3ONMENTAL ENGINEERING, INC CREST AVENUE, SUITE 21 5.UL, MINNESOTA (612) DATE: Copyright 1992 Capsule Environmental Engineering, Inc.

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1 MINNESOlA, TECHNICAL ASSISTANCE PROGRAM TH ST SE STE 207 MINNEAPOLIS, MN (MN Only) FAX ONMENTAL ENGINEERING, INC CREST AVENUE, SUITE 21 5.UL, MINNESOTA (612) printed on recycled papet DATE: JUNE 25, 1991 Copyright 1992 Capsule Environmental Engineering, Inc.

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3 A SAMPLE POLLUTION PREVENTION PLAN PREPARED FOR: CAPSULE EQUIPMENT COMPANY 100 MAIN STREET BORA BORA, MINNESOTA PREPARED BY: CAPSULE ENVIRONMENTAL ENGINEERING, INC OAKCREST AVENUE, SUITE 21 5 ST. PAUL, MINNESOTA (61 2) DATE: JUNE 25, 1991 Copyright 1992 Capsule Environmental Engineering, Inc.

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5 CERTlFlCATlON of the POLLUTION PREVENTION PLAN for the Capsule Equipment Company Bora Bora, Minnesota I certify under penalty of law that I have personally examined and am famiiiar with the information contained in this plan, and that based on my inquiry of those individuals who prepared or are responsible for obtaining that information, I believe that the information is true, accurare and complete. I am aware that there are significant penalties for submitting false information, incfuding the possibility of fines and imprisonment. Facility Manager Title Date Company Officer Title Date

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7 TABLE OF CONTENTS Pollution Prevention Policy... Facility Identification... Name and Location... SICCode... Business Activity... Time in Business... Number of Employees... Facility Description... Major Wastestreams and Emission Sources... Current Pollution Prevention Practices... Machining... Cleaning... Painting... Plating... Pollution Prevention Options... Machining... Cleaning... Painting... Plating.... Technological and Economic Feasibility Study a 9 Machining... 9 Cleaning... 9 Painting Plating Goals and Objectives Appendices Appendix A: Appendix B: Block Ftow Diagrams Economic Analyses

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9 POLLUTiON PAEVENTiON POLICY for Capsule Equipment Company Capsule Equipment Company is commirted to excellence and leadership in protecting the environment. In keeping with this policy, our objective is to work towards the elimination of hazardous wastes and emissions by modifying our products and processes. We strive to set a standard for excellence in pollution prevendon. By successfully preventing pollution at its source, we can achieve cost savings, increase operational efficiencies. improve the quality of our products and services, and maintain a safe and healthy work place for our employees. Capsule Equipment Company's environmental guidelines include the following: e e e Environmental protection is everyone's responsibility. Capsule is committed to being a good neighbor and to operate in complete compliance with federal, state, and local environmental laws. Meeting this commitment requires the continued efforts of all employees. Preventing pollution by reducing and eliminating the generation of waste and emissions at the saurce is a prime consideration in plant operations. Capsule is cnmmitted to identifying and implementing pollution prevention opportunities through encouragement and involvement of all employees. Technologies and methods which substitute nonhazardous materials and utilize other source reduction approaches will be given top priority in addressing all environmental issues

10 . FACILITY IOENTlFlCATlON Name and Lacar ion Capsule Equipmenr Company 100 Main Street Bora Bora. Minnesota 55555, SIC Code Farm Machinery and Equipment Business Activity Capsule Equipment Company manufactures an automated food dispensing system for farm animals. The equipment made at this facility is a control mechanism which consists of a cabinet containing various small machined parts. Parts are machined and plated, and cabinets are formed and painted at Capsule. - Time in Bus ines -- Capsule Equipment Company ha5 manufactgred.cabinets.a this 'facility since _ ;.i +'.''.?"),/": ~..., Number of Emaloveez. ~. ~. Average number of employees:

11 FACILIN DESCRfPTlON Capsule Equipment Company manufacturing operations can be broken down into three areas: fabricating, painting, and plating. The fabricating area consists of machining, press and welding operations, and also has supponing operations such as cleaning. Two types Of cleaning processes are used on production pans: immersion tanks with an alkaline cleaning solution for in-process cleaning and 1,1,1 trichloroethane vapor degreasing for final cleaning. The machining operations use both straight cuning oils and water soluble coolants. The cabinets are painted for both aesthetics and corrosion protection. The painting is done using conventional air spray application equipment in dry booths. Solventbased compliance coatings consisting of 20 to 25 percent 1,1,1 trichloroethane make up the majority of paint used. The plating area contains two automatic barrel non-cyanide alkaline zinc dichromate plating lines and the facility wastewater pretreatment system. Carbon steel parts are plated to provide corrosion protection for the components

12 MAJOR WASTESTREAMS AND EMISSION SOU RCES In order to establish priorities. Capsule defines a major wastestream as one which constitutes greater than 5 percent by weight of the total hazardous waste generated at the facility. Ultrafiltration waste is also included in this evaluation even though it is not a hazardous waste since Capsule is concerned that this oily wastestream could be regulated as a hazardous waste in the future. Processes which generate SARA Title 111 Form R reponable emissions are considered major sources of emissions. Appendix A includes block diagrams showing the raw materials used, final products produced, and hazardous wastes and emissions generated for each process. Wastest ream Waste Quantity Emissions o m Wastewater pretreatment sludge 32,000 Cleaning wastes (trichloroethane) 17,000 50,000 Ultrafilter oii/water concentrate 61,400 Paint wastes (trichloroethane)..i= , Total 125,800 70,

13 CURRENT POLLUTION PREVENTION PRACTICES Mach in ing Many of the machining oils have been replaced by aqueous solutions to minimize the generation of oily wastes. All aqueous machining waste is processed through an ultrafilter to remove oil prior to being pumped to the wastewater pretreatment system. The wastewater from the ultrafilter is processed through the same pretreatment system used for the plating wastewater to remove any metals before final discharge. Gleaninq A small aqueous cleaning system was purchased to remove coolants and oils prior to in-process inspection. This system eliminated the use of solvent cold cleaners. The vapor degreaser is covered when it is not in use and is also equipped with a still for solvent recovery. Painrinq.-.. Painting wastes are minimized through good employee practices.. These practices include keeping unused paint containers covered, minimizing the amount of solvent used for gun cleaning, and avoiding leaving excessive paint in pots which may-:.:.:: require disposal. PIatino In the plating area, water is conserved by turning off rinses when the system is not in use. Flow restrictors have been installed on all rinses. Deionized water is used to make up baths to minimize sludge generation and reduce the need to dispose of baths. Capsule also convened from cyanide zinc plating to non-cyanide alkaline processes. While it was hoped this would allow waste sludge to be considered nonhazardous (non-cyanide zinc plating on steel is exempt from F006 classification), it is still hazardous due to the presence of leachable chrome. The current plating wasewater treatment system consists of chrome reduction, metals precipitation, and ph adjustment to remove metals from plating and ultrafiltered fabricating wastewater. '.._ - Lz

14 POLLUTlON PREVENTION OPTIONS Machininq A coolant management program can be developed to review the types of coolants being used and if and how they can be recycled. Through consolidation the number of coolants will be reduced, making recycling easier to accomplish. The processes still using straight oils can be evaluated for the feasibility of switching to water soluble machining fluids. If this cannot be done, the oils can be filtered and reused. Several'equipment options are available for the coolant recycling program. A central or satellite recycling system can be implemented. A senling tank using a drag chain can be used for chip removal or a filtration device can be used. Belts, discs or coalescers can be used to remove contaminating tramp oils. Finally a chemical maintenance program is required for biocide addition, ph adjustment, and coolant make-up. The key to good fluid management is to have a commitred program supporred by management and operations personnel. The program requires regular artention.. with machine and chemical maintenance:.the proper fluid recycling equipment can.'.. simplify the management of -such a program:- '..' - ' ' - -. There are two systems being considered. - 8oth:options require the: use of water soluble metal working fluids. Since there is no existing trenching system at Capsule's facility, satellite systems are recommended over a central system. A sump cleaner will be used to empty the machine sumps and transpon the contaminated fluid to the recycling equipment. The sump cleaner will have a 1 cubic foot capacity strainer with a fabric liner to capture metal chips and fines. Overhead return pipes will return the cleaned fluid to the machines. System One is a single pass pasteurization unit. The used fluid is heated to 160 degrees Fahrenheit to kill most of the bacteria. The heat also improves the removal of tramp oil by coalescence. Chemical maintenance takes place in the clean fluid tank. The entire operation treats 200 gallons of fluid in eigh? hours. System Two is a filtration and coalescing unit. A floating skimmer in the inlet tank removes free floating tramp oils, and a bag filter is used to remove suspended solids. The bag filter prevents buildup of fines on the coalescer. The coalescer removes free floating, dispersed, and loosely emulsified tramp oils. The fluid overflows from the clean tank to the dirty tank for further clarification, providing

