United States
Environmental Protection
Agency

Solid Waste
and Emergency Response
(5305W)

&EPA

WASTE
MINIMIZATION
NATIONAL PLAN

~T
0X1cs mOtr llabon·s UJaste

EPA530-F-97-028
December 1997
http://www.epa.gov

 Solid Waste and

United States
Environmental Protection
Agency

&EPA

EPA530-N-97-001
May 1997

Strategy:wpClate

··.

A Newsletter on EPA's Hazardous-_ Waste
Minimization an€i Combustion. Activities

TECHNICA~
<

'

STANDARDS
'

Status of Combustion Rule

G

n April 19, 1996 (61 Federal Register 173 58), EPA proposed Revised
Standards for Hazardous Waste Combustion Facilities under joint
authority of the Clean Air Act (CM) and Resource Conservation and
Recovery Act (RCRA). The revised standards cover. azardous waste-burning
incinerators, cement kilns, and lightweight aggregate kilns. For each unit, the
standards would impose the maximum achievable control technologies (MACT)
provisions of the CAA. The MACT standards will limit emissions of dioxins and
furans, mercury, semivolatile metals, low-volatile metals, particulate matter (PM),
acid gas, hydrocarbons, and carbon monoxide. For compliance with PM and
mercury (Hg) standards, tbe Agency also proposed requiring continuous emissions
monitoring systems (CEMS). CEMS would address, among other things, local
citizen and environmental group concerns about timely assurances of compliance
with emission limits at affected facilities. EPA is currently evaluating the long-term
performance of the CEMS on hazardous waste combustion devices (see sidebar).

EPA is also considering accelerating a final rule for certain portions of the hazardous
waste combustion rulemaking in advance of promulgating the overall set of final
standards. This would be intended to prevent delays in the implementation of the
final standards when adopted and allow more facilities to come into compliance
within the required 3- to 4-year time frame. This rule, anticipated in the fall of
1997, would streamline RCRA permitting modification procedures under which
permitted facilities could more quickly make
changes to their processes ancl/or operating
parameters to comply with the final MACT
standards. 8,lso slated for acceleration are the
comparable fuels exclusion, provisions related
to the compliance period, and a facility
implementation plan. The comparable fuels
exclusion will ensure that an excluded
hazardous waste fuel is similar in composition
to commercially available liquid fossil fuels.
Because of the additional time needed to
analyze and respond to the numerous
comments and data submitted on the proposal,
EPA has developed a revised schedule for the
final combustion rule. Also, in spring 1997,
EPA plans to publish further information on
~

W

Recycled/Recyclable
Printed on paper that contains at least 50 percent recycled fiber.

(Continued on page 2)

 TECHNICAL STANDARDS
(Continued from page 1)

CEM testing and MACT options in two Notices of Data
Availability (NODAs). The anticipated schedule for key Federal
Register notices is:
•
•
•
•

March 1997: NODA: CEMS PM and Hg Testing Report
April 1997:
NODA: Revised MACT Levels
Fall 1997:
Accelerated Final Rule
Spring 1998: MACT Standards Final Rule

Overview of Comments on Proposed Rule
The comment period for the proposed standards, which included
a 60-day extension, ended on August 19, 1996. Approximately
145 sets of comments were received covering virtually every
provision of the proposal. EPA will be addressing these comments
in developing the accelerated and final MACT standard rules.

MACT Standards-In general, the commenters were divided
over issues such as whether the three source categories covered
by the rule should be subdivided and the appropriateness of
establishing MACT floors for each proposed hazardous air
pollutant (HAP). Some commenters felt the proposed MACT
floors were skewed high because the emissions data applied in
developing the standards were obtained during compliance
testing and trial bums, thus representing a set of operating
conditions rarely approached. In response to the new data
submitted, EPA has updated its database of emissions and
ancillary information on hazardous waste combustors (see
sidebar). Another area of controversy was the Agencys application
of the priority pollutant provisions of section l 12(c)(6). Many
industry commenters believed that EPA inappropriately applied
section 112(c)(6) in that: (1) area sources would be required to
meet MACT standards for all proposed HAPs and not just those
enumerated in section l 12(c)(6), and (2) other section l 12(c)(6)
requirements were not
fulfilled prior to EPAs
proposal to subject all area
sources to the MACT
standards.
Comparable FuelsNumerous comments
addressed the impacts of
fuels exclusion, the
benchmark approach,
implementation of the
exclusion, and the syngas
specifications. Some
commenters did not
believe that the Agency had
adequately evaluated the
impacts of the exclusion on
human health, the
environment, and waste
minimization and recycling
efforts. Others opposed a

2

blanket exemption from all hazardous waste
regulation. In general, however, most
commenters supported EPA's proposed benchmark approach to
determine the scope and levels of a comparable fuel specification.
Commenters were divided over whether process knowledge
should be allowed in determining whether a waste meets the
specification for exclusion. Commenters were also divided over
whether the exemption should be expanded to include other
emissions sources and whether blending should be allowed to
meet heating value specifications. Several commented that the
Agency lacks the Subtitle C regulatory authority over syngas
because it aoes not meet the definition of a solid waste and that
the proposed implementation approach is inappropriate for
syngas because it is specifically for liquid fuels. Some commenters
also supported the Chemical Manufacturers Association proposal
that would establish clean fuel specifications based on the
technology-based MACT emission standards.
CEMS-Commenters questioned this proposal (high cost often
being cited as a reason). However, some commenters did address
how the new CEMS could be implemented (e.g., establish sitespecific performance specifications based on CEMS performance
during a trial period). Commenters also addressed what to do
when the CEMS is down or not operating properly. Suggestions
were made for establishing averaging periods for CEMS when
only manual method testing data were available.
Risk-Several comments addressed the indirect risk assessment
conducted in support of the proposed MACT standards. One
commenter stated that the indirect exposure methodology should
not be applied for setting national standards because the current
guidance for conducting these assessments is believed to be
inadequate and the applied methodology has not been adequately
modified to address Science Advisory Board and public
comments. Others suggested that risk results from the case study
sites did not represent risks posed by hazardous waste emissions
and that the modeled scenarios did not adequately address
sensitive and highly exposed populations. One commenter
believed that risks posed by dioxin were exaggerated by applying
the dioxin toxicity equivalents (TEQ) methodology. Other
commenters stated that ecological risks were not fully considered
as part of the assessment process.

Economics-In general, commenters believed that the
regulatory impact analysis underestimated compliance costs and
impacts on small business and did not fully consider feed waste
reductions. Others commented that the proposal will discourage
waste-to-energy efforts causing wastes currently combusted to be
managed in ways that are less environmentally friendly.
Waste Minimization-One commenter suggested that
companies be required to complete pollution prevention (P2)
planning prior to making decisions concerning emission control
equipment and that beyond the floor (BTF) emission limits
should factor in P2 and waste feed reductions. Some commenters
stated that the comparable fuels exclusion created disincentives
for waste minimization; others believed it should be broadened.

 '

PERMITTING ,,~AND

""
PUBLIC

INVOLVEMENT

Implementing the Combustion Strategy's
Permitting Policy
'

he Combustion Strategy permitting policy is implemented by EPA regional offices or
authorized states, which are the permitting agencies for hazardous waste combustors
under RCRA.

