segregate and Recycle Cleaning Wasle. 725 96.7 $5.400 $25.750 4.8
Use Bag Type Flllera. --- 90.0 $1.260 $23.950 19.0
Use Metal Mesh Type Fillers. -- 100.0 $6.660 $9.830 1.5
General Cleaning With {') Segregate and Recycle Cleaning Wasle. 2.350 50.0 $11.650 $25.750 2.2
Isopropyl Alcohol
TCA Primary Recovery O Install a Secondary Recovery System. 2.015 73.3 $7.100 $25,750 3.6
All Solvent Wasle Sourcea Use a Common Batch Still lor (') Melhoda. 5,810 54.3 $30,190 $25,750 0.9
Shown Above
-------
I able tt Sunindry of Postulated Options for Minimization of Listed Waste t.O/l
Opt ion
Descriplion
lype of
opt ion
Advantages
Disadvantages
Potent id I
sov ing:>
(J/yi)
Reduction of depleted
brine dissolved sulfdle
level to minimise
sdlurdtor insoluble?
(jenei dl ion
Source Reduce general ion rate of saturator
reduction insoluble; portion of K07I waste by as
much as one-third Save significant
laboi cost currently involved in
periodic c leanout of saturators
Depleted bi me side stieam treatment
needed to reduce dissolved sullale
lesults in excessive precipitant cost
as well as large additional general ion
ot mercui y-conldininated wastes
llju ot prepui if led salt Source
Iced block reduct ion
Essentially complete elimination of
mercury-contaminated K071 wdSte
generation in NdOh production
Unacceptdble economics
C Use of solar salt as a
feed slock
Source
reduct ion
Significant reduction of niercui y-
conlammated k071 generation in NdOh
product ion
Unacceptdb le economics
D(l)(a] Removal of mercury lion
depleted brine prior to
bi me resaturai ion.
using suit ide
piec ipilat ion with
disposal of mercury
sulf ide waste
Source Lssenl lal ly complete elimination of
reduction mercury-contaminated K07I waste
geneialion in HMn j.iuduction
Commercially unpioved process.
creation of another KO/I waste.
unacceptable economics
-------
lable t) (Cont mued)
OpI ion
Descriplion
lype of
opt ion
Advantages
Disadvantages
Putenl til
sav my^>
0(l)(b) Reinovn) of mercury from
depleted brine prior to
brine resaturation using
sulfide precipitation.
to I lowed by mercury
icloiting dud recovery
t luu meiLunc suit ide
waste
Source Same as in D(l)(a)
reduction
Conine re id lly unproven process.
unacceptable economics
CO
en
of mercury from
...ltd br me pi lor to
brine resaluralion
using ion exchange resin
Source
reduct ton
Same as D(l)(a)
No coiiinercitf lly aval Idble resin
available for handling harsh depleted
brine environment Milhout extensive
pretreatment tor chlorine lemoval.
limited resin capacity and allowable
brine flow rate require very large
resin beds (unacceptable economics)
Conversion of mertuiy
electiolyt ic cells lo
membiane eleitiolyl ic
cells
Source Complete c I unin^i um of all
reduction nieicury-beanng streams results in
elimination of K07I and KlOb wastes.
preliminary economics indicate
acceptable payback period (-2 years)
Membrane technology commercially
proven
Detailed feasibility study using
definitive bdse cost:> may shuw much
worse payback than preliminary
estimate Space requirements tor
auxiliary equipment may be unavailable
COO.QUO
-------
lable 8 (Continued)
Option Description
Type of
opt ion Advantages
Potent lal
savings
Disadvantages (i/yr)
(I) Use o( a washing
piocess to reduce the
level of mercuiy in the
kO/l saturated
insoluble;, below 12 ppb.
enabling this waste to
be dulisted
Treatment Simple, commercially-proven process
that would allow delist ing of a large
port ion of K071 waste Favorable
payback period (-2 years) Space
availability at plant is not a problem
Potential delay in achieving EPA
de)isting because of lengthy piocedure
involved
380.000
CO
a\
(I) baine as (I) for
salurator insolubles
coupled with NoSN
tieatment process for
bi me pur if icat ion
muds, enabling
Ue list ing of the entire
k07l waste itiearn
Treatment Same as in (1) for saturator
insolubles. addition of process for
brine muds still shows favorable
payback period (2 3 years) Space
availability at the plant for a
combined treatment process is not a
problem
Sulfide treatment step foi brine
pur if (Cat ion muds IS cuiinerc la lly
unproven Lack of proven treatmenI
process could delay up IPA delist ing ol
the entire itiearn until adequate body
of process data is available
J2b 000
(J) banie di (I) tor
idturator insoluble:.
coupled with Vulcan
I redIment Process for
brine purification
muds, enabling
de listing of the entire
kO/l waste stream
Treatment Same as (I) lu> --.ji.ndtor insolubles
Vulcan process is coinnerctally proven
and is expected to be BOAT for K07I
waste Space availability at plant
for combined treatment process is no
problem
Economics of Vulcan process toi
combined HaCI and KCI brine stream
purification muds appears unfavoiable
at this tune Vulcan process may also
generate highei IDS in effluent from
Plant No I than State will allow
-------
lable 9 laliu Idled Projected Costs and Required Site Modifications UM Options for DOD Installation (00? anil F004 Wastes
UM
Opt ion Waste source
Proposed equipment
Option descript ion modifications
1st i ma ted
installed
cost (S)
Lsl imated annual
direct oueiat ing
cost2 U/yr)
Required site
modif ical ions
Payback
pei lod
(years)
(1) Udste paint stripping
solvent disposal
Continuous removal of
paint sludge from
solvent (using a solid
bowl centrifuge Solvent
replaced annually
Add a pump and so I id bow I
centrifuge to each of the
six paint stripping solvent
tanks, unit operates at
about S gpm flow rate
bO.OOO b.OOO Adequate floor space is
aval laLle in front of
each of these stripping
tanks to peimit installa-
tion without inajoi exist-
ing equipment ie location
Waste paint stlipping
solvent disposal
Continuous removal of
paint sludge from
solvent (using a two-
stage filtration unit)
Solvent replaced
annud lly
Add a pump and two-stage
filtration unit to each of the
six paint stripping solvent
tanks (first stage is basket
type filter for large pieces
and second stage is a porous
metal filtration cartridge for
micron-size particles
60.000 9.000 Adequate floor spdi.e is
dvdi Idble in front ot
each of these stripping
tanks to permit installa-
tion without major exist-
ing equipment relocation
0 b/
I
All out ions shown are source reduction options
Ottiei than Hie cost of replacing spent paint stripping solvent, which is estimated separately
-------
Idble 10 tabulated Projected lasts UH Options foi OOD Installation fOOt Uiisle:.'
WM
option Waste source
Opt ion
type
Proposed equipment
Option description modifications
fit undted
insldl led
cost (J)1
[si imdted annua 1
opei at my cost
U/yr)
(d/LN Barrel Plot ing Source
I me reduct ion
Use of elect roc lean rinse
waters as feed to pickling
rinse water tank
Water piping and pump
J 1.000
t too
(a)(2) td/LN Hdiuidl Plating Source
I me reduct ion
Use of elect roc lean rinse
waters as feed to pickling
rinse watei tank
Water piping and pump
I. QUO
'.,00
(l.)(D ( il/ln boiic-1 Plot my Source
1 me reduct ion
CO
CO
(!>)(?) Lil/Cn Hanudl Plating Souice
I me reduct ion
((.)(!) (d/ln Manual Plat mg Souice
I me i educl ion
(L)(?) Uu omiuin Manud I buurce
P Idling Line reduction
Destruction of cyanides in
st i II rinse tank
Destruction of cyanides in
st i II rinse tank
Improved dragout iei.(ivui y.
drain booid. spray/Iuy
rinsing noizles ovei
plating tank
Improved dragout recovery.
dram boaid. spray/fog
rinsing
Insertion of bb Cdthodes and 2.000
anodes in still rinse tank
and operat ion in a CN
destruction mode during
p lat ing 1 me downt ime
Insertion of SS Cdthodes and 2.000
anodes in still rinse tdiik
and operdtion in a CN
.destruction mode during
plating line downtime
Add drain board between Cd l.SOO
plating tank, diid still rinse
tank, install spiay/loy rinse
Add dram board between Cr l.bOO
plating tank and still rinse
tank, install spray/fog rinse
nozzles over plating tank
10.000
10,000
1.000
1.000
-------
Table 10 (Continued/
UH Opt ion
up I tun Waste source type
(d) Both Cd/CN Plat ing Recycle/
L ines reuse
Option description
Evaporation of Cd/CN rinse
water discharge and recycle
to both plating lines in
appropriate quantities to
maintain individual plating
bath water balances
fstimated 1-.I nnaleil oimua 1
Proposed equipment installed opeiul my cost
modifications cost (1) (i/yr)
Install evaporation unit and 79.000 2/.000
auxiliaries in Building 114
basement near Cd/CN waste
sump
(«.)(!) (.tl/tn bdi rel Pldt my
I me
Recycle/reuse Plating out of cddmium in
still rinse tank
Insertion of SS cathodes and Use the same
anodes in still rinse lank equipment
to operate in a Cd plating as in (li)
mode during plating line
downt line
20.000
(fc)(?) Ltl/Cn Mdiiudl
Pldl ing I me
Recycle/reuse
Plating out of cadmium in
stil I rinse tank
Insertion of SS cathodes and Use the same
anodes in still rinse lank equipment
to operate in a Cd plat ing as in (l>)
mode during plating line
downt inie
20.000
(I) Lliroinium Hdnudl Souice
Pldtinij line reduction
(y) ( liromium Honua I Source
.ng 1 me reduct ion
Improved dragout recovery
replacement ot running
rinse tank with spiay chamber
Reduction of chromium metal
losses from hood vents over
plat ing tanks
Install suitable banks of 5.000
spray nozzles in empty
running rinse lank
Add Idyer of plastic balls Nil
on surface of chromium
plat ing tanks
2.000
Nil
1 Oitlei ol mayniluile costs (± bO percent accuracy)
-------
WASTE MINIMIZATION
SOURCE REDUCTION
RECVCLINO
RELATIVE ENVIRONMENTAL DESIRABILITY
GREATER
to*
LESSER
ORDER OF EXPLORATION
FIRST
SECOND
FIGURE 1. COMPONENTS OF WASTE MINIMIZATION, THEIR HIERARCHY AND DEFINITIONS
-------
PHOUUCi SUUSIIHillOtl
EXAMPIE.
CONCHE1E MARINE PI INGS
HlSIEADOf
SOURCE CONTROL
MOIE. CAI4UE EXIEIUIAL 1O
CENEHA10I1
IPUIMA1EMAL CHANGES
&IIUUIIIIIIIQN
ONIIIITJM
lECtimi OGV.CIUMGES
PROCESS TJIANOES
EfMIIPMENf .PH'VIQ Oil I AYOUf
T4IMKIES
CHANGES lOOPEIUlinNAI.
SfclHNOS
AIMHIIDNAI AllinMAflDN
PHOCCOUHAUNSII1U11QNAL QIANGEh
PBOCEOtMUl MEASURES
lOSSPIUEVtMIION
PERSONNEI I'HACIICES
SEGIttUAIKU*
MAIEIUAI
Flyure '£. Llcmcnts uf source reduction
-------
RECYCLING/REUSE
ONSITE RECYCLING
OFFSITE RECYCLING
RETROGRADE USES
DIRECT REUSE
TECHNIQUES
USE OF WASTES AS FUEL
FEED FOR OTHER PROCESSES
LOWER PURITY FEEDSTOCKS
USE AS CONSTRUCTION
MATERIAL ADDITIVES
VAPOR-LIQUID SEPARATION
DISTILLATION (FRACTIONIZATION)
EVAPORATION
GAS ABSORPTION
SOLID-LIQUID SEPARATION
FILTRATION
CLARIFICATION
CRYSTALLIZATION
CENTRIFUGATION
SOLUTE RECOVERY
PRECIPITATION
MEMBRANE SEPARATION
ION EXCHANGE
FIGURE 3. ELEMENTS OF RECYCLE/REUSE
-------
WATER
1
N»OH
KOH WATER WATER
f | STAINLESS f
STAINLESS KOLENE
STEEL STRIP TREATMENT
to KOLENE STRIP RINSE
"* QUENCH ~"
1 RINSE WATER
V
COLLECTION TANK 1 ' SPENT ACIDS
1 PARTIALLY
RECYCLED T<
KOLENE WASTE PICKLING
, , OPERATIONS
FERROUS
SULFATE
NITRI
FUMES CHUCK WATER
fiCHIIBHFR ^ HCCYCLED
SCRUBBER Tfl p|CKUNQ
C ACID
HYDROFLUORIC ....,.:
ACID WATER
STEEL STHIP_
*"
1 1
T,
,?
SPENT PICKLE LIQUOR
PERIODICALLY DISCHARGED
TO COLLECTION TANK
" VI
RINSE WATER
i
CHROMIUM HEXAVALENT | CO"'C«°« '*»«< | | COLLECTION TANK |
\
TO WASTEWATER
TREATMENT
TREATMENT
TREATMENT
FIGURE 4. SIMPLIFIED SCHEMATIC OF EXISTING STAINLESS STEEL SURFACE
TREATMENT AND PICKLING PROCESSES
-------
COMBINED
SPENT PICKLE
LIQUOR AND
RINSE WATER
SLAKED
LIUE
COAGULANT
WATER
WASH
i
PARTIAL
NEUTRALIZATION
TO ptl 2.S
I
SLURRY
I
[UNDERFLOW!
^CLARIFICATION
FILTRATION
FILTRATE
SLAKED
LIUE
L_I
I
1.300 TPV
OVERFLOW (COAGULANT
NEUTRALIZATION
TO pH a
RECYCLED FILTRATE
1
SLURRY I 1 UNDERFLOW I"
-H CLARIFICATION | W FILTRATION
TREATED
KOLENE WASTE
OVERFLOW
TO
OUTFALL
RECOVERED CALCIUM
FLUORIDE
SOLIDS (FLUORSPAR)
TO MELT
SHOP FLUX USE
NONHAZARDOUS
SOLIDS TO
OFFSITE
DISPOSAL
LEGEND
EXISTING
EQUIPMENT
mi
EQUIPMENT
Figure 5. Proposed Alternative Treatment System For Recovery Of Calcium Fluoride From
Combined Spent Acid Pickle Liquor And Rinsewater
-------
Dielectric Powder Preparation
Drying
Sovenl/Binder Solution Preparaiion
Weighing I
IPolymeQ p*~-~»^r
Weighing l_ ^l
1 Solvents) |
High Shear
Dissolution
Ink Preparation
B...
I Mllllnlng I
TrantUr
Dielectric Slurry
Preparation
Note: Shaded areas Indicate aolvenl-use/wasla Intensive operations
Capacitor Finishing Operations
Soldering
H »-- H
a.
H * H
"CAPS" Operations
(Layering)
Slu»y
Application
Ambient
Diylng
Conductive
Ink Appl.
Drying
o
DC
Drying
Encapsulation
H pf""ii>">a I"
Solvent
lleheup
Carrier
Cleaning
|
«
t_
*
8
-+\ FINAL PRODUCT]
FIGURE 6
SIMPLIFIED SCHEMATIC OF CERAIWifiC CAPACITOR MANUFACTURING PROCESS.
-------
Recycled RM-513
Virgin RM 513
Ball Mill
OH Spec
Daich
i
r
- fc
Ball Mill
Primary
Rinse
I
k^
Tranbler Pol
X,
^
Transfer Pol
....
BalMil
Secondary
Rinse
I
...A,
Transfer Pol
Wiping
RMS 13 Rinse
TC A Rinse
RESIDUAL
, SLURRY
I
(SECONDARY CLEANING)
Feed Pol
Emptying & Wiping
i
..-*
*
Feed Pol
RMS 13 Rinse
OFF SPEC
r SLURRY ,
r
t
fe
k
t
/
k
f^>
^.
55
n
u
"*k
Drum
NEW
STILL
STILL
BOTTOMS
Vermiculile
If
55 gal.
Drum
Slurry Applicator
1st Flush &
Filler l)ii(.kiwash
Slurry Applicator
2nd Flush &
Filler HacXwash
55 gal.
Drum
OFFSITE
LANDFILL
Figure 7. Proposed RM 5t3 Cleaning Solvent Recycle System.
-------
NaCI(ROCK SALT)
VENT
DEPLETED NaCI BRINE
SALES
H2
COMPRESSION
H2
BRINE AREA
RESATURATED
NaCI
BRINE
CELLROOM
ci2
CHLORINE Cla
GAS
SALES
NaOH
50%
BOILERS
T
ELECTRICITY
STORAGE
50% NaOH SOLUTION
SALES
FIGURE 8. NaOH/CHLORINE PRODUCTION PROCESS
-------
NaCL
00
NaCL
SATURATORS
K071
SLUDGE
Na2CO3
REACTION
TANK
BRINE RETURN
NaCL
SLUDGE PADS
< BRINE SLUDGE ' >
-»»KO71 SLUDGE
NaCL
CLARIFIER
BRINE
HCI
BRINE
SLUDGE
FILTERS
> CI2TO PROCESSING
VACUUM
DECHLORINATION
DEPLETED
BRINE
NaOH
CI2CONDENSATE
FROM CHLORINE
PROCESSING
CELLROOM
HCI
FIGURE 9.NaCI BRINE TREATMENT SYSTEM
-------
OECIILORINATEO
DEPLETED BRINE FROM
MERCURY CELLS
ROCK
SALT
RECYCLED
BRINE
TREATED. PURIFIED
BRINE TO MERCURY CELLS.
BRINE
6ATURATORS
VO
SATURATOR
INSOLUBLES
SOLIDS
HOLDING
AREA
WATER
MAKEUP
BRINE TREATMENT
AND CLARIFICATION,
FILTER BACKWASH
SOLIDS CLARIFICATION
HOT
PROCESS
TREATMENT
SOLIDS
UNDERFLOW
SOLIDS
LEGEND
EXISTING PROCESS
\//A PROPOSED PROCESS
\//A MODIFICATIONS
/OCLAHIFIEHX'
^/THICKENER//
L UNDERFLOW
SOLIDS *
/ * ' / ' '/
/ROTARYV
/VACUUM y
/ FILTER /
f f J J S f S
FILTER CAKE (KO71
TO HAZARDOUS
WASTE
DILUTE
BRINE
RECYCLE
LANDFILL
DISPOSAL
RECYCLED WATER
FROM WASTEWATER
TREATMENT SYSTEM
SLURRY
/PREPARATION/
TANK
VTANK
1
Y//////////7//
HORIZONTAL VACUUM/
BELT FILTER/WASHER^
WASHED NOH HAZARDOUS FILTER
CAKE TO SANITARY LANDFILL DISPOSAL
ROCKS.
TRASH
WASH WATER
TO WASTEWATER
TREATMENT SYSTEM
FIGURE 10 PROPOSED WATER WASHING PROCESS FOR
NaCI SATUHATOR INSOLUBLES
-------
DECHLORINATED
DEPLETED BRINE
FROU MERCURY CELLS
ROCK SALT
OB KCI
RECYCLED BRINE
I
BRINE
8ATURATORS
RE8ATURATED
BRINE
(Nad or KCI)
TREATED. PURIFIED N»CI OR
KCI BRINE TO UERCURV CELLS
OR KCI BRINE TREATMENT
AND CLARIFICATION. FILTER
BACKWASH SOLIDS
CLARIFICATION
HOT PROCESS TREATMENT
SOLIDS (NaCI BRINE ONLY)
N.Ct
SATURATOR
INSOLUBLES
(KCI SATURATOR
INSOLUBILES ARE
NEGLIGIBLE)
LEGEND
| |
EXISTING PROCESS
\S/J( PROPOSED PROCESS
\//4 MODIFICATIONS
TO WATER WASHING
PROCESS (FIGURE »
WASH WATER
TO
WASTEWATER
TREATMENT
SYSTEM
!
FIGURE 1 1 PROPOSED SULFIOE PRECIPITATION OPTION FOR REMOVAL OF
ENTRAINED MERCURY FROM THE KO7I BRINE PURIFICATION
WASTES
WASHED NON-HAZARDOUS FILTER CAKE
TO SANITARY LANDFILL DISPOSAL
-------
Legend
Workplace Flow
Waste Flow
Finished
Cadmium
Plated
Paris
Westewaler
lo Acid/Base Sump
Waslewaler
lo Acid/Base Sump
HCI
Pickle
i
Cold
Rinse
Blow
Dryer
Cadmium
Plate
Cold
Rinse
Chromatc
Dip
Running
Rinse
Still
Rinse
Intermittent
Disposal
Waslewaler
lo Cr Sump
Waslewaler
lo Cd/CN Sump
Figure 12. Simplified Schematic: Automatic Barrel Cadmium Plating Line
-------
Legend
Wofkpleco Flow
Wast* Flow
Drying
Owen
f
IH.I
Rinse
Cold
Rinse
«
Chiomale
Dip
+
Hoi
Rinse
*
Running
Rinse
*
Sllll
Rinse
*
Cadmium
Plate
+
Cold
Rinse
+
Reveise
Cuifenl
Clean
*
Cold
Rinse
*
HCI
Pickle
₯
Finished
Cadmium
Plated
Pails
Wsslawsler lo
Cr Sump
tin
Waslewalar to
Cd/CN Sump al
End ol Shin
J
Wsslawaler lo
AcldJBase Sump
Figure
Simplified Schematic: Manual Cadmium Plating Line
-------
Legend
Woikpleca Flow
Waste Flow
Dryer
en
CJ
Cold
Rinse
T
Chrome
Plating
Pre-Hoal
WaM
Waslewalar le
Cr Sump
Finished
Chromium
Plaled
Pails
I
i
Racking
Table
Chroma
Strip
(optional)
Figure u. Simplified Schematic: Manual Chromium Plating Line
-------
The Environmental Audit: Shield or Sword
Presented by
Edward A. Hogan, Esq.
Coauthored by
Lisa Murtha, Esq.
Porzio, Bromberg and Newman
Morristown, New Jersey
-------
THE ENVIRONMENTAL AUDIT; SHIELD OR SWORD?*
EDWARD A. HOGAN** AND LISA MURTHA***
It has often been said that a little bit of knowledge
is a bad thing. That is particularly and alarmingly true in the
area of environmental audits. More important, therefore, than
the question: "What can an environmental audit do for you?", is
the question: "What can an environmental audit do to you?". The
answer to that inquiry is "plenty" and unless a company
undertaking such a task is prepared and committed to take both
the good and the bad that may be generated by an environmental
audit, it should neither commission nor perform one.
The well-established purpose of an environmental audit
is to provide a concise, comprehensive evaluation of a company's
actual and potential environmental liability and to measure the
level of compliance with the myriad of local, state and federal
regulations which govern the generation, treatment, storage, and
disposal of hazardous substances and wastes. Financially, an
environmental audit can reveal methods by which to streamline
present practices and cut expenses and can provide a basis upon
which to project the future costs of compliance. Environmentally,
an audit can demonstrate whether a company is in full compliance
0Copyright reserved 1987 by Edward A. Hogan and Lisa Murtha.
Principal and Chairman, Department of Environmental Law,
Porzio, Bromberg & Newman, P.C., Morristown, New Jersey. B.S.,
St. Peter's College, M.F.S. Yale University School of Forestry
and Environmental Studies, J.D., Georgetown University.
Associate, Department of Environmental Law, Porzio, Bromberg
& Newman, P.C., Morristown, New Jersey. B.A., Summa Cum Laude,
Caldwell College, J.D., Summa Cum Laude, Seton Hall University
School of Law.
54
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with the applicable regulations and, perhaps even more
importantly, symbolize its interest in and commitment to
maintaining high standards of environmental quality.
In addition to complementing a company's ongoing
business, an environmental audit is an essential tool in the
acquisition of new businesses. A competent review of a selling
business' present and future environmental liability is of
fundamental importance in the acquisition of that corporation and
will significantly effect whether the sale occurs at all as well
as the price.
With the ever growing complications of governmental
regulation, the prohibitive costs of the generation,storage and
disposal of hazardous substances, the threat of civil, monetary
and criminal sanctions, and the potential for liability for
personal injury and property damage, there can be no doubt that a
complete and in-depth analysis of a company's environmental
concerns is of the utmost importance.
Given the significant issues addressed by environmental
audits it is no suprise that they now seem to be well-entrenched.
First appearing in the mid-1970's when the Securities and
Exchange Commission required three corporations to audit their
environmental liabilities, over two-thirds of the larger
companies in the basic manufacturing and process industries and
over 50% of large companies in general, now perform environmental
audits on a regular basis.
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The legal consequences of an environmental audit are,
however, grave and must be fully appreciated before such a
process is initiated. Just as an audit may function as a shield
protecting a business from potential liability, it may also act
as a sword which can inflict serious, even fatal, damage if not
properly sheathed. Accordingly, the issues which businesses
conducting environmental audits must address early on are: "How
best can that sword be sheathed?" and "What are the legal
consequences of an environmental audit?"
Environmental audits can be harbingers of both good,and
bad news. The good news about environmental audits is that they
can assure a company that it is in compliance with all pertinent
regulations and statutes or, at least, compel swift compliance
should it not have been achieved previously.
The bad news is that an environmental audit can
generate information concerning the use and disposal of hazardous
substances or wastes that, at worst, demonstrates a violation of
the applicable laws and, at best, may trigger reporting
responsibilities that will, in turn, invite governmental
monitoring, intervention and oversight. It is imperative,
therefore, that before undertaking an environmental audit, a
corporation be prepared to confront the consequences of knowledge
that may include:
1. The duty to report past and present
violations.
2. The spectre of increased governmental
inspection and oversight.
56
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3. The imposition of civil or criminal
penalties.
4. The necessity to perform remediation.
Conducting an environmental audit, therefore, is
somewhat like eating of the forbidden fruit in the Garden of
Eden. No matter how alluring it may be, it is an act that may
banish a company from the paradise of self-satisfaction and
environmental complacency. No company should initiate and no
consultant should recommend an environmental audit unless it is
clearly understood from the outset that information relevant to
violations may be discovered and that information requiring
governmental reporting or regulation may be unearthed.
Indeed, one of the most critical aspects of an
environmental audit is that it can generate facts which will
trigger a reporting responsibility on the part of the business
conducting the audit. A number of state and federal
environmental statutes impose a positive obligation to advise the
responsible agencies of certain facts concerning not only present
problems but environmental incidents which may have occurred in
the past as well. Environmental audits may, therefore, directly
lead to just that type of governmental entanglement that a
business may be seeking to avoid through a thorough review of its
environmental programs and systems.
For example, the New Jersey Spill Compensation and
Control Act (N.J.S.A. 58:10-23.11 et seg.) specifically requires
any person who has discharged hazardous substances or who is in
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any fashion responsible for the hazardous substances which may
have been discharged, to notify the New Jersey Department of
Environmental Protection (NJDEP). (N.J.S.A. 58:10-23.lie). The
statute is applicable to discharges occurring both prior to and
after April 1, 1977, the effective date of the Act. Accordingly,
the obligation to report discharges applies not only to current
or present discharges but also to the discovery of discharges
which may have occurred in the past. The NJDEP has taken the
position that the responsibility to report arises not only in
regard to discharges of which an owner or an operator may be
aware and which occurred either before or after the effective
date of the statute but also in regard to discharges of which the
owner or operator may not have been previously aware but which
are later discovered. Discovery of contamination, therefore,
which indicates that there must have been a past discharge, will
trigger the reporting obligation, similarly, reporting will be
required in regard to property previously but not currently
owned. Neither the Spill Act nor the associated regulations
include any threshold, de minimus, quantities for purposes of
reporting. The implementing regulations do, however, require
reporting in regard to discharges of hazardous substances "in
such quantities or concentrations as may be harmful or which
poses a foreseeable risk of harm to public health or welfare, or
to natural resources." N.J.A.C. 7:1E-2.1. The determination as
to what amount would be harmful or would pose such a threat is
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left to the reporting party. Clearly, this standard is broad and
the responsibility to report comprehensive. The facts determined
through an environmental audit could, therefore, easily require a
company to comply with the reporting requirements of the Spill
Act.
Similarly, the Hazardous Substances Discharge-Reports
and Notices Act, N.J.S.A. 13:1K-15 et seq., requires owners of
industrial establishments or real property which was once a site
of an industrial establishment to report known or suspected
discharges of hazardous substances occurring either above or
below ground. This act requires the owner to report such events
not to the NJDEP, as in the Spill Act, but to the governing body
of the municipality in which the industrial establishment or
property is located and to the local health department. These
local agencies, in turn, are responsible for advising the NJDEP.
An industrial establishment is any business which handles
hazardous substances and has an SIC number within groups 22
through 39, 46 through 49, 51, 55, 75 or 76. Hazardous
discharges are defined as discharges reportable to NJDEP pursuant
to the Spill Act.
A number of additional state and federal statutes,
including the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) (42 USCA §9603(a)) and others not
listed herein, contain similar reporting requirements that may be
activated by the information developed through an environmental
59
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audit. Environmental audits should, therefore, be undertaken
only with a complete understanding of these possible
responsibilities.
In addition to revealing facts requiring reporting,
audits can develop facts which may not require notification to
governmental agencies but which are, nonetheless, alarming or
disturbing. Moreover, ignoring the bad news of an environmental
audit can lead to violation notices, fines, criminal sanctions,
private liability, and a severely damaged public reputation.
Without question the failure to address known problems is clearly
more damning than the failure to discover those problems in the
first instance. Knowing violations of environmental regulations
will, in some instances, absolutely assure the imposition of
criminal sanctions upon responsible company employees. [Under
RCRA, for example, penalties starting at $50,000 per day of
violation plus a term of imprisonment may be imposed for
knowingly violating the provisions of that and other statutes.
See 42 U.S.C. §6928(d) and (e). Criminal penalties may also be
imposed under the federal Clean Air Act (42 U.S.C. §7413(c)), the
federal Clean Water Act (33 U.S.C. §1319(c)); the state Air
Pollution Emergency Control Act (N.J.S.A. 26:2C-33) and the state
Water Pollution Control Act (N.J.S.A. 58:10A-10).] In short, a
business should not perform or initiate an environmental audit
unless it is committed to confronting the responsibility
conferred by knowledge.
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Similarly, environmental audits can easily be
transformed into instruments of destruction if they become
available to the general public or if they are discovered by
adversaries during the course of litigation. By performing an
audit a corporation may, in fact, be preparing the very record
needed to destroy it in litigation or enforcement actions. In
short, from a regulatory point of view, an environmental audit
can provide the United States Environmental Protection Agency
(EPA) with a ready-made basis for instituting an enforcement
action. Public disclosure of environmental audits can destroy a
company's previously good public reputation, can invite the
institution of citizen's suits provided for under several of the
federal environmental statutes, and can clearly place a company
in a disadvantageous position in on-going litigation. In each of
these instances a business' own environmmental audit can,
ironically enough, be used against it. From a legal perspective,
however, there are means by which to insulate an environmental
audit, at least to a certain extent, from the ramifications of
public exposure and from the effects of release to adversaries in
litigation.
Although a company may internally limit the
distribution or publication of an environmental audit and intend
to preserve its confidentiality, it may nevertheless be disclosed
either through the request of the EPA for reports or information
or through the request of adversaries in litigation by use of the
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rules of pre-trial discovery. Both the broad administative
enforcement powers of the EPA and the liberally construed rules
of discovery are sufficiently comprehensive to compel the
production of audits. Companies may, therefore, be vulnerable to
the disclosure of what they meant to be confidential and private
internal documents.
A number of so called privileges, which have arisen in
the course of general litigation, may be applied to environmental
audits to protect them against public dissemination. More
specifically, there are three privileges that may be invoked:
1. The lawyer-client privilege.
2. The work-product rule.
3. The privilege of self-evaluative analysis.
Preliminarily, it is essential to the protection of an
environmental audit to involve legal counsel as soon as possible
in all aspects of the audit. Because the assurance of the
confidentialty of an environmental audit is as critical as the
audit itself, the participation of counsel is a measure of
caution that should be assured early on. Without the association
of counsel, the lawyer-client privilege and the work-product rule
will not apply at all. Similarly, the involvement of an attorney
at the outset will ensure that the environmental audit and the
audit process are structured so as to assure the maximum degree
of insulation. The necessity for legal advice and supervision in
the environmental audit is a factor which must, therefore, be
62
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considered at the time that the company is first considering the
performance of an audit. Legal participation will demand a
commitment of the time of in-house counsel or, alternatively, the
commitment of resources to the cost of retaining outside counsel.
In view of the ramifications of public disclosure of such audits
it is, however, a cost well worth incurring.
Although industry, long sensitive to the need for the
non-disclosure of environmental audits, has consistently urged
the EPA to adopt rules or policies assuring the confidentiality
of such reports, the Agency has declined to do so to date.
Indeed, it has been suggested that in order to encourage
environmental audits the EPA should agree not to seek the
production of such reports in enforcement actions thereby
assuring some degree of protection. Given the agency's ability
to compel the collection and production of such materials
independent of the audit, such protections would have no effect
on its ability to enforce compliance. Conversely, a policy
insulating internal audits would encourage voluntary, self-
policing by industry. Therefore, although at some point the EPA
may accede to the wishes of business to grant some degree of
protection, the only privileges presently available are those
generally developed in the context of litigation.
THE LAWYER-CLIENT PRIVILEGE
The laywer-client privilege, codified in New Jersey as
Rule 26 of the New Jersey Rules of Evidence, provides that:
63
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... communications between a lawyer and his
client in the course of that relationship and
in professional confidence are privileged and
a client has a privilege (a) to refuse to
disclose any such communication, and (b) to
prevent his lawyer from disclosing it, and (c)
to prevent any other witness from disclosing
such communication if it comes to the
knowledge of such witness (i) in the course of
its transmittal between the client and the
lawyer, or (ii) in a manner not reasonably to
be anticipated or (iii) as a result of a
breach of the lawyer-client relationship or
(iv) in the course of a recognized
confidential and privileged communication
between such client and witness.
This rule generally protects discussions,
communications, and correspondence between counsel and client
providing they occur in the context of a professional
relationship. In order to invoke this privilege it must have
been the intent of the parties to the communication that it be
kept confidential. The circulation of the audit or its
preliminary drafts should, therefore, be limited to only the
lawyer, the consultants engaged by the lawyer, and those in the
corporation who need to know the results of the audit.
There are, of course, exceptions to the privilege.
These, too, are set forth in the rule. The only exception
relevant to this particular area provides that the privilege
shall not extend to a communcation occurring in the course of
legal services sought or obtained in aid of the commission of a
crime or a fraud. To the extent that failure to comply with or
violation of the federal or state environmental statutes
constitutes a criminal offense this exception may apply to
64
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communications between a client and a lawyer which relate to the
perpetuation or commitment of such activity. As such, these
communications are not within the shield or the protection and
may be revealed. Indeed, in some instances they must be reported
by the attorney. This is a significant caveat that should be
clearly understood by the client from the outset. A lawyer
cannot be used to protect communications regarding the commission
of criminal activity. This exception refers, however, only to
communications in aid of the commission of a criminal act. It
does not exclude from protection discussions concerning completed
or antecedent criminal activity. Matthews v. Hoagland, 48 N.J.
