TRAINING COURSE
FOR
MULTI-MEDIA
INSPECTORS
Instructor Manual
Mexico City, D.F., May 31-June 3,1994
SEDESOL
SECRETARIA DE DESARROLLO SOCIAL
net!
NATIONAL ENFORCEMENT TRAINING INSTITUTE
LLJ
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/tf£ri
Section I Mexican Environmental Program Overview
Section n Health and Safety for Field Activities
Section III Fundamentals of Environmental Compliance
Inspections
Section IV Air Pollution/Hazardous Waste Inspections
Section V Pollution Prevention
Section VI Industrial Processes
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TRAINING COURSE
FOR
MULTI-MEDIA INSPECTORS
Instructor Manual
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TABLE OF CONTENTS
Introduction iii
Workshop History iii
Workshop Planning 1
Hints for Conducting a Successful Workshop 7
Course Outline 9
Lesson Plans 13
Workshop Introduction 15
Agenda 19
Course Critique 21
Section I - Mexican Environmental Program Overview 1-1
Section II - 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 III - 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 - 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 V - Pollution Prevention
Chapter 1 - Introduction to Pollution Prevention 1-1
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Section VI - 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
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INTRODUCTION
KD
This manual is designed to assist instructors who present the workshop Training
Course for Multi-Media Inspectors. The instructor manual is based on the student
manual and includes lesson, plans and marginal notations regarding audiovisual
material, demonstrations, and handouts. A complete description of the audiovisual
materials used in this course can be found in the accompanying Training Course for
Multi-Media Inspectors (Audiovisual Presentation Guide).
WORKSHOP HISTORY K2)
Under the Pollution Prosecution Act of 1990, the United States Environmental
Protection Agency's (EPA's) National Enforcement Training Institute is responsible
for training various technical experts, criminal investigators, lawyers, inspectors, civil
investigators and others in the enforcement of the Nation's environmental laws. One
important element of this responsibility is to assist in the improvement of
enforcement of the environmental laws of other countries, especially border countries.
During 1991, in recognition of the need for long-term protection of human health and
natural ecosystems along their border, Mexico and the U.S. developed the Border
Plan which was released in February 1992. Key components of the Border Plan are
increased training and education of environmental agency personnel.
Since the fall of 1991, EPA has worked closely with Mexico's Secretaria de Desarrolla
Social (SEDESOL) to develop and present a five-day field inspector training course,
Training Course for Multi-Media Inspectors, in support of the Border Plan. Designed
to enhance the enforcement of, and thereby improve compliance with Mexico's
environmental laws, the course has taken on even greater significance as a result of
the 1993 North American Free Trade Agreement, for increased trade between
Mexico and the United States creates the potential for significant environmental
impacts.
The course materials initially developed included information regarding health and
safety issues, environmental compliance inspections, and the following industries:
electroplating, printed circuit boards, furniture finishing, and wood preservation.
Each of these course components was designed as an independent entity so that
courses which uniquely address inspectors' needs could be planned and presented.
When the agenda for the first inspector training course (held in Tijuana, Baja
California, March 23-27, 1992) was being planned, EPA was asked to include
presentations on health and safety, environmental compliance inspections, and
electroplating and printed circuit board industries, since such facilities were major
environmental threats in the Tijuana area.
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The second inspector training course was held in Juarez, Chihuahua, June 8-12, 1992.
To address the needs of inspectors in this area, new course materials regarding
injection molding and rock-crushing/cement production were developed.
Two more courses based on the original materials were later held in two additional
border locations: Matamoros, Tamaulipas (September 14-18, 1992) and Mexicali,
Baja California (September 21-25, 1992).
When subsequent training was being planned for presentation in interior locations of
Mexico, SEDESOL requested that EPA develop new materials which addressed
major environmental concerns of these sites. Specifically, EPA was asked to provide:
1) brief summaries of process descriptions, air pollution emission points, potential
hazardous waste generation, and pollution prevention and control activities for nine
industries, 2) materials concerning air pollution control devices, and 3) information
regarding air pollution and hazardous waste inspection procedures.
Such changes to the course materials necessitated alterations of the presentations as
well. Whereas three industries commonly had been discussed in great detail during
the border-area courses, five or six of the new, abbreviated industry presentations
were now requested. Two inspector training courses based on the new materials have
been offered in interior locations: Mexico City, D.F., April 26-30, 1993, and
Guadalajara, Jalisco, July 19-23, 1993.
To date, nearly 500 Mexican environmental inspectors and other SEDESOL
personnel have attended the 5-day training course. Since numerous personnel remain
to be trained, however, SEDESOL has requested EPA's assistance in developing a
"Train-the-Trainer" workshop in which select, experienced members of SEDESOL's
staff will become qualified to take over the training needs for SEDESOL.
You have been selected to be a member of the core group of instructors who will
conduct future presentations of the Training Course for Multi-Media Inspectors. We
hope that you find the information provided useful and encourage you to revise or
create materials as necessary to accommodate the needs of your agency personnel.
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WORKSHOP PLANNING
INTRODUCTION
The overall success of a workshop rests, in large part, on the adequacy of the
planning and execution of workshop logistics. Experience has shown that the meeting
room setup, ease of registration, access to refreshments, lighting, quality of
audiovisuals, etc., directly affect the perceived value of the training program. This
section identifies numerous activities involved in preparing for and conducting a
successful workshop.
WORKSHOP DATE(S)
Determine what, if any, conflicting events (e.g., holidays, locally-held conferences,
etc.) might interfere with the date(s) to hold the course.
Provide sufficient lead time so that all other workshop planning activities may be
accomplished.
COURSE FACILITY
Location
Select the course location based on cost, conference room acceptability, accessibility
to attendees, proximity to field trip sites, and safety/entertainment considerations.
Try to hold the course at a hotel (or conference center), rather than at an agency
office. If the course is held where attendees work, other business concerns may prove
to be distracting, and attendance may suffer. Hotels offer several additional
advantages. If sufficient numbers of people register, lodging rates may be reduced,
and conference rooms may be offered at little or no cost. In addition, since many
hotels provide free transportation to and from airports, vehicle rental may be
unnecessary. Attendees who stay in a hotel where the course is given are also more
likely to arrive on time on a daily basis. Many hotels/conference centers also can
provide audiovisual equipment and cater to breaks/lunch needs.
Breaks
Try to provide coffee, tea, soft drinks, and healthful snacks to the course attendees
during scheduled breaks. Having these items available either within or near the
conference room is advisable. Ice water should be available at all times.
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Meals
Breakfast
If the course is being held at a hotel where attendees have registered, try to make
arrangements for a low-cost breakfast for all participants.
Lunch
Try to provide an on-site lunch. Course participants will benefit from the social time
together, and will not have to leave the premises, thereby reducing the number of
late arrivals to the afternoon session.
Conference room
Using a well-designed conference room greatly enhances the effectiveness of the
workshop, for if attendees are comfortable and can hear and see presentations
without difficulty, they will remain more attentive.
Before selecting a conference room, determine the following:
Can the room be darkened so that slides/videos can be seen?
(Try to obtain a room which has rows of lights controlled by dimmer
switches.)
Can the room's temperature be controlled?
Is there a raised platform at the front of the room?
(Instructors/demonstrations will be more visible.)
Does the room have a public address system? (A cordless microphone
and microphone stand are useful items.)
May items be taped onto the walls?
Is there room for several large tables for demonstration items?
Are there comfortable chairs and tables for the attendees?
Is a lectern available?
Is the shape of the room appropriate? (A short, wide room is more
desirable than a long, narrow one.)
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AUDIOVISUAL EQUIPMENT
See if the course facility can provide audiovisual equipment. Many hotels/conference
centers provide such equipment for a daily rental fee or at no cost. Facilities which
do not have necessary items often can provide information regarding where such
equipment can be rented.
The following items are used in the Training Course for Multi-Media Inspectors'.
videocassette recorder
(2) television monitors
slide projector (preferably with telephoto lens, extra bulb, autofocus,
remote control, and long extension cord for remote control)
screen (as large as possible)
slide trays (be sure your trays will fit the projector to be used)
electrical extension cords
laser pointer (optional)
flip charts/easels/marking pens and/or blackboard/chalk
TRAVEL ARRANGEMENTS 1(9)
Make arrangements well in advance for transportation and lodging. Determine if a
rental vehicle is necessary. Obtain tourist guides and other city information if
possible.
REGISTRATION FORMS
Have course attendees complete and submit these to you before attending the
workshop. In addition to the attendee's name, address, title, etc., the registration
form should request information regarding educational background, work experience,
and any special needs (e.g., sign-language interpreters, wheelchair access to
conference room, etc.).
Pre-registration will facilitate making arrangements for the conference room, breaks,
lunch, and field trip, and preparing appropriate amounts of course materials.
INSTRUCTORS
Select instructors who have both technical expertise and the ability to communicate.
Instructors should be accustomed to enhancing their presentations with slides,
videotapes, and other audiovisual materials, and know how to operate audiovisual
equipment.
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Try to use instructors who have compliance inspection, health and safety, industrial
process, and teaching backgrounds.
COURSE MATERIALS
Agenda
Include in the agenda the name, address, room and telephone number of the course
location; course dates; course contact name and telephone number; and presentation
information (session titles, times, instructors).
Be sure to schedule sufficient time for breaks (approximately 10 minutes every IV2
hours) and lunch {Wi hours).
Provide the agenda to the course attendees before the workshop, so they can make
appropriate travel plans. Include an agenda in the student course manual as well.
Critique
Include a course critique in the student manual. Information received can help
improve the course.
Manuals
Once the number of attendees has been determined, make sufficient copies of the
student and instructor manuals (including the audiovisual presentation guide). If
possible, have several extra sets of manuals on hand to accommodate late registrants,
course visitors, technical help, interpreters, etc. Consider printing student manuals
single-sided, or provide blank pages at the end of each course session or a notebook
for note-taking. Use three-hole punched paper, and three-ring binders for the
manuals. Order divider sheets for the manuals well in advance of the course, for
these often must be specially ordered. Using different color, heavy-gauge paper stock
for the student and reference manual cover sheets/spines makes it easier to distribute
and refer to these materials during the presentations.
Attendance List/Records
List, alphabetically, the names of the course attendees and keep daily (a.m. and p.m)
attendance records. Be sure to verify the spelling of the attendees' names before
completing certificates of attendance. Retain a copy of the attendance list, for
validation of the individual's attendance may be required in the future.
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Certificate
Create a certificate and complete one for each individual who has met all workshop
requirements. If possible, issue these to the attendees before they leave the
workshop.
Miscellaneous materials
Nametags (clip-on or pin-on)
Stiff paper for name "tents"
Pencils, pens
Breakfast, lunch tickets
SHIPPING COURSE MATERIALS i(ii)
Demonstration equipment/materials and manuals should be assembled, packaged,
and shipped to a responsible individual at the course location. NEVER ship
workshop slides and videotapes ahead, nor entrust them to airport baggage handlers.
Such materials should be personally transported.
FIELD TRIP PLANNING
Whenever possible, local agency personnel should select and visit potential field trip
sites. The facilities should be within 30 minutes driving distance from the workshop
location, and have good compliance and safety records. While at the facilities,
agency personnel should discuss the purpose of the proposed field trip, request
permission to visit, and arrange for personal protective equipment for attendees if
necessary.
Based on the expected number of attendees, determine the type, size and number of
vehicles needed and make arrangements for their use on the day of the field trip. If
vehicles must be rented, make arrangements well ahead of time.
PRE-WORKSHOP COMMUNICATIONS
Local contact
Develop a relationship with a responsible party at an environmental compliance
agency near the workshop location. This individual may be able to assist in the
selection of the workshop location and field trip sites, and may accept responsibility
for shipped course materials.
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Attendees
Send attendees a verification of registration, agenda, and detailed travel information
several weeks before the workshop.
Instructors
Provide instructors with an instructor manual, audiovisual presentation guide, and
detailed travel information before the workshop.
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HINTS FOR CONDUCTING A SUCCESSFUL WORKSHOP
1(12)
INSTRUCTORS
Designate a "lead" instructor who will be responsible for introducing the course and
making final decisions regarding any problems which may arise. This individual
should monitor all presentations and ensure that the objectives of the presentations
are met and that instructors abide by the designated time allotments.
AUDIOVISUAL MATERIALS
Prior to the workshop, become thoroughly familiar with the various
audiovisual materials (slides, videotapes, demonstration items) which
accompany presentations Learn how to operate the VCR/monitors and slide
projector (and how to change the bulb) and how to present demonstration
materials, so there is minimal disruption during presentations.
Before showing a videotape, describe to the attendees the video's content and
length. After the video has been show, briefly discuss it.
Whenever possible, pass demonstration items among the attendees during the
presentation and leave items on display for further examination.
PRESENTATION 1(13)
Try to alternate instructors as the course progresses. This will help keep the
instructors' voices healthy and maintain the attendee's interest in the material
being presented.
Use anecdotes to capture the. attendees' interest. Describe pertinent personal
experiences and ask the attendees to relate their own.
Diversify the course presentations A combination of lecture material,
audiovisual presentations, and hands-on and group activities will help to
maintain interest in the course.
When forming groups, combine experienced and inexperienced individuals
from different regions; each combination of individuals, however, should have
approximately the same total experience.
Encourage participation by asking numerous questions and soliciting questions
from the attendees. If the answer to a particular question will take too long or
is of limited concern to the rest of the audience, meet with the interested
individual(s) during a break or after the course has ended for the day to
address the issue.
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Speak in a clear, deliberate, but stimulating way (no monotone!), and at a
pace that allows easy note-taking.
When presenting material, keep in mind the experience/ability level of the 1(14)
audience. Avoid technical jargon if individuals aren't familiar with the
terminology.
Tell attendees frequently where you are in the course materials. When you
cite specific written materials or diagrams, etc., allow sufficient time for the
attendees to find referenced items before proceeding with the presentation.
If time permits, try to involve members of the audience when demonstrating
equipment or procedures.
At the end of each session, answer any questions the attendees may have, and
then introduce the next session.
Stick to the break schedule during the workshop.
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COURSE OUTLINE
K15)
WORKSHOP GOAL
The five-day Training Course for Multi-Media Inspectors has been developed to
enhance the enforcement of (and thereby improve compliance with) Mexico's
environmental laws. The workshop was created in response to the need for increased
training and education of environmental inspectors which was stated as a key
objective in the Mexico-U.S. Border Plan. The Border Plan was developed to
provide for the long-term protection of human health and natural ecosystems along
the border between Mexico and the U.S.
WORKSHOP OBJECTIVES
During the Training Course for Multi-Media Inspectors, Mexico's environmental
program, health and safety issues, compliance inspection planning, plant survey and
inspection techniques, industrial processes, air and hazardous waste emission points,
air pollution control devices, and pollution prevention activities are discussed.
After attending this workshop inspectors should be able to:
determine the applicability of Mexican environmental regulations to the site
being inspected;
recognize potential safety hazards, select and use proper personal protective
equipment, and conduct a safe inspection;
plan and prepare properly for inspections;
conduct environmental compliance inspections which are effective in
promoting compliance with environmental regulations;
locate and evaluate potential air and hazardous waste emission points at
various industrial facilities;
assess the effectiveness of air pollution control devices encountered during
inspections; and
discuss and encourage the implementation of pollution prevention activities at
industrial facilities.
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PRESENTATION MATERIALS AND EQUIPMENT
Course texts:
Training Course for Multi-Media
Training Course for Multi-Media
Training Course for Multi-Media
Training Course for Multi-Media
Slide projector
VCR with two monitors
Laser pointer (optional)
Slides
Videotapes: Workplace Safety: Everybody's Business
Heat Stress
Respiratory Protection
Pollution Prevention: The Bottom Line
Pollution Prevention: Reducing Waste in the Workplace
Demonstration materials (See individual lesson plans for more detail.)
Flipcharts
Markers
Nametags
Name tents
Adhesive tape
Cordless microphone
Extension cords
Inspectors (Student Manual)
Inspectors (Industrial Processes Reference Manual)
Inspectors (Instructor Manual)
Inspectors (Audiovisual Presentation Guide)
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COURSE SESSIONS
Session Topic Duration (hrs.1
Course Introduction 1.00
I. Mexican Environmental
Program Overview 6-8
II. Health and Safety for 1.0 Preparation for Field Activities 0.50
Field Activities
2.0 Hazards, Exposure and Evaluation 3.00
3.0 Protective Clothing and Equipment 0.75
4.0 Respiratory Protection 0.75
III. Fundamentals of 1.0 - 2.0 Introduction, Planning/Preparation 0.50
Environmental
Compliance Inspections 3.0 Entry/Opening Conference 0.50
4.0 Information Gathering and
Documentation 1.50
5.0 Post-inspection Activities 0.25
IV. Air Pollution/Hazardous 1.0 Principles of the Baseline Method,
Waste Inspections Level II Inspections 1.00
1.0 Air Pollution Control Technologies 2.25
2.0 Hazardous Waste Inspections 1.00
V. Pollution Prevention 1.0 Introduction to Pollution Prevention 1.00
VI. Industrial Processes 1 Petrochemical Industry 1.00
2 Chemical Manufacturing 1.00
3 Pharmaceutical Manufacturing Plants 1.00
4 Metallurgical Industries 1.00
5 Tanneries 1.00
6 Cement Industries 1.00
7 Printed Circuit Board Manufacturing 1.00
8 Electroplating 1.00
9 Lead Smelting 1.00
VII. Field Trip/Course Wrap-up 6-8
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REFERENCE MATERIALS
Much of the health and safety information presented in this workshop was derived from
the U.S. EPA's Basic Health and Safety Manual for Field Activities.
