Quest Consultants & Associates, Inc.
WASTE MINIMIZATION/POLLUTION PREVENTION PLAN
INTRODUCTION
In accordance with the United States Environmental Protection Agency Resource Conservation and Recovery Act (RCRA) as Amended by the Hazardous and Solid Waste Amendments of 1984, Quest Consultants has developed a Waste Minimization/Pollution Prevention plan which will encourage clients to conscientiously strive to reduce waste and prevent pollution.
Waste Minimization means the reduction to the extent feasible, of hazardous waste that is generated prior to treatment, storage and disposal. It is defined as any source reduction or recycling activity that results in either
(1) Reduction of the total volume of hazardous waste,
(2) Reduction of the toxicity of the hazardous waste, or
(3) Both.
Practices that are considered waste minimization include recycling, source separation, product substitution, manufacturing process changes, and the use of less toxic raw materials.
Pollution Prevention is the use of materials, processes, or practices that reduce or eliminate the creation of pollutants or wastes at the source. It includes practices that reduce the use of hazardous and non-hazardous materials, energy, water, or other resources as well as those that protect natural resources through conservation or more efficient use. Pollution Prevention is the maximum feasible reduction of all wastes generated at production sites. It involves the judicious use of resources through source reduction, energy efficiency, reuse of input materials, and reduced water consumption.
COMPONENTS OF THE WASTE MINIMIZATION PLAN
1. MANAGEMENT INITIATIVES PROGRAM
a. Management Support and Employee Participation
A clear commitment by senior management through policy, communications, and resources, to Waste Minimization and Pollution Prevention is essential to earning the dedication of all employees. For this to happen, a formal policy statement must be drafted and adopted. The purpose of this statement is to reflect the departments and ultimately the clients commitment and attitude toward protecting the environment, minimizing or eliminating waste, and reuse or recycling materials. Creative, progressive, and responsible leadership will serve to develop environmental policy; however, the total employee workforce will need to be involved to realize the fruits for the planning.
b. Training
As with any activity it is important for management to train employees so the have an understanding of what is expected of them and so they understand why they are being asked to change the way things are done. Employees must be provided formal and on-the-job training to increase awareness of operating practices that reduce both solid and hazardous waste generation. The training program includes the regulatory compliance requirements which may be found in the waste management policies, occupational health and safety requirements which can be found in both the Employee Hazard Communication/Right to Know and Safety Standard programs, and a statement of the clients approach to waste minimization which is to be found (by example) in this plan. Additionally, training on waste minimization and pollution prevention is given in the RCRA Hazardous Waste Training provided by the Department of Environmental Health and Safety (EHS).
c. Waste Audits
A program of departmental level waste audits should be implemented to provide a systematic and periodic survey of the clients operations designed to identify areas of potential waste reduction. The audit program includes the identification of RCRA hazardous wastes and the sources of these wastes, the prioritization of various waste reduction actions to be undertaken, the evaluation of some technically, economically and ecologically feasible approaches to waste minimization and pollution prevention, the development of an economic comparison of waste minimization and pollution prevention options, and the evaluation of their results.
2. WASTE MINIMIZATION OPTIONS PROGRAM
The Department of Environmental Health and Safety, in cooperation with the clients departments and or department mangement, will investigate, evaluate, and recommend waste minimization options. This program will include a step-by-step analysis of waste reduction options, recycling options and finally, only after acceptable waste minimization techniques have been investigated and evaluated, waste treatment options. Waste minimization options can include but are not limited to the following options:
a. Good Operating Practices
These practices involve the procedural or organizational aspects of the clients operations, research or production activities and in some areas changes in operating practices, in order to reduce the amount of waste generated. These practices would include, at a minimum, material handling improvements, scheduling improvements, spill and leak prevention, preventive maintenance, corrective maintenance, material/waste tracking or inventory control, and waste stream segregation according to toxicity, type of contaminant and physical state.
b. Material Substitution Practices
The purpose of these practices is to find substitute materials which are less hazardous than those currently utilized and which result in the generation of waste in smaller quantities and/or less toxicity.
c. Technological Modification Practices
These practices should be oriented towards process and equipment modifications to reduce waste in the clients setting. These practices can range from changes that can be implemented in a matter of days at low cost, to the replacement of process equipment involving large capital expenditures.
d. Recycling Options
These options are characterized as use/reuse and resource recovery techniques. Use and reuse practices involve the return of a waste material either to the originating process or to another process as a substitute for an input material. Reclamation practices tenders a waste to another company.
e. Surplus Chemical Waste Exchange Options
Inter- and intra-department chemical exchange has been implemented and encouraged by departments and staff of clients. A material exchange not only reduces wastes, it also saves money, both important considerations during times of fiscal crises.
f. Treatment Options
These options should be oriented to the changes of physical, chemical or biological character of the hazardous waste in order to reduce the toxicity and the volume to render such waste available for storage and safer to manage.