Eq. 455 (Ch. 1891).
"Client", in the term lawyer-client privilege, is
defined to include corporations that consult a lawyer for the
purpose of retaining the lawyer or securing legal services or
advice from him in his professional capacity. Early case law
limited the extent of the protection in the corporate context to
communications between the lawyer and only those corporate
employees responsible for directing a corporation's action in
response to legal advice, the so-called "control group". In
Upjohn Co. v. United States, 449 U.S 383, 103 S.Ct. 677, 66
L.Ed.2d 584 (1981), however, the United States Supreme Court
broadened the protection to include communications between a
lawyer and any employee providing the disclosure concerned
matters within the employee's scope of corporate duties and
65
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providing that the communication was made for the purpose of
enabling the lawyer to provide legal advice to the corporate
client. See also SICPA North America v. Donaldson Enterprises,
Inc., 179 N.J. Super 56 (Law Div. 1981), United Jersey Bank v.
Wolosoff, 196 N.J. Super 553 (App. Div. 1984). Therefore, a
communication between an employee and an attorney retained for
the purpose of providing counsel to the corporation will be
protected from disclosure, providing the communication pertains
to information within the employee's scope of employment and
relates to the legal matter for which the attorney has been
engaged.
The Courts have created a distinction between
"communications1' which may be protected by the privilege and the
"facts" communicated which may not be privileged. A communi-
cation involves a conversation between the employee and the
lawyer. The privilege provides that the employee or the lawyer
may not be questioned as to what was said during that
conversation. A "fact", however, which may be within a client's
knowledge and which may have been communicated during the course
of the conversation with the attorney is not protected even
though relayed to a lawyer as a basis for providing legal advice.
UpJohn Co. v. United States, 449 U.S. 383, 101 S.Ct. 677, 66
L.Ed.2d 584 (1981), Philadelphia v. Westinghouse Electric Corp.,
205 F.Supp. 830 (E.D. Pa. 1962).
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Information, therefore, concerning the facts of
company's environmental compliance or noncompliance (i.e.
existence of hazardous substances or wastes, manners of disposal,
quantities or types of discharges, spills, etc.) are not
protected by the laywer-client privilege, even though provided to
an attorney in a course of preparing an environmental audit.
Anyone may freely inquire into those facts. What would be
protected, however, is any discussion the attorney and the client
may have had concerning the facts and, even more importantly, the
attorney's advice in response to those facts. Accordingly, any
plan, response or advice which an attorney may formulate in an
environmental audit as well as the attorney's assessment of
liability will all be protected by the lawyer-client privilege
although the facts underlying the advice will not be shielded.
An important caveat in invoking the laywer-client
privilege is that during the course of the professional
relationship the attorney must be acting in his role as an
attorney in order to claim the privilege. The communication must
be made for the purpose of obtaining legal advice. The privilege
is limited to communications made to an attorney acting in his or
her professional capacity. If, then, the lawyer is being used
merely to gather information and compile it into the report, the
lawyer is, in fact, performing a task that could be performed by
a non-lawyer. As such, communications made to the lawyer in that
context are not protected. See Metalsalts Corp. v. Weiss, 76
67
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N.J. Super. 291 (Ch. Div. 1962), United Jersey Bank v. Wolosoff.
196 N.J. Super. 553 (App. Div. 1984), L.J. v. J.B.. 150 N.J.
Super. 373 (App. Div. 1977). Only if the attorney is acting in a
professional capacity either in preparing for litigation or in
the process of rendering legal advice is the communication within
the ambit of the privilege. In preparing environmental audits,
then, it is imperative to draft the aid of the attorney not
merely as a clearing-house to gather information and data but
additionally to solicit legal advice in regard to the
environmental issues addressed in the audit. This should be made
crystal clear in any correspondence retaining counsel in relation
to the environmental audit.
Similarly, the audit itself should be structured as a
legal opinion rendered in response to the information gathered in
the course of the audit.
The use of in-house counsel presents special problems
in this regard as it may be difficult in some instances to
separate purely legal tasks from simply information-gathering or
ministerial tasks. Again, in enlisting the aid of in-house
counsel it is important, for the purposes of maintaining
confidentiality, to limit their responsibility to the rendering
of legal advice to protect the audit.
Simply compiling a report without the participation of
counsel but later including it into the corporation's legal file
or directing it to the legal department would be an inadequate
68
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basis upon which to claim the protection offered by this
privilege. Wylie v. Mills, 195 N.J. Super. 332 (Law Div. 1984).
The six simple rules, then, of preserving the shield of
this protection include:
1. Involve legal counsel at the beginning of
the process.
2. Clearly designate counsel's role in the
process as providing legal advice and
guidance.
3. Limit the participants to communications
to the lawyer and the employees of the
client with relevant knowledge or a need
to know.
4. Incorporate the attorney's advice,
guidance and opinion in the audit and
label it as such.
5. Memoralize the intent that communications
regarding the audit are to be kept
confidential.
6. Confirm and reconfirm the attorneys' role
in all correspondence.
In sum, in order to secure the shield offered by the
lawyer-client privilege for an environmental audit it is
necessary to involve counsel in the process of information
gathering and evaluation and, more importantly, in that phase of
the audit relative to a company's response and reaction. Mere
token association of legal counsel will severely threaten the
applicability of the privilege.
WORK-PRODUCT ROLE
A related privilege, the work-product rule, may also be
used under certain circumstances to protect at least part of the
69
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environmental audit. This privilege shields from production or
release documents prepared in anticipation of or in preparation
for litigation. If an environmental audit, then, is prepared in
the course of an on-going lawsuit or in anticipation of a lawsuit
for the purpose of evaluating a company's past, present and
future environmental liability, a claim may be made that it is
shielded from public scrutiny by this privilege. More often,
however, an audit is prepared as a matter of good management. As
such, it cannot be said to have been prepared in anticipation of
litigation. To help build a record in this regard, the company
should document, either in the letter retaining counsel
concerning the performance of the audit or in the audit itself,
that it anticipates an enforcement action or litigation and why.
An unsubstantiated recitation that litigation may occur will be
inadequate to trigger the work-product rule. There must be a
good-faith expectation of such action.
A simple method of at least providing a basis for the
invocation of this rule is to mark all correspondence between
attorney and client as ''Privileged and Confidential." While this
designation will not, of course, assure confidentiality it will
signal the intention of the parties should the issue later arise.
The work-product rule, set forth in Rule 4:10-2(c) of
the Rules Governing the Courts of the State of New Jersey,
provides that the information in the audit may be released if the
party seeking disclosure can demonstrate that it has a
70
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"substantial" need for the materials in question and that it is
unable, without undue hardship, to obtain a substantial
equivalent of these materials by other means. See also Hickman
v. Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 L.Ed. 451 (1947). Even
where an opponent can make such a showing, the courts are
directed to protect against the disclosure of the mental
impressions, conclusions, opinions or legal theories of the
attorney concerning the litigation. At least that portion of the
environmental audit, then, which includes counsel's evaluation of
a company's present environmental systems, its vulnerability to
suit, its chances of success should suit actually be instituted,
the formulation of environmental strategies and similar opinions
could be brought within the protection of the work-product rule
even if the rest of the investigation in the audit could be
revealed. For that reason, those portions of the audit
containing such opinions should be clearly designated as such.
They may, then, be more easily excised should the audit have to
be disclosed.
In terms of damage control, it is clear that the
greater potential for problems rests not with the discovery of
the facts unearthed by the audit but with the discovery of a
company's response or non-response to these problems. For
example, a company's failure to comply with its own in-house
control systems, its failure to design response plans, or its
policy in regard to continuing problems can severly cripple its
71
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ability to enter into settlements with the government or private
litigants. An audit, by bringing the facts of violations into
focus, can transform a business into a knowing violator that can,
in turn, justify criminal sanctions. If an important aspect of
environmental audits is to solve problems, a company must, then,
be free to insure the confidentiality of its response to
problems. The protection afforded by the work-product rule
shields the response plan and alternatives suggested by legal
counsel. This protection, then, while not all-encompassing,
protects the most sensitive portions of the audit.
The courts which have considered the protection
afforded by the work-product rule have held that an attorney's
notes of interviews with employees or oral statements by
employees are protected as opinion work product even though an
employee's own written account may not be so protected. Upjohn
CO. V. United States, 449 U.S. 383, 501 S.Ct. 677, 66 L.Ed. 2d
584 (1981). Therefore, the guarantee of protection is enhanced
by permitting an attorney to gather the necessary information for
the audit himself and to record it in his or her own handwriting.
To claim the protections afforded by the work-product
rule a company should:
1. perform environmental audits anticipating
suit either by the government in
enforcement actions or private citizens
in citizen suits,
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2. designate sensitive documents as "Privileged
and Confidential",
3. avoid the generation of reports,
writings, memorandum, and
4. permit counsel to gather and memorialize
the necessary information.
PRIVILEGE OF SELF-EVALUATIVE ANALYSIS
The final privilege which may be invoked to shield an
environmental audit against public disclosure, the privilege of
self-evaluative analysis, is a less well established but
potentially useful tool of confidentialty. This privilege seeks
to protect reports, documents, studies, etc. generated in the
process of studying a particular problem, issue or accident. The
policy behind according confidentialty to such documents is the
interest in encouraging business to review and analyze situations
so as to avoid similar future accidents and incidents. By freely
compelling the production of such studies, it is feared that
candid, thorough review will be stifled. Because this privilege,
also referred to as the privilege of self-examination or self-
critical analysis, has not yet won wide acceptance in New Jersey,
the protections it may afford are clearly less certain than those
provided by the lawyer-client privilege and the work-product
rule.
In order for this protection to apply, the business
must demonstrate that:
1. the audit process is a self-evaluative
process,
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2. there is a strong public interest in
environmental auditing, and
3. there is a likelihood that
environmentally beneficial auditing would
be curtailed unless confidentiality was
assured.
The privilege of self-critical analysis is said to
prevent the disclosure of "confidential, critical, evaluative
and/or deliberative material whenever the public interest in
confidence outweighs an individual's need for full discovery."
Wylie v. Mills, 195 N.J.Super 332, 338 (Law Div. 1984). It will
protect criticisms and evaluations deemed to be essential in
recognizing the cause of past problems and the elimination of
future problems. The courts in New Jersey have recognized that:
Valuable criticism can neither be sought nor
generated in the shadow of potential or even
possible public disclosure. It is not
realistic to expect candid expressions of
opinion or suggestions as to future policy or
procedures in an air of apprehension that such
statements will be used against a colleague or
employer in a subsequent litigated matter.
The purpose of an investigation intended to
seek criticism, opinion, or suggestion and
form the basis of then existing policy or
procedure is self-improvement. The value of
the investigation is questionable if the input
is not reliable. It is clear that the
reliability of the input in the situation
varies inversely with the risk of the
disclosure or the input or results of
criticism. [Wylie v. Mills, 195 N.J. Super.
332, 340 (Law Div. 1984)].
This privilege is specifically applicable to a
corporation's internal evaluative reports. Environmental audits
would clearly appear to fall within this category of documents.
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Like the lawyer-client privilege, however, the privilege of
self-evaluative analysis, when applied, has not been extended to
factual information contained in such reports. Only the
"evaluative" portions of the reports have been deemed to be
protected.
As in the work-product rule, courts in this context
will weigh the need for the information against the interest in
preserving its confidentialty. If the information in question is
unavailable from other sources more serious consideration will be
given to compelling its production.
Unlike the other privileges, the applicability of this
privilege is limited. It has generally been honored only in the
context of discovery in private actions. It has not been held to
protect against disclosure in governmental enforcement actions.
Therefore, it may not protect an audit from disclosure to a
governmental agency.
CONCLUSION
In conclusion, while environmental audits can help a
company to assess potential liability, predict the cost of doing
business, assure compliance, and analyze what must be done in the
future, they can, at the same time, clear a path of destruction
unless properly protected and insulated. The legal consequences
of an environmental audit are significant. At the outset, it is
critical to understand that the information and facts generated
by an environmental audit may create a responsibility to respond
74A
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on the part of the corporation. The results of the audit may
trigger a reporting duty of which the corporation was previously
unaware. They may similarly reveal situations requiring the
outlay of considerable time and capital to correct and assure
compliance. Failure to address problems revealed by an
environmental audit will surely compound the difficulties posed
by the problems themselves and increase the likelihood of
criminal sanctions.
Unless properly protected, an environmental audit can
provide ammunition for adversaries in citizen's suits. If
publicly disseminated, environmental audits can also destroy a
company's previously good reputation in the community. It is,
therefore, imperative to understand the privileges which may
protect an environmental audit and to structure the audit so as
to assure to the company the greatest protection possible. The
lawyer-client privilege, the work-product rule and the privilege
of self-evaluative analysis can all shield, at least in part, the
environmental audit and help to preserve it as a helpful rather
than a harmful management tool.
74 B
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Waste Minimization: An Update
Presented by
Harry Freeman
Research Program Manager
Hazardous Waste Engineering Research Laboratory
U.S. Environmental Protection Agency
Cincinnati, Ohio
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WASTE MINIMIZATION: AN UPDATE
Harry Freeman
U.S. Environmental Protection Agency
Hazardous Waste Engineering Research Laboratory
Cincinnati, OH
Background
There 1s a national policy In the
United States to eliminate the generation
of hazardous waste. The U.S. Congress
stated m the Hazardous and Solid Waste
Amendments of 1984 to the Resource Conser-
vation and Recovery Act of 1976:
The Congress hereby declares it to
be the national policy of the United
States that, wherever feasible, the
generation of hazardous waste is to
be reduced or eliminated as expedl-
tlously as possible. Waste that 1$
nevertheless generated should be
treated, stored or disposed of so as
to minimize the present and future
threat to human health and the
environment.
Reflecting the intent of this
policy, there have been adopted by the
EPA and other public agencies similar
variations of the hierarchy shown below
as a guide for hazardous waste
management options:
1* Source reduction: reduce the
amount of wasti at the source
through changes 1n Industrial
processes;
2. Waste separation and
concentration: Isolate hazar-
dous materials from mixtures in
which they occur;
3. Waste exchange: transfer
wastes through clearinghouses
so that they can be recycled
1n Industrial processes;
4. Energy/material recovery:
reuse and recycle wastes for the
original or some other purpose.
such as for materials recovery
or energy production;
5. Incineration/treatment:
destroy, detoxify, and
neutralize wastes into less
harmful substances; and
6. Secure land disposal: deposit
wastes on land using volume
reduction, encapsulation, leach-
ate containment, monitoring, and
controlled air and surface/
subsurface water releases.*
The term "waste minimization' has
been defined differently by different
organizations. The US EPA, m Us
October 1986 Report to Congress on the
minimization of hazardous waste, defined
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 1n either: (1) the
reduction of total volume or quan-
tity of hazardous waste or (2) the
reduction of toxldty of hazardous
waste, or both, so long as the
reduction Is consistent with the
goal of minimizing present and
future threats to human health and
the environment.'
*Th1s six-point hierarchy 1s contained in
41 FR 35050. August 18. 1976.
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In addition to the EPA Report to
Congress, other studies by the Office of
Technology Assessment, the EPA's Science
Advisory Board, the National Research
Council, and others have shown general
agreement that an EPA program to encourage
industry to accelerate Its efforts to
reduce the generation of wastes should be
an important Agency objective. EPA's
efforts should support and catalyze both
the development and Industry acceptance of
Industrial manufacturing and production
techniques and recycling methods (both
in-process and otherwise) that will
produce less waste and/or less-hazardous
waste for treatment and disposal.
At least 10 of the states have
Initiated rather significant programs to
encourage Industries within their boun-
daries to reduce waste generation. Most
of the ideas contained 1n this proposed
Agency strategy are based on successful
programs that have been undertaken by the
various states. Consequently, the
programs and experiences of these states
will be utilized by the Agency 1n struc-
turing the federal programs proposed 1n
this document. The success of this strat-
egy wl 1 1 be based to a great extent on the
success of the Agency In Incorporating the
states as partners 1n the effort.
Although H is really quite diffi-
cult to know with certainty how ouch
industrial waste could be eliminated
through stepped-up waste minimization
programs, it 1s strongly suspected that
the amounts are very significant. The EPA
Report to Congress contained data that
suggested that, in general, industry could
still reduce their hazardous waste streams
by 20 to 30 percent. The EPA and OTA
policy studies Include many examples of
successful waste minimization activities.
The Massachusetts League of Women Voters
has compiled reports regarding 20 to 30 of
the major companies 1n the country that
show that waste Minimization on the order
of 30 to 50 percent Is not at all out of
the ordinary when waste minimization has
been actively supported by a company's
management. The OTA has suggested that a
goal of 10 percent waste reduction annu-
ally for the next five years for the
country as a whole 1s not beyond achieve-
ment.
The Current £,JA wasce m.Timizd:.on
Program
Office of Solid Waste. For the past
two years, the Office of Solid Waste (OSW)
has been actively Involved in the area of
waste minimization. In October of 1986,
the EPA submitted the Report to Congress
on the minimization of hazardous waste.
The report was the culmination of an
extensive study conducted by OSW on source
reduction and recycling techniques, the
two primary elements of waste minimiza-
tion. The goal of this study was to
profile current waste minimization prac-
tices by the industrial sector and make
estimates on current and future trends in
waste minimization. In addition, the
study Identified the current Incentives
and disincentives (I.e., economic, regula-
tory, and technical) which exist for waste
minimization.
For the next several years, the
OSW will be developing and Implementing
the Agency's waste minimization program
which was Introduced 1n the Report to
Congress. The goal of this program 1s
to promote the national policy established
in the Hazardous and Solid Waste Amend-
ments of 1984 regarding the minimization
of hazardous waste.
As U 1s presently structured, the
program has two principal objectives: (i)
evaluate the need for regulations for
waste minimization and present this evalu-
ation along with appropriate recommenda-
tions In a report to Congress 1n 1990; and
(2) foster the use of waste minimization
through technology transfer and informa-
tion dissemination activities. In order
to ah1eve this goal, OSW has developed its
FY87 and FY88 programs to focus on the
tasks of gathering Information and data to
establish trends In waste minimization and
developing information dissemination/
technology transfer activities.
Office of Research and Development.
The Office or Research and Development
(ORD) has supported a small waste minimi-
zation extramural program over the past
few years, cooperated with the states of
North Carolina and Minnesota 1n supporting
programs to assist small businesses to
minimize their wastes, and cooperated witn
the Governmental Refuse Collection and
Disposal Association (GROCA), a trade
association concerned with providing
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technical assistance to small waste
generators. Modest funding for the two
state and trade association cooperative
agreements has totaled $420K over two
fiscal years. Matching funds by the
states has brought a significant increase
1n the funding to allow for a substantial
federal-state-private sector relationship.
ORO has also provided rather
substantial support to one of the Agency's
Centers for Excellence, the Illinois
Institute of Technology (IIT), to support
fundamental research into Industrial waste
elimination. The EPA has also cooperated
closely with the Tufts Center for Environ-
mental Management to support various waste
minimization studies and conferences.
HWERL projects to evaluate various recyc-
ling options 1n the printed circuit board
Industry and several smaller projects to
carry out waste minimization audit studies
at five manufacturing facilities have
recently been completed. Currently, as a
continuation of the audit studies program,
the ORO Is supporting the development of a
manual to be used In carrying out waste
minimization audits. Funding for the
audit program has remained constant at
approximately $200K per year for the past
two fiscal years. The IIT program has
expended some $1.5 million since 1978 to
support many broad-scale waste elimination
research projects and some $250,000 has
been provided by the Agency to the Tufts
Center to support waste minimization
projects.
Current Activities
There 1s presently underway within
the EPA the development of an Agency-wide
strategy to convert Into action the goals
and policies of the EPA Report to
Congress, and to provide a technical foun-
dation for furthering the acceptance of
technologies that reduce the generation of
hazardous waste.
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Overview of the Multi-Option Model:
A Computerized Waste Reduction Information
and Advisory System
Presented by
Frank M. Brookfield
Data Management Specialist
Illinois Department of Energy and Natural Resources
Savoy, Illinois
(Originally Exhibited at Illinois Hazardous Waste Reduction '87
September 22-23, 1987)
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Overview of the MULTI-OPTION MODEL (MOM): A Computerized Waste
Reduction Information and Advisory System
The Multi-Option Model (MOM) is an interactive computerized
waste management tool originally developed by ICF Technology,
Inc. for the Maryland Hazardous Facilities Siting Board and the
USEPA. Its primary purpose is to assist generators and state
technical assistance officials with the completion and analysis
of technologies and methods for the reduction, reuse and
treatment of solid and hazardous waste. Recently the Illinois
Hazardous waste Research and Information Center (HWRIC)
contracted with ICF Technology, Inc. for further development of
two components of the MOM.
As shown in Figure 1, the MOM is envisioned to consist of
three components, a Waste Reduction Advisory System, a Treatment,
Storage and Disposal Advisory System, and an interactive waste
Exchange service. The Waste Exchange component is not currently
developed. The other two components exist but have only
partially developed data bases and have had limited field
evaluation. Additional development is being undertaken and
suggestions for revisions are welcome.
The Waste Reduction Advisory System
The Waste Reduction Advisory System (WRAS) currently
consists of a Waste Reduction Audit Checklist (WRAC) developed
for the Illinois HWRIC and an Information Base. These components
and the general types of information they contain are illustrated
in Figure 2. The WRAC consists of information on the seven waste
reduction topics listed in Table 1. These topics range from low
capital approaches to those that are more costly such as
equipment or process modification, and cover options from the
beginning of the industrial process through waste production and
reuse. The information in the WRAC is intended to introduce the
user to the full range of types of waste reduction alternatives
that may be appropriate. More detailed waste reduction case
studies are included in the following Information Base section of
the WRAS.
For each topic in the WRAC the user is first asked if
his/her company has ever tried that approach (for example,
conducted a waste audit). If the user answers yes, the next
screen asks general questions about the results. If that
approach has not been tried, the user is asked to indicate the
reasons why. The WRAC also contains a definition screen for each
topic and a screen where a user can request additional
information and/or technical assistance.
The WRAS Information Base contains descriptions of waste
reduction applications from literature and documented case
studies. Information is shown on potential waste reduction
78
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measures tailored to either the unit processes (across industrial
categories) or by a particular industry as selected by the user.
Th» user is first hown several headline descriptions of the
i iation. Mor_ details can be requested in associated
a. sts and citations. Ultimately, the literature cited in the
.1 format ion Base will be accumulated in a clearinghouse.
The Treatment, Storage and Disposal (TSD) Advisory System
Based on information specified by the user regarding waste
type and facility location, the TSD component of the MOM model
provides an array of waste management options and cost estimates.
Guidance is given on:
- Applicable treatment technologies;
- Available facilities;
- Engineered costs for transportation, treatment, and
disposal ;
- Recycling opportunities; and
- Waste handling brokers.
Most of the information in the TSD data base on management
options for wastes currently is for facilities and services in
the northeastern states. The Illinois HWRIC-sponsored study
enhanced the TSD system by adding a price query to allow waste
management service price/cost comparisons. The engineered cost
estimation component was also improved by accounting for
economies of scale for the transport of less-than-truckload waste
quantities .
Further Information
More information on this computerized waste reduction system
can be obtained by writing or calling the following:
Illinois Hazardous Waste Research and Information Center
1808 Woodfield Drive
Savoy, Illinois 61874
(217) 333-8940
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Figure 2:
WASTE REDUCTION ADVISORY SYSTEM
Industry and
Process
Categories
INPUT
Waste Reduction
Audit Checklist
oo
o
Question
and Answer
Screens
Definition
Screens
Information
Screens
TOPIC MENU
Information
Base
CITATION
ABSTRAC
HEADLN
Industry
-M
CITATION
ABSTRAC
HEADL
General
Advisory
CITATION
ABSTRA(
HEADL
Process
Advisory
-------
Figure 1:
MULTI OPTION MODEL
FOR WASTE REDUCTION
Technical
Assistant
oo
Waste
Reduction
Advisory
System
MultiOption
Model
I
Generator
Generator
Characterization
I
TSD
Advisory
System
Waste
Exchange
-------
Figure 3:
TSD Advisory System
Waste Type
and Volume
en
i
Optimize
Treatment
and Disposal
i
Comparative
Cost
Evaluation
Transportation
Treatment
Service
Information
Base
Disposal
-------
CD
10
Table 1: TOPICS IN THE
WASTE REDUCTION AUDIT CHECKLIST
1. Management Strategies
2. Waste Audit
3. Good Operating Practices
4. Raw Material Substitution/Product Reformulation
5. Equipment/Process Modification/Replacement
6. Wastewater Reduction
7. Resource Recovery
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Hazardous Waste Minimization
at Olin Corporation
Presented by
R. E. Mooshegian
Environmental Coordinator
Olin Corporation
East Alton, Illinois
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HAZARDOUS WASTE MINIMIZATION
OLIN CORPORATION
EAST ALTON, IL
01 in Corporation operates two manufacturing facilities in East Alton,
IL that generate, treat and/or store hazardous waste. They are referred
to as the Main Plant Facility and the Zone 17 Facility.
The Main Plant Facility includes manufacturing operations conducted by
the Brass Group and by the Defense Systems Group, Winchester Division.
The Zone 17 Facility includes manufacturing operations conducted by the
Brass Group and by 01 in Electronics Materials Corporation (OEMC), a wholly
owned subsidiary of 01 in Corporation. The Brass Group manufactures brass
and copper alloy products. Winchester manufactures small arms ammunition
and explosives. OEMC manufactures dad-metal strip used for the
manufacture of electronic components.
Olin's waste minimization program addresses the criteria set forth by
Congress under Section 3002 of RCRA by (1) reducing the volume or quantity
and toxicity of hazardous waste to the degree determined by 01 in to be
economically practicable and (2) treating, storing, or disposing of the
hazardous waste generated using methods that minimize the present and
future threat to human health and the environment. Olin's program also
addresses recently enacted legislation by the State of Illinois which
severely restricts the landfilling of any hazardous waste unless specific
authorization is granted by the Illinois EPA.
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Specifics of the program include an annual review of the following
items for each hazardous waste generated:
1. Review of raw materials used in the process that generates the
waste to determine if other materials can be used that will
render the waste non-hazardous.
2. Review of the current management practices used to
treat/store/dispose of the waste to determine if a better
alternative can be instituted.
3. Discussions with department(s) that generate the waste to
determine what measures can be implemented to reduce the volume
and/or toxicity of the waste.
Overall potential improvements identified as a result of this program
are presented to 01 in management to obtain approval for implementation.
To date, three major hazardous waste minimization projects have been
identified and presented to management for approval. The projects are:
1. Installation of a belt filter press at the Main P" Zone 6
Wastewater Treatment Facility (WWTF) to replace a -y drum
vacuum filter used for sludge dewatering. The -jit press
dewaters more efficiently than the vacuum filter resulting in a
reduction in the volume of hazardous sludge that must be
landfilled.
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2. Segregation of the hazardous wastewater discharges from the
non-hazardous wastewater discharges that are currently combined
before they enter the Zone 6 WWTF and cause the dewatered sludge
to be a listed and characteristically hazardous waste. The
listed hazardous wastewater discharges, which make-up
approximately 4% of the total volume of wastewater treated at the
Zone 6 WWTF, will be redirected to a second, new and smaller
wastewater treatment plant that will also be located in Zone 6.
Once the new wastewater treatment plant is operational, the
volume of hazardous sludge that must be landfilled will be
reduced by as much as 91%.
3. Construction of a new chemical fixation facility that will
convert 1,500 cubic yards per year of characteristically
hazardous waste to non-hazardous waste.
01 in management has already approved the monies necessary to implement
the first two projects and has also approved the money necessary to begin
operation of a pilot plant to develop the needs for a full scale chemical
fixation facility planned to be operational in 1988.
A detailed discussion of Olin's manufacturing operations and the three
major waste minimization projects follow:
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DISCUSSION OF WASTE MINIMIZATION PROJECTS;
As stated previously, 01 in Corporation's Main Plant Facility (MPF) is
made-up of manufacturing operations conducted by two operating divisions,
referred to at the Brass Group and the Defense Systems Group. Process
wastewater discharges from these operations currently discharge into the
MPF's process sewer system which in turn leads to one centralized
wastewater treatment plant referred to by 01 in as the Zone 6 Wastewater
Treatment Facility (WWTF). The Zone 6 WWTF influent flow averages 3.5
million gallons per day. A very small percentage (approximately 4%) of
the Zone 6 WWTF influent comes from hazardous processes. The MPF also
operates its own potable water plant, which is referred to as the Filter
Plant. The Filter Plant's primary source of raw water is the Mississippi
River. The Filter Plant produces 4 to 5 million gallons of potable water
per day. Filtered river solids from the water plant are also discharged
into the MPF's process sewer system.
The processes that discharge hazardous wastewater include
electroplating operations and explosive manufacturing operations, all of
which are listed hazardous waste processes. Since the listed hazardous
wastewater is combined with all of the non-hazardous wastewater from the
rest of the Main Plant's manufacturing operations, the influent to the
Zone 6 WWTF is considered a hazardous waste.
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The operation at Zone 6 consists of both physical and chemical
treatment processes. The influent pH is normally in the range of 4 to 6.
Lime is added to the wastewater for pH adjustment and formation of
insoluble metal hydroxides. Treatment pH is in the range of 9 to 9.3.
With the aid of polymers the insoluble solids settle to form a sludge.
The treated wastewater effluent is then discharged into the East Fork of
the Wood River. The sludge, referred to as Zone 6 WWTF Sludge, is
thickened, dewatered by using vacuum filtration and placed into roll-off
type dumpsters that are routinely hauled off-site to a hazardous waste
landfill. Over the last six years, an average of 8,300 cubic yards (yd3)
of sludge per year has been sent to off-site hazardous waste landfills.
Since the Zone 6 WWTF Sludge represents the largest single source
(80%) of hazardous waste that is generated at Olin's East Alton Facilities
and sent to off-site hazardous waste landfills, reducing its volume has
been given top priority by 01 in management to comply with the intent of
Section 224 of the 1984 Amendments to the Resource Conservation and
Recovery Act and the prohibition on the landfill ing of hazardous waste
after January 1, 1987 set forth by Section 39(h) of the Illinois
Environmental Protection Act.
The two waste minimization projects described below deal directly with
reducing the volume of Zone 6 WWTF Sludge.
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Belt F;lter Press
The first project, the use of a belt filter press for dewatering, came
about as the best method to solve the problem of free-running liquid in
the Zone 6 WWTF Sludge.
Up until November, 1985, 01 in sent most of the hazardous waste it
generated to a permitted facility about twenty miles from East Alton.
However, the landfill closed in November, 1985 which meant that 01 in had
to start sending its hazardous waste to the next closest facility which
was 170 miles away. Soon after the Zone 6 WWTF Sludge was being sent to
the new landfill, some loads were returned to Olin due to free running
liquids. At first, it was thought that there might have been a problem
with the vacuum filters which were used for dewatering. However, careful
examination of the sludge being discharged f the vacuum filter and into
the dumpsters indicated no free running liquids. If a dumpster of sludge
left Olin "dry" but had free running liquid in it after arriving at the
landfill, then the vibration of the dumpster during the trip must have
caused some of the moisture in the sludge to leach out.
Initially, this problem was fought by dumping up to as much as
1,000 pounds of lime in the dumpster to absorb any free running liquid
that leached . t of the sludge during the trip to the landfill. However,
this became very time consuming and did not always guarantee that a load
of sludge would not be returned to Olin. As a result, it became apparent
that some other way of eliminating this problem must be found.
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The vacuum filters at Zone 6 normally dewater the sludge to a solids
content of 30% to 35% which is effectively at the limit of their
capability. To eliminate the free running liquid problem, some type of
filtration equipment more efficient that a vacuum filter would be
required. Several types of filters were considered, including cake
presses, plate & frame filter presses, and belt filter presses. Based on
laboratory tests conducted on the Zone 6 WWTF Sludge, the belt filter
press produced the driest filter cake, which had a solids content of about
50%. To assure that the filter press would dewater just as efficiently on
a larger scale as in the laboratory, a pilot unit was leased and brought
to the Zone 6 WWTF. The small press performed quite well and indicated
that it could reduce the volume of hazardous sludge generated by the
vacuum filters by approximately one-third or 2,700 yd3 per year.
A full size filter press was purchased in May, 1986 and began
operating at the end of the year. Based on the first nine months of
operation in 1987, the filter press is performing better than expected and
has reduced the volume of sludge generated at the Zone 6 WWTF from a six
year average of 8,300 yd3 per year to a volume of about 5,400 yd3 per year
(pro-rated for 1987). The belt filter press performance equates to a 35%
reduction in the volume of sludge to be disposed of.
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Hazardous Waste Stream Segregation
The second waste minimization project designed to reduce the volume of
Zone 6 WWTF Sludge involves the physical segregation of all hazardous
wastewater discharges at the Main Plant from all non-hazardous wastewater
discharges. The hazardous wastewater discharges will be isolated and
redirected to a second, new and smaller wastewater plant that will also be
located at Zone 6.
As stated in the beginning of this paper, a very small percentage (4%)
of the wastewater that is generated at the Main Plant comes from hazardous
processes. However, since the wastewater comes from listed hazardous
waste processes and because it is mixed with non-hazardous wastewater, the
entire wastewater influent to the Zone 6 WWTF and the sludge that comes
out of the facility are considered to be hazardous wastes.
Because of the constantly rising prices for the landfill ing of
hazardous waste, and more importantly because of the environmental
liability associated with landfilling, Olin looked at several different
methods to further minimize the volume of Zone 6 WWTF Sludge including
incineration and a delisting petition as well as the segregation of the
wastewater discharges. The listed hazardous waste processes at the Main
Plant include electroplating and explosives manufacturing operations.
Since the wastewater generated by all of the hazardous processes is
pretreated before it is discharged into the process sewer system,
consideration was given to whether or not a delisting petition could be
91
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obtained for the Zone 6 WWTF Sludge. However, based on sampling and
analyses conducted upon all of the listed process wastewater discharges
and Zone 6 WWTF Sludge, it was determined that the sludge would sometimes
fail the EP Toxicity test for lead. Thp lead comes from the manufacturing
of explosives and the chemical treatment and breakdown of explosive
containing waste. There are no substitute raw materials to take the place
of the lead bearing compounds necessary for the manufacture of explosives.