Information regarding inspection techniques was obtained primarily from the following
U.S. EPA training materials:
Fundamentals of Environmental Compliance Inspections.
Baseline Inspection Techniques
Level II Inspection Manual for Air Pollution Stationary Sources
Air Compliance Inspection Manual.
Sources used in preparing the industrial process sections of this workshop are listed in a
bibliography at the end of each industrial process.
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LESSON PLANS
Detailed lesson plans for the "Health and Safety for Field Activities", "Fundamentals of
Environmental Compliance Inspections", "Air Pollution/Hazardous Waste Inspections",
"Pollution Prevention", and ."Industrial Processes" components of this course have been
placed at the beginning of the written material for each course session in this instructor
manual.
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WORKSHOP INTRODUCTION
Duration: 1.00 hour
References: Training Course for Multi-Media Inspectors (Instructor Manual)
Training Course for Multi-Media Inspectors (Student Manual)
Training Course for Multi-Media Inspectors (Industrial Processes
Reference Manual)
Training Course for Multi-Media Inspectors (Audiovisual Presentation
Guide)
Session outline:
Distribute course materials.
Introduce course/welcome participants.
Introduce instructors.
WO(l)
Ask participants to complete registration forms; discuss issuance of certificates.
Tell attendees to put their names on the front covers of the course manuals.
Determine participants' backgrounds in general - ask them what their duties
are within the enforcement agency, how long they've done this kind of work,
etc. - this will permit instructors to gear technical information to the
ability/backgrounds of attendees.
Ask participants to introduce themselves, describe their job responsibilities,
and say how long they have worked in the enforcement area.
Discuss participant responsibilities: attendance, participation, critiques.
Discuss facility information: telephone number of facility, smoking areas,
bathroom/telephone locations, parking, obtaining messages, lunch
arrangements.
Present course background:
The Training Course for Multi-Media Inspectors was developed in
response to an agreement between Mexico and the United States to
support one another's efforts in the areas of pollution prevention and
environmental law enforcement. The course has been designed for
individuals involved in enforcement of Mexico's environmental laws.
As such, SEDESOL's field inspectors and in-house personnel, such as
permit writers, managers, and legal staff can benefit from the
information presented during this workshop.
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During the five-day workshop, Mexico's environmental program, health and
safety issues, basic inspection techniques, air pollution/hazardous waste
inspection techniques, and industrial processes are discussed.
To date, over 400 Mexican environmental inspectors and other SEDESOL
personnel have attended this course which has been presented in cities along
the Mexico/U.S. border area and in the Mexican interior.
Review course materials:
Training Course for Multi-Media Inspectors (Student Manual)
Have the participants scan through the manual. Tell them that this
workshop provides only preliminary information regarding several areas
of importance and encourage them to obtain more advanced training
whenever they can.
Training Course for Multi-Media Inspectors (Industrial Processes Reference
Manual)
This manual contains detailed information regarding six
industrial processes: furniture finishing, electroplating, printed circuit
boards, wood preservation, rock crushing/cement production, and
injection molding. When the workshops were first presented, three of
the six industries in this reference manual were discussed in great
detail. Since that time, the course has been altered so that more
industries can be discussed.
Discuss critique forms - ask participants to complete as course progresses.
Discuss agenda - note starting/ending times, breaks, lunch, topics.
Day 1 - Mexican Environmental Program Overview
Day 2 - Course Introduction, Health and Safety for Field Activities
Day 3 - Fundamentals of Environmental Compliance Inspections, Air
Pollution/Hazardous Waste Inspections, Pollution Prevention
Day 4 - Industrial Processes
Information for as many industries of concern as possible will be
presented; due to time constraints, probably only five will be discussed.
For each industry selected, the process itself, emission points for air
pollutants and hazardous waste, pollution prevention and control, and
health and safety issues will be discussed.
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Day 5 - Field Trip
On the fifth day, workshop attendees will visit one or two local
industries whose processes have been discussed and make note of
health and safety issues and the status of the facility's compliance
with environmental regulations. All participants should wear
appropriate clothing and bring a notebook and pen to record
observations. After the field trip and lunch, attendees will discuss
observations and complete the course critiques.
Audiovisual and graphic materials:
Slides: WO(l)
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TRAIN THE TRAINER (T3)
WORKSHOP AGENDA
DAY 1
09:00 a.m. - 09:30 a.m.
09:30 a.m. - 10:30 a.m.
10:30 a.m. - 10:40 a.m.
10:40 a.m. - Noon
Noon - 12:15 p.m.
12:15 p.m. - 02:00 p.m.
02:00 p.m. - 03:30 p.m.
03:30 p.m. - 04:15 p.m.
04:15 p.m. - 04:25 p.m.
04:25 p.m. - 05:30 p.m.
DAY 2
09'00 a.m. - 09:30 a.m.
09:30 a.m. - 10:30 a.m.
10:30 a.m. - 10:40 a.m.
10:40 a.m. - 11:40 a.m.
11:40 a.m. - 12:15 p.m.
12-15 p.m. - 12:30 p m.
12.30 p.m. - 02.00 p.m.
02:00 p.m. - 03:30 p.m.
i.unsikuman
Presenter
Introduction W. Haythe
Course/Instructors/Participant Introductions J. Jeffery
MINI-BREAK
Organizing a workshop
BREAK
Organizing a workshop (cont'd)
LUNCH
Health and Safety
MINI-BREAK
Health and Safety
N. Lebedzinski
J. Jeffery
O. Loera
N. Lebedzinski
Health and Safety
N. Lebedzinski
Fundamentals of Environmental Compliance
Inspections
MINI-BREAK
Fundamentals of Environmental Compliance
Inspections (cont'd)
Video: The Bottom Line/discussion
BREAK
Air Pollution/Hazardous Waste Inspections
LUNCH
O. Loera/
N. Lebedzinski
O. Loera
O. Loera
J. Jeffery/
J. Van Gieson
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03:30 p.m. - 04:15 p.m.
04:15 p.m. - 04:25 p.m.
04:25 p.m. - 05:00 p.m.
05:00 p.m. - 05:30 p.m.
DAY 3
09:00 a.m. - 10:30 a.m.
10:30 a.m. - 10:40 a.m.
10:40 a.m. - Noon
Noon - 12:15 p.m.
12:15 p.m. - 02:00 p.m.
02:00 p.m. - 03:30 p.m.
03:30 p.m. - 04:15 p.m.
04:15 p.m. - 04:25 p.m.
04:25 p.m. - 05:15 p.m.
05:15 p.m. - 05:30 p.m.
DAY 4
09:00 a.m. - 01:00 p.m.
01:00 p.m. - 02:00 p.m.
02:00 p.m. - 03:30 p.m.
03:30 p.m. - 04:30 p.m.
04:30 p.m. - 05:00 p.m.
T3INSIRU.MAN
Air Pollution/Hazardous Waste Inspections
(continued)
J. Jeffery/
J. Van Gieson
MINI-BREAK
Air Pollution/Hazardous Waste Inspections
(continued)
J. Jeffery/
J. Van Gieson
Video: Reducing Waste in the
Workplace/discussion
J. Jeffery
Industrial Process
MINI-BREAK
Industrial Process
BREAK
Industrial Process
LUNCH
Industrial Process
MINI-BREAK
Industrial Process
Field trip preparations
N. Lebedzinski
J. Jeffery
O. Loera
J. Van Gieson
N. Lebedzinski
O. Loera
Field trip to industries
Return from field trip
LUNCH
Field trip discussion
Workshop review/closing J. Jeffery/
W. Haythe
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INDIVIDUAL WORKSHOP CRITIQUE
Name of Workshop:
Location: Date:
Your evaluation of this course and suggestions for future workshops are important to us.
Please take time to share your thoughts with us by completing this form and submitting it to
us at the end of the workshop.
1. Was the time allowed for questions/discussions adequate?
2. The best part(s) of the workshop was/were:
3. Please suggest ways to improve the course:
4. What other training would you like to see offered?
5. When would you like this additional training to take place?
6. Additional comments
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rating scale
1 Excellent 2 Very Good 3 Good 4 Fair 5 Poor
Using the above rating scale, please indicate to which extent you were satisfied with the
following aspects of the workshop.
Organizing a Workshop
Session content
Iristructor(s)
Course manual
Health and Safety
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Course manual
Inspection Fundamentals
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Instructor(s)
Course manual
Air/Hazardous Waste Inspections
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Industrial Processes
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Field Trip
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Discussion
IUNS1RUMAN
22
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MEXICAN ENVIRONMENTAL PROGRAM
OVERVIEW
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LESSON PLAN
MEXICAN ENVIRONMENTAL PROGRAM OVERVIEW
Objective:
Duration:
References:
Session outline:
Background guidance:
Audiovisual and graphic material:
Additional activities:
HINSIKU MAN
1-i
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¦DINSIRIUIAN 1-li
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HEALTH AND SAFETY MANUAL
FOR
FIELD ACTIVITIES
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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
12 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 2-27
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
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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 2-10
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 2-27
2-4 Dose-response curve for a chemical with no TLV 2-28
2-5 Dose-response curve for a highly toxic chemical 2-28
3-1 The ear 3-3
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ii
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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.
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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.
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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
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LESSON PLAN
1.0 PREPARATION FOR FIELD ACTIVITIES
Objective: To identify key elements that must be considered when preparing for field
activities.
Duration: 0.50 hour
References: Training Course for Multi-Media Inspectors (Student Manual)
Section II, Chapter 1
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide) -
Section II, Chapter 1
Session outline: 1.1 Objective
1.2 Introduction
1.3 Pre-Field Activity Evaluation
1.4 On-site Evaluation
Background guidance: Basic Health and Safety Manual for Field Activities
Audiovisual and graphic material:
Slides: H(intro) - H1.4(5)
Additional activities: None
Chspter J
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T3INSTRU MAN
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CHAPTER 1
1.0 PREPARATION FOR FIELD ACTIVITIES
1.1 OBJECTIVE
To identify key elements that must be considered when
preparing for field activities.
1.2 INTRODUCTION
Importance of
Preplanning
Field personnel encounter a wide variety of
potential hazards.
Preplanning can reduce or eliminate many
hazards.
HU(l-8)
Planning Process
Sources of
Information
Research potential hazards.
Evaluate the risks.
Select appropriate protective equipment and
clothing.
Plant personnel
Agency files
Agency employees
Industry standard references
HU(9)
1.3 PRE-FIELD ACTIVITY EVALUATION
H1J(1)
Planning Guide
Components of the
Planning Guide
Prepare planning guide. (See Appendix 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
Review
Appendix 1-A
1-1
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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
H1.4(l)
Request a health and safety briefing.
Conduct a walk-through survey,
hidden hazards
natural hazards
H1.4(2)
H1.4(3)
Record unexpected hazards, additional gear
requirements.
H1.4(4,5)
1-2
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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
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LODGING ARRANGEMENTS: Motel/Hotel
Location
Telephone
SITE ACCESS REQUIREMENTS:
Identification
Permits
Visitor's agreement
Special problems
Type of communication needed
VEHICLE(S) AND EQUIPMENT:
Motor Vehicles
Make License Plate
Mobile laboratory 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
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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 #
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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
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1-6
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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 emergen*^. A
second copy should be filed with a supervisor oefore leaving for the site. Such information is
particularly important for visits to sites where crews may be stranded or lost.
1-7
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LESSON PLAN
2.0 HAZARDS, EXPOSURE AND EVALUATION
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.
Duration: 3.00 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section II, Chapter 2
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide)-
Section II, Chapter 2
Session outline: 2.1 Objective
2.2 Introduction
2.3 Safety Guidelines and Techniques
2.4 Heat Stress
2.5 Fire and Explosion Hazards
2.6 Selection and Use of Fire Extinguishers
2.7 Chemical Hazard Recognition and Evaluation
2.8 Effects of Toxic Chemicals in the Body
2.9 Dose-Response Curves
2.10 Evaluating Health Hazards and Toxicity Information
2.11 References
2.12 Emergency First Aid for Field Activities
Background guidance: Basic Health and Safety Manual for Field Activities
Audiovisual and graphic material:
Videotapes: Workplace Safety, Heat Stress
Booklet: Confined Space Entry
Demonstration materials: Pocket Guide to Hazardous Chemicals, first aid manual,
Material Safety Data Sheets (MSDSs), fire
extinguishers
Slides: H.Ch2(a) - H2.12(l)
Additional Activities:
Set out MSDSs for chemicals inspectors are likely to encounter.
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T.MNSTRU.MAN 2" i 1
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CHAPTER 2
2.0 HAZARDS, EXPOSURE AND EVALUATION H.Ch2(a,b)
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 H2.2(i)
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 H23(i)
Lifting and carrying
Ladders and climbing
Power sources and electrical equipment
Confined spaces
Mechanical hazards
Biological hazards Show video.
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Lifting and carrying
Assess the following:
overall weight
distribution of weight
security of contents
distance
obstacles
surface conditions
visibility
H23(2-4)
Use two people.
Lift with power of leg muscles.
Do not climb ladder with heavy load.
Ladders and H23(5,6)
Climbing
Portable Ladders Inspect ladders for hazards. H23(7-i3)
Position ladder base 1/4 of working length from H23(i4,i5)
wall.
Use only ladders with non-skid feet; be sure ladder H23(16)
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. H23(17,18)
Have someone stabilize bottom.
Do not hand carry anything up the ladder. H23(19)
Prevent tools and equipment from catching on H23(20)
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.
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Fixed Ladders
Working
Surfaces
Power Sources/
Electrical
Equipment
Electrical
cords/plugs
Uninsulated
Electrical
Conductors or
Metal Parts
Static Electricity
Sources include:
particulates in process stream
electrostatic precipitators
lightning
Safety precautions:
H23(27-33)
Minimum design load: 91 kg (200 lbs) H23(2i-26)
Evenly spaced stepping surface < 30 cm (12")
Adequate clearance
Minimum 18 cm (7") clearance behind each rung
Safety devices or cages: >6m (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. H23(34)
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. H23(35)
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 H23(36)
grounded.
Use a Ground Fault Circuit Interrupter (GFCI) in the line.
Use double-insulated power tools.
H23 (37,38)
H23(39)
ground sampling probes
be aware of weather conditions
discontinue sampling where lightning hazard exists
use A.M. radio for weather reports/static interference H23(40)
2-3
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Mechanical
Hazards
Confined Space
Biological
Hazards
Remotely controlled vehicles
Forklifts
Potential entanglements
See booklet for information on confined space entry.
Entering certain locations can be hazardous due to the
.presence of various biological hazards.
H2J(41-44)
H2 j(45-51)
Distribute and
review booklets.
H23<52)
Ticks Live in areas with tall grasses, bushes. H.23(53)
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.
Snakes Learn to recognize poisonous varieties. H23(S4)
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
Spiders
Bees/wasps
Scorpions
Learn to recognize dangerous varieties. H23(55)
Get medical help for bites as soon as possible.
Tarantula bites are painful but seldom serious.
Recognize their habitats. H23(56)
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. H23(57)
Carry anti-sting kit - sting can be fatal to allergic
individual.
Administer CPR if necessary.
Seek medical help if stung.
2-4
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Rabid Animals Can infect any warm-blooded animal (foxes, dogs, H23(58)
bats, raccoons, skunks, squirrels).
Animals may exhibit lack of fear, aggressiveness,
dropping head, peculiar trotting gait, unusual
behavior.
H23(59)
Micoorganisms
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.
H23(60)
2.4 HEAT STRESS
H2.4(l-3)
Preventing/
Reducing 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
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.
Briefly review 2.4
and show video.
2-5
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Drink appropriate amounts and types of fluids:
250 ml (V2 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.
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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 QA cup) every 15 minutes for one
hour.
Get medical help if symptoms not relieved
2.5 FIRE AND EXPLOSION HAZARDS
H2.5(l)
Recognition of
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.
