TRAINING COURSE



                      FOR



            MULTI-MEDIA INSPECTORS
                   Student Manual
13INSTRU.MAK

-------
SECTION I      MEXICAN ENVIRONMENTAL PROGRAM OVERVIEW
SECTION II     HEALTH AND SAFETY FOR FIELD ACTIVITIES
SECTION in    FUNDAMENTALS OF ENVIRONMENTAL COMPLIANCE
              INSPECTIONS
SECTION IV    WASTE WATER INPSECTIONS


SECTION V     AIR POLLUTION/HAZARDOUS WASTE INSPECTIONS
SECTION VI     POLLUTION PREVENTION
SECTION vn    INDUSTRIAL PROCESSES

-------
                         THIS PAGE LEFT BLANK
I3INSTRU.MAN

-------
                               TABLE OF CONTENTS


Section I - Mexican Environmental Program Overview  	1-1

Section n - Health and Safety for Field Activities

      Chapter 1 - Preparation for Field Activities   	1-1
      Chapter 2 - Hazards, Exposure and Evaluation	2-1
      Chapter 3 - Protective Clothing and Equipment  	3-1
      Chapter 4 - Respiratory Protection  	4-1

Section m - Fundamentals of Environmental Compliance Inspections

      Chapter 1 - Introduction to Environmental Compliance	1-1
      Chapter 2 - Inspection Planning and Preparation	2-1
      Chapter 3 - Entry and Opening Conference	3-1
      Chapter 4 - Information Gathering and Documentation	4-1
      Chapter 5 - Post-Inspection Activities  	5-1

Section IV - Waste Water Inspections

      Chapter 1 - General Procedures	1-1
      Chapter 2 - Sampling Techniques	2-1
      Chapter 3 - Treatment Technologies  	3-1
      Chapter 4 - Pollution Prevention Techniques	4-1

Section V - Air Pollution/Hazardous Waste Inspections

      Chapter 1 - Baseline Inspection Techniques for Air Pollution Sources	1-1
      Chapter 2 - Hazardous Materials/Hazardous Waste Inspection Procedures  	2-1

Section VI - Pollution Prevention

      Chapter 1 - Introduction to Pollution Prevention	1-1
T3INS1KUJMAN

-------
                         TABLE OF CONTENTS (Continued)
Section Vn - Industrial Processes

      Chapter 1 - Petrochemical Industry	1-1
      Chapter 2 - Chemical Manufacturing	2-1
      Chapter 3 - Pharmaceutical Manufacturing Plants	3-1
      Chapter 4 - Metallurgical Industries	4-1
      Chapter 5 - Tanneries	5-1
      Chapter 6 - Cement Industries	6-1
      Chapter 7 - Printed Circuit Board Manufacturing 	7-1
      Chapter 8 - Electroplating	8-1
      Chapter 9 - Lead Smelting	9-1
T3INSIRUJMAN                                11

-------

-------
MEXICAN ENVIRONMENTAL PROGRAM




           OVERVIEW

-------
II

-------
               HEALTH AND SAFETY MANUAL




                          FOR




                     FIELD ACTIVITIES
hlthsfiy.eng

-------
                               TABLE OF CONTENTS

Chapter                                                                        Page

INTRODUCTION  	  iii

OPENING STATEMENT	 iv

LIST OF ABBREVIATIONS AND ACRONYMS 	v

1.0    PREPARATION FOR FIELD ACTIVITIES 	   1-1
       1.1  Objective	   1-1
       1.2  Introduction	   1-1
       1.3  Pre-Field Activity Evaluation 	   1-1
       1.4  Onsite Evaluation	   1-2

2.0    HAZARDS, EXPOSURE AND EVALUATION  	   2-1
       2.1  Objective	   2-1
       2.2  Introduction 	„.	   2-1
       2.3  Safety Guidelines and Techniques	   2-1
       2.4  Heat Stress	 2-5
       2.5  Fire and Explosion Hazards 	 2-7
       2.6  Selection and Use of Fire Extinguishers 	  2-12
       2.7  Chemical Hazard Recognition and Evaluation  	  2-15
       2.8  Effects of Toxic Chemicals in the Body	  2-19
       2.9  Dose-Response Curves	  2-25
       2.10 Evaluating Health Hazards and Toxicity Information	  2-30
       2.11 References	  2-35
       2.12 Emergency First Aid for Field Activities  	   2-38

3.0    PROTECTIVE CLOTHING AND EQUIPMENT  	   3-1
       3.1  Objective	   3-1
       3.2  Selection of Personal Protective Clothing and Equipment (PPE)  	   3-1
       3.3  Levels of Protection  	   3-6
       3.4  Controlling the Transfer of Contaminants	   3-6
       3.5  Decontamination	  3-11
       3.6  Donning and Doffing Protective Clothing	  3-12
       3.7  Storage of Equipment	  3-12

4.0    RESPIRATORY PROTECTION 	   4-1
       4.1  Objective	   4-1
       4.2  Recognition of Respiratory Hazards	   4-1
       4.3  Types of Respirators	   4-4
       4.4  Respirator Selection  	   4-9
       4.5  Respirator Use	  4-11
       4.6  Special Considerations  	  4-12
       4.7  Respirator Fit Testing	  4-12
Uttafty.eng

-------
                         TABLE OF CONTENTS (CONTINUED)

                                      APPENDICES

Number                                                                            Page

1-A   Sample Safety and Health Planning Guideline for Field Activities	   1-3
3-A   Performance Requirements of Protective Clothing 	  3-13
3-B   Protective Materials	  3-15
3-C   Procedures for Donning and Doffing Personal Protective Clothing	  3-17

                                        TABLES

Number                                                                            Page

2-1    Characteristics of Flammable Liquids  	  2-11
2-2    Fire Classification and Extinguishing Media 	  2-14
2-3    Fire Extinguisher Identification	  2-14
2-4    Characteristic of Air Contaminants in Work Places	   2-17
2-5    Industrial Toxicants That Produce Disease of the Respiratory Tract	  2-24
2-6    Organs/Systems Affected by Chemical Exposure	  2-26
2-7    Some Direct-Reading Instruments	  2-33
3-1    Typical Noise Reduction Ratings (NRRs) for Common Hearing Protection
       Devices 	   3-4
3-2    Physical Characteristics of Protective Materials	   3-5
3-3    Level of Protection  	   3-7
4-1    Physiological Effects of Oxygen Deficiency  	   4-3
4-2    Relative Advantages and Disadvantages of Air-Purifying Respirators	   4-6
4-3    Respirator Styles	   4-6
4-4    Relative Advantages and Disadvantages of Atmosphere-Supplying Respiratory
       Protective Equipment  	   4-7
4-5    Respirator Protection Factors 	  4-10
4-6    Advantages and Disadvantages of Qualitative and Quantitative Fit Testing	  4-13

                                       FIGURES

Number                                                                            Page

2-1    Skin cross-section	  2-20
2-2    Organs of the human respiratory system 	  2-21
2-3    Classic dose-response curve	  2-25
2-4    Dose-response curve for a chemical with no TLV	  2-26
2-5    Dose-response curve for a highly toxic chemical  	  2-26
3-1    The ear	3-3
hltbsfty.eng                                     11

-------
                                    INTRODUCTION

The Basic Health and Safety section of this SEDESOL inspectors' training course has been
developed using many materials on occupational safety and health that are part of the training
for inspectors from the United States Environmental Protection Agency (EPA).  Their training
is designed to protect them from many of the same hazards that you too will face. By following
the practices detailed herein, you can help ensure your own health and safety and ultimately that
of your family members as well.

In some places in your manual you will see references to standards or rules set by U.S. agencies
such as the Occupational Safety and Health Administration (OSHA) or the National Institute
for Occupational Safety  and Health (NIOSH). The standards that these agencies establish for
individuals who come in contact with hazardous materials, or who work under hazardous
conditions, are based upon the best scientific estimates of conditions that are acceptable to
maintain the good health of workers. You may see reference, for example, to Permissible
Exposure Limits (PELs); it is believed that most people who are exposed to the PEL of a
harmful substance during the course of an eight-hour work day will not experience any harmful
effect from such exposure.  Exceeding a PEL puts you at an increased risk to the toxic effects of
hazardous materials.

You will also see references to rating standards for protective equipment or monitoring
instruments.  In the United States an independent  group called Underwriters Laboratory (UL)
examines and rates electrical equipment (including monitoring equipment) for safe use under
different conditions. Inspectors are advised to look for these rating systems to help them
evaluate whether or not  equipment is safe to  use under the expected work conditions.  For
instance, a monitoring device that is not spark proof may pose a severe risk if it is used in an
environment that has sufficient concentrations of explosive vapors or dust.

Additional information pertaining to health and safety issues can be obtained from your
instructors and the reference materials listed  in this manual.
hlthsftyeng                                    111

-------
                                 OPENING STATEMENT

                         BASIC HEALTH AND SAFETY MANUAL
                                FOR FIELD PERSONNEL
Field inspections involve a certain degree of risk. Inspections of wastewater treatment plants,
manufacturing plants, laboratories and mines are each associated with various hazards.  A safe
field inspection depends on the recognition, evaluation and control of hazards.  During field
activities, it is not always possible to eliminate hazards.  However, it is possible to reduce the
risk associated with these hazards, through the use of monitoring or testing equipment,
engineering controls, personal protective equipment and employee training.

This course manual is an introduction to the basic health and safety training required for
conducting field activities.  The goal of this manual is to provide you with the information
necessary to make the correct health and safety decisions in the field.  This manual examines
health and safety principles and identifies methods to recognize and evaluate the hazards
associated with field activities.
hllhsftyeng                                     IV

-------
                     LIST OF ABBREVIATIONS AND ACRONYMS
ACGIH      American Conference of Governmental Industrial Hygienists
ANSI        American National Standards Institute
CFR        Code of Federal Regulations
CPR        Cardiopulmonary Resuscitation
CHRIS      Chemical Hazard Response Information System
EPA        Environmental Protection Agency
IDLH        Immediately Dangerous to Life or Health
LEL        Lower Explosive Limit
MSHA      Mine Safety and Health Administration
NFPA        National Fire Protection Association
NIOSH      National Institute for Occupational Safety and Health
OSHA       Occupational Safety and Health Administration
PAPR        Powered Air-Purifying Respirator
PEL         Permissible Exposure Limit
PPE         Personal Protection Equipment
REL        Recommended Exposure Limit
SAR        Supplied-Air Respirator
SCBA        Self-Contained Breathing Apparatus
TLV        Threshold Limit Value
TWA        Time Weighted Average
UEL        Upper Explosive Limit
USCG        U.S. Coast Guard
hlthsfty cog

-------
                                 CHAPTER 1
               1.0  PREPARATION FOR FIELD ACTIVITIES
                                1.1 OBJECTIVE
                   To identify key elements that must be considered when preparing
                   for field activities.
                             L2  INTRODUCTION
Importance of
Preplanning
Planning Process
Sources of
Information
Field personnel encounter a wide variety of potential
hazards.
Preplanning can reduce or eliminate many hazards.

Research potential hazards.
Evaluate the risks.
Select appropriate protective equipment and clothing.

Plant personnel
Agency files
Agency employees
Industry standard references
                    1.3  PRE-FIELD ACTIVITY EVALUATION
Planning Guide
Components of
the Planning
Guide
Prepare planning guide.  (See Appendk 1-A).
Acquire pertinent medical records and other information.
Take guide and information to the site.
Leave a copy with your supervisor.

Activity location
      name and address
      contact name and telephone number
      photographs
Historical information
hlthsftyeng
             1-1

-------
                          Activity schedule
                          Inspection personnel
                                 names
                                 restrictions
                                 required training

                          Lodging
                          Hazards
                                 transportation (distances, chemicals, supplies, test
                                 equipment, etc.)
                                 noise
                                 fire/explosion
                                 biological
                                 weather-related
                                 chemicals
                                 atmospheric
                                 thermal
                                 radiological
                                 confined space
                                 drowning
                                 physical and mechanical (height, machinery, etc.)

                          Vehicles
                          Required permits
                          Emergency and rescue
                                 communication (telephone, two-way radio, etc.)
                                 warning signals (fire, evacuation, severe weather,
                                 etc.)
                                 hospitals, emergency assistance personnel

                          Personal protective equipment and clothing
                          Miscellaneous
                            1.4  ONSITE EVALUATION
                          Request a health and safety briefing.
                          Conduct a walk-through survey.
                                 hidden hazards
                                 natural hazards

                          Record unexpected hazards, additional gear requirements.
A92-333.1                                 1-2

-------
                             APPENDIX 1-A

           SAMPLE SAFETY AND HEALTH PLANNING GUIDELINE
                         FOR FIELD ACTIVITIES
Facility/Site:

Location:
Agency files exist	Yes 	No

If yes, list pertinent historical information
DATES AND LENGTH OF PROPOSED ACTIVITY:	

SITE CONTACTS:

Name                      Position                     Tel. Number
INSPECTION TEAM:
                Medical    Field     Respiratory    Medical/Physical
Name           monitoring  training   training       restrictions
hlthsfty.eng                             1-3

-------
LODGING ARRANGEMENTS: Motel/Hotel



Location	
SITE ACCESS REQUIREMENTS:




Identification	
Permits
Visitor's agreement



Special problems	
Type of communication needed
             Telephone
VEHICLE(S) AND EQUIPMENT:




Motor Vehicles	
Make
Mobile laboratory
License Plate
  Other (list)
Vehicle safety check made?  	yes  	no




      Boat/Airplane will be used? 	yes	no




      List vehicle to be used	
      Boat/plane safety check made?	yes	no






ANTICIPATED HAZARDS TO CONSIDER:




Driving distance	  Biological hazards	




Hauling reagents	  Radiological hazards




Hauling test equipment	  Noise	




Moving hazards	  Heights	
bllhsfty eng
1-4

-------
Thermal hazards	Confined space



Chemical hazards	 Weather	



Flammable hazards	 Terrain	
TOXIC SUBSTANCES (LIST):
HAZARD MONITORING EQUIPMENT:
EMERGENCY SIGNALS AND COMMUNICATION:




Fire signal is	
Evacuation signal is
Severe weather signal is



Toxic release signal is _
EMERGENCY AND RESCUE:




Is first aid available in the area?	yes	no



Location	  Telephone #
A92-333.1                            1-5

-------
Is ambulance available?	on site	on call Tel. #



Nearest hospital with emergency services: Location	
                                                Telephone #
Heavy and special rescue services/equipment available:  Yes/No_



Specify:	
PERSONAL PROTECTIVE EQUIPMENT/CLOTHING:  (Check if needed)



Eyes and Head



Safety glasses	      Type	
Face shield	      Goggles



Hard hat	      Type	



Hearing protection	      Type	



Other	
Body, Hands, Feet



Coveralls	Type



Foul weather gear	
Fully encapsulating gear
Safety footwear	  Type




Boot/shoe covers	
Gloves	  Type



Other special equipment/clothing	
hlthsfty.eng                                1-6

-------
Respiratory Protection
Air-Purifying Respirator	  Type
Cartridge, Filters	  Type
SCBA	  Type
Emergency Escape Mask	   Type
Airtank Full	yes	no
Special  Health and Safety Equipment
Life belt	
Safety line
Other	
Decontamination Supplies
Waste bags and ties	
Cleaning solution	
Disposable brushes
Disposable towels and towelettes	
Disposable containment tubs	
MISCELLANEOUS
Rope	String	Tape
Matches	Food	Additional Clothing	
Potable Water	

Note:
A copy of this summary should be taken along for reference in the event of an
emergency. A second copy should be filed with a supervisor before leaving for the site.
Such information is particularly important for visits to sites where crews may be stranded
or lost.
A92-333.1                                1-7

-------
                                CHAPTER 2

              2.0  HAZARDS, EXPOSURE AND EVALUATION
                               2.1  OBJECTIVE
                   To provide information regarding general safety considerations,
                   how exposures to hazardous chemicals may occur, how to assess
                   these hazards, and how to protect oneself and others.
                             2.2  INTRODUCTION
                        Inspectors will encounter a variety of physical, biological, and
                        chemical hazards during inspections.

                        Exposure to chemicals is the most common and significant
                        health hazard field personnel encounter.

                        Chemicals may be hazardous because they are toxic,
                        flammable, combustible, explosive, corrosive, reactive,
                        radioactive, biologically active, or some combination of these
                        and other characteristics.

                        Inspectors should learn basic first aid techniques.
                 2.3  SAFETY GUIDELINES AND TECHNIQUES
                        Lifting and carrying
                        Ladders and climbing
                        Power sources and electrical equipment
                        Confined spaces
                        Mechanical hazards
                        Biological hazards
blthsftyeng                               2-1

-------
Lifting and
Carrying
Ladders and
Climbing

Portable Ladders
Assess the following:

       overall weight
       distribution of weight
       security of contents
       distance
       obstacles
       surface conditions
       visibility

Use two people.
Lift with power of leg muscles.
Do not climb ladder with heavy load.
Inspect ladders for hazards.

Position ladder base 1/4 of working length from wall.

Use only ladders with non-skid feet; be sure ladder rests on
non-slip level surface.

Wear appropriate clothing.

Do not use:

       step ladders  >6 m (20')
       straight ladders >9 m (30')
       two-section extension ladders > 15 m (48')
       three-section extension ladders > 18 m (60')

Face ladder when climbing and descending.

Have someone stabilize bottom.

Do not hand carry anything up the ladder.

Prevent tools and equipment from catching on ladder or
falling.

Do not use ladder as scaffold or bridge.

Do not permit more than one person on ladder.

Do not reposition ladder while on it.
A92-333.1
              2-2

-------
Fixed Ladders
Working Surfaces
Power Sources/
Electrical
Equipment
Electrical
cords/plugs
Uninsulated
Electrical
Conductors or
Metal Parts
Static Electricity
Mechanical
Hazards
Minimum design load:  91 kg (200 Ibs)
Evenly spaced stepping surface < 30 cm (12")
Adequate clearance
Minimum 18 cm (7") clearance behind each rung
Safety devices or cages: >6 m (20')
Pitch:  75°-90°

Check integrity of elevated platforms before climbing up to
them.
Discontinue inspection if personal safety is jeopardized.

Shut off power where possible.

Remove highly conductive equipment if power cannot be shut
off.

Wear protective gear - hard hats, gloves, etc.

Inspect periodically and repair.

Use three-wire equipment.

Ensure continuity of grounding wire.

Ensure diameter of wires is sufficient to prevent loss of
voltage or overheating.

Ensure exposed  metal parts of electrical equipment are
grounded.

Use a Ground Fault Circuit Interrupter (GFCI) in the line.

Use double-insulated power tools.

Sources include:

      particulates in process stream
      electrostatic precipitators
      lightning

Safety precautions:

      ground sampling probes
      be aware  of weather conditions
      discontinue sampling where lightning hazard exists
      use A.M.  radio for weather reports/static interference

Remotely controlled vehicles
Forklifts
Potential entanglements
hlthsftyeng
               2-3

-------
Confined Space
       See booklet for information on confined space entry.
Biological
Hazards

Ticks
Snakes
Spiders
Bees/wasps
Scorpions
Rabid Animals
Entering certain locations can be hazardous due to the presence of
various biological hazards.

       Live in areas with tall grasses, bushes.
       Burrow into skin and suck blood.
       Transmit Rocky Mountain Spotted Fever, Lyme's Disease.
       Wear light-colored clothing; tuck pant legs into socks.
       Examine body for presence of ticks.
       Seek medical  help if fever, rash or bull's eye pattern
       develops.

       Learn to recognize poisonous varieties.
       Wear knee-high, thick, leather boots and leather gloves.
       Be aware of their habits.
       Bring snake bite kit.

       To treat snake bite:
             keep victim calm
             slow circulation
             use snake bite kit
             get immediate medical help

       Learn to recognize dangerous varieties.
       Get medical help for bites as soon as possible.
       Tarantula bites are painful but seldom serious.

       Recognize their habitats.
       Carry bee-sting kit if allergic.
       To treat sting:

             keep victim calm
             remove stinger
             cool area with ice
             administer cardiopulmonary resuscitation (CPR) if
             necessary
             seek medical help

       Usually found under other objects.
       Carry anti-sting kit - sting can be fatal to allergic individual.
       Administer CPR if necessary.
•      Seek medical  help if stung.

       Can infect any warm-blooded animal (foxes, dogs, bats,
       raccoons, skunks, squirrels).
A92-333.1
                     2-4

-------
Micoorgamsms
Animals may exhibit lack of fear, aggressiveness, dropping
head, peculiar trotting gait, unusual behavior.

Seek immediate medical help if bitten by rabid animal;
infection nearly 100% fatal if untreated.

Harmful bacteria, viruses and fungi can be found in soil,
waste water, medical and pharmaceutical waste.

Inspectors should avoid  direct contact with these materials.
                                2.4  HEAT STRESS
                           Heat production exceeds heat loss.
                           Often accompanied by increased:

                                 heart rate
                                 body temperature
                                 respiration
                                 perspiration

                           Adverse effects range from cramps to death.
                           Contributing factors:

                                 ambient temperature
                                 radiant heat
                                 physical labor
                                 chemical exposure
                                 humidity
                                 altitude
                                 inadequate acclimatization
                                 fatigue
                                 alcohol consumption
                                 cardiac and respiratory conditions
                                 some medications
Preventing/
Reducing Heat
Stress
A92-333.1
 Assess probability of heat stress.
 Schedule work for cool periods of day.
 Take adequate breaks.
 Hoist, rather than carry, heavy loads.
 Use protective heat shields, insulating materials, reflectors,
 tarpaulins.

               2-5

-------
Heat Stress
Disorders

Heat Stroke
Symptoms
Emergency
Treatment
Heat Exhaustion


Symptoms
Emergency
Treatment
                          Drink appropriate amounts and types of fluids: 250 ml (
                          cup) water every 15 minutes.

                          Wear head coverings and clothing.
                                light in color
                                absorbent
                                loose fitting

                          Know the symptoms, prevention and treatment of major
                          heat stress disorders.
 Life-threatening
 Sweating mechanism shuts down; body overheats.

 Red or flushed skin
 Hot, dry skin
 Very high body temperature:  41°C (106°F)
 Dizziness
 Nausea
 Headache
 Rapid, strong pulse
 Unconsciousness

 Cool person rapidly - water, fan, air conditioning.
 Get immediate medical care.
 Allow person to sip water if conscious.

 If left untreated, may progress to heat stroke.
 Inadequate blood flow and dehydration.

 Pale, clammy skin
 Profuse perspiration
 Extreme fatigue, weakness
 Normal body temperature
 Headache
 Vomiting
Move victim to cooler location.
Have person lie down and elevate feet 20-30 cm (8-12").
Loosen clothing.
Have person drink electrolyte replacement solution or juice if
possible (every 15 minutes for one hour).
Get medical aid if condition does not improve.
A92-333.1
              2-6

-------
Heat Cramps


Symptoms
Treatment
      Muscle pains and spasms (abdomen, legs) caused by loss of
      electrolytes.

      Painful muscle cramping and spasms
      Heavy sweating
      Vomiting
      Convulsions
      Alert, well-oriented, normal pulse and blood pressure

      Rest quietly in cool location.

      Loosen clothing.

      Massage cramped muscle.

      Give clear juice or electrolyte replacement solution: 250 ml
      (₯i cup) every 15 minutes for one hour.

      Get medical help if symptoms not relieved
Recognition of
Hazards
                      2.5  FIRE AND EXPLOSION HAZARDS
During your field work you may be exposed to fire and explosion
hazards from materials you may be using or encounter.

Recognizing fire and explosion hazards requires an understanding
not only of the types of materials that can catch fire  or are reactive
with air or water, but also of the processes by which  materials burn
or explode.
hlUufty eng
                    2-7

-------
 Essential     •      Combustible material (fuel)
 Components  •      Oxidizer (oxygen in atmosphere)
                    Ignition energy (heat)

 Combustible  Those posing greatest concern are dusts, vapors, and gases that can be
 Materials     ignited easily and burn rapidly or explosively;

                    Gases - diffuse and mix readily with oxygen.

                           Combustible gases - acetylene, ammonia, butane, hydrogen,
                           methane, propane, etc. - hazard also from containers of
                           combustible gases.

                    Solids

                           Must be converted to gas or vapor before they will burn.

                           Finely divided may be dangerous (flour, steel wool).

                           Combustible dusts - agricultural products, wood products,
                           chemicals, Pharmaceuticals, metals, and plastics.

                    Liquids

                           Must be converted to gas or vapor before they will burn.

                           Sprays, mists, foams, or dispersions.

                           Combustible liquids - liquids capable of being ignited -
                           includes flammable liquids.

                           Flammable liquids - flash point temperatures below 100°F
                           (38°C) - many industrial chemicals, paints, thinners, solvents,
                           fuels - containers of these are also hazardous.  See Table 2-1.

Ignition       •      Amount needed depends on:
Energy
                          state and concentration of the combustible material; and

                          concentration of oxygen.

                    Sources:
                          heated metal
                          sparks
                          flames
                          static electricity and sparks
                          sunlight
                          lasers
                          ionizing radiation

hllhsny.cng                                  2-8

-------
                    •      Ignition temperature

                                Minimum temperature necessary to start the material
                                burning.

                                Varies greatly for different materials.

                                Based on normal concentration of oxygen (21%).

Oxidizer             •      Is usually oxygen in air.

                          Peroxides, perchlorates, permanganates, sulfuric acid,
                          chlorine and fluorine may act as oxidizers.

Fire and             Many factors contribute to the occurrence of a fire or an explosion.
Explosion
Characteristics

Flammable          •      Flammable concentration:  all concentrations at which flame
Concentration and         will travel through the mixture.
Flammable Limits
                                Explosion Limits - range of concentrations of gases in
                                air which will support the explosive process is bounded
                                by measurable limits called  explosive limits.  The
                                upper explosive limit (UEL) and the lower explosive
                                limit (LEL) define the parameters of this range.
                                Limits are measured and published as the percentages
                                by volume of vapor  or gas in air containing the normal
                                concentration of oxygen.  See Table 2-1.

                                Lower explosive limit (LEL):  minimum flammable
                                concentration of a material  - also referred to as the
                                lower flammable limit (too "lean").

                                Upper explosive limit (UEL): maximum flammable
                                concentration of a material  - also referred to as the
                                upper explosive limit (too "rich").

Vapor pressure       •      Pressure of the vapor above the surface of the liquid in a
                          container;  liquids with high vapor pressures are generally
                          more hazardous than those with low vapor pressures
                          (temperature dependent).  See Table 2-1.
hlthsfty.eng                                  2-9

-------
Flash point
Specific Gravity
Vapor Density
Temperature at which a liquid will give off enough vapor to
allow flame to propagate through the vapor-air mixture;
liquids with low flash points are generally more hazardous.
See Table 2-1.

Most combustible and flammable liquids have specific
gravities less than 1.0 - will float on water; water should not
be used for firefighting.

Greater than 1.0 - will sink in water; water can be used for
firefighting.

If less than 1.0, vapor rises.
If greater than 1.0, vapor sinks.
          TABLE 2-1. CHARACTERISTICS OF FLAMMABLE LIQUIDS
Liquid
Vinyl acetate
Acetone
Ethyl alcohol
Methyl ethyl
ketone
Gasoline
Kerosene
Toluene
Trichloroethylene
Xylene
Explosion Limits
(% in air)
2.6 - 13.4
2.6 - 12.8
3.3 - 19.0
1.4 - 11.4 (93°C)
1.4 - 7.6
0.6 - 5.0
1.2 - 7.1
12.5 - 90
1.1 - 7.0
Vapor Pressure
(mm Hg at STP)
115
227
50
71
?
?
30
77
10
Flash Point (°C)
-8
-18
13
-9
-43
38
4
37
29
hlthsftyeng
                                      2-10

-------
Preventing Fire
and Explosions
Identification of
Hazards
Control of
Ignition Sources
Instruments and
Equipment
Control of Static
Electricity
      Keep ignition sources away from flammable concentrations.

      Limit amount of flammable liquids taken on field activities.

      Use available ventilation during transfer of liquids.

      Transport flammable liquids in tightly-sealed containers
      protected against impact.

      Get information from Agency files, co-workers who have
      inspected the site, plant personnel.

      Identify materials which may be present; read reference
      sources to determine hazards; take appropriate precautions.

      Use direct-reading instruments to detect flammable
      concentrations onsite.

      Be aware of sources: matches, cigarette lighters, electrical
      switches, electrical equipment, welding sparks,  engines.

      All electrical equipment, sampling apparatus, portable
      instruments, and other possible sources of ignition must be
      safe for use in atmospheres containing flammable
      concentrations of dusts, vapors or gases.

      Most battery-operated  or line-powered field instruments are
      not safe for use in flammable atmospheres.

      If possible, use only  equipment approved by Underwriters
      Laboratory (UL) or  Factory Mutual (FM) for use in specific
      flammable atmospheres.

      Enclose and ventilate sampling equipment which is not
      approved for use in such atmospheres.

      Be aware that some  monitors which check flammable
      concentrations will give false readings if the concentration is
      above the upper flammable limit for the material.

Since static electricity (which  accumulates to higher voltages in
atmospheres with low humidity and  during dry weather) can provide
sufficient ignition energy to set fire to flammable concentrations of
gases and vapors, it is important to recognize what can generate
static electricity and what can be done to prevent accumulation and
discharge of this energy.
hlthsfty.eng
                                       2-11

-------
Sources             •      Particulates moving through a stack.
                    •      Gas issuing from a nozzle at high velocity.
                          Pouring or spraying nonconducting liquids or solids.
                          Materials flowing through pipes, hoses or ducts.
                          Belt running over a pulley.
                          Person walking across a floor.
                          Pouring solvents.
                          Working near a process that generates static electricity.

Preventing           •      Ground probes used for stack sampling.
Accumulation or
Discharge           •      Provide a bonding connection between metal containers when
                          flammable gases or liquids are transferred or poured.

                          Wear footwear with adequate conductivity for the conditions.
              2.6  SELECTION AND USE OF FIRE EXTINGUISHERS
                   Fire is an oxidation process which requires three key components:
                   fuel, oxygen, heat. Removal of any of these  three will stop the
                   oxidation process.

Fire Classifi-        •      See Table 2-2.
cation/ Treatment

Fire Extinguisher    •      See Table 2-3.
Identification

Firefighting         •      Warn others to evacuate area.
Precautions         •      Call Fire Department.
                          Evaluate ability to fight the  fire.

                                proper type and size of extinguisher?
                                additional help?
                                obstacles?
                                retreat?

                          Contain the fire to prevent spread.
                    •      Fight the fire.
                          Never turn your back on the fire.
hllhsftyeng                                  2-12

-------
Using a Fire
Extinguisher

Fire Hose
Soda-add
Aqueous-charged
Dry Chemical
Liquid CO2
Foam
Prepare and test extinguisher before approaching fire.
Aim at base of fire.

Stream reaches about 9 m (30').
Stand back so pressure does not scatter fire.

Turn upside down to mix chemicals and start flow.

Spread stream into fan-shape with finger if pressure is not
too great.

Usually rated "B" and "C"; some are rated "A", "B",  and "C".
Use side-to-side sweeping motion.

       Cover Class A fire.

       Start spraying Class B fire at closest edge and continue
       to far edge; do not get too close.

Low velocity discharge of CO2; need to get within 2 to 4 feet
of fire.

Flow of gas generates extreme cold and static electricity.

Aqueous foam.
Effective on Class A or B fires.
Works well on fairly large fires.
hlthsfty eng
              2-13

-------
     TABLE 2-2. FIRE CLASSIFICATION AND EXTINGUISHING MEDIA
Class
A
B
C
D
Description
ordinary
combustibles
flammable or
combustible liquid
or gases
electrical
equipment
combustible metals
that burn vigorously
and react violently
with water
Examples
wood, paper, cloth,
rubber
gasoline, fuel oil,
kitchen grease,
alcohol, propane
electrical
equipment
Na, K, Mg, Ti, Zi
Extinguishing
Media
water, Halon 1211,
baking soda
CO2, dry
chemicals, foam,
Halon 1211, Halon
1301
dry chemicals,
CO2, Halon 1211,
Halon 1301
dry powders
(graphite, NaCl,
other free-flowing
noncombustible
materials
           TABLE 2-3. FIRE EXTINGUISHER IDENTIFICATION
Class Type
A
B
C
Symbol Description
Burning wastebasket and bonfire
Container pouring liquid and a fire
Electrical plug and a receptacle with
flames
httbsftyeng
                              2-14

-------
           2.7 CHEMICAL HAZARD RECOGNITION AND EVALUATION
Physical
Classification
Solids
Liquids
The degree of hazard associated with a particular chemical
will depend on its toxicity, the way it is used and the
environment in which it is encountered.

The following factors must be considered in evaluating the
degree of hazard present:
      physical form or classification of the chemical
      physical and chemical characteristics  of the chemical
      warning properties
      airborne concentration
      mode of usage
      other environmental conditions

Solids
Liquids
Aerosols
Gases and vapors

Particulates (lead, asbestos)
Sensitization (Ni)
Fumes
Sublimation
Reactivity

Degree of hazard depends on characteristics of the liquid
and how it is used

Factors influencing hazard include:
      temperature
      vapor pressure
      toxicity
                          Types of hazards
                                skin damage
                                direct absorption through skin
                                enhanced absorption of other chemicals
                                splash hazard
                                slipping hazard
                                reactivity
hllhsfty.eng
             2-15

-------
Aerosols
Gases and Vapors
Physical and
Chemical
Characteristics
  Aerosols are fine particulates (solid or liquid) suspended in
  air (dust, fumes, mist, fog, smoke and smog).

  See Table  2-4 for characteristics of air contaminants in work
  places.

  Results may present inhalation, eye or skin hazards.

  A gas is a  state of matter in which the material has very low
  density and viscosity.

  Vapors are the evaporation products of chemicals that are
  normally liquid at room temperature.

  See Table  2-4 for gas/vapor characteristics.

  Gases and  vapors may present inhalation, eye and skin
  hazards.

Boiling point - temperature at which liquid changes to a gas.

Melting point - temperature at which a solid changes to a
liquid.

Vapor pressure • pressure of vapor immediately above the
surface of a material. Term generally applied to liquids;
however, solids have vapor pressure as well. Materials with
high vapor pressure can create  high airborne exposure risks.

Solubility - maximum amount of that substance that will
completely dissolve in a given volume of another substance.

Flash point  - lowest temperature at which a liquid gives off
enough vapor to form an ignitable mixture with air and
produce a flame when an ignition source is present.
Flashpoint and boiling point are used to determine the
classification of flammable  liquids.

Explosion Limits - range of concentrations of gases in air
which will support the explosive process is bounded by
measurable limits called explosive limits. The upper
explosive  limit (UEL) and the lower explosive limit (LEL)
define  the parameters of this range.  The concentration is
generally expressed in percent gas in air.
Mthsftyeng
              2-16

-------
TABLE 2-4.  CHARACTERISTICS OF AIR CONTAMINANTS IN WORK PLACES
Form
How Generated
Example/Size
(micrometers)
Concentration
Expressed As
Aerosols

Dust
Fumes
Mist
Smoke



Gases and Vapors

Gases
Vapors
From solids by
mechanical means:
- grinding
- blasting
- drilling

Condensation
products of metals
and solid organics,
welding on metal

Liquid droplets
formed by atomizing
liquids or
condensing liquids
from vapors,
entrainment

Products of
combustion of
organic materials
Occupy space of
enclosure, liquify
only under increased
pressure and
decreased
temperature

Evaporation
products of
substances normally
liquid at room
temperature
(solvents, gasoline).
Quarry dust (less
than 1 to 10)
Lead fume (less than
0.001 to 0.1)
Chromic acid mist
mg/m3(
mg/m3
mg/m3
Incinerator (less
than 0.5)
CO
mg/m3
ppm1'
Acetone
Carbon disulfide
Benzene
ppm
(1)  mg/m3 - milligrams per cubic meter.
(2)  ppm - parts of gas or vapor per million parts of air.
Uthsfty eng
                   2-17

-------
Warning
Properties
Odor Threshold
Eye, Nose and
Throat Irritation
Taste
Airborne
Concentration
Reactivity - refers to the likelihood of reacting, rather than
the ability to react.  Most chemicals will react with some
other chemical given the right set of conditions.

May include odor, eye, nose or throat irritation and taste.

To be useful  in preventing overexposure, must be evident at
a concentration below the permissible exposure limit (PEL).

Some chemicals have good warning properties (NH3) while
others have none at all (CO).

Odor threshold is airborne concentration at which a chemical
can be detected by smell.

Individuals vary.

Useful odor thresholds are well below the PEL.   (NH3)

Useless  odor  threshold is well above PEL.  (vinyl chloride)

Olfactory fatigue may influence recognition of hazard. (H2S)

PELs for many chemicals have been based on irritation when
it has been demonstrated that toxic effects are produced only-
by substantially higher concentrations. (HC1)

May be useful if a taste is produced at concentrations below
the PEL.  (saccharin)

Since some chemicals do not have adequate warning
properties and because individuals vary in their sensitivities
to various substances, measurement of airborne
concentrations of chemicals may  prove to be useful.

If the potential for chemical exposure is unknown you should
not enter the area unless you are properly protected or until
the chemicals have been identified and the concentrations
reliably  measured or estimated.

If you find yourself in an area where an unknown exposure or
spill occurs, or where you begin to experience signs or
symptoms of exposure (headache, eye  irritation, etc.), leave
the area at once.
hlthsfty.eng
              2-18

-------
Chemical Use       •      Degree of hazard is significantly influenced by the way a
                          chemical is used.

                                 open tanks, hot chemicals, high vapor pressure, poorly
                                 designed or malfunctioning ventilation system = high
                                 airborne concentration

                                 closed system = lower airborne concentrations

Other              •      Temperature.
Environmental      •      Relative humidity.
Factors
               2.8 EFFECTS OF TOXIC CHEMICALS IN THE BODY
                    Toxic chemicals can affect the body in different ways, depending on
                    the combination of several factors:

                          Route of entry.
                          Length of exposure.
                          Organs or systems affected.
                          Absorption, distribution, storage, and elimination.

Routes of Entry     •      Chemical substances may enter the body through the skin,
                          respiratory tract and gastrointestinal tract.

                          Exposures during field activities are most likely to occur
                          through skin contact or inhalation.

Skin                •      Usually effective barrier for  protecting underlying body
                          tissues (see Figure 2-1).

                          Short exposures to strong concentrations of extremely toxic
                          substances (e.g., organic phosphates, phenol, cyanide) can be
                          serious or fatal.

Potential effects of   •      No reaction - skin acts as effective barrier
chemical contact     •      Skin irritation or destruction of tissue
                          Skin sensitization
                          Chemical penetrates skin and enters blood stream
hlthsfty-eng                                  2-19

-------
                                       hair shaft
                                                               nerve ending
                                                               (pair, receptor)
                                                                          perspiration
                                                                          pcre
farty layer.    /
(subcutaneous)\
                capillaries

                muscle

                oil gland

               nerve ending
               (pressure
               receptor)

               sweat gland

Sf'^SS^P^- blood vessels
                                         \                 V
                      connective tissue    hair follicle      /atcells
                          Figure 2-1.  Skin cross-section
                                               2-20

-------
Factors
influencing effects
Respiratory System
         Skin thickness
         Chemical properties
         Skin condition
         Duration of exposure

         Most common route of entry for gases, vapors and airborne
         particulates (see Figure 2-2).

         Major factors influencing the toxic effects of airborne
         chemicals include:
               concentration in ambient air
               physical and chemical properties
               sites of deposition within respiratory system
               body's ability to counteract effects
                                             septum o(
                                             nasal co»i!y
                                             rrcuth cavity
                                             epiglottis
                                             larynx
                                             esophagus
                                             trachea
right lung
(micaie
lorje] \
     \  trachea "••:--
escphajj'js '  .	•..-'"
                                          rv~~^—-L abdominal
                                           \    \ covity
                       Figure 2-2. Organs of the human  respiratory system
hlthsl'ty.cng
                        2-21

-------
Damaging          •     Asphyxiants - gases which can deprive body tissues of oxygen.
substances
                                 simple asphyxiants - displace oxygen and lead to
                                 suffocation (N2, He, CH4, Ne, AT)

                                 chemical asphyxiants - prevent oxygen utilization by
                                 chemical interaction (H2S, CO, HCN)

                          Irritants - may produce inflammation of the sinuses, throat,
                          bronchi, and  alveoli. Cell death may result, leading to edema
                          and secondary infection.  May cause increased pulmonary
                          flow resistance. Examples:  O3, HF, NH3, SOX.

                          Fibrosis producers - kill normal lung tissue and produce scar
                          tissue which may result in oxygen deprivation.  Examples:
                          silicates, asbestos, beryllium.

                          Allergens - substances that act as an antigen upon contact
                          with body tissues (inhalation, ingestion, or skin absorption).
                          Allergens may cause allergic response in the form of
                          bronchoconstriction and pulmonary disease. Examples:
                          isocyanates, sulfur dioxide.

                          Carcinogens - substances that cause cancerous growth in
                          living tissues, such as the lungs.  Examples: coke oven
                          emissions, asbestos, and arsenic.

                          Systemic Toxicants  - substances  that enter via the respiratory
                          tract, but affect other parts of the body. Examples: organic
                          solvents, anesthetic  gases, lead, and mercury.

                    Table 2-5 gives a partial list of industrial toxicants that produce
                    respiratory tract disorders.

Gastrointestinal     •     Chemicals may have a toxic effect on all major and accessory
System                    organs (e.g., liver) of the gastrointestinal tract.

Potential means of  •     Mouth pipetting
ingestion            •     Contaminated water or food
                          Contaminated smoking materials or cosmetics
                          Contaminated hands
                          Drinking from contaminated containers
Utbsftyeng                                  2-22

-------
Length of
Exposure
Acute Exposures
and Effects
Chronic
Exposures and
Effects

Organs and
Systems Affected
Toxic chemicals may affect the body in different ways, depending
not only on the route of exposure but also on the length of
exposure.  Toxic effects may be produced by acute or chronic
exposure to chemical agents.

•     Acute, or short-term, exposures to some chemicals can cause:
             acute effects (sudden onset, short duration)
             permanent adverse effects
             delayed effects (temporary or permanent)
             chronic effects

      You may not be aware of an acute exposure unless there is
      an immediate reaction (pain, irritation).

•     Repeated or prolonged exposure to low concentrations of
      some toxic chemicals can cause adverse effects of long
      duration or frequent reoccurrence.

•     Many toxic substances are associated with specific toxic
      effects on one or more organs or systems, which suggests that
      there is a selective mode of action for many hazardous
      substances. While chemical substances may have a broad
      range of toxic effects on an organism, the effects are
      sometimes so specific that they are defined in terms of the
      most susceptible "target cell" or "target organ."

      Eight other major organs or systems are frequent sites of
      toxic response to chemical substances (see Table 2-6).
bttbsftyeng
                    2-23

-------
TABLE 2-5. INDUSTRIAL TOXICANTS THAT PRODUCE DISEASE OF THE
           RESPIRATORY TRACT
Toxicant
Aluminum
Ammonia
Arsenic
Asbestos
Beryllium
Boron oxide
Cadmium oxide
Carbides of
tungsten, titanium,
and tantalum
Chlorine
Chromium VI
Site of Action
Upper airways
Upper airways
Upper airways
Lung tissue
Alveoli
Alveoli
Alveoli
Upper, lower
airways
Upper airways
Nasopharnyx, upper
airways
Acute Effect
Cough, shortness of
breath, irritation
Irritation
Bronchitis irritation,
pharyngitis

Edema, Pneumonia
Edema, hemorrhage
Cough, pneumonia
Hyperplasia,
metaplasia of
bronchial cells
Cough, irritation,
asphyxiant
Nasal irritation,
bronchitis
Chronic Effect
Fibrosis and
emphysema
Bronchitis, edema
Cancer, bronchitis,
laryngitis
Fibrosis, cancer
Fibrosis, ulceration

Emphysema
Fibrosis

Cancer
Cobalt
Lower airways
Asthma
Fibrosis, interstitial
pneumonitis
Hydrogen chloride
Iron oxides
Isocyanates
Manganese
Nickel
Upper airways
Alveoli, bronchi
Lower airways,
alveoli
Lower airways
alveoli
Nasal mucosa,
bronchi
Irritation, edema
Cough
Bronchitis,
pulmonary edema,
asthma
Pneumonia, often
fatal
Irritation

Benign
pneumoconiosis

Recurrent
pneumonia
Cancer
hltbsfty eng
                                  2-24

-------
                              TABLE 2-5 (CONTINUED)
Toxicant
Nickel carbonyl
Nitrogen oxides
Osmium tetraoxide
Ozone
Phosgene
Phthalic anhydride
Sulfur dioxide
Site of Action
Alveoli
Bronchi, alveoli
Upper airways
Bronchi, alveoli
Alveoli
Lower airways,
alveoli
Upper airways
Acute Effect
Edema (delayed
symptoms)
Edema
Bronchitis,
bronchospasm
Irritation, edema,
hemorrhage
Edema
Bronchitis, asthma
Bronchoconstriction,
cough, tightness in
Chronic Effect

Emphysema
Bronchopneumonia
Emphysema,
bronchitis
Bronchitis, fibrosis,
pneumonia
Emphysema
Bronchitis,
nasopharyngitis
Tin
                                                chest
Bronchioles, pleura
Widespread mottling
of x-ray without
clinical signs (benign
pneumoconiosis)
Toluene
Vanadium
Xylene
Upper airways
Upper, lower
airways
Lower airways
Bronchitis, edema,
bronchospasm
Irritation, nasal
inflammation, edema
Edema, hemorrhage

Bronchitis

hlthsfty.eng
                                          2-25

-------
    TABLE 2-6 ORGANS/SYSTEMS AFFECTED BY CHEMICAL EXPOSURE
      Organs or System
Chemicals Causing Effects
      Liver and Bile Ducts
      (Hepatic System)

      Kidney (Renal System)
      Blood and the Blood-
      forming System
      (Hematopoietic System)

      Heart, Cardiovascular
      System (CVS)

      Neuroendocrine System

      Immune/Allergy System

      Central Nervous System
      (CNS)
Vinyl Chloride, Aromatic
Hydrocarbons

Heavy Metals,  Halogenated
Hydrocarbons

Benzene, Lead
Carbon Monoxide, Arsine


DDT

Triphenyltin

Pesticides, Thallium
hltbsttyeng
                                   2-26

-------
                          2.9  DOSE-RESPONSE CURVES
A dose-response curve describes the relationship between the absorbed dose
(concentration versus time) and the biological response.  The threshold limit value
(TLV) is that dose below which no significant effect is expected to occur.  At higher
doses certain effects may be observed which compensate for the toxic effect.  At still
higher doses, reversible damage to organs may be observed. This damage may become
irreversible at sustained or higher levels. As this dose increases to even more toxic
levels, death will occur.  The shape of the curve will depend on the lexicological
properties  of the material.  See Figures 2-3, 2-4, and 2-5  for representative dose-response
curves.
   Response
t
               Dose
                         Threshold
                         Limit
                         Value
                                                               Death
                                             Irreversible
                                             Effects
                       Figure 2-3.  Classic Dose-response Curve.
hllhslty cng
                                        2-27

-------
Response
t
   Dose
                                      Irreversible
                                      Effects
                                                   Death
                Compensation
            Figure 2-4. Dose-response Curve for a Chemical with no TLV.
 Response
        Threshold
        Limit
        Value
           Reversible
           Effects
                  Compensation
             Dose
 Irreversible
. Effects
Death
            Figure 2-5.  Dose-response Curve fora Highly Toxic Chemical.

                                    2-28

-------
Types of Effects

Harmful Effects
Sensitization Effects
Some chemicals do not elicit such dose-response relationships.

      Include toxic and lethal effects
      Result from overexposure or overdose
      Three major classes:

             non-specific corrosive - irreversible damage to cells
             and tissues,  (strong acids, bases, oxidants)

             specific toxicologies! effects - effects on specific target
             organs or systems - usually reversible if recognized
             early. (CC14 liver cell damage, HCN asphyxiation)

             pathological effects - chronic, usually irreversible.
             (cancer, mutations, birth defects)

      Not dose-dependent
      Require preconditioning exposure
      Immune system affected
      Allergic and hypersensitivity reactions (Ni, nitrophenols,
      isocyanates, formaldehyde, etc.)
Factors
Influencing
Intensity of Toxic
Action

Route of Entry
Age
State of Health
Previous Exposure
      Intensity and nature of response depends on route of
      exposure:  lead (inhalation vs. ingestion).

      Intensity also related to the acute and chronic toxicity of a
      substance: hydrogen sulfide.

      Infants, children, adults, and senior citizens differ in their
      circulatory and excretory systems,  musculature and
      metabolisms which affect the distribution and toxicity of
      substances: newborns (CNS stimulants/suppressants).

      Pre-existing disease may increase sensitivity to toxic agents.

      Nutrition may affect responses.

      Diet can change body composition, physiological and
      biochemical functioning.

      Tolerance
      Increased sensitivity
      No effect
httbsfty eng
                                         2-29

-------
Environmental
Factors
Host Factors
Temperature
Barometric pressure
Radiation

Species
Sex
Hereditary factors
     2.10 EVALUATING HEALTH HAZARDS AND TOXICITY INFORMATION
Reasons to Seek
Information
Exposure Limits
Skin Contact and
Ingestion Exposure
Inhalation
Exposure Limits
Does a hazard exist?
What degree of risk?
Is air monitoring needed?
Can pre-exposure monitoring be done?
Can personal monitoring be done during the activity?
Should possible exposures be documented by medical
monitoring?
What specific protective equipment and clothing are
necessary?
How should one use such equipment and clothing?

Limits on skin  contact
Permissible Exposure Limits (PELs)

Most industrial chemicals required to have precautionary
labels.

Skin and systemic toxicity information provided.

Threshold Limit Values (TLVs) - reviewed and adopted
annually by the American Conference of Governmental
Industrial Hygienists (ACGIH) - advisory,  but more up-to-
date.

Permissible Exposure Limits (PELs) - adopted by the
Occupational Safety and Health Administration (OSHA) -
mandated.
hllbsfiyeng
                                      2-30

-------
Categories of       •     Time-Weighted Average (TWA) - concentration of a toxic
Exposure Limits           substance to which nearly all workers may be repeatedly
                         exposed without adverse effect - based on eight-hour
                         workday, 40-hour workweek.

                         Short-Term Exposure Limit (STEL) - 15-minute time-
                         weighted average exposure which  shall not be exceeded at
                         any time during a work day.

                         Ceiling (C) - concentration that should not be exceeded
                         during any part of the working day.

Important          •     PELs do not represent a fine line between safe and
Information               dangerous.
                         PELs may not be appropriate for  extended shiftwork.
                         PELs may not protect all workers.
                         PELs are not a relative index of toxicity.
                         PELs are based on the best available information.

Signs and          Since you may not know the identity of toxic chemicals to which you
Symptoms of       are-being exposed, and many chemicals have inadequate warning
Overexposure       properties, you must be aware of signs and symptoms of
                   overexposure.

                         Signs - observable by others
                         Symptoms - not observable by others

Signs of            •     Sneezing
Inhalation          •     Coughing
Exposure

Symptoms of       •     Headache
Inhalation          •     Dizziness
Exposure           •     Nausea
                         Irritation of eyes, nose, throat
                         Increased mucus in nose and throat

Signs of            •     Redness
Skin Contact       •     Swelling
                         Dry, whitened skin
hlthsfty.eng                                2-31

-------
 Symptoms of
 Skin Contact

 Other Signs
 and Symptoms
 Evaluating
 Exposure with
 Instrumentation
Preparing for
Field Use of
Equipment
Charactenslics of
Air Monitoring
Instruments
Quantification of
Airborne
Contaminants
      Irritation
      Itching

      Changes in behavior
      Periods of dizziness
•     Muscle spasms
      Irritability

Air monitoring instrumentation provides the most reliable means of
identifying and quantifying airborne contaminants. Information may
be used to help:

      Determine level of worker protection needed;

      Evaluate the level of exposure and, therefore, the health risk
      to field personnel and the need for medical monitoring;

      Assess potential environmental effects; and

      Provide indicators of the effectiveness of hazard abatement
      activities.

Once the appropriate equipment has been selected:

•     Read all instructions.
      Practice using  the equipment.
      Calibrate the equipment before and after using it.

      Portable.
      Able to generate reliable and useful data.
      Sensitive and selective.
      Inherently safe.

•     Direct-reading instruments (See Table 2-7)

             Flammable or explosive atmospheres
             Oxygen deficiency
             Certain gases and vapors
             Ionizing radiation
hlthsfty eng
                    2-32

-------
                TABLE 2-7.  SOME DIRECT-READING INSTRUMENTS
Instrument
Application
Limitations
Combustible Gas
Indicator (CGI)
Flame lonization
Detector (FID) with
Gas
Chromatography
Option
Gamma Radiation
Survey Instrument

Portable Infrared
(IR) Spectrophoto-
meter
Measures the
concentration of
combustible gas or
vapor
In survey mode,
detects the total
concentrations of
many organic
gases and vapors.
In gas
Chromatography
(GC) mode,
identifies and
measures specific
compounds.  In
survey mode, all
the organic
compounds are
ionized and
detected at the
same time. In GC
mode volatile
species are
separated.

Gamma radiation
monitor

Measures
concentration of
many gases and
vapors in air.
Designed to
quantify one- or
two-component
mixtures.
Accuracy depends, in part, on the difference between
the calibration and sampling temperatures.  Sensitivity
is a function of the differences in the chemical and
physical properties between the calibration gas and
the gas being sampled. The filament can be damaged
by certain compounds such as silicones, halides
tetraethyl lead and oxygen-enriched atmospheres.
Does not provide a valid reading under oxygen-
deficient conditions.

Does not detect inorganic gases  and vapors or some
synthetics. Sensitivity depends on the compound.
Should not be used at temperatures less than 40°
F(4°C).  Difficult to absolutely identify compounds.
High concentrations of contaminants or oxygen-
deficient atmospheres require system modification.  In
survey mode, readings can only be reported relative to
the calibration standard used.
Does not measure alpha or beta radiation.
In the field, must make repeated passes to achieve
reliable results.  Requires 115-volt AC power. Not
approved for use in a potentially flammable or
explosive atmosphere. Interference by water vapor
and carbon dioxide.  Certain vapors and high moisture
may attack the instrument's optics which must then be
replaced.
httbsfty eng
                      2-33

-------
                                 TABLE 2-7 (CONTINUED)
Instrument
Application
Limitations
Ultraviolet (UV)
Photoionization
Detector (FID)
Direct-Reading
Colorimetric
Indicator Tube
Oxygen Meter
Detects total
concentration of
many organic and
some inorganic
gases and vapors.
Some
identification of
compounds is
possible if more
than one probe is
used.

Measures
concentrations of
specific gases and
vapors. Available
for a wide variety
of chemicals.

Measures the
percentage of O2
in air.
Does not detect methane.  Does not detect a
compound if the probe used has a lower energy level
than the compound's ionization potential.  Responses
may change when gases are mixed. Other voltage
sources may interfere with measurements. Readings
can only be reported relative to the calibration
standard used. Response is affected by high humidity.
The measured concentration of the same compound
may vary among different manufacturers' tubes.
Many similar chemicals interfere.  Greatest sources of
error are (1) how the operator judges stain's end-
point, and (2) the tube's limited accuracy. Affected
by high humidity.

