United States
Environmental Protection
Solid Waste
and Emergency Response
December 1997
    Reducing Toxics in Our Ration's lllaste

                       United States
                       Environmental Protection
              Solid Waste and
              Emergency Response
  May 1997
&EPA        Strategy   Update
                       A  Newsletter on  EPA's  Hazardous  Waste
                       Minimization  and  Combustion Activities
 THE  Director's Chair
 By Elizabeth. Cotfworth
 Acting Dk'&tor
 EPA Office of-Solid Waste
         As many of you undoubtedly
         know; a number of signifi-
         cant milestones ha-re been
 reached since the last edition, of the
 Strategy Update. This Update covers
 these milestones and also gives you
 a "heads up" on osher important
 upcoming items.
 Foremost is our continuing work on
 the proposed emission standards for
 the hazardous waste incinerators,
 cement kilns, and lightweight, aggregate
 kilns. Our major work at EPA since last
 August has been to analyze the reams
 of comments received from ail quarters.
 These comments provided good insight
 into the sweugfbs and the shortcomings
 of OUT proposal. We knew at the outset
 that some, aspects would need to be
 I would like to express my appreciation
 to ail those who have spent firm- and
 effort working on data, ideas, or other
 regulatory details brought to EPA's
 attention. Responding to these
 comments is requiring considerable
 effort. As a result, our ambitious
 schedule for promulgating a final rule
 has changed. We now project  a tinal
 rule in March-April 1998, pending
 results of additional comment analysis
 this  spring. However, OSW plans 10
 aceekiate some pieces of the proposal
 by Jate 1997 {e.g., permit modification
 changes and the comparable fuels

 On the. waste minimization front,
 3 .ti:s} of the most persistent,
 bioaccumulative, and toxic (PBT)
Status of Combustion  Rule
        On April 19, 1996 (61 Federal Register 17358), EPA proposed Revised
        Standards for Hazardous Waste Combustion Facilities under joint
        authority of the Clean Air Act (CAA) and Resource Conservation and
Recovery Act (RCRA). The revised standards cover hazardous waste-burning
incinerators, cement kilns, and lightweight aggregate kilns. For each unit, the
standards would impose the maximum achievable control technologies (MACT)
provisions of the CAA. The MACT standards will limit emissions of dioxins and
furans, mercury, semivolatile metals, low-volatile metals, particulate matter (PM),
acid gas, hydrocarbons, and carbon monoxide. For compliance with PM and
mercury (Hg) standards, the Agency also proposed requiring continuous emissions
monitoring systems (CEMS). CEMS would address, among other things, local
citizen and environmental group concerns about timely assurances of compliance
with emission limits at affected facilities. EPA is currently evaluating the long-term
performance of the CEMS on hazardous waste combustion devices (see sidebar).
EPA is also considering accelerating a final rule for certain portions of the hazardous
waste combustion rulemaking in advance of promulgating the overall set of final
standards. This would be intended to prevent delays in the implementation of the
final standards when adopted and allow more  facilities to come into compliance
within the required 3- to 4-year time frame. This rule, anticipated in the fall of
1997, would streamline RCRA permitting modification procedures under which
permitted facilities could more quickly make
changes to their processes and/or operating
parameters to comply with the final MACT
standards. Also slated for acceleration are the
comparable fuels exclusion, provisions related
to the compliance period, and a facility
implementation plan. The comparable fuels
exclusion will ensure that an excluded
hazardous waste fuel is similar in composition
to commercially available liquid fossil fuels.
Because of the additional time needed to
analyze and respond to the numerous
comments and data submitted on the proposal,
EPA has developed a revised schedule for the
final combustion rule. Also, in spring 1997,
EPA plans to publish further information on
CEMS Update
ihe CEMS demonstration
ujsuiig program, co-sponsored
by EFVVs Office of Solid Vfastt •,
and the Department of Energy's
Westinghoitse Savannah River
Site (DGEAVSRS), began in
Septf-mber 1996 for PM and in
August  1996 for Hg Both teas
are. expected to ccinsjnue into
the early summer oi 1*W7. l-ook
for upcoming federal Reg&tcr
notices describing initial results
of this: test program.
         4-   —
                                         1 Printed on paper that contains at least 50 percent recycled fiber.
                                                    (Continued on page 2)

(Continuedfrom page 1)
CEM testing and MACT options in two Notices of Data
Availability (NODAs). The anticipated schedule for key Federal
Register notices is:
• March 1997:  NODA:  GEMS PM and Hg Testing Report
• April 1997:   NODA:  Revised MACT Levels
• Fall 1997:     Accelerated Final Rule
• Spring 1998:  MACT Standards Final Rule

Overview of Comments on Proposed Rule

The comment period for the proposed standards, which included
a 60-day extension, ended on August 19, 1996. Approximately
145 sets of comments were received covering virtually every
provision of the proposal. EPA will be addressing these comments
in developing the accelerated and final MACT standard rules.

MACT Standards—In general, the commenters were divided
over issues such as whether the three source categories covered
by the rule should be subdivided and the appropriateness of
establishing MACT floors for each proposed hazardous air
pollutant (HAP). Some commenters felt the proposed MACT
floors were skewed high because the emissions data applied in
developing the standards were obtained during compliance
testing and trial burns, thus representing a set of operating
conditions rarely approached. In response to the new data
submitted, EPA has updated its database of emissions and
ancillary information on hazardous waste combustors (see
sidebar). Another area of controversy was the Agency's application
of the priority pollutant provisions of section 112(c)(6). Many
industry commenters believed that EPA inappropriately applied
section 112(c)(6) in that: (1) area sources would be required to
meet MACT standards for all proposed HAPs and not just those
enumerated in section 112(c)(6), and (2) other section 112(c)(6)
                                  requirements were not
                                  fulfilled prior to EPAs
                                  proposal to subject all area
                                  sources to the MACT
 EPA Releases
 Updated Database
 Based on comments and
 additional data subaijited, EPA
 updated its emissions database
 on hazardous waste combusiors
 in the January 8,1997, F^rsi
 Register. The updated datatrase
 contains stack gas emissions
 data, process operating dam,
 and facility equipment design
Implementing the Combustion  Strategy's
Permitting  Policy
       he Combustion Strategy permitting policy is implemented by EPA regional offices or
       authorized states, which are the permitting agencies for hazardous waste combustors
       under RCRA.
As a general rule, the Agency's position is that its regulations are protective of human health
and the environment and that permits containing these regulatory standards will also be
protective. However, the Agency's Combustion Strategy in 1993 indicated that the current
regulations for hazardous waste combustors may, after site-specific inquiry, need to be
supplemented through use of the omnibus provision to protect human health and the
environment.  In such cases, use of the omnibus provision as part of the permitting process
is appropriate. Under the omnibus authority, permit writers determine on a site-specific
basis what, if any, additional permit conditions are necessary to ensure protection of human
health and the environment. Under 40 CFR 270.10(k), EPA may require the applicant to
submit additional information that the Agency needs to make required determinations
under the omnibus provision. For combustion facilities, multipathway site-specific risk
assessments often provide information needed to make such determinations. EPA has made
it clear that the decision to invoke omnibus authority must be made on a case-by-case basis
and only when the permitting agency, after examining all  relevant data supplied during the
permitting process, determines that additional conditions are necessary to ensure protection.

