Prepared by n

Woodward-Clyde Consultants w 500 12th Street, Suite 100, Oakland, CA 94607- 4014

WASTE AUDIT STUDY FIBERGLASS = REINFORCED

AND COMPOSITE PLASTIC PRODUCTS

PREPARED FOR

ALTERNATIVE TECHNOLOGY SECTION TOXIC SUBSTANCES CONTROL DIVISION

CALIFORNIA DEPARTMENT OF HEALTH SERVICES

April 1989

I 8720052 FNT COT- 1

FCEP ,’ Waste Management Pdlutiori Prevention Program Lloraty N o . a i , f i .-&?lcf

YASTE AUDIT STUDY FIBERGLASS-REINFORCED AND COMPOSITE PLASTIC PRODUCTS

Prepared by

Woodward-Clyde Consul tants 500 12th Street , Suite 100

Oakland, California

Prepared for

California Department o f Health Services A I ternative Technology Section

714/744 P Street Sacramento, California

April 1989

- I

I I I

I I I I

i

I 1 I I i !

I

8720052FNT COT-2

ABSTRACT

The State of California Department of Health Services (DHS) has a hazardous waste minimization program to support a state mandate to phase out land disposal of hazardous wastes. been conducted as part of this program. focused on small manufacturing and repair operations which are often unaware of waste minimization opportunities. technical expertise to analyze these opportunities.

A number of industry studies have

Many lack the resources and

These studies generally have

This report is the consummation of the study of waste management practices in the fiberglass-reinforced and composite plastic products industry. The study describes waste minimization opportunities identified and analyzed from on-site hazardous waste management audits of three firms in this industry. employees). The third was relatively small (less than 10 employees). Manufacturing operations were analyzed to appraise current waste management practices. hazardous waste were identified.

Two of the firms audited were medium sized (50 to 100

Opportunities that could be used to reduce, recycle or treat

Source reduction opportunities were extensive. This includes minimization of the quantity of waste generated during manufacturing. Recycling and resource recovery opportunities are also significant. Solvents can be recovered from waste cleaning fluids by distillation. Incineration of waste solvents is also practiced. However, other opportunities for resource recovery to reduce waste volume or toxicity are limited. polymerized during processing and therefore unsuitable for reuse.

This is because much of the waste generated by this industry is

This report also includes self-audit guidelines and a waste reduction checklist to facilitate self-audits by the industry.

i

- 8720052FNT COT-3

ACKNOWLEDGEMENTS

Woodward-Clyde Consultants acknowledges the assistance of Benjamin We also Fries and Eric Workman at the Alternative Technology Section.

thank the owners and staff of the firms that participated in the study. The help of industry associations, equipment manufacturers, chemical suppliers and waste recyclers who provided performance and cost data required for the analysis of opportunities is appreciated.

Pays" for allowing reprint of figures from their publication in this text. Special acknowledgement to the North Carolina "Pollution Prevention

This report was prepared by Diana Evans and Jonathan Tuck of Woodward- Clyde Consultants and was submitted in fulfillment o f DHS Contract NO. 86-T0077.

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8720052FNT COT-4

DISCLAIMER

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

The

REGULATORY CAVEAT

All text pertaining to law and regulations contained within this report are provided for general information only. That information is not reliable for use as a legal reference. legal sources and regulatory authorities for up-to-date regulatory requirements and their interpretation and implementation.

The generator must contact the appropriate

CONTRACT

Contract No. 86-TOO77 provided $24,980 to prepare this report.

iii

8720052FNT COT-5

CONTENTS

Sect ion Page

Abstract Acknowledgements D i scl aimer Regulatory Caveat Con t r a c t

1,0 CONCLUSIONS AND RECOMMENDATIONS

1.1 Process and Waste Overview 1.2 Waste Min imiza t ion Oppor tun i t ies

1.2.1 Source Reduction 1.2.2 Recycl ing and Resource Recovery 1.2.3 Treatment

1.3 Audit Findings 1.4 Add i t i ona l Recommendations

2.0 INTRODUCTION

2.1 Objec t ives 2.2 Approach t o Waste Reduction 2.3 Aud i t Elements 2.4 Plan t Se lec t i on

3.0 PRODUCT MANUFACTURE

3.1

3.2

Raw Mate r ia l s 3.1.1 Resins 3.1.2 F iber Substrate 3.1.3 Cata lysts 3.1.4 Addi t ives 3.1.5 Solvents Process Descr ip t ions 3.2.1 Mold-Based Fiberglass Products

3.2.1.1 Mold Preparat ion 3.2.1.2 Waxing Mold 3.2.1.3 Resin Preparat ion 3.2.1.4 Gelcoat A p p l i c a t i o n 3.2.1.5 F i berg1 ass Appl i c a t i o n

i ii iii iii iii

1-1

1-1 1-2 1-2 1-3 1-4 1-4 1-5

2-1

2-1 2-1 2-2 2-5

3-1

3-2 3-2 3-2 3-5 3-5 3-7 3-7 3-7 3-7 3-9 . 3-9 3-9 3-9

i v

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8720052FNT COT-6

CONTENTS (continued)

Section

3.2.2 Coated Fiberglass Products 3.2.2.1 Epoxy Resin Pretreatment 3.2.2.2 Resin Mixing 3.2.2.3 3.2.2.4 Slitting/Rewind

Fabric Coating and Heat Curing

Waste Generation 3.3.1 Liquid Waste 3.3.2 Solid Waste

3.3.3 Volatile Waste

3.3.2.1 Gelcoat and Resin Overspray 3.3.2.2 Thickened Gelcoat and Resin

Page

3-10 3-10 3-10 3-12 3-12 3-14 3-14 3-14 3-16 3-16 3-16

4.0 SOURCE REDUCTION

4.1 Material Application 4.1.1 Spray Del ivery Systems 4.1.2 Non-Spray Resin Application Methods

4.1.2.1 Prepreg Riber Reinforcing 4.1.2.2 In-house Resin Impregnat ion 4.1.2.3 Resin Roller Dispensers 4.1.2.4 Vacuum Bag Molding Processes 4.1.2.5 Closed Mold Systems

4.2 Thermoplastic Resins 4.3 Operating and Waste Management Practices

4.3.1 Spray Orientation 4.3.2 Reduce Rinse Solvent Usage 4.3.3 Modify Resin Pan 4.3.4 Reduce Transfer Pipe Size 4.3.5 Waste Segregation

4.4.1 Prevention o f Surplus Inventory 4.4.2 Drum Management 4.4.3 Computerized Inventory Control

4.4 Inventory Control

5.0 RECYCLING AND RESOURCE RECOVERY

5.1 Solvent Use and Waste Management

4-1

4-1 4-2 4-3 4-4 4-4 4-5 4-5 4-10 4-11 4-11 4-12 4-12 4-14 4-14 4-14 4-15 4-15 4-16 4-16

5-1

5-1

V

8720052FNT COT-7

CONTENTS (continued)

Section Page

5.2 On-site Solvent Recovery 5.2.1 Batch Distillation 5.2.2 Continuous Distillation 5.2.3 Filtration 5.2.4 Audited Plant Recycling

5.3 Reuse of Rinse Solvents 5.4 Waste Exchange 5.5 Waste Management Cooperative 5.6 Off-Site Solvent Treatment and Recycling

5.6.1 Batch Tolling 5.6.2 Locations and Capacity 5.6.3 Selection o f a Commercial Facility

of Solvent Waste

5.8.1 Recovery of Sawdust and Floor Sweepings 5.8.2 Cardboard Recovery 5.8.3 Container Recycling

5.7 Recommendations for Improving Recyclability

5.8 Other Resource Recovery Opportunities

6.0 INCINERATION

6.1 Incinerable Waste 6.2 Incineration Barriers

7.0 ECONOMICS

7.1 Baseline Measurements 7.2 Source Reduction

7.2.1 Improve Spray Orientation 7.2.2 State-of-the-Art Spray Gun 7.2.3 Reduce Rinse Solvent Usage 7.2.4 Resin Pan Modifications 7.2.5 Reduce Pipe Size from Mix Tank to

Treater Pan 7.2.6 Reuse Rinse Solvent

7.3 Solvent Recovery Systems . 7.4 Equipment Reliability, Performance and Servicing 7.5 Order o f Implementation

5-3 5- 3 5- 3 5-6 5-6 5-7 5-8 5-9 5-9 5-10 5-10 5-15

5-16 5-17 5-17 5-18 5-18

6-1

6-1 6-1

7-1

7-1 7-3 7-4 7-4 7 -8 7 -8

7-13 7-13 7-16 7-21 7-25

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8720052FNT COT-8

CONTENTS (continued)

Section

7.6 Incentives 7.7 Summary o f Opportunities

8.0 SELF AUDIT GUIDELINES

8.1 Audit Implementation 8.2 Typical Barriers to a Successful Waste Audit

9.0 SUMMARY OF PLANT AUDITS

9.1 Plant A 9. I. 1 Epoxy Resin Pre-Treatment 9.1.2 Resin Mixing 9.1.3 Fabric Coating and Heat Curing 9.1.4 Solvent Recycling 9.1.5 SlittinglRewind 9.1.6 Chemical and Waste Storage

9.2.1 Raw Materials 9.2.2 Spray Equipment 9.2.3 Solvent Recycling

9.2 Plant B

9.3 Plant C

10 .O REGULATORY ASPECTS

10 . 2 Regu 1 atory Caveat 10.2 Responsible Agencies 10.3 Land Disposal Restrictions 10.4 Air Regulations 10.5 Permitting Requirements 10.6 Community Right-to-Know Legislation 10.7 Legislation Pending 10.8 Statutes and Regulations

Page

7-25 7-25

8-1

8-3 8-3

9-1

9-1 9-3 9-3 9-4 9-5 9-6 9-6 9-6 9-7 9-8 9-8 9-8

10-1

10-1 10-1 10-2 10-2 10-3 10-4 10-5 10-6

11.0 BIBLIOGRAPHY

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CONTENTS (concluded)

S e c t i o n

APPENDIX A

APPENDIX B

APPENDIX C

APPENDIX 0

APPENDIX E

APPENDIX F

APPENDIX G

GLOSSARY

COMMUNITY RIGHT-TO-KNOW LAW

PENDING L E G I S L A T I O N

WASTE REDUCTION SELF A U D I T CHECKLIST

STATUTES AND REGULATIONS

REGULATORY AGENCIES

ORDER FORM FOR HAZARDOUS WASTE LAWS AND REGULATIONS

Paqe

A- 1

B- 1

c- 1

D- 1

E - 1

F- 1

G- 1

v i i i

8720052FNT COT-10

TABLES

T a b l e

3- 1

5- 1

5-2

7 - 1

7-2

7 -3

7 -4

7 -5

7 -6

7-7

7-8

7-9

7 - 1 0

7-11

7 -12

7-13

Page

HAZARDOUS SOLVENTS 3-4

TYPICAL SOLVENT RECYCLING EQUIPMENT 5-4

WASTE SOLVENT RECYCLING FIRMS 5-11

FIBERGLASS SHOWER STALL COST DATA 7-5

ANNUAL COST SAVINGS FOR SPRAY ORIENTATION IMPROVEMENT 7-6

PAYBACK PERIOD FOR AIR-ASSISTED AIRLESS SPRAY GUN 7-7

ECONOMIC EVALUATION OF SOLVENT RINSE USE REDUCTION 7 -9

FABRIC AND TREATER PAN WIDTH MATCH 7-11

ECONOMIC EVALUATION OF REDUCING TREATER PAN WASTE 7-12

COST ESTIMATE FOR REDUCING P I P E S I Z E ON RESIN DELIVERY SYSTEM TO TREATER PAN 7-14

ECONOMIC EVALUATION OF REDUCING P I P E S I Z E ON R E S I N DELIVERY SYSTEM TO TREATER PAN 7-15

CAPITAL AND OPERATING COSTS FOR RECOVERED SOLVENT SYSTEM 7-17

ASSUMPTIONS FOR ECONOMIC EVALUATION OF RINSE SOLVENT 7-18

ECONOMIC EVALUATION FOR REUSE OF RINSE SOLVENT 7-19

SOLVENT RECYCLING COST FOR BATCH S T I L L 7-22

PROCEDURE FOR CALCULATING COOLING’WATER FLOW RATE FOR THE SOLVENT S T I L L CONDENSER 7 - 2 4

7-14 SUMMARY OF MAJOR A U D I T COST SAVINGS 7-26

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8 7 2 0 0 5 2 F N T COT-11

F IGURES

F igure

3- 1

3-2

3-3

4 4

4-2

4-3

4-4

5-1

WASTE A U D I T PROCESS SCHEMATIC - SPRAY MOLDING

WASTE AUDIT PROCESS SCHEMATIC - COMPOSITES MANUFACTURE

FABRIC COATING AND HEAT CURING PROCESS

IN-HOUSE IMPREGNATOR SYSTEM FOR FIBERGLASS

R E S I N ROLLER DISPENSER ATTACHMENT

VACUUM BAG MOLDING SETUP

FIBERGLASS WASTE A U D I T R E S I N SPRAY TECHNIQUE

BATCH D I S T I L L A T I O N SETUP

Page

3-a

3-11

3-13

4-6

4-7

4-9

4-13

5-5

X

90189H-S1 COT-1

1.0 CONCLUSIONS AND RECOMMENDATIONS

This report summarizes the results of a waste minimization study in the fiberglass-reinforced composite plastic products industry of California. As part of the study, three small- to medium-sized plants were audited. Waste reduction opportunities were identified through technical and economic evaluations. pages. In addition, a self-audit protocol has been developed for use in the industry and is presented in this report. is presented in Appendix D to assist companies conduct self-audits.

These opportunities are described in the following

A waste reduction checklist

1.1 PROCESS AND WASTE OVERVIEW

The most significant processing activity for this industry involves the combination of resin and reinforcing material. with an excellent strength-to-weight ratio. The resin is a polymerizing plastic. The reinforcing material is commonly fiberglass. The resin and reinforcing material are either sprayed onto a mold or the reinforcing material i s coated with the resin.

The result is a product

The product is usually lighter than metal or wooden products and is stronger than that resulting from unreinforced plastic construction. include partially solidified resin, contaminated solvent from equipment clean-up, scrap coated fiber and solvated resin streams.

Major wastes generated by the industry

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90189H-S1 COT-2

1.2 WASTE MINIMIZATION OPPORTUNITIES

Waste minimization opportunities are in three general areas:

Source reduction Recycling and resource recovery Treatment

The order listed above usually is the environmentally preferred order of implementation. Cost-effectiveness also tends to decrease in the same order.

1.2.1 Source Reduction Source reduction is the prevention or minimization of the volume and/or

hazardous nature o f wastes generated by a production activity. reduction i s usually the preferred approach to minimizing waste. source reduction options require only improved housekeeping, minor design modifications, or operating practice changes. options are:

Source Many

Examples of source reduction

Schedule production to minimize residual wastes.

Chemical substitution using less hazardous raw material chemicals.

Reuse spent solvent from equipment cleaning. reuse-in subsequent formulations.

It may be suitable for

Implement process and equipment changes that result in less chemical usage.

o Reduce the volume o f solvent waste generated in equipment cleanouts. wipe down the sides of mixing tanks. repetitively for cleanout.

For example, wiper blades or squeegees may be used to Spent solvent may be reused

1-2

90189H-SI COT-3

Use bulk storage where possible.

Redesign tanks to minimize sharp angles.

Assign tanks, sinks, and other process equipment for use by a given chemical or formulation. equipment cleanout, and reduce the quantity of waste generated.

This can minimize operator time needed for

Routine evaluation o f waste generation data by management can identify waste reduction opportunities.

Waste reduction training programs with incentive compensation can achieve waste reduction goals

1.2.2 Recycl i ng and Resource Recovery Recycling and resource recovery involve using a waste as a raw material

for another process. Alternatively, valuable materials can be recovered from a waste stream before disposal. of waste solvent streams and the reuse of spent containers in which hazardous materials are stored. resource recovery opportunities exist for reuse of scrap prepreg fabric. These include finding in-plant uses or marketing the prepreg fabric as a raw material to other firms. for recovery and reuse. be viewed as resource recovery as well as treatment, if energy is

Examples include recovery and reuse

In the case of composites manufacturing,

In addition, waste solvent can be distilled Combustion of liquid and vapor solvent wastes can

recovered.

As is the case with source reduction, routine evaluation o f waste generation data will identify recycling and resource recovery opportunities. Employee training programs will encourage employee discussion and subsequent development of these opportunities.

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1.2.3 Treatment In the fiberglass-reinforced plastics (FRP) and composites industry,

treatment opportunities for waste reduction include reacting partially cured resin waste with catalyst to yield a non-hazardous solid suitable for disposal in a municipal landfill, and combustion of solvent liquids or vapors. However, if this constitutes treatment, it might require a permit. A variance from a permit might be allowable.

1.3 AUDIT FINDINGS

From the three audits that were conducted, it was evident that employee knowledge of waste streams, waste minimization approaches and the hazardous waste regulatory structure varied greatly. The largest plant audited had an engineering staff. hazardous waste generation. technical staffs. Most of their technical expertise came from on-the-job experience or vendor contacts. were sketchy. minimization. In all three cases, accurate material balances often could not be prepared because of poor record keeping.

It had some mechanisms in place to track total The two smaller plants did not have trained

Their records of hazardous waste generation There was little understanding of the importance o f waste

Three major waste minimization projects were identified at the largest plant audited. from these projects were estimated at $180,000. to be saved by modifying the treater pans to reduce solvated waste. For the second largest plant, overhauling an inoperative recycling still and

Each had payouts of less than 6 months. The annual savings Approximately $100,000 was

improving spray orientation to minimize the loss of raw material were recommended. The potential savings were estimated at $15,000 annually. At the third plant, the sale of waste solvent to an outside broker was recommended to reduce liability and provide a small cost savings. Although the economic payback periods for most projects identified by the audits were favorable, resistance to change and a lack of commitment by upper management prevailed at some o f the firms visited. major impediment to the implementation of recommendations.

This was seen to be a

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1.4 AODIT IONAL RECOMMENDATIONS

Additional recommendations specific to source reduction, recycling, and economics are contained within the following sections.

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8720052-S2 COT-1

2.0 INTRODUCTION

In this study, Woodward-Clyde Consultants (WCC) investigated waste minimization opportunities in the fiberglass-reinforced and composite plastic product industry. Cost-effective methods that minimize waste generation, especially hazardous waste generati.on, were identified in three plant*audits and in a review of technical literature. A waste reduction checklist (Appendix D) was developed for the industry to assess their specific waste reduction opportunities.

2.1 OBJECTIVES

The Department of Health Services (DHS) has implemented a policy of hazardous waste reduction for California industry as part of its program for land disposal phase out. Hazardous waste reduction i s beneficial both for the economic well-being of the affected industries and for the environment. In the current program, emphasis is placed on communicating with and advising small industrial operations which may lack an awareness of hazardous waste management issues and the technical expertise to address these issues. TG implement the program, DHS is being supported by contractors with technical expertise in hazardous waste management.

2.2 APPROACH TO WASTE REDUCTION

The first step to be taken by the small generator to reduce hazardous The waste audit identifies waste generation is to perform a waste audit.

opportunities for implementing hazardous waste reduction methods and incorporating technologies into existing production systems. should be designed to answer several significant questions including:

The audit

2- 1

8720052-S2 COT-2

How much waste is produced? Which waste streams are hazardous? What is the actual and design processing efficiency for waste generating operations? Are there unaccounted material losses? What are the current and projected disposal costs for the major waste streams? How can waste production be reduced cost-effectively?

2.3 AUDIT ELEMENTS

The audit identifies housekeeping problems and operating inefficiencies that cost little to implement. estimating the payback period o f other more expensive waste reduction opportunities. data, an intrinsic part of the waste audit, is a valued benefit, since these data assist in performance assessment and process optimization, leading to additional savings in labor, energy, and raw materials.

The audit also provides information for

The collection of process operating and waste generation

Information presented in the audit report should include:

1. Manufacturing processes, raw materials, and equipment used.

2. Waste types and quantities generated.

3. Current me-thods and costs for waste disposal.

4. Current and possible future regulations and laws affecting product manufacture and waste management.

5. Waste minimization opportunities including technical and economic analyses.

2- 2

8720052-S2 COT-3

6. Guidelines on how to implement a waste management program

7. Recommendations for further action

A company must be aware of risk when implementing a waste reduction strategy. obtaining data. Implementation of many of the opportunities developed as part o f a waste reduction strategy require modifications to standard operating procedures. The effectiveness of these changes on reducing waste cannot always.be determined until they are tested. barrier to waste reduction. committed to pursuing waste reduction and provide for the risks in its waste reduction economics.

Not all waste reduction opportunities will be apparent simply by Research and experimentation may be needed.

The risk of failure can be a Therefore, it is essential that management be

For a waste audit to be successful, it also must be broad in scope. A

study of a plant's waste problem requires more than a characterization of the various waste streams. stream often involves modifying material inputs or production procedures. Therefore, an audit must examine raw material usage, production processes and schedules, and waste handling methods in a systematic manner.

The solution for reducing a particular waste

The procedure for implementing a waste reduction audit can be broken down into several steps, as follows:

1. The waste audit manager and team is selected based on process design and operations knowledge, availability, and commitment.

2. Preparation for the audit begins by identifying the plant's current waste generation problems and identifying the production processes that contribute to waste generation.

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8720052-S2 COT-4

3. The initial survey is performed to collect existing background information on the plant's operations. available data on material flow rates, waste generation rates, and the costs associated with raw material purchases and waste disposal.

The auditor compiles

. 4. Data are analyzed to identify potential waste reduction

opportunities as well as additional data requirements necessary to evaluate these opportunities. A priority list is developed.

5. A comprehensive plant assessment is performed to fill in data gaps and to obtain detailed information such as process operating parameters, waste characteristics, and operational procedures. Sampling and analyses of waste streams may be necessary.

6. The final step in the audit process is the evaluation o f waste minimization opportunities. used to perform technical and cost/benefit analyses on applicable opportunities to determine their effectiveness. The cost of implementation must be evaluated in comparison to the benefits. possible benefits include reduced raw material cost, reduced waste disposal cost, and reduced liabilities associated with handling and disposing of hazardous waste.

The data obtained during the audit are

The

The results of an audit do not necessarily result in a definitive plan for addressing all of a plant's waste management problems. Experiments in modifying process parameters or production procedures may continue and the results of the audit may be used to develop a waste reduction strategy that will be an ongoing effort.

The estimated scope and cost o f performing a waste audit varies, depending on the size and type of operation. The level o f effort required to identify raw material usage and waste generation rates and to evaluate the process efficiency of the operation generally determine the cost of the audit.

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2.4 PLANT SELECTION

The plants targeted for appraisal and audit for this study were small quantity generators of hazardous waste. The plants were selected from more than 1200 firms listed in the Ca ifornia Manufacturer's Register under SIC codes 3079, 3732, and 7819. The plant managers were interviewed by telephone to obtain additional p ant details and confirm willingness to participate in the program. The firms were prioritized to assist in selection o f those facilities which offered representative manufacturing and hazardous waste generating activities, and which also offered potential for waste reduction.

