paint manufacturing industryhazardous waste minimization audit studies on the paint manufacturing...

WASTE AUDIT STUDY

PAINT MANUFACTURING

INDUSTRY \

PREPARED FOR

ALTERNATIVE TECHNOLOGY SECTION TOXIC SUBSTANCES CONTROL DIVISION

CALIFORNIA DEPARTMENT OF HEALTH SERVICES

PREPAREDBY

HTM DIVISION JACOBS ENGINEERING GROUP, INC.

251 SOUTH LAKE AVENUE PASADENA, CA 91101

APRIL 1987

HAZARDOUS WASTE MINIMIZATION AUDIT STUDIES

ON THE

PAINT MANUFACTURING INDUSTRY

Prepared by:

Jacobs Engineering Group, Inc.

251 South Lake Avenue

Pasadena, CA 91101

. Prepared for:

Department of Health Services

Toxic Substance Control Division

Alternative Technology Section

Sacramento, California

April 24, 1987

Jacobs Project No. 27-8671-00 DHS Contract No. 85-87152

ABSTRACT

In California, the Department of Health Services (DHS) is charged with promotion of efforts to reduce the generation of hazardous waste- Accordingly, DHS has retained Jacobs Engineering Group, Inc. to conduct a waste audit study of select paint and coatings manufacturing plants. The objective of the study was the evolution of general guidelines that would allow other similar plants to address numerous waste minimization options.

Waste audit studies were conducted at three paint manufacturing plants in the L o s Angeles area. The audited plants were selected based on their willingness to participate, applicability to study objectives, and potential usefulness of data derived from the audit to the industry as a whole.

The results of the first two audits were utilized to prepare a general Self-administered waste audit checklist. This 'checklist was sent to the third plant for testing of its effectiveness as a self-audit tool. The checklist is broken down into the following categories: facility characterization, raw material hand1 ing , material substitution and product formulation, process operation, plant operations management,' and waste management. The checklist was developed as a tool for the industry to systematically evaluate their current processes and operations for additional waste minimization potential.

i

I

ACKNOWLEDGEMENTS

Jacobs Engineering Group, Inc. would like to acknowledge the efforts of those individuals who contributed to this report. In particular, we wish to thank David Leul Benjamin Fries, Kim Wilhelm, and Jan Radimsky of the Alternative Technology Section at the California Department of Health Services; Deborah Hanlon of the County of Ventura; and the technical and management staff of the cooperating firms for their invaluable support and guidance.

This report was submitted in fulfillment of Contract No. 85- 87152 by Jacobs Engineering under the auspices of the California Department of Health Services. Work f o r this Final Report was completed as of April 24, 1987.

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DISCLAIMER

The statements and conclusions of this report are those of the Contractor and not necessarily those of the State of California. The mention of commercial products, their source, or their use in connection with material reported herein is not to be construed either as actual or implied endorsement of such products.

CONTRACTS

c o n t r a c t N o . 85-87152 provided $ 2 4 , 7 2 5 t o prepare t h i s r epor t . N o subcont rac tors w e r e involved i n t h e p repa ra t ion .

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CONTENTS

Chapter

ABSTRACT

ACKNOWLEDGEMENTS

DISCLAIMER

CONTRACTS

LIST OF FIGURES

LIST OF TABLES

1.0

2.0

3.0

4.0

5.0

6.0

7.0

SUMMARY AND CONCLUSIONS

INTRODUFTION

PROJECT APPROACH

CURRENT REGULATORY ASPECTS

4.1 Regulations Relevant to the Paint Manufacturing Industry

4.2 Regulatory Agencies

WASTE MINIMIZATION AUDIT GUIDELINES

5.1 Existing Incentives for an Audit

5.2 Self-Audit Guidelines

REFERENCES

GLOSSARY

Pase

i

ii

iii

iv

vii

viii

1

5

6

7

7

12

13

13

13

15

16

I

CONTENTS

Pase

APPENDICES

A WASTE REDUCTION AUDIT REPORT FOR PLANT A A-1

B WASTE REDUCTION AUDIT REPORT FOR PLANT B B-1

C PRELIMINARY SELF-AUDIT CHECKLIST AS COMPLETED BY PLANT C

EXHIBIT

WASTE MINIMIZATION AUDIT CHECKLIST FOR PAINT MANUFACTURING PLANTS

e-1

E-1

V I

I

LIST OF FIGURES

Paae Ficrure

A-1

A-2

A-3

A-4

A-5

A-6

A-7

A-8

A-9

B-1

B-2

B-3

B-4

Annual Production Rates of Paints at Plant A since 1982 A-3

Dispersion and Let-Down Steps - Prevalent Route A-6

Dispersion and Let-Down Steps - Minor Route A-7

Let-Down Operation for Stationary Tanks at Plant A A-a

Let-Down Operation for Portable Tanks at Plant A A-9

Management of Solvent Cleaning Waste at Plant A A-10

Aikaline Cleaning of Portable Tanks and Aqueous Wash Residuals Reclamation at Plant A A-11

Amount of Waste Landfilled by Plant A since 1982 A-14

Specific Waste Generation Rates for Plant A since 1982 A-22

Primary Dispersion Process for Paint Manufacture at Plant B B-5

Let-Down Operation for Portable Tanks at Plant B B-6

Container Cleaning Operation at Plant B B-7

Lay-out of Solvent Input Lines at Plant B B-8

LIST OF TABLES

Table

1

A- 1

A-2

A- 3

A- 4

B-1

B-2

B-3

B-4

B-5

B-6

B-7

B-8

B-9

E-1

E-2

E-3

List of Codes -and Regulations Relevant to the Paint Manufacturing Industry

Raw Materials Used at Plant A

Origin and Treatment/Disposal of Paint Manufacturing Process Wastes at Plant A

Summary of Source Reduction Measures for Plant A

Summary of Recycling and Resource Recovery Measures for Plant A

Coatings Produced by Plant B in 1985

Raw Material Consumption Rates at Plant B in 1985

i

Raw Material Costs and Disposal Costs

Origin, Treatment/Disposal, and the 1985 Generation Rates of Paint Manufacturing Process Wastes at Plant B

Summary of Source Reduction Measures for Plant B

Summary of Recycling and Resource Recovery Measures for Plant B

Economic Aspects of On-Site Distillation

Economic Aspects of Replacing Cartridge Filters with Bag Filters

Economic Aspects of Replacing Bag or cartridge Filters with Wire Mesh Filters

Paae

8

A-4

A-13

A-23

A-24

B-2

B-3

B-9

B-14

B-2 3

9-24

B-26

B-29

B-3 1

Principal Raw Materials' Receiving, Storage, Transportation, Consumption, and Cost Data E-4

Overall Material Balances for the Paint Manufacturing Plant E-13

Waste Description for a Paint Manufacturing Plant E-23

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1.0 SUMMARY AND CONCLUSIONS

SUMMARY

The objective of the study was to develop general guidelines in the form of a checklist for conducting self-administered waste reduction audit in paint manufacturing plants. The development of such guidelines was based on studies of waste minimization measures at three plants in the Los Angeles area. The audited plants were selected based on their willingness to participate, applicability to study's objectives, and potential usefulness of data derived to the industry as a whole. Plant A produces water-based architectural coatings, Plant B produces solvent-based industrial coatings and Plant C produces solvent-based finishing stains. It should be noted that the waste minimization efforts summarized in this study relate to the waste reduction within the plant boundary. The study did not address the,waste aspects of paint application and painted parts or stripped paint disposal.

The first two audits were conducted at Plants A and B. Results of these two audits were utilized to prepare a waste audit checklist to be completed by paint manufacturing plants as a self-audit. This checklist was sent to Plant C to test its effectiveness. The checklist is broken down into the following categories: facility description, raw materials handling, material substitution and products formulation, process operation, plant operations management, and waste management. The checklist was developed as a tool for the industry to systematically evaluate their current processes and operations for additional waste minimization potential.

Based on the results of Plant C waste audit, we conclude that the self-audit checklist has met its objectives. The audit team went through the checklist in detail with the staff of Plant C. It was indicated that the checklist forced them to review the operation in ways they had not previously done. As a result, the following waste-reducing methods were collectively evolved:

o Computerized inventory system.

o Solvent substitution (use water-based formulations)

o Waste segregation

o High-pressure spray cleaning

o Documentation of waste origins and generation rates

3 Increased supervision

In addition to these potential measures, Plant C currently incorporates the following procedures or practices:

o Inventory minimization

o Use of high level shutoff switches and flow totalizers for storage tanks

o Use of high solids formulations

o Dedication of equipment

o Reuse of solvent waste

o Light-to-dark product sequencing

o Standardizing cleanup solvents

Plant A is a large manufacturer of architectural coatings. The following primary waste minimization measures are currently employed here:

o Use of alkaline instead of caustic cleaning solutions

o Use of high-pressure spraying systems

o Dedication of let-down tanks

o Ensure proper batch formulation and scheduling

o Use of non-hazardous slurried pigments

o Rework of solvent waste into marketable products

o Use of water soluble bactericide bags

o Segregation of water- and solvent-based wastes

In 1985, Plant A ' s waste minimization efforts resulted in zero hazardous waste shipped off-site for landfill disposal.

Plant B produces solvent-based industrial finishes. The following waste minimization measures are currently used:

o Cleaning of mills with compatible solvent for let- down formulation

o Rework of off-specification and returned products

3 Raw material substitution

o Stationary tank dedication

o Reuse of spent solvent whenever possible

o Dry cleanup of spills

Additional measures that may be implemented at Plant B include the following:

o Improved production scheduling to minimize product transfer to intermediate storage and subsequent mill cleaning waste generation

the use of multiple containers o Recirculation of pigment and solvent which minimizes

o Replacement of caustic solution with more effective alkaline solutions

o Dewatering of caustic wash sludge

o High-pressure cleaning of stationary tanks

o Minimize unnecessary cleaning

o Light-to-dark sequencing

o Computerized inventory and waste documentation

o Use of bag or wire screen filters in place of disposable cartridge filters

o Use of slurried pigments

o On-site distillation

Of these potential waste minimization procedures, on-site distillation, minimization of unnecessary cleaning, replacement of caustic cleaning solution, and the use of wire screen filters are considered economically attractive. Of particular interest is on-site distillation unit which can provide an annual savings of $ 21,000 in solvent purchasing and disposal costs after a payback period of 1.9 years.

CONCLUSIONS AND OBSERVATIONS

Tank cleaning is the principal source of waste generation in - the paint manufacturing (batch formulation) process.

Numerous waste minimization techniques can be applied, however, procedure-oriented techniques, such as light-to- dark batch sequencing, xaximizing equipment dedication,

standardization of cleaning solvent, and avoidance of unnecessary cleaning are of special significance, because of

implementation. their minimal Capital requirement and ease of

Internal reuse or recycling of cleaning residues has proved extremely effective, at least, in one plant where hazardous waste generation was virtually eliminated by rework of residues into marketable product.

It is noted that on-site recycling of hazardous waste in the paint manufacturing facility usually means an increase in the product yield. Considering that some components of hazardous waste are the very same components that exit the plant as final products, the net global environmental benefit of on-site recycling efforts may be questioned. However, it also must be noted that the current regulatory framework and the economic incentives clearly favor such approach.

T h e use of stFctured checklist-based approach to reduce waste appears beneficial judging by the positive results of testing such a checklist at Plant C. The developed checklist (presented in the Exhibit) should not be viewed as rigid, all-encompassing methodology. Rather, it should be considered as a first-of-a-kind result subject to further refinement. The applicability of the checklist is not limited to paint manufacturing only - large parts of it could be useful for other manufacturing processes involving batch formulation.

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2.0 INTRODUCTION

The State of California Department of Health Services (DHS) is responsible for promoting the efforts to minimize the generation of hazardous wastes. Accordingly, the Department has initiated a waste audit study program to provide technical assistance to California industries. As a part of this program, DHS contracted with Jacobs Engineering Group, Inc. to conduct a hazardous waste minimization audit study of the paint manufacturing industry to identify the available source reduction and recycling options.

There are 219 paint manufacturing plants in California, of which 101 are located in the L o s Angeles County. In 1981, the U . S . paint, coating, and ink manufacturers contributed to a 44 percent market share for solvents El]. Solvents are used in the paint manufacturing industry as carriers for resins and pigments. Solvents are also used to clean the various prokess equipment used for production. Although cleaning solvents are often distilled and reused, a residual paint sludge remains. These residues contain solvents, and in some cases, toxic metals such as mercury, lead and chromium. Depending on the constituents, the wastes could be considered RCRA wastes F002 (halogenated solvents), F003 (non-halogenated solvents such as MEK, acetone, xylene, etc.), F004, or F005. The paint manufacturing industry in California disposed of 21,000 tons of solvent-bearing waste off-site. It was the highest-volume generator of manifested solvent wastes in 1984 [ 2 ] .

The scope' of this study consisted of conducting waste minimization audit studies at three paint manufacturing plants in the Los Angeles area, and developing generic self- audit guidelines for the paint manufacturing industry based on these studies.

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3.0 PROJECT APPROACH

The paint manufacturing plants for the waste audit were chosen based on their Willingness to participate, the applicability of the facility's operation to the study objectives, and the potential usefulness of the data derived from the plant audit when applied to other paint industry facilities. Based on these criteria, 3 plants were chosen as the study candidates. Plant A produces water-based architectural coatings, Plant B produces solvent-based industrial coatings, and Plant C produces solvent-based wood finishes. Thus, these three facilities represent a broad spectrum of paint manufacturing processes and are considered as a representative set for the entire industry, at least for the purpose of the present work. The waste audit involved the study of the facility operation, manufacturing process, waste generation and management practices, and the chqracterization of existing and available waste minimization options. Economic analyses were performed on chosen waste reduction options.

Initially, the waste audits were performed on Plants A and B and the audit reports prepared. Based on these studies, a set of waste audit guidelines were developed. These guidelines, presented in the form of a checklist, could be completed by a paint manufacturing plant conducting a self- audit. This checklist was then forwarded to the third plant, and the third waste audit report was then prepared based on the completed checklist. Based on the third audit, it was determined that the formulated guidelines were effective and thus can be used as a self-audit tool by a paint manufacturing plant.

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4.0 CURRENT REGULATORY ASPECTS

In this section, the various regulations relevant to the paint manufacturing industry are presented. A list of the various regulatory agencies is also provided.

4.1. Reaulations Relevant to Paint Manufacturina Industry

Table 1 contains a list of federal and state codes and regulations that are relevant to the paint manufacturing industry. The list contains existing and pending legislations on topics such as raw material handling, waste disposal, air quality, sewer discharge, etc.

The main regulatory concern at present is the November 8, 1986 landfill ban of halogenated and non-halogenated solvent wastes, as mandated by the 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA [ 3 ] . However, HSWA provide options for a delay of up to two years in the enforcement. On November 7, 1986, the Environmental Protection Agency (EPA) announced limited extensions on the landfill ban, stating the lack of sufficient treatment capacity [ 4 ] . According to the new restrictions, the spent solvent wastes F001-FO05 are .prohibited from land disposal starting on November 8 , 1986, unless one or more of the following conditions are met:

(1). The generator of the solvent waste is a small quantity generator of 100-1000 Kgs/month of hazardous waste;

(2). The wastes contain less than 1 percent total F001-FO05 solvent constituents:

(3). The solvent waste is generated due to actions taken under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980.

However, the solvent wastes listed in items 1 to 3 above will be banned from land disposal effective November 8, 1988. In the meantime, these wastes can be disposed in a landfill that is in compliance with the requirements specified in RCRA. Dilution as a means to meet the requirements stated in item 2 above is also prohibited as per the new EPA regulations [ 4 ] .

7

Table 1. ~ i s t o f Codes and Regulations Relevant t o the Paint Manufacturing Industry

+.. .............+..............................+......................................... +

I Category I Regulation/Rule I Descr i p t i on I + ...............+..............................+......................................... +

I A i r q u a l i t y I SCAQMD Rule 442 I Res t r i c ts discharge of organic materials1

I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I I I I I

I .

+- - - -

I SBAQMD Rule 317. I i n t o the atmosphere f r a n equipment in I I MBUAPCD Rule 416 I which solvents are used. I I BMQMD Regulation 8,Rule 35 I I 1 KCAPCD Rule 410 I I I SLOCAPCD Rule 407 H (1) I I +... . . . . . . . . . . . . . . . . . .---*.---*+-----------------------------. .----------+

I SCAom) Rule 413 I I I l a k l e d t o indicate t h e i r photochemical I

I Requires coatings and solvents t o be

I I reac t i v i t y . I +-.---.....--........--....----+-.-.---..-----.----...........-..-.------+ I SCAQMD Rule 1113 I 1 SBAQMD Rule 323 I tec tu ra l and special ty a rch i tec tu ra l I

I Establishes VOC standards f o r archi-

I MBUAPCD Rule 426 I coatings. I I BMQCT) Regulation &!,Rule 3 I I I KCAPCD Rule 410.1 I I I SLOCAPCD Rule 407 H (3) I I +.....---....-...----.....-....+-..-...-..------.--...----..-........--..+ I SCAQMD Rule 1141.1 I Establishes operating requirements f o r I I I coatings and inks manufacturing. I

I BMQllo Regulation 8,Rule 5 I I I liquids. I

I MBUAPCD Rule 429 I I KCAPCD Rule 413 I I

+.................-.-.--.....*.+--.........-...-...----.~~---.......-----+ I Deals wi th the storage o f organic

+..----.....-- --.-.....-.-.-.--+.-----...-.--------.....-.--------.-----.+ I DeaLs with organic l iquid loading.

+-...-......----......-.--.....+....-.........-....--.-.----........-----+ I sBAam Rule 322 I Proh ib i ts photochemic.al1y reac t ive metai l I SOLCAPCD Rule 407 H (2) I surface coating thinners and reducers 1 I I in the d i s t r i c t . I +..--.-......-.---. '--.-...--'-+--.--.-.-..--..-......--.......~~~.~~+ I SBAQMD Rule 324 I Deals wi th the disposal and evaporation 1 I KCAPCD Rule 410.2 I solvents. I I EMQMD Regutation 8,Rule 39 1 I I SLOCAPCD Rule 407 H ( 4 ) I I

- - - - - - . - + - - . . . - - - - - - - - - - - - - - - - - - - - - . - - . - - - + - - - - - - . . - . . - - - . - - - - - - - - - - - - - - - . . - - - - - - . - - -

Notes: AQW - A i r Qual i ty Management D i s t r i c t APCD - A i r Po l l u t i on Control D i s t r i c t SE - Santa Barbara KC . Kern County BA - Bay Area MBU - Monterey Eay U n i f i e d

SC . South Coast VOC - Vo la t i l e Organic Chemicals SLOC ~ San Luis Obisw County

8

Table 1. L i s t of Codes and Regulations Relevant t o the Paint Manufacturing Industry (Continued)

+ ................+.................+..........................................+........................ +

I Category I Regulation/Code I Descript ion I Remarks I

I waste treatment1 CHSC 25715 I Provides a l i s t i n g of recyclable I I I o r disposal I I hazardous wastes foud by DHS t o k I I I I 1 econanically and technical ly feasible I I

I I to recycle. I I I I

+ ................+.................+..........................................+........................ +

+ .................+..........................................+....................... .+

I T i t l e 22, CAC I Provides a l i s t of recyclable wastes I I I 66796. I and suggests methods of recycle. I I + .................+..........................................+........................ .

