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Hazardous Waste Minimization Checklist & Assessment Manual for Paint Formulators

CALIFORNIA DEPARTMENT OF TOXIC SUBSTANCES CONTROL

OFFICE OF POLLUTION PREVENTION AND TECHNOLOGY DEVELOPMENT

TECHNOLOGY CLEARINGHOUSE UNIT

ACKNOWLEDGEMENTS

This document was prepared by Kathryn Barwick, under the direction of James T. Allen, Ph.D., Kim Wilhelm, P.E., and Dave Hartley, M.P.H., of the California Department of Health Services, Toxic Substances Control Program, Alternative Technology Division, Technology Clearinghouse Unit. Daniel Q. Garza and Robert Ludwig provided critical comment and review. The Department wishes to express appreciation to Michael Callahan of Jacobs Engineering Group, Inc. for preparation of the “Waste Audit Study for the Paint Formulating Industry”. Designed by Merle Rae Hopkins, Bruce Clarke and Nancy S. Ostrom.

DISCLAIMER

The mention of commercial products, commercial services, their sources or their use in connection with material reported herein is not to be construed as actual or implied endorse- ment of such products or services.

WE’VE CHANGED.. . On July 17, 1991, the California Environmental Protection Agency officially came into existence and the Toxic Substances Control Program became the Department of Toxic Substances Control under that Agency. The Toxics Program is no longer affiliated with the Department of Health Services or the Health and Welfare Agency. The wording within this particular document has not been changed to indicate this new affiliation. The new mailing address follows:

Department of Toxic Substances Control Office of Pollution Prevention and Technology Development

400 P Street, 4th Floor P.O. Box 806

Sacramento, CA 95812-0806 (916) 322-3670

TABLE OF CONTENTS

INTRODUCTION

SECTION 1 : PAINT FORMULATING CHECKLIST

INTRODUCTION TO WASTE MINIMIZATION

PRINCIPLES OF WASTE MINIMIZATION ASSESSING YOUR WASTE MINIMIZATION OPPORTUNITIES WASTE MINIMIZATION OPTIONS MANAGEMENT PRACTICES PLANT OPERATIONS MANAGEMENT RAW MATERIALS STORAGE AND HANDLING Drums, Containers, and Packages Spills

MATERIAL SUBSTITUTION AND PRODUCT REFORMUL T I 0

/ / / / / I / /

FURTHER INFORMATION 39

PROCESS OPERATIONS Primary Dispersion Let-Down Tanks Filltering and Filling Tunk/Container Cleaning

RECYCLING Increase Rec yclability Onsite Recycling Offsite Recycling

HAZARDOUS WASTE STORAGE AND HANDLING

SECTION 2: EVALUATION OF WASTE MINIMIZATION OPTIONS

SECTION 3: PROFITABILITY WORKSHEET

APPENDIX A: TABLES OF WASTE MINIMIZATION OPPORTUNITIES

ADDITIONAL PUBLICATIONS

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TABLES

Table I :

Table 2:

Table 3:

Table 4;

Table A I :

Table A2:

Table A3:

Table A4:

Table A5:

Table A6:

Table A7:

Table A8:

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The Waste Minimization Assessment Procedure 3

How Do You Store Your Raw Materials and Hazardous Wastes? 8 -

Waste Minimization Option Evaluation

Annual Operating Cost Savings

Summary of Management Practices and Plant Operations Management Waste Minimization Opportunities

Summary of Raw Materials Storage and Handling Waste Minimization Opportunities

Summary Containers and Spill Prevention Waste Minimization Opportunities

Summary of Material Substitution and Product Reformulation Waste Minimization Opportunities

Summary of Process Operations and Filtering Waste Minimization Opportunities

Summary of Tank and Container Cleaning Waste Minimization Opportunities

Summary of Recycling and Resource Recovery Waste Minimization Opportunities

Summary of Hazardous Waste Storage and Handling Waste Minimization Opportunities

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I NTRO D U CTI 0 N Waste minimization consists of source reduction and recycling, the first two elements of the preferred waste management hierarchy, which consists of source reduction, recycling, treatment, and residuals disposal. Tackling waste management problems using the hierarchy can help save you money, by reducing the amount of hazardous wastes you have to manage. Waste minimization can involve simple and easily implemented strategies, or complex, state-of-the-art technologies. The extent to which you implement a hazardous waste minimization program wholly depends upon your plant’s or shops particular operations and procedures.

Waste minimization can help you achieve compliance with regulatory requirements by reducing the waste generated. In some instances it might even allow small quantity generators to drop out of the regulatory loop altogether. Waste minimization may also be able to reduce the fines or fees assessed by publicly owned treatment works (POTWs) by reducing your loads on their pretreatment systems.

This assessment manual was developed by the Technology Clearinghouse of the Alternative Technology Division to aid paint formulators in evaluating their shops for waste minimization opportunities. The manual contains three sections. Section 1 is a checklist to help you in evaluating your shop for waste minimization opportunities. Section 2 is comprised of tables listing the waste minimization options from the checklist and four areas for evaluation:

Waste Minimization Hierarchy (WMH) Implementation Potential (IP)

Type of Option Cost of Option

Each of these areas have different point values, which will be explained in Section 2. The total scores of the options will allow you to prioritize the options. Section 3 is a economics worksheet to help you decide which options are cost effective for implementation.

SECTION 1: PAINT FORMULATING CHECKLIST Paint formulators generate a variety of hazardous wastes in their operations. Tank cleaning is the principal source of waste generation. Common waste types include:

solvents, used as carriers for resins and pigments and to clean production process equipment. Solvent distillation residues can contain solvents and, sometimes, toxic metals such as mercury, lead and chromium.

obsolete stock spills

customer returns spent filter bags

off-specification products empty bags and packages

In general, a waste is hazardous if it is toxic, corrosive, ignitable or reactive. The criteria for determining these hazardous properties are complex. You can find the criteria in the California Code of Regulations (CCR) (Article 9 and Article 11 in Chapter 30, Title 22).