EPA Regional and State  Implementation Activities

• Each region and state currently continues to examine facility permit applications
  to determine whether to exercise the RCRA omnibus permitting authority to apply
  additional permit controls beyond those required under the current regulations.
  To ensure sufficient protection of human health and the environment, site-specific risk
  assessments (SSRAs) are being conducted. More than 50 SSRAs have been completed  or
  are under way at hazardous waste combustors across the country EPA understands that
  the State of Texas expects to perform risk assessments first on a selected and limited
  group  of hazardous waste combustors. They then intend to use these results, as
  appropriate, to set protective  permit conditions for the assessed facilities as well as for the
  remaining combustors if possible.
• In a joint action by U.S. EPA's Region 7 and the Kansas Department of Health and
  Environment, the first national permit to bum hazardous waste in cement  kilns was
  issued to the Ash Grove Cement Company in Chanute, Kansas, on August 15,  1996.
• The Agency has developed  a new Draft Protocol for Screening Level Human Health Risk
  Assessment (SLHHRA). The purpose of this document, which was drafted by Region 6,
  is to provide guidance to both regions and states on performing SLHHRAs for hazardous
  waste combustion facilities. Information on performing ecological risk assessments is
  provided in a companion document titled Draft Protocol for Screening Level Ecological Risk
  Assessments (SLERA). EPA expects that SLHHRA and SLERA reports, prepared in
  accordance with these guidance documents, will be used by the permitting authority
  to support permitting decisions for hazardous waste combustion units. The Agency
  anticipates having these documents out  to the regions and states for their internal peer
  review and comment by April 1,  1997.
Texas Industries Permit
Texas Industries, Inc.. (TX1),
operates four hazardous waste-
burning WL'L process cement kihis
At ii5 Midlothian, Texas, cement
piant. TXt's draft permit has been
strongly contested by local And
national environmental group:. io.r
several years. They allege that
emissions from TXHs wasie-
buming kilns have negative!1.'
affected human health and t'r.e
environment. Independent
studies by the Texas Naomi!
Resource Conservation
Commission and the Texas
Department of Health determined
that the kilns presented no
significant nsk. Due to the intense
public scrutiny, in. January 19%,
Region 6 assessed the cumulative
risk from TXI and three nearby
facilities. The results were below
the thresholds of concern,
however, Region 6 maintains
that fish monitoring provisions
should be included in the. TXT
Site permits..
                                                                                    Permitting Roundtables
                                                                                    During the summer of 1996, EPA
                                                                                    held two permitting roundtable
                                                                                    meetings to discuss issues that
                                                                                    developed from the proposed
                                                                                    combustor rule. EPA brought
                                                                                    together representatives of the
                                                                                    various stakeholders for an  open
                                                                                    dialogue concerning RCRA/CAA
                                                                                    interaction, permitting, and state
                                                                                    authorization. The meetings were
                                                                                    intended to help stakeholders
                                                                                    focus their comments on the
                                                                                    proposed rule and to give EPA
                                                                                    some idea of dieir key concerni
                                                                                    Representatives from industry,
                                                                                    EPA HQ, EPA regions/lnbs, states,
                                                                                    and federal facilities attended .k:
                                                                                    meetings. (Environmental group;
                                                                                    were invited, but none attended.)
                                                                                    EPA may consider holding a third
                                                                                    permitting roundtable meeting
                                                                                    later this spring to discuss further

  TH[ Director's Chair
  (Continued J'ram pa^e 1}

  chemicals and a report identifying
  the waste streams that contain
  these priority P8T chemicals art
  soon to be issued, later in 1997
  we will publish a measurement
  approach for determining
  reductions in waste streams that
  contain those PBTs.
  At the facility and community
  level, risk assessments have been
  completed or are in process at.
  over 50 facilities, with more
  planned for the near future. These
  risk assessments have turned out
  to be very important mtlesiOEtei
  tor the permitting agencies, the
  facilities, and the public.
  On the other hand, these risk
  assessments tend to lengthen the
  time to final permit decisions at
  some facilities. In my view, the
  ijnport^nce of risk assessments
  often justifies the dtlay. I am also
  pleased, however, to see thai local
  actions are.being taken 1.0 keep
  the-permittingprocess en track.
  For example, a dialogue between
  Region 6 and the State of Texas
  has led 10 an agreement on how
  to proceed with an overall
  permitting strategy that will lead
  to the fastest possible decision-
  making on key facility permit
  As I sasd in the last Update, it is
  truly invaluable lor EPA to have u
  continuing dialogue with all
  interested groups on the
  keystones of our Combustion.
  Strategy. Again, 1 urge you  to let
  the Agency know your views.
Waste Minimization  and  Pollution Prevention
 For More Information
         As OSW finalizes the MACT Combustion Rule, several efforts based on the goals
         and objectives of the Waste Minimization National Plan are encouraging waste
         minimization and pollution prevention (WM/P2) at affected facilities (including
combustors). EPA is (1) developing regulatory incentives for WM/P2 within the MACT rule,
(2) identifying opportunities for WM/P2 that apply to facilities generating streams sent to
combustion onsite, and (3) identifying overall waste minimization priorities.
•  Developing Regulatory Incentives in the MACT Rule—In its April 1996 proposal,
   EPA requested comment on several waste minimization approaches that could reduce the
   amount and/or toxicity of combusted wastes. These included proposals to require waste
   minimization planning for all facilities to identify measures to reduce the amount of
   waste combusted; require waste minimization planning on a case-by-case basis; and
   allow a case-by-case 1-year extension beyond the 3-year compliance deadline set in the
   Clean Air Act for facilities that need more time to plan and implement waste
   minimization measures. As an outgrowth of these options, EPA is also considering
   voluntary incentive-based options that would encourage companies to consider waste
   minimization measures as a means to achieve MACT standards. For example, EPA might,
   under the auspices of the Agency's audit policy, consider allowing companies to enter
   into compliance orders if they can demonstrate that they can meet MACT standards
   using waste minimization measures but need more than the 3 years plus a  1-year
   extension to complete the testing and installation of new approaches.
   These waste minimization incentives are intended to reduce the amount of persistent,
   bioaccumulative, and/or toxic (PBT) wastes, such as heavy metals, that are currently
   generated and combusted and the releases to the environment that result from
   combustion. Additional benefits may include a reduction in the use of raw materials and
   worker exposure to hazardous materials and wastes.

•  Identifying Process Opportunities—EPA has identified facilities impacted by the
   MACT combustion rule and is evaluating WM/P2 opportunities for waste streams
   generated at these facilities and combusted onsite. After assessing the costs of these
   opportunities and estimating the waste quantity reductions likely to be achieved, EPA
   plans to make this information available to facilities and the public.
•  Identifying Overall Waste Minimization Priorities—As one means of prioritizing
   waste minimization activities, OSW is developing products to help EPA regions, states,
   and others identify PBT chemicals in their RCRA hazardous waste (including wastes
   managed by combustion). These products include: a list of chemicals ranked based on
   the PBT criteria, a "cross-walk" between these chemicals and the RCRA hazardous waste
   codes that are likely to be associated with them, and a software tool automating the
   process of linking PBT chemicals with waste codes. OSW plans  to refine the products
   and make them available through the RCRA Hotline during spring 1997.

                                    These efforts involve coordination with state and
                                    regional regulators, plus extensive information
                                    exchange with representatives of impacted facilities
                                    and other stakeholders. EPA's goal is to incorporate
                                    a set of incentives into the MACT rule that
                                    encourage WM/P2 and to offer documents to
                                    generators on stream-specific waste minimization
 For more information, cail the RCRA Hotline at 800-424-9346 or TDD
 800-553-7672. The StnJU'gy Update is also available on the Internet.
 To access thss through the World Wide Web, type; http://www.epa.gov/
 epaoswer/hazwaste/combust/strat.txt. Please submit comments on the
 Strategy Update to Keely Clifford, editor, at cliflord,keely@epamail.epa.gov.

                         United States
                         Environmental Protection
                         Solid Waste
                         and Emergency Response
          December 1997
Welcome  to  the Waste
Minimization  National   Plan
                               Across the nation, a long-term national effort is under way to reduce the
                               quantity and toxicity of the most persistent, bioaccumulative, and toxic
                               (PBT) chemicals in the nation's hazardous waste. Minimizing waste can
                         reduce costs and regulatory burden, show environmental leadership, and improve
                         human health and the environment.