As a general rule, the Agency'.s position is that its regulations are protective of human health
'and the environment and that permits containing these regulatory standards will also be
protective. However, the Agency'.s Combustion Strategy in 1993 indicated that the current
regulations for hazardous waste combustors may, after site-specific inquiry, need to be
supplemented through use of the omnibus provision to protect human health and the
environment. In such cases, use of the omnibus provision as part of the permitting process
is appropriate. Under the omnibus authority, permit writers determine on a site-specific
basis what, if any, additional permit conditions are necessary to ensure protection of human
health and the environment. Under 40 CFR 270. lO(k), EPA may require the applicant to
submit additional information that the Agency needs to make required determinations
under the omnibus provision. For combustion facilities, multipathway site-specific risk
assessments often provide information needed to make such determinations. EPA has made
it clear that the decision to invoke omnibus authority must be made on a case-by-case basis
and only when the permitting agency, after examining all relevant data supplied during the
permitting process, determines that additional conditions are necessary to ensure protection.

EPA Regional and State Implementation Activities

'

'

• Each region and state currently continues to examine facility permit applications
to determine whether to exercise the RCRA omnibus permitting authority to apply
additional permit controls beyond those required under the current regulations.
To ensure sufficient protection of human health and the environment, site-specific risk
assessments (SSRAs) are being conducted. More than 50 SSRAs have been completed or
are under way at hazardous waste combustors across the country EPA understands that
the State of Texas expects to perform risk assessments first on a selected and limited
group of hazardous waste combustors. They then intend to use these results, as
appropriate, to set protective permit conditions for the assessed facilities as well as for the
remaining combustors if possible.
• In a joint action by U.S. EPA's Region 7 and the Kansas Department of Health and
Environment, the first national permit to burn hazardous waste in cement kilns was
issued to the Ash Grove Cement Company in Chanute, Kansas, on August 15, 1996.
• The Agency has developed a new Draft Protocol for Screening Level Human Health Rish
Assessment (SLHHRA). The purpose of this document, which was drafted by Region 6,
is to provide guidance to both regions and states on performing SLHHRAs for hazardous
waste combustion facilities. Information on performing ecological risk assessments is
provided in a companion document titled Draft Protocol for Screening Level Ecological Rish
Assessments (SLERA). EPA expects that SLHHRA and SLERA reports, prepared in
accordance with these guidance documents, will be used by the permitting authority
to support permitting decisions for hazardous waste combustion units. The Agency
anticipates having these documents out to the regions and states for their internal peer
review and comment by April 1, 1997.

3

 WASTE MINll\ltlZATION

Waste Minimization and Pollution Prevention

A

s OSW finalizes the MACT Combustion Rule, several efforts based on the goals
and objectives of the Waste Minimization National Plan are encouraging waste
minimization and pollution prevention (WM/P2) at affected facilities (including
combustors) . EPA is (1) developing regulatory incentives for WM/P2 within the MACT rule,
(2) identifying opportunities for WM/P2 that apply to facilities generating streams sent to
combustion onsite, and (3) identifying overall waste minimization priorities.

• Developing Regulatory Incentives in the MACT Rule-In its April 1996 proposal,
EPA requested comment on several waste minimization approaches that could reduce the
amount and/or toxicity of combusted wastes. These included proposals to require waste
minimization planning for all facilities to identify measures to reduce the amount of
waste combusted; require waste minimization planning on a case-by-case basis; and
allow a case-by-case 1-year extension beyond the 3-year compliance deadline set jn the
Clean Air Act for facilities that need more time to plan and implement waste
minimization measures. As an outgrowth of these options, EPA is also considering
voluntary incentive-based options that would encourage companies to consider waste
minimization measures as a means to achieve MACT standards. For example, EPA might,
under the auspices of the Agencys audit policy, consider allowing companies to enter
into compliance orders if they can demonstrate that they can meet MACT standards
using waste minimization measures but need more than the 3 years plus a 1-year
extension to complete the testing and installation of new approaches.

These waste minimization incentives are intended to reduce the amount of persistent,
bioaccumulative, and/or toxic (PBT) wastes, such as heavy metals, that are currently
generated and combusted and the releases to the environment that result from
combustion. Additional benefits may include a reduction in the use of raw materials and
worker exposure to hazardous materials and wastes.
• Identifying Process Opportunities- EPA has identified facilities impacted by the
MACT combustion rule and is evaluating WM/P2 opportunities for waste streams
generated at these facilities and combusted onsite. After assessing the costs of these
opportunities and estimating the waste quantity reductions likely to be achieved, EPA
plans to make this information available to facilities and the public.
• Identifying Overall Waste Minimization Priorities-As one means of prioritizing
waste minimization activities, OSW is developing products to help EPA regions, states,
and others identify PBT chemicals in their RCRA hazardous waste (including wastes
managed by combustion). These products include: a list of chemicals ranked based on
the PBT criteria, a "cross-walk" between these chemicals and the RCRA hazardous waste
codes that are likely to be associated with them, and a software tool automating the
process of linking PBT chemicals with waste codes. OSW plans to refine the products
and make them available through the RCRA Hotline during spring 1997.

These efforts involve coordination with state and
regional regulators, plus extensive information
exchange with representatives of impacted facilities
and other stakeholders. EPA's goal is to incorporate
a set of incentives into the MACT rule that
encourage WM/P2 and to offer documents to
generators on stream-specific waste minimization
opportunities.

4

,., .

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5305W)

EPA530-F-97-030
December 1997
http://www.epa.gov/wastemin

Welcome to the Waste
Minimization National Plan
cross the nation, a long-term national effort is under way to reduce the
quantity and toxicity of the most persistent, bioaccumulative, and toxic
(PBT) chemicals in the nation's hazardous waste. Minimizing waste can
reduce costs and regulatory burden, show environmental leadership, and improve
human health and the environment.

A

The U.S. Environmental Protection Agency (EPA) developed the Waste
Minimization National Plan with a goal of helping companies reduce the amount of
PBT chemicals in waste 50 percent by the year 2005. You can support this effort by
implementing source reduction techniques, facilitating environmentally sound recycling, and preventing the transfer of chemical releases from one medium to another
(such as from water to air).
To help you learn more about how your company or facility can contribute to the
nation's waste minimization goal, EPA has prepared several informational and technical publications. Most of these brochures, guidebooks, periodicals, and other
documents are available at no charge. They also are available on the Internet at
<www.epa.gov/wastemin> .

Want to Learn More?