Incinerating the Zone 6 WWTF Sludge was considered since 65% - 70% of
the sludge is water. However, incinerators are expensive to operate and
maintain and would have to comply with the USEPA's stringent RCRA
Subpart 0 rules. Additionally, because the Zone 6 WWTF is in a remote
area of the Main Plant, the waste heat from incineration could not be
reused. Finally, an incinerator will not destroy the lead contained in
the sludge and would possibly require costly air pollution control
equipment.
The only viable alternative to significantly reduce the volume of
Zone 6 WWTF Sludge was to segregate all of the hazardous wastewater
discharges from the non-hazardous and treat them separately. An
engineering firm was selected to perform a treatability study and provide
the design development of the treatment system. The following describes
the activities conducted in the development of this option.
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The first step in the treatability study was to determine the type of
samples required. Since most of the sources to be sampled had continuous
discharges it was decided to collect composite samples. Automatic
samplers were set up at each source and adjusted to collect 30 gallon
samples over a 24 hour period. A series of flow measurements were taken
during sample collection to establish minimum and maximum flows from each
source for design purposes. Production data was also collected to
determine if normal production activities occurred during sample
collection. After the samples were collected they were composited on a
flow proportional basis using average flow. The samples were then sent to
the lab where they were prepared for testing. Once at the lab the samples
were analyzed for selected parameters to determine the wastewater
characteristics.
In order to determine the or HJITI treatment process a series of
screening tests were performed. The- screening tests indicated which
treatment technologies should be furtner investigated. The technologies
evaluated included oxidation with ozone (with and without ultraviolet
light), ion exchange and chemical precipitation. After treatment each
sample was analyzed for dissolved lead. Dissolved lead was chosen as the
indicating parameter for treatment efficiency due to the low discharge
limits for total lead expected in the NPDES Permit. The samples treated
with ozone resulted in very high dissolved lead levels. The ozone caused
a drop in pH and therefore resulted in placing the lead in solution.
Analyzing of the samples after ion exchange treatment indicated only a 50%
reduction in the dissolved lead concentration. In evaluating chemical
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precipitation a pH range of 6 to 11 was investigated. Calcium hydroxide
and sodium hydroxide were tested as precipitants. The tests indicated
that dissolved lead concentrations of 2.0 ppm could be achieved by
treatment with either chemical at a pH range of 9.0 to 9.5. Based on
these results it was decided to develop the chemical precipitation
process.
One objective in the development of the treatment process was to make
it compatible with the Zone 6 WWTF to take advantage of existing
equipment. The Zone 6 WWTF uses lime for precipitation therefore it was
decided to use lime for the new treatment system and avoid the cost of
another chemical feed system.
\
The next step in developing the chemical precipitation process was to
determine the level of treatment that can be achieved. The use of a
coagulant followed by pH adjustment with lime was evaluated. The
coagulants investigated included magnesium sulfate, aluminum sulfate,
ferric chloride and ferrous sulfate. Magnesium and aluminum sulfate
produced a fine particle which would not settle out on its own. Ferric
chloride and ferrous sulfate produced particles which settled well and
resulted in acceptable dissolved lead concentrations. However, the solids
generated by treatment with ferric chloride began to resuspend. Based on
the tests it was decided to optimize the use of ferrous sulfate.
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In order to determine the optimum ferrous sulfate dosage a series of
tests were set up. The ferrous sulfate dosage was varied from 325 to
400 ppm and the treatment pH was in the 9.0 to 9.5 range. After
treatment, each sample was analyzed for its dissolved lead content. The
analysis indicated that at a ferrous sulfate dosage in the range of 375 to
400 ppm a dissolved lead concentration of 0.10 ppm could be achieved.
Coagulation followed by precipitation produced some fine particles
which did not settle well. It was apparent that a polymer would be needed
to aid in settling. Based on past, in-house experience, a high molecular
weight am'onic polymer was needed. In order to determine the optimum
polymer dosage another set of tests were performed. A sample of the
wastewater was first treated by adding ferrous sulfate to a concentration
of 400 ppm. The pH was then adjusted to 9.3 with calcium hydroxide to
begin formation of a micro-floe. With the sample thoroughly mixed
portions were taken for the addition of polymer. Polymer was added to
each portion at dosages that ranged from 1 to 10 ppm. Each portion was
rapid mixed (100 rpm) for one minute and then mixed slowly (15 rpm) for
flocculation. At this rate, a slow, gentle motion of the particles
resulting in good floe formation was observed. After a flocculation time
of ten minutes the portions were then poured into graduated cylinders to
determine the rate of settling and the volume of sludge generated. From
these tests it was determined that a polymer dosage of 2.0 to 4.0 ppm was
the best. To further evaluate the use of polymers, several manufacturers
were investigated. The results indicated that as long as a high molecular
weight am'onic polymer was used good settling could be achieved.
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The main objective of this project was to substantially reduce the
volume of hazardous sludge generated. The next step was to evaluate the
new treatment process to determine if the sludge generation rate could be
reduced without sacrificing treatment. After reviewing the process it was
decided to substitute sodium hydroxide for calcium hydroxide. Another set
of samples were treated as previously described substituting the sodium
hydroxide. The samples were analyzed with the results indicating
acceptable lead treatment and a sludge generation rate 50% less than that
of calcium hydroxide. Magnesium hydroxide was also investigated however
treatment was not as good. Sodium hydroxide was then selected as the
treatment chemical for pH adjustment.
In order to verify this process a series of grab samples were
collected and treated. This time the treated samples were analyzed for
all metals for which NPDES monitoring would be required. The test results
indicated that the treatment process should meet the anticipated NPDES
limits.
Having identified the optimum treatment process the next step was
design development of the treatment system. Collection of the wastewater
was complicated by the fact that the sources were scattered throughout a
500 acre manufacturing facility. It was decided to provide a central
collection point for the wastewater and from there pump it to the
treatment equipment. After evaluating the sources it was determined that
all but one source would require its own pump station. To further
complicate the project, more than half of the piping for the transmission
Of.
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system would have to be above ground requiring the piping to be heat
traced and insulated. Because of the potential of corrosion, 304L
stainless steel was selected for most of the above ground piping. Due to
the presence of chlorides from the copper plating operation, it was
decided to use 316L stainless steel to prevent stress corrosion cracking.
For the underground piping PVC was selected.
Due to the potential for stringent discharge limits for lead it was
decided to solicit proposals from wastewater treatment equipment
manufacturers. Samples of the wastewater along with the expected MPDES
limits were sent to several manufacturers for their evaluation. Only one
manufacturer indicated that their equipment coii'd meet the discharge
limits and were willing to guarantee them with the use of a dual media
pressure filter. The preliminary design was submitted and approval given
for final design.
Upon completion of final design a contractor was selected and
construction began in July, 1987 with plant start-up in October, 1987.
The treatment system consists of the following:
i) Five individual source pump stations
ii) Two main collection pump stations
iii) 9,200 feet of force main
iv) Two 10,000 gallon influent wet wells
v) Chemical feed systems
vi) Wastewater treatment equipment
vii) Sludge dewatering equipment
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The end result of this waste stream segregation project is a reduction
in the volume of hazardous waste generated at the Zone 6 WWTF will from
5,400 yd3 per year to less than 500 yd3 per year. This project coupled
with the belt filter press will result in a 94% reduction in the volume of
hazardous waste generated by 01 in and landfilled in Illinois.
Chemical Fixation
The third major waste minimization project identified by 01 in involves
the installation and operation of a chemical fixation facility that will
convert approximately 1,500 yd3 per year of characteristically hazardous
waste to non-hazardous waste.
This project was initiated in mid-1986 in order to comply with
Section 39(h) of the Illinois Environmental Protection Act which prohibits
the landfill ing of any hazardous waste after January 1, 1987 unless
specific authorization is granted by the Illinois Environmental Protection
Agency. The Agency cannot grant authorization unless the generator of the
waste demonstrates that considering technological feasibility and economic
reasonableness, the waste cannot be recycled for reuse, incinerated, or
chemically, physically, or biologically treated so as to neutralize and
render the waste non-hazardous.
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The hazardous waste streams generated by 01 in that are applicable to
the landfill ban include:
Zone 3 Incinerator Ash - generated by two incinerators that burn
factory trash & certain Special Wastes. The waste heat is converted
into process steam for use in manufacturing. The waste is hazardous
due to EP Toxicity for lead. The source of lead comes from the
contamination of combustible materials throughout the small arms
manufacturing areas at the Main Plant. Lead and/or lead bearing
compounds are used to manufacture lead shot, lead bullets, and
explosives.
There is not enough lead present in this waste to consider recycling.
The only means to render it less hazardous or non-hazardous is to
subject it to chemical fixation.
Zone 3 Baghouse Dust - generated by two baghouses that are used to
control particulate emissions generated by the two Zone 3
Incinerators. The waste is hazardous due to EP Toxicity for lead.
The source of lead is the same as for Zone 3 Incinerator Ash. There
is not enough lead present to consider recycling.
However, about one-third of the dust is lime dust (lime is injected
upstream of the baghouses to control HC1 emissions). 01 in is
considering the reuse of the baghouse dust as a source of lime for
other processes, but if a beneficial reuse of the dust cannot be
found, it will be subjected to chemical fixation.
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Ballistics Sand - generated by the test-firing of projectiles into
bunkers of sand. The waste is hazardous due to EP Toxicity for lead.
The source of lead is the lead bullets and lead shot used to
manufacture small arms ammunition. There is not enough lead present
to consider recycling. 01 in plans to install a screening operation
that will remove the larger pieces of lead and allow the reuse of most
of the sand. However, the non-reusable portion of sand will be
subjected to chemical fixation.
Tumbling Media - generated through the cleaning of certain types of
small arms ammunition. The source of lead is the lead bullets used to
manufacture small arms ammunition. There is not enough lead present
in this waste to consider recycling, however, since most of the waste
is made-up of organic media, incinerating it could substantially
reduce its volume even though it would not render the waste
non-hazardous. In February, 1987, 01 in began incinerating this waste
at the Zone 3 Incinerator facility. Unfortunately, after many
attempts to incinerate this waste over a period of three months, it
became obvious that Tumbling Media could not be treated in this manner
without severely affecting the operation of the incinerators. The
major problem encountered was the melting of the lead contained in the
waste (lead melts at 620°F and the lower chamber temperature in the
incinerator is usually about 1,600°F) as soon as the waste was charged
into the incinerator. The lead clogged the underfire combustion air
vents and quickly shut down the incinerator. For this reason the
Tumbling Media will be subject to chemical fixation.
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To determine the best technology available to chemically fixate EP
Toxic waste, 01 in consulted with several different companies who
commercially offer these types of treatment services as well as searching
through published reports and literature to determine the chemistry
involved with chemical fixation.
It quickly became evident that by mixing EP toxic wastes with Portland
cement and a binder to encapsulate the heavy metals, the wastes could
easily be rendered non-hazardous. 01 in performed its own laboratory tests
upon each of the waste streams to develop the chemical recipes necessary
to make the wastes non-hazardous. Based on the lab tests, 01 in discovered
that all of the wastes could be rendered non-hazardous and disposed of at
a sanitary landfill for less money than it costs right now to send the
untreated waste to a hazardous waste landfill.
This result and the Illinois EPA landfill ban justified monies to
install a chemical fixation pilot plant. The pilot plant began operating
on August 3, 1987 and will operate until the end of November, 1987. The
results obtained from the pilot plant will be used to design a full scale
chemical fixation treatment facility that 01 in plans to put into operation
on or about August 1, 1988. The Illinois EPA has granted 01 in
authorization to continue to landfill its EP Toxic waste untreated until
the treatment facility is put into operation.
Once all three waste minimization projects have been implemented, Olin
will have reduced the generation of hazardous waste at its East Alton, IL
facilities by 95%, or 9,300 yd3 per year.
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Waste Reduction at the Campbell Soup Company
Presented by
Ted Birchmeier, Area Manager
Container Manufacturing
Campbell Soup Company
Camden, New Jersey
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The system that ve had put Into effect worked as follows:
A. Log all material received.
B. Mark each container clearly regarding its contents.
C. Report all activity shipped.
D. Log daily all hazardous waste shipped to storage areas.
E. Audit all areas daily.
That is a simple overview, to actually put it ir.to effect was a task in
itself.
One of the first steps taken to get the system started, was meetings with
the actual people that handle the materials. Once all the input was
gathered we were able to set up our Hazardous Waste System.
All materials received went to a predetermined storage area. We then could
keep track of all incoming materials. Then we had the receiving and
shipping clerk generate a weekly report of all activities. The hazardous
waste that we made could be calculated by the usage of materials received.
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We designated two storage areas to accommodate our hazardous waste. We
collected waste in three 55 gallon drums, one which was marked solvent,
another marked water and the third container marked cleaning material. When
the empty drums were put into the storage areas the date and name tags were
affixed to the drums.
When the drums became filled then the Hazardous Waste stickers were placed
on the side of the drums with the appropriate information, they then were
shipped to the storage area. We shipped out of the plant every 40 days in
which 80 drums were sent to our TSDF (to assure we were in compliance we
would audit the TSDF site twice a year). After inspecting the storage areas
both the shipping clerk and the supervisor would enter their findings In a
daily log book.
In 1984 we started a program to reduce the amount of hazardous waste
generated. We investigated the alternatives to cleaning materials, one of
our suppliers came up with a cleaning material to replace our cleaning
solvent.
Our next project was to find a means of recovering our solvent in the
coating operation. With the aid of our Quality Circle group we found a
recovery system which recovered the solvent at a rate of 8 gallons per hour,
at a cost of $.10 per gallon, the material was 99.5% pure.
A Corporate decision was made to discontinue the manufacturing of containers
at the Camden Plant. We are currently phasing out our hazardous waste area.
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A Waste Audit Workshop for the
Vehicle Maintenance Industry
Presented by
Robert H. Salvesen, Ph.D.
S&D Engineering Services, Inc.
Metuchen, New Jersey
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Hazardous Waste Management Waste Reduction Audit Workshop
Vehicle Maintenance Industry
1. Introduction
This paper will cover the following aspects of the vehicle maintenance
industry.
o Types of oils, solvents and other materials used
o How wastes are generated
o Nature of wastes generated
o Reclamation options
o Waste Reduction Practices and Examples
Proper management of the materials used can result in significant reduction in
the volumes and costs of wastes to be disposed. In order to accomplish these
objectives, it is helpful to get a better understanding of what materials are
used, and handling, treatment, recycling and disposal options that are
available.
2. Types of Oils. Solvents and Other Materials Used
2.1 Oils
The types of oils generated in vehicle maintenance are obviously those
necessary for functioning of the various types of vehicles. These may be
categorized mainly as lubricating, hydraulic and transmission oils. In
addition, some other oils may be generated in large vehicle maintenance
operations, such as cutting and cooling oils. For our purposes today, I would
like to classify these oils by three types:
o Engine Oils
o Non-engine Oils
o Water Soluble Oils (emulsion)
Reasons for these classifications will be evident in the following
discussions, but briefly the lube oils in combustion engines pick up a broader
range of contaminants than the non-combustion engine oils. Water soluble oils
are obviously different.
2.1.1 Engine Oils
Lubricating oils for both gasoline and diesel internal combustion engines are
the major types of oils used. The major differences in these oils are the
type and amounts of additives used. All are available in different viscosity
grades. Most lube oils are made from petroleum and contain hydrocarbons of
various structures. These oils are generally made from either paraffinic or
naphthenic base stocks. Paraffinic oils are composed of straight chain
hydrocarbons, naphthenic oils are mixtures of various cyclic and branched
chain hydrocarbons. Synthetic oils are composed of compounds called esters,
which are generally made from the reaction of organic acids and long chain
alcohols.
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All lube oils contain additives to impart specific properties to the various
oils. The additive materials commonly used include:
o Metallic salts of sulfuric acid (ie) Barium, Calcium salts of organic
sulfonates
o Metallic salts of phenol derivatives and phenyl sulfide derivatives
o Metallic salts of naphthenic and carboxylic acids
o Polymers of methacrylic esters and amides
o Imides of polymeric acids
These additives can be present from 0.1 - 20+ wt. X, depending upon the
severity of the application.
Some of the major differences in lube oils are as follows:
o Gasoline Truck Engine Lubricants - Requires somewhat higher relative
detergency than passenger car lubricants and high viscosity index (VI)
to ensure good cold-starting characteristics.
o Diesel Engine Lubricants - Diesel engines require a relatively high
level of detergency to minimize the effect of soot formation in the
combustion chamber. In addition, the high compression ratio of diesel
engines creates very high piston ring zone temperatures. This requires
lubricants with good oxidation stability (paraffinic-base stock).
Diesel lubricants can use high alkaline detergent additives to
neutralize some of the effects of diesel fuels with relatively high
sulfur content.
o Aviation Piston Engine Lubricants - Aviation piston engines require
very good oxidation stability and high VI. Thus, lubricants for this
service are parrafin-base stocks and usually contain oxidation
inhibitor and dispersant additives.
From the standpoint of reclamation and handling of used petroleum-based
lubricants, the greater the levels of detergents and dispersants, the
greater the tendency of these materials to form emulsions which may be
difficult to treat for water and solids removal. Diesel and heavy-duty
piston engine lubricants may be more of a problem than lubricants for
passenger vehicles.
2.1.2 Non-Engine Oils
Used hydraulic and transmission oils are the major oils in this classification
that are produced in this industry. Hydraulic fluids are either petroleum
based oils or synthetic fluids. The petroleum oils are similar to engine lube
oils, but generally contain less and different additions. Synthetic
hydraulics fluids designated as fire-resistant fluids generally consist of
phosphate-esters, polyglycols, polyolefins, silicones, silicate esters, and
halogenated hydrocarbons such as chlorofluorocarbon polymers, fluoroesters and
blends of these compounds.
These materials can generally be designed (by modification of chemical
structure) to have a broad range of properties without the use of additives.
Chemical complexity and diversity of the above types of used oils sometimes
makes it beneficial to separate these synthetics from petroleum-base used
oils. This is especially true if enough used material is generated to sell to
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a recycler.
2.1.3 Other Oils
This category includes cutting, machine, quench, forging and a wide variety of
neat and emulsified oils. The neat oils can be mixed with other oils and
recycled as described below, but emulsified oils and oil/water emulsions need
to be handled separately. The latter are more difficult to recycle and there
are a number of suppliers who provide equipment for this purpose.
2.2 Solvents
The major solvents generated by the vehicle maintenance industry may be
classified as follows:
o General purpose cleaners
o Carbon removers and paint strippers
o Paint Thinners
o Halogenated Solvents
A discussion of the types of materials used follows.
2.2.1 General Purpose Cleaners
Hydrocarbon solvents are most commonly used for this purpose. They may be
called by different names, but are generally very similar in properties. In
the petroleum industry they an designated as mineral spirits or naphtha.
However, some products may have additives which appeal to individual shops and
are preferred over other products. For example, some products may contain the
following types of additives:
o Detergents - these can provide better penetration of oil and grease on
automotive parts and also allow water washing for cleanup.
o Lanolin - this and other similar additives may be added to leave a
residue on the skin to reduce skin irritation.
o Color and perfumes - to provide a recognizable more attractive product.
There can be some real differences in the basic properties of petroleum
products used for these purposes, however, the industry usually does not
distinguish among them. For example, the higher the aromatic content of the
mineral spirits, the better the solvent power.
Products supplied by service organizations, such as, Safety-Kleen and others
are general purpose hydrocarbon based cleaners.
Other solvents used are noted below along with brief comments:
o High flash naphtha - this is a petroleum hydrocarbon with- a Flash Point
above 140 F to provide an added safety ractor. All petroleum general
purpose cleaners such as those noted above should have a Flash Point of
100 F minimum.
o Odorless solvenc - some shops have been found to use an odorless paint
Uiinner for general purpose cleaning. While this solvent smells nice
and can do a good job, it takes more "elbow grease" to remove oil and
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grease and also costs more.
o Safety solvents - these may be a. High Flash naphtha such as noted
above, or a blend of hydrocarbon and chlorinated (i.e. Methylen^
chloride) or Freon solvents. Such solvents can serve a very us^ 1
purpose, and may be required in some applications. However, so. ents
containing chlorinated or Freon solvents are often not desired for
engine uses because of the concern for corrosion if left in engine
components. Freon solvents are less of a concern than chlorinated
solvents.
2.2.2 Carbon Removers and Paint Strippers
While these products differ in some respects, they are similar in that they
generally contain tt-'o or -nore of the following:
o Hydrocarbons
o Chlorinated solver (generally methylene chloride)
o Phenolic compounds
o Alcohols, esters, etners
o Colors, detergents, and odorants
These are powerful solvents and a wide variety of formulations are available
especially for removal of different types of paint.
2.2.3 Paint Thinners
Industrial operations involving painting use one or more paint thinners.
These materials are formulated specifically for the type of paint used and may
contain onje or more of the following types of materials:
o Hydrocarbons {Mineral Spirits, naphtha, toluene, xylene, etc.)
o Alcohols (Methanol, Ethanol, Isopropanol, etc.)
o Esters (Ethyl acetate, amyl acetate, etc.)
o Ketones (Methyl ethyl ketone, Methyl isobutyl ketone, etc.1
2.2.4 Halogenated Solvents
Halogenated solvents used include a variety of chlorinated solvents and Freon
113. Several popular chlorinated solvents have been designated as potential
carciniogens by EPA and thus the major products still in use are:
o Methylene chloride
o Trichloroethane (TCA)
o Freon 113
Reference has been made above to the use of methylene chloride in cleaners and
strippers. This material and TCA are also used to clean electrical parts.
Freon 113 and TCA are also used for precision cleaning of bearings. The major
benefits of these halogenated solvents are:
o High solvent/cleaning power
o Rapid evaporation rate (low residue)
o Non-flammability
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2.3 Other Materials Used
The other major materials used are antifreeze and water based materials.
There are two types in general usage
2.3.1 Antifreeze
o Ethylene glycol
o Isopropyl alcohol
Except for very low temperature service ethylene glycol is commonly used.
Isopropyl alcohol has very good low temperature properties, but for all year
use, it tends to boil off in wanner weather.
2.3.2 Water Based Materials
The major systems used are:
o Detergents
o Alkaline solutions
A wide variety of detergents can be used for cleaning purposes which generally
contain phosphates and/or organic compounds. These may be used in conjunction
with steam or hot water systems.
Alkaline solutions may contain either sodium hydroxide (caustic soda) or
organic amines. These are generally used to dip tanks and must be handled by
trained personnel since they can cause severe skin burns and are very toxic.
3. Generation and Properties of Used Oils and Solvents
3.1 Used Oils
"Used Oil", as defined by EPA "is petroleum-derived or synthetic oil
including, but not limited to oil which is used as a lubricant, hydraulic
fluid) metalworking fluid, insulating fluid or coolant and which is
contaminated through use or subsequent management." Used oil varies greatly
in its composition, depending on the type of oil, the extent to which it was
used, and the intentional or unintentional addition of other wastes to the
oil. In this industry, used oils are generated mainly from equipment
drainings.
Used oils obviously contain additives originally found in the oils as noted in
Section 2.1 and contaminants picked up in use such as:
o Lead (Fb) from leaded fuels and bearings
o Chromium, Manganese, Iron and other metals from wear of engine parts
o Water from combustion and condensation
o Antifreeze and solvents from leaks and intentional or unintentional
contamination
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Typical used oil compositions are shown in Table 3-1 (1) *
Many used motor oils have low Flash Points due to the presence of unburned
gasoline.
RCRA regulations for burning of used oils are given in Table 3-2.
Metalworking fluids frequently contain higher levels of heavy metals and
chlorinated compounds than do other industrial oils (including hydraulic,
compressor, turbine, and electrical). Many times the roetalworking and
hydraulic oils contain extreme pressure additives which are chlorinated
hydrocarbons. (1)
Hydraulic and transmission oils often have few contaminants. However,
hydraulic systems are often flushed out with halogenated solvents and thus the
used oils may contain as much as 10 - 30 of TCA or Freon 113.
3.2 Used Solvents
Used solvents may be defined as any used organic fluid contaminated as a
result of use for cleaning, thinning, or use as a solvent, antifreeze or
similar purpose. Used solvents are generally volatile in nature. They
include hydrocarbons, halogenated hydrocarbons, oxygenated hydrocarbons and
mixtures of these materials.
Used cleaning solvents are generally produced by spraying* physical or vapor
washing, dipping and other means. Used paint thinners are a special case
since they are produced by cleaning paint equipment rather than from thinning
operations.
Typical properties for used hydrocarbon, TCA and Freon 113 solvents are given
in Tables 3-3, 4 and 5 along with properties of virgin or reclaimed solvents.
Properties for virgin and reclaimed solvents should be essentially the same
and can generally be accomplished with available resources. No properties
are given for paint thinners since reclaimed paint thinners should not be used
as paint thinner. However, the reclaimed thinners can be used for cleaning
paint equipment and no specifications are needed. If it works, OK, but if
not, it should be disposed or reformulated if desired.
* Numbers in parenthesis refer to references given at the end of this paper
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Type
Variable
Table 3-1
Typical Used Oil Composition
Motor Oil (1) Industrial Oil
Value Value
Gravity, °API 24.6
Viscosity/100«F, Centistokes 53.3
Viscosity/21O>F, Centistokes 9.18
Flash Point, F 215
Water (by distillation), Vol. % 4.4
Sulfur, WT X 0.34
Ash, Sulfated or Sulfonated, WTX 1.18
Lead, WTX 0.11
Calcium, WTX 0.17
Zinc, WTX 0.08
Phosphorus, WTX 0.09
Barium, ppm 568
Iron, ppm 356
Vanadium, ppm 5
Arsenic (As), ppm
Cadmium, (Cd), ppm
Chromium, (Cr), ppm
26 - 35
3-25
160 - 240
0.1 - 0.5
0.2 - 1.3
3-5 ppm
<0.5
<0.2
<0.5
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Table 3-2
RCRA Regulations For Used Oils Burned As Fuels
Variable Value
Flash Point, F, mm 100
Metal Content, ppra maximum
As 5
Cd 2
Cr 10
Pb 100
Total Halogens, ppn, maximum* 1000 (rebuttable)
4000 (non rebuttable)
* If the total halogens are in the range 1000 to 4000 ppn and one can prove
that his oil has not been mixed with hazardous waste, then this oil will meet
the on-specification criteria.
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Table 3-3
Typical Properties of Used, Virgin or Reclaimed Hydrocarbon Cleaning SoUent
Properties For
Test Test Method
Flash Point, TCC.F ASTM-D-56
Distillation,F ASTM-D-86
IBP
10X
20X
30X
40X
SOX
60X
70X
SOX
90X
FBP
Residue
Chlorine Content
Water, Oil & SedimentX ASTM-D-95
Appearance Visual
Used
Solvent
< 100- 140
150-330
150-340
170-340
300-345
320-350
325-350
330-370
340-390
350-400
400-600
Above 500
Virgin or
Reclaimed
Hydrocarbon
Solvent
102-110
315-330
320-340
325-350
330-365
350-400
Virgin or
Reclaimed
High Flash
Solvent
140 mm
355-360
360-370
365-380
375-390
415 Max
30 VolX (Max) 2-5 VolX
2-20
Brown/
Black
2-5 VolX
Clear/
White
Clear/
White
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Table 3-4
Typical Properties of Used, Virgin, or Reclaimed TCA Solvent
Properties For
Flash Point, TCC/F
Distillation, F
IBP
SOX
FBP
Residue
Water Content, ppm
Appearance
Specific Gravity
9 25 C
Acid Acceptance No.
rag NaOH
Test Method
ASTMD1310
ASTMD1078
16822A
Visual
ASTMD2111
16822A<«)
Used
Solvent
None
149+
190-
250
500+
10-40*
1-5X
Black
1,15-1.3
Virgin or Reclaimed
Solvent
None
171
190
10 ppm (Max)
100 ppm (Max)
Clear /White
1.317-1.324
0.20 (Min)
(*) Need to check supplier for details of tests to be run and additives
required to reformulate reclaimed solvent.
113
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Table 3-5
Typical Properties For Used and Virgin Freon 113
Properties For
Test Method
Boiling Point,F
Residue
Water Content, ppra
Appearance
Specific Gravity
a 25 C
Acid Number, mg KOH
Particulate Matter
25-100/100 ml
<*)
(*)
Karl Fisher
Visual
ASTMD2111
(*)
(*)
Used
Solvent
104+
20% (max)
1-5X
Brown/Black
1.2-1.565
<0.5
100+
Virgin Solvent
117.6
< 2 ppm
<10 ppm (Max)
Clear/White
1.565
0.003 (Max)
100 (Max)
See DuPont Technical Bulletin for details
114
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Options
4.1 Used Oils
The major options for used oils are on or off-site reclamation. Reclamation
can produce oils mainly for the following purposes:
o Fuel use - most used oils end up as components of fuels
o Original use - extending the life of oils and treating for the original
purpose are mainly appropriate for turbine and some lube oils
o Downgraded use - some synthetic oils, if properly segregated, can be
used as plastic izers
4.2 Used Solvents
Both on and off site options are available for solvent reclamation. The major
options are:
o Distillation on site - this is appropriate for most solvents except
carbon and paint strippers provided the economics can be justified.
o Off site toll recycling - outside contractors will reclaim and return
solvents to the user for a service (toll) charge). This is generally
limited to hydrocarbon solvents and carbon removers. However, these
services are not universally available.
o Off site recycling - outside contractors will buy or accept many but
not all solvents for reclamation. Generally only large volume
generators can be serviced.
4.3 Other Materials
Antifreeze - some industrial concerns are starting to accept antifreeze and
this material is dewatered and burned as fuel.
Aqueous emulsions - high water content emulsions need to be treated to
separate out the oils and grease. The clean water can be discharged to a
sewer (where permitted) and the oil and grease disposed.
Caustics - these materials should be neutralized carefully and treated in an
industrial wastewater treatment plant.
Further details and examples of hazardous waste reduction in management of
used oils and solvents are given in the next section.
5 . liMMmH** Vflflte Red'ytion Practices ftr>d Fy>||iple3
5.1
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.
A standard format is given in Table 5-1 (2). As can to been from the
complexity of the audit form the information needed to do a thorough job can
be extensive. However, in many cases it is quite simple, but it is essential
to know what is being used, how it is used and how are the waste managed.
115
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The benefits of an audit are as follows:
o It requires thought and consideration of current practices
o Materials are identified by chemical types and properties
o Evaluation should reveal opportunities for improvement
o Regulatory deficiencies should be identified
o Corrective actions can be initiated
116
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Table 5-1
Standard Waste Audit Format - Automotive Repairs (2)
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
e
Item Raw Descrip. Hazard ID No. Density Quantity Stor-
Material Clan Ib/gal Used Disposed age
gals/ gals/ Fac.
mo mo gals.
Ex 1 Parts Petroleum Combustible 7 50 50 250
etc. Cleaning Solvent Liquid
Solvent BP 310-3470F
o Raw Material Storage (Complete for each item)
- Raw material (Brand name/common name)
- Item No.
- Volute in Inventory
- Describe usage
- Describe disposal practice
- Describe storage facilities
ie. 55 gal drum
Containers (Volume)
Above or underground tank
Covered/open
Indoor/outdoor
Secured
117
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Table 5-1 - continued
- Delivery system
ie. Gravity
Funnel
Pump
- Material Control Practices
ie. Stockroom attendant
Access (Limited/Unlimited)
Signout sheet
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 (Describe, if yes)
- If no segregation describe practice
- What options are available for segregation
- Storage facilities (describe)
- Disposal practices
ie. On-site recycling
Serviced by Equipment Leasee/Maintenance Contractor
Picked up by contractor
Disposed in Municipal Solid Waste
Disposed to Municipal Sewer
- Disposal Costs
Oils
Solvents
Residues/Sludges
Antifreeze
Aqueous materials
Others
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
118
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5.2 Identifications of Options
Once the audit has been completed, it is necessary to consider what options
for waste management are appropriate. The major areas for consideration are
noted below.
5.2.1 Material Selection
Can other material be found that will reduce the volume and management
problems?
Example - For the Navy, a Flash Point minimum of 140 F is essential for
reclamation as a fuel. By changing from low to high flash cleaning solvent,
the used solvent could be blended with used oils and burned in their
powerhouse. Recycling this solvent was not practical because of the low
volumes and no off-site services were available.
Example - A large repair shop switched from TCA to High Flash Petroleum
solvent because of a concern about the toxicity of TCA. Those operations
involving mechanical equipment favored the change because of the oily film
left on cleaned parts. By contrast, those involving electrical equipment did
not like the change because of the oily residue.
Example - A shop using TCE was convinced by a supplier to change to a
reportedly safer hydrocarbon solvent. The material provided was an odorless
paint thinner which did not have the desired solvent power.
Example - Users of hydrocarbon cleaning solvents are convinced to switch to
detergent formulations for cleaning all types of mechanical and electrical
parts. While the cleaners may perform satisfactorily, the used aqueous
mixture may or may not be legally disposed to the sewer.
Example - Hydrocarbon cleaning solvent is used to clean high precision
bearings. There used product can then b» distributed to less critical parts
cleaning operations.
5.2.2 Segregation
Segregation is probably the single most important and readily manageable
practice which can have a major impact on hazardous waste reduction. Past
practices generally have not mandated segregation so all of us dump into the
nearest waste container and let the disposer handle the wastes. Segregation
is essential to not only proper but any kind of management of all types of
wastes.
Segregation into various types of used oils and solvents is a must to reduce
both costs and problems. Grouping by the following types of materials can be
useful.
o Oils for Fuel Use
This group contains all used oils and solvents with a Flash Point above 140 F,
No halogenated materials are allowed
119
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o Individual Solvents and Oils
Each solvent should be kept separate to optimize the potential for recycling
whenever possible. In cases where disposal options and costs are not affected
by composition, segregation may not be appropriate.
Some oils, especially synthetic lube and fire safe hydraulic oils, if
segregated can be sold for recycling or reuse as plasticizers.
o Low Flash Materials and Mixtures with Halogenated Solvents
Materials with a Flash Point below 100°F and mixtures with halogenated
solvents, especially low volumes are difficult to recycle and dispose.
Generally the generator will have to either avoid these materials or pay the
costs for disposal.
Example - Many automotive shops dispose of solvents and oils in a common
receptacle. The practice generally increases disposal costs. Segregation is
mandated in many areas, but is dependant upon local options.
5.2.3 Recycling
5.2.3.1 Oils
As noted in Section 4.1, recycling of used oils is generally limited to the
following:
o Fuel Use
o Extended life and Lube Oil Recycling
o Downgrading
Examples of Fuel Usage
- Many large industrial operators segregate and collect used oils for in-house
fuel use
- Small generators are usually limited to segregation and disposal to
collectors who blend used oils for fuel use. Costs vary from no charge to
90.25/gal for disposal
- Small used oil burners are available for on site recycling
- Mixtures of fuels, solvents and some chlorinated solvents can be disposed
for use aa fuel for asphalt and cement kilns. Some limits are generally
placed on their composition.