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8720052-S2 COT-6

3.0 PRODUCT MANUFACTURE

~~ ~~ ~

In 1987 reinforced plastics demand in the U.S. was growing at 5.5% per year.' plastic demand. compounding. Combined with technological advances, this will increase the demand for reinforced plastics. &ins among the thermoplastics. becoming more significant with an annual growth rate of 16%. is the dominant reinforcing material, representing about 33% of

reinforcement materials in use.

Currently this type of plastic makes up about 5% of the total New developments are occurring in blending and

Nylon and polypropylene are the dominant

Glass fiber However, thermoplastic polyester is

Markets for thermoplastic and thermoset reinforced plastics include thousands of products. These cross many industrial categories. These include hulls for recreational and commercial watercraft; bodies for recreational vehicles; building panels; sporting equipment such as tennis rackets, skis, and fishing poles; furniture; electrical panels; housing and components for business equipment, appliances, and power tools; bathtub, shower, and vanity installations; and automotive, aerospace, and aircraft

astic products improves resistance and

components. The fiberg strength and rigidity. dielectric strengths.

ass reinforcing in these p

J t also provides high heat

1. C&EN, Nov. 2, 1987, Fredonia Group, Cleveland

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8720052-S2 COT-7

3.1 RAW MATERIALS

The materials primarily used by the fiberglass reinforced plastic (FRP) and composite plastic product manufacturing industry include resins, fiberglass or other fiber substrate, solvents, catalysts, and other specialty chemical additives. Chemicals marked with an asterisk in this section are listed in California Code of Regulations as hazardous waste. Other chemicals may be considered hazardous depending on the characteristics of the chemical. Material Safety Data Sheets and chemical suppliers should be consulted as a first step.

3.1.1. Resins For FRP and composites industries, resin is supplied dissolved in an

organic solvent. processing, and also serves to dissipate heat generated in the exothermic crosslinking reaction. Thermosetting resins are used in product

In this form, the solvent acts as a carrier to facilitate

manufacture.

Typical res

Polyesters

Epoxies

Polyamides

Phenolics.

n classes used by FRP and composites manufacturers include:

These resin classes refer to functional groups found in the monomer. The chemical formula for the resin raw material varies, depending on specific properties required for the end product. Generally, these resins alone in solid form are not considered hazardous materials. They are not reactive, corrosive, flammable or toxic, and do not meet any criteria in California

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Code o f Regulations, Article 9 or 11. solvent, however, the nature of the solvent may require treatment of resin waste as hazardous. should be consulted as an indication o f the hazardous nature of the solubilized resin.

Because the resin is supplied in

Material Safety Data Sheets supplied with the resin

Resin waste in FRP/composites manufacturing is determ'ned by the carrier solvent, since the resin itself is not hazardous. If the waste contains no residual solvent, it is not hazardous. If the waste is a liquid containing residual solvent and the solvent i s listed as an F-series solvent from a non-specific source (Code o f Federal Regulations Title 40, Section 261.31), it is a hazardous waste. in'Table 3-1. presented in Article 11, Section 66696 (a) and (c) will determine whether the resin waste is hazardous. The generator is responsible for verifying whether a chemical waste is hazardous and for keeping this information up- to-date in terms of hazardous waste classification.

A list o f these solvents appears If the solvent is not listed in Table 3-1, criteria

3.1.2 Fiber Substrate Glass fibers are manufactured in several basic forms. This allows

flexibility in cost, strength, and compatibility with the resin system. Fiberglass content in the product generally ranges from 10 to -15 percent. The basic forms include continuous-strand woven fabric, chopped fiber, and milled fiber. resin matrix during molding than others.

Some o f these types are more easily dispersed throughout the

* Many resins do not adhere well to glass. Vinyl chlorosilane or other

chemicals may be applied to the fiber surface. processing, maintains fi.ber integrity, and establishes compatibility with specific resin systems.

Th is facilitates

* Hazardous material

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8720052T COT1

Table 3-1. Hazardous Solvents

EPA Hazardous Waste No. Sol vent

F002

F003

F005

Tetrachlorethylene Met hy 1 ene C h 1 or i de Trichloroethylene (TCE) l,l,l-Trichloroethane (TCA) Chlorobenzene ly1,2-Trichloro - l,Z,Z-Trifluoroethane O-Dichlorobenzene Trichlorofluoromethane

Xy 1 ene Acetone Ethyl Acetate Ethyl Benzene Ethyl Ether Methyl Isobutyl Ketone n-Butyl Alcohol Cyclohexanone Met hano 1

To1 uene Methyl Ethyl Ketone (MEK) Carbon Disulfide Isobutanol Pyr i di ne

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8720052-S2 COT-9

3 . 1 . 3 Catalysts

catalysts to develop desirable properties. Agents include amines, anhydrides, aldehyde condensation products, and Lewis acid catalysts. Typically, aliphatic amines such as diethylenetriamine and triethyl- enetetramine are often used for room temperature curings. such as methylenedianiline, are used where elevated temperature cures are acceptable. Formulated epoxy systems generally contain accelerators, additives, and fillers. These reduce costs, shrinkage, and coefficient of thermal expansion.

In the case of epoxy resins, curing is undertaken using hardeners or

*

Aromatic amines,

Although some of these chemicals may classify as non-hazardous, the generator is responsible for that determination. up-to-date information on the hazardous waste classification standards.

The generator must keep

3.1.4 Additives Chemical additives also may be introduced to obtain certain product

characteristics. These product characteristics include resistance to heat aging, electrical properties, optical clarity, permeability, flame retardance, and processibility. Because of the diversity of consumer requirements, additive requirements are often complex. They may include mold release agents, f 1 ame retardants, f i 1 lers, low-shrink, low-prof i le additives, tougheners, and thickening agents, colorants, foaming agents, lubricants, antioxidants, antistatic compounds, ultraviolet stabilizers, lubricants, plasticizers, and free radical initiators. There are literally hundreds o f chemicals used as additives. Four functional classes of additives are fillers, plasticizers, reinforcements and colorants. These account for about 90% of all additives used in plastics. Compared to resins, these materials are generally chemically inert. Except for plasticizers, they are unaffected by light, heat and atmosphere. The remaining 10% of plastics additives are dominated by flame retardants. These are chemically reactive and generally hazardous.

* Hazardous material

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8720052-S2 COT-10

The hazardous waste classification caveats stated above for resins and catalysts also apply for additives.

Plastic additives enter the environment via various routes. During processing, additives may form volatiles, aerosols, and particulates. As wastes, these chemicals can leach and contaminate water supplies. Examples of additives are:

Antioxidants - alkylated phenols and bisphenols, alkylidene polyphenols, polyalkylated phenols, amines, esters, organic phosphates, and phosphates

Antistatic compounds - amines, quaternary ammonium compounds, anionics, various proprietary substances

Flame retardants - various types, including many ha hydrocarbons, metal (e.g., antimony, barium) salts

Free radical initiators - alkyl peroxides, azos, di etc.

Lubricants - esters, amides

Plasticizers - chlorinated paraffins.

ogenat ed

cy1 perox i des,

The use of additives in plastics is not necessarily based on solid technical rationale. Use is often based on the operator's prior experience to achieve the desired properties and performance of the fabricated item.

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3.1.5 Solvents Solvents are used in large quantities for diluting the resin mix and

for equipment clean-up. Acetone, methyl ethyl ketone and methanol are most frequently used. These are all listed hazardous wastes, as found in Table 3-1.

3.2 PROCESS DESCRIPTIONS

Typical processes are described in the following two sections under mold-based fiberglass products and coated fiberglass products.

3.2.1 Mold-Based Fiberglass Products

of steps detailed below: Manufacture o f molded fiberglass products generally involves a number

Mold preparation Waxing mold Resin preparation Gelcoat application Fiberglass application

The sequence of operations in a typical mold based manufacturing process is shown in Figure 3-1.

3.2.1.1 Mold Preparation.

molds often require a fine finish and considerable detail work. are made of wood with a plastic finish. is sometimes used in the mold preparation, creating a clay-like material. Methylene dianiline (MDA) is mixed in, sometimes by hand. MDA vapor appears not to be a significant threat to respiratory function because MDA has a very low vapor pressure.

At some plants, molds are constantly being built and redesigned. These Most molds

An epoxy resin system with filler

However, skin contact i s hazardous.

3- 7

Wax Mold & Spray Gelcoat & Drying Step

1st Resin Spray b Trim Edges M d Dry

h 1

Trim, Dry, Separate

from Mold 0 2nd Resin Spray , 0 Finished Piece Add Reinforcing

Materials

Figure 3-1 WASTE AUDIT PROCESS SCHEMATIC - SPRAY MOLDING

3-8

3720C52-S2 C O T - 1 2

3.2.1.2 Waxing Mold. Waxing of molds is done with paste wax and rags, similar to waxing a

car. No significant hazardous waste generation occurs.

3 . 2 . 1 . 3 Resin Preparation.

stored either in a tank or 55-gallon drums and is pumped from storage into spray or chopper guns. Filler and pigment may be added to the resin in the tank or drum. Solvent and catalyst are added through a separate feed line.

Most companies purchase pre-promoted resin. Generally, the resin is

3.2.1.4 Gelcoat Application.

styrene content is approximately 35%. Application to the product is with either an air atomized or airless spray gun. spray booth. weighed amount into a container feeding the spray gun. catalyst can be injected through a separate line into the gun head where it mixes with the resin. Once reacted or polymerized, polyester resins are thermosetting. When cured, they cannot be softened and reshaped by heat. Polyester resin in spray-upllay-up operations genera ly results in use of a clean-up solvent. Most often acetone and occasional y methylene chloride are used. The clean-up solvent is used liberally to keep the spray gun unclogged and to clean the hands o f the operators.

Gelcoat is a pigmented resin or a polyester resin based paint. The

It is usually conducted in a

Alternatively, the The catalyst can be added to the resin by hand mixing a

3.2.1.5 Fiberglass Application. For fiberglass molded products, the viscous resin is either mixed with,

sprayed or brushed onto fiberglass reinforcing material. in either a woven mat or cord-like roving which is applied with resin during fabrication. mix to provide additional body.

Fiberglass comes

Fillers.or thickeners can be stirred into the resin

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8720052-S2 COT-13

3.2.2 Coated Fiberglass Products

the substrate and the coating. such as fiberglass matting. production process for composites is discussed below. A process flowsheet for a typical composite product manufacturing operation is shown in Figure 3-2.

Coated composite sheeting consists of two distinct parts. These are The substrate is usually a woven material

The coating is a synthetic resin. The

Descriptions o f specific unit operations are as follows:

3.2.2.1 Epoxy Resin Pretreatment. In this step, the epoxy, catalyst, any fillers, and solvent are added

to a reactor. Heat starts the resin curing process. The reactor must be washed and rinsed with solvent between pretreatment batches, especially when two consecutive pretreatment batches consist of different epoxy formulations.

3.2.2.2 Resin Mixing.

catalyst, filler, pigment, and stabilizer. The mixture results in properties tailored for the product being run. calculated based on the quantity of fabric to be produced.

This step mixes in the other chemicals. These include resin, solvent

The quantity mixed is Mixing the

improper quantity can generate excess resin waste.

The mix can be covered and stored in a cool room until it is used. Most mixes can be stored for about 14 days at 45°F without adverse effect on product quality.

There are literally hundreds of possible mix types. These are determined by customer requirements which cannot be control led. variety o f resin mixes and strict customer specifications are two major factors limiting efforts to reduce and recycle wastes.

The

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LEGEND

Lab Pack and Manulwturer Samoles

i- I

I I- Chemical Storage Warehouse / Bulk Storage Tanks 0 Hazardous Waste Management Step

I I

- Epoay Resins.

Solrent Solvent Pigments Solvent Solvent catalvsts. Wash/Rlnse Addmres WashlRinse WashlRinsc

- Recovered Solvent Epoxy

Pretreitment Fumes Reactor

Mir ing V l t l

Completed WeshlRinv Solvent Wish /Rinse Solvent Production md Leftover and Scrap Solvated Rolls Mix Bitches Resin

t t WashlRinse Solvent

WashlRinc Solvent Treater

Mixing V8lS ac-product

Samolmp from Chemical 4 Catalvsts Storlgc Additives

- - Solrent (as Diluentl

%rap Solvated Resin

WashlRinse Solvent WashlRinse Solvent

Hazardous Waste Landfill

t A Leltovcr Mia Batches

U Discard alter Retain P e r d

Recvclcd Solvent to Chemical Storage

+ Solvent Stdl Bottoms lo Hazardous Waste - --- Stor.ge

Process Steo

Process Line

Auxiliary Svstcms

SlittinglRewind (when required)

I %rip Pre-Prcg Fabric

Scrip Pre-Prq Fabric

Fiaure 3 7 WASTE AUDIT PROCESS SCHEMATIC ~ COMPOSITES MANUFACTURF

8720052-S2 COT-14

F I

3.2.2.3 Fabric Coating and Heat Curing. The specific gravity o f the resin mix must be adjusted by adding

solvent at a small reservoir tank upstream of the treater pan. pan holds the resin which coats the fabric. resin is continually circulated between the reservoir and the treater pan.

The treater During the coating process,

The pan and associated piping typically hold about 100 pounds of ~

I resin.

The coating process begins by filling the treater pan. The fabric to be coated is loaded onto the unwind shafts. The fabric dips into the pan and then passes between two metering rollers. approRriate amount o f resin into the fabric. speed of the fabric through the mix pan, the spacing of the rolls, and the final specific gravity of the resin. can result in offspec material and a shortage or excess quantity of resin applied. process variables.

These squeeze the The operator controls the

Improper setting for these parameters

The mix quantity is calculated based on specific values for these

The coated fabric is then fed to the treater. This cures the resin coating at an elevated temperature. solvent. for solvent recovery or burned in a thermal oxidizer. Heat recovery from the thermal oxidizer may be used to cure the composite in the treater. cured composite is cooled before it is wound on the final roll.

The curing heat drives off the The solvent-laden air stream may be passed through a condenser

The

At the end of a run, the resin pan must be emptied and cleaned. The leftover solvated resin must be recycled or managed as hazardous waste. Figure 3-3 depicts the fabric coating and heat curing process.

3.2.2.4 Slitting/Rewind.

roll i s slit and rewound into separate rolls of 2-inch-wide tape. If a product roll is soiled or rolled imperfectly during production, the operator marks the damaged section for removal during rewind.

Some products are required in 2-inch widths. Then a full-width product

3- 12

W I

w

I I 1 I I I I I I I I I

I I I I I I I

I I

I

I 1 I I I I

Heat Curlng ’ Section

/ Cooling Section

scrap prepreg Fiber

x / Treater Pan

Solvated Resin Waste Rinse Solvent Waste a

Figure 3-3 FABRIC COATING AND HEAT CURING PROCESS

3720052-S2 COT-15

3.3 WASTE GENERATION

The generation of hazardous waste by-products in the manufacture of FRP and composite plastic products is common. These hazardous waste by- products may be in the form o f chemical-contaminatcd reagent and additive containers, solvent rinse liquids used in machine cleaning, fume Sxhausts, wash-down wastewater, and contaminated hydraulic fluids. The quantities of waste generated range from one or two gallons per month to several tons, depending on the products manufactured and the size of the plant.

3.3.1 Liquid Waste Liquid hazardous waste ' ,eludes:

Cleaning solvent from equipment cleanup Scrap solvated resin leftover in mix tanks and diluted resin from the treater pan Partially cured resin

The mix vessel and treater clean-up waste solvent is contaminated with resin from the cleaning. and treater pan at the end of a run, and any leftover mix resin that cannot be stored for later use. a small quantity, infrequent product run using only a partial drumload of a

The scrap solvated resin comes from the piping

The partially cured resin generally results from

resin.

3 . 3 . 2 Solid Waste Solid waste includes:

Gelcoat and resin overspray material that lands on the floor instead of on the mold.

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8720052-S2 COT-16

Unused raw material resin that has exceeded the shelf life date or otherwise thickened beyond usefulness.

*

Sawdust collected with the swept-up floor waste generated in the resin delivery step.

Raw material containers including plastic containers for organic peroxides, boxes for glass roving, drums for Gelcoat, and paper bags for Cabosil and aluminum trihydrate additives.

*

* Empty resin and solvent drums.

Pre-preg waste fabric.

* Clean-up rags.

* Lab packs from research operations.

Scrap pre-preg material may also be generated when a product does not meet customer specification or is otherwise discarded.

Empty drums may be collected by a barrel reconditioning company, often at no charge. projects should be collected for hazardous waste disposal.

Rags from clean-up operations and lab packs from research

From the standpoint of hazardous waste minimization and exposure, two so1i.d wastes are most significant. These are resin overspray and the resin and Gelcoat waste that has th

* Hazardous waste

3- 15

occupational the Gelcoat and ckened.

8720052-S2 COT-17

3.3.2.1 Gelcoat and Resin Overspray The Gelcoat overspray accumulates as a paint-1 ike coating wherever it

settles and dries. From plant audit data, approximately 85% of the resin spray goes onto the mold and 15% ends up as waste. sawdust may be raked up from the floor and disposed in a dumpster.

Sawdust is often provided as a floor protector.

After each item is sprayed, the overspray and

3.3.2.2 Thickened Gelcoat and Resin The waste from thickened Gelcoat and resin that is no longer suitable

for spraying is solidified further by mixing with catalyst. The solidified material is then discarded as a non-hazardous waste. Similar waste is also obtained when the resin tank is cleaned. This is often an annual occurrence.

The cost of Gelcoat and resin waste disposal is often small. However, the lost use of raw material (resin and catalyst) is a more significant cost. of raw materials are lost.

For each 100 pounds of resin disposed in this way, approximately $70

3.3.3 Volatile Waste Any open vessel containing solvent generates fugitive emissions.

Fugitive air emissions are often generated during mixing and in the treater, where excess solvent from the coated fabric is driven off during the resin curing process. Emission rate of a treater may range up to 100 pounds of solvent per hour.

The use o f ventilation and a thermal oxidizer can capture and incinerate approximately 80 percent o f the solvent emissions. the-art techniques allow recovery of solvents by activated carbon economically in concentrations above 70 ppm. reclamation is not economical thermal oxidation o f the solvent emissions can be conducted, with an oxidation efficiency exceeding 97,percent.

State-of-

When solvent vapor

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8720052-S3 COT-1

4.0 SOURCE REDUCTION

Source reduction can reduce the amount of hazardous wastes generated by a manufacturing operation. capital requirements. composite plastic product manufacturers only require housekeeping changes or minor in-plant process modifications. sav i ngs.

Some source reduction approaches have low Many o f the source reduction options available to

These can yield significant cost

The following categories of source reduction were identified during this study:

Optimized material application Use of thermoplastic resins Improved operating practices Inventory control

Waste reduction opportunities in these categories are discussed in the following sections. Economic details are presented in Section 7.2.

4.1 MATERIAL APPLICATION

Significant waste reduction is available by optimizing material application processes. non-spray resin application methods. reinforcing, in-house resin impregnation, resin roller. dispensers, vacuum bag molding processes and closed mold systems. methods reduce material waste and other expenses, in particular energy

These processes include spray delivery systems and The latter include prespray fiber

Non-spray resin application

4- 1

8720052-S3 COT-,?

purchase cost. the cost and maintenance of pressure lines, pumps, controls, and fittings. Routine cleanup of work areas is also reduced in terms of frequency and difficulty.

Lower oDerating pressures for spray delivery systems reduce

4.1.1 Spray Delivery Systems ’

Most open mold fabricators o f fiberglass products utilize resin spray applicators for transferring and applying coatings, resins, and fibers to the mold. Conventional gun-type resin application systems use compressed air, high fluid pressures, or combinations of fluid pressure and compressed air to atomize resin materials. Catalysts for the resin systems are normally introduced inside the spray apparatus or as the resins are atomiz’ed from the spray nozzle. These systems may also be equipped with glass choppers which chop fiberglass roving into short lengths and propel it onto the molding surface. Application of the Gelcoat layer does not require the glass chopper attachment, since resin only i s applied i n this step.

The fabrication process for fiberglass-reinforced plastic (FRP) products and the waste produced is highly dependent on the equipment and procedures used. The current line of resin and Gelcoat delivery systems used by FRP fabricators include high-pressure air, medium-pressure airless, and low-pressure air-assisted airless spray guns. In the order listed, the atomization and spray patterns become more efficient, reducing excessive fogging, overspray, and bounceback. Other key issues associated with these delivery systems are as follows:

The high-pressure air system is practically obsolete due to the large amounts of expensive high-pressure compressed air required and high air emissions o f styrene. In California, styrene emission limits generally cannot be met using a high-pressure air system.

4- 2

8720052-S3 COT-3

In the airless method a pressurized resin stream is electro- statically atomized through a nozzle. spray angle can be varied by using different tips. the orifice affects the delivery efficiency, with larger orifices resulting in greater raw material loss. Airless spray guns are considered to be very efficient in delivering resins to the work surface, however excessive fogging, overspray and bounceback may occur.

The nozzle orifice and The size of

The air-assisted airless technology modifies the airless gun by introducing pressurized air on the outer edge of the resin stream as i t exits the pressure nozzle. which focuses the resin to follow a controllable, less dispersed spray pattern. Lower resin delivery pressures can be used since the air assist helps distribute the resin. pressure also reduces fogging, overspray, and bounceback which in turn reduces raw material waste. Since more resin ends up on the product, the amount of spraying is reduced, leading to a reduction in styrene air emissions. net loss of resin spray waste for an air-assisted airless gun compared to an airless gun were given by vendors.

The air stream forms an envelope

Low air delivery

Estimates of 5 to 20% savings in the

4.1.2 Non-Spray Resin Application Methods While

most open processes efficient Spray del

use o f spray delivery of resins has become standard practice for mold fabricators o f fiberglass products, alternative application do exist. Conventional gun-type resin application systems are in delivering large quantities of resins to the work surface. very systems are also advantageous when the product mold has many

recesses or is convoluted. or even impossible in some cases. consideration in other circumstances. The various non-spray resin application methods are as follows.

Non-spray application techniques would be messy However, other delivery techniques merit

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8720052-S3 COT-4

4.1.2.1 Prepreg Fiber Reinforcing. Use o f fiber reinforcements that are presaturated with resins

("prepregs") offers a number of advantages over conventional spray techniques. In particular, resin to fiber ratios can be strictly controlled; atomization of pollutants is practically eliminated; and cleanup and disposal problems are greatly reduced.

Prepregs are generally formulated with more expensive epoxy based resins which require placing the mold in an oven or autoclave to complete the cure cycle. These more expensive resins are normally combined with exotic, high strength reinforcing materials, such as graphite fibers. Storage is a problem since the materials must remain refrigerated until the lay-up process is begun. Because o f the higher raw material cost, energy requirements for curing, and the storage needs of prepregs, they appear to be best suited for applications where extremely high strength-to-weight- ratios are required and cost factors are secondary.