-

Wtzste Minimization: Increased
Profits and Productivity (PPG
Industries) (EPA530-F-97-022)

-

Wtzste Minimization: Reducing
Releases of Chlorinated Solvents
(Ford Motor Company) (EPA530F-97-023)

-

Wtzste Minimization: ReliefFrom
RCRA Large Quantity Generator
Status (I 05th Airlift Wing, New
York Air National Guard)
(EPA530-F-97-024)

-

Wtzste Minimization: Increased
Profits and Productivity (Charles
H Lilly Company) (EPA530-F97-025)

-

Wtzste Minimization: Reducing
Paint Wtzste Through Efficiency
(General Motors Hamtramck
Plant) (EPA530-F-97-026)

-

Wtzste Minimization: Increased
Profits and Productivity (HADCO
Corporation) (EPA530-F-97-009)

+ Waste Minimization National Plan:
Reducing Toxics in Our Nation's Wtzste
(EPA530-F-97-010) is a short, easyto-read, introductory brochure. It
provides an overview of the goals
of the Waste Minimization
National Plan, the chemical focus to
reach these goals, and the resources
available.

+ The following series of fact sheets
highlights specific companies that
have successfully reduced the presence of PBT chemicals in waste.
Each fact sheet briefly profiles the
company, its environmental
achievements, regulatory relief,
implementation process, economic
impact, and hurdles overcome.
-

-

Wtzste Minimization: Increased
Profits and Productivity (Harris
Corporation) (EPA530-F-97-020)
Wtzste Minimization: Reduction in
Combustible Wtzste (FMC
Corporation) (EPA530-F-97-021)

 + Strategy Update: A Newsletter on
EPA's Hazardous W'tiste Minimization
and Combustion Activities (EPA530N -97-00 J) is a source for keeping
up with the latest changes and priorities, significant milestones, and
opportunities for public involvement associated with EPA's waste
minimization and combustion
activities.

+ W'tiste Minimization National Plan
Kit (EPA 530-F-97-028) includes the
first three items described in this fact
sheet in an attractive folder.

+ The W'tiste Minimization
Prioritization Tool, Beta Test Version
1.0 (EPA530-C-97-003) is a flexible
Windows-based software program
that ranks chemicals according to
their persistence, bioaccumulation
potential, and human and ecological
toxicity. It allows you to rank specific
chemicals based on PBT and chemical quantity.

+ W'tiste Minimization Prioritization
Tool [WMPT}, Beta Test Version I. 0:
User's Guide and System
Documentation (EPA530-R-97-019)
presents step-by-step guidance on
installing and using the WMPT 1.0
system to generate outputs that will
aid in decisions about setting waste
minimization priorities. This guidebook explains how to maneuver
within the system, how to input
data, and how to generate scores and
formatted outputs.

+ The Chemical- Waste Code Crosswalk
(EPA530-D -97-005) consists of a series
of tables, separated into wastewaters
and nonwastewaters. It identifies the
RCRA hazardous waste codes that
potentially contain PBT chemicals.

+ The Prioritized Chemical List
(EPA530-D -97-004) is a relative
ranking of 879 chemicals with data
on their persistence, bioaccumulation, and toxicity. Designed as a
flexible screening tool to help identify priorities for the National Plan,
this document ranks chemicals by
their human health risk potential and
their ecological risk potential.

+ *W'tiste Minimization for Selected
Residuals in the Petroleum Refining
Industry (PB97-121 -180) provides an
industry overview with process
descriptions and presents options for
source reduction practices for 29
residuals of concern, including
sludges, catalysts, and treating clays.
Both source reduction and recycling
techniques are described in this
document.

+ *International W'tiste Minimization
Approaches and Policies to Metal
Plating (PB96-J96-753) provides an
industry overview, a description of
metal plating processes, a characterization of waste streams produced,
suggestions for waste minimization
and pollution prevention techniques,
and tools for evaluating pollution
prevention opportunmes.

For Information or
Documents •••
Call the RCRA Hotline at
800 424-9346 or TDD 800 553-7672.
In the Washington, DC area call
703 412-9810 or TDD 703 412-3323 .

* To order these two documents, please
call NTIS at 703 487-4650.

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
{5306W)

EPA 530-F-97-009
August 1997

Waste Minimization:
Increased Profits and
Productivity
HADCO Corporation
What is the HADCO
Corporation?
HADCO Corporation is one of
the nation's largest manufacturers of
printed wiring boards, the fundamental building blocks of all electronic components. Common uses
include computers, telecommunications, medical devices, and automotive components. The complex,
multi-step manufacturing process
requires many hazardous solvents,
including 1, 1, 1-trichloroethane
(TCA) and methylene chloride.

What Did They Accomplish?
Through their continued efforts
in waste minimization, HADCO has
succeeded in reducing both releases
and transfers of toxic chemicals targeted in EPA' s 33 I 50 program by
99.5%. As a result, the facility saves
$600,000 per year in avoided chlorinated solvent purchases and associated disposal costs.

Environmental
Achievements
HADCO's achievements at the
Derry, New Hampshire facility
occurred in two stages. First, they
implemented a solvent recovery system on two of the five production
lines that used methylene chloride.
At the same time, they eliminated

chlorinated solvents from the other
three production lines. In the second
stage, HADCO eliminated TCA and
methylene chloride completely from
all five production lines by switching to aqueous solvents such as
monoethylamine.
Elimination of chlorinated solvents has impacted more than just
air and water emissions: annual disposal of 800,000 pounds of spent
methylene chloride has also been
eliminated. Prior to implementing
the program, HADCO was the
largest environmental polluter in
New Hampshire. These achievements have greatly improved public
relations, and moved HADCO
down the list of New Hampshire's
pollution generators.

Regulatory Relief
To meet regulatory requirements
for the solvent recovery system,
HADCO was required to install a
continuous emissions monitoring
system (CEMS) and to produce
monthly reports. The CEMS generated high maintenance and operational costs. Once the solvent recovery system was discontinued, the
costly CEMS was no longer
required.
Eliminating chlorinated solvents
reduced regulatory burdens associ-

 %:;::c~

y

N

<{~

;0:0.<~'>

'"""""""'

vw:;,1~1y

~~/"'/«-«'

;Waste Minimization: lnc'r eased Profits anCJ :lld!qd,uctilE1ty'
HADCO Corporation
"
, ,
,:;":"
~~

_.,

»

©;:;:]»=~

~

", ,
:, ,
~~

"""

ated with several environmental
statutes:
•Clean Air Act - eliminated
solvents were targeted for
phase out;
• Emergency Planning and
Community Right-to-Know
Act - eliminated solvents
were reportable under Section
313;
• Resource Conservation and
Recovery Act - eliminated
solvents were regulated as hazardous.

The Implementation Process
Impetus for the initial solvent
recovery system and later for the
elimination of TCA and methylene
chloride primarily came through
HADCO's senior management.
They thought HADCO should be
" ... number one in making circuit
boards, not number one in Toxic
Release Inventory releases." Both
approaches were developed in
house, involving site engineers and
the corporate vice president of engineering. Implementation of the initial solvent recovery system required
about a year from inception to execution, though Mr. Wilmot, Manager
of Corporate Safety, Health, and
Environmental Affairs, noted that
obtaining air and water permits created the biggest delays. Once the
recovery system was implemented,
workers needed to be trained in
operating the CEMS. Afterward,
HADCO phased out chlorinated
chemicals from all production lines.
HADCO monitored effectiveness
of the systems in two ways:
•Cost accounting, which examined operational costs of pro-

duction and costs of chemical
purchasing; and
•Chemical monitoring of both
raw material inputs and effluent.

