paint and coatings manufacturing sector - p2ric

Paint and Coatings Manufacturing Sector

A Pollution Prevention Assessment and Guidance

Washington State Department of EcologyHazardous Waste and Toxics Reduction Program

June, 1998Publication #98-410

printed on recycled paper

For a copy of this document, please contact:

Department of EcologyPublications

P.O. Box 47600Olympia, WA 98504-7600

Please include your street address for UPS delivery

If you have questions or would like more informationabout this report, please contact the Paint andCoatings Manufacturing team member nearest you.

Margit Bantowsky Olympia (360) 407-6353Mark Benedict Yakima (509) 575-2803James DeMay Bellevue (425) 649-7090Judy Kennedy Olympia (360) 407-6744Miles Kuntz Olympia (360) 407-6748Byung Maeng Bellevue (425) 649-7253Jeff Phillips Spokane (509) 456-3162

The Department of Ecology is an equal opportunity agency and does not discriminate on the basis ofrace, creed, color, disability, age religion, national origin, sex, marital status, disabled veteran’s status,Vietnam Era veteran’s status or sexual orientation.

If you have special accommodation needs or require this document in alternative format, please contactthe Hazardous Waste and Toxics Reduction Program at (360) 407-6700 (voice) or (360) 407-6006(TDD).Ecology’s telecommunications device for the deaf (TDD) number is (360) 407-6006. Regional TDDnumbers are:

CRO (TDD) (509) 454-7673 NWRO (TDD) (425) 649-4259ERO (TDD) (509) 458-2055 SWRO (TDD) (360) 407-6306

Table of Contents

EXECUTIVE SUMMARY 1

I. BRIEF PROJECT HISTORY 4A. Ecology and Sector Projects 4B. How Paint and Coatings Manufacturing was Selected 4C. Initial Research 4D. Feedback from Northwest Paint Council (NWPC) 4E. Initial Scoping Efforts 5

II. SITE VISITS 6A. Purpose of Visits and Site Selection 6B. Site Visit Objectives and Approach 7

III. POLLUTION PREVENTION:�visit results, recommendations 8& resourcesA. Common Industry Practices 8B. Future Pollution Prevention Opportunities 10

IV. SOLID WASTE�visit results, recommendations & resources 13A. Drums 13B. Five-Gallon Pails & Dry Ingredient Bags 13C. Pallets 13

V. DANGEROUS WASTE�visit results, recommendations & 14resourcesA. Corrections to Common Mistakes 14B. Clarification of Pertinent Dangerous Waste Regulations 14

VI. ORPHAN WASTE�visit results, recommendations & resources 16

VII. SPILLS�visit results, recommendations & resources 16

VIII. STORMWATER�visit results, recommendations & resources 16A. Cover and Containment 17B. Permitted Facilities 17C. Ecology’s Stormwater Compliance Staff 17

IX. AIR QUALITY�visit results, recommendations & resources 18

X. ADDITIONAL ISSUES�visit results, recommendations & resources 18A. Paint Distributers 18B. Paint Recycling 18C. Measuring Environmental Success 19D. Internet Use 19E. Preferred Forms of Technical Assistance 19

XI. MEASURING PAINT & COATINGS SECTOR�Project Success 20

XII. POSSIBLE TECHNICAL ASSISTANCE PROJECTS BY ECOLOGY 20A. Paint and Coatings Manufacturer’s Materials Exchange 20B. Paint and Coatings Manufacturer’s Environmental Website 20C. In-House Ecology Compliance Inspector Briefings 21D. Technical Assistance Visits to Remaining Manufacturers 21E. Information Transfer to Production Staff 21

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APPENDIX A 23Paint and Coatings Manufacturers in Washington

APPENDIX B 25Survey Forms: Compliance Checklist and Supplemental Questions

APPENDIX C 29Pollution Prevention Results

APPENDIX D 37Pollution Prevention Opportunities Checklist

APPENDIX E 43Toxicology of Hazardous Pigments and Chemicals

APPENDIX F 47Vendor Listings

APPENDIX G 53Guidance on Counting Hazardous Waste

APPENDIX H 67ShopTalk Article on Speculative Accumulation

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Acknowlegements“ The success of this project is a result of the efforts of many people. First of all, the Paint Sector Team, would like toexpress gratitude for the Pacific Northwest Paint Council’s Operating Committee’s continued support and participation.Without the committee’s input, this project could have easily veered into a number of less-effective directions. In particular,we would like to extend special thanks Ms. Laurel Jamison, Operating Committee chair, and President of Rudd Companyfor her leadership not only on the committee but in modeling good environmental practices in her business, and for hersense of humor. We are also deeply appreciative of the time and information provided by the eleven facilities we visited inMarch - they provided the foundation of data for this report.

Finally, as project lead, I wish to acknowledge the hard work and dedication of my Sector Team-mates—Mark Benedict,James DeMay, Judy Kennedy, Miles Kuntz, Byung Maeng and Jeff Phillips—I feel blessed to have worked with such agreat group of individuals.”

Margit Bantowsky

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Paint and Coatings Manufacturing Sector Project 1

EXECUTIVE SUMMAREXECUTIVE SUMMAREXECUTIVE SUMMAREXECUTIVE SUMMAREXECUTIVE SUMMARYYYYY

In 1997�1998, the Washington State Department of Ecology�s (Ecology) Hazardous Waste andToxics Reduction Program conducted a statewide technical assistance project for the paint and coatingsmanufacturing industry sector. The project was conducted in consultation with the Operating Commit-tee of the Northwest Paint Council (NWPC), a trade association for paint and coatings manufacturers.The project focused on pollution prevention (P2) and hazardous waste regulatory compliance, but italso addressed issues related to air quality, water quality and solid waste management. Ecology�s PaintSector Team sought input on the project�s goals and objectives from the industry representatives on theNWPC Operating Committee. The technical assistance (TA) provided in this report and the five future�projects� listed in the last chapter are based on input from the NWPC, and on the site visits to elevenpaint and coatings manufacturers throughout the state, conducted in March 1998.

The Paint Sector Team and the NWPC drafted the following project vision statement:

�To engage in a collaborative effort with Washington�s Paint Manufacturers to achieve measur-able reductions in material consumption, toxicity, and/or releases, thereby reducing risk to humanhealth and the environment. In doing so, we want to provide excellent service to this industry andfoster action that is both good business and steps towards sustainability/global stewardship. We wantto craft goals and project elements that are supported by the industry and Ecology, and to successfullycomplete these elements in the allotted time frame. We would like this project to be a positive examplefor other Ecology-Industry endeavors.�

The scope of the project included:

4 Researching industry-specific pollution prevention practices

4 Conducting P2/regulatory compliance site visits at a cross-section of Washington�s paintmanufacturing facilities

4 Identifying P2 and waste management issues that could and should be addressed consistently inthe paint manufacturing sector, thereby �leveling the playing field�

4 Highlighting and providing resources for future P2 actions.

4 Developing a technical assistance strategy for Ecology�s follow-up technical assistance efforts

Site visits to a selection of 9 paint manufacturing and 2 distribution facilities in March 1998resulted in the following observations and the identification of technical assistance needs.

Pollution Prevention: Pollution prevention (P2) is considered any activity that reduces or eliminatespollutants entering the environment such air emissions, water discharges, or solid or dangerous wastes.Ecology also considers pollution prevention those activities that reduce either the quantity or thetoxicity of materials used.

The facility visits revealed that the paint and coatings manufacturing industry is already doing asignificant amount of pollution prevention. For example, most facilities reuse their wash solvent andwash waters in subsequent formulations, use dedicated equipment to reduce the need for cleaning, andare actively reformulating products to reduce their toxicity.

Even though nearly all the facilities indicated that they employed efficient materials managementtechniques, the Paint Sector Team found that there was a range of effectiveness in this area. Ecologybelieves that improved materials management could be a fruitful area for future waste reduction formost facilities.

2 Washington State Department of Ecology

Additional areas likely to have future benefit are (for more detail, see Section III PollutionPrevention):

1. Increasing the use of reusable and recyclable containers (for raw materials and for finishedproduct);

2. An industry-specific materials exchange to encourage the re-use of off-spec, obsolete, or excessamounts of materials and products;

3. Use of high-pressure tank and tote wash systems, including re-circulating systems to reuse thewash water;

4. Use of counter-current rinse methods (e.g. using dirty solvent for first rinse, cleaner solvent forsecond rinse, virgin solvent for final rinse);

5. Reducing the generation of materials and products that need to be �re-worked� into futureformulations or disposed of; and

6. Use of �shower caps� to reduce evaporative losses on smaller process tanks.

Solid Waste: A variety of containers are used to transport raw materials and product. Some of thedrums are sent back to the raw material suppliers, and reused; some drums are sent to drum recyclers.A number of raw materials are delivered in bulk in large, re-usable totes (e.g., solvents, titanium diox-ide, common resins). Some facilities use totes to package product for their larger customers. Usingthese reusable containers seems to be dependent on the supplier-manufacturer and the manufacturer-customer relationships, but Ecology encourages increasing the use of re-usable and bulk containerswhere possible. In addition, there is a need to find ways to recycle 5-gallon buckets (metal and plastic).Ecology provides some recycling vendor information in this report.

Dangerous Waste: Regarding compliance, we did not find any substantial dangerous waste (DW)regulatory violations. The most common minor violation was small containers of new solvent andwaste solvent left open or not tightly closed. For the most part, dangerous waste was stored, managed,and disposed of appropriately. In this report Ecology provides clarification on pertinent DW regula-tions. Counting recycled solvent is an area that needs particular clarification.

Orphan Waste: Paint wastes being abandoned or �orphaned� on a manufacturer�s property by thepublic turned out not to be a significant problem for most facilities. Only one facility had some recur-ring problems. The rest of the facilities have secured property limiting access to disposal areas. Or-phan waste may be more of an issue for distributors or retail paint stores.

Process Water Discharges: Although four facilities discharged some process water (wash water) tothe sewer, most manufacturers reincorporate process water into subsequent product batches. In the fewcases where more wash water was generated than could be reworked, the facilities either evaporated thewash water, or sent it for off-site disposal.

Stormwater: There was a significant range in how facilities were handling the outdoor storage ofmaterials and wastes exposed to precipitation and run-off. Because of the potential for environmentalimpact and because stormwater is outside of the purview of the Hazardous Waste and Toxics ReductionProgram, we recommend that

1) paint and coatings manufacturers with any questions regarding compliance with stormwaterrequirements contact Ecology�s staff (see Section VII Stormwater), or

2) request a technical assistance visit from Ecology�s Stormwater staff (in the Water Quality Pro-gram) for in-depth assistance.

At a minimum, cover and containment should be provided for all materials stored outdoors (contain-ment is required for hazardous waste, whether stored indoors or outdoors). Pertinent best manage-ment practices are outlined in this report.

Spills: Evidence of spills was observed at only one facility. This does not appear to be a significantissue for the industry at this time.


Air: Manufacturers addressed air by concerns keeping lids on tanks, and using minimal solvent towash tank walls during product let-down (dispensing into product containers). Ecology does, however,recommend that �shower cap� covers be used in conjunction with the wooden lids to reduce evapora-tive losses.Operations and maintenance (O+M) procedures for emission reductions during tank clean-out were not verified during the visits.

Possible Technical Assistance Follow-up Efforts for Ecology

In addition to the assistance and resources provided in this report, Ecology identified five poten-tial activities/services that could be valuable to and effective for the industry:

1) A paint and coatings-specific materials exchangeThe Pollution Prevention Resource Center in Seattle is planning to design and implement thematerials exchange.

2) A paint and coatings manufacturing environmental/P2 websiteThe Pollution Prevention Resource Center will be lead on this effort as well.

3) Paint industry briefings for dangerous waste inspectors (internal to Ecology)The Paint Sector Team member in each Ecology regional office will share the findings of thisproject with their respective dangerous waste inspectors.

4) Providing technical assistance visits to the remaining ten coatings manufacturersEcology management has agreed to extend the resources of this project in order to conductthese visits, which are being planned for October-November 1998.

5) Assisting facilities in disseminating compliance and P2 information from this report/project totheir production workersThis potential service will be evaluated after this report has been submitted to the industry.


I.I.I.I.I. BRIEF PROJECT HISTBRIEF PROJECT HISTBRIEF PROJECT HISTBRIEF PROJECT HISTBRIEF PROJECT HISTORORORORORYYYYY

A. Ecology and Sector PrA. Ecology and Sector PrA. Ecology and Sector PrA. Ecology and Sector PrA. Ecology and Sector ProjectsojectsojectsojectsojectsIn 1995, the Department of Ecology began

an effort to provide Washington businesses withstatewide industry-specific pollution prevention(P2) assessments and technical assistance. P2 isany activity that reduces or eliminates pollutantsentering the environment such as air emissions,water discharges, or solid or dangerous wastes.Ecology also considers pollution prevention thoseactivities that reduce either the quantity or thetoxicity of materials used.

Ecology�s technical assistance focused onreducing the use of hazardous substances, reduc-ing the generation of hazardous wastes, andcompliance with the Dangerous Waste Regula-tions. By choosing specific industry sectors forshort-term focused assistance, Ecology hoped toprovide a better service to business and makesome long-term environmental gains by reducinghazardous substance use and hazardous wastegeneration.

To date, Ecology has conducted sectorprojects with the electroplating, fiberglass, andprinted circuit board manufacturing industries. In1998, sector projects will be completed with thepaint and coatings manufacturing industry andfacilities providing national security defense.This report provides a project summary and thefindings of the Paint and Coatings ManufacturingSector Project as well as recommendations,information and resources for paint manufactur-ers.

BBBBB. How P. How P. How P. How P. How Paint and Coaaint and Coaaint and Coaaint and Coaaint and CoatingstingstingstingstingsManManManManManufufufufufacturing wacturing wacturing wacturing wacturing was Selectedas Selectedas Selectedas Selectedas Selected

The environmental impacts associated withthe management of paint and paint related wastesare a continuing concern for Ecology. Also aconcern are the potential environmental andhuman health effects of hazardous chemicals usedin the production, application and clean up ofpaints and coatings. As a result, Ecology�sHazardous Waste and Toxics Reduction (HWTR)Program chose to address paint and paint wasteissues by starting with paint manufacturers, withan eye toward possibly assisting paint distribu-tors, applicators, and contractors in the future.For the purposes of this project, the paint manu-facturing sector includes manufacturer�s ofcoatings such as paints, stains, sealers, varnishes,lacquers, and a variety of specialty industrialcoatings.

CCCCC..... Initial RInitial RInitial RInitial RInitial ResearesearesearesearesearccccchhhhhThe Paint Manufacturing Sector Team

initially identified 30 facilities in the state thatreported their industrial activity as paint andallied products manufacturing under the StandardIndustrial Classification (SIC) code 2851. Verifi-cation efforts trimmed that list to 19 facilities thatwere actually manufacturing paint and/or coatings(see Appendix A for the list of WA facilities). Tenfacilities manufacturing paint or related productswere in Ecology�s database of hazardous wastegenerators. Collectively, these facilities hadreported generating a total of over 345,000 lbs. ofhazardous waste and 50,300 lbs. of toxic airemissions in 1995.

DDDDD. F. F. F. F. Feedbaceedbaceedbaceedbaceedback frk frk frk frk from Norom Norom Norom Norom Northwthwthwthwthwest Pest Pest Pest Pest PaintaintaintaintaintCouncil (NWPC)Council (NWPC)Council (NWPC)Council (NWPC)Council (NWPC)

To better understand paint manufacturingneeds and issues, Ecology�s Paint Sector Teamattended a meeting with the Northwest PaintCouncil (NWPC) on September 10, 1997, inKelso, WA. The Council brought to our attentionthe following issues:

1.Government Specifications�Some governmentspecifications limit product use (e.g. a specifica-tion requires the use of solvent-based coatingsalthough qualified water-borne coatings areavailable).

2.Level The �Playing Field��Pro-active paintcompanies are already doing pollution prevention.Transfer these practices to smaller, and/or lesscompliant manufacturers by:

v Developing and distributing informationabout reduction practices, and

v Ecology conduct site-visits to thesefacilities

3.Develop Markets for Recyclable Materialsv Paperv Cans, drums, containersv Un-sellable paintsv Plastics

4. Address �Single-Use� Issue�A Department ofTransportation regulation that restricts the re-useof containers by requiring integrity-testing, etc.

5. Orphan Waste�Paint waste illegally droppedoff at a paint manufacturer�s site.

6. Contractor Paint Waste�Re-use and recycling,interface with distributors and manufacturers.


E. Initial Scoping EfE. Initial Scoping EfE. Initial Scoping EfE. Initial Scoping EfE. Initial Scoping EffffffororororortststststsThe Ecology Paint Sector Team received

these comments and developed an initial projectscope. The plan was to visit a representativesample of paint and coatings manufacturers to 1)verify the technical assistance needs listed inSection D, above; to 2) identify the level of on-going pollution prevention activity; and 3) toassess the level of regulatory compliance. Theproject vision statement that was collaborativelydeveloped was:

�To engage in a collaborative effort withWashington�s Paint Manufacturers to achievemeasurable reductions in material consumption,toxicity, and/or releases, thereby reducing risk tohuman health and the environment. In doing so,we want to provide excellent service to thisindustry and foster action that is both good busi-ness and steps towards sustainability/globalstewardship. We want to craft goals and projectelements that are supported by the industry andEcology, and to successfully complete theseelements in the allotted time frame. We would likethis project to be a positive example for otherEcology-Industry endeavors.�

Ecology�s responses to the NWPC issuesraised in Section D, above, are:

1. Government Specifications�Ecology is work-ing with the Washington State Department ofTransportation (DOT) through the PollutionPrevention Planning process to modify coatingspecifications in order to allow the use of moreenvironmentally friendly materials. Lobbying thefederal DOT is beyond this project scope.

2. Level The Playing Field�Ecology responded tothis request by visiting a selection of facilities togain an understanding of �playing field� issues andby sharing the results of those visits with theindustry statewide through this report. Ecologyand the NPWC are evaluating the possibility ofvisiting the remaining 10 manufacturers to shareproject results such as common and future P2opportunities, compliance issue clarifications/guidance, and vendor information. Stormwatermanagement and material management were twoareas that showed the greatest variability.

3.Develop Markets for Recyclable Materials�Developing markets for recyclable materials isnot within Ecology�s current capabilities, how-ever, information to help facilitate reuse andrecycling of the solid wastes of concern isincluded in this report.