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There is an address in the Appendix if you want to request a copy of the Code. According to these regulations, it is your (the generator’s) responsibility to use these criteria to find out if your wastes are hazardous. If you’re not sure if your wastes are hazardous or you need help understanding the criteria, call your local Department of Health Services (DHS) Regional Office or the DHS Alternative Technology Division (telephone numbers are listed in the Appendix).

INTRODUCTION TO WASTE MlNlMlZATlON

Waste minimization consists of waste management approaches that reduce the amount of hazardous waste generated or requiring disposal.

Waste minimization can reduce the amount of hazardous wastes generated in your shop. . This benefits you by minimizing:

disposal costs regulatory compliance costs (recordkeeping, reporting, tracking, etc.) costs of future liabilities current operating costs (i.e., raw material costs) transportation costs offsite treatment costs worker safety cost laboratory costs (for compliance with land disposal restrictions) fees and taxes insurance costs

These benefits can be realized by your firm by implementing the following waste minimization methods:

Source reduction: substituting input material, or changing production processes or waste handling methods to reduce the amount of waste generated.

Recycling: employing onsite or offsite techniques to remove or destroy contaminants from a waste stream so that the material can be reused.

To be successful, your waste minimization program must be organized. It is not hard to organize waste reduction, but you will need to spend a little bit of time at first to get started. Keep in mind the following principles of waste minimization:

PRINCIPLES OF WASTE MlNlMlZATlON

1. Plant owners and managers must be committed to waste minimization for it to work.

. 2. Your waste minimization program whould have specific goals and objectives.

3. You should know how your hazardous waste is managed and how much your present

4. Train all your employees in hazardous waste handling and your waste minimization

5. Be aware of the hazardous materials regulations that apply to you.

waste management costs.

methods.

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TABLE 1 : The Waste Minimization Assessment Procedure

The recognized need to minimize waste

Planning and Organization

Assessment Phase

Feasibility Analysis Phase

Implementation

Procedure Result

Get management commitment

Set overall assessment program goals

Organize assessment program task force

Collect process and facility data

Prioritize and select assessment targets

Select people for assessment teams

Review data and inspect site

Generate options

Screen and select options for further study

Technical evaluation

Economic evaluation

Select options for implementation

Justify projects and obtain

Installation (equipment)

Implementation (procedure)

Evaluate performance

funding

4ssessment xganization and :ommitment to xoceed

4ssessment report of selected options

Final report, including recommended options

Successfully implemented waste minimization projects

1 (Source: The EPA Manual for Waste Minimization Opportunity Assessments)

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ASSESSING YOUR WASTE MlNlMl2ATlON OPPORTUNITIES

This booklet will help you perform a waste minimization assessment. The objective of this assessment is to identify ways to reduce or eliminate waste, through a careful review of your operations and waste streams. After you select a specific area (or areas) to focus on in your waste minimization efforts, a number of options are developed and evaluated. Then, the technical and economic feasibility of the selected options are evaluated. Finally, you’ll choose the most promising waste minimization options for implementation.

When performing your waste minimization assessment, the answers to the following questions can help guide your efforts:

1.

2.

3.

4.

5. 6.

7.

8.

9.

What are the waste streams generated at your plant? What are the volumes generated?

Which processes or operations do these waste streams come from?

Which wastes are classified as hazardous and which are not? What makes them hazardous?

What are the input materials used that generate the waste streams of a particular process or plant area?

How much of a particular input material enters each waste stream?

How much of a raw material can be accounted for through fugitive losses?

How efficient is the process?

Are unnecessary wastes generated by mixing otherwise recyclable hazardous wastes with other process wastes?

What types of housekeeping practices are used to limit the quantity of wastes generated?

10. What types of process controls are used to improve process efficiency?

(Source: EPA Waste Minimization Assessment Manual)

WASTE MlNlMl2A TlON OPTIONS

Most waste minimization options available for paint formulators involve the following:

pigment substitution; proper batch scheduling; . dedication of process equipment; preventing obsolescence of raw materials; washing and drying filter bags prior to disposal; and reworking spilled materials and wastes into usable products. ..

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Complete the following waste minimization checklist to see if you are maximizing waste minimization techniques. The preferred answers are in bold print and helpful hints are in the right hand column.

MANAGEMENT PRACTICES 1. Does your facility have an established waste minimization program in place?

13 Yes 0 No

Is a specific person assigned to oversee the success of the program?

0 Yes No

Does the program have a set waste reduction goal?

Yes0 No

2. How frequently are overall material balances for the plant performed?

3. Are there employee educa- tion programs on how to avoid excessive waste generation?

0 Yes 0 No

How often are the training programs offered? Are there employee incentive programs regarding waste reduction?

0 Yes 0 No

Have you increased employee supervision?

0 Yes 0 No

4. Are you fully aware of the current local, State, and federal regulations related to hazardous material storage, treatment, disposal, and recycling?

0 Yes 0 No

J Waste minimization programs are more successful if they contain these elements.

J In order to accurately assess your waste reduction efforts, you must keep track of the raw materials entering and the products and wastes leaving your processes.

J You can reduce the amount of waste generated by spills if you train your employees to properly handle and store hazardous materials. Some trade associa- tions and local environmental health agencies sponsor employee training seminars and some consulting firms offer employee training as part of their package of services for hazardous waste management.

J Compliance with existing laws and regulations is essential to a good waste minimization program.

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Has your facility conducted an environmental audit to assess compliance with these regulations?

0 Yes 0 No

PLANT OPERATIONS MANAGEMENT

Plant operations management involves the proper scheduling of production to reduce the need for equipment cleaning, and dealing with management practices, such as employer/ employee relationships, that may have an influence on the amount of waste generated.

1. Do you attempt to vary the production schedule to de- crease waste production?

0 YesO No

2. Does the production schedule include light-to-dark color product sequencing?

0 YesO No

3. Is the batch formulation attempted in the lab before large scale production?

0 YesO No

If yes, how many times is the lab scale test repeated to ensure proper batch formulation?