Must be calibrated prior to use to compensate for
altitude and barometric pressure.  Certain gases,
especially oridants such as ozone, can affect readings.
Carbon dioxide (COj) poisons the detractor cell.
Source: NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities
hlthsfty.eng
                                              2-34

-------
                         Laboratory analysis of air samples
                               Anions
                               Aliphatic amines
                               Asbestos
                               Metals
                               Organics
                               Nitrosamines
                               Particulates
                               PCBs
                               Pesticides
                               2.11 REFERENCES
                   Some sources which can provide information concerning the toxicity
                   and other potential hazards of chemicals are listed below.
Airborne
Exposure Limit
Information
Occupational Safety and Health Administration (OSHA) -
Permissible Exposure Limits (PELs) can be found in 29 CFR
1910 Subpart Z.

National Institute for Occupational Safety and Health
(NIOSH).

      Recommended exposure limits (RELs) can be found
      in criteria documents available from NIOSH, the
      National Technical Information Service (NTIS), or, in
      some cases, the EPA

      Pocket Guide to Chemical Hazards - provides useful
      information on regulated chemicals: PELs, TLVs,
      RELs and data regarding synonyms, IDLH levels,
      physical description,  chemical and physical properties,
      incompatibilities, measurement methods, personal
      protection, respirator selection and  health hazards.
      Single copies available from NIOSH at no charge.

American Conference of Governmental Industrial Hygienists
(ACGIH) - Threshold Limit Values (TLVs) are reviewed
periodically and the TLV list published annually - available
from ACGIH Publications Office, 6500 Glenway Avenue,
Building D-7, Cincinnati, OH 45211-4438.
hlthsfty eng
                                      2-35

-------
Material Safety
Data Sheets
Other Sources
OSHA Hazard Communication Standard requires all
chemical manufacturers and vendors to provide material
safety data sheets (MSDSs) for the products that they sell.

MSDSs contain information concerning:
      hazardous ingredients
      physical and chemical characteristics
      acute and chronic health hazards
      respiratory protection and ventilation requirements
      fire and reactivity data
      spill control measures
      disposal requirements
      labeling requirements
      other requirements relevant to the safe use of the
      product

Employers are responsible for obtaining or developing an
MSDS for each hazardous  substance used in their workplaces
and ensuring that employees have  access to this information.

NIOSH/OSHA Occupational Health Guidelines for Chemical
Hazards, U.S.  Government Printing Office, Washington, DC
20402

Documentation of the Threshold Limit Values (TLVs),
ACGIH Publications Office, 6500 Glenway Avenue, Building
D-7, Cincinnati, OH 45211

CHRIS:  Chemical Hazard Response Information System -
available through the National Response Center - Volume 2 -
information on hazardous waste spills and dump site cleanup.

Fire Prevention Guide on Hazardous Materials, seventh
edition, National Fire Protection Association (NFPA),
Quincy, MA 02269 - information on pure chemicals; very
little on mixtures.

The Merck Index, 10th edition (1983), Merck and Company,
Inc., Rahway, NJ  07065 - information on chemicals, drugs,
and biological substances.
bltbsflyeng
              2-36

-------
                         Dangerous Properties of Industrial Materials, (current
                         edition), edited by N. Irving Sax, Von Nostrand Reinhold
                         Co., 135 W. 50th Street, New York, NY 10020 - information
                         and technical data on nearly 13,000 industrial and  laboratory
                         chemicals.

                         Condensed Chemical Dictionary, 10th edition (1981), Gessner
                         G. Hawley, Von Nostrand Reinhold Co., 135 W. 50th Street,
                         New York, NY 10020 - concise, descriptive technical data on
                         thousands of chemicals and reactions.

                         Farm Chemicals Handbook, (1984), Richard T. Meister,
                         editorial director, Meister Publishing Co., 37841 Euclid
                         Avenue, Willoughby, OH 44094 - annual publication listing
                         information regarding pesticides and products.

                         NIOSH Registry of Toxic Effects of Chemical Substances,
                         (RTECS), 1980 edition, U.S. Department of Health and
                         Human Services, Public Health Service, Centers for Disease
                         Control, NIOSH, Cincinnati, OH  45226, or Government
                         Printing Office, Washington, DC - contains toxicity data on
                         nearly 40,000 chemicals and lists over 145,000 chemical
                         substances.

                         1984 Emergency Response Guidebook:  Guidebook for
                         Hazardous Materials Incidents, 1984, U.S. Department of
                         Transportation, Materials Transportation Bureau, DMT-11,
                         Washington, DC 20036.

                         Emergency Handling of Hazardous Materials in Surface
                         Transportation, 1981, Bureau of Explosives, Association of
                         American Railroads, 1920 L Street, NW, Washington, DC
                         20036.

                         Handbook of Toxic and Hazardous Chemicals, 1981,
                         Marshall Sitting,  Noyes Publications, Noyes Building, Park
                         Ridge, NJ 07656.

                         Toxic and Hazardous Industrial Chemical Safety Manual,
                         1982, International Technical Information Institute - available
                         through Laboratory Safety Supply, P.O. Box 1368, Janesville,
                         WI 53547-1368, and others.
hlthsfty.eng                                 2-37

-------
                        Data bases available to EPA personnel:

                              OHMTADS: Oil and Hazardous Materials Technical
                              Assistance Data System (developed by EPA)

                              HMIS:  Hazardous Materials Information System
                              (developed by DOD, Defense Logistics Agency,
                              Defense General Supply Center, Richmond, VA
                              23297

                              MEDLARS
                              TOXLINE
                              TOXBACK
                              TOXBACK/65
             2.12 EMERGENCY FIRST AID FOR FIELD ACTIVITIES
                  Since employees engaged in field activities are often in remote,
                  unaccessible areas, it is essential that they know the basics of
                  emergency first aid.

                  Every field team should have at least one member with current
                  training in first aid, cardiopulmonary resuscitation (CPR) and
                  chemical splash treatment.

                  Each employee should carry a wallet card with important medical
                  information such as blood type, allergies, current medication and
                  physical impairments.

                  The  following information is very basic and does not take the place
                  of a  first aid or CPR course.  You should obtain more information
                  on each of the medical emergencies mentioned.  The information in
                  this section is  derived from two publications: American Red Cross:
                  Adult CPR and American  Red Cross:  Multimedia Standard First Aid.

Planning to        •     Urgent care essential:
Provide First
Aid or Urgent            -     severe bleeding
Care                    -     breathing has stopped
                              no pulse

hlthsBy-eng                               2-38

-------
Preplanning
Complete a Medical Emergency Planning Checklist:
Initial
Response

Providing
First Aid or
Urgent Care
Obstructed
Airway

Conscious Person
      location of nearest medical facility
      emergency communication and transportation
      available
      risks involved in field activities
      exact location of field activity
      identification of first aid/urgent care providers in the
      crew

Ensure that crew members complete and carry medical
information card.

Gather first aid/urgent care supplies.

Assess and prioritize treatment (breathing, bleeding).
Request help or secure transportation for victim.

Make a prompt rescue.
Ensure breathing/pulse.
Control severe bleeding.
Protect victim from unnecessary manipulation/disturbance.
Avoid or overcome chilling.
Determine injuries or cause for sudden illness.
Examine victim methodically.
Carry out appropriate first aid.
Follow specific procedures for the following:

      obstructed airway
      adult rescue  breathing
      CPR
      electrical  shock
      wounds (severe bleeding) and shock
      specific injuries to head, neck and back
      chemical splashes, inhalation of toxic gas and burns
      drowning
      heat stress

Determine whether the person is choking (ask him!).
Have another person request medical assistance.

Perform "Heimlich Maneuver".
hlthsfty.eng
              2-39

-------
Unconscious
Person
Adult Rescue
Breathing
Procedure
hltbsfly.eng
If you are choking, perform Heimlich Maneuver using fist or
back of chair.

Request help.

Position person on back.

Open airway.

Look, listen and feel for breathing.

Attempt to give two full breaths.

If unsuccessful, retilt head and try again.

If still unsuccessful, perform abdominal thrusts and finger
sweep to clear obstruction.

May be required  due to:

       allergic reactions
       electric shock
       oxygen-deficient atmosphere
       toxic gas paralysis
       obstructed airway

Check for consciousness, breathing and pulse.

Have someone get medical assistance.

Position victim onto back.

Open airway.

Check again for breathing (listen, watch chest and feel for
breath).

Give two full breaths.

If still not breathing, reposition head.

Try again.

Perform Heimlich Maneuver if airway is blocked.

              2-40

-------
Cardiopubnonary
Resuscitation (CPR)
Electrical
Shock
Wounds
(Severe
Shock)
Check carotid pulse.

Begin rescue breathing.

       one breath every five seconds (approximately 1 to l!/2
       seconds/breath)

       listen and feel for breath, watch chest

Recheck pulse after one minute of rescue breathing.

Continue rescue breathing until:

       victim breathes;
       another rescuer takes over;
       emergency personnel arrive;
       you can't continue.

Chest compressions and rescue breathing used together (15
compressions/two breaths).

May be needed for:

       heart attack (most common)
       electrical shock
       chemical exposure

CPR should be administered only by personnel specially
trained in the procedure.

Can stop breathing  and heart or cause heart to beat
ineffectively.

If victim still  in contact with source of electricity:

       shut off power; or
       safely move victim away from source.

Determine need for rescue  breathing/CPR.

Stop bleeding.
Protect wounds from contamination.
Prevent shock.
Get medical help.
hlthsfty.eng
              2-41

-------
Severe
Bleeding


Shock
Head, Neck,
Back Injuries

Head, Neck
Back
Chemical
Splashes
Direct pressure/elevation.
Pressure points.
Tourniquet (sacrifice the limb!)

Comfort, quiet, soothe victim.

Keep victim lying down, normal temperature.

Standard position - feet and injury elevated.

If head wound or breathing difficulty, elevate head and
shoulders.

If fractures suspected and not splinted, or elevation is painful,
keep victim flat on back.

Bleeding from mouth, nauseous, vomiting - lie on side.
Signs of injury:

       bumps, bruises, cuts
       headache
       dizziness
       unconsciousness
       unequal pupils
       sleepiness
       bleeding/fluid - mouth, nose, ears
       paralysis

Sometimes difficult to decide - suspect injury whenever an
accident involves force.

Keep injured head, neck, spine from moving.

Keep victim lying flat (raise head, shoulders), monitor
breathing, get medical help, do not administer stimulants.

Handle victim carefully.
Administer rescue breathing without repositioning.

Flush chemicals off as quickly and thoroughly as possible (15
minutes).
hllhsfiy.eng
                                        2-42

-------
                          Splashes of hot, concentrated or corrosive chemicals (several
                          hours).

                          Medical followup where indicated.

Eyes                •      Irrigate thoroughly (15 minutes).
                    •      Contact lenses may aggravate chemical burns.
                          Do not use neutralizing solutions.

Skin                •      Remove contaminated clothing.
                          Wash affected skin thoroughly.
                          Be aware of potential spread of contaminant.
                          Try to find water source whose  temperature can be adjusted
                          for prolonged washing.
                          If victim is conscious, give plenty of non-alcoholic liquids to
                          drink.

Inhalation of        •      Get exposed person out of toxic atmosphere.
Toxic Gas
                          If a toxic liquid has been splashed on victim's face, wash it
                          off quickly.

                          Administer rescue breathing.

                          Continue until normal breathing is restored or a resuscitator
                          is available.

                          Treat for shock.

Bums               •      Can be life-threatening depending on location and amount of
                          body affected.

                    •   •   If bum results from chemical splash, first treat for splash,
                          then burn.

                          Stop, drop, roll.

                          Major objectives:
                                relieve pain
                                prevent contamination
                                reduce likelihood of shock

                          Cooling and aspirin help relieve pain.


hlthsfty.eng                                  2-43

-------
Small Shallow
Bums
Large Shallow
Bums
Deep Bums
Shock Prevention
Insect Stings
and Allergic
Reactions
Drowning
Use cool water directly on burn on unbroken skin; immerse if
possible.

Pat dry with sterile gauze.

Bandage if necessary.

Cool with water until pain subsides.
Dry gently and cover with thick, dry, sterile dressing.
Use insulated cold packs over dressing if helpful.

Do not put water on open burn to cool it.
Cover burn with thick sterile dressing and bandage.
Do not remove clothing which is sticking to a burn.
Use dry, insulated cold packs to relieve pain.
Seek medical assistance for extensive deep burns.

Have victim lie down.
Elevate burned areas (if possible).
Maintain normal body temperature.
Have victim drink water is possible.

Ensure adequate airway.
Remove stinger.
Use emergency kit.
Obtain medical attention.

Unless trained in lifesaving, do not attempt personal rescue;
use boat, life preserver, etc.

Begin  rescue breathing as soon as possible.

Use proper technique to move or lift victim with suspected
head, neck or back injury.

Administer rescue breathing and CPR for lengthy time to
victim of cold water drowning:  <21°C (70°F)

Victim may vomit.
hlthsfiyeng
              2-44

-------
                                  CHAPTER 3
                3.0 PROTECTIVE CLOTHING AND EQUIPMENT
                                3.1  OBJECTIVE
                  To provide general information on selecting and using appropriate
                  personal protective clothing and equipment.
                SELECTION OF PERSONAL PROTECTIVE CLOTHING
                            AND EQUIPMENT (PPE)
General
Precautions

Head Protection
Eye and Face
Protection
Proper selection of PPE requires a thorough understanding of the
hazards to be faced:

      Chemical - inhalation, skin contact
      Mechanical - falling objects, moving parts
      Physical - noise, radiation
      Thermal - heat, cold
      Electrical

      Use the correct type of equipment needed.
      Use only properly fitting personal protective equipment.

      Essential where there are overhead hazards (platforms,
      scaffolding, piping)

      American National Standards Institute (ANSI) standard:
      impact of 400 foot-pounds and insulation against 2,200 volts.

      Adjust suspension harness so there is 3 cm (1") clearance
      between hat and top of head.

      Can be equipped with insulation and chin strap.

      Store properly.

      Use whenever there is danger of flying or falling particles or
      chemical splashes.

      Use eye and face protection which meets ANSI Z87.1-1981
      standards and OSHA requirements.
hlthsfty eng
                                      3-1

-------
Foot Protection
Impact
Penetration


Chemicals
Ankle Twists and
Sprains
hlthsfty.eng
      Ordinary prescription glasses do not meet standards.

      Always carry and use your own eye protection.

      Side shields, goggles and face shields may be necessary.

      Contact lenses should not be worn at sites where eye and
      face protection is necessary:

             May complicate first aid efforts.

             May absorb gases and vapors from the air and
             aggravate chemical injury.

             OSHA prohibits use of contact lenses when respirators
             are worn.

Make selection based on hazard to be encountered:

      Impact
•     Penetration
      Chemicals
      Ankle twists and sprains
•     Slippery surfaces
      Cold
      Heat
      Static electricity

•     Use steel-toed footwear where heavy objects may drop on the
      foot (ANSI Z41.1).

•     Metatarsal guards may be required at the site.

      Where soles may  be penetrated, wear safety boots with
      reinforced soles.

•     Select footwear (boots, pullover boots, shoe covers)  based on
      ability to resist penetration or permeation by the chemicals.

      Possible materials:  neoprene, PVC, butyl rubber,  natural
      rubber.

      Do not wear leather footwear where contamination  may
      occur.

      Wear high-top industrial work boots where there are
      hazardous walking/working surfaces.

                    3-2

-------
Slippery Surfaces
Slips, trips and falls are most frequent and most disabling.
Static Electricity
Hearing
Protection
Select footwear with hazard in mind - design and material of
sole is important.

Rubber-soled shoes increase the hazard.
Use special conducting shoes or other static diffusing devices.

Long-term exposure can cause permanent loss of hearing (see
Figure 3-1).

Shorter exposures may result in temporary loss.

If conversation is difficult at  a  distance of three feet, hearing
protection should be used.

Noise Reduction Rating  (NRR):  ability of hearing protector
to reduce sound levels -  NRR increases as ability to protect
increases (See Table 3-1).

Choose proper hearing protector for the work  environment.

Be aware of potential  contamination of hearing protection.
                                                          SEMICIRCULAR
                                                            CANALS
                                                                      EIGHTH NERVE
                                                                     OVAL WIKOOW
                       External Ecr
                                                  ORGAN
                                            ROLWO   Of
                                           W1MOO*  COBTI
                             COCHLEA
                Middle     Inner
                  Ear      Ear
                                         Figure 3-1.  The ear
hlthsfty.cng
               3-3

-------
TABLE 3-1.  TYPICAL NOISE REDUCTION RATINGS (NRRs) FOR COMMON
             HEARING PROTECTION DEVICES
Type of Hearing Protection Device                         Range of NRRs


Premolded earplugs (including flanged and conical models)   16 to 27

Custom-molded earplugs                                  11 to 31

User-molded earplugs                                    16 to 26

Self-molding earplugs (expandable foam)                   29 to 32

Self-molding earplugs (glass fiber)                         22 to 27

Ear muffs (over the head)                                 19 to 29


Source:  NIOSH Compendium of Hearing Protection Devices, 1984.
Hand Protection    •      Gloves should be selected based on the probability of:
                               abrasions, bruises, lacerations, splinters, etc.
                               chilling, freezing, or burns
                               chemical and biological contaminants
                               electrical shock

                   •      Refer to the Guidelines for the Selection of Chemical
                         Protective Clothing (EPA Regional Health and Safety
                         Offices).

                         Liquid-proof gloves are not necessarily permeation resistant.

                         A variety of gloves may be necessary to provide proper
                         protection (wear durable over impermeable but delicate).

                         See Table 3-2 for information on the physical characteristics
                         of protective materials.

                         Have extra gloves available during field activities.

Skin and Body      •      Select clothing for resistance to  chemical degradation and
Protection                permeation, and heat resistance.
hlthsfty eng                                3-4

-------
                        TABLE 3-2.  PHYSICAL CHARACTERISTICS OF PROTECTIVE MATERIALS*
Abrasion
Material Resistance
Butyl Rubber (Butyl)
Chlorinated Polyethylene (CPE)
Natural Rubber
Nitrite-Butadiene Rubber (NBR)
Neoprcne
Nitrile Rubber (Nitrite)
Nitrite Rubber & Polyvinyl
Chloride (Nitrile & PVC)
Polyethylene
Polyurethane
Polyvinyl Alcohol (PVA)
Polyvinyl Chloride (PVC)
Styrene-Butadiene Rubber (SBR)
Viton
F
E
E
E
E
E
G
F
E
F
G
E
G
Cut
Resistance
G
G
E
E
E
E
G
F
G
F
P
G
G
Flexibility
G
G
E
E
G
E
G
G
E
P
F
G
G
Heat
Resistance
E
G
F
G
G
G
F
F
G
G
P
G
G
Ozone
Resistance
E
E
P
F
E
F
E
F
G
E
E
F
E
Puncture
Resistance
G
G
E
E
G
E
G
P
G
F
G
F
G
Tear
Resistance
G
G
E
G
G
G
G
F
G
G
G
F
G
Relative
Cost
High
Low
Medium
Medium
Medium
Medium
Medium
Low
High
Very High
Low
Low
Very High
'Ratings are subject to variation depending on formulation, thickness, and whether the material is supported by fabric.
E-excellent; G-good; F-fair; P-poor
       A92-333.1
3-5

-------
                        No one suit will provide appropriate protection in all
                        situations.

                        A variety of protective garments are available.

                        Materials are not intended for prolonged contact with
                        concentrated chemicals;  always have extra clothing at the site.

                        Do not use synthetic fabric suits when contact with hot
                        surfaces is possible.

                        See Appendices 3-A and 3-B for information regarding
                        protective clothing and materials.
                         3.3 LEVELS OF PROTECTION
                   To aid in selecting PPE, EPA has developed a protocol consisting of
                   four levels of protection.  Each level provides  a given degree of
                   protection to the skin and respiratory system (See Table 3-3).
Considerations
Reasons for
Upgrading
Reasons for
Downgrading
Type, measured concentration, and toxicity of the chemical
substance in the ambient atmosphere.

Potential for exposure to airborne materials, liquid splashes,
or other materials.

Known or suspected presence of dermal hazard.
Occurrence or likely occurrence of gas or vapor emission.
Change in work task.
Personal request.

New information regarding hazard.
Change in site conditions.
Change in work task.
            3.4  CONTROLLING THE TRANSFER OF CONTAMINANTS
                   Improper use or handling of materials can unintentionally result in
                   transfer of contaminants to unintended objects.  Proper preparation
                   will minimize the potential for such contamination.
hlthsfty.eng
                                       3-6

-------
                                                           TABLE 3-3.  LEVEL OF PROTECTION
Level of Protection
Equipment
Protection Provided
Should Be Used When
Limiting Criteria
                           RECOMMENDED-

                           •  Pressure-demand, full-facepiece
                              SCBA or pressure-demand supplied-
                              air respirator with escape SCBA.

                           •  Fully-encapsulating, chemical-
                              resistant suit.

                           •  Inner chemical-resistant gloves

                           •  Chemical-resistant safety
                              boots/shoes.

                           •  Two-way radio communications
                              (intrinsically safe)

                           OPTIONAL:

                           •  Cooling unit
                           •  Coveralls
                           •  Long cotton underwear
                           •  Hard hat
                           •  Disposable gloves and boot covers
                                        The highest available level of
                                        respiratory, skin, and eye
                                        protection.
                                  The chemical substance has been
                                  identified and requires the highest
                                  level of protection for skin, eyes
                                  and the respiratory system based
                                  on either.

                                   •  measured (or potential for)
                                      high concentration of
                                      atmospheric vapors, gases, or
                                      particulates or

                                   •  site operations  and work
                                      functions involving a high
                                      potential for splash, immersion,
                                      or exposure to  unexpected
                                      vapors, gases, or particulates of
                                      materials that are harmful to
                                      skin or capable of being
                                      absorbed through the  intact
                                      skin.

                                   Substance with a high degree of
                                   hazard to the skin are known or
                                   suspected to be present, and skin
                                   contact is possible.

                                   Operations must be conducted in
                                   confined, poorly ventilated areas
                                   until the absence of conditions
                                   requiring Level A protection is
                                   determined.

                                   Direct reading field instruments
                                   indicate high levels of unidentified
                                   vapors and gases in the air.
                                   Fully-encapsulating suit material
                                   must be compatible with the
                                   substance involved
         A92-333.1
                                   3-7

-------
                                                                     TABLE 3-3 (CONTINUED)
Level of Protection
Equipment
Protection Provided
Should Be Used When
Limiting Criteria
B
RECOMMENDED:

•  Pressure-demand, full-facepiece
   SCBA or pressure-demand supplied
   air respirator with escape SCBA.

•  Chemical-resistant clothing (overalls
   and long-sleeved jacket; hooded,
   one- or two-piece chemical splash
   suit; disposable chemical-resistant
   one-piece suit).

•  Inner and outer chemical-resistant
   gloves.

•  Chemical resistant safety
   boots/shoes.

•  Hard hat.

•  Two-way radio communications
   (intrinsically safe).

OPTIONAL:

•  Coveralls
•  Disposable boot covers
•  Face shield
•  Long cotton underwear
The same level of respiratory
protection as Level A but less
skin protection.

It is the minimum level
recommended for initial site
entries until the hazards have
been further identified.
The type and atmospheric
concentration of substances have
been identified and require a high
level of respiratory protection, but
less skin protection.  This involves
atmospheres'

•  with IDLH concentrations of
   specific substances that do not
   represent a severe skin hazard;
   or

•  that do not meet the criteria
   for use of air-purifying
   respirators.

Atmosphere contains less than
19.5  percent oxygen

•  Presence of incompletely
   identified vapors or gases is
   indicated by direct-reading
   organic vapor detection
   instrument, but vapors and
   gases are not suspected of
   containing high levels of
   chemicals harmful to skin or
   capable of being absorbed
   through the intact skin.
   Use only when the vapor or
   gases present are not suspected
   of containing high
   concentrations of chemicals that
   are harmful to skin or capable
   of being absorbed through  the
   intact skin.

   Use only when it is highly
   unlikely that the work being
   done will generate either high
   concentrations of vapors, gases
   or particulates or splashes of
   material that will affect exposed
   skin.
         A92-333.1
                                   3-8

-------
                                                                  TABLE 3-3 (CONTINUED)
Level of Protection
Equipment
Protection Provided
Should Be Used When
Limiting Criteria
                           RECOMMENDED:

                           •  Full-facepiece, air-purifying,
                              canister-equipped respirator.

                           •  Chemical-resistant clothing (overalls
                              and long-sleeved jacket; hooded,
                              one- or two-piece chemical splash
                              suit; disposable chemical-resistant
                              one-piece suit).

                           •  Inner and outer chemical-resistant
                              gloves.

                           •  Chemical-resistant safety
                              boots/shoes.

                           •  Hard hat.

                           •  Two-way radio communications
                              (intrinsically safe).

                           OPTIONAL:

                           •  Coveralls
                           •  Disposable boot covers
                           •  Face shield
                           •  Escape mask
                           •  Long cotton underwear
                                        The same level of skin protection
                                        as Level B, but a lower level of
                                        respiratory protection
                                     The atmospheric contaminants,
                                     liquid splashes, or other direct
                                     contact will not adversely affect
                                     any exposed skin.

                                     The types of air contaminants
                                     have been identified,
                                     concentrations measured, and a
                                     canister is available that can
                                     remove the contaminant.

                                     All criteria for the use of air-
                                     purifying respirators are met.
                                     Atmospheric concentration of
                                     chemicals must not exceed
                                     IDLH levels.

                                     The atmosphere  must contain at
                                     least 19 5 percent oxygen.
          A92-333.1
                                   3-9

-------
                                                              TABLE 3-3 (CONTINUED)
Level of Protection
Equipment
Protection Provided
Should Be Used When
Limiting Criteria
D
RECOMMENDED:

• Coveralls
• Safety boots/shoes
• Safety glasses or chemical splash
  goggles
• Hard hat

OPTIONAL:

• Gloves
• Escape mask
• Face shield
No respiratory protection
Minimal skin protection.
  The atmosphere contains no
  known hazard.

  Work functions preclude
  splashes, immersion, or the
  potential for unexpected
  inhalation or contact with
  hazardous levels of any
  chemicals.
  This level should not be worn
  in highly contaminated areas

  The atmosphere must contain at
  least 19.5 percent oxygen.
Adapted from:  NIOSH/OSHA/USCG/EPA:  Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, 1985.
        A92-333.1
                               3-10

-------
 Planning          •     Disposable equipment
                         Onsite decontamination
                         Method of decontamination
                         Disposal
                         Appropriate supplies

 Preventing         •     Minimize surfaces touched.
 Transfer of        •     Avoid walking on or through chemical spills.
 Contaminants      •     Wrap contaminated equipment and containers before placing
                         them on a clean surface.

                         Control personal habits which may transfer contaminants to
                         clothing or exposed parts of body.

                         Remove protective clothing and discard properly.

                         Use disposable equipment and discard on site.

                         Decontaminate nondisposable equipment immediately after
                         use or package properly for later decontamination.
                            3.5 DECONTAMINATION
                   Contamination may occur even though protective clothing and
                   respirators are used and good work practices are followed. To
                   prevent transfer of contaminants into clean areas, decontamination
                   must be performed. This consists of physically removing
                   contaminants or changing their chemical nature.  Use of soap and
                   water is often sufficient for proper decontamination.

                         Refer to the NIOSH/OSHA/USCG/EPA Occupational
                         Safety and Health Guidance Manual for Hazardous Waste
                         Sites, 1985, or the EPA Standard Operating Safety Guides.

                         Use large, thick, plastic bags for the  disposal of contaminated
                         disposable materials.

                         Set up an area onsite for the decontamination of sampling
                         equipment, sample containers, and their carrying containers.

                         Wash exposed areas prior to eating, drinking, or using
                         tobacco products with soap and water or premoistened,
                         disposable towelettes.              r:^ "»?/• v^-
-------
             3.6 DONNING AND DOFFING PROTECTIVE CLOTHING
                    Achieving the complete benefits of protective clothing depends on
                    the techniques used for donning and doffing the clothing. In
                    general, care must be taken to avoid tearing or puncturing the
                    materials, and to avoid contaminating the inside of the garments.

Helpful Hints       •     Pull pants of protective clothing down over the boots and
                          tape in place.

                          Tape gloves to sleeves of protective clothing in similar
                          fashion.

                          Have an assistant help when you are donning or doffing
                          protective clothing.

                          Store protective clothing where it will not become
                          contaminated.

                          See Appendix 3-C for specific donning and doffing
                          procedures.
                         3.7 STORAGE OF EQUIPMENT
                    Proper storage can result in:

                          longer life;
                          reduced maintenance;
                          increased availability of critical gear;
                          minimization of cross-contamination; and
                          prevention of punctures and tears.
A92-333.1                                3-12

-------
                                 APPENDIX 3-A
         PERFORMANCE REQUIREMENTS OF PROTECTIVE CLOTHING
Clothing Section
Resistance to
Degradation by
Chemicals

Resistance to
Penetration by
Chemicals
Select personal protective clothing which will provide the best
possible protection against the chemicals and environment to which
you will be exposed.

Important characteristics to consider:

      Strength and durability - generally proportional to thickness;
      however, increased durability generally reduces flexibility.

      Thermal resistance - behavior in hot/cold environments? -
      melting?

      Ability to be cleaned, decontaminated, or protected from
      contamination.

      Resistance of protective clothing to chemical damage or
      degradation, mechanical penetration, and permeation
      through the intact material.

A great deal of information concerning the chemical resistance of
materials from which protective gloves and clothing are made can
be obtained.

      Select personal protective clothing with care; porous
      materials, tears, punctures, stitched seams, button holes and
      loose openings can allow penetration.

      Store, transport and handle gloves and protective clothing
      with care at all times.

      Inspect personal protective clothing for holes before use.

      Seal openings between garments, gloves and boots with
      adhesive tape that will resist the hazardous material you
      expect to encounter.
A92-333.1
                   3-13

-------
Resistance to         •      Gases, liquids and some solids can diffuse through materials
Permeation by             used to make protective gloves and clothing.
Chemicals
                           Permeation can occur without degradation or damage to the
                           protective material.

                           No protective material will resist permeation by all
                           chemicals.

                           Reduce permeation by:

                                 minimizing concentrations in contact with protective
                                 materials;

                                 using thicker materials; and

                                 avoiding prolonged exposure or contact with
                                 chemicals.
A92-333.1                                3-14

-------
                                 APPENDIX 3-B
                            PROTECTIVE MATERIALS
Fabrics              •      Tyvek:  non-woven fabric; resists tears, punctures and
                           abrasion; relatively inexpensive; used for disposable
                           garments; resists buildup of static electricity (unless
                           laundered); melting point:  135°C (275°F).

                           Nomex:  woven fabric of polyamide fibers; very durable and
                           acid-resistant; flame-resistant, but not noncombustible;
                           allows passage of gas, vapor and steam.

Elastomers          Are natural or synthetic polymeric materials that exhibit good
                    elasticity and varying degrees of resistance to chemical degradation
                    and permeation.

                           Polyethylene:  inert but permeable material that will absorb
                           organic solvents; sometimes used to coat Tyvek garments to
                           provide resistance to acids, bases and salts.

                           Polyvinyl chloride (PVC):  resistant to acids, but somewhat
                           permeable and retentive of contaminant; coating for fully-
                           encapsulating suits made of Nomex.

                           Neoprene: better general protection than PVC; retains
                           contaminants; many respirator facepieces and breathing
                           hoses.

                           Chlorinated polyethylene (CPE or Choropel):  resists
                           degradation by many chemicals; permeation resistance
                           unknown; splash suits and fully-encapsulating suits.

                           Butyl Rubber:  highly resistant to permeation by gases; does
                           not resist halogenated hydrocarbons and petroleum
                           compounds; does not retain contaminants; boots, gloves,
                           splashsuits, aprons and fully-encapsulating suits.

                           Viton: fluoroelastomer with greater resistance to
                           degradation and permeation than neoprene and butyl
                           rubber; does not protect against some chemicals like
                           ketones and aldehydes; does not retain contaminants; fully-
                           encapsulating suits.

A92-333.1                                3-15

-------
                            Natural rubber:  resists degradation by alcohols and
                            caustics; used for boots and gloves.

                            Milled nitrite:  resists petroleum products; boots and gloves.

                            Polyvinyl alcohol (PVA):  soluble in water but protects
                            against aromatic and chlorinated hydrocarbons.

                     For additional information consult EPA's Guidelines for the
                     Selection of Chemical Protective Clothing, 1987.
A92-333.1                                 3-16

-------
                                APPENDIX 3-C
            PROCEDURES FOR DONNING AND DOFFING PERSONAL
                            PROTECTIVE CLOTHING
Using Gloves
Gloves
Removing Gloves
Using Boots

Boots


Removing Boats
Trim fingernails and remove jewelry which may puncture
material.

Use powdered gloves if possible.

Use several layers of differing gloves if necessary.

Loosen both gloves by pulling lightly on each fingertip of
the gloves.

Do not touch your skin with the outer surface of either
glove.

Remove the first glove either by pulling on the fingertips or
by grasping it just below the cuff on the palm side and
rolling the glove off the fingers.

Remove the second glove by inserting the ungloved fingers
inside the cuff on the palm side without touching  the
outside of the glove, and pushing or rolling the glove off the
fingers.

Before use, be sure shoes cannot puncture overboots.

Use layers of boots of differing capabilities if necessary.

Wear gloves unless boots are very loose.

Loosen boots by pulling them lightly with  the gloved hand.

Do not allow outside of boot to contact bare skin.

Remove first boot by pulling it off the foot with a gloved
hand or a bootjack, or by inserting the ungloved fingers
inside the boot and pushing it off without  touching the
outside of the boot.
A92-333.1
            3-17

-------
Using and
Removing Full
Body Suits
Donning the Suit
Doffing the Suit
Remove second boot in the same fashion.

Safe use of full protective equipment requires a team of
persons who are  physically fit and trained and practiced in
the use of self-contained breathing apparatus and use of the
complete suits. Assistants must be prepared to:

Carry out emergency rescue if necessary.

Assist the wearers into the breathing apparatus and the
suits.

Decontaminate the outside of the suit before it is removed.

Assist the wearers in removing the suits (normal  and
emergency removals).

Thoroughly inspect the suit for holes, rips, malfunctioning
closures, cracked  masks or other deficiencies.

Wear a minimum of clothing beneath suit (cotton).

Use talcum powder as necessary.

Remove any extraneous or disposable clothing, boot covers,
or gloves.

Have assistant perform the following:

      Loosen and remove the steel-toe and shank boots.

      Open front of suit to allow access to SCBA regulator.
      (Leave  breathing hose attached as long as there is
      sufficient pressure.)

      Open suit  completely and lift the hood over the head
      of the wearer; rest it on top of the SCBA  tank.

Remove arms, one at a time, from suit. Once arms are
free, have assistant lift suit up and away from the SCBA
backpack, avoiding any contact between the outside surface
of the suit and the wearer's body, and lay the suit out flat
behind the wearer.  Leave internal gloves on.

While sitting, remove both legs from the suit.
hlthsflyeng
             3-18

-------
                           After suit is removed, remove internal gloves by rolling
                           them off the hand, and turning them inside out.

                           Proceed to the clean area and follow procedure for doffing
                           SCBA.

                           Remove internal clothing and thoroughly cleanse body.
A92-333.1                                3-19

-------
                                 CHAPTER 4

                     4.0 RESPIRATORY PROTECTION
                                4.1  OBJECTIVE
                   To provide basic information on the selection, use and
                   maintenance of respiratory protective devices so that they may be
                   used in a safe and effective manner.
                4.2  RECOGNITION OF RESPIRATORY HAZARDS
                   Respiratory hazards may be encountered during any field activity.
                   Respiratory protection is needed if personnel must enter any area
                   in which there may be either a deficiency of oxygen or a high
                   concentration of toxic chemicals in the air.  In such atmospheres,
                   life or health may depend  on using respiratory equipment which
                   can provide a supply of clean breathing air.

Hazard Locations   •     Spill scenes
                         Discharge or emission sites
                         Mines
                         Industrial plants
                         Hazardous waste sites
                         Confined spaces

General            •     Do not rely on workaday respiratory use policy.
Considerations      •     Assume the worst conditions.
                         Three basic categories of hazards

                               oxygen deficiency
                               aerosols
                               gases and vapors

Oxygen            •     Causes
Deficiency
                               displacement
                               oxidation
A92-333.1                               4-1

-------
                           Minor to fatal effects (see Table 4-1)
                           < 19.5% oxygen at sea level (OSHA)

Aerosols             •     Fine paniculate (solid or liquid) suspended in air
                           Physical classifications

                                  spray
                                  fume
                                  fog
                                  smoke
                                  smog

                           Physiological classification

                                  nuisance
                                  inert pulmonary reaction
                                  lung fibrosis
                                  irritation
                                  systemic poison
                                  allergen
                                  carcinogen

Gaseous             •     Chemical classification
Contaminants
                                  acidic
                                  alkaline
                                  organic
                                  organometallic
                                  hydrides
                                  inert

                           Physiological classification

                                  irritant
                                  asphyxiant
                                  anesthetic
                                  systemic poison
                                  allergen
                                  carcinogen
A92-333.1                                 4-2

-------
      TABLE 4-1. PHYSIOLOGICAL EFFECTS OF OXYGEN DEFICIENCY
Oxygen Volume at Sea Level (%)       Effects

12 to 16                       -Breathing volume and heart rate increase.
                              -Attention and coordination impaired.

10 to 14                       -Loss of peripheral vision.
                              -Poor coordination.
                              -Rapid fatigue with exertion.
                              -Emotional upsets and faulty judgment.
                              -Respiration disturbed.

6 to 10                        -Nausea and vomiting.
                              -Unable to move freely.
                              -Possible loss  of consciousness.

Below 6                       -Convulsions
                              -Gasping respiration immediately prior to cessation of
                              breathing which is followed quickly by death.
A92-333.1                               4-3

-------
                           4.3  TYPES OF RESPIRATORS
Basic Types


Facepieces

Tight-fitting



Loose-fitting
Air-Purifying
Respirators
Precautions
Air-purifying
Atmosphere-supplying

Tight-fitting or loose-fitting

Quarter mask
Half mask
Full facepiece

Hoods
Helmets
Suits
Blouses

Consist of face-piece and air-purifying device.

Can remove specific airborne contaminants by

       filtration;
       absorption;
       adsorption; or
       chemical reaction.

Are approved for use only in atmospheres of certain
concentrations of chemicals (see cartridges or canisters).

Usually operate in negative-pressure mode (exception:
powered air-purifying respirators).

Cartridges in two-cartridge respirators must be of same type.

Combination cartridges may be used for protection against
more than one type of chemical.

Use air-purifying respirators when:

       identify and concentration of contaminant are known;
       oxygen in  air is at least 19.5%;
       contaminant has adequate warning properties;
       approved canisters or cartridges for the contaminant
       and concentration are available;
A92-333.1
             4-4

-------
Styles

Atmosphere
Supplying
Respirators
SCBA
SAR
      the Immediately Dangerous to Life or Health
      (IDLH) concentration is not exceeded.

See Table 4-2 for advantages/disadvantages of air-purifying
respirators.

See Table 4-3 for styles of respirators.

Consist of facepiece (loose or tight-fitting) and device which
provides clean respirable air.

Two basic types:

      self-contained breathing apparatus (SCBA)
      supplied air respirator (SAR)

Carried by wearer
Consists of:

      facepiece
      hose
      regulator
      air source

Protects against most levels and types of contaminants.

Duration of use limited by amount of air carried and
breathing rate.

Increases likelihood of heat stress and fatigue due to weight.

Impairs movement.

See Table 4-4 for advantages/disadvantages of SCBAs.

Also known as air-line respirators.

Supply air to facepiece via a supply line from a stationary
source.

Source may  be onsite compressor or compressed air
cylinders.

Available in positive- and negative-pressure modes.
A92-333.1
             4-5

-------
  TABLE 4-2.  RELATIVE ADVANTAGES AND DISADVANTAGES OF AIR-
                 PURIFYING RESPIRATORS
     Type of Respirator
 Advantages
       Disadvantages
  Air-Purifying
  Air-Purifying Respirator
  (including powered air-
  purifying respirators
  (PAPRs)
Enhanced mobility

Lighter in weight than
an SCBA Generally
weighs 2 pounds (1 kg)
or less (except for
PAPRs).
Cannot be used in IDLH or oxygen-
deficient atmospheres (less than 19.5
percent oxygen at sea level).

Limited duration of protection. May be
hard to gauge safe operating time in
field conditions.

Only protects against specific chemicals
and up to specific concentrations.

Use requires monitoring of contaminant
and oxygen levels.

Can only be used (1) against gas and
vapor contaminants with adequate
warning properties, or (2) for specific
gases or vapors provided that the service
life is known and a safety factor is
applied, or if the unit has an ESLI (end-
of-service-life indicator)
Source:  NIOSH/OSHA/USCG/EPA:  Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities, 1985.
TABLE 4-3. RESPIRATOR STYLES
Facepiece
Half-mask
Full-face mask
Helmet
Air-Purifying Unit
Twin
Cartridges
X
X

PAPR at Waist
X
X
X
Chin-mounted
Canister

X

Harness-
mounted
Canister
-
X

A92-333.1
             4-6

-------
TABLE 4-4. RELATIVE ADVANTAGES AND DISADVANTAGES OF
              ATMOSPHERE-SUPPLYING RESPIRATORY PROTECTIVE
              EQUIPMENT
Type of Respirator
Advantages
Disadvantages
Self-Contained Breathing
Apparatus (SCBA)
Positive Pressure Supplied-Air
Respirator (SAR) (also called
air-line respirator)
   Provides the highest
   available level of
   protection against
   airborne contaminants
   and oxygen deficiency.

   Provides the highest
   available level of
   protection under
   strenuous work
   conditions.

   Enables longer work
   periods than an SCBA.

   Less bulky and heavy
   than a SCBA. SAR
   equipment weighs less
   than 5 pounds (or
   around 15 pounds if
   escape SCBA
   protection is included).

   Protects against most
   airborne contaminants.
•  Bulky, heavy (up to 35 pounds).

•  Finite air supply limits work duration.

•  May impair movement in confined
   spaces.
•  Not approved for use in atmospheres
   immediately dangerous to life or
   health (IDLH) or in oxygen-deficient
   atmospheres unless equipped with an
   emergency egress unit such as an
   escape-only SCBA that can provide
   immediate emergency respiratory
   protection in case of air-line failure.

•  Impairs mobility.

•  MSHA/NIOSH certification limits
   hose length to 300 feet (90 meters).

•  As the length of the hose is
   increased, the minimum approved air
   flow may not be delivered at the
   facepiece

•  Air line is vulnerable to damage,
   chemical contamination, and
   degradation. Decontamination of
   hoses may be difficult.

•  Worker must retrace steps to leave
   work area.

•  Requires supervision/monitoring of
   the air supply line.
Source:  NIOSH/OSHA/USCG/EPA
Waste Site Activities, 1985.
     Occupational Safety and Health Guidance Manual for Hazardous
A92-333.1
               4-7

-------
Precautions
Combined
SCBA/SARs
Respirator
Certification
Limitations
Assigned
Protection Factor
(APF)
Should not be used in IDLH atmospheres unless equipped
with escape SCBA.

Use of compressors limited by quality of ambient air.

Couplings must be incompatible with outlets of other gas
systems used onsite.

See Table 4-4 for advantages/disadvantages of atmosphere-
supplying respirators.

Can operate in either SCBA or SAR mode.
      SCBA - entry and exit.
      SAR - extended work in contaminated area

NIOSH/MSHA

Respirators and components are certified as a unit;
interchanging parts voids certification.

Air-purifying filters and cartridges approved for only certain
materials and conditions of use (organic vapor cartridge -
adequate warning properties and at least 19.5% O2).

Each type of respirator (half-mask, PAPR, etc.) is assigned
an APF.

APF = Outside Concentration/Inside Concentration.

Example - respirator with APF of 100

If outside concentration = 200 ppm, what is concentration
inside facepiece?

100 = 200 ppm/x ppm

x = 2 ppm

Can use APF and PEL or TLV to determine maximum
concentration of contaminant in which respirator can be
used.

Maximum concentration (ppm)  = APF x Allowable
Exposure Limit
A92-333.1
            4-8

-------
                         Example - Air-purifying, half-mask respirator: APF

                         Contaminant:  TLV = 20 ppm

                         Maximum Concentration = APF x TLV
                         x = 10 x 20
                         x = 200 ppm

                         See Table 4-5 for assigned protection factors.
                                                10.
                         4.4  RESPIRATOR SELECTION
                   Respirator selection is a complex process that should be performed
                   only by a trained industrial hygienist familiar with the actual work
                   environment and job tasks to be performed.
General
Considerations
Contaminant
Considerations
Respiratory
Hazards
Oxygen Deficiency
Flammable
Atmospheres

Toxic
Atmospheres
Nature of hazardous operation, process or condition
Contaminant, type of hazard, concentration, effects on body
Activities to be conducted
Time protection needed
Escape time
Available respiratory protection equipment
Service life of cartridges/canisters

Physical, chemical, toxicological properties
Odor threshold
REL, TLV, PEL
EDLH concentration
Eye irritation potential

Oxygen deficiency
Flammable atmosphere
Toxic atmospheres

SCBA/pressure-demand
SAR/auxiliary SCBA

General Policy:  do not enter if > 25 % of LEL.
SCBA/pressure-demand

DDLH - SCBA/pressure-demand
Above PELs but below IDLH - APR or SAR
Below PEL - none required
A92-333.1
             4-9

-------
TABLE 4-5. RESPIRATOR PROTECTION FACTORS
Assigned
Protection
Factor
10
25
50
1000
2000
10,000
Type of
Respirator
APR/half-
mask
APR/full-face
SAR/half-
mask/negative
PAPR/hood or
helmet
SAR/hood or
helmet/
continuous
flow
APR/full-face
PAPR/tight-
fitting
SAR/full-face/
negative
SAR/tight-
fitting/
continuous
flow
SCBA/full-
face/negative
SAR/half-
mask/positive
SAR/full-
face/positive
SCBA/full-
face/
positive
SCBA/full-
face/
positive/
auxiliary
positive
Contaminant
Particulate
X
X (any type)

X
X
X (HEPA)
X (HEPA)
X

X
X
X
X
X
Gas/Vapor
X

X
X
X
X
X
X
X
X
X
X
X
X
Combination
X
X (any type
paniculate
filter)
X
X

X (HEPA)
X (HEPA)
X
X
X
X
X
X
X
A92-333.1
4-10

-------
                              4.5 RESPIRATOR USE
Respirator Policy
Respirator
Program
Requirements
Provide appropriate respiratory protection devices for
agency employees.

Require use of devices when necessary to protect health:

      high potential for sudden release, or actual release of
      toxic gases/vapors;

      hazardous environments or locations (spill sites);

      confined spaces;

      engineering controls not feasible.

Allow employees to wear respiratory protection even when
concentrations are not expected to harm health and others
are not affected.

Keep hazardous conditions under surveillance.

Keep employee exposure or stress at safe levels.

Require standby personnel at IDLH atmospheres.

Require written Standard Operation Procedures (SOPs) for
selection and use of respiratory protective equipment.

Written program  (SOPs)
Respirator selection
Training
Respirator assignment
Cleaning
Storage
Inspection and maintenance
Surveillance
Program evaluation
Physical examination
A92-333.1
             4-11

-------
                         4.6 SPECIAL CONSIDERATIONS
                           Facial hair
                           Eye glasses
                           Contact lenses
                           Facial deformities
                           Communication
                          4.7  RESPIRATOR FIT TESTING
Fit Checks
                           Required for negative pressure air-purifying respirators.

Varieties             •      Two types:

                                 qualitative
                                 quantitative

                           See Table 4-6 for  advantages/disadvantages of qualitative
                           and quantitative fit testing.

                           Negative Pressure Test - tests exhalation valve and facepiece
                           seals.

                           Positive Pressure Test - tests inhalation valves and facepiece
                           seals.

                           Determine sensitivity to challenge material:

                                 banana oil  (isoamyl acetate)
                                 saccharin
                                 irritant smoke (stannic chloride)

                           Select respirator.

                           Conduct positive/negative fit check.

                           Enter test chamber.

                           Introduce challenge material.
Qualitative Fit
Testing
A92-333.1
                                       4-12

-------
        TABLE 4-6. ADVANTAGES AND DISADVANTAGES OF
                   QUALITATIVE AND QUANTITATIVE FIT TESTING
         Fit Test
       Advantages
      Disadvantages
  Qualitative
Fast
Inexpensive
Simple
Easily performed in the
field
Relies on wearer's subjective
response (may not be
reliable).
  Quantitative
Does not rely on wearer's
subjective response
(Is recommended when the
respirator is used in highly
toxic atmospheres or those
immediately dangerous to
life and health).
Requires qualified personnel
and equipment.

Testing cannot be done on
the respirator which will be
used.
A92-333.1
           4-13

-------
                     •     Perform test exercises (minimum of one minute each):

                                 breathe normally
                                 breathe deeply
                                 turn head side to side
                                 nod head up and down
                                 talk aloud several minutes
                                 jog in place
                                 breathe normally
                   M
                     •     If challenge material is not detected, subject has passed test
                           (PF = 10).

Quantitative Fit      •     Conduct qualitative fit test.
Testing
                           Follow instructions for quantitative fit testing equipment
                           used (fit test chamber, "Portacount").

                           Perform test exercises.

                           Determine fit factor.
A92-333.1                                 4-14

-------
Ill

-------
          FUNDAMENTALS OF




ENVIRONMENTAL COMPLIANCE INSPECTIONS

-------
                           TABLE OF CONTENTS

Chapter                                                                Page

1.0    INTRODUCTION TO ENVIRONMENTAL COMPLIANCE	   1-1
      1.1 Course Objectives	   1-1
      1.2 Compliance Monitoring	   1-1
      1.3 Motivation for Compliance 	   1-2
      1.4 The Inspector's Role	   1-2

2.0    INSPECTION PLANNING AND PREPARATION	   2-1
      2.1 Responsibilities of the Inspection Team	   2-1
      2.2 Reviewing Available Information	   2-1
      2.3 Preparing the Inspection Plan  	   2-2
      2.4 Preinspection Checklist	   2-3

3.0    ENTRY AND OPENING CONFERENCE	   3-1
      3.1 Key Elements of Entry 	   3-1
      3.2 Approaching the Facility	   3-1
      3.3 Entry Procedures  	   3-2
      3.4 Opening Conference	   3-2
      3.5 Amending the Inspection Plan	   3-3

4.0    INFORMATION GATHERING AND DOCUMENTATION  	   4-1
      4.1 Types of Information and Documentation  	   4-1
      4.2 Documenting Information	   4-1
      4.3 Techniques for Improving Information Gathering Skills	   4-2
      4.4 Records Inspection	   4-3
      4.5 Physical Sampling	t	   4-5
      4.6 Interviews	'	  4-14
      4.7 Observations and Illustrations	  4-17
      4.8 Exit Interview	  4-18
      4.9 Exit Observations/Activities  	  4-19

5.0    POST-INSPECTION ACTIVITIES  	   5-1
      5.1 The Inspection Report 	   5-1
                                  Figures

Number                                                                Page

4-1.   Sampling from a high-negative-pressure duct 	4-11

-------
                                CHAPTER 1

       1.0 INTRODUCTION TO ENVIRONMENTAL COMPLIANCE




                          1.1 COURSE OBJECTIVES
                  This section of the SEDESOL inspector's course provides a brief
                  overview of the course Fundamentals of Environmental Compliance
                  Inspections that EPA uses in training its new inspectors.  It is hoped
                  that you will 1) gain an understanding of the policies, procedures
                  and techniques an EPA inspector is required to follow and 2) find
                  the information provided to be useful in conducting your own
                  environmental compliance inspections as well.

            Note: All the following information represents EPA, not SEDESOL policy.
                       1.2  COMPLIANCE MONITORING


Purpose of        To ensure that environmental requirements are being
Inspections        implemented effectively, inspections are conducted to:

                        Assess compliance status and document violations for
                        enforcement action.

                        Provide oversight of inspection programs carried out by other
                        agencies such as state jurisdictions.

                  •     Gather data as part of an area/industry-wide inspection plan
                        to assess the need for additional controls.

                        Promote voluntary compliance.

                        Establish an enforcement presence to promote compliance.

                        Support the permit issuance process.
A92-333.2                              1-1

-------
                      L3  MOTIVATION FOR COMPLIANCE
Motivating
Factors
Natural
Disincentives
Role of
Enforcement

Credible
Enforcement
Presence
Societal/moral factors
Short-run economic factors
Long-run economic factors

Individual property rights
Economic advantages of noncompliance
Fear of change
Expediency
Lack of knowledge on how to comply or where to get that
knowledge

Fear of detection
Assurance of fairness

Likelihood of detection
Serious consequences of detection
Swift and sure response
Fair and consistent response
                          1.4  THE INSPECTOR'S ROLE
                   The inspector plays a crucial role in motivating companies to comply
                   with environmental regulations, thereby protecting the people who
                   might otherwise be exposed to toxic chemicals and other hazardous
                   materials. The more effective the inspector can be, the higher the
                   rates of compliance will be. Higher rates of compliance mean lower
                   risks to human  health and the environment. If an inspector does
                   not find and properly document a violation, there can be no
                   enforcement.

                   Inspectors must master both the "science" and the "art" of
                   inspections.  You need  not only a thorough understanding of the
                   technical aspects of the job  - you also need to learn to ask the right
                   questions, follow the paper trails, and check out inconsistencies.
A92-333.2
              1-2

-------
                                CHAPTER 2

           2.0  INSPECTION PLANNING AND PREPARATION


                  Planning and preparation are essential to:

                        Focus the inspection on the most important issues.

                        Make the most efficient and effective use of time on site.

                        Ensure that equipment will be available when needed.

                        Ensure that proper procedures are followed.



              2.1  RESPONSIBILITIES OF THE INSPECTION TEAM
Inspector          Effective inspections begin with careful planning that includes:
Responsibilities
                  •     Reviewing available information on the facility, and

                        Preparing an inspection plan.
                 22 REVIEWING AVAILABLE INFORMATION


                  A review of available information will enable inspectors to:

                        Become familiar with the facility (personnel, size,
                        operations);

                        Learn about findings from previous inspections, including
                        violations;

                        Avoid requesting previously submitted information; and

                        Clarify legal and technical issues before entry.
A92-333.2                              2-1

-------
Available          The following information might be available:
Information
                          Facility location, geographical features;
                          Names of officials or representatives;
                          Descriptions of recordkeeping/filing systems;
                          Previous entry problems;
                          Safety requirements;
                          Special exemptions from requirements;
                          Notifications;
                          Prior inspection records;
                          Compliance problems/enforcement actions;
                          Complaints from citizens about the facility; and
                          Correspondence.
                    2.3  PREPARING THE INSPECTION PLAN
                   An inspection plan is an organized approach to guide the conduct of
                   the inspection.  It:

                          States the reason for inspection;
                          Defines the scope of the inspection;
                          Specifies procedures;
                          Defines tasks; and
                          Identifies equipment and materials needed.

Inspection         An inspection plan should include:
Plan Elements
                          Objectives and scope;
                          Inspection activities and field techniques;
                          Quality Assurance Project Plan, including a sampling plan;
                          Safety plan; and
                          Administrative requirements.

