p2infohouse.orgwaste minimization for hazardous materials inspectors: module 1 __ introductory text...

WASTE MINIMIZATION FOR HAZARDOUS

MATERIALS INSPECTORS: __ MODULE 1

INTRODUCTORY TEXT WITH SELF-TESTING EXERCISES

PREPARED FOR

C1 .IFORNIA DEPARTMENT OF HEALTH SERVICES TOXIC SUBSTANCES CONTROL PROGRAM

ALTERNATIVE TECHNOLOGY DIVISION

and

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

PREPARED BY

UNIVERSITY EXTENSION UNIVERSITY OF CALIFORNIA, RIVERSIDE

AUTHOR:

SHERIDAN V. (DAN) MERRITT, Ph.D. PROFESSOR OF ZOOLOGY UNIVERSITY OF LA VERNE

PROJECT MRECTOR:

MOLLY W. CARPENTER, M.A.T. CONTINUING EDUCAllON SPECIALIST

UNIVERSITY OF CAUFORMA EXTENSION UNIVERSITY OF CAUFORMA, RIVERSIDE

J A N U A R Y 1 9 9 1

ACKNOWLEDGEMENTS

SPECIAL THANKS TO: Marilyn Kraft, REHS, County of San Bernardino, Department of Health Services (Contributions to Chapter 5)

Jack Van Hise, Artist, Publications Department, UCR Extension (Formatting and Graphics)

Hazardous materials inspectors at San Bernardino County Department of Environmental Health and Riverside County Department of Health, who field- tested this manual.

PROJECT ADVISORY COMMITTEE MEMBERS

John Aubert, General Dynamics, Pomona Division

Kathy Barwick, Califomia Department of Health Services, Sacramento

AI Crane, General Dynamics, Pomona Division

Cathy Godfrey, Bourns Inc., Riverside

Jon Kindschy, University of California Extension, Riverside

Marilyn Kraft, County of San Bernardino, Department of Environmental Health Services

Robert Ludwig, California Department of Health Services, Sacramento

Michael Meltzer, Lawrence Livermore Lab, University of California, Berkeley

Steve Mercer, Rohr Industries, Riverside

Judy Orltung, County of San Bernardino, Department of Environmental Health Services

Mike Shetler, Riverside County Health Department, Hazardous Materials Branch

Donna Toy-Chen, Board of Public Works, Hazardous and Toxic Materials Project, Los Angeles

Linda Verhooven, Rohr Industries, Riverside

Janet M. Weder, Seven W Enterprises and Highland Supply Corp, Redlands

Significant portions of Chapters 4 and 8 were derived from, W t e M inimization Besource Maaual &MA, 1989). Permission for use was granted, on condition that the Chemical Manufacturers Association material not be construed as the “only way” or as an industry standard.

ii WASTE MINIMIZATION: AN INTRODUCTION

Numerous government agencies responded to requests for information about local programs for minimizing hazardous wastes.

Hazardous Waste Research and Information Center, Savoy, Illinois

Alaska Health Project, Anchorage, Alaska

State of California, Department of Health Services, Alternative Technology Section, Sacramento, California

State of Delaware, Department of Natural Resources and Environmental Control, Division of Air and Waste Management, Dover, Delaware

State of Florida, Department of Environmental Regulation, Tallahassee, Florida

State of Georgia, Department of Natural Resources, Environmental Protection Division, Atlanta, Georgia

Household Hazardous Waste Project, Springfield, Missouri

The Council of State Governments, Lexington, Kentucky

Division of Lifelong Education, North Carolina State University, Raleigh, North Carolina

Center for Waste Minimization Management, North Carolina State University, Raleigh, North Carolina

State of Nebraska, Department of Environmental Control, Lincoln, Nebraska

State of Oregon, Department of Environmental Quality, Portland, Oregon

Department of Environmental Resources, Bureau of Waste Management, Division of Waste Minimization and Planning, Harrisburg, Pennsylvania

State of South Dakota, Department of Water and Natural Resources, Pierre, South Dakota

State of Tennessee, Department of Health and Environment, Nashville, Tennessee

State of West Virginia, Department of Natural Resources, Division of Waste Management, Charleston, West Virginia

State of Washington, Department of Ecology, Olympia, Washington

State of Wisconsin, Department of Natural Resources, Madison, Wisconsin

This manual was developed under Contract No. 88-TO363 with the Toxic Substances Control Program of the Department of Health Services.

ACXNO WLEDGEMENTS iii

iv WAsT% MZNIMUATDN: AN RUII(0DUCTION

DISCLAIMER The statements and conclusions of this report are those of the Regents of the University of California and not necessarily those of the State of California or the United States Environmental Protection Agency. The mention of commercial products, their source, or their use in connection with material reported herein is not to be construed as either an actual or implied endorsement of such products.

INCENTIVES FOR INDUSTRY PARTICIPATION IN WASTE I"1MEATION V

vi WASTE MINIMIZATION: AN INTRODUCTION

CONTENTS INTRODUCTION

How to Use This Manual ..................................................................... 1

Overview of Chapter Contents ............................................................... 2

Organization of Chapters ..................................................................... 3 Background: Moving Toward Prevention ................................................... 3

Recent Government Action ............................................................... 3 Relief for Business ..................................................................... 4 Need for Information .................................................................. 4

Waste Minimization: A Different Way of Thinking .................................... 5

CHAPTER 1 . WHY REDUCE HAZARDOUS WASTE? Risks to Health. Damage to Environment. Destruction of Natural Resources

Representative Cases Acid Deposition ........................................................................ 7 Depletion of Ozone Layer ............................................................ 8 Global Climatic Changes ............................................................ 8 Chlorinated Organic Chemical Wastes .......................................... 9 Heavy Metal Wastes .................................................................. 11

Hazardous Waste Dumping ......................................................... 11 Other Reasons ................................................................................. 12

Self-Testing Exercise ........................................................................ 13

CHAPTER 2 . WHAT IS HAZARDOUS WASTE? Defining Hazardous Wastes ............................................................... 15 From Definition to Regulation ............................................................... 17 From Regulation to Reduction ............................................................... 18 Self-Testing Exercise ........................................................................ 19

CHAPTER 3 . WHAT IS WASTE MINIMIZATION? The Waste Management Hierarchy ...................................................... 21

Waste Minimization .......................................................................... -21 Source Reduction ........................................................................... 22 What is not Source Reduction? ......................................................... 23 Recycling .................................................................................... 24


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CONTENTS vii

CHAPTER 4 . INCENTIVES FOR INDUSTRY

Economic Incentives ........................................................................... 29

Reduced Waste Management Costs ................................................... 29 Improve Operations ........................................................................ 30 Reduced Liability Risk ..................................................................... 30 Competitive Advantage .................................................................. 31

Regulatory Incentives ........................................................................ 31 Land Disposal Ban ........................................................................ 31 Activity Reporting ........................................................................... 32 Manifest Certifications ..................................................................... 32 Permit Certifications ........................................................................ 32

Other Incentives ................................................................................. 33 Positive Public Image and Concern for Environment .............................. 33 Product Quality Improvement ............................................................ 33 Govemment Assistance Program ...................................................... 33


PARTICIPATION IN WASTE MINIMIZATION

CHAPTER 5 . WHAT IS THE INSPECTOR’S ROLE IN WASTE MINIMIZATION?

Incentives ....................................................................................... 37 Relationship to Facility ........................................................................ 38

Regulator. Consultant. or Both? ...................................................... 38 Experience as Both Regulator and Advisor .......................................... 38 Potential Conflicts ........................................................................... 38 A Cautionary Note ........................................................................... 38 Role of the Inspector in the Adoption of a Waste Minimization Program ...... 39 Information .................................................................................... 39 Inspection .................................................................................... 39

Relationship to Regulatory Agencies ...................................................... 40 Acquiring Information for Departmental Programs ................................ -40

Interaction With Other Concerned Agencies ....................................... 40 Awareness of Barriers Facing Industry ................................................ 40

Self-Testing Exerclse ........................................................................ 43

viii

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WASTE MINIMIZATION: AN INTRODUCTlON

CHAPTER 6 . SOURCE REDUCTION STRATEGIES AND EXAMPLES

Source Reduction .............................................................................. 45 Good Operating Practices ............................................................... 46

Waste Management Cost-Accounting .......................................... 46

Inventory Management ............................................................... 47 Production and Procedural Scheduling .......................................... 47 Material Handling Improvements and Loss Prevention ..................... 47 Waste Stream Segregation ......................................................... 48 Personnel Education. Communication and Involvement ..................... 49

Changes in Technology .................................................................. 49 Process Changes (including in-process recycling) ........................... 49 Equipment. Piping or Layout Changes .......................................... 50 Additional Automation ............................................................... 51

Changes in Input Materials .............................................................. 31 Material Purification .................................................................. 51 Material Substitution .................................................................. 52

Changes in Product ........................................................................ 52 Product Substitution .................................................................. 52 Product Conservation ............................................................... 53 Changes in Product Composition ................................................ 53

Source Reduction Checklists ............................................................ 53 Source Reduction Opportunities Applicable to All Operations ............ 53 Source Reduction Opportunities in Continuous Process Operations ... 54 Source Reduction Opportunities in Batch Operations ........................ 54 Source Reduction Opportunities in Manufacturing Operations ............ 56


CHAPTER 7 . RECYCLING TECHNIQUES . ONSITE AND OFFSITE Onsite Use and Reuse ........................................................................ 62

Return to Original Process ............................................................... 62 Raw Material Substitute for Another Process ....................................... 62

Offsite Recovery or Reclamation ............................................................ 63 Interindustry Waste Exchange ............................................................... 63 Energy Recovery .............................................................................. 64 Self-Testing Exercise ........................................................................ 65

.

.

CONTENTS ix

CHAPTER 8 . BARRIERS TO EFFECTIVE WASTE MINIMIZATION

Financial ....................................................................................... 67

Technical ....................................................................................... 68 Institutional ....................................................................................... 69 Self-Testing Exercise ........................................................................ 71

CHAPTER 9 . WASTE MINIMIZATION SUCCESS STORIES

.................................................................................... Informational 68

Source Reduction .............................................................................. 74

Comprehensive .............................................................................. 74

Good Operating Practices ............................................................... 75 Changes in Technology .................................................................. 76

Changes in Input Materials ............................................................... 78

Changes in Product ........................................................................ 79

Recycling ....................................................................................... 79

Off site ....................................................................................... 80

Waste Exchange ........................................................................... 81

Self-Testlng Exercise ........................................................................ 83

Onsite ....................................................................................... 80

APPENDIX A . TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF INTRODUCTION

Classifying Hazardous Waste Streams ................................................... 85

Common Industrial Sources of Hazardous Wastes .................................... 90

Small Quantity Generators (Examples of waste streams) ........................ 92

A Closer Look- Organic Solvent Waste Streams in California Industry ......... 94

Types of Commonly Used Organic Solvents ....................................... 94

Processes That Use Organic Solvents ................................................ 94

Major Solvent-Generating industries and Processes in California ............ 95


APPENDIX B . SB 14 . HAZARDOUS WASTE SOURCE REDUCTION AND MANAGEMENT REVIEW ACT i o 3

REFERENCES .............................................................................. 133

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.

X WASTE MINIMIZATION: AN lNTRODUCTlON

INTRODUCTION

HOW TO USE THIS MANUAL This manual is written for use by both experienced and novice hazardous materials inspectors who wish to learn more about hazardous waste minimization.

NOTE TO SUPERVISORS: The material will be retained best if read over a period of several days with opportunity for discussion and reflection between chapters.

Field tests indicate that six to eight hours should be allowed for experienced hazardous materials inspectors to complete the manual. Inexperienced inspectors and trainees require between 12 and 16 hours.

NOTE TO EXPERIENCED INSPECTORS: Chapters 1 and 2 and Appendlx A review basic information on environmental pollution, hazardous waste definitions, and types and sources of hazardous wastes. If you have experience and/or training in hazardous materials regulation or management, you may already know the information presented. In that case, you may wish to go directly to the self-testing exercises for these sections and test your knowledge of the material covered. If you know 75% of the correct answers go to chapter 3.

After reading the chapters carefully and completing successfully, in writing, the self-testing exercises, you should have a good working knowledge of

Some of the reasons that a pollution prevention approach is needed.

What waste minimization is.

Barriers and incentives to industry participation in hazardous waste minimization programs.

Some of the basic hazardous waste minimization techniques and strategies being used successfully in several types of industries.

You will also have reviewed some of the ways that

w Waste minimization is already a part of the inspector’s work.

The relationship between inspector and generator may change as a result of their cooperative work in hazardous waste minimization.

Suggested procedure for mastering the contents of each chapter: 1) Read carefully through each chapter. Skim the main points again.

2) Turn to the appropriate self-testing exercise in the back of the manual.

3) Write the answers to each of the questions.

4) After you have completed the exercise, check each answer by rereading the appropriate topic section of the chapter.

INTRODUCTION 1

5) If you answered the question incorrectly, study that section again.

a) If the question was an essay question, try closing the book and

b) If the question was objective (multiple choice, matching, etc), test

writing the complete answer correctly,

yourself again by restating the question as an essay question, then answering it.

for your brilliance and proceed to check the next question.

process with the next.

6) If you answered the original question correctly, then congratulate yourself

7) After you have mastered the material in that chapter, go on to repeat the

You may wish to work with another person or in a small group and discuss the material before beginning the self-testing exercise. For some people, the combination of oral articulation and written exercise increases learning efficiency and retention. You are also encouraged to challenge and debate the information and interpretations presented in this manual and to suggest alternatives.

OVERVIEW OF CHAPTER CONTENTS Chapter 1, “Why Reduce Hazardous Waste?”, underlines the inadequacy of so called “end-of-pipe” pollution control approaches by reviewing several examples of global and local environmental pollution problems threatening human health and the integrity of the environment. The cases discussed here have led to wide public support for preventing hazardous waste entering the environment.

Chapter 2,“What is Hazardous Waste?”, reviews the definitions of ”waste” and “hazardous waste” as presented in RCRA and as adapted for California. These definitions are discussed in the context of evolving environmental laws and regulations.

Chapter 3, “What is Wake Minimization”, defines and gives examples of waste minimization and its two subcategories: source reduction and recycling. The distinction is made between waste minimization and treatment/disposal operations. Examples of actions which are not considered by California law to be source reduction are reviewed.

Chapter 4, “Incentives for Industry Participation in Waste Minimization”, answers-from an industry point of view-the question, “What do businesses have to gain from adopting waste mimimization practices?”.

Chapter 5, “What is the Inspector’s Role in Waste Minimization?”, examines incentives that might motivate inspectors to adopt the waste minimization approach, and what the inspector’s relationship to the facility and to the regulatory agencies might be in his or her capacity as waste minimization “consultant/advisor”. Ways that an inspector might best help facility personnel overcome the barriers to adoption of waste minimization practices are suggested.

2 WASTE MINIMIZATION: AN INTRODUCTION

Chapters 6 and 7. Provide examples of general and operation-specific changes that business personnel can make in applying waste minimization practices to their facilities.

Chapter 8, “Barriers to Effective Waste Minimization”, discusses some of the factors discouraging the adoption of source reduction and recycling by industry.

Chapter 9, “Waste Minimization Success Stories”, presents short summary accounts from businesses that have successfully applied waste minimization practices to their operations.

Appendlx A. For those inspectors who wish to have a review of the main types of hazardous wastes generated by various processes, Appendix A has been included. Although space and time does not permit an exhaustive review of this field, in the Appendix you will find a discussion of some types and sources of hazardous waste. It provides:

1) a brief introduction to hazardous waste stream classification ;

2) a list of general types of hazardous waste you can expect to see on visits to

3) a detailed look at a representative waste stream common to California

small quantity waste generating shops and plants; and

industry- organic solvents.

ORGANIZATION OF INDIVIDUAL CHAPTERS Chapters include:

A listing of the main points to be covered in the chapter.

The main body of text. Wherever appropriate, items being discussed in detail are first listed, then discussed and illustrated with examples.

Figures to clarify and graphically summarize information.

Tables and figures presenting additional information and examples.

A self-test for each chapter.

BACKGROUND: MOVING TOWARD PREVENTION Reduction of waste through prevention (source reduction) and recycling is an idea whose time has come. The general public, the business community and government agencies are seeking solutions to the very grave problems presented by toxic and otherwise hazardous chemical wastes.

RECENT GOVERNMENTAL ACTION In the past, government has responded to evidence of damage to health and the environment by regulating the treatment and disposal of hazardous wastes and attempting to mitigate damages already done. In recent years, however, widespread concern over risks to public health and damage to the environment has pressured local, state and federal governments to adopt ways of limiting the generation of hazardous wastes at their sources.

INTRODUCTION 3

A national policy of reducing or eliminating the generation of hazardous waste was promulgated in the1984 amendments to RCRA (Resource Conservation and Recovery Act). These amendments recommended that hazardous waste reduction at the source be considered first-before recycling, treatment and disposal options. More recently, some states have adopted laws devoted specifically to waste minimization.

For example, in California, Senate Bill 14 (Roberti), the Hazardous Waste Reductlon and Management Revlew Act, was passed in 1989. This bill is designed to reduce the generation of hazardous waste and the release of chemical contaminants into the environment. It intends to promote exchange of information about waste reduction and recycling between governmental agencies, industry and the public.

Under this law, certain industries are required to submit hazardous waste reduction evaluation review plans and implementation reports, which will then be available for public review. (Other aspects of this law and recent federal regulations will be discussed in the text. See Appendix B for the text of the statute and/or regulations. Regulations were not available at the time of this writing.)

Relief For Business Minimizing the generation of hazardous waste is a promising alternative for industry. Increasing numbers of companies are being identified as generators of hazardous wastes under evolving hazardous waste management laws and regulations. Further, the costs of treating and disposing of hazardous wastes continue to rise. Meanwhile, as the discovery of past mistakes in waste disposal has grown, so has the extent to which the generator of those wastes is held liable for damages to the environment and to public health. The potential financial impad of cradle-to-grave liability on hazardous waste generators is having a profound effect. For example, many companies that used accepted disposal methods decades ago are being sued for cleanup and cost-recovery.

On the other hand, many businesses that have adopted waste minimization programs have, as a result, reduced operational costs, improved worker safety and enhanced their public image.

Need For Information One of the factors identified as a barrier to wider participation of industry, particularly smaller facilities, in waste minimization programs has been a lack of information about practical alternatives to treatment and disposal (CMA, 1989).

To assist in overcoming this hurdle the Alternative Technologies Division of Califomia’s Department of Health Services has, for the past few years, administered a Waste Reduction Program. This program has provided industries with technical information and grant assistance for various approaches to waste reduction, including treatment as well as source reduction and recycling.

This manual has been developed (under a grant from the State Department of Health Services) to help bring you, the field inspector, into the information dissemination process. The emphasis here is on the promotion of waste minimization--source reduction and recycling--as alternatives to treatment and disposal.

4 WASTE MlNlMlZATION: AN INTRODUCTION

As a hazardous materials inspector with knowledge of and experience with regulations and with management options for handling hazardous materials, you are in a unique position to work together with generators who are exploring the applicability of waste minimization principles within their industries. Your training in recognizing possibilities for changes in processes and procedures can be put to good use in helping to reduce hazardous waste generation within these companies.

WASTE MINIMIZATION A DIFFERENT WAY OF THINKING Some of the ways that the waste minimization approach differs from treatment and disposal are presented below:

W The focus of waste minimization is first on - of waste (source reduction) and second on -what waste has been generated.

W Waste minimization is not a "technical fix". Although it may involve some technological changes, its successful application relies on an assessment of the overall, as well as individual, steps of manufacturing, processing or handling operations.

Waste minimization cannot be left to the environmental compliance person, the plant engineer or any other single person in the organization. It succeeds best with strong endorsement by management and active support and participation throughout the facility.

W Waste minimization is especially suited to promoting cooperation between generators of hazardous waste and regulators and between generators of hazardous waste and environmental protection groups. For example, The Environmental Defense Fund and the Metropolitan Water District of Southern California, traditional adversaries,recently established the Source Reduction Research Partnership for the purpose of assessing the potential for reducing the use of chlorinated solvents in industry through waste minimization strategies.

is more akin to the self-renewing biogeochemical processes operating in nature. Source reduction and recycling help to reduce the rate at which natural resources are removed from the environment, thus allowing more time for their replacement, if they are renewable resources, and for substitutes to be found if they are not.

In addition, source reduction and recycling- by reducing the amount and toxicity of materials returned to the environment- can help avoid ovetwhelming the earth's natural transformation and biodegradation processes. Source reduction will play a central role in the emerging field of "Industrial Ecology" (Frosch & Nicholas,l989).

W The waste minimization approach to hazardous waste management

\

INTRODUCl7ON 5

6 WASTE MlNIMZATION: AN INTRODUCJTON

Demonstrate the need to reduce hazardous waste generation through the review of six cases of environmental pollution. This review will illustrate the extent to which these pollutants:

Pose risks to public health

Cause damage to the environment

Destroy natural resources

Chapter 1 WHY REDUCE HAZARDOUS WASTE?

The management of hazardous wastes and other contaminants exclusively through "end-of-pipe" pollution control approaches has proved grossly inadequate for safeguarding human health and preventing environmental degradation. In spite of numerous laws and regulations and extensive government and industry expenditures for treatment and disposal of pollutants, unacceptable amounts of dangerous and ecologically damaging chemicals have been and continue to be discharged into the environment.

It is important for anyone promoting waste minimization to understand this and to be familiar with the body of information on which this conclusion is based. For this reason we will devote the next few pages to discussing six representative cases of environmental pollution that show the degree to which public health, the environment and natural resources are jeopardized by current practices. Societal concern about these issues is fueling the widespread popular support for reducing environmental pollution.

The six cases discussed are:

1. Acid deposition ( e.g., acid rain)

2. Depletion of the ozone layer

3. Global climatic changes

4. Chlorinated organic chemical wastes

5. Heavy metal wastes

6. Hazardous waste dumping

1. ACID DEPOSITION/ACID RAIN It is now widely known that the sulfur and nitrogen oxides produced by coal- burning power plants, automobiles, and factories form sulfuric and nitric acids in the atmosphere. The acidic rain, snow and dust washed back to the earth is driving the pH of water and soil in poorly buffered regions to levels so low that they cannot support most forms of life. The water in many lakes, in fact, has become toxic to fish, amphibians, and microfauna. --

WHY REDUCE HAZARDOUS W S T E ? 7

For example, in 1930,96% of the Adirondack Mountain lakes in New York State supported healthy fish populations. Today, all but 10% of the high mountain lakes are too acidic (pH < 5) for fish to survive and reproduce. In southeastern Canada 1,400 lakes have lost their fish population. In the lake-rich mountains of Sweden 6,000 lakes are dead-without fish or invertebrates.

Acid precipitation also interacts with other wastes. Nitric acid rain and snow, formed from nitrogen oxides generated in western and Pacific Coast urban centers, are leaching heavy metals from the mine tailings of 10,000 abandoned mines into streams, rivers, and lakes of the Rocky Mountain watershed.

A recent study, based on EPA data, found that half the streams of the mid- Atlantic and southeastern states are either now acidic or are on the verge of acidity. Another study estimated that 25% of the nitrogen entering the Chesapeake Bay is provided by acid deposition and has contributed to the unusual ,'brown tides" (algae blooms) which are driving the dissolved oxygen levels down and threatening the regional fisheries industry.

Pine trees in two-thirds of the San Bemardino National Forest have been damaged by a combination of ozone, acid rain, acid fog, and consequently suffer increased susceptibility to infectious agents. One-third of the trees in the forests of Germany show visible damage by ozone and acid deposition.

2. DEPLETION OF THE OZONE LAYER Since a large hole in the stratospheric ozone envelope was discovered a few years ago over the Antarctic, it has been established that the thinning of the ultra violet-filtering ozone layer is a general global phenomenon and poses serious risk of increased skin cancer cases, severe sunburn, and damage to the eyes. UV light also causes direct damage to plants. It has been found to slow the rate of photosynthesis in oceanic phytoplankton which produce about 80% of the earth's new oxygen and which serve as the foundation for complex oceanic food webs.

Predictions of the rate at which chlorofluorocarbons (CFCs), volatile chlorinated solvents, and nitrogen oxides are depleting the ozone layer vary. Estimates range from 2 to 12% reduction of stratospheric ozone content over the next 100 years. Some studies indicate that an overall 3% thinning of the ozone layer has occurred during the past 10 years. A single chlorine atom from a CFC molecule may destroy 10,000 ozone molecules. Parts of Australia experienced a 14% average increase in UV exposure during the month of December, 1989. This represents a significant public health risk, since a 1% decrease in ozone is estimated to generate a 245% increase in the incidence of human skin cancer.

3. GLOBAL CLIMATIC CHANGES

8

Increased scientific research and multinational conferences are addressing the growing evidence that the earths temperature is rising due to an increased rate of buildup of the greenhouse gases: carbon dioxide, CFCs, and methane in the upper atmosphere. Predictions of the effects of this global warming include elevation of sea level around the world and severe disruption of weather patterns

WASTE MlNIMlZATlON: AN INTRODUCTION

in many regions. Evidence of a tong-term warming trend is still being weighed at the time of this writing but a consensus is growing among international scientists and government leaders that significant global warming is occurring.

The following three cases represent what would be considered, from a regulatory point of view, to be more strictly within the scope of hazardous waste issues. They involve toxic chemical wastes that have entered the soils, rivers, lakes, groundwater and oceans. Initially, their damaging effects were felt only locally. These effects have begun to spread beyond the community and national boundaries within which the wastes were generated.

4. CHLORINATED ORGANIC CHEMICAL WASTES Polychlorinated biphenyls (PCBs), banned in the 1 9 7 0 ~ ~ continue to haunt us. Together with the pesticide DDT, they have taught us costly lessons about the mobility, toxicity, and pervasiveness of pollutants in the environment.

PCBs, along with other chlorinated organic compounds, can be found sequestered in the fat deposits of virtually all Americans. Indeed, levels of PCBs, DDT, and dieldrin were found by the EPA (1976) to be so high in the milk of nursing mothers they exceeded the FDA's daily permissible intake dose for infants. Though little is known about the long-term health effects of chronic exposure to low levels of these toxins, there is ample reason for concern about latent cancer, birth defects, and reproductive problems.

Where are the 1.4 billion pounds of PCBs which were manufactured in the U.S. before production was banned in 1979? Only 4% are considered to have been disposed of safely. Ten percent were exported to other countries and their fate is unknown. Presumably they are making their way into the environment. More than 50% of the PCBs manufactured are still in use in the U.S., mostly in electrical equipment.

Over 32% of the PCBs produced have already been lost to the environment. Two-thirds of these are in landfills (half of which appear to be leaking into the soil and/or groundwater) and 1/3 are in the air, lakes, rivers, open ocean, and bottom sediments of fresh and marine waters. They have been found in ice and snow samples from both poles and increasingly in deep ocean sediments. From the water and bottom sediments, PCBs have been entering complex environmental cycles and undergoing biological magnification in fish, fish-eating birds, and aquatic mammals.

Striped bass and salmon from the Hudson River, the main spawning water for the east coast from Massachusetts to Delaware, have shown PCBs as high as 100 ppm. Fish in the St. Lawrence River and the Great Lakes frequently show levels in excess of 5 ppm (2 1/2 times the allowable levels set by EPA). New York State has begun issuing, together with fishing licenses, a warning not to eat striped bass and to consume other fish caught in state waters only sparingly.