Fuel
H2i(2)
Heat
Oxygen
2-7
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Essential
Components
Combustible
Materials
Combustible material (fuel)
Oxidizer (oxygen in atmosphere)
Ignition energy (heat)
Those posing greatest concern are dusts, vapors, and gases
that can be 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.
H2.5(3)
H2J(4)
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.
H2.5(5)
H2.5(6)
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.
H2.5(7)
H2i(8)
Ignition
Energy
Amount needed depends on:
state and concentration of the combustible
material; and
concentration of oxygen.
Sources:
heated metal
sparks
flames
static electricity and sparks
H2J(9)
O 0
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sunlight
lasers
ionizing radiation
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 H2.5Q0)
acid, chlorine and fluorine may act as oxidizers.
Fire and Many factors contribute to the occurrence of a fire or an H2.5(ii)
Explosion explosion.
Characteristics
Flammable Flammable concentration: all concentrations at
Concentration and which flame 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.
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Flash point Temperature at which a liquid will give off enough H23(i2)
vapor to allow flame to propagate through the Review Tab*,
vapor-air mixture; liquids with low flash points are
generally more hazardous. See Table 2-1.
TABLE 2-1. CHARACTERISTICS OF FLAMMABLE LIQUIDS
Liquid
Explosion Limits
(% in air)
Vapor Pressure
(mm Hg at STP)
Flash Point (°C)
Vinyl acetate
2.6 - 13.4
115
-8
Acetone
2.6 - 12.8
227
-18
Ethyl alcohol
3.3 - 19.0
50
13
Methyl ethyl
ketone
1.4 - 11.4 (93°C)
71
-9
Gasoline
1.4 - 7.6
?
-43
Kerosene
0.6 - 5.0
?
38
Toluene
1.2 - 7.1
30
4
Trichloroethylene
12.5 - 90
77
37
Xylene
1.1 - 7.0
10
29
Specific Gravity
Vapor Density
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.
H2.5(13)
2-10
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Preventing Fire Keep ignition sources away from flammable 112.5(H)
and Explosions concentrations.
Identification of
Hazards
Control of
Ignition Sources
Instalments and
Equipment
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 H2.5(i5)
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 H2J(19)
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.
H2.5(16)
H2.5(17,18)
Control of Static
Electricity
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.
Sources
Preventing
Accumulation or
Discharge
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.
Ground probes used for stack sampling.
Provide a bonding connection between metal
containers when flammable gases or liquids are
transferred or poured.
Wear footwear with adequate conductivity for the
conditions.
H2.5(20)
H2.5(21)
2.6 SELECTION AND USE OF FIRE EXTINGUISHERS H2.6(
Fire Classification/
Treatment
Fire is an oxidation process which requires three key
components: fuel, oxygen, heat. Removal of any of these
three will stop the oxidation process.
See Table 2-2.
Review Table 2-2.
Fire Extinguisher
Identification
See Table 2-3.
Review Table 2-3.
H2.6(2-4)
Firefighting
Precautions
Warn others to evacuate area.
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.
n
-------
Prepare and test extinguisher before approaching fire.
Aim at base of fire.
Stream reaches about 9 m (30').
Stajid 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 C02; 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.
2-13
-------
TABLE 2-2. FIRE CLASSIFICATION AND EXTINGUISHING MEDIA
Class
Description
Examples
Extinguishing
Media
A
ordinary
combustibles
wood, paper, cloth,
rubber
water, Halon 1211,
baking soda
B
flammable or
combustible liquid
or gases
gasoline, fuel oil,
kitchen grease,
alcohol, propane
C02, dry
chemicals, foam,
Halon 1211, Halon
1301
C
electrical
equipment
electrical
equipment
dry chemicals,
C02, Halon 1211,
Halon 1301
D
combustible metals
that burn vigorously
and react violently
with water
Na, K, Mg, Ti, Zi
dry powders
(graphite, NaCl,
other free-flowing
noncombustible
materials
TABLE 2-3. FIRE EXTINGUISHER IDENTIFICATION
Class Type
Symbol Description
A
Burning wastebasket and bonfire
B
Container pouring liquid and a fire
C
Electrical plug and a receptacle with
flames
2-14
-------
2.7 CHEMICAL HAZARD RECOGNITION AND EVALUATION
H2.
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
Physical Solids H2.7(2)
Classification Liquids
Aerosols
Gases and vapors
Solids Particulates (lead, asbestos) H2.7(3)
Sensitization (Ni)
Fumes
Sublimation
Reactivity
Liquids 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
2-15
-------
Aerosols
Gases and Vapors
Physical and
Chemical
Characteristics
Aerosols are fine particulates (solid or liquid) 112.7(4-6)
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. Review Table 2-4.
Gases and vapors may present inhalation, eye and
skin hazards.
Boiling point - temperature at which liquid changes H2.7(7,8)
to a gas.
Melting point - temperature at which a solid H2.7(9)
changes to a liquid.
Vapor pressure - pressure of vapor immediately H2.7(10)
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 H2.7(ll)
that will completely dissolve in a given volume of
another substance.
Flash point - lowest temperature at which a liquid H2.7(12)
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 H2.7(i3)
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.
o 1 r.
-------
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/m
J(i)
mg/m3
mg/m3
Incinerator (less
than 0.5)
mg/m3
CO
HjS
ppm
(2)
Acetone
Carbon disulfide
Benzene
ppm
(l) mg/m3 - milligrams per cubic meter.
ppm - parts of gas or vapor per million parts of air.
2-17
-------
Warning Properties
Reactivity - refers to the likelihood of reacting, H2.7(14)
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 H2.7(15)
and taste.
Odor Threshold
Eye, Nose andThroat
Irritation
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 H2.7(i6)
(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.
(NH,)
Useless odor threshold is well above PEL. (vinyl
chloride)
Olfactory fatigue may influence recognition of H2.7(17)
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 H2.7(i8)
concentrations below the PEL. (saccharin)
Airborne Since some chemicals do not have adequate H2.7(i9-22)
Concentration 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
?-1R
-------
Chemical Use Degree of hazard is significantly influenced by the way a H2.7(23)
chemical is used.
open tanks, hot chemicals, high vapor pressure, H2.7(24)
poorly designed or malfunctioning ventilation
system = high airborne concentration
closed system = lower airborne concentrations
Other Temperature. H2.7(25)
Environmental Relative humidity.
Factors
2.8 EFFECTS OF TOXIC CHEMICALS IN THE BODY
Toxic chemicals can affect the body in different ways, H2.8(i)
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 H2.8(2)
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 H2.8(3)
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 No reaction - skin acts as effective barrier H2.8(4)
of chemical Skin irritation or destruction of tissue
contact Skin sensitization
Chemical penetrates skin and enters blood stream
2-19
-------
hair shall
epidermis
dermis ¦<
/arty layer J
(subcutaneousj[_
nerve ending
(pain receptor)
lal cells
perspiration
pore
capillaries
muscle
oil gland
nerve ending
(pressure
receptor)
sweat gland
blood vessels
connective tissue hair follicle
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
H2.8(5)
H2.8(6)
epiglottis
^larynx
scplum of
nasdlcaviiy
moulh cavity
longue
pleural
pharynx
mcrnb(a*\c
(surrounds
vocal
me lungs)
epiglottis
larynx
esophagus
trachea
nghl lung
(middle
lobe)
\
esophagus
trachea
lell bronchu
bronchiole
bronchial
tube
diaphragm
abdominal
cavity
Figure 2-2. Organs of the human respiratory system
2-21
-------
Damaging Asphyxiants - gases which can deprive body tissues of H2.8(7)
substances oxygen.
simple asphyxiants - displace oxygen and lead to
suffocation (N2, He; CH4, Ne, Ar)
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: 03, HF,
nh3, so,.
Fibrosis producers - kill normal lung tissue and produce H2.8(8)
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 Review Table 2-5.
respiratory tract disorders.
Gastrointestinal Chemicals may have a toxic effect on all major and H2.8(10)
System accessory organs (e.g., liver) of the gastrointestinal tract.
Potential means Mouth pipetting
of ingestion Contaminated water or food
Contaminated smoking materials or cosmetics
Contaminated hands
Drinking from contaminated containers
2-22
-------
Length of Toxic chemicals may affect the body in different ways, H2.8(ii)
Exposure 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 Exposures Acute, or short-term, exposures to some chemicals can
and Effects 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).
Chronic Repeated or prolonged exposure to low concentrations
Exposures and of some toxic chemicals can cause adverse effects of long
Effects duration or frequent reoccurrence.
Organs and Many toxic substances are associated with specific toxic
Systems Affected 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 H2.8(12)
toxic response to chemical substances (see Table 2-6).
2-23
-------
TABLE 2-5. INDUSTRIAL TOXICANTS THAT PRODUCE DISEASE OF THE
RESPIRATORY TRACT
Toxicant
Site of Action
Acute Effect
Chronic Effect
Aluminum
Upper airways
Cough, shortness of
breath, irritation
Fibrosis and
emphysema
Ammonia
Upper airways
Irritation
Bronchitis, edema
Arsenic
Upper airways
Bronchitis irritation,
pharyngitis
Cancer, bronchitis,
laryngitis
Asbestos
Lung tissue
Fibrosis, cancer
Beryllium
Alveoli
Edema, Pneumonia
Fibrosis, ulceration
Boron oxide
Alveoli
Edema, hemorrhage
Cadmium oxide
Alveoli
Cough, pneumonia
Emphysema
Carbides of
tungsten, titanium,
and tantalum
Upper, lower
airways
Hyperplasia,
metaplasia of
bronchial cells
Fibrosis
Chlorine
Upper airways
Cough, irritation,
asphyxiant
Chromium VI
Nasopharnyx, upper
airways
Nasal irritation,
bronchitis
Cancer
Cobalt
Lower airways
Asthma
Fibrosis, interstitial
pneumonitis
Hydrogen chloride
Upper airways
Irritation, edema
Iron oxides
Alveoli, bronchi
Cough
Benign
pneumoconiosis
Isocyanates
Lower airways,
alveoli
Bronchitis,
pulmonary edema,
asthma
Manganese
Lower airways
alveoli
Pneumonia, often
fatal
Recurrent
pneumonia
Nickel
Nasal mucosa,
bronchi
Irritation
Cancer
2-24
-------
TABLE 2-5 (CONTINUED)
Toxicant
Site of Action
Acute Effect
Chronic Effect
Nickel carbonyl
Nitrogen oxides
Osmium tetraoxide
Ozone
Phosgene
Phthahc anhydride
Sulfur dioxide
Tin
Toluene
Vanadium
Alveoli
Bronchi, alveoli
Upper airways
Bronchi, alveoli
Alveoli
Lower airways,
alveoli
Upper airways
Bronchioles, pleura
Upper airways
Upper, lower
airways
Edema (delayed
symptoms)
Edema
Bronchitis,
bronchospasm
Irritation, edema,
hemorrhage
Edema
Bronchitis, asthma
Bronchoconstriction,
cough, tightness in
chest
Bronchitis, edema,
bronchospasm
Irritation, nasal
inflammation, edema
Emphysema
Bronchopneumonia
Emphysema,
bronchitis
Bronchitis, fibrosis,
pneumonia
Emphysema
Bronchitis,
nasopharyngitis
Widespread mottling
of x-ray without
clinical signs (benign
pneumoconiosis)
Bronchitis
Xylene
Lower airways
Edema, hemorrhage
-------
TABLE 2-6 ORGANS/SYSTEMS AFFECTED BY CHEMICAL EXPOSURE
Organs or System
Chemicals Causing Effects
Liver and Bile Ducts
Vinyl Chloride, Aromatic
(Hepatic System)
Hydrocarbons
Kidney (Renal System)
Heavy Metals, Halogenated
Hydrocarbons
Blood and the Blood-
Benzene, Lead
forming System
(Hematopoietic System)
Heart, Cardiovascular
Carbon Monoxide, Arsine
System (CVS)
Neuroendocrine System
DDT
Immune/Allergy System
Triphenyltin
Central Nervous System
Pesticides, Thallium
(CNS)
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 toxicological properties of the material. See Figures 2-3, 2-4, and
2-5 for representative dose-response curves.
Response
1
H2.9(l)
Dose
Compensation
Reversible
Effects
Death
Threshold
Limrt
Value
Irreversible
Effects
Figure 2-3. Classic Dose-response Curve.
2-27
-------
Response
Dose
H2.9(2)
Reversible
Effects
Irreversible
Effects
Death
Compensation
Figure 2-4. Dose-response Curve (or a Chemical with no TLV.
Response
Threshold
Limit
Value
H2.9(3)
Reversible
Effects
Irreversible
- Effects
Death
Compensation
Dose
Figure 2-5. Dose-response Curve for a Highly Toxic Chemical.
-------
T^pes of Effects Some chemicals do not elicit such dose-response relationships. H2.9(4)
Harmful Effects
Sensitization
Effects
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 toxicological 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
H2.9(5)
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
H2.9(6)
H2.9(7)
2-29
-------
Environmental Temperature
Factors Barometric pressure
Radiation
Host Factors Species
Sex H2.9(8)
Hereditary factors
2.10 EVALUATING HEALTH HAZARDS AND TOXICITY INFORMATION H2.10(1)
Reasons to Seek
Information
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?
H2.10(2)
Exposure Limits
Limits on skin contact
Permissible Exposure Limits (PELs)
H2.10(3)
Skin Contact
and Ingestion
Exposure
Most industrial chemicals required to have precautionary
labels.
Skin and systemic toxicity information provided.
Inhalation
Exposure Limits
Threshold Limit Values (TLVs) - reviewed and adopted
annually by the American Conference of Governmental
Industrial Hygienists (ACGIH) - advisory, but more up-
to-date.
Review an MSDS.
Permissible Exposure Limits (PELs) - adopted by the
Occupational Safety and Health Administration (OSHA)
- mandated.
2-30
-------
Categories of
Exposure Limits
Important
Information
Signs and
Symptoms of
Overexposure
Signs of
Inhalation
Exposure
Symptoms of
Inhalation
Exposure
Signs of
Skin Contact
Time-Weighted Average (TWA) - concentration of a toxic H2.i0(4)
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.
PELs do not represent a fine line between safe and H2.10(5)
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.
Since you may not know the identity of toxic chemicals to
which you are being exposed, and many chemicals have
inadequate warning properties, you must be aware of signs and
symptoms of overexposure.
Signs - observable by others
Symptoms - not observable by others
Sneezing H2.i0(6,7)
Coughing
Headache H2.10(8-12)
Dizziness
Nausea
Irritation of eyes, nose, throat
Increased mucus in nose and throat
Redness
Swelling
Dry, whitened skin
2-31
-------
Symptoms of
Skin Contact
Other Signs
and Symptoms
Evaluating
Exposure with
Instrumentation
Irritation H2.10(13
Itching
Changes in behavior H2.i0(i4)
Periods of dizziness
Muscle spasms
Irritability
Air monitoring instrumentation provides the most reliable H2.10(15)
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.
Preparing for Once the appropriate equipment has been selected: H2.i0(i6)
Field Use of
Equipment Read all instructions.
Practice using the equipment.
Calibrate the equipment before and after using it.
Characteristics of
Air Monitoring
Instruments
Quantification of
Airborne
Contaminants
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
H2.10(17)
Review Table 2-7.
2-32
-------
TABLE 2-7. SOME DIRECT-READING INSTRUMENTS
Instrument
Application
Limitations
Combustible Gas
Indicator (CGI)
Measures the
concentration of
combustible gas or
vapor
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.
Flame Ionization
Detector (FID) with
Gas
Chromatography
Option
Gamma Radiation
Survey Instrument
Portable Infrared
(IR) Spectrophoto-
meter
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.
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
2-33
-------
TABLE 2-7 (CONTINUED)
Instrument
Application
Limitations
Ultraviolet (UV)
Photoionization
Detector (PID)
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 02
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 oxidants such as ozone, can affect readings.
Carbon dioxide (COj) poisons the detractor cell.
H2.10(22,23)
H2.10(24-28)
Source- NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance Manual for Hazardous Waste Site
Activities
2-34
-------
Laboratory analysis of air samples
Anions
Aliphatic amines
Asbestos
Metals
Organics
Nitrosamines
Particulates
PCBs
Pesticides
H2.10(29)
2.11 REFERENCES
H2.11(l)
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.
Show
Pocket Guide.
2-3S
-------
Material Safety OSHA's Hazard Communication Standard requires all Show an S
Data Sheets 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.
Other Sources 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.
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 Dictionai^, 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.
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 H2.12(1)
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 - severe bleeding
Aid or Urgent - breathing has stopped
Care - no pulse
2-38
-------
Complete a Medical Emergency Planning Checklist:
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".
2-39
-------
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.
Tiy again.
Perform Heimlich Maneuver if airway is blocked.
2-40
-------
Check carotid pulse.
