Waste Reduction-Pollution Prevention: Progress and Prospects Within North Carolina"

“WASTE REDUCTION- POLLUTION PREVENTION: PROGRESS AND PROSPECTS WITHIN NORTH CAROLINA”

POLLLJllONs PREVENTION PAYS P NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND COMMUNITY DEVELOPMENT

James G. Martin Governor, North Carolina

S. Thomas Rhodes Secretary, NRCD

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PROCEEDINGS OF THE CONFERENCE "WASTE REDUCTION-POLLUTION PREVENTION: PROGRESS AND PROSPECTS WITHIN NORTH CAROLINA"

March 30-31, 1988 Raleigh, NC

Jeri Gray James M. Stewart Donald Huisingh

Conference and Proceedings financed in part by The Pollution Prevention Program of the Division of Environmental Management of the N.C. Department of Natural Resources and Community Development

through the The Water Resources Research Institute of The University of North Carolina Ackrmr(edgnents

Program planning for this statewide conference uas carried out by a steering comnittee conlposed of the following people: James M. Steuart, Associate Director, UNC Water Resources Research Institute 1 Roger N. Schecter, Director, N.C. Pollution Prevention Program Donald Huisingh, Professor, North Carolina State university Division of University Studies Gary E. Hunt, Envirowntal Engineer, N.C. Pollution Prevention Program Linda Little, Executive Director, Governor's Was e Management Board Edgar Mil ler, Governor's Waste Management Board T 1 I William Paige, Solid and Hazardous Waste Management Branch, N.C. Department of Human Resources

The following organizations assisted uith mailing lists, publicity, and speaker contacts: N.C. League of Municipalities * N.C. County Conmissioners Association * Consulting Engineers Council of N.C. * N.C. Textile Manufacturers Association American Furniture Manufacturers Association * Blue Ridge Branch of I the Electroplaters Association Professional Engineers of N.C. * Citizens for Susiness and Industry NCSU Industrial Extension Service * National Association of Hosiery Manufacturers League of Women Voters of North Carolina * Conservation Council of North Carolina Clean Water Fund Sierra Club * N.C. Water Pollution Control Association * Southeast Waste Exchange I The organizers of the conference wish to extend special thanks to all the speakers for their participation and assistance and to the follouing people for special assistance in developing technical sessions: Jerome Kohl, Senior Engineering Extension Specialist, NCSU; Roy Carauan, Professor of Food I Science, NCSU; Mary Beth Edleman, UNC Environmental Resources Project, UNC-Chapel Hill; Donald M. Preiss, Materials Engineering and Extension Specialist, NCSU; Stan Taylor, Data General; Setsy Dorn, Mecklenbilrg County Engineering; Michael Smith, Sandoz Chemical Corporation.

Special thanks are also due the following people: Linda Lambert, Administrative Officer uith WRRI I for facilities and registration coordination; Eva Teu, Frances Yeargan, Dot Ruffner, and Andrew Lawler of the WRRI staff for registration and other assistance; Charlotte Luke, Administrative Secretary uith the Pollution Prevention Program for assistance in conference coordination; John Hardy, artist uith the N.C. Department of Natural Resources and Cormunity Developnent, for brochure and proceedings cover design. I No longer uith this organization I I I I 1 i Copyright 0 1988 North Carolina Pollution Prevention Program

All Rights reserved. No part of this publication may be reproduced, stored in a retrieval system or I transmitted in any form or by any means: electronic, electrostatic, magnetic tape, mechanical, photocopying, recording or otherwise, without permission in writing from the Pollution Prevention Program, North Carolina Department of Natural Resources and Comnunity DeveLopnent, P.O. Box 27687, Raleigh, NC 27611, (919) n3- 7015. 1 ii I 1 1

PROCEEDINGS OF THE CONFERENCE "WASTE REDUCTION-POLLUTION PREVENTION: PROGRESS AND PROSPECTS WITHIN NORTH CAROLINA"

March 30-31, 1988 Raleigh, NC

Edit ed by : Jeri Gray James M. Stewart Donald Huisingh

Conference and Proceedings financed in part by The Pollution Prevention Program of the Division of Environmental Management of the N.C. Department of Natural Resources and Community Development through the

The Water Resources Research Institute of The University of North Carolina 1 .. . Ackmledgtmts 1 Program planning for this stateuide conference uas carried out by a steering comnittee conposed of the follouing people: James M. Steuart, Associate Director, UNC Water Resources Research Institute Roger N. Schecter, Director, N.C. Pollution Prevention Program 1 Donald Huisingh, Professor, North Carolina State University Division of University Studies Gary E. Hunt, Environmental Engineer, N.C. Pollution Prevention Program Linda Little, Executive Director, Governor's Was e Management Board Edgar Mi l ler, Governor's Yaste Management Board ! 1 I William Paige, Solid and Hazardous Waste Management Branch, N.C. Department of Hunan Resources

The foltouing organizations assisted with mailing lists, publicity, and speaker contacts: N.C. League of Municipalities * N.C. County Comnissioners Association Consutting Engineers Council of N.C. * N.C. Textile Manufacturers Association American Furniture Manufacturers Association * Blue Ridge Branch of I the Electroplaters Association * Professional Engineers of N.C. * Citizens for Business and Industry NCSU Industrial Extension Service * National Association of Hosiery Manufacturers League of Women Voters of North Carolina Conservation Council of North Carolina Clean Uater Fund * Sierra Club N.C. Water Pollution Control Association * Southeast Waste Exchange 1 The organizers of the conference uish to extend special thanks to all the speakers for their participation and assistance and to the following people for special assistance in developing technical sessions: Jerome Kohl, Senior Engineering Extension Specialist, NCSU; Roy Carauan, Professor of Food I Science, NCSU; Mary Beth Edleman, UNC Environmental Resources Project, UNC-Chapel Hill; Donald M. Preiss, Materials Engineering and Extension Specialist, NCSU; Stan Taylor, Data General; Betsy Dorn, Mecklenhrg County Engineering; Michael Smith, Sandoz Chemical Corporation. I Special thanks are also due the following people: Linda Lambert, Administrative Officer uith URRI for facilities and registration coordination; Eva Teu, Frances Yeargan, Dot Ruffner, and Andreu Lauler of the URRI staff for registration and other assistance; Charlotte Luke, Administrative Secretary uith the Pollution Prevention Program for assistance in conference coordination; John Hardy, artist uith the N.C. i Department of Natural Resources and Cwmhlnity Developrent, for brochure and proceedings cwer design. ' No longer uith this organization 1 I I i 1 1 Copyright 0 1988 North Carolina Pollution Prevention Program

All Rights reserved. No part of this publication may be reproduced, stored in a retrieval system or I transmitted in any form or by any means: electronic, electrostatic, magnetic tape, mechanical, photocopying, recording or otherwise, without permission in writing from the Pollution Prevention Program, North Carolina Department of Natural Resources and Comnunity Developrent, P.O. Box 27687, Raleigh, NC 27611, (919) 733- 7015. ii 1 . i Abstract

1 North Carolha has been a leader in pnanoting the Pollution Prevention axxept. In May 1982, the first Pollution Prevention Pays symposium in the United States was held in Winston-Salem, and shortly thereafter a statewide 1I program of multimedia waste reduction assistance-the North Qrolh Pollution h-evention established in the Division of EnvhmtalNamgement of the Deprtment of Natural Resources and Omnuru'ty Developrent. Since then 1 the nonregulatory Pollution Prevention m-Ogram has dozmwnted mysuccesses in waste reduction and has been recognized as the most effective in the country. lhis conference, 'Waste Reduction-Pollution Prevention: PrOJress and 1 Prospeclts in North mlha,"was an important step in North Carolina's contiriuing efforts to educate industrialists, govenrment leaders, public officials, and citizens about the concepts, approaches, and current technology wfiereby wastes, pollution, and their associated cc5ts can be curbed. The conference kgan with an opening plenary session in which speakers L_'1 presented local, state, national, and globdl perspectives on waste reduction, including an assessment of the status of waste reduction technology and practices. ?he session was follmed by 16 cement sessions featuring 50 technical presentations addressbq a camplete range of baste 1 reduction concans fm regulatory and financial incentives to state-of-the-art technology for specific in?ustries. In the cldncj plenary session speaF;ers representing industry, errviromtal, and regulatory perspedives presented 3 their rewmmendations for prm0tb-g waste nzduction practices nationwide.

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TABLE OF CONTENTS Page Overview of North Carolina's Waste Reduction Efforts and Purposes of the Conference Roger Schecter, Director N.C. Pollution Prevention Program .....1.1-1.4 National Waste Reduction Strateqies James Lounsbury, Director, EPA Waste Minimization Staff...... 2.1-2.5 Brinqina It Home: N.C. PersDectives "North Carolina's Commitment to Pollution Prevention" S. Thomas Rhodes, Secretary of Natural Resources and Community Development ...... 3.1 Waste Reduction and the Siting of Hazardous Waste Treatment Facilities: A Legislator's Viewpoint" Bruce Ethridge, N.C. House of Representatives ...... 4.1-4.3 "Waste Reduction: An Environmentalist's Perspective" Bill Holman, Environmental Lobbyist ...... 5.1-5.4 "Waste Minimization: Concepts Utilized by GE-Manufacturing Facility, Wilmington, NC" Robert Pace, General Electric Company ...... 6.1-6.3 Waste Reducins, Clean Technolosies in Europe--Fact or Fantasy Don'Huisingh, North Carolina State University ...... 7.1-7.6 Electroplating Eliminatins Wastewater Discharqe from a Platins Facility Greg Piner, MCAS Cherry Point ...... 8.1-8.2 Waste Reduction in a Platins Line George McRae, Stanadyne Inc...... 9.1-9.2 Atmospheric Evaporative Recovery on a Nickel Platinq ODeration Gary Hunt, N.C. Pollution Prevention Program and Brian Wells, Ilco Unican Corp ...... 10.1-10.11 Textiles Waste Reduction and Pollution Prevention in the Textile Industry - A Perspective for Wet Processors Sam Moore, Burlington Research Inc...... 11.1-11.3 Research to Minimize Waste Production in the Next Century Michael Overcash, North Carolina State University ...... 12.1-12.4 Influent Toxicity Reduction Throush Choice of Biodeqradable Surfactants Lou Kravetz, Shell Development Corp ...... 13.134

V Degreasing Operations .. Hazardous Waste Reduction in Metal Parts Cleaninq 1 Jerry Kohl, North Carolina State University ...... 14.1-14.3 1 Gettina Rid of Solvent-Based Deareasinq in a Diesel Ensine Remanufacturins Plant Alice Johnson, Mack Truck, Inc...... 15.1-15.: I Low-level Rad-waste Management The Development and Implementation of a I Dry Active Waste (DAW) Sortins Proqram J.H. Schulte, Duke Power Company ...... 16.1-16.; Low-level Rad-waste Reduction-Pollution Prevention I in the Asricultural Division Laboratories of Ciba-Geiw Corporation Bill Secrest, Ciba-Geigy ...... 17.1-17.4 I Low-level Radioactive Waste Manaqement-Seekinq an ODtimum Volume Reduction Strateqv I Mark H. Voth, Penn State University ...... 18.1-18.8 Furniture I Waste Reduction-Pollution Prevention in the Furniture Industrv: New Technolosies for Reducins Finishins Wastes and VOC Emissions Vincent Ross, Ross Associates, Inc...... l9.1-19.3 I Hiqh-Solids Coatinqs. Electron Beam Curins and Ultraviolet Curinq I Keith Clark, UCB/Radcure Specialties ...... 20.1-20.2 Commercial Clinical, and Educational Laboratories Chemical Laboratory Distillation, Small-scale Neutralization and In-house Waste Exchanqe Wayne Thomann, Duke University ...... 21.1-21.12 I Commercial Laboratory--1ntra-laboratory Methodoloqies Rosanne Feild, Becton Dickinson...... 22.1-22.4 1 Reduction of Hazardous Wastes i from North Carolina Hish School Laboratories 1 George Wahl, North Carolina State University ...... 23.1-23.3

Vi I 1 . '. Developing and Implementing Waste Reduction Programs 1 Developins a Waste Reduction Prosram Gary Hunt, N.C. Pollution Prevention Program...... 24.1-24.15 1 pow to Reduce Waste, Save Monev, and Be a Good Neishbor: Waste Reduction Stratesies for Small and Medium Size Companies 1 P.A. Vesilind, Duke University ...... 25.1-25.2 Viable Options for Household Hazardous Waste Management Household Hazardous Waste Collection Proqrams in the United States ..7 Dana Duxbury, Tufts University ...... 26.1-26.3 The Federal Perspective on Manaqinq Household Hazardous Waste Allen Maples, EPA...... 27.1-27.5 Contractins with Commercial Hazardous Waste Manaqement Firms for Handlins, TransDortation, and Treatment/DisDosal of Collected Household Hazardous Waste II Elizabeth McCormick, GSX Chemical Services ...... 28.1-28.4 3 Kaking Pollution Prevention Pay for Food Processing A Dairy Processor Does It! R.A. Bullard, Maola Milk and Ice Cream Co...... 29.1-29.6 A Breaded Foods Processor Does It Too! :I James V. Waynick, The Equity Group ...... 30.1-30.9 Can Water Recyclinq Work for Poultry Processors? Brian W. Sheldon & Roy Carawan, North Carolina State University ...... 31.1-31.5 How Pollution Prevention Pays for Food Processors Roy Carawan, North Carolina State University ...... 32.1-32.8 Microelectronics

Waste Marketins: A Case Study from the Electroplatinq Industry Terry Schurter, Data General Corp...... 33.1-33.3 The Use of Canister Ion Exchanqe Technoloqv in a Zero Discharue Facility John Eason, NAPCO, Inc...... 34.1-34.2 Waste Reduction/Pollution Prevention throush Alternative Process Technoloqv in Printed Wirins Board Fabrication d John Roy, Olin Hunt specialty Products, Inc...... 35.1-35.3

vii New Concepts in Municipal Solid Waste Reduction Closina the Loop in Plastic Container Recvclins: Market Development/Increased Materials Recovery I Luke B. Schmidt National Association for Plastic Container Recovery ...... 36.1-36.3 Private/Public Partnerships I in Promotins Waste Minimization and Recvclinq E. Gifford Stack National Recycling Coalition and National Soft Drink Assoc...37.1-37. I Regulatory Incentives and Issues in Waste Reduction Incentives and Resulatorv Issues in Waste Reduction I William Paige, N.C. Hazardous Waste Management Branch...... 38.1-38.3 Incentives and Resulatorv Issues in Waste Reduction: Case Study Examples I Bill Pitchford, N.C. Hazardous Waste Management Branch...... 39.1-39.' The City of Raleish: Participation and Incentive: I Utilizins the Pollution Prevention Prosram for Industry Leon Holt, City of Raleigh ...... 40.1-40.. I Chemical Processing Technical'Approaches to Waste Reduction Gregory J. Hollod, E.I. Du Pont de Nemours & Company ...... 41.1-41.2 I Waste Minimization and Recyclinq Opportunities in a Multipurpose Chemical Manufacturins Plant I William M. Archer, Sandoz Chemicals Corporation ...... 42.1-42.4 Waste Reduction: Prosram Practice I and Product in Chemical Manufacturinq Ryan Delcambre, Dow Chemical USA ...... 43.1-43.1: Printing I Water Based Inks in Flexosraphic Printinq George Makrauer, Amko Plastics, Inc...... 44.1-44.9 I Reduction of Hazardous Waste in Coatins/Lamination: One Orqanization's Approach i Gordon Miller, Rexham Corporation ...... 45.1-45.3 Solvent Recovery from Flexosraphic Printins Inks I Danny Crump, Rexham Corporation ...... 46.1-46.3 viii I *. -. Filtration Recovery Process for Oil/Carbon Black Base Inks n Danny Collins, News and Observer Publishing Company ...... 47.1-47.2 Fiberglass Moldings 1 Reduction of Hazardous Wastes: An Overview of Fiberslass Moldinq Darryl Davis, East Carolina University...... 48.1-48.E _I On-site Recovery William Johnson, Recyclene Products, Inc...... 49.1 Fiberslass Moldinqs: An Overview of Materials Safety Data Sheets n ...... 50.1-50.8 Lori Piantadosi, East Carolina University Financial Incentives to Waste Reduction 1I" Hazardous Waste Reduction - Measurement of Prowess Michael Overcash, North Carolina State University ...... 51.1-51.25 L. L. In Food Plants Pollution Prevention Is More Economical than Pretreatment 3 Roy Carawan, North Carolina State University ...... 52.1-53.12 EPA's Waste Minimization Benefits Manual 3 Ron McHugh, U.S. Environmental Protection Agency ...... 53.1-53.2 Concluding Plenary Session Federal Hazardous Waste Reduction Policy: Debate and Surmort Stalled Joel Hirschhorn Congressional Office of Technology Assessment ...... 54.1-54.8 Waste Reduction Pollution Prevention Initiatives: Industry's Need for Pollution Prevention Joe Harwood, N.C. Citizens for Business and Industry ...... 55.1-55.2 Rethinkins Waste Manaqement: From "Hole in the Ground" to Holistic Linda W. Little, Governor's Waste Management Board ...... 56.1-56.6 The Need for a Focus on Waste Reduction in Professional Education and Practice David H. Howells Professor Emeritus, North Carolina State University ...... 57.1-57.3 LIST OF PARTICIPANTS...... 58

ix 7 n Rqer N. Schecter The 325 people who signed up for this conference did not have to sign up. Neither were they lured here by prdse of interpretations of the Federal Register that would help them figure out hm to neet environmental regulations. The representatives of trade asscciations, individual industries, environmental w,and state agencies who are here came in a spirit of moperation to share infomtion and learn in an effort to achieve two key goals for our state. The first goal is environmental quality. me second goal, altYays associated with envhnmental quality, is econmic development.

Waste reduction-reducing, preventing, or eliminating waste at the source-- is the key to allawing econOmic development to go hand-in-hand with preserving environmental quality. If you let waste be generated, then you let it be regulated. Regulation is expensive and may only shift waste fmone place to another.

U.S. Industry Spends $70 billion a Year on mllution control According to Joel Hirschhom of the congressional Office of Techn01cg-y Assessment, American industry spent $70 billion on pollution control in 1986. ?hat is just pollution control after the bwte is generatd. It does not include permit fees, monitoring costs, liability insurance, and so forth.

The Federal Register currently includes about 7,000 pages of regulations for pollution control. Quick arithmetic shows that every time one page is added to the Register, it adds $1 million to inauStry's cost for pollution control. ?he increase in Register pages in the last two years roughly equates to a $1 billion e>rpense for business. And, we're still not methat we're achieving mjor long-last- effects on environmental quality. We are sure, hmever, that regulation is having a major econdc bpct on inauStry, and we're still havbq mjor envhmtal problems. Waste Reduction Effort Is Nonregulatory In North Qr0lh-n a voluntary, nonregulatory approach has been the cornerstone of a very successful state government effort to protect er~~hmnentalquality through waste reduction. mer the last five years, in a very cooperative effort, North Carolha industries, state agencies, universities, and public interest groups have mde great prcgress in raking pollution prevention pay. Of the 50 presentations to be made at this conference, the majority are by representatives of North Qrolh hdustripc who have taken the concept of baste reduction and made it work.

The North Carolha Pollution mevention m-Ogram is not one in which gaVe"ent goes to industry with the attitude that gwenment hm everythins Director, Pollution Prevention Frogram, Division of Eslvhmtal r"nnagement, North Carolina De-t of Natural Resources and On-"'ty Development, P.O. Box 27687, Raleigh, NC 27611.

1.1 and that hhstry needs governent help. We think that what industry does need frcan g"ent is our support, our information, our resources, our ear. with gwenrment rmpport, industry, which has its problems and its processes, can 1 develop the prooess changes that will elhnhate wastes, including toxic or hazardous chemicals, for its am benefit as well as the benefit of the envhmt. I

L 'ibis is an irrrportant concept not only for industry but also for local gavemment. Regulatory pressure and rspnsibility in rqard to toxic and 1 hazaxdaus materials and any wastes that impact hurnan health and the environment have been passed fram federdl guvermnent to state government, and the state is passing responsibility on to govermnent--partiaarly for pretreatment I. 1 prograrrrs to protect water quality. The acceptance of an discharge into a municipal wastewater treabnent system is no longer samething that can be taken for granted. Both the volume and caposition of industrial discharges are nm subject to close scrutiny because lccal governments have to answer for I the qualily of their wastewater treabnent syste?l effluent. i There are essentially two ways local guverments can deal with increashg volume and unacceptable composition of industrial discharges into municipal wastewater treahent systenrs. These are the same two ways that industry can deal with e"matal contaminants. You can build a bigger, hopefully better treahent plant, and industries can build pretreatment systas--which you hope will work. The second way to deal with wastes is to create new and innovative ways to eliminate the hydraulic load, the toxicity, or even the standard pollutantS of B3D and (XID. This waste-reduction approach to envhmtal problems my take a little more time initially but it will prduce Mate results.

Ixlrhg this conferenas! we will hear fram myNorth Carolina coTi[pani-1 local gavenrments, and state agencies that invested the tine in waste reduction and are ~xlwenjoying the results. We will also consider the prospectS in North Carolina for further progress in reducing wastes. It is a purpose of this conference to pmtewaste reduction practices by htrducing mre North Carolina westo waste reduction concepts and pmven baste r-ction techniques. The State of North Carolha is supprting this effort because, as I said, the approach is so vital to both enviromtal qyality and economic develapnent here.

waste Reduction supports Econcmic Developnent

(xlr state faces many challenges related to wastes, and t&y we are looking for additional ways to help meet those challenges. ?he Pollution Prevention Prcgram works through the kparbent of conmsxe with new jsdustr ies ccxning into the state. when inctustry chooses a location, it may find that a particular watershd or stream or wastewater treatment faciliw or airshd, may be at or near its capcity to assimilate wastes. By helping existing industry in the area cut its waste load and helping new the industry hold dawn its wastes, we may be able to allm additional development in areas fiere it would otherwise be impossible. Over the next few years we must convince ourselves and the public that new solid waste landfills, hazardous waste treabnent facilities, and lm-level rad- 1.2 1 waste disposdl sites are really needed. If inaustry reaches the point where it is proaUcing the lmest amount of waste possible, then the need for treatment

1 ~~ and disposal facilities my be more evident and qprtable. ?here is no such ~aSZer0waste. We cannot reuse, recycle, and r&ce everything. ?he 1-7 question of exactly hm much we can reduce our wastes is very difficult and it is being investigate3 now at the national level by EPA. We have to be able to answer the question to convince people that we need the trealment and disposal II facilities, and we have to be realistic in our answer. N.C. Waste &duction Effort ~eganin 1982, :1 Involves several Wencies The North Carolha effort to prevent pollution through waste reduction is not just a single-agency effort. In addition to the Pollution Revention Prugram, this effort involves the Hazardous Waste Branch--particulary the 3 Technical Assistance Unit--which deals with regulated RCRA hazardous wastes as well as nonreylated waste; and the Governor’s Waste mgement Board, vhich reo3gnizes industries throughout the state for significant adevenent in waste :1 reduction and through this recqnition prqmn has mntributed significantly to spreading the concept and technologies for waste reduction.

The waste reduction concept bas originally intrcduced in North Carolina n thnxrgh a conference organized by Bn Huisbgh and held in Winston-Salem in 1982. The group of industri-, citizens, businesses, and public interests groups that organized that symposium essentially laid the foundation for a coordinated state effort and a state policy to reduce, prevent, and eliminate wastes before they are released to North Carolina’s envhmt. ‘Ihis confereme gives us the opportunity to see haw much progress North Carolina has mde in identifying, developing, and applying waste-reducing practices since that 1982 conference and allas us to exa” local government, i..- ] state, national, and even international perspectives on the current and future state of this effort. Nationally, ow perspective on protecting the mir0rrment needs to change. Over the last eight months I have worked with the EPA and the people there who are trying to champion the cause of waste reduction at the national level. Making waste reduction/pollution prevention a priority at the national level is going to be very difficult because we have a pollution control mentality. There is so much attention focused on the If& of the pipe,##that we hzve all but ignored the potential for waste reduction. We need to change our national Perspective and add waste reduction as a real way of dealing with waste. Nationally as well as locally, waste management should be based on a four-level hierarChy-with source reduction and recycling king the first two levels in that hierarchy and accounting for the mjority of our waste managenat fcxus. Treat”t and finally disposal are at the next two levels of the hierarchy and shmld be enployed only for those wastes we cannot manage at the first two n levels. North Carolina Has Opportunity to Help Set i National Agenda North Carolina‘s effort in waste reduction now serves as a delfor other J states interested in developing waste reduction progrcrms, and some basic J 1.3 elements of our program are being incorporated into the U.S. E”rrmenta.l Prutection AgMcy’s national waste reduction program. Our state is a leader in waste reduction, ad we ncw have the opprtmiw to help create the agenda for I other=states an3 for the nation. What we must do is damstrate that waste reduction is not mtherhd and apple pie but a workable concept with both 1 =nomic and envhmtal benefits.

We documented last year 60 inauStripc in North Carolina that collectively saved $16 million by adopt- waste reduction prqmns, and those savings OCCUT I annually. Ccrinpare 60 industries swing $16 million annually through pollution prevention to the industries spending $70 billion on pollution control. ?his is the message that North Carolina nust spread throughout its mn borders and take to the nation as a whole. 1 I

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The U.S. Environmental Protection Agency (EPA) is developing a national program that focuses on preventative nethods for protecting the environnent. EPA's waste minimization program focuses on protecting the environment by reducing the generation of pollutants at the source, particularly at production facilities, and by recycling pollutants that continue to be generated. The background, purpose and elements of this program are described in this paper. The Need for Waste Minimization The Federal governnent of the United States is at a critical juncture in environzental nanage3ent. Until the mid 70/s, the Federal 'envircnnental statutes in the United States focused mostly on ltconventionalltpollutants, i.e., those that were the most obvious, the most understood in terms of environmental impacts, and the most controllable from a technological perspective. Particulates, SOz, suspended solids, BOD, and solid waste were familiar tersns to regulators and industry. Our national environmental manaqenent franework assumed that appropriate requirements at the end-of-the-pipe would maintain the balance between pollution and environnental

tolerance. Controlling conventional pollutants would also I adequately control toxic pollutants, or so it was believed. However, during the past decade, we have found we xere wrong on several assumptions. First, the effects of thousands of chemicals and wastes used and disposed of each year on human health and the environment were barely understcod. Xany sanitary landfills of the 1960's that were believed to be the best safe nethod for disposal of all our solid xastes (toxic and nontoxic) are ncw costing us millions of dollars to clean up under the Superfcnd program. Even some of.the conventional pollutants we thought we understood undergo,changes in the environment and result in toxic environmental damage. For example, SO2 emissicns can form acid rain deposits hundreds of miles away. We were wrong on our assuaption that stricter controls and higher costs at end of pipe would also adequately control waste volumes. To the contrary, while more and inore strict end-of-pipe treatment and disposal requirements have been put in place, waste generation and release to the environnent continue at an unacceptable pace. Strong public oppcsition to siting of waste management facilities often stems from a legitimate concern that too little is being done to reduce pantities of waste generated at the source.

Director, Waste Minimization Staff, U.S. Bdrairinental Protection Apncy (N-3- 565), 401 M. St., S.W., Washington, E 20460 J 2.1 The critical juncture in our national pollution control framework was expressed clearly in Congress‘ amendments to the ” Resource Conservation and Recovery Act, known as the Hazardous and Solid raste Amendments of 1984 (HSWA). HSWA shifted the nation‘s priorities for protecting human health and the environment from end-of-pipe treatment and disposal to reducing or eliminating the qeneration of hazardous wastes, wherever feasible and as expeditiously as possible. Congress also prohibited land disposal of hazardous wastes unless they are first treated using best demonstrated available technology. Both changes are intended to force industry to reduce waste generation. In EPA’s 1988 appropriation, Congress gave EPA further direction to develop a waste minimization program that extends beyond hazardous waste to a multimedia approach across all major EPA programs. This policy change is another strong indication that the public is becoming less and less tolerant of the current and future threats to human health that result from the release of toxic substances. In environmental legislation of the 1980‘s Congress has become increasingly more stringent and significantly more specific in the level of detail provided in its environmental statutes. The HSWA amendments of 1984, the Superfund Amendments and Reauthorization Act of 1986, and the Asbestos Hazard and Emergency Response Act of 1986 provide new benchmarks for legislative detail. To implement this policy shift will take years, but the initial steps that we must take are reasonably straight forward. Among environmental professionals, there is a broad consensus on a hierarchy of waste management practices that should be factored into decisions concerning environmental protection. The hierarchy includes four basic technical concepts. Most environmental managers within and outside EPA agree that these options should be pursued in priority order, as presented below:

0 Source Reduction: the reduction or elimination of waste at the source, usually within a process. Source reduction measures include process modifications, feedstock substitutions, improvements in feedstock purity, housekeeping and management practice changes, increases in the efficiency of equipment, and recycling within a process.

0 Recycling: the use or reuse of waste as an effective substitute for a commercial product or as an ingredient or feedstock in an industrial process. It includes the reclamation of useful constituent fractions within a waste material or the removal of contaminants from a waste to allow it to be reused.

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0 Treatment: any method, technique or process that Thanges the physical, chemical or biological character of any waste so as to neutralize such waste, to recover energy or material resources from the waste, or so as to render such waste non-hazardous, less hazardous, safer to manage, amenable for recovery, amenable for storage, or reduced in volume.

0 Disposal: the discharge, deposit, injection, dunping, spilling, leaking, or placing of waste into or on any land or water so that such waste or any constituents may enter the air or be discharged into any waters, including groundwater. 9L EPA has spent 18 years and millions of dollars on developing treatment requirements and has made significant headway. However, EPA‘s focus is beginning to shift to the top :i two priorities in the hierarchy. Collectively, EPA refers to these priorities as waste -1t; minimization--changes that can be made in a production process to effectively reduce or recycle waste generated that would otherwise have to be disposed of or treated for the purpose of disposal. There are many nethods and practices that lead to source reduction and recycling. Some examples are highlighted in Table A. ,1 Production managers have always looked for ways to reduce production costs for competitive reasons. While there is generally a wide range of changes that could be made, available information suggests that only a very small percentage of firms, out of the tens of thousands of waste generators and other pollution generators in the United States, have focused systematically on identifying and implementing methods to t. I minimize waste generation. As long as there is an adequate supply of treatment and disposal capacity and as long as the costs of treatment and disposal can be passed through in whole i‘I-- or in part to the consumer, waste minimization will not be an attractive opportunity for most production managers. The tendency will be to continue to rely on known requirements for treatment and disposal in order to avoid the potential risks associated with changing an established production process.

!IL .. What‘s the Solution? Many changes can be made that reduce waste and save money without changing product quality. What‘s needed first in most plants is a willingness to step back and take a careful look at (1) what generates the waste in the first place and (2) what the costs for waste disposal really are. Let’s look at three r3 examples based on audits and cost estimates conducted at typical plants. 11 2.3 J I - TABLE A I Waste Minimization Approaches and Techniques I Inventory Management and Improved Operations Production Process o Inventory and trace all raw 0 Substitute nonhazardous I materials. for hazardous raw materials. I o Purchase fewer toxic and 0 Segregate wastes by type more nontoxic production for recovery. materials. I o Implement employee training 0 Separate hazardous from and management feedback. nonhazardous wastes. 1 o Improve material receiving, 0 Redesign or reformulate storage, and handling practices. end products to be less hazardous. I 0 Optimize reactions and raw material use. I Modification of Euuipment Recvclins and Reuse I 0 Install equipment that produces o Install closed-loop less or no waste. systems.

0 Modify equipment to enhance o Recycle onsite for I recovery for recycling options. reuse.

0 Redesign equipment or o Recycle offsite for I production lines to produce reuse. less waste. I 0 Improve operating efficiency o Exchange wastes. of equipment. ‘I 0 Maintain strict preventive maintenance program. I I I

2.4 I I FxamDle one: In a large scale spray painting operation, the productsleing painted go through a spraying booth according to

~~ the ~~~~orders that are received--first a red one, then blue, green, another red, two blues, and so on. After each product is painted, the paint lines are flushed with solvent to prepare for the next item. The flushed solvent containing paint goes into the wastewater treatment unit. Also going into the waste stream is about 40 percent of the paint that misses the product and goes into the air and down into the waste water stream. According to the company's records, the costs for waste management include only the cost of treating wastewater and sludge disposal. A step back and a little closer look at the costs for xaste management showed that some of the real costs of waste management were not included in the company's total estimates. For example, the cost of the paint that goes into the waste as overspray was not included in the costs of waste management, nor was the cost of the solvent used to purge the paint lines or the paint that is flushed from the lines. The company underestimated their waste management costs by almost half. A look at the real costs got management attention and a surprisingly simple solution was found. The company reprogrammed its computer to paint all the products in groups of the same color each day, i.e., all red items, then blue, and so on. This reduced solvent costs, reduced the cost of purged paint and reduced the volume, concentration and costs of wastewater treatment. The final costs of waste management were reduced by about 20 percent with no up front cost for the changes. EXamDle two: In a medium size plant the most significant waste disposal problem was disposal of 40-50 glue barrels each month that were each 1/4 to 1/3 full of dried unusable glue. These costs were pa'id for several years before the plant manager looked into the problem. After a step back and a closer look, the reason for wasting the glue was identified by the shift foreman. At the beginning of each shift, the glue operator switched to a full glue barrel that would last through his shift. He didn't want to be the person responsible for stopping the operation while he switched barrels. At the start of the next shift glue operator would do the same. At the end of the month, 40-50 partly full barrels of dried glue were disposed of at a cost of about $lOO,OO per year. The solution was simple. For $200, a new glue pump was installed that locked in place and could only be removed by the shift foreman after the pumping mechanism reached the bottom of the barrel, thereby preventing partially full barrels from being thrown away. The cost of glue hauling and treatment was reduced by about 80 percent.

2.5 Example three: In a small electroplating plant, raw netal parts wen1 into a plating bath and then were rinsed in high trohme, continued flow water baths. The company found that the installation of two still water rinse baths after the plating bath and before the final flow rinse, and switching from continuous flow to a fine spray rinse cut down on the need for rinse water by 90 percent. Also, as the metal content of the still rinse baths increased to high levels, they were recycled back into the plating bath. Overall the amount of metal purchased for the plating baths was reduced, the volume of sludge generated for treatment and disposal was reduced, and overall waste water volume and associated treatment costs were reduced by over 30 percent. These examples illustrate the types of progress made by many firms. However, there is still a long way to go. What's needed is:

1) A willingness and encouragement by corporate executives to look for ways to reduce costs by generating less waste, and 2) Useful technical information that is available to production managers and line operators to help identify waste minimization opportunities. I How can these remedies be Drovided? i Federal leadership is critical for promoting progress. The expectations of the Congress and the public to make progress are high. It will take years to shift the emphasis at thousands of production facilities. Progress will depend on ! strong Federal leadership and active State technical assistance programs to work with firms who need assistance. The U.S.. Environmental Protection Agency (EPA) is committed to a ! national program that builds on the innovative accomplishments of industry and States. During 1988, the EPA will publish an Agency policy statement that commits EPA to identifying and implementing source reduction and recycling opportunities I throughout its air, land,surface water and ground water programs. The objectives of the EPA program are to: i 0 Promote waste reduction by making technical information available to state technical assistance programs and firms who need assistance. I A great deal of non-confidential technical information is available to help firms explore various waste minimization techniques, such as: waste segregation I or other operating practices, equipment modification, chemical substitution in maintenance or production 1 processes, and recycling. EPA is developing a three I 2.6 I Example one: In a large scale spray painting operation, the productsJeing painted go through a spraying booth according to the orders that are received--first a red one, then blue, reen,-another red, two blues, and so on. After each product is painted, the paint lines are flushed with solvent to prepare for the next item. The flushed solvent containing paint goes into the wastewater treatment unit. Also going into the waste stream is about 40 percent of the paint that misses the product and goes into the air and down into the waste water stream. According to the company's records, the costs for waste management include only the cost of treating wastewater and sludge disposal. A step back and a little closer look at the costs for xaste management showed that some of the real costs of waste management were not included in the company's total estimates. For example, the cost of the paint that goes into the waste as overspray was not included in the costs of waste management, nor was the cost of the solvent used to purge the paint lines or the paint that is flushed from the lines. The company underestimated their waste management costs by almost half. A look at the real costs got management attention and a surprisingly simple solution was found. The company reprogrammed its computer to paint all the products in groups of the same color each day, i.e., all red items, then blue, and so on. This reduced solvent costs, reduced the cost of purged paint and reduced the volume, concentration and costs of wastewater treatment. The final costs of waste management were reduced by about 20 percent with no up front cost for the changes. gxample two: In a medium site plant the most significant waste disposal problem was disposal of 40-50 glue barrels each month that were each 1/4 to 1/3 full of dried unusable glue. These costs were pa'id for several years before the plant manager looked into the problem. After a step back and a closer look, the reason for wasting the glue was identified by the shift foreman. At the beginning of each shift, the glue operator switched to a full glue barrel that would last through his shift. He didn't want to be the person responsible for stopping the operation while he switched barrels. At tha start of the next shift glue operator would do the same. At the end of the month, 40-50 partly full barrels of dried glue were disposed of at a cost of about $lOO,OO per year. The solution was simple. For $200, a new glue pump was installed that locked in place and could only be removed by the shift foreman after the pumping mechanism reached the bottom of the barrel, thereby preventing partially full barrels from being thrown away. The cost of glue hauling and treatment was reduced by about 80 percent.

2.5 ...

Example three: In a small electroplating plant, raw netal parts wen1 into a plating bath and then were rinsed in high volume, continued flow water baths. The company found that the installation of two still water rinse baths after the plating bath and before the final flow rinse, and switching from continuous flow to a fine spray rinse cut down on the need for rinse water by 90 percent. Also, as the metal content of the still rinse baths increased to high levels, they were recycled back into the plating bath. Overall the amount of netal purchased for the plating baths was reduced, the volume of sludge generated for treatment and disposal was reduced, and overall waste water volume and associated treatment costs were reduced by over 30 percent. These examples illustrate the types of progress made by many firms. However, there is still a long way to go. What's needed is:

0 Promote waste reduction by making technical information available to state technical assistance programs and firms who need assistance. A great deal of non-confidential technical information is available to help firms explore various waste minimization techniques, such as: waste segregation or other operating practices, equipment modification, chemical substitution in maintenance or production processes, and recycling. EPA is developing a three

2.6 part strategy to help make this information available. First, EPA is developing information fact sheets that will summarize current technical and regulatory developments for states and industry

~ officials. EPA is also working with several States and firms to collect technical information and make it available through a computer-based information system. The last part is an information hotline to help answer inquiries from the field.

0 Advise Congress on national progress on waste minimization. EPA is developing a national database to provide Congress information on national trends. A good database will help EPA determine whether there is a need for regulations or other incentives -- or removal of disincentives -- to reduce or eliminate waste generation. We will build the database in several ways. Waste minimization questions are included in a recent waste management survey sent to over 10,000 hazardous waste generators. Hazardous waste generators will also be required to answer a series of questions on their waste minimization activities in the 1987 RCRA Biennial Report. Finally, companies that are required to complete a chemical inventory under the "community right to know" provisions of the Superfund law will be asked to provide optional information on waste minimization practices. All of this data will go into a computerized, publicly available database. It will be EPA's primary source of information for evaluating national progress within particular industry sectors, among particular states or regions, and over time as the data base is updated. Future data collection and evaluation will focus more on source reduction and recycling in the air and water programs as well as solid waste.

0 Foster development of state waste minimization programs. States will be the front line agencies that assist firms in identifying waste minimization technologies. EPA is offering two types of grants as seed money to develop these programs, including grants for training and demonstration projects and grants to set up or expand technical assistance programs. Several States have active programs underway that provide assistance particularly to medium and small firms that have limited information or expertise. North Carolina began its program in 1983 and has had measurable success. Several other States, including California, Minnesota, Oregon, Massachusetts, Pennsylvania, New ;i York and New Jersey also have programs underway. Many more states are trying to get started and will benefit J from initial grant funds. 2.7 o -Develop outreach and communication programs with the goal of raising awareness of the beaefits of waste 1 minimization within government, industry, and the pub1 ic. I Direct communication with industry and state officials is a top priority. EPA is also working to develop a range of awareness raising tools, including videotapes, brochures, posters and technical manuals. EPA has initiated several workshops that are attended by a wide range of industry, state and environmental organizations and individuals. Presentations at conferences and informal meetings with trade associations and individual company officials have been very effective.

Summary : EPA is focusing on four priorities to enhance national progress in waste minimization: (1) the transfer of technical information to States to assist firms who do not otherwise have ready access to technical information on source reduction and recycling; (2) supporting the development of State programs to provide technical assistance to firms, particularly medium and small firms; (3) developing outreach and public information programs to encourage changes an a broad scale; and (4) monitoring national progress and recommending to Congress next steps to ensure continued progress. Success for this national program depends on continued cooperation with many States, industry, and environmental organization.

2.8 Waste reduction has bewme an integral part of the way our department deals with mvirorrmental management. particularly in the last three years, we have seen the concept of preventing waste mive increasing attention throughout all agencies dealing with camplex envhmtal issues fmthe siting of a hazardous waste treatment facility to recognizing significant irdustrial waste reduction aoxmplishments thmugl~our Gwemor's Awards. We are comim=ed that North Qrolha can achieve envi"=ntal and econmic benefits through pollution prevention. of course, a strong regulatory program for all envhmnental releases is required. Waste rdction, hmever, is one of the few positive alternatives where industry, government and the envirorrment are all winners. We have come a long way in making pollution prevention pay for North Carolina, ?he potential was clearly identified during the 1982 Symposium on Pollution Prevention where business,' gwernmental, and envhmtal leaders met to discuss the concept, share information, and enmurage implementation of a pollution prevention policy. 'Ihe Lqislature responded by empxerhq the Legislative Research Mssion to study the vvdesirabilityand feasibility of creatbg a Pollution Prevention Pays Research Center in North Carolina." The Hazardous Waste Study ca"ission of 1983 was apphM to study prevention, reduction, treatment; incineration, and recycling alternatives to lariifill disposal and to explore the idea of a research mter. The study "ission expnded the objectives to address a dtbndia mste reduction prq" instead of a typical vtresearchcenterv1 solely for hazardous wastes. To implement the waste reduction effort, the canrmission direthat our proposed pollution prevention program be nonregulatory, yet operate in coordination with regulatory and other agencies to meet its goals. The camnission further recammended that the lead program be funded and established to carry out waste reduction and work with other agencies. The developrent and hplemntation of such a waste reduction effort preceded other state initiatives and federal activity. North Carolha is recOgnized as the leading state in the nation in implementing a multimdia waste reduction prqram. With the qpxt of state business and envhmtal leaders, state government has adopted the pollution prevention pays philosophy as a major policy to re3uce hazardous wastes and water and air pollution in environmental protection efforts. The simple goal of the North Carolina program is to find and pramOte ways to reduce, recycle, and prevent wastes before they became pollutants. We have five years of exprience implementing a waste r&ction program. Naw, the Envbmnentdl mptection Agency is leading a national effort for waste "ization, and Congress and state assmblies are considering a variety of legislative approaches, mlic interest groups are strongly advocating pollution prevention aver pollution control. -try and local gwernments must find reasonable but effective alternatives to waste disposal. i rl Secretary of Natural Resources and C"ity Development, P.O. Box 27687, Raleigh, NC 27611

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me Honorable Bruce W. Ethridge Wemrnent is morally responsible for protecting the health of citizens and the environment; therefore, the responsibility for sit- and regulating hazardous waste treatment facilities belongs to government. While hunran health and the envirOnment must be protected regardless of the oost, government is also often held to be responsible for “mic health. In regard to hazardous waste, these dual responsibilities put legislators and gaverrmrent officials in a dilatu~for which there has seemed to be no good solution. Citizens 2ire C”ed Hazardous Waste Facilities Pose Unacceptable and Avoidable Risk to Health and ~~t public opposition to sit& of hazardous waste facilities in North Carolina has bem strong because the majority of citizens believe that any proposed waste facility imposeS risk to their health, envhnment, and econdc well being that are unacceptably high and largely avoidable. These beliefs provide justification for their *‘notin my backyard” stand. At the same the, without adequate waste treatmat and disposal capacity, ecoIxxILic development in the state is likely to begin to suffer. That is why waste reduction is as inportant as any envhnnental and hm health issue facing our state and nation today. Since it has always been and will continue to be less costly to prevent pollution than to clean it up, waste reduction offers us a way to inmediately curb the risks associatecl with hazardous wastes without shutting the door on econdc developinent. ~azardousWaste Redudion Is a policy option with myBenefits Reducing hazardous waste generation offers samething for nearly everyone. Industry can reduce its steadily increasing cost of waste mgement, regulatory cumpliance, sqerfmd liabilities, and other indirect short-term and long-term costs. ?bus waste reduction pmvidPc inauStry with an opportunity to enhance its profitability and campetitiveness at a time when these goals in the face of international campetition have more urgency than ever before. At the same time, waste reduction offers the public a more dinway to reduce health and envbnmental risk than relying on pollution control technologies. ”over, it offers the public an opportunity to curb costly and ineffective replation and enforcement programs. In addition, minimizing the a.munt of hazardous waste we generate will be a key factor affecting the need for additional waste facilities. If waste reduction were pursued as a policy option of equal rank with pollution control, Representative from the Fourth District to the N.C. House of Representatives, Jacksonville, NC. (Representative Ethridge cited a paper, vt€” Facility Siting to Waste Reductionvvby Joel Hirschhom and Kirsten Oldenburg of the Office of Technology Assessment, U.S. ~~ngress,as a so- of information.)

4.1 the need for new hazardous waste rtlaMgement capacity would likely be less than current projections. ne of the most interesting aspects of the relationship between siting and waste zxduction is the clear historical evidence that hazardous waste treatment and disposal facility siting cannot proceed quickly. myyears can be spent on u~.lfllccessfulsiting efforts, as we in North Carolina realize. On the other hard, contrary to popular belief, a significant mtof waste reduction can be immediately put into effect. This does not always require substantial capital investment, time, or basic changes in the p-ction process. Hwever, in spite of pingdiscussion abut mste rrduction and the inherent logic of this policy option, hazardous waste reduction rerrrains largely ignored among the nation's hazardous waste prqnms. In discussion of the need for new facilities nationwide, there have been few attapts to consider the potential for waste reduction. For -le, of the $16 billion spent each year on ernrirormrental protection programs by local, state, and federal governnents, only $4 million--one percent-was spent on k=te reduction in 1986. me rest was spent on programs to control and ranage the waste once it was pmfiucecl. Waste mgemmt budgets in private industry shm very similar patterns. Moreover, for the mst part, people interest& in siting hazardous waste facilities have not been involved in waste reduction, and those interested in waste reduction have rarely participated in site negotiations and decisions. What should be two closely related aspects of hazardous waste mgement are rarely discussed in the same context.

The Relationship between Waste Reduction and IIazardous Waste Treatment Facility Si- Kust be ReCa&zed To hpmve hazardous waste magement programs in North Carolina, the relationship between waste reduction and siting must be recognized. Such recognition would help advance currently policy discussion and improve the climate in which policy debates and decisions are taking place. In addition, aggressive promotion of waste reduction policies could help to restore public confidence in the decision-mkiq pmcess, not only rakitq future siting negotiations more fruitful but also raising the overall level of trust between public officials and citizens that they serve. muse the real problem of siting is a public confidence gap that is not likely to be closed easily or soon, waste redudion offers a way to help the public accept new facilities. It should be qhasized, however, that waste reduction policies and programs are not solely the responsibility of government. Since the industrial processes that generate the waste are largely in private hands, the initiative to zxduce the amount of waste we prcduce largely rests there. when idustry in general can demonstrate success with and &tment to baste &&ion, they will have gone a long way tclward convincing the public that there mins an h-&ucible amount of hazardous waste that must be "aged safely with the best available technology.

4.2 Waste reduction can be an ally of siting efforts and offer better envhmtal proteztion than the mze of ineffective regulations while it simultaneously improves the economic conditions of our industries. TO be able tg tg&tPadvantageof all the potential waste reduction offers, public confidence must be restored in gavermnental regulations and enforcement programs and in industry's willingness to camply with regulations beyon3 the letter of the law to meet broader envhnnental goals.

In North Camlina, considerable discussion has been underway since 1980 regarding waste management, particularly management of hazardous waste. Reccwnendation of the Governor's Waste Management Task Force resulted in passage of the Waste Management Act of 1981 containing a strong policy statement that hazardous waste should be kept out of landfills. The statute reads: "The General Assembly of North Carolina hereby finds and declares that prevention, recyclir~~,detoxification, and rection of hazardous waste should be enaxraged and ~mrnoted.~~In North Carolina, state gavemment has adoptea the pollution prevention philosophy as a mjor policy for environrmentdl protection to reduoz? hazardous waste and other fom of pollutants. The sinrple principle underlying the state's RAlution Prevention is that r&ucing wastes pays off econdcally and enviromtally. ?he goal of the prq" is to find and promote ways to reduce, recycle, and prevent wastes before they bewme pollutants. The pollution prevention pays coqt is that camnercial, industrial, and gwemmental operations can save money by reaUcing the amunt of waste they generate instead of treating and disposing of that waste. The concept becanes more valid every day as the state and the nation win to run cut of waste disposal sites and as the liability attached to waste disposal methods that do not protect human health and the envhnment rises. North Carolina has been a leader in pmmothg the pollution prevention pays concept, and many North Carolina firms have found the concept to be a sound one. These firms have used techniques such as volume r&uction, prcduction process moaification, and recwery and reuse to rdce their overall manufacturing cost. They are saving thousands of dollars each year in waste mgement and disposal and raw rraterial costs. It is my hope that we can continue our leadership role by eq"g'our pollution Prevention m-ogram in technical assistance, research and education, andfinancialassistance. I assure you that the Generdl Assembly is supportive of these programs.

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‘I.- 7 Bill Holman There is a broad base oC flzpport for the concept of pollution prevention and an appreciation of the multimedia approach of North Carolinafs pollution h-evention Program among public interest groups in North Qrolha. The ”tion ccxlncil of North Carolina, the Sierra Club of North Carolina, the N.C. League of Wanen Voters, and the Wildlife Federation have been active lobbying on waste mgement issues in the North Carolh General Assembly. We believe that pollution prevention/wa&e reduction is the best long-term approa& to solving envhmtal pmblerrrs because our min goal is not numerical standards for particular pollutants but results-getting the pollutants out of the envhmt. We are pessimistic-mybe qmical is a better word--about the abiliw of the &-of-pipe envirormrental regulation approach to mhtain envbmtal quality. Limits are not adopt&; limits are not enforced; there will never be enough regulators to check on every pipe. What we need is a different attitude, an attitude that “nits us to pollution prevmtion-wasdx reduction.

The conservation oryankations are really quite proud of North Caro1i”s __-1 Pollution Prevmtion Ragram. One reason we are proud is a sense of “ership in it. We have been proponents of the prqram fmthe beginniq. We lobbied the 1981 General Assembly to have pollution prevention declared a top priority of the state. We have lobbied for funding for the program over the years, and we were involved in its creation. We believe it has a Cmrrmitted staff. We’ve been involved in an advisory amnittee, and we think it represents state g“mt at its best. It brings different interests and perspectives wether in an effort to solve environmental problems. There are not my envhnmental programs in North Qrolh or at the national level which receive tjt.lolehm eminnmental endorsement, but the pollution hvention does. N.C.‘s Pollution Prevention Program Illustrates to C~nservationists II the Value of prap~singAlternatives To errvhnmental groups, the pollution Prevention program represents increasing sophistication among conservation organizations. AS you hw, environmental gmqs have been quick to point out when gmerment, inaustry, or anyone else has done some- wrong. We have been quick to say why a landfill should not go on the edge of a river or why a marh should not be built in a particular spot or why a pennit should be issued or denied. But we have not been as quick to ccune up with alternatives. We believe that waste reduction- pollution prevention is a viable alternative to waste treabent and disposal, and the success of this program has sham us the value of proposing alternatives to envhmtal problems. ri: In the last session of the General Assembly, we took it for grant& that this successful program would have smooth sailing in the budget process and

1 wist in the N.C. Legislature for the sierra club of ~01thcar~lina & the (3”ation Council of North Carolina, 206 New Bern Place, Raleigh, NC 27601

5.1 that Governor Martin's request to expand the program would also have s"th sailing. ~nfortunately,the research part of the program was in a separate dttee, and it was easy for the wmmittee to make a cut. c"ation gruups were very disappointed in the action of the 1987 General Assably in regard to the Pollution Prevention mPgram, and we are planning to work to restore the cut in the research side of the program and to get Gavernor Martin's -ion request throu@ the 1988 session. Enviromtal ~roupsHave specific Ooncerns for the Near Future

I wuuld like to xnake sme observations about what errvhnmental organizations see ahead in the area of waste reduction-pollution prevmtion. These may or may not be trends. It is oux perception that we really are just starting to scratch the surface of the waste reduction-pollution prevention potatial. There are great gains still ahead in this effort. We have started to get s~meof the easy things done, but there is still a lot more potential. several speakers today have touched on the difficulty of siting new waste treabent and disposal facilities. I agree with the point that Representative Ethridge made that pblic confidence is essential in siting new facilities. Although there is probably better enforcement of our envhrrrnental laws f~lw than at any other the in history, public confidence in enforcanat is at the same level or perhaps has eroded. When you go to places like Scotland county or Davidson County, where we have had major controversies Surrounaing proposed facilities, one of the first things the citizens ask is 'what is being done to reduce the waste?'I T3at is a very legitimate a",and until our state guvenrment can answer We have done everythhg we can to reduce the volume and toxicity of wastes,11 it is going to be very difficult to convince the dtythat the facility is needed and will pose a mini" threat to the residents. That is part of what I call %unedtl confidence. The only way to earn confidence is to take meaningful steps. PR does not work to earn confidence. If anything, it drives opinion the other way. me state is going to have to "nit itself to mwdn#ul waste reduction to ~~ opposition to siting facilities. ?hat leads me to another point which is that we do not do very much planning in North Cardha or anyhere else about waste reduction. The GENernor's Waste Kmagement Board in 1983-1984 looked at the waste that was be- sent offsite for treahent and disposal in North Qrolha and "ended some technologies to handle that waste. That should be an annual or biennial process in which we continually assess the waste that is bew produced in the state and what the best options for its prevention, reduction, recycling, and treatmmt are. In the process that the G"r's Waste Management Board used in 1983-84, there was same consensus building-a lot of participation by inaustry and whmtal gmup and some participation by local governments. what resulted was a plan that was not 100 percent acceptable to dl1 groups but that gave everyone a sense of participation and a sense that we were heading in the right direction. I would hope that our state government Wdstart pl- ahead. I am afraid that the Hazardous Waste -bent Ccnranission whose job it is to site a hazardous waste treabmt has not done eMxlgh planning, and I am afraid that lack of planning is continue to cause that cmrnission mjor difficulties.

5.2 1

Anather thing I think environmental grmp will focus on is what I will -1 call ttpmlemtffacilities. For instame , we hew that there are major problenrs withlkxaqulf 3mth in their emissions and their discharge. There seemed to be a bad attitude at Texasgulf as well. A coalition of most of the state's conservation groups calling itself the ttTexasgulfTask Forcetf focused considerable effort on drawing atbation to the ampmy's dssions and discharge. While we cannot take credit for the large fine that was assessed against the wsnpany for noncmpliance with air standards, we do think we have influaced the attention being paid to gettins the disclmqe out of the pamlico River. We think this is an -le of a successful effort by a coalition of conservation groups, and we will be looking at other problem facilities--not onlv inaustr ies but also municipal wastewater treatment facilities as well. We & it is time for these faciiities to clean up their acts as well. We also think that increasiq pennit fees will serve as a disincentive to discharge or emit pollution. We support having the dischargers and emitters of pollution in the state pay some of the cost of qprting the regulatory Prograrrrs- I agree with James Lounsbury that there are different attitudes hI hdustxy. There are many in inauStry, such as those rezedby the Garemor for excellence in waste management, who did not need prodding from the state to take steps to reduce their wastes. There are same who first try a political fix by sending their lobbyists to the legislature and if that does not work then turn to lawsuits. lhis ttlet's-dig-in-and-fi~t-th~lfattitude is very cuunterprductive. me pollution Wvention Program effort, again, represents a hope for working together to solve probl-. Assimilative capacity Is LimiM, can Restrict Developrrent As Roger Schecter mentioned, another thing I think we will be facing North Carolina is llassimilativecapacity.f1 mere is only so much air and water to put bastes into. It tha becanesI a matter of reject- industrial development in areas where assimilative capacity has been reached. mere are scxne areas in the country where another major inaustry cannot be accmmdated because the assimilative capacity of the air and hater has been used up. mis is a situation in which waste reduction-pllution prevention can be a great help. Emrironmental -ups Are Willing to Voluntaxy Approach to Waste Reduction

There has been sume talk at the national level about a resulations requiring waste reduction-pollution prevention prograrrrs. I thi;lk by and larye, North Carolina conservation oryanizations are willing to give the voluntary approach a chance to work. We have been th- the experience of the Categorical limits that EPA has set for effluents and those set by the Nuclear Regulatory Ccmdssion for radiation safety, and we do not think those kinds of prescriptive approaches have worked very well. We hope the voluntary approach will work.

5.3 I keep hoping that samewfere there is a candidate for president or govezbor &o will pick up on the waste re3uction-pollution prevation theme and oonnect it to our national ooncems about efficiency an5 ccanpetitiveness. I

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5.4 WASTE MINIMIZATION: CONCEPTS UTILIZED BY GE-MANUFACTURING FACILITY, WILMINGTON, NC

ROBERT c. PACE^

Waste minimization programs are an integral part of production management at the General Ylectric manufacturing facility located in Wilmington, NC, This large plant site, 1,650 acres, is host to two distinct GF businesses - Aircraft Fngines and Nuclear Fuel & Components Manufacturing. Their products are rotating parts for jet engines and nuclear fuel for electrical power generation. Both of these operations comply with applicable waste disposal regulations as imposed by Federal and State environmental agencies. In addition, those activities pertaining to uranium processing are conducted under a license granted by the US Nuclear Regulatory Commission. Planning and Technology Are Vital To Program Implementation A variety of tools are used in implementing waste minimization programs -the primary ones being Planning and Technology. Planning involves the categorization of generated waste. Beneficial classifications include:

0 Hazardous vs. non-hazardous e RCRA vs. non-RCRA

0 Uranium bearing vs. non-bearing

0 Disposal options

0 Destinations of waste by state Technology as applied at GY, Wilmington, has a very broad spectrum. Occasionally, the correct approach may be a very complex process that requires multi-million dollar investments. Other times an equally effective approach may be characterized as common sense -low cost and simple to operate and maintain. Through the use of planning and innovative technology, the GE facility has reduced the quantity of wastes generated, improved the efficiency of waste management systems both within and outside the company, and converted waste materials into usable raw materials. These actions have not only benefited the environment, but have proven to be cost effective.

1 Manager, Powder Production Unit, Nuclear Fuel & Components Manufacturing, GE, P.O. Box 780, Wilmington, NC 28402

6.1 .. Specific achievements that are noteworthy include: An ammonia recovery system was developed and installed to replace a conventional air striping operation for ammonia removal for a large volume waste stream. On site beneficial reuse of 800 tons of ammonia annually was achieved.

e Developed a market for a used sodium hydroxide solution. The benefits were two fold: the sale generated revenues and precluded the need to annually purchase 87 tons of sulfuric acid used in neutralization of the sodium hydroxide prior to discharge.

0 In conjunction with Federal Paper Board Company, a biological destruction technology for ammonium nitrate was developed and implemented. Under a mutual benefit agreement, 4.5 million gallons are transported from GE to Federal Paper each year, This program not only allowed Federal Paper to reduce the amount of purchased ammonia added to its biological treatment plant, but also provided GF a controlled, economical disposal method and precluded the addition of ammonium nitrate nutrients to a receiving stream. Realized a 90 percent reduction in the volume of spent machining coolants by use of a relatively new technology - ultrafiltration. Eligher molecular weight coolants are separated from the water base, which is ultimately discharged after further treatment. Newer facilities have been designed with essentially a zero discharge system. The recycled coolant process produces a very small quantity of oil and solids as a waste. e Achieved and maintained over a seven-year period a 70% reduction in the amount of low level radioactive waste generated for burial each year. The keys to a successful program such as this have been education and training of employees, assignment of a responsible person during the initial stages, a comprehensive study of all the sources of waste, and the realization that no single solution is the answer.

0 Installed a state-of-the-art incinerator for the recovery of uranium in contaminated, combustible waste, thus reducing the volume of waste by 95%. The uranium state was also changed to a more recoverable form.

0 Installed processes that reduced the uranium content in a calcium fluoride sludge sufficiently to re-classify this waste from a low level radioactive waste to a

6.2 chemical waste. A dewatering process was also installed II to reduce the current generation by 70% prior to dksposal as a chemical waste. Efforts are currently underway to find a market for reuse of this material.

0 Developed a central trash sorting facility for the site. Significant cost reductions have been made by compaction of trash, removal of material for sale or reuse, and the elimination of contract services. Risk control is another realized benefit as all trash is inspected for n hazardous material during the sorting operation. These examples of waste minimization demonstrate GE's commitment to protecting the environment while providing efficient and :p cost-effective methods of managing waste.

J €. 3 J '1

Lr3

J 1

nl recent years there has been mch aiscussion about the similarities and differences in environmentdl protection approaches utilized in Europe and in the United States. Some American researchers have said that European industries are *+way ahead of their American industr ial counteqprts!** and have cane back fm brief Eurapean visits with **lessonsfrom Europe.** On the other hand, same Eurapean researchers have visited the Unit& States briefly and have returned to their countries with statements about American inttustr ies that are Way ahead of their European industrial counterparts,11and have presented their versions of l*lessonsfrum the United States.** Is each group correct? Yes! No! Wing the last three years, I have worked in seven European countries for a total of 18 mnths. Based pnthe okemations I have made, I can say that there are excellent lessons to be learned by gov-tal and industrial leaders fran each other on both sides of the Atlantic. Concepts, policies and technologies are being developed and implemented in some Countries and in sane firms in Europe that would benefit American fhns and our ernrirOrnent. Simi.larly, Europeans can also learn much from Arerican experiences. A few -1es of both types of lessons are summarized in the following paragraphs. The lbntreal. Protocol on Substances That Deplete the Wzone UyeP The *Won- Pmtml**has been hailed as an encouraging example of the beginning of a new era in international errvhrnnental efforts to help prevent or to rectuce pollution. The Montreal Protocol is designed to help "ize further destruction of the ozone layer that protects all life on earth from excessive W energy fran the sun. me proposed date of entry into force (EIF) of the meaflves within the Montreal Protocol is January 1, 1989, provided amugh nations have ratified the Protocol. Six mnths after ED, conslrmption of the controlled substam=es must not exceed the 1986 levels. After July 1, 1993, 'c0rE"ption rrmSt no exceed 80 percent of the 1986 levels. After July 1, 1993, cowionmust not exceed 50 percent of the 1986 levels. mere are II many exceptions for **developingcountries,** and nonsignatory nations me Swedish Minister of the Envhmt, Biryitta Dahl and her actvisors agree with many scientists who say that we must phase out the use of ozone- %

Professor in the Division of University Studies, North Carolina State Univexsity, Box 7107, Raleigh, North Carolina 27695-7101, USA. F" August 1987 t0 August 1989, he is Visit- Professor, UniverSity of Lund/T E M, in Imd, Sweden. Mailing address: University of Lund, T E M, Box 62, Asunqatan 38, 275 00 Sjabo, meden. d 7.1 depleting ccarpaurds mch faster than what was agreed upon in Montreal because CFCs are definitely causing a much more rapid and extensive.. ozone layer l5L"g than was previously anticipated. merefore, Muuster Dahlhas proposed that Sweden mandate CFC usage be reduced by 50 percent in two years and that all uses be eliminated within five years. She has proposed support for extensive research on safer altermtive substances and processes. Same processes an3 pmducts, previously utilizing CFCs have already been change3 to other proaesses or axpour& that do not destroy the ozone layer. Other uses, acconling to a series of Nordic studies, will be replaceable within the timetable outlined We.

IsthisaSca"' vian dream or is it possible? "=rsations with SXE industrial representatives lead one to conclude it is a dream and that the Montreal pratocol contains a yeaso on able^^ timetable for phasing our the use of ozone-layer depleting canpun%. Cornrersations with otha industrial represerrtatives lead one to conclude that the Swedish plan of accelerated is technolcgically feasible. wrt is it economically sensible? Is it ecolcgically sensible to destroy our ozone layer? What do we have to learn frm this debate? What do we have to contribute to this effort? European Initiatives to Reduce Heavy Mew Pollution fran Batteries The response to the ozone layer issue illustrates one facet of Swedish envhnmental leadership. Another, quite different example, pertains to the reduction or prevention of societal and environmental pollution frcnn cadmium and mercury. The Swedish gcnrernment has worked with xlarry industrial branches to help them irrp?lement ways to reduce their use and release of these elements. As a consequence, industrial emissions of heavy metals have been substantially redud in recent years. However, mk.sions of these metdLs fmm consumer dkposal of batteries is nm seen as an increasingly significant and unacceptably laxye scxvce of heavy metal pollution. Voluntary collection of batteries on a nationwide scale in several European nations, hcludbq Sweden, has not reached the desM effectiveness; therefore, an htemational meeting was held in Sjobo, Sweden, March 10-12, 1988. One conclusion frurn this meeting was that depsit-based battery collection systems will soon be implemented within sevd European countries. A second conclusion was that international cooperation on the bplementation of such deposit-based battery collection system is essential. A third conclusion was that international cooperation is desirable for research and development of envhmentally safer systems for the recuvery of the metals contained within the batteries and for the development of batteries that contain less of these toxic heavy metals. I3 my estimation, we in the United States and Canada, should also implement nationwide, deposit-based battery collection systems as one way to prevent or reduce this source of heavy metal pollution throughout the United States and Canada. Further, we should join in joint research and development efforts to develop better systems for the recovery of heavy metals fran the rekuned batteries. Additionally, we should support resear& on the developat of envirornnentally friendly batteries.

. 7.2 1

International Workshop on Clean Technologies and c1 Product Design Held in Vienna The Austrian section of the International Association of clean Technologies sponsored a workdmp Vienna, Austria, on February 24 25, in *. and 1988. The wr>rkshap focused upon a number of issues to cleaner technologies and prodtuct design. Space in this fll~nmarydoes not permit a ample- recap of the items addressed; hmever, it became evident that much more UTternational cooperation is needed in the co"ication of results of new Waste-rebucirrg and pollution-pmenting technologies for the prcduction of products naw being produced.

Additionally, the conferqes concluded that in addition to inrpming the manufacturing processes of axmmtly produced items, priority attention should be given to the devd-t of criteria to be used to guide the developnent of new procblcts. The design criteria would help product designers and manufacturers consider the life-cycle impacts of their products as they design them. Such efforts would address factors of raw materials ccnrrposition and production, prcduct manufacture, consumer use of the products and disposition of the products at the end of their %seful lifetimes.1g Issues perbmmga. to prcduct safety, durability, repairability, reusability and recyclability are amng the factors that shauld be addressed by the pnduct design criteria. In my estimation, American creativity in the design of proztuctS that are environmentally friendly in the ways discussd in the conference in Vienna would help to reduce and/or to prevent pollution in the future. lhis could be the next, very important thrust of the U.S. EPA and of the North Camlha Pollution Prevention Program. It would be possible, through such efforts to effect pollution prevention in a more "p&ensive and effective than is possible today by foc=using upon waste reduction pollution prevention- and within present+y production facilities producing present-day products with present-day prcduction processes!

The Gerrtlan 'IBlue Angel11 approach to evaluate and label prcducts for the mironmental friendliness, is seen as one step taward encouraging prcduct designers and producers to inc;rorpOrate life-cycle envhnmental considerations int0 the design and prcduction of their products. Sweden is giving serious consideration to the implementation of the IIBlue Angel,I1 System. Similarly, Canada is quite close to implementing a similar program. krhaps the Unit& States shdd also give the "Blue serious consideration as one hst"ent for encouraging SOciety-Wide emphasis upon Pollution Prevention.

Sweden Will Phase out mclear pcrwer Before a'.ternobyl, many Eurapean countries were planning on placing hereasing reliance upon nuclear mer. Since then, huwever, xrany are rethinking their entire energy programs. According to the Wedish Rlviromtal Minister , Bbgitta Dahl, Sweden will begin to phase out nuclear per in 1995. 9310 nuclear reactors, one at Barseback and the other at Ringhals, are to be closed in 1995 and 1996. The loss of electricity output will be -de up by means of econcmization on a gigantic scale, beginning

7.3 immediately, and by apanhng* such alternative power sources as gas, hydropower, and wind per. Electricity prices will rise gradually. Special working parties are to investigate ways of sustaining industrial output and emplayment during and after the change-uver.

Sweden, with 8.5 million residents, will hest the equivalent of $16 million per year on the developmnt and implementation of alternative energy approaches and $66 million to be utilized during the next five years for energy I conservation activities. Similarly, very ambitious efforts to move increasingly tcrward reliance upm energy conservation and renewable en- sources are under way in Denmark and other European countries. iI I urye North Carol~ansto take a careful look at the Swedxsh andDanish efforts to reduce waste and to prevent pollution through fundamental structural I changes in their energy systems. I urge the United states as a whole to also I take seriously their responsibility for help- to ensure our children's future through emphasis upon energy mnsemation and upon safer energy sources. \ f If the United States were to invest at a proportional per capita rate as the Swedish will be during the next five years, we would allocate $4.67 billion. I believe $4.67 billion irnrested in eneryy conservation and alternative energy soun=es during the next five years, instead of being I invested in new and better ways to kill people would help the United States to take seriously their stated priority of pollution prevention. present-day governmental investment and regulatory actions speak much more loudly than all I the high-so"g' political rhetoric! This conference is a waste of time for all of us if we don't make a nwtber of f"tal changes in our actual priorities! I recmmnd that those factors referred to in the forqoing paragraphs be among thc5e mes. I Swedish Ernrironmental policy Tcrward Waste Reducing- i Pollution preventing pgproaches I I stated earlier that there are lessons to be learned on both sides of the I Atlantic. I wish to highlight several such lessons Eurapeans can learn frm I us. First, since 1975, it has been Swedish Envhmtal Policy to place full responsibility upon the producer through the so-called, ~"-oducerbys I Principle." this tenn, it is implied that each producer is responsible for the envhrm-te.ntally sound management of prduction wastes and of co~lsumer wastes. In spite of that 1975 policy statawnt, it was not until December of i 1987 that the Swedish Parliament demanded that the Swedish National Envir"ental protection E?oard develop plans to implement that principle. The Environmental Pmtection Board, in January 1988, asked my colleagues at TEM in i the University of Lurid to develop the policies and strategies for hplementiq waste reducing and pollution preventing technologies thmughout Sweden as a way of actualizing their 1975 priority policy. I In one way, this was a giant step in the direction of implementing this policy. Hmever, since the Whnmental'mtection Board only asked for programs and policies to focus upon ways to reduce or to prevent the producrtion 7.4 of solid and hazardous wastes and didn't also ask for enp3hases upon ways to sinniltaneously reduce air emissions and water emissions, they missed an hporkmkm of the opportunity. The reprt that was developed and submitted wat mu& further than what the ,Swedish National Ehvhnmental Protection Board requested and included emphases upon an integrated, systems approach to pollution prevention and to waste and toxicity reduction. myof the recammendations were based pnmterials published in the United states during the last three years on all the areas addressed by this conference. In that respect, the term ttlessons from the United Statestt is sppropriate. l?ractical Experiences Helping to Change Swedish Industrial Practices My colleagues and I are currently engage3 in a project with seven small and medium-sized industrial firms in Iandsl;roM, Sweden. ?he project is designed to de- ' if the waste reducing and pollution preventing concepts that are working for scnne American and Canadian firms will also work for Swedish firms. It is clear, six mntk into the project, that these concepts and approaches function well within Swedish finns also.