4. Work on DOT�s Single-Use Regulations�Again, Ecology believes that lobbying to changefederal DOT regulations is beyond the scope ofthis project.

5. Orphan Waste�Ecology did assess the extentof this issue by conducting site visits and foundthat it is not a significant issue for most manufac-turers.

6. Contractor Paint Waste�Ecology assessed theclimate for paint waste recycling during sitevisits. At this point, paint waste recycling is acase-by-case arrangement between the manufac-turer and its customers. Trying to organize andinstitutionalize customer paint waste recycling isa very complex endeavor with many barriers toovercome. Consequently, given our currentlimited resources, Ecology is focusing instead onpromoting ways to reduce the need for paintwaste recycling.


II.II.II.II.II. SITE VISITSSITE VISITSSITE VISITSSITE VISITSSITE VISITS

A. PurA. PurA. PurA. PurA. Purpose ofpose ofpose ofpose ofpose of V V V V Visits and Site Selectionisits and Site Selectionisits and Site Selectionisits and Site Selectionisits and Site SelectionThe purpose of the 11 site visits (9 manufacturers, 2 distributors) was to assess the pollution

prevention activity level and to evaluate some of the issues raised by the NW Paint Council. Ecologyfocused on both pollution prevention and environmental compliance.

The facility selection was based on size and nature of operation, and was conducted with inputfrom the NW Paint Council. Consequently, the site visit group had representation from national, largeregional, local, small specialty, and industrial coatings manufacturers. Six of the facilities were locatedin the Seattle/King and Pierce County area, and five were located in eastern Washington in the Spo-kane, Yakima and Tri-Cities areas.

Facility Name Location Distributor or Type of CoatingsManufacturer

Columbia Paint Spokane NW Regional mfr. Architectural, industrial,stains, traffic

Daly�s Inc. Seattle Small specialty mfr. Specialty wood coatings

Daniel Boone Seattle/Tukwila Small local specialty mfr. Architectural, traffic paint,industrial

Kelly-Moore/ Seattle Large Regional mfr. Architectural, PreservativePaint industrial enamels

Lilly Industries Seattle Large National/ Industrial wood coatings �International mfr. stains, finishes, primers, top

Perfection-Letz Kennewick Small mfr. Architectural, industrial,agricultural, metal primer

Rudd Company Seattle NW Regional mfr. Industrial wood coatings fordoors & cabinets, floors

United Coatings Spokane/ Regional industrial mfr. Industrial, architectural,Greenacres roofing, paving coatings

Wasser High-Tech Seattle Industrial specialty mfr. Architectural, industrial

Sherwin Williams Spokane Distributor/blender Architectural, industrial

Standard Paint Yakima Distributor Architectural, industrial


BBBBB. Site V. Site V. Site V. Site V. Site Visit Objectivisit Objectivisit Objectivisit Objectivisit Objectives and Appres and Appres and Appres and Appres and ApproacoacoacoacoachhhhhFor recording the status of the many issues

and concerns, Ecology used three survey forms:one for pollution prevention activities, one fordangerous waste compliance, and one called�supplemental survey.� The supplemental surveycovered many of the questions/items that the NWPaint Council identified. The pollution preventionsurvey is discussed in Section III below. Copiesof the dangerous waste compliance checklist andthe supplemental survey can be found in Appen-dix B.

The site visit objectives were:

1. To assess the �level playing field� issue withrespect to both pollution prevention andenvironmental compliance

2. To identify new pollution prevention opportu-nities Ecology should be promoting in thisindustry

3. To assess whether distributors warrantattention/inclusion in this project

4. To assess paint recycling issues5. To assess solid waste issues (paper, plastic,

containers)6. To assess orphan waste issues7. To identify possible project success measure-

ments8. To document current and improved practices

(camera � photos to illustrate practices)9. To identify air and water issues10. To find out whether facilities would use an

internet website for information11. To determine what form facilities would like

their technical assistance to be in (e.g.,checklist, pamphlet, visits, etc.)

12. To identify additional research needs

Since the questions and checklists werefairly extensive, and the Paint Sector Teamwanted to document some of the practices withphotographs, it was decided to have teams ofthree on-site: two staff completing the surveysand one photographer. The Paint Sector Teammailed invitations to all the facilities three weeksbefore the visits began, and made appointments.The invitations included an endorsement letterfrom the NW Paint Council, and a letter fromEcology�s Hazardous Waste and Toxics ReductionProgram Manager stating these were technicalassistance visits, not for enforcement. The visitswere voluntary, and all the selected facilitiesaccepted our invitation to meet with them.

The entire Paint Sector Team began with agroup visit to one facility to verify our approachto conducting the site visits. Ecology is mostgrateful for Rudd Company�s generous offeringof their site, time, and assistance for this initialteam visit. The eleven visits were completedwithin the month of March 1998, and althoughthey were time-consuming (average on-site timewas 3 hours), the visits were productive and themanufacturers were very helpful.


III.III.III.III.III. POLLPOLLPOLLPOLLPOLLUTION PREVENTION:UTION PREVENTION:UTION PREVENTION:UTION PREVENTION:UTION PREVENTION:�visit r�visit r�visit r�visit r�visit resultsesultsesultsesultsesults, r, r, r, r, recommendaecommendaecommendaecommendaecommendationstionstionstionstions& r& r& r& r& resouresouresouresouresourcescescescesces

Ecology�s objectives in evaluating pollutionprevention (P2) activities were:

(1) to identify the common industry practices,and

(2) to identify the P2 actions that representthe most beneficial future opportunities.

The practices described below are based on18 sets of data: 11 site visit surveys and 7 mailed-in surveys from unvisited facilities. The consoli-dated data can be found in Appendix C. Thecomplete list of P2 opportunities is provided inAppendix D which manufacturers can use as achecklist for periodic self-auditing. A summary ofthe toxicology of the chemicals listed in the P2table can be found in Appendix E.

A. Common Industry PrA. Common Industry PrA. Common Industry PrA. Common Industry PrA. Common Industry PracticesacticesacticesacticesacticesListed below are P2 practices that were

common to most of the facilities surveyed, andwhich are likely to be valuable to most paint andcoatings manufacturers. They should be consid-ered baseline practices, in other words, facilitiesthat are not following these practices (whereapplicable) are not practicing P2 at the same levelas their peers.

Baseline P2 Practices for Paint Manufacturers

1. Blending off-spec materials into new product2. Elimination of heavy metals and chlorinated

compounds3. Reformulation into water-borne products4. Materials management5. Offering mistints and off-spec products to

non-profit organizations6. Giving or selling overages on custom products

to the customer7. Using re-usable and recyclable containers8. Formulator works with the paint maker9. Clearly indicating/highlighting formula

changes10. Using re-usable bag, metal, or vortiseive

screens and filters11. Use of sandmills12. Scheduling from light-to-dark products13. Dedicating equipment to a product or family

of products14. Wash the tanks as they are being let down15. Re-work wash solvent and wash waters back

into product16. Manually cleaning tanks17. Solvent distillation18. Maximize batch size

Some observations regarding each of thesecommon P2 practices are given below:

1. Blending Off-Spec Materials Into NewProductThis is an on-going effort for all facilities andis driven more by economics than environ-mental regulation�it�s expensive to turnproduct into waste.

2. Elimination of Heavy Metals andChlorinated CompoundsChromium, lead, mercury-based bactericide,and methylene chloride have virtually beeneliminated. Other metals and chlorinatedcompounds are being aggressively targetedand reduced. Appendix E contains informa-tion about the toxicological effects of thesecompounds.

3. Reformulation Into Water-Based ProductsMany solvent-based products have beenreformulated to be water-based. This hasgreatly reduced the industry�s use of hazard-ous chemicals.

4. Materials ManagementThough all companies are doing some levelof materials management to reduce waste andcosts, Ecology believes this is an area thatcould provide worthwhile reductions in thefuture as well.

5. Offering Mistints and Off-Spec Productsto Non-Profit OrganizationsSchools, low-income developments, commu-nity projects and organizations often seek outmaterials donations such as paint frombusinesses in the communitiy.

6. Giving or Selling Overages on CustomProducts to the CustomerRather than keeping small overages oncustom products or trying to find anothercustomer or use for them, many manufactur-ers are making an effort to give or sell smalloverages to the customer who ordered theproduct.


7. Using Re-Usable and RecyclableContainersSome manufacturers actively pursue usingrecyclable containers for raw materials andfinished product to reduce the generation ofsolid waste. (Although a common practice tosome degree, this remains an area for futureopportunity. See Section IV Solid Waste.)

8. Formulator Works With the Paint MakerWhen manufacturing a new product for thefirst time, the formulator will work with thepaint maker to limit the production of off-specification product.

9. Clearly Indicating/Highlighting FormulaChangesTo prevent producing off-spec products due tohuman error, manufacturers are taking steps tocall attention to formula changes throughhighlighting or other indicators.

10. Using Re-Usable Bag, Metal, or VortisieveScreens and FiltersA common practice for the reduction of solidwaste from paint filtering is the use of re-usable rather than disposable filters.

11. Use of SandmillsInstead of ballmills, use sandmills for grind-ing and mixing ingredients. Sandmills aremore efficient and they require less solventfor cleaning. Also, by dedicating mills tospecific colors or color-ranges, less cleaningis required.

12. Scheduling From Light-to-Dark ProductsTo minimize the amount of cleaning neededbetween batches or similar formulations,milling is scheduled to start with light colorsand progress toward dark colors.

13. Dedicating EquipmentTo reduce the need for cleaning and thegeneration of wash solvent or wash water,equipment is dedicated to a particular productor family of products.

14. Wash the Tanks As They are Being�Let-Down�Paint can dry on the tank walls as the productis gradually transferred/pumped (let-down)into final packaging. Continuously washingthe tanks walls with solvent during let-downprevents the paint from drying on the tankwall and significantly reduces the solventneeded for cleaning when the tank is empty.The solvent is calculated to be incorporatedinto the final formulation.

15. Re-Work Wash Solvent and Wash WatersWash solvent and wash water is worked intofuture product formulations rather than beingdisposed.

16. Manually Cleaning TanksCleaning tanks manually with a wiper orsqueegee rather than solvents scored highlyon the survey and appears to be a commonpractice, but Ecology did not see that manymanufacturers actually doing this. It couldhave just been that site visits did not occurwhen tanks were being cleaned.

17. Solvent DistillationInstead of disposing of waste solvent, distillthe liquid for re-use. All the facilities aredistilling solvent; about half are distilling on-site, and the rest are sending solvent to off-site recyclers.

18. Maximize Batch SizeTo reduce clean-out waste, batch sizes aremaximized.


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Listed below are the P2 opportunities thatshould be considered �next steps.� This listing isbased both on survey results and observationsmade during the site visits:

Future P2 Opportunities for PaintManufacturers

1. Materials management2. Paint and coating manufacturer�s material

exchange3. High-pressure wash systems4. Wash water recirculation/filtration5. Counter-current rinsing6. �Shower caps�7. Reducing rework/off-spec coatings8. Testing raw materials9. Purchasing pre-dispersed pigments10. Re-using baghouse dust11. Increase automation12. Increase dedication of filling units13. Pre-determine re-work potential14. Totes for large volume customers15. Tanks with 1:1 diameter ratio16. Automated tank cleaner17. Employee incentives18. Laboratory and manufacturing personnel

rotations

Clarifying comments on each of theseopportunities is given below:

1.Materials Management and HousekeepingHousekeeping

During the site visits it became evident thathousekeeping was an important factor in reducingwastes. There was wide variability in how suc-cessful the different facilities were at maintainingan organized operation. The facilities with a focuson housekeeping and tracking were more orga-nized and efficient in managing their materials.

Housekeeping is how materials are handled,stored, and maintained at a facility, and is one ofthe easiest and most inexpensive ways to reducewaste, increase efficiency, and reduce liability.Some examples of good housekeeping are:

v Labeling and dating all containersv A management policy and actions that

maintain a well-organized facilityv Uniformity of practices (for formulating-

blending, cleanup, etc.)v Training for all employees on the estab-

lished practices and protocols of materials

management, including storage, cleanup,and handling of materials

v Good communication between workersv Routinely inspecting/checking the

facilityv Documenting plant operations with flow

diagrams and process specificationsv Establishing simple names/codes for

materials

For housekeeping to be successful, it mustbe the effort of the entire company. The efforts ofthe production team must be backed by a realcommitment by management.

Materials TrackingPaint and coating manufacturing involves

materials-intensive batch production processes.The ability to accurately and efficiently track andmanage raw materials inventories is a key tosuccessful production management. Most of themanufacturers visited use Batchmaster �software to track production and raw materialuse. Users were uniformly frustrated with theamount of effort required to use Batchmaster �data to generate hazardous waste and emissionsreports.

Ecology team members recognized theimportance and value that enhanced materialsmanagement capabilities would add to paint andcoating facility operations. However, Ecologydoes not at this time have the expertise to providethis type of technical assistance. As an alterna-tive, Ecology recommends that the manufacturerscontact environmental software companies thathave developed products with hazardous materi-als management capabilities and have theircurrent needs and existing materials managementsystems evaluated. A listing of these softwarecompanies is included in the vendor informationin Appendix F.

2. Paint and Coatings Manufacturer�sMaterial Exchange

A material exchange is a service that mostof the visited facilities thought would be useful.Through a materials exchange program, onemanufacturer could sell or give away unusedresins, pigments, and other raw materials toanother manufacturer for use as product. ThePollution Prevention Resource Center, an inde-pendent, not-for-profit organization in Seattle,has grant funding to provide technical assistanceto the paint and coatings industry, and is planningto assist NWPC in establishing a material ex-


change system in the Northwest, possibly inconjunction with King County�s Industrial Materi-als Exchange (IMEX). Ecology will providePPRC with appropriate support (see Section XII,Possible Technical Assistance Projects, for moreinformation).

3. High-Pressure Wash SystemsA potential future opportunity is to use

pressurized water to clean tanks. The pressureaffords mechanical energy that removes coatingproduct from the tank wall thus reducing thequantity of liquid required and waste liquidgenerated. One facility is successfully usingpressurized solvent and is considering a similarsystem for water, however, because of potentialfire hazard, we recommend consulting with thelocal fire officials before pursuing a pressurizedsolvent system.

Pressure wash equipment is available from anumber of vendors. Pressure wash systems whichinclude water recycling components are listed onthe �Thomas Register� Internet site under theheadings �water recycling� and �pressure washerwater recycling equipment� (see Appendix F forvendor listings).

4. Wash Water Recirculation/FiltrationThe concept here is to filter or centrifuge

wash water for continued re-use. Wash water isgenerated by the rinsing of tanks used to formu-late water-borne products, and rinsing raw mate-rial totes and containers. Though many facilitiesare able to successfully reincorporate the rinse/wash water into subsequent formulations, some-times the rate of washwater generation exceedsthe rate at which washwater can be reworked. Aclosed-loop, recirculating, pressurized washwatersystem could significantly reduce cleaning watergeneration and reduce water discharge or need tore-work wash water. Pressurized water is sprayedthrough a nozzle, used to rinse the container, andthe rinsate is collected in a reservoir. The rinsateis then filtered and transferred to the feed tank andis used again (see Appendix F for vendor listings).

5. Counter-Current RinsingCounter-current rinsing is the process of

matching a rinse solution to the rinse job, basedon the initial level of contamination in the solu-tion. In other words, using �dirty� (but not spent)solvent for first rinse, followed by a slightlycleaner solution for the second rinse, ending withfinal rinse of clean or virgin solvent. This methodsignificantly reduces the volume of solvent orwater needed for cleaning, and is particularlyeffective with at least three stages.

6. Shower Caps and Tank Covers�Shower cap� tank covers for covering in-

process tanks or tanks of product awaiting pack-aging, are available from a number of vendors(see Appendix F). These elasticized, disposablecovers fit a variety of tank sizes and are oftenused in conjunction with the standard plywoodlids. If a more customized or more durable coveris desired, there are many manufacturers ofcustom plastic and composite products. The�Thomas Register� Internet site lists many ofthese companies under the heading �tank covers.�

7. Reducing Re-work Materials Including Off-spec Coatings

Off-spec coatings and other re-workablematerials are a burden for paint manufacturers. Ittakes valuable time and attention to manageinventory and create opportunities to re-blendthese materials back into products. It is importantfor facilities to continue identifying causes of re-work materials and implementing solutions.Some causes of rework include: customer returnsof excess paint, mis-tints, bad batches, and out-of-date products.

Some ways manufacturers can reduce theamount of re-work materials are:

v selling or giving away part-gallonoverages to customers on custom prod-ucts

v selling or donating off-spec product tonon-profit organizations, schools, theatergroups, etc.

v not accepting customer returns on cus-tom-tinted products

v requiring customers to supply a substratesample with their color-match requests

v clearly indicating and highlightingformula changes

v quality control methods to reduce formu-lation mistakes

v providing employee training on customtinting procedures

v computer-supplemented tinting proce-dures

v good material tracking capabilities toidentify low-use stock items

v providing employee training on quantityestimation (to help customers accuratelycalculate amount of paint/coating neededfor a particular job).


8. Testing Raw MaterialsThis practice prevents off-spec material from

ruining product batches. Although testing rawmaterials before accepting from the supplier isalready being done successfully by some of thefacilities, at least five manufacturers indicated thiswas a potential future opportunity.

9. Purchasing Pre-Dispersed PigmentsThis practice reduces solvent waste gener-

ated from mill wash-out. A few facilities arepurchasing pre-dispersed pigments, however, thisremains a viable future opportunity for manyfacilities.

10. Re-Using Baghouse DustA few manufacturers are successfully

reincorporating baghouse dust into product, thuspreventing it from becoming waste. Dedicatingbaghouses and re-using baghouse dust in formula-tions is a potential future opportunity for somefacilities.

11. Increase AutomationAutomation tends to reduce wastes gener-

ated because of operator error. At least fourmanufacturers indicated that increasing automa-tion is a viable future P2 opportunity.

12. Increase Dedication of Filling UnitsIncreased dedication of filling units is a

potential opportunity for several facilities. Dedi-cating equipment to a particular product or line ofproducts reduces the need for cleaning solvent(clean less frequently and thoroughly).

13. Pre-Determine Re-Work PotentialA practice that several facilities indicated

could be a future opportunity is that laboratoryand management determine re-work potentialbefore releasing experimental products. Thisprevents the product from becoming waste shouldit fail to meet performance/quality criteria.