15 continuous processing. Chemical maintenance takes place in the clean tank. For coolants which cannot be recycled. the plant has an ultrafiltration sysrem. There are improvements that can be made to the system to ensure more efficient operation and reduced machine downtime. The benefit of these changes are that the improved sysrem will reduce the amount of coolanrs wnicf! are shipped off site. The plant can more tightly control what is disoosed in the waste coolant tank. Tramp oils or other floating oil sludges and solids should not enter the system. 'These will cause the membranes to foul more quickly, if not damage them permanently. Oil skimmers can be used wherever possible to remove the floating oils from coolants before processing, and filtration should be used in areas like the slop room to reduce solids loading. Cleaning Significant waste and emission reductions can be realized in the cleaning/degreasing operations. The existing degreaser can be retrofitted and brought up to current standards or a new degreaser can be purchased. To eliminate solvent use entirely, the degreasing process can be replaced with aqueous cleaning operations. It is important to have adequate rinsing following the aqueous deaning to minimize spotting and poor paint adhesion. The spent aqueous c!eaner along with the spent alkaline cieaner already in use can be transferred to the ultrafiltration system for concentration prior to disposal. Filtration and reuse of the cleaner should be investigated to reduce the volume of spent cleaner produced... s. Paintinq The painting at Capsule is done using conventional air spray application equipment in dry booths where solvent-based coatings consisting Of 1,1,1 trichlorethylene make up the majority of paint used. In order to reduce the emissions and solvent wastes, high solids and waterborne paints should be considered. Also more efficient paint applicarion equipment can be used. Powder coating provides a means to eliminate solvent emissions and save money by applying a 100 percent solid powder rather than a solvent dispersed resin. Similar pans to those painted by Capsule are powder coated at other companies. For this reason. powder coating is seen as a technically feasible option. The feasibility of waterborne coatings can also be investigated. More efficient application equipment can reduce the overspray thus reducing the amount of paint used and associated paint wastes. Electrostatic spray guns and high volume low pressure (HVW) guns are both good options for this particular application

16 Paint wastes can be reduced by using alternate filters in the spray booths, increasing the loading of paint on the filters before they are spent. This increases the time between filter changes and results in a reduction in the generation of wastes. Plating Capsule s Wastewater treatment of plating rinsewaters currently produces 32,000 pounds of sludge annually. Implementation of a metals recovery process could reduce the generation of sludge by as much as 75 percent. Recovery of metals from the plating rinsewaters requires potentially expensive equipment. Options include ion exchange, reverse osmosis, electrolyxic recovery, and process modifications such as dragout reduction techniques. Another series of options may allow the waste generated to be no longer considered a hazardous waste. Low and no-chrome seal coatings may be able to replace the existing chromate coating. These coatings would reduce or eliminate chrome in the wastewater sludge, rendering it nonhazardous