We are working with each firm's management and with their employees in help- them to utilize the systms approach to systemtically perfom waste reduction audits. In the process we, tcgether with each firm's staff, have identified several significant policy and technological changes each firm can make that wmld result in significant reduction in wastes produd. We are in the early stages of aaluating alternatives for saw of the changes. TNO of the changes are highlighted as lessons two and three from the United States.

Lesson two frat the United states pertains to a printing firm that specializes in print* on polyethylenebased materials. lxlrhq 1987, this fhn released 47 tons of volatile organic canpmds (VOCS) in to the atmosphere of the Mhnaregion. (meir official air emissions permit allmd them to release up to 50 tons of VOCs per year.) Based pnanticipated in prcduction, they requested pemission to release 70 tons of VOCS during 1988. Ihe loml er~~hmtalauthorities Said, "No, you must decrease your missions during 1988 to 15 tons of vOCs!lt What can this fh's management do? There are several options, but the one that looks most promising is for them to change fmn organic-wlvent based inks to water-based inks. ~ay 16th of this year, we will have a day-long seminar for this ccnrrpany and for Scandinavian printers, ink suppliers, and printing equipat suppliers. !the semhr will be led by Amko Plastics mident, Mr. George MaJrauer. He and his fhhave successfully changed their printing on polyethylene fm organic- solvent based inks to water-based inks. He has also implaenated the prahction of biodegradable plastic at this firm. (Incidentally, Mr. Makauer will share his experiences at this conference as a speaker in concurrent session N: Waste Reduction-pollution Prevention in the printing Industry.)

Lesson three fmn the United States pertains to two metal working firms that currently use substantial quantities of trichlorcethylene in their metal degreashg processes. Their challenge is to reltuce reliance upon the use of trichloroethylene as a degreasing agent. 7.5 1

me option that is most prclmising and which is being evaluated in tests in Lands)uoM at this "ent is to use a --emulsifiable, bidegradable I -acanpaund extra&& fmm citrus fruit rinds. Ihe prcduct contains no chlorine ccBnpOundS and therefore does not present a risk to the ozone layer. 1 Its toxicolqical properties and bidqmdability also mke it look like a I favorable candidate for replacing trichloroethylene in dqreasing operations. The material prepared and marketed by petrofm Inc., of FeIT"' Beach, Florida, under the trade name of BIOACT, has reprtedly been successfully used I by AT&T during the last several years to replace same of its three million paund CFC usage per year in the cleaning of their print& circuit boards. lhus, a new American product made from a biological source looks very I interesting as a partial or complete replacement for trichloroethylene in metal degxeasing operations and as a replacement for much of the ClEYls currently used in the cleanirrg of "electronic circuit board assemblies. I Many other examples could be presented of U.S. lessons for Europeans. certainly all of us have mch to learn from each other nationally and internationally in this dynamic and exciting area of pollution prevention and I waste reduction. I wonder what successes we will be able to discuss in North Carolina six years from now. I I I i 1 1 _J

i i

7.6 f 1 1

Greg Piner

The Naval Aviation Depot is one of the laryest industrial facilities in eastern North Grrolina, employing about 3,200 people. We aisassemble aircraft, rework parts, add new parts, and reassemble the a-ft. As part of that operation, we supply engineering support for our reworked aircraft, so part of our facility is industr ial and another part is engineering. My position is in the materials engineering laboratory, which bridges both those areas. I am responsible for materials and processes for the electroplating and, in same ways, the paint-stripping operation for the industrial facility. I am also responsible for the integrity of the parts as they leave the facility. Solvent waste frum paint stripping and wastes fmm chromium, c&mium, and silver electroplating operations are among our most important environmental concerns. cur c=h”ium plating operation is significantly different frm typical cmmrcial chromium plating. our coatings are functional and are measured in thousandths of an inch whereas carmnerical chmmium coatings are in the millionths of an inch range. A typical plat- cycle for an amftpart- -for instance , c=h”ium plating the inside diameter of a connecting link for a helicopter rotor head--would require four to six hours in the plating tank. That’s plating at about 2/1OOOths of an inch per hour to build the part up to mer the finish dimensions so it can be ground back dm. In addition, we deal with far fewer parts than carmnerical operations. Recent interpretations by Region IV EPA have reqkred that we make same fairly drastic changes in our water use ard wastewater generation. We have a premtment qstm for wastes fmn our industr ial operations. After being pretreated, the wastewater goes to our domestic wastewater treatment plant, achis the same as a municipal wastewater treatment plant. me ~urce Conservation and Recovery Act (RCRA) Section 261.4 excludes frum hazardous waste regulation any mixture of d&ic sewage and other waste that passes through a sewer system to a publicly owned Treatment Works (m)for treatment. However, EPA Region IV ruled that our wastewater treatment plant is not a FWIW and requird us to either (1) treat all sludge fmm our dcrmestic wastewater trealmmt plant as RcRA-contolled hazardous waste or (2) eliminate industrial aischarges to our d&ic system. We decided that disposing of all OUT sludge as hazardous waste was not an option we would consider because of the landfill burden. Therefore, we were faced with detemunmg.. , in a matter of a few week, if there were an acceptable alternative to contracting all our work out. Obviously, the alternative was zero discharge, but we had to discover haw to accamplish that.

We were already doing some recycling in OUT hard chromium plating operation, which, as I stated before, is different frm a typical Commerical chrmium plating operation. We were operating a straight chrmic acid and

Chemist, Naval Air Rework Facility, U.S. Marine Corps Air Station and Naval Aviation Depot, cherry point, NC

8.1 I sulfuric acid bath operated at 140 degrees F Whi& is very tolerant of fairly high aegreeS of metallic impurities and had been able to use a static rinse I system in which the rinse waters go fram the rinse tank back into the electroplating tank. We were essentially operating the chnxnium plat- I aperation with no wastewater disdmqe.

Hmever, we did have pmblems recyclw into tanks such as cadmian plating that were not heated and required close control of bpuritie. It is i the height of folly in a cadmium plating operation to recycle rinse waters for several months and then find that due to contamination caused by recycling you no longer have a good admiun plating solution. You will have created mre hazardous waste by having to aispcxSe of the tank than rinse waters would have I -ted in severdl years. We mged to solve our problem and reach zero discharge by using a I cmnbination of &/water spray rinses and static rinse tanks. We were operating with nonnal overflaw rinses that were conscrming at least five gallons of water per "te, which amounts to 300 gallons of water per hour and 5,400 1 @lo= of water in 18-h0ur, two sfiift day. Most of that water was clear because, unlike many rack plating operations, we did not have a tremendous amount of drag-out. Nonetheless, we were using 5,400 gallons of water a day per tank. We did same quick calculations with cur air/water spray guns (which I uses a small a"t of water and provides force by canpressed air) and found that by using the ah/watex spray gun we could reduce cur per -per day water consuption to 12 and 15 gallons of water per day. We thought that with I that small quantiw of water we might find an econcnnicdlly feasible way to evaporate the water. We design& a system in whi& we pump water from the a&/water spray I rinse tank to a heated tank. The evaporation rate of water in the the heated tank is much greater than the quantity of water we use. We initiated use of this system about August 19, 1987, and dcrmped the tank for the first time on I March 29. Wing that time we had generated about 110-120 gallons of sludge which will be disposed of as hazardaus waste. By mnparison, if we had been aperating our overflcrw tank rinse system during that same time period we would I have used about one and one-half million gallons of water. Reducing wastewater fram our plating operations solved for the short-term i our waste disposal problem. In addition, we found that Pursuing waste reduction is very positive from a production standpoint in that it reduces materials consumption. -1 i 1

8.2 George MdRae

-dyne, located in Sanford, NC, prodtuces plumbing pm3ucts, and in the process produces various wastes. Degreashg, brazing, bright-dipping, plating on zinc di- ' and on brass parts all generate wastes. Our purpose in being in business is not to produce wastes but is to p"!e prducts that can be sold at a reasonable price. In 1982-83, we enbarked on a waste-reduction program with the goals of reducing hazardous waste dispcsal costs, using raw materials mre efficiently, reducing wastewater treatment cost, and, therefore, helping keep our products cost cmpetitive. Other benefits realized from implementation of the cxxnprehensive waste reduction plan were to reduce long-term liability, to ease cumpliance with state and federal regulations and to help maintain good c"ity relations. The fixst steps in our waste reduction effort were simple but had himediate effects. For -le, by using simple waste reduction methds in our zinc die-casting operation, we achieved a 20 percent reduction in chemical cost per hour in our fixst year. In our brass stripping operation, we achieved an 81 percent r&uction in chemical cost per hour. With a 15 percent production .hxease zinc die-cast plating, a 56 percent prahction bcrease of plating on brass, and a 35 percent production increaSe in bright-dipphg, we achieved a 20 percent reduction in wastewater treatment chemical co5t. Further, during this micd when our production went up, our sludge generation increased OfiY abaut two percerrt. We a-lishd all this without adding any equipment. I am going to talk about scrme of the simple first steps an electroplater can take to achieve an immediate a 20 to 25 percent waste reduction with very little investment. Analyze your wastes: One way to start your waste reduction program is to analyze your sludge to determine its composition, with particular attention to water. You may find, as we did, that there is a substantial percentage of water in your sludge and that simply drying sludge can help reduce disposal costs. Be aware of mtchemicals you're us- and what wastes you're creating in your prduction processes. Copper build-up in the sulfuric acid dip used to remove copper oxide frm brazed parts can be plated out as copper metal and thereby avoid prcduction of metal hydroxide sludge. Identify chdcal loss: Analyze your processes to see where chdcal loss is occurring. muate sources for potential reductions. 1) Evaluate plating bath concentrations and consider lawering than if it can be accorrrplished without causing plating problems.

1Stmadyne, Inc., 2609 Cox Mill Road, Sanford, NC 27330

9.1 2) Maximize drip tim by alter- xnachine motion but beware of Creating dXyQnS.

3) “e rack designs by streamlining rack configurations and by racking parts so that dragout is “ized.

Filters: Evaluate filter types, filtering methds and the process you use when your filters are changed. Filters are there to remove particles fram the plating solution. when we change filters, we hook the low-pressure air up to the bleed-off valve on the filter and transfer the solution into another tank so that when we change the filter we can reduce solution loss. We have changed fm plastic cylinder type filters to horizontal paper filters which has rwastesandcost. Tank clean-out: Evaluate tank clean-out procectures to determine if losses can be redud. Quality control: Consider the effectiveness of your quality-control program. Stripping and reprocesshg defective parts produces more than three times as mchwaste as making the part right to begin with. Pre-inspeCtion of parts to detect defects before they go thrcplgh the plating process can be very helpful. mills and leaks: ?he mst important thing is to pay close attention to spills and leaks. If you have a leak, fix it. It’s that sinple. If you have a spill, figure out why it occurred and how you can redesign your system to prevent spills in the future.

9.2 1

ATMOSPHERIC EVAPORATIVE RECOVERY 1 ON A NICKEL PLATING OPERATION Brian E. Wells 1 and Gary E. Hunt

Ilco Unican Corporation, the world's largest key blank and security product manufacturer, operates a plant in Rocky Mount, NC, which produces primarily key blanks. Approximately 80 % of the key blanks produced are nickel plated. The nickel plating process, like many other plating processes, produces rinse waters containing inorganics, which are hazardous wastes under current EPA regulations. In recent years, Ilco Unican Corporation has processed its rinse waters by several methods. The most recent method has been neutralization by adjusting the pH, clarification by flocculation, settling, filtration and compaction of the sludge generated, and then disposal of the sludge in a hazardous waste landfill. Using this method of treating wastewater and disposing of waste, Ilco Unican incurs considerable cost and liability. The pretreated rinse waters generate approximately 12,500 pounds of compacted sludge every 90 days. Although the pretreatment system is virtually automated, considerable labor costs are incurred in handling the sludge. The filter press requires dumping twice weekly. Approximately six man-hours are required to make each dump. The annual labor costs, including overhead, are estimated at $14,480. A roll-off container is rented on a monthly basis to hold the sludge, adding $3,000 a year to sludge-handing costs. In 1986, the cost of transporting the container to the landfill was $3,351, and the cost of disposing of the sludge was $4,300. The sludge represents the loss of about $4,000 worth of metals. Adding all these costs shows that managing sludge in this manner costs Ilco Unican $29,000 a year. This does not take into account liability associated with the waste and compliance costs associated with EPA regulations. As EPA regulations become more stringent with regard to landfilling hazardous waste, Ilco Unican Corporation must make every effort to recover valuable metals from plating waste and thereby reduce, or if possible eliminate, its plating waste.

' Plant Engineer, Ilco Unican Corp., 400 Jeffries Road, Rocky Mount, NC 27801 * Pollution Prevention Program, Division of Environmental Management, N.C. Department of Natural Resources and Community Development, Box 27687, Raleigh, NC 27611

10.1 After evaluating several recovery methods, Ilco Unican decided to investigate the feasibility of applying an atmospheric evaporation system to its electroplating operation. Evaluation of results of this investigation indicates that it is feasible to use this process to close the loop on the electroplating line and recover all constituents of the electroplating solution. Atmospheric Evaporation Process Is optimized by High Air Temperature, Low Humidity, and High Air Flow The atmospheric evaporation process as applied to an electroplating process involves the installation of evaporators near the electroplating or nickel plating baths. Consideration should be given to locating the evaporator close to a source of clean and dry air. A continuous flow of air which is humidified by the electroplating bath is drawn off and expelled to the atmosphere. Unsaturated air absorbs moisture from a wet surface. Therefore, as the relative humidity drops, the evaporation rate increases. Head space or room is created in the plating tanks by taking advantage of the air's ability to absorb water while leaving the valuable constituents of the bath behind. The water evaporated is replaced by water from the rinse cycle. Figure 1 illustrates the evaporation process. The electroplating bath solution is pumped through the feed line to the two spray nozzles on top and one spray nozzle in the middle front of the evaporator. it is then sprayed over the packing material while air is pulled through the packing. This causes the water to evaporate from the plating solution. The humidified air is then expelled to the atmosphere through a duct. The bath contents which are not evaporated return to the original bath by gravity through a drain line. The replacement of evaporated water in the nickel bath is accomplished by pumping from Rinse #l. The amount of replacement is determined by the evaporation rate via a level control in the nickel bath. Simultaneously, counterflow from Rinse j2 and Rinse #3 occurs as the level in Rinse #1 drops. As the level drops in Rinse #1, a solenoid valve is opened allowing for deionized water to enter Rinse #3. Evaporation rates vary and are determined by conditions of the surrounding air, temperature of the solution, and flow of air. Conditions which favor evaporation are hot air, dry air, hot solution, and high air flow. Figure 2 shows the equipment manufacturer's actual and theoretical evaporation rates. Actual rates, according to the manufacturer, are results reported by users of the systems.

10.2 Samuel B. Moore The textile hdustry is a diverse and ever-changing mufacturing segment of the North carolha eco~xny. To meet the challenges psed by foreign imports, environmental control costs, and campetition fram other industries for our qlayees, the textile industq must "ize the prduction and impact of the waste it creates. Definition of Waste IS central to understanding Waste Reduction

Waste is a by-product of "facturiq that costs real dollars to reTiKxre fmthe production facility. For -le, thermal waste (heat) generated in mufacturing requires re"al by air conditioning to create a suitable workplace. Chemical waste generated by a cleankg mchh in a maintenance shop must be disposed of under FCRA regulations as a hazardous waste. Wastewater created by the dyeing of fabrics must be pretreated to re"e certain constituents before being discharged to a municipal FWW. This requires capital expenditures to build a pretreatment systm. Waste "ization is designing n-anufacturing systems to achieve the lowest possible volume of waste per volume of finished g& produced. ?his can be sham by the equation: Was* volume/volume of finishd goods = waste volume per unit lhis equation can never equal zem unless zero waste is prcduced. mis is not possible under current technology, but as dl energy and matter became precious, as resoul~esbewme scarce, what is today's waste heat or spent oil bewmes tomorr"s raw materials. The qineering challenges facing tday's textile wufacturer be" a problem of moving wastes or creating wastes that can be used as raw materials for further operations. An example of waste minimization is one of heat exchange. Waste heat fmthe ayebath of a dyeing operation should be used to Meat the next batch or used to heat the building in which the operation is housed. Another example: a hosiery mill dyes pantyhose that contain 2-3% OWG of mineral oil and butyl stearate as process lubricants. when one-hundred- thousan3 (100,000) pxnds of yarn are dye3 monthly, it creates 3,000 pounds of oil per month that must be treated in an activated sludge plant was waste, rather than utilized as a fuel for their boiler. What is lacking is separation and economic incentives to reduce this waste.

President, Burlington Research, Inc., 615 Huffman Mill Rd-P.O. Box 2481, Burlhgton, NC 27215

31.1 pollution prevention is optimization of mufacturing systems to lessen the envhmnental impact of the waste that is produced. pollution Index = mxicity - waste Volume A-oduced AS toxicity lessens, the pollution index approaches zero. Toxicity issues, frum aquatic to genotoXicity, will beccnne mre important as health and envhmnental concerns are voiced. The relative costs associated with us- &n dioxide as a supercritical fluid for dyecleaning became insignificant if 10% of the cancers found in employees in dyecleaning shops are determined to be caused by perchloroethylene or dyec1eank-g fluid. %e incentives for industry to use pollution prevention and waste “ization techniques always derive frcm-i regulatory or ecodcal considerations. Usually the two are interrelated. For example, the cost of sewer services for the dyehouse begins to approach $50,000 per month due to regulations forcing the municipality to build a mre efficient KYIW. A wastewater treatment plant Costs the co~i~pany$500,000 but will save $2,500.00 per month in sewer-use fees. Therefore, after 20 mnths it is possible to reamer the investment. In other words, econdc incentives caused by haeased regulation force waste minimization.

Practical Steps to Minimize waste Production in Textile mehauses 1. No matter what the age, have a scherrratic drawing of your plant shming all electrical, air, water, sewer, steam, and other utilities. Knclw where all drains lead and where they hterwnnect. 2. Force the dyehouse to pmve they have optimized all process fonnulae, amunts of chemicals usd, and the way the dyehouse chemicals are measured. With new experimental design software (such as is offered by BEN in their E1 series), prudent experimental design can shm dramatic savings by formulae optimization.

3. Chemical structure and persistent toxicity data must be h”on eveq chemical wmpound that is usd and must ultimately be disposed of. If a chemical is shm to have hurran health effects or erwironmental persistence and there exists a viable alternative- -use it. %e long te.nn costs associated with using la” cancer- causing agents, or environmentally persistent CcrmpOundS, will be higher than the higher costs of using a less toxic, alternate CcBnpCIund. 4. Understand and measure the waste h“irg on raw mterials. For -le, if a mill is buying fibre which costs $5.00/pwnd and the fibre contains 4% of process lubricants or oils, for every 100 pounds of yarn you buy you also buy 4 pmds of oil at $5.00/pound. Many of these lubricants are necessary, but knming hm much is necessary and hm to measure and control this parameter is an .important step in reducing waste and pollution.

11.2 ...... 1. .. Qonclusions "I %ether or not the textile industry survives the current onslaught of hipart& produds or the hcreasing burden of envhnmental regulation depends on its ability to "ize waste. Waste "ization reduces costs, increases 7 productivity, and ensures long-term gmwth. Public pressure is increasing to reduoe the hpct of this industry on the envhmt. Without increased efforts for pollution prevention and waste reduction, the textile industry will -.-1 decline. The American public will view the cheaper foreign textile product as a product that is produced on the other side of the world and is, therefore, not polluting their whmnent. This is a misunderstanding of the problem, but the American @lit is not used to thhkirg in terms of worldwide pollution. Reduchg textile wastes is critical in aadressing the problem of aquatic toxicity. Of the 10 aquatic toxicity reduction evaluations we have worked on in the last 5 years, mostly municipal, the textile inaustry was the mjor pollution-using source that had to be reduced to achieve lwer aquatic toxicities. muse of the large VO~LIIIES of water used to pmcess our fabrics, yam, fibres, and garments, we are a target. pollution prevention and waste "ization are the hope for our inauStry to "pete and thrive during the next century.

31.3 1 n

:I 1 -1 3 I1 :I

A. 1

J It would be gwd to go into industries and research universities and find doors with signs that say 'Waste Reduction Research,tt but I can tell you that is not the case. In fact, what we find is that we are making progress in waste reauction, but we have yet to clearly identify long-term waste reduction resear& nee%. We are, hawever, taking a fhtstep tclward identifying those needs.

In about 1980 a small number of engineers and scientists began suggsting that waste reduction, or waste minimization, could be an effective bay of reaching erdpints such as those listed under FCRA. While the concept emerged in the area of hazardous waste, it soon became evident that the biggest potential might be in the air and water regimes. In the early years, those of us involved in research took the view that the waste reduction effort would best be served, not by research, but by a simple change in philosophy. We felt that most helpful effort at the thwould be for the cbemical engineering and engineering "unities to go out and produce same results in the area. We thought that once the effort had gotten underway and sc~neresults had been documented, we could then be$n to determine research neads. It was our intuition at the time, and 1 think it has been shown to be correct, that a lot of the first steps in waste reduction are things that we already knm haw to do.

Three stages of waste Reauction Developnent Are Evident obviously, there is a need to go beyond the first, easy steps. To reach the full potential, waste reduction must be about more than changing a few valves or trying to select for less hazardous chemicals. If the "nitment to waste reduction is to continue over the Coming decade, we need to be able to attack s~meof the mre difficult problems.

Frwm wfrat we have learned so far, it appears that the development of waste -&ion contains three phases. The first are readily implementea techniques, involving prkily technology transfer and equipment market development. For -le, to reduce the generation of waste solvents today, you put in a solvent still. ?hat is fairly well knc;rwn, even though there are still myinauStries that have not decided that they need to take this step. The second phase involves experimental, or innovative, engineering aimed at chemicals that we know intuitively have a reasonable potential for reduction. By intuitively 1 mean that when an chemical or manufacturirg engineer looks at

1 mfessor, Department of ~1.lemicalmineering, BOX 7905, ~orthcar~lina State University, Raleigh, NC 27695-7905.

12.1 the process, he autamaticdlly says, 'We really ought to be able to reduce that." Reauction in this phase does not come very clearly out of the volume of but more out of the ~tureof the chemicals, the ecodc potential for reduction, or possibly the toxicity. In this phase, obviously, a greater a"t of e>qwrtise is required. The third phase involves process technology, manufacturing concepts, or significant wastes for which there are no obvious reduction tedmologies or opportunities, and evolution into this phase rquires a long-tenn dtment to research. National science "dation Panel Examined Waste Rebudion Research Needs In November of 1987, the National Science Foundation convend the Engineering and Science Panel on the Future of Industrial Waste Reduction to learn fmindustry's perspective what the needs are for waste reduction research. The panel was almost exclusively of repr=atativPc fm11 industrial groups. The first thing we did was to have all the industrial represmtatives list topics that they consider& to represent research needs in waste reduction. Then, once we had a list of topics, we tried to interpret the list in terms of generalized, or themes across industries. Mple involved in research 3" fmexprience that research dollars in waste reduction are very few and that small research efforts have to go far. Therefore, we caphasized the transferability issue. After going through these exercises, we identified three broad kinas of research needed to facilitate further waste reduction over then Ccrming decades. To ame up with the first area, we siTIp31y asked, "If each of you went hto your manufacturing facilities and implenentea what you lcnaw you can do and what you can reasonably assume you could do with a certain amount of innovation, would you have reached zero waste?11 The answer was almost Universally, I'No." So, we asked What's left?" and whatever was left is one of the crucial areas for research. Another broad area for research is in new and meryb-g mnufacturhg technologies. state and federal pnqra~need to be able to track new technologies and introauce to them the conoept of waste reduction, muse it is at the beginning point of the evolution of new technologies that you have the best opportunity to suggest alternatives that might curb waste generation. A third part of the research venue is the magnitude and concentration of waste streams.

Panel Identified SiX Basic Research Topics

Ran interpretation of the various respo~lseswe received fminaustry, we concluded that there are essentially six central topics for research-areas in wfrich we can take problems fman industrial context and reduce them to sume basic research needs. They are as follaws: 1. me chemical role in manufacturinq: We f& that often industries do not knm the function in the manufacturing

12.2 1

process of chemicals that they use. obviously, if you do not ’7 knclw the function of chemicals, it will be impossible to -~apasea substitute for those that have been identified as ttpmblemttchemicals. This was illustrated well by the example 7 of chlorofluorocakn behavior on silicon surfaces. We were told that chlorofluomcar3mns are absolutely essential to the ~CroeleCtrOnicsindustry. Yet, when you ask what exactly do --1 these chemicals do at the surfaces, we found that the function was largely Unknm. In textile industris, we face not so much transforrations of 1 chemicals as applications of chemicals. mt in the chemical inhstry which produces dyes and other chemicals, the entire faxs is on intermediate or side reaction of chemicals. our basic understanding :1 of haw these things behave--not in a chemistry sense but in a real- world sense--leads to a lhitation of control techniques. :I 2. Manufacturinq ~rocessinefficiency: We found that in my cases, while the manufacturing process was sufficient to produce quality products on a cost-effective, competitive basis, the proass was not understood well enough to judge if :’I the process had been optimized or if it could be changed without affecting quality. In work we have done in this area we have discovered that (1) solving a problem with a process :I ddcal often requires uncoupling it fmanother chmical, and (2) often we are dealing with a chemical that is not a part of the process but has been introduced as an inpurity in the 3 raw material. 3. Universal evaluation conce~tsfor waste: ?heare rudimentary mgineering concepts that we might be able to apply across my n was- for the purposes of reduction. One is a qlete econmic evaluation to assess waste reduction: If you make a substitution, hm will that affect pro3uc-t quality and the 1J bottom line? Another is using energy, entropy, and chemical activity 11 concepts to judge relative waste generation. ?here are chemical functions that we might use to CcTmpare irdustries in terms of relative efficiencies of conversion. 4. I5-rhanced treatability: The concern about waste end-pints is not merely hm much there is but hm compatible it is with the emvhmt. We need, fma regulatory standpint, to codify :-I waste end-points, so that we can mefm a strictly volume- based system to a system in which cmpnies get credit for replacing a thousand pounds of toxic waste with a thousand -i pounds of an envhmhlly benign subs-. Of course, many of the problems we have in treating wastes do have to do with large diluents-large amounts of air or water 4 in a waste stream. WIenhance both treatment and recovery we need to examine at a basic level the purpose of the diluent. J ?hat has already been a very fruitful area of research and we J 12.3 .. ! think will rain important. 5. Traditionally difficult issues: Non-routhe wastes, such as I contaminated soils and other materials fmm spills, is one -le. 1

6. Waste as a bvproduct: This involves exambhg baste for recycling potential and asking hm we might: alter the characteristics of a waste p&ct to enhance recycling I potential.

mereport of the National Science Foundation is nearly complete. We think we have laid some inportant groundwork for the werall agenda for waste I redudion in this Country, because when we go past the -secord phase we should already be thinking abut the third phase--research. ?he mnnal lag time between the intrduction of research and the results of research is always I significant so it is not too soon to bqin waste reduction research.

I I i 1 I I i i i I

J I 12.4

11 1

IN”ll TOXICITY REMlcTIoN 7 -UGH (3g3Ic1E OF BIODEGRADABLE

LOU hvetz 1 A broad range of industrial product mufacturhg, including the textiles industries, requires the use of surfactants. Surfactants are important organic CCIIlTpOUndS without which textile wet processing and dye* would be inpossible. Their interesting physical properties, essential in such operations as wetting, scouring and dye leveling, can pose problems to the envi”t at relatively lw concentrations unless steps are taken to biodegrade than into non surface- active fllbstances which are not toxic to aquatic life. Here are sane of the common uses for surfactants in textile processing: * lubricating * spin finishing * desizing

* mercerizing * bleaching * wet finishing * foam finishing :I * aye- 11 * foam dyeing Problans of Foaming in Receiving Waters :.1 Became Evident in 1940s Errvironmental problems with surfactants are not new. They first came to light wha the detergent industry during World War I1 switched from soap to the synthetic surfactants. The synthetic surfactant of choice at that time bas a branched alkylbenzene sulfonate. As these surfactants becane widely used the erivhmtal collseqllences became evident. Extensive foaming in the receiving n waters-twentq-to-thkty foot munds of foam--were obvious in the 1940s, 1950s, and early 1960s.

i The reason for this foaming is that branched alkylbenzene sulfonates (ABS) are poorly biodegradable. When they go through conventional sewage treatment-- I an aerated, activated sludge process or a trickling filter process--they exit zl J Shell Developmt Corporation, E3B 1380, Houston, TX 77701 13.1 J with their surface-active properties intact because the microbes in the biotreatrnent units are unable to break them dawn into non surface-active fiaynents.

Ihe government was poised to crack dawn on these surfactants when, in 1965, the detergent industry voluntarily switched to linear alkylbenzene SUIfonateS which biodegrade readily. mese almost overnight reduced the fOaming problem.

Concerns abut surfactants Are ~awRelated to Aquatic -city

"I, with the Clean Water Act of the 1980s, we are concerned about a different problem--effluenttoxicity. The Clean Water Act requires both acute and chronic aquatic toxicity tests to be perform3 on waste treatment plant effluent. We believe that the mandated chronic aquatic toxicity testing is going to have mjor implications for POTws and industries, including textile prwessors, that discharge to KYIWs. Surfactants carpose one class of chemical of great concern--nonionic surfactants kill fish in the part-per-million range and produce chronic effects in the 0.1 to 1.0 part-per-million range. So, we are going to be faced with two choices: get rid of surfactants, which means closing groups of industries, or use surfactants which POTws can break dminto harmless cmponents.

Ttvo ir;rportant classes of surfactants are nonionic, that is they dissolve in water without the fomtion of ions, or anionic, those that form negative ions when dissolved in water. Within the nonionic and anionic groups, an inportant characteristic of a surfactant is its hydrophobe type. The hydrophobe is that part of the surfactant, spealiing in mldar tenns, that orients akay from the water molecule, and a surfactant my be of the linear hydrophobe type (straight chain structure) or the branched hydrophobe type (aUyl side chain structure). The hydrophile is the part of the surfactant molecule that orients t"rd the water molecule. The water-loving (hydrophilic) and hater-hating (hydropbbic) properties of surfactants make them important in dyeing, scour^, and wetting of fabrics . The major nonionic classes of surfactants are as follcws: * the alcohol ethowlates, which are derived from ethylene (essentially linear, straight chain structure which microbes can break dmeasily) , propylene or butylene (highly branched, with an alkyl side chain which is difficult for microbes to utilize), and vegetable triglycerides (essentially linear and bidegradable) * alhylphenol ethowlates, which are derived from propylene (contains a branched nonyl and is the most commonly used product) or butylene (contains a branched octyl) me major anionic classes of surfactants are as follms:

13.2 1 * alkvlbenzene sulfonates, which are linear and branched but only the linear biodegradable ones are used today and have no kn" adverse efnrkemmtal effects * alcohol ethomsulfates, which are linear and branched but only the linear ones are used today and these are also biodegradable

Studies Cempare Biodegm&&ilityof Nonylphenol Ethoxylate and Alcohol Ethoxylate In the folloWing discussion the term AE will be used to designate linear 7 primary alcohol ethoxylates. The term NPE will be used to designate nonylphenol ethoxylate--the nonionic surfactant nentioned abuve derived fm propylene and containing a branched nonyl.

( Note that there are two kinds of alcohol ethoxylate.s--lhear and branched. Sinply replacing a norhiodegradable surfactant with an alcohol ethoqlate that you may have heard is biodegradable may not be enough unless you are very :1 careful to choose the alcohol ethoxylate With the kind of structure which lends itself to ready biodegradability.)

1 Our studies shm that temperature is an important influence in biodegradation of surfactants in FCYIWs, particularly in the Northeast. In one study, we measure3 the concentration of nonbicdegraded alcohol ethoxylates (AE) :I and nonylphenol ethoxylates (NE) in the effluent of a simulated wastewater treahent plant--* measurirg foam height--at different temperatures. We found that at 25 degrees Centigrade both degrade fairly well. Hawever, for NPE at 12 degrees C, there is a small increase in foaming; and when the tmpmture drop 3 to 8 degrees C (the average winter conditions of a FOIW in the northern part of the United States), there is extensive f-. For AJ3, the concentration as :I measured by foaming rains essentially the same at all temperatures. In our studies, msurmts of tritiated mter, another indication of biodegradation, also shm that a dropping tmpemture depresses bicdegradation n of NPE but has no appreciable effect on AE. In another of our studies, we simulated an activated sludge wastewater treabent plant and ran three tests. One was a control, in which the influent 11 contained no surfactant. In a second test, we progressively increased the arrrwnt of AE added to influent, and in a third, we prap-essively increased the ?J amount of NFE added to influent. We ran the test over a year and a half and measured foaming as an indication of surfactant concentration in effluent. In the control, as would be expected, there was essentially no foaming. (A :I blip did cccur because bacteria sanetines produce their &TI surfactants.) The AE also shm& very little foaming. But with the NPE, vhen we reached 10 pp surfactant in the influent, we start& seeing foaming. 'Ihe foaming went up and rl dmwith time, but essentially increased as the concentration of surfactant in the influent increaa. I Thestudies make it reasonable to conclude that since surfactant 3 concentrations going into WIWS from textile or pulp and paper operations can !d range fram 50 ppn through 200 ppm, use of surfactants which cannot be readily J 13.3 biodegraded within the treatment plant can be responsible for gffluent which is either acutely or chronically toxic to aquatic life. I In our cxhln acute fish toxicity studies, the JX50, the effective concentration required to kill 50 percent of the test species, for NPE required I reauction helm 7.3 percent of the effluent. ?hat is not sufficient to pass an

EPA acute toxicity test. AE shawed no toxicity at full 100 percent effluent. I I Linear alcohol ethoxylates biodegrade very quickly to almhol and to hydrophobes and hydrophilpc which are nontoxic. These nontoxic mterials further biodegrade to harmless 032 and water. The branched surfactants biodegrade slawly to bioresistant and still toxic materials. By carefully ! choosing easily biodegradable surfactants, textile processors can help r&ce influent toxicity which may upset treatment operations and be responsible for toxic components in effluents. i 1

13.4 HAZARDOUS WASTE REDUCTION IN METAL PARTS CLEANING JEROKE KOHL^

Virtually all fabricated metal objects require some form of cleaning prior to surface coating by painting, plating or vapor deposition. Cleaning is normally carried out by the use of: abrasives, solvents (halogenated and non halogenated), aqueous cleaners (acids or alkalies), and water (sometimes as steam). The use of solvents results in the production of vapors which can cause air pollution and of "dirty or used" solvents which comprise a hazardous waste. This paper discusses reduction in the amount and/or toxicity of these used solvents by examining: practices that result in a reduced cleaning load; good housekeeping practices; recycling solvents in or out of the facility; substitution of an abrasive, a less toxic solvent or an aqueous based cleaner. .4 full discussion of metal parts cleaning can be found in Chapter B-20 of Volume 11, Waste Mininization Issues and Options, available from NTIS as PB87-114-367.

Reducing The Cleaning Load

Practices that have been used to reduce the cleaning load include the following:

Increase the drainage time prior to cleaning. Centrifuge the objects to remave metal working fluids and particulates. Design the objects so they retain less fluid. Use a low viscosity metal working fluid so it flows readily from the object. Use a surface coating method relatively insensitive to the cleanliness of the surface. For example, use of cyanide zinc plating in place of nickel plating will reduce the cleanliness requirement. Inspect parts prior to cleaning to reduce unnecessary cleaning of faulty objects which would later be rejected. Practice good inventory control so as to minimize unnecessary cleaning or too early cleaning which in turn can lead to objects becoming rusty or dirty requiring a second cleaning. Practice good storage practices for uncleaned and cleaned parts to minimize soiling during storage. Pre clean by use of compressed air, brushes or buffing equipment to remave soil.

Good Operating or Housekeeping Practices

operating or housekeeping practices which can reduce the formation of waste solvents or still bottoms inciude:

(1) Waste stream segregation and identification of the waste as a recyclable stream rather than as a waste can improve recycling yield and keep water and foreign matter from the waste solvent container. (2) Personnel training can stress operating practices which reduce the production of waste solvents. (3) Purchasing practices can reduce or eliminate the generation of surplus or "off-spec" solvents.

1. Senior Extension Specialist, NCSU, Box 7909, Raleigh, NC 27595-7909.

14.1 (4) Loss preventive practices such as spill prevention, preventive maintenance (particularly of pump and valve packing glands) can reduce leakage and spillage). (5) Use of readily cleaned and purged filters can reduce dumping liquids from the filter container. (6) Emergency preparedness can reduce the formation of wastes due to a leak or spill of solvent.

Reducing Waste Solvent Formation Recycling Solvents

Solvents are used for various cleaning operations by a large segment of industry. Actions to reduce the amount of waste solvent produced include:

(1) Watch operating practices to avoid cross-contamination of solvents and water contamination. Remove sludge as it forms - zinc and aluminum fines catalyze the breakdown of chlorinated solvents forming acids. (2) Analyze the solvent and add needed specific components rather than adding fresh solvent or replacing the bath. (3) Locate cold cleaning tanks away from heat sources. (4) Avoid spraying (cleaning) parts above the cooling jacket zone. (5) Yinimize solvent "drag out" by the design of the parts and their conveyor and by maximizing drip or drying time. Vapor drag out can occur, if the part is withdrawn too rapidly or exerts a piston effect.

Tens of thousands of vehicle repair facilities use solvent parts cleaners which comprise a sink placed atop a drum of solvent. Dirty solvent is filtered, returns to the drum, and is pumped to a spray cleaning nozzle in the sink. When the filter and/or solvent needs replacement a service firm such as Safety-Kleen replaces the solvent and filter and carries the dirty solvent to a recycling facility. The solvent can be halogenated or non halogenated and can be owned by the user or leased from the service company.

In production operations soak tanks and vapor degreasers are both commonly used. For both types of degreaser, the most important source reductiJn techniques are the minimization of solvent vapor loss and the maintenance of solvent quality. Solvents contain chemical stabilizers that help prevent acid formation and remove acid contaminants. Solvent vapor loss can preferentially lose stabilizers reducing solvent life before replacement. Techniques to reduce vapor loss include:

(1) Installation and use of tank covers -- slide covers horizontally, don't hinge; cut entry holes the shape of entering and leaving parts. (2) Increase free board space. (3) Install freeboard chillers in addition to cooling jackets.

Many operators of soak tanks and vapor degreasers have a solvent still directly connected to the degreaser. In other cases dirty solvent is piped or drummed to a centrally located in house still. Such stills are available with a capacity ranging from 1 gallon/hour to several hundred gallons/hour. Other operators send their dirty solvent to a recycler on a toll basis or for a fee determined by the value of the solvent when recycled compared to the recycling cost. Information on Still Suppliers and on Recyclers is contained in "Managing -and Recycling Solvents" by Kohl et a1 which is available from the North Carolina

14.2 Pollution Prevention Program (Division of Envi"enta1 Management, NRCD, P.O. Box 27687, Raleigh, NC 27611 [919] 733-7015)

Waste or Toxicity Reduction by Media Substitution

Some parts cleaners have replaced the halogenated solvents (which result in "listed hazardous wastes) with non-halogenated solvents, such as Varsol or another petroleum solvent. While a change of this type reduces the problems of inhalation and vapor and skin contact toxicity it increases the fire hazard since the non halogenated solvents are readily flammable and their vapor can produce explosive mixtures.

Many former users of halogenated degreasing solvents have switched to alkaline or acid cleaners. The two other speakers in this session will explain why they made a switch of this nature and will describe their experiences with aqueous based degreasing media.

d 14.3 J 1 1 ESF'ERIENCES IN GETTING RID OF SOLVENT BASED DECREASING IN A DIESEL ENGIKE REMANUFACTING PLANT by ALICE J. JOHKSON

First of all, we sho\;ed our upper managment the importance of removing the solvents that vaporized benzene. We used as esample the OSHA literature that cited benzene as a health hazard. Once this k-as established they \;ere very encouraging about the remo\*al h-hich gave the Supervisors the freedom to seek out chemical vendors and experiment. As more information was available to the public this helped upper managment see the need for the removal of any possible chemical problem.

After we established the need for change Ke also wanted to guide the direction of the change and showed the benefits of k-ater based cleaners: health effects are lessened; cheaper initial purchase;less costly if spilled; easier disposal.

Employees that ~orkedin these areas had been complaining of mild symptoms. The most frequent was a headache. There vere also complaints of sore throats and skin rashes. As the '\Cord' got around to the employees they became hesitant to deal with certain areas for fear of 'chemical reactions'. They also spent more time in the First Aid dept. checking to be sure they did not have some major disease process.

1, ALICE J. JOHSSON, Health Senices Specialist, \CM RE,' NVFXCTTR I NG CENTER, Industrial Driye, New Bern, NC 28562

15.1 .-

To begin our con\-ersion to water based products \,-e (1) prepai.ed a list of the problems that we wanted to eliminate. Then \:e (2) contacted chemical vendors and explained exactly what we r;antEc in a replacement chemical. h'hen you are doing this research you need to keep in mind certain aspects such as: Are i ,. 21157 c c'nmon health hazards (read the ?lSDS); .4re there ail, 1ds for disposal

(can it go to the landfill in your . 1 ' 5- GI' do~s3 t Iia-. t' ? I , treated before ?-our POTW ! t:*~t?ptit? 1 A1.p tIie1-t ali? i:~eit ? (1,: can contact? Any hi.-~t :ic.cidents? .And of I I :):it i 5 t lie c~,si

fcr jt I . lI:iig? 01ict. all 11~1s112s 1)$"-1! t~siall!islitd :uu (3) can disc k- ' ai informat ioJi 1.; t 11 'jdJIrtG.tr5PJit tiid tclgetlier nialce a betlr-i' decisioii foi ) JJI l-?aiit . (4\ Ha\e a trial run crf one cllemical at a Ijme>, Tf ) GI, ;,st nure thail c,Jitr' then ?-cju ~*il1 Le unsure as to r,llich

*s?jvd:l:t $1; i.c,rl\ed for your situation. Then finall?, (5) ex-aluate the 1 iL7j : Hc,t. IL,II~ as tile shelf 1 ife? k'as t1iei.e ally residue on the me-l~l" P~r-xs it \.-or]\ efft.cti\-ely ~ithtf,e c~therchemicals in use? HGL haid js ji to (1eali the etlui]'nient? lias it difficult to use 5)- t?,e emplo>ees? 1s it cost effective? An article I read recent:) rti:i;Ided me that the most important thing to remFiliber about a decision js how fast can it be ie~~ersed.This is helpful to 1in0~ in ad\.ance and if you complete thcde items before you makc :. .i;xp?ett. conversion you \.-ill be ;;repared for tlie change. i

After our cc)n\-ersicJnto the \.-atel- based pi(.d*2;s 1.e n~teda deci 35~ iv LIur initial cost of the chemical. Sut later, as ?1aiiitenanct i hcLsame more in\-olved there 1.; a noticable decrc.-.se iii dor;ii tine to clean the ma~lii:!~--. There \;as a decrease -11 r1aintenai;ce cost of supplies fa: !ie Irrachiiies and t111 zrrrount of tjiiie needed to do tlie rain1 enanc e. (See Table 2)

Once \.-e began LG~Jtir~g on elimiiiating tlie sulxents I\L ;Ioticed tliat ?-I), i e ~e3eprollems because of the coolailtts. The ci,l\eiit to cleaii I - :l,c- -,elals had heeii oil based and \:e cliaiiged tc, :\atel* byst d. , 'I \,e :loticed that the coolants could not he washed off at all I-J! of the r-atei- based cleaners. So \;e begaii seai-t-!.;~~gjl-,i (3 ~ater i based coolant. Again rqe aslied the chemical I epi eceiitat ives. h'e ran trjal runs of the coola~itshiid liari dSscussions at production meetings, Finally \-e Iiac! coii\ el ted all our sol\.ents and coolants to r;ater based. Tlle Table shows some of the PROS znd CONS we noted 1 af:+i. 1-e coii~pletedour con\ersion to \cater based products. After ?Iii s rtl,ai,ge xe noticed some other positive things. (See Table 1) i When we used oil based coolants we still had to allor< time for the metals to cool before xe could gage them. When using the water I based you do not need to allow a cool dor;n time. We also noted that 1 due to vater based coolants we could eliminate one cleaning stage altogether. There was one draw back and that xas due to the extra chemical r;e had to purchase to complete a thorough cleaning for the I machine (this is shok-n by the $41.35-).

15.2 1 7 ESF‘ERIENCES IN GETTING RID OF SOLVENT BASED DEGREASING IN A DIESEL EXGINE REMANUFACTING PLANT by ALICE J. JOHNSON

Our facility remanufactures Mack Truck engine parts. In order to do this we receive used engine parts and clean them before beginning the process of remanufacturing. During remanufacturing F;e use coolants and cleaners at various stages of the \;ark. When our facility opened in the fall of 1985, \.-eused some solvents which had benzene and oil based compounds for machining. After some testing for benzene in the air we noted that the level was too high, It had been at O.6ppm r;hich at that time \;as the notification leL-el. We realized early that this needed to be decreased. And then a year later OSHA did change the maximum level of Benzene to 0. lppm.

First of all, we showed our upper managment the importance of removing the solvents that vaporized benzene. We used as example the OSHA literature that cited benzene as a health 11 hazard. Once this was established they were very encouraging about the remo\-al which gave the Super\-isors the freedom to seek out chemical vendors and experiment. As more information was available to the public this helped upper managment see the need for the removal of any possible chemical problem.

After r;e established the need for change we also Kanted to guide the direction of the change and shah-ed the benefits of Kater based cleaners: health effects are lessened; cheaper initial purchase;less costly if spilled; easier disposal. :-._1 Employees that h-orlied in these areas had been complaining of mild symptoms. The most frequent was a headache. There were also 11 complaints of sore throats and skin rashes. As the ’r;ord’ got around to the employees they became hesitant to deal with certain areas for fear of ’chemical reactions’. They also spent more time in the First Aid dept. checking to be sure they did not have some major disease process.

! 1. ALICE J. JOHNSON, Health Services Specialist, ?3.4CK RE?lANLFACTLRINC 3 CENTER, Industrial Drive, New Eern, NC 28562

15.1 J To begin our conversion to water based products \,-e (1) prepared a list of the problems that we wanted to eliminate. Then \-GI' ~OPS1t Ila\t. t I < treated before ?-our POTW 1 ! 1:'c ept it?); P there a!;) iiC€!> > ou ( 3 1 can disc t - 3 L~~rinfurmatio~i LI~II Y~ii:~~.'tii~~-'~if hi~d tagether nialce a bettt..l. decibioji for ? )ill p! ailt . (1) Ha\ r a ti-ial run of one cllemical at a i ljrrie, Tf ?oi, I~SCmure Ihaii GII~then yc)u i2i11 Le iiiisurtf as to \,i~ich .*ijt-:.,:t c12 t.brl,ed for youi* situation. Then finzll?., ( 5 1 e\-aluate the

1 I jLll : h'i_>t. !c,iig \.as t11e shelf life? \

After our con\-ersidn to the water based Prt-iJi ;ts rye noted a deci. ~.se iil clur initial cost of the chemical. Eut later, as ?laintenanc+: i b'c_,*amemore in\-ol\.ed there 1.:; '4 a noticable deert:.-,se in dotcn lime to clean the mbchi!i. -. There i;as a decrea5.e 11~maintenai-ice cost of supplies for, :lie ~rrachiiiesand 1111 zrnount. of tiilie needed to do tlie n:ainl.enance. (See Table 2) 1

Once ~-ehegan \Lcii-.IJ iitg on elimiiiat ing the sol\.i.nts r;c :.loticed that tli, !.e \(eIe protl ems because of the coolants. The c.ol\-ent to clean I ?l,i:' ?;et315 had Lee11 oil based and \;e cilarlged ti; ;\atei*b.~.si:d. Til :i r;e noticed that the coolants could not he washed off at all by +CC)L:F of the \cater based cleaners. So !;e begaii seai-c!:jiig f'~,i.ii 1;ater I based coolant. Again \

15.2 I 1 f. When we used oil-based cleaners we had to change the machine filters two times a week instead of once a month. Of course because of this there was a-&amattc deer-se in the time to complete the cleanup work. Again, I wish to repeat, you should start with a list of the problems you have been having with a chemical, research what hazards are known, contact vendors, have a one chemical trial, then evaluate the effectiveness of the :1 test.

BENEFITS OF WATER BASED PRODUCTS

:I 1. Health effects are lessened 2. Cheaper at initial purchase

3. Less costly to clean up if spilled .1 :, 4. Disposal is easier a

J 15.3 Table 1

PROS AND CONS FOR OIL vs. WATER BASED PRODUCT

Oil Based Uater Based Product Product

1. Ability to clean equipment Easy Extra cleaning necessary

2. Ability of cutting stones to work with solution No problem loads stone if ANY OIL mixes with the solution

3. Cleanliness of solution Sloppy Area usually neat

4. Quarantee on machinery Yes Lose quarantee

5. Frequent cleaning stations Yes No

Table 2

COMPARISON FOR COOLANT PER HONTH

Oil Based Yater Based $$$ Product Product Savings

1. Amount of chemical used $466.40 $125.04 $341.36

2. Chemical needed for cleaning 0 41.35 41.35-

TOTAL $466.40 $166.39 $300.01

3. Amount of Time needed to clean 12 hours 4 hours 8 hours 4. Special cleaning 0 3 hours 3 hours -

TOTAL 12 hours 7 hours 5 hours * I/ I

15.4 1

’-7 Table 3

1 COMPARISON FOR CLEANER SOLUTION PER WNTH

Oil Based Water Based $$$ Product Product Savings

1. Amount of chemical used $487.20 $446.00 $ 41.20

2. Cost of changing 6 replacement filters 424.00 53.00 371.00 TOTAL $911.20 $499.00 $412.00

3. Time needed to complete cleaning 12 hours 4 hours 8 hours 4. Extra work for disposal 2 hours 0 2 hours TOTAL 14 hours 4 hours 10 hours

- Table 4

CHEHICAL COMPARISON PER MONTH

Oil Based Water Based Product Product

1. Coolant Cost $466.40 $166.39

2. Coolant labor 12 hours 7 hours

3. Cleaner Cost $91 1.20 $499.00

4. Cleaner labor 14 hours 4 hours

3 15.5 J 3

J THE DEVELOPMENT AND IMPLEMENTATION OF A DRY ACTIVE WASTE (DAW) SORTING PROGRAM

J. H. Schultel

Duke Power Company, like other nuclear utilities, bears a burdensome radwaste disposal cost that has rapidly escalated during recent years. Dry active waste (DAW) represents approximately 85% of the total radioactive waste volume shipped to low-level disposal facilities. Sorting waste with less than detectable radioactivity from waste with detectable radioactivity provides a volume reduction (VR) technique that can save significant radwaste disposal costs and conserve dwindling burial space. This paper presents the development and results of a project that was conducted at Catawba Nuclear Station to determine the volume reduction potential from sorting DAW. Guidelines are given so that other utilities can perform a VR potential study on a low cost basis. Based on the results of the DAW VR study, an overall DAW volume reduction program was initiated at Duke Power Company. This program includes personnel training, drumming techniques, bag tracking and equipment purchases for sorting. This program has been fully implemented at Duke Power Company since January 1, 1988 and preliminary results and savings are given.

INTRODUCTION In 1984 as the cost for disposal of radioactive wastes escalated, Duke Power began to see a need to look closely at ways to reduce the volumes of waste being generated and sent for burial. Since DAW represents approximately 85% of the total volume shipped, emphasis was placed on potential reduction of this waste stream. At that time, it was the Company's policy to rely on a General Employee Training (GET) Program and a color-coded drumming program to segregate clean from potentially contaminated trash in the Radiation Controlled Areas (RCAs). Materials deposited in clean (blue) receptacles were generally routed after survey to a municipal landfill and materials deposited in contaminated (yellow) drums were destined for burial at the low-level waste burial site. The company had recently made great strides in reducing DAW generation through increased housekeeping awareness and a strengthened GET program. A reduction in the volume of unnecessary materials brought into the RCA and then segregating necessary RCA trash through the drumming program accounted for most of the DAW volume reduction at the time. The DAW VR potential study, through the use of sorting techniques, was initiated in an effort to determine '3 methods to further reduce the DAW volumes sent for burial. The decision to lAssociate Engineer, Radwaste Engineering, Duke Power Company, P.O. Box 33189, Charlotte, NC, 28242. This paper was previously given jointly with P.N. McNamara, Scientist, Catawba Nuclear Station, Clover, SC at Waste Management cl '88 In Tucson, Arizona. 16.1 J 1 perform such a study was influenced by a recommended good practice in Institute of Nuclear Power Operations (INPO) Operating Experience Notice 9 I (OEN-9) to develop a sorting program. I SORTING PROJECT OUTLINE A DAW VR potential study can be performed on a low cost basis. First, equipment must be obtained and used to produce about the same sensitivity as i DAW VR equipment on the market today (approximately 5000 dpm/100 cm2). If using friskers, care must be taken to properly integrate detection parameters (e.g. geometry, velocity, false alarm rate, etc). If friskers are used i without glove boxes or other engineered respiratory controls, then a1 ternate means should be used to address respiratory concerns. The second step in setting up a study is to determine qualifying waste. This i step involves placing manageable limits on the volume, type, and origin of the material to be surveyed in order to control the magnitude of the project that I will yield estimates representative of a full scale program. For example, I waste generated in a nuclear sampling lab would not qualify because of its high contamination potential. For the Catawba study, after determining from which areas the waste would be sorted, further guidelines were developed for i qualification. This involved obtaining external dose rates from the bagged material. Only bags with dose rates less than or equal to 2 mR/hr. were considered for sorting. i The final aspect of preparing a DAW VR study involves determination of what to document. This would include methods for calculating mass balance and how to relate the fraction studied to the whole DAW stream for VR ratio 1 determination. Once the VR ratio is known, then economic analyses based on cost/benefit can be presented to management for program justification. 1 PROJECT DESIGN The DAW sorting project began with a literature search to determine what ! guidance and precedence existed for sorting trash. Contacts were made with INPO to identify utilities engaged in trash sorting within NRC Regions I and 11. From this, Beaver Valley Power Station and Salem Nuclear Station were I found to be the closest nuclear facilities to have active trash sorting programs with offsite release. Beaver Valley's program used manual trash survey techniques. Salem's program employed a prototype version of a mostly -1 mechanized process that included sophisticated counting and handling devices. Capital allocations for this project were restricted to the use of existing Station manpower and equipment resources. Based on this criterion, Beaver i Val 1ey's assistance was sol i ci ted because their successful program provided a proven format from which the test structure could be developed. Beaver Valley provided procedures, guidelines, drawings, and statistical records to assist i in the project design. Guidelines for organizing the stepwise process of hand1 ing waste were adapted to Catawba's needs, further reducing project development costs. 2

16.2 I

JI The primary survey instrument used throughout the project was the Eberline , RM-l4/HP260 (frisker) with alarm setpoints (ASP) based on a modified version -& #e methodology presented by J. F. Sommer as the technical basis for IE Circular 81-07. The modified equation for ASP methodology was used to generate a table of ASP values corresponding to 5000 dpm/100 cm2 in fast response detection mode as a function of background. The modifications made to Sommer's equation included the use of a calculated and empirically proven 1.62% effective moving efficiency for a 100cm2 planar source versus the 10% stationary counting efficiency Sommer used for point source detection. Particular attention was needed in the guidelines for respiratory concerns. Although only bags with dose rates of less than or equal to 2 mR/hr were selected for sorting, the potential existed for intake of respirable contaminants from those being opened. Because the test could not provide for engineered respiratory controls, comprehensive air sampling was performed followed by daily analysis. In addition, daily composites were made from rejected, (greater than ASP), radioactive trash which were analyzed daily. Alarming air monitor setpoints were determined based on .25 x MPC for the limiting nuclide identified from daily analyses of air sample media or sample composites. Trash sorting personnel received weekly body burden analyses to further control the potential for, and to identify, any intake.

SORTING RESULTS Documentation was developed to provide historical records for mass balance determination. The volume reduction ratio was calculated on worksheets by dividing "clean" trash mass by total trash mass. "Clean1' trash mass included non-reclaimable items frisked without alarm. Total trash mass included the sum of "clean" trash, contaminated trash and reclaimed article mass. Reclaimable article mass included repairable Anti-Cs and respirators, tools, equipment (including metals) and wet articles. Over 3,000 lbs. of qualifying paper or paper equivalent density trash from the DAW stream was surveyed with approximately 90% sorted out as having undetectable activity. About 10% of the station DAW did not qualify for sorting because of its origin (high contamination potential) or because the contact dose rate measured external to its container exceeded 2 mR/hr. The total trash sorting test effort yielded a volume reduction potential for qualifying waste of 89% based on a counting instrument alarm setpoint of approximately 5,000 dpm/100 cm2 (see Table 1). The volume reduction potential for the entire DAW stream was estimated to be 80%. It should be noted that very few reclaimable articles were found.

16.3 J J Table 1 Volume Reduction Ratio Contaminated Clean Mass Reclaimable Phase Mass (lbs) (lbs.) Articles (lbs) % I 138.5 856 32 83 I1 108 801 8 87 111 80 1270 0 94

Total 326.5 2927 40 89

It is recognized that the stated volume reduction potential is specific to Catawba Nuclear Station for the conditions under which it was determined. Unit 1 had been operational for 2 years and Unit 2 had been critical less than a year. We expect the VR potential to decrease somewhat in the future as a function of plant maturity, housekeeping and other changing radiological parameters.

ECONOMIC ANALYSIS Simplified economic analysis calculations were performed based on the results of the sorting study and purchase of semiautomated equipment in order to determine the cost effectiveness of such a purchase. Several VR percentages were used because of the different radiological parameters at the different Nuclear Stations in the Duke System. Following are the equations and assumptions used: Project Costs: o Equipment, initial cost of $400,000, lifetime of 5 years, interest rate of 12% per year. o Operating and Maintenance cost of $35,000 per year. Present Value of Costs: PV of costs = $400,000 + (P/A, 12%, 5)($35,000) + (100,000) = $400,000 + (3.605)(35,000) = $626,175

o Disposal costs from a percent VR of an assumed 17,000 ft3/year DAW waste generation at $40/ft3 can be avoided. o Net salvage value of $5,000 at the end of the 5th year.

16.4 '1 '1 Present Value of Benefits: - ---PV of Benefits = (P/A, 12%, 5)(17,000 ft3)(VR)($40/ft3) + (P/F, 12%, 5)($5,000) = (3.6O5)($68OyO0O)(VR) + (.5674)($5,000) = $2,451,400 (VR) + $2,837 Benefit to Cost Ratio: B/C = (PV of Benefits)/(PV of Costs) In this analysis, if the present value of the benefits exceeds that of the costs (B/C > 1) then the project is considered economically viable. As can be seen in Table 11, it appears that the decision to implement a sorting program will be economically viable as long as a VR between 20 and 30% is obtained.

Table I1 Benefit to Cost Ratios

t- 7 VR PV of costs PV of Benefits B/C % ($1 ($1 Ratio

13 80' 626,175 1,963 ,957 3.14 70 626,175 1 ,718,817 2.74 60 626,175 1,473,677 2.35 3 50 626,175 1,228,537 1.96 40 626,175 983 ,397 1.57 30 626,175 738)257 1.18 20 626,175 493)117 .79

L.'1 DAW VR PROGRAM DEVELOPMENT As a result of the VR Study, Duke Power Company developed an overall DAW reduction program system wide. The major components of this system are: management commitment, General Employee Training (GET), RCA trash segregation by color coded drums, bag tracking and trash segregation through the use of state-of-the-art equipment. In the General Employee Training (GET) all station workers and vendors are taught radwaste minimization techniques. Through this training volume reduction is obtained by a reduction in the volume of unnecessary materials being brought into the RCA, proper disposal of materials that are brought into the RCA, and protection and reuse of equipment used in the RCA. As described before, color coded drums are used to initially segregate materials used in the RCA. If used properly, this results in a very effective drum controlled volume reduction technique with an excellent cost/benefit 3 ratio.

16.5 Bag tracking is a method of identifying where each bag of trash originates. The personnel involved in collecting the bags label each with a location and drum number. Through bag tracking, areas of high contamination can be isolated and studied. Also, if a bag from an area is discovered to have been used improperly or to contain excess contamination, it can be tracked back to where it came from. Since the drums are emptied daily, often the source of the contamination can be identified and corrected in a short period of time. This leads us to the most important component in any radwaste minimization system, management commitment to the program. Without it, none of the administrative programs would be effective. Once the source of a problem is identified, there must be action taken to minimize its recurrence. Since radwaste minimization is a station problem, not just a Health Physics or Radwaste problem, management support is needed for reinforcement. The final component of the DAW VR Program is the trash segregation equipment. Duke Power decided to purchase state-of-the-art equipment to sort trash. It consists of a three stage process: a sorting booth which is a manual stage, a conveyor monitor for redundancy and an aggregate monitor for final QA. A shredder is also used to ensure a constant detection geometry that also produces an unrecognizable product.

CONCLUSIONS The DAW volume reduction program has been fully implemented at all three of Duke Power Company's Nuclear Power Stations since January 1, 1988. The operating algorithms of the sorting equipment have been optimized to encompass the regulatory guidance found in: 1E IN 85-92, Regulatory Guide 1.86 and system release criteria. The potentially contaminated material that qualifies for sorting is presorted by obtaining external dose rates from the bagged material. Bags that read less than or equal to 2mR/hr are sent through the sorting equipment. Bags that are from 2 to 10 mR/hr are presorted to remove articles that may be causing the higher dose rate. Bags that are greater than 10 mR/hr are sent to the compactor to be disposed of as contaminated material. At this time the equipment is being operated to sort material into that which has detectable contamination and that which does not. The sorting table is being operated so that the MDA does not exceed 5000 dpm/100cm2 with a 95% confidence level. This can only be done in a relatively low background area or the count times become restrictive and productivity drops off drastically. The conveyorized monitor has a comparable MDA setpoint based on the respective area of the detector. The bag monitor setpoint is based on the area of the detector and the setpoints of the other equipment to ensure that there has not been an accumulation of activity slightly below the other setpoints. Based on the simp1 ified economic analysis calculations, and the assumption that intermediately contaminated trash (0-5000 dpm/100cm2) does not constitute a large share of the total trash volume, it appears that the decision to implement a sorting program will yield both substantial burial cost savings and burial space conservation. Even if intermediately contaminated, or very low-level trash represents a larger fraction of the DAW stream than assumed, then an approved de minimus or a BRC application pursuant to lOCFR 20.302 will provide the "clean" disposal option and allow the company to optimize the

16.6 7 aforementioned benefits of a trash sorting program. Initial results from sorting of qualifying trash indicate a 65 to 70% reduction, however, only a relatively small portion of the potentially contaminated waste stream has been qualified for sorting at this time. Therefore, a corresponding VR can not be ‘I determined this early in the implementation stage of the program. In the long run, based on initial experience and current industry experience, Duke Power expects to see approximately a 40% VR without an approved BRC application that _r’ will be pursued. It is apparent that trash sorting offers substantial benefit to the Company from both economic and environmental standpoints. Economical ly it provides the potential to save substantial burial costs, and, moreover, it provides the ‘I Company an opportunity to play a larger role in the industry’s efforts to be environmental stewards preserving ever dwindling burial space.

J J 16.7 I

,'I .J

1 3 -1

LOW-LEVEL RAD WASTE REDUCTION-POLLUTION PREVENTION IN THE AGRICULTURAL DIVISION LABORATORIES OF CIBA-GEIGY CORPORATION william L. Secrestl

CIBA-GEIGY Corporation is a diversified chemical cornpany engaged principally in the discovery, development, manufacture and marketing of a wide variety of special purpose chemicals throughout the United States. Research activities in Greensboro, rYC and Research Triangle Park, NC require the use of radioactive materials to meet specific federally mandated requirements for the registration of agricultural chemicals and agricultural oriented biotechnology research, respectively. The Greensboro Facility has a Broad Scope Radioactive Materials License issued by the State of North Carolina Department of Yman Resources, Radiation Protection Section. Under this License, the Agricultural Division utilizes carbon-14 as a tracer in studies corlducted for registration of agricultural chemicals by the Environmental Protection Agency. During 1987, 375 cubic feet of Low-Level Radioactive Waste (LLRW) were shipped for disposal at the Barnwell, SC LLRW disposal site.

The Research Triangle Park Facility has a Specific Radioactive Materials License issued by the Radiation Protection Section. Under this license, the Agricultural Division utilizes radioactive isotoDes of phosphorus, sulfur, hydrogen and carbon as tracers in plant biotechnology research. Each isotope is collected in a separate waste strean so that waste containing the short half-life isotopes may be held for decay to nondetect able levels eliminating the need for disposal as LLRW. No LLSW was shipped froT this site during 1987 since most work involved the short half-1 ife isotopes phosphorus-32 and s ulfur-35.

Every reasonable effort is made to maintain radiation exposures arld releases to unrestricted areas as far below the regulated limits as reasonably achievable, taking into account the state of technology and the economics of improvements in relation to the public health benefits. With this principal in mind, the following procedures are designed to minimize the amount of LLRY generated for shallow land disposal and to insure that radioactive materials are not released into the environment.

Prevention Of Pollution By Facility Design

All fume hoods located in areas that could generate airborne radioactive material are equipped with a High Efficiency Particulate Air (HEPA) and carbon filter system. The performance of these s,ystems is monitored to insure that no radioactivity is exhausted into the environment.

1. Radiation Safety Officer, CISA-GEJGY Corporation, P. 0. Box 18300, Greensboro , NC , 27419-8300

L-1 17.1 The sanitary sewage system is not used for disposal of radioactive waste at either location. During the design of the Biotechnology Facility enough space was provided to hold for decay all radioactive waste containing isotopes with half-lives of ninety days or less. A qreenhouse, currently under construction in Greensboro, will be used for studies involving plants treated with various carbon-34 compounds. 411 effluent from this greenhouse will pass through a charcoal treatment system into a holding tank where it will be monitored for radioactivity. If detectable levels of radioactivity are Dresent, the effluent will be recirculated through the charcoal system until all detectable radioactivity is removed before being released to the sanitary sewage system. Waste Prevent ion By Prep1 anning Processes Preplanning is a fundamental ingredient in the safe use of any hazardous substance such as radioactive material. Our concept of preplanning is carried out as a two part process: a) Each research qroup using radioactive material operates in accordance with a Radioactive Material Project approved by the Radiation Safety Comnittee. In addition, prior approval of all new or untried research is required. The Radiation Safet.y Officer reviews all new projects and amendments with the authorized user so that waste management can be factored into the work at this early staqe. The Radiation Safety Officer must approve all transfers of radioactive material between Projects to insure that no more radioactive material is used than necessary to generate the requirsd data. b) Establishing preplanning as a requirement for day to day laboratory work is an integral management concept. Perhaps no other aspect of our Radiation Safety Program is more effective than this concept in promoting our overall safety effort. This includes radioactive waste vanagement because here is where the source of all future radioactive waste can be controlled. This preplanning concept is included as part of our formal Radiation Safet.y Training. Preplanning at this level insures that all quantities of radioactive material, reagents, suDplies, liquid volurnes, etc. are kept to a minimum, consistent with accomplishTent of the work. System For Monitoring Radio act i v ity Leve 1 s A program for radiological surveillance has been established to insure that our uses of radioactive materials do not result in significant exposure of personnel and dispersal of radioactive materials to the research facilities or the general environment. This survei 11 ance includes performing standard tests for removable surface contamination and measuring radiatim intensity with radiation survey equipvent. The techniques and equipvent used are state of the art and are maintained by quality control tests and calibrations traceable to the National Bureau of Standards. These survei 11 ance measurements are performed at least monthly in all areas using any quantity of radioactive material and weekly in the radiochemical synthesis area. In addition to this formal surveillance, individual users continually monitor their work area. ,411 surveillance activities include the important provision that if any significant

17.2 contamination is discovered immediate action is taken to remove such containation. The surveillance program also includes surface swipe tests of appropriate hood exhaust ducts to insure that the filtration systems are trapping a1 1 radioactive materi a1 . Waste Treatment and Disposal Processes Used And Resultant Cost Savings Or Avoided Costs

Dry solid waste (paper, gloves, plastic, glass, etc.) is coqpacted using a Model DOS-RAW-CB1 Radioactive Waste Press (Consolidated Baling Machine Company). This press compacts the waste directly in a 55 gallon drum with a compression pressure of 80 PSI for a volume reduction of eight to one. This resulted in a reduction of 2,460 cu. ft. of waste during 1987. All wet plant inaterial is oven dried so that it inlay be packaged for disposal as dry solid waste instead of biological waste. Any airborne radioactivity, created by the dryinq process, is trapped by a particulate and carbon filter system connected to the oven exhaust. A twenty to one reduction is achieved by this process since the packaging of biological waste requires additional absorbing materials be added to each container. This resulted in an additional reduction of 750 cu. ft. of waste during 1987. This combined volume reduction of 3,210 cu. ft. resulted in a cost savings of $138,000.