Restrictions and wamings on consumption of PCB-contaminated fish have been imposed on both east and west coasts, as well as the nearshore waters of the Gulf of Mexico. Anglers surf-fishing on beaches near Los Angeles are advised by posted wamings against the consumption of white croakers due to contamination with PCBs and DDT. These chemicals had been dumped since

WHY REDUCE HAZARDOUS W!ZE ? 9

the late 1940s into sewer systems or directly into California coastal waters by several local companies. At the time of this writing 15 companies are being sued by the National Oceanic and Atmospheric Administration for this dumping.

Researchers continue to find high concentrations of PCBs, DDT, and their derivatives in sediments, in worms and shellfish, and in fish in the area. The increased concentration of toxins found in the upper levels of the food chains reflects a textbook definition of biological magnification. Furthermore, the local fish exhibft significantly higher numbers of liver and skin lesions than do uncontaminated fish from outside this area. Similar findings are reported for San Francisco Bay and Puget Sound, Washington.

Dloxlns include about 75 different closely related compounds. Some (the tetrachlorodibenzo-paradioxins, or TCDDs) are considered to be the most toxic synthetic chemicals known. They are often found together with PCBs. They occur as by-products in the manufacture of many synthetic halogenated organic chemicals as well as during their biological and industrial destruction or transformation. Because of their similar properties, much of what has been said above about PCBs is true for dioxins, including environmental dispersion and accumulation in body fat of humans and wildlife.

Dioxins gained much media attention when it was discovered that the city of limes Beach, Missouri, had been contaminated for several years by dioxin- contaminated used oil. The oil had been bought from a “recycler” and spread over the dirt roads to control the dust. In 1983 the town was bought by EPA for $30 million and 300 residents were relocated. Most of the contaminated soil was removed to landfills. Twenty-six other Missouri sites are known and seventy-five more are suspected to be contaminated with dioxins.

There is growing public concern about the production of dioxins during incinerator operation. Much of the local opposition to siting of waste incinerators is based on fear of the release of dioxins and dioxin-like substances (e.g., chlorodibenzofurans from PCBs) that are produced during combustion of various halogenated organic compounds.

TCE (trichloroethylene or trichloroethene) and other carcinogenic chlorinated organic solvents escaping through leaking underground storage tanks, poorly managed industrial operations, and poor disposal practices by industry and the military, have seriously damaged drinking water supplies in the United States.

In Northern California, extensive TCE contamination of wells has been discovered in the ”Silicon Valley” area of Santa Clara County and around military bases near Sacramento. In Southern California, numerous community drinking water wells in the San Gabriel and San Fernando Valleys (near Los Angeles) remain closed since TCE at 1 to 190 ppb was discovered in the water in 1979. These levels are up to 180 times the action levels set by the State. By 1990, after 11 years and $10 million had been spent studying the problem, cleanup still had not yet begun. Estimates on the cost of cleanup with federal and State Superfund money are in the hundreds of millions to one billion dollar range. Remediation is expected to take an additional 10-20 years or longer.

Continued pollution of existing groundwater supplies, combined with the fact that the water table is being drawn down faster than it is being replenished, could lead to severe shortages of potable water in much of the State in the near future.

10 WASTE MINIMIZATION: AN INTKODUCTION

This is of particular concern for Southern California, which relies heavily on groundwater sources. The rapidly growing inland communities draw about 80% of their drinking water from groundwater.

5. HEAVY METAL WASTES The socalled “heavy metals” pose a hazard to humans and many other organisms by virtue of their organ and tissue toxicity and their tendency to accumulate within the body.’ Like the halogenated organics, some of them also undergo biological magnification as they are processed through plants and animals at successive levels of the natural food chainshvebs.

Mercury, cadmium, chromium, zinc, arsenic, and lead are among the more toxic inorganics found in the environment, in hazardous waste dumps and existing industrial hazardous waste streams. In Califomia, 20% of the hazardous wastes generated contain acids carrying these dissolved metals. Major sources include metal plating, forging, photoprocessing, mining, and electronics industries. Specific industrial and process sources are identified in Appendix A.

Lead According to a 1986 study by EPA, 77% of the U.S. population overall, and 88% of all children under the age of five have unsafe levels of lead in their blood. Even low levels of lead can exert neurological effects leading to hearing loss, high blood pressure, and diminished capacity to learn. Children under the age of nine are most susceptible to lead poisoning. Most of the lead absorbed accumulates in their bones, where it has a long residence time.

Most (goo/,) of the lead dispersed to the atmosphere, soil, and water comes from burning leaded gasoline. Other sources include paint on older structures abandoned waste sites, and lead-soldered water pipes.

6. HAZARDOUS WASTE DUMPING The impact of decades of careless and intentional land disposal of hazardous waste in the U.S. is inestimable. The EPA guesses that 30,000 to 50,000 hazardous waste sites exist. Ninety percent of those in the eastem half of the country are leaking toxic substances into groundwater. The number of sites eligible for federal and state Superfund cleanup assistance, according to the Office of Technology Assessment, is expected to grow to 10,000 at an estimated remediation cost of $100 billion over 50 years. Half of the people in the U.S. reside within a county with a Superfund site. Over 950 sites have been placed on the National Priorities List because of threats to nearby populations via air, surface water or groundwater. New Jersey has the greatest number of priority sites of any state, with 96. California is ranked fifth with 48 sites.

In addition, the severity of chemical and radioactive contamination of federal lands used for military weapons research and development is only recently coming to light.

As the amount of hazardous waste generated by the large industrial centers along the east coast continues to grow and the number of disposal sites to shrink, the pressure is on the rural midwest to receive more imported waste. Similarly, the pacific coast cities are looking to their inland desert lands as waste

WHY REDUCE HAZARDOUS WSTE ? 11

depositories.

Some waste handlers have been looking to Third World countries as potential custodians of our toxic waste. Export of hazardous wastes from U.S. and Western Europe to African, Eastern European, and South Pacific Island nations has become big business with the known amount shipped out between 1987 and 1989 reaching 3 million tons.

Later in this manual we will discuss other motivating factors for seeking ways to minimize hazardous waste. These factors are focused more on economic considerations, which tend to be more appealing to business people, whose performance is generally evaluated on short-term profitability. However, economic factors can change rapidly and public opinion is exerting increasing pressure on business and government alike to reduce environmental pollution. Regardless of the presence or absence of profitability associated with reducing hazardous waste production, the facts and trends presented above make it quite apparent that the pollution control approaches of the past, that relied on end-of- pipe treatment and disposal, are unacceptable for the future. Alternative approaches are needed. Pollution prevention through waste minimization is a promising alternative.


CHAPTER 1 -

WHY REDUCE HAZARDOUS WASTE?

SELF-TESTING EXERCISE Instructions: Read through each question carefully and wriie your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter. Note that you are asked to explain your answers to the some of the questions.

Questions:

1.1 What two types of acid comprise the most common forms of acid precipitation?

1.2 Which type is most common in the Western U.S.?

1.3 Describe two examples illustrating the extensive damage done to the environment by acid precipitation.

1.4 Explain how acid rain can be a factor in increasing heavy metal pollution of mountain streams.

1.5 The earth's stratospheric ozone envelope provides living forms protection from exposure to what?

1.6 Name three substances that have the ability to reach the stratosphere and to break down the ozone molecules. For each, identify a major contributing source of emission.

1.7 Name two consequences for human health and one for the environment that may result from further depletion of the ozone layer.

1.8 Name three greenhouse gases name a major source* for each. ('These sources were not specifically mentioned in text.)

WHY REDUCE HAZARDOUS M14STE ? 13

1.9 Which of the series below correctly reflects the increasing (from left to right) concentration (biological magnification) of DDT or PCB in the oceanic environment? (Not specifically delineated in text)

A. humans--> marine fish--> marine worms--> Ocean sediment--> Ocean water

B. ocean sediment--> ocean water--> marine worms--> marine fish--> humans

C. ocean water--> ocean sediment--> marine worms--> marine fish--> humans

D. ocean water--> ocean sediment--> marine fish--> marine worms--> humans

E. None of the above is correct.

1.10 Discuss each of the following with respect to TCE.

A. Primary industrial sources.

B. Public health concerns.

C. Well water contamination that has been reported in areas other than those mentioned in the chapter (Silicon Valley and San Gabriel Valley).

1.11 Discuss each of the following with respect to heavy metal wastes.

A. Most hazardous types (List at least 5).

B. Major sources (Be as specific as you are able).

C. Health and environmental hazards posed by lead contamination.

1.12 Briefly discuss the history and current status of a hazardous waste site in your local geographic area. You may wish to interview someone in your department for this information. In your discussion touch on some or all of the following points:

w Location

Historical background

w Users (industrial, municipal, etc.)

w Still operating?

w Any toxic material escaping?

Public attitude toward the facility.

w State or federal Superfund Site?

w Plans for remediation or removal. Cost estimates.

w Ongoing litigation, if any.

14 WASTE MINIMIZATION: A N INTRODUCTION

H Present and discuss the limitations of some of the definitions and

H Review the formal legal definitions of “waste” and “hazardous waste” as

names given to “hazardous waste”.

found in federal and California environmental laws.

H Delineate some of the criteria and lists that define hazardous

H Discuss the need for a broader definition of hazardous waste to help us move

waste for the purposes of its regulation.

from hazardous waste control to hazardous waste minimization.

Chapter 2 WHAT IS HAZARDOUS WASTE?

A text-book definition of hazardous waste might read as follows:

A hazardous waste is any discarded material that may pose a substantial threat or potential hazard to human health or the environment when managed improperly The above definition of hazardous waste is clear, uncomplicated, and appears to cover whatever contingencies might arise. It is the kind of crisp, clear, easily memorized definition that students newly introduced to a subject hope for. Unfortunately, as lawmakers and administrative agency regulators have learned, as a definition takes on the weight of law it becomes more complex. Unforeseen contingencies, differing interpretations, specified exceptions, and new technical information influence the metamorphosis of the definition from its general form to the specific, detailed wording needed for effective regulation.

The derivation of a widely accepted, legally defensible definition of hazardous waste has not come easily or without some confusion. Existing statutory definitions have evolved gradually through a complex series of environmental laws, amendments, and regulations promulgated during the 1970s and 1980s. Within these laws various terms and criteria, such as source, human and environmental effects, and/or the physical and chemical characteristics of the substances involved, have been used to define hazardous wastes.

Hazardous waste by any other name A variety of terms appears in the patchwork of early federal environmental laws. The name used has often varied with the form of the material and the environmental medium (land, air, inland surface waters, groundwater, etc.) into which it passed. Some examples follow:

Law Term ~

Resource Conservation and Recovery Act (RCRA)

(Continued on next page)

“Hazardous Waste”

WHATIS HAZARDOUS WASTE ? 15

Clean Air Act (CAA) “Criteria Polluntants” and “Hazardous Air Pollutants” (“Air Tox ics”)

Clean Water Act (CWA) “Conventional Pollutants” and “Toxic” or “Priority Pollutants”

Comprehensive Environmental Response, “Hazardous Substances” Compensation, and Liability Act (Includes all the above by (CERCIA, Superfund) reference)

RCRA ‘Waste” RCRA is the source from which most federal and state definitions of hazardous waste have arisen. It begins the definition of hazardous waste by defining “solid waste” (Sec. 1004(27)).

The term ”solid waste” means any garbage, refuse, sludge, from a waste treatment plant, water supply treatment plant or air pollution control facility and other discarded material, including SOW, liquid, semisolid, or contained gaseous materials resulting from industrial, commercial, mining and agriculture operations and from community activities ...( continues with exceptions) (italics added).

Note that RCRA’s definition of “solid waste”, has the potential to include any hazardous material whether in the solid, liquid, or gaseous form.

EPA, in implementing RCRA, has further clarified and broadened the definition of solid waste in a series of definitions and subdefinitions:

Solid waste

Discarded material

= Any discarded material not excluded by

= Material abandoned, recycled or inherently

regulation (40CFR 261.2(a)).

wastellke (40CFR 261.2(c)).

Abandoned = Disposed of, burned, or incinerated, or accumulated, stored or treated prior to or in lieu of abandonment (40CFR).

inherently waste-like = If so defined by EPA regulations (40 CFR).

RCRA ”Hazardous Waste” In the regulatory sections of RCRA this broadly defined solid waste is identified as hazardous through further definition as:

a solid waste or combination of solid wastes, which because of its quantity, concentration, or physical , chemical or infectious characteristics may

(A) cause, or significantly contribute to an increase in mortality

16 WASTE MlNIMlZATlON: AN INTRODUCl‘ION

or an increase in serious irreversible, or incapacitating reversible, illness; or

(6) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed.

California Hazardous Waste In California law the word “solid“ was dropped because it has a different meaning as used in State regulations (Tile 22, Health & Safety Code, 25148.5). California also added to the definition any material in mislabeled or inadequately labeled or deteriorating or damaged containers (Health & Safety Code, 2511 7 & 25124). Otherwise, the Caliiornia definition is patterned after the federal solid waste definition.

FROM DEFINITION TO REGULATION Hazardous Waste Hit ”Lists” Within California, wastes which are to be regulated as “hazardous” appear on lists. Some of the lists have been prepared at the federal level while others come from the State. Federal examples include those in RCRA (40CFR, 261) in CERCLA (40CFR 302.4), and in Superfund Amendments and Reauthorization Act (SARA) Tile 111 (40CFR 372.65). In Callornia, see the Calilomia Code of Regulations (CCR), Tile 22, Art. 9 & 11 and the “Governor’s List” in California Health and Safety Code (CH&SC, Sec. 25249.8) as examples.

Criteria or Characteristic Wastes Other wastes are regulated as hazardous based on their physical, chemical, or toxicological (both human and environmental) properties. These criteria vary within statutory and agency documents with slight differences between those used by EPA, DOT, and the State of California. This classification scheme is sometimes referred to as a chemical hazard classification.

The following are representative of classes of criteria waste likely to be encountered at fixed-site waste generating facilities.

1. Ignltable/flammable/combustible hazard

2. Reacthre hazard

Chemicals producing fires under various circumstances.

Usually refers to chemicals that undergo violent or high toxicity reactions under ambient conditions or with water, e.g., water-reactives such as elemental sodium. Compatibility between waste types is of concern here. Includes explosives.

3. Corrosive hazard Chemical reactions which are damaging to associated materials, including human tissue. Includes halogens and strongly acidic or alkaline (pH 12 or 212.5) substances.

WHAT IS HAZARDOUS WSTE? 17

4. Toxic hazard In addition to listing toxic chemicals, regulations have established criteria for determining whether chemicals are toxic hazards (CCR l itle 22, Art.11). These criteria include: LD50, LC50, and other data that indicate a chemical is or is likely to be a somatic or reproductive toxin, a mutagen, a carcinogen, or a teratogen.

Envlronmentally Persistent and Bloaccumulative Toxins Regulations for toxic chemicals have been designed to protect the environment as well as human health. For example, toxic chemicals that have been shown to be slow to degrade or to concentrate within organisms as they are passed through the trophic levels of the food chains or webs are regulated. CCR, Tile 22, Art. I1 contains a list of regulated inorganic and organic persistent and bioaccumulative toxic substances.

FROM REGULATION TO REDUCTION Need for a Broader Definition What about efforts undeway to shift from an emphasis on simply regulating hazardous waste production to reducing the amount of hazardous waste being generated in the first place? Is the legal definition of hazardous waste presented above adequate? The Congressional Off ice of Technology Assessment (1 986) has suggested a broadened definition of hazardous waste as

all nonproduct hazardous outputs from an industrial operation into all environmental media, even though they may be within permitted or licensed limits. (emphasis added)

This definition suggests compliance beyond existing federal regulatory limits and addresses the problem of treatment procedures that simply transfer waste from one environmental medium to another, possibly less well regulated, medium without reducing the quantity or toxicity of the waste. Both of these points are part of the overall approach needed for effective waste minimization. We will return to this issue later as we review various strategies for achieving hazardous waste minimization.

Types and Sources of Hazardous Waste A few of the general waste streams and the specific types of hazardous waste substances you are likely to encounter as a site inspector are presented in Appendix A. If you are new to the field and are uncertain about your knowledge of this area, try the test questions for Appendix A.

18

Waste Minimization Through the next chapter we will enter the heart of this manual with a discussion of what hazardous waste minimization is and how it differs from waste treatment and disposal approaches.

WASTE MINIMIZATION: AN INTRODUCTION

CHAPTER 2

WHAT IS HAZARDOUS WASTE ?

SELF-TESTING EXERCISE Instructions: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter. Note that you are asked to explain your answers to some of the questions.

Questions: 2.1 Is the following statement true or false? (Explain your answer.)

Since RCRA regulations only define “solid waste” it has been necessary for EPA to provide definitions and regulations to cover liquid and gaseous wastes.

2.2 Complete the following EPA definitions:

A) is any discarded material not excluded.

B) “Discarded material” is material which has been abandoned, , or is

C) “Abandoned means disposed of, or I or accumulated, stored or treated prior to or in lieu of abandonment.

2.3 Complete the following RCRA definition of hazardous waste.

“a solid waste or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may

A)

2.4 Name two ways that California law clarifies and broadens the RCRA definition of hazardous waste?

2.5 Define criteria or characteristic wastes. Give two examples.

WHAT 1s HAZARDOUS WASTE? 19

2.6 Match the following hazards with the correct definitions:

Hazard Deflnltlon or Example

- Reactives A. Producing fires under various

- Ignitable, flammable or combustible

circumstances.

B. Likely to be somatic or reproductive

- Corrosives toxins, mutagens, carcinogens, or teratogens.

C. Include halogens and strongly acidic or alkaline (pH s 2 or 112.5) substances.

D. Undergo violent or high toxicity reactions under ambient conditions or with water.

- Toxics

2.7 Which article of California CCR, Tile 22, contains a list of regulated inorganic and organic persistent and bioaccumulative toxic substances?

2.8 How does the following definition differ from the federal and California statutory and regulatory definitions?

"Hazardous waste includes all nonproduct hazardous outputs from an industrial operation into all environmental media, even though they may be within permitted or licensed limits."

2.9 Does carbon dioxide, as a major greenhouse gas, fit any of the previously discussed definitions of hazardous waste? Which one(s)?

Optional Question: Do you think carbon dioxide emissions should be regulated to slow the buildup of greenhouse gases? Explain your answer.

Optional Question: It has been suggested that regulating carbon dioxide emissions would require an unprecedented degree of cooperation among regulatory and other administrative agencies and industry. Explain why this would be so.


H Present the Waste Management Hierarchy Define and discuss -Waste Minimization -Source Reduction -On and Offsite Recycling

Reduction according to SB 14 Discuss and provide examples of actions considered not to be Source

Chapter 3 WHAT IS WASTE MINIMIZATION?

THE WASTE MANAGEMENT HIERARCHY In 1976 the EPA established, through a policy statement, a hazardous waste management hierarchy. This hierarchy represents an attempt to build environmental protection into the industrial waste management process. It encourages industries to reduce their hazardous wastes at the source and to recycle rather than treat and/or dispose of wastes to land, air and water. This hierarchy of hazardous waste management is presented in Figures 3-1 and 3-2.

r\ Source Reduction I Minim:$:: 4 Onsite Recycling

I \ Offsite Recycling / \ Treatment /

Disposal v Figure 3-1. The Hazardous Waste Management Hierachy I

WASTE MINIMIZATION In examining Figure 3-1, you will note that the top three sections of the pyramid include Source Reduction at the top, Onsite Recycling next and Offsite Recycling in third order of preference. Source reduction and recycling taken together represent two approaches to Waste Mlnlmlzatlon.

(Another term, "waste reduction", is sometimes used interchangably with waste minimization. However, as generally used, waste reduction includes treatment along with source reduction and recycling. Unfortunately, as with most

WHAT IS WASTE MINIMIZATION? 21

definitions, the distinction between recycling and treatment blurs a bit when we consider that many methods of recycling require that the waste be purified- treated in some way before recycling. This will be discussed further in Chapter 7.)

Waste Mlnlmlzatlon effectively reduces the amount of hazardous material that permanently leaves the production process as waste. It was the intention of EPA, later reaffirmed in the 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA, that industry implement source reduction and recycling before resorting to treatment andlor disposal. However, until recently, this intent has not been widely implemented.

Waste Minimization contrasted with Waste Management

Source Reduction Recycling Treatment Secure StorageFieleas

Waste Management

Waste

~~

SOURCE REDUCTION Source reductlon is defined in the California Hazardous Waste Source Reduction and Management Review Act of 1989 (SB 14) as any of the fo1lowing:l

(A) any action that causes a net reduction In the generation of hazardous waste.

(B) any action taken before the hazardous waste is generated that results in a lessening of the properties which cause it to be classified as a hazardous waste. (Emphasis added.)

Source reduction, therefore, is pollution prevention. It reduces the toxicity and/or quantity of hazardous material at the source. In this way it is fundamentally different from the pollution management practices of recycling, treatment and disposal.

A few examples of source reduction are listed in Figure 3-2 and in Table 3-1. A detailed discussion of source reduction techniques is presented in Chapter 6.

1. See Appendix B for excerpts from SB 14 -Article 11.9, Chapter 6.5, Division 20 of Calif. Health & Safety Code. Regulations are being drafted at the time of this writing.

22 WASTE MlNIMIZATION: AN INTRODUCTlON

HAZARDOUS WASTE MANAGEMENT HIERARCHY

REDUCE OR ELIMINATE THE USE OF HAZARDOUS MATERIALS

MATERIALS SUBSTITUTION PRODUCT SUBSTITUTION PRODUCT REFORMULATION

REDUCE OR ELIMINATE THE GENERATION OF HAZARDOUS WASTES

PROCESS OR EQUIPMENT CHANGES IMPROVE PLANT OPERATIONS IN-PLANT RECYCLING

AIR EMISSIONS WATER DISCHARGES-

4 OFFSITE RECYCLING 1-• AIR EMISSIONS WATER DISCHARGES

ONSITE RECYCLING -

A’R E M I S s ’ o N s ~ ONSITE TREATMENT .-B WATER DISCHARGES I

OFFSITE TREATMENT AIR EMISSIONS WATER DISCHARGES- b

I HAZARDOUS WASTE RESIDUALS 3 RES1 DUALS REPOSITORY

Figure 3-2 In this illustration of the Hazardous Waste Management Hierarchy the flow of hazardous waste is shown by arrows

WHAT IS NOT SOURCE REDUCTION? Waste minimization and source reduction have been defined in various, often contradictory, ways in government and private publications. California’s SB 14 sharpens and delineates the meaning of source reduction by adding to the definition a list of actions that do not represent source reduction.

According to SB 14, source reduction does not include any of the following:

Actions taken after a hazardous waste is generated.

w Actions that merely concentrate the constituents of a hazardous waste to

Actions that dilute hazardous waste after generation to reduce its

reduce its volume.

hazardous characteristics.

WHAT 1s WASTE MINIMIZATION? 23

Actions that merely shift hazardous waste from one environmental medium to another environmental medium.

Actions taken after a hazardous waste is generated. This clearly excludes any form of treatment, such as:

Detoxification.

Incineration.

Thermal, chemical or biological decomposition.

Stabilization through solidification.

Embedding or encapsulation.

Recycling is not usually considered to be source reduction. If, however, residual hazardous material contained within an existing process or operation is fed back into the process then it is considered to be source reduction by the State of California (HSC 25244.14 (e)(2)(C)).

Actions that merely concentrate the constituents of a hazardous waste to reduce its volume. Volume reduction operations, if they simply reduce the total volume without reducing the toxicity of a waste, do not qualify as source reduction. For example, in reducing the amount of water (dewatering) in heavy metal sludge waste through pressure filtration and drying, the number of molecules of toxic heavy metals in the sludge in the first place have not been reduced. In fact, the concentration of the metals has been increased. Although dewatering is an important treatment method that reduces both the cost of handling and the capacity for migration of waste from the site of deposition it does not prevent waste generation or reduce the amount or toxicity of waste being generated.

Actions that dilute the hazardous waste after generation to reduce its hazardous characteristics. Dilution is the “flip side” of volume reduction. As with volume reduction, waste dilution constitutes treatment applied to the waste stream after generation. It does nothing to reduce the amount or hazard of the waste at its source of production.

Actions that merely shift hazardous waste from one environmental medium to another environmental medium. Many of the waste management, treatment and control practices used to date have simply collected pollutants and moved them from one environmental medium to another, sometimes less well regulated, one. Two examples illustrate:

1. Collection of pollutants from air and water via pollution control devices which are then legally disposed of in land disposal sites.

2. Transfer of volatile pollutants from surface impoundments, landfills, water treatment units, groundwater air stripping operations, etc., to the air through evaporation.

24

RECYCLING Recycling is the use, reuse or reclamation of a waste after it has been generated. Through recycling and reuse, hazardous “waste” is routed into a production process rather than being released to the environment as a waste.

WASTE MINIMIZATION: AN ZNTRODUCT‘ION

Under some conditions, recyclingheuse may be considered to be source reduction. For example, according to SB 14, "the return of materials or their components, for reuse within the existing processes or operations, so as to reduce, avoid, or eliminate the generation of hazardous waste", is considered source reduction.

Reclamation is usually considered to be a part of recycling because it recovers raw material for reuse. However, keep in mind that the processes used to reclaim useful materials from waste often generate hazardous wastes of their own. This is an example of the trade-offs that must be examined when assessing waste minimization options.

The recycling option is less preferable and should be resorted to after all feasible source reduction options have been explored and implemented. Onsite recycling has a higher priority than off site recycling because reducing transportation, storage and other handling of hazardous wastes reduces the risks to health and the environment.

More detailed discussion of techniques and strategies for both source reduction and recycling are presented in Chapters 6 and 7.

Why might business operators choose to set up waste minimization programs in their facilities? What would they gain by reducing the amount and toxicity of the hazardous waste they generate? Incentives for industry participation in waste minimization programs are discussed in the next chapter.

Table 3-1. Source Reduction and Recycling, Summarized

Eliminates or reduces the use of hazardous materials and/or the generation of hazardous waste at the point of generation.

Examples:

SOURCE REDUCTION

w Improvements in operating practices w Changes in process and equipment

(may include reuse of material within existing process)

w Changes in input material w Changes in product

RECYCLING Reduces the amount of virgin feedstock that must be produced and/or purchased by reusing or reclaiming hazardous wastes being generated. Recycling may be done onsite or offsite. Onsite is preferable.

Examples:

w Reuse of low specification raw material in lower specification job

w Reclamation and reuse on or offsite w Selling or leasing to recycler

W A T IS WASTE MINIMIZATION? 25

26 WASTE MINIMIZATION: AN INTRODUCIYON

CHAPTER 3

WHAT IS WASTE MINIMIZATION?

SELF-TESTING EXERCISE instructions: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter. Note that you are asked to explain your answers to some of the questions.

Questions:

3.1

3.2

3.3

List the elements of the Hazardous Waste Management Hierarchy and rank them in the order that affords the greatest-to-the-least environmental protection.

Draw a circle around the elements in your list that constitute waste minimization.