Begin rescue breathing.
one breath every five seconds (approximately 1 to
IV2 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.
Cardiopulmonary Chest compressions and rescue breathing used together
Resuscitation (15 compressions/two breaths).
(CPR)
May be needed for:
heart attack (most common)
electrical shock
chemical exposure
CPR should be administered only by personnel specially
trained in the procedure.
Electrical Can stop breathing and heart or cause heart to beat
Shock 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.
Wounds Stop bleeding.
(Severe Protect wounds from contamination.
Bleeding and Prevent shock.
Shock) Get medical help.
2-41
-------
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).
2-42
-------
Splashes of hot, concentrated or corrosive chemicals
(several hours).
Medical followup where indicated.
Irrigate thoroughly (15 minutes).
Contact lenses may aggravate chemical burns.
Do not use neutralizing solutions.
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.
Get exposed person out of toxic atmosphere.
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.
Can be life-threatening depending on location and
amount of body affected.
If burn 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.
2-43
-------
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.
2-44
-------
LESSON PLAN
3.0 PROTECTIVE CLOTHING AND EQUIPMENT
Objective: To provide general information on selecting and using appropriate personal
protective clothing and equipment.
Duration: 0.75 hour
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section n, Chapter 3
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide)-
Section II, Chapter 3
Session outline: 3.1 Objective
3.2 Selection of Personal Protective Clothing and Equipment
3.3 Levels of Protection
3.4 Controlling the Transfer of Contaminants
3.5 Decontamination
3.6 Donning and Doffing Protective Clothing
3.7 Storage of Equipment
Background guidance: Basic Health and Safety Manual for Field Activities
Audiovisual and graphic material:
Slides: H.Ch3 - H3.5(4)
Demonstration materials: hard hat, safety glasses, boots, hearing protection,
gloves, protective clothing
Additional activities:
Personal protective clothing demonstration: an instructor should suit up in a
Level C outfit (see pg. 3-9) to show participants proper donning and doffing of
protective gear.
Demonstration materials should be set out so inspectors can examine them at
their leisure.
3-i
-------
THIS PAGE LEFT BLANK
TJINSI HUMAN 3-ii
-------
CHAPTER 3
3.0 PROTECTIVE CLOTHING AND EQUIPMENT
3.1 OBJECTIVE
H.Ch3
To provide general information on selecting and using
appropriate personal protective clothing and equipment.
3.2 SELECTION OF PERSONAL PROTECTIVE CLOTHING
Proper selection of PPE requires a thorough understanding of H3.2(2,3)
the hazards to be faced:
Chemical - inhalation, skin contact
Mechanical - falling objects, moving parts
Physical - noise, radiation
Thermal - heat, cold
Electrical
AND EQUIPMENT (PPE)
H32(l)
General
Precautions
Use the correct type of equipment needed.
Use only properly fitting personal protective
equipment.
Head Protection
Essential where there are overhead hazards
(platforms, scaffolding, piping)
H3.2(4-7)
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.
Demo: hardhat
Can be equipped with insulation and chin strap.
Store properly.
Eye and Face
Protection
Use whenever there is danger of flying or falling
particles orchemical splashes.
H3.2(8-12)
Use eye and face protection which meets ANSI Z87.1-
1981 standards and OSHA requirements.
1-1
-------
Foot Protection
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:
Demo: safety
glasses
Impact
Penetration
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 H32(t3)
reinforced soles.
Chemicals
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.
Ankle Twists and
Sprains
Do not wear leather footwear where contamination
may occur.
Wear high-top industrial work boots where there are
hazardous walking/working surfaces.
H3.2(14,15)
¦X-l
-------
Slippery Surfaces
Static Electricity
Slips, trips and falls are most frequent and most 1132(16-19)
disabling.
Select footwear with hazard in mind - design and
material of sole is important.
Rubber-soled shoes increase the hazard. Demo: boots
Use special conducting shoes or other static diffusing
devices.
Hearing
Protection
Long-term exposure can cause permanent loss of H3J(20-24)
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 Review Table 3-1.
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.
Demo: hearing
protection
H A M U£ R
SEMICIRCULAR
CANALS
EIGHTH NERVE
E AR DHUU
OVAL WINOO*
223
FLUlO
eustachian
luoe
KOUKO
inNOO* CORTI
COCHLEA
External Ear Middle Inner
Ear Ear
Figure 3-1. The ear
-------
TABLE 3-1. TYPICAL NOISE REDUCTION RATINGS (NRRs) FOR COMMON
HEARING PROTECTION DEVICES
T^pe 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
H32 (25-291
Show glove
selection guide
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.
Skin and Body
Protection
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.
Select clothing for resistance to chemical degradation
and permeation, and heat resistance.
Review Table 3-2.
Demo: gloves
3-4
-------
TABLE 3-2. PHYSICAL CHARACTERISTICS OF PROTECTIVE MATERIALS*
atenal
Abrasion
Resistance
Cut
Resistance
Flexibility
Heat
Resistance
Ozone
Resistance
Puncture
Resistance
Tear
Resistance
Relative
Cost
'tyl Rubber (Butyl)
F
G
G
E
E
G
G
High
ilonnaied Polyethylene (CPE)
E
G
G
G
E
G
G
Low
aural Rubber
E
E
E
F
P
E
E
Medium
inle-Butadiene Rubber (NBR)
E
E
E
G
F
E
G
Medium
:oprene
E
E
G
G
E
G
G
Medium
inle Rubber (Nurile)
E
E
E
G
F
E
G
Medium
inle Rubber & Polyvinyl
Ihlonde (Nitrilc & PVC)
G
G
G
F
E
G
G
Medium
lyethylene
F
F
G
F
F
P
F
Low
¦lyurethane
E
G
E
G
G
G
G
High
lyvinyl Alcohol (PVA)
F
F
P
G
E
F
G
Very High
lyvmyl Chloride (PVC)
G
P
F
P
E
G
G
Low
Tene-Butadiene Rubber (SBR)
E
G
G
G
F
F
F
Low
on
G
G
G
G
E
G
G
Very High
Ratings are subject to variation depending on formulation, thickness, and whether the material is supported by fabric,
excellent; G-good, F-fair; P-poor
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 HS3(l)
Review Appoidices
3-A & 3-B.
Show types of
protedhcdothing.
Considerations
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).
Type, measured concentration, and toxicity of the
chemical substance in the ambient atmosphere.
Potential for exposure to airborne materials, liquid
splashes, or other materials.
Reasons for
Upgrading
Reasons for
Downgrading
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 H34(l)
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.
-------
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 chcmical-rcsistant gloves
Chemical-resistant safety
boots/shoes
Two-way radio communication?
(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
Fully-encapsulating suit material
must be compatible with the
substance involved
Direct reading field instruments
indicate high levels of unidentified
vapors and gases in the air
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-picce 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
3-8
-------
TABLE 3-3 (CONTINUED)
Level of Protection
Equipment
Protection Provided
Should De Used When
Limiting Criteria
RECOMMENDED
Full-facepiece, air-punrying,
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)
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
Atmospheric concentration of
chemicals must not exceed
IDLH levels
The atmosphere must contain at
least 19.S percent oxygen
Inner and outer chemical-resistant
gloves
Chemical-resistant safety
boots/shoes
Hard hat
Two-way radio communications
(intrinsically safe)
OPTIONAL
All criteria for the use of air-
punfying respirators are met
Coveralls
Disposable boot covers
Face shield
Escape mask
Long cotton underwear
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-
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
Gloves
Escape mask
Face shield
dapted from- NIOSH/OSHA/USCG/EPA Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, 1985.
3-10
-------
Planning Disposable equipment
Onsite decontamination
Method of decontamination
Disposal
Appropriate supplies
j
Preventing Transfer Minimize surfaces touched,
of Contaminants Avoid walking on or through chemical spills.
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 H3.5(l-4)
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 Safely 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.
3-11
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3.6 DONNING AND DOFFING PROTECTIVE CLOTHING
Demo: sr
Achieving the complete benefits of protective clothing up in prou>.. <
depends on the techniques used for donning and doffing clothing,
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 ReviewAppendix
procedures. 3-C.
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.
3-12
-------
APPENDIX 3-A
PERFORMANCE REQUIREMENTS OF PROTECTIVE CLOTHING
Clothing Section 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.
Resistance to A great deal of information concerning the chemical
Degradation by resistance of materials from which protective gloves and
Chemicals clothing are made can be obtained.
Resistance to Select personal protective clothing with care;
Penetration by porous materials, tears, punctures, stitched seams,
Chemicals 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.
3-13
-------
Gases, liquids and some solids can diffuse through
materials used to make protective gloves and
clothing.
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.
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
3-15
-------
butyl rubber; does not protect against some
chemicals like ketones and aldehydes; does not
retain contaminants; fully-encapsulating suits.
Natural rubber: resists degradation by alcohols
and caustics; used for boots and gloves.
Milled nitrile: 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.
3-16
-------
APPENDIX 3-C
PROCEDURES FOR DONNING AND DOFFING PERSONAL
PROTECTIVE CLOTHING
Using Gloves Gloves'
Removing Gloves
Using Boots
Boots
Removing Boots
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.
3-17
-------
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).
Donning the Suit 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.
Doffing the Suit 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.
Using and
Removing Full Body
Suits
3-18
-------
While sitting, remove both legs from the suit.
After suit is removed, remove internal gloves by
rolling ihem off the hand, and turning them inside
oul.
Proceed to the clean area and follow procedure
for doffing SCBA.
Remove internal clothing and thoroughly cleanse
body.
3-19
-------
LESSON PLAN
4.0 RESPIRATORY PROTECTION
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.
Duration: 0.75 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section II, Chapter 4
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide)-
Section II, Chapter 4
Session outline: 4.1 Objective
4.2 Recognition of Respiratory Hazards
4.3 Types of Respirators
4.4 Respirator Selection
4.5 Respirator Use
4.6 Special Considerations
4.7 Respirator Fit Testing
Background guidance: Basic Health and Safety Manual for Field Activities
Audiovisual and graphic material:
Slides: H.Ch4 - H4.7(l)
Videotape: Respiratory Protection
Demonstration materials: respirators, fit test apparatus, cleaning materials
Additional activities:
Set out a variety of respirators, filter cartridges, fit test apparatus, and respirator
cleaning materials for attendees to examine.
4-i
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THIS PAGE LEFT BLANK
T31NSTRU MAN 4"ij
-------
CHAPTER 4
4.0 RESPIRATORY PROTECTION
H.Ch4
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
Hazard Locations
General
Considerations
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.
Spill scenes
Discharge or emission sites
Mines
Industrial plants
Hazardous waste sites
Confined spaces
Do not rely on workaday respiratory use policy.
Assume the worst conditions.
Three basic categories of hazards
H4.2(1.3)
oxygen deficiency
aerosols
gases and vapors
Oxygen Deficiency
Causes
displacement
oxidation
4-1
-------
Minor to fatal effects (see Table 4-1) ReviewTal
< 19.5% oxygen at sea level (OSHA)
Aerosols Fine particulate (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
4-2
-------
TABLE 4-1. PHYSIOLOGICAL EFFECTS OF OXYGEN DEFICIENCY
Oxygen Volume at Sea Level (%)
Effects
12 to 16
10 to 14
6 to 10
-Breathing volume and heart rate increase.
-Attention and coordination impaired.
-Loss of peripheral vision.
-Poor coordination.
-Rapid fatigue with exertion.
-Emotional upsets and faulty judgment.
-Respiration disturbed.
-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.
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%;
H43(l)
Show respirators.
Briefly discuss
rest ot chapter.
Show video.
4-4
-------
contaminant has adequate warning
properties;
approved canisters or cartridges for the
contaminant and concentration are
available;
the Immediately Dangerous to Life or
Health (IDLH) concentration is not
exceeded.
Styles
Atmosphere
Supplying
Respirators
SCBA
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
Review Tables
4-2 & 4-3.
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 Review Table 4-4.
SCBAs.
SAR 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.
4-5
-------
TABLE 4-2. RELATIVE ADVANTAGES AND DISADVANTAGES OF AIR-
PURIFYING RESPIRATORS
Type of Respirator
Advantages
Disadvantages
Air-Purifying
Air-Punfying Respirator -
(including powered air-
puriiying 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-scrvicc-bfc indicator)
Source. NIOSH/OSHA/USCG/EPA: Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities, 1985.
TABLE 4-3. RESPIRATOR STYLES
Facepiece
Air-PuriF
fing Unit
Twin
Cartridges
PAPR at Waist
Chin-mounted
Canister
Harness-
mounted
Canister
Half-mask
X
X
Full-face mask
X
X
X
X
Helmet
X
4-6
-------
TABLE 4-4. RELATIVE ADVANTAGES AND DISADVANTAGES OF
ATMOSPHERE-SUPPLYING RESPIRATORY PROTECTIVE
EQUIPMENT
Advantages Disadvantages
Type of Respirator
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
MSHA/NTOSH 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.
Impairs mobility
Source: NIOSH/OSHA/USCG/EPA- Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities, 1985
4-7
-------
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% 02).
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
4-8
-------
Example - Air-purifying, half-mask respirator:
APF = 10.
Contaminant: TLV = 20 ppm
Maximum Concentration = APF x TLV
x = 10 x 20
x = 200 ppm
See Table 4-5 for assigned protection factors. Review Table 4-5.
4.4 RESPIRATOR SELECTION H4.4(i)
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.
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
General
Considerations
Nature of hazardous operation, process or
condition
Contaminant
Considerations
Physical, chemical, toxicological properties
Odor threshold
REL, TLV, PEL
IDLH concentration
Eye irritation potential
Respiratory
Hazards
Oxygen deficiency
Flammable atmosphere
Toxic atmospheres
Oxygen Deficiency
SCBA/pressure-demand
SAR/auxiliary SCBA
Flammable
Atmospheres
General Policy: do not enter if >25 % of LEL.
SCBA/pressure-demand
Toxic Atmospheres
IDLH - SCBA/pressure-demand
Above PELs but below IDLH - APR or SAR
Below PEL - none required
4-9
-------
TABLE 4-5. RESPIRATOR PROTECTION FACTORS
Assigned
Protection
Factor
Type of
Respirator
Contaminant
Particulate
Gas/Vapor
Combination
10
APR/half-
mask
X
X
X
APR/full-face
X (any type)
X (any type
particulate
filter)
SAR/half-
mask/negative
X
X
25
PAPR/hood or
helmet
X
X
X
SAR/hood or
helmet/
continuous
flow
X
X
50
APR/full-face
X (HEPA)
X
X (HEPA)
PAPR/tight-
fitting
X (HEPA)
X
X (HEPA)
SAR/full-face/
negative
X
X
X
SAR/tight-
fitting/
continuous
flow
X
X
SCBA/full-
face/negative
X
X
X
1000
SAR/half-
mask/positive
X
X
X
2000
SAR/full-
face/ positive
X
X
X
10,000
SCBA/full-
face/
positive
X
X
X
SCBA/full-
face/
positive/
auxiliary
positive
X
X
X
4-10
-------
4.5 RESPIRATOR USE
H4.5(l)
Respirator Policy 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.
Respirator Program Written program (SOPs)
Requirements Respirator selection
Training
Respirator assignment
Cleaning
Storage
Inspection and maintenance
Surveillance
Program evaluation
Physical examination
4-11
-------
4.6 SPECIAL CONSIDERATIONS
Facial hair
Eye glasses
Contact lenses
Facial deformities
Communication
4.7 RESPIRATOR FIT TESTING H4.7(i)
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.
Fit Checks Negative Pressure Test - tests exhalation valve and
facepiece seals.
Positive Pressure Test - tests inhalation valves and
facepiece seals.
Qualitative Fit Determine sensitivity to challenge material:
Testing
banana oil (isoamyl acetate)
saccharin
irritant smoke (stannic chloride)
Select respirator.
Conduct positive/negative fit check.
Enter test chamber.
Introduce challenge material.
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.
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
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.
4-14
-------
-------
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 4-5
4.6 Interviews 4-14
4.7 Observations and Illustrations 4-16
4.8 Exit Interview ; 4-17
4.9 Exit Observations/Activities 4-18
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
fundinst cng
i
-------
LESSON PLAN
1.0 INTRODUCTION TO ENVIRONMENTAL COMPLIANCE
Objective: To provide information concerning the purpose of inspections, factors
which motivate regulated industries to comply with environmental
requirements, and the role of enforcement in achieving compliance.