Counting operations performed at the Greensboro Facility are such that no waste materials resulting from liquid scintillation counting contain radioactivity in excess of the limits sDecified in the "North Carolina Regulations for Protection Against Radiation" (10 NCAC 36 ,2516 (h) (1)). Therefore, these materials are treated as flammable liquid waste. This waste is shipped and incinerated by a commercial hazardous waste disposal company. In order to reduce the volume of liquid scintillation waste shipped for disposal a laboratory robot (Zynark Corporation) is used to empty the scintillation fluid from the vials. A six to one volune reductim is achieved by this process and resulted in a reduction of 200 cu. ft. of hazardous waste during 1955 for a saving of $14,300.

All phosphorus-32 and sulfur-35 wastes are held for decay until the radioactivity is below our detection liqits, therefore resulting in no LLRW. gecaying these isotopes resulted in volume reduction of 250 cu. ft. of LLRW during 1937 for a savings of $10,700.

In Summary, net savings frorn the waste management program for the Worth Carolina Facilities during 1987 was $163,000. More importantly, these efforts resulted in no LLRW being released into the environment and a reduction of 3,460 cu. ft. of LLRW which did not have to be buried at the Barnwell, SC disposal site. The waste Tanagement orogram is continually updated to keep the LLRW and hazardous waste volume as low as possible in order to vinimize the impact on the national waste disposal situation and decrease waste disposal costs.

17.3 ..

160

IS0 :*OD 5 1 9.

140

Total Jiswsal Plus 'JR Cost 130 (l/ft3)

1:c

1oc

L i' .[ Fipre 1. Unit Dispcral Cost for a t:nvent!onal S?sall% I I I I I Lana Burial Dperation [rleftrencc :) 0.2 0.4 0.5 0.3 1.J

iracticn of :he :n?t;al 'lo1s-e :mainin9 a] Snall Cmact

M-

a- + Total Sisposal 21us VR Cost

:ita1 Dispsal 30- "us VP cost Cc:: per Snit ($if:.') Yo I me of :'ar:e ?rior ?o VR ZD-

10- I 0 1.0 Fraction of the Initial Volune Renaining

I I I I FiSure 2. Finding the Point of Optfmum VR (Re'treice 1) !I 0.2 0.4 0.6 0.8

17.4 LOW LEVEL RADIOACTIVE WASTE MANAGEMENT - SEEKING AN OPTIMUM VOLUME REDUCTION STRATEGY Marcus H. Vothl

The formation of a volume reduction (VR) strategy for low level radioactive waste (LLRW) management requires a thorough understanding of the nature of the waste and the VR technologies. Next the natural incentives for the waste generator to implement VR practices must be compared to the ulterior goals of society. If natural incentives do not direct the waste generator to these goals artificial constraints must be developed to accomplish the objective.

An Effective Volume Reduction Strategy Addresses the Nuances of Low Level Radioactive Waste Form, Activity, and Volume

LLRW is waste containing material made radioactive in a nuclear reactor. The radioactive material is generally in one of three forms: material intentionally irradiated in a reactor (eg. irradiated reactor components or material produced in a reactor of medical purposes), corrosion products and other water impurities passing through the reactor incidental to its operation (eg. filter media and water cleanup demineralizer system resins), and material contaminated by these impurities (eg. protective clothing and tools). The radioactive material in LLRW is therefore relatively dilute especially relative to the high level waste form. By definition LLRW consists of primarily short half-life material which in many cases decays to harmless, non-radioactive states in a short period of time. Some LLRW can be stored and decayed in place such that it need not be disposed as radioactive material; other LLRW requires decades to decay and decay-in-storage is therefore impractical . A common myth is that the volume of LLRW is proportional to the>publicity it receives.- In reality, a major problem in the LLRW disposal issue is that the volume is so small that economies of scale do not exist which drives up the per unit disposal cost to the point of making VR difficult to justify on an economic basis. On a per capita basis, each year Americans generate a truck load (5 cubic yards) of solid waste, a trunk load (6 cubic feet) of hazardous waste, and an ashtray (22 cubic inches) of LLRW. The annual per capita LLRW generation is equivalent to the volume of a Rubik's cube.

Associate Professor of Nuclear Ehgineerhg and Director of the Fenn State University Breazeale Reactor, University Park, Pa 16802 (814) 865-3110

18.1 Alternative Volume Reduction Technologies Must be Considered

Good waste management is the first approach to volume reduction. This includes programs aimed at minimizing the generation of waste, keeping non-radioactive material from being included as LLRW, segregating waste to allow short half-life material to decay on site, etc. Frequently these steps are simply good standard operating procedures and policies. Compaction and ‘I super compaction are other VR technologies involving the simple compression of waste into smaller volumes. Incineration not only gives a greater VR factor, but also allows for solidification of the ash to a more stable waste form less subject to migrate from a LLRW disposal cell. Decontamination and reclamation is another form of VR technology, removing the radioactive material and returning the item to usable service.

The above list of VR technologies is not intended to be exhaustive but is presented for general classes of technologies. They are listed in the order of decreasing return on investment. For a relatively modest investment, significant VR can be achieved through improved waste management practices while a major decontamination effort and investment is required to accomplish the last increment of VR. It should be recognized that in the VR .process there is no reduction in the radioactivity, only in the volume over which it ! is distributed (with the obvious exception of steps to avoid generating LLRW in the first place). h

Economic Motives Provide Natural Incentives for Volume Reduction

The reasons and incentives for practicing LLRW-VR can be grouped into three categories; deriving immediate economic benefit (eg., reduced transportation and disposal cost), meeting quotas and regulations set forth by the government (eg., waste packaging, waste form stability, characterization, and documentation required by the regulations), and demonstrating a corporate conscience to achieve long-range public acceptance (eg., voluntarily reducing volume without economic gain to reduce the number of over-the-road shipments, conserve natural resources, and generate a positive public image). A waste generator must first assure himself that he meets all regulations and quotas in his LLRW disposal plan and that he includes any surcharges in his economic model. From a purely capitalistic economic viewpoint, he can then determine his VR costs and find the point where the disposal, transportation, and VR costs are a minimum. At this point, his incremental cost to VR further exceeds the incremental savings projected for disposal and shipping costs. Likewise, his incremental savings if he chooses not to VR as much, are not as great as the incremental increase in disposal and transportation cost for the larger volume of waste.

Artificial Constraints Imposed by Government Policy Augment Natural Economic Incentives

Society’s goals in the area of preserving natural resources are frequently incongruent with economic principles (References 1 and 2). For example, t economic theory says that as more electricity is consumed, the unit cost should decrease; a policy of long range preservation of natural resources says the large consumer s,hould pay more as an incentive to conserve, and therefore,

18.2 1

-1 the unit cost should increase instead of decrease. While the volume of LLRW is relatively small, and therefore a relatively small amount of land is committed for this purpose, society senses minimizing land use as a priority .~‘I (reducing the number of LLRW disposal sites nationally would be a far more effective way of achieving this objective). This objective can be artificially imposed as a quota on volume per waste generator or as a surcharge which encourages VR. Technologists must accept the political reality that unless the general public accepts the fact that land use for LLRW disposal is insignificant with respect to other commitments of land, artificial constraints will become part of public policy based on the prevailing perception, albeit incorrect. Our various levels of government promulgate regulations to protect the health and safety of the general public. Since VR decreases the number of shipments of LLRW, highway safety is enhanced. Also the improved waste stabilization following some forms of VR decrease the probability of releases from the waste cell and remedial site stabilization. It has become in vogue to evaluate the impact of regulations by evaluating dollars spent per fatality or injury averted. In theory, as a society we should allocate our limited resources to those areas where the greatest benefit for mankind can be derived. At the present time, however, radioactive waste disposal practices have reached $10,000,000 per fatality averted. By comparison, society allocates $30,000 to $35,000 per fatality on such policy actions as allocating funding for mobile intensive care units and highway guardrail improvements (Reference 3). Again, regulators can be expected to impose artificial VR constraints on waste generators in the name of safety so long as uncertainty and a public opinion of risks exist.

Analytical Modeling Helps Evaluate the Impact of a VR Strategy Before Implementation References 1 and 2 present in-depth descriptions of analytical model techniques for LLRW disposal options. Figure 1 shows the disposal cost for a ‘t range of waste volumes typical of U.S. regional compacts based on shallow land burial technology in compliance with 10 CFR Part 61. The slope of the curve shows that for volumes below 1,000,000 cubic feet per year fixed costs dominate and above 10,000,000 variable costs begin to dominate the unit disposal cost. By comparison, the total U.S. LLRW production is projected to average approximately 40,000,000 cubic feet per year over the next 30 years I with the largest of the regional compacts being about a tenth of the total. Since VR is most effective economically where variable costs dominate, and regional compacts are too small for variable costs to be significant, natural :I economic incentives for VR are questionable. To evaluate the incentives for VR, each waste generator must consider what it will cost per unit of LLRW volume, as shown in Figure 2. By adding the VR 3 cost to the new disposal and shipping costs (for the reduced volume) there is an economic incentive so long as the sum is less than the disposal cost without VR. This simplistic approach is valid if only a small portion of the total LLRW destined for the disposal site is processed for VR; if the entire compact implements VR the disposal site must assess the higher unit cost for disposal given in Figure 1. When the appropriate secondary reactions are included, the true incentives for VR are apparent. J 18.3 The regulations, quotas, and surcharges initiated to advance land use and safety principles will be considered minimum requirements for all waste generators to meet. Beyond these requirements, VR will generally be used to the optimum economic advantage of the waste generator. Large volume generators will find it easier to justify expenditures for VR equipment. Small generators will use mobile systems or go without. Figure 3 shows a composite study of a specific set of conditions. From a pure economics point of view, the total cost for the large compact is relatively independent of VR; the small compact has a slight benefit from VR. When surcharges are imposed to artificially impose a VR strategy, the incentives are seen to be more pronounced. In conclusion, one can say that VR has far reaching implications in an overall LLRW management program. The strategy developed must be carefully analyzed both qualitatively and quantitatively to assure that it accomplishes the objectives. Analytical models are available for this purpose.

References 1. Voth, M.H. and W.F. Witzig, "A Model of Economic Incentives for Volume Reduction of Low Level Radioactive Waste," Nuclear and Chemical Waste Management, vol. 6 (1986).

2. Voth, M.H. and W.F. Witzig, "Determination of Optimum Alternative Low Level Radioactive Waste Disposal Site/Disposal Technology Combinations," Nuclear Technology, vol. 78 (1987). 3. Cohen, B.L., Before It's Too Late, Plenum Press, New York (1983).

15.4 17 1000 -I

100

Unit 5 -If Disposal cost ($/ft3) 2

104 2

ANNUAL VOLUME (ft3/yr)

Figure 1. Unit Disposal Cost for a Conventional Shallow Land Burial Operation (Reference 1)

i 18.5 I \\b- Total Disposal Plus VR Cost I \'\ \\ Point of I \ \ ', Optimum VR Cost per Unit \ Volume of Waste Prior to VR Disposal Cost

\ VR Cost

0 1.0

Fraction of the Initial Volume Remaining

Figure 2. Finding the Point of Optimum VR (Reference 1)

18.6 1000

100

Unit 5 D is pos a1 cost (S/ft3) 2

104 2 5 105 z .- 5 106 z 5 107

ANNUAL Y OLUME ( ft3/yr )

Figure 1. Unit Disposal Cost for a Conventional Shallow Land Burial Operation (Reference 1)

18.5 + Total Disposal Plus VR Cost \ \. Point of

Cost per Unit Volume of Waste Prior to VR

0 1.0 Fraction of the Initial Volume Remaining

Figure 2. Finding the Point of Optimum VR (Reference 1)

18.6 I 40 -

Total Disposal 30 - Plus VR Cost (S/ft3)

C I I I I 1.0I I 0.2 . 0.4 0.6 0.8 Fraction of the Initial Volume Remaining b) Large Compact - Figure 3. The Effect of Surcharge (SC in $/ft3) on LLRW Disposal Costs for a) a Small Compact b) a Large Compact (Reference 1) Part 2

18.7 160,

150

140

Total Disposal Plus VR Cost 130 ($/ft3)

120

110

100

< 0

I 0.2 0.4 0.6 . 0.8 1.0 Fraction of the Initial Volume Remaining a) Small Compact

Figure 3. The Effect of Surcharge (SC in $/ft3) on LLRW Disposal Costs for a) a Small Compact b) a Large Compact Part 2

18.8 n

Because fumiture finishing products have been traditionally solvent- based, the issue of reducing wastes fm fhishhg proiiucts is bund up with the issue of reducing volatile organic CcBnpOund (VE) emissions. currently it is VOC emission regulation much more than a concern about reducing wastes that is drivirg whatever mement there is in the industry tmard substitute finishing products and technologies.

Furniture finishing as it relates to high quality residential fumiture involves a process which may consist of 30-35 steps. The pnxess my include application of various kinds of stains, fillers, glazes, sealers, wash coats, and top coats which are used to achieve a specific and distinctive final appearance, It is this distinctive appearance that the furniture maker is selling, and the process used to achieve this look is crucial. In many cases, the individual finishing processes have evolved over long periods, perhaps 50 years, and represent substantial hves~tson the part of the manufacturers the and process research. The processes were developed uskg very specific finishing products, and while some modern finishing P-h- , for instance-my be acceptable substitutes for older ones, in l~nycases substitutions dramtically alter the appearance of the finished pmduct. "is is particularly true in the case of top coatings: substituting the mre recently developed water-based coatings for organic solvent-bome coatings upon which the processes were originally based may change the entire process and alter the distinctive appearance of the final product. Although some of the major finishing product mufacturers have worked on develop- water-based top ccats, they have been unable to achieve the clarity that my furnitum manufacturers need.

Sane Segments of the Furniture Industry Can Take Advantage of Alternative Coating Technologies Manufacturers of ContempOLary furniture-particularly contemporary furniture with high+xs finishes, which is essentially constructed fram panels that lend themselves to flat-line finishing, can now rely on largely non-polluting finishing processes such as ultraviolet curing and/or electron beam curing, These processes can help certain segments of the furniture industry reduce finishing wastes because they use high-solid materials and very little solvent to produce almost instantaneous cures. These processes are not suitable, however, for finishing carved furniture such as the Chippendale style.

Metal furniture can be finished using mer coating and electrostatic application techniques, which again use very little solvent. any manufacturers of juvenile furniture also successfully use electrostatic finishing. In juvenile furniture, the COnceM is not so much with the quality

President, Ross Associates Inc, P.O. Box 2018, Asheville, NC 28802 (704) 255- 8778

19.1 of the finish as with its non-toxicity. These processes, hmever, are not applicable to high-quality, fashion furniture.

So, scnne segments of the furniture industq can significantly reduce their use of solvents and therefore their generation of solvent waste. However, these are few substitute prodtucts or techniques manufacturers of high- quality residential and office furniture can take admntage of, and there seems to be little cooperation between the fumitum makers and the manufacturers of finishing products to develop acceptable substitutes. The furniture makers take the position that when samething satisfactory is available, they will use it, and the finishing products manufacturers take the position that it is not reasonable to expect them to make the entire irrvestnent in research and development since they can sell their current prducts with no problem. Breaking out of this stand-off may require that furniture inaustry associations, such as the American -tun= Manufacturers Association or the National Kitchen Cabinet Association, get out front and take a proactive position on the waste reduction issue. ?he industry my also need help in encouraging wider adoption of the available successful techniques fran the universities, where a lot of the technology resides but has not been transferred. The muse of waste reduction needs to be given impetus in the furniture inaustry because it is going to beccane necessary, and them is no use in waiting until our backs are against the wall to respond.

Waste Disposal Pmblans Can create unaqected crises for Manufacturers Recently I visited a furniture plant which had just gotten word that the qlier of the rags used in the company’s wiping stain process is going out business. The rag qlier had also been laundering the rags and had been told that the& wastewater treatment plant can no longer camply with EPA regulations. The furniture manufacturer was faced with re-evaluatw its enth finishing process, which it had been using for many years, in two weeks. -Another fllbstance that the furniture industry is going to have to deal with soon is urea formldehyde. Most of the glue that is used in prcduction gluing, such as veneer or plastic lamination, is based on urea formaldehyde. Regulations rqaxdmg’ this substance have became very stringent, about one part per million, and that‘s almost zero. mture manufacturers are going to have to address both the emission of VOCS fmthe finishing producrts and glues they use and the disposal of wastes i from these products. Still, no one has taken the initiative to aggressively address the issue. Same processes that are begiming to offer mid sdctims to voc: a-d waste problems for furniture manufacturers are the new high-- coating methods, sane of which I referred to earlier. AS 1 have explained, these new methods are excellent for sane uses but totally inadequate for others, so they are not a cure-all. However, solvhg the problems we can solve is a first step, and more wideSpreaa adoption of these processes would certainly have benefits. The coating methods to which I refer are as follows:

19.2 7 3

Vincent Ross 1

muse furniture finishing products have been traditionally solvent- :1 based, the issue of reducing wastes fm finishbq prducts is bound up with the issue of reducing volatile organic cmpund (VE) emissions. CUrrenuy it is VOc mission regulation much more than a concern about reiiucin~wastes that is driving whatevm mavetrent there is in the industry tcxlJard substitute 7 finishing prcducts and technologies. Furniture finishing as it relates to high quality residential furniture :I involves a process which may consist of 30-35 steps. The process may include application of various kinds of stains, fillers, glazes, sealers, wash coats, and top coats which are used to achieve a specific and distinctive final appearance. It is this distinctive appearance that the furniture maker is selling, and the process used to achieve this look is crucial.

In many cases, the individual finishing processes have evolved over long -1 periods, perhaps 50 years, and represent substantial hestmnts on the part of the manufacturers in time and process research. The processes were develow us- very specific finishing products, and while same modern finishing P-h- ' , for instance-may be acceptable substitutes for older ones, in many cases substitutions Hramatidly alter the appearance of the finished product. ?his is particularly true in the case of top CcMtings: substituting the mre recently developed water-&sed coatings for oqadc solvent-bme coatings upon which the processes were originally based may change the entire process and alter the distinctive appeannce of the final pmduct. Although same of the major finishing prcduct manufacturers have worked on developing water-based top coats, they have been unable to achieve the clarity that many furniture manufacturers need.

Scnne segments of the Furniture Industry Can Take Advantage of Alternative Coating Technologies Manufacturers of contempoLary furniture-particularly contemporay furniture with high-gloss finishes, which is essentially construct& frcnn panels that lend themselves to flat-line finishing, can now rely on laqely mn-polluting finishing processes such as ultraviolet curing and/or electron beam curing. These processes can help certain segments of the furniture industry reduce finishing wastes because they use high-solid materials and very little solvent to produce almost instantaneous cures. These processes are not :I suitable, hmever, for finishing carved furniture such as the Chippendale style. ri' Metal furniture can be finished using powder ccatiriy and electsostatic application techniques, which again use very little solvent. my manufacturers of juvenile furniture also su-sfully use electrostatic :i finishing. In juvenile fumiture, the concern is not so much with the quality President, Ross Associates Inc, P.O. Box 2018, Asheville, NC 28802 (704) 255- 8778 %I

19.1 of the finish as with its non-toxicity. These processes, however, are not applicable to high-quality, fashion furniture. So, same segments of the furniture industry can significantly reduce their use of solvents and therefore their generation of solvent waste. However, there are few substitute pmcts or techniques manufacturers of high- quality residential and office furniture can take advantage of, and there seems to be little cooperation between the furniture makers and the manufacturers of finishing products to develop acceptable substitutes. The furniture makers take the position that when samething satisfactory is available, they will use it, and the finishing products manufacturers take the position that it is not reasonable to apct them to make the entire inveshent in research and developrmt shethey can sell their current prducts with no problem. Itieaking out of this stand-off may require that furnitun? industry associations, such as the American Furniture Manufacturers Association or the National Kitchen Cabinet Association, get out front and take a proactive position on the waste reduction issue. The industry my also need help in enaxraging wider adoption of the available successful techniques fmn the universities, where a lot of the technology resides but has not been transferrad. The cause of waste reduction needs to be given impetus in the furniture industry because it is going to become necessary, and there is no use in waiting until our backs are against the wall to respond.

Waste Disposal prc\blems Can Create Unexpcted crises for Manufacturers

Recently I visited a furniture plant Wfiich had just gotten word that the supplier of the rags used in the capany's wiping stain process is going out business. The rag supplier had also been laundering the rags and had been told that their wastewater treatment plant can no longer ccnrrply with EPA regulations. The furniture manufacturer was faced with reevaluating its entire finishing prccess, which it had been using for many years, in two weeks. -Another "e that the furniture industry is going to have to deal with soon is urea fonmldehyde. Most of the glue that is used in prcduction gluing, such as veneer or plastic lamination, is based on urea formaldehyde. Regulations reprdmg' this substance have becclme very stringent, about one part per million, and that's almost zero. Furniture manufacturers are going to have to address both the emission of VOcs fram the finishing products and glues they use and the disposal of wastes fm these products. Still, no one has taken the initiative to aggressively address the issue.

Same processes that are beginning to offer partial sclutions to Vex: and waste problems for furniture manufacturers are the new high-tech coating methods, same of which I referred to earlier. AS 1 have explained, these new methods are excellent for sane uses but totally inadequate for others, so they are not a cure-all. However, solving the problems we can solve is a first step, and more widespread adoption of these processes would certainly have benefits. The coating methe to which I refer are as follows:

19.2 1 1

Vincent Ross 1

Because furniture finkhing products have been traditionally solvent- -.-1 based, the issue of reducing wastes from fhishirq products is bound up with the issue of reducing volatile oryanic CcBnpOund (W) emissions. currently it is VOC emission regulation much more than a concern about reducbq wastes that is driving atever "ent there is in the industry tmard substitute finishing prducts and technologies. Furniture finishing as it relates to high quality residential furniture involves a process which may consist of 30-35 steps. The process may include application of various kinas of stains, fillers, glazes, sealers, wash mats, and top cats which are used to achieve a specific and distinctive final appearance. It is this distinctive appearance that the furniture maker is selling, and the process used to achieve this look is crucial. In many cases, the individual finishing processes have evolved over long periods, perhaps 50 years, and repmt substantial invesmts on the part of the manufacturers in time and process research. The processes were developed using very specific finishing prcducts, and wfiile some modern finishing P-h- * , for instance-my be acceptable substitutes for older ones, in many cases substitutions dramatically alter the appearance of the finished p-ct. ~s is particularly true in the case of top coatings: substituting the more recently developed water-based coatings for organic solvent-borne coatings pnwhich the processes were originally based my change the entire process and alter the distinctive appearance of the final pmct. Although same of the major finishing product It.rarmfacturers have worked on developing water-based top coats, they have been unable to achieve the clarity that many furniture "facturers need.

Scene segments of the Furniture Industry Can Take Advantage of Alternative Coating Technologies

Manufacturers of contemporary furniture-particularly contemporary furniture with high-gloss finishes, which is essentially constructed fram panels that lend themselves to flat-line finishing, can now rely on largely non-polluting finishing processes such as ultraviolet curing and/or electron beam curing. These processes can help certain sespnents of the furniture industry reiiuce finishing wastes because they use hig-h-solid materials and very little solvent to produce dLmost instantaneous cures. mese processes are not suitable, hmever, for finishing carved furniture such as the Chippendale style.

Metal furniture can be finished using mer coating and electrostatic application techniques, which again use very little solvent. Many manufacturers of juvenile furniture also successfully use electrostatic finishing. In juvenile furniture, the concern is not so much with the quality

President, Ross Associates Inc, P.O. Box 2018, Asheville, NC 28802 (704) 255- 8778

19.1 of the finish as with its non-toxicity. These processes, however, are not applicable to high-quality, fashion furniture. SO, same segments of the furniture industry can significantly reduce i their use of solvents and therefore their generation of solvent waste. Hmwer, there are few substitute products or techniques manufacturers of high- quality residential and office furniture can take admntage of, and there seam to be little cooperation between the furniture makers and the manufacturers of finishing products to develop acceptable substitutes. The furniture makers take the position that when sm~thingsatisfactory is available, they will use it, and the finishing products manufacturers take the position that it is not reasonable to expect them to make the entire hesinent in research and development since they can sell their current proctuctS with no problem. Breaking out of this stand-off my require that fLlrnitUre inaustry associations, such as the American mture Manufacturers Association or the National Kitchen Cabinet Association, get out front and take a proactive position on the waste reduction issue. The inauStry my also need help in encaUraging wider adoption of the available successful techniques from the universities, where a lot of the technology resides but has not been transferred. The cause of waste reduction needs to be given impetus in the furniture jrdwtry because it is going to become necessary, and there is no use 1 in waiting until our backs are against the wall to respond.

Waste Disposal prablems Can create Unexpcted crises for Manufacturers Recently I visited a furniture plant which had just gotten word that the supplier of the rags used in the ampany’s wiping stain process is going out businesS. The rag Wlier had also been laundering the rags and had been told that their wastewater treatment plant can no longer ccnnply with EFA regulations. The furniture manufacturer was faced with reevaluating its entire finishing process, which it had been using for many years, in two weeks. -Anothersubstance that the furniture industry is go% to have to deal with soon is urea formdldehyde. Most of the glue that is used in prcduction gluing, such as veneer or plastic lamination, is basd on urea formaldehyde. Regulations rqardmg’ this substance have becaw very stringent, about one part per million, and that’s almost zero. Furniture manufacturers are going to have to address both the emission of VoCs fmthe finishing prcducts and glues they use and the disposal of wastes from these products. Still, no one has taken the initiative to aggressively address the issue.

same processes that are begLmLxJ tG off= p-itial SdXtiGns to “oc: &i waste problems for furniture manufacturers are the new high-tech coating methods, sane of which 1 refwed to earlier. AS I have explained, these new metha are excellent for sane uses but totally inadequate for others, so they are not a cure-all. However, solving the problans we can solve is a first step, and more widspread adoption of these processes would certainly have benefits. The Coating methods to which I refer are as follows:

19.2 Because huniture finishing products have been traditionally solvent- based, the issue of reducing wastes fram finishing products is bound up with the issue of reducing volatile organic cumpoud (VOC) emissions. currently it is VOC emission regulation much more than a concem about reducing wastes that is driving whatevw "ent there is in the industry tmard substitute finishing products and technologies. F"ilxre finishing as it relates to high quality residential furniture hwolves a process which may consist of 30-35 steps. The process may include application of various kinds of stains, fillers, glazes, sealers, wash coats, and top coats which are used to achieve a specific and distinctive final appearance. It is this distinctive appearance that the furniture der is selling, and the process used to achieve this look is crucial. In many cases, the individual finishing processes have evolved over long periods, perhaps 50 years, and represent substantial hvestments on the part of the manufacturers in the and process research. The processes were developed using very specific finishing products, and while sane modern finishing P--- P--- , for instance mybe acceptable substitutes for older ones, in many cases substitutions dramatically alter the appearance of the finished product. "is is particularly true in the case of top coatings: substituting the more recently developed water-bsed coatings for organic solvent-borne Coatings upon which the processes were originally based may change the entire process and alter the distinctive appearance of the findl prduct. Although some of the major finishing product mufacturers have worked on developing water-based top coats, they have been unable to achieve the clarity that my furniture manufacturers need. sane segments of the Furniture Industry Can Take Advantage of Alternative CCMting TechmlOgies Manufacturers of cOntempOLarY furniture-particularly ContempOLary furniture with high~lossfinishes, which is essentially constructed fm pels that lend thanselves to flat-line finishing, can now rely on largely non-polluting finishing processes such as ultraviolet curing and/or electron beam curing. These processes can help certain segments of the furniture inauStry reduce finishing wastes because they use high-solid materials and very little solvent to produce almost instantaneous cures. These processes are not suitable, hcwever, for finishing carved furniture such as the Chippendale style. Metal furniture can be finished us- PCxJder coat- and electrostatic application techniques, which again use very little solvent. Many manufacturers of juvenile furniture also successfully use electrostatic finishing. ~njuvenile furniture, the concern is not so much with the quality

President, Ross Associates Inc, P.O. Box 2018, Asheville, NC 28802 (704) 255- 8778

19.1 of the finish as with its non-toxicity. These processes, hawever, are not applicable to highwity, fashion furniture. SO, same mtsof the furniture industry can significantly reduce their use of solvents and therefore their generation of solvent waste.

However, these are few substitute products or techniques manufacturers of high- ~ quality residential and office furniture can take ahtage of, and there seems to be lime cooperation between the furniture makers and the mufacturers of finishing products to develop acceptable substitutes. The furniture makers take the position that when sumethjng satisfactory is available, they will use it, and the finishing pmcts manufacturers take the position that it is not reasonable to e>rpect them to make the entire investment in research and developmt since they can sell their current prodtucts with no problem. Breaking& Of this Stand-off lMy -that furniture indU&rY associations, such as the American Furniture Manufacturers Association or the National Kitchen Cabinet Association, get out front and take a proactive position on the waste reduction issue. The industry may also need help in encoUraging wider adoption of the available successful techniques fmn the universities, where a lot of the technology resides but has not been transferred. me cause of waste r&uction needs to be given impetus in the furniture inaustry because it is going to beccane necessary, and there is no use in waiting until our backs are against the wall to respond. Waste Disposal Pmblems Can Create Un- crises for Manufarrturers

Recently I visited a furniture plant which had just gotten word that the supplier of the rags used in the company's wiping stain process is going out business. 'Ihe rag sqqlier had also been launderhg the rags and had been told that their wastewater mtment plant can no longer ccsnply with EFA regulations. The furniture manufacturer was faced with re-evaluathg its entire fhhhhg process, which it had been using for many years, in two weeks. -Another fllbstance that the furniture industry is going to have to deal with soon is urea formaldehyde. Most of the glue that is used in production gluing, such as veneer or plastic lamination, is based on urea formaldehyde. Regulations regardulg' this substance have became very strirgent, about one part per million, and that's almost zero. Fbmh~manufacturers are going to have to address both the emission of vocls fram the finishing prcducts and glues they use and the disposal of wastes from these products. still, no one has taken the initiative to aggressively address the issue.

Same processes that are beginning to offer partial solutions to voc anti ~ waste problems for fumiture manufacturers are the new high-tech coating methods, saw of which I referred to earlier. AS 1 have explained, these new methods are excallent for scrme uses but totally inadequate for others, so they are not a cure-all. Hmever, solvh-q the problems we can solve is a first step, and more widespread adoption of these processes would certainly have benefits. The Coating methak to which I refer are as follows:

19.2 * Electrostatic spray coating uses the attractive force between materials of oppasite electrical charye to aid in applying a uniform coating to various surfaces. n-ris method reduces overspray ard waste, thus imprwing application efficiency over ordinary spray coating processes. organic emissions are reduced because of this efficient p"e. For solvent and water-bome coatings, the amaunt of coating solids and corresponding solvent carrier needed for a specific coating job are also reduced. Electrostatic spray coating is used to apply solvent-borne, water-bo-, or pcrwder coatings. * Hot melt formulations are applied in a molten state. mere is no solvent to evaporate so about 100 percent of the mterials that are deposited remain as a solid part of the coating. Hot melt coatings are most often applied to paper, pa-, cloth, and plastic. Because hot melts work only for certain purpses, they cannot be judged universally applicable in the paper and fabric coating

-0 * High-solids coatings reduce solvent anissions. The basic wentin an organic coating is the binder or resin, which is a film-forming oryanic polymer with glassy, plastic, or rubbery pmperties in the dried state. mere are two categories of high solids resins: two capnent ambient temperature cured, and single cmponent heat converted. High-solids coatings can be used to redtLlce solvent emissions in a variety of industrial coating P-= P-= * Electron beam curing is a process in which high energy electrons are used to cure electron beam-c=urable coatings. Electrons bambard a coating and produce free radicals throughout the coating, thus initiating a c=rosslinking reaction that continues until the coating is cured. This process is most effective on flat surfaces where the electron beam strikes the surface vertically. If the beam strikes the surface at an angle closer to horizontal, the amount of aksorkd energy is too dland causes the coating to cure impraperlY * ultraviolet curing is a process in which ultraviolet light reacts with photcsensitizers in the coating to initiate crosslinking to form a solid film. The main cmponents of an ultraviolet curable coating are an ultraviolet-curable base polymer, diluent monmers, and ultraviolet photochemical initiators. Ultraviolet light for curing is useful and effective on flat surfaces where the light reaches the surface vertically. when the ultraviolet light strikes a surface at an angle closer to the horizontal, the amount of absorkd light is too small for effective curing.

19.3

Keith Clark Ultraviolet (W)processing is beginning totouch every aspect of our lives. W makes possible aseptic packaghg of fruit juices and other foods, and it cures the finishes on no-wax floors, beer cans, reflector panels for automobile headlights, and hundreds of other products. Electron beam (EB) processing is a related curing method. Both systems instantaneously cure inks and coatings which do not contain solvents or other volatiles. W curing uses photons generated by ultraviolet light. The light is comtrakd by reflectors and is to the product which contains materials with light reactive photoinitiators. The reaction betw~the UV light and the photoinitiators in the coat- prduces a solid film. ?he W process can be used to cure a wide variety or proctucts frm flat sheets and webs of paper to wmplw three-dimensional objects like furniture and autamotive trim pieces. In E5 curing, electrons dtt& from hot cathcdes and accelerated to near the speed of light are passed through thin metal foils to the prduct, where they set up a crc5slir3cing reaction that results in curing. Accelerated electrons can penetrate dense materials and are used in curing lamhates and other opaque materials. One of the fh& things UV was used for, in about 1976, was filling for printed particleboard. ?he gwexal process for prd~~cingprinted particleboard today is to w fill with a base coat, put a woodgrain printed paper over it, put a clear coat over that, and then cure everything all at once by EB. 'ihis process is very quickly replacing lm- and high-pressure laminatins prcesses for the proltuction of wod panels for use in hausehold furniture, office furniture, kitchen cabinets, vanities, table tops, store fixtures Id shelvhg. The same processes are used to produce solid color panels. W can be used to addeve the real look of wood veneer, a high+oss finish, or a dead flat finish, and it can be used to apply a coating that will resist water marks and stains. It is quite viable for myuses. EB and W curing have myadvantages. By using lower tarrperature prmessing and reaUcing curing time, radiation curing saves energy. W and EB e.quipnent use abut 20 percat of the energy consumed by thermal systas. The use of these processes also saves plant floor space because the equipment is more -ct. coor~,for instance, replaced a 230-fwt oven used to cure paint on beer cans with a six-foot w box. The processes ais0 save time because they work almost instantaneously, and goods can be handled and packed h"ediately after being cured. And, of course, the advantages you are mst interested in tcday are that because they use no solvents or other volatiles, they re3uc.e concern about air pollution and worker exposure, and they eliminate solvent and

UCB/Radare Specialties, 5365-A Robin Hood Rd., NorfolJc, VA 23513 (1-800) 4 26-382 0

20.1 other hazardous chemical wastes. meze are many ewmples of finns that have been able to elkbate entirely their solvent use and get rid of solvent syste~~by adoptkg radiation curing-3M and Hallmark cards are two. Hallmark uses W for curing the high gloss finish on sane of its cards.

lhere are, hmever, sa~=regulatory concerns related to radiation curing. ~- While the pmcesses help to solve a& pollution problem, there are sane concerns abuut possible health effects of the acrylics used and about the health effects of the radiation itself.

20.2 HAZARDOUS WASTE VOLUME REDUCTION: THE NEW MANDATE Wayne R. Thomann 1 Historically, burial in a secure landfill has been the primary method of hazardous waste management. Landfill burial was initially popular because it was the cheapest and easiest disposal method available. However, the recognition that no landfill is permanently llsecurellhas resulted in a strong mandate to reduce the volume of hazardous waste being disposed of in this manner. The 1984 Reauthorization of the Resource Consenration and Recovery Act (RCRA) includes an amendment prohibiting the landfill disposal of certain hazardous wastes. Another amendment requires that hazardous waste generators document efforts to reduce the quantity of hazardous waste they generate. In addition, the State of Washington has prohibited the disposal of deregulated low-level radioactive waste at the Hanford, Washington, site. The safety professionals at the Duke University Medical Center, having anticipated this regulatory pressure, have been developing a comprehensive hazardous waste management program that utilizes alternative management practices to significantly limit hazardous wastes requiring landfill disposal. Alternative methodologies that either have been or will be implemented include: recycling, redistillation, neutralization, substitution of less hazardous materials in specific processes, volume reduction through crushing/compacting, and legitimate and beneficial use of hazardous waste as a fossil-fuel replacement. In addition to the environmental and regulatory benefits of this program, it is estimated that the institution will save $275,000 annually in both disposal and repurchase costs. The development of the hazardous Waste Management Program has been facilitated by the concomitant development of a computerized system for monitoring hazardous material from arrival at the facility through ultimate disposal. The computer system is comprised of several interrelated databases. A laboratory audit database includes information on the hazardous material used and the wastes generated in each laboratory or work area. A hazardous waste disposal database contains information on the types of waste, quantities of waste, and ultimate disposal method. Interfacing these programs allows both the rapid identification of wastestreams that are candidates for alternative management methods and the evaluation of the efficie~t7' "1 of present waste managexent practices.

' Safety and Hospital Epidemiology, Duke University Medical Center, Box 3914, Durham, NC

21.1 The regulatory and technical aspects of alternative management practices will be discussed. The application of alternative methods to specific wastestreams and the development of hazardous waste computer systems also will be presented, Small, Diverse Wastestreams Make Laboratory Waste Management Difficult The management of hazardous waste is not a new problem in diagnostic and research laboratories. Although there are numerous options for the management of chemical wastes, the burial of waste in secure landfills has been the primary method of disposal. This option is generally selected because it has been the simplest and least expensive methods available. Alternative waste management strategies are not new and have been applied to industrial waste streams for years. However, research institutions have only recently begun to exploit these technologies. The explanation for the lack of initiative in laboratory facilities is in part related to the differences in the characteristics of the waste streams generated in these varied settings. In the industrial setting, a limited number of chemical wastes are generated in large volume from a relatively small number of work areas. This wastestream is very compatible with the implementation of tfon-sitetlvolume reduction efforts. On the other hand, laboratory activities produce a diverse wastestream generated in small volumes from numerous work areas. In addition, the potential hazards of some research chemicals may not be clearly defined, These factors contribute to complicated on-site management and necessitate a sophisticated program to facilitate effective volume reduction. Before considering the waste management options that could be incorporated into a comprehensive program, it is necessary to consider some of the forces that will influence our re-evaluation of our present waste management practices. We must develop our programs within the constraints of the regulatory mandate, environmental issues, public relations and community awareness, extended liability, and fiscal limitations. The regulatory mandate was initiated with the enactment of Public Law 94-580, the Resource Conservation and Recovery Act of 1976 (RCRA). RCRA represented a national initiative to track chemical waste from "cradle to grave"--that is, from the point of generation, through transportation and treatment, to ultimate disposal.

Hazardous and Solid Waste Amendments of 1984 Regulate Small-Quantity Generators, Madate Volume Reduction More recently, the U.S. Congress passed the Hazardous and Solid Waste Amendments of 1984 which included the reauthorization of funding for RCRA. Through these amendments, Congress directed the Environmental Protection Agency (EPA) to

21.2 develop regulations for facilities that generate between 100 and 1,000 kilograms of hazardous waste per month, This new classification of small quantity generators will include many previously unregulated laboratories that will be required to develop waste management programs. Further, Congress mandated that all hazardous waste generators must document efforts to minimize waste generation as of September 1, 1985. The amendments also included a new statement of national policy regarding hazardous waste management: The Congress hereby declares it to be the national policy of the United States that, wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment. They went on to state: ...land disposal, particularly landfill and surface impoundment, should be the least favored method for managing hazardous waste. Further, generators were directed to minimize both the generation and land disposal of hazardous waste by encouraging process substitution, materials recovery, recycling, reuse, and treatment. These policy statements of the hazardous and Solid Waste Amendments of 1984 are clearly a sweeping mandate that all hazardous waste generators re-evaluate their management practices. Another factor influencing hazardous waste management is environmental concerns, We are all familiar with the highly publicized consequences of inappropriate management of hazardous waste. Leachates from a toxic waste dump at the Love Canal resulted in the relocation of an entire community. The clean-up of abandoned hazardous waste sites looms as a major drain on our national resources. All hazardous waste generators have a moral and legal responsibility to assure that similar situations do not recur in the future. The public relations aspect of hazardous waste must also be considered. The community is becoming increasingly concerned. about what wastes are being generated, how they are stored on=site, how they are managed, and how our waste might impact on the health of the community. These concerns may evolve into fears which can adversely affect how the citizens perceive our status within the community. Consequently, it is advisable to keep specific community support groups apprised of your hazardous waste management procedures. In fact, RCRA requires all

21.3 regulated generators to develop a contingency plan which includes the establishment of a cooperation agreement with local emergency response personnel.

Liability, Cost of Disposal Encourage Use of Disposal Alternatives Another issue is the liability associated with hazardous waste. Increased liability is inherent in many of the waste management operations. Liability begins with the transportation of hazardous materials onto the site and continues through transportation of the waste for ultimate disposal. Even on-site management of hazardous chemicals and waste has it own associated risks, and a risk-benefit analysis should be conducted before specific management options are adopted. Liability also increases during on-site storage, as larger volumes of waste accumulate prior to shipment off-site. Additional storage liability may be incurred because the contracted transporters or treaters of your waste may temporarily store them (up to 10 days) in relatively insecure sites prior to ultimate disposal. Waste handlers must be carefully selected and monitored because even seemingly legitimate and reputable contractors may employ reckless methods of disposal. Illegal "idnight dumping" still occurs, and the generator may be found liable for the resultant environmental or public health consequences. Such inappropriate disposal liability was delineated when the U. S. Congress enacted the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980. CERCLA is more commonly known as the Superfund act. As a final consideration, we must evaluate the fiscal consequences of waste management. In the past, disposal cost was a primary concern, and simple, inexpensive disposal methods were employed. Generally, the method was disposal in a secure landfill. However, more recently, the potential cost benefits of effective waste management have been identified. This new recognition is resulting in the development of complex hazardous waste management systems with appropriately trained support personnel. On-site management is beginning to be exploited and incineration is being used increasingly as the method of ultimate disposal. Comprehensive Hazardous Waste Management Systems Are Aimed at Minimizing Cost, Environmental Impact Recognizing the interactions of all of the above mentioned influencing factors, we have been developing a comprehensive hazardous waste management program within my institution. It is intended that the following observations may serve as a guide for the re-evaluation of waste management in other institutions.

21.4 The objectives in developing a comprehensive program were first to review our past experience and to correct any existing problems. Next, we sought to develop procedures to facilitate tracking of hazardous waste from cradle to grave (an on-site extension of RCRA). Finally, the ultimate goals were to minimize the fiscal and environmental impact of our generated wastes. The necessary steps in developing the program were the characterization of the wastestream, the development and application of appropriate management methods, and the establishment of mechanisms to support compliance. The first step in the strategy for implementation was a characterization of the entire wastestream, including both the types and volumes of wastes generated. The vehicle for collecting this information was the development of a laboratory audit program. The information collected was not limited to a simple chemical inventory, but rather, included specific data regarding (1) laboratory safety practices; (2) containment devices: (3) chemical handling and storage practices; (4) hazardous waste management practices; (5) handling and storage of biological materials; (6) the identification and disposal of imminent chemical hazards. Obviously a great deal of the collected information was not directly related to hazardous waste management, however, this broad base of data has served as the foundation around which numerous other health and safety programs have been established. The specific chemical waste information that was collected included: (1) the identification of chemicals routinely used: (2) identification of specific chemical wastestreams: (3) the evaluation of intralaboratory disposal methods: and (4) the identification of chemicals requiring special handling. The next step, after identifying the facility's hazardous waste profile, was the evaluation of appropriate waste management options which included both intralaboratory and facility-wide procedures. Some of the waste management strategies that were considered are listed in Table 1. Process or material substitution is one option that has application in numerous laboratory settings. This strategy is based on the premise that the substitution of either nonhazardous or less hazardous starting material will reduce the impact of managing the resultant waste. One example of the application of this option can be found in the clinical microbiology laboratory. A modified method for the extraction of the organic acids produced by anaerobic bacteria has been developed. The routinely employed solvents, ethyl ether and chloroform, were replaced with the less toxic and safer solvent, methyl-tert butyl ether (MTBE). Since MTBE waste is easier and cheaper to dispose of than chloroform, the substituted methodology has both reduced

21.5 potential hazards in the laboratory and simplified the disposal of the generated waste. Waste Recovery, Recycling, Reuse Are Options

Another management option is the recovery of the waste ~ through a "legitimate and beneficialttreclamation of its BTU or heat value as a replacement of a fossil fuel. Specific provisions in RCRA exempt legitimately and beneficially reused waste from many of the regulations of the act. However, it must _- be noted that this exemption is currently being reviewed by the EPA, and consequently, state and/or federal waste management offices should be consulted prior to implementing this option at any facility. The utilization of this option is most frequently applied to non-halogenated flammable solvents. For example, it was determined that 55% of all hazardous waste generated at my . institution fell into this category. Consequently we contracted to dispose of this wastestream as a fossil-fuel substitute in an EPA regulated rotary-kiln incinerator, with the resultant savings of over $2,000 per year in disposal costs. We also significantly reduced the volume of waste being disposed of in a secure landfill. Recycling and/or reuse represents a third waste management option. The use of waste exchanges is one of the methods included within this option. Many states have developed waste exchange networks which will help identify contractors that can beneficially utilize your wastes. These contractors can either reduce your disposal cost or provide a profit by purchasing your waste materials. An example of this type of contractor is the Bethlehem Apparatus Company, who will purchase waste metallic mercury for redistillation and reuse. The use of this option has produced a $1,200 annual savings at our facility. It is also possible to develop an intrafacility waste exchange in which virgin materials that are no longer used in ne laboratory can be supplied for use in another laboratory. If this virgin material were not reused, much of it would eventually be disposed of as a hazardous waste. Another method of recycling waste is distillation. The advantages of on-site distillation and reuse of chemicals include reduced disposal volumes and cost, reduced costs for purchasing new starting materials, and reduced liability in transporting and disposing of the waste materials. The effectiveness of redistilling organic solvents is well documented. The cost- benefits of this methodology have been demonstrated at my institution where the distillation of xylene and ethanol generated in the pathology department is estimated to produce a $23,000 savings in disposal and repurchase costs.

21.6 It should be noted that an expanded application of the distillation technology may provide significant savings from a different wastestream. The potential benefits of redistilling and preparing scintillation cocktail from our low-level radioactive waste is presently being studied. Preliminary results indicate that 90% of all scintillation fluid waste can be recycled with at least a 60% recovery. Implementation of this recycling program would remove; 3,000 gallons of waste from disposal and would produce a $25,000 - $50,000 annual savings. A fourth management option is treatment of the generated waste. Generally treatment is limited to neutralization and detoxification. Neutralization is primarily directed toward treating acids and bases to render them noncorrosive. Detoxification methodologies have been developed that eliminate the hazards of certain toxins such as carcinogens. On-site treatment has the advantage of being relatively simple, producing a significant volume reduction, and being compatible with intralaboratory management of the waste. However, there is some question about the acceptability (under RCRA) of generators treating their waste to reduce disposal. One should discuss any proposed chemical treatment program with the EPA or other state regulators prior to utilizing this option. The final waste management option is the selection of a method for ultimate disposal of waste that cannot otherwise be managed on-site. The preferred method of ultimate disposal is incineration. Incineration in an EPA certified incinerator has the advantage of providing complete thermal destruction of the waste material. Since the physical and health hazards are eliminated, liability is essentially terminated--unlike the prolonged liability associated with wastes disposed of in secure landfills. Disadvantages include the fact that there are relatively few national contractors for incineration and that incineration is more expensive than landfill disposal.. However, if one performs a risk/benefit analysis, the advantages of reduced liability and more environmentally sound management should outweigh the disadvantages of incineration. Another method of ultimate disposal is burial in a secure landfill. While this represents an inexpensive option, it must be noted that no landfill is permanently secure and this method of disposal is considered environmentally unsound. In addition, landfill disposal carries the burden of extended liability for accidents or exposures that may occur in the distant future. The previous discussion has been directed primarily at chemical waste; however, we must also briefly consider radioactive wastes. Low-level radioactive waste is the primary component of the toxic wastestream generated from biomedical research and patient care activities, and effective management of

21.7 these wastes can provide significantly reduced disposal costs. Specific management strategies, amy of which are the same as those applied to chemical waste, are listed in Table 2. Specialized equipment for crushing and compacting plus space for on-site processing and decay are required for effective management of the low-level radioactive wastestream. Since such facilities were not available at Duke University, a new 8,000 - square-foot Environmental Safety Building was commissioned. It is projected that the construction costs will be repaid within four years from savings in disposal and repurchase costs. A summary of the cost-benefits of improved hazardous waste management is presented in Table 3. These savings will continue to grow as we expand the application of the various hazardous waste management strategies. Waste Management Program Includes Information Management The final component in establishing a hazardous waste management program is the development of mechanisms to support compliance. One element of support is the implementation of a system that is not restrictive and is easy for the laboratorian to utilize. The laboratorian's responsibilities within the program must be clearly defined and reasonable. Another element of support is the development of information management systems that facilitate compliance. To that end, we have applied the systems approach to develop an integrated computerized information management system. Numerous commercially formatted database management programs are presently being marketed. However, there are significant shortcomings associated with these programs. First, these packages are relatively expensive and must be used with specific computer hardware. Further, since the programs are preformatted, one must adapt data collection and entry to fit the constraints of these packages. On the other hand, developing internal programs from commercial software packages with user programmable database management capabilities offers significant advantages. The primary advantage is flexibility. Software packages such as SYMPHONY, d-BASE and Knowledgeman can be easily modified to facilitate the manipulation of distinctly different groups of information. Flexibility reduces redundancy in record keeping by allowing the user to develop customized, streamlined databases. The database can be developed to contain only that information relevant to a facility's operation. Updating of files as well as the addition and interfacing of new information can be accomplished without disrupting the existing database.

21.8 Additionally, these packages are reasonably priced and easy to use (user friendly). The database management capacity of these software packages allows databases to be organized according to various specific criteria. Several options for data manipulation and application are available to the user. Sorting of information allows records in a database to be ordered as selected by the individual. Records meeting specific criteria can be queried and extracted using user defined criteria. Hard copy printout of entire files, or specific section, is an option available to the user. Statistical analysis of data can be performed easily. For effective presentation of information, the graphic capabilities of these packages are useful. We have developed individual databases for our laboratory audits, hazardous waste disposal, emergency response and hazardous communications. Each of these databases is unique and provides specific information. Interfacing allows the cross- referencing of these databases. Interfacing can act like a check and balance system. For example, compliance with appropriate facility disposal policies can be evaluated and verified by cross-referencing the hazardous waste management and facility audit databases. Facility audit information will show what chemicals and processes are used in a specific location. The chemical waste stream(s) generated will also be noted. A correlation should be observed between the hazardous waste management database and the facility audit database. Taking into consideration the processes used and any in-house recycling, there should be a balance seen between chemicals entering the facility and chemicals disposed of as hazardous waste. Cross-referencing is also beneficial in preparing safety personnel for site visits or inspections. Without visiting a work area, one can access site specific information such as chemicals stored, processes used, and employee training records. Appropriate information such as material safety data sheets, information on labeling and protective measures and training materials can be compiled prior to such a review. In conclusion, I would repeat that hazardous waste volume reduction is truly THE NEW MANDATE. I challenge you to re- evaluate your current waste management practices and then to implement improved management strategies. Finally, you must share your experiences with your colleagues so that we all may promote a truly protected environment.

21.9 Table 1. Hazardous Waste Management Strategies

Process/Materi a1 Substitution Recovery Recycl ing/Reuse - waste exchange - distillation treatment - neutral izaii on . - detoxification U1timate Disposal - incineration - secure landfill

21.10 TABLE 2. Radioactive Waste Management Strategies

o Selection of Radioactive Material o Volume Reduction - Compaction (solid waste) - Crushing (liquid scintillation waste) o Regulated Release to Sanitary Sewer System o On-Site Storage for Decay o Distillation of Scintillatjon Fluid o Precipitation for Removing Radioactivity o incineration

21.11 ,

Table 3. Cost/Benefit Of Improved Management Of Hazardous Waste

Manaqement Strateav Annual Savings Legitimate and beneficial reuse as fuel supplement $2,000

Mercury recycl ing through a waste exchange activity $1,200

Chemical Waste Distillation - xylene 91 3 ,000 - ethyl alcohol $1 0 ,coo

Scintillation Fluid Recycling S25,OOO - 50,000

Crushing/Compacting Radioactive blaste $1 45,000

21.12 --mRIEs: IMTA-LABORXLORY KEZDlXX2Xl3S

Rosanne Feild ~ mere are three issues to consider when discussirg waste management in any kind of laboratory-id, clinical, academic, or research. These are - regulatory constraints, liability, and fiscal considerations. The Resaurce Conservation and Rewveq Act (RCRA) of 1976 was passed to protect human health and the envbmmt fmm the improper "agerent of hazardous wastes. Protection of hurrran health and the envhmtwas to be accmplished by %radle to gravet' tracking of hazardous wastes through the use of a manifest. when RcRA was enacted, it was geared txxJard the large qyantity generators, those generating more than 1,000 kilograms per calendar month. The sd.1 quantity generator was exempt frcsn RcRA provisions. Waste Minimization Efforts Are Madated

The Hazmous and Solid Waste A"ents of 1984 made up sane of the most significant legislation passed regarding hazardous waste managemat. These a"ents, fM,reauthorized RCRA. Secondly, they required the regulation of Wl-quantity generators, and this extended cuvemge to a lot of university and other smaller institutional laboratories. It mqwhd the re-evaluation of listed hazardous waste including new land dispsal restrictions. ?his has changed the way we dispose of a lot of our hazardous waste and the way we manage it both on-site and off-site. Finally, the Hazardous and Solid Waste &"mix requim waste "ization for bath larye- and small-quantity genmtors. the manifest that must be signed for hazardous waste shipped off-site there is a clause by which the person signing confirms that the cc~~lpafiyor institution has mde efforts to "ize waste. one Way to Minimize Liability Is to Minimize Waste Liability affects the ways in which we manage our hazardous waste. We can "ize our liability by dow the follOWing:

* utilizing environmentally sound waste lrranagement practices * "izing the transportation of wastes (If you can recycle on site or use volume reduction techniques, you can reduce the volume of waste you have to transport.)

* chocsing a reputable hazardous waste managanent company (There are a number of companies that claim to be hazardous waste "gement Companies when they are actually *lbrokers" or middlemen who simply hold wastes and hope that they can ccxne up with ways of aisposing of it, so check out the campany that you use very thorougfily. 1 * utiliziq waste "ization technologies on-site

I Becton Dickinson, 21 Davis Drive, Research Triangle Park, NC 27709 (919) 549- 8641

22.1 Letting Disposal Cost DiCtate Disposal Method Can Be False Ecoaany

Everyone is co;IlceTned with the cust of hazardous waste management, and cc.st seems to be the determining factor in eyaluating and choosing a waste disposal methcd. However, letting Cost be the deciding factor can be false ~ econamy if there is a slighUy more expensive methcd that reduces your liability. You can dispose of your waste at a minimal cost in a landfill, or you can disrx>se of it by incineration at a higher cost. Eut, several years dawn the mad, if that landfill should beeme a flrperfund site or if there - should be a leak or other incident, you will pay many ththe original disposal fee in clm-up costs. !&e best way to ri=duce aisposal costs is to reduce the amount of waste you aispose of by using waste exchanges, recycling techniques, and waste redudion.

Past Practices and Attitudes mardous waste Are No Ianger Valid

In the pt, we've looked to landfill disposal as the numbsr one disposal method because we have had the out-of-sight, out-of-mind mtality. That will no longer hold up. There is a great deal of long-term liability associated with landfilling, and we cannot simply forget about the wastes we place there. In the past, we have chemicals in large volumes because they were cheaper that way. If them's been a sale on a case of acetone, we my have bought a few gallons when we only need a few hundred milliliters. A substantial portion of a large-quantity Fplrchase may just sit in the laboratory until eventually it must be aisposea of. Today, there is a significant cost associated with diSpOS;h of that unused chemical. In the past, we have nut been strongly motivated to try new technologies. Now, regulations mandate that we try to &ce our hazardaus wastes. ~qonly the mtity of chemicals You Need One way to win to solve waste disposal problems arki reiiuce waste disposal costs is to buy only what you need rather than large quantities because it is cheaper. You can't always consider just the Unit cost in trying to make economical chemical purchases. As examples fmm the prmerican chemical Society's publication 'TES IS ~ettes"illustrate, you must take into a&unt the cost of disposing of unused chemicals to reach a true total cost. mere is a chemical supply ctrmpany that will package in any quantity that you require most of the chemicals they supply. With this service, you can order the exact munt of almost any chemical you need.

Recycle Wastes

Mother way to solve waste disposal problems and reduce waste disposal wsts is to implement waste "ization technolsgies. Among these technologies is recycling. Recycling can include several practices, including waste exchanges. Waste exchanges can be intra-facility, in which your cdnpany sets up a system-perhaps circulation of a cmputer printout of available chemicals or newsletter or bulletin board notices-letting people knm what's available. There are regional waste exchanges, which are set up primarily for large ccxmnercial users of chemicals, the nearest of which is the southeast Waste Exchange in charlotte.

22.2 Recycling can also refer to recavery of chemicdls. solvents can be distilled on-site and reused, or they can be sent off-site for distillation and ~-xe@rned to you for reuse. off-site distillation can be applied to Wmmercial grade &emi&s-things like paint thinners that do not require high purity-or to laboratory reagents in which high purity is required. You can substantially reduce the quantity of solvents you have to purchase thmqh recycling, and you can alnrost eliminate the diqcsal costs associated with solvents and greatly reduce the liability associated with dispsal. ?he %till bottciin~”are regulated and must be disposd of, so there is SCXIE remining liability associated with disposal of %till battams,” unless you send them offsite for incineration. your liability associated with transportation is also reduced. On the other hand, you can only send larye-volume (seveEd 55-gallon drums), siqlvnent solvent waste off-site for distillation, and, of course, you have to pay for distillation. Also, there is still liability associated with transportation because you are shipping the solvent off-site and it is being shipped back to you. merefore, you will want to weigh the advantages and disadvantages of off-site distillation against the advantages and disadvantages of on-site distillation. If you distill waste solvents on site, ycm have costs associated with eqyipnmt purchase and maintenance and personnel to operate the still. precious metals can also be recovered fmwastes. Waste containing metallic mercury-from broken thermometers or barmeters, for example-is difficult to dispose of. mere is a ccnnpany in Pennsylvania called Bethlehem Apparatus which redistills and recycles mercury. They handle both dl quantities from laboratories and lqequantities fmindustry. Silver in laboratory or photcgra@c wastes can be recovered. For lab wastes, the recovery can be incorporated into the actual p”e that generates the waste. A few added steps at the end of the p-e will recover silver in the form of silver powder or silver nitrate, depending on the number of steps utilized, fmwaste. The recovered mterial such as silver nitrate, whi& is a fairly expensive reagent, can then be used in -ent experiments. Silver can be recovered fmm phot0g”c solutions by electrolytic recovery or chemical recovery cartridges which are available frm Kodak. If you have larye quantities of X-ray film you can sell it to brokers who will pay you for the silver in it and ship it off to have the silver recwered.

process Modification an =so mce mardous waste -tities Anather area of waste reduction technology is process modification. This refers to the utilization of 1- hazardous or non-hazardous chemicals in place ~ of hazardous mterial. For example, in an experiment calling for benzoyl peroxide, an O~CperoXide which poses a pbblem from waste disposal cumpanis. Hmever there was an exprimental method available which utilized hydrogen peroxide, which is a great deal easier to dispose of than benzoyl peroxide. Process modification can also refer to the utilization of alternate p”eS to accomplish the same goal and to the reduction of the opntity of hazardous material used for a specific p”e. You can sale dm pl”!s in ally laboratory to use very dlamounts of chemicals. Volume reduction refers to three areas: neutralization, precipitation, and inactivation of wastes. Neutralization is applicable to small quantities of certain acids and bases, primarily mineral acids ad bases such as scdium hydroxide and potassium hydroxide. Neutralization can generally be

22.3 aaxmplished in a simple two-step proedure which most labs are capable of doing. Precipitation is applicable to snall quantities of inorganic heavy metal campow& and their aqueous solutions. It does not eliminate the hazardous CCBnponent of a waste, but it does "ize it. It separates out the hazardous of a waste that the remahhg waste, generally aqueous, can be component so ~ - dhpcsed of through the sanitaxy sewer. meintion is applicable to small quantities of carcinogen wastes, antineoplastic wastes, and hazardous pharmaceutical wastes. It involves the transformation of a hazardous material to a non-hazardcrus material by a &emical reaction or a series of chemical reactions. It is important to verify that the material yau are trying to inactivate has actually been destroyed kfore yau dispose of the material down the sanitary sewer. Finally, e31~s-ln3y recovery refers to recovering energy prbmrily fm waste solvents in the form of a fuel supplement. There is a company in Virginia called Oldover Corporation which has made a big business of energy recavery. reccrvery should be considered as a waste "ization alternative if distillation is not applicable to your waste stream. It requires wastes that have a high EmJ value and law water and halogen content. It is cost efficient for as little as one or two 55-gallon drums of solvent waste. As a generator of hazardous waste you have a responsibility to seek the most appropriate envhmtally sound management methods. these are reducix~the amount of waste that is shipped off your site by employing waste reduction tedmolcgies and eliminating the land dbposal of hazardous wastes by seeking alternative "gemtat options.

22.4 REDUCTION OF HAZARDOUS WASTES FROM NORTH CAROLINA HIGH SCHOOL LABORATORIES

George H. Wahl, Jr.1 Each school day, about 30,000 High School students are taught Chemistry in some 1300 classes throughout North Carolina. Since the typical High School laboratory may contain 500 or more different chemicals, the chances for unnecessary and dangerous chemical exposure and accidents are very high.

Moreover, since few if any High Schools have staff dedicated to the safe ordering, storage and disposal of chemicals, this responsibility usually falls on the already overworked Chemistry teacher. Without adequate time and/or experience to plan a year's experiments ahead of time, many teachers unwittingly have ordered chemicals already in stock, or have ordered quantities far in excess of the amounts needed in the belief that the volume discount will result in a net savings to the school. However, the cost of disposing of many chemicals far exceeds the original purchase price. Thus there has developed a great backlog of chemicals in the High School laboratories of North Carolina. This backlog presents a significant. safety hazard and a great financial liability to the school for the costs of the hazardous waste disposal.

Under the sponsorship of the Pollution Prevention Pays program, a task force of six competitively selected High School chemistry teachers from across the State met with the author and several resource persons for an intensive week at North Carolina State University during July 1987. This group assesed the present High School laboratory conditions in North Carolina, 'brainstormed' alternate solutions to the hazardous chemical dilemma and then developed an outline for a Handbook to be given free of charge to all High School chemistry teachers throughout the state. Each participant then worked with the director to write parts of the Handbook. We believe that it is more cost effective to educate the teachers with this Handbook than to attempt to directly remove the unnecessary chemicals from all of the High Schools in the state. The philosophy of the group can be summarized as - "Less is Better" . That is, if a laboratory can be conducted using a few drops of chemicals, there is no reason to use larger quantities. By decreasing the quantities of chemicals used, many benefits immediately appear. The initial cost of purchasing chemicals decreases significantly. Morever, the amount of hazardous waste is t rem end o u s 1y d e c re ase d w i t h t h e at t e n d ant f i n an c i a 1 and env i r 0n.m ent a1 benefits. By minimizing the quantities of chemicals present in a High School, the dangers of accidental spills or unauthorized use are also decreased. Another real benefit accrues in the liability realm. By minimizing the amounts of chemicals used, the teacher significantly decreases the chances of being sued as a result of an accident or other unforseen chemical encounter.

Professor of Chemistry and Director of Organic Chemistry, North Carolina State University, Raleigh, NC 27695-8204

23.1 This "Micro-scale" approach is rapidly replacing the more traditional techniques that require large quantities of chemicals.2

"Less is Better" also permits mpre laboratory inst ruction. With decreased quantities of materials to handle, students finish experiments faster and have more time to think about the results, or to repeat the experiment to check reproducibility, or to repeat it under a different set of conditions to gather more data. Since High School laboratory periods are very short, many experiments are omitted since they can not be completed in the time available. With the shorter "Micro-scale" experiments, teachers are likely to include more experiments, thereby giving the students better laboratory experience. Likewise, with significantly reduced amounts of materials the "Ch emopho bia I' that has paralyzed many is essentially neutralized and students participate more freely and concentrate more on the experiment rather than on worrying about what disaster is about to befall them.

The teacher's Handbook that we produced discusses the importance of laboratory work and encourages teachers to consider expanding the amount of time they devote to hands-on experiences for the students. It lists the various learning objectives of the North Carolina Competency based Curriculum in Chemistry and indicates appropriate experiments from the several most commonly used laboratory texts. In this listing, comments are included to indicate how the experiment could be scaled down to "Micro-scale" to accomplish the same objectives with one-tenth to one-hundredth of the amounts of chemicals suggested in the text. This reduction by itself greatly reduces the amount of hazardous waste generated.

The Handbook also contains a section on the importance of current Chemical Inventories. All schools need to keep their chemicals in a secure, well ventilated area. The Inventory of these chemicals must be kept current to decrease the chances of unnecessary orders and to alert the faculty and administration of the presence of any unusually dangerous materials or to the unauthorized loss of chemicals. Moreover, the Inventory is required by the 'spirit', if not by the letter of the community "Right to Know" law. The Handbook describes two currently available, easy to use, micro computer based inventory systems designed for the school laboratory.

The Handbook contains a well annotated list of all of the chemicals on the several lists in the well used "STOP" manual3 and attempts to put those listings in perspective. Many schools have incorrectly abandoned every chemical that is listed in the STOP manual. In the present Handbook, the chemicals are listed, and, for many, some measure of their realtive toxicity is given. The decision to use or not to use can not be made for all schools from a central authority. What is OK in a High School laboratory supervised by a well trained teacher, may not be suitable for a junior high lab supervised by a teacher without cenification in Chemistry. That chemical may be vital to the High

J. L. Mills & M. D. Hampton, "Microscale Laboratory Manual for General Chemistry", Random House, NY, 1988 ISBN: 394-37415-0; D. W. Mayo, R. M. Pike, S. S. Butcher, 'tMicroscale Organic Laboratory", John Wiley & Sons, NY, 1986, ISBN: 0-471-82448-8 "STOP - Safety First in Science Teaching", Division of Science, North Carolina Department of Public Instruction. Raleigh, NC 2761 1, Revised 1983.

23.2 School program and so should not be universally banned simply because it is not suitable in the least supervised circumstance.

The disposal of hazardous materials is carefuly discussed. Some typical costs are given to impress the teacher of the importance of minimizing the quantities used. Several ideas on how to neutralize typical wastes are discussed along with the suggestion that the topic of hazardous waste disposal be treated formally as part of the chemistry course under "Relevance and Current Topics in Chemistry" in the curriculum.

A section on how to take a typical experiment and scale down the quantities of chemicals used is included. It is hoped that individual teachers will take the time to adapt their favorite experiments to the more realistic "Micro-scale"2 approach. The importance of involving students in the cause of decreased quantities is stressed and suggestions are given on ways to involve students both within the curriculum and as extra-curricular activities.

The Handbook concludes with a Bibliography of significant reference material and articles that discuss situations familiar to the classroom teacher. Copies of the Handbook may be obtained from the author during the Summer of 1988.

The teachers who participated in the Workshop and in the production of the Handbook were:

Alice Anderson, E. A. Laney High School, Wilmington, NC

Rodney M. Bost, Alleghany High School, Sparta, NC Peggy Dowdle, Franklin High School, Franklin, NC

Richard S. Gizinski, East Forsyth High School, Kernersville, NC

Rhonda E. Weathersbee, Enloe High School, Raleigh, NC

Catherine W. Wooten, Kinston High School, Kinston, NC

Special thanks to Dr. William Spooner of the NC Department of Public Instruction for invaluable assistance in many phases of this task.

23.3

DEVELOPING AND IMPLEMENTING A WASTE REDUCTION PROGRAM by Gary E. Hunt, Environmental Engineer North Carolina Pollution Prevention Pays Program Raleigh, North Carolina

The development and implementation of a waste reduction program is a key element in any environmental management program. An effective reduction program must be based on accurate and current information on waste stream generation, and economical and technically-effective waste reduction techniques. This can be accomplished by establishing procedures to collect information, evaluate options, and identify cost-effective reduction techniques. Once identified, the techniques can then be implemented and become an established part of the facilities management and operation. An approach to developing and implementing a waste reduction program is summarized in Figure 1. This approach can be used by all types and sizes of companies. The first step in developing a program is to establish clear corporate policy. The full commitment from management of time, personnel, and financing is an extremely important requirement. Lack of this Commitment is often one of the most formidable obstacles to waste reduction.

_. 1.0 Facility Assessment

A facility assessment, or audit, provides a basis to collect the technical and economic information necessary to select appropriate waste reduction techniques. Depending on the size of the facility, an audit can be done by a single person or a team. The team approach is the best as the team as a whole will contain a wider range of experience, knowledge, and problem perception. ' An in-house team can include-. --management . and plant personnel from facilities engineering, environmental engineering, safety and health, purchasing, materials and inventory control, finance, and product quality control. The team should be selected and led by a technically competent person with sufficient authority to do the job.

24.1 Once the appropriate personnel have been selected, the next step ‘is to conduct the facility assessment. Information should be collected on the types, quantities, compositions, and sources of all air, solid, hazardous, and wastewater waste streams. This information is obtained through a search of available background data and supplemented with detailed data from a plant survey (1,2).

Background Information

All available background information must be collected first. This includes information on the production process, facility layout, waste stream generation and waste management costs. Some sources of this information are listed in Table 1.

Based on the collected information, a general flow diagram or material balance for each process step can be developed. The diagram should clearly identify the source, type, quantity, and concentration of each identified waste stream (see Figure 2). The background information can be used to develop and organize the plant survey and help identify data gaps, sampling points, problem areas, and data conflicts.

-< Plant Survey

After reviewing the background information and identifying additional data requirements, a survey can be conducted: (1) to verify background data and fill gaps; (2) to identify additional waste streams, and (3) to observe and collect data on actual operation and management practices. Each step in the

~ manufacturing process from the material delivery area to final product storage must be examined. Table 2 lists some of the types of waste that can be generated in each production area. Examples of specific process information which can be collected by a survey are listed in Table 3.