17 TECHNOLOGICAL AND ECO NOMIC FEASIBILIlY Machining Evaluation: Two options are outlined above. Under consideration are a pasteurization unit and a filtration unit. 80th systems are easy to operate and maintain and have been widely used in industry. In removing the tramp oil and continuously recircularing the fluid, the filtration unit accomplishes the same task as the pasteurization unit. The bacterial concentration is reduced by removing its food (tramp oil), aerating the fluid thus killing the anaerobic bacteria, and adding biocide during chemical maintenance. The pasteurization unit also claims to reduce the bacterial concentration, bur still leaves colonies to grow in the Somewhat stagnant solution. Option One has higher capital costs and operating costs than Option Two. The payback period for Option One is 6.3 years and for Option Two is 3.0 years. An economic analysis is included in Appendix 8. Selected Measure: Option Two, the filtration unit, was selected for the fluid management program in the machining area. It is a proven technology at reasonable cost. Rejected Measure: Opfion One, the pasteurization unit,-was rejected for the fluid managemenr program. -The costs were significantly higher than for Option One with no significant added efficiency.. Cleaninq Evaluation: The first option is upgrading or replacing the degreaser to continue with solvent cieaning. The second option is to design and instail an aqueous cleaning system. 1 The first option has proven its cleaning ability in the plant for over 20 years; however, the regulatory environment has changed significantly. Considering the ongoing tightening of regulations, it is not feasible to continue to operate a solvent emitting system. The costs of solvent and solvent disposal in the future are not. known. but they most certainly will rise. The second option has been shown through testing to meet cleaning requirements. The system which was investigated is a conveyorized spray system using an alkaline cleaner. It is followed by two rinses, the second using deionized water with a rust inhibitor. Cleaner wastes will be processed through the existing ultrafiltration system to reduce oil and BOD loading in the wastewater. An

18 economic analysis compares this system to the current system, using waste disposal costs for The anticipated payback period is 4.8 years (See Appendix 8). Selected Measure: The second option, aqueous cleaning, was selected for the cleaning operation. Its major advantage is that it eliminates the use of solvents. It cleans well and has a good payback period. Rejected Measure: The first option, upgrading or replacing the vapor degfeaser was rejected. Although it cleans well, there are other economically feasible options which clean equally well without the hazards of solvents. Paintinq Evaluation: The options being considered are the use of water-based coatings or powder coating, along with improved application equipment. The safety hazards and emitting potential of the water-based and powder coatings are much lower than with the current solvent-based paints. Some concerns of water-based paints are transfer efficiency and texture consistency. The problems can be reduced. but not eliminated by using better application methods. The economic analysis for a water-based coating using HVLP guns gives a payback of.4.3 years: -. Y'-- Transfer efficiencies for powder coating with an electrostatic spray gun are very good because the overspray can be collecred and reused; The texture is also improved over the liquid spray painting applications. The payback period for the second system is 3.8 years (See Appendix El. Selected Measure: Powder coating using electrostatic spray equipment appears to be the best option. It provides a good finish and minimizes waste and economic losses because it is able to be reused. Thus, this is also an economically feasible option. Rejected Measure: The use of water-based coatings was rejected due to low transfer efficiency compared to powder coating and inconsistent texture. Platinq Evaluation: Options for waste reduction in the plating area include ion exchange, reverse osmosis, electrolytic recovery, and process modifications. Recovev technologies concentrate the metal ions, allowing for easier metals recovery through electrolytic recovery or same other process. In general, these processes

19 , have significant capital requirements relative to other chemical modification options. The option with most promise appears to be the use of no or low-chrome seals to eliminate or significantly reduce the hazardous constituent from the plating sludge, thus making it nonhazardous. Selected Measure: Capsule will evaluate. and if acceprabie. implement the use of no and low-chrome seals to replace the present chromate coating. This process change has no capital cost and will eliminare the hazardous constituent from this wastestream. Rejected Measures: Plating rinsewater and metal recovery systems were rejected due to cost. These options may be reevaluated in a future plan to reduce water use and discharges and to minimize the generation of the nonhazardous sludge

20 GOALS AND OBJECTIVES, The goal of Capsule Equipment Company is to reduce hazardous waste generation by 75 percent within 3 years and 90 percent within 5 years. Capsule also expects to eliminate SARA Form R reporrable emissions by The base line year is Changes in production from the base line year will be taken into account when evaluating progress towards these goal. Hours of direct labor will be used to relate production growth to waste generation. In 1990, there were 340,000 direct manufacturing labor hours. Capsule's objective is to accomplish its goal through material substitution, process modification. recyciing and reuse, as well as by involving employees in the program. Employee involvement includes enlisting the support of existing quality circfes and periodic updates on the status of environmental activities in the facility newsletter

