Vol. 3. No. 1 S D M E 1994

Pollution Prevention Challenge Grants Offer Waste Reduction/Cost Benefits

T he Office of Waste Reduction (OWR) of the North Carolina

Department of Environment, Health and Natuql Resources (DEHNR) has recently sent out requests for proposals for the 1994- 1995 Pollution Prevention Challenge Grants. The Pollution Prevention Program (PPP) has administered 102 Challenge Grants since 1985; these add up to over

Solid and Hazardous Waste Issu

The Regulatory Arena

Pollution Prevention Advisory Council . . . . . . . . . . . . . . . . . . 5 PPAC Hearing Schedule . . . . . . . . . 5 Solid Waste Managemart Update . . . . 6 WasteM’ . . bim Requirements . . . 8 ProposedExpansionfor TRI . . . . . . 9

Other Waste Reduction News

Painting Waste Reduction Project . . . 10 Case Study: Ethnn AUar’s Waste Reduction Initiatives. . . . . . . . . . 11 O m ’ s Rec cle and Reuse Business Assistance (!eater . . . . . . . . . . . 13

Retreatment . . . . . . . . . . . . . . 13 Reaerant Technician Certification . 14 Questions and Answers . . . . . . . . 15

update: P2 m wastewater

in company investments for projects during the 9-year period. The 1994- 1995 proposals will be due on July 1, 1994.

The PPP grant program is designed to help North Carolina businesses and industries develop and implement innovative projects that eliminate, reduce, or recycle air emissions, wastewater discharges, and solid a d hazardous waste. Pmjects that address waste reduction through source reduction or recycling and are not part of entrepreneurial endeavors or propnewy systems are eligible.

Grants Assist Company’s Pollution Prevention Efforts

The Challenge Grants offer several benefits to businesses and industries. For example, many pollution prevention projects must compete for company capital along with other investment projects, and a challenge grant of up to Sl5,OOO may be just enough to help an innovative project clear its return on investment hurdle rate. For other facilities, the grant may be a sizeable poition of project cost; and without the grant, the facility clearly could not consider project fundug A Challenge Grant may also help sell a pollution prevention initiative to upper management. With payback periods of

Office of Waste Redaction North Carolha Department of Environment, Halth, and Natural R e s o u m ~

3825 Bamtt Drive, Rakigh NC 27609. Telephone (919) 571-4100

one to two years for a ma~ority of recent projects, the grants promote DEHNR’s goal of a healthy environment and sound e c o n o m y . C n a i i e n g e Grants are a public/private partnership that can offer

With pollution prevention projeds competing for company capital along with other i n v e s t m e n t projects, a grant of up to S15,OOO m a y be just enough to help un innovmive project clear its return on invesi- ment hurdle rate.

positive exposure and demonstrate a company’s leadership role in environmental management.

What the State Expects From Grant Recipients

A provision of the Challenge Grant contract requires that a recipient submit an interim and f d report on the project, and the scope of the project should be completed within a typical 7-month contract. OWR will, upon request, make these reports available to other adustries pursuing similar projects. In some instances, OWR will develop follow-up case studies on the projects or waste reduction guidance for general

FOCUS Page 2 Spring 1994

Challenge Grants, continued

publication. These Challenge Grant projects promote successful waste reduction techniques with th~s mformation.

Hints To Help Get a Project Funded

Challenge Grants are awarded through a competitive process. Over the past three grant rounds, OWR has funded an average of 21 percent of project applications submitted. To ensure favorable consideration, applicants should read the proposal instructions carefully and make sure the application is complete with cover letter, grant proposal, and project summary form The current gmnt review criteria favor innovative projects and those with s o w e reduction measures. This year, special emphasis is bemg placed on small businesses and on facihties seelung cowersions to recycled feedstocks. Other important criteria include degree of company commitment to sustaining the project, transferability of project to others, waste reduction and cost savings potential, project feasibility, and quantitative measurable results. The applicant's recent environmental compliance history w i U also be reviewed.

FOCL5 readers should have received a Challenge Grant request for proposal (RFP) in April. If you need an RFP, call the NC Office of Waste Reduction at (919) 57 1-4100. The RFP contains application instructions and detailed information on eligibility and requirements. The table on page 3 summarizes grant projects from 1992 through 1994. 0

FOCUS: U'mteMinimization is publishedthree times ayearby the Office of Waste Reduction, the Division of Solid Waste Management, and the Division of Environmental Management of the Department of Environment, Health, and Natural Resources. It is intended to provide North Carolina industries and other interested parhes with current mformation concerning proper waste management and waste reduction. The mformation contained in this publication is believed to be accurate and reliable. However, the application of th~s information is at the reader's own risk

Mention of products and services in the publication does not constitute an endorsement by the State of North Carolina The infonnation contained in the publication may be cited freely.

State of North Carolina: James B. Hunt, Jr., Governor DEHNR: Jonathan B. Howes, Secretary

Oftice of Waste Reduction: Gary Hunt, Director Managing Editor: Terry Albrecht. Production Editor: Mattha Upchurch

Comments?

If you have any comments, waste minimization case summaries, resource mformation, or questions for the next issue of the FOCUS newsletter, contact Terry Albrecht at (919) 571-4100 (FAX: (919) 571-4135)) or write the N.C. Office of Waste Reduction, 3825 Barrett Drive, Raleigh, NC 27609.

A Special Thanks to the Solid Waste and Hazardous Waste Sections.

Available through the NC Office of Waste Reduction at (919) 571-4100:

0 Directorv of Markets for Recyclable Materials, March 1994.

0 Waste Reduct- for clal /Industrial Solid A Guide for J.ocd

Govenunents. March 1994.

0 Waste Reduction Tips: Pallet

Waste Reduction Tips:

Management, March 1994.

