This paper presents general guidelines on what electroplaters and surface finishers need

Transcription

1 POLLUTION PpEVENTION PLANNING FOR ELECTROPLATERS Daniel P. Reinke, P.E. Capsule Environmental Engineering, Inc Oakcrest Avenue, Suite 215 St. Paul, Minnesota qF u2 Many states as well as the EPA are actively working to reduce industrial wastes and emissions through voluntary and mandatory efforts by manufacturers. As part of this work, 17 states have passed legislation requiring companies to prepare written plans that address the sources of wastes and emissions within the facility, options for reducing these wastes, and facility plans to implement these options. This paper presents general guidelines on what electroplaters and surface finishers need to do to meet these planning requirements, as well as the resources available to assist them in these efforts. Introduction With every manifest they complete, large quantity generators of hazardous waste certify that they have a program in place to reduce the volume and toxicity of their waste. In recent years, however, additional regulations have been promulgated that require generators to take a more structured role to reduce their wastes and emissions. These regulations are coming at manufacturers from many fronts. The benefits of implementing pollution prevention projects are well documented. Large and small companies have realized reductions in the following areas: Raw materials costs Waste management capital and operating costs Regulatory costs and reporting requirements Disposal liabilities Potentiai for spiiis Employee health and safety concerns Permitting requirements Compliance difficulties In addition, pollution prevention has resulted in improved process efficiencies, product quality, and customer and community relations. 1

2 I I The Proceedings oi the 79th AESF Annual Technical Conference SUWF~NQ w ~ z S M N i Aun- ZZ=ZL5,1SDSZ Atlanta, Georgia The American Electroplaters and Surface Finishers Society, Inc. (AESF) is an international, individualmembership, professional, technical and educational society for the advancement of electroplating and surface finishing. AESF fosters this advancement through a broad research program and comprehensive educational programs, which benefit its members and all persons involved in this widely diversified industry, as well as govemment agencies and the general public. AESF disseminates technical and practical information through its monthly joumal, Plating and Surface finishing, and through reports and other publications, meetings, symposia and conferences. Membership in AESF is open to all surface finishing professionals as well as to those who provide services, supplies, equipment, and support to the industry. According to the guidelines established by AESF s Meetings and Symposia Committee, all authors of papers to be presented at SUWFIN@ have been requested to avoid commercialism of any kind, which includes references to company names (except in the title page of the paper), proprietary processes or equipment. Statements of fact or opinion in these papers are those of the contributors, and the AESF assumes no responsibility for them. All acknowledgments and references in the papers are the responsibility of the authors. Published by the American Eiedroplaters and Sudace Finishers Society, Inc Research Parkway Ollando, FL Telephone: Fax: Copyright 1992 by American Electroplaters and Surface Finishers Society, Inc. AI1 rights reserved. Printed in the United States of America. Ibis wblication may not be reproduced, stored in a retrieval system, or transmitted in whole or part. in anv form or by any means, electronic, mechanical, photocopying, recording, or otherwise without the prior written permission of AESF, Research Parkway, Orlando, FL Printed by AESF Press SUmINeis a registered trademark of the American Electmplaters and Surface Finishers Society, Inc.