I I T i t l e 22, CAC I I f a “recyclable88 waste i s disposed then I

I I I explain why the waste was not recycled. I I I 66763 I DHS may request the generator t o I

I I I The generator nust respond. I

I I CHSC 25190 1 Sanctions speci f ied fo r non-canpliance I I I

* I I I CHSC 25155.5 I Requires incinerat ion of hazardous wastes1 I I I I I I Hazardous waste wi th VOCs in spec i f ied I I I I I comentrat iorw t o be determined by DOHS I I

I I by January 1, 1987. I Effective1990 I I I

I I I hazardous waste i n t o a surface I I I I i q ” n t . I I I

I

1,and 25186 (c) I to the above regulations. I I +.-.--..-.......--+...----.--.---.-.............-..-....-----+.--..*.-.---.--......-*-+

I with greater than 3000 BTU/lb and I E f fec t i ve 1988 I

+..-------.......-+ ....--.-.....-.---.........*..-...--------+.---.........-.------.-.+ I I CHSC 25208.4 I Prohibi ts discharge of any liquid I Ef fec t i ve June 30, 19881

+“.- .--------.-..+...........*.......-.....-.--..+.------------.-.....--..+ I CHSC 25202.9 I Requires amur1 c e r t i f i c a t i o n by I I I generators of a TSD f a c i l i t y that a waste( I I minimization program i s in operation. I I I Further, i t m s t demonstrate tha t the I I I disposal method minimizes threat t o hunanl

I I health and the e n v i r m t . I , ................+.................+..........................................+........................ +

Notes :

1. CHSC - Ca l i fo rn ia Health and Safety Code 2. CAC - Ca l i fo rn ia Adninistrat ive Code 3. DHS - Department of Health Services 4. vOC - Vo la t i l e Organic Compounds 5. TSD - Treatment, Storage, or Disposal

9

Table 1. L i s t o f Codes and Regulations Relevant t O the Paint Manufacturing ~ d u s t r y (continu&)

+ ................+..................+...........................................-.................... +

1 Category I Regulation/Code I Descript ion I Remarks I + ................+..................+................................................................ +

I CHSC D iv is ion 2 , I Regulates underground storage of hazardous1

I Chapter 617 I substances. I

I . I I

I CAC T i t l e 22, I I Div.4: Ch.30, I solvents. I I A r t i c l e 23 I I

I Regulates the use and management of

I Wastewater I Clean Water Act I Water q u a l i t y control f o r waste water I I I discharge I 32 U.S.C. 1251 I disposed i n surface waters, M i c i p a l I I

I e t seq. I sewers, and in jec t i on net t . I I I . I

I I Safe Drinking I Water q u a l i t y control f o r waste water I I I I Water Act. I disposed in surface naters, municipal I I

I 40 CFR 141 I s m r s , and in jec t i on uell . I I I I I I NPDES regulations1 Regulat iom on the reduction o f po l lu tan t I I I I 40 CFR 122 I discharges i n to the waters of the United I I I I I States. I I

+..-.-.--.---------+-------...--..-.---.-...-................-.+.-------------------+

+-------...-.-----.+.---.--.--.-.--...-....---.------.......---+---------.--.---.---+

................+..................+...........................................+.................... +

Notes :

CHSC - Ca l i fo rn ia Health and Safety Code CAC - Ca l i fo rn ia Adninistrat ive Code DHS - Department of Health Services NPDES - National Pol lutant Discharge El iminat ion System CFR - Code of Federal Regulations USC - United States' Congress

13

Table 1. L i s t of Codes and Regulations Relevant t o the P a i n t Manufacturing I rdus t ry (Continued)

+... ............+.....................+.........................................+........................ ...*

I Category I Regulation/Code I Descript ion I Remerks I

I Land disposal I CHSC 25122.7 ~

+ ...............+.....................+.........................................+........................... +

I I and T i t l e 22 I hazardous uastes (e.g. uastes containing1 halogenated organics,and I I I 7/8/87 fo r organic sludges( I I I conpounds1 1 and so l ids containing I I I I I halogenated conpaunds. I

I Prohib i ts land disposal of r e s t r i c t e d I E f fec t i ve 1/1/85 f o r I

I CAC 66900-66935 I more than 1000 mg/kg o f halogenated

+.............*.......+-...-..-....-....------------------------+--.-----..-*---------------+

I 40 CFR 264.314 I Prohib i ts Land disposal o f bulk or non- I Ef fec t i ve May 8, 1985 1 I (b) I containerized l iquid hazardous waste o r I I I I hazardous uaste containing f ree l iqu ids. I I + .....................+.........................................+........................... +

I RCRA 3004 (e ) ( 1 ) I Prohib i ts land disposal o f most solventsl E f fec t i ve Novrmber 8, 19861

I I I I consti tuents) are met. I I

I unless treatment Levels ( 2 ppn f o r most I

+... . . . . . . . . . . . .------+-.-----.-*. . . . .--------*-------.- . . .-----+----. .---.-------------.--.+

I General I 40 CFR 046 I EPA guidelinea and standards f o r Paint I I I I formulating industry. I

Notes :

CHSC - Ca l i fo rn ia Health and Safety Code CAC - Ca l i fo rn ia Adnin is t ra t ive Code DHS - Department o f Health Services RCRA - Resource Conservation and Recovery Act CFR - Code o f FederaL Regutations

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4.2. Reaulatorv Asencies

The following is a list of some regulatory agencies that may be concacted with questions on the handling and disposal of paint manufacturing wastes:

Aaencv

U.S. EPA RCRA Hotline

Office of Solid Waste EPA, Washington DC

Department of Health Services Toxics Division, regional offices

Emeryvi 11 e L o s Angeles Sacramento

\

Office of Permit Assistance

Telephone Number

(800) 424-9346 (800) 231-3075

(202) 382-4770 (a)

(415) 540-2043 (213) 620-2380 (916) 739-3145

(916) 322-4245

Regional Water Quality Control Boards

Los Angeles region Oakland region Palm Desert region Sacramento region San Diego region San Luis Obispo region Santa Ana region Santa Rosa region South Lake Tahoe region

(213) 620-4460 (415) 464-1255 (619) 346-7491 (916) 445-0270 (619) 265-5114 (805) 549-3147 (714) 782-4130 (707) 576-2220 (916) 544-3481

(a) For technical information on solvent waste disposal.

5 . 0 WASTE MINIMIZATION AUDIT GUIDELINES

Waste minimization audits were conducted in three cooperating paint manufacturing facilities in the L o s Angeles area. The audit reports for the these plants are provided in Appendices A, B, and C. Based on the experiences associated with these audits, waste minimization audit guidelines were developed for the paint manufacturing industry and are presented in this section.

5.1. Existina Incentives for an Audit

There are both regulatory and economic incentives for conducting a waste minimization audit. As seen from Table 1, the generator is required to submit a report once every two years on his waste reduction efforts. Waste audits are encouraged, but are not required by law.

Due to the prevailing regulatory mood it is safer for the . waste generators to be in an anticipatory mode, as opposed to a reactive mode. It is better to identify and correct problems associated with waste generation in order to minimize liability and to avoid future fines. One aspect of waste minimization is better raw material utilization, which translates into better production efficiencies with associated cost savings. Production costs and disposal costs can be cut simultaneously by doing a review of the existing operating practices, as demonstrated by the waste audits and the checklist presented below.

5.2. Self-Audit Guidelines

A sample checklist for self audit for a paint manufacturing plant is shown in the Exhibit. The checklist is meant to walk the user through the process and force a systematic compilation of information. Such information would be used to develop a set of waste minimization options. The checklist addresses the following topics:

Facilitv DeSCriDtiOn section includes such items as product types (solvent- or water-based), their relative production rates and sales volumes. The production rates for the last four years need to be provided to indicate the trends in the market demand or in the degree of product substitution.

Raw Materials Handlinq section compiles information on the wastes associated with raw material handling and the associated source reduction measures. After compiling this

~ information, the generator can focus his efforts on specific waste streams that require immediate attention.

1 3

Material Substitution and Proauct Reformulation section gathers information on the potential f o r raw material substitution or product reformulation to decrease and/or eliminate hazardous wastes.

Process ODeration section walks the auditor through the paint manufacturing process, identifying along the way the origins of waste generation. By conducting an overall material balance (see the Exhibit), the generator (or the auditor) gets an overview of the lost raw material or production. Specific processes such as dispersion, let-down, filtering & filling, and portable tank and container cleaning, are addressed separately. Source reduction/ resource recovery methods that are applicable to each of the processes are also presented to allow the auditor to make a quick assessment of the need for additional minimization measures.

Plant ODerations Manaaement section addresses the key factors related to waste minimization : management attitudes and operating practices. The importance of production scheduling, arid management practices such as employee training programs, waste minimization goals, etc., in relation to waste minimization are illustrated in this section.

Waste Manaaement section gathers information on the existing waste management practices and the possible options to some

. management methods.

6.0 REFERENCES

1. Pace Company Consultants and Engineers, Inc. Solvent Recoverv in the United States 1980-1990., Houston, TX, 1983.

2. ICF Consulting Associates, Jacobs Engineering Group, and Versar. Guide to Solvent Waste Reduction Alternatives. Prepared for California Department of Health Services, Alternative Technology and Policy Development Section, October 10, 1986.

3. Resource Conservation and Recovery Act (RCRA) 3004 (e) (1) 1984.

4. Bureau of National Affairs. 40 CFR 268, EPA Realations of Land DisDosal Restrictions, Section 268.3, Washington DC, November 28, 1986.

15

7.0 GLOSSARY

APCD AQMD BA CAC CERCLA

CFR CHSC DHS EPA HSWA KC MBU MEK NPDES osco PRI RCRA SB sc SLOC TSD USC voc

Air Pollution Control District Air Quality Management District Bay Area California Administrative Code Comprehensive Environmental Response, Compensation, and Liability Act Code of Federal Regulations California Health and Safety Code Department of Health Services Environmental Protection Agency Hazardous and Solid Waste Amendments Kern County Monterey Bay Unified Methyl Ethyl Ketone National Pollutant Discharge Elimination System Oil and Solvent Processing Company Progressive Recovery Incorporated Resource Conservation and Recovery Act Santa Barbara South Coast San Luis Obispo County Treatment, Storage, and Disposal United States' Congress Volatile Organic Chemicals

APPENDIX A

WASTE MINIMIZATION AUDIT REPORT

f o r

PLANT A

A . 1 . FACILITY DESCRIPTION

Plant A produces a wide variety of architectural coatings. Plant A manufactures 76 lines of paint products and eight lines of aerosol spray paints for distribution through retail outlets, and 55 lines of aerosol and specialty paints for sale through distributors. About 80 percent of the paints produced at this facility are water-based and the remainder are solvent-based. The water-based coatings are latexes and the solvent-based coatings are mostly alkyd resins dissolved in solvents. Figure A - 1 presents the annual production rates of paints since 1982. Most of the paints produced by Plant A are for use by the general public.

A . 2 . R A W MATERIALS MANAGEMENT

The raw materials used at Plant A include resin solutions, emulsions, solvents, pigments, bactericides, fungicides, extenders, etc. ,Some defoamers and surfactants are also added to the water-based batches. Table A-1 lists the principal raw materials used by Plant A in 1985.

The solvents used at this facility include aliphatics, aromatics, ketones, or glycol ethers. Glycols such as diethylene glycol, propylene glycol, or Texanol are added to the water-based

. formulations to increase the paint drying time and to act as an anti-freeze. The solvents are either delivered and stored in drums or delivered in bulk and held in the above-ground diked storage tanks.

The pigments are delivered in bags when used in powder form, and in drums or in bulk when used in slurried form. The use of slurried pigments is predominant in water-based formulations. Some solvent-based formulations use pigments in paste form, which are purchased in 5 gallon containers.

A complete inventory check is done 4 times a year, though limited inventory checks are done on a daily basis. Plant A is planning to convert from a manual to a computerized inventory system.

T

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Table A-1. Raw Materials Used at Plant A

Description Material

Solvents

\

Resins

Pigments

Extenders

Miscellaneous Additives

Aliphatics Aromatics Ketones Alcohols Diethylene glycol Propylene glycol

Acrylics Vinyl-acrylics Alkyds

Titanium dioxide Organic pigments Red oxide Yellow oxide Other inorganic pigments

Calcium carbonate Clay Talc Silicates

Bactericides & fungicides Surfactants & defoamers Viscosity modifiers Ammonia Others

1-4

A . 3 . PROCESS DESCRIPTION

The following paragraphs describe the production of paints at Plant A. Figures A-2 through A-7 show the block flow diagram of the process. The description is general enough to apply to the production of both solvent- and water-based paints in most cases.

The first step in paint production is the dispersion of the pigments (see Figure A - 2 ) . The pigments in emulsion or slurry form, along with the solvents, resins, and additives are added directly to a mill in the primary dispersion step. The dispersed material from the mill is then pumped directly to the let-down tanks. In less than 5 percent of the cases, the pigments (in emulsion, slurry, or dry fom) are added to other raw materials in a portable tank or a small container. The contents of the tank or container are then dispersed in a sand mill, ball mill, or high-speed mill and either collected in another portable tank or directly added to the let-down tank. In all cases, the portable tanks or containers are reused several times without any cleaning but are ultimatdly sent for cleaning.

The dispersion mills are dedicated to a particular type of product to the fullest extent possible. The dedicated mills are not cleaned. The non-dedicated mills are purged with solvent or water at the end of the dispersion process and the wash material

. is mixed with the dispersed product in the let-down step.

In the let-down step (see Figures A-4 and A - 5 ) , the dispersed pigments from milling operation are mixed in portable or stationary tanks with additional diluents, resins, and additives. The tanks have capacity varying from 50 to 10,000 gallons. The additives constitute bactericides, fungicides, surfactants, defoamers, or extenders. The bactericides and fungicides used for water-based batches are mercury based whereas non-mercurials are used for solvent-based batches. Solvents, such as diethylene glycol or propylene glycol are added to water-based paints to extend the drying time and act as an anti-freeze in cold climates.

The stationary tanks have a capacity greater than 4 0 0 gallons while the portable tanks have a 50 to 400 gallon capacity. About 25 percent of the total number of batches are let-down using portable tanks, which accounts for less than 10 percent of the total paint volume produced at Plant A . The mixing in the tanks is performed using turbine mixers. When the properties of the batch reach the required standards, the mixing is stopped. The tank contents are then pumped through bag filters to the filling unit, which can fill 5 gallon, 1 gallon, 1/4 gallon, or 1j2 pint cans.

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1-6

1 Emulsion, slurry

PIGMENTS

WATER OR SOLVENTS

I I

BATCHING U

Note: The process shown in this diagram is used in less than 5 % of the cases. The most commonly used procedure for primary dispersion is shown in Figure A-2.

I 1

@ DISPERSION

I

4 . I

I a

Mill rinse with water or solvent

CLEANING See Figs. A-6,A-7

Figure A-3. Dispersion and Let-Down Steps - Minor Route

SIlldS . iy

El- Sll!dS

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Resins Water I Additives

. Dispersed pigments primary dispersion (see Figure A-2)

PORTABLE TANK

Q .'

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r

I Product 1 + SHIPPING/ container STORAGE

Figure A-5. Let-Down Operation for Portable Tanks at Plant A.

Reclaimed solvent

A b

Rinse solvent

L 1

I- O

Fresh solvent makeup

I

BLENDlNG FII TRATIOM

Figure A-6. Management of Solvent Cleaning Waste at Plant A

FlLLlNG

ALKALINE CLEANING

DIRTY I I TANK

Clean tank return

Makeup ~ + . Sludge ALKALINE +- solution CLEANING

MACHINE (Intermittent stream) See Note

AQUEOUS WASH RESIDUALS RECLAMATION SYSTEM

Required raw materials

Mote: The alkaline sludge and the rinse water stream are processed separately and are not albwed to mix. The same separation tank is used tor handling both streams. but at separate times. When treating alkaline sludge, acid neutralization is used.

I Settled solids

1 I

FlLLlNSFlLTRATlON BLENDlNG

Rinse water from cleaning ot stationary tanks

See Note

0 Water

STATDNARY TANK

Clarified 8 decanted wastewater to sewer

Figure A-7. Alkaline Cleaning of Portable Tanks and Aqueous Wash Residuals Reclamation at Plant A.

A . 4 . WASTE DESCRIPTION

The principal Wastestreams generated by Plant A include the following:

o Equipment cleaning wastes o Obsolete stock o Returns from customers o Off-specification products o Spills o Spent filter bags o Empty bags and packages

Table A-2 shows the various waste streams along with their origin and treatment/disposal methods used in the past and present. The waste generation rates for individual streams could not be established. Figure A-8 shows the amount of waste landfilled by Plant A since 1982 . A s seen from this figure, landfill disposal is no longer employed. From Table A - 2 , it is seen that the waste management methods have evolved into the present state, where most of the wastes are recycled, reused, or reworked. The following sections discuss each of these waste streams.

A . 4 . 1 . Equipment Cleaning Wastes

The process equipment is routinely cleaned to prevent product contamination and/or to restore operational efficiency. The resulting cleanup residuals constitute a major wastestream generated by the facility. Most of the cleanup wastes generated at Plant A are reprocessed into marketable products.

A . 4 . 1 . 1 . Mill cleaning

The mills are dedicated to a single type of product whenever possible. In such cases, post-batch cleaning of the mills is not necessary. If dedication of a mill to a single product is not possible, e.g. due to demand fluctuation, then cleaning is necessary. Cleaning is accomplished by flushing the mill either with water or a solvent, depending on the batch. The flush is then mixed with the batch in the let-down step. Thus, mill cleaning does not produce a disposable waste at Plant A .

A . 4 . 1 . 2 . Portable tank cleaning

Portable tanks are first scraped manually to remove residual clingage. Next, the tanks are washed with high pressure jets of a commercially available alkaline cleaning solution. The cleaning solution is recirculated and the blowdown or purge is sent to wastewater treatment. This process consists of flocculation and pH adjustment. The clear water effluent is drained to the sewer,

- and the settled solids containing 7 0 to 7 5 percent water are sent to a blending tank (see Figure A - 7 ) . Blending .with new material produces a beige-colored coating which is sold as a general purpose coating.