Ccmugated Cardboard March 1994.

0 NC Businesses Manufacturing Recycled Products

Available Through the Division of Solid Waste Management at (919) 733-4996:

1993 Special Renort: North Carolina Solid Waste Disposal, January 1994.

0-

hhW2dw, February 1994.

Spring 1994 Page 3 FOCUS

Summary: Pollution Preventon Program Challenge Grants, 1992 Through 1994

I

I A n n u a l savings, s

Company Invest-

Gmt, $ Results ment, $

199119

15,000 -

15,000 I 1 i I

L

Craftsman Fabrics Industries

Hatteras Yachts,

~~

High Point

H a t k I a S Yachts, New Bern

~~

Reduce water and chemical consumption through improved dye bath equipment processing control.

Evaluate HVLP spray guns for polyester gel and direct application rolla equipment of polyester resin m large boat manufacturing.

22,112 Projected benefits: 20% KXIUAOU m I TBD’ chemicals, 1.9 million gaYmonth wster i comeavation. Potentinlreetuctionsinstyru~eemissicms , TBD by reducing vaporization during spmymg ~

of polyester resin and gel coats. I

Potential duction m left-over catalyzed TBD paint and cleanlp waste solvents; potmtial reduced VOCs fiom increased application efficiency of high solid coatings.

Potential reduced use of alnriliary TBD blowing agents and substantial reduction in emissions.

Potential elimination of nickel-bearing TBD wastewater sent to POTW. Potentla1 reductions m water consumption of 285% and in mckel cumpomd air emissions , and recovered chemicals of 99%. ,

530 gaVmonth water reduction; 2.706 substantial reduction m chemical use. I

Metal f i proved to be economical 4,907 and effkient; 8-week payback on fihers reusable m e 1 filters, 72% projected d Y combined toxics reduction for water-bome coating system.

90,000 lbsryear of caamic raw material 8 14.000 will be reclaimed instead of landfiied as j hazardous waste plus labor, time, mwl, enagy savmgs.

Reviewed seven westewater reclaim NIA aitematives to remove solids -30 p. Pilot I studies found no system that met eumomic and processing requiraneats. ~

60-pacent (27,000 lbs) reduction in methyl chloroform use; employee training, product testing, and evaluation I 24’000 -ducted. ~

, I

I

20,295

Evaluate new multi-component HVLP spray equrpment for applymg linear polyurethane extenor paint for fiberglass yachts.

15,000 19.346

TllIUlY America Corp.

Implement experimental pilot machine in production of flexible polyurethane foam without use of a e r y blowing agents.

15,000 15.000

C & R Electroless Nickel

Implement closed loop electroless nickel plating line; record befordafter savmgs and reduction m pollutant releases.

10,000 30.445

Services

1992-1993

, T.S. Designs, 1 Design and install recovery system for water IUC. ! and chemicals used m cleaning ink printing

’ screens.

2,573 2.573

t 12,900 15,080 Henredon Furniture Ind.

Spray booth retrofii with usable metal filters, hybrid water-borne coating conversions for high-end wood furniture.

t Kemd Elearonics Corp.

Develop process to reclaim a latex/canmic film for reuse m capacitor manufacturing.

15,000 80,2285

I

t ManningtU?l Ceramic Tile

Reduce water consumption by 85% to 90% with low-cost wastewater reuse project

1,950 1.950

t I

Tillet Chemical, Inc.

Substitute methyl chlorofom with isopropyl alcohol m manufactme of carboxyrndhyl starch.

14,000 36,300

i L

(Cmtinued on page 4)

FOCUS Page 4 Spring 1994

Challenge Grants Summary, continued

i j Company 1 i Invest- A n n u a l 1 Grant, $ ment, S iResults savings, $ Company Project I

1991-1992 , Recover 5.1 million lbdyear of aggregate I 30,650 equal in qualay to virgin material and I reuse 650,000 galslyear of wash water to 1 make a stronger concrete product ~

purchnsed baler to facilitate cardboard ~ 5 5,175 recycling of 85 tons/year, polymer I sheets pressed into walkway pads or , ground for reuse reduced 222 todyr of ~

polymerwaste.

Shq, to a smelter carbon dust with 10% ' 69.000 or more copper constituency, thereby reducing DO08 waste by 228,900 Ibdyear.

Determined different plating efficiencies ~ 5.958 for varying anodes and initial bath type; , plating out copper reduced 80% of F006 , waste generated.

Non-cmtaminated chrome and wash ~ 6,000 water reused in the plating operation 1 reduced 1,440 galdy-r of hazardous waste j and 96% of emissions.

1.247 galslyrof l,l,l-TCE reduced as 118.350 plasma welders eliminated need for one degreaser and two other degreasers were I

replaced with aqueous spray cleaning SY-

Reducedmaterialpurchases by 13,300 137,500 galdy-r (65% equalizer; 65% stain; 65% toner; 35% glaze; 35% no-wipe; I 53% water-based fmishes).

Custom-designed wash system 1 104,700 elimmated generation of 2,000 lbs/yr of FOOl waste and =25,000 Ibdyr of VOCs.

I

I

Throu& coolant recovery, 23340 lbdy 1 4 1,472 of waste were eliminated and material , purchases were reduced by 50%.

By uthzmg mobil oil reprocessing unit, ~ 21.580 reduced lubricatmg oil waste by 3,150 galdy-r; reduced 4,400 galdy-r coolant ~

use by installation of independent m-site coolant recovery units; reduced paint equipmeat cleaning waste by 11,000 g a l e by installation of an evaporation

Reduced hazardous waste by 540.000 ~ 162,489 Ibdyr and VOCs by 3 10.000 lbdyr by converting to water-based coatings 95% of overlaquer used on labels, crush-proof boxes, and cartons and 95% of clear slq, coats and innerliners.

unit 1

30,000 Watauga

Concrete, Inc. Ready-Mbr

Purchase system to clean and separate coarse and fme aggregate from waste concrete.