3 While many companies have jumped on the bandwagon and now actively promote pollution prevention, many others have been slower to realize these benefits. To further encourage firms to conduct these activities, state and federal laws and regulations have been developed. From a political viewpoint, these laws are difficult to oppose. They require manufacturers (polluters) to do something that will ultimately save them money and reduce the impact of their facility on the environment. For this reason it is not unreasonable to expect that further regulations in this field will be forthcoming. The specific regulations vary in scope and impact. Most laws focus on "pollution prevention. 'I EPA defines pollution prevention as "the reduction, elimination, or recycling of pollutants otherwise discharged into the air, water or land." Pollution prevention can be accomplished through source reduction, reuse and recycling. Massachusetts and Oregon have laws addressing "toxic use reduction," which is more controversial since these laws target the actual materials used in the manufacturing process instead of the emissions and wastes created through the processes. A closed loop hexavalent chrome plating process with a 100 percent efficiency scrubber system may adequately address pollution prevention regulations, whereas conversion to trivalent chrome plating may be required to meet toxics use reduction goals. Regulatory agencies are also mandating pollution prevention activities through permit requirements. Facilities may only be able to meet tightening emissions and discharge limits by significantly modifying processes. Some platers are changing from cyanide to noncyanide processes while others have installed zero-discharge systems to address wastewater violations. In addition to regulatory requirements for pollution prevention, there are other factors encouraging certain manufacturers to conduct these activities. Environmental organizations conducting citizen suits against violators of SARA reporting requirements or the Clean Water Act are including pollution prevention planning requirements in negotiated settlements. Environmental certification programs such as the Green Seal may require that member companies have active pollution prevention programs. The Chemical Manufacturers Association requires members to adhere to the Responsible Care program, which calls for continued pollution prevention efforts. Federal Programs There =e several federal iquirenefits h i pohtiofi preventior, plannkg. Under the Pollution Prevention Act of 1990, toxic release inventory reporting forms (Form Rs) must now include questions on pollution prevention activities. Questions are included on source reduction practices used, recycling practices, production ratios and techniques used to identify source reduction opportunities

4 Under the new storm water permitting requirements, facilities that report releases on Form Rs that are seeking general permits must include a discussion of pollution prevention activities in the permit application. At this writing, rules were not finalized for facilities seklcing individual permits. In addition, the phase-out of the production of ozone-depleting chemicals represents chemical-specific federal pollution prevention activities. President Bush has recently proposed an accelerated schedule to eliminate CFC production by State Programs As of the writing of this paper, 17 states have passed laws requiring certain facilities to prepare pollution prevention plans. These states include Arizona, California, Georgia, Louisiana, Maine, Massachusetts, Minnesota, Mississippi, New Jersey, New York, North Carolina, Oregon, South Carolina, Tennessee, Texas, Vermont and Washington. In addition, Georgia s law requires out-of-state large quantity generators who use Georgia s hazardous waste facilities to also prepare pollution prevention plans. The exact requirements of pollution prevention or toxic use reduction plans vary from state to state. In general, however, the laws require the following items to be included in a plan: certification policy statement description of facility and processes description of wastes and emissions description of present pollution prevention practices identification of options evaluation of options - environmental, technical and economic selection of options implementation schedule Progress towards implementing the plan components is either addressed through plan updates or progress reports. Progress reporting typically allows for an adjustment in waste generation due to changes in production levels. For platers, production levels are usually best expressed in square feet of plated area. Other potential production indicators include machine run time for automatic plating lines and direct labor hours for hand lines. E I 3

5 PreparinP a Plan It may be possible to meet the legal requirements for a pollution prevention plan by one individual sitting down with the necessary data and writing up a discussion of available options. The plan can be set aside on a shelf and no changes made on the shop floor other than those previously planned. In order to reap the benefits of pollution prevention planning, however, you must identify and implement specific activities. A good plan can be viewed as a business planning document. Preparing a business management plan requires input from sales, operations, legal, and financial groups. Likewise, preparing a pollution prevention plan may require input from purchasing, vendors, marketing, product engineering, quality control, operations, environmental, and maintenance groups. If the plan is to be released to the public, it may also be beneficial to enlist the services d a specialist in community relations to review the plan. As with a business plan, it is important to establish goals. There are two types of goals that can be set. The first are broad corporate or facility-wide goals, such as the elimination of SARA Form R releases or a 90 percent reduction of hazardous waste generation. Other goals are process specific and are targeted to the individual projects developed in the planning process. Developing goals is beneficial because it helps focus facility efforts. Goals can be included in the policy statements required in some pollution prevention plans. Developing goals requires the support and commitment of upper management. This support is needed both to initiate and sustain a successful program, and should be periodically reinforced. Reinforcement of management support can be accomplished through employee meetings for smaller companies or through a newsletter or bulletin board postings for larger firms. Presenting a description of current processes and the wastes and emissions generated from those processes can be difficult. If wastewater from a number of plating operations is combined prior to treatment, you may need to measure the flow and analyze wastewater samples from each process to estimate the amount of sludge resulting from each operation. Another alternative for estimating the impact of various processes on sludge generation is to compare the total (not TCLP) metals concentration in a representative sample of the sludge. Developing and evaluating options is the key to a good plan. The key to developing options is to review every process in the facility while asking "Why?" Often by asking simple questions, simple answers appear. For a captive shop, product modifications could eliminate the need for plating altogether. For a job shop, changing to trivalent chrome or noncykide processes may be possible. These basic product changes should be identified and evaluated first before studying process modifications such as dragout reduction and zero discharge systems