14. Totes for Large CustomersUsing totes for large customer orders

reduces packaging wastes and costs. Thoughsome facilities are providing totes for largecustomer orders, this is an area that many manu-facturers are working on and continues to affordopportunity.

15. Tanks With 1:1 Diameter to Height RatioDesigning tanks with a 1:1 diameter to

height ratio would reduce surface area to becleaned. While this was a high-scoring futureopportunity in Ecology�s survey, more compellingvariables determine tank dimensions such asmotor size, impeller diameter, efficiency ofmixing, and physical space constraints. Becauseof these limitations, Ecology doesn�t see this as abig future opportunity, but encourages facilities todo this where feasible.

16. Automated Tank CleanerThis is a viable future opportunity, particu-

larly when employee health impacts from manualtank cleaning are considered, but none of thefacilities were using such a device. This practicecould be particularly effective if pressurized washfluid (solvent or water) is used, thereby reducingthe amount of fluid needed per tank cleaning (seeAppendix F for vendor listings).

17. Employee incentivesSeveral manufacturers indicated that provid-

ing bonuses, rewards, or incentives for employeesto reduce wastes is a future reduction opportunity.This has a low implementation cost, but couldresult in significant reductions and encourageteamwork.

18. Laboratory and Manufacturing PersonnelRotations

Rotating laboratory personnel into manufac-turing positions, or vice versa, is a practice thatreceived a significant positive response frommanufacturers. A low-cost opportunity, rotatingpersonnel should be relatively easy to implement,yet have a positive impact on communicationsbetween laboratory and manufacturing personnel,and reduce batch-making errors and inconsisten-cies.


IVIVIVIVIV..... SOLID WASTE�SOLID WASTE�SOLID WASTE�SOLID WASTE�SOLID WASTE�visit rvisit rvisit rvisit rvisit resultsesultsesultsesultsesults, r, r, r, r, recommendaecommendaecommendaecommendaecommendations & rtions & rtions & rtions & rtions & resouresouresouresouresourcescescescesces

The major solid waste streams are drums(steel, plastic, and fiber), 5 gallon pails (metal andplastic), dry-ingredient paper bags, and woodpallets.

In general, solid waste streams can bereduced by switching to reusable packaging; usingpackaging which is recyclable; or minimizing theamount of packaging (i.e., designing more effi-cient containers). The following reusable contain-ers are in use at several facilities: Super Sacks -1000 & 2000 lb. sizes (manufactured by B.A.G.Corp. 800-331-9200), collapsible totes, andcardboard totes (330 gal. size). The cardboardtotes use disposable latex bladders/liners. Thecardboard can be recycled when the tote is nolonger usable.

A. DrA. DrA. DrA. DrA. DrumsumsumsumsumsMost facilities are recycling metal and

plastic drums through local vendors. The vendorsare charging $2 - 3 per drum and may require aminimum number of drums (e.g., 50) for pickupservice. Some steel or plastic drums may havedeposits (e.g., $25) associated with them or thevendor may have a leasing arrangement withregular customers. Fiber drums are less com-monly used and are being disposed as solid waste.If fiber drums are in use, encourage the supplier toswitch to reusable drums (metal or plastic) orreusable totes. Consult the vendor listings inAppendix F, King County�s IMEX catalogs (http://www.metrokc.gov/hazwaste/imex/), or call 1-800-RECYCLE for new contacts.

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Pails and paper ingredient bags are currentlybeing disposed by all facilities. Metal pails aredifficult to clean to the satisfaction of metalsrecyclers. Consult vendor listings in Appendix For call 1-800-RECYCLE. There are listings in theMay/June 1998 IMEX catalog (Wanted � Plastics/Rubber) for plastic pails. If pails are clean, ingood condition, and with handles, they might bedonated to paint retailers or thrift stores (Good-will, Salvation Army, etc.) for resale. There mayalso be a market for recycling HDPE buckets intopallets, new buckets, or other recycled contentplastic products. Investigate alternative packag-ing with your supplier. For recyclers of dry

ingredient bags, consult King County�s IMEXcatalog (http://www.metrokc.gov/hazwaste/imex),consult the listings in Appendix F, or call 1-800-RECYCLE and ask for recyclers of �mixedpaper.�

CCCCC. P. P. P. P. PalletsalletsalletsalletsalletsOnly a few facilities reported problems

when recycling pallets. These were due to lack ofa local vendor/pickup route or non-standard sizes.See listings in Appendix F, or King County�sIMEX listings under �Wanted � Wood/Paper�(http://www.metrokc.gov/hazwaste/imex/).


In general, Ecology did not witness substan-tial dangerous waste (DW) violations. ViolationsEcology would consider �significant� includesuch practices as spilled hazardous substancesthat are threatening health or environment,improper or illegal disposal, improper designationof wastes, and waste containers that are open,leaking, incompatible, or handled in a manner thatcould cause damage.

A. CorA. CorA. CorA. CorA. Corrrrrrections to Common Mistakections to Common Mistakections to Common Mistakections to Common Mistakections to Common MistakesesesesesThere were, however, a few areas that

require attention. These are listed below, alongwith a description of the correct practice accord-ing to the DW regulations:

v Accumulation tanks or containers forwaste solvents or paint sludge were leftopen or not tightly closed.

Correct Practice:A container holding dangerous wastemust always be closed, except when it isnecessary to add or remove waste (WAC173-303-630). In addition, tank systemsholding dangerous wastes which areacutely or chronically toxic by inhalationmust be designed to prevent escape ofvapors, fumes, or other emissions into theair (WAC 173-303-640).

v Some facilities had not establishedaccumulation areas for their dangerouswastes to be temporarily stored whilewaiting for final disposal.

Correct Practice:Dangerous waste must be stored in adesignated accumulation area beforebeing recycled or disposed of off-site.Designated dangerous waste accumula-tion areas must have a containmentsystem that is capable of collecting andholding spills and leaks (WAC 173-303-630(7)). In other words, you must have aspecial, clearly marked area for wastestorage, and this area must be able tocontain leaks and spills.

v Improper labeling of dangerous wastecontainers.

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Correct Practice:While being accumulated on site, eachcontainer or tank must be labeled ormarked clearly with the words �Danger-ous Waste� or �Hazardous Waste.� Thedate upon which each period of accumula-tion begins is also marked and clearlyvisible. (WAC 173-303-200(1))

v At one facility, dangerous wastes fromretail centers were being treated at themain manufacturing facility.

Correct Practice:Some paint manufacturers have localretail outlets that generate hazardouswastes. These retail outlets are typicallysmall quantity generators, and although itwould make sense for the manufacturer tohandle waste from it�s retail outlets, theproblem is that paint manufacturerstypically are not legally allowed to dothis. A facility must have a �RCRA PartB� permit before it can treat or recyclewaste generated from another location �in other words, you must be a permittedTreatment, Storage and Disposal facility.Therefore, the retail outlet must contractwith an off-site transporter/recycler, orhaul their wastes off-site to permittedwaste disposal facilities.

v At least two facilities had �dangerouswaste counting� problems (WAC 173-303-070).

Correct Practice:The correct counting of dangerous wastedetermines what size generator the facilityis (either a small, medium, or large-quantity generator). It can be confusingto know when to �count� a material ornot. See the following sections on washsolvent and wash water. Another goodresource is �Counting Dangerous WasteUnder the Dangerous Waste Regulations,August, 1998� (see Appendix G).

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The following paragraphs clarify specificsegments of dangerous waste regulations relevantto paint and coatings manufacturing.


1. Wash SolventIn most cases, spent wash solvent is a

dangerous waste (DW). Therefore, it must bemanaged in compliance with all the requirementsunder the State Dangerous Waste Regulations.

i. Total amount of spent solvent generatedfrom paint manufacturing process has tobe counted as DW, and included in theDangerous Waste Annual Report (WAC173-303-070).

ii. If spent solvent is immediately (i.e.,closed loop: hard-piped directly to distil-lation unit, no storage of waste solvent)recycled without accumulating, then thisamount is not counted or reported in theAnnual Report (WAC 173-303-070(7)(c)(iv)).

iii. If spent solvent is accumulated prior tooff-site recycling, then this accumulatedamount has to be counted and reported inthe Annual Report. This spent solvent canbe accumulated on-site no longer than 90days for large quantity generators or 180days for medium quantity generators.

If the spent solvent is recycled on-site(distillation), then waste is counted according tothe reference in Appendix G �Counting Danger-ous Waste Under the Dangerous WasteRegulations�(refer to counting discussion #5).Basically, you count one �batch� of waste permonth, plus still bottoms, plus make-up solvent(WAC 173-303-070(7)(d)(iii)).

2. Wash WaterBefore wash water is discharged, it must be

tested in accordance with the requirements underthe State Dangerous Waste Regulations (WAC173-303-090, and -100). If the wash waterdesignates as DW, the manufacturer has to followthe counting methods described above in the�Wash Solvent� section. There are some dis-charge options for wash water that may apply:

i. If wash water is not a DW, then the washwater can simply be discharged to sewersystem upon the local sewer district�sapproval.

ii. If wash water is a state-only waste orhighly diluted federal listed waste andtreatable by the local POTW, this washwater can be discharged to sewer systemby obtaining an appropriate permit issuedby the Department of Ecology or localsewer district (WAC 173-303-071(3)(a))(see Ecology Publication #94-136,Revised 6/97, Domestic Sewage Exclu-sion). This wash water is excluded from

DW counting requirements unless anytreatment is involved before discharge.

iii. If wash water is a characteristic waste, theDomestic Sewage Exclusion does notapply. This wash water has to be managedas DW. There may be treatment-by-generator options, such as elementaryneutralization or evaporation that apply(see Ecology Publication #96-412 �Treatment by Generator).

3. Returned Materials or Off-Spec Materialsi. If returned or off-spec materials designate

as DW, and are disposed of or reclaimedthrough appropriate treatment, thesematerials are DW. Therefore, thesematerials have to be managed as DW andaccumulated in a designated dangerouswaste accumulation area until disposed orreclaimed. Total amount of these materi-als has to be included in the AnnualReport (WAC 173-303-070). If thesematerials are donated as products to non-profit organizations or low-incomehousing, or through IMEX to be used as-is, the materials will be excluded fromDW counting requirements.

ii. If returned or off-spec materials are reusedin a manufacturing process without anytreatment involved, these materials are notDW (WAC 173-303-016).

4. Speculative AccumulationOff-spec paints, returned paints, and old or

off-spec raw materials are not DW if they arereworked back into product, provided that thesematerials are not reclaimed prior to reuse. In otherwords, the materials must be used/reworked as-is.Blending, filtering, and tinting do not constitutereclaiming. However, Ecology staff has comeacross materials that have been stored for severalyears without any attempt to use them. When thishappens, it is important to ask a series of ques-tions to decide if the materials are still useable orif they have become dangerous waste (see Ecol-ogy Hazardous Waste Shoptalk, Summer 1997,Vol. 7, No. 3 in Appendix H).

Generators must show that 75 percent of anaccumulated material has been legitimatelyrecycled over the course of a calendar year. If thisis not possible, the material becomes a solid wasteand possibly an illegally stored dangerous waste.All dangerous waste must be properly managedunder the conditions of the Dangerous WasteRegulations.


VI.VI.VI.VI.VI. ORPHAN WASTE�ORPHAN WASTE�ORPHAN WASTE�ORPHAN WASTE�ORPHAN WASTE�visit rvisit rvisit rvisit rvisit resultsesultsesultsesultsesults, r, r, r, r, recommendaecommendaecommendaecommendaecommendations &tions &tions &tions &tions & r r r r resouresouresouresouresourcescescescesces

Only one manufacturer reported a problem with clandestine dropping off or dumping of paint-related waste. Distributors and retail stores tend to have more occurrences of orphan waste. CountyModerate Risk Waste (MRW) paint collection programs have reduced the orphan waste problem inareas where they are in effect. Some preventative measures that can reduce such unwanted deliveriesinclude:

v Fencing the facility (particularly shipping & receiving areas);v Locking and/or screening the dumpsters;v Improving lighting;v Installing fake video cameras; andv Instituting a �returned goods� authorization procedure that allows return of products under

certain circumstances for exchange or partial refund may help.

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Minimal evidence of spills was observed during the site visits.

VIII.VIII.VIII.VIII.VIII. STSTSTSTSTORMWAORMWAORMWAORMWAORMWATER�TER�TER�TER�TER�visit rvisit rvisit rvisit rvisit resultsesultsesultsesultsesults, r, r, r, r, recommendaecommendaecommendaecommendaecommendations & rtions & rtions & rtions & rtions & resouresouresouresouresourcescescescesces

One of the potential environmental issuesexamined at each facility was the possibility ofintroducing pollutants to the environment throughthe storage of raw materials, products and wastesin outdoor, exposed areas. Spills, leaks ofproducts or waste exposed to rainfall can con-taminate stormwater that runs off the propertyand often drains directly to a surface water bodyor storm drain.

Industrial facilities with stormwater dis-charges to surface waters (including storm drains)are required to implement Best ManagementPractices (BMPs) to prevent pollution of surfacewaters or groundwater. A General IndustrialStormwater Permit from the Department ofEcology is required for industries with certainStandard Industrial Classification codes that storeraw materials, products or wastes outdoors.

Ecology noted several problems or potentialproblems related to stormwater protection duringthe site visits. Although several of the facilitiesvisited have a Stormwater Permit, the problemsnoted occurred both at facilities with and thosewithout a Stormwater Permit. The problemsinclude:

v Containers of liquid materials withunsecured lids that are exposed to therain and stored so that stormwater runoffhas direct access to a storm drain

v Solid wastes, raw materials and paintwastes stored outside and uncovered

v A fill pipe for an underground storagetank located adjacent to a storm drain

v Bulk raw material filling sites withoutspill containment and stormwater protec-tion

v Outdoor tote cleaning with the washwater going directly to the storm drain

The variety and extent of these problemscombined with the fact that problems are occur-ring at permitted facilities as well as those with-out a permit, indicates that the paint manufactur-ing industry needs some guidance and technicalassistance with stormwater management. Itwould be difficult, if not impossible, to ad-equately address these issues in a facility-specificmanner through this report. Rather than attemptto do so, Ecology has chosen to provide somebasic guidance on covering and containingmaterials stored outdoors (see below) andstrongly encourages facilities with any questionson stormwater management to contact Ecology�sstormwater compliance staff listed below.


A. CoA. CoA. CoA. CoA. Covvvvver and Containmenter and Containmenter and Containmenter and Containmenter and ContainmentTo prevent pollution from stormwater

runoff, industrial facilities should, at a minimum,follow these guidelines for materials storedoutdoors:

v Containers (including dumpsters) musthave covers or lids that are secured

v Loading and unloading areas and storageareas (including transfer areas for aboveand below ground tanks) must be de-signed to prevent run-on and run-off ofstormwater and containment of spills,i.e., secondary containment

v Liquids in drums or other containers mustbe stored in a lean-to (roofed) typestructure to prevent rainfall from reach-ing the drums

v Pallets or other materials must be storedin a lean-to (roofed) type structure orcovered with plastic sheeting to preventrainfall from reaching them

BBBBB. P. P. P. P. Permitted Fermitted Fermitted Fermitted Fermitted FacilitiesacilitiesacilitiesacilitiesacilitiesFacilities that currently have or are deter-

mined to need a Stormwater Permit must preparea Stormwater Pollution Prevention Plan thatidentifies potential sources for stormwaterpollution to be in compliance with the permit.This Plan includes development of Best Manage-ment Practices (BMPs) for source control andoperational activity to reduce or eliminate thosesources and an action plan that addresses spillresponse and clean up. In addition to the Coverand Containment guidelines listed above, BMPsfor stormwater management include pollutionsource control for:

3 Fueling stations3 Equipment cleaning3 Loading and unloading liquid materials3 Liquid storage in above-ground tanks

Ecology staff trained in stormwater manage-ment can provide assistance in the developmentof BMPs or the Stormwater Pollution PreventionPlan.

CCCCC. Ecology. Ecology. Ecology. Ecology. Ecology��s Stormws Stormws Stormws Stormws Stormwaaaaater Complianceter Complianceter Complianceter Complianceter ComplianceStafStafStafStafStaffffff

By taking the initiative to contactStormwater staff at Ecology you can be assuredthat you will get the help you need that is specificto your facility in a non-enforcement orientedenvironment. However, should a water qualityviolation from stormwater mismanagement belinked to your facility and you are not takingaction to correct the situation, an enforcementaction may result. Seeking assistance fromEcology to determine if there is a potentialproblem or to fix an existing problem will helpyou to avoid an enforcement action or a thirdparty lawsuit. Contact the Ecology staff person inyour region (see inside front cover for a regionalmap) if:

3 You are uncertain if your facility needs aStormwater Permit

3 Any of the issues listed above apply toyour facility

3 You have any questions about currentpractices and possible stormwater impactsat your facility even if your facilitycurrently has a Stormwater Permit

Northwest Regional OfficeBellevueRon Devitt (425) 649-7028Bob Newman (425) 649-7046Bob Wright (425) 649-7060

Southwest Regional OfficeOlympiaDick Schroeder (360) 407-6273

Eastern Regional OfficeSpokanePaul Turner (509) 625-5181

Central Regional OfficeYakimaSteve Huber (509) 454-7298


IX.IX.IX.IX.IX. AIR QUAIR QUAIR QUAIR QUAIR QUALITY�ALITY�ALITY�ALITY�ALITY�visit rvisit rvisit rvisit rvisit resultsesultsesultsesultsesults, r, r, r, r, recommendaecommendaecommendaecommendaecommendations & rtions & rtions & rtions & rtions & resouresouresouresouresourcescescescesces

Local air quality regulations require that operations and maintenance procedures be in place tominimize VOC emissions from mixing tanks while they are in service or being cleaned. The tanksmust have 90% of their rims covered while in use. All visited facilities had covers on their tanks.Mechanical scraping prior to rinsing reduces the amount of wash solvent (or wash water) used. Mostfacilities have a clean-as-you-go policy (immediate cleaning). The use of epoxy-lined tanks to reduceadhesion is very effective for water-borne products, but the durability of epoxy coatings when exposedto solvent-based products is an issue. In a number of facilities, baghouses collect dust which may berecycled into future batches. Existing practices can be improved by assuring that tanks remain coveredafter mixing and prior to transfer of product to shipping containers. Use of durable materials for coverfabrication will help insure a tight fit to the tank. (One facility was using cardboard tank covers�which is not advisable.) Use of plastic �shower cap� covers (see Section III.B.6 of this report) will alsohelp minimize VOC emissions.

