Source Reduction Strategy Manual

SOURCE REDUCTION STRATEGY MANUAL

PENNSYLVANIA

COMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF ENVIRONMENTAL RESOURCES

BUREAU OF WASTE MANAGEMENT

Robert P. Casey Arthur A. Davis Governor Secretary An Equal Opportunity iAfCimsUve Adon Employar

July 1,1992 Revised May 28,1993 . TABLE OF CONTENTS

INTRODUCTION ...... 1

ELEMENTS OF A SOURCE REDUCTION STRATEGY ...... 2

QUESTIONS AND ANSWERS ...... 3

BEYOND THE REGULATIONS ...... 5

ELEMENTS OF A SOURCE REDUCTION PROGRAM ...... 5

MEASURING SOURCE REDUCTION ...... 7

SOURCE REDUCTION OPPORTUNITY ASSESSMENT ...... 11

1. Planning and Organization ...... 11 2. Assessment ...... 13 3. Feasibility Analysis ...... 20 4. Implementation ...... 21

APPENDIX A - A MATERIAL BALANCE APPROACH TO AUDITING

APPENDIX B - SRS REPORTING FORMS

APPENDIX C- THE REGULATIONS

APPENDIX D - ADDITIONAL SOURCES OF INFORMATION

Recycled Paper

SOURCE REDUCTION STRATEGY MANUAL

I INTRODUCTION I

Source reduction provides opportunities for industry to achieve both environmental and economic benefit. There is growing awareness that we cannot continue to throw away our valuable resources. Source reduction allows us to provide for our physical needs while preserving the natural environment that is essential for all life.

Pennsylvania's residual and hazardous waste regulations focus on source reduction as a means to prevent waste. In the waste management hierarchy, source reduction is of highest priority, followed by use and reclamation, treatment and, finally, disposal as a last resort. Source reduction is the reduction or elimination of waste at the source, usually within the production process. The term includes process modifications, feedstock substitutions, improvements in feedstock purity, improved housekeeping and management practices, increases in the efficiency of machinery, use or reclamation within a process, or any other action that reduces the amount of waste leaving a process. The use or reclamation of waste after it leaves the industrial process is not source reduction. These activities are still preferable to treatment or disposal when conducted in an environmentally sound manner. Dewatering, compaction, or other treatment techniques that prepare the waste for disposal are not source reduction. Any activity that simply transfers the waste to another media, such as air or water, is not source reduction.

There are many benefits to be gained from source reduction. Most fundamentally, the generation of waste may indicate some inefficiency or incomplete use of resources. Therefore, to reduce waste is to increase industrial efficiency. As Michael Royston explains in Pollution Prevention Pavs (1979): "Industrial operations begin to affect the environment with the investment decision which is taken internally and subject to internal criteria of financial return and technological feasibility. However, in order to become operational, technology requires resources -- water, air, land, raw materials, energy -- which are to be found in the physical environment. This inter- action between technology and the physical environment results in depletion of resources on the one hand and a build-up of wastes -- pollution -- on the other. The strategy which the modern manager must learn if he is to cope with this double problem is that of a non-waste technology, one which conserves resources, reduces pollution and saves money at the same time." A comprehensive source reduction program can have many benefits, including conservation of raw materials, reduced disposal costs, reduced environmental liability, higher product yields, enhanced corporate image, and reduced environmental compliance burden.

-1- This manual has been developed for two purposes. First, it is designed to help waste generators comply with the regulatory requirements for a Source Reduction Strategy. Second, it is intended to help generators achieve substantial environmental and economic benefits through significant source reduction accomplishments.

I ELEMENTS OF A SOURCE I REDUCTION STRATEGY

The new state regulations require that generators of residual and hazardous waste prepare and implement a source reduction strategy (SRS). Generally, the SRS must include:

1. A description of the source reduction achieved during the past five years, including a quantification of the results. This is intended to provide recognition for past achievements and provide a background for the activities planned for the future. Various methods for quantifying the results will be discussed later.

2. A statement that a source reduction program has been established. This may include a statement of corporate source reduction goals or of top management’s commitment to implement the program.

3. A description of what will be done to reduce waste, when the action will be done, and what amount of reduction is anticipated. This is intended to be a simple and direct representation of the results of the assessments made within the facility and the decisions reached regarding source reduction actions that will be taken.

If no source reduction action is proposed, the facility is required to submit detailed justification. This must demonstrate that a thorough internal investigation of source reduction opportunities has been completed. This information must include an extensive waste stream characterization, potential source reduction options __ considered, how these options were evaluated, and why each option was not selected. Sufficient detail must be provided to demonstrate the technical or economic barriers that prohibit reductions. The level of detail required to justify not participating in ~ source reduction is substantially greater than preparing and implementing a source reduction plan.

-2- I QUESTIONS AND ANSWERS I

Who mustprepare the source reduction strategy?

The state residual waste regulations require that anyone who generates more than 2,200 pounds of residual waste in any calendar month must prepare a source reduction strategy. The Department has waived the SRS requirements for individual types of waste that are generated in quantities of less than 2,200 pounds per month per generating location (See 8287.51). This waiver will be reevaluated two years after the effective date of the regulations. The purpose of this waiver is to allow generators to concentrate on reducing or eliminating larger waste streams where greater economic and environmental benefits can be attained.

The hazardous waste regulations exempt those who generate less than 1,000 kilograms of hazardous waste in each month of the year. There is no waiver for small waste streams.

When must the SRS beprepared?

For residual waste, there is a one year interim period during which special provisions have been made to allow the SRS to consist of a presentation of a firm’s ongoing efforts to reduce wastes. This is described as option 3 on Form 25R (see Appendix B). For example, during the first month after the regulations are published, the strategy might consist of the general information portion of the form plus a list of the members of the assessment team and what they are doing. The SRS should be regularly updated to reflect progress in developing a finished SRS. A final SRS must be available for inspection by July 4,1993.

For hazardous waste, the full SRS must be prepared by January 17,1994. There is no one year interim period for the hazardous waste SRS.

When must the strategy be submitted to the Department?

The SRS must be available for inspection at any time and must be submitted to the Department upon request. The SRS must be submitted to the appropriate DER regional ofice with any Form U (request to process or dispose of an industrial waste at a permitted facility) or Module 1 (request to process or dispose of hazardous waste). The SRS must also be submitted with any application for a permit to treat, process, or dispose of either residual or hazardous waste.

-3- How often must the strategy be updated?

The SRS must be updated every five years unless an alternate schedule is established in writing by the Department. The SRS must also be updated any time there is a ~ significant change in the type of waste generated or in the manufacturing process. The update should include the progress achieved during the past five years as well as plans for the next five years.

Are regular progress reports required?

Progress in achieving source reduction will be described as part of the biennial report for residual waste generators. Hazardous waste generators will describe the results in the EPA biennial report. Additionally, the SRS itself includes a description of past achievements.

Is an SRS required for each waste stream?

Generally, a separate SRS is needed for each waste stream. In some cases, it is acceptable to combine several related waste streams which are generated through the same process where the source reduction actions are the same. For example, one SRS could include plating sludge, spent plating bath solutions, and plating rinse water because they come from the same industrial process line and they can be reduced by common means. Another example is in the generation of waste laboratory reagents removed via lab packs. Although there may be 200 different waste reagents, they can all be reduced through common means such as inventory control and a reagent exchange program. Therefore one SRS may be adequate for all 200 waste streams.

I have form 25R forpreparing the residual waste SRS, but what form should I use for the hazardous waste SRS?

Form 25R should also be used for the hazardous waste SRS. Be sure to indicate whether the waste is hazardous or residual by checking the appropriate box in Item I on the first page (waste stream name and description).

Are research and development facilities exempt from the SRS requirement? Under residual waste regulations, the Department may waive requirement for the SRS at __ R&D facilities. This would be done on case by case basis if it can demonstrate why the SRS does not make sense. There may be many opportunities for SRS at these facilities. There is no such waiver available for hazardous waste generated at R&D ~ facilities.

-4- Where can Iget additional information about source reduction approaches for my industry?

The Pennsylvania Department of Environmental Resources' Source Reduction Unit is available at (717) 787-7382 to provide source reduction/pollution prevention technical assistance information to businesses. The unit is developing a clearinghouse of case studies and technical information that can be used by firms working to develop and implement source reduction strategies. In addition, consult Appendix D of this document which provides additional sources of information.

I BEYO.ND THE REGULATIONS I

The remainder of this manual is designed to provide a variety of considerations and approaches useful in the internal identification and evaluation of source reduction opportunities. Topics include:

1. Elements of a source reduction program. 2. Measuring source reduction. 3. Conducting a source reduction opportunity assessment (an internal auditing approach). 4. A material balance approach to auditing (Appendix A).

The regulations only require that industry provide a summary of source reduction achievements and plans. The manual provides an in-depth discussion of source reduction techniques that will allow firms to achieve economic and environmental benefit through reducing waste.

I ELEMENTS OF A SOURCE I REDUCTION PROGRAM

The following six step outline is derived from Draft Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program. The outline was published by EPA in the Federal Register, Vol. 54, No. 111, pp. 25056-25057on Monday July 12,1989. The guidelines were developed to help hazardous waste generators comply with the certification on each manifest that "the generator of the hazardous waste has a program in place to reduce the volume or quantity and toxicity of such waste..." The guidance has been revised to reflect the Department's specific focus on source reduction.

-5- A. Top Management Commitment. Top management should ensure that source reduction is a company-wide effort. There are many ways to accomplish this goal.

- Make Source Reduction a company policy. Put the policy in writing and distribute it to all departments. Make it each person's responsibility to identify and implement opportunities to reduce waste. Reinforce the policy in day-to-day operations, at meetings and other company functions. - Publicize success stories. It will trigger additional ideas. - Set specific goals for reducing the volume or toxicity of waste streams. - Commit to implementing recommendations identified through assessments, evaluations or other means. - Designate a source reduction coordinator at each facility to ensure effective implementation of the program. - Reward employees that identify cost-effective source reduction opportunities using monetary awards representing a portion of the cost savings. - Train employees on aspects of source reduction that relate to their job. include all departments, such as those in product design, capital planning, production, operations, and maintenance.

B. Characterization of Waste Generation. Maintain a waste accounting system to track the types, amounts and hazardous constituents of wastes and when they are generated. Identify and analyze the process that generates the waste

C. Periodic Source Reduction Assessments. Track materials that eventually wind up as waste, from the loading dock to the point at which they become a waste.

- identify opportunities at all points in a process where materials can be prevented from becoming a waste. Examples include using less material, recycling materials within the process, finding substitutes, or making equipment changes. Individual processes or facilities should be __ reviewed periodically. Larger companies may find it useful to establish a team of independent experts that may include both consultants and internal staff. ~ - Determine the true costs of the waste. Calculate the costs of the materials found in the waste stream based on the purchase price of those materials. Calculate the cost of managing the wastes that are

-6- generated, including costs for personnel, record keeping, transportation, liability insurance, pollution control equipment, treatment and disposal and others.

D. A Cost Allocation System. Departments and managers should be charged "fully-loaded'' waste management costs for the wastes they generate, factoring in liability, compliance and oversight costs.

E. Encourage Technology Transfer. Seek or exchange technical information on source reduction from other parts of your company, from other firms, trade associations, State and university technical assistance programs or professional consultants. Many techniques have been evaluated and documented that may be useful in your facility. Share the results of your efforts and obtain favorable publicity by applying for the Governor's Waste Minimization Award. Sources of further information are listed at the end of this manual in Appendix D.

F. Program Evaluation. Conduct a periodic review of program effectiveness. Use these reviews to provide feedback and identify potential areas for improvement.

I MEASURING SOURCE REDUCTION I

The regulations require that the generator quantify past reductions in the weight or toxicity of waste generated and quantify the projected reductions that will result when the strategy is implemented. Several methods can be used to quantify source reduction, including actual quantity change, adjusted quantity change, throughput, and changes in level of hazard or toxicity. Waste generators must determine which method of measurement is most appropriate for each specific waste stream.

The actual quantity change is the change in weight or volume of waste generated in a given time. This is a simple method, but it may not accurately describe the amount of waste reduction that has occurred. This is because other factors, such as changes in production levels or product quality are not considered. For example, the Pennsyl- vania Widget Factory generated 100 tons of widget sludge in 1991 and 50 tons of sludge in 1992. It might appear that source reduction has occurred. In fact, the facility did not implement their SRS and no reduction actually took place. We'll see why by analyzing the waste generation more closely.

This leads to the second measurement method, adjusted quantity change. An activity index is used to adjust the actual quantity change to account for changes in production activity. The measure of production activity selected should be the factor which is most closely correlated to waste generation. Possibilities include number of employees, weight of product, number of units of product, surface area of product, and dollar value of product. The best measure is based on the mechanism by which the waste is generated. For example, a firm which plates zinc on metal sheets may choose the surface area plated as the most appropriate measure of activity. Thus, waste generation might be expressed as pounds of plating waste per square foot of metal plated. Analysis of the Pennsylvania Widget Factory's waste generation figures taking into account production figures reveals the following:

~ Widgets Sludge Tons of Sludge Year Produced Generated (Tons) Per Widget 1991 1,000 100 0.1 1992 400 50 0.125

Actually, the firm's production decreased at a greater rate than waste generation. In fact, the amount of waste per widget actually increased. This indicates that no waste minimization has occurred.

activity/production index 1992 production 400 widgets for 1991-1992 - ...... - ____------_----__= 0.4 1991 production 1,000 widgets *

100 tons of sludge X 0.4 = 40 tons of sludge (expected) This represents the amount of sludge expected in the current year if no waste minimization has occurred.

