~

William W. Doerr, Ph. D. Black & Veatch Cambridge, MA

Alternately, peroxide is quickly destroyed by heating. Slowly heating the spent solution to near boiling point will destroy all peroxide. You could use an immersion heater, or if in 55 gallon drums, use an external heat belt. If you have a spent electroless copper bath, this can be slowly mixed as it is also a reducer. The result is very amenable to plate-out.

ur aqueous based coolant 0 works great, lasts a long time and does everything we ask of it - except it is a waste disposal prob- lem. We know its only about 5% oil with surfactants to keep it emulsi- fied. The problem is that we have to pay t o haul away 100 gallons of waste coolant that only contains 5 gallons of oil. We tried acids, poly- mers, etc. but nothing works. Any help would be appreciated.

Batch treat the waste coolant the easy way. Use a high speed mixer and slowly add Magnesium Sulfate (Epsom Salts) at the rate of one pound per 10 gallons waste. Let it mix at high speed for anoth- er hour and then allow the batch to go still. Over the next several hours, the oil will rise to the surface for skimming and proper disposal. The water phase can then go to waste treatment for pH adjust- ment and solids separation.

e are a small operation with a W modest batch type wastewater treatment system using caustic soda and polymers to remove heavy met- als. What is the minimum amount of safety equipment we need?

The list of items you should have is fairly long. However, good sense dic- tates you must have at least the follow- ing items:

Safety Glasses -they are inexpen- sive, so keep spares around. (These are essential due to the real risk of caustic soda splashing or spraying into the eyes.)

*PVC or Neoprene Gloves - buy the "gauntlet" type as they minimize liquids going inside the glove. Keep several pairs on hand to allow for rinsing conta- minated gloves.

Note: Glasses and gloves are those type of items that are constantly mis- placed or lost. Keep a half dozen spares on hand at all times.

Combination Wash Stations - drench s howe r/ey e wash stat ions. These units should be no more than

,

100 feet apart in any area where chem- icals are handled. They are expensive and annoying to install, but you will be sorry if you don't! You will use them!

ur spent plating bath is chelated 0 with EDTA. As a result it i s almost impossible to waste treat to remove the heavy metals. Your sug- gestions would be appreciated.

There are several viable approaches to solving the problem.

1. Lower the pH to 2.5. The EDTA

3

will become insoluble and c2n be removed by filtering. After removal, raise the pH to precipitate the metals and polish any remaining metals with a chelate-breaker precipitant. Or,

2. At the normal pH for precipitation, add a polythiocarbonate precipitant plus a polyquaternary amine polymer. Mix for 30 to 60 minutes and then allow the metals to settle. 0

For more information on this department, circle 400 on card.

Accurate, reliable and cost-effective analyses are achieved for VOC's in water, including Trihalomethanes and Halomethanes, to sub-PPB levels.

CIRCLE 250 ON CARD FOR FREE INFO.

The National Environmental Journal May/ June 1994 55

- .

Motivation Many in industry are currently strug-

gling with the many new pollution pre- vention initiatives that deal with multimedia pollution (cumulative air, water, and solid waste discharges), haz- ardous waste, air toxic chemicals, and Maximum Achievable Control Technolo- gy standards being phased in through early in the 21st century. Nearly half of the 50 states have some form of pollution prevention legislation that requires plans and programs for pollution reduction.

The U.S. Environmental Protection Agency (EPA) Administrator’s Pollution Prevention Policy statement of June 15, 1993, states that, “regulatory devel- opment, permitting, inspections, and enforcement ... must reflect [EPA’s] commitment to reduce pollution at the source and minimize cross-media transfer of waste.” This policy is reflected in EPA’s “Elements of a Waste Minimization Program,” which establishes the requirements for the “Plan in Place” for Resource Conserva- tion and Recovery Act (RCRA) genera- tors that may have in the past paid only cursory attention to waste minimization planning. Nearly 1 ,I 00 companies have been participating voluntarily in EPA’s 33/50 program for multi-media pollution prevention, striving to achieve numerical multi-media pollution reduc- tion goals for 1992 and 1995. Separate industry initiatives, such as those by the Chemical Manufacturers Associa- tion or the Synthetic Organic Chemical Manufacturers Association (SOCMA) have made pollution prevention part of the Responsible Care program.

A common element in many regula- tions and programs is the requirement for periodic pollution prevention or waste minimization assessment, review, or analysis. The guideword technique helps identify opportunities for pollution prevention or reduction of pollutants and therefore can become the key first step in pollution assess- ments. The technique is more compre- hensive than the “checklist” method, another structured method. Both meth- ods have their roots in hazard identifi- cation and have been widely used for several decades for process safety management. Checklists and the guideword technique both help identify pollution reduction opportunities.