X.X.X.X.X. ADDITIONADDITIONADDITIONADDITIONADDITIONAL ISSUES�AL ISSUES�AL ISSUES�AL ISSUES�AL ISSUES�visit rvisit rvisit rvisit rvisit resultsesultsesultsesultsesults, r, r, r, r, recommendaecommendaecommendaecommendaecommendations &tions &tions &tions &tions &rrrrresouresouresouresouresourcescescescesces

Besides the pollution prevention and envi-ronmental compliance arenas covered in thesections above, Ecology investigated a number ofother topics. These are detailed in the subsectionsbelow.

A. PA. PA. PA. PA. Paint Distribaint Distribaint Distribaint Distribaint DistributeruteruteruterutersssssPaint manufacturers market directly to

original equipment manufacturers, industrialaccounts, agricultural accounts, and contractors.Some market through their own distributioncenters or retail stores or through regional inde-pendent distributors, via the independent�s retailstores. One manufacturer sells directly to thegeneral public. Export markets make up a signifi-cant portion of sales for several manufacturers.

Wastes are generated at the distribution levelfrom custom tint returns, spray equipment rentaland cleanup, and routine brush or containercleaning. These wastes include wash water, washsolvent, off-spec or mistinted paint, and rags.Technical assistance on pollution prevention andwaste management practices for distributors andcontractors are being considered for an up-comingtechnical assistance project. The NWPC feltdistributors should be addressed in conjunctionwith contractors

BBBBB. P. P. P. P. Paint Raint Raint Raint Raint RecececececyyyyyccccclinglinglinglinglingDuring initial project scoping, Ecology was

interested in the links between paint and coatingmanufacturers and painting contractors. One suchlink is waste paint. Because a key wastestreamfor contractors is leftover paint, Ecology wascurious to assess the manufacturer�s ability to

recycle this paint back into useable product. Apilot project in Portland, OR and surroundingareas is providing paint recycling services tohomeowners through a selection of local paintdistributors with some success. However, region-wide, organized paint recycling for contractors (amuch larger undertaking than homeowner waste)is a remarkably complex issue and developing anysuch system is beyond the scope of this project.

Most manufacturers prefer not to recycletheir customer�s paint, but will do so on a case-by-case basis in order to maintain positive cus-tomer relationships. Seven of the eleven manu-facturers visited indicated they recycle paintreturned by their customers. Such returns may bethe result of paint ordered in excess of actualneed, �mistints.� or quality problems. The paintis recycled by:

3 Reworking of paint for resale as anotherproduct

3 Reworking for resale or donation to lowincome housing projects or schools

Those manufacturers who did not recyclecustomer paint cited the following barriers torecycling:

7 Short pot-life or shelf-life products7 Colors that are hard to convert7 Materials mixed with dissimilar products7 Belief that partially used product must be

handled as dangerous waste


CCCCC. Measuring En. Measuring En. Measuring En. Measuring En. Measuring Envirvirvirvirvironmental Successonmental Successonmental Successonmental Successonmental SuccessMeasuring reductions in environmental

impact helps a facility determine the effectivenessof their pollution reduction efforts. During thesite visits, companies reported a variety ofmethods used to measure environmental success.The list below addresses a number of differentenvironmental facets, and Ecology encouragesmanufacturers to track as many of these variablesas appropriate:

3 Reduction in amount of toxic ingredientsused

3 Increase in amounts recycled3 Increase in amounts of water-based

coatings produced3 Compliance with federal VOC standards3 Reduction in amount of hazardous waste

shipped off-site3 Success in implementing pollution

prevention opportunities identified intheir pollution prevention plan

3 Amount of solid waste reduced3 Reduction in pounds of waste or emis-

sions per gallons manufactured

DDDDD. Internet Use. Internet Use. Internet Use. Internet Use. Internet UseFive of the eleven facilities visited had

connections to the Internet; an additional facilitywas planning to connect soon. Two other facilitymanagers used the Internet at home. One facilityhas its own website; another was planning to haveone on-line soon.

Three facilities had accessed the Departmentof Ecology website in the past. Another uses theNational Paint and Coating Association website.

E.E.E.E.E. PrPrPrPrPrefefefefeferererererrrrrred Fed Fed Fed Fed Forms oforms oforms oforms oforms of T T T T TececececechnicalhnicalhnicalhnicalhnicalAssistanceAssistanceAssistanceAssistanceAssistance

During the site visits Ecology askedmanufacturer�s their preferences for differentforms of technical assistance. The most preferreditems were checklists, case studies, and informa-tion on a web page. Manufacturers also indicateda preference for site visits. Workshops, pam-phlets, and E-mail were the least desirable formsof assistance.


XI.XI.XI.XI.XI. MEASURING PMEASURING PMEASURING PMEASURING PMEASURING PAINT & COAINT & COAINT & COAINT & COAINT & COAAAAATINGS SECTTINGS SECTTINGS SECTTINGS SECTTINGS SECTOR�OR�OR�OR�OR�PROJECT SUCCESSPROJECT SUCCESSPROJECT SUCCESSPROJECT SUCCESSPROJECT SUCCESS

The project mission statement articulates the desire to achieve �measurable reductions in materialconsumption, toxicity, and/or releases� (�releases� refers to wastes, emissions, discharges). Obtainingnumerical data on actual reductions has historically been a remarkably challenging undertaking.

One way to measure whether this project achieved such reductions would be to conduct a surveyin the first half of year 2000 to determine what activities manufacturers implemented as a result of thisassistance project and then estimate the numerical reductions these activities amounted to. If numericalestimates are too difficult to come up with, Ecology could measure the number of P2 opportunitiesimplemented (behavior changes) within the year. The survey must be �low-impact;� in other words,Ecology must be sensitive to the paperwork burden to the industry. It may be possible to link datacollection to Pollution Prevention Annual Reporting requirements already in place.

Other goals of the project were to provide �excellent� service to the industry and to craft projectelements that were supported by both industry and Ecology. These goals could also be measured bysome form of a survey.

XII.XII.XII.XII.XII. POSSIBLE TECHNICAL ASSISTPOSSIBLE TECHNICAL ASSISTPOSSIBLE TECHNICAL ASSISTPOSSIBLE TECHNICAL ASSISTPOSSIBLE TECHNICAL ASSISTANCE PROJECTS BYANCE PROJECTS BYANCE PROJECTS BYANCE PROJECTS BYANCE PROJECTS BYECOLECOLECOLECOLECOLOGYOGYOGYOGYOGY

The five projects/services described belowemerged as needing resources beyond this phaseof the project. They are presented below forEcology management�s review and for review bythe NW Paint Council. We will collaborativelymake the decision which items to move forwardon. The Ecology Paint Sector Team recommendsthat items A-D be implemented, and that item Ebe evaluated with the industry.

A. Paint & Coatings Manufacturer�sMaterials Exchange

The concept here, as mentioned earlier inthe report, is to create a materials exchangespecific to the paint/coatings manufacturingindustry to promote off-spec material re-use. Atthis point, the Pollution Prevention ResourceCenter (PPRC) in Seattle has agreed to be lead onthis project/service. However, the success of thiseffort will hinge on the active participation of theNorthwest Paint Council and its members. Theproject should also be coordinated with theSeattle-King County IMEX (industrial materialsexchange) service.

Ecology should provide PPRC some supportsuch as project review regarding DW rules, typesof information listed, and exchange design, aswell as perhaps helping the NW Paint Councilmarket the exchange service to non-paint-councilmembers in Washington and Oregon.

Benefits: 1) Insure product quality2) Increased membership will likelydivert more �waste� material3) Increased membership will make thematerial exchange more viable

Budget: 50 hours

B. Paint and Coatings Manufacturer�sEnvironmental WebSite

Eight of eleven facility managers said theywould be interested in a paint manufacturers�website. Some of the information these managersindicated would be valuable to them are:

3 Links to the National Painting andCoatings Association, environmentalregulations, waste exchanges

3 Case studies of pollution prevention forpaint manufacturers

3 Pollution prevention methods for paintmanufacturers

3 Ability to ask questions and share an-swers

3 Short checklist of �To Do�s� for custom-ers


Other possible website features:3 Copy of this report3 Summaries of P2 opportunities, BMPs,

O+M procedures3 Connection to Envirosense and paint

manufacturer�s sites3 Information on electronic reporting of

environmental data3 Links to other related sites: e.g., chemical

toxicology information for evaluatingproduct ingredients

The PPRC is lead on this project as well �they have grant funding for this specific purpose.Ecology should support this effort by providingmaterials and results from the Paint Sector Projectsuch as the complete P2 opportunities table,compliance issue summaries, photos of P2 prac-tices, an electronic version of the Paint SectorProject Report, etc. Ecology probably should alsoprovide some website feedback and �designreview.� Provide long-term on-going support andfeedback (e.g., 2 hours per month).

Benefits: 1) Increased (nation-wide, globalactually) distribution/impact of informa-tion gained in the Paint Sector Project2) Insure product quality

Budget: 60 - 80 hours

C. In-House Ecology Compliance InspectorBriefings

The intent of this option is to communicatethe project P2 and DW compliance findings withEcology�s DW compliance staff in order to shareknowledge and promote consistency within in theagency. Given the small number of paint manu-facturing facilities in the state and the availabilityof this sector report, it is recommended that eachPaint Sector Team member provide a short (anhour or less) briefing to the compliance staff intheir regional office highlighting salient aspects ofour findings.

We also recommend that the report be madeavailable electronically via a Paint and CoatingsManufacturing page of Ecology�s internal �P2Toolbox� (\\hwp_hqf3\apps\P2\P2REFS2.HTM).The page should include:7 Executive Summary of this report7 Links to PPRC�s Paint and Coatings Manufac-

turing website7 Top compliance issues and P2 opportunities to

look for:

Benefits: 1) Statewide consistency in applyingand implementing regulations as theyapply to this sector (improved publicperception of Ecology)2) Promoting P2 in this industry via theinspectors3) Provide consistency and communi-cation between Toxics Reduction staffand compliance inspectors

Budget: 4 briefings at 1 hour each = 4 hours

D. Technical Assistance Visits to RemainingManufacturers

An effective way to provide consistenttechnical assistance and promote a �level playingfield� to the industry, statewide, would be toconduct site visits to the remaining 10 paintmanufacturers. There would be environmentaland business benefit to offering this service.Ecology�s concern is the resources necessary toprovide quality visits.

Like the survey visits, these would be�voluntary,� but Ecology would be activelypromoting and scheduling. Ecology should takethe time to cover pollution prevention and compli-ance items in some detail, thus the visits willprobably take 2-3 hours each. Because of theamount of information to cover, it would probablybe most effective for teams of two to conduct thevisits.

Benefits: 1) P2 and compliance informationdelivered consistently2) Whole industry will have beeninformed statewide3) Industry prefers hands-on site visitmode of info-transfer = quality ofservice4) Gain support for the materialsexchange and for the PPRC website

Budget: Site visit preparation/logistics = 80hours10 sites x 2 people x 5 hours/site = 100hoursSite visit follow-up: 11 x 3 hours = 33hours

TOTAL 200 � 300 hours


E. Information Transfer to ProductionStaff

Ecology has some concern that the informa-tion and resources contained in this report beaccessible to manufacturing-level employees.Once this report is distributed to the manufactur-ers, Ecology should ask the manufacturers if itwould be helpful to have information in anotherform for line-staff (e.g., one-page fact sheets onwaste compliance do�s and don�ts, a fact sheet onre-work reduction, or a summary of top P2options, etc.). We need industry interest andsupport to make this project worthwhile and todefine the scope of this effort.

Benefits: 1) Promote further understanding andimplementation of P22) Increase effectiveness of the project

Budget: 70 � 100 hours


APPENDIX A

PPPPPAINT AND COAINT AND COAINT AND COAINT AND COAINT AND COAAAAATINGS MANUFTINGS MANUFTINGS MANUFTINGS MANUFTINGS MANUFAAAAACTURERS CTURERS CTURERS CTURERS CTURERS IN IN IN IN IN WASHINGTWASHINGTWASHINGTWASHINGTWASHINGTON STON STON STON STON STAAAAATETETETETE

Manufacturer Name Location

Asahipen America Seattle

Best Paint Seattle

Cook Composites and Polymers Arlington

C & C Paint Seattle

Daly�s Inc. Seattle

Daniel Boone Tukwila

Eco Chemical Inc. Seattle

Farwest Paint Mfg. Co. Tukwila

Gaco Western Tukwila

Kelly-Moore/Preservative Paint Seattle

Lilly Industries Seattle

Rudd Company Seattle

System 3 Resins Seattle

Wasser High-Tech Coatings Seattle

Perfection-Letz Kennewick

Columbia Paint Spokane

United Paint Mfg. Greenacres

Burke/Cascade Washougal

Parker Paint Mfg. Co. Tacoma

Appendix A


APPENDIX B

SurSurSurSurSurvvvvveeeeey Fy Fy Fy Fy Forms: Compliance Checorms: Compliance Checorms: Compliance Checorms: Compliance Checorms: Compliance Checkkkkklist and Supplemental Questionslist and Supplemental Questionslist and Supplemental Questionslist and Supplemental Questionslist and Supplemental Questions

Compliance Indicator Checklist

FACILITY:_____________________________Recorder:_______________________________ Date:__________________

Violation >>> If you see�. Examples References com-ments

Spills or WAC 173- Hazardous substances Dip tank solution Spills NotificationDischarges 303-145(3) or wastes spilled AND flowing to storm FOCUS sheet, 8/92.

threatens health or drain. Leaking Small Spillenvironment, AND no drum of paint Cleanup Guidance,or inadequate mitigation/ waste on bare soil. 6/95control.

Improper/ -141(1) or DW not offered to TSDR, DW in dumpster. HW Services Dir,Illegal -150, or illegal disposal of DW; division, Mixing used oil 12/94Disposal -950(2) dilution, or accumulation with carb cleaner. ShopTalk, Spring,

to evade DW requirements. 1997.Product or HW?

Designation -170(1)(a) & Wastes are generated and What�s this purple-070 treated, stored, disposed or stuff in the drum?

recycled without designation, �I don�t know�.or without following proper Sand blast grit usedprotocols. as fill.

Container -200(1)(b) & DW in containers that leak or Wet & deterioratingManagement -630(2) in poor condition. fiber drum holding

DW. Bulging drum ofpaint waste.

-200(1)(b) &-630(4) Container or liner holding DW Corrosive DW in

is not compatible with the unlined fiber drum.hazards presented.

-200(1)(b) & Container holding DW is not Any open container-630(5)(a) kept closed. of DW.

-200(1)(b) & Container holding DW is Haphazard stacking of-630(5)(b) opened, handled or stored in a containers of DW.

manner that may causeruptures or leaks.

Appendix B


SUPPLEMENTSUPPLEMENTSUPPLEMENTSUPPLEMENTSUPPLEMENTAL SURAL SURAL SURAL SURAL SURVEY QUESTIONSVEY QUESTIONSVEY QUESTIONSVEY QUESTIONSVEY QUESTIONSMarch 1998

1.) Pollution Prevention Table of Opportunities2.) Compliance Indicator Checklist

3.) Distributors: how is paint distributed, what are the levels and functions of distribution? How might wastebe generated at the distribution facilities (and how much)?

4A.) Paint Recycling: In-House (what are current paint recycling practices, what works, what are some prob-lems?)

4B.) Paint Recycling: External (is customer paint waste being recycled, what are the opportunities and barriersto customer paint waste recycling?)

5.) Solid Waste: What types and quantities of solid waste are being generated? What are the problems regarding solid waste reduction or recycling? Recycling/ disposal costs?

6.) Orphan Waste: What types and quantities of orphan waste have been received? What is the cost of han-dling these wastes? How might they be prevented?

7.) Solvent Recycling/ Waste Counting: What is average still batch size? How many batches per month?What is waste amount reported on Dangerous Waste Report?

8.) How does facility measure their environmental success?

9.) We would like to document �current/ conventional�, �good�, and �best� practices, for educational purposes.Do we have your permission to take photos? (Verbal permission or signature).

10.) Air: (list top three APCA concerns)

a. Mixing Tanks must have 90% of rim covered?b. Minimize VOC emissions while cleaning tanks?c. Have O+M procedures for cleaning/ using tanks?

11.) Cleanup/ Spills (any evidence of spills outside?):

12.) Stormwater � Are they storing �product�, materials, or machinery outdoors � exposed to rain? If so, theyneed a permit. If not, they don�t need a permit.

13.) Domestic sewage exclusion � Discharging wastestream into sewer? If so, has this wastestream been desig-nated? If its DW, then need a specific permit.


14.) NPDES permit? Any discharge to water body? (unlikely for this industry�)

15.) Treatment by Generator (describe)

16.) Website Information4 Do you currently have access to the Internet?4 Have you ever accessed Ecology�s Web page?4 Would you be interested in a Paint Sector Web page?4 What kinds of information would need to be on the Web page to make it meaningful to you?

Examples:P2 Opportunities for Paint ManufacturingCase Studies of Best Management PracticesLinks to Paint Associations, Equipment Vendors, or Other P2 Sites

17.) What form of technical assistance would the facility use/prefer:ChecklistsPamphetsSite VisitsWorkshopsCase StudiesInformation provided over the Internet via E-mailInformation from a Web Page

18.) (optional) Trade Journal subscriptions:Association Memberships: (NWPC, other?)Internet Listserves:

19.) (optional) Additional Research Needs:

20.) Production DataProduct mix: architectural, industrial, etc.

# of gallons produced in 1997:

# of gallons or % solvent-based product:

# of gallons of % water-based product:

21.) How are materials tracked? (especially residues, leftovers, off-spec materials, etc.)

Appendix B

Paint and C

oatings Manufacturing Sector P

roject29

ProductFormulation

Hazardous Chemicalsand Pigments

Eliminate chromium compounds (e.g.sodium chromate)

12 0 1 Viable alternatives have been available for thelast few years (e.g. metaborate for rust,organics for color).

ProductFormulation


Eliminate lead driers and colorants 13 0 2 Virtually eliminated industry-wide. Less than0.06% lead required by federal law.

ProductFormulation


Eliminate xylene 7 1 3 Alternatives are alcohols or methylene amylketone but chemical substitution is customerdriven.