4-12

Table A - 2 . Or ig in and Treatment/DiswsaL of Paint Manufacturing Process wastes a t Plant A

+ ....+.................+..........................+.................................................. +

I I I 1 lreatment/Disposal Method I ] ..........+.........+.........+.........+......... + NO. (waste Description1 Process Or ig in

I I I I Before I 1983 I 1984 I 1985 I 1986 I ................+....-......................+..........+.........+.........+.........+......... +

Equipncnt I Solvent cleaning of I D I E I A I A I A I cleaning wastes1 process equipment . I I I I I I

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

I Uater cleaning of IF : before I G,H I 6 I 6 I 6 I I process equipment I 1976 I I I I I I 1G: star ted( I I I I I l i n 1976 I I I I I +---.--.---.----.-....-....+..-----.--+.-------.+-.----...+----.--..+--...--.-+

I 6 I F i l t e r bags I F i l t r a t i o n of paint I 1 I ~ I I I ~ I I I

I I packages I and other addit ives i n t o I I I I I I I I I mixing tanks I I I I I I

+....+ .................+..........................+..........+.........+.........+.........+...... ...+

I 7 I ERpty bags and I Unloading of pigments I I I I I I I I I I I

+ ....+.................+..........................+..........+.........+.........+.........+....... ..+

Notes:

A - Reused t o the extent possible, d i s t i l l on-s i te t o recover solvent, rework s t i l l bottoms 6 - Blend t o make a marketable product C - L a n d f i l l disposal (Discontinued in Septenkr 1986)

E - Same as A except that the s t i l l bottoms are land disposed F - Overflow discharge t o the sewer and l a n d f i l l disposal of the so l ids se t t led ih weirs G . Flocculat ion followed by discharge of decanted water t o the sewer and

H . Vacuum f i l t r a t i o n i . Sanitary l a n d f i l l a f t e r washing

- -D - O f f - s i t e recyc l ing

Land f i l l disposal o f the se t t led so l ids

4-13

0

0 0 e v

0 0 cv T-

0 0 0 7

0 0 a3

a v) c.

5 cc 0 v) t 0 I-

0 0 0 0 0 e cu

L. m a >-

a ?

4-14

A . 4 . 1 . 3 . Stationary tank cleaning

The stationary tanks are to a large extent dedicated to the making of a single product. In such cases, the residue on the tank walls (clingage) is allowed to build up to a certain thickness, before being scraped off manually. Following the manual cleaning, no further rinsing is necessary. The scraped paint residues were drummed and disposed of in a landfill until September 1986. Since that time, Plant A has developed a process to rework these residues into a useful product.

Non-dedicated tanks are rinsed with high pressure jets of water or hosed with solvent depending on whether the tank is used for water- or solvent-based product preparation. The rinse water is sent to a holding tank where it is blended with other aqueous wash streams to produce a general purpose paint following flocculation and pH adjustment. The rinse solvent is reused several times and then sent to an on-site still, where the solvent is recovered for reuse. The distillation bottoms are converted ipto a primer product by blending with solvents and other additives.

A . 4 . 1 . 4 . Filling unit cleanup

Separate filling units are used for water- and solvent-based paints. Filling units for water-based products are rinsed with water. The rinse water is sent for treatment as described previously. The filling lines used for solvent-based paints are back-flushed with a compatible solvent into the tank from which the product was drawn. The spent solvent is then reused or sent to the solvent recovery still, as described previously.

A . 4 . 1 . 5 . Container cleaning

The small containers (cans, pails, etc.) containing residual paint are sent for metal reclamation without any on-site cleaning. Containers in which mercury-based bactericides are delivered are returned to the supplier without any cleaning.

A . 4 . 2 . Obsolete Stock

Obsolete stock is the paint that is no longer marketed, or raw material that can no longer be used. The obsolete. paints that are made by Plant A are reworked into other marketable products. The obsolete raw material is returned to the suppliers.

4-15

A . 4 . 3 . Returns From Customers

AS with the obsolete stock, the returns from customers are reworked at Plant A into other Products and the empty containers are sent off-site for metal reclamation.

~ . 4 . 4 . off-specification Products

Off-specification products are the result of bad batches that are caused by errors in batch for"Ulati0n or the failure of quality control to detect off-specification raw materials. At Plant A , the off-specification products are reworked into other usable products.

A . 4 . 5 . Spills

Spills are inadvertent discharges that occur at various places in the plant. At Plant A , the spills are scooped up to the fullest extent possible. If the scooped up materials are water-based then they are sent to the water treatment unit. If they are solvent- based then they are sent to the solvent recovery still. The spills that cannot be scooped up are cleaned with commercially available adsorbents. The use of lldry" cleaning methods over manual scooping is discouraged, since it is difficult to rework the adsorbents containing the spilled material.

A.4.6. Filter Bags

Plant A uses bag filters for all filtering applications. Cartridge filters are not used due to the associated disposal problems. The spent bag filters (used for both water- and solvent-based products) are washed and dried and disposed as non-hazardous waste.

A . 4 . 7 . Empty Bags and Packages

Plant A has eliminated the use of all hazardous lead and chromate pigments, as most of the paints produced by Plant A are for use by the general public. Therefore, the presence of residual pigments does not make the bags/packages hazardous and thus they are disposed of as non-hazardous waste. In addition, since the pigments used at Plant A are mostly in slurried form, the use of pigments in bags and packages is limited.

A . 5 . SOURCE REDUCTION MEASURES

The following paragraphs describe the application and use of source reduction measures to various waste streams at Plant A .

-4-16

A - 5 . 1 . Equipment Cleaning Wastes

This stream constitutes a large portion of the total waste generated. The following currently used source reduction measures were noted:

o

In the past, the portable tanks and small containers were cleaned with caustic solution. Three years ago, the caustic cleaning solution was replaced by a proprietary alkaline solution. As the replacement frequency of this cleaning solution is half that of the regular caustic solution, the cleanup residuals' volume was reduced nearly by a factor of two.

Replacement of Caustic cleaning solution- I I

F 0 Use of high-pressure spraying systems. i

In the past, the water-based process equipment were rinsed clean with water from low-pressure hoses. Since this procedure generated a large quantity of wastewater, a portable high . pressure spraying system was purchased. This modification contributed to a reported 2 5 percent reduction in cleanup waste volume.

0 Dedication of let-down tanks.

The let-down tanks that make white paints are dacated to making whites alone which reduces the intermediate washing of these tanks to a minimum. The deposits in the stationary tanks are allowed to build up for a period of time and then are scraped off manually. Dedication of the stationary tanks contributed to a reported 5 to 10 percent reduction in associated cleanup waste volume, when compared to a previous situation where the tanks were not dedicated and hence required cleaning after each batch.

0 Proper batch scheduling.

At Plant A, certain batches are sequenced in the order of light to dark paint manufacture. This kind of scheduling often eliminates the need for intermediate cleanup steps.

I 0 Pigment substitution. 6 Plant A has already eliminated the use of lead and chromium pigments, since these pigments are prohibited from use in consumer products.

0 Non-mercury bactericides.

The only place where a raw material substitution will reduce the degree of hazard is for mercury-based bactericides. Non-mercury- based bactericides have replaced mercury-based counterparts i n

I a l l solvent-based paints but not in water-based formulations. k t

A - 1 7

Plant A continues to use mercury-based bactericides for water- based paints since their search for effective non-mercury substitutes was unsuccessful. It is suggested that the search for the substitutes should continue in spite of continual set backs.

A.5.2. Obsolete Stock

0 Prevent obsolescence of raw material.

Prevention of raw material obsolescence is accomplished by care- ful control and monitoring of the inventory. The raw material is used up as quickly as possible to avoid the expiration or degradation. The raw materials are accepted from the suppliers only when they meet the stringent quality control standards. When a raw material becomes obsolete, it is returned to the supplier.

0 Prevent obsolescence of finished stock.

Obsolete finished material can be virtually eliminated by proper production planning and inventory control. The current manual inventory control system is very efficient in limiting the ob'solete stock'. The company is planning to purchase a computerized raw material inventory control system. The computerized system is expected merely to provide more detailed information about the inventory in a shorter time period.

A . 5 . 3 . Off-Specification Products

The off-specification products are reworked on-site to produce marketable products. To achieve additional savings in reprocessing cost, however, reauction of off-specification product generation can be further promoted by proper quality control of the raw material, increased process automation, and by ensuring effective cleanup of equipment. Tight control measures have been extremely effective at Plant A.

A.5.4. Spills

As mentioned previously, the spills are first recovered by manual scooping, then reworked into useful products. Only the residuals remaining after the recovery are subject to IIdryll cleaning using adsorbents. Direct use of adsorbents (i.e. without prior recovery) is discouraged as the resulting waste is difficult or impossible to re-process.

A . 5 . 5 . Filter Bags

The use of cartridge filters was eliminated since their disposal proved problematic. Plant A , at present, uses bag filters for all purposes. These filters are reused to the extent possible. The spent bag filters when rinsed and dried are not considered hazardous waste.

A . 5 . 6 . Empty Bags and Packages

4-18

0 Use of non-hazardous pigments.

AS none of the pigments used at Plant A are hazardous, the empty bags and packages Containing residual amounts are not considered hazardous.

0 Use of pigments in slurry form.

Most of the pigments used by Plant A are in slurry or paste form, and therefore, the use of bags and packages for pigments is small.

0 Use of water-soluble bags.

Some of the mercury-based bactericides are delivered to Plant A in water-soluble bags. These bags are added to the batch along with the bactericides, thus avoiding the generation of waste in the form of empty bags and packages.

A.6 . RECYCLING AND RESOURCE RECOVERY MEASURES

The use of the following aspects of recycling and resource recovery were examined:

- waste segregation - on-site recycling - off-site recycling Each of these items is discussed in the following paragraphs.

A . 6 . 1 . Waste Segregation

0 Segregate water- and solvent-based wastes.

The solvent-based equipment cleanup wastes are segregated from the water-based wastes. This facilitates the rework of both these streams into marketable products. The solvent- and water-based wastes are reworked as shown in Figures A-6 and A-7, respectively. The rework strategies shown in these figures would not be effective if the waste streams are allowed to mix.

0 Segregate alkaline cleanup wastes from rinse water wastes.

The alkaline cleanup wastes are segregated from rinse water wastes. Both these waste streams are separately reworked (see Figure A-7) into useful products.

A - 19

A . 6.2. On-Site Recycling

0 Reuse of water-based equipment cleanup wastes.

In the past, partially dewatered cleanup wastes were landfilled. This procedure was modified 10 years ago by adding a flocculation step to remove the solids prior to discharging the stream to the sewer. The flocculated solids containing 70 to 75 percent water were disposed of in landfills. Six years ago this procedure was again modified by adding a vacuum filter to reduce the water content in the disposed solids to 30-35 percent.

Since all these process modifications still involved disposal of solids in a landfill, Plant A decided to pursue other process changes that would eliminate such disposal. This decision was based, in part, on anticipated landfill ban. Currently, the water-based equipment cleaning wastes are blended with additives after flocculation to generate a beige-colored product (see Figure A-7) which is sold as a general purpose paint. Thus, by rework, the landfilling of water-based equipment cleanup wastes is. avoided altqgether.

0 Reuse of alkaline cleaning wastes.

The alkaline cleaning of portable tanks generates a waste stream. This stream is segregated from the aqueous wastes described in the previous paragraph, but processed in the exact same manner

. (flocculation, pH adjustment and blending) to produce a marketable product (see Figure A - 7 ) .

0 Reuse of solvent-bearing cleanup wastes.

The cleanup solvents are reused several times for rinsing tanks. This procedure ensures that the total solvent usage for cleaning is minimized. When the rinse solvent is considered too dirty for direct reuse, it is distilled on-site. The solvent reclaimed by distillation is recycled to the cleaning operation. The distillation bottoms are sent to a holding tank, where they are blended with solvents and other raw materials to produce a primer product (see Figure A - 6 ) .

0 Rework wastes

All of the wastes due to customer returns, scraped paint residues, obsolete finished products, off-specification products, and scooped up spills are reworked into marketable products. Proper identification of the customer returns is central to

- determining the rework strategy for this waste. For the scraped paint residues (generated due to the mechanical cleaning of stationary and portable tanks), Plant A has developed a process to rework these residues into a useful product. This process is currently being refined.

4-20

A . 6 . 3 . Off-Site Recycling

In the past, the solvent-based cleanup wastes were sent to oil and Solvent Processing Company (OSCO) for reclamation. The reclaimed solvent was purchased from OSCO and reused. As this process proved expensive, Plant A discontinued off-site recycling four years ago in favor of On-Site recycling. At present, off- site recycling is practiced only on a sporadic basis.

A.7. ECONOMIC ASPECTS OF WASTE MINIMIZATION

The specific economic aspects of implementing each of the source reduction/resource recovery options were not separately documented by Plant A. Most of the source reduction aspects employed are essentially good operating practices, and hence did not require a large capital investment. However, the rework strategies and their evolution did require a large R&D expenditure, The implementation of these measures seemed to be guided more by the intuition and foresight of the plant personnel than by the calculated benefits that may have been indicated by an a priori detailed economic evaluation.

The plant personnel indicate that the increase in operating expense for rework breaks even with the increased revenues due to the sale of reworked products. The avoided disposal costs, however, are expected to be quite significant. In 1984, 181 tons of waste (equivalent to about 660 fifty-five gallon drums) was landfilled (see Figure A-9). In 1985, due to a comprehensive rework strategy, no waste was landfilled. Using present landfill disposal costs of $155/drum (charged, for example, by Rollins Environmental Services), Plant A saved $102,000 in avoided disposal costs as compared to 1984. Performing the same analysis for 1982, and using the same disposal costs, Plant A has saved $693,300 due to their comprehensive waste minimization efforts.

A . 8 . RATING OF WASTE MINIMIZATION MEASURES

Table A-3 lists the various source reduction measures noted above for each waste stream. Table A-4 lists the recycling and resource recovery options. Each measure is qualitatively rated on a scale of 0 (low) to 10 (high) for its waste reduction effectiveness, extent of current use, and future application potential. The waste reduction effectiveness indicates the amount of waste reduction that is possible by implementing a particular source reduction/recycle measure. The extent of current use, as the name implies, is a measure of current usage of a particular waste reduction option. The future application potential is a

44-21

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Table A-3. Suniiary of Source Reduction Measures for Plant A

Equipment Cleaning Wastes

1.Replacement of caustic cleaning solution 2.Use of high-pressure spraying systems 3.Oedication of let-down tanks 4.Proper batch scheduling 5.Pigment substitution 6.Use of non-mercury bactericides

9 7 9 9

10 10

Obsolete Stock 1.Prevent raw material obsolescence 2.Prevent finished stock obsolescence

10 10

Off-Spec Products 1.Ensurc proper batch formulation lo I Spi l ls I 9 I 1.Discourage dry cleanup nethods I filter Bags 10 I 1.Uas.h and dry before disposal I

9 8

10 10 10 0

8 6 9 9 10 0

lo I O I 1 ° 1 , . .+

8 i n

5 n

10 6 5

0 ---> 1

n ---

Table A - 4 . S m r y of Recycling and Resource Recovery Measures for Plant A

+ . . . . . . . . . . . . . . . . . . . . r . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . . . . . . . . . . t.-. .......... t... ..........+.............+............. +

Uaste

Effect i veness

+ ........................................+.............

Control Methodology Reduction

1.Segregate uater and solvent uastes

2.Segregate uater and alkali uastes

10

10

Recycling/Resource Recovery Measure

..................

Uaste segregation

Extent of Current Use

t.............

10

10

.................

On-site recycling

Future 4ppL i cat i on Potent i a1

Off-S + I .......

Current Reduction

Index

...........

.........+

te recycling

............

...

1 1. Off-site reclamation/incineration.

1. Reuse

2. Reuse

3.Reuse

rinse uater uastes

alkaline cleanup uastes

solvent-bearing cleanup uastes

10

10

10

10

10

10

.......

.......

.......

.......

Future Reduc t i on

Index

....+ .............

.......

............

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . O I O I O I +

qualitative measure of the probability that the measure would be implemented in the future. This probability is a function of the cost, degree of technical risk, and the extent of current use.

AS most of the waste minimization methods presented in this report are already in use to a large extent at Plant A , the future reduction index is low in most cases. The following source reduction measures are currently used by Plant A to a large extent: pigment substitution, proper batch scheduling, dedication of process equipment, prevent obsolescence of raw material, ensure proper batch formulation, and wash and dry filter bags prior to disposal.

The extensive rework of wastes is responsible for a zero waste generation at present and therefore given a zero future reduction index in Table A-4. The use of non-mercury bactericides and the the use of pigments in slurry or paste form are rated high for future application potential. These two measures, however, have a very low impact on reducing waste volume as these processes generate a small volume of waste to start with.

b

A . 9 . SUMMARY

The methods listed in Tables A-3 and A-4 have contributed to the elimination of the hazardous waste leaving the facility. Figures A-1 and A-8 show the production and waste generation rates for the last 4 years at Plant A. Figure A-9 shows the specific waste generation rates (lb waste/gal product) during the last four years. From Figure A-9, the effectiveness of the waste reduction program used by Plant A is clearly seen. The specific waste generation rate was reduced from 0.34 lb/gal in 1982 to zero in 1985. The following factors contributed to this successful waste reduction effort at Plant A:

- Proper planning and foresight. The problems associated with off-site waste disposal were anticipated well in advance and measures were implemented ahead of time. Total elimination of landfill disposal was a goal set by the management. Waste minimization and other environmental issues are given high priority.

- Proper perspective of the waste minimization issue. Good operating practices contributed to successful source reduction, recycling, and reworking of all the generated wastes. The research and development effort resulted in the formulation of new products from the waste and at the same time reduced the need for disposal.

- Experienced employees. The average seniority is well over 10 years for the employees at Plant A . As the employees

-4-25

understand the process very well, mistakes that result in waste generation are few and infrequent.

- Product usage. Most of the paints produced by Plant A are for use by the general public. For this reason, extreme care is taken in the choice of raw material and product formulation. This is seen in the rapid replacement of solvent-based formulations by water-based formulations in the architectural paints category in the last decade.

- Product variety. Most of the paints produced at Plant A are water-based latexes and blending of waste latexes to produce a marketable product is easier compared to other types of paints. Hence, waste reuse to produce a marketable product may not be a viable option to industrial paint manufacturers who produce solvent-based acrylics, epoxies, urethanes, etc., to successfully blend wastes.

- Marketing outlets. Plant A markets its products through retail outlets and commercial service centers. Any new product regulting from ireworking processes can be easily sold from these outlets using price discount programs. Also, as the home interior paint is purchased for aesthetic rather than functional attributes, the consumers are more liberal in experimenting with new products. The same advantage is not there for industrial paint manufacturers, where the functional use of the products limit their usage and marketability.

APPENDIX B

WASTE MINIMIZATION AUDIT REPORT

f o r

PLANT B

B . l . FACILITY DESCRIPTION

Plant B produces a wide variety of industrial coatings. About 90 percent of the coatings produced at this facility are solvent- based: with the remainder being water-based. About 10 years ago, the water-based paints constituted only 1 percent of the total production.

The solvent-based paints produced include pigmented tints, pigmented non-tints, lacquer thinners, unpigmented paints (clears), and stains. The water-based formulations are mostly emulsion paints. The production rate of the major products are listed in Table B-1.

Table B-1. Coatings Produced by Plant B in 1985

Product Production Rate (gal/yr) c.

i

Pigmented products (enamels) 360,000

Reducers & Solvents 260,000 Stains & Fillers 310,000

Clear products (lacquers & varnishes) 1,220,000

B.2. RAW MATERIALS MANAGEMENT

Numerous organic solvents are used at Plant B in paint production. Other raw materials in paint production include resins, pigments, extenders, and additives. Table B-2 presents the consumption rates of the major raw materials in 1985.

The selection of solvents used in paint production is based on the end use of the paint. The solvents used at Plant B include methanol, methyl ethyl ketone (MEK), Tolusol-6, toluene, lacquer thinner, and mineral spirits. The solvents are purchased in bulk or in drums. The solvents in bulk form are stored in underground storage tanks. The solvents in drums are stored in an outdoor storage area.