4.1.2.2 In-House Resin Impregnation.

advantages offered by prepregs while using lower cost polyester resins and fiberglass materials. area of a plant and can be mounted in such a manner as to feed resin saturated reinforcing materials directly to the molding operation. Conventional resin pumps and catalyst metering devices supply resins to a roller-reservoir system. through this reservoir system.

Equipment is now available to provide the fabricator with some of the

Impregnators can be placed within the lamination

Woven fiberglass is impregnated as it passes

Impregnators can be designed to fit a variety of potential applications. The units can be mounted to overhead track and lift systems, over stationary conveyor feed lines, on bridge cranes, or on portable carts. Conventional resins and roll fiber materials can be used. Machine size and capacity can be engineered to provide a variety o f output feed rates and to accommodate a number of roll widths. Units currently

4-4

8720052-S3 COT-5

available can produce as much as 20 linear feet per minute. ratios are controllable to within 22%.

capacity exceeding 1,000 pounds of laminate per hour with a 50% glass content.

Resin-to-glass Larger units have an output

Impregnators appear to have considerable potential for the reduction of pollution associated with open molding operations, to the reinforcing laminate by means o f an impregnator would help ensure that a cleaner, safer, and more comfortable work area would be maintained. Since there would be no spray atomization of resins, the levels of in-plant and external emissions would be minimized. Raw material waste due to overspray/bounceback and requirements for high levels of make- up’ air and elaborate air handling systems are eliminated or greatly minimized. A typical in-house resin impregnator system for fiberglass is shown in Figure 4-1.

Delivery of the resin

4.1.2.3 Resin Roller Dispensers.

lines. head. A perforated T-bar attachment directs the catalyzed resin directly onto the roller surface.

These units pump resin and catalyst from drums or bulk distribution Resin and catalyst are precisely metered and mixed in a gun-type

A resin roller dispenser is shown in Figure 4-2.

Resin roller dispensers can transfer catalyzed resins t o the molding surface while reducing material losses due to excessive fogging, overspray, turbulence, and bounceback. The low delivery pressures required can help ensure maintenance of a cleaner, safer, and more comfortable work area. External emissions and the need for high levels of make-up air are also reduced.

4.1.2.4 Vacuum Bag Molding Processes.

operations. techniques required for production of conventional molds.

These processes can replace many conventional open molding Molds are produced from the same materials and with the same

Resins and

4-5

- - reinforcinp fiber

resin resetvoir t1 squeeze roller

c

Figure 4-1 IN-HOUSE IMPREGNATOR SYSTEM FOR FIBERGLASS

4- 6

-

hose attached to resin mix chamber

T-bar dispenser resin

O l I

Figure 4-2 RESIN ROLLER DISPENSER ATTACHMENT

4- 7

8720052-S3 COT-6

filler materials differ little from those used to produce components in conventional open molds. Conventional gel coating operations can also be uti 1 ized.

Vacuum bagging is carried out in a sealed mold at room temperature. Processing begins with the application of a gel coat to the surface o f the mold. When a high quality finish is desired, a surfacing layer of glass is carefully placed over the gel coat. Glass reinforcing and other materials, such as core stock, are cut to fit and placed in the mold. Catalyzed resin can be sprayed, pumped, or poured over the lay-up. Where multiple layers of reinforcing and/or core materials are used, the resin should be applied so that proper distribution to all parts of the lay-up can be assured. Once tfie lay-up materials are in place, the exposed area i s covered by special layers o f plastics which are sealed to the edges of the mold. Before the resins begin to cure, a vacuum is drawn through one or more strategically located ports in the mold or the plastic cover. shows a typical vacuum bag molding setup.

Figure 4-3

Benefits can be derived from vacuum bag lay-up. With the exception o f the gel coat, resin delivery can be accomplished without atomization. Labor involved in rolling out air bubbles and distributing the resin is reduced since the vacuum can be used to ensure full distribution of resin to all parts of the lay-up. A high degree of control o f resin-to-glass ratios can be maintained by carefully controlling the vacuum and by providing a bleeder material to absorb excess resin. Complicated lay-ups of reinforcing core stock can be accomplished in one operation instead of in steps which require that the resins be cured before new layers are added. Product quality and strength are improved since the vacuum removes trapped air and serves as a clamp to insure tight bonding of all materials in the lay-up. The release film, or ply, applied over the lay-up can be smooth or textured to produce a rough, smooth, or patterned surface.

4-8

f

lay-up vacuum bag 1 core I 1 bleeder

material

seal nttape f film sealant tape

to vacuum mdrd to vacuum

#

Figure 4-3 VACUUM BAG MOLDING SETUP

4-9

8720052-S3 COT-7

When spray guns are not used to deliver resin to the mold, air pollution and waste output can be greatly reduced. distribution of the resin to all areas of'the lay-up is largely controlled by the vacuum, gel coating is the only step in vacuum bag molding that requires atomization of resin. resin into a closed mold eliminates fogging, bounceback, and overspray. Vapor emissions and odor are further reduced by confining the resins in the covered mold until curing is complete. bleeder material placed under the vacuum bag. secondary grinding operations are reduced because the closed molding system eliminates most flash removal and edge smoothing requirements.

Since final

Pumping or pouring premixed catalyst and

Excess resin can be trapped by Even dust-generating

4.1.2.5 Closed Mold Systems.

atomization of resins and may offer a number o f production advantages over conventional approaches to molding. The closed molding technologies most frequently applied to production of fiberglass components are compression molding and resin transfer molding (RTM).

Closed molding operations practically eliminate requirements for

In compression molding, the molding compounds are compressed between Output is high because the heated matched molds, usually made of metal.

molding compounds cure rapidly in the heated mold. satisfactory finish without application of a gel coat.

Some materials yield a

Resin transfer molding also utilizes matched molds. However, the matched molds do not have to be made of metal, and high pressure mold closing systems are not required. The spray atomization gelcoat step cannot be eliminated in the RTM process.

With the closed mold processes, pumping catalyzed resin instead of spraying eliminates fogging, bounceback, and overspray. Vapor emissions and odor are further reduced by confining the vesins in the mold until curing is complete. There is little, if any, waste of resin. Even dust

4- 10

8720052-S3 COT-8

producing secondary grinding operations are reduced because the closed molding system eliminates most flash removal and edge smoothing requirements.

4.2 THERMOPLASTIC RESINS

Thermoplastic resins are easily reused. By the application of heat, the resin is returned t o a liquid state and can be reused in the manufacture of molded plastic products. faster curing cycles, lower emissions during processing, lower costs per pound o f raw material, ease of recycling, and lower labor intensity. Open molding of thermosetting plastics is likely to continue as a viable process be'cause of the design constraints associated with many products, limited unit production requirements, performance requirements, and market demands. However, recent advances in processing technologies and thermoplastic resin systems are causing the industry to examine alternative approaches to other molding processes. New thermoplastics can be reinforced with fiberglass or other fibers. strength of thermosets.

Thermoplastics processing offers

These materials can rival the

4 . 3 OPERATING AND WASTE MANAGEMENT PRACTICES

Improving operating efficiency and waste management practices can provide significant source reduction opportunities. operating practices and waste management improvements were identified as opportunities. Some apply to the spray mold process, some to composites manufacture, and some to both.

The following

1.

2.

Change spray orientation in the spray mold processes to reduce overspray and bounceback wastes.

Reduce solvent usage for treater pan and vessel cleanouts.

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I 8720052-S3 COT-9

3. Modify the resin delivery process for the short width fabric to produce less solvated resin waste at the end of a treater run.

4. Use a small pipe size for piping between the resin delivery reservoir tank and the resin pans on the treater.

5. Segregate wastes wherever possible.

Each o f these are discussed in detail below, including an economic analysis of the benefits of the recommended improvement where appropriate.

4.3.1 Spray Orientation

often occurs because the tip of the spray gun i s directed downwards to the bottom of the object, and not horizontally (see Figure 4-4).

Waste often accumulates around the bottom of sprayed objects. This

Likewise, it may be difficult for the operator to shoot the top o f high objects. instead of horizontally, the spray dissipates as a fine mist up to several feet away from the object.

If spraying is directed vertically to the top of the object

Operators at one plant were often observed using overturned paint

However, overspray waste sti 1 1 buckets as stools so they can shoot down at tall objects and thereby obtain better coverage and reduce overspray. resulted if the operator was not high enough.

4.3.2 Reduce Rinse Solvent Usage

pretreaters, mix tanks and treater pans. Using small lab-type wash bottles for treater.pan cleanouts can reduce solvent usage. Squeegee tools can also be used for the treaters and vessels cleanouts. smaller amount of solvent can be applied to the vessel to dissolve the solvated resin remaining.

Substantial quantities of solvent are used for cleanout of epoxy

Subsequently a

The squeegee may also be pressed against the

4- 12

CURRENT SPRAY OR1 ENTATION IMPROVED SPRAY ORIENTATION

SPRAYING LOWER PORTION

Resin Floor Waste/

SPRAYING UPPER

Stepladder ’

PORTION

Figure 4-4 FIBERGLASS WASTE AUDIT RESIN SPRAY TECHNIQUE

4-13

8720052-S3 COT-10

vessel walls to force the remaining resin to the bottom of the pan or vessel for collection. A reasonable estimate for the solvent usage reduction due to squeegee usage is 25 percent.

4.3.3 Modify Resin Pan

110 pounds of solvated resin - the contents o f the treater pan and piping to the treater pan - was wasted at the end of every run. different treaters, with pan widths o f 60", 78", 84" and 86", may be used by an operator. wider than the fabric should be used. If a narrow width fabric is run in an unnecessarily wide pan, an additional quantity of solvated resin is wasted, since the wide pan holds a larger quantity of solvated waste resin at the end of the treater run.

At one of the plants audited, it was estimated that approximately

It was noted that

It was recommended that a pan width no less than 10 inches

A simple adjusting device can be made to fit into the treater pan to reduce treater pan waste production. wooden, or metal part molded to fit into the end o f the treater pan which would occupy volume in the treater pan usually filled with resin but not required when coating the narrow fabric.

This could consist of a plastic,

4.3.4 Reduce Transfer Pipe Size

tank. discarded, along with the resin in the pipe that goes between the mix tank and the treater resin pan. installing smaller diameter pipe. For example, changing the pipe diameter from 2 inches to 1 1/2 inches would result in more than 1000 lb per annum reduction in resin usage.

Typically, several feet of pipe connect the mix tank and the treater Each time a run is ended the solvated resin in the treater pan is

Significant savings in resin can be realized by

4.3.5- Waste Segregation

process waste streams. Waste reduction may be available through the segregation o f the various

This can improve recyclability and reduce treatment

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8720052-53 COT-11

costs. mold industry, it is relevant to FRP composites manufacturing. Distillation and recycling of resin-contaminated solvent can only be done if the resin is epoxy. contaminated resins would promote solvent reuse.

Although waste segregation is not applicable to the FRP spray

Waste segregation of non-epoxy and epoxy-

4.4 INVENTORY CONTROL

Inventory control can be defined as management of the amount of raw materials, semi-finished goods and finished products within a plant. The fundamental principle of inventory control is to avoid having any more material on hand than is necessary to keep the plant running and priduct i ve.

Two sources of waste can be reduced by improved inventory control. One is material that has been in stock so long that it has exceeded its shelf life and must be disposed of. The other is material that is in stock but is no longer needed in carrying out the function of the plant.

4.4.1 Prevention of Surplus Inventory

generation of surplus inventory: The following initiatives should be taken to reduce or prevent the

1.

2.

Container Management. filled containers on site, materials should be purchased in larger containers or in returnable or reusable containers.

To reduce the quantity of empty or partially

Purchase Quantity Requirement. material needed for a specific production run so that no material is left over to put into storage.

Only purchase the quantity of

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3. Purchasing and Storing Resins. A number of approaches are utilized for purchasing resins for open molding operations. Many processors elect to purchase all materials in 55-gallon drums while others prefer to purchase resins in bulk quantities. Large firms, such as bath fixture manufacturers, purchase practically all general purpose resins in bulk and store these materials in large storage tanks.

4.4.2 Drum Management

rate, and may be difficult to dispose of. drums. Disposal of drums containing liquid residue may call for handling the drum as hazardous materials. Landfills will not accept drums containing liquids. Storage of full drums and empty ones is also a problem. Considerable floor space is required for storing large quantities.

Drums may create waste disposal problems. Drums can collect at a rapid Many landfills refuse to accept

A storage permit might be required.

4.4.3 Computerized Inventory Control

improve inventory control and identify areas for waste minimization. A

basic system can be set up us ng widely available spreadsheet or database programs. available from software companies such as Waste Documentation and Control, Inc. of Beaumont, Texas and Intellus Corporation in Irvine, California.

Computerizing raw materia purchases and waste generation data can

Alternately more task specific and user friendly programs are

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5.0 RECYCLING AND RESOURCE RECOVERY

Recycling and resource recovery includes direct use of waste as raw material for another process. It includes recovering valuable materials from a waste stream. It reduces hazardous waste generation.

In the plants au'dited in this study, a number of resource recovery opbortunities were identified. reuse of rinse solvents, waste exchange, and off-site recycling. details on these opportunities are in Section 7.3.

These were distillation, filtration, and Economic

5.1 SOLVENT USE AND WASTE MANAGEMENT

Solvents are part of operations at both FRP spray mold and composites coating manufacturing. methanol, methylethylketone (MEK), toluene, and xylene. equipment cleanup and for adjusting the specific gravity o f the resin before processing. of hands and spray equipment was recorded at one plant. from a second plant indicated that approximately 300 gallons per day of make-up solvent were required for resin dilution and equipment clean-up,

Solvents used include acetone, methylene chloride, These are used for

An average of 5 gallons per day of solvent for clean-up Inventory figures

especially vessel.rinsing. per day of solvent in clean-up.

The third plant audited used less than 1 gallon

Acetone and other similar solvents are used for general cleaning. This is standard practice for most open mold fabricators of fiberglass products. rollers, brushes, tools, finished surfaces, and the hands of employees

Solvents are used to remove uncured resins from spray equipment,

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8720052-~5 COT-2

involved in lay-up operations. usually circulated through the lines after the spray operation is shut down for the day. Open containers of acetone solvent may be kept near the resin spray area for hand and tool cleaning. The acetone cleaning solution is reused until the high concentration of resin contamination prevents effective cleaning.

To clean the spray equipment, acetone is

Disposal of contaminated solvents represents a major hazardous waste management expense. $300 per barrel. RCRA imposes "cradle-to-grave" responsibility for hazardous waste. Long-term liabilities and responsibilities exist for problems that might evolve from contaminated solvent storage or disposal. These long-term costs and risks must also be considered.

Prices for waste transportation and storage can exceed

In the past, some operators have allowed evaporation or spills to take care o f contaminated acetone. record keeping requirements are making these sloppy practices very risky, even for the smallest operations. In extreme cases, solvent users can be held accountable for solvent waste quantities based on records of solvent quantities purchased. regulated.

Recent developments in regulations and

On-site storage of contaminated waste is strictly Severe penalties may be imposed upon violators.

Considerable emphasis should therefore be placed on the recovery of solvents due to increased stringency of regulations for volatile organic emissions. cost is incurred. Given the status of current air quality regulations and rising solvent costs, alternative solvent management systems such as onsite recycling, off-site recycling, and incineration should be considered.

If solvents are left to evaporate naturally, no waste disposal Also, no savings are available from recycling.

5-2

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5.2 ON-SITE SOLVENT RECOVERY

-

Distillation can provide cost-efficient solvent waste management. Usable solvents are produced. reduced.

The purchase of new solvents can be A sampling of distillation equipment and prices is in Table 5-1.

5.2.1 Batch Distillation. Batch-type distillation units have proven to be successful in meeting

the needs of firms producing small to moderate quantities of contaminated solvents such as acetone. gallon units.

Unit sized commonly available range from 5 to 55

A basic batch type system consists of four major components-a contaminated solvent collection tank, a heated boiling chamber, a condenser, and a clean solvent collection container. A typical low cost system is shown in Figure 5-1. typically contained within a single compact cabinet. house a unit is generally less than the space required for storage of virgin solvents and contaminated waste.

The operating systems for these units are Space required to

There are a number of cost factors affected by-the use of batch distillation units. In comparison to conventional disposal techniques, the quantities of solvents which must be disposed of by hazardous waste handlers may be reduced by as much as 90%. produced, the outside purchase of virgin solvents can be significantly reduced. The units do require a modest initial investment. Prices may vary from approximately $3,000 for a basic 5 gallon per batch unit to more than $30,000 for a relatively sophisticated 55 gallon unit with labor saving automatic control systems and pumps.

Since usable solvents are

5.2.2 Continuous Distillation Large volume producers of contaminated solvents may find continuous

feed distil lation equipment better suited to their requirements than batch

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90189-T51 CON-1

Table 5-1. SOLVENT RECOVERY EQUIPMENT

Supplier

Temp. Equipment Limit Mode 1 Capac i ty costa ( O F )

Recyclene Products, Inc. R-2 5 ga1./4 hr. $2,495 ~375"

(415) 589-9600 RX-35AF 12-16 gph $25,850 <375"

405 Eccles Ave. RS-20 5 - 7 gph $11,000 <375" S. San Francisco, CA 94080 RS-35AF 6 - 8 gph $21,000 c375"

Solvent Distlln. Equip. LS-Jr. 5 ga1./8 hr. $2,995 ~320" Finish Engineering Co. LS-15 15 ga1./8 hr. $5,895 <320" 921 Greengarden Rd. LS-15V 15 ga1./8 hr. $9,390 ~500" Erie, PA 16501 (814) 455-4478

a 1986 dollars.

5-4

r

distillation unit

condenser recovered :ontamhated

Figure 5- 1 BATCH DlSTl LLATlON SET-UP

5- 5

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recovery units. commonly available can range from 250 gallons per shift to as much as 200 gallons per hour.

Recovery output for continuous feed systems which are

The continuous feed distillation system consists of the same components included in a batch type distillation unit together with more elaborate controls and materials handling equipment.

An automatic pumping system is required to transfer contaminated solvents from storage to the boiling chamber. water or air cooled. with &monitoring system to avoid overflow.

Condensers may be either The clean solvent collection system must be equipped

Just as with batch type units, there are a number of cost factors to be considered in the selection of continuous feed distillation units. Continuous systems require an initial investment that is much larger than that for smaller batch type units. Installation costs for large units are likely to exceed $50,000. These types of units are not likely to fit the requirements o f firms with recovery needs of less than 100 gallons per day.

5.2.3 Filtration Often solvated epoxy resin is the only resin suited to the batch

distillation process. Other non-epoxy resins (phenolic, polyamide, and polyester) have lower flash points and are more susceptible to runaway reactions. Reducing the solids content in solvated non-epoxy resin streams may be possible with filtration, yielding the same result without violating any temperature contraints.

5.2.4 Audited Plant Recycling

solvent recykling. The smallest plant used a crude filtering approach - dirtied solvent was poured over a mass of charcoal, whereby paint wastes would be filtered out onto the charcoal and the solvent recovered for reuse.

Each plant visited as part of this audit relied on some form of on-site

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A second plant had a small distillation unit capable of processing one 15 gallon batch over an 8-hour period. operating headache for the plant and therefore had not been operated for some. time.

This apparatus had become an

The symptoms of the problem included:

1) Excessive warm-up time 2) Batch cycle up to 16 hours instead of the standard 8-hours 3) Poor recovery percentages.

After discussions with the equipment vendor it was determined that the still's heat transfer media needed replacement.

At the third plant, a 55-gallon drum batch recycling still was operated 24 hours per day for non-epoxy contaminated solvent waste. handled both wash solvent waste and solvated resin waste. records were kept at the plant as to the quantity of solvent recycled, amount o f still bottoms produced, or percent recovery of the still operation.

This unit No production

5.3 REUSE OF RINSE SOLVENTS

At many plants, fresh solvent or solvent recycled from a still is used for various plant clean-up operations. In many cases, the used solvent can be stored and reused before being disposed or recycled. substantial reduction in operating costs, raw material costs, and hazardous waste disposal- costs can be realized.

In this way, a

This methodology appeared to be feasible at one of the plants audited since washout of vessels produced only moderate contamination o f the solvent. changes were recommended.

In order to implement this measure, the following operational

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1. The rinsing was to be divided into two steps - an initial rinse with recycled solvent would be followed by final rinse with fresh solvent. hazardous waste or recycled and the second rinse (with fresh solvent) was to be collected, stored and reused.

The first rinse was to be collected for disposal as

2. A procedure for segregating non-epoxy from epoxy rinse solvent was to be developed. the recycling still after the reuse step since the non-epoxy rinse solvent was potentially unstable in the still as the temperature was raised and the resin concentration in the still increased.

Non-epoxy rinse solvent was not to be recycled in

3. Storage tanks for the once-used solvent and pumps and piping between the tank and treater were to be installed in the treater building. Separate tanks were to be required for the non-epoxy and epoxy rinse solvent. Rinsing solution from the final rinsing step using clean solvent was to be collected from the treater and delivered to the recycled solvent tanks.

5.4 WASTE EXCHANGE

The U.S. Environmental Protection Agency has stated that when participation in a waste exchange program represents part of a generator's efforts to reduce the volume of hazardous wastes, such participation may be used to satisfy the waste minimization certification requirement on the Uniform Hazardous Waste Manifest used to track hazardous waste disposal.

In addition to helping meet regulatory requirements, participation in a waste exchange program provides the waste generator with an opportunity to explore alternative waste management options that may lead to a more cost- effective waste management program. vehicle for increasing recycling and resource reuse opportunities and can be an important part of a company's overall strategy to manage waste in an environmentally sound and cost-effective manner.

Waste exchanges are an effective

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Two wastes of the FRP spray mold and composites industries appear to be

The California Solid Waste Management Board was contacted for well suited for waste exchange listings--partially solidified resin and scrap fiber. leads to firms in the plastics recycling industry who might have a use for partially solidified resin. After talking to people at various plastic recycling companies it was apparent the industry is concentrating on thermoplastics which can be melted and reformed (such as polyethylene terephthalate (PET)). thermosets which cannot be reformed once they are cooled.

However, the resins used by the plants audited were

5,5 WASTE MANAGEMENT COOPERATIVE

The industry should make an effort to find recycled uses for thermoset Precise segregation of these

This can include milling wastes and miscellaneous reinforcing wastes. wastes can maintain a purity suitable for reuse. waste, reinforcing fabric trimmings and loose fibers. for formatting lower quality plastics and providing materials for other creative outlets. a waste management cooperative that could be established by an industry association.