-a- To calculate the amount of source reduction, subtract the quantity of waste actually generated in the current year from the expected amount. 40 tons of sludge (expected) - 50 tons (actual)of sludge = - 10 tons Thus, a negative 10 tons indicated that negative source reduction, or an increase in waste generation, actually occurred.

A third quantitative measure of source reduction uses changes in the throughput ratio over time. The throughput ratio is defined as the ratio of the quantity of a chemical released as waste before treatment to the total throughput. The total throughput is the sum of the amount of chemical generated as waste plus the amount consumed in the process plus the amount incorporated in the product. Calculating the amount of throughput and the throughput ratio can make apparent source reduction opportunities and evaluate the efficiency of a manufacturing process.

The final class of quantification is reduction in toxicity or hazard. One indication of reduced hazard is if a hazardous waste is converted to a residual waste by changing raw materials or inputs to the manufacturing process. It is important to avoid transferring pollutants to another media or to dilute a waste. These activities are not source reduction. The important factor in documenting reductions in toxicity or hazard is to select proper criteria for each waste. For example, toxicity may be of little concern for a highly ignitable hazardous waste. Decreased ignitability so that the waste is no longer classified as hazardous might be a more relevant improvement. Evaluations of toxicity can be based on various properties of the waste and its potential effects on human health and the environment. The chemical, physical, and toxicological properties of the waste interact with the routes of exposure to result in risk. Essentially, the generator must use his knowledge of the waste and its potential effects on the environment to select a proper measure of toxicity and document a reduction in toxicity.

The key to selecting an appropriate means to measure source reduction is designing a system that accurately reflects the results of the source reduction actions. The mechanism by which the waste is generated is a key factor in selecting the optimum measurement method. The regulations allow the flexibility for the generator to design the best measurement method for each waste stream.

Much of this information was derived from Alternatives for Measuring Hazardous Waste Reduction, Baker, Dunford and Warren, Center for Economics Research, Research Triangle Institute, April 1991. (Prepared for the Illinois Hazardous Waste Research and Information Center).

-9- The Shiny Plating company has good records on their waste generation since 1987 and wants to be recognized for their residual waste reduction efforts. The firm generates a residual sludge from a line which plates zinc on watering cans. They first write in the actual tons of plating sludge generated in eachyear.

waste generation activity/production adjusted waste (tons) index (1987base year) generation (tons) 1

Then they calculate an activitylproduction index for each year. They have determined that the generation of sludge is directly related to the number of wateringcans plated. They list the number of cans manufactured each year and calculate the activitylproduction index by dividing each year's production figure by the 1987 production figure.

production calculation activitylproduction (number of cans) index (1987base year) 1987 1000 NA 1 1988 1100 110011000 1.1 1989 1700 1700/1000 1.7 1990 2100 2100/1000 2.1 1991 500 500l1000 0.5

Now, we simply take these activitylproduction index numbers and put them into the report chart. year waste generation activitylproduction adjusted waste (tons) index (1987base year) generation (tons) 1987 10 1 1988 10 1.1 1989 15 1.7 1990 18 2.1 1991 7 0.5

Then the adjusted waste generation is calculated by dividing the tons generated by the index. year waste generation activitylproduction adjusted waste (tons) index (1987base year) generation (tons) 1987 10 1 IO 1988 10 1.1 9.1 1989 15 1.7 8.8 1990 18 2.1 8.6 1991 7 0.5 14

By reviewing the completed calculations, we can see that although the waste generation increased from 1988 through 1990,the adjusted waste generation figures show that less waste was produced per unit of production. In 1991 less waste was generated, however, the adjusted waste generation figure shows that more waste was generated per unit of production.

-10- I SOURCE REDUCTION I OPPORTUNITY ASSESSMENT I

The elements of a source reduction program described previously outlined in general terms the vital components of a successful program. The source reduction opportunity assessment described here is a more detailed evaluation by which opportunities can be identified and internal decisions made regarding their implementation. This procedure may be used to develop the SRS required in the regulations, but only the results of the internal decisions need be presented in the SRS.

Auditing the waste generating process is essential to determine what can be done to reduce waste. One methodical procedure for analyzing the potential for reducing waste is outlined in The EPA Manual for Waste Minimization Opportunity Assess- -, EPA/600/2-88-025, April 1988. The manual includes numerous forms which may be useful in collecting, organizing, and analyzing pertinent information. Copies may be obtained from the RCRA hotline at 1-800-424-9346. The manual is designed to evaluate both source reduction and recycling. For purposes of the SRS it is important to maintain the emphasis on source reduction, although environmentally sound use or reclamation is still preferable to disposal. The following discussion, derived from the manual, has been revised to emphasize source reduction.

The essential steps in completing a source reduction opportunity assessment are:

r------7 I I I I 1. Planning and Organization I I I I 2. Assessment I I I 3. Feasibility Analysis I I I I 4. Implementation I I I

1. Planning and Organization

The first step in planning a successful source reduction strategy is obtaining the commitment of top management. Managers will support a source reduction program if they are convinced that the benefits of such a program will outweigh the costs. The benefits of reducing or eliminating waste include economic savings, conservation of raw materials, fewer regulatory requirements, reduced liability, improved public relations, and reduced environmental impact. A formal policy statement should be developed that spells out the firm’s commitment to reduce waste. Commitment throughout the organization is

-11- essential in order to resolve conflicts and remove barriers to source reduction. Employees are involved in the generation of waste, and they can contribute to the success of the program. Bonuses, awards, plaques, and other forms of recognition are often used to provide motivation and to boost employee ~ cooperation and participation. In some companies, meeting the waste minimization goals is used as a measure for evaluating the job performance of managers and employees.

The source reduction program will affect numerous groups within a company. For this reason, a program task force should be assembled. The Task Force should include members of all groups or departments in the company that have an interest in the outcome of the program. The typical responsibilities of the task force include: .

- Getting commitment from management. - Establishing program goals and policy statement. - Establishing a waste tracking system. - Prioritizing waste streams for assessment. - Selecting the assessment team. - Conducting assessments. - Conducting technicaVeconomic feasibility analyses of favorable options. - Selecting options for implementation. - Obtaining funding and setting schedules for implementation. - Preparing the written source reduction strategy (SRS). - Directing implementation. - Monitoring performance of the program.

The first priority of the task force is to establish goals that are consistent with the policy adopted by management. Initially, the goals can be quantitative or qualitative. However, a numerical estimate of waste reductions anticipated must be developed by the time the SRS is prepared. As the focus of the source reduction program becomes more defined, the goal should be updated. The goal should be measurable, motivational, and achievable with a practical level of effort.

Next, an assessment team must be assembled. The team should include people with direct responsibility and knowledge of the particular waste stream or __ process. In addition to internal staff, consider trade association representatives, consultants, or experts from different facilities of your company as members of the team. Quality circles have been used by many companies to improve ~ product quality and production eficiency. Quality circles foster participation and commitment, and they can be a valuable technique in developing successful source reduction programs.

-12- 1. Planning and Organization 2. Assessment 3. Feasibility Analysis 4. Implementation

2. Assessment

The purpose of the assessment phase is to develop a comprehensive set of source reduction options. In order to develop the options, a detailed understanding of the plant's wastes and operations is required. The assessment should begin by examining information about the processes, operations, and waste management practices at the facility.

Information should be collected to answer questions like the following:

. - What waste streams are generated? How much? How are they managed? - From which processes or operations do these waste streams come? - Which wastes are hazardous and which are not? What makes them hazardous? - What are the input materials used in the processes which generate the waste? - How much of the input material enters each waste stream? - How efficient is each process? - What types of housekeeping practices are used to limit the quantity of wastes generated? - What types of process controls are used to improve process efficiency? - What is the total cost of managing the waste, including internal and external costs.

One of the first tasks is to identify and characterize the waste streams. Infor- mation about waste streams can come from a variety of sources. Information on the quantity, destination and types of waste can come from hazardous waste manifests and shipping papers. Costs of off-site management can be obtained from waste management facility invoicing. A form U--request to treat or dispose of any waste in a Pennsylvania facility--includes detailed chemical and physical characterization of the waste and some information on how it is generated. Analytical test data from previous waste determinations, evaluations and routine sampling may be available.

-13- Flow diagrams provide the basic means for identifying and organizing information that is useful for the assessment. Flow diagrams should be prepared to identify important process steps and to identify sources where wastes are generated.

Flow diagrams are essential in developing material balances that quantify losses or releases that were previously not considered. Material balances also assist in developing the following information: ~

- A baseline for tracking progress of the source reduction efforts. - A method of measurement most useful for quantifying progress. - Data to estimate the size and cost of any additional equipment and other modifications. - Data to evaluate economic performance.

In its simplest form, the material balance is represented by the mass conservation principle: Mass in = Mass out + Mass accumulated

The material balance should be made individually for all components that enter and leave the process. When chemical reactions take place in a system, there is an advantage to doing "elemental balances" for specific chemical elements in a system.

Material balances can assist in determining concentrations of waste constituents where analytical test data is limited. Characterizing waste streams by material balance can require considerable effort. It can result, however, in a more complete understanding of the mechanisms by which waste is generated. It also can lead to an understanding of how to effectively measure waste reduction. Sources of information for completing the material balance include:

- Samples, analyses, and flow measurements of feedstocks, products, and wastes. - Raw material purchase records. - Material and emission inventories. - Batch make-up records. - Product specifications. - Production records and operating logs. - Standard operating procedures and operating manuals. - Waste manifests and shipping papers.

Material balances are more meaningful and accurate when they are done for individual units, operations, or processes. For this reason, it is important to

-14- define the material balance envelope properly. The envelope should be drawn around the specific area of concern, rather than a group of areas. Developing a material balance for a complex process can be a complicated undertaking. Such tasks are generally performed by chemical engineers, often with the assistance of computerized process simulators.

See Appendix A for an alternate auditing approach developed by the Ontario Waste Management Corporation with a strong emphasis on the material balance study.

The next phase of the assessment is the site inspection. Although data collection is vital to understanding the processes involved, site visits allow the team to see the actual operation of the facility. An inspection agenda may be helpful in planning the visit.

Guidelines for the Site Inspection

- Prepare an agenda in advance that covers all points that require clarification. Make staff contacts in the assessment area before the inspection.

- Schedule the inspection to coincide with vital operating procedures such as start-up, equipment cleaning, bath dumping and shutdown.

- Monitor the operation at different times during the work day, especially when waste generation is dependent on human activity.

- Observe and speak with plant operators, shift supervisors, and foremen. Assess their awareness of waste generation.

- Photograph or videotape the area of interest. Many details can be captured in photographs that otherwise would be forgotten or inaccurately recalled.

- Observe housekeeping details such as spills or leaks. Assess the overall cleanliness of the area. Note any odors or fumes.

- Assess the organizational structure and level of coordination between various departments in dealing with environmental activities.

- Assess administrative controls such as cost accounting, material purchasing procedures and waste generation records.

- 15- The site inspection should follow plant operations from the point where raw materials enter the process, to the point where the products and wastes leave. The team should identify the sources of waste. The inspection may result in preliminary conclusions on the causes of waste generation. Confirmation of the conclusions may require additional data collection, analysis or site inspections.

Now that the origins and causes of waste generation are understood, the team can generate a comprehensive set of source reduction options. Identifying _____ potential options relies both on the expertise and creativity of the team members. Again, team member can obtain additional information from trade associations, published literature, equipment vendors, and consultants. DER maintains information on waste reduction for many common waste streams and industrial processes. See Appendix D for additional sources of information.

Source reduction techniques can be characterized as good operating practices, technology changes, material changes, or product changes.

Good operating practices include procedural, administrative, or institutional measures that are used to reduce waste. Good operating practices apply to the human aspect of manufacturing operations. Many of these measures are used in industry largely as efficiency improvements and management practices. Good operating practices often can be implemented with little cost and, therefore, have a high return on investment. The practices can be implemented in all areas of a plant, including production, maintenance operations, and in raw material and product storage. Good operating practices include:

- Management and personnel practices. - Material handling and inventory control. - Loss prevention. - Waste segregation. - Cost accounting practices. - Production scheduling.

Management and personnel practices include employee training, incentives, bonuses, and other programs that encourage employees to strive to reduce waste. Material handling and inventory practices include programs to reduce loss of input materials due to mishandling, expired shelf life and improper __ storage conditions. Loss prevention minimizes wastes by avoiding leaks from equipment and spills. Waste segregation practices reduce the volume of hazardous wastes by preventing the mixing of hazardous and nonhazardous ~ wastes. Cost accounting practices include programs to allocate waste treatment and disposal costs directly to the departments that generate waste, rather than charging the costs to general overhead accounts. Departments that generate

- 16- the waste become more aware of the effects of their treatment and disposal practice, and have a financial incentive to minimize their waste. By judicious scheduling of batch production runs, the frequency of equipment cleaning can be reduced.

In four years, General Dynamics achieved a 75 percent reduction in hazardous waste generation. Both management and union officials are committed to continuing their waste minimization efforts. The corporate goal is zero waste . discharge.