WASTE MINIMIZATION/POLLUTION PREVENTION AT THE POINT OF GENERATION
An effective waste minimization/pollution prevention program starts at the point of generation. When planning or actively pursuing an investigation or course of study, investigators must consider the hazardous nature of all materials involved. Once a table of materials has been defined, each investigator is responsible for determining whether material substitution will reduce the generation of hazardous waste. For instance, non-hazardous biodegradable scintillation cocktails may be substituted for traditional solvent based media; a non-chlorinated solvent may be substituted for a chlorinated solvent; end-products may be rendered non-hazardous by incorporating additional procedures into the manufacturing production or non-productive protocol.
Known, non-hazardous materials or wastes must not be declared hazardous for the purposes of disposal. Conversely, each client must take responsibility for the analysis of unknown materials which it has generated in the past and which remain in the custody of the generator for inordinate periods of time.
1. PROCUREMENT OF MATERIALS
Attention must be given to initial and subsequent procurement of chemicals and other hazardous materials. Volume packaging and pricing may appear attractive until waste disposal costs of unused materials are considered. For example, 500 grams of Sigma supplied hexachlorocyclohexane (Lindane gamma isomer) at $46.35 costs less per gram than the 100 gram or 50 gram packaging size ($16.85 and $9.35), however if only 150 grams are needed, disposal costs for the unused 350 grams range from $30.00 to $75.00 depending on disposal contractor and disposal methodology.
The waste minimization aware researcher would take into account the disposal costs and purchase the two smaller quantities. Multiply the number of researchers by the number of material purchases annually and it is apparent that significant savings will occur. Whether chemicals are purchased in milligram or gallon quantities, Hazardous Waste Disposal costs must always be considered.
2. TREATMENT OF LABORATORY WASTES AND RESIDUALS
By incorporating bench-scale waste treatment techniques in production and non-production protocols, a significant percentage of client generated hazardous wastes can be eliminated. Several simple methodologies may be employed.
Elementary neutralization of acids and caustics is simple and immediate. Precipitates (if hazardous) are removed by filtration while the supernate is disposed via sanitary drain.
Solvents are candidates for re-distillation. Recovered solvent can either be reused or used for a less critical application if solvent purity is a research criterion. Distillation residues must be handled as hazardous waste. Waste solvent disposal can be curtailed by at least 50 percent.
Other waste minimization/reduction techniques to be employed include oxidation or reduction and precipitation of toxic ions as insoluble solids. Detailed waste treatment/disposal procedures for over 400 specific laboratory chemicals may be found in the following book:
• Hazardous Laboratory Chemicals Disposal Guide by Margaret A. Armour, CRC Press, Inc., 2000 Corporate Blvd., N.W., Boca Raton, Florida 33431
In addition, the following publications include both specific and generic waste treatment information:
• Prudent Practices for Disposal of Chemicals from Laboratories, National Research Council, National Academy Press, Washington, D.C.
• The Sigma-Aldrich Library of Chemical Safety Data, R. E. Lenga, Sigma-Aldrich Corporation, Milwaukee, WI.
• Catalog Handbook of Fine Chemicals, Aldrich Chemical Company, 1001 West Saint Paul Avenue, Milwaukee, WI 53233
• Destruction of Hazardous Chemicals in the Laboratory, G. Lunn & E. B. Sansone, John Wiley & Sons, New York, NY 10158
STORAGE, CONSOLIDATION, AND SEGREGATION OF WASTES
1. USE OF CONTAINERS
As a rule of thumb, the largest possible container consistent with safety and space requirements should be used to store hazardous wastes. One 5 gallon plastic carboy takes up less space than five one liter bottles. A 55 gallon drum, which takes less floor space than four five gallon containers, may be placed in an unused storage space of the clients’ facility. Avoid using one liter or smaller containers for waste disposal. Transfer wastes to a larger container, triple rinse the small container, allow to air dry and dispose as trash.