Residues may be used

Reuse o f residues can be facilitated by the formation of

5.6 OFF-SITE SOLVENT TREATMENT AND RECYCLING

Commercial solvent recycling facilities are privately owned companies that offer a v-ariety of services ranging from operating a waste treatment/recycling unit on the generator's property to accepting and recycling solvent waste at a central facility. Some recyclers accept both halogenated and non-halogenated solvents, others specialize in one or the other. Many recyclers accept only non-halogenated wastes. Some companies specialize in a particular market, such as perchloroethylene recycling for the dry cleaning industry. volume of waste accepted and later credit the generator's account for the

The recycler might charge the generator by

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value of saleable solvent recovered from the batch of waste. Other recyclers charge a straight fee or accept waste at no charge depending on the type and volume of waste received. The value of a solvent waste to a commercial recycler depends on the type, market value, purity (quality) , and quantity of waste generated; how often the waste is produced; and the distance between the generating facility and the recycling facility.

Off-site commercial recycling services are often well suited to small quantity generators (SQGs). sufficient volume of waste solvent to justify on-site recycling. The off- site services are also attractive to generators who prefer to avoid the technical, economic, and managerial demands of on-site recycling. Off-site recycling has, however, the disadvantage o f potentially high transportation costs and liability.

This is because SQGs may not generate

5.6.1 Batch Tolling

batch tolling. In a batch tolling arrangement, the commercial recycler accepts solvent waste from a generator, distills or otherwise reclaims the solvent, and resells the recovered product to the original generator for reuse. Batch tolling is attractive if the price of reclaimed solvent is less than the equivalent grade o f virgin solvent.

A commonly practiced arrangement between generator and recycler is

5.6.2 Locations and Capacity

most commercial recyclers are located near the industrial centers for solvent waste generation; namely Los Angeles and Santa Clara counties. indicated from 1985 permits, the maximum solvent recycling capacity in California is approximately 140,000 tons. approximately 75,000 tons or 53 percent o f capacity.

The information available from the DHS permit database indicates that

As

Annual throughput for 1985 was

Table 5-2 shows a list of California TSD facilities specializing in solvent recycling.

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Table 5-2. WASTE SOLVENT RECYCLING FIRMS

Name Address Solvents Received

Services/Recycling Technologies

Allied/Baron Blakeslee, Inc.' Chlorinated and fluorinated solvents Pot distillation 3596 California Street San Diego, CA 92101 (619) 295-0041

Baron Blakeslee, Inc. 8333 Enterprise Drive Newark, CA 94560 (415) 794-6511

Chlorinated and fluorinated solvents Single plate distillation

Chlorinated and fluorinated solvents yl

c.r I Bayday Chemical c.r 2096-8 Walsh Avenue

Santa Clara, CA 95050 (408) 727-8634

Demenno/Kerdoon 2000 North Alameda St., Compton, CA 90222 than 100" F.

Petroleum solvents, gasoline, jet fuels, and naphthas with a flashpoint greater

(213) 537-7100

Detrex Chemical Industries, Inc. Chlorinated and fluorinated solvents Gold Shield Solvent Division 3027 Fruitland Avenue Los Angeles, CA 90058 (213) 588-9214

Distillation, electric

Filtration/sedimentation, decant / de -emu 1 s i f y / a i r flotation, vacuum distillation, flash distillation, steam stripping, boiler, chemical dehydration.

Single plate distillation

90189-T52 CON-2

Table 5-2. WASTE SOLVENT RECYCLING FIRMS (continued)

Name Address Solvents Received

1

Services/Recycling Technologies

Holchem/Service Chemical Chlorinated and fluorinated solvents Not available 1341 East Maywood Santa Ana, CA 92706 (714) 546-5890

Van Waters and Rogers, Inc. 5353 Jillson Street Comnerce, CA 90040 (213) 269-9531

Chlorinated and fluorinated solvents

ul c.’ I Oil and Solvent Process Company Aliphatic and aromatic hydrocarbons,

1704 West First Street Freons, chlorinated hydrocarbons, Azusa, CA 91702 lacquer wash thinner, all types o f (818) 334-5117 chemical solvents.

Omega Recovery Services All types of refrigerants, lithium 12504 East Whittier Boulevard bromide, halogenated and oxygenated Whittier, CA 90602 solvents, tetrahydrofuran, dimethyl- (213) 689-0991 formamide, Freons, paint wastes,

lacquer thinners, dry cleaning solvents

Orange County Chemical Co. 1230 East Saint Gertrude Place Santa Ana, CA 92707

Chlorinated and fluorinated solvents

(714) 546-9901

Stores solvents for transfer to other facilities for processing

Pot distillation, film evaporation

Film evaporation

Filtration, flash distillation

90189-T52 CON-3

Table 5-2. WASTE SOLVENT RECYCLING F I R M S (continued)

Name Address Solvents Received

Services/Recycling Technologies

P l a s t i c Mater ia ls, Inc. Ketones, ch lor inated solvents 3033 West Mission Road Alhambra, CA 91803 (818) 289-7979

Recl amar 131 North Marine Avenue Wilmington, CA 90744 (213) 835-3103

v1

t-’ 1 Rho-Chem Corporation w 425 I s i s Avenue

Inglewood, CA 90301 (213) 776-6233

Romic Chemical Corporation 2081 Bay Road East Palo Al to, CA 94303 (415) 324-1638

Drycleaning wastes containing perchloroethylene

D i s t i l l a t i o n

Not Avai lable

l , l , l - t r i c h l o r o e t hane, perch1 oroethyl ene, methylene chlor ide, t r i c h l o r o t r i f u o r o - ethane, alcohols, ketones, aromatics, lacquer th inner and pa in t thinners.

F i l m evaporation

A1 iphat i c , aromatic, ch lor inated and f l uo r ina ted substances; alcohols; esters, t r ichloroethane, methylene ch lor ide, 1 acquers, p a i n t thinners, Freons, ketones, tetrahydrofuran, methylpyrrol idone. Water wastestreams containing lower concentrat ions o f solvents l i k e acetone, methylethyl ketone (MEK) and isopropanol ( I P A ) . Also blend f o r i nc ine ra t i on a t another f a c i l i t y .

Fract ional d i s t i l l a t i o n

VI I c1 P

90189-152 CON-4

Table 5-2. WASTE SOLVENT RECYCLING FIRMS (concluded)

Name Address I Solvents Received

Services/Recycl ing Techno 1 og i e s

Safety-Kleen Corp. 8125 Sunset Avenue, S u i t e 259 F a i r Oaks, CA 95628 (916) 635-2542

Solvent Services, Inc. 1021 Berryessa Road San Jose, CA 95133 (408) 286-6446

Van Waters and Rogers, Inc. 2256 Junc t ion Avenue San Jose, CA 95131 (408) 435-8700

Van Waters and Rogers, Inc. 5353 J i l l s o n S t r e e t Comerce, CA 90040 (213) 269-9531

Hydrocarbon solvents, methylene c h l o r i d e Solvent exchange serv ice w i t h automobile r e p a i r shops.

A1 1 halogenated and non-halogenated s o l vents.

l , l , l - t r i c h l o r o e t h a n e and Freons

l , l , l - t r i c h l o r o e t h a n e and Freons

D i s t i l l a t i o n , g rav imet r ic separat ion

Stores so lvents f o r t r a n s f e r t o o ther f a c i l i t i e s f o r processing

Stores solvents f o r t r a n s f e r t o o ther f a c i l i t i e s f o r processing

Reference: D i r e c t o r y o f I n d u s t r i a l Recycles, C a l i f o r n i a Waste Exchange. Services , 1988.

C a l i f o r n i a Department of Hea l th

8720052-~5 COT-9

5.6.3 Selection of a Commercial Facility

recycling or treatment service: The following factors should be considered before choosing a commercial

1. Certification held by the facility (Interim Status Document or Permit?) .

2. Types o f solvent wastes managed.

3. Ability to meet solvent purity specifications i f the solvent is to be returned to the generator.

4. Availability of registered trucks to transport the solvent wastes.

5. Distance to the recycling facility and associated transportation costs.

6. Available laboratory facilities and analytical procedures.

7. Record keeping practices.

8. Availability of custom recycling services (e.g., vendor-owned recycling unit that can be operated on the generator's property).

9. Expertise in waste management strategies and process controls.

10. Insurance for recycl ing/treatment/disposal operations.

11. Disposal procedures for sti 1 1 bottoms and solvents that cannot be recycled.

12. State regulatory agency's compliance records on the facility.

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13. Current customers' comments on the facility.

14. Facility's financial stability.

These factors can be readily checked by visiting the recycling facility, by questioning regulatory agencies and by obtaining references.

5.7 RECOMMENDATIONS FOR IMPROVING RECYCLABILITY OF SOLVENT WASTE

A 1986 solvent waste reduction study' produced the following recommendations for improving the solvent waste recyclability.

A. Segreqate solvent wastes

Segregation of solvents was the most frequent suggestion to improve the recyclability of wastes. separating:

Specific recommendations included

chlorinated from nonchlorinated solvent wastes; aliphatic from aromatic solvent wastes; freon from methylene chloride; water waste from flammables.

B. Keep water out of the waste solvents

Drums should be covered to prevent contamination with water.

C. Minimize solids

* GuTde to Solvent Waste Reduction Alternatives - Final Report, 1986, ICF Consultinq Associates, Incorporated. Los Angeles. Prepared for the California Department o f Health Services, Toxics Substances Control Di vi si on.

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Solids concentration should be kept at a minimum to allow for efficient solvent reclamation.

D. Control solvent concentration

Maintain solvent concentration at 2 40 percent.

E. Label waste

Keep a chemical identification label on each waste container. Record the exact composition and method by which the solvent waste was generated.

5.8 OTHER RESOURCE RECOVERY OPPORTUNITIES

Resource recovery often involves managing a waste for reuse as a raw material in the same industrial process or in a different industrial process. Three typical resource recovery options are described below.

5.8.1 Recovery of Sawdust and Floor Sweepings

floor is swept up between spraying, the waste normally goes to a dumpster. Disposal may be at a Class 111 landfill. The cost is approximately $9/cubic yard.

Often sawdust is spread on the floor to capture overspray. When the

Sawdust reuse will reduce purchase and disposal costs. To achieve this, the following recycling method i s suggested: square holes can be fitted over the bin where the fresh sawdust is stored. The floor sweepings containing large matted pieces of resin- contaminated sawdust can be spread over the screen and the screen shaken back and forth to get as much loose sawdust to go back into the fresh sawdust bin as possible. The waste left on top of the screen is then transferred to the waste storage bin.

a screen with 1-inch

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Similarly, other small, dry particulate floor sweepings can be so screened and recovered. overspray.

These can also be spread on the floor to capture

5.8.2 Cardboard Recovery

be saved and sold to a paper recycling firm instead of being thrown into the dumpster. Other paper waste suitable for recycling includes empty cabosil and aluminum trihydrate bags and balsa wood cut-outs discarded from reinforcing operations.

Large quantities of cardboard cartons used to deliver glass roving can

5.8.3 Container Recycling

for on site management o f drums. The report i s expected to be available in June, 1989. Acceptable practices include cleaning o f reusable reagent and additive containers and the sale of the containers to scrap dealers or drum recycling firms. Drums could also be returned to the reagent supplier for refilling. wastes. In every case, the most important aspect in reuse or recycling of drums is that they be completely empty.

The DHS is working on a report which summarizes acceptable practices

Used containers may also be suitable for the storage o f other

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6.0 INCINERATION

The most common treatment alternative employed the composite plastic Incineration eliminates product manufacturing industry is incineration.

the liabilities associated with storage, reuse, and land disposal methods. However, air emissions and ash residues must be addressed.

6.1 INCINERABLE WASTE

Incineration is a waste management option for contaminated solvents, resins, contaminated clean-up rags and off-spec products. these wastes can provide economical heat recovery because high BTU value and low halogen content. Companies can install in-plant incinerators to burn waste solvents. Alternatively, off-site incineration may be attractive. One o f the plants audited discontinued landfilling of hazardous waste.

Incinertion of

It was transporting all wastes off-site for incineration.

Transportation remains a drawback of offsite plant incineration. Solvent waste must be transported by a licensed waste hauler. generator's responsibility does not end when it is loaded on the truck. The RCRA "cradle-to-grave" regulations place ultimate liability for proper handling and disposal of waste with the generator o f that waste. includes any impairment caused by transport accidents or migration from a landfill site.

The

This

6.2 INCINERATION BARRIERS

Because of land disposal phaseout, the demand for incineration services is growing rapidly. At the same time, new incineration capacity is slowed

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8720052-~6 CON-2

by siting barriers. The near future for incineration will surely be a seller's market. and competition among generators for access to available capacity. Generators should avoid this developing constraint by seeking alternatives to incineration.

There will be continued escalating costs for the service,

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7.0

ECONOM ICs

The cost of various waste reduction technologies determines the feasibility of using it in company operations. investments in equipment and installation, production down-time during installation, operation and maintenance, and impact on product quality and production capacity. including reduced waste management costs and raw material costs. benefits are difficult to quantify. liabilities associated with generating, storing, and managing hazardous wastes. will vary with plant capacity, raw material usage, and waste generation characteristics and volumes.

Costs include capital

These costs must be compared to potential benefits, Other

These include reductions in potential

The cost/benefit analyses for waste reduction at a specific plant

This chapter contains examples of cost/benefit analyses that can assist plant personnel evaluate the economics of their own specific waste reduction opportunities. consumer waste reduction opportunities are presented together with the potential savings these opportunities can provide.

The cost parameters associated with many o f the

7.1 BASELINE MEASUREMENTS

savings is to determine the current historical data such as the quantit wastes produced are not avai lable. are made during the waste audit.

One of the first steps in defining any waste reduction or raw material these materials. Often, coat, resin, wash solvent and to determine these parameters

usage of es o f Ge Attempts

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At one plant audited, waste quantity estimates were based on observations made from the production of one large shower stall. shower stall was sprayed, the overspray remaining on the floor was collected and weighed as waste. be approximately 15% of the total resin and fiberglass applied. the accuracy o f this estimate was affected by the practicality of the procedure. In particular, the following two items affected the determination:

After the

The waste so generated was calculated to However,

1. When sprayed resin waste was collected from the floor, sawdust which stuck to it was also collected and weighed as part of the waste. This error can be voided by weighing the sawdust applied to the floor before spraying. is weighed. waste.

-. -

Then all the sawdust and sprayed resin waste The difference in weight represents sprayed resin

2. Sprayed waste further than 2 feet away from the object was not collected, since sawdust sticking to the resin would be collected along with the sprayed waste, and beyond two feet it seemed likely that more sawdust than sprayed waste would be collected.

It was assumed the extra sawdust from 1) would partially offset the amount of waste missed from 2), but this assumption could not be verified.

An alternative method for estimating the waste generated per the above example is to measure the difference between the weight resin and glass delivered to the weight of resin and glass in the product. The delivered weight of resin and fiberglass can be mea

materials and associated subtracted from the fina resin/glass in the final

tem in of the final ured by

placing the resin barrel and glass roving on a scale and noting the initial ‘and final weight on the scale. When several items are completed and in the yard awaiting shipment, the final product is weighed and miscellaneous

weights that are part of the item must be ght of the

product weight to obtain the we product. The difference between

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8720052-~7 COT-3

fiberglass/resin weight in the final product and the measured fiberglass delivered from the resin barrel and glass roving is the weight of the waste fiberglass.

7.2 SOURCE REDUCTION

Technical details on these opportunities are in Section 4.0

Improved operating practices, good housekeeping, and process modifications can reduce or eliminate hazardous waste generation. Improved operating practices generally have the least immediate cost. because they do not require extensive changes in plant equipment. However, implementing the revised operating procedures may reduce plant efficiency in the short term. The revised procedure may also increase labor and other costs. Therefore, a comprehensive economic analysis should be prepared for all source reduction options. It should include expenditures, operating costs, and reduction in waste disposal cost A s an example, a plant may consider the use of a detailed record keeping system for the type and quantities of flushing media. for additional rinsing/flushing or as a diluent in subsequent formulations. The cost components o f this system would include:

This is c. .

This could be used to optimize media reuse

The design and printing of record keeping forms;

Training plant personnel to use the new record keeping system and meet waste reduction goals;

The labor required to enter the information on the new forms;

The additional management cost required to review and evaluate the new records;

The value o f storage space needed for used rinsing/flushing media.

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Other source reduction opportunities described in Section 4.0 include adjusting the spray orientation during fiberglass application; using air- assisted airless guns in fiberglass delivery; improving clean-up procedures resulting in reduced solvent usage; and modifying treater pans and transfer pipes to reduce solvated resin waste. The economics of these recommended source reduction opportunities are discussed below.

7.2.1 Improve Spray Orientation Raising the mold so that less overspray is produced was recommended at

one of the plants audited. to the rolling carts which handle the mold were specified.

ment, also required that the operator use ladders or similar equipment when spraying the top of the object. changes was estimated to be $400. shooting the objects would probably increase slightly at first as the operators adjusted to the new situation. difference would result. resulting reduction in raw material waste was estimated to be at least

To implement raising the mold, modifications These

\--modifications, which could be made with a small capital and labor invest-

The total investment for the necessary It was assumed that the labor costs for

In the long term, no labor By raising the object height when shooting, the

25%. This translated to approximately 2 percent reduction on the production cost. Shooting 10 objects per day would result in a payback period of 10 work days. estimated. Details of the economic analysis are presented in Tables 7-1

and 7-2.

An annual raw material cost savings of $9600 was

7.2.2 State--of-the-Art Spray Gun Estimates of 5 to 20% savings in the net loss of resin spray waste for

an air-assisted airless gun compared to an airless gun were given by vendors. An estimate of the payback period for purchasing an air-assisted airless gun (at $1500) is calculated at 100 days or 5 months in Table 7-3. In this example, the annual savings gained by installing an air- assisted air gun for resin/glass fiber delivery was over $3700.

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Table 7-1. FIBERGLASS SHOWER STALL COST DATA

Total Cost for

Item One Large

Quantity o f Unit Price Shower Stall % o f Total Raw Material (Dollars) (Dollars) Unit Cost

Ge 1 coat 20 pounds 1.03

Initial Fiberglass Coat Resin Usage 131 pounds 0.56 Glass Usage 44 pounds 0.84

Catalyst 1.3 pounds 1.40

Acetone

Balsa Board c- .

E 1 ectr i c i tya

Manpower Costs

Waste Disposal CostsC

b

3.7 pounds 0.27

13.5 sq ft 1 .oo

TOTAL U N I T COST FOR LARGE SHOWER STALL

Raw Material Waste 25.5 pounds 0.63d

20.60

73.36 36.96

1.83

0.99

13.50

6.00

93.90

1.59

245.73 - 16.07

8.3

29.5 14.9

0.7

0.4

5.4

2.4

37.7

0.6

6.5

a Based on $1200 per month electricity bill and an average o f 10 shower stalls per day Based on $4695 per week payroll and an average o f 10 shower stalls per day Based on two dumpsters per month with a tip fee o f $159 per dumpster, and an average of 10 shower stalls per day. "Unit Price" is the composite price of the glass and resin lost as waste.

7- 5

I 8720052-c COT-1

Table 7-2. ANNUAL COST SAVINGS FOR SPRAY ORIENTATION IMPROVEMENT

RAW MATERIAL WASTE COST, RMWC ( f rom Table 7-1)

RMWC = $16.l/shower s t a l l

RAW MATERIAL COST SAVINGS, RMCS (assuming 25% waste reduc t i on )

10 shower s t a l l s 240 days d aY year X

16.1 RMCS = shower s t a l l

= $9660/year

PAYBACK PERIOD, PP

$400 x 52 weeks/year 9660/year PP = 3

= 2 weeks

PRODUCT I O N COST SAVING , PCS

Cost of 1 shower s t a l l , ,mater ia ls and Labor = $250

Raw mate r ia l savings per shower s t a l l = 25% x $16 = $4.

$4 x 100% = $250

= 1.6% -

7-6

8720052APB COT-12

Table 7-3. PAYBACK PERIOD FOR AIR-ASSISTED AIRLESS SPRAY GUN

To estimate the payback period for switching to an air-assisted airless gun, an estimate of the raw material savings is made. reduction/raw materials savings range from 540%. reduction of waste for ten large shower stalls manufactured per day was used for the calculation below.

Probable waste A conservative 10%

Raw Material Savings (RMS):

For a 10% reduction in waste:

RMS = 0.1 x 25.52 pounds

= 2.5 lbs/stall

= 25 lbs for 10 stalls

c- .

Cost Savinqs (CSL:

For 10 shower stalls, and fiberglass resin valued at $0.60 per lb.

CS = 25 pounds x $0.60 d aY pound

= $15/day

= $3750/year

Estimated Payback Period (EPP)

Cost of Spray Gun = $1500

EPP = $ i5eo/cs

= 100 days

= 5-month payback period

7- 7

8720052-~7 COT-5

7.2.3 Reduce Rinse Solvent Usage

industry. solvent being applied to the vessel to dissolve the solvated resin remaining.

A significant quantity of solvent is used for vessel cleanouts in the The use of squeegee tools may result in a smaller amount of

A typical economic evaluation of solvent rinse use reduction using the squeegee cleaning system is summarized in Table 7-4. Costs for additional time required for each vessel cleaning, and a one-time operator training program are subtracted from the raw material and disposal cost savings due to reduced solvent usage to give the total cost savings. Total monthly

---cost savings were estimated at more than $3700. The calculated payback period was slightly under one month.

7.2.4 Resin Pan Modifications The treaters often handle fabrics with widths of 38 to 72 inches. A

pan width 10 inches wider than the fabric is required. a wider pan, solvated resin is wasted. At one of the plants audited, it was recommended that a simple adjusting device be made to fit into the treater pan to reduce treater pan waste production. of a mold fitted into the end o f the treater pan. There would be minimal labor requirement associated with this change, as the operator would only have to insert and remove the block within the treater pan as required by the fabric width.

If fabric is run in

This device consisted

Table 7-5 .summarizes a typical production match between fabric and treater pan width. As shown in Table 7-6, the excess width resulted in additional solvated resin waste at the end of the treater run. pounds of waste are produced per run when a 60" treater pan is used on a 32" width fabric. to excess pan width was 51,500 pounds of solvated resin per year, equal to a raw material and disposal cost savings of $91,700 per year.

The average excess width was 22.4 inches per treater.

For example, 15 additional

Table 7-6 shows an example where the avoidable waste due

7- 8

8720052-a CON-1

Table 7-4. ECONOMIC EVALUATION OF SOLVENT RINSE USE REDUCTION

SOLVENT RINSE USE REDUCTION BASIS

In this example, current total solvent use per month i s determined from a knowledge o f the quantity o f nonepoxy solvent disposed each month. disposal quantity is ratioed-since the plant produces 70% epoxy resin-based products and 30% non-epoxy resin-based products, the total amount of solvent rinsate is in the same proportion.