Economics: Costs and
Paybacks
Funding for these improvements
came from internal sources. While
Mr. Wilmot noted that there is typically internal competition for capital
improvement projects, funding for
these improvements was non-discretionary.
HADCO invested $1.7 million in
the project, which covered the cost
of installing the initial solvent recovery system on two production lines
and the cost of converting all five
chlorinated solvent-using lines to
aqueous solvents. This included
equipment purchase, installation
and labor.
Payback for these activities came
within three years, and resulted primarily from HADCO no longer
spending $600,000 per year on chlorinated solvents. There were no
reductions in disposal costs - in fact,
before implementing these changes,
spent methylene chloride was
shipped off site at no charge for
recovery. The current aqueous solvents annually generate 200,000
pounds of sludge that HADCO must
pay to have disposed as hazardous
waste.

across the fact that when the CEMS
malfunctioned, production had to be
stopped. This required a significant
behavioral change in a plant that
operates continuously. This behavioral change was only temporary,
since elimination of the chlorinated
solvents also eliminated the need for
the CEMS. There were no negative
impacts to the quantity and quality
of goods produced.

Words to the Wise
Lee Wilmot cautions those considering implementation of waste
minimization projects to look closely
at their cost accounting systems.
"Total cost accounting is what is selling pollution prevention and waste
minimization. But if you don't factor in the cost of those releases going
up your stack or out your discharge
or out in bulk shipments for off site
treatment and disposal, then you
don't really have a good appreciation [for the actual costs of pollution]. If all you' re focusing on is
how much it costs to operate your
solvent recovery system or wastewater treatment system, or transporting that waste to the end site,
you've missed a big, big part of your
cost of operations."

Hurdles
Implementation of these changes
presented no major hurdles. The
most difficult problem with the solvent recovery system was getting

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

~Tim; mlkrllabmls UJa&e

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97-020
August 1997

Waste Minimization:
Increased Profits and
Productivity
Harris Corporation
What is the Harris
Corporation?
The Broadcast Division of Harris
Corporation manufactures radio and
television transmitters. Their manufacturing process released several
hazardous air pollutants and hazardous chemicals such as 1,1,1
trichloroethane (TCA), methylene
chloride, and methyl ethyl ketone
that were used as cleaning solvents,
thinners, and degreasers.

What Did They Accomplish?
Harris implemented a broad
range of waste minimization initiatives that reflect the company's environmental policy. Harris' savings
resulting from all of its waste minimization efforts total about $125,000
annually.

Environmental
Achievements
Harris' pollution prevention and
waste minimization program is
broad in scope and has enjoyed
numerous successes ...
• Alteration of the paint mixing
process to a batch process
reduced wastes from 1I4 gallon to less than a cup per
batch, contributing to a reduction in waste paint generation

from 3,000 gallons per year to
about 900 gallons per year.
• Installation of a solvent distillation unit also contributed to
waste paint reduction.
•Replacement of TCA with isopropyl alcohol during circuit
board cleaning eliminated
waste TCA.
• Replacement of methylene
chloride in the vapor degreaser
with an aqueous solution eliminated 25,000 lbs. of air emissions per year.
•Implementation of a closedloop water supply for a spot
welder cut water use.
• Replacement of an old, largerthan-necessary compressor
reduced overall energy consumption by 4%.
• Replacement of two 45 kw
water heaters with a single gas
heater slashed energy use.

Regulatory Relief
Because they eliminated methylene chloride from their vapor
degreaser, Harris avoided the need
to apply for a Clean Air Act (CAA)
Title V Permit and is not subject to
Emergency Planning and
Community Right-to-Know Act

 ~Wfu~~hfu,~,'

v

;,:x ~,,.,,

x'«":;:;:;;0'

<;;

v«.*"'»~'v

~waste Minlmiza~ion:

~x<=:>~->/->

.,..., "'w~>«

.,-::;» ~:;:::.,,

~ »«>h~ ~~h:;;::;:::W~#,,~f«>F«'»=''ff""efXJ;'» »x

·increased P.rofjts' an·ci;t?roclucii~ltv'

;Harris Corporation
t

<

,

:·
x

(EPCRA) Section 313 requirements.
The company is now on its way to
being regulated as a RCRA small
quantity generator. Also, by not
using chlorofluorocarbons or Class I
ozone depleting substances, Harris
avoided the mandatory labeling
requirements under the CAA. The
elimination of methylene chloride
obviated the need for additional
ventilation in the metal finishings
room.

The Implementation Process
The driving force behind implementation of Harris' environmental
efforts was a corporation-wide
emphasis on the need for quality
environmental compliance. As those
efforts matured, Harris transited
from a regulatory-based approach to
waste minimization and pollution
prevention, whereby the environmental health and safety organizations contribute to the company's
bottom line.
Harris continuously evaluates its
waste streams and processes, and
performs annual formal evaluations
to develop three-year, rolling strategic plans. Pollution prevention and
waste minimization efforts are incorporated into the business unit's
overall annual operating plan. The
plan is considered a living document and its goals are subject to
change. Current goals are to:
•Reduce solid and hazardous
waste;
• Continue compliance with
environmental safety regulations;

"t·:'' ·
->'»'}

Vh'v

;:co;::::::=:'.!

,, .,,,
~ .'

.,,

'~t:;~ itx

• Reduce toxicity of metal finishing chemicals;
•Reduce utility costs by 10% per
year; and
• Increase quality.
Most ideas were generated in
house. However, when the company eliminated its methylene chloride
vapor degreaser and switched to an
aqueous degreaser, it contacted the
Illinois technical assistance program
for an analysis of available aqueous
degreasers.

Economics: Costs and
Payback
Reductions in paint waste have
resulted in enough savings to pay
for the changes several times over
since 1992. Reduction in water consumption resulting from implementing a closed loop system on the spot
welder has saved about $14,000 in
water and sewage fees per year, cutting the division's annual water
costs by 15%. The spot welder project paid for itself in less than three
months. Savings in the electric bill
resulting from replacement of the
oversized compressor are about
$20,000 per year, representing 4% of
the division's electriC bill.
Replacement of the two 45 kw water
heaters saves $5,100 per year.

obtaining project funding. He
accomplished this by implementing
small projects that targeted "easy
money" and demonstrated the
resulting savings to management.
This established credibility and
opened the door to greater funding.

Words to the Wise
Mr. Edgar advises that managers
wishing to implement waste minimization focus on trying to add
value to the company. This helps to
keep the projects from being viewed
as a necessary evil.
In addition, he is a proponent of
tapping non-management employees who " ... have a thorough knowledge of their job, and credible ideas
of how to develop and implement
improvements."

Hurdles
The biggest difficulty was in
securing project funding from upper
management. Manager of Facilities
and Environmental Compliance
Andy Edgar's solution was to establish the necessary credibility for

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

~ Tmaa;m lkrllal:Joils m&e

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97 -021
August 1997

Waste Minimization:
Reduction in Combustible
Waste
FMC Corporation
What is FMC Corporation?
FMC's Naval Systems Division
is a defense contractor in
Minneapolis, Minnesota. Their
work revolves primarily around the
design and production of military
equipment. Before implementing
their waste minimization programs,
FMC generated about 8,250 gallons
of spent 1,1,1,- trichloroethane
(TCA) annually. FMC used this solvent for a variety of common cleaning applications including overhauled valve housings, large metal
parts prior to painting, electrical
components, dewaxing of metal
prior to plating, and a variety of
maintenance uses. Various grades
of spent solvent were being generated. Final disposal of these solvents
typically required incineration.