Technology changes are oriented toward process and equipment modifications to reduce waste. These changes include:

- Modifications to the production process - Equipment, layout, or piping changes - Use of automation - Changes in process operating conditions

- 17- Case Studies of Technology Changes

0 AT&T Microelectronics in Reading, Berks County, reduced chlorofluoro- carbon (CFC) and chlorinated solvent use by revising two production processes. A wax removal process using a chlorinated solvent was eliminated by employing a mechanical device to hold wafers during the polishing process, The wax was previously used to secure the wafers on a polishing chuck. This process reduced AT&T's chlorinated solvent usage by more than 50 percent, A step toward eliminating CFCs in production was achieved by evaluating the need to clean. Several wafer process steps were revised to eliminate non-critical cleaning, reducing CFC use by 65 percent. AT&T received the Governor's Waste Minimization Award in 1991. The Merck & Company's Cherokee Plant in Riverside, Northumberland County, received the Governor's Award in 1990. The plant manufactures chemical intermediates used in the production of PRIMAXIN@,an antibiotic. One of the intermediates required purification via caustic hydrolysis to assure that the material did not degrade while being held for subsequent processing. The caustic purification generated 2,300gallons of waste water per batch and 1,640 pounds of toluene air emissions each year. Laboratory experiments were undertaken to determine if the intermediate product stabilitycould be maintained without the caustic purification. The experiments indicated that by modifying the mole ratios of the reagents used in the process, the reagent causing the degradation could be significantly reduced. This resulted in a dramatic increase in product stability and also increased product throughput. After thorough quality testing, the caustic purification step was eliminated. Cost savings of $280,000 were achieved in 1989 without expenditures for new equipment.

Input material changes accomplish source reduction by reducing or eliminating the hazardous materials that enter the production process. Changes in input materials can be made to avoid the generation of hazardous wastes within the production process. Two types of input material changes are material purification and material substitution.

Case Study of Input Material Change

0 General Dynamics previously cleaned parts with a trichloroethane vapor degreaser. The solvent was replaced with a washer that uses non- hazardous cleaning materials. The new process saved $2,500 in annual disposal costs and eliminates toxic air emissions. P i

-18- Product changes are performed by a manufacturer with the intent of reducing waste resulting from a product's use. Examples include product substitution, product conservation, and changes in product composition.

In the paint manufacturing industry, water-based coatings are noH' being used instead of solvent-based paints. The products do not contain toxic or flammable solvents that make solvent-based paints hazardous when discarded. Solvents are no longer needed to clean brushes, paint rollers and trays. The use of water-based paints instead of solvent-based paints also greatly reduces volatile organic compound emissions to the atmosphere.

The process of identifying source reduction options should occur in an environment that encourages creativity and independent thinking. Techniques such as brainstorming may be useful in developing a wide variety of options. After options have been generated, it is necessary to identify those that offer a real potential to reduce waste and save money. This preliminary screening procedure serves to eliminate marginal, impractical, or inferior options without a detailed and costly feasibility study. The screening method can include an informal review by the program manager, a vote by team members, or a quantitative decision making process. Whatever method is used, the screening procedure should consider the following questions:

- What is the main benefit gained by implementing this option? - Does the necessary technology exist to develop the option? - What is the cost? Is it cost effective? - Can the option be implemented within a reasonable amount of time without disrupting production? - Is there evidence that the option will work? - Does the option have a good chance of success? - What additional benefits will result?

The options now can be implemented if costs are acceptable and the benefits are apparent. Otherwise, the remaining options can be subject to detailed technical and economic feasibility evaluations.

-19. 1, Planning and Organization 2. Assessment 3. Feasibility Analysis 4. Implementation

3. Feasibility Analysis

The final product of the assessment is a list of source reduction options. The assessment will have screened out the impractical or unattractive options. The next step is to determine if the remaining options are technically and economically feasible.

The technical evaluation determines whether a proposed source reduction option will work in a specific application. If the option does not involve significant capital expenditures, the evaluation should be completed quickly and the options implemented. For equipment related options or process changes, visits to existing installations may be arranged through equipment vendors and industry contacts. Bench-scale or pilot tests may be necessary. The technical evaluation must also consider facility constraints and product requirements.

The economic evaluation is carried out using standard measures of profitability, such as a pay back period, return on investment, and net present value. Each company has its own method of analysis and economic criteria. The federal EPA Manual for Waste Minimization Opportunity Assessments contains principles of economic analyses, sample calculations and worksheets. An additional consideration, though difficult to quantify, is the reduced environmental liability associated with the reduction or elimination of a waste stream.

The final product of the assessment is a report that presents the results of the assessment and the technical and economic feasibility analyses. The report also contains recommendations to implement selected options. A quality final report can be a vital tool for getting a project funded and implemented. __ The report should include not only how much the project will cost and its expected performance, but also how it will be done. It is important to discuss:

~ - Reliability of the technology, with examples of successful applications, - Estimated construction period and production downtime.

-20- - How the performance of the project can be measured. - Reduced liabilities and improved public image.

1 ii Plan;:k;p,,,d Organization Feasibility Analysis 4. Implementation

4. Implementation The report provides the basis for obtaining company funding of source reduction projects. Because projects are not always sold on their technical merits alone, a clear description of both tangible and intangible benefits can help in obtaining funding.

Waste reduction projects generally involve improvements in process efficiency and/or reductions in operating costs of waste management. Even when a project promises a high internal rate of return, some companies may have difficulty raising funds internally for capital investment. Private sector financing includes bond loans and other conventional sources of financing. The state Department of Commerce offers low interest loans for the purchase of industrial equipment where jobs will be created or retained. Contact the Governor's Response Team at 717-787-8199for additional information. Additional sources of financial assistance are listed in Appendix D.

Source reduction options that involve operational, procedural, or materials changes without equipment changes should be implemented as soon as the potential cost savings, production and material scheduling feasibilities have been determined. For projects involving equipment modifications or new equipment, the installation of a source reduction project is essentially no different from other capital improvement projects.

The source reduction strategy may require modification based on experience gained in the initial implementation stages. Options that don't measure up to their original performance expectations may require changes. A quantitative measure of the success of the option should be developed based on the measurement methods discussed earlier.

-21- SUMMARY OF THE SOURCE REDUCTION ASSESSMENT PROCEDURE

The recognized need to reduce waste

PLANNING AND ORGANIZATION

Get management commitment 0 Set overall assessment program goals 0 Organize assessment program task force

&tm”ent organization aad commitment to proceed ASSE;SIMENT PHASE

0 Select people for assessment teams 0 Collect process and facility data 0 Carefully identify and characterize wastes Select new 0 Review data and inspect site assessment targets 0 Generate options and reevaluate 0 Screen and select options for further study previous OptiOnS

Assessment report of SdeCted QRtiOnS - 1I I PBASIBIllTY ANALYSIS PHASE I 0 Technical evaluation Economic evaluation I 0 Select options for implementation

IMPLEMENTATION Repeat the process 0 Justify projects and obtain funding - 0 Installation (equipment) Implementation (procedure) 0 Evaluate and measure performance APPENDIX A

A MATERIAL BALANCE APPROACH TO AUDITING

This material is reproduced courtesy of the Ontario Waste Management Corporation (OWMC). The material is from the "Industrial Waste Audit and Reduction Manual: A practical guide to conducting an in-plant survey for waste reduction." Copyright 1987 by OWMC. OWMC is a provincial Crown agency created by an act of the Ontario legislature in 1981 to establish a provincial system for treating and disposing of liquid industrial and hazardous waste. OWMC also helps industry with waste reduction, reuse, recycling, recovery and exchange. This information provides an excellent discussion of an auditing approach with a strong emphasis on process flow and material balance concepts.

Chapter 2: Overview An Approach This chapter describes an approach to conducting your waste audit. It is designed to be generic in nature to apply to as broad a spectrum of Ontario industry as possible. As you go through the 18 steps, it may become obvious that some parts do not apply to your particular circumstances. You may also require additional or modified steps for your individual needs. If this is the case, then adapt as necessary. However, we feel that the following approach is sound and should form the basis of your investi- gations. The waste audit/waste reduction approach is divided into six phases and incorporates a number of steps as follows:

Phase One: Understanding the processas in your plant Step 1: Listing of unit processes Step 2: Constructing a process flow diagram

Phase Two: Defining process inputs Step 3: Determining resource usage Step 4: Investigating raw material storage and handling losses Step 5: Recording water usage Step 6: Determining current levels of waste reuse

Phase Three: Defining process outputs Step 7: Quantifying process outputs Step 8: Accounting for wastewater flows Step 9: Documenting wastes stored and hauled off-site for disposal

Phase Four: The material balance study Step 10: Assembling unit process input and output information Step 1 1 : Deriving a preliminary material balance for unit processes Step 12: Evaluating the material imbalance Step 13: Refining the material balance

Phase Five: Identifying waste reduction alternatives Step 14: Examining obvious waste reduction measures Step 15: Targeting problem waste streams Step 16: Developing long-term waste reduction altematives

Phase Six: Cost/ benefit analysis and implementing action plan Step 17: Doing a cost/benefit analysis for waste treatment/reduction Step 18: Implementing your action plan: reducing wastes and increasing production efficiency

I” The following section describes the 18 steps. It should be emphasized that although the auditing procedures are described as discrete steps, the audit needs to be thoroughly planned and developed by the user into an efficient and integrated approach. For example, Phases Two and Three should be run concurrently. It may also be worthwhile to refer to the case studies while you progress through the audit.

Phase One of the waste audit involves going into the plant Step 1: listing of unit processes and developing a sound understand- Your plant consists of many unit processes. The first step in the waste ing of all the proc- audit is to identify and list all your unit processes and then assemble as ess components and much information on them as possible. Record this information in a table, their interrelation- similar to Table 1 below, and begin developing a file of all existing infor- ships. It is worth- mation. For the sake of keeping records, assign a name to each unit proc- while at this stage to ess. While it will be obvious to you that a reactor or plating bath is a unit solicit help from process, it will be equally important to identify and describe ancillary staff who are famil- features such as storage locations, pumping stations, warehouses, cooling iar with the day-to- towers, and even treatment lagoons and wastewater treatment systems as day operations of unit processes. Each will have discrete inputs and outputs, although they the plant. are not directly part of the production process.'

Tabis 1: Idsntificatinn nf nnlt nrncw

Unit Process Functional Descipiian File Number

e.g. Surface Trealmeni -Surface treaimeni of meial I (A) products before painting -10 m' spray chamber -6 iets. 100Um oumo

(B)etc. 2

Use your discretion as to the level of detail collected. It may be necessary to concentrate on certain problem areas to start with, e.g. in Case Study One, the complexity of the plant was such that the waste audit was done with specific reference to copper - the contaminant causing major problems with respect to sewer discharge compliance. However, before you decide to narrow your field, ensure that it is done from a basis of sound understanding of the process involved. Bear in mind, also, that experience has indicated that large amounts of waste can occur before or after the actual production process.

Step 2 Constructing a process flow diagram

Once all your unit operations are listed, prepare a process flow diagram describing the interconnections between the individual process components. Intermittent processes, such as cleaning, make-up or tank dumping, should also be included in the process flow diagram and can be identified by broken lines and labelling. Figure 1 shows an example of a simplified process flow diagram.

0 c 4 0 0 S/_."Ct ..*.,"a nr.wI*l ===%%:- II..... , m*.*... !#I."..,.".a**...... ,.*"I l...tl"l ._( ...... ,...,""a ....

"_ ...... ;:..,.'.I..,., ...... c

FIDY'. t

LI&YPLE OF PROCESS FLOW DIAOI1Y

One of the most basic and widely used principles of chemical engineering is that of material balance, i.e. the total of what goes into a system must equal the total of what comes out. The principle of material balance is used later in the waste audit (Phase Four), but it is worthwhile considering the approach at this stage. By obtaining information on inputs, outputs and losses the material balance can be written around a single item of the process equipment, a portion of a process, a complete process or an entire processing plant. It is here that your decision has to be made as to the level of detail you require. As mentioned previously, you may wish to home in on specific problem areas to begin with. It is important to realize, however, that the more general the material balance becomes the more information is likely to be masked or lost. For example, in Figure 1 there are seven unit processes. It would be possible to define the inputs and outputs to each unit process, but if time is limited or you consider that the storage tanks are not of specific concem then effort could be concentrated on the major unit processes, i.e. surface treatment (A), rinsing (B), and painting (C). However, if the surface preparation and painting operations were grouped together then in- __ formation on the loss of water and surface treatment chemicals between the surface treatment stage and the rinse stage could be lost. Measurement of the volume of water and the quantity of the surface ' treatment chemical that is carried over to the rinsing stage could identify ' significant raw material losses with subsequent reduction in rinsing efficiency and contamination of the discharge to the sewer. The level of detail and homing in on important areas is therefore very important at an early stage. Wastes of concern that should be audited first are those which are: costly to dispose of generated from expensive raw materials causing processing, handling or discharge problems considered to be hazardous or regulated under govemment legislation

inputs need to be quantified. Step 3 deals with raw materials, chemicals and power, Step 4 with identification of raw material losses, Step 5 with water usage and Step 6 with current levels of waste reuse.