15,000

15,000 60,000 P S Elastomerics

Condud six pilot-scale pmgrams to inveshgate reuse and recycle of waste cardboard and polymer sheets.

17,460 Morganite, InC.

Briquette copper dust to allow it to be reclaimed by a smelter.

5,000

5,200 11,000 Diversified TechnologieS

Develop p l a t q methods to recover copper bdore chemical wastewater treatment to reduce F006 waste.

15,000 35,575

447,000

10,000

45,000

C & R Installation of PVC ventilation system on Hardchrome two chrome plating operations to facilitate

recovery and reuse of chrome and water emissions. -~ - . ~ ."" ~ " .

Black & Replace three parts washers uthzmg Decker l,l,l-~chloro&ane (TCE) with two

-

, aqueous washers and a plasma weldmg operation.

Thomson Replace air-assisted spray gum with HVLP Crown Wood spray equipment.

15,000

10,000

15,000 Parker H d m Replace methylene chloride in vapor degreasing system with a biodegradable cleaner and basket wash system to eliminate FOOl waste.

Replace uhaf i i t i on unit with centrduge system hat will allow reuse of machine coolant.

t

I 15,000 45,000 Yale Materials

15,000 Fabco Fastening systems

Purchase and install coolant recycling system, oil recychg syste-m, and install process to reduce water-based paint cleaning waste.

20,000

735,000 Propose to reduce 60% of solvent-based ink coatings with water-based coatings.

15,000 R.J. Reynolds

'TBD=To Be Determined.

Spring 1994 Page 5 FOCUS

T he Pollution Prevention Advtsory Council (PPAC), a 15-member panel created by the General Assembly in 1993

through the enactment of House Bill 976, is charged with malang recommendahons to enhance waste reduction efforts, improve hazardous waste management, and address hazardous waste management capacity needs of North Carolina businesses and industries.

The bill requires the council to prepare a final report by October 1, 1994, as an advisory for the Governor; the Secretaries of the Departments of Environment, Health and Natural Resources (DEHNR) and of Commerce (DOC); and the Environmental Review Commission of the General Assembly.

The council represents a broad range of interest groups incloQng DEHhR and I)c?c Secptzfi-ries (or their designees); B State Senator, and representatives from the Environmental Review Commission, industries (including small business), the environmental and conservation community, county and city governments, and the public.

The council is utili- a consensus-based format to develop legislative, policy, regulatory, and procedural recommendations that, if implemented, will enhance waste reduction activities and hazardous waste management in the state and determine the course the state will take concerning hazardous waste capacity.

The council has established three committees, the Regulatory, Pollution Prevention, and Capacity Committees, to develop the recommendations. The council has met monthly since November 1993, and the committees also meet at least monthly.

0 TheRegulatoryComm~willevaluateandmakepolicy, legrslative, or regulatory recommendations in the mas of education and traintng; permitting (i.e., public parhcipation and siting); regulatory and non-regulatory barriers to waste reduction and environmentally sound recycling, fees; inspection; enforcement; penalties; and universal waste issues such as fluorescent lamps, batteries, and household hazardous wastes.

0 The PoUution Prevention Committee, wluch is focusing on multimedia waste reduction initiatives, is currently reviewing programs and policy in the areas of pollution prevention planrung, incentive-based policy/legslation, and

education and training of industrial communities and the general plblic.

The Capacity Committee is studyingtwo major mas. The first involves an assessment of current hazardous waste generation rates and in- and out-of-state hazardous waste capacity. Close attention is gven to the waste streams and

.waste management methods that are most vulnerable to inadequate capacity. The committee also will evaluate alternative waste minimization efforts and treatment methods that would assure the availability of adequate capacity for North Carolina's hazardous waste. In the second area, the Capacity Committee will evaluate the utility of the capacity "needs" statute requirements and the current provisions enabling the state to pre-empt local ordmnces.

Ths council has stress& the importance of dwussing its work with North CaFOlina citizens and industries and will hold three public meetings to solicit comments.

For at least one week prior to each meeting, materials addressing the PPAC's proposed recommendations wdl be placed on reserve in the main public library in the cities of Greensboro, Wilmington, and Asheville. AI1 concerned individuals are encouraged to participate in the public meetings.

For more information on PPAC activities, call Jodi Bash, PPAC Director, (9 19) 7 15-4 190.0

FOCUS Page 6 Spring 1994

. . a briefing on local government waste management plan lequirements, landfill closures, landfill disposal bans, and local rovernment recycling eflorts.

Rules To Require Local Government Solid

Waste Management Plans

The Division of Solid Waste Management’s Solid Waste Section in the NC Department of Environment, Health and Natural Resources is writing rules to require the submissian of comprehensive local government solid waste I

management plans. All local governments must meet the planning requirement, either individually or jointly, and must present their plans for meetmg 1

the state’s goal of a 40-percent reduction in solid waste by June 30, 2001.

B e c a u s e businesses and i n d u s t r i e s g e n e r a t e approximately two thirds of all municipal solid waste, they will be expected to play a key role in the development of the plans. Rules are being considered which wdl require all solid waste generators to manage wastes in a manner consistent with local plans. In addition, private industrial landfills may be required to either participate in a local government plan or develop a plan of their own.