ProductFormulation


Eliminate ethyl benzene 7 0 0 Many facilities able to eliminate.

ProductFormulation


Eliminate methylene chloride 10 0 2 Many facilities able to eliminate. Still used insome aerosol products.

ProductFormulation


Eliminate ethylene glycol 5 2 5 Alternatives still being developed. Used inwaterborne paints. Partial success replacingwith propylene glycol which is less toxic.

ProductFormulation


Eliminate n-butyl alcohol 5 0 4 Limited success eliminating it. Less commoningredient.

ProductFormulation


Eliminate toluene 5 1 4 Some companies have successfully eliminatedtheir toluene use. Substitutes still beingdeveloped.

ProductFormulation


Eliminate mercury-based bactericides 14 0 0 Basically eliminated industry-wide. Alternativeshave been available for at least 10 years.

ProductFormulation


Eliminate crystalline silica 6 1 1 Switch to non-crystalline silica. Crystalline silicais an inhalation hazard to paint workers.

ProductFormulation


Eliminate zinc 4 2 1 Carefully evaluate, some alternatives are morehazardous. Zinc is used mainly in primers.

ProductFormulation


Eliminate methanol 1 1 3 Hard to eliminate because they are used inwaterborne paints and lacquers as substitutesfor aromatic solvents.

ProductFormulation


Eliminate MEK 1 2 3 Alternatives are available. Used mainly inlacquers.

ProductFormulation


Eliminate ammonia 0 1 3 No apparent success in eliminating it. Ammoniais a key ingredient in many waterbornecoatings.

ProductFormulation


Reformulate solvent-based productsinto water-based products

14 0 0 Nearly all facilities are doing this, but limited bymarket acceptance. Waterborne paints shouldbe aggressively marketed as replacements tosolvent based coatings.

ProductFormulation


Reformulate into U.V. cured products 2 1 2 Some coating manufacturers are currentlyresearching this option. May not be viable forcertain applications.

The P2 survey results are tabulated from 18 data sets (11 site visits and 7 surveys). The list of P2 opportunities was modified after the initial surveys.

Therefore some options were added and combined in the list. The opportunities are classified by three columns: Yes, No and Maybe. The �yes� column

indicates the number of facilities currently implementing the opportunity. The �no� column indicates the number of facilities that are not implementing the

opportunity and have tried it in the past. Lastly, the �maybe� column denotes possible or future opportunities that a facility is considering to implement.

Waste/SubstanceProcess Reduced Reduction Method Yes No Maybe Comments

AP

PE

ND

IX C

�P

OL

LUT

ION

PR

EV

EN

TIO

N R

ES

ULT

S

Appendix C

30W

ashington State Departm

ent of Ecology

ProductFormulation


Reformulate into powder coatings 2 2 0 Limited to very specific applications (primarilyfor metal substrates).

ProductFormulation


Reformulate into high-solidsformulations

13 0 2 Market driven.

New ProductInitiation

Off-Spec Product Laboratory and managementcoordinate efforts to determine re-workpotential before releasing experimentalproducts

8 0 5 Several facilities trying to do this. Importantduring the development of new coatings.

New ProductInitiation

Off-Spec Product Formulator works with paintmaker whenmanufacturing a new product for thefirst time

15 0 0 Common practice.

InventoryManagement

Raw Materials Establish a centralized purchasingprogram

13 1 1 Fairly common practice; though an opportunityfor some.

InventoryManagement

Raw Materials Use improved inventory managementpractices

16 0 1 Valid opportunity for most facilities - materialsmanagement and housekeeping. Ongoingpotential for improvement.

InventoryManagement

Raw Materials Test raw materials before acceptingfrom supplier. (Send product samplesback to vendors to avoid disposal aswaste.)

6 2 5 Some success with this. Usually done onselected raw materials.

InventoryManagement

Raw Materials Use “just-in-time” inventory control 12 1 2 "Just-in-time" inventory means matchingarriving shipments of materials tomanufacturing schedule. Minimizes shelf timefor feedstocks. Many facilities have limitedstorage space and can not stock excessmaterials.

InventoryManagement

Raw Materials Use containers with removable liner 10 0 5 Mixed success with liners. Some dissolve insolvent.

InventoryManagement

Raw Materials Inspect packaging for tears, repairimmediately

11 1 1 Alleged common practice. Reduces materialloss due to spills.

InventoryManagement

Raw Materials Simplify inventory, combine andstandardize where possible

14 0 1 Fairly common practice. Reduces human errorand the number of ingredients being used.

InventoryManagement

Raw Materials Certification program for raw materialsuppliers

8 1 5 Some facilities successful with this (e.g. pre-approved/certified vendors for selected rawmaterials , or require "certificate of analysis"before shipment.

InventoryManagement

Raw Materials Sell or give away obsolete rawmaterials for re-use (e.g. tomanufacturers, wholesalers or throughmaterial exchange).

12 1 2 Or, if possible, return to vendor.


Paint and C


roject31


UnloadingMaterials intoMixing Tanks

Spilled Raw Materials Prevent tanks from overfilling (e.g. byinstalling high-level cutoff and flowtotalizers with cutoff).

3 0 8 Most facilities rely on operator observation.Sometimes filling hose contains check-valve.One facility uses "programmable" meters. Onefacility actually has cutoff and alarm on bulksolvent tanks.

InventoryManagement

Packaging / Solid Waste Purchase pre-weighed hazardousingredients or design formulas to usewhole bags whenever possible.

6 2 4 Some facilities doings this. Must negotiate withsupplier and customer. Try to design formula tonearest full-bag.

InventoryManagement

Packaging / Solid Waste Use packaging that can be sent back tosupplier (e.g. recyclable or reusabledrums)

12 0 3 Many facilities are using some recyclabledrums; must negotiate with suppliers. Sporadicsuccess.

InventoryManagement

Packaging / Solid Waste Order common materials in bulk toreduce packaging.

For example use super sacks for bulkquantities of dry pigments instead of paperbags or totes / tanks for liquids.


Pigment Dusts Use pigments in slurry/paste form 5 1 7


Pigment Dusts Re-use baghouse pigment dust (e.g.Install dedicated baghouse systems)

12 0 2 Some manufacturers doing this successfully.May not work with transparent products.

Production(Grinding,mixing, blending)

Excess Product Sell or give away part-gallon overagesto customers on custom products

12 1 3 for example, have verbal agreement withcustomer to accept up to 10% overage.


Off-Spec Product /Excess Product

Sell or offer off-spec product or excessproduct to non-profit organizations,schools, theater groups, or IMEX.

14 2 1 Fairly common practice.


Off-Spec Product Blend into new products 17 0 0 Very important. An inventory system shouldtrack off-spec material and be included onbatch tickets.


Off-Spec Product Test batch formulation in lab beforegoing to manufacture.

14 0 0 Standard operating practice for most paintmanufacturers.


Off-Spec Product No returns on custom-tinted products 13 2 1 Most trying to do this, but strongly depends oncustomer relationship.

Appendix C

32W


ent of Ecology


Off-Spec Product Have customers supply a substratesample with their color-match requests

13 1 2 Common practice. Another option, havecustomer test a small amount before ordering.


Off-Spec Product Laboratory use brush-out and draw-down sample methods instead of usingspray equipment

16 0 0 Standard practice.


Off-Spec Product Clearly indicate or highlight formulachanges

15 0 0 Reduces human error. Standard practice.


Off-Spec Product Install timers on mixing tubs to preventovermixing and reduce adjustment withadditional raw material

3 2 6 Potentially viable for select manufacturers.Usually checked by paint maker duringblending/grinding. Most mixing isn’t time-based,it’s quality-based.


Spills Increase use of automation 6 1 4 Effectiveness increases with increasingproduction.


Spills Recycle as much of spill into product aspossible

15 0 1 Common practice


Spills Clean remaining spill with dry methods(not with water or solvent)

12 0 1 Common practice. Valid option after recyclingas much of the spill as possible (See aboveoption).


Spills Purge pipelines before disconnecting. Standard practice. One facility uses air valve toflush lines.


Solvent Evaporation Cover all vessels with lids and covers 18 0 0 Standard practice, but must be rigorouslyenforced. Plastic covers (shower caps) are anexcellent first layer.

Milling Wash Solvent Change from ballmill to disperser, don’thave to use as much solvent to clean-out

9 0 2 Ballmills generally obsolete. Sandmills anddispersers are common practices.

Milling Wash Solvent Schedule milling from light to darkcolors



Paint and C


roject33

Milling Wash Solvent Dedicate a mill for light and brightcolors


Milling Wash Solvent Install more efficient mills that do notrequire multi-pass dispersions

6 0 4 Potential opportunity for some manufacturers.Alternative: purchase pre-milledpigments/colorants that meet yourspecifications.

Filtering Spent Filters Use as small a cartridge as possible 3 1 2Filtering Spent Filters Use reusable bag or metal mesh filters

(e.g. vortisieve screens).16 0 0 Common practice.

Filtering Spent Filters Clean out filters regularly (or use self-cleaning filter system)

10 0 2 One paint manufacturer uses a self-cleaningsystem (Roninger-Pedingter filter system) thatavoids the use of filter bags. This system paidfor itself in a year. The captured solids arerecycled into later batches.

Filtering Spent Filters Improve pigment dispersion to reducelumps

12 0 1 Many manufacturers working on this.

ProductPackaging

Wash Solvent Increase dedication of filling units 4 1 6 Potential future opportunity.

ProductPackaging

Waste Drums andBarrels

Provide totes to customers with largeorders

10 0 4 Some totes can be used up to 3 to 4 dozentimes. Fairly common practice whereapplicable. Some contractors may not haveequipment needed to handle totes.

ProductPackaging

Solid Waste Purchasing raw materials in totes &bulk to reduce drum use

10 0 0 Common practice, done where possible. Stillbeing developed.

ProductPackaging

Solid Waste Can crusher to crush cans to EPArecyclable standard

3 0 3 A few facilities use can crushers. Severalinvestigating the option.

EquipmentCleaning

Wash Solvent/Water Maximize batch size to reduce clean-out waste


EquipmentCleaning

Wash Solvent/Water Dedicate equipment to single productor family of products to reduce need forcleaning

10 0 3 Separate lines for water and solvent products isstandard practice. Additional dedication beingdone by several facilities and is a future optionfor some.

EquipmentCleaning

Wash Solvent/Water Schedule production to minimize needfor cleaning: (e.g. light to dark colors,similar formulations)

10 0 2 Not only will this reduce the amount of solventneeded to wash the tanks but wash solventcan then be incorporated or used as feed stockin the next batch.

EquipmentCleaning

Wash Solvent/Water Re-use equipment cleaning wastes:collect wash solvent/ water and use innext compatible batch of paint as partof formulation

15 0 0 Common practice to extent possible. Onemanufacturer evaporates excess washwater.Key is to use the minimum of water/solventrequired for the job.


Appendix C

34W


ent of Ecology

EquipmentCleaning

Wash Solvent/Water Clean equipment immediately beforepaint dries. (Prevent paint from dryingin tanks.)

16 0 0 Important practice. Usually a standardoperating procedure, but it must be continuallystressed.

EquipmentCleaning

Wash Solvent/Water Use high-pressure wash systems andefficient nozzles

7 3 3 One facility successfully uses high pressuresolvent wash to clean tanks. Potential future formany facilities.

EquipmentCleaning

Wash Solvent/Water Mechanically clean with squeegees orwiper blades before washing tanks

12 0 3 Common practice. High impact in reducingsolvent wash.

EquipmentCleaning

Wash Solvent/Water Use non stick tanks (e.g. stainlesssteel, or lined with Teflon or epoxy)

4 3 5 Valid opportunity - but proceed with caution,mixed reports from site-visits !! Liner coatingsneed annual maintenance. Epoxy lining onlyworked for water-borne products. Coating lostadhesion due to penetration by solvent insolvent-based formulations. United Coatingsmade a tank coating from isocyanates & epoxy;in use 5 yrs. Costs $50/gal.

EquipmentCleaning

Wash Solvent/Water Use foam or plastic “pigs” to clean outlines

0 5 6 Caution: pigs have a tendency to get stuck inpipes especially where the lines bend. (Betterto dedicate lines - don't need as muchcleaning.)

EquipmentCleaning

Wash Solvent/Water Purge lines with compressed air/gas Reduces need for solvent wash.

EquipmentCleaning

Wash Solvent/Water Collect solvent and re-distill (on or off-site)

7 2 4 About half the manufacturers distill on site.Some facilities are able to re-work ALL theirwash solvent!

EquipmentCleaning

Wash Solvent/Water Use still bottoms in formulation ofproduct

3 4 4 A challenging opportunity. One company hasbeen able to use still bottoms in the formulationof its primers.

EquipmentCleaning

Wash Solvent/Water Use counter-current rinse methods(First wash with dirty solvent, then rinsewith clean)

7 0 4 Several facilities doing this with wash solvent.Less common with water which is noteconomical.

EquipmentCleaning

Wash Solvent/Water Increase spent rinse settling time oruse de-emulsifiers on spent rinses forcontinued use.

6 1 3 The objective of increasing the settling time isto allow solids to fall to the bottom of thesolvent container, allowing the top fraction ofthe solvent to be reused.

EquipmentCleaning

Wash Solvent/Water Filter or centrifuge wash water so it canbe reused (esp. for tote washing)

0 1 5 Valid opportunity - filtering and re-usingwashwater (not sludge) could be a good wayto reduce washwater consumption andgeneration.

EquipmentCleaning

Wash Solvent/Water Design tanks with length-to-diameterratio of 1:1 (minimizes surface area tobe washed per batch)

2 0 6 Should be one of the design criteria for newtanks, however, many other factors areinvolved.


Paint and C


roject35


EquipmentCleaning

Wash Solvent/Water Automated tank cleaners 1 1 4 Negative comments are that automated tankcleaners are too expensive and require toomuch space. Remains a future opportunity.

EquipmentCleaning

Wash Solvent/Water "Clean as you go" policy - rigorouslyenforced

7 0 1 Common practice, need reminders. One of themost successful waste elimination procedures.

EquipmentMaintenance,Testing

Waste Solvent Use abrasive blasting for removingpaint on equipment.

5 1 4 A few manufacturers doing this, severalconsider it a future opportunity.


Waste Solvent Use needle gun for removing painton equipment.

the only waste generated is plaint chips(eliminates volumes of blast grit.


Waste Solvent Only strip the area needed for repair 7 0 2 Several manufacturers do this as commonpractice.


Waste Solvent Use water whenever possible fortesting or demonstrating


EmployeeTraining,Supervision

Inefficiencies, Spills Operation of equipment to minimizeenergy use and material use

9 0 2 Ongoing training - Common practice.


Inefficiencies, Spills Detecting and minimizing material lossto air, land or water

12 0 1 Ongoing. Common practice. For example, usemass balance measurement techniques.


Inefficiencies, Spills Proper materials handling to reducewastes and spills

16 0 0 Ongoing training. Common practice. Should bepart of hazmat training requirements.


Inefficiencies, Spills Emergency procedures to minimizematerial loss during accidents

13 0 0 Training in spill response and operation isessential in minimizing material loss.Information regarding spill procedures isavailable from NPCA “Coatings Care” program.


Inefficiencies, Spills Laboratory personnel rotate intomanufacturing positions to understandprocess (vice versa)

3 1 6 Helps with formulating and recipe-making.More common for factory personnel to rotateinto lab positions. Viable future opportunity.


Inefficiencies, Spills Provide incentives, bonuses, rewardsfor employees to reduce wastes

5 0 6 Some successful programs. Viable futureopportunity.

Appendix C


APPENDIX D

PPPPPollution Prollution Prollution Prollution Prollution Preeeeevvvvvention Opporention Opporention Opporention Opporention Opportunities tunities tunities tunities tunities ChecChecChecChecCheckkkkklistlistlistlistlist

Process Waste/Substance Reduction Method CommentsReduced

Product Formulation Hazardous Chemicals Eliminate chromium compoundsand Pigments (e.g. sodium chromate)

Product Formulation Hazardous Chemicals s Eliminate lead driers and colorantsand Pigment

Product Formulation Hazardous Chemicals Eliminate xyleneand Pigments

Product Formulation Hazardous Chemicals Eliminate ethyl benzeneand Pigments

Product Formulation Hazardous Chemicals Eliminate methylene chlorideand Pigments

Product Formulation Hazardous Chemicals Eliminate ethylene glycoland Pigments

Product Formulation Hazardous Chemicals Eliminate n-butyl alcoholand Pigments

Product Formulation Hazardous Chemicals Eliminate tolueneand Pigments

Product Formulation Hazardous Chemicals Eliminate mercury-basedand Pigments bactericides

Product Formulation Hazardous Chemicals Eliminate crystalline silicaand Pigments

Product Formulation Hazardous Chemicals Eliminate zincand Pigments

Product Formulation Hazardous Chemicals Eliminate methanoland Pigments

Product Formulation Hazardous Chemicals Eliminate MEK and Pigments

Product Formulation Hazardous Chemicals Eliminate ammoniaand Pigments

Product Formulation Hazardous Chemicals Reformulate solvent-basedand Pigments products into water-borne products

Product Formulation Hazardous Chemicals Reformulate into U.V. curedand Pigments products

Product Formulation Hazardous Chemicals Reformulate into powder coatingsand Pigments

Appendix D



Product Formulation Hazardous Chemicals Reformulate into high-solidsand Pigments formulations

New Product Initiation Off-Spec Product Laboratory and management coordinateefforts to determine re-work potentialbefore releasing experimental products

New Product Initiation Off-Spec Product Formulator works with paintmakerwhen manufacturing a new productfor the first time

Inventory Management Raw Materials Establish a centralized purchasingprogram

Inventory Management Raw Materials Use improved inventory managementpractices

Inventory Management Raw Materials Test raw materials before acceptingfrom supplier.(Send product samplesback to vendors to avoid disposal aswaste.)

Inventory Management Raw Materials Use �just-in-time� inventory control

Inventory Management Raw Materials Use containers with removable liner

Inventory Management Raw Materials Inspect packaging for tears, repairimmediately

Inventory Management Raw Materials Simplify inventory, combine andstandardize where possible

Inventory Management Raw Materials Certification program for rawmaterial suppliers

Inventory Management Raw Materials Sell or give away obsolete rawmaterials for re-use (e.g. tomanufacturers, wholesalers or throughmaterial exchange).