J Plan your production schedule in a way that minimizes the need for intermediate storage and excessive cleaning. For example, in one shop, mills were usually cleaned with a compatible solvent, thereby generating a stream used in the let-down formulation. This was not done, however, if the pigments were dispersed for subsequent storage. In the latter case, MEK was used to clean the roll mill. By planning the production schedule in such a way that the pigments were dispersed only before a batch formulation (thus eliminating the need for intermediate storage), the generation of spent MEK wastes could be avoided. Alternatively, the mills could have been cleaned with a small amount of compatible solvent to be combined with the batch destined for intermediate storage.

J The need for equipment cleaning can be reduced if paints are produced in a sequence in which the residues from a previous batch do not affect the color quality of the next batch.

J Accurate lab scale tests can eliminate the production of off-specification product, which can end up being hazardous waste.

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RAW MATERIALS STORAGE AND HANDLING

Raw materials are the unused supplies of materials that you keep on hand. If you allow these supplies to become too old to be used, they may become hazardous wastes. Obsolete stock can be minimized by proper planning and inventory control.

1. Are all raw materials tested by the quality control department before being accepted from the suppliers?

0 YesO No

If no, what safeguards are employed to prevent the use of materials that may generate off -spec product?

J Off-specification raw materials, if accepted, can become hazardous waste. In addition, the use of these materials may generate an off-spec product, which then may require disposal as a hazardous waste. Some off-spec products can be reworked into usable products.

2. Is the inventory system computerized?

0 YesO No

If yes, what information does the system track?

J Installation of a computerized inventory system can improve raw material tracking and help identify and remedy raw material losses at an early stage. By using such a system, inventory can be checked more frequently, and overstocking can be reduced.

3. Does the layout of the facility require a heavy amount of traffic through the raw material storage area ?

0 YesO No

Can traffic through the storage area be reduced?

0 YesO No

4. Do you minimize your shop’s stock to keep supplies from becoming too old to be used?

0 Yes 0 No

J Heavy traffic increases the potential for contami- nating raw material with dirt or dust and for causing spilled materials to become dispersed throughout the facility.

J You can easily rotate and maintain your stock by labeling, dating and inspecting new material containers as they are received. Then, use the earliest labeled stock. Schedule a full scale inventory of your raw materials at least once a year.

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/ TABLE 2: How do you store your raw materials and hazardous wastes? Check the boxes that apply to your storage area@).

Hazardous Raw Storage Wastes Materials

Indoors

Outdoors

Comments

Some fire departments recom- mend storing flammable wastes outdoors to reduce fire danger, but remember to follow the other storage hints.

A covered storage area is important because rain water can increase your waste volumes or contaminate raw materials. Also, exposure to sunlight can change the characteristics of raw materials or dangerously raise the pressure inside sealed containers. You should also keep individual containers covered to prevent evaporation and spills.

A diked concrete pad will contain spills better than asphalt or dirt.

Storage of materials on dirt surfaces should always be avoided. In addition to potential ground contamination, moisture collecting under drums can lead to corrosion and failure of the drum. For facilities with limited space, combination pallet/containment systems are available.

Without secure storage facilities, some unscrupulous hazardous waste generators may deposit their wastes in your containers, increasing your disposal costs.

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5. Is it established policy to utilize raw materials on a first-in first-out basis?

0 YesO No

6. Is obsolete raw material returned to the supplier?

0 Yes 0 No

7. Do you maintain, and en- force, a clear policy of using raw materials only for their intended uses?

0 Yes 0 No

8. Are empty raw materials drums returned to the suppliers?

0 YesO No

If yes, are the drums washed before returning?

0 YesO No

Are the drums reused?

0 Yes 0 No

If yes, are they washed before reuse?

Yes 0 No

9. Is any effort toward using rinseable/recyclable drums attempted?

Cl Yes 0 No

Drums, Containers, and Packages

1. Do you fully inspect all drums, containers and packages before accepting them from the supplier?

0 YesO No

J Raw materials, if allowed to become too old to be used, may become hazardous wastes. Having a “first-in, first-out” inventory policy can prevent this from happening.

J Returning obsolete raw materials can prevent you from having to dispose of them as wastes.

J You may generate unnecessary hazardous waste if you use supplies for purposes other than their intended uses. For example, don’t use equipment cleaning solvents to clean your floors.

J Replacement of bagdpackages with rinseable/ recyclable drums can be addressed through inquiries with suppliers.

J Damaged packaging can lead to product contamination, which can cause off-specification products.

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2. Do you accept customer returns?

Yes0 No

If yes, do you have customer incentive programs to encour- age purchase in bulk form or in bigger containers?

Yes 0 No

J Bulk purchasing can reduce the total number of containers returned to your facility, which then require cleaning and/or disposal. Customers who purchase large volumes of paint in drums could be offered incentives to convert to bulk purchase. This will reduce the quantity of returned drums requiring cleaning.

3. Have you attempted to purchase pre-weighed materials in soluble bags?

0 Yes 0 No

J Mercury-based fungicides are available in pre- weighed soluble bags, which do not require disposal. But be aware that mercury in your waste stream can complicate treatment of the waste prior to disposal. Mercury fungicides should be avoided.

Spills

If you spill a raw material or hazardous waste and absorb it with sawdust (or some other absorbent), the sawdust becomes a hazardous waste and is subject to all of the hazardous waste regulations. Also, if your floors are heavily soiled when you wash them, then your wash water may become hazardous. Reduce this type of waste by handling all materials carefully to reduce spills.

1. Do you generate hazardous wastes due to spills during raw material storage or during equipment cleaning?

0 Y e s 0 No

J Spills are inadvertent discharges that occur at various places in the plant. Spills occur mainly because of splashing during manual transfer, tank overfilling and leaks in process equipment and

The spilled materials can then be reworked into product. Spills that cannot be scooped up should be cleaned with commercially available adsorbents. This “dry” cleaning method is discouraged, as the resulting waste is difficult or impossible to reprocess.

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piping. Scoop spills up to the fullest extent possible. I

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2. How frequently and for what reasons do spills occur in your plant?