The local government plans will contain a detailed assessment. of the local solid waste stream to determine the best targets for waste reduction, and they will iden@ appropriate reduction program. Local government plans in areas where commercial and industnal wastes are prevalent will include measures to reduce those wastes. Examples of such measures include material disposal restrictions (e.g.. a ban on

(Continued an page 7)

~ ~~

cardboard disposal), recycling services, and

Public Harings /Advisory Boards

Public Mcipation is critical to the creation and success of the plans. The rules are likely to require the

ectucational programs.

appointment of an advisory board for each planning area and may reauire that the

I board include industrial and commercial representatives. In addition, the rules will probably require at least one public hearing and will recommend that other opportunities for public participation. Commercial and industrial waste generators should be siren m.ple oppom;nity to become involved in the local planning process. The Division of Solid Waste Management scheduled seven regonal meetings in April to discuss the development of these rules.

Scott Mouw of the Office of Waste Reduction at (919) 571-4100 or JoanTroy or AndreaBorresen of the Solid Waste Section at (919) 733-0692 can provide more information on local government solid waste management plans. ’ I NC LandfiU Closures I As a result of the implementation of Federal RCRA Subtitle D landfill rules, 54 municipal solid waste lanctfills have closed before April 9, 1994. Cumntly, 57 publicly owned landfills are open and operating across the state. Most counties that are closing lanN1lls will build transfer stations to transport solid waste to out-of-county landfiills. Much of the transferred waste will go to six private landfills under development at various locations around the state. Some counties are also joining together to operate regional publicly owned landfills.

Spring 1994 Page 7 FOCUS

Solid Waste Management Update, continued

Shift to Lined Landfills

One major effect of the landf i l closings is a sluft in Qsposal of wastes from unhned to lined facilities as prescribed under Subtitle D. It is estimated that the 20 lined landfills in the state that are either currently operational or soon to open wdl receive approximately 40 percent of the state's waste in FY 94-95, up from 12.5 percent in FY 92-93. After January 1, 1998, all solid waste &sposed in the state must go to lined landfills.

The move to lined landfiils and the use of transfer stations will increase the costs of solid waste disposal. Economies of scale at large regtonal landfills will mitigate the increase, but Qsposal costs are expected to rise Substantially above the current state average of about $.22/ton Waste reduction programs will help solid waste generators reduce haulmg, Qsposal, and potential liability costs over the long term.

Landfill Disposal Ban

Passed in the 1993 session of the NC General Assembly, Senate Bill 59 added aluminum cans and ant&eeze to the list of materials banned from disposal in North Carolina landfills. The ban on antifreeze is effective immediately, and the ban on aluminum cans takes effect July 1, 1994. Both m a t e d , in addition to steel cans and appliances, are also bannedfrom dlsposal in incinerators after July 1, 1994.

Other materials banned h m disposal in landfNs by previous leplation include used motor oil, yard waste, tires, white goods, and lead acid batteries. Some local bans or restrictions, ptimanly on cormgated cardboard, are also in place in various areas of the state. A bill to ban pallets from disposal failed in 1993 but may be introduced agam in 1994.

To meet the intent of the bans, waste generators are encouraged to implement recovery and recycling programs for the materials. Businesses and industries

should contact their local recycling coordmator for information on programs and services they may be able to use. The Wlce of Waste Reduction at (919) 571-4100 can provide the name and telephone number of local recyclmg coordinators.

~~

ILocal Government Recycling Efforts Reported1

As detailed in the FY 92-93 Solid Waste Management Annual Reports submitted to the Solid Waste Section, local governments in North Carolina continue to increase their recychg efforts. Table I below shows the number of local government recycling programs by type and the changes over previous years.

Table 1. Number of NC Local Government Recycling Programs

FY

ProgramQpe 90-91 91-92 92-93

Curbside 95 126 199 Drop-off 199 21 7 235 Reuse 26 18 48 Other ' 45 82 79

With the increase in recycling programs, more materials are being recovered. The 616,369 tons of materials recycled in FY 92-93 represent a substantial jump over the previous year. Table I1 below shows a recovery breakdown by major material group.

Table 2. Local Government Material Recovery

Material FY W91, FY 91-92, FY 92-93, Yo In~r-se (tons) (tons) (tons) Over

FY 91-92

CIms 16,816 2%m 32.611 25 Phslic 2.878 6,128 9,264 51 M d 18,736 34.148 44302 30 Paper 99,488 98,730 151,676 54 Orgmia* 105,811 267,428 378,516 42

~ Total 243,789 433,430 616,369 43 Indudes yard wade, which h bannod from dispaul. plus wood m s t e 8nd ~ 8 U c b

In a special summary report published by the Solid Waste Section in January 1994, reports from local government showed that the amount of solid waste Qsposed decreasedby6.4percentinthefiscalyearJuly 1,1992,toJune30,1993;thlsreduction was 18.6 percent short of the 25-percent solid waste reduction goal set for June 30, 1993. However, many local governments made signrficant progress toward thls gal ,

and the state recorded a decrease for the third consecutive year in the amount of sdid waste disposed on a per capita basis. 0

FOCUS Page 8 Spring 1994

Regulatory Requirements for Large Quantity Generators

Requirements for waste minimization programs for large quantity generators (LQGs) under current state and federal hazardous waste regulations are referenced in several areas, as outlined below.

Waste Minimization References Current Requirements

40 CFR 262.41(a) (6) & (7) since 1984 (Annual) description of efforts and achievements to reduce volume and toxicity of waste generated.

40 CFR 262.20 Manifest Certification Generator's certification that there exists a "program in place" to reduce the volumeor toxicity of waste generated to an economically practical degree.

G.S. 130A - 294 (k) since 1989 (Annual) written description of any program to minimize or reduce (North Carolina Statute) the volume or toxicity of waste.

Note: Regulations carry sirmlar requirements for operators of hazardous waste treatment, stora& and d~sposal facilities.