Inventory Management Packaging / Solid Waste Purchase pre-weighed hazardousingredients or design formulas to use

. whole bags whenever possible(e.g. recyclable or reusable drums)

Inventory Management Packaging / Solid Waste Use packaging that can be sent backto supplier

Inventory Management Packaging / Solid Waste Order common materials in bulk to reduce packaging.



Unloading Materials Spilled Raw Materials Prevent tanks from overfillinginto Mixing Tanks (e.g. by installing high-level cutoff

and flow totalizers with cutoff).

Unloading Materials Pigment Dusts Use pigments in slurry/paste form into Mixing Tanks

Unloading Materials Pigment Dusts Re-use baghouse pigment dust (e.g.into Mixing Tanks Install dedicated baghouse systems)

Production (Grinding, Excess Product Sell or give away part-gallon overagesto customers on custom products

Production (Grinding, Off-Spec Product / Sell or offeroff-spec product or excessmixing, blending) Excess Product product to non-profit organizations,

schools, theater groups, or IMEX.

Production (Grinding, Off-Spec Product Blend into new productsmixing, blending)

Production (Grinding, Off-Spec Product Test batch formulation in lab beforemixing, blending) going to manufacture.

Production (Grinding, Off-Spec Product No returns on custom-tinted productsmixing, blending)

Production (Grinding, Off-Spec Product Have customers supply a substratemixing, blending) sample with their color-match requests

Production (Grinding, Off-Spec Product Laboratory use brush-out and draw-mixing, blending) down sample methods instead of using

spray equipment

Production (Grinding, Off-Spec Product Clearly indicate or highlight formulamixing, blending) changes

Production (Grinding, Off-Spec Product Install timers on mixing tubs to preventmixing, blending) overmixing and reduce adjustment with

additional raw material

Production (Grinding, Spills Increase use of automationmixing, blending)

Production (Grinding, Spills Recycle as much of spill into productmixing, blending) as possible

Production (Grinding, Spills Clean remaining spill with dry methodsmixing, blending) (not with water or solvent)

Appendix D



Production (Grinding, Spills Purge pipelines before disconnecting.mixing, blending)

Production (Grinding, Solvent Evaporation Cover all vessels with lids and coversmixing, blending)

Milling Wash Solvent Change from ballmill to disperser,don�t have to use as much solventto clean-out

Milling Wash Solvent Schedule milling from light to darkcolors

Milling Wash Solvent Dedicate a mill for light and brightcolors

Milling Wash Solvent Install more efficient mills that do notrequire multipass dispersions

Filtering Spent Filters Use as small a cartridge as possible

Filtering Spent Filters Use reusable bag or metal mesh filters(e.g., vortisieve screens).

Filtering Spent Filters Clean out filters regularly (or useself-cleaning filter system)

Filtering Spent Filters Improve pigment dispersion to reducelumps

Product Packaging Wash Solvent Increase dedication of filling units

Product Packaging Waste Drums and Provide totes to customers with largeBarrels orders

Product Packaging Solid Waste Purchasing raw materials in totes &bulk to reduce drum use

Product Packaging Solid Waste Can crusher to crush cans to EPArecyclable standard

Equipment Cleaning Wash Solvent/Water Maximize batch size to reduceclean-out waste

Equipment Cleaning Wash Solvent/Water Dedicate equipment to single productor family of products to reduce needfor cleaning

Equipment Cleaning Wash Solvent/Water Schedule production to minimize needfor cleaning:(e.g., light to dark colors,similar formulations)



Equipment Cleaning Wash Solvent/Water Re-use equipment cleaning wastes:collect wash solvent/ water and use in next compatible batch of paint as partof formulation

Equipment Cleaning Wash Solvent/Water Clean equipment immediately beforepaint dries. (Prevent paint from dryingon tank walls.)

Equipment Cleaning Wash Solvent/Water Use high-pressure wash systems andefficient nozzles

Equipment Cleaning Wash Solvent/Water Mechanically clean with squeegees orwiper blades before washing tanks

Equipment Cleaning Wash Solvent/Water Use non-stick tanks (e.g. stainlesssteel, or lined with Teflon or epoxy)

Equipment Cleaning Wash Solvent/Water Use foam or plastic �pigs� to cleanout lines

Equipment Cleaning Wash Solvent/Water Purge lines with compressed air/gas

Equipment Cleaning Wash Solvent/Water Collect solvent and re-distill (on oroff-site)

Equipment Cleaning Wash Solvent/Water Use still bottoms in formulationof product

Equipment Cleaning Wash Solvent/Water Use counter-current rinse methods(First wash with dirty solvent, thenrinse with clean)

Equipment Cleaning Wash Solvent/Water Increase spent rinse settling timeor use de-emulsifiers on spent rinsesfor continued use.

Equipment Cleaning Wash Solvent/Water Filter or centrifuge wash water so itcan be reused (esp. for tote washing)

Equipment Cleaning Wash Solvent/Water Design tanks with length-to-diameterratio of 1:1 (minimizes surface area tobe washed per batch)

Equipment Cleaning Wash Solvent/Water Automated tank cleaners

Equipment Cleaning Wash Solvent/Water �Clean as you go� policy - rigorouslyenforced

Equipment Maintenance, Waste Solvent Use abrasive blasting for removing paintTesting on equipment.

Appendix D



Equipment Maintenance, Waste Solvent Use needle gun for removingTesting paint on equipment.

Equipment Maintenance, Waste Solvent Only strip the area neededTesting for repair

Equipment Maintenance, Waste Solvent Use water whenever possibleTesting for testing or demonstrating

Employee Training, Inefficiencies, Spills Operation of equipment toSupervision minimize energy use and material

use

Employee Training, Inefficiencies, Spills Detecting and minimizing materialSupervision loss to air, land or water

Employee Training, Inefficiencies, Spills Proper materials handling toSupervision reduce wastes and spills

Employee Training, Inefficiencies, Spills Emergency procedures to minimizeSupervision material loss during accidents

Employee Training, Inefficiencies, Spills Laboratory personnel rotateSupervision into manufacturing positions to

understand process (vice versa)

Employee Training, Inefficiencies, Spills Provide incentives, bonuses,Supervision rewards for employees to reduce

wastes


APPENDIX E

TTTTTOOOOOXICOLXICOLXICOLXICOLXICOLOGY OF HAZARDOUS CHEMICALOGY OF HAZARDOUS CHEMICALOGY OF HAZARDOUS CHEMICALOGY OF HAZARDOUS CHEMICALOGY OF HAZARDOUS CHEMICALS & PIGMENTSS & PIGMENTSS & PIGMENTSS & PIGMENTSS & PIGMENTS

Ammonia: Irritating to the skin, eyes, and mucous membranes of the respiratory tract. Danger-ous at high concentrations: causing severe burns due to corrosivity.

Chromium compounds (e.g. sodium chromate): CAS # 7775-11-3. Carcinogenic (group 1,human carcinogen ->lung cancer). Soluble salts of hexavalent chromium are corrosive and haveproduced skin ulceration, dermatitis, perforation of the nasal septum, respiratory sensitization andlung cancer. Acute poisoning with soluble salts usually results in local tissue necrosis and severekidney damage. Electroplaters and paint pigment workers who expressed symptoms of cough, indiges-tion and dermal itching were found to have urine chromium concentrations of 91-1116 ug/l.

Ethyl benzene: CAS# 100-41-4. Ethylbenzene is an eye, skin, and mucous membrane irritant.Exposure to ethylbenzene may cause profuse lacrimation, conjunctivitis, nasal and respiratory tractirritation, skin sensitization or burns, chest constriction, vertigo, headache, irritability, functionalnervous system disturbances, hematologic disorders (leukopenia, lymphocytosis), and liver enlarge-ment.

Chronic exposure in humans has caused fatigue, sleepiness, headache, and irritation of the eyesand respiratory tract. In experimental animals, exposure to ethylbenzene has caused eye, skin, andmucous membrane irritation; changes in liver and kidney weights; hematologic changes; CNS depres-sion; pulmonary edema; and respiratory failure.

In young children, developmental defects including learning disabilities, lowered IQ, and behav-ioral abnormalities, can occur without symptoms at blood lead levels above 10 micrograms/deciliter.At higher levels of exposure headache, fatigue, irritability and malaise may occur. At high levels,encephalopathy, seizures and focal neurologic findings with imminent risk of death, permanent mentalretardation, and motor deficits may occur.

Ethylene glycol: CAS#107-21-1. Exposure to ethylene glycol may occur through inhalation,ingestion, or eye contact.

PHASE ONE: CNS and metabolic abnormalities occur within minutes to hours followingingestion and include ethanol-like inebriation, ataxia, slurred speech, seizures, coma, cerebral edema,anion gap metabolic acidosis associated with tachypnea, and Kussmaul�s respiration.

PHASE TWO: Occurs 12 to 36 hours post ingestion. Progressive tachypnea, cyanosis, pulmo-nary edema, and cardiomegaly. Death is most common in this phase.

PHASE THREE: Occurs 2 to 3 days post ingestion. Signs of renal insufficiency may occur assoon as 36 to 48 hours post ingestion. Renal injury may vary from proteinuria, hematuria, and crystal-luria with a mild increase in BUN to prolonged anuria and azotemia. Chronic exposures to the vapormay cause unconsciousness, nystagmus, and lymphocytosis. Even a small amount of ethylene glycolmay have toxic effects on the kidney.

Lead: CAS# 7439-92-1. Animal carcinogen, probable human carcinogen. Toxic by ingestion andinhalation of dust or fume. Lead is poisonous in all forms. Systemic lead poisoning can result from theinhalation of airborne lead particulate matter or fumes, or from the ingestion of lead in its ionic formfrom water, food, etc. In homes built before 1980, lead-containing paint may be the source. The hazardof exposure to lead is particularly severe in small companies/operations, often employing no morethan three or four workers, engaged in radiator repair, leaded or stained glass production, laboratories,or ceramics.

Appendix E


N-butyl alcohol: CAS# 71-36-3. Acute exposure to higher alcohols (alcohols with a 3,4,5 carbon chain) usuallyresults in CNS depression, hypotension, nausea, vomiting, and diarrhea. Butanols and amyl alcohols are irritants. Ifaspirated, hemorrhagic pneumonitis may be noted. Vapor or splash contact exposure may cause burning, lacrimation,blurring of vision, and vacuolar keratopathy. Hypotension and cardiac arrhythmias may occur. Inhalation causes pulmo-nary tract irritation and rarely pulmonary edema. Severe respiratory depression or death has not been reported afterinhalation. Headache, dizziness, giddiness, ataxia, sedation and coma may occur.

Mercury: CAS# 7439-97-6. Adverse effects chiefly result from vapor inhalation. The respiratory system is prima-rily affected. Pneumonitis, necrotizing bronchiolitis, pulmonary edema, and death can result. Central nervous systemeffects, renal damage, gingivitis, and stomatitis can develop.

Nervous system manifestations predominate with chronic exposure. Personality changes, hallucinations, delirium,insomnia, decreased appetite, irritability, erethism, headache, memory loss, altered sense of taste and smell, and diges-tive disturbances may occur. Bilateral fine tremors, ataxia, exaggerated reflexes, paresthesias, excessive perspiration,and blushing may occur.

Chronic mercury exposure may also cause rashes, and corneal and lens changes with visual impairment. Childrenand some adults develop acrodynia, which is associated with severe leg cramps, irritability, and peeling erythematousskin on the fingers, hands, and feet. Allergic dermatitis may occur. Renal dysfunction has been reported in some personsexposed to mercury vapors. Chronic mercury poisoning (�mercurialism�) usually results from inhalation of elementalmercury vapors or particles. Evidence of chronic poisoning may occur within weeks of an extreme acute exposure ormay develop insidiously over many years. Children are more susceptible than adults to mercury poisoning.

Methanol: CAS# 67-56-1. Methanol is highly toxic, producing severe metabolic acidosis, blindness, and death.The onset of symptoms may be delayed for 18 to 24 hours after ingestion. Toxicity is related to the degree of acidosisproduced and thus the time interval between exposure and specific treatment.

Ingestion or inhalation of methanol-containing substances may cause severe toxicity. Dermal exposure to methanolmay also cause significant toxicity.

Methanol cannot be made nonpoisonous. Acute methanol poisoning usually causes initial confusion and ataxia,followed by a 6- to 12-hour latent period with nonspecific malaise, headache, vomiting, severe abdominal pain, andvisual changes. Later stages, if untreated, progress to coma,metabolic acidosis, and finally respiratory or circulatoryarrest.

The most common permanent sequel following severe acute methanol poisoning are optic neuropathy with bilateralblindness, Parkinsonism, and limb polyneuropathy.

Persons with existing skin, kidney, liver, or eye disorders may be at an increased risk when exposed to methanol.Methanol is teratogenic in mice and rats.

Methylene chloride: CAS# 75-09-2. Probable human carcinogen (2B). Methylene chloride may be absorbedfollowing inhalation, ingestion, or dermal exposure. Acute exposure causes mucous membrane and respiratory tractirritation, headache, and at high concentrations central nervous system (CNS) depression and respiratory failure. Dermalcontact may cause irritation and burns. In humans exposed by ingestion or inhalation, paresthesias, somnolence, alteredsleep patterns, convulsions, euphoria, and change in cardiac rate may occur. Combustion of methylene chloride or usearound open flames or heated surfaces may evolve hydrogen chloride, phosgene, and chlorine.

Methyl Ethyl Ketone (MEK): CAS# 78-93-3. Acute inhalation may result in eye, nose and throat irritation,nausea, headache, vertigo, uncoordination, CNS depression, narcosis and cardiorespiratory failure. If splashed in theeyes it may produce painful irritation and corneal injury. Short exposure of workers to 500 ppm in the air provokednausea and vomiting. The common symptoms of short term exposure are fatigue, headache, nausea, sleep disturbance,and alteration in memory. Reduced psychomotor performance and adverse effects on intellectual or memory functionsare demonstrated with psychological test batteries after long-term occupational exposure.


Toluene: CAS# 108-88-3. The nervous system appears to be the most sensitive to the effects of toluene. CNSexcitation (euphoria, giddiness, tremors, nervousness, insomnia) followed by CNS depression (headache, dizziness,fatigue, muscle weakness, drowsiness, confusion, vertigo, decreased reaction time); metallic taste, and nausea arecommon after exposure to 400 to 800 ppm. Toluene appears to produce reversible effects upon liver, renal, and nervoussystems. High-level toluene exposures produced uncoordination, ataxia, unconsciousness and eventually, death.

Ataxia, severe fatigue, and seizures lasting up to several days have been reported after exposure to 800 ppm. Rapidgeneral anesthesia follows exposure to 10,000 ppm or greater. Chemical pneumonitis and respiratory failure haveoccurred after sniffing paint or toluene. Among painters exposed to toluene in concentrations ranging from 100-1000ppm, findings include enlargement of liver, macrocytosis, moderate decrease in erythrocyte count & absolute lymphocy-tosis, but no leukopenia. Toluene causes defatting of the skin with subsequent danger of dryness, fissuring and secondaryinfection. Sudden death among �sniffers� may be attributed to lethal cardiac arrhythmias following sensitization of themyocardium.

Xylene: CAS# 1330-20-7. Xylene is irritating to the eyes, skin, and mucous membranes. Exposure may causedyspnea, anorexia, nausea, vomiting, dermatitis, fatigue, headache, dizziness, incoordination, irritability, changes inreaction time, narcosis, partial paralysis of the hands and feet, and anemias. In severe cases, unconsciousness and deathcan occur. Chronic exposure to xylene may cause defatting dermatitis, reversible eye damage, dyspnea, confusion,dizziness, apprehension, memory loss, headache, tremors, weakness, anorexia, nausea, ringing in the ears, irritability,thirst, mild changes in liver function, renal impairment, anemia, and blood dyscrasias. Aspiration of xylene or IV injec-tion can cause pneumonitis, pulmonary edema, hemorrhage and respiratory failure. Inhalational exposure to 1000 ppm isconsidered immediately dangerous to life or health.

Zinc: CAS# 7440-66-6. BRONZE-POWDER - A severe necrotizing bronchitis and bronchopneumonia can followinhalation of bronze-powder (70% copper, 30% zinc stearate). ZINC STEARATE is present in commercial talcumpowders and can cause severe irritation of the respiratory tract if aspirated by infants. Ingestion of corrosive zinc saltsmay produce gastroenteritis. Symptoms are characterized by intense gastric and substernal pain, violentvomiting,diarrhea, shock, circulatory collapse, and possible death. (Example: Zinc phosphide.) Chronic anemia unre-sponsive to iron in 3 children was attributed to zinc poisoning. The urine contained 1.8-3.65 mg of zinc/l. Each of thechildren chewed metal toys made of zinc containing alloy. When the toys were withdrawn the anemia responded tocontinued treatment with iron.

Appendix E

Paint and Coatings Manufacturing Sector Project 47Appendix F

APPENDIX F�VENDORS

VENDOR CONTACT INFORMATION

Vendor Location / City Contact #�s Products / Description / HomePage

AUTOMATED TANK CLEANERS

C.B. Mills Div. Gurnee, IL (800) 522-7343 User friendly, micro-processor controlled, high pressureOf Chicago Boiler spray to clean tanks, totes, & drums with minimal opera-

tion attention.

Cloud Co. San Luis Obispo, CA (805) 549-8093 Manufacturer of tank cleaning machines

Distil-Kleen, Inc. Irvington, NJ (973) 372-1500 Tank, drum, & container high pressure/brush washingequipment for portable and stationary containers.

Gamajet Cleaning Malvern, PA (800) 893-6362 Tank cleaning machines, industrialSystems, Inc. applications

Tank Cleaning St. Charles, IL (630) 377-3812 Designers & manufacturers of tank & barrel cleaningSystems machinery for industrial applications

Woma Corporation Everett, WA (800) 258-5530 High and ultra high pressure water blasting pumps & sys-tems for tank cleaning

ENVIRONMENTAL (including HAZARDOUS MATERIALS MANAGEMENT) SOFTWARE

Contemporary Pittsburg, PA (412) 642-2222 Enviroware integrated waste management software pack-.Software Fax:(412) 642-2223 age includes materials tracking and bar coding capabilities

Corbus Kennett Square, PA (800) 524-7096 A leader in the field of environmental, health and safety,and

(610) 444-5691 compliance software, www.corbus.comFax:(610) 444-6461 Email: [email protected]

Essential Rockville, MD (800) 999-5009 Environmental, health and safety information systems,Technologies, Inc. Fax:(301)284-3001 www.essentech.com

Jordan System, Cedar Rapids, IA (800) 859-3023 Environmental software solutions for today�sInc. environmental health & safety manager,

www.jordansystems.com

Logical Tech- Peoria, IL (800) 266-7591 Regulatory compliance software reporting hazardousnology Inc. (309) 689-2900 material management. www.logicaltechnology.com

Fax::(309) 689-2911

Logical Data Palm Beach (561) 694-9229 EPOCH offers a series of application modules that can beSolutions, Inc. Gardens, FL Fax:561-694-9131 used in a stand-alone mode or fully integrated to form a

comprehensive environmental information managementsystem.