Examples of Extended Life and Lube Oil Recycling
- Used oils from various sources can be processed to extend their useful life.
This is not common practice for engine lube oils. Some hydraulic and many
turbine lube oil users have in-house systems to treat oils. These systems
remove volatiles (water and low boiling hydrocarbons) and solids to clean up
the oils for reuse.
- Lube oil recycling has fluctuated with the price of oil. Recyclers can
handle most engine and industrial oils. Processing generally involves the
following steps:
120
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1. Settling to remove water and solids
2. Fractional distillation to separate low boiling fractions
3. Vacuum distillation to produce lube oil base stocks
4. Treatment of the lube oil fractions (Clay or hydrogen treatment)
The lower boiling fractions are generally used on site for fuel and higher
boiling fractions blended into 12 Fuel Oil. Lube oil fractions, after
treatment, are sold for reformulation.
Examples of Downgrading
Used fire safe hydraulic oils can be sold. Recyclers will take a minimum of
4-6 drum lots containing less than about 2-4% petroleum oils for reprocessing
and sales as plasticizer.
5.2.3.2 Solvents
Options were noted in Section 4.2 and include on and off site recycling.
On-site options require purchase of simple equipment to recycle segregated
solvents. Off-site options include toll recyclers and reprocessors.
o On-site Recycling
Numerous suppliers provide equipment for recycling of almost all solvents.
The equipment does not provide fractionation or separation of solvents.
Equipment sizes range from 5 - 500 gals/day and costs range from $2 - 3,000 on
up. There are two major types of equipment.
- Externally heated vessels with or without vacuum attachments for high
boiling solvents
- Steam injection units where live stream is injected into the solvent and
both are distilled and condensed. This is appropriate only for water
immiscible solvents.
Examples
- A road asphalt supplier used a 5 gal/day still to recycle chlorinated
solvents from laboratory testing operations. This is done to minimize
disposal problems.
- Many firms have in-house solvent stills to recycle solvents such as:
Shipyards - hydrocarbons, Freons, paints
Machine shops - hydrocarbons, TCA
Electrical motor rebuilders - TCA
Ink manufacturers - organic chemicals, etc.
- Hydraulic shops use a stream injection unit to remove TCA from hydraulic
oils. The TCA and oils are recycled.
o Off-site Recycling
Many solvent recyclers are available to handle relatively large generators of
solvents. The National Association of Solvent Recyclers lists 15-20 major .
companies in the eastern US. These firms service a radius of up to about 500
miles.
121
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Toll recyclers provide service to both small and large industries. One
example is Safety-Kleen, others also provide this type service. Toll
recyclers rent the equipment and solvent, when it is dirty the solvent is
replaced and the unit serviced (filter cleaned or replaced). They charge for
this service, but it relieves industries from handling wastes. A major
problem of toll recyclers is that their services are generally limited to
petroleum hydrocarbon cleaning solvents and carburator cleaners. Paint and
halogenated solvents are not generally accepted. However, this nay change as
the industry sees the need.
6. Conclusions
Management of used oils and solvents is becoming more of a necessity and
burden to all. However, it is necessary to protect our environment especially
our water resources. Indescriminant disposal of wastes can no longer be
tolerated. All oils and solvents encountered in visits to hundreds of shops
in this country and overseas have been found to be recyclable. The econonu.cs
and best management practices need to be evaluated generally on a site-by-site
basis in order to select the optimum system. In many locations solvent
recycling equipment can be paid off in 2-10 years depending upon the volumes
and costs of the solvents. At major oil generating facilities, savings have
amounted to hundreds of thousands of dollars per year.
122
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References
1. Kohl, Jerome, et. al. "Managing Used Oils", Industrial Extension Service,
School of Engineering, North Carolina State University, Raleigh, NC
(Mar. 1987)
2. Toy, Wesley M., "Waste Audit Study on Automotive Repairs", report prepared
for the California Department of Health Services, May 1987.
123
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Waste Minimization Program at Union Carbide
by
Ronald Burstein, P.E., CHMM
Staff Environmental Engineer
Union Carbide Corporation
Bound Brook, New Jersey
(Originally Presented at CMA Seminar - November 1987)
-------
WASTE .MINIMIZATION PROGRAM
UNION CARBIDE - BOUND BROOK PLANT
The Union Cacbide Corporation site located in Piscataway. New
Jersey, produces specialty polymers. The site also hosts a major
technical center consisting ot various R&D laboratories and pilot
plants. The site currently has approximately 1200 employees. Due
to the diverse nature ot the site's operations, developing and
implementing an ettective waste minimization plan has been a
challenge. This presentation will tocus on the development of the
waste minimization plan.
As with most plants, the Bound Brook site implemented many waste
minimization projects over the years. As examples, during the 70's
and early 8O's. the plant began using waste steams as boiler fuel.
installed an incinerator and implemented recovery operations for
stillwashes. With the passage of the 1984 RCRA amendments, the
plant formalized its waste minimization efforts and implemented the
tormal corporate-wide program. Various projects were under
consideration in 1986 when the plant tocused on hazardous waste
disposal costs. The 1987 budget process highlighted the dramatic
increase in hazardous waste disposal costs (up over 200%) since 1983
even though the plant was generating significantly less waste in
1987. Plant management challenged the Environmental Protection
Department to develop a comprehensive waste minimization.program to
identity reduction potentials. The steering team and unit audit
teams were tormed. audits were conducted and numerous projects were
identified. The expected benefits (over a two-year period) include
an overall waste reduction of approximately 50* and hazardous waste
disposal cost reductions of approximately 25% to 30%. The
presentation will focus on the various steps of the process
(Formation of Steering Committee. Formation of Unit Teams.
Conducting the Audit. Audit Reporting. Evaluation Process. Tracking
System and Follow-up).
In addition to the RCRA waste minimization requirement, the State of
New Jersey and the local county courts recently adopted more
encompassing recycling requirements. The presentation will briefly
discuss this development and the impact on the site.
124
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RACKGRQUND: HISTORICAL ACTIVITIES
1972/1973 - USE WASTES AS BOILER FUEL
1975 - ELIMINATE HAZARDOUS WASTE LANDFILLING OF LIQUIDS
1976 - INSTALL HW INCINERATOR (R&D)
1978 - USE "SECURE" HW LANDFILLS FOR SOLIDS
1983 - BOILER FUEL "BUBBLE" APPROVED BY NJDEP (NOT
IMPLEMENTED)
1983 - RESIDUE PROJECT TEAM (UTILIZED "WASTE MINIMIZATION
DISPOSAL HIERARCHY)
198<4 - USE HOPE DRUMS FOR HW (REDUCE "METALS")
1985 - "TOLL RECOVER" STILLWASHES
125
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1987 BUDGET
- "STRAW BREAKING THE CAMEL'S BACK"
EP BUDGET (SITE) = $1.600.000
WATER POLLUTION = $500,000
SOLID WASTE (NONHAZARDOUS) = $WO,000
CHEMICAL WASTE (HAZARDOUS) = $700.000
- CHEMICAL WASTE COSTS (ABOVE) JUMP 200% SINCE 1983.
126
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WASTE MINIMIZATION AUDIT PROGRAM - 1987
GOALS:
1. REDUCE EP WASTE-GENERATING BUDGETS BY $100,000. (1987 DOLLARS)
AND
2. PROVIDE STAFF SUPPORT TO OPERATING AREAS TO REDUCE THE QUANTITY
AND/OR TOXICITY OF WASTES AND ASSOCIATED COSTS.
127
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HOW:
1. ESTABLISH HIGH VISIBILITY AND CREDIBILITY BY CREATING WASTE
MINIMIZATION AUDIT TEAMS.
2. CONDUCT AUDITS OF ALL OPERATING AREAS INCLUDING R&D. REVIEWING
METHODS/PRACTICES CREATING WASTES.
3. INCLUDE THE GENERATION AND REDUCTION OF WATER POLLUTION. SOLID
WASTE. AND CHEMICAL WASTE.
128
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WHAT TO DO:
1. CONDUCT ALL AUDITS (7) WITHIN 3 MONTHS.
NOTE: TENTATIVE AUDIT SCHEDULE TO BE ISSUED WITHIN ONE MONTH
FOLLOWING KICK-OFF MEETING.
2. INVESTIGATE SOLID WASTE RECYCLING. I.E.. PAPER, CARDBOARD.
PLASTICS, GLASS, ETC.
3. INVESTIGATE ON-SITE WASTE BURNING.
4. INVESTIGATE RAW MATERIAL USAGE PRACTICES AND DISPOSITION. I.E.
RETURN TO SELLER. USE LESS HAZARDOUS MATERIAL. MAINTAIN LESS
INVENTORY.
129
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ORGANIZATION:
1. SITE EP ENGINEER; CHAIRMAN; EXPERIENCE IN ALL AREAS OF SITE.
2. ENGINEERING MANAGER; DEPARTMENT HEAD REPRESENTATIVE (CAN
COMMUNICATE TO DEPARTMENT HEAD GROUP). AND DELEGATE WORK
ACTIVITY (PROJECT FEASIBILITY) WITHIN ENGINEERING); EXTENSIVE
PRODUCTION BACKGROUND.
3. SUPERVISORY (SHIFT) ORGANIZATION; EXTENSIVE PRODUCTION
EXPERIENCE.
4. EP REPRESENTATIVE FROM LARGEST OPERATING DEPARTMENT; EXTENSIVE
PRODUCTION AND R&D BACKGROUND.
5. EP COORDINATOR AND/OR DAY COORDINATOR OF AUDITED DEPT; ASSIST
TEAM IN REVIEWING SPECIFIC DEPARTMENT'S OPERATION; MUST BE WELL
VERSED IN WASTE-GENERATING PRACTICES.
130
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WHAT TO DO:
5. ISSUE REPORTS FOR EACH AUDIT AFTER U/A WITH RESPONSIBLE MANAGER,
DELINEATING RECOMMENDED WASTE REDUCTION PROGRAMS AND THEIR
POTENTIAL COST AVOIDANCES.
6. ONCE AUDITS ARE PERFORMED, ISSUE QUARTERLY "TRACKING REPORTS"
COMPARING BUDGETED VERSUS ACTUAL WASTE COSTS AND QUANTITIES FOR
DEPARTMENTS. PLANT AND SITE. ISSUE "TRACKING REPORTS" FOR
SPECIFIC RECOMMENDED PROJECTS. I.E.. CAPITAL AND EXPENSE.
131
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1987 CHEMICAL WASTE DISPOSAL:PHENOUCS
2
U
wi
PS
81
o
c
Q.
340
320 -
300 -
28O -
260 -
240 -
220 -
200 -
180 -
160 -
140 -
120 -
100 -
80 -
60 -
40 -
20 -
0
(Includes disposal costs thru 6/3O/87)
ACT YTD
1 i
NO UIN EOY
BUD EOY
i
PCAST EOY
COST SCENARIOS
132
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AUDIT PROCEEDINGS
I. DEVELOP UNIT BASELINE
- USE 1986 GENERATION RATE; DO GENERICALLY.
- USE 1987 ACTUAL WASTE COST PER STREAM
II. PREAUDIT PLANNING
- REVIEW (I)
- UNDERSTAND WASTE GENERATION
III. AUDIT
- PRIORITIZE FROM (II)
- VERBALIZE FINDINGS
IV. POST AUDIT REVIEW OF DRAFT REPORT
V. DEPARTMENT HEAD REVIEW & ACCEPTANCE
VI. ISSUE REPORT
VII. ACTION PLAN AND FOLLOW-UP
133
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FINDINGS
NOTE: FULL IMPLEMENATION COULD TAKE TOP-THREE YEARS
DEPARTMENT
STAFF A
PRODUCTION A
STAFF B
PRODUCTION B
STAFF C
PRODUCTION C
RESEARCH & DEVELOPMENT
TOTAL
MAXIMUM
POTENTIAL
WASTE REDUCTION
MAXIMUM
POTENTIAL
COST REDUCTION (87$'S)
65%
70%
M0%
75%
60%
55%
_55%
60%
$20,000
SMOO.OOO
$15.000
$170,000
$1.500
$100,000
$125.000
$800. 000+
134
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BOUND BROOK SITE
RECYCLING PROGRAM/CHARTER
OBJECTIVE:
IMPLEMENT RECYCLING PROGRAM FOR BOUND BROOK SITE - FOR HIGH-GRADE
PAPER, ALUMINUM CANS, GLASS, NEWSPAPERS/MAGAZINES, AND CORRUGATED
CARDBOARD - BY AUG*UST 1, 1987 (BEGAN JUNE 23RD).
KEY TASKS:
- IDENTIFY QUANTITY AND COMPOSITION OF RECYCLABLE SOLID WASTES
(NEED TO ASSESS THE POTENTIAL RECYCLABILITY OF ALL STREAMS)
- EVALUATE THE LOGISTICS FOR RECYCLING
- ASSESS/ASSURE MARKETS FOR RECYCLABLES
- IMPLEMENT PROGRAM
135
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TEAM COMPOSITION:
STEERING COMMITTEE
- SITE EP ENGINEER. TEAM LEADER
- WASTE MINIMIZATION AUDIT TEAM
- R&O MAINTENANCE DEPARTMENT HEAD
- PURCHASING/MATERIALS MANAGEMENT REPRESENTATIVE
WORKING COMMITTEE (UTILIZE SOME SUPERVISORY AND WAGE PERSONNEL)
- ONE ADDITIONAL R&O REPRESENTATIVE
- OPERATING/STAFF DEPARTMENT REPRESENTATIVES (WASTE
MINIMIZATION REPRESENTATIVES) AND
- CONSULTANT (AD HOC MEMBER) (CRITICAL)
136
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PROGRAM
- SOURCE SEPARATION (BY AREA, BUILDING. FLOOR)
OFFICE PAPER
CORRUGATED CARDBOARD
COMPUTER PAPER
ALUMINUM CANS
GLASS
- USE EXISTING SOLID WASTE EQUIPMENT.
- CONTAINERIZATION OF RECYCLABLES.
- MANPOWER AND LOGISTICS FOR COLLECTION/PICK-UPS
- PUBLICITY.
137
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RESULTS
- ANNUAL COST AVOIDANCE (1987 DOLLARS) OF $120.000!
- OTHERS:
- DECREASED USAGE OF GARBAGE CONTRACTOR,
- DECREASED USAGE OF JANITORS,
- INCREASED EMPLOYEE MORALE.
138
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Union Carbide's Emission Reduction Program
Presented by
Gary M. Whipple
Assistant Director
Chemicals and Plastics Environmental Affairs
Union Carbide Corporation
Danbury, Connecticut
-------
UNION CARBIDE'S EMISSION REDUCTION PROGRAM
by
Gary M.Whipple
Chemicals and Plastics Environmental Affairs
Union Carbide Corporation
Introduction;
Today, I would Like Co snare the results of Union Carbide Chemicals and
Plastics' Emission Reduction Program with you. This program was conceived to
restore confidence in Union Carbide following the Bhopal tragedy and a release
at Institute. The program is designed to achieve a thirty percent reduction
in continuous emissions for each of three years* and a thirty percent
reduction in episodic releases for each of three years. Union Carbide
dedicated SlOOMM of capital, over and above normal expense and capital
programs, to achieve these goals. The work described herein started in
September of 1985, and is expected to continue for at least another eighteen
months.
139
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As you'd expect, ic took considerable time and effort to translate these
goals into a workable program, and to identify the projects that would
maximize emissions reduction and reduce potential episodic releases. I would
like to present an overview of the process used to determine which projects :o
fund, and the results of the program to date.
Discussion!
Program
We were helped considerably in our efforts by Che discussions that led to
the development of the CMA Air Toxics Policy. Union Carbide's policy is
similar to CMA's and was established at about the same time. Union Carbide's
Air Toxic Policy provided a framework that helped move the program forward.
It requires:
0 Accuratet annual air emissions inventories
Identification of possible accidental release scenarios
" Assessment of the impact of releases
0 Corrective actions where appropriate
140
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Having an accurate emissions inventory and a corporate policy helped to focus
first on preventing episodic events that could affect the community or pose
health and safety risks to our employees. The emissions inventory also helped
us establish priorities that put potentially toxic air pollutants ahead of
volatile organic emissions. As part of our SARA Title III reporting, we are
developing an online environmental database that will make it easy and
convenient to update our emissions inventory each year.
Very early in the process, we understood the need to treat routine,
continuous emissions differently from abnormal, episodic emissions. In the
case of continuous emissions, we were striving for reductions of pounds of air
pollutants. In the case of episodic emissions, however, we were trying to
reduce both the number of pounds emitted and the probability of a release.
With episodic emissions, the primary goal is prevention by reducing the
chances of an occurrence; however, the need for mitigation of a potential
event was also considered.
Continuous Emissions)
We began the Continuous Emissions Program by focusing on routine,
continuous emissions such as point sources, secondary emissions, fugitive
emissions, and startups and shutdowns. To help direct efforts; to sources of
hazardous air pollutants, we devised a new index, called an AAPU, or Adjusted
Air Pollutant Unit:
141
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AAPU » Mass Emitted (tons/year)
TLV (rag/m1)
This new index helped us keep score, and ultimately was one of the ways we set
spending priorities to make the most effective use of our funds. As we Look at
Figure , you can see that the AAPU index focused attention on materials
like ethylene oxide, rather than bulk solvents.
Once we had an inventory of all of our continuous emissions, we set out to
determine which had the most significant impact on the surrounding
communities . First, we eliminated any emissions which fell below
predetermined de minimus values based on consideration of a chemical's
toxicity:
TLV, mg/m1 Oeminimus Emission Rate,lb/hr
< S 1.0
6-12 1.5
13-25 3.0
26-50 7.1
51-250 13.0
251-500 65.0
> 500 130.0
142
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We subjected all continuous emissions that exceeded the deminimus values co a
second Level screen, which was a simplified dispersion model:
C - 32 Q tTl<
-------
it was appropriate. Since the second level screening model assumed worst-case
meteorological conditions, the modeling was extremely conservative and
resulted in a number of failures. Of the 1152 continuous emissions first
identified, 675, or 58%, were eliminated by the de minimus criteria from
further consideration. The second level screen reduced the number further co
a total of 8& sources for final action.
Episodic Emissions
We followed a parallel screening effort for episodic emissions like
spills, tank ruptures, relief valve discharges, and rupture disk discharges.
Once again, we began with an inventory x>f possible releases. We defined
episodic emissions as those which result from sudden, accidental releases
which are abnormal and unplanned. In this case, we included releases to the
water and land as well as to the air, while the continuous emissions effort
was limited to air. We included in our criteria the maximum amount of
material that could be released if the release occurred. Reportable episodic
releases met thct criteria:
" a releaae reported to a government agency
144
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needed a refined analysis. The elevated source screening model was a Gaussian
model that calculated maximum ground Level concentrations at the fence Line or
beyond under the worst case combination of wind speed and stability. A
protocol was included to select plume rise (or fall) category based on
apparent initial plume density and discharge orientation. The refined
analysis involved evaluations on a scenario by scenario basis using the best
available tools, including evaporation and flashing models, dense jet and
dense plume models where appropriate. Finally, all the remaining "failures"
were ranked according to the percentage of criteria met. In the case of
episodic emissions, further action, including more analysis or corrective
action was required for all those sources we exceeded lOt of the IOLH.
Results;
The program has so far been successful by several criteria. We exceeded
the 30 per cent reduction per year in continuous emissions that were set as a
goal, acheiving a 36 percent reduction by the end of 1986, and another 27 per
cent reduction forecast by the end of 1987.
With respect to episodes, we have reduced the number of reportables from
361 in 1985 to 248 in 1986, and based on the year to date, we should be down
to 173 by the end of 1987 an almost exactly 30 percent reduction in each
year.
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NJHVRAV 1987 - HAZARDOUS VAS.TEVATER MINIMIZATION
Hazardous Components of Waste
The chemical process industry manufactures a vide variety of synthetic
materials which make it possible for people to feed, clothe, house,
transport, employ, and entertain each other vith less work than would be
required using naturally available materials. Ve take it for granted chac in
the processing of natural materials there are particular components which we
want to use, while other components are inappropriate for the immediate
purpose. The useful components we call raw materials and the others we call
wastes. The same situation applies in the chemical process industry.
Chemical plants start with stable natural minerals such as coal, petroleum,
limestone, salt, and sulfur. These are taken apart and reacted with air and
water to form both the desired useful materials, and byproduct waste
materials for which no significant use is presently available.
"Hazardous waste" is a technical description which is often misused by
nontechnical enthusiasts. A distinction needs to made between ordinary
waste, which can be handled along with regular municipal waste, and special
waste, which requires different handling for safe decontamination. The
description "hazardous waste" should be reserved for those particular special
components which are so difficult to decontaminate that they must be
processed individually and appropriately to assure complete decontamination.
Figure 1 shows some examples of typical liquid wastes which may be hazardous
due to the presence in low concentrations of genuinely hazardous components.
One of the most effective ways of minimizing the generation of hazardous
waste is to change chemical processes so as to avoid diluting toxic
substances with inerts such aa water. This paper will explore the subject of
changing chemical process design to minimize the emission of potentially
hazardous aqueous wastes into land disposal or wastewater treatment plants.
DuFont had a company-wide symposium on waste minimization last year in which
examples of waste minimization were highlighted by more than 60 different
speakers. Figure 2 shows those engineering technologies which I have chosen
to highlight today as examples of waste minimization. I have personally been
involved in one way or another with all of these. You will notice that none
of these are "classical" chemical engine*-ing in the sense of petrochemical
separations, where equipment can be desi id by standardized computer
programs with little need for experience^ consultants. All of these
technologies are still emerging into chemical engineering science. It is
precisely in these frontier areas that many of the opportunities lie which
keep the practice of chemical engineering in the sunrise rather than the
twilight zone of the marketplace.
Crystallization
Crystallization is a good example of one of our old technologies which is
being revitalized a* a result of improving techniques for measuring the
characteristics of ions in solutions and of fine particles in suspensions.
What actually happens is still very much under the control of the kinetics of
several things happening in series, some of which are typically very fast and
some very slow. A solution ready to crystallize can be supersaturated with
respect to several different species at once, and can be encouraged to grow
the desired product by seeding with a small amount of it. The rate of that
growth is also important. In order to control the particle size
distribution, you must control the rate of development of supersaturation to
match the crystal growth rate so that a relatively moderate number of larger
"templated" crystals are produced by precipitation on the seed compared to a
relatively enormous number of tiny uncontrolled crystals.
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NJHVRAV 1987 - HAZARDOUS WASTEWATER MINIMIZATION
Sodium silicate, aluminum sulface, ferric chloride, or potassium permanganate
can all be used to generate charged floes which are appropriate for removing
polar materials which would normally pass through primary treatment to
contaminate biosludge and require expensive tertiary treatment with activated
carbon. Ferric chloride is a particularly apt water treating agent, since ic
is generally a non-prime product from steel or titanium dioxide plants.
Filtration
It is appropriate while discussing primary sludge to move on from the subject
of crystallization to the subject of filtration. Filtration of primary
wastewater treatment sludge to reasonably high percent solids for disposal is
one of the classical chemical engineering challenges. It can be done
successfully provided that careful attention is paid to the fundamentals
controlling fluid flow through a porous medium.
From the beginning it must be recognized that filtration in general is by the
accumulated filter cake rather than the fabric filter support medium. It is
important that the medium be economical, durable, and capable of forming a
good filter cake quickly. Beyond that point all the action is in the filter
cake. It is important that it contain a range of particle sizes, especially
some relatively larger and stronger particles to serve as a porous matrix
through which fluid can flow and within the pores of which the smaller
particles can collect without seriously obstructing flow. It is helpful when
the environment is strongly ionic so as to minimize the degree of hydration
of the finer particles and therefore permit forming a dryer cake.
Lime is typically used as a primary treating agent for wastewater. It is
well suited for that purpose since it generally does not dissolve completely,
but tends to dissolve with precipitation of solids like calcium sulfate or
hydrated iron oxide as a skin on the residual kernal of lime. Permeability
of the resulting filter cake is much better than it would be without the
matrix of lime kernels. Oewatered primary sludge is ordinarily disposed of
to a landfill; where it contains high concentrations of lime or of organics
it can be appropriate to incinerate it, as will be discussed later.
Another type of filtration which can be appropriate for waste minimization is
the polishing removal of fine suspended solids by filtration through a deep
bed of fine fibers or granular solids. That is similar to the treatment of
potable water, where water after primary treatment to remove suspended solids
is filtered through beds of sand to remove all remaining solids including
bacteria. The difference in using deepbed filtration for waste minimization
is that typically the flows are small, the solids are sticky, the filtrate is
to be recycled, and the filter medium cannot be reused but itself becomes a
waste. Polypropylene fiber mats and pellet beds are particularly
appropriate, since they are resistant to most chemicals and are easily
incinerated. Beds of polypropylene "sand" in the ten micron size range, for
instance, are well suited for removal of heavy metal hydrated oxide slimes
from hydrochloric acid recovered from the incineration of chlorocarbons.
Adsorption
One of the principle sources of sticky solids in recovered hydrochloric acid
is traces of calcium and magnesium chloride which get into incinerator offgas
and come over into the scrubbing system as slowly soluble sticky oxychloride.
One of the ways to minimize such carryover is to use liquid/liquid adsorption
to remove hazardous chlorocarbons from wastewater and eliminate the need to
decontaminate the entire wastewater steam by incineration. That is
particularly effective when carried out before discharge of the strong
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NJHVRAtf 1987 - HAZARDOUS WASTEWATER MINIMIZATION
itself by stages from the liquid outlet (weakest solution) to the liquid
inlet (strongest solution). This is particularly good when dealing with high
concentrations of material which would require frequent regeneration.
Permeation represents another approach to that sort of problem. It is the
application of the scientific principle of reverse osmosis. Osmosis of
course is the diffusion of solvent (usually water) through a membrane from a
weaker to a stronger solution. The concentration gradient is the driving
force. Reverse osmosis causes solvent to move from a stronger to a weaker
solution under the influence of some other driving force strong enough to
overcome the concentration driving force. That would typically be either
hydrostatic pressure or electrostatic field. There will obviously be a
tradeoff between flux rate and selectivity, with membranes capable of
generating purer solvent having lower capacity per unit area.
Reverse osmosis systems are perhaps best known for their capability of
producing good quality drinking water from brackish or saline water sources.
They are a cost-effective alternative to expensive distillation. They are
especially effective in pretreatment of water to be deionized as feedwater
for boilers or plating rinsewater, since by removing the bulk of soluble
salts before ion exchange they minimise the amount of strong regenerant
chemical solutions which must otherwise be treated for disposal.
Azeotropic Distillation
There are times when classical distillation is the appropriate technology.
That is particularly true when it is only necessary to remove a relatively
small amount of material, for instance water formed by the nitration of
organic materials. Ordinarily it would be necessary co purge a large amount
of mixed acid in order maintain its strength. It would typically be bucked
up by stripping with hot dry combustion gases. A different approach would be
to avoid the need to remove wet acid from the system at all, by stripping off
water as fast as it forms with hot dry organic vapors. This azeotropic
distillation is the equivalent of steam distillation, but in reverse. It is
energy efficient since most organics have relatively low heat of vaporization
compared to the energy losses in conventional acid strippers.
Waste Acid Incineration
Acid which has been contaminated with high boilers must be regenerated by
incineration back to sulfur dioxide gas which can be used to make fresh acid
to be recycled back into the process. Conventional spent acid regeneration
plants require more heat input than is possible burning spent acid alone,
therefore must produce more acid than they recycle. Finding a market for
that acid these days may not be easy, since most customers are only
interested in buying acid which you are willing to take back for regeneration
or disposal after they are finished using it. We are presently involved with
several patented developments which make it possible to minimize both the
amount of new acid which must be disposed of from a spent plant and also the
amount of purge acid required to flush out ash coming in with the feed.
The key to minimizing new acid is to reduce the influx of inerts into the
system. That is accomplished in practice by using oxygen enriched combustion
air, by controlling oxygen leaving the spent furnace to unusually low
levels, and by taking advantage of all opportunities for heat recovery. Fast
measurement and precise feedback control of oxygen is particularly critical.
since spent acid sludge can vary from almost pure acid to almost pure organic
in a matter of moments.
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Union Carbide's Emission Reduction Program
Presented by
Gary M. Whipple
Assistant Director
Chemicals and Plastics Environmental Affairs
Union Carbide Corporation
Danbury, Connecticut
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NJHVRAtf L937 - HAZARDOUS VASTEVATER MINIMIZATION
FIGURE ONE
TYPICAL POTENTIALLY HAZARDOUS LIQUID WASTES
* USED CRANKCASE OIL FROM MOTOR VEHICLES
* SPENT CUTTING OIL EMULSIONS FROM METAL MACHINING
* METAL-FINISHING WASTE (SPENT PICKLE, PLATING BATH, RINSEWATER)
* WASTEWATER FROM MANUFACTURE OF INORGANIC COMPOUNDS
* WASTEWATER FROM MANUFACTURE OF ORGANIC COMPOUNDS
* SPENT MIXED ACID FROM NITRATION OF ORGANIC COMPOUNDS
* SPENT SULFURIC ACID CATALYST FROM PETROLEUM PROCESSING
* HIGH BOILERS FROM PURIFICATION OF PETROCHEMICALS
* HIGH BOILERS FROM PURIFICATION OF CHLOROCARBONS
FIGURE TWO"
PROCESS MODIFICATIONS TO MINIMIZE WASTEWATER EMISSIONS
DECONTAMINATION BY SEPARATION OF HAZARDOUS COMPONENTS FROM WATER:
* CRYSTALLIZATION
* FILTRATION
* ADSORPTION
* ION EXCHANGE
* PERMEATION
DECONTAMINATION BY SEPARATION OF WATER FROM HAZARDOUS COMPONENTS:
* AZEOTROPIC DISTILLATION
* WASTE ACID INCINERATION
* DRY SCRUBBING
* SPRAY DRYING
* SLUDGE INCINERATION
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WASTE REDUCTION AT A PAINT PLANT
AN OE APPROACH
Waste reduction or minimization is not a new objective. Re-
duction of cost by eliminating unwanted and unneeded waste is an
economic goal long pursued by process engineers. We all know that
less waste means higher yields, which in turn results in lower
unit costs and ultimately more earnings for the innovative firm.
In addition to the dollar value in increased yields, the foregone
waste management costs for treatment and disposal compound the
economic return of minimization efforts. Concurrently, we are all
well aware that the 1984 RCRA Amendments made instituting a waste
minimization program a regulatory requirement.
Thus, we can see that there are dual driving forces to
encourage establishment of such programs in any operation that
creates waste especially hazardous waste. The initiator of any
one waste reduction program can come from one of three directions:
- Desire to increase yields to bolster profits
- Need to make less of a waste that is particularly
difficult or expensive to dispose of
- Direct effort to reduce waste generation
The result can be the same in terms of cost improvement and waste
reduction regardless of the initial impetus. A waste minimiza-
tion program can make use of efforts driven by any or all of the
three motivators.
In plants where OE, or Organizational Effectiveness, is an
active philosophy, participation is a key word. There is no
better arena to employ OE techniques of involvement than in waste
minimization! Waste is not generated by the plant manager! He may
dictate or encourage such a program, but to increase the
effectiveness of waste reduction, one MOST INVOLVE the workers
who actually generate the waste. Of course, process engineers and
line supervision especially first line must be on the team
to provide technical expertise and action for implementation.
I would like to discuss an success story in one of our paint
plants and give recognition to the site environmental coordina-
tor, John Lang, as the spark that got this program underway. We
had initiated some yield improvement programs through the techni-
cal organization prior to John's approach with some success. The
best example was a division-wide implementation of product line
"pigging*. For those of you unfamiliar with this technique, it
involves pushing a flexible plastic "pig* or bullet through pipe
lines containing paint with nitrogen gas pressure. Paint normally
left for the washing procedure is pushed out ahead of the pig and
packaged resulting in a yield improvement AND a reduction in
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established as something really not part of doing
business today and thus directly eliminated??
- Establish changes in processes and procedures to get
the waste generation down. Be sure to watch for
the interaction with your changes some might
increase waste somewhere else OR create more re-
duction in a synergistic manner!
- Review any new process, new equipment project or
operating changes BEFORE line organization
approval to obtain the HWM Committee approval.
The HWM Committee met every week at the beginning. After several
months they reduced their meetings to monthly and occasionally
less frequently. There were instances where the operators
involvement was so intense that they came to meetings on their
own time because they were on shifts!
Emphasis was placed on a blend of the operators' experience
and the process engineer's expertise and investigative skills.
For instance, as they worked together to reduce waste and improve
yields, the engineer naturally looked at the equipment and
process with quality in mind. The operators looked more at pro-
cedures and Area Operating Procedures. But, by communicating and
interacting, this blend focused on areas of opportunity. At the
same time, because their mission was widely publicized, there was
an influx of suggestions from other site personnel.
Their first task was to communicate to the entire site the
importance of waste Minimization and publicize the cost of HW
disposal for the plant. Crew meetings were held everywhere in an
effort to inform and raise awareness. Special meetings were held
with the engineers to bring their awareness of their potential
contribution in the area of process, procedure and equipment im-
provements. And after the program was underway, spot checks were
made by the Committee to identify obvious wasteful operations.
Their second task was to create an accurate inventory of
which wastes were generated by which operations. To get the
needed handle on this, a site-wide waste container marking
program was instituted by area. This was necessary because more
than one area generated some waste of the same characterization.
An example would be spent wash solvent.
After a careful and thorough listing of every waste generat-
ed at the plant, they were ready to start evaluating sources.
One of the most obvious waste stream to focus on was the paint
filter cartridges used on the filling floor. This plant produces
automobile refinish lacquers and enamels, which require extremely
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good filtration to yield grit-free, high gloss products. Often
the filtration step is the limiting factor in packaging rates
because the filling machines can easily pump paint into cans
faster than it can be pushed through the cartridges.
coincidently, a technical task force had been established to
improve filtration quality called the "Grit Group"! Can you
imagine the concern the HWMC had when appraised of this effort?
Of course, to improve quality, this group would most likely make
recommendations that would INCREASE filter usage in the name of
QUALITY!!
Well, the benefits of communication and cooperation were demon-
strated by the Grit Group and the HWM Committee working closely
together. Grit was reduced and 50 percent fewer paint contamina-
ted filters were generated! This was a resounding victory for
both groups. Whoa, you say how did they get to this
result?
The first step of investigating the WHY questions was to
look at past practices by the combined group. Let me give you
some of the historical background so that you might appreciate
the approach and technique the committee used.
- When a completed batch of paint was OK'd by the quality
control lab, a filter setup was prepared by starting
with a relatively porous cartridge (150 micron) because
this would allow the fastest and most productive
filling out of the batch.
- A gallon or so of paint was run through the filter and
lines; a sample was taken and submitted to the lab for
a grit and fineness check. The lab entered the filter
rating and the check results on the test card under the
paint formula in process.