                          The U.S. Environmental Protection Agency (EPA) developed the Waste
                         Minimization National Plan with a goal of helping companies reduce the amount of
                         PBT chemicals in waste 50 percent by the year 2005. You can support this effort by
                         implementing source reduction techniques, facilitating environmentally sound recy-
                         cling, and preventing the transfer of chemical releases from one medium to another
                         (such as from water to air).

                          To help you learn more about how your company or facility can contribute to  the
                         nation's waste minimization goal, EPA has prepared several informational and tech-
                         nical publications. Most of these brochures, guidebooks, periodicals, and other
                         documents are available at no charge. They also are available on the Internet at
 Reducing Toxics m Our Ration's Ulaste
Want to Learn More?
4 Waste Minimization National Plan:
   Reducing Toxics in Our Nation's Waste
   (EPA530-F-97-010) is a short, easy-
   to-read, introductory brochure. It
   provides an overview of the goals
   of the Waste Minimization
   National Plan, the chemical focus to
   reach these goals, and the resources
4 The following series of fact sheets
   highlights specific companies that
   have successfully reduced the pres-
   ence of PBT chemicals in waste.
   Each fact sheet briefly profiles the
   company, its environmental
   achievements,  regulatory relief,
   implementation process, economic
   impact, and hurdles overcome.
    - Waste Minimization: Increased
      Profits and Productivity (Harris
      Corporation) (EPA530-F-97-020)
    - Waste Minimization: Reduction in
      Combustible Waste (FMC
      Corporation) (EPA530-F-97-021)
- Waste Minimization: Increased
 Profits and Productivity (PPG
 Industries) (EPA530-F-97-022)
- Waste Minimization: Reducing
 Releases of Chlorinated Solvents
 (Ford Motor Company) (EPA530-
- Waste Minimization: Relief From
 RCRA Large Quantity Generator
 Status (105th Airlift Wing, New
 York Air National Guard)
- Waste Minimization: Increased
 Profits and Productivity (Charles
 H. Lilly Company) (EPA530-F-
- Waste Minimization: Reducing
 Paint Waste Through Efficiency
 (General Motors Hamtramck
 Plant) (EPA530-F-97-026)
- Waste Minimization: Increased
 Profits and Productivity (HADCO
 Corporation) (EPA530-F-97-009)

  Strategy Update: A Newsletter on
  EPA's Hazardous Waste Minimization
  and Combustion Activities (EPA530-
  N-97-001) is a source for keeping
  up with the latest changes and pri-
  orities, significant milestones, and
  opportunities for public involve-
  ment associated with EPA's waste
  minimization and combustion
  Waste Minimization National Plan
  Kit (EPA 530-F-97-028) includes the
  first three items described in this fact
  sheet in an attractive folder.
^ The Waste Minimization
  Prioritization Tool, Beta Test Version
  1.0 (EPA530-C-97-003) is a flexible
  Windows-based software program
  that ranks chemicals according to
  their persistence, bioaccumulation
  potential, and human and ecological
  toxicity. It allows you to  rank specific
  chemicals based on PBT and chemi-
  cal quantity.
  Waste Minimization Prioritization
  Tool [WMPT], Beta Test  Version 1.0:
  User's Guide and System
  Documentation (EPA530-R-97-019)
  presents step-by-step guidance on
  installing and using the WMPT 1.0
  system to generate outputs that will
  aid in decisions about setting waste
  minimization priorities. This guide-
  book explains how to maneuver
  within the system, how to input
  data, and how to generate scores and
  formatted outputs.
   The Chemical-Waste Code Crosswalk
  (EPA530-D-97-005) consists of a series
  of tables, separated into wastewaters
  and nonwastewaters. It identifies the
  RCRA hazardous waste codes that
  potentially contain PBT chemicals.
 >  The Prioritized Chemical List
   (EPA530-D-97-004) is a relative
   ranking of 879 chemicals with data
   on their persistence, bioaccumula-
   tion, and toxicity. Designed as a
   flexible screening tool to help identi-
   fy priorities for the National Plan,
   this document ranks chemicals by
   their human health risk potential and
   their ecological risk potential.
 '  * Waste Minimization for Selected
   Residuals  in the Petroleum Refining
   Industry (PB97-121-180) provides an
   industry overview with process
   descriptions and presents options for
   source reduction practices for 29
   residuals of concern, including
   sludges, catalysts, and treating clays.
   Both source reduction and recycling
   techniques are described in this
   *International Waste Minimization
   Approaches and Policies to Metal
   Plating (PB96-196-753) provides an
   industry overview, a description  of
   metal plating processes, a characteri-
   zation of waste streams produced,
   suggestions for waste minimization
   and pollution prevention techniques,
   and tools for  evaluating pollution
   prevention  opportunities.

For  Information or
 Call the RCRA Hotline at
800 424-9346 or TDD 800 553-7672.
In the Washington, DC area call
703 412-9810 or TDD 703 412-3323.
 * To order  these two documents, please
call NTIS at 703 487-4650.

                           United States
                           Environmental Protection
                    Solid Waste
                    and Emergency Response
         EPA 530-F-97-009
         August 1997
Waste  Minimization:
Increased  Profits and
HADCO  Corporation
    SUM Investment;
Payback in 3 Years

 _ Eliminated Continuous

    Eliminated Disposal of
800,000 Pounds of

If you don't factor in the cost
of those releases going up
your stack or out your dis-
charge or out in bulk ship-
ments for off site treatment
and disposal then you don't
really have a good apprecia-
tion for the actual costs of
 What is the HADCO

    HADCO Corporation is one of
 the nation's largest manufacturers of
 printed wiring boards, the funda-
 mental building blocks of all elec-
 tronic components. Common uses
 include computers, telecommunica-
 tions, medical devices, and automo-
 tive components. The complex,
 multi-step manufacturing process
 requires many hazardous solvents,
 including 1,1,1-trichloroethane
 (TCA) and methylene chloride.

 What Did They Accomplish?

    Through their continued efforts
 in waste minimization, HADCO has
 succeeded in reducing both releases
 and transfers of toxic chemicals tar-
 geted in EPA's 33/50 program by
 99.5%. As a result, the facility saves
 $600,000 per year in avoided chlori-
 nated solvent purchases and associ-
 ated disposal costs.


    HADCO's achievements at the
 Derry New Hampshire facility
 occurred in two stages. First, they
 implemented a solvent recovery sys-
 tem on two of the five production
 lines that used methylene chloride.
 At the same time, they eliminated
chlorinated solvents from the other
three production lines. In the second
stage, HADCO eliminated TCA and
methylene chloride completely from
all five production lines by switch-
ing to aqueous solvents such as

   Elimination of chlorinated sol-
vents has impacted more than just
air and water emissions: annual dis-
posal of 800,000 pounds of spent
methylene chloride has also been
eliminated. Prior to implementing
the program, HADCO was the
largest environmental polluter in
New Hampshire. These achieve-
ments have greatly improved public
relations, and moved HADCO
down the list of New Hampshire's
pollution generators.

Regulatory Relief

   To meet regulatory requirements
for the solvent recovery system,
HADCO was required to install a
continuous emissions monitoring
system (CEMS) and to produce
monthly reports. The CEMS gener-
ated high maintenance and opera-
tional costs. Once the solvent recov-
ery system was discontinued, the
costly CEMS was no longer

   Eliminating chlorinated solvents
reduced regulatory burdens associ-

          nnirnization: increase'
 HADCO Corporation
ated with several environmental

    • Clean Air Act — eliminated
     solvents were targeted for
     phase out;

    • Emergency Planning and
     Community Right-to-Know
     Act — eliminated solvents
     were reportable under Section

    • Resource Conservation and
     Recovery Act — eliminated
     solvents were regulated as haz-

The Implementation Process

    Impetus for the initial solvent
recovery system and later for the
elimination of TCA and methylene
chloride primarily came through
HADCO's senior management.
They thought HADCO should be
"...number one in making circuit
boards, not number one in Toxic
Release Inventory releases." Both
approaches were developed in
house, involving site engineers and
the corporate vice president of engi-
neering. Implementation of the ini-
tial solvent recovery system required
about a year from inception to exe-
cution, though Mr. Wilmot, Manager
of Corporate Safety, Health, and
Environmental Affairs, noted that
obtaining air and water permits cre-
ated the biggest delays. Once the
recovery system was implemented,
workers needed to be trained in
operating the CEMS. Afterward,
HADCO phased out chlorinated
chemicals from all production lines.