{Note: The following companies also produce environmental management software which includes hazardous materi-als management capabilities.}

AV Systems Inc. Fax:(313) 677-4480

Abkowitz & Associates Inc. Fax:(615) 321-4886

Apex Environmental Inc. Fax:(301) 975-0169

CAE Consultants Inc. Fax:(914) 376-5011

Canadian Center for Occupational Fax:(905) 570-8094Health & Safety

Chemical Safety Co. Fax:(510) 594-1100

CHEMTOX Fax:(615) 370-4339

Delta Systems Inc. (800) 585-MSDS

Earth Soft (800) 649-8855Fax:(303) 932-1030

Envirogenics Fax:(609) 586-4426

Environmental Software Cooperative Fax:(805) 642-4020

Environmental Software & Systems Inc. Fax:(419) 353-8540

Environmental Support Solutions Fax:(602) 834-4319

EnviroWin Software Inc. Fax:(773) 244-1922

Harding Lawson Associates, Fax:(303)292-5411Applied Information Tech. Unit

HazMat Control Systems Inc. Fax:(562)597-9904

Knoor Associates Fax:(973)-492-0453

LFR Technology Fax:(650)712-7479

McLaren/Hart Inc. Fax:(518) 869-3971

Micromedex Inc. Fax:(303) 486-6464

Modern Technologies Corp. Fax:(937) 252-9227

Pacific Environmental Services Inc. Fax:(919) 941-0234

RPM Software Fax:(612) 475-1138

Safeware Inc. Fax:(650) 578-1246


Softrak Systems Inc. Fax:(610) 868-2448

Technical Environmental Fax:(504) 348-3043Services Inc.

Telstar Associates Inc. Fax:(208) 385-9168

Terralink Software Systems Inc. Fax:(207)767-1022

Tracker Technologies Fax:(714) 442-7822

Trans Mountain Consulting Co. Fax:(303) 526-7841

Veeder-Root Fax:(860) 651-2719

VISTA Information Solutions Inc. Fax:(619)450-6195

Wixel Inc. Fax:(303) 796-0043

HIGH-PRESSURE WASH SYSTEMS / WATER RECYCLING SYSTEMS

Aaladin Elk Point, SD (800) 411-4261 Hot & cold water pressure washers, steam cleanersIndustries, Inc.

AAR Power Aberdeen, NC (800) 982-1227 Self-contained pressure spray/vacuum units for washdownBoss, Inc. and hazardous material recovery.

Acme Cleaning Houston, TX (800) 231-9708 Hot & cold water pressure cleaning equipment, steamEquipment, Inc. cleaners, water reclamation equipment

Alcota Cleaning Veradale, WA (800) 255-6823 Surface cleaning and waste water treatmentSystems, Inc.

B & M Enterprises Fife, WA (253) 536-7700 Steam cleaners, pressure washers, wastewater treatmentsystems, closed loop recycling systems

Citation Pressure. Duncanville, TX (972) 461-0812 Hot & cold pressure washing equipment, installationsWashers, Inc

The Hotsy Englewood, CO (800) 525-1976 Hot and cold water pressure washers, steam cleaners, andCorporation wastewater recycling systems.

Landa Water Camas, WA (800) 792-6174 Hot/cold water pressure systems, steam cleaners, washCleaning Systems water recycling systems, waste water treatment

Niagara National Atlanta, GA (800) 635-8342 High pressure washers & wash water treatment and recy-Corporation cling systems

RGF Environ- Palm Beach, FL (800) 842-7771 Advanced water treatment/recycling systems.mental Systems

Spartan Manu- Kernersville, NC (336) 996-5585 Portable pressure washers & steam cleaning equipment,facturing Corp. wastewater capture systems, all industries

Upstream Tech- Lexington, KY (606) 269-6097 Closed loop water cleaning systems, hot & cold high pres-nologies, LLC sure washers, steam cleaners

Appendix F


RECYCLERS OF DRUMS � METAL AND PLASTIC

American Re- Spokane, WA (509) 535-4271 Takes almost all metal barrels if triple rinsed.cycling Corp.

Denton Plastics/ Portland, OR (503) 257-9945 Plastic pickup depending on volume and quantity.Pickup

Earthworks Spokane, WA (509) 534-1638 Takes metal and plastic barrels. Call first.Recycling

Eastbury Salvage Marysville, WA (360) 659-1540 Metal drums have to meet standards. Will pick up.

Flotation Services Bellevue, WA (425) 453-1139 Accepts only large 50-55 gal plastice drums. Drums need tobe triple rinsed. Call for pickup.

Interstate Plastics Vancouver, WA (360) 694-1753 Will pay for plastic if over 1000lbs. Pickup depends onquality. Commercial customers only.

Northwest Seattle, WA (800) 451-3471 Drum recycling. Deals mostly with metal barrels.Cooperage Co.

Northwest Plastic Tacoma, WA (253) 274-8294 Takes 55 gallon plastic barrels, crates and totes.Recovery

Offshore Scrap Seattle, WA (206) 726-2884 Interested in 55 gal drums, either metal or plastic. MainlyIron commercial, will pickup large quantity.

Seattle Barrel Seattle, WA (800) 556-4271 Drum recycling. Will accept steel and plastic.Company

Steelhead Indust- Spokane, WA (509) 468-9688 Drum disposal and recyclingries

Waste Control Longview, WA (360) 425-4302 Will accept 55 gal metal barrels if triple rinsed.Recycling Inc.

Z Recyclers Lynden, WA (360) 398-2161 Barrels must be metal & visibly clean (any size).

RECYCLERS OF FIVE GALLON PAILS

Denton Plastics/ Portland, OR (503) 257-9945 Plastic pickup depending on volume and quantity.Pickup

Interstate Plastics Vancouver, WA (360) 694-1753 Will pay for plastic if over 1000lbs. Pickup depends onquality. Commercial customers only.

Nature�s Market- Vancouver, WA (360) 695-8878 Accepts #2 and #5 plastic pails.place

Northwest Plastic Tacoma, WA (253) 274-8294 Takes 4 or 5 gal HDPE buckets.Recovery

Yelm Earthworm Yelm, WA (360) 894-0707 Will accept 1 gal and up plastic pails or buckets.& Castings Farm


RECYCLERS OF PAINT CANS

Proler Interna- Seattle, WA (206) 947 6622 Recycle used paint canstional

Seattle Barrel Seattle, WA (206) 622 7218 Recycle used paint cansCompany

RECYCLERS OF PALLETS

Cascade Pallet Ellensburg, WA (800) 962-4213 Takes wood. Cleaner wood eventually used to make paper.Pasco, WA Pays for 48-40 reusable pallets.

Earthworks Spokane, WA (509) 534-1638 Takes pallets.Recycling

Girard�s Wood Puyallup, WA (800) 532-0505 Handles pallets in any condition.Products

National Pallet Orting, WA (360) 897-8132 Purchase of pallets depending on quality and size. Recondi-Service tions pallets for reuse.

Nepa Pallet & Snohomish, WA (360) 568-3185 Will take pallets in good condition and may pay.Container Co.

NW Wood & Auburn, WA (253) 939-5497 Accepts clean wood, pallets, crates, and plywood.Fibre Recovery

Pallet One Tumwater, WA (360) 956-9541 Pallets and clean lumber.

Pallet Services Mount Vernon, WA (800) 769-2245 Buys if in good shape. May pay for broken pallets.Pasco, WA (800) 769-2252 Call for prices. Always make an appointment.Seattle, WA (206) 625-9053Spokane, WA (800) 563-6684Tacoma, WA (800) 872-5069

Rainier Pallets Auburn, WA (253) 813-0770 Payments are negotiable depending on condition of thepallets. Will pickup large amounts.

Recycle America / Seattle, WA (206) 762-3000 Accepts pallets and crates, various wood materials.Waste Management

Triangle Resources Camas, WA (360) 834-7253 Wood waste, pallets, and clean lumber. Call first.

Weyerhaeuser Everett, WA (425) 303-0744 Clean wood, pallets, crates, dimensional lumber.Wood Recycling

Yelm Earthworm Yelm, WA (360) 894-0707 Will take pallets and orchard boxes.& Castings Farm

Appendix F


RECYCLERS OF PAPER SACKS

The Department of Ecology compiles a list of companies that provide recycling services for mixed paper in WashingtonState. The services provided my any particular company are subject to change. Contact Ecology for an up to date list ofcompanies in your area. (800) RECYCLE

(800) 732-9253

SHOWER CAPS / TANK COVERS

Canvas Specialty Los Angeles, CA (888) 641-3225 Industrial fabric products, custom covers

Detroit Tarpaulin Romulus, MI (800) 457-5054 Covers, tents, and curtains

Hendee Inter- Houston TX (800) 231-7275 Process tank covers,prises Inc.

John Johnson Co. Detroit, MI (800) 991-1394 Canvas & synthetic, coated & uncoated covers

Reef Industries Houston, TX (800) 231-6074 Specialty plastic films, covers, liners, and tarps

SUPER SACKS

B.A.G. Corp. Dallas, TX (800) 331-9200 Super Sacks, bags, and equipment

Hosokawa Minneapolis, MN (800) 607-2470 Equipment and systems for packaging dry solids into bags,Bepex Corp. boxes, drums, totes, and supersacks

MacMillan . Montgomery, AL (800) 239-4464 Packaging: bulk (supersacks, boxes, totes)BloedelPackaging, Inc


APPENDIX G

DEPARTMENT OF ECOLOGYAugust 8, 1998

TO: Hazardous Waste Staff

FROM: Thomas Cusack, Hazardous Waste SpecialistHazardous Waste and Toxics Reduction Program

SUBJECT: Counting Dangerous Waste Under the Dangerous Waste Regulations

IntroductionThis document provides guidance on �counting� dangerous waste as it applies to the Dangerous Waste Regula-tions, Chapter 173-303 WAC. This memo replaces TIM No. 89-1, dated 11/14/89, titled �Counting Spent Sol-vents and the Closed Loop Exclusion� and the previous version of this memo dated April 1, 1996. It is notintended to replace state or federal regulations or to explain how to designate waste. �Counting� refers to addingthe total weight of dangerous waste generated during a calendar month in determining generator compliancestatus.

How to Use This DocumentThis memorandum is not meant to function as a �stand alone document� and may not cover every possiblesituation readers may find themselves in. It will help the reader understand the Dangerous Waste Regulationsand when to count dangerous wastes. Due to the complexity of regulations involved and terms used, it is sug-gested the reader have a recent copy of the Dangerous Waste Regulations. Flow diagrams and an attachedcounting matrix have been provided to help explain counting dangerous waste in relation to recycling and totreatment. Attached, as part of this memo, is a series of short �counting� discussions associated with the Domes-tic Sewage Exclusion (DSE), storage or accumulation, Treatment by Generator (TBG), Permit-By-Rule (PBR),the Multiple Counting Exclusion, and recycling in general.

Reasons to Count:Reasons for counting dangerous waste include:

To determine generator compliance status (i.e., small, medium, or large quantity generators).

To comply with generator requirements associated with submitting Dangerous Waste Annual Reports.

To determine if a pollution prevention plan should be submitted. (Those requirements are clearly outlined inChapter 173-307 WAC and will not be covered by this paper.)

Counting Frequency:Generators must count their waste each calendar month. Significant changes in the monthly totals can cause achange in the generator�s status.

Appendix G


Counting Dangerous Waste MemoradumAugust 8, 1998Page 2

Attachments (11)Flow Chart 1: Counting Dangerous Waste in Relation to RecyclingFlow Chart 2: Counting Dangerous Waste in Relation to TreatmentCounting Discussion 1: Counting and the Domestic Sewage ExclusionCounting Discussion 2: Counting and Storage or AccumulationCounting Discussion 3: Counting and Recycling/Excluded Wastes in GeneralCounting Discussion 4: Counting and Recycling Without Prior Accumulation or StorageCounting Discussion 5: Counting and the Multiple Counting ExemptionCounting Discussion 6: Counting and Treatment by GeneratorCounting Discussion 7: Counting and Permit-By-RuleCounting Discussion 8: Counting and Annual Reporting Requirements�What to Count� Matrix


Flow Chart 1: Counting Dangerous Waste in Relation to Recycling

Is the dangerous waste conditionallyexcluded from the DangerousWaste Regulations?(section -071(3)(c - bb)NO - continue

YES - THE WASTE IS NOTCOUNTED AS DANGEROUSWASTE

Is the dangerous waste specificallyidentified as a waste not to becounted when recycled in aspecific manner? (section -120(2)(a)and -120(3)(c, e, f, & h)NO - continue


Is the dangerous waste beingstored/accumulated before recycling?(sections -200 and -201)YES - continue

NO - THE WASTE IS NOTCOUNTED AS DANGEROUS

Will the dangerous waste besent off-site for recycling ordisposal?NO - continue

YES - THE WASTE ISCOUNTED AS DANGEROUSWASTE

Is the dangerous wastespecifically a spent material?(section -040)YES - continue

NO - THE WASTE ISCOUNTED AS DANGEROUSWASTE

Was the spent material counted once during thecalendar month in which it was generated? (section070(7)(c))YES -THE WASTE IS NOT COUNTED ASDANGEROUS WASTE

NO -THE WASTE IS COUNTED AS DANGEROUSWASTE

Is the material considered asolid waste? (section-016)YES - continue

NO - THE WASTE IS NOTCOUNTED AS DANGEROUSWASTE

Does the solid waste designate asa dangerous waste? (section -070)YES - continue


Is the dangerous waste directlydischarged under the conditions ofthe Domestic Sewage Exclusion orthe Industrial Wastewater DischargeExclusion? (section -071(3)(a, b)NO - continue


Was the spent materialgenerated, reclaimed andreused on-site?YES - continue

NO - THE WASTE ISCOUNTED AS DANGEROUSWASTE

Ü Ü

ÜÜ

Ü

Ü

Ü

ÜÜ

Appendix G


Flow Chart 2: Counting Dangerous Waste in Relation to Treatment

Will the dangerous waste betreated on-site under the Permitby Rule provisions in a wastewater treatment unit, elementaryneutralization unit, or totallyenclosed treatment facility(section -802)1

NO - continue


Does the solid waste designate asa dangerous waste? (section -070)YES - continue


Is the material considered asolid waste? (section-016)YES - continue


Is the dangerous waste beingstored/accumulated beforetreatment? (sections -200 and -201)NO - continue


Will the dangerous waste be sentoff-site for treatment and/ ordisposal?NO - continue


1 Dangerous waste residues from the on-site Permitby Rule treatment of dangerous waste are counted ifdisposed outside the Permit by Rule provisions.

2 Dangerous waste residues from the on-sitetreatment of dangerous waste under theTreatment by Generator provisions are counted

Will the dangerous waste be treated under theTreatment by Generator provisions? (sections -170, -200 & -201)2

YES -THE WASTE IS COUNTED ASDANGEROUS WASTE

NO -THE WASTE IS COUNTED AS DANGEROUSWASTE AND A RCRA TREATMENT PERMIT IS REQUIRED.

Is the dangerous waste directlydischarged under the conditions ofthe Domestic Sewage Exclusion orthe Industrial WastewaterDischarge Exclusion? (section -071(3)(a, b)NO - continue


Is the dangerous wasteconditionally excluded from theDangerous Waste Regulations?(section -071(3)(c - bb)NO - continue

YES - THE WASTE IS NOTCOUNTED AS DANGEROUS

Ü Ü

ÜÜ

Ü

ÜÜ


Counting Discussion 1

Counting and the Domestic Sewage ExclusionThe Domestic Sewage Exclusion (DSE) allows dangerous waste to be discharged to a publicly-owned treatmentworks (POTW) only when such wastes are treatable at the POTW, and the discharger has a permit which autho-rizes the discharge of certain waste described in the permit. The dangerous waste is only excluded from theDangerous Waste Regulations after it enters the sanitary sewer system. For additional guidance on the DomesticSewage Exclusion, refer to Ecology�s Technical Information Memorandum (TIM) titled �Domestic SewageExclusion,� publication number 94-136 and WAC 173-303-071(3)(a).

Dangerous waste counted under the DSE:Dangerous waste managed prior to being directly discharged under the DSE to the sanitary sewer system iscounted. This means dangerous waste stored, treated, or recycled prior to the point of direct discharge iscounted.

Dangerous waste not counted under the DSE:As a policy, Ecology will not require dangerous wastes mixed with domestic sewage to be counted when thewaste is being directly discharged into the POTW system in compliance with the domestic sewage exclusion(WAC 173-303-071(3)(a)).

The following flow diagrams are intended to help explain when counting is applicable under the DSE:

FFFFFlololololow Diaw Diaw Diaw Diaw Diagggggrrrrram Number 1am Number 1am Number 1am Number 1am Number 1Point of *-(NC)- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ->POTWGeneration direct discharge to

Point of -(C) - - - - - - - - - - - - - - - - -> treat prior *-(NC) - - - - - - - ->POTWGeneration to direct

discharge to

Point of -(C) - - - - - - - - - - - - - - - - -> store/recycle *-(NC) - - - - - �>POTWGeneration prior to direct

discharge to

*means when the DSE applies.(C) means count dangerous waste.(NC) means no counting of dangerous waste.

Appendix G



Counting and Storage and/or Accumulation�Storage� means the holding of dangerous waste for a temporary period and is commonly subject to RCRAstorage permit requirements. �Accumulation� of dangerous waste, by the generator on the site of generation, isnot storage as long as the generator complies with the applicable requirements of WAC 173-303-200 and 173-303-201. However, the terms �storage� and �accumulation� are used interchangeably. For additional guidance onstorage and on satellite accumulation refer to the following TIMs: � �Effective Date of the 90-Day Storage(Accumulation) Requirement, TIM 82-5 (Revised 10/93); � �Satellite Accumulation,� publication number 94-120.

