Waste Reduction and Pollution Prevention Assessment

Module Objective Having read this, you should know the following: Basic motivation and history of waste reduction and pollution prevention in manufacturing What a generator and SQG are The definition and good practices of waste reduction How to perform a pollution prevention assessment and improvement using mass (& energy) balances.

Pollution prevention efforts are often mandated by legislation. History Practiced in industry, pollution prevention usually focuses on elimination of pollutants from existing products and process technologies Pollution prevention and waste reduction procedures are predecessors to DFE and ECDM and are well established and well known in the US. Initial impetus came from the 1960s when the US pollution became to high to bear in some locations and the US Environmental Protection Agency was formed. Pollution prevention efforts are often mandated by legislation. For example, US regulations require pollution prevention programs for companies emitting hazardous substances.

Hazardous Wastes and Toxic Chemicals The following laws exemplify legislation about hazardous and/or toxic chemicals: National Emission Standards for Hazardous Air Pollutants (NESHAP); Hazardous Air Emissions. Asbestos, beryllium, mercury, vinly chloride, benzene, arsenic, and radionuclides in general. Clean Water Act; Priority Pollitants. 126 individual chemicals, including volatile organic substances, acid compounds, pesticides, heavy metals, etc. Resource Conservation and Recovery Act (RCRA); Hazardous Wastes. More than 400 discarded commercial chemical products and specific chemical constituents of industrial waste streams destined for treatment or disposal on land. Superfund Amendments and Reauthorization Act (SARA) Title II, Section 313; Toxic subtances. More than 320 chemicals and chemical categories released into air, water and land. Under specified conditions, facilities must report releases of these chemicals to EPA's annual Toxics Release Inventory. Superfund Amendments and Reauthorization Act (SARA) Section 302; Extremely Hazardous Substances. More than 360 chemicals for which facilities are required to prepare emergency action plans if these chemicals are present at the facility above certain treshold quantities. Releases trigger required reporting by the facility to the State Emergency Response Committee (SERC) and the Local Emergency Planning Committee (LEPC) under SARA Section 304.

Regulatory compliance Federal and state laws require all firms classified as hazardous waste generators or small quantity generators (SQGs) to implement a pollution prevention program to reduce the quantity of waste to the extent that it is economically feasible. Small quantity generators are facilities that generate more than 100 kg/month but less than 1000 kg/month of hazardous waste. A facility generating more than a 1000 kg/month is classified as a generator. Firms permitted as hazardous waste generators are generally required under the Resource Conservation and Recovery Act (RCRA) to report sampling data on a regular basis. When hazardous wastes are minimized, the frequency of sampling and data reporting is also minimized. If a disposal facility releases contaminants, then the original generators of the waste are also reponsible/liable for these releases under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

Regulatory Compliance Certification Generators are required to sign the following statement: Unless I am a small quantity generator who has been exempted by statute or regulation from the duty to make waste minimization certification under Section 3002(b) of RCRA, I also certify that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable, and I have selected the method of treatment, storage, or disposal currently available to me which minimizes the present and future threat to human health and the environment.

Who are Small Quantity Generators? It is estimated that there are 600 to 700 thousand SQGs in the nation. These businesses may generate as much as 940,000 metric tons of hazardous wastes annually. These generators generally have fewer than 5 to 10 employees and are managed by persons with limited training in identification and management of hazardous wastes. Technical Assistance Programs and some EPA grant programs are focused on SQGs.

SQG Industries and wastes Spent solvents Strong acids and alkalis Photographic wastes Dry cleaning filtration residues Pesticide solutions Waste formaldehyde Empty pesticide containers Ignitable wastes Major Waste Types Metal manufacturing Photography Ceramics Construction Textile manufacturing Paper industry Motor freight terminals Wholesale and retail establishments Analytical and chemical laboratories Furniture/wood manufacturing and refinishng Pesticide formulators, applicators and end-users Cleaning agents and cosmetic manufacturing Educational and vocational establishments Vehicle maintenance Printing Dry cleaning Equipment repair Chemical manufacturing Wood preserving General manufacturing Major Industry Groups – Small Quantity Generators

Waste Reduction – Definition and Good Practices

What is Waste Reduction? Any activity that REDUCES or ELIMINATES the generation of waste AT THE SOURCE Changes in: Operating Practive Technologies Inputs Products Recycling In process In-Line Closed-Loop

Good Operating Practices Waste Minimization Programs Management and Personnel Practices Material Handling / Inventory Practice Loss Prevention Waste Segregation Cost Accounting Practices Production Scheduling

Equipment, layout or piping Automation Operating conditions Technology Changes Production process Equipment, layout or piping Automation Operating conditions Flow rates Temperatures Pressures Residence times