$ID”.. 1

EIAYPLE OF PROCESS fLOW DllDllY

Step 3 Determining resource usage

Now that all the unit processes are designated and the interconnections are established, begin to account for material flows to each process at the detail you have decided to use. Process inputs should include raw materials, chemicals, process water, steam, and power (to be used for cost/ benefit analysis). This study usually begins by examining {he company purchasing records of raw materials used annually in the plant. Assign quantities of raw materials used in each unit process. If accurate information about raw material consumption rates for individual unit processes cannot he obtained from purchasing records, then measurements will have to be made. This should be done over a sufficient period of time to smooth out fluctuations and then be extrapolated for a monthly or annual figure. Attention to detail and thoroughness is essential at the beginning of the audit to accurately assess waste reduction opportunities. Process input data should be recorded on your flow diagram or in a table like Table 2. 1-2 Lrrl nfnr~b

Raw Matenal I Raw Malcnal2 Raw Matcnal3 Raw Matenal4 Unit Roccsr (m'lyr) (tanneslyr) (tonncslyr) (tonneslyr)

Surface water Metal Mums Surface Treatment - Treatment (A) Chemical

~ Rmsc (8) wa1cr Metal Mucis .

Painting (0 Water MetalMucts . Painr

Taal Raw Malerial Used in All Unit Roccrres

Informal discussions between the waste audit supervisor and the plant operators can yield useful information about what has gone on in the past, what goes on in the present, and why certain things are being done in the plant. Furthermore, the waste audit supervisor should be familiarizing himself with the various unit processes and should be questioning and developing ideas for improvements.

Step 4 Investlgatlng raw material storage and handling losses

Often, significant quantities of raw materials are lost during storage or material handling. These losses can be quantified as the difference between the total amount of purchased material and the total used in production. You can identify these losses by developing a table like Table 3.

1- W Ilbrfllslaraga md hudlly IeSns

Quanlity of Quantity of Raw Raw Mntcnal Matcnal Used Average Estimated Raw PvrthrJsd In Fmduction Typ of Length Annual Raw Matenal (per mum) (pr mum) Storage' of Storage Matmal Losses

Raw Malmal I IKl kg 95 kg warehouse I month 5 kg (surface mUll.2llt ckmlcd) I Raw Matennl 2

'For example. opn vs. closed

__ Make notes regarding raw material storage and material handling practices. Consider such things as evaporation losses, spills, leaks from under- ' ground storage tanks, vapour losses through storage tank pressure relief ~ 1 vents and contamination of raw materials. Find out reasons for on-site ' spillage. Purchasing practices should be re-evaluated if high raw material 1 inventories result in spoilage. Step 5 Recording water usage

Large quantities of water are frequently used in production for cooling, gas scrubbing, clean-ups, product washing and rinsing. Record your water usages on the process flow diagram or in Table Water which is not 4. ~~ directly used in the processing operations and which is not contaminated during processing can sometimes be left out of the waste audits, although excess water use and the effect on sewer surcharges should be considered. Similarly you may wish to consider steam only when it is used in a direct ____ (contact with fluid) fashion.

Process Cleanmg Stcam Cwling Other W.tm use Used Reused Used Reused Used Reused Used Reused Used Reused

Unit Rocesr A

Unit Rocess B

Unit Roccss C

Ulcd: @anlily of water used in unit pmcess Reused Quantify of water Rcirculatcd All mw.um"ts in standard units. c.g. m'lannum

Reduction and tighter control of water use can reduce the volume of waste requiring treatment and result in overall cost savings. Attention to housekeeping practices can often reduce water usage and the amount of waste requinng treatment. The cost of storing clean-up waters for later reuse may be far less than the cost for their treatment and disposal. Counter- current rinsing and rinsewater reuse will be highlighted in case studies one and two in Chapter 3. Water usage can be estimated through properly calibrated metering or measurement at the point of use, as necessary. Identify the number of times per day clean-up is undertaken and evaluate the appropriateness of reducing these practices. What controls are placed on indiscriminate water use? Using less water can have even greater cost savings than the actual cost of water. By reducing the amount of water used, through devices like flow restriction valves, waste treatment systems can operate more effectively and be sized smaller. If your wastewaters are metered and your costs based on the quantity of effluent, then these costs are also reduced.

Step 6 Measuring current levels of waste reuse

Some wastes lend themselves to direct reuse in production. Other wastes may require some level of treatment or modification for reuse as a raw material. In addition, some wastes can be recycled through waste exchanges (see Chapter 4), and may even generate profits or offset costs if

sold to another industry. These reused waste streams should be quantified. I'@ Estimate the annual quantity of waste reused as a production raw material and record the quantities on your process flow diagram or in Table 5.

Site and SIUand Quantity of Quantity of Unit Waste Waste Reuw Waste Waste Reuse Process Type (m'lannum) Type (m'lannum)

Surface Surface Surface Treatment Treatment (A) Treat" Chamkr Chemical 12 WO mYyr

Unit Rocess El (CtC.)

Unit Rocess C tetc.)

c.g. Waste Type X could be contaminated Msewater used as m&e-up in Unit Roccss A

The reuse of waste can be facilitated by waste segregation. Mixing waste streams often compounds treatment problems, sometimes rendering generally non-hazardous waste as hazardous, i.e. by combining a non- hazardous waste stream with a hazardous waste stream you can generate a hazardous waste stream of greater volume. Review your waste collection and storage approaches to determine if waste segregation is possible. It could be useful to overall plant production.

outputs from the unit processes need to be quantified. Step 7 deals with the overall output picture, Steps 8 and 9 specify the wastewater jlows and wasies hauled off- site.

FNur. * CXAYPLE OF mOCESS FLOW DllQllY

I" Step 7: auantlfying process outputs

The previous steps should document all process inputs as either resources (including power) or reused wastes. Now it is necessary to identify and quantify the outputs as primary products, co-products, waste to be reused ~ and waste to be disposed of. The end product output quantities can probably be determined from company records but should also be measured. In the case of intermediary products measurements, samples and analyses will have to be made. Be sure to identify the units of measurement. Record ______your process outputs in your process flow diagram or in a table like Table 6. Steps 8 and 9 will assist you in assembling the output information.

Unit messB ~

Unit mesr~j

~ ~~ ~ ~~

Nme: Examples arc included in Chapter 3

Step 8 Accounting for wastewater flows and concentrations

~ If your plant is like many others, then significant quantities of both clean and contaminated water are discharged to the sewer. This costly practice has the potential for undesirable environmental effects, and could result in possible liability to your company. For these reasons, Step 8 is very important to the waste audit and to your company's operation. In Step 8 you should account for all wastewater flows. In addition to the wastewater flows, the concentration of contaminants of concern in the wastewater should be measured to determine the fate of chemicals, metals,

~ etc., and to facilitate the constructing of the material balance. If you do not have in-house analytical facilities, then reputable contract laboratories should be contacted for this purpose. Plan your sampling program thoroughly and try to take samples over a range of plant operating conditions, e.g. full production, start-up, shut- __ ' down and clean-up. Composite samples should be taken for continuously running wastewater streams (i.e. collection of small volume, say 100 mL, : every hour through production period, say IO hours, to give a 1000 mL composite sample). The composite sample then represents the average - wastewater conditions through that period. For batch tanks and periodic dumping a single grab sample is adequate although periodic sampling of one batch and from batch to batch can highlight operating variations. Advice on sampling techniques can be obtained from OWMC, environmental consultants or a contract laboratory. The sum of the wastewaters generated from each unit process should equal the amount metered into the plant and also the amount sewered, stored, reused, discharged to the atmosphere, and disposed of at an off-site facility. It should be noted that “double counting” can occur where wastewater is reused. This emphasizes the importance of understanding your processes and their inter-relation- ~~ ships. Record wastewater flows and concentrations of contaminants of _____ concern to you in your process diagram or in a table like Table 7.

Discharge 10

Sanitary Stormwatcr Watercourse Reuse Storage Total Waste- Sewers water Output source of Wa.wwater flaw Conc’n Flow Conc’n Flow Conc’n Flow Conc‘n Flow Conc’n Flow Conc‘n

Unit Racsr A

Unit RmssB

Unit RmssC

Flows m m’/d Cmcesrations of CmIaminants of concem m ma

Measuring wastewater flows can be relatively simple if your system is metered. However, ensure your meters are accurate and implement a regular calibration check to maintain accuracy. If your flows are not metered then measure flows manually or analyze pumping times and rates. Record these measurements over a sufficiently long period of time and update regularly. One factor that is often overlooked is the use of several discharge points. It is important to identify the location, type and size of all discharge flows. Determine where the discharge usually goes (Le. sanitary or storm sewer or direct discharge to a watercourse). For this purpose it could be very beneficial to construct a process flow sheet to relate the layout of the process drains and their interconnections. This type of evaluation has often led to startling discoveries about how much waste is inadequately managed.

Step 9 Documenting wastes stored and hauled off-site for disposal

Measure the quantity of sludge or liquid waste hauled off-site for treatment and/or disposal and record these quantities, and the concentrations of contaminants of concern, on your process flow diagram and/or in Table 8. The MOE manifest records may be useful here if the waste is defined as a “registerable industrial waste” or a “hazardous waste”. According to Regulation 309, all waste generators in Ontario are required to register with the MOE the types and quantities of liquid industrial and hazardous (solid and liquid) wastes they produce at their facilities. Each time a shipment of these wastes is hauled off-site, a manifest form must be written up according to MOE requirements. The waste generator keeps one copy of these manifests and from these it is possible to calculate the quantities of hazardous waste generated.

~ ~~~ Registerable Wasies

Non-Registerable Wastes (including classification) ~

Solid Liquid Total Solid Liquid Tomi

ware Qry Conc'n QIy Conc'n Qty Qty Conc'n Qly Conch Qty Conc'n

waste c

All quantities m tannes/annum Concentrauons of conmmants of concern in grams contmmantskg waste

When totalling these wastes, take a look at whether any hazardous and non-hazardous waste streams are combined. Review invoices for non- registerable wastes that are hauled by a commercial contractor. Again, take samples of your wastes that are hauled away and conduct analyses to ietermine the wastes' constituents.

We have now investi- gated and described what goes into the ,I This procedure is designed to identify areas where information is inaccu- production processes rate or lacking. For example, if the total input to a given process for mate- and what has come rial X is 100 kg and only 50 kg is accounted for in the process output, out of these proc- either the output or the input data are inaccurate or the output data is esses. As described incomplete. This approach is termed the material balance investigation. earlier, one of the Where data is deficient, concentrated efforts are required. Keep in mind basic laws of chemi- that it could take a long time before all raw material and waste flows are cal engineering is accounted for. The waste audit essentially never stops, and there is usually that the total of what room for improvement. Furthermore it must be emphasized that it will be goes into a system almost impossible to derive a perfect mass balance-a balance to within must equl the total 10 percent (e.g. Inputs/Outputs x 100 = 90 - 110%) would be deemed of what comes out. very satisfactory in most industrial circumstances. Therefore, the next stage is to compare Step 10 Assembling unit pmcess input and output information the inputs to your i ~ production process Begin the material balance by developing standard units of measurement with the outputs. (litres, tonnes or kilograms) on a per day, per year or per batch basis. This is the only practical way that a balance for the whole plant, or a unit process, can be carried out. Summarize the measured values in standard units in schematic form by utilizing your process flow diagram (Figure 1). Note: modifications might be needed to Figure 1 following your work in the plant. The inputs and outputs can also be listed in tabular form as in Table 9.

I Inputs (amounts. per annum)

: 'Amounts in slsndnrd units.

Step 11: Deriving a preliminary material balance for unit processes

Now it is possible to complete a preliminary material balance. For each , unit process utilize the data developed in Steps 1 through 9 and construct ' your material balance. Use the process flow diagram to construct a graphi-

I cal material balance. You might also find it useful to tabulate your input and output information as in Figure 2.

Inputs (tonnes)

Raw matarial A Raw material B Rawmatarialc Waste rem v Unit Process A 1

Manufactured product Raw productlocms Reused wmta Sewered wmta Solid wmta Liquid wmta Hazardous W&

c Step 12 Evaluating the material imbalance

Whether you have a material imbalance or not, the individual and sum totals making up the material balance should be reviewed to determine information gaps or inaccuracies. If you do have a significant material imbalance then further investigation is needed. For example, if outputs are less than inputs, then look for obvious sources of loss or waste discharges

(e.g. evaporation). ~ It is also possible for outputs to apparently be greater than inputs if _____ large measurement or estimating errors are made or some inputs are not accounted for. You should now take the time to examine where unnoticed losses may be occurring, even if the equation appears to balance. It might be necessary to repeat some of your information gathering activities. Remember that you need to be thorough and consistent in order to obtain a satisfactory material balance. The material balance not only reflects the adequacy of your data collection activities, but by its very nature ensures that you have a sound understanding of the processes involved.

Step 13 Refining the material balance

Now you can reconsider the material balance equation by adding previously unaccounted for losses into the output side and any adjustments to the total inputs, and run through another material balance. If necessary, estimates of unaccounted for losses will have to be calculated. Remember, ideally the inputs should equal the outputs. In practice, however, this will rarely be the case and some judgement will be required to determine what accuracy is acceptable. In the case of high strength and hazardous wastes accurate measurements should be obtained for the waste reduction studies. The material balance approach should be performed at the level of detail you decided to conduct the study. You may need to repeat the material balance for a number of the unit processes identified in Steps 1 to 9 as well as an entire production area. Again, continually review, refine and, where necessary, expand your database. The compilation of accurate, comprehensive data is essential to your successful waste audit and subsequent waste reduction.