- Should the fineness/filter check fail to produce the
specified quality, a recommendation for a finer car-
tridge would be transmitted to the filling floor.
- This procedure would be repeated until the filtered paint
was of the grit free quality needed for our customers.
It was then filled our into the specified containers.
Some members of the committee felt that the "false starts* from
trying coarser filters first might be counterproductive. A
detailed review of the history cards in the quality control lab
by the process engineer revealed a startling fact! A majority of
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the batches of the formulas with grit problems eventually needed
a 250 micron filter to get the desired quality. Filter specifica-
tions on the batch cards were changed to START with 250 microns
on those product lines. Results:
1. ~"*lity was consistently higher for grit.
2. -/entually 50 % fewer cartridges were used (all 250 m.)
which translated into 50 % less volume in this waste
stream.
3. Cost savings for the filters not used and the extra
samples not taken increasing yields.
4. Corollary waste reduction: lab waste stream down as
fewer samples were submitted.
5. Corollary cost savings: less lab time spent per
batch and less setup time by the filling line crew.
Tine lost in flow through the finer filters was more
than made up for by less changing time!
This may not seem like much per batch, but the leverage was felt
day in and day put over many batches. The second most significant
achievement was* the waste reduction. The most important was the
proof that, after identification of the waste source needing
scrutiny, a thorough questioning of WHY resulted in very positive
waste reductions. The HWM Committee's process was working!!
Successes were publicized widely around the plant. Sugges-
tions starting rolling in from all quarters!! Engineers were
carefully screening present processes and scrutinizing future
projects.
The next major waste stream to receive focus was the largest
one of all: spent wash solvent. Quality efforts over the years
had always stressed cleanliness between batches. The traditional
approach was to use more solvent to 'ensure* cleanliness. After
all, wasn't the solvent recycled by distillation for reuse as
wash solvent! Tank washing including the lines to and the
filling machines was creating nearly 90 % of the hazardous
waste. Another truism was established: go after some of the big
streams where a one percent reduction is significant -in pounds.
A thorough study of the operation of the "Rotojets" that had
been permanently installed in every tank was undertaken. The
habits of operators doing the cleaning between batches were care-
fully analyzed. The results again were somewhat astounding: there
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was no specific time to run the jets solvent valves were just
opened and away they went until the operator finished whatever
task he was working on in the meantime. They always gave the
tanks a "good" cleaning -- but at what cost in quantity of wash
solvent used. Of course the assumption that it was recycled for
use again was also a false couifort, since the best yields ever
attained on the plant thin-film evaporator were never 100 %.
How did they get at this unrestrained practice? The HWM
Committee recommended a timer and solenoid valve be installed on
each 'Rotojet" solvent feed line. The timers could be set for 5
minutes or 2 minutes. The AOP was rewritten to specify a 5
minute wash to start followed by inspection and then subsequent
2 minutes washes and inspections until the desired degree of
cleanliness was attained. Note that if an operator was tied up
with other tasks, no large excesses of solvent would be sprayed
in the tank. With extensive, uncontrolled sprayings no longer the
norm, some standards for determining when the tanks were clean
needed to be put in the AOP on cleaning. Concurrent with mixing
tank cleaning, the lines, hoppers, filter casings, vibrating
screens, and filling machines were washed in series with the same
solvent fed by gravity. The committee developed a basic premise
hardly revolutionary that if the wash solvent started to
come out clean from the filling equipment after some number of
timed jet spray cycles upstairs, then the tank must be clean. But
how do you communicate the cleanliness check without running up
and down stairs or running too many cycles. Easy! Have the
operator upstairs check with the filling floor operator by
hand-held radios. Of course, as you might imagine, a whole new
era of communication developed quickly between the floors and
productivity flourished (using waste minimization justified
radios!).
With the total volume of wash solvent reduced I can't
give you a percentage yet as this system is still being fine
tuned the HWM Committee turned to look at the solvent
recovery process. The still bottoms from wash solvent recovery
remained the main waste stream of the plant. Using the thin-film
evapora-
tor with high pressure steam and vacuum, the still bottoms had
traditionally been concentrated to 70 % and solidified upon cool-
ing. At this recovery percentage, the engineers were sure they
were creating the minimum amount of still bottoms.These "blobs"
of resin, pigment, and some high boiling solvents, plasticizers,
etc. were packaged in lined cardboard drums and incinerated in
rotary kilns at RCRA facilities.
A look at alternatives and process balancing at the solvent
recovery operation by the Committee with some extra engineering
help revealed an interesting option. The optimum solids level was
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established at 30-40 % so as to keep the still bottoms pumpable.
The outlet selected now was a fuels program for cement kilns.
Ah, you say, "That increased the waste generated and reduced the
amount of recycled wash solvent." Not all bad though. When the
higher boiling solvents were left in the still bottoms, the
resultant recycled wash was much more effective in cleaning the
tanks, lines, and filling machines. This is due to the higher
solvency of the "active" solvents such as the ketones and
esters and a higher percentage of toluene and xylene in the
wash. This effect, of course, will vary with the paint/lacquer
formulations you might be manufacturing. Guess what synergistic
effect this change in wash solvent composition had? Fewer number
of "Rotojet" cycles were needed with the better solvency wash!
A further waste reduction! A collorary benefit was substantially
lower disposal costs even for a somewhat larger volume of
still bottoms due to the fuels program costs being so much
lower than rotary kiln incineration. Remember, the second part of
the RCRA waste minimization requirements is to select the treat-
ment/disposal method that reduces the toxic impact on human
health and the environment. The still bottoms are exposed to
higher temperatures and usually longer dwell times in most
cement kilns than is required in RCRA incinerators and the inor-
ganic pigments are captured with the cement product the
ultimate encapsulation.
There are two other waste streams that have been success-
fully reduced by the Committee efforts. Pigments have been tradi-
tionally package in fifty pound paper bags. Lead chromate bags
have been a waste problem with potential EP Toxicity and risk of
unacceptable health exposures to handlers. Traditionally, exhaust
systems have been designed to remove the dusts involved from the
operators work area. The dust collectors on these systems yield a
hazardous waste when they are emptied if you consume enough lead
chromate (and other chromates). By switching to bulk titanium
dioxide and returnable, reusable air pallet bags, the plant was
able to halve their pigment dust and lead chromate bag waste
streams.
The last investigative approach from the plant that I will
mention is to look at similar or identical operations and ensure
they are all running the same for instance, are the three
parallel and identical pint/quart filling lines producing about
the same amount of waste? Are all three operators following the
AOP's that yield the least amount of waste? Of course-, such an
evaluation must consider other operating parameters such as
quality and productivity when making judgements.
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Some of the ideas for waste reduction come from outside the
plant but need plant people to participate in divisional or
departmental projects to reduce waste. Another waste stream that
was identified as significant to the entire department was the
discontinued finished product stock. This was mostly in the
control of marketing, but site stock control personnel joined
with stock analysts at department level to attack this problem.
The result is a new "leveling" computer program to start up in
early 1988 which will search for stockkeeping units at 2 plants
and 27 warehouses for transfer before asking for another batch
to be made as the product movement slows or it approaches time of
obsolescence. Transportation costs for shuffling finished product
are becoming insignificant when compared to Hazardous Waste
disposal costs. Reworking of obsolete products into newer ones is
also being actively pursued by an inter-plant team.
In summary, the approach of the Moberly, MO plant designed
by John Lang, was to assemble a team with a wide variety of
skills and experiences to foster as wide an involvement of site
personnel as possible in the waste reduction effort. This
Hazardous Waste MANAGEMENT Committee has been very effective in
motivating the entire plant. Waste disposal costs were widely
publicized, as were successful waste reduction efforts. Using OE
frameworks, they established a communication and training program
to foster participation site wide. Their program was simple:
- Identify all waste streams
- Identify WHY this waste is generated
- Identify and implement process, equipment and procedural
changes to reduce the waste
- Review all on-going changes in the plant to discover ways
to reduce waste or to prevent adoption of changes that
would increase waste generation
This OE approach did get the involvement and participation it was
designed to obtain.
R. A. Mead
E. I. du Pont de Nemours and Company
Wilmington, DE 19898
October 8, 1987
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Waste Reduction in the Paint Application Industry
Presented by
Herbert S. Skovronek, Ph.D.
Environmental Services
Morris Plains, New Jersey
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PAINT-APPLICATION: WASTE MANAGEMENT
by
Herbert S. Skovronek
ENVIRONMENTAL SERVICES
In 1986, 967 million gallons of paints and coatings were shipped by the US
coatings industry according to Chemical & Engineering News. If we
conservatively say that these coatings contain approximately 501 solvents
and other volatile materials, and if we recognize that the application and
curing of these coatings occurs with the loss of all of those solvents by
evaporation, we have put almost 0.5 billion gallons, or 500 million
gallons, or 4 BILLION pounds of solvents into the air. Certainly, some of
today's coatings contain much more than 50% solids and some of the
solvents are non-hazardous while an increasing portion contain water.
And, it is certainly true that some portion of the hazardous solvents are
trapped, collected, or treated in some way, nevertheless, the conclusion
remains quite clear that the use of coatings currently puts a great deal
of undesirable pollutants into the atmosphere. The scenario with other
components may, on a global basis, be less overwhelming since the
non-volatile components tend to remain on the substrate to which they are
applied, but still can reach high levels. For example, while only 101 of
the solids may be lost as overspray or other production losses, and 90% of
those solids may be trapped in some fashion, this still suggests that 40
million pounds of paint solids are lost directly. In addition, many of
the coated substrates ultimately are disposed of, leading, potentially to
downstream pollution, either through corrosion/erosion or as incinerator
ash or landfill runoff.
But, perhaps it is best to first look at the sources and the means of
controlling many of the losses at these sources -- at least for those that
are controllable. I will try to devote this presentation to the
opportunities that exist in the application sector for controlling and
minimizing waste generation and discharge.
The idea of waste minimization appears to be relatively new. However, I
find this somewhat surprising since it always seemed to be good
engineering practice to look at all aspects of a problem and all means of
preventing ultimate environmental insult. This means examining the total
scenario and considering all methods of minimizing waste. For example,
while my colleague may not appreciate it, one alternative that must be
considered iss "why paint?" Bear in mind that you, the fabricator, may
not want to be a painter.
In any review or audit of a waste generation/control problem, there are
several questions or basic groundrules that need to be examined. These
include:
a. Know what you've got
b. Know where it's going
c. Know if where it's going is socially acceptable
d. Look at the costs (all!) for the current practice
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e. Don't just Look at the waste, but look at the whole operation/
process/sequence.
To try to generalize, we might have the following scenario:
I sell widgets that need to be protected from certain exposure. That
might be refrigerators, bridges, home siding, automobiles or safety
lines down a highway.
Traditionally, 1 have used paint, in its most generic fora, to do
these jobs. To do this I have purchased a product to certain
specifications, made color adjustments and dilutions with solvents,
and applied the modified product to my substrate by brush, dipping,
spraying, or some modification of these techniques and "curing" the
product coating by heat, time, or some other technique. Before I
applied the coating I may also have prepared my substrate by sanding,
degreasing, etching or priming. As part of my quality control, I
invariably have had some losses due to unacceptable quality,
substrates that either had to be discarded or reprocessed by touchup
or stripping and recoating.
What are my wastes along the way? Depending on my operation, they might
incl .e dusts and solvents from preparation, excess or off-specification
coating materials and container "stickage", equipment cleanup wastes,
drippage or overspray, solvent emissions during drying and curing and
paint stripper wastes or decomposed or dissolved coating materials from
reprocessing. In addition, there probably also are secondary wastes from
maintenance opeationa and from ongoing environmental efforts (e.g., loaded
filters). In moat operations, the two largest waatestreams would be
paint-contaminated thinner (equipment cleaning) and solvents lost during
application. Clearly, then, these are the primary targets, although other
"opportunities" should not be ignored.
In trying to get control of the overall or total process, it is necessary
to examine - in detail -- all aspects and all steps in the operation. In
many cases, such an analysis will uncover inefficiencies that have crept
into the operation in spite of management's best intentions. These are
moat easily corrected and can have a major impact on material use (and
cost) and, ultimately, on waste generated. Some examples along this line
might include:
* gradually Increasing the volume of coating product purchased to be
snre that there is enough for the Job;
* decreased filter efficiency as filter life is extended because of
the coat or the inconvenience of replacement;
* increased application rates to assure coverage; and
* poor housekeeping and equipment maintenance.
Even before correcting such oroblens, we need to go back and ask ourselves
some basic questions. For \mple:
Is a coating needed?
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Can another coating/protection system be used? In many architectural
areas, protective synthetic coatings (paint) have been replaced by
what I call "pre-rusting". What about good old galvanizing?
Can the part be made from a different material? Plastic may be
"better" and may even allow incorporation of color. Maybe the
stainless steel or fibreglass car body isn't that bad an idea when
you look at all the costs involved in painting a car. (Of course,
alternate materials of fabrication may present their own
environmental problems.)
But, let's assume that we conclude that a paint coating on an existing
substrate is necessary. What economies can be achieved by limiting the
options I offer my customers (do I really need fire engines in red, orange
and yellow?) Limiting my colors (or other properties) reduces my
inventory (and eventual coating wastes), reduces my cleanup frequency, my
cleanup wastes, my lost production time, and simplifies my scheduling
woea. If I look at all costs, perhaps I'm better off offering only the
highest of my quality options, even if the preliminary cost seems to be
higher until I consider all the factors and MARKET the high quality.
Finally, if I must offer or have available a range of colors or
properties, an I better off buying painta to those specifications or
should I develop my own color matching capability that allows me to reduce
waste (wrong colors, excess supply, etc.)* Does ready availability of
colors improve my ability to schedule my operations and thus, again,
reduce my cleanup problems?
Often, offering a wide range of services or products complicates my
business more than it's really worth. Careful, hard business analysis may
show that becoming a specialist in one phase of the business may allow me
to do a better Job in that area while minimising my peripheral problems
such as inventory and waste management. If I must service my customers
with variety, perhaps I can make an arrangement with a (friendly)
competitor so that I do all the red work and he does all the green work?
Perhaps the next question to consider is what sort of application do I
need to use: dip, spray, or brush, each with its own sub-options?
Realistically, most commercial application today probably is either by dip
coating or by spray application. Both offer environmental opportunities
and present environmental problems that need to be considered as part of
the operational and coat analysis. While this question may have been
answered when you opened your door for business several years ago, has
your business - or your problems changed enough since then that a
revaluation is warranted even if it means a major capital expenditure
in the near future. Certainly energy, environmental and employee health
questions have changed over the past several years.
Let's look more closely at spray painting as an example of how decisions
may need to be made. A similar scenario can be developed for dip coating
or others. We'll assume that decisions have already been made that (a)
the substrate is unalterable; (b) a coating is needed; and (c) spray
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application la the moat efficient means of achieving the needed coverage.
We've recognized that some fora of spray booth la going to be needed to
contain the overspray and fumes, provide an OSHA-complylng workplace --
and keep out quality-damaging duat from other operations. Today, energy
considerations also need to be a major factor in how you schedule your u«e
of that booth and, perhaps in the products you select as your baalc
coating system. Unfortunately, energy cost has become a very volatile and
uncertain question, depending on the mid-east status at the moment. And,
since moat coatings are derived from petroleum products and use energy for
curing, petroleum cost impacts is at least tvo ways. Employee health
considerations are becoming another major Issue, again mandating an
efficient, pollutant free work environment achievable by Increased
ventilation or a change In products used. But, while OSHA says get It
out of the shop, EPA says don't put It Into the outside environment.
Such factors are forcing manufacturers (fabricators/finishers) to look at
nev options in coating systems (In the broadest definition of "system").
Today, alternate systems range from waterborne coatings to high solids
coatings and powder coatings. These newer systems tend to minimize or
eliminate the environmental, health and fire problems related to solvent
emissions and may also have other advantagea such as the ability to
recover end recycle overspray (powder coatings). However, these benefits
do come at various costa; products may be alower or require more energy to
cure, more sophisticated air handling systems may be needed to assure dust
free atmospheres, totally new equipment may be needed (powder coating) and
new hazards such as dust explosions need to be addressed. For example, and
in spite of the foregoing comments, one firm, Bergstrom Manufacturing,
reduced labor and material cost by going to a poweder coeting system.
Energy requirements for exhaust air was also reduced by 901 and that
required for curing was reduced by 501. Another, Steelcase, reported a
401 reduction in VOC emissions by going to a hi-solida coeting and Stanley
Works experienced an 871 drop in emissions by changes including a shift to
a dip coeting with e water based coating for shelf brackets.
With nev coating systems also have come new curing techniques that offer
benefits end problems that need to be considered. Radiation curing with
ultraviolet light or electron beams is an exciting new opportunity to
reduce energy requirements and volatile organic emissions, but, at
present, such systems may require redesign of substrates since they only
work on thin coating* end for "line of sight" coeting. The; latter
technique also requires an inert atmosphere to prevent "poisoning" of the
curing mechanism by oxygen.
But, let's go back to the conventional spray coating systems that most
firms are still using. What are its problems and what can be done within
the system to minimize these problems or their effects? Whether it's en
auto body shop or a fabricator painting medicine cabinets, the problems
tend to be similar: Volatile organic solvents lost during application and
curing and paint soli') lost as overspray during application. If we look
at a typical small br up-to-date body shop we probably are applying leas
than 2 gallons of pal - coating materials per day. These materials are
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diluted for application with approximately an equal volume of thinner,
i.e., another 2 gallons. The shop haa a spray booth, probably installed
within the last fev years to meet employee health, product quality and
fire regulations -- at a cost of between 120000 and $30000! Vhen one sits
down to develop the air permit for the stack from such a facility, one
finds:
Material use: 2 gallons paint at 50% solids/50% VOCs or, at 8
Ib/gal, approximately 8 Ibs solids and 8 Iba thinner.
2 gallons of thinner at 1001 VOCs or, at 8 Ib/gal,
approximately 16 Ibs of thinner.
Overspray estimated at 101
Booth filter capture 901 of overspray solids
Emissions: Solids: 8 Ibs x 101 overspray x 101 loss -0.08
Ib/day.
VOCa: 8 Ib(paint) -I- 16 Ib(thinner) x 100% loss 24
Ib/day.
While these numbers are very approximate, they probably are "fair";
overapray may be greater than 101 but filter capture should be better than
901. (An article describing an alternate technique for pressure spraying
suggests that conventional high pressure (60-90 pel) guns produce as much
as 60-651 overspray (WASTE!) while newer, low pressure guns (1-3 psi) can
reduce overspray to less than 201.) At this time I know of no practical
control system for the VOCs from a small facility's spray booth. One
could say that 24 Ibs of VOC are "de minimus"... at least until we realize
that there are about 2000 such shops in New Jersey, with a high
concentration in the very urban areas that are of moat concern for their
VOC emissions. In addition, bear in mind that this is a 10 billion dollar
business (collision and repair) that used 66 million gallons of paint in
1986!
What can such a shop do? The paint manufacturers, while seeing the need
for improved VOC control coming, are the first to admit that alternate,
less polluting systems such as waterbased coating systems for refinishing
are several years away - at least - even though they are now finding use
in manufacturing plants. There are condensation, carbon adsorption, and
incineration system* available for the large user, but these systems are
not practical nor coat-effective for small facilities at capital costs of
150000 and up. There is limited availability of carbon filters for such
systems, but little evidence that they can do more than cosmetic cleanup
of VOCa from such installations (collecting 24 Ibs of VOC/day may require
about 125 Ibs of carbon. Even if such filters were incorporated, their
subsequent disposal becomes still another problem, unless a regeneration
subsystem is also developed.
In other areas in such shops considerable headway has been made in
reducing "fugitive" emissions. For example, spray equipment cleanup
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systems such as those marketed by Safety-Kleen reduce the amount of
solvent used, contain all solvent and incorporate arrangements for pickup
and off-site reclamation of the solvent.
In general, the size of such operations -- and the lack of technical
expertise being applied to these problems -- precludes on-site recycle of
the solvents. In the near future, hardware and other technical
improvements may have to take a backseat to more mundane changes such as
training employees to make less paint, waste less paint, and, generally
speaking, avoid the unnecessary loss of solvent vapors.
As we move to larger operations where paint use is a full scale daily
operation, we begin to see interesting options to minimize waste
generation and loss. Smaller and smaller stills are becoming available
that allow recovery of spent solvents from waste paint, equipment cleanup,
etc. Naturally, the more a shop sticks to one brand and one product line,
the more likely they are going to be able to reuse that recovered
solvent. However, even still-recoverable paint wastes will continue to
have limited value at the low production end. Reclaimed solvents can be
used for equipment cleanup and some product dilution. Only in the largest
installations is it likely that the capability will exist to use (and
destroy) the solvents as a fuel supplement.
It has also been suggested that the partially evaporated aludge from such
stills may be incorporated into an "undercoating" material to be applied
to the refinished vehicle, thus avoiding its ultimate destination aa
hazardous waste. The solvents emaining in the "undercoat" are then lost
as that product dries, but replaces other, virgin solvents that would have
been evolved. Unfortunately, the current regulatory protocols, by which
waste solvent going to on-site reclamation must be "counted" in a
facility's waste volume, inhibits marginal shops from embarking on this
investment. Once recordkeeping, manifesting, and pickup by a licensed
hauler become necessary (100 kg), the added volume of recovered solvent
becomes less of a detriment and less of a motivation for recovery. In
fact, by reducing the volume, the site becomes a less attractive pickup
and finding a reputable firm that will make the stop every 90 days becomes
a serious hurdle. I should note one interesting approach that has been
taken. One industry group has cooperatively purchased a small still.
While use by any one member would not have been cost-effective, the
part-time use by several shops may make solvent recovery more attractive
for all participants. However, where this would fit in DBF's view, as a
portable IDS facility requiring permitting or as an on-site recovery
system (aa it will be in each shop when used) is an interesting question.
Clearly, if DIP takes the first view, it would seriously hamper the
success of this effort.
Continuing with the larger facilities such as fabricated metal
manufacturers, we begin to have other options. Both carbon adsorption and
refrigeration/condensation systems are available for recovery of solvent
vapors, but only for such larger systems. Fabricators include firms such
aa American Environmental International, Inc., who market a chiller or
condensation system for recovery of printing solvents. Cost seems to
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start at about $50,000, which again reflects the unattainability of such
systems for snail shops where the spray booth itself nay have cost, as
noted earlier, 120-50,000, and where space is at a premium. Depending on
the variability of the coating systems used during a production campaign,
the recovered solvent may be reused in the process or may be useful as an
fuel supplement to the curing ovens. Again, only larger facilities using
oil or gas fired curing ovens would be able to take advantage of such
supplementation. Carbon adsorption systems -- with on-site regeneration
and solvent recovery -- probably start at about 1100,000 and require a
source of steam for regeneration. Incinerative and catalytic destruction
systems are also available but they offer little in benefits besides the
destruction of the wastes.
At least when waste destruction appears to be the moat attractive, still
another option is to reexamine the total system. For example, while coil
coating of steel or aluminum has lost significant markets, new ones are
being developed including the precoating of metal for subsequent
fabrication into furniture, siding, etc. This offers the distinct
advantage of eliminating all wastes related to the painting step for the
fabricator.
In the area of waste paint solids minimization (recovery, reclamation,
reuse), the technology is, frankly, not very sophisticated. From an
economic point of view, it is in the applicator's best interest to control
his substrate design as much as possible to minimize dragout or the need
to overspray to get coverage of difficult areas. Electrostatic spraying
may be a significant advantage In minimizing the amount needed for uniform
coating while producing minimum overspray. With the exception of powder
coating, once overspray is generated it is unlikely that it will have any
value and disposal of sludges or loaded filters may be a real problem
because of the metal content of such materials. In fact, disposal cost
may be a driving force toward other changes in the system that can reduce
the volume of such material.
While vendors may be pursuing modlficationa in both materials and systems
that would enable fabricators (i.e., applicators) to recover paint solids
and solvents, their emphasis is, naturally, on the larger, more lucrative
markets where such investments can be made. In most cases, the technology
has not yet filtered down to the smaller operations.
In summary then, what are some things that every fabricator/applicator can
do to minimize his waote load.
Consider whether coating is needed
Minimise inventory
Minimize changes in products, colors, etc.
Schedule for minimum washup requirements
Design substrate and handling system to minimize overuse
Look at total cost for coating operation, including energy and
waste disposal costs
Segregate wastes to the maximum extent possible
Install OSHA/EPA vapor collection systems with an eye to recovery
Increase cooperation with competitors, customers
Specialize
Lobby for changes in regulations that stimulate reuse and
reclamation/recycle, whether on-site or off-site
Herbert S. Skovronek
ENVIRONMENTAL SERVICES
88 Moraine Road
Morris Plains, NJ 07950
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AUDIT
AN I DOING THE OPTIMUM JOB?
DO I MEED A FINISH?
DO I NEED TO FINISH IN-HOUSE?
CAN I CHANGE SUBSTRATE DESIGN?
CAN I CHANGE SUBSTRATE MATERIAL?
WHAT DOES IT COST?
(production, material losses,
energy, enviro/OSHA compliance)
SOURCE ELIMINATION
Change Substrate
Change Coating
Change System
Housekeeping
Techniques
Segregation
Scheduling
Maintenance
SOURCE REDUCTION
Modify Process
Modify Substrate
Automate
RECYCLE
In Process
In Plant
As Fuel
Waste Heat
OFF-SITE USE
WASTE CONCENTRATION
EMPLOYEE ATTITUDE
Distill
Adsorb
Filter
Insolubilize
Recovery
Fuel
As is
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AUTO REFINISH SPRAYBOOTH PERMIT DEVELOPMENT
MATERIAL USE: 2 gallons paint at 501 solids/507. VOCs or,
at 8 Ib/gal, approximately 8 Ibs solids and 8
Ibs thinner.
2 gallons of thinner at 100% VOCs or, at 8
Ib/gal, approximately 16 Ibs of thinner.
Overspray estimated at 101
Booth filter capture 90% of overspray solids
EMISSIONS: Solids: 8 Ibs x 10% overspray x 101 loss -
0.08 Ib/day.
VOCs: 8 Ib(paint) -I- 16 lb(thinner) x 100% loss
24 Ib/day.
BUT:
2000 SHOPS IN NEW JERSEY
66 MILLION GAL PAINT USED IN 1986
$10 BILLION SALES (COLLISION/REFINISH) IN 1986
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The R&D Sector: Optimizing Waste Minimization Practices
Presented by
Elizabeth A. Holland
Senior Research Chemist
Safety Assurance Section
Lever Research, Inc.
Edgewater, New Jersey
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THE R&D SECTOR; OPTIMIZING WASTE MINIMIZATION PRACTICES
Waste minimization in the research and development
sector must be implemented in accordance with the
premise upon which R&D is built; innovation and
creativity. In a manufacturing situation, processes
may be streamlined which maximize waste reduction.
R&D however, may only optimize, or make the most
effective use of waste minimization through creative
implementation of a unique and facility-specific
program. A variety of practices and procedures
currently used in the R&D industry shall be reviewed
for practical application purposes.
Following inception of the 1984 HSWA waste minimization require-
ments, the research and development sector recognized its unique
inability to achieve measurably reduced levels of hazardous waste
annually, as the practicable minimization of waste runs contrary
to this sector's underlying principles and operating characteris-
tics.
Whereas in a manufacturing situation, processes may be altered,
streamlined, substituted, or decreased to maximize waste
minimization, R&D may only optimize (on a case by case basis),
waste minimization techniques currently available. Hultivariate
inputs do not allow for reduction design application nor do most
recognized test methods utilize or specify reagents on the basis
of their hazard potential.
It is believed that although some of the manufacturing sector's
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existing processes and technologies may be adapted for
incorporation into laboratory and pilot plant areas, the most
effective means currently available by which a minimization plan
may be adopted is through creative implementation of a program
which is tailored to meet the needs of the facility and
qualitatively demonstrate waste minimization.
Lever Research, located in Edgewater, New Jersey has based its
program upon the premise of R&D: Innovation and creativity. By
finding new ways to optimize its hazardous waste reduction, the
company increased employee involvement and awareness, gained
acceptance of the program internally, and received positive feed-
back from State authorities.
Some of the methods Lever utilizes to minimize and reduce
hazardous waste are facility-specific. However, it is believed
the balance of these techniques may be incorporated into other
R&O systems with no or minor revisions.
Like many other research institutions which do not qualify as
small quantity generators, Lever Research maintains an hazardous
waste storage facility. This facility must meet full RCRA com-
p]'ance requirements because of the following conditions: Types
a. quantities of wastes generated; longer accumulation times
required; unique characteristics of the waste streams; ongoing
selection of disposal options in accordance with "best management
practices", and; greater than 90 day .ime requirements for waste
evaluation and processing.
Until now, no treatment activities have been performed at our
site other than elementary neutralization and incorporation of
"totally enclosed treatment facilities", as Lever's RCRA permit
allows for storage activities only. However, following New
Jersey's recent approval of "accumulated-waste treatment" without
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a permit (reference: The New Jersey Hazardous Waste Quarterly,
Vol. 1» No. 2, 1987), the company intends to take full advantage
of this option and incorporate this treatment exemption in order
to reduce the volume and/or toxicity of hazardous waste destined
for manifested disposal. The effect of this interpretation is
expected to substantially contribute to waste minimization for
generating processes which cannot be reduced by other "before
generation" means.
Other than this new method of in-house waste reduction, Lever has
deemed it appropriate to rely on support activities versus
process control.
Lever's waste minimization program was strategically developed
for incorporation with minor revisions into the company's
existing RCRA program. It was initially determined, inception
and acceptance of minimization practices would be implemented
more rapidly and effectively if existing waste management
guidelines were followed.
In developing the program, six key areas were defined as
essential elements needed to create a viable, systematic process
of rules. These areas are defined as follows:
-Corporate Commitment
-Institution of Site Procedures
-Incorporation of Communication Channels
-Education and Training
-Support Activities
-Feedback
In order to assess the program's value, each of these issues shall be
addressed individually. Please note, as effectiveness is achievable
only through the simultaneous enforcement of each variable, their
interdependance will be referred to as well.
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Corporate commitment. In order to gain commitment, the introduction
of any new program must be evaluated for compatibility vith the
corporate mission. Lever developed its waste minimization program to
meet the company's R&O philosophy of Innovation Vith Integrity.
Although this statement refers to all areas of regulated compliance,
the hazardous waste minimization concept encompasses all implications
of this succinct phrase.
All companies must provide a written statement certifying the
program's existence in accordance vith State and Federal law. The
existence of such a document though, does not necessarily preclude
effective application and enforcement of program provisions.
Therefore, an additional commitment to the development of a flexible
program must be obtained from upper management in order to provide
impetus and authority for implementation.
The effective approach which Lever used, is that of gaining acceptance
through perceived value. By speaking in terms of real dollars,
program implementation may be viewed as a viable opportunity to
potentially reduce disposal costs, liability, and hazardous waste
generated.
Institution of site procedures. In accordance with Lever's current
waste identification program and procedural channels of hazardous
waste handling responsibility, waste minimization practices were
implemented through the currently existing system. A minor revision,
consisting of the increase in involvement of the Shipping/Receiving
and Purchasing departments in the procedural process was made, as
these channels are utilized to provide measurable recordkeeping data.
Prior written notice of hazardous waste generation is received through
the mandatory use of waste identification forms. The individuals
primarily involved in the progr n's procedural signatory approvals are
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designated as those authorized and responsible for handling hazardous
wastes generated by a particular source.
Primarily, the existing chain of command was followed in establishing
procedural recognition of types and quantities of wastes to be
disposed of.
Incorporation of communication channels. This is considered to be a
key element in maintaining an effective waste minimization/reduction
program as these channels provide feedback mechanisms for all on-site
hazardous waste generators. In order to obtain maximum value from all
site inputs, Lever has adopted a proactive communication strategy. It
is based on an interactive relay of ideas which crosses and typically
runs contrary to the procedural channels previously discussed, and
encourages face-to-face communication. As each individual is his or
her own generator, these individuals are most capable of providing new
waste minimization and reduction techniques as they apply to specific
activities.
Education and training. The training forum for Lever's waste
minimization plan has become the annual RCRA training update meeting.
Intermittent updates are further related through memos of proposed
activities and ongoing discussions with hazardous waste coordinators
and hazardous waste management team members.
The hazardous waste coordinator is an individual appointed in each
department. Following participation in the training program and
passage of the review exam, he or she becomes directly responsible for
implementation of generator level RCRA activities and concurrently
provides educational know-how for the generators within their depart-
ment. The hazardous waste coordinator follows a written job descrip-
tion which provides guidance during hazardous waste handling
activities, and; holds at least a bachelor's degree in one of the
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sciences (or equivalent experience). The coordinators' activities and
training are included as part of their permanent record and related
successes of waste minimization and reduction activities are
identified for performance evaluation purposes.
As formally educated professionals, the employees lend a unique degree
of expertise to the RCRA program, and also provide first-hand
knowledge of departmental activities for identifying waste minimiza-
tion opportunities.
Support activities. The actual minimization and reduction techniques
employed at the Lever facility are numerous and varied. Although some
of the activities are utilized for purposes of gaining corporate and
employee commitment, i.e. returning materials to suppliers, most of
these measures contribute in part to demonstrate an overall decrease
with no single practice consistently contributing substantially more
than another. The listed activities as they apply to either Research
or Development and their subsequent application throughout the
generation process, have been attached for reference.
Although the list of activities appears extensive, each practice is
evaluated by the individuals performing the waste reduction activities
on the basis of feasible introduction. As expressed earlier, research
and development must adopt a facility-specific program and
additionally, extend it in application to the level of individual
generators.
Feedback. The last element to be outlined is also the most important
in ensuring program effectiveness. Feedback concerning the existing
program's viability is first and foremost obtained through application
of minimization measurements as reported in the Facility and Generator
Annual Reports.
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Lever, as all other research and development institutions, could not
calculate its waste minimization effectiveness on the basis of State
established measurements. Therefore, the company chose as its
baseline figure, budgetary expenditures less capital expenditures. As
project priorities and resultant activities (i.e. waste generation)
vary, time and salary allotment to specific SIC-coded activities is
deemed to be a measurable baseline. Although it is not a true
indicator, further clarification is given in the reports to explain
any discrepancy between the calculated figures and efforts applied.
Additionally, an in-house evaluation program has been established
through the effective use of communication channels in order to
provide an ongoing indicator of waste minimization successes and
failures.
In conclusion, six basic elements have been defined as essential in
the development of a workable, measurable and enforceable waste
minimization program. Although there are currently no quantitative
measures by which to gauge compliance, Lever believes it is the
qualitatively measured "good faith effort" employed which shall
determine whether or not the company has fulfilled regulatory
requirements. Furthermore, these practices will assure recognition of
the unique conditions under which the R&D sector generates hazardous
waste and more importantly, aid in the development of realistic
hazardous waste minimization and reduction requirements in the future.
