Prepare a well written, 2-3 page (single spaced) evaluation of the case study,

NAME: ______________________________

Industrial Wastewater Management (ESHS-614)

Homework Assignment #4

20 Points

This homework assignment involves the review and evaluation of a pollution prevention case study. Select one of the pollution prevention case studies from those posted on myCourses in the Reference Materials, PP Case Studies module. Prepare a well written, 2-3 page (single spaced) evaluation of the case study, addressing most if the questions/issues given below. All of the points listed may not be applicable to the case study of your choice, and, therefore, it might not be possible to answer all of the questions for each base study. Assume that your audience has not read the case study.

· Describe the facility which is the bases of your case study and its operations.

· Describe the types of waste generated at the facility and the source of each waste.

· What were the goals of the pollution prevention investigation?

· What was the primary reason for implementing the pollution prevention study?

· What tools or processes were used to identify the sources of waste?

· Were reduction targets set before or after the waste was characterized/measured and what were they?

· Were the reduction targets met? Why or why not?

· What types of changes were made to reduce the volume of wastewater discharged and/or the contaminants discharged?

· What process or methodology was used to determine which changes to make to achieve pollution prevention results?

· Who initiated the WM/PP program or project (top management, line management, EHS manager, outside interest)? How much support was there for the project and for the changes that were proposed or made?

· What were the overall benefits of the pollution prevention program?

·

Indicate at least one overall lesson that you learned from this case study?

Industrial Wastewater Management 1

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To many of us today, the thought of not recycling packaging and unused materials, and not
designing products so that they can generate less waste during manufacture and use seems
unconscionable. But things were not always that way. It has only been in the last 30 to 35
years that waste minimization and pollution prevention became common words in the
environmental vocabulary. Prior to that, the focus was on treatment – get rid of waste in
the most practical and (probably) safe manner. Resources were plenty, and there was little
thought as to the inevitable time when they would not be plenty.

Fortunately for all of us, EPA recognized that there needed to be a change in strategy and
that treatment should be preceded by a number of other activities that would reduce the
amount of waste requiring generation. It is unclear to me how much of the rationale was
based on reducing the volume of waste compared with the desire to save natural
resources. The RCRA amendments in 1984 was the first time that pollution prevention was
listed as a policy, and that waste treatment would no longer be preferred.

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In 1990, the pollution Prevention Act was passed. It set in place the policy stating that
source reduction of waste would be preferred and that waste reduction and elimination
were ultimately the goals. Unlike other “Waste Acts”, however, the Pollution Prevention
Act was not codified into a new regulation; rather its goals and policies have been
embedded into most major environmental legislation via internal EPA policies and
amendments to major legislation, such as the Clean Water Act, the Clean Air Act, the
Resource Conservation and Recovery Act, the Toxic Substances Control Act, the Emergency
Planning and Community Right-to-Know Act (EPCRA), the National Environmental Policy
Act, and the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA).

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The Pollution Prevention Act established for the first time what is often referred to as the
Waste Management Hierarchy. It establishes the order of preference for various waste
management strategies, starting at the top with the most preferable, and moving to the
bottom with disposal being the least preferred option, to be chosen after consideration of
all the approaches above it in the hierarchy. Definitions of these terms are on the next
slide.

And just so you are aware, Woodsy the Owl was around when I was growing up! His focus
was more on litter than anything else, but I thought he fit here anyway.

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Reduction means that a waste material is not generated to start, and therefore requires no
further management or treatment, thus saving the most resources.

Recycling means that a waste or scrap material was generated, but the material can be re-
processed and re-used, often but not always in the same process that generated it.

Recycling can occur within different facilities or within the same facility that generated the
material to be recycled.

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One of the new terms that arose around this same time period is “Waste Minimization”. If
you are like me, you will often get confused between the terms Waste Minimization and
Pollution Prevention. Waste minimization encompasses a wide variety of methods and
activities, all focused on reducing the environmental impact of waste. To me it is a term
that is broadly applied across different facilities and industries – not just focused on a
specific industry. Waste minimization programs could include things like working with
other facilities to use their waste as your raw material; pollution prevention concepts seem
to be applied more “locally” – to one process or one facility.

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This description of pollution prevention comes from EPA’s web site. It is similar to the
waste minimization description, but it also incorporates a recognition that pollutants in
themselves are waste, and the protection of natural resources. Because it excludes out of
process recycling, it is a narrower application of recycling and reduction principles.

At the end of the day, however, whichever term you use is not important, as long as you
embody their principles and put them to work to reduce and eliminate waste, and to save
natural resources.

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Since pollution prevention is a key policy in national environmental protection activities EPA
has developed a 2010-2014 Pollution Prevention Program Strategic Plan. Within this plan
are 5 key goals, shown in this slide. They go way beyond just reducing the amount of waste
placed into landfills or incinerated. They promote key strategies related to long-term goals
for the country – conservation of natural resources, reduction of greenhouse gas emissions,
reduction in the use of hazardous materials, and integrating pollution prevention practices
into all aspects of business.