If detailed or specific data on waste stream quantity and composition are not available or cannot be calculated, then a sampling program should be included as part of the survey. Sampling points should be identified before the survey begins based on the waste flow diagram. However, additional

24.2 Facility Assessment Evaluation 6 Selection of Technique Program Implementation L Monitoring

Collect Background .Data

Identify Identify Waste

Plant + Economic Waste Overa 11 Data Specific ' + Survey Evaluations Specific Program Gaps Techniques i Plans Assessment Develop Corporate b Revise Policy Program I----- Develop Idcn t ify Implement Waste !laste .% t e t ial Overall Techn ica 1 Overall Sampling -b - Balance Facility Evaluation , Facility 3 Reduction L Techniques Program Assessment N I P w Ah k Tabulate Select Short Completeness (r Lonn Term .e i u Check

FIGURE P Approach to Developing and Implementing a Waste Minimization Program Detergent --+ Surface Cleaning L Water 80 l/min

Stannous -b Sensitizing * chloride 4 l/min 10 mg/l tin

P 4 Silver nitrate --+ Recovery 4 l/min Sodiug hydroxi- S.ilver Coating -+ Unit + Dextrose L 4 On-site . Wastewater --I ,4 Silver solijs 'treatment v (220 l/week) 288 l/min Copper sulfate + r\ ,Of f-site 120 l/min Recovery Iron Copper Coating 75 mg/l Copper ' F Sludge /\ Off -site (220 l/week) 'Landfill

* -.. De-ionized 80 l/min Rinsing/Drying water 10 ppm copper *

1 Spent xylene Off -site Paint Pain t ing (220 l/week) __+ incinera- ~ Xylene b Atmosphe:

Inspection/ Rejected +Off-site ~ Packaging 1 0 0/we e! wid g e t s landfill

Storage

FTCURE 2 Shiny Widget Production Process Material Balance

24.4 TABLE 1' Background Infonnation

Production Process Infomation

Process flow diagrams and plant layout

O Sewer layout diagrams

O Purchasing records

O Material Safety Data Sheets

Operating Manuals

O Water usage rates

O Plant operating schedule

O Production records

Waste Stream Information

O Manifests, annual reports and related RCRA information

O Environmental monitoring reports

Environmental pennits (solid waste, hazardous waste, NPDES, pre-treatment, air emissions)

O Information on any regulatory violations -'

O Location of all solid and hazardous waste collection/storage points

O Diagram of air, wastewater and/or hazardous waste treatment units

O Operating manuals for treatment units

Economic Information

O Water and sewer costs

'-Solid and hazardous waste management costs

O Cost of operating on-site treatment units

O Waste management contracts and billings

General Information

O Current waste minimization practices

O Copies of previous environmental audits

O Vendor information

24.5 a m m C v) v) d a M L d a m e, u m 3 & a, d -0 at a m 4 w v) d v) m I & at C w a, & ld w u & 0 (d li U E li d L fn a 2 v) v) 3 0 a a U L) m d U v) m 0 s a, J2 C u L (d v) 4 & U a, li li a, (I] rt ri u v) 0 rl U rJ m J= a m a, 01 e o L L v) 0 m m v) C & a, m U a > & C I4 a, a, CL? (d C M ? C ? d C li m (d ri 0 a m U cz VI v) C E s a 0 3 m '0 a U a & rl \ a C a a M U 0 a, C d m M rl 3" U v) (d 3 c E % % d m a ld 0 a 4 3 01 c5

m v) a, C d [I) a li (3 u a a 01 a &l 0 rl a 5 a dh0 M rr M e 0 C 4 rl 3 m d a aJ L) V U & C a 3 rl M 0 v) a li n rl v) v) 0 PI

C 0 d cv U U W 3 0 & 3 I&

24. € TABLE 2 Possible Sources of Waste (continued)

Plant Category Area Possible Waste Material

Support services Laboratories Reagents, off-spec chemicals, samples, sample

containers

Maintenance shops Solvents, cleaning agents, degreasing sludges,

sand-blasting waste, lubes, oils, greases,

scrap metal, caustics

Garages Oils, filters, solvents, acids, caustics,

cleaning bath sludges, batteries

Powerhouse/boilers Fly ash, slag, tube clean-out material, chemical

additives, oil, empty containers

Cooling towers Chemical additives, empty containers, cooling

tower bottom sediment

Source: After 3

! ‘I TABLE 3 Examples of Information from In-Plant Survey

Area Information

Material delivery and storage O Material transfer and handling procedures

O Storage procedures

Zvidence of leaks or spills

O Inventory of materials

O Condition of pipes, pumps, tanks, valves, and storage/delivery area

Production process Exact sources of all $rocess.waste

O Waste flow/quantity and concentration

O Operational procedures

Source, quantity and concentration of intermittent waste streams (i.e. cleaning, batch dumps, etc.)

O Condition of all process equipment including ?anks, pumps, pipes, valves, etc.

Evidence of leaks or spills

O Maintenance procedures and schedule

O Potential sources of leaks and spills

Waste management O Operational procedures for waste treatment units

O Quantity and concentration of all treated wastes and residues

Waste handling procedures

Efficiency of waste treatment units

O Waste stream mixing

24.8 samples may have to be taken as new waste streams are identified during the survey. Sampling of the waste streams should be done over a period of time to account for variations in production scheduling. Sampling may also have to be carried out over an extended length of time if products are produced on an irregular or seasonal basis. However, in many cases only qualitative information is needed. This usually can be calculated from the process input composition and simple flow measurements or historical records on waste generation. A preliminary review of the data should be performed during or just after the survey. This can help identify missing or inaccurate information. Additions and corrections should be made to the waste flow diagram and the overall data reviewed for completeness. For each waste stream the following information should be available:

Point of origin Subsequent handling/treatment/disposal Physical and chemical characteristics Quantity Rate of generation (i.e. lbs/unit of product) Variations in generation rate Potential for contamination or upset -, Cost to manage/dispose

2.0 Evaluation and Selection of Waste Reduction Techniques

Procedures used to identify, evaluate and select applicable waste reduction techniques will depend on the complexity of the manufacturing process, and the quantity and variety of waste generated. Successful approaches range from simple group discussions to complex computer modeling techniques (1, 2, 4 4). However, all approaches will contain the same basic steps: (1) list waste streams; (2) identify potential waste reduction techniques for each waste stream; (3) evaluate the technical and economic aspects of each technique; (4) select the most cost-effective waste reduction technique(s) for each waste stream. In addition to addressing specific waste streams, general recommendations on facility-wide reduction methods should also be

24.9 made. These could include such areas as material handling, maintenance, and operating procedures.

Once the techniques for each waste stream have been identified, the technical feasibility of each technique should be evaluated. An engineering evaluation should take into account such factors as applicability, waste reduction potential, operation and maintenance requirements, safety and health, ease of implementation, reliability, and any special design considerations. Not all of these factors are equally important for each technique. For example, an evaluation of a change in inventory management may only have to consider ease of implementation and reduction potential. At this point an engineering.consultant may be employed to provide additional expertise in evaluating technical feasibility.

As part of the technical evaluation, each technique should be evaluated according to the hierarchy shown in Figure 3. The liability associated with each step in the hierarchy increases as one goes down it. This will help during the selection process to bring the risks and liabilities associated with managing a waste into the evaluation process. As indicated, the best techniques for waste minimization is the elimination 01: reduction of the waste at its source. This will eliminate the risks and costs associated with management of the waste.

In addition to the technical evaluations, an economic analysis of each reduction technique should be done. Cost factors to consider include implementation costs (capital, installation, operating and maintenance) as well as cost savings due to lower production costs and waste management/disposal costs. Based on this information, a return on investment analysis can then be done to estimate the payback period. The current waste management cost is a very important factor which is often overlooked. These costs include not only the cost of shipping a waste off-site, but also includes the on-site expense of labor and time required to handle, manage, track, store, treat, and manifest the waste. Other considerations are harder to quantify but are very important and include liability insurance premiums, long-term liability and legal costs, worker health and safety, community relations , and regulatory compliance (1,2).

24.10 Liability Waste Minimization Category least

Inventory Management

Production Process Modification

I In-Process Recovery and Reuse

On-Site Recovery and Reuse

Inter-Industry Exchange

1Off-Site Recovery Greatest

FIGURE 3 Waste Reduction Hierarchy

24.11 The completed technical and economic analyses will enable the best waste minimization options for each waste stream to be selected. Techniques may be short term such as inventory control or longer term such as process modifications. This selection process is rather subjective and is usually based on the experience of several people who are in the decision-making process. In many cases there are just one or two technically-feasible and cost-effective alternatives. In some cases several techniques may be effectively used together to reduce the waste. For example, the first technique may be a segregation of a waste stream which enables recovery and reuse on-site.

Once the reduction techniques are identified, an implementation plan should be developed for each waste stream. This should include information on the implementation schedule, equipment needs, conceptual design, implementation requirements, management requirements, and cost estimates.

3.0 Waste Minimization Program Implementation and Monitoring

The waste stream reduction plans along with any general facility recommendations will form the basis of the waste minimization program. To insure continued program effectiveness, procedures must be established for -, monitoring and evaluating the techniques once in place. The program should address review and updating procedures as well as how the program will be integrated into the management structure. In addition, the program should be dynamic in nature to allow for production change and development of new waste reduction techniques.

The implementation of a waste reduction program can be done in a phased manner. Waste streams which present management problems and/or where the investment will have a rapid payback period, can be addressed first. Simple and low-cost techniques can also be put in quickly. In many cases this just involves improvements in inventory control, operation, and maintenance. One important factor is to keep the employees informed and involved at all steps in the development and implementation of a program. Employees will also be extremely valuable in evaluating a minimization program and in identifying ways to improve program performance.

24.12 A record-keeping system should be established to track the effectiveness of each segment of the program. Waste generation and reduction data should be calculated in terms of product production rates (i.e. pounds of waste per pound of product, pounds of waste per area of product, etc.). This would allow accurate comparison of waste generation and reduction data over time. Associated economic data as discussed above should also be tabulated to evaluate the efficiency of the waste stream reduction techniques. Based on the collected information, the program should undergo regular review and updating.

As discussed earlier, corporate commitment is a most important factor in the initial and continuing success of a waste reduction program. The program must become an integral part of a firm's corporate policy, product development procedures, operational procedures, and training program. A senior manager or executive committee could be given the authority and resources to develop, operate, and monitor the program throughout the company. If a firm is large enough, a small staff may be needed to evaluate the success of the program and develop new waste minimization approaches. Such a high level management commitment will help to keep the waste minimization program active in all parts and levels of the company, from new 1 product development to the maintenance staff. --

Companies have taken a number of simple approaches to insure the initial and continued success of a waste minimization program. Many have established, at the corporate level, a waste reduction engineering group that can provide technical assistance to all plants. Awards and financial incentives have been used to foster new ideas and innovations. Some firms also conduct annual audits of their plants to review and update existing waste reduction programs and to identify applicable new waste reduction methods. The establishment of a company-wide information exchange program using newsletters, fact sheets, publications, and/or internal conferences to transfer ideas has been successfully used. Other companies have instituted separate capital expenditure review procedures for waste minimization projects that require less paperwork and have a quicker review process.

24.13 4.0 SOURCES OF ADDITIONAL INFORMATION

Information on waste assessment techniques and applicable waste reduction methods can be obtained from the North Carolina Pollution Prevention Pays Program. The Program provides free technical-assistance to North Carolina industries and municipalities on ways to reduce, recycle and prevent wastes before they become pollutants. This non-regulatory program, located in the Division of Environmental Management, addresses water and air quality, toxic materials, and solid and hazardous waste. Designated as the lead agency in waste reduction, the Program works in cooperation with the Solid and Hazardous Waste Management Branch and the Governor' s Waste Management Board. The services and assistance available fall into the following categories :

Information Clearinghouse. An information data base provides access to literature sources, contacts, and case studies on waste reduction techniques for specific industries or waste streams. Information is also available through customized computer literature searches. Waste reduction reports published by the Program are also available.

Specific Information Packages. The staff can prepare facility or -* waste-stream-specific waste reduction reports for industries and communities. Information provided by the facility is used to identify cost-effective waste reduction options. A short report detailing these options is provided along with references, case studies, and contacts.

On-site Technical Assistance. The-staff can provide comprehensive technical assistance through facility visits. During an on-site visit, detailed process and waste stream information is collected. The information is analyzed, and a series of waste reduction options are identified. A report is prepared detailing these options and includes literature, contacts, case studies, and vendor information.

24.14 Outreach. The staff can give presentations on pollution prevention to industries, trade associations, professional organizations, and citizen groups. Depending on the audience, these programs range from an overview of the State's Pollution Prevention Program to in-depth discussions of technologies for specific industries.

Challenge Grants. A matching grant program provides funds for the cost of personnel, materials, or consultants needed to undertake pollution prevention projects. Projects eligible for grant funds range from characterizing waste streams in order to identify pollution reduction techniques to conducting in-plant and pilot-scale studies of reduction technologies.

'For further information contact the Pollution Prevention Program, Division of Environmental Management, P. 0. Box 27687, Raleigh, NC 27611. Telephone: 919/733-7015.

5.0 References

1. USEPA, Manual for Waste Minimization Opportunitv Assessment, Office of Research and Development, Cincinnati, Ohio, 1988. -.a

2. Ontario Waste Management Corporation, Industrial Waste Audit and Reduction Manual, Toronto, Ontario, Canada, 1987.

3. H. William Blakeslee and Theodore M. Grabowski, A Practical Guide to Plant Environmental Audits, Van Nostrand Reinhold Company, New York, MI, 1985.

4. Carl H. From and Michael S. Callahan, "Waste Reduction Audit Procedure--A Methodology for Identification, Assessment and Screening of Waste Minimization Options" in Proceedings of the National Conference on Hazardous Wastes and Hazardous Materials, Hazardous Materials Control Research Institute, Silver Springs, MD, 1986.

24.15 I

t HOW TO REDUCE WASTE, SAVE MONEY, AND BE A GOOD NEIGHBOR:

WASTE REDUCTION STRATEGIES FOR SMALL AND MEDIUM SIZED COMPANIES

Brian W. Baetz, Eric I. Pas and P. A. Vesilind(1)

Waste reduction is a primary environmental protection policy in North Carolina. While large corporations have for some years had the experience and financial resources to embark on waste minimization programs, many smaller companies have not undertaken such programs mainly because they are unaware of how to begin, and are too small to hire outside consultants to assist them. Accordingly, a project funded by the Pollution Prevention Program in the Department of Natural Resources and Community Development was initiated to develop a manual which would be directed at small and medium-sized businesses which are interested in developing or expanding their waste reduction programs. Waste reduction is defined and described in the first section of the manual, and the distinction between waste reduction, waste minimization, and waste management is drawn. The benefits of waste reduction are highlighted in the second section of the manual. The primary benefit of pursuing waste reduction is an economic one. Economic benefits are obtained through the reduction of either waste management costs or raw material costs. Other benefits such as energy savings, increased product yield, and improved public relations, are also discussed. A framework for organizing a waste reduction program is presented in section three. An approach for determining the potential significance of waste reduction for small- to medium- sized businesses is suggested, and considerations for a successful program are listed. The components of a waste reduction program are divided into personnel-oriented and process-oriented areas. Personnel-oriented components include education, team building, and motivation and recognition options.

(1) Graduate Student, Associate Professor and Professor, respectively, Department of Civil and Environmental Engineering, Duke University, Durham NC 27706

25.1 It is suggested that increasing waste reduction is analogous to increasing product quality, and the concept of quality circles from the production management area is proposed as a suitable technique to get all plant personnel involved in developing and accomplishing waste reduction goals. Process-oriented components include flow and cost accounting, housekeeping, capital and technology intensive modifications, and research/development opt i ons .

Materials to get an industrial facility started on developing a waste reduction program are included in section four. These materials include information on North Carolina's Pollution Prevention Program and the technical and educational services they offer to industries, listings of local industries who have implemented waste reduction programs, available literature, and a description of waste exchanges and industrial trade associations who could also assist an industry starting out in the waste reduction area.

25.2 Household hazardous waste falls into five basic categories: * pesticides, * autamotive * paints and related products, * household cleaners, and

* the ubiquitous llother,ltthat may include things such as home chemistry kits, pool cleaners, and phannaceuticdls. Citizen pups, particularly the League of women Voters, have become active on the issue of hausehold hazardous waste and have hpn to sponsor household hazardous waste collection prcgrams for three reasons. First, they have cane to realize that there are many tkings in people’s hasin the five categories listed above and that it is wise to get out of the home products which contain hazardous constituents that are explosive, flammable, concosive, and toxic. These prodtucrts create a variety of problems. They are responsible for fires and explosions and fatal poisonings in the home. They threaten the safety of Sanitation workers, who my unknowingly be exposed to their fumes or the possibility of explosions. when these wastes get into the solid waste strearn, they can cause toxic air emissions, containinate graundtwater through landfill leachate, or, in the case of incineration, prcduce toxic ash. If any of these wastes are poured dawn the drain, some can corrode pipes and most will have an impact on septic system or sewage treatment plants. Same people pour waste oil dmstorm drab where it is simply washed into streams and rivers. other people may simply dump oil and other hazardous wastes on the ground in the backyard or in the woods where they can contaminate soil, and if the quantity is significant, g-r”ter. Another reason citizen groups have started establishing household hazardous waste collection programs is that these programs serve to educate the public. Tfiis is an issue that speaks to eveqone. It is an issue that - apwe.rs people, lets them control their own destiny, and it is a very effective tool for educating people on broader waste and environmental topics. A third reason for household hazardous waste prcqams is to encourage a reduction Fn the use of toxic inqredients, to encourage designing-- prducts in such a way that we eliminate problems of envhma hazards.

1 senior ~hvironmental~e~ear~h myst, center for Enviromtal Management, Curtis Hall - Tufts Universitq, 474 Boston Avenue, Medford, MA 02155 (617) 381- 3486

26.1 Wllection Programs Are Growing in "ber, Are of various xinds In 1981, there were two household hazardous waste programs in the country. Since that the there have been mer 850 programs in 42 states-288 collection progra~trs in 1987 alone, and no one has mandated these programs. They have been sponsored by the states--sametimeS with financial help fran ~ regional EFA offices, by counti-, by the Cooperative mionSewice, by regional planning agencies, by dties,by public intereSt groups, even by one chamber of cammerce, and by quite a few industries. The industries have sponsored hausehold hazardous waste collection prqmms for the& workers and for the Carmrmnity as godwill gestures. Ibw Chemical has held them for years in -ties where company facilities are located and has even taken the wastes into its waste management facility and incinerated most of them. The majority of collection prqram are one-day events. Some have been specialized. For instance, h Sections of the Country where there have been a nuniber of farm closings, a great deal of pesticide has been sinply left sitting in the barns, and pesticide collection has been perfomed as a Community service. In other ccanmunities, the focus has been on collecting used mtor oil or used batteries.

Sane of the pmgrams have accepted wastes from small-quantity generators as well as households. These are usually called anmw-day programs because snall-quantiw mialgenerators are given mesty from the hazardous waste transportation regulations for one day so that they can bring their wastes to the collection site. l%ere is a new wave of permanent sites, where household hazardous wastes may be b-t wery weekend or every day of the week. In California, Washington, Massachusetts, New York, Florida, and Michigan, we already have had perrrranent sites establish&. Having penmnent sites helps to reduce costs and provides greater corrvenienCe, and is therefore, we think, the wave of the future.

Some states have laws mandating household hazardous waste collection. Most are simple laws, but s(3me States, such as Florida, have established rather extensive programs, mandating collection programs in every county and the establishment of transfer stations.

Same states have been actively involved in approving plans for collection ~ programs to &e sure that programs are carried out using best management practices. Fed- law-and I believe North Carolina law--says that household hazardous waste is exempt from hazardous waste regulations, but sponsors of hausehold hazardous waste collection programs all handle than as thou& they were regulated hazaxdous wastes, so some states have been involved in plan review and appmval.

Same states are trying to redslce the liability of the sponsor of the programs. Qonso?zs are not liable under Subtitle C of the Resource Conservation and Recovery Act (Rm) or the state Counterpart, but they are

26.2 indeed subject to the provisions of the federal clean-up law-the camprehensive Environmental Response, &”sation, and Liability Act of 1980- which regulates not by the source or the amount but by the particular chd~al. If a chemical is found in a waste site, then the individual or entity who put it there is strictly liable. The idea of being left holding the bag on clean- ~ up costs at a CammerCial hazardous waste facility has been frightenjng to many “unities, so some states have addressed this issue by limiting the liability of collection program sponsors. The state of California, for instance, says that a program sponsor is not liable if it Contributes less than .05 percent of the waste to a commercial facility-if, in other words, it is a de minimus source.

Another major problem for sponsors of household hazardous waste collection programs is dioxin. Herbicides and some wood preservatives contain dioxins, and there are no permanent facilities in the country for dioxins to go to at this point. sponsors of collection programs generally hire a Cammercial hazardous waste disposdl firm to oversee collection and transportation of the wastes. So, in some cases citizens have brought household hazardous wastes containing dioxins to collection programs, the constituents have been identified, and the sponsor of the program has had to tell the citizens to take the wastes back haw. There are facilities that could handle wastes containing dioxin in a way that would meet federal regulations, they are unwilling to take the wastes at this time. This is a problem that we hope the EPA will help c”ities address. Iabeling is another problem: many sponsors of collection programs fed that products are not labeled properly either for their constituents or their disposal. We are beginning to make some progress on labeling. The paint and related products industry is developing a notice to go on their prducts saying something like %ave unused paint for a hazardous waste collection day or contact yaur local or state officials.11

26.3 i- t- t- Allen Q. Maples The Esnrhnmental Protection Agency is particularly interested in what can be done at the camunity level and by the individual hcxneawner to reduce pollution through source reduction. cur figures shm that the average individual produces about one ton of waste per year, and a certain percentage of this is hazardous waste. To arrive at a definition of trhouseholdhazardous waste,Il EPA joined two definitions: "household waste," which is material generated in the hame, and %azardaus waste,t1 which either is defined as a substance listed under the Resmrce -tion and mezyAd. (FCRA) Subtitle c or as a substance which exhibits certain hazardous characteristics-ignitability, corrosivity, reactivity, toxicity. Basically, a household hazardous waste is one generated in the hame which would be considered hazardous if it were generated in a commercial operation. EA'S list of common hazardous household products includes the follmiq: * household cleaners * automotive prodtucts

* lawn and garda products * miscellanems products (photo processing chdcals, batteries and electronic items, persondl care products, pool chemicals) EPA studies have shown that between .35 and 1 percent of all residential waste is hazardous waste. That my seem &l until you consider that larger landfills may receive up to 1,000 tons of waste per day and, in that quantity, the volume of household hazardous waste could be significant.

Last year the agency published studies of the composition of household hazardous waste in min County, California and New Orleans, Louisiana. The data were provided by the garbage project at the University of Arizona, where they a-ly sort and weigh residential trash. The objective of the studies was to characterize the camposition and determine the amount of household hazardous wastes entering landfills. The results of those studies are shown in the acccanpanying charts. In the Marin County study, the largest category was household maintenance followed by batteries and electrical cOmpOnentS, household cleaners, autmtive mai.ntenance, pesticides and yard maintenance, cosmetics, prescription drugs, and other in that order. In the New Orleans study, automotive maintenance was the second largest category, and pesticides and yard maintenance was the srdlest category. We are not sure what factors determine the differences in composition-perhaps socioecondc factors.

Envhnmental Scientist, U.S. Eslvhnmental Pmtection Agency Office of Solid Waste - WH 565, 401M Street, SW, Washington, DC 20460 27.1 EPA is working on formulating a policy on several qyestions that often arise in regard to household hazazdous waste: (1) reccxnmendations for managing hausehold hazardous wastes, (2) options for disposbq of dioxin, and (3) cclmprehensive Ehvhmtal Response, compemation, and Liability A& of 1980 (-) and RQ?A liability. ?he policy will also address the issue of varying state 'ves and how they can be taken into account. Hausehold waste is exapt fram RCRA Subtitle C hazardous waste rules so EPA has htexpreted this to exqt hazardous wastes collected through household hazardous waste collection prcgrams fram Subtitle C. So, legally, these materials can go to a Subtitle D or dcipl landfill, but EPA reccrmmends that collected materials go to a Subtitle C facility because of the greater level of protection. It hardly makes sense to go to the effort and expense to corduct collection days and then put the materials in a municipal landfill. Most camunities which conduct collection days contract with a licensed hazardous waste management firm to collect, package, label, and transport the wastes to Subtitle C facilities, and this is what the EPA reccxrnnends. EPA subscribes to the hierarchy of waste management alternatives alluded to by a nmber of speakers at this conference for the management of household hazardcxls wastes. In this hierarchy, reuse and recycling is the preferred management method, follmed by trabent of what cannot be reused or recycled, and, as a last resort, disposal in the proper landfills of what cannot be taken care of by the first two methods.

EPA regulations req"g' dioxin do not apply to household hazardous wastes containing dioxin. They are exempt fmm EPA's rule banning land dkpsal. of dioxinmntaining substances. ?herefore, waste management firms are legally permitted to take this waste along with other household hazardous wastes to Subtitle C treatment or diw sites. However, because of public perceptions abcplt dioxins, few of the Subtitle C companies have chosen to accept dioxin wastes. EPA does not see any clear options for disposal of dioxin-ntahhg household hazardous wastes at this time. One option may be to encourage the Subtitle C COIllpanies to accept the waste because they have the lllDst exprima and best methods for handling it, but that is not certain. Same camunities have chosen to temporarily store the wastes until a permanent management option has been found. Regarding the question of liability of collection sponsors, RCRA is not a problem because of the exclusion of household hazardous waste from Subtitle C ~ regulations. However, -CIA is different. CERCLA regulates by constituent. EPA will be aamhhg the possibility that dtysponsors of collection prugrams can be ex- fram liability under CERCLA. At this point, it appears that will be possible. Hmever, there is a bright side. Waste collected under a camunity collection program and taken to a Subtitle C dkpsal. facility may be eligible for treatment under the de minimus quantity ~~ prwision, which basically means that the smallest contributor to a waste facility would have to pay the least amount for a Suprfmd cleanup. In conclusion, EPA strongly supports the dty-based household hazardous waste collection programs, not only because they help keep hazardous waste out of sanitary landfills but also because they serve to educate the general public on the subject of hazardous waste. Once people participate in a collection program they begin to understand that they, too, are generators of

27.2 hazardous waste, and they may begin to understand the need for hazardous waste treatment and disposal facilities. This does not mean that EPA is pmmoting the siting of hazardous waste facilities. We strorgly support waste reauction practices as the first and major step in waste nranagement, but we believe the American public needs to be ectucated about the entire spectrum of necessary waste Inanagenmt methods.

27.3

There are a number of issues that sponsors of household hazardous waste collection programs should consider before embarking on the project. There are, as far as I haw, no standard contracts in use by canmenial firms for handlhg and disposing of collected household hazarfious waste. There is, hmever, a set of a"on considerations that sponson and contractors should address advance of the the that you invite people to bring their waste material to a collection site. I will list some of these issues and talk about the options that have been used across the country. GSX has worked with sponsors of about 200 collection programs, and each program has been different.

Decide Who Will Be the Generator

One question that arises is who is going to be considered the generator of the waste. Even thou@ these household wastes collected through camunity programs are leplly exempt from the Resource Consemation and Recovery Act (RCRA) Subtitle C regulations, EPA does encourage collection program sponsors to handle them as hazardous waste. Therefore, it is necessary to designate a generator. ?hat can be a contracted or negotiated issue. In some cases the sponsor may choose to sign the manifest as the generator. In other cases the sponsor may prefer that the contractor be the generator simply because the contractor bows hcw to file all the paperwork that must accmpny the waste. In uther cases, there may be a third ---for example, a state or local mbmnental agency-that agrees to be the generator and to keep track of all the paperwork.

Make Sure You Have Insurance Caverage

who will be the generator is not as great a concern as it was a few years ago because we're not as concerned about the RCRA liability. Comprehensive Envbmnental Response, Compensation, and Liability Act of 1980 (CERCLA, or suplJ.fund) liability, while still there, is not a major obstacle because of the di ~~ provision. Hcwever, everyone involved in a collection program Tlillst still be concemed about third party liability. Slips and trips and falls, autcanobile accidents-basic liability issues-are still a concern. To date there have been no suits of any kinds against a sponsor or participant of a household hazardous waste collection program, but given the litigious inclination of our society, general liability cannot be ignored. The sponsors should check their liability coverage. Many dcipdlities have general liability coverage for special events. The owner of the prom, if it is private property, where the collection site will be located should check coverage. If the property owner is not mered, he may be able to get a special one-day event rider or he my be able to be covered by the contractor's insurance. At one the it was impossible to become an I1additional insuredll on a contractor's liability insurance, but today it can occasionally be done. It is not done easily, but it is a possibility.

GSX Chemical Services, 121 Executive Center Dr., Congaree Bldg., Colmbia, SC 29210

28.1 ?here are sane ways in which you can minimize your potential liability and pmtezt yourself in the event of a suit. BY planning carefully and using great caution, you my be able to avoid conditions that might contribute to accidents. You can reduce the possibility of accidents by minimizing out-of- car traffic at the colletion site and limiting access to the site. Of course, you need to corduct very thomu& trainhg of site personnel, including ~ volunteers. If you have Boy scouts direzting traffic, they need to lcnaJ contingency plans for any problems. It is always a good idea to let the police and 3fes

Unlaxlwns ccxnp~~ethe laryest problem that you my run into. For instanCe, saneone brings in a jar which has no label on it. The substance hide is green. Haw are you going to handle it? You need to advise people that to the extent possible they should identify their wastes, and you should have decided what your policy on un3inaJns is.

Dioxins present a unique problem. By permit, most carmnerical hazardous waste management firms are unable to accept dioxins if they are classified as hazardous waste. Since wastes collected through c"mity programs do not have to be treated as hazardous wastes, Commerical fhcould take dioxin-bearing household hazardous wastes fram cormurdity programs. However, if a fhmakes an exception and takes dioxin fram a c"uniQ collection program, it appears to the public that we are slithering through a loophole or that we are not playing the whole game. Dioxin which is classified as a hazardous waste is chemically identical to dioxin that is not classified as a hazardous waste. The only differen- is legal. So, most Cammercial hazardous waste firms decline to accept any dioxins. Knowing that there are a number of substances and materials that will present Serious problems for your collection prqram, you should make strong efforts to infonn the public that you prefer not accept these materials. Then you should be prepared to deal with them anyway. Plan for contingencies by alerting the local bcrmb squad, police, and the Dmge mforcement Administration, and if possible make special arrangements with your contractor, who may be able to handle some of these materials for an additional fee. Providing for on-site testing of unknowns is also a good idea. And, you should ~ designate the person who will be responsible fortelling people when you cannot accept their wastes, and you should be able to offer same suggestion about what they can do with it. Sponsors of household hazardous waste collection programs

28.2 will encounter serious problems, but these problems can all be handled if they are planned for in advance. Be Familiar With Waste Management Gptions and Their Costs

waste maMgement options are another issue. You are not going to be dealing with one hazardous waste facility unless you deal with a transfer facility. %en you deal with a bmd variety of wastes there is no one single waste management option that will take care of everything. YOU cannot recycle every single ounce of what you collect. Neither can you hchezate evesything. You can designate preferences, and costs will vary based on your management selections. One possiblity is to pack for your favorite choice and leave managanat options open if it is rejected. An0the.r possibility is base maMgement option selection on budget considerations.

Understand Budget Items and Pravide Adequate Funding Labor will be the most expensive item on your budget after actual dispsal. Your contractor can provide turnkey services or can provide minimal services that can be augmented by local staff or volunteers. A certain nunher of local staff people will be essential, but you have a choice abut the extent to which you will use local manpower. ~0”uru‘ty volunteers are wonderful at aireding traffic and at filling ogt questionnaizes and getting information from program participants, but you don’t necessarily want to use *&em as chemists to ask questions about unknm or to handle explosives. If your CCBlllINnity has a hazardous waste response team, ma* you could get these people to help in areas where you would not want to use regular volunteers. Take advantage of whatever resources you have available and then make a decision about what roles you wE?t everyone to play.

If you get hto using a diverse group of people, you will have to do a great deal more planning to meld the group hto a smoothly running team, and you will need a manpwer coordinator whose sole responsibility is unifying this team. men, you will need to find saneone to axduct a training program. Fl-e.quently this will be your mntractor. It does “ize your liability to have a good training program. No one has an unlimited budget to conduct a collection program, so being aware of waste management firms’ pricing structures is important. There are a couple of possibilities to consider. Fixed versus unit prices is one. The rate of participation in your program will detexmine which will ke more advantageous for you, but prdicting participation is difficult. If you ask for Unit pricing so that you haw how much per item you will pay, then you must consider the nature of the unit. If you choose incineration, then the unit will be a 20-gallon drum or something similar. If you choose recycling, the unit will be different. SO find out what units are available so you compare apples to apples. Instead of cost per container of waste, you my be quoted %et-uptl fees, in which you pay so much to have a certain number of people and a specific kind of transportation for a certain nunher of hours. There are a nmbr of financial arrangements under which collection programs can be conducted. But, you should how that the largest cause of participant ill-will at collection programs is closing collection sites early because a higher-than-anticipate2 participation rate has prduced all the waste that can be handled with money allocated. Inadequate funding of a collection program can jeopardize future programs if you have to send people back hcnne with their wastes. You should consider what you will do if your participation rate produces more waste than you have money to handle. You may be able to store the waste and wait until you have more money. Or you may be able to get an emergency appropriation from your lagover"t. But if you plan for this possibility and knm what you will do in case of higher-than-anticipated participation, you can minimize the confusion and friction.

provide for site safety Site safety must be one of your major concerns. In every public event, yau will have a certain amount of confusion, but if you do a contingency plan for emeqencies or unexpckd situations you can "ize confusion. You need to de-e what conditions would cause you to consider evacuating the site. and what signal you will use if you need to evacuate the site. You my have a worker emergency, in fich someone is injured, or a material emeryenq, in which a potential contaminant has been released. How will you handle those emergencies? You also need to think about hm are you going to deal with the media and what will the media have access to. A collection program presents sane wonderful phato opprtuniies, but there has to be a point beyond which you allow no access without protective clothing. You need to have all emergency phone numbers posted throughout the site and air horns or similar devices to be used for an evacuation signal.

Plan for Follcrw Up If you do all this preplannhq, then you are ready to hire a contractor. You Will find several Campanies that are willing to work with you on collection p-, and you should use the same criteria for selecting a hazardous waste nxmagenent contractor that you would use in selecting any other contractor. Reputation, experience, and insurance coverage are certainly factors. As with any other kind of municipal contracting you may want to ask for performance bond. Even after the event you will be concerned with the company's perfomce until you are sure that all the waste has been properly disposed of. You have a couple of options for assuring performance past the cleanup day, such as withholding part of the payment. You will need to provide follow up to the collection day. In spite of all your efforts to infonn the public, you will receive same calls from people who want to get rid of their wastes but missed the collection day. One tool we have found very useful is to have two collection days about two weeks apart. ~ Ihe first is a primry program that is very well publicized, and the second is a follow-up program that may not get as much attention but may brbg in a significant amount of waste.

28.4 A. 13d.kcd1, Jdrn E, Ehrshing2 arrl €&Yy E, d

Rxb5.q -wash= load frcm a dairy ard ice e" plant The waste load frum a dairy processing plant is largely a result of milk pnxtucts which are intentionally or inadvertently lost to the sewer system. Resear&- have estimated that over 90 percent of the waste load is fm lost milk and milk products. The reductLon of water use and p-ct waste requires the application of the best "agelent practices and technology. The typical dairy plant uses approximately 3 gallons of water for each gallon of milk prccess&. The waste concentrztion frum a typical daiq with ice cream production usually exceeds 3,000 q/l.

There are two pmen ways to redtuce water use, wastewater discharge, waste load and product loss. One method is to operate the plant more efficiently. ?he other is to institute prczess changes.

?he costs related to water and sewage discharge, including surcharges, can be significant to arry dairy plant. This factor, combined with increased effluent constmints placed on dairy plants over the last sevm years, led Maola Milk and Ice Czream Ccrmpany to seekmethods to reduce its discharge volume and load.

Maola Milk and Ice Cmpany is a rdtiprduct dairy locate3 in New Bern, NC, on the banks of the New River. The plant discharges its waste to the City of New Bern municipal treatment system. Maola has always tried to be an exemplary corporate citizen. lhmgement recognized that reducing waste load fram the dairy plant would not only reduce current and future dairy pmcssing mds; it wmld al;o help the city by reducing load, reducing treahent costs and allowing exparsion needed to accommOdate new citizens and businesses.

An initial sulvey of the plant identified sounes of milk solids losses frum production processes. Methods to reduce or to recover and reuse the milk solids lost frum the qstem were sugyested as an alternative to trebent processes. costs and payback period for such changes relating to pollution prevention needed evaluation so a challenge Grant was initiated with the NC pollution mevention pays program to study this. With management fully ccamnitted to action, a resear& team was fonned with plant management aril NcmJ food scientists from the North Carolina Agricultural

1m. R.A. mid,piant mga, %ala M~UCand I- cream campany, m., P.O. Drawer "S", New Bern, NC 28560.

2~.~zushing and cara~an,mion specialists, FOO~science Department, North Carolina State University, 13ox 7624, Raleigh, NC 27695-7624.

29.1 Extension Service. Fundiq for the study was provided by the NC Follution Revention Pays Program and the NC Dairy Foundation. The team selected the follawing format for the study:

1. Drawings of product lines and equi-t were reviewed and updated. 2. A wey of all plant processes and operations was corducted under the leadership of the plant manager to ascertain practices which allowed product to escape to the floors or drains. 3. Saurces of cbviuus waste were identified and eliminated to the extent possible. 4. ?he literature was -eyed for ham recovery methods. 5. Other dairy plants and equipment manufacturers were contact& for ideas and suggestions. 6. Key employees were interviewed at their work stations and in a workshop to generate ideas. 7. The team reviewed the sources of waste and product losses. In situations where the source could not be eliminated, the feasibility of reccNerywas assessed. 8. With management carrrmitrnent, a plan for waste prevention and recovery of losses was instituted.

!Ihe survey alme can field fpsuzts Management eqhasis during the survey led to an increases awareness of p-ct loss among enphyees. when the plant manager was okemed measuring losse~, recording results and discuss ing alternatives with other employees, avoidable losses decreased rapidly. Milk plant losses in September of 1986 were estixnated at 250,000 Ibs. Lc6ses steadily decreased monthly until DecE?mber losses were recorded at only 86,309 Ibs. (Table 1). ?he resulting savings in dollars was about $24,000 per month. The 170,000 lbs. of milk saved resulted in a decrease of 17,000 Ibs. of BOD. The dCation of management cmmiment yielded impressive results. During 1987, the obsewed reduction was continued with monthly mi& loss not excedmg' 100,000 pounds per month. Table 1. Milk Plant Iisses

September 250 ,OOOa

October 172 ,688

Nwaber 126,798

DecEnber 86,309

=Estimated

29.2 Waste-related process changes and prccess alternatives to decrease the B3D load were evaluated collectively and individually. The changes studied utilized product-water recovery for use either as a raw material in ice cream mix or as an animal food. me study utilized initial plans and cost information developed by Seiberling Associates for the plant. These long range plans included process modernization and were ccgnbined with planned immediate projects for product recovery by M.G. Newell, Inc.

The changes did not include all the waste prevention changes that a dairy could make, but were selected for Maola. For reuse, recavered product must be micsrabiologically and chemically safe. Also, it must be legal for use as raw mterial. Tests are necessary to confirm the chemical and microbial safety of these materials just as for any ingredient or for the raw milk sup$y.

Waste-related alternatives evaluated include:

1. a collection tank for prcducts or prcduct-water mixtures 2. a system to -er the HIS" starkrp and changewers from both pasteurizers which are prcduct-water mixhrres 3. a system to aid in the recovery of frozen ice cream 4. a system to aid the fluid milk filler operator in dbpsing of the milk products from the filler bowls and frum damaged or underfilled cartons 5. systems to recaver initial potable water rinses for the pasteurized pmC3uc.t lines, tanks ard CIP system 6. collection tanks and system(s) to aid in the use or dispsal of the milk- water mixtures from changeavers and start-ups 7. a sealed dumpskr for solid waste 8. elimination of water chases between prcducts on the KIST'S 9. a loss prevention program for the plant several of the alternatives were selected due to their ease of implementation and their cost effectiveness. hose impknented changes and their projected annual EDD5 recuveries are OUUMin Table 2. Several of the changes involved the high-tmperature-short-time (KIST) pasteurizing system which was found to be a major contributor to product loss and waste load. The raw and pasteurized cleaning-in-place (m)systems were found to be the next largest contributor to the waste load. In all, the alternatives selected were predicted to reduce waste load at Maola by 320,000 pounds of biochemical oxygen per y-0

29.3 Table 2. projected Dairy Product Recovery and Annual FKI% Recovery

mily Recovered Annual mct mct mD5 Recovery Description Recwery

(-/daY)

Milk Plant mss program 5 ,000 milk 130,000

ICe Csream Flush 900 ice creaxq/water 45,000

Elimination of Selected HIST Pmductflater Chases 4 ,000 milk/mter 55,000 sealed Ixmrpster 400 milk 11 ,000

1,300 17 ,000

CIpRinseRecQvery (Raw) 2 ,400 19, 000

CIP Rinse Recovexy (Past.) 2,400 19, 000

Carton Recovery 860 23,000

~~ ~

mtal 320,000

Material and installation costs for the changes were estimted at about $54,000. Annual hcreas& costs due to operating and xraintenance were estimated to be $35,000. For this bvesbnent, savings of $302,050 were considered possible. Kmagmt is planning new piping and valving, new tanks

and autcrrnation which will allm greater recovery and waste load reduction but ~ these changes will not be as cost effective.

Ihe results of the project tell the tale! changes suggested in the study are being implemented as quickly as possible. By October of 1987, all of the changes in Table 2 were installed except for Carton Recovery. me municipal treatment works which receives the waste discharge frnm Maola reported llprofoundtl results. Influent data to the city's plant shmd a 14.7 percent reduction in EOD5 per day and 22.8 percent decrease in suspended solids (Table 3). While all of this was probably not attributable to the Maola prcgram, city officials were quick to recognize Maola's efforts.

29.4 Table 3. Influent Solids Reduction to City of New Bern Waste Treatment Plant

suspended ED& Load Solids Load

(uss/daY)

Aug. 1 to Sept. 18, 1987 4006 3224

Sept. 21 t0 Oct 16, 1987 3418 2487

REduction 588 737

Pscment reduction 14.7 22.8

Savings to the plant include materials that can be reclaimed and reused as well as that naterial which can be diverted to animal feed ..(Table 4). Annual savings h value of product alone is abaut $60,000 with rmnunal invmt. Other savings such as averhead costs, lost sales, surcharge, and other items would im=reaSe this value. These savings are addition to the $288,000 being saved annually from prcduct loss prevention resulting fmn the management and employee awareness, education and action program. Manag-t is predicting tom savings during 1988 in excess of $350,000. TOWsavings with all possible alternatives fully implemented should exceed $500,000 mually.

An effedive program to reduce lcsses and waste requires mgement awareness, employee education and a ccnranitment to necessary action. other dairy processing plants can benefit from this infomation and should be able to profit similarly. Pollution prevention does pay for dairy processors. Mamgemnt changes and pm3uc-t recovery are effective pretreatment processes for dairy processing plants.

29.5 Table 4. Material Diverted from the Waste Stream Annually

Recwered miry Material wltterfat Solids

1.4 8.0 13 ,148 61,981 18 ,802 23 ,555 other Reusable Material 3.5 12.5 (Presently Diverted to 8 ,644 22 ,136 Feed; Value Sham 12 ,361 8,412 for Reuse)

Ice cream Plant 8 32 (Recovered and Reused 9,360 28,080 Material) 13,385 $ 10,670

Unreusable waste 0.5 4.0 (Animal Fa) 4,025 28 ,174 0 0

Bullard, R.A., Camwan, R.E., and Rushing, J.E. 1986. Reduction in Waste Lcad From a DEI- and Ice Cream Plant. NC Pollution Prevention Pays Program. 76pgs.

Carawani R.E., Rushing, J.E., and Willard, R.A. 1987. Detailed Plans for the Reauction in Waste Lmd from a Dab and Ice Cream Plant: NC pollution Prevention Pays m-ogram. 33 pgs.

The activities described in this paper were enhanced through two Challenge Grants from the North Carolina Pollution Prevention Program.

29.6 Many food processors tcday are literally washkg their profits dmthe drain. The Equity Group of Reidsville was one such campany...until they teamed with food scientists fram the NC Agricultural Extension Service and the NC Pollution Prevmtion Pays Program to reduce their costly plant waste and help the City of Reidsville get publicly "d treatment works (m)back into cmpliance.

Water is essential for the food industsy. It my be a key ingredient as well as a means to clean the product and the plant's equipwnt. 'Ifiis clean-up with water also flushes loose flesh, blood, soluble protein, inorganic particles and other food waste to the sewer. ?his organic load rises in proportion to its amount and adds a high level of biochemical oxyyen demand (BOD5). Sewer plants add sunharyes per pound of EOD5 mer set limits, which can run into hundreds of thousands of dollars for the ampany ea& year.

The Equity Group CO. facility was built in 1980 and is a division of Keystone Foods. Each day, the Reidsville facility produces arourd 2.5 million chicken nuggets for the southeastern McDonald's stores. The plant uses almost 200,000 gallons of water per day (Table 1). The capany qloyees 275 people in two product=ion shifts and one cleanup shift and operates five to six days a week. When the problem of waste mamgement was first approa&ed, ED& level was around 4,500 pounds per day. The Equity Group meat plant is required to f0ll~very high standards. These high standards reflect on high water wage to mintain the quality demanded. Recently, the U.S. Department of Agriculture (USIc1TI) required the pmduction lines to be free of any meat accumulation at dl times wfiile in operation. H0sh-g the eqdpwnt three times per shift accmplished this reqUirement. Consequently, water use and the organic load tenfold. Fkpity, hawever, has never operated under a strict organic load reauction program. Thus, withcut restraints, several pounds of organic mterial were being flushed to the sewer and directed to the pretrea-t plant. An average of 55 pounds of meat, three pounds of tempUra and 15 pounds of dxy batter per line per shift were being lost to the sewer.

'James B. Waynick, Director of Personnel, Equity Group, P.O. Box 1436, Reidsville, NC 27320.

2-y E. caram, FOO~science Department, NO^ ~uplinastate university, BOX 7624, Raleigh, NC 27695-7624.

3Fred R. Tamer, Jr., Food Science Department, North Carolina State University, Box 7624, Raleicjh, NC 27695-7624.

30.1 Table 1. Equity, Reidsville Facility

* Allncst 200,000 gal/wat€T per day * Load 4,500 Ibs/day

one shift Cleanup

* 2,500,000 McNuggets/day

'lhe City of Reidsville ran into problems with their sewage treah-mt plant in 1987 when it was fined by the state for polluting Little Troublesame Creek and it was pointed out that the city hadn't consistently met state discharge standards for sewage tr&"t plants sh1985, Equity was notifid that the city's.System was incapable of processing their pretreated effluent (waste). 'lhe city also set a B3Dg limit on this effluent and levied heavy surcharges for levels aver the set limit. Equity appointed an in-house task force to -lore ways of reducing the plantts waste and effective managemmt of its water use,

Waskwater parameters the Esuity GLWUP concerned themselves with are BO&, the p~ (acidity) level, TSS (total suspended solids) and (fats, oils and grease). E" the four categories, waste in the form of batter, tempura, breading mix, chi- shreds, juice (soluble protein), blood and fat, nugyet pieces, patty pieces, and cooking fat were being flushed down the drains costing the cxnrpany in raw mterial loss, water use, and sewage surcharges and causing a problem for the city of Reidsville since their treatrrient plant could ~ not handle the amount of waste.

JhWaynkk was designatd to head the Equity Task Torte for waste reduction. me cormnittee contacted Dr. Roy camwan and Dr. Fred Tamer of the Department of Food Science Extension at N.C. State University who, in turn, &led in the pollution Prevention Pays mPgram of the NC Department of Natural. Resources andcBTl"'ty Developent. Waynick commented, 'We thought we had a problem but we didn't realize what an opportunity we had until Roy (Qrawan) and Fred (Tamer) shmed us!"

30.2 The Fquity Group applied for and received a Udlenge Grant fram the NC FollUtion Wention Pays mPgram for use in developing their water and waste reduction progranr;. mese grants are awarded to businesses and axmiunities to assist in the development of waste -&ion programs. ?he concept of NC Pollution Prevention pays (PPP) Program, administrator of the grant, is +a attack pollution at its souz13e. PPP councils the prevention of pollution/ waste at the outset instead of worrying with what to do with it once it's created. Waynick, DirecrtOr of Personnel for the cmpany, helped a"te the cc~npany's efforts to reduce waste and noted that, plpersonneL mgers really don't have a lot of training in waste As the work has proceeded, this lack of Jmmledge has actually becane an asset as Waynick and the others were not aware why changes h attitude and technology would not work. Also, his maMgement exprience in the "people businesst1 helped him un3ersm-d hm to affect attitudes and enct changes that employees und- and follmed. The Equity Group's task force met with Pollution Prevention Pays representatives, -wan and Tarver, and Reidsville city officials for an analytical session on the problems the cu"y and the city faced and possible solutions.

Nuggets are formed fram the highest Wity chicken breast and thigh meat. The process is shm diagmmtically in Figure 1. chicken meat is ground, blended, formed, battered, bread&, battered (lknp.ra), fried, frozen and then Padkaged. steps taken to Equity's problem by the task force and specialists are list& in Table 2 and include: (1) Education on water use and waste load, (2) Study, (3) procesS evaluation, (4) Dry Cleanup, (5) Residual recovery and Utilization and (6) Pretreatment enhancement.

Mucatian is first and foremst The mast critical step was the education of the plantls managers and employees. Few realized the ir~~~~rtanceof waste and water control and the staggering rnrmbers, in weight and dollars per day, that accOmpany the careless approach to waste management and use of water.

30.3 FIGURE 1. NUGGET LINE --(BLENDER) '--+ Breader

Batter + PACKAGING

~~ FIGURE 2. WASTE FLOWCHART

SOLIDS PLANT

I PRETREATMENT

PH Control

ToP Reidsville POTW

30.4 * Managment~loyeeIBucation * Water Useflaste Lcad Studies * Proce~~Evaluation/Recarmnendations

*Drycleanup * Residual. Rewvery/&a"btiow * m-mt Ehhancement

Enploy= are sensitive to a manager's priorities. If the "agemat shows lack of concern and ca"t to the reduction of water use and waste pmduction, the errrployees will have little incentive to care as well. mp managemmt must shm a genuine caring and cmmimt to finding a solution to the problem. Without mnagemmt's cooperation and interest, the waste, excess water and the cc8npany's profits will continue to go dmthe drain. Also, with this lack of concern, canes the potential for a poor public image for the ccnnparry. The public today is highly ttpollution-zonsciousll and if a cc~npany does not shm equal consciousness, it may find itself with a bad public relations and image problem. This was one problem Equity did not have. Its mamgers were all concerned and ready to try any avenue offered to solve the plant's problerrrs. When the reports of areas of waste proctuCtion and heavy water use were in, Jerry Gotro, Equity's vice president, said, ltlisis not a slap on the hand. No one is to be ashamed of what the reprt states. ~n the other hand, everyone will I?& . to be 150 pen=ent dedicated and involved in the ultbte solution...( it's time to) roll up our sleeves and get it done." ?hen Mr. Goblisted mnagment considerations as employee trainhg and awareness, the design, maintenance and operation of equipment efficiently, careful production practices and dry c1wnl.p.

survey- ~iesclean-upasanqpcartrrru'ty A waste and water survey determined where water use occurred and where wastes were generated in the process. The survey shuwed mer half the waste load could occur during cleanup. ?he Challenge Grant was used in part to develop a training program for the clvcrew. specialists from laboratories were called in to andlyze the process and rrake recammendations. Though no final results are available yet, the Equity Group has made significant strides in reducing its waste prcduction and water use (Table 3).

30.5 Table 3. Initial Results

MeasUre Before NOW Goal water- (sdl) 4,250,000 3,000,000 2,000,000 waste Loads mD5 (WdaY) 4,500 1,000 500

Landfill Disposal (tons/wk) 30 0 0 (Scrap, Inedible Rxduct)

Admil Fod Collection (tons/wk) 0 50 30

Dry Cleanup Pollution Prevented (lbs XIDdday) 0 2,200 2,500

W~=w?isplrsued Dry cleanup is where much of the waste was previously produced. NOW, instead of usiq water to flush the floors and letting prcduct mterial such as batter, breading, cooking oil, breading mix and chicken shreds go dawn the drain to the pretreamt plant to be dealt with there, collection systems for drips and disposals of batters have been installed. Most of the effluent that comes out of the plant is carbohydrate and protein- based. With dry cleanup, a good deal of the waste is reclaimed and put to secondary use. part of the llwastettcollected during dry cleanup is shipped to an Atlanta-based company to use for animal food; currently, they are picking up this material at a rate of over 5,000,000 pounds per year. ?he rest is picked up by a renderer for their use. Other ideas considered are presented in Table 4.

Some of Quityls problems identified by the task force and its specialists were insufficient equiprent for waste collection, no collection equipment for waste under certain processes, leaks in ma&q, worn-out equipment and

30.6 Table 4. Fossible Utilizatioq/Dkpsal of Food Plant Residues

1. Dkect Uses Pet Food

3. Install or Utilize mineration

4. send to Landfill 5. contact Recovers a. Renderers b. Grainproduct

lines, employees' ignorance of the importance of water conservation and waste reduction, hosing most waste dawn the drain without attempting to pick it up and dispose of it in a Irdrylf manner, leaving equipnmt to be cleaned up by next shift. Renarks about the plant's problems were: "only raising employee consciousness a well-planned traMng program, adequate equipment treatment and the "hction of the right in-plant utensils may reduce significarrtly waste BOD5 levels."

A plant survey was ordered. The equipment losses and causes for organic loss to the sewer were d"xked. It was concluded that: (1) the &pent used to pmdue the nuggets rendered heavy losses in the plunger area, the batterer, tempUra contahers and mixers; (2) the conbiment trays and devices were insufficient, required mintenance and needed redesigning; (3) the employees, although conscious of the problem, were not properly trained to tackle it; (4) there exists a huge coxmudcation gap among ccnrrparry direCTt0=; (5) the sanitation procedures needed to be revid and; (6) an anixldl feed prcducer will buy part of the inedible. mpcedures given to E9uity's task force by Esctension and lab specialists included hnpmement of "ication between direct0rs and between manage-rent and employees; presentation of specific areas of plant losses (where breading is spilled, etc. ) ; specific equipment that needed repairs or replacement; specific recammendations for additional eqUiPment such as trays under breaders to catch spillage: hiriq employees specifically to supenrise floor/equip"t waste pickup and separation solid/liquid/breading for both the first and second shifts; training and educating all employees, but especially those in cleanup as to the seriousness of the situation and the proper pmfor efficient cleaning; production of a videotape for trah5-g pvrposes; emphasis of water usage to all employees and mnagen-ent to "ize its use; encourage any and all input on employees' ideas for water use and waste rettuction.

30.7 ?he sanitation aspect was hitially addressed. Praricrus to hos-, sanitation elnplqyees in both shifts are being direcrted to collect all possible meat residue, as well as dry batter. Nonetheless, 27 percent remains uncolleded, and it is flushed during hasing. lis is true for both breaks, 15-minb ard lunch. Steps are behq taken to correct this situation; hawever, furthex action reqires USD& appruval.

______?frird shift sanitation employees use an avexage of 75,000 gallons of water. ?he water is used to both sanitize ard to push scattered organic material to the sewer. Placing mats on the drains during the second to third shift transition period may be a viable solution an3 is being considered. Tbmqhat this period, much organic waste is flushed to the sewer. me water/organic load mixftrre would be vacuumed with special a-t. me collected waste may be mixed with that sold to the animal feed renderer.

A concept as s-le as %eqing the stuff off the floors an;l cut of the drains" will save W annpany many thousands of dollars per year and reduce the strain on its city's sewage treabnent plant. Most of the implementations to reztuce water use and waste cost the cumpany little or nothing. carelessness, a costly trait for any business, wds simply prevented by qloyee awareness ard management aphasis on the problem. "on sense appma&es to cleanup such as trays beneath machines to cat& spillage, picSring up spillage before hosing down the floors ard screens wer drains were used at little cost. Consciousness of the seriousness of the problem connected with reckless water use cost the ampany nothing but time for enployeesl education. One of the lines has been designated as an exemplary line. Main- will -de the equipmt parts, seal all leaks, tighten nuts and bolts, and the Proper antahnent trays will replace the existing ones. A .study of the hpct this my have on waste reduction will yield informtion applicable thruugh the rest of the plant.

Esuity had pretreamt facilities as sham in Figure 2 before the arrent pmblexrrs surfad. A grease trap, solids recovery basin and an activated sludge with pmvisions for control were in place. The activated system p~ - sl-e system lacked sophistication and its operation had been minircral in the past. ?he initial results indicated that production and cleanup changes are the most effeive and econcnnical form of pretreatmmt. Nevertheless, as part of the total approach, engineers and Keystone F& corporate engineers are studying enhancements in the current system. A pilot ~- dissolved air flotation system is being run with sane sporatic, but promising, results.

The Equity Group has shown that it is possible to obtain rductions in their ~ Bo& level by over 50 percent in dry cleanup alone. Overall, the carpany expects up to a 75 percent reduction in their waste load. Such a reduction in waste load and water use will reduce water, sewer and surcharge costs and may eliminate the need for a costly pretreahmt system.

30.8 The savings will be mostly due to the reduction of such mjor capital experditures as the sewage flurharges, water use and pretreamt system, as well as reclaiming IIlDst of the residual waste and recycling it. Since the waste is nat generated as pollutants to water but reclainred, less pretmhnent is necessary, mcbqcosts in this high- area as well.

The Equity GrcRlp cb. showed not only good social consciausness in worm to mcethe waste they were sending to Reidsville's sewage treainat plant, ht good business sense in &Cing wa* costs, waste removdl COSI and finciing creative ways to use their residual waste for their "pry's ard socieQ's benefit.

Jim Waynick concludes, We have just begun to fight. We must date ourselves into a different way of thinking1' which canes frum his prioritized list of what has mrked for him (Table 5). Table 5. prioritized List for Waste control

Priority change Required

Management Attitude is the Key ltlBhk Wildtt - Look at All Ideas Listen to Everyone - the wloyees May WdyHave a Solution Look for Help frum Associations, Friends, Agencies

Identify Your problem, Note the Problem Areas Rrployee Attitudes Are wrtant - !they Mirst Understand that Without Success the -t Truck May Come and the Plant will be closed. 7 Note that Water, Water Everywhere is not the Way of Busbess Anymore 8 contain Wet Wastes

9 control Dry Waste

10 Do not Look at Just the costs, Look at the Savings. Begin a New Way of Life

?he authors appreciate the qprt of North Carolina Pollution Prevention Pays Prcgram and their challenge Grant Program which supprkd these activities.

30.9

Wastewater effluent streams frum poultry plants usually contain an average Chemical Oxygen Demand (COD) and Total Solids (23) load of 1,000 and 900 parts per million (ppm) respectively. Effluent wastes can range frum a high of 4,000 p~pnCOD and 3,000 pp TS in the giblet chiller to a low of 250 pp (COD, TS) in the whole bird washer. A study was corducki to identify effective anl econcanical water treabnmts inchdhg disinfection processes that fulfill the US. Deparbmt of Agriculture's (USM) criteria for recycling broiler chiller overflaw water (Table 1). reov over, other process waters including giblet chiller water and whole bird rinse waters were similzrly treatd to explore the feasibility of reconditioning these paultry process waters. Reconditioned chiller waters meeting the USDA criteria were LEXXIto chill hot broiler carcasses. The quality of the chilled carcasses ms subqyently evaluated. Usm recycling regulations require a minimum 60 percent reduction of dl1 microorganisms including coliforms, Esherichia coli, and salmonella. ?hese same regulations also call for a "rm percent light transrmss' ion (T) in treated water of at least 60 percent at 500 nm. The "rm recycle rate is 1.75 gallons of recycled chiller water to 1.0 gallon of fresh water. This rate derreases to a ratio of 1.10 gallons of reconditioned watecl.0 gallon of fresh water as the quality of the reconditioned water imprwes. Several water treat~~~tswere test& on broiler prechiller overflow water including direct ozonation, a ambination of Screening, ozonation and rapid sand filtration, a "bination of saeenhg, diat"s earth (DE) filtration and ozonation and a cabination of ' and DE filtration us- either a 3.14 in2 malton filter) or 1.0 ft- leaf filter. The quality of overflaw preckiller water was significantly hpmed with all treabrents examined , surpassing the USDA recyclLtq requirements in nearly all trials. Mcst methods intpruv&i the water quality beyod atwould be needed to recycle at the 1.1 gallons of reconttitioned water to replace 1.0 gallon of fresh wa* recycle rate. ozonation alone significantly imprmrea the quality of the chiller water which met all requirements for recycling within 10 minutes of treatment (Table 2). Ten minutes of ozonation reduced the U3D by 48 percent, TS by 19 percent ard fats/oil/grease (FCG) by 76 percent. Bacterial reductions of 3.43 logs or 99.96% for the aerobic microflora were seen after 10 "tes of ozonation in addition to the complete elimination of coliforxls and E. coli. Both filtration treatments, sand and DE, impruved the water quality beyond federdL recycling rqdmwnts. By far, the method arrployiq saeenhg, DE filtration and ozonation rated superior to the other treabsnts. Five minutes of filtration through a Hayward Mlex DE filter follmed by 15 minutes of ozonation resulted in an average percent t"IS' ion (500 nm) of 97. This methcd also reduced COD by 87 percent, TS by 65 percent and FOG by

1. Associate Professors of Food Science, IXprtnmt of Food Science, North Carolina State University, Box 7624, Raleigh, NC 27695-7624.

31.1 94 percent (Table 3). Tatal mirrabial loads were reduce3 by mre than 3 decimal reductions (99.9%) with no detectable wliforms or SdLmonella isolated following disinfection. me findings of this study substantiate those of Lillard (1978) who fdsimilar rettuctions in the organic loads of chiller water after passage thraugfi a vertical tank pressure leaf filter and pcrstchlorination . Passage of overflow chiller water thruugh a screen and DE pressure lea€ filter (3.14 in2, Walton filter) resulted in significant zeduckions in COD and aembic plate counts (E)of 70.9 percent and 90-96 percent, respectively (Table 4). Tght transruss’ ion or clarity of the filtered water impmvea dramtically reaching a high of 97.9 pen=ent. % treated water adqualify for recycling at a rate of 1.25 gallons of recondl‘tioned water for every gallon of fresh water. Similar firdings bere obtamed withseveral grades of DE using the one square foot pressure leaf filter (%le 5). Significant reductions in COD, Apc, colifom and E. coli. of 60.6, 95.8, 98.4 and 90.5 percent respectively, were ckbined after t”t. fight transmission averaged 95.6 percent following the recorditioning treabnmt. In addition to treating whole carcass overflow water, the efficacy of smxmhg, DE filtration (perflex DE filter) and ozonation on reconditioning whole binl rinse and neck chiller waters was explored. The quality of these two process waters was significantly impruved by passage thruugh this water treatment. Both treated waters satisfied the chiller water recycling Wtsnot to rention the ptential for significant reductions in wastewater pollutants aischarqea to wastewater treabvmt facilities. TI-&, steady thus provides evidence that would support the recyclhq of other pultq process waters nut currently allmed by the USDA. No significant carcass quality differences were detected between carcasses chilled in tap mter and those chilled in recycled chiller water (1.1:l.O recycle rate) with regard to skin color, meat flavor, shelf life or presence of coliforms or %bnnella.

Results of this study shaw that effective water treatmmts do exist for reducing effluent waste loads at their scurces and that fresh water demanfk can be r&uc& in paultry chillers.

-c m?=t

~ current USDA regulations require that a half gallon of water be used to chill every broiler. If a plant processes 200,000 broilers per day, then it uses at least 100,000 gallons of water daily to chill can=asses. If 85 percent of the water could be reconditioned, then the plant would save 85,000 gallons of water per day or 21.2 million gallons per year. At $1.90/1000 gallons of water, a plant of this capacity could save over $40,000 per year water and sewer service charges. Effluent dis&arye loads axld also be reduced by approximately 154,000 paunds of COD and 70,000 pour& of TS ea& year. The BOD and susperded solids surcharge savings axld be aln-cst $25,000 per year. A total potential savings for water, sewer and fllrcharges of $65,000 per year is estimatd not to mention energy savings in refrigeration costs and sale of recovered solids to renderers. costs for pdmsing and operating these sys” are presently being determined.

31.2 Table 1. USEA Criteria for recycling chiller water ltux”.. pescent r&uction of M percent light Gallons of rewndi- micro-organi= in treated transmission in tioned waw to re- wae treated water (500 nm) place 1 gallon of fresh water

60 ...... 60 1.75 70 ...... 70 1.50 80 ...... 80 1.35 90 ...... 80 1.25 98 ...... 80 1.10

Table 2. Effect of ozomtion of overflm chiller water on water qudlity

water wityparametersb Ozonation

0 37.8 a43 675 234 4.39 2.42 2.42 .

10 65.2 435 546 57 0.96 0 0

20 83.8 366 476 27 0.41 0 0

30 90.7 334 477 22 0 0 0

50 95.0 323 452 57 0 0 0 a Ozone generator output: 18.1 p. b *light tr”s ion, COD-chdcal oxyyen de,TS-total solids, FOG fats/oil/grease, APC-aerobic plate count, COLIF’mlifonns.

31.2 %le 3. Effect of screemq' , diatoaMcecrus earth filtration and ozonation on reconditioning broiler overflow driller water

Control 1 37.0 1570 818 698 3.88 - - Control 2 37.3 777 530 179 3.95 3.00 1.38

DE 93.4 246 295 52 4.52 - - WO3 97.0 206 288 37 0.53 0 0

a Control 1-before trabent, Control 2-after screening, DE-5 min. of filtration, DE/03-5 min. filtration/i5 min. ozomtion (30.4ppm generator outyxlt) b See Table 2, SALM-Salmcnella.

Table 4. Effect of scmmiq and diatmaceous earth filtration (Walton 3.14 in2 fi_lter) on 'tiom broiler overflow chiller water

1-2 99.1 279 2.55 3-4 97.8 348 - 5-6 98.4 3 64 -

7-8 97.1 373 2.93 9 97.0 - -

a ~ee%le 2. b chiller water after saeeniq.

31 .$ Table 5. Effect of saeenhg and diatamceous earth filtratian (1.0 ft2 filter) on recondl'tioning broiler overflclw chiller wakr

Water oual itv -ha

Filtration time %T OD Apc am E. Coli (500 m) (mg/L) CfU(loglO)/ml

ob 22.0 925 4.24 3.11 2.35 5 97.1 335 2.81 1.23 1.23

15 97.5 384 2.85 1.36 1.36

25 92.3 375 2.91 1.36 1.36 a see Table 2. b chiller water after -.

31.5

Ei@ltPXO=SSO~havereceivedUlall~GtZWh

A unique program of pollution prevention has benefited at least eight food processors in North Carolina. Tko daw plants, two poultry prccessors, a beef slaughtering facility, a breaded foods plant, a snack foods plant and a seafood pmcessing plant have received Challenge Grants fmm the NC Pollution "tion Pays Program administered by the NC Department of Natural Resources andcommunl'ty Development. The Department of Food Science Esrtension faculty at NC State University helped implement each study to assess pollution prevention in these food process^ plants.

Four food processors have campleted their studies and demonstrat& the potential for savings from pollution prevention activities. Th- processors include the two dairy plants, beef slaughtering facility and seafood processing plant. The processors are Maola Milk and Ice cream ccxnpany (MAOLA) h New Bern, NC; Hunter Jersey Farxrs (HUNTER) in Charlotte, NC; Randolph Packing Co. (RANDOLPH) in Asheboro, NC and Emufort Fisheries (BEAuEI3#T) Beaufort, NC as listed in Table 1. MAOIA received two Challenge Grants with one study -let& in 1986 and the other in 1987.

Each Grant was used to fund a study to assess management and process changes to prevent pollution. The studies were each implemented with the assistance of the NC Agricultural Extension Service faculty in the Dewtof Food Science at NC State University. The studies were for the demonstration of the savings possible by reducing dispcsal/dis&arye and prduction costs while increasing plant efficiency and in- from sale or use of recovered focd pm3ucts or by-prcducts.

Nc l?" utilizes pllutim pT32venh'on Pays ?he Governor has charged the NC Department of Natural Resources and Con"'ty Developentwith creating and implementing the pollution Prevention Pays (PPP) Program. The Department is convinced that pollution prevention provides technolcgicdl, econcnnic and environmental advantages over traditional methods. The lfend-of-the-pipeftand landfill approaches are expensive to inctuStry and create regulatory costs and problems for government. They

1% E. carawan, Extension specialist, Departrnent of FOO~science, NO^ Carolina State University, Box 7624, Raleigh, NC 27695-7624

32.1 Table 1. Food procesSing Plants, Fmduction, Location and Study

NC Plant Foods processed Capletion Designation city

Maola Milk and Ice cream co. MilyICe cream/Drinks 1986 MAOLA New Bern Maola Milk and Ice cream co. mom I1 New Bern MDnter Jersey FamS Fluid Miuc/ Drinks 1986 charlotte Randolph Packing co. Beef Slaughtering 0. 1986 Asheboro Beaufort Fisheries CO. Menhaden 1986 BFAuFQRr Beaufort

discourage creativity and hmvation. The Challenge Grant program pmvides 'cost sharing grants to inctustry to em=aurage new methods for reduciq pollution.

Although lrrany scientists and bxhnical people have practiced pollution prevention pays, Dr. Joesph T. Ling of the 3M company can be credited with first using the 3M Pollution Prevention Pays (3P) Program. Dr. Ling concluded that industry and beginning be government, the public are to aware of the ~~ shorkmings of conventional pollution controls, not to mention their cost. Pollution Prevention pays utilizies the concept that the conservation approach should be used to eliminate the causes of pollution before spending mney and resources to clean up afterward. Dr. Lhq defines the conservation approach as the practical application of knowledge, methcds, and means to provide the

ZIlDSt rational use of resources to improve the environment. Dr. Ling believes ~ that the pollution prevention approach has been kindered or precluded by many rigid errvirorrmental laws and regulations. They specify m deviation from the conventional technology nor do they allw alternative abatement approaches.

One exarrp?le is municipal prembnent ordinances with specific limits on the Concentration of pollutants in wastewater discharge. For food prccesshq plants, maxi" concentration limits on compatible pollutants such as m~g often preclude water reuse and recycling. Studies indicate that plants with

32.2 the least amount of water use per unit of prduct processed have the least amount of pollutants per unit of product processed. mus, such ordinances discourage water conservation and waste rmction practices.