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23 APPENDIX A BLOCK FLOW DIAGRAMS

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25 BLOCK FLOW DIAGRAM Raw Materials Carbon Steel Stock Sheet Metal Water Soluble Coolants Cutting Oils - FA I3 R I CAT IN G AREA Final Products Sheet Metal Cabinets Carbon Steel Components Cleaning Chemicals Waste Streams Miscellaneous Floor Cleaner Oil Absorbent Socks Air Emissions Spent Coolant Spent Cuttino Oil Spent Alkaline Cleaner Spent Trichloroethane Wastewater

26 BLOCK FLOW DIAGRAM Raw Materials Sheet Metal Cabinets Palnt Solvent fl PA I NT I N G AREA /r Final Products Painted Sheet Metal Cabinets Miscellaneous Booth Air Filters J 1/ Waste Streams Air Emissions Spent Air Filters Waste Solvent Waste Paint Booth Filters

27 BLOCK FLOW DIAGRAM Raw Materials Alkaline Zinc Plating Chemicals Chromate Chemical Carbon Steal Press Parts Rinsewatar,i. AREA Final Products Zinc Plated Carbon Steel Cabinet Hardware Components Cleaning Chemicals Alkeline Cleanei Acid Activator Miscellaneous Fabricatin0 Wastewater.. Waste Streams Spent Platina Bath Rinse and Fabricating Wastewater Spent Alkaline Cleaner Spent Acid. r'

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29 I APPENDIX 8 ECONOMIC ANALYSES,

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31 MACHINING Equipment Cost Recyc!ing Equipment Sump Cleaner Mechanical/Piping Installation and Materials Electrical Installation and Materials Total installed cost Ootion One $32,000 10,000 a, ooo 2.ooo $5 2,000 Ootion Two $ 1 7,000 10,000 8,000 * 2.ooo $ Labor Raw Materials Maintenance Replacement Parts Utility Cost Total Annual Operating Cost Savings Material Handling Raw Material Waste Disposal $30, ,000 6,000 1,200 AQQQ $ $11,500 26, $30,500 11,000 6,000 1,200 - $ $11,500 26, Total Annual Savings $ $61,000 Economic Payback Installed Equipment Cost + (Savings - Operating Cost) $ ($6 1,000-52,7OO~ = 6.3 years $ (561, OOJ 3.0 years

32 CLEANING Equipment COSTS Deionizer $ 3,000 Cleaning Tank 16,000 Rinse Tanks MecbanicallPiping 1,000 - Installation and Materials Electrical Installation and Materials -239Q Total Installed Cost Labor Raw Materials Maintenance Replacement Pans Utility Cost $30,500 5,000 4, ,100 Total Annual Operating Cost $ ~... Savings Material Handling Raw Material Waste Disposal $22, Total Annual Savings $ Economic Payback Installed Equipment Cost +(Savings - Operating Cost) = $28,700 ($53,500-47,500) = 4.8 years

33 *.- PA INTI NG Equipment Casts Paint 800th Cure Oven Parr Rack Fiiters Installation Electrical Powder/E?ectrosratic $130,000 34,000 1, , WaterborneIHVLP Use Exisring 3,000 4,000 1,60Q Total Installed Cast $ $ 8,600 Operating Costs Paint Maintenance Replacement Parts Utility Labor.~ $ 9,500 3,000 1,000 8, Q $ 43,000 4,500 1,000 28,000 LzL5QQ Total Anflual Operating Costs $ 81,500 $ Savings Material Handling Raw Material Waste Disposal Economic Payback $ 11, , $ Installed Equipment Cost + (Savings - Operating Cost) = $ 35,500 72,000 3,ooo $1 11.ooo $1 75,200 $8.000 ($128,000-87,500) ($1 19, ,000) 5: 3.8 yeais = 4.3 years