Containers used for storage of Hazardous Wastes must be compatible with the stored material and must have a secure closure.
Solid chemicals may remain in their original container.
2. SOLVENTS
Chlorinated and non-chlorinated solvents should never be mixed. The disposal cost to incinerate chlorinated solvents can approach six times the amount to fuel-blend non-chlorinated solvents. Clients generating large quantities of a particular chlorinated solvent such as Methylene chloride, 1,1,1-trichloroethane, should further segregate them, as there is an active recycling market for these waste streams.
Mixed chlorinated/non-chlorinated solvents generated as a result of production protocols should be distilled and components placed in appropriate containers. If distillation is not possible the material should be placed in a chlorinated solvent waste drum.
3. CORROSIVES
Simple acids and caustics should be neutralized in the clients’ facility and not consolidated into drums for waste disposal. Acids and caustics may be consolidated using appropriate safety protocols, however corrosives containing heavy metal salts should be kept separate.
4. FORMALDEHYDE SOLUTION 37% (FORMALIN)
Formaldehyde Solution is a hazardous waste because it exhibits the characteristic of ignitability (Flash Point is 140EF.) Specimens preserved in Formalin are not hazardous waste because the specimen has a higher Flash Point. Specimens shall be removed from the formaldehyde solution and handled as biohazard or special medical waste. The formaldehyde solution may be consolidated to a container. Specimen jars/containers shall be rinsed with water and reused or discarded as trash.
These guidelines are not all-inclusive. Many opportunities for waste minimization and waste segregation present themselves to the waste generator. All members of the clients’ community are encouraged to question their present chemical usage and waste disposal methods and develop more efficient minimization strategies.
WASTE MINIMIZATION PLAN IMPLEMENTATION
1. EMPLOYEE TRAINING
The Waste Minimization/Pollution Prevention employee training requirements can be satisfied by RCRA Hazardous Waste Management Training requirements for Hazardous Waste Generators provided by EHS. The training procedure includes an employee affirmation of training form for clients’ department records.
2. WASTE AUDITS
Waste audits should be performed by the Department Environmental Coordinator (or employee or contractor granted authorization to perform audits) in cooperation with EHS. Each location within departments should perform a chemical inventory using forms provided. The forms will also be used to assess department operating practices, material handling capability and production operating practices and waste minimization options.
3. FILES
All records of training and audit files are required to be maintained for at least three (3) years and are to be kept at the departmental level. It is strongly recommended that all documents required by, or in support of, Federal and/or State environmental regulations be held for the life of the client facility.
WASTE MINIMIZATION TARGETS
Experience has shown that a significant percent of the waste received from generators consists of surplus and unused chemicals. By auditing each department a knowledge base of chemical purchase and usage will be developed, allowing each department to develop and implement controls on the purchase of chemicals, client intra-departmental chemical sharing/swapping programs, and eliminate excessive purchase and usage.
Laboratory protocols (R&D) and production need to be examined to determine whether changes in protocols will result in the generation of non-hazardous or less hazardous waste, or waste reduced in toxicity or volume. Specifics to consider include the substitution of non-toxic materials for inorganic, heavy metal containing salts, treatment or neutralization of experiment end products, distillation or evaporation of water-based chemical end products, reclamation and reuse of common solvents, use of non-chromate glass cleaners, incorporating waste treatment methodology (neutralization, deactivation, chemical reaction, incineration, etc.) as a standard part of the client protocol in order to generate non-hazardous end products
Facilities Operations need to be examined to determine whether changes in practices and procedures will result in the generation of non-hazardous or less hazardous waste, or waste reduced in toxicity or volume. Specifics to consider include the substitution of non toxic materials for toxic ones, distillation or evaporation of water-based chemical end-products, reclamation and reuse of common solvents, use of non-chromate cleaners, as a standard part of doing business to generate non-hazardous end products.
By implementing and adhering to the guidelines for handling and storing wastes at the point of generation, the costs associated with hazardous waste disposal will also be minimized.
ADDITIONAL INFORMATION
Additional information may be found in the following:
EPA/625/7-90/010 Guides to Pollution Prevention-Research and Educational Institutions June 1990
EPA/625/7-88/003 Waste Minimization Opportunity Assessment Manual July 1988
(United States Environmental Protection Agency Risk Reduction Engineering Laboratory Center for Environmental Research Information Cincinnati, Ohio 45268)
888-730-4646
E-mail: Quest@QuestInc2.com