Which of the following is the correct sequence in the Hazardous Waste Management Hierarchy (Assume that left-to-right indicates decreasing desirability from an environmental protection point of view.)? (Explain your answer.)

A. Recycling->Treatment->Disposai->Source Reduction B. Treatment-->Disposal->Source Reduction->Recycling C. Source Reduction->Recycling->Disposal->Treatment D. Source Reduction->Treatment->Recycling->Disposal E. None of the above is correct.

3.4 Which pair of the following terms constitutes waste minimization?

A. Source reduction and treatment

B. Source reduction and recycling

C. Source reduction and disposal

D. Source reduction and treatment


3.5 Write a definition of source reduction which you feel would be most easily understood by a lay person.

W A T IS WASTE MRJIMEATION? 27

3.6 Identify the chief difference between source reduction and the three main “end-of-pipe’’ approaches to hazardous waste management.

3.6 List the four actions identified in SB14 as not constituting source reduction. Give a specific example from industry for each.

3.7 Distinguish between source reduction and recycling.

3.8 Explain why source reduction provides more effective environmental protection than recycling does.

3.9 Indicate the procedures in the following list that are not source reduction explain why they are not.

Incineration in a rotary kiln.

Dewatering to levels acceptable for landfilling.

Recycling.

Encapsulation.

Dilution to levels acceptable for sewer discharge.

Installation of an ion exchange system for the recovery of metals.

3.10 Under what specific conditions may recyclingheuse be considered to be source reduction?

3.11 List two industrial hazardous wastes that are commonly reclaimed and treated for reuse.

3.12 Explain why onsite recycling is preferable to offsite recycling, from an environmental protection as well as a business perspective.

28 WASTE MlNlMlZATlON: AN INTRODUCTION

Discuss the following five incentives that may encourage industry to reduce hazardous waste generation through waste minimization:

w Economic w Regulatory w Public image w Healthy environment w Product quality

Chapter 4 INCENTIVES FOR INDUSTRY PARTICIPATION IN WASTE MINIMIZATION

All generators of waste, whether small, local businesses or mutti-national, industrial conglomerates, have powerful incentives to reduce the volume or hazardous nature of their wastes. These incentives may be economic, regulatory, or a variety of other incentives either unique to the individual firm or common to business in general.

ECONOMIC INCENTIVES Economic incentives reward those who reduce their wastes. These incentives can be either real savings, which can be clearly quantified on a balance sheet, or estimated savings, which can be quantified based on avoiding potential future costs. In either event, the overall economic incentive is the potential for increased competitive advantage through lower operating and production costs. Economic incentives apply to the generation of both nonhazardous and hazardous wastes.

Such incentives can be grouped into four basic categories:

w Reduced waste management costs. w Improved operations.

a Reduced liability risks.

w Increased competitive advantage.

Reduced Waste Management Costs The most obvious and quantifiable economic incentive is the reduced waste management costs that result simply from having less waste to manage. The Congressional Budget Office has estimated that the annual cost to industry of hazardous waste management was between $4.2 and $5.8 billion in 1983 and will be between $8.4 and $11.2 billion by 1990 (Bergeson, 1988).

INCENTIVES FOR INDUSTRY PARTICIPATlON IN W44STE MINIMIZATION 29

Plenty of direct waste management cost savings are available through waste minimization. Depending on the individual site and its operations, these savings might be achieved through one or more of the following:

Lower onsite handling costs.

Less waste storage area (hence, more available production area).

Lower offsite transportation and disposal costs.

m Lower paperwork and record-keeping costs.

Possible shift from treatment, storage, and disposal facility (TSD) status to non-TSD status, with associated lower costs.

Reduced waste end-tax obligations.

One company has documented $390 million in savings as a result of waste minimization efforts through 1986 (Bringer, 1987).

In New York State, each hazardous waste generator’s waste end-tax obligations can be reduced by as much as $40,000 per year, depending on the amount of hazardous waste generated (Ginger, 1987). In essence, generators can then “double-dip’’ their savings-not only are savings achieved through reduced waste management costs, but taxes will be proportionally less too.

Examples of savings within specific industries are presented in Chapter 7, “Waste Minimization Success Stories”.

Improved Operations As wastes are reduced, the proportion of raw materials being converted to desired end-products increases. Thus, waste minimization leads directly to improved operations through yield improvements and increased production capacity. The economic savings obtained through even simple efforts can be substantial, oftentimes resulting in capital investment recovery in only a few months (Rice, 1987). These savings can be even more impressive when calculated on a long-term basis, which includes minimizing future liability costs. Annual cost reductions can be 30 to 50 percent.

Reduced Liability Risks Reducing the amount and toxicity of wastes being handled onsite also reduces the likelihood that violations of hazardous waste laws will occur. Recently, civil and criminal penalties are being more vigorously pursued. Criminal penalties are much more severe for hazardous control law violations than other regulatory crimes. In an increasing number of cases, the corporate veil has been parted and individual management personnel have been prosecuted. Some convictions relating to the mismanagement of hazardous wastes have occured without a showing of criminal intent leading to the violation (Dufour).

Reducing future liabilities and risks is, for many industries, the greatest long-term economic incentive for waste minimization. Involvement in a hazardous waste site cleanup can be enormously costly in time, money, morale, and erosion of public trust. “Cradle-to-grave’’ responsibility for generated wastes can weigh heavily on the shoulders of both large and small businesses. There is little security to be found through liability insurance, since policies have become

30 WASTE MRJIMIZAl’lON: AN INTROVUCTION

prohibitively expensive or unavailable for certain hazardous waste generators.

Another source of liability risk is worker exposure to hazardous materials, including waste. Reducing the amount of hazardous material that is handled and the amount or toxicity of waste generated can have thc dual benefi of improving worker safety and morale and of reducing the risk of lawsuits attendant with injury.

While hard to quantify in specific economic terms, "ruleof-thumb" estimates place liability savings on the order of $1 00 to $300 per ton, depending on a variety of factors (McClean, 1987).

Least

Liability Waste Minimization Category

Inventory Management I Production-process Modification

I I In-process Recovery and Re-use 1 I I I

I Onsite Recovery and Reuse I I , i

Interindustry Exchange i ' 1 1

Greatest I Offsite Recovery I

Figure 4-1 Waste Minimization Liability Hierarchy. (adapted from Hunt & Schecte6 1988)

When relative liability risks associated with various approaches to hazardous waste management are compared, a hierarchy parallel to the waste management hierarchy presented in Chapter 3 emerges. The greatest liability is associated with treatment and disposal; the second greatest is with recycling and resource recovery; and the least is with source reduction (Wyman & Register, 1 989).

Increased Competitive Advantage All these economic incentives can combine into a single, powerful result that is universally understood in business: increased competitive advantage. By reducing costs, increasing productivity, and reducing long-term liabilities, organizations have the ability, in some cases, to capture market share, increase revenues, and increase profitability. As stated recently:

The company that has an economically and environmentally acceptable plan for waste management may well be the low-cost producer, and hold the key to the success or failure of a business (Hollod and McCartney, 1988).

REGULATORY INCENTIVES Compliance with federal and State regulatory requirements is a key incentive for waste minimization.

Land Disposal Ban The land disposal ban, with its prohibitions on the land disposal of untreated hazardous waste, is a powerful incentive to reducing the generation of the hazardous waste in the first place.

INCElVl7VES FOR INDUSTRY PARTICIPATION IN M S T E MINIMIZATION 31

Section 224(a) of HSWA sets forth specific requirements for generators:

m Manifest certifications.

Permit certifications.

Reporting of waste minimization activity.

In addition, mandatory federal and State survey questionnaires often inquire about waste minimization activities. While the primary effort has been toward solid waste reduction, other efforts directed toward other environmental media have been increasing.

Activity Reporting California‘s 1989 Hazardous Waste Source Reduction and Management Review Act (SB 14) requires that generators who generate more than 12,000 kg of hazardous waste or 12 kg of extremely hazardous waste per calendar year prepare a hazardous waste reduction evaluation review and plan and a hazardous waste management performance report & summary, which document hazardous material management approaches implemented by the generator. Specific regulations and report forms are being developed at the time of this writing. See Appendix B for wording of the statute.

All hazardous waste generators are required, as part of their biennial EPA report or applicable state report, to describe their waste minimization activities during the subject period. This would include any efforts to reduce the volume and toxicii of the wastes generated, comparing actual results to previous years’ wastes.

Reporting waste minimization activity is also required for various external federal and State surveys and questionnaires. EPA’s recent Treatment, Storage, Disposal, and Recycling (TSDR) and Generators surveys posed a series of questions regarding waste minimization; similar questions are asked in various State and industrial association surveys.

Manif est Certifications Each Uniform Hazardous Waste Manifest now requires generators to certify that they have “...a program in place to reduce the volume or quantity and toxicity of waste to the degree determined by the generator to be economically practicable ...” A false certification is a direct violation of RCRA, possibly leading to civil and criminal proceedings against the person making the false Certification.

32

Permit Certifications Each generator obtaining a RCRA permit for the treatment, storage, or disposal of hazardous waste must certify, as a permit condition requirement, that he has a waste minimization program in place. A false certification could lead to a violation and penalty and/or be a factor in potential revocation of the subject permit.

WASTE MNIMIZATION: AN INTRODUCTION

OTHER INCENTIVES Economic incentives are by themselves compelling reasons for manufacturers to reduce their wastes. However, there are additional incentives:

I Positive public image.

I Healthy environment.

Product quality improvement.

Government assistance programs.

Policy adherence.

These incentives are more difficult to quantify than either regulatory or economic incentives, though no one should doubt or underestimate their value.

Positive Public Image Waste minimization is very attractive to the public. Everyone supports it and any effort involving it projects a positive image of an organization’s concern for the community and the environment. Waste minimization provides industrial firms with the unique opportunity to: 1) meet regulatory requirements, 2) realize economic benefits, and 3) obtain a positive public image-all at the same time, and for the same effort.

Notes on waste minimization in an organization’s annual report or quotes in newspapers, magazines, and journals all enhance the public’s perception of the company as a good corporate citizen.

As with other programs, increased personnel interaction and involvement are important incentives for companies to participate in waste minimization activities. Waste minimization projects can give employees a sense of individual contribution not only to the company but to society and their community. This, in turn, improves employee morale.

Healthy Environment The quality of life, for all of us, depends on a healthy and sustainable environment. Preventing the deterioration of the environment is a responsibility shared by both producers and consumers.

Product Quality Improvement Improving product quality can be a natural outgrowth of waste minimization evaluation. Any time a process or unit is investigated closely in a new manner, by a variety of people, opportunities emerge for improvements that might not otherwise have been discovered. In one case, waste minimization efforts created a new process technology and brought new life to a plant that otherwise might have been forced to close (Kaplan, 1982).

Government Assistance Programs Several forms of assistance exist and more are under development to help industries adopt waste minimization practices. The economic incentive programs include such things as grants, loans, and tax and fee incentives. You may be able to assist businesses in contacting the California DHS, the

INCENTIVES FOR INDUSTRY PARTICIPA77ON IN WASTE MINIMIZATION 33

34

Environmental Protection Agency, the California Pollution Control Financing Authority, the Small Business Administration and other agencies for further information.

Where do you, as a hazardous materials inspector, fit into the waste minimization adoption process? The next chapter discusses various aspects of the roles that inspectors can and already do play in encouraging the use of waste minimization by industry.

INCENTIVES FOR RJDUSTRY PARTICIPATION IN WASTE MINIMIZATION

CHAPTER 4 INCENTIVES FOR INDUSTRY PARTICIPATION IN WASTE MINIMIZATION


Questions: 4.1 The four basic categories of economic incentives discussed in this

chapter were: (Explain your choice.)

A. Improved operations; reduced liability risks; reduced waste management costs; increased competitive advantage

6. Improved operations; reduced liability risks; improved yield & production capacity; increased competitive advantage

C. Improved operations; reduced liability risks; reduced waste management costs; reduced waste-end tax obligations

D. Improved operations; positive public image; reduced liability risks; reduced waste management costs


4.2 List at least five types of cost savings that can be achieved through waste minimization.

4.3 Explain how waste minimization can lead to improvements in yield and to increased production capacity.

INCENTIVES FOR INDUSTRY PARTIclPA770N IN M S T E MlNIMIZATION 35

4.4 Based on your knowledge and experience as a generator inspector, identify the types of liability risks that hazardous waste generators face and indicate, for each, how waste minimization might reduce that liability.

4.5 List four regulatory incentives that encourage waste minimization. Which, do you believe, has provided or will provide the greatest incentive for adoption of waste minimization programs.

4.6 Discuss ways in which you, as a generator inspector, are well-suited -in knowledge, experience, and perspective-to encourage increased industry participation in waste minimization efforts.

36 WASTE MNlMIZATION: AN INTRODUCTION

Discuss ways in which involvement in waste minimization programs may change the relationship of the hazardous materials inspector to industry.

H Review ways in which the experienced inspector is already prepared to work cooperatively with industry in developing waste minimization programs.

H Identify additional waste minimization information and approaches needed to enhance the inspector’s effectiveness.

Discuss possible problems which might arise in the course of doing waste minimization work with industry.

W Discuss ways in which involvement in waste minimization programs may change the relationship of the inspectors to their own or other regulatory agencies.

W Discuss the role of inspectors in enhancing effective waste minimization programs within their own departments and in other concerned agencies.

Chapter 5 WHAT IS THE INSPECTOR’S ROLE IN WASTE MINIMIZATION?

INTRODUCTION The effort to minimize hazardous waste requires cooperation between regulatory agencies and the facilities that need to accomplish hazardous waste minimization. The inspector, as an agency representative, can be a valuable resource to the hazardous waste generator seeking to minimize wastes within a complex regulatory framework.

INCENTIVES Waste minimization is a winning proposition for hazardous waste generators, for regulators of hazardous materials and waste and for the community at large. Minimization of hazardous wastes results in a reduced need for disposal facilities, a lessened risk to the community from hazardous waste releases and consenration of natural resources. The hazardous materials inspector can make a valuable contribution to this effort in his or her regular inspection activities and by acting as a resource and support person for those facilities working on waste minimization programs.

As a result of inspectors becoming more involved in the onsite development of waste minimization programs, their relationships with industry may undergo some change. It is very important that you, as an inspector, give some thought to both the problems and opportunities that might arise.

WHAT IS THE WSPECTOR 5 ROLE IN WASTE MINIMIZATION? 37

RELATIONSHIP OF INSPECTOR TO FACILITY Regulator, Consultant or Both Would assisting a facility in the establishment and implementation of a waste minimization program constitute too great a shift in the role of inspector, as regulator, toward that of consultant to the industry? The following discussion suggests that consultation/advisement is not a new activity for inspectors and that individual discretion and departmental guidelines can help to ensure a balanced approach.

Experience as Both Regulator and Advisor Acting as a consultant to the regulated community is nothing new to the experienced hazardous materials inspector. Simply by virtue of the number of facilities examined, the inspector becomes acquainted with many different ways in which facilities attempt to comply with regulations, conserve costs, and minimize liability. Each inspector receives a unique and continuous on-the-job training experience due to the nature and complexity of the types of facilities and processes he or she has investigated. A particularly challenging experience at one facility may lead to thorough research and investigation of an overall industry. Therefore, it is to be expected that each of you will have different strengths and weaknesses, based on your level of training and experience.

The more technical expertise an inspector can develop the better the inspector may be able to assist industry in adopting waste minimzation techniques and strategies. However, as you will see in Chapter 6, many basic aspects of waste minimization are common to a variety of industries and processes and require little specific technical knowledge.

Potential Conflicts Inspectors often juggle the roles of advisorkonsultant and regulator. In most jurisdictions, the inspector has a primary duty to protect public health and the environment, and may be the person primarily responsible for enforcing hazardous materials regulations and investigating environmental crime. Often, especially for the small company, the inspector and the hazardous waste hauler are the only sources of information on hazardous materials regulations. The potential for differences in interpretation arises when the inspector and waste hauler, one having responsibility to check for compliance with laws and regulations and the other having an economic interest in the company’s generation of hazardous waste, address the various approaches to management of hazardous materials.

A Cautionary Note Other potential problems arise when an inspector gives advice to a business. As an inspector, you must be very careful not to step beyond the boundaries of your expertise and authority. And because of the potential for advisor/regulator conflict, regulatory requirements must be clearly distinguished from “helpful advice”. A well articulated department policy and standardization of waste audit or waste minimization assessment procedures can help prevent misunderstandings.


Role of the Inspector in the Adoption of a Waste Minimization Program In spite of the potential problems arising when an inspector addresses waste minimization, there is much to be gained by the facility and the regulatory agency through this cooperative effort. Waste minimization is a win-win situation for regulators and generators alike with reduced regulation, disposal costs, and liability for the facility and reduced risk to public health and the environment.

Individual agencies have different policies for waste minimization activities, but this manual assumes a definite distinction between the responsibilities of the inspector and those of the generator. The legal responsibility for minimizing wastes belongs to the generator of the waste. The inspector can encourage and facilitate waste minimization through actions that serve the generator as well as the regulatory agency. As with other inspection activities, the extent of the inspector’s role in waste minimization efforts will vary with the interests and needs of the facility and the number of other competing responsibilities. The basics of facilitating waste minimization are all familiar to inspectors. They consist of:

providing information

performing inspections

documenting

w interacting with other agencies

Information The inspector and his or her department have the ability to provide critical information to a facility regarding waste minimization alternatives. In fact, the inspector may be the individual who initially motivates a company to explore the possibilities of waste minimization. This happens quite naturally during the process of sharing success stories of similar companies who have minimized waste. But the inspector also serves as a check on the legality and possible restrictions on proposed waste minimization alternatives. In view of the potential conflicts mentioned earlier, however, an important way in which an inspector can be valuable to a company is to extend the company’s access to waste minimization information beyond his or her department and beyond the waste hauler.

Access to the waste minimizaton information network may be increased through industry and regulatory contacts, educational opportunities (seminars, etc.), and published information-information specific handouts, fact sheets and government publications.

Inspection There are some common problems in hazardous materials management and operations, such as poor waste inventory management, careless handling and storage of materials, comingling of waste streams and inadequate employee education, training and communication, that have some simple solutions. Inspectors can identify these problems and make recommendations. Taking action to solve these management problems also achieves the goals of waste minimization. These specific waste minimization steps and others will be reviewed in more detail in the next chapter.

WHAT IS THE INSPECTOR ‘S ROLE IN WASTE MINIMIZATION? 39

In some cases, unnecessary generation of waste is linked to careless management practices, which may constitute violations of law. Consistent enforcement of regulations can be a major Incentive to reduce hazardous wastes through improved management and operations. A facility that is required to dispose of contaminated soil, mixed wastes, and “mystery” (unknown) wastes is more likely to appreciate the economic incentives for proper hazardous waste management and waste minimization. Lawful management of hazardous materlals and hazardous wastes Is the first step In waste minimization and may represent quite an achievement for facilities with consistent violations. Waste minimization may be all that is necessary for some small companies with simple waste streams to come into compliance with hazardous waste laws.

As you have seen in Chapter 4 there are economic, regulatory and public relations benefits to be gained by businesses that apply waste minimization to their operations. It may, therefore, be appropriate for the inspector to bring waste minimization problems and possibilities to the attention of a level of management within the company concerned about business management and company liability.

It is likely that the inspection will be conducted in the presence of a plant manager or operator who is most familiar with hazardous materials inventory management, the processes that use hazardous materials and hazardous waste handling, storage and disposal. It may be beneficial, in addition, to arrange to have the business manager accompany you in order to discuss the legal requirements, alternative waste management possibilities and company hazardous materials management policy. This not only allows you to educate a manager unfamiliar with hazardous materiahaste management, but provides an opportunity to open the lines of communication between the business manager and the plant manager in the setting of the facility. You can also learn valuable information about costs associated with hazardous wastes and company perceptions of barriers to waste minimization.

RELATIONSHIP OF INSPECTOR TO REGULATORY AGENCIES

Acquiring information for departmental programs As liaison in the field, the inspector plays a key role in maintaining an agency’s awareness of its regulated industries’ activities. The documentation of field situations that an inspector develops and shares with other agency personnel can influence the department’s perceptions of the problems, needs and concerns of industry as well as the perceptions of the public. In this way documentation can help to shape department policy.

Interaction with other concerned agencies Since various agencies (air quality, sewering, regional water quality control boards, DHS) regulate hazardous waste generating facilities, waste minimization activities in one jurisdiction may affect programs under other jurisdictions. It is important that agency representatives remember that the goal of waste minimization is to accomplish an overall reduction in the waste generated, not


simply a transfer from one environmental medium to another. As a hazardous materials inspector, you can help a facility achieve waste minimization within the regulatory constrictions and requirements of your own and other agencies by being alert to opportunities for interagency cooperation and by maintaining referral contacts with other agencies.

AWARENESS OF BARRIERS FACING INDUSTRY The movement of industry toward waste minimization is not without its obstacles. The recognition of the hazards, liabilities and costs associated with hazardous waste generation is relatively new to the industrial community. In some ways, the barriers to waste minimization are similar to those that delay other major changes in business practices. These barriers and other disincentives to business participation in waste minimization programs are discussed in more detail in Chapter 9. They include significant limitations on available financial resources, information and technical capabilities. Waste minimization can be further limited by the "end-of-pipe" outlook, which persists in many industries and regulatory agencies. The inspector is in a good position to help a facility's personnel to overcome the "lack of information barrier" as well as their reluctance to examine unfamiliar alternative approaches.

Another service the inspector can provide to the generator and the regulatory agency is to become aware of the barriers which generators are facing and bringing them to the attention of the appropriate people. Local agency personnel may be able to offer some assistance in overcoming the barrier or in seeking the help of state and federal agencies.

The role which the inspector plays in a facility's conduct of a waste minimization assessment is discussed in detail in the second manual of this series.

IN SUMMARY An experienced and well trained hazardous materials inspector will already have most of the knowledge and skills needed to assist facilities with development of waste minimization programs. By supplementing these with 1) a thorough knowledge of the basic elements and techniques of waste minimization and 2) a familiarity with information about its advantages as illustrated by various success stories, an inspector can help a facility's personnel to overcome the "lack of information barrier" as well as their reluctance to examine unfamiliar alternative approaches. The onsite plant inspection provides opportunities to help educate plant personnel at all levels about the importance and benefits of pollution prevention through waste minimization.

The increased involvement in cooperative waste minimization projects with industry brings with it both significant opportunities and the potential for confusion regarding traditional roles of regulator and advisor/consultant. A well articulated department poky and standardization of waste audithaste minimization assessment procedures, together with the use of common sense in staying within the bounds of your own expertise, can help prevent misunderstandings and lawsuits.

WHATIS THE JNSPECTOR'S ROLE IN WASTE MINIMIZATION? 41

What are some of the general categories and specific examples of source reduction techniques and strategies that can be adopted to prevent or reduce the quantities or toxicity of hazardous wastes generated? The next chapter, “Source Reduction Strategies and Examples”, presents and discusses these.

42 WASTE MlNlMIZATlON: AN INTRODUCTION

CHAPTER 5

WHAT IS THE INSPECTOR’S ROLE IN WASTE MINIMIZATION?

SELF-TESTING EXERCISE InstWctiOns: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter. Note that you are asked to explain your answers to some of the questions.

Questions:

5.1

5.2

5.3

5.4

5.5

Is it likely that the relationship between you and the facilities you inspect will be different when you are emphasizing source reduction and recycling alternatives in addition to your traditional regulatory compliance emphasis?

If you answered, “Yes”, then explain briefly.

If you answered, “NO”, then explain why not.

Describe at least three specific ways that the experienced generator inspector is already adequately prepared to work with industry in developing waste minimization programs.

Present three types of waste minimization-specific information and approaches that would enhance a generator inspector’s effectiveness in assisting a facility to adopt a waste minimization program.

A network of information on waste minimization exists, in addition to the local department and the contracted waste hauler. List three major sources from which this information would be available.

Some common problems in hazardous materials management and operations are said to have simple solutions and would constitute steps toward effective waste minimization.

Identify four of these.

WHAT IS THE INSPECTOR’S ROLE IN WASTE MlNIh4IZATION? 43

5.6 “Lawful management of hazardous materials and hazardous waste is the first step in waste minimization.”

Explain this statement and give examples.

5.7 It has been suggested that an inspector include both the plant manager and the business manager in a plant inspection tour, especially when discussing waste minimization opportunities.

What are the advantages of this practice?

Would you suggest that any other facility personnel be involved?

Who? Why? Why not?

5.8 Discuss the importance of inspection documentation in increasing understanding and support for waste minimization programs.

5.9 Explain why il is important to have ongoing communication with other regulatory agencies regarding industry efforts to institute waste minimization practices.

5.10 In your opinion, with respect to waste minimization, is there an inherent conflict for the inspector in his dual role as regulatorkonsultant? Explain your answer.

5.11 Discuss what can be done to minimize any confusion or misunderstanding about the regulator/consultant role of the generator inspector who is advising a business on waste minimization.


Describe the following approaches to source reduction and provide examples:

Good Operating Practices

Changes in Technology

Changes in Input or Feedstock Materials

Product Changes

Chapter 6 SOURCE REDUCTION STRATEGIES AND EXAMPLES As indicated previously, source reduction is pollution prevention in contrast to practices that manage hazardous waste after it has been generated. As such,

1 Waste Minimization Techniques

Onsite & Offsite

Figure 6-1. Waste Minimization Techniques. Dashed lines indmte lack of concensus on the status of energy recovery.

source reduction requires a fundamentally different approach. Successful source reduction depends partly on technological changes, but also requires changes in altitude and perspective. Hazardous waste is seen as a more significant liability than in the past. Efficiency gets a second look as a source of cost savings. Procurement practices and scheduling of processes deserve re-evaluation. Greater involvement of employees becomes essential. Regulatory agencies (including flsld inspectors)

SOURCE REDUCTION STRATEGIES AND EXAMPLES 45

become partners, assisting industries in achieving the common objectives of decreasing the amount and toxicity of waste generated.

A note of caution. Inspectors should bear in mind that although some of the changes described here can be made with relative ease, many of them involve overcoming formidable obstacles and require long-term planning (See Chapter 8 “Barriers to Effective Waste Minimization”). In addition, many of the strategies examined involve “trade-offs” , some of which would offer only slight or no benefit toward overall pollution prevention. Under these circumstances it would be preferable to leave a process unchanged.

Source Reduction

Source reduction techniques vary greatly from one industry to another, many being quite process-specific. However, there are some elements common to all. Approaches to source reduction in our discussion will be grouped in four major categories which follow, in most cases, the techniques presented in Figure 6-1. Please refer to this figure as you read through the following discussion.

Good Operating Practices

m Changes in Technology

Changes In Input or Feedstock Materials

m Changes in Product

f f .i ...I i

Good operating practices include many procedural changes that can be implemented in many areas of plant operation. Many effective operating practices can be implemented at low cost giving a good return on the investment in a relatively short time. The following specific aspects of good operating practices will be

Waste management cost-accounting

w Inventory management

w Procedural scheduling

w Material handling improvements and loss prevention

Waste stream segregation

Personnel education, communication & involvement

Waste management cost-accounting is especially important for dealing with major hazardous waste streams and should be started early in the process. Meaningful process review and evaluation will be impossible without this

46 WASTE MNIMIZATION: AN INTRODUCTION

information. Often the costs of generating hazardous wastes are unknown to facility managers. Complete and accurate record keeping should be instituted to delineate all waste management costs including fees, storage, treatment, transportation, disposal, trackin management overhead, insurance, energy, and raw material expenses.