    HADCO monitored effectiveness
of the systems in two ways:
     duction and costs of chemical
     purchasing; and

   • Chemical monitoring of both
     raw material inputs and efflu-

Economics:  Costs and

   Funding for these improvements
came from internal sources. While
Mr. Wilmot noted that there is typi-
cally internal competition for capital
improvement projects, funding for
these improvements was non-discre-

   HADCO invested $1.7 million in
the project, which covered the cost
of installing the initial solvent recov-
ery system on two production lines
and the cost of converting all five
chlorinated solvent-using lines to
aqueous solvents.  This included
equipment purchase, installation
and labor.

   Payback for these activities came
within three years, and resulted pri-
marily from HADCO no longer
spending $600,000 per year on chlo-
rinated solvents.  There were no
reductions in disposal costs - in fact,
before implementing these changes,
spent methylene chloride was
shipped off site at no  charge for
recovery. The current aqueous sol-
vents annually generate 200,000
pounds of sludge that HADCO must
pay to have disposed as hazardous

    Implementation of these changes
presented no major hurdles. The
most difficult problem with the sol-
vent recovery system was getting
across the fact that when the CEMS
malfunctioned, production had to be
stopped.  This required a significant
behavioral change in a plant that
operates continuously. This behav-
ioral change was only temporary,
since elimination of the chlorinated
solvents also eliminated the need for
the CEMS.  There were no negative
impacts to the quantity and quality
of goods produced.

Words to the Wise

   Lee Wilmot cautions those con-
sidering implementation of waste
minimization projects to look closely
at their cost accounting systems.
"Total cost accounting is what is sell-
ing pollution prevention and waste
minimization. But if you don't fac-
tor in the cost of those releases going
up your stack or out your discharge
or out in bulk shipments for off site
treatment and disposal, then you
don't really have a good apprecia-
tion  [for the actual costs of pollu-
tion]. If all you're focusing on is
how much  it costs to operate your
solvent recovery system or waste-
water treatment system, or trans-
porting that waste to the end site,
you've missed a big, big part of your
cost  of operations."

    • Cost accounting, which exam-
     ined operational costs of pro-
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                           Reducing loacs m Our Datum's UJaste

                            United States
                            Environmental Protection
                    Solid Waste
                    and Emergency Response
         EPA 530-F-97-020
         August 1997
Waste  Minimization:
Increased  Profits and
Harris Corporation
• S125K Savings

    Exempted from CAA
and EPCRA Section 313

Implementing small projects
that demonstrated the result-
ing savings to management
established credibility and
opened the door to greater
funding for waste minimization
 What is the Harris

    The Broadcast Division of Harris
 Corporation manufactures radio and
 television transmitters. Their manu-
 facturing process released several
 hazardous air pollutants and haz-
 ardous chemicals such as 1,1,1
 trichloroethane (TCA), rnethylene
 chloride, and methyl ethyl ketone
 that were used as cleaning solvents,
 thinners, and degreasers.

 What Did They Accomplish?

    Harris implemented a broad
 range of waste minimization initia-
 tives that reflect the company's envi-
 ronmental policy. Harris' savings
 resulting from all of its waste mini-
 mization efforts total about $125,000


    Harris' pollution prevention and
 waste minimization program is
 broad in scope and has enjoyed
 numerous successes...

    • Alteration of the paint mixing
     process to a batch process
     reduced wastes from 1/4 gal-
     lon to less than a cup per
     batch, contributing to a reduc-
     tion in waste paint generation
    from 3,000 gallons per year to
    about 900 gallons per year.

   • Installation of a solvent distil-
    lation unit also contributed to
    waste paint reduction.

   • Replacement of TCA with iso-
    propyl alcohol during circuit
    board cleaning eliminated
    waste TCA.

   • Replacement of rnethylene
    chloride in the vapor degreaser
    with an aqueous solution elim-
    inated 25,000 Ibs. of air emis-
    sions per year.

   • Implementation of a closed-
    loop water supply for a spot
    welder cut water use.

   • Replacement of an old, larger-
    than-necessary compressor
    reduced overall energy con-
    sumption by 4%.

   • Replacement of two 45 kw
    water heaters with a single gas
    heater slashed energy use.

Regulatory Relief

   Because they eliminated rnethyl-
ene chloride from their vapor
degreaser, Harris avoided the need
to apply for a Clean Air Act (CAA)
Title V Permit and is not subject to
Emergency Planning and
Community Right-to-Know Act

 Waste Minimization: Increased Profits and Productivity
 Harris Corporation
(EPCRA) Section 313 requirements.
The company is now on its way to
being regulated as a RCRA small
quantity generator. Also, by not
using chlorofluorocarbons or Class I
ozone depleting substances, Harris
avoided the mandatory labeling
requirements under the CAA.  The
elimination of methylene chloride
obviated the need for additional
ventilation in the metal finishings
The Implementation Process

   The driving force behind imple-
mentation of Harris' environmental
efforts was a corporation-wide
emphasis on the need for quality
environmental compliance. As those
efforts matured, Harris transited
from a regulatory-based approach to
waste minimization and pollution
prevention, whereby the environ-
mental health and safety organiza-
tions contribute to the company's
bottom line.

   Harris continuously evaluates its
waste streams and processes, and
performs annual formal evaluations
to develop three-year, rolling strate-
gic plans.  Pollution prevention and
waste minimization efforts are incor-
porated into the business unit's
overall annual operating plan. The
plan is considered a living docu-
ment and its goals are subject to
change. Current goals are to:

   • Reduce solid and hazardous

   • Continue compliance with
     environmental safety regula-
   • Reduce toxicity of metal finish-
     ing chemicals;

   • Reduce utility costs by 10% per
     year; and

   • Increase quality.

   Most ideas were generated in
house. However, when the compa-
ny eliminated its methylene chloride
vapor degreaser and switched to an
aqueous degreaser, it contacted the
Illinois technical assistance program
for an analysis of available aqueous

Economics: Costs and

   Reductions in paint waste have
resulted in enough savings to pay
for the changes several times over
since 1992.  Reduction  in water con-
sumption resulting from implement-
ing a closed loop system on the spot
welder has saved about $14,000 in
water and sewage fees per year, cut-
ting the division's annual water
costs by 15%. The spot welder pro-
ject paid for itself in less than three
months. Savings in the electric bill
resulting from replacement of the
oversized compressor are about
$20,000 per year, representing 4% of
the division's electric bill.
Replacement of the two 45 kw water
heaters saves $5,100 per year.


   The biggest difficulty was in
securing project funding from upper
management. Manager of Facilities
and Environmental Compliance
Andy Edgar's solution was to estab-
lish the necessary credibility for
obtaining project funding. He
accomplished this by implementing
small projects that targeted "easy
money" and demonstrated the
resulting savings to management.
This established credibility and
opened the door to greater funding.

Words to the Wise

   Mr. Edgar advises that managers
wishing to implement waste mini-
mization focus on trying to add
value to the company. This helps to
keep the projects from being viewed
as a necessary evil.

   In addition, he is a proponent of
tapping non-management employ-
ees who "...have a thorough knowl-
edge of their job, and credible ideas
of how to develop and implement
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                           Reducing Tones m Our IMion's llbste

                            United States
                            Environmental Protection
                    Solid Waste
                    and Emergency Response
         EPA 530-F-97-021
         August 1997
Waste  Minimization:
Reduction  in  Combustible
FMC Corporation
    $14,800 Initial
Investment; Payback in Less
Than 1 Year

    Eliminated Need to
Incinerate Spent Solvents

    Relief from EPCRA
Section 313 SCAA

"Draw on the experience of
employees who work in the
area,  (they) know if some-
thing will work, or will have
valuable input."
 What is FMC Corporation?