Dr. Ling notes that pollution controls solve no prablem; they only alter the prablem. He says there is significant opportunity if realistic and effective solutions are sought for pollution probleii.

Pretreamt of focd plant wastewater does not really solve a pollution problem. It only generates sludge which must be dim of properly to prevent mving the pollution to another location. AS pretreatment or treatment requirements increase, the resowes consum&, the residues produced and the costs incurrea rise expmtially. Dr. Ling defines this mironmental paradox as follm: "It takes resources to wrove pollution; pollution removal generates residue; it takes more resources to dispose of this residue and disposal of this residue also produces pollution."

Bli&ael G. Royston rewgnizes pollutants as mterial residues fmbihstrial, dcmestic or agricultural p"zs which are discharged inta the envirommt. He believes that such materials could either be reused or they should not have ken produd in the fixst place. Royston notes that pollution acts as an indication of inefficient processes. He concludes that as inefficiencies are r&u&, so is pollution reduced.

The Studies reported in this pper were performa3 to help food processors apply their ingenuity to develop cost effective resource conservation practices and technology and to increase plant efficiency. MU& of what is reported was I" to the general industq but not practiced by the plants studied. The help, resources and encouragement of the Pollution Prevention Pays Program and the NC Agricultural Drtension Sewice were the conpnents necessary to make such activities happen.

-& stsldy has a similar format me four fmd plants were each reviewed by a study team for n-anagement practice and process changes to prevent pollution. changes were selected for evaluation and econumic analysis. changes were selected frcan those opportunities shm in Table 2. A conceptual xheme was developed for each study based on r-ction of cwrpatible pollutants such as B3Dg and cost effectiveness.

Evaluation was done by a team carprise3 of two or more extension specialists frum NCSU and a pmject leader at each plant. Each evaluation was planned for a six month period but the studies required 9 to 12 months to amplete. Evaluations focused on the follming:

32.3 Table 2. Measums to Control Water Use, product Loss and Waste Load l4umb€r MeasUre

1. Managenmt UrdeETbmnq' , interestandsqpo~ 2. Installation of lrrodern pmxsses, equiprmt and piping to mceloss of product to sewers and to "ize water use

3. pgpoinbnent of water use waste control supemisor

4. Enployee training

5. Accurate mrds of hater use and waste

6. scheduling to redtuce wake use and waste 7. h-oper ard efficient cleaning procdues

8. Wastewater mnitorirq 9. Planned IMinteMnce program to reduce water use, losses ard waste

10. Planned quality control program to reduce losses and waste 11 . Systems to merwasted or undesired parts of product 12. Developing of altemative uses for basted or undesired p-ct recovery 13 . Installation of processes that can merlost pro%& fm the wastewaterst"

1. 'Irechnolqical feasibility 2. &@idle regulations 3. Safety and sanitation requirements 4. Managementacceptance 5. zmpactonwasteloads 6. Impactofwateruse 7. Cost as cauld be esthted without a detailed study 8. Impact on plant efficiency 9. Employeetrainingrequirements

The sequence of the studies was as follms:

1. Literature search for krwn practices to race pollution for the food Mustry StLldied. 2. Plant visits with the team to review current water use, waste load and operatiom1 factors. 3. Review of observed inefficient practices to seek alternatives. 32.4 Employees were asked for solutions to known problems. 4. A Benchmark water use and pllutional load was established. 5. changes were selectel for evaluation. 6. After the changes were individually evaluated, a report ccanbining changes Prepared. 7. The mprt- was discussed with management and possible plans for bplementation reviewed.

Initial costs. Initial costs for changes were estimated by the team or obtained from suppliers. Initial costs included @pent, materials, erection and labor necessary for the installation of each change. The limited scope of these studies did not allow detailed engineering studies and costs to be develaped.

Increased Cost. mintemnce, interest, depreciation, labor and utilities were totaled to determine the hmeased cost of any change. Utilities include water use, energy and cleaning &edd costs. costs &d predict the annual increase in aperating cost for any change. Increased costs were developed specifically for each plant. Costs to the studies included maintenance at 15 percent of material cost, interest at 9-10.5 percent, installation labor at $20-30 per hour, electricity at $O.O6/kWh, depreciation at 14.3 percent for hoses, tanks and lines and 5 percent for buildings, water at $1.00 per 1,000 gallons, sewer at $1.00 per 1,000 gallons, plant labor at $8.00 per hour and surcharge prevention at $0.10-0.20 per pound of Bo% eliminated. *

Annual wldsets. Budgets were developed utilizing the following methods and p"eS. Lncreased revenues are sham for recovered material used as product or for salvage and for by-prcducts. Reduced Costs include surcharge prevention. Icss prevention was shown for the dairy plants studied and energy costs and employee labor for products which are not lost but recovered.

Net savings or loss was determined as follows: NS (L) = IR + RC - IC

where NS(L) = Fet savings (loss) IR ="easedrevenues Rc =R&cedcosts IC = costs. The results show great promise.

?here are four reasons that a foad processing plant would incorpOrate management and prooess changes to reduce waste load which can be directly related to pollution. These reasas include:

1. public image 2. Efficiency 32.5 3. Cost reduction 4. Regulatozy requirert.lents

-&nark. A beginning water use and waste load was established for each plant studied. Water use coefficients ranged froan 200 gal/l,OOO lb of raw milk received (RM) for HUNTER to 6,000 gal/l,OOO lb fish received (FR) for surimi precessing at EEAU". Waste load coefficients were froan 3.0 lb/l,OOO lb RM for HUNTER to 125 lb/l,OOO lb FR for BEATJEDKI?.

Pollution Prwerrtion Potential. For each study, the pollution reduction patential was tataled for the incorporation of all the changes. The pollution prevent& was Summarized for biochemicdl oxyyen demand (Bok) load reduction and is presented in Table 3. The prevention Langed from 320,000 Ibs BODg per year for BEAuFt3HT to 60,000 Ibs B3Dg per year for RAND0L;RI.

costs and %virws. The costs and savings for the re"end& changes for each study were tatald and are presented in Table 3. Initial costs ranged fmn $8,000 for RANDOLPH to $312,500 for FBAUFORT. Annual casts ranged frm $10,555 for RANDOLPH to $308,377 for -KT. Net Savings were predicted fram BFWKIIQ at $900,000 to RANDOLPH at $1,425 annually.

Table 3. pollution prevention potential (Bok),Initial Qst, Annual Cost and Net Savings (Loss)

Pollution Prevention Initial Lm=reased Net study patentid cost cost Savings

~~ ("3 ($1 ($1 ($1 I.lu" 226,400 166,962 75 ,390 62,894

MAOLA 320,000 206,342 111 I 179 339 ,699 mIA-I1 320,000 53 ,530 35,006 302,050

BEAUFOHT 250,000 312 ,500 308 I 377 900 ,000

RANDOLPH 60,000 8,000 10,555 1,425

Wastewater characteristics. Marry food plants discharging to municipalities are finding their wastewater discharge regulated by limits on the concentrations of seleded mstewa* parameters such as EO&, chemical oqgen demrd, (COD); total suspended solids, (TSS); and fats, oils and greases, (FOG). The benchmark wastewater EOD5 concentration for the plants studied was 1,800 q/l for -, 2,900 mg/l for MAOM, 2,400 q/l for M7lOLA-11, 2,500 32.6 ny/1 for BEAURXT and 2,543 ny/1 for (Table 4). Wastewater parameters predicted after reccnmnended changes are estimated to be from 4,496 ny/l for BEAuI;DHI: to 610 ny/l for RANCOLSH. Table 4. Estimate3 or Measured B3D5 for Food Plants Studied

----(q/l)- - - -

HuNIER Milyminks 1,800 1,200

MAOLA Multiproauct 2 ,900 1,900

MAOLA-I1 Multiproduct 2,400 1,900 l3ExmDm Menhanden-surilni 2 ,500 4 ,500

Fa" Beef 2 ,543 610

The increase in B3Dg c=onCentration predicted for BFAUFD~from 2,500 to almost 4,500 q,/l helps to demonstrate the need for mass limits if society wants to el-te pollution. Food plants with lower water use coefficients almost always have lower waste load coefficients. If water use reauction is a worthy enviromtal goal, then water reuse and recyclj3lg needs to be t"raged. me inwrporation of such changes frequently, as observed for BEAUFOHT, leads to reductions in water use and waste load butthe concentration of wastewater parameters often inmeass.

Top managanent is responsible for a firm's acccrmplishments in the environmental field. Their attitude is responsible for water use rectuctions and waste elmtion. Each of the Campanies studied could only achieve success because someone at the top thought this activity was important. They quickly realized that the lowest cost control measures usually are those that attack the problem at its source. None of the changes reviewed for the food plants studied can be implemented successfully without continuing interest by TMMgement.

Each of the studies has dmnstrated the savings possible through avoidance of disposal/discharge costs, reduced production cost, illmas& plant efficiencies and incame from &e or reuse of recovered materidls. other changes my be feasible for these plants and recammended changes my need modification before installation. However, all food plants can benefit fronu similar studies of their operations to select cost beneficid changes for preventing pollution.

32.7 Conclusions

1. Food processors can reduce pollution. In many cases this activity can pay with savings greater than the costs to inpllement necessary changes. 2. Ihe mnagaent of food processing plants similar to these studied can often reduce water use and pollutants without expkhq' capital. capital expemiitures can further decrease water use and pollutants.

1. sewer use and pI-r.3-mt ordinances shdd contain ZMSS limits and not concentration limits.

2. sewer use and pre-mt ordinances should recqrdze process and management changes as effective pretreatment pmc&ures. 3. The disposal of residues, by-pmducts and sludges from food processing plants needs more efficient and effective m&hofiologies. 4. Food plant enqloyees should be tram to "ize water use and wastes.

These Mviduals formed the teanrs that participted in these challenge Grants. 'lhe author appreciates and values the contribution of each team member, the h-dmkry participation and the support of the North Carolha Pollution Prevention Pays Program. Project reports are available from the NC Pollution Prevention Pays Program office.

Department of Food Science study Representative- Faculty (Extension) MAOLA I R.A. wzllard JahnE. Rushing mom I1 R.A. Willard Roy E. Carawan HUNTER J.M. Hunter John E. rzushing RoyE. Carawan RANDOLFIH Craig Hamlet Dwah H. Pilkhgton RoyE. -wan

BEAITFo#r SamD. Thomas F'rankB. Thanas David P. Green Roy E. Carawan

32.8 Teresa L. Schurter In 1964 Congress passed the Fazardous and Solid Waste Amendments modifying the Resource Conservation and Recovery Act (RCRA) in a nurrber of sigEificsnt ways. Two aspects of particular concern ir. the microelectronics industry are 1 ) the Waste Ninimization Prograri and 2) the land disposal restrictions - specifically for F-series wastes such as electroplating wastewater treatment sludges and some solvent wastes. Although these efforts are administered separately they are closely linked from the viewpoint of waste nanagenent at Data General's printed circuit board manufacturing facility. Tht ?urpose of this paper is to discuss how Data General is workice to mininize waste as well as avoid potential burial restrictions and long time liabilities through waste marketing. There are several waste streams generated at Data General rihicn are recycled/recovered off site at little or no expense to tke fscility. They include spent ammonia and cupric chloride etchants which have always been segregated and shipped off site for copper reclamation. Provided specif ications for copper concentration sre met, a small return is received from this pr2ctice. Solvents such as 1 ,1 ,1 trichlcroethane and methylene chloride are carefully segregated and recovered thrcugh off site thin filK evaporative methods. Copper sulfate crystals are washed and dried leaving no corrosive residue, and this waste is also sold for a small profit. These wastes accouct for approximately 73'; of our &ener a te6 w aste. Our greatest marketing challenge, our FG06 electroplating wastewater treatment sludge, a copper hydroxide sludge, makes up another 19;; of generated waste. After many months of work to modify process chemistry and nany more months of searchifig for a suitable disposal site, we are finally able to ir,clL;de this ir. oL;r total of recyclable waste streams. This brings the percentzge of marketed waste to 92% of the total hazardous waste volume ge ne r a ted.

Locating a Market For Your Waste Case Study: F006 Electroplating Wastewater Treatment Sludge The first step taken in develcping a marketable waste is to determine what your potential "customers" want in a product. First, we contacted recleimers, sEelters, etc., and offered

1. Supervisor/Chemical Engineer, Data General Corporation, P.O. Box 186, Clayton, NC 27520

33.1 sanples of our waste electroplating sludge for evaluation of recovery value of the copper. The overwhelming response was that -our copper concentrations were tos :cw (&-lo$), and that the contaminant levels (particularly iror;) were excessive. As a result of this information we began chemical Kodification of our treatnent process and gradually reduced the iron used in the process and thus reduced the iron concentration in the sludge. Currently, there is essentially no iron in our waste sludge, total sludge volune has been reduced to approximately 50% of previous volunes, and copper concentrations range between 25-35: dry weight ba si s.

After makicg the chemical modificstions Data General created a sludge product which has a reclaim value and which several of the companies originally contacted would now readily hand1 e. However, we faced two tlproblemslf at this point. Fiost of the interested conpanies were recycle facilities and did not have the necessary perzits to handle listed hazardous waste. Those that did have the permits recognized that we wanted to dispose of llHazardous V.:'!Tstell and thus would accept our sludge for 2 fee just slightly less than the cost of buri&l. This second difficulty was both frustrating and annoying to us. \Je knew that we had pl;t ourselves icto 2 position that lane disposal was no longer a way of life, but we also knew that our sludge had value and yet we were being asked to pay another company to recover the metal when they would certainly collect the reclsmation value as well.

Fros 1984 to 1386 Data General shipped our sludge to a copper smelter in West Germany. The reclaim value of the sludge was sufficient to pay for transportation as well as associated brokerage fees. However, with the changes in export regulations in August 1966, notification and approval for export became much more complicated ar,d we aid not feel that we could guarantee the control and handling of our waste in foreign countries. In 1986/87 both waste treatment engineers and one of our purchasing agents began again to search for a company who could successfully and legally utilize our copper sludge as a resource. Our purchasing agent describes this endeavor as "the single ncst challenging task" he has undertaken in his career with Data General. \le contacted conpanies listed in industrial directories, those suggested by US EPA cofitacts, ltwcrd-of-moutk;ll contzcts, etc. As potential llcustoners'f Were located we contacted thes by ~ telephone to determine possible icterests, If response was positive, we would then contact stste agencies and the regionEl EPA office for permit status, com~liancerecords, and general information. Through these efforts, one facility was located which we felt could handle our FG06 waste. Arrangements were then made for a plant visit. At this time operations and permits were - inspected in detcil, and appropriate government agencies were contacted in person. In late 1987 we were successful in locating a qualified disposal site.

33.2 Although the process undertaken to create a marketable material as well as that used to lGcate a qualified customer has been both the consuxing and difficult, the rewards for efforts are certainly apparent in light of the upcoming land ban of metal hydroxide sludges. Aaditionslly, while the search for a suitable aisposal site was taking place we continued working with EPA's Office of International Affairs, and we have recently been authorized to again export our sludge overseas. As difficult and exasperating as these efforts may seem they have given us an alternative to land filling this waste, and our sludge is now being successfully reused so that it poses no further threat to human health ana the environsent.

33.3

THE USE OF CANISTER ION EXCHANGE TECHNOLOGY IN A ZERO DISCHARGE FACILITY John Easonl

This paper will focus on the use of ion exchange to achieve a true zero discharge from a large circuit board facility. Zero discharge in this case being no flow and no hazardous waste. Case study data will be presented showing how this technology can be used in various applications to upgrade existing systems, treat difficult chelated streams at the source, and provide an alternate technology for smal 1 dischargers. This case study involves Martin Marietta's printed circuit board shop in Florida. First, the individual process lines were evaluated to determine the best procedure for reducing drag-out. New machines were designed and installed with dual stagnant rinses followed by a counterflow closed loop rinse. The first stagnant rinse was dumped to a holding area once the concentration reached about 30% of bath strength. The first stagnant rinse tank is then made-up with solution from the second stagnant rinse, and the second replenished with fresh water. The counterflow rinse following the stagnant rinses was then circulated in a close loop manner through a series of four to eight ion exchange canisters. Organic adsorber resins were utilized to remove any organics which may be present. The canisters were operated until a preset conductivity of about 10-20 microsiemens-cm was reached. The loaded canisters are then removed and taken to a remote regeneration area. Regeneration of cation canisters is accomplished by recirculating a 5% sulfuric acid solution through the canisters for a period of about one hour. This is followed by a fresh acid regeneration with about one-two bed volumes. The fresh acid is then used to replenish the recirculated acid supply. Anion resins were similarly treated with 5% caustic substituted for sulfuric acid. This regeneration cycle results in significantly reduced regeneration volume. This facilitates metal recovery from the regenerate solution and the zero di scharge concept. Regeneration wastes from the canisters were combined with contaminated drag-out solutions. The metals were then removed to less than 100 mg/l by electrolytic plate out cells. The spent plate solution was batch treated to precipitate the remaining metals. The metal hydroxides were dissolved in acid and sent back to the plate-out cell. The filter press filtrate was polished with a cation canister system utilizing chelate type resins. The metal free solution was then concentrated in a vapor recompression evaporator, and the distil late used for cooling tower make-up. The concentrated brine was then cooked to form a salt which is removed as a non-hazardous waste.

1. Manager, Pollution Abatement, NAPCO Incorporated, P.O. Box 26, Plymouth Industri a1 Park, Terryvil le, CT 06786 34.1 Individual canister systems can also be used by small dischargers to recycle rinses, or to remove metals prior to discharge. The small volume of regenerate wastes can then be treated by electrolytic pl ate-out of metals or simple batch treatment. Companies with existing treatment systems can use canister ion exchange to recycle rinses to reduce the hydraulic load. Hard to treat solutions containing chelates can also be treated to separate the metals from the chelates, thereby reducing the load on end of line treatment.

34.2 If could collect the agendas fran the Board Rx", Production and Supr- visor's meetirgs of printed wiring Board (RJB) fabricators, we would find waste treatment environmental ard safety cmcerns as prominent issws on those agendas. This prominence is the result of increased awareness, legislation and concern for the people in the mrkplace ad the enviromnt. A geat deal of work has generated some progress in reducing effluents, but there is another approach which deserves OUT attention - changing the production pocess technology so that it doesn't produce the waste in the first place. This paper describes a case of technolcgy replacement in a print& wiring board fabrication line which minimized the volume md classification of the waste stream.

In the Fabrication of a multi-layer printed wiring board there are many mechanical and chemical operations to be performed. A simple segmentation of these operations is: Innerlayer manufacture - lamination - drill - Smear removal - electroless coppr depsition - image - electroplate - etch There are many operations within the segments above, and additional segments are required for certain bard types ie. nickel/gold tabs, SMCBC. This papr will focus on the electroless copper depsition segment of the PFjB fabrication opration.

The steps of a typical electroless copper process are listed klow in Table 1. Alongside each process step is the cunpnent(s) that requires spcial handliq:

Formaldehyde, cmplexors, stabilizers, chelators, th, and as the name %lies, copper itself are key cOmpOnentS in the prcxhction of this prcduct. These mteridls either require specid handling and are potentially hazardous to your operators of you must by law treat and dispose of them. Table 1

Electroless Coppr Spcial Handling Canpnents

Alkaline Cleaner Keak/Strong Complexor, Cu Rinse Neak/Strong Cmplexor, Cu Conditioner Weak/Complexor , Cu Rinse Keak/Canplexor, Cu Micro-etch Cu (Sulfuric/Peroxide or Persulfate) Rinse Cu (Sulfuric/Feroxide or Persulfate) Sulfuric Acid 10% Cu, Acid Rinse Cu, Acid

1. lkchnical Service Manager, Printed Wire Board Division, Olin Hunt SPCialtY Products Inc., 201 bosevelt Place, Palisades Pzrk, NJ 07650-0800 35.1 Table 1 (continued)

Electroless Coppr Spcial Hardling Canpnents

Activator Pre-Dip Sodium Chloride, HC1, Cu Activator W, Tin, Cu, Sodium Chloride HC1 Drag-out Rinse Pd, Tin, Cu, sodium Chloride HC1 Rinse W, Tin, Cu, Sodium Chloride Hc1 Accelerator Sn, Cu, Acid (HBF4) Rinse Cu, Acid (HBFb) Sn, 1 Electroless Coppx Strong Canplexor (Quddral, EDTA) Cu, Stabilizers, Formaldehyde Rinse Cu, Stabilizers, Fbrmaldehyde Rinse Cu, Stabilizers, Formaldehyde Acid Dip Cu, Acid Rinse Cu, Acid Dry ?his is a heavy load on a manufacturing facility from the viewpoint of safety, process separation, waste treatment ard disposal.

?he alternative technology to replace the mnventional copper process is called BLACKHOLE”.

BLAcxHoLE ‘IM provides a simpler, safer and quality conscious alternative for preparhg hole walls for subsequent electroplatbg. A reduction in both the volume axi classification of the waste is mized frm ‘IM processing which benefits the waste treatxmt area.

?he EUCKHOE ‘IM bath itself is a carfxln black dispersion with a viscosity about the same as water. it contains no metals, no chelators, and most importantly, no formldehyde. The process steps of the BIACKHOU pms are laid out in Table 2. Table 2

BLACKHOLE” Process Special Hardling Ccmpnents

BLACKHOLE” Cleaner Weak Complexor, Cu Rinse Weak Canplexor, Ch BLACKHOLE” andit ioner Weak Complexor, Cu Rinse Weak Canplexor, Ch BLACKHOLE” Bath Aqueous Carbon Black Dispersion Oven - Mic r o-e tch Cu (Sulfuric/Perox ide Per sulfate) Rinse Cu (Sulfuric/Feroxide Fersulfate) Scr ub/Dr y -

By canprison with the electroless ccppr Pocess, only one cmpnent chemical associated with the BLACKHOLE” process requires special handling - the chelator fourd in the BLACKHOLE” cleaner ad conditioner pocess steps. There are no special waste treatment or disposal requirements with the BLACKHOLE” bath. Copper which is a major waste treatment mncern, is not pesent at initial make-up.

35.2 As with the electroless copper deposition process, copper is removed from the PWB in the cleaning ard conditionig steps of the BLACKHOLE” pocess. However the BLACKHOLE” cleaner and conditioner employ a weak complexer at a relatively low alkalinity which reduces the amount of ccpFr removed kan the PWB at a throughput of 300 SSF/sal of operative solution. The measured copper content in the BLACKHOLE“ cleaner was approximately 600 ppn ad approximtely 400 ppn was measured in the BLACKHOLE“ conditioner. At our current field evaluation site the rinses followiq the BLACKHOLE” cleaner and conditioner pesently met EPA requirements and do not require treatment. By amtrast the existing electroless coppr line generates approximately 16 lbs. of cqper pr day, which must be extracted from the rinses and overflow from electroless copper bath.

While classification of waste is imprtant, perhaps of even greater relevance is the volm of material to be treated. In the electroless coppr pocess massive amounts of water are used. This is the result of its many process steps an3 the need for rinsiq betwen them. Even employirq mter conservation techniques like counterflow rinse, the volume is still substantial. In preparing this paper, an informal survey of these PWB fabricators in the production range of one million surface square feet per year, the lowest rinse volume off the line was 30 gal../min. BLACKHOLE” with its fewx number of process steps and rinses benefits waste treatment from a volume viewpoint. Usiq the same flow rates in the rinses as electroless ccppx, a calculated water savings of at least 50% can be realized. In summary, with issues su& as Proposition 65 in Calikrnia ad ever re- stricting regulations on waste (like sludge to landfills facing manufacturers) , w must not only look to improved waste treatrrent pocedures, but look toward alternative technologies which do not produce the waste requiring treatment and disposal.

35.3

U;e B. Schmidt

It is entirely appropriate that the subject of plastic recycling be examined -~ during this waste reduction conference. Given the current interest by citizens, industq , the press, gwernme.nt officials, and miromUists in not only pollution but also solid waste disposal, it is important that the subject of recycling be thomug~yexamined by all industries-including the Packagirrg industry. As an integral part of the packaging indtustry, the plastics industry is nm playing a lea- role in the recavery of its own products for recycling into na~end-use prcducts. Given the current landfill crisis in this Country, it is important that all of us put the subject of recycling in its proper place as one of the mcst important items on our agendas.

There is absolutely no question that there is a solid waste crisis of almost epidemic proportions facing the United States today. All one has to do is La pick up the newspaper or turn on the evening news to read or hear more about the problem. me nation is simply running out of rcuin to dispose of its wge. In PeMsylvania, ten years ago there were nearly 1,700 operating landfills. Today, by contrast, there are only 90, with no new facilities planned. Ihe city of Philadelphia is now talking about shipping its solid waste all the bay to the Hauston area in Texas. As you might imagine, this proposal has met with opposition fmthe citizens of Texas. In Florida, landfills in 33 of 67 counties will close this year. Last summer, the much heralded %prbage barge" made its cdyssey dmthe Atlantic coast and around the Gulf of Mexico in search of a state or nation which would accept its cargo. Perhaps more than any other single occurrence, the garbage barye pointed out the need for a change in the way we approach the solid waste problem in this country.

A recent article in the Orlando Sentinel pointed out some other interesting facts concerning solid waste:

* Acmrding to a study done by Franklin Associates for the EPA, Americans throw away 135 million tons of municipal solid waste each year.

* In another way of looking at the problem you can take this same 135 million metric tons and campletely fill the Louisiana superdome fram floor to ceiling every two days for an entire Y-* In North Carolina, during the next five years, perhaps as many as one-third of all 100 county landfills will close. In six to ten years, an additional 12

President, National Association for Plastic Container Recovery, 5024 parkway Plaza Blvd, Suite 200, Charlotte, NC 28217

36.1 country landfills will close. Clearly, a crisis is developing right here in North Carolina. All of you are aware of the problems and delays which can occur r$len tqiq to site a new landfill or resource recovery plant. mere have to be alternative solutions to the problems posed by solid waste, and recycling is one of them. what is needed is a balm& usage of the three primary disposal methcds currently available; landfill, incineration, and recycling. ~~

Plastic Recycling Is part of a Balanced Waste Managanent *roach

___ currently, plastics ccnnpose between four and seven percent of all of the solid waste in the United States. Although not the leading contributor to the waste stream, the plastics industry recognizes that it has a role to play in helping the nation find solutions to the solid waste problem. In my the inauStry has determined that recycling will help it to solve its share of the solid waste problem.

As you kncw, there are mytypes of recyclable plastic containers. nese include the plastic soft drink container, made of polyethylene terephalate (commonly known as FBI?), and plastic milk contahers, which are made of a high density polyethylene (HDPE) . Other plastics used to make containers which are recyclable include polyvinylchloride and polypropylene.

pGT Is particularly Well suited for Recycling PEI’, which is used primarily for the mufacture of plastic soft drink containers is recyclable. myenvironmentalists and other folks not knowledgeable on the subject will tell you that it is not. Hmever, the container can be and is being recycled into a variety of end-uses. These include textile fibers such as fiberfill for dmsleeping bags and ski jackets; scouring pads, carpet backing, strapping or banding material; woven fabrics; nonwoven fabrics; injection molded distributor caps for engines, and more. Ixlring 1987 an esthted 150 million pounds of PET was recycled in the united states.

NApcclR Fonned to mte Reuse of PElT Because of the mypositive attributes of recycling, the nation‘s leading polyester resin and polyester bottle manufacturers decided to form the National Association for Plastic container Recuvery--a new national trade association better known by its acronym, mR.

NAFCOR’s members include Easa memicals Division of the Eastman Kdak Camparsy, Goodyear, ICI Americas, Hoescht Celanese, Ixzpont, Sewell Plastics, Johnson Controls, Southeastern Contaker, and Western Container. A nonpmfit copration chartered in the state of Delaware, NAPCX>R is a national trade association and is based in Charlotte, NC. Its pr- mission is to facilitate the collection, reclamation and development of d-uses for post consumer bottles with the initial emphasis placed on the PET soft drink container. NAFCOR’s goals include the following: * Achieve a recycling rate equal to 50 percent of all PET soft drink amtahers sold in the United States by the end of 1992

36.2 * Ixlrhg 1988, initiate and develop new PFT recovery projects in at least few stx&f?s, to be followed by others (States currently under consideration include Rhode Island, Pennsylvania, North Carolina, South Carolina, Kentucky, Florida, Texas, Wisconsin, andMinnesota.) * rXUrw 1988, increase the amount of PET soft drink contain- recycled by 30 million pounds, an increase of 20 percent nationally * Elnsure that all m that is collect& recycled * support sound forms of packaging legislation that pertain to recycling W'sprimary efforts will be in the area of container collection. Currently there are three primary means of collection--buy-back, drcp-off, and curb-side. mRwill evaluate these and other subsequent collection systems as we develop full Scale recwery programs by attempting to develop a collection program that is well suit& to a particular market.

curb-side Collection Program in Mecklenburg County, Nc, shcrws Advantages of Public, Mvate -tion PET is nm be- collected in a buy-back progrzm in Louisville, Kentucky; through a cub-side collection program in Mecklenbuxg County, NC; and through a wmbhtion of drop-off and cwb-side in various cities in New Jersey. The Mecklenburg County proj& has been very successful in tenns of a multi- material axbide recyc1h-g program. Started as a pilot project in February 1987 by the County with qprt from both the Coca-Cola and &psi Cola bcrttlers, the project originally served 9 ,000 homes. It is now being med to mer all 130,000 hames in ~lotte/M&enbury. The MecMenbq prcgram is really very simple. First, each home was pmided with a plastic container for recyclable PET, aluminUm, glass and newspaper. Homeowners were asked to place all of their recyclable mterials in the container and set the container at the curb on specific pick-up days. Specially designed trucks pick up the recyclables, with pick-up crews sorting the various materials at the curb into special bins on the trucks. Once the truck is full, it goes to a central materials recovery facility, commonly known as an MRF, where the materials are further sorted, densified, and sorted for later resale to umunercial recyclers. Ihe Mecklenbq county program clearly points out that PFT can easily became a part of a multi-material recovery program. The program's success has been due in no small part to the cooperation between the public and private sectors. Response from consumers has been excellent, with over 75 percent of all households in the test market area setting out LFeir recyclable= st least once a mnth. This ncrmber should increase as time goes on.

Plastics Recycling Is Part of Statewide Programs in California and New Jersey PET is be- collected and recycled in California on a statewide basis under California's Assembly Bill 2020, which was implemented last year. That bill calls for the creation of 2,700 recyclbg center within convenience zones.

36.3 Each of these zones is located within onehalf mile of a supermarket which has $2 million or more in anrmal sales. me plastics industry has creat& the ZLaskbs Recycling Corporation of California to provide cor"^ &cation regarding plastics recycling and to help develop markets. Although Assembly Bill 2020 was just recently implemented, we will soon how haw successful this alternative approach to recycling will be. ~

Ih connection with the new mandatory recycling law in New Jersey, the plastics industry, thmugh the Plastics Recycling Corporation of New Jersey -- (PRCNT), is "raging and developing plastic recavery programs thmughout that state. NApo3R is a major contributor to and ScrppOrter of PRW. We fully expect that within a reasonable period of time, plastic containezs will achieve recycling rates camparable to theof al~umand glass. At the same time, it is important to note that these materials have been pmting their recyclabiliw for a much longer time. Aluminum has been market& as recyclable since 1971. By contrast, the PET soft drink container did not became a viable consurer package until the early 1980s. NAPCOR will also work with collection entities--groups such as local governments, CammerCial waste haulers, and scrap 6ealers-to help establish markets for collected PET in given areas. At present there are four major FEr CammerCial recyclers-Wellrrran of Johnsonville, SC; ENVIPCD of Allentam, PA: St. Jude polymer of Frackville, PA; and Star Plastics of Albany, NY. There are other ampanies in the business and new CCTmpanies Ccrming forward.

NAPCORwill also help to develop public awareness materials that will help to educate evqone involved in the recycling processwnsumers, recyclers, legislators, and errvironmentalists about the advantages of pE;T recycling. Tb this end, we have hires Ketchum Public Relations of Washington to design a program. Yau will be hearing more about our campaign in the mnths ahead.

At the same time, MlpcoR will work with other industry and trade groups, such as the Plastics Recycling Foundation and the Society of Plastic Institute, to actvance the -use of plastics recycling. In summary, the recycling of plastic is not only real, it is now ready to becane a viable part of a c"mity's recycling program. The process of recyclh PET into new end-use products is here. The collection systems are emergins- 'ties which want assistance in developing such collection programs are- Coming forward. And, NAPCOR is quickly developing its capabilities to assist co"ity efforts by develop- markets for the recycled material and by promoting and supporting the establishment of collection Programs-

36.4 Even though some recycling FI-CX~~Sare very old, the national press has recently discovesed the topic of^ rezycling. Just yesterday USA Today had a story about the twentieth anniversxy of the Reynolds can recycling program. Of course, glass recycling is 01Se.r than that. me March 14 issue of Newsweek had an feature on recycling as i5ci the April 11 issue of Fortune. One reason recycling has became a hot topic is that we are running out of landfill space. Ten years ago thewere 18,000 imlfills in this countxy. Today there are 6,054 landfills. In addition, +&ere are questions about the advisability of incineration of solid waste, particulw about the disposal of incinerator ash.

Realistic -roach Is Key to ~~ccessof Waste Reduction and Recycling Program

Waste reduction and recycling are cdning to be seen as part of the solution to our solid waste problems, and these alternatives certainly can play a mjor role. My message is that in designing our waste reduction and recycling programs, we must be realistic. We are a convenience-oriented society, and the efficiency prrx?~ckkwe have cxxne to rely on &e it hard for us to go back to earlier ways of doing things. For instance, some environmental group have sugges+xd that we do away with plastic diapers. I submit to you that the mothers of Axrica are in no mood to go back to cloth diapers. Components of waste reauction programs must be acceptable to the public. We motdo away with a certai? segment of our waste stream and tell the public that they just have to figure out a way to get along without the products. me public will not tolerate that. In addition, we must look at multiple solutions, not just a single approach, and approaches must k adaptable, not set in concrete. As an example, consider the soft drink inauStry. We study packaging carefully to see what the consmer wants. Right ncxJ plastic packaging is gaining in popularity, but it is particularly popular i??Athe south. In the North, however, the can may be the consmer‘s choice. So, we in the soft drink industry would like to see particularly aggressive effct-ts to recycle plastic in the south and cans in the north.

Reynolds estimates that one out of every two aluminum cans is naw recycled, but they say that with +their present capacity, they can recycle 80 percent of all aluminum cans. 1”azt they need is an effective xrecham‘sm for getting the cans back. In the 9hss recycling prq”, about 15 percent of dl the glass in the United States cets recycled. mey tell me that they have the capacity to recycle about 50 percent. The plastics recyclers for soft drink packaging could recycle 20 percmt of the soft drink plastics now and 50 percent in five years. We need to promote dl1 these efforts, not focus exclusively on any one.

I Director, Recycling Prqnms, Yational Soft Drink Association, 1101 16th St, NW, Washington, E, 20036-4803 (202) 463-6740. 37.1 Finally, we need to avoid restrictive approaches. Recyclers do not like €ixz!ed wits. Nine states now have required deposits of up to 10 cents on beer and soft drink containers. ?his system is costly to the consumer, to the grocer, and to the soft drink industry. It generates a loss of sales which is a loss of tax revenue. Furthermore, it does little to solve the litter and solid waste problems, which is the reason it was designed. Beer and soft drink dinerscc~npose only about 10 percent of litter, and about 4.5 percent of the solid waste stream. So the deposit program is a very na" solution to a very narrow problem. What can governments, federal and state, do to prcnnote effective waste reauction prcgrams? ?heir proper role, we think, is research and analysis. Governments need to help define what we are trying to do and huw we can best aaxnplish our objectives because we need to understand the situation better. ?he private sector's role is to be proactive and positive, to get out front with its own solutions and programs. lche private sector must be self regulating and must unite in approaches to waste reduction.

Mney and comrenience Are &ys to success of Recycling programs What is it that makes recycling work? Studies Mcate that there are two reasons (1) money and (2) convenience. If you can make it very convenient for people, they will recycle, and that is a message people in local governmats should heed. The curbside pickup program in Mecklenbury county, which is voluntaxy, is about as convenient as it can get, and that is the key to its success. The conclusion that money is a strong motivation to recycling canes frm surveys that show that a mere 20 percent of the population returns the 50 percent of the al"m cans that are recycled. ?his 20 percent is mainly ccnnposed of youth groups and nonprofit organizations which pick up cans along the side of the road and otherwise collect recyclable mterials to earn money. mere are other reasons why people will recycle-saving the environnent, saving lard-but the fact is that mney and convenience are the keys to a successful approach.

Designing a rational recycling program requires that we understand the cost factors related to recycling. We can recycle anything we want to--at a cost to samebody. Samebody has to pay, and the public should understand this principle. At the same time, the..re are very tangible econdc benefits to saving landfill space, and these benefits need to be translated into tenns people can understand. As with waste reduction, recycling efforts must include a variety of approaches and must take into account regional differences. ?he soft drink industry feels that the solid waste issue is so inportant - that we have hired a consultant to help us get a broad understanding of the issue and all its ramifications. One of the questions we are asking ourselves is whether we should have an industry position on voluntary recycling in which

37.2 the consumer has a choice in haw he wants to recycle-a curbside pickup program or a recyclix-q center retum prcgram-as opposed to mandatory recycling. By us- the term llmandatory recycling11I do not refer to forced deposit, which we do'not support, but a legally mandated recycling program. States now have laws mardating recyclirq-New Jersey, %ode Island, Connecticut. The laws provide that if the hanemner does not separate recyclables fmother trash when he sets it at the curb, then it will not be picked up. I suggest that it would only take a corrple of weeks of not having trash picked up for any hc"er to catch on to what he must do. Surveys show, however, that the voluntary recycling programs have about as high a participation rate as the mandatory programs--about 78 percent. The voluntary prcgram have been creatively pro"arketed-like consumer products.

Government and Mvate Sector Cooperation on ~ecyclingprograms cazl Generate High Participation

*. Governments can pramote recycling by dete"g what kind of programs are going to work on regional and local bases, by stimulatkg markets for recycled materials by buying them, and by recycling its own wastes. The private sector role in recycling, like its role in waste reduction, is to act, not react. If we want to make sure that the consumer has choice in packaging, then we have to stay out in front in prcxnoting recycling. Ihe private sector also has to examine altematives. In the state of Washington, when the private sector was faced with the possibility of a deposit law, businesses came up with a suggestion for what is called a "litter tax." Businessesand~ies that typically relate to the litter stream-frcun fast food to soft drinks to diapers-were asked to voluntarily put a tax on their sales. The tax brings in about $3 million a year in the state which is dedicated to pick-up programs and eclucational programs on littering and recycling. A very hprtant role for the private sector is to Cooperate with gwerment, as the soft drink industry has done in helping local government in Mecklenburg County design and implement its recycling program. We believe that if government and the private sector work wether on waste reduction and recycling prcgrams, we can involve the consumers in ways that will make the programs successful and benefit all of us.

37.3

Incentives and Regulatory Issues in Waste Reduction BY 1 William Paige

Waste reduction can save money - often substantia amounts - through more efficient use of valuable resources and reduced waste treatment and disposal cost. However, a question commonly ask by industry and business is "what are the incentives and issues involved with a comprehensive waste reduction program?" This paper will examine the question from a regulatory viewpoint with particular emphasis on the 1984 RCRA amendments and the current definition of a solid waste (January 4, i985). The biggest incentive for generators to reduce their hazardous waste volume is the high and escalating cost of other forms of hazardous waste management. Land disposal cost has risen from $10 per ton of waste to at least $240 per ton. Disposal sites are in short supply, and prices keep rising. Anocher important incentive is that Congress has directed the Environmental Protection Agency (EPA) to phase out the land disposal of certain types of untreated wastes. Under the 1984 amendments to the Resource Conservation and Recovery Act many untreated wastes that were previously sent to landfills will now be incinerated or otherwise treated at costs many times higher than those for land aisposal. 1984 Amendments The Hazardous and Solid Waste Amendments of 1984 (HSWA) represent a clear shift in national policy away from land disposal and towards waste minimization. This policy is supported by the North Carolina General Assembly. The 1984 amendments ban the land disposal of hazardous waste unless EPA finds that such action will not endanger human health and the environment. Landfilling of bulk liquids has been prohibited since May 8, 1985. On November 7, 1986 the EPA promulqated final regulations on the land disposal of spent solvent and dioxin- containing hazardous waste. Effective November 8, 1986, certain spent solvent wastes cannot be land-disposed unless they meet certain concentration-based trez&rent standards-. All other spent solvents and dioxin-containing waste will be subject to the land disposal restriction on November 8, 1988.

1 supervisor, Technical Assistance/suppOrt Unit, Hazardous Waste Management Branch, Solid Waste Management Section, N.C. Department of Human Resources

38.1 The HSWA focuses attention in the area of waste minimization by establishing as national policy the reduction of hazardous waste. More specifically it states that:

0 Whenever feasible, the generation of hazardous waste is to be eliminated (i.e., waste reduction) as expeditiously as possible; and 0 Waste that is nevertheless generated should be treated, stored, or disposed so as to minimize present and future threats to human health and the environment.

As a result of these amendments, waste minimization considerations must be addressed in various areas of the RCRA process. These areas include: 1. manifest 2. biennial reports (annual in North Carolina) 3. on-site treatment,. storage and disposal permits Solid Waste Definition The current definition of a solid waste contains language that describes which "materials" are wastes when recycled. While recycling is normally not viewed as a waste reduction technique - unless in-process - it can serve as a viable option for managing many waste streams thus minimizing the waste volume requiring disposal. The definition adopts the approach that for secondary materials being recycied, one must know both what the material is and how it is being recycled before determining whether or not it is a RCRA hazardous waste. A waste cannot be classified as hazardous under RCRA without being first defined as a solid waste. This approach differs sharply from the previous definition which considered RCRA sludges, and most secondary materials (i-e., all those that are sometimes discarded by anyone managing them) as waste no matter how they are recycled. Four categories of recycling activities are currently regulated under the hazardous waste regulations:

0 Use constituting disposal 0 Reclamation 3 Speculative accumulation 0 Burning waste or waste fuels for energy recovery, or using wastes to produce a fuel These categories of recycling activities are further divided according to types of secondary material - spent materials, sludges, by-products, or commercial chemical products.

38.2 The following table summarizes when a secondary material being recycled is considered a solid waste.

spnt raterials (htb Listed and nontisted/ YeS YeS Yes charact-teristic). Sludges (listed) YeS Yes YeS Yes sludges (mr&sted/chracteristiic Yf?S Yes NO Yes By-products (listed) Yes Yes Yes YeS Q-prcducts (mnlisted/cbaracteristic) YeS Yes No Yes Ccmercial chemical products listed in No No 42 CFR 254.33 that are rim ordinarily applied to the lad or burned as fuels. Scrap metal Yes YE5

'ies--defined as a solid waste k--Not &fiwd as 6 soiid waste

Not all recycling activities are regulated by RCRA. Excluded activities either involve the direct use or reuse of a secondary material, or a material is recycled without first being reclaimed by being returned as a raw material substitute to the original primary production process. These activities are not considered "Waste" management since they are like ordinary production operations or ordinary usage of commercial products. Conclusion The waste management regulations are complex and a through understanding of them is required before an industry or business implements a major waste minimization program. If careful planning is conducted in the early stages of a comprehensive program the regulatory burden may be reduced. Also a thorough understanding of the regulations insures that maxi" environmental protection is achieved while also allowing an industry or business to save money, often substantial amounts, through a waste minimization program which includes recycling.

38.3 i Incentives and Regulatory Issues in Waste Reduct ion: Case Study Examp 7es Wi 7 7 iam S. Pitchford

The "1966 North Carolina Hazardous Waste Minimization Report" states that the main reascns hazardous waste generators seek to 3mprove their wastn ninimization programs is to reduce costs afid comply with regulation. These factors are closely linked ana often interdepenaent. For exampie, "complying wi7;h regulation" usually means avoiding costs such as fines 37 cleanups, and the "reduced costs" offered i;y a new piece of equipment may be balanced by the neea clor csstly regulat.zry oernits.

Searing this in mice, one shouia evaiuate potential waste minimiz2tion strategies by comoaring the potential cost savings of an ep+,ion with tr8e eppropriaze reguiatory changes; with the 90s: of implementing the ::~r-ra-,agy -+,172~ ~r.nccc?sthe 9c.s'; c~st.sa\/jr,,;s 2nd :h7e !S.EST; I?~:W ,- regu; atrJr:,{ ~ecu:rsxencs. j-i-,1s I-Jz.~31- x7 ,l s.re9jne LZS T""u?ar_.cyj/bY requirements of several common wiiste miniRizziticn strateg'es and discuss new regulatory issues that will aTfect future waste minimizatiGn efforts.

Eest A 7 ternat ive is Source Reduct ion

The best method of reducing reguyatory requirements and reaucing costs :s to base a waste minimization program en source reauction in tne form ~f process substltution. In ctner words, stoD generating fiazarc'ous wasre by substituting CGn-hazardous ingredients f9f nazardcLts ones. Examples r,f process substituticn include usins water- casea inks instead of solver~t-basedinks ana alkaline cleaccrs ir, place of soivsnts.

Process substitution may be The %st rnethcd of waste minimization, but ;t alsi; can be the most ciiffic~i~~c.It forces ane to redesign a proven Grccess wjthout sacrificing cr-scll-'c*LL cuality. 'It can also 5s 2. tim consurr,?~~process testing vzrioL;s prcducf fcr~ciztionsor of .- nanufzctur?ng ~rncessestic~;: a s;~;;:::essfu? ::~:zc~~iatu~onis rs--chec. of as hazardous waste. As disposal costs for the solvent became unacceptable, a search began for solvent substitutes. The first substitute for l,l,l,-trichloroethane involved use of a water soluble oil. Parts costed in this oil were then cleaned using an alkaline cleaner. This method significantly reduced the use of the solvent but caused deterioration of the stamping dies. Because of these effects, a new solution was needed. In order to dispense with the cleaning step altogether, the stamping process was reexamined. A new lubricant was selected which would take advantase of the next process step: annealing. The prcduct selected had the dual merits of being noncorrosive to the stamping dies and also could be burned off cleanly during the annealing cycle. This effectively eliminated the need fcr any cleaning step.

This is jusr, one example cf how a step by step approach tr, ;=recess substitution can proatice sisnificant and prcfi'tabie results. hamiltor! ?each iizs been able to rcdzce its gsneraticn of hazarzc~s:VZSLS 'rcrn 3~3rcy.j 1 y 2.3, :23.> lbs jn 1212 to apprcxim2~ejy ;3,CG,cr 15s jq '25,s. This rEornsents a rough COSL savings of $12,900.00 per year in disposal costs, raw material costs, and labor costs involved in the use of both l,l,l-trichloroethane and the alkaline cleaner.

Recycling of Process Streams One of the most common nethods of waste minimization is recycling hazardous waste streams. Some forms of recycling include: 1. In-process closed-loop recycling 2. Recycling through a waste excnange 3. Out-of-process recyc1ir.g

In-Process, Closed Loop !?ecvclincl In-precess, closed-loop recycIin9 can 50 ccmcared with sotirce reduction. Hazarczus wastes are recycled and returned tt\ the process without dver 1ezv.i::g 9 ciosea systsm cf piDing ana Isrccsss eauipmen~. ct~r exiimple! dry c'ieaning soivents are ~fcenrscia:med by in-line cistiilaLicn units and reused. This nethod 07 rec;/r?i:?g !s prefsrred since materials recycled ;n th:s manner are exempt from reguiation. Hwever: residues resulting frsm recycle, such ils 5cttcms or filters, bre sti:l sub>ect to resulation.

39.2 manufacturing process. No treatment, such as distillation, of the material before usage is allowed. Examples include the use of concentrated caustic solutions to neutralize acidic wastewaters and the use of spent freon in processes not requiring high purity material. Out of Process Recvclinq Out-of-process recycling usually involves the use of a batch distillation unit to recover solvents from a waste stream. The waste stream is collectec on-site until sufficient quantities are collected. The waste is then recycled, and the solvents reused with the still bcttcms being disposed of according to hazardous waste regulations. Regulation of this type of recycling is different from in-process recycling. Prior to being recycled, the solvent must be counted as a hazardous waste when determining the quantity of waste il facility generates in one mcnth (for determining generator status). tiowever, since the material may be recycled several times during the month it nesd only be ‘c3unted 3ns t;me. These rogu’atisns zre best exclained ’7 :he T’o!lcwjng ejcmpie:

Company A generates 300 Kgs of solvent waste per production run with typically 4 production runs per month for a total of 1200 Kgs of waste per month. This caused the company to be listed as a large quantity generator. After purchasing a reccvery still, the company would count the 300 Kgs only once durinG the month. This allcwed Company A to change their status to a smalf quantity generator.

New Regu7atory Issues Upcoming in Waste Minimization

One issue that will clearly affect future waste minimization efforts is the use of Mobile Treatmect ‘Jnits (MTU’s). YTU’s are devices or equipment, or combineticn of devices or equipmenc, thet treats hazsrdcus :t/astean6 t52t is desisned to he trzns?crted and ocerated at ~~~~~i&~c cf fdfs:s in^^^^^ dei,,ratsring e~ujpnc.r,t, -Gr5 Lh.2t7 oze s?te. incinerators, and distiilatjon ecjui~x~nes.The use of this eouipnent is ;+ell s~itedto s’sa cleanups but has a7so been advertised 2s the wests minimizetfcn mcwer for small Slensrators thzt cannot affcrd tc purchase this equipment cn their own.

However, serious cuast:ons ha.ie ~SB!-Irsi sed ever the regu7atzr-y requirements of sce:i ~citssizlcs trezrment cf a kzzardous wzste, in I -. the csnventicnai sense, reauires a F?C=f?A~erxl:t. Treatment is se~inea by 42 CF2 as “z~ymethcd, techniaue, or ~racess,inciuding neutral izet’sn, desifned to change thit physical, chemical, or b’olcgicai charzctsr cr ccz~cs

39.3 The requirement of a permit has caused a great deal of concern and controversy within the MTU industry and with state regulators. This is primarily a result of the cost associated with obtaining a RCRA Treatment permit and the time required to obtain one. The fact is many companies offering mobile treatment services have continued to treat hazardous waste because of ignorance of the law or lack of enforcement. The North Carolina Hazardous Waste Management Branch has received numerous questions regarding the use of this equipment. There has been particular interest in the use of portable sludge drying equipment.

A portable sludge dryer is used to remove excess water from a hazardous waste sludge. Volume reduction (dewatering) is clearly defined in the above definition as treatment. However, there are many examples of North Carolina companies that use a filter press and\or sludge dryer to dewater hazardous waste sludges. None of these units are currently permitted as XRA treatment facilities due to the exemption a1;Gwed under 40 CFR, 264.1. This Section exempts the treatment of wasc;ss managed in a wastewater trearcment unit regulated sf .. ;,, .- 1 $ iJ(icer sesr,j;;r, sd,,.- .,ai7 iv’ater Act cr..sviced these ijischrirges BTS sut3jecz to En NFDES permi’; c,r- to the pretreatnent stancaras of a lr,cal FOTW (Pub1icly Cwned Treatment Works).

A portable sludge dryer could be considered exempt from RCRA when it is used as an integral part of a permitted wastewater treatment unit. However, a RCRA treatment permit is required when dewatering is performed outside of a permitted wastewater treatment unit. For example: sludges removed from a wastewater treatment system and stored in drums or surface impcundments and subsequently dewatered would require a RCRA permlt since the dryer would not be an integral part of a wastewater treatment unit.

EPA has propcsea new stanaards fGr the use of mobils treatment unlts. These new regulations are designed LO allow MTU’s ro operate wirn mere freely by easing their permitt’ng Surdsn. Units would be required to Oi3tain sin5-te permit for a piece of equipment and updats Lhis permit at each site wnere it operaT;es. This vrould el:m?nate :!?.e ?roc.i?n of havins to cbrain a 3CRA treatment pernit a: eacn s-ite.

39.4 Leon M.Holt

Since the inception of its Industrial Waste Program in 1976, the City of Raleigh has been actively involved in the regulation of industrial and "nercial wastewater dischargers. The industrial Waste Program initially taryetd all industr ial users (IUS) that were discharging more than 50,000 gallons of wastewater per day. taryet value was in keeping with the pmvisions of the Gene Fwtreabent standards and allowed the City to better qualify the sources of wastewater being treated by the its publicly owned treabnmt work (FOIWs). currently the City has adopted a smaller discharge mtof 25,000 gallons per day as the criterion for a "significant industrial User. "

As hdustrial user discharye flm rate alone could not and should not be the only barmeter utilized by municipal errvironmental. personnel charged with the responsibility of protecting the integrity of the pcMw and its receiving stream, there was the clause in the General Pretreatment Standards (EPA) that included pollutant pass-through, inhibition and/or interference of the treabmt system, solids handling options limitations, and personal health/safety of the pcMw employees.

The City of Raleigh Encourages Waste Minimization, suggests 'Follution mention as Viable Alternative to Treamt

Realizing that cmpliance with local, state, and ultimately federal regulatory demands and limitations would be required, affected industrial users on the City wastewater disposal system began ' the feasibility of utilizing better environmental management practices. Such measures would lessen the dependency on &-of-pipe treatment through pollutant control. mct recovery fram mterials previously regarded as wastes and lower treamt costs would be realized.

several bldustripc and manufacturing processes on the Raleigh wastewater sysW have been assisted by the efforts of the N.C. Pollution Prevention Program. These include but are not limited to the following: printed circuit board manufacturers, metal heat treating operations, food processors/product manufacturers, autamotive repair shops, and radiator repair shops. Most of these industrial users benefitted frm the Pollution Prevention Program by identifying waste areas and were given suitable alternatives to reduce pollutant loading through waste "ization.

The City of Raleigh continues to utilize the broad fields of expertise and hodledge exhibited by the staff of the Pollution Frevention Prcgram. Through continued mutual cooperation between industry, ernriromtal regulatory agencies, and technical and monetary assistance organizations, the problem of increasing pollution fram manufacturing processes can be minimized.

coordinator, City of Raleigh Industrial Pretreatment Prq", P.O. Box 590, Raleigh, NC 27602

40.1 case Histories ~~~~nstratepotential of pollution Prevention In 1984, a food pmcessinS facility conn- to the City of Raleigh's waste collection and treatment system was paying extremely high monthly sewer sulcharges because of excess BOD and 'IS. The City introduced the company to the concept of waste mgement and called upon the N.C. Pollution Prevention Program's technically competent and process-familiar personnel to consult with plant management. subsequent meetings between Pollution prevention and plant staff and krmledgeable persons associated with waste minimization practices in this industry resulted in a prcduct recovery system that elhinates excess EOD and 23s and is saving the plant approximately $18,000 per year in surcharge fees.

After a regulatory visit fmm the N.C. Division of Ehvhnmental Management, a particular radiator rewir shop was issued a Notice of Violation for an illegal discharge to the surface waters of the state. 'Ihis action pranpted the facility to contact the city about a permanent sewer connection. A site inspection was perfod by the City and the assessment was made that, unless pretreatment of various wastewater streams was initiated, no connection and permit for discharge to the City could be issued. The Pollution Prevention program was contactd and after an initial waste audit had been performed, collaborated with the consulting firm that was retain& by the facility to formulate a pretreabent approach. The recycle of clarified water fram the batch treabent tank to the boillxlt tank saved the facility sevd hundred dollars per year in water consumption costs. In addition, the use of waste heat fmm the boil-out tank was utilized to augment the drying of hydroxide sludge generated in heavy metals re"al. Oil skinrming devices were employed in the treabent system to recover many gallons of oil (which was later sold to an oil recycler) fmm the oil/waste separator.

The heat treat- of ferrous metals had been resulting in the formation of cyanide- and oil-bearing waste streams from a facility on the City's collection and treatment system. The city, the pollution mention program, and the industrial user collaborated on research that led to the replacement of cyanide with a arbonate-dependent scheme. In addition, the deployment of a belt/squeqee oil skimmer from gum& waters resulted in the collection of oils. &npliance with City pretreatment program limitations was achieved.

Ele~tr~~latinq processes result in a significant amount of metal-bearing sludge as well as the potential for metal-bearing wastewater streams. Pollution Prevention was again requested by the City to conduct a waste audit of a facility experiencing problems in mahtahhg continued compliance with pretreatment program regulations. After review of affected processes, a thorough waste "ization scheme was presented to the facility. In the proposal were recammendations for hydraulic reduction, alternative eleCtroplathg techniques, and modified waste treatment practices. Reduction of loading to the existing pretreabent system by capturing the pollutant prior to its becaming waste was stressed. The use of gravity thickening had initially saved this facility hundreds of dollars in energy costs associated with electrically driven dewatering devices. Utilization of an intern fm the chemical Ehgineerh'q Department of North Carolha State University was an additional use of the available technical resources in the area.

40.2 Since the hption of its -ial Waste Program in 1976, the City of Raleigh has been actively involved in the regulation of industrial and Cammercial wastewater dischargers. The Lndustrial Waste Program initially taryeted all jndustrial users (IUS) that were discharging more than 50,000 gallons of wastewater per day. This taryet value was in keeping with the provisions of the General -treatment Standards and allowed the City to better qualify the sources of wastewater being treated by the its publicly owned treatmmt work (ms). currently the City has adopted a smaller discharge amount of 25,000 gallons per day as the criterion for a ttsignificantindustrial user. It

As industrial user discharge flm rate alone could not and should not be the only barmeter utilized by municipal envhmtal personnel chqed with the responsibility of protecting the integrity of the po?w and its receiving stream, there was the clause in the General Retreatment Standards (EPA) that included pollutant pass-through, inhibition and/or interference of the tr-tment system, solids options limitations, and persondl healwsafety of the Fo?w employees.

The City of Raleigh Encourages Waste Minimization, wests pollution mevention as viable Alternative to Treatment Realizing that compliance with local, state, and ultimately federal regulatory demands and limitations would be required, affected industrial users on the City wastewater disposal system began ’ the feasibility of utilizing better environmentdl management practices. such measures would lessen the dependency on end-of-pipe treatment through pollutant control. Mct recovery fmm materials previously regarded as wastes and lmer -bent costs would be realized.

several industr ies and manufacturing processes on the Raleigh wastewater system have been assisted by the efforts of the N.C. Pollution Prevention Program. These include but are not limited to the follming: printed circuit board manufacturers, metal heat treating operations, fccd processors/prcduct manufacturers, autmtive repair shops, and radiator repair shops. Most of these industrial users benefitted fmm the Pollution Prevention m-Ogram by identify- waste areas and were given suitable alternatives to reduce pollutant loading through waste minimization. The City of Raleigh continues to utilize the broad fields of expertise and knowledge exhibited by the staff of the pollution prevention Program. Through continued mutual moperation between industry, envirorirnental regulatory agencies, and technical and monetary assistance oryanizations, the problem of increasing pollution fmm manufacturing processes can be minimized.

coordinator, City of Raleigh Industrial Pretreatmat Prq”, P.O. Box 590, Raleigh, NC 27602

40. I case Histories Denronstrate potential of pollution Prevention

In 1984, a food 13rocessh facility connected to the City of Raleigh's waste collection and treatment system was paying extraly high monthly sewer surcharges because of excess BOD and TSS. The City introauced the company to the concept of waste management and called upn the N.C. Pollution Prevention Pr0gra"s technically cmpetent and pnx=ess-familiar personnel to consult with plant management. subsequent meetings between Pollution Prevention and plant staff and hxldgeable persons associated with waste minimization practices in this indusky result& in a prcduct recovery system that eliminates wcess B3D and ?-ss and is saving the plant appmximamy $18,000 per year in surcharge fees. After a regulatory visit from the N.C. Division of Eslvhnmental Management, a particular radiator remir shop was issued a Notice of Violation for an illegal discharge to the surface waters of the state. l%is action pmnpkd the facility to contact the City about a permanent sewer connection. A site hspection was perfow by the City and the assessment was made that, unless pretreatment of various wastewater streams was initiated, no comeion and pennit for discharge to the City could be issued. ?he pollution Prevention program was contacted and after an initial waste audit had been performed, collaborated with the consulting firm that was retained by the facility to formulate a pretreamt approach. 'ke recycle of clarified water frcnn the batch treatment tank to the boil-out tank saved the facility several hundred dollars per year in water consmption costs. In addition, the use of waste heat frcnn the boil-out tank was utilized to au-t the drying of hydroxide sludge generated in heavy metals removal. Oil skimming devices were employed in the treatment system to reaver many gallons of oil (wirich was later sold to an oil recycler) fmthe oil/waste separator. The heat treat% of ferrous metals had been resulting in the formation of cyanide- and oil-bearing waste streams from a facility on the City's collection and treatment system. 'Ihe City, the Pollution Prevention program, and the industrial user collaborated on research that led to the replacement of cyanide with a carbnate-dependent scheme. In addition, the deployment of a belt/sque.gee oil skimmer fmm quench waters resulted in the collection of oils. cmpliance with City pretreatmentprogram limitations was achieved.

Electrop latinq processes result in a significant amount of metal-bearing sludge as well as the potential for metal-bearing wastewater streams. Pollution Prevention was again requested by the City to corduct a waste audit of a facility e>rperiencing problems in maintaining continued compliance with pretreatment prcgram regulations. After review of affected processes, a thorough waste "ization scheme was presented to the facility. In the proposal were recommendations for hydraulic reduction, alternative elecrtroplatiq techniques, and modified waste treabent practices. Reduction of loading to the existing pretreatment system by capturing the pollutant prior to its becaming waste was stressed. The use of gravity thickening had initially saved this facility hundreds of dollars in energy costs associated with electrically driven dewatering devices. Utilization of an intern from the Chemical Engineer- Department of North Carolina State University was an additional use of the available technical resources in the area.

40.2 Conclusion: Through the efforts of the North Carolina Pollution prevention program, indiustrial wastewater streams to the City of Raleigh have been reduced. By reducing treatment load, the City has saved money, and by reducing their need for raw materials and waste treabmt and disposal, industries have realized cost savings.

40.3 , TECHNICAL APPROACHES TO WASTE REDUCTION Gregory J. Hol lod, Ph .D.1 I?. F. McCartneyZ

A better understanding of the dynamic interactions of chemicals and chemical by-products in the environment which began to develop in earnest in the 1960's, has since focused national attention on the management of hazardous waste. An early response to waste management was to attack the problem at the end of the pipe. Subsequently, attention has begun to shift toward minimizing the production of waste at its source. Today, it is generally agreed that minimization at the source is the most desirable, albeit often most difficult, way to reduce waste. Recognizing the need'for minimizing the generation of hazardous waste, the chemical industry is experiencing a surge in the initiation of programs for reducing such waste. Hith a new realization that the cost of handling waste may be many-fold higher than the value of the materials lost in it, generators need to examine a new end point for optimizing its processes--one that includes the total cost of waste management as well as the conventional cost elements such as raw materials, power and the like. Du Font has been cognizant of the importance of minimizing waste, and active in doing so, since it was founded in 1802. In the early days, managers and operators alike worked continually at making the manufacture of black powder cheaper and safer. It was readily recognized that the process waste was hazardous in a very immediate sense, and it was to everyone's advantage to keep it to a minimum. In 1980, the Company adopted a policy which stated that we intend to "minimize the generation of waste to the extent that it is technically and economically feasible". As the waste reduction effort matured through the '~O'S,we focused our attention on three essential areas of the program. First, the organizational and technical resources necessary to do the job; second, a defined target of waste to reduce; and third, a means for tracking performance. The responsi bi 1 i ties for the waste reduction committee was established at the highest level of the Company's Management, confirming its belief that the only way to get the job done is with commitment and leadership from the top. The positioning of the organization between senior management and actual plant operations demonstrates the need to include environmental activities within the line organization. Clearly, waste reduction cannot be a staff function, but must be integrated into the main line of the manufacturing units to protect the business. lEnvironmenta1 Services Group, E. I. du Pont de Nemours & Company, Inc. Technical Laboratory, Chambers Works, Deepwater, New Jersey 08023 (Presenter) 2Consultant Manager, E. I. du Pont de Nemours & Company, Inc. Engineering Department, P. 0. Box 6090, Newark, DE 19714-6090

41.1 The concept of waste reduction must become institutionalized to the point where it is a primary choice for action in any plan. Once the target of waste reduction has become ingrained within the entire organization, more progress will be made, especially by the business and product managers. ___ A target of waste reduction was selected and defined in 1984 and called "Du Pont Tabulated Haste". The definition categorizes the waste in accordance with the manner in which they are produced or are managed, which is obviously much broader and more encompassing than RCRA-defined waste, per se. It has particular advantages in that it provides a consistency across the Company so that all plants can work toward a common goal, and the performance of all can be compared equitably. As the business needs change and our waste reduction program develops, we may need to include still other wastes. The "Du Pont Tabulated Waste" definition targets those wastes most important for Du Pont to reduce. Once waste has been targeted and a program for reduction has been implemented, it then becomes important to track performance. Tracking the progress of waste reduction is no different than tracking any other production variable.

A tracking system can be used to identify waste-reduction opportunities which will ultimately lower operating cost and improve earnings. Such considerations as volume of waste, cost of handling, regulatory impact, product-1 i fe cycle, marketing opportunities and basic manufacturing processes can be factored intoan alogrithmic function and coupled with a tracking function to identify opportunities. The identification process would allow any business team to maximize the technical and capital resources available and direct them to the most needed part of the business to improve its overall performance. The author will present the Du Pont Company's approach to waste reduction. First, the organization and the definition of waste reduction will be reviewed. Then this will be followed by an outline of the tracking function used to measure, among other things, the 35% (wet wt. lb. wastellb product) waste reduction goal for 1990 compared to 1982 was generation.

41.2 WASTE MINIMIZATION AND RECYCLING OPPORTUNITIES IN A MULTIPURPOSE CHEMICAL MANUFACTURING PLANT William M. Archer1

Multipurpose chemical manufacturing plants generally offer a wide variety of opportunities for waste minimization and recycling. The Sandoz Chemicals Corporation, Mount Holly Plant, located near Charlotte, N. C., is such a facility. This plant has been a leading producer of sulfur dyes for over 50 years. More recently, manufacturing has diversified into production of chemicals for use by the pharmaceutical, electronics, polymer and agricultural industries. Recycling and waste minimization have been practiced at the facility for years but have gained a new emphasis supported by recent economic and regulatory changes. Pollution Prevention Has Been Paying For Years The manufacturing plant has been reclaiming hydrogen sulfide gas for over 20 years. Absorption of the H2S gas from manufacturing processes into a caustic solution produces a NaHS solution that is used back in manufacturing processes as a raw material. In 1987 over 150 tons of H2S werecaptured in this manner to produce raw materials worth approximately $90,000. The plant has also sold used acid for years as a replacement product for virgin acid. Sandoz uses sulfuric acid in manufacturing operations that becomes partially diluted with water during the processing. The resulting 80% acid cannot be reused in the original process but can be used by other industries in place of 98% sulfuric acid. Several thousand tons of acid are sold annually for such uses. Solvent recovery by distillation is not new. However, the efficiency of recovery has improved over the years. Sandoz implemented a solvent recovery process in 1986 that employs high vacuum and relatively high temperatures to recover and reuse approximately 2000 tons of xylene per year at about 9% total efficiency. In addition, a project is underway to find a replacement solvent for the xylene, such that still bottoms from this operation will no longer be classified as hazardous waste. Current Opportunities

Sandoz is continuing to identify and develop new recycling and waste minimization opportunities. In some instances waste recovery is an added benefit from projects that are initiated for other reasons. In one instance, a wastewater pretreatment process using carbon adsorption for removal of a phenolic compound was found to actually recover the compound in a usable form when the carbon was regenerated with caustic. In another instance, a project to improve the cycle time for a process resulted in energy recovery by preheating the next batch's charge with the exotherm energy from the prior batch.

Environmental Manager, Sandoz Chemicals Corp., Mount Holly Plant, P. 0. Box 669246, Charlotte, N. C. 28266

42.1 Several other projects have potentially significant economic returns but must overcome a number of obstacles before any of them can be implemented. One such project involves the elimination of a filtration residue that currently must be handled as a hazardous waste. Ideally, this waste could be completely eliminated by switching to other filtration technologies. Unfortunately, tremendous capital out1 ays would be required to replace existing equipment that still has usable life. Questions of maintaining product quality must a1 so be answered.

Two other projects involve efforts to develop a usable by-product from existing waste streams. Both projects represent interdisciplinary challenges involving marketing, chemical and process engineering participation to address nonhazardous waste minimization problems. In one instance, the current cost for disposal of the waste stream is not great, but the potential market value of the by-product could approach a million dollars annually. In the other instance, the market value of the potential by-product is only $15,000 annually, but carries a disposal cost of roughly $200,000 per year. In both cases, identifying existing markets and establishing product specifications are necessary prior to developing the technology to isolate the desired by-product. Capital and operating costs must then be evaluated to determine if by-product recovery is economically feasible.

While many of the obvious and easily implemented waste minimization and recycling projects have been completed, many opportunities still remain. To achieve continuing successes, imagination and innovation are needed to identify the potential opportunities, and a dedication of resources is necessary to overcome the hurdles these more complex projects will present.

42.2 Waste reduction ... Who can argue against the concept? Reducing waste in today's economic environment means increased productivity, lower environmental compliance cost, lower operating cost and a better profit margin, This practice has long been an integral part of our company's manufacturing management goals for the continuous improvement in productivity, quality and safety. This practice has been applied by many industries over the years. The 1970's was a decade that brought new challenges to the manufacturing and engineering community and an awareness of environmental concerns facing our nation. Industry faced rapid escalation of both energy and raw material cost that in most cases out-paced our ability to raise the cost of products. Environmental regulations were promulgated and enacted to minimize adverse impact on our air, water and land. Waste reduction during these changing times meant market competitiveness and stable profits.