The pigments are delivered in plastic or paper bags, which are stored in an indoor storage area. The inventory is typically capable of meeting the production requirement for two months. In addition to raw materials, some process intermediates are also stored indoors.

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c-

Table B-2. Raw Material Consumption Rates at Plant B in 1985

No. Material Annual Consumption Rate

1. 2. 3. 4. 5. 6. 7. 8.

9. 10. 11.

12. 13. 14. 15.

16. 17. 18.

19. 2 0 .

Solvents

Methanol Methyl ethyl ketone Tolusol-6 Solvent IB Lacquer thinner (blend) Mineral spirits Filmcol A-4 Isobutyl Esobutyrate

1

Resins

Beckosol Coconut Alkyd Rhophex WL-91

Pigments

Titanium dioxide Yellow oxide Burnt umber Van dyke brown

Extenders

Calcium carbonate Talc Clay

Miscellaneous

Drying oils Plasticizers

48,000 gal. 178,000 gal. 361,000 gal. 186,000 gal. 170,000 gal. 132,000 gal. 82,000 gal. 51,000 gal.

41,515 gal. 33,575 gal. 16,000 gal.

350,000 lbs. 32,000 lbs. 51,000 lbs. 56,000 l b s .

52,000 lbs. 128,000 l b s . 30,000 lbs.

30,000 gal. 10,000 gal.

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Each of the raw materials 1s assigned an identification number for inventory control and product formulation. The amounts of various raw materials for each batch are determined through a computer and the data is punched out on computer-generated batch cards. The employee at the production unit follows the instructions given on the cards and obtains the raw material from the storage area using the coding sequence for the material.

B . 3 . PROCESS DESCRIPTION

The following description highlights the production of a solvent- based paint at Plant B. The block flow diagram for this process is presented in Figures B-1 through B-3.

The production of the paint begins with dispersing the pigments -+ in either a roll mill or a sand mill. The sand mills are

horizontal or vertical and employ sand/glass/steel bead/shot to disperse the pigments in a small quantity of solvent/resin mixture. The primary dispersion is carried out in batches of 30 or 55 gallons. After passing through the mill, the mixture of pigments and solvent/resin is collected in another container and sent to intermediate storage, let-down, or the next step in .production. Sometimes, the mixture is passed through the mill up to 3 times to achieve the required degree of dispersion. In such instances, two containers (feed container and receiver container) are used. The same containers are used for all the passes through the mill, and the containers are cleaned after each pass.

The let-down step consists of filling the mixing tank with the primary dispersions, solvents, plasticizers and other additives. The solvents are pumped into the tanks using the filling system shown in Figure B-4. The contents are then mixed. For portable tanks high-shear vari-speed mixers are employed. For the stationary tanks a low-speed mixing is used. When the tank contents attain the proper viscosity, color, and gloss, the mixing is stopped and the contents are filtered and dispensed into product containers. The filtration is achieved using bags, cartridge filters, or vibrating screens. If the tanks are portable, they are moved to the filling area and the contents are gravity fed to the filling unit.

The batch sizes are 55, 110, 220, 300 or 550 gallons for the portable tanks. Larger batches are prepared in stationary tanks with capacity of 1000, 1500, or 3000 gallons. Figure B-4 shows the lay-out of the tanks in the production area. The stationary tanks are usually dedicated to one product and therefore, there is no cleaning required between subsequent batches. At present, the products prepared in the stationary tanks (in the order of

EmDty bats

Empty cans

Obsolele stock

Evaporat we losses

I

wastes

ii; 4

-4

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9 ----t Evaporative 4 losses

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t

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ai

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A b P

4 Lines UNDERGROUND STORAGE

TANKS

L 1

METERING STATION

- A - 1000 gal tank B - 1500 gal tank C - 3000 gal lank P - Portable tank

1 Line

I I I 1

Figure 8-4. Lay-out of Solvent Input Lines at Plant B.

decreasing production quantity) are clears, stains, and enamels. Similarly, the major products produced using portable tanks are stains, mamels, and clears.

B . 4 . WASTE DESCRIPTION

The major wastes generated by Plant B are (in the order of decreasing volume); equipment cleaning waste, obsolete products, returns from customers, off-specification products, spills, filter bags and cartridges, and empty bags and packages. The sections below discuss each of these wastes.

The solvent waste is sent to Oil and Solvent Process Company (OSCO) for reclamation. On-site solvent recovery was conducted in the past, but was discontinued when it proved too expensive. OSCO charges $0.65/gal of spent solvent to reclaim it at 60 % minimum yield and return it to Plant B. The distillation residues generated during the reclamation are disposed of at a surcharge of $0.75/gal-spent solvent. OSCO charges $l/gal if the solvent waste is incinerated in a cement kiln. OSCO is planning to substantially increase their service charges (e.g. $ 2.60/gal for incineration) in the near future.

Table B-3 presents the costs ($/ton) of some solvents used by *Plant B. Also presented are some disposal costs figures from osco.

Table B-3. Raw Material Costs and Waste Disposal Costs

No. Solvent/Waste cost ($/ton)

1. 2 . 3. 4 . 5.

Lacquer thinner Methyl ethyl ketone Mineral spirits Recyclables (a) Incinerables (a,b)

386.00 470.00 2 0 4 . 0 0 2 8 0 . 0 0 200.00

Notes: (a) A density of 10 lb/gal was assumed for liquid waste

(b) Indicates price charged by OSCO in 1985 and does not streams.

include lost raw material costs.

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8 . 4 . 1 . Equipment Cleaning Wastes

Equipment, such as mills and mixing tanks are cleaned after each batch in order to prevent cross-contamination. Unusable storage containers, such as drums and pails, are cleaned before sending them for off-site metal reclamation. The equipment cleaning generates two waste streams: spent solvent from solvent rinsing operations and paint sludge from caustic cleaning.

B . 4 . 1 . 1 . Mill cleaning

The mills are usually cleaned with a solvent used in formulation of the next batch. When this is not possible, MEK is used for cleaning. The cleaning solvent is let through the operating mill immediately following the batch. The spent MEK is reused if contamination is not a problem. Spent solvents from mill cleaning operation are used directly as part of formulation if let-down step immediately follows milling. In cases where the intermediate

c- dispersion is stored for later use, the flush solvents are collected and reclaimed off-site by OSCO.

B . 4 . 1 . 2 . Portable tank cleaning

Manual cleaning with spatulas is used to remove clingage from portable tanks before cleaning with a - caustic solution. The removed clingage is drummed and sent for off-site incineration.

' Following clingage removal, the portable tanks (and barrels/pails) are cleaned in a caustic cleaning machine employing a high pressure spray. Generally, the tanks are cleaned immediately after use to prevent drying of the residues on the tank walls. When cleaning cannot be performed immediately after clingage removal, a small quantity (e.g. one quart) of solvent is added to the tank to prevent drying of residuals. This solvent is either lost due to evaporation or removed by the caustic cleaning. The caustic cleaning solution comprises 600 gallons of water with 4 7 5 lbs of dissolved sodium hydroxide at 200-205 F. The caustic solution is recirculated and the sludge drawn off into reclaim drums for disposal through off-site incineration. In 3 0 percent of the cases, the caustic wash alone is insufficient, and further cleaning with a solvent (such as MEK or lacquer thinner) is required. The solvent wash residuals are drummed and sent off-site for solvent reclamation. This additional cleaning is common for handling acrylic paint deposits. Plant B is installing a new high pressure nozzle to improve the cleaning efficiency of the caustic cleaning system.

B . 4 . 1 . 3 . Stationary tank cleaning

The stationary tanks are usually dedicated to the production of a single product. In such cases, the tank walls are rinsed with the solvent used in the formulation. The rinse solvent then becomes part of the next batch. When a different product is to be prepared in the tank, the tank is rinsed with 3 gals of lacquer

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thinner before starting the new batch. The spent solvent is reused for rinsing whenever possible. Nhen this is not possible, the spent solvent is drummed and sent to osco for reclamation/incineration.

B.4.1.4. Filling unit cleanup

The filling unit consisting of a positive displacement pump, filter, and associated piping, is solvent-cleaned between filling campaigns of different products. Prior to solvent cleaning, the residual paint is emptied from the suction side into a container using the pump. The residual paint from inside the filter housing and the discharge side is normally drained into a separate bucket, and combined with the product. MEK is then used f o r rinsing the filling Unit. The spent MER is reused if possible or drummed and sent to OSCO for reclamation/incineration.

B.4.1.5. Turbine mixer cleaning

The turbine mixers used for let-down in portab solvent cleaned. Here, the mixer is lifted from lowered into a barrel containing solvent, and solvent in the barrel is reused several times off-site for reclamation/incineration. Prior to cleaning with brushes is sometimes employed.

le tanks are also the mixing tanks, then rotated. The before being sent solvent cleaning,

B . 4 . 1 . 6 . Returned product container cleaning

The returned tote bins containing residual paint are cleaned by an off-site contractor. Before sending the drums, pails, and cans off-site for metal reclamation, they are cleaned either on-site or off-site. In the past, the containers could be sent for metal reclamation without any cleaning. At present, the reclaimers do not accept uncleaned containers.

B.4.2. Obsolete Products

Obsolete products are mostly paint that is no longer produced or marketed. These materials are usually reworked into marketable products. When this is not possible, they are sent to OSCO for reclamation or incineration. Unusable shipping containers that contain some leftover paint are a part of this stream. These pails may be washed on site or sent .off-site for cleaning. After cleaning, the pails are sent for off-site metal reclamation.

B.4.3. Returns from Customers

Unused or spoiled paints are often returned to Plant B clients. These returns are accepted to maintain good relations. After lab analysis, some of these wastes are into marketable products and the remainder is sent to reclamation/incineration. The containers that are return customers are handled in the manner discussed in the

by their customer reworked

o S C 0 for ed by the previous

paragraph.

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B.4.4. Off-Specification Products

off-specification products are usually generated due to the following causes :

- Errors in the computer codes for the raw materials. This can cause the operators to use the wrong materials or formulation for the batch.

- Spoiled or degraded raw materials. The raw material are routinely tested, however, time and production constraints sometimes result in the quality control steps being by-passed.

- The I1reworklg material may sometimes be introduced into a wrong batch.

- Contamination due to improper cleaning of the tank.

i

The average seniority of employees at Plant B is about 10 years and the employees have considerable experience, which makes errors in batch formulation infrequent. The off-specifications products are usually reworked and when this is not possible, they are sent off-site for reclamation/incineration.

’ B.4.5. Spills

Spills are inadvertent discharges of paint that occur in the production area. Spills are usually cleaned by lvdryIt methods. Saw dust or sand is sprinkled on the spill and then scraped up and drummed for disposal in a landfill. The area is then mopped with a thinner.

B.4.6. Filter Bags and Cartridges

The spent filter bags and cartridges are disposed in a landfill. As of November 8 , 1986, this waste may not be disposed in a landfill if the solvent content is more than 1 percent. Plant B is considering alternate disposal options including the use of an off-site incinerator.

B.4.7. Empty Bags and Packages

The pigments are usually delivered in paper bags. The empty bags and packages containing traces of pigments is a hazardous waste. These bags and packages are baled and sent to a landfill for disposal.

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B . S . WASTE GENERATION RATES

Table B-4 presents the individual waste streams along with their origin, treatment/disposal, and their generation rates in 1985. Generation rates for waste streams such as obsolete stock, customer returns, off-specification products and spills are not documented separately at Plant B; these figures are included in the equipment cleaning waste generation rate shown in Table B-4. The amount of solvent consumed in cleaning operations is about 1500 gallons per month, which gives a measure of the equipment cleaning wastes. The caustic wash process generates about 2 2 0 gallons of sludge per month.

B . 6 . SOURCE REDUCTION MEASURES

The following aspects of source reduction were considered:

- raw qaterial substitution - plant modernization - process redesign - process automation - equipment modification - good operating practices. The following paragraphs discuss these source reduction alternatives for each of the waste streams.

B . 6 . 1 . Equipment Cleaning Wastes

This stream constitutes a major portion of the total wastes generated by Plant B. The following existing and new source reduction measures were noted.

B . 6 . 1 . 1 . Raw materials substitution

Plant B uses lead and chromate pigments for making special primers. The use of these pigments should be reduced or eliminated to the fullest extent possible. Equivalent formulations using less hazardous pigments are commercially available (e.g. the no-lead and no-chrome alternatives marketed by Halox Pigments) and should be tested for customer acceptance. Chrome yellow pigment can be substituted by organic pigments or yellow iron oxide. However, the color obtained with yellow oxide pigments is not as bright when compared with chrome yellow counterparts. Customer acceptance is viewed as a major obstacle, however.

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1 Equiplent cleaning wastes

+

+

i

!

Table 13-4. Origin,Treatment/Disposal ,and the 1985 Generation'Rates o f Paint Manufacturing Process Wastes a t Plant B

+ ....+............................. ........................... + .......................... + ........................................ I Generation Rates, Short tons

...+-.........t......... +

Solvents I Solids I Sludge I Total 1 ...... ....+.........+.........t......... t

148.5 I 75 I N/A I 223.5 + I I

Process Or ig in

Equipment cleaning using solvent

Equipnent cleaning sludges removed from the caustic cleaning so lut ion

Paint that i s no longer produced or marketed, obsolete rau materials

Unused or spoi led paints returned by customers

Spoiled batches

Accidental discharges

..........................

...........................

...........................

...........................

...........................

...........................

TreatmentiDisposal

Sent t o osco for o f f z s i t e rec 1 amat i on/ inc inera t i o n

Sent t o OSCO f o r o f f - s i t e inc inerat ion

..........................

..........................

I i

i

N ~ A I NIA I 13.2 13.2 I .. . . . . . . . . . . . . . . . . . . . . . . .*. . . .+..~ ......+ .......................... i

Some of i t i s reworked 8 the res t i s sent t o OSCO

.......................... i .. ........+.........t... ......+......... Some o f i t i s reuorked 8 the res t i s sent t o OSCO

Some of i t i s reworked 8 the res t i s sent t o OSCO

Dry cleanup fol lowed by l a n d f i l l disposal o f the spent adsorbents

Land f i l l ed a t present, planning a l ternate means of disposal

Landf i 1 led

..........................

..-.------..--._________..

.........................

.........................

+ i

t.. ..t.............................

I I + ....+.............................

F i l t e r bags and cartr idges

Enpty bags and packages

I 6 I t ....+.............................

1 7 I t . . . .+. . . . . . . . . . . . . . . . . . . . . . . . . . . . .

........................... f i l t r a t i o n o f pa int

.......................... Unloading of pigments and other addi t ives i n t o mixing tanks ..........................

.........t... ......+.........+......... t

N/A 1 Unknown I N/A I 0.1 I t ....................... t .........+.........+.........i.........

Notes:

* - Data included in the equiplent cleaning wastes N/A - Not appl icable

B.6.1.2. Process modifications

0 Improved production planning.

The mills are usually cleaned with a compatible solvent thereby generating a stream that is used in the let-down formulation. However, this is not done if the pigments are dispersed for subsequent storage. In the latter case, MEK is used to clean the roll mill. By planning the production schedule in such a way that the pigments are dispersed only before a batch formulation (thus eliminating the need for intermediate storage), the spent MEK wastes can be minimized. Alternatively, the mills can be cleaned with a small amount of compatible solvent to be combined with the batch that is destined for intermediate storage.

0 Recirculation through the mill.

Recirculating the mixture of pigments and solvent through the mill and returning them to the same container should be explored. This process avoids the use of a second container for collecting the material’from the mill, with the elimination of one cleaning step. This method has more potential for waste reduction in cases where multiple passes through the mills are necessary. The dis- advantage of this method is that fine, dispersed pigments are allowed to mix with undispersed pigments before going through the mill again. This may reduce the efficiency of the mill and require running the mill for a longer period of time. Excessive degradation of the polymers (resins) can a lso be a problem with this recirculation scheme. The economics of increased power consumption should be weighed against the reduction in labor required for cleaning plus the reduced disposal costs.

0 Replacement of caustic solution.

The caustic solution used for cleaning can be replaced by a more stable cleaning fluid. Some commercially available alkaline cleaners were found to be an effective alternate by other users. There are no expected disposal problems associated with the use of these formulations. One such washing agent, when substituted for caustic solution at another facility, reduced their cleaning solution replacement frequency by a factor of two.

c*

0 Caustic wash sludge dewatering.

The sludge generated from the caustic cleaning system is generally drummed for disposal. Dewatering the sludge by flocculation, filtration, or centrifugation can minimize this waste volume. Adding de-emulsifiers to the rinse water can also break the emulsion and decrease the sludge volume. The spent rinse water should be allowed to settle for an adequate period of time to allow for complete solids separation. It should be noted that dewatering, while effective as a cost reduction measure, has few, if any, environmental benefits.

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8 . 6 . 1 . 3 . Equipment modification

0 Mechanical cleaning.

Use of mechanical devices for cleaning the tanks is at present practiced only on small tanks. Here, the paint residues are removed with a spatula before sending the tank for caustic cleaning. For larger tanks, the use of rubber/metal blade wipers appears to be limited.

0 High-pressure nozzle replacement.

Plant B is replacing the existing high pressure nozzle used for caustic spray cleaning with a more efficient unit. Increased cleaning efficiency will contribute to a reduction in solvent cleaning that is currently found necessary in some cases after the caustic cleaning.

0 Replacement of existing mills.

Replacement of' existing mills (as part of future plant modernization) should include considerations of installing more efficient mills that would not require multi-pass dispersions.

c- "

0 High-pressure cleaning of stationary tanks

The large (stationary) tanks can be cleaned by efficient high ' pressure cleaning systems such as the ones used by Lilly Industrial Coatings in High Point, North Carolina. This measure would decrease the total amount of solvent required for cleaning.

B . 6 . 1 . 4 . Improved operating practices

0 Avoidance of unnecessary cleaning.

Equipment should be cleaned only when necessary. For example, when the primary dispersion is done employing more than one pass through the mills, the containers are currently rinsed between each pass. This intermediate cleanup can be avoided if the product contamination is not significant. In general, the feasibility of eliminating the cleaning step between subsequent batches should be explored. Experiments could be conducted on a small scale in the laboratory to measure the degree of contamination due to the elimination of cleaning. If the contamination of the products is within the quality control standards then the cleanup step can be eliminated.

0 Light-to-dark batch sequencing.

The scheduling of the batches in such a way that light paints are produced before dark paints, could mean the elimination of an intermediate cleaning step in some cases.

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0 Prevent paint drying in the tanks.

Cleaning the tanks immediately after use prevents scaling due to paint drying. This also reduces the cleanup requirements. Though a quart of solvent is poured into the tank to prevent drying, the tanks may be left unused long enough for this quantity to evaporate. Proper coordination between production and cleaning can prevent such occurrences.

0 Computerized inventory control.

There are several commercially available computerized inventory systems. Installation of these systems can improve the raw material tracking and help identify and remedy raw material losses at an early stage.