3. Do you have any of the following safeguards to prevent the spillage of liquids while filling storage tanks?

high level shutdown alarms

0 flow totalizers

0 pipeline drainage or purging

0 dikes

before disconnect

How are the liquids in these tanks dispensed to the users (i.e., in small containers or hard piped)?

J Some spills will occur. Hang a clipboard in a handy spot and keep a record of larger spills (when they occur and why). Use this information to identify the spill prevention options that might help your shop. Many of these options are listed throughout the checklist. Remember, minimizing spills helps to reduce the amount of cleaning material you use, and reduces the amount of hazardous spent absorbent and used floorwash you generate.

J Prevent leaks via proper equipment maintenance. Increased training and closer supervision can prevent overfilling and spills during manual transfer.

J All of these can help you reduce the amount of waste you generate through spillage.

MATERIAL SUBSTITUTION AND PRODUCT REFORMULATION

1. Do any of your products contain hazardous materials (i.e., chlorinated solvents, lead or chrome pigments, mercury, etc.)?

0 Yes No

If yes, has material substitution been tried?

0 Yes0 No

J Substituting end products that do not contain hazardous materials for those that do, to the extent possible, can help reduce your overall generation of hazardous wastes. No-lead and no-chrome alternatives are commercially available and should be tested for customer acceptance.

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2. Has there been an increased market demand for high-solids or water-based paints?

Yes 0 No

J Be aware of market demands. If there is an increased demand for water-based or high solids paints, it may give you an opportunity to implement source reduction and increase your profits.

3. Have you considered using pigments in slurry or paste form?

0 Yes0 No

J Explore the availability of pigments in slurry form through vendor contacts. Such use could mean a reduction in waste bags and packages. The pigment slurry can be bought in drums or bulk form; drums can be returned to the vendor. Using pigments in slurry form rather than dry will also help reduce dust in your plant.

PROCESS OPERATIONS

Primary Dispersion

1. What is the most commonly used method of feeding raw materials to the mills and discharging dispersed materials from the mills?

0 manual,

0 gravity,

0 forced feed, from

0 small (5 gal.) containers,

0 portable mix tanks, or

0 large storage tanks.

2. What percentage of the dispersed material is sent to intermediate storage instead of being used immediately to produce paint?

How long do materials usually remain in intermediate storage before being utilized?

J Automated feeding systems can help reduce spillage. Switching from numerous small containers to one larger container can help reduce cleaning waste. For large scale dedicated equipment, clean- in-place systems are effective in reducing cleaning waste.

J Intermediate storage will require additional cleaning steps, thus generating unncecessary cleaning wastes.

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3. Indicate the percentage of material that must be passed through the mill:

- once,

- twice, - or more.

4. For materials passed through the mill more than once, are separate containers used for feeding and receiving?

0 Yes 0 No

5. Indicate the number or percentage of mills that are dedicated to the production of a single product: -.

6. How frequently are the mills cleaned?

7. Solvent cleaning of the mills is

used for solvent-based

0 used for all batches,

not used at all.

batches only,

8. Do you use the same kind of solvent for as many of your processes as possible?

Yes 0 No

J If multiple passes are necessary, try recirculating the mixture of pigments and solvent through the mill and returning them to the same container. This will eliminate one cleaning step. The disadvantage of this method is that fine, dispersed pigments are allowed to mix with undispersed pigments before going through the mill again. This may reduce the efficiency of the mill and require running the mill for a longer period of time. Excessive degradation of polymers (resins) can also be a problem with this recirculation scheme. The economics of increased power consumption should be weighed against the reduction in labor required for cleaning plus the reduced disposal costs.

J Reduce the number of containers used by con- tinuously recirulating the material through the mill instead of using multiple passes. Also, the purchase of a more efficient mill might eliminate the need for multiple passes.

J When multi-pass dispersion is used during the primary dispersion, try to eliminate container rinsing between passes. This can be done if the product contamination is not significant.

J Dedicating equipment to a single product elimi- nates the need for intermediate cleaning steps, thus reducing solvent waste generation.

J Clean mills only when necessary.

J Don’t use solvent cleaners to clean residues from water-based products.

J If you standardize the solvents used in your facility, your waste management costs can be reduced.

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9. The waste stream generated from mill cleaning is

0 drummed for disposal,

0 drummed for disposal after being reused - times,

0 drummed for use in a subsequent batch of paint,

added to the let-down tank as part of the current batch of paint, or

0 sent to a holding tank.

10. If you are planning any future plant modernizations, do you consider replacing existing mills with more efficient ones?

0 Yes 0 No

Lef-Down Tanks

1. The capacity of portable let- down tanks used in the facility ranges from -to - gallons. The stationary let-down tanks range in size from -to - gallons. - percent of the batches, or - percent of the product volume produced in the facility, is made in portable tanks.

2. Indicate the most commonly used method of discharging paint from the portable let- down and stationary let-down tanks:

0 manual,

0 gravity,or

0 forced discharge into-

another portable tank, or

0 directly into the filtering and

small (e.g., 5 gal.) containers,

filling system.

J Maximize your use of the solvents you do use. Reusing solvents as much as is practicable can significantly reduce your total solvent waste generation. Used solvents can also be reworked into usable products.

J A more efficient mill can reduce total cleaning waste volumes by eliminating the need for multi- pass dispersions.

J Again, an automated paint discharge system can help reduce spills. In addition, accuracy and consis- tency can be improved, thus reducing the generation of off-spec product.

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Filtering and Filling

Use wire screens whenever possible for filtering, since they can be reused almost indefi- nitely when backwashed with a solvent. Use wire screens when the contaminated solvent- bearing washwater can be reused or reworked onsite. The next best filtering alternative is bag filters. These contain much less paint in comparison to spent cartridges, and can be reused several times. However, bag filters are more expensive than cartridge filtration units. Unusable bag filters can easily be washed with solvent and dried prior to disposal as non- hazardous waste. Combine wash solvent with other solvent wastes and reclaim onsite or offsite.

1. What are the types and number of filtering units used in your facility?

0 fiber cartridge (--. cartridges per unit),

0 wire mesh cartridge ( -cartridges per unit),

0 bag L bags per unit),

0 other (-).