The regulatory and legislative community first addressed this practice in 1976 when the EPA published it's preferred hierarchy for waste management and listed waste minimization as the top choice. In 1984, during the reauthorization of the Resource Conservation Recovery Act, Congress defined the desirability of waste minimization as a national policy, thus increasing the public's int rest in the chemical industries' measurable performance. f The reauthorization also mandated that all generators of hazardous waste certify that they have "a program in place to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be economically practicable." The EPA and the Office of Technology Assessment was requested to report to Congress in late 1986 as to the extent that Industry has and could reduce it's waste. It is important to understand the intent of Congress was, in affect, to reduce the amount of waste that was to be landfilled consistent with the "land ban" requirements. The EPA used the RCRA biennial report and contractors to evaluate progress that Industry has made. The .- reports differed in the assessment of progress and compliance of Industry. The EPA believed that companies had made satisfactory progress in waste minimization and after the implementation of the "land bans" further reductions would occur as economic incentives. The OTA, however, believes very little has been accomplished and without attention by both the EPA and Congress the full value of waste reduction will not be realized. It is important to understand one fundamental difference in both reports which is definition. The EPA uses the term waste minimization which

Em "id USA, 2030 Willard H. DGW Ctr., Midland, MI 48674

43.1 includes recycle and some forms of treatment that reduces the volume and toxicity of waste that have already been produced. The OTA uses the term source reduction that focused solely on avoidance of waste production. Even with the vast difference in definition it was a common belief by both organizations that the available data was insufficient at this time to develop a legislative or regulatory mandate.

PROGRAM

Any program, if it is to be successful, will contain the following common elements:

Management support Goals Participant identification Procedural guidelines Measurement tools to track and report progress Recognition of excellence

Management support is paramount for program success. Support for our company's program was accomplished through specifying waste reduction as the first priority in both the corporate environmental policy and in the U.S. Area waste management guidelines. These policies and guidelines were established years before a formal waste reduction program was developed under the name WRAP (Waste Reduction Always Pays).

WRAP is a long-term plan to formalize our past, present and future efforts in a form that can be used to establish our progress and future directions. The goals of the program are to reduce waste to the environment, provide incentives for waste reduction projects, provide recognition for those who excel in waste reduction and re-emphasize the need for continuous improvement by recognizing opportunities in waste reduction. By actively pursuing waste reduction opportunities, our waste management cost will be reduced, improve operations productivity, demonstrate to the public our commitment to environmental protection and as a mechanism for advocacy support that a voluntary program of waste reduction can work without government oversight.

The program has two main objectives from the U.S. Area perspective: 1. data base for tracking progress, 2. a compendium of projects implemented or proposed that reduces waste. Specific details of the objectives are:

1. Data base requires that each plant should develop an inventory of 811 process losses to the environment (air, water and solids). This inventory should be both quantitative and qualitative and source specific. These losses should then be a ratio of production rates to account for production variances and

43.2 allow for calculating a weighted average for each division. This waste index (#waste/#product) can then be tracked and evaluated by each site at some frequency.

2. Projects that qualify must have a measurable reduction of waste to the environment. The projects can be capital, maintenance or operational/administrative changes. It would be preferable for these projects to save money (including avoided cost) where possible but, some projects may not have a ROI that can be quantified. The use of a form to document projects was instituted. The reason this type of documentation was encouraged is due to the many improvements that can occur within the process area that require no capital and would otherwise go unrecognized. This will also assist in advocacy support of operations, as states become more active in this area of concern.

Division implementation and recognition has varied due to the diverse product lines, age of the operations, resource availability and present stage of emission inventory. Each production facility is evaluating losses and developing action plans. Those include the following: inventorying all process losses to air, water and land, identify sources, prioritize, quantify losses and ratio to production, evaluate environmental impact and risk, set action priorities, determine cost effective actions, set reduction goals, determine resources necessary to accomplish goals, track and communicate performance and plan for future reductions. By applying these action plans, facilitator can evaluate the right operation to work on; the right areas of these operations are identified and proper planning and allocation of resources can be accomplished. In most cases the 80/20 rule applies, i.e. 80% of the opportunities for economical reduction will be found in 20% of the operations.

Within our program it is recognized that waste reduction is not a panacea for waste management. Waste is a sign of life and like all living things as long as there is manufacturing there will be some waste. Safe and permanent waste management, compliance with state and federal laws and environmental protection are still top priorities and must be balanced with waste reduction efforts. Process assessment, research and modification take time and resources. During this evaluation phase, waste management will still be a critical part of our overall objectives.

PRACTICE

Before putting our program in practice to yield a product, definition of the practice is required. Waste reduction has been defined as:

33.3 o Any in-plant practice or process that avoids, eliminates or reduces waste so as to reduce environmental risk to any media.

o The treatment, reuse or recycle of any material which reduces the volume and/or toxicity of waste prior to final disposition.

General practices used to reduce waste are: o Improved raw material purity o Raw material substitution o Improved instrumentation/computer control o On stream analyzers o Process analysis by statistical methods o Improved sampling techniques o Predictive, preventative maintenance programs o Modify operating procedures/parameters o Catalyst improvements

These practices can be as simple as housekeeping or as sophisticated as complete process redesign. Continuous evaluation of the process and results of reduction efforts will help decide the most cost effective practice.

PRODUCT (2)

Using the practices outlined, DOW'S Louisiana Division, which is a large and diversified manufacturing division, has demonstrated over the past ten years an increase in production and subsequent decrease in emission and discharge to the environment.

As the graphs indicate (Figures 1, 2, and 3), production increased from approximately 8 billion pounds/year to 12 billion pounds/year. During this same period of time, they reduced hydrocarbon emission by 92%, and chlorinated hydrocarbon discharges to the water by 98%.

Dow's Texas Division also realized similar results.

A typical hydrocarbon plant uses vent condensing and recovery, closed loop cooling systems, incineration and recycle and reuse to reduce losses to the environment (Figure 4).

Specific examples of waste reduction and results are:

Agricultural chemical business has made significant reductions in contaminated container volumes by working with contract packagers.

DURSBAN 50W, a wetable powder insecticide widely used in the landscape maintenance and horticulture business, was sold in

43.4 2 pound metal cans which required decontamination prior to disposal. This water soluble powder is very dusty and posed a significant exposure potential by inhalation and skin contact if not used properly. We now package this product in 4 ounce water soluble packages. The overpacking material can be disposed of as any household waste.

Another example of waste reduction is the shipment of an activated ingredient for use in an insecticide formulation. This ingredient was being shipped in 55 gallon metal drums that had to be decontaminated and crushed before disposal. This product is now shipped in tank cars. When these tank cars require cleaning they are decontaminated with a solvent used in the formulation of the activated ingredient.

One production facility investigated ways to reduce the amount of effluent leaving a crude product drying system (Figure 5). The drying agent is a purchased item and the production staff recognized the value of reducing both the environmental impact as well as cost reduction.

Initially, operations manually added the drying agent based on production with a standard minimum flow. Samples were run 6 times per day with an average sample volume of 3 gallons/day.

Engineering and production developed a scheme that allowed the computer to ratio the drying agent addition based on feed flow (feed forward) and an on-stream analyzer was added to replace lab analysis and reset the ratio to a minimum (feed back).

The results of this project were immediate in both waste and cost reduction. A measured reduction of 37% in effluent volume and a corresponding reduction in purchased material cost was realized. The ROI of this project including manpower was 67%.

Figure 6 is an example of a chlorinated hydrocarbon process that used process condition changes anti recycle to reduce waste and profitability. This reduction was accomplished in three phases over a 2-1/2 year period. - PHASE I

Changing operating temperature on condensing column bottoms and subsequent shift in solubility of chlorinated hydrocarbon resulted in reduction of 30% chlorinated hydrocarbon volume in effluent.

- PHASE I1

Addition of a residence time reactor ("bump in line") and heat further reduced chlorinated hydrocarbon volume by 90%.

43.5 - PHASE I11

Addition of a post reactor stripper reduced chlorinated hydrocarbon volume 99.9% of PHASE I1 levels. Quality of effluent suitable for use in other production facilities.

- The plant realized a 2% carbon yield increase for all three phases and a 99.999% chlorinated hydrocarbon reduction in effluent.

- Project ROI (overall) 40%

The last example presented (Figure 7) came about through an investment in personnel. First, quality improvements in this process was a result of the application of simple statistical tools (Pareto charts, histograms, X and R charts). Application of these tools resulted in a first quality improvement by identifying and solving problems within the process and reducing off spec product that had to be treated by 4 million pounds/year. This investment in personnel resulted in additional profits of $100,000.

There are many more examples of waste minimization success. Companies should be encouraged to investigate the opportunities within their organizations to reduce waste and increase profit. Hopefully one or all of the techniques presented here can be of useful in achieving these goals.

REFERENCES

(1) Hazardous and Solid Waste Amendment of 1984, House of Representative Report 98-1133, October 3, 1984

(2) Delcambre, P. R., Fourth Annual Hazardous Material Management Conference, TCMC, 1986, pp. 602-609

43.6 14

B i 10 1 1 i 0 8 n S P u 7 6 Y r . 4

0 1970 1972 1974 1976 1978 1980 1982 1984 Year Figure 1. DIVISION TOTAL- PROMJCTION

I U H

43.8 43.9 Vent Incineration > With Heat Recovery 99.99% Destruction Efficiency

> Purified Raw -> I Hydrocarbon Product Materials -> Organic Recycle Incineration -> Process 99.99% By-products - Destruction

Figure 4. PROCESS PLANT WITH INCINERATION AND RECYCLE/REUSE ADDITION

43.19 Crude Product 1 Drying Agent <

Wet Crude Product >

* Effluent

nitial effluent was 16# product/# effluent

.. Computer control of feed to drying agent .. On-stream analysis of control parameters inal effluent was 21.99# product/# effluent or 37% effluent waste eduction and sample volume reduced from 3 gallon/day to "0".

.O.I. of this project was 67%.

ure 5. SOURCE REDUCTION -- COMPUTER CONTROL

43.11 < Crude Product Condensing > Column < Water Vapor Acid Adlilcmal Water, Acid Residence PHASE I1 > IR-C1 ' s Reactor c

Water, Acid Trace R-Cl's Post > Reaction PHASE I11 Stripper

Figure 6. SOURCE REDUCTION -- RECYCLE PROCESS MODIFICATION

43.12 QUALITY IMPROVEMENT

Meets production specs 95.1m#/yr > Reprocess/blend l.Om#/yr 100 MM#/yr Product >

Out of spec reprocess tank 1.3MM#/yr

Off Spec Product 4.9 m#/yr <-

95.1% 1st Quality Level

99.1MM#/yr > 0 m#/yr 100 MM#/yr Product Cut/recycle 0.9m#/yr 1 0 m#/yr 0.9 m#/yr -

99.1% 1st Quality With 4% Quality Improvement

Assumed manufacturing cost of product = $0.10 with a return on sales of 25%

Value of product manufactured = $0.10/# x 4MM#/yr = $400,00O/yr

Sales at .0125 = $0.125/# x 4MM#/yr = $500,00O/yr

j 100,000 prof it

Figure 7. SOURCE REDUCTION -- EMPLOYEE TRAINING/STATISTICAL METHODS

43.13

WATER BASED INKS IN REXOGRAFHIC PRINTING HIGH SL IP fmYEHlXENE FlLW

George A. Makrauerl

Thls presentation describes the efforts, diff iculties, and successes of Amko Plastics Inc. in converting their flexographic printing operations from alcohol based inks to water based inks for printing on I cw dens1 ty pol yethy I ene f i I ms.

Flexographic Printing - Background Information Flexographic printing is the primary printing process used in decorating polyethylene films. It is a method of rotary letterpress printing using flexlble printlng plates and fluid Inks. The inks traditionally used in printing polyethylene films are alcohol solvent, polyamide resin based, The resin is a sol id organic material dissolved in solvent to become the vehicle which carries and binds the pigment and other ink additives to the printed substrate. During the printing process Itself, alcohol (usually ethyl or n-propyl) is added to the printing ink on press to control both its color strength and processing properties.

Traditional Preference for Alcohol Based Inks Alcohol solvent inks have been used for printing polyethylene fllms for three major reasons: 1. The surface of the polyethylene must be uniformly wetted. Otherwise visual qual ily suffers frcm streaking, pin-hol ing, and variegated color. Alcohol readily achieves uniform wett I ng, 2. During flexographlc printing, the inks must dry immediately after appl ication to the substrate. Inadequate drying adversely affects finished print qual ity and retards production rates. Alcohol dries at a fast rate. 3. Ink sol ids are readily resoluble in alcohol. Poor resolubll ity negatively affects print qual ity and the downtime required for press wash-up.

1. President and Chief Executive Officer, hko Plastics Inc., 12025 Tr icon Road, Ci ncl nnati, Oh io 45246-1 792

44.1 Major Production RobIsms Enmuntered Unlform Wettlng of Film Not Achievable Low denslty polyethylene is manufactured wfth a I1sI ip addltive" to al I ow the f 1 I m sufaces to SI ide freely over each other. Without the SI ip addltlve, low density polyethylene has a high coefficient of frlctlon (from 0.6 to 1.0). It Is so high that the film surfaces severely stick together. (Note: This applies only to low denslty polyethylene. Hlgh denslty polyethylene has an inherently low coefflclent of surface frlctlon and does not requlre the additlon of sl ip addltlves.) A low coefflclent of frlction (0.1 to 0.15) between film surfaces Is req u I red for two reasons: 1. Fllm handl lng characterlstlcs are optimized during al I manuf actur lng processes (thereby prov fdlng ef f iciencles and corn pet 1 ti ve costs) 2. Easy customer use, handl lng, loading and emptying of the finished bags is achieved. The sl lp add1 tive is ei ther erucamid or oleamide, an oi ly material homogenlzed throughout the film when it Is manufactured. The I1sI lprl blooms to the surface of the f llm after the f 1 Im leaves the extruder. Effectively, a mlcroscopical ly thln layer of oil Is present on the polyethylene surface. In order for the Ink to uniformly wet the pol yethy I ene surface, the ink must compl etel y cut through the surface coatlng of sl ip. Slnce alcohol and the sl ip addltive are miscible, alcohol inks cut through the SI lp wlth ease and uniformly wet the fllm surface. Water inks do not easily cut the SI lp , since water and of I are lmmlscible. Thorough wetting of the polyethylene film surface was not unlformly achievable. As a result, generation of scrap fllm and Ink increased by 40s.

Press Speeds Dropped Preclpltously

Polyethylene Is non-absorbent, unl ike a paper substrate. Drying ink on polyethylene is who1 ly dependent upon the evaporation of the I iquid portion of the ink. Differences In the thermodynamics of evaporating water versus alcohol yielded slgnif lcant problems. Alcohol inks drled at rates that satisf led production and qual Ity objectives; press speeds ranged from 500 to 700 feet per mlnute. When printing with water inks commenced, press speeds tumbled to 160 to 200 feet per minute. Amko's printlng production capacity was cut by almost two-th i rds.

44.2 Qual Ity Problans Increased Drunatlcal Jy

Solving production problems In the pursuit of compl lance was not the oqly chal lenge. Amko al so had to be able to satisfy Its custaners' continual ly increasing demands for qual lty, servlce and del ivery throughout the trans 1 t ion period. Unf ortunatel y, the early water based Inks were rlfe with problems Including low color strength, poor g I oss, poor adhes 1 on, poor dry i ng, 1 nadeq uate wet-rub res1stance, and inadequate dry-rub res1stance.

lmplanentlng the Conversion to Water Based Inks

The Inltial trial and production runs of water based inks revealed that modlf led, If not completely new, Ink formulatlons, prlntlng press equipment, operating practices, and polyethylene f llm characterlstlcs would be essential to the successful use of water based lnks. Amko's initlal evaluatlons led to the bel ief that most (perhaps 85% to 90%) of the new technol ogy and developmental effort woul d be concentrated on ink formulations. The smat ler balance of effort would deal wlth eq u i pment and pol ythy lene f 1 I ms. As the conversion program unf ol ded, however, it became clear that lnk issues were only 50% of the issue. Equipment, f 1 Im, and f 1 Im additives were equal ly important as Ink. More people and f lnancial resources were poured Into the project.

Ink Systaas, Formul atlons, and Techno1 ogy

As I ate as mld-1986, as reported to Amko by many ink manufacturers and several ink resin producers, no strong commltment nor aggresslve act 1 v 1 ty 1 n bas1 c chem 1 stry research and devel opment had been mounted to achieve success in uslng water based lnks to print polyethylene f i Ims. The ink companies and thelr suppl Iers dld not feel sufflclent Industry-wide demand exlsted to justlfy a commitment of money and other resources to new baslc R8D. As a result, the only water based lnks that were avallable for experlmentatlon and use In productlon were modif lcations of existing technologles.

Res i n producers and 1 nk manufacturers consi der the1 r new technol ogi es to be proprietary. Technical details of resin and ink formulation are not avallsble for disclosure. But, it can be dtsclosed in general terms that progress and/or on-press experimentation have been made wlth the fol Iowlng: 1. New generations of acrylic lnks 2. Polytmide water lnks 3. llCanbinationtr acryl lc/polymide water inks 4. Catalytic resin water inks

44.3 Amko's experlmentatlon wlth all of these ink systems requlred a large expenditure involving people, press tlme, f llm, Inks, solvents, printing plates, and contrlbutlons from Its extrusion and bag making de partment s.

Printfng Press WlfIcatlons

Drylng Systans

To dry the prlnted Ink, heated air 1s directed onto the printed fllm from drier heads posltioned between successive color prlnt stations and from an oven after the f inal cot or print station. Slnce water based inks dry more slowly than alcohol based Inks, greater drylng capabil ity is requlred for water. That capabil iiy 1s comprised of 1) alr volume onto and away frun the prlnted fllm, 2) alr velocity as the alr lmplnges the printed fllm, and 3) the amount of heat in that alr. Experlmental press runs showed that air volume and air velocity were more important for drying than was the amount of heat. As a result of those f lndlngs, air blowers, plenums and dryer hoods were redeslgned, and new ones were instal led on al I presses.

Ink Metering Systems

The ink meterlng system on each prlnt station transfers ink frun the stationls Ink fountaln to the prlnting plate for appl icatlon to the substrate. A f lexographlc lnk metering system is composed of two rol lers, a fountaln rol I and an Anilox rot 1. huntaln RQL The fountain rol I transfers lnk fran the Ink fountain to the An1 lox rol 1. It 1s a soft surface (rubber or plastlc) rol 1 of smooth face which runs in dlrect contact agalnst the An1 lox rol 1.

Ani lox Rol I, The An1 lox rot I transfers ink frun the fountaln rot I to the printing plate. It 1s a hard surface roll covered wlth mlllions of uniformly shaped depressions or cel Is which are filled with and carry most of the ink. The cells are of one shape or another (quadrahel lcal, lnverted pyramid, other). Cel Is are regul arl y spaced, in a range of denslty between 160 to 550 cel Is per inch I inearly and circumferential ly on the rol 1. Cel Is are either mechanical ly, electronical ly, or laser engraved on the rot I surface. Traditional An1 lox rot Is have metal surfaces which are chrane plated.

44.4 Increased Pr I ntI ng Press Repa I r and Ma I ntenance

Ynant 1 c1 gated I ncreasg-1 n Ani I ox Rol I Wear, W Ith greater use of water based 1 nks, an new probl em developed and reccurred in the ink metering systems. Due to the greater chemical and mechanical abrasiveness of water based inks compared to alcohol based inks, the chrome Anilox rol iers wore out considerably faster. As Anilox rolls wear down, ink I ay-down inconsistencies and appearance qual ity prob I ems become obv 1 ous. When pr i nti ng w I th al coho1 based inks, the wear life of a metal Anilox roll was approximately a year. After sw itching to water based inks, wear I lfe dropped to approximately one week. It became too expensive to re-chrome them weekly. And, frequent removal and replacement of these rol Is incurred signlf icant mal ntenance downtime and associated add1 tional costs.

-JlSurfeguf red, A new type of Ani lox rol 1 had been introduced to the Industry. It was coated with a ceramic surface, not chromed metal, and its cel Is were laser engraved. A trial rol I was instal led for evaluation. That ceramic Anllox rol I ran without any notlceable deterloratlon for more than two months.

AI I metal Anilox rol Is were replaced with cermlc rol Is. The cost was impressive. A new metal rol I cost approximately $1,400. Each ceranic rol I, however, cost $4,900 pl us freight and instal lation. Although ceramic rol Is cost as much as three and one half times the metal anilox rol Is, the higher cost was justified by its extended I ife, the decrease in downtime, and the consistency of print quality. hko's first ceramic roll was installed in April 1985. It is still (first quarter 1987) In use and is operating at satisfactory qual ity and production standards.

YnanfldpaicsLhicrease in Fountain Rol I We& The harder surface ceramic Ani lox rol I, however, had an increased wearing effect on the rubber fountai n rol I s. These rubber rol 1 s had to be resurfaced more frequent I y than before.

Polyethylene Fl Im Extrusion Modif lcations Required Slip Addltlve Content Control Is Essential

The high SI ip levels required for efficient processabil ity and ease In product end-use created major problems In printing with water based inks. High quality, high speed printing with water ink requires that the amount of SI Ip on the surface be reduced to the bare minlmum.

44.5 In order to minimize the amount of SI ip that blooms to the surface, Amko had to develop systems and equipment to inversely vary the percentage of SI ip additive with the film thickness being extruded: as fi Im thickness increased, the percentage of SI ip additive had to decrease. Amko learned that precise control of SI ip levels is crucial In making a success of the conversion from alcohol to water based inks. Amko believes it could not have achieved the results it has, without having had an in-house abii i?y to control the characteristics of its own f llm requirements.

Surface Tension of Polyethylene FIlm Must Be Increased

The surface tension of extruded low density polyethylene is in the range of 32 to 33 dynes per centimeter. Printing with alcohol based inks requires a surface tension of fran 37 to 38 dynes per centimeter. This increase Is achieved by corona treating the surface as the film cools on the extruder tower. For satisfactory ink wetting and adhesion, water based fnks require a higher surface tension of at least 42 dynes. New, larger, and more expensive treating systems were instal led to produce sufficient treat at the previously establ ished extruder output rates.

Although not a part of Amko's practice, some printers operate a film treating system in-I ine with a press unwind system to boost surface treatment to sat i sf actory I eve1 s. hinting Plate litaterlals

Printing plates are affixed to plate cylinders in a fllm flexographic press us1 ng sheets of double 'sticky-back' adhesive. "Impression" in flexographic printing is the term indicating the pressure of the inked pr i nting pl ate agai nst the pr 1 nted substrate. Water based 1 nks require a noticeably greater amount of impression for uniform f ilm wetting and transfer of ink from the plate to the film. This additional pressure Is best compensated for by using a foam 'sticky-back' to provide cushioning while securing the plate to the cy I inder i n the press.

Different printing plate materials render different results in pr intabi I ity. Traditional natural rubber plates transfer water inks excellently. Until late 1987, Amko did not have access to a photopolymer plate that performed as satisfactorily. Final ly in late 1987, DuPont's new 'PLS' grade of Gyre1 plate was tested and found to perform excel lently.

44.6 Poor Resol ubl I 1iy of Water Based Ink Generates Rob1ems Press Downtime, Scrap, and Labor Costs Increase

Water based Ink sol ids are more d fflcult to redissolve in water based Inks than are alcohol ink sol ids in alcohol Inks. Therefore, a cohol ink sol ids which accumulate on pr ntlng plate edges during press stops quickly redlssolve when an alcohol press run is recommenced. Alcohol ink sol ids which accumulate on press rot lers and parts during a press run are easily removed w Ith cleaning solvents during press wash-up perlods. The opposite is true for water based lnks. As a result, add iti onai downtime is requl red for the extra efforts necessary both to clean plates durlng a press run and to wash-up press parts during wash-up periods. Further, as water based ink sol ids accummulate around the plate edges during a run, print qual ity suffers until the press is stopped and the plates cleaned.

After a press run is completed, It is essential the rolls, pans, and pumps be cleaned Immediately and thoroughly, before any sol ids can fully dry on them. Ink which has dried must be removed with a special detergent, brass brushes, and cons1 derabl e el bow-grease. Housekeepl ng maintenance costs are increased as more downtime and labor are required. A major asslst In clean-up Is provided by the use of a I iquid composed of the mixture of 280 Ibs water, 20 Ibs isopropyl a1 cohol , and 20 I bs tr Isod1 um phosphate.

Benef Its of Rfntlng with Water Based Inks

The primary benefits of printing with water based Ink are that a printer can continue to operate his business, and he can do so in compl lance with EPA regulatons. There are other operational adv antages.

Color Control

As the technology and performance of water based inks have improved, advantages in printing have resulted. One re1 ates to color control. The intensity of the printed color varies directly with the viscosity of the Ink. During the printing process, the agitation of the ink in the fountain, the flow of ink through the pumping system, and the appl ication of ink to the substrate stimulate I iquid evaporation. As evaporation occurs, the ink's viscosity increases, and print color intensifies. Control of the color, then, is dependent upon monitoring the ink! s vlscosity and adding I iquid (water or alcohol 1 through the ink pump to bring the viscosity back down to the correct value.

44.7 Because water evaporates more slowly than alcohol, vlscosity change due to evaporation takes place more slowly. Wlth smal ler vlscoslty f I uctuat ion, it is easier to hold conslstent color throughout a press run of water based Ink.

Yield Economy

Water based inks have greater coverage yield than alcohol based inks. If a water ink color and an alcohol ink color cost the same per pound, the water ink w I I I have better coverage econuny. Although the cost per pound of some water inks Is higher than alcohol Inks, the cost margin is generally less than the increased yield and a final ink cost advantage ex1 sts.

Also, slnce the primary reducing ttsolventtt In water based Ink is water, and since water costs less than alcohol, addftional cost savl ngs are incurred through the decreased usage of al cohol sol vent.

Pressroam Air Qual ity

A most noticeable benefit Amko experienced was the overal I Improvement In worklng conditions in Its PrIntIng Department. Due to the drastic reduction of alcohol solvent vapors, there Is a notlceable Improvement in the qual ity of ambient press roan air. And, that Is, after al I, consistent with the origlnal objective of the Clean Alr Act.

Production Sucaess Ach ieved To-Date

As a result of the new technotogles developed by Amko and Its suppl iers, Amko Is now able to print high qual ity multi-color graphics at speeds up to 600 to 700 feet per minute on a daily production basis. Amko's latest press, instal led in operation In December 1987, was specif ical ly designed to run water based Inks exclusively. Productlon runs up to 970 feet per minute are regularly achieved. Those speeds running water generally match those being run with al cohol Inks prior to the conversion program. AI I the modif ications and new systems added to the presses have el fminated most of the early equlpment related problems Amko experienced when It flrst converted to water based Inks.

44.8 WaJor Goals Yet to Accanpl Ish Although Amko has succeeded in converting to water based inks, It continues to have three objectives to attain: 1. Many water based inks currently avai I able continue to be inferior to alcohol based inks in drying speed. 2. Some water based inks have laver gloss levels than alcohol based inks.

3. Amko continues to experience increased costs as a result of sl wer speeds, more down-time and increased scrap rates. The problems Amko faces today are not related to technological devel opment, per se. Rather, they ref I ect uneven enforcement of CI ean Ai r Act regul ations. State and I oca1 I aws and regul at ions vary considerably in their stringency from state to state. Consistency would clearly force continuing development of new technology and nationwide Industry compl iance at a timely rate. Amko PI astics Inc. has demonstrated that water based inks do work on high si ip, low density polyethylene f I Ims. However, the long-term success of Amko' s program and, indeed, al I techno1 ogy-forcl ng programs, can only be achieved as more participants - printers, ink companies, ink resin producers, polyethylene producers, and additive manufacturers - actively stimulate and maintain their interest In additional research, development, and implementation of new technology. Amko believes the participants will make and fulfill those commitments If there is either a rewarding gain for doing so or a uniformly imposed penalty for not going forward toward ccinpl lance.

44.9 \ Rexbm Corpration‘s Lndustrial Division is a coater/laminator of various high technology pro3ucts for major p;merican companies. Prduction of these Pm- =w==’ the use of solvent-based coatiqs, same using water-based technology, 0th- us- organic solvent-bas€d technolq. use of these systems requires the handling of air emissions as well as hazardous waste generated fram the pmsoperations.

?tJo metha employed to redhlce the impact of emissions and hazardous waste on the operations- of Rexh“s Industrial Division are discussed tf-iis presentation. In both cases, the reducecl cost of dealing with waste materials has resulted in substantial savings to the division along with reduced liability for W dispsal.

the of CCMthg-- aperatiOnS are the waste coat- solutions ana b& ClElnUp solutions. In xlost cases, these solutions are relatively high in solvents and lm in solids, this being particularly true for the Waste cleanup solutions. Noting that the cost of disposal of such wastes is significant and likely to get higher in the future, it is reasonable to look for means to reduce the quantity that leaves the facility. It is also reasonable to return to the process any chemicals that can be reused if they can be reprocessed to meet specifications for a particular need. After reviewing the ptatial for coating and claw waste reduction, Rexh”s Irdustrial Division embarked on a project to reclaim solvmts fram waste solutions. Technologies were reviewed an3 sinp3le distillation was found to be best suited to the needs of the operations. specifically, the project was aim3 at tdl5.q unusable coating solutions and waste cleanup solutions and distilling out the methyl ethyl ketone component for reuse as a washup solvent.

’ An authorization was mde to purchase a Finish Engineerbq Carpmy Mdel 360 distillation Unit. The unit was installed in the Matthews facility in the faurth quarkr of 1985. Dxitial operation hqan 1986. The Cost of purchase - and installation was appr”ately $75,000.

Ixlring the course of the first year of operation, 24,414 gallons of unusable Coating solution and waste cleanup solvent were run through the unit. A solvent containing approxbately 90% methyl ethyl ketone was produd. The remaining carpnents were other her-boiling-pint solvents that were found in various Coating mixes. No specific effort was mde to prodtuce absolutely pure ~ methyl ethyl ketone. The requirements for washup solvent were that it be cmptible with current and anticipated product ckanup ne.

Manager, Safety and Ebviromtal Affairs, Rexfiam Corp., P.O. Box 368, Matthem, N.C. 28106 (704) 847-9171

45.1 Fram the 24,414 gallons processed, some 15,415 gallons of good material were created. The remaining still bottams, sane 7,000 gallons of waste, were handled through our hazardous waste management program and sent off-site for thdoxidation. This resulted in a reduction of waste of approximtely 71.3%.

Wing 1987, the process was continued and the follmhg amounts of unusable coat- solution and waste cleanup solution were handled:

33,756 gallons - waste input hto still 11,541 gallons - Still bottams

22,175 gallons - good material

65.7 percent waste reduction

In relation to the initial cost of the Unit, the payback period using cost of alternative disposal and cost of equivalent washup solution was found to be approximately 13 months. This is a conservative estkte since he used cost figures fmthe bqinning of 1986, which increased substantially during the year. The Unit has run successfully since 1986 with “I problans. No major perfor”=e problems were nated other than those which could be attributed to normdl wear and tear on the unit. The project was successful and resulted in the installation of a similar unit at the lancaste.r facility of Rexha”s Industrial Division in 1987. Figures are prelbrhaq, but the Lancaster unit appears to be creating a similar product with similar payback potential. Emissions re used to ~roductsteam Another project authorized by Rexb“s Industrial Division was to evaluate the use of waste solvents from carbon bed absorption as a fuel for steam production in the on-site boiler. As part of the air pollution abatement program for the site, both thermal incineration and carbon bed absorption are utilized. The &n bed system generated solvents which for a number of years had been sold into the secondary chemical markets. Principally, this included the paint thinner and other similar applications. Hmever, the lnarket for the secondary chemicals produced was not consistent. Additionally, the chemicals frum the carfxln absorption system were not adequate by specification to be remin the process or for other less critical on-site uses.

carbon bed absorption uses large amounts of steam as part of the ~~ operation of the unit. ‘kis steam was created in an on-site boiler system fired by natural gas with curtailment operations requiring the use of #2 fuel oil. Under this project, evaluation was made as to whether the solvent fran the carbon bed system could be utilized in place of the traditional fuels. Authorization was sought for funding this project. In the project, funding was sought for piping and boiler modifications to allm routine use of

45.2 the solvents in place of other fuels. Hmever, in the event of solvent needs and/or sales, the Unit could be easily converted to the traditional fuel system. This would permit opthal usage of fuels as they were available with continuous operation of the prccess.

Work was ccrmpleted in early fourth gUarter, 1987. Costs totaled approximately $27,000. Air pollution testing was conducted and the operation was found to be burning the solvent at 99.9% efficiency. Noting usage rates of carbon bed solvents when compared to previous operations under traditional fuels, the boiler is expectd to save approximately $150,000 per year in traditional fuels. It should be noted that inventories of carbon bed solvents my not mtch exactly boiler needs so an esthted $15,000 in traditional fuels is apected to be needed during 1988.

As can be seen, paw& is a relatively short 2.2 months. It is also important to note that steam being generated goes directly back into the carbon bed absorption system to create good air-pollution control needed for environmental control.

su(~~na~y:no projects outlined in this presentation represent good applications of engineering technology to meet facility requirements. The results have been redud needs of outside resources with the better utilization of in-house resources along with rduction in waste generated which had to be handled through off-site disposal methods. project costs were managed to keep payback periods acceptable with good long-term outlooks on continued cost reduction. Simply, it is god ideas requiring reasonable capital irrVeStment which produce god and consistent returns to the organization.

...

45.3

SOLVENT RECOVERY FROM FLEXOGRAPHIC PRINTING INKS Danny C. Crumpl

The installation of a two-stage distilling process at Rexham Corpora- tion's Flexographic printing plant in Greensboro has been a continuing success. The benefits have been both economic and environmental. The solvent based flexographic inks must be compatible with the distilling equipment. Important safety features were included in the original design of the room and equipment. Eliminating Hazardous Waste Was The Most Economical Thing To Do The solvent based inks used in flexographic printing must be cut with various solvents to obtain the desired viscosity and running characteristics. Those solvents used are normal propyl alcohol, ethyl alcohol and normal propyl acetate. The inks themselves contain methanol, isopropanol and heptane. The solvent is used for washup of rollers and fountains between jobs on the press. Thein-plant recycling of used solvent is done in a two-stage process using two different stills. The first still has two heat jackets which surround two 55 gallon drums in which the used solvent and ink have been placed. The barrels have a vapor line screwed into the large bung. The distilling process takes approximately 8 hours to complete. The barrels are processed one at a time. One can be unloaded and prepared while the other is heating. The results of this process are approximately 35 gallons of reclaimed solvent and 15 gallons of grease-like still bottoms. The second still opens on the top exposing an aluminum foil lined pot of 20 gallons capacity. The still bottoms of the previous operation are placed in this pot and distilled down to a dry cake. This dry cake of ink pigments has been approved by state and local officials for disposal in a landfill. Safety When the first still was installed a special room was built in a corner of an existing, 4 hour, Class I flammable liquid storage room. The room to house the stills is surrounded by a 2 hour wall. The room and still installations were approved by our insurance carrier, City fire department and met applicable building codes. Safety features in the room are sprinklers, explosion proof lights, floor sweep powered exhaust, floor level fresh air vents and a pressure relief wall. Safety features on the first stage still include air purge control panel, high temperature shut-off in vapor lines, pressure relief blow- out disc in vapor trail (vented to outside) and fresh air intake across primary condensing coils. It also has a fan, compressor and heating element interlock. I. Industrial Engineer, Rexham Film and Label Plant, P.O. Box 5466, Greensboro, NC 27435 46.1 The second stage unit has a high temperature shutoff. The condensor is water cooled. All controls are explosion proof. Electrical shut offs to both pieces of equipment are located outside the flammable storage area. The main safety feature in the entire operation is an attentive operator who frequently observes the operation of the stills. Advantages and Disadvantages The units have been relatively problem free during the years of operation. Due to the nature of the operation, safety is a prime concern. Several incidences have occurred involving leaks around seals on the barrel and joints on the vapor line. This is best minimized through frequent inspection at startup and good ventilation of the room. The transfer of the still bottoms from the first stage to the second unit is somewhat messy and cumbersome. The operators wear an organic respirator mask during this operation. We have found that uncut ink cannot be distilled. This is ink that comes from our supplier and has not been thinned by adding of additional solvent. We have found that charring occurs around the barrel edges and forms an insulation before the entire contents can be raised to a temperature high enough for distilling. Due to the reduction of hazardous waste with distilling we have gone from a generator to a small generator status. We consider this operation which began eight years ago a success by any standard.

46.2 First Stage (1980) Second Stage (1985)

Type of Still (2) 55 Gallon Batch 20 Gallon Pot Brand Cardinal Corp. Recycl ene AC-20 RS-20 Cost: Project $16,519 $8,965 Still $ 9,500 $7 ,500 In Li qui d Thin Grease out Thin Grease Dry Cake Vol ume Before 25/Month 5/Month (Drums) After 5/Mon t h 0 Savings: Disposal $ 1,500 $ 500 Sol vent $ 2.300 $ 500 $1,ooo $4,800 Total Uti 1 i ties Air (Instrument) Air E 1 ec tr i c E 1 ectr i c Chilled Water Load Time 10 Minutes 20 Minutes Process Time 8 Hours 9 Hours

46.3

FILTRATION RECOVERY PROCESS FOR OIL/CARBON BLACK BASE INKS Danny Col 1ins* At the News and Observer Publishing Company, we publish two newspapers, the morning paper seven days a week with a circulation of 146,000 and our Sunday paper circulation is 195,000. Our afternoon paper, The Raleigh Times, is published Monday through Friday with a circulation of 27,000. We are a letter press operation. In 1987 we printed 45,000 total number of pages and consumed 32,000 tons of newsprint and 500,000 pounds of black ink and 100,000 pounds of color ink. It is our goal to reduce our waste generated to zero or as near zero as practical to protect our environment. In 1982, we purchased a Semler Portable Fountain cleaner and ink filtration system , model number RLR200 for our letter press operation. Today the unit goes for about $7,100.00. At first, we only used the Semler system to clean out ink fountains and did not have an active program to recycle our waste ink in previous years. We were generating about 10 drums per year of waste ink of which we had to ship off to be incinerated. In 1987, we started an active program of ink conservation and recycling all waste ink through the Semler system which has reduced our waste ink to essentially zero drums per year.

We average running the system about 5 hours per week, recycling about 75 gallons of ink per week. We have not had any scrap ink after June of 1987. As you can see, it is a very practical and cost effective to reduce your waste ink to near zero with minimal labor efforts and cost expenditure. To say the least, the system has been very effective in our location. We consume approximately 36,000 tons of newsprint annually generating about 749 tons of printed waste and about 235 tons of white waste. We keep the printed and white waste separate and it is sold to a paper stock dealer for recycl i ng . Currently, the only waste we generate each month is Safety Kleen which averages around 800 pounds per month, which is charged to us as waste -5 generated. The laws do not seem to be reasonable in relation to this matter. It seems to me that if a material is recycled like the Safety Kleen is, that the only waste generated is the residue left over after it’s recycled. I do not understand why the entire volume is considered waste as if it was totally disposed of and not recycled. Another peculiar thing about the laws in relation to Safety Kleen is the only way that they will allow it to not be considered waste is to have a completely sealed closed recycling system and automatically handling the recycling of the Safety Kleen. The less expensive systems are not totally automatic and require handling drums of material.

*Production Director, News & Observer Publishing Company, 215 South McDowell St., Raleigh, NC 27602

47.1 As long as the job can be safely accomplished without affecting our environment, I do not understand why it is still considered waste. If we had a Safety Kleen recycling system, the only waste we would generate would be the sludge left over after distilling it.

In relation to inks for the newspaper industry, I feel the future is in inks made from soybean oil instead of petroleum-based oil, providing us a much more environmentally safe product with one of the side benefits being a cash crop for our farmers and not depleting our world's petroleum resources. We feel strongly the soybean-based ink might and should be in the future of our industry. It prints better, but, unfortunately, black ink is considerably more expensive; fortunately, the color ink is only marginally more expensive. As an experiment, we have been using 100% soybean color ink since February of this year.

I would like to show you a video put out by General Printing Inc. of Sun Chemical Corporation introducing their soybean ink product line. I'm not promoting GPI as such, but strongly suggest that the printing industry look towards soybean-based inks for both letter press and offset.

47.2 REDUCTION OF HAZARDOUS WASTES: AN OVERVIEW OF FIBERGLASS MOLDING

A. Darryl Davis'

Open molding of fiberglass components is carried out in a variety of North Carolina firms. Some of these companies operate facilities which are dedicated almost exclusively to the production and marketing of molded components such as boat hulls, bath fixtures, bathtubs, large storage tanks, and vehicle body components. Other firms may accommodate open molding only to the extent of producing accessories or parts for the more complex products which are assembled in their facility.

Such molding are an important element of North Carolina's economy. Several thousand residents are employed in jobs that are directly related to the production of open molded plastic products. Many others find employment in the support or related areas. Facilities may range in size from local one or two man operations to nationally and internationally recognized organizations which employ more than 1,000 people. Many of these firms employ far fewer than 50 people in daily plant operations. Plants are located in all geographic regions of the state. Many existing operations have found the economic climate conducive to expansion and at the same time the number of new facilities has increased.

North Carolina will be likely to continue attracting open molding industries. These firms find that a skilled and unskilled work-force is available. The moderate climate is well suited to the requirements for processing thermosetting plastics such as polyesters. Since many open molding firms are already located in the state, a good network of equipment and materials suppliers is already well established. Transportation systems for delivery of processing materials and shipment of products are good. North Carolina also has an excellent market for many of the goods produced by the industry. The state is geographically situated so that shipment of products to the heavily populated Northeast and the rapidly growing Southeast is relatively fast and inexpensive. The available waterway transportation is particularly important to boat manufacturers who must ship finished yachts that are too large to transport by truck or rail. Growth in fiberglass molding operations will probably continue during the next several years.

Fabrication Processes and Facilities

Although the composition, shape, and size of molded fiberglass products can vary significantly, some aspects of the fabrication requirements remain consistent. For products with a smooth durable finish a mold which is smooth and highly polished is required. A gel coat resin (which sewes as the exterior finish) will be applied as the first step in the lay-up. Either male or female molds may be used. Polyester resins are used in most gel coats and as the resin matrix for most lay-ups. In most production systems application of resin is accomplished through spraying. The fiber reinforcing materials used may take the form of roll stock or short chopped fibers which are sprayed in with the resin. Hand rolling operations are essential for removing voids and ensuring proper integration of resin and reinforcing material.

Some variation in processing approaches may be traced to the diversity of products produced. For example, techniques used to mold a large storage tank are different than the approaches used to mold a shower stall. Approaches to producing basically similar products can also vary because of differences in facilities and the organization's production concepts. Where high

Chairman, Department of Manufacturing, School of Industry and Technology, East Carolina University, Greenville, NC, 27858

48.1 production outputs are required, larger companies can develop facilities which have specific areas and production equipment designated for each unique operation. Smaller organizations frequently are forced to perform a variety of operations within the same production area and with the same basic equipment. Resources for equipment, facility improvements, and efficient management of production and pollution outputs are frequently a problem for smaller firms.

Physical plant arrangements for most producers consist of one or more open production areas. In open areas where resins are sprayed, a number of exhaust fan outlets are normally used to remove vapors and odor. The use of resins leads to potential pollution problems in terms of airborne solids and styrene vapor emissions. Even where exhaust systems are provided, there may be problems with design strategies as related to control of air flow inside and outside the facility. Molders must also deal with other potential pollution and safety problems in terms of materials storage, contaminated solvents, waste disposal, highly flammable liquids and vapors, and dust.

Establishing Pollution Reduction Strategies

Because of the products used in fiberglass molding, the industry can expect increased emphasis on safety and pollution reduction issues. Federal and state regulations are undergoing constant revision in terms of new approaches to managing potentially hazardous materials, atmospheric emissions, and worker safety. Implementation of pollution reduction strategies is often an outgrowth of problems created by regulatory and enforcement demands. Managers should be aware of these regulations and health standards when they select materials for processing, design production facilities, and develop production processes. There must also be concern for the health of workers as well as the health of the environment. On the positive side many producers have found that pollution reduction strategies can actually be cost effective. A number of these strategies will be reviewed during this session.

In establishing a pollution reduction program a firm must be willing to take a long term view of managing resources. In some cases the past approaches to facility and process development in the fiberglass industry can be categorized as being short-sited. Operations have been set up in open general purpose structures with little regard for anything other than basic lay-up and secondary finishing. Potential problems are most acute for smaller operations where there is often little advanced planning or management emphasis on waste disposal, materials storage, or environmental control. Many pollution related problems, created by these approaches, can be minimized through refining management strategies, basic production approaches, and facility des ign .

When calculating the overall effects of implementing a pollution reduction strategy, it is often difficult to get a clear picture of the actual costs and benefits of all available alternatives. The following cost factors must be included in order to obtain an accurate analysis: capital equipment, equipment operation, virgin solvent, transportation of virgin materials and waste, waste disposal, fees for obtaining any required permits, and legal liability. These cost factors must be carefully weighed against productivity needs, available assets, incentive and disincentives. Long-term liability may be the most important factor in the decision making processes which relate to waste and pollution reduction strategies. Regardless of perceived expenses or profits, ignoring sound waste reduction and pollution prevention strategies will be more costly in the end.

A number of regulatory factors dictate an interest in waste and pollution reduction strategies. According to the code of federal regulations, all industrial installations are legally obligated to properly handle, ship, store, and dispose of hazardous materials and waste. In addition, there are regulations specifically issued for the protection of employees in the work-place. In order to know what materials are regulated by governmental agencies, the regulation under which the

48.2 material is governed should be specified. However, in fiberglass molding industries, since the process only involves a small number of compounds, materials which have the potential to be hazardous either for human health or for the environment can easily be identified. The most common materials are styrene, methyl ethyl ketone peroxide, acetone. A brief description of these materials and their properties is included in the report presented by Lori Rosinus.

Production-Based Waste and Pollution Reduction Strategies

Air Assisted Airless Sprav Guns ; Use of resin spray applicators has become standard practice for most fabricators of fiberglass products. Conventional gun-type resin application systems use either compressed air or high fluid pressures to atomize resin materials. In air spray systems atomization requires the flow of a large volume of air at high pressure. These systems offer good control of spray patterns but are not well suited for efficient delivery of thick resins such as those used for gel coats and lamination. Airless spray gun systems are designed so that resins are atomized by being pumped at extremely high pressure through an atomizing nozzle. Airless spray guns are considered to be efficient in delivering resins to the work surface. Large quantities of gel coat and other resins can be rapidly transferred with these systems. For efficient atomization and delivery, pressures in excess of 3,500 psi may be required. These high pressures, while necessary for atomization and spray pattern development, contribute to excessive fogging, overspray, and bounceback during the spray-up process.

Recent developments in spray-gun design have resulted in new systems which blend positive characteristics of both air and airless spray guns into one unit. Air assisted airless guns, like conventional airless guns, utilize high fluid pressures to atomize resins through a spray nozzle. This high pressure nozzle atomization is further augmented by introducing pressurized air into the resin as it exits the pressure nozzle. Unlike conventional air spray guns, air assisted airless systems require a very low compressed air pressure at the nozzle. Air assisted airless spray guns can ensure that the high volumes of material transfer attainable with airless systems can be maintained while reducing material losses due to excessive fogging, overspray, turbulence, and bounceback. Reduced delivery pressures can help ensure that a cleaner, safer, and more comfortable work area is maintained. External emissions of vapors and the need for high levels of make-up air may also be reduced.

PreDrea F iber Re inforc ina; For a number of years fabricators of composite aircraft structures have relied on the use of fiber reinforcements that are presaturated with resins. These materials, referred to as "prepregs," offer a number of advantages over conventional spray techniques. Resin to fiber ratios can be closely controlled; atomization of pollutants is practically eliminated; and cleanup and disposal problems are greatly reduced. These advantages are, however, not enough to make prepregs widely accepted by most fiberglass fabricators. Prepregs are generally formulated with more expensive epoxy based resins which require placing the mold in an oven or autoclave to complete the cure cycle. These more expensive resins are normally combined with exotic, high strength reinforcing materials, such as graphite fibers. Storage is also a problem since the materials must remain refrigerated until the lay-up process is begun. Prepregs appear to be best suited for applications where extremely high strength-to-weight-ratios are required and cost factors are secondary.

In-Plant Resin ImDreanat ion; Equipment is now available to provide the fabricator with some of the advantages offered by prepregs while using lower cost polyester resins and fiberglass materials. Impregnators can be placed within the lamination area of a plant and be mounted in such a manner as to feed resin saturated reinforcing materials directly to the molding operation. Conventional resin pumps and catalyst metering devices supply resins to a roller-reservoir system. Woven fiberglass is impregnated as it passes through this reservoir

48.3 system. Impregnators can be designed to fit a variety of potential applications. The units can be mounted to overhead track and lift systems, over stationary conveyor fed lines, on bridge cranes, or on portable carts. Conventional resins and roll fiber materials can be used. Machine size and capacity can be engineered to provide a variety of output feed rates and to accommodate a number of roll widths. Since there is no spray atomization of resins, impregnators would appear to have considerable potential for the reduction of airborne emissions associated with . ._ fiberglass molding operations.

____ Resin Rollet Dispensers ; Resin roller dispenser units utilize a fluid pumping system to draw resins from drums or bulk distribution lines. This pumping system also includes a separate, fully adjustable catalyst pump. Resin and catalyst are precisely metered and pumped to a gun-type head for mixing. The gun head is essentially an internal mix airless spray gun without an atomization nozzle. The atomization nozzle is replaced by an attachment which directs the catalyzed resin to an attached roller. Units which attach to existing spray gun heads or other feed systems are available. A flexible material hose is attached to the mixing chamber of the spray gun. This hose will feed resin directly to the roller dispenser. Resin is dispensed directly onto the roller surface through a perforated T-bar. The high pressures normally associated with the use of either airless spray guns or air assisted airless guns are not required. Since atomization is not required, airborne emissions are greatly reduced. Compression MoIdina; Fabricators who make fiberglass reinforced polyesters the material of choice must carefully consider changing production technologies. Open molding spray-up and hand lay-up production techniques are frequently employed by smaller firms or those who produce limited numbers of units from each mold. Open molding carries a high per piece cost due to labor intensity, limited daily output from each mold, and considerable atomization of resins. Closed mold technologies may offer a practical alternative for some companies. Closed molding operations, such as compression molding, eliminate requirements for atomization of resins and may offer a number of waste reduction and production advantages over conventional approaches to molding.

Compression molding can reduce high per unit cost, but only if production volume is high enough to sufficiently spread out the high cost of the required matched metal dies. Special molding compounds of resin and reinforcing materials are normally required. The molding compounds are compressed between heated matched molds. Output is high because the molding compounds cure rapidly in the heated mold. Some materials yield a good finish without application of a gel coat. Both surfaces of the molded product will be as smooth as the mold surfaces. Compression molding processes have been used successfully in the automotive industry for more than 25 years. Production output requirements for the majority of fiberglass molders do not approach the 150 parts-per-mold-per-shift figure required to ___ reasonably spread out the costs of molds and tooling.

Resin Transfer Moldina; Another closed mold process known as resin transfer molding (RTM) has recently seen a surge of interest. Like compression molding, RTM utilizes matched molds. However, the matched molds do not have to be made of metal, and high pressure mold closing systems are not required. RIM appears to offer many advantages to firms that seek production of 100 to 10,000 parts per year. RTM production systems can be set up to replace many conventional open molding processes. Molds can be produced from the same materials and with the same techniques required for production of conventional molds. The molding resins and filler materials differ little from materials used to produce similar components in open molds. Even the gel coat finishes may be the same as those produced in open molding.

48.4 RTM is carried out in a closed mold at room temperature. Where a gel coat finish is required, processing begins with the application of a gel coat to one or both sides of the mold. Quality finishes may also be produced without the use of a gel coat. Glass reinforcing and other materials, such as core stock, are placed in the bottom half of the mold. The mold halves are closed and securely clamped. After the mold is closed, catalyzed resin is injected through one or more strategically located ports. Since molding pressures typically are low, the molds can be made of plastic based composites rather than metal. The matched molds are laid-up over a pattern in the same manner and with the same types of materials used to produce molds for open molding. Some specialized tooling is required to ensure that alignment and clamping pressure are maintained when the molds are closed. The molds must also be properly reinforced to avoid flexing during the injection and curing cycles.

Pollution output is greatly reduced since application of the optional gel coat is the only step in RTM that requires atomization of resin. Pumping catalyzed resin into a closed mold eliminates fogging, bounceback, and overspray. Vapor emissions and odor are further reduced by confining the resins in the mold until curing is complete. There is little, if any, waste of resin. Dust and solid waste producing secondary grinding and bonding operations are reduced because the closed molding system eliminates most flash removal and edge smoothing requirements.

RTM applications seem best suited for intermediate volume production of small to mid-size components. Large items, such as boat hulls, are produced using RTM techniques, but tooling costs per unit are quite high. Items such as restaurant seats, hatches, doors, automotive parts, tubs, and shower units are much better suited to this type of processing. Molds for these products can be kept to a reasonable size and can produce parts that require a minimum of trimming, assembly, and secondary finishing.

Thermoplastic Moldina: The plastic industry uses far more thermoplastics than thermosetting plastics. Thermoplastics processing offers faster curing cycles, lower emissions during processing, lower costs per pound of raw material, waste recycling, and lower labor intensity. Open molding of thermosetting plastics is likely to continue as a viable process because of the design constraints associated with many products, limited unit production requirements, performance requirements, and market demands. Recent advances in processing technologies and thermoplastic resin systems are causing many in the industry to examine alternative approaches to the molding process. New engineering grades of thermoplastics can be reinforced with fiberglass or other fibers. These materials can rival the strength of many of the strongest thermosets. Production machinery and tooling costs are still high for thermoplastics forming processes such as injection molding, extrusion, and blow molding. Often thousands of products must be produced in order to provide a reasonable amortization for mold costs alone (large molds machined from stainless steel may cost more than $100,000). Molds for processes such as rotational molding can be produced at costs low enough to warrant the interest of some open molders.

Rotational molding provides an attractive alternative to in-plant production of open molded assemblies. Tooling costs for molds are considered to be compatible with tooling costs for conventional molds. Rotation molds can produced from inexpensive aluminum castings. Because open molding fabrication and curing cycles are lengthy, a number of conventional molds may required to insure adequate daily output. Only one rotational mold would be required to maintain the same volume of production several conventional molds. Per unit production costs are compatible with open molding on medium volume runs and less expensive per unit on high volume runs.

48.5 Managing Materials

A number of approaches are utilized for purchasing resins and solvents for open molding operations. Many processors elect to purchase all materials in 55 gallon drums while others prefer to purchase resins in bulk quantities. Large firms, such as bath fixture manufacturers, ~ purchase practically all general purpose resins in bulk and store these materials in large storage tanks. Smaller companies usually purchase general purpose resins in drums. Specialty resins such as gel coat colors, tooling resins, and fire retardant resins are almost always purchased in drums or small containers.Use of drums creates a number of problems. A systematic approach to inventory, control, and disposal must be established in order to assure that materials are used before their storage life expires. Drums can collect at a rapid rate, and it may be difficult to dispose of them. Many landfills refuse to accept drums. Disposal of drums containing liquid residue may call for handling the drum as hazardous materials. Use of drums normally implies a commitment of labor to materials handling.

Both the bulk and drum purchase strategies have positive and negative attributes. Where large quantities of resins are consumed, bulk systems enable companies to purchase resins at lower prices. Lower prices are possible because of quantities purchased, elimination of packaging in the form of barrels, and ease of handling in terms of loading and unloading. Bulk systems are well suited for delivering large quantities of resins to vats for mixing with fillers or other additives. Drum purchases fit the needs of users who need flexibility in terms of quantities purchased. Use of drums does not require installation of expensive storage tanks and resin delivery pumps and piping. Occasional users find that drums eliminate storage tank cleanup and reduce the likelihood of overextending the storage life of large quantities of resin. Fabricators can consider an approach to resin storage that offers some advantages over both the bulk and barrel strategies. Special containers which are large enough to supply several hundred gallons of resin, but small enough to be handled by a small forklift, form the heart of what are referred to as mini-bulk resin systems. These stainless steel containers are shipped to the user by truck and are stored in one central location. Since the units can be stacked, floor space dedicated to resin storage is greatly reduced. When new shipments of resin arrive, the empty containers are returned to the supplier where they are steam cleaned and refilled for delivery. Inventory, product control, and record-keeping are easier to manage. As with bulk storage, there is a need to use a materials distribution system to deliver resins to the work area. This resin distribution system is typically a closed loop plumbing system which is used to circulate resin to all areas of the facility. This circulation system helps keep the resins mixed and prevents settling and the build-up of contaminants.

Conclusions __ Cost efficient waste and pollution reduction programs can be established for fiberglass molding operations if a take a long term view toward managing resources is adopted. In many cases firms have implemented sound approaches, to waste reduction and management, which have provided profitable returns on the required investments. Efficient management of pollution and waste related problems requires careful examination of all available alternatives. Management must look beyond simple one step solutions that often simply sidestep or delay dealing with the problems at hand. Consideration must be given to selecting approaches which interact with all areas including basic production approaches, facility design, and management strategies. Profitable reduction approaches are best developed when careful attention is paid to refining material flow patterns, conserving materials, conserving utilities, separating incompatible operations, elimination of liabilities, and inventory control. ON SITE SOLVENT RECOVERY: A UNIQUE SOLUTION TO YOUR SOLVENT DISPOSAL DILEMMA

William C. Johnson

As the U.S. Environmental Protection Agency relies more heavily on State environmental agencies to monitor compliance of Resource Conservation Recovery Act regulations, on site recovery will become a more attractive solution to solvent disposal.

The Environmental Protection Agency believes on-site recycling is the most advantageous way to deal with waste solvent that if released to the environment, would present a hazard to human life and health. This is evidenced in the softening of the users responsibilities to the federal regulations concerning on-site recovery. There is no permitting required for on-site recycling and that a generator need not count, in determining how much hazardous waste he generates, solvent used and then reclaimed and reused at the site of generation. i This means the user that chooses to recycle on-site will be the least regulated user and generator of waste solvent.

The economic advantages of on-site recycling are paramount as well. Liability cost are reduced as a result of having lower quantities of solvent waste to dispose of or incinerate. The administrative costs of manifesting, record keeping and reporting are sharply reduced as well. Data recently gathered by Seymour I. Schwartz, a University of California, Davis, Professor confirms convincingly that even under the most conservative assumptions, an investment in small scale recycling should pay itself back in less than two years, and under many conditions, in less than one year.

Solvent recovery is a very simple process. Contaminated solvent is poured or pumped through a fill port. Solvent in the boiler is heated to its boiling point and pure vapors rise. Solvent vapors travel through the water-cooled condenser and gravity fed to a clean approved container. Recovered solvent is typically 99.5% pure and most residue can be disposed easily as solid or semi-solid waste.

1. Regional Sales Manager, Recyclene Products, Inc. 405 Eccles Ave., So. San Francisco, CA, 94080 49.1

FIBERGLASS MOLDINGS: AN OVERVIEW OF MATERIALS SAFETY DATA SHEETS

Lori Piantadosil

The fiberglass molding industry utilizes a number of regulated materials and produces considerable quantities of contaminated solvents and hazardous wastes. Because of the hazard potential associated with these chemicals, special attention must be focused upon their management and upon controlling occupational exposure to them.

Many firms in this industry are unaware of a basic source of information that is provided by a manufacturer about their product. This information is compiled on an OSHA standardized form called a Material Safety Data Sheet or MSDS.

The MSDS collection can provide a starting point for an integrated Health and Safety program. This program can aid a company in reducing occupational exposure to hazardous chemicals and it can aid in proper management techniques for these chemicals.

The fiberglass moldings industry utilizes a number of regulated materials which make knowledge of environmental and health regulations essential to the survival of these companies. As liabilities continue to increase, the fiberglass industry must take steps to educate themselves of their responsibilities and perhaps even to anticipate regulatory change.

Because of the nature of the materials used, processing produces considerable quantities of contaminated solvents and hazardous wastes. Therefore, special consideration is necessary for the handling, storage and disposal of both the raw materials and the resulting wastes. For example, Polyester resins, paints and varnishes in common use in the industry contain 20- 50% Styrene as a crosslinking agent and solvent. Styrene may be considered to be a liver toxin, a teratogen and a carcinogen. Additionally, Styrene is a fire and explosion hazard. Another chemical in general use in the industry is Methyl Ethyl Ketone Peroxide (MEKP) which is used as a catalyst. MEKP is very caustic and if splashed into the eyes can damage the cornea resulting in blindness. MEKP is commercially available diluted to 50-60% with Dimethyl Phthalate (DMP) which itself is a potential teratogen. (A chemical that is a teratogen causes birth defects).

Acetone is a third chemical which is heavily depended upon in the industry. Its use is as a general solvent for cleaning. While it is not as potentially damaging as Styrene or MEKP, it is an irritant which may cause dermatitis and is narcotic in high concentrations. There are other specialty chemicals with similar hazards.

Environmental mishandling of hazardous materials may lead to fines. Poorly ventilated application processes may expose workers to toxic vapor concentrations. Dust from grinding and finishing operations contribute to deteriorating air quality both in and outside of the plant. As a point of information, an OSHA compliance officer can suspect a health hazard when any of the following conditions occur: Eye irritation is felt when entering the work area A strong odor is noticed when entering the work area Visible fume or dust clouds are observed coming from the operation into the work place or visible clouds are observed coming from poorly maintained ventilation systems.

1 Laboratory Research and Teaching Assistant, Department of Environmental Health, East Carolina University, Greenville, NC, 27858 50.1 As stated earlier, because of the hazard potential associated with these chemicals, special attention must be focused on their management and on controlling exposures to them. Good management requires knowledge of correct: Storage Use Disposal

Controlling exposure is best accomplished by an integrated, active program of health and safety. __ Health and safety have two inseparable aspects: Human Protection Environmental Protection

Where do you get the information you need to be able to effectively begin a program of health and safety?

One of the first sources of information is provided by a manufacturer about their product on a Material Safety Data Sheet or MSDS. The MSDS, if properly and objectively completed, is a convenient source of information compiled on a standardized form. It is designed to present guidelines that cover product identification, health hazard data, safety hazard data and physical hazard data. It should be used in support of, and not in place of, a Health and Safety program. Many larger companies write their own in-house MSDS' based on information provided by the manufacturer, standard reference materials and their own safety programs. Some of these sheets can become an elaborate database of information, as illustrated by the following MSDS developed for styrene.

The first section of an MSDS contains general product identification. The company listed should be the backup source of detailed information on the hazards of the materials covered by the MSDS, and as such, they are required to provide an emergency contact number. In addition, many MSDS' include a nation-wide, 24-hr a day emergency number like CHEMTREC. This contact provides response/action information for emergency circumstances. CHEMTREC forwards information to appropriate agencies and provides sufficient information for critical first steps in controlling an emergency. CHEMTREC is strictly an emergency operation service.

Next, the product should be identified in terms of a chemical family, synonyms, and trade names. A chemical family is a designation of similarity. Synonyms are those names commonly used, especially in formal chemical nomenclature. A trade name is a product designation or a common name. Not all chemicals have trade names or other common names. For some chemicals, it would be impossible to use every name or designation. A simple and standardized identification exists in the use of the CAS number. The CAS number is a unique numerical designation, given to every chemical entity be the Chemical Abstracts Service of the American Chemical Society. Its use helps to avoid confusion and ambiguity caused by multiple synonyms, common names, or similar chemical formulas. For example, styrene is # 100-42-5. The CAS number is also useful for cross-referencing in different hazard classification schemes.

The materials listed as hazardous ingredients are those substances which are a part of the product covered by the MSDS, and individually meet any of the criteria defining a hazardous ~~ material. Hazardous materials are those that are: Ignitable (flammable) Corrosive Reactive (explosive) Toxic

50.2 In simple terms, all ingredients are listed Their percent composition and their toxic hazard data are included in this section. Becausf s?yrene is extremely reactive, an inhibitor is added which prevents spontaneous polymerizati ~iTherefore in this section it is appropriate to include notation of this product as a mixtur

In the case of proprietary formulas (know as trade secrets), precise percentages may be substituted by ranges or maximum values.

Toxic hazard data is a concept which refer- to exposure to substances and conditions in which workers may have repeated and/or conti s exposure. Toxicity is one of the criteria of a hazardous material. Control of the work nment is based on the assumption of a threshold limit, below which exists a safe or tole level of exposure. This is termed the TLV, or Threshold Limit Value. The TLV is bas the best information from industrial experience, experimental human and animal studies, 01 d2 combination of all three. The original idea of the TLV is a concept from the American Confe:z:nse of Governmental Industrial Hygienists (ACGIH); it was intended as a guide in control of heal: hazards of the job. When OSHA was established in the early 1970'~~many of the existing ere incorporated as legal standards and renamed PEL'S, for Permissible Exposure Li cause substances vary, people have different susceptibilities, work conditions vary, ntific testing methods become more sensitive, the precision of the TLV and other e e limits continue to be revised. New TLV's are published annually, but most PEL valu ot been updated. Because the MSDS is required to reflect current data, Styrene and m hemicals have two or more values. OSHA's PEL is the enforceable limit, but the TLV is the advisory standard. It is easy to become confused because the term TLV has come to represt33 the concept of the safe exposure limit. Whenever you see a TLV with OSHA beside it, that is tbL+';iimit.

The numbers of the TLV for gas or ~2-3~are based on the airborne concentration of contaminants and thus what would be rear+!vinhaled while breathing. Emphasis is placed on inhalation exposure because it is usually t: ;t fastest way which a potentially toxic material can cause health effects, in an occupational set: ;;

Units of measurement for a gas TLV are vc ?e units such as parts per million, ppm. You may see the TLV expressed in other units such : Tilligrams per cubic meter, mg/m3. To appreciate the magnitude of these numbers, 100ppw CY analogous to 100 cents (one dollar) in 10,000 dollars. -

Note that for substances which are classi; :: as carcinogens, there is no threshold of safety. Thus any contact is potentially harmf;&v strict control measures are necessary to protect health.

Section three of the MSDS is a chemicz description of the product based on its physical properties at some defined standard temp a:ure and pressure. Styrene is a colorless liquid with a very low odor threshold. At low Incentrations it is sweet and aromatic. At high concentrations it is sharp and penetrating. i is only slightly soluble in water and the vapor is more than three and a half times heavier an air. This means that without air currents the vapor sinks. Evaporation rate, specific r i5Jity and vapor density are useful for designing proper ventilation systems and filters.

The fire and explosion section should coni '1 as much information as possible about potential product hazards resulting from exposure 7 fire, sparks, of sources of ignition. A flashpoint determination is the lowest temperature I which sufficient vapor is emitted to form an ignitable mix with air. A standard methr !Ike tag closed cup, or Cleveland open cup as specified by the American Society for Testi and Materials is used for this determination.

50.3 LEL and UEL are indicators of the explosive or flammable limits in air, above which or below which combustion does not occur. The lower explosive limit (LEL) is a minimum concentration below which the air-product mix is too "lean" to ignite. The upper limit (UEL) is the maximum concentration above which mixture with air is too "rich" to burn. Results are expressed in percentages by volume of gas or vapor in air. lgnitabifity is one of the criteria that define hazardous material.

Any special procedures or precautions in a fire situation should be fully described. We already know that styrene is not very soluble in water and therefore, water is useful only for cooling the fire. Other forms of extinguishing media need to be specified.

Chemical components also have properties relating to their inherent stability. See Section 6. This is termed reactivity and relates to the degree of susceptibility of materials to release energy. Styrene is normally stable under appropriately managed conditions. Stable materials have a normal capacity to resist changes in their chemical composition, despite exposure to air, water or heat. Unstable materials are those which will undergo chemical changes and vigorously decompose, condense, or become self-reactive (polymerize). Reactive materials are those which readily undergo chemical reaction with other stable or unstable materials and may be corrosive. This chemical incompatibility may be dangerous or destructive if not noted. Reactivity and corrosivity are two more criteria that define a hazardous material.

Because of styrene's ability to polymerize and its corrosivity to copper, flushing it into the sewers is dangerous. As a hazardous material, it is not allowable in the environment.

Polymerization is a chemical reaction which produces large molecules by a process of repetitive addition which is similar to an analogy of uncontrolled growth. Frequent monitoring of products that may polymerize is a necessity and storage time of polymerizable materials should be minimized. For styrene, proper inhibitor levels and proper temperature are necessary to maintain stability.

The section of health and safety should reflect the combined health hazards of the product, physiological effects of overexposure and specific emergency/first aid procedures. The TLV for the product should be listed as opposed to the TLV for each individual component, which is often duplicated for the hazardous materials section. A product TLV is not always available since few products are thoroughly evaluated by independent laboratories. Therefore, different types of TLV's are used to help evaluate health and safety hazards.

The most common TLV is expressed as the TLV-TWA. This is a threshold limit value based on a time weighted average. The TWA is an exposure level which accounts for day to day fluctuations .- by averaging the exposure over a 40 hour work week, 8 hour shifts. There is also a 12-hour TWA which is based on a 12-hour shift. The TWA more closely approximates a worker's weekly exposure than a flat TLV rate.

The second TLV is the TLV-STEL. This is a short term exposure limit which reflects the maximum concentration to which exposure can occur (up to 15 minutes) without ill effects. A worker is allowed four excursions with a minimum sixty-minute break between exposures. - Additionally, the daily TLV-TWA must not be exceeded.

The third TLV is the TLV-C. This is a ceiling limit which should not be exceeded, even instantaneously. Styrene has an OSHA ceiling of 200 ppm. NIOSH, a research and education organization associated with OSHA has a recommended ceiling value of 100 ppm, and a TLV of 50 ppm over a ten hour workday.

50.4 The effects of overexposure should be written in lay terms where possible. "Headaches, dizziness, nausea" or "necrosis of the cornea" are examples. Very often, toxic hazard data are included in terms of concentration, mode of exposure, or of a toxicity test. An LD50 is a dose per kilogram of body weight which is lethal to 50% of a test population. An LC is a lethal concentration, a designation used for airborne contaminants.

Emergency first aid procedures should also be written in lay terms. These instructions need to be specifically categorized into procedures to perform under different types of accidental contact. First aid for eye, skin, inhalation and ingestion contact should be explicit.

Instructions for detailed spill or leak procedures for cleanup and disposal should be listed with emphasis on precautions to protect the workers on cleanup duty. Disposal methods, neutralizing chemicals, warnings and proper tools are a necessary part of these instructions. Note that this section does not tell you how to go about the disposal, but should refer you to applicable areas that do.

Special protection information, such as ventilation requirements, respirators, eye protection and protective clothing need to be specified. Since the MSDS is a resource available to the employees, this will tell them what they must use for their own protection. An eyewash and emergency shower should be a standard specification easily accessible in the plant.

Special precautions are those statements about the product that can affect its safe use, storage, handling or transportation. "Store below 90 degrees F", "inspect weekly" and "no smoking" are examples. One special precaution is for the worker not to wear contact lenses when using styrene or a product containing styrene. There is a necessary redundancy in the information as listed between the sections. What is an applicable reactivity concern is also applicable to a fire and explosion hazard. What is considered a toxic hazard is reflected in the health and safety and special protection sections.

Minimally, the MSDS should provide guidelines covering major points associated with methods of handling, controlling, using and disposing of a substance in a safe manner.