                   Use the preinspection checklist that follows this section or develop
                   one of your own to ensure that you have completed all planning
                   tasks for each inspection.
A92-333.2                                2-2

-------
     2.4 PREINSPECTION CHECKLIST
          GENERAL EQUIPMENT

      Camera
      Film and flash equipment
      Pocket calculator
      Tape measure
      Clipboard
      Waterproof pens, pencils, and markers
      Locking briefcase
      "Confidential Business Information" stamp
      Stamp pad
      Pre-addressed envelopes
      Plastic covers
      Plain envelopes
      Polyethylene bags
      Disposable towels or rags
      Flashlight and batteries
      Pocket knife
      First Aid Manual
      Kneeboard
      Knapsack
      Rope

         SAMPLING EQUIPMENT

Sampling equipment will vary by program and media. Examples of
typical sampling equipment follow.

      Crescent wrench, bung opener
      Siphoning equipment
      Weighted bottle sampler
      Bottom sediment sampler
      Liquid waste samplers (e.g., glass samplers)
      Auger, trowel, or core sampler
      Scoop sampler
      Sample bottles/containers (certified clean bottles with teflon-
      lined lids)
      Labeling tags, tape
      Storage and shipping containers with lids
      Ice chest
      Container for contaminated material

                    2-3

-------
Hazard labels for shipping samples
Ambient air monitor
Field document records
Vermiculite or equivalent packing
Thermometer
Colorimetric gas detection tubes
pH equipment
Explosimeter
Oxygen meter

     SAFETY EQUIPMENT

Safety glasses or goggles
Face shield
Ear plugs
Rubber-soled, metal-toed, non-skid shoes
Liquid-proof gloves (disposable, if possible)
Coveralls, long-sleeved
Long rubber apron
Hard hat
Plastic shoe covers,  disposable
Respirators and cartridges
Self-contained breathing apparatus
Drinking water - plain and salted (1 tsp. salt/5 liters H2O)

  EMERGENCY EQUIPMENT

Substance-specific first aid information
Emergency telephone numbers
First-aid kit with eyewash
Fire extinguisher
Soap, waterless hand cleaner, and towels
Supply of clean water for washing
              2-4

-------
                                CHAPTERS

                3.0 ENTRY AND OPENING CONFERENCE
                        3.1 KEY ELEMENTS OF ENTRY
                  Inspectors should:
                        Follow correct administrative procedures and requirements
                        failure to do so can jeopardize subsequent enforcement
                        actions.

                        Check planned inspection activities against the actual
                        situation at the site and make adjustments as needed.
                      3.2  APPROACHING THE FACILITY


                  The investigation begins before you reach the front door of the
                  facility. As you approach the facility, look for signs of potential
                  violations. These can include:

                        Dead or unhealthy vegetation

                        Unusual emissions from stacks

                        Ponds or lagoons on the property that appear to contain oily
                        or discolored water or sludges

                        Leaking containers

                        Uncovered piles of waste

                        Open burning or burn pits

                        Oil or discoloration of water in streams or rivers that
                        surround the property
A92-333.2                              3-1

-------
      Strong or noxious odors

      Dust or debris on haul roads

•     Deposits on vehicles

Be prepared to amend your plan to focus on these potential
problems.
         3.3 ENTRY PROCEDURES


Inspectors should follow proper procedures when entering a facility
so that no questions or challenges can be raised regarding the
legality of the inspection.

      Arrive during normal working hours.

      Use the main entrance.

•     Ask to see the owner or other authorized facility
      representative.

      Present your credentials.

      Explain the inspection authority.
        3.4  OPENING CONFERENCE
The inspector should use the opening conference to inform the
facility representative of planned activities, to gain an understanding
of the facility's operations and practices, and to address logistical
arrangements. Inspectors should:

      Explain the anticipated inspection activities in general terms.

      Identify activities and processes that occur at the site and
      their environmental implications.
                     3-2

-------
      Determine what environmental programs and controls are in
      place (e.g., air monitoring, employee training, equipment
      maintenance) and what records are available.

      Verify the applicability of regulations or requirements.

      Determine who the responsible parties are for the site.
  3.5 AMENDING THE INSPECTION PLAN
Information gathered as you approach the site and during the
opening conference may lead to changes in the inspection plan.  Be
prepared to add or change interviewees, sampling points, and record
reviews.
                    3-3

-------
                                CHAPTER 4
       4.0 INFORMATION GATHERING AND DOCUMENTATION
             4.1 TYPES OF INFORMATION AND DOCUMENTATION
Types of
Information
There are four types of information and documentation:

      Testimonial (what you are told)
      Real (physical samples you gather)
      Documentary (written records you collect or copy)
      Demonstrative (photographs and drawings you make)
                     4.2 DOCUMENTING INFORMATION
Field Logbook
An inspector's field notes/logbook:

      Provides the foundation for preparing reports.

      Is useful in refreshing memory.

      Should contain information which is objective, factual, and
      free of personal feelings or conclusions.

      Should be bound and consecutively numbered.

      Should list documents taken or prepared, photos taken,
      unusual conditions, problems, interview notes, general
      information, incidents, and administrative data.

Inspectors should:

      Maintain one logbook per inspection.
      Use waterproof ink.
      Write legibly.
      Draw a line through incorrect entries and initial them.
      Make a diagonal line at the conclusion of an entry and initial
      it.
A92-333.2
                   4-1

-------
    4.3  TECHNIQUES FOR IMPROVING INFORMATION GATHERING SKILLS


                  Detecting hints of potential violations will help you focus your
                  inspection on the most important issues.

                  In interviews, listen for:

                         Reports of knowing violations, such as night dumping or
                         shutting down of pollution control equipment.

                         Reports of accidental releases, such as spills.

                         Complaints about odors, skin problems, or other health
                         effects that workers believe might be related to contact with
                         hazardous or toxic materials in the workplace.

                         Stories or information that conflict with written records or
                         reports from other workers.

                  During the inspection, look (and smell) for:

                         Excess or uncontrolled emissions.

                         Excess odors.

                         Spills, leaky containers, and generally poor housekeeping.

                         Inoperable equipment or equipment in a gross state of
                         disrepair.

                         Equipment that has been damaged from fire or explosion.
A92-333.2                                4-2

-------
                           4.4 RECORDS INSPECTION
                   The two objectives of inspecting facility records are to:

                          Determine whether required records are being maintained;
                          and

                          Use facility records as a substantiation of compliance or
                          noncompliance.

Review             The inspector should note the  kinds of records examined and why.
Considerations     When reviewing records, consider these questions:

                          How complete is the information?

                          What are alternative sources for the same information?

                          Has the facility tried honestly to meet recordkeeping
                          requirements?

                          Are there discrepancies or suspicious consistencies between
                          current reports and field data or past reports?

                          Are the required reports complete,  accurate, and of good
                          quality?

                          Do the records comply with retention requirements?

                          Does information in the records seem consistent with first-
                          hand observations?

Targeting and      As part of determining exactly what records an inspector needs to
Locating Records   examine, he or she should:

                          List the kinds of records needed for compliance and their
                          retention requirements.

                          Become familiar with the facility's recordkeeping system.

                          Establish priorities for the  material  to be reviewed.

                          Request that facility personnel identify pertinent files and
                          sources.

A92-333.2                                 4-3

-------
                         Check back-up and cross-filing systems that might make
                         retrieval more efficient.

Records Sampling  Time constraints often prevent inspectors from examining all records
                   at a facility. Therefore, the inspector reviews only a sample of these
                   records.  To increase the likelihood that problems will be detected,
                   it is important that the sample is "representative" of the entire
                   universe of records, just as it is important that a physical sample is
                   representative of air emissions or water effluent.

                   The key point in sampling is to think systematically. If the inspector
                   suspects a problem, the sample should be drawn from records that
                   are likely to document the problem.  The sample could focus on a
                   particular time period, a specific set of employees, or specific
                   activities.

                   Sampling methods include:

                         Random sampling - each record  has an equal chance of
                         being included in the sample.

                         Interval sampling -- every fifth, tenth, etc. record is selected
                         based on a random starting point.

                         Stratified sampling - breaks the entire population into
                         categories based on relevant characteristics and applies
                         random or interval methods within categories. A larger
                         sample can be drawn from categories of concern.

                         Block sampling - selects records  only within a specific
                         category.
A92-333.2                                 4-4

-------
                            4.5 PHYSICAL SAMPLING
Why Take          Physical samples are taken during a compliance inspection to
Physical Samples   substantiate that a violation occurred. Samples provide quantitative
                   data to assess the nature, level, and extent of pollution or
                   contamination that result from a violation. Physical samples may
                   include the results of in-situ monitoring, or later analysis of samples
                   of soil, water, air, wastes, sludges, and residues from a site.
                   Sampling  may even include biological sampling to establish whether
                   or not contaminants have damaged or have the potential to damage
                   the environment or human health.

Developing A Plan  In order to conduct sampling  that supports the goals of an
                   environmental inspection, it is important to develop a plan that will
                   guide the  selection of appropriate sampling.methods.  The Plan
                   should:

                          Establish and communicate sampling objectives and data
                          quality requirements;

                          Identify levels of discharge that will be  within compliance;

                          Make realistic projections of cost and time required for
                          sampling;

                          Establish comprehensive sampling and quality assurance
                          protocols; and

                          Identify and characterize broader site conditions to support
                          sampling data.
What Information
Can Be Used for
Planning?
SEDESOL Inspectors are responsible for monitoring compliance for
all potential sources of pollutants. An examination of any available
records about a site is a useful way to begin planning an inspection.
Many of the sites you will inspect may already be permitted. If this
is the case, the office with jurisdiction over the facility might
maintain a file on the permits that contains information about the
types and amounts of discharges that will be found at a site.  It may
also contain reports and information on previous inspections.  Your
job,  here, will be  to assess whether or not a site has come into
compliance or has maintained compliance.

Many of the sites that you will inspect may not have permits or
applications for permits on file.  These sites may have been brought
                                        4-5

-------
                   to your attention by citizen complaints, news reports, police reports,
                   or observations collected in a visit to a nearby site.  You may have
                   little information to use in developing a plan but you will need to
                   identify a best approach before you go into the site  to conduct an
                   effective compliance inspection.

Developing A       A quality assurance project plan (QAPP) should be developed for
Project Plan        each sampling inspection. This plan details how the inspection will
                   be conducted and what the objectives for the inspection are.  It
                   should include the following:

                          A description of the site and project;

                          Identification of the data quality objectives for the study;

                          A description  of the sampling to be done and justification for
                          selection of sample sites;

                          A description of quality assurance and quality control
                          methods and requirements;

                          A description of the analysis and sampling plans and standard
                          operating procedures (SOPs);

                          A description of sample preservation and chain of custody
                          requirements;

                          A description of documentation required to meet the
                          administrative and technical requirements;

                          A project safety plan; and

                          Other relevant information.

                   The description of the site should include any available maps that
                   will be useful in identifying sampling locations  and points of
                   reference.  Even for unpermitted and undocumented sites, it may be
                   useful to include the best available map so that probable points of
                   discharge, wells, and other surface features can be used to identify
                   probable sampling  points. Samples and/or appropriate on-site
                   monitoring instrument analysis should be taken from every
                   observable aqueous discharge. Samples may also be taken  from
                   process reactors when necessary to identify or confirm the chemical
                   processes occurring at a facility.  Samples from pools of water near
                   waste drums and containers may reveal leakage from these
                   containers.
                                        4-6

-------
                    Because many of the facilities that you will visit are not yet
                    permitted, you will often need to make decisions in the field on
                    what should be sampled. Let your eyes, nose, and ears be your
                    guide! The presence of unusual solids, scums, and corrosion near a
                    discharge outlet, pipes, or valves may be a good indicator that a
                    toxic or hazardous material has escaped into the environment. You
                    may want to carefully collect samples of these residues for analysis.
                    Samples from nearby wells may also reveal the presence of
                    contaminants in groundwater.

                    For air quality, you may want to monitor, or collect samples from
                    stacks, but you may also want to use monitoring equipment to check
                    around tank seams, pipes, valves, and tank openings to look for
                    fugitive emissions.

                    You may also want to take samples of soil surrounding process
                    tanks or piping if there is any indication of spillage. Similarly, soil
                    samples from storage depots where drums or containers of suspected
                    wastes are kept may  confirm  the nature and extent of any spills.
                    Soil samples can be taken from the surface or from deeper in the
                    ground using coring or drilling devices.

                    Data quality objectives (DQOs) should be identified as part of the
                    QAPP, prior to the actual inspection.  DQOs are specifications for
                    what is required to establish a statistically sound characterization of
                    conditions at the site. DQOs will identify where and how many
                    samples will be taken to establish a representative picture of site
                    conditions. The DQO statements will also establish the statistical
                    requirements for detectibility, precision and accuracy in analysis or
                    on-site monitoring and identify what will be required to achieve
                    completeness in sampling.  These short definitions may help you
                    understand these concepts associated with chemical analysis:

                          Detectibility - the lowest concentration of a substance that
                          can be measured as being present

                          Accuracy - the degree of agreement of a measured value and
                          a true value for a substance

                          Precision -- the degree of agreement between repeated
                          measurements of the same sample

How Do DQOs      It has been said that  "the ability to correctly determine the
Help?               difference between a bull and a mouse at least 95% of the time" is a
                    data quality objective for selecting the right mouse trap. While this
                    is a very simplified picture of what DQOs do, it does illustrate how
                    important it is to identify what you will need to do the job correctly.
                    A better example of how to select DQO's might be found in

A92-333.2                                4-7

-------
                   selecting methods of chemical analysis that will be sensitive enough
                   to determine if the concentrations of a contaminant in a sample are
                   in violation or not.

                   When and how often you sample may also be very important and
                   the QAPP should identify the timing and frequency of samples. An
                   example of this is often seen when you are required to monitor
                   discharges that are part of specific industrial- process that occur only
                   at specific times.  Unless you have a system that monitors
                   continuously over a period of time, you may  miss the discharge
                   violation.

QA/QC            There are a number of steps an inspector should take to provide
                   information about the quality of sampling and analysis.  The
                   laboratory should provide you with information from analysis that
                   will allow you to assess whether or not the analytical quality
                   objectives were met, but you must also be prepared to assess the
                   quality of on-site monitoring and sample collection. The QAPP
                   should also include protocols and special samples (Quality
                   Assurance or QA Samples) that will help you assess data quality.
                   These steps should include:

                         Exact protocols on daily calibration of field monitoring
                         equipment such  as pH meters, flow meters, UV gas detectors,
                         and conductivity meters.  Manufacturers' manuals should be
                         provided to ensure correct calibration.

                         Protocols for quality control checks during operation of field
                         and laboratory instruments. Frequent  use of independent
                         quality control check standard materials (QCCS)
                         (independent of calibration standards) will be necessary.

                         Protocols for collection of QA samples including field
                         duplicate samples to measure field variability; and field blank
                         samples - samples that are laboratory pure water (deionized
                         and distilled) but handled just as any other sample - are used
                         to check for cross-contamination between samples.

                         Protocols for cleaning of equipment and safe
                         decontamination of field  equipment to avoid cross-
                         contamination of samples or health risks to inspectors and
                         technicians.

                         Protocols for laboratory QC sample analysis for assessment of
                         accuracy, precision, and detectibility.

                         Protocols to identify the number and types of sample
                         containers to be used and the volumes of samples and
                         preservatives required.
                                        4-8

-------
Plan The Logistics  Arrangements for travel and secure shipment of samples should be
                    made ahead of time.  Make sure that the materials you will require
                    are collected, packed and shipped (when necessary) to a place
                    where they will be secure until you arrive. Checklists are often used
                    to verify that you will take everything you need. Use a field log
                    book with numbered sequential pages for maintaining observations
                    taken during your inspection. Make all entries directly in this book.
                    Do not transcribe them from other papers but take this book into
                    the field with you.  Do not obliterate entries but place a single line
                    through incorrect entries, make corrections and initial corrections in
                    the margin of the page.

                    If you are taking any monitoring instruments to the inspection site,
                    such as pH meters, flow meters, gas detectors, etc. check them out
                    before you pack them to make sure they work and can be calibrated
                    for use.  Carry fresh  spare batteries for instruments that are battery-
                    powered as well as some alcohol and an abrasive cloth to keep
                    battery terminals clean.

                    Carry an ample supply of clean laboratory water for use as field
                    blanks or to make  buffers and other reagents in the field. If
                    possible, make up standards for calibration fresh for each inspection
                    and refrigerate them while you are in transit.

                    It will be important to coordinate your activities with  the laboratory
                    that will analyze the samples. Check requirements  for sample
                    volumes and preservation methods with the laboratory and give
                    them advance warning about when and how many samples will
                    arrive at the laboratory.  Make sure someone will be there to
                    receive them so that  the samples will be maintained in a chain of
                    custody.

Identifying          Inspectors should rely on the QAPP and the Sampling Plan  in that
Sampling Points     document to identify sites where samples are to be  taken. In
                    permitted sites, you may find conditions that are not in agreement
                    with what is stated in the QAPP and you will have to  use your
                    discretion about drawing additional samples based upon your
                    interview and what your eyes, ears, and nose tell you.   Monitoring
                    instruments that you  carry may extend the sensitivity of those senses
                    but your most important tool will be your judgment. Remember
                    that deviations from your Sampling Plan and QAPP will need to be
                    documented in your field notes and  that you will need to amend
                   your QAPP when you return to  your office to provide justification
                   for  the change in the inspection and guidance to the next inspector
                   who visits that site.
                                        4-9

-------
                  Many inspectors find it useful to photograph each sample location at
                  the time the sample is taken or monitoring is performed to capture
                  a visual image of conditions. If you can photograph the sampling,
                  remember to write the frame number in your field notes.

Using Monitoring  If you are using monitoring instruments, you will need to check their
Equipment        operation and calibrate them at the beginning of each day.  Follow
                  the manufacturer's instructions regarding recalibration and use of
                  quality control check standards.

                  Record all instrument readings in your log book along with date,
                  time, and specific sample site location (for example - "air vent near
                  process tank on northwest corner/second floor of building #2- see
                  indicator on map"). Also indicate in your field notes if other
                  samples were also collected at the site.

Collecting Samples Samples or monitoring readings (when appropriate) should be
                  collected at all observed discharges for water and air effluents when
                  discharges are occurring. Locations that show discoloration, scums,
                  slimes, deposits, corrosion,  and other indications of chemically
                  contaminated discharges should have the highest priority. Similarly,
                  air monitoring may be appropriate where discharges are apparent,
                  or where odors, visible vapors, air flow noises, or abrupt heat
                  differences indicate stack or fugitive emissions. Permanent
                  collection devices, such as bag or precipitator air cleaning devices
                  may be sampled as can process reactors  if it  is  desirable to
                  characterize and quantify ingredient/process/waste/ product streams
                  for the application  of mass-balance approaches to determining
                  wastes.

                  Water samples may be collected directly from flows by grab sample,
                  or by pump or collection bottle, taking precautions to rinse
                  collection devices and go from areas of lowest contamination levels
                  to high if possible to minimize sample cross-contamination.

                  Air samples are most often obtained using monitoring
                  instrumentation, or by the use of a pump and adsorbent system to
                  capture contaminants from an air stream (see Figure 4-1).

                  Solids such as soil can be scoop sampled, or  drilled,  or cored. Liquid
                  wastes  such as solvents or chemicals in barrels  are best sampled
                  using a dipper that is usually called a "thief.

                  AT ALL TIMES DURING SAMPLING, INSPECTORS SHOULD
                  KEEP THEIR SAFETY FOREMOST IN THEIR MIND.
                  INSPECTORS SHOULD NOT RISK THEIR LIVES OR
                  HEALTH TO COLLECT SAMPLES.
                                      4-10

-------
                   Sample volumes vary with the media to be analyzed and the
                   contaminants of interest.  Laboratories can advise you concerning
                   the types of containers that  should be used for specific sampling and
                   the volume or weight of sample to be collected.  Reference guides
                   such as the Water Pollution Control Federation (WPCF) Handbook
                   for Chemical Analysis of Freshwater can also give you guidance.
                                                 SANDING DISK

                                                   COPPER TUBE
                                                   RUBBER STOPPER
                                   -DUCT WALL
               Figure 4-1.  Sampling from a high-negative-pressure duct
QA Samples        Quality Assurance Samples from the field will account for about
                   10% of the total number of samples sent to the laboratory.  They
                   include field blank samples to identify background levels of
                   contamination encountered in sampling; field duplicates to identify
                   site variability; and split samples (where a sample is divided in half
                   and put into two separate containers in the field)  for estimating
                   variability introduced by sampling itself.

Preservation        Most samples will need to be preserved to stabilize the
                   contaminants in the sample against  thermal, chemical, or biological
                   decomposition. Some samples can be preserved chemically but
                   many will need to be refrigerated at 4 degrees Celsius for shipment
                   to the laboratory  to retard decomposition. It is  very important to
                   ship samples well chilled in the fastest possible way.  The
                   temperature of the samples upon arrival at the laboratory will also
                   need to be recorded.
                                       4-11

-------
Labels
Sealing
Chain of
Custody
 Samples taken in the field need to be labeled completely and
 correctly prior to shipping.  Every sample label should contain:

       a unique sample number;
       site name;
       date;
       time;
       analysis;
       preservative used; and
       inspector's name.

 The sample control number should be recorded in the field log book
 along with a description of the sample that includes sample location
 and type as well as the dates of sampling and shipping and
 conditions of shipping.  Later, you will confirm the sample's
 condition at the time of arrival at the laboratory and make that part
 of your log entry.

 Samples should be sealed with a protective band of tape that
 prevents seepage  that could contaminate the sample.  Sealing the
 sample in a plastic bag, or even two plastic bags, will help prevent
 contamination of other samples. Ice that is used to cool the samples
 in the cooler for shipping should also be bagged in plastic to
 minimize the risk of melt-water contaminating the samples.  At the
 laboratory, the bags and seals should be inspected by the technicians
 to confirm that no breakage, leakage, or tampering has occurred.

 Once the shipping container containing the samples is full,  and the
 shipping temperature of the samples  can be confirmed at 4 degrees
 C, die cooler should be closed, sealed with packing tape, and then
 sealed with a custody seal.  Transfer of the cooler  from inspector, to
 shipping agent, to laboratory clerk should be documented with
 signatures and dates  on a chain-of-custody  receipt  that travels with
 the samples. Upon arrival at the laboratory, the laboratory
 technician or clerk who receives the samples should examine the
 seal for tampering and certify it's integrity before opening the
 shipping cooler.  The technician should confirm the 4 degree C
 temperature in the cooler upon opening, and store the samples in a
secure, cold location, where access is regulated and documented.  In
this way sample integrity can be assured and documented to refute
any claim of tampering or mishandling that could compromise the
data. In general,  samples should arrive at the laboratory within a
day or two of collection to ensure adequate refrigeration, and
samples should be packed with an equivalent weight of ice  (5 liters
of samples needs 5 kilograms of ice) to ensure adequate
preservation in transit.
                                       4-12

-------
Confirm Condition  It is the inspector's responsibility to confirm that the samples arrived
of Samples on      safely and that all samples were intact and that refrigeration was
Arrival             adequate. To complete his records, the inspector should request the
                    chain of custody receipt form and seals be returned to him for
                    inclusion in the inspection file.
Evaluating the
Data
Laboratory and
Field Quality

Control Data
Quality Assurance
Maintaining
Records
Both quality control and quality assurance data need to be evaluated
before you can use the sample data with confidence. Here are some
things to look for.

       Confirm that all laboratory analyses support the "accuracy"
       data quality objective for each
       analysis parameter.

       Confirm that the laboratory has tested accuracy of analysis
       using either analysis of an independent audit material,
       recovery  of a "spike" of the analyte of concern added to a
       sample after original analysis, or in the case of analysis  for
       unknown organic materials,  that a surrogate organic
       compound of similar molecular weight and structure can be
       quantified accurately.

       Confirm that the laboratory has analyzed duplicates or splits
       of samples and that the results  are repeatable within the data
       quality objective for precision.

       Confirm that the laboratory has satisfactorily demonstrated
       the detection limit for the analytes of interest on a regular
       basis.

       Examine the results of field blank analysis and confirm  that
       field blanks  do not contain contaminant of interest in
       concentrations greater than 3 times higher than the
       instrument detection limit.

      Examine the results of field duplicate analysis to characterize
      field variability of the contaminant.

       Examine the results of field split analysis - variability should
      not exceed the specified data quality objective for precision.

      Examine sample results data for outlier values — data which
      lie far below or far above the mean and  standard deviation
      for the rest of the field sample  (don't include the blank)
      results. These data may be suspect. Applying a statistical
      test for outlier value (such as Grubbs outlier test) can assist
      you with this evaluation.

Original copies of laboratory reports, chain of custody documents,
calculation worksheets, and your field  notebook should be
maintained as part  of the inspection file.  These records should be
secured to avoid loss or tampering.
                                        4-13

-------
                                 4.6  INTERVIEWS
Planning the
Interview
Conducting and
Documenting
the Interview
Questioning
Techniques
As the first step in the interviewing process, planning the interview
should involve:

      Identifying the interviewees who could provide information to
      meet inspection objectives;

      Identifying the specific reason that a particular person is to
      be interviewed and information to be  obtained; and

      Scheduling the interview at a convenient time and place for
      the interviewee, if possible.

The initial contact between inspector and interviewee sets the tone.
The main points of the interview include:

      Asking the employee to explain his or her responsibilities as
      they relate to  the topics being reviewed  in the inspection;

      Asking specific and concrete questions to help answer the
      compliance questions raised in the inspection plan;

•     Rechecking after each phase of the interview to see that all
      the "unknowns" have been explored;

      Rearranging the information mentally into a logical order;
      and

      Summarizing the  interview to allow the  interviewee to correct
      any mistakes.

An inspector should always document an interview, either by taking
detailed notes, getting signed statements, or tape recording the
interview.

The basic questions used in interviewing are:

      What happened?
      When did it happen?
      Where did it happen?
      Why did it happen?
•     How did it happen?
      Who was involved?
                                       4-14

-------
Collecting
Written
Statements
Suggestions for improving interviews are:

      Ask questions that require narrative responses rather than
      "yes" or "no" answers. Yes/No questions should be used only
      when summarizing or verifying information that has already
      been given.

      Avoid leading or suggestive questions which might bias the
      interviewee's answers and detract from their objectivity.

      Avoid questions that ask for two separate pieces of
      information.

      Order the questions from general to specific topics:
      determine what was done before exploring how it was done.
      Start with the known areas of information and work toward
      the undisclosed information.

      Work backwards in time, from the most recent events.

      To help interviewees estimate quantities more accurately, use
      well-known reference points, relate to commonly observed
      quantities, or compare to similar items  or distances at the
      interview site.

      Give the interviewee time to think about the response.

When taking written statements,  an inspector should:

      Determine the need for a statement.

      Ascertain all the facts and record those which are relevant
      regardless of  the source.

      Prepare a statement by:

            Using a simple narrative style,

            Narrating the facts  in the words of the person making
            the statement, and

            Presenting the facts in chronological order.

      Identify the person positively (name, address, position).

      Show why the person is qualified to make the statement.

      Present the pertinent facts.
                                       4-15

-------
                         Have the person read the statements and make any necessary
                         corrections before signing (all mistakes that are corrected
                         must be initialed by the person making the statements).

                         Ask the person making the statement to write a brief
                         concluding paragraph indicating that he or she read and
                         understood the statement.

                         Have the person making the statement sign it.  If the person
                         refuses, then ask for a statement in the person's own
                         handwriting stating that the statement is true, but that he or
                         she refused to sign it.

                         Give a copy of the statement to the signer if requested.
                   4.7 OBSERVATIONS AND ILLUSTRATIONS


                   Make use of all sense perceptions: sight, smell, hearing, or touch.
                   Make use of sketches, field notes, and photography.

Photographs as     Photographs are becoming increasingly important in the
Evidence           enforcement of environmental law because they are persuasive in
                   court proceedings and provide excellent documentation.

                   For these reasons it is very important that inspectors become good
                   photographers. Before visiting a facility inspectors  should learn:

                         Which film type is best for the expected conditions;

                         How to  load and unload the film;

                         How to  insert batteries for the flash unit (if  separate) and
                         camera;

                         The minimum focal distance of the camera;

                         How to  operate the flash unit;

                         The maximum flash distance;  and

                         Whether the camera has a sliding lens cover.

                   Although the right to photograph is part of the right to inspect,
                   inspectors must testify that photographs fairly and accurately
                   represent site conditions.

                                      4-16

-------
Tips on Taking
Photos
       Maintain fresh film and batteries.

       Use a waterproof camera if possible.

       Pay special attention to composition, including the center of
       interest, background, and scale.

       Use a camera which automatically records the date and time
       on the film.
Drawings and
Illustrations
       Document photos by noting in logbook the frame number
       along with a detailed description of the subject matter.

       Take a picture of your business card as the first photograph
       on the film.

 •      Record necessary information on the back of the photo when
       working with an instant camera.

       Place a common item next to the item of interest to indicate
       size and scale.

       Photograph all sides of an item if necessary to document a
       violation.

       Take several photographs using different settings if the light
       is poor.

       Take overlapping photographs to depict a wide area.

Maps showing location of facility and plot plans showing activities
within facility are useful. Use sketches to supplement photos of
equipment.  Identify photo sites, sample sites, and observation sites
on a sketch map or on the original site map in your logbook.
                              4.8 EXIT INTERVIEW
                   When the inspection is complete, the inspector should conduct a
                   quick, concise, wrap-up interview to obtain any additional
                   information necessary and to convey to the facility representative
                   the findings of the inspection.

                   However, inspectors should carefully avoid conveying conclusive
                   compliance determinations because:
                                       4-17

-------
       The inspector has not had time to reflect upon and correlate
       all observations;

       Laboratory analyses have not been completed;

       Other individuals may ultimately determine the facility's
       compliance status; and

       The inspection findings may represent only a portion of an
       enforcement case.

If asked if any violations were found, the inspector may point out
various items the facility officials might want to recheck for
compliance purposes.  Inspectors should never say "there are no
violations" at the facility.

Inspectors also should  not leave a copy of field notes or checklists
with the facility representative because:

       The inspector's  notes or shorthand may be  misunderstood;
       and

       The inspector may remember and write down something after
       leaving the site  (may result in discrepancies).
   4.9  EXIT OBSERVATIONS/ACTIVITIES
Upon leaving the facility, the inspector should resurvey the site and
note whether any significant changes have occurred since the
inspection began. Such observations may better represent typical
operating conditions than what was recorded while the inspector was
on site.

The inspector should also review and complete site drawings and
chain-of-custody forms following the inspection.
                    4-18

-------
                                  CHAPTERS

                    5.0  POST-INSPECTION ACTIVITIES
                         5.1 THE INSPECTION REPORT
                   The purpose of the inspection report is to present a complete,
                   accurate, and factual record of an inspection.  It organizes all
                   evidence gathered in an inspection.

Elements of an     Although the format and exact contents of an inspection report will
Inspection Report   vary, each one  should provide enough information to tell the reader:

                         The specific reason for the inspection;

                         Who participated in the inspection;

                         That all required notices, receipts, and other legal
                         requirements were met;

                         What actions were taken during the inspection, including the
                         chronology of these actions;

                         What statements, records, physical samples, and other
                         evidence were gathered during the inspection;

                         What observations were made during the inspection; and

                         The results of the sample analyses related to the inspection.

                   Also, most reports will contain inspection report forms, narrative
                   reports, and documentary support.

Writing an         When writing an inspection report, it is important to relate the facts
Effective           and evidence relating to the inspection simply and with the reader
Inspection Report   in mind. A good inspection report exhibits:

                         Fairness;
                         Accuracy;
                         Conciseness;
                         Clarity;
                         Completeness;
                                       5-1

-------
                          The source of evidence;
                          Exhibits (supplementary material);
                          Organization; and
                          Good writing.

Narrative Report   Narrative reports, as part of an overall inspection report, should be
                   a concise, factual summary of observation and activities. Basic steps
                   involved in writing the narrative report include:

                   •      Receiving the information;
                          Organizing the material;
                          Referencing accompanying material; and
                          Writing the narrative report.  Be sure to:

                                use a simple writing style;
                                keep paragraphs brief and to the point;
                                avoid repetition; and
                                proofread the narrative.

                   Despite the variations in the specific information contained in a
                   narrative report, most reports can follow an outline, which features
                   the:

                          Introduction

                                general information
                                summary of findings
                                history of the facility;

                          Inspection activities

                                entry/opening conference
                                records
                                evidence collection
                                physical samples
                                closing conference; and

                          Attachments

                                list of attachments
                                documents
                                analytical  results.

                   Include photos, maps, and illustrations if they are available.
                                        5-2

-------
IV

-------
WASTE WATER INSPECTIONS

-------
                            TABLE OF CONTENTS

Chapter                                                                  Page

1.0   GENERAL WASTEWATER INSPECTION PROCEDURES	  1-1

      1.1    Objective  	  1-1
      1.2    Purposes of Wastewater Inspections	  1-1
      1.3    Inspection Procedures	  1-1
      1.4    Pre-Inspection Preparation	  1-2
      1.5    Onsite Activities	  1-4
      1.6    Follow-Up Activities	1-10

2.0   WASTEWATER  SAMPLING TECHNIQUES	  2-1

      2.1    Purposes for Sampling	  2-1
      2.2    Sampling Procedures	  2-1

3.0   WASTEWATER  TREATMENT TECHNOLOGIES   	  3-1

      3.1    Introduction	3-1
      3.2    Types of Wastewater Treatment  	  3-1
      3.3    Flow Equalization	  3-2
      3.4    Typical Treatment for Metal Finishing Wastewater	  3-3
      3.5    Other Treatments for Metals Removal	  3-6
      3.6    Organics Treatment	  3-7
      3.7    Oil Removal  	3-9

4.0   POLLUTION PREVENTION TECHNIQUES	  4-1

      4.1    Introduction	4-1
      4.2    Process Changes	4-1
      4.3    Material Substitution	  4-4
      4.4    Material Inventory and Storage	  4-5
      4.5    Waste Segregation	4-5
      4.6    Good Housekeeping/Preventative Maintenance/Employee Education  . . . 4-6
      4.7    Product Changes	4-7
      4.8    Water/Energy Conservation	  4-8
      4.9    Recycling	4-9

-------
                                    CHAPTER 1
                           WASTEWATER INSPECTION PROCEDURES
                                     1.1  OBJECTIVE
                This section provides general procedures to follow when inspecting a
                facility's wastewater generation and discharge.
                    1.2 PURPOSES OF WASTEWATER INSPECTIONS

Purposes of     There are many purposes for conducting wastewater inspections at industrial
Inspections      and commercial facilities. One of the primary purposes is to gather
                information about the facility's processes and operations and to characterize
                its discharges. This characterization should include the volume of
                wastewater discharges, the types of pollutants the facility discharges or has
                the potential to discharge, and whether or not the facility's discharge has
                the potential to cause damage to the receiving stream or the environment.
                Information gathered can be used to assess the need for pollutant controls
                and to develop discharge permit conditions or other associated requirements
                aimed at reducing pollutant discharges and thus reducing the negative
                impacts of these discharges on the environment. If facilities are required to
                submit information such  as permit applications, or responses to surveys,
                inspections can also serve as a means of verifying the accuracy of data and
                information submitted by the facility.  Once this information has been
                gathered, inspections should be performed to maintain and update
                information on facilities.

                Information gathered during inspections can also be used to evaluate the
                facility's compliance with any standards or requirements and to support any
                necessary enforcement action for noncompliance. Inspections can also be
                performed to verify the correction of problems and the attainment of
                compliance, such as the installation of wastewater treatment equipment.
                            1.3  INSPECTION PROCEDURES

Inspection      As with all types of inspections, a wastewater inspection consists of three
Procedures     general steps; pre-inspection preparation, onsite activities, and follow-up
               activities. Pre-inspection preparation is important so that an inspection is
               well planned and efficient and that the inspection objectives are met.  Onsite
               activities are the most essential part of the insDejctipn .and may include
                                        1-1

-------
                meeting with facility representatives, conducting a thorough inspection of
                the facility (including its operations and manufacturing processes, storage
                areas, and wastewater treatment systems), and examining records.  Follow-
                up activities are necessary to ensure that inspection findings are properly
                documented. Each of these steps will be discussed in greater detail.
                           1.4  PRE-INSPECTION PREPARATION
Pre-Inspection  Pie-inspection preparation involves several activities including review of
Preparation    facility records and literature references, development of an inspection plan,
                notifying the facility (if applicable), and assembling and calibrating safety
                and sampling equipment.  Each of these activities will be discussed in
                greater detail.
Records        The inspector should begin preparation for an inspection by reviewing any
Review         background information already gathered on the facility. Information to be
                reviewed may include data submitted by the facility such as responses to
                surveys or questionnaires or permit applications and correspondence.  In
                addition, reports from any previous inspections or site visits and
                information relating to the facility's compliance history should be reviewed.
                During this review, any unresolved compliance problems should be noted so
                that the inspector can verify these problems onsite. In order to determine
                compliance, the inspector must be knowledgeable about any regulatory
                requirements that apply  to the facility.  If not familiar with these
                requirements, the inspector should review all relevant requirements, such as
                permit conditions prior to the inspection.
Literature      To perform a thorough but efficient inspection and to establish credibility
Review         with the facility, the inspector should have at least a basic working
                knowledge of die facility's manufacturing process. If the inspector is
                unfamiliar with the particular operation or manufacturing process performed
                by the facility, applicable literature sources  should be reviewed in order to
                gain a better understanding of the specific process or operation.
Inspection      Once the inspector is familiar with the facility's background information, an
Plan           inspection plan should be developed. Basically, an inspection plan should
                outline the scope and objectives of an inspection and identify how the
                inspection objectives are going to be met.  The objective of the inspection
                will determine the scope and depth of the inspection.
                                          1-2

-------
                During preparation for an inspection, the inspector should note any
                questions that need to be answered during the onsite activities.  By
                preparing a list of, the inspector can better ensure that all necessary
                information to develop a
                complete picture of the facility is gathered.
Facility         In some cases it may be appropriate to notify the facility of an impending
Notification     inspection.  For instance, if a complete facility tour is desired, it may be
                beneficial to notify the facility so that the appropriate representatives are
                present.  In other cases, such as if noncompliance is suspected or in the
                event of a spill, notification may not be desirable. The inspector should
                determine if notification is appropriate and, if so, should contact the facility
                by telephone or by sending a letter.

                In the United States  three types of inspections are performed—scheduled,
                unscheduled, and demand.

                •  Scheduled  inspections are those that  are scheduled in advance and that
                    the facility has been notified of the approximate date and time the
                    inspection  will occur.  Scheduled inspections are most often used for
                    initial or routine inspections.

                •  Little or no advance notice is  given to the facility in an unscheduled
                    inspection.  Unscheduled inspections are useful as  random spot checks
                    in certain cases  such as the facility is suspected to be out of
                    compliance.
                                                                                 s

                •  Demand inspections are generally conducted in response to a specific
                    problem or emergency situation such as a spill.
                                          1-3

-------
Health and     Ensuring inspector safety is very important during an inspection.  Specific
Safety          information on safety equipment necessary for the particular facility being
                inspected should be gathered prior to the onsite activities.

                This information can be obtained from previous inspection reports, talking
                to people that have visited the facility in the past, or by obtaining the
                information directly from the facility.  If the facility is  notified of an
                inspection, this may be a good opportunity to inquire about safety
                equipment necessary for the inspection.
Equipment     The final step prior to an inspection is to prepare any equipment necessary
Preparation    for the inspection.  The type of equipment needed will be dependent on the
                nature of the inspection and may include safety and/or sampling and flow
                measurement equipment. The inspector should ensure that all equipment to
                be used is calibrated and is in proper working order. The inspector may
                also want to take a camera so that photographs of the facility can be taken.
                                  1.5 ONSITE ACTIVITIES
Periphery       Prior to entering, the inspector should conduct an examination of the
Inspection      periphery of the facility. If an inspection has not been performed
                previously, the inspector should note the general size of the facility
                including the number of buildings at the site.
                Any problems around the facility's perimeter such as apparent spills or
                improperly stored chemicals should be noted.  Environmental conditions
                such as the condition of surrounding vegetation, odor problems, abnormal
                stack emissions, and whether the facility has a direct discharge to a
                receiving stream should be noted.

                If outside chemical or waste storage areas are visible, the inspector should
                note the condition of these areas, including spill containment, and any
                associated problems such as leaking drums.

                Finally, if located in an easily accessible area,  the inspector may want to
                look at the facility's discharge points to see if there are any unusual
                discharges.
                                              1-4

-------
                 If sampling is to be conducted as part of the inspection, the inspector may
                 want to set up the sampling equipment at this time.  It may also be useful to
                 perform certain analyses such as pH prior to entering the facility.  Doing
                 this may provide insight to additional problems that should be addressed
                 during the inspection.  Any problems noted during the examination of the
                 facility's periphery should be addressed during the inspection.
Facility
Entry
When entering the facility, the appropriate facility representative should be
located.  The inspectors should identify themselves and be familiar with and
follow applicable procedures for facility entry.  Inspectors should provide a
copy of the written inspection order.
Opening        It is generally a good idea to conduct an opening conference or pre-
Conference     inspection meeting with facility representatives, particularly if it is the first
                visit to the facility.

                During this meeting the inspector should briefly state the purpose of the
                inspection and inform the facility representatives of the intended schedule
                and order of the inspection.  By doing this, it can be better assured that the
                proper facility representatives will be available to conduct the tour and
                answer questions. The inspector should also identify any additional records
                or information that will be needed so that the facility can gather the
                necessary information while the inspector is onsite.

                The inspector should use the opening conference to ask any questions
                identified during the pre-inspection preparation and to obtain general
                background information such as the number of employees,  production  rates,
                wastewater flow rates, and any changes that have been made since the last
                inspection.  Since many manufacturing facilities are noisy,  it may be
                difficult for the  inspector to hear during the tour.  Therefore,  it  may be
                beneficial to have facility representatives give a brief description of the
                industrial processes during the opening conference, particularly if it is  the
                inspector's first  visit to the facility.  If the facility has a plant  schematic, the
                inspector  should obtain a copy to make the tour easier to follow and to
                better ensure that all areas of the facility are covered.

                Inspectors should also answer any questions the facility may have.  From
                the start the inspector should strive to establish a good rapport with facility
                representatives so that they are comfortable and will more readily answer
                questions  and provide the information the inspector needs.

                Inspectors should also provide facility representatives with  information on
                applicable regulations and their associated responsibilities.  If the facility
                does not have copies of applicable regulations, the inspector should provide
                and review these during the opening conference.  General information  on

                                           1-5

-------
                pollution reduction and pollution prevention techniques such as brochures or
                guidance manuals should also be provided.

                Inspectors need to remain flexible and be ready to mate changes in their
                inspection plans.  Based on the observations during the examination of the
                facility's periphery or information obtained during the opening conference,
                it may be necessary to change the objectives or order of the inspection. For
                instance, if it was noted during the examination of the facility's periphery
                that a sump collecting runoff from a hazardous materials storage area was
                being pumped directly to the surrounding ground, this area should be
                investigated as soon as possible so that the problem is not discovered and
                corrected by the facility before the inspector has a chance to investigate it.
Facility         After the opening conference, the inspector should conduct a full tour of the
Tour           facility. Conducting a tour is very important to allow a full description and
                understanding of the facility's processes and to verify information provided
                by the  facility.  Tours also allow the inspector to identify problem areas that
                can be improved through pollution  reduction techniques.  The tour should
                focus on areas of the facility where wastestreams and/or pollutants are
                produced, processed, pumped, conveyed, treated,  or stored.  Such areas
                may include the facility's production processes, storage areas, and treatment
                equipment.  The inspector needs to gain a full understanding of the
                facility's wastewater generation and treatment. For better understanding of
                the entire process, it is best to tour the facility in order of production,
                starting from raw materials and following to the finished product.

                Throughout the inspection, the inspector needs to locate all sources or
                potential sources of wastewater discharge.  Sources may range from those
                that are easily identified such as a running water rinse from a plating bath
                to those more difficult to identify such as a discharge from a wet air
                scrubber.  A description of each discharge should be obtained. This
                information should include whether the discharge is batch or continuous, the
                amount of discharge, pollutants potentially in the discharge, and frequency
                of each discharge. The inspector also needs to identify the destination of all
                wastewater generated and all discharge points. Some wastewater may  be
                discharged directly to a receiving stream while some may be discharged to
                the sanitary sewer with or without  first going  to a pretreatment system.

                If possible, all wastewater flows should be measured or information on
                wastewater flows from each process should be requested from facility
                representative.  All  recirculating systems such as air conditioners should be
                noted and it should be determined if these systems ever discharge.
                Evaporation, use in products, and washwater should be accounted for.
                Washdown of vessels and process areas can be a significant source of
                wastewater. It should be determined if any batch discharges occur.
                                          1-6

-------
Reactors, plating tanks, and process tanks are often periodically discharged.
The amounts and chemical nature and frequency of discharge, and treatment
and disposal should be noted.

The inspector should also gather information on the flow of incoming water
to the facility.  With information on incoming water flow and wastewater
generation and flow, the inspector may be able to calculate a rough flow
balance. A flow balance compares the incoming water flow to the total
outgoing wastewater flow to ensure all water use at the facility is accounted
for. If the flow balance indicates discrepancies in flow volumes between
the incoming water and outgoing wastewater, the inspector should discuss
them with the facility representatives. Causes of the discrepancies may
include evaporation or water that is used but not discharged such  as water
contained in the product used in a  recirculating cooling system.

All industrial processes,  raw materials, and finished products should be
evaluated to determine pollutants being used or generated.  For example, at
a facility performing electroplating, quantities and types of plating and
associated chemicals used, frequency of disposal and treatment and/or
disposal methods should be noted.

Throughout the entire inspection process, inspectors should attempt to
identify areas in which the industry can decrease its use of chemicals and
reduce the amount and pollutant concentration of its discharges through
pollution reduction technologies.

The inspector should require schematics of the facility from the industry
before the first inspection. A schematic of the facility that shows the
processes, their wastewater discharges, flow through the treatment system,
and discharges points.  A description and process flow diagram for each
major product line should also be provided.  Then,  throughout the
inspection, these schematics should be checked by the inspector to make
sure these are accurate.

The quantities and types of raw materials, finished products, and  wastes
stored at the facility should be noted.  The inspector should evaluate storage
areas to determine the potential for spills to occur and to enter the sanitary
sewer.  The proximity of floor drains to any area where pollutants are
stored or handled such as storage and processing areas should be
determined.

If floor drains are present, the inspector should determine whether or not
the floor drains are used. The condition of a floor drain may  indicate
whether or not it is used.
                              1-7

-------
For example, the floor drain may be corroded, indicating that corrosive
materials have been discharged.  Floor drains that are permanently capped
or welded shut are preferable to just being plugged since these can be
removed.  In cases where the floor drains are capped or plugged, but not
welded, the inspector should inspect the floor drain for evidence that the
cap or plug is simply removed when the facility wants to discharge
material.  The inspector should also determine where the floor drains flow.
For example, some floor drains may flow to the wastewater treatment
system while others may discharge directly to the sanitary  sewer.

Spill containment structures such as berms and dikes should also be
evaluated to determine if they are adequate to contain spills.

Inspectors should inquire as to the cleanup and disposal procedures the
facility would follow in the event of a spill.  The  industry  should have a
spill plan on file at the facility. The inspector should evaluate the potential
for a spill to enter the sanitary sewer when the facility's procedures are
followed.

The wastewater treatment system  should also be inspected  to ensure that it
is properly maintained and is in good working condition. Treatment systems
may consist of physical, chemical, or biological processes  that are used to
remove or treat pollutants prior to discharging wastewater.  Wastewater
treatment can range from a simple oil and grease  separator to a complex
chemical system designed to remove metals. The inspector should note the
type of treatment used, any associated chemicals used, and any
circumstances under which the treatment system would be  shut down or
bypassed.

Information should also be obtained on any sludges or residuals generated
during the wastewater treatment process and methods by which these
sludges and residuals are disposed.

Operation and maintenance procedures implemented in the treatment system
should be discussed and appropriate documentation should be reviewed.
For example, if the facility continuously monitors pH, the  pH logs should
be reviewed and the inspector should determine the frequency at which the
pH probe is calibrated, ink is added, or the paper is changed.  In addition,
the inspector should verify that adequately trained staff are available to
properly operate and maintain the wastewater treatment system.  It is also
helpful to develop a diagram detailing the treatment process.

Many industrial processes such as cleaning, degreasing, grinding, and
chemical wastewater pretreatment produce a sludge or other waste that must
be disposed of.  For instance, vapor degreasing often produces a sludge as
well as spent solvent waste that must be disposed  of. The inspector should
                          1-8

-------
determine the waste generation rates, how often disposal occurs, and the
method of disposal.

If sampling is to be conducted at the facility, the inspector may want to
identify an appropriate sampling location during the inspection.

The inspector should review any records the facility may have compiled that
relate to its discharges.  These records may include analytical results of its
wastewater discharge, flow records, and treatment system operation and
maintenance records.

Although general inspection procedures have been outlined in this
presentation,  questions to ask facility representatives and necessary
information to gather depends on the type of facility being inspected.
Checklists that detail questions for general industrial inspections as well as
questions for specific types of industries are included as part of the handout.
It may be useful to review these questions and take a copy of the checklist
into die field. For example, specific information to obtain during inspection
of a facility performing electroplating may include the following:

•  Chemicals used in plating and cleaning baths (including cyanide)

•  Volume of plating and cleaning baths

•  Frequency at which plating and cleaning baths are changed

•  Treatment and disposal methods of spent baths

•  Description of all wastewater generated and methods of treatment and
    disposal

•  Whether any floor drains are located in process or storage areas

•  Whether any solvents or degreasers are used and, if so, methods of
    treating and disposing of spent solvents

•  Whether any sludges are  generated in plating baths, degreasing units,
    or wastewater treatment systems and, if so, how are they treated and
    disposed. The inspector  should review any records or file with the
    industry  showing how much sludge was generated and where it was
    disposed (onsite or off site).  If shipped off site, the inspector should
    inquire as to the final destination.  If these waste tracking records do
    not exist, the inspector may want the industry to start keeping  records.

•  Whether any air pollution control equipment uses water.
                          1-9

-------
                Note the ventilation system above the plating tanks.  The inspector should
                determine whether the collected vapors pass through a wet air scrubber.
Closing         After conducting the facility inspection, the inspector should meet with
Conference     facility representatives to ask for any further information or clarify any
                outstanding issues.  The inspector should prepare a written summary of
                inspection findings.  The inspector should also answer any of the facility's
                questions and allow the facility to respond to the inspection findings.
                              1.6  FOLLOW-UP ACTIVITIES
Follow-Up      In order to ensure that the inspection is documented so that information can
Activities       be readily retrieved for subsequent pretreatment program activities and to
                aid in any enforcement action necessary, an inspection report should be
                prepared. All inspection information including inspection notes, copies of
                file information, photographs, and other information should be carefully
                documented. Inspectors may also need to initiate or follow-up on any
                enforcement actions necessary based on the findings of the inspection.
                                         1-10

-------
                                    CHAPTER 2
                           2.0 SAMPLING TECHNIQUES
                             2.1 PURPOSES FOR SAMPLING
Purposes for    Although inspections may indicate which pollutants are potentially in a
Sampling       facility's discharge, they cannot conclusively determine specific pollutant
                information.  To determine the types and concentrations of pollutants in a
                facility's discharge, it is necessary to perform sampling. This specific
                pollutant information can then be used to identify which pollutants in a
                facility's discharge need to be reduced.  Pollutant information can also be
                used to determine the significance of a particular pollutant in the discharge
                so that necessary monitoring frequencies can be determined.  Sampling also
                provides a means to determine a facility's compliance with its discharge
                limits and as a basis for supporting enforcement actions.  Finally, if a
                facility performs self-monitoring, sampling  can be performed to verify the
                accuracy of that self-monitoring.
                              2.2  SAMPLING PROCEDURES

Preparation     It is important to be adequately prepared prior to going onsite so that all the
and Imple-      equipment needed to perform the sampling is available and that personnel
mentation       are properly prepared for the types of sampling required. Therefore,
of Sampling     general sampling procedures should be developed and followed when
Procedures      sampling at all facilities.  Sampling procedures should include designation
                of sample types, volumes, containers, and preservation methods to be used
                for each pollutant parameter as well as sample identification and
                documentation procedures.  Although these general procedures apply to all
                facilities, specific information on each facility should also be developed.
                This information may include pollutant parameters to be sampled, sampling
                location, and safety concerns. Obtaining this information prior to the
                sampling trip will allow the sampler to bring the proper  equipment, know
                where to sample and what pollutants to sample for, and be familiar with
                necessary safety precautions.
Coordination   The samplers should coordinate their sampling activities with the laboratory
with Analytical that will be performing the analyses.  The laboratory can provide
Laboratory    information on the types and volume of samples needed for particular
               pollutant parameters, sample preservation methods and  holding times, and
               shipping instructions. Laboratories may also provide sampling equipment
               such as samplers, pH meters, sample containers, chain-of-custody forms,
               sample labels, tags, and seals.
                                         2-1

-------
Preparation     Prior to the sampling trip, any required sampling and safety equipment
of Sampling     should be assembled, cleaned, and checked to ensure that it is in proper
and Safety      working order. All necessary paperwork should also be prepared prior to
Equipment      the trip.  This may include assembling and marking, as possible, the
                required sample container labels or tags, chain-of-custody forms, and lab
                request sheets.  Sampling and field analytical equipment such as pH meters
                should be calibrated.

                When conducting sampling, samplers need to be aware of health and safety
                hazards and take the proper precautions.  Safety requirements can be
                gathered from file information,  personnel that have previously sampled the
                facility, or by contacting the facility. Samplers need to be properly clothed
                and have adequate safety equipment available.

                Samplers should not enter confined spaces unless they  are properly trained
                and have the proper equipment  such as rescue equipment and respirators.
                Confined spaces should never be entered unless first tested for sufficient
                oxygen and lack of toxic and explosive gases.  Two persons should be
                present, one to enter the confined space and one to be  outside of the
                confined space.  The person entering the confined space should wear a
                safety harness that is attached to a retrieval system.  Use of this type of
                system will allow the rescue of the person in the confined space without
                requiring anyone else to enter.

Sampling       Samples should be collected from a location that is representative of the
Location        facility's discharge.  If the facility has more than one discharge point it may
                be necessary to collect samples  from several locations  in order to
                adequately characterize the facility's entire discharge.  Convenience,
                accessibility, and safety should also be considered when selecting a
                sampling site.  Appropriate sampling sites may include manholes as shown
                here. Other appropriate sites may be a process tank.

                Samples should be collected from the center of flow with the container
                facing upstream to avoid contamination.  Samples should be collected in
                areas that  are turbulent and well mixed and where the  chance of solids
                settling is  minimal. When sampling, the surface of the wastewater should
                not be skimmed nor should the  channel bottom be dragged. Samples should
                not be collected from stagnant areas containing immiscible liquids or
                suspended solids.
                                             2-2

-------
Sample Types   There are two basic types of samples:  grab and composite samples.
                Grab samples are individual samples collected over a period of time not
                exceeding IS minutes and represent wastestream conditions only at the time
                the sample is collected.  Grab samples are usually taken manually but can
                be collected using an automatic sampler.  Grab samples may be appropriate
                for batch discharges, constant waste conditions, to screen the discharge to
                see if particular pollutants are present, or if extreme conditions such as high
                pH are characteristic of the discharge. In addition, grab samples should be
                collected for pollutants that tend to change or decompose during the
                compositing period such as  pH, cyanide, total phenols, and volatile
                organics. In addition, grab samples should be collected for oil and grease
                samples since the oil and grease tends to adhere to sampling equipment.