If wire mesh filters are used, are they backwashable?

0 Yes 0 No

If yes, how is the waste stream from backwashing handled?

If no, how are the wire mesh filters cleaned?

2. Are any of the filter units dedicated to a particular product line?

0 Yes 0 No

3. If bag filters are used, are they cleaned and reused?

0 Yes 0 No

How many times can they be reused? __ . How are the cleaning wastes handled?

J Dedication of the filter units will reduce cleaning wastes.

J Spent bag filters can be washed, dried, and disposed as non-hazardous waste.

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Tank/Con tainer Cleaning

1. Is the piping to and from tanks routinely flushed with water or solvent?

0 Yes0 No

Is the piping “pigged” before flushing?

0 Yes 0 No

2. What is the cleaning sequence (i.e., manually scraped, washed with a high-pressure spray system using caustic, then solvent rinsed) used for cleaning portable and fixed let-down tanks and the mixing units?

3. Have you investigated the effect of reduced cleaning on product quality?

0 Yes 0 No

4. Are all of the tanks cleaned promptly after use?

0 Yes 0 No

J Use a plastic or foam “pig” to clean pipes. The “pig” (slug) is forced through the pipe from the mixing tank to the filling machine hopper. The “pig” pushes ahead paint left clinging to the walls fo the pipe. This increases yield and redudes the degree of pipe cleaning required. Inert gas is used to propel the “pig” and minimize drying of paint inside the pipe. The equipment (launcher and catcher) must be carefully designed so as to prevent spills, sprays, and potential injuries, and the piping runs must be free of obstructions so that the “pig” does not become stuck or lost in the system.

J To reduce the amount of paint left clinging to the walls of a mix tank, use rubber wipers to scrape the tank sides. This operation requires manual labor; hence, the percentage of waste reduction is an operator function.

J Mechanization/automation of this technique should be considered. Many new mixers are available that are designed with automatic wall scrapers; these mixers can be used with any cylindrical mix tank (flat or conical bottom).

J Unnecessary cleaning of equipment increases the amount of cleaning wastes generated. The feasibility of eliminating cleaning steps between subsequent batches should be explored. Conduct experiments on a small scale in the laboratory to measure the degree of contamination due to the elimination of cleaning. If the contamination of the products is within quality control standards, then the cleanup step can be eliminated.

J Allowing paint to dry in the tanks before cleaning increases the need for solvents and/or caustic cleaning compounds.

Are any precautions taken to prevent the paint from drying?

0 Yes 0 No

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5. Are there established procedures for communication between cleaning and production crew?

0 Yes 0 No

6. If a high-pressure spray system is not used for cleaning tanks, do you plan on installing one soon?

0 Yes 0 No

7. If you have high pressure spray systems, is the nozzle as effective at removing dried paint as originally designed or expected?

Yes 0 No

If no, has the use of new nozzle heads or higher pump pressures been attempted?

0 Yes 0 No

8. Do you use a counter-current cleaning sequence?

Yes No

J Proper coordination between production and cleaning crews can prevent such things as paint drying in the tanks.

J Using high pressure hoses for spray cleaning can significantly reduce your waste volume. Consider purchasing a portable high pressure spraying system.

J After scraping the tank walls, high pressure spray hoses can be used in place of regular hoses to clean water-based paint tanks. High pressure wash systems can reduce water use by 80 to 90 percent. In addition, high pressures sprays can remove partially dried-on paint so that the need for caustic is reduced.

J Tanks used for making solvent-based paints normally employ a built-in high pressure cleaning system.

J For facilities that have additional space available, countercurrent rinsing can be employed. This techniques uses recycled “dirty” solution to initially clean the tank. Following this step, recycled “clean” solution is used to rinse the “dirty” solution from the tank. Since the level of contamination builds up more slowly in the recycled “clean” solution than with a simple reuse system, solution life is greatly increased. Countercurrent rinsing is more common with clean-in-place systems, but can be used with all systems.

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9. If you are currently using caustic, have alternative commercial cleaning solutions been tried?

0 Yes 0 No

If caustic cleaning is used, is it sometimes necessary to clean with a solvent?

Yes 0 No

If yes, are attempts made to use a more efficient cleaning solution?

0 Yes 0 No

10. If you use a caustic cleaning system, do you dewater the sludge before disposal?

Yes 0 No

1 1. The product containers are mostly cleaned

0 onsite 0 offsite.

12. Do you keep solvent- and water-based wastes segregated?

Yes 0 No

13. Do you rework water-based and alkaline cleaning wastes?

0 Yes0 No

J Substituting a proprietary alkaline cleaning solution for their caustic solution cut one audited facility’s solution replacement frequency in half, thereby reducing the volume of cleaning solution requiring disposal. Another company replaced its caustic cleaning solution with a proprietary alkaline solution with a replacement frequency of half that for the caustic solution. The cleanup residuals volume was therefore reduced nearly by a factor of two. There are no expected disposal problems associated with the use of replacement cleaning solutions.

J Dewatering the sludge by flocculation, filtration, or centrifugation can minimize this waste volume. Adding de-emulsifiers to the rinsewater can also reduce the volume by breaking the emulsion. In this case, the spent rinsewater should be allowed to settle for an adequate period of time to allow for complete solids separation.

J Cleaning containers onsite can reduce waste management costs by eliminating the need for transporting contaminated containers.

J This facilitates the rework of both these wastestreams into marketable products. Also, segregate alkaline cleanup wastes from rinsewater wastes, since these can also be reworked.

J These cleaning wastes can be blended with additives (after flocculation) to generate an all- purpose beige paint.

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RfCYCLlNG

Recycling is not source reduction per se, but recycling can significantly reduce the volume of wastes treated or disposed. Paint formulators should consider the following when looking at recycling as a waste minimization option:

increase recyclability onsite recycling offsite recycling waste exchange possibilities

Increase RecjdaM#y

1. Do you maintain a minimum solvent content in your solvent waste?

0 Yes c? No

2. Do you segregate your solvent wastes?

0 Yes No

J If offsite reclamation is the preferred method for dealing with solvent wastes, it is most economical to generate a waste containing more than sixty percent solvent. Maintenance of this minimum solvent content increases the recyclability of your solvent wastes. For example, one recycling company will reclaim solvent wastes only if the solvent yield from the waste is more than sixty per cent. If the solvent yield is lower, the wastes are incinerated, and you incur the additional cost of having to replace the lost solvent.