Phases I ro 4 have been involved with developing the n'aste Step 14 Examining obvious waste reduction measures .- audit for your planr. Phase 5 now looks at Now that your waste audit has been essentially completed, it is time to

using rhe informarion look into implementing waste reduction measures which probably became ~ obrained 10 identrh obvious during the studies. You should adopt and maintain a definite wasre reduction waste prevention program by developing a code of good operating prac- alternatives. tice. For example: Plug leaks and fit flow restrictors to try to reduce water consumption. Implement a thorough and satisfactory maintenance program to prevent leaks. Install level controls to prevent overflows. Attempt to reuse washwaters and rinsewaters. Install adequate storage capacity to prevent overflows. Install tanks to hold wastewaters for reuse. Install tanks that are, or can be, pitched and elevated from the floor and that have well rounded comers for ease of drainage and rinsing. Determine whether or not your wastes can be separated “clean” from “dirty” or “aqueous” from “organic”. If this is done, then concentrate on material recovery from the “dirty” wastewater.

9 Find out if hazardous wastes can be segregated from non-hazardous wastes and implement segregation where possible. Find out if solid wastes can be segregated from aqueous waste streams and implement segregation where possible. Consider reusing scraps of material. Study your plant processes and review the potential for low waste technologies. List your wastes in the Canadian Waste Materials Exchange Bulletin. Other plants might be able to recycle your wastes in their processes.

Step 15 Targeting and characterizing problem waste streams

Having gone through Steps 1 to 14, you should have identified and characterized all your wastes and have begun to consider them for waste reduction, reuse, recycling and recovery (the 4 Rs). Obvious waste reduction measures were identified in Step 14. However, you may find it necessary to focus attention on the “problem” waste streams that are:

costly to dispose of generated from expensive raw materials causing treatment problems classified as hazardous under government regulations

Wastes which are of particular concern should be characterized fully in order to know how best to use or dispose of them. This may necessitate additional sampling and analysis of your “problem” wastes. An example< of a “problem” waste is described in Case Study One. In this instance, the presence of chelating agents in a copper containing wastewater prevented copper removal by conventional metal hydroxide precipitation. At this stage, you should conduct some treatability studies to determine optimum treatment requirements or examine the present treatment method to determine its efficiencies. Waste streams should be tested individually and as a group to determine if waste segregation is required. Treatability testing should yield information on optimum chemicals required, optimum dosages, sludge production and feasibility of resource recovery. Water treatment chemical suppliers or environmental consultants can do treatability testing for you and equipment suppliers can run laboratory and pilot tests to determine efficiencies for treatment and recovery. In order to determine what options are available you should make use of the resources and information described in Chapter 4.

Step 16 Developing long term waste reduction alternatives

Longer term waste reduction altematives will require the evaluation of ~ potential process/production changes, waste recovery and reuse, and ~ treatment technologies. Potential process/production changes which may increase production efficiency and reduce waste generation include:

continuous versus batch production process retention times, temperatures, agitation, pressure, catalyst;, etc. use of dispersants in place of organic solvents where appropriate reduction in the quantity or type of raw materials used in production raw material substitution through use of wastes as raw materials and the use of different raw materials associated with less waste generation.

Waste reuse can often be implemented if materials of sufficient purity can be concentrated or purified. Technologies such as reverse osmosis, ul- trafiltration, electrodialysis, distillation, electrolysis and ion exchange may enable materials to be reused and reduce or eliminate the need for waste treatment. Where waste treatment is necessary, a variety of technologies should also be considered. These include physical, chemical and biological treatment processes. In some cases the treatment method can also recover valuable materials for reuse. Chapter 4 describes how you can get further technical information relating to recovery, reuse, waste treatment and associated technologies. Once the potential opportunities for waste recovery and reuse have been identified, the smaller company may wish to bring in a reputable environmental consultant with the technical expertise to evaluate the various technologies. Step 17: Doing a cost/benefit analysis for waste treatmentheduction

From Step 16, a number of waste treatment/recovery altematives have been identified which may have widely differing effects on your processing plant. Long term waste treatmentheuse altematives may include:

process related changes (e.g. acid recovery for steel pickling) technology for treating and recycling specific waste streams (e.g. ion exchange or electrolytic metal recovery) implementation of technology for end-of-pipe treatment (e.g. biological treatment of combined chemical wastewaters)

Although these cases represent different circumstances, the general procedure for conducting the costbenefit analysis is the same and involves a current waste treatment cost analysis, projected alternative waste treatment cost analysis and finally a costbenefit comparison. The approach described below is, of necessity, fairly simplistic as different companies have different methods of conducting their cost evaluations. a)Present waste treatment cost analysis The annual operating costs for the existing treatment system can be evaluated as in Table 10.

hm Annual Cost 0)

Raw material A (e.& lime) Raw material B (c.g. polymer) Sewer (surcharge and fees) Electricity Off-rite disposal water Labour Maintenance Adminislrative cos1 (e.& SUpeNisiOn. regulatory response)

Twl Annual Wauc Tmatmcnt Cost*

*For tix imam" ofa specific waste stream (from Racers AI. the bottom ltn~uauld relate to the tuml annual waste ueslment cost for Rocor A. whcrca\ for an cnd-of-pipe ItealmCnl 81 would relaic IO all process uaw mmnunt costs If there are any monetary benefits from your waste treatment (e.g. reused or recycled materials), then these should be subtracted from the total waste treatment cost.

Tad Annual Net Cost Tolal Sum of Operating Total Waste ~ Of Cvmnt Waste - And Maintenance Waste - Treatment Tmatmcnt Roccrr Treatment Costs Benefits

b) Determination of cost (and benefits) of each alternative waste treatment technology The operating costs of each waste treatment altemative is then determined using a table like Table 11 below.

1- 11: Lupl opmlhgand malntmunw wsts for an a~lrsheabnsnt hchnolopv

Item Annual Cost (16)

Raw matenal A used m altm"e waste treatment Raw mtenal B used m ahematwe waste ireatment Scwer discharge UCemCltY Off-nte Water EMIS labcur Msrnicnance

Toul Annvsl Openung costs of Altcmativc Treatmcnt Technology

, Information for the costing study can be obtained from the equipment 1 suppliers and possibly from reference material (see Chapter 4).

~ If there are any monetary benefits from the altemative waste treatment ' processes these are also subtracted from the total operating cost as below:

1 Net Tom1 Annul opcmting Total Annual Operating Annual Waste i CM~of Altemslive Wasu- = Cast of Allemalive - Treatment

~ Water Treanncht Technology Waste Treatment Manelary Benefit i I i c) Costlbeneft comparison of current and alternative treatment 1 technologies In cases where the total annual operating cost of an altemative treatment technology is lower than the total annual operating cost of the current I waste treatment, a study should be undertaken to determine whether this 1 net benefit is sufficient to pay for the cost of purchasing and installing the altemative treatment technology. Each company has its own method of , conducting this evaluation. Discounted cash flow analysis is one com- monly used method. The costhnefit approach used in the above items to evaluate alternative treatment technologies is based solely on economics. While the economic factor is generally the main motivation for companies to adopt waste reduction alternatives, there are cases in which other factors can override short-term economic costs associated with waste reduction. For example, infringements of environmental or occupational health regulations could result in heavy fines or even in a court injunction to shut down the pollut- ing company. Sometimes the benefits are intangible, such as creating a cleaner, healthier workplace with increased employee morale and reduced absenteeism. The public relations value of implementing waste reduction measures likewise should not be overlooked. It could also turn out that the alternative waste reduction technology will simultaneously improve the quality of the final product and result in increased sales. The fact that such intangible benefits are difficult to quantify from a monetary point of view does not diminish their contribution to the overall success of your operation. The case studies in Chapter 3 give different examples of cost/benefit analyses.

Step 18 implementing your action plan: reducing wastes and increasing production efficiency

You have now completed the important first step in the waste audit/waste reduction study and have amassed a wealth of information and no doubt increased your knowledge of the plant. It is now time to review what has been done and to develop an action plan for the future. To get ready, answer the following questions:

Did the exercise highlight areas of inefficiency and enable you to improve production efficiency and waste management approaches and costs? Quantify your successes.

Is outside expertise or additional manpower required to complete the audit or undertake further work? If so, consult Chapter 4 or enquire about reputable consulting services.

Are the costs of implementation too high? If so, consult the sources of public funding discussed in Chapter 4. Can implementation be done in stages?

Have you highlighted significant information gaps or inconsistencies? If so, concentrate on these areas and explore ways and means of developing these additional data. Is outside expertise required? Again, see Chapter 4.

I" Discuss your approach and solicit ideas from other staff. Utilize in-house expertise first.

Attempt to develop a specific waste audit/waste reduction approach for your plant. Discuss this approach with similar industry people who may have undertaken a plant waste assessment or are about to do so.

Consider all possible resources. If you are looking for further information, call the Waste Reduction Program at the Ontario Waste Management ~ Corporation (416) 923-2918 or 1-800-268-1179(toll free). ~ APPENDIX B

SRS REPORTING FORMS

R-WM-349: Rev. 5/93 COMMONWEALTH OF PENNSYLVANIA ,structions DEPARTMENT OF ENVIRONMENTAL RESOURCES BUREAU OF WASTE MANAGEMENT FORM 25R SOURCE REDUCTION STRATEGY

'his form provides guidance on the content and format of the written source reduction strategy (SRS). Supplemental . ~~~ iuidance on the comprehensive process of analyzing the processes by which waste is generated and developing and valuating source reduction options is available from the Department in a separate document, the "Source :eduction Strategy Manual". The written SRS is intended to summarize the results of a comprehensive internal lrocess of source reduction assessments and decisions. Generally, a separate SRS should be prepared for each type of .~~~~

esidual waste generated. The strategy may be prepared on this form or prepared on separate paper using this ~ ormat.

ource reduction is the reduction or elimination of the quantity or toxicity of waste before it is generated. Source eduction may be achieved through changes within the production process, including process modifications, eedstock substitutions, improvements in feedstock purity, shipping and packing modifications, housekeeping and ianagement practices, increases in the efficiency of machinery, and recycling within a process. Please note that wrce reduction does not include dewatering, compaction, waste reclamation, or the use or reuse of waste. These ctivities. although they can result in environmental benefit, are of lower priority in the waste management ierarchy and should not be included in the SRS. These processing, use, and reclamation activities are encouraged irough the permit-by-rule and beneficial use provisions of the residual waste regulations and through permit by Jle provisions of the hazardous waste regulations.

lazardous Waste Requirements

eople who generate a total of less than 1,000 kilograms of hazardous waste in each month are exempt from the SRS ?quirements.

here is no exemption in the hazardous waste regulations for individual waste streams generated in small quantities

he hazardous waste SRS must be completed by January 17, 1994

esidual Waste Requirements

mall quantity generators, who generated less than 2,200 pounds of all residual waste in each month of the previous 2ar. are not required to prepare an SRS.

he Department is hereby waiving for a period of two years the SRS requirement for individual residual waste types iat are generated in quantities of less than 2,200 pounds per month per generating location. This will enable enerators to concentrate first on larger waste streams where greater environmental and economic benefits can be ttained through successful source reduction. This waiver will be reconsidered two years from the effective date of le residual waste regulations.

final residual waste SRS must be completed by July 4, 1993

he hazardous and residual SRS must be available on-site for inspection and must be submitted: with a Form U or Module 1 (for the disposal ar processing of waste at a permitted site) with a permit application upon request by the department

egulatory References:

'azardous Waste Regulations 260.2 (definition of "source reduction") 262.80 (source reduction strategy) 264.13(a)(7) (General Requirements) Residual Waste Regulations 5287.53 (duties of generators: source reduction strategy) 5276.1 (definition of "source reduction") §287.52(b)(6) (biennial reports) 5287.133 (waste analysis: source reduction strategy)

Municipal Waste Regulations 5271.1 (definition of "source reduction") 5271.612 (Additional Application Requirements)

SRS Ootions:

1. If you have established a source reduction program and know what action you will take to reduce this waste stream then the general information and Part A should be completed.

2. If you are proposing to do nothing to reduce the quantity or toxicity of waste, then the general information and Part B should be completed.

3. for residual waste only, if you have established a program but are still evaluating what you will do, you should complete the general information plus the applicable sections of both parts A and B. You should present the ongoing source reduction evaluations which will lead to a completed strategy. This third option may only be used for one year following the effective date of the regulations. A final residual waste strategy, as described in options 1 or 2. must be completed by July 4, 1993. iR-WM-349: Rev. 5/93 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES Generator's I.D. Number BUREAU OF WASTE MANAGEMENT FORM 25R SOURCE REDUCTION STRATEGY

General Information The information contained in this This part must be completed. form is true and correct to the best Senerator: of my knowledge and belief. Contact Person: 'hone Number: Wailing Address: Name of Responsible Official

Title

:acility Address: Signature of Responsible Official

if different from nailing address) Date

Waste stream name and description: 0 Residual waste 0 Hazardous Waste

Describe source reduction actions taken during the past five years. You should quantify any reduction in the weight or toxicity of waste and maintain records to document this reduction. This question is intended to give recognition for past source reduction achievements.

State whether you have established a source reduction program. You may include a statement of top - management's support or corporate source reduction goals.

Page 1 of 4 ER-WM-349: Rev. 5193 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES Generator’s 1.0. Number BUREAU OF WASTE MANAGEMENT

FORM 25R Part A

Complete this part if you have established a source reduction program and are proposing to take action to reduce the quantity or toxicity of this waste.