Federal and State Activities

On May 8,1993, the Environmental Protection Agency (EPA) published interim final guidance for suggested elements of waste minimintion programs in the Federal Register Thts guidance was ongunally published as a draft in June 1989 and has not undergone substantial revision. In November 1993, Carol Browner, Adrmnistrator of EPA, mailed notices to generators and permitted facilities requestingthat they commit to the development of a waste minimization program. At the state level, North Carolina's Pollution Prevention Advisory Council is currently considering multimedia pollution prevention planning as a recommendation for the General Assembly in October 1994. Whde North Carolina has not promulgated the speclfc elements of waste minimization programs, the state and federal regulatory requirements for the establishment of some type of waste minimization program are clear.

Purpose of EPA Waste Minimization Guidance

The Agency has been developing guidance to help hazardous waste management facilities and generators design satisfactory programs that fulfill the provisions of the Resource Conservation and Recovery Act and meet the facility's waste management and economic needs. The intent of waste minimization guidance is to suggest actions that a genefator should already be undertalang as part of sound business decisions to reduce waste management costs, reduce handling

health and the environment. The EPA interim final guidance is based on common elements in programs that facilities have planned and implemented successfully and cost effectively.

Definition of Waste Minimization

According to EPA, the term waste minimization includes source reduction and environmentally sound recycling Some recyclmg activities that closely resemble conventional waste management activities such as treatment for the purpose of destruction or dtsposal are not considered environmentally sound recvcline.

(Ccntinued on page 9)

Spring 1994 Page 9 FOCUS

Regulatory Requirements for LOGS, continued

Muttimedia vs. Hazardous Waste Minimization Programs

EPA believes that the concepts of the waste mimmktion programelements listedabove shouldbeincorporatedsuchthat they meet an organization's needs from a management, financial, and waste management perspective. Generators are encouraged to consider these elements in designing and implementmg any multimedta pollution prevention program beyond the hazardous waste focus. Generators may be planning or have already implemented multimedia waste pollution prevention programs addressing reductions in air, wastewater, solid, and hazafilous waste as a blroader facility or corporate waste management policy.

North Carolina Hazardous Waste Inspection Requirements

Generators visited by a North Carolina hazardous waste inspector will be expected to demonstrate a written waste minimization plan and evidence that the plan components are being implemented as a "program in place." Although generators are encouraged to use EPA's interim final guidance to enhance the program, they are not explicitly required to follow each element of the guidance.

Annual Hazardous Waste Reporting Requirements

Currently, the annual waste minimization reporting requirements are bemg fulfilled via the EPA Hazardous Waste Report, which is submitted to the State. This form includes questions on waste minimization assessments, source reduction and recycling activities and quantities, and factors

. I i

-

dubiting waste minimization activities. The Oftice of Waste Reduction ((919) 5714100) will help with questions about completing this portion of the form.

Waste Minimization Requirements for Small Quantity Generators

North Carolina General Statute 130A - 294 (k) requires from small quantity generators (SQGs) an annual written description of any program to minimize or reduce the volume or toxicity of waste. The hazardous waste manifest also requires certification that the SQG has made a good faith effort to minimize waste. The SQG annual reports form (issued to meet the general statute requirement) are typically mailed in July along wia the annual waste fee invoice. These reports contain questions on waste minimization strategjes, obstacles, and assistance needs. The Office of Waste Reduction ((919) 571-4100) can provide more information on waste minimization strategies and programs for SQGs.

Additional Waste Minimization Assistance

EPA, states, and other assistance providers have many guidance documents available to help generators establish waste reduction programs. The Office of Waste Reduction ((919) 571-4100) provides North Carolina facility waste minimization program guidance and on-site waste reduction assessments. 0

The Toxics Release ad Inventory (TRI) is a database of toxic chemical releases considered to have a potentially adverse effect on human health and the e n v i r o n m e n t . Companies must

Y report annually to J ~ p ~ a n d t h e states I their releases of

listed toxic chemicals into the environment. The TRI, wluch was mandated by the Emergency Planning and Community fight-To-Know Act (EPCRA) of 1986, is based on the premise that citizens have a "right to how" about the routine storage,

EpA's proposal on January 6,1994, to expand the TRI by 3 13 toxic chemicals would almost double the size of the inventory. Prior to the proposal, 320 chemicals or chemical categories were on the list. The pfoposed expansion is based on EPA's intention to provide citizens with a more complete picture of the chemicals that af€ect their communities and to focus industry's attention on pollution prevention and source reduction opportunities.

~ ~ ~~

Later this year, a second phase of expansion by EPA will include additional facilities that must report under TRI. EPA plans to identrfy non-manu€actu- inciusmes with signrficant releases and determine their suitability for TRI reportug. Currently, only manufacturing industries identified by standad industrial classrfication codes 20-39 must comply with the annual reporting date of July 1. Other recent changes now make federal facilities subject to the TRI reporting.

The EPCRA Hotline at (800) 535-0202 can provide add~tional use, and emissions of toxic chemicals. I information on the proposed expansions of TRI. 0

FOCUS Page 10 Spring 1994

In September 1993, Hazardous Waste Section and Office of Waste Reduction (OW) of the NC Department of Environment, Health and Natural Resources contracted Research Tnangle Institute to assist the state in a study of waste reduction practices among large quantity hazardous waste generators that run painting operations. This study was the first phase of a targeted assistance project for industries with painting operations. The purpose of the study was to iden@ innovative waste reduction practices among the sample group and areas where waste reduction practices couldbe improved through an assistance effort. For thts s t u d y , detaded telephone surveys were made of approximately 100 facilities, and nine facilities were visited.