I

The Process Techniques Structured techniques are one of many

methods by which pollution reduction opportunities can be identified for indus- try. Structured methods are generally more objective than other methods because documents, step-by-step process review, and select skills are used. The primary advantage of the guideword technique is its unbiased ability to include both the collective experience of site- based individuals familiar with an industri- al process and the site documents for the process being examined.

The guideword process for identify- ing industrial pollution reduction oppor- tunities consists of three steps:

Obtain background data and seg- ment the process flow sheet, manu- facturing flow diagram, or step-wise operations. Apply “What If?” guideword-based questions in a collaborative forum and brainstorming discussion. Document responses for followup. In the first step, or preparatory phase,

background data on pollution produced by the process being studied are gath- ered for each waste stream at the site. The background data consist of pollu- tion amounts and composition (from manifests, EPA Form R submittals, per- mits, process flow sheets, or emissions monitoring), site-specific operating and maintenance procedures for the process being examined, and the process flowsheets or manufacturing flow diagrams. The emission inventory data and the operating and mainte- nance procedures are needed to identify the location, amount, composition, and media (air, water, or solid) form for: (1)

the waste streams that are routinely emitted, and (2) the waste streams that may be pro- duced peri- odically as a result of tran- sient opera-

During the guideword process, team members collaborate to brainstorm and identify pollution reduction opportunities.

~

tions such as startup, shut down, clean-out, maintenance activities, or non-continuous emissions due to batch type operations. Industry is generally well prepared to characterize the amounts for routine emissions. How- ever, the transient operations frequently represent significant amounts of waste for certain industries, such as the SOCMI or the pharmaceutical industry.

Also in the preparatory phase, each process flow diagram or manufacturing flow diagram that produces waste is seg- mented. These documents should be site-specific. The segments are charac- terized by the chronological division of key processes, operations, or steps. Within each selected segment of opera- tion, there are: (1) a low number of waste streams in the activity, and (2) all pieces present of equipment making up the process contributing to the waste releas- es. In the segmentation of the process or operation, it is generally useful to choose coupled equipment - particularly if the waste-producing operation is coupled with a control technology device, which may also generate waste. Segmentation following this guideline allows for easier analysis in the subsequent steps.

In the second step, each segmented operation is studied in a collaborative group forum with topical guideword questions. The general topics for guide- words focus on handling, changing, or time modifying actions associated with the industrial process, waste, or fre- quency of activity at the industrial site. The desired result of the interrogation is to reduce, recycle, or replace the waste.

The guideword questions suggested for waste handling analysis are listed in Table 1 , for the analysis of process changes in Table 2, and for operational frequency in Table 3. In the third and final step of the process, the efforts of the guideword review are summarized in tabular form for consensus, review, and followup.

The National Environmental Journal May/ June 1994 57

The Participants

FOR COMPLETE INFORMATION, CONTACT: The Environmental & Hazardous Materials Management Programs THE UNIVERSITY OF FINDLAY

~ ~~~~~ ~~~

1000 N. Main St. Findlay, OH 45840 419-424-4647

I yield loss I I I

Secondary Recirculation of Utilities? avoid once-through system I I

change order of steps I

I I

RCRA GENERATOR TRAINING

A INTRODUCTORY RCRA PERSONNEL TRAINING

A ANNUAL REVIEW RCRA A WASTE MINIMIZATION A ADVANCED COMPREHENSIVE

HAZ. WASTE MANAGMENT STRATEGIES

RC RA/C E RC LA A SITE REMEDIATIONS

=I 1 =800=52 1 1292

During the guideword process, the team members must collaborate to investigate and identify pollution reduc- tion opportunities. This team is selected from the individuals at the site who are able to contribute based on their aware- ness, knowledge, and skills associated with the process(es) being investigated. This team represents seven key skills, with each skill represented by one per- son from the site. For a small plant, this is unrealistic; instead, one person may represent two or more skill areas. If so, it is important that the team has all skills represented even if these are repre- sented by only a few people. A knowl- edgeable outside participant may be called in to ensure that all skills are rep- resented. The required skill areas and justification for including each skill are summarized on the next page.

The Forum The guideword review is performed

in a classroom setting. Beforehand, the facilitator is responsible for the initial

OJCOdCHdCO RESPIROMETER

I Measures 02/C02/CH4/CO gas exchanges in air or other atmospheres: oxidation, biological oxygen demand, photosynthesis.

10L head space, 0.2pL/h sensitivity, real-time graphics, protection against sample cross contamination, fully automatic operation, superior performance to any other respirometer. I Applications: bioremediation; respiration of insects,

bacteria, algae or plants; oxidation of polymers, etc. For more information contact:

P.O. Box 44049 Columbus, OH 43204 USA Ph:(614)276-0861 Fax:(614)276-0529

Toll Free in USA 1-800-669-5011

I Simultaneously measures 1-80 chambers with 50mL to

Columbus Instruments

CIRCLE 251 ON CARD FOR FREE INFO.