1. Describe the methods and procedures that you will use to achieve source reduction for this waste

2. Quantify the projected reduction by weight or toxicity for each technique described in #l.You may use the method of measurement most appropriate for the waste and the generating process. Discussion of several measurement options is contained in the ”Source Reduction Strategy Manual”.

3 Specify when each method or procedure describe in #l will be implemented.

Summary of Part A

method or procedure expected reduction implementation date

Page 2 of 4 ER-WM-349: Rev. 5/93 COMMONWEALTH~~ OF PENNSYLVANIA Date Prepared DEPARTMENT OF ENVIRONMENTAL RESOURCES Generator's I.D. Number I BUREAU OF WASTE MANAGEMENT I FORM 25R I 'art B omplete this section only if you have not established a source reduction program for this waste stream, that is, if you re not proposing to takeany action to reduce-the quantity.or toxicity of the waste.

Characterize the waste stream, including source, hazards, properties, generation rate, and current management techniques and costs. Attach chemical analyses or other documentation as needed to fully describe the identity and source of waste.

Describe all the potential source reduction options that you considered.

Describe in detail how each option was evaluated. Include the specific technical, economic, or other criteria that were used.

Page 3 Of 4 ER-WM-349: Rev. 5/93 COMMONWEALTH OF PENNSYLVANIA Date Prepared DEPARTMENT OF ENVIRONMENTAL RESOURCES Generator's 1.0. No. I I BUREAU OF WASTE MANAGEMENT FORM 25R r--l

4. Explain why each option was not selected

Summary of Part B

method or procedure considered whv not selected

Page 4 of 4 APPENDIX C

THE REGULATIONS

TITqE 25. ENVIRONIIENTAL RESOURCES PART I. DEPARmENT OF ENVIRONMEWTAL RESOURCES Subpart C. PROTECTION OF NATURAL RESOURCES ARTICLE 011 RAZARDOUS WASTE NANAGENEWT CHAPTER 260 - DEFINITIONS AND REQUESTS FOR DET~IMATION 5260.2. DOfinitiOnS. (a) Definitions. The following words and terms when used in this

article.~ have the following meanings, unless the context clearly indicated otherwise. *****

Source reduction -- The reduction or elimination of the quantity or toxicity of hazardous waste generated. Source reduction may be achieved through changes within the production process, including process modifications, feedstock substitutions, improvements in feedstock purity, shipping and packing modifications, housekeeping and management practices, increases in the efficiency of machinery, and recycling within a process. The term does not include dewatering, compaction, reclamation, treatment, or the use or reuse of waste. _.

***** SUBCHAPTER H: SOURCS REDUCTIOli STRATEGY S262.80. Sourco Roduction Stratogy.

(a) By Januar 17,'f%h. Note: one year after the effective date of this regulat+ on) a person or municipality that generates hazardous waste shall prepare a source reduction strategy in accordance with this section. Except as otherwise provided in this Article, the strategy shall be signed by the person or municipality that generated the waste, shall be maintained on the premises where the waste is generated, shall be available on the premises for inspection by any representative of the Department and shall be submitted to the Department upGn request. The strategy ‘may designate certain production processes as confidential and such confidential information may not be made public without the expressed written consent of the generator. Unauthorized disclosure is subject to appropriate penalties as provided by law. (b) For each type of waste generated, the strategy shall include:

(1) A description of the source reduction activities conducted by ~ the person or municipality in the five years prior to the date that the __ strategy is required to be prepared. The description shall quantify any reductions in the weight or toxicity of waste generated on the premises.

(2) A statement of whether the person or municipality has established a source reduction program.

(3) If the person or municipality has established a source reduction program as described in paragraph (2), the strategy shall identify the methods and procedures that the person or municipality will implement to achieve a reduction in the weight or toxicity of waste generated on the premises, shall quantify the projected reduction in weight or toxicity of waste to be achieved by each method or procedure, and shall specify when each method or procedure will be implemented.

(4) If the person or municipality has not established a source reduction program as described in paragraph (2), the strategy shall include the following: (i) A waste stream characterization, including source, hazards, chemical analyses, properties, generation rate, management techniques and management costs. (ii) A description of potential source reduction options. (iii) A description of how the options were evaluated. (iv) An explanation of why each option was not selected. (c) The strategy required by this section shall be updated when any of the following occur:

(1) There is a significant change in a type of waste generated on the premises or in the manufacturing process, other than a change described in the strategy as a source reduction method. (2) Every five years, unless the Department establishes, in Writing, a different period for the person or municipality that generated the waste. __

(d) If hazardous waste generated by a person or ncnicipality will be treated, stored or disposed of at a solid waste management facility which has applied to the Department for approval to treat, store, or ~ dispose of such waste, the person or municipality that generated such hazardous waste shall submit the source reduction strategy required by this section to the facility upon the request of the facility. (e) This section does not apply to persons or municipalities that senerate a total of less than 1,000 kilograms of hazardous waste in each month of the year. (f) A person or municipality that generates hazardous waste may reference existing documents it has prepared to meet other waste minimization requirements to comply with this section, including those proposed to comply with 40 CFR 261.41(a)(5), (6) and (7) (relating to biennial report).

****. S264.13. Qanaral raquirements for hazardous vaate management approval8 and analysis. (a) Except as provided in (e) and ( (f), before an owner or operator treats, stores or disposes of a specific hazardous waste from a specific generator for the first time, the operator shall submit to the Department for approval, on a form provided by the Department, a report which the owner or operator shall retain for 20 years. The include the following information: report shall *****

7. A copy of the generator's source reduction strategy: *****

3-25-92

Subpart D. ENVIR0NMEN"AL EEALTE AND SAFETY ARTICLE VIII. MUNICIPAL WABI'B CHAPTER 271. MUNICIPAL WAgFB MANAGEMENT-GENEEAL PROVISIONS Subchapter& GENERAL

S27l.l. Definltioona

The following words and terms, when wed In this article, have the following meanings, unless the context clearly Indicates otherwise:

**+**

Source reduction-- The reduction or elimination of the quantity or toxicity of residual waste generated. Source reduction may be achieved through changes within the production process, including process modifications, feeclatak substitutions, improvements in Ceedatock purity, shipping and packing modiflcatlona, housekeeping and management practices, increases In the efficiency of machinery and recycling within a process. The term does not include dewatering, compaction, reclamation, or the we or reuse of waste. *+***

S271.612. .Souroe reduction strategy.

An application for the processing or disposal of residual waste shall contain a copy of the source reduction strategy required by Section 287.53, for each residual waste to be disposed of or processed at the facility.

3-25-92 . ARTICLE IX

CHAPTER 287. RESIDUAL WASl'E MANAGEMENT- GENERAL PROVISIONS Subchapter A. GENERAL

&C.

287.1. Definition& 287.1. Scope. 287.3. Environmental protection. 287.4. Computerized data submission. 287.5. Public recorda and confidential Information. 287.6. Conslgnment or other transfer of waste. 287.7. Determination that a material is no longer a waste. I s 287.1. Definitions. The following words and terms, when used In this article, have the following meanings, unless the context clearly indicate otherwise:

Source re&ction-The reduction or elimination of the quantity or toxicity of residual waste generated source reduction may be achieved through changes within the production process, including procem modifications, feedstock substltutlona, improvements In feedstock purity, shipping and packing modifications, housekeeping and management practices, incremes in the efficiency of machinery and recycling within a process. The term does not include dewatering, compaction, waste reclamation, or the use or reuse of waste.

SUBCHAPTER R DUTIES OF CENERATOBS S287.51. Scope. This subchapter contains requirements that are directly applicable to persons or municipalities that generate more than 2,200 pounds of residual waste per generating location in any single month of the previous year. The Department may waive or modify the requirements of this section for individual types of waste that are generated in quantities of less than 2,200 pounds per month per generating location. s 287.52. Biennlal report (a) By (Editor's note: The blank refers to a date 6 months after the effective date of these regulations), and by March 1 of each odd numbered year thereafter, a person or municipality subject to this subchapter shell file a report with the Department. (b) The report, which shall be submitted on a form prepared by the Department, shall include the following:

+.+..

(6) A description of the generator's efforts to implement its source reduction strategy under S287.53 (relating to source reduction strategy) and, to the

.extent such information Is available for yem before 1991, a description of changes in ____ the weight or toxicity of waste achieved during the year compared to previous yean.

.++*+

S t87.53. Source reductloll strategy.

(a) A person or municipality subject to this subchapter shall prepare a source reduction strategy in accordance with this section. Except as otherwise provided in this Article, the strategy shall be maintained on the premises where the waste is generated, shall be available on the premises for inspection by any representative of the Department and shall be submitted to the Department upon request.

(b) For each type of waste generated, the strategy shall include:

(1) A description of the source reduction activities conducted by the person or municipality in the five years prior to the date that the strategy Is required to be prepared. The description shall quantify MYreductions in the weight or toxicity of waste generated on the premises. The first strategy prepared by a person or municipality under this section shall describe source reduction activities conducted by the person or municipality in the five years prior to the effective date of these . regulations, if the generator has sufficient recorda to accurately document these activities. (2) A statement of whether the person or municipality has established a source reduction program. (3) If the person or municipality has established a source reduction program as described in paragraph (21, the strategy shall identify the methods and procedures that the penon or municipality will implement to achieve a reduction in the weight or toxicity of waste generated on the premises, shall quantify the projected reduction in weight or toxicity of waste to be achieved by each method or procedure, and shall specify when each method or procedure will be Implemented. (I) If the person or municipality has not established a source reduction program M described in paragraph (2), the strategy shall include the following:

(i) A waste stream characterization, including source, hazards, chemical analyses, properties, generation rate, management techniques and management costs. ~

(ii) A description of potential source reduction options. (111) A description of how the options were evaluated. (iv) An explanation of why each option was not selected. (E) The strategy required by this section shall be updated when any of the .following occur: (1) There Is a significant change in a type of waste generated on the premises or in the manufacturing process, other than a change described in the strategy as a oource reduction method. (2) Every five yean, unless the Department establishes, in writing, a different period for the person or municipality that generated the waste.

(a] If residual wmte generated by a person or municipality wW be processed or disposed of at a solid waste management facility which has applied to the Department for approval to process or dfspooe of such waste, the person or municipality that generated such residual waste shall submit the source reductlon strategy required by this section to the facility upon the request of the facility. If residual waste generated by a person or municipality is processed or disposed of at a solid waste management facility which has received written approval from the Department to process or dispose of such waste, the person or municipality shall submit the source reduction strategy required by this section to the facility whenever the Department requires the person or municipality to update the strategy. (e) The strategy shall be signed by a responsible official for the person or municipality that generated the waste. If the person or municipality Is a corporation or partnership, the report shall be signed by an officer of the corporation or a partner in the putnershlp, whichever is applicable. (0 The Department may in writing waive or modify the requirements of thh section for research and development activities. .*... . WASPE ANALYSIS s 287.131. Scope. (a) Sections 287.131434 apply to residual waste management facilities that apply to receive residual waste for processing or disposal. Sections 287.132-.134 do not apply to:

(1) Transfer facilities, except as otherwise required in writing by the ~

Department. ~

(2) The disposal at permitted Clasa I or Class Il residual waste landfllla of residual waste from a person or municipality that generates a total quantity of 2,200 pounds or less of residual waste per generating location in each month, if the applicant demonstrates to the Department's satisfaction that the waste & not hazardous.

(3) The disposal at permitted Class I or Class Il residual waste landfib of an individual type of residual waste from a person or municipality that generates a total of 2,200 pounds or less of that type of residual waste per generating location in each month, if approved by the Department In writing.

(b) The requhments of these SeCtiOM are in addition to the application and operating requirements in this article...... s 287.133. Source reduction strategy. An application for the processing or disposal of residual waste shall contain a copy of the source reduction strategy required by Section 287.53, for each residual waste to be disposed of or processed at the facility. APPENDIX D

ADDITIONAL SOURCES OF INFORMATION

REFERENCES

Available from DER'S Source Reduction Section (717-787-7382):

1992 Governor's Waste Minimization Awards. (Describes industrial,

municipal, and market development efforts demonstrating a range of ~ technical and management innovations to achieve waste minimization.) Listing Catalog: Northeast Industrial Waste Exchange, Inc. published quarterly. (Lists wastes which are wanted or available for exchange.) The Department also maintains technical references on the reduction of some common waste streams from selected industrial sectors.

Available from EPA's hotline (1-800-424-9346): The EPA Manual for Waste Minimization Opportunity Assessments. USEPA, EPA/600/2-88-025, April 1988. (This manual is a source of concepts and ideas for developing and implementing a waste minimization program. A set of worksheets useful in carrying out assessments is included.) Facility Pollution Prevention Guide. USEPA, EPA/600/R-92/088, May 1992. (Contains information on developing, implementing, and maintaining a multi-media pollution prevention program. Included are chapters on measuring progress and conducting an economic analysis.) Waste Minimization: Environmental Quality with Economic Benefits. USEPA, EPA/530-SW-90-044, April 1990. (Booklet provides a general introduction to waste minimization and its benefits.)

Other references: Hazardous Waste Minimization Handbook. Thomas E. Higgins, Lewis Publishers, 1989. (Includes chapters on machining, solvent degreasing, metal plating, painting, and paint removal.) Industrial Waste Audit and Reduction Manual. Ontario Waste Management Corporation, 1987. (Includes the auditing approach reproduced in Appendix A plus case studies for printed circuit board manufacturing, steel pickling, and detergent manufacturing.)