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ATTACHMENT
Before Generation
IN THE LABORATORY
During Generation Following^Generation
-Evaluate
-Search for
alternatives
-Return to suppliers
-Proper labeling
-Safe handling
-Education
-Collective use
-Separate hazardous
from nonhazardous
-Dewater/Avoidance
of dilution
-Compatibility
monitoring
-Recycle
-Reclaim
-Resell
-Condense
-Manifested disposal
using "best management
practices"
Before Generation
IN THE PILOT PLANT
During Generation
Following Generation
-Evaluate by-
products/end-
products
-Search for
alternatives
-Return to suppliers
-Safe handling
-Enforce OSHA HCS
-Computerized
inventories
-Incorporate totally
enclosed treatment
facility
-Substantiation of
process prior to
testing
-Combine activities
-Separate hazardous
from nonhazardous
-Reduction of batch
size
-Container reuse
-Rework formulations
-Resell
-Manifested disposal
using "best management
practices"
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Waste Reduction in the R&D Industry
Presented by
Steven C. Rice, P.E.
Corporate Ecology
BASF Corporation
Cherry Hill, New Jersey
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WASTE REDUCTION IN THE RID INDUSTRY
Waste reduction 1s becoming an increasingly important aspect of
virtually all Industrial organizations, large and small. Real incentives for
reductions are provided by disposal cost increases on the order of 25% to 100%
per year and by potential long-term waste generator liabilities associated
with waste disposal site cleanups. When combined with regulatory pressures,
shrinking disposal options such as the recent EPA land disposal bans and by
minimization certifications, there are significant driving forces to reduce
the volume and/or hazardous nature of our wastes.
This paper presents practical experiences with waste reduction for
R&O organizations and shares some of the difficulties that appear to be rather
common among those organizations which have made attempts at reducing their
wastes. Major areas of discussion are:
+ The unique characteristics of experimental units,
+ Waste reduction opportunities and experiences,
+ Tracking and reporting of R&O waste reduction efforts, and
+ A suggestion as to the future challenge for the R&O industry.
The Information presented reflects a compilation of personal experience as
well as that of my counterparts in other organizations, based on our mutual
contacts, activities and discussions. Thus, Individual details should not be
considered to be automatically applicable to all companies or organizations,
as each will have their own situations for which success or failure may be
realized based on a variety of factors.
Recent conference presentations and journal articles, even the
Office of Technology Assessment Report on serious waste reduction, have
provided a significant amount of Information on the economics, technologies,
and even operational changes for waste reduction In manufacturing facilities.
Unfortunately, little if any of this Information 1s of much use In the
research and development environment because of the unique characteristics of
experimental units. Haste reduction during research and development 1s
helpful not only to the specific research operation and site, but also to the
operating/production facility which may utilize the new or modified process
units resulting from that research.
The three unique characteristics of experimental units - diversity,
variability, and originality - all suggest that the waste reduction
opportunities for R&O organizations may be quite different than those for
manufacturing sites:
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1) Diversity: Each lab or pilot unit area is always working on a wide
range of investigations in diverse interest areas. Approaches
suitable 1n one area with one set of constraints may be quite
unsuitable for another area.
2) Variability: The nature of research work requires that different
techniques and different activities be attempted, very unlike
operating plants. A problem once resolved for one unit may no longer
be resolved a few days or weeks later since the work, the kinds of
materials or their amounts may have changed. New circumstances are
constantly being presented as new work is being Initiated.
3) Originality: One of the many purposes of R&O 1s to do new work, often
in new areas, such that one can rarely go to published literature to
find out how someone else resolved a particular environmental issue.
Also, the project's environmental Impact and waste generation charac-
teristics may not always be clear at the beginning of the effort.
Therefore, waste reduction for research and development activity 1s much more
than a "one shot deal" to implement. It becomes more of an effort to create a
mental attitude within each research scientist or engineer to think of waste
reduction continually in all phases of his or her work.
Haste Reduction Opportunities And Experiences
Waste reduction opportunities and experiences In the R&O Industry
are as varied as the nature of the work. There are several approaches that
can be taken, the advantages and success of which will depend on the specific
situations at the specific organization and site. While diverse approaches
have been developed, most of them can be grouped Into seven basic areas as
discussed below.
Provide employees with Information. Because of the diverse,
semi-autonomous climate In which most research Is usually conducted,
development of an organizational mind set becomes one of the first and most
important waste reduction opportunities for R&O organizations to pursue.
Without such a mind set, further efforts may have little or no affect without
constant reminders and reviews. Through a series of Internal seminars and
presentations, possibly coupled with letters and brochures, employees can be
provided with detailed Information on why reduction is important, the
cost-saving potential and the basic rationale for such a program. Here is
where one tries to create the desired thought process.
This Information should review the possible methods to achieve
reduction, and encourage attempts at Innovative approaches, ideas, and
solutions. In order to garner the maximum amount of individual interest and
support for such an effort, it's important to emphasize what's in it for them.
Approaches which have been met with success suggest 1) there will be reduced
operating costs, thus freeing the budget for other work in his or her area and
2) the development of new or modified processes for the competitive advantage
of the organization and the personal recognition that could result. This
second aspect will be discussed in more detail later in the paper.
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Two vital pieces to the ultimate success of this opportunity are the
inclusion of executive management in the program and obtaining their support
and commitment for all facets of the activity. They will be able to supply
the loud and clear message that they view waste reduction as an important,
worthwhile effort for all employees to take the time to pursue. Without such
support and commitment, any efforts are likely to be difficult to implement
and yield only marginal results.
Some of the surest and least expensive opportunities for reducing
waste are those which keep non-waste from becoming waste. There are several
ways to accomplish this, three of which are discussed below.
Purchase smaller-sized units of stock chemicals. The stocking of
smaller sized units of stock chemicals 1s more of a materials handling
consideration than a technical consideration. This approach involves making
available the smallest sized units of the chemical necessary for an
experiment. Instead of stocking only gallon-sized containers of a material,
consider stocking additional quantities of quart or pint-sized containers.
While the initial cost for the chemical purchase may be higher, in many cases
disposal costs for unwanted remainders often exceed the purchase cost. Thus,
the increased purchase cost will be more than offset by the reduced waste
cost. Of course, in certain instances larger unit sizes are truly needed and
justifiable - these can be handled on an individual case-by-case basis rather
than through the stockroom supply system.
Restock unopened materials. A second method to keep non-waste from
becoming waste Is to restock unopened stock chemicals. Research scientists
and engineers who possess unopened stock chemicals should be encouraged to
return these materials to the stock or supply room instead of discarding them.
In this way, others may be able to use the materials which might otherwise
become wastes though each container may have to be dated to determine if its
usefeul shelf life has been exceeded. If possible, the restocking of opened
stock chemicals is also an alternative. However, 1n research work this is
seldom practical due to the high quality material required (or in some cases
merely desired) by each researcher and their uncertainty about the quality of
the material remaining In the container.
Create an Internal material exchange. Perhaps the largest
opportunity for keeping non-waste from becoming waste exists in the creation
of an Internal material exchange or "classified ads" system to keep surplus
non-stock or open stock materials from being discarded unnecessarily. This
can be done in a variety of techniques. An organization might develop a multi-
accesslble computer network or organize a manual system utilizing a trained
contact person.
If conducted through a computer, entries can be logged into a data
base by research scientists and engineers to create a chemical exchange
program. More and more organizations are creating a chemical inventory system
as a part of their R1ght-to-Know and SARA Title III compliance programs, so
the exchange portion would represent only a small Incremental cost to set up.
If conducted through a manual system, researchers can call a contact person
who keeps entries indexed by file cards or a dedicated personal computer.
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Information can be distributed via a weekly posting, newsletter, or hotline
telephone number.
Regardless of the type of information system used, it's important to
refer to the materials by their chemical abstract number due to the various
synonyms used for the same material. In one instance, more than twenty
different entries were found for exactly the same chemical, largely due to
different manufacturers' commercial product names. Also, each system should
have "available" as well as "wanted" listings which contain information such
as the person owning or wanting the material, the location, amount and grade
of material, the size of the container, and the date when it is desired or
will be available. It would be important to purge the entry information
periodically.
Allocate disposal costs. Allocation of disposal costs is perhaps
the greatest single, effective tool to heighten Individual awareness of waste
reduction. Often the researcher and the Individual line organization is not
aware of the costs of disposing the wastes from their subject research. One
very effective opportunity to encourage such consideration 1s the allocation
of waste disposal and handling costs as a separate line Item Internally billed
directly to the account of the generating project or organizational unit.
When such costs show up as an accountable expenditure which the generator must
budget and track throughout the year, additional attention is directed to
them. In some situations a revised accounting system may be required for
separate billing on such a basis.
Essential to the viability of this opportunity is the accurate
identification of the generating lab, division, or project on each container's
waste Identification form. The disposal and handling cost of each container
of waste then can be back-charged to the generator as part of his or her total
project budget. Experience has shown that in a research environment
frequently the Individual cost of each container cannot be determined. In
those cases some type of prorated share of the waste disposal costs for
similar materials can be distributed among the generators.
This cost allocation concept has the potential for being extremely
effective In developing the generator's awareness to the cost of waste
disposal and the saving that may be realized to his or her organization by
reducing waste. As long as disposal costs remain a hidden budget Item,
visible only to administrative or operational personnel and not to the
Individual research project or generator, specific attention to this type of
cost will not be achieved to the maximum extent. Attention brought about by
this form of awareness Is also beneficial in maintaining the desired mental
attitude of each employee.
Treat at the source. Treatment at the source has been emphasized in
most of the published Information applicable to R&O activities. The American
Chemical Society's pamphlet "Less I letter" stresses this as a primary
opportunity when discussing researcn applk-tlons, as does the Duke University
Medical Center's document, "Management Strategies and Technologies for the
Minimization of Chemical Wastes from Laboratories". While there are some
advantages to this approach, there Is a significant caution which should be
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given careful consideration before proceeding - there may be regulatory
implications with "treating" hazardous wastes without an appropriate permit.
Authorities such as EPA, the respective state agency, and possibly an
environmental lawyer should be consulted prior to actively pursuing this
opportunity.
Conduct environmental audits. An environmental audit program for
experimental units can provide the opportunity for necessary issues to be
considered during the project or unit design phase, prior to construction and
operation. Such a review is most easily implemented if included within an
existing safety or budget review procedure. While including environmental
considerations, it can also be used to include industrial hygiene aspects,
which frequently address parallel issues.
There are several ways to address this opportunity, the specifics of
which need to be formulated to meet the needs and objectives of the individual
organization. One technique incorporates the project review within the
regular planning and budget process. Figure 1 shows how a review system, which
includes safety, environmental, and industrial hygiene aspects, can be
structured. Regardless of the exact flowplan, the central concept is to
assure that all suitable work is reviewed and that there is a cross-check at
some point in the process. In this case, the cross-check 1s the requirement
that the project review must be completed before the budget estimate can be
released.
A copy of the environmental portion of an experimental unit review
form 1s presented In Figure 2. The purpose of a form such as this Is not to
solicit all applicable Information on the unit or Us operation. Rather, it
is to develop enough information so that a knowledgeable person can determine
if follow-up consultation 1s required. For example, based on the rather
simple information it may appear that an air pollutant emissions certificate
is needed or that the site wastewater treatment plant cannot handle the type
or amount of effluent. While the requested information may not always be
readily available, the form provides for a consistent set of questions for
which answers ought to be obtained for the benefit of the organization, the
research person, and the environment.
Note that there are two Items relating to hazardous waste generation
and minimization. If nothing else, the opportunity for the researcher to
respond to the requested Information may get him or her to think about their
work in a slightly different light, so as to Include proper waste handling and
waste reduction as a part of their daily research objectives. Responses such
as "according to company procedures" or "as usual" usually indicates that the
researcher doesn't know and further follow-up by the site environmental
contact may be necessary.
A key advantage to an environmental audit at this stage .of the
research work is that such considerations can be addressed at a time when
cost-effective solutions can be incorporated easily. For example, a unit was
proposed for the separation of rubber polymer from a solvent base. The
original design had a simple stripper which vaporized and vented much of the
solvent, with the remaining wet residual polymer to be handled as a hazardous
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waste liquid. By considering air emissions and waste disposal, minor
modifications reduced hydrocarbon emissions by 90% and upgraded the waste
stream such that virtually 100% of the polymer was recovered and most all the
solvent could be recycled back into the process. Not only did this reduce
hazardous waste generation but those design Improvements had a pay out time of
only about 2 months due to reduced waste disposal costs and feed solvent
purchases. It will also greatly enhance the profitability of similar units in
operating plants.
As such, units which have environmental solutions or improvements
incorporated into their designs have distinct advantages. Several
corporations have formal programs for their operating plants - 3M Company's
Pollution Prevention Pays program is perhaps the best known and documented.
However, I've not been able to find any published literature suggesting
organized efforts to apply such concepts to R&O activities.
Tracking And Reporting Of UP Haste Reduction Efforts
A key element to any serious waste reduction effort 1s the tracking
of how well your program Is doing. This Is usually done by comparing waste
generation and costs from one time period to another, with figures often
normalized to a common factor such as throughput, production, or sales.
Reports are developed for Internal evaluation and/or submitted to regulatory
authorities pursuant to applicable hazardous waste regulations.
Unfortunately, problems have been encountered with the tracking and
reporting of waste reduction efforts by the R&O Industry, largely due to the
Inherent variability of each organization's activities. Tracking and
reporting accurate, meaningful results 1s no easy task. Project initiation or
expiration Impacts each year's types and quantity of waste. The Initiation of
a single large unit can overshadow current waste generation quantities and
wipe out true reduction successes. Conversely, an expiration of one or two
key projects can Inaccurately show up as a significant waste reduction
success.
Laboratory cleanouts can also distort an Individual year's
generation, especially In a smaller organization or If cleanouts are not
conducted frequently. It 1s not uncommon to see an Increase of 10%-50% in an
annual reporting quantity due solely to a site-wide cleanout.
Part of the difficulty In accurate tracking and reporting goes back
to the difficulty In determining how much waste is being generated since such
determinations are not as straight forward as in a manufacturing plant.
Research wastes are often accumulated 1n a "lab-pack1, which 1s a drum or box
of several Individual but compatible containers of waste. A weight basis for
determining the amount of waste usually Includes the glass or metal
containers, cushioning material, and the overall drum or box. Since in many
cases the major weight Is the individual and overall packaging, the actual
weight of the waste material is difficult If not impossible to determine.
Also, true weight reductions in lab-pack wastes may be overwhelmed by the year
to year variations experienced due to project initiation/expiration and
cleanouts.
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Converting to a mixture of weights and volumes to report the various
waste streams can alleviate this somewhat, particularly if the much heavier,
drummed liquid wastes are reported separately from lab pack wastes. However,
the routine administrative tracking and reporting then becomes even more
cumbersome as most wastes would then require at least isa reporting parameters
and many lab-pack liquids will still need to be shipped and reported under the
DOT "solids" designation. It 1s clear that each organization should
investigate the associated advantages and disadvantages in light of their own
particular waste streams and set of circumstances.
The use of a normalization factor in reporting waste generation and
reduction Is instrumental In generating useful data for internal or regulatory
agency study. NJOEP recognized this and incorporated the concept into last
year's annual reporting requirements for hazardous waste generators. This
raised the question of what would be an appropriate factor for the R&O
industry? Factors such as production, throughput and sales were clearly
inappropriate.
Several factors such as research dollars, number of research units,
number of researchers, among others are somewhat indicative of research
activity and should have at least a casual relationship to waste generation.
While research dollars may be the most accurate normalizing factor, often it
is proprietary Information and not available for release. Research units can
be operating or Idle at almost any given time or duration. Also, not all
units are the same - a wet chemistry unit could not be comparable in waste
generation to a semi-works pilot plant.
Thus, the total number of on-site people appears to be a suitable,
albeit not perfect normalizing factor. For Intensive research sites, it
should be close to the total research population and somewhat Indicative of
site activity and waste generation. For less Intensive office/research sites,
this would be less sensitive to annual swings and variations in individual
research programs. However, as the resultant waste per person value will tend
to be much lower at this second type of site there is an Inherent difficulty
in comparing waste generation rates between the two types of sites.
The Future Challenge For Ri~D Organizations
A few short years ago the first industrial waste reduction efforts
were directed toward alternate disposal strategies, usually away from land
disposal and final treatment or Incineration. Lately, the thrusts have been
directed toward changing 1n-plant procedures, equipment, or feedstocks. The
future direction for Industry may be to go further upstream, to address waste
reduction before the plant or process Is designed and constructed.
Thus, as an Integral part of the total waste reduction effort, the
R&O Industry faces a rather formidable future challenge - to develop new or
modified processes which Incorporate waste reduction into their basic,
intrinsic designs. This probably has the potential to provide the most
significant, long term reduction in Industrial waste generation by ensuring
the amount or hazardous nature of any waste is reduced to the minimum level
possible, hopefully even to the point of elimination in many cases. By
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working with the process designers, especially those working on the research
or pre-connerc1al1zat1on activity, the concept of how to reduce wastes can be
Included within the chemistry and engineering of the process. The audit
technique discussed earlier can be an Instrumental tool In addressing this
challenge.
An effort such as this has advantages which may be more clearly
understood by others less familiar with hazardous waste Issues if put into
terms familiar to them. First, 1t has the potential to result in Increased
competitive advantage for the company or organization. Waste reduction of
10%, when put on a large scale commercial basis, yields substantial savings on
waste disposal costs. When that 10% Is compounded by annual disposal cost
Increases of 25-100%, It becomes even greater. Such reductions 1n a unit's
operating cost can make a process a star money-maker 1f the competition has
operating costs which still Include waste disposal. Alternately, these
reductions can change what might otherwise be a non-competitive product
Improvement Into a highly competitive one. This aspect 1s especially
Important 1n mature Industries, where significant Industry-wide process
Improvements may not otherwise be available.
Second, recognition for both the personnel and the organization can
come from such an effort. Personnel can get recognized for contributing to
the success of the organization. Patents, awards and promotions are but a few
of the possible resultant rewards. For the organization, 1t can make their
R&O more valuable to the commercial sectors it supports. That can bring in
either more work or better supported work into the organization. Of course,
there are also the public affairs aspects which can be used to promote the
favorable public image every organization strives to achieve.
The uniqueness of experimental units requires unique approaches to
waste reduction. Approaches common to manufacturing plants are seldom
applicable or effective 1n the R&O industry. Nevertheless, there are several
waste reduction opportunities available to R&O organizations, many of which
are relatively simple and inexpensive to initiate. An environmental audit
during a project's design phase can provide a forum to discuss waste
reduction, along with a variety of other environmental Issues.
Haste reduction tracking and reporting are difficult due to the
nature of R&O work and the types of wastes generated. Accurate, meaningful
comparisons between different organizations or across time frames require more
than a cursory investigation. The future challenge for the R&D industry is to
develop new or modified processes which Incorporate waste reduction with their
Inherent designs. Besides long term waste reduction, Increased organizational
competitiveness and personal recognition are but two of the rewards which can
result from such an effort.
Steven C. Rice, P.E.
Corporate Ecology
BASF Corporation
November, 1987
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FIGURE 1
FLOW PLAN FOR EXPERIMENTAL UNIT REVIEW FORM
Client and
Proposed
Project
Planning
ft Budget
Group
oo
to
Prepare ft Releaae
Initial Schedule
& Coat Estimate*
Client Review
and Approval
Receipt of
Initialed
REVIEW FORM
Planning Gives
EXPERIMENTAL UNIT
REVIEW FORM to
Client for Client
to Complete
Prepare ft Releaae
Final Schedule
and Coat Estimate
Client Review
and Approval
Project
Initiation
Construction
Initialed REVIEW
FORM Returned
to Client
or the Engineer
Client Completes
REVIEW FORM and
Retuma It to the
Engineer
for REVIEW FORM to be Reviewed
and Initiated by:
Safety Engineer
Environmental Engineer
Industrial Hygtonlat
Any Other Appropriate
Personnel
This Can be Accomplished by
Either a Joint Review With the
Client or Individual Reviews
With the Client.
-------
FIGURE 2
ENVIRONMENTAL SECTION OF EXPERIMENTAL UNIT REVIEW FORM
F. EariroamenUl Concerns
Maximum Emission Rate
Will there be any potential for: Yes/No Maierul(i) per hour per day
air pollutant emissions? _^_____ (Ibs) ^___ (Ibs)
(includes use of vent lines) ___^^_ __^____ ___^^_. _
ewater discharge? __^___ (gal)
(includes overflow or release to sewer)
ground/soil contamination?
(includes spill during operation
or material handling)
Are there any emission control devices anticipated in the unit's design?
D exhaust filters D cyclones D scrubbers D liquid/vapor separators D other emission control devices?
If so. describe:
Describe how wastes (unused feeds, samples, and products) will be identified and handled.
Describe how the volume or hazardous nature of the wastes can be reduced
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Zero Discharge, Zero Pollution,
and Source Reduction
Presented by
Robert H. Elliott, Jr.
President
Zerpol Corporation
Hatfield, Pennsylvania
-------
Zero 'Discharge, Zero Pollution, and Source Reduction
by Robert H. Elliott, Jr.
ZerpofCorporation, Hatfield, Pennsylvania 19440
Two hundred years ago the industrial revolution began. In this century
we have a new kind of revolution - environmental. The first revolution im-
proved our quality of life. The second is destroying it. In 1950 the Chesa-
peake Bay started to decline and with each year the rate is accelerating. Our
streams, lakes and rivers are being polluted on a daily basis. Some scientists
say our aquifers cannot be saved, but we must look for that reversal.
Let me tell you one way that we can stop this trend - zero discharge/
zero pollution. For such a system to be successful it must be cost effective.
A plater wants to see a waste treatment system after it has been running for
three, four, five years. So many equipment companies have gone bankrupt and,
unfortunately, taken some platers with them in the first year. Even systems
that continue to operate have upsets and with increasing frequency in the
second and third year.
Zero discharge is simply cementing over the drain so that no wastewater,
treated or untreated, can leave the plant. Of course, we build the system
first... a quality system, one that will take any chemical such as cyanides,
chelates. and electroless copper or nickel and treat it with precision even
if there is an unexpected slug, no environmental spills, no fines. The other
consideration for a quality system is leaving room for expansion. In 1981
we built a complete new shop for a 20 year old business with the assurance
that the owner could double his plating operations. He moved in and doubled
his business the first year. In 1985 he doubled his volume again and without
any modification of h'is Zerpol system.
Papers have been given on our patented Z.D. system and there are reprints
here telling how the system works. I will discuss the system briefly and then
move on to zero pollution. The process is a batch operation with chemical
destruction of cyanide and hexavalent chrome. Chlorine is never useti* in any
form. The final adjustment is pH to a level of 9 to 10 and the tank is left
to settle overnight. No flocculating agents are used. The crystal clear
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Zcrpol Corporation
water is pumped to the clear water storage tank and the sludge to a sludge
concentrator. Over a period of time the suspended solids will'increase from
1/4 percent to as high as 10 percent. I will come back to the alternatives
for sludge control during the discussion of zero pollution and again on source
reduction.
Once the metal hydroxides settle in the sludge concentrator the clear
water is decanted off and is used to dissolve the treatment chemicals (chroae
reductant, acid, alkali etc.) for the next batch. Of the many systems built
since 1979 the size has varied from 6000 gallons to 250,000 gallons. A typi-
cal 20 nan shop nay require a batch size of 25,000 gallons. Of course, the
metals plated may vary the amount of rinsing as does rack plating versus bar-
rel plating. The normal amount of sludge is, say, 500 gallons and the clear
water may be 500 gallons. After the purped sludge settles the clear water
may be 800 - 850 gallons.
The recycling of the water from the sludge concentrator has several ad-
vantages. The sludge remains in the system and, therefore, is not subject
to the 90 day storage rule. Only when.the concentrated sludge (102) is re-
moved, 'does the clock start running. The mixed mecals go directly to a treater
or preferably to a smelter. They can also have an intermediate seep of a filter
press. Another combination is Co filter press and dry. A third method is
to dry the metal hydroxides directly in a 400° F. oven.
The description of the sludge concentrator is cor.plete and now the salts
concentrator will be discussed. The clear water contains salts, such as sod-
ium chloride, sodium sulfate and sodium nitrate and ou occasion potassium salts.
In order to remove these economically, we use the company boiler. The salts
typically enter the boiler at 6000 ppm and concentrate in the blowdown. From
the blowdown pan the salts are pulped to the salts concentrator. A small fan
pulls off the moisture laden air (about 130° F.) and sends the condensate
(1-5 ppm dissolved solids) to the same tank as the boiler condensate. Again,
the 90 day storage rule does not apply until the salts, which contain 10 -
15 ppn of various metals, leave the system.
Zero Pollution
In order to achieve zero pollution from a plant, the three separations -
organics, salts and sludge nust be dealt with in a very precise manner. Oil
(organics) may enter the plant on steel parts to be plated, or as in the case
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Zerpol Corporation
o£ the first installation of the Zerpol concept in 1979, about half a truckload
of waste oil vas generated each month due to punch presses and elaborate form-
ing devices. At first, the oil was burned but the methylene chloride was too
high and started to attack the fire side of the boiler. In addition we were
not sure of a quality burn. There were no P.C.B.s present and the temperature
in the furnace was 1800° F. The methylene chloride was less than 1000 ppm.
It was contemplated that the methylene chloride and a lesser amount of trichloro-
ethylene could be separated but at the same time, the idea occurred why not
separate the various oils ar.: have them reprocessed. This was accomplished
and-at a very substantial sa ugs. The remaining oil was so small that it
was shipped -with the metal h. roxides to a waste treater. Normally, oil or
organics are se to a cert: .-d burner that is approved by E.P.A. or the in-
dividual state. Reclaiming -of the oil, of course, is a source reduction.
The-next item to remove so that we do not harm the environment is salt.
Many managers, platers, scientists, et al, ask why treat sodium chloride or
sodium sulfate as a hazardous waste? Sodium is bad news for heart patients
and up to recently limits were not enforced. In some areas the limits are
250 mg/1 for each* salt. A continuous discharge system may dump 1500 to 3000
mg/1 on a daily basis and such high dosages flowing into our streams and
aquifers are highly detrimental. A few months ago we installed a zero dis-
»
charge system in Florida and the president of the company now states that they
have better water in their plating shop than in their drinking fountains,
about 10 ppm total dissolved solids. When a truckload of salts is accumulated
and the concentration reaches 30 - 40 percent, it is either mixed with the
sludge and dried to 100 percent hard cake or transported to a salts treater,
such as Du Pont Chambers Works in New Jersey or made into caustic soda and
sulfuric acid in the job shop. This latter method is primarily, for anodizers
where the bulk of the raw materials are sulfuric acid and caustic soda. No
salts leave the plant and the traces of zinc, copper, iron, etc. in the cau-
stic cell are removed to the sludge concentrator.
The final hazardous waste to remove from the closed system are-Che metal
hydroxides. The amount may vary from one truckload (40,000 Ibs.) of 10 -T
cent solids per year to one truckload of hard sludge (100 per cent dry) .
month or a raffge of 4000 pounds to 480,000 pounds. A typical 20 man sho;.
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Zerpol Corporation
rack placing copper, nickel and chrome on sceel and zinc die castings will
yield about 12,000 pounds of dry sludge and salts.
The best metal sludge disposal method is smelting and it is the most
economical. Our company has been working with a primary mining company near
our plant in eastern Pennsylvania for seven years. At first the truckloads
were liquid but now the sludge must be dry cake. It must also be 14 percent zinc.
The waste is fired at 2500° F. for 30 to 40 minutes. The zinc goes off as
a gas in the range of 600 - 1000° F. The cadmium, lead, mercury and other
volatile metals go off as gases, but the temperature continues to climb and
for a -very desirable reason. The iron, copper, nickel and chrome fuse into
an inert mass. Leachate tests on the cinders show below detection limits for
all metals except iron and calcium. Interestingly enough complete dissolving
of the cinders showed iron, chromium, copper and nickel but no zinc. Zinc
ore samples from many parts of the country could not come close to pass-
ing the E.P.A. leachate test.
People try to point out that we do not have zero pollution even after
they have seen a half dozen systems functioning perfectly. Part of the pic-
ture is how we define pollution. A daisy in the middle of the lawn is a weed,
but hundreds along the edge are a pretty border. Lead in a mine is valuable,
but lead in our water is a pollutant. My personal conviction of success in
fighting pollution will be borne out when the incidence of cancer declines
dramatically.
Up until now the total toxic organics (TTO) have not been mentioned.
Visualize a kiln 250 feet long and 12 feet in diameter at 2500° F. No TTO's
could possibly make that trip. It is well documented that organics adhere
to sludge.
Actually TTO's are destroyed in the Zerpol closed system and tests show
no detection of the 28 priority pollutants in the volatile section for two
plants operating for three years. These same two plants were measured again
after another three years and again the data showed below detection which were
levels about 1 part per billion. Perhaps someday instruments will measure
molecules per liter because that is the level of concern, but if we capture
everything (TTO's), we can wait for the instrument.
On the other hand, if a continuous discharge system after chlorination
discharges to a sewer or stream, it will probably be 2000 to 4500 parts per
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Zerpol Corporation
billion of TTO's. Mosc company presidents are put in a state of shock at our
reports and we encourage them to get independent' reports. Companies will fol-
low "solvent management rules" and they feel comfortable until they receive
one of our reports. It is the generation of nine or ten TTO's, especially
chloroform, when chlorine is used to destroy the cyanide present. E.P.A. rules
require the use of chlorine when discharging. If no cyanide is present, the
organics move on to the P.O.T.W. where chlorine has a second opportunity to
generate carcinogens.
Source Reduction
With total control of end-of-pipe (over " billion gallons without a
fine or spill), we turn our attention to source reduction. High quality dis-
tilled water is available from the boiler and at a cost considerably lower
than the city tap water. A triple counterflow i-s placed after a nickel plating
tank. The evaporation rate is 80 gallons per day from the nickel tank. A
restrictor is placed on the third tank to equal the 80 gallons and meter in
distilled water. A small air pump or sealless magnet coupled pump is used
to move the nickel solution back into the plating tank. The cost of the pump
is $100 and the stainless steel counterflow may be $1500. The operating cost
is less than a hundred dollars per year. In sharp contrast reverse osmosis,
evaporators, ion exchange and atmospheric evaporators cost $10,000 to $20,000
per year to operate and substantial amounts to install. There is another aspect
about atmospheric evaporators besides the $10,000 fuel bill, which is that
the evaporator throws TTO's into the atmosphere.
For chrome plating it is suggested that a four or five stage counterflow
be used. Usually a chrome bath is operated at a lower temperature (120° F.)
than nickel. We like to see a temperature of 135° F. which will double the
evaporation rate. To evaporate one gallon of water requires about 8000 BTU's.
The evaporation rate is one pound per square foot at 120° F., two pounds at
135° F and four pounds at 150° F. or about 1/2 gallon. A 4' x 10' tank of
nickel solution would evaporate about 20 gallons per hour with rocker arm agi-
tation and about SO percent higher for air agitation. Conservatively, this
is more than enough water loss to run a triple counterf '. I would be remiss
if I didn't mention another source reduction method for 'eel that is very
economical to run.
It is precipitation of the nickel in the first and second stage of a three
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Zerpol Corporation
stage counterflov at a pH 9. The nickel rinses are continuously filtered
(30" cartridge type) and when the cartridges are fully loaded, they are placed
in sulfuric acid. The same acid used to adjust the pH of the nickel bach.
Some platers report they use a carboy a week for adjustment and this is more
than adequate to redissolve the nickel hydroxide. Distilled water is used
in the third stage and the result is very pure nickel sulfate.
The three, four, five stage counterflow principle can be applied to any
of the common plating baths except precious metals. In general, the recovery
costs of the various metals is less than 10 percent of their market value ver-
sus two to three times their market value for other methods and economics is
the name of the game.
'Some companies will justify the additional expense by claiming the tre-
mendous savings in waste treatment. This is not true. With total control
of the end-of-pipe we can easily measure the amount of nickel, copper, zinc
or other metals. Here is a case history of a job shop with sales of $2,000,000
per year. They had a continuous discharge system for six years, which cost
$142,000 per year and now they have a Zerpol zero discharge system, which costs
$39,200 per year average to operate. Their sales /aried but the above figures
are based on $2,000,000. At this point in time (Fall 1987), they have completed
six years with zero discharge, which matches the six years with continuous
discharge. There were many fines with the old system and none with the new
system. The state of New Jersey sent many people to show how it should be
done and the owners were very pleased and proud of what they were doing for
the environment. They are currently being televised on Nova as the company
that is doing something about our deteriorating environment.
We mention this case history to illustrate a point. The electroplater
had two percent zinc in his sludge even though he did not zinc plate. He plated
copper on zinc die castings and some zinc dissolved in the cleaners and pick-
ling acids. In order to ship the sludge to the smelter, it was necessary to
get the zinc content up to seven percent. Most of the sludge was iron. The
plan was to recover all the nickel and about half the copper to bring the zinc
to the magic seven. It was a shock to learn that half the nickel was still
in the sludge. At the same time, the smelter announced that the zinc concent
must be at least fourteen percent and they were receiving so much placers'
"ore" that they shut down cheir own mine in New Jersey.
196
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Zerpol Corporation
Meanwhile a. zinc plater in Ohio was very pleased with the smelting
operation. He installed a Zerpol system and a filter press under our direction
and he was actually getting a substantial rebate. Here is the story. About
every five weeks a truckload is shipped and if the zinc content is fourteen
percent, the price is $1200, but if the zinc content is high, the price can
be as low as $500 plus freight. Is there any doubt that this is the cost-
effective way? Do not think of this as a zinc haulaway, but one that takes
the "inert" dirt in the cleaner tank, the inseparable metals in the pickle,
the hard to handle strippers and the daily post treatment dumps. Just as
Zerpol gives you end-of-pipe perfection, smelting gives you inert fused nuggets.
In summary, we must give the plater total answers, practical, econoni-
cal ones. If plating becomes too expensive, industry will turn to painting.
Therein lies the danger of toxic organics. If source reduction becomes too
tough, the plater will turn to dilution and a waste of our most important re-
source - clean water. Our solutions must be permanent answers for the eons
of time to come.
197
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A Waste Reduction Audit Workshop for the
Metal Plating & Finishing Industry
Presented by
Robert H. Salvesen, Ph.D.
S&D Engineering Services, Inc.
Metuchen, New Jersey
-------
1. Introduction
This paper will cover the following aspects of the metal plating and finishing
industry:
o Solvents used
o Source and Nature of Waste
o Reclamation Options
o Waste Reduction Practices and Examples
A paper entitled "Waste Minimization Alternate Recovery Technologies" (D*
which appeared in 1986 provides an excellent summary of recovery and recycling
technologies for metallic sludges and aqueous systems used in the industry.