J Recyclability is improved by waste segregation. If possible, standardize the solvents you use.

Onsite Recycling

1. Do you rework cleanup solvents and wastes into useful products?

0 Yes 0 No

J Cleanup solvents from various cleaning operations can be blended and reworked into marketable products. All of the wastes due to customer returns, obsolete finished products, off-spec products, and scooped up spills should be reworked to the fullest extent possible.

2. Do you reuse cleanup solvents to the fullest extent possible?

0 Yes 0 No

J Reuse of your cleanup solvents can reduce waste solvent quantity. Wash solvent from each (or at least the most prevailing type) of solvent-based paint batches can be collected and segregated to facilitate reuse. The wash solvent can then by reworked into compatible batches.

19

3. Do you reuse your filter bags? J Filter bags can be rinsed clean and reused several

Yes n NO times, thus decreasing the volume of spent bags requiring disposal.

4. Has onsite distillation of the spent solvent ever been attempted?

J Onsite distillation is often less expensive than offsite processing. Also, distillation bottoms can sometimes be reworked into marketable products. In the automotive refinishing industry, rework of distillation bottoms into automotive undersealer has been reported.

Yes u NO

5. If you generate too many small volume solvent waste streams to justify onsite distillation, can the solvent used for equipment cleaning be stan- dardized?

U Yes 0 No

Offsite Recycling

1. Do you consider offsite recycling?

0 Yes 0 No

HAZARDOUS WASTE STORAGE AND HANDLING

You may generate additional hazardous waste if you store raw materials or hazardous wastes improperly. Store them in covered containers. A locked, covered, indoor area with a concrete floor and curbs for spill containment would be ideal for storage. Inspect the storage area often, at least once a month, to look for leaky containers or improper storage.

1. Do you inspect storage area(s) to make sure containers aren’t leaking and are stored properly?

0 Yes 0 No

J A good time to inspect your storage area(s) is during your raw materials inventory.

20

2. Do you store different waste types in separate containers?

0 Yes No

3. How long do you usually store your hazardous wastes?

4. Are storage containers covered?

Yes No

5. Have you installed containment, such as a curb or dike, in storage areas to minimize the area contaminated by a spill?

0 Yes 0 No

6. Are any storage tanks tied into a vapor recovery system?

0 YesO No

7. Are all above and below ground storage tanks routinely monitored for leaks?

0 YesO No

8. Do you document individual wastes with their sources of origin and eventual disposal, along with the incurred disposal costs?

0 Yes 0 No

J Waste reduction requires waste segregation. Mixed wastes cost more to manage.

J You may store hazardous waste in tanks or containers (less than 5000 gallons or 45,000 pounds) for up to 90 days. If you generate less than 2.2 pounds of hazardous waste in a month, you may begin counting the 90 days of storage after you have collected a total of 220 pounds of hazardous waste (or 2.2 pounds of extremely hazardous waste). If you store hazardous waste for more than 90 days, you will need a storage permit or variance. Contact your local DHS Regional Office for information on applying for a permit. Also, your local county or city requirements may be more restrictive. Contact your local environmental health office for more information on local requirements.

J Covered containers will help reduce spills and evaporation, contamination of product from dust, and corrosion of the drum top from rain.

J A curb or dike surrounding the storage pad will prevent spills from leaving the storage area. A slightly sloped storage pad will help accumulate the spill in a smaller area so it will be easier to clean up.

J A vapor recovery system can help reduce evapo- rative losses.

J Routine tank monitoring is essential to prevent major losses through leaks, and may be required by law.

J Computerized waste documentation and control can help track the wastes in the process and can help in undertaking control strategies.

. ..

21

9. Are all empty bags, packages, and containers that contained hazardous materials fully segregated from those that contained non-hazardous wastes?

0 Yes 0 No

10. Are the different solvent wastes due to equipment cleanup kept segregated?

0 Yes0 No

1 1. Are the aqueous wastes associated with equipment cleanup kept segregated from the solvent wastes?

0 Yes 0 No

12. Are the spent alkaline solutions kept segregated from the rinse water streams?

0 Yes 0 No

13. Have you investigated offsite reuse through Waste Exchange services?

0 Yes 0 No

J If you mix different kinds of wastes, you reduce recycling potential.

J The California Waste Exchange lists materials both wanted and available. For information about the Waste Exchange, call the Alternative Technol- ogy Division at the number at the back of this checklist. .

22

/ I / / / / / /

SECTION 2: EVALUATION OF WASTE MINIMIZATION AND WASTE MANAGEMENT OPTIONS After completing the checklist and identifying your waste minimization options, you can use the following table to evaluate your options. Each option will be evaluated in four areas: 1) waste management hierarchy, 2) implementation potential, 3) type of options, and 4) cost of the option.

1. The waste management hierarchy (WMH) consists of the following, which are, in the preferred order, 1) source reduction, 2) resource recovery and recycling, and 3) treatment.

SR = Source Reduction RR = Resource Recovery RI = Recycling (in process) = 4 pts. RE = Recycling (end-of-pipe) = 3 pts. TI = Treatment (in process) = 2 pts. TE = Treatment (end-of-pipe) = 1 pt.

= 5 pts. = 4 pts.

2. The implementation potential (IP) is the chance that you believe this option has of being implemented in yqur shop.

High = 4pts. Low = 2pts. Medium = 3 pts. None = Opts.

For options that you evaluate as “none”, or having no potential for being implemented into your shop, no further evaluation is necessary, since you feel that you cannot implement those options.