Duration: 0.25 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section III, Chapter 1
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide)-
Section III, Chapter 1
Session outline: 1.1 Course Objectives
1.2 Compliance Monitoring
1.3 Motivation for Compliance
1.4 The Inspector's Role
Background guidance: Fundamentals of Environmental Compliance Inspections
Audiovisual and graphic material:
Slides: F.intro - F1.2(l)
Additional activities: None
fundiast cng
1-i
-------
THIS PAGE LEFT BLANK
T3INSTKU MAN 1-H
-------
CHAPTER 1
F. intro
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 F.12(1)
Purpose of To ensure that environmental requirements are being implemented
Inspections 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.
fundmsl cng
1-1
-------
1.3 MOTIVATION FOR COMPLIANCE
Motivating
Factors
Natural
Disincentives
Role of
Enforcement
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
Credible
Enforcement
Presence
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.
fundinst cng
1-2
-------
LESSON PLAN
2.0 INSPECTION PLANNING AND PREPARATION
Objective: To stress the importance of planning and advance preparation and to present
information on key planning activities.
Duration: 0.25 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section III, Chapter 2
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide) -
Section III, Chapter 2
Session outline: 2.1 Responsibilities of the Inspection Team
2.2 Reviewing Available Information
2.3 Preparing the Inspection Plan
2.4 Preinspection Checklist
Background guidance: Fundamentals of Environmental Compliance Inspections
Audiovisual and graphic material:
Slides: F.Ch2 - F2.3(l)
Additional activities: None
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CHAPTER 2
F.Ch2
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.
2.2 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.
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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: F23(i)
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.
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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
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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 H20)
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
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LESSON PLAN
3.0 ENTRY AND OPENING CONFERENCE
Objective: To provide information on entry procedures which have proven successful in
enforcement of environmental regulations.
Duration: 1.00 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section in, Chapter 3
Training Course for Multi-Media Inspectors (.Audiovisual Presentation Guide) -
Section III, Chapter 3
Session outline: 3.1 Key Elements of Entry
3.2 Approaching the Facility
3.3 Entry Procedures
3.4 Opening Conference
3.5 Amending the Inspection Plan
Background guidance: Fundamentals of Environmental Compliance Inspections
Audiovisual and graphic material:
Slides: F.Ch3 - F3.4(l)
Additional activities: None
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CHAPTER 3
3.0 ENTRY AND OPENING CONFERENCE
F.Ch3
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: F32(i-13)
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
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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 F33(i)
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 F3.4(l)
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.
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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.
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LESSON PLAN
4.0 INFORMATION GATHERING AND DOCUMENTATION
Objective: To provide information on the types of evidence and how to collect and document
information gathered during a compliance inspection.
Duration: 1.50 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section III, Chapter 4
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide) -
Section III, Chapter 4
Session outline: 4.1 Types of Information and Documentation
4.2 Documenting Information
4.3 Techniques for Improving Information Gathering Skills
4.4 Records Inspection
4.5 Physical Sampling
4.6 Interviews
4.7 Observations and Illustrations
4.8 Exit Interview
4.9 Exit Observations/Activities
Background guidance: Fundamentals of Environmental Compliance Inspections
Audiovisual and graphic material:
Slides: F4.1(l) - F4.7(6)
Demonstration materials: Chain-of-custody forms
Sample containers and labels
Air monitoring equipment
Additional activities:
Set out a variety of sampling tools, sample containers, labels, and air monitoring equipment
for attendees to examine.
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CHAPTER 4
4.0 INFORMATION GATHERING AND DOCUMENTATION
4.1 TYPES OF INFORMATION AND DOCUMENTATION F4.i(i)
"types of There are four types of information and documentation:
Information
Testimonial (what you are told)
Real (physical samples you gather) F4.i(2)
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: F4J>(1)
Provides the foundation for preparing reports. F42(2)
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.
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43 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.
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4.4 RECORDS INSPECTION
F4.4(l)
The two objectives of inspecting facility records are to: F4.4(2r3)
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 examine, he or she should:
Records
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.
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Check back-up and cross-filing systems that might make
retrieval more efficient.
Records Time constraints often prevent inspectors from examining all records
Sampling 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.
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4.5 PHYSICAL SAMPLING
Why Take Physical samples are taken during a compliance inspection to
Physical substantiate that a violation occurred. Samples provide quantitative
Samples 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.
F4.5(l)
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
What
Information
Can Be Used
for Planning?
Identify and characterize broader site conditions to support
sampling data.
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
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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 F4.5(2)
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.
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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 F4.5(3,4)
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 F4.S(5)
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
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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 - sa'mples 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.
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Plan The Arrangements for travel and secure shipment of samples should be
Logistics 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 document to identify sites where samples are to be taken. In
Points 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.
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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 If you are using monitoring instruments, you will need to check their F4.5(6-9)
Monitoring operation and calibrate them at the beginning of each day. Follow
Equipment the manufacturer's instructions regarding recalibration and use of
quality control check standards.
Record all instrument readings in your log book along with date, F4.5(i0,ii)
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 or monitoring readings (when appropriate) should be F4.5(12-14)
Samples 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.
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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.
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Labels
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.
Sealing Samples should be sealed with a protective band of tape that F4.5(i5)
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.
Chain of Once the shipping container containing the samples is full, and the
Custody shipping temperature of the samples can be confirmed at 4 degrees
C., the 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.
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Confirm
Condition of
Samples on
Arrival
Evaluating the
Data
Laboratory and
Field Quality
Control Data
It is the inspector's responsibility to confirm that the samples arrived
safely and that all samples were intact and that refrigeration was
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.
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.
Quality ¦ Examine the results of field blank analysis and confirm that
Assurance 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.
Maintaining Original copies of laboratory reports, chain of custody documents,
Records 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.
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4.6 INTERVIEWS
Planning the
Interview
As the first step in the interviewing process, planning the interview
should involve:
Conducting
and
Documenting
the Interview
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.
Questioning
Techniques
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?
F4.6(l)
-------
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.
Collecting When taking written statements, an inspector should:
Written
Statements 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.
-------
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.
-------
Tips on Taking Maintain fresh film and batteries. F4.7(i)
Photos
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.
Document photos by noting in logbook the frame number F4.7(2)
along with a detailed description of the subject matter.
Take a picture of your business card as the first photograph F4.7(3)
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 F4.7<4)
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. F4.7(5)
Drawings and Maps showing location of facility and plot plans showing activities F4.7(6)
Illustrations 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:
-------
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.
-------
LESSON PLAN
5.0 POST-INSPECTION ACTIVITIES
Objective: To make compliance inspectors aware of the importance of, and how to write, a
good inspectipn report.
Duration: 0.25 hours
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section HI, Chapter 5
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide)
Section III, Chapter 5
Session outline: 5.1 The Inspection Report
Background guidance: Fundamentals of Environmental Compliance Inspections
Audiovisual and graphic material: F5.1(l)
Additional activities: None
fundinsl cng
5-i
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TJ1NSTRU MAN 5-U
-------
CHAPTER 5
5.0 POST-INSPECTION ACTIVITIES
5.1 THE INSPECTION REPORT
FS.l(l)
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 vary, each one should provide enough information to tell the reader:
Report
Writing an
Effective
Inspection
Report
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.
When writing an inspection report, it is important to relate the facts
and evidence relating to the inspection simply and with the reader
in mind. A good inspection report exhibits:
Fairness;
Accuracy;
Conciseness;
Clarity;
Completeness;
fundinst cng
5-1
-------
The source of evidence;
Exhibits (supplementary material);
Organization; and
Good writing.
Narrative Narrative reports, as part of an overall inspection report, should be
Report 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.
lurulinst cng
5-2
-------
-------
AIR POLLUTION/HAZARDOUS WASTE
B.intro.
INSPECTIONS
-------
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-------
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) 1-18
1.11 Cyclones/Multi-cyclone collectors 1-21
1.12 Wet scrubbers 1-24
1.13 Carbon bed adsorbers 1-31
1.14 Incinerators 1-33
1.15 Condensers 1-35
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 2-5
2.6 General inspection procedures 2-6
2.7 Inspection checklists 2-7
2.8 Waste sampling ; 2-7
2.9 Documentation 2-9
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 1-15
1-4 Pulse-cleaning 1-16
1-5 ESP collection schematic 1-19
1-6 Electrostatic precipitator 1-19
i
-------
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 1-27
1-11 Countercurrent packed tower 1-28
1-12 Conventional venturi scrubber 1-29
1-13 Activated carbon adsorber 1-32
1-14 Direct-fired incinerator 1-34
1-15 Catalytic incinerator 1-34
1-16 Contact condenser 1-36
1-17 Surface condenser 1-37
Appendices
Appendix Page
1-A Safety Guidelines 1-39
1-B Recommended List of Inspection Equipment 1-41
1-C Baseline Air Pollution Quiz 1-43
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
ii
-------
LESSON PLAN
1.0 BASELINE INSPECTION TECHNIQUES FOR AIR POLLUTION
SOURCES
Objective: To provide information and techniques to support inspection personnel in
conducting field inspections which are necessary to promote compliance.
Duration: 3.25
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section IV, Chapter 1
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide) -
Section IV, Chapter 1
Session outline: 1.1 Objective
1.2 Introduction
1.3 Principles of the Baseline Method
1.4 Levels of Inspection
1.5 Level II Source Inspections
1.6 Components of the Control System
1.7 Ancillary Components
1.8 Classification of Air Pollution Control Devices
1.9 Fabric Filters
1.10 Electrostatic Precipitators (ESPs)
1.11 Cyclones/Multi-cyclone Collectors
1.12 Wet Scrubbers
1.13 Carbon Bed Adsorbers
1.14 Incinerators
1.15 Condensers
Background guidance: Baseline Air Inspection Techniques for Air Pollution Sources, Level
II Inspection Manual for Air Pollution Stationary Sources, Air
Compliance Inspection Manual, and Inspection Protocol and Model
Reporting Requirements for Stationary Sources
Audiovisual and graphic material:
Slides: Bl(a) - B1.15(2)
Additional activities: Have easel or blackboard available to make drawings of control
equipment, flow charts, etc.
Quiz
1-i
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TJINSTRUJUAN 1-ii
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CHAPTER 1
1.0 BASELINE INSPECTION TECHNIQUES FOR bi
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 Bl3
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
1-1
-------
on other similar sources. This is important, because
substantial differences in performance and vulnerability to
problems have 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
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1.4 LEVELS OF INSPECTION
B1.4(l)
Introduction
Level I
inspections
Level II
inspections
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.
The Level I inspection is a field surveillance tool intended to B1.4(2)
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.
The Level II inspection is a limited "walk through" evaluation Bl.4(3)
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
-------
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.
Level III The more detailed and complete Level III inspection may be
inspections 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:
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 Bi.4(4)
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.
Level IV The Level IV inspection, identical in scope to the Level III Bi.4(5)
inspections 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 B15(1)
Introduction 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.
General The scope of the Level II inspection should be limited to
information 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
-------
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.
Safety Nothing should be done which jeopardizes the health and Bi.5(2)
considerations 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.
Limitations 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 Bi.6(l)
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 Bi.6(2)
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.
8
O)
JS
a.
V»
o
E
Operating
controls
Hoods
Monitor
Dampers
Control device
Transport
Hoods
Air mover
Contaminant
removal
Figure 1-1. Typical air pollution control system
1-7
-------
1.7 ANCILLARY COMPONENTS
Containment
capture
Level II
inspection points
Transport
The objective of this system component is to effectively capture Bi.7(i)
(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 Bi.7(2)
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.
Level II
inspection points
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 The purpose of the fan is to move the gas stream through the Bi.7(3)
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.
Level II Physical condition: indications of corrosion.
inspection points
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.
Instrumentation Operating controls are important to the function of the air Bi.7(4)
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.
Level II Physical condition: indications of excessive wear, obvious
inspection points signs of failure or disconnected controls.
1-9
-------
Set-point values: changes in set-point values for
temperature, pH, rapping intensity, air pressure and other
controllers may affect system performance.
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.
Other There can be many other components in an air pollution Bi.7(5)
components 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.
Level II Solids handling:
inspection points
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.
1-10
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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.
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 81.8(1)
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 Bi.8(2)
Settling chamber
Fabric filter
Electrostatic precipitator
Cyclone
Gases only Bi.8(3)
Wet collector
Adsorber
Incinerator
1-11
-------
Vapors only
Condenser
Incinerator
Particles, gases and vapors
Wet collector
Incinerator
1.9 FABRIC FILTERS Bi.9(l)
General Fabric filters remove particles by passing the contaminated gas
information 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 Bi.9(2)
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.
1-12
-------
Clean air
outlet
Dirty air ^JTrT-.
inlet
Collection hopper
Clean air
side
Filter bags
Cell plate
Figure 1-2. Shaker-cleaning fabric filter
1-13
-------
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.
B1.9(3)
Pulse-cleaning
Figure 1-4 shows a typical pulse-cleaning collector. Cylindrical Bl.9(4)
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.
Level II
inspections
B1.9(5)
Inspection
activities
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.
1-14
-------
Figure 1-3. An example of a large reverse-air fabric filter
(Courtesy of MikroPul Corporation).
1-15
-------
:n
/A
nnnnmn
mmmnTr
^7
Figure 1-4. Pulse-cleaning fabric filter
1-16
-------
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.
Obse'rve and describe corrosion of baghouse shell and
hoppers.
Evaluate bag failure records, gas inlet temperature records,
pressure drop data, and other maintenance information.
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 III
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.
1-17
-------
1.10 ELECTROSTATIC PRECIPITATOR'S (ESPs)
B1.10(l)
General Electrostatic precipitators remove particles from a
information ' 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 BU0(2)
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.
The electric field is powered by direct currents supplied from B1.10(3)
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).
1-18
-------
Discharge
electrode (-)
Charging field
Charged
particles (-)
Collecting
baffle
Grounded ( + )
collecting surface
Discharge
electrode
tension weight
Figure 1-5. ESP collection schematic
Rappers
Transformer-rectifier (T-R)
Collection
electrode
Discharge electrode
Figure 1-6. Electrostatic precipitator
1-19
-------
Level II
inspections
B1.10(4)
Inspection
activities
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.
Performance
evaluation
Process operating data.
Transmissometer strip chart records and electrical set
records.
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.
1-20
-------
Safety Inspectors should be trained in safety procedures prior to
considerations 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 BUi(i)
General In a cyclone, the dirty gas stream is directed into a cylindrical
information 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
Single cyclones Cyclones can be constructed in either single or multiple Bl.li(2)
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 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 Multi-cyclones have numerous small diameter (typically 15-23 Bl.ll(3)
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 nm 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.
1-21
-------
High efficiency High throughput
Figure 1-7. Single cyclone collectors
Figure 1-8. Multi-cyclone
1-22
-------
Method 9 observation of the stack for a sufficient period to bi.ii(4)
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.
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.
1-23
-------
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 Bi.l2(i)
General Wet collectors remove contaminants from a gas stream by
information transferring them to some type of scrubbing liquid. For
particles larger than about 1 Mm, 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.
Wet collectors 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.
Spray tower A simple spray tower is illustrated in Figure 1-9. The dirty gas Bi.l2(2)
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
1-24
-------
Clean gas
Water
sprays
Figure 1-9. Simple spray chamber
1-25
-------
can be effective gas absorbers if the contaminant has a
moderate affinity for the liquid.
Tray scrubber A tray scrubber (see Figure 1-10) can also be used for both Bi.i2(3)
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 nm and can be an effective gas
absorber when the contaminant has a moderately low affinity
for the liquid.
Packed tower Packed towers are used primarily for gas absorption because of bi.12(4)
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.
Venturi scrubber A conventional venturi scrubber is shown in Figure 1-12. The Bl.l2(5)
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.
1-26
-------
Clean gas
Plates
Detail of plate
Figure 1-10. Tray scrubber
1-27
-------
Clean gas
an
.w:-7»y r >.t*
' i\\' *v.. r;
Mist eliminator
Water sprays
Packing
j^l^pirty gas
ure 1-11. Countercurrent packed tower
1-28
-------
Dirty gas
Clean gas
Cyclonic separator
Water sprays'
Figure 1-12. Conventional venturl scrubber
1-29
-------
Level II
inspections
Inspection
activities
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.
B1.12(6)
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.
Performance
evaluation
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.
1-30
-------
Safety All ladders and platforms should be checked before use.
considerations 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.
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 Bl.l3(l)
General Adsorbers remove gaseous contaminants from an air stream by
information 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. B1.13(2)
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.
1-31
-------
Adsorbers on stream
Adsorber
Regenerating
rSolvent Ladei
Air
Condenser
Clean air
exhaust
Stream
Solvent
Figure 1-13. Activated carbon adsorber
1-32
-------
Level II
inspections
Physical
condition
Adsorption/de-
sorption cycle
times
Steam pressure/
temperature
during desorption
B1.13(3)
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.
1.14 INCINERATORS Bl.l4(l)
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 B1.14(2)
chambers with a gas or oil burning apparatus plainly
visible (see Figure 1-14).
