Large Quantity to Small Quantity Generator

Transcription

1 Karen Goryl Sr. Environmental Engineer Detroit Diesel Corporation -, NA AHMP National Conference - Austin Texas August 30, :00PM Large Quantity to Small Quantity Generator Through the extraordinary efforts of the environmental team and with the assistance from the operational departments in the past 5 years, we have managed to transform this facility from a large quantity generator of hazardous waste to a small quantity generator. The viewpoint before the start of this project was that it would be nearly impossible to convert this large and complex manufacturing plant into a small quantity generator of hazardous waste! Kenneth Saari, Director of Core Facilities (March 15, 2009) Detroit Diesel Redford 2 Project: In 2005 Detroit Diesel Corporation (DDC) set a goal to minimize hazardous waste generated at the facility and to achieve Small Quantity Generator Status by Background Information DDC History Large Quantity Generator: Where we Were Small Quantity Generator: Where to Start Process Changes Actions Challenges Accomplishments Trend Charts Additional Benefits 2

2 DDC: Designs, tests, manufactures, distributes and services heavy and medium-duty diesel engines for road and non-road applications Located on the border line of the City of Detroit and Redford Township, Michigan 131 acres of environmentally impacted property 3.1 million ft 2 facility 2.9 million ft 2 in production space Detroit Diesel s History For the past 73 years this manufacturing facility has been owned and operated by: General Motors ( ) Penske Corporation ( ) DaimlerChrysler ( ) North America (2007 to present) 3 During the past 6 years DDC has Revitalized and transformed into a sustainable modern Manufacturing Mall Renovated the building to maximize space and improve function Installed the next generation heavy/medium duty diesel engine production and machining lines Increase employees from 1,800 to 2,500 Added 5 new business tenants MTU-Detroit Diesel Axle Alliance Corporation Purem Mercedes Benz Research & Development North America Daimler Truck North America Consolidation Center Detroit Diesel s History With the addition of the new processes, increases in production and new tenants DDC reduced hazardous waste an average of 24% a year since US EPA definition of a Large Quantity Generator (LQG): a facility that generates more than 1000 kg of hazardous waste in a calendar month. DDC generated: Large Quantity Generator (Where We Were) 33 tons of hazardous waste in 2001 (averaging 2,750 kg/month) Classified as a Large Quantity Generator (LQG) of hazardous waste Generated Waste Streams: 77% hazardous paint wastes 13% hazardous lab solvent wastes 10% hazardous cleaning solvents 4

3 Small Quantity Generator (How is this done?) US EPA definition of a Small Quantity Generator (SQG): a facility that generates less than 1000 kg of hazardous waste in a calendar month. Where to Start? 1 st review waste generation practices on the plant floor Who generates waste? What types of waste are generated? When is waste generated? Where is waste collected? How is waste managed during & after collection? 2 nd implement process changes to improve waste generation practices by: Segregating hazardous and non-hazardous waste streams Providing training and standardize work practices 3 rd change the way chemicals are approved for use Improve the chemical approval process Introduce more green chemical usage where practical 4 th develop other chemical management strategies 5 Challenges: DDC & tenant production used many hazardous and non-hazardous chemicals which generated multiple waste streams Waste streams were mixed at point of generation, making most waste hazardous The workforce was comfortable with this practice Action Steps: Train personnel to identify and segregate non-hazardous from hazardous wastes on all processes Develop waste management work instructions and hold the departments accountable for all wastes generated Standardize waste collection areas and provide visual aids Accomplishments: Improve Waste Segregation Process 30% reduction in hazardous waste disposal from 15 to 10 tons/yr (05 vs. 06) 6 Improve Chemical Approval Process Challenges: Hazardous chemicals were routinely approved with few restrictions Chemicals were purchased without proper approvals Action Steps: Re-evaluate the chemical approval process: Restrict toxic chemicals from entering the facility Require a review & approval from environmental engineering department Before purchase a chemical tracking number must be acquired Reduce the total number of chemicals approved in the system Encourage the use of non-hazardous chemical substitutions Accomplishments: Toxic chemical usage and restriction list employed Reduced the approved chemical list from 3,700 down to1,485 (60%) in 3 yrs More green chemicals approved for use Improved the environmental, health, and safety of our employees 8