The rates of generation of existing hazardous wastes should also be documented.

Baseline assessment information may already be available in analyses done to meet requirements for Tile 22, RCRA, SARA Ill, 313 (Form R), etc. In any case, beginning Sept. 1991 , facilities generating more than 12,000 kg of hazardous waste or 12 kg of extremely hazardous waste per year will be compiling such data for reports required under SB 14.

Inventory management: A business may benefit from developing a review procedure for identifying incoming hazardous materials. The availability of nonhazardous alternative materials should be explored with suppliers.

Purchasing only the required amount of material needed for specific jobs and time periods can reduce waste. Apparent cost savings from buying hazardous materials in bulk can be deceiving if handling and disposal costs are not considered. Unused hazardous materials may represent a significant liability. When they no longer meet specifications because of prolonged storage or through contamination, they become hazardous waste, and their handling and disposal costs must be added to their original purchase price.

Potential new product lines should also be reviewed with respect to their potential for increasing the use of hazardous materials.

Procedural scheduling: "Just-in-time" manufacturing is an example of procedural or production scheduling, which has been extensively field tested by large industries such as 3M. Raw materials are delivered to the plant a short time before they are to be used. In this way many problems associated with storage and product line changes are minimized. For example, parts sitting exposed to the elements for long periods of time require more cleaning-often with hazardous solvents.

In batch production operations the amount of cleaning waste generated is directly related to the frequency of cleaning. Coordinating scheduled equipment usage to reduce the need for clean-out or wash-down between batches can reduce the amount of hazardous waste generated.

Material handling improvements and loss prevention ("Good housekeeping"): Many immediate and direct reductions in waste and costs can be realized through compliance with existing hazardous material and hazardous waste management regulations.

Often more efficiency and care can be exercised in the handling of hazardous

NSITE I OFFSITE

SOURCE REDUCTION STRATEGES AND EXAMPLES 47

material and waste. With your knowledge of and experience with the basic rules and procedures for handling hazardous materials, you can be of great assistance with this approach to source reduction. You may wish to remind plant personnel of preventive measures, such as:

I Training employees in the operation, capacity, and capabilities of each kind

I Providing for regular monitoring of storage areas.

I Allowing adequate, clear space between rows of drums so that each

I Stacking containers in a way that minimizes the chance of tipping, tearing,

I Raising drums off the floor to prevent corrosion through spills or concrete

I Maintaining adequate distance between different chemicals to prevent

I Keeping containers closed except when material is being removed.

of transfer equipment (forklifts, dollies, conveyers, etc.).

container can be visually inspected for corrosion and leaks.

puncturing, or breaking.

“sweating”.

cross-contamination or chemical reactions in case of spills.

Providing funnels and other transfer equipment which reduces loss of material during transfer.

I Providing adequate lighting in storage areas.

Mantaining a clean, even surface in areas trafficked by personnel and equipment.

Curbing and diking storage and process areas where hazardous substances and/or wastes are present.

I Using containers appropriate to the job at hand-large containers (tote bins or super sacks) in lieu of 55-gallon drums. Unless properly cleaned and recycled, drums may have to be disposed of as hazardous waste. These larger containers are often no less portable than the smaller and may be reusable. Many are equipped for top and/or bottom discharge, cleaning access, and easy transporting.

Loss of hazardous material due to equipment failure can also be reduced by a strict and thorough maintenance program that stresses corrective and preventive maintenance.

Waste stream segregation: Keeping nonhazardous and hazardous waste separate decreases costs for disposal since a mixed stream must be managed as hazardous. For example, hosing down or sweeping ordinary “household” dust and debris into a sump designed to collect hazardous waste wash-down might be avoided by vacuuming the nonhazardous dust. This decrease the total volume of hazardous waste generated.

Separation of waste streams also increases opportunities for recycling and reuse. In working with solvents, it is essential to segregate solvents to retain their recyclability. Some recyclers cannot accept organic solvents that are contaminated with even minute amounts of chlorinated solvents.

48

In addition, the quality of chlorinated solvents will deteriorate rapidly, forming

WASTE MlNIMIZATION: AN INTRODUCTION

hydrochloric acid, if they have been contaminated with water or other solvents. As little as 0.1% of 1’1 ,1-TCA mixed into a tank of TCE can cause an acid condition.

Personnel education and communication: Waste minimization programs can vary from simple pollution awareness programs, where managers and employees are asked to identify ways of reducing the generation of waste, to complex programs that are independently staffed by corporate personnel and that extend to worldwide operations. In either case employees play a vital role.

An effective campaign to reduce the amount of waste generated must incorporate an effective employee training program that teaches employees how to detect spills, leaks, and releases of material. Process operators and maintenance personnel should be given additional training that stresses waste minimization methods. Incentive programs that reward employees for waste reduction ideas have been particularly successful.

Since many of the source reduction options require coordination and cooperation of employees at various points in the overall operation of the plant, information about the benefits to be derived from reducing hazardous material being handled and hazardous waste being generated needs to be communicated to all employees. This includes people in planning, procurement, production, engineering, environmental affairs, maintenance, and so on. As many of these people as possible should be involved in the search for waste minimization opportunities.

Source reduction strategies involving changes in technology tend to be industry and process specific and require a good understanding of the details of a facility’s operation. A few examples from specific industrial processes are provided below. You are encouraged to examine some of the sources listed in the bibliography for further illustrations and details. Categories of technological changes to achieve source reduction include:

Process changes

m Equipment, piping or layout changes

Additional automation

Process changes: Developing an alternate process that generates less waste without changing product specifications is part of the challenge industry faces. The starting point here is a careful review of the production process, from delivery area through to final product storage, for ways to improve efficiency. Following this review an examination of specific steps within the process may be conducted to identify ways to reduce the quantity or toxicity of materials being generated.

For example, in parts cleaning operations, the following series of questions might be asked:

Is cleaning necessary?

How much cleaning is needed?


Can the need to be cleaned be diminished in some way by reducing time stored before cleaning?

-by pre-rinsing in a nontoxic bath?

-by pre-wiping?

-by storing parts in a more protective environment?

-by replacing protective oil coatings with protective peel coatings?

If cleaning or surface coat removal is necessary, what are the available alternative methods or materials? Mechanical brushing? Sandblasting (paint stripping)? Plastic bead blasting (paint stripping)? Agitation? Sonication? Nonhalogenated or aqueous solvents?

Specific examples of other process changes are discussed below.

Countercurrent rinsing, which has been used successfully in the metal plating industries to reduce the amount of water used (and contaminated)

Minor process modifications can sometimes reduce the evaporative loss of volatiles -for example, keeping solvent tanks covered when not in use, using surfactant foam or floating plastic balls on the surface of the liquid.

decreasing inefficiency. It may be worthwhile to field test equipment to determine whether it is being operated at its optimal efficiency with respect to feed rate, temperature, pressure and other parameters.

adjusted relatively easily. For example, drag-out (the amount of solution remaining on a workpiece) can be reduced by slowing the withdrawal of the workpiece from the solution bath; this lessens solution carryover and contaminated water and sludge generation. In another example, the concentration of potassium cyanide in a cyanide copper-plating bath operation can be reduced, thereby reducing the amount of cyanide added and minimizing the amount of cyanide drag-out.

reuse within the existing processes or operations -_ is a form of source reduction being used increasingly by industry. Examples include reuse of baghouse dusts and recirculation and reuse of rinse water.

by UP to 90%.

Operational adjustments of existing equipment may reduce waste by

In the metal plating industry, cleaning and plating operations can be

In-process recycling --the return of materials or their components, for

See Chapter 9, “Success Stories” and the references for further examples.

Equipment, piping or layout changes: Replacement or modification of equipment that is operating inefficiently and/or generating excessive amounts of waste may be an option. For example, a vapor degreaser that uses a chlorinated solvent may be replaced with an alkaline degreaser in some operations.

Equipment may be modified to reduce waste generated without changing the process. More efficient equipment may reduce the number of rejected or off - specification products that have to be reworked or disposed of. Attaching covers and spillboards to vats of volatile liquids can reduce losses and worker exposure. Mechanical wipers may be used to wipe out mixing vats or pipes emptied


between operations. This simple procedure may significantly reduce hazardous waste generation.

Pipes and valves can be modified to deliver materials more effectively and with less loss through leakage or overfill. For example:

w Continuous processing operations contain a significant number of pumps. Using double mechanical seals on pumps can lower the chances of spillage and subsequent waste cleanup.

Heat exchangers, common equipment in nearly all plants, can be modified to reduce fouling and, hence, to generate less waste when cleaned. For instance, fouling can be reduced by creating higher turbulence (e.g., using tube inserts) or by providing smoother heat exchanger surf aces.

Reviewing the plant layout with an eye to conserving raw materials and reducing generation of hazardous waste may also lead to improvements in process efficiency.

Additional automation: In operations requiring precise timing and close monitoring to minimize waste, automatic systems might be more effective and could free workers to carry out other activities. For example, continuous monitoring of wash, rinse or plating baths can ensure that maximum use is made of solutions and can trigger a quick response when operational changes occur.

In batch operations, automated systems can replace manual handling of substances. A closed, automated transfer system can reduce error and the likelihood of spills and emissions.

Use of robotics in painting operations have reduced paint wasfe and increased the uniformity of paint thickness. Bear in mind that installation of robotics involves a major financial investment. This option may be accessible only to large companies.

1 This is an active and growing area of industrial research and development. Less toxic substitute products are being developed and tested. Procedures for increasing the purity of raw materials are also gaining favor.

w Material purification

Material substitution

Materlal purification: Hazardous material may enter the process as a contaminant in raw material or feedstock. If raw material is available having a lower concentration of hazardous contaminants, it might be possible for some manufacturers to reduce or eliminate these hazardous waste byproducts from their operations.

For example, some foundries have begun using metal feedstock with fewer impurities. Other industries have begun using acids and organic liquids with reduced levels of metal impurities. This reduces the metal waste generated through reaction processes.


Material substitution: Several examples can be found to illustrate material substitution or modification as an approach to source reduction. A list of examples is presented in table 6-1.

Industry

Printing

Textile

Printed Circuit Boards

Plumbing Fixtures

Electronic Components

Pharmaceuticals

Substltutlon/ModIflcatlon

Water-based ink for solvent-based ink.

Use nonphosphate-containing chemicals

Water-based developing instead of solvent-based.

Replace hexavalent chrome-plating bath with less toxic, low concentration trivalent chrome.

Ozone instead of organic biocides in cooling towers.

Replace solvent-based tablet coating process with water-based process.

Fasteners I Substitute zinc for cadmium in coating. [adapted lLom Hunt d S c h ” , 1988)

The amount or toxicity of hazardous waste generated from a product’s end-use may be reduced by substitution of one product for another, conservation of the product, or altering the composition of the product.

Product substitution

Product conservation

Changes in product composition

Product substitution is exemplified by two widely successful product substitutions, plastic bumpers for chrome bumpers on automobiles and concrete utility poles for chemically treated wood ones.

Public concern about destruction of stratospheric ozone by chlorofluorocarbons (CFCs) led to the banning of their use as aerosol propellants in the U.S. in 1978. International interest in finding a substitute for CFCs in cooling systems is growing.

The pesticide manufacturing and agribusiness industries shifted from heavy reliance on organochlorine pesticides to the less ecotoxic organophosphates after DDT was banned in the 1970s.

A growing number of fast-food companies are replacing polyurethane food containers with paper ones.

52 WASTE MlNIMIZATION: AN INTRODUC7‘ION

Product conservation refers to the way in which an end product is used. For example, better maintenance of process equipment and components by industry can decrease the frequency of equipment component replacement, which in turn reduces waste generated by the used component. Similarly, consumers can, through careful maintenance, extend the life of the products they buy and use. In this way they reduce the amount of waste generated in the manufacture of a replacement product.

Changes In product composition involves manufacturing a product with reduced or no hazardous components. For example, a nonhalogenated solvent might be used in place of a halogenated one as the active ingredient in a chemical formulation. Organic pigments have been used in place of heavy metal pigments in the manufacture of paint.

FURTHER EXAMPLES OF SOURCE REDUCTION ALTERNATIVES

The following tables present a list of various changes that might be used to achieve source reduction. These examples are grouped according to type of production operation and include source reduction opportunities applicable to: 1 ) all operations, 2) continuous process operations, 3) batch operations and 4) manufacturing operations.

These examples are presented for reference only. You need not memorize them. However, you may wish to familiarize yourself with them as a checklist for future reference. You may also want to add to them examples from your own experience.

TABLE 6-2

SOURCE REDUCTION OPPORTUNITIES APPLICABLE TO

SOURCE OF WASTE

All Waste Streams

Adapted ltwn CMA (1989),

SOURCE REDUCTION OPPORTUNITY

Use higher purity materials Use less toxic raw mateials Use noncorrosive materials Convert from batch to continuous process Tighter equipment inspection Better operator training Closer supervision Practice good housekeeping Eliminate or reduce water use for splli cleanup Implement proper equipment cleaning Use improved monitoring systems Use pumps with double mechanical seals

h r n andcallahan (IQ86) end From, et 81. (1987)


I'ABLE 6-3

SOURCE REDUCTION OPPORTUNITIES IN CONTINUOUS PROCESS OPERATIONS

SOURCE OF WASTE

Heavy and Light Ends

Spent and Lost Catalyst

Equipment Cleaning Wastes

Leaks and Spills


Develop more selective catalyst Optimize the reduction variables/

Use alternate process routes reactor design

Develop tougher catalyst support Use filter inside reactor freeboard

Use high pressure rinse system Increase equipment drainage time Reuse spent rinse water Use corrosion resistant materials Agitate and/or insulate storage tanks Re-examine the need for chemical cleaning Use nitrogen blanket to reduce oxidation Use in-process cleaning devises

Segregate (for reuse or recycling)

Use bellow-sealed valves Use canned (seal-less) pumps Maximize use of welded vs flanged

Use pumps with double mechanical seals

(mechanical wipers, etc.)

pipe joints

Adapted from CAM (1 989). F r o " and Callahan (1986) and Fmmm, et al. ( 1 987)

TABLE 6-4

SOURCE REDUCTION OPPORTUNITIESIN BATCH OPERA TlONS

SOURCE OF WASTE Material Handling

Reaction/Processing Step

SOURCE REDUCTION OPPORTUNITY Segregate containers by prior contents Use rinsable/recyclable drums Purchase materials in preweighed packages Use pipeline for intermediate transfer Keep containers sealed to maximum possible extent Store materials in tanks instead of containers

Optimize reaction variables/reactor design Optimize the reactant addition method

54 WASTE MlNlMIZATION: AN INTRODUCTION

Table 6-4 continued from previous page

Reaction/Processing Step (Cont.)

Filtration and Washing

Baghouse Fines

Off -Specification Product

Equipment Cleaning

Leaks and Spills

Reduce the use of toxic catalysts Document operating and maintenance procedures Charge materials closer to stoichiometric (more exact molecular weight-based) ratios

Employ efficient washingkinsing methods Eliminate the use of filter aids Use counter-current washinghinsing Recycle spent washhinse water within process Use cleanable filters instead of disposable

Increase use of dust suppression methods Use wet instead of dty grinding Schedule baghouse emptying Segregate (for reuse or recycling) - ~~ ~

lighter control of reaction operating parameters Reuse in low-spec stage of process Segregate (for reuse or recycling)

Install high-pressure spray wash system Alter production schedule Use mechanical wipers on mix tank side walls and in large pipes Clean mix tanks immediately after use Use a counter-current rinse sequence Recycle spent rinse water within process Increase spent rinse settling time Re-examine need for chemical cleaning

Use bellow-sealed valves Install spill basins or dikes Install splash guards or drip boards Install overflow-control devices Maximize use of welded vs flanged pipe joints Use pumps with double mechanical seals

Adapted from CAM (1989), Fro” and Callahan (1986) and Fromm, et al. (1987)


TABLE 6-5

SOURCE REDUCTION OPPORTUNITIES lN MANU FACTURING OPERATIONS

SOURCE OF WASTE

Materials Handling

Solvent Cleaners

Alkaline/Acid Cleaners

Plating/Etching/Surface Finishing Solutions


Segregate containers by prior contents

Use rinsable/recyclable drums

Purchase materials in bulk or in larger containers

Purchase materials in preweighed packages

InstalVoperate cleaning tanks properly

Avoid cross-contamination of solvents

Avoid water contamination of solvent

Remove sludge continuously

Monitor solvent composition

Consolidate cold cleaning operations

Use plastic bead blasting for paint stripping

Cover solvent in tanks with lid or floating balls or foam

Use refrigerated freeboard on vapor degreaser units

Redesign drain racks for reduced drag-out

Determine optimal drainage time to minimize drag-out

InstalVoperate cleaning tanks properly

Avoid cross-contamination of solvent

Remove sludge frequently

(segregate)

Increase plating solution bath life Recirculate contaminated rinse water through plating tank

Adapted from Cu4 (1989)


CHAPTER 6

SOURCE REDUCTION STRATEGIES AND EXAMPLES

SELF-TESTING EXERCISE Insttuctlons: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter. Note that you are asked to explain your answers to some of the questions.

Questions: 6.1 Source reduction is said to involve both technological changes and

changes in attitude and perspective. Select, from among the following examples, those that represent changes in attitude and perspective likely to assist in successfully identifying and implementing source reduction strategies in the workplace. (Select as many as apply.)

1. Recognizing hazardous waste as a significant liability.

2. Recognizing that source reduction is a job which can most effectively be done by one person and without influencing the operational routine of the plant.

3. Recognizing that re-evaluating procurement practices and scheduling of processes might hold clues to ways to reduce waste production.

4. Looking to efficiency as a worthwhile source of cost savings.

5. Considering employees as potentially active participants in waste reduction assessment and implementation.

6. Approaching regulatory agencies and generator inspectors as partners with whom to work in reducing waste production.

7. Seeing source reduction as a short-term technical fix that will assure reduced costs and increased production.

6.2 In considering the costs to be saved through source reduction which of the following need not be m? (Explain your answer.)

A. Fees, insurance and management overhead costs.

B. Energy and raw materials costs.

C. Storage and tracking costs. D. Treatment, transportation and disposal costs.

E. All should be considered.


6.3 Which of the following \ N a s t presented in the text as a major strategy for achieving source reduction? (Explain your answer.)

A. Good operating practices

B. Onsite recycling

C. Changes in technology

D. Changes in input or feedstock materials

E. Product changes

F. All were included.

6.4 Which of the following statements is DQ$&UQ of source reduction through good operating practices? (Explain your answer.)

A. They involve mainly procedural changes.

B. They often can be done at low cost.

C. They often show good return on investment in a short time.

D. They include product substitution.

E. All of the above statements are true.

6.5 The good operating practices approach to source reduction does not include (Explain your answer.)

A. Material handling improvements and loss prevention.

B. Waste stream segregation.

C. Inventory management.

D. Personnel education, communication and involvement.

E. Additional automation.

F. Procedural scheduling.

G. All are included.

6.6 Which of the following statements is not true of source reduction applied through waste management cost accounting? (Explain your answer.)

A. It may be started later, after equipment alterations and other technical changes have been shown to be succeeding.

B. It provides essential baseline data for determining cost-benefit effectiveness of waste minimization efforts.

C. Some baseline assessment data may already be available to a company in reports prepared for compliance with Title 22, RCRA, SARA 111 (313), SB14 (beginning Sept. 1991).

D. Should include information on the rate at which hazardous wastes have been and are being generated.

E. All of the above statements are true.


6.7

6.8

6.9

6.10

6.11

6.1 2

6.13

Give one example of an inventory management action which might reduce the amount of hazardous waste accumulated in a facility.

Define "just-in-time" manufacturing amount of hazardous waste being generated.

explain how it might reduce the

Industry compliance with existing regulations is an immediately accessible means of reducing waste and conserving materials. As an experienced generator inspector, you can be of assistance to plant personnel in identifying preventive measures which minimize waste.

List at least five measures you might suggest to improve the handling of hazardous materials in a facility.

List at least two advantages to be gained from segregating the waste streams being generated within a plant.

What advantages are to be gained from having maximum employee awareness and involvement in the waste minimization process? Suggest two specific examples of ways to encourage employee participation.

Source reduction strategies using changes in technology would not include (Explain your answer.)

A. Process changes.

B. Additional automation.

C. Offsite recycling.

D. Equipment, piping and layout modifications.

E. All would be included.

In reviewing the production process for changes that might reduce the generation of hazardous waste, which of the following approaches would probably be the least fruitful? (Explain your answer.)

A

8.

C.

D.

E.

Determining whether each step which uses hazardous material is necessary.

Asking whether the process could be dons more efficiently or with alternative, less toxic chemicals.

Increasing the efficiency of treatment processes, such as dewatering or dilution.

Testing the operating efficiency of equipment at the settings (temp, feed-rate, etc.) currently being used.

Asking whether the procedure could be changed to reduce the loss of hazardous material to the environment.


6.14 List at least three equipment, piping or layout changes imd explain how each change might decrease the amount or toxicity of hazardous waste being produced.

6.15 With respect to source reduction through changes in input materials, distinguish between material purification and material substitution i-md give an example of each.

6.16 Match the industry on the left with the appropriate material substitution or modification described on the right.

Industry SubstitutiodModif ication

- Textile A. Water-based ink for solvent-based ink

- Printed Circ. Brds. B Water-based developing instead of

- Fasteners (boketc) C. Use nonphosphate-containing

- Pharmaceuticals D. Replace solvent-based tablet coating

- Plumbing Fixtures E. Substitute zinc for cadmium in coating

- Printing F. Replace hexavalent chrome-plating bath with less toxic, low concentration trivalent chrome

6.17 The amount or toxicity of hazardous waste generated from the use of a product after it has been manufactured may be reduced by making changes in the product.

Describe the three changes in product which were discussed and give an example of each.

Comment on the role which consumers might play in influencing source reduction through product changes.


Describe hazardous waste recycling techniques and give examples of:

W Onsite use or reuse

W Offsite recovery or reclamation

W Waste exchanges

Energy recovery

W Recycling technologies

Chapter 7 RECYCLING TECHNIQUES - ONSITE AND OFFSITE

Recycling is the use, reuse, or reclamation of all or part of a waste. It is the most preferable waste minimization method following source reduction. The most

Waste Minimization Techniques

Source Reduction

Figure 7-1. Waste Minimization Techniques. Dashed lines indicate lack of concensus on the status of energy recovery.

preferable form of recycling is that which requires the least amount of management and which returns the greatest proportion of the material for reuse. It is economically advantageous because the need for raw materials is reduced. It is environmentally beneficial because it conserves natural resources and it avoids the higher risk that comes with treatment and disposal operations.

RECYCWNG TECJJNIQUES - 0 N S f l E AND OFFSITE

Recycling Onsite & Offsite

Recycling generally falls into two categories: onsite and offsite.

Onsite recycling is the reuse of waste materials at the site of generation. It may be used in the same or another process. Examples include reuse of cleaning washes and of solvents in the production process (possibly in a process requiring less purity). This type of recycling reduces the cost of raw materials as well as the cost of waste disposal.

Offsite recycling involves transporting the waste to a commercial recycler who processes and returns the material to the generator or sells it. Common examples of this are solvent leasing, battery recycling, and used oil recycling- all very common practices in the automotive repair industry. Offsite recycling generally reduces disposal costs and may result in some savings on purchase of these materials.

The suitability of a waste for recycling depends on the purity, the concentration, and, sometimes, the chemical form of the reusable material in the waste. For this reason, some waste materials must be treated before being recycled. This "treaVpurify-then-recycle" option is less desirable than direct in-process recyclingheuse without treatment. However, if in-process recycling and other source reduction approaches are not possible, then the treat/purify-then-recycle methods should be examined. Those methods that generate and release to the environment the lowest quantity and toxicity of hazardous waste should be selected. Furthermore, the temptation simply to transfer waste from one environmental medium to another should be avoided.

I I Onsite

Return to the Original Process (In-Process Recycling): This was discussed under source reduction in Chapter 3, where you learned that, according to SB 14, "the return of materials or their components, for reuse within the existing processes or operations, so as to reduce, avoid, or eliminate the generation of hazardous waste" is considered source reduction. As mentioned above, this is the most desirable form of recyclingheuse.

In-process and other onsite recycling options may be made more feasible by the adoption of other source reduction practices, such as waste segregation to cut down contamination of materials such as solvents, baghouse dusts, lubricating oils, or rinse waters.

Reuse as Raw Material Substitute for Another Process: If material cannot be reused in the original process because of contamination or other problems, it may be possible to find an alternative use (with lower raw material specifications) within the plant. For instance, contamination is a key concern in the electronics industry. Solvents that have been used to clean circuit boards may contain very


few contaminants and can be reused as cleaning agents in degreasing operations or as a thinner or ingredient in paints. In another case, an electroplater may have a customer who requires that a new electroplating solution be prepared for his parts. After the solution has been used to coat these parts, the remaining electroplating solution may still meet specifications for routine electroplating operations. This solution can be directly reused in another electroplating operation, thereby saving raw material and reducing costs. Again, this option avoids expensive treatment of discarded solution.

It may not always be feasible or economical to recover waste at the operating unit t h t generates it. If, for example, a plant has a number of different departments and processes generating waste solvents, a central distilling department within the plant may offer economic advantages. A single recovery operation may be less expensive from both a capital and operating labor standpoint. The disadvantages of this type of operation are the additional storage, segregation, and handling requirements, all of which increase the possibility of environmental incidents and liability. The overall economics of centralizing a recovery operation must be assessed on a case-by-case basis.

I

Reclamation is the recovery of a valuable material from a hazardous waste. Reclamation techniques differ from use and reuse techniques in that the recovered material is sold to another entity rather than being used in the facility generating it. This option should follow exhaustion of onsite recovery options because of the increase in potential liability, both economic and environmental, with the transportation of waste to the offsite facility.

A waste stream must be characterized before it can be sent offsite. Recovery firms usually require fairly constant composition and relatively high generation rates, such as tanker quantities. These requirements are becoming less restrictive as competition between recovery firms increases along with pressure to avoid using treatment and disposal.

The basic offsite recycling options vary depending on which party, the generator or the recycler, retains ownership of the recycled material. In most cases, the recycler markets the recycled materials.

An increasingly popular approach to recycling is the use of a waste exchange, which is a clearinghouse approach involving the transfer of treated and untreated hazardous wastes to another industrial user for use as raw material. If the industry can find another industry in need of the waste material, it can eliminate disposal costs for that waste stream and may recover some of the costs for the raw materials used in the process. The Califomia Department of Health Services-

Toxic Substances Control Program ( CDHS-TSCP) coordinates the California Waste Exchange, which provides this kind of service.

RECYCUNG TECHNIQUES 4NSJTE AND OFFSlTE 63

The last form of reuse is the use of a waste material for energy production. (There is some disagreement about when energy recovery should be considered recycling - a n d a part of waste minimization-and when it should be considered treatment. This raises a complex technological and regulatory issue which is beyond the scope of our discussion here. You are encouraged to explore this further on your own.)