50.5 SAMPLE MATERIAL SAFETY MSDS-Styrene DATA SHEET DATE

s-, STYRENE MONONOMEX

1 GENERAL CHEMTREC 1-800-424-9300 MANUFACTURER'S NAME EMERGENCY TELEPSONE NUMBER

CHEMICAL NAME AND SYNONYMS TRADE NAME AND SYNONYMS VINYL BENZENE, CINNAMENE, VINYL BENZOL PHENYLETHYLENE, Cg Hg FokYULA C H CHCH2 CAS # CHEMICAL FA!!ILY AROMATIC HYDROCARBON 100-42-5

2. HAZARDOUS INGREDIENTS

TLV PAINTS, PRESERVATIVES, b SOLVZNTS ALLOYS AND METALLIC COATINGS % I tux, I (Units) PIGMENTS BASE METAL

CATALYST ALLOYS

VEHICLE METALLIC COATIKG:

SOLVENTS I I FILLER METAL

ADDITIVES OTHSRS

OTHERS (SEE BELOW) INHIBITOR

~ ~ ~~ ~ -~

HAZARDOUS MIXTUWS OF OTHER LIQUIDS, SOLIDS, OR GASES 'Units)

STYRENE (CAS # 100-42-5) PEL (OSHA) as mixture: .OO ppm TLV (ACGIH) as mixture : 50 PPm

~~ ~ - P-TERTIARY BUTYL CATECHOL (CAS # 27213-78-1) (added at rate of 1O-i5 ppin I prevents spontaneous polymerization of styrene)

3. PHYSICAL DATA (at 25Oc 760 mm hg)

BOILING POINT (F) 145.20~ I 293.4 I SPECIFIC GRAVITY (2 0=1) 1 3.6 I VAPOR PRESSURE (mm-Hg. ) 6.45 PERCENT VOLATILE BY VOLUNE ($1 100 VAPOR DENSITY (AIR=l) EVAPORATION RATE g/c$ 0.9018 (------= 1) SOLUBILITY IN WATER 2 5mg/ 10Og MELTING POINT I I I -23OF APPEARANCE AND ODOR colorless liquid, odor threshold < 1 ppm, sweet aromatic at low concentraions; sharp, penetrating at high csncentrations, very OTHERS slightly soluble in water miscible in alcohcl, ether :%>S ?AGE 1 CF 3 50.6 4. FIRE AND EXPLOSION DATA FLASH POINT (method used) FLAMMABILITY LIMITS Le1 I 1.1% 94'f (34.4'~) tag closed cup Ue1 1 6.1% + 1 EXTINGUISHING MEDIA (water, for cooling only may be dry chemical, CO 2, foam, water spray, water fog ineffective due to low solubility- VAPOR DENSITY (AIR=l) AUTOIGNITION TEMPERATURE of styrene in water) 0.9018 g/cm3 914'F (490°C) SPECIAL FiRE FIGHTING PROCEDURES Self-contained breathing apparatus. eye and body protection. Fight fire from safe distanct or protected location. Notify authorities if liquid enters sewer or waterways

UNUSUAL FIRE AND EXPLOSICN HAZARDS Eeat, lack of inhibitor,impurities, radiation, sudden exposure to air, may result in spontaneous reacton, may generate heat, build pressure, and rupture containers. Liquid is normally inhibited, but not the vapors. The vapors may condense as solids and plug pressure relief valves, causing rupture of storage containers.

5. HEALTH AND SAFETY DATA TSRESHOTYD LIMIT VALUE 100 ppm NIOSH 50 ppm 10 Hr TWA ACGGIH 50 ppm OSHA 200 ppm ceiling 100 Dum 15 Min Ceilina EFFECTS OF OVEREXPOSURE Severe eye irritant, drowsiness, weakness, aspiration hazard. Unsteady gait, narcosis, skin irritation, nausea, CNS depression

EMERGENCY AND FIRST AID PROCEDURES

EYE: Irrigate innnediately with large amounts of water for at least 15 minutes. Contact lenses should not be worn. Obtain emergency mecical attention.

SKIN: Immediately remove any contaminated clothing, wash thoroughly with mild soap and water. If sticky, a waterless cleaner may be used prior to soap and water wash. Seek medical attention if ill effects or irritation develop

INHALATION: Remove to fresh air immediately. Administer oxygen or artificial respiratioi as needed (especially if cyanotic). Obtain emergency medical attention.

INGESTION: Give pint of lukewarm water if victim is conscious and alert. DO NOT INDUCE VOMITING. Obtain emergency medical attention. Prompt action is essential.

OTHER : Styrene is a mutagen and a suspected animal carcinogen I .

STAB1L1TY UNSTABLE CONDITIONS TO AVOID Normally stable with proper maintenance of inhibitor levels. Avoid heat, flame, STABLE and contaminants. Corrosive to copper and copper X allcvs . Dissolves rubber.

HAZARDOUS MAY OCCUR x CONDITIoNS TO AVOID Improperly cieaned , containers, inadequate maintenance of inhibitor POLYMERIZATION WILL NOT OCCUR levels. Improperly vented storage containers. Storage at temperatures above 90'F.

MSDS PAGE 2 OF 3 50.7 I 1 7. SPILL OR LEAK PROCEDURES

STEPS TO BE TAKEN IN CASE MATERIAL IS RELEASED OR SPILLED Immediate danger of polymerization. Evacuate area and limit access. Stop release and prevent flow into sewers and waterways. Impound large land spills. Soak up small spills with inert absorbent material. On water, spills float; contain dispersion and collect. Report spills as per regulatory requirements.

WASTE DISPOSAL METHOD May be RCRA/OSHA hazardous. Determine standards that apply.Regulations may require use o registered transporters and permitted landfill sites. Use vented contaniners for storage of waste. Storage must be in accordance with state, EPA, and RCRA/OSHA regulations.

VENTILATION LOCAL EXHAUST TLV SPECIAL

MECHANICAL (General) OTHER

PROTECTIVE CLOTHING Polyethylene gloves, EYE PRoTECT1oN Chemical splash=proof goggles apron, sleeves, and boots or face shield w/respirator.

9. SPECIAL PRECAUTIONS

PRECAUTIONS TO BE TAKEN IN HANDLING AND STORING DOT Hazard: Flannable liquid, store below 90'F. Inspect inhibitor levels bi-weekly. Do no' store more than 30 days. Keep containers properly closed and vented. Inspect containers and observe proper cleaning standards. OTHER PRECAUTIONS Do not wear contact lenses. Observe good personal hygiene procedures, especially befor1 eating, drinking, or smoking. Thoroughly clean all equipment after each use 1 1

MSDS PAGE 3 OF 3

50.8 1 HAZARDOUS WASTE REDUCTION - MEASUREMENT OF PROGRESS Michael R. Overcash *

The management of hazardous waste has increasingly been viewed as an integrated or interconnected aggregation of industrial choices. There are both technical alternatives as well as economic factors which favor certain technologies. It is a constant challenge to understand the technical as well as the cost-based system by which hazardous wastes are actually managed by industry. The concept of a hierarchy for hazardous waste management is often used to provide a perspective on technology alternatives. This hierarchy concept was developed in about 1980 (Overcash 1981, 19821, Figure 1. With some minor variations, this hierarchy has continued in use (National Research Council 1983, 1985; Office of Technology Assessment 1983, 1986). . In Figure 1, the sequential position of waste minimization depicts the interest in reducing waste at or near the source. The philosophical and long term environmental consequences which differentiate waste minimization have been given in depth (National Research Council, 1985, Overcash 1981, 1986). (Note: focus is directed in this paper to hazardous waste, but virtually all of these concepts are applicable to water discharges, atmosphere emissions,' or a multi-media evaluation 1.

The Hazardous and Solid Waste Amendments of 1984 (HSWk 1984) have adopted a renewed emphasis on hazardous waste reduction; that is, the upper facets of the hierarchical approach referred to previously, Figure 1. This portion of HSWA 1984 states:

"the permittee certifies, no less often than annually, that--

"(1)the generator of the hazardous waste has a program in piace to reduce the volume or quantity and toxicity of such waste to the degree determined by the generator to be economically practicable; and "(2)the proposed method of treatment, storage, or disposal is that practicable method currently availabie to the generator which minimizes the present and future threat to human health and the environment".

' Article reprinted here with consent of author from Hazardous Waste and Hazardous Materials, V5 (3):251-266, 1988.

Professor, Department of Chemical Engineering, Box 7905, North Carolina State University, Raleigh, NC 27695-7905

51.1 I WASTE MINIMIZATION I

PROCESS RECYCLE 8 MODIFICATION REUSE I I I

-.... -...... -...... - ...... - ...... - ...... * ......

CONVERSION OF HAZARDOUS TO LESS OR NON - HAZARDOUS

THERMAL CHEMICAL, OCEAN 8 TREATMENT

I 1 1 I II II

ARID REGION UNDERGROUND WASTE SUR FACE SALT LANDFILL UWTURATED I N J ECTlON PILES IMPOUNDMENTS FOfW4TioIJS ZONE

Fi-qure I Relationship of alternate waste reduction concepts to overall hierarchy of hazardous waste. management The permittee certification thus links waste reduction and practicable treatment to accomplish the management of hazardous waste. Such a combined approach recognizes that it is unlikely to completely eliminate hazardous waste through reduction or recycle and thus regulated, effective treatment must be available. The advocacy of waste minimization has been a positive stimulation to achieve progress, but the nature of the industrial in-plant modifications must be viewed as only one aspect of the overall manufacturing technology investment. Thus a distinct feature of waste reduction as an environmental approach is that choices must be weighed against the typically large economics of manufacturing. That balance has sometimes led to substantial success in waste reduction, but may often lead to decisions against process modification.

Balanced economic language in HSWA 1984 reflected that; 1) other means exist for protecting the environment beside waste reduction, particularly at the source, and 2) that proprietary production choices involve a large array of other economic considerations. As a casual observation of the waste reduction status, across all types and size of industry, there are three phases or waves through which waste reduction technology proceeds.

1) Identification of direct techniques to reduce waste. These are the body of much published literature, equipment supplier material, and technology transfer efforts (e.9. use of distillation units for solvents, or detailed housekeeping reductions).

2) Evaluating wastes which on an intuitive engineering basis appear to be reducible but for which substantial engineering innovation and testing are needed. These development projects require longer time, are by no means assured of success, and are evaluated by management against other production improvements when allocating resources for development activities.

3) Recognition of wastes or process technologies which appear very difficult to reduce or change. That is, we have no firm concepts for engineering solutions, often because these wastes have been evaluated previously and no reduction or improved efficiency could be developed. It is this third plateau which represents areas of needed research to continue momentum in the field of waste reduction. At this time, many manufacturing systems are still working with the most direct, first phase waste reduction while others are beginning the middle phase involving greater engineering activities. Thus, in most firms the formal engineering evaluation of waste reduction opportunities, often as a waste

51.3 audit, leads to some success identifying cost-effective waste reduction.

DEFINITIONS The dynamics of much current public, regulatory, and scientific debate have evolved from the waste minimization section of HSWA 1984. The difficulties of the nonregulatory issues and economic feasibility have been described. Further, there are nuances of the waste reduction concept which have also emerged and must be discussed prior to a proposed assessment of progress in this field. The first nuance centers on the overall definition of waste reduction. One group suggests that the in-plant modification and recycle/reuse are the only waste minimization approaches embodied in the definition. This is exemplified by the philosophy of the Office of Technology Assessment . (1986). This is depicted in Figure 1 with the dotted line. A subset of those holding this opinion proceed further to establish a priority for in-plant modifications as a hazardous waste source control with recycle/reuse at a lower priority. As a note of observation, such priority setting is not a neutral exercise of decision-making, but leads to broad public perceptions of second class, inferiority, and a significantly adverse effect on human health and the environment associated with technologies other than waste reduction. Further, the priority classes become the basis for judging progress and hence a potential argument regarding overall environmental progress. The second, and counter opinion involves an assessment of the broad environmental or public health, goals on which the impetus of environmental protection is based. That is, the overall goal is to reduce the broad dispersion of waste constituents' to such environmental compartments as landfills, water receiver discharges, or emissions to the atmosphere (Royston 1979). On this basis, waste minimization encompasses the combined approaches of Fn-plant modification and recycle/reuse with the various unit processes which treat or convert hazardous waste to less- or non-hazardous materials. In Figure 1 this approach is depicted by the dashed line. In this focus on the overall environmental goal, the legitimate balance between regulated, approved treatmznt and approaches involving waste reduction is recognized. 3, more systems approach is achieved than with a limited focus on reduction to achieve environmental objectives. The debate between these two definitional approaches is not merely semantics, and can be linked to both the history and future of waste reduction. In the 1980-1983 period the effort to obtain a higher visibility and greater resources for in-plant

51.4 modification and recycle/reuse development was aided by creating a special focus or category (Overcash and Miller 1981, Hunt and Schecter 1986). This allowed industrial and governmental personnel to understand the differences and potential advantages of this emerging technology. If at that stage, a broader definition were adopted then the very limited resources available were likely to be diverted to treatment-only activities as representing the major approaches extant. Thus, to foster more nontraditional waste reduction nearer the source, it was critical to differentiate and emphasize this approach. Such emphasis involved subtle de-emphasis of treatment or waste conversion schemes. With the substantial growth and broad evaluation of approaches to manage hazardous waste, the recognition of solutions involving in-plant modification and recycle/reuse has become wide-spread. It is increasingly rare not to observe substantial commitment to the evaluation of waste reduction by industry generating significant quantities of wastes. With this growth in waste reduction commitment, the broader definition (Figure 1 dashed line) may now be more appropriate for several subtle reasons. First, there are legitimate (that is in compliance with all environmental regulations) approaches which utilize unit processes to treat wastes. Second, the continual subtle de-emphasis or lower priority assigned to treatment alternatives is probably inaccurate when gauged by any broad assessment of risk or major environmental improvement resulting from a narrow versus broad definition (Figure 1 dotted line versus dashed line). There is therefore a potential for substantial divergence of the scientific basis and justification of waste reduction from the perceptual and public opinion of these fields. Such divergence is inherently weakening the ability to protect the environment. In the limit, continual second or low priority may lead to a ban on treatment emanating from -ingrained perceptions of nontechnical issues in hazardous waste management. Such consequences lose sight of the objective in a positive program to stimulate innovative and meaningful consideration (engineering and scientific effort) of different, better ways for reducing truly adverse impacts from waste discharges, whether such approaches involve treatment or in-plant modifications. As an additional note, the European approaches, regarded as reasonably advanced in development (Office of Technology Assessment 1986, Overcash 19861, use the broader definition, except in narrow evaluations of the types of technical approaches used by icdustry.

51.5 PROGRESS Within the debate on successful means to protect the environment and human health, it is however possible to focus on the technologies of in-plant source reduction and recycle/reuse and to discuss progress. Several States and the U.S. Environmental Protection Agency (1986) have assumed the responsibility to implement approaches to xaste reduction. The implementation involves the selected use of public sector resources to stimulate the progress of industry in this field. Such implementation is more complex than the task of consciousness-raising and general guidelines for action. An implementation program must make critical technical decisions with limited resources. Thus, the strategy adopted by states may differ among states and probably will differ from national efforts by trade associations and the U.S.E.P.A.. Clearly, the public sector resources are much less than the total resources (financial and engineering) necessary to achieve major national waste reduction, however defined. Within the broader interest in steadily improving the management of hazardous waste (the entire spectrum from treatment to prevention) some specific focus on the prevention technologies is beneficial. The primary strategy of the U.S.E.P.A. is to stimulate waste reduction. The difficulty in evaluating waste reduction progress centers on measurement versus the several issues surrounding actual manufacturing decision-making in the private sector. An effort is thus made to decouple these conflicting perspectives and develop a measurement system that utilized the factors used by industry to make decisions regarding process changes or recycle/reuse opportunities. In order to develop a measurement approach that reflects the decision-making processes involved in the technology of waste minimization, it is important to focus on the attributes of both concepts. Measurement is important within industry, for government agencies (including Universities), and for society as a means of determining effectiveness. In addition, measurement, when the entire process of managing hazardous waste is included, assists in assuring a complete approach and prevents mistakes of limited objectives. Measurement can also put in perspective the concept of an appropriate level of waste reduction or of any other facet in the overall cycle of hazardous waste management. Industrial decision-making involves to the use of expertise, r-esources, and commitment toward improved hazardous waste management. Since a significant component of waste reduction resides within the private sector then the progress tokrard minimization must build on the positive factors by which industry can invest resources and adopt desirable changes. Thus measurement of progress should reinforce industrial decision-making by presenting realistic alternatives and

51.6 defining legitimate goals that reflect the means by which industry approaches hazardous waste. Within the rapidly growing field of waste minimization, it is a challenge to develop a measurement approach which encompasses the steady adoption by industry of process modification or recycle/reuse. An initial concept has been to relate waste reduction progress to tho mass of hazardous waste reduced. From this concept proposals for industry to achieve targets for reduction have been made (OTA 1981, Center for Environmental Management 1987). However, hazardous waste volume is more useful in defining what wastes might be reduced than in measuring the implementation of cost-effective waste reduction. Thus research has been underway to develop an approach which will measure waste reduction progress by more effectively including the decision-making progress. The specific objectives of this research and for this paper are: 1) to describe current assessment schemes

2) to discuss the anomalies which exist in current measurement approaches 3) to provide an innovative alternative approach for judging the rate of waste reduction technology by industry.

CURRENT CONCEPTS The initial concepts for measuring progress in waste reduction are variations of a single approach which might best be described as a mass-(of waste) based system. The two major measurement variations are:

1) mass of hazardous waste per unit time (e.g. kg waste/year )

2) mass of hazardous waste per unit manufactured product (e.g., kg waste per metric ton ethylene produced). Both of these measurements are examples of absolute scales, Figure 2. That is, a phenomenon is measured and expressed on a scale which has zero as the lowest value. The very nature of an absolute scale is that focus is readily drawn to zero as an endpoint. The call for zero volume of hazardous waste is already illustrated in a recent report by the Office of Technology Assessment (1987). The linear scale of a mass-based system does not differentiate the degree of difficulty in achieving lower absolute values. The existence of an absolute

51.7 51.8 mass-based scale leads to such judgemental goals as a 50% reduction or a 10% reduction per year primarily because of the measurement scheme adopted (the vertical axis). In fact, the progress of an innovative technology, such as waste reduction, is more commonly depicted in Figure 2. The very close connection between the manufacturing technology and the opportunities for waste reduction is an important factor which leads to very different possibilities for waste reduction among industries (Ling 1979). In general, the utilization rate of waste minimization alternatives has an asymptotic characteristic since at a certain level approved alternatives such as treatment or ultimate disposal become more economic. If industry B and C had worked equally hard and implemented all the cost-effective waste reduction possible for their manufacturing unit, the mass-based judgement would adversely reflect on industry C. The mass-based measurement cannot account for such valid differences. Thus a natural zero generation focus conflicts with most actual practices.

LIMITATIONS OF CURRENT CONCEPTS There are a series of substantial anomalies which are generated as a result of a mass-based absolute scale for the assessment of the industrial utilization rate for hazardous waste reduction. The first anomaly is that most assessments begin at a prescribed date, some even utilize the current year as a starting point since waste minimization progress evaluation is rather recent. As a result, no credit for past commitment and utilization of process modification or recycled reuse is received. Thus firms with substantial success are disadvantaged. This anomaly centers primarily on the perception of zero as an endpoint without an evaluation of the potential or feasibility of further reduction or the degree of overall minimization’ achieved. Use of variable baseline or starting periods among industries or manufacturing plants would not resolve this difficulty without an essentially random approach to comparative measures. A second anomaly derives from the essential private sector differences in manufacturinq technologies. The nature of the process may substantially affect the hazardous or other waste production even when the same manufactured product is involved. This is depicted in Figure 2 by industrial plant h and C in which the absolute waste mass (or mass per unit of production) is controlled not by commitment to waste minimization, but by the very nature of the mznufacturing technology. Thus the inevitable comparison of industry A and C could lead to a biased conclusion for industry C which does not reflect the actual utilization of waste reduction technology by both plants. Generally both A and C are achieving compliance with all environmental regulations and thus would only be operating with a different balance of in-plant and treatment technologies.

51.9 The use by different corporations of essentially the same manufacturing technology does not also assure that a similar utilization rate for waste minimization would be adopted. The age, capital depreciation rate, and other factors related to the manufacturing cycle can have a direct impact on either waste generation or the feasibility of waste minimization process changes. This is the third anomaly in regard to the mass-based approach. The rate of adoption of new modifications can be heavily related to a series of relatively much larger manufacturing and related financial decisions. That is, waste minimization must compete on a substantially different basis for capital investment funds when one moves from one firm to another.

A fourth anomaly of mass-based assessment mechanism is that there is a heavy dependence on actual manufacturing volume. The manufacturing level is controlled by a series of market factors and thus variations in production lead to increases or decreases in waste generation per year. Normalizing waste generation by production volume will not solve this anomaly since there may be a nonlinear relation between these two parameters. For example, a sudden product volume increase, due to market demand, might produce a substantial increase in waste per unit product. Capacity for large waste surges may be more easily handled in the treatment arena rather than by providing excess capacity in a waste minimization technology. Thus an appropriate management decision would call for treatment of more waste to comply with environmental standards even though one element of the overall system , i.e. waste reduction would increase. In this case, the complex manufacturing/treatment economics 'lead to a changing waste reduction picture with variations in the overall production rate. A reverse case may occur when product demand drops forcing much more critical attention on eliminating inefficiency'. In this case, wastes are reduced SO that profitability is maintained. Thus it is clear that the substantial manufacturing decision-making influence on waste production (mass/year or mass per unit production) leads to largely incomparable systems even if all industry had the same commitment and resource utilization directed at hazardous waste reduction. The anomalies described above reduce the suitability of a mass-based approach for the only measure of national progress in waste reduction. In other words, the simplicity of a mass-based assessment is an illusion when used to compare even two manufacturing systems, much less a State, an industrial category, or a national trend. However, evaluating hazardous waste volume in relation to waste reduction can serve an important role. The advantages in a mass-based approach are

51.10 most prevalent in the task of defining which wastes should be considered for reduction. Both toxicity and volume are used in establishing priorities for engineering efforts with in-plant or recycling/reuse alternatives. It is also important to consider economics and relative feasibility when investing resources in a corporate waste reduction effort. It is also clear that if the economics of waste management are small or insignificant then mass or chemical concentration are the useful evaluation criteria. In this author's experience, such circumstances are not common, and that eventually the cost of pursuing smaller levels of waste for further reduction become the controlling principle in corporate decisions. It can also be observed that hazardous waste mass can be easily obtained and therefore should be the measure of waste reduction progress. If, however, this accessible information requires substantial work to explain the various anomalies in a nontechnical setting, then the suitability as a national industrial measure is greatly reduced. Further, mass or volume is only one of many factors which are included in the thought process for investing resources in waste reduction. Minimizing a small toxic constituent in a waste stream may be more beneficial than a large volume of inert constituent reduction. Thus, a mass-based system cannot reflect other waste characteristics. Finally decision-making in waste reduction is more critically dependent upon economic feasibility and thus a mass-based system cannot completely represent the underlying mechanisms by which industry pursues waste reduction.

ALTERNATIVE ASSESSMENT OF WASTE REDUCTION TECHNOLOGY ASSESSMENT , Research conducted by the author has sought significant improvement ' in the current schemes for evaluating the utilization rate of technology for the reduction of waste. The first step was to re-evaluate the overall objective for such a program. In a substantially non-regulatory arena, and with a heavy dependence on substantial private sector decision-making, there is an advantage in a measurement concept which gauges the potential for waste reduction. That is, could one evaluate the rate of utilization by measuring the economic basis on which industry renders decisions. Having quantified the feasible waste reduction choices for any manufacturing unit, it is then possible to challenge industry to undertake a reasonable rate of adoption for economically feasible waste reduction. Instead of an absolute scale, this might be viewed a scale of potential for waste reduction in which the endpoint in measuring national progress is a hundred percent of the potential for waste minimization.

51.11 The development of such a feasibility scale would proceed with conceptual stages of,

1) defining the baseline economics for alternatives used in regulated hazardous waste management 2) establishing technical alternatives for the process modifications and recycle/reuse alternatives

3) estimating the economics of these waste reduction options

4) calculating the costs of waste reduction relative to other alternatives or the potential for economic feasibility in waste reduction.

STAGE 1

Regulated management of hazardous waste involves the use of treatment, stabilization, and/or disposal in such facilities as underground injection or secure landfill. There should be a continual technical and economic review of these alternatives by each industry as a matter of sound fiscal policy. In a general circumstance, these alternatives and costs might be displayed as in Figure 3. There are multiple options with different costs. The economic axis can be costs or more usefully cost per unit of waste treated or managed according to all environmental regulations. Through these means one can'determine a baseline for the economics of these alternatives foT managing hazardous waste. Some approximate measure of the several least cost alternatives would be established, as depicted by the dashed line - in Figure 3. This baseline defines approved regulated choices of a manufacturing unit and reinforces that such treatment alternat.ives are permitted. The definition and economics of the treatment and disposal options allows for factors such as plant location, local -- alternatives, transportation distances, and the current ~ situation at a manufacturing unit. This would be expected to vary among industrial categories even in the Sam3 general location. However, within an industrial group it is reasonable to expect a greater uniformity in the economics for regulated hazardous waste. Further, the nature of these information are _____ not highly proprietary since the actual alternatives (bars in ~ Figure 3) may be listed with only letter designation. The dashed line thus defines one asymptote to be used in the determination of appropriate waste minimization (in-plant or

51.12 COSTS,

OR cn P $/MASS P w OF

WASTE

DISPOSAL LIMIT

TD TD 4 5

Figure 3 Costs (expressed in appropriate units) for hazardous waste treatment or disposal options as determined at individual manufacturing facility. recycle/reuse). These costs are the lower direct economic limit on waste minimization feasibility.

STAGE I1 In the next phase for evaluating waste minimization progress, each manufacturing facility must identify in-plant and recycle/reuse choices. These alternatives are usually quite plant specific and represent current options. Previous waste reduction alternatives would have already been adopted and therefore not included. The choices would be developed with the variety of approaches used by industry. For example, waste audit procedures (U.S.E.P.A. 1987) could be used, specialty consultants employed, the State waste reduction sources could be consulted, or other techniques used. The primary objective is to undertake a broad and innovative approach which in a reasonably exhaustive manner establishes a full range by which a specific plant might reduce wastes. At this stage, the same level of development or feasibility details among alternatives are not needed since this overall process is best viewed as iterative (possibly every 2-5 years).

The alternatives identified (which need only be listed by letter or generic designation) are evaluated in detail to establish the cost for undertaking each choice, Figure 4. The economics can be in costs alone (capital, operating, or annualized values) or in cost per unit of waste or waste constituent(s1 reduced. In many cases, a series of alternatives will be available. The author's experience and that of others (Schecter 1987, Fromm 1987) is that wit'h a steady focus on pollution prevention and innovative use of engineering and existing techniques that multiple options are available in many plants. This observation is modified by the degree of previous waste - reduction activity at a particular plant. Thus it is expected that at some locations no alternatives may exist, but this would generally not be the case. At this stage, little or no economic prejudgement is given since the objective is establishment of alternatives. Further, a high degree of technical feasibility may not be necessary. Experience has shown that detailed studies and pilot-scale testing are needed to give missing information to establish actual feasibility. A considerable range in number of alternatives usually result from this second stage. Since a number of waste reduction schemes are actually profitable, these alternatives have a negative cost, Figure 4.

51.14 I ~ -1

. U Cll

51.15 STAGE I11 The treatment or disposal limit can be transferred to Figure 4 and a new depiction of the relative treatment or disposal costs versus waste minimization is gained, Figure 5. The potential for waste minimization (in-plant or by recycle/reuse) is obtained from Figure 5. The waste reduction potential is defined as the cost difference between the individual alternatives and the treatment or disposal limit, Figure 5. One may express this difference in costs figures or a waste minimization percentage of the cost for the treatment or disposal limit. A waste minimization percentage representation provides a useful relative judgement of any given waste reduction alternative to the cost of current hazardous waste management expenditures. The alternatives with a positive waste minimization potential (A, B, C, & F) would be those expected to be implemented by a particular plant. Again this measurement technique allows for significant inclusion of local conditions which actually establish the progress of the waste reduction philosophy, even on a national basis. In Figure 5 a number of alternatives have a substantial negative potential for waste minimization and might be expected to be inappropriate for adoption. Some modification of this balance point is described in a later section. Concern has been expressed that such an evaluation approach leads inevitably to no potential for waste minimization. Such a concern warrants closer scrutiny. First the experience of numerous case studies, corporate reporting, experience in State programs clearly demonstrates that there are generally positive potential alternatives. That is, techniques can be found to give some reduction in hazardous waste volume generated in a manufacturing facility. It is the disciplined, stepwise process of reviewing treatment or disposal options and costs, the innovative development * of alternatives, and the careful review of waste reduction options which repeatedly leads to waste minimization alternatives that are cost-effective (Versar and Jacobs 1986, Fromm and Callahan 1986). Thus, practical experience carefully gained over the last 1-5 years suggests that alternatives will be identified. Further, as reports and industry association studies are assembled, it will become clearer if major inaccuracies exist using such a plant-specific approach. However, at this stage the success and positive discussions by industry suggest that a concern for identifying no waste minimization potential is unfounded. However, it must be recognized that the sign of successful waste minimization will be to reach the point at which "no" alternatives exist having a positive potential for implementation (as developed in this evaluation scheme). It is desirable to reevaluate the existence of waste minimization alternatives at some recurring interval since the economics of both the treatment or disposal options and the availability of

51.16 K 0

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51.17 waste reduction or recycle/reuse options are constantly changing. The research or more in-depth engineering challenges .are established by those alternatives with a negative potential or large wastes remaining after implementing the options with a positive economic potential.

Modification of a Strict Economic Feasibility Criterion The use of a treatment or disposal cost limit for judging feasible waste reduction can be further modified. It is suggested in much public debate and in a number of industrial circles that some costs or economics are difficult to quantify. Beyond such an observation it is also difficult to agree on the magnitude of such missing costs. The waste minimization evaluation techniques developed herein allows for the specific inclusion of undefined costs associated with industrial discharges or associated with the liabilities of generating such wastes. If one chose to establish that there be an additional cost equal to 10% (as an illustration) of the current treatment or disposal economic limit then a new calculation of the waste minimization potential would result. This change would be shown in Figures 4 and 5 from which the waste reduction potential and alternatives are changed, Figure 6. In this illustration the in-plant modification labeled G would now be less expensive than the available treatment or disposal limit. This would mean a positive potential for adoption, Figure 6, rather than a negative choice, Figure 5. These modifications of techniques to be adopted would clearly be plant-specific and thus reflect the decision-making process of each manufacturer; It is important to understand the implications of an extra margin of treatment or disposal costs, such as that described herein. The method in this paper would more adequatelyaassess the national economic consequences of such actions. With the information obtained from individual plants in a range of industries it would be possible to establish how much more waste minimization might occur. Further, the calculational procedures described herein are the only method currently available to establish how much more society will pay for such a reduction. Without such a cost rationale the establishment of a percent margin to account for unknown liabilities or costs is guesswork for which little measure of economic implication is available. As previously stated, adding a margin to stimulate waste reduction implies that the standards for acceptable treatment are wrong or inadequate since waste reduction and treatment are balanced to achieve environmental compliance.

51.18 COSTS , $ OR $/MASS OF WASTE T. or D.

SAVINGS

WASTE REDUCTION POTENTIAL,

COSTS OR % COST (+) OF T. or D. 0 A B LIMIT (-1

Figure 6 Revised treatment or disposal economic limit (raised 10% and resulting changes in potential for waste minimizatio options

51.19 STAGE V Collective Assessment of National Progress In the course of waste minimization certification, each plant would prepare a document establishing that a programmed investigation of waste reduction and recycle/reuse options had been completed. The extent of progress on a State or national level could then be determined. A random subset of each standard industrial category (SIC) would be selected and the number of waste reduction options actually implemented could be quantified. This measure of progress would establish the percent of all feasible waste reduction options that had been adopted on a certain anniversary. At that time the progress toward waste minimization, relative to any margin of incentive, (limit line, Figures 4 and 6) would be established. The national endpoint would then be 90-100% of all in-plant or recycle/reuse options with a positive endpoint or potential for implementation. In addition, the resulting reduction in mass or other measure of toxicity of wastes could be simultaneously asses sed. In this manner a measurement scheme which more accurately reflects the basis for industrial decisions is achieved without a primary mass-based scale of waste reduction.

RELATIONSHIP OF MEASUREMENT APPROACHES The conflicts, difficulties, and inaccuracies associated with the use of a mass-based measurement scheme to judge national waste reduction progress were described earlier in this article. The objectives in this research effort were to develop a measurement approach which adequately reflects national progress, but also resolves the anomalies present with a mass-based system. An alternative has been proposed and a specific review of the resolution of these anomalies is given in this section. It is envisioned that a mass-based system would continue in' use to direct waste reduction activities, .but is less suited to measuring national progress. In those firms which have already implemented waste reduction options (whether a few or many) the judgement of current status using the economic-based approach is made only on the remaining alternatives. That is, progress is acknowledged and, in the limit, if a firm had completed all options then no choices with positive potential would be available. That firm would be acknowledged as successfully achieving the goals of waste reduction and not be penalized for not having a continuing reduction in mass of wastes. An acknowledgment is also made that an appropriate balance had been achieved between treatment or disposal versus in-plant modifications or recycle/reuse. This balance is altered if the treatment or disposal techniques were to rise in cost. If further acknowledgment of previous

51.20 commitment to waste minimization is desired then Figures such as 4 and 5 could be prepared as the situation existed in some previous year (e.9. 1984) and thus reflect th.at historically a firm had implemented waste reduction. Thus the anomaly of little further hazardous waste mass reduction due to past accomplishments is resolved by focusing on an endpoint of adopting all cost-effective options. A balance between treatment and waste reduction is carefully described by this feasibility-based system for measuring industrial progress in pollution prevention. The manner in which each plant evaluates and describes the options for in-plant modifications and recycle/reuse makes it clear that each plant must legitimately weigh these choices using plant-specific data. In this way local circumstances are included directly in the methodology to measure national progress. Thus the second mass-based system anomaly, the inclusion of different specific manufacturing technology, is avoided since only the economics of a manufacturing location are used. The further (third) ancmaly of corporate locations with similar manufacturing technologies, but different age or economic life is also resolved. In this case the list of positive waste reduction options is specific to the existing treatment alternatives as well as the costs or paybacks for available waste reduction alternatives. This approach thus tracks more accurately the progress and realistic expectations for industry. Since waste minimization choices are' also dependent in a nonlinear fashion on the level of manufqcturing output, the iterative evaluation of options to reduce waste is an important feature of the proposed cost feasibility approach. With the focus- on economic potential or feasibility a plant might adopt in-plant modifications or recycle/reuse during those parts of the production cycle when it is mcst favorable. The use of treatment would accommodate increased wastes due to production increases to the extent determined by the relative economics of either choice.

SUMMARY AND CONCLUSIONS A number of technical, economic, and philosophical concepts have been presented surrsonding the evaluation of national progress with in-plant mcdification or recycle/reuse to reduce hazardous wastes. These issues are equally applicable to air emissions, wastewater discharges, or any multi-media approach. Specific conclusions were r;Eched from this research.

51.21 (1) A number of waste reduction decisions involve in-plant modifications. These decisions are imbedded in a very large complex, cost competitive system which the United States relies upon for manufacturing. This system allows competitive, free-market selection by industry of manufacturing technology. Thus, there are important nontechnical issues involved in the means by which those outside a corporate structure use to encourage waste reduction. Other aspects of waste reduction such as recycle/reuse may be more independent of private sector manufacturing decisions.

(2) Two interpretations exist of the national effort to reduce waste and improve the environment: reduction: alonly techniques which reduce wastes in-plant or find alternate reuse options constitute waste reduction blall techniques which reduce the broad distribution or long term storage of wastes are candidates leading to protection of the environment through waste reduction (3) Since the in-plant and recycle/reuse options are often profitable or represent minimization of costs, these are logically given priority in industrial decision-making. However, this priority is primarily one of timing not in relative economics. Thus, the priority can mistakenly lead to a second class status for approved forms of treatment with concern that banning of treatment may evolve as in the case for landfills. The need for a balance between 'in-plant options and treatment technologies is important. (4) It is appropriate to evaluate on a national or state basis the progress made by industry in reducing wastes in-plant or by recycle/reuse. -This is also true of the total hazardous waste generated, treated, or managed in perpetual storage. However, the current measures of source reduction or recycle are mass-based and appear to have substantial anomalies as an appropriate measure of national progress. These anomalies reflect the fact that mass-based systems may be more useful in identifying wastes to be reduced. Mass-based systems do not necessarily reflect toxicity reduction. Thus the goal of an economic potential approach is to measure progress and can be used with mass or toxicity reduction planning efforts.

51.22 (5) A new progress measurement was developed on the concept of establishing the potential within industry for waste reduction and then to move toward achieving 100% of that potential. The potential is the positive economic factor comparing the cost of process modification or recycle/reuse to the cost of approved treatment or disposal. (6) Four stages are involved in calculating the potential for waste reduction at an individual plant with a fifth stage used in establishing the national progress toward lowered generation of wastes. These are: a) establish a cost for regulatory-approved treatment or disposal of hazardous waste (several cost bases can be used). This is the base economic limit b) define a complete range of alternatives which contribute to hazardous waste reduction by in-plant modifications or with recycle/reuse options. c) the costs of each alternative is estimated and displayed as a bar chart. Generic listing of options may be used in outside reporting d) the difference in cost for each alternative and the base economic limit for treatment or disposal is calculated and becomes the potential waste reduction savings of each option. All options with a positive dollar value would represent the pool for implementation at a given plant. Then the fifth stage would be the use of government resources to achieve and measure progress toward all the waste reduction alternatives identified as having positive potentia’l. Federal and State evaluations of progress (such as future Reports to Congress) would focus on the validity and sufficiency of waste reduction alternatives at plants. Actual statistical data could be obtained on the average number of options at individual plants within each industrial category. Data on the percentage of these options actually achieved would be the measure of progress integrated across the diversity of industrial manufacturing plants. Corollary information on mass reduction can also be obtained. In this manner a realistic measure of progress in waste reduction is achieved in which the factors controlling further progress are more clearly demonstrated . since the basic feature of industrial decision-making is directly reflected. (7) The decision-making and economic feasibility approach

51.23 described above represents a major concept for measuring national progress in hazardous waste reduction. A mass-based approach has substantial difficulties in gauging national progress, but is useful in planning areas for in-plant or recycle/reuse development. The advantages of an economic measure of progress is that it parallels industrial decision-making. These decisions are on actual in-plant modifications as well as the balance between waste treatment and waste reduction. An economic-based measure of progress - appears to correct the anomalies associated with various mass-based concepts. Finally, the evaluation of potential for reduction fits logically with the waste minimization certification concept in HSWA 1984 and the EPA Hazardous Waste Audit procedures (1986).

ACKNOWLEDGMENTS This research was developed as a part. of a cooperative agreement with the U.S. Environmental Protection Agency, Office of Research and Development, Hazardous Waste Environmental Research Laboratory. Specific support and cooperation from Dr. Harry Freeman, Dr. Clyde Dial, and Dr. Tom Hauser have made this work possible and has encouraged new approaches to waste reduction. Early work on these concepts was supported by the North Carolina Pollution Prevention Pays Program. In addition, the opportunity afforded by the Tufts University Waste Minimization Policy Forum to clarify the concepts herein was appreciated.

REFERENCES ,

1. Center for Environmental Management, Waste Minimization ‘Policy’Forum, Coolfont, W.V. July 13-15, 1987, . Tufts University, Medford MA, 34p. 1987 2. Fromm C. H. and M. S. Callahan, Waste reduction audit procedure, Hazardous Materials Control Research Institute .__ Conf. Proc. Atlanta, GA, 427-435, 1986. 3. Fromm, C., Personal Communications, Jacobs Engineering Pasadena, CA 1987. 4. Hunt, G. and R. Schecter, Accomplishments of N.C. Industry. N. C. Dept. of Natural Resources and Community Development, Raleigh, N.C., 36p. Jan. 1986. 5. Ling J. Preface in Pollution Prevention Pays, Pergamon Press, New York, N.Y., 197p. 1979.

51.24 6. National Research Council, Management of Hazardous Industrial Wastes: Research and Development Needs, Sublkation NMAB-398, National Academy Press, kuashiqton D.C. 76p. 1983. 7. Nationa.1 Research Council, Reducing Hazardous Waste Generation, National Academy Press, Washington, D.C. 359. "1985.

8. Office a'f Technology Assessment, Technologies and Management Strategies for Hazardous Waste Control, OTA-M-396, OTA, Washington, D.C. 407p. 1983.

9. Office -Of Technology Assessment, Serious reduction of hazardous waste, OTA-ITE-317, OTA, Washington D.C., 254p. 1986. IO. .Odfice,af Technology Assessment, From pollution to prwaxtion: A progress report on waste reduction -

~ special report OTA-ITE-347, Washington, D.C., 54p. June 7987.

11. CWercas%, M. R. and D. Miller. Integrated Hazardous Waste -Management, Today Series, Amer. Inst. Chem. Engrs., Hev Xmrk, NY', 580p., 1981.

12. Overcash-, M. R. Implications and Procedures for Waste Elhb,zition of Hazardous Wastes, Ed. D. Huisingh and Y:*Ba-iley, Pollution Prevention Pays, Pergamon Press, -'6.8-7'@. 1982. 13. @~ercash,M. R. Techniques for Industrial Pollution Frexmrtion, Lewis Publishers, Chelsea, MI. 203 p. 1986.

14. Aqstm,' M. G. Pollution Prevention Pays. Pergamon Press, New:Y-ark, N.Y., 197p. 1979. 15. Sebe-rrt-e-er, R. Personal Communications, N. C. Natural fZesavrces and Community Development Dept. Pollution -fsexenTion Pays Program, Raleigh, NC 1987.

16. U.5. E2P.A. Report to Congress: Minimization of Haza?kbus Wastes. EPA/530-SW-86-033, Off ice of Solid WastEr;, USEPA, Washington D.C. 133p. 1986. 17. Versar and Jacobs. Waste minimization: issues and options, ..- - "YP~.'.XI, U.S.E.P.A. , Washington, D.C., C3t. 1, 1986.

51.25

IN FOOD PLANTS POLLUTION PREVENTION IS MORE ECONOMICAL THAN PRETREATMENT Roy E. Carawan 1 In the last 25 years, many food plants have experienced four-to ten-fold increases in municipal water and sewer bills. At the same time, new and expanded rcunicipal ordinances are imposing increasingly stringent restrictions on waste discharges to Publicly Owned Treatment Works (POTWs) , and many food processors are finding that pretreatment technology adequate to comply with municipal restrictions is prohibitively expensive. The enactment and enforcement of sewer use ordinances, pretreatment ordinances, and surcharges are threatening the economic viability of some food processing plants, and growing water supply and waste disposal costs will continue to take larger and larger bites out of all food processors' profits. Only consistent and strong advocacy from top management can guarantee successful efforts to control these escalating water and waste costs. Since the lowest cost control measures are usually those that attack the problem at its source, food industry managers should become thoroughly acquainted with the Pollution Prevention Pays concept and consider its potential applications in their plants. Whether managers must act to comply with increased municipal waste load restrictions for existing plants, make decisions about process design for new or expanded facilities, or respond to bottom-line pressure from shareholders, adoption of water conservation and waste reduction programs should receive first consideration. Pollution Prevention Pays

Joseph T. Ling of the 3-M Company is generally credited with originating the Pollution Prevention Pays concept. Dr. Ling advanced the idea that the conservation approach should be used to eliminate the causes of pollution--which he identified as waste-- before spending money and resources to clean it up. Dr. Ling defines the conservation approach as the practical application of knowledge, methods, and means to provide the most rational use of resources. Dr. Ling concluded that government, industry, and the public are beginning to become aware of the shortcomings and enormous cost of conventional pollution controls. He also pointed out that pollution controls do not solve but only alter pollution problems.

' Department of Food Science (Extension), North Carolina State University, Box 7624, Raleigh, NC 27695

52.1 For example, pretreatment of food plant wastewater does not eliminate pollution. It only generates sludge which must be handled in such a way as to prevent it from becoming a pollutant. As wastewater pretreatment or treatment requirements become more stringent, and sludge disposal becomes more difficult and costly, the resources that a company must commit to these processes continue to increase. Dr. Ling defined this environmental paradox as follows: "It takes resources to remove pollution: pollution removal generates residue; it takes more resources to dispose of this residue, and disposal of this residue also produces pollution. It was his recognition of this pollution cycle that led Dr. Ling to conclude that significant economic benefits can accrue to companies which seek more realistic and effective solutions to pollution through conservation-oriented technology.

Food Industry Must Change Attitude About Water Use Water is becoming an increasingly scarce and costly commodity. Increased domestic demand fueled by a growing population, increased industrial and agricultural demand, and degradation of many water sources have combined to bring an end to the era of cheap, high- quality water. Recent droughts have underscored the fact that there are now greater numbers of people competing for less high- quality water. Food processors need clean, pure water and should be concerned about water availability. However, the people at the top of the management structure in the food industry should be concerned about more than just the short- term availability of water of sufficient quality for food processing. Those who are responsible for the future of the industry should also be concerned about the depletion or loss of water resources and about the effect on water resources of the disposal of industrial wastes including both processing residuals and wastewater treatment process residuals. Each area has technological, economic, legal, regulatory, and image concerns. These factors combine to make water supply and waste disposal issues critical in the location and continued operation of many food plants. Over the last two decades, the public has become increasingly vocal about maintaining the quality of our groundwater and water in our streams, rivers, estuaries, and oceans. Public concerns about water quality have prompted new economic, regulatory, and political changes that necessitate a change in attitudes about water use in the food industry.

52.2 Food Processing Operations Use Large Volumes of Water Water is important to the food industry. It is an ingredient in many food products, and it is used for washing products, blanching, making syrups and brines, cooking, cooling, cleaning, and sanitation. Obviously, food processors use large amounts of water. For example, * dairy plants use about three gallons of water for every gallon of milk processed: * meat processors use about one gallon of water for every pound of hamburger produced; * vegetable processors use about one gallon of water for every can of sweet potatoes produced. (See Table 1 for other examples) Table I As the water is used in the food plant, parts of the food product being Water Use in Food Processing processed are deposited in the water, and this wastewater must be ITEM QUANTITY OF WATER properly handled to USED FOR prevent pollution. PROCESSING (GAL) Water use in food processing plants is dependent on the kind of One Fryer 8 - 13 products produced, the processes utilized Can Sweet Potatoes 1-4 (including whether the process is dry or wet), Can Apples 1-2 and production capacity. Some large food plants, Can Green Beans 1-2 suchasbakeries, mayuse less than 20,000 gallons 1 lb. Hamburger 0.5 - 1 of water per day while others, such as canning 1 lb. Pork Chops 1-2 plants, may use up to 20 million gallons per day. 1 gal. Beer 6 - 10 Most North Carolina food processing plants use 1 gal. Milk 1-3 less than 100,000 gallons per day. However, some of our poultry processing plants--which are among the largest in the country--use and discharge more than 4 million gallons per day.

52.3 In most food plants, water used for washing, conveying, processing, cooling, and clean-up is discharged as wastewater. However, breweries and soft drink plants incorporate as much as 90 percent of their water use into their products. Wastewater Treatment Is a Hidden Water Cost

Water cost for food processors has not been a major concern in the ____ past. Even today, most food plants pay only $0.20 - $2.00 per thousand gallons of water used. In North Carolina, most plants pay about $1.00 per thousand gallons. Is this a significant cost? In answering that question, remember that water not put into the product must be discharged, and treatment is often required. A food plant using 5 million gallons of water per day could face water and wastewater costs exceeding $2.5 million annually. Past studies and the author's personal experience indicate that plants with the least amount of water use per unit of product processed have the least amount of pollutants per unit processed. How can water use impact the food industry in the future? In South Dakota, legislation has been proposed that would impose a fee of $.002 per gallon for water use including production and processing. This would raise the cost of one pound of hamburger by $14 and the cost of milk would increase by $19 per gallon. Consumers have indicated they want clean water, but it is obvious there is a limit to food prices consumers will pay, so how would such surcharges affect food industry profits and the availability of food products? Treating Wastewater Is Costly Treatment of wastewater from agricultural products processing plants-can be costly and complex. High strength wastewaters and highly variable seasonal loadings make many treatment schemes ineffective and not cost efficient. Biochemical oxygen demand (BOD,! is the most-used test for measuring the waste concentration in wastewater from food processing plants. The BOD, test indicates the amount of oxygen that will be consumed by the biochemical oxidation of wastewater. The test is widely used because in wastewater from food plants oxygen deficiency is usually the cause of polluted water and fish kills, and processes to reduce oxygen demand are often the most costly of wastewater treatment.

~~ High BOD, in food plant effluent is usually an indication of inefficient processes and is directly related to food products in the wastewater. In fact, BOD, can be estimated in food plant wastewaters by determining the fat, protein and carbohydrates in a wastewater and using the following factors:

52.4 Food Constituent Pounds BOD, Der pound of food constituent Carbohydrates 0.65 Fats 0.89 Protein 1.03

BOD, and other characteristics of food processing effluents are highly variable, as is effluent volume. The BOD, may be as low as 100 milligrams per liter (mg/l) or as high as 200,000 mg/l. Suspended solids, almost completely absent from some wastes, may be found in other wastes in concentrations as high as 120,000 mg/l. Wastes may be highly alkaline (pH 11.0) or highly acidic (pH 3.5). Nutrients such as nitrogen and phosphorus may be absent or they may be present in concentrations that inhibit efficient biological wastewater treatment. The volume of wastes may range from more than a million gallons per day per plant in heavy processing seasons to virtually a trickle at other times.

One food processing plant may have biochemical oxygen demand (BOD,) equal to that of a city of a quarter million people. The BOD, concentration of food plant wastewaters is typically 10 to 100 times greater than domestic sewerage. Agricultural products processing wastes are largely compatible with conventional biological treatment and land application of sludge. Common treatment processes for food plant wastes include land disposal, anaerobic ponds, aerobic ponds, activated sludge, clarifiers, trickling filters, and rotating biological contractors (RBCs). But, even after costly treatment, food processing wastewaters discharged directly into surface waters can impose a serious burden on small streams and even large rivers. Some food plants are located so they can utilize land application of wastewater. Land application sites may need to exceed one thousand acres of suitable soil for proper disposal. Such sites are limited, and this limitation could hamper industry growth. Moreover, when chemicals are used (as lye for peeling vegetables, chlorine for sanitation and cleaning, or sodium chloride for pickling operations) unique disposal problems exist. Toxics are not often a worry for the managers of most agricultural processing plants. However, laboratory wastes can present difficulties, and as regulations become more restrictive and analysis techniques more sensitive, highly alkaline or acidic wastewaters or wastewaters containing copper, zinc, chrome, or chloride may require additional pretreatment.

52.5 More Municipalities Are Requiring Pretreatment, Levying Heavy Surcharges The disposal of wastewater from food processing plants to POTWs incurs two types of costs: (1) cost of pretreatment and disposal of pretreatment residual or sludge, and (2) cost of discharge. Discharge costs include sewage fees and any surcharges. Currently sewer costs in North Carolina average about $1.00 per 1,000 gallons. Food plants in other states pay sewer charges that range from $0.20 to about $6.00 per 1,000 gallons. Surcharges are levied for waste loads discharged above some limit. Surcharges are assessed for BOD, , total suspended solids (TSS), fats, oils and greases (FOG) , total kjeldahl nitrogen (TKN), phosphates, and other waste constituents. BOD, costs range from $0.25 to $2.00 per pound while TSS surcharges range to almost $3.00 per pound of excess suspended solids. The maximum surcharge for North Carolina food plants is about $0.40 per pound for both BOD, and TSS. Pretreatment Is Costly and Usually Not Adequate to Meet Restrictions Municipal pretreatment requirements for food plants discharging to POTWs can include effluent restrictions on selected wastewater parameters such as BOD,, chemical oxygen demand (COD) , FOG, TKN, and flow. Many municipalities have already imposed such limits in their pretreatment ordinance to help provide for safe and more efficient wastewater treatment and to control discharge of pollutants. To meet pretreatment requirements, food processing plants may adopt processes ranging from pH control and flow equalization to full secondary treatment. Conventional pretreatment technology is based on use of equipment such as clarifiers, separators, and/or dissolved air flotation (DAF) units to remove settleable and/or floatable solids. Pretreatment processes that are economical and easy to operate are not readily available for most food processors. As more municipalities require pretreatment, improvements in the processes become necessary. Perhaps the best pretreatment schemes involve using food residues to produce methane for fuel and treating and recycling wastewater into potable water for reuse.

Pretreatment Costs May Be Higher Than Sewer Costs Pretreatment and sewer use ordinances can impose significant restrictions on food plants. Pretreatment costs are always

52.6 significant, and sometimes there are no pretreatment processes available to the food processor that will accomplish what ordinances dictate. Special agreements are necessary to exceed limits in almost all cases the author has studied. Requirements for testing such as for chronic toxicity can easily push costs for monitoring above $ 1 million annually for a large food plant. Recently, the author worked with a snack food processor who was predicting variable costs for treatment (fat separator, clarifier, activated sludge, sludge disposal) that exceeded $5.00 per pound of BOD,, and this did not include a fixed cost in excess of $250,000 for a 20,000 gallon per day discharge. Analytical costs and permit records and reporting are also becoming significant costs. A quick survey of a number of poultry and dairy plants produced interesting numbers. It appears that pretreatment costs may exceed the costs many municipal systems charge for BOD, and TSS removal. Not enough information is available for a comparison of pretreatment and treatment systems for nutrient removal. BOD, removal costs for pretreatment ranges from $0.11 to $0.27 per pound of BOD, removed at the pretreatment system. Thus, removal costs may exceed $0.30 per pound of BOD2 removed. Many municipal systems operate more efficiently than this. The environmental director of a large dairy firm has said, ttYou cannot operate a pretreatment system cheaper than the city." He indicated that current wastewater disposal charges in the Midwest for his plants ranged from $0.23 to $0.28 per pound of BOD,. Some of these plants have pretreatment and some do not. Those plants with pretreatment have costs for pretreatment ranging from $0.21 to $0.24 per pound of BOD,. Depreciation and capital account for 20% of these costs while power, labor, chemicals, and sludge disposal account for the remainder. Management and Process Changes to Reduce Water Use and Waste Generation Can Be More Beneficial than Pretreatment For most food processors, pretreatment may be the least desirable way of reducing waste load. There are other proven ways to reduce water use, product loss, waste loads, and wastewater discharge. One method is to operate the plant more efficiently. The second is to institute process changes that result in a conservation- oriented operating environment. The author has participated in a number of water and waste management studies. These studies were performed to help food processors apply their ingenuity to develop cost effective resource conservation know-how. Savings of up to 72% have been demonstrated in some plants.

52.7 Table I1 Much of what is reported was known to Pollution Prevention Potential the general industry but was not practiced STUDY POLLUTION by the plants studied. PREVENTION The help, resources (Pounds of BOD5/year) and encouragement of the ~ollution Hunter 226,400 Prevention Program and Maola 320,000 the North Carolina Maola-I1 320,000 Agricultural Extension Beaufort 250,000 Service made these 60,000 accomplishments Randolph possible. In most food plants, corporate engineers could duplicate these accomplishments. Several food processing plants were studied to determine the feasibility of process and management changes to reduce the waste load. The net savings were predicted for these plants using the following formula:

WHERE NS (L) = NET SAVINGS (LOSS) IR = INCREASED REVENUES RC = REDUCED COSTS IC = INCREASED COSTS

Table 111

Ratio of Increased Cost, Initial Cost, and Waste (BOD,) Reductions

INCREASED COST INITIAL COST SAVINGS STUDY WASTE REDUCTION WASTE REDUCTION WASTE REDUCTION

...... ($/1,000 lb BOD,)------

Hunter 333 737 278 Maola 347 645 1062 Maola-I1 109 167 945 Beaufort 1243 1260 3589 Randolph 99 75 13

52.8 Five studies included Hunter (fluid milk plant), MAOLA (dairy plant), MAOLA I1 (an alternative study, another set of changes at the same dairy plant), BEAUFORT (fisheries plant), and RANDOLPH (beef slaughter plant). The potential reduction in waste load for these studies varied from 60,000 to 320,000 pounds of BOD, per year (Table 2). The increased cost is the total cost that the plant would incur with implementation of all the changes studied. As surcharge costs do not usually exceed $0.40 per pound of BOD, in North Carolina, any waste reducing measures incurring increased cost not exceeding $400 per thousand pounds of BOD, reduction ($.40 per pound of BOD,) should be implemented by any food plant as long as capital considerations do not preclude the change. Of the five studies, only BEAUFORT had increased costs exceeding this level (Table 3). As BEAUFORT is in a coastal area and wastewater treatment costs will be more than for many other locations, savings of $3589 per 1,000 pounds of BOD, were predicted. The savings predicted in these studies ranged from $13 per thousand pounds of BOD, reduction at RANDOLPH to $3589 per thousand pounds of BOD, reduction at BEAUFORT. Studies Reveal other Impacts of Reduced Water Use

A consulting engineer has Table IV estimated that a reduction in water use at a poultry plant Capital Cost for could have a significant impact Dissolved Air Flotation on the cost of a pretreatment For Poultry Processinga system. The capital cost for a dissolved air flotation unit for a 200,000-broiler-per-day WATER USE COST processing plant would be (GPB) $450,000 -for- water use of 8 gallons per bird and $375,000 3 $335,000 for 3 gallons per bird. Thus 8 480,000 water use reductions pay not only by water and sewer cost a 200,000 birds/day reductions but also by the cost gallons per broiler of pretreatment facilities. Further, operational costs for pretreatment such as power and chemicals would be reduced with the smaller wastewater flow-- another reason to properly manage water and wastes in food plants. The author has found that food plants that use the least amount of water per unit of product have the least waste load per unit of product when compared to other similar plants. However, sometimes water use reductions on a percentage basis will exceed waste load reductions. In such cases, plants can reduce their waste load only to see their wastewater concentration increase. Note the concentration of BOD, before and after changes for BEAUFORT. The

52.9 Table V

Estimated or Measured BOD, for Food Plants Studied Study Products MG/L BOD, MG/L BOD, Processed Before Changes After Changes

Hunter Mi lk/Dr inks 1,800 1,200 Maola Multiproduct 2 ,900 1,900 Maola-I1 Multiproduct 2 ,400 1,900 Beaufort Menhaden-Surimi 2 ,500 4,500 Randolph Beef 2 ,543 610

concentration increased to 4,500 mg/l from 2,500 mg/l even though there was a significant reduction in waste load. This supports the concept of mass load limits for food plants.

Public Image and Plant Efficiency Are Additional Reasons to Consider Water Use and Waste Generation Reduction There are two reasons in addition to reduced cost and compliance with municipal POTW restrictions that management and process changes might benefit a food processor more than adoption of end- of-pipe pretreatment technology. First, most food processing plants are very concerned about public image and do not want to be seen as polluters. Food plants processing under brand names are probably more concerned by this public perception. However, in this author's experience, almost all food plant managers try to be exemplary corporate citizens; Reducing waste load from a food plant can not only reduce company costs but, in plants discharging to municipalities, can also help reduce municipal costs. Reduced loads for municipalities should reduce municipal treatment costs, minimize need for expansion of treatment facilities, help to maximize treatment efficiency and allow new citizens and businesses into publicly owned treatment works (POTWs) with reductions in peak loading.

Second, food plants that minimize wastes often find they have ~~ increased plant efficiency. As wastes are eliminated, more product is packaged for sale for any given throughput.

52.10 Municipalities and Regulatory Agencies Need to Consider Ultimate Environmental and Health Objectives Considering the cost of pretreatment, which eventually is borne by the consumer, perhaps we need to ask if pretreatment requirements for food processors accomplish environmental goals in the most economical manner for society. The author believes that we must consider several vital factors when setting pretreatment requirements for food processors: First, we should consider whether we might accomplish environmental goals more economically if llpretreatmenttlwere defined as in the Nashville, Tennessee, ordinance to include process and management changes that reduce waste loads or alter the nature of the waste so as to make it more easily treated. Second, we should consider the concept expressed in EPA Construction Grants Guidance that I1Industrial use of municipal facilities should be encouraged when environmental and monetary costs would be minimized.I1 Third, we must consider human health and safety. Food plant biological pretreatment systems can be reservoirs of microbial pathogens that can and have contaminated food processing facilities. Some sites do not provide adequate room for a safe location. Fourth, we should consider the processor8s capability to dispose of pretreatment sludge and ask if it is reasonable to require pretreatment without an expressly stated municipal policy and procedure for sludge disposal. Fifth, we should consider the Pollution Prevention Pays concept and examine all possible management and process changes that could bring about a conservation-oriented operating environment before end-of-pipe treatment alternatives are utilized. Conclusion Process and management changes can be used to reduce the water use and waste load from food processing plants. Process waste load reductions are more economical than pretreatment processes. Pretreatment at food processing plants often costs more than POTW treatment, may present health and safety concerns with microbial pathogens and perhaps viruses, and generates sludge which is difficult and expensive to dispose of in an environmentally sound manner. Pretreatment of food plant wastewaters is necessary when fats may clog drains, when the food plant wastewater accounts for a large proportion of a POTW influent, and when special wastewaters (such

52.11 as caustic peeling waters) pose operational problems for a POTW. In most other cases, pretreatment may not be economically and environmentally sound, and in these cases municipal restrictions which dictate pretreatment should be re-examined. It is probable .-~ that smaller food plants should not venture into pretreatment without serious consideration of operational problems and sludge disposal. Larger food plants, in terms of water use and waste load, and those with wastewater parameters that can pose operational problems for a POTW must install pretreatment and direct their managment skills and resources toward meeting any restrictions necessary to protect the municipal POTW. We can expect more food plants to find pretreatment necessary in the future. Municipal officials and food processors need to communicate mutual concerns about pretreatment so that society receives maximum waste reduction with a minimum of resources. As studies in food plants have shown, frequently the least expensive and most effective way to pretreat wastes is to implement management and process changes that "prevent pollution" by reducing water use and waste generation.

52.12 EPA'S WASTE MINIMIZATION BENEFITS WWUAL Ron McHugh It is EPA's policy that minimization of tthazardousreleases'' i.e., pollution prevention through source reduction and recycling practices is preferable to controlling such releases after they are generated or produced. Further, EPA will aggressively implement waste minimization (WM) through source reduction as an integral part of its programs to protect all aspects of our nation's environment--air, water, land, and groundwater. EPA believes that while there are sufficient incentives for firms to prevent pollution, many times firms do not understand the economics of prevention activities. EPA has produced a manual to simultaneously achieve both increased environmental protection and reduced environmental compliance costs. The purpose of the Waste Minimization Benefits Manual is to promote a complete and objective analysis of the economic benefits of WM projects. Since the passage of the Hazardous and Solid Waste Amendments (HSWA) to RCRA in 1984, EPA has been developing a program to meet the statutory goal to reduce or eliminate the generation of hazardous waste as expeditiously as possible. EPA has met with corporate managers to discuss how the goals can be met without recourse to additional regulations. A major theme has been that waste minimization projects frequently do not get undertaken because the benefits of the project are poorly understood--particularly in terms of reduced environmental regulatory compliance and liability costs. Further, as many firms currently involved in Superfund cleanups can attest, the fact that a company followed all existing rules at the time a waste was generated does not guarantee that the firm will be free from future liabilities resulting from legal actions. EPA's Office of solid Waste and Office of Policy, Planning and Evaluation undertook the preparation of the manual so that plant managers can evaluate the Ittruettcost of current hazardous materials management against waste minimization alternatives, primarily source reduction and recycling. Until these true costs, often underestimated by managers by an order of magnitude, are correctly understood, more hazardous waste will be produced and managed than need be--thus imposing additional costs on the generator, the environment, and society as a whole. EPA believes the issue and this manual represent an extraordinary commonality of interests between economic self-interest and environmental protection. The manual is designed to be used in conjunction with either EPA's Waste Minimization Opportunity Assessment Manual or with an

' Environmental Protection Agency, 401 M St. SW, Room 3006 (PM- 223), Washington, DC 20460 (202) 382-2693

53.1 environmental assessment performed by an environmental or waste minimization (WM) auditing firm whose assessments would have detailed both current practice and a WM alternative.

The manual enables users to initially calculate the lltruell .~ cost of current waste management practices and then evaluate the financial payback of the WM alternative. A method for conducting a series of such calculations is presented and illustrated with an example to allow users to evaluate the benefits of the WM alternative relative to current practice. These benefits may occur in one of four categories or lltiers.llThe first tier demonstrated a protocol for calculating . the usual payback--e.g.! improvement in product yield from,WM projects. The second tier of benefits analysis involves estimating lleveryday,"but often unseen regulatory costs which can be legitimately avoided through source reduction, recycling or other means of WM. The third tier includes, in addition to the other benefits, avoided corrective action and legal costs for leaks or other releases from the facility. Finally, the fourth tier discussion suggests a way in which a decision on WM can incorporate such potential benefits as impact on sales of company goodwill, etc. These benefits are real, though hard to quantify. A real-world example showing how to use these four tiers and how to present the economic and financial parameters is also presented.

53.2 FEDERAL HAZARDOUS WASTE REDUCTION POLICY: DEBATE AND SUPPORT STALLED Joel S. Kirschhorn and Kirsten U. Oldenburgl

ABSTRACT

It is easy to miss the obstacles to waste reduction and, therefore, not understand why Federal policy is important and to overlook the negative consequences of relying on industry and the States to implement waste reduction. There is little public debate on Federal waste reduction policy. Industry fears burdensome regulation of waste reduction. Companies in the waste management and pollution control business fear a loss of markets. Environmental organizations worry about loss of support for established regulatory programs. The new interest in waste reduction may hide a serious national problem: nearly every part of American society is mentally locked into the established, institutionalized pollution control culture--or paradigm--whichdefines environmental protection in terms of what is done to wastes and pollutants once they are produced. As always, we need to learn from the past. The benefits of waste reduction were recognized in theory over ten years ago. But practice has not followed theory. Federal environmental policy has been part of the problem. And, even with new, strong Congressional interest in waste reduction, progress may be slow unless we understand why people and organizations cling to the old approach to protecting the environment.

INTRODUCTION

Reducing the generation of all environmental pollutants by changing industrial production processes, technologies, procedures, and materials is gaining popularity. But this new interest by industry and government in what is an old idea may not be as significant as it seems. A national, long term commitment to waste reduction, as a serious complement to traditional environmental protection, is not at hand. (Office of Technology Assessment, 1986) Companies and environmental groups are neither supporting nor opposing a Federal waste reduction initiative. They are either ignoring waste reduction or giving it a low priority relative to more established environmental issues. Waste reduction seems different than other areas of Federal involvement because its benefits appear so great and widespread. It seems as though it should happen by itself. It is easy to miss the obstacles to waste reduction and, therefore, not understand why Federal policy is important and to overlook the negative consequences of relying on industry and the States to implement waste reduction. The general public has hardly heard about waste reduction, partly because waste reduction as good news does not compete well with all the bad environmental news. From a historical perspective, we don’t seem to make the connection between successful experiences with energy conservation and preventive health care and environmental waste reduction. There is little public debate on Federal waste reduction policy. [This discussion is not meant to support any particular legislation or policy proposal.]

IOffice of Technology Assessment, United States Congress, Wash., DC 20510. The views expressed here are those of the authors and not necessarilty those of OTA.

54.1 Moreover, widespread frustration with the ineffectiveness and inefficiency of the current pollution control system--oftenseen in gridlock-- has not created a movement that puts waste reduction at the center of an integrative, parallel strategy attractive to government, business, and environmentalists. Why not? After a hard analytical look at the facts, government agencies and public interest groups agree that a major national shift away from traditional regulated end-of-pipepollution control to voluntary pollution prevention is ~ technically and economically feasible, but has not yet occurred. Extensive data from industrial examples make the case that true waste reduction, as a preventive tactic, provides the most certain environmental protection is profitzble to industry. Pollutants not produced cannot harm human health and the environment. Waste reduction can cut industry's escalating waste management, pollution control, regulatory compliance, and liability costs. And it can do so with small investments that yield returns within weeks or months, rarely more than a year or two. If we accept these findings, then we must understand why industry and public interest groups don't support government help to industry--help designed to reap the benefits of waste reduction for the public. Some feel that a Federal effort is unnecessary because industry and individual States are doing enough. There are more and more publications and conferences about waste reduction, and some States have passed laws and set up programs to help industry reduce waste. But these efforts are very small compared to established environmental programs, are often focused on minimizing land disposal rather than on true waste reduction, and frequently direct their efforts to small waste generators who account for a tiny fraction of the nation's environmental waste generation. We believe that the private sector does not support a Federal waste reduction progran because they are worried about possible secondary impacts.

Industry fears burdensome regulation of waste reduction. Companies in the ~ waste management and pollution control business fear a loss of markets. Environmental organizations worry about loss of support for established regulatory programs. These fears, if not confronted, will handicap the public debate and impede development of Federal waste reduction policy.

THE REAL PROBLEM

The new interest in waste reduction may hide a serious national problem: nearly every part of American society is mentally locked into the established, institutionalized pollution control culture--or paradigm--which defines environmental protection in terms of what is done to wastes and pollutants once they are produced. Many people don't realize that pollution control often transfers pollution from one regulated environmental medium to another, and sometimes to a less or non regulated medium. And pollution control is based on the concept of safe or allowable levels of pollution which, because they are so difficult to set, means that many hazardous substances are left unregulated, while debate continues for years. Pollution control also pits economic and health benefits against one another. Stepping briskly from belief to political action seems impeded by diffuse, cautious support for waste reduction, not explicit objection to it. ~- A number of waste reduction bills have been introduced in Congress to greatly expand the Federal waste reduction effort at the Environmental Protection Agency, to provide a consistent national framework including how to define and measure waste reduction, and to fund State programs. klile differing in a

54.2 number of details, none of these bills calls for traditional regulations to prescribe waste reduction actions for industry. Instead, these bills call for government to provide technical assistance to industry, of a kind already proven in several demonstration programs (e.g., Ventura Country, California and North Carolina). Although there are many dedicated people working to put waste reduction on the national agenda, there has been no significant public support of these bills by either industry or public interest groups. Lack of visible, organized support seems inconsistent with the generally accepted benefits of waste reduction. And, without support, Congressional debate or action on any waste reduction bill is unlikely. For example, six months after the first bills were introduced, no House or Senate committee of jurisdiction had yet held a hearing on waste reduction. EPA does not support the bills and in fact maintains they are unnecessary. Meanwhile, using the appropriations route, Congress has supported waste reduction by providing greatly increased funding for waste reduction in EPA's FY88 budget. Included are $4 million for grants to States and $0.5 million for expanded activities by EPA.

