Pollution Prevention Information

Background

Reducing the amount of waste (air, water, solid, and hazardous) produced at the source is the only permanent and practical solution to the myriad of problems caused by environmental pollutants. Additionally, pollution prevention makes economic sense; today's generators are tomorrow's potentially responsible parties with legal liability even if current regulations are followed.
Pollution prevention means source reduction. Waste minimization means reduction, to the extent feasible, of any solid or hazardous waste prior to any treatment, storage, or disposal. Waste reduction means the reduction of volume, and/or toxicity, of waste after the waste has been generated and prior to disposal. In practice, pollution prevention and waste minimization are broken down into two basic activities:

* Source Reduction - in-plant changes that either reduce or eliminate the generation of hazardous waste; and

* Recycling - reuse of a waste stream as an ingredient in a productive process or recovery of a reusable product.

Source reduction is usually preferable to recycling from an environmental perspective. Recycling is less desirable because the generation of waste still occurs and the recycling process results in waste residues. Therefore, the waste management hierarchy is: source reduction, recycling, treatment, disposal.

Pollution Prevention Techniques

Source Reduction includes inventory control, improved housekeeping, production/process modifications, product substitution or reformulation, waste segregation, and new uses.
Recycling includes the use or reuse of the material as an effective substitute for a commercial product, or as an ingredient or feedstock in a process. It includes the reclamation of useful constituents within a waste material, or removal of contaminants from a waste to allow it to be reused.

Purchasing and Inventory Control

In the past, the basic purchasing consideration for chemicals was cost, with little or no attention given to the expenses and liability incurred during disposal. As a result, chemicals were often purchased in large quantities. In addition, various brands were purchased to take advantage of sales. This created hazardous waste disposal problems that can be easily solved by following some of the following suggestions.

* Require supervisor approval prior to purchasing hazardous chemicals. This forces workers to think twice before requesting that a hazardous material be purchased, and it makes management aware of when and how often chemicals are being added to the inventory.

* Keep the inventory of hazardous chemicals to a minimum. This will assist in container rotation and reduced shelf-life problems. In addition, when less product is available, workers generally use less.

* Reduce the number of brands or products used for the same purpose. Numerous brands of the same product increase shelf-life problems.

* Purchase only what will be used within a short period of time. Manufacturing facilities call this "just-in-time".

* Use simple labeling codes, such as an orange sticker, to identify chemicals that contain hazardous constituents. Train individuals who are using these chemicals to recognize the code and to use proper handling and disposal techniques.

A strict purchasing and inventory control program will prevent the generation of hazardous waste due to poor product management. Rigid inventory control provides a very effective means of source reduction at virtually no cost to the operator.
Additional examples include: Restricting the purchase of solvents and materials that contain chlorinated compounds like trichloroethylene (TCE), and restricting the access of employees to storage areas.

Improved Housekeeping

Good housekeeping can solve a variety of hazardous waste generation problems. In addition, housekeeping changes can be implemented quickly and with little cost. Sloppy housekeeping which includes leaks from tanks, pumps and valves, and the release of product onto the floor, can dramatically increase the volume of hazardous waste. Other practices such as tank overfills, lack of drip boards, and chronic spills and leaks add to the hazardous waste stream. Not only is valuable product lost, but the volume of waste generated is increased due to the materials (rags, floor dry and water) used during cleanup.
In Michigan, an auto plating shop carefully pretreated parts prior to placing them into a plating bath. As a result of the pretreating, the plating bath did not need to be drained during 27 years of operation. Most other auto plating shops drained plating tanks once a year at an approximate cost of $25,000 per shop.
Evaporation is a material loss that can be controlled through the use of tight-fitting lids, spigots, and other accessories. The reduction of evaporation will increase the amount of available material and result in lower solvent purchase costs.
Additional examples include: utilizing drip pans, improving liquid transfer techniques, and reducing water usage during floor cleaning by using spot washing instead of whole-floor cleaning.

Production/Process Modifications

Outdated equipment and traditional production methods can generate large volumes of hazardous waste, especially when production is the gaol and waste generation is largely ignored. Although the capital investment to purchase new equipment or to modify existing equipment can be high, the investment payback is usually significant when compared to disposal and liability costs.
For example, a manufacturing company now uses a water-based electrostatic paint system instead of a conventional organic solvent system. The new system has improved the quality of application, decreased downtime, reduced generation of aromatic waste by 95 percent, reduced paint sludge by 97 percent, and resulted in up to 95 percent recovery and reuse of paint.
Another way to reduce VOC emissions is to reduce the amount of paint sprayed by using high transfer efficiency equipment. The standard method of applying paint is the air spray gun. Typical transfer efficiency is on the order of 20 to 40 percent. Many of the newer spray application systems have transfer efficiencies of greater than 65 percent.
Additional examples include: filtering solvents for extended reuse, switching to industrial parts washers, and utilizing predictive maintenance programs.

Product Substitution/Reformulation

Substituting a non-hazardous chemical for a hazardous one has obvious benefits for waste minimization, environmental protection, and worker health and safety. Many products are being reformulated by chemical manufacturers due to increased pressure placed on them by industry.
For example, The Department of Defense developed Plastic Media Blasting to strip paint from military aircraft. In this process, small plastic beads are air blasted at the aircraft's surface, removing the paint by mild abrasion. This method requires less time and generates substantially less hazardous waste than the traditional wet stripping. Plastic Media Blasting is quickly becoming the standard method of paint removal for both government and private facilities.
In Denver, the Regional Transportation District switched from a solvent that resulted in a hazardous waste to a non-hazardous product. Not only did several maintenance facilities immediately reduce their hazardous waste generator status, but also realized significant cost-savings.
Additional examples include: switching to water-based parts cleaners, hot water parts washers, and using lower flash point solvents.

Waste Segregation

Many wastes are actually mixtures of hazardous and non- hazardous waste, such as chlorinated solvents in waste oil. When this happens, regulatory definitions place the entire waste stream in the hazardous waste category. By segregating key constituents, generators can realize substantial cost savings on waste disposal. Waste segregation can also assist in recycling. An unsegregated waste stream may be too costly to recycle because of the large component of nonrecyclable waste.
Many operations have received notices of violations that result in fines exceeding one million dollars for mixing chlorinated solvents (F-listed waste) with used oil. In addition, several companies have been named as responsible parties in "Superfund" cleanups for disposing of contaminated oil in landfills. Many of these cleanups will easily exceed 10 million dollars.
Additional examples include: segregating hazardous waste solvent-coated rags from non-solvent rags, segregating different types of paint waste, and segregating recyclable solid waste materials.

New Use

When a waste material can be reused as in recycling, or when a "new use" can be found for the materials, several positive things happen. Disposal costs are reduced or eliminated, and raw material purchase costs are also reduced. Operations are encouraged to seek out new and environmentally sound uses for waste materials which were previously treated and/or disposed of. Some assistance can be found with the expanding waste exchange programs being established across the United States.
Examples include: utilizing used oil for energy recovery on-site in used oil furnaces/Space heaters; using old tires for cable trees or underwater reef structures; and using used oil as a crude lubricant.