What Did They Accomplish?
In 1989, FMC implemented an
in-house recycling program that
allowed 142 of the 150 drums of
spent solvent generated annually to
be recycled at the facility. Then, in
1991, FMC topped that by eliminating the use of TCA altogether, and,
therefore, the need to incinerate
spent solvents.

Environmental
Achievements
The recycling system was only
in operation for one year before
FMC eliminated TCA. While it was
running, the recycling system's
capacity was approximately 150
drums of solvent for that year.
Helen Addies, Environmental
Engineer, points out that this
amount might have increased over
time to a higher annual average, had
the system been used longer.
Since 1991, when TCA was eliminated, there has been a companywide change in attitude; currently,
FMC disposes of wastes only when
there is no alternative use for the
waste. They are constantly in search
of ways to divert flow away from
the waste stream and reduce waste
volume. To this end, FMC now
places HazMat codes on various
chemicals in an effort to track their
use and ultimate destination, with
the goal of eliminating as much
waste as possible, either through
minimization or recycling.
In addition to its efforts to
reduce TCA, FMC has actively pursued several other waste minimization opportunities. For instance:
• FMC has reduced its use of
chemicals targeted by EPA' s
33 I 50 program, such as methyl
ethyl ketone

 ~

/

~

.,,

~

"'

m

""''

,,

""'

~~

v

""

,; "'

v

,.,,,,.,,~

~""

~/"""4»'~~_.,~x ~,;::>;<:d£%<»t"""~;,~,:$'~""N""

:waste 'l\1iinimizatiori: Reduction 'ltl;•omtli{iiHne'wasle
: FMC Corporalian
~

', ,
« "'

• FMC is always looking for substitutes. Working with the military makes this difficult, since
there are often stringent specifications that preclude the use
of substitute materials or
process changes. As a result,
FMC has emphasized reusing
materials. For example, FMC
reuses foundry sand generated
on-site. In 1995, they sold
about 78,000 lbs. to an asphalt
company, which earned FMC
an EPA WasteWi$e leadership
award.
There have also been many lesstangible benefits. For instance, FMC
has improved its community and
public relations through the receipt
of numerous pollution prevention
awards.

Regulatory Relief
Due to its efforts, FMC earned
relief from Emergency Planning and
Community Right-to-Know Act
(EPCRA) Section 313 reporting
requirements in 1995, resulting in
less data collection, recordkeeping
and reporting. In addition, FMC
eliminated TCA use well ahead of
the phase-out schedule established
by the Clean Air Act (CAA)
Amendments.

','',,

1

,,,:,

:

N;:::x ~~wm

, "'
<

~

N

Addies notes: "Quite a few of our
people were ardent environmentalists, which helped quite a bit."
Workers did need some training,
first to run the recycling system, and
then to adjust to working without
TCA.

chemicals to be phased out. Ms.
Addies estimates total savings
resulting from TCA elimination to
be approximately $100,000.

The recycling project took about
six months from conception to
implementation. FMC phased out
TCA entirely within three years (two
years after implementing the recycling system). Installation initially
affected production, but the problems were quickly solved. Quality
was not affected.

No significant hurdles presented
themselves when FMC implemented
these measures. A few management
and labor issues arose; however,
they were quickly resolved.

To monitor the success of the
recycling system, FMC utilized
chemical tracking and costaccounting systems. These systems
were already in place, although
FMC purchased software upgrades
to improve accuracy.

Economics: Costs and
Payback

The Implementation Process

FMC funded these projects internally, and there was no competition
from other projects at the time.
Retrofitting the vapor degreaser into
a solvent recycling center represented the primary initial cost of $14,800.
Ms. Addies estimated operating
costs of the recycling center to be
approximately $15,000 during that
year.

FMC's environmental department designed the original recycling
system and the method for eliminating TCA with input from several
other areas within the company.
This was a team effort including
both engineers and people who
actually worked with TCA. Ms.

As a payback for their efforts,
FMC realized a return on their
investment in the recycling system
in 3 to 4 months. Later, elimination
of TCA resulted in significant savings in time and disposal and purchasing costs. It also facilitated CAA
compliance, as TCA is on the list of

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

Hurdles

Words to the Wise
Ms. Addies passes on one piece
of advice to those thinking of implementing waste minimization and
pollution prevention at their own
facilities:
"Draw on the experience of
employees who work in the area,
(they) know if something will work,
or will have valuable input."
She added that employees often
have considerable outside knowledge that could be useful for project
development and implementation.

~Tim> m!krllal:nls Ulm

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97-022
August 1997

Waste Minimization:
Increased Profits and
Productivity
PPG Industries
What is PPG Industries?
The automotive coatings plant of
PPG Industries, Inc. (PPG), located
in Cleveland, Ohio, manufactures
both solvent-based and water-based
coatings. Prior to 1992, PPG used
thousands of liters of water each
week to clean manufacturing equipment and incinerated a large volume of wastewater contaminated
with methyl isobutol ketone, butyl
cellosolve, and lead.

What Did They Accomplish?
In 1992, PPG designed and
installed a combined ultrafiltration/ reverse osmosis (UF /RO)
process to recycle wastewater. By
combining the two membrane-based
technologies, PPG was able to utilize
a progressive filtering system that
cleaned the wastewater to a level
suitable for reuse in equipment
cleaning operations. As a result,
PPG has cut the volume of hazardous waste requiring incineration
from 400 ,000 gallons per year to
80,000 gallons per year and saves
$205,000 annually.

Environmental
Achievements
PPG received a National
Industrial Competitiveness through
Energy, Environment and

Economics (NICE3 ) grant from the
U.S. Department of Energy (DOE)
and worked cooperatively with the
State of Ohio to promote the UF /RO
cleaning technology. The UF /RO
system reduces the volume of waste
disposed by about 80%, depending
on the level of production. This
experience serves as one example of
how a successful partnership
between government and industry
can foster waste reduction.
Another major achievement of
this project was the increased awareness of waste minimization that
grew throughout the company. This
awareness was due in part to the
publicity the company received
through NICE 3 • The increased
awareness served as a springboard
for development and implementa-

tion of more projects. PPG has
undertaken numerous projects at all
of its approximately 15 facilities
located in nine countries. The corporation as a whole openly embraces
waste minimization as a major goal.

Regulatory Relief
Though PPG's regulatory status
has not changed, less waste means
fewer opportunities for spills, accidents and violations and therefore
fewer legal liabilities.

 The Implementation Process
Design of the UF /RO process
was accomplished by an in-house,
cross-functional team comprised of
environmental managers, production managers, and other staff working with outside consultants who
provided expertise on UF /RO.
Because the system was new,
three operators received training
during one session. From concept to
implementation, the process took
about eight months.

agement and technical issues arose;
however they were quickly resolved.

