Hazardous waste management methods that are affordable and. relatively simple to implement are often overlooked as

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1 PRACTICAL METHODS FOR HAURWUS WASTE IIANACEMENT IN TYPICAL Sue Sullivan, MPH McLaren Environmental Engineering 2855 S. Pullman Street Santa Ana, California (714) ABSTIUCT Hazardous waste management methods that are affordable and relatively simple to implement are often overlooked as environmental managers aearch for process modifications or chemical substitutions. Process modifications often require capital funding and lengthy schedules for implementation, while chemical substitutions often require extensive research and testing. Methods such as eliminating the application of resin with brushes (which trap excessive waste in their bristles) and substituting spatulas (which can be scraped back into the product can) can be employed while a study is conducted to find suitable replacements for the resins. The procurement of chemicals from vendors who will allow the return of left-over product or deliver bulk shipments in phases, based upon production need, will reduce waste created by shelf-life expiration or weather damage. As long-term waste minimization solutions are sought, immediate waste reduction can be achieved through practical

2 PRACTICAL WETHODS FOR HAZARDOUS WASTE WNAGMENT IN TYPICAL Sue Sullivan, W H administrative or engineering controls. This paper discusses several methods that can be successfully implemented at military, aerospace, automotive, and petrochemical facilities as well as in most typical industrial settings. INTRODUCTION Industrial facilities produce a wide variety of hazardous waste streams as by-products of production and productionsupport activities. Hazardous waste produced by industry are categorized as liquids, sludges, and solids as well as some unidentifiable waste type^"^'^. These categories can be broken down further into several common waste types (see Table 1) that can be managed using practical administrative or engineering controls. Administrative controls are policy or procedural measures that result in lower quantities of hazardous waste (source reduction) in the use, reuse, or reclamation of hazardous materials (recycling) or in rendering chemicals non-hazardous

3 PRACTICAL METHODS FOR HAZARWUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan, MPH through physical or chemical change (treatment). 2 *5,6 Engineering controls are the implementation of technology or changes in stock materials to achieve source reduction, recycling or treatment. An example of an administrative control is the decision to cover all paint cans after each use to avoid the curing or coagulation of usable product resulting in the production of hazardous waste. Examples of engineering controls are the substitution of a water soluble paint for an oil-based paint and the installation of an in-line distillation unit to recycle degreasing solvents at the source.

4 PRACTICAL METHODS FOR HAZARDOUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan, MPH TABLE 1 COMMONLY PRODUCED HAZARDOUS WASTE STREAMS Liquids Oils Fuels Metal containing liquids Halogenated organics Non-halogenated organics Corrosives Pesticides - Paints Sludges Pigment containing sludges Oily sludges Metal containing sludges - Miscellaneous organic and inorganic sludges Solids Contaminated drums and containers Halogenated and non-halogenated organic solids Contaminated soil - Contaminated building/construction materials 1. California Department of Health Services, Toxic Substances Control Division, Technical Reference Manual of the Guidelines for the Preparation of Hazardous Waste Management, June 30, Noll, K.E., et. el., Recovery, Recycle, and Reuse of Hazardous Waste.

5 PRACTICAL METHODS FOR HAZARDOUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan, W H MANAGING WARDOUS WASTE THROUGH ADMINISTRATIVE CONTROLS Administrative controls can be implemented during the following phases of the waste production cycle; - Procurement, - In-house Operations, and - Waste Management. procurement practices contribute to the production of hazardous waste when excessive quantities or varieties of stock feed chemicals are brought into a facility. The consolidation of chemicals that perform the same function and the vendors that supply the chemicals is useful in reducing the influx of chemicals which fuel the production of hazardous waste. For example, one or two solvents could be purchased for use in both manufacturing and maintenance activities from a single vendor. Contractural arrangements should be made to allow for the phasing of deliveries based upon production needs and for the return of both unused product and empty containers.