Proper management of the organic materials used can result in significant
reduction in the volumes and costs of wastes to be disposed. In order to
accomplish these objectives, it is helpful to get a better understanding of
what materials are used, and handling, treatment, recycling and disposal
options that are available.
* Numbers in parenthesis indicate reference given at the end of this paper
198
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2. Types of Solvents and Other Materials Used
The major used solvents generated by the Metal Plating and Finishing industry
nay be classified as follows:
o General purpose cleaners
o Carbon removers and paint strippers
o Halogenated Solvents
A discussion of the types of materials used follows:
2.1 General Purpose Cleaners
Hydrocarbon solvents are most commonly used for this purpose. They may be
called by different names, but are generally very similar in properties. In
the petroleum industry they an designated as mineral spirits or naphtha.
However, some products may have additives which appeal to individual shops and
are preferred over other products. For example, some products may contain the
following types of additives:
o Detergents - these can provide better penetration of oil and grease on
automotive parts and also allow water washing for cleanup.
o Lanolin - this and other similar additives may be added to leave a
residue on the skin to reduce skin irritation.
o Color and perfumes - to provide a recognizable more attractive product.
There can be some real differences in the basic properties of petroleum
products used for these purposes, however, the industry usually does not
distinguish among them. For example, the higher the aromatic content of the
mineral spirits, the better the solvent power.
Products supplied by service organizations, such as, Safety-Kleen and others
are general purpose hydrocarbon based cleaners.
Other solvents used are noted below along with brief comments:
o High flash naphtha - this is a petroleum hydrocarbon with a Flash Point
above 140 F to provide an added safety factor. All petroleum general
purpose cleaners such as those noted above should have a Flash Point of
100 F niininfMI
o Odorless solvent - some shops have been found to use an odorless paint
thinner for general purpose cleaning. While this solvent smells nice
and can do a good job, it takes more "elbow grease" to remove oil and
grease and also costs more.
o Safety solvents - these may be a High Flash naphtha such as noted
above, or a blend of hydrocarbon and chlorinated (i.e. Methylene
chloride) or Freon solvents. Such solvents can serve a very useful
purpose, and may be required in some applications. However, solvents
containing chlorinated or Freon solvents are often not desired for some
uses because of the concern for corrosion if left on components. Freon
solvents are less of a concern than chlorinated solvents.
o Ethyl Acetate - This is a pure chemical and is used either in dip tanks
or vapor degreasers. It is a highly volatile and flammable solvent
that is generally being replaced by TCA (Triehloroethane).
199
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2.2 Carbon Removers and Paint Strippers
While these products differ in some respects, they are similar in that they
generally contain two or more of the following:
o Hydrocarbons
o Chlorinated solvents (generally methylene chloride)
o Phenolic compounds
o Alcohols, esters, ethers
o Colors, detergents, and odorants
These are powerful solvents and a wide variety of formulations are available
especially for removal of different types of paint.
2.3 Hplogenated Solvents
Halogenated solvents used include a variety of chlorinated solvents and Freon
113. Several popular chlorinated solvents have been designated as potential
carciniogens by EPA and thus the major products still in use are:
o Methylene chloride
o Trichloroethane (TCA)
o Freon 113
Reference has been made above to the use of methylene chloride in cleaners and
strippers. This material and TCA are also used to clean electrical parts.
Freon 113 and TCA are also used for precision cleaning of bearings. The major
benefits of these halogenated solvents are:
o High solvent/cleaning power
o Rapid evaporation rate (low residue)
o Non-flaramability
2.4 Other Materials
Aqueous based emulsion and alkaline solutions are used for a number of
stripping and cleaning applications. A wide variety of detergents can be used
for cleaning purposes, which generally contain phosphates and/or organic
compounds. These may be used in conjunction with steam or hot water systems.
Alkaline solutions may contain either sodium hydroxide (caustic soda) or
organic amines. These are generally used in dip tanks and must be handled by
trained personnel, since they can cause severe skin burns and are very toxic.
3. Generation and Properties of Used Materialg
3.1 Used Solvents
Used solvents may be defined as any used organic fluid contaminated as a
result of use for cleaning, thinning, or use as a solvent, antifreeze or
similar purpose. Used solvents are generally volatile in nature. They
include hydrocarbons, halogenated hydrocarbons, oxygenated hydrocarbons and
mixtures of these materials.
200
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Used cleaning solvents are generally produced by spraying, physical or vapor
washing, dipping and other means.
Typical properties for used hydrocarbon, TCA and Freon 113 solvents are given
in Tables 3-1, 2 and 3 along with properties of virgin or reclaimed solvents.
Properties for virgin and reclamed solvents should be essentially the same
and can generally be accomplished with available resources. Ethyl acetate is
a pure compound with a boiling point of 171°F.
201
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Table 3-1
Typical Properties of Used, Virgin or Reclaimed Hydrocarbon Cleaning Solvent
Test Method
ASTM-D-56
ASTM-D-86
Test
Flash Point, TCC,F
Distillation,F
IBP
10%
20%
30%
40%
SOX
60%
70%
SOX
90X
FBP
Residue
Chlorine Content
Water, Oil & SedloentX ASTM-D-95
Appearance Visual
Properties For
Used
Solvent
< 100- 140
150-330
150-340
170-340
300-345
320-350
325-350
330-370
340-390
350-400
400-600
Above 500
Virgin or
Reclaimed
Hydrocarbon
Solvent
102-110
315-330
320-340
325-350
330-365
350-400
Virgin or
Reclaimed
High. Flash
Solvent
140 mm
355-360
360-370
365-380
375-390
415 Max
30 VolX (tax) 2-5 VolX
2-20
Brown/
Black
<0.1
Clear/
White
2-5 VolX
Clear/
White
202
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Table 3-2
Typical Properties of Used, Virgin, or Reclaimed TCA Solvent
Properties For
Flash Point, TCC/F
Distillation, F
IBP
50%
FBP
Residue
Water Content, ppm
Appearance
Specific Gravity
a 25 C
Acid Acceptance No.
og NaOH
Test Method
ASTMD1310
ASTMD1078
16822A
Visual
ASTMD2111
16822A(«)
Used
Solvent
None
149+
190-
250
500+
10-40X
1-5%
Black
1.15-1.3
Virgin or Reclaimed
Solvent
None
171
190
10 ppm (Max)
100 ppm (Max)
Clear /White
1.317-1.324
0.20 (Mini
(*) Need to check supplier for details of tests to be run and additives
required to reformulate reclaimed solvent.
203
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Table 3-3
Typical Properties For Used and Virgin Freon 113
Properties For
Test Method
Boiling Point,F
Residue
Water Content, ppm
Appearance
Specific Gravity
9 25 C
Acid Number, rag KQH
Participate Matter
25-100/100 ml
(*)
(*)
Karl Fisher
Visual
ASTMD2111
(*)
Used
Solvent
104+
20X (max)
1-5X
Brown/Black
1.2-1.565
<0.5
100+
Virgin Solvent
117.6
< 2 ppm
<10 ppm (Max)
Clear/White
1.565
0,003 (Max)
100 (Max)
* See DuPont Technical Bulletin for details
204
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4. Reclamation Options
4.1 Used Solvents
Both on and off site options are available for solvent reclamation. The major
options are:
o Distillation on site - this is appropriate for most solvents except
carbon and paint strippers provided the economics can be justified.
o Off site toll recycling - outside contractors will reclaim and return
solvents to the user for a service (toll) charge). This is generally
Limited to hydrocarbon solvents and carbon removers. However, these
services are not universally available.
o Off site recycling - outside contractors will buy or accept many but
not all solvents for reclamation. Generally only large volume
generators can be serviced.
4.2 Other Materials
Aqueous emulsions - high water content emulsions need to be treated to
separate out the oils and grease. The clean water can be discharged to a
sewer (where permitted) and the oil and grease disposed.
Caustics - these materials should be neutralized carefully and treated in an
industrial wastewater treatment plant.
Further details and examples of hazardous waste reduction in management of
used oils and solvents are given in the next section.
PUS Waste Reduction Practices
5.1 Audits
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.
A standard format is given in Table 5-1 (2). As can to been from the
complexity of the audit form the information needed to do a thorough job can
be extensive. However, in many cases it is quite simple, but it is essential
to know what is being used, how it is used and how are the waste managed.
The benefits of an audit are as follows:
o It requires thought and consideration of current practices
o Materials are identified by chemical types and properties
o Evaluation should reveal opportunities for improvement
o Regulatory deficiencies should be identified
o Corrective actions can be initiated
205
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Table 5-1
Standard Waste Audit Format - Automotive Repairs (2)
o Same and location of shop or business
o Mame 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
- Qjick 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
Item Raw Descrip. Hazard ID No. Density Quantity Stor-
Material Clan Ib/gal Used Disposed age
gals/ gals/ Fac.
mo mo gals.
Ex 1 Parts Petroleum Combustible 7 50 50 250
etc. Cleaning Solvent Liquid
Solvent HP 310-3470F
o Raw Material Storage (Complete for each item)
- Raw material (Brand name/common name)
- Item No.
- Volume in Inventory
- Describe usage
- Describe disposal practice
- Describe storage facilities
ie. 55 gal drum
Containers (Volume)
Above underground tank
Coverc-. jpen
Indoor/outdoor
Secured
206
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Table 5-1 - continued
- Delivery system
ie. Gravity
Funnel
Pump
- Material Control Practices
ie. Stockroom attendant
Access (Limited/Unlimited)
Signout sheet
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 (Describe, if yes)
- If no segregation describe practice
- What options are available for segregation
- Storage facilities (describe)
- Disposal practices
ie. On-site recycling
Serviced by Equipment Leasee/Maintenance Contractor
Picked up by contractor
Disposed in Municipal Solid Waste
Disposed to Municipal Sewer
- Disposal Costs
Oils
Solvents
Residues/Sludges
Antifreeze
Aqueous materials
Others
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
207
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5.2 Identifications of Options
Once the audit has been completed, it is necessa. to consider whe.-. options
for waste management are appropriate. The major areas for consideration are
noted below.
5.2.1 Material Selection
Can other ;aaterial be found that will reduce the volume and management
problems?
Example - For the Navy, a Flash Point minimum of 140 F is essential for
reclamation as a fuel. By changing from low to high flash cleaning solvent,
the used solvent could be blended with used oils and burned in their
powerhouse. Recycling this solvent was not practical because of the low
volumes and no off-site services were available.
Example - A large repair shop switched from TCA to High Flash Petroleum
solvent because of a concern about the toxicity of TCA. Those operations
involving mechanical equipment favored the change because of the oily film
left on cleaned parts. By contrast, those involving electrical equipment did
not like the change because of the oily residue.
Example - A shop using TCE was convinced by a supplier to change to a
reportedly safer hydrocarbon solvent. The material provided was an odorless
paint thinner which did not have the desired solvent power.
Example - Users of hydrocarbon cleaning solvents are convinced to switch to
detergent formulations for cleaning all types of mechanical and electrical
parts. While the cleaners may perform satisfactorily, the used aqueous
mixture may or may not be legally disposed to the sewer.
Example - Hydrocarbon cleaning solvent is used to clean high precision
bearings. There used product can then be distributed to less critical parts
cleaning operations.
5.2.2 Segregation
Segregation is probably the single most important and readily manageable
practice which can have a major impact on hazardous waste reduction. Past
practices generally have not mandated segregation so all of us dump into the
nearest waste container and let the disposer handle the wastes. Segregation
is essential to not only proper but any kind of management of all types of
wastes.
Segregation into various types of used solvents is a must to reduce both costs
and problems. Grouping by the following types of materials can be useful.
o Individual Solvents
Each solvent should be kept separate to optimize the potential for recycling
whenever possible. In cases where disposal options and costs are not affected
by composition, segregation may not be appropriate.
208
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o Low Flash Materials and Mixtures with Halogenated Solvents
Materials with a Flash Point below 10OF and mixtures with halogenated
solvents, especially low volumes are difficult to recycle and dispose.
Generally the generator will have to either avoid these materials or pay the
costs for disposal.
Example - Many shops dispose of solvents in a common receptacle. This
practice generally increases disposal costs. Segregation is mandated in many
areas, but is dependent upon local options.
5.2.3 Recycling
5.2.3.1 Solvents
Options were noted in Section 4.1 for recycling solvents and include on and
off site recycling. On-site options require purchase of simple equipment to
recycle segregated solvents. Off-site options include toll recyclers and
reprocessors.
o On-site Recycling
Numerous suppliers provide equipment for recycling of almost all solvents.
The equipment does not provide fractionation or separation of solvents.
Equipment sizes range from 5 - 500 gals/day and costs range from $2 - 3,000 on
up. There are two major types of equipment.
- Externally heated vessels with or without vacuum attachments for high
boiling solvents
- Steam injection units where live stream is injected into the solvent and
both are distilled and condensed. This is appropriate only for water
immiscible solvents.
Examples
- A road asphalt supplier used a 5 gal/day still to recycle chlorinated
solvents from laboratory testing operations. This is done to minimize
disposal problems.
- Many firms have in-house solvent stills to recycle solvents such as:
Shipyards - hydrocarbons, Freona, paints
Machine shopa - hydrocarbons, TCA
Electrical motor rebuilders - TCA
Ink manufacturers - organic chemicals, etc.
- Hydraulic shops use a stream injection unit to remove TCA from hydraulic
oils. The TCA and oils are recycled.
o Off-site Recycling
Many solvent recyclers are available to handle relatively large generators of
solvents. The National Association of Solvent Recyclers lists 15-20 major
companies in the eastern US. These firms service a radius of up to about 500
miles.
Toll recyclers provide service to both small and large industries. One
209
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example i3 Safety-Kleen, others also provide this type service. Toll
recyclers rent the equipment and solvent, when it is dirty the solvent is
replaced and the unit serviced (filter cleaned or replaced). They charge for
this service, but it relieves industries from handling wastes. A major
problem of toll recyclers is that their services are generally limited to
petroleum hydrocarbon cleaning solvents and carburator cleaners. Paint and
halogenated solvents are not generally accepted. However, this may change as
the industry sees the need.
6. Conclusions
Management of used solvents is becoming more of a necessity and burden to all.
However, it is necessary to protect our environment especially our water
resources. Indescriminant disposal of wastes can no longer be tolerated. ^1
solvents encountered in visits to hundreds of shops in this country and
overseas have been found to be recyclable. The economics and best management
practices need to be evaluated generally on a site-by-site basis in order to
select the optimum system. In many locations solvent recycling equipment can
be paid off in 2-10 years depending upon the volumes and costs of the
solvents.
210
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References
1. Steward, F.A., & McCay, W.J., "Waste Minimization Alternate Recovery
Technologies" Metal Finishing Guidebook & Directory 1986 Edition
211
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A Hazardous Waste Reduction Audit of
Pioneer Metal Finishing, Inc.
Presented by
Harry DeSoi
Pioneer Metal Finishing, Inc.
Franklin, New Jersey
-------
Hazardous Waste Reduction Audit
of
Pioneer Metal Finishing Inc.
As with solving any problem the problem must be clearly identified
and the final goal must be clearly defined. Pioneer Metal
Finishing Inc. provides a service to manufactures. This
service is to electroplate copper, nickel and chrome onto
substrate metals consisting of steel, cast steel, zinc diecasting
and brass. The buffing room had potential air problems but
they will not be discussed at this time.
The problems
areas:
were identified and divided* into the following
Hex-Chrome tanks
Cyanide-Copper tanks
Nickel tanks
Cleaner ranks
Acid tanks
The most serious problems were yet to be identified.
#1
#2
#3
#4
#5
Dragout
Dragout
Dragout
Dragout
Dragout
from
from
from
from
from
#6 Periodic dump of
#7 Periodic curap of
#8 Periodic dump of
quantities of Zn and
#9 Periodic dump of
metal and very high
Diecast soak
Oil containing Ste~el soa'<
Diecast electro-cleaner containing
Cu and Cr.
steel electro-cleaner containing Cr
content of caustic.
large
#10 Periodic dump
#11 Periodic dump
copper plus up to
#12 Periodic dump
content of copper,
of II sulfuric with up to 2000 ppm zinc
of 75% hydrochloric with up to 1000 ppm
600 Ib of ferric-chloride
of saturated rack strip with very high
nickel and chrome
rejects
#13 Periodic dump of saturated strip used to strip
This contains high volumes of copper and nickel.
#16 Water from vibratory finishing containing large volume
of zinc metal, media (ceramic and plastic) and vibratory
compounds that do not want to let go of the metal.
Upon close examination we discovered that we had problems
within problems that were not to be solved by simple treatment
steps. Most treatment "experts" selling treatment systems
had very little experience in solving problems when small
quantities of metals were left in the water that had to be
discharged. They were good at getting 300 and 400 ppm of
metal out but were confused when you get down to 6 to 10
ppm and the remaining metal will not drop out. Some of these
chemical companies have admited that their proprietor/ chemicals
will not release all of the metal by using conventional treatment
methods. Some act as if it is not a problem while others
212
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ace concerned.
Through trial and error we found these additional problems:
#15 One soak tank contained a chemical that at a pH of 9.5
to 10 retained metals.
#16 One elecrocleaner was heavy formulate with chemicals
used very widely in the cleaning industry which are very
difficult to treat.
#17 One plating bath contained enough ammonia to retain enough
metals to place our discharge violation even after treatment.
#18 Concentrated strip would not treat by conventional methods
The most serious compliance problem of all came last. If
we could install a system that would produce acceptable water
on a reliable basis what would me do to stay in compliance
as equipment ages and normal unexpected problems present
themselves? On a normal day there are many variables in
the plating that create some rejects. In waste treatment
there could be many variables that could produce water in
violation of State and Federal laws.
Reducing £2££!H£!!
Now that we found most of our problems we had to look at
the expense of correcting these problems. The cost of equipment
is significant but the week to week expenses can even be
more detrimental. We had to look at the most expensive treatment
problems and see if we could change some of :he products
we were using.
#1 We changed one of our soak solutions to one that is more
treatable .
#2 We changed products in one of our electroc leaners to
a product that treats quite easily.
#3 We changed from hexovalent chrome to tri-valent chrome
in our chrome plating line. We then went to a tri-valent
chrome containing no ammonia. Trivalent chrome is treated
by simply raising the pH to 9.5. Hexovalent chrome solutions
are 20 times more concentrated with metal and very costly
to treat.
#4 We installed spray rinsing, educated employees, redesigned
plating racks and increased drip time to conserve on chemicals
drug out of plating baths.
#5 Replaced batch dump strips with electro strips that can
be filtered. Batch strips are very expensive to treat.
Most must be greatly diluted to be treated properly if they
are cyanide strips.
#6 The greatest area to reduce expenses was in the type'
of treatment. From 1975 to 1981 we used a segregated-cont inuous
discharge system. From 1981 to present (1987) we have used
a close looped batch treatment system.
Continuous discharge system was heavy on chemical use, heavy
on maintainance , heavy on sludge production and heavy on
213
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labor. Approximate expenses were 102 of gross sales. Batch
treatment-Close Loop system has low chemical use, low on
maintainance , low in sludge production and very low on labor.
Approximate expenses are 3% of gross sales.
The most threatening liability is the potential of discharging
in violation of Federal, State or local laws. The way we
reduced this liability to the lowest possibility was to replace
our continuous discharge system with a close-loop system
that captures all rinses water and dumps, treats water, desalts
the water through modified boilers and reuses the water.
While there was water leaving the plant the liability factor
was greatly increased. With no process water leaving the
plant the liability factor is greatly reduced.
Other steps to reduce liability is to reuse as much as possible
in the plant, substitute less toxic chemicals for more toxic
ones and throughly investigate the companies to be used to
haul any waste from the plant.
214
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WATER FROM PLANT
IX)
I
en
TREATMENT TANK B
TREATMENT TANK A
uUDGE
SLUDCJE CONCENTRATOR
TREATED HATER
TO BE REUSED IN PLANT
Tfl HTN1R TANKS
STEAM RETURN
Modified
BOILER
DISTILLED UATER TO
BE USED IN PRIME
RINSES
Pioneer Metal Finishing Inc
Close-Loop treatment system
(Zerpol)
iStartup Aug. 1981
-------
PIONEER METAL FINISHING INC.
CONTINUOUS DISCHARGE SYSTEM
(Purification Industries)
OPERATION 1975-Aug. 1981
CENTRIFUGE.
O
final
PH
fi t
CYANIDE WASTE
WASTE
CHROME WASTE
PUMPS 14
Q MIXERS , S
A PROBES > 5
-------
A Waste Audit/Reduction Program for the Printing Industry
Presented by
Richard A. Goldbach
Environmental Coordinator
United States Printing Ink Corporation
East Rutherford, New Jersey
-------
Waste Audit/Redaction Program
UNITED STATES PRINTING INK CORPORATION
The increasing liabilities and public concern with the environmental
exposure to hazardous chemicals and substances have increased the
concerns of the Corporate Headquarters. Besides the EPA regulations
dealing with RCRA and hazardous waste, many states have adopted
more stringent regulations which increase the scope of what is con-
sidered a hazardous waste or nonhazardous waste. It doesn't really
matter if the material is a nonhazardous waste if you are to dispose
of this material in a secure landfill. In five, ten, twenty years
from now it might be considered a hazardous substance, therefore, we
would be liable for any Superfund cleanup at a site even though the
material itself might not be a hazardous material. This is due to
the EPA regulations changing and redefining the chazacteristics of a
hazardous substance.
We have to look at the many characteristics of waste and determine the
alternative for disposal of the material which may include waste re-
duction, landfilling, incineration, or recycling. All of these things
must be taken into consideration when we are thinking about Corporate
Capital Expenditures for the year. Many incentives for the reduction
of waste generation are being considered by the Corporate office. It
is desirable as far as environmental, it can reduce our potential
liability for problems associated with the offsite waste handling
and disposal. We must evaluate our waste streams to determine if
waste minimization, source reduction, recycling, waste treatment or
incineration would be the best alternative for our waste generation.
The best alternative at the present time would be incineration since
total destruction of the waste would prevent further liabilities from
superfund sites. To accomplish such a program would require the
committment of top management, allocation of funds and basically the
217
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support of Che technical staff to investigate alternative methods of
waste reduction and routes of disposal. Although the initial objectives
may not return a net profit for the company, in the future it may pre-
vent or lessen the liabilities and clean-up cost.
To establish an Environmental Audit/Reduction Program, we must plan and
have scopes of investigation in mind. Waste is not the only by-product
of concern, we have other items which might also be included, such as,
waste water discharge, air pollution control, and empty drum disposal.
In order to determine what approach we are going to take in this pro-
gram we have to first determine what are our waste streams, how are
they generated, and what are the waste characteristics. Are these waste
streams hazardous or nonhazardous according to State and/or Federal
regulations? This does not make any difference in today's rules and
regulations because what eventually might happen is that the material
which is not a hazardous waste today could be a hazardous waste tomor-
row. We have to review our processes and formulations to determine if
any of the materials can be replaced or eliminated to deter the type of
waste generated and reduce the volume. Research and development will
have to play an important roll in the reformulation and reduction program.
To begin our Waste Audit/Reduction Program we have to first have a
pre-audit schedule of each of the individual plants, meaning we need
to prepare a list and Inspection agenda, compile data and select target
waste streams, inspect the plants, generate a comprehensive list of
minimization objectives, evaluate the options and select the options for
further analyses. He would have to conduct technical and economical
feasibility studies, suggest preferred options, design and construct
major monitoring performance programs. Determination of the waste
streams would include:
A. What are the waste streams generated?
B. How can we reduce them?
C. Is there a way of eliminating them?
D. How do we determine if the material is actually a
hazardous waste?
218
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Once we have determined the above, we have to look at the options chat
are available in today's technology. We could consider the possibility
of purchasing a higher grade of raw material, tighten our equipment
inspections, improve our operators training and provide closer super-
vision of our personnel.
One of our main objectives here is to reduce our waste volume and that
may be accomplished by segregating the different waste streams and using
recycling drums, buying raw material in bulk, purchasing the material in
pre-weighed packages, and investigating the improvement of mechntcal
operation of equipment through engineering. We would have to ask our-
selves:
A. Is this the best way of handling this material?
B. Is it the best to optimize the waste generation?
C. Is there a better way that we can develope and incorporate
into our production?
It isn't waste generation alone that is important, we have to take into
consideration also the waste that is generated through clean-up of plant
equipment, floor cleaning and general housekeeping of the plant. In
fact, sometimes the cleaning materials that are utilized to clean the
equipment and plant are worse than the actual waste streams generated
from production. Of course any waste reduction program that we would
set into effect would have to be cose effective, not only for the plants
but for the corporation itself. Therefore, we would have to evaluate
each of our alternatives very closely, and evaluate each one individually.
Due to the fact that our waste streams are basically nonhazardous, dis-
posal can be accomplished with minimal problems; therefore, we at United
States Printing Ink Corporation have decided that all waste should be
incinerated. The ink oils used in production are pure and have a high
BTU value making our waste ink streams very economical for incineration.
The waste can be used as a supplementary fuel to heat cement kilns and
219
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other type of incerators which require a high BTU value waste stream.
By incineration of our waste it would eliminate many of the possible
liabilities that would be involved in land disposal. At the present
time we are investigating a situation which would incorporate all of
our plants throughout the twelve states in which our manufacturing
plants are located, to have our waste incinerated at specific cement
kilns. The largest problem we are currently faced with is- the high
viscosity of our waste inks. For them to be incinerated the viscosity
would have to be greatly reduced. The waste ink viscocity would have
to be below 200 cps in order for the material to be atomized econ-
omically in the kiln.
Understanding the Resource Conservation and Recovery Act (RCRA) rules
and regulations can cause confusion in the determination of what act-
ually constitutes a hazardous waste. As ink manufacturer we work with
and assist our customers to develope an understanding of the RCRA rules
and regulations in order for the disposal of their generated waste. We
suggest to our customers that they should segregate their waste streams,
solid froa liquid, in order to prevent any possibility of cross con-
tamination from pressroom materials which might alter the waste charact-
eristics. Waste ink according to RCRA is a nonhazardous waste, it is
noncorrosive, nonreactive, aonignitable, and non-EF Toxic based upon
numerous tests performed by outside certified laboratories. We strongly
urge all of our?custoaers to segregate their pressroom material and
dispose of it legally and properly. You must have an EPA ID number for
manifesting of the waste even if the material is not a hazardous waste;
when it comes down to it if you don't know where your waste went you
will still be liable for it. You must keep in mind that the generator
of a waste stream is liable no matter to whom you release your waste to.
It is your responsibility to know where it is.'going, what will happen
to it, and how the facility will secure it from contaminating the envir-
onment. If your waste should end up in a river or along a roadside you
can be held responsible for any cleanup cost and contamination, you could
even be faced with the possibility of a willfuf violation of the RCRA
regulations.
220
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Investigation of the waste disposal facility is very important. Even
though the state may say at this time that everything seems to be in order
and that there are not any violations against the disposal facility, you
don't know what is going to happen tomorrow. Very close tabs have to be
taken with the selection of a disposal facility. Investigate then, look
at them, visit them if possible and determine how they are handling c^
waste.' Are there alot of spills on the ground? How is their housekee. _ng7
Where are they disposing of their empty containers? Do they have the
proper EPA ID numbers and are they allowed to accept this type of waste
stream? Do they carry enough liability insurance to cover any superfund
clean-up due to contamination? Liability extends beyond your waste stream,
beyond anything you can think of. If you produce any type of waste,
hazardous or nonhazardous, you are still responsible for it and therefore
you should know what's happening to it. No matter what type of waste is
generated, remember, handle all waste in an environmentally sound manner.
Destroy or recycle waste rather than contain or bury them. Whenever
feasible you should work the waste ink back into the ink system, of course
this can only be done with the segregation of your waste.
If you are not registered with the EPA as a generator or small quantity
generator, you should obtain an EPA number. By doing this it would allow
you to dispose of your waste with legally documented manifest. Even
though you might be considered a small quantity generator, that is a person
that generates between 100 kilo's to 1000 kilo's or 220 pounds to 2,200
pounds a month, you are still regulated under RCRA and you have to keep
certain records and manifest available for state and/or federal inspections.
If you need assistance with the small quantity generator rules and
regulations, you have many organizations available to you that are quite
versed in the situation (AN?A, GATF, PIA). They have programs established
that can help you with waste disposal information, possible collection
points within your local, and suggestions for the reduction of your waste
volume. Liability insurance is very expensive now a days and it's only
going to increase, therefore, we must learn to reduce our waste volume.
Capital expenditures may be high but down the line it will save you and
your company many problems including financial and possibly criminal
221
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charges if it is a willful violation of Che RCRA Act. Through a wasce
audit/ reduction program, you could evaluate and determine what are your
best alternatives, and what is the most reasonable method for financial
outlay.
Submitted by
Richard A. Goldbach
Environmer al Coordinator
United States Printing Ink Corporation
222
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Hybrid Membrane Systems In Waste Management
Presented by
William F. Weber
Du Font Separation System
E. I. Du Pont De Nemours & Co. (Inc.)
Wilmington, Delaware
(Originally Presented at the Membrane Technology Planning Conference
Cambridge, Massachusetts - November 6, 1986)
-------
INTRODUCTION
Whenever one is pursuing a new market, there are several
basic questions which need to be answered.
The crossflow membrane filtration market is no different.
MARKET POTENTIAL
The first question one hears is: "How big is the market?"
Last year, we outlined Du Pont's perspective to this ques-
tion. As you'll recall, the forecast for sales of membrane
systems and services in gas and liquid processing applications
was expected to increase from $500MM in 1985 to over $2MMM by
1995.
Our experience since that time has confirmed that there are
significant and emerging opportunities for membranes in food
processing, aqueous waste management, gas separations and
biotechnical applications. Specifically in the market of treat-
ment of hazardous wastes, the potential for the use of membrane
systems is outstanding. As can be seen in Figure 1, approximate-
ly 270 million tons of hazardous wastes regulated under the
Resource Conservation and Recovery Act (RCRA) are generated in
the United States annually. Over 60 percent of this total is in
the form of dilute aqueous wastes, most of which contains 0.1-1.0
percent of hazardous constituents. Industry spends about 11 to
12 billion dollars a year to treat these wastes. Historically,
most of this treatment has consisted of on-site conventional
primary and/or secondary treatment prior to discharge to a local
surface water or municipal sewer. However, the regulations on
-------
these discharges is being tightened every year, mandating the
need for additional treatment. The technologies being looked
upon as most likely to fill this treatment gap are carbon absorp-
tion, ion exchange, steam/air stripping and membrane separation.
If membranes can be adopted to even a small portion of this
opportunity, it will represent a very attractive market niche to
go after. We estimate membrane systems and services sold into
this emerging market niche within the last year was over $25
million dollars.
CRITICAL SUCCESS FACTORS
Once one has sufficiently proven that the opportunity is
a large enough carrot to go after, the next question is "What do
we have to do to get it?".
First, one has to be sure to target the right applications,
especially because in most waste treatment cases membranes are
only one of several alternate separation technologies available.
Therefore, to determine whether or not membranes are right for a
given application, one must consider the specific site conditions
such as:
o System Size - flow rates up to 100,000 gallons per day
(gpd) are often attractive.
o Nature of Constituents to be Removed - the higher the
molecular weight, the better.
o Purity Requirements - removal of over 95 percent often
needs polishing steps in addition to membrane separa-
tions.
224
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But even if a potential application fits these criteria,
there are several other even more important critical success
factors required from the supplier of the membrane system, as
follows:
o Understanding of the membrane capabilities and limita-
tions.
o Access to various kinds of membranes - including
microfiltration, ultrafiltration and reverse osmosis -
as well as various configurations - such as spiral,
hollow fiber, tubular and plate and frame.
o Ability to provide non-membrane options for
pretreatment, polishing and/or ultimate disposal.
o Ability to engineer the integration of membrane unit
processes with other unit processes into a hybrid
system.
o Ability to deliver a low cost system.
o Ability to provide full service for these systems,
including start-up, operation and troubleshooting.
It is worth repeating that the capability to integrate
membranes into an overall hybrid separation system is critical to
be successful in emerging separation applications.
225
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CASE HISTORIES
Finally, once one has reasoned that a target market is big
enough at which to shoot, and one has determined a direction in
which to shoot, only one question remains - "Can you prove it?".
The remainder of this paper will give a brief review of some
of the applications in which we have recently been involved which
begin to "prove out" that membrane systems do work!
1.) TEXTILE FINISH WASTE
The first case deals with the use of a membrane system
to concentrate industrial wastes for more economical dispos-
al. It involves textile finish wastes from the manufacture
of synthetic textile fibers.
Textile finish wastes are similar in some respects to
metal finishing oils, but they can be more difficult to
treat because each textile product may use a different
finish formulation and each plant uses a variety of finishes
simultaneously. A typical formulation may contain 8 to 10
components, many of which are proprietary. In general
though, the finish is a mixture of surfactants, oils and
polymers.
At this site, the waste disposal problem was two-fold.
First, the permit for the existing disposal technique of
spray irrigation onto a field was about to expire and the
manufacturer did not expect it to be renewed. Secondly, the
manufacturer was introducing several new finish formulations
226
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into the process which would introduce a solution waste in
addition to the previous emulsion waste.
The first proposed remediation scheme can be seen in
Figure 2. It consisted of a dual collection system to
segregate the emulsion and solution waste and an alum
treatment system to chemically split the emulsion into oil
and water phases. The remaining water from the emulsion
would be treated on site by biotreatment and the emulsion
sludge and solution waste were to be shipped off site for
disposal.
As an alternate, we proposed to install a membrane
system to treat the the combined finish oil wastes from the
entire plant, thereby eliminating the need for the dual
collection system and the alum treatment plant (see Figure
3). We conducted pilot tests with both simulated waste
streams and actual plant samples using both spiral wound and
hollow fiber membranes. We found that although both mem-
branes suffered an almost immediate reduction in productivi-
ty, after the system had stabilized, the hollow fiber
devices yielded a higher productivity. The reason for this
was traced to the surface active ingredients in the finish-
es, which coat the membrane and reduce their permeability to
water. Having a much higher water flux, the spiral wound
elements suffered from this effect much more severely than
the hollow fiber. As seen in Figure 4, the pilot study
results for the hollow fiber membranes were very
227
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encouraging. High volume reduction of both emulsion and
soluble wastes was achieved with extremely low penetration
of finish through the membrane.
Based on the pilot test results, this alternate
remediation scheme was chosen for the full scale system
which is shown in Figure 5. It is a 5 gallon per minute
(gpm) system which operates in a batch mode for about 3 to 6
hours per day. The waste from the various spinning machines
are put into a collection tank to allow the de-emulsified
oils to rise to the sarface. This material is decanted into
drums for incineration. The remaining liquid is pumped
through a 1 micron filter and then a biocide is added. From
the RO feed tank, the material ia filtered again, put
through a heat exchanger to maintain 86°F, and pumped at 400
psig to parallel hollow fiber permeators. The permeate goes
directly to the biotreatment facilities and the concentrate
is recycled back to the feed tank. In this way, the oils
are concentrated to as much as 35% by weight.