This known

Current solvent use per montha lb rinsate rinses a1 lons

= 16,800 month 0.3 NES rinses 0.8'~ 8.34 lb = 8400 gallons/month

Volume of solvent saved @ 25% use reduction c- -

= 2100 gallons/month

RAW MATERIAL SAVINGS (RMS)

RMS = 2100 gal x 0.45 (acetone)

TOTAL = $5000/month

x 0.792(8.32)($0.23/lb) = $1400 x 0,792(8.32) ($0.365/1b) = $2300

= $1300 2100 gal x 0.45 ( M E K ) 2100 gal x 0.10 (Methanol) x 0.792(8.32)($0.96/lb)

DISPOSAL COST SAVINGS (DCS) NES rinse o.8 8.32 lbs. $0.14 all rinse gallon lb DCS = 2100 gallons x 0.3

= $590/month

LABOR COST INCREASE (LCI) 15 additional minutes 339 cleanouts $22

LCI = c 1 eanou t month 60 minutes o f labor = $1865/month

MONTHLY COST SAVINGS (MCS)

MCS = $5000 + $590 - $1865 = $3725/month

7-9

8720052-a CON-2

Table 7-4. ECONOMIC EVALUATION OF SOLVENT R I N S E USE REDUCTION (concluded)

OPERATOR T R A I N I N G COST (OTC)

OTC $ 22 = 15 operators x 8 hours x hour = $2700

PAYBACK PERIOD (PP)

$2700 pp = =month

= 3 weeks

a NES = Non Epoxy Solvent c- .

7- 10

I 8720052AT5 CON-8

Table 7-5. FABRIC AND TREATER PAN WIDTH MATCH

Compos i t e Fabr i c Treater Percent o f Excess,, Excess Inches Width Pan Width Product i ona Inches o f One Treater '

32" 60 'I 40% 18 7.2

38 I' 78" 20% 30 6

50" 84" 15% 24 3.6

44" 84" 5% 30 1.5

50" ' 86" 9% 26 2.35

60 I' 86" 11% 16 1.76

AVERAGE EXCESS 22.4

c- -

a These percentages represent ac tua l p roduc t i on o f f a b r i c w id th versus pan w id th from P l a n t A produc t ion records January through September 1987.

"Excess Inches" i s t he d i f f e r e n c e between pan and f a b r i c width, minus the 10-inch c learance requ i red by the machinery.

Th is column i s equal t o "Percent of Product ion" column m u l t i p l i e d by t h e "Excess Inches" column. For examples, 0.4 x 18 = 7.2.

7-11

I 8720052-f CON-1

Table 7-6. ECONOMIC EVALUATION OF REDUCING TREATER PAN WASTE

D E S I G N BASIS

No. of treater cleanouts for 9 month period 1369 Average excess inches per treater cleanout (from Table 7-5) 22.4

0.22 1.1

Wetted cross-sectional area o f treater pan ( ft2) a Specific gravity o f treater resin Treater waste reduction per excess inch 1.26

Cost of raw material ($/lb) 1.64 Cost o f incineration disposal ($/lb) 0.14

1000

of treater pan (lb)

Cost for modification to treater pan ( 8 )

RAW MATERIAL COST SAVINGS (RMCS)

1.26 lb resin 22.4 inches waste reduction 1369 treater cleanouts

RMS = treater excess inch 9 months c 1 eanou t

$1.64 x- - 51,500 lb - year lb

= $84,50O/year

DISPOSAL COST SAVINGS (DCS) ounds $0.14 DCS = 51,500 x pound

= $7,200/year

TOTAL COST SAVINGS (TCS)

TCS = RMS + DCS = $84,500 + $7,200

= $91,00O/year

PAYOUT PERIOD (PP) $1 000

pp = 898,900/yr = week

12 mo. $1.64 year lb x- X

a Assumes a 4" x 8" wetted cross-sectional area 7- 12

8720052-~7 COT-6

7.2.5 Reduce Pipe Size From Mix Tank to Treater Pan

pi.pe connected the mix tank and the treater tank. each run the solvated resin in the treater pan was discarded, along with the resin in the pipe. The reason for the 2-inch pipe was that some of the resins are more viscous and require a fairly large pipe size to prevent plugging. resin viscosity is 1000 cp.

At one of the plants audited, approximately 8 feet of 2-inch diameter At the completion of

The flow rate does not justify the 2-inch size.

Average epoxy

The volume per lineal foot of 2-inch compared to 1 1/2- and 1 1/4-inch pipe is 164 percent and 220 percent, respectively. could be used on the less viscous resins, it was calculated that approximately 1270 pounds of resin per year could be saved for 6 treaters. of 1 1/2-inch pipe and valving to allow the operator to select the pipe size for resin delivery based on the resin mix viscosity. period for the system, based on being able to use the smaller pipe 1/6 of the time was 2-1/3 years. modifications and Table 7-8 the payback period calculations.

If the 1 1/2" size c-

The process change would require installation of a parallel run

The payout

Table 7-7 shows the cost estimate for the

7.2.6 Reuse Rinse Solvent

once instead of being discarded or sent to a recycling still, a substantial reduction in operating costs, raw material costs, and hazardous waste disposal costs may be realized. At one of the plants audited, several operational changes were required to realize this opportunity.

If the used solvent for non-colored resin batches is stored and reused

1. Treater rinsing would be divided into two steps - an initial rinse with recycled solvent would be followed by final rinse with fresh solvent. The first rinse would be collected for disposal as hazardous waste and the second rinse with fresh solvent. It would be collected, stored and reused.

7-13

I 8720052AT5 CON-4

Table 7-7. COST ESTIMATE FOR REDUCING P I P E S I Z E ON R E S I N DELIVERY SYSTEM TO TREATER PAN

Pipe

guant i t y

8 feet, 1%'' p ipe

E 1 bows 4

Tees 2

Valves 4

c- - TOTAL SYSTEM COST (system requ i red on a l l 5 t r e a t e r s )

I n s t a l l e d Uni t Cost Tota l Cost

$550/100 f e e t $ 55

$55/each $ 220

$70/each $ 140

$l50/each $ 600

$1070

$5350 -

7- 14

I 8720052AT5 CON-2

c- -

Table 7-8. ECONOMIC EVALUATION OF REDUCING PIPE SIZE ON RESIN DELIVERY SYSTEM TO TREATER PAN

DESIGN BASIS

2-Inch Pipe l$-Inch Pipe Gallons per Lineal Foot 0.1743 0.1058

Total Gallons, 8 Feet of Pipe 1.39 0.85

ASSUMPTIONS FOR ECONOMIC EVALUATION Additional Gallons/Treater Cleanout Treater cleanoutslday Operating dayslyear Disposal cost/lb for solvated resin Raw material cost/lb for solvated resin Percent resin in solvated resin Density of solvated resin Frequency of smaller pipe use

0.54 6 256 14$/lb $1.64 65% 1.1 Every 6th treater

RAW MATERIAL AND DISPOSAL SAVINGS (RMADS) (Total pounds solvated resin saved/year)

ft3 256 days 6 treaters 1 0.54 gals, 1.1 x 62.4 lb treater ft3 7.48 gal. x g x d aY RMADS = yr

$1.78 = 1,269 lbs/y.r x

= $2,822/yr

PAYOUT PERIOD (PP)

Estimated Cost of .Process Change = $5,350 (From Table 7-7)

$5 350 pp =B2,258/year

= 2-1/3 years

7- 15

8720052-~7 COT-7

2. A procedure for segregating non-epoxy from epoxy rinse solvent would be required since the non-epoxy rinse solvent would not be recycled in the recycling still after the reuse step. The non-epoxy rinse solvent cannot be recycled because of the risk of a runaway reaction.

3. Storage tanks for the once-used solvent and pumps and piping between the tank and treater would be installed in the treater building. Separate tanks would be required for the non-epoxy and epoxy rinse solvent. Collection of rinse solvent from the mix vessel rinses and epoxy pretreater rinses at the Mix House would still have to be done manually. Rinsing solution from the final rinsing step using clean solvent would be collected from the treater or Mix House and delivered to the recycled solvent tanks. The once-used solvent from the recycled solvent tanks would then be used to make the initial rinse on the process vessels.

.-A .

The estimated capital and operating costs for the solvent reuse system are shown in Table 7-9. operating costs. It was assumed that labor costs for bringing the solvent to and from the reused solvent storage tanks in the Treater Room would be

equal to the time now spent getting the solvent from the current tanks and taking it in drums to the hazardous waste storage area. The payback cal- culation is shown in Table 7-11. The assumptions used in the calculation are shown in Table 7-10. reduction was estimated at 2.6 months.

Operator training costs were included in the

The payback for solvent reuse with no solvent

7.3 SOLVENT RECOVERY SYSTEMS

Technical descriptions of solvent recovery systems are in Section 5.2.

Operating a solvent recovery system requires electricity and labor. Based on the kilowatt rating of the still and approximate cycle time of one shift, the cost of recycling acetone at one of the plants audited was

7- 16

8720052AT5 CON-3

Table 7-9. CAPITAL AND OPERATING COSTS FOR RECOVERED SOLVENT SYSTEM

CAPITAL COSTS

I tem

Pumps

500 gallon tanks

Pipe and fittings to the 5 treater stations

Electrical wiring 81 conduit

c- . Operator training

x 8 hours) (15 operators x $22/hr

Instal led Quantity Unit Cost Total Cost

2 $2000/pump $4000

2 $2000/tank $4000

1500 feet, $176/100 feet $2650 1/2" pipe

150 feet $500/100 feet $ 750

$2700

TOTAL CAPITAL COST $14,100

ANNUAL OPERATING COSTS

Pumps ( 2 Q 1 hp, running 2 hours per day) $ 75 0.7457 Kilowatts 21 days 12 months $0.10 horsepower month year x -1 Kw-hr

Maintenance (5% of capital cost, not including operator training)

TOTAL ANNUAL OPERATING COST

$ 570

7- 17

8720052AT5 CON-6

Table 7-10. ASSUMPTIONS FOR ECONOMIC EVALUATION OF R I N S E SOLVENT

R I N S E SOLVENT RECYCLED ( R S R I

16,800 l b s NERS 0.7 ERS g a l l o n month 0.3 NERS 0.8 x 8.32 l b s RSR =

= 5890 g a l lons/month

RINSE SOLVENT DISPOSED (RSD)

16,800 l b s NERS g a l l o n RSD = month 0.8 x 8.32 l b s

= gal lons/month

SOLVATED EPOXY R E S I N R I N S E SOLVENT RECYCLED (SERRSR)

SERRSR = 16,800 l b s NER disposed 0.7 epoxy r e s i n g a l l o n month 0.3 NER 1.1 x 8.32 l b

c- . = gal lons/month

SOLVENT I N STILL BOTTOMS (S ISB)

S I S B = 35%.by weight i n bottoms

SOLVENT REUSE (SR)

SR = 100% - (use a l l r i n s e so l ven t t w i c e p r i o r t o sending t o s t i l l o r d isposal )

STILL OPERATING COST (SOC)

SOC = 8250/day - ( i n c l u d e s steam, c o o l i n g water, and opera t i ng l a b o r )

NERS: Non-epoxy r i n s e so l ven t ERS: Epoxy r i n s e so l ven t NER: Non-epoxy r e s i n

7- 18

8720052-d CON-1

Table 7-11. ECONOMIC EVALUATION FOR REUSE OF RINSE SOLVENT

SOLVENT USAGE

Without Reuse With Reuse

Epoxy rinse solvent distilled 5890 (gallons per month)

Non-epoxy rinse solvent disposed 2540 (gallons per month)

Distilled solvated epoxy resin 4280 (gallons per month)

2945

1270

4280

RAW MATERIALS SAVINGS (RMS)

_ _ _ Raw material savings from reduced non-epoxy rinse solvent disposal

x 0.792 (8.34) ($0.23/lb) = $ 868/month a1 lons RMS = 1270 treaLr rinse

1270 & x 0.45 (MEK) x 0.792 (8.34) ($0.365/1b) = $1378/month

1270 $$!& x 0.10 (methanol) x 0.805 (8.34) ($0.96/lb) = $ 818/month

TOTAL = $3064/month

DISPOSAL COST SAVINGS (DCS)

(50% less rinse solvent disposed)

= $1190/month

OPERATING COST SAVINGS (OCS)

0.58 Rinse Solvent Volume - 5890 All Feed to Still - 5890 + 4280 =

= 0.37 Reuse Rinse Solvent Volume - 2540 All Feed t o Still - 2540 + 4280

x 21 days ocs = - 8250 x (0.58 - 0.41) month day

= $1100/month

7- 19

8720052-d CON-2

Table 7-11. ECONOMIC EVALUATION FOR REUSE OF R I N S E SOLVENT (concluded)

TOTAL MONTHLY COST SAVINGS (TMCS)

TMCS = RMS + DCS + OCS

= $3064 + $1190 + $1100

= $5360/month

PAYOUT PERIOD (PP)

Estimated capital cost o f process change = $14,100 (From Table 7-9)

,.PP = 3- $14 100 5360/month

= 2.6 months

7-20

8720052-~7 COT-8

estimated to be approximately 66 per gallon of acetone recovered. 7-12 shows this calculation. This compares with $1.80 per gallon for virgin solvent. An annual savings o f $2100 would result from solvent recycling at this plant. No labor cost was assumed in the calculation, since the operation was performed as part of the normal duties of the operator's workday. Labor and other expenses include disposal of distilled bottoms, replacement of heat transfer fluid and bags, and maintenance. These operating costs will generally be less than 506 per gallon. manufacturers claim costs under 206 per gallon.

Table

Some

7.4 EQUIPMENT RELIABILITY, PERFORMANCE AND SERVICING c- .

At one of the plants audited, the solvent recycling unit did not appear t o function properly. Audit observations indicated that it took approximately 6 hours to recycle 3 gallons of acetone, whereas according to design specifications, the period should have been less than 2 hours. observed that the still seemed to take an abnormally long period of time to warm up. hour, which seemed low.

We

The condenser cooling water flow was set at only 1/2-gallon per

The recycling still manufacturer was contacted and questioned as to proper operating conditions and typical sources of malfunction o f the unit. The most likely source o f malfunction was identified to be the jelling of the heat transfer media. the cooling water flow setting for should be approximately 30-gallons per hour. shown in Table 7-13.

The manufacturer also recommended that

A summary of a method for estimating condenser water flow rate is

Based on the vendor's recommendations, the.recycling still's heat transfer media was checked and replaced and the cooling water rate adjusted according to the manufacturer's instructions.

7-21

8720052APB COT-13

Table 7-12. SOLVENT RECYCLING COST FOR BATCH STILL

Solvent recovery cost is a function o f cycle time, the cost of power, and the power rating o f the distillation unit. In the following example, a 1 KW unit is selected, and physical property data for pure acetone are used in the estimation of cycle time. Power cost is 10#/kwh. However, due to the different properties of the acetone resin mixture that is actually distilled, a longer cycle time is expected. calculating the cost of recovery is assumed at 7.5 hours instead of the calculated cycle time o f 4.8 hours. or 12 gallons is assumed.

The cycle time used for

Recovery of 80% of a 15-gallon batch

c- - Acetone Properties:

Molecular Weight = 58 Boiling Point = 133" F Heat o f Vaporization = 12,528 BTU/lb mole Specific Gravity = 0.79 Density = 49.42 lb/ft3

Energy Usage (EU):

EU = 1.00 KW

= 3413 BTU/hr

Evaporation Heating Duty (EHD) for Pure Acetone:

ft3 49.42 lb 16 mol 12,528 BTU 58 l b lbmol EHD = 12 gal acetone x 7.78 gal

ft3 = 16,400 BTU/lb

7-22

I 8720052APB COT-14

Table 7-12. SOLVENT RECYCLING COSTS FOR BATCH STILL (concluded)

Recycling Unit Cost (RUCL:

Still Efficiency = 0.70

EHD 1 Cost of Electricity ($/kwh) EU 0.7 Gallons Recovered RUC = - x -

16,400 - BTU 1 0.10

RUC = 3413 BTU 0.70 12 x- lb

h r

a

= 6$/gallon

7-23

8720052-AL CON-24 I

Table 7-13. PROCEDURE FOR CALCULATING COOLING WATER FLOW RATE FOR THE SOLVENT STILL CONDENSER

STEP ONE: P o s i t i o n a l a r g e bucket (about 5 ga l lons) t o c o l l e c t c o o l i n g water discharge from e x i t hose.

STEP TWO: W r i t e down the t ime on attached form a t the commencement o f c o l l e c t i n g the water discharge. minutes.

C o l l e c t water f o r about 5-10

STEP THREE: Remove hose from bucket and w r i t e down t h e f i n i s h t ime on at tached form.

STEP FOUR: Weigh the bucket w i t h water. Note on at tached form.

STEP F I V E : Weigh the empty bucket and note on at tached form.

‘*SEE ATTACHED FORM FOR FURTHER CALCULATIONS.

A. STARTING TIME, SECONDS

B. FINISH TIME, SECONDS

1) B-A, SECONDS

C. WEIGHT OF FULL BUCKET, kg

D. WEIGHT OF EMPTY BUCKET, kg

2) C-D, kg

E. COOLING WATER FLOW RATE (CWFR)

- - kg/minute

7-24

8720052-~7 COT-9

Before installing an onsite solvent recovery system, the generator should verify reliability of the equipment, its performance, and the vendor servi ci ng .

7.5 ORDER OF IMPLEMENTATION

The general, waste minimization objectives in the composite plastic product industry are to reduce solvent usage, reuse solvent and/or reduce the amount of solvated resin waste. Common sense dictates that it is better to first work on solvent use reduction before reuse of solvent, especially since the capital cost of use reduction is much less than

c- solvent reuse. The payback period of solvent reuse is directly affected by the amount of solvent use reduction.

7.6 INCENTIVES

Worker incentives should play a role in any waste reduction program. The key to waste reduction is often in the hands of the operating staff. The operator, however, needs positive reinforcement from management. Waste reduction programs accompanied by a strong commitment from management have a greater chance for success. with the operating staff explaining process modifications and asking for suggestions of new waste minimization ideas are examples of employee involvement. of solvent not identified in this report.

Waste minimization round table discussions

The operations staff may also be able to describe other uses

7.7 SUMMARY OF OPPORTUNITIES

A summary of the estimated cost savings, payback period, and annual savings of the waste minimization opportunities identified by the audits conducted during this study are presented in Table 7-14.

for the various projects range from less than a week to 33 weeks, with capital costs ranging from less than $100 to $14,100.

Payback periods

7- 25

I 8720052AT5 CON-5

Table 7-14. SUMMARY OF MAJOR AUDIT COST SAVINGS

Capital & Operating cost of Annual Process Payback Savings

Modifications Per i od (8)

Modify Spray Orientation $ 400 2 weeks 9,600

State-of-the-Art Spray Guns $ 1,500 32 weeks 2,160

Fix Solvent Recovery System $ 90 2 weeks 2,100

c- - Solvent Use Reduction $ 2,700 2.8 weeks 45,900

Solvent Reuse (without $14,100 2.6 months 61,800 sol vent use reduct ion)

Solvent Reuse (with $14,100 3.4 months 48,900 solvent use reduction)

Pipe Size Reduction $1,070 2 years 2,800

Treater Pan Modification $1,000 <1 week 91,700

7-26

8720052-~8 COT-1

8.0

SELF AUDIT GUIDELINES

The following provides guidelines for implementing a waste audit program in a composite plastic product plant. filed on site as a supporting document for manifest form EPA 8700.22, Item 16, Generator Certification of Waste Minimization.

The completed audit may be

c-

The first step is to gather background data to identify all the hazardous waste sources. The various process steps associated with producing composite plastic products need to be identified. inputs and outputs should be described in detail and the potential waste reduction opportunities identified. Appendix D presents a self audit checklist t o assist in this task.

The material

As a second step, waste reduction opportunities identified should be evaluated. Examples of waste reduction opportunities include:

a. Reformulating products so as to employ safe substitute materials for processing and avoid generation of hazardous waste.

b. Redesigning processes to decrease hazardous waste generation.

c. Automating processes to minimize quantities of hazardous waste generated.

d. Improving general operating practices to minimize quantities of waste resulting from spillage, handling, and cleaning activities.

8- 1

8720052-~8 COT-2

e. Installation of equipment and processes for on-site recycling.

f. Adopting management practices which support recycling and,resource recovery.

g. Utilizing off-site recycling and waste exchange services.

By developing and implementing a comprehensive waste audit program based on the responses to the above items, a composite plastic product manufacturing company can effectively assess its waste reduction opportunities. A waste audit is an essential starting point for

incorporated into an existing manufacturing plant. housekeeping problems and operating inefficiencies that cost little to correct. The critical elements of a successful waste reduction audit program are:

,.identifying areas where hazardous waste reduction technologies can be An audit can identify

Management commitment Personnel involvement Access to background data Resources to obtain additional data

Full commitment of management is necessary to perform a comprehensive waste reduction audit program. A commitment in terms of time, personnel, and financing is essential. and administered with input from the company's senior management level. Without management support and interest, the waste reduction audit becomes simply an exercise that achieves little actual waste reduction.

The waste reduction audit should be planned

Production personnel can be valuable sources of information and they should be available for consultation during the audit. describe actual operating activities in greater detail than supervisory or management personnel. Also, because of their close involvement with the

Often they can

8- 2

8720052-~8 COT-3

production line, operational personnel may already have ideas of where waste can be reduced through housekeeping and process modifications. plant personnel are involved in the waste reduction program from the early stages, awareness and cooperation during implementation of the program can be more easily obtained.

If

A waste reduction audit will inevitably identify areas where necessary information is unavailable. For the plastic products industry, these may include the quantities of resin and fiber used, the concentration o f solvent in waste streams, and the quality of solid waste. To obtain this information, usage or wastage can be measured and waste components identified. A minor shut down in production to try new techniques may be necessary. obtain this additional data.

- - - The audit team must have the resources available to them to

8.1 AUDIT IMPLEMENTATION

The checklist presented in Appendix D should be reviewed by the audit team prior to beginning the audit and used to assist in the design of the audit. The audit team should then identify and determine the feasibility of implementing the various waste reduction techniques described in this report. and process and treatment chemical suppliers t o perform these evaluations. Finally, economic data should be used to perform a cost/benefit analysis on those waste reduction techniques that display potential for _implementation.

The audit team should utilize the expertise o f equipment suppliers

8.2 TYPICAL BARRIERS TO A SUCCESSFUL WASTE AUDIT

Innovative thinking is usually required to identify appropriate waste reduction techniques available to a company. opportunities are apparent simply by gathering and analyzing data. Furthermore, potential results cannot always be estimated. Therefore,

Not all waste reduction

8- 3

8720052-~8 COT-4

decisions to implement waste reduction technologies often require certain levels of risk. A company often must overcome barriers to implementing waste reduction techniques that can prevent innovative ideas from being tested. Several of these barriers are as follows:

Lack of information about available waste reduction techniques and the benefits that can be achieved.

Concerns for upsetting product quality.

The "If it ain't broke - don't fix it" attitude.

A reluctance to deve1op.innovative ideas because of the fear of f ai lure.

The attitude that a new technology will not succeed because it is outside the range o f plant personnel expertise.

The audit team must recognize these barriers and be prepared to address them during the audit. This is important to ensure that all potential waste reduction opportunities are identified and assessed. Once again, management commitment to the waste reduction program is essential for overcoming these barriers.