Words to the Wise
PPG is enthusiastic about waste
minimization and environmental
stewardship, especially considering
the positive publicity that came from
the UF /RO process.

PPG has not altered the UF/RO
system since its inception in 1992.
The system has in no way impeded
manufacturing or lowered product
qu ality. PPG has measured the success of the process by analyzing
reductions in waste using in-house
measurement tools.

Economics: Costs and
Payback
PPG received funding from DOE
and the Ohio Department of Energy.
In addition, PPG contributed an initial capital outlay of over $200,000.
Annual operating costs for the unit
are estimated at $175,000.
Annual savings resulting from
the project have remained fairly
steady at a level of $205,000, equal to
$380,000 worth of savings in water
d isposal costs less the $175,000 in
operating costs. The investment
paid for itself in just over two years.

Hurdles
No significant hurdles presented
themselves when PPG implemented
these measures. A few minor manFor more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

~ T~ m!krlla:l:IOlis Ulaste

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97-023
August 1997

Waste Minimization:
Reducing Releases of
Chlorinated Solvents
Ford Motor Company
What Does the Ford
Ypsilanti Plant Do?

Environmental
Achievements

The Ypsilanti plant (just outside
of Detroit, Michigan) manufacturers
starters for Ford products.
Originally, the plant manufactured a
"field-wound" starter. In 1991, a
new product, called a "permanent
magnet" starter was introduced as
part of an ongoing effort to improve
product quality. The new starter
was smaller than the field-wound
type, thereby reducing the weight of
the part and the vehicle. In addition, the new starter replaced a copper ring with tubing, which eliminated a welding step and reduced
the need for cleaning.

At the time of the product
change, the plant was participating
in EPA's 33/50 Program and in
Michigan's Great Lakes Auto
Project. Both programs had lists of
hazardous chemicals targeted for
reduction; each list included TCE
and methylene chloride.

What Did They Accomplish?
The Ypsilanti plant was scheduled to undergo a design change to
phase out the field-wound starter
and phase in the permanent magnet
type. This design change necessitated the purchase of new equipment.
Ford used this opportunity to evaluate possible changes to reduce or
eliminate the use of chlorinated solvents. The end result? Ford estimates that over 30,000 pounds of
trichloroethylene (TCE) and about
5,000 pounds of methylene chloride
releases are being eliminated annually.

The design change was a perfect
opportunity for the plant to demonstrate its support for these voluntary
environmental programs while
improving product quality.
When the new starter was being
developed, manufacturing engineers
replaced the methylene chloride and
TCE-based cleaning and drawing
chemicals with a water-based compound. This change eliminated
TCE and methylene chloride releases and the plant no longer disposes
of liquid hazardous waste from the
dip tank.

Regulatory Relief
At the time the project was
implemented, the Clean Air Act's
(CAA) permitting requirements
were not in place. The plant phased
out the use of these two chlorinated
chemicals just before the regulation
became effective. The chlorinated
solvent phase-out saved the plant

 l

~-"

'~-"~

?t'<N~ ,m;»,"v,>.>ffi~""" .."!<~ft~"'"'

;.l'

;;:;>:o:~

>

'Waste Minimization: Reducing Releases of CtllorinateCI Solvents
,
: :.
:: ; , ,
Ford Motor Company
'

from having to report on the two
chemicals under the CAA.

The Implementation Process
The Ford Ypsilanti plant's business and product cycles routinely
include consideration of environmental issues. In doing so, the
plant's manufacturing engineers
developed the approach to the chlorinated solvent reduction project.
Staff had to be acquainted with the
new solvents, but this was only a
small part of the overall training that
employees received to adapt to the
plant's overall design change.
The design change took about
two years to complete. To measure
success of the project, the plant uses
standard cost accounting procedures
and tracks overall solvent use.

Economics
The project was incorporated
into the design change budget,
which used funds set aside for new
product development. The design
change cost Ford Motor Co. about
$50 million, but the percentage of
that amount spent on the process to
eliminate the use of chlorinated solvents is unknown.

"

~/« ~ ::

:';:

Hurdles
The solvent change caused
minor disruptions in manufacturing
for a short time and caused a few
minor technical problems. The plant
overcame these problems by consulting the solvent suppliers and the
manufacturing engineers, and simply by becoming familiar with the
new water-based materials.

Words to the Wise
Phil Lawrence, Principal Staff
Engineer from Ford's Environmental
Quality Office, and Jim Luckhardt,
Ford Environmental Engineer, are
quick to acknowledge how well the
solvent change fit into the plan for
the plant's design change. They
stressed the comparative ease of
implementing any waste prevention
project early in the design process as
opposed to trying to work changes
in later.
"Doing it right the first time is
always easier and cheaper than
retrofitting later!" - Phil Lawrence

The plant used to spend approximately $45,000 on chlorinated solvents annually. The current expenditure on water-based solvents is
approximately $20,000, for a total
raw material annual savings of
$25,000. In addition, the plant no
longer pays to dispose of the hazardous liquid waste from the dip
tank.

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97-024
August 1997

Waste Minimization: Relief
from RCRA Large Quantity
Generator Status
105th Airlift Wing, New
York Air National Guard
What is the 105th Airlift
Wing?
The 105'h Airlift Wing is an Air
National Guard Base in Newburgh,
New York. Work at the base
revolves around the enormous C-5
Galaxy, a plane used to transport
military personnel and their equipment. The Wing uses solvent sinks
for cleaning and degreasing the CSs. Many different solvents are
used at the base, such as PD 680, oil
degreasers and defoamers, methyl
ethyl ketone, and light paint thinners. The Wing also uses several
types of detergents that may contain
light oils, paraffin waxes, or linseed
oil.

The new parts washing solvents are
not hazardous under current regulations and output from the washers
is 96 to 99% pure steam, alleviating
the need for further emission controls. Total waste generation is very
small, to the point where it is difficult to quantify, but can be estimated at approximately one pound per
year of solid waste and three gallons
per year of liquid waste. This
amount is in contrast to much larger
volumes, which Master Sergeant Jan
Brown, Chief of Bio-Environmental
Engineering Services, could not
quantify but classified as " ... enormous ... highly significant."
Another major benefit of the
program was the development of
teamwork and trust between the

What Did They Accomplish 7
The 105'h Airlift Wing, formerly
regulated under RCRA as a Large
Quantity Generator (LQG), has
recently achieved the less regulated
status of Small Quantity Generator
(SQG).

environmental managers and personnel from throughout the base.
Because of the success of these programs, environmental managers
have gained credibility, allowing
them to continue environmental
efforts in other areas.

Regulatory Relief
Environmental
Achievements
The group achieved its SQG status through the acquisition of aqueous-based parts washers and
through elimination of some solvent
sinks and downsizing of others.

Having achieved SQG status, the
105u, Airlift Wing enjoys fewer and
less stringent reporting and recordkeeping requirements. In addition,
the 105'h Airlift Wing has reduced
the use of Emergency Planning and
Community Right-to-Know Act

 'waste Minimization: R~lief t"rom RCRA
105th Airlift Wing

!!ms Stat~~ : ', ," ", ,",

<

(EPCRA) Section 313 chemicals to
the extent that it no longer must
submit Form Rs. The reduction in
labor hours formerly used to prepare Form Rs saves money for the
group.