Center for Hazardous Materials Research University of Pinsburgh Applied Research Center 320 William Pm Way . Pmsburgh. PA 1523.9 Fax (41 2) 826-5552 (412) 826-5320 _- - SOURCES FOR POLLUTION PREVENTION lNFORMA77ON

This document provides a lisling and description Os numerous sources of infomalion for pollution prevention and waste reduction technical and financial assistance. These indude: Center for Hazardous Materials Research (CHMR), Useful Mailing Lists, Eauioment Buyers' Quides. Hazardous Waste Recovery, Treatment, & Disposal Fadties. Federal 8 Slate Contacts for Financial Assistance, Important Telephone 6 Hotline Numbers 1. CENIER FOR HAZARDOUS MATERIAIS RESEARCH (CHMR) CHMR is a non-proltl subsidiary of the Univenny of Pittsburgh TNSI and is a non-regulatory organization. its mission is to assist in develo Ing and implementing practical solutions to the technical. environmental. economic. and hean[ roblems associated wilh hazardous materials and waste. CHMR's Technical Assistance Program ps a one-stop source lor environmental information and assistance, including. A Hofllne Thai ProvOvMes Ansmn Answers to your environmental questions are only a phone call away wilh the nationwide. toll-free, CHMR Hazardous Materials Hotline. Informationk avallable on a wide range of regulatory and technical issues. Calls are completely confidential. Dbll4OOW-CHMR. Scmlnars and Workshops Envlronmenfal Servlar - Pollution prevention techniques Pollution prevention assessments. * Environmental regulations. Regulatwy compliamn asseasments. * Health and Safety OSHA), Facllity permitling guidance. - Right-to-Know (SAk A Title 111) Community Right-to-b. - Emeraencv resoonso. Contamination invesligalkrm. - Undergrothd sioragelanks. Risk assessments. - Pesticides Publlcaflons The Center For Hazardous Malerials Research (CHMR) offers a variely of documents which provide usetul additional informationand guidance on polution prevention and control. CHMR's quarterly newsletter -- IheMiflimizQr -- can help kee you ap rised of the latest information in the environmental field and how it may affect your business. figther pu licatlons on specific waste reduction and environmental compliance issues are also available. On-Slte Consulfaflons CHMR can also perform on-site consultation services to provide clients with a general assessment of their hazardous waste management needs and compliance requirements. as well as identification ot opportunities for minimizing waste generation.

For mom pollullon pnvenllon lnlonnaflon, co ks ol CHMR documents, orforr subscripflon fo CJ MRL uarterty newsleffer - The Mlnlmlzer - /usf call eHMR'a hofllne, 800.334CHhiR.

A Subsidiary 01 the University 01 Pinsburgh TrUSl 2 MAILING LISTS Subject-specific mailing lists are available to help businesses kee up to date with changes and information on specific regulatory and waste reduction subjects. E ome of these indude the following. Center For Hazardous Materials Research Information For Small Business' 320 William Pitt Wa Small Business Ombudsman Pinsburgh. PA 15& U.S. Environmental Protection Apffiy 412) 826-5320 401 M Street. SW (A-14%) 1-800-334-CHMR Washington. DC 20460 (800) 3865888 U.S. Environmental Protection Agency Emergency Planning 6 Conimuruty Rlght-to-Know Center tor Environmental Research Information (CERI) Docuinent Distribution Center Technology Transfer P.O. Box 12505 U.S. Environmental Protection &ncy Cindmati. OH 45212 P. 0. Box 12505 800-535-0202 Cincinnati. OH 45212 U.S. Environmental Protection A ency The 33lH) Program OHke of Underground Storage Anks EPA Ts-79211 Box-... 6DM.. . . 401 M Street SW Rockviile, MD 20850 Washington. DC 20460 202-554-1404 3. HXllPMENT BUYERS (3UIDES

Numerous equipment buyers' guides are available which provide the names Of manufacturers and vendors of equipment for waste reduction and/or recycling. Subsal lions to equipment buyers guides' are usually free. Some useful guides and subscriptions Include the Pollowing. Pdlulion ET' en1 News Water & Warlea Digest Chnnical upmOnt Rimbach P& Inc. Scranion OikUe Communicllllorn. Inc. Gordw, pawHoIu, Inc. m5o LLrd 380 Nofthweat H' hay Box 1952. PklrbWgh. PA 15237 Des Phines. IL &,e D0m.W 07801 (412) 364-5366 (312) 296-6622 (201)36t.W80 4. WASTE mcHANGES The Northeast industrial Waste Exchange (NIWE) functions as an Information clearinghouse. Established in 1981 by the Manufacturers Association of Central New York in cooperation with the Central New York Regional Plannin and Development Board, the non-prolit exchange ts co-sponsored and partially funded by the New Yo !I State Environmental Facilities Corporation, the Ohio Environmental Protection A ency, and the US. Environmental Protection Agency. NIWE's Information is widely circulated but use8 primarily in the northeastern United States. Information is distributed in two ways-a Listin s Catalog is published quarterly, and a computerized waste materials listings service Is available. Zach Februv M~J, Art.and November, a list of 'Materials Available' and 'Materials Wanted' Is printed an dist but as widely as possible, with Current circulation numberin 10,500. A ccrn an wishing to have information included in a list may do so lor $25 for threc issues. Bhe inlormation Prs a so made available on the computerized listings for the same period of time. The computerized service is provided tree of charge and Is available to anyone having access to a mlcrocom uter and modem. The servlce is designed to allow Immediate access to current Information. For more Pnformation contact: Northeast Industrial Waste Exchange 90 Presidential Plaza

Suite~~ .. 122~~ Syracuse, NY 13202 (800) 237-2481

01/30/92 2 *CHMR 1992 WPPPP4 i 5. DlRECTORlES OF COMMERCIAL HAZARDOUS WASTE RECOVERY, TREATMEW. AND DLSPOSAL FACILITIES There are several publications which provide comprehensive listings of commercial hazardous Waste recovery, treatment and disposal faciliies.

Harardacn Waste Smkes Huedous Wastes Management El Environmen(a1SerAcea Direclay Dhed Rderenm Direcloy Ewkmnmn(.l Inlamalbn. LM J J. K%r 6 Aaarosiales. IK. Rimbash Pddisli 4801 Wual81sl Stred 145 Weal Wmconain Avenue 8650 8.bsoek Bou*e wed Inc Suite119 P.0 Box368 Pbbqh.PA 16237 b.MN 55437 (412j3W-5386

For more information dl CHMR's toll-free Hazardous Materials Hotline. (800) 334-CHMR. 6. FEDERM 6 STATE CONTACTS FOR FINANCVU. ASSISTANCE Federal and state contacts for financial assistance which are potentially useful to small business owners hdude: 6.1 Yenture Ca&! Venture capital financing involves direct investment of capital in a business by a private group. The investment is generally structured to allow the group to convert tiieir equity position into cash or other liquid assets within a few ears There are private sources of venture capital. as well as capital firms Hcensed by the Small BusI. ness Administration (SBA). called the Small Business Investment Companies (SBIC). Your regional SBA office can refer you lo the SBlC in your area. Control I" The U.S. Small Business Administration (SBA) has made its new Poilutiin Control Loan (PCL) regulation effective as of December 22.1989. The new regulation s ifically provides for loan asststance to small businesses in need of capital lo comply with envp" ronmentai requirements or otherwise prevent and reduce pollution. The SBA pro ram has been specifically targeted toward small business who may also be small quantity generators (8QQs) and in one manner or another subject to Federal, State or local regulatory requirements. Under Ws new ro ram, the SBA can and will uarantee loans to affected small buslnesses providing that they meet JB8s credit and cotlateral uite8a. In considering applications for a guaranteed loan. the SBA wlll want to review the Federal. State or local regulation that requires an expenditure of funds for an environmental remedy. In the event of pollution prevention or r cling expenditures, a state" b the appropriate environmental agency validating the usefu"r ness or potential usefulness of the proposa! s would be necessary. Small businesses should find the program valuable in accessing capital when faced with compliance requirements. Others may want to use the program to purchase newer environmentally compatible equipment or recycling processes that reduce operating costs while reducing waste products. For more information on this new SBA Pr ram, you ma contact an Re ional, State or local SBA Office. or Ms. Karen V. Brown, €PA Small"$ usiness Om !I udsman at $03-%!57-1938or 1-800-368-5888. Sman Bushns MmWtbalion SmIl Business AdminisIralion Small Bushes8 Administralion Phiwa@hbMstrkl onice Pinsbugh Dblrkl OHice Hanisbuf DblridOHke Sulle 400 GSILobby 906 Penn Avenue. 5th Floor 100 Choakul Slreot. Suile 309 ~2~~~-.PA19004 PLtsbugh. PA 15222 Hanhburg. PA 17101 (412) 644-2760 (717) 782-3840

01~0m2 3 %HMR is2 WPPPPNl 62 p- One approach to private funding involves the use of business development corporations Through a BDC.financing is provided in conjunction with another lending institution. BD lenders who secure loans for businesses which would not normally be approved for conventiond financing. Therelore loans must be evaluated by the BDC and the convenlional institution. If one is participating. Under this program, loans must be used lo purchase land or buildings, lo rehabilitate or construd buildings. and/or to purchase equipment. machinery, lumlture, fixtures, and llution control equipment. Funds may also be used lo make leasehold improvements. For additionap" lnformation contact one of Ihe lollowing local Business Development Corporations.

C Rw Mora P.ul Mnchrll Pmrylvmh 0.v crd(c:orp. Soutlwestan Ponnsylvm~iaD.v. Fund Joaep4IMDqyWeslm Pnimylvn D.V . Crdd, or*ca"a c.nw 3 Ponn Cenler Plaza. Suite 604 m lM~l.lah ,SJI. 103 PWw.PAbhia.PA 19102 3ihhT-BldP. __ PA 17110 215-w84677 PNlsbugh.PA 162219 ,";%a34 412-2899208 6.3 The PA kmauof Emnomlc Assislance has two rams under which a buslness may be able to galn Rlranchl support for pollution control or waste rJT udon projects. The Pennsylvania capital loan fund wlll flnance the purchase of any piece of equipment A $345 mNion dollar revenue bondlmorlgage pro ram win offer financial asslstance lo hezardws and solid waste disposal programs wit1 Ihe stlpulalion that at least 25% of the funds be spenl on sdld waste disposal. Both are contingent on the fact that the improvement will Increase employment In the area. For more hformafionon x e98 programs, contact: Buroau 01 EcoMmic AsdsUm Rorm 405 Faun Wldi Hurlabur .P?17120 (717) 787?1000 6.4 Fn- Under the Hazardous Sba Cleanup Acl. Acl 108. which was SI ned Into Law In October 1988. faclitles that install and operate recycling equi men1 ~Q~QIBApril 15, 198 3. are ellp(Me for a grant of up to 25 percent of installalion cosls. Two millP on dollars Is available each year lor this program. The ACl deflnes 'recycling equlpment' as 'machinery used exclusively lo process and redalm hazardous waste materials Into a raw producl that Is non-hazardous and reusable. thereby redudn the total amount of hazardous matefial produced al a particular Iocauon.' AddlUonal infonnaUon on t s grant m be oblained Irom: R

Grog Hardwr (This grant program has expired. Division d Wule Minimizntion nnd plnnning Ponm VUJ. Dqmrbnont of EmlronmonW Roaoueos Contact Georgia Kagle regarding P.O. froa2065 any future reauthorization.) Hanbbvrg. PA 17120 (717)787-7382 7. There are a number ol private and public organlralions offerin technical assistance to businesses and the communhy via telephone. oflen through toll-lree hotlines. 8ucii services can oflen provide quick and easy answers lo questbns related lo hazardous materials. Below are tele hone numbers for hotlilies and infonnalbn services coverlng a variety of Iiazardous materials topL . .-

OlnO192 4 QCHMR 1902 WPPPP/41 €-- €-- Technical information (800)334-CHMR on hazardous materials and Federal/stale regulations

Em.!!-

EPA chemical Et””- For information on proper (800) procedures lor handling chemical emergendes - €PA RcRAlcERCLA For help with hazardous (800)424-9346 Holhe waste and/or Federal Super- fund related problems For 33/50Program information (202) 5x1404 8 for problems related to TSCA toxic substances EPAsmelBushass For help with environ- (m) ombudsman mental roblems specific - to smalP business (800)426-4791

FPAWASF REDUCTION PROORAMS/RESEARCLI O(1ScedReseaeh Technical information (513) -7529 on Waste Reduction Wsste“q MLmhalkn Div. chchnels.OH

EMERGFNCY RESPONSF

Assistance for hazardous W)-2z2 materials problems lnvolv- lng railroads (Operates 24 hours per day.) To report major chemical (800)4244” spills

For response teams (802)479-2307 (public or Industrial) requiring information on tools. materials. emergency planning, etc. To report a chemical (800)424-8802 spill on navigable waterways

”SPORT A-OF-MATERtALs oepa”totT-- To receive assistance (202)3664488 patation- on Federal hazardous substance transportation regulations

01130192 5 %HMR 1992 wPPPP;41 OSHA Homne inlormation on occupa- (202) 523-8036 tional exposure to hazardous substances

PFSTICIDES AND TOXIC SUBSTANCES Wf=~MAllON

NStiOdM For consultation in the (217) 333-3611 POiSOncarwl- diagnosis and treatment of universiyof- suspected or actual animal poisonings (Staffs a North American response team.)