When waste is used for energy production it can be processed in a variety of ways, such as in cement kilns or asphalt plants, in cofiring fossil-fuel-fired plants, or in incinerators equipped with an energy recovery system. Larger firms with their own power generation facilities may have the flexibility to cofire moderate- to-high Btu wastes. Waste characteristics, such as chlorine content or ash composition, may restrict use of the waste as a fuel due to either regulatory requirements (public health and environmental risks) or concern for boiler corrosion.

Commercial fuels-blending programs are usually run in conjunction with treatment or incineration firms. These firms blend a variety of high Btu wastes with varying compositions, from a number of generators, to produce a fuel with particular specifications. These blended fuels are usually fired in cement kilns or asphalt plants. Waste generators considering such alternatives should perform site inspections and investigate the blending firm and the ultimate user of the fuels. Full regulatory and legal reviews should also be conducted.

Incineration is the last form of energy recovery. Some hazardous waste incinerators and many refuse incinerators are equipped with energy recovery equipment. While some major facilities operate either or both types of incinerator, most firms must resort to offsite treatment. These treatment facilities should be carefully evaluated from an economic, regulatory, and operations standpoint. While these facilities reduce volume and, generally, toxicity, air pollutant generation and the final incinerator ash disposal must still be considered and may impact a generator’s liability. At the present time, there is still significant public concern about and opposition to incineration of hazardous wastes.

What are some of the obstacles that impede the adoption of waste minimization approaches by businesses? Some of these impediments and the ways you might help overcome them are discussed in the next chapter, “Barriers to Eff edive Waste Minimization”.


CHAPTER 7

RECYCLING TECHNIQUES - ONSITE AND OFFSITE


Questlons: 7.1

7.2

7.3

7.4

7.5

Define recycling and indicate where it lies in the waste management hierarchy. Give two examples of hazardous wastes that are commonly recycled in your geographic area.

What are three advantages of recycling? Are there disadvantages? Identify one.

The suitability of a waste for recycling is dependent on the I

the I and sometimes, the of the reusable material in the waste.

What is in-process recycling?

From the perspective of environmental protection, which list includes methods of recycling arranged correctly from most-to-least desirable (left to right)? Explain your answer.

A. Return to original process->Offsite treatment and reclamation->Reuse onsite as raw material in another process without treatment->Reuse onsite as raw material in another process following onsite treatment--> Incineration with energy recovery.

6. Return to original process-->Reuse onsite as raw material in another process following onsite treatment-->Reuse onsite as raw material in another process without treatment-->Offsite treatment and reclamation-dncineration with energy recovery.

C. Return to original process->Reuse onsite as raw material in another process without treatment-->Reuse onsite as raw material in another process following onsite treatment->incineration with energy recovery-Offsite treatment and reclamation.

D. Return to original process-->Reuse onsite as raw material in another process without treatment-->Reuse onsite as raw material in another process following onsite treatment-Offsite treatment and reclamation-hcineration with energy recovery.

RECYClINC TECHNIQUES -ONSITE AND OFFSlTE 65

7.6 Discuss two specific examples that illustrate the reuse of hazardous waste as a raw material substitute for a process different from the one that generated it. (Use one from your own experience or one from the text.)

7.7 How does reclamation differ from other methods of recyclingheuse?

7.8 Describe what a waste exchange is. What is the most common hazardous waste recycled through waste exchange in your area?

7.9 List three ways in which hazardous waste is used for energy production.

7.10 Briefly discuss some of the factors that may limit the use of hazardous waste as a fuel.

7.11 Why, in your opinion, is high temperature incineration of hazardous wastes not more widely used?

Optional Ouestion: In your opinion does the burning of hazardous waste for energy meet the definition of "waste minimization"? Defend your answer.


Describe the following barriers to effective waste minimization and suggest ways that you, as an inspector, can assist with each.

Financial barriers

Informational barriers

Technical barriers

H Institutional barriers

Chapter 8 BARRIERS TO EFFECTIVE WASTE MINIMIZATION

The shift of emphasis from end-of-pipe waste management and pollution control to waste minimization is not without its obstacles. However, in some ways, the barriers to waste minimization are similar to those of any other major change in business practices. The recognition of the hazards, liabilities, and costs associated with hazardous waste generation is relatively new to the industrial community and there are significant limitations on available financial resources, information, and technical capabilities. Waste minimization can be further limited by institutional barriers due to the persistent end-of-pipe outlook on hazardous wastes that is common to both government and industry.

The Sate of California has recognized these barriers and is attempting to provide some assistance to the regulated community in these matters. You are challenged, as an inspector working within the regulatory framework, to assist generators in their efforts to overcome some of the obstacles.

Some of the barriers to waste minimization include:

Financial Barriers

Informational Barriers

Technical Barriers

Institutional Barriers

FINANCIAL BARRIERS Many generators lack the available capital to implement costly equipment changes and process modifications. However, as you have seen, many of the opportunities to minimize waste-both source reduction and recycling-require little or no significant capital outlay or equipment changes.

You are in a position to introduce the facility personnel to some of these low- cost, low-technology, quick-retum waste minimization alternatives. You may also be able to motivate generators to take a longer view of the financial

BARRIERS To EFFECTIVE WASTE MINIMIi!ATlON 67

ramifications by providing examples of other businesses that have achieved economic advantages through waste minimization (See Chapter 9).

Management personnel should also be encouraged to adopt a thorough waste management cost-accounting system to assess the feasibility of waste minimization for their facility. An improper accounting system--by hiding the ”true” costs of generating hazardous waste--may serve as a disincentive to adopting a waste minimization program.

The number of government and private financial assistance programs designed to encourage reduction in hazardous waste generation has recently grown. You and your department can help put business managers in touch with agencies that provide such assistance. Some of the agencies to contact are the California Department of Health Services, the U.S. Environmental Protection Agency, the California Pollution Control Financing Authority and the Small Business Administration.

INFORMATIONAL BARRIERS Generators may lack knowledge of waste minimization methodologies and regulatory requirements, or lack the technical expertise to institute waste minimization strategies.

This is the barrier which you are in the best position to help overcome. Keep in mind that many of the waste minimization options do not involve highly technical information. Providing locally appropriate information in an accurate and understandable manner is essential to the widespread adoption of waste minimization strategies.

At a minimum, you should be sufficiently knowledgeable to respond to inquiries and to identify sources of further information. Optimally, you will provide unsolicited information regarding waste minimization at every available opportunity. Many smaller generators, in particular, are of a mindset that tends not to question past ways of doing things, despite these ways being economically or environmentally disadvantageous. Your insights may be very influential with them.

It is not expected that you will become a technical expert in each of the industrial processes that you are called upon to inspect. Your best informational assistance in technical matters will generally be the creation of linkages between your generators and sources of technical information such as trade associations, publications, and specialized units within State and federal agencies.

TECHNICAL BARRIERS As we have already mentioned above, technology in general is not a factor that should seriously limit a generator from implementing many of the methods of waste minimization. You have learned about several of these in earlier chapters.

However, in some cases, the lack of specially designed equipment and technical expertise do impede the changeover to practices that generate less waste or recycle what is generated. Again, it is important to remember that the role of the


inspector in to assist hazardous waste generators by tapping into sources of technical information that are available through local, State and federal government agencies, as well as through professional trade organizations and technical journals.

INSTITUTIONAL BARRIERS Hazardous waste generators often are unable to devote attention to assessing their operations for waste minimization opportunities because they are putting so much energy, money and time into complying with existing regulations and keeping ahead of new regulations. In many cases they may lack confidence in the regulating community. For example, in spite of the call for placing waste minimization high on the list of priorities, the federal govemment, until very recently, has done little in the way of implementation-leaving the job largely to the states.

Lack of knowledge among regulators and lack of flexibiliy in regulations have been cited as limitations. Existing regulations and market factors may work against efforts to implement waste minimization. For example, small quantity generators are sometimes caught between the regulators and the recyclers. While regulations limit the amount of hazardous waste that they can accumulate on site, the recyclers often require large quantiiies of waste to qualiiy for their services. This is compounded by the fact that fluctuations in market values of virgin stock can cause unpredictable changes in demand for recycled raw materials.

Other disincentives include extensive permitting requirements and restrictions on onsite treatmenVpurification of hazardous wastes for recycling. Finally, in many cases, management is simply not willing to devote company resources without regulatory incentives.

As with many other aspects of your work as a hazardous materials inspector, assisting generators to overcome some of the barriers to waste minimization can best be achieved through recognizing your own limitations in this area, providing what information and encouragement you can, and conducting as thorough and conscientious a facility inspection as you are able.

Anyone venturing into new territory is likely to be encouraged by reports of successful efforts by other adventurers. In the next chapter, Waste Minimization Success Stories", we discuss several examples from a variety of industries.

BARRIERS TO EFFECTNE WASTE MINIMIZATION 69

- -

W4S"E MINIMIZATION: AN INTRODUCTION

CHAPTER 8

BARRIERS TO EFFECTIVE WASTE MINIMIZATION

SELF-TESTING EXERCISE Instructions: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter.

Quest Ions:

8.1 List the four barriers to effective waste minimization that were discussed in this chapter.

8.2 Which two of these barriers are you, as an experienced and well-trained inspector, best equipped to help businesses overcome?

Describe what you can do most effectively in each case.

8.3 Respond, briefly, to the following statements, which could have been made by large or small quantity generators.

A. “I can’t do anything to reduce the amount of waste I generate because I don’t have the capital to change or replace any of my equipment .”

B. “This is a small operation. That high tech stuff is for the big companies with special budgets for hiring outside consultants.”

C. “It seems to me that it’s cheaper and less trouble to send our hazardous wastes to a TSD facility and let them deal with them.”

D. “Waste minimization may work for some industries, but it isn’t worth-while in mine.” (Note: You may want to skim Chapter 9 before responding to this one.)

8.4 Identify two institutional barriers to the adoption of waste minimization strategies. Assess what you, as an inspector, could or could not do to help overcome each of these barriers.

8.5 Based on your knowledge or experience, identify the most significant disincentive that operates to discourage the adoption of waste minimization strategies or techniques.

BARRIERS TO EFFECTIVE WASTE MlNlMZZATlON 71 a:

H Present several examples of successful applications of waste minimization practices which have been put into effect by large and small hazardous waste generators. (Emphasis on source reduction.)

minimization. Identify tangible benefits realized from these applications of waste

Chapter 9 WASTE MINIMIZATION SUCCESS STORIES

INTRODUCTION As a hazardous materials inspector, you should bear in mind that it may be difficult for people in industry, particularly those who have invested years of attention, time and financial resources in technologies or strategies designed to cope with waste after it is generated, to see any value in seeking ways of decreasing the amount of waste generated in the first place. However, many industries have discovered that pollution prevention through waste minimization can save money, improve worker safety, reduce environmental pollution and enhance public image . In summarizing its waste reduction efforts since 1975, the 3M Company, an industry leader in waste minimization, reported the following:

The combined total of almost 1,900 projects has resulted in eliminating annually the discharge of almost 110,000 tons of air pollutants, over 13,000 tons of water pollutants, and over 260,000 tons of sludge of which over 18,000 tons are hazardous - along with the prevention of approximately 1.6 billion gallons of wastewater. Cost savings to 3M total more than $292 million.

The 3M report identified the following sources of their savings:

1. Pollution control facilities that did not have to be built.

2. Reduced pollution control operating costs.

3. Reduced manufacturing costs.

4. Retained sales of products that might have been taken off the market as environmentally unacceptable (OTA, 1986).

The experiences of 3M and other industries that have succeeded with waste reduction programs have shown that waste minimization succeeds when it is part of the everyday awareness of all workers and managers involved with production - where the waste reduction opportunities are - rather than when it is a job only of those responsible for complying with end-of-pipe pollution control regulations.

WASTE MZNZWZATION SUCCESS STORIES 73

Among the examples presented below, we have included a variety of commercial operations that have employed different aspects of the waste minimization approach, but especially source reduction.

Where possible, the cost benefits in dollars, as provided by the business itself, are presented. However, as you have learned, there are other less tangible benefits and incentives-such as improved worker safety, reduced liability, less environmental pollution and enhanced public image-that may not have been recognized or acknowledged.

If you need further information on the examples presented or if you wish to locate other examples, see the references at the end of the manual.

For ease of understanding, these success stories are arranged according to the particular waste minimization technique applied. This is a somewhat artificial arrangement, since most successful waste minimization efforts include a broad- based approach integrating various strategies.

You should recall these categories from Chapter 6, “Source Reduction Techniques and Examples”:

Source Reduction

W Good Operating Practices

H Changes in Technology

Changes in Input Materials

W Changes in Product

SOURCE REDUCTION Comprehensive Many companies, such as, 3M, General Dynamics, Hewlett-Packard, and others, have applied source reduction in a comprehensive manner. For example, Stanadyne Company has undertaken a comprehensive and systematic review of its electroplating processes in order to reduce or eliminate waste generation. Its efforts have resulted in a broad spectrum of activities that have saved the firm money and minimized pollution-a total waste reduction of 46 percent being realized. Some ot these activities included:

A sulfuric/peroxide bright dip was substituted for a chromic acid bright dip for cleaning brass and copper parts that have been brazed together. This substitution reduced overall sludge production.

The concentrations of chemicals used in the cyanide, copper and chrome plating baths were reduced. By running the potassiuum cyanide concentration at 2.5 instead of 3.5 ounces per gallon, the cyanide drag-out concentration has been reduced by 28 percent, without any adverse effect on plating quality. In the chrome baths, the chromic acid levels are now maintained at about 29 instead of 32 ounces per gallon. These actions resulted in a 9 percent reduction in raw material use.

A simple drag-out recovery system was installed on the nickel plating machine

74 WASTE MlNlMlZATlON: AN INTRODUCTION

for zinc diecastings. Less than $1,000 was invested for a storage tank. This

generation of nickel sludge by 9,500 pounds per year.

Items to be electroplated are now inspected to eliminate defective parts before they enter the plating process. Since plating a defective part creates the same amount of waste as plating a good one, the elimination of defective parts from the plating operation results in direct waste reduction. (- m, 1989)

1 c system saves the firm $4,200 worth of nickel per year, and reduces the

. . .

Good Operating Practices Inventory Management A firm producing plastic beads for manufaturers of plastic goods addressed the ongoing problem of disposal of nearly 100,000 empty 50 Ib bags that had contained various hazardous additives. They installed 2,000 Ib reusable "supersacks", which can be filled from rail car or semi truck shipments. They still use 50 Ib bags for low use additives.

Benefit: The above changes, together with recycling arrangements for liquid wastes, have reduced the previous 500 tons of annual waste to 148 tons/yr. (Ventura County Environmental Health, 1987)

Employee Involvement & Inventory Management A committee of safety, medical, legal and technical people from within a dye company was set up to screen all chemicals on the basis of their relative safety in use, fire potential and hazard to the environment. They also reviewed chemicals to be used in the development of new products.

Benefit: Accidents were reduced and spill cleanup costs were saved. (( , 1989) . . . .

Employee Involvement & Inventory Management A similar screening committee was formed by a diesel engine manufacturer.

Benefit: As a resultof this committee's work, the costs of environmental and worker safety regulation compliance were reduced. The company reported that waste management, long-term health care and liability costs were also reduced.

, 1989) (-us w- , , . . . .

Employee Tralnlng Hubbard Enterprises of San Diego County, as a part of its overall waste minimization program, implemented an ongoing training program for the manual copper cyanide electroplating department employees. The program focused on proper rinsing techniques.

Benefits: This single step reduced loss through drag-out by 4550%. (San Diego County Department of Health Services, 1987)

Waste Stream Segregation & In-Process Reuse A pesticides manufacturing company had been collecting, in a single baghouse, pesticide dust from two

WASTE MlNIhf.lZATION SUCCESS STORIES 75

major processes. The firm replaced the single baghouse with two separate vacuum-air-baghouse systems specific to the two production lines. Segregation of the two streams stopped cross-contamination and allowed the collected pesticMes to be reused within the original process.

Benefit: Savings on annual disposal costs of over $9,000. Savings on recovered pesticide was over $2,000. One-time cost of replacing original

, 1989) baghouse system was $9,600. (S . . . .

Waste Stream Segregation & In-Process Reuse A label printing company eliminated waste toluene from printing press cleanup by segregating the solvent according to the color and type of ink cleaned from the press. Each segregated batch of toluene is now reused for thinning the same color ink. (Hazardous Waste Minimization ..., 1989)

Waste Stream Segregatlon & In-Process Reuse A film developing unit at 3M’s Electronics Products Division stopped discharging waste water contaminated with 1,l ,l-trichloroethane by installing a decanter system that provided gravity separation of the solvent from the water. Both the solvent and the water are being cycled back into the process.

Benefit: Installing the decanter system cost $4,000; it saved the company $12,000 during the first year of use. The company also achieved compliance with waste water discharge regulations. -us Waste M inimization..,, 1989)

I Waste Stream Segregation & Recycling Offslte Major Paint Company, a subsidiary of Standard Brands Paint of Torrance, California, successfully segregated its waste streams, allowing for collection and recyclingheuse of both its aqueous and solvent-bearing waste. Water-based cleanup wastes are now blended with additives to create a beige-colored paint. The solvent-bearing wastes are reused several times and then shipped to an offsite reclaimer. Customer returns, obsolete finished products and off -specification products are reworked into new paints.

Benefit: Land disposed waste was reduced from 1,226 tons/yr in 1982 to zero in 1985. (Local Govemment , Oct.1988)

Changes in Technology Process & Equipment Changes Several newspapers are switching from letter press and lithography to flexolography, a process that allows the use of water-based inks. The Long Beach Press-Telegram has converted some of its eight printing presses to the flexolography process.

Benefit: Ink containing the wash water, which is the only waste produced by this process, is then easily purified by sedimentation or filtration, and the filtrate can be discharged into the sewer. The small volume of pigment that remains can be recycled. (DHS, July 1986)

Process & Equlpment Changes A small manufacturer of fabricated metal products in Ventura switched from an alkaline bath process to a mechanical

76 WASTE MMMIZATION: AN INTRODUCTION

abrasive system for cleaning nickel and titanium work pieces.

Benefit: Alkaline waste of 12,00O/yr was eliminated. Savings on disposal costs is $7,50O/yr. (Local Government Commission, Oct.1988)

Process & Equlpment Changes Hill Air Force Base in Ogden, Utah changed its paint stripping operation from solvent-based to plastic bead blasting.

Benefit: For each aircraft stripped through the mechanical stripping method, the Air Force saves 302 person hours, $5,076 in raw materials, $935 in disposal costs, $1,485 in waste water treatment costs and $104 in energy costs. (Local Govemment Commission, Dec.1988)

Process & Equlpment Changes & In-Process Reuse An office furniture manufacturer installed a small waste lacquer thinner recovery unit, which recovers about 85% of the solvent for in-process reuse.

Benefit: Savings on solvent costs average about $1 OOMeek. The recovery , 1989) unit paid for itself in one year. (M . . . .

Process & Equlpment Changes & In-Process Reuse Company in Pittsburgh, California installed in-process feedback loops to recirculate hydrogen chloride gas. (DHS, July 1986)

Dow Chemical

Process & Equlpment Changes & Recycling Vulcan Automotive Equipment Ltd., a remanufacturer of used automotive engines, substituted a high-velocity 'aluminum shot" system for a caustic inorganic cleanser. The total cost of the system was about $80,000.

Beneflt: An annual savings of $40,000 is expected. All by-products of the process are now recycled. Worker safety has been enhanced. Productivity and product quality has improved. The overall appearance of the plant has improved.

, 1989) . . . . ((

Automation & Materlal Substitution An electric company increased productivity, reduced operating costs and minimized waste generation rates through automation and material substitution.

Benefit: 1) An automated electroplating system has reduced process chemical usage by 25 %, process batch dumps by 20% and waste water treatment costs by 25%.

2) The replacement of a solvent-based painting system with a water- based electrostatic immersion painting system has reduced waste solvent and waste paint solids generation by over 95%. %, 1989)

. . . .

WASTE MlNfMfZATfON SUCCESS STORIES 77

Changes in Input Materials Materlal SubaituUon Monitor Labs, a manufacturer of air quality analyzers in San Diego, substituted Simple Green for methylene chloride and methanol for cleaning and degreasing parts.

Benefit: By switching to this common household cleaning product hazardous waste has been reduced by 80%, saving the company $1,80O/yr in disposal costs. (Local Government Commission, Oct.1988)

-

Material Substitutlon manufactures small electric appliances. Successful small-scale tests led to the substitution of a water-soluble synthetic cleaner for 1 ,1 ,1-trichloroethane (TCA) in some degreasing operations.

Benefit: They have reduced TCA use by 30% for an annual savings of $12,000.

The Hamilton Beach Division of Scovill, Inc.,

,1989) . . . .

Material Substitution A milk testing facility in Raleigh, North Carolina reported exchanging potassium dichromate preservative (which was causing a high level chromium waste discharge to the sewer system) for a non-toxic organic substitute.

Benefit: Making this subtitution saved the cost of constructing a pretreatment system. (Local Government Commission, Oct. 1988)

Material Substitution ITT Telecom replaced a TCAlmethylene chloride-based, photo resist system with an aqueous-based system. The aqueous-based system uses water-miscible solvents from the glycol-ether family to develop and strip the photo resist from the circuit board.

Benefit: TCA and methylene chloride waste was reduced. Product quality improved. Production time was reduced. (&ga&us Waste M i n i w t ion.,, 1989)

. . .

Material Substitution Reevaluation of its production process enabled a textile dye and finishing plant to reduce its phosphorus discharge to environmental compliance levels by substituting non-phosphorus-containing chemicals for hexametaphosphate and phosphoric acid.

Benefit: Waste water discharge standards were met without installation of expensive waste water treatment systems. (Hazardous Waste M inimization ..., 1989)

Materlal Substitutlon & Process Change Riker Labs, a pharmaceutical company and a division of the 3M Company located in Northridge, CA, successfully solved the problems it confronted in substituting an aqueous solution for an organic solvent in its medicine tablet coating process.


Benefit: Eliminated emission problems with that organic solvent and ultimately saved several thousand dollars. (DHS, July 1986)

Changes in Product Changes in Product Composition Static control mats, being manufactured for use under personal computers at 3M, contained two metal catalysts classified RCRA-hazardous. Nonhazardous substitute chemicals were found.

Benefit: Several tons per year of hazardous waste were eliminated. (Hunter and Benforado, 1987)

Changes In Product Composition 3M also eliminated some of the hazardous materials incorporated into products destined to be discarded by customers. They succeeded in removing cadmium, mercury and asbestos from their respective product lines. (Hunter and Benforado, 1987)

Discontinued Product A California-based cosmetics formulating company discontinued its nail product line after determining that it was responsible for all its solvent waste.

Benefit: Eliminated 100 gal. of waste solvent/yr. (Ventura County Environmental Health, 1987)

Product & Process Modification An aluminum forging company in Ventura County negotiated with its trucking industry customers to begin accepting hubs that were not shine-etched, thus cutting out a process that generated large amounts of acid and alkaline wastes. Once the hubs are in place on the truck, they are not visible! (Ventura County Environmental Health, 1987)

RECYCLING In California each year, several hundred thousand tons of hazardous waste are recycled offsle. The volume of waste oil exceeds all other hazardous waste recycled, with oilhater separation sludge in second place. Used or contaminated solvents represent about 20% of the total, with acid and alkaline solvents (including metal contaminants) and miscellaneous making up the remaining 56%.

The California Department of Health Services (DHS) has an active industrial recycling assistance program. The Califomia Waste Exchange publishes a Newsletter/Catalogue, which lists hazardous wastes available and hazardous wastes wanted. The Department also publishes a Directory of Industrial Recyclers. Many other publications dealing with recycling are published by State and federal agencies. The Department is publishing an extensive bibliography of waste minimization publications, including recycling. Because recycling techniques are very industry-specific and because abundant published material exists, we have included only a few examples of recycling stories here. Your

WASTE MNIhfIZATION SUCCESS STORIES 79

Department may have compiled industry or process-specific information on recycling in your area.

A few examples are presented below.

H Onsite

Offsite

H Waste Exchange

Onsite In-Process Reuse (See Source Reduction).

Onsite Recycling & Reuse The Rexham Corporation facility in Greensboro, North Carolina, installed a Cardinal distillation unit to reclaim n-propyl alcohol from their waste solvent generated in the manufacture and printing of specialized product labels.

Benefits: Total installed cost of unit = $1 6,000. Efficiency = 85% solvent recovered. Savings = $15,00O/yr in virgin solvent costs; $22,800 savings in

, 1989) hazardous waste disposal costs. (m . . . .

Onsite Recovery & Reuse treatment facility that allows it to treat scrubber waste and reuse 260,000 gal of water/day in cooling towers rather than discharging it as hazardous waste.

Benefit: Savings are $30,00O/yr in water and pump costs, $1 00,00O/yr in sewer charges and $740,00O/yr in disposal costs. (Solvent WastcRe$uct ion-, 1986)

IBM in San Jose, California built a waste

Offsite Offsite Recycling & Reuse contracted with Ashland Chemical Company to distill and recycle waste 1,1,1- trichloroethane generated during degreasing of metal stampings. The waste solvent had previously been collected in 55-gallon drums and housed in a special storage building and disposed of at a TSD facility.

Benefit: The plant reduced raw material costs by $5,32O/yr and eliminated all

1989)

A small electric appliance manufacturer

. . . . of its waste disposal costs of about $3,00O/yr. (Hazardous Waste Miniruabon . . - 9

Offsite Recycling & Reuse Sacramento Bee, the Los Angeles Herald Tribune, and the Press Democrat , have successfully recycled and reused ink.

Benefit: Most commonly used printing inks are classified as hazardous material in California. Waste disposal costs have been reduced (DHS, July 1986).

Many California newspapers, such as, the


Offsite Recycling equipment cleanup in a fiberglass coating company has been recovered through off site recycling.

Benefit: Waste disposal costs were eliminated for the company, and the cost of recycled acetone is 10% less than for virgin solvent. Minimization..., 1989)

Seventy percent of the acetone used for process

Waste Exchange General Dynamics Convair Division (San Diego), established an industrial chemical waste exchange to make surplus, unused chemicals available-at no cost40 industrial users in the plating, metal finishing and electronics industries. Most of the materials had been left over from completed projects and all were available in the original unopened containers. General Dynamics periodically publishes an inventory of available chemicals in its Industrial Chemicals Exchange newsletter. (San Diego County Department of Health Services, 1987)

WASTE MINlMEATlON SUCCESS SrORlES 81

82 INCENTNES FOR INDUSTRY PARTICIPATION IN WASTE MNIMlZATlON

CHAPTER 9

WASTE MINIMIZATION SUCCESS STORIES

SELF-TESTING EXERCISE Instructions: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the chapter.

Questions:

9.1 The goal of reducing hazardous waste generation applies across all environmental media. Review the information about 3M Company’s experience and comment briefly on its success in this regard.

9.2 Review the Stanodyne Co. information and classify each source reduction technique according to the categories you learned in Chapter 6, “Source Reduction Strategies and Examples”.

9.3 Review the examples of source reduction and recycling success stories and create a table showing: a) the different types of businesses and/or industries that are represented b) the industrial processes affected c) the specific source reduction and recycling technique@) adopted and d) the benefit@) gained.