Below is a summary of the most common waste reduction activities practiced by the North Carolina generaton surveyed

0 MOW patnt line fluslung techtllques, e.g, change to less hazardou~ solvents, purge lines with air before solvent, pump

Recycle spent solvents for use in equipment cleaning and, in some cases, for pnt thnning

0 Change painting scheiiule to reduce color changes and associmed line flush and eqtipment cleaning waste.

0 Implement statistical process control to reduce the amount of patnt applied, e.g., use gauges more than visual inspection.

0 Re-examine and adjust gun angles to improve transfer efficiency.

0 Eliminate heavy metals in paints though investigation and implementation of alternatives.

0 Switch to high-volume, low-pressure (HVL,P) and other types of higher-efficiency coatmg application equipment.

0 Improve inventory control and housekeeping to minimize disposal of off-spec patnt.

0 Reposition p n t booth filters to increase Me, e.g., in automaled, conveyorized s y s t e m s .

0 Switch from orgatuc solvent to powder coating s y s t e m s .

0 ~nstall a centrifuge to reduce volume of paint booth sludge.

0 Reduce solvent content in pnts by switching to high solid paints or ultra-low solvents and waterborne coatings.

0 Switch from solvent-based cleaners to aqueous-based cleaners for substrate wipe-down and overspray clean-off.

0 Recycle paints in wash-off tanks following electrodeposition diptanks.

0 Eliminate water wash booth by switchmg to dry filter booth.

new paint through without solvent flustung.

F

A second phase of the waste reduction assistance project currently underway will synthesize and enhance guidance information and case studes for facilities generating waste from p n t m g operations. Information will be distributed as it becomes avatlable.

The oftice of Waste Reduction and the Hazardous Waste Section appreciate the cooperation of the industries parhcipatmg in the initial survey and welcome any suggestions or requests for information concerning waste reduction related to pamtmg operations that can be incorporated into the guidance material. 0

Spring 1994 Page 11 FOCUS

Background The Ethan Allen facility in Old Fort, N.C., manufacturesdmngandbedroomfumiture. Coating procedures in the finishing operations produced approximately 37,000 pounds of hazardous waste annually. To reduce the quantity and disposal cost of this waste, the company made the equipment substitutions aad cleanup changes discussed below.

Emplovee WasteKOst-Reduction Activities Some of the modifcations came dimt ly

A Case Studv

Ethan Allen’s Initiatives

Painting Waste By Mickey O’Keefe, Plant Engineer

(704) 688-7686

from employee suggestions. The company implemented a cost-reduction program to facilitate employee involvement in wastekost reduction activities. Employees submit waste/cost-reduction ideas, whch are evaluated by a cost-reduction committee, and valid suggestions are assigned for s a v i n g s calculations.

Waste Reduction Activities Three main components of the coatings operation generate hazardous waste: ovefspray collection systems, merial m a systems, and equipment cleanup procedures.

0

- Metal filters replaced paper/cardboard filters for all the coating operations. The metal filters are cleaned in a tank in which solvent is circulated with a d~q,hragm pump. The waste solventkoating mix is &stilled, and only the overspray is drummed for d i s p o s a l . The cleaning solvent is reused. The metal filters-used for lacquer and sealer overspray are hand wiped, and the dust is sent off-site for recycling to Histrand Chemicals, Inc.

- A fabricated, sloped polyethylene-lined trough replaced an absolt#nt and wood shavings used to catch overspray in the wiping stain booth The trough is squeeged into a paq and only the liquid overspray is drummed for dsposal.

- High-volume, low-pressure (HVLP) spray guns repked conventional air-assisted spray gun equipment. As a result, the quantity of overspray to be fdtered is reduced, and spraying efficiency is increased. Each operator is required also to attend an annual technical training session provided by a representative of the spray gun manufacturer.

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- Polyethylene covers replaced cardboard covers for pallets used to transport products through coating operations. The overspray is peeled off the polyethylene cover and drummed for disposal.

periodically during the boiler watchman’s free time. Thus, the employee’s time is better utilized, and the racks can be reused. Tlus procedure lengthens the Me of the racks, which must be cleaned or disposed of as a solid hazardous waste.

A solvent distillation unit was installed to recover usable solvents and reduce hamdous disposal. A 7-gallon batch still, which is run twice daily, recovers 5 gallons of reusable solvent for every 7 gallons of cleanup waste.

-The racks used to transport material on the conveyor system are now cleaned

d o -

(coatinued m page 12)

FOCUS Page U Spring 1994

Ethan Allen, continued

Waste Reduction Results These equipment substitutions and changes in cleanup procedures resulted in the elirmnation of 25,900 pounds of hazardous waste annually for a estimated cost savings of $129,465 per year. The chart below lists the process, cost of implementation, quantity of waste reduction, and annual cost savings.

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Ethan Men, Inc, Old Fort, NC: Waste Reductions

Process Capitol - WasteReduction, - Savings, Investment, s Ibs/year Slyear

Metal Filters . . . . 57,000 . . . . . . . . . 10,000 . . . . . . . . . . . . 48,125 Lacquer and Sealer Recycle . . . . 1,500 . . . . . . . . . . 2,300 . . . . . . . . . . . . . 6,150

Polyethylene Trough . . . . . 400 . . . . . . . . . . 6,100 . . . . . . . . . . . . 38,430 HVLP Spray Gun . . . . . . . . 3,000 Material Use Material Use

(12 guns @ $250 ) Reduction Savings Sap stain . . . 27% . . . . . 15,000

Sealer . . . .20% . . . . . . . . to Lacquer . . . . 1 1% . . . . . 20,000

Polyethylene Pallet Covers . . . . 2,050 . . . . . . . . . . 3,700 . . . . . . . . . . . . . 7,450 KackCleanmg . . . . 2,001 . . . . . . . . . . . 900 . . . . . . . . . . . . . 8,250