TexasTech Um Contact to reach the (soo) 8587378 PesGddeHolAne National Pesticide Telecommunication Network. providing health, toxicology. and cleanup information For problems related to TSCA toxic substances

For technical inlormation on Radon CMA NaIiod chemical For technical inlormation ReswceM~ on hazardous chemicals center chemicslservices Can put you in touch wifh (202) -7285 int0r”nNehVak manufacturers of chemical in question AsbestosTechnlcal For inlormation on (202) 554-1401 hbt”.and handling asbestos Re(erral

CaMlmecROdud For information on sately 638-2772 =v of consumer goods ’ HasshddProduds- Information on disposal of (202) =*!E35 ”- household hazardous waste

CANCER CAUSING (!CARCMoGF NICI SUBSTANCE INFORMA- UaIiKlIdhstitute For inlormation on the 422-6237 OfHealth-Cancer carcino enic qualities bltomrrbon.service of certaB n chemicals

01130l92 6 %HMR 1992 WPPPPII 1 Center for Hazardous Materials Research University 01 Pinsburgh Applied Research Center 320 William Pin Way - Pittsburgh, PA 15238 Fax (412) 826-5552 (41 2) 826.5320 - - .. ___ USEFUL REFERENCE DOCUMENTS

The Canter For Hazardous Materials Research (CHMR) oflers a variety of documents which provide useful additional information and guidance on pollution prevention and control.

For co lea of CHMR documenfa, or lor8 aubscrlpflon to CHR R'a quarlerly newaletfer - The Mlnlmkor -/uaf call CHMR'a hofllne, 800-334-CHMR.

CHMR Manuals. ReDOI1S. and fnfomaflon Packefp * Industrial Waste MinimizationManual. October 1891. Cost: $60.00 * Underqround Storaoe Tank fUST) InformationPacket. July 1990. Cost: $20.00. - Waredness. Prevention and Conllnoencv fPPCI Plans InformalionPacket. January 1991. Cost: $25.00

CHMR F8cf Sheefs (No Char@) Pollution Prevention -- General - Pdlulion Prevention: The Environmental Strategy 01 The Nineties 1990. - Sources For Pollution Prevention Information * Pollution Prevention Equipment & Supplies - CHMR Pollution Prevention Programs Waste Minimization Bibliography Pollution Prevention -- lndustrv SDeciflc Pollution Prevention: Strategies For Chemical Production. 1990. * Pollution Prevention: Strategies For Metal Finishing. 1990. * Pollution Prevention: Strategies For The Coal Mining Industry. 1990. * Pollution Prevention: Strategies for DemolitionWaste. 1990. * Pollution Prevention: Strategies For Fossll Fuel Power Generation. 1990. * Pollution Prevention: Strategies For Paper Manulactudng. 1990. * Pollution Prevention: Strategies For Petroleum Refining. 1990. Pollution Prevention: Strategies For Printing. 1990. - Pollution Pievention: Strategies For The Steel Industry. 1990. * Pollution Prevention: Strategies For Waste Water Treatment. 1990. Reaulatory

* Makina.. . -. . . .~~ a Waste Determination 9 The Toxicity Characlerlstic (TC) Rule Transporting Hazardous Waste: How the Manifest Svstem Works In PA * Compatiblek'aste Group Categories - Emergency Response Reportin - Under round Storage Tanks (U8T's) - What 80 I Do When My Underground Gasoline Storage Tank Leaks? * Wastewater - Storm Weter * General Permits For Storm Water * Hlghli 111s 01 The Clean Air Act Amendments The &an Air Act Amendments Air Toxlcs Provisions - Hazardous Waste Issues Bibliography

. .- .. . __- A Subsidiary 01 the University 01 Pittsburgh Trust SDecific Wastes

* Lead Acid Battery - Radon. .- _.. . * UsedOil - Are Used Oil Filters Hazardous Waste? mcyclino & Household Hazardous Waste - Act 101 * Household Hazardous Substances -.and Alternatives * Household Hazardous Waste

*g!?l

Guides To Pollution Prevention - The Pesticide Formulatin Industry (625/77-90/004) - The Paint Manulacturing sndustry 625/77-90/005) * The Fabricated Metal Products Ind ustry (625/7-90/006) * The Printed Circuit Board Manufacturi Ind~strj'(625/7-90/007) - The Commercial Printing Industry 623-90/006) * Selected HospiIal Waste Streams \625/7-90/00g) Research 6 Educational Institutions (625/7-90/010) - The Automotive Repair Industry (625/7-911013) * The Fiberglass-Reinforced 6 Composite Plastics Industry (625/7-91/014) * The Marine Maintenance 6 Repair Industry (625/7-91/015) - The Automotive Refinishing lndust (62.5/7-9t/016) * The Pharmaceutical industry (625/r-91/017) -Titleen& - SARA Title 111 Fact Sheet (February 3990) * Understandin Sections 31 1 6 31; IPCRA * Section 313 llelease Reporting sments Toxic Chemical Release Inventor) iitgorting Form R 6 Instructions (1990) * Section 313 Issue Paper: Clarification6 Guidance For The Metal Fabrication Industrv * Common Synonyms ' Air Contamlnank: Permissible Exposure Limits (OSHA, tQB9) * Titie 111, Section 313 Release Reporting Guidance: Estimating Releases From: - Monofilament Fiber Manufacturing - Electroplating Operations - Presswood 6 Laminated Wood Products Manufacturing - Printing Operafions - Semiconductor Manufacturing . Textile Dyeing - Wood Preserving Operations Q@er Available EPA Documene The 33/50 PrT.m: Forging An Alliance For Pollution Prevention * US. EPAs Po ution Prevention InformationClearin house (PPC) Waste Minimization Opportunity Assessment Manuag (625/7-8elo03) * Understandingthe Small Ouantit Generator Hazardous Waste Rules - Notificationof Regulated Waste ictivity Application Package (wRh PADER Supplement)

- Waste Reduction 6 Rec cling For Pennsylvania Biisinesses * Pennsylvania Used Oil Aecovery Facilities 6 Haulers * Waste Minimization Fact Sheet - Waste Exchangs Fact Sheet * Northeast Indusmial Waste Exchange Listings Catalo * Directory of Recycling Markets & Operations. Cost: 85.OOIPADER Region

01/30192 2 w PPPP14 1 Appendix from EPA's "Guides to Pollution Prevention" series

Appendix B Where to Get Help Further Information on Pollution Prevention ~

Additional information on source reduction. reuse and The Guides to Pollution Prevention manuals"' describe recycling approaches to pollution prevention is available in waste minimization options for specific industries. This is a EPA repons listed in this section. and through stale programs continuing series which currently includes the following titles: and regional EPA offices (lisled below) that offer technical and/or financial assistance in Ihe areas of pollution prevention Guides to Pollution Prevention: The Paint Mon@mturing and treatment. Ind~rry.EPAI625/7-90/005

Waste exchanges have been established in some areas of Guides to Pollution Prevention: The Pesticide Formulating the US.to put waste generators in contact wilh potential users Industry. EPA/625/7-90/004 of hewaste. Twenty-four exchanges operating in the US. and Canada are listed. Guides to Pollution Prevention: The Commercial Priming Industry. EPiV62517-901008

US. EPA Reports on Waste Minimization Guides to Pollution Prevention: The Fabricated Metal Indus- Waste Minimization Opportunity Assessment Manual. EPAl try. EPA/625/7-90/006 625/1-88/003."' Guides to Polluion Pievention For Selected Hospital Waste Waste Minimization Audit Report: Case Studies of Corrosive Stream. EPA/625/7-90/W and Heavy Metal Waste Minimization Audit a a Specialty Steel Manufacturing Complex. Executive Summary.' NTlS Guides lo Pollution Prevention: Research and Educalio~l

No. PB88 ~ 107180 Instituions. EPA/625fl-90/010

Waste Minimization Audit Report: Case Studies of Minimiza- Guides to Pollution Prevention: The Printed Circuit Board tion ,of Solvent Wastcfor Parts Cleaning and from Electronic ManyfaCliUiq Industry. EPA/625/7-90/007 Capacitor Mani&acturing Operation. Executive Summary.' NTlS No. PB87 - 227013 Guides to Pollution Prevention: The Pharmaceutical Indus- rry. EPAI625l?-91/017 Waste Minimization Audit Report: Case Studies of Minim'za- tion of Cyanide Wastesfrom Electroplating Operations. Ex- Guides to Polluion Prevention: The Photoprocessing Indus- ecutive Summary.' EPA No. PB87 -229662. try. EPAI625/7-914 12

Report to Congress: Waste Minimization. Voh.I andll. EPAI Guides to Pollution Prevention: The Fiberglass-Reinforced 530-SW-86-033and 034 (Washington. D.C.:U.S.EPA.1986)." and Composite Plastic Industry. EPA/625/7-911tl14 Waste Minimization - Issues and Options. Vols. 1-111 EPAI Guides to Pollution Prevention: The Automotive Repair In- 530-SW-86-041 through -043. (Washington. D.C.: dustry. EPiV625fl-91r013 U.S.EPA.1986." Guides 10 Pollution Prevention: The Marine Repair Industry. __ EPAJ625n-9 ID15

'ErccuivcSumuy av8ibblefmn EPA.CW Putdiuliau UNl. 26 Wen US. EPA Pollution Revention Information Clearinghouse MhLulher King Drive. Cincinnau. OH. 45268; full rspnt wulrble (PPIC): Electronic Informion Exchange System (EIES) - fmn the Nalian.1 Tcclniul Informatian Service (NITS). US.Depvunslt ~ orCanmenx. Spingf~ld.VA7.2161. User Guide, Version 1.1. EPAI600/9-89/086 "Av.il.blefmnlheNaudTeshniul InformuionScmce~~~8ve~volumc 14KlIs No. PB87-114328. "'Available fmm EPA CWPubliulimr Unit. 26 Wen hninLuther King hive. Cincinnati. OH 45268. (513) 569-7562

41 Waste Reduction Technical/Financial Assistance Program The EPA Pollution Prevention Information Clearinghouse (PPIC) was established 10 help reduce industrial pollulants through technology msfer, education, and public awareness. PPIC collects and disseminates technical and olher information on pollution prevention through a telephone hotline and an electronic information exchange network. Indexed bibliog- raphies and abstracts of reports, publications. and case studies about pollution prevention are available. PPIC also lists a calendar of peninent conferences and seminars; information about activities abroad and a directory of waste exchanges. Its Pollution Prevention Information Exchange System (PIES) can be accessed electronically 24 hours a day without fees.

For more information contact PIES Technical Assislance Science Applications Intemational Corp. 8400 Westpark Drive McLean. VA 22102 (703) 8214800

Or U.S. Environmental Protection Agency 401 M Smet S. W. Washington. D. C. 20460 Myles E. Morse OfIice of Envimnmental Engineering and Technology Demonstration (202) 475-7161

Priscilla Flattery Pollution Prevention Office (202) 245-3551

The EPA's Office of Solid Waste and Emergency Re- sponse has a telephone call-in service to answer questions regarding RCRA and Superfund (CERCLA). The telephone numbers are:

(800) 424-9346 (outside the District of Columbia)

(202) 382-3000 (in the District of Columbia) PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES SOURCE REDUCTION STRATEGY COORDINA~RS RgGIOW...... Calvin Ligons 215-832-6212 DER, Bureau of Waste Management Lee Park, Suite 6010, 555 North Lane rConshohocken PA 19428 ucks, Chester, Delaware, Montgomery & Philadelphia Counties ...... Bob Wallace 717-826-2549 DER, Bureau of Waste Management 90 East Union St. Wilkes-Barre PA 18701-3296 arhn, Lackawanna, Lehigh, Luzerne, Monroe, Northampton, Pike, Schuylkill, iusquehanna, Wayne & Wyoming Counties RgGIOW...... Dave Richard Bob Zaccano 717-657-4588 DER, Bureau of Waste Management 1 Ararat Boulevard Harrisburg PA 17110 ams, Pedford, Berks, Blair, Cumberland, Dauphin, Franklin, Fulton, tingdon, Juniata, Lancaster, Lebanon, Mifflin, Perry & York Counties REGIOW...... Dennis Wright 717-327-3653 DER, Bureau of Waste Management 200 Pine Street Williamsport PA 17701 radford, Cameron, Centre, Clearfield, Clinton, Columbia, Lycoming, Montour, orthumberland, Potter, Snyder, Sullivan, Tioga & Union Counties REGION...... Fred DeNorscia 412-442-4000 DER, Bureau of Waste Management 400 Waterfront Drive Pittsburgh PA 15222-4745 legheny, Armstrong, Beaver, Cambria, Fayette, Greene, Indiana, Somerset, shington & Westmoreland Counties. REGION...... Brian Mummert Sigma Toth 814-332-6848 DER, Bureau of Waste Management 1012 Water Street Meadville PA 16335 , Clarion, Crawford, Elk, Erie, Forest, Jefferson, Lawrence, McKean, ercer, Venango & Warren Counties PerI

I I I!

PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES Bureau of Waste Management Division of Waste Minimization and Planning P.O. Box 8472 Harrisburg, PA 17106-8472 -C (717) 787-7382 -. C a a Q