The Implementation Process
The idea to replace and downsize solvent sinks originated from
several sources, including EPA, the
Occupational Safety and Health
Administration (OSHA), Surgeon
General bulletins, the Air Force
Center for Environmental Excellence
(AFCEE), and EPA-Air Force "Cross
Talk" newsletters and conferences.
In addition, many ideas originated
in house, thanks to a quality initiative that motivated personnel. The
Hazardous Materials Pollution
Prevention (HMP2) Team reduced or
eliminated solvents in all areas
where they were used. Seven to 15
sinks were eliminated from various
functional areas within the base, the
smallest being approximately 25 gallons and the largest about 300 gallons.
As part of the process, the Wing
purchased new equipment to test
oil, Halon, refrigerants, and
antifreeze, a reclamation system
used to capture airplane de-icing
materials, and jet washers to replace
the solvent sinks. An engineering
company supplied the jet washers,
which were, in essence, "glorified
dishwashers." The manufacturer
installed the washers and trained
personnel on their use.

,

,,
"

,

~

"<;"""

Economics: Costs and
Payback
Waste minimization efforts have
resulted in significant reductions in
costs that are tracked monthly and
reported quarterly to Command.
Savings have generated positive
feedback from commanding officers.
Much of the money saved through
waste minimization efforts is
returned to the base for uses that
include recreation equipment.

players can be integral to the program's success." Master Sergeant
Brown also cautioned others: "don't
reinvent the wheel." He stressed
that those beginning programs
should recognize that others have
done this successfully. Realize that
"you're not alone out there," and
apply others' ideas to your needs.

Hurdles
At the program's inception, personnel expressed general skepticism
and resistance. However, environmental managers welcomed the
input of workers and empowered
them in project development. As a
result, acceptance increased rapidly.
Now, Master Sergeant Brown
explains, staff members regularly
approach him with new waste minimization ideas. The 105'hAirlift
Wing also implemented an electronic bulletin board that staff can use to
point out base activities that are candidates for waste minimization.

Words to the Wise
Master Sergeant Brown recommends getting all levels of staff,
especially those doing the actual
work, involved. " ... That's been our
success story ... solicit people's
ideas, and let them learn by doing ...
give them a real stake in the process,
as opposed to making a 'token
effort' to obtain their involvement.
Allowing workers to become key

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

~ T~ mlb-llabmis llla&e

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97-025
August 1997

Waste Minimization:
Increased Profits and
Productivity
Charles H. Lilly Company
What is the Charles H. Lilly
Company?
Charles H. Lilly Company, in
Portland, OR, is a major batch formulator and distributor of herbicides, insecticides, and fungicides in
the Pacific Northwest. Its main
plant generates hazardous wastewater when batch formulation tanks
and transfer lines are cleaned for
product changeovers. Lilly's wastewater contains organic solvents,
detergents, and pesticides.

What Did They Accomplish?
Lilly implemented an on-site
wastewater reuse process involving
waste segregation, solvent extraction, filtration, wastewater reuse,

and minimal waste concentrate disposal. They now reuse approximately 95% of their wastewater and
have cut waste concentrate disposal
to about 5%. As a result of these
efforts, Lilly is no longer considered
a Large Quantity Generator (LQG)
under the Resource Conservation
and Recovery Act (RCRA).

through evaporation, solidification,
and incineration. They now generate about 30 gallons per month.
Since inception of the program
in 1989, Lilly also has replaced toxic
constituents (e.g., atrozenes and triozenes) with ingredients that are
less toxic and achieve the same formulation requirements. Lilly also
implemented a closed-loop system
for non-hazardous wastes and
strives to overcome the need for
storage drums on site. Instead, Lilly
uses items like round-trip containers, which reduce drum-washing
needs, generate less waste, and
lessen the handling of hazardous
materials.
One additional achievement has
been an increase in company pride
and environmental stewardship
among employees.

Regulatory Relief
As a result of its efforts, Lilly is
no longer an LQG, and, therefore, is
subject to fewer and less stringent
reporting and recordkeeping
requirements.

Environmental
Achievements

The Implementation Process

Prior to implementing the program, Lilly produced about 550 gallons of hazardous wastewater per
month. Disposal was off-site

Four people were key to successful implementation: the facilities
manager, the environmental manager, a chemist, and the equipment

 ~Waste Minimization~ ' incr~ased 'Profit~ ~~ii P,rod,~cii'1itv
, Charles H. Lilly Company
supplier. The system they put in
place necessitated a change in
employee behavior. In the past,
approximately 80 hours per week
were required to collect wastes in
drums, and label and separate them
for evaporation. With the newer
system, liquids are simply transferred directly to influent holding
tanks. A handling job that took 80hours per week was reduced to 2025 hours.
To monitor the effectiveness of
the waste management process, Lilly
used two tools:
•Chemical QA/QC to monitor
system performance: Lilly sent
influent and effluent samples
to an off-site lab for analysis,
and;
• Cost accounting: focused on
savings in energy use and in
disposal costs.
Once Lilly personnel decided to
implement the process, the project
took about six months to finish.
Lilly continues to use the filtration
system today.

Economics: Costs and
Payback
Lilly paid for this project on its
own. Funding faced competition
from other projects within the company, resulting in implementation
delays.
Lilly invested $100,000 in the solvent recycling system. This included
everything: the system itself, influent and effluent tanks, carbon filters,
piping, monitoring, and certification
for construction of the secondary
containment system.

',

The initial investment for
QA/QC monitoring involved sending samples to an off-site lab for
influent and effluent analysis.
Monitoring costs $2,000 to $3,000 up
front and $100 to $200 per month.

In addition, there were no negative
impacts on either the quality or
quantity of products.

Savings have occurred in three
areas: energy use, staff hours, and
savings from reduced disposal costs.
During the first year, the waste management system accrued savings in
these three areas totaling just under
$100,000. This made for a payback
period of about one year.

Brent Jorgenson, Lilly's former
environmental manager who was
instrumental to the success of this
effort, asserts that companies hoping
to initiate waste minimization projects should keep an open mind to
all alternatives that might fit that
facility. He claims that, " ... while it
may seem easier to take an "off-theshelf" system and try to retrofit your
facility, this is probably not the best
approach. What companies should
do is examine their processes closely
and keep an open mind."

Though Lilly continues to enjoy
reduced costs and labor-hour
requirements associated with hazardous waste handling, the savings
resulting from avoided disposal
costs has dropped from levels
achieved during the inaugural year.
This is due largely to the fact that
other hazardous waste reductions
lessen the need for the filtration system. The savings now are approximately $30,000 to 45,000 per year in
avoided disposal costs and materials
recovered.

"The system paid for itself
within the first year, and has
continued to provide us a boost
every year since then." - Nick
Williams, Environmental
Manager

Words to the Wise

Jorgenson also recommends
spending time and effort up front in
getting management involved.
Both Jorgenson and Williams
attribute much of their success to
empowering and involving those
people who work "in the trenches."
They are closest to the work, can be
a rich source of ideas, and can pro-

vide valuable input into design and
implementation phases.