6 37 A number of resources are available to assist in developing and evaluating pollution prevention options. Resources include: employees trade associations vendors consultants state technical assistance programs (TAPS) EPA pollution prevention database regulators universitiedtrade schools The person or team preparing the plan needs to discuss potential options with the individuals whose support will be necessary to implement the recommended options. Enlisting the support of these people will minimize the potential for problems after implementation. The operators and maintenance personnel involved with a particular process are often the most knowledgeable people on that process and can be a valuable source of ideas on how to make that process more efficient. Once a list of options is developed, these options must be evaluated and selected for implementation. Factors to consider in evaluating options are listed below. The relative importance of these factors needs to be established for each facility to determine which option is best for that facility s operations. capital cost and availability operating cost savings environmental impact, both short- and long-term occupational hazards impact labor requirements or savings maintenance requirements or savings energy requirements or savings technical risk product changes required and customer approvals process changes required additional facility changes required production shutdown requirements technical support required and available implementation schedule Generally, these factors fall into three general categories - environmental issues, technical issues and economic issues. Team members should consult the internal and external resources listed earlier for help with the environmental and technical review of Options, which usually occurs before the economic evaluation. Those involved in the 5

7 environmental and technical review would ask the following questions: Will it prevent pollution? Will the option work in this application? Has it worked ekewhere in similar conditions? What are the potential problems? What are the labor and maintenance requirements? What results have been obtained? The economic review of pollution prevention options is generally no different than that conducted for any facility capital expenditures. However, for a pollution prevention project, a facility may allow a longer payback or return on investment in an attempt to account for the numerous intangible benefits. Obtaining the information necessary to conduct the economic review is not always an easy task. The evaluation must include capital and operating costs as well as expected savings. While vendors can supply much of this information, facility personnel also must review the numbers to ensure they accurately represent the expected costs and savings for the facility. This review should again use the internal and external resources identified earlier. In the review process, certain options may fall out as being obviously beneficial and easily implemented. Other options may have longer paybacks but may have a high priority due to intangible benefits. This prioritization of projects should lead to the development of an overall schedule for implementation of selected activities. The schedule should be realistic and should consider personnel available to complete the projects. With the information developed in the review process and the overall project schedules, you should be able to estimate expected reductions in wastes and emissions. If these reductions do not meet the corporate or facility-wide goals, additional projects may need to be identified. The plan should include a discussion of all the options identified and evaluated, as well as the reasons for selecting certain options for implementation. Writing this all into the plan simplifies any plan updates or progress reports that must be completed. Once the plan document is completed, it typically must be certified by the management personnel responsible for the facility. Specific state regulations should be reviewed to determine the submittal requirements. In some states, including Minnesota and Mississippi, plans do not need to be submitted and are nonpublic documents. In other states, such as Washington and Oregon, you must submit a certification that you have completed your plan or an executive summary of the plan. In New Jersey, Arizona, and Georgia full plans must be submitted to the 6 376

8 regulatory agency. Many states require that the plan be made available to regulatory inspectors. In California the plans must be made available to the general public upon request. Typically states require submittal of penodic progress reports. Summq New pollution prevention regulations aside, the procedure of evaluating products and processes for waste reduction opportunities is a logical step for any manufacturer looking to improve cost efficiency. A critical review of your operations allows you step back from daily activities and evaluate where you are going and how to get there. Pollution prevention planning provides a method for realizing the benefits of effective manufacturing processes. 7