3. “Type of option” refers to the groups or classes the authors felt would cover the majority of the options. these four classes or types of options are our designations; you may feel that a further breakdown is necessary. You may want to establish your own classes, which is oky since only you know about your individual shop practices. The four classes are:

P/P = Policy or ProceduralChange = 4pts. PM = Process Modification = 3 pts. EM = Equipment Modification = 2 pts. NE = NewEquipment = 1 pt.

4. The ‘cost of option’ refers to what you feel it will cost to implement this waste minimization option.

None or no cost = 4 pts. Medium cost = 2 pts. Low cost = 3 pts. High cost = 1 pt.

Example: Evaluate the following two options to determine the most attractive waste reduction option:

1) First-in , first-out material policy 2) Install distillation unit to recycle solvents in process

23

/ /

TABLE 3: Waste Minimization Option Evaluation

Waste Minimization Technique

1. First-in First-out Material Policy

2. Recycling (in process)

WRH"

Scored bY

authors

I * WRH = Waste Reduction Hierarchy * IP = Implementation Potential

Option Total

(9)

After totaling the scores you can see that implementing a first-in first-out material policy should be implemented before in process recycling. The next step is further evaluation of the economic feasibility and associated payback period, using the worksheet in Section 3.

After evaluating each option in the four areas, ac'd up their scores and complete the table. After completion of the table for the options identified for use in your shop, a prioritization or order in which to further explore the options should result.

This is a preliminary analysis of the options to quickly identify those options desirable for implementation in your shop. A more detailed study into the costs of each option should be conducted to see exactly how the option will affect your shop financially.

The above classes and point values for each area were determined by the authors of this document; they are not hard and fast rules, only guidelines. If you feel you have more than four types of options, you can develop your own types of options and their respective point values. This document is to stimulate your thinking about waste minimization options within your plant.

24

7// TABLE 3: Waste Minimization Option Evaluation


1. Management Practices

0 Established waste minimization

Material balances performed

0 Regulatory compliance

program

2. Plant Operations

Vary production schedule

0 Light-to-dark batch sequencing

Lab-scale tests

Management

3. Raw Materials Storage and

0 Test before accepting from

0 Computerized inventory system

0 Reroute traffic to avoid storage

Minimize stock

0 First-in first-out usage

Return obsolete material to

Clear policy for materials use

Return empty drums to supplier

Handling

supplier

area

supplier

Reuse drums

Use rinseable/recyclable drums

WRH"

scored bY

authors

* WRH = Waste Reduction Hierarchy * IP = Implementation Potential

Option Total

25



4. Drums, Containers, and

Inspect drums before acceptance

Purchase pre-weighed materials

Customer incentive program

Packages

(bulk purchasing)

5. Spills

Spill prevention policy

High level shutdown alarms

Flow totalizers

Pipeline drainage or purging

Dikes

before disconnect

6. Material Substitution and Product Reformulation

Substitute for hazardous materials (i.e., chlorinated solvents, lead or chrome pigments, mercury, etc.)

based paints

form

Substitute high-solids or water-

Use pigments in slurry or paste

7. Process Operations

Minimize passes through the mill

WRH"

Scored bY

authors


Option Total

26

i’ TABLE 3: Waste Minimization Option Evaluation


For multiple passes, use separate containers for feeding and receiving

Dedicate mills

Minimize mill cleaning

Standardize solvent usage

Maximize solvent life

Use more efficient mills

Automate paint discharge system

8. Filtering and Filling

Use wire screens

Use backwashable wire screens/filters

Dedicate filter units

Reuse bag filters

9. Tank/Container Cleaning

“Pig” piping before flushing

Scrape tanks before washing

Reduce cleaning

Prevent paint from drying in

Use high-pressure spray system

Counter-cun-ent cleaning

tank

sequence

WRH”

Scored bY

author!

* WRH = Waste Reduction Hierarchy * Ip = Implementation Potential

Option Total

27

WRH"

icored bY

iuthors

/ /



Use alternative cleaning solutions

Clean containers onsite

Use high pressure hoses for tank cleaning

Segregate solvent- and water- based wastes

Rework water-based and alkaline cleaning wastes

10. Recycling

Maintain minimum solvent content to maximize rec yclability

Segregate solvent wastes

Rework cleanup solvents and wastes into useful products

Distill solvents onsite

Reuse cleanup solvents

Reuse filter bags

Standardize solvents

Offsite recycling

1 1. Hazardous Waste Storage

Inspect storage areas

Store different waste types in separate containers

and Handling


Option Total

28

/



Cover storage containers

Containment (curbs or dikes)

Vapor recovery system for

Tanks monitored for leaks

Document wastes (Le., origin and disposal, w/incurred disposal costs)

hazardous wastes

wastes

storage tanks

Segregate hazardous and non-

Segregate different solvent

Consider Waste Exchange

WRH"

icored bY

iuthors

-

Option Total

The following section is for you to identify waste reduction opportunities that are specific to your shop, or that we may have overlooked. The table is for your use only, as is this entire document.

~

1.

2.

3.

4.

5.


29

/ / / / / / / /

Estimated cost Savings per unit

Material or Service (units) (1)

Water

Sewer

Power

Chemicals

Waste Handling

Feespenalties

Labor

Misc.

SECTION 3: PROFITABILITY WORKSHEET

Total Savings

($/unit) (2)

The worksheet below can be used to calculate rough estimates of projected costs, savings, and payback periods associated with each waste reduction technology. These worksheets do not take into account amortization, depreciation, or tax factors.

Waste Reduction Technique:

Capital Costs

Equipment Payback period =

Capital Investment Installation

Annual Operating Cost Savings Utilities

Production Down Time

Construction Materials

Other

Implementation Costs:

/ TABLE 4: Annual Operating Cost Savings (Use negative numbers to indicate costs that will increase.)

30

APPENDIX A: TABLES OF WASTE MINIMIZATION OPPORTUNITIES

The following tables summarize the waste minimization options in the checklist sections. They will assist you in prioritizing the options you may be able to implement. (Tables summarizing the waste minimization options are included for each section of the checklist.)