Cataytic units, which have the appearance of a duct Bl.i4(3)
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 (1300°F); most systems operate in the
816-982°C (1500-1800°F) range. Catalytic units are generally
designed for a bed inlet temperature of 371-482°C (700-900°F).
1-33
-------
Refractory lined
steel shell
Burner ports
Refractory ring baffle
Inlet for contaminated
; airstream
Gas burner
piping
Burner
block
Figure 1-14. Direct-fired Incinerator
Heat exchanger tubes
Catalyst
Figure 1-15. Catalytic Incinerator
1-34
-------
Level II
inspections
Physical
condition
Outlet
temperature
Temperature rise
B1.14(4)
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 Bi.i5(l)
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:
Contact or barometric condensers, where a direct spray Bl.l5(2)
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 B1.15(3)
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.
1-35
-------
Level II
inspections
Physical
condition
81.15(4)
Indications of corrosion or physical damage.
Outlet
temperature
Liquid turbidity/
settling rate
Droplet re-
entrainment
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.
Mist eliminator
Figure 1-16. Contact condenser
1-36
-------
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THIS PAGE LEFT BLANK
1-38
-------
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.
1-39
-------
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.
15. 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.
1-40
-------
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)
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
Self-contained breathing
apparatus
1-41
-------
Checklists
Notebook
Notice of inspection (if
applicable)
Chain of custody
Field data sheets
1-42
APPENDIX 1-B. (Continued)
PAPERWORK
Proper identification
Copy of facility's inspection file,
permit, and monitoring schedule,
including:
- maps
- photographs
- enforcement actions
-------
APPENDIX 1-C. BASELINE AIR POLLUTION QUIZ
1. True or false? The Baseline Inspection Technique involves detailed internal 1. __F_
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. b
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. _d_
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. _c_
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. _T
contribute to excess emissions and/or bag failure rates.
7. In an ESP, are used to control the strength of the electric field 7. __b_
generated between the discharge and collection electrodes.
a. rappers
b. transformers-rectifier sets
c. capacitors
d. adsorbers
1-43
-------
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. NOt and SOx
b. H202 and C02
c. NO, and H20
d. COj and H20
1-44
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LESSON PLAN
2.0 HAZARDOUS MATERIALS/HAZARDOUS WASTE INSPECTION
PROCEDURES
Objective: To provide information and techniques to support inspection personnel in
conducting field inspections which are necessary to promote compliance.
Duration: 1.00 hr.
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section IV, Chapter 2
Training Course for Multi-Media Inspectors (.Audiovisual Presentation Guide) -
Section IV, Chapter 2
Session outline: 2.1 Introduction
2.2 Inspection Preparation
2.3 Health and Safety Requirements
2.4 Inspection Equipment
2.5 Operations, Waste Handling, and Record Review
2.6 General Inspection Procedures
2.7 Inspection Checklists
2.8 Waste Sampling
2.9 Documentation
2.10 Field Notebook
Background guidance: RCRA Field Inspection Guidance Manual
Audiovisual and graphic material:
Slides: B2.1(l)
Additional activities: Have easel or blackboard available to make drawings of control
equipment, flow charts, etc.
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TMNSTRU MAN
2-ii
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CHAPTER 2
2.0 HAZARDOUS MATERIALS/HAZARDOUS WASTE
INSPECTION PROCEDURES
2.1 INTRODUCTION B2.l(i)
Purpose 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.
Inspector Inspectors should be aware of all Federal, State, local, and
responsibilities 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
2-1
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result, inspectors will develop specialized skills in inspecting
that type of facility or practice 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.
2.2 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.
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Determine health and safety requirements and
equipment needs.
Activities the inspector should undertake to achieve these
objectives are discussed in the following sections.
2.3 HEALTH AND SAFETY REQUIREMENTS
Planning the Although routine inspections generally do not involve activities
inspection 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.
Special In some cases, the inspector will have limited information on
considerations 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.
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2.4 INSPECTION EQUIPMENT
Select 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.
Ensure proper The inspector should identify and obtain the equipment
functioning 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.
Consider Special circumstances may require the use of additional
additional equipment such as fireproof clothing or self-contained
equipment 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.
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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, the inspector should be
familiar with the facility through previous review of the facility's
file. Therefore, the 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.
Record review 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.
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2.6 GENERAL INSPECTION PROCEDURES
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 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:
Maintain control 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.
Remain oriented 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.
Follow
inspection
plan/strategy
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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.
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
Sampling is generally conducted to verify the identity of a waste
or to identify potential releases of hazardous wastes or
constituents to the environment.
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.
-site activities 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
2-7
Reasons for
sampling
Inspection
planning
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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.
Reasons for There are many possible conditions or activities which may lead
future sampling 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.
(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.)
Whenever such condition/activities are encountered, the
inspector should identify the media or wastes to be sampled,
the physical 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.
Useful
information for
future
inspections
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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 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.
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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
- AJconox
- brushes
- grate
- deionized water
- solvents for equipment
cleaning
- steam cleaning machine
- plastic bags
2-11
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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
3. Street
2. Telephone Number
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
3. Title
2. Organization
4. Telephone No.
J.
Inspection Participants
1.
6.
2.
7.
3.
8.
4.
9.
5.
10.
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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
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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
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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
I. 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
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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?
OR
Yes No
e. protection from precipitation and
run-on by some other means? Yes No
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APPENDIX 2-E (Cont.)
D. MONITORING AND INSPECTION
1. Are liners and covers inspected for damage during
construction? Yes
2. Are waste piles inspected weekly for deterioration,
run-on and runoff controls, wind dispersal control, and
proper function of leachate collection system? Yes
E. IGNITABLE OR REACTIVE WASTES
1. Are ignitable or reactive wastes placed in the pile? Yes
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
. Is there evidence of fire, explosion, gaseous emissions,
leaching, or other discharge? (Use narrative explanation
sheet.) Yes No
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INTRODUCTION TO
POLLUTION PREVENTION
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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 1-9
1.4 Selected Pollution Prevention Case Studies 1-10
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ii
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LESSON PLAN
INTRODUCTION TO POLLUTION PREVENTION
Objective: To introduce inspectors to the basic concept of pollution prevention (P2). To
provide them with potential methods and procedures to implement P2, and to
show what selected industries have done in the area of P2.
Duration: 1.00 hr.
References: Training Course for Multi-Media Inspectors (Student Manual) -
Section V
Training Course for Multi-Media Inspectors (Audiovisual Presentation Guide)-
Section V
Session outline:
1.0 Introduction to Pollution Prevention
1.1 Waste Management Hierarchy
1.2 Source Control Methods
1.3 Implementation of Pollution Prevention Techniques
1.4 Selected Pollution Prevention Case Studies
Background guidance: Introduction to Pollution Prevention
Audiovisual and graphic material:
Slides: P2(l) - P2(26)
Additional activities:
No classroom activities. Facility visit(s) should include as many
pollution prevention issues as is available.
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CHAPTER 1
1.0 INTRODUCTION TO POLLUTION PREVENTION
Pollution Prevention is generally defined as any in-plant process that P2(i)
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 P2(2)
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 P2(3)
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.
1-1
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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:
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.
Recycling 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).
Treatment 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).
Disposal 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
Source
Reduction
1-2
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best way to reduce or control pollution considering their potential
environmental and economic advantages which include:
P2(4)
Energy and resources conservation;
Raw material losses reduction;
Treatment and disposal cost reductions;
Reduction of long-term liabilities associated with
environmental waste or cleanup;
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: P2(5)
1. Process Changes
2. Material Substitution
3. Material Inventory and Storage
4. Waste segregation
5. Good housekeeping/Preventive Maintenance/Employee
Education
6. Product changes
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7. Water and energy conservation
8. Recycling/waste exchange
Process Process changes consist of changing one or more processes used by P2(6)
Changes 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. 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 P2(7)
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 P2(8)
Substitution pollutant 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.
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P2(9)
Material Proper material inventory and storage refers to the purchasing, P2(i0)
Inventoiy and tracking, storage, and handling of hazardous materials. There are
Storage two facets of material inventory and storage:
Using good inventory and tracking procedures of hazardous P2(ii)
materials help minimize overstocking and contamination and
reduces the need to dispose of expired or contaminated
materials. 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 P2(i2)
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 of different types of wastes can be a simple and
Segregation 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: P2(i3)
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.
P2(14)
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Good These procedures are generally simple and inexpensive to
Housekeeping/ implement and effectively reduce pollution at its' sources.
Preventive
Maintenance/
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.
P2(15)
Preventive
Maintenance
Employee
Education
Providing funnels and other transfer equipment to reduce loss
of material during transfer.
Preventive maintenance reduces malfunctions and leaks and can also
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 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.
P2(16)
P2(17)
P2(18)
P2(19)
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Ensuring that all employees know and practice proper and
efficient use of tools and supplies. This is especially
important for cleaning operations.
Product Product changes that are considered pollution prevention techniques
Changes 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 P2(20)
assessment include:
Inventory analysisIdentification and quantifying of energy
and resource use and waste emissions;
Impact AnalysisAssessment of the consequences those
wastes have on the environment; and
Improvement AnalysisEvaluation and implementation of
opportunities to effect environmental improvements.
Water and Water and energy conservation should be considered as part of an
Energy overall pollution prevention strategy. Benefits to reducing water
Conservation 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: P2(2i)
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.
P2(22)
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Recycling/ Recycling can be used where further source reduction techniques
Waste Ex- cannot be implemented. Recycling involves the use of a waste as an
change effective substitute for a commercial product or as a raw material in
the manufacture of a product.
On-site Recycling the waste on-site by returning the waste back to the
Recycling 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).
Off-site Recycling waste off-site by sending it to a recovery/reclamation
Recycling/ facility for processing (e.g., sending metal-bearing sludges from
Reclamation industrial waste water treatment processes to Off-site reclamation
facilities).
P2(23)
Waste Exchange 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.
P2(24,25)
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.
P2(26)
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.
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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.
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.
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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 sue facilities.
From July, 1989 through August, 1990 the company implemented a $1.7 million process conver-
sion and emission control project at its Derry 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 dichloromethane.
A screen cleaning use of dichloromethane was also replaced with an aqueous cleaning solution
at the Owego, NH facility.
HADCO's conversion project iias 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 1,1,1-trichloroethane through conversion of the cleaning and dry film
processes 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
installed a dual-bed activated carbon adsorption recovery system at its Derry, 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 law did not require control of methyl ethyl ketone or 1,1,1-trichloroethane at the Derry
site. Thus, HADCO has reduced air emissions by more than 270,000 pounds over the state re-
quirements,
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%.
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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, IL. 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 chemicals 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 in 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 xylene, 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 circulation 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
increased 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.
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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 than 50 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 ketone, methyl isobutyl ketone, and xylene at the
Consumer Products plant in North Brunswick, NJ. These chemicals were used in the
manufacturing process for the company's Band-Aid Brand adhesive bandages. Vinyl
extrusion and the use of a water-based emulsion has been substituted in the manufac-
turing 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;
implementing 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 52% in releases and transfers of all
these chemicals between 1988 and 1992.
Material substitution at Ethicon plants in Somerville, NJ and San Angelo, TX, as well as
the Advanced Materials facility in Gainesville, GA and the Vistakon plant in
Jacksonville, FL, resulting in a decrease of over 66,500 pounds (73%) in releases and
transfers of 1,1,1-trichloroethane between 1988 and 1992. A biodegradable cleaner was
substituted for 1,1,1-trichloroethane.
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
reductions were due principally to the conversion of the adhesive carrier to aqueous emulsion in
the Band-Aid 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.
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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 eliminated, 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 facili-
ty 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
replaced 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 the 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 disposal.
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.
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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 duct 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
emission sources. The survey followed the "solvent trail" through the entire manufacturing
process, from unloading of solvent from tank trucks to post-manufacture disposal of rubber
scrap. After completing the facility survey and evaluating the results, AJdan 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
renovation, 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 recovery 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 re-
moves excess rubber, dirt, and other contaminants from production machinery. To
eliminate this use of toluene, AJdan 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 or 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
transfers 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.
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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 Teduce releases of selected chemicals:
Releases of methyl ethyl ketone have been reduced 93% (113,000 pounds) through
substitution of water 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 in 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 a result of substitution of methyl ethyl ketone-based primers
with a water-based formulation.
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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 Fryeburg, Maine and a plant in El 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 implemented 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
clean 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.
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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.
The 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
coverage 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
generalized 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 40% 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
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Automobile and Truck Components (seat and trim)
Douglas & Lomason Company is a manufacturer of automobile and truck compoments, primarily
seat and trim parts. The company is headquartered in Farmington 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-trichloroethane as a solvent, was replaced with a water-based formulation. This
substitution completely eliminated the use of 1,1,1-trichloroethane, 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, xy-
lene, 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 ap-
proach 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 Tust protection. The use of solvents in the paint has
been eliminated 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, IA, 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
reducing 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 Colum-
bus, 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
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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 well 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 the environment include:
Olin Corp, Rochester, NY. Olin's Rochester facility produces over 60 different types of specialty chemi-
cals ~ relatively low volume products tailored to the specific needs of individual customers, including
biocides (anc 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.
In 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 pro-
duction 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-trichloroethane 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 reduc-
tion 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.
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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, Seal, and Filtration. The
company's Aerospace segment is a single group with several divisions that account for tlie 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 agita-
tion.
Eliminated 453,000 pounds of releases and transfers of methyl ethyl ketone and toluene by substitut-
ing 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,
and xylene by substituting water-based adhesives and paints for solvent-based adhesives 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
improved quality control.
Reduced releases and transfers of cadmium and cadmium compounds by 15,000 pounds by substitut-
ing 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 have 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 eliminated 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.
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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 alf use of dichloromethane in its operations. To accomplish 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 1,1,1-
trichloroethane. These changes eliminated 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 methanol.
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 sue vendors nationwide over a two-year period to identify re-
placements 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 for 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
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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 equipment), elec-
tronics (including guidance systems, guided missiles, printed circuit boards, and communications equip-
ment), and energy/environmental services (including power, transportation, logistics support, and road
building equipment). Raytheon is headquartered in Lexington, Massachusetts and had twenty five facili-
ties 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-trichloroethane,
tetrachloroethylene, trichloroethylene, and CFC-113 were all targeted by Raytheon's ODS and
suspected carcinogen phaseout goals. In 1988, these solvents were used at 18 facilities for elec-
tronics cleaning and metal degreasing, and as general solvent cleaners.
Terpene-based cleaners and mildly alkaline aqueous solutions were identified as alternatives to
these solvent cleaners. Raytheon has successfully eliminated its use of dichloromethane, tetra-
chloroethylene, and CFC-113, and has significantly reduced its use of 1,1,1-trichloroetbane and
trichloroethylene as a result of the development of these alternate 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 has
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-trichloroethane and
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 reductions account
for approximately 28% of total reductions of releases and transfers of these chemicals during that period.
The replacement of 1,1,1-trichloroethane 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
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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 011 the Mon Valley Works.
The other plants are the Gaiy (Indiana) Works and the Fairfield (Birmingham, Alabama) Works.
U.S. Steel expected to achieve its reductions through material reuse/recycling, process modifications, and
product changes. Based on its reported 1988 emissions data, the company's goal translates 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 implement-
ed 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
inert 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 pelletizingprocess. 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 ben-
zene and toluene. The facility switched to clean quench water 100% of the timej 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.
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INDUSTRIAL PROCESSESES
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INDUSTRIAL PROCESSES
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
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LESSON PLAN
1.0 PETROCHEMICAL INDUSTRY
Objective: To provide information concerning petrochemical production processes, sources of
pollution and their control.
Duration: 1.00 hours
References: See page 1-6
Session outline: A. Process Description
B. Sources of Pollution
C. Pollutants and Their Control
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a petrochemical
manufacturing plant, observe and make note of process operations, pollution control
devices and pollution prevention activities, take photographs, slides, or make a videotape,
and acquire "show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: PC(1) - PC(ll)
Additional activities:
If possible, provide manufactured petrochemical products for attendees to examine.
TJ1NS1 KU MAN
1-i
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TMNS*I RU.MAN 1-jj
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PETROCHEMICAL INDUSTRY
The petrochemical industry is a large and complex source category that is very difficult PC(i)
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 PC(2)
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 PC(3)
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 PC(4)
3. BTX production
4. Naphthalene production
5. Production of cresols and cresylic acids
6. Separation of normal paraffins
1-1
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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.