Dangerous waste counted under the accumulation regulations:Dangerous waste is counted at the point of generation prior to storage or accumulation in the generator�s 90 or180 day accumulation area. Likewise, dangerous waste accumulated under the satellite accumulation (SA)provisions (WAC 173-303-200) is also counted toward the generator�s status on a monthly basis (flow chartnumber 2).

Dangerous waste not counted under the accumulation regulations:It is not necessary to count the dangerous waste again when it is moved from satellite accumulation to thegenerator�s 90 or 180 day accumulation area.

The following flow diagram is intended to help explain when counting is applicable when storing or accumulat-ing waste:

FFFFFlololololow Diaw Diaw Diaw Diaw Diagggggrrrrram Number 2am Number 2am Number 2am Number 2am Number 2Point of - (C) - - - - to - - - - -> 90/180 day - (NC) - - - -> Removed for properGeneration accumulation *unit management

Point of - (C) - - - - to - - - - -> On-site RCRA- (NC) - -> Removed for properGeneration permitted storage *unit management

Point of - (C) - - - - to - - - - -> SA container - (NC) - -> Removed for properGeneration management

Point of - (C) ->SA container - (NC) ->90/180 day - (NC) ->Removed for properGeneration accumulation management

*unit(C) means count dangerous waste.(NC) means no counting of dangerous waste.*unit means tank or container.



Counting and Recycling / Excluded Wastes in GeneralAs a general �rule,� dangerous waste stored, disposed of, treated, recycled, or manifested are counted. How-ever, there are exceptions to this �rule� where some dangerous wastes are not counted. These exceptionsinvolve wastes being recycled a certain way or when a waste or management activity fulfills the requirementsof a conditional exclusion.

�Recycle� means to use, reuse, or reclaim a material. �Use or reuse� means to employ a material as an ingredi-ent in an industrial process or an effective substitute for a commercial product without first being reclaimed.Dangerous wastes may be used/reused, as described above, in such a way that they are removed from the statusof a solid waste (WAC 173-303-017(2 & 3)) and not counted (refer to FlowChart 1). The reason for this is thatcertain waste materials can be used/reused in ways that are not considered to involve waste management andbecome exempt from the Dangerous Waste Regulations.

Some dangerous wastes hold conditional exclusions from the Dangerous Waste Regulations. When specificterms of an exclusion are met, Ecology conditionally excludes the waste. This is because the materials are notdangerous waste, are regulated under other state and federal programs, or are recycled in ways which do notthreaten public health or the environment. When the specific terms of an exclusion are met, the dangerouswaste may become conditionally excluded from rule and not counted (WAC 173-303-071). A few examplesinclude treated wood waste, polychlorinated biphenyls (PCBs), waste generated in a product or raw materialstorage tank until removed, and waste reclaimed and reused in a closed loop system (refer to Flow Chart 1).

The Dangerous Waste Regulations list certain dangerous wastes that are not counted when recycled in a certainway. Like the excluded categories of waste, recyclable materials must be recycled following specific condi-tions. When the conditions are met, the waste is not counted toward the generator�s status. Refer to WAC 173-303-070(7)(c & d) and Flow Chart 1. Examples of wastes having recycling conditions include used oil, spentCFC and HCFC refrigerants, spent lead acid batteries, used batteries, scrap metal, spent antifreeze, wasterecycled without prior storage or accumulation (see discussion number 4), and waste recycled under the �mul-tiple counting exemption� (see counting discussion number 5).

Note: There is no flow diagram to accompany this discussion.

Appendix G



Counting and Recycling Without Prior Accumulation or StorageUnder this counting exclusion there can be no storage or accumulation prior to the recycling activity. Theadvantage to the generator, then, would be no counting of the dangerous waste entering the recycling unit.�Without prior storage or accumulation� means that as soon as the waste is generated it immediately enters therecycling unit. Wastes can not be carried in containers, for example, between the point of generation and therecycling unit. For more detail refer to WAC 173-303-070(7)(c)(iv).

Dangerous waste counted with no prior storage or accumulation:Dangerous waste residues generated from the recycling activity are counted.

Dangerous waste not counted without prior storage or accumulation:Dangerous waste are not counted when it can be recycled on-site, without first being stored or accumulated,only in an on-site process subject to regulation under WAC 173-303-120(4)(a).

The following flow diagram is intended to help explain when counting is applicable when storage or accumula-tion does not occur prior to on-site recycling:

FFFFFlololololow Diaw Diaw Diaw Diaw Diagggggrrrrram Number 4am Number 4am Number 4am Number 4am Number 4Point of��(NC)��*immediately enters��on-site recycling��(C) DW residuesGeneration unit

Point of��(C)��90/180 day��(NC)��enters��recycling unitGeneration accumulation

Point of��(C)��Storage��(NC)��enters��recycling unitGeneration

Point of ��(C)��Sattellite ��(NC)��enters��recycling unitGeneration accumulation

(C) means count dangerous waste(NC) menas no counting of dangerous waste*immediately enters means without first being stored or accumulated



Counting and the Multiple Counting ExemptionThe �multiple counting exemption� applies only to a time frame of one calendar month and is often used when wastes arestored or accumulated prior to recycling. It is intended to eliminate the multiple counting of spent materials that arereclaimed and then reused many times during that month. Spent materials (for example, solvents) which are generated,reclaimed, and reused (all occurring on-site) are counted only once during the month the material became spent. So at aminimum, the recycled spent material is counted once each month it is generated. Also, all dangerous waste residues (forexample, still bottoms) produced from the recycling process are counted each month (refer to WAC 173-303-070(7)(c)(ii)and Flow Chart 1). It is recommended that the reader first review the multiple counting diagram below, prior to readingthe entire narrative.Flow Diagram 5: Example of the Multiple Counting Exemption

Flow Diagram 4: Example of the Multiple Counting Exemption

Cleaning ProcessSolvent and DirtyParts

Evaporative LossSolvent onClean Parts

○

○

○

ðð 9 lbs. Spent Solvent - Thirduse for some - Second usefor some - tt C5- First usefor some (2 lbs.)

ðC6 - 1 lb. ofstill bottoms

Ä

ðCleanSolvent -8 lbs. ð

End of theMonth

Counting (C) LogC1 9 lbs. spent solventC2 1 lb. still bottomC3 2 lbs spent solventC4 1 lb. still bottomC5 2 lbs. spent solventC6 1 lb. still bottomMonthly 16 lbs. of dangerous wastetotal

tt Refer to “Counting Make Up”

NOTE: Without the multiple counting option, agenerator would have counted 30 pounds insteadof 16 pounds.



○

○

○

ðð 9 lbs. Spent Solvent -Second use for most -tt C3- First use for some[i.e. spent solvent frommake up (2 lbs.)]

ð10 lbs.Solvent=

2 lbs. NewSolvent(Make Up)

+ðC4 - 1 lb. ofstill bottoms

Ä

ðCleanSolvent -8 lbs.

Beginning ofthe month:Recycled ornew solvent -10 lbs.



○

○

○

ððC2 - 1 lb. ofstill bottoms

Ä

ððC1 - 9 lbs.Spent Solvent(first use)

CleanSolvent -8 lbs.

+ = ð10 lbs.Solvent

2 lbs. NewSolvent(Make Up)

Still

Appendix G


The previous flow diagram is ONLY ONE example that may help in clarifying this exemption, but is not meantto cover every situation or counting method in relation to the �multiple counting exemption.� Remember, thecounting process starts over again at the beginning of each calendar month.

Convert Gallons to Pounds:Three acceptable (but not the only) options to do this are:

Collect a gallon of waste and weigh it.

Multiply 1 gallon by 8.33 pounds/gallon.

Review MSDS information which may provide the specific gravity of the solvent product. Then take thatspecific gravity value and multiply it by 8.33 to convert to a weight amount.

Counting Make Up:�Make up� generally refers to unused solvent added to a batch of useable or recycled solvent for the purpose ofreplacing solvent which has been lost during the cleaning process. During the cleaning process, solvents may be�lost� through evaporation or perhaps remain on cleaned parts. These lost solvents would not be countedtoward the generator�s status. Solvents, on the other hand, which evaporate during a waste treatment or recy-cling process are waste and must be counted. This type of evaporation would be considered disposal of adangerous waste and may require a permit.

Since �make up� is considered product, it is not counted either, �until it becomes spent.� It would be thegenerator�s responsibility to determine how much of the make up was actually lost in the manner discussedabove and how much became spent for the first time, and therefore counted. This may be done throughrecordkeeping, determining a solvent use/loss ratio, knowledge of the process and materials used, or physicalmeasurements.

To simplify this determination, it would be acceptable to count the make up toward the monthly totals to deter-mine generator status. If the generator chooses to count make up, consider the following: Count �make up�added to the �system� to replace solvent lost through evaporation during a waste treatment or recycling process.These evaporative losses are considered waste. Do not count �make up� added to replace solvent lost during thecleaning process (i.e., solvent on parts, evaporative losses).WWWWWastes lost thrastes lost thrastes lost thrastes lost thrastes lost through mishandling and spills:ough mishandling and spills:ough mishandling and spills:ough mishandling and spills:ough mishandling and spills: Any dangerous waste generated through mishandling/spillswould not fit the requirements of the �multiple counting exemption� is are therefore counted toward thegenerator�s monthly generation status.



Counting and Treatment by GeneratorThe �Treatment by Generator� (TBG) provisions found in WAC 173-303-170(3) and -200 allow generators totreat their own dangerous waste on-site without obtaining a RCRA �TSD� treatment permit. For additionalguidance, refer to TIM Number 89-3 (revised July 1993), titled �Treatment by Generator.�

Dangerous waste counted under TBG:Dangerous waste intended for treatment under the TBG allowance is counted toward the generator�s statusbefore it is treated (see Flow Chart 2). A TBG activity is considered a separate activity from the production orcleaning process originally generating the dangerous waste. Therefore, dangerous waste derived (generated)from a TBG activity is also counted toward the generator�s status.

Dangerous waste not counted under TBG:Waste not counted under TBG includes wastes derived from the TBG activity which do not designate as danger-ous waste. Also, dangerous waste from TBG activities that are directly discharged into the POTW system incompliance with the domestic sewage exclusion (WAC 173-303-071(3)(a)) are not counted.

The following flow diagram is intended to help explain when counting is applicable when treating waste underthe TBG provisions:

FFFFFlololololow Diaw Diaw Diaw Diaw Diagggggrrrrram Number 6am Number 6am Number 6am Number 6am Number 6Point of��(C)��treat in��if DW��(C)��properly managedGeneration TBG unit

Point of��(C)��treat in��if non-DW��(NC)��properly managedGeneration TBG unit

Point of��(C)��90/180 day��(NC)��to TBG��if DW��(C)��properlyGeneration accumulation unit managed

Point of��(C)��treat in TBG unit & then*��(NC)��POTWGeneration direct discharge to POTW

(C) means count dangerous waste.(NC) means no counting of dangerous waste.SA means satellite accumulation under Section 200.SW means solid waste.* means when the DSE applies.

Appendix G



Counting and Permit by RuleThe Permit-by-Rule (PBR) provisions allow on-site treatment of dangerous waste without a written RCRA �TSD� treat-ment permit under certain conditions. For PBR to apply, generators must treat their waste only in a wastewater treatmentunit, elementary neutralization unit, or totally enclosed treatment unit. Details are outlined in Flow Chart 2, as well as inWAC 173-303-040 and -802(5).

Dangerous waste counted under PBR:Dangerous wastes removed from the PBR unit and no longer covered by the PBR provisions, such as sludge removed forland disposal, are counted.

Dangerous waste not counted under PBR:Wastes managed immediately upon generation in an on-site PBR unit are not counted. The key term in this provision is�immediately�, which means as soon as the waste is generated it must directly enter a PBR unit. There is no temporarystorage, accumulation or other type of management of waste between the point of generation and the PBR unit. Also,dangerous waste discharged in compliance with the PBR provisions are not counted. For example, wastes discharged incompliance with the unit�s NPDES discharge permit.The following flow diagram is intended to help explain when counting is applicable when treating waste under the PBRprovisions:

FFFFFlololololow Diaw Diaw Diaw Diaw Diagggggrrrrram Number 7am Number 7am Number 7am Number 7am Number 7Point of��(NC)��immediately��(NC)��DW disposed in compliance withGeneration managed in a PBR provisions (i.e., DSE or NPDES

PBR unit permit)

Point of ��(NC)��immediately��(C)��DW disposed �outside� of the PBRGeneration managed in a in provisions (e.g., sludge)

PBR unit

Point of��(C)��90/180 day��(NC)��to PBR��see above twoGeneration accumulation unit diagrams

or SA

(C) means count dangerous waste.(NC) means no counting of dangerous waste.(SA) means satellite accumulation under Section 200.



Counting and Annual Reporting RequirementsThe second reason to count hazardous waste under the Dangerous Waste Regulations is to comply with annualreporting requirements associated with submitting a Dangerous Waste Annual Report. All generators, transport-ers, TSDs and recycling facilities with a RCRA Identification Number are required to complete the annualreport for each calendar year in which their ID number is active.

A generator must count and record the amount of dangerous waste generated, accumulated and recycled eachmonth for the reporting year. The generator�s status for the purpose of completing the Annual Report forms isdefined based on the greatest quantity of dangerous waste generated in any one calendar month or accumulatedat any time during the year.

The generator must know whether they are a small (SQG), medium (MQG), or large quantity generator (LQG)to know which Annual report forms to fill out. For example, if a generator is an SQG for most of the year butbecomes an MQG for one month, the generator would fill out the reporting forms required for an MQG.

Annual Report Book 1:The �Annual Report Book 1� contains forms and instructions. Worksheets are available to help the annualreporter select their correct reporting status and determine which forms to fill out. SQGs and transporters fill outlimited information. Refer to the Dangerous Waste Annual Report instructions for further details.

Appendix G

66W


ent of Ecology

Counting Dangerous Waste Under the Dangerous Waste Regulations

1) Direct DischargeUnder DomesticSewage Exclusionor NPDES discharge

Not Applicable

Not Applicable

Not Applicable

2) Accumulation/ Satellite AreaWastes

Count

Do Not Count

Do Not Count

3A)On- Site

CountIf accumu-lated

Count

Do NotCount - Ifa product

3C)Off- Site

Count

NotApplicable

NotApplicable

4) TreatmentbyGenerator

Count

Count

*Count*Do not count ifdirect dischargeunder the DSE

5) Permitby Rule

Do Not Countif immediatelyenters PBR

Count

Do NotCount - ifdischargedunder DSE orNPDES

Recycling Process / #3)

3B)On- Site,closed loop

Do Not Count

Count

Do Not Count -if in “loop

WWWWWASTE ASTE ASTE ASTE ASTE TYPETYPETYPETYPETYPE

A) Wastes going intothe treatment/ recyclingprocess or toaccumulation

B) Residues generatedas a result of theprocess or toaccumulation

C) Wastes fromtreatment/ recyclingprocesses oraccumulation that still

ProductionTreatment or

Recycling ProcessTSD or POTW

or NPDES

A) Wastes going into process B) Residues C) Wastes that are treated, recycled or

What to �Count� Matrix


APPENDIX H

SHOPTSHOPTSHOPTSHOPTSHOPTALK ARALK ARALK ARALK ARALK ARTICLE ON SPECULTICLE ON SPECULTICLE ON SPECULTICLE ON SPECULTICLE ON SPECULAAAAATIVE ATIVE ATIVE ATIVE ATIVE ACCUMULCCUMULCCUMULCCUMULCCUMULAAAAATIONTIONTIONTIONTION(Summer 1997, Volume 7, No. 3)

Is It A PrIs It A PrIs It A PrIs It A PrIs It A Product Or A Woduct Or A Woduct Or A Woduct Or A Woduct Or A Waste?aste?aste?aste?aste?

Are the materials described below products or wastes?

4 A large painting contractor has over fortycontainers of unused paint and used thinner.He stores them outside his main shop and sayshe plans to remix them or use them �as is� onfuture jobs.

4 A chrome plating company keeps eight drumsof spent hydrochloric acid in its storage area.The manager says they can regenerate the acidand use it again for parts cleaning andstripping.

4 Seventeen various-sized containers of lubeoil, cutting oils, machine coolant and paint arekept behind a machine shop. The operatorbought them as a �lot� at an auction. He usessome of the cutting oils, but has not yet founda use for the rest.

�Southwest Regional Office Hazardous Waste Special-ists Nicky Rushing (right) and Joe Cason (left) go overa checklist from a recent inspection. As complianceinspectors, they often need to decide if a material is aproduct or a waste.�

Normally, it is relatively easy to tell when something isa waste�the business operator says it is. In theexamples above, the operators plan to eventually usethe materials. The Dangerous Waste Regulations allowgenerators to reuse or recycle materials without callingthem dangerous wastes.

Ecology staff occasionally come across materials thathave been stored for several years without any attemptto use them. When this happens, inspectors ask a seriesof questions to decide if the materials are still useableor if they have become dangerous wastes.

1) Are there signs of spills or releases?Spills and leaks indicate containers have beenneglected, attacked by the weather or are corrod-ing.

2) Does the owner know what the materials are?Product labels, Material Safety Data Sheets, andsales brochures list what materials are as well astheir age, hazards and if they can be reused orrecycled.

3) Are the materials managed in the same way asother products kept on-site?Materials should be kept indoors in sealed, labeledcontainers. This shows that the owner values them.

4) How old are the materials and what conditionare they in?Materials can deteriorate with age and exposure tothe elements. They should not be past the productshelf life or contaminated with rust or water,which makes reclamation difficult and expensive.

5) Can the business show that it has the ability touse or recycle the materials?A business shows a pattern of use or recycling byhaving the equipment or contracts in place, or bykeeping records showing that reuse occurs.Generators must show that 75 percent of anaccumulated material has been legitimatelyrecycled over the course of a calendar year. If thisis not possible, the material becomes a solid wasteand possibly an illegally stored dangerous waste.All dangerous waste must be properly managedunder the conditions of the Dangerous WasteRegulations.

The answers to these questions can uncover a situationthat could threaten the environment. If there is littleevidence to support a claim that materials can or willbe used as products, Ecology may declare them to bewastes. The owner of the materials must then deter-mine whether they are dangerous wastes and managethem accordingly.

Questions? Call your local Ecology regional office andask for a Hazardous Waste Specialist.

Appendix H

paint and coatings manufacturing sector - p2ric

Documents