    FMC's Naval Systems Division
 is a defense contractor in
 Minneapolis, Minnesota. Their
 work revolves primarily around the
 design and production of military
 equipment.  Before implementing
 their waste minimization programs,
 FMC generated about 8,250 gallons
 of spent 1,1,1,- trichloroethane
 (TCA) annually. FMC used this sol-
 vent for a variety of common clean-
 ing applications including over-
 hauled valve housings, large metal
 parts prior to painting, electrical
 components, dewaxing of metal
 prior to plating, and a variety of
 maintenance uses.  Various grades
 of spent solvent were being generat-
 ed.  Final disposal of these solvents
 typically required incineration.

 What Did They Accomplish?

    In 1989, FMC implemented an
 in-house recycling program that
 allowed 142 of the 150 drums of
 spent solvent generated annually to
 be recycled at the facility. Then, in
 1991, FMC topped that by eliminat-
 ing the use of TCA altogether, and,
 therefore, the need to incinerate
 spent solvents.

   The recycling system was only
in operation for one year before
FMC eliminated TCA. While it was
running, the recycling system's
capacity was approximately 150
drums of solvent for that year.
Helen Addies, Environmental
Engineer, points out that this
amount might have increased over
time to a higher annual average, had
the system been used longer.

   Since 1991, when TCA was elim-
inated, there has been a company-
wide change in attitude; currently,
FMC disposes of wastes only when
there is no alternative use for the
waste. They are constantly in search
of ways to divert flow away from
the waste stream and reduce waste
volume. To this end, FMC now
places HazMat codes on various
chemicals in an effort to track their
use and ultimate destination, with
the goal of eliminating as much
waste as possible, either through
minimization or recycling.

   In addition to its efforts to
reduce TCA, FMC has actively pur-
sued several other waste minimiza-
tion opportunities. For instance:

   • FMC has reduced its use of
    chemicals targeted by EPA's
    33/50 program, such as methyl
    ethyl ketone

 Waste Minimization: Reduction in Combustible Waste
 FMC Corporation
   • EMC is always looking for sub-
     stitutes. Working with the mil-
     itary makes this difficult, since
     there are often stringent speci-
     fications that preclude the use
     of substitute materials or
     process changes. As a result,
     FMC has emphasized reusing
     materials.  For example, FMC
     reuses foundry sand generated
     on-site.  In 1995, they sold
     about 78,000 Ibs. to an asphalt
     company, which earned FMC
     an EPA WasteWi$e leadership

   There have also been many less-
tangible benefits. For instance, FMC
has improved its community and
public relations through the receipt
of numerous pollution prevention
Regulatory Relief

   Due to its efforts, FMC earned
relief from Emergency Planning and
Community Right-to-Know Act
(EPCRA) Section 313 reporting
requirements in 1995, resulting in
less data collection, recordkeeping
and reporting.  In addition, FMC
eliminated TC A use well ahead of
the phase-out schedule established
by the Clean Air Act (CAA)
The Implementation Process

   FMC's environmental depart-
ment designed the original recycling
system and the method for eliminat-
ing TCA with input from several
other areas within the company.
This was a team effort including
both engineers and people who
actually worked with TCA. Ms.
Addies notes: "Quite a few of our
people were ardent environmental-
ists, which helped quite a bit."
Workers did need some training,
first to run the recycling system, and
then to adjust to working without

   The recycling project took about
six months from conception to
implementation.  FMC phased out
TCA entirely within three years (two
years after implementing the recy-
cling system). Installation initially
affected production, but the prob-
lems were quickly solved. Quality
was not affected.

   To monitor the success of the
recycling system, FMC utilized
chemical tracking and cost-
accounting systems. These systems
were already in place, although
FMC purchased software upgrades
to improve accuracy.

Economics: Costs and

   FMC  funded these projects inter-
nally, and there was no competition
from other projects  at the time.
Retrofitting the vapor degreaser into
a solvent recycling center represent-
ed the primary initial cost of $14,800.
Ms. Addies estimated operating
costs of the recycling  center to be
approximately $15,000 during that

   As a payback for their efforts,
FMC realized a return on their
investment in the recycling system
in 3 to 4 months. Later, elimination
of TCA resulted in significant sav-
ings in time and disposal and pur-
chasing costs. It also facilitated CAA
compliance, as TCA is on the list of
chemicals to be phased out. Ms.
Addies estimates total savings
resulting from TCA elimination to
be approximately $100,000.


   No significant hurdles presented
themselves when FMC implemented
these measures. A few management
and labor issues arose; however,
they were quickly resolved.

Words to the Wise

   Ms. Addies passes on one piece
of advice to those thinking of imple-
menting waste minimization and
pollution prevention at their own

    "Draw on the experience of
employees who work in the area,
(they) know if something will work,
or will have valuable input."

   She added that employees often
have considerable outside knowl-
edge that could be useful for project
development  and implementation.
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                           Reducing Tones m Ourlkboris Waste

                            United States
                            Environmental Protection
                    Solid Waste
                    and Emergency Response
         EPA 530-F-97-022
         August 1997
Waste  Minimization:
Increased Profits  and
PPG  Industries
    2 Year Return on
    320,000 Gal.,
Reduction in incinerated
    Fewer Reporting
Requirements and Less Legal
Publicity is important even if
only in internal publications.
Increased awareness serves
as a springboard for more pro-
 What is PPG Industries?

    The automotive coatings plant of
 PPG Industries, Inc. (PPG), located
 in Cleveland, Ohio, manufactures
 both solvent-based and water-based
 coatings. Prior to 1992, PPG used
 thousands of liters of water each
 week to clean manufacturing equip-
 ment and incinerated a large vol-
 ume of wastewater contaminated
 with methyl isobutol ketone, butyl
 cellosolve, and lead.

 What Did They Accomplish?

    In 1992, PPG designed and
 installed a combined ultrafiltra-
 tion/reverse osmosis (UF/RO)
 process to recycle wastewater. By
 combining the two membrane-based
 technologies, PPG was able to utilize
 a progressive filtering system that
 cleaned the wastewater to a level
 suitable for reuse in equipment
 cleaning operations. As a result,
 PPG has cut the volume of haz-
 ardous waste requiring incineration
 from 400,000 gallons per year to
 80,000 gallons per year and saves
 $205,000 annually.


    PPG received a National
 Industrial Competitiveness through
 Energy, Environment and
Economics (NICE3) grant from the
U.S. Department of Energy (DOE)
and worked cooperatively with the
State of Ohio to promote the UF/RO
cleaning technology. The UF/RO
system reduces the volume of waste
disposed by about 80%, depending
on the level of production.  This
experience serves as one example of
how a successful partnership
between government and industry
can foster waste reduction.

   Another major achievement of
this project was the increased aware-
ness of waste minimization that
grew throughout the company. This
awareness was due in part to the
publicity the company received
through NICE3. The increased
awareness served as a springboard
for development and implementa-
tion of more projects. PPG has
undertaken numerous projects at all
of its approximately 15 facilities
located in nine countries. The corpo-
ration as a whole openly embraces
waste minimization as a major goal.

Regulatory Relief

   Though PPG's regulatory status
has not changed, less waste means
fewer opportunities for spills, acci-
dents and violations and therefore
fewer legal liabilities.

 Waste Minimization: Increased Profits and Productivity
 PPG Industries
The Implementation Process

   Design of the UF/RO process
was accomplished by an in-house,
cross-functional team comprised of
environmental managers, produc-
tion managers, and other staff work-
ing with outside consultants who
provided expertise on UF/RO.

   Because the system was new,
three operators received training
during one session.  From concept to
implementation, the process took
about eight months.