0 Computerized waste documentation and control.

Computerized waste documentation and control can help track the wastes in the process and can help in undertaking control strategies. , Companies offering such systems (hardware and software) include Waste Documentation and Control Inc., in Beaumont, Texas, and Intellus Corporation in Imine, California.

B . 6 . 2 . Obsolete Products

0 Proper planning and inventory control.

Obsolete stock can be minimized by proper planning and inventory control. Currently, the inventory check is done twice a year. By having a computerized inventory system, the inventory can be checked more frequently and over-stocking, to some degree, can be reduced.

B . 6 . 3 . Returns from Customers

0 customer incentive programs.

When the customers return unused paint, the paint is reworked into other products, and the containers are cleaned. Customers that purchase large volumes of paint in drums could be offered cost incentives to convert to bulk purchase (e.g. 400 gallon Tote drums). This will reduce the quantity of returned drums that require cleaning at Plant B and will also result in reduction of residuals. The size of the containers used by Plant B's clientele can be controlled to some extent with similar incentive programs, if the cost savings in cleaning are significant.

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B.6.4. Off-Specification Products

0 Ensure proper batch formulation.

Before making a batch, it is a current practice to attempt the formulation at a small scale in Plant B ' s labs. When large batches of paint are made, the lab scale formulations must be repeated two to three times to ensure that the formulation is correct. This prevents a large volume batch from becoming spoiled.

B. 6.5. Spills

0 Improved training and supervision.

Spills occur due to three reasons:

- splashing during manual transfer - overfilling of the tanks - leaks occurring in process equipment and piping t

Proper equipment maintenance can prevent leaks, and increased training and closer supervision can prevent overfilling and spills during manual transfer.

0 -Discourage dry cleanup methods.

Dry cleanup with solid adsorbents is widely used at Plant B for dealing with spills. Dry cleanup produces spent adsorbent waste that is not amenable to rework and thus needs to be disposed. Therefore, dry cleanup should be avoided to the extent possible, if the scooped up spills can be reworked.

B.6.6. Filter Bags and Cartridges

0 Use bag filters in place of cartridges.

Plant B uses two cartridge filtration units, each containing 6 cartridges. The disposal of the spent filter cartridges is an anticipated problem. The cartridge filters can be replaced by bag filters. The spent bag filters contain much less paint in comparison to the spent cartridges and they can be reused several times, however, bag filters are also more expensive. Unusable bag filters can easily be washed with solvent and dried prior to their disposal as non-hazardous waste. Wash solvent can be combined with other solvent wastes and sent for off-site reclamation.

0 Use of wire screens in place of filter bags/cartridges

Wire screens can be reused almost indefinitely when backwashed with a solvent and therefore preferred to bags/cartridges. The backwashing process may generate a solvent-bearing waste. Therefore, the use of wire screens is recommended only if this

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waste stream can be reused or reworked on-site. Plant B already uses wire screen filters in 2 of the 8 filtration units and is currently testing wire screen filters to replace the remaining filters.

B . 6 . 7 . Empty Bags and Packages

0 Use rinseable/recyclable drums.

Replacement of bags and packages (used for hazardous materials) with rinseable/recyclable drums can be addressed through inquiries with suppliers.

0 Use of pigments in slurry form.

The availability of pigments in slurry form should be explored through vendor contacts. The use of pigments in slurry form means a reduction in waste bags and packages. The pigment slurry can be bought in drums or bulk form and the drums could be returned to the vendor.

0 Segregation of empty bags and packages.

Currently, all the empty bags and packages are baled and disposed of as hazardous waste, even though only some of the bags and packages contain hazardous material. Segregating the bags and packages containing hazardous pigments (lead or chromate) from those that do not contain hazardous materials., prevents the rest of the bags and packages from being considered hazardous.

B . 7 . RECYCLING AND RESOURCE RECOVERY

The following aspects of recycling and resource recovery were considered for the facility:

- increase recyclability - on-site recycling - off-site recycling - waste exchange possibilities. Each of these aspects are discussed in detail in the following paragraphs.

B.7.1. Increase Recyclability

0 Maintenance of minimum solvent content in the waste.

The spent solvent from Plant B is sent to OSCO for reclamation/incineration. OSCO reclaims the solvent (at a net cost of $1.40/gal) only if the solvent yield from the waste is

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more than 60 percent. If the solvent yield is lower, the wastes are incinerated at a cost of $l.OO/gal. Incineration has an additional cost associated with the lost solvent, that needs to be replaced ( $ 1.57/gal for MEK) . It is economically beneficial to generate a waste containing more than 60 percent solvent, if off-site reclamation is the preferred method. This creates an interesting constraint on all efforts aimed at reducing solvent use at the facility: the amount of solvent that ends up as a waste destined for off-site reclamation must be reduced toqether with the amount of solids that such a waste contains, e.g. by reducing clingage prior to cleaning or by improved caustic wash. Also, the amount of solvent evaporated during miscellaneous operations must be reduced.

0 Segregation of the solvent wastes.

The recyclability is improved by segregation of the wastes. Segregation of cleanup wastes containing MEK and lacquer thinner should be tried to improve the recyclability of both streams. Another possibility involves using only one solvent (MEK or

c. lacquer thinner) for all cleaning purposes. This generates a larger, single waste stream that is easier to handle.

B . 7 . 2 . On-site Recycling

0 Reconsideration of on-site distillation option.

. Plant B has attempted on-site reclamation using a solvent recovery still. This method, however, proved unprofitable in the past and thus was discontinued. This method should be reconsidered in light of the present disposal costs.

0 Reuse of cleanup solvent.

Reuse of the cleanup solvent to the fullest extent possible can reduce waste solvent quantity. Wash solvent from each (or at least the most prevailing type) of solvent-based paint batches can be collected and segregated to facilitate reuse. The wash solvent can then be reworked into compatible batches. One example of such reuse is presented below.

The mills used for primary dispersion are cleaned by rinsing with solvent. The rinse solvent is added to the let-down tank, only if let-down is the immediate next step in the process. Sometimes, the dispersed pigments from the primary dispersion are sent for intermediate storage. In such cases, the rinse solvent is drummed for disposal and sent to OSCO. The rinse solvent can be saved in a separate container, and then added to the let-down when the compatible batch of dispersed pigments from intermediate storage is being processed in the let-down tank.

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0 Rework cleanup Solvents into useful products.

Cleanup solvents from various cleaning operations can be blended and reworked into a marketable product. This method was attempted with success by one firm to produce a primer product.

0 Rework wastes.

All of the wastes due to customer returns, obsolete finished products, off-specification products, and scooped up spills should be reworked to the fullest extent possible. This is already being practiced to a some extent at Plant B.

0 Reuse of filter bags.

The filter bags can be rinsed clean and reused several times. This is already practiced to some extent at Plant B. Such a reuse will decrease the the volume of spent filter bags that require disposal.

B.7.3. Off-site Recycling

Off-site recycling is already in use at Plant B. OSCO reclaims and returns the solvent from the wastes if the solvent yield from the wastes is more than 60 percent. However, increasing insurance costs incurred by OSCO are being transferred to generators such as Plant B.

B.7.4. Waste Exchange Possibilities

The following identification codes were listed by the California Waste Exchange pertain to the wastes wanted by some facilities in California :

- W030004. CA 415 solvents. MEK, acetone, lacquer thinner with no more than 40 percent solids for Orange/San Diego areas. - W030009. CA 805 solvents. All ignitable wastes for incineration for statewide facilities. - W030010. CA 408 solvents. MEK, acetone, lacquer thinner in any quantity for Santa Clara. - W030012. CA 408 solvents and/or oils. All types of solvents in 5 5 gal or bulk for Santa Clara.

- W030014. CA 415 solvents. No more than 40 percent solids, with 500 gal minimum in drums or tank truck for Statewide facilities.

Each of these sources were contacted to explore the possibility of a waste exchange. However, all of these facilities turned out to be commercial recyclers.

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~ . 8 . RATING AND SCREENING OF WASTE MINIMIZATION MEASURES

Table B-5 lists the various source reduction measures noted f o r each waste stream. Table B-6 lists the recycling and resource recovery options. Each measure is rated on a scale of 0 (low) to 10 (high) for its waste reduction effectiveness, extent of current use, and future application potential. The waste reduction effectiveness indicates the amount of waste reduction that is possible by implementing a particular source reduction/ recycle measure. The extent of current use, as the name implies, is a measure of current usage of a particular waste reduction option. The future application potential is a qualitative measure of how easy it is to implement due to technical and/or financial aspects.

According to facility personnel, the most effective source reduction measure for decreasing equipment cleanup wastes was caustic sludge dewatering. This method would require the

-+ installation of equipment for dewatering. Other source reduction methods considared effective by the facility personnel for dealing with equipment cleanup wastes were avoidance of unnecessary cleaning, replacement of caustic cleaning solution, and prevention of paint drying in tanks.

The following source reduction methods were rated high by the facility personnel for dealing with other specific waste streams:

stock: - Proper planning and inventory control for obsolete - Customer incentive programs for customer returns: - Ensure proper batch formulation for off-specification products :

- Improved training and supervision for spills: - Use of bag filters in place of cartridges: - Use of wire screen filters in place of bag/cartridge

filters: and - Use of rinseable and recyclable drums for empty bags or packages.

Among the recycling and resource recovery options, reconsideration of on-site distillation received the highest rating of 8 . This measure would involve the installation of a distillation unit. Other recycling/resource recovery measures rated high include reuse of spent solvent, rework of various waste streams, and the segregation of solvent waste streams to promote their recyclability.

3 - 2 2

?

Uaste Reduction

Effectiveness . _ _ _ _ _ _ .____._

Future I Potent i a1

ExtenJ of Current Use Application

. - - - - - . - . - - . . . + - - - . - - - - . - - - -

Current Reduc t i on

Index ...--.-_- .-.-

Future Reduc t ion

Index ._ ._ _._ - _ _ _ _ - - 9 6 2 5 7 5 5 2 2 8 5 5 5 5 . .----.-__

9 6 0 0 0 5 5 2 2 5 5 3 3 0 . - - - . - .

Equipent Cleaning 1. Rau material substitution.

3. Recirculation through the mill. 4. Replacement of caustic solution 5. Caustic uash sludge dewatering. 6. Mechanical cleaning. 7. High-pressure nozzle replacement. 8. Replacement of existing mills. 9. High-pressure clean stationary tanks. 10.Avoidance of unnecessary cleaning. 11.Light-to-dark batch sequencing. 12.Prevent paint drying in the tanks. 13.Corrputer i zed inventory control 14. Conputer i zed uas te docunentat ion

Uas t es 2. improved production planning.

. . . . . - - - - - . - - . - - - . - + - - . - - - - - - - - - - - - - - - - - - - - - - . - - - - - - - - - - - - - - Obsolete Products 11. Proper planning 8 inventory control. I

W 1 N W

5 1 3 1

2 5

--- ---> : I

t

2 5

0 2

!

On-Site Recycling

Y N L' + . - - - - - - . . . . - - - - - - . -

Off-Site Recycling

Uaste Exchange

1. Reconsider on-site distillation unit. 2. Reuse of cleaning solvent. 3. Reuork of cleanup solvent. 4. Reuork uastes 5. Reuse filter bags

7 I 1. Off - si te reclamat ion/incinerat ion.

3 I 1. Off-site reuse. I

5 4

7

0

Future Current Future Awl i cat ion Reduc t ion Reduc t ion Potential Index 1 ndex

9 0 ==E> 8 7 2 3 7 2 3 7 2 3 5 3 1

B . 9 . FEASIBILITY ANALYSIS OF SELECTED WASTE MINIMIZATION OPTIONS

Following discussions with facility personnel, some of the options discussed in the previous section were selected for further investigation. The economic analysis was based on the raw material and waste disposal costs provided by the facility personnel, and the economic and technical information provided by the equipment vendors. The measures evaluated in this section include: use of on-site distillation for solvent recovery, caustic sludge dewatering, replacement of caustic cleaning solution, avoidance of unnecessary cleaning, replacement of cartridges with bag filters, and replacement of cartridge or bag filters with wire mesh filters. Other options such as reuse of cleaning solvent and rework of various waste streams, are to be examined mainly by Plant B for their technical feasibility. Since these measures involve more efficient use of the materials, the economic benefits are obvious.

B . 9 . 1 On-site Distillation

c. On-site distillation was attempted in the past at Plant B, and was discontinued as it proved unprofitable. But, the present disposal costs, and their expected increase, justifies a re- examination of this option. The following conditions must be satisfied for the distillation still to be purchased and installed:

- the still should meet the technical requirements for reclaiming the solvents:

- the economics of on-site distillation must be proven to be favorable: and

- the measure should be proven to be an environmentally safer option (short term and long term) compared to the presently employed off-Site recycling:

The total waste sent to OSCO in 1985 is 223.5 tons/yr, which amounts to 44,700 gal/yr (assuming a density of 10 lb/gal) Assuming a one shift operation and a 5 day work week, a maximum of 2,080 hrs/yr of onstream time is available. This results in a minimum throughput of 21.5 gal/hr. Using a conservative estimate of 5 hours per batch, a batch capacity of 100 gallons is recommended. For a base case analysis, the economics of using the Progressive Recovery Inc. (PRI) Model SC-400, which has a batch capacity of 120 gallons is presented in Table B-7.

Based on the analysis presented in Table B-7, the installation of an on-site still appears to be economically attractive since it has a payback period of 1.9 years, and, as such, is much less than the (rule-of-the-thumb) hurdle rate of 3 years. As this

3 - 2 5

Table B-7. Economic Aspects of On-Site Distillation

Installation Costs

Capital cost, still, PRI Model SC-400 with autofill and cycle complete shutoff Freight Cost (a) Tax (b)

Installation (labor plus supplies), 50 ft. of 1" pipe for cooling water and two explosion-proof conduits

Total Installed Cost

Current Annual DisDosal Costs

Recycling costs' @ $130/tOn Surcharge for disposal of distillation residues @ $150/ton

i-

Total Disposal Costs

' Annual Incremental Savinas

Lost raw material costs (c) Disposal Costs (a) Labor (e) Other (Utilities) (f)

Savings

Pay back period, years

$ 32,150 $ 1,930 $ 2,090

$ 3,500

$ 39,670

$ 29,055

$ 6,980 $ 44,610 - $ 18,720 - $ 12,023

$ 20,847 ------o--

1.9

(a) Estimated as 6 'i; of capital cost (b) 6.5 % sales tax (c) The solvent is assumed to be MEK. (d) Incineration of distillation residues @ $200/ton assumed. The

recovery process is assumed to have a 90 % solvent recovery. The disposal costs of distillation residues is $ 17,970.

(e) Estimated for 40 hr/wk @ $9.00/hr. (f) Based on a still operating cost of $0.30/gal of recovered

solvent.

3 - 2 6

economic analysis does not consider the major price hikes contemplated by OSCO, the on-site distillation option has a still greater economic appeal.

The technical feasibility of on-site distillation can be examined by sending a solvent waste sample to PRI. The reclaimed solvent and the distillation residues returned by PRI can be examined by Plant B for the distillate yield and the quality of recovered solvent. PRI's equipment have been used to deal with paint process wastes at other facilities and is therefore expected to meet the requirements of Plant B.

On-site reclamation has the following benefits:

- the transportation of the wastes and the associated risks are minimized as less waste leaves the facility;

- Plant B has more control over the purity of the reclaimed solvent:

- even though the distillation residues require off-site incineration, the disposal costs will be less affected by increases in charges by off-site recyclers, as the waste volume is considerably lowered:

- it is cheaper to recover on-site: and - on-site reclamation is not considered treatment by RCRA and therefore does not require a TSDF status to be obtained by the facility.

The following are the disadvantages of on-site reclamation:

- capital investment needed for the still. - additional operating costs. - possible need for operator training. - permits from AQMD needed to operate the equipment. - Landfill disposal option for distillation bottoms is probably not available, as it is doubtful that residues will pass the new TCLP test requirements (Nov.8, 1986 landfill ban regulations). This leaves only the incineration option. - liability and risks due to improper equipment operation or solvent quality maintenance are incurred.

As the distillation bottoms can be incinerated off-site, the environmental and regulatory aspects do not play as big a role in converting to on-site reclamation as the economics does.

B.9.2 Caustic Sludge Dewatering

Alkaline cleaning of portable tanks produces a sludge that is sent to OSCO for incineration. This sludge contains a significant amount of alkaline solution. Dewatering will decrease the sludge

9 - 2 7

volume, and yield lower disposal costs. At present 13.2 tons/yr of sludge is disposed of at a cost of $l.OO/gal through OSCO. Assuming the density of 10 lb/gal for the sludge, this represents an annual disposal cost of $ 2,640. Assuming that the sludge contains 10 percent of solids, and that dewatering produces sludge with 30 % solids, a savings of $ 1,770/yr can be achieved. The operating costs of dewatering unit were not subtracted from these savings. Small savings such as these do not seem to warrant the purchase of even a not very efficient filtration unit. In addition, the environmental benefits of dewatering are questionable. The recovered aqueous portion will need additional treatment such as neutralization before discharge to the sewer. Therefore, caustic sludge dewatering is not expected to have any significant economic or environmental impact.

~.9.3 Replacement of Caustic Cleaning Solution

The presently used caustic cleaning solution could be replaced with more efficient commercially available alkaline cleaning

-+ agents. Based qn the experience of a different facility, a 50 percent reduction in cleaning solution replacement is expected. This translates roughly into a reduction of 50 percent in sludge waste volume, or a savings of about $ 1,32O/yr. The increase in the purchase cost of the cleaning solution should be lower than this amount to justify substitution. In addition, the effectiveness of the new cleaning solution has to be

. demonstrated on a trial basis.

B.9.4 Avoidance of Unnecessary Cleaning

The technical feasibility of eliminating a cleanup step can be established by examining the effect of eliminating a cleanup step on the quality of product in a lab scale experiment. If the product contamination is within the quality control standards of the facility, the cleanup step can be eliminated. This option does not involve any capital investment. If avoiding of unnecessary cleaning can result in a decrease of 10 percent in waste volume, it amounts to about $6,00O/yr savings in disposal costs with the present means of disposal.

B.9.5 Replace Cartridges with Bag Filters

Plant B uses cartridges in 2 filtration units, each containing 6 cartridges. To use bag filters in place of cartridges, one possibility is the purchase of 12 new filter housings. Other possibilities include the purchase of 2 housings, each containing 6 bag filters. As an example, Table B-8 presents the economics of replacing cartridge filters with bag filters in 12 new housings. The payback period is 7.4 years and therefore the option is not considered viable. The use of 2 filter housings, each holding 6 filters (with total capital cost of $ 20,000) does not seem to have a significant impact on reducing the payback period. In addition, the technical feasibility of using

3 - 2 9

Table B-8. Economic Aspects of Replacing Cartridges Filters with Bag Filters

Installed Cost

Filter Housings (12), delivered cost including tax and freight

Installation including labor and supplies

Total Installed Cost

Annual Incremental Savinas

Raw materials, Solvents (a) Disposal costs (b) Operating costs (c)

Savings

Payback period, years

$ 20,950

$ 3,000

$ 23,950

$ 470 $ 2,770 $ 0

$ 3,240

7.4

(a) Assuming no solvent retention in bag filters. (b) It is assumed that the cartridge filters are replaced 12

times/week. Using bag filters in their place reduces volume of solid waste by 6.0 ft3/wk. Current disposal fee is assumed to be $9.25/ft3.