                Composite samples are collected over time (either by continuous sampling
                or by combining individual  grab samples) and reflect the average
                characteristics of wastewater during the sampling period.  Composite
                samples are either flow proportional or time composited:

                •  In flow proportional  sampling, the volume of sample collected is
                   proportional to waste flow at the  time of sampling.  Flow proportional
                   samples can be obtained by collecting various sample volumes at equal
                   time intervals in proportion to flow or by collecting a constant sample
                   volume per unit of wastewater flow.

                •  Time composite samples consist of constant volume sample aliquots
                   collected in one container at equal time intervals.  For example, 500
                   milliliters of sample collected every  IS minutes over  a 24-hour period.

                Composite samples may be needed to determine the average characteristics
                of wastestreams, particularly if the wastestream has a highly variable
                pollutant concentration or flow rate.   Composite samples  should be
                collected during the entire period the  facility is operating  and discharging.
                For example, if the facility  has processes that discharge 16 hours a day,
                samples should be collected during the entire 16-hour period.

Sampling       Both  grab and composite samples can either be collected manually or with
Equipment      automatic samplers.  However, it is not recommended that automatic
                samplers be used to collect  samples for certain pollutants  such as oil and
                grease and volatile organics since oil  and grease may adhere to the sides of
                the sampler tubing and air may be introduced into volatile organic samples.
                                         2-3

-------
Sample         Sample volumes needed for analyses depend on the type and number of
Volumes        analyses to be performed.  The sampler should contact the person or
                laboratory that will be performing the analyses to determine sample
                volumes needed for a particular sampling event.  Adequate sample volume
                should also be collected to allow for QA/QC and for spillage

Sample         Sample containers should be made of chemically resistant materials that will
Containers     not affect the nature or concentration of pollutants being measured.
                Containers  must be large enough to hold the required sample volume.
                Glass containers should be used for oil and grease, phenol, and organics
                samples.  Amber glass  sample containers should be used for pollutants such
                as iron cyanide that oxidize when exposed to sunlight.  Containers with
                teflon lined lids should  be used when collecting volatile organics.  Plastic is
                easier to handle and is less likely to break, so  it may be the best type of
                container to use when glass is not needed.  Sample containers should be
                properly cleaned prior to use.  The laboratory  that will be performing the
                sample analyses should be contacted for specific cleaning instructions.
                Some laboratories may  provide pre-cleaned sample containers.
Sample Preser- Many pollutants are unstable and may alter in composition prior to analysis.
vation and      Therefore, to ensure that samples remain representative, they should be
Holding Times  analyzed as soon as possible after collection. If immediate analysis is not
                possible, samples should be preserved to minimize the changes in pollutant
                concentrations between collection and analysis.  There are three basic types
                of preservation:  cooling, pH adjustment, and chemical fixation.  Cooling is
                accomplished by chilling samples to 4°C by either refrigeration or by
                placing on ice.  Cooling suppresses biological activity and volatilization of
                gases and organic substances.

                If composite samples are collected, the samples should be cooled to 4°C
                throughout the compositing period. Samples should also be kept cool
                during transport to the analytical laboratory.

                Even with proper preservation, samples should be analyzed within certain
                recommended holding times. These holding times are the maximum times
                allowed between the time the sample is collected and when it is analyzed.
                If composite samples are collected, the holding time limitations begin when
                the last aliquot is added to the sample. Performing sample analyses within
                the allowable, holding times helps ensure that the analytical results are valid
                and representative of the wastewater.  Certain pollutant parameters such as
                pH have no standard method of preservation and should be analyzed
                immediately.
                                          2-4

-------
                                    CHAPTERS
               3.0  WASTEWATER TREATMENT TECHNOLOGIES
                                  3.1  INTRODUCTION
               It is helpful to understand the types of wastes generated in various industrial
               categories and common waste treatment and reduction techniques. The
               following discussion will provide a brief description of some of the most
               common types of waste treatment.
                     ?3.2  TYPES OF WASTEWATER TREATMENT
Classification
of Treatment
Techniques
Wastewater treatment technologies can be grouped by type of treatment into
four classifications:

Physical treatment technologies modify the physical structure of the
wastewater and its pollutants or separate the wastewater into various
components.  Physical treatment does not change the chemical structure of
the wastewater pollutants. Physical treatment is useful for separating
hazardous and non-hazardous components of a wastestream, separating a
wastestream  into various components for different treatment operations,
conditioning a wastestream for further treatment, and removing solid
particles or objects.  The most common physical treatment processes
include; equalization, screening, sedimentation, flotation, filtration,
adsorption, ultrafiltration, and stripping.

Chemical treatment technologies modify the chemical structure of the
wastewater pollutants to aid  removal of these pollutants from the
wastewater.  Chemical treatment technologies are usually relatively  easy,
but generate a solid sludge that must be managed and disposed.  The most
common chemical treatment processes  include neutralization, precipitation,
oxidation/reduction, and  dechlorination.

Biological treatment technologies degrade organic components of the
wastewater using microorganisms. These organics may be decomposed into
water and methane, other less toxic simpler organics, or microbial matter.
Toxic chemicals can inhibit biological treatment systems by killing the
microorganisms.  Also, high concentrations of inorganics and high
temperatures can inhibit biological treatment.  Also of concern, nitrogen
                                         3-1

-------
                and phosphorus are needed for biological activity to occur and are often not
                present in industrial wastewater.  The most common biological treatment
                processes include stabilization, activated  sludge, trickling filters, anaerobic
                digestion, and aerated lagoons.

                Thermal  treatment  processes achieve significant reductions in waste volumes
                and achieve a high degree of destruction of organics.  Unfortunately,
                thermal treatment often generates hazardous air emissions that must be
                controlled. The most common thermal treatment technologies include
                incineration and evaporation.

                Probably the  most appropriate way to discuss treatment technologies is in
                terms of  the nature of pollutants to be removed (i.e., metals,  organics, oil
                and grease, etc.). A brief discussion of various accepted treatment
                technologies for removing these pollutants follows; with a discussion of
                some treatment practices common to all types of wastewater treatment
                presented first.
                                3.3 FLOW EQUALIZATION
Flow           Combining wastewater flows to dampen fluctuations in flow rates and
Equalization    pollutant concentrations prior to further treatment or prior to discharge
                (i.e., equalization) provides an extremely valuable performance
                specification. Equalization typically occurs in tanks or basins that often
                contain a large capacity to handle wastewaters for an extended period of
                time.  Often variable flowrates and pollutant concentrations can reduce
                treatment efficiency.  For example, equalization before chemical treatment
                reduces the variability of flow, thereby reducing the necessary process
                controls, minimizing  the likelihood of over-or under-feeding of the
                treatment chemicals.  Equalization is useful for preventing slug loads from
                inhibiting further treatment processes or for preventing excessive
                concentrations in the  treatment system effluent. Equalization can also act as
                neutralization where both acidic and basic wastes are combined.

                Another technique for equalizing wastewaters is to hold high concentration
                wastes in a separate tank or basin and then bleed this waste into the more
                dilute waste stream over a period of time to minimize the impact.
                                          3-2

-------
          3.4 TYPICAL TREATMENT FOR METAL FINISHING WASTEWATER
Chemical       Metal finishing/plating/printed circuit board manufacturing facilities are one
Treatment      type of facilities that most often use chemical treatment technology.
                Typically, these facilities will require four types of chemical treatment for
                pollutant removal; neutralization, hexavalent chromium reduction, cyanide
                destruction, and chemical precipitation. A discussion of these treatment
                technologies follows.
Neutralization/  Biological treatment operates most effectively at a pH of 7. Variations in
pH Control     pH can have a significant impact on the treatment efficiency of biological
                systems including total inhibition of microbial activity. Another reason for
                pH control is for treatment performance optimization. This is especially
                true for treatment to remove metals.  Therefore, pH control is a crucial
                component in wastewater treatment.

                A pH control system typically comes in one of three  forms, continuous
                uncontrolled, batch controlled,  and continuous controlled.

                The simplest form is a continuous uncontrolled system that consists of
                running acidic wastewater through a bed of limestone chips.

                Another method is to batch treat a wastewater, whereby the pH is taken,
                acid or base  is added, the pH is reanalyzed, and the process continues until
                the desired pH is achieved. At that point, the wastewater can be discharged
                to the sewer  or to additional treatment, if necessary.

                The most advanced method of pH control is a continuous system  where pH
                sensors are used to measure the pH and to add the necessary treatment
                chemicals. In a continuous system,  a pH sensor determines the pH and
                signals  a pump to add neutralizing chemical, and the wastewater is mixed to
                provide homogeneous chemical addition. More complex systems have
                multiple pH sensors and multiple chemical addition points to further refine
                chemical addition to obtain more constant pH values.  Electrode
                maintenance  is a must for proper operation of the system as the electrodes
                are prone to  fouling, especially in extremely corrosive wastewaters.
Chromium      Chromium is one of the most common plating metals.  Wastewaters
Reduction      containing hexavalent chromium are generated from chromium
                electroplating, chromate conversion coating, etching with chromic acid, and
                metal finishing on chromium metal.  Hexavalent chromium (i.e., Cr+6) is
                the soluble ion most commonly used in the plating bath and is much more
                                         3-3

-------
               .toxic than the trivalent form (i.e., Cr*3).  Hexavalent chromium, which
                includes chromic acid (H2Cr04), chromium trioxide (CrO3) and chromates,
                must be reduced to the trivalent state to allow for chemical precipitation.
                Some manufacturers will use a trivalent form of chromium, such as
                chromium trichloride (CrCl3) or chromium sulfate (Cr2(SO4)3), in the
                process baths although these chemicals are more expensive to use and may
                not provide desirable qualities on the finished product that are achieved with
                hexavalent chromium.  Once the chromium has been reduced to its trivalent
                state, it can be subjected to chemical precipitation to remove the chromium
                and any other toxic metals.

                Reduction is typically done using gaseous sulfur dioxide or sodium bisulfite.
                Because the reaction proceeds much faster at low pH, the reduction should
                be performed at a pH of 2-3. The closer this reaction is to a pH of 3, the
                less sulfur dioxide will be released.

                Iron or iron salts may also be used to reduce the hexavalent chromium to its
                trivalent state.  A third, patented process, uses small pieces of scrap steel,
                adjusting the pH of the influent to a pH of 2.0-2.2, and  then flowing the
                wastewater through the steel scraps.

                Chromium reduction is a proven technology that is easy  to use and well
                suited to automation.  Reduction efficiencies of over 99.5 percent are easily
                achieved with concentrations of 0.05 mg/1 readily attained.  [Development
                Document for Effluent Limitations Guidelines and Standards  for the Metal
                Finishing Point Source Category, June 1983] Chromium reduction
                equipment is very simple and should include: a separate wastewater
                collection system for wastewater that contains hexavalent chromium only (as
                chemical interference is possible if mixed metal wastes are subjected to the
                chromium reduction process), metering equipment, contact tanks with
                agitation, and pH and oxidation-reduction potential (ORP) instrumentation.
Cyanide        Cyanide may be used as a cleaning agent and a complexing agent in zinc,
Destruction     cadmium, silver, copper and other plating baths. Cyanide can be destroyed
                through oxidation techniques. Chlorine (elemental or hypochlorite) is the
                most common oxidation chemical used to destroy cyanide.  Chlorine gas
                treatment is about half the cost of sodium hypochlorite treatment, but
                chlorine gas is dangerous to handle and should be accounted for when
                evaluating options.

                The alkaline chlorination reaction, by far the most common cyanide
                destruction method, is a two step process and proceeds as follows:

                1)   C12 + NaCN + 2NaOH = NaCNO + 2NaCl + H2O
                2)   3C12 + 6NaOH + 2NaCNO = 2NaHCOj + N2 + 6NaCl +  2H2O
                                         3-4

-------
                The destruction typically occurs in two tanks.  In the first tank, the system
                is monitored to maintain a pH of 9.S-11 with an oxidation-reduction
                potential of 300-400 millivolts. This is where  the cyanide is oxidized to
                cyanates.  This is also where the metal complex is broken, thus allowing
                some of the metals to precipitate.  In the second tank, the desirable pH is
                8.0-8.5 with an oxidation-reduction potential of 600-800 millivolts.

                Since cyanide is destroyed in the first stage reaction, many facilities have
                eliminated the second stage since this second stage is costly and poses a
                dangerous reaction situation (hydrogen cyanide gas generation) if the first
                stage is not adequately controlled.

                Alkaline chlorination of cyanide wastes is a proven technology with
                destruction efficiencies of over 99 percent and  effluent concentrations below
                detection readily available.

                Very simple equipment is needed for cyanide destruction including a
                separate collection system for cyanide bearing wastewaters, contact vessels
                with agitation, chemical metering, and pH and ORP instrumentation.
Chemical       The most common pretreatment technology for pollutant removal is
Precipitation   chemical precipitation. Chemical precipitation is used to reduce the
                concentration of metals in wastewater to levels below concern.

                Chemical precipitation is a three step process consisting of coagulation,
                flocculation, and sedimentation.  Through chemical addition, the
                interparticulate forces in the contaminants are reduced or eliminated thus
                allowing interaction of particles through molecular motion and physical
                mixing.  Rapid mixing allows for dispersion of the treatment chemical
                throughout the wastewater and promotes collisions of particles. Collision of
                these particles causes the particles to aggregate and form larger particles,
                which is known as coagulation.  The chemicals added to promote this
                aggregation, known as coagulants, serve two basic purposes: (1) to
                destabilize the particles, thus allowing for interaction, and (2) to promote
                aggregation of particles through floe strengthening.

                Alum (i.e., aluminum sulfate) and lime (calcium oxide) are the two most
                common coagulants used in the U.S. although organic polymer coagulants
                (i.e., long-chain, water-soluble polymers) have gained widespread
                acceptance.  Ferric compounds also  are used as  coagulants although these
                compounds are corrosive and difficult to dissolve in water.  [Water
                Treatment Principles and Design, James Montgomery Consulting Engineers,
                1985.]

                After a rapid mix period, mixing must be slowed to allow for formation of
                larger floes.  (At higher mix rates, the aggregate floe will continue to be

                                          3-5

-------
                destroyed through excessive physical contact.)  This process is known as
                flocculation. Because of the size of the particles, some mixing is required
                to cause contact between solid masses and to promote larger floe formations
                that will settle rapidly.

                During precipitation, the solids are separated from the liquid, usually by
                settling. This should result in two distinct layers, one solid and one liquid
                that can be readily separated.

                Typically,  coagulation equipment consists of tanks with rotating impellers
                for rapid mixing, but in-line blenders and pumps or baffles may be used.
                Flocculation equipment consists of tanks with paddle type mixers for slow
                agitation and flocculation. Sedimentation equipment usually consists of a
                clarifier unit which has inclined plates (lamella separator) or tubes. These
                units operate by gravity, require little space, and have minimal installation
                and maintenance costs.
                  3.5 OTHER TREATMENTS FOR METALS REMOVAL
Ion Exchange   In the ion exchange process, wastewater is passed through a container of
                anionic or cationic resin particles.  As the solution passes through the resin
                bed, there is an exchange of innocuous ions (e.g., H+ or OH') from the
                resin for the undesirable  similarly charged ions (e.g., Cu2+ or CN')
                dissolved in the solution. Each resin has a distinct number of ion sites that
                determines the maximum number of exchanges per unit of resin.  As the
                resin exchanges ions, it will reach a state in which it has adsorbed its
                capacity of ions.  The resin must then undergo regeneration during which
                the resin will be backwashed.  The regeneration process results in a small
                volume of backwash solution which has a very high concentration of the
                removed ions.

                Ion exchange units may be a batch tank, but are normally an enclosed
                pressurized column.  The process may be operated as a single unit, in
                parallel, or in series.

                The resin used in a column is selected for the constituents to be removed.
                Resins can be broadly classified as strong or weak acid cation resins or as
                strong or weak base anion resins. Strong acid and base resins operate
                independently of pH,  while the operation of weak acid  and base resins
                depends on the pH.  Chelating cations may also be used, but are expensive.

                As described above, typical ion exchange systems consist of one or more
                columns operated in a continuous mode, with  separate columns included for
                each type of resin.  Multiple columns of the same resin are used to prevent
                                         3-6

-------
                pass through of pollutants into the effluent after breakthrough has occurred.
                Additionally, duplicate systems are often employed to allow a flow to be
                diverted to a second unit during regeneration of the columns.
Reverse         Osmosis is the spontaneous flow of water from a dilute solution through a
Osmosis         semipermeable membrane to a more concentrated solution.  Reverse
                osmosis includes the application of pressure to overcome osmotic pressure
                and force the flow of water through the membrane toward the more dilute
                solution.  This increases the concentration of pollutants in the wastewater,
                but reduces the volume of contaminated water.  Ions and small molecules
                can be separated using this technology.

                Reverse osmosis units are sensitive to the environment and must be
                carefully checked for chemical attack, fouling, and plugging.  Maintaining a
                pH of 4 to 7.5 will help to minimize fouling and plugging.  Reverse
                osmosis is not effective for highly organic wastes as the organic materials
                act to dissolve the membrane.  Oxidizing agents, such as iron and
                manganese, particulates, and oil and grease must be removed prior to
                reverse osmosis. Biological growth on the membrane (which is promoted at
                low organic concentrations) can also reduce unit efficiency, although
                addition of chlorine or other biocides can eliminate this fouling.  Operating
                reverse osmosis units in series can improve the handling of variable
                flowrates and pollutant concentrations.
                              3.6  ORGANICS TREATMENT
Organics        Wastewater treatment to remove organic compounds has historically been
Treatment      through biological degradation (i.e., the breakdown of compounds through
                microbial digestion).  While this method is quite effective for domestic type
                wastes, biological treatment of industrial wastes containing organic
                chemicals is not always as effective.  Reasons for this ineffectiveness
                include; certain organic compounds may be toxic to the microorganisms
                thereby inhibiting the degradation  activity, not all materials are biologically
                degraded, and it is often difficult to treat down to the necessary
                concentrations.  As such, several techniques common to organic chemical
                production have been further developed as wastewater treatment
                technologies.

                The treatment technologies found to be the most effective at reducing the
                concentration of organic pollutants in wastewater and used regularly in the
                treatment of organics include:
                •   Carbon adsorption
                •   Air stripping
•   Steam stripping
                                         3-7

-------
Carbon         First, definition of the term "adsorption" is helpful when understanding the
Adsorption     concept of carbon treatment.  Commonly, this term is confused with
                "absorption."  Adsorption is the taking up of a liquid, gas, or dissolved
                solids onto the surface of a solid or liquid. Absorption is the taking up of a
                liquid, gas, or dissolved solids into the molecular structure of the solid or
                liquid.  The basis for carbon adsorption is the high surface area per weight
                on the activated carbon due to a very high porosity and the natural affinity
                of a liquid (or gas) to be attracted to and held on the surface of a solid.
                Surface areas of 100 m2/g are common.

                Carbon adsorption is typically the most effective technology for removing
                dilute concentrations of organic compounds from wastewater.  Often it is
                used as a final polishing step prior to discharge.  Carbon is widely used in
                the U.S. for drinking water treatment.

                Two types of activated carbon  application are used for wastewater
                treatment, granular and powdered. Granular carbon typically is contained
                in packed  columns, with the wastewater flowing either up or down through
                the carbon packing.

                Typically, carbon columns are operated in series, with two or more
                columns.  This ensures that as  the first column reaches its capacity and the
                effluent from this column becomes more contaminated, the second column
                can treat this contamination and prevent contaminated discharges to  the
                municipal  treatment plant. New carbon can then be added to the first
                column, the second column can become the first column while the old first
                column is  being refilled, and the old first carbon column can now become
                the second column in series. A similar approach can be taken for more
                than two columns as well.

                Powdered  activated carbon is added to water to form a slurry and then
                introduced into the wastewater. This wastewater and carbon mixture is then
                agitated to increase contact between the carbon and contaminants, and then
                allowed to settle in a quiescent state.  The treated wastewater can then be
                pumped off the top with the carbon sludge hauled off for disposal or
                regeneration.
Air Stripping
Air stripping defines the practice of removing volatile contaminants from
wastewater by contacting the wastewater with a steady stream of air through
a packed column (typically countercurrently).  The air (which now contains
the contaminants from the wastewater) can then be released to the
atmosphere or preferably recovered or further treated using carbon
adsorption, incineration, or open flame.

In a packed column, air is drawn up through the column with fans and the
water trickles down the column.  Packing materials, such as berl saddles or

                          3-8

-------
                raschig rings, provide more surface area to promote mass transfer between
                the air and wastewater.

                The benefits of air stripping columns are that they take up little space,
                operate in a continuous mode, and are inexpensive to operate. Energy costs
                comprise the sole operating cost.

                Air stripping is a common practice for treatment of contaminated
                groundwater.  Here, the water is pumped out of the ground and  treated.
Steam          Steam stripping operates similar to air stripping except that steam is
Stripping       introduced rather than air, thereby heating the water and improving the
                transfer of contaminants.  This is similar to distillation of volatiles from the
                wastewater.  One method to improve the efficiency of a steam stripper is to
                condense a portion of the vapor leaving the top of the column and return it
                to the column as a liquid. In the U.S.,  where organic chemical plants use
                stripping  technology for wastewater, over 90 percent use steam stripping
                rather than air stripping. Halogenated aliphatics (e.g., methylene chloride,
                chloroform, and vinyl chloride) are very conducive to steam stripping
                technology.

                For volatile pollutants, over 99-percent removal is common.  Steam
                stripping  is more effective than air stripping although considerably more
                expensive (because of energy costs).
                                    3.7 OIL REMOVAL
Oil Removal    Many types of industrial facilities generate wastewater containing oil and
                grease, the concentration of which can vary drastically. For example, a
                textile manufacturer may generate wastewater with 10-50 mg/1 of oil and
                grease; a food processor between 100-1,000 mg/1; a commercial laundry
                between 100-2,000 mg/1; and a metal fabricator between 10,000-150,000
                mg/1.  [Toledo Division of Continuing Education.]

                To discuss oil and grease removal, the three types of oil and grease must
                first be identified.  These include free oils (which rise to the surface and
                can be skimmed off), emulsified oils (which must have the emulsion broken
                before removal), and dissolved oils (which require biological treatment or
                more sophisticated  treatment techniques for removal).

                The simplest form of oil removal is gravity separation. Oil-containing
                wastewater is held in a quiescent state, where the free oil being lighter than
                water, will float to the top and can be skimmed or pumped off.  Rotating
                                         3-9

-------
belts are often used to remove the oil from the surface.  Solids that settle to
the bottom can also be removed.

Emulsion breaking is necessary to remove oils where the oils are present as
an emulsion (e.g., coolants applied directly to metal components or metal
fabricating equipment during operation).  (Emulsified oils are often called
"soluble oils" as the oil appears to be dissolved in water; however, the oils
are actually present as tiny droplets suspended in water.) Typically,
emulsions are broken by pH adjustment or chemical addition.
Polyelectrolytes have come to be the treatment method of choice for
emulsion breaking because of the wide selection of chemicals available and
the limited volume of sludge produced  (versus the older method of choice
of lime or alum addition).

After breaking the oil emulsion, the oil can be removed  using air flotation
techniques; either dissolved air flotation or induced air flotation.  In
dissolved air flotation, the wastewater is pressurized in the presence of air,
thereby dissolving the air in the water.  When the water is discharged from
the pressure line into an open tank,  small air bubbles form which carry the
free oil and suspended solids to the  surface where they can be removed with
skimming apparatus.  Induced air flotation consists of introducing fine
bubbles underneath a liquid and as the air rises, the bubbles collect the oils
and suspended solids lifting them  to the surface where they can be removed.
(Air bubbles in induced air systems  are an order of magnitude larger than in
dissolved air systems.)

Recently, ultrafUtration techniques have been used to remove oil from
wastewater. In ultrafUtration, the wastewater is pumped past a membrane
where the water and other dissolved substances flow through the membrane.
The large emulsified oil molecules are retained. Subsequent passes through
an ultrafUtration unit can  further purify the contaminant  oil.  Reductions in
volume by 95-97 percent are achievable through ultrafiltration.
                         3-10

-------
                                    CHAPTER 4
                  4.0  POLLUTION PREVENTION TECHNIQUES
                                  4.1  INTRODUCTION
Introduction   Pollution prevention techniques are considered to fall under the first two
               tiers of the waste management hierarchy, that being, source reduction and
               recycling.  As described previously, pollution prevention techniques under
               these two categories can be grouped into eight classifications.  To better
               understand the impacts of these eight types of pollution prevention
               techniques, specific methods to reduce wastewater pollution in the
               electroplating/metal finishing industry are presented and discussed in detail.
                                4.2 PROCESS CHANGES
Process        The greatest number of pollution prevention techniques in the electroplating/
Changes       metal finishing industry can be classified as process changes.  As mentioned
               above, process changes may affect either procedures or equipment and
               influence the quantity or toxicity of wastes generated.
               Considering how a metal part is electroplated, in an ideal situation, all the
               water would drain off the workpiece as it is removed from the plating bath,
               negating the need for rinsing.  However, it is clear that this is not the case
               and that even in the best of situations, a small amount of plating bath
               remains on the workpiece and must be removed to stop any further
               chemical action by this solution. This phenomenon leads to the first and
               often the most opportunistic area for pollution prevention at a plating
               facility: dragout. Dragout is the plating term for the plating  solution that
               is carried out of the plating bath as the workpiece is removed from the
               bath. Minimizing the carryover of this dragout into subsequent rinse tanks
               can drastically reduce wastewater flow rates and pollutant loads, thereby
               reducing both the amount of raw materials that must be purchased and the
               cost of pollution control.
                                        4-1

-------
Plating Bath    The first area to consider for dragout reduction is the plating bath.  Several
                modifications to the plating solution makeup can  impact the amount of
                dragout. The most common techniques include:

                •  Increase the temperature of the bath, thereby reducing the surface
                    tension and viscosity of the bath (promoting  quicker drainage of the
                    plating solution)

                •  Decrease the concentration of metals in the plating bath such that a
                    more dilute solution is being carried over into the rinse tanks

                •  Add wetting agents/surfactants to the bath to reduce the surface tension
                    (again promoting quicker drainage).
Plating         Even if the plating bath is adjusted as described above, dragout can still be
Techniques     a major source of wastewater pollutants if improper plating techniques are
                used. When plating, workpieces are either hung on a rack or loaded into a
                barrel (for small parts) and then submerged into the plating tank.  After a
                specified period of time, the parts are lifted out of the bath and transferred
                to a rinse tank where the residual plating solution is cleansed off the parts.
                Techniques that can minimize carrying  over dragout from the plating tank
                to the rinse tank include:

                •   Design plating racks that do not have cups or pockets that could
                    possibly carry plating solution over into a rinse tank.

                •   Design racks that hold the workpieces in an optimum configuration to
                    minimize dragout (i.e., the part should be at an angle with the smallest
                    surface area the last to leave the plating bath). For example, if plating
                    an axle, the axle should be removed from the bath near vertical rather
                    than horizontal.

                •   Inspect racks regularly for worn insulation or corrosion that could form
                    pockets  for plating solution.

                •   Withdraw parts from the plating bath slowly and allow to drain over
                    plating tank for at least 10 seconds.

                •   Install air knives over plating solution that drives the plating solution
                    off the workpiece and back into the plating tank as the part is
                    withdrawn from the plating bath.

                •   Install a fine mist spray  (fog spray) over the plating bath to spray the
                    plating solution off the workpiece and back into the tank. However,
                                          4-2

-------
                    the flowrate of the spray cannot exceed the evaporation rate of the
                    plating solution.

                •  Agitate the workpiece or barrel after it is removed from the plating
                    bath, thus promoting drainage back into  the tank.

                •  Install drain boards and drip guards between the plating tank and
                    subsequent rinse tanks to catch any residual drainage and return this
                    solution back into the plating tank.
Rinsing         When designing the rinse system, several configurations are recommended,
Techniques     including:

                •  Use a static rinse (often called a dragout tank or dead rinse) as the first
                    rinse to cleanse off the most concentrated plating solution. After a
                    period of time, the concentration of plating solution in this tank will
                    increase to the point where it can either be fed directly back into the
                    plating tank or can be purified using techniques such as evaporation or
                    reverse osmosis and then fed back into the plating tank.

                •  Add air or mechanical agitation to the rinse tank and all subsequent
                    rinse tanks to promote complete rinsing (this is especially important for
                    complex workpieces with a lot of angles and crevices).

                •  Install rinsewater control hardware such as flow control meters, flow
                    restrictors, foot-controlled spray nozzles, and photosensors (which turn
                    on the rinsewater as the plated parts pass through the line of sight of
                    the photosensor) to minimize and control rinsewater usage
                •   Use high-pressure spray rinses for effective cleansing with a minimal
                    amount of water.

                •   Allow an adequate amount of time in the rinse tank to promote good
                    rinsing (for rinsing simple parts in well agitated tanks, 5-10 seconds
                    may be enough time, but, for complex parts in a poorly agitated rinse
                    tank,  10 minutes may not even be enough time).

                •   Use multiple countercurrent rinse tanks.
Extending      In addition to dragout control, several techniques can be used to minimize
Plating         contamination of the plating bath as well as any precleaning baths (e.g.,
Bath Life       acids or alkaline cleaners), thereby extending the useful life of the bath

                                          4-3

-------
                while at the same time promoting recovery/recycling techniques. These
                methods include:

                •  Preclean parts using mechanical methods, such as wiping, squeegeeing,
                    or shot blasting

                •  Minimize dust and dirt in the plating room

                •  Cover plating bath to minimize contamination

                •  Replenish baths rather than batch dumping and replacing

                •  Reduce dragging of pre-plating solutions (e.g., acids or alkaline
                    cleaners)

                •  Install a continuous filtering system on the bath to remove impurities

                •  Remove anodes from the plating tank when not in use.

                Use of the process changes described above can save the plating shop a lot
                of time and money without changing the physicochemical process.


                             4.3  MATERIAL SUBSTITUTION
Material        The second pollution prevention category, material substitution, takes
Substitution    electroplating modification one step further. In this case, a plating facility
                may choose to modify the raw materials used at the facility to minimize
                pollution. These modifications may include:

                •   Use deionized water in the plating bath and dragout tank (i.e., the tank
                    that will eventually be recycled back into the plating tank) to remove
                    contaminants that will build up over time and contaminate the bath.

                •   Use high-purity raw materials (i.e., anodes, plating chemicals, acids,
                    etc.) that will minimize contamination.

                •   Change to a non-cyanide plating bath (e.g., pyrophosphate copper, acid
                    sulfate cadmium, or zinc chloride) to eliminate the use of toxic and
                    hazardous cyanide.

                •   Use non-chelated chemicals (i.e., chemicals that do not form organic/
                    inorganic complexes with the toxic metals, thereby inhibiting metal
                    removal using conventional treatment technologies).
                                         4-4

-------
                •   Use aqueous cleaners rather than organic solvents to remove dirt and
                    oil.

                •   Reuse spent acids and bases in other areas where purity is not as vital
                    (e.g., similar to countercurrent plating baths, countercurrent acid rinses
                    can  minimize acid and water use)

                •   Use treatment chemicals that minimize sludge generation (e.g.,
                    magnesium hydroxide rather than lime or caustic).
                      4.4 MATERIAL INVENTORY AND STORAGE
Material        The process of electroplating requires the use of a wide variety of raw
Inventory       materials, from plating chemicals, to acid/alkaline cleaners, organic
and Storage     solvents, and wastewater treatment chemicals.  Proper inventory and storage
                of these materials can minimize pollutant loadings to the environment.
                Considerations include:

                Material Inventory

                •   Use raw materials before the shelf life or expiration date (use the first-
                    in, first-out practice)

                •   Buy an appropriate amount of raw materials, only buying large amounts
                    of materials with an unlimited shelf life (e.g., metal prices fluctuate
                    regularly and the quantity and time of purchase is often highly
                    dependent on the current price)

                •   Purchase raw materials from suppliers that will buy back chemicals that
                    are out-of-date.

                Material Storage

                •   Divert storm water away from material storage (including covering raw
                    materials, either inside or under roof, tarp, etc).

                •   Install spill containment around raw materials and do not store
                    materials outside this containment (as is often done  with one drum or a
                    few bags of a chemical).

                •   Store raw materials as specified by the manufacturer (e.g., proper light,
                    temperature, etc).
                               4.5 WASTE SEGREGATION
                                            4-5

-------
Waste          Segregation of wastes is important for two reasons:  (1) regulations differ
Segregation     for different wastes and by segregating, costs can be minimized, and
                (2) treatment techniques often are more effectively performed on individual
                wastestreams rather than on the combined wastestream.  However,
                oversegregation of wastes can also be a problem, causing greater
                environmental release potential, repetitive equipment costs, and more
                difficulty meeting environmental regulations. Therefore, segregation of
                wastes should be analyzed in detail before designing wastewater
                management systems and procedures.  Factors that should be considered
                include:

                •   Segregating hazardous and non-hazardous wastes to keep waste
                    management costs to a minimum.

                •   Using separate treatment systems for different metals to  produce higher
                    quality sludge, thereby increasing its likelihood of reuse.

                •   Keeping non-metallic and metallic wastes separate to eliminate
                    unnecessary metals treatment of nonmetallic wastes.

                •   Keeping hexavalent chromium and cyanide wastes separate to minimize
                    the flow to be reduced or oxidized.
             4.6  GOOD HOUSEKEEPING/PREVENTATTVE MAINTENANCE/
                                 EMPLOYEE EDUCATION
Good
Housekeeping
Proper operation and implementation of the equipment and procedures
assure pollutant loading reductions.  Good housekeeping practices that
should be employed in a plating shop include:

•   Use a dry floor for the plating line, rather than an overflow system
    where water overflows the plating line tanks into a sump.  (This
    stresses the importance of keeping the plating area clean and dry and
    inhibits sloppy water use practices.)

•   Keep area clean and dry at all times (so that if leaks, spills, or
    overflows occur, the source of the problem can be easily identified and
    corrected).
Preventative
Maintenance
As with any manufacturing operation, preventative maintenance is essential
if a facility intends to operate for any length of time without fear of
equipment failure or loss of product quality.  In the plating shop, this type
                                         4-6

-------
                of situation can occur quickly if proper preventative maintenance is not
                performed.  Activities should include:

                •  Install high-level alarms on tanks that could overflow and cause
                    environmental or safety hazards

                •  Regularly check for leaks in tanks, valves, fittings, pumps, etc. and
                    repair immediately

                •  Keep a supply of extra parts on hand for commonly replaced
                    components

                •  Maintain plating racks in good condition to minimize dragout or poor
                    electrical conductivity

                •  Calibrate conductivity,  pH, and flow meters regularly

                •  Inspect workplaces prior to plating to eliminate rejects before
                    processing through plating line.
Employee       One of the most critical components of pollution prevention in a plating
Education      shop (especially in a small shop where parts are manually transferred from
                tank to tank), is the need for employee education and training.  Throughout
                the U.S., plating shops have been found to have excellent equipment and
                procedures in place to minimize pollution, but for one reason or another,
                the plating line operators prevented these pollutant reductions from actually
                occurring.  Steps that can be taken to improve employee habits include:

                •   Provide regular training to employees on proper operating practices,
                    including the economic benefit of following those procedures.

                •   Provide employee incentives for beneficial suggestions or for meeting
                    certain pollution prevention goals (e.g., no noncompliance events while
                    maintaining a low wastewater flowrate).

                •   Educate employees on water conservation.  [Water use can be a
                    significant concern since many plating line operators will increase rinse
                    rates to speed up the process, irrespective of supervisor's instructions.]

                •   Post important information on equipment and procedures for employees
                    to use as a reference (e.g., dragout times and a clock, contents and
                    concentrations in all tanks, markings on valves as to the proper open
                    position, spill cleanup procedures and equipment).
                                 4.7 PRODUCT CHANGES

                                            4-7

-------
Product        Similar to material substitution, the plating facility should consider product
Changes        changes that can minimize pollution. For electroplaters, this could include:

                •   Replace toxic metals with non-toxic metals (e.g., replace cadmium with
                    aluminum).

                •   Replace hexavalent chromium with trivalent chromium. [Note:  most
                    bivalent chromium formulations produce a duller plate than the shiny
                    plate produced by hexavalent chromium, trivalent chromium is more
                    expensive than hexavalent chromium, and, excluding decorative
                    applications, the physical and chemical properties of the trivalent
                    chromium may limit the applicability.]

                •   Redesign manufactured parts to minimize pockets and cups that can
                    dragout plating solution (often this is done simply by designing a hole
                    in the location of the cup or pocket)

                •   Evaluate the possibility of non-plated parts (e.g., powder coating).

                Most often, product changes resulting from material substitutions must be
                evaluated in great  detail to determine the saleability of the redesigned
                product.  In some instances (e.g., putting holes in the legs of chrome plated
                chairs and tables to promote drainage during plating), the change likely will
                not effect the resale value of the pan.  Conversely, a plater may be able to
                use this redesign to its advantage by advertising the new chair as an
                environmentally-sensitive design.
                         4.8  WATER/ENERGY CONSERVATION
Water/Energy  Water/energy conservation is often the result of one of the other seven
Conservation   pollution prevention classifications.  However, several steps can be taken in
               the plating shop to further minimize energy and water consumption.  This
               includes:

               •  Reuse deionized rinsewater in other areas of the plating shop where
                   purity is not as important.

               •  Cover tanks when not in use to reduce heat loss and evaporative losses
                   (e.g., the use of polypropylene balls, which float on the surface of the
                   bath, reduce evaporation significantly).
                                         4-8

-------
                    Recycle once-through cooling water for rinse water or makeup water
                    for other baths (it is unlikely that this water is suitable for the plating
                    bath or the stagnant rinse tank).

                    Turn off rinse tanks when not in use (e.g., use of photosensors which
                    automatically turn the water on and off as working pieces are rinsed).

                    Use conductivity sensors and pH probes to control rinsewater quality,
                    whereby freshwater is added only when the conductivity or pH
                    approaches a certain unacceptable level.
                                      4.9 RECYCLING
Recycling       1.  Waste Exchange. One technique that has been increasing in popularity
                in the U.S. as the cost of pollution control continues to rise is waste
                exchange.  This technique encourages exchanging of wastes with others for
                reuse of the waste or recovery of valuable materials.  Several types of
                wastes in the electroplating/metal finishing industry are conducive to waste
                exchange, namely metal sludges, spent plating baths, and spent acids and
                alkaline cleaners.  Some of the wastes suitable for exchange include
                pickling wastes (i.e., sulfuric acid and ferrous sulfate) for use in fertilizer
                production, sodium hydroxide from electrowinning for use in neutralization,
                and reclaimed oils available for reuse as fuel.

                2.  Wastewater Recycling. Several technologies are commonly used to
                reduce the volume of contaminated wastewater in the metal finishing
                industry with the purpose of recovering the concentrated solution for reuse.
                Techniques such as evaporation, ion exchange, reverse osmosis,
                ultrafiltration/microfiltration, electrodialysis, and electrowinning are readily
                available technologies for the recover/recycle of raw materials.

                3.  Evaporation.  Evaporators can be used to recover a wide variety of
                acidic and basic baths including; chrome plating, chromic acid etch, nickel
                plating, copper sulfate,  precious metals, cyanide plating (zinc, copper,
                cadmium, silver),  and zinc chloride. Recovery consists of boiling off water
                until the concentrate can be returned to the plating bath.  Vapor is
                condensed and recycled for use as rinse water.  Pressurized evaporation
                prevents thermal degradation of plating chemicals and reduces energy costs.
                Evaporation also concentrates contaminants in the plating bath which must
                be removed before reuse.  Technologies such as carbon filtration or ion
                exchange may remove these contaminants to a sufficient concentration to
                allow for reuse.
                                          4-9

-------

-------
AIR POLLUTION/HAZARDOUS WASTE




         INSPECTIONS

-------
THIS PAGE LEFT BLANK

-------
                             TABLE OF CONTENTS

Chapter                                                                       Page

1   Baseline Inspection Techniques for Air Pollution Sources	1-1

    1.1    Objective	1-1
    1.2    Introduction	1-1
    1.3    Principles  of the baseline method	1-1
    1.4    Levels of inspection	1-3
    1.5    Level II source inspections	1-5
    1.6    Components of the control system  	1-6
    1.7    Ancillary components	1-8
    1.8    Classification of air pollution control devices	1-11
    1.9    Fabric filters   	,	1-12
    1.10  Electrostatic precipitators  (ESPs) 	1-17
    1.11  Cyclones/Multi-cyclone collectors	1-20
    1.12  Wet scrubbers  	1-23
    1.13  Carbon bed adsorbers	1-30
    1.14  Incinerators  	1-32
    1.15  Condensers  	1-32

2   Hazardous Materials/Hazardous Waste Inspection Procedures	2-1

    2.1    Introduction	2-1
    2.2    Inspection preparation 	2-2
    2.3    Health and safety requirements  	2-3
    2.4    Inspection equipment	2-4
    2.5    Operations, waste handling, and record review  	2-4
    2.6    General inspection procedures 	2-5
    2.7    Inspection checklists	2-6
    2.8    Waste sampling  	2-7
    2.9    Documentation	2-8
    2.10  Field notebook	2-9

                                      Figures

Figure                                                                         Page

1-1   Typical  air pollution control system	1-7
1-2   Shaker-cleaning fabric filter 	1-13
1-3   An example of a large  reverse-air fabric filter	1-14
1-4   Pulse-cleaning  	1-16
1-5   ESP collection schematic  	1-19
1-6   Electrostatic precipitator	1-19

-------
                                  Figures (Cont...)

Figure                                                                        Page

1-7   Single cyclone collectors	1-22
1-8   Multi-cyclone	1-22
1-9   Simple spray chamber	1-25
1-10  Tray scrubber	1-26
1-11  Countercurrent packed tower	1-27
1-12  Conventional venturi scrubber  	1-28
1-13  Activated carbon adsorber  	1-31
1-14  Direct-fired incinerator	1-33
1-15  Catalytic incinerator	1-33
1-16  Contact condenser  	1-34
1-17  Surface condenser   	1-35


                                    Appendices

Appendix                                                                     Page

1-A   Safety Guidelines	1-37
1-B   Recommended List of Inspection Equipment  	1-39
1-C   Baseline Air Pollution Quiz  	1-41
2-A   Hazardous Materials/Hazardous Waste Sampling Equipment	2-11
2-B   General Site Inspection Information Form 	2-13
2-C   Waste Information Worksheet  	2-15
2-D   Containers Checklist	2-17
2-E   Waste Piles Checklist	2-19
                                         11

-------
                              CHAPTER 1

1.0 BASELINE INSPECTION TECHNIQUES FOR AIR POLLUTION
                               SOURCES
                             1.1 OBJECTIVE
                To provide information and techniques to support inspection
                personnel in conducting field inspections which are necessary to
                promote compliance.
                           1.2 INTRODUCTION
                During the period from 1970 to 1975, the majority of sources in the
                U.S. installed pollution control equipment to satisfy recently
                promulgated regulations.  Most of these systems operated well
                initially; however, as they aged, operation and maintenance problems
                began to emerge. The baseline inspection method was developed to
                provide  agency personnel with an aid to diagnosing these emerging
                problems.  The ultimate goal is to be able to identify deteriorating
                performance before non-compliance occurs and restore collection
                efficiency to  its original level.

                In this chapter, information concerning the baseline method, various
                types of inspections, air pollution  control systems, and common air
                pollution control devices is presented.
                         1.3  PRINCIPLES OF THE BASELINE METHOD


                The baseline inspection method embodies four major principles:

                1.   Every source and every control device is unique.

                    Each control system should be approached initially as if it
                    performs in  a manner different from other similar systems on
                    other similar sources. This is important, because substantial
                    differences in performance and vulnerability to problems have

                                  1-1

-------
    been noted in a number of cases where identical control systems
    have been installed on identical or similar sources. With the
    baseline method, a symptom of potential problems is simply a shift
    in a measured or observed parameter from the value or condition
    it had when the source was known or assumed to be in
    compliance. It should be noted that one symptom is rarely used
    alone.  Rather, a combination of symptoms is analyzed to
    determine if there are potential problems.

2.   On-site instruments are often unreliable or unavailable.

    If the control device has operation and maintenance problems, it
    is very likely that the instruments are also not working properly.
    Also, particularly on smaller systems, a parameter of interest may
    not be measured.  It is important that the inspector be aware of
    this possible limitation and be prepared to either use less- than-
    desirable data or to make the needed measurements with portable
    instruments.

3.   A counterflow inspection approach ensures that information of most
    value is obtained first.

    In the counterflow approach, the inspection begins at the stack
    and proceeds toward  the source in a direction counter  to the gas
    flow.  One of the main advantages of this is that the scope of the
    inspection can be limited to specific  conditions, if any,  which are
    symptoms of operating problems.  Thus, process equipment would
    be inspected only if it had been determined that process changes
    were the likely cause of control system performance shifts.  In
    many  cases, this approach will minimize both the inspector's time
    and the inconvenience to operator personnel.

4.   Judgement of the inspector is the most important factor.

    Effective inspection of air pollution control systems goes beyond
    simply filling out a checklist. Because of the diversity of control
    system designs and differences in the degree  of maintenance, it is
    important that the inspection procedure not be rigid.  Maintaining
    this flexibility requires the inspector  to continually exercise
    judgement, both in determining how to proceed  with the
    inspection and in interpreting the symptoms observed.
                    1-2

-------
                           1.4  LEVELS OF INSPECTION
Introduction         It is desirable to conduct detailed engineering-oriented inspections at
                    all sources.  This is obviously impractical, however, since large
                    numbers of air pollution sources must be inspected regularly, and
                    Agency manpower and resources are  limited.  To give control agencies
                    the opportunity to properly allocate limited resources, four levels of
                    inspections have been designed.

                    The levels of inspection are denoted as I through IV with the intensity
                    of the evaluation increasing numerically. The types of activities
                    normally associated with each level and the experience levels
                    necessary to conduct the different levels vary substantially.

                    The most complete and time-consuming evaluations are done only
                    when preliminary information indicates that there is or soon will be a
                    significant emission problem.

Level I inspections   The Level I inspection is a field surveillance tool intended to provide
                    relatively  frequent but very incomplete indications of source
                    performance.  No entry to the plant grounds is usually necessary and
                    the inspection is never announced in advance. The inspector makes
                    visible emission observations on all stacks and vents which are visible
                    from the plant boundary and which can be properly observed given
                    prevailing meteorological conditions.  Odor conditions are noted both
                    upwind and downwind of the facility.  General plant operations are
                    observed to confirm that these conform to permit requirements.
                    Unusual conditions provide the stimulus for an in-plant inspection in
                    the near future. If the visible emission observations and/or other
                    observations will probably result in the issuance of a notice of
                    violation,  the information should be transmitted to source
                    management personnel immediately.

Level II inspections  The Level II inspection is a limited "walk through" evaluation of the
                    air pollutant source and/or the control device. Entry to the facility is
                    necessary.  The inspection can be performed either in a co-current or
                    countercurrent fashion depending on the anticipated types of
                    problems. In either case, the inspection data gathered are limited to
                    that which can be provided by on-site, permanently-mounted
                    instrumentation.  An important aspect of this type of inspection is the
                    evaluation of the accuracy of the data from this instrumentation.
                                        1-3

-------
Level HI
inspections
 When control devices are not in service during the plant inspection,
 the Level II inspections can include checks on the internal conditions.
 This is particularly useful for the evaluation of fabric filter
 performance. The inspection involves observations from access
 hatches and under no circumstance includes entry into the collector by
 the inspector.

 The more detailed and complete Level III inspection may be
 conducted when the Level I data and/or the preliminary observations
 during Level II  inspections indicate problems. Where necessary,
 portable gauges provided by the inspector are used to measure certain
 operating parameters. The types of instruments generally used
 include:
Level IV
inspections
     •   static pressure gauges;
     •   thermocouples and thermometers;
     •   oxygen and carbon dioxide monitors;
     •   pH meters; and
     •   pitot tubes.

The Level III inspection includes a detailed evaluation of stack
effluent characteristics, CEM monitoring data, control device
performance parameters, and  process operating conditions.  Raw
material and fuel analyses  may be reviewed and samples of the
scrubber liquor may be obtained for later evaluation. Failed bags or
electrostatic precipitator discharge electrodes may be obtained to
confirm that the plant has  correctly identified the general type of
problem(s).  In some cases, the Level III inspection will include an
evaluation of the internal portions of an air pollution control device.
This is done simply be observing conditions from an access hatch and
under no circumstances should include entry of the inspector into the
control device. The internal checks are included only when the  unit is
locked off line or when one or more compartments can be safely and
conveniently isolated for evaluation.

The Level IV inspection, identical in scope to the Level III procedures,
is done explicitly to gather baseline information for use later in
evaluating the performance of the specific sources at a given facility.
This type of inspection should be done jointly by a senior inspector
and the Agency personnel who will be assigned responsibility for the
plant.  Such inspections are done in conjunction with stack tests of
major sources such as large electrostatic precipitators, scrubbers, and
fabric filters.  With smaller sources which are rarely tested, the Level
IV  inspection is done during a period when source personnel believe
that the source is in  compliance and the control device is working
properly.
                                        1-4

-------
                     An important part of the Level IV inspection is the preparation of
                     general process and control device flowcharts. These should be
                     prepared in accordance with published guidelines.  As a starting point,
                     the inspector should request the block flow diagrams or drawings for
                     the portions of the  plants which are of interest. Specific flowcharts
                     should be prepared so that all of the important information
                     concerning process  flow streams, measurement ports, locations of
                     vents and bypass stacks, and locations of all control devices is clearly
                     shown.
                       1.5  LEVEL II SOURCE INSPECTIONS
Introduction
General
information
A Level II inspection involves an on-site evaluation of the control
system and relies on plant instrumentation for the values of any
inspection parameters.

Since this is the type of inspection most commonly conducted by
Agency personnel, additional information is provided in this, and
subsequent sections.

    The scope of the Level II inspection should be limited to
    absolutely essential operating parameters and conditions necessary
    to evaluate compliance status and/or to evaluate progress toward
    compliance.

•   The Level II inspection should require a maximum of 4 hours on
    site.  Small sources should require less time.

•   The inspection form should be identical to the inspection report
    form.  Preparation  of the report should require less than 1 hour
    even for major sources.

    While on site, it should be possible for inspectors to compare
    inspection data against site-specific baseline data and industry
    "norms".  The inspection form should help inspectors determine
    the follow-up information needed to evaluate the adequacy of
    source operation.

•   The inspection procedures and inspection form should include a
    checklist to help inspectors conduct a complete and consistent
    inspection. However, the form must allow for flexibility so that
    inspectors can exercise professional judgement while performing
    the inspection.
                                        1-5

-------
Safety
considerations
Limitations
    Evaluation of the accuracy of certain on-site instruments must be
    completed before data from the instruments is recorded in the
    inspection notes and report.

    Nothing should be done which jeopardizes the health and safety of
    the inspector and/or the plant personnel.

    Under no circumstances should a regulatory agency inspector
    enter any air pollution control device or any process equipment.

    The inspection is intended to evaluate progress toward compliance
    and to identify abnormal operating conditions which may be
    indicative of excessive emissions. It is not intended to provide a
    definite measure of the pollutant emission rate.  This can only be
    determined by means of the promulgated reference method test.

    Due to the complexity of interrelated performance variables and
    the lack of on-site inspection time, it is generally impractical for
    the inspector to positively identify the specific operating problem
    causing excess emissions.  The inspection is inherently limited to
    the determination of the general type of problem or problems
    which exist.

    The inspection does not provide a specific list of repairs and/or
    modifications necessary to achieve compliance with applicable
    emission regulations.

    The Level II inspection is limited to the observations which can be
    made by the inspector and any data which can be obtained for
    plant instruments. These instruments can include permanently
    mounted gauges on the plant equipment or portable instruments
    used by plant personnel while the inspector is present.
                 1.6 COMPONENTS OF THE CONTROL SYSTEM
Introduction
Control of air pollution emissions usually involves a system that
employs several components to accomplish its task.  The system begins
with the collection of contaminants from the area of generation and
continues through ductwork and assorted system components until the
cleaned gas stream is discharged through a vent or stack to the
outdoor air.
                                        1-6

-------
Components
An air pollution control system includes the following:

     •   Contaminant capture (hoods)

     •   Transport (ductwork)

     •   Gas stream cleaning (control devices)

        Air moving (fan)

     •   Instrumentation (controls and monitors)

     •   Other activities (gas cooling, chemical feeding, waste disposal,
        etc.)

The components of a control system are usually divided into two
groups: (1) the air pollution control device, and (2) its ancillary
equipment.

Figure 1-1 illustrates a typical air pollution control system

Contaminated air is captured by a series of hoods located over
operations which are the source of contamination. The captured
contaminants are conveyed through a branched ductwork system to
the control device. Dampers control the flow from each hood. The
fan draws the gas flow through the hoods, ductwork and control device
and discharges it into a stack and on to the atmosphere.
                                                             Contaminant
                                                             removal
                    Figure  1-1.  Typical air pollution control system

-------
                          1.7  ANCILLARY COMPONENTS
 Containment
 capture
Level II inspection
points
Transport
Level II inspection
points
The objective of this system component is to effectively capture (with
minimum air flow into the system and minimum pressure loss on
entry) the contaminants  being released from a source. Optimization
of both air flow and pressure loss reduces fan horsepower and
operating costs and the size and cost of the control device and its
ancillary equipment.

    Capture efficiency: visual evaluation of fugitive losses as indicated
    by escaping dust or refraction lines.

•   Physical condition: hood modifications or damage that could
    affect performance; evidence of corrosion.

•   Fit of "swing-away" joints:  evaluation of gap distance between
    hood system and duct system on movable hoods.

•   Hood position/cross-drafts:  location of hood relative to point of
    contaminant generation; effect of air currents on contaminant
    capture.

The duct system transports  the contaminated gas stream between
other components in the control system.  The design objective is to
select duct and fitting sizes  that provide optimum conveying velocities
while minimizing friction and turbulence losses.

•   Physical condition: indications of corrosion, erosion or physical
    damage; presence of fugitive emissions.

•   Position of emergency dampers:  emergency by-pass dampers should
    be closed and not leaking.

•   Position of balancing dampers: a change in damper positions will
    change flow rates; mark dampers with felt pen to document
    position for later inspections.

    Condition of balancing dampers:  damper blades can erode and
    change system balance;  remove a few dampers to check their
    condition.
                                        1-8

-------
Air moving
Level II inspection
points
Instrumentation
Level II inspection
points
The purpose of the fan is to move the gas stream through the air
pollution control system.  To do this, the fan must be sized for the
proper air flow and must be able to overcome acceleration and
entrance losses at the hoods and friction losses in the ductwork, the
control device and other system components.

The fan may be positioned upstream or downstream of the control
device. A downstream fan position creates a negative pressure  at the
control device, drawing air in through any cracks or openings and
minimizing leakage of contaminants.  However, if the openings are
excessive, in-leakage may diminish the required capture velocity at the
source, allowing emissions to escape. When the fan is located
upstream of the control device, a positive pressure is created that
permits contaminants to escape through cracks or holes in the  casting
or connecting ductwork.