8-4

8720052-~9 COT-1

9.0 SUMMARY OF PLANT AUDITS

Woodward-Clyde Consultants performed waste reduction audits at three FRP manufacturing plants. used to: (1) identify waste reduction technologies available to FRP manufacturers, and (2) develop guidelines to be used by FRP and composite plastic product manufacturers to perform their own audits.

The information obtained during these audits w a s

c_

Performance of the three waste audits provided valuable information on

the potential for implementing waste reduction technologies in the plastic product industry. The audits also provided information on the limitations to waste reduction inherent to the industry. The audit team observed several waste reduction techniques being used at these plants and also identified potential waste reduction opportunities that the plants have not yet employed. Descriptions of the three plants audited follow.

9.1 PLANT A

Plant A produces coated composite sheeting which consisted o f two distinct parts, the substrate and the coating. woven material such as fiberglass matting or paper. The coating i s a

The substrate is usually a

synthetic resin. The combination of these two materials result in a product with high strength to weight ratio, which make it a valuable starting material for the aerospace and transportation industry. Approximately 60 percent o f Plant A's business is attributed to the aerospace/transportation industry. the composite sheets as a raw material for their products, such as pole vaulting poles, skis, and golf club shafts.

Many types of sporting goods also use

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Raw materials include fabrics, resins, catalysts and curing agents, additives and property modifiers, and solvents.

Fabrics. The fabric usually comes on rolls 38 to 72 inches wide. Frequently used materials are Kevlar@, glass, graphite, nylon, polyvinyl alcohol (PVA), and paper. The material is usually woven.

Resins. There are over 100. resins used by Plant A. They are classed broadly as epoxy, polyamide, polyester, or phenolic. Over 70 percent used is a type of epoxy. Use of the other types is approximately 10 percent

supplied in jacketed totes. It could be melted as required by connecting steam to the outer jacket to melt the resin. liquid epoxy resin was bought in bulk and stored in an underground tank onsite. The other resins were supplied in liquid form in drums.

,.each. The epoxy comes in either liquid or solid form. The solid was

The most frequently used

Catalysts and Curinq Aqents. in the mix batch to promote curing of the resin. to the resin at the mix step in very small amounts.

Various catalysts and curing agents are added These chemicals are added

Additives and Modifiers. Additives and modifiers include pigments, flow inhibitors, fillers, fire retardants, surfactants, hardeners and plasticizers. descriptive names indicate. very small amounts.

These chemicals give the product a certain property as their They are also added to the mix resin batch in

Solvents. and for equipment cleanup. Acetone, methyl ethyl ketone, and methanol are used most frequently and stored in underground tanks. Others are supplied in drums. MEK, and methanol respectively.

Solvents are used in large quantities for diluting the resin mix

The approximate proportion o f use is 45/45/10 percent acetone,

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Processes. There are five main processes at the plant:

Epoxy resin pretreatment Resin mixing Fabric coating/heat curing Epoxy-contaminated solvent recycling Slitting and rewind

Although not a process, the storage of raw materials and waste i s

another major operation.

- - - 9.1.1 Epoxy Resin Pre-Treatment In this pretreatment step for epoxy resins, the epoxy, catalyst, any

fillers, and solvent are added to a reactor and heated to start the resin curing process. pretreatment batches, especially when two consecutive pretreatment batches are different epoxy formulations. the mix tank area by gravity piping.

The reactor must be washed and rinsed with solvent between

The pretreated resin is transferred to

9.1.2 Resin Mixing

Standards. (resin, catalyst, filler, pigment, stabilizer, etc.), the order of addition, time of mixing, and any special instructions or safety precautions. forklift to the treater area for processing. The maximum mix is approximately 2200 pounds, with a resin solids content of approximately 70 percent. solutions.

The resin mix instructions were contained in Plant A ' s Resin Mixing These instructions give the weight of each chemical in the mix

The mix tanks are portable vessels that are transported by

The mix-ng consists of combining 3-4 individually mixed Total mixing time of 1-5 hours is typically required.

It is the Mix House operator's responsibility to mix the proper quantity o f mix resin for the corresponding fabric yardage requiring coating. Ten percent o f the customers allow Plant A t o overrun an order by

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10 percent and 90 percent allow the order to be underrun by 10 percent. Mixing the exact quantity becomes more critical as the production run becomes smaller. When the run requires only one mix tank batch, mixing the improper quantity for the run will either leave excess solvated resin or require that a small additional mix is made in order to complete the run. If the run is more than one batch all the mixes except the last one do not require exact quantities.

After the mix is made it is covered and stored in a cool room if it will not be used right away. 45°F without adverse effect on product quality.

Most mixes can be stored for about 14 days at

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There are literally hundreds o f possible mix types that Plant A runs, determined by customer requirements which cannot be controlled. variety of resin mixes and strict customer quality specifications are two major factors affecting efforts to reduce and recycle wastes at the Plant A

faci 1 i ty.

The

9.1.3 Fabric Coating and Heat Curing

adjusted by adding solvent at a small reservoir tank upstream of the treater pan. During the coating process, resin is continually circulated between the reservoir and the treater pan. approximately 110 pounds o f resin.

The specific gravity of the resin mix from the previous step must be

The treater pan holds the resin which coats the fabric.

The pan and associated piping hold

The coating process begins by filling the treater pan. The fabric to The fabric dips into the pan

The operator controls the speed of the

Improper setting for these parameters can

be coated is loaded onto the unwind shafts. and then passes between two metering rollers which squeeze the appropriate amount of resin into the fabric. fabric through the mix pan, the spacing of the rolls, and the final specific gravity of the resin. result in offspec material and also a shortage or excess quantity of resin

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since the mix quantity was calculated assuming specific values for these process variables. fabric for 8-10 hours.

One mix tank of resin is usually sufficient to coat

The coated fabric is then fed to the treater to cure the resin coating The curing heat drives off the solvent, and at an elevated temperature.

the solvent-laden air stream is burned in a thermal oxidizer prior to release to the atmosphere. Heat recovery from the thermal oxidizer is used to cure the composite in the treater. The cured composite is cooled before it is wound up on the final roll.

At the end of a run, the resin pan must be emptied and cleaned. The leftover solvated resin must be disposed of as hazardous waste if it is non-epoxy based, or sent to the recovery still i f it is epoxy-based. Plant A has estimated that each cleaning averages 12 gallons of solvent for non- colored resin batches and 30 gallons for colored batches. process takes approximately 20-30 minutes.

The cleaning

9.1.4 Solvent Recycling

contaminated rinse solvent from the epoxy pretreatment reactor, mixing vat, and resin pan cleanings are recycled through the solvent recovery still. Polyester, polyamide and phenolic resin or wash solvent cannot be recycled in the still because the fire hazard and runaway reaction risk is too great. Epoxy resin composites account for 70 percent o f the Plant A

production, so that a large percentage of solvent in scrap resin and from cleaning operations is currently recycled. Recycled solvent can be used for vessel cleanouts in the production of militarylaerospace products, but cannot be added directly to t k resin mix at the mix house or in the dilution step at the treater. the resin during processing of Plant A ' s sporting goods product line, since quality control specifications are not as strict as for aerospace products.

Solvated epoxy resin scrap from the treater process and epoxy-

-

Recycled solvent can be added directly to

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9.1.5 Slitting/Rewind Some products are required in 2-inch widths, so that a regular width

product roll is slit into separate rolls of 2-inch-wide tape. Also, if a product roll is soiled or rolled imperfectly during production, the operater marks the damaged section so it can be removed. of the roll are rewound by the rewind operator.

The good portions

9.1.6 Chemical and Waste Storage

solvents, and drummed hazardous wastes are stored. The site also has areas for empty drum storage and dry chemical storage, finished goods storage,

Acetone, MEK, methanol and the most frequently used epoxy resin are stored on site in underground storage tanks. generator.

Plant A has a dedicated storage room where the drummed resins,

,.and a warehouse for raw material fabric storage.

Plant A is registered under RCRA as a hazardous waste They accumulate wastes for bulk shipment up to 90 days.

9.2 PLANT B

The manufacturing process employed at Plant B consists of a series of steps by which successive layers of various materials are applied to a mold.

The first step requires that the mold be waxed with a mold release agent. This is followed by the application of Gelcoat. The Gelcoat forms the surface coating of the product which is exposed when the completed part is separated from the mold. The Gelcoat is applied to the mold by spraying the mold to a uniform thickness. A catalyst is atomized into the Gelcoat stream as the resin exits the spray gun.

After the Gelcoat has set, the first coat of a general purpose liquid polyester resin (also called GP resin) and glass roving is applied to the mold. The resin is applied with a spray gun similar to the gelcoat gun except that the orifice tip is usually smaller and a chopper attachment is

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added to deliver glass fiber of approximately 1-1/2 inches in length into the resin stream. When the first coat has become tacky, the edges of the mold are trimmed, and, if required, reinforcing materials added to the piece.

A second GP resin/glass roving coat is added after the first coat has set. In some cases this second coat is made fire retardant by mixing aluminum trihydrate into the resin batch. resin coat, the edges are trimmed of excess resin while the resin is still tacky. sets. The finished object i s then removed from the mold.

After spraying the second GP

Sufficient additional drying time must pass until the resin totally

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9.2.1 Raw Materials

bus bumpers. Raw materials used in the manufacture of these products include general purpose (GP) liquid polyester resin, 1 iquid polyester Gelcoat resin, catalyst, glass fiber, additives, reinforcing materials, and sol vents.

Products include shower stalls, radomes, airport runway markers, and

Gelcoat resin is a pigmented polyester resin "paint" that is applied as a base coat to the waxed mold. approximately 30% and is slightly more viscous than the GP resin. resin is a mixture of approximately 60% polyester resin and 40% styrene monomer. be sprayed. proceeds. Since polymerization at room temperature proceeds slowly, an organic peroxide catalyst such as methyl ethyl ketone peroxide (MEKP) is introduced into the resin stream during processing to reduce the polymerization time. Chopped glass fibers are also introduced into the GP resin stream to give the finished product increased strength. fiber, called roving, is supplied on spools as a continuous strand.

It has a styrene monomer content of The GP

The styrene monomer is added to thin the resin so it can easily It also cross-links with the polyster resin as curing

The glass

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8720052-~9 COT-8

For some products, the GP resin is extended or properties modified with additives. The most common resin additives are Cabosil, an extender, and aluminum trihydrate, a fire retardant. Other components, such as metal bands, corrugated cardboard, and flexible balsa wood sections are added to some pieces for reinforcement. Auxiliary materials used include acetone solvent for cleaning hands and tools, and sawdust, which is spread on the floor to facilitate cleanup of resin overspray.

9.2.2 Spray Equipment

recently installed an air-assisted airless gun for Gelcoat delivery.

9.2.3 Solvent Recycling

operations at the plant to make its recycling practical. Plant B has such a small batch still, but it does not appear to be used on a regular basis.

Plant B uses an airless spray system for GP resin delivery and has

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Sufficient quantity of waste solvent is generated in cleaning

9.3 PLANT C

Plant C is engaged in the repair o f hulled boats. The manufacture of FRP boats uses polyester resin containing 40 to 60 percent styrene monomer. oil. Acetone is used as a cleanup solvent.

The main type of hazardous waste generated was crankcase sump

Repair work generates significant solid non-hazardous waste. Grinding generates resin and fibrous glass dust. the air.

It can create a noticeable haze in

Plant C is divided into 2 main work areas; an applications building containing saws, drills and other equipment and a mechanical repair area where the repair of engine, electrical and plumbing systems is performed. WCC's audit consisted of a plant inspection tour and an interview with the Plant Manager. During the audit, methods for reducing waste, disposing of

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the crankcase oil and permitting requirements were reviewed. It was recommended that resin be applied by airless spray guns. down on styrene emissions and minimize resin overspray. not accumulated longer than 90 days prior to disposal, a hazardous waste storage facility permit was not required. However, the drummed oil was to be stored and transported in accordance with the requirements for generators o f hazardous waste (Article 6, Title 22, California Administra- tive Code). 100 kg during any calendar month, the 90-day accumulation time limit would begin when the amount o f oil exceeded 100 kg. limit is reduced to 1 kg for waste classified as extremely hazardous.

This would cut Since the oil was

It was noted that in the event of Plant C generating less than

Additionally, the 100 kg

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10.0

REGULATORY ASPECTS

Companies manufacturing fiberglass-reinforced plastic products are subject to various federal, state and local hazardous waste requirements. These requirements are often confusing to the small business inexperienced with government agencies and their requirements, and lacking the resources

--to- track regulatory changes.

10.1 REGULATORY CAVEAT

All text pertaining to law and regulations contained within this report are provided for general information only. That information is not reliable for use as a legal reference. appropriate legal sources and regulatory authorities for up-to-date regulatory requirements and their interpretation and implementation.

The generator must contact the

10.2 RESPONSIBLE AGENCIES

Government agencies responsible for the regulation of hazardous wastes generated by manufacturing operations in California include the California Department of Health Services (DHS) and the U.S. EPA. In some cases the applicable California Regional Water Quality Control Board (for waste discharges that have actual or potential impacts on surface or groundwater quality), or Air Pollution Control District or Air Quality Management District (for air discharges).might also be involved.

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A number of federal, state, and local laws, regulations and ordinances are having an impact on hazardous waste minimization. Some of these requirements, including the State of California's land disposal restrictions and standards for generators, transporters and treatment, storage, or disposal (TSD) facilities, directly promote waste reduction by prohibiting or increasing the costs of other options such as off-site treatment or disposal. reduction because they command the immediate attention of the plant's owner/operator due to potential regulatory agency enforcement actions and fines. Compliance with these requirements might be given a higher priority, in terms of capital investments and time, than waste reduction. Alternatively, the most effective response might involve waste reduction or treatment.

Other requirements indirectly affect waste

10.3 LAND DISPOSAL RESTRICTIONS

The first of several restrictions on the land disposal of certain liquid wastes was implemented on June 1, 1983 (Section 66905(a)(l), CCR). Certain solvent wastes were restricted from land disposal effective November 8, 1988.

land disposal. The impact of increased waste disposal costs has had a positive impact on the implementation of waste reduction technologies.

These wastes now require some form of treatment prior to

10.4 AIR REGULATIONS

for the styrene

styrene 40-42%

Styrene emissions represent the most noticeable waste emission problem fabrication of product from resin. monomer is currently equivalent to a styrene monomer content of n the resin. In the San Francisco Bay area, only resin with monomer content below this percentage can be bought for use.

The percentage loss allowed for

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The Bay Area Air Quality Management District (BAAQMD) is currently formulating regulations for tighter control of styrene emissions. regulations will probably be modeled after the South Coast Air Quality Management District Rule 1162 (Los Angeles area). The South Coast Air Quality Management District's Rule 1162 requires:

These

1. Use of polyester resin with styrene monomer content of no more than 35% by weight.

2. Use of airless or air-assisted airless spray guns.

3. Use of closed containers for polyester resin material and cleaning sol vents.

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4. Use of solvent reclamation system for companies which generate more than 4 gallons of waste solvent per day.

10.5 PERMITTING REQUIREMENTS

Many expensive permitting requirements, including preparation o f permit applications and payment of permit fees, personnel training, contingency plans, and record keeping, are generally applicable to plants that store hazardous wastes for more than 90 days. Businesses that store wastes for 90 days or less face fewer of these requirements. However, many small FRP and composite plastic product manufacturers have trouble meeting the 90-day accumulation-restriction while also attempting to accumulate enough wastes to minimize transportation costs. Furthermore, implementing waste reduction technologies might cause greater difficulty in meeting the 90-day accumulation limit. Alternatively, since the 90-day accumulation time begins when 100 kg of hazardous waste or 1 kg of extremely hazardous waste are accumulated (provided that the plant generates no more than these quantities during any calendar month), quantities less than these are not subject to the 90-day accumulation limit. Therefore, for many small generators, these accumulation restrictions actually encourage waste reduction.

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The nature of the operations of most small FRP and composite plastic product manufacturers is such that they do not fall under the category of hazardous waste storage according to the DHS and EPA definitions. than 100 Kg. per month of hazardous waste is generated, a storage permit may not be required. required.

I f less

DHS should be contacted to determine if a permit i s

Some of the wastes generated by plastic products manufacturers are hazardous by regulatory criteria. These include acetone, liquid resin and organic peroxide catalyst discarded as waste. Since liquid resin wastes are usually solidified by adding catalyst, these wastes can be converted into a non-hazardous form and can then be disposed of at a Class 111 landfill. However, one large fiberglass manufacturer contacted during this study was unable to employ solidification since the solidification step was defined as hazardous waste treatment by DHS. have required extensive time for obtaining a permit or a variance. Minimizing the formation of thickened, unusable resin by efficient management of raw materials is the best way to minimize the impact of regulatory agencies' requirements. The alternative to solidification of resin waste at a DHS-permitted facility is disposal o f unsolidified resin waste at a Class I landfill, the cost of which ranges up to $600 (1988) per 55-gal 1 on drum.

c _ _

Use of this procedure would

10.6 COMMUNITY RIGHT-TO-KNOW LEGISLATION

Another statutory requirement that affects the FRP and composite plastic product manufacturer is the "Community Right-To-Know Law." state law requires local governments to develop programs to implement regulations related to hazardous material storage. This affects manufacturers in two ways: require capital expenditure to upgrade plant and prepare permit applications and hazardous material management plans; and (2) since permit

This

(1) compliance with the local programs may

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8720052~10 COT-5

fees are based on the type and quantity of hazardous materials stored at a plant, decisions on source segregation and batch treatment of wastes and the storage and use of hazardous materials may be influenced by the local ordinances. The impact of the first item may be a reduction in the resources manufacturers are able to allocate to waste reduction. The second item could both discourage and encourage waste reduction. Segregation of materials and batch treatment may require additional storage tanks. his could increase a company's storage permit fees and its exposure to liability costs due to spills or other releases. Alternat vely, storage permit fees may encourage plants to reduce their material inventories and waste generation to minimize their permit costs.

*- Further detai 1 s on the "Community Right-To-Know Law" are presented in Appendix B.

10.7 LEGISLATION PENDING

Hazardous waste control requirements today aim toward the minimization and treatment of wastes that have a detrimental effect on human health and the environment. by requiring generators to submit a statement at least once every 2 years (HSC, Section 25244.4) detailing efforts t o minimize their hazardous waste generation. Requirements in the future will continue to discourage landfilling of hazardous waste, and continue to stimulate waste minimization practices such as source separation, process modification, and recovery and recycling of waste streams.

The State of California is encouraging waste minimization

Copies of bills pending in the Legislature that deal with hazardous wastes and related issues and which might affect the small plastic product manufacturer, may be obtained as described in Appendix C.

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10.8 STATUTES AND REGULATIONS

Appendix E conta ins d e t a i l e d d iscuss ion and references t o s t a t u t e s and

regu la t i ons a f f e c t i n g hazardous waste generators.

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11.0 BIBLIOGRAPHY

State Department of Health Services. Toxic Substances Control Division. California Waste Exchange Newsletter/Catalog.

Todd, W.F. and S.A. Shulman. Control of Styrene Vapor in a Large Fiberglass Boat Manufacturing Operation. American Industrial Hygiene Association Journal 45(12):817-825 (1984).

Alternatives, Final Report, Prepared for California Departmentof Health Services, Alternative Technology and Policy Development Section. October, 1986.

c- - ICF Consulting Associates, Inc. Guide to Solvent Waste Reduction

Davis, Darryl. Pollution Reduction Strategies in the Fiberglass Boatbuilding and Open Mold Plastics Industries. Chairman, Department of Manufacturing, East Carolina University. North Carolina, 1987.

Toy, W.M. Waste Audit Study - Automotive Repairs. Prepared for Alternative Technology Section, California Department of Health Services. May, 1987