6 PRACTICAL METHODS FOR HAZARDOUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan, MPH In-house oderations such as the storage, distribution and use of hazardous chemicals can be controlled to improve waste management efforts. Stock chemicals which are improperly stored are often damaged by excessive heat or cold or exposure to rain or snow. Proper stock rotation and timely return or sale of excess stock can avoid waste production due to expired shelf-life. In the event chemicals do have an expired shelf life, they can be used for non-specified processes. For example, paint can be used to coat storage containers, transportation equipment, and the facility in general. Another example of re-use is the use of contaminated solvents to wipe machines, rinse trenches, drip pans, and other non-production items where complete cleaning or degreasing is not necessary. Useful methods to control the production of hazardous waste efficiency are as follows: - Use only the minimum amount of working chemicals necessary to do the job, If, for example, resins are mixed in gallon cans and product is consistantly

7 PRACTICAL JfETHODS FOR HAZARDOUS WASTE HANAGWENT IN TYPICAL Sue Sullivan. W H leftover. switch to pint cans or to smaller containers until only the amount of resin that will be used in a particular operation can be mixed. - Control the movement of hazardous chemicals by placing identifying marks on containers indicating the person or department responsible for the chemical. This is best done by stock room personnel, at the time of stock distribution. However, individuals who are familiar with chemical usage in production can place markings on containers after the containers have been placed in their respective departments. Identifying marks on chemical containers will allow for the tracking of the type and quantity of waste production by individual departments and for the identification of drum contents in the event the label is missing or illegible. - Control unauthorized dumping by placing the keys for all forklifts into the hands of lead personnel who are responsible for tracking the forklifts and their users.

8 PRACTICAL KETHODS FOR HAZARDOUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan. MPH The use of a clipboard showing the date and time a forklift key is checked out and the user s signature is most effective in reducing the unauthorized movement or disposal of hazardous waste. - Manage large volumes of separable liquid waste streams, such as water wash paint booth waste, by allowing the solids to settle and removing the upper liquid portion. The solids can then be removed for disposal or treatment and the liquid portion can be placed back into the system and reused. The addition of commercially available flocculants can enhance the settling of solids. - Eliminate the rinsing of tanks, drums and other containers with water if they are used repeatedly for the same or similar materials. Other areas where rinsing can be eliminated is in the cleaning of floors (which should be swept or mopped), and in the rinsing of parts or equipment (which could be dipped into reusable water instead of hosed or sprayed).

9 PRACTICAL MJZTHODS FOR HAZARDOUS WASTE HANAGEMENT IN TYPICAL Sue Sullivan, MPH - Reduce the transfer of batch tank chemicals from production parts into rinse tanks (commonly referred to as "drag-out") by allowing the chemicals which are clinging to the parts sufficient time to drain back into batch tanks. - Reduce the amount of lab-packing (the placement of several small containers into drums for subsequent landfilling), by pouring like chemicals into larger containers for transfer to treatment or recycling facilities. Also, controlling the number or size of samples that are brought into a facility will significantly cut down on the amount of lab-packed waste. - Eliminate rinsing of paint guns and equipment with solvent into water wash spray paint booths. Train line operators to dip or rinse painting equipment into containers filled with solvent that is re-used and is eventually sent for recycling. - Train line operators to shut down as many waste producing operations as possible during breaks and between shifts.

10 PRACTICAL METHODS FOR HAZARDOUS WASTE WAGEHENT IN TYPICAL Sue Sullivan, HPH - Implement batch makeup schedules based upon quality rather than time. For instance, batch tanks in a metal finishing line that are recharged every week, should be tested for specific chemical concentrations and recharged when their performance falls below specified quality parameters. Waste Manaeement methods that fall under the classification of administrative controls, are effective in managing hazardous waste on-site as well as waste that is sent off- site for disposition. Diversion of hazardous waste from landfills for recycling and treatment is made simpler if waste segregation and proper container labeling are practiced. Materials, such as off-specification oils or paints can be taken out of the waste classification and used for maintenance or other support activities by the original generator or by other industries. An internal manifest system will make the tracking of the type and quantity of hazardous waste easier.