•   Physical condition: indications of corrosion.

•   Vibration: indications of balance problems due to material build-
    up or wheel erosion or corrosion; severely vibrating fans are  a
    safety hazard.

•   Belt squeal: squealing belts under normal operation indicate  a loss
    of air volume.

•   Fan wheel build-up/corrosion:  internal inspection of non-operating
    fans.

•   Condition of isolation sleeves:  check vibration isolation sleeves for
    holes.

•   Rotation direction:  check rotation direction with direction marked
    on fan housing.

Operating controls are important to the function  of the air pollution
control system and may directly affect its performance.  For example,
changing the timing cycle on a fabric filter cleaning system may cause
pressure loss to increase, reducing the air flow from the fan and
allowing emissions to escape at the source.

•   Physical condition:  indications of excessive wear, obvious signs of
    failure or disconnected controls.

•   Set-point values:  changes in set-point values for temperature, pH,
    rapping intensity, air pressure and other controllers may affect
    system performance.
                                         1-9

-------
Other components
Level II inspection
points
    Timer settings: check for changes in cleaning cycle, chemical
    delivery cycle and other timer settings.

•   Emission monitors:  evaluate general condition and siting; have
    operator check zero and span values; review historical data.

There can be many other components in an air pollution control
system,  including such items as chemical feed systems and catalyst
regeneration units.  A component found with all of the dry collection
devices  is a dust handling system.  This component is responsible for
removing the collected particles from the control device and conveying
them to the final disposal site.  Common to such systems are a
collection hopper, a dust transfer valve and the piping or conveying
equipment.

Many control systems capture gases that are too hot to introduce
directly to the control device. In these systems, a component for
cooling  the gases will be found. This cooling may be accomplished  by
diluting the hot gases with cooler air, by evaporating water into the
hot gas  stream or by radiation and convection to the atmosphere.

Solids handling:

    •   Physical condition:  indications of hopper corrosion or physical
        damage; condition of level detectors, heaters, vibrators,
        insulation, etc.

    •   Discharge valve:  check  for presence and operating status and
        indications of air leakage.

    •   Solids discharge  rate:  rate of solids discharge should be
        reasonable.

Gas cooling:

    •   Physical condition:  indications of corrosion, erosion or
        physical damage; presence of fugitive emissions.

    •   Outlet temperature:  observe plant instruments to determine
        cooler effectiveness; if controller is used, compare to set-point
        value.

    •   Spray pattern/nozzle condition: indications of effective
        atomization on evaporative coolers.
                                         1-10

-------
       Water flow rate: observe plant flow meters or pressure gauges
       to evaluate changes in water flow rate on evaporative coolers.
 1.8 CLASSIFICATION OF AIR POLLUTION CONTROL DEVICES
Control devices:

    •   Separate contaminants from a gas stream and then remove
       them without re-entrainment, either continuously or
       intermittently, to a disposal system; or

    •   Change the contaminant from offensive to inoffensive; or

    •   Both separate and remove, and change contaminants from
       offensive to inoffensive.

Control devices can be classified according to the contaminants they
are typically used to remove:

    •   Particles  only

           Settling chamber
           Fabric filter
           Electrostatic precipitator
           Cyclone

    •   Gases only

           Wet collector
           Adsorber
           Incinerator

    •   Vapors only

           Condenser
           Incinerator

    •   Particles, gases and vapors

           Wet collector
           Incinerator
                  1-11

-------
                                1.9  FABRIC FILTERS
General
information
                     Fabric filters remove particles by passing the contaminated gas stream
                     through a woven or felted fabric, usually in a cylindrical configuration.
                     Depending on the direction of gas flow, particles are deposited on
                     either the inside or outside of the cylindrical "bag".  Initially, such
                     forces as impaction,  diffusion and electrostatic attraction are primarily
                     responsible for particle capture by the fabric fibers.  However, as the
                     dust coats the filter and increases in thickness, direct sieving begins to
                     dominate.

                     As the thickness of the dust-cake increases, so does  the pressure lost
                     in moving the gases across the filter.  To keep pressure loss
                     reasonable, it is necessary to periodically clean the fabric.  The three
                     most popular cleaning  methods are shaking, reversing air flow
                     direction and pulsing with compressed air.
Cleaning methods

Shaker-cleaning
                     A typical shaker-cleaning collector is shown in Figure 1-2.  The dirty
                     gas stream enters the hopper area and then moves across a tube-sheet
                     to the inside of the filter tubes.  The gas stream passes through the
                     filter, depositing the particles on the inside. When it is time to clean
                     the fabric, the collector is isolated from air flow and the bag shaken
                     by moving the supports from which  the bags are hung. The dust drops
                     into the hopper where it  is  removed through a dust discharge valve.

Reverse-air-cleaning   The reverse-air-cleaning collector (Figure 1-3) is nearly identical in
                     appearance to the shaker, except the bags are hung from rigid
                     supports.  Cleaning is accomplished by isolating the collector from the
                     dirty gas flow and introducing clean gas flow in the reverse direction.
                     This  reverse flow dislodges the dust which  falls into the hopper.  At
                     this point the cleaning air is quite dirty, so it is ducted to an operating
                     unit for cleaning. Thus, a reverse-air collector requires  a minimum of
                     two units.
                                        1-12

-------
   Clean air
   outlet
Dirty air
Clean air
tide
                                                              Filler bags
                                                              Cell pi,
         Figure  1-2.  Shaker-cleaning fabric niter
                               1-13

-------
Figure 1-3.   An example of a large reverse-air fabric filter
             (Courtesy of MikroPul Corporation).
                           1-14

-------
Pulse-cleaning
Level II inspections

Inspection activities
Figure 1-4 shows a typical pulse-cleaning collector.  Cylindrical bags
are suspended from a tube-sheet located near the top of the collector,
and the dirty gas flow is directed through the outside of the bags and
up through the center to the clean gas discharge.  Metal cages are
placed inside the bags to prevent collapse.  Cleaning is accomplished
by directing a pulse of compressed air into the top of the bag and
against the dirty gas flow. This pulse momentarily dislodges the dust
from the outside of the bag and slowly works it down toward the
hopper.  Bags are usually cleaned one row at a time without isolating
the collector from the dirty gas flow.
    Method 9 observation of the baghouse discharge.

    Method 9 observation of fugitive emissions from baghouse solids
    handling operation (if reentrainment is occurring).

    Method 9 observation of fugitive emission from process
    equipment.

    Counterflow checks of audible air infiltration into fan, baghouse
    (solids discharge valve, access doors, shell) and ductwork.  Also
    check physical condition and location of hoods.

    Static pressure drop across baghouse using on-site gauge; compare
    with baseline data.

    Comparison of compressed air pressures at baghouse reservoir
    with baseline values. Check for audible leaks of compressed air at
    fittings.

    Check operation of diaphragm valves, record number of valves
    which do not appear to be working properly.

    Check inlet gas temperatures using on-site gauge.

    Observe and describe  corrosion of baghouse shell and hoppers.

    Evaluate bag failure records, gas inlet temperature records,
    pressure drop data, and other maintenance information.
                                        1-15

-------
Figure  1-4.  Pulse-cleaning fabric filter
              1-16

-------
Performance
evaluation
Safety considerations
    Visible emissions greater than 10% from the baghouse indicate
    poor performance. Inspection should include evaluation of bag
    problems, including but not limited to abrasion, chemical attack,
    ember damage, high temperature damage, and improper cleaning.
    A rip test should be done on  failed bags unless quantitative fabric
    tests have been performed. If conditions appear to be severe, a
    Level HI inspection (primarily clean side checks) is warranted.

    Fugitive emissions from all process sources should  be carefully
    documented.  Reasons for poor capture should be  investigated,
    including, but not limited to, air infiltration, poor hood condition
    or location, fan belt slippage (listen for squeal), fabric blinding
    and poor cleaning effectiveness.  The static pressure drop data and
    cleaning system performance checks (compressed air pressures,
    conditions of diaphragm valves and frequency of cleaning) are
    very important.

    The counterflow check of the entire system for air  infiltration is
    very important since this can generally lead to severe problems.

    The Level II inspection involves some climbing and close contact
    with the pulse jet baghouse.  Check the integrity of all supports
    and ladders. Climb ladders properly.  Avoid contact with hot
    ducts and roofs.  Avoid downward pointing gas discharge points.

    Since  the inspector must enter the facility to make  a
    Level II inspection, all normal safety precautions apply.
                 1.10 ELECTROSTATIC PRECIPITATOR'S (ESPs)
General
information
Electrostatic precipitators remove particles from a contaminated gas
stream by employing the principle of attraction of opposite charges.
The particles are charged in a high voltage electric field created by a
corona discharge electrode and are then attracted to a collection plate
of opposite charge (see Figure 1-5).  When the particles reach the
collection plate they slowly lose their charge through conduction,
ideally retaining just enough charge to hold the particles to the plate
but not so much that it inhibits further deposition or makes removal
difficult.  Periodically, the plate is vibrated or rapped and the dust
drops into the hopper.
                                       1-17

-------
Level II inspections

Inspection Activities
                     The electric field is powered by direct currents supplied from
                     transformer-rectifier (T-R) sets mounted on the roof.  Each T-R set
                     serves one or two fields or electrical sections. Efficiency of collection
                     is usually highest when the voltage is highest. Most industrial ESPs
                     operate with a negative corona because of its stability under high
                     voltage  conditions.  Peak performance is indicated by the beginning of
                     sparking from electrode to plate.

                     The plates are generally rapped by hammer mechanisms mounted
                     outside  on top of the housing.  In some designs the rappers are
                     located  inside the housing and cannot be seen by the inspector.  Also
                     located  on top of the housing will be vibrator units for keeping the
                     discharge electrodes clean.

                     The electrostatic precipitator looks very much like a fabric filter, i.e.,  a
                     large box-shaped structure with hoppers beneath it.  However, the
                     ESP is distinguished by the rapping mechanisms and transformer-
                     rectifier sets mounted on top of the housing and by inlet/outlet
                     locations that are generally on the ends (see Figure 1-6).
Method 9 observation of the stack discharge.

Timing, duration and pattern of intermittent puffs.

Characteristics of any detached, condensing or reactive plumes.

Physical conditions of transmissometer transmitter and
retroreflector.

Transmissometer zero and span values, status of window lights.

Transmissometer strip chart data

Precipitator electrical set data, including plots of the secondary
voltages, secondary currents,  and spark rates for each chamber
starting with the inlet field and proceeding to  the outlet field.

Process operating data.

Transmissometer strip chart records and electrical set  records.
                                        1-18

-------
                          Charging fjc|J
           Charged (-)
           particles
                                                                          Collecting
                                                                          baffle
         Rippen
Collection
eleeirode
                                                        Grounded (4
                                                        collecting surface
                          Dhchargc
                          electrode
                          tension weight
                         Figure   1-s.  ESP collection schematic
                                                                         .Transformer-rectifier ff-R)
                                                                                     electrode
                      Figure   i-«.  Electrostatic precipitator
                                          1-19

-------
Performance
evaluation
Safety considerations
    An increase of more than 5% opacity in the visible emission since
    the baseline period or visible emission within 5% opacity of the
    regulatory limit warrant a Level III inspection.

    If the data indicate the unit is operating in moderate or high
    resistivity conditions, the power input should be computed and
    compared against the baseline values.

    The secondary (or primary) voltages  should be compared with the
    baseline values.

    The field-by-field electrical data plots should be compared with
    baseline plots.

    The transmissometer strip charts should be analyzed for
    characteristic patterns of operating problems.

    Inspectors should be trained in safety procedures prior to using
    stack elevators to reach  transmissometers mounted on stacks.

    All ladders and platforms should be checked before use.  Safe
    ladder-climbing practices are  necessary.

    Poorly ventilated areas around expansion joints, flanges and other
    areas must be avoided.
                1.11 CYCLONES/MULTI-CYCLONE COLLECTORS
General
information
Cyclones

Single cyclones
In a cyclone, the dirty gas stream is directed into a cylindrical shell,
either through a tangential entry or through turning vanes.  The result
is a confined vortex in which centrifugal forces drive the entrained
particles toward the outside wall. Particles successfully deposited slide
down the wall and into the hopper from which they are removed
through a dust discharge valve.
Cyclones can be constructed in either single or multiple configurations.
Single cyclones are generally characterized as either high efficiency or
high throughput (see Figure 1-7). High efficiency cyclones have a
narrow inlet opening in order to attain high inlet velocity, a long body
                                        1-20

-------
Multi-cyclones
Level II inspections

Inspection activites
Performance
evaluation
length relative to its diameter and a small outlet diameter/body
diameter ratio.  High throughput cyclones, which are inherently less
efficient, have larger inlet openings, a shorter body length and larger
gas exits.

Multi-cyclones have numerous small diameter (typically 15-23 cm (6"-
9") cyclone tubes in parallel inside a single housing (see Figure 1-8).
Each cyclone is  mounted into a  lower "tube-sheet" which separates the
in-coming dirty gas stream from the hopper level below.  The outlet
tube from each cyclone extends  up  through  the in-coming dirty gas
stream and into an upper tube-sheet that separates the dirty gas from
the cleaned gas.

Cyclone efficiency is very sensitive to particle size, with performance
deteriorating rapidly for particles less than about 2-5 jum diameter.
When particle size  distribution and gas flow rate are relatively
constant, changes in pressure drop across a  cyclone provide a good
indicator of changes in collection efficiency.
    Method 9 observation of the stack for a sufficient period to fully
    characterize conditions during normal process cycles.

    Method 9 observation of any fugitive emissions from process
    equipment, material handling operations, and stockpiles.

•   Air infiltration sites on collector shell, hopper, solids discharge
    valve, and inlet ductwork.

    Static pressure drop across collector as indicated by on-site gauge.

    Inlet gas temperature as indicated by on-site  gauge.

•   If the visible emissions have increased more than 5% opacity since
    the baseline period or if the visible emissions are within 5% of the
    regulatory limit, a Level II or Level III inspection is necessary.

    Fugitive emissions from the process area can be at least partially
    due to air infiltration into the ductwork or collector. The process
    area and ductwork should be checked in any  subsequent Level II
    or  III inspections.
                                        1-21

-------

     Hijjli efficiency     High ihroughpul
Figure   1-7.  Single cyclone collectors
      Figure  1-8.  Multi-cyclone
                    1-22

-------
Safety considerations
    The static pressure provides an indication of the flow rate and the
    resistance of gas flow.  The static pressure should be checked
    against baseline static pressure drops for similar process operating
    rates. If the present value is higher, then pluggage is possible.  If
    the static pressure drop is now lower, erosion of outlet tubes and
    gasket problems are likely.

    Position selected for the Method 9 observations should be secure
    from moving vehicles such as cars,  trains, and moving machinery.

    There must be secure footing. Stockpiles are not acceptable.

    All climbing and walking safety procedures are very important.
    Some horizontal structures may not be able to withstand the load
    of accumulated solids and several people.

    Contact with hot surfaces must be avoided.

    Many multi-cyclone collectors are located in hot areas. Heat
    stress should be avoided by limiting the time spent in the area
    (moderate heat conditions) or by not entering the area (high heat
    areas).

    Poorly ventilated areas must be avoided.
                              1.12 WET SCRUBBERS
General
information
Wet collectors remove contaminants from a gas stream by transferring
them to some type of scrubbing liquid. For particles larger than about
1 urn, the dominant separation mechanism is impaction onto liquid
droplets or wetted targets.  For sub-micron particles and gases, the
dominant mechanism is diffusion to liquid surfaces. Because of
incompatible requirements, wet collectors are generally designed to
perform as either a particle or a gas collector. Simultaneous
collection of both particles and gases is usually possible only when the
gas has a very high affinity for the scrubbing liquid.

Contacting the contaminated gas stream with the scrubbing liquid is
only the first stage of a wet collector. Because the contact phase
usually results in liquid entrained in  the gas stream, the second stage
is some type of liquid-gas separator.  Common entrainment separators
include chevron baffles, mesh pads and single-pass cyclones.
Contactors producing large droplets may require only a little low-
velocity head-space to allow the droplets time to settle back into the
unit.
                                       1-23

-------
Wet collectors
Spray tower
Tray scrubber
Packed tower
Venturi scrubber
The almost endless variety of wet collectors makes it difficult to
include all types and varieties in one discussion. To illustrate the
range of designs and performance levels, four types of scrubbers will
be briefly described:  (1) a spray  tower, (2) a tray scrubber, (3) a
countercurrent packed tower and (4) a venturi scrubber.

A simple spray tower is illustrated in Figure 1-9.  The dirty gas stream
enters at the bottom of the scrubber and flows upward at velocities
between 0.6 and 3.0 meters (2 and 10 feet) per second.  The liquid
enters at the top of the unit through one or more spray headers, so
that all of the gas stream is exposed to the sprayed liquid.  A spray
tower has only limited particle removal capacity, and is  generally
selected for applications where the particles are larger than about  5
Mm. Spray towers can be effective gas absorbers if the contaminant
has a moderate affinity for the liquid.

A tray scrubber (see Figure 1-10) can also be used for both particle
and gas collection.  The gas stream again enters at the bottom and
passes upward through holes in the  trays.  The liquid enters at the top
and cascades across one tray and then flows down to the next. An
overflow weir is used  to maintain a liquid level on each tray.
Variations in tray design include the placing of assorted "targets"
above each hole to enhance the scrubbing action.  The tray scrubber is
an effective collector of particles larger than about 1 p.m and can be
an effective gas absorber when the contaminant has a moderately low
affinity for the liquid.

Packed towers are used primarily for gas absorption because of the
large surface area created as the liquid passes over the packing
material. The beds can be either vertical or horizontal.  The most
efficient arrangement is the vertical countercurrent packed tower
shown in Figure 1-11.  The gas stream again enters at the bottom and
passes upward through the packing. The liquid is sprayed from the
top and flows downward in a thin film over the surface of the packing.
The packed tower is an effective gas absorber when the contaminant
has a low affinity for the liquid.

A conventional venturi scrubber is shown in Figure 1-12.  The dirty
gas stream enters a converging section and is accelerated toward the
throat by approximately a factor of ten.  The liquid is injected into the
scrubber just beyond the entrance to the  throat, where the  liquid is
shattered into droplets by the high velocity gas stream.  Particles are
collected primarily by being impacted into the slower moving drops.
Following the contactor is usually a single-pass cyclone for
entrainment separation. The venturi scrubber is an effective collector
of particles down to the sub-micron range, comparable in performance
to the fabric filter or ESP, and can be an effective gas absorber when
the contaminant has a moderately high affinity for the liquid.
                                        1-24

-------

Figure  1-9. Simple spray chamber
           1-7S

-------
                                Clean
           Plain
Dirtj
                                                                Detail of plate
                        Figure MO.  Tray scrubber

                                   1-26

-------
                Clean
                                  MLst eliminator
                                  Water ipraji
                                     ^;.*.. Dirty
Figure   Ml. Countercurrent packed tower
                1-27

-------
    Dirtj gai
                                     Clean
Water »praji
  Figure  1-12.  Conventional venturi scrubber
                       1-28

-------
Level II inspections

Inspection activities
Performance
evaluation
Safety considerations
Method 9 observation of the stack for a period of not less than 6
minutes. Average opacity should be calculated. Cycles in the
average opacity should be described. •

Method 9 observation of all bypass stacks and vents. Method 9
observations of any fugitive emissions from process  equipment.

Presence of rainout close to the stack or mud lips at the discharge
point.

Presence of fan vibration.

The liquor flow rate indicated by on-site gauge.

Physical condition of shell and ductwork.

Recirculation pond layout and pump intake position.

Physical condition of nozzles observed through  access hatch.

Means used to dispose of purged liquor should be noted.

A shift in the average opacity may be due to  a  decrease in the
particle size distribution of the inlet gas stream. A  co-concurrent
inspection of the  process operation is often advisable.

Anything which affects the nozzles will reduce performance.  The
liquor turbidity is related to the vulnerability  to nozzle pluggage
and erosion.

Shell and ductwork corrosion is often caused  by operation at pH
levels which are lower than desirable. The liquor pH should be
measured using in-plant instruments if available.

The performance of a spray tower scrubber is dependent on the
liquor flow rate.  Any problems which potentially reduce the flow
rate should be  fully examined.

All ladders and platforms should be checked  before use.  Safe
climbing and walking practices  are important, especially in cold
weather.

Poorly ventilated areas should be avoided.

Hot duct and pipes should  not be touched.
                                        1-29

-------
                         The inspection should be terminated if a severely vibrating fan is
                         noted in the general vicinity of the scrubber.

                         Under no circumstances should the inspector attempt to look
                         inside an operating wet scrubber.

                         Visible emissions observations should be made only in secure
                         areas.
                          1.13  CARBON BED ADSORBERS
 General
 information
Level II inspections

Physical condition

Adsorption/de-
sorption cycle times

Steam pressure/
temperature during
desorption
Adsorbers remove gaseous contaminants from an air stream by
transferring them to the surface of some high-surface-area solid
adsorbent.  In air pollution control systems, adsorbers which use
activated charcoal as the adsorbent are typically employed to remove
volatile organic compounds.  Adsorption is most effective when the
system temperature is about 24°C (75°F) and the compounds have
molecular weights between about 45 and 200.

The most popular cleaning method is to introduce low-pressure steam
into the bottom of the bed to raise its temperature and cause the
contaminants to desorb from the carbon.  The mixed stream of
organic vapor and steam coming from the bed is condensed  and the
solvent recovered by decanting or distillation. Following desorption,
the bed is allowed to cool and dry before being put back on line.

A typical multi-bed adsorption system is shown in Figure 1-13.  Here,
the left two beds are on line and contaminated gas is passing vertically
down through each unit. As the system continues to operate, the on-
line beds approach saturation with the contaminants and must be
taken off line for  cleaning to prevent breakthrough of the organic
contaminant.  This condition is represented in the  right hand corner.
    Indications of corrosion or physical damage.

    An increase in the interval between bed cleanings could mean
    breakthrough is occurring.

    A decrease in steam pressure/temperature could indicate
    insufficient steam flow for regeneration.
                                        1-30

-------

              Adtorlicn on stream
                                               Adsorber
                                              Regenerating
Clean air
 cxhauil
             Figure   1-13.  Activated carbon adsorber
                            1-31

-------
                              1.14 INCINERATORS
Level II inspections

Physical condition


Outlet temperature


Temperature rise
                    Incinerators remove gaseous contaminants from an air stream by
                    oxidizing them to compounds not considered to be contaminants.  The
                    two most common types of incinerators are:

                        •   Direct-fired or thermal units, which are refractory-lined
                            chambers with a gas or oil burning apparatus plainly visible
                            (see Figure 1-14).

                        •   Cataytic units, which have the appearance of a duct heater
                            and are more highly instrumented (see Figure
                            1-15).

                    In both thermal and catalytic units, the principal parameter for
                    indicating efficiency is temperature, the value of which is dictated by
                    the characteristics of the contaminant to be  oxidized.  In thermal
                    units, the recommended minimum outlet temperature  is 704°C
                    (1300T); most systems operate in the 816-982°C (1500-1800T) range.
                    Catalytic units are generally designed for a bed inlet temperature of
                    371-482°C (700-900°F).
Indications of corrosion or physical damage; indication of air
infiltration.

Decreased outlet temperature may mean reduced VOC
destruction efficiency.

Decreased temperature rise across the catalyst bed may mean
reduced VOC destruction efficiency.
                               1.15 CONDENSERS
                    Condensers remove vaporous contaminants from a gas stream by
                    cooling it and converting the vapor into liquid.  In some instances,
                    control of volatile contaminants can be satisfactorily achieved entirely
                    by condensation. However, most applications require additional
                    control methods. In such cases, the use of a condenser reduces the
                    concentration load  on downstream control equipment. The two most
                    common types of condensers are:
                                       1-32

-------
Gaj burner
piping
                                         Refractory lined
                                             ihell
                                          Refractory ring baffle
Inlet for contaminated
aintrcam
           Figure   M4.  Direct-fired Incinerator
                             Hemt exchanger tuba
          Figure  MS.  Catalytic Incinerator

                             1-33

-------
Level II inspections

Physical condition

Outlet temperature
Liquid turbidity/
settling rate

Droplet re-
entrcanment
                             Contact or barometric condensers, where a direct spray
                             contacts the vapors to cause condensation (see Figure 1-16).
                             The liquid leaving the condenser contains the coolant plus the
                             condensed vapors.

                             Surface condensers, such as the shell-and-tube heat exchanger
                             (see Figure 1-17).  This device consists of a shell into which
                             the vapor stream flows. Inside the shell are numerous small
                             tubes through which the coolant flows. Vapors contact the
                             cool surface of the tubes, condense and are collected without
                             contamination by the coolant.
Indications of corrosion or physical damage.

Provides an indirect indication of the liquid flow rate and nozzle
condition; increases may indicate nozzle pluggage and lower
coolant flow rates; decreases may indicate nozzle erosion and
higher flow  rates (contact-type only).

High settling rate indicates coarse solids that could plug nozzles
(contact-type only)

Droplet rainout  or a mud-lip on the stack indicates a significant
demister problem.
                                                                 MLst eliminator


                                                                 Spray nozzle?
 Figure   1-16.  Contact condenser
                                         1-34

-------
cliaiincl
 cover
          Reversing channel
                                                       Inlet
                                                      channel
                                                                             RcmovaMc
                                                                              channel
                                                                               covxrr
                       Figure   1-17.  Surface condenser
                                 1-35

-------
THIS PAGE LEFT BLANK
        1-36

-------
                      APPENDIX 1-A. SAFETY GUIDELINES
1.     Do not do anything which you feel is dangerous.  Do not ask plant personnel to do
      anything which either you or the plant personnel believe could be unsafe.

2.     Interrupt the inspection immediately whenever you feel any of the symptoms of
      possible exposure to pollutants.  These include, but are not limited to:  headache,
      nausea, dizziness, drowsiness, loss  of coordination, chest pains, shortness of breath,
      vomiting, and eye, nose, or throat  irritation.

3.     Conduct the inspection at a controlled pace.  Do not hurry.

4.     Avoid areas of possible risk during the inspection if the necessary personal
      protection equipment is not available.

5.     Do not make internal inspections of air pollution or  process equipment under any
      circumstance.

6.     Do not wear contact  lenses during the inspection unless specifically allowed by
      both agency and source safety personnel.

7.     Avoid areas with potentially high pollutant concentrations which could exceed PEL
      levels and/or the capabilities of the available respirators.  Such areas are common
      around positive-pressure equipment and areas with many process stacks and vents.

8.     Use only intrinsically-safe portable instruments when inspection locations are
      classified as hazardous.

9.     Exercise extreme caution  when walking across roofs and elevated platforms.
      Weak spots are not always apparent.  Walk behind plant personnel. Avoid roofs
      whenever possible.

10.    Evaluate means for rapidly leaving elevated roofs or platforms in the event of
      sudden plume downwash  or process fugitive emissions of high-temperature steam
      or toxic gases.

11.    Do not smoke while conducting inspections.

12.    Discard or wash contaminated work clothes separately from personal clothing.

13.    Know the meaning of all  plant warning sirens/codes  and know the proper
      evacuation routes.
                                       1-37

-------
14.   Avoid areas of dripping and/or splashing chemicals. Flush eyes for at least 15
      minutes as soon as possible after contact.  Get medical attention.

IS.   Remove all affected clothing and shower immediately for a period of at least 15
      minutes if there is contact with chemicals. Get medical attention.

16.   Exit areas around severely vibrating fans immediately.  Notify plant personnel
      immediately of this  condition.

17.   Conduct plant inspections only in the company of a responsible plant
      representative.

18.   Wear gloves whenever climbing ladders which are possibly hot, covered with small
      quantities of contaminants, or which have abrasive and/or sharp edges.

19.   Do not climb unsafe ladders.  Exercise care in climbing. Both hands must be free
      for holding the ladder. Grasping of the foot rungs rather than the side rails is
      normally recommended by industrial safety personnel.

20.   Avoid all rotating equipment which is  improperly shielded.

21.   Use grounding and bonding cables  when obtaining samples of flammable liquids.
      Comply with all  regulations regarding  flammable liquid sampling and shipping.

22.   Stand clear when plant personnel are opening any hatches.

23.   Ask plant personnel to obtain any samples needed.

24.   Wear splash goggles whenever dripping chemicals are possible.

25.   Comply with all  plant and agency safety requirements.
                                        1-38

-------
  APPENDIX 1-B.  RECOMMENDED LIST OF INSPECTION EQUIPMENT
                        GENERAL EQUIPMENT

Camera, film, and flash equipment

Pocket calculator

Tape measure

Clipboard

Waterproof pens, pencils and markers

Locking briefcase

Plain envelopes
                                            •
Polyethylene bags
                                            •
Wind meter or Admiral  Beaufort wind scale
                                            •
Ruler (for use as scale in photos)


                         SAFETY EQUIPMENT

Safety glasses or goggles

Face shield
                                            •
Coveralls, long-sleeved

Hard hat

Plastic shoe covers (disposable)

Self-contained breathing apparatus
Disposable towels or rags

Flashlight and batteries

Pocket knife

Pocket tape recorder

Level

Range finder/optical tape
measure

Compass

Stopwatch

Square
Rubber-soled, metal toed,
non-skid shoes

Liquid-proof gloves
(disposable if possible)

Long rubber apron

Respirators and cartridges
                                 1-39

-------
                       APPENDIX 1-B.  (Continued)

                              PAPERWORK

Proper identification                            •     Checklists

Copy of facility's inspection file,                 •     Notebook
permit, and monitoring schedule,
including:                                      •     Notice of inspection (if
                                                    applicable)
-  maps
-  photographs                                 •     Chain of custody
-  enforcement actions

Field data sheets
                                   1-40

-------
                 EXHIBIT 1-C.  BASELINE AIR POLLUTION QUIZ
1.  True or false? The Baseline Inspection Technique involves detailed internal        1.
    inspections of the control systems.

2.  True or false? Control systems designed by the same manufacturer and             2.
    operated under similar conditions can be assumed to operate in a similar
    manner.

3.  If a canopy hood has a capture efficiency of 80 percent, the overall efficiency        3.
    of the air pollution control system must be:

    a.   less than 80 percent.
    b.   no greater than 80 percent.
    c.   unable to be calculated.
    d.   at least 75 percent.

4.  If the fan is located after the air pollution  control device, the static pressure         4.
    plot should:

    a.   show static pressure steadily becoming less negative with measurements
        taken closer to the fan.
    b.   remain essentially level.
    c.   reflect sharp changes in pressure depending on the direction of the
        ductwork.
    d.   become progressively more negative with measurements taken closer to
        the fan.

5.  Bags in a reverse air unit are cleaned in the following manner:                     5.

    a.   bag by bag.
    b.   row by row.
    c.   compartment by compartment.

6.  True or false? Both very high and very low gas inlet temperatures can              6.
    contribute to excess emissions  and/or bag failure rates.

7.  In an ESP,	are used to control the strength of the electric field                7.
    generated between the discharge and collection electrodes.

    a.   rappers
    b.   transformers-rectifier sets
    c.   capacitors
    d.   adsorbers
                                        1-41

-------
8.  Rappers are:                                                                  8..

    a.   commonly used for removing dust from discharge and collection
        electrodes.
    b.   commonly used for removing dust from collection electrodes only.
    c.   a type of capacitor used to store discharge electrode voltage.

9.  True or false? Increases in gas velocity result in more reentrainment of            9..
    particles during rapping.

10. Particle collection efficiency in a cyclone depends upon a number of factors         10.
    including:

    a.   cyclone dimensions.
    b.   inlet gas velocity.
    c.   particle size.
    d.   dust concentration.
    e.   all  of the above.
    f.   a, b, and c only.

11. Multi-cyclone collectors have a	static pressure drop than large-diameter      11.
    cyclones.

    a.   higher
    b.   lower

12. Wet scrubbers are pollution control devices that use a liquid to remove             12.
    	from an exhaust gas stream.

    a.   particles
    b.   pollutant gases
    c.   both a & b
    d.   none of the above

13. Symptoms of poor thermal incinerator burner performance include:                 13.

    a.   blue smoke generation.
    b.   higher than normal outlet temperatures.
    c.   lower-than-normal outlet  temperatures.
    d.   lower-than-normal VOC outlet concentrations.

14. When complete combustion of a gas containing only organic compounds
    occurs,	are the products  formed.                                           14.

    a.   NO, and SO,
    b.   H2O2andC02
    c.   NO3 and H2O
    d.   CO2 and H2O

                                       1-42

-------
                                 CHAPTER 2

          2.0  HAZARDOUS MATERIALS/HAZARDOUS WASTE
                        INSPECTION PROCEDURES
                              2.1  INTRODUCTION
Purpose
Inspector
responsibilities
The primary purpose of this section is to provide procedural and
technical guidance for performing inspections of those facilities which
use hazardous materials or generate hazardous wastes. The procedures
are general and are not intended to be prescriptive.

Inspectors should be aware of all Federal, State, local, and
international regulations a facility must meet in order to be in
compliance. No matter what the reason for the inspection, it must be
performed in a manner which is both technically and legally correct.
Flaws in either the technical or legal conduct of an inspection may
hamper, prevent, or invalidate the use of inspection results for
enforcement purposes.

Two overriding criteria must guide the conduct of inspections to insure
that inspections optimally fulfill their role in enforcement:

1.  Technical accuracy and integrity

    Inspections must be technically correct. Any  measurements or
    other data collection and analysis must be thorough, technically
    proper, and appropriately documented.

2.  Legal propriety

    Legal requirements concerning the conduct of inspections must be
    scrupulously followed.

It is important for inspectors  to know current enforcement priorities
and develop the specific skills necessary to perform the inspections
required under those priorities.  They also need to be aware of
changes in priorities and be flexible so such changes can be
accommodated.

In  accordance with contemporary program priorities, inspectors are
frequently assigned to concentrate on inspections of a particular type
of  facility or waste management practice.  As a result, inspectors will
develop specialized skills in inspecting that type of facility or practice
                                      2-1

-------
                     through training, research and experience.

                     It is important, however, that inspectors also maintain a good general
                     knowledge of the overall hazardous material/waste program so that
                     they can respond to new enforcement priorities or changes in
                     assignment which require them to inspect other types of facilities and
                     practices. To maintain knowledge, inspectors should review:

                         •  major new regulations as they are promulgated;

                         •  new and existing guidance on inspecting other types of facilities
                           and practices; and

                         •  new and existing technical guidance that could provide quick
                           background information on other types of facilities and
                           practices.
                         22  INSPECTION PREPARATION
Purpose
Objectives
Adequate preparation is critical to the effective performance of
hazardous materials/waste inspections. Generally, inspectors will have
only a relatively brief period of time on site in which to perform an
inspection; therefore, it is important that the inspection be properly
scoped and planned in order to use time  on site as efficiently as
possible and to insure that all aspects of the facility which should be
evaluated are inspected.

When preparing for the inspection,  inspectors should:

    • Determine  the scope of objectives  of the inspection.

    • Coordinate inspection activities with other regulatory or
      enforcement personnel as necessary.

    • Develop  a thorough understanding of the technical, regulatory,
      and enforcement aspects of the facility.

    • Develop  a plan or strategy for conducting the inspection
      consistent with inspection objectives.
                           Determine health and safety requirements and equipment
                           needs.
                                        2-2

-------
                     Activities the inspector should undertake to achieve these objectives
                     are discussed in the following sections.
                    2.3  HEALTH AND SAFETY REQUIREMENTS
Planning the
inspection
Special
considerations
Although routine inspections generally do not involve activities in
which inspectors must physically contact hazardous wastes (except
inspections involving sampling, in which incidental contact with wastes
may occur), there is always the potential for inspectors to be exposed
to hazardous wastes or substances during the course of an inspection.
Therefore,  in planning the inspection, inspectors should:

    • Determine the nature of the chemical hazards that may be
      encountered during the inspection (based on the types of
      materials handled on site, as identified in the file review).

    • Identify and obtain proper safety equipment.

    • Become familiar with the proper use of safety equipment (if not
      already familiar with its use), check equipment for proper
      function, and perform necessary maintenance on the equipment
      (if appropriate and within the technical abilities of the
      inspector).

    • Obtain and become familiar with  all applicable safety guidance
      and practices.

    • Determine any facility-specific safety requirements by contacting
      the facility  (only in cases where the facility is being notified of
      the inspection) or by review of previous inspection notebooks.

In some cases, the inspector will have limited information on the
facility, or may be inspecting an uncontrolled site.  The inspector
should be prepared to encounter the worst conditions in such cases.
Inspectors should never proceed with inspections involving site
conditions for which they are not prepared and do not have the
proper safety equipment.
                                        2-3

-------
                         2.4  INSPECTION EQUIPMENT
Select equipment
Ensure proper
functioning
Consider additional
equipment
The kind of equipment that the inspector takes into the field is
dependent on the kind of inspection to be performed and the type of
facility to be inspected.  Inspectors should use their knowledge of the
facility, understanding of inspection objectives, training, and
experience to decide which equipment is necessary for  a particular
inspection.  Inspectors may wish to consult with other inspection
personnel or their supervisor in determining equipment requirements.
Inspection requirements, the availability of certain equipment, and
Regional or State policies and conditions should also be considered
when selecting equipment during inspection planning.

Appendix 2-A provides a list of equipment that is commonly used in
performing inspections.  Inspectors may not need all of the equipment
listed for every inspection; however,  inspectors may need additional
equipment for some inspections.  The list is divided into four
categories of equipment:  general equipment, safety equipment,
sampling equipment, and paperwork.

The inspector should identify and obtain the equipment necessary to
perform the inspection from the appropriate source.  The inspector
should  check inspection equipment to insure that it is in good working
order prior to going into the field, and should perform, or have
performed by the appropriate agency personnel, any needed
maintenance or repairs.  The inspector should also insure that he or
she is familiar with the use of the equipment; generally, the use and
operation of most of the standard inspection equipment listed is
apparent.

Special circumstances may require the use of additional equipment
such as fireproof clothing or self-contained breathing apparatus.  The
inspector should determine whether  such additional equipment is
necessary in conjunction with his or her supervisor, and, if appropriate,
the facility's owner/operator or plant manager.
                     2.5  OPERATIONS, WASTE HANDLING, AND RECORD REVIEW
Initial interview
The inspector should have the facility representative describe facility
operations and waste management practices following the opening
discussion.  In general, tRe inspector should be familiar with the
facility through previous review of the facility's file. Therefore, the

                   2-4

-------
Record review
purpose of this discussion will be to:

    • Obtain a more detailed understanding of operations.

    • Answer any questions the inspector may have on waste
      generation, waste flow, and waste management activities.

    • Identify any changes in operating and/or waste management
      practices.

    • Identify and reconcile any discrepancies between the operations
      described by the facility representative and those described in
      the facility file.

During the discussion, the inspector should prepare waste information
sheets on each waste managed at the facility.

After discussing facility operations and waste handling practices,
inspections usually proceed to the record review.  The record review
provides the inspector with the opportunity to become thoroughly
familiar with the facility (e.g., through review of the operating record)
and formulate specific questions to be investigated during the visual
inspection of the facility. However, the record review does not have
to occur before the visual inspection.  In some cases, inspection
objectives may be best served  if the visual inspection occurs before the
record review.  The visual inspection may be performed first for other
reasons as well (e.g., availability of facility personnel or weather
conditions).

The regulated community must address administrative requirements
for manifests, recordkeeping, and reporting; and hazardous waste
facilities must  comply with technical requirements mandating plans for
waste analysis, training, contingency procedures, groundwater
monitoring, and closure.
                    2.6  GENERAL INSPECTION PROCEDURES
Follow inspection
plan/strategy
In general, the visual inspection of the facility should proceed in
accordance with an inspection plan or strategy developed by the
inspector during inspection planning.  This plan should lay out,  in the
level of detail considered appropriate by the inspector (which may
vary according to individual preferences), the operations the inspector
intends to inspect and the tentative order in which the inspection will
proceed. The inspector may, however, determine that it is appropriate

                   2-5

-------
Maintain control
Remain oriented
 to modify the plan based upon information obtained during the record
 review or other factors, such as the availability of specific personnel
 for interviewing or the scheduled operations of waste management
 units to be inspected.  Inspectors should be flexible in changing their
 planned approach to suit conditions encountered at the facility. Step-
 by-step procedures for visually inspecting a facility will vary according
 to the type of facility and the objectives of the inspection.

 When planning and performing the visual inspection, it is generally
 desirable that the inspection proceed in a way which allows the
 inspector to evaluate and understand the waste flow within the facility
 and to determine the compliance status of each segment of the
 facility's waste management system. For  example, in a plant which
 generates hazardous waste, stores waste for off-site disposal, and treats
 some waste on-site, the inspection could proceed as follows, in brief:

 Inspectors should not allow facility representatives to hurry the
 inspection, direct the route of the inspection, or prevent them from
 asking pertinent questions of facility personnel.  Inspectors should ask
 relevant questions of both the facility representative guiding them
 through the facility and of other personnel.  Questioning diverse
 personnel may identify inconsistencies in  explanations of procedures or
 operations that could indicate possible non-complying conditions that
 should be further investigated, and can also give the inspector  an
 indication of the adequacy of the personnel training program.
 Answers to questions and observations that are not reported on
 checklists should be recorded in a field log or notebook.

 Inspectors should be careful to remain oriented during the tour of the
 facility so that  they can accurately note locations of waste
 management areas, possible releases, potential sampling locations, etc.
 At larger facilities, inspectors should carry a map or plot plan in order
 to note locations and maintain their orientation.
                          2.7 INSPECTION CHECKLISTS
Pre-inspection
activities
As previously discussed, the inspector should complete as much of the
applicable checklist(s) as possible in the facility office, generally
during the record review, prior to .visually inspecting the facility
(unless the objectives of the inspection or other reasons  dictate that
the visual inspection occur before the record review).  The inspector
should leave blank those sections of the checklist(s) which cannot be
answered without visual inspection.
                                         2-6

-------
Inspection
activities
During the visual inspection, the inspector should complete these
sections. However, completing these sections is not the sole purpose
of the visual inspection, and it is critical that the inspector not limit
the visual inspection to only completing the checklist.  Inspectors
should be aware of, and investigate, all relevant waste generation and
management activities throughout the facility, and be alert to what is
happening around them as they tour the facility. If inspectors conduct
visual inspections in ways which allow them to understand how wastes
are generated, transported, and managed at the facility (as previously
discussed), they should be able to complete the applicable checklists
easily during the inspection.
                              2.8  WASTE SAMPLING
Reasons for
sampling
Sampling is generally conducted to verify the identity of a waste or to
identify potential releases of hazardous wastes or constituents to the
environment.
Inspection planning  If sampling is to be conducted during an inspection, the need to
                     sample will be determined or made known to the inspector during
                     inspection planning. The inspector should refer to  sampling manuals
                     during inspection planning to obtain information on preparing
                     sampling plans, taking samples, preserving samples, splitting samples
                     with the owner/operator, and completing chain-of-custody
                     requirements.
On-site activities
Reasons for future
sampling
In most cases, sampling will not be performed during routine
inspections. However, the inspector should be aware of, and identify,
potential sampling requirements that may need to be fulfilled in future
inspections, particularly in cases where the inspector has identified
potentially non-complying conditions or criminal activity during the
course of the inspection. In these cases, it is possible that case
development inspections will be performed at the facility, and it is
helpful when planning these inspections to have the results of previous
inspections in which potential sampling locations and needs have been
identified based on observed conditions at the facility.

There are many possible conditions or activities which may lead the
inspector to determine that future sampling will probably be necessary.
Examples of some of these conditions include situations in which:
                                   /

    • The  owner/operator is handling a potentially hazardous waste
      as a  non-hazardous waste.
                                        2-7

-------
                           (Sampling may be required to verify that the waste is hazardous
                           or non-hazardous.)

                         • In-plant waste handling practices indicate that
                           mislabeling/misidentification of waste is likely to occur, or that
                           wastes may vary significantly in characteristic over time and be
                           mismanaged as a result.

                           (Sampling may be required to demonstrate that the facility is
                           mislabeling or misidentifying wastes.)

                         • There is visible or other observable evidence of possible
                           releases of hazardous wastes from waste management units,
                           satellite storage areas, waste generating areas, etc.

                           (Sampling media and wastes may be required to demonstrate
                           that a release has occurred or is occurring.)

                         • Wastes may be being managed improperly, i.e., in an
                           inappropriate treatment or disposal unit.

                           (Sampling may be required to verify that the correct wastes are
                           being managed in the facility's various waste management
                           units.)

Useful information   Whenever such condition/activities are encountered, the inspector
for future            should identify the media or wastes to be sampled, the physical
inspections           locations to sample (e.g., the location of a possible release), the steps
                     within a treatment process to sample, the physical characteristics of
                     the medium to be sampled (e.g., sludge, granular solid), and other
                     relevant information that would be helpful in developing a sampling
                     plan  for a future inspection.
                              2.9  DOCUMENTATION
General
information
Documentation refers to all printed and mechanical media produced,
copied or taken by the inspector to provide evidence of suspected
violations.  It is strongly recommended that the inspector record
information collected during the inspection in only the following types
of records:  field notebooks,  checklists, photographs, maps, and
drawings.  Recording information on other loose papers  is
discouraged; loose papers may be easily misplaced and the
information on them discredited during hearings.  Proper
documentation and document control are crucial to the enforcement
                                        2-8

-------
                    system, as the Government's case in a formal hearing or criminal
                    prosecution often hinges on the evidence gathered by the inspector.
                    Therefore, it  is imperative that each inspector keep detailed records of
                    inspections, investigations, photocopies, photographs taken, etc., and
                    thoroughly review all notes before leaving the site.

Document control    The purpose  of document control is to assure the accountability of all
                    documents for the specific inspection when that inspection is
                    completed. Accountable documents include  items such as logbooks,
                    field data records, correspondence, sample tags, graphs, chain-of
                    custody records, bench cards, analytical records, and photos. To
                    ensure proper document control, each document should bear a
                    serialized number and should be listed, with  the number,  in a project
                    document inventory assembled upon completion of the inspection.
                    Water-proof ink should be used to record all data on serialized,
                    accountable documents.
                             2.10  FIELD NOTEBOOK
                    In keeping field notes, it is strongly recommended that each inspector
                    maintain a legible daily  diary or field notebook containing accurate
                    and inclusive documentation of all inspection activities, conversations,
                    and observations. Field notes should include any comments, as well as
                    a record of actual or potential future sampling points, photograph
                    points, and areas  of potential violation. The diary or field notebook
                    should contain only facts and observations because it will form the
                    basis for later written reports and may be used as documentary
                    evidence in civil or criminal hearings.  Notebooks used for recording
                    field notes should be bound and have consecutively numbered pages.
                    A separate notebook should be used for each facility inspected.
                                        2-9

-------
THIS PAGE LEFT BLANK
        2-10

-------
APPENDIX 2-A. HAZARDOUS MATERIALS/HAZARDOUS WASTE SAMPLING
                              EQUIPMENT
 Bucket auger

 Bucket

 Containers

 - jars
 - plastic (for metals)
 - organic sample containers

 Bailers

 Pumps

 Rope '

 Glass tubes

 Ice

 Scoops

 Trowels

 Tape

 - labeling
 - duct
 - electrical
Conductivity meter

Thermometer

Dissolved oxygen meter

Steel tape measure

Sampling safety equipment
(in addition to Appendix 1-B
items)

- Tyvek suit
- booties
- gloves
- harnesses
- chemical-resistant suit
- Organic Vapor Analyzer
   (OVA)

Decontamination
equipment

- buckets
- Alconox
- brushes
- grate
- deionized water
- solvents for equipment
   cleaning
- steam cleaning machine
- plastic bags
                                  2-11

-------
THIS PAGE LEFT BLANK
        2-12

-------
      APPENDIX 2-B. GENERAL SITE INSPECTION INFORMATION FORM
A.  Site Name                   B.  Street (or other identifier)
C. City                         D.  State
E. Site Operator Information

    1.  Name                               2.  Telephone Number
    3.  Street                               4.  City                  5.  State
F. Site Description



G.  Type of Ownership

1. Federal	     2. State	        3.  Municipal	       4.  Private	



H.  Site classification

1. Generator	  2.  Transporter	  3.  Treatment	  4.  Storage__   5.  Disposal	



I.   Inspector information

    1. Principal Inspector             2.  Organization
    3. Title                                      4.  Telephone No.



J.  Inspection Participants

1	6,	
1	L	
1	&	
£	9,	
1	1O	

-------
THIS PAGE LEFT BLANK
        2-14

-------
              APPENDIX 2-C. WASTE INFORMATION WORKSHEET
                      (To be filled out for each facility waste)
1. Waste Name:
2. Process generating the waste:
3.  Waste classification


    Hazardous	(Waste code:
    Non-Hazardous	
4. How has the facility made this determination?

    Testing	
    Process knowledge	

5. Are any test results available?
    Yes	 (if so, look at)
    No
6.  Waste generation rate:.

7.  Disposal procedure:
    Current

    Past	
8.  Have manifests been used for off-site shipment?


    Yes	(if so, look at)
    No	

9.  Is waste subject to land disposal restrictions?  Yes	  No	


                                      2-15

-------
THIS PAGE LEFT BLANK
         2-16

-------
                 APPENDIX 2-D.  CONTAINERS CHECKLIST
A. USE AND MANAGEMENT

1. Are containers in good condition?                            Yes	  No	


B. COMPATIBILITY OF WASTE WITH CONTAINER

1. Is container made of a material that will not react
   with the waste which it stores?                               Yes	  No	


C. MANAGEMENT OF CONTAINERS

1. Is container always closed while holding hazardous waste?         Yes	  No	

2. Is container handled so that it will not be opened,               Yes	  No	
   handled, or stored in a manner which may rupture it or
   cause it to leak?


D. INSPECTIONS

1. Does owner/operator inspect containers at least weekly for
   leaks and deterioration?                                     Yes	  No	


E. CONTAINMENT

1. Do container storage areas have a containment system?           Yes	  No	


F. IGNITABLE AND REACTIVE WASTE

1. Are containers holding ignitable and reactive waste located
   at least 15m (50 ft) from facility property lines?                  Yes	  No	
                                   2-17

-------
                            APPENDIX 2-D. (Cont.)
G.  INCOMPATIBLE WASTE
1.  Are incompatible wastes or materials placed in the same
    containers?                                                  Yes	  No	

2.  Are hazardous wastes placed in washed, clean containers
    which previously held incompatible waste?                       Yes	  No	

3.  Are incompatible hazardous wastes separated from each
    other by a berm, dike, wall, or other device?                     Yes	  No	
H.  CONTINGENCY PLAN AND EMERGENCY PROCEDURES

1.  Is a contingency plan maintained at the facility?                  Yes	  No

    If yes, does contingency plan include:

      a.    arrangements with local emergency response
       organizations?                                            Yes	  No

      b.  emergency coordinators' name, phone numbers,
         and addresses?                                          Yes	  No

      c.  list of all emergency equipment at facility
         and description of equipment?                             Yes	  No

      d.  evacuation plan for facility personnel?                      Yes	  No

2.  Is there an emergency coordinator on site or on call at
    all times?                                                    Yes     No
                                     2-18

-------
                  APPENDIX 2-E. WASTE PILES CHECKLIST
A. DESIGN AND OPERATING REQUIREMENTS

1. Is the pile containing hazardous waste protected from
   wind?                                                       Yes	  No	

2. Does waste pile have a liner and leachate collection
   system?                                                     Yes	  No	

3. Is run-on diverted around active portion?                       Yes	  No	

4. Is runoff collected and controlled?                              Yes	  No	

5. Are collection and holding facilities emptied after storms?         Yes	  No	

B. WASTE ANALYSIS

1. Is a representative sample of waste from each incoming
   shipment analyzed before the waste is added  to the pile
   to determine the compatibility of the  wastes?                    Yes	  No	

2. Does the analysis include a visual comparison of color
   or texture?                                                  Yes	  No	

C. CONTAINMENT

1. Is the leachate or runoff from the pile considered  a
   hazardous waste?                                            Yes	  No	

   If yes, is the pile managed with the following:

      a. an impermeable base compatible with the
         waste?                                                Yes	  No	

      b. run-on diversion?                                       Yes	  No	

      c. leachate and runoff collection?                            Yes	  No	

      d. periodic emptying of collection and holding facilities?        Yes	  No	
       OR

      e. protection from precipitation and
        run-on by some other means?                              Yes	  No
                                     2-19

-------
                              APPENDIX 2-E (Cont.)


D.  MONITORING AND INSPECTION

1.  Are liners and covers inspected for damage during
    construction?                                                 Yes	  No	

2.  Are waste piles inspected weekly for deterioration,
    run-on and runoff controls, wind dispersal control, and
    proper function of leachate collection system?                     Yes	  No	

E.  IGNITABLE OR REACTIVE WASTES

1.  Are ignitable or reactive wastes placed in the pile?                Yes	  No	

    If yes,

      a.    Does the addition of the waste result in the waste or mixture no longer
           meeting the definition?                                 Yes	  No	

           (Use narrative explanation sheet to describe procedure)

      OR

      b.    Is the waste protected from sources of ignition or reaction? Yes	  No	

       1.  If yes, use narrative explanation sheet to describe separation and
           confinement procedures.

       2.  If no, use narrative explanation sheet to describe sources of ignition or
           reaction.


F. INCOMPATIBLE WASTES

1.  Are incompatible waste  placed together in the pile?               Yes	  No	

2.  Are incompatible waste  separated from each other by a
    dike,  berm, or wall?                                            Yes	  No	

3.  Is there evidence of fire, explosion, gaseous emissions,
    leaching, or other discharge?  (Use narrative explanation
    sheet.)                                                        Yes	  No	

                                      2-20

-------
VI

-------
  INTRODUCTION TO




POLLUTION PREVENTION

-------
THIS PAGE LEFT BLANK

-------
                         TABLE OF CONTENTS






Section                                                                  Page



1.0   Introduction to Pollution Prevention  	1-1



1.1   Waste Management Hierarchy	1-1



1.2   Source Control Methods	1-3



1.3   Implementation of Pollution Prevention Techniques	1-8



1.4   Selected Pollution Prevention Case Studies  	1-9

-------
THIS PAGE LEFT BLANK
         11

-------
                                  CHAPTERl

          1.0 INTRODUCTION TO POLLUTION PREVENTION
                    Pollution Prevention is generally defined as any in-plant process that
                    reduces, avoids, or eliminates the use of toxic materials and/or the
                    generation of pollutants and wastes so as to reduce risks to human health
                    and the environment and to preserve natural resources through greater
                    efficiency and conservation.  The goal of pollution prevention is to
                    minimize environmental risks by reducing or eliminating the source of
                    risk (rather than reactively through treatment and disposal of wastes
                    generated).

                    There are significant opportunities for industry to reduce or prevent
                    pollution at the source through cost-effective changes in production,
                    operation, and raw materials use. The opportunities for source reduction
                    are not often realized because existing environmental regulations, and the
                    industrial resources they require for compliance focus upon  treatment and
                    disposal, rather than source reduction. Source reduction is different and
                    more desirable than waste management and pollution control.