Basic Material & Product Changes Input Material Changes Material purification Material substitution Product Changes Product substitution Product conservation Product composition

Use and Reuse Return the material: To the originating process as a substitute To another process as an input

What is NOT Waste Reduction? Dewatering Dilution Evaporation Waste burning in industrial furnaces, boilers, cement kilns Waste shifting Off-site recycling Any other end-of-pipe management

Procedure & Tools

Basic Assessment Flow Diagram

Used = amount in product + air emissions + wastewater + waste Materials Balance List the raw materials How much is: Used In the product Lost as air emissions Lost in wastewater Found in waste Used = amount in product + air emissions + wastewater + waste

Materials Balance Example

Describe the Waste Is it: How much: An air emission? A waste water discharge? A sludge? A liquid? Mixed with other wastes? A hazardous waste How much: Is generated in a year? If in batches, how often and how much?

Describe the Waste Example

Electroplating In-Class Example Draw a process flow chart for electroplating operation Set up a basic material balance Describe the wastes Identify opportunities for waste reduction and pollution prvention

Industrial Examples

Waste Reduction by Dow Chemical Several chemical process industries have compiled an outstanding record in minimizing waste generated at their facilities. Dow Chemical is one example. Dow takes a balanced approach to reducing environmental impact of operations with a focused effort on source reduction and recycling. The environmental policy places a priority on waste and emission reduction, and environmental guidelin support the hierarchy of waste management, that is, 1) source reduction, 2) recycling, 3) treatment, 4) and land disposal as the last option When efforts to reduce a waste stream either at the source or by recycing have not been successful, Dow (like many others) still has the responsibility to manage and treat the waste stream. Dow uses state-of-the art incineration and biological treatment facilities.

Waste Reduction Always Pays (WRAP) Dow has implemented a WRAP program and an individual contact in each of its division. The WRAP contacts design their activities around the following broad goals: 1) Reduce waste to the environment. 2) Give recognition for excellence. 3) Develop a pollution prevention mentality. 4) Provide support for pollution prevention projects. 5) Measure and track progress. 6) Strive for continuous improvement. 7) Reduce long term costs.

WRAP Implementation The following iterative process is used to implement the WRAP program: 1) Inventory of all process loss to air, water, and land. 2) Identify the sources of those losses. 3) Prioritize reduction efforts. 4) Allocate resources and implementation projects. 5) Document and report progress. 6) Communicate progress internally and externally. 7) Plan for future reductions.

Polution Prevention Assessment (PPA) procedure (1) EPA Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003) Planning and organization Get management commitment Set overall assessment program goals Organize assessment program task force Assessment organization and commitment to proceed. Assessment Phase: Collect process and facility data. Prioritize and select assessment tables. Select people for assessment teams. Review data and inspect sites. Generate options. Screen and select options for further study. Select new assessment targets and reevaluate previous options. Assessment report of selected options.

Polution Prevention Assessment (PPA) procedure (2) Feasibility Analysis Phase: Technical evaluation. Economic evaluation. Select options for implementation. Final report, including recommended options. Implementation: Justify Projects and obtain funding. Installation (equipment). Implementation (procedure). Evaluate performance. Repeat the process

Focusing Your Efforts

Criteria for selecting principal waste streams The following criteria can be used to identify principal waste streams: Composition Quantity Toxicity of wastes Method and cost of disposal Compliance status Potential for minimization Priorization of waste streams to be tackled should also include consideration of available budget for the PPA The best means for identifying information on all waste streams is the use of flow diagrams and, then, material balances.

Technical Evaluation of Options When evaluating the options for minimizing waste streams, the following technical criteria should be considered: Technical reliability System safety Product quality maintenance Space requirements Compatibility of proposed system with existing systems Downtime necessary for installation Special expertise requirements Labor and utility requirements For economic evaluation, make a break-down in capital cost operating cost

Economic Evaluation For economic evaluation, make a break-down in capital cost and operating cost/savings. Capital costs include: fixed capital cost for designing, purchasing, and installation equipment cost for working capital, permitting, training, start-up, and financing charges. Operating costs and savings: reduction in waste treatment, storage and disposal raw material cost savings insurance and liability savings increased cost or savings associated with product quality decreased or increased use of utilities decreased or increased revenues from changes in production of marketable by-products.

Profitability If capital cost and operational costs/savings are known, then profitability can be calculated. Also consider that violation of environmental regulations may result in shut-down and criminal penalties. Rule: Options requiring no capital investment should be implemented as soon as possible.

The Problem with Pollution Prevention and End-of-Pipe Approaches