11 PRACTICAL llethods FOR HAZARDOUS WASTE HANAGWENT IN TYPICAL Sue Sullivan, MPH MANAGING HAZARDOUS WASTE THROUGH ENGINEERING CONTROLS In most cases, engineering controls require capitol funding and are designed for specific waste streams. However, situations exist, such as the installation of a simple float system to avoid overfilling vessels with hazardous materials, where a minimal amount of time and money are required. The following are examples of engineering controls that have been used successfully at industrial facilities for: - metal-containing sludges, - degreasing operations, and - metal finishing operations. Hetal-containine sl udeeq are usually processed through a filter press to remove their liquid component. The sludges are subsequently sent to landfills or to treatment or reclaimation facilities depending on their constituents. Often, the excessive water in sludges can be eliminated by pressing for longer periods of time. In this situation, an engineering control would be to modify or install new timers

12 PRACTICAL METHODS FOR HAZARDOUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan, HPH on the press to enable it to operate to its full potential during off-hours or to install additional filter press capacity. penreasine OD erations produce used solvent with varying levels of contamination. Lightly contaminated solvents can be used for equipment cleaning or other maintenance activities while heavily contaminated solvents can be recycled with an in-line distillation unit. Beta1 finishing operations produce liquid hazardous waste which can be controlled with the use of continuous countercurrent leaching (also called countercurrent rinsing) where a batch tank is combined with two to three rinse tanks. The rinse tank furthest away from the batch tank is the inlet for fresh water and the rinse tanks are drained into each other toward the direction of the batch tank while the parts are routed through the rinse tanks away from the batch tank. Thus, the term countercurrent rinsing. The purpose of this technique is to concentrate the chemicals into the rinse tank closest to the batch tank and to introduce the most saturated parts into the more concentrated rinse and the partially cleaned parts into the fresher rinse.

13 PRACTICAL nethods FOR HAZARDOUS WASTE MANAGEMENT IN TYPICAL Sue Sullivan, llph The concentrated rinse tank can then be combined with stock chemical in recharging the batch tank or treated more efficiently than the more dilute second and third rinse tanks. 8UXUAB.Y This paper discusses just a few of the many practical methods for managing hazardous waste. Administrative and engineering controls that are used in conjunction are most effective in overall hazardous waste management. However, administrative controls can usually be implemented quickly with significant waste minimization results, while engineering controls are tested and funded.

14 PRACTICAL METHODS FOR HAZARDOUS WASTE MANAGEMENT IN TYPCIAL INDUSTRIAL. SETTINGS Sue Sullivan, MPH BIBLIOGRAPHY 1. California Department of Health Services, Toxic Substances Control Division, Technical Reference Manual of the Guidelines for the Preparation of Hazardous Waste Management Plans, June 30, From, Carl H., et. al., "Overview of Waste Minimization Issues, Approaches and Techniques", Presented at the Conference on "Performance and Costs of Alternatives to Hazardous Waste", Air Pollution Control Association, New Orleans, Louisiana, December 10-12, Noll, K.E., et. al., "Recovery, Recycle, and Reuse of Hazardous Waste", Hazardous Waste Management, Volume 36, No. 10, October, "National Survey of Hazardous Waste Generators and Treatment, Storage, and Disposal Facilities Regulated under RCRA in 1981," U.S. EPA, EPA 530/SW , "Report to Congress, Minimization of Hazardous Waste," U.S. EPA, Office of Solid Waste and Emergency Response, EPA 532-SW , Washington D.C., U.S. Government Printing Office, October, 1986.

15 PRACTICAL IfETHODS FOR HAZARDOUS WASTE MANAGWENT IN TYPICAL Sue Sullivan. NPH 6. Resource Conservation and Recovery Act, Subtitle A, Section 1004 (34), PL Warren McCabc, et. al.. ynit beration s of Che mica1 Eneinr+rine, Third Edition, McGraw-Hill Chemical Engineering Services, McGraw-Hill, Inc., pages