                    A logical waste management hierarchy would be based on the principal
                    that pollution should be prevented or reduced at the source wherever
                    feasible, while pollutants that cannot be prevented should be recycled in
                    an environmentally safe manner.  In the absence of feasible prevention or
                    recycling opportunities, pollution should be treated. Disposal or other
                    release into the environment should be used as a last resort.  This
                    hierarchy is described in more detail in the next section.
                                1.1 WASTE MANAGEMENT HIERARCHY
                    In this section, a waste management hierarchy was developed as an
                    approach to prioritize pollution control methods. This hierarchy assesses
                    four types of pollution control methods based on their effectiveness in
                    reducing the risks to human health and the environment from pollution.

Source Reduction    The most desirable option of the hierarchy and the most effective way to
                    reduce risk is through  source reduction.  Source reduction is defined as
                    any method that reduces or eliminates the source of pollution entirely.
                    This includes any practice that:
                                        1-1

-------
Recycling
Treatment
Disposal
•      Reduces the amount of hazardous substances, pollutants, or
       contaminants entering a waste stream or otherwise released into
       the environment prior to recycling, treatment, or disposal; and

•      Reduces hazards to public health and the environment associated
       with the release of such substances, pollutants, or contaminants.

       The term source reduction includes equipment or technology
       modifications, process or procedure modifications, reformulation
       or redesign of products, substitution of raw materials, and
       improvements in housekeeping,  maintenance, training, or
       inventory control. It is important to note that the term source
       reduction does not include any practice which alters the physical,
       chemical, or biological characteristics, or the volume of a
       hazardous substance, pollutant, or contaminant through a process
       or activity which itself is  integral to, and necessary for, the
       production of a product or the provision of a service.

Where pollution cannot be prevented through source reduction methods,
the wastes contributing to the pollution should be recycled.  Recycling is
the use, reuse, or reclamation of waste after it has been generated (e.g.,
recycling spent solvents).

Wastes that cannot be feasibly reduced  at the source or recycled should
be minimized through treatment in accordance with environmental
standards and regulations that are designed to reduce both the hazard and
volume of waste streams  (e.g., adsorption of organic vapors onto
activated carbon).

Finally, any residues remaining from the treatment of waste should be
disposed of safely to minimize their potential for release into the
environment.  Disposal involves  the transfer of a pollutant to the
environment in either air, solid waste, or water (e.g.,  landfilling metal
scrap wastes).

Pollution control techniques include all four choices in the hierarchy.
Pollution prevention techniques include only source reduction or closed-
loop recycling, the first two choices in  the hierarchy. Implementation of
pollution prevention methods is the best way to reduce or control
pollution considering their potential environmental and economic
advantages which include:

•      Energy and resources conservation;
•      Raw material losses  reduction;
•      Treatment and disposal cost reductions;
•      Reduction of long-term liabilities associated with environmental
       waste or cleanup;
                                          1-2

-------
                     •      Improved worker health and safety; and
                     •      Reduced regulatory requirements.

                     The waste management hierarchy establishes a set of guidelines to follow
                     rather than a fixed set of rules.  Practices such as treatment and proper
                     disposal can be protective of the environment when performed properly.
                     Industries can be expected to balance the costs and benefits when
                     evaluating pollution control strategies.  Specific factors which must be
                     evaluated will be discussed in detail in a later section.

                     Many countries that are adopting pollution prevention as a national
                     environmental program rely on voluntary efforts by industries and
                     government to implement pollution prevention methods.  These voluntary
                     efforts have been quite  successful due to several factors including the
                     increasing costs of treating wastes, the increasing costs of transferring
                     wastes to landfills, treatment plants, and hazardous waste management
                     facilities; financial liabilities; and public pressure. These non-regulatory
                     incentives are causing industries to realize the economic and
                     environmental benefits gained from adopting pollution prevention control
                     methods.
                                     1.2 SOURCE CONTROL METHODS
                     Source control (pollution prevention) techniques can be grouped in
                     numerous ways (as evidenced in the many manuals and guides prepared
                     by EPA and other U.S. agencies). For this presentation, the techniques
                     are grouped into the following eight classifications:

                            1.      Process Changes
                            2.      Material Substitution
                            3.      Material Inventory and Storage
                            4.      Waste segregation
                            5.      Good housekeeping/Preventive Maintenance/Employee
                                   Education
                            6.      Product changes
                            7.      Water and energy conservation
                            8.      Recycling/waste exchange
Process Changes     Process changes consist of changing one or more processes used by the
                     facility, or changing the equipment used in the process(es).  The changes
                     can result in both reduced volume and/or toxicity of the waste generated.
                     Process changes may not necessarily be extensive or costly to implement.
                                         1-3

-------
                     Some examples of potentially simple and inexpensive process changes
                     which are considered pollution prevention techniques include:

                     •     Reducing drag-out (transfer) of pollutants from process solutions
                            by slowing withdrawal speed of metal parts and allowing sufficient
                            drainage time over process tanks (or over drip tanks). These
                            procedures, along with other drag-out reduction techniques can
                            reduce the waste of expensive chemicals, the quantity of
                            pollutants in rinse waters, the toxicity of waste waters, and the
                            quantity of sludge generated.

                     •     Adjusting production  schedules or dedicating  process equipment to
                            reduce the quantity of cleanup wastes generated (e.g., use of
                            dedicated tanks in the paint formulating industry to eliminate
                            intermediate washing).

                     •     Use of still rinse techniques to reduce the volume of waste water
                            generated in electroplating processes. Still rinses  are static (no
                            inflow or outflow) and are used  to rinse metal parts after plating
                            processes. When constituent concentrations become unacceptably
                            high within the rinse  tank, rinse waters may be  used  to replenish
                            the upstream plating bath.  Evaporative equipment may be used  to
                            concentrate rinse waters prior to replenishing  the plating baths.

Material             Changes in the raw  materials used in a  process can result in pollutant
Substitution         source reduction by reducing or eliminating the hazardous materials that
                     enter the production process. Examples of pollution prevention using
                     material substitution techniques include:

                     •     Substituting organic polyelectrolytes  in place of traditional
                            coagulation and flocculation agents (e.g., lime, alum) to reduce
                            quantities of sludge generated;

                     •     Substituting alkaline cleaners or  citric acid cleaners for organic
                            solvents; and

                     •     Replacing environmentally hazardous hexavalent chromium
                            electroplating solutions with trivalent chromium.
Material Inventory   Proper material inventory and storage refers to the purchasing, tracking,
and Storage          storage, and handling of hazardous materials.  There are two facets of
                     material inventory and storage:

                     •      Using good inventory and tracking procedures of hazardous
                            materials help minimize overstocking and contamination and
                            reduces the need to dispose of expired or contaminated materials.

                                         1-4

-------
                            These procedures should ensure that raw materials are purchased
                            only when needed and in appropriate quantities.  Expiration dates
                            of materials should be tracked and a "first-in, first-out" (FIFO)
                            policy (older materials used first) should be adopted.

                      •     Developing procedures and obtaining appropriate equipment to
                            prevent and respond to all potential sludge discharges including
                            spills, leaks, bypasses, and upsets (e.g., utilizing secondary
                            containment around tanks and containers of hazardous materials
                            and process equipment to prevent discharge of hazardous materials
                            and to reduce the quantity of waste generated from cleanup of
      '                     spills or leaks).

Waste Segregation    Segregation of different types of wastes can be a simple and effective
                      pollution prevention technique applicable to a wide variety of waste
                      streams and industries.  By segregating wastes at the source of generation
                      and by handling hazardous and non-hazardous wastes  separately, waste
                      volume and management costs may be reduced. Additionally,
                      uncontaminated or undiluted wastes may be reusable in the production
                      process or may be sent off-site for recovery.  Practices for segregating
                      wastes include  the following:

                      •     Isolating hazardous waste from nonhazardous waste.  Blending
                            such waste makes all the waste hazardous and  increases treatment
                            or disposal costs.

                      •     Segregating different types of solvents, particularly halogenated
                            solvents from non-halogenated solvents, and aromatic solvent from
                            aliphatic solvents.  Solvents are harder to recycle and reuse.

                      •     Avoiding contamination of wastes with water.  Solvents and oils
                            that are contaminated  with water are harder to recycle and reuse.
                            In addition, wastes and waste water that are mixed with  large
                            amounts of storm water require additional treatment steps and
                            costs.
                                          1-5

-------
Good                These procedures are generally simple and inexpensive to implement and
Housekeeping/Pre-   effectively reduce pollution at its' sources.
ventive Main-
tenance/Employee
Education

Good Housekeeping  Some examples of such procedures include:

                     •     Reducing dripping and splashing from parts being dipped in
                            process and rinse tanks.  This prevents this waste water from
                            entering drains to the sewer or waste water treatment system.

                     •     Maintaining adequate distances between different chemicals to
                            prevent cross contamination; and

                     •     Keeping containers closed except when material is being removed.
                     •     Providing runnels and other transfer equipment to reduce loss of
                            material during transfer.

Preventive           Preventive maintenance reduces malfunctions and leaks and can also
Maintenance         reduce the quantity of waste generated.  Preventive maintenance consists
                     of regular inspection, cleaning, testing, and lubrication of process,
                     storage, handling, monitoring and treatment equipment.  A master
                     preventive maintenance file which documents all maintenance work
                     should be kept. Also, any parts that are worn or broken should be
                     replaced before a problem occurs (e.g., regular replacement of seals and
                     gaskets to prevent leaks from pumps, joints, valves, etc.).

Employee Education  Employee education may be the most basic pollution prevention technique
                     and yet it is often overlooked.  Pollution prevention education should be
                     an integral part of the training normally given to employees when they
                     begin a job and during regular refresher training. Two of the most
                     important aspects of training include:

                     •     Educating employees to know and understand the company's
                            pollution prevention goals. It is important for employees to know
                            and understand the benefits of reducing hazardous materials being
                            handled and generated.  To accomplish this task, many companies
                            establish a facility-wide training program to educate employees on
                            pollution prevention techniques used by the facility.
Product Changes
•      Ensuring that all employees know and practice proper and efficient
       use of tools and supplies.  This is especially important for cleaning
       operations.
Product changes that are considered pollution prevention techniques

                    1-6

-------
Water and Energy
Conservation
Recycling/Waste
Exchange
On-site Recycling
include any changes in the composition or use of an intermediate or end
product which results in reducing waste from the manufacture, use, or
ultimate disposal of the product.  A life-cycle assessment of a product can
be used as an objective tool to identify and evaluate opportunities to
reduce the environmental impacts associated with its manufacture, use, or
disposal.  The three components of the assessment include:

•      Inventory analysis—Identification and quantifying of energy and
       resource use and waste emissions;

•      Impact Analysis—Assessment of the consequences those wastes
       have on the environment; and

•      Improvement Analysis—Evaluation and implementation of
       opportunities to effect environmental improvements.

Water and energy conservation should be considered as  part of an overall
pollution prevention strategy.  Benefits to reducing water and energy  use
include reduced waste water generation and associated treatment/disposal
costs and reduced pollution associated with producing potable water and
the generation of energy. Examples of water and energy conservation
techniques include:

•      Employing timed automatic shutoff valves on equipment using
       water such as rinses on a metal finishing line.  This technique is
       relatively inexpensive,  but can result in substantial decreases in
       water use and waste water generated.

•      Recirculating cooling waters through a cooling tower.  Water  used
       in cooling heavy machines, quenching hot metals, molding and
       forming processes, etc. should be recirculated to significantly
       reduce  water use.

•      Utilizing heat exchangers on high temperature discharges  to heat
       incoming water.  This  practice is employed at many industrial
       laundries (including those at hospitals), chemical manufacturing,
       and power generating facilities.

Recycling can be used where further source reduction techniques cannot
be implemented. Recycling involves  the use of a waste as an effective
substitute for a commercial product or as a raw material in the
manufacture of a product.

Recycling the waste on-site by returning the waste back to the process or
another process (e.g., the use of waste acids and bases  for pH adjustment
in waste water treatment systems or the use of a small On-site still to
purify degreasing solvents for subsequent reuse).

                    1-7

-------
Off-site Recycling/
Reclamation
Waste Exchange
Recycling waste off-site by sending it to a recovery/reclamation facility
for processing (e.g., sending metal-bearing sludges from industrial waste
water treatment processes to Off-site reclamation facilities).

Advertising the sale or the availability of wastes through a private- or
government-funded organization.  Waste exchanges can help bring
together generators of waste with companies that can use the waste in
their production process.
                                  1.3 IMPLEMENTATION OF POLLUTION
                                        PREVENTION TECHNIQUES
                     When industries are deciding whether to implement pollution prevention
                     techniques in their facilities, several items must be examined.

                     First, it must be determined if the pollution prevention technique will
                     result in cross medium transfer of pollutants. It is important to avoid
                     transfer of pollutants from one media to another. The three types of
                     media are air, land, and water. Most treatment or disposal methods
                     transfer pollutants from one media to another. For example, wastewater
                     treatment that uses coagulation and sedimentation to remove metals
                     generates a sludge which is usually disposed in landfills.  In this case, the
                     metal pollutants are transferred from the waste water to the sludge placed
                     in the landfill.  Another  example is the use of air stripping to remove
                     volatile organic compounds (VOCs). In this case, the volatile organic
                     compounds are removed from the waste water and released to the air.

                     Pollution prevention strategies can substantially decrease pollutant loads
                     to the environment without transferring pollutants from one medium to
                     another. An example includes substituting powder paints for water-based
                     and solvent-based paints for example, eliminates cleanup wastes and
                     emissions of VOCs.

                     A second consideration is worker health and safety.  For example, the
                     substitution of a coagulant chemical which generates less sludge in a
                     pretreatment system may be more hazardous to workers handling it.
                                         1-8

-------
        Finally, any pollution control technique utilized must comply with all
        applicable Federal, State and local laws and regulations. Some pollution
        prevention strategies may require obtaining a permit or license or making
        a special notification to the appropriate regulatory agency.
1.4 SELECTED POLLUTION PREVENTION CASE STUDIES
        The United States Evironmental Protection Agency has established a
        voluntary pollution prevention program intiative called, the 33/50
        Program. The program derives its name from its overall goals-an
        interim goal of 33% in 1992 and an ultimate goal of a 50% reduction by
        1995 in releases and transfers of 17 high-priority toxic chemicals, using
        1988 Toxic Release Inventory (TRI) reporting as a baseline.  During
        1988, 1.48 billion pounds of the target chemicals were either released to
        the environment on-site or transferred off-site to waste management
        facilities. The aim of the 33/50 Program is  to reduce this amount by at
        least 50%-743 milliion pounds-by 1995, with an interim reduction target
        of more than 490 million pounds by 1992.

        The Program is part of a broad group of EPA activities designed to
        encourage pollution prevention as the best means of achieving reductions
        in toxic chemical emissions.  More than 16,000 facilites have reported
        33/50 Program chemicals  to the Agency since 1988. By contacting the
        chief executives of the parent companies of TRI facilities that report
        33/50 Program chemicals, the Program seeks to instill a pollution
        prevention ethic throughout the highest echelons of American businesses.

        In an effort to recognize companies making  significant progress in
        reducing chemical releases and transfers, Company Profiles have been
        developed to provide detailed information about the reduction efforts
        companies have undertaken. The following  case summaries represent 14
        companies, of the more than 1200 companies participating in the
        Program, that have added to the success of the 33/50 Program.
                            1-9

-------
PRINTED CIRCUIT BOARDS
HADCO Corporation is a manufacturer of custom printed circuit boards and backplanes for use in
electronic components. Approximately 60% of the boards produced are used in computers, and an
additional 30% are used in telecommunications equipment.  The remaining 10% find end uses in
various types of instrumentation, principally in medical devices and the automotive industry.
HADCO is headquartered in Salem, New Hampshire, and operates six facilities.

From July, 1989 through August, 1990 die company implemented a $1.7 million process conver-
sion and emission control project at its Deny facility. The project's goals were to eliminate use or
minimize air emissions of chemicals used in the facility's manufacturing operations.

The cornerstone of the project was implementation of new aqueous-based chemicals in the cleaning
and dry film processes.  The dry film process was modified to include carbonate based developers
instead of 1,1,1-trichloroethane, and hydroxide solutions instead of dichloromemane,  A screen
cleaning use of dichloromethane was also replaced with an aqueous cleaning solution at the Owego,
NH facility.

HADCO's conversion project has resulted in the following source reduction of chemicals:

•       Significant reduction in dichloromethane through conversion of six of the  eight dry film
        and cleaning processes to water based chemistry;

•       Elimination of l,l,l~trichloroethane through conversion of the cleaning and dry film pro*
        cesses to water based chemistry; and,

•       Elimination of methyl ethyl ketone as an additive to dichloromethane in cleaning (its only
       use at the facility).

Certain circuit board processes could not be replaced with this new water-based technology,
however, because of user specifications. To reduce emissions of these chemicals,  HADCO also in-
stalled a dual-bed activated carbon adsorption recovery system at its Deny, NH facility, which
reduced remaining emissions of the three solvents by over 99%.

As an alternative to a recovery system, HADCO replaced both 1,1,1-trichloroethane and
dichloromethane with a terpene solvent at its Owego, NH facility.

The recovery system was installed to further reduce  air emissions.  However, HADCO's process
conversion and emission control program achieved significantly greater reductions  than required by
New Hampshire Air Toxics Regulations (adopted April, 1990). HADCO's state permit for
dichloromethane allows emissions of no more than one pound per hour; however, the company
estimates that its emissions level has been reduced to 0.3 pounds per hour. In addition, the State
tew did not require control of methyl ethyl ketone or 1,1,1-trichloroethane at the Deny site. Thus,
HADCO has reduced air emissions by more than 270,000 pounds over the state requirements.

HADCO's efforts in pollution prevention and solvent recovery allowed the company to achieve its
goals two years ahead of schedule. Company-wide  releases and transfers of its' major solvents
chemicals decreased 95% between 1988 and 1992, reflecting a reduction of almost 2.2 million
pounds. In addition, according to company  officials, the company achieved additional reductions in
1993 that have brought its total reductions to 99.5%.
                                          1-10

-------
STEEL PRODUCTS

Acme Metals Incorporated, based in Riverdale,  Illinois, is the parent company of an integrated
steelmaker and three steel fabricating subsidiaries. Although interrelated, each subsidiary is
responsible for its own environmental programs.

Acme Steel Company, an integrated producer of steel products, operates coke and ironmaking
facilities in Chicago, IL and a steelmaking plant in Riverdale, DU Acme Packaging Corporation, a
manufacturer of steel strapping tools, operates facilities located in Riverdale, IL, Leeds, AL, New
Britain, CT, and Pittsburg, CA.  These two subsidiaries are responsible for virtually all releases
and transfers of selected dimn?.f-"l« and are the focus of this profile.

Acme Metals Incorporated reduced annual releases and transfers of selected chemicals by more
than 833,000 pounds by 1992 from 1988 levels.

Acme achieved an 89% reduction in releases and transfers of these chemicals from 1988  to 1992,
surpassing its pledged reduction of 70% by  1995.

Since 1988, Acme has implemented several programs aimed  at further reducing releases and
transfers of these chemicals. Acme has completed the following projects at its Chicago Coke plant:

•       Replace cooling system. Acme replaced its contact gas cooling system with a non-
        contact, wet surface air cooler b the coke byproducts recovery process.  The replacement
        of the cooling system resulted in reductions of releases of approximately 143,000 pounds
        of benzene, 276,000 pounds of cyanide, 28,000 pounds of toluene, and 6,000 pounds of
        xyleoe, as well as 1,450,000 pounds of ammonia, and 10,000 pounds of naphthalene.

•       Install emission collector headers. Acme installed emission collector headers to remove
        volatile chemicals, such as benzene, toluene, and xylene, from the headspaces of process
        units and storage tanks.  This process uses steam moving under negative pressure to sweep
        the volatile chemicals into the byproduct recovery system.  Emission collector headers
        were installed at the light oil storage tank, the wash oil decanter, and the wash oil circu-
        lation tank and resulted in a  14,000 pound reduction in releases of benzene, as well as
        smaller reductions of toluene and xylene.

In addition, at Acme Packaging's Riverdale facility, spent lead dross from the steel strapping
production process is now sent to an off-site recycler. Previously, the lead was landfilled.  The in-
creased recycling of lead resulted in a reduction of approximately 333,000 pounds of releases and
transfers of lead.  Small components of lead are still landfilled as a component of nonhazardous
sludge generated from pollution control activities.

Acme reduced releases and transfers of other selected chemicals by nearly 2,600,000 pounds (75 %)
between 1988 and 1992.
                                           1-11

-------
HEALTH CARE PRODUCTS

Johnson & Johnson is the world's largest health care company, with over 80,000 employees and
manufacturing and sales locations in more man SO countries. The company manufactures toiletries
and baby care products, medical supplies, and pharmaceutical products.

To reduce releases and transfers of selected chemicals, Johnson & Johnson has
undertaken several projects at its various facilities:

»       Eliminating the use of methyl ethyl katone, methyl isobutyl ketone, and xylene at the Con-
        sumer Products plant in North Brunswick, NJ. These chemicals were used in the
        manufacturing process for the company's Band-Aid1* Brand adhesive bandages.  Vinyl
        extrusion and the use of a water-based emulsion has been substituted in the manufacturing
        process, resulting in a decrease of over 380,000 pounds in releases and transfers of these
        three solvents between 1988 and 1992.

•       Equipment and procedure changes in several processes at the Noramco facility in
        Wilmington, DE, resulting in a combined reduction in releases and transfers of
        dichloromethane and toluene of over 131,000 pounds between 1988 and 1992.  These
        changes by Noramco include: using dichloromethane and toluene as the seal fluid in liquid
        ring vacuum pumps, instead of water, thereby reducing wastewater transfers; imple-
        menting a leak detection and  repair program to reduce fugitive emissions; and eliminating
        one product recovery step, further reducing dichloromethane transfers in wastewater.  This
        facility has achieved reductions of 51% in  releases and transfers of all these chemicals be-
        tween 1988 and 1992.

•       Material substitution at Ethicon plants in SomerviUe, NJ and San Angelo, TX, as weQ as
        the Advanced Materials facility in Gainesville, G A and the Vistakon plant in Jacksonville,
        PL, resulting in a decrease of over 66,500 pounds (73 %) in releases and transfers of
        l,t,l-trichloroethane between 1988 and 1992.  A biodegradable cleaner was substituted for
        1,1,1-tnchIoroethane.

As a result of Johnson & Johnson's pollution reduction efforts, releases and transfers of selected
chemicals decreased 63% (469,981 pounds) between 1988 and 1992. The largest reductions were
for xylene and methyl ethyl ketone, which decreased by 93% and 80% respectively. These reduc-
tions were due principally to the conversion of the adhesive carrier to aqueous emulsion in the
Band-Aid1" manufacturing process.

Releases and transfers of 1,1,1-trichloroethane also fell by 74% (66,580 pounds), in conjunction
with the company's goal of eliminating the use of this chemical and other ozone depleting
substances.

Johnson & Johnson has stated that participation in a Pollution Prevention (P2) program has helped
significantly in formulating reduction initiatives and in obtaining corporate support for their
implementation.  The requirement of reporting releases and transfers of hazardous chemicals to
EPA initially made the company aware of the extent of its emissions and off-site transfers.  The
company began to develop strategies for reducing releases and transfers of hazardous chemicals as
figures were first compiled company-wide. The P2 focus on a distinct set of chemicals then helped
Johnson & Johnson to develop and choose among specific source reduction projects for these
targeted chemicals.
                                           1-12

-------
METAL AND PLASTIC HARDWARE

Aladdin Industries Inc. is a manufacturer of metal and plastic hardware for consumer and industrial
use. Located in Nashville Tennessee, Aladdin produces a wide variety of products such as lunch
kits, thermos bottles, hospital trays, Coffee cups, lamps, and coolers.

Although Aladdin is a relatively small generator of toxic chemical emissions, the company has
stated that, as a corporate citizen, it feels an obligation to reduce any emissions generated.
Aladdin's ultimate objective is to eliminate the emissions of toxic chemicals completely, primarily
through source reduction methods. However, in cases where source reduction is not possible,
Aladdin is looking to other means of reducing emissions such as treatment and recycling.

In order to meet its goals, Aladdin designed in-house projects focusing on each of the chemicals to
be ^"""Mh**, controlled, or replaced. For each of these projects, one staff member was appointed
project leader and had primary responsibility for ensuring the project's completion.  For each
project, a goal, target implementation date, base year, and method for completion were articulated.

To date, Aladdin has completed the following projects:

•       All trichloroethylene usage was  eliminated during 1993. Trichloroethylene was required
        to remove petroleum oils from metal  parts during metal forming processes. Synthetic
        lubricants are now used in place of petroleum oils and are removed from parts with an
        aqueous alkaline cleaner. The water  from the alkaline cleaning process is  treated on-site.

•       Dichloromethane use was completely eliminated from the facility as of 1993 by replacing
        the polystyrene used in trays with polypropylene. Previously, the polystyrene trays were
        cut from a  sheet and blemishes around the edges were removed using dichloromethane.
        Since the polypropylene trays are now injection molded, there are no blemishes to remove.

•       Toluene and methyl isobutyl ketone were completely eliminated from the Aladdin facility
        as of 1993  by replacing a thinner containing toluene and methyl isobutyl ketone with a
        thinner containing 25% toluene and 75% 1,1,1-trichloroethane.  This thinner was later re-
        placed with a thinner containing acetone in place of the toluene. The company is currently
        investigating options to eliminate the  1,1,1-trichloroethane from this formulation.

•       Aladdin eliminated all releases and transfers of chromium, along with phosphoric acid and
        sulfuric acid — as of 1992.  Using a newly installed on-site waste treatment facility,
        Aladdin removes toxic materials from a water mixture containing chromium, phosphoric
        acid, and sulfuric acid.  Fifty percent of the water is recycled, while die remainder is of
        sufficient quality to discharge to the sanitary sewer.  The sludge is of sufficient quality to
        be considered nonhazardous and is disposed of in a landfill. Prior to the installation of the
        on-site treatment facility, all of these wastes were transferred off-site for treatment or
        Aladdin eliminated its lacquer painting process by switching to a dry powder coating,
        thereby eliminating the use of lead, xylenes, and ketones.  Small quantities of lead,
        xylenes, and ketones were previously used at Aladdin in its painting process for thermos
        bottles.
                                            1-13

-------
RUBBER-COATED FABRICS

Aldan Rubber Company is a manufacturer of rubber-coated fabrics that are used in a wide variety
of applications, including protective clothing for fire fighting, flexible duet connectors, convertible
tops, and baby products.  Aldan is located in Philadelphia, Pennsylvania.

Aldan conducted a survey to identify areas in the manufacturing process where significant emis-
sions were taking place. This allowed the company to focus reduction efforts on the largest emis-
sion sources. The survey followed the "solvent trail"  through the entire manufacturing process,
from unloading of solvent from tank trucks to post-manufacture disposalof rubber scrap.  After
completing the facility survey and evaluating the results, Aldan identified five major activities that
would significantly reduce chemical emissions:

•       Totally enclose the rubber spreader.  In its 1976 project, Aldan installed a hood to cap-
        ture solvent emissions over part of its spreader. The captured solvent was then routed to a
        recovery unit  Aldan recently enclosed the entire spreader so that all solvent emissions are
        captured and recycled, rather  than just  those under the partial hood.

•       Renovate the solvent recovery system.  In order to improve the efficiency of its solvent
        recovery system, Aldan renovated the system put in place in 1976.  As part of the renova-
        tion, the recovery unit received a complete overhaul, including replacement of the carbon
        recovery media, cooling coils, and old  seals and valves. Aldan reported the solvent recov-
        ery unit's efficiency at 98% -  99% after the renovation, an increase of approximately 20%
        from the previous efficiency level.

•       Use an alternative cleaner for machinery clean-up.  Aldan traditionally used toluene in
        a hand-wipe application to clean its equipment on a periodic basis.  This cleaning removes
        excess  rubber, dirt, and other contaminants from production machinery.  To eliminate this
        use of toluene, Aldan now uses a d-limonene cleaner in a similar hand-wipe application,
        with reduced but satisfactory performance, and somewhat higher but still acceptable cost.

•       Institute an employee awareness program.  Aldan recognized that a significant quantity
        of solvent emissions could be  eliminated simply by improving the handling of process
        materials. An employee awareness program, mandatory for all employees who handle
        solvents, was implemented to  achieve this goal. During the program, Aldan explained to
        workers the environmental problems associated with the solvent emissions and made
        suggestions for reducing emissions. Company officials believe that the employee aware-
        ness program has been a great success.

•       Improve management of rubber scrap.  Aldan developed a proprietary process by which
        it is able to reduce solvent emissions from rubber scrap. This process is one in which the
        scrap is processed to remove excess solvent prior to scrap disposal.  Aldan has found that,
        not only does the process reduce emissions of solvent to the air, but it also renders the
        rubber scrap nonhazardous. The scrap can then be disposed of in a municipal landfill.

As a result of the efforts described above, by 1992 Aldan Rubber had reduced releases and trans-
fers of selected chemicals by 73% from the 1988 baseline, almost reaching its goal  of an 80%
reduction. Reductions for toluene alone accounted for more than 1,000,000 pounds.
                                           1-14

-------
SPECIALTY FENCING PRODUCTS

Anchor Fence, Inc. is a manufacturer of high quality chain link fencing systems, gates, and
specialty fencing products. The company has one facility located in Baltimore, MD, employing
approximately 85 workers.

The company has undertaken the following activities to reduce releases of selected chemicals:

•       Releases of methyl ethyl ketone have been reduced 93* (113,000 pounds) through substi-
        tution of wafer based formulations of primers for pipes and fittings.  This action accounts
        for all of the observed decrease in releases of this chemical. In addition, all solvent based
        paint applications are being strictly monitored to determine which can be converted to
        •water based products in the future.

•       Improvements in the operation of the company's waste water treatment system have re-
        sulted in a 50% reduction in releases of lead, nickel, and zinc compounds between 1988
        and 1992. These improvements consist primarily of adjusting the pH of the system to
        increase efficiency of metals removal.

•       Eliminating the use of dichloromethane at the plant by shifting the PVC stripping process
        for off-quality products to an off-site cleaning company that uses a hot salt bath PVC
        removal process.  This change resulted hi cost savings for the company.

•       Examination of solvent based cleaning processes using toluene and methyl ethyl ketone to
        determine where solvent evaporation can be reduced.  The company intends to install a
        water-cooled component cleaning tank to further reduce releases of the solvents.

By 1992, Anchor Fence had reduced release of these chemicals by  87$ from 1988 levels.
Virtually all of this reduction, was « result of substitution of methyl ethyl ketone-based primers with
a water-based formulation.
                                           1-15

-------
STAINLESS STEEL

Carpenter Technology Corporation manufactures stainless steel and other specialty metals for a
variety of industries including aerospace, nuclear,  and electronics. The company is headquartered
in Reading, Pennsylvania and has four facilities that report emissions.

Its two largest facilities are in Reading, Pennsylvania and Orangeburg, South Carolina. The
former produces a variety of bar wire and strip metal products while the latter produces fine wire.
In addition, a small plant in Fiyeburg, Maine and « plant in £1 Cajon, California also make metal
products.

In 1988, as a first step in identifying source reduction opportunities, Carpenter set up a team
dedicated to continuous environmental improvements. This team consisted of key staff from
engineering, production,  and research and development.  The team identified several types of
projects including solvent substitution, reduction in solvent emissions through process
modifications, increased recycling of metal-bearing waste streams, and changes in operator
procedures to reduce the  amount of acid used for metal descaling.

Specific changes «n*p^>v*«>fl^ by Carpenter to reduce solvent emissions include:

•       Substituting mineral spirits (petroleum-based solvents) for trichloroethane for cleaning
        certain types of metal parts.

•       Eliminating non-cleaning uses of 1,1,1-trichloroethane (e.g., as a lubricant).

•       Improving vapor degreaser process control to minimize  the amount of solvent needed to
        dean metal components, and reducing by 50% the number of vapor degreasers used.

•       Improving process control to minimize the amount of waste acid generated and eliminate
        the need for sending acid bath wastes off-site for treatment

Two additional changes resulted in the elimination of-all  releases of metals (1,608,250 pounds of
chromium and nickel) to  land and a significant reduction  in the amount of metals transferred  off-
site for treatment:

•       Improving sludge drying operations and recycling rolling mill sludges, resulting in a 400%
        increase in the amount of metal oxides that can be recycled.  These wastes were
        previously transferred off-site for treatment.

•       Adding chemical inhibitors to acid bath solutions to reduce the amount of dissolved metals
        being transferred to the acid waste streams.

In addition, for economic reasons, the company consolidated its  operations in 1989 by closing the
Bridgeport plant while maintaining similar company-wide production levels through operation of
four other plants.  Through this action, Carpenter was able to achieve a 35% reduction in releases
and transfers  of selected chemicals.
                                            1-16

-------
SHOES

Dexter Shoe Company is a manufacturer of shoes for men, women, and children. The company is
headquartered in Dexter, Maine and has four facilities in Maine:  two in Dexter, one in
Skowhegan, and one in Milo.

Both the Headquarters and Skowhegan facilities are using a three-tiered approach to meet its
reduction goals:  reduction in chemical use, substitution with less hazardous chemicals, and solvent
recovery.

Hie Skowhegan facility has had particular success in substitution and solvent recovery. The
facility reports the following activities:

•       Replacing two solvent-based waterproofing agents  with aqueous-based products.  These
        new products are more expensive than their solvent predecessors, but provide better cover-
        age using less product.

•       Replacing methyl ethyl ketone as a cleaning solvent with heptane. Because heptane still
        poses some risk, however, the company is continuing to investigate other alternatives.

•       Employing solvent recovery for cleaning solvents, such as methyl ethyl ketone and
        heptane.  Dexter uses solvent recovery both for reuse of individual solvents and for gener-
        alized recovery  of mixed cleaning solvents.  Some of the solvent recovery is done within
        the process for which the chemicals are used and,  thus, can be considered source
        reduction.

A similar progress report from Dexter's Headquarters facility describes the following .individual
reduction accomplishments:

•       Substituting  solvents and cleaners containing methyl ethyl ketone, methylene chloride, and
        toluene with water-based products.

•       Replacing a  filler product containing 4096 acetone  with a cut insert material bonded to the
        upper part of the shoe with a hot melt adhesive.

•       Installing a solvent recovery system for reuse of cleaning solvents.

Emissions of all reported chemicals at the company's two participating facilities have already
decreased 47% from  1988 to 1992 through elimination of 209,471 pounds of emissions:
                                            1-17

-------
AUTOMOBILE AND TRUCK COMPONENTS  (SEAT AND TRIM)

Douglas & Lomasoo Company is a manufacturer of automobile and truck components, primarily
seat and trim parts.  The company is headquartered in Farrmngton Hills, Michigan and operates 16
manufacturing facilities located in Alabama, Arkansas, California, Georgia, Iowa, Maryland,
Mississippi, Missouri, Nebraska, Tennessee, and Texas.

To meet its reduction goals, Douglas & Lomason has undertaken a number of source reduction
activities, primarily product and process reformulation.  The company has completed projects to
reduce chemical use in both the molding and painting processes.

*       Implementing a new mold-release agent formulation.  The Havre-de-Grace, MD,
        facility manufactures foam seat pads using a molding process.  This process involves
        applying a wax mold-release agent to the mold to facilitate the  removal of the finished
        molded product. Douglas & Lomason's traditional mold-release agent, which contained
        1,1,1-tricbloroetbaneas a solvent, was replaced with a water-based formulation. This
        substitution completely rfimimted the use of 1,1,1-trichloroelhane, a reduction of 350,000
        pounds.

•       Using "high-solids" paint formulations.  At one facility, Douglas & Lomason manufac-
        tures metal trim parts which are painted. The amount of solvent, such as toluene, xylene,
        and methyl ethyl ketone, used in these paints was reduced through the use of reformulated
        "high-solids"  paint.  "High-solids* paint uses a reduced percentage of solvent in
        formulating the paint, thereby increasing the percentage of solids. This approach resulted
        in achieving reductions at the Phenix City, AL, facility.

•       Using water-based paint.  At several facilities, Douglas & Lomason manufactures  metal
        seat frames which are painted for rust  protection.  The use of solvents in the paint has
        been rfitnitmtad by using water-reducible paints, in which the solvents (in this case toluene
        and xylene) are  replaced with ethylene glycol. • This approach was used at the Columbus,
        NE, facility, contributing to reductions of 86,454 pounds of toluene and xylene releases
        between 1988 and 1992.

•       Eliminating the use of paints.  Solvent use has also been reduced or eliminated through
        the implementation of two new processes that eliminate the need to paint certain parts.
        First, the spray-application of rust inhibitors'has eliminated the need for painting, thereby
        reducing and  in some cases eliminating the use of solvents. A second process
        implemented by Douglas & Lomason involves the chemical application of a coating to
        metal parts using a process that requires  no solvents. The Red Oak, 1A, facility used this
        process to eliminate releases and transfers of 61,000 pounds of toluene and xylene.

As a result of these and other efforts,  Douglas  & Lomason has made outstanding progress in reduc-
ing its releases and transfers of selected chemicals,  including surpassing its 1995 reduction goal
several years early.  Douglas & Lomason succeeded in reducing its releases and transfers by 88%
between 1988 and 1992, a reduction of 525,285 pounds.  This reduction in releases and transfers
was achieved despite an increase in production  between 1988 and  1989.

As part of Douglas &  Lomason's efforts, the Havre-de-Grace, MD, Red Oak, IA, and Columbus,
NE facilities have completely eliminated their use of selected air toxic and other chemicals.  The
company as a whole has completely eliminated the use of 1,1,1-trichloroethane.
                                           1-18

-------
SPECIALTY CHEMICALS AND METALS

Olin Corporation is a Fortune 200 company, headquartered in Stamford, CT, with 29 facilities
nationwide in 15 states. The company manufactures a wide variety of products, including specialty
chemicals, metals, and other materials, as weU as products for the defense, aerospace and sporting
ammunition industries. Examples of significant projects at Olin facilities that have successfully
reduced the emissions of these chemicals to me environment include:

Olin Corp., Rochester, NY*  Olin's Rochester facility produces over 60 different types of specialty
chemicals - relatively low volume products tailored to the specific needs of individual customers,
including biocides (zinc or sodium pyrithione), aniline dyes, and pharmaceutical ingredients. In
1988, the facility reported air emissions  of 11,540 pounds of carbon tetrachloride, which is used as
a non-reactive diluent.  La order to recover carbon tetrachloride from air vents, the plant installed a
scrubber and additional process vent collection equipment, and now reuses the reclaimed material
in several of the facility's production processes.  1992 air emissions of carbon tetrachloride were
reduced to 3,437 pounds at this facility,  a reduction of 70%.  This facility is also investigating the
substitution of carbon tetrachloride and other chemicals with non-toxic raw materials.

Olin Ordnance, Red Lion, PA.  The Red Lion facility produces various munitions for the military.
In 1988, this facility reported air emissions of 122,535 pounds of 1,1,1-trichloroethane.  This
chemical is used as a multi-purpose cleaner  and degreaser. The Red Lion facility took a number of
steps to reduce the use of this chemical,  including: restricting access and requiring employees to
justify their use of the material; identifying material substitution options for products not required
to use the chemical (e.g., by military procurement specifications); and modifying the chiller on a
solvent degreaser to enhance vapor capture.  As a result of these efforts, air emissions of 1,1,1-tri-
chloroethane were reduced to 21,700 pounds in 1992, a reduction of over 80% from 1988 levels.
The facility is currently investigating two additional actions to further reduce the use of 1,1,1-
trichloroethane: installing a parts washer which will use water-based cleaners instead of
chlorinated solvents, or altering the overall production process to completely eliminate the cleaning
process.

Bridgeport Brass Co.,  Indianapolis, IN. In 1988 this facility reported air emissions of 37,000
pounds of 1,1,1-trichloroethane and dichloromethane, which were used as degreasers.  By 1990,
the facility had completely eliminated its use of these two chlorinated solvents by switching to the
use of water-based soaps and hot water rinsing in its metal processing and maintenance operations.

Main Plant Facility, East Alton, IL.  Olin's East Alton Main Plant facility used to landfill large
quantities of lead wastes (off-site disposal of 815,853 pounds in 1988), primarily from bullets test-
fired into sand traps at the Winchester sporting ammunition plant  The facility used to screen as
much lead as possible out of the sand for reuse in their own production processes, and landfill the
remaining lead-contaminated sand off-site. The facility began selling unscreened material to a
battery manufacturer, and more recently began selling  it to a lead smelter.  The sand/lead mixture
is used directly as a recycled raw material in the smelting process. The landfilling of lead wastes
has thus been dramatically reduced to 39,673 pounds in 1992, for an overall reduction of 95%.

Between 1988 and 1992, Olin reduced its releases and transfers of selected chemicals by 67%, a
reduction of 1,367,614 pounds. Much of this reduction was the result of eliminating or capturing
473,114 pounds of air emissions from solvents.  In addition, Olin reduced off-site chemical
disposal 876,904 pounds between  1988 and  1992, including shifting 776,180 pounds of lead from
off-site disposal in a landfill to off-site recycling — an action that represents a move up the
pollution prevention hierarchy.
                                            1-19

-------
MOTION CONTROL PRODUCTS

Parker Hannifin Corporation manufactures a broad array of motion control products for industrial and
aerospace applications. The company is headquartered in Cleveland, OH and employs nearly 26,000
individuals "worldwide at 143 manufacturing plants and 87 administrative and sales offices, company
stores, and warehouses. Parker's Industrial segment, which accounts for 75% of the company's sales,
is comprised of five groups: Fluid Connectors, Motion & Control, Automotive & Refrigeration, Seat,
and Filtration. The company's Aerospace segment is a single group with several divisions that account
for the remaining 25% of Parker's sales.

To reduce releases and transfers of selected chemicals at its facilities in the United States, the company
undertook the following activities between 1988 and 1992:

•       Eliminated 756,000 pounds of releases and transfers of dichloromethane, tetrachloroethylene,
        1,1,1-trichloroethane, and  trichlorethylene by switching to aqueous cleaning systems  for
        degreasing operations. Because the aqueous cleaning process requires agitation of the parts,
        part of the conversion involved redesigning the racks used to hold parts during cleaning to
        accommodate agitation,

*       Eliminated 453,000 pounds of releases  and transfers of methyl ethyl ketone and toluene by
        substituting water-based solutions for  solvent solutions used  to carry  cements  in  the
        manufacture of rubber hoses. This substitution required the addition of a drying step because
        of the relatively slow evaporation rate of water.

•       Eliminated 109,000 pounds of releases and transfers of carbon tetrachloride, methyl isobutyl
        ketone, &nd xylene by substituting water-based adhesives and paints for solvent-based adhe-
        sives and paints.

•       Eliminated 30,000 pounds of releases and transfers of chromium and chromium compounds
       , -used in coloring processes that are part of the metal finishing operations. This reduction was
        achieved through waste minimization techniques such as  counter-current rinsing, reduced
        drag-out rates, and unproved quality  control.

•       Reduced releases and transfers of cadmium and cadmium compounds by 15,000 pounds by
        substituting zinc plating for all of the  cadmium plating process carried out in metal  finishing
        operations.  Cyanide releases and transfers associated with the cadmium plating operations
        nave increased.  This increase is due to the fact  that the company switched approximately
        50% of its cyanide treatment from on-site to off-site. (Waste treated on-site is reported only
        for quantities  not destroyed or removed, while the full quantity treated off-site is reported as
        a transfer).  Parker estimates, however, that releases and transfers of cyanide will be elimi-
        nated by 1994 when the conversion to zinc plating will be complete at all of its facilities.

In addition to these activities, Parker is working with steel suppliers to minimize emissions of metals
during machining operations by developing raw  material steel with  a low or zero lead content. This
effort is currently in the development stage, but promising results are expected in the future.  In the
meantime, Parker achieved reductions in metal emissions through improved scrap recovery and control
methods.  However, because these reductions are relatively small, they are not measured  by  the
company and therefore cannot be quantified.

As a result of Parker's pollution prevention efforts, releases  and transfers of selected chemicals
decreased by more than 1,350.000 pounds between 1988 and 1992. This reduction of 71 % exceeds
the company's Program goal of a 50% reduction more than three years ahead of schedule.
                                           1-20

-------
PRINTED CIRCUIT BOARDS

Printed Circuit Corporation, located in Woburn, Massachusetts, is a manufacturer of printed circuit
boards. The company provides its products to companies in the electronics, instrumentation,
telecommunication, and automotive industries.

In order to meet its program goals, Printed Circuit adopted a two-step approach, first, the
company focused its efforts on eliminating all use of dichloromethane in its operations. To accom-
plish this goal, the company implemented a process that uses a water-based cleaner to strip away
excess polymer from the etched circuit boards.  In addition, Printed Circuit switched all solvent
cleaning operations to l,i,l-trichloroethane.  These changes eliminaffd all use of dichloromethane
at Printed Circuit by the end of 1991.  As a result of the process change,  the company also was
able to minimize its use of meuanoL

Although the switch to 1.1,1-trichloroethane for all solvent cleaning operations caused releases of
the chemical to increase between 1990 and 1991, Printed Circuit showed an overall reduction in
releases of selected chemicals between the two years.  The company believed that by focusing its
efforts on one chemical at a time, it would be able to make more rapid progress toward reducing
emissions than if it were addressing several chemicals simultaneously.

To eliminate the use of 1,1,1-trichloroethane, the company undertook an evaluation of potential
replacements.  Printed Circuit worked with six vendors nationwide over a two-year period to
identify replacements that would;

•       be compatible with other chemicals and materials  used in production;
•       comply with environmental  standards; and
•       be economically feasible.

As a result of  the study, the company has replaced its use  of 1,1,1-trichloroethane as a developing
agent with a water-based sodium carbonate solution. In addition, Printed Circuit now uses a mild
detergent with water tor the final cleaning of completed circuit boards, in place of dichloromethane
and 1,1,1-trichloroethane.

As a result of  these efforts, Printed Circuit Corporation reduced total releases of selected chemicals
by 87% from 1988 to 1991 after the elimination of dichloromethane. Furthermore,the company
completely eliminated releases of all 17 selected chemicals by 1993 after the elimination of 1,1,1-
trichloroethane, far surpassing its goals.
                                           1-21

-------
AIRCRAFT, RESIDENTIAL AND COMMERCIAL APPLIANCES

Raytheon Company is a diversified organization whose major interests include manufacturing of
aircraft, residential and commercial appliances (including refrigeration, cooking, and laundry equip-
ment), electronic? (including guidance systems, guided missiles, printed circuit boards, and
communications equipment), and energy/environmental services (including power, transportation,
logistics support,  and road building equipment).  Raytheon is headquartered in Lexington, Massa-
chusetts and had twenty five facilities in the United States that reported releases and transfers of
chemicals in 1988.

Raytheon's reductions of selected Chemicals were achieved as a result of several on-going projects.

•       Eliminate or reduce solvents in cleaning operations.  Dichloromethane, 1,1,1-trichloro-
        ethane, tetrachloroethylene, trichloroethylene, and CPC-113 were all targeted by
        Raytheon's ODS and suspected carcinogen, phaseout goals. In 1988, these solvents were
        used at 18 facilities for electronics cleaning and metal degreasing, and as general solvent
        cleaners.

        Terpene-based cleaners and mildly alkaline aqueous solutions were identified as alterna-
        tives to these solvent cleaners, Raytheon has successfully eliminated its use of
        dichloromethane, tetrachloroethylene, and CFC-113, and nas significantly reduced its use
        of 1,1,1-trichloroethane and trichloroethylene as a result of the development of these alter-
        nate cleaners.

•       Eliminate the use Of dichloromethane for paint stripping applications.  At the Wichita
        facility, dichloromethane was used to strip paint from aircraft. Raytheon implemented a
        dry media (wheat starch) blasting system for paint stripping that completely eliminated the
        need for  dichloromethane at this facility.

•       Reduce 33/50 Program chemicals in painting and soldering applications. Lead, chromium,
        toluene, and xylene are used at Raytheon facilities in painting and soldering operations.
        Raytheon has identified and implemented a powder paint system in some facilities which
        nas resulted in a reduction of releases and transfers of these chemicals. For applications
        in which  powder painting is not technically feasible, Raytheon is working with its coating
        suppliers to reduce the amount of solvent used in its coatings.

As a result of these and other efforts, Raytheon's releases and transfers of selected chemicals
decreased over 2.5 million pounds between 1988 and 1992 — a 65% reduction from 3,883,820
pounds to 1,360,658 pounds.  The major components of this reduction were the elimination of
dichloromethane and tetrachloroethylene, and the significant reduction of releases and transfers of
1,1,1-trichloroethaneand trichloroethylene.

The phaseout of the use of dichloromethane and tetrachloroethylene resulted in a reduction of
706,701 pounds of releases  and transfers  of these chemicals between 1988 and 1992. These reduc-
tions account for approximately 28% of total reductions of releases and transfers of these chemicals
during that period.  The replacement of 1,1,1-trichIoroedume and trichloroethylene resulted in a
reduction of 1,354,654 pounds of releases and transfers of these chemicals. This reduction
accounts for approximately 54% of total reductions from 1988 to 1992.
                                           1-22

-------
INTEGRATED  STEEL

U.S. Steel is a large, integrated steel manufacturer and also includes several smaller diversified
businesses.  USX Corporation also is involved in the oil and natural gas businesses through its
Marathon Oil Group and Delhi Group.  U.S. Steel has its headquarters in Pittsburg, Pennsylvania,
and operates six wholly-owned plants which report releases and transfers of chemicals.  In
addition, U.S. Steel is involved in several joint Ventures including USS/POSCO Industries and
USS/Kobe Steel.

Four of U.S. Steel's six facilities are in Pennsylvania:  The Clairton Works (Clairton), and the
Edgar Thomson (Braddock), Irvin (West Miffin), and Fairless (Forest Hills) plants on the Man
Valley Works.  The other plants are the Gary (Indiana) Works and die Fairfield (Birmingham,
Alabama) Works.

U.S. Steel expected to achieve its reductions through material reuse/recycling, process modifica-
tions, and product changes.  Based on its reported 1988 emissions data, the company's goal trans-
lates into an overall reduction of 2,250,952 pounds in total releases and transfers.

U.S. Steel  achieved significant reductions in releases  and transfers of selected Program chemicals
through source reduction and recycling initiatives at several of its facilities.  Examples of specific
changes implemented by the company include:
                                  *                  ^^
•       Installation of inert gas blanketing systems.  These systems use nitrogen to confine air
        emissions of volatile toxic chemicals such as benzene, cyanide, toluene, and  xylene.  By
        maintaining a layer of bert gas over an open tank or container,  toxic chemical vapors are
        unable to escape from the tank. U.S. Steel has installed blanketing systems on product and
        by-product storage tanks and decanters at both its Gary and Clairton plants.

•       Implementation of dust pelletiang process.  In  the Steel making operations, pollution
        control dusts  containing iron units and various metallic compounds are produced.  Under
        normal circumstances, these dusts are landfilled.  Because of the recoverable iron units in the
        dusts, the Edgar Thomson plant, U.S. Steel Mon Valley Operations has implemented a
        pelletizing operation. The pellets are recycled back into the steel making operations.

•       Modification of coke quenching process.  After the coke is removed from the Coke ovens,
        it must be cooled rapidly. Previously, the Clairton Works used contaminated water to quench
        the coke.  Use of contaminated water, however, resulted in releases of 33/50 Program
        chemicals such as benzene and toluene. The facility switched to clean quench  water 100%
        of the time,  thus  eliminating the releases of benzene  and toluene  from the quenching
        operations. The contaminated water is currently treated at the facility's waste water treatment
        plant where contaminants are removed to permitted levels.

As a result of these and a variety of other projects and initiatives, U.S. Steel has surpassed its goal
of a 30% reduction in releases and transfers by 1992. The company successfully reduced its overall
releases and transfers of selected chemicals by 6,582,277 pounds, amounting to a reduction of 88%
from 1988  levels.  In  addition, although not an explicit part of U.S. Steel's goals, the company
reduced annual releases and transfers of other selected chemicals by almost 14 million pounds from
20,148,876 pounds for a reduction of 69% since 1988.

Overall, U.S. Steel has reduced its  annual releases and transfers of all chemicals by a remarkable
20,508,069 pounds since 1988.  This represents a 74% reduction in all releases and transfers.
                                           1-23

-------
This page left blank
        1-24

-------
VII

-------
INDUSTRIAL PROCESSES

-------
                        INDEX








SECTION




1     Petrochemical Industry




2     Chemical Manufacturing




3     Synthesized Pharmaceutical Manufacturing Plants




4     Metallurgical Industries



5     Tanneries




6     Cement Industries



7     Printed Circuit Board Manufacturing



8     Electroplating



9     Lead Smelting

-------

-------
                           PETROCHEMICAL INDUSTRY

The petrochemical industry is a large and complex source category that is very difficult to
define because its operations are "intertwined functionally or physically with the inorganic
sector of  the chemical  industry, with  downstream  (manufacturing),  fabrication  or
compounding activities, or with the petroleum refining industry.  (This results in) mixing of
vertical operating steps in official statistics".  Petrochemical industries are involved in the
production of several chemicals which fit into one or more of the following four categories:

       1.  Basic raw materials
       2.  Key intermediates
       3.  Minor intermediates
       4.  End products

The petrochemical industry also includes the treatment of hydrocarbon streams from the
petroleum refining industry and natural gas liquids from the oil and gas production industry.

Some of the  raw  materials used in the  petrochemical industry include petroleum,  natural
gas, ethane, hydrocarbons, naphtha, heavy fractions, kerosene, and gas-oil.  Natural gas and
petroleum are the main feedstocks for  the petrochemical industry. That is why about 65
percent of petrochemical facilities are located at or near refineries.

The petrochemical  industry produces solvents  and chemicals of  various grades  or
specifications which are used to produce industrial organic chemicals, including benzene, the
butylenes, cresols and  cresylic acids, ethylene, naphthalene, paraffins,  propylene, toluene,
and xylenes.   Approximately 2500 organic chemical products  are produced directly or
indirectly from basic petrochemicals.   The  industrial organic chemicals produced from
petrochemicals are employed in downstream  industries  including  plastics  and   resins,
synthetic fibers, elastomers,  plasticizers, explosives, surface active agents, dyes,  surface
coatings, pharmaceuticals, and pesticides.

A.     PROCESS DESCRIPTION

A process  converts a raw material into products, by-products, intermediate products, or
waste streams. The main  processes conducted in the basic petrochemicals industry are
separation and purification.  Some chemical  conversion processes such  as  cracking,
hydrogenation, isomerization, and disproportionation are also carried out.   Six groups of
related processes, termed operations, are employed  by the petrochemical industry:

       1.  Olefins production
       2.  Butadiene production
       3.  BTX production
       4.  Naphthalene production
       5.  Production of cresols and cresylic acids
       6.  Separation of normal paraffins

Each operation employs several varied process lines and procedures. The production of 1,3-
butadiene will be used as an  example of the types of processes used in the petrochemical
industry.


                                        1-1

-------
 1,3-butadiene is a high-volume, intermediate organic chemical used commercially to produce
 various types of rubber, resin, and plastics.  1,3-butadiene is involved in several different
 reactions, including addition, oxidation, and substitution reactions; however, its main use is
 for polymerization.

 Producers of 1,3-butadiene typically generate the feedstock at the same location as the 1,3-
 butadiene production.  Most 1,3-butadiene is used in synthetic elastomer production, and
 some is used in adiponitrile production, the raw material for nylon 6,6 production.  The
 overall demand of 1,3-butadiene is expected  to increase due to the growth of specialty uses
 for 1,3-butadiene.