58

CIRCLE 252 ON CARD FOR FREE INFO.

The National Environmental Journal May/ June 1994

Scribe

preparation for the guideword review. This review includes understanding the process flow diagrams and operating procedures, an optional tour of the affected process(es), segmentation of

Familiar with organizing and documenting in ledger style.

the process diagrams, preparation of the guideword questions for each seg- ment, preparation of any visual aids to speed up the guideword review of the process(es), identifying, organizing,

Control Emissions. ANNUBAR"

MASS FLOW M0NITC)RING SYSTEMS The new AnnubareMass Flow Monitoring System, featuring the DSF-46 Annubar and Dart'"I1 Flow Computer, is the low cost, reliable way to measure mass flow accurately. Annubar is the solution. Dieterich Standard, P.O. Box 9000, Boulder, CO 80301 (303) 530-9600 FAX: (303) 530-7064

Dieterich Standard A Industries Company

CIRCLE 253 ON CARD FOR FREE INFO.

The National Environmental Journal May/June 1994

and scheduling the team review, and leading the group and documenting the results. The role of the facilitator is to elicit responses from all participants while maintaining progress in the review.

The responsibility of each of the group members is to attend the meeting and brainstorm in an unconstrained manner any options for reducing overall the industrial pollutants from the process waste streams being studied. The role of the scribe is to document (in tabular form) the suggestions offered during the review. As with HAZOPs used in process safety management, the scribe should not be one of the individuals pro- viding the other skills. This combination of responsibilities slows the review and constrains the same individual whose other role is to volunteer options for pol- lution reduction.

~ _ _

~

The Followup The results of the guideword "What

If?" review are recorded on a standard tabular form prepared by the facilitator and the scribe.The standard form

4 POLY or STEEL PORTABLE SPILL CATCHERS ENVIROSTORTM Vaults for drummed or bagged hazardous in-process or waste materials.

Dikes limit your ex- posure to environ- mental and safety problems of spills indoors. ENVIROSTORTM Comprehensive Emergency Spill Clean-up Kits for quick response to chemical or oil spills.

ENVIROSTORTM

( E l l - - ENVIRONMENTAL CONTAINER CORPORATION 1-800-729-71 37

CIRCLE 254 ON CARD FOR FREE INFO.

59

should indicate who the participants were, the process flow diagram, basis for the review, and the date and loca- tion of the review. The data entries on the form for the response to the “What If?” guideword should consist of: (1) the segment being evaluated, (2) the “What If?” guideword question, (3) the response to the question, (4) the needed followup, and (5 ) potential for pollution reduction. These results, after being prepared by the scribe and reviewed by the facilitator, are then used by the responsible environmental authority at the site for ordering of options, evaluation, decision making, and implementation of the significant results to reduce pollution. Other data, such as waste amounts, waste han- dling fees, and other pertinent informa- tion could be included on the summary table if necessary for the followup. Many methods are available to evalu- ate or rank the tabular options using technical, financial, or regulatory schedule criteria; this would be done after the guideword analysis is com- pleted.

Application & Discussion The guideword analysis method can

be applied at two stages of an indus- trial process - during the conceptual design phase, or during operation, as part of a periodic review for waste reduction opportunities. If applied dur- ing the conceptual design phase, the technique provides the greatest oppor- tunity to address design changes, oper- ating and maintenance practices, and environmental requirements at the ear- liest possible time and with the least cost impact. If performed during opera- tion, the technique is fast and inclusive for providing input and options for fur- ther study.

Many state pollution prevention regu- lations require some kind of periodic audit or review and the guideword method could become part of the review. In addition, the guideword tech- nique includes a written summary of what was last achieved and therefore during periodic audits can become the basis for reviewing what was last con- sidered. The summary can also become the basis for identifying longer term research and development needs for an operating industrial facility.

60

0 water), could suggest briquetting the oily liquid and scale together in a thermal form- 0 ing process. The product oil and scale composite could then be recycled to an iron

reduction process, such as a blast furnace where iron oxide and Btu value are needed. The followup would be to examine regulatory barriers as well as process

0 feasibility. Pollution reduction would be achieved by recycling the waste mixture and eliminating organic liquid and solid wastes.

ProcesslPurging Capture purged

Process/Recirc Water reuse

grease Maintenance oil only

Oil reuse Scale/quality unrealistic

Frequency/Cleaning Clean less Quality oil only

Frequency/Order Intermittent Water Quality water only 0