Solvent Distillation . . . . 4,500 . . . . . . . . . . 1,900 . . . . . . . . . . . . . 3,200

TOTAL . . . . 68,650 . . . . . . . . . 25,900 . . . . . . . . . . . 129,465

I Mission Statement: N o d Carolina Office of Waste Reduction I 'Ihe Oftice of Waste Reduction is the agency responsible for carrying o u the State's program of pollution prevention. The goal of the program is to promote the elimination, reduction, or recycling of waste prior to treatment or dqosal. This e f h t addresses air aad water quam, solid and hazardous wastes, and toxic chemicals. The goals are accomplished by providmg non-regulatory technical assistance, traiuing, policy support, and fwa l support to industries, local gOVermIIQts, and &ate a g e n c i e s The office has two programs, the Poll\tion prevention Program, which addresses multimedia industrial waste, and the Solid Waste Reddon Program, which address redudion and recycling of municipal solid waste. Additional information and technical assistance are available at (919) 571-4100. 0

Spring 1994 Page 13 FOCUS

OWR To Establish Recycling and Reuse Business Assistance

Center L: The Office of Waste Reduction (OWR) in coopemtion with tie North CarolinaDepamnent of Commerce was recently selected by the U.S. Environmental Protection Agency to negotiate a contract for the establishment of a Recycling and Reuse Business Assistance Center (RBAC). Designed to establish a structure for coordinating the many progmns and activities for recycling market and economic development in the state, the RBAC urlll focus those resources to achieve three primary goals:

0 To expand existug market development capcity for recyclable materials collected in public and private recycling programs throughout the state;

0 To link existing business financing and incentive programs to the recycling community; and

0 To support the recycling industry to create jobs and strengthen the economy of the state.

These goals will be acheved through a combination of targeted efforts:

- Technical assistance to recyclmg businesses and to businesses interested in utilizing recycled matenals in lieu of virgin materials;

- Training programs for professionals in both the recycling and economic development fields to foster

,'a thorough understandug of each discipline and 'interaction between the fields; - Demonstration projects to test recycling market

development approaches; - Promotion of recycled product procurement to dnve the demand for secondary materials; and

- Development of a coordnating structure to facilitate cooperation between the economic and recycling market development fields to achieve common objectives.

North Carolina, California, Minnesota, and New Yo& were the four states selected from 23 applicants. The total project budget for North Carolina's RBAC is $739,713, which includes a 34-percent match of $250,281 by the s t a t e . 0

Update on Pollution Prevention in Pretreatment Programs

In the Fall 1992 issue of FOCUS, an article entitled "P2 in Pretreatment" introduced a Department of Environment, Health and Natural Resources (DEHNR) project to integrate pollution prevention m w e s into local wastewater pretreatment programs. The PollutionF%eventionF%ogmn in the office of Waste Reduction and the Pretreatment Unit of the Division of Environmental Management's Water Quality Section established pilot studies to implement pollution prevention into two municipal wastewater pretreatment programs. The City of Winston-Salem and the Town of Troy were selected for the studies.

On January 1, 1994, when the pilot programs were officially completed, both municipalities had successfully implemented pollution prevention into their pretreatment p r o g m m s . Each program has achieved success and is continuing to use pollution prevention technologies to lower the pollutant and hydraulic 10- to the wastewater stream.

(Continued m page 14)

FOCUS Page 14 Spring 1994

P2 in POTW Update, continued

Waste Reduction Successes

The City of Winston-Salem targeted molybdenum as a specific wastewater parameter of concern. Through product substitution of a phosphate-based corrosion inhibitor for a molybdenum-based corrosion inhibitor in industrial air washers, the city’s influent levels of molybdenum were lowered by 84 percent.. This redudon should help the City’s wastewater treatment sludge meet the new 40 CFR Part 503 limits on molybdenum.

Through application of pollution prevention technologies, the Town of Troy reduced the hydraulic flow to its wastewater treatment plant by approximately 20,000 gallons per day. During an inflow/infiltration investigation, once-through chiller water was chverted out of the town’s sewer system and is currently being evaluated for a possible alternative use.

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These programs are continumg to expand, and project leaders anticipate additional successes in the future.

Grant Program Initiated

Another goal achieved in the Pollution Prevention in Pretreatment project was a gaut program set up to promote pollution prevention in other pretreatment programs. Grant recipients for 1994 are the City of Henderson, the Town of Fannvdle, and the Water and Sewer Authority of Cabarms County. The Pollution Prevention Program and the Pretreatment Unit look folward to working with these grant recipients.

Lindsay Mize of the Pollution PreventionProgmn is avdable at (919) 571-4100 to provide additional information on the pretreatment programs andor &cuss other pretreatment issues. 0.

The uaitmg program for certification of technicians in refrigerant recovery/recycling offered by the North Carolina State Board of Refrigeration Examiners (SBRE) in Raleigh is one of 27 such programs approved by EPA nationwide. The SBRE program will be admuustered by the state’s community colleges. When participants have successfully completed training, they will receive a certlfcation card tha! allows them to purchase refrigerants and perform service work involving refrigerants. Persons wishing to purchase or recladrecycle refrigerants must have ths card by November 14, 1994.

Grandfather” Provisions

EPA has not provided definite guidance on “grandfathering” those who took cedcation tests before these programs were officially approved. Whether such a techmcian is officially certified depends upon the scope of the earlier training and the tests admuustered The

SBRE in Raleigh at (919) 781-1602 or a local community college can provide information about certification training.

EPA also provides a list of all approved program and a questiodanswer sheet on certification issues to those who call the Stratospheric Ozone Hotline at (800) 296- 1996. The Office of Waste Reduction at (919) 571-4100 will provide a copy of this infonnation sheet and the certification mining contacts upon request.