   PPG has not altered the UE/RO
system since its inception in 1992.
The system has in no way impeded
manufacturing or lowered  product
quality.  PPG has measured the suc-
cess of the process by analyzing
reductions in waste using in-house
measurement tools.
agement and technical issues arose;
however they were quickly resolved.

Words to the Wise

   PPG is enthusiastic about waste
minimization and environmental
stewardship, especially considering
the positive publicity that came from
the UF/RO  process.
Economics: Costs and

   PPG received funding from DOE
and the Ohio Department of Energy.
In addition, PPG contributed an ini-
tial capital outlay of over $200,000.
Annual operating costs for the unit
are estimated at $175,000.

   Annual savings resulting from
the project have remained fairly
steady at a level of $205,000, equal to
$380,000 worth of savings in water
disposal costs less the $175,000 in
operating costs.  The investment
paid for itself in just over two years.


   No significant hurdles presented
themselves when PPG implemented
these measures. A few minor man-
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                         NATIONAL PLAN
                                         Reducing Tones in Our Ratal's UJaste

                            United States
                            Environmental Protection
                    Solid Waste
                    and Emergency Response
         EPA 530-F-97-023
         August 1997
Waste  Minimization:
Reducing Releases  of
Chlorinated Solvents
Ford  Motor  Company
   , Reduction in Releases
of Chlorinated Solvents

    Avoided CAA Reporting
   , Design Change Was
Waste Minimization

It is comparatively easy to
implement a waste prevention
project early in the  design
process as opposed to trying
to work changes in  later.
"Doing it right the first time is
always easier and cheaper
than retrofitting later!"
 What Does the Ford
 Ypsilanti Plant Do?

    The Ypsilanti plant (just outside
 of Detroit, Michigan) manufacturers
 starters for Ford products.
 Originally, the plant manufactured a
 "field-wound" starter. In 1991, a
 new product, called a "permanent
 magnet" starter was introduced as
 part of an ongoing effort to improve
 product quality. The new starter
 was smaller than the field-wound
 type, thereby reducing the weight of
 the part and the vehicle. In addi-
 tion, the new starter replaced a cop-
 per ring with tubing, which elimi-
 nated a welding step and reduced
 the need for cleaning.

 What Did They Accomplish?

    The Ypsilanti plant was sched-
 uled to undergo a design change to
 phase out the field-wound starter
 and phase in the permanent magnet
 type. This design change necessitat-
 ed the purchase of new equipment.
 Ford used this opportunity to evalu-
 ate possible changes to reduce or
 eliminate the use of chlorinated sol-
 vents. The end result? Ford esti-
 mates that over 30,000 pounds of
 trichloroethylene (TCE) and about
 5,000 pounds of methylene chloride
 releases are being eliminated annu-

   At the time of the product
change, the plant was participating
in EPA's 33/50 Program and in
Michigan's Great Lakes Auto
Project.  Both programs had lists of
hazardous chemicals targeted for
reduction; each list included TCE
and methylene chloride.

   The design change was a perfect
opportunity for the plant to demon-
strate its support for these voluntary
environmental programs while
improving product quality.

   When the new starter was being
developed, manufacturing engineers
replaced the methylene chloride and
TCE-based cleaning and drawing
chemicals with a water-based com-
pound.  This change eliminated
TCE and methylene chloride releas-
es and the plant no longer disposes
of liquid hazardous waste from the
dip tank.

Regulatory Relief

   At the time the project was
implemented, the Clean Air Act's
(CAA) permitting requirements
were not in place. The plant phased
out the use of these two chlorinated
chemicals just before the regulation
became effective. The chlorinated
solvent phase-out saved the plant

 Waste Minimization: Reducing Releases of Chlorinated Solvents
 Ford Motor Company
from having to report on the two
chemicals under the CAA.
The Implementation Process

   The Ford Ypsilanti plant's busi-
ness and product cycles routinely
include consideration of environ-
mental issues. In doing so, the
plant's manufacturing engineers
developed the approach to the chlo-
rinated solvent reduction project.
Staff had to be acquainted with the
new solvents, but this was only a
small part of the overall training that
employees received to adapt to the
plant's overall design change.

   The design change took about
two years to complete. To measure
success of the project, the plant uses
standard cost accounting procedures
and tracks overall solvent use.

   The project was incorporated
into the design change budget,
which used funds set aside for new
product development. The design
change cost Ford Motor Co. about
$50 million, but the percentage of
that amount spent on the process to
eliminate the use of chlorinated sol-
vents is unknown.

   The plant used to spend approxi-
mately $45,000 on chlorinated sol-
vents annually. The current expen-
diture on water-based solvents is
approximately $20,000, for a total
raw material annual savings of
$25,000. In addition, the plant no
longer pays to dispose of the haz-
ardous liquid waste from the dip

   The solvent change caused
minor disruptions in manufacturing
for a short time and caused a few
minor technical problems. The plant
overcame these problems by con-
sulting the solvent suppliers and the
manufacturing engineers, and sim-
ply by becoming familiar with the
new water-based materials.

Words to the Wise

   Phil Lawrence, Principal Staff
Engineer from Ford's Environmental
Quality Office, and Jim Luckhardt,
Ford Environmental Engineer, are
quick to acknowledge how well the
solvent change fit into the plan for
the plant's design change. They
stressed the comparative ease of
implementing any waste prevention
project early in the design process as
opposed to trying to work changes
in later.

   "Doing it right the first time is
always easier and cheaper than
retrofitting later!" - Phil Lawrence
                                          NATIONAL PLAN
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                          fteduong Tones in Our nation's IMe

                           United States
                           Environmental Protection
                   Solid Waste
                   and Emergency Response
         EPA 530-F-97-024
         August 1997
    Changed RCRA
Generator Status from
Large Quantity to Small
    Significant reductions
in costs

    Developed Teamwork
& Trust Throughout the Base

"Don't reinvent the wheel.
Recognize that others have
done this successfully. Realize
that you're not alone out there,
and apply others' ideas to your
Waste Minimization:  Relief
from RCRA Large Quantity
Generator Status
105th  Airlift Wing,  New
York Air  National  Guard
 What is the 105th Airlift

    The 105th Airlift Wing is an Air
 National Guard Base in Newburgh,
 New York. Work at the base
 revolves around the enormous C-5
 Galaxy, a plane used to transport
 military personnel and their equip-
 ment. The Wing uses solvent sinks
 for cleaning and degreasing the C-
 5s.  Many different solvents are
 used at the base, such as PD 680, oil
 degreasers and defoamers, methyl
 ethyl ketone, and light paint thin-
 ners. The Wing also uses several
 types of detergents that may contain
 light oils, paraffin waxes, or linseed
 What Did They Accomplish?

    The 105lh Airlift Wing, formerly
 regulated under RCRA as a Large
 Quantity Generator (LQG), has
 recently achieved the less regulated
 status of Small Quantity Generator

    The group achieved its SQG sta-
 tus through the acquisition of aque-
 ous-based parts washers and
 through elimination of some solvent
 sinks and downsizing of others.
The new parts washing solvents are
not hazardous under current regula-
tions and output from the washers
is 96 to 99% pure steam, alleviating
the need for further emission con-
trols. Total waste generation is very
small, to the point where it is diffi-
cult to quantify, but can be estimat-
ed at approximately one pound per
year of solid waste and three gallons
per year of liquid waste. This
amount is in contrast to much larger
volumes, which Master Sergeant Jan
Brown, Chief of Bio-Environmental
Engineering Services, could not
quantify but classified as "...enor-
mous... highly significant."