After each batch treatment, a regular cleaning of the
membranes is done with a detergent solution at a reduced
pressure. This prevents any residual oils from
de-emulsifying within the permeators. Once completed, the
spent cleaning solution is added to the RO feed tank.
We found that membranes performance could be improved
by the addition of certain detergent agents to the feed tank
which had the effect of improving circulation in the
228
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permeators. We use what we call a "working solution"
method, in which we estimate the quantity of detergent
necessary to concentrate a given volume of waste and added
it to the feed tank as it is filled the first time.
This system has proven to be extremely cost-effective
(see Figure 6). By eliminating the alum splitting system
and dual waste collection for each machine, capital costs
were reduced from $900,000 to $150,000 for the membrane
system. More importantly, due to the volume reduction of
waste for off site disposal, disposal costs have been
reduced by over $250,000 per year. Due to the success of
this system, several other textile manufacturing plants have
modelled waste concentration systems after this one.
2.) PETROLEUM PRODUCTION BYPRODUCTS
Another example of waste concentration involves the
byproduct stream from offshore oil production. It illus-
trates the flexibility and varied experience that a membrane
supplier who is also a large industrial company can bring to
developmental technologies as well as commercial ones.
The byproduct stream consists primarily of seawater
with residual amounts of organics, primarily acetate-type
compounds with molecular weights ranging from 80 to 110.
The organic level was about 80 percent higher than the EPA
limit however, which prevented the disposal of this
byproduct stream directly back into the sea.
229
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A pilot program was developed to determine if an
on-site, space-efficient, low-cost treatment system could be
designed to eliminate or greatly reduce the volume of
wastewater being shipped to land for disposal. The studies
looked at both hollow fiber and spiral wound reverse osmosis
membranes as well as spiral wound ultrafiltration membranes.
The ultrafiltration membranes had insufficient rejection
rates of the organics and the standard seawater RO membranes
had unacceptable recovery rates, primarily due to osmotic
pressure buildup.
Therefore, evaluations were also made on several
reverse osmosis membranes being developed to operate at feed
pressures up to 1500 psig. These membranes are tailored to
provide variable passage of selected constituents.
As can be seen in Figure 7, in this case, the rejec-
tions of the acetate-type compounds was quite good while
much more salt was allowed to pass through the membrane. In
fact, the use of these membranes in the system reduced
osmotic pressure buildup and achieved higher recovery
rates/volume reductions. The system we designed was able to
produce product water whose quality was well within the EPA
disposal limits (80 percent organic reduction) as well as
reduce the volume of the brine stream by a factor of 5 to 10
times.
230
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3.) GROUNDWATER REMEDIATION
In this case, membranes economically assisted more
conventional remediation technologies to restore groundwater
which had been contaminated with industrial processing
waste. At the site in question, the originally proposed
remediation scheme called for a groundwater withdrawal of
130,000 gallons per day via a drain tile collection system
for subsequent treatment. It was determined that this
groundwater flowing into the collection system was picking
up in excess of 200 pounds of wastes (primarily volatile
organics) per day. The treatment objective was to remove
over 98 percent of the total groundwater volatile organic
compounds (VOC) and reduce each VOC constituent to no
greater than 50 parts per billion (Figure 8).
Four alternative treatment systems were considered:
o biodegradation in a retention pond, which was consid-
ered too expensive;
o air stripping, which was politically unacceptable in
the area since it would essentially transfer a large
quantity of hazardous waste from the water into the
air;
o steam stripping, which was technically feasible and
more cost effective than a biopond;
o membrane system, which was considered to be potentially
the most economical solution if technical viability
could be demonstrated.
231
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Accordingly, in-house feasibility tests were performed
with laboratory spiked samples of the volatile organic
compounds. Rejection and flux results of several different
commercially available reverse osmosis membranes showed the
"Permasep" B-10 permeator to be the most effective membrane.
Subsequently, a 5 gpm portable pilot system was tested on
site at a wide variety of operating conditions, including
feed pressures from 240 to 1000 psig and recovery rates from
38 to 92 percent. Results of these tests are summarized in
Figures 9 and 10.
These tests demonstrated membrane concentration was
effective in reducing the VOC content by 85 to 90 percent,
and improvements were identified which raised that to 90 to
95 percent. A polishing step using air stripping would have
achieved the 98 percent VOC removal goal and still kept the
total discharge of VOC's to the air at less than the goal of
10 pounds per day.
Based on the pilot test results, the conceptual design
for a full scale system was prepared and is seen in Figure
11. When compared to the projected performance and cost of
a steam stripper, the hybrid system of a membrane system/air
stripper was shown to be effective alternative as can be
seen in Figures 12 and 13.
232
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4.) RESOURCE RECOVERY
Here, an in-line closed loop system is used to prevent
valuable raw materials from becoming unusable and thus
disposed as wastes.
In one case, for example, we developed a system using
membranes to recovery copper cyanide from the rinse water in
a plating operation. Details of this system are in Figure
14. The system separated the plating water into two
streams: a product stream having low TDS for direct dispos-
al to the public sewer or reuse in the rinse tanks, and a
highly concentrated brine containing the plating chemicals
for reuse in the plating bath. The membrane system operates
at approximately 1000 psig feed pressure and is sized to
treat 2.2 gpra feed flow (see Figure 15). The system oper-
ates at 90 to 95 percent recovery and rejects 97-98 percent
of the copper cyanide.
This system cut the company's processing costs two
ways. First, it allowed them to eliminate a waste treatment
system along with the associated chemicals, manpower and
water. Second, it reduced their total purchases of raw
processing materials. The combined savings result in a
payback of the system cost within a matter of months.
In some cases, the payback period for a resource
recovery membrane system can be even shorter1 We are
presently doing feasibility testing in a case involving the
recovery of an exotic dispersing agent used in a
233
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polymerization process. The system would be used to concen-
trate the effluent of an exhaust stream which has been
processed through a scrubber. The full scale system would
be about 20 gpm. Since the value of dispersing agent used
in this process is over 5 million dollars annually, the cost
of a membrane system could be made up within a matter of
daysl
CONCLUSIONS
Du Pont is committed to pursuing the waste management market
with hybrid membrane systems!
Why, can be seen from the answers to these three questions:
o How big is it - So big, that it's scary.
o How do we get it - By providing the total solution to
the separation need.
o Can you prove it - As shown in these examples, the
proof is in the pudding.
These answers also explain why we've gotten continued
interest from potential clients for new applications. We've been
able to demonstrate the significant economic, environmental, and
product quality advantages over other separation technologies.
But our demonstrations have only been successful in these unique
applications because we've committed ourselves to providing the
total solution to a client's separations need. We have tapped
into the extensive resources and experience of the Du Pont
company to provide hybrid membrane systems which are integrated
in the given site specific conditions of an application. For a
234
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membrane system to be successful any or all of the following must
be offered: problem analysis, feasibility testing, solutions
design, systems fabrication and installation, and field service.
Only by assuming the full responsibility for the separations
solution do we foresee the continued acceptance of membrane
separation as the next viable unit process for these emerging
applications.
235
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Figure 1
Annual Estimated Hazardous
Waste Generation
Total = 270 Million Tons
no
Go
CTi
Aqueous
Waste
(61%)
Organic Waste 16%
Sludges & Solids
(4%)
Liquids
(12%)
Inorganic Waste 23%
Sludges (8%)
Solids (15%)
-------
Figure 2
Waste Oil Treatment
Emulsion Plus Solution Finish
Solution
waste
Spinning
machines
Emulsion
waste
Dual collection system
Sludge
Alum
treatment
Vendor
disposal
Water
phase
Plant
biotreatment
-------
Figure 3
Waste Oil Treatment
Combined Waste Using Membrane Separation
Combined
waste
Spinning
machines
Single collection system
oo
n
CVJ
Membrane
separation
Alum
treatment
I
Concentrate
L____J
Vendor
disposal
Plant
biotreatment
-------
o
o
OL E
CO
CO 73
II C
CJ»
60
CO
±: ^ so
5 o 40
«3 3
o -o
w 30
20
10
Figure 4
Permeator Productivity
vs. Finish Concentration
en
n
CM
I
I
I
I
I
I
I
I
6 8 10 12 14 16 18 20
Average finish oil concentration (%)
22
-------
Combined finish waste
Pump
Filter
Figure 5
RO System
Collection
no. 2
Recycle
RO feed
Heat
exchanger
Concentrate
Concentrate storage
(periodic disposal offsite)
Permeate
(to bio-
treatment)
High pressure pump
-------
Figure 6
Economic Viability
Collection system
Capital cost ($)
Savings in disposal
cost ($/yr.)
Hybrid
Membrane Alum
Concentrator Treatment
Single
150,000
250,000
Dual
900,000
-------
100
Figure 7
IDS Rejection vs. O & G Rejection
O 80
-------
Figure 8
Groundwater Characterization
Average Predicted maximum
Parameter ppb ppb
Vinyl chloride
Methylene chloride
Trans- 1 ,2-dlchloroethylene
Chloroform
Trlchloroethylene
Tetrachloroethylene
1 , 1 ,2,2 -tetrachloroethane
Benzene
1 ,4 -dlchlorobutane
2-methylfuran
Tetrahydrothlophene
Total recoverable phenols
Total organic carbon (mg/l)
Total cyanide (mg/l)
Total suspended solids (mg/l) ,
pH (units) range
Temperature (°F) Winter
Summer
400
2,200
3,000
5,000
9,000
6,500
3,100
700
-
-
-
270
100
17
.
6-9
50
70
900
6,000
9.500
20.000
20,000
9,000
7,500
1.500
50,000
50.000
60.000
430
150
27
50
CM
-------
Figure 9
Rejection of Specific Volatile Organic Compounds
Using B-10 Permeator
(At 1000 pslg and 90% Recovery)
Rejection
Parameter %
Vinyl chloride 75
Methylene chloride 28
Trans-1,2 -dlchloroethylene 33
Chloroform 75
Trlchloroethylene 49
Tetrachloroethylene 83
1,1,2,2-tetrachloroethane 95
Benzene 91
1,4 -dlchlorobutane 73
2 - me thy If ura n 42
Tet rahydrot hiophene 9 0
-------
Figure 10
Rejection of Inorganics and T.O.C.
Using B-10 Permeators
(At 1000 pslg and 90% Recovery)
Rejection
Parameter %
Calcium 99
Magnesium 98
Sodium 93
Potassium 92
Strontium 98
Iron 69
Manganese 97
Silica 98
Ammonia (as N) 88
Bicarbonate 31
Sulfate 99
Chloride 98
Nitrate (as N) 33
Fluoride 90
Total cyanide 99
Total filterable residue (180°C) 97
Total organic carbon 75-85
in
*a-
CM
-------
Figure 11
Process Description
To atmosphere
From p 13|
codec- r iai
llon V - 23«
system Y ~ Z3'
P= 13
rRecyc
V = 48
I pre. p = 143
> ment V = 255
RO
PASS1
(B-10)
P= 14
V = 1650
I
Ift
;o
P= 129
V-77
RO
PASS 2
(B-10)
u
P= 116
V = 35
&A,A.a ^^. *
I
Air
i
V = 34
P= 116 To
stripper y < f ~
A*
I^M **
To concentrate
(tank car for
disposal)
11 volatile organic compounds
hi parts per minion
P = groundwater processed
hi thousand gallons per day
-------
Figure 12
Projected Effluent Quality (ppb)
Hybrid System
Constituent
1 , 1 ,2,2 - tetrachloroethane
Benzene
Tetrahydrothlophene
Tetrachloroethylene
Vinyl chloride
Chloroform
1 ,4 -dichlorobufane
Trlchloroethylene
2-methylfuran
Trans- 1,2 dichloroethylene
Methyl chloride
Total organic carbon (TOC)-mg/!
Phenols - fig /I
Cyanide - mg/l
IDS/ heavy metals mg/l
Max
feed
7,500
1,500
60,000
9,000
900
20,000
50,000
20,000
50,000
9,500
6,000
60
430
27
2,000
% refection
at 90%
conversion
95
91
90
83
75
75
73
49
42
33
28
80
50
99
98
RO
pass 2
19
12
600
260
56
1,250
3,645
5,200
16,820
4,265
3,110
2.4
113
0.003
1
Air
stripper
4
1
228
1
1
1
<50
1
1
1
1
2.4
113
0.003
1
Steam
strippe
50
1
350
60
400
27
2,000
-------
Figure 13
Economic Viaoility
Hybrid
membrane Steam
concentrator stripper
Capital cost $ 2-2.5MM 2.5MM
Operating cost $/yr. 600,000 500,000
oo
-------
Figure 14
Copper Cyanide Plating RO Recovery System
^x^* Cascade
^ flow
(
Rinse >t
tank ^2 < Parts |
RO make-up
water
RO
unit
Plant
water
Permeate RO Unltx*^1
^^
*
"**
-^
^ *
Rinse
tank #1
<
Plating ^
drag -out
vi
< Parts |
^^^s. |
Plating
bath
t
/ \ Booster
Vs^x pump
[FT Heat
1 8-J- exchanger
[~| Cartridge
filter
Concentrate
. High pressure
pump
TL _
-------
Figure 15
RO Recovery System Performance
PH
Conductivity
CuCN (oz/gal)
Pressure (psig)
Feed
11.5
4,800
0.18
Free CN (oz/gal) 0.03
970
Product
11.0
400
0.004
0.01
Brine
12.8
5.8
0.26
Average
plating
solution
12.5-13.9
130,000 125,000
6-8
1-2
Flow (gpm)
2.2
2.0
0.2
-------
Waste Classification and Tracking
A Tool for Waste Minimization
Presented by
Richard A. Dennis
Manager, Environmental Affairs
Chemical Group
American Cyanamld Company
Wayne. New Jersey
-------
ELEMENTS OF A WASTE
MINIMIZATION PROGRAM
IDENTIFICATION OF WASTES
. GENERATING OPERATION OR PROCESS
. INDIVIDUAL WASTE STREAMS
WASTE CHARACTERIZATION
AND CLASSIFICATION
WASTE GENERATION DATA
. QUANTITY
. COMPOSITION
WASTE DISPOSAL DATA
METHOD
LOCATION
QUANTITY
251
-------
DATA COLLECTION
AND ANALYSIS
TARGETS FOR
MINIMIZATION
MINIMIZATION PLANS
AND SCHEDULES
IMPLEMENTATION
OF PLANS
EVALUATION OF
ACHIEVEMENT
252
-------
I «^**4;y%?« ff;*xy':xig
I
ro
en
CO
PLANT
PROCESSES
MANAGEMENT
REPORTS
GENERATED
WASTES
WASTE
DATA
BASE
CHARACTERIZATION
AND
CLASSIFICATION
H
QUANTITATIVE
GENERATION
DATA
-------
WASTE TRACKING
EACH WASTE IS UNIQUELY
LINKED TO THE PROCESS
WHICH GENERATED IT
EACH WASTE IS
CHARACTERIZED AND
CLASSIFIED
CHARACTERIZATION AND
CLASSIFICATION DATA
ARE REVIEWED
CHARACTERIZATION AND
CLASSIFICATION DETAILS
BECOME PART OF THE WASTE
DATA BASE
QUANTITATIVE GENERATION DETAILS
BECOME PART OF THE DATA BASE
254
-------
WATE GENERATION
en
en
ORVGi
PROCESSIhG/
blSROSAl.
OFF-SITE
PROCESSING/
DISPOSAL
RESIDUALS
-------
MANAGEMENT REPORTS
SUMMARIZE DATA
IN A VARIETY OF WAYS
GENERATION DATA BY PROCESS
DISPOSAL DATA AND COSTS BY PROCESS
REPORTS SERVE TO:
1. SELECT TARGETS FOR
MINIMIZATION
2. CONFIRM/EVALUATE
MINIMIZATION
PROGRAMS
3. ALLOCATE COSTS TO
GENERATING PROCESSES
TRACK DISPOSAL/TREATMENT BY:
A. FACILITY
B. METHOD
c. WASTE/CLASSIFICATION/ JMPONENT
256
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Hazardous Waste Reduction Auditing
Presented by
Mark Lewis, P.E.
Coauthored by:
A. J. Sederis
Hoffman-La Roche Inc.
Nutley, New Jersey
-------
HAZARDOUS HASTE REDUCTION AUDITING
M. Lewis and A. J. Sederis
Hoffmann-La Roche Inc.
I. Principles of Haste Minimization Auditing:
A. Key elements in waste minimization program
1. Establish goals and objectives
2. Select an audit team
3. Conduct pre-audit activities
4. Perform the audit
5. Conduct post-audit activities
B. Establishing goals and objectives
1. Identify waste minimization options
2. Employee awareness/training
3. Management accountability
4. Operating practice review
5. Records review
6. Material balance
7. Flow-tracking and reporting
C. Selection of the audit team members
1. Familiar with the facility
2. Knowledgeable of environmental regulations
3. Understand work minimization techniques
4. Majority from outside department to be audited
5. Should be responsibility of corporate environmental
staff
257
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0. Pre-audit activities
1. Compila* of environmental inventory by operations
staff -- charges to air, water, and solid/liquid
waste fo. Disposal
2. Hold audit team meetings to develop work plans
3. Notify plant manager and appropriate personnel
4. Review site records
5. Prepare audit questionnaires, check lists, supporting
materials covering -
(a) facility organization
(b) site operations and proposed changes
(c) pollution prevention activities and programs
(d) permits and regulated activities
(e) areas that may be out of compliance and/or
may require special attention
E. Performing the audit
1. Identify waste streams
(a) direct (process wastes)
(b) fugitive (evaporative)
(c) secondary (spent cleaning solvents)
2. Evaluate waste streams
(a) waste stream type
(b) waste characterization
(c) quantity
(d) flow (continuous vs. intermittent)
(e) media affected (air, water, and/or land)
3. Evaluate operations generating individual waste
streams
258
-------
4. Identify areas with greatest potential for waste
minimization through -
(a) Source reduction
i use and alteration of input materials (purification
or substitution of materials)
ii use and modification of equipment/technology
(layout, operational settings, process changes,
automation, materials conservation, water
conservation, energy conservation)
iii operating practices (personnel practices,
procedures, loss prevention, material handling
and storage, waste stream segregation)
iv product alteration (composition, substitution,
and conservation)
(b) Recycling options
i reuse
ii reclamation
iii separation
iv recovery
(c) Treatment
i type - chemical, biological, thermal
ii efficiency
iii applicability
Iv operating requirements - materials, energy,
personnel
F. Post-audit activities
1. Report of findings
2. Management response to findings
3. Identify specific examples with best potential for
waste minimization
4. Conduct feasibility study of most promising options
259
-------
5. Implement most practical (and profitable options)
6. Monitor to assure objectives are met
II. An example of a waste reduction audit for a facility manufacturing
medicinal products:
A. Pharmaceutical Industry
1. Serums/vaccines, Biologicals, Extracts, Fermentation
Products
2. Pharmaceutical preparations
3. Medicinal products
B. Modern Environmental Regulations
1. Federal Water Pollution Control Act - 1972
2. Federal Clean Air Act - 1970
3. Resource Conservation and Recovery Act - 1976
C. HLR Waste Management Program - Began 1974
1. Assess manufacturing processes to quantify pollution
(a) Roche for twenty-five years had been estimating
environmental impacts of processes - estimate
fate of rm's and products to air, wastewater,
solid/liquid waste
(b) Processes ranked on basis of waste generated -
1 air emissions
11 discharges to process sewers
111 solid/liquid waste disposal
2. Solid/liquid waste disposal
(a) Identify individual waste streams
(b) Characterize
i physical state - solid, liquid, multiphase
ii chemical composition
260
-------
D. Waste Minimization
1. Not new concept
(a) Chemical process development
i optimize conditions - time-temperature,
catalysts, solvents, etc. - efficient use
of raw material
(b) Recovery of solvents for reuse
i integral part of process
2. Review waste streams for volume reduction
(a) Different raw materials; different solvent
i Pharmaceutical industry unique - NOA locks
in process - no change in process without
approval by FDA
(b) Optimize current process - study time temperature,
relationships, use of catalysts
(c) Operator training
(d) Automation
E. Alternatives to Off-Site Disposal
1. Recover/re-use - on site
(a) Same process
(b) Different process - recovered pharmaceutical
raw material use in shampoo
(c) Different use - alcohol for windshield washer
fluid/gasoline additive
2. Noncommercial fuel - beneficial recovery of heat
(a) On site burning - boiler
(b) Off site Industrial furnace - cement/steel
F. Example of Typical Chemical Reaction i
(See Figures 1 and 2)
261
-------
Sodian Aaeotbate
o * ta
1 I
H-C
JO-C-H
C-HOH
2
Ascorbic Sodium C,HeOH
Acid + Bicarbonate 2 5
il
C-
2
"3
H-C-
I
RX-H
Carbon
Sodiui Ascorbata Dloxid* Water
262
-------
INFLUENCE ANALYSTS BY PROCESS STEP. WICRIALS
PROCESS! ASCORBIC ACID
PRODUCT PRODUCT
OGDB DESCRIPTION U/W
IOU
IYTDI
PROD-DAYS
(YIP)
AVCI1AGB
HKTGirr/PnQD DAY
AVERAGR
HBICirr/HAICII
60477
Sodlin
Ascorbate USP KG
C OMSUMPTIOM
ENVIRON MEN T
ADJUSTED REQUIRED
t
CTt
d
-JO
rn
MATERIALS CONSUMED
Ascorbic Acid USP
Alcohol Foraula 23A
Sod Bicarbonate Bulk
Ibtal
% of ibtal
KG/KG
.934
.110
.432*
1.476
100.0
FOR
CA!£.
.934
.110
.121"
1.165
TO FORM LIQUID
PRODUCT DISPOSAL
.889
.111"
1.000
85.8
SOLID
DISPOSAL
.001
.001
.002
.2
AIR
oiscin.
.003
.089
.004
.096
8.2
SEWER
OlSCin. RECnVERY CVYflFNTC
.041
.021
.005
.067
5.0
Average Batch Production Kg
As Sodium Bicarbonate
As Sodlira
-------
WASTE REDUCTION
IN
PRINTING INK MANUFACTURING
AND PRINTING
PRESENTED BY: PAUL VOLPE
TECHNICAL COORDINATOR
NAPIM
HARRISON/ NY
GIVEN AT: HAZARDOUS WASTE REDUCTION AUDIT WORKSHOP
NOVEMBER 17, 1987
-------
Waste Reduction in Printing Ink Manufacturing and Printing
To those of you who are in the printing ink manufacturing
sector my opening remarks will be very basic, covering informa-
tion which you already know very well. However, in order to put
the question of waste generated by the printing ink manufacturing
and printing industries into the proper perspective, let's look
at what are the constituents of any printing ink regardless of
the method of printing. They are:
- Colorants which impart the color you see.
- Vehicles which carry and fix the colorants to the printed
substrate.
- Additives which give the ink the special physical and
other properties desired.
Printing inks generally can be divided into two major
groups: Paste inks used for letterpress and offset printing and
liquid inks used for flexographic and gravure printing. Screen
printing inks might fall into either group. Paste inks are
usually oleoresinous - that is, the vehicle is composed of some
type of oil and resin. Liquid inks can be either solvent based
or water based and the resin systems for each are quite dif-
ferent.
Solvent based liquid inks almost always contain organic
solvents which have flashpoints below 140°F. Some of the
common solvents with flashpoints below 140° are shown here.
Since the flashpoint of a printing ink is a function of the
264
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solvents used in its formulation we can conclude that most
solvent based inks would have flashpoints below 140°* a
sufficient quantity of these inks enter the waste stream from
your plant to cause a representative sample of the waste to have
a flashpoint below 140° the entire waste would be considered
hazardous from the standpoint of its ignitability.
Now what about water based inks which may contain organic
solvents such as alcohols and have flashpoints below 140°? In
the RCRA regulations, EPA excluded from the ignitable classifi-
cation aqueous solutions with flashpoints below 140°F which
contain less than 24% alcohol by volume. Although this exclusion
applies mainly to solutions, EPA mentions in the preamble to the
regulations liquid waste such as latex paints. Like printing ink
latex paints are not true solutions but EPA includes them in the
exclusion. Since they do not sustain combustion because of the
high percentage of water in their formulation, EPA has stated
that such wastes would not be considered ignitable even though
they may have flashpoints below 140°.
Let us now consider another characteristic which may make a
waste hazardous; that of corrosivity. If a waste is aqueous and
has a pH of 2 or less or 12.5 or more, or is a liquid that
corrodes steel at the rate of 6.35 mm (0.25 inch) per year at a
test temperature of 130°F it is considered to be corrosive. I
do not know of any ink or raw material generally used in inks
which exhibits properties which would cause the ink to fit into
the corrosive category.
265
-------
The third characteristic which makes a waste hazardous is
that of reactivity. We know that some inks, those which dry by
radiation curing or those which are thermally activated catalyzed
systems, dry by internal chemical reactions. In judging whether
these inks would be hazardous because of reactivity we refer to
the wording of the regulations. One of the properties given for
a waste to be considered reactive is that it is normally unstable
and undergoes violent change. The key words here are "unstable"
and "violent". These inks as well as all other types of inks are
not unstable nor do they dry by a violent chemical reaction.
On the other hand, another property of a reactive waste is
that the material is capable of an explosive reaction if heated
under confinement. Most organic solvents and solvent based inks
stored in closed containers when heated tend to build up vapor
pressures and at high temperatures may rupture the containers
with an explosive reaction. However, we can conclude that no
printing inks when stored at ambient temperatures and pressures
would be hazardous by virtue of reactivity.
The last characteristic used to judge whether a waste is
hazardous is that of toxicity based upon an extraction procedure
set forth by EPA in the regulations in Appendix II of Part 261.
This is called EP Toxicity. Late last year, EPA also issued in
Appendix I of Part 268, covering land disposal of waste, a
procedure called Toxicity Characteristic Leaching Procedure
(TCLP). This is designed to determine the mobility of both
organic and inorganic contaminants in the waste. It is expected
that the more restrictive TCLP toxicity testing will replace EP
Toxicity in determining the hazard of a waste.
266
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The toxicity characteristic of a waste mixture such as
printing ink waste is the most critical and usually the most
difficult to judge when determining whether or not the waste is
hazardous under the RCRA regulations. In Section 261.24 a waste
is considered to be EP Toxic if, when tested by the procedure set
forth in the regulations, the extract contains a concentration
equal to or greater than the values given in Table 1 of this
section for any of the listed contaminants. Eight metals and six
organic pesticides are listed together with the maximum
concentration permitted for each in the extract from a
representative sample of the waste. Listed on this chart are the
eight metals, but the six organics have been omitted since it is
not reasonable to expect any ink waste to contain these
materials.
Whether or not the listed metals are present in an ink
depends principally on the pigments used. Of these metals, the
ones which are potentially the most likely to be introduced by
ink are lead, chromium and barium. The other metals, arsenic,
mercury, cadmium, selenium and silver are only expected to be
present in ink as trace contaminants, if present at all.
Note that earlier I said concentration in the extract and
not in the waste itself. It must be understood that the level of
"toxic" materials such as barium, lead or chromium in the ink
does not in itself determine whether the waste is EP Toxic. The
determining factor is the quantity of the toxic metal which is
leached from a representative sample of the waste.
267
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If the inks do not contain pigments which are compounds of
lead and chromium (such as lead chromates and molybdate orange)
it is most unlikely that sufficient lead and chromium would be
present to result in the leaching of these metals in excess of
the given limits. On the other hand, many clean yellow shade
reds are formulated with pigments which are compounds of barium
and sufficient barium could be present resulting in the leachate
containing barium in excess of the limit.
Several years ago, the National Printing Ink Research
Institute at Lehigh University ran a series of EP Toxicity tests
on a wide range of ink-related wastes in an attempt to determine
which would or would not be EP Toxic. It was hoped that the
results would indicate on a broad scale the types of ink related
wastes which could be considered non-toxic without having to test
samples of each individual waste stream. Unfortunately, when the
wastes contained lead or Barium based pigments, the test results
showed that no definite conclusions could be drawn. While the
majority of the samples were found to be EP Toxic, some were not.
Included in the samples were water flexo inks, some containing
lead chromate and others, barium-based pigments. Also tested
were samples of the actual pigments. Shown on this chart are the
results obtained from these samples.
268
-------
The only conclusion that can be made is that the test for EP
Toxicity is very waste specific. Because of this, ink manufac-
turers cannot give any assurances to their customers that the
inks they supply would not be EP Toxic if the inks are formulated
with pigments which are barium or lead/chromium based. The best
solution is to avoid mixing waste from inks containing these
metals with other non-hazardous waste. In fact, the solution to
the entire problem of waste disposal is to reduce the amount of
waste generated. How does one go about doing this?
To begin with, use common sense. This morning we heard
several speakers give talks on waste auditing. Find out where
your waste is being generated, what type of waste and how much.
Keep in mind that a material does not become a waste until you
judge it to be unusable. This can be a major factor in reducing
the amount of waste generated.
Let's look at solvents used for cleaning equipment. Many
have flashpoints below 140° and thus would be considered
hazardous if they entered the waste stream. Many times clean up
solvents are used once and then thrown into the waste or slop
bucket together with other waste, some of which is even non-
hazardous, making the whole mess hazardous. Why not save the
wash-up solvent and use it over and over again. You will find
that even though the solvent is somewhat dirty it still does a
good job in removing ink from the equipment and presses. A
little virgin solvent may be necessary for final clean-up but
this usually just requires a rag moistened with the clean
solvent.
269
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By placing your wash-up solvent in a drum after it is used
to clean equipment, you will find that the solids normally tend
to settle out and the solvent toward the top of the drum can then
be used many times before it gets too dirty to be effective. An
ink manufacturer making solvent-based inks can also recycle his
wash-up solvent after it is used several times into the next
batch of black ink which he makes. A flexographic printer using
solvent-based inks normally reduces his inks at press-side with
solvent. He can also recycle his wash-up solvent when he reduces
either blacks or dark colored inks on press. Keep in mind,
however, that recycling the wash-up solvent will only work if you
keep the solvent separated from other wastes.
What about waste water from washing equipment or presses
where water-based inks were used? Here again, the solution is to
use a minimal amount of water for clean-up. Don't use what I
call the "garden hose" method. In the past it was common
practice for printers to wash water-based inks from presses by
placing a garden hose into the ink fountain and flushing every-
thing down into the sump. They ended up with a massive amount of
colored water which usually went into the sewer. Today this will
not work since most municipal sewer departments will no longer
accept this material. How then can you effectively dispose of or
reuse this wash water?
If you separate the solids either by filtration or precipi-
tation, you effectively remove the colored pigments and i: .en the
clear water can be reused for clean-up, for making press-side
270
-------
reductions, or added to the glue used in most corrugated opera-
tions and what cannot be reused could then be placed down into
the sewer.
What about waste ink? In my opinion, no ink should be
wasted and very little should enter into the waste stream. As an
ink manufacturer you paid for every raw material used in making
your inks. As a printer, you paid for every pound of ink which
was shipped to your plant. So why waste this material? Most ink
manufacturers use so-called off-standard inks as work-off in
subsequent batches. If all else fails the work-off can be used
in batches of black inks. Printers can do the same with the
small quantities of ink remaining from press runs. Press returns
should be carefully stored by individual color and used during
subsequent runs. For example you can mix all left over yellows
together; do the same with the other colors. When you have a
sufficient quantity you could then use the resulting ink for
other print jobs.
Another example - let's say you have some yellow left over
and blue left over. If you mix the two you end up with a green
ink that you possibly could use for another print job. The same
t
applies to let's say yellow and red - you could make an orange.
If this is not possible you could still add these leftover ink
colors to whatever black inks you are running.
In certain states, such as New Jersey, where even oil based
inks are considered hazardous due to the fact that oily waste is
deemed to be hazardous, reducing the amount of waste ink can save
271
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you money. Not only because you do not throw out materials you
have already paid for, but you save the cost of having it hauled
away as a hazardous waste.
Now a word about empty containers which previously held inks
or raw materials. These are not considered hazardous under the
Federal RCRA regulations even though they might still contain a
small amount of residue of a material which might otherwise be
considered hazardous. EPA has defined an empty container as one
from which all material has been removed that can be removed
using practices commonly employed to remove materials from that
type of container. The definition further states that no more
than one inch of residue remain on the bottom on the container.
After scraping as much of the contents from your metal containers
you could then crush them and after accumulating a sufficient
quantity dispose of them by selling to a scrap metal dealer. If
you are not able to do this, you could still dispose of them with
your ordinary trash at a much lower cost versus hauling away as a
hazardous waste.
I would like to conclude by saying - take a hard look at
your waste. I'm sure that by doing this you can come up with
many more ways to reuse materials that in the past entered the
waste stream from your plant. This will not only minimalize your
waste disposal problems, but also save you money.
272
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PRINTING INK CONSTITUENTS
COLORANTS - PIGiMENTS
DYES
VEHICLES - RESINS
SOLVENTS
ADDITIVES - WAXES
ANTIFOAM AGENTS
SLIP AGENTS
273
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SL'le A
COMMON FLEXO INK SOLVENTS
Flash Point Below 140*F (Closed Cup)
IGNITABLE
TYPE EXAMPLES
ALCOHOLS
ESTERS
GLYCOL ETHERS
ALIPHATIC
HYDROCARBONS
AROMATIC
HYDROCARBONS
KETONES
Methyl Alcohol
Ethyl Alcohol
Isopropyl Alcohol
Normal Propyl Alcohol
Ethyl Acetate
Isopropyl Acetate
Normal Propyl Acetate
Cellosolve
Methyl Cellosolve
Hexane
Heptane
VM&P Naphtha
Toluene
Xylene
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
274
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EP TOXIC-SECTION 261.24
A waste is EP Toxic if leachate from extraction
test contains more than:
ARSENIC 5.0 Mg/L
BARIUM 100.0
CADMIUM 1.0
CHROMIUM 5.0
LEAD 5.0
MERCURY 0.2
SELENIUM 1.0
SILVER 5.0
Plus six organics not found in printing inks.
275
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Slide No. 4
PRINTING INK
SOLID WASTE SURVEY
Sample Type
Water Flexo Inks
containing
Lead/Chromium:
Number
Tested
15
Number Over EPA Limit
total Pb Pb/Cr Ba
Lead/Chromium
Pigments*:
18
15 13
2
Water Flexo Inks
containing
Barium Pigments:
11
Barium Pigments**:
* Pigment samples included:
Medium Chrome Yellow, Primrose, Light Chrome Yellow and Molybdate Orange,
** Pigment samples included:
Barium Lithol (R49:l) and Red Lake C (R53:l).
276
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