IMPLEMENTATION IS A PROBLEM

There is a voluminous literature that details the technical and economic feasibility, costs, and benefits of waste reduction. Thus, there is no need here to repeat yet again examples of successful waste reduction. There is only need to caution that just as zero risk and zero emissions make little sense, zero waste generation for all industry is also an abstraction that must yield to the'laws of physics and chemistry. But the waste reduction literature does make it clear that it is sometimes possible to totally eliminate a specific wastestream, even a very large one from a mature industrial process. Additionally, the level of yet unrealized waste reduction is large; the Office of Technology Assessment recently estimated that neither technology nor economics prevent industry from reducing its environmental wastes by up to 50 percent within the next few years. (Office of Technology Assessment, 1987) R&D efforts could, in time, lead to even larger reductions. The larger problem with implementing waste reduction in industry is that a host of non-technical factors limit its application. Therefore, it is common for people in industry to conclude that they have exhausted their waste reduction opportunities when, in fact, they have not. These non-technical factors include: competing production priorities, belief that legally required pollution control is good enough, lack of management support to allocate people's time and capital for waste reduction, lack of rewards for successful waste reduction, accounting systems which do not allocate total environmental costs to production profit centers, incomplete data on the exact sources and amounts of environmental wastes, and the difficulty of simultaneously spending resources on regulatory compliance and waste reduction. Another problem, particularly in the environmental and public interest community, is the difficulty in seeing waste reduction as a fundamentally different strategy to achieve commonly accepted environmental protection goals. The switch from pollution control to pollution prevention is a classic example of a paradigm change. A changeover to a new paradigm takes time, like the nucleation and growth of crystals forming from liquid. In the interim, most people fail to see the advantages of the new paradigm, and the old prevails. And so it is for waste reduction. Many people don't see waste reduction negatively, but they do see it as no better than pollution control.

54.3 In this regard, note that Congress has made the critical leap in thinking. The Hazardous and Solid Waste Amendments Act of 1984 says: "The Congress hereby declares it to be the national policy of the United States that, wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste nevertheless generated should be treated, stored, or diposed of so as to minimize the present and future threat to human health and the environment." While Congress has unambiguously stated the primacy of waste reduction, it has not applied the principle to all wastes and pollutants, because HSWA deals only with legally defined hazardous wastes, a subset of all environmental pollutants. [The law also included minor regulatory requirements. Companies must certify that they are pursuing "waste minimization," a term broadly interpreted by industry and EPA to include both waste reduction and waste recycling and treatment.] Many companies and some States have also adopted a hierarchy of waste management options with waste reduction at the top. To agree in principle with the primacy of waste reduction, however, is not the same as implementing it. For example, in 1976 EPA adopted the hierarchy, but until waste reduction was publicly resurrected this year, had devoted nearly no resources to its implementation.

ARE CURRENT EFFORTS ENOUGH BECAUSE WE HAVE TURNED THE CORNER?

The most obvious explanation for the lack of interest in establishing a major Federal waste reduction effort is the belief that, for the most part, industry has gotten the waste reduction message, taken its primacy seriously, understands its benefits, and made the necessary commitments to implement it over the long term. This hypothesis is not easy to prove in the affirmative or negative. Because we have a dominant end-of-pipepollution control system, we have very little systematic, reliable data on waste reduction. It is the authors' belief, based on monitoring of waste reduction data from industry and government and participation at waste reduction conferences nationwide, that all the talk about waste reduction is misleading. We don't think the nation has turned the corner on waste reduction implementation. Waste reduction has not yet taken hold as an environmental protection strategy. Very few companies provide detailed information on their waste reduction performance on a plant or company basis. They speak in generalities or give specific examples which tell very little about the company's total generation of waste relative to changes in its production output. Much of the available data is misleading. Improving industrial efficiency by cutting waste production is variously called waste reduction, source reduction, pollution prevention, or waste minimization. There are no standard definitions. Companies often claim waste reduction credit for activities such as incineration that follow generation of a waste, rather than only those that avoid waste creation, handling, movement, and management. Survey results and published papers show that probably 75 percent of companies use a definition of waste reduction or some other term which gives them credit for improved waste mangement and pollution control. Data from government sources suffer because wastes are differently accounted for by environmental media and because it is not possible to separate out effects on waste generation figures from other factors, such as changing regulatory definitions, plant closings, and varying levels of regulatory enforcement.

54.4 Finally, a public policy that ignores waste reduction may realize only short term benefits. Waste reduction proceeds in stages. Companies that successfully tackle the first, easy, and low cost waste reduction opportunities may then lose interest or commitment and not push their waste reduction to its limits. As industry's waste reduction paybacks decrease and projects become more complex and dependent on R&D, public policy will play a more critical role. Already, there are some companies that say they have done all the waste reduction they can. A few companies are providing good data that show that very large amounts of profitable waste reduction can be accomplished quickly. But these companies are the exception, not the rule; their successes don't mean that current public policy is sufficient, only that some companies have the resources to recognize and do what is in their self interest. 3M's Pollution Prevention Pays and Dow Chemical's Waste Reduction Always Pays are more than slogans; they are simple statements of economic fact. These companies and others overcame both internal obstacles to waste reduction and obstacles in the public sector. Not every company will be able to do so.

COMPETING INDUSTRIAL PRIORITIES

There are other, more plausible explanations for the lack of industrial support for a Federal waste reduction initiative. Ask two questions about a company: Does it have a successful waste reduction program? Is it in the waste management or pollution control business? The second question is more important than most people recognize. The steadily increasing national spending on the environment--now about $80 billion--helpscompanies understand the benefits of waste reduction. It is also a business opportunity for many of America's largest manufacturing companies. Waste management and pollution control is not a niche market. More and more companies have been entering this business, using the waste treatment expertise they have gained internally. This is particularly true since Congress mandated the shift away from land disposal of hazardous waste. When a company has a successful waste reduction program and is in the waste management business, there is no net advantage for it to foster a government program that would assist other companies to reduce their waste generation and, hence, shrink the waste management/pollution control market. Although some new business would be created for waste reduction consulting, there is little expensive hardware or engineering services to be sold. Waste reduction government intervention would create economic winners and losers. When the company has a successful waste reduction program but is not in the waste management/pollution control business, a government program could reduce its competitive advantage relative to firms without a successful waste reduction program. Moreover, the company that has done it on its ommay feel that it is unfair for the government to assist other companies with less initiative. And companies without successful waste reduction programs? If a company is in the waste management/pollution control business it wants to maintain the market. If not, it sees no benefit in changing the status quo if its own environmental costs are relatively low. And a company that hasn't recognized the economic benefits of waste reduction, will not see any purpose in a government waste reduction program. For all companies, and particularly for those without a successful waste reduction program and no waste management/pollution control business, there is the understandable fear that any Federal waste reduction initiative, even if

54.5 it is non-regulatory today, will lead to a traditional regulatory program tomorrow. Waste reduction, in other words, falls victim to industry's mistrust of any regulatory agency. [This is why some States have kept their waste reduction programs out of their environmental regulatory agencies.] Indeed, Congressional waste reduction action to date has been in the context of the Resource Conservation and Recovery Act regulatory program for hazardous waste. Few companies see a non-regulatory waste reduction program as making the regulatory programs easier to bear, or they give greater weight to their fears, as discussed above. Industry has three concerns about waste reduction regulation: --Requirements to cut waste generation might result in eliminating certain products and the waste reduction concept might be extended to unregulated wastes and to post-consumer wastes. The latter is particularly threatening because, from the industrial perspective, a company not itself generating a harmful waste or which is managing a waste in compliance with regulations could be forced to change or drop an established, profitable product because of waste created late in the product's lifecyle. --Acompany which voluntarily reduced its waste generation today-or yesterday-might tommorow be required to meet some arbitrary additional level of waste reduction at great cost and difficulty. [This concern explains why some major companies are not revealing past waste reduction accomplishments; they are "banking" them in case they are needed to satisfy future regulatory requirements.] --Some companies would like to keep the status quo because they have not suffered from pollution control regulations. Some large, low cost producers have increased profits because their price increases, unlike other, high cost producers in the same industry, have surpassed regulatory cost increases. Lastly, industry has recently been funding university work in risk assessment and supporting expanded government activities in this area. Risk assessment can assist the troubled regulatory system by better allocating resources for traditional pollution control technology. And while no industrial money has been committed to public waste reduction programs, some leading companies, including several very active in waste reduction, have recently established a new trade association: the Coalition For Responsible Waste Incineration.

ESTABLISHED PRIORITIES AND SKEPTICISM BY PUBLIC INTEREST GROUPS

People active in waste reduction during the past decade are perplexed that environmentalists and, even more so, environmental and public interest organizations have not made waste reduction a high priority. [A few grassroots, activist groups have, but they are not active at the Federal policy level.] The early writings of environmentalists, such as Rachael Carson, contain the prevention theme, such as banning the manufacture of certain hazardous materials. Early on, environmentalists accepted the pollution control strategy as expedient. Limiting, not eliminating, pollution was a practical first approach to solving the newly perceived and overwhelming problem. However, organized environmental interests and public policy have developed an attachment to the pollution control strategy. As Robert Reich has written, environmentalists like everyone else in the environmental regulatory arena have learned to play, maintain, and expand the game according to established rules. Indeed, many environmentalists move over to private industry or the government.

54.6 Expertise, priorities, and commitments are established. Partial wins seem preferable to gambling on a new strategy. Support of a Federal waste reduction initiative might detract from political interest in and, possibly, funding for existing regulatory programs. Waste reduction might even make the limits and faults of hard fought for regulations more visible. Moreover, there is a deep suspicion among environmentalists that a non-reeulatorv waste reduction program might give opportunities to industry to compromise regulatory programs without really eliminating pollution. Some environmentalists and people in government advocate the indirect approach of expanding the end-of-pipe regulatory program and improving its enforcement, thus increasing costs to industry, which will then turn to waste reduction to lower costs. But this strategy discounts industrial responses to rising regulatory costs other than waste reduction. These responses include plant relocation and closings, use of traditional pollution control technologies, litigation, lobbying to change laws and regulations, and, sometimes, even illegal waste disposal.

SHARED CONCERNS

There may be mutually reinforcing silence on Federal waste reduction policy. Simply put, private sector players (and even some regulatory bureaucrats) may have independently reached a similar conclusion: helping to create a Federal waste reduction program might crystallize the uncertain secondary impacts--outsidetheir control--that we have discussed here. Giving visible support to waste reduction legislation might lead to a snowball effect if others, particularly those who do not perceive negative consequences, join in. Silence seems safe, especially as long as concerned parties think that Congress will not pass waste reduction legislation. This is a rational strategy from their perspective, because waste reduction is environmental legislation and therefore must compete for Congressional attention with older, established environmental laws with active constituencies in government and the private sector. And the absence of good data can be used to defend the position that a Federal program is unnecessary or to delay action, for years, while information is obtained. But we see little chance of getting good data on true waste reduction for all of American industry for some years.

ADDRESSING CONCERNS ABOUT SECONDARY IMPACTS

Waste reduction supporters can adopt a strategy to broaden public support. First, three factors must be assumed: (1) the nation has not yet turned the corner on successful long term waste reduction and is not likely to under current public policy, (2) lack of private sector support results from perceived negative secondary impacts of a Federal program, and (3) overall, serious long term waste reduction is good for society as a whole. Waste reduction proponents could tackle the concerns described earlier head on. For example, they might convincingly argue that applying traditional regulatory measures is technically infeasible and administratively impractical, because of the enormous number and diversity of waste generating situations. Waste reduction supporters can be unequivocally positive that technical assistance can work and will be made to work. Industry’s concerns are valid because, in its report to Congress on the subject, EPA stated it is still studying the possibility of future regulation; nor can current waste reduction bills rule out future regulation.

54.7 Regarding waste reduction’s effect on the waste management/pollution control market, proponents of waste reduction can point to the large toxic waste site cleanup market and emphasize that we can never reach the zero waste level. Moreover, the bulk of the American industrial base could be convinced about the benefits they would receive from a major Federal waste reduction program. Concerns of environmental groups could be allayed through a commitment to maintaining the regulatory program which, indeed, is necessary but not sufficient for a successful waste reduction program. A case might be made to increase regulatory penalties and liabilities over time as industry becomes able to reduce its waste generation and exit in part from the regulatory system. More efforts to educate the general public about waste reduction and primacy over pollution control would also help environmental organizations to rethink their priorities. The public benefits of waste reduction likely offset its negative consequences and costs. For example, not assisting waste reduction could contribute to increased risks and costs associated with producing avoidable environmental wastes. If ten more cleanup sites are created a year because substantial feasible waste reduction is not done, then at a typical cleanup cost of $10 million a site another $100 million is added to the national cleanup bill, which OTA has estimated to be about $300 billion already. If industry cut 10 percent of its waste generation a year, now at over 500 million tons a year, then waste management costs of several hundred million dollars would be saved. In comparison, the costs of State and Federal technical assistance programs for waste reduction are not likely to exceed about $10 million to $20 million a year. Increased taxes on increased profits resulting from waste reduction savings could pay for such government activity.

CONCLUSION

As always, we need to learn from the past. The benefits of waste reduction were recognized in theory over ten years ago. But practice has not followed theory. Federal environmental policy has been part of the problem. And, even with new, strong Congressional interest in waste reduction, progress may be slow unless we understand why people and organizations cling to the old approach to protecting the environment.

REFERENCES

Office of Technology Assessment, 1986, Serious Reduction of Hazardous Waste, Wash., DC.

Office of Technology Assessment, 1987, From Pollution To Prevention, Wash., . DC .

54.8 WASTE REDUCTION POLLUTION PREVENTION INITIATIVES INDUSTRY'S NEED FOR POLLUTION PREVENTION Joseph E. Harwood On behalf of the Environmental Concerns Committee of the North Carolina Citizens for Business and Industry (NCCBI), we are pleased to participate in and be a sponsor of this Pollution Prevention Pays Conference. The NCCBI represents over fiefteen hundred industries across North Carolina. We have found that the terms "industrialist" and "environmentalist" are not mutually excl usi ve. Waste Management is a Genuine Concern of All Industries The desire to do the right thing is one common thread running through all industries. This desire plus the need for regulatory compliance provide every incentive to manage wastes properly. Industries are, however, faced with limited resources to address new problems immediately. All industries are focusing efforts on Pollution Prevention Pays, but in the meantime the regulatory compliance programs move on. Industries must continue to allocate resources to regulatory related activities such as inspections, report preparation, new compliance programs, and providing comments on new proposed state, federal , or 1 oca1 regul ati ons. Waste Reduction is a Change to Our Society's Cui ture From the early days of the industrial revolution resources have been focused on products, their quality and uniqueness. The first part of the twentieth century was spent refining those products which resulted in more convenience, longer life expectancy, and increased leisure time. The 1960-70's saw the birth of the environmental movement with emphasis on pollution control. The 1980's have seen great progress in cleaning up the environment. Implementa- tion of pollution control programs such as CWA, CAA, RCRA, TOSCA, FIFRA, and SARA are currently costing about $290 per person annually. Now is the time to look at production processes. Can they be fine tuned to minimize waste production? Are waste management practice costs approaching the value of the product being produced? Cultural changes are slow because they are also phi- 1 osophi cal changes. There is al so psycho1 ogi cal opposi ti on to change. Many like the old ways of doing things and there is often an attitude of "if it isn't broke, don't fix it." These attitudes and fear of new approaches must be overcome before effective waste reduction can be implemented.

1 Environmental Affairs Manager, Duke Power Company, P. 0. Box 33189, Charlotte, NC 28242.

55.1 There are Numerous Incentatives for Industry to Look at New Ways to Actually Reduce or Better Manage Waste High regulatory compliance costs under RCRA and other end-of-pipe programs are the prime incentive to pursue waste reduction. These costs are estimated at 80 billion dollars per year. Additionally, industries face liability for mis- management of wastes under RCRA and CERCLA. In contrast, industry recognizes the benefit of the limited regulatory approach to waste minimization. These factors result in tangible rewards for companies who do a good job with waste reduction and management. There is a New Environmental Cultural Change Underway in Industry The change in environmental culture within North Carolina and around the country revolves around waste reduction. Just two weeks ago Governor Martin presented the 1987 Waste Management Awards to Newton Industries Company of Butner and Rexham Corporation of Matthews. Governor Martin cited these two company's "ongoing environment commitment to environmental protection beyond what is required by state and federal regulations." His comments highlight the cultural change from regulatory compliance to waste reduction. A total of thirteen companies submitted applications for the 1987 awards. The NCCBI Supports Pollution Prevention Pays and Safe Waste Disposal Facilities in North Carolina Even with successful waste reduction efforts, there will always be some waste. This is true of any process, including biological processes. There is a defi- nite need for safely designed, built, and operated waste disposal facilities in North Carolina. Industry thinks this can and should occur. The risks to human health and environment of not having such a facility surely out weight the risks of having a safe facility. But only through cooperation and coordination of all of North Carolina's citizens, corporate and private, are we going to achieve the goal of a safe facility. A step in the right direction is a recently proposed position by the Corporate Conservation Council of the National Wild1 ife Federation on waste management. The position encourages waste reduction and treatment but recognizes that there will always be a need for a place for disposal. We encourage all special interest groups to consider joining with industry groups in supporting the need for safely designed, built, and operated facilities in North Carolina. Industry supports the concept of Pollution Prevention Pays and also encourages the siting of a safe hazardous waste disposal faci 1 i ty in North Carol i na. North Carol ina has always been a leader in the environmental area. Here is another opportunity for leadership, this time in waste management.

55.2 RETHINKING WASTE MANAGEMENT: FROM "HOLE IN THE GJXOUND" TO HOLISTIC

Linda W. Little*

For centuries waste management consisted simply of dumping wastes outside of the doors of homes and businesses. Jonathan Swift's "A Description of a City Shower,'' published in 1710, paints a vivid picture of the results:

Now from all parts the swelling kennels flow, And bear their trophies with them as they go: Filths of all hues and odours, seem to tell What streets they sail'd from, by the sight and smell,

...... a. Sweepings from butchers stalls, dung, guts, and blood, Drown'd puppies, stinking sprats, all drench'd in mud, Dead cats, and turnip tops come tumbling down the flood.

As the concept of "an eye for an eye and a tooth for a tooth" was a major advance over the practice of massacring a tribe over a mere insult, so was the landfill or "hole in the ground" approach a major advance over tossing trash in the streets or dumping it into open piles frequented by rats, flies, and mosquitos.

In the mid-1970's it became apparent that landfills, while an improvement over earlier disposal practices, were not the final solution to waste management needs. Many landfills leaked, posing actual or potential threats to groundwater. Some things, like tires, would not stay buried. And as waste generation of households grew to nearly 4 pounds per person per day, an alarmtng amount of space was being required for disposal.

The Resource Conservation and Recovery Act of 1976 made it plain that land disposal by itself was not the answer to waste management, and the Hazardous and Solid Waste Amendments Act of 1984 went further to state:

The Congress hereby declares it to be the national policy of the United States that, wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment.

While this policy in itself is generally applicable, to date implementation has consisted of categorization of wastes according to source followed by regulation of only some sources. This approach, while probably the most feasible approach from the standpoint of priorities, has unfortunately resulted in an overly narrow regulatory system and a polarization of industry and the public as to responsibility for waste management.

*Executive Director, Governor's Waste Nanagement Board, 325 N. Salisbury Street, Raleigh, N.C. 27612

56.1 Hirshhorn and Oldenburg [Office of Technology Assessment, undated] comment, "While Congress has unanimously stated the primacy of waste reduction, it has not applied the principle to all wastes and pollutants, because HSWA deals only with legally defined hazardous wastes, a subset of all environmental pollutants." [Emphasis supplied.] The Government Affairs Committee of the Water Pollution Control Federation has also recognized this problem:

Although much attention has been focused on contamination from abandoned hazardous waste disposal sites, there are many other threats to groundwater supplies, including landfills, septic systems, underground storage tanks, pesticides, brine disposal, abandoned mines, agricultural run-off, road salt, and salt water intrusion. Current federal clean-up and prevention efforts are narrow in scope, addressing specific causes and not the problem as a whole. [Journal of the Water Pollution Control Federation 60:305 (1988)1

Hirshhorn and Oldenburg refer to "a serious national problem: nearly every part of American society is mentally locked into the established, institutional pollution control culture -- or paradigm -- which defines environmental protection in terms of what is done to wastes and pollutants once they are produced." One must then ask the questions, "At what point does something become a waste or pollutant?" and "Who is responsible and at what point in the process?" As is shown in the examples in Figures 1 and 2, there are many points at which hazardous materials may enter the environment but the focus of regulation, promotion of waste reduction, and development of infrastructure for collection and management have been focused almost entirely on a few producers of point sources. Furthermore, the resources of both federal and state government have been concentrated on these producers and the burden of dealing with wastes not regulated as hazardous has fallen almost entirely on local governments.

Because of the regulatory pressure on industry, the "hole in the ground" approach is now shifting to the prevention and reduction approach. There are direct incentives and disincentives to encourage pollution prevention at the source. Since industries pay for waste disposal on a per unit disposed basis, that is, so much per pound or per cubic foot, there is a strong incentive to reduce waste generation. At both the federal and state level there are massive efforts underway to site waste treatment facilities capable of reducing the volume and toxicity of hazardous waste. Industries must certify that they have made an effort to minimize waste generation. There are fines and other disincentives for improper waste disposal.

On the other hand, for the general public about the only incentive is that I1virtue is its own reward." As a rule, the cost to the homeowner of garbage pickup is unrelated to the amount produced. There are no regulations requiring waste minimization. As for disincentives, it is usually attractive to buy products in the giant economy size, and fancy and excessive packaging is used to lure customers. Probably the biggest disincentive to proper management is the lack of an infrastructure to facilitate recycling, reuse, or even safe disposal -- just try to get rid of a few quarts of used oil or leftover paint or old tires.

56.2 Local governments still rely on the "hole in the ground" approach €or waste management and there is considerable hue and cry that in North Carolina the requirements for landfills are overly stringent and are interfering with efforts to build or expand landfills. There seems to be little or no acceptance of the fact that municipal landfills have the potential to adversely impact public health and the environment.

In a single day, I had the opportunity to read two letters from the same county manager, one blasting the state for not regulating commercial hazardous waste treatment facilities more stringently, the other blasting the state for burdening counties with overly strict landfill requirements! Clearly, there is a schizophrenic, rather than a holistic, view of waste management.

So much stress has been put on hazardous industrial waste that many people feel that the whole answer to waste management is to put further restrictions on industry. There is not a clear understanding that if -all industrial hazardous wastes were minimized to the maximum there would still be environmental problems due to the sheer volume of household wastes generated, some of which are hazardous even if not regulated as such.

There is also among the public a poor understanding of cause and effect, that is, the relationship between the production of goods and services and the production of wastes. A passage in a recent novel is apropo: "They want it all: Sex without babies, ... art without effort ... Dinner, in other words, and no washing up." [Fay Weldon, The Hearts and Lives of Men, Viking Press, 19881

Finally, as Hirshhorn and Oldenburg state, "The general public has hardly heard about waste reduction, partly because waste reduction as good news does not compete with all the bad environmental news."

Small wonder, then, that in the public's view waste management has become public against industry, us against them, victim against victimizer. When such polarization develops, it is difficult to work together for the common good and it is easy to point the finger elsewhere for the solution. As Hirshhorn and Oldenburg state, ... it is easy to overlook the negative consequences of relying on industry and the states to implement waste red uc tion . TJe may be at a crucial turning point now -- the Board's office is getting many calls from individuals and communities who want assistance so that they can manage their waste safely. Unfortunately, in many iastances there is little advice to of fer.

What can be done, here and today, with used oil, used tires, leftover paints, spent batteries, or leftover or contaminated cleaning solvents? Who is going to scold, much less penalize, a person who simply throws them out back somewhere? In contrast with industrial hazardous waste, for household wastes (1) there are no direct monetary incentives to prevent, recycle, or reuse wastes, (2) there are few or no regulatory incentives to reduce waste or to handle it properly, (3) there is no infrastructure (funds, personnel, facilities) to facilitate waste reduction and proper waste management.

56.3 My father maintains that when a child wants to learn something, that is the time to teach him -- if he is old enough to ask the question, he is old enough to get the answer. A significant portion of the public wants to learn how to properly manage household wastes, and it is high time we had some answers. We should capitalize OA that interest by demonstrating that the homeowner's problems in dealing with household hazardous waste are not unlike the problems faced by the industrial generator -- he may be able to substitute a non- hazardous for a hazardous material, but it might not perform quite as well; he may be able to treat wastes on-site, but it may take special and expensive equipment; he might be able to recover and reuse some of the materials, but they may not be as satisfactory as new materials; he may be able to ship waste off-site, but first he has to locate someone who will take it and he will have to be prepared to pay for the service.

When the public becomes personally involved in pollution prevention and waste reduction, when the public understands where wastes come from, and when the public understands the need for waste management facilities, I believe that the whole waste management program in this country will benefit. The fish in a river cannot distinguish between a regulated hazardous waste and a non- regulated waste, between the lead in an industrial effluent and that in a gasoline spill, between the pesticide in a pesticide manufacturer's wastes and that running off a cornfield, so we might as well move beyond this artificial and simplistic categorization wherein we scare the wits out of people in regard to one source and for all practical purposes ignore other sources.

When we move beyond a fragmented and polarized approach to waste management and we each realize we are all part of the problem, then maybe we will be able to join together to prevent or minimize the impact of waste on the environment that we all share.

We have rethought the "hole in the ground" approach and found it sadly inadequate. Now we must rethink the approach that relies on industry and the states to solve all waste management problems. Only when we move to the level of individuals and local government will we really develop a holistic and effective approach to waste management. The holistic approach will not happen by itself, regardless of its merits. It will take time, money, education, encouragement, perseverance, and patience. The general public is sending signals of readiness to learn and participate in waste reduction and now is the time to capitalize on that readiness.

56.4 INVENTION --) PRODUCTION -) AUTOMOBILE OF AUTOMOBILE OF AUTOMOBILE SALES

vI * AUTOMOBILE MANUFACTURING BY -PRODUCTS

I I r I J/ SPILLS & LEAKS FROM PETROLEUM TRANSPORT & STORAGE

USED TIRES,

SPENT BATTERIES

AUTOMOBILE CARCASS

* PRIMARY REGULATORY FOCUS

FIGURE 1 AUTOMOBILE PRODUCTION AND USE

56.5 DISCOVERY OF -) MUFACTURE OF ,-) FORMULATION OF -) XARKETER OF PESTICIDE PESTICIDE PESTICIDE PESTICIDE I I I I vI vI * PESTICIDE * PESTICIDE MANUFACTURING FORMULATION BY-PRODUCTS BY -PRODUCTS

USER OF PESTICIDE

PESTICIDE, PESTICIDE CONTAINERS

/ 3 UNINTENDED TARGETS

* PRINARY REGULATORY FOCUS

I RUN-OFF \’ c <- - - - - PESTICIDE TARGET / GROUNDWATER/./

FIGURE 2 PESTICIDE PRODUCTION AND USE

56.6 David Hawells

tlpOllution Prevention Rysft is a fetching new title for an idea that has been around for myyears. mt, changing cin=umstanceS and new leadership ncw make the idea far more attractive than before. It is truly an idea whose time has came... if we can adjust our approach to water pollution problem to give waste reduction its proper qhasis in the hierarch of alternatives. %t will take education at all levels of professional practice. Let's step back a little and re-examine the concept of mste prevention in the historical context in which it developed. Concern over water pollution fhst arose mer the treatment of human wastes so as to control water-borne disease. ?hat required disinfection. me unsightliness of raw sewage and its effects bruught primary treatment to remove the settleable and float- solids. The next step in waste treabent arose from the concern expressed by fish and wildlife groups over fish kills and general debility of aquatic life Coming frm depressed dissolved oxygen levels. That brought secondary treatment to reduce the oxygen-demndiq cdnponents of municipal and inctustsial wastewaters. There was a great deal of debate between the proponents and oppnents of adjusting public policy to require secondary rather than prhxy treatment to protect surface waters for "fishing and s&"'as eventually imposed by the 1972 Clean Water Act. It's important to remember that con= mer the so-called !Inon- conventionaltt pollutants and water quality parameters which took us beyond such measures as bacterial density, dissolved oxygen, and the like is of fairly recent origin. In a number of respects, we are still precccupied with the earlier concerns which viewed waste treamt as the principal approach to water quality management. Dilution became an important consideration where major reservoirs were constructed. But the mphasis by and larye remained on waste treahnent.

!Che.re are a number of examples of waste reduction in earlier eras where waste treatment costs could be reduce3 or avoided to one degree or another. Quite urdersbr&bly, they focused on reduction of oxygen demand to be satisfied through waste treatment. Ekamples include recovery and reuse of whey produced in the manufacture of cheese and the manufacture of vanillin and yeast frm pulp mill wastes. Whey recovery and reuse proved economical, but utilization of pulp wastes did not prove so because of lack of sufficient mrket for the by-prcducts. A major reason that waste recovery and reuse did not progress further than it did was that the Costs of secondary treatment-- particularly with the large federal subsidies-were socially acceptable, and there was insufficient incentive to pursue other alternatives to meet water quality goals. The federal subsidies will soon cume to an end adding further to the importance of reducing local waste treatment costs.

Professor Emeritus, North QrolhState University, Box 7912, NCSU, Raleigh, NC 27695-1912

57.1 In recent years, population growth and econdc development have impoSea ever mre demands on surface waters as receptacles for wastewater effluents. Secondary treabnmt is im=reasingly not encuqh, and the incremesltal costs of tertiary and altvanced wastewater treatment are often unacceptably high. Thus, we find ourselves facing the need to deadditional alternatives even to cape with conventional pollutants. While the production of synthetic organic chemicals has been accelerating since World War 11, we did not attenpt to cope with these in any systematic way until potential bioaccumulation in fish and presence in drhkhg water raised a whole new set of wncems over water quality and its effects on human health. Until quite recently, regulatory permits for the discharye of wastewaters dealt only with conventional parameters and a few toxic chemicals, largely metals and pesticides. Indeed, the composition of ccnr~plexindustrial wastewater streams was more oftm than not undefined beyond what could be qressed in terms of solids or oxygen demand. Nm, the rules are charging rapidly, and we are being faced with the need to identify wastewater c6(Iponents and to selectively remove them through the least costly means available+& is often waste recovery and reuse. Yet, the attitudes of regulatory agencies, consulting engineers, sialtechnologists, and acaddcians are, to a considerable extent, still attuned to waste treatment. This attitude has been heavily reinforced by federal and state grants for the construction of wastewater treatment plants in the absence of a parallel emphasis on pollution prevention as a first step. It has been firmly implanted institutionally as well as individually in the minds of the principals involved... Additional educational efforts at all levels of professional and ad" tive practice will be required to turn this around. M"tors must be sufficiently inform3 as to the potential for pollution prevention so as to assure that budgetary and legislative proposals include prevention as a key element.. of water quality managanent propms. This means corporate manag-t and a&" tors at the local level as well as state and federal regulatory agencies. consulting engineers must be capable of examining complex systems in light of waste characterization and prevention at point of origin rather than point of treamt. Pre-treamt programs should be expected to consider waste prevention on a source-specific basis to the extent needed to assure that this alternative is being optirrally utilized. This my well mean a greater effort to educate local government and industr ial officials than heretofore. Regulatory personnel must routinely expect permitees to thoroughly hvestigate and report on pollution prevention alternatives before considerhg wastewater treatment. This approach must have real substance, became a way of thinking, and tsanscend the mindset institutionalized by more than half a ~ century's preoccupation with end-of-pipe wastewater treatment. Last, but not least, the universities and technical &wls must rea" their errvironmental engineering programs at the undergraduate, graduate, and continuing education levels to assure that they, too, have mved f-y into the present era wherein the demands placed upon the limited water resources and water quality management costs are such that we can no longer afford to give little mre than lip service to pollution prevention.

57.2 Part of the problem in academia arises fram specialization. The environmental engineer may lack expertise in specific industrial processes, and the industr ial technologist may lack wise in water quality managanent. Tkis may arise from corporate secrecy which can effectively block dcation. But, it is hard to believe that consultative rdationships cannot this problem. Linkages between industr ial technology and envir0mtal prograrrrs in Universities could also be developed further than they have ken. Obviously, short cou~sesthrough university continuing amtion program will continue to have an important place in the education scheme. Let's nmember that deeply held attitudes cemented into place by decades of experience and practice are not easily changed. The effort to institutionalize pollution prevention as a key element in the matrix of alternative means for addressing water pollution nust reach all levels of government, corporations, consulting firms, and academia if it is to be successfully implementea. It must becc-sme a way of tt-rinking and addressing water quality problems. It must en- the first set of questions asked, the first alternatives considered, and our retmspective review of hm we address these problems.

57.3

Michael Alexander Margaret J. Babb AWT, m. Haz. Waste Branch Po Box 36008 Bath Bldg. Raleigh, NC 27606 Raleigh, NC Inter-Off. 919: 851-4761 919: 722-2178 Carolyn Allen Brian metz NC League Wamen.VoterS Duke University 215 N Dawson St Civil Engr., Ixlke U. Raleigh, NC 27603 Durham, NC 27706 919:839-5532 919: 684-2434 Marty Allen William -lowe Wake Co. Health Dept NFCD-DEN FOB 949 Archdale Bldg. Raleigh, NC 27602 Raleigh, NC Inter-Office 755-07 61x27 1 Rc5anne BaroM Charlene P. Alston NRCD-DEM Southeast Waste Exchange 512 Salisbury St. ~C-charlotte Raleigh, NC Charlotte, NC 28223 704: 547-2307 Bill Barriger Alewnderco. mix. Hlth. Dept. RiM(Pete) Andrews 255 Liledoun Rd., Box 3 UNC Inst. for Rw. Studies Taylorsville, NC 28681 (33 7410, 311 Pitrsboro St. 704: 632-4166 chapel Hill, NC 27599 966-2359 John Beale HickoryMt. Farms William M. Archer POB 455 sand02 chemicals corp. Siler City, NC 27344 Po Box 669246, Hwy. 27 W 919 :742-2144 Charlotte, NC 28266 Bruce BeiM Jon Arnold southchem, Inc. Civil Engr. Dept. POB 1491 CB 7908, NCSU Ixlrham, NC 27702 Raleigh, NC 27695-7908 919 :596-0681 919: 737-2331 B. F. Bentley Kenneth B. Amold General Electric Company Facet Ehterprises, Inc. Po Box 780 Po Box 1637 Wilmhgton, NC 28402 Henderson, NC 27536 919: 343-5386 919: 492-1141 Walter Bentley Marshall Ashcraft GTE south City of Raleigh 4020 Roxboro Rd. Po BOX 590 1xlrham, NC 27704 Raleigh, NC 27602 919: 471-7877 919: 890-3070

58. I Mary Birch IeeBrawn Ixlkepclwer(2mpany mgeDisposal Sew. Inc. POB 33189 FOB 2943 QlarlOtte, NC 28242 Hickory, NC 28603 704:373-4504 704:256-2158

John Bittle, Jr. Charlie Bryant armberland Co. Solid Waste Mgt. Sanford 1m 698 Ann St. FOB 338 Fayetteville, NC 28301 Sanford, NC 27330 919:483-4897 77 6-97 14

Jean H. Blalock (Mr.) I@n Bryant Ball-Incon Glass Packaging Corp. Burlington Industries POB 887 Box 691 Annex Henderson, NC 27536 Wlrlington, NC 27215 919:492-1131 919~228-2811

Robert Bonne William wlchanan Tcrwn of cary SSuareD POB 1147 Hwy 64 East Gary, NC 27513 Knightdale, NC 27545 919 :469-4024 919:266-3671

-Bayd R.A. (Bo) wlllard, V-Pres. B&L, Harris Energy center Maola Milk & ~ce~3ream co. Rt.1, Box 327 Po Drawer s New Kill, NC 27562 New Bern, NC 28560 362-3239 919:638-1131

Johnnie Braxton Robert E. Wurage Tire Recovery Inc. Qbarrus creamery co., Inc. Po Box 516 PO Box 188 Deep Run, NC 28525 CQnCOrd, NC 28206 919:568-3124 704:782-3131

Paul Brittain Frank Butler Burke Mills, Inc. B & W Metal Fabricators POB 190 FOB 729 Valdese, NC 28690 Welccm~,NC 27374 704 :874-2261 704 :731-8417 Joe Brooks Ken Cable Jefferies Southem Q12m Hill PO Box 430 229 Peachtree St.,NC,Ste300 Albemarle, NC 28001 Atlanta, GA 30303 704:982-8101 404:523-0300

Michael G. BKxJman Janeth A. Gmpbell m FL w.Env. Regulations 270 Haney Bldg. 2600 Blair Stone Rd. Chattanocqa, 37401 Tallahassee, FL 32399 615:751-7341 904:488-0300

58.2 Roy Carawan Jesse Collum NCSU Food Science Wpt. schrader Bellows CB 7624 US#1 North Raleigh, NC 27695-7624 Wake Forest, NC 27587 919:737-2956 919: 556-4031

James A. Grter Maryw. clnwr NC Hazardaus Waste Mgt. J3r. mer campany 306~.wilmington St, p0~2091 Po- Box 223 Raleigh, NC 27602-2091 Clover, SC 29710 919:733-2178 803: 831-3500 Liz cave James canner Wake Ccnmn. Recycling & Sierra Club Alamance co Hlth Wpt 407 Columbia Dr. 209 N Graham, Hopedale Rd Raleigh, NC 27604 Wurlington, NC 27215 919:834-7719 919:227-0101 Tory champlin Ivan cooper ESE HMIEngineering UNC-CH 6400 Fairview Rd. Chapel Hill, NC #312 charlotte, NC 28210 704:364-1800 Claude church United Metal Finishing Cqstal mch 133 Blue Bell Rd City of Winston-Salem Greensboro, NC 27406 IWC 2799 Griffith Rd 919:272-8107 Wir" Salem, NC 27103 919: 765-0134 Edith Clark WanSonaMfg. mrp. oscarv. coulter 1 Wansona Place of Spruce Pine Waded", NC 28170 Rt#l, Box 28 704~694-4146 Spruce Pine, NC 28277 704:765-6029 Sally Clotfelter Greensboro New & Record Brad S. Crawford Greensboro Carolina power & Light Co. North Carolina 7B3 OW, FOB 1551 Raleigh, NC 27602 Newton Cohen 919 :836-7085 Co. commissioner 202 N. Main St. Richard D. Crime11 Salisbury, NC 28144 Civ. per. Wt. PSC-4098 704:636-0361 CPT-Stop 7 MCAS cherry Point, NC 28533-4098 myCollins 919: 466-3992 News & Observer Pub. Co. 215 Scuth "well St. RichardD. Crocrm Raleigh, NC 27602 Asheville-w"be Tech. co". Col . 919:829-4782 340 Victoria Rd. Asheville, NC 28801 704:254-1921

58.3 Steve Croslin Jim Dhon Carolina mer & Light co. Sci. Teacher, Garinger High FOB 327 1100 Eastway Dr. New fill, NC 27562 Charlotte, NC 28205 919:362-3478 704 ~537-8261

Danrry- Grady Dabson F&xham cow. NRCD €OB 5466 Suite 714 Wachovia Bldg. Greensboro, NC 27435 Fayetteville, NC 28301 919:292-9911 919 :486-1591 Timothy L. Curtin Mark mrfman Civ. Fers. Dept. FSC-4098 InfOI-iIl cpp-stop 7 Mas 381 Park Ave., S. Cherry Point, NC 28533-4098 New York, NY 10016 919:466-3992 212: 689-4040

~arrymil Betsy Dom mcipal wineeriq Sem Mecklenbq Co. Etqr. Wpt. FOB 97 700 N. Tryon St. Garner, NC 27529 Charlotte, NC 28203 919 :772-5393 704:336-3873 Dennis Danner Wm W (Bill) Daw AeroquiP carp. Gav’s waste Mpt. Bd. Rt 2, Box 96 Rt. 3, Box 333 Forest City, NC 28043 Pittsboro, NC 27312 704 :286-4157 919:542-5528 -1 -1 Davis Wayne Thamann EaDept. of Manufacturing Duke University Medical Ctr. East Carolina univ. aJMC 3914 Greenvale, NC #142 IUrhxn, NC 27710 919:757-6705 919: 684-6320

Michele Daws DonP. Duncan City of Asheboro City of Ubamrle FOB 1106 FOB 190 Ashebor~,NC 27204-1106 AUwnarle, NC 28002-0190 919:626-1245 704:982-0131x250

Ryan Delcambre Bob map Dcrw Chemical USA western Carolina univ. 2030 Willard H. D3w Ctr. FOB 312 Midland, MI 48674 Whittier, NC 28789 517:636-2953 704:497-7298

F. A. DiGiano Dana Wury, Sr.ERA Ept. ESE Ctr. for m.Mgt., Tufts Univ. UNC-CH 474 Boston Ave Chapel Hill, NC #312 Medford, MA 02155 617:381-3486

58.4 Nathan Eagle David Ellis unitex memical corp. IIXX) unican corp. POB 16344 400 Jeffries Rd. Greensboro, NC 27406 Rocky Mount, NC 27801 919~446-3321 John Eason NAPCO, Inc. Bob Ellman FOB 26, Plymouth Ind. Park Equip. Associates Terryville, (2 06786 920 BlahkLll =,Suite 104 203 :589-7800 Charlotte, NC 28217 704: 522-0170 William F. Eberle NYSDEC Rich Elm 50 Wolf Rd. Equipnent kssociates Albany, NY 12233 920 BlaMll Rd., Suite 104 518:457-7267 Charlotte, NC 28217 704:522-0170 Maq Beth "an UNC Env. Res. Project Steve Erikson 311 Pittsboro St., CB 7400 Burke county UNC-CH, chapel Hill, NC #3l2 FOB 219 919: 966-3332 Morganton, NC 28655 704~433-4000 Gmer EdwanI, P1. Engr Consolidated Diesel (Env. Res.) Samuel w. Erwin ' Box 670, Mail code 81-20 Western Piectmont C. of ~av. Whitakers, NC 27891 317 1st Ave., NW 919 :437-9373 Hickory, NC 28601 704 :322-9191 Gary L. lBvards Civ. Pers. Ept. PSC-4098 Bruce midge CPT-Stop 7 MCAS NC House of Representatives Chw Poht, NC 28533-4098 115 Ann St. 919~466-3992 Beaufort, NC 28516 919:346-1273 R. J. Edtwards, I11 Haz. WaSteMgt. Branch Kenneth J. Fanfoni. POB 2091, Bath Bldg. Public Works ca". Raleigh, NC 27602 Po Dr. 1089, 508 Ferson St. 919: 733-2178 Fayetteville, NC 28302 483-1401x338 JosephB. Elkins Civ. Pers. Ept. PSC-4098 Carol W. Fann CPT Stop 7, MCAS City of Clinton ChqPoint, NC 28533-4098 FOB 199 919:466-3992 Clinton, NC 28328 592-1961x252 Yancey C. Elliott, Jr. Runnyn-de Mills, Inc. Rosanne Feild, Safety Ofr. Po Box 1239 Beckton Dickinson Tarboro, NC 27886 21 Davis Dr. 919: 823-2141 RI", NC 27709 919:549-8641

58.5 Kevin FenterS Keith Clark MacfieldTexturhg, Inc. Univdwoods, Inc. FOB 1437 2600 Grassland Dr. Reidsville, NC 27323 Blue Grass Ind. Pk. 919:342-3361 bukville, KY 40229 502 :491-1461 CWFinan City of Reeky Mount Kaulerine Nler FO Box 1180 MCNC Rocky Mount, NC 27804 3021 Cormallis Rd. 919:977-2689 KI'P, NC 27709

H. Flocd, Jr. Schwitzer Ray FOB 15075 City of concord Asheville, NC 28813 161 Breezy Lane 704 :684-4000 concord, NC 28025 704:788-4164 Jack Floyd NRCD-DEM Th Furr FOB 27687 City of concord Raleigh,NC 27611 161 Breezy Lane 919:733-5083 Comrd, NC 28025 704:788-4164 William D. Forbes caldwell cacrnty Wendy FOB 2200 city of- High point LSIO~,NC 28645 POB 230 704:758-8451 High Point, NC 27261 919:887-2511 Michael Fox City of Camver Furman Gaddy FOB 549 ww Treatment Conaver, NC 28613 Box 553 919:465-2279 Wadesboro, NC 28170 704~694-5293 Frank mzier City of Henderson JohnW. Gardner . .. FO Box 1434 Royal cake CQ., Inc. Henderson, NC 27536 Drawer AB, Salem Station 919:492-6111 Whton-Salem, NC 27108 919:785-8700 Joseph M. Freemen Naval Aviation De@ Mike Garlick NCAS Burlington Industries Cherry Point, NC 28533 FOB 788 919:466-7604 Clarksville, VA 23927 Kathy French Leon Gatewocd NCSU-IES ww TrEatmerlt CB 7902 Box 553 Raleigh, NC 27695-7902 Wadesboro, NC 28170 919:737-2356 704~694-5293

58.6 RonaldK. Gaynor -Y us Ecology GlenddLe- Hodeq Co. 1600 Dave, St.,Ste 408 FOB 686 NewpoA Beach, CA 92660 Siler City, NC 27344 714 :955-1201 919~663-2200

Th Green Meg -n Alamance Co Hlth Dept Radian mrp., progress ctr. 209 N Graham-Hopedale Rd FOB 13000, 3200 E. CH Rd/Nelson Hwy wlrlington, NC 27215 KIF, NC 27709 919:227-0101 919:541-9100 Wilbur K Greer Richard J. Haryitt Quantum, Emery Div. Writ FOB 628 FOB 800 Mauldin, SC 29662 Kinston, NC 28501 803:967-5153 919: 522-6725

Harry Gregori HaroldHarmon, Gen. kmn. vi4 Dept of waste Mgt. southern F2ls"g svstems 101 N. 14th St. FOB 1360, 1211 Barkley Rd Richmond, VA 23219 Statesvfile, NC 28677 804:225-2497 704:873-7211

Martie G"e StephenR. Haqer City of GEen&" GATech. Res. Inst. Drawer w-2 GrRI-EI-ISD-ETB Greensboro, NC 27408 Atlanta, GA 30332 919:375-4116 404:894-8058

Karin Gschwandtner Cathy Harris pacific Environmental Services VA Dept. of waste Mgt. 1905 Chapel Hill Rd. 101 N. 14th St. Ixlrfiam, NC 27707 fichmond, VA 23219 919~493-3536 804:225-2497

David E. Gurley, Jr. Joe Harwood Glenoit Mills, Inc. EC ca".,NC Citizens for Bus.&Ind. FOB 1157 Dike Fuwer Co., FOB 33189 Tarboro, NC 27886 Charlotte, NC 28242 823-2124-76 704:373-8494

John E. Ham, Plant Erqr Susan Healy Rego company NC Assoc Co Canmissioners 100 ReJk., POB 247 FOB 1488 Elon College, NC 27244 Raleigh, NC 27602 449-7707x241 919 :832-2893

William F. Hamnex pkillip E. Heck NCHaz. WasteMgt. Br. Black & Veatch, Inc. POB 2091 FOB 728 Raleigh, NC 27602 Asheboro, NC 27204 919: 733-2178 919:672-3600

58.7 Gisele Hedrick Gregory J. Hollod City of Lexbgton, Water Res. E.I.IXzPont Nemours & Co. 28 W. Center St. Tech. Lab(d), Chamber Works Lexhgton, NC 27292 -ter, NT 08023 704:352-7889 609:540-4075

James A. Heist Bill Holmn Heist Engr. Corp. Ehv. Lahbyist/ccN/Sierra Club 5929 Market St., Box 4518 206 New &rn Place Wibninglmn, NC 28406-4518 Raleigh, NC 27601 919 ~791-6766 919: 787-8921

Phyllis Hines &on Holt Tam of cary City of Raleigh, RJ Bpt. FOB 1147 FOB 590 w, NC 27513 Raleigh, NC 27602 919:469-4024 919: 779-2010

J& HirschhOm Margaret Holton Office of Technology Assessment League Warm Voters U.S. congress 411 Holly Lane Washington, DC 20510-0825 Chapel Hill, NC 27514 202:226-2089 919:929-1339

Randy Hite M. E. Hmper Emory L. Wilson & ASSOC. unitex chemical corp. 256 Little -tee Rd. FOB 16344 Colfax, NC 27235 Greensboro, NC 27406 919:668-7784 919:378-0965 Dennis J. Hcdge C. SuzanneHmer City of Mebane NRcD-DEM 106 E. Washington St. FOB 27687 Mebane, NC 27302 Raleigh, NC 27611 919: 563-6141 919~733-5083

Kenneth Hofban David H. Hawells Mecklenburq County m9f. nTleritus, NCSU 700 N. Tryon St. CB 7912 Charlotte, NC 28202 Raleigh, NC 27695-7912 704:336-3713 919:737-2815

Vic Holland sandy Huff Fieldcrest Cannon City of Whiteville Box 107 FOB 617 Kannapolis, NC 28082 Whiteville, NC 28470 704:933-1221 919~642-5818 Mark E. Hollis Don Huisingh WeWer Co. Univ. Studies, NCSU (on leave) FQB 33189, WC-2809 Univ. of Iund, TDl, Box 62 Charlotte, NC 28242 S-2700 Sjobo, Sweden 704: 373-4258 9-011-464-162-7300

58.8 Gary HiJnt Fred Kibler Pollution mention program Torpedo Wire & Strip NRCD-DDl, Archdale Bldg. POB 7338 Raleigh, NC Rocky mt, NC 27804 919:733-7015 919~977-3900 Allen D. Isley cinay Kling City of wlrlington Pub. util., City of Raleigh FOB 1358 POB 590 wlrlirqton, NC 27215 Raleigh, NC 27602 919:222-5133 919: 890-3400

Richard J. Jendrucko George Knox Eng. Sci. & Mech., Univ. Tenn. a. coarrmissioner 310 perkins Hall 202 N. Mah Street Knoxville, TN 37996 Salisbury, NC 28144 615:974-7682 704 :636-0361

Alice Johnson Jerry KohJ. Hlth. serv. spec, MackTnl&, Inc. NcmJ Industrial Ekt. Senrice Industxial Dr. CB 7909, NcmT New Bem, NC 28560 Raleigh, NC 27695-7909 919:633-5151 919 ~737-2303 William C. Johnson John Kramer Recycle Mcts Inc. Black & mer 2870 Liberty et. HWY 301s Marietta, GA 30066 F’ayetteville, NC 28306 404~924-3023 919:423-3254

Delores Jones Lrxl Kravetz City of Burlington Shell Development Gorp. FOB 1358 POB 1380 wlrlington, NC 27215 HoustOn, TX 77701 919 :222-5133 713 :493-7311 Denny E. Jones Richard Kriesel €XEHs IL#) unican FOB 12233 400 Jefferson Rd. €U”P,NC 27514-1668 Rocky=, NC 919:547-4237 919 :446-3321

LeahJung changfuhm Duke Mdical Center, Errv. Safety mer CCapanY Box 3914 POB- 33189 lkrhm~,NC 27710 charlotte, NC 28241 919~684-3096 704: 373-5691

Randy Jones Barrett Lasater NRCD-DEM Greenville Utilities Ccnnm. FOB 27687 POB 1847 Raleigh, NC 27611-7687 Greenville, NC 27834 919~733-5083 752-7166x347 58.9 Todd Layman J- Lrxmsbury,sP -0 vanguanl supreme Waste Minimization, USEPA, (WH565A) POB 5009 401 M St., SW Monroe, NC 28110 Washington, Dc 20460 704:283-8171 202:382-4807

Bill Leathd Ivan IJJwv B & W Metal Fabricators unitex chemical mrp. POB 729 FOB 16344 Welcome, NC 27374 Greensboro, NC 27406 704 :731-8417 919~378-0965

David G. I& Judith Lurid Hanes Knit ProducZs NCHaz. WasteMgntt. Br. 1205 W. Main St. POB 2091 Forest City, NC 28043 Raleigh, NC 27602 704:248-1511 919: 733-2178

Steven Levitas Earl R. MacComc NC Envhmnental Defense Fund Gc"s Sci Adv, Off. of GCW. 128 E.Haryett St, Suite 250 Rm. 1027, a.Bldg. Raleigh, NC 27601 Raleigh, NC Interoffice 919:821-7793 919~733-6500 w. TedLewis GeoryeMakrauer, pres. HamiltonBeach, Inc AmkoPlastics, ~nc. POB 1158 12025 Triton EM. W&hgtOIl , NC 27889 Cincinnati, OH 45246 919 :975-1158 513:671-1777 Lindaw. Little Liindam W.'s waste Mgntt. Board NIMS, Mail Drop c1-02 325 N. Salisbury St. 737 Alexander Dr. Raleigh, NC 27611 KIP, NC 27709 919:733-9020 919:541-3384

Gary Liu AllenMaples, Env. Sci NHT Sanford Tool mrp. USEPA Off. Solid Waste, E65 2903 Lee Ave. , 401 M. St., SW Sanford, NC 27330 Washhgton, Dc 20460 919: 775-2311 Wad Martin Oscar Lizararzu wlrlington Ind. Sheffield Fin. Plt. Nm-Ekt. Off. 500 Ahport Rd. 2825 Conifer Dr. Rocky Mt. , NC 27804 Raleigh, NC 919: 972-6327 919: 737-2956 Julie Martin Gary brig &son Record sandoz campany Po Drawer 959 Box 18278 Wadesboro, NC 28170 Charlotte, NC 28218 704 :694-2161 704 :331-7088

58.10 LarryMartin, Director George McRae HWM, Inst. for Local Self Reliance stanam, Inc. 2425 18th St., NW 2609 cox Mill Road W-n, Dc 20009 Sanford, NC 27330 202:232-4108 919:258-3341 Debbie Massengill Jerry Messick Adam Millis Hosiery Corp. United Metal Finishing POB 2489 133 Blue Bell EM Him Point, NC 27262 Greensboro, NC 27406 919:889-2311 919:272-8107 Tom Mather Richardr4essjnger News & Obsenrer CO. canmissioner Raleigh 202 N. Main St. North Carolina Salisbury, NC 28144 704:636-0361 sandi Mawer Land of Sky Reg. Council mgar Miller 25 Heritage Dr. Afton Associates Asheville, NC 28806 230 "E" St. , NC 704:254-8131 Washington, 20002 202:675-6266 William T. Mcclelland NC Dept. of Agriculture Gary Miller FOB 27647 UNC-A, E~Iv. Studies Raleigh, NC 27611 1 Univ. Heights 919:733-7366 Mevale, NC 28804 704:251-6441 Elizabeth ?4c"ck GSX chemical Services Gordon Miller 121 Ex Ctr Dr,Congaree Bldg. Rexham Corp. Colwlbia, SC 29210 FOB 368 803:798-2993 Matthews, NC 28106 704:847-9171 Michael E. =Daniel RCZkb3hn Co. Health Dept. phylissa Miller Rt 8, Box 7015 Univ. of Tennessee Reidsville, NC 27320 310 Ferkins Hall 919:342-8180 Knoxville, ?N 37996 615:974-4752 Babette McKemie NC-MICD Gregory Mmney POB 27687 cH2M Hill Raleigh, NC 27611 229 Peachtree St,NC-Ste 300 919:733-5083 Atlanta, GA 30303 404:523-0300 Tim McNeill Technibilt Sam Moore FOB 309 WurlingtonReSearch, Inc. Newton, NC 28658 615 Huffman Mill Rd-FOB2481 704 :464-7388 E?urlhgton, NC 27215 919:584-5564

58.11 David H. Moreau Marion Nichol Director, Water Res Res Inst Cons. Council of NC CB 7912, NCSU 1508 Ward St. Raleigh, NC 27695-7912 l%rh"L, NC 27707 919:737-2815 919 ~489-4439

Wallace Morgan Ve.mnica Nickolas "II of Winton JacksonCo. (Co. Cam.) FOB 134 Winton, NC 27986 Mickey O'Keefe 358-3041/1033 Ethan Allen, Inc, Pine Valley Div. Po Drawer 639 MarkM. Moroukian Old Fort, NC 28762 NYSDEC 704:668-7686 50 Wolf Rd. Albany, Ny 12233 Steve Oakley 518:457-7267 Showell Farms, Inc. FOB 524 Jewel Morris Siler City, NC 27344 EPA 919~742-4102 Rt 5, Box 282 ape^, NC 27502 Mary cdom scatland 0. Box 7 Dean Morrison Wagran, NC 28396 Town of Forest City 919:369:2362 FOB 728 Forest City, NC 28043 Michael oven=ash 704:245-4317 NCSU, Chem. Engr. CB 7905, NCSU Marian p.ludar Raleigh, NC 27695-7905 Ehv. Facilties Gorp. 919:737-2325 50 Wolf Rd Albany, NY 12205 Fred G. 0v-t 518~457-4132 Forqth Co. Ehv. Health 720 Ridge Avenue Wolfgang Muller Winston-Salem, NC 27102 VPI 919~727-2760 Architecture Annex, VPI&SU Blacksbury, VA 24060 Robert C. (Bob) Pace 703:961-7508 General Electric POB 780, M/C H-02 Thclmas Mullins Wilmincjton, NC 28402 Civ. Pers. Dept. PSC-4098 919~675-5385 CPT-Stop 7, MCAS Ch- Ft., NC 28533-4098 -rye W. page 919:466-3992 unitex chemid corp. POB 16344 Raymond D. Nelson Greensboro, NC 27406 Civ. Pers. Dept. PSC-4098 919:378-0965 CPT Stap 7, MCAS cherry Pt., NC 28533-4098 919:466-3992

58.12 William paise, TA Unit Larry- Haz. WaSteMgmt. Branch Black & Vat&, Lnc. NC Div Hlth Serv-Bath Bldg. FOB 728 Raleigh, NC Interoffice Asheboro, NC 27204-0728 919: 733-2178 919~672-3600

Chris Wisher ROY Sanford wwrp Schrader- Bellaws FOB 338 US #1 North Sanford, NC 27330 Wake Forest, NC 27587 919:776-9714 919: 556-4031

Russell A. Wker 'IbersaG. Pereira Compuchem Laboratories public Works commission FOB 12652 FO Dr. 1089, 508 Person St. RI", NC 27709 Fayetteville, NC 28302 919 :248-6480 483-1401x302

David Pasquini Jerry F. perrell DNS Electronic Materials Weber U S A, Inc. FOB 13488 FOB 548 KIF, NC 27709 Sanford, NC 27330 919:941-8811 919~776-4111

Bvid Patte -Perry MPAGrad. Student, NW Alamance co Hlth Dept 951 St. Mary's St. 209 N Graham-Hopedale Rd Raleigh, NC 27605 wlrlington, NC 27215 919: 828-0915 919:227-0101

Elizabeth Pam Helen phifer Assoc. Co. Cormnissioners Ixlpont FOB 1488 FOB 800 Raleigh, NC 27602 Kinston, NC 28501 919: 832-2893 919:522-6445 Patrick patton Terry Pierson Newton Instr. Co. Res. Triangle Inst. FOB 727 FOB 12194 Wltner, NC 27509 KIF, NC 27709 919: 575-6426 919:541-7406

Wiley payton C. Greg Piner Carolina mer 64 Light co. Naval Aviation Dept Rt 1, Box 327 NCAS New Hill, NC 27562 cherry Point, NC 28533 919: 362-3227 919:466-7604

&MA. Pazderski Bill Pitchford mion, Inc. NCHaz. WasteMgmt. FOB 760 FOB 2091 Sanford, NC 27330 Raleigh, NC 27602 919: 775-2201 919:733-2178

58.13 DonaldM. Preiss Don Rhcsm NCSU Industrial Esrt. Service City of Shelby CB 702, NCSU FOB 207 Raleigh, NC 27695-7902 Shelby, NC 28150 919:737-2356 484-6844

Philip prete StepllanieRichardson UNC-CH MlQFDETvl 311 Pittsbom St, CB 7410 116 1/2 W. Haryett St. chapel Hill, NC 27514 Raleigh, NC 27601 919:966-1301 919 :733-6900 Doug Rader Joe Riddle NC RIVDefense Fund Neptco Im= 128 E Hargett St-Ste 250 R3B 1766, Rt 321 south Raleigh, NC 27601 Lenok, NC 28645 919: 821-7793 704:728-5951

Nick Rawls Jess Riley Edward Week Gav. waste Mgmt E?d 100 Weck m. RE', NC 27709 Chrlotte, NC 28307 919:544-8000 704:375-4342 Jahn B. Razza Barry Robbins Mic=rabics Textilease mrp. 2024 Eldorado Dr. 821 S. Church St. Atlanta, GA 30345 Rocky Mount, NC 27803 404:633-2783 919:977-1445

Todd Redman Mike Roepke Em. Inks and coat~s western Carolina univ. 1 Quality products Dr. €OB 1603 MorgantOn, NC 28655 Cullowt-lee, NC 28723 704:433-1922 704:293-9244

Jim Reid Larry R- NFCEDEM mispy-menf2 Doughnut FOB 370 FOB 83 Asheville, NC 28802 Winston-Salem, NC 27102 704:251-6208 919: 725-2981

Frank Reinhart vim=ent Ross Glendale Hosiery Co. RcssAssociates, Inc FOB 686 FOB 2018 Siler City, NC 27344 Asharille, NC 28802 704 :255-8778 Ricky Revels John Roy NFCIFDEM 01h Hunt specialty Prod., Inc. Ste714, Wachovia Bldg 201 Rmsevelt Place Fayetteville, NC 28301 Palisades park, NT 07650-0800 919: 486-1541 201:944-1449

58.14 John Rutten John Scott H.B. Fuller Campany southchem, Inc. 1200 WoltersBlvd-Vadnais Hts FOB 1491 Minneapolis, MN 55110 Ixlrham, NC 27702 612:481-3300 919: 596-0681

Glenn sanderson Ric scruggs G1we.r Printing m.waste Qord., Ixlke mer Co. 2401AtlantiC Ave. CMIX;D, FOB 219 Raleigh, NC 27604 Seneca, SC 29679 821-5535 803:882-0954

Wyne schaenzer Bill secsrest Siemens Erierqy & Auto. ciba-igy POB 29503 FOB 18300 Raleigh, NC 27626 Greensboro, NC 27419 919:365-6660 1800334-9481x2539

Roger Schecter, Dkr. Jim Sellers pollution prevention Pmg., NlicD Hanes Knit products MS WH 562-A, 40lM St, SW POB 3019 Washington, DC 20460 Whston-Salan, NC 27102 202:382-4617 919:744-2104

Wce B. Mdt, Pres. Lm Natl.Ass0 Plastic Container Recovery Tam of -Tari” 200 One PhBrwk Plaza FOB 220 Charlatte, NC 28217 Tarbro, NC 27886 704 :523-8543 919: 641-4251 Roland Schmidt Asad Sui Black & Decker -DEN Ih.Jy 301 S ArcMale Bldg Fayetteville, NC 28306 Raleigh, NC 919~423-3258 Jane sharp Judy H. Schulte NC Co- Council We mer Co. 307 Granville Rd. FOB 33189 Chapel Hill, NC 27514 Charlotte, NC 28242 919:942-1080 704:393-8143 Ed Sheffield Terry Schurter,WT SLqXr. walterKidde, Inc. Data General Corp. 2500 Airport Rd FOB 186 Wilson, NC 27893 Clayton, NC 27520 919:237-7004 919:553-5076 Brian W. Sheldon, Ass. Prof. Rob Schwarz NCSU Food Science De@. Fast Food Merchar& ‘sers, Inc. CB 7624, NCSU 1233 N. (31- St. Raleigh, NC 27695-7624 Rocky Mount, NC 27801 919:977-8518

58.15 Antony Shoaf Denise smith Bowman Gray Sch. of Medicine Civ. Fers. Dept. PSC-4098 300 S. Hawthorne Rd. cpp-stop 7, MCAS Winston-Salem, NC 27103 cherry Pt., NC 28533-4098 919:748-4885 919~466-3992

Steve Shcaf Dick smith UNCU-I Ethan Allen, Inc. Pine Valley Div. Dept ES, CB 7400 Po Drawer 639 chapel Hill, NC 27514 Old Fort, NC 28762 704:668-7686 Danny Sigmon City of Newton Garyo. smith FOB 550 City of Albemarle Newton, NC 28658 POB 190 704:465-7480 ABemarle, NC 28002-0190 704:982-013U250 Mary L. Sigmon [email protected], Inc. Ralph smith Rt 14, Box 350 meGenerdL corporation Statesfile, NC 28677 FOB 186 704~873-8954 Clayton, NC 27520 553-5076x62 35 Duane siler Inst. of Scrap Recycling Industries Susan smith 1627 K St, NC, Suite 700 ctr for Iqr. Mtn. Living Washington, Dc 20006 Western ~rolinaUniversity 202:466-4050 Cullowhee, NC 28723 704:227-7492 Pamela Simpson Duke Wer Co.-CMD-North RLdy smithwick FOB 33189 NRCD-DDI Charlotte, NC 28242 POB 1507 704~875-5100 Washington, NC 27889 919: 946-6481 Eric A. Slaughter Self-employed Peter somers 5228 HilltopNeedmore city of Raleigh Fuq~ay-Vah27526 FOB 590 919: 552-4341 Raleigh, NC 27602 919 :890-3070 George Smelcer U. TN ctr. for Lndustrial Service charlie Soto Ste401-226 Capital Blvd Bldg Merk, Sharp & Doh Nashville, TN 37219-1804 Rt. 2, Box 558 Wilson, NC 27893 AllenR. smith 919~243-1196 Civ. Pers. Dept. PSC-4098 CPT-Stop 7, MCAS Marlene A. Spritzer ChqPt., NC 28533-4098 muflamb hiby & Mame 919~466-3992 POB 31507 Raleigh, NC 27622 919:787-5200

58.16 Myrtle Snead IBward Taylor Hornwood, Inc. E. Gifford Stack €OB 799 National Soft Drink Assoc. Waded", NC 28170 401 16th St., NW 704 :848-4121 Washington, Dc 20036 202:463-6740 Stan Taylor Data General Robert J. Stalter, Jr. pOB 186 whitin Rcdserts co. Clayton, NC 27520 FOB 250 919~553-5076 Sanford, NC 27330 919:775-7321 Gutwinski Thamas OKD-m Tom Ste@m-son A-2380 perchtoldsdorf Industrial Ext. senrice Uhnskh~St. 36, AUSTRIA CB 7902, NCSU 0222/725107/244or243 Raleigh, NC 27695-7902 919:737-3262 Rick~~n,Mfg.Mgr. Southem Fastening systems Christine stevens POB 1360, 1211 Barkley Rd ctr. for mr. Mtn. Living Statesrille, NC 28677 Western &rolina Univexsity 704 :873-7211 Cullowhee, NC 28723 704 :227-7492 Glennmore, VP, M€g. Land E Packaging, Inc. JamesM. Stewart 2100 Summit Ave, POB 14429 Asst. Dk., WRRI Greensboro, NC 27415 CB79l2, NCSU 919: 621-2570 Raleigh, NC 27695-7912 919:737-2815 Gary T. "weed NFCE-DEM Walter stone POB 370 Clyde Fabric Asheville, NC 28802 FOB 760 704~251-6208 Newton, NC 28658 704:464-4662 Robert uho* Research Triangle Institute Iarry street POB12194,3040 Cornwallis Rd Glendale Hosiexy Co. KI'P, NC 27709 FOB 686 919:541-6978 Siler City, NC 27344 919:663-2200 peter vandenberg city of Laurinburg William C. Stuckey POB 249 Be1dh-q Corticelli Research Laurinbury, NC 28352 FOB 310 919~276-8324 Hendersonville, NC 28793 Marcus H. Voth June Swallm Fenn State University NCHaz. WasteMgmt. Branch Breazeale Reactor FOB 2091 University Park, PA 16802 Raleigh, NC 27602-2091 814:865-3110 919:733-2178

58.17 George Wahl Vicki westbrook NCSUDept. chemistry City of D&mn, Water Res. CI3 8204, NCSU 1900 East Club Blvd. Raleigh, NC 27695-8204 Ixlrfiam, NC 27704 919:737-2941 919:683-4386 Keith E. Wandell, Vpopes. Janet Hatley white southern Fkishuq* m- mgue Women Voters & buisbury col. EOB 1360, 1211 Barkley Rd. 1 -11 Place - Statesvfile, NC 28677 -, NC 27549 704:873-7211 496-2523x210 G. Edward Warren, Jr. R.B. white NRCEDEM, Water Quality Kemet Electsonics cow. 1424 Carolina Ave. POB 2428 Washington, NC 27889 Shelby, NC 28150 919:946-6481 704~484-8181 JamesV. Waynick, Per. Dh. JohnE. whitehurst The Equity Group Bertie county Mgr. POB 1436 POB 530 Reidsville, NC 27320 Windsor, NC 27983 919:342-6601 919:794-4031

Ruby weathersbee George J. whitesides Fer.Mgr.-Safety, L&E Packaging, Inc. WrennHandling, Inc. 2100 Sunnnit Ave, POB 14429 FOB 30337 Greensboro, NC 27415 charlotte, NC 28230 919:621-2570 704:588-1300 Ken weaver M.E. (Pete) Williams southern Recovery poritts & spencer, Inc. EOB 3279 FOB 1411 Ft. Mill, SC 29715 Wilson, NC 27893 803:548-5740 919: 291-3800 Dennis w. weeter Stan Williams Dennis weeter Assoc/U.of m -Deea Rt 4, Box 283 PO Dr. 1417 Louisville, TN 37777 Rockingham, NC 28379 615:970-2313 Larry Williamson Christine Wesson Hornwood, Inc. MCNC POB 799\Wadesboro, NC 28170 3021 C~rnwallkRd RI'P, NC 27709 John Willis 919~248-1461 AMP, Inc. 3900 Reidsville Rd Mike West WinstOn-Salem, NC 27102 DNS 919~727-5351 POB 13488 m,NC 27709 919:941-8811

58.18 Douglas E. Wilson HeritageEnv. Sesvices, Inc. 4132 Pompano Rd . Charlotte, NC 28216 704:392-6276 Tam Woods T" of Wake Forest 400 Elm St. Wake Forest, NC 27587 919:556-1469

Nelson Young Gilbarco, Inc. Box 22087 Grea~sbom,NC 27420 919:547-5211 Bill Zaist Roy F. Weston, Inc. 4020 Westchase Blvd. #375 Raleigh, NC 27607 919:832-7042

58.19