9.4 Add an additional three success stories or case studies which apply to industrial operations in your geographic area. Include detailed information on the processes involved and the waste minimization techniques used. Indicate the sources of your information. You may need to interview department personnel for this information.

WASTE MlNIMUATION SUCCESS STORIES 83

Briefly discuss systems for classifying hazardous waste streams.

Present the 80-element California hazardous waste classification system.

m Present a 17-element waste stream classification scheme.

Identify the most common waste streams produced by small business

Discuss the types, uses and major industrial process sources of one of

operations.

these waste s t reamrgan ic solvents.

APPENDIX A TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF INTRODUCTION

CLASSIFYING HAZARDOUS WASTE STREAMS Unfortunately, there is no universally accepted system for classifying hazardous industrial waste streams. Several factors hamper efforts to establish such a scheme. These include differences between federal and state laws and regulations and the ways in which administrative agencies monitor and enforce the regulations. Uniformity is further compromised by jurisdictional subdividing of the environmental media (air, water, land) into which the waste streams flow. The complex chemistry of waste stream composition and the overlap among industrial processes further complicates the issue.

Examples of Waste Stream Classification Schemes The available classification schemes have been designed to meet specific needs.

In California: The State of California has identified 80 categories of hazardous waste for use by waste generators in defining the type of waste which they ship offsite. These categories are listed on the back of the Uniform Hazardous Waste Manifest, which must accompany hazardous waste in transit (See Table A-1). This statutory list enables regulators to track the offsite movement of specific types of hazardous waste, however, it may be difficult for non-technical personnel to use in doing preliminary waste minimization assessment work.

APPENDIX A T Y P B AND SOURCES OF W A R D O U S WSTE: A BRIEF INTRODUCIION 85

111

112

113

121

122

123

131

132

133

134

1%

141

151

161

162

171

172

181

21 1

212

21 3

214

221

222

223

231

232

24 1

251

252

Table A-1. CALIFORNIA WASTE CATEGORIES

Acids with metals

Acid without metals

Unspecified add

Alkaline with metals

Alkaline without metals

Unspecifii alkaline

Aqueous with reactive anions

Aqueous with metals

Aqlmous with total organics >lo%

Aqueous with total organics ~10%

Unspecified aqueous solution

Off-spec, aged or surplus organics

Asbestoscontaining waste

fluid catalytic cracker waste

Other spent catalyst

Metal sludge

Metal dust

Other inorganic solid waste

Halogenated solvents

Oxygenated solvents

Hydrocarbon solvents

Unspecified solvent mixtures

Waste oil and mixed oil

Oillwater separation sludge

Unspecified oil containing waste

Pesticide rinse water

Pesticides & pesticide production waste

Tank bottom waste

Still bottoms with halogenated organics

31 1

321

322

331

341

342

343

351

352

41 1

42 1

431

441

451

461

471

48 1

491

51 1

51 2

51 3

52 1

531

541

55 1

561

571

Other still bottom waste 581

Pharmaceutical waste

Sewage sludge

Bid. waste other than sewage sludge

Off-spec, aged or surplus organic

Organic(nonso1vents) liquids with

halogens

Organic liquids with metals

Unspecified organic liquid mixtures

Organic solids with halogens

Other organic

Alum and gypsum sludge

Lime sludge

Phosphate sludge

Sulfur sludge

Degreasing sludge

Paint sludge

Paper sludge/pulp

Tetraethyl lead sludge

Unspecified sludge waste

Empty pesticide containers > 30 gal

Other empty containers < 30 gal

Empty containers < 30 gal

Drilling mud

Chemical toilet waste

Photochems./photoprocessing waste

Lab waste chemicals

Detergent and soap

Fly ash, bottom ash and retort ash

Gas scrubber waste


261 Pdychlofinated biphenyls 591 Baghouse waste

271 Organic m m e r waste

272 Polymeric resin waste 611 Contaminated soil

281 Adhesives 612 Household wastes

291 Latexwaste

711 Liquids with cyanides > 1000 mgIl

721 Liquids with arsenic > 500 mgA

722 Liquids with cadmium > 100 mgA

723 Liquids with chromium > 500 mgA

724 Liquids with lead > 500 mgA

725 Liquids with mercury > 20 mg/l

726 Liquids with nickel > 134 mgA

727 Liquids with selenium > 100 mgA

728 Liquids with thallium > 130 mgll

731 Liquids with PCBs > 50 mgll

741 Liquids with Halogenated organic compounds > lo00 mgA

751 Solids with halogenated organic compounds > 1000 mg/l

791 Liquids with pH e 2

801 Waste potentially containing dioxins

Efforts to simplify: The Toxic Substances Control Program of the State Department of Health Services has made available a simpler, more user-friendly classification scheme. DHS has encouraged its use by:

1) local agencies (see, c m s m

2) generators ( s e e , L for recv-

The simplified system was recommended to generators to assist them in their efforts to identify offsite hazardous waste recycling, treatment and disposal facilities within and outside the State. See Table A-2. This system combines the 80 California waste categories into 17 general waste groups -- sometimes called "Tanner" categories -- for use by small quantity generators in making preliminary determinations of the hazardous nature of their waste. It is considered by DHS to reflect the current knowledge of hazardous

-, 1987) and

1988.)

.. .

APPENDIX A TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF INTRODUCTION 87

waste stream composition in California.

However, this 17-group system of classification has been criticized for several shortcomings and inaccuracies. For example, it does not distinguish between organic wastes that contain metals and those that do not. Nor does it include characteristic or criteria wastes-those deemed hazardous because of their

(DHS, June 1987) for ignitability, corrosiviiy, reactivity, etc. See, further comparisons of the two systems.

. .

Table A-2

SEVENTEEN HAZARDOUS WASTE GROUPS ORGANIC WASTE

LIQUIDS

Waste oil

Halogenated solvents

Non-halogenated solvents

Other Organic liquids

Pesticides

PCBs & Dioxins

SLUDGES AND SOLIDS

Oily sludges

Halogenated organic sludges & solids

Non-halogenated 04. sludges & solids

Dye & Paint sludges & Resin wastes

NON-ORGANIC WASTE

LIQUIDS SLUDGES AND SOLIDS

Metal-containing liquids Metal-containing sludges

Cyanide & Metal liquids

Non-metallic inorganic liquids

Non-metallic sludges

Contaminated Clay, Soil, & Sand

Miscellaneous wastes

lThe miscellaneous waste group includes such diverse wastes as asbestos, metal dust, baghouse dust, biological, household, empty container, photochemical and photoprocessing wastes.

Some examples of the types of waste to be found in these general waste groupings are presented in Table A-3.

88 WASTE MINIMIZATION: AN INTRODUCTlON

Table A-3

APPENDZX A TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF LVTRODUCTION

EXAMPLES OF GENERALIZED WASTE GROUPS - EXAMPLES

Waste Oils ............................... ..Spent crankcase oil, industrial lubricants

Halogenated Solvents .................. Spent TCE, chloroform, carbon tetrachloridc

Llqulds

Non-halogenated Solvents .......... ..Spent acetone, methyl ethyl ketone

Other Organic Liquids ................. .Aqueous organic solutions from cleaning or degreasing operations

Metal-containing Liquids ............... Metal finishing solutions (acid or alkaline)

Cyanide and Metal Liquids .......... ..Neutralized acid or basic washes with

PCBs ....................................... Fluids from old electrical transformers

cyanide salts

Non-metalic, Inorganic Liquid ......... Acidic or basic solutions without metals

Sludges

Halogenated Organic Sludge ......... Halogenated still bottoms

Metal-containing Sludge .............. .Electroplating or chrome pigments,

Oily Sludge.. ............................... Tank bottoms, oilhnrater separation sludge

Non-halogenated Organic Sludge ... Still bottoms without halogens

wastewater treatment sludge

Cyanide and Metal Sludge ............ Metal heat treating sludge

Non-metallic Inorganic Sludges ...... Suffer sludges, lime sludges

Dye and Paint Sludges .................. Sludges from pigments and stabilizers used

Solids

in dye and paint production

Non-metallic Solids ..................... Inorganic dusts, precipitator or baghouse wastes

Contaminated Clay, Soil, Sand ..... .Clay filters, spilled material

Metallic Solids ........................... Dusts, and shavings, primary metal dusts and metal machining wastes, emission control dusts from steel and lead industries

Halogenated Organic Solids ....... ..Polyvinyl wastes

Non-halogenated Organic Solids ... Polyethylene, cyclic intermediates

Miscellaneous Wastes ................. .Lab waste chemicals, equipment containers

Infectious Waste ........................ Materials from medically related sources capable of spreading communicable diseases

(From Department of Health $enfices, Dec. 1988)

89

Other systms for classifying wastes and waste stream are in use at local, State and federal levels. Each has advantages and disadvantages. Interagency efforts are currently underway to develop a uniform and pragmatic classification system.

COMMON INDUSTRIAL SOURCES OF HAZARDOUS WASTE

Natlon-wlde While about 850,000 different plants and businesses across the US. contribute to the total amount of hazardous waste generated, most of the industrial hazardous waste is produced by the chemical and petroleum (71%), and metal-related (22%) industries. See Figure A-1 .

All Other

M etal- Re1 at ed I nd u s t r i es (22%)

,Chemical and Petroleum Industries (71 Yo)

Figure A-1 Major Sources of the 586,00,00 Ibs. of Industrial Hazardous Waste Produced Annually in the U.S.

(Based on 1985 €PA data)

In Callfornla It is difficult to find reliable data on the total amount of hazardous waste generated in California because many hazardous wastes have gone unreported in the past. For example, in 1984, it is estimated that a total of 1.8 million tons of wastes were sent to offsite facilities (reported) and 1.1 million tons

90 WASTE MlNIMlZAl'lON: A N INl'HOI~UCI'ION

were treated and/or deposited at the site where they were generated (Governor's Task Force, 1986). In spite of this limitation, estimates of the relative amounts of hazardous waste generated by various types of industries in California have been made by DHS. For example, see Figure A-2.

4% Transport

5% El ecticaVElectron ic

7% Utilities

8% Metals

15% All Others

22% Chemicals & Allied

40% Petroleum Related

Equipment

Equipment

Figure A-2 Hazardous Waste by Industry Group in California (Based on Governor's Task Force, May 1986)

Hazardous wastes are generated by both large and small businesses. Small businesses, although not individually generating large volumes of wastes, often generate highly toxic and more concentrated waste. Because they do not have the technical or financial resources to initiate waste minimization programs on their own, they are likely to be the most direct beneficiaries of your assistance as an inspector. You should be familiar with the general types of hazardous waste generated by small businesses.

Small Business Operations Table A-4 contains a listing of representative small business operations and their hazardous waste streams. Space available does not allow for a detailed listing of specific chemicals found in the waste streams but publications are available that do.


Table A 4 EXAMPLES OF WASTE STREAMS FROM SMALL QUANTITY GENERATORS

INDUSTRY

Equipment repair

Bulldlng cleaning & maintenance

Vehicle maintenance

Motor freight terminals & Railroad transportation

Laundries & Dry cleaners

Printing & Allied industries

Wood furniture manufacturing & Refinishing

Manufacturing of: -Textiles -Leather

Metal manufacturing

Chemical manufacturers

WASTE STREAM

acids/bases ignitable wastes ~

solvents

acids/bases ignitable wastes - lead acid batteries solvents

acidshases solvents

acids/bases heavy metals/inorganics ignitable wastes lead acid batteries solvents

acids/bases heavy me tal s/ino rg an ics ignitable wastes lead acid batteries solvents

dry cleaning filtration residues solvents

~~ ~

acids/bases heavy metals/inorganics ink sludges spent plating wastes solvents

ignitable wastes solvents

heavy metals/inorganics solvents

acids/bases cyanide wastes heavy metals/inorganics ignitable wastes reactives solvents spent plating wastes

acids/base cyanide wastes heavy metals/inorganics

92

continued on next page


ignitable wastes reactives solvents

Manufacture of Cleaning agents & Cosmetics

Formulators (various)

Pesticide end-users & Application services

Laboratories

Educational & Vocational shops

Wood preserving

Funeral services

acidshases heavy metalsAnorganics ignitable wastes solvents

acidshases cyanide wastes heavy metalslinorganics ignitable wastes pesticides reactives solvents

heavy metalshnorganics pesticides solvents

acidstbases heavy metalslinorganics ignitable wastes reactives solvents

~ ackls/bases ignitable wast 8s pesticides reactives solvents

preservative agents solvents

solvents (formaldehyde)

Note that the three most common waste stream components listed above from small business operations are 1) solvents (in every industry listed) 2) heavy metals and 3) acids/bases.

Wastes containing acids and dissolved metals represent about 20% of the hazardous waste generated in California. These wastes come primarily from metal plating processes. Plating and rinse solutions contain sulfuric, nitric, hydrochloric, and sometimes hydrofluoric acids. The main metal constituents of the waste streams are zinc, nickel, cadmium, and chromium.

Sources of acid and metal wastes, in addition to those listed above, are mining, wet-cell storage battery manufacture and recycling, petroleum refining, and printed circuit board manufacturing.

Cyanide wastes are often generated together with metals in several industrial processes, including extraction of ore, processing of photographic material, and

APPENDIX A TYPES AND SOURCES OF HAZARDOUS WASPE: A BRIEF mRODUCTlON 93

metal finishing. In metal finishing, cyanide is used to hold zinc and cadmium in solution during electroplating and as a component in stripping solutions.

Organic solvents are widely used (about one billion metric tons of halogenated organic solvents per year) by a variety of industries in the U.S. And, as we pointed out in an earlier section, they are one of the principle contributors to contamination of groundwater in the state. With this in mind we will focus, for the rest of this discussion, on the use of organic solvents in California.

~

A CLOSER LOOK-ORGANIC SOLVENT WASTE STREAMS IN CALIFORNIA INDUSTRY

Because of their wide use, high toxicity, and restrictions on treatment and disposal, the halogenated organic solvents are excellent candidates for waste minimization. Much attention has been given recently to reducing their use and increasing their recyclability.

Types Of Commonly Used Organic Solvents In industrial parlance a solvent is a substance used as a dissolving agent. A number of inorganic solvents exist but the most widely used industrial solvents (other than water) are organics. Some examples:

Halogenated organlc solvents

w trichloroethylene (TCE)

w perchloroethylene (PERC)

w 1 ,l,l-trichloroethane (TCA)

w carbon tetrachloride

w methylene chloride (METH)

w CFC-113

Non-halogenated organic solvents

xylene

w toluene

w acetone

w ethyl acetate

cyclohexane

w methanol (& other alcohols)

Processes That Use Organic Solvents Solvents are commonly used In these operations:

w Dry cleaning

w Cold cleaning

w Solvent extraction

w Vapor degreasing

94 WASTE MlNIMlZATION: AN INTRODUCl'lON

Solvents are also used in the production of:

Coatings

m Stains

Wood-treatment Chemicals

Printing inks

Pesticides

Agricultural chemicals

Polyurethane foam

Chemical formulations

Pharmaceutical f ormu tat ions

They are also used as Inert reaction media In:

In some of these processes solvents are incorporated into the product, for example in manufacture of printing ink or formulation of surface coatings. In others, such as, degreasing of metal parts, the use of the solvent is confined to the cleaning process and the solvent becomes spent as it picks up oil and grease from the metal parts.

Major Solvent-Generating Industries And Processes In California The industries and processes generating the greatest volume of organic solvent waste have been identified through analysis of hazardous waste manifests and other sources of data (DHS, Oct.1986). This information can be useful in selecting industries for which waste minimization efforts could achieve a significant reduction in output in a relatively short time. The industries and processes in California that generate large volumes of organic solvents are reviewed briefly below.

Paint, varnish, lacquer 8 enamel manufacturing. The paint manufacturing industry was the highest volume generator of all California industries in 1984. Solvents are used as carriers for resins and to clean the formulating equipment between batches.

The wastes disposed of offsite were in the form of unspecified mixtures of solvents, paint sludges or halogenated organics.

If solvents are distilled and recycled a sludge residue forms which may also be contaminated with toxic metals, such as mercury, chromium and lead.

Manufacture of semiconductors 81 related devices generates large volumes of unspecified mixtures of solvent waste and paint sludges. The solvents are used during the etching of silicon wafers. Rinsing of wafers generates large volumes of low concentration waste.

Use of pollution control devices to capture volatile organic compounds (VOCs) results in an additional quantity of solvent waste for most facilities. Of the 237 establishments in the state, 127 are in Santa Clara County (“Silicon Valley”).

APPENDIX A TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF IAV‘RODUCIION 95

Manufacture of electronlc components and accessories, such as printed circuit boards, receiving antennas, switches, magnetic recording tape, ceramic capacitors, and other electronic components, generates halogenated and unspecified mixtures of solvents. These wastes often contain toxic metal contaminants. There are over 1,000 facilities manufacturing electronic components in California.

Manufacturers of automoblles and aircraft use solvents primarily in surface coating operations and degreasing of metal parts. VOC emissions from these processes require air pollution control devices at most facilities.

U.S. Defense Department Installations in the state generate large volumes of waste solvent primarily through building, equipment, and vehicle maintenance operat ions.

Solvent reclamation facilities generate halogenated organic still bottoms, which are residues from distillation of halogenated solvent wastes.

Other large volume solvent generators include: petroleum refineries, industrial organic chemical manufacturers, and manufacturers of pesticides, agricultural chemicals, and printing inks.

96 WASTE MMIMIZATION: AN INTRODUCTION

The table below summarizes solvent use in common industrial operations:

Table A-5 SOLVENT USE-INTENSIVE OPERATIONS (Adapred from DHS, Ocr. 1986)

Operation Type

Industry Cleaning 1 parts

Solvent Redamati I coatings Manufacturing I cYdicCompoundsa Intermediates I Industrial Organic Chemicals Mfg.

Pesticides a Ag. Chem. Formulation

Inks Manufacturing

Chemicals Preparations

Petroleum Refining

Semiconductors Mfg. I

Electronic Components Manufacturing I

Motor Vehicles Mfg.

Dry Cleaning I Automobile Service . Pharmaceuticals Mfg.

Metal Furniture hnuf. I I p ~

Photo Processiing

Reaction Entrainer Extraction f 1 &% 1 Medium 1 A z e o ~ I Me; Application Distillation

I I

I B I I B I I B I

APPENDIXA TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF INTRODUCTION 97

98 WASTE MINIMIZATKIN: AN INTRODUCUON

APPENDIX A

TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF INTRODUCTION I

SELF-TESTING EXERCISE Insttuctions: Read through each question carefully and write your answer on a separate sheet of paper. After completing the self-test check your answer to each question by rereading the corresponding section of the appendix.

Questions:

A.l Look again at the two hazardous waste classification systems that were presented in Tables A-1 and A-2. List two advantages and two limitations for each of the two schemes.

Optional Question: Drawing from your training and experience, present a system for classifying waste streams that would be most useful for small generators in doing preliminary evaluation of their waste generating processes.

A.2 List the three most common types of waste produced by the small industries listed in Table A.4.

A.3 Name three types of acids generated in metal plating processes.

A.4 Name three types of metals generated in metal plating processes.

A. 5 Identify five industrial sources of acid and metal waste in addition to metal plating processes.

APPENDIX A TYPES AND SOURCES OF HAZARDOUS WASTE: A BRIEF I ~ R O D U ~ I O N 99

A.6 List three industrial processes that generate cyanide waste.

A.7 What is a halogenated organic compound? (This was not defined in the text.)

A.8 Halogenated organic solvents are prime targets for waste minimization efforts at both State and federal levels. Present a rationale for this in terms of each of the following:

1) Public health

2) Worker safety

3) Environmental degradation

A.9 For each of the compounds listed below indicate which of the types of solvent listed on the right would apply:

A. Perchloroethylene (PERC)

B. Ethyl acetate

C. Sulfuric acid

D. 1,1,1 -trichloroethane (TCA)

E. Carbon tetrachloride

F. Toluene Halogenated Organic Solvent

Non-Halogenated Organic Solvent G. Cyclohexane

H Methylene chloride (METH) Neither

1. Chlordane

J. CFC-113

K. Trichloroethylene (TCE)

L. Ethanol

M. Xylene

N. Acetone

100

A.10 Name three operations that commonly use organic solvents.

A . l l For each of the industries and operations listed below identify

1) What solvents are used for and 2) The nature of the solvent waste stream generated.

(Use the waste categories presented in either Table A-1 or A-2.)

A. Solvent reclamation

B. Defense Department installations

C. Manufacture of semiconductors

D. Manufacture of aircraft

E. Manufacture of automobiles

F. Manufacture of electronic components & accessories

G. Dry cleaning

H. Paint manufacturing

A.12 Identify the two or three large industrial operations in your geographic area that generate hazardous wastes in the greatest quantity or at the highest risk.

Do the same for 5 small operations. Utilize whatever resources are available to you to answer these questions.


\


APPENDIX B SB 14 HAZARDOUS.. . ACT

Senate Bill No. 14

CHAPTER 1218

An act to add Article 11.9 (commencing with Section 25244.12) to Chapter 6.5 of Division W, of the Health and Safety Code, relatina to hazardous waste.

[Approved by Governor October 1. lm. Filed with sccretpry of State October 1. I=.]

LEGISLATIYE COUNSELS D I G W SB 14, Roberti. Hazardous waste reduction. (1) Under existing law, every geqerator of hazardous wastes is

required to submit a report to the State Department of Health Services at least once every 2 years concerning changes in waste volume and toxicity achieved through waste reduction. Under existing law, the money in the Hazardous Waste Control Account in the General Fund may be expended by the department, upon appropriation by the Legislature, to carry out the hazardous waste control law.

This bill would enact the Hazardous Waste Reduction and Management Review Act of 1989, which would require the department to adopt a format to be used by generators by Jarmary 1,1991, and to establish a technical and research assistance program to assist hazardous waste generators in reducing hazardous waste.

The bill would require each generator of hazardous waste, as spe&ed, on or before September 1, 1991, and every 4 years thereafter, to complete and conduct a source evaluation review and plan and a source evaluation review and plan summary specifying sou~ce reduction measures which will be implemented by the generator. The bill would require each generator to certify that the plan will be implemented. The bill would also require each generator of hazardous waste, on or before September 1,1991, and every 4 years thereafter, to prepare a hazardous waste management performance report and a hazardous waste management performance report summary concerning the hazardous waste management approaches implemented by the generator. The bill would require the department to select at least 2

categories of generators on or before September 1,1992, and every 2 years thereafter, for +ed enforcement activities. The bill would also authorize the department, on and after September 15, 1991, to require a generator to provide the department with a copy of the generator's review and plan. plan summary, report, or report summary, within 30 days after the request of the department. The department would be required to take specified enforcement actions to require the completion of the review and plan, plan summary, report, or report summary and wouid be authorized to take S = - l t q r

APPENDlX B SB14 HAZARDOUS. . .ACT 103

(=h. 1218 -2-

enforcement actions to require the implementation of the review and plan or plan summary. The bill would require the State Director of Health Services to

submit a report to the Governor and the Legislature commencing July 1,1993, and once every other year thereafter, concerning the implementation of the act and would require the Auditor General to submit a report by December 1.1993, assessing the department’s performance in the implementation of the act. The bill would also establish procedures for the protection of trade secrets.

The bill would require the department to adopt, by regulption, on or before January 1,19991, a system for charging and collecting a fee from generators subject to the act, set in an amount sufficient to produce revenues to implement the act and would authorize the department to set the fees at a level to repay the Hazardous Waste Control Account for the initial costs of implementing the act. The fees would be required to be paid by September 1,1991, and to be deposited in the Hazardous Waste Control Account in the General Fund, for expenditure by the department, upon appropriation by the Legislature, to carry out the act.

(2) The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement. This bill would impose a state-mandated local program by creating

new crimes concerning the generation of hazardous waste. The bill would provide that no reimbursement is required by this

act for a specified reason.

The people of the State of California do enact ns follows:

SECTION 1. Article 11.9 (commencing with Section 25244.12) is added to Chapter 6.5 of Division 20 of the Health and Safety Code, to read:

-3- a. 1418 required to be made if theae goals are to be achieved.

(b) It b the g d ofthis article to do all ofthe following: (1) Reduce the generation of bazardous waste. (2) Reduce the release into the environment of cbemid

contaminants which have adverse and seriow health or environlnental ef€e€ts.

(3) Document hazardous waste “gemen t information and d e that information available to state and local government.

(c) It is the intent of this article to promote the reduction of hazardous waste at its source, and wherever source reduction is not feasible or practicable, to encourage recycling. Where it is not feasible to reduce or recycle hazardous waste, the waste should be treated in an environmentally safe manner to minimize the present and future threat to health and the environment.

(d) It is the intent of the Legislature not to preclude the regulation of environmentally harmful releases to all media, including air, b d , surface water, and groundwater, and to encourage and promote the reduction of these releases to air, land, surface water, and groundwater.

(e) It is the intent of the Legislature to encourage all state d e m e n t s and agencies, especially the State Water Resources Control Board? the California regional water quality control boards, the State Air Resources Board, the air pollution control districts, and the air quality management districts, to promote the reduction of environmentally harmful releases to all media

25244.14. For purposes of this article, the following definitions apply:

(a) “Appropriate local agency” means a county, city, or regional Bssociation which has adopted a hazardous waste management plan pursuant to Article 3.5 (commencing with Section 251%).

(b) “Hazprdous waste management approaches” means approaches, methods, and techniques of managing the generation and handling of hazardous waste, including source reduction, recycling? and the treatment of hazardous waste.

(c) “Hazardous waste management performance report” or “report” means the report required by subdivision (b) of Section 35344.20 to document and evaluate the results of hazardous waste management practices.

(d) “Hazardous waste management ped~i-~~~pnce report summary” or *‘report ~ummary” means the summary required by subdivision (c) of Section eSerre0.

(e) (1) ”Source reduction” means one of the f o l l o m (A) Any action which causes a net reduction in the generation of

huardous waste. (B) Any action taken before the hazardous waste is generated

that r d t s in a 1- of the properties which cause it to be clnssified as a hazprdous waste.

(2) “Source reduction” includes, but is not limited to, all of the

Article 11.9. Hazardous Waste Source Reduction and Management Review Act of 1989

25244.12. This article shall be known and may be cited as the Hazardous Waste Source Reduction and Management Review Act of 1988.

25244.13. -The Legislature finds and declares as follows (a) Wting law requires the department and the State Water

Resources Control Board to promote the reduction of generated hazardous waste. This policy, in combination with hazardous waste land disposal bans. requires the rapid development of new programs und incentives for achieving the god of oprirnal minimization of the generation of hazardous wastes. Substantial improvements and additions to the state’s hazardous waste reduction program are

Ch. 1818 -4-

fdlowing: (A) “Input change” which means a change in raw materials or

lkabtocks wed in a production procszls or opqration so as to reduce, avoid, or eliminate the generation of hazarddus waste. (B) “Operational improvement” which means improved site

management so as to reduce, avoid, or eliminate the generation of hazardous waste.

(C) “Production process change” which means a change in a proceqs, method, or technique wbich is u96d to produce a product or a desired result, including the return of materials or their components. for reuse within the existing processes or operations, so as to reduce, avoid, or eliminate the generation of hazardous waste. (D) “Product reformulation” which means changes in design,

composition, or specifications of end products, including product substitution, so as to reduce, avoid, or eliminate the generation of hazardous waste.