(c) The bags are replaced 3 times/wk at $12/bag and the cartridges are replaced 12 times/wk at $3/cartridge.

3 - 2 9

bag filters over cartridges must be established through trial runs.

B . 9 . 6 Replace Cartridges and Bag Filters with Wire Mesh Filters

Plant B uses 4 bag filter units and 12 cartridge filter units. The wire screen filters can be reused almost indefinitely as they are backwashable. Therefore, this measure could eliminate the spent filter bag/cartridge waste. Table B-9 presents the economics of replacing these with wire mesh screens. The increase in disposal costs associated with the solvent-bearing waste from backwashing is not considered to be significant in this analysis. Such a waste can be combined with other solvent wastes destined for reclamation. As seen from Table B-9, the payback period for implementing this measure is 0.2 years. Plant B is already testing some wire mesh filters for their effectiveness. If the technical requirements are met, it is recommended that wire mesh filters replace bag/cartridge filters.

B.lO. SUMMARY AND DISCUSSION

The paint manufacturing process at Plant B was investigated for waste minimization potential. The major source of waste

. generation at this facility is the equipment cleaning operation. The waste minimization options were identified to reduce, reuse, or recycle each of the wastes. These options were tabulated and rated. Based on these ratings the following options were chosen for additional economic analysis:

- on-site distillation - caustic sludge dewatering - replacement of caustic cleaning solution - avoidance of unnecessary cleaning - replacement of cartridges with bag filters - replacement of cartridges and bags with wire screen filters

The equipment cleaning wastes can be distilled on-site at an annual savings of about $ 21,000. The payback period for installation of an automatic still is 1.9 years, which makes this option economically attractive. Other waste reduction measures considered to have a high potential are avoidance of unnecessary cleaning, and replacement of caustic cleaning solution.

Caustic sludge dewatering, though effective in decreasing waste volume, is not recommended as the environmental and economic benefits do not seem significant enough to warrant capital investment. Replacement of cartridges with bag filters has a pay back period of about 7 . 4 years and therefore not a viable option.

3-30

c-

Table B - 9 . Economic Aspects of Replacing Bag or Cartridge Filters with Wire Mesh Filters ._

Installed Costs

Metal mesh filters (16), deliveree . . - cost including sales tax

Installation, including labor and supplies

Total Installed Costs i

Annual Incremental Savinas

Raw material, solvents (a) Disposal costs (b) Labor (c) Other (cartridges,bags) (d)

Total Savings

Pay Back Period, years

$ 2,550

$ 470 $ 2,775 $ 0 $28 , 800 $32 , 045 --------

0.2

(a) Based on 1 ton/yr loss of solvent (MER) (b) Based on reducing the volume of solidified waste by 6.0

ft3/wk. Current disposal fee is $9.25/ft3. (c) Assuming that the change in labor costs is not significant. (d) Based on the use of 144 cartridges/wk at $3.00/cartridge

and 12 bags/wk at $ 12.00/bag.

B-31

However, replacement of bags or cartridges with wire screen filters has a pay back period of 0.2 years and therefore is highly attractive if the technical requirements are met.

In summary, the economic feasibility of on-site distillation appears to be well established. The next step is to establish the technical feasibility by doing trial runs. This measure could have a major impact on minimizing waste at Plant B. The technical feasibility of using wire screen filters in place of bag or cartridge filters also needs to be established.

APPENDIX C

PRELIMINARY SELF-AUDIT CHECKLIST

AS COMPLETED BY PLANT C

5- 1

c.1. FACILITY DESCRIPTION

Plant C manufactures a wide variety of wood finishing stains. This facility was chosen to test the effectiveness of the self-audit guidelines that were developed based on the audits conducted at Plants A and B. The self-audit guidelines were presented in the form of a checklist to the facility personnel.

C.2. WASTE MINIMIZATION AUDIT CHECKLIST

Section 2 . 1 shows the checklist as completed by the facility personnel. In their opinion, the checklist was very comprehensive and made them think about all the waste minimization aspects relevant to paint manufacturing. Some items in the checklist needed further elaboration, and these items were explained with the use of footnotes in the final version of self-audit guidelines.

The following waste minimization efforts were already in use at Plant C:

c* i

o Minimize inventory. The inventory is kept as low as possible in order minimize the possibility of raw material obsolescence.

o High level shutoff switch and flow totalizers with cutoff are employed to minimize spills during storage tank filling.

o Slurried pigments. The pigments are purchased in a slurry form which minimizes dust and eliminates the generation of waste bags and packages.

o Product reformulation. High solids formulations are used in many cases to reduce overall solvent consumption and waste generation.

o Equipment dedication. The mixing tanks are dedicated to the manufacture of single product to the extent possible. This practice reduces cleaning frequency.

o Light-to-dark sequencing. Whenever possible, the products are formulated in a light-to-dark sequence to eliminate the need for intermediate cleaning of mixing tanks.

o Prompt cleaning. The equipment are cleaned immediately after use in order to prevent the drying of the products on the tank walls.

o Standardize cleaning solvent. Mineral spirits are used for all cleaning purposes. As mineral spirits are a major ingredient in all the formulations, this measure would facilitate the rework of the cleanup wastes.

o Solvent waste reuse. The solvent wastes from all cleanup operations are collected in a holding tank and allowed to settle. The clear solvent from the top is reused and the settled solids are drummed for disposal.

o Dry cleanup methods. All the spills are handled with rags or solid adsorbents, thus eliminating liquid waste streams.

The following waste minimization options were identified through the use of the checklist to have a high potential for future implementation:

r-

o Computeri'zed inventory system.

o Solvent substitution. Water-based wood finishes are not currently available and there is a possibility of their availability in the future.

containing various pigments are collected in a settling tank. By segregating wastes by color, they can be directly reworked. This would reduce the equipment cleanup wastes considerably.

o Waste segregation. At present, the cleanup wastes ?.

o High-pressure spray cleaning. The tanks are presently cleaned with solvent pumped through hoses. Using high-pressure nozzles the consumption of cleanup solvent will be decreased.

o Increased supervision.

o Employee incentives. Employees will be rewarded for suggestions that reduce the waste generation.

o Waste documentation. Currently, the origins and generation rates of the various wastes are not documented. Such a documentation will prioritize the processes that generate high quantity of wastes.

The filled out checklist is given in the following pages.

c ,-3

, - e L.-.l. S e l f - A u d i t C h e c k l i s t as Com_sleted by P l a n t C P e r s o n n e i

FACILITY DESCRIPTION

Company Name Division Street Address City/State/Zip Code

Name of Contact Tit le/ Pos it ion Telephone No.

Number of Employees Average Seniority

Annual Gross Sales f o r the Year Ending 86

Production 20 Administration 1 5 Production Administration

Solvent-Based Water-Based

Architectural Coatings Industrial Coatings

Other Speciality Coatings 1 0 0 6 . o M . o c o

Annual Production Rates in Gallons f o r 1984 1985 1986

Enamels Lacquers Varnishes Reducers Thinners Solvents stains Fillers Aerosols Latexes Other Finishes 56o.ooO 91s.

1987

#-

RAW MATERIALS HANDLING

aefore proceeding further, please fill out the blanks i n Table 1. The infornation requasted in Table 1 is intended to document the management of raw materials entering the facility and to Fr3vrd.e the auditor with insight as to where waste minimization e f f c r z s should be focused. In addition to Table 1, the following l i s t of malor sources of waste associated with raw material handlrzq should be completed by the auditor.

Waste Source/Type Relative Waste Disposal Method/ Volume, % Handling Procedure _____-____------_---____________________-------~---~----------

off-spec materials Obsolete materrals Spills and leaks (liquids)

Empty container cleaning Container disposal (metal) Container disposal (paper) - spills (powders) 5 osco

Pipeline/tank drainage 95 0 x 0 gvaporative l o s ses

100

Are all raw materials tested by the quality control departxent no. If no,

what safeguards are employed to prevent the use of materials that may generate off-spec product ? *Sometimes before being accepted from the suppliers ?x yes, -

The current raw material inventory is capable of meeting 1 M o n t h months worth of production. A complete inventory check is performed 17 times per year. Spot checks are performed D a i l y times per year.

Is the inventory system computerized ? yes, no.If y e s , what information does the system track ?-

Is it established policy to utilize raw materials on a first-ln no. first-out basrs ?x yes, -

Is obsolete raw material returned to the supplier 1- y e s ,

- EO. N / A

e -* -

m 0

z U

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - t . t , ., . , . . . .,. . . . . . . , . . . . . . . . 1 . . . ( . H.iIer bel Or ig ina l Or ig ina l Storage lrensler AmuaI Spi l l s anti Cost ( 8 )

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4 . . . . .

I I

D r y i n g o i l s

P l a s t i r i z c r s

Bac ter ic ides (mercuric) I Bacter ic ides (non .mrcu r i c ) )

. . . . . . . . . . . . . . . . . . . * . . . . . . . . . . . . . . . . . . . . . . . . . * . . . . . . . . . . . . . . . . . . . . . . . . . . . *.

I 1 I I I I I I , 4

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S u r lac t ant s

Defoamers

. . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . .

. . . . . . . . . . . . . . . . . . . . . . . I v i s c o s i t y d i t i e r s

I Amnonia

I Caustic

I Aqueous cleaners

I Aqueous cleaners

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N l J l C \ : 1. 2. 3 . 4.

5 . 6. 7 . 8 .

I n l i r s i e D i u m ( D ) , B u l k (8). Begs (Bg), or Packages ( P I Ind ica te container s i z e in Ibs, gals, tons, etc. Ind ica te storage capaci ty in ga ls for l i q u i d s end Ibs for so l i ds or I of containers or tanks, i f ePProPrietc l nd ice te outdoor storage (O) , indoor drm storage ( I D ) , uxlergrouxl storage (U), abovegrand b u l k S t O r W e ( A ) , indoor b.ig/packagc storage ( I P ) , or other (spec i fy ) Ind ica te Pcnp (P) , f o r k l i f t ( f ) , Pnctmatic t iansport (P), conveyer (C), or other (spec i fy ) I r d i t a t e gals for l i q u i d s end I b s for solids I i d i r a i e annual - ts l o s t and lrcqucncy of occurewe l i d t r a l e S/lb l o r so l i ds and $/gal for l i p r i d s

Does the current inventory control system adequately z r e v e r z xaste qeneratron ? A yes, - no.

:==a the following list of source reduction techniques assocra’-,eci xrth general raw material handling, indicate which technrques a r e czrrently being used in the facility and to what exter.: techniques ROC currently being used could be:

-

11. BULK LIQUIDS

Describe the,safequards that are in place to prevent the spillage of liquids during the filling of storage tanks (i.e., high level shutdown alarms, flow totalizers, pipeline drainage or purging before disconnect, diket,etc.):u l p v p l O f f $ - pre -set fillina

i d @ roam

Are any storage tanks tied into a vapor recovery system ?-yes, 2 ne. If yes, describe the system:

Are all storage tanks routinely monitored f o r leaks I - yes, - no. Describe procedure for above-ground tanks:

visual

Underground t ,anks: N / A

How are the liquids in these tanks dispensed to the users (1. e . , i n small containers or hard piped) ? Hard PiDed

What measures are employed to prevent the spillage of 11qurds being dispensed ? Hiah level shut o i f s - P r e s e t meters

When a spill of liquid o c c u r s in the facility, are dry cLeanc? nethods employed ?x yes, - no. Are wet cleanup YetRCdS employed ? - yes, 1 no. Describe the cleanup procedure including how the resulting waste is handled: Sdfe-Sieo

3-9

From the f3llowing list of source reductzon technrques assoc:z:e’cI w i t n bulk liquid raw inateriai handlzng, r?,dicate wnicn tecnn’qz-es are currently belng used in the facility and to what exts?..= zecnniques not currently being used could be:

Sourze Reductis3 Currently Implementatlon Potent-ai Technique Done (Y/N)? High Medium Low ::one --_--_--_-_-------__-----------------------------------~------

X X ---- High level shutdown alarm yes

Flow totalizers w/cutoff yps ---- Pipeline drainage No ---- Vapor recovery No ---- Leak monitoring Yes x--- Spilled material reuse No ---- Dry cleanup methods(a) No ----

---- ---- .............................................................. (a) This method will only reduce waste if the waste due to

wastewater treatment (generated when wet cleanup methods are employed) is not used to formulate a product.

111. DRL’MS, CONTAINERS, AND PACKAGES

Are all received drums, packages, and containers fully inspected for damage before being accepted ? X yes, - no. If damaged items are found, describe the handling procedures employed:

Are items properly stored to prevent possible damage sr contamrnation?X yes, - no. Are items that are stored

no. outdoors protected from rain and snow ?X yes, - Are employees properly trained in the ways to safely handled the different types of drums, contarners, and packages the facilrty receives ?A yes, - no. Are they properly trained in the vays

no. of handling spilled raw materials ?x yes, - Are a l l empty bags, packages, and containers that c9ntarned hazardous materials fully segregated from the empty Sags, packages, and contamers that contained non-hazardous wastes ? - x yes, - no. If no, explain why not and the method currently Seing used to dispose of this waste

13- 10

a To reduce the qeneratrsn o f empty kags and packaqes, has ~ 7 . - facility attempted to use pigments 13 slurry f o m ? - :: yes, - no. if yes, discuss the results:

Has the facility attempted to use soiuble bags? - yes, 1 no. - c y e s , discuss the results:

To reduce the generation of dust, has the facility attempted t.= use pigments in slurry or paste form ?- yes, - no. :f yes , discuss the results: N 1 A

Does the layout of the facility require a heavy amount of t r a f f l c through the raw material storage area (heavy traffic increases the potential €or contaminating raw materials with dirt or dusc and for causing spilled materials to become dispersed through- out the facility) ? - yes, A no. Can traffic through the storage area be reduced ?- yes, - no. From the following list of source reduction techniques associated with drums, containers, and packages, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

b

Source Reduction Currently Implementation Potential Technique Done ( Y / N ) ? High Medium Low ‘lone ..............................................................

Raw material inspection Proper handling Proper protection/storage Waste segregation Soluble bags Reusable drums slurry/paste pigments Reduce traffic Spilled material reuse

Yes Yes Yes No L Na ycs N/A Na

x x x x

30 any of the products produced contain hazardous naterrals ( i . e . , lead, chrome, aercury, e t c . ) ?a y e s , - no. If y e s , has material substitution been tried ?x yes, - no. Discuss the results if yes or the reasons why if no:nlrfT

.as there been an inc&edRe8&@6y demand for high-solids c z water-based paints ?y yes, - no. If yes, did the facilrty experience an - increase orseAlaJdecrease in the amount af hazardous waste produced. Discuss any problems or benefits t h e facility faced due to this change in demand: No significant change

From the following list of source reduction techniques associated with material substitution and product reformulation, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

Pigment Solvent Product Other ra

substitution substitution ref onnulat ion w mat1 substi

No No Yes

tution NO X

X

X

X

,- v- 1 2

PROCESS OPERATICN

Eihile every manufacturing facility is unique in its layout a r d operation, there are many activities that are common to ail. Process examination, based on a generic paint inanufacturrzq facility layout, should include raw material handling (prevrausly discussed) , primary dispersion, let-down, filtering, ar.d packaging. Areas of concern common to all these 0peratFsr.s include design, use, maintenence, and cleaning of specif,=: equipment along with all associated piping, pumps, and valves.

Complete the overall mass balance for the facility as shown Lr. Table 2 . In addition to Table 2 , the following list of major sources of waste associated with process operations should be completed by the auditor.

c* . .

Waste Source/Type Relative Waste Disposal Method/ Volume, % Handling Procedure ..............................................................

Mill cleaning Portable tank cleaning Container cleaning. . Stationary tank cleaning . _ 5 0 0 x 0 - Drums Mixer cleaning Filter equipment cleaning - Spent filter elements Filling equipment cleaning 5~ O F r O - D r D S

100 ............................................................... I. GENERAL

idow frequently are overall material balances for the plant performed ? NO . Are the operators provided with detailed operating manuals =LT instruction sets ? - yes, no. Are all operator job functions well defined ?x yes, - no. II. PRIMARY DISPERSION

Indicate the type or number of primary dispersion mills used in the facility (if mills are not used in the facility chen t h i s section may be skipped). - sand, - glass bead, - seeeb

Indicate the most commonly used method of feeding raw materrzls 5 3 the mills. - manual, - gravity, or - forced feed f r z? .

sinall (e.g., 5 gallon) contarners, - portable mix csnics, = r - l a r g e scorage tanks.

N/ A

shot, - roll, - turbine, - other ( 1 .

-

1 - 1 3

'a n U

3 'd

- - a 1 3 3 i 3. a 3 3

3 n a

f

:4/ A Indicate the most commonly used method ?acerials from the mills. - manual , of discharqinq dispersed - -

gravity, o r - f o r c e d ) containers, - FortaDie What percentage of :.?e

- discharge into - small (e.g., 5 gal. 311% tanks, or - let-down tanks. dispersed material is sent to intermediate storage instead cf being used immediately to produce paint . How ionq d o

materials usually remain in intermediate storage before being utilized

Indicate the percentage of material that must be passed througn the mill once , twice , or more . For materials passed through the mill more than once,are separate contarners used for feeding and receiving - yes* - no. Can the number of containers used (and hence require cleaning) be reduced b y continuously recirculating the material through the mill instead of using multiple passes - yes, - no. Would the purchase of a more efficient mill eliminate the need for multiple passes -

Ind the ded mil

eve

icate ,the percentage or number of mills that are dedicated to production of a single product . How frequently are the icated mills cleaned . With the non-dedicated

after every batch, - after every batches, or - only when the product changes (approximately Is, are they cleaned -

batches). ry - Solvent cleaning of the mills is - used for solvent-based batches only, - used for all batches, - not used at all. The type of solvent used for cleaning is - the same as the solvent

) . used in the batch, - MEK, - other (

The waste stream generated from mill cleaning is - drummed fzr disposal, - drummed for disposal after being reused - trzes, - drummed for use in a subsequent batch of paint, - added ts the let-down tank as part of the current batch of paint, cr - sent to a holding tank for

From the following list of source reduction techniques associated with the primaq dispersion operation, indicate which techniques are currently being used in the facility and to what e x t e n t techniques not currently being used could be:

3-15

source Reduction Current 1 y Ixplementatlon ?~)zer.ziz.L Technique 3one ( ' f / N ) ? Eiiqh Yedium Low :;cr.e

?reduction planning Recirculation thru mill Reuse rinse solvent Yechanical cleaning Waste segreqation Rework rinse solvent Dedicate mills Standardize clng. solvent Clean w/part of batch Install efficent mills

111. LET-DOWN TANKS

The portable let-down tanks used in the facility are sized frm ~ a o o tor- gallons. The stationary let-down tanks range LE size from to gallons. 0 percent of the batches, Or - percent of the product volume, produced in the facility is made in portable tanks.

N/A Indicate the most commonly used method of discharging paint from the portable let-down tanks. - manual, - gravity, or - another portable tanks, or' - directly into the filtering and filling system.

forced discharge into - small ( e . g . , 5 gal.) containers, I

Indicate the most commonly used method of discharging paint ~ Z ~ Z I the stationary let-down tanks. - manual, gravity, or y forced discharge into - small (e.g., 5 gal.) containers, - another portable tanks, or - X directly into the filtering and filling system.