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APPENDIX A

GLOSSARY

~~~ ~~~ ~~~~ ~~

BAAQMD Bay Area Air Quality Management District

Bounceback

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Class I landfill

Class 111 landfill

Composite

DHS

FRP

Gel coat

In FRP production, bounceback is the resin waste produced when the resin spray hits the mold with enough force that it bounces off and falls to the floor as waste

A landfill constructed to specific technical standards and fulfilling siting criteria which make it suitable to accept wastes specified by the €PA as hazardous

A solid waste management unit which provided adequate separation between nonhazardous.waste and waters o f the State of California

A resin combined with another material such as glass fiber in such a way product has improved phys

Department of Health Serv

that the resulting cal properties

ces

Fiberglass-reinforced plastic

A pigmented resin or polyester resin-based paint sprayed as the first coat on the mold to yield a smooth, finished surface

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8720052-6 COT-2

GP

ME K

MDA

Overs p r ay

PET c- -

Pre-preg

PVA

RCRA

Rov i ng

RTM

SIC

Solvated resin

SQG

General purpose (resin)

Methyl ethyl Ketone

Methylene dianiline

In FRP production, overspray is the resin waste produced when the resin spray misses the target mold

Polyethylene Terephthalate

The industry name for composite sheeting ( a combination of resin and fibers) which is used as a raw material in such fields as aerospace and sporting goods

Polyvinyl Alcohol

Resource Conservation and Recovery Act

A term which describes the continuous strand fiber which is fed into the resin spray gun, chopped, and sprayed onto the mold with the resin

Resin Transfer Molding

Standard Industrial Code

Resin dissolved in a solution of solvent

Small Quantity Generator

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Thermoplastic

Thermoset

TSD

WCC c- .

A type o f resin that is easily reused since, with heat application, it can be returned to a liquid state

A type of resin that is permanently cross-linked upon curing and that cannot be returned to a liquid state with the application o f heat

Treatment, storage and disposal

Woodward-Clyde Consultants

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APPENDIX B "COMMUNITY RIGHT-TO-KNOW LAW"

REGULATORY CAVEAT

All text pertaining to law and regulations contained within this report are provided for general information only. That information is not

--reliable for use as a legal reference. appropriate legal sources and regulatory authorities for up-to-date regulatory requirements and their interpretation and implementation.

The generator must contact the

COMMUNITY RIGHT-TO-KNOW LAW

Effective January 1, 1986, AB 2185 (Chapter 1167, Statutes of 1985)

created a statewide "Community Right-to-Know Law" (Section 25500 et seq., Chapter 6.95, Division 20, HSC). communities with detailed information regarding the hazardous materials present in their areas so that they could use such information when making land use planning decisions. Significant amendments occurred during 1986.

The purpose of the new law was to provide

AB 2185 is different from, but comparable to, the pre-existing "Worker Right-to-Know Law." their respective communities about the hazardous materials present on their premises. their workers about the hazardous substances present in their respective work places.

For example, AB 2185 requires businesses to notify

The "Worker Right-to-Know Law" requires employers to advise

Under AB 2185 as amended, every business is generally required to submit to the administering agency an inventory of the hazardous materials on hand at its location and a business plan for managing such materials. "hazardous material" includes: a hazardous waste, as defined by DHS' laws

A

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and regulations; a hazardous substance, as defined by the worker right-to- know regulations; a radioactive material; and a substance which ( i f shipped) must be transported in a vehicle placarded in compliance with U.S. Department of Transportation requirements. Each business is required to submit an annual inventory of the following items:

A listing of the chemical name and common names of every hazardous substance or chemical product handled by the business;

The category of waste, including the general chemical and mineral composition of the waste listed by probable maximum and minimum concentrations,, for every hazardous waste handled by the business;

A listing of the chemical names and common names of every other hazardous material or mixture containing a hazardous material handled by the business which is not otherwise listed above;

The maximum amount of each hazardous material or mixture containing a hazardous material disclosed above which is handled .at any one time by the business over the course of the year;

Sufficient information on how and where the hazardous materials disclosed above are handled by the business to allow fire, safety, health, and other appropriate personnel to prepare adequate emergency responses to potential releases of the hazardous material s;

The SIC Code number of the business if applicable;

The name and telephone number of the person representing the business and able to assist emergency personnel in the event of an emergency involving the business during nonbusiness hours.

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8720052-S2 COT-20

In addition to the inventory described above, each business (as specified) is required to submit at a specified time a business plan to the administering agency. The business plan must be specific to each facility, site, or branch or a business and must include the following items (among others) :

The inventory of information described above and whatever additional information that the administering agency finds is necessary to protect health, safety, and the environment.

Emergency response plans and procedures in the event of a

including all of the following: c- - reportable release or threatened release of a hazardous material,

- Immediate notification to the administering agency and to appropriate local emergency rescue personnel and the Governor's Office of Emergency Services (OES) ;

- Procedures for the mitigation of a release or threatened release to minimize any potential harm or damage to health, safety, and the environment; and

- Evacuation plans and procedures, including immediate notice, for the business site.

Training for all new employees and annual training, including refresher courses, for all employees in safety procedures to be used in the event of a release of threatened release of a hazardous material.

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AB 2185 (1985) as amended generally applies only to businesses which handle at any one time during the reporting year one or more of the following quantities of hazardous materials: gallons, or (if the materials are compressed gases) 200 cubic feet, as applicable. lower limits than these. exempt from certain AB 2185 requirements businesses which meet specified prerequisites. For example, businesses which handle only retail products are categorically exempt. These requirements are usually administered by local authorities. regarding changes in the law and its implementation.

a minimum of 500 pounds, 55

However, administering agencies have the authority to impose Administering agencies also have the authority to

The generator should periodically contact the authority

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Source: Woodward-Clyde ,onsultants

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8720052-S2 COT-22

APPENDIX C PENDING LEGISLATION

The generator should be mindful of pending legislatian that can influence waste management decisions and plans.

To obtain a copy o f pending legislation, write or call the fo110i4ing: c- -

Legislative Bill Room

State Capitol Sacramento, CA 95814

ROOW 6- 32

(916) 445-2323

The first copy o f any bill ordered is free.

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8720052APB COT-1

APPENDIX D WASTE REDUCTION SELF-AUDIT CHECKLIST

~ _ _ _ ~ ~ ~

The following checklist can assist in the performance of waste reduction audit at a reinforced plastics products manufacturing plant. Plant personnel performing the audit should review the checklist and complete the accompanying worksheets prior to beginning the audit. information will provide guidance and the selection of waste reduction opportunities for investigation.

The c _ _

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8720052APB COT-3

0.1 GENERAL INFORMATION

Company Name: Company Address:

Contact Person: Phone Number:

Number of Employees: Hours of Operation Per Day:

Products and Annual Production Rates:

c- - 0.2 MATERIAL BALANCE SCHEMATIC

Provide a waste stream schematic with a material balance for each major waste generating operation (see Figure D . l ) .

0.3 RAW MATERIAL USAGE/HANDLING

Many wastes are generated by degradation of raw materials and by spills. This section is design to help determining if these wastes can be minimized by improving raw material usage and handling.

0.3.1 Inventory Control Are off-specification material wastes generated because the material

has exceeded its shelf life? -

Yes - No - What is the annual cost of disposal of off-spec. materials?

$

The current raw material inventory is capable of meeting months o f production.

How often is an inventory performed to identify an accumulation of materials? Continuously Annual ly Month 1 y

Other-

Does the company utilize a first-in first-out material usage policy to Yes - No prevent materials from deteriorating in storage? -

Does the company minimize inventory to prevent material degradation due Yes - No to prolonged storage? -

Does the company computerize raw material and waste inventories to Yes - No facilitate record keeping and data analysis? -

D-2

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D- 3

8720052APB COT-4

D.3.2 Sample Materials Control Does the plant accept samples from chemical suppliers? Yes - No

Yes - No Do unused samples become waste? - Has a person been designated for approving the acceptance of samples?

Yes - No - Are suppliers required to take back unused samples they provide?

Yes - No - D.4 WASTE GENERATION/HANDLING

The following section is designed t o assist in the identification of opportunities in waste reduction and handling.

‘D.4.1 Spi 11 Control Does the plant generate wastes due to spills during material handling

Yes - No If yes, describe the frequency of these spills.

- or storage?

How often is the storage area inspected to check the integrity of - containers and their proper storage?

Are personnel trained to ensure proper handling and storage of

Is spill containment provided to minimize the amount of clean-up

Yes - No

Yes - No

- materials?

materials used to contain and clean-up spills? - Describe spill containment used in material storage areas.

0.4.2 Waste Reduction Opportunities Check the type and note the cost of recycl

recovery/treatment/ disposal practices current plant.

Offsite hazardous waste landfill Offsite reclamation

~

Waste exchange program - Offsite sanitary landfill

i ng/resource ly in operation at your

COST

- Treated onsite -Other

Recycled onsite

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8720052APB COT-5

How are wastes removed from your plant? - Private waste hauler - Recycler/recl aimer - Public refuse system

Other - How long are wastes stored until a certain volume is reached?

Waste Accumulated Storage Period Type Vo 1 ume (days)

Are wastes segregated? Yes - No -

Yes - No Can wastes be re-used if segregated? -

Have you explored opportunities for on-site or off-site reuse? Yes - No -

Do you have wastes which could be listed by a waste exchange service?

Can you reuse scrap fiber internally or sell externally? Yes - No -

Can you solidify resin waste with catalyst to facilitate disposal?

Do you generate sufficient waste solvent to justify the purchase of a Yes - No sti 1 l? -

Do you generate sufficient waste solvent to justify investigating the Yes - No purchase o f an incinerator? -

D- 5

8720052APB COT-6

Can low-pressure air-assisted airless spray guns be utilized for resin and gelcoat delivery? Yes - No

Can spray orientation be changed to reduce waste generation?

Can non-spray resin application methods replace spray methods?

Can thermoplastic resins be used in place o f thermoset resins in the Yes - No -manufacturing of your product line? -

Can you utilize filtration to produce a reusable rinse solvent?

Can treater pans and transfer pipes be modified to reduce solvated Yes - No - resin waste?

Can you schedule production to minimize residual wastes? Yes - No -

Can you substitute less hazardous chemicals in your production process? Yes - No -

Can you use spent solvent from equipment decontamination as makeup in Yes - No subsequent formulations? -

Can process and equipment changes be implemented to reduce chemical Yes - No usage? -

Can the volume of solvent waste generated in equipment'cleanouts be reduced by using wiper blades or squeegees to physically wipe down the

Yes - No sides of mixing tanks? -

D- 6

8720052APB COT-7

Can you use bulk storage to reduce hazardous residual and spent Yes - No container wastes? -

Yes - No Can you re-use spent storage containers? -

Yes - No Can tanks be redesigned to minimize sharp angles? -

0.5 MANAGEMENT PRACTICE

Do you believe that routine evaluation of waste generation data by

c- . management can help identify potential areas for waste reduction? Yes - No -

Do you think employing waste reduction training programs with incentive compensation for achieving waste reduction goals will reduce waste

Yes - No generation? -

Are incentives offered to employees to encourage waste reduction?

Are there employee education programs on how to avoid excessive waste Yes - No generation? -

Are there employee education programs on how to avoid excessive waste Yes - No generation? -

Does the plant have an established waste minimization program in place?

Is plant management fully aware of current local, state and federal requirements related to hazardous material storage, treatment, disposal and

Yes - No recycl i ng? -

D- 7

8720052APB COT-8

Has an environmental audit been conducted to assess compliance with Yes - No government requirements? -

D- 8

90189H-C1 COT-1 I

Table D-1. RAW MATERIAL DATA

Ma te r ia l Suppl i e r Cost/Uni t Annual Usage

Annual .Cost ,$

Process/ App l i ca t i on

D-9

90189H-C3 COT- 1

?

Table D-2. R A W MATERIAL R E C E I V I N G STORAGE AND ON-SITE TRANSPORTATION

Mater i a1 Contai ner

Type1

Cont a i ner s i ,e2

I n d i c a t e drums (D), bu lk (B), bags (Bg), packages (P), o r p a i l s (p)

S t o r age ~ a p a c i t y3

S t o r age oca t i on4

S t o r age Period5

* I n d i c a t e conta iner s i z e i n lbs, gals, tons, e t c Ind i ca te p l a n t storage capaci ty i n lbs , tons e t c Descr ibe whether indoors (I), outdoors (0), covered (C) , uncovered (U) , concrete f l o o r (CF), asphal t f l o o r (AF), d i r t (D) , locked (L), unlocked (UL)

I nd i ca te days o r months I n d i c a t e manual (V ' ; , f o r k l i f t (F) , conveyor ( C ) e tc .

Transfer Mode 1

90189H-C3 COT-2

Table D-3. HAZARDOUS WASTE DATA ~~

Waste Generating Process Composition 1

Hazardous Constituents’

General description Chemical name and concentration Gallons, drums, pounds or cubic yards per day Type of disposal or reclamation method $ per gallon, drum, pound or cubic yard

Generation Rate3

Waste Management 4

Disposal Cost5

90189H-C1 COT-3

Table D-4. WASTE REDUCTION ASSESSMENT

?

c: w N

Waste Reduct i o n

Ippor tun i t y

Current 1 y Used V / N )

Waste TY Pe

___

Annual Quan t i t y

Current Annual Disposal Cost, $

Poten t i a1 Annual Saving, $

Implementation Po ten t i a l High Med i um Low None

90189H-C1 COT-4

Table D-5. WASTE REDUCTION PERFORMANCE

' y p e / So u r c e o f Waste

Annual Quan t i t y

Waste Reduct i o n Met hod

Measured % Reduction

Up-front cos t f o r waste reduc t i on implementation

Cost Saving = Disposal cos t - Operating Cost * For the waste reduct i o n oppor tun i ty

Cap i ta l Cost 12 Payout Period = Annual Cost Saving

Cap i ta l Cost1, $

Annual Operating CostP, $

Annual cost Saving', $

Payout Period, Months

4

8720052APB COT-15

APPENDIX E STATUTES AND REGULATIONS

The following contains descriptions of statutes and regulations affecting hazardous waste generators.

REGULATORY CAVEAT

All text pertaining to law and regulations contained within this report are provided for general information only. That information i s not reliable for use as a legal reference. appropriate legal sources and regulatory authorities for up-to-date regulatory requirements and their interpretation and implementation.

The generator must contact the

E-1

APPENDIX E STATUTES AND REGULATIONS AFFECTING

HAZARDOUS WASTE GENERATORS

CONTENTS

Subject Paqe E.l Introduction . . . . . . . . . . . . . . . . . . . . . E-2

E.2 Generator Standards . . . . . . . . . . . . . . . . . E-2

E.2.1 Determination of Waste Classification . . . . . E-2 E.2.2 EPA Identification Number . . . . . . . . . . . E-3 E.2.3 Uniform Hazardous Waste Manifest . . . . . . . E-3 E.2.4 Reports . . . . . . . . . . . . . . . . . . . . E-4

E.3 Recyclable Hazardous Wastes . . . . . . . . . . . . . E-4

E.4 High BTU Wastes . . . . . . . . . . . . . . . . . . . E-4

E.2.5 Packaging. Labeling and Marking Requirements . E-4 c- .

E.5 “Lab Packs1’ . . . . . . . . . . . . . . . . . . . . . E-4

E.6 Other State and Federal Statutes and Regulations . . . E-5

E.5.1 Federal Clean Water Act . . . . . . . . . . . . E-5

E.5.3 California Proposition 65 . . . . . . . . . . . E-5 E.5.2 Federal Occupational Safety and Health Act . . . E-5

E.7 Solvent Wastes: Land Disposal Restriction . . . . . . E-6

E.8 Summaries of Pertinent Statutes. Regulations and . . . . . . . . . . . . . . . . . . . . . . Ordinances E-6

E.9 Regulatory Agencies and Information . . . . . . . . . E-6

TABLES E-1 Recyclable Hazardous Wastes . . . . . . . . . . . . . E-7

E-2 Restricted Hazardous Wastes . . . . . . . . . . . . . . E-8 E-3 Solvent-Containing Hazardous Wastes for Which Land

Disposal Restrictions Were Proposed by EPA . . . . . . E-9 E-4 Summary of General Requirements . . . . . . . . . . . E-11

Hazardous Waste Generation and Management . . . . . . E-13 E-5 Selected Codes and Regulations Relevant to

E-1 a

E

October 19, 1988

APPENDIX E

STATUTES AND REGULATIONS AFFECTING HAZARDOUS WASTE GENERATORS

E.l Introduction

California generators, transporters and treatment, storage and/or disposal facility operators must comply with laws for handling hazardous materials and wastes. The California Department of Health Services (DHS) is the state agency responsible for controlling and monitoring hazardous waste management. appendix will discuss some of the federal, state, and local laws, regulations and ordinances that apply to generation, transportation, treatment, storage, and/or disposal of hazardous

This

-- -waste. Summaries of relevant requirements appear in Tables E-4 and E-5. Persons involved in regulated activities should become familiar with the requirements. If needed, additional help can be obtained from the agencies listed elsewhere in this report. Contact those sources for details and updated information.

E.2 Generator Standards

Article 6, Chapter 30, Division 4, Title 22, Califarnia Code of Regulations (CCR) details requirements with which all generators of hazardous waste must ordinarily comply. These requirements include the following:

- Determine if each generated waste is hazardous. - Obtain an EPA Identification Number. - Prepare a manifest for all off-site shipments of hazardous waste.

- Prepare and submit biennial reports covering generator activities of the previous year with respect to hazardous waste.

- Comply with requirements for generators who accumulate hazardous wastes outsite, pending off-site shipment within 90 days.

- Ship hazardous wastes off-site within 90 days or obtain a hazardous waste storage facility permit from DHS and comply with other requirements applicable to facility operators.

E-2

October 19, 1988

- Ensure that prior to shipment off-site, all wastes conform with DHS and Department of Transportation regulations for proper packaging, labeling, and marking.

- Pay applicable fees to the California State Board of Equalization for hazardous wastes generated.

The generator is responsible for meeting other requirements that might not be specified in this appendix.

E.2.1 Determination of Waste Classification

The generator of a waste must determine if the waste is hazardous. To do this, the generator must determine if the waste is specif- ically listed as a hazardous waste (Article 9, CCR), and/or if it is a characteristic hazardous waste (ignitable, corrosive, toxic, reactive) (Article 11, C C R ) . Certain wastes are also classified as

c- - @@extremely hazardous wastes." These are listed in Article 9, CCR and their characteristics are identified in Article 11, CCR.

E.2.2 EPA Identification Number

Any generator of hazardous waste must obtain from EPA or DHS an EPA Identification Number. This number must be used on all official documents involving waste generation, transportation, treatment, storage, and/or disposal. This number must also appear on all required reports. A generator shall not offer his hazardous waste to a transporter or to an operator of a treatment, storage, and/or disposal facility who does not have an EPA Identification Number.

E. 2.3 Uniform Hazardous Waste Manifest ( *@Manifestmt)

A generator who offers for transportation a hazardous waste for treatment, storage and/or disposal off-site must prepare a manifest before shipping the waste off-site. document that allows the generator and the DHS to track shipments of hazardous waste. The manifest also provides the DHS with data on waste generation throughout the state.

The generator must designate on the manifest one facility which is permitted to handle the waste described on the manifest. each manifest must be sent to the DHS, and another copy must be maintained by the generator for at least three years.

The manifest includes a waste minimization certification. "Large- Quantity1@ generators must certify "...that I have a program in place to reduce the volume and toxicity of waste generated to the degree I have determined to be economically practicable. . . .@I

language appears as Item 16 on the Uniform Hazardous Waste Manifest.) made gaod-faith efforts to minimize waste generation. The generator must also certify that he or she has chosen the safest method of treatment, storage, and/or disposal.

The manifest is a multicopied

A copy of

(This

"Small-Quantity" generators must certify that they have

E-3

October 19, 1988

E. 2.4 Reports

A generator who ships (currently) 5 tons or more of his hazardous waste off-site during the calendar year shall prepare and submit a biennial report to the DHS by March 1 of each even numbered year. The report covers generator activities with respect to hazardous wastes during the previous calendar year. A separate report must be sent annually to the California State Board of Equalization for taxation purposes.

E.2.5 Packaging, Labeling and Marking Requirements for Generators

Hazardous waste must be packaged in accordance with DHS and Department of Transportation (DOT) requirements prior to shipment to a treatment, storage and/or disposal facility. Marking and labeling must also be in accordance with DOT guidelines. A

_hazardous waste label must be affixed to all hazardous waste containers.

E.3 Recyclable Hazardous Wastes (Recyclable Materials)

If a hazardous waste such as a spent solvent can be recycled and used on-site, it might be exempt from many of the above listed requirements, as well as from DHS permit requirements. The recycling must generally be done continuously without storing the waste prior to reclamation. The recycled material is not consid- ered a waste. Other conditional exemptions for recycling of hazardous waste also exist (Section 25143.2, California Health and Safety Code [ CH&SC] ) . The DHS' regulations provide a list of recyclable hazardous wastes and suggest methods for recycling them. If a llrecyclablett waste is disposed of, the DHS may require the generator to explain why the waste was not recycled. The generator must respond. (See Section 25175, CH&SC and Sections 66763 and 66796, CCR).

E.4 High BTU Wastes

By 1990, any hazardous waste that is to be disposed and that has a heating value greater than 3000 Btu/lb must be incinerated or go through an equivalent treatment process. Also, in 1990, hazardous wastes destined for disposal and containing volatile organic compounds in concentrations exceeding standards to be determined by DHS must be incinerated or be disposed by an equivalent treatment process.

E.5 "Lab Packs"

Most laboratory-generated waste is disposed of in lab packs. Lab packs are steel drums containing small containers of compatible hazardous wastes. The small containers in the drum are packaged in chemical adsorbent. The drum is then sealed and sent to a

E-4

E

October 19, 1988

hazardous waste landfill. As of July 8 , 1989 certain waste chemicals in lab packs are restricted from landfills. Most of these are listed in Table E - 2 .

If a lab pack includes a hazardous waste that contains any of the elements/compounds at or in excess of any of the limits listed in Table E-2, it cannot be disposed on land on and after July 8 , 1989.

E . 6 Other State and Federal Statutes and Regulations

There are many federal statutes and regulations requiring compli- ance. Many of these federal laws are the same as California laws. Some of these federal and state laws are discussed below.

E . 6 . 1 Federal Clean Water Act

The Federal Clean Water Act (CWA) mandates the establishment of *- pretreatment standards for discharges to mfpublicly owned treatment

works" (POTW). Institutions that are connected to public sewers must comply with the CWA pretreatment standards. This could result in not allowing certain compounds down the drain even if diluted (e.g. formaldehyde cannot be discharged to a POTW even in minute quantities with abundant dilution).

The CWA has also established the National Pollutant Discharge Elimination System (NPDES) program which regulates discharges to surface waters. The California State Water Resources Control Board and its 9 regional boards carry out the NPDES program in California.

E . 6 . 2 Federal Occupational Safety and Health Act