(3) “Source reduction” does not include MY of the following: (A) Actions taken after a hazardous waste i s generated. (B) Actions that merely concentrate the constituents of a

hazardous waste to reduce its volume or that dilute the hazardous waste to reduce its hazardous characteristics.

(C) Actions that merely shift hazardous wastes from one environmental medium to another environmental medium. (D) Treatment. ( f ) “Source reduction evaluation review and plan” or “review and

plan” means a review conducted by the generator of the processes, operations, and procedures in use at a generator’s site, according to the format established by the department pursuant to subdivision (a) of Section 25244.16, and which does both of the following: (1) Determines MY alternatives to, or modifications of, the

generator’s processes, operations, and procedures that may be implemented to reduce the amount of hazardous waste generated.

(2) Includes a plan to document and implement source reduction measures for the hazardous wastes specified in paragraph (1) which are technically feasible and economically practicable for the generator, including a reasonable implementation schedule.

(g) “Source reduction evaluation review and plan summary” or ”plan “nary” means the summary required by subdivision (c) of Section eSerr.19.

(h) “SIC code” has the same meaning as defined in Section e5501. (i) “Hazardous waste,” “person,” “recycle,” and “treatment”

have the same meaning as defined in Article 2 (commencing with Section 25110). 5%944.15. (a) The department shall establish a program for

hazerdous waste source reduction pursuant to this article. (b) The department shall coordinate the activities of all state

agencies with responsibilities and duties relating to hazardous waste and shall promote coordinated efforts to encourage the reduction of

- 5 - Ch. 1818

hazardous waste. Coordination betweam the program and 0th relevant state agencies and program shall, to the fulkst extent possible, include joint planning processss and joint research and studies.

fc) The department shall adopt regulations to carry out this article.

(d) (1) This article applies only to generators who, by dte, routinely generate, through ongoing proceslles and operations, more than 12,,oOO kilograms of hazardous waste in a calendar yenr, or more than 12 kilograms of extremely hazardous waste in a calendar year.

(2) The department shall adopt regulations to establish procedures for exempting generators from the requiremenb of this article where the department determines that no source reduction opportunities exist for the generator. 25244.16. On or before January 1,1991, the department shall do

both of the following: (a) Adopt a format to be used by generators for completing the

review and plan and plan s u m m a r y required by Section W244.19, and the report and the report summary required by Section 35344.20. The format shall include at least all of the factors the generator is required to include in the review and plan, the plan summary, the report, and the report summary. The department may include any other factor determined by the department to be necessBfy to carry out this article. The adoption of a format pursuant to this subdivision is not subject to Chapter 3.5 (commencing with Section 11340) of Part 1 of Division 3 of Title 2 of the Government Code.

(b) Establish a data and information system to be used by the department for developing the categories of generators specified in Section 25244.18, for processing and evaluating the source reduction and other hazardous waste management information submitted by generators pursuant to Section 25244.18, and for developing the program evaluation required by Section 25244.22 In establishing the data and information system, the department shall do all of the following: (1) Establish methods and procedures for appropriately

processing or managing hazardous waste source reduction and management information.

(2) Use the data manngement expertise, resources, and forms of already established environmental protection programs, to the extent practicable.

(3) Establish computerized data retrieval and data processing systems, including safeguards to protect trade secrets designated pursuant to Section 35344.23.

(4) Identify additional data and information needs of the PTOgTalll. f

2W4.17. The department shall establish a technical and research assistance program to assist generators in identifying and applying methods of source reduction end other hazardous waste

al. lele -6-

"ngemen t appnwches.Theproenm shdemphukerrdrhrrs to

IWOWWJ for o b b h i q idormath, r#.*inn "e reduction methods, and developing and applying source d M o n techniques. The program shall include at least dl of tbe following elements, which shall be carried out by the department:

(a) The department shall encourage progr~ls by private or public consultants, including onslte consultation at titea or l d o m where hazardous waste is generated, to aid thore generaton requiring assistance in developing and implementing the review and plan, the plan summpty, the report, and the report summary required by this article.

(b) The department shall conduct review .and plan cusbtance programs, seminars, workshops, t dnhg programs, and other similar activities to assist generators to evaluate source reduction alternatives and to identify opportunities for source reduction.

(c) The department shall establish a program to assemble, catalogue, and disseminate information about hazardous waste source reduction methods, available consultant services, and regulatory requirements.

(d) The department shall identify the range of generic and specific technical solutions that can be applied by particular types of hazardous waste generators to reduce hazardous waste generation.

(a) On or before September 15, 1991, and every two years thereafter, the department shall select at least two categories of generators by SIC Code with potential for source reduction, and, for each category, shall do all of the following: (1) Request that selected generators in the category provide the

department, on a timely basis, with a copy of the generator's completed review and plan, or plan summary, or both, and with a copy of the generator's completed report, or report summary, or both.

(2) Examine the review and plan or plan summary and the report or report summary of selected generators in the category.

(3) Ensure that the selected generators in that category comply with Sections 25244.19 and 25244.20.

(4) identify successful source reduction and other hazardous waste management approaches employed by generators in the category and disseminate information concerning those approaches to generators within the category.

(b) In carrying out subdivision (a), the department shall not disseminate information determined to be a trade secret pursuant to Section %M.e3.

(e) On and after September 15,1991. the department may request from any generator, and the generator shall provide within 30 days of the request, a copy of the generator's review and plan, plan rwnmary. report, or report summary. ntc deputment may evaluate any of these documents submitted to the department to determine

lllyuct bushmestbat haw iludequata t echn iddzhunrr ir l

25344.18.

-7- a. la8 whetbbr it satisfies the requirements of this article.

(d) If the dqwtment detarminsr that a generatoo hr llot complsted the review and pLn or plan in the a"r required by Section 25W4.19, or the report or report summary in the manner required by Section 25M.20, the department rhpll provide the generator with a notice of noncompliance, spedfyins the deficiencies in the review and plan, plan summary, report, or report summary identified by the department. If the de-nt findr that the review and plan does not comply with Section 2SM.19. the department shall consider the review and plan to be incomplete. A generator shall file a r e v i d review and plan, plan summary, report, or report summary correcting the deficiencies identified by the department within 60 days of the receipt of the notice. The department may grant, in response to a written request from the generator, an extension of the W a y deadline, for cause, except that the department shall not grant this extension for more than an additional 60 days.

If a generator fails to submit a revised review and plan, plan summary, report, or report s u m m a r y complying with the requirements of this article within the required period, or if the department determines that a generator has failed to implement the measures included in the generator's review and plan or plan summary for reducing the generator's hazardous waste, in accordance with Section 25244.19, except as provided in subdivision (e), the department may impose civil penalties pursuant to Section 25189.3, in an amount not to exceed one thousand dollars ($l,OOO) for each day the violation of this article continues, notwithstanding Section e5189.2, seek an order directing compliance pursuant to Section 25181, or enter into a consent agreement or a compliwce schedule with the generator.

(e) if a generator fails to implement a measure specified in the review and plan, or plan summary, pursuant to paragraph (5) of subdivision (b) of Section 25244.19, the generator shall not be deemed to be in violation of Section 25244.19 for not implementing the selected measure if the generator does both of the following:

(1) The generator finds that, upon further analysis or.as a result of unexpected consequences, the selected measure is not technically feasible or economically practicable. or if the selected approach has resulted in any of the following:

contaminaqts to other media.

human health or the environment.

to comply with the requirements of Section 25244.19.

(A) An increase in the generation of hazardous waste.. (B) An increase in the release of hazardous chemical

(C) Adverse impacts on product quality. (D) A significant increase in the risk of an adverse impact to

(2) The generator revises the review and plan and plan summary

(r) When taking enforcement pctipn pursuant to this article, the

Y b o\

I i l

Ch. 1318 -8-

deputment t h d nat judge the .pptoptiatenerr of MY dcclsions or propo#d mepsures contained in a review and plan, plan "unary, report, or report s u m m ~ ~ y , but shpll only determine whether the raylsw and p h , p h ban"y, report. or report sumrmvy is coin ete, prepared, and implemented in accordance with thie

3 fg) On and after September W, 1991. an appropriate local agenay which has jurisdiction over a generator's site may request from the generator. and the genetator shnll provide within 30 days, a copy of the generatar's currGat review and p h , plan summary, report, and report

WZ44.19. (a) On or before September 1, 1991, and every four years thereafter, each generator shall conduct a source reduction evduation review and plan and a source reduction evaluation review and plan summary pursuant to subdivisions (b) and (e).

(b) Except as provided in subdivision (d), the source reduction evaluation review and plan required by subdivision (a) shall be dmducted and completed for each site pursuant to the format adopted pursuant to subdivision (a) of Section 25244.16 and shall in&&, at a " m , , e l l of the following:

(1) The name and location of the site.

I" 3) ldentiflcation of all routinely generated hazardous waste $tteams which result from ongoing processes or operations that have a yearly volume exceeding 3 percent of the total yearly volume of b d o u s &e generated at the site, or, for extremely hazardous

ertic t . .,-

) The SIC Code of the site.

-9- Q Il18

toward8 &plementah of the #bcQd ratrcrs f e h c t h RIyIrm

rrpedfisd in P-F& (6).

required by ruwtvidolr (a) rhnbecompbted in r##dmoswi theformatadoptedpurruMttonrbdivtion(a)dSectloll068CCiQ a n d s h n l l i n d u d e t h e ~ (I), @ ) a ( 3 ) , d (6) of r e q d -t to (4) (5) af" (b).

p-, operations# and wa8te 8treunq the g " t o r 4uy pspge

(8) (e). ( c ) ~ ~ r e d u c t b n ~ r e v b w d p L n 7

(b) * ~ o f t b e i n s a m r l s c a

T

(d) If a generator owna or operabs mulbipb dta witb .hnlLr

a single mdtisite review and plpa and plan nmuaupr &maim# rll of these sites.

pursuant to this section shall be submitted by the review and certification by M engineer who ia rsgirtsred w a professional engineer pursuant to ssction ot the Budnsr .ad Professions Code and who haa d e " t e d srpsrtirs in htrrQU0 waste management, by an individual who ia rsrpmribb far the procespes and operations of the site, or by an en-td lyy~ who is registered p l l " t to sation m.3 .Dd wba ho demonstrated expertise in hazardous waste "e&. Tbe engineer. individual, or environmentpi a"r rhn the review and plan and plan summary o d y if the revlsrv .ad p h d plan summary meet all o f t b fdbwine requirssrrsnb:

(1) The review and plan a d d " each h.urdoucwrrtsrtr#m identified pursurnt to parapph (3) of d d i v W o o (b).

(2) The review and plan pddrss#s the -n approaches SpeCiRed in subparagraph (B) aC PurCPyPb (4) of subdivision (b) .

(3) The review and plan clearly mta forth tbs" to be taken with respect to each hazrwlwswaste stream for w M c h m " reduction hss been found to be technicplly fhdb& d e c a o d d y practicable, with timetables for making reamnabb and "hie progress, and properly documents the r a t i d for rqbthg available source reduction measures.

(4) The plan summary meets the requkwmnts ofsubdividon c)

hazardous waste from one envhmmentd medium to another environmental medium by in"hg e" or dbcbga to air, water, or land.

(f) At the time a review and plan or a p h a m ~ u y i r n r b m i t t a d to the department, the generator shall certify tht the g e x ~ & ~ hr impIemented;ia implemen or will be implementing, tbe "e

the review and plan or the plpn -. A #y determine not to imphemt a "re d o c t d in purgrph (W'd

(e) Every review and plan and plan a"ry

(5) The review a d plan and plan rummorydoar not merely Ibw

r e d w i o n m ~ e a i d e n t i f i 2 inthereviswandpLIIorthephn ~ o c c o r d i n e t o t 4 e ~ - - ~ t a

b 3

waste, 5 percent of the total yearly volume generated at the site. (4) For each hazardous waste strerun identified in paragraph (3),

the review and plan shall include all of the following information: (A) An estimate of the quantity of hazardous waste generated. (B) An evaluatibn bf source reduction approaches available to the

generator which are potentially viable. The evaluation shall consider at leest all of the following source reduction approaches:

ti) Input change. (a) Operational improvement. (iii) Production process change. iv) Product reformuiation. - 1 5 ) A specification of, and a rationale for, the technically feasible

and economically predicable source reduction measures which will be taken by the generator with respect to each hazardous waste stream identified in paragraph (3). The review and plan shall fully document any statement explnining the generator's ,rationale for rejecting any available sou- reduction approach identified in W P h (4). 1 . 1

* '(6) An evaluation, and, to the extent practicable. a quantification, addre &ktcts of the chosen source reduction method on emissions ~ K I didurges to air, water, or land. '. &f7) 'A tlmetaMe fot m&king reasonable and measurable progjrtys

w 0 U

Q 1818 - 10-

-(b)onlyifhfP--detarmuwr, a uponcoaductine hrtk analysis or due to Ctrmmrbacer, that the *" is nat technicrlly feadble or ecaromlcrlly prrrticrbb. or if attempts to im-t that mea" r e v d t h t the n" would d t b, hU l d t d b, My ofthe fouowhg:

(1) An increme in the generation of hazardwa waste. (2) An - in the roleme of bazardoua chemic& to other

envinWment.lmsdt0. (3) Adverse impacts on product quality. (4) A rjsnificont increme in the risk of an dverae impact to

human health or the environment. (g) If tbe generator elects not to implement the review and plan

or plan summary, including, but not limited to, a selected measure pursuant to subdivision (f) , the generator shall amend ib review and plen and plan summary to reflect this rejection and include in the review and plan and plan summary proper documentation identifying the rationale for this rejection.

85241.20. (a) On or before September 1, 1991. and every four yean thereafter, each generator shall prepare a hazardous waste management performance report and a hazardous waste management performance report sum- documenting hazardous waste "qement approaches implemented by the generator.

(b) Except as provided in subdivision (e), the bardous waste management performance report required by subdivision (a) shall be prepared for each site in accordance with the format adopted pursuant to subdivision (a) of Section 25244.16 and shall include all of the following:

(1) The name and location of the site. (2) The SIC Code for the site. (3) All of the following information for each waste stream

identified punuant to paragraph (3) of subdivision (b) of Section SM4.19: (A) An estimate of the quantity of hazardous waste generated and

the quantity of hazardous waste managed, both onsite and offsite, during the current reporting year and the baseline year, as specified in suMivieion (d) . (B) An acsessment of the effect, during the current year, of each

hazardous waste management measure implemented since the baseline year, upon the generation and the onsite and ofkite management of hazardous waste. The report shall consider, but shall not be limited to, measures which use all ofthe following approaches:

(i) Source reduction. (ii) Recycling. (iii) Treatment. (C) A description offactors during the current reporting year that

have afFected hazardous waste generation and onsite and offsite hazardous waste management since the baseline year, including, but not lirnrited to, any of the following:

-11- a. 1p18 (0 QmPh--tY. (ii) ChngeBhrndedrrlticrtka. (W N u - (iv) Other f.cton th.t k e * & the quantity of

b.Eudaur wsste gsnanted or ondta and c&ke b.t9rdaur waste " g a m r m t "ts.

(4) The certUicatim ofthe report punwnt to RIwkrLion (f). (c) The hazardous waste " g a m m t p"mm report

summary required by subdivision (a) shall be campletod in axordance with the format adopted punnmnt to subdivtron (a) of Section M . 1 6 , shrrll provide the informotion -'in paragraphs (1) and (2) of suMvlsion (b), and a smnmpry of the iufonnation required by paragraph (3) of subdivision (b), and shall be certified pursuant to subdivision (f).

(d) For purposes of subdivision (b), the following definitions apply:

(1) The current reporting yepr is the calendar yenr immediately preceding the year in which the report is to tre prepared.

(2) The baseline year is either of the following, whichaver is applicable: (A) For tha initial report, the baaeline year is the dmdar year

selected by the generator for which m b t i a l hazudous waste generation, or onsite or offsite -ement data is available, prior to 1991, except the generator may select lee0 an the baseline year. If the generator selects 1990 as the b r r s e b year for the initial report, the information re@ired pursuant to paragraph (3) of subdivision (b) for the initial report shall be provided for the 1980 calendar year only. (B) For all subsequent reports, the besaliac year is the current

reporting year of the immediately preceding teport. (e) If a generator owns or operates multiple dtes wjth sianilar

proceasa, operations, and waste streams, the geaerator may prepare a single mdtisite report nnd report summary ddresshg all of these sites.

(f) Every report and report summary oampleted pursuant to this =tion shall be submitted by the generator for review and certification by an engineer who is registered u a pmfeasional engineer pursuant t~ section 8762 of the Eku$less and Rofssaions Code and who has -mated expmth~ in howdour waste managememt, by M individual whb is respondMe for the proce~ses and opentlons of the site, or by an en-tal who is registered pursupnt to sccrion !255'70.3 and who has demonmated expertise in hazardow waste management. The -, individupI. or environmental assessor shall certify the rsgort red toport

(1) Thereportidentifiemkctanthat~lthsganantrwmbd

rummory only if the tepart and "rt )d"rymeet all M the

onsite d & t e managpnent o f b " J wwaad-

. I following r e q u i r m B , lb appk6bbr - 5 t ' *

cr 0 00

L 2

m m

0.1918 -12- -13- Q m rummuy, report, or rsport ~fmmuy. Solob kx tbs prppbia 6f

to a requsrt plrrurnt to tbb dnWdoa, tbedspatodat

summery to be a public record subject to ssction eS T-3s 6U.d act in c0mP)iance with that rection.

thereafter, the director shall prepare and " i t to tbe caverbior and the Legislature a report of the dsp.rtmszlt'a q" m a d activities in CBflYing out this article. "he dirrrctotmay Include tbis report within the report required under sectiOll811171. "b report shall include, but not be limited to, all of the Wlowirq W o n :

(a) An evaluation of the hazardous waste auurce roducth progress in the state.

(b) Recommendations for legislation. (c) Identification of any state, federal, or private economk and

financial incentives that can best accelernte and "iz+? the research and development of aource reduction md other t"a waste management technologiea and apprwches.

(a) The department shall adopt regulations to en" that trade secrets designated by a generator in all or a portioa M the review and plan, the plan summary. the report, or the report summary required by this article are utili@ by the dirsctar, the

responsibilities of the department pursuant to this article, pad &at thoae trade secrets are not otherwise dimeminated by the the department, or any authorized representative of the department, or the local agency, without the conaent of the generator. However, any information shall be made aMiLble to governmental agencies for use in making studias and fbt m in judicial review or enforcement proceedings involviq the petarn furnishing the information. As provided by Section SlS.5, the regulations ahall conform with the corresponding trade secret regulokions adopted by the Environmental Protection Agency pursuant to the Resource Conservation and Recovery Act of lW8, aa amended (42 U.S.C. Sec. 6601 et seq.), except that the regulations adopted b the department may be more stringent oc m&e extensive dan the federal trade secret regulations. 'Trade "b," as used in this section, may include, but are not limited to, + procedure, production data, or compilation of tnfarmotian which ir not patented, which is known d y to certnin in&* with a commercial concem who are using it to fkbricato,

and which gives its wer an opportunity to &ah & b&ness advantage over comptitora who do not know or use it.

(b) The department and the apprapiirte local ~ ~ B W Y rhll protect from disclosure any trade secret -ted by the generator

z!ii=- deem the review uxi p l ~ , pbn dmunuy,

2WM.B. Commencing July 1, 1983, and every other

(d) The status, fiinding, and results of all redeptch pro-. 25M.23.

department, or the local agency only in c o r " ' with the

formula, plan, pattem, process, tool, * "pounk

compound an article of trade or n service haw

m (A

9

&im effect of t h e fadoxu on the generation and onrlte and ofwre

(8) Ths rt summary compliea with the requirements

SB44.W. (a) Every generator shpll retain the original of the c\rrrsnt review nnd pks plan summpry, report. and report summary, &dl meiDtain a copy of the current review and plan, plan summary. report, and report summpry at each dte, or, tor a multiaite

ravhw central dE! and upon request, ahall make it available to any a u t b i d r e p " t a t i v e of the department conducting an inrpsction pursuant to stction 25185. If a generator fails, within five days, to d e available to the inspector the review and plan, plan "uy. report, or report "unary, the department or MY authorized representative of the department conducting an kupectron pursuant to Section 25185, shall, if appropriate, impose a

ty pursuaut to Section 25188.3, in an mount not to exceed ddc OD8 d dollan ($l,oOO) for each day the violation of this article continues, nohvithstanding Section !Bl89A

(b) If a generator faib to respond to a request for a copy of its review and pian, plan summary, report, or report summary made by tbedsprrtment pursuant to subdivision (c) of Section 25244.18, or by e M lylsnty pursurrnt to subdivision (8) of Section 25244.18, within 30 &g from the date of the request, the department shall, if .pproPriete, sssess a civil penalty pursuant to Section 25189.3, in an amount not to e x c e e d one thousand dollars ($I,OOO) for each day the vidrtlon af this article continues, notwithstanding Section 25189.2.

(c) Any persun m a y request the department to certify that a cpelrptor ia in compliance with this article by having the L t certify that the generator has properly completed the

review and pkn, plan summpty, report and report summary requited pursuant to Sections 25244.19 and 25244.20. The department ahaU respond within 60 days to a request for certification. Upon M v i n g a request for certification. the department shall request Cram the generator, which i s the subject of the request, a copy of the gmmrator's review and plan,.plan summary, report, and report SUUUIWY, pursuant to subdivmon (e) of Section 25244.19, if the dsputment does not have these documents. The department shall rorwud a copy of the review and plan, plan summary, report, and rsport to the person requesting certification, within 10 &ys after tbe deporhnent receives the request for certification or rodves the review and plan, plan summery. report, and report su"ry, whichever is later. The department shall prQtect trade

$n rrcordpna with Section Ma3 in a review and plan, r repoft, or report summary, requested to be releami pursuant to this aubdiviaion. Ti& Rlwivision does not prohibit any person from directly .

requswnS from a generator a copy of the review and plan, plan

" t o f W w u t s r .

qpedied in 3&dOn (c).

plln aunmary, report, or report su"9ry. at a

ow 14n

-15- Q 1818

(b) AUfssrodbctadpvsurnttotbLrsctiorrIhllbepaidtothe

in tbe Haadow Warts Control Account in the Gswrpl Fund, for

SEC 2. No rdmbumment Q required by thia act section 6 Article B ofthe cplifornto conrtitution EZttE only costs which m y be incurred by a local agency or schod dhbict will be incurred because this act createa a new crime or Mraetioon, changes the definition of a crime or infraction, changes the penalty for a crime or infraction, or eliminates a crime or infraction. Notwithstanding Section 17380 of the Government Code, unless otherwise specified in this act, the provisions of this act shall become operative on the same date that the act takes effect pursuant to the California Constitution.

d e g ” t m or bsfars septemsr 1,1991, md Ihll be Qporited

Legislature, to cany out thia article. by the daputment. upon rpproprktion by

+ + 0

E 2

Gh. 1818 -14-

pununt to thia saction. The d q ” m t shell unke available if&”- co“hg “8 rsductian .pprocrcber that hve paved m“di& od wbich do notconstitute a trade recrst, when cpnyfns out subdividon (c) of Section 85611.17 and to subdivision (a) of Section 25244.18.

(c) ‘IWa section does not permit .-tor tarshrse to disclose the fntormption ~ e d p u r s u u a t to this article to the &partmat or to the approprhtekud agency, except an oillam or employee of the department, or the -@date locpl agemy, in connection with the official dutios of tbpt dRcer or

(d) Any deer or employee ofthe depcuhneat or the appropriate l d agency, or any other person, who, because of his or her employment or o f R d podtion, has poasessian of, or has occesg to, confidential infonnotian, and Who, knowing that disclosure of the information to the general public is probibited by this section, knowingly and willfully discloses the information in MY manner to any person not entitled to receive it. is guilty of a d e m e a n o r and, upon conviction thereof, shall be punished by imprisonment in the county jail not exceeding six months, by a fine not exceeding one thousand d o h ($1,000), or by both the fine and imprisonment.

Z5244.M. On or before December 1,1993, the Auditor General shall submit a report to the Legislature, assessing the performance of the department in carrying out this article. The report shall include information on all of the following:

(a) The effectiveness of the source reduction evaluation reviews and plans in achieving a net reduction in the generation of hazardous waste. (b) Data on the frequency of requests for certification pursuant

to subdivision (c) of Section 25244.21, and an evaluation of the effectiveness and efficiency of this provision, including the department’s implementation, in providing timely information to the public.

(c) Data on regulatory and enforcement activities conducted by the department pursuant to Section 25344.18, and the effectiveness of this section, including the department’s implementation, in accomplishing compliance with this article.

(d) Data on the certification process required by Sections 25244.19 and esOCr.!40, and the effectiveness of this requirement in

reports, and report summaries. (a) On or before Jan- 1.1991, the depattment shall

adopt, by regulation, a fair and equitable system for charging and collecting a fee from hazardous waste generators subject to this article. The department shall set the fee in an amount suf€icient to poduce reventm to efliciently and ef€ectively implement this article, and may set the feea at a level sufficient to repay the IWardow Waate Control Account for the initial coats of impk” t ing this article.

under thia erticle.

guaranteeing the integrity of the review and plans, plan sununari a,

!U!HUS.

0

APPENDIX B SB14 HAZARDOUS.. . ACT 111

SB 14 DRAFT REGULATIONS #R-90-31

Title 22, Chapter 30, Article 6.1

Hazardous Waste Source Reduction and

Hanagement Review

The purpose of this article is to implement the Hazardous Waste Source Reduction and Management Review Act of 1989, commencing with section 25244.12 of the Health and Safety Code. The goals of this Act are to:

(1) Reduce the generation of hazardous waste at its source;

(2) Reduce the release into the environment of chemical contaminants which have adverse and serious health or environmental effects: and

(3) Document hazardous waste management information to be made available to the State and local government.

This article establishes a format to be used by generators to:

(1) Complete and conduct a source reduction evaluation review and plan and plan summary; and

(2) Prepare a hazardous waste management performance report and report summary.

This article also establishes:

(1) A list of hazardous waste streams which are not subject to review and are exempt from calculations of the volume, or comparable weight of hazardous waste produced by site.

(2) A procedure to protect trade secrets designated by a generator in the source reduction evaluation review and plan, the plan summary, the hazardous waste management performance report and the report summary.

Authority cited: Sections 208, 25150, 25244.15, Health and Safety Code.

Reference: Section 25244.12 et seq. of the Health and Safety Code.

1 November 8,1990

WASTE MINIMIZATION: AN INTRODUCTION 112

a .

66521 APDlicabllltv (a) This article applies to generators who, by site, routinely

generate, through ongoing processes and operations, more than 12,000 kilograms of hazardous waste in a calendar year, or more than 12 kilograms of extremely hazardous waste in a calendar year.

(b) A generator may petition the Department in writing to exempt -

a hazardous waste stream. The generator shall provide documentation to demonstrate that no source reduction opportunities exist for the requested waste stream exemption. The Department shall public notice the acceptance of any exemption petition. A minimum of 45 days shall be provided for public review and comment prior to the Department rendering any determination on a petition. Petitions with insufficient information to document that no source reduction opportunities exist, may be summarily rejected.