TABLE Al: Summary of Management Practices and Plant Operations Management Waste Minimization Opportunities

Waste Reduction Techniques

Management Practices

Established waste

Material balances

Regulatory compliance

minimization program

performed

Plant Operations Management

Vary production

Light-to-dark batch

Lab-scale tests

schedule

sequencing

Currently Used

CleslNo)

Implementation Potential ~

High Medium Low None

31

TABLE A2: Summary of Raw Material Storage and Handling Waste Minimization Opportunities


Raw Materials Storage and Handling

Test before accepting

Computerized inventory

Reroute traffic to avoid

Minimize stock

First-in first-out usage

Return obsolete material

Clear policy for materials

Return empty drums to

Reuse drums

Use rinseable/recyclable

from supplier

system

storage area

to supplier

use

supplier

drums

Currently Used

r/es/No)

Implementation Potential

High Medium low None

32

TABLE A3: Summary of Containers, and Spill Prevention Waste Minimization Opportunities


Drums, Containers, and Packages

Inspect drums before

Purchase pre-weighed

Customer incentive

acceptance

materials

program (bulk purchasing)

Spills

Spill prevention policy

High level shutdown

Flow totalizers Pipeline drainage or purging before disconnect

alarms

Dikes

Currently Used

(Yes/No)



L

33

ITABLE A4: Summary of Material Substitution and Product Reformulation Waste Minimization Opportunities


Material Substitution and Product Reformulation

Substitute for hazardous materials (i.e., chlorinated solvents, lead or chrome pigments, mercury, etc.)

water-based paints

or paste form

Substitute high-solids or

Use pigments in slurry

Currently Used

Cles/No)



34

/ /

/ TABLE A5: Summary of Process Operation and Filtering Waste Minimization Opportunities


Process Operations

Minimize passes through the mill

For multiple passes, use separate containers for feeding and receiving

Dedicate mills

Minimize mill cleaning

Standardize solvent

Maximize solvent life

Use more efficient mills

Automate paint discharge

usage

system

Filtering and Filling

Use wire screens

Use backwashable wire screens/filters

Dedicate filter units

Reuse bag filters

Currently Used

(Yes/No)



-

35

/

TABLE A6: Summary of Tank and Container Cleaning Waste Minimization Opportunities


Tank/Container Cleaning

0 “Pig” piping before

0 Scrape tanks before

0 Reduce cleaning

Prevent paint from drying

0 Use high-pressure spray

0 Counter-current cleaning

Use alternative cleaning

0 Clean containers onsite

0 Use high pressure hoses for tank cleaning

Segregate solvent- and water-based wastes

0 Rework water-based and alkaline cleaning wastes

flushing

washing

in tank

system

sequence

solutions

Currently Used

r/es/No)



36

TABLE A7: Summary of Recycling and Resource Recovery Waste Minimization Opportunities

Waste Reduction Techniques (Yes/No) High

Recycling

Maintain minimum solvent content to maximize recyclability

Segregate solvent wastes

Rework cleanup solvents and wastes into useful products Distill solvents onsite

Reuse cleanup solvents

Reuse filter bags

I

I

Standardize solvents Offsite recycling

Medium low None

37

/ TABLE A8: Summary of Hazardous Waste Storage and Handling Waste Minimization Opportunities


Hazardous Waste Storage and Handling

Inspect storage areas

Store different waste types in separate containers

Cover storage containers

Containment (curbs or dikes)

Vapor recovery system for storage tanks

Tanks monitored for leaks

Document wastes @e., origin and disposal, w/ incurred disposal costs)

Segregate hazardous and non-hazardous wastes

Segregate different solvent wastes

Consider Waste Exchange

Currently Used

OleslNo)


High low None

38

ADDITIONAL PUBLICATIONS Waste Audit Study: Paint Manufacturing Industry

The California Waste Exchange

Technical Report: Solvent Waste Reduction Alternatives, Final Report and Conference Proceedings

Third Biennial Report on Technology for Recycling and Treatment of Hazardous Wastes

Fourth Biennial Report: Economic Implications of Waste Reduction, Recycling, Treatment and Disposal of Hazardous Wastes

Fifth Biennial Report: Alternative Technologies for the Minimization of Hazardous Wastes

Other reports are available from the Department. For a complete publications list, call the Office of Pollution Prevention and Technology Development at the number listed below.

FURTHER INFORMATION For more information, contact the Technology Gearinghouse in the Office of Pollution Prevention and Technology Development at: Department of Toxic Substances Control 7 14/744 P Street P.O. Box 806 Sacramento, CA 95812-0806 (916) 322-3670

For information about your regulatory requirements, contact the DTSC regional office nearest you:

Region 1 - Sacramento (916) 855-7700 - Fresno (209) 297-3901

Region 2 - Berkeley (510) 540-2122 Region 3 - Glendale (818) 551-2800 Region 4 - Long Beach (3 10) 590-4868

To get an €PA ID number, contact: Program and Administrative Support Division Department of Toxic Substances Control 7 14/744 P Street P.O. Box 942732 Sacramento, CA 94232-7320 (916) 323-3418

39

/ / / / I / / /

To et a copy of the California Code of Regulations, call (916) 973- 378, or write: Department of General Services, Publications Section P.O. Box 1015 North Highlands, CA 95660 (There is a charge for the regulations.)

California Highway Patrol California Highway Patrol California Highway Patrol Motor Carrier Safety Unit Motor Carrier Safety Unit Motor Carrier Safety Unit 3601 Telegraph Ave. 437 N. Vermont Ave. 11336 Trade Center Dr. Oakland, CA 94609 Los Angeles, CA 90004 P.O. Box 8001 (415) 658-2928 (213) 736-2996 Rancho Cordova, CA

95670-8001 (916) 366-5185

For general questions about small quantify generators or federal regulations, call: U.S. EPA, Small Quantity Generator Hotline U.S. EPA, RCRA (Resource Conservation and Recovery Act) Hotline U.S. EPA, RCRA Hotline, Region IX, San Francisco, CA

(800) 368-5888 (800) 424-9346 (800) 231-3075

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alifornia Department of Toxic Substances Control Office of Pollution Prevention and Technology Development Technology Clearinghouse Unit

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