Is the piping to and from the tanks routinely flushed with water or solvent - yes, - X no. Is the piping I1piggedtl befc re flushing - yes, - X no.

Describe the cleaning sequence (i.e., manually scraped, washe5 with a high-pressure spray system using caustic, then solvenc rinsed) used for cleaning portable let-down tanks.

~~

9escribe the cleaning sequence used for cleaning fixed ?et-dc;in tanks. Solvent Rinse

c-

Gescrrbe the cleaning sequence used far cleaning the y:~::; units. ;4IR

unnecessary cleaning of equipment increases the amount zf cleanrng wastes generated. Can production batches be sequence2 from light-to-dark colors so as to reduce the need for clean::? - x yes, - no. Has the facility investigated the effect st reduced cleaning on product quality - yes, X no. If yes, *,.as the testing performed - on a lab scale or - in proauction. What were the results

Much more drastic cleaning measures are usually required when the paint is allowed to dry inside the tank. Are all of the tanks cleaned promptly after use - X Yest - no. If no, how long do the tanks wait to be cleaned and why

Are any precautions taken during this time to prevent the paint from drying - yes, - no. If yes, describe

Are there established procedures for communications between cleaning and production crew? - YeSl - no. N/A

If a- high-pressure spray system is not used for cleaning tanks, does the facility plan on installing one soon yes, - no. If

N/A

no, why

F o r facilities using high pressure spray systems, is the nozzle as effective at removing dried paint as originally designed or" expected - yes, - no. If no, has the use of new nozzle heads If the facility is currently using caustic, have alternatry/e commercial cleaning solutions been tried - yes, - no. If yes, what were the results N/A

or higher pump pressures been attempted - yes, - no* N / R

From the following list of source reduction techniques associated with the let-down process, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

3- 17

Source Reduction Currently Inplementaticn PotentL3l Technique 3one ( ' i / N ) ? High Yedrum Low !:one

Dedicate tanks Xechanical cleaning "Prqging" pipelines Light-to-dark sequence Prevent paint drying Clean promptly

Yes NO No Yes Yes yes

Proper communications Yes High-pressure spray clng. No Use of efficient nozzles NO Replace caustic solution N / A Waste segregation No Solvent waste reuse Yes Rework solvent waste yes Standardize clng. Solvent Yes Avoid unnecessary clng. Yes Ensure proper batching Yes Minimize evqporative loss NO

x x

i

x IV. FILTERING h FILLING

Indicate the type or number . facility (if filters are not sect unit

.on may be skipped). - * f , wire mesh cartridge bags per unit), - other

of filtering units used in :?.e used in the facilitv then this

iber cartridge (- cakridges per (- cartridges per unit), - bag

\

If wire mesh filters are used, are they backwashable? -x, yes, - no. If yes, indicate how the waste stream from backwashing ;s handled Nnne n p w r a t e d

If no, Indicate how the wire mesh filters are cleaned ana how m e waste is handled

Are any of the filter units dedicated to a particular pr3ducz line? yes, - no. If cartridge filters are used, how many spent cartridges does t h e facility produce per week . Has the facility attempted E3 replace disposable filters with reusable filters - yes, - no. If yes, what type of reusable filter was tried and what x e r e the results

If bag filters are used, how many spent bags does the facL11ty

y e s , - no. If yes, now many times can they be reused and indicate how tiCle cleaning wastes are handled

produce each week . Are the bags cleaned and reused? -

3-18

Filling units cleanup: - not cleaned as they are dedicated, y solvent cleaned, - Water cleaned. If they are cleaned, iridicacs =?,e cleaning procedure and how the cleanup wastes are handled -

5~ a ? Drpvious

From the following list of source reduction techniques associated xith filtering and filling, indicate which techniques are currently being used in the facility and to what extenc techniques not currently being used could be:

Source Reduction Current 1 y Implementation Potentla1 Technique Done ( Y / N ) ? High Medium Low None

Use wire screen filters Yes X Use bags not cartridges NO X Reuse filter bags N/A Dedicate ,filter units Yes X Dedicate filling units No X Light-to-dark sequence Yes X

V . PORTABLE TANKICONTAINER CLEANING

The portable tanks are cleaned mechanical, solvent, - caustic. If caustic cleaning is usedf is it sometimes necessary to clean with a solvent? - Yesf - no. If yes, are any attempts made to use a more efficient cleaning solutions? yes, - no. I f yes, indicate the results

N/A

The containers are mostly cleaned on-site, x off-site.

Are the containers cleaned before sending f o r metal reclamation? - yes, A no.

Do you have customer incentive programs to encourage purchase 1:: bulk form or in bigger containers? - yes, no.

Are the empty drums that contained raw materials returned to the suppliers? - yes, no. If yes, are the drums washed before

Yesf - no* N / A returning? - Are the drums reused? - yes, y no. If yes, then are t k e y washed before reuse? - yes, - no. Any effort towards using rinseable/recyclable drums attempted? - yes, J- no. If yes, indicate the result

2- 19

From the following l i s t of source reduction techniques assocrazed 21th the cleaning of portable tanks or cgntainers, ind.icate ..+r,i:: :echnrques are currently being used in the facility and t3 ;;nac extent techniques not currently berng used could be:

Source Reduction Currently Implementation Potentral Technique Done ( Y / N ) ? High Medium L o w ::one

Rinseable drums NO X Customer incentives Mechanlcal cleaning Replace clng. solution NO Efficient clng. nozzle NO

No x No X

X X

Prevent paint drying No x

2-20

PLANT OPERATIONS MANAGEMENT

Plant operations management involves the proper scheduling of production to reduce the need for equipment cleaning, and dealing with management practice such as employer/employee relationships that may have an influence on the amount of waste generated.

I. PRODUCTION SCHEDULING

Are there any attempts at varying the production schedule t3 decrease waste generation? J- yes, - no. If yes, with what

nerated Less l a b o r results t o s s clean1 na waste ae

Does the production include light-to-dark manufacturing sequence? A Yest - no. If yes, indicate results Same as above

Are there any attempts at eliminating some cleanup steps between subsequent batches? A yes, - no. If yes, indicate results -

Is the batch formulation attempted in the lab before large scale production? - yes, 2 no? If yes, how many times is the l a b scale test repeated to ensure proper batch formulation

From the following list of source reduction techniques associated with production scheduling, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

Source Reduction Currently Implementation Potential None Technique Done (Y/N)? High Medium Low

x Light-to-dark sequence ype; x Increased supervision No x Avoid unnecessary clng. Y P S x Ensure proper batching NO

11. MANAGEMENT PRACTICE

Are there employee education programs regarding waste qeneraticn? - yes, no. Are there employee incentive programs regardir.3 xaste reduction ?- yes, J- no.

Does the facility have an established waste minimization pr=?ra - in place ?x yes, - no. If yes, is a specific person assigr,eci to oversee the success of the program ? - x yes, - no . 2oes t:e program have a set waste reduction goal 7 - X yes, - no. iias Eke prcgram achieved its goals ? - Ye=, - no. Explain:

A l w a y s t r v i n a

Is the facility aware of the local, state, and federal regulations related to hazardous material storage, treatment, disposal, and recycling? J- yes, - no. Has the facility conducted an environmental audit to assess compliance with t h e s e regulations? - yes, 1~ no. Does the facility have a problem with the cleaning of containers returned from their clients - yes, no.

Does the facility have a customer incentive program to purchase products in bulk ?- yes, J- no. Does the facility view the widespread use of bulk containers (such as Tote bins) as a way of -- reducing the, amount of container cleaning waste generated?- y e ~ , J- no.

From the following list of source reduction techniques associated with management practices, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

Source Reduction Currently Implementation Potential Technique Done ( Y / N ) ? High Medium Low None

Employee incentives No X

minimization programs Yes X is-L Set reduction goals 'des X 35 cc Employee training prgms. NO X S S l t . Customer incentives No X Increased supervision No X

Established waste

WASTE MANAGEMENT

c.

~ l l of the wastes generated at the facility should be tabulated in Table 3. Provide a separate copy of Table 3 for each solvene waste: for example, if MEK and lacquer thinner are both used t3 clean equipment, fill Table 3 separately for MEK and for lacquer thinner (i.e. 2 tables). Provide sketch of existing on-site treatment system including wastewater treatment, incineratlDn, etc.

Does the facility document individual wastes with their sources of origin and eventual disposal along with the incurred disposal costs 3- yes, x no. Are the different Solvent wastes due to equipment clean-up kept segregated ?- Yes, - no. Are the aqueous wastes associated with equipment clean-up kept segregated from the solvent wastes ? - yes,' - no. Are the spent alkaline solutions kept

no. segregated from the rinse water streams ? - .est - Has on-site distillation of the spent solvent ever been attempted? y y e s , - no. If yes, is distillation still beinq performed? - y e s , Y no. If no , explain why :

N/A

NO t n eceq w v

If the facility generates too many small volume solvent waste streams to justify on-site distillation, can the solvent used f o r

Did the facility investigate off-site reuse through Waste Exchange services? - yes, y no. If y e s , indicate the results

equipment cleaning be standardized ? - Yest - no- N / A

Is the spent cleaning solvent reused to the extent possible? ]i no. Yest -

Are there any attempts at making the rinse solvent part of a batch formulation (rework)? yes, - no. If yes, indicate the results Most cleaninq solvent re-used

Are there any attempts made to blend various waste streams t3 produce a marketable products? - yes, X no. If yes, then t3is measure was successful, unsuccessful for water-based paints, and successful, unsuccessful for solvent-based paints.

I . i l ) l c 5 . U n \ i r rjp5(t i p t i o i i f o r a paint Mantifat t i i r ing f a c i l i t y

. . . . . . , . . . . e . . * . . . . , . . . * . . . . . , ~ . . . -! t

C-nt s

. . . . . . . . . . . . . . . ..............*...............,............... 4 ..........(..............*........+......... 4 . . . . . . . . . . . . .

C o r p o S l I i m ( 3 ) C m r a t i m ' Uaste Oisposat I r C a t n n t * ' I rate (4) Inenag-nt (5) lcost ( 6 ) ( c o s t ( 6 ) 1 1 Manual c leaning I

I Solvent cleaning I Yes + . . . . . . . . . . . . . . . . . . . . * . . . . . . . . . . .

* . . . . . . . . . . . . . . . . . . 4 . . . . . . . . . . .

I Voter r i n s i n g I * . . . . . . . . . . . . . . . . . .*. . . . . . . . . . . . I Alka l ine c leaning I * .................... 4 - . - . .

I I mi nerd I I I

. . . + . . . . . . .

. . . * . . . . . . .

. . . * . . . . . . . .

. . . * . . . . . . . .

. . . + . . . . . . . .

I

I M I &

4 . . . . . . . . .

. . . . . K C ....... ......... . . . . . ivr i . . . . . . . . . .

I 1 I I I I I . . . . . . . 4 ............... 4 ......................... 4 ........ 4 . . . . . . . . . + . . . . . MA ........... 4

I I I I I I I . . . . . . . 4 ............... 4 .......... 4 .............. 4 ........ 4 ......... 4 __._.ryA ............ +

I I I I I I I ....... ............... .......... . . . . . . . . . . . . . . + . . . . . . . . ......... . . . . . WA ........... I Obsolete raw n s t c r i a l l .....+............ , . . . . . . . . . . . . . . . .

I Obsolete produc * . . . . . . . . . . . . . . . . S I I I I I I I I I . . . . . ............... . . . . . . . . . . . . . . . ............... .......... + , WA +

I I I I I I I I I ........ . . 4 . c - . ........... + . . . . .... 4 . ....... . * . . . . . w A . . ......... .............. ........ ......... .... . . . . . . . . . . .

- * . . . . . e . . ............ . * . . . . . . . . . . . ...,...............

I I

. . . . .......... ............ ............. . . . . . . . . . . . ..... . . . . . . . ... . . . . . . . . I I

I I I I

I I

I I I I . . e . . . . e . . . + . .42.-. . 4 . . . * . . . + . . 4 . .MA.. . +

I Yes . . . . , . . . . . . . . . . . . . . . . . . . . . . ! m~ra!. sprts!erdt !.gafes.v b. ~ r . *. . . . . .L . . . . . . . * . . ...... . . . . . . . . . . . . . . . . .

* . . . . .

I t

4 I I ....... 4 . . . . + I I . . . . . . . 4 . . . . . . . .

. . . * . . . . . . . . * . . . . . . . . . , . . . . . . . . . . . . . . . . I I I N/A

I . . . . . . . . . . . . . . . * . . . . . . . .

.. * I .* 4 I . . . . . . . . . . . I .............

4 I . . . 4 I .......... 4 I ........... I I , I ............... . . .* . . . . . . . .* . . . . . . . . .* . . . . . . . . . . . . . . . . . . + . . ..........

Notes: 1. Ind ica te yes ( I ) or no (N) 2 . Ind ica te the u j o r c m r t i t u c n t that causes the waste lo be labeled hazardous 3 . Provide separate sheet, i f necessary C . Ind ica te the o i t s ( e . 9 . gal/yr, drms/yr , ctc . ) 5. ind ica te sani tary I a n d f i t I (si), c lass I tsndfiti ( I ) , off s i t e recyc le (OR), o f f - s i t e inc inera t ion (01). On-site d i s t i l

m s i t e icusc (on), rcuorkrd i n t o other p r o r k t s (I), waste erchange (U), discharge t o sewer ( 0 ) . ncutra l iZ . t im (n), f l o r c u l a r i o n ( f ) , dewatering (OU), recyc led (RE), on site incinerattan ( O w l ) , sent for metal reclrrrtim (M), other (spc

6 Indicate w i t s (e.9. Sldrm, $/gal , $/ton, c t c . 1

r-

If off-site disposal methods are used for solvent wastes, 1 s there any attempt to generate a waste that will be recycled ;lst incinerated? - yes, no. if yes, explain how this ;as achieved

Is there any economic advantage in generating a recyclable waste? x Yest - no. Are you sure that your waste is segragated from other wastes when reclaimed by off-site recycler? - yes, - x no.

Are the spills collected and reworked? yes, X no. If yes,

yes* - no. If spills are not collected and reworked, are tne dry cleanup methods encouraged (e.g. by closing floor drains)?

no. x Yesf - Are empty bags and packages containing hazardous material segregated from the rest before disposal? - Yes, From the 'following list of source reduction techniques associated with waste management, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

then are dry cleanup methods discouraged at the facility? -

- no* WA

Source Reduction Currently Implementation Potential Technique Done ('Y/N)? High Medium Low None

Reuse cleanup solvent YeS Rework cleanup solvent YeS Segregate bags/packages P ~ J Segregate wastes L Rework wastes L Discourage dry cleanup m Encourage dry cleanup ypz Caustic sludge dewatering m Waste documentation L

X X

x x

x

c.3. SUMMARY

The effectiveness of the waste minimlZatiOn audit checklist was tested on Plant C, a wood finishing stain manufacturer. Based on this experience the checklist was modified as presented in the main report.

The waste minimization audit identified waste segregation to be the most effective option to reduce or eliminate the equipment cleanup wastes. As Plant C is a small quantity generator, the economic incentive f o r waste reduction is not significant. However, increasing disposal costs could alter this condition.

c. .

EXHIBIT

WASTE MINIMIZATION AUDIT CHECKLIST

FOR PAINT MANUFACTURING PLANTS

E- 1

FACILITY DESCRIPTION

Company Name Division Street Address City/state/Zip code

Name of Contact Title/Position Telephone No.

Number of Employees Production Administration Average Seniority Production Administration

Annual Gross Sales for the Year Ending ,

Architectural Coatings Industrial Coatings Specialty Coatings Other

Annual Production Rates in Gallons for

Enamels Lacquers Varnishes Reducers Thinners Solvents Stains Fillers

Solvent-Based Water-Based

% VOl. $

1904

Aerosols Latexes Other

Total

1985 1906 1907

E-2

RAW MATERIALS HANDLING

Before proceeding further, please fill out the blanks in Table E- l. The information requested in Table E-l is intended to document the management of raw materials entering the facility and to provide the auditor with insight as to where waste minimization efforts should be focused. In addition to Table E-1, the following list of mayor sources of waste associated with raw material handling should be completed by the auditor.

Waste Source/Type Relative Waste Disposal Method/ Quantity,% Handling Procedure ..............................................................

Off-spec materials Obsolete raw materials

Spills and lea'ks (liquids) Spills (powders)

r- Obsolete products

Empty container cleaning Container disposal (metal) Container disposal (paper) Pipeline/tank drainage Laboratory wastes Evaporative losses

100 .............................................................. I. GENERAL

Are all raw materials tested by the quality control department before being accepted from the suppliers 1 - Yesf - no. If no, what safeguards are employed to prevent the use of materials that may generate off-spec product ?

The current raw material inventory is capable of meeting months worth of production. A complete inventory check is performed times per year. Spot checks are performed times per year.

Is the inventory system computerized ? - Yesf - no. If yes , what information does the system track ?

Is it established policy to utilize raw materials on a first-in no. first-out basis ? - Yesf -

5 - 3

Table E-1. P r i n c i p a l Raw M a t e r i a l s ' Receiving, Storage, Transportat ion, Consunption, and Cost Data

Pi c- I

?

1. I nd i ca te D r a s ( D ) , Bulk (E), Bags (891, Packages (P), o r P a i l s (PL) 2. I n d i c a t e conta iner s i z e in Ibs, gals, tons, etc. 3 . I n d i c a t e storage capaci ty i n gals f o r l i q u i d s end Lbs f o r s o l i d s or I o f containers o r tanks, if appropr iate 4. I n d i c a t e outdoor storage ( O ) , indoor drun storage ( I D ) , underground storage (U), aboveground bulk storage (A) ,

indoor bag/package storage ( IP ) , o r o ther ( spec i f y ) 5. I nd i ca te Punp (PI , Fork l i f t ( F ) , P n e m t i c t ranspor t (P t ) , Conveyer (C), O r o ther (spec i fy) 6. I nd i ca te ga ls f o r l i q u i d s and Ibs f o r s o l i d s 7. I nd i ca te L / l b f o r s o l i d s and $/gal f o r l i q u i d s

?

I I I I I I I I I I I

1. indicate D r u m (D ) , Bulk (B), Bags (Bg), Packages (P ) , or Pails (PL) 2. Indicate container size in Lbs, gals, tons, etc. 3. Indicate storage capacity in gals for liquids and Lbs for solids or 1 of containers or tanks, if appropriate 4. Indicate outdoor storage (O), indoor drun storage (ID), underground storage (U), a b o v e g r d bulk storage ( A ) ,

indoor bag/package storage (IP), or other (specify) 5. Indicate Punp (P), Fork Lift ( F ) , P n e m t i c transport (Pt), Conveyer (C), or other (specify) 6. Indicate gals for liquids and Lbs for solids 7. Indicate L/ lb for solids and $/gal for liquids

Is obsolete raw material returned to the supplier ?- yes I no. -

Does the current inventory control system adequately prevent no. waste generation ? - Yest -

Is there a formal personnel training program on raw material handling, spill prevention, proper storage techniques,and waste handling procedures? - Yes, - no. If yes, how often is the training given?