(c) The following hazardous wastes shall not be included in calculating the volume, or comparable weight of waste produced and are not subject to this article:

(1) Infectious waste.

(2)

(3) Samples and evidence from enforcement actions .

Waste from site cleanup and mitigation activities including remedial investigations.

(4) Asbestos.

( 5 ) PCBs.

(6) Formation fluids and solids from oil and gas exploration and field development.

(7) Automotive fluids.

(8) Lead acid batteries.

(9) Household hazardous wastes, wastes from household collection events and wastes separated at community landfills.

(10) Waste pesticides and pesticide containers collected by __ County agricultural commissioners. ~

(11) Demolition waste/major renovation waste.

(12) Waste generated from emergency response. -

2 November 8,1990 \

APPENDIX B SBl4 HAZARDOUS.. . ACT 113

(13) Spent munitions and ordnance

(d) A new generator who begins generating hazardous waste overthe threshold amount during the four years between reporting cycles shall conduct a source reduction evaluation review and plan and plan summary, and a hazardous waste management performance report and report summary by September 1 of the year following the next reporting year.

(e) When there is a change in ownership of the business, institution, or facility, the new owner shall have six months from the date of purchase to amend or rewrite the plan, the report and the summaries. If the new owner fails to revise the plan, report or summaries during this time, the existing plan, report and summaries shall remain in effect.

(f) When there is a change in the state or federal analysis and testing criteria which causes additional materials to be classified as hazardous waste, these newly classified hazardous wastes shall be considered in calculating the volume, or comparable weight of hazardous waste produced at the generator's site starting the next reporting year.

(9) Any generator that is a small business may complete a Department Hazardous Waste Audit Study Checklist as the plan, and plan summary if documents for that specific industry are available from the Department. The generator's most recent biennial report, as required by section 66493 can be used as the report and report summary required by this article.

(h) If a generator owns or operates multiple sites with similar processes, operations, and wastes the generator may prepare a single multisite review and plan, plan summary, report, and report summary addressing all of these sites.

If a generator owns a large site with multiple operations that are managed as independent businesses, the generator may prepare a separate review and plan, plan summary, report, and report summary for each independently managed business at the site.

(i)

Authority cited: Sections 208, 25150, 25244.15, and 25244.19, Health and Safety Code.

Reference: Sections 25244.15 and 25244.19, Health and Safety Code.

3 November 8,1990

WASTE MINIMIZATION: AN INTRODUCTION 114

For the purpose of this article, the following definitions shall apply:

llApplicable hazardous wastet1 means any hazardous waste, including extremely hazardous waste, subject to Health and Safety Code section 25244.19(b)(3) or this article section 66523.1(h). -

"Appropriate local agency" means a county, city, or local agency which has regulatory authority over the management of hazardous waste.

-

llAutomotive fluid" means fluid associated with operating motor vehicles such as transmission oil, hydraulic fluid, brake fluid, antifreeze, power steering fluid, gasoline etc.

"Baseline year" is the following:

(1) Except as provided in subsection (d)(Z) of this section, the baseline year is the reporting year of the immediately preceding four year report cycle.

( 2 ) For the reports to be completed by September 1, 1991 and for a new generator's first report, the baseline year is either the calendar year, selected by the generator, for which substantial hazardous waste generation and management data is available or the reporting year.

I1Concentrationt1 means the amount of a given substance in a stated unit of mixture, solution or waste. For purposes of this article it also means the range typically found in the waste.

t8Constituent11 or llhazardous waste constituentt1 means the principal constituent or constituents that causes the waste to be hazardous.

llHazardous waste management approaches" means approaches, methods, and techniques of managing the generation and handling of hazardous waste, including source reduction, recycling, and treatment of hazardous waste.

- *'Hazardous waste management performance reportm1 or llreportll means the report required by Health and Safety Code section 25244.20(a) to document and evaluate the results of hazardous waste management practices.

~

APPENDIX B SB14 HAZARDOUS.. . ACT

4 November 8,1990

115

(i ) tlHazardous waste management performance report summary1@ or "report summary" means the summary required by Health and Safety Code Section 25244.20(c).

@'New Generator1t means any of the following: (j)

(1) A newly constructed business, institution, facility or production line that begins generating hazardous waste or extremely hazardous waste over threshold amount as referenced in the Health and Safety Code Section 25244.15(d)(l).

( 2 ) An existingbusiness, institution, manufacturing facility or production line that, after January 1, 1991, begins generating hazardous waste or extremely hazardous waste over threshold amount as referenced in the Health and Safety Code section 25244.15(d)(l).

(k) "Reporting year" is the calendar year immediately preceding the year in which plans, reports, and summaries are to be prepared.

( 1) llRoutinely generatedtg means hazardous and extremely hazardous wastes that result annually from ongoing processes or operations pursuant to Health and Safety Code section 25244.19(b)(3). It shall also include hazardous wastes generated from regularly scheduled maintenance or production activities performed less frequently than annually.

(m) ltSmall businesst1 means ttsmall businessg1 as defined in Government Code, section 11342(e).

(n) (1) llSource reductiont8 means one of the following: (A) Any action which causes a net reduction in the

generation of hazardous waste. (B) Any action taken before the hazardous waste is

generated that results in lessening of the properties which cause it to be classified as a hazardous waste.

5

116

November 8,1990


(2) "Source reduction" includes, but is not limited to, all of the following: (A) @@Input change" which means a change in raw

materials or feedstocks used in a production process or operation so as to reduce, avoid, or eliminate the generation of hazardous waste. '@Operational improvementta which means improved site management so as to reduce, avoid, or eliminate the generation of hazardous waste. @@Production process change@@ which means a change in a process, method, or technique which is used to produce a product or a desired result, including the return of materials or their components, for reuse within the existing processes or operations, so as to reduce, avoid, or eliminate the generation of hazardous waste.

(D) #@Product reformulation" which means changes in design, composition, or specifications of end products, including product substitution, so as to reduce, avoid, or eliminate the generation of hazardous waste.

(B)

( C )

( 3 ) @@Source reduction1@ does not include any of the following: ( A ) Actions taken after a hazardous waste is generated. (B) Actions that merely concentrate the constituents of

a hazardous waste to reduce its volume, or comparable weight or that dilute the hazardous waste to reduce its hazardous characteristics. Actions that merely shift hazardous wastes from one environmental medium to another environmental medium.

(C)

(D) Treatment.

(0) @@Source reduction evaluation review and plan" or "review and plana@ or @@plan1@ means the report required by Health and Safety Code section 25244.19(a) to document and evaluate the results of hazardous waste management practices. It is a review conducted by the generator of the processes, operations, and procedures in use at a generator's site, which does both of the following:

(1) Determines any alternatives to, or modifications of, the generator's processes, operations, and procedures that may be implemented to reduce the amount of hazardous waste generated.

(2) Includes a plan to document and implement source reduction measures which are technically feasible and economically practicable for the generator, including a reasonable implementation schedule.

-

~

-

6 November 8,1990

117 APPENDIX B SBl4 HAZARDOUS.. . ACT

( p ) "Source reduction evaluation review and plan summary" or "plan summary" means the summary required by Health and Safety Code section 25244.19(c).

(9) "SIC Codel@ has the same meaning as defined in Health and Safety Code section 25501.

(r) "Hazardous waste", "person", Vecyclel@, and "treatmentn have the same meaning as defined in Article 2, commencing with Health and Safety Code section 25110.

(s) "Site" and nGeneratorn have the same meaning as defined in Article 9.1, Health and Safety Code section 25205.1.

Authority cited: Sections 208, 25150, 25244.14, 25244.15, 25244.19, and 25244.20, Health and Safety Code.

Reference: Sections 25110, 25135 et seq., 25244.14, and 25501, Health and Safety Code. Section 11342, Government Code

7

118

'November 8,1990


23 S W ~ ~

(a) on or before September 1, 1991 and every four years thereafter, each generator shall prepare a written source

pursuant to sections 66523.1 and 66523.2.

A copy of the plan and plan summary shall be kept at the site

Department or any appropriate local agency.

(c) A copy of the plan and plan summary, which excludes trade secret information, shall be made available locally for public review. This may be accomplished by making documents available at the generator's facility, at a public library or at the offices of any local governmental agency which is willing to act as a repository for this information. A copy of each document shall also be provided to the County Environmental Health Agency upon their request.

reduction evaluation review and plan, and plan summary -

and furnished upon request to representatives of the -

(b)

(d) Except as provided in sections 66521(h) and 66521(i), a source reduction evaluation review and plan, and plan summary shall be prepared for each site.

(e) A generator may determine not to implement a source reduction measure selected in section 66523.1(m) only if the generator determines, upon conducting further analysis or due to unexpected circumstances, that the selected measure is not technically feasible or economically practicable, or if attempts to implement that measure reveal that the measure would result in, or has resulted in, any of the following:

(1) An increase in the generation of hazardous waste.

(2) An increase in the release of hazardous chemicals to other environmental media.

( 3 )

( 4 )

Adverse impacts on product quality.

A significant increase in the risk of an adverse impact to human health or the environment.

8 November 8,1990

119 APPENDIXB SB14 HAZARDOUS.. .ACT

( f ) If the generator elects not to implement the plan, including, but not limited to, a measure selected pursuant to section 66523.1(m), the generator shall amend its plan and plan summary within 90 days to reflect this rejection and include in the plan and plan summary documentation identifying the rationale for this rejection.

Authority cited: Sections 208, 25150, and 25244.15, Health and Safety Code.


5 5 Except as provided in section 66521(g) each generator shall prepare a plan with sufficient detail to convey an understanding of the source reduction evaluation review and analysis performed, using narratives, photographs, illustrations, figures or data which includes, at a minimum, all of the following:

Name and location of the site.

Four digit SIC codes applicable to activities at the site.

Type of business or activity conducted at each site.

Length of time the company has been in business at the present site.

Major products manufactured or services provided and, if necessary to convey and understanding of the business, their general applications or examples of their applications or end use.

Number of employees.

A general description of site operations with corresponding block diagrams focusing on quantity and type of hazardous wastes, raw materials, and final products produced at the site.

120

9 November 8,1990

WASTE MUv'IMIZATlON: AN INTRODUCTlON

(h) Identification of all routinely generated hazardous waste streams which result from ongoing processes or operations that have a yearly volume, or comparable weight exceeding five percent of the total yearly volume, or comparable weight of

hazardous waste, five percent of the total yearly volume, or comparable weight generated at the site. Similar industrial processes or institutional activities generating similar wastes (with the same California Waste Codes) shall be considered a single waste stream for purposes of determining applicability.

(i) All of the following information for each hazardous waste stream identified in subsection (h) of this section:

hazardous waste generated at the site, or, for extremely -.

-

An estimate of the weight of hazardous waste generated. The applicable California waste code. The processes, operations and activities generating the waste(s), with corresponding block diagrams to illustrate the basis of generation. A description of any source reduction measures that were implemented in the previous reporting year. A listing and inventory of hazardous materials and quantities mandated by Health and Safety Code chapter 6.95 commencing with section 25500 that contribute to hazardous waste generation.

(j) An evaluation of source reduction measures available to the generator which are potentially viable. The evaluation shall consider at least all of the following approaches: (1) Input changes. (2) Operational improvement. (3) Production process changes. (4) Product reformulation. (5) Administrative steps taken to reduce hazardous waste

generation including but not limited to: A. Inventory control; B. Employee award programs; C. Employee training; D. In-house policies; E. Corporate or management commitment; and F. Other programs or measures.


10 November 8,1990

121

(k) Consideration of the following factors for each measure evaluated in accordance with subsection (j) of this section (where a specific factor does not apply identify as N/A): (1) Expected change in the amount of hazardous waste

generated; (2) Technical feasibility; (3) Economic evaluation:

A. Capital cost, operating cost, waste management cost:

8 . Return on investment (ROI), breakeven point, avoided cost, pretax payback period, or any other economic comparison method:

(4) Effects on product quality; (5) (6) Permits, variances, compliance schedules of applicable

(7) Releases and discharges.

Employee health and safety implications;

state local and federal agencies;

(1) Any pertinent information, such as waste stream constituents and concentration of constituents, needed to evaluate and implement source reduction measures.

(m) A specification of, and a rationale for, the technically feasible and economically practicable source reduction measures which will be implemented by the generator with respect to each hazardous waste stream identified in subsection (h) of this section. The specification should include at a minimum, a narrative description of the factors in subsection (k) of this section and also address system capacity and efficiency. Photographs, illustrations, figures or data should be used to convey an understanding of the source reduction measure in sufficient detail to allow transfer of the measure to other generators with similar processes or procedures.

(n) An evaluation, and, to the extent practicable, a quantification, of the effects of the chosen source reduction measure on emissions and discharges to air, water, or land.

( 0 ) A list of each measure considered but not selected for a detailed evaluation as a potentially viable source reduction measure. For each measure rejected, explain the generator's rationale. This list shall be supplemented for waste streams where no measures were identified with a narrative demonstrating the good faith efforts undertaken to identify measures.

i

i

122

11 November 8,1990

WASTE MlNlMlZATlON: AN INTROUUCl'fON

(p) A timetable for making reasonable and measurable progress towards implementing the selected source reduction measures specified in subsection (m) of this section. It shall also include an implementation schedule for completing the

it shall prioritize processes and wastes for future research, development and source reduction analysis.

evaluation of potentially viable source reduction measures and -



v of Source Reduct&Qxl Evaluation Review

Except as provided in section 66521(g) , the plan summary shall contain:

The generator's name, mailing address, site address, telephone number and EPA I.D. number and four digit S I C code(s).

A brief overview of the plan.

A summary of the information used for evaluation of each source reduction measure, required by section 66523.1(k).

A summary of the information required by section 66523.1(m) for the chosen alternative(s).

A summary of the information required by section 66523.1(0) for each rejected alternative.


12 November 8,1990

123

(g) A brief abstract for each source reduction measure to be implemented or those which have been implemented in the reporting year. Abstracts shall include the following components: (1) Quantity of waste: (2) Process or activity generating the waste: (3) Source reduction approach (e.g. input changes,

operational improvements, production process changes, product reformulations and administrative policies):

(4) Brief description of source reduction measure: (5) Brief economic overview, including capital and operating

and maintenance cost: (6) Estimated source reduction in terms of weight or the

properties which cause it to be classified as a hazardous waste:

(7) Barriers/obstacles: (8) Identification of discharge impacts to air, water, and/or

land, if any.


Reference: Section 25244.19, Health and Safety Code.

66523.3 Certification of Source Reduction Evaluation Review Plan * . - (a) The review and plan and plan summary conducted pursuant to

this article, shall be reviewed by an engineer who is registered as a professional engineer pursuant to section 6762 of the Business and Professions Code and who has demonstrated expertise in hazardous waste management, by an individual who is responsible for the processes and operations of the site, or by an environmental assessor who is registered pursuant to section 25570.3 and who has demonstrated expertise in hazardous waste management. The engineer, individual, or environmental assessor shall certify the review and plan and plan summary only if the review and plan and plan summary meet all of the following requirements:

(1) The review and plan addresses each hazardous waste stream identified pursuant to section 66523.1(h).

(2) The review and plan addresses the source reduction approaches specified in section 66523.1(j).

13

124

November 8,1990


( 3 ) The plan clearly sets forth the measures to be taken with respect to each hazardous waste stream for which source reduction has been found to be technically feasible and economically practicable, with timetables for making

documents the rationale for rejecting available source reduction measures.

reasonable and measurable progress, and properly -

(4) The plan summary meets the requirements of section 66523.2.

( 5 ) The plan does not merely shift hazardous waste from one environmental medium to another environmental medium by increasing emissions or discharges to air, water, or land .

(a) The plan and plan summary shall be signed and dated by a person who is capable of committing the financial resources necessary to implement the plan; either the owner, the operator, a responsible corporate officer of the site or an authorized individual and it shall contain the following language :

"1 certify that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or the persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for making false statements or representations to the Department, including the possibility of fines for criminal violations."

(c) At the time a plan or a plan summary is submitted to the Department, the generator shall certify that the generator has implemented, is implementing, or will be implementing, the source reduction measures selected in the plan according to the implementation schedule contained in the plan.

Authority cited: Sections 208, 25150, and 25244.15, Health and

Reference: Sections 25244.19 and 25570.3, Health and Safety

Safety Code.

Code. Section 6762, Business and Professions Code

14 November 8,1990

125

On or before September 1, 1991, and every four years thereafter, each generator shall prepare a hazardous waste management performance report and report summary pursuant to sections 66524.1 and 66524.2.

A copy of the hazardous waste management performance report and report summary shall be kept at the site and furnished upon request to representatives of) the Department or any appropriate local agency.

A copy of the report and report summary, which excludes trade secret information, shall be made available locally for public review. This may be accomplished by making documents available at the generator's facility, at a public library or at the offices of any local governmental agency which is willing to act as a repository for this information. A copy of each document shall also be provided to the County Environmental Health Agency.

Except as provided in sections 66521(h) and 66521(i), the hazardous waste management performance report and report summary shall be prepared for each site.

Authority cited: Sections 208, 25150, and 25244,15, Health and Safety Code.

Reference: Sections 25244.20, 25244.21, and 25244.23, Health and Safety Code.

66524.1 Ha= t o r t a e

(a) Except as provided in section 66521(g) and in subsection (b) of this section, each generator shall prepare a report with sufficient detail to convey an understanding of the hazardous waste management approaches used at the site, using narratives, photographs, illustrations, figures or data which includes, at a minimum, all of the following:

(1) Name and location of the site

(2) Four digit SIC code(s) for the site

I

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WASTE MMIMIZATION: AN lNTRODUCTION

(3) All of the following information for each waste stream identified pursuant to section 66523.1(h): ( A ) An estimate, in pounds, of the quantity of

hazardous waste generated and the quantity of hazardous waste managed, both onsite and offsite, during the current reporting year and the baseline year.

(e ) A description of current hazardous waste management approaches and identification of all approaches implemented since the baseline year.

(C) An assessment of the effect, since the baseline year, of each implemented hazardous waste - management approach on the weight of hazardous waste generated, the properties which cause it to be classified as a hazardous waste and/or the onsite and offsite management of hazardous waste. The report shall consider, but shall not be limited to all of the following approaches: 1. Source reduction: 2. In process reuse of materials: 3. Onsite or offsite recycling: . 4. Onsite or offsite treatment.

(D) A description of factors during the current reporting year that have affected hazardous waste generation and onsite and offsite hazardous waste management since the baseline year, including, but not limited to, any of the following: 1. Changes in business activity; 2. Changes in waste classification; 3. Natural phenomena; 4. Other factors that have affected either the

quantity of hazardous waste generated or onsite and offsite hazardous waste management requirements.

An assessment of the net effectiveness in terms of reducing weight of wastes going into land disposal.

If the generator selects the reporting year as the baseline year, the information required pursuant to subsection (a)(3) of this section shall be provided for the reporting year only.

-

-

(E)

(b)



Safety Code.

16 November 8,1990

127 APPENDIX E S E l l HAZARDOUS.. . ACT

Except as provided in section 66521(g), the report summary shall contain:

The name and location of the site

The four-digit SIC code(s) for the site

A summary of the information required by section 66524.1(a)(3).

Abstracts for each source reduction, recycling or treatment technology implemented from the baseline year through current reporting year, if reporting year is different from baseline year

Where changes in business activity significantly affect waste generation, a narrative description of the change and a brief assessment of the effect.

Net waste reduction achieved by site if reporting year is different from baseline year.



Safety Code.

(a) Every report and report summary completed pursuant to this section shall be submitted by the generator for review and certification by an engineer who is registered as a professional engineer pursuant to section 6762 of the Business and Professions Code and who has demonstrated expertise in hazardous waste management, by an individual who is responsible for the processes and operations of the site, or by an environmental assessor who is registered pursuant to section 25570.3 and who has demonstrated expertise in hazardous waste management. The engineer, individual, or environmental assessor shall certify the report and report summary only if the report summary meet all of the following requirements, as applicable:

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November 8,1990


(1) The report identifies factors that affect the generation and onsite and offsite management of hazardous wastes and summarizes the effect of those factors on the generation and onsite and offsite management of hazardous wastes.

(2) The report summary complies with the requirements -

specified in section 66524.2.

(b) The report and report summary shall contain the following -

language signed and dated by either the owner, the operator, or the responsible corporate officer of the site or an authorized individual; who is capable of committing financial resources necessary to implement the plan:

"1 certify that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or the persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware that there are significant penalties for making false statements or representations to the Department, including the possibility of fines for criminal vio1ations.I'

Authority Cited: Sections 208, 25150, 25244.15, and 25244.20,

Reference: Sections 25244.20 and 25570.3, Health and Safety

Health and Safety Code.

Code. Section 6762, Business and Professions Code

APPENDlX B SB14 HAZARDOUS.. . ACT

18 November 8,1990

129

c (a) Any information submitted to the Department pursuant to this

article may be claimed as confidential by the generator. Any such claim shall be asserted at the time of submission by placing the words stconfidential business informationst on each page containing such information. If no claim is made at the time of submission, the Department shall make the information available to the public without further notice. If a claim is asserted, the information shall be treated in accordance with 40 CFR part 2 and the Health and Safety Code, sections 25173 and 25244.23.

-

-

(b) Claims of confidentially for the name and address of any generator shall be denied.

(c) If a claim of confidentiality is asserted, two versions of the document shall be submitted: one version with the confidential pages and one version without the confidential pages but with a clear indication of which pages are removed as confidential.

Authority Cited: Sections 208, 25150, 25244.15, and 25244.23, Health and Safety Code.


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November 8,1990


ERRATA FOR REGULATION PACKAGE /R-90-31

1) Section 66523.2, page 12. The six subsections (a) through (9) are mislabeled omitting (d). They should be relabeled (a) through (f).

-

2) Section 66524(c) Should read: A copy of the report and report summary, which excludes trade secret information, shall be made available locally f o r public review. This may be accomplished by making documents available at the generator's facility, at a public library or at the offices of any local governmental agency which is willing to act as a repository for this information. A copy of each document shall also be provided to the County Environmental Health Agency pnon their request.

APPENDIX B SB14 HAZARDOUS., .ACT 131

REFERENCES (An extensive waste minimization bibliography is being prepared at the time of this writing. Contact DHS for further information.)

Bergeson, L.L., June 1988. Legal aspects regarding waste reduction. on E-.

Bringer, R.P., Nov. 1987. Important elements of an industrial waste . . . . minimization program. CMA W-on Worksm p r o c e w . New Orleans, LA.

n the World: A Worldw&hh3U& ReDod 0 Process Toward -. W.W. Norton, NY.

Brown, et al., 1984 - 1990.

CBO, May 1985. -s Wa-nt Chanaes and Policv m. Congressional Budget Office, Washington, D.C.

. Chemical CMA , 1989. -urce Manual . . . . Manufacturers Association, Washington, D.C.

f DHS, July 1986. Alternative Te- for R e c v w n d Treatment o ous Wastes: Third Riennial RepPd. California Department of Health . . .

Services.

DHS, June 1987. Guidelines for the Prep- of I-kzxdous Wask m m e n t Plau. California Department of Health Services. (The waste groups were derived from categories used in the report,

Congressional Budget Office, 1985). ardous -ent C h a m and Policy Alternativs,

ing, DHS, Dec. 1988. Commer- Facilities for Recvcl .. . ment. and. California Department of Health Services.

DHS, Oct. 1986. (Consulting Associates, Inc.), Guk@- Rermes: Final Report. Califomia Department of Health

Services.

k: Dufour, J.T., Editor, June 1989. B u s -nt Handboo .. D-bv S m - e (Interim edmn). California Chamber of Commerce, Sacramento, CA.

Environmental Defense Fund 1986. A m roaches to Sou rce Reduction of us Waste: Practical Guidance from Existina Policies & Proarams.

California Institute of Public Affairs, Claremont, CA.

133

li wi h n mi . . . . EPA, Oct. 1987. Benefits. Washington, D.C.

Epstein, S. S., L. Bmwn I3 C Pope 1982. &za.~Ious Waste in Amerim. Sierra Club Books, San Francisco.

Fromm, C.H. et al., Sept. 1987. Succeeding at waste minimization.

Frosch, R. A. & N. E. Nicholas 1989. Strategies for manufacturing. S c l e n t r f l c ( 3 ) .

. I .

er's -force on and techno-loav : Final reDort (Vo 1. 2). May 1986. Technical Advisory Committee Reports, State of California.

s W-I for S m a l l a n t itv Gene rators. Oct. . . . . 1989. Center for Hazardous Materials Research, University of Pittsburgh. Pittsburgh, PA.

Hollod, G.J. & R.F. McCartney, Feb.1988. Waste reduction in the chemical industry. Joumal of the Air PouutjpD Control Assoc iation a(2).

Hunt, G.E. & R.N. Schecter 1988. Minimization of hazardous-waste generation in L Waste Treatme nt and Dispom I. Harry M. Freeman, editor McGraw-Hill, NY.

Hunter, J.S. & D.M. Benforado 1987. Life cycle approach to effective waste minimization. JAPCA 37(10).

Kaplan, L.J., June 1982. Improved titanium dioxide process keeps plants alive. Fnaineer i m ( 12).

Local Government Commission, Oct. 1988. Lpw Cost Wavs of Promote p Sacramento, CA. . . . .

Local Government Commission, Dec. 1988. Reduc ina lndust rial Toxic Waste%

MacLean, R.W., Nov. 1987. Financial analysis of waste minimization options.

and Dis-s: The

CMA -ion Workshop Proceedinas. New Orleans, LA.

of POTWs. Sacramento, CA.

. . . .

Malins, D. C., et al. 1987. Toxic chemicals, including aromatic and chlorinated hydrocarbons and their derivatives, and liver lesions in White Croaker

Science and T e m 31 (81. 765-7(1, v o n e m from the vicinity of Los Angeles. Environmental

134 WASTE MINIMI%ATlON: AN INl'1ZO1)UC170N

Miller, Jr., T. 1988. I ivim in the F n v i r o n m e m Introduction to Fnv ironmental nce f5th e a Wadsworth Publ., Belmont, CA.

Oldenburg, K.U. & J.S. Hirschhorn, Mar. 1987. Waste reduction: A new strategy to avoid pollution. Fnvi-

F. Congressional Off ice of Technology Assessment, Washington, D.C.

. . OTA 1986. of -us \nlaste for Polluibn Prevent!-

ReVelle, P. & C. Revelle 1988. Jhe F n v v and w e s for (3rd ed). Jones & Bartlett Publ., Boston.

' Rice, S.C., Nov. 1987. Incorporating waste minimization into research . . . . operations and process development. CMA W-ion Workshoo p r o c e m , New Orleans, LA.

San Diego County Department of Health Services (L. Pratt & J. Potter), Nov. 1987. c. . . . .

Solvent Waste Reduction A w v e s S m Conference Proceed inas, Oct. 1986. ICF Consulting Associates, Inc.

USA bv the Numbers: A S m a l R e D a 1988. Zero Population Growth, Inc., . . Washington, D.C.

Ventura County Environmental Health, July 1987. Hazardous W i x k Minimbation Proar- Cas- * . Final Report to State of California DHS.

Wyman, R. A. & A. E. Register, Sept. 1989. Waste minimization liability issues. in SQlvent M&& RedU(;ion AI- * . USEPA, Cincinatti, OH.J

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