1,3-butadiene is a high-volume, intermediate organic chemical used commercially to PC(5)
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, coproduced 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. PC(6)
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 PC(7,
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
1-2
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Exhibit 1: Process Diagram of Production of a Mixed C(4)
Stream Containing Butadiene
Vent B
L_
Control device(s)
(if installed)
Feedstock
3
Steam
t
Vent A
Caustic
Steam
cracking
furnace
t
Vent A
T
Fuel
Mixed
hydrocarbons
I
t
Degassing
Vent A Vent A
Quenching
Gasoline
*
fractionation
J
J
Olefins to
recovery
t
Vent A
Compressors
r
Vent A
1
Olefins to
recovery
Acid gas
removal
Further
refining
Mixed C(4) stream to
butadiene recovery
process
Denotes potential location of emission source
A Denotes process vent
B Represents emissions after a control
-------
hydrocarbons such as acetylene to olefins. The product C4 stream from the hydrogenator
is combined with a 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 PC(8)
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
adsorption 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: PC(9)
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. PC(io,ii)
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
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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
Control Device
Control
Efficiency (%)
Particulates
(For gases)
VOC
- Gas recovery (boiler)
999
Hydrocarbons
- Flare
98
so,
- Incinerator
98
NO,
CO
Chemicals used or produced (benzene,
1,3-butadiene, naphthalene)
1-5
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Exhibit 3: Hazardous Waste Generation From the Petrochemical Industry
Pollutant
Amount
Disposal Method
Hazardous solids
Not available
Land disposal
Incineration
Salvage & recycle
Hydrocarbons
Not available
Chemical & biological
Any hazardous chemicals used or
Not available
treatment
produced
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
-------
ro
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LESSON PLAN
2.0 CHEMICAL MANUFACTURING
Objective: To provide information concerning chemical manufacturing processes, sources of
pollution and their control.
Duration: 1.00 hours
References: See page 1-6
Session outline: A. Process Description
B. Sources of Pollution
C. Pollutants and Their Control
1. Air Pollution
2. Solid/Liquid Waste
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a chemical
manufacturing plant, observe and make note of process operations, pollution control
devices and pollution prevention activities, take photographs, slides, or make a videotape,
and acquire "show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: CH(1) - CH(42)
Additional activities:
If possible, provide chemical manufacturing products for attendees to examine.
T.MNSTKU.MAN 2-i
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T3INSTRU.MAN 2-ii
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CHEMICAL MANUFACTURING
A. PROCESS DESCRIPTION CH(i)
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 CH(2)
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 (750-950T). 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, CH(3,4)
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
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Exhibit 1: Sources of Pollution at a Typical ACN Plant
~
\ Incinerator /
A /
Air
Ammonia
Propylene
Deep well
pond
Wastewater
column
Acetonitrile
column
Product
column
Crude
ACN
storage
Absorber
Light ends
column
Recovery
column
Quencher
ACN storage
ACN loading
Reactor
Air emissions
Solid/Liquid waste
-------
Exhibit 2: VOC and Acrylonitrile Emissions From ACN Manufacturing"
Emission Point
Emission Rate (kg/hr)
Control Method
Control
Efficiency
(%)
Acrylonitrile
Total VOC
Absorber Vents
2.05
2050
Thermal Incineration
Catalytic Oxidation
99.9
95-97
Column Vents
103
205
Flare
98-99
Storage Tanks
13.5
14.8
Double Seal Floating Roof
Water Scrubber
N/A
99
Loading"
3.44
3.98
Flare
Incinerator
98-99
99
Fugitive
9.5
19.5
Leak Detection/Maintenance
N/A
Incinerator Stack
7.4
N/A
N/A
Deep Well/Pond
267
Water Scrubber
N/A
Model plant has an annual ACN capacity of 180 million kg, and is assumed to operate 8760 hours annually
Loading uito tank can, 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, C02, 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 NOx by operating under fuel-rich conditions in
the flame zone where most of the NO* is formed and oxygen-rich conditions downstream
at lower temperatures where NOx is not appreciably formed.
Ammonia injection reduces NOx 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 NOx destruction efficiencies in the range of 80%,
which is compatible with the residence time required for VOC destruction.
Deep Well/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 CH(5)
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
Pollutant
Amount
Disposal Method
Wastewater Column
Ammonium Sulfate
Heavy Hydrocarbons
N/A
Deep well pond
Acetonitrile Column
Heavy Bottoms
N/A
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.
CH(6-42)
2-6
-------
CO
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LESSON PLAN
3.0 SYNTHESIZED PHARMACEUTICAL MANUFACTURING PLANTS
Objective: To provide information concerning the production of synthetic pharmaceuticals,
sources of pollution and their control.
Duration:
1.00 hour
References: See page 1-10
Session outline:
A. Process Description
B. Sources of Pollution
1. Reactors
2. Distillation Operations
3. Separation Operations
4. Dryers
5. Storage and Transfer
C. Pollutants and Their Control
1. Air Emissions
2. Solid and Liquid Wastes
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a pharmaceutical
manufacturing plant, observe and make note of process operations, pollution control
devices and pollution prevention activities, take photographs, slides, or make a videotape,
and acquire "show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: PH(1) - PH(38)
Additional activities:
If possible, provide "show-and-tell" items for attendees to examine.
T3INSTRUMAN
3-i
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tmnstru-man 3-ii
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SYNTHESIZED PHARMACEUTICAL MANUFACTURING PLANTS
A. PROCESS DESCRIPTION
The synthesis of medicinal chemicals may be done in a very small facility producing only PH(i)
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 PH(2)
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 PH(3)
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.
3-1
-------
EXHIBIT 1: Typical Synthetic Organic Medicinal Chemical Process
Vent Vent
Solids
Water solvent
Vent
Solvent
Vent
Vent
Solvent
receiver
Solvent
Batch
centrifuge
Dryer
Reactor
Holding
tank
Solvent
Distillation
Crystalizer
Y
A Water or solvent
I
! Air emissions
1
I
! Liquid waste
I
Y
Typical Cycle = 24 Hours
-------
The crude product may then be dissolved in another solvent and transferred to a PH(4,5)
crystallizer for purification. After 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.
PH(6)
B. SOURCES OF POLLUTION
Exhibit 2 identifies pollutants from a typical pharmaceutical process. Volatile organic PH(7)
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 PH(8)
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 PH(9-12)
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 PH(13)
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: M^jor Pollutants From Solvent Use in Pharmaceutical Production'
Pollutant
(Solvent)
Ultimate Disposition (%)
Air
Emissions
Sewer
Incineration
Solid
Waste
Product
Acetic anhydride
1
57
42
Acetone
14
22
38
7
19
Amyl alcohol
42
58
Benzene
29
37
16
8
10
Carbon tetrachloride
11
7
82
Dimethyl formamide
71
3
20
6
Ethanol
10
6
7
1
76
Ethyl acetate
30
47
20
3
Isopropanol
14
17
17
7
45
Methanol
31
45
14
6
4
Methylene chloride
53
5
20
22
Solvent B (hexanes)
29
2
69
Toluene
31
14
26
29
Xylene
6
19
70
5
a Numbers are based on a survey of 26 U.S. manufacturers
3-4
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3. Separation Operations
PH(14)
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 PH(15)
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
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5. Storage and Transfer
PH(16-19)
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 PH(20)
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
VOC's 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
1. Emissions from batch extraction stem mainly from displacement of vapor while
pumping solvent into the extractor and while purging or cleaning the vessel after
extraction. Some VOCs also may be emitted while the liquids are being agitated.
3-6
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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 ciystallization 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 of the drum and from the ensuing waste stream. These filters
can be shrouded or enclosed for control purposes.
3-7
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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
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2.
Solid and Liquid Wastes
PH(21)
The manufacture of the following types of pharmaceutical products can generate
hazardous wastes:
Organic medicinal chemicals Medicinals from animal
Inorganic medicinal chemicals glands
Antibiotics Biological products
Botanicals Miscellaneous products
The largest quantities of hazardous waste are from the production of organic medicinal PH(22)
chemicals and antibiotics. Exhibit 3 identifies potential hazardous wastes from
pharmaceutical production:
Exhibit 3: Potential Hazardous Wastes from Pharmaceutical Production
Product or Operation
Potential Hazardous Wastes
Estimated U.S.
Generation (dry
metric tons/yr)1
Organic medicinal chemicals
Heavy metals
Terpenes, steroids, vitamins,
tranquilizers
Ethylene dichloride
Acetone, toluene, xylene,
benzene isopropyl alcohol,
methanol, acetonitrile
Zinc, arsenic, chromium,
copper, mercury
1,700
13,600
3,400
23,800
2,700
Inorganic medicinal chemicals
Selenium
200
Antibiotics
Amyl acetate, butanol, butyl
acetate, MIK, acetone,
ethylene glycol, monomethyl
-ether
12,000
Botanicals
Ethylene dichloride,
methylene chloride
Methanol, acetone, ethanol,
chloroform, heptane, naphtha,
benzene
Misc. organics
100
100
700
Medicinals from animal glands
Misc. organics
800
Biological products
Vaccines, toxoids, serum, etc.
Ethanol
500
300
Misc. sources
Misc. solvents
63,900
'Hazardous waste amounts arc for 1973 estimated total U S generation
PH(23-38)
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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
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LESSON PLAN
4.0 METALLURGICAL INDUSTRIES
Objective: To provide information concerning metallurgical industrial processes, sources of
pollution and their control.
Duration: 1.00 hour
References: See page 1-9
Session outline: A. Process Description
1. Mold and Core Production
2. The Melting Process
3. Casting, Cooling, and Finishing
B. Sources of Pollution
C. Pollutants and Their Control
1. Emission Sources
2. Air Pollution Control Measures
3. Hazardous Air Pollutants From Other Metallurgical
Industries
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a foundry, observe
and make note of process operations, pollution control devices and pollution prevention
activities, take photographs, slides, or make a videotape, and acquire "show-and-teH" items
whenever possible.
Audiovisual and graphic material:
Slides: M(l) - M(55)
Demonstration materials: raw materials, molded items
Additional activities:
Set out demonstration materials for attendees to examine.
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T3INSTRU MAN
4-ii
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METALLURGICAL INDUSTRIES
The metallurgical industries can be broadly divided into primary, secondary, and M(i)
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:
As a representative industry within the metallurgical classification, iron foundries have M(2,3)
been selected for discussion.
Methods 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.
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
Primary Aluminum
Metallurgical Coke
Copper Smelting
Ferroalloy Industry
Steel Industry
Primary Lead Smelting
Zinc Smelting
Secondary Aluminum
Secondary Brass and Bronze
Melting Processes
Iron Foundries
Secondary Lead Smelting
Steel Foundries
Secondary Zinc
A. PROCESS DESCRIPTION
M(4)
4-1
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the 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.
cL 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
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of alloying agents selected for their desired metallurgical properties. The molten
material then is 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. M(5)
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 M(6)
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 M(7-2i)
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 M(22-28)
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.
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Exhibit 1: Emission Points in a Typical Iron Foundry
A
Air Emissions
Solid/Liquid waste
Furnace/
Cupola
Finished
product
Metallics
Coke
Pouring
Fluxes
Molding
Finishing
Core making
Cooling and
cleaning
Casting
shakeout
-------
Exhibit 2: Emissions From Iron Foundry Processes
Emission Point
Pollutants
Control Methods
Mold and Core Production .
particulates
VOCs
carbon monoxide
Melting
fugitive particulates
fumes
organic compounds
carbon monoxide
VOCs
Induction and Arc Melting
particulates (metal
oxides)
organics
Wet Scrubbers
Cupola Melting
dust consisting of:
iron oxide
silicon dioxide
Fabric Dust
zinc oxide
Collectors/Baghouses
magnesium oxide
manganese oxide
calcium oxide
Afterburners
lead
cadmium
Charcoal Adsorption
gases:
carbon monoxide
sulfur oxides
lead
organic emissions
Pouring, Casting, Cooling and
particulates
Finishing
magnesium oxides
metallic fumes
carbon monoxide
organic compounds
VOCs
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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
lb/ton melted. Electric induction furnaces, however, may emit particulates at one tenth
of that value.
cL Cupola Melting
The quantity and composition of particulate 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 particulate per ton melted. Eighty-five percent of such emissions may
be greater than 10 /xm 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 M (29-37)
Particulate 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
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methods, such as the tundish method, result in significantly lower emissions than others.
Emissions from pouring consist of metal fumes, carbon monoxide, organic compounds, M(38-40)
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 M(4i-47)
a much lower rate. Finishing operations, such as the removal of burrs, risers, and gates, M(48-52)
and shotblast cleaning, also e'mit 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 M(53)
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 particulate 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 particulate matter
from an air stream or gas stream is the fabric dust collector or baghouse. With a mass
median size of 0.5 pm, 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.
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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 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. Adsorption
Charcoal adsorption has been used in conjunction with other control devices for VOC
control.
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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 M(54,55)
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
Furnaces
Converter/charging
Beryllium
Foundry mold and core
Furnace tapping
Chromium
decomposition
Furnace charging
Copper
Metal casting
Lead
Manganese
Nickel
Zinc
Iron
Exhibit 4: Hazardous Air Pollutants from Aluminum Production
HAPs
Potential Emission Sources
Potential Fugitive
Emission Sources
Fluorides
Calciner
Furnace tapping
Chloride
Material handling
Furnace charging
Hydrogen chloride
Furnaces
Coke quenching
Material crusher and mills
Storage and handling areas
Reduction cells
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.
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LESSON PLAN
5.0 TANNERIES
Objective: To provide information concerning tanning processes, sources of pollution and their
control.
Duration: 1.00 hour
References: See page 1-7
Session outline: A. Process Description
1. Chrome Tanning
2. Vegetable Tanning
B. Sources of Pollution
C. Pollutants and Their Control
1. Air Emissions
2. Process Liquid and Solid wastes
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a tannery, observe
and make note of process operations, pollution control devices and pollution prevention
activities, take photographs, slides, or make a videotape, and acquire "show-and-tell" items
whenever possible.
Audiovisual and graphic material:
Slides: T(l) - T(118)
Demonstration materials: leather samples - "blue stock", splits, finished leather (embossed,
surface-coated, staked, unstaked)
Additional activities:
Set out demonstration materials for attendees to examine.
IJINSTRU MAN
5-i
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T3INSTRU MAN 5"ii
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TANNERIES
T(U)
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 T(3)
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 T(4-8)
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 T(9)
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. T(iO,ii)
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EXHIBIT 1: Process Flow Diagram of a Typical Chrome Tannery
A
i
i
To sanitary
landfill
Air emissions
Liquid waste
To sewer
Finished
leather
Cured
cattle
hides
Wring
Split
Shave
Side soak
Flesh
Bate
Pickle
Tan
Retan
Color
Fat liquor
Dry
Condition
Finish
Trim
Screening
Solid waste
-------
Cattlehides are too thick for most purposes so the tanned hides are split using a machine T(i2-i7)
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 T(i8-28)
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 and the hides are taken out and
wrung to remove excess moisture. 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 T(29-59)
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 T(60-73)
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
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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 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 T(74)
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 T(75-87)
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 T(88,89)
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.
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Exhibit 2: Emissions of Toxic Air Pollutants From a Topical Tannery
Emission Point
Pollutants
Emission Rate
kg/hr
Control Methods
Solvent Receiving
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylol
22.58
167
10.04
1.17
Mixing Vault
Methyl Ethyl Ketone
0.52
Supply Drum
Methyl Ethyl Ketone
0.52
Spray Chamber
Diacetone Alcohol
Glycol Ether EB
Glycol Ether PMA
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylol
1.89
11.85
7.6
75 72
59 05
95.78
33 38
Incineration
Dryer
Diacetone Alcohol
Glycol Ether EB
Glycol Ether PMA
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Toluene
Xylol
1.89
11.85
76
75.72
59 05
95 78
33.38
Process Modification
(e.g, water-based process
instead of solvent-based
process)
Receiving Recycled Solvents
Acetone
Methyl Ethyl Ketone
Toluene
0.61
0 98
0 61
Cleaning Operation
Less than 1 kg/hr of each pollutant
Waste Solvent Storage
Less than 1 kg/hr of each pollutant
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 T(90
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.
-------
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
Pollutant
Concentration Range"
(wet weight in mg/kg)
Disposal Method
Chrome trimmings &
Shavings
Cr+3
2,200 - 21,000
Chrome fleshings
Cr+3
4,000
Unfinished chrome
leather trim
Cr43
Cu
Pb
Zn
4,600 - 37,000
23 - 468
2.5 - 476
9.1 - 156
Landfill
Buffing dust
Cr°
Cu
Pb
Zn
19 - 22,000
29 - 1,900
2 - 924
160
Dewater sludge; all
waste disposed in
certified hazardous
waste disposal facility
Finishing residues
Cr+3
Cu
Pb
Zn
0.45 - 12,000
0.35 - 208
2 5 - 69,200
14 - 876
Finished leather trim
Cr+3
Pb
1,600 - 41,000
100 - 3,300
Landfill with leachate
Sewer screenings
Cr43
Pb
Zn
0.27 - 14,000
2 - 110
35 - 128
collection
Wastewater treatment
residues (sludges)
Cr°
Cu
Pb
Zn
0 33 - 19,400
0 12 - 8,400
0 75 - 240
1.2 - 147
' Range not shown when only one sample was analyzed for the constituent T(98-118)
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
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5-8
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o>
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LESSON PLAN
6.0 CEMENT INDUSTRIES
Objective: To provide information concerning the production of cement, sources of pollution
and their control.