From the following list Of source reduction techniques associated with general raw material handling, indicate which techniques are currently being used in the facility or to what extent these techniques can be used:

Source Reduction Currently Implementation Potential Technique Done ( Y / N ) ? High Medium Low None

r. Quality control check Minimize inventory Computerize inventory Return obsolete material

11. BULK LIQUIDS

Describe the.safeguards that are in place to prevent the spillage of liquids during the filling of storage tanks (i.e. , high level shutdown alarms, flow totalizers, pipeline drainage or purging before disconnect, dikes,etc.):

Are any storage tanks tied into a vapor recovery system ? yes, - no. If yes, describe the system:

Are all storage tanks routinely monitored for leaks ?- yes, - no. Describe procedure for above-ground tanks:

Underground tanks:

How are the liquids in these tanks dispensed to the users (i.e., in small containers or hard piped) ?

What measures are employed to prevent the spillage of liquids being dispensed ?

E -7

r -

When a spill of liquid occurs in the facility, are dry cleanup

no. Can the wet cleanup wastes be reused? - yes, - no. Describe the cleanup procedure including how the resulting waste is

methods employed ?- yes, - no. Is a residue generated? - Ye*, - no. Are wet cleanup methods employed ? - Yesf -

handled:

Does the current cleaning method allow for recycling of the spilled material? - yes, - no. If no, would switching methods allow for recycling? - Yes? - no. Explain:

From the following list of techniques associated with bulk liquid raw material handling, indicate which are currently being used in theifacility or to what extent they can be used if not currently in place:

Source Reduction Currently Technique Done ( Y / N ) ? ...................................

High level shutdown alarm Flow totalizers w/cutoff Pipeline drainage Vapor recovery Leak monitoring Spilled material reuse Dry cleanup methods(a)

Implementation Potential High Medium Low None

.............................................................. (a) This method is effective in cases where the waste due

to wastewater treatment (generated when wet cleanup methods are employed) is not used to formulate a product.

111. DRUMS, CONTAINERS, AND PACKAGES

Are all received drums, packages, and containers fully inspected for damage before being accepted ?- Yest - no. If damaged items are found, describe the handling procedures employed:

E-a

Are items properly stored to prevent possible damage or contamination? - Yes? - no. Items that are stored outdoors are protected from - rain, - snow, - sun, - extreme heat or cold.

Are employees properly trained in the ways to safely handle the different types of drums, containers, and packages the facility receives ? - Yes?- no. Are they properly trained in the ways

Are all empty bags, packages, and containers that contained hazardous materials fully segregated from the empty bags, packages, and containers that contained non-hazardous wastes ?- Yes? - no. If no, explain why not and the method currently being used to dispose of this waste

no. of handling spilled raw materials ? - Yes, -

~

c.

To reduce the’generation of empty bags and packages, has the

no. If yes, discuss the results: facility attempted to use pigments in slurry form ?- Yest __

Has the facility attempted to use soluble bags? - yes, - no. If yes, discuss the results:

To reduce the generation of dust, has the facility attempted to use pigments in slurry or paste form ?- yes, - no. If yes, discuss the results:

Does the layout of the facility require a heavy amount of traffic through the raw material storage area (heavy traffic increases the potential for contaminating raw materials with dirt or dust and for causing spilled materials to become dispersed through- out the facility) ? - Yes? - no. Can traffic through the storage area be reduced 7- yes, - no.

c.

From the following list of Source reduction techniques associated with drums, containers, and packages, indicate which techniques are Currently being used in the facility and to what extent techniques not currently being used could be:

Source Reduction Currently Implementation Potential Technique Done (Y/N)? High Medium Low None ..............................................................

Raw material inspection Proper handling Proper protection/storage Waste segregation (a) Soluble bags Reusable drums Slurry/paste pigments Reduce traffic Spilled material reuse

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MATERIAL SUBSTITUTION AND PRODUCT REFORMULATION

Do any of the products produced contain hazardous materials (i.e., chlorinated solvents, lead or chrome pigments, mercury, etc.) ? - Yest - no. If yes, has material substitution been tried ?- Yesf - no. Discuss the results if yes or the reasons why if no:

Has there been an increased market demand for high-solids or water-based paints ?- yes, - no. If yes, did the facility experience an - increase or - decrease in the amount of hazardous waste produced. Discuss any problems or benefits the

r- facility faced,due to this change in demand:

. Prom the following list of source reduction techniques associated with material substitution and product reformulation, indicate which techniques are currently being used in the facility and to what extent techniques not currectly being used could be:

Pigment substitution -- Product reformulation -- Other raw mat1 substitution --

-- Solvent substitution

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PROCESS OPERATION

r -

While every manufacturing facility is unique in its layout and operation, there are many activities that are common to all. Process examination, based on a generic paint manufacturing facility layout, should include raw material handling (previously discussed), primary dispersion, let-down, filtering, and packaging. Areas of concern common to all these operations include design, use, maintenence, and cleaning of specific equipment along with all associated pumps and piping.

On a separate sheet give a brief description of the manufacturing process including steps such as primary dispersion, let-down, filtering and filling. Provide sketches when necessary.

Complete the overall mass balance for the facility as shown in Table E-2 . zn addition to Table E-2 , the following list of major sources of waste associated with process operations should be completed by the auditor.

Waste Source/Type Relative Waste Disposal Method/ Quantity, % Handling Procedure ..............................................................

Mill cleaning . Portable tank cleaning Container cleaning Stationary tank cleaning Mixer cleaning Filter equipment cleaning Spent filter elements Filling equipment cleaning -

100 .............................................................. I. GENERAL

How frequently are overall material balances for the plant performed ?

Are the operators provided with detailed operating manuals or instruction sets ? - Yesf - no. Are all operator job functions well defined ?- yes, - no.

Is there a formal personnel training program in place focused on proper process operation and reduction of waste generation? - Yesf - no. If yes, how often is the training provided?

Water

Solvents

Other liquids

Solids

PAINT MANUFACTURING I

FACILITY

Aqueous Solvent Other wastes wastes wastes

Water-based producls

Solvent-based products

Table E-2. Overall Material Balances for the Paint Manufacturing Facility

11. PRIMARY DISPERSION

Indicate the type or number of primary dispersion mills used in the facility (if mills are not used in the facility then this section may be skipped). - sand, - glass bead, - steel

other ( 1 . shot, - roll, - turbine , - Indicate the most ccmmonly used method of feeding raw materials to the mills. - manual , - gravity, or - forced feed from

small (e. g. , 5 gallon) containers, - portable mix tanks, or - . - - large storage tanks. Indicate the most commonly used method of discharging dispersed materials from the mills. - manual , - gravity, or - forced discharge into - small (e.g., 5 gal.) containers, - portable mix tanks, or __ let-down tanks. What percentage of the dispersed material is sent to intermediate storage instead of being used immediately to produce paint . How long do materials usually remain in intermediate storage before being utilized

Indicate the percentage of material that must be passed through the mill once , twice , or more . For materials passed through the mill more than oncefare separate containers used for feeding and receiving - Yest - no. Can the number of containers used (and hence requiring cleaning) be reduced by continuously recirculating the material through the mill instead of using multiple passes - Yes, - no. Would the purchase of a more efficient mill eliminate the need for multiple passes __

no. Yesf - Indicate the percentage or number of mills that are dedicated to the production of a single product . How frequently are the dedicated mills cleaned . With the non-dedicated mills, are they cleaned - after every batch, ___ after every - batches, or - only when the product changes (approximately every - batches). Solvent cleaning of the mills is - used for solvent-based

used for all batches, - not used at all. The type of solvent used for cleaning is - the same as the solvent

1 - used in the batch, - MEK, - other (

The waste stream generated from mill cleaning is - drummed for disposal, drummed for disposal after being reused - times ,

added to the let-down tank as part of the current batch of paint, or __ sent to a holding tank for

From the following list of source reduction techniques associated with the primary dispersion operation, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

batches only, -

- drummed for use in a subsequent batch of paint, -

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Source Reduction Currently Implementation Potential Technique Done (Y/N)? High Medium Low None

Improve Prod. planning -,

Recirculation thru mi11 Reuse rinse solvent Mechanical cleaning. Waste segregation Rework rinse solvent Dedicate mills Standardize clng. solvent Clean w/part of batch Install efficent mills

111. LET-DOWN TANKS

The capacity of portable let-down tanks used in the facility c. ranges from to - gallons. The stationary let-down tanks

range in size'from to gallons. percent of the batches, or percent of the product volume, produced in the facility is made in portable tanks.

Indicate the most commonly used method of discharging paint from the portable let-down tanks. - manual, - gravity, or - forced discharge into - small (e.g., 5 gal.) containers, - another portable tanks, or - - directly into the filtering and filling system.

Indicate the most commonly used method of discharging paint from

forced discharge into - small (e.g., 5 gal.) containers, - another portable tanks, or - directly into the filtering and filling system.

Is the piping to and from the tanks routinely flushed with water or solvent - Yesf - no. Is the piping lfpiggedfl before

no. flushing - Yesf - Describe the cleaning sequence (i.e., manually scraped, washed with a high-pressure spray system using caustic, then solvent rinsed) used for cleaning portable let-down tanks.

the stationary let-down tanks. - manual, - gravity, or -

Describe the cleaning sequence used for cleaning fixed let-down tanks.

Describe the cleaning sequence used for cleaning the mixing units.

Unnecessary cleaning of equipment increases the amount of cleaning wastes generated. Can production batches be sequenced from light-to-dark colors so as to reduce the need for cleaning - Yesf - no. Has the facility investigated the effect of reduced cleaning on product quality - Yesf - no. If yes, was

in production. the testing performed - on a lab scale or - What were the results

c-

Much more drastic cleaning measures are usually required when the paint is allowed to dry inside the tank. Are all of the tanks cleaned promptly after use - Yesf - no. If no, how long do the tanks wait to be cleaned and why

b

Are any precautions from drying - Ye*I

taken during this time to prevent the paint - no. If yes, describe

Are there established procedures for communications between cleaning and production crew? - yes, - no. For facilities using high pressure spray systems, is the nozzle as effective at removing dried paint as originally designed or expected - yes, - no. If no, has the use of new nozzle heads

If a high-pressure spray system is not used for cleaning tanks, does the facility plan on installing one soon - yes, - no. If

no. or higher pump pressures been attempted - yes, -

no, why

If the facility is currently using caustic, have alternative no. If yes, commercial cleaning solutions been tried - yes, -

what were the results

c t-16

From the following list of source reduction techniques associated with the let-down process, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

Source Reduction Current 1 y Implementation Potential Technique Done (Y/N)? High Medium Low None

Dedicate tanks Mechanical cleaning ffPigging@@ pipelines Light-to-dark sequence Prevent paint drying Clean promptly Proper communications High-pressure spray clng. Use of efficient nozzles Replace caustic solution Waste segregation Solvent waste ,reuse Rework solvent waste Standardize clng. solvent Avoid unnecessary clng. Ensure proper batching Minimize evaporative loss

IV. FILTERING & FILLING

Indicate the type or number of filtering units used in the facility - fiber cartridge (- cartridges per unit) , wire mesh cartridge (- cartridges per unit), - bag (- b e per unit) , - other ( 1 -

If wire mesh filters are used, are they backwashable? - Yes? no. If yes, indicate how the waste stream from backwashing is

handled

If no, indicate how the wire mesh filters are cleaned and how the waste is handled

Are any of the filter units dedicated to a particular product line? Yesf - no. - If cartridge filters are used, how many spent cartridges does the facility generate per week . Has the facility attempted to replace disposable filters with reusable filters - yes, - no. If yes, what type of reusable filter was tried and what were the results

If bag filters are used, how many spent bags does the facility produce each week . Are the bags cleaned and reused? - yes I - no. If yes, how many times can they be reused , and indicate how the cleaning wastes are handled

Filling units cleanup: - not cleaned as they are dedicated, - solvent cleaned, - water cleaned. If they are cleaned, indicate the cleaning procedure and how the cleanup wastes are handled -

From the following list of source reduction techniques associated with filtering and filling, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

Source Reduction Currently Implementation Potential Low None Technique Done (Y/N)? High Medium

Use wire screen filters Use bags not cartridges Reuse filter bags Dedicate filter units Dedicate filling units Light-to-dark sequence

V. PORTABLE TANK/CONTAINER CLEANING

The portable tanks are cleaned mechanical, solvent, - caustic. If caustic cleaning is used, is it sometimes necessary to clean with a solvent? - Yesf - no. If yes, are any attempts made to

no. If yes, indicate the results use a more efficient cleaning solutions? Yesf -

off- The product containers are mostly cleaned on-site, site.

Are the product containers cleaned before sending for metal reclamation? - Yesf - no. Comment:

Do you have customer incentive programs to encourage purchase in no. bulk form or in bigger containers? - Yesf -

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Are the empty drums that contained raw materials returned to the no. If yes, are the drums washed before

Are the drums reused? - yes, - no. If yes, then are they

suppliers? - Yes, - no. returning? - Yes, -

no. washed before reuse? - Yes, - Any effort toward using rinseable/recyclable drums attempted? - Yest - no. If yes, indicate the result

From the followlng list of source reduction techniques associated with the cleaning of portable tanks or containers, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

c.

Source Reducdion Currently Implementation Potential Technique Done (Y/N)? High Medium Low None

Rinseable drums Customer incentives Mechanical cleaning Replace clng. solution Efficient clng. nozzle Prevent paint drying

c i-19

PLANT OPERATIONS MANAGEMENT

Plant operations management involves the proper scheduling of production to reduce the need for equipment cleaning, and dealing with management practice such as employer/employee relationships that may have an

I. PRODUCTION SCHEDULING

influence on the amount of waste generated.

Are there any attempts at varying the production schedule to decrease waste generation? - Yest - no. If yes, with what results

Does the production include light-to-dark manufacturing sequence? 7 Yesf - no. If yes, indicate results Are there any attempts at eliminating some cleanup steps between subsequent batches? - yes, - no. If yes, indicate results -

Is the batch formulation attempted in the lab before large scale Yesf - no? If yes, how many times is the lab

scale test repeated to ensure proper batch formulation

From the following list of source reduction techniques associated with production scheduling, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

production? -

Source Reduction Currently Implementation Potential Technique Done (Y/N)? High Medium Low None

Light-to-dark sequence Ensure proper batching Increased supervision Avoid unnecessary clng.

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11. “AGEMENT PRACTICE

Are there employee education programs on how to avoid excessive waste generation? - yes, - no. If yes, how often are the training programs offered? . Are there employee

no. incentive programs regarding waste reduction ?- Yes, - Does the facility have an established waste minimization program in place ?- yes, - no. If yes, is a specific person assigned to oversee the success of the program ? - Yesf - no. Does the program have a set waste reduction goal ? - Yesf - no. Has the program achieved its goals ? - Yesf - no. Explain:

Is the facility fully aware of the current local, state, and federal regulations related to hazardous material storage, treatment, disposal, and recycling? - yes, - no. Has the facility conducted an environmental audit to assess compliance with these regulations? - yes, - no. Does the facility have a problem with the cleaning of containers returned from their clients - Yesf - Has the facility conducted a waste reduction audit or survey in the past? - Yesf - no. If yes, discuss the outcome

c.

no.

Does the facility have a customer incentive program to purchase products in bulk ?- yes, - no. Does the facility view the widespread use of bulk containers (such as Tote bins) as a way of

no. yest - From the following list of source reduction techniques associated with management practices, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

reducing the amount of container cleaning waste generated? -

Source Reduction Currently Implementation Potential None Technique Done ( Y / N ) ? High Medium Low

Employee incentives Established waste minimization programs Set reduction goals Employee training prgms. Customer incentives Increased superrision

WASTE MANAGEMENT

All of the wastes generated at the facility should be tabulated in Table E-3 . Provide a separate copy of Table E-3 for each solvent waste; for example, if MEK and lacquer thinner are both used to clean equipment, fill Table E-3 separately for MEK and for lacquer thinner (i-e. 2 tables). Provide sketches of existing on-site treatment systems including wastewater treatment, incineration, etc.

Does the facility document individual wastes with their sources of origin and eventual disposal along with the incurred disposal costs ?- yes, - no Are the different solvent wastes due to equipment clean-up kept segregated ?- yes, - no. Are the aqueous wastes associated with equipment clean-up kept segregated from the solvent wastes ? - Yest - no. Are the spent alkaline solutions kept segregated from the rinse water streams ?- yes, - no. Has on-site distillation of the spent solvent ever been attempted? - yes, - no. If yes, is distillation still being

no. If no I explain

r.

performed? - Yes I - why:

If the facility generates too many small volume solvent waste streams to justify on-site distillation, can the solvent used for

no. equipment cleaning be standardized ? - Yes? - Did the facility investigate off-site reuse through Waste Exchange services? - Yes I no, or commercial brokerage firms? - yes, - no If yes, indicate the results

Is the spent cleaning solvent reused to the extent possible? - Yesf - no. Are there any attempts at making the rinse solvent part of a batch formulation (rework)? - yes, - no. If yes, indicate the results

E-22

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Are there any attempts made to blend various waste streams to produce a marketable products? - yes, - no. If yes, then this measure was successful, unsuccessful f o r water-based paints, and successful, unsuccessful for solvent-based paints.

If off-site disposal methods are used for solvent wastes, is there any attempt to, generate a waste that will be recycled not incinerated? - Yesf - no. If yes, explain how this was achieved

Is there any economic advantage in generating a recyclable waste? - Yesf - no. Are you sure that your waste is segregated from other wastes when reclaimed by off-site recycler? - yes, I no.

Are the spills collected and reworked? - Yesf .-. no. If yes,

Yesf - na. Clarify why or why not then are dry cleanup methods discouraged at the facility? -

If spills are not collected and reworked, are the dry cleanup methods encouraged (e.g. by closing floor drains)? - yes, - no. Does dry cleanup generate residue or solid waste? - yes, - no. If yes, then how is it managed?

Are empty bags and packages containing hazardous material segregated from the rest before disposal? - yes, - no. Is there a formal personnel training program in place with regards to proper waste management? - yes, - no. If yes, how often is the training provided?

E-24

From the following list of source reduction techniques associated with waste management, indicate which techniques are currently being used in the facility and to what extent techniques not currently being used could be:

source Reduction Currently Implementation Potential Technique Done ( Y / N ) ? High Medium Low None

Reuse cleanup solvent Rework cleanup solvent Segregate bags/packages Segregate wastes (a) Rework wastes Discourage dry clnp. (b) Encourage dry cleanup (c) Caustic sludge dewatering Waste documentation Settling tanks (d)

(a) Refers to segregating various liquid waste streams to facilitate their reuse. F o r example, cleanup wastes containing different colored pigments could be collected in separate containers to facilitate their rework.

(b) If the s p i l l s are collected in sumps and reworked, then it is recammended that dry cleanup methods be discouraged as the wastes generated by them are not amenable to rework.

(c) If the s p i l l s are not reworked at the facility, then the use of dry cleanup methods are recommended as they generate a lower waste volume.

(d) Allowing the solvent wastes to settle and collecting the settled solids, the solvent content in the waste is reduced.

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