4 Challenges: Paints stored on-site in large quantities and automatically re-ordered Paints were routinely consumed by a Last-In-First-Out (LIFO) process Reduce residual paint waste purchased for bulk discount Action Steps: Instituted a First-In-First-Out (FIFO) system for paint inventory to reduce the amount of out-of-date paints Instituted a Just-In-Time (JIT) paint delivery process to minimize total paint inventory Change paint container size from 5 gallons to 1 gallon to eliminate residuals Accomplishments: Improve Paint Inventory Management Process Implementation of FIFO in 2007 resulted in a 50% reduction in obsolete paint Container size changed to 1 gallon Implementation the JIT process in 2008 reduced paint storage by 50% Reduced paint waste disposal 53% from 7 tons (2006) to 3.5 tons (2008) Conserved raw materials and saving ~$40,000 in out-of-date paint disposal 7 Challenges: Remove methyl-ethyl-ketone (MEK) from water-based engine paints Removal of MEK could impact the quality of the engine paint s durability Acquiring accurate chemical composition from paint suppliers Action Steps: Involved production, quality and the paint suppliers to remove MEK from the water-based engine paints Required the paint suppliers to provide certification of MEK free water-based engine paints Accomplishments: 2008 the MEK free paint met paint durability requirements & was approved 80% reduction in hazardous paint waste from 3 tons (2008) to 0.6 tons (2010) Reduced the toxicity and fire hazards from the water-based engine paints Enhanced our air permit & SARA reporting information Reduce Hazardous Paint 9 Small Quantity Generator (What was achieved) By minimizing the amount of hazardous waste generated, DDC became a Small Quantity Generator in Achievements In 2008 our total hazardous waste disposal was 7 tons By 2010 process improvements reduced our hazardous waste disposal to 2 tons/yr During this time frame Production levels increased 70% in 2008 from 2007 Dropped 20% in 2009 Recovered 30% in 2010 Currently in 2011 with the addition of a second shift we are on track to generated no more than 1.5 tons of hazardous waste 5

5 Overall Accomplishments of the Program These changes resulted in the following improvements: A 94% reduction of hazardous waste plant wide since 2001 A 96% reduction in paint related waste since 2003 A 96% reduction in hazardous waste disposal costs from 2001 Saving $50,000/year Changed classification to a Small Quantity Generator in 2008 Saving $42,500/year in compliance related costs Total annual savings of $92,500 Significantly reducing environmental risks and liabilities Minimizing hazardous chemical exposure to the workforce 10 SQG Status Demonstration Small Quantity Generator Status maintained since Lbs / Month Monthly Hazardous Waste Disposal Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Hazardous Waste Disposal / Production Volumes Demonstration Hazardous Waste Disposal per Production Units Tons / yr , , , , ,000 75,000 50,000 25,000 0 Production Units / yr New Heavy Duty Engine EPA Mandates Hazardous Waste Production Hazardous waste reduction of 94% from 2001 to 2010 (bar graph) Production Units: (line graph) Engine Production Axle Production Gear Sets Production Filter Unit Production Market Crash 2009 DDC & Tenant Production Increases

6 Correlation Between Hazardous Waste & Hazardous Paint Waste 25.0 Total Hazardous Waste Generated Annually Total Hazardous Waste Paint Generated Annually 20.0 Tons per Year Cost Savings Achieved through Hazardous Waste Reductions $180,000 $160,000 $140,000 $120,000 $100,000 $80,000 $60,000 $40,000 $20,000 $- Annual Hazardous Waste Costs SQG Achieved (includes required RCRA Training if LQG) 14 Additional Benefits from our Program Statewide recognitions: Michigan Department of Environmental Quality Clean Corporate Citizen Michigan Business Pollution Prevention Partner 2011 Michigan Green Leader 15

7 Michigan s Clean Corporate Citizen Certificate Reflects our efforts in hazardous waste reduction, pollution prevention & community outreach 16 Michigan s Business Pollution Prevention Partnership Certificate Demonstrating our continuing efforts on pollution prevention Michigan Green Leader Award Honoring individuals, businesses and organizations moving the state forward in innovation, job creation, sustainable development, community advocacy, conservation and more. DDC s commitment to the environment starts with: 11 employee-based recycling programs Reducing landfill waste by more than 54% & overall trash by 30% in one year Internal conservation efforts at DDC s state-of-theart manufacturing facility have resulted in: 17% improvement in energy efficiency since 2009 saving more than $3 million since

8 Environmental Policy & ISO Certification 19 Thank You 22