   Another major benefit of the
program was the development of
teamwork and trust between the
environmental managers and per-
sonnel from throughout the base.
Because of the success of these pro-
grams, environmental managers
have gained credibility, allowing
them to continue environmental
efforts in other areas.
Regulatory Relief

   Having achieved SQG status, the
105th Airlift Wing enjoys fewer and
less stringent reporting and record-
keeping requirements.  In addition,
the 105th Airlift Wing has reduced
the use of Emergency Planning and
Community Right-to-Know Act

 Waste Minimization: Relief from RCRA LOG Status
 105'" Airlift Wing
(EPCRA) Section 313 chemicals to
the extent that it no longer must
submit Form Rs. The reduction in
labor hours formerly used to pre-
pare Form Rs saves money for the

The Implementation Process

   The idea to replace and down-
size solvent sinks originated from
several sources, including EPA, the
Occupational Safety and Health
Administration (OSHA), Surgeon
General bulletins, the Air Force
Center for Environmental Excellence
(AFCEE), and EPA-Air Force "Cross
Talk" newsletters and conferences.
In addition, many ideas originated
in house, thanks to a quality initia-
tive that motivated personnel. The
Hazardous Materials Pollution
Prevention (HMP2) Team reduced or
eliminated solvents in all areas
where they were used. Seven to 15
sinks were eliminated from various
functional areas within the base, the
smallest being approximately 25 gal-
lons and the largest about 300 gal-

   As part of the process, the Wing
purchased new equipment to test
oil, Halon, refrigerants, and
antifreeze, a reclamation system
used to capture airplane de-icing
materials, and jet washers to replace
the solvent sinks. An engineering
company supplied the jet washers,
which were, in essence, "glorified
dishwashers." The manufacturer
installed the washers and trained
personnel on their use.
Economics: Costs and

   Waste minimization efforts have
resulted in significant reductions in
costs that are tracked monthly and
reported quarterly to Command.
Savings have generated positive
feedback from commanding officers.
Much of the money saved through
waste minimization efforts is
returned to the base for uses that
include recreation equipment.


   At the program's inception, per-
sonnel expressed general skepticism
and resistance. However, environ-
mental managers welcomed the
input of workers and empowered
them in project development.  As a
result, acceptance increased rapidly.
Now, Master Sergeant Brown
explains, staff members regularly
approach him with new waste mini-
mization ideas.  The 105'h Airlift
Wing also implemented an electron-
ic bulletin board that staff can use to
point out base activities that are can-
didates for waste minimization.

Words to the Wise

   Master Sergeant Brown recom-
mends getting all levels of staff,
especially those doing the actual
work, involved.  "...That's been our
success story ... solicit people's
ideas, and let them learn  by doing ...
give them a real stake in the process,
as opposed to making a 'token
effort' to obtain their involvement.
Allowing workers to become key
players can be integral to the pro-
gram's success."  Master Sergeant
Brown also cautioned others:  "don't
reinvent the wheel." He stressed
that those beginning programs
should recognize that others have
done this successfully. Realize that
"you're not alone out there," and
apply others' ideas to your needs.
For more information about the Waste Minimization National Plan, call {800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                          Itetoig loses mlr (ton's IMe

                            United States
                            Environmental Protection
                    Solid Waste
                    and Emergency Response
         EPA 530-F-97-025
         August 1997
Waste  Minimization:
Increased  Profits  and
Charles  H.  Lilly  Company
    $100,000 Investment;
Payback in 1 Year

    Savings in 1) Energy
Use; 2) Staff Hours; and 3)
Disposal Costs

    Changed RCRA
Generator Status from
Large Quantity to Small

   The system paid for itself
within the first year, and has
continued to provide us a
boost every year since then.
 What is the Charles H. Lilly

    Charles H. Lilly Company, in
 Portland, OR, is a major batch for-
 mulator and distributor of herbi-
 cides, insecticides, and fungicides in
 the Pacific Northwest. Its main
 plant generates hazardous waste-
 water when batch formulation tanks
 and transfer lines are cleaned for
 product changeovers. Lilly's waste-
 water contains organic solvents,
 detergents, and pesticides.

 What Did They Accomplish?

    Lilly implemented an on-site
 wastewater reuse process involving
 waste segregation, solvent extrac-
 tion, filtration, wastewater reuse,
 and minimal waste concentrate dis-
 posal. They now reuse approxi-
 mately 95% of their wastewater and
 have cut waste concentrate disposal
 to about 5%. As a result of these
 efforts, Lilly is no longer considered
 a Large Quantity Generator (LQG)
 under the Resource Conservation
 and Recovery Act (RCRA).


    Prior to implementing the pro-
 gram, Lilly produced about 550 gal-
 lons of hazardous wastewater per
 month.  Disposal was off-site
through evaporation, solidification,
and incineration.  They now gener-
ate about 30 gallons per month.

   Since inception of the program
in 1989, Lilly also has replaced toxic
constituents (e.g., atrozenes and tri-
ozenes) with ingredients that are
less toxic and achieve the same for-
mulation requirements. Lilly also
implemented a closed-loop system
for non-hazardous wastes and
strives to overcome the need for
storage drums on site. Instead, Lilly
uses items like round-trip contain-
ers, which reduce drum-washing
needs, generate less waste, and
lessen the handling of hazardous

   One additional achievement has
been an increase in company pride
and environmental stewardship
among employees.

Regulatory Relief

   As a result of its efforts, Lilly is
no longer an LQG, and, therefore, is
subject to fewer and less stringent
reporting and recordkeeping

The  Implementation Process

   Four people were key to success-
ful implementation: the facilities
manager, the environmental manag-
er, a chemist, and  the equipment

 Waste Minimization: Increased Profits and Productivity
 Charles H. Lilly Company
supplier. The system they put in
place necessitated a change in
employee behavior.  In the past,
approximately 80 hours per week
were required to collect wastes in
drums, and label and separate them
for evaporation. With the newer
system, liquids are simply trans-
ferred directly to influent holding
tanks. A handling job that took 80-
hours per week was reduced to 20-
25 hours.

   To monitor the effectiveness of
the waste management process, Lilly
used two tools:

   • Chemical QA/QC to monitor
     system performance: Lilly sent
     influent and effluent samples
     to an off-site lab for analysis,

   • Cost accounting:  focused on
     savings in energy use and in
     disposal costs.

   Once Lilly personnel decided to
implement the process, the project
took about six months to finish.
Lilly continues to use the filtration
system today.

Economics: Costs and

   Lilly paid for this project on its
own. Funding faced competition
from other projects within the com-
pany, resulting in implementation

   Lilly invested $100,000 in the sol-
vent recycling system. This included
everything:  the system itself, influ-
ent and effluent tanks, carbon filters,
piping, monitoring, and certification
for construction of the secondary
containment system.
   The initial investment for
QA/QC monitoring involved send-
ing samples to an off-site lab for
influent and effluent analysis.
Monitoring costs $2,000 to $3,000 up
front and $100 to $200 per month.

   Savings have occurred in three
areas: energy use, staff hours, and
savings from reduced disposal costs.
During the first year, the waste man-
agement system accrued savings in
these three areas totaling just under
$100,000. This made for a payback
period of about one year.

   Though Lilly continues to enjoy
reduced costs and labor-hour
requirements associated with haz-
ardous waste handling, the savings
resulting from avoided disposal
costs has dropped from levels
achieved during the inaugural year.
This is due largely to the fact that
other hazardous waste reductions
lessen the need for  the filtration sys-
tem. The savings now are approxi-
mately $30,000 to 45,000 per year in
avoided disposal costs and materials

    "The system paid for itself
within the first year, and has
continued to provide us a boost
every year since then." - Nick
Williams, Environmental


   Lilly experienced very few hur-
dles while implementing waste min-
imization. During  construction,
manufacturing was disrupted
briefly. Once installed, the process
required changes in employee
behavior and functions. While oper-
ators faced a learning curve, there
was no resistance from personnel.
In addition, there were no negative
impacts on either the quality or
quantity of products.

Words to the Wise

   Brent Jorgenson, Lilly's former
environmental manager who was
instrumental to the success of this
effort, asserts that companies hoping
to initiate waste minimization pro-
jects should keep an open mind to
all alternatives that might fit that
facility. He claims that, "...while it
may seem easier to take an "off-the-
shelf" system and try to retrofit your
facility, this is probably not the best
approach. What companies should
do is examine their processes closely
and keep an open mind."