 1,3-butadiene is produced by one of two processes:

       (1)    Recovery from a mixed  hydrocarbon stream, and
       (2)    Oxidative dehydrogenation of n-butenes.

 1,3-butadiene production through recovery is by far the most common approach.  In this
 process, a mixed hydrocarbon stream containing butadiene, reproduced in an olefins plant
 during cracking of large-molecule hydrocarbons to manufacture ethylene or other alkenes
 (Exhibit 1), is routed to a recovery unit where the butadiene is separated.

 In an olefins plant a steam cracking furnace is used to crack the hydrocarbon feedstock.
 The heavy hydrocarbons are broken into two or more fragments, forming a stream of mixed
 hydrocarbons. The concentration of butadiene in this mixed hydrocarbon stream varies with
 the type of feedstock. The flue gas from the cracking furnace is vented to the atmosphere.

 After the cracking step, the mixed hydrocarbon stream is cooled and, if naphtha or gas oils
 were the initial feedstock, the stream is sent to a gasoline fractionator. The fractionator is
 used to recover heavy hydrocarbons (C5 and higher). For some olefins units the quenching
 step shown occurs after gasoline fractionation.  The mixed stream is then compressed prior
 to removal of acid  gas (hydrogen sulfide) and carbon monoxide.  Acid removal usually
 involves a caustic wash step.  The mixed hydrocarbon stream then goes through additional
 refining steps, where it is separated from olefins (Q and lower).

The mixed C4 stream may be sent directly to butadiene recovery at the same plant. Olefins
plants that do not produce finished butadiene use the by-product mixed C4 streams in the
following ways:  (1) recover the crude butadiene from the stream and sell it to a butadiene
producer,  (2) recirculate the stream into  the front of the ethylene process, and/or (3) use
the stream to fuel the equipment (e.g., furnaces) in the ethylene process.

The second part of this butadiene production process involves recovering the butadiene from
the mixed C4 stream.  The mixed C4 stream is fed from pressurized  storage tanks into a
hydrogen reactor along with hydrogen to convert some of the unsaturated hydrocarbons such
as acetylene to olefins.  The product C4 stream from the hydrogenator is combined with a

                                        1-2

-------
                                             EXHIBIT 1:
     Process Diagram for Production of a Mixed C(4)  Stream  Containing Butadiene
                                                VENT B
FEEDSTOCK
 STEAM
             4

              1
               VENT A
   	|\STEAM
       \  CRACKING
     	h\   FURNACE
                    i
                    4

                    1
                     VENT A
                                                  t
                                           CONTROL DEVICE (S)
                                             (IF INSTALLED)
        i
       4

        1
                                                 VENT A
DEGASSING
   VENT A
             4

              1
FUEL
     HYDROCARBONS
QUENCHING
S
1
r
fc.
w
GASOLINE
FRACTIONATION
\
r
                                                                        VENT A
                                                           OLEFINS
                                                         TO RECOVERY
                                               COMPRESSORS
1
                                     OLEFINS
                                   TO RECOVERY
                                                    4
                                                                              STREAM TO BUTADIENE
                                                                                RECOVERY PROCESS
                           Denotes potential  location of emission source
                                                                A  - Denotes process vent

                                                                B  - Represents  emissions after a control  device

-------
solvent (typically furfural) and fed into an extractive distillation operation. In this operation,
most of the butanes and butenes are separated from butadiene, which is absorbed in the
solvent along with residual impurities. A stripping operation is then used to separate the
butadiene from the solvent.

The stream containing butadiene typically has a small amount of residuals.  Some of these
residuals are alkynes that were not converted to olefins in the hydrogenation reactor. These
residuals are removed from the butadiene stream by distillation and are usually vented to
an emission control device. The bottom stream exiting the acetylenes removal operation
contains butadiene and residuals such as polymer and 2-butene. The residuals are removed
in the butadiene finishing operation and sent to a waste treatment system or recovery unit.
The finished butadiene is then stored in pressurized  tanks.

In the dehydrogenation process, steam and air are combined with n-butenes and preheated,
then passed through a dehydrogenation reactor.  Hydrogen is removed from the butenes
feed stream.  Next,  the stream is compressed and sent to a hydrocarbon absorption and
stripping process. The product is then routed to a light-ends column for further separation.
Finally, distillation and separation take place, with the finished butadiene sent to storage.

B.    SOURCES OF POLLUTION

There are five main sources of pollutant emissions in the production of 1,3-butadiene:

      •      process vent discharges,
      •      equipment leaks,
      •      secondary sources,
      •      storage, and
      •      emergency or accidental releases.

Process vent discharges can be from reactor  vessels, recovery columns, and other process
vessels.   Equipment leaks include pump seals, process valves, compressors, safety relief
valves, flanges, open-ended lines, and sampling connections.  Secondary  sources include
process and other waste streams.  Emissions from storage vessels are assumed negligible
since 1,3-butadiene is stored in  pressure vessels with no breathing or working losses. There
are no data available regarding emission amounts from emergency or accidental releases.

C.    POLLUTANTS AND THEIR CONTROL

Exhibits 2 and 3 identify air pollutants and hazardous waste pollutants, respectively.  Little
information is available regarding amounts  of  pollutant  emissions  from the entire
petrochemical industry, including 1,3-butadiene production. Many petrochemical processes
are located at or near petroleum refining operations; therefore, many of the air pollutants
and hazardous wastes generated by the petroleum industry are also present at petrochemical
facilities.  It is important to note that the Exhibits  represent facility-wide pollution.

                                        1-4

-------
In general, the waste streams from the petrochemical industry are quite similar to those of
the petroleum refining industry.  Limited data are available, but almost all assume waste
management operations and facilities are probably of the same degree of sophistication as
those of the petroleum refining industry.

Wastewater, which is a basic source of emissions, can be categorized in five ways:

       (1)    Wastes containing a principal raw material or product;
       (2)    By-products produced during reactions;
       (3)    Spills, leaks, washdowns, vessel cleanouts, or point overflows;
       (4)    Cooling tower and boiler blowdown, steam condensate, water  treatment
             wastes, and general washing water; and
       (5)    Surface runoff.

Disposal of solid wastes is  a significant problem for the petrochemical industry.  Waste
solids include water treatment sludges, ashes, fly ash and incinerator residue, plastics, ferrous
and nonferrous metals, catalysts, organic chemicals, inorganic chemicals, filter cakes, and
viscous solids. General methods of disposal are depicted in Exhibit 3.
               Exhibit 2:  Pollutant Profile of the Petrochemical Industry
Pollutants
Participates
VOC
Hydrocarbons
SOX
NO,
CO
Chemicals used or produced (benzene,
1,3-butadiene, naphthalene)
Control Device
• (For gases)
• Gas recovery (boiler)
- Flare
- Incinerator




Control
Efficiency (%)

99.9
98
98




                                                            r,-- —7-
                                         1-5

-------
       Exhibit 3:  Hazardous Waste Generation From the Petrochemical Industry
             Pollutant
  Amount
  Disposal Method
 Hazardous solids
 Hydrocarbons

 Any hazardous chemicals used or
 produced
Not available
Not available

Not available
   Land disposal

    Incineration

  Salvage & recycle

Chemical & biological
     treatment
D.    REFERENCES

1.     Federal Energy Administration (Office of Economic Impact).  Report to Congress
      on Petrochemicals. Public Law 93-275, Section 23 (no date:  circa 1974).

2.     Industrial Process Profiles for Environmental Use.  Chapter 5 - Basic
      Petrochemical Industry. EPA document 600/2-77-023, January, .1977.

3.     Locating and Estimating Air Emissions from Sources of 1.3-Butadiene. EPA
      document 450/2-89-021, December, 1989.
                                        1-6

-------

-------
                          CHEMICAL MANUFACTURING
A.    PROCESS DESCRIPTION

Due to the  broad expanse  and complexity of the chemical  manufacturing industry,
acrylonitrile manufacturing has been selected as being representative of it; however, process
procedures may vary somewhat between different chemical industries.

Nearly all of the acrylonitrile (ACN) produced in the world today is produced using the
SOHIO process for ammoxidation of propylene and ammonia.  The overall reaction takes
place in the vapor phase in the presence of a catalyst.  Exhibit 1 shows a typical simplified
process flow diagram for an uncontrolled SOHIO process.

The primary by-products of the  process are hydrogen cyanide,  acetonitrile, and carbon
oxides.  The recovery of these by-products depends on such factors as market conditions,
plant location, and energy costs.  Hydrogen cyanide and acetonitrile, although they carry a
market value, are usually incinerated, indicating that the production of these by-products has
little effect on the economics of producing ACN.

In the process represented in  Exhibit 1, by-product hydrogen cyanide and acetonitrile are
routed to an incinerator. Variations within the SOHIO process may provide for purification,
storage, and loading facilities for these recoverable by-products. Other variations of the
SOHIO process include the recovery of ammonium sulfate from the reactor effluent to allow
for biological  treatment of a wastewater stream and variations in catalysts and reactor
conditions.

In the standard SOHIO process, air, ammonia, and propylene are introduced into a fluid-
bed catalytic reactor operating at 5-30 psig and -400-510°C (750-950°F).  Ammonia and air
are fed to the reactor in slight excess of stoichiometric proportions because excess ammonia
drives the reaction closer to completion and air continually regenerates the catalyst.  A
significant feature of the process is the high conversion of reactants on a once-through basis
with only a few seconds residence time.  The heat generated from the exothermic reaction
is recovered via a waste-heat-recovery boiler.

The reactor effluent is routed to a water quench tower, where sulfuric acid is introduced to
neutralize  any unconverted  ammonia.   The product  stream then  flows  through  a
countercurrent water absorber-stripper to reject inert gases and recover  reaction products.
The operation yields a mixture  of ACN,  acetonitrile, and water  and  then is sent to  a
fractionator to remove hydrogen cyanide. The final two steps involve the drying of the ACN
stream and the final distillation to remove heavy ends. The fiber-grade ACN obtained from
the process is 99+% pure.

Several fluid-bed catalysts have been used since the inception of the  SOHIO ammoxidation
process. Catalyst 49, which represents the fourth major level of improvement, is currently
recommended in the process.
                                       2-1

-------
Emissions of ACN during start-up are substantially higher than during normal operation.
During  start-up, the reactor is  heated to operating temperature  before the  reactants
(propylene and ammonia) are introduced. Effluent from the reactor during start-up begins
as oxygen-rich, then passes through the explosive range before reaching the fuel-rich zone
that is maintained during normal plant operation. To prevent explosions in the line to the
absorber, the reactor effluent is vented to the atmosphere until the fuel-rich effluent mixture
can be achieved.  The ACN emissions resulting from this start-up procedure have been
estimated to exceed 4500 kg (10,000 lb)/h.

The absorber vent gas  contains nitrogen and unconverted oxygen from the air fed  to the
reactor, propane and unconverted propylene from the propylene feed, product ACN, by-
product hydrogen cyanide and acetonitrile, other organics not recovered from the absorber,
and some water vapor.

The ACN content of the combined column purge vent gases is relatively high, about 50%
of the total VOCs emitted from the recovery, acetonitrile, light ends,  and product columns.
The rest of the vent gases consist of noncondensibles that are dissolved in the feed  to the
columns, the VOCs that are not condensed, and, for the columns operating under vacuum,
the air that leaks into the column and  is removed by the vacuum jet systems.

For the ACN process illustrated in Exhibit 1, by-product hydrogen cyanide and acetonitrile
are incinerated along with product column bottoms. The primary pollutant problem related
to the incinerator stack is the formation of NOX from the fuel nitrogen of the acetonitrile
stream and hydrogen cyanide. Carbon  dioxide and lesser amounts of CO are emitted from
the incinerator stack gas.

Other emission sources involve the volatilization of hydrocarbons through process leaks
(fugitive  emissions) and from the  deep well  ponds, breathing and working losses from
product storage tanks, and losses during product loading operations. The fugitive and deep
well/pond emissions consist primarily of propane and propylene, while the storage tank and
product loading emissions consist primarily of ACN.

B.    SOURCES OF POLLUTION

Exhibit 2 presents an emissions profile  for sources in an ACN manufacturing facility, along
with pollution control options and their efficiencies.  Seven points are included:

      1.     Absorber vent gas
      2.     Column purge waste gas
      3.     Fugitive emissions
      4.     Incinerator stack gas
      5.     Deep well/pond emissions
      6.     Storage tank emissions
      7.     Product transport loading facility vent

Wastewater for disposal is generated mainly from the wastewater and acetonitrile columns.
                                        2-2

-------
                                           EXHIBIT  1:
                     Sources  of  Pollution at a  Typical ACN  Plant
  AIR
   AMMONIA
U)
   PROPYLENE —
                        WASTEWATER
                          COLUMN
ACETONITRILE
  COLUMN
                                    DEEP HELL
                                      POND
                                                                                          INCINERATOR
                                                                                 ACN LOADING
                                                                               Air Emissions
                                                                               Solid / Liquid Waste

-------
        Exhibit 2:  VOC and Acrylonitrile Emissions From ACN Manufacturing3
Emission Point
Absorber Vents
Column Vents
Storage Tanks
Loading"
Fugitive
Incinerator Stack
Deep Well/Pond
Emission Rate (kg/hr)
Acrylonitrile
2.05
103
13.5
3.44
9.5


Total VOC
2050
205
14.8
3.98
19.5
7.4
267
Control Method
Thermal Incineration
Catalytic Oxidation
Flare
Double Seal Floating Roof
Water Scrubber
Flare
Incinerator
Leak Detection/Maintenance
N/A
Water Scrubber
Control
Efficiency
(%)
99.9
95-97
98-99
N/A
99
98-99
99
N/A
N/A
N/A
  Model plant has an annual ACN capacity of 180 million kg, and is assumed to operate 8760 hours annually
  Loading into lank cars, does not include loading into barges
C.     POLLUTANTS AND THEIR CONTROL
1.
Air Pollution
Absorber Vent Gas.  The absorber vent gas stream contains nitrogen, oxygen, unreacted
propylene, hydrocarbon impurities from the propylene feed stream, CO, CO2, water vapor,
and small quantities of ACN, acetonitrile, and Hydrogen cyanide. Two control methods are
used to treat this stream: thermal incineration and catalytic oxidation.

The thermal incineration units have demonstrated VOC destruction efficiencies of 99.9%
or greater, while most catalytic units can achieve destruction efficiencies only in the 95-97%
range. Destruction efficiencies in the 99% and greater range can be achieved with catalytic
oxidizers, but these are not achieved on a long-term basis because of deactivation of the
catalyst by a number of causes. The advantage of catalytic oxidation is low fuel usage, but
emissions of NOX formed in the reactors  and not destroyed across the catalyst can pose
problems.
                                         2-4

-------
Column Waste Purge Gas. Waste gas releases from the recovery column, light-ends column,
product column, and the acetonitrile column are frequently tied together and vented to a
flare. The estimated VOC destruction efficiency of the flare is 98-99% for all streams with
a heat content of 300 Btu/scf or greater. The use of a flare is ideally suited for streams that
are intermittent and having heating values of 300 Btu/scf.

Fugitive emissions.  Fugitive emissions from piping, valves, pumps, and compressors are
controlled by periodic monitoring by  leak checking with a  VOC detector and a directed
maintenance program.

Incinerator Stack Gas. Staged combustion and ammonia injection are used to control the
emissions of  NOX from  the incinerator that treats  the  absorber  off-gas vent,  the  crude
acetonitrile waste gas stream, and the by-product liquid HCN stream.  Staged combustion
suppresses the formation of NO, by operating under fuel-rich conditions in the flame zone
where most  of  the  NOX  is formed  and oxygen-rich  conditions  downstream at  lower
temperatures where NOX is not appreciably formed.

Ammonia injection reduces NO, by selectively reacting ammonia with NOX.  The reaction
occurs at temperatures in the range of 870-980°C (1600-1800°F) and, as such, the ammonia
must be injected in the postflame zone of the combustion chamber. Residence times of 0.5-
1.0 second  are  required for NO, destruction efficiencies in the range of 80%, which is
compatible  with the residence time required for VOC destruction.

Deep  Wett/Pond Emissions.  Emissions of acrolein and other odorous components  in vents
from wastewater treatment steps are controlled with water scrubbers.  In some cases, pond
emissions are controlled  by adding a layer of a low-vapor-pressure oil on the surface of the
pond  to limit volatilization.

Storage Tank Emissions.  Product storage tank  emissions are controlled with double-seal
floating roofs or, in some cases, water scrubbers. Field experience indicates that a removal
efficiency of 99% can be achieved with water scrubbing.

Product Transport Loading.  Emissions from product transport loading vents are gathered
and sent  to  a  flare or incinerator for VOC control.  Destruction efficiencies of 98-99% are
achieved using the flare  and greater than 99% using incineration.

2.     Solid/Liquid Waste

Wastes include salts of hydrogen cyanide, metal cyanide complexes, and organic cyanides
(cyanohydrins) as solutions or solids. The wastewater from the wastewater column contains
ammonium  sulfate and heavy hydrocarbons, while the wastewater from the acetonitrile
column mainly contains heavy bottoms. The wastewater from both these columns is typically
discharged to a deep well  pond (Exhibit 3). Other methods of waste treatment include
alkaline chlorination  in a recycle lagoon system, and incineration.

                                       2-5

-------
   Exhibit 3:  Potentially Hazardous Wastes Generated From Acrylonitrile Production
Waste Source
Wastewater Column
Acetonitrile Column
Pollutant
Ammonium Sulfate
Heavy Hydrocarbons
Heavy Bottoms
Amount
N/A
N/A
Disposal Method
Deep well pond
Deep well pond
D.    REFERENCES

1.     Wilkinsin, Gary R.  The Manufacture and Use of Selected Inorganic Cyanides.
      Kansas City: Midwest Research Institute (for the U.S.EPA), April 2, 1976.

2.     Air and Waste Management Association.  Air Pollution Engineering Manual. New
      York: Van Nostrand Reinhold, 1992.
                                      2-6

-------

-------
          SYNTHESIZED PHARMACEUTICAL MANUFACTURING PLANTS

A.     PROCESS DESCRIPTION

The synthesis of medicinal chemicals may be done in a very small facility producing only one
chemical or in a  large integrated facility producing many chemicals by various processes.
Most pharmaceutical manufacturing plants are relatively small.  Organic chemicals are used
as raw materials and as solvents. Nearly all products are made using batch operations. In
addition, several  different products or intermediates are likely to be made in the same
equipment at  different  times  during the year;  these products, then,  are  made in
"campaigned" equipment.  Equipment dedicated to the manufacture of a single product is
rare, unless the product is made in large volume.

Production activities  of the pharmaceutical industry can be  divided into the following
categories:

       1.     Chemical Synthesis - the manufacture of pharmaceutical products by chemical
             synthesis.
       2.     Fermentation - the production and separation of medicinal chemicals such as
             antibiotics and vitamins from microorganisms.
       3.     Extraction - the manufacture of botanical and  biological products by the
             extraction of organic chemicals from vegetative materials or animal tissues.
       4.     Formulation and Packaging - the formulation of bulk Pharmaceuticals into
             various dosage forms such as tablets, capsules, injectable solutions, ointments,
             etc., that can be  taken by the patient immediately and in accurate amount.

Production of a synthesized drug consists of one or more chemical reactions followed by a
series of purifying operations.  Production lines may contain reactors, filters, centrifuges,
stills, dryers,  process  tanks, and crystallizers piped together in a specific arrangement.
Arrangements can be varied in some instances to accommodate production of several
compounds. A very small plant may have only a few pieces of process equipment but a
large plant can contain literally hundreds of pieces.

Exhibit 1  shows  a  typical flow  diagram  for  a batch  synthesis operation.  To begin a
production cycle,  the reactor may be water washed and perhaps dried with a solvent.  Air
or nitrogen is usually used to purge the tank after it is cleaned. Following cleaning, solid
reactants and solvent  are charged to the  glass batch reactor equipped with a condenser
(which is usually water-cooled). Other volatile compounds may be produced as product or
by-products.  Any remaining unreacted volatile compounds are distilled off.  After the
reaction and solvent removal are complete, the pharmaceutical product is transferred to a
holding tank.  After  each batch is placed in the holding tank, three to four washes of water
or solvent may be used to remove any remaining reactants and by-products. The solvent
used to wash may also be evaporated from the reaction product. The crude product may
then be dissolved  in  another solvent and transferred to a crystal! izer for purification. After


                                       3-1

-------
             EXHIBIT 1:  Typical Synthetic Organic Medicinal Chemical Process
                     Vent
                       A
                   Vent
                     A
        Solids
    Solvent
OJ
Vent
 A
       Reactor
    Holding
      tank
                                          Solvent
 Solvent
Distillation
Crystal izer
           Air emissions
            Liquid waste
                                                           Water solvent
                                         Vent
                                           A
  Batch
centrifuge
                                                          Water or solvent
                                                   Vent
                                                    A
Dryer
                                                                                                  Product
      Typical Cycle = 24 Hours

-------
crystallization, the solid material is separated from the remaining solvent by centrifugation.
While in the centrifuge the product cake may be washed several times with water or solvent.
Tray, rotary, or fluid-bed dryers may then be employed for final product finishing.

B.     SOURCES OF POLLUTION

Exhibit 2 identifies pollutants  from a typical pharmaceutical process.   Volatile organic
compounds may  be emitted  from  a  variety  of  sources within  plants  synthesizing
pharmaceutical products. The following process components have been identified as VOC
sources and will be discussed further: reactors, distillation units, dryers, crystallizers, filters,
centrifuges, extractors, and tanks.

1.     Reactors

The typical batch reactor is glass lined or stainless  steel  and has a capacity  of 2,000 to
11,000 liters (500-3000 gallons).  For maximum utility the tanks are usually jacketed to
permit temperature control of reactions.  Generally, each tank is equipped with a vent which
may discharge through a  condenser.  Batch reactors can be operated at atmospheric
pressure, elevated pressure, or under vacuum, and may be used in a variety of ways. Besides
hosting chemical reactions, they can act as mixers, heaters, holding tanks, crystallizers, and
evaporators.

A typical reaction cycle takes place as  follows.   After the reactor is clean and dry, the
appropriate raw  materials, usually including some solvent(s),  are  charged for the next
product run. Liquids are normally added first, then solid reactants are charged through the
manhole. After charging is complete, the vessel  is closed and  the temperature raised, if
necessary, via reactor jacket heating. The purpose of heating may be to increase the speed
of reaction or to  reflux the contents for a period which may vary from 15 minutes to 24
hours.  During refluxing,  the  liquid phase may be "blanketed"  by  an inert gas, such as
nitrogen, to prevent oxidation or other undesirable side reactions.  Upon completion of the
reaction, the vessel may be used as a distillation pot to vaporize the liquid phase (solvent),
or the reaction products may be pumped out so the vessel can be cooled to begin the next
cycle.

2.    Distillation Operations

Distillation may be performed by either of two principal methods.  In the first method, the
liquid mixture to be separated is boiled and vapors produced are condensed and prevented
from returning to the still. In the second method, part of the condensate is allowed to
return to the still so that the returning liquid is brought into intimate contact with the vapors
on the way to the condenser.  Either of these methods may be conducted as a batch or
continuous operation.
                                        3-3

-------
   Exhibit 2:  Major Pollutants From Solvent Use in Pharmaceutical Production3
Pollutant
(Solvent)
Acetic anhydride
Acetone
Amyl alcohol
Benzene
Carbon tetrachloride
Dimethyl formamide
Ethanol
Ethyl acetate
Isopropanol
Methanol
Methylene chloride
Solvent B (hexanes)
Toluene
Xylene
Ultimate Disposition (%)
Air
Emissions
1
14
42
29
11
71
10
30
14
31
53
29
31
6
Sewer
57
22
58
37
7
3
6
47
17
45
5
2
14
19
Incineration

38

16
82
20
7
20
17
14
20
69
26
70
Solid
Waste

7

8

6
1
3
7
6
22

29
5
Product
42
19

10


76

45
4




Numbers are based on a survey of 26 U.S. manufacturers
                                       3-4

-------
3.     Separation Operations

Several separation mechanisms employed by the industry are extraction, centrifugation,
filtration, and crystallization.

Extraction is used to separate  components of liquid mixtures or solutions.  This process
utilizes differences in solubilities of the components rather than differences in volatilities (as
in distillation); i.e., solvent is used  that will  preferentially combine with  one of  the
components. The resulting mixture to be separated is made up of the extract which contains
the preferentially dissolved material and the raffinate which is the residual phase.

Centrifuges are used to remove intermediate or product solids from a liquid stream.  Center-
slung, stainless steel basket centrifuges are most commonly used in the industry. To begin
the process, the centrifuge is started and the liquid slurry is pumped into it. An inert gas,
such as nitrogen,  is sometimes introduced into the  centrifuge to avoid the buildup of an
explosive atmosphere.  The spinning centrifuge strains the liquid through  small basket
perforations. Solids retained in the basket are then scraped from the sides of the basket and
unloaded by scooping them out from a hatch on the top of the centrifuge or by dropping
them through the centrifuge bottom into receiving carts.

Filtration is used  to remove solids from a liquid; these solids  may be product, process
intermediates, catalysts, or carbon particles (e.g., from a decoloring step).  Pressure filters,
such as shell and leaf filters, cartridge filters, and plate and frame filters are usually used.
Atmospheric  and vacuum  filters have their  applications too.   The normal filtration
procedure is  simply to  force  or draw  the  mother liquor through  a filtering medium.
Following filtration, the retained solids are  removed from the filter medium  for further
processing.

Crystallization is  a means of separating an  intermediate or final product from a liquid
solution.  This is done by creating  a supersaturated solution, one  in which the desired
compound will form crystals.  If performed properly  and in the absence of competing
crystals, crystallization can produce a highly purified product.

4.     Dryers

Dryers are  used to remove  most of  the  remaining solvent in  a centrifuged  or filtered
product.  This is done by evaporating solvent until an acceptable  level  of "dryness" is
reached.  Evaporation is accelerated by applying heat and/or vacuum to the solvent-laden
product or by blowing warm air around or through it.  Because a product may degrade
under severe drying conditions, the amount of heat, vacuum, or warm air flow is carefully
controlled.  Several types of dryers are used in synthetic drug manufacture.  Some of  the
most widely used are tray dryers, rotary dryers, and  fluid bed dryers.
                                         3-5

-------
5.     Storage and Transfer

Volatile organic compounds are stored in tank farms, 233 liter (55 gallon) drums, and
sometimes in process holding tanks.  Storage tanks in tank farms range in size from about
2,000-20,000 liters (500-5,000 gallons). In-plant transfer of VOCs is done mainly by pipeline,
but also may be done manually (e.g. loading or unloading drums).  Raw materials are
delivered to the plant by tank truck, rail car, or in drums.

C.     POLLUTANTS AND THEIR CONTROL

1.     Air Emissions

Solvents constitute the predominant  VOC emission from production.  Plants  differ in the
amount of organics used; this results in widely varying VOC emission rates.  Therefore,
some plants may be negligible VOC sources while others are highly significant. In addition,
all types of equipment previously described have the potential to emit air pollutants.

a.     Reactors

Reactor emissions stem from the following causes: (a) displacement of air containing VOC
during reactor charging, (b) solvent evaporation during the reaction cycle (often VOCs are
emitted along with reaction by-product gases which act as carriers), (c) overhead condenser
venting uncondensed VOC during refluxing, (d) purging vaporized VOC remaining from a
solvent wash, and (e) opening reactors during a reaction cycle to take samples, determine
reaction end-points, etc.

Equipment options available to control emissions from reactors include surface condensers,
carbon adsorbers,  liquid scrubbers,  and vapor incinerators (under  certain  conditions).
Condensers are often included on reactor systems as normal process control equipment.

b.     Distillation Operations

Volatile organic compounds may be emitted from the distillation condensers used to recover
evaporated solvents. The magnitude of emissions depends on the operating parameters of
the condenser, the type and quantity of organic being condensed, and the quantity of inerts
entrained in the organic.

Emissions from distillation condensers can be controlled through the use of aftercondensers,
scrubbers, and carbon adsorbers.

c.      Separation Operations

I.     Emissions from  batch extraction stem  mainly from displacement of  vapor while
       pumping solvent into  the extractor and while purging or cleaning the vessel after


                                       3-6

-------
       extraction.  Some VOCs also may be emitted while the liquids are being agitated.
       A  column  extractor  may  emit VOCs  while the column is  being filled, during
       extraction, or when it is emptied after extraction.  Emissions occur not only at the
       extractor itself, but also at associated surge tanks. These tanks may emit significant
       amounts of solvent due to working losses as the tank is repeatedly filled and emptied
       during the extraction process.

2.     A large potential source of emissions is the open-type centrifuge which permits large
       quantities of air to contact and evaporate solvents.  The  industry trend is toward
       completely  enclosed  centrifuges and, in  fact,  many  plants  have  no  open-type
       centrifuges.  If  an inert gas blanket is used, it can act as a transport vehicle for
       solvent vapor.  This vapor may be vented directly from the centrifuge  or from a
       process tank receiving the mother liquor. However, this emission source is likely to
       be small because the inert gas flow is only a few cubic  feet per minute.

3.     If crystallization is done mainly through cooling of a solution, there will be little
       VOC emission.  In fact, the equipment may be completely enclosed. However, when
       the crystallization is done by solvent evaporation, there is greater potential for
       emissions. Emissions will be significant if evaporated solvent is vented directly to the
       atmosphere.  It is more likely,  however, that the solvent will be passed through a
       condenser or from a vacuum jet (if the crystallization is done under vacuum), thereby
       minimizing  emissions.

       Several add-on  control technologies  may  be used on  the separation equipment
       described above.  Condensers,  which can be applied  to individual systems, are
       effective and may be the least costly option. Water scrubbers also have found wide
       usage in the industry.  They are versatile and capable of handling a variety of VOCs
       which have appreciable water solubility. Scrubbers can be either small or quite large;
       thus, they can be designed to handle emissions from a  single source or from many
       sources (via a manifold system).  Carbon adsorbers can be and have been employed
       on vents from separation operations.  Several vents may be ducted to an adsorber
       because it is likely that emissions from a single source would not warrant the expense
       of  a carbon adsorption  unit.   Finally, in some  instances, incinerators  may  be
       applicable.  They may not be a good choice, however, since the expected variability
       from these emission sources might make continuous incinerator operation difficult.

4.     Enclosed pressure filters normally do not emit VOCs during a filtering  operation.
       Emissions can occur, however, when a filter is opened to remove  collected solids.
       Emissions can also occur if the filter is purged  (possibly  with nitrogen  or steam)
       before cleaning.  The purge gas will  entrain evaporated solvent and probably be
       vented through the receiving tank for the filtered liquid.  The largest VOC emissions
       are from vacuum drum  filters which are  operated by pulling solvent  through a
       precoated filter drum. Potential emissions are significant both at or near the surface
                                        3-7

-------
       of the drum and from the ensuing waste stream. These filters can be shrouded or
       enclosed for control purposes.

d.     Dryers

Dryers are potentially large emission sources.  Emission rates vary during a drying cycle and
are greatest at the beginning of the cycle and least at  the end of the cycle.  Drying cycle
times can range from several hours to several days.  Control options used for dryers include
condensation, wet scrubbing,  adsorption, and  incineration.

1.     Condensers are  often the  first  control devices selected  when dealing  with  air
       pollution from vacuum dryers. They can also be used by themselves or in series with
       another device.   Condensers are not typically used  on  air dryers  because the
       emissions are dilute.

2.     Wet scrubbers  have also been used to control many plant sources, including dryers.
       They can  also remove particulates  generated  during  drying.  For water soluble
       compounds, VOC absorption efficiencies can be quite high (i.e. 98-99%).

3.     Carbon adsorbers may also be used, especially following a condenser. Not only will
       overall efficiency increase  but  a longer regeneration cycle  can  be used in the
       adsorber.

4.     Vapor  incinerators might be viable controls although varying VOC flows to the
       incinerator may present operating problems.

e.     Tanks

The vapor space in a tank will in time become saturated with the stored organics. During
tank filling vapors are displaced, causing an emission or a "working loss." Some vapors are
also displaced as the temperature of the stored VOC rises, such as from solar radiation, or
as atmospheric pressure drops; these are "breathing losses." The amount of loss depends
on type of VOC stored, size of tank, type of tank,  diurnal temperature changes, and tank
throughput.

Emissions from storage or process holding vessels may be reduced with varying efficacy
through the use of vapor balance systems, conservation  vents, vent condensers, pressurized
tanks, and carbon adsorption.
                                        3-8

-------
2.     Solid and Liquid Wastes
The manufacture of the following types of pharmaceutical products can generate hazardous
wastes:

       •     Organic medicinal chemicals
       •     Inorganic medicinal chemicals
       •     Antibiotics
       •     Botanicals
       •     Medicinals from animal glands.

The largest quantities  of hazardous waste are from the  production of organic medicinal
chemicals  and  antibiotics.   Exhibit  3  identifies  potential hazardous  wastes  from
pharmaceutical production:

       Exhibit 3: Potential Hazardous Wastes from Pharmaceutical Production
Product or Operation
Organic medicinal chemicals
Inorganic medicinal chemicals
Antibiotics
Botanicals
Medicinals from animal glands
Biological products
Misc. sources
Potential Hazardous Wastes
• Heavy metals
• Terpenes, steroids, vitamins,
tranquilizers
• Ethylene dichloride
• Acetone, toluene, xylene,
benzene isopropyl alcohol,
methanol, acetonitrile
• Zinc, arsenic, chromium,
copper, mercury
• Selenium
• Amyl acetate, butanol, butyl
acetate, MIK, acetone,
ethylene glycol, monomethyl
ether
• Ethylene dichloride,
methylene chloride
• Methanol, acetone, ethanol,
chloroform, heptane, naphtha,
benzene
• Misc. organics
• Misc. organics
• Vaccines, toxoids, serum, etc.
• Ethanol
Misc. solvents
Estimated U.S.
Generation (dry
metric tons/yr)1
i;7oo
13,600
3,400
23,800
2,700
200
12,000
100
100
700
800
500
300
63,900
'Hazardous waste amounts are for 1973 estimated total U.S. generation.

                                        3-9

-------
D.    REFERENCES

1.     Control of Organic Emissions from the Manufacture of Synthesized
      Pharmaceutical Products. Environmental Protection Agency, Research Triangle
      Park, NC, December 1978.

2.     The Handbook of Hazardous Waste Management. Metry, Amir A., Ph.D., P.E.,
      Technomic Publication, January, 1980.
                                    3-10

-------

-------
                         METALLURGICAL INDUSTRIES

The  metallurgical  industries can  be  broadly  divided  into primary, secondary,  and
miscellaneous metal production operations.  "Primary metals" refers to the production of
metals from ore. "Secondary metals" refers to the manufacturing of alloys by utilizing metals
from scrap and salvage, as well as ingots.  "Miscellaneous metal" production encompasses
industries with operations that produce or use metals for final products.   Metallurgical
industries include the following:

       •      Primary Aluminum                     •      Secondary Aluminum
       •      Metallurgical Coke                     •      Secondary Brass and Bronze
       •      Copper Smelting                             Melting Processes
       •      Ferroalloy Industry                     •      Iron Foundries
       •      Steel Industry                         •      Secondary Lead Smelting
       •      Primary Lead Smelting                 •      Steel Foundries
       •      Zinc Smelting                         •      Secondary Zinc

As a representative industry within the metallurgical classification, iron foundries have been
selected for discussion.

Method to control  air pollution produced by iron foundries are selected based on  the
methods of melting, the handling of sand, the types of molten metals and other materials,
and the cleaning of finished castings. Air pollutant characteristics are affected by a number
of factors, including the type of melting unit, material-handling and hooding systems, and
emission control systems.  Air pollution is prevented by  capturing the smoke,  dust, and
fumes at the furnace and  other sources, and transporting these contaminants to suitable
control devices.

A.     PROCESS DESCRIPTION

1.     Mold and Core Production

Molds are forms used to shape the exteriors of castings.  The green sand mold, the most
common type, consists of moist sand mixed with 3-20% clay and 2-5% water, depending on
the process.  To prevent  casting defects materials such  as  seacoal (a pulverized high-
volatility, low-sulfur  bituminous coal),  wood or corn flour, oat hulls,  or similar organic
matter may be added to the sand mixture. Cores are molded sand shapes used to form  the
internal voids in castings.  They are made by mixing sand with various binders, shaping it
into a core, and curing the core with a variety of processes.

2.     The Melting Process

a.    Electric Furnace (General)

In the electric furnace, the basic process operations are (1) furnace charging, in which metal,
scrap, alloys, carbon, and  flux are added  to the  furnace; (2) melting, during which  the

                                        4-1

-------
furnace remains closed; (3) back-charging, which involves the addition of more metal and
alloys; (4) refining and treating, during which the chemical composition is adjusted to meet
product specifications; (5) slag removal; and (6) tapping molten metal into a ladle or directly
into molds.

b.     Induction Furnaces

Electric induction furnaces are  either horizontal or vertical, cylindrical, refractory-lined
vessels. Heating and melting occur when the charge is energized with a low-, medium-, or
high-frequency alternating current.  Induction furnaces also may be used for holding and
superheating. Electric induction furnaces  generally have lower emissions per ton of metal
melted than the other furnace types. As a  result, in spite of a generally lower unit capacity,
induction furnaces have supplanted cupolas  in many foundries.

c.     Electric Arc Furnaces

Electric-arc melting furnaces are large, welded-steel  cylindrical vessels equipped with a
removable roof through which three carbon electrodes are inserted. The electrodes  are
energized by three-phase alternating current, creating arcs that melt the metallic charge
material.   Additional heat is generated by  the electrical  resistance of the metal to  the
current between the arc paths. The most common method of charging an arc furnace is by
removing the roof and  introducing  the charge material  directly.   Alternatives include
charging through a roof chute or side charging door.  Once the melting cycle is complete,
the metal is tapped by tilting the furnace and pouring the metal into a ladle.

d.     Cupola

The cupola is a vertical, cylindrical shaft furnace which may use pig iron, scrap iron, scrap
steel, and coke as the charge components. 'Melting is accomplished in the cupola by heat
released from the combustion of coke (the reaction between oxygen in the air and carbon
in the fuel) that is in direct contact with the metallic portion of the charge and the fluxes.

One of the advantages of using such a furnace is that counterflow preheating of the charge
material can occur. In a cupola, upward flowing hot gases come into close contact with the
descending burden, allowing direct and efficient heat exchange to take place. The running
or charge coke, which replenishes fuel consumed, is also preheated before it reaches  the
combustion zone, thus enhancing the combustion process. Greater understanding of these
features accounts, in part, for the continued popularity of the cupola  as a melting unit.
However, recent design improvements, such  as  cokeless,  plasma-fired types that alter
emission characteristics are now encountered.

3.     Casting, Cooling, and Finishing

After melting, molten metal is tapped from the  furnace and poured into a ladle or directly
into molds. If poured into a ladle, the molten iron may be treated with a variety of alloying
agents selected for their desired metallurgical  properties.  The molten material then is


                                        4-2

-------
 ladled into molds which are allowed to cool in open floor  space, or,  (in larger, more
 mechanized foundries)  are conveyed  automatically through a  cooling  tunnel  before
 separation of the casting from the mold (shakeout).  Molding and core sand are separated
 from the casting(s) either manually or mechanically.  In some foundries the cooled  molds
 are placed on a vibrating grid to shake the mold and core sand loose from the casting.
 Used sand from casting shakeout is  usually returned to the  sand preparation area and
 cleaned, screened, and processed to make new molds.  Because of process losses and
 potential contamination, additional makeup sand may be  required.

 When castings have cooled, any unwanted appendages such as sprues, gates, and risers are
 removed by an oxygen torch, abrasive saw, friction cutting tool, or hand hammer.  The
 castings then may be subjected to abrasive blast cleaning and/or tumbling to remove any
 remaining mold sand or scale.

 B.    SOURCES OF POLLUTION

 Exhibit  1 illustrates the operations of a typical iron foundry and emissions they generate.
 Processes which produce air emissions include melting (furnace or cupola), molding, core-
 making, pouring, casting shakeout, cooling/cleaning, and finishing.  These are described in
 greater detail in  the next section.

 C.    POLLUTANTS AND THEIR CONTROL

 Exhibit 2 summarizes the pollutant emissions from the various processes in a typical iron
 foundry, and indicates appropriate types of control methods.  The nature of emissions from
 each source is described in this section.

 1.    Emission  Sources

a.    Mold and Core Production

The major pollutants emitted in mold and core production operations are particulates from
sand preparation, mold core forming, and  curing.  Volatile organic compounds (VOCs),
carbon monoxide, and particulates also may be emitted during core and mold curing or
drying.

b.    Melting

The melting process begins with the handling of charge materials going  into the melting
furnace. Emissions from raw material handling are fugitive particulates generated from the
receiving, unloading, storage, and conveying operations.  Scrap preparation and preheating
may emit one or more of the following: fumes,  organic compounds, carbon monoxide, or
coarse particulates.  Scrap preparation with solvent degreasers may emit VOCs.
                                       4-3

-------
EXHIBIT 1:   Emission Points in a Typical Iron Foundry
FLUXES METAJ
T ^
^
/ FURN;
1 CUP
A
: i
Jl i Air Emissions
COKE |
! Solid / Liquid Haste
r ir
A
i
r !
VCE / \
OLA )
A A
i i
r ' '
pivcTTNn
MOLDING fc DOiipTNn fe, "*=>iinu
""""*•"*' . ^ W --WWM.I^W ^ SHAKKOUT
A
CORE
MAKING
A A
i i
v : : ~^s
COOLING AND PTHTRHTiin FINISHED
CLEANING ~ ir.nn«i PRODUCT


-------
               Exhibit 2:  Emissions From Iron Foundry Processes
           Emission Point
    Pollutants
Control Methods
Mold and Core Production
Melting
Induction and Arc Melting
Cupola Melting
Pouring, Casting, Cooling and
Finishing
particulates
VOCs
carbon monoxide
fugitive particulates
fumes
organic compounds
carbon monoxide
VOCs
particulates (metal
 oxides)
organics
dust consisting of:
 iron oxide
 silicon dioxide
 zinc oxide
 magnesium oxide
 manganese oxide
 calcium oxide
 lead
 cadmium

gases:
 carbon monoxide
 sulfur oxides
 lead
 organic emissions
particulates
magnesium oxides'
metallic fumes
carbon monoxide
organic compounds
VOCs
                                                             Wet Scrubbers
                                                              Fabric Dust
                                                          Collectors/Baghouses
                                                              Afterburners
                                                          Charcoal Absorption
                                      4-5

-------
c.     Induction and Arc Melting

The highest concentrations of furnace  emissions occur during charging,  back-charging,
alloying, slag removal, and tapping operations. These emissions are primarily particulates
(metal oxides) and possibly organics, depending on the scrap quality and pretreatment.
Typical dust loading  from electric arc furnaces can range from 10 - 15 Ib/ton melted.
Electric induction furnaces, however, may emit particulates at one tenth of that value.

d.     Cupola Melting

The quantity and composition of paniculate emissions vary among cupolas, and even at
intervals in the same cupola. Causes include changes in iron-to-coke ratios, air volumes per
ton melted, stack velocity, and the quality of the scrap melted. Where oily scrap is charged,
the raw emissions potentially will be greater in quantity and much more visible.  Based on
a survey, the average emission from an uncontrolled cupola was approximately 13 - 17
pounds of paniculate per ton melted. Eighty-five percent of such emissions may be greater
than 10 Mm in size.

Dust amount and composition vary from cupola to cupola. Each cupola has varying airflows
at different  phases in the melt process which affect the grains per standard cubic foot in
emitted stack gases if all other factors are equal. The source of the raw charge materials
also has a significant impact on dust composition and quantity.  The dust can include some
or all of the following materials:

•      Iron oxide                •     Silicon dioxide   .        •      Zinc oxide
•      Magnesium oxide         •     Calcium oxide            •      Cadmium
•      Manganese oxide         •     Lead

In addition, other gases and organic compounds may be emitted as part of the melting
process.  These include carbon monoxide, sulfur oxides, lead, and organic emissions.  Both
sulfur and organic emissions  are influenced by the amount of oil or grease on the scrap.
The quantity of sulfur oxides generated may be large enough to cause  corrosion of air
pollution control  equipment.  There are a number of instances where rapid deterioration
of dust collectors on cupolas occured where corrosion protection was not considered.
Where fluorspar  is used  as  an additive, the fluorine driven off can  cause  a corrosion
problem with dust collection  equipment.  Fluorine also has the potential  to dissolve glass
bags.   Carbonic acid, formed when carbon dioxide reacts with water vapor, may cause
corrosion problems  as well.

e.     Pre-pouring, Pouring, Cooling, and Finishing

Paniculate emissions can be generated during the treatment and inoculation of molten iron
before pouring. For example, the addition of magnesium to molten metal to produce ductile
iron causes a very violent reaction accompanied by various  emissions of magnesium oxides
and metallic fumes, depending on the method of treatment.  Some methods, such as the
tundish method, result in significantly lower emissions than others. Emissions from pouring


                                       4-6

-------
 consist of metal fumes, carbon monoxide, organic compounds, and particulates evolved when
 the molten iron contacts the mold and core materials. Emissions continue as the molds cool
 and during the shake-out operation, although at a much lower rate.  Finishing operations,
 such as the removal of burrs, risers, and gates, and shotblast cleaning, also emit particulates,
 primarily iron, iron oxide, and abrasive media. The painting of castings also can lead to a
 variety of VOC emissions.

 2.     Air Pollution Control Measures

 There are two primary collection methods for foundry particulates - wet and  dry.  Wet
 scrubbers include low- and high-energy types. Dry collection includes baghouses, mechanical
 collectors, and electrostatic precipitators.  In addition, to control emissions  of  organic
 compounds,  incineration or  afterburners may be required.   Air toxics  merit  special
 consideration, requiring careful selection of the emission control method.

 a.     Wet Scrubbers

 For paniculate collection, the mechanisms used in a wet-type collector are inertial impaction
 and  direct interception.  These are used either separately or in combination.  In studying
 wet collector performance, independent investigators developed the contact power theory,
 which states that, for a well-designed wet-scrubber, collection efficiency is a function of the
 energy consumed  in the air-to-water contact process and is  independent of the collector
 design.  On this basis, well-designed collectors operating at or near the same pressure drop
 can be expected to exhibit comparable performance.  All wet collectors  have a fractional
 efficiency characteristic ~ that is, their cleaning efficiency varies directly with the size of the
 particle being collected.  In general, collectors operating at  a very low pressure loss will
 remove only medium to coarse particles. High-efficiency collection of fine particles requires
 increased energy input, which will be reflected in higher collector pressure loss.

 In addition to particulates, gas scrubbers may be used to control odors and toxic and sulfur
 dioxide emissions.  In this case, acids, bases, or oxidizing agents may have to be added  to
 the scrubbing liquid.  Disposal of this stream is subject to effluent guidelines  for metal
 molding and casting.

b.    Dry Collectors

The most frequently encountered equipment for the removal of solid paniculate matter from
an air stream or gas stream is the fabric dust collector or baghouse.  With a mass median
size of 0.5 Aim,  a collection efficiency of 98-99+% can  be expected. As the  filter medium
becomes coated in a fabric collector, the collection efficiency rises.  However, as material
continues to build on the bag surface,  higher pressure drops occur, which result in a
significant  reduction in airflow.  To maintain design flows, the  bags must be cleaned
periodically by  mechanical shaking or with pulsed air.

Filter media are now available for hot corrosive atmospheres, such as furnace  emissions.
Operating inlet temperatures up to 500°F (260°C) are not uncommon.  High humidity can


                                        4-7

-------
be a problem if no provision is included for the  condensation  of free moisture.   Free
moisture and acid dew point are the worst enemies of all fabric collectors. It is important
to have the following design information in  order to select the proper fabric  and the
quantity of bags required:

             •      Gas flow rate
             •      Temperature and dew point
             •      Acid dew point
             •      Particle size and  distribution
             •      Concentration  of solids
             •      Chemical and physical properties of solids

Teflon-coated,  woven glass-fiber bags  have been used on a large  majority  of cupola
installations because of their high temperature resistance. If fluorspar is used, Nomex bags,
which are acid-resistant, but combustible,  are generally installed.  The temperature  of the
gases entering the baghouse then must be reduced to a maximum of 400°F (204°C). Use
of these lower-temperature  bags creates a potential corrosion hazard because of the acid
dew  point problem.  For reverse-air  and  mechanical shake collectors,  air-to-cloth  ratios
range from 1.5-2.5:1.

Pulse-jet and cartridge collectors also can be used to collect pollutants from sand systems
and casting cleaning operations.  With either type of unit, care must be taken to select the
proper air/cloth ratio (maximum of 25:1 with pulse jet and 1.5:1 with cartridge). In general,
these types  of collectors will have only  marginal results with furnace and inoculation
emissions. If considered, they should be employed at a very low air/cloth ratio. In addition,
moisture introduced with compressed  air may be significant and cause system failure.

c     Incineration

Afterburners may be used in some  processes to control emissions, particularly when oily
scrap or hydrocarbons in any form are charged into the furnaces or scrap preheat systems.
Afterburning is required for below-the-door cupola emission systems. If afterburners are
not used,  carbon monoxide  and oil  vapors may be emitted through the discharge stack of
the air pollution equipment.  In order to achieve the required incineration, sufficient
retention  time (a minimum  of 0.6 second) and ignition temperatures must be maintained.

In general, in the selection of collection devices for all processes, moisture, temperature, and
the presence of corrosive materials must be considered.   The temptation to operate at
higher air/cloth ratios in baghouses  must be avoided. Similarly, claims that lower pressure
drops in scrubbers create high efficiencies have been proved to be false.

d.     Absorption

Charcoal  absorption  has been used in  conjunction with other control devices for  VOC
control.
                                        4-8

-------
3.     Hazardous Air Pollutants From Other Metallurgical Industries
Hazardous Air Pollutants (HAPs) emitted from other metallurgical industries include both
organic and inorganic substances.  Exhibits 3 and 4 identify  some HAPs  from process
operations at steel foundries and from aluminum production.

              Exhibit 3:  Hazardous Air Pollutants from Steel Foundries
           HAPs
Potential Emission Sources
    Potential Fugitive
    Emission Sources
  arsenic
  beryllium
  chromium
  copper
  lead
  manganese
  nickel
  zinc
  iron
furnaces
foundry mold and core
decomposition
converter/charging
furnace tapping
furnace charging
metal casting
           Exhibit 4: Hazardous Air Pollutants from Aluminum Production
           HAPs
Potential Emission Sources
    Potential Fugitive
    Emission Sources
  fluorides
  chloride
  hydrogen chloride
calciner
material handling
furnaces
material crusher and mills
storage and handling areas
reduction cells
furnace tapping
furnace charging
coke quenching
D.    REFERENCES

This report contains excerpts of information taken directly from the following source:

Air and Waste Management Association.  Air Pollution Engineering Manual. New York:
Van Nostrand Reinhold, 1992.
                                       4-9

-------
THIS PAGE LEFT BLANK
       4-10

-------

-------
                                   TANNERIES
A.     PROCESS DESCRIPTION

Tanning involves a complex combination of mechanical and chemical processes. The heart
of the process is the tanning operation itself in which organic or inorganic materials become
chemically bound to the protein structure of the hide and preserve it from deterioration.
The substances generally used to accomplish the tanning process are chromium or extracts
from bark of trees, such as chestnut.  These tanning agents give rise to the two predominant
types of tanning operations - chrome and vegetable tanning.

1.     Chrome Tanning

Most leather produced is chrome tanned. Chrome tanning produces leather better suited
for certain applications, particularly for the upper parts of boots and shoes, and requires less
processing time than traditional vegetable tanning.  The general steps required for chrome
tanning of leather are shown in Exhibit 1 and described briefly below. No two tanneries are
identical; each has its unique characteristics and subprocesses; some perform only some of
the processes shown and ship their goods to another tannery to complete the processing.

Hides and skins are received from meatpacking  plants by truck or railroad car. Each
cattlehide is tied in a bundle weighing approximately 25 kg. The bundles are cut open and
the hides unfolded, inspected, and usually  split along the backbone,  producing two sides
from each hide.

Next follows a sequence of wet operations. The sides are soaked in water to return some
of the lost natural moisture.  The remaining flesh or fatty substance adhering to the inside
or flesh surface of the side is removed; these fleshings are usually either rendered in the
tannery or sold. The cattlehides are then soaked in a lime and sulfide solution which either
loosens or dissolves the attached hair. In some operations, the hair is only loosened through
the caustic action of the lime, with the hair removed mechanically, followed by washing,
drying, and  sale as a by-product (for carpet pads and similar uses).  However, the more
common approach for hair removal is to completely dissolve the hair and discharge it to the
wastewater stream.

Following hair removal, the hides are ready to be prepared for the actual tanning operation.
The  hides are placed in large rotating drums and treated in turn with an enzyme solution
and  then a salt-acid  solution.  These operations (respectively called bating and pickling)
prepare the hide for the tanning process.  While still in  the drum after discharge of the
pickling solution, the hides are tanned. A chromium sulfate solution is added to the drum
and  the hides and chrome solution are mixed for periods of up to 24  hours.

Following chrome tanning, all hides have a characteristic blue color caused by the chrome
tanning solution. Upon removal from the tanning drums, excess moisture is removed from
the hides through a wringing operation.
                                       5-1

-------
    EXHIBIT 1: Process Flow Diagram of a Typical Chrome Tannery

c.. , Bate Wr
Side soak . «,
_,. , *• 1 1CK1C ~ *• op
Fl6Sh Tan Sta
)
' >
V
r
in
li
IV
\
if

g
t
e
r







Retan
Color
Fat liquor

)

if



D
Cond
Fin
Tr

^

ry
lition Finished
lsh *" leather
im
Y To sanitz
landfil
i


Air emissions
Liquid waste
Solid waste
   Y



To sewer

-------
Cattlehides are too thick for most purposes so the tanned hides are split using a machine
similar to a horizontal band saw.  The splitting operation produces a grain side of more or
less uniform thickness. One surface of this grain side is the original  outer surface of the
cattlehide and retains the natural grain.  The splitting operation also yields a thin, inner
portion of the hide known as a "split" or "blue drop." Splits have no graining and are often
used for suede garments. Both the grain side and the split may be further processed to form
a piece of material of uniform thickness.  This operation is called shaving and results in the
removal of small pieces of leather with a consistency similar to very coarse sawdust.

Another series of wet operations gives the leather the color and other properties desired in
the  finished material.  The tanned hides are placed into another drum for retanning,
coloring, and fatliquoring. Retanning is a second, shorter tanning operation normally using
a tanning agent other than chromium. After the retanning solution is  discharged from the
drum, a pigment is added in order to dye the leather to the desired color.  The coloring
solution is also discharged from the drum. Next a mixture of oils is added and the hides and
oil are rotated in the drum. This operation, called fatliquoring, helps to produce the desired
softness.

After removal from the retan, color, and  fatliquor drum, the leather is dried and physically
conditioned. The two most common approaches to this conditioning are staking  and buffing.
Staking is a form  of massaging which makes the leather more pliable.  Buffing is a light
sanding operation applied to either the grain surface or the underside of a piece of leather.
It  is used to improve the nap  of the underside or to smooth out surface imperfections on
the grain surface.