Duration:
1.00 hour
References: See page 1-12
Session outline: A. Process Description
B.
C.
D.
1. Raw Material Acquisition
2. Raw Milling
3. Pyroprocessing
4. Clinker Cooling
5. Clinker Storage
6. Finish Milling
7. Packing and Loading
Sources of Pollution
Pollutants and Their Control
1. Air Pollutants
2. Liquid and Solid Wastes
References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a cement
manufacturing plant, observe and make note of process operations, pollution control
devices and pollution prevention activities, take photographs, slides, or make a videotape,
and acquire "show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: CE(1) - CE(34)
Additional activities:
If possible, provide "show-and-tell" items for attendees to examine.
HINSTRU MAN
6-1
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T31NSTRU MAN
6-ii
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CEMENT INDUSTRIES
A. PROCESS DESCRIPTION CE(l)
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 CE(2-8)
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).
Dry process
Go to Part 2
on next page
Wet process
Go to Part 2
on next page
Water
Grinding mill
Grinding mill
Raw material
proportion
Raw materials
storage
Quarried raw
materials
Purchased raw
materials
Air separator
Dust collector
~
' Particulate Emissions
-------
Exhibit 1: Basic Flow Diagram of the Portland Cement
Manufacturing Process (Part 2).
Go to Part 3
on next page
Particulate emissions
Dust collector
Clinker cooler
Fuel
Clinker storage
Dry raw meal
blending &
storage
Dust collector
Kiln
Slurry blending
& storage
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
Oust collector
Shipment
Air separator
Cement storage
Grinding mill
A
| Particulate emissions
i
-------
3. Pyroprocessing
CE(9)
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 CE(10)
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 CE(iM3)
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
CE(ls
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 particulate 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 particulate 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
6-6
-------
Exhibit 2: Air Pollution and Control at Cement Production Facilities
Emission Point
Pollutants
Emission Rate
(gr/acf1)
Control Device
Percent
Efficiency
Quarries
Particulates
5-40
Fabric Filter:
Pulse Jet
Reverse Air/Shaker
i 99.6
Raw Mill
Systems
Particulates
5-20
Fabric Filter:
Pulse Jet
Reverse Air/Shaker
Cartridge
* 99.6
Kiln System
Particulates
4-18
Dust Collectors:
Reverse Air
Precipitator
* 99.5
Clinker Coolers
Particulates
5-10
Fabric Filters:
Pulsed Plenum/Pulse Jet
Reverse Air
Precipitator
* 99.6
Finish Mill
Systems
Particulates
5-20
Fabric Filter:
Reverse Air/Shaker
s 996
Finish Mill
Systems
Particulates
5-100
Fabric Filters-
Pulse Jet
Pulsed Plenum
* 996
For use with
High-
Efficiency
Separators
Particulates
150-300
Fabric Filters:
Pulse Jet
Pulsed Plenum
:> 99.9
Packing and
Loading
Departments
Particulates
5-40
Fabric Filters:
Pulse Jet
Reverse/Air Shaker
Cartridge
*996
1 gr/acf = grains/actual cubic foot
6-7
-------
Exhibit 3: Applicability of Emission Control Methods
Operation
Mechanical
Wet
Fabric
Electrostatic
Gravel Bed
Collector
Scrubber
Collector
Filter
Primary
Unsatisfactory
Not
Successful
Not
None in use
grinding
efficiency
applicable
applicable
Air
Not
Not
Successful
A few
Questionable
separators
applicable
applicable
installations
application
Mills
Not
Not
Successful
A few
Questionable
applicable
applicable
installations
application
Storage
Not
Not
Successful
Not
Impractical
silos
applicable
applicable
applicable
Feeders
Not
Not
Successful
Not
Impractical
and belt
applicable
applicable
applicable
conveyors
Packing and
Not
Not
Successful
Not
Impractical
loading
applicable
applicable
applicable
Coal
Preliminary
Practicable
Successful
Not
Practicable
dryer
cleaning only
common
Kiln
Preliminary
Impractical
12 x 30 Glass
Successful
Practicable
gases
cleaning only
Successful
Clinker
Preliminary
Not
Successful
Not
Successful
cooler
cleaning only
applicable
common
6-8
-------
combustion of fuel in rotary 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 particulate matter.
Particulate matter is also emitted from the handling, loading, unloading, and transport
of raw materials, such as coal, purchased from another source. In certain areas, exhaust
from portable equipment may also be a consideration.
The following methods are used to control particulate emissions generated from the
quarry and handling of purchased raw materials:
CE(15-17)
fabric filters (pulse-jet or reverse-air/shaker)
water sprays (with and without surfactants)
silos (with and without exhaust venting to
fabric filters)
mechanical collectors
chemical dust suppressants
material storage buildings
equipment enclosures
enclosures
wind screens
foams
bins
paving
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 CE(i8)
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 CE(i9-22)
(CKD) is also produced.
The cement kiln itself has been designated as best available control technology (BACT)
for the control of S02. The highly alkaline conditions of the kiln system enable it to
capture up to 95% of the possible S02 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 particulate 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 CE(23)
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
-------
e Clinker Storage
The devices used to control dust emissions from clinker storage areas are similar to
those used in the raw milling process. The particulate 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.
f 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 particulate 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 CE(24-29)
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 CE(30-34)
The overflow from slurry concentrating equipment (i.e. thickeners) constitutes the main
water pollution problem. For new plants that process slurry, cfosed-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
6-11
-------
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.
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
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^1
-------
LESSON PLAN
7.0 PRINTED CIRCUIT BOARD MANUFACTURING
Objective: To provide information concerning printed circuit board manufacturing processes,
sources of pollution and their control.
Duration: 1.00 hour
References: See page 1-6
Session outline: A. Process Description
B. Sources of Pollution
C. Pollutants and Their Control
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a printed circuit
board manufacturing facility, observe and make note of process operations, pollution
control devices and pollution prevention activities, take photographs, slides, or make a
videotape, and acquire "show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: PCB(l) - PCB(138)
Demonstration materials:
drilling machine tape, positives, negatives, laminated copper board, board laminated
with photosensitive film, developed (imaged) board, soldered board (etch resist),
etched board (soldered), finished board (tinned), solder-masked board, finished
board (soldered)
Additional activities:
Set out demonstration materials for attendees to examine.
T3INSTRU.MAN
7-i
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TJINSTRU MAN 7"ii
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PRINTED CIRCUIT BOARD MANUFACTURING
A. PROCESS DESCRIPTION PCB(i)
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 PCB(2)
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 particulate form and can be removed by filtration or
centrifuge. Equipment is available to remove this copper particulate, 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 a plating resist is applied to the panel and photo-imaged
to create the circuit design. Copper is then electroplated on the board to its final
thickness. A thin layer of tin lead solder or pure tin is plated over the copper as an etch
resist. The plating resist is then removed to expose the copper not part of the final
circuit pattern.
The exposed copper is then removed by etching to reveal the circuit pattern. 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 PCB(3)
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 PCB(4)
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
7-2
-------
EXHIBIT 1: Process Flow Diagram of a Typical Printed Circuit Board
Manufacturing Plant
i
OJ
Board
Electroless
Imaging
Copper
Solder
Stripping &
Final
preparation
>-
plating
>~
electroplating
electroplating
etching
processes
A
I
I
I
I
y
Air emissions
Solid/liquid waste
-------
the cleaning processes. Some particulates 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. PCB(5)
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. PCB(o,/;
PC B (8-138)
7-4
-------
Exhibit 2: Air Emissions from Printed Circuit Board Manufacturing
Emission Point
Pollutants
Control Device
Surface Preparation
Particulates
VOC
Baghouses/Cyclone separators
Carbon adsorber
Surface Cleaning
Acid fumes
VOC
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
Waste rinse water
metals, fluoride, acids, halogenated
solvents, alkali, board materials,
sanding materials
Electroless Plating
Spent electroless copper bath
Spent catalyst solution
Spent acid solution
Waste rinse water
acids, stannic oxide, palladium,
complexed metals, chelating agents,
copper
Pattern Printing and
Masking
Spent developing solution
Spent resist removal solution
Spent acid solution
Waste rinse water
vinyl polymers, chlorinated
hydrocarbons, organic solvents, alkali
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.r and Looby, G. P. Waste Minimization Assessment for a
Manufacturer of Printed Circuit Boards. July 1991. EPA/600/M-91/022
7-6
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00
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LESSON PLAN
8.0 ELECTROPLATING
Objective: To provide information concerning electroplating processes, sources of pollution and
their control.
Duration: 1.00 hour
References: See page 1-5
Session outline: A. Process Description
1. Material Preparation
2. Plating
3. Alternative Processes
B. Sources of Pollution
C. Pollutants and Their Control
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit an electroplating
facility, observe and make note of process operations, pollution control devices and
pollution prevention activities, take photographs, slides, or make a videotape, and acquire
"show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: EP(1) - EP(9)
Demonstration materials: items (before/after electroplating)
Additional activities:
Set out demonstration materials for attendees to examine.
T3INSTRU.MAN 8"i
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TJINSTRU.MAN 8"U
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ELECTROPLATING
Electroplating is the process of depositing a coating having desirable characteristics by EP(i)
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 EP(2)
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 EP(3)
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
8-1
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and grease. 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 EP(4)
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 EP(5)
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
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Exhibit 1: Sources of Pollution in the Electroplating Process
~
Work piece
Deionized water
Caustic
soda
HCL
Air emissions
Filters
Finished
product ,
Plating bath
Rinsing
Surface cleaning/
preparation
Carbon filters
Wastewater
storage
cation/anion beds
Solid/Liquid waste
I
t
-------
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 EP(6,7)
Emission
Source
Pollutants
Emission
Rate
Control
Device
Control
Eff. (%)
Surface Cleaning/ Preparation
Covers
Acid/alkali cleaning
Cu, Ni, Zn, Pb
Fe
3 mg/1 each
36 mg/1
Increased
freeboard
Cold cleaners
Vapor degreasers
VOC
voc
190-560 kg/yr
9500 kg/yr
Refrigerated
chiller
Carbon adsorber
Surface Modification
Hard chromium plating
Decorative chromium
plating
Chromic acid anodizing
Cr+6
15-90 g/hr
4-66 g/hr
1 2-2 8 g/hr
Demister
Wet scrubber
Chemical fume
suppressants
87 9-99 7
95.4-99.4
99 5-99 8
Exhibit 3: Potentially Hazardous Wastes Generated From Electroplating Operations EP(8)
Waste Source
Pollutant
Amount
Disposal Method
Chemical operations
Heavy metals
Landfilling
Electroplating
operations
Heavy metals
Oil and grease
Asbestos
Cyanides
Solvent
N/A
Landfilling
Degreasing
Chlorinated & fluorinated hydrocarbons'
N/A
'Hydrocarbons include trichloroethylene, perchloroethylene, methyl chloroform, trichlorolrifluoroethylene, methylene
chloride
8-4
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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 dewatering 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 disposaj costs.
The increasing costs and liability of hazardous waste disposal are leading many EP(9)
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
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8-6
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CO
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LESSON PLAN
9.0 LEAD SMELTING
Objective: To provide information concerning lead smelting, sources of pollution and their
control.
Duration: 1.00 hour
References: See page 1-8
Session outline: A. Process Description
1. Primary lead smelting
2. Secondary lead smelting
B. Sources of Pollution
C. Pollutants and Their Control
D. References
Background guidance:
To prepare for (and enhance) this presentation, instructors should visit a lead smelting
facility, observe and make note of process operations, pollution control devices and
pollution prevention activities, take photographs, slides, or make a videotape, and acquire
"show-and-tell" items whenever possible.
Audiovisual and graphic material:
Slides: L(l) - L(10)
Additional activities:
If possible, provide show-and-tell items for attendees to examine.
T3INSTRU.MAN
9-i
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T3INSTRU.MAN 9-ii
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LEAD SMELTING
Lead is usually found naturally as a sulfide ore containing small amounts of copper, iron, L(i)
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, L(2)
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
9-1
-------
sulfides), slag (primarily silicates), and lead bullion. The first three layers are
collectively called slag, 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 NaN03.
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 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 drossing", 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 POLLUTION
Exhibit 1 is a flow diagram of the primary lead smelting process. Both air emission L(4)
points and hazardous waste generation points are identified. Exhibit 2 identifies the air L(5)
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
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Exhibit 1: Diagram of a Typical Primary Lead Smelting Process
t
Drossing
bullion
Bullion
Sinter
Concentrate
Rellned leac
Limestone
PbO
Ammonium chloride
Silica
Coke
Soda ash
Dross
Sinter
Sulfur
Slag
Limestone
Flue dust
Flue dust
Silica
Coke
Coke
Soda ash
Sulfur
Pig iron
PbO
Coke
Matte and
speiss
ZnO
Sinter
machine
Drossing
kettles
Slag fuming
furnace
Refinery
Blast furnace
Dross
reverberatory
furnace
| Air emissions
-------
Exhibit 2: Diagram of a Typical Secondary Lead Smelting Process
Pretreatment
Smelting
Refining
Products
Draining &
decasing
V7
i i
Crushing
*
_L_
A
I
Sloping
hearth
T
Dross &
fine dust
Reverberatory
Sows
Hogs
r
Dust
agglomeration
Casting
I
Zinc leaching
FT
Ventilation system to
emission controls
~
I
%
Reverberatory
FT
»
_L
Kettle
softening
Air emissions
%
Effluent stream
I
i Pigs
6
-W Soft lead
Casting
' "1
t t
i i
Oxidation
kettle
Semisoft
lead
Battery )
Reverberatory
Yellow
Alloying
kettle
Hard lead
Casting
Other lead
alloys
1
Solid residues
-------
Exhibit 3: Air Emissions From Primary and Secondary Lead Smelters
L(6-9)
Emission
Point
Pollutants
Emission
Rate
Control Device
Control
Eff.(%)
PRIMARY LEAD SMELTING
Ore Crushing
Particulates
S02
1.0 kg/mt
No data
Baghouse
95-99
Sinter Machine
Particulates
S02
POM1, As, fluorides,
Sb, Pb, Hg, Se
106.5 kg/mt
275.0 kg/mt
Trace amounts
Baghouse
ESP
Sulfuric acid plants
95-99
95-99
>96
Blast Furnace
Particulates
S02
POM, As, fluorides,
Sb, Cd, Pb, Hg, Se
180.5 kg/mt
22 5 kg/mt
Trace amounts
Baghouse
95-99
Dross Reverb.
Furnace
Particulates
100 kg/mt
Refining
Particulates
so2
Materials
Handling
Particulates
W
S02
2 5 kg/mt
No data
Enclosures
Water spraying
SECONDARY LEAD SMELTING
Reverb Furnace
Particulates
S02; S03; oxides,
sulfides/sulfates of
Pb, Sn, As, Cu,
1 4-4.5 gr/ft3
Baghouse with gas-cooling
devices & settling chambers
Lead Blasts
Furnace
Particulates
CO
Up to 4 gr/ft3
Hoods; Baghouse;
Afterburner
Pot-type
Furnace
Lead oxide
Particulates
Baghouse
'Polycyclic organic material.
9-6
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Exhibit 4: Sources of Hazardous Waste in Lead Smelting Operations
L(10)
Waste Source
Pollutant
Amount (mt/y)'
Disposal Method
Primary
Heavy metals
4400
Land storage before recycle.
(As, Cd, Cr, Cu, Hg,
Immediate recycle.
Pb, Sb, Zn)
Land storage or open dumping
of dredged sludge in unlined
lagoons.
Secondary
Heavy metals
160
Dumping in lined or unlined
(Cu, Cr, Pb, Sb, Sn,
lagoon.
Zn)
Blast furnace
Cr
2
slag
Cu
18
Mn
2
Ni
2
Pb
162
Sb
10
Sn
2
Zn
10
Scrubber slag
Cd
002
Cr
0 001
Cu
0 001
Mn
0 005
Pb
24
Sb
05
Zn
0 001
Open dumping of discarded
Cupola furnace
Cu
41
slag
slag & matte
Mn
04
Ni
04
Pb
158
Sb
4
Sn
0.4
Zn
2
Reverb furnace
Cr
08
slag
Cu
0.2
Mn
12
Pb
8
Sb
01
Sn
30
Zn
08
1
a metric tons per year
9-7
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D. REFERENCES
1. Air Pollution Engineering Manual. Air & Waste Management Association.
2. 40 CFR 60, Part R
9-8
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