   Jorgenson also recommends
spending time  and  effort up front in
getting management involved.

   Both Jorgenson  and Williams
attribute much of their success to
empowering and involving those
people who work "in the trenches."
They are closest to the work, can be
a rich source of ideas, and can pro-
vide valuable input into design and
implementation phases.
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                           Reducing Tows in Our IMiorisUJastfi

                           United States
                           Environmental Protection
                   Solid Waste
                   and Emergency Response
         EPA 530-F-97-026
         August 1997
   I Reduction in VOC and
Sludge Emissions

    $85K Savings

    Fewer Potential Legal

This is a perfect example of
how waste minimization can
often be very simple - it is
just a matter of paying atten-
tion to details, fine-tuning,
and maximizing small opportu-
nities for change
Waste Minimization:
Reducing  Paint Waste
Through  Efficiency
General  Motors
Hamtramck Plant
 What Does the GM
 Hamtramck Plant Do?

    The General Motors Hamtramck
 plant (Detroit and Hamtramck,
 Michigan) manufactures and paints
 various GM automobiles. At the
 time this project occurred, the
 Hamtramck facility was responsible
 for the production of flagship cars in
 the Cadillac line: the DeVille,
 Seville, and Eldorado.

 What Did They Accomplish?

    Constantly looking for ways to
 improve product quality and reduce
 waste, the plant recognized that its
 primer surfacer application could be
 improved.  In particular, the jets
 were spraying paint for several frac-
 tions of a second after the target
 automobile had moved out of range.
 By changing the timing, an even
 coat of paint was applied while
 waste was slashed. The end result
 was a reduction of 5.5 tons of
 volatile organic compounds (VOC)
 emissions and four tons of paint
 sludge per year.


    Although the timing of the paint
 jets was adjusted by mere fractions
 of a second, the tremendous volume
on which the plant operates meant
that these simple changes yielded
significant results. Adjusting the
jets by varying increments resulted
in the plant reducing 3,000 gallons
of primer waste annually (which
contained toluene, xylene, methanol
and butyl cellosolve acetate).

Regulatory Relief

   Though the GM Hamtramck
plant's regulatory status has not
changed, reduced waste makes for
fewer opportunities for spills, acci-
dents and violations, and therefore
fewer potential legal liabilities.

The Implementation Process

   The GM Hamtramck facility reg-
ularly holds meetings to examine
methods for product improvement,
waste reduction, and cost savings.
Input comes from environmental
engineering, paint shop mainte-
nance, paint production, facility
engineering, powerhouse personnel,
purchasing, and finance. Supplier
representatives are also an integral
part of the team.

   Implementation of this project
involved no capital or labor costs on
the part of GM. Worker training
was unnecessary. This is a perfect
example of how waste minimization
can often be very simple—it is just a

 Waste Minimization: Reducing Paint Waste Through Efficiency
 General Motors Hamtramck Plant
matter of paying attention to details,
fine-tuning, and maximizing small
opportunities for change.

   The effort took about a month,
during which time an operational
audit was conducted, the data ana-
lyzed, and solutions implemented.
Tracking of success included gather-
ing data on Toxic Release Inventory
chemicals and materials consump-
tion. The latter was accomplished
via a purchasing system that tracks
all purchases on a monthly basis.


   At the time the project was
implemented,  an annual savings of
$85,000 was achieved. This savings
is primarily the result of lower paint
and waste disposal costs. The sav-
ings have varied over time, due to
production volume fluctuations. In
addition, waste disposal require-
ments were cut.
                                  Words to the Wise

                                     Senior Environmental Engineer
                                  Roger Johnson noted that communi-
                                  cation of successes is vital for a pol-
                                  lution prevention effort. Doing so
                                  not only gains recognition, but may
                                  also elicit ideas from people who
                                  might not otherwise have participat-

                                      "If you achieve a success - com-
                                  municate it!"- Roger Johnson

                                     Another important aspect men-
                                  tioned by Mr. Johnson is creating a
                                  culture that accepts change and
                                  innovation. Doing so facilitates
                                  rapid development of new solutions.

   The project was implemented
during scheduled plant shutdowns,
eliminating any disruptions.
Product quality rose, since the cars
now receive a more even application
of paint.
                                                                           NATIONAL PLAN
For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize
                                                                           Reducing Ta»csin Our Data's Waste

Where to Go for Help

For copies of prioritization resources
mentioned in this brochure, or for other waste
minimization information, contact:
H? The RCRA hotline at 800 424-9346 or
   TDD 800 553-7672.

For technical assistance, contact:
® The National Pollution Prevention
   Roundtable's P2 Hotline at 888 745-7272.
A Member of Partners for the

     The Waste Minimization National Plan is
     part of EPA's Partners for the
     Environment. The pro-
gram works with small and
large businesses, citizens'
groups, and other organiza-
tions to incorporate pollu-
tion prevention as a central
consideration in doing busi-
ness. The programs set reachable
environmental goals, such as conserving water
and energy and reducing toxic emissions and
solid wastes.  These voluntary efforts are
achieving measurable environmental results
often more quickly and with lower costs than
traditional regulatory approaches.
                                                                       CO CD
                                                                       O =J
                                                                       O Q)
  3   »
                                                                              (Q CO

       CD ™ UJ.
      O W-g
    ro <
    o ,~
                                                                                                              United States
                                                                                                              Environmental Protection
                                                        September. 1997
Solid Waste and Emergency Response
National Plan
Reducing Toxics
In  Our  Nation's

 What Is the Waste Minimization
 National Plan?

     The Waste Minimization National Plan is a
     long-term national effort to reduce the quan-
     tity and toxicity of hazardous wastes.  The
goals of the National Plan are to:
                                                   Why Target PBT Chemicals?
                       NATIONAL PLAN
• Reduce by 50 percent
  the most persistent,
  bioaccumulative, and
  toxic (PBT) chemicals
  in the nation's haz-
  ardous waste by the
  year 2005, as com-
  pared to the baseline
  year of 1991.

• Emphasize source
  reduction (reducing
  waste at its source,
  before it is even gener-
  ated) and environ-
  mentally  sound recy-
  cling,  over waste treat-
  ment and disposal.

• Prevent transfers  of chemical releases from
  one medium (air, water, or land) to another.
   Why  Minimize  Waste?
   •  In Reduce Costs
   •  To Reduce Impacts of RCRA Requirements
   •  To Improve Human Health and the
   •  To Exhibit Environmental Leadership
   •  To Build Better Community Relations
      educing the presence of PBT chemicals in
      waste will reduce long-term threats to
      human health and the environment.
• Persistent (P) chemicals generally do not break
  down in the environment.

• Bioaccumulative (B) chemicals tend to concen-
  trate in animal and plant tissue.

• Highly Toxic (T) chemicals can cause cancer or
  other health effects in humans, and greatly
  endanger the environment.
What Resource is Available to Help
Identify PBT Chemicals and Set

      The Waste Minimization Prioritization
      Tool (WMPT) is a flexible Windows-
      based software system that provides
relative rankings of chemicals according to
their persistence, bioaccumulation potential,
and human and ecological toxicity. It allows
you to rank specific chemicals based on PBT
and chemical quantity.

  Using the Chemical-Waste Code Crosswalk
function, the Tool also allows you to identify
which RCRA waste codes potentially contain
PBT chemicals.
                                                     EPA will use the Tool to identify a subset
                                                  of ranked chemicals with which to track
                                                  and report national waste minimization
Other Resources:

   State and local environmental agencies, public
and private sector technical assistance centers,
trade associations, and product suppliers are all
sources of specific technical assistance. (See
reverse for addresses and phone numbers.)

 As a Waste Generator, How Can I
 Make the Plan a Reality?