Mail-In Test Available

A self-administered, mail-in test developed by the National Association of Retail Dealers of AmericaWARDA) and the Association of Home Appliance Manufacturers (AHAM) is also available for techniciarrs who work only on small appliances. Called the AHAM-NARDA Refrigerant Recovery Certification Rogram and approved as an official testing medium by EPA, the mail-in program enables technicians

who work on s m a l l appliances to s t u d y and take the test at their convenience. Those who score at least 84 percent will receive a cettifcate and card attesting their fitness to recover refrigerant from small appliances. EPA defines a small appliance as one that is fully manufactured, charged, and hermetically sealed at the factory with 5 pounds or less of refrigerant. Examples of small appliances include home refrigerators and freezers, room air conditioners (including window units), dehumidifiers, vending machtnes, and dnnkrng water coolers.

The tests are avadable for $22 each and canbepurchasedviaMastercardorV1sa at 1-806394-8378; or checks can be sent to NARDA, 10 East 22nd Street, Lombard, Illinois 60148 ((708) 953-8950). The test package includes a 56page comprehensive s t u d y manual, test booklet, and forms. All techrucians who service small appliances must be certified by November 14,1994. 0

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Spring 1994 Page 15 FOCUS

Questionsr & ZLnulpr-rre?mss By the NC Hazardous Waste Section

What is the current regulatory status offlowescent l a n p s t

Under current state and federal law, fluorescent lamps (and other lamps containing mercury) may be a hazardous waste. Under the Resource Consexvation and Recovely Act (RCRA), used fluorescent lamps (like most other wastes) are subject to evaluation for the RCRA hazardous waste charclcteristic, including the toxicity characteristic. The generator of the waste is responsible for making this determination. Wastes found to exhibit the toxicity characteristic are defined as hazardouswasteandmustbemanagedaccordtngtohazardous waste storage, treatmentand disposal regulations, unless otherwise excluded Because the mercury content of spent fluorescent lamps can cause them to be classified as hazardous waste under these regulations, management of them as a hazardous waste is required. Tests conducted by the National Electrical Manufactunng Association and by EPA in studies contracted thorough SAIC have shown a significant percentag of fluorescent lamps to exceed the RCRA toxicity characteristic leachug procedure (TCLP) mercury limit of 0.2 mg/l.

The Department of Environment, Health and Natural Resources encourages recycling of used fluorescent and other lamps containing mercury before disposal options are evaluated. The NC m i c e of Waste Reduction at (919) 571-4100 or the Hazardous Waste Section at (919) 733-2178 can provide a list of fluorescent lamp recyclers.

Howl should I handle obsolete or non-jiictional cathode ray terminals (CRTS) i f I want to recycle them?

CRTs such as computer monitors and television tubes contain sufficient quantities of lead as a shielding to warrant their recovery. If a CRT is intact and sent for recyclmg it can be considered a scrap metal. As a scrap metal (recyclable material), intact CRTs would not be subject to r e w o n under 40 CRF 262 - 266,268,270, or 124 as indicated by 40 CFR 261.6 ccdified 15A NCAC 13A .0006. CRTs that have been accidentally or purposely crushed/processed are no longer similar to materials that meet the defimtion of scrap metal and, thus, are considered spent material. Spent materials are considered solid wastes when reclaimed and are subject to applicable hazardous waste management regulations. Envuocycle, Inc., in Vestal, N y , ((607) 729-8973) is the only known recycling facility for CRTs.

Do I need to manifest rags or wipes contaminated with listed or flammable solvents if I choose to send them to an industrial launderer for reuse?

No. If rags are bemg laundered and then sent back to the facility, they are not considered solid or hazar&us waste.

Is paint tbat has been thinned with a Foo1-FOO5 solvent now an FoOl-FoO5 waste if it is later disposed of as waste?

procesS waste contarniag solvents where the solvent is an mgredient in the fornulation of a product is not covered by the spent solvent luting In this specific case, the addition of solvent to a paint product constitutes the formulation of a modified paint product. The EPA does not recognize a distinction between a paint that contains solvents when purchased and paint to which solvents have been added. Therefore, thinned paint (as described in the case above) that is later discarded as a waste would not be covered under the F001 - FOO5 spent solvent listings. However, it would probably,tneet the characteristic of ignitability DO01 or may be charac'histically toxic accorQng to TCLP.

As a used oil generator, I sometimes mix, fdter, or separate used oils in my operations, e.g., reconditioning/maintenance to extend the life of the oil or the separation of used oil from wastewater discharges. The waste oil is then sent to a processor or re-refiner. Am I a used oil pmcessor?

No. A used oil generator is NOT considered a processor if the used oil is not being sent directly off-site to a burner of on-spec or &-spec oil.

What is the "rebuttable presumption" for used oil in the Standards for the Management of Used Oil?

EPA assumes that the used oil has been mixed with ahazardous waste if the halogen content is greater than 1,000 ppm and, thus, considers the used oil a hazardous waste. This presumption applies for both used oil generators that are either small quantity or large quantity hazardous waste generators. To &ut this EPA presumption, i.e., prove that it is not valid, the generator must show that the used oil originally contains halogenated compounds by a chemical analysis or a Material Safety Data Sheet.

Used oils from refrigeration units which contain CFCs (chlorofluol~.nrbons) may exceed the 4,000 ppm total halogen test. Is this used oil considered a hazardous waste?

No, it is not presumed to be a hazardous waste if the CFCs are destined for reclamation. The oil would be managed as an off-spec used oil for recycling or burning for energy recovery. If the CFCs are not destined for reclamahon, the oil would be considered hazar&us waste. 0

printed on Recycled Paper 5,100 copes of tlus publication were printed at a cost of $969 or $0. 19 per copy.