One or more of several possible finishing steps give the leather the required pattern gloss
or waterproof qualities.  Usually all leather receives at least one  coat of a liquid finish
material. Finishes are either rolled or sprayed onto the leather. Often three or more coats
of finish are applied to leather,  each one  followed by a drying cycle.  Other finishing
operations include embossing, in which patterns are pressed  into the leather surface.
Finally, the  surface area of each piece of leather is measured electronically and the area
stamped on the underside.  The leather is then packaged and stored for shipment.

2.      Vegetable Tanning

Vegetable tanning employs the use of extracts from the bark of various trees as  the tanning
agent.  Since the introduction of chrome tanning, vegetable  tanning  has  decreased in
importance.  Soles of shoes have been traditionally vegetable tanned; however, since the
introduction of synthetic materials for shoe soles, vegetable tanning has  further decreased
in  importance.  Vegetable tanning is also used to produce leather used in crafts.

Many of the basic steps used in the chrome tanning process are also present in vegetable
tanning. The sequence in which these steps are employed is somewhat different, and there
are few finishing operations associated with vegetable tanning. The processing of hides prior
to  vegetable tanning begins with a soak in lime to loosen the hair.  Hides are then removed
from the lime solution and the hair is removed mechanically. The hides are then soaked
and  rinsed, and the fleshing operation is accomplished.  Note that in  the chrome tanning

                                        5-3

-------
process, fleshing preceded the hair removal operation. After fleshing, the hides are trimmed
into a roughly  rectangular shape and then passed  through a bate and  pickle operation
similar to that used in the chrome tanning process.  Coloring, the next operation, is often
done utilizing a weak  tanning solution.  Normally vegetable tanned leather is not highly
colored.  After  coloring, the hides are placed into vats containing the bark extract tanning
solution and moved from a strong tanning solution to a slightly weaker one, then rinsed and
partially dried.

True splitting is not usually a part of the vegetable tanning process; however, an operation
called leveling is used to produce a uniformly thick piece of leather. Leveling removes only
the thickest portions of the underside of the hide, and no "split" is produced.  Next, the hide
is oiled, which is a process similar to the fatliquoring in chrome tanning.  Following oiling,
the hide is dried and then mechanically conditioned.

Virtually no finishing is done at vegetable tanneries.  Few, if any, spray finishes  are applied
and often the only finishing process employed is pressing to yield a smooth grain surface.
Finally, the hides are  measured, packaged, and stored prior to shipment.

B.     SOURCES OF POLLUTION

Typical sources of emissions include (1) solvent receiving, (2) mixing vault, (3) supply drum,
(4) spray chamber, (5) dryer, (6) receiving recycled solvents, (7) cleaning operation, (8)
waste solvent storage  (See Exhibit 2 for  air emissions  and solid waste generation points).

C.     POLLUTANTS AND THEIR CONTROL

1.      Air Emissions

Typical pollutants (either solid or gaseous) from a tannery include chlorine, formaldehyde,
sulfuric acid, glycol ether EB, glycol ether PMA, methyl isobutyl ketone,  toluene, xylol,
phosphoric acid, methanol, manganese sulfate, chromium III, ethylene glycol, lead, copper,
and zinc.  See Exhibit 2 for  a sample listing of toxic air pollutants and their amounts.

Air pollution control  methods can include the use of a water fall (efficiency  = 50% for
particulates and 10%  for VOC),  a fume  incinerator  for spray booth exhausts, and process
modifications (using more water-based processes and less solvent-based ones).
2.     Process Liquid and Solid Wastes

Pieces of leather (containing  10 to 50% moisture) in various stages of processing,  and
wastewater treatment sludges constitute the bulk of the process solid waste from tanneries.
In order to produce the quality products required by leather consuming industries, tanneries
trim off inferior portions of hides at many  steps  in processing. Smaller pieces of leather
wastes are produced  in shaving and buffing operations. Approximately 35% of all tannery
solid waste is trimmings and shavings of various types.
                                        5-4

-------
          Exhibit 2:  Emissions of Toxic Air Pollutants From a Typical Tannery
Emission Point
Solvent Receiving
Mixing Vault
Supply Drum
Spray Chamber
Dryer
Receiving Recycled Solvents
Cleaning Operation
Waste Solvent Storage
Pollutants
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylol
Methyl Ethyl Ketone
Methyl Ethyl Ketone
Diacetone Alcohol
Glycol Ether EB
Glycol Ether PMA
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylol
Diacetone Alcohol
Glycol Ether EB
Glycol Ether PMA
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylol
Acetone
Methyl Ethyl Ketone
Toluene
Emission Rate
kg/hr
22.58
1.67
10.04
1.17
0.52
0.52
1.89
11.85
7.6
75.72
59.05
95.78
3338
1.89
11.85
7.6
75.72
59.05
95.78
33.38
0.61
0.98
0.61
Less than 1 kg/hr of each pollutant
Less than 1 kg/hr of each pollutant
Control Methods
Incineration
Process Modification
(e.g., water-based process
instead of solvent-based
process)
Another source of tannery wastes is the finishing department. Finishes are sprayed or rolled
onto leather and the  residue is considered to be a solid waste since it  is land disposed.
Finish residues are usually slurries containing 10 to 50% solids.  Waste finishes account for
about 2% of tannery solid waste.

Wastewater treatment is the single  largest source of process solid waste.   Almost all
tanneries screen their wastewater. Direct dischargers and some discharging wastewater into
municipal sewers have some form of primary or secondary treatment (only direct dischargers
use secondary  treatment).  The screenings and sludges from these operations contain lime,
chromium compounds, pieces of leather, hair, and other protein-like substances which are
land disposed.  Wastewater screenings and sludge account for about 60% of tannery solid
waste.
                                        5-5

-------
Floor sweepings are the final source of process solid waste. These include twine used to tie
bundles of hides, salt used to preserve the hides prior to handling, and general plant debris.
Approximately 3% of tannery solid waste is floor sweepings.

Wastewater pretreatment is accomplished through sludge dewatering.  Sludge dewatering
is performed using gravity (sequential settling) or mechanical means.  Three  mechanical
methods of sludge dewatering are used by tanneries - vacuum filters, centrifuges, and filter
presses.  All three are effective; however, there seems to be a preference for filter presses
due to the slightly drier (40% solids) filter cake produced.

See Exhibit 3  for solid wastes, their amounts, and methods of disposal.

                 Exhibit 3: Hazardous Wastes From a typical Tannery
Waste Source
Chrome trimmings &
Shavings
Chrome fleshings
Unfinished chrome
leather trim
Buffing dust
Finishing residues
Finished leather trim
Sewer screenings
Wastewater treatment
residues (sludges)
Pollutant
Cr+3
Cr*3
Cr+3
Cu
Pb
Zn
Cr+3
Cu
Pb
Zn
Cr+3
Cu
Pb
Zn
Cr+3
Pb
Cr+3
Pb
Zn
Cr+3
Cu
Pb
Zn
Concentration Range*
(wet weight in mg/kg)
2,200 - 21,000
4,000
4,600 - 37,000
2.3-468
2.5 - 476
9.1 - 156
19 - 22,000
29 - 1,900
2-924
160
0.45 - 12,000
0.35 - 208
2.5 - 69,200
14-876
1,600 - 41,000
100 - 3,300
0.27 - 14,000
2- 110
35- 128
0.33 - 19,400
0.12 - 8,400
0.75 - 240
1.2 - 147
Disposal Method
Landfill
Dewater sludge; all
waste disposed in
certified hazardous
waste disposal facility
Landfill with leachate
collection
1 Range not shown when only one sample was analyzed for the constituent
                                         5-6

-------
D.    REFERENCES

All information on air emissions for this report was taken from Assessment of Information
Available Through State & Local Air Pollution Control Agencies to Support NESHAP
Development presented by Vi'GYAN Inc. to the U.S. EPA on February 26, 1993.

All other information for this report was taken from Assessment of Industrial Hazardous
Waste Practices in Leather Tanning and Finishing Industry presented by SCS Engineers to
the U.S. EPA in November 1976.
                                     5-7

-------
THIS PAGE LEFT BLANK
         5-8

-------
6

-------
                              CEMENT INDUSTRIES
A.     PROCESS DESCRIPTION

Cement industries typically produce portland cement, although they also produce masonry
cement (which is also manufactured at portland cement plants). Portland cement is a fine,
typically gray powder  comprised  of dicalcium silicate, tricalcium silicate, tricalcium
aluminate, and tetracalcium aluminoferrite, with the addition of forms of calcium sulfate.
Different types of portland cements are created based on the use and chemical and physical
properties  desired. Portland cement types I - V are the most common. Portland cement
plants can  operate continuously for long time periods (i.e. > 6 months) with minimal shut
down time  for maintenance.  The air pollution problems related to the production, handling,
and transportation of portland cement are caused by the very fine particles in the product.

Exhibit 1 illustrates the stages of cement production at a portland cement plant:

       1.     Procurement of raw materials
       2.     Raw Milling - preparation of raw materials for the pyroprocessing system
       3.     Pyroprocessing - pyroprocessing raw materials to form portland cement clinker
       4.     Cooling of portland cement clinker
       5.     Storage of portland cement clinker
       6.     Finish Milling
       7.     Packing and loading

1.     Raw Material Acquisition

Most of the raw materials used are extracted from the earth through mining and quarrying
and can be divided into the following groups: lime (calcareous), silica (siliceous), alumina
(argillaceous), and iron (ferriferous). Since a form of calcium carbonate, usually limestone,
is the predominant raw material, most plants are situated near a limestone quarry or receive
this material  from a source via inexpensive transportation.  The plant must minimize the
transportation cost since  one third of the limestone 'is converted to C02 during the
pyroprocessing and is subsequently lost.   Quarry operations consist of drilling,  blasting,
excavating, handling, loading, hauling, crushing, screening, stockpiling, and storing.

2.     Raw Milling

Raw milling  involves  mixing the extracted raw materials to obtain the correct chemical
configuration, and grinding them to achieve the proper particle-size to ensure optimal fuel
efficiency in the cement kiln and strength in the final concrete product. Three types of
processes may be used:  the dry process, the wet process, or the semidry process.  If the dry
process is used,  the  raw materials  are dried using impact dryers,  drum dryers, paddle-
equipped rapid dryers, air separators, or autogenous mills, before grinding, or in the grinding
process itself.  In the wet process, water is added during grinding. In the semidry process
the materials are formed into pellets with the addition of water in a pelletizing device.
                                        6-1

-------
                                                     EXHIBIT 1:
                 Basic Flow Diagram of  the Portland Cement Manufacturing Process (Part 1)
    iQUARRIED RAM
    i  MATERIALS
   RAW
MATERIALS
 STORAGE
NJ
      PURCHASED
         RAW
      MATERIALS
RAW MATERIAL
 PROPORTION
                                                  DRY  PROCESS
A


k
A
1
1
GRINDING
MILL


                                                                                                      DUST
                                                                                                    COLLECTOR
   AIR
SEPARATOR
                                                                                                        Go to Part 2
                                                                                                        on next page
                                                    WET PROCESS
                                           GRINDING
                                             MILL
                                                                                                        Go to Part 2
                                                                                                        on next page
                                                                                            Particulate Emissions

-------
                                       EXHIBIT 1:

  Basic Flow Diagram of -the Portland Cement Manufacturing  Process  (Part  2)
DRY RAW MEAL
BLENDING AND
  STORAGE
                            DUST
                         COLLECTOR
   SLURRY
BLENDING AND
  STORAGE
  DUST
COLLECTOR
                                            KILN
                                                                                           Go to Part 3
                                                                                           on next page
                                                       Particulate  Emissions
                                                       Nitrogen, Carbon Dioxide,  Water, Oxygen,
                                                        Nitrogen Oxides, Sulfur Oxides,  Carbon Monoxide,
                                                        and Hydrocarbons

-------
                                 EXHIBIT 1:
Basic Flow Diagram of the  Portland Cement Manufacturing Process (Part 3)
      GYPSUM
4 A
i i
i i
CEMENT
STORAGE
fc
w
SHIPMENT
                                                                   Particulate Emissions

-------
3.     Pyroprocessing

In pyroprocessing, the raw mix is heated to produce portland cement clinkers. Clinkers are
hard, gray, spherical nodules with diameters ranging from 0.32 - 5.0 cm (1/8 - 2") created
from the chemical reactions between the raw materials. The pyroprocessing system involves
three steps: drying  or preheating,  calcining (a heating process in which calcium oxide is
formed), and burning (sintering).  The pyroprocessing takes place  in  the burning/kiln
department.  The raw mix is supplied to the system as a slurry (wet process),  a powder (dry
process), or as moist pellets (semidry process).  All systems use a rotary kiln and contain the
burning stage and all or part of the calcining stage. For  the wet and dry processes, all
pyroprocessing operations  take place in the rotary kiln, while drying and preheating and
some of the calcination are performed outside the  kiln on moving grates supplied with hot
kiln gases.

4.     Clinker Cooling

The clinker cooling operation recovers up to 30%  of kiln system heat, preserves the ideal
product qualities, and enables the cooled clinker to  be maneuvered by conveyors. The most
common types of clinker coolers are reciprocating grate, planetary, and rotary. Air sent
through  the  clinker to cool  it is  directed to the  rotary  kiln where it nourishes  fuel
combustion.  The fairly coarse dust collected from clinker coolers is comprised of cement
minerals and is restored to the operation.  Based on the  cooling efficiency and desired
cooled temperature, the  amount of air used in this  cooling process is approximately 1-2
kg/kg  of clinker.   The amount of gas to  be cleaned following the cooling process  is
decreased when a portion of the gas is used for other processes such as coal drying.

5.     Clinker Storage

Although clinker storage capacity is based on the state of the market, a plant can normally
store 5 - 25% of its  annual clinker production capacity. Equipment such  as conveyors and
bucket elevators is used to transfer the clinkers from coolers to storage  areas and  to the
finish mill. Gravity drops and transfer points typically are vented to dust collectors.

6.     Finish Milling

During the final stage of portland cement production known as finish milling, the clinker is
ground with other materials (which impart special  characteristics to the finished product)
into a fine powder.  Up to 5% gypsum  and/or natural anhydrite  is added to regulate the
setting time of the cement.  Other chemicals, such as those which regulate flowability or air
entrainment, may also be added.  Many plants use a roll crusher to achieve a preliminary
size reduction of the clinker and gypsum.  These materials are then sent through ball or
tube mills (rotating,  horizontal steel cylinders containing steel alloy balls) which perform the
remaining grinding.  The grinding process occurs in a closed system with an air separator
that divides the cement particles according to size.  Material that has not been completely
ground is sent through the  system again.
                                        6-5

-------
7.    Packing and Loading

Once the production of portland cement is complete, the finished product is transferred
using bucket elevators and conveyors to large, storage silos in the shipping  department.
Most of the portland cement is transported in bulk by railway, truck, or barge, or in 43 kg
(94 pound) multiwalled paper bags. Bags are used primarily to package masonry cement.
Once the cement leaves the plant,  distribution terminals are  sometimes  used as an
intermediary holding location prior to customer distribution. The same types of conveyor
systems used at the plant are used to load cement at distribution terminals.

B.    SOURCES OF POLLUTION

Although portland cement plants generate the same final product using similar processes,
plant layouts vary  according to fuels  and  raw  materials used,  location,  climate, site
topography, and the manufacturer of the equipment.  The flow diagram in Exhibit 1 depicts
the manufacturing  process  at a portland cement  plant and  indicates  emission points
throughout the'process.

C.    POLLUTANTS AND THEIR CONTROL

This section briefly discusses the nature of the pollutants generated from, and controls used
at, several sources in the cement manufacturing process.  Air pollutants  are typically  of
greater concern than solid or liquid wastes.

1.    Air Pollutants

Air pollutants generated during the cement  manufacturing process consist  primarily  of
particulates from the raw and finished materials, and fuel combustion by-products. Exhibit
2 indicates sources of air pollution, and differentiates between particulates and other air
pollutants.

Controlling paniculate emissions from sources other  than the kiln usually entails capturing
the dust using a hood or other partial enclosure and transporting it through a series of ducts
to the collectors.  The type of dust collector used is based on factors such  as particle size,
dust loading, flow rate, moisture content, and gas temperature.  The best disposal method
for collected dust is to send it through the kiln  creating the clinker. However, if the alkali
content of the raw materials is too high, the dust must be discarded, or must be pretreated
before introduction into the kiln. The highest allowable alkali content is 0.6 percent (as
sodium oxide). Exhibit 3 summarizes the general applicability of a number of collection
systems for use by the cement industry.

Additional air pollutants emitted include such  materials as sulfur oxides and nitrogen oxides
generated from the kiln and drying processes. Sulfur dioxide is  generated from the sulfur
compounds in the ores and the combusted fuel and varies in amount produced from plant to
plant.  The efficiency of paniculate control devices is inconclusive as the  result of variables
such as feed sulfur content, temperature, moisture, and feed chemical composition, in addition
to alkali and sulfur content of the raw materials and fuel. The combustion of fuel in rotary

                                         6-6

-------
           Exhibit 2: Air Pollution and Control at Cement Production Facilities
Emission Point
Quarries
Raw Mill
Systems
Kiln System
Clinker Coolers
Finish Mill
Systems
Finish Mill
Systems
For use with
High-
Efficiency
Separators
Packing and
Loading
Departments
Pollutants
Particulates
Particulates
Particulates
Particulates
Particulates
Particulates
Particulates
Particulates
Emission Rate
(gr/acf1)
5-40
5-20
4-18
5-10
5-20
.5-100
150-300
5-40
Control Device
Fabric Filter:
• Pulse Jet
• Reverse Air /Shaker
Fabric Filter:
• Pulse Jet
• Reverse Air/Shaker
• Cartridge
Dust Collectors:
• Reverse Air
• Precipitator
Fabric Filters:
• Pulsed Plenum/Pulse Jet
• Reverse Air
• Precipitator
Fabric Filter:
• Reverse Air/Shaker
Fabric Filters:
• Pulse Jet
• Pulsed Plenum
Fabric Filters:
• Pulse Jet
• Pulsed Plenum
Fabric Filters:
• Pulse Jet
• Reverse/Air Shaker
• Cartridge
Percent
Efficiency
299.6
299.6
299.5
299.6
299.6
299.6
299.9
299.6
1  gr/acf = grains/actual cubic foot
                                          6-7

-------
Exhibit 3: Applicability of Emission Control Methods
Operation
Primary
grinding
Air
separators
Mills
Storage
silos
Feeders
and belt
conveyors
Packing and
loading
Coal
dryer
Kiln
gases
Clinker
cooler
Mechanical
Collector
Unsatisfactory
efficiency
Not
applicable
Not
applicable
Not
applicable
Not
applicable
Not
applicable
Preliminary
cleaning only
Preliminary
cleaning only
Preliminary
cleaning only
Wet
Scrubber
Not
applicable
Not
applicable
Not
applicable
Not
applicable
Not
applicable
Not
applicable
Practicable
Impractical
Not
applicable
Fabric
Collector
Successful
Successful
Successful
Successful
Successful
Successful
Successful
12 x 30 Glass
Successful
Successful
Electrostatic
Not
applicable
A few
installations
A few
installations
Not
applicable
Not
applicable
Not
applicable
Not
common
Successful
Not
common
Gravel Bed
Filter
None in use
Questionable
application
Questionable
application
Impractical
Impractical
Impractical
Practicable
Practicable
Successful
                       6-8

-------
cement kilns generates nitrogen oxides from the nitrogen in the fuel and incoming combustion
air. The amount emitted depends on several factors including fuel type, nitrogen content, and
combustion temperature.  Both sulfur dioxide and some of the nitrogen oxide react with the
alkaline cement and are removed from  the gas stream.

a.     Raw Material Acquisition

During raw  material acquisition the primary air pollutant emitted  is paniculate matter.
Paniculate matter is also emitted from the handling, loading, unloading, and transport of raw
materials purchased from another source, such as coal. In certain areas exhaust from portable
equipment may also be a consideration.

The following methods are used to  control paniculate emissions generated from the
quarry and handling of purchased raw materials:

•      fabric filters (pulse-jet or reverse-air/shaker)    •     equipment enclosures
•      water sprays (with and without surfactants)     •     enclosures
•      silos (with and without exhaust venting to       •     wind screens
        fabric filters)                                •     foams
•      mechanical collectors                          •     bins
•      chemical dust suppressants                    •     paving
•      material storage buildings

Dust that is collected by these means is restored to the process.  For quarry operations, newer
plants typically use the pulse-jet fabric  filters while older plants  employ the reverse-air or
shaker-type fabric filters.

b.     Raw Milling

Fugitive dust is emitted from raw material feeders, stackers, blenders, reclaimers, conveyor belt
transfer points, and bucket elevators used for transferring materials to the  mill department
from storage. Particulate emissions from  the dry raw mills and subsequent equipment occur
during temporary failure or from improperly designed or maintained seals.
The following devices are used to collect  particulate matter in the raw mill and raw mix storage
areas:

       •      mechanical cyclones (usually used in series with another control)
       •      fabric filters (pulse jet or reverse air/shaker)
       •      electrostatic precipitators (rarely used)

Newer plants typically use the pulse-jet fabric filters while older plants employ the reverse-air
or shaker type fabric filters.
                                          6-9

-------
c.     Pyroprocessing

The main pyroprocessing system emissions are nitrogen, carbon dioxide, water, oxygen, nitrogen
oxides, sulfur oxides, carbon monoxide, and hydrocarbons.  Cement kiln dust (CKD) is also
produced.

The cement kiln itself has been designated as best available control technology (BACT) for
the control of SO2. The highly alkaline conditions of the kiln system enable it to capture up
to 95% of the possible SO2 emissions.  However, if sulfide sulfur (pyrites) is present in the kiln
feed, this absorption rate can decline to as low as 50%.  Therefore, sulfur emissions can be
decreased through careful selection of raw materials.

No device to control cement kiln NOX emissions has been developed, but there are several
prospects:

       •      stable kiln operation (reduces long term NOX emissions);
       •      burner configurations for the rotary kiln (efficiency varies);
       •      staged combustion for precalciner kilns;
       •      recirculation of the flue gas  (oxygen deficient air in the rotary kiln); and
       •      alternative/low-nitrogen fuels.

Cement kiln dust (CKD) is  the powder retrieved from the exiting gases and is either all or
partly returned to the operation or removed entirely. The type of system, the chemical makeup
of the raw materials and fuel, and the condition of the system operations all affect the chemical
configuration of the CKD. Portland cement specifications usually limit the amounts of sodium
and potassium.  Because bypass CKD contains a large quantity of these minerals, CKD is
usually removed from the process. The CKD from a preheater tower is composed of the same
general elements as the kiln feed  and therefore is returned to the process.  The  handling,
storage, and deposition of CKD can generate fugitive dust emissions.

The following methods are used to  control paniculate emissions from the kiln system:

       •      reverse-air fabric filters
       •      electrostatic precipitators (ESPs)
       •      acoustic horns (sometimes used in conjunction with the two devices above)

d.     Clinker Cooling

Reciprocating grate clinker coolers most often employ fabric filters, but ESPs and gravel bed
filters are also used with a mechanical cyclone or multiclone dust collector sometimes placed
in front.  Newer plants typically use pulse-jet or pulsed-plenum fabric filters and older plants
use reverse-air type fabric filters which may simply be a smaller form of a kiln fabric filter.
Gravel bed  filters, which are also used by the cement industry,  contain quartz  granules;
contaminated gas passes through this filter and the dust settles to the bottom of the bed.
                                         6-10

-------
&     Clinker Storage

The devices used to control dust emissions from clinker storage areas are similar to those used
in the raw milling process.  The paniculate emissions generated by dropping clinkers onto
storage piles can be reduced by using a rock ladder or variable-height, automatic, stacker belt
conveyor systems.  Fugitive dust generated from open storage piles is tempered by rain and
snow, wind breaks, and pile  covers. Clinker in open piles is moved using front-end loaders;
in storage halls overhead bucket cranes are used.  Fugitive clinker dust emitted from open
storage piles is common and very difficult  to control.

/      Finish Milling

Particulate matter is emitted from mill vents, air separator vents, and material-handling system
vents.  Newer plants usually use pulse-jet or pulsed-plenum fabric filters with high-efficiency
separators, while older plants use reverse-air/shaker fabric filters.  The cement dust collected
by the fabric filter is restored  to the system.  In cold weather, a plume may develop  at the
baghouse vent; this may be mistaken for paniculate matter, but actually is condensed water
vapor from the cooling system.

g.     Packing and Loading

In the shipping department particulate matter is emitted from the silos and the handling and
loading operations.  Active and passive fabric filters are used to collect this dust.  During
loading of the product, particulate emissions are controlled by a fabric filter connected to the
transport vessel; collected dust is restored to the shipment. To ensure dust-free  loading onto
the transport vessel, a flexible loading spout consisting of concentric tubes is used. The  outer-
most tube seals the delivery spout to the  transport vehicle.  The product is then delivered
through the inner tube and displaced air drawn up the outer tube to a filter.   At distribution
terminals, fabric filters are again used and the collected dust is returned to the product. New
plants typically use pulse-jet fabric filters  while  older plants use reverse-air or shaker-type
fabric filters.

2.     Liquid and Solid Wastes

The overflow from slurry concentrating equipment (i.e. thickeners) constitutes the main water
pollution problem. For new  plants that process slurry, closed-cycle water systems are used to
return the overflow water to the process. Another source of waste is the stripped overburden,
which is used as a raw material or disposed of in a local landfill.  An estimate of overburden
deposited in a landfill varies from 0 - 3 metric tons per metric ton of cement produced.

The combustion  processes of cement kilns and  rotary kilns have been used to dispose of
hazardous waste material.  For the  cement kiln, waste material is burned with a primary fuel.
For a wet process kiln, the raw materials are introduced  into the top of the kiln and exit at the
bottom as cement clinker.  The burner is located at the lower end of the kiln where the fuel
and waste are ignited. The hot gases move up the kiln and heat the raw materials, exit the
kiln, and are then cleaned in a baghouse prior to exiting through a stack. When waste is fired,
any ash generated becomes a part of the cement product.

                                         6-11

-------
D.    REFERENCES

1.     Air and Waste Management Association.  Air Pollution Engineering Manual.  New
      York: Van Nostrand Reinhold, 1992.

2.     Hall, F.D.  Evaluation of the Feasibility of Incinerating Hazardous Waste in High-
      Temperature Industrial Process. 1984.

3.     Reding, J. T., P.E. Muehlberg, and B.P. Shepherd (Dow Chemical). Industrial Process
      Profiles for Environmental Use: Chapter 21.  The Cement Industry, February 1977.
                                       6-12

-------

-------
                  PRINTED CIRCUIT BOARD MANUFACTURING
A.     PROCESS DESCRIPTION

Printed circuit boards are electronic circuits created by mounting electronic components on
a non-conductive board, and creating conductive connections between them. The creation
of circuit patterns is accomplished  using both  additive  and subtractive methods.  The
conductive circuit is generally copper, although aluminum, nickel, chrome, and other metals
are sometimes used. There are three basic varieties of printed circuit boards: single-sided,
double-sided, and multi-layered.  The  spatial and density requirement, and the circuitry
complexity determine the type of board produced.  Printed circuit boards are employed in
the manufacturing of business machines and computers, as well as communication, control,
and home entertainment equipment.

Production of printed circuit boards involves the plating and selective etching of flat circuits
of copper supported on a nonconductive sheet of plastic.  Production begins with a sheet of
plastic laminated with a thin layer of copper foil.  Holes are drilled through the board using
an automated drilling machine. The holes are used to mount electronic components on the
board and to provide a conductive circuit from one  layer of the board to another.

Following drilling, the board is scrubbed  to remove fine copper particles left by the  drill.
The rinsewater from a scrubber unit can be a significant source of copper waste.  In the
scrubber, the copper is in a paniculate form and can be removed by filtration or centrifuge.
Equipment is available to remove this copper paniculate, allowing recycle of the rinsewater
to the scrubber. However, once mixed with other waste streams, the copper can dissolve
and contribute to the dissolved copper  load on the treatment plant.

After being scrubbed, the board is cleaned and etched to promote good adhesion and then
is plated with an additional layer of copper. Since the holes are not  conductive, electroless
copper plating is employed to provide a thin continuous conductive layer over the surface
of the board and through the holes.  Electroless copper plating involves using  chelating
agents to keep the copper in solution at  an alkaline pH. Plating depletes the metal and
alkalinity of the electroless  bath.    Copper sulfate and  caustic  are  added  (usually
automatically) as solutions, resulting in a  "growth" in volume  of the  plating solution.  This
growth is a significant source of copper-bearing wastewater in the circuit board industry.

Treatment of this stream (and the rinsewater from electroless plating) is complicated by the
presence of chelating agents, making simple hydroxide precipitation ineffective.  Iron salts
can be added to break the chelate, but only at the cost of producing a significant volume
of sludge.  Ion exchange is used to strip the copper from the chelating agent, typically by
using  a chelating ion exchange resin. Regeneration of the ion exchange resin with sulfuric
acid produces a concentrated copper sulfate solution without the chelate. This regenerant
can then be either treated by hydroxide precipitation, producing a hazardous waste sludge,
or else concentrated to produce a useful product.
                                        7-1

-------
Growth from electroless copper plating is typically too concentrated in copper to treat
directly by ion  exchange.   Different methods have  been  employed to reduce  the
concentration of copper sufficiently either to discharge the effluent directly to the sewer or
to treat it with ion exchange.  One method, reported by Hewlett-Packard, replenishes growth
with formaldehyde and caustic soda to enhance its autocatalytic plating tendency, and then
mixes  it with carbon granules on which  the  copper plates out  in  a  form suitable for
reclaiming.

Following electroless plating, copper is electroplated on the board to its final thickness, and
a layer of tin-lead solder is plated over the copper.  A photoresist material is then applied
to the board and exposed by photoimaging a circuit design.   Following developing and
stripping a selected portion  of the photoresist, that portion of the  tin-lead plate is etched
to reveal the copper in areas other than the final desired circuit pattern.

The exposed copper is then removed by etching to reveal the circuit pattern is the remaining
copper.  Ammonia-based etching solutions are most widely used.   Use of ammonia
complicates waste treatment and makes recovery of copper difficult.  An alternative to
ammonia etching is sulfuric  acid/hydrogen peroxide etching solutions. This  latter etchant
is  continuously replenished by adding concentrated peroxide and  acid as the copper
concentration increases to about 80 g/L At this concentration, the solution is cooled to
precipitate out copper sulfate.  After replenishing with peroxide and acid, the etchant is
reused. Disadvantages of the sulfuric acid-peroxide etching solution are  that it is relatively
slow when compared with ammonia, and controlling temperature can be difficult.

Exhibit 1 shows the general  processes in printed circuit board manufacturing.

B.     SOURCES OF POLLUTION

Wastes are generated from the following five processes that are common to the manufacture
of all types of circuit boards:

       •      cleaning and surface preparation
       •      catalyst application and electroless copper plating
       •      pattern printing and masking
       •      electroplating
       •      etching

The wastes generated  include  airborne  particulates, spent  plating  baths,  and waste
rinsewater among others.  Exhibit 1 indicates the sources of pollution.

C.     POLLUTANTS AND  THEIR CONTROL

Emissions of air pollutants from the manufacture of printed circuit boards stem primarily
from the board cleaning and preparation process; other emissions are generally of much less
significance.  The majority of the emissions are acid fumes and organic  vapors from the
                                        7-2

-------
EXHIBIT 1: Process Flow Diagram of a Typical Printed Circuit Board
                       Manufacturing Plant
                                 A
Imagine

I.IS

>..
*

Copper
electroplating
ily

>fc

Solder
electroplating


>fc

Stripping &
etching
os

>fc
*

Final
processes

                                 Y
                                                            Air emissions
                                                            Solid/liquid waste

-------
cleaning processes.  Some participates are also emitted in the drilling and finishing of the
boards.  Proper ventilation and  exhaust of all  process  baths,  rinse  operations, and
mechanical operations is essential to managing the air emissions of a printed circuit board
manufacturing operation and can also contribute to reduction in liquid and metal waste
generation.  Exhibit 2 lists air pollutants and methods of control.

Each manufacturing process may generate multiple waste streams.  Rinse water and other
rinse solutions are usually  the largest  streams  by volume, but are generally lower in
concentration of hazardous  chemicals than spent process baths.   Contamination of rinse
streams can be minimized by strategies that reduce drag-out of process solutions.  Treatment
and reuse of rinse streams is also effective in reducing overall waste generation.

Airborne particulates emitted from cutting, sanding, routing, drilling, beveling, and slotting
operations during board preparations  are usually  controlled  by baghouse and  cyclone
separators. The collected pollutants are then disposed of, along with other solid wastes at
landfills.

Acid fumes from acid cleaning and organic vapors from vapor degreasing are usually not
contaminated with other materials, and  therefore are often kept separate for subsequent
treatment.  The acid fume air stream is collected via chemical fume hoods and sent to a
scrubber where the acid is removed with water.  The scrubbed air  then passes on to the
atmosphere, and the absorbing solution is neutralized along with other acidic waste streams.
Similarly, organic fumes are  often collected and passed through a bed of activated carbon.
The  carbon bed is then  regenerated with steam.  In many cases, the regenerative vapor is
cooled and the condensate containing water and solvent drummed and set aside for off-site
treatment.  In  a few cases, the regenerative vapor is combusted in a closed fumes burner.

The  spent acid and alkaline solutions from the cleaning steps  are either sent off site for
disposal or neutralized and discharged to the sewer.  Spent chlorinated organic solvents are
often gravity separated and recovered in-house, or hauled away for reclaiming.

Most of the remaining wastes are liquid waste streams containing suspended solids, metals,
fluoride, phosphorus, cyanide, and chelating agents.  Low pH values often characterize the
wastes due to acid cleaning operations.  Liquid wastes may be controlled using end-of-pipe
treatment systems,  or a combination  of in-line treatment and separate  treatment  of
segregated waste streams.  A traditional treatment system for the wastes generated is often
based on pH adjustment and the  addition of chemicals that will  react with the soluble
pollutants to precipitate out  the dissolved contaminants in a form such as metal hydroxide
or sulfate. The solid particles are removed as a wet sludge by filtration or flotation, and the
water is discharged to the sewer.  The diluted sludge is usually thickened before disposal in
landfills. Recent improvements in in-line treatment technologies, such as reverse osmosis,
ion exchange, membrane filtration, and advanced rinsing techniques, increase the possibility
for the recovery and reuse of water and  metallic  resources.

Exhibit 3 delineates the waste streams from printed circuit board manufacturing.
                                        7-4

-------
         Exhibit 2:  Air Emissions from Printed Circuit Board Manufacturing
Emission Point
Surface Preparation
Surface Cleaning
Pollutants
Particulates
VOC
Acid fumes
VOC
Control Device
Baghouses/Cyclone separators
Carbon adsorber
Wet scrubbers
Carbon adsorber
     Exhibit 3:  Waste Streams From the Manufacture of Printed Circuit Boards
   WASTE SOURCE
   WASTE STREAM
     DESCRIPTION
      WASTE STREAM
        COMPOSITION
Cleaning/Surface Preparation
Spent acid/alkaline solution
                            Spent halogenated solvents
metals, fluoride, acids, halogenated
solvents, alkali, board materials,
sanding materials
                            Waste rinse water
Electroless Plating
Spent electroless copper bath
                            Spent catalyst solution
acids, stannic oxide, palladium,
complexed metals, chelating agents,
copper
                            Spent acid solution
                            Waste rinse water
Pattern Printing and Masking
Spent developing solution
                            Spent resist removal solution
vinyl polymers, chlorinated
hydrocarbons, organic solvents, alkali
                            Spent acid solution
                            Waste rinse water
Electroplating
Spent plating bath
                            Waste rinse water
copper, nickel, tin, tin/lead, gold,
fluoride, cyanide, sulfate
Etching
Spent etchant
                            Waste rinse water
ammonia, chromium, copper, iron,
acids
                                           7-5

-------
D.    REFERENCES

This report contains excerpts of information taken directly from the following sources:

1.    Higgins, Thomas. Hazardous Waste Minimization Handbook. Chelsea, Michigan:
      Lewis Publishers, Inc., 1991.

2.    Jacobs Engineering Group, Guides to Pollution Prevention: The Printed Circuit
      Board Manufacturing Industry. Pasadena, California, June 1990.

3.    Kirsch, F. W., and Looby, G. P. Waste Minimization Assessment for a Manufacturer
      of Printed Circuit Boards. July 1991.  EPA/600/M-91/022
                                      7-6

-------
8

-------
                                ELECTROPLATING

Electroplating is the process of depositing a coating having desirable characteristics by
means of electrolysis. The purpose of electroplating is to alter the characteristics of a base
metal's or  other material's surface  to provide improved appearance, ability to withstand
corrosive agents, resistance to abrasion, or other desired properties, or a combination of
them.  The electroplating industry utilizes chemical and electrochemical operations to effect
these improvements. Because metal electroplating is the most prevalent type, it will be used
for process descriptions and pollutant identification.

A.     PROCESS DESCRIPTION

1.     Material Preparation

Base  materials  are  generally  prepared for  plating  by  mechanical,  chemical, or
electrochemical means. Metal imperfections, scales, oils, and grease must be removed from
the surface if  electroplating is  to  be successful.  Mechanical operations performed in
electroplating facilities include abrasive blast cleaning, barrel finishing, grinding, polishing,
and buffing.  Chemical operations include degreasing, alkaline cleaning, acid treatments,
chromating, phosphating, passivating, bright dipping, chemical polishing,  and electroless
nickel  plating.

2.     Plating

Electroplating operations include nickel, chromium, cadmium, zinc, copper, tin, iron, gold,
and silver plating as the most important processes. Alloys may be deposited from solutions
with compatible anions.  Anodizing is used most often for aluminum  plating.  Each
electroplating metal is chosen for its particular characteristics.  Some common electroplating
metals and their specific characteristics are:

       • nickel:     corrosion and wear resistance, and to rebuild worn parts.
       • chrome:   corrosion resistance,  bright metallic appearance, impart improved
                    mechanical properties (hardness, lubricity) to base.
       • cadmium:  corrosion protection
       • zinc:       corrosion protection
       • copper:    electrical conductivity properties
       • gold:       high conductivity, inertness, aesthetic appeal.
       • silver:     high conductivity, inertness, aesthetic appeal.

The plating cycle following the pretreatment steps can be very simple, such as a sequence
of cleaning-rinsing-plating-rinsing-drying, or very complex, requiring a number of cleaning
steps with  additional steps  of  acid  dipping, striking, activation, multiple rinses  and the
deposition of more than one metal.  All  processing steps within a given cycle must be
arranged so that the solutions will not be contaminated.  Cleaners, acid dips and strikes vary
in  composition and  concentration  and are formulated  for  a  particular base material.
Cleaners are generally alkaline and are used to remove the last traces of oil and grease.


                                         8-1

-------
Acid dips are not intended to remove scales or oxides but are used to neutralize traces of
alkaline cleaners left on the base material after rinsing and to activate the surface to receive
the electrodeposit.  Some materials require more intense activation steps than others. Each
base material must  be treated differently and each metal deposited requires a specific cycle.

Thus, each electroplating operation is comprised of a number of steps of different duration,
where the products are moved in a sequence from one chemical solution to another.  Two
operations used most frequently are barrel operations and rack plating.

       •     In barrel operations small parts are electroplated while tumbling freely in
             rotating barrels.

       •     In rack plating, components held in a rack are dipped into an electroplating
             solution.   Rack plating is  required for  a large percentage of materials
             electroplated. Racks are used for reasons including maintenance of shape or
             surface conditions, achievement of the desired distribution of coating, or size
             or shape of workpiece.

3.     Alternative processes

Recent developments such as new regulations on the discharge of toxic materials, the small
number of certified landfill sites, and the rising costs of plating metals and chemicals have
given rise to alternative electroplating methods.  Some of  the more prevalent methods
include aluminum electroplating and ion vapor depositing.

a.    Aluminum electroplating

Aluminum electroplating imparts corrosion resistance to the base material.  This  method
is being used as a substitute for the  costly and highly toxic cadmium electroplating.
Aluminum is less costly than cadmium, and can be used at higher temperatures.

b.    Ion vapor deposition

Old  electroplating methods applied  coating by dipping or by a metal  spray.  These are
inefficient since they do not impart a thin and uniform coating. Ion vapor deposition utilizes
a high-voltage system inside a vacuum to ionize the coating substance and impart a negative
charge to the parts. This charge causes the coating substance ions to electrodeposit in the
air. The air in the chamber is replaced by a low-pressure ionized gas. The substance's vapor
must interact with the  ionized inert gas to attract oppositely charged parts and coat them
uniformly. Ion vapor deposition is most often used when aluminum is the coating substance.

B.     SOURCES OF POLLUTION

There are several possible process paths for electroplating, each dependent on such factors
as electroplating metal type, reason(s)  for electroplating, and dip tank  chemical makeup.
The  process diagram shown in Exhibit 1 is for a general electroplating process with acid
recovery. All sources in  the electroplating process emit air pollutants, and many generate
hazardous waste. These  are indicated in the exhibit.
                                        8-2

-------
          EXHIBIT 1:    Sources of Pollution  in  the  Electroplating Process
     ""WORK
     PIECE
oo
SURFACE
CLEANING /
PREPARATION


              AIR EMISSIONS
              SOLID / LIQUID WASTE
PLATING BATH
RINSING
                                                      WASTEWATER
                                                        STORAGE
                                                        FILTERS
FINISHED
PRODUCT
                                                                         DEIONIZED WATER
                                       CARBON
                                      FILTERS
                                                                                      HCL

                                                                                      A
                                                                                             CAUSTIC
                                                                                              SODA
                             CATION / ANION
                                 BEDS

-------
c.
POLLUTANTS AND THEIR CONTROL
Exhibit 2 identifies air emissions from electroplating operations, and Exhibit 3 identifies
potentially hazardous waste generation.

Exhibit 2: Air Emissions From Different Chrome Electroplating Operations
Emission
Source
Surface Cleaning/ Preparation
• Acid/alkali cleaning
• Cold cleaners
• Vapor degreasers
Surface Modification

• Hard chromium plating
• Decorative chromium
plating
• Chromic acid anodizing
Pollutants

Cu, Ni, Zn, Pb
Fe
VOC
VOC


Cr+6


Emission
Rate

3 mg/1 each
36mg/l
190-560 kg/yr
9500 kg/yr


15-90 g/hr
4-66 g/hr
1.2-2.8 g/hr
Control
Device
Covers
Increased
freeboard
Refrigerated
chiller
Carbon adsorber

Demister
Wet scrubber
Chemical fume
suppressants
Control
Eff. (%)





87.9-99.7
95.4-99.4
99.5-99.8

Exhibit 3: Potentially Hazardous Wastes Generated From Electroplating Operations
Waste Source
Chemical operations
Electroplating
operations
Degreasing
Pollutant
Heavy metals
Heavy metals
Oil and grease
Asbestos
Cyanides
Solvent
Chlorinated & fluorinated hydrocarbons'
Amount

N/A

Disposal Method
Landfilling
Landfilling
N/A
      'Hydrocarbons  include  trichloroethylene,  perchloroethylene,  methyl   chloroform,
      trichlorotrifluoroethylene, methylene chloride.
                                        8-4

-------
Potentially hazardous wastes are found in one of three forms: (1) low-solids slurry, (2) high
solids sludge, and (3)  solid waste.   Treatment of the low-solids slurry is performed by
densification or densification and de water ing to produce a waste more easily disposed of to
the land.   Concentrated  solutions  of heavy  metals  may alternatively  be treated  by
reclamation or chemical fixation and solidification.  High-solids sludge and solid wastes are
sometimes treated  by  volume  reduction processes, such  as  incineration, to reduce the
transportation and final disposal costs.

The increasing  costs  and liability  of  hazardous  waste disposal are  leading  many
electroplating facilities to  incorporate process  modifications  to  reduce hazardous waste
generation.  Some of these modifications include:

       •      Reduction of drag-out.  Drag-out  is the liquid which clings to a part as it is
             removed  from a process bath.
       •      Modification of rinsing operations that are used to remove residual drag-out.
       •      Recovery of materials from rinsewaters.
       •      Reducing or eliminating tank dumping.
       •      Substituting less hazardous materials into  the  process (noncyanide  baths,
             vacuum disposition, ion vapor deposition).

D.    REFERENCES

1.     Assessment of Industrial Hazardous  Waste Practices:  Electroplating and  Metal
      Finishing Industries - Job Shops. EPA Hazardous Waste Management Division, 1976.

2.     Hazardous Waste Minimization Handbook. 1991, pp. 75-212.
                                        8-5

-------
THIS PAGE LEFT BLANK
        8-6

-------
9

-------
                                 LEAD SMELTING

 Lead is usually found naturally as a sulfide ore containing small amounts of copper, iron,
 zinc, and other trace elements. There are two major lead smelting processes: primary lead
 smelting and secondary lead smelting.  Primary lead smelting involves any process engaged
 in the production of lead from sulfide ore concentrates through the use of pyrometallurgical
 techniques.  Secondary lead smelting involves the reclaiming and refining of lead from
 leadbearing scrap materials in which the predominant component  is lead.

 A.     PROCESS DESCRIPTION

 1.     Primary lead smelting

 The processing of lead from sulfide ores involves three major phases -- sintering, reduction,
 and refining.

 a.     Sintering

 The sulfide ore is first reduced to sinter.  Sinter is a coherent mass  of  lead formed by
 heating, but not melting, the ore. The sinter machine is a continuous steel pallet conveyor
 belt moved by gears and sprockets, with each pallet consisting of perforated or  slotted
 grates. Fans beneath the pallets create a draft, either up or down, to create the conditions
 necessary for autogenous primary reactions.

 The updraft sinter machine design is superior to the down-draft design for many reasons.
 The sinter bed is more permeable, which permits a higher production rate.  Second, the
 small amounts of lead that form will solidify at their point of formation, instead of flowing
 down and collecting on the grates or at the bottom of the sinter charge and causing reduced
 blower capacity, as they do in a down-draft sinter machine.  Also, the  updraft design can
 produce  sinter of higher lead content. Finally, the updraft design can produce a single
 strong sulfur dioxide effluent stream by the use of weak gas recirculation. This is extremely
 helpful in air emissions control.  To maintain a desired sulfur content of 5 to 7 wt % in the
 sinter charge, limestone, silica, sinter recycle, and flue dust  are often added to the sinter
 mix.

 b.    Reduction

 After sintering, lead reduction occurs in a blast furnace. The blast furnace, which is a water-
jacketed  shaft furnace supported by a refractory base, is charged with a mixture of sinter,
 metallurgical coke, and  various recycled and cleanup materials.

 Solid products from the blast furnace generally separate into four layers:  speiss (the lightest
 material, basically arsenic and antimony),  matte (copper sulfide and other metal sulfides),
 slag (primarily silicates), and lead bullion.  The first three layers are collectively called slag,

                                         9-1

-------
and contain most of the impurities.   The  slag is  continuously collected and is either
processed at the smelter for its metal content or shipped to treatment facilities.

After the lead bullion leaves the blast furnace, it usually requires preliminary treatment, or
drossing, in kettles before undergoing refining operations. As the bullion is cooled, copper,
sulfur,  and other  metals and impurities collect on the surface as  dross.  The dross is
removed from the solution and may undergo some recovery methods.

c.     Refining

The final  smelting phase is refining, which  is done in cast iron kettles.  There are five
refining steps:

      1.     Removal of antimony, tin, and arsenic.
      2.     Removal of metals by Parke's process.
      3.     Vacuum removal of zinc.
      4.     Removal of bismuth by the Betterson process.
      5.     Removal of remaining traces of metal impurities by the addition of NaOH
             and NaNO3.

The final refined lead is then cast into pigs for shipment.

2.     Secondary lead smelting

Three types of furnaces are employed in the recovery of lead from scrap material, each with
different processes and emissions: reverberatory, blast, and pot furnaces. Each furnace type
also produces  a different lead grade:  soft, semisoft, and hard.

a.     Reverberatory Furnaces

Reverberatory furnaces are used in sweating operations.  Sweating heats  the mix charge,
melting the metal which is tapped off at intervals as semisoft lead.  This is a continuous
process, with more charge being added in such a manner as to keep a small mound of
unmelted material on top of the bath. Reverberatory furnaces are also used to reclaim lead
from oxides and drosses.

The reverberatory furnace produces semisoft lead  which usually contains trace amounts of
antimony and  copper.

b.     Blast Furnaces

Blast furnaces, or cupolas,  are similar to those used in the ferrous industry. Rerun slag,
scrap cast iron, limestone,  coke, drosses, oxides,  and  reverberatory slags form the usual
charge in a blast furnace.  Hard lead is charged into the cupola at the start of the process

                                        9-2

-------
 to provide molten metal to fill the crucible. The charges are added as the material metal
 melts down.  The limestone and iron form a flux that floats on the top of the molten lead
 and retards oxidation.

 Slag is tapped at intervals while the molten lead flows from the furnace at a more or less
 continuous rate. Approximately 70% of the molten material is tapped off as lead and the
 remaining 30% as slag.  About 5% of the slag is retained for later use.  The blast furnace
 produces hard lead, which typically contains 5-12% antimony and trace amounts of arsenic,
 tin, copper, and nickel.

 c.    Pot Furnaces

 Pot-type furnaces are used for  remelting, alloying, and  refining processes.  Remelting is
 usually done in small furnaces using alloys in ingot form as charge.  Alloying usually begins
 with a metal lower in the percentage of alloying  materials than  desired. The required
 amount is then added to the molten material. Antimony, tin, arsenic, copper, and nickel are
 the most commonly used alloying  elements.

 The refining processes most  commonly used are  those for the removal of copper and
 antimony to produce soft lead, and those for the removal of arsenic, copper, and nickel to
 produce hard lead. Aluminum  is  often added to the molten lead.  The aluminum reacts
 with copper, antimony, and nickel to form complex compounds that can be skimmed off the
 surface.  A procedure known as "dry dressing", where sawdust is introduced into the agitated
 mass of molten metal, is also used. During dry drossing, carbon, which aids in separating
 globules of lead suspended in the  dross, is formed.

 Pot furnaces generally produce soft lead, a high-purity  grade  formed after considerable
 refining has been performed.  Soft lead may be designated as corroding, chemical, acid
 copper,  or common desilverized lead.

 B.    SOURCES OF POLLUTANTS

 Exhibit 1 is a flow diagram of the primary lead smelting process. Both air emission points
 and hazardous waste generation points are identified. Exhibit 2 identifies the air emission
 points and hazardous waste generation points for the  general secondary lead smelting
 process.

 C.    POLLUTANTS AND THEIR CONTROL

 Exhibits 3 and 4 identify the  pollutants by source that  are emitted or generated by the
various smelting processes.  Exhibit 3 presents air pollutants, and identifies control devices,
 if any, for primary and secondary lead smelters.   Exhibit 4  presents hazardous waste
pollutants, and identifies the disposal methods, if any.
                                       9-3

-------
EXHIBIT 1:  Diagram of a Typical  Primary Lead  Smelting Process
A A A
' ' DROSS™" '
C ^ SINTER SINTER BULLION DROSSING BULL
CONCENTRATE fc SINTER k BLAST DROSSING
1 A w' MACHlNci A ^ rURNAUE A w' Kbl ILbio
L )\ \ *t
	 LIMESTONE 1 	 PbO
	 SILICA 1 	 COKE
	 SINTER REYCLE
FLUE DUST
COKE _.
4 i
	 AMMONIA CHLORIDE
	 SODA ASH
SLAG 	 SULFUR
. . FLUF, DUST
1 	 COKE A
' ! ^
DROSS
r
SLAG DROSS
FUMING REVERBERATORY
FURNACE FURNACE
f Zr
i
r
T— >i (NATTE AND |
'° J SPEISS
ION
^ RRFTMEBV


	 LIMESTONE
	 SILICA
SOPA ASH
	 SULFUR
	 PIG IRON
	 PbO
COKE

                                                                      REFINED LEAD
                                                                 AIR EMISSIONS

-------
                  EXHIBIT  2:   Diagram  of a Typical Secondary  Lead  Smelting Process
   PRETREATMENT
                    SMELTING
  REFINING
      PRODUCTS
DROSS AND
FINE DUST
                          i
                                                         i
                        REVERBERATORY
                           / BLAST

                     DUST
                 AGGLOMERATION
                     ZINC
                   LEACHING
                                       CASTING
                                                       REVERBERATORY _,
                                                         i
                                                  KETTLE
                                                 SOFTENING
                                                                i
      i
Ventilation System to
Emission Controls
                                Air Emissions
Effluent Stream
Solid Residues

-------
Exhibit 3:  Air Emissions From Primary and Secondary Lead Smelters
Emission
Point
Pollutants
Emission
Rate
Control Device
PRIMARY LEAD SMELTING
Ore Crushing
Sinter Machine
Blast Furnace
Dross Reverb.
Furnace
Refining
Materials
Handling
Participates
S02
Participates
SO2
POM, As, fluorides,
Sb, Pb, Hg, Se
Participates
S02
POM, As, fluorides,
Sb, Cd, Pb, Hg, Se
Participates
Participates
S02
Particulates
S02
1.0 kg/mt
No data
106.5 kg/mt
275.0 kg/mt
Trace amounts
180.5 kg/mt
22.5 kg/mt
Trace amounts
10.0 kg/mt

2.5 kg/mt
No data
Baghouse
Baghouse
ESP
Sulfuric acid plants
Baghouse


Enclosures
Water spraying
Control
Eff.(%)

95-99
95-99
95-99
>96
95-99



SECONDARY LEAD SMELTING
Reverb. Furnace
Lead Blast
-•Furnace
Pot-type
Furnace
Particulates
SO2; SO3; oxides,
sulfides/sulfates of
Pb, Sn, As, Cu,
Particulates
CO
Lead oxide
Particulates
1.4-4.5 gr/ft3
Up to 4 gr/ft3

Baghouse with gas-cooling
devices & settling chambers
Hoods; Baghouse;
Afterburner
Baghouse



                                     9-6

-------
Exhibit 4:  Sources of Hazardous Waste in Lead Smelting Operations
Waste Source
Primary
Secondary
Blast furnace
slag





Scrubber slag




Cupola furnace
slag & matte




Reverb, furnace
slag




Pollutant
Heavy metals
(As, Cd, Cr, Cu, Hg,
Pb, Sb, Zn)
Heavy metals
(Cu, Cr, Pb, Sb, Sn,
Zn)
Cr
Cu
Mn
Ni
Pb
Sb
Sn
Zn
Cd
Cr
Cu
Mn
Pb
Sb
Zn
Cu
Mn
Ni
Pb
Sb
Sn
Zn
Cr
Cu
Mn
Pb
Sb
Sn
Zn
Amount (mt/y)1
4400
160
2
18
2
2
162
10
2
10
0.02
/ 0.001
0.001
0.005
24
0.5
0.001
41
0.4
0.4
158
4
0.4
2
0.8
0.2
1.2
8
0.1
30
0.8
Disposal Method
Land storage before recycle.
Immediate recycle.
Land storage or open dumping
of dredged sludge in unlined
lagoons.
Dumping in lined or unlined
lagoon.










Open dumping of discarded
slag.









 metric tons per year
                                       9-7

-------
D.    REFERENCES




1.     Air Pollution Engineering Manual. Air & Waste Management Association.



2.     40 CFR 60, Part R
                                    9-8

-------