The Federal Occupational Safety and Health Act (OSHA) and State occupational safety laws regulate chemical handling on public and private locations. OSHA's Wight-to-Know" provision requires employers to train their employees about hazardous substances they handle. The law applies to paid employees but not necessarily to other individuals. The OSHA vtRight-to-Know@g provisions (and state 9tRight-to-KnQw8t laws) have increased the awareness of chemical hazards and they have given impetus to the creation of hazardous waste management programs.

There is currently pending in the California Legislature a bill called the "Student-Right-To-KnowW1 bill which would require educa- tional institutions to develop a safety program for students who handle hazardous materials.

E . 6 . 3 California Proposition 65

Proposition 65 requires private employers to post warnings for persons handling carcinogenic compounds, and restricts all discharges of carcinogenic compounds. This is a new law that at

E-5

October 19, 1988

present does not affect public institutions. However, state legislation is pending that will require public institutions to comply.

E.7 Solvent Wastes: Land Disposal Restriction

The 1984 Hazardous and Solid Waste Amendments (HSWA) to RCRA mandated the November 8, 1986 federal restriction on the land disposal of halogenated and non-halogenated solvent wastes. Restricted solvent wastes are numbered F001-F005 as defined in Section 261.31, Title 40, Code of Federal Regulations. On November 7, 1986, EPA announced a conditional extension on the implementation of the restriction. restriction, solvent wastes were prohibited from land disposal starting on November 8, 1986, unless one or more of the following conditions applies:

According to the modified

The generator of the solvent waste is a small quantity generator of 100-1000 kg/month of hazardous waste.

The waste contains less than 1 percent total of F001-F005 solvent constituents.

The solvent waste is generated due to cleanup or other reme- dial action taken under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of 1980, as amended.

However, the solvent wastes listed in Items 1 to 3 above are restricted from land disposal effective November 8, 1988.

E.8 Summaries of Pertinent Statutes, Regulations and Ordinances

Table E-5 contains a list of federal, state and local statutes, regulations and ordinances that are relevant to hazardous waste generators. handling, waste disposal, air quality control, and discharges to sewers.

The list includes requirements for raw material

E.9 Regulatory Agencies and Information

Appendices G through J identify the regulatory agencies that may be contacted with questions 'on the management of hazardous wastes. Appendix F has Form DHS 8400 (6/87). obtain copies of California hazardous waste control laws and regulations.

This form can be used to

E-6

October 19, 1988

TABLE E-1

RECYCLABLE HAZARDOUS WASTES

0

0 Solvents, used or contaminated, including:

Commercial chemical products including unused laboratory grade products.

- Halogenated solvents such as trichloroethane, perchloroethylene, methylene dichloride, chloroform, carbon tetrachloride, and Freons;

- Oxygenated solvents, such as acetone, methyl ethyl ketone, methanol, ethanol, butanol, and ethyl acetate; and

- Hydrocarbon solvents, such as hexanes, Stoddard, benzene, Used or unused petroleum products, including motor oils, hydraulic fluids, cutting lubricants, and fortified weed oils.

toluene, xylenes, and paint thinner.

o

0 Pickling liquor.

0 Unspent acids, such as hydrochloric, hydrofluoric, nitric, phosphoric, and sulfuric, in concentrations exceeding 15%.

o Unspent alkalis, including: hydroxides and carbonates of sodium, potassium, and calcium; and acetylene sludge.

Unrinsed empty containers of iron or steel used for pesticides or other hazardous chemicals:

o

- Pesticide containers; and - Other hazardous chemical containers.

E-7

October 19, 1988

Element/Compound

1.

2 .

c- -

3 .

4 .

5 .

TABLE E-2

RESTRICTED HAZARDOUS WASTES

Liquid hazardous wastes containing free cyanides

Liquid hazardous wastes containing one or more of the following:

Arsenic and/or arsenic compounds

Cadmium and/or cadmium compounds

Chromium VI and/or chromium VI compounds

Lead and/or lead compounds

Mercury and/or mercury compounds

Nickel and/or nickel compounds

Selenium and/or selenium compounds

Thallium and/or thallium compounds

Liquid hazardous wastes with a pH less than or equal to 2.0

Liquid hazardous wastes containing polychlorinated biphenyls (PCBs)

Liquid hazardous wastes containing halogenated organic compounds (i.e. chlorinated solvents)

Concentration Limit of Restriction

> 500 mg/liter

> 100 mg/liter

> 500 mg/liter

> 500 mg/liter

> 2 0 mg/liter

> 134 mg/liter

- > 100 mg/liter

> 130 mg/liter

- - - - - -

-

> 50 mg/liter -

- >lo00 mg/kg

E-8

October 19, 1988

TABLE E-3

SOLVENT-CONTAINING HAZARDOUS WASTES HAVING EPA LAND DISPOSAL RESTRICTIONS

Waste code Description

FOOl The following spent halogenated solvents used in degreasing: tetrachloroethylene, trichloroethylene, methylene chloride, l,l,l-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; spent solvent mixtures/blends used in degreasing contain- ing, before use, a total of 10 percent or more (by volume) of one or more of the above halogen solvents or those solvents listed in F002, F004, and F005; and still bottom from the recovery of these spent solvents and spent solvent mixtures.

F002

F003

PO04

The following spent halogenated solvents: tetrachloroethane, chlorobenzene 1,1,2-trichloro- 1,2,2-trifluoroethaner ortho-dichlorobenzene, and trichlorofluoromethane; all spent solvent mixture/ blends containing before a total of 10 percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F001, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

The following spent nonhalogenated solvents: xylene, acetone, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol cyclohexanone, and methanol; all spent solvent mixtures/blends containing solely the above spent nonhalogenated solvents; and all spent solvent mixtures/blends containing, before

- use, one or more of the above nonhalogen solvents, and a total of 10 percent or more (by volume) of one or more of the solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.

The following spent nonhalogenates solvents: cresols and cresylic acid and nitrobenzene; all spent solvent mixtures/blends containing, before use, a total of 10 percent or more (by volume) of one or more of the above nonhalogenated solvents or those solvents listed in F001, F002, and F005; a still bottoms from the recovery of these spent solvents and spent solvent mixtures.

E-9

October 19, 1988

TABLE E-3 (continued)

Waste code Description

F005 The following spent nonhalogenated solvents: toluene, methyl ethyl ketone, carbon disulfide, isobutanol, and pyridine: all spent solvent mixtures/blends containing, beofre use, a total of 10 percent or more (by volume) of one or more of the above nonhalogenated solvents or those solvents listed in F001, F002, and F004; and still bottoms from the recovery of these spent solvents and solvent mixtures.

A November 8, 1986 at 40 CFR 268.30(b).

E-10

October 19, 1988

ACTIVITY

Waste Generation

New Process or Process Modification; Material substitution

On-site Treatment

On-site Recycling

Off-site Recycling

TABLE E-4

SUMMARY OF GENERAL REQUIREMENTS

REQUIREMENT

Shipments of waste must be accompanied by a minifest.

Prepare biennial report concerning the volume of waste generated.

If wastes are temporarily stored on site, the generator must comply with handling procedures, personnel requirements, etc.

Generators disposing of "recyclable wastes1* might be asked to provide justification for not recycling.

If the new process or process modifi- cation involves treatment of a hazardous waste, a treatment, storage and/or disposal (TSD) permit might be necessary. In some cases material substitution may constitute process modification.

Process must comply with fire codes occupational health requirements.

In general, a treatment, storage and/or disposal facility permit is required. DHS may grant variances for activities that are adequately regulated by other agencies or for wastes that are insignificantly hazardous.

Same as above; however, some on-site recycling activities are categorically exempt from permit requirements.

Commercial (i.e., off-site) recycling activities generally require a TSD permit.

Commercial recyclers must submit an annual facility report.

AGENCY

DHS

DHS

DHS, county hazardous material regulators

DHS

DHS

Local fire department, Cal/OSHA

DHS

DHS

DHS

DHS

E - 1 1

October 19, 1988

ACTIVITY

Disposal

c- .

Industrial

Industrial

TABLE E-4 (continued) SUMMARY OF GENERAL REQUIREMENTS

REQUIREMENT AGENCY Some resource recovery facilities are DHS eligible for Series @A@, IBv, or ICv resource recovery facility permits in lieu of TSD permits.

In California, several classes of hazardous waste are restricted from land disposal.

A national land disposal restriction program is being implemented.

Disposal facilities must have a TSD permit and comply with technical and financial regulations.

DHS

EPA

DHS

Air Pollution

All devices emitting air pollutants Local APCD/ must be permitted or exempted. AQMD

If changes in equipment or procedures Local APCD/ result in an increase of any pollutant AQMD above a specified level, a permit is required.

If certain designated toxic air contaminants are emitted, the generator must comply with rules established under the toxic air contaminant program.

If there is an increase in an @@attainment pollutantvt by a significant amount (generally 25 to 40 tons/yr), a permit may be necessary.

Water Pollution

Discharge of industrial waste to sewer requires a sewer permit.

Discharge of waste to land requires a discharge permit.

Discharge of waste to public waters requires an NPDES permit.

Local APCD/ AQMD

EPA Region IX

Local sewer agency

Regional Water Quality Control Board

Regional Water Quality Control Board

E-12

TABLE E-5

SELECTED STATUTES, REGULATIONS AND ORDINANCES RELEVANT TO HAZARDOUS WASTE GENERATION AND MANAGEMENT *

Category Requlation/Rule Description

Air quality SCAQMD Rule 442 Restrict discharge of SBAQMD Rule 317 organic materials into MBUAPCD Rule 4 1 6 the atmosphere from BAAQMD Regulation 8 , equipment in which Rule 3 5 solvents are used.

KCAPCD Rule 4 1 0 SLOCAPCD Rule 407 H ( 1 ) VAPCD Rule 6 6

SCAQMD Rule 4 4 3

SCAQMD Rule 1113 SBAQMD Rule 323 MBUAPCD Rule 4 2 6 BAAQMD Regulation 8 ,

KCAPCD Rule 4 1 0 . 1 SLOCAPCD Rule 407 H ( 3 )

Rule 3

SCAQMD Rule 1 1 4 1 . 1

BAAQMD Regulation 8 , Rule 5

MBUAPCD Rule 4 2 9 KCAPCD Rule 4 1 3

SBAQMD Rule 322 SOLCAPCD Rule 407 H ( 2 ) .

SBAQMD Rule 3 2 4 KCAPCD Rule 4 1 0 . 2 BAAQMD Regulation 8 ,

SLOCAPCD Rule 407 H(4) Rule 39

Requires coatings and solvents to be labeled to indicate their photochemical reacti- vity.

Establish VOC standards f o r archi- tectural and specialty architectural coat- ings.

Establish operating requirements for coat- ings and inks manu- facturing.

Deals with the storage of organic liquids.

Deal with organic liquid loading.

Prohibit photochem- ically reactive metal surface coating thinners and reducers.

Deal with the dispo- sal and evaporation of solvents.

E-13

Category

Solvent storage

R e m 1 at ion/Rul e

CCR Title 23, Chapter 3, Sub- chapter 16

CHCSC Division 20, Chapter 6.7

CCR Title 22, Div. 4, Ch. 30, Article 24

CCR Title 22, Division 4 , Chapter 30, Article 6

CH&SC Section 25123.3

CH&SC Division 20 Chapter 6.95

CCR Title 22, Division 4, Chapter 30, Section 66470 to Section 66515

Hazardous CCR Title 22, Materials Division 4, and Wastes Chapter 30,

Section 66680

Description

Addresses underground storage of solvents.

Regulates underground storage of hazardous substances.

Regulates the use and management of containers.

Sets requirements for generators of hazardous wastes including restrictions on how long wastes can be accumulated without the storage facility being permitted.

Definition of "storage facility'', including quality and time limits for qualification as a storage facility.

Requires local government agencies to implement hazardous material manage- ment programs requiring local businesses to submit business plans and inventories for the storage and handling of hazardous materials.

Require generators of hazardous waste to store, label, and manifest hazardous wastes properly.

Lists specific elements, compounds, and generic materials that are potentially hazardous wastes when they are no longer useful. For example, llsolventsl' are

E-14

Cateqory Requlation/Rule

40 CFR Part 268

CCR Title 22, Division 4, Chapter 30, Section 66693 to Section 66723

CH&SC Sec. 25180 to Section 25196

wastewater Clean Water Act discharge 32 U.S.C. 1251

et seq.

Safe Drinking Water Act. .

40 CFR 141

NPDES regulations 40 CFR 122

- CCR Title 23 subchapter 9

Local municipal codes addressing discharges to POTWs

Description

listed as potentially hazardous based on the ignitability criterion.

Sets forth federal regula- tions that restrict the disposal of spent solvents and solvent-containing wastes.

List the criteria for determining whether a waste is considered hazardous or extremely hazardous, using criteria for ignitability, toxicity, corrosivity, and/ or reactivity.

Identify penalties for non-compliance with hazardous waste control laws and regulations.

Water quality control for waste water disposed in surface waters, municipal sewers, and injection well.

Water quality control for waste water disposed in surface waters, municipal sewers, and injection well.

Regulations on the reduction of pollutant discharges into the waters of the United States.

State regulations govern- ing the discharge of waste waters to surface waters. Includes provisions for issuance of permits and setting effluent limitations.

Discharge requirements set by local POTWs restricting the concentrations of pol- lutants in waste waters discharged to sanitary sewers.

E-15

Cateqory Regulation/Rule

Waste CH&SC Section treatment, 25175 recycling, or disposal

Title 2 2 , CCR Section 66796

Title 22, CCR Section 66763 and CHCSC Section 25175

CH&SC, Section 25143.2 (b), (c) and (e)

CH&SC Section 25180-25196

CH&SC Sections 25180-25196

CH&SC Section 25155.5(a)

Description

Authorizes DHS to provide a listing of recyclable hazardous wastes found by DHS to be economically and technically feasible to recycle. A l s o authorizes fee penalties for failure to do so, as specified.

List for CH&SC Section 25175 provides a list of recyclable wastes and suggests methods for recycling them.

Specifies method for CH&SC Section 25175 if a ttrecyclablett hazardous waste is disposed, authorizes DHS to request that the generator explain why the waste was not recycled. The generator must respond. DHS can assess penalties for failure to comply.

Exempt recyclable materials from hazardous waste control require- ments if they meet certain conditions.

Specifies penalties for generator non-compliance with the regulations.

Specifies penalties for facilities with permits, non-compliance with the regulations.

Requires incineration or equivalent treatment of hazardous wastes with greater than 3000 Btu/lb. Existing law becomes effective postponed to 1990.

E-16

Category Requlation/Rule

CHtSC Section 25155.5(b)

CH&SC Section 25208.4

CH&SC Section 25202.9

CH&SC Section 25244.4

CH&SC Section 25179.6

40 CFR Part 165

Description

Requires incineration or equivalent treatment of hazardous wastes containing volatile organic compounds in concentrations exceeding standards to be determined by DHS. Existing law becomes effective in 1990.

Prohibits discharge of any liquid hazardous waste into a surface impoundment located within 1/2 mile of a potential source of drinking water. Contains important exemption provisions.

Requires annual certifica- tion by hazardous waste generators who operate onsite TSD facilities that they have a waste minimization program in operation. Further, they must certify that the treatment, storage; or disposal methods minimize threats to human health and environment.

Requires generators to submit a report every two years on waste reduction status.

Would prohibit land disposal of all untreated hazardous wastes with specified exceptions. Effective 1990.

Recommended procedures for the disposal and storage of pesticides and pesticide containers.

E-17

Category

Land disposal

~ - . .

Requlation/Rule

32A CFR Part 650

CH&SC Section 25122.7 and Title 22 CCR Sections 66900- 66935

40 CFR Section 264.314 (b)

RCRA Section 3004(e) (1)

40 CFR Section 268.3

40 CFR Section 265.314 and CCR Title 22, Div. 4, Ch. 30, Sec. 67422

General 40 CFR Part 446

Description

Hazardous and toxic materials management (bibliography and tables).

Specifies lanu disposal restrictions. Lists therein restricted hazardous wastes which include wastes containing more than 1000 mg/kg of halogenated organic compounds.

Prohibits land dis- posal of bulk or non- containerized liquid hazardous waste or hazardous waste con- taining free liquids.

Prohibits land disposal of most solvents unless treatment levels (2 ppm for most constituents) are met.

Prohibits land disposal of dilute waste waters containing solvents and having 1% or less total organics.

Prohibits land disposal of bulk or non- containerized liquid hazardous wastes or hazardous wastes containing free liquids.

EPA guidelines and standards for Paint formulating industry.

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Abbreviations:

APCD - Air Pollution Control District AQMD - Air Quality Management District BA - Bay Area Btu - British thermal unit CCR - California Code of Regulations CFR - Code of Federal Regulations CH&SC- California Health and Safety Code DHS - Department of Health Services KC - Kern County MBU - Monterey Bay Unified NPDES- National Pollutant Discharge Elimination System POTW - Publicly Owned Treatment Works RCRA - Resource Conservation and Recovery Act SB - Santa Barbara SLOC - San Luis Obispo County TSD - Treatment, Storage, or Disposal VOC - Volatile Organic Compounds V - Ventura * The generator should contact the appropriate local, state, or federal authority for complete, detailed, and updated regulatory information.

---SC - South Coast

Source: Jacobs Engineering Group, Inc. 1987; and ESE, 1987.

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8 7 2 0 0 5 2 A P B COT-16

APPENDIX F REGULATORY AGE N C I E S

Regulatory agency locations and telephone numbers are presented in the following pages.

F- 1

Table F-1 FEDERAL AND STATE AGENCIES

Federal Agenc ieq

U . S . Environmental Protection Agency RCRA/Superfund Hotline Title I11 Hotline Small Business Ombudsman Hotline Region XI - San Francisco

General Information Industry Assistance Line Emergency Response Section Asbestos Information Radon Information

U . S . Department of Transportation Information Hotline Southern California (El Monte) Northern California (Sacramento)

U.S. Coast Guard/National Response Center U.S. Public Health Service, National Health

Information Clearinghouse

Other

Chemical Manufacturers Association CHEXTREC (transportation accidents) CHEMTREC (non-emergencies) National Pesticide Telecom Network 800-858-7378 National Animal Poison Control Center

State Agencies

California Department of Health Services Used Oil Recycling and Regulatory Information Manifest and EPA Identification Number Information Recycl'ing of Hazardous Wastes Northern California Section North Coast California Section Southern California Section Fresno District Office Transportation Unit

Office of Emergency Services 24-Hour Number for Reporting Spills/Releases Hazardous Materials/Emergency Response Planning

California State Water Resources Control Board Water Quality Division Underground Tank Program

800-424-9346 800-535-0202 800-368-5888

415-974-8071 415-974-7472 415-974-8131 415-974-7551 415-974-8378

202-366-4488 818-405-7110 916-551-1300

800-424-8802 800-336-4797

800-424-9300 202-887-1255

217-333-3611

916-324-1807 916-324-1781 916-324-1807 916-739-3145 415-540-2043 213-620-2380 209-445-5938 916-323-6042

800-852-7550 916-427-4287

916-445-9552 916-324-1262

F-2

Table F-1 FEDERAL AND STATE AGENCIES (CONT.)

California Waste Management Board General Information on Solid Waste Used-oil Recycling Center Locations

California Highway Patrol/Motor Carrier Section

916-322-3330 800-553-2962

916-445-6211

California Local Air Pollution Control Districts Amador County-APCD (Mountain Counties) Bay Area AQMD (San Francisco Bay Area) Butte County APCD (Sacramento Valley) Calaveras County APCD (Mountain Counties) Colusa County APCD (Sacramento Valley) El Dorado County APCD (Lake Tahoe and Mountain Counties) Fresno County APCD (San Joaquin Valley) Glenn County APCD (Sacramento Valley) Great Basin Unified APCD (Great Basin Valleys)

Kern County APCD (San Joaquin Valley and Southeast Desert) Kings County APCD (San Joaquin Valley) Lake County AQMD (Lake County) Lassen County APCD (Northeast Plateau) Madera County APCD (San Joaquin Valley) Mariposa County APCD (Mountain Counties) Mendocino County APCD (North Coast) Merced County APCD (San Joaquin Valley) Modoc County APCD (Northeast Plateau) Montery Bay Unified APCD (North Central Coast) Mountain Counties Air Basin North Coast Unified AQMD (North Coast Air Basin) Northern Sierra AQMD (Mountain Counties Air Basin) Northern Sonoma County APCD (North Coast) Placer County APCD (Lake Tahoe, Mountain Counties, and Sacramento Valley) Sacramento County APCD (sacramento Valley) San Bernadino County APCD (Southeast Desert) San Diego County APCD (San Diego) San Joaquin County APCD (San Joaquin Valley) San Luis Obispo County APCD (South Central Coast) Santa Barbara County APCD (South Central Coast) Shasta County APCD (Northeast Plateau and Sacramento Valley) Siskiyou County APCD (Northeast Plateau) South Coast AQMD (South Coast) Stanislaus County APCD (San Joaquin Valley) Sutter County APCD (San Joaquin Valley) Tehama County APCD (Sacramento Valley) Tulare County APCD (San Joaquin Valley) Tuolumne County APCD (Mountain Counties) Ventura County APCD (South Central Coast) Yolo-Solano APCD (Sacramento Valley) Yuba County APCD (Sacramento Valley)

c- - Imperial County APCD (Southeast Desert)

F- 3

Permitting. Surveillance And Enforcement Of Local Treatment. Storage And Disposal Facilities

Local Superfund And Other Site Mitigation ActiviIiet

Val Siebal, Chief REGION ~/SACIU%I'O

42% Power Inn Road Sacramento. CA 95826

/Toxic Substances Control Division

916/739-3145

REGION l/FRESNO .Toxic Substances Control D~~~~~~~ 5545 East Shields Avenue

vard Hatayama, Chief GION Z/MERWIU

trkeley. CA 94608 5/540-2043

Dennis Dickerson, Chief REGION 3lBURBANK Toxic Substances Control Division 1405 NO. San Fernando Blvd., Suite 300 Burbank, CA 91504 818I567-3OOO

I

REGIONAL OFFICES OF CALIFORNIA DEPARTMENT OF HEALTH SERVICES TOXIC S U B S T A N C E S CONTROL DIVISION AND THE REGIONS SERVED BY THEM

.. F-4

STATE WATER RESOURCES CONTROL BOARD P. 0. Box 100, Sacramento, CA 95801

CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARDS

NORTH COAST REGION (1) 1440 Guerneville Road Santa Rosa, CA 95403

SAN FRANCISCO BAY REGION (2) 11 11 Jackson Street, Rm. 6040 Oakland, CA 94607

(707) 576-2220

(41 5) 464-1 255

CENTRAL COAST REGION (3) 1102-A Laurel Lane San Luis Obispo, CA 93401

LOS ANGELES REGION (4) 107 South Broadway, Rm. 4027 Los Angeles, CA 90012 (21 3) 620-4460 CENTRAL VALLEY REGION (5) 3443 Routier Road Sacramento, CA 95827-3098

Fresno Branch Off ice 3614 East Ashlan Ave. Fresno, CA 93726

Redding Branch Office 100 East Cypress Avenue Redding, CA 96002

(805) 99-31 47

(91 6) 361 -5600

(209) 445-51 16

LAHONTAN REGION (6) 2092 Lake Tahoe Boulevard P. 0. Box 9428 - South Lake Tahoe, CA 95731

Victonrille Branch Off ice 15371 Bonanza Road Victorville, CA 92392

(91 6) 544-3481

(619) 241-6583 COLORADO RIVER BASIN REGION (7) 73-271 Highway 11 1 , Ste. 21 Palm Desert, CA 92260

SANTA ANA REGION (8) 6809 Indiana Avenue, Ste. 200 Riverside, CA 92506 (714) 7824130 SAN DlEGO REGION (9) 9771 Clairemont Mesa Blvd. Ste. 8 San Diego, CA 92124

(61 9) 346-7491

(619) 265-5114

8-87

F-5

8720052APB COT-17

APPENDIX G ORDER FORM FOR HAZARDOUS

WASTE LAWS AND REGULATIONS

The fol lowing order form may be used t o obtain Ca l i fo rn ia hazardous waste control laws and regulations.

G- 1

State o f Cal l fornl tHaalth and Welfare Awncy Dooartmnt of Hwlth Swviur

ORDER FORM FOR CALIFORNIA HAZARDOUS WASTE CONTROL

LAWS AND REGULATIONS

Copies of hazardous waste control laws and regulations administered by the California Department of Health Services may be ordered by completing the form below and mailing it with the applicable payment to:

Department of General Services, Publications Section P.O. Box 1015 North Highlands, CA 95660

The laws and regulations are not identical, so both are generally needed to obtain complete information.

The laws (Chapters 6.5 through 6.98, Division 20, California Health and Safety Code) were enacted by the Legislature. Recent history indicates that the laws change to some extent each year, usually effective January first. TO keep UP to date with the laws, reorder them each year, because no amendment service is available.

The regulations (Chapter 30, Division 4, Title 22, California Code of Regulations) were adopted by the Department of Health Services within the scope of the DHS' authority under the laws. The regulations may change a t any time during the year according to specified administrative procedures. Therefore, continuous amendment service is avaTiable by subscription. The amendment service is useful only in conjunction with the complete regulations (i.e., Division 4, Title 22, CCR).

(916) 973-3700

I . Please check al l applicable boxes and complete all applicable blanks.

0

0

0

Please send me Control Law (Chapten 6.5 - 6.98, Division 20, Health and Safety Code), at $25.00 per copy, including postage, taxes, and handling costs.

Please send me Code of Regulations [CCR] ) at $8.48 per copy, including postage, taxes, and handling costs. (Item Number 0030-0224-7)

Please accept my subscription(s) to the continuous amendment service for the regulations (Division 4, Title 22, CCR) at $12.00 per subscription per year, including postage and handling costs. The complete regulations must be ordered separately by checking the applicable box. (Item Number 22-04-00)

Make check or money order for the total amount payable to: State of California.

copy(ies) of Item No. 7540-958- 1016-6, Hazardous Waste $

copy(ies) of the regulations (Division 4, Title 22, California $

S

\

TOTAL AMOUNT $

I I . Please print or lype your mailing address and telephone number below; then sign and date the form.

NcmeKompany Name

Attention

Address

City State Zip

Telephone Number (In case we need to contact you about your order)

DHS 8400 (2/89) ' 6-2

c- .