Hurdles
Lilly experienced very few hurdles while implementing waste minimization. During construction,
manufacturing was disrupted
briefly. Once installed, the process
required changes in employee
behavior and functions. While operators faced a learning curve, there
was no resistance from personnel.

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

~Timi mlkrllal:nls Waste

 United States
Environmental Protection
Agency

&EPA

Solid Waste
and Emergency Response
(5306W)

EPA 530-F-97-026
August 1997

Waste Minimization:
Reducing Paint Waste
Through Efficiency
General Motors
Hamtramck Plant
What Does the GM
Hamtramck Plant Do?
The General Motors Hamtramck
plant (Detroit and Hamtramck,
Michigan) manufactures and paints
various GM automobiles. At the
time this project occurred, the
Hamtramck facility was responsible
for the production of flagship cars in
the Cadillac line: the DeVille,
Seville, and Eldorado.

What Did They Accomplish?
Constantly looking for ways to
improve product quality and reduce
waste, the plant recognized that its
primer surfacer application could be
improved. In particular, the jets
were spraying paint for several fractions of a second after the target
automobile had moved out of range.
By changing the timing, an even
coat of paint was applied while
waste was slashed. The end result
was a reduction of 5.5 tons of
volatile organic compounds (VOC)
emissions and four tons of paint
sludge per year.

Environmental
Achievements
Although the timing of the paint
jets was adjusted by mere fractions
of a second, the tremendous volume

on which the plant operates meant
that these simple changes yielded
significant results. Adjusting the
jets by varying increments resulted
in the plant reducing 3,000 gallons
of primer waste annually (which
contained toluene, xylene, methanol
and butyl cellosolve acetate).

Regulatory Relief
Though the GM Hamtramck
plant's regulatory status has not
changed, reduced waste makes for
fewer opportunities for spills, accidents and violations, and therefore
fewer potential legal liabilities.

The Implementation Process
The GM Hamtramck facility regularly holds meetings to examine
methods for product improvement,
waste reduction, and cost savings.
Input comes from environmental
engineering, paint shop maintenance, paint production, facility
engineering, powerhouse personnel,
purchasing, and finance. Supplier
representatives are also an integral
part of the team.
Implementation of this project
involved no capital or labor costs on
the part of GM. Worker training
was unnecessary. This is a perfect
example of how waste minimization
can often be very simple- it is just a

 matter of paying attention to details,
fine-tuning, and maximizing small
opportunities for change.
The effort took about a month,
during which time an operational
audit was conducted, the data analyzed, and solutions implemented.
Tracking of success included gathering data on Toxic Release Inventory
chemicals and materials consumption. The latter was accomplished
via a purchasing system that tracks
all purchases on a monthly basis.

Economics
At the time the project was
implemented, an annual savings of
$85,000 was achieved. This savings
is primarily the result of lower paint
and waste disposal costs. The savings have varied over time, due to
production volume fluctuations. In
addition, waste disposal requirements were cut.

Words to the Wise
Senior Environmental Engineer
Roger Johnson noted that communication of successes is vital for a pollution prevention effort. Doing so
not only gains recognition, but may
also elicit ideas from people who
might not otherwise have participated.
"If you achieve a success - communicate it!" - Roger Johnson

Another important aspect mentioned by Mr. Johnson is creating a
culture that accepts change and
innovation. Doing so facilitates
rapid development of new solutions.

Hurdles
The project was implemented
during scheduled plant shutdowns,
eliminating any disruptions.
Product quality rose, since the cars
now receive a more even application
of paint.

For more information about the Waste Minimization National Plan, call (800) 424-9346
or check the World Wide Web at http://www.epa.gov/epaoswer/hazwaste/minimize

 -EA ""tJ 0
W CD 0 :J ~
0 P.l Q _

United States
Environmental Protection
Agency

EPA530-F-97-010
September 1997
http ://www.epa.gov

Solid Waste and Emergency Response

;:::;: P.l

Where to Go for Help

'< 0 OJ

~ 55
""tJ -~

::::i

-· CD

< en

For copies of prioritization resources
mentioned in this brochure, or for other waste
minimization inf ormation, contact:

if The RCRA hotline at 800 424-9346 or
TDD 800 553-7672 .

P http://www.epa.gov I epaoswer/hazwaste/
minimize

For technical assistance, contact:

if The National Pollution Prevention
Roundtable's P2 Hotline at 888 745-7272 .
Q http ://www.epa.gov/envirosense/n ppr

A Member of Partners for the
Environment

P.l

co

cen
CD

en

&EPA Waste
Minimization
National Plan

Reducing Toxics
In Our Nation's
Waste

 What Is the Waste Minimization
National Plan?
he Waste Minimization National Plan is a
long-term national effort to reduce the quantity and toxicity of hazardous wastes. The
goals of the National Plan are to:

T

• Reduce by 50 percent
the most persistent,
bioaccumulative, and
toxic (PET) chemicals
in the nation's hazardous waste by the
year 2005, as compared to the baseline
year of 1991.
• Emphasize source
reduction (reducing
waste at its source,
before it is even generated) and environmentally sound recycling, over waste treatment and disposal.

WASTE
MINIMIZATION
NATIONAL PLAN

~
••

r•......
•.
....

.

• Prevent transfers of chemical releases from
one medium (air, water, or land) to another.

Other Resources:

Why Target PBT Chemicals?

R

State and local environmental agencies, public
and private sector technical assistance centers,
trade associations, and product suppliers are all
sources of specific technical assistance. (See
reverse for addresses and phone numbers.)

educing the presence of PBT chemicals in
waste will reduce long-term threats to
human health and the environment.

• Persistent (P) chemicals generally do not break
down in the environment.
• Bioaccumulative (B) chemicals tend to concentrate in animal and plant tissue.

As a Waste Generator, How Can I
Make the Plan a Reality?

• Highly Toxic (T) chemicals can cause cancer or
other health effects in humans, and greatly
endanger the environment.

What Resource is Available to Help
Identify PBT Chemicals and Set
Priorities?
he Waste Minimization Prioritization
Tool (WMPT) is a flexible Windowsbased software system that provides
relative rankings of chemicals according to
their persistence, bioaccumulation potential,
and human and ecological toxicity. It allows
you to rank specific chemicals based on PET
and chemical quantity.

T

Using the Chemical-Waste Code Crosswalk
function, the Tool also allows you to identify
which RCRA waste codes potentially contain
PET chemicals.
EPA will use the Tool to identify a subset
of ranked chemicals with which to track
and report national waste minimization
progress.

Supporting the Plan

0
0

Set your own

ion goals.
.
r7r M
ev1ng your goals
L!..I
easure your
·
progress along th
0 Identify th
e way.
waste.
e most PBT chemicals in your

0
0

Deve/o

..

waste min1mizat'

p a plan for achi

Determine wh· h
facility genera~~ /~rocesses in your

Waste

Research and
·
1
and recycling ~~:r~t ~?urce reduction
or reduce these ch a .1ves to eliminate
em1ca/s.