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Unlike many other environmental regulations and policies, pollution prevention has distinct
advantages to those entities that embrace it and implement it. First and foremost, it can
reduce the use of raw materials and energy and decrease waste treatment costs. In
addition, many manufacturers find quality improves in their products when sources of
waste are eliminated. Many companies are now requiring their suppliers to be
“sustainable”, and pollution prevention is an essential element towards becoming a
sustainable company. I’m sure all of you have heard advertisements from different
manufacturers claiming that they are a “zero landfill” facility – a claim that at first seems to
indicate that they don’t produce any waste (which we all know is not true). To many
consumers, environmental claims like this are an incentive to purchase that company’s
products.

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But since we are learning about wastewater in this class, it is also important to understand
the impacts of WM/PP of wastewater on the “disposal facility” – the POTW (for indirect
dischargers anyway).

The National Pretreatment Program – which incorporates the categorical discharge
standards – embraces PP. Its intent is to prevent the discharge of toxic pollutants to POTWs
by the implementation discharge limits, which force the use of upstream controls. By
keeping these toxic pollutants out of the POTW, many of which are metals, the opportunity
for beneficial reuse of the biosolids (sludges) from the POTW improves.

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As mentioned before, keeping metals and non-degradable organics out of the wastewater,
or recovering them at the point of generation, improves the quality of the sludge at the
POTW. In many cases, it can be composted or applied directly for its nutrient content to
agricultural land.

In addition to improving biosolids quality, there are other cost and process benefits to the
POTW. Adding special equipment to remove these pollutants is not necessary if they are
managed upstream. If pollution prevention also leads to a decrease in the flow rate, then
the useful life of the POTW can be extended before expansion is required, if required at all,
to treat wastewater from expanding communities.

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There are several different ways in which pollution prevention can be implemented at a
manufacturing facility. Most of these approaches can prevent pollution from both solid
waste and wastewater.

The first of these approaches is to simply improve operations. It sounds simple, but it is
often easily overlooked. Equipment may not have been cleaned and calibrated recently,
causing an increase in waste. Or maybe the process was incorrectly designed and needs to
be modified to optimize it. Consult with those that have been operating the process for a
long time and seek their input.

Next, investigate whether there have been technology improvements or changes since the
current equipment was installed. Often, additional instrumentation can provide the data
necessary to make operational improvements. Is the process working at its design
capacity? Processes generally are most efficient at the design rate and less efficient above
or below that rate. It might be better to operate part time at higher rates than full-time at
lower rates.

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Material substitution can lead to significant reductions in the amount of waste generated,
and save a lot of energy related to the production of raw materials but it is not always a
quick or simple thing to do. Even if there is a one-to-one substitution or a recycled material
is used rather than a new material, tests generally need to be run to determine if the
substitute is acceptable and produces a product that meets specifications.

Product reformulation is even more complicated that material substitution. An entirely
new way of making a material or product may be researched, followed by testing again to
determine if the product manufactured with the new process meets performance and
customer specifications. While this can be the most expensive approach, it can also be the
most rewarding, both financially and environmentally.

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If some amount of waste in inevitable, then recycle as much as possible back into the
process or into another process. A good example of this is metal plating solutions. When a
part is removed from a plating bath, if it is allowed to drip back into the bath it was
removed from, cross-contamination or dilution of downstream baths does not occur. The
removal of excess solution can also be enhanced with forced air to “blow” off the excess
solution.

Sometimes a waste requires treatment because it contains a mixture of raw materials that
can not easily be separated or a reactant that can not be recycled directly back into the
process. Often waste treatment is either easier, more cost effective or more efficient if it is
not comingled with other wastes or diluted. This is certainly the case in wastewater
streams where most of the equipment is sized according to flow rate. Another example is
pretreatment to separate a solid from a liquid, where one of the two streams can either be
re-used or sold.

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If you decide to implement the pollution prevention approach in a facility or process,
several different alternatives to reducing waste and saving resources may be discovered.
Before you jump in with two feet and begin pursuing any changes, each alternative should
be completely evaluated to determine if it will be cost effective and if there are any hidden
costs or problems.

As environmental professionals, we would like management to pursue and implement
pollution prevention because it is the right thing to do. Unfortunately, in the business
world, many companies do not do “the right thing” unless it also saves them money. To be
effective, you need to learn the language of business and use it to sell your PP ideas.

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Even with the best research and investment, there will always be barriers or impediments
to implementing pollution prevention alternatives. These are some of the more common
barriers. First, technology may not exist to do what it is you want or need to do. A
company may invest in the research to develop new technology or wait until the
technology is developed. Cost can be a huge barrier to implementation of alternatives.
Even though the desire may be there on the part of management for change, when you get
right down to it pollution prevention and waste minimization have to be cost effective. If
they are not, the companies that invest in new alternatives will soon be out of business,
leaving those that have not invested.

Some companies are not organized to effectively investigate or implement WM or PP
changes. It could be that one department needs the assistance of another to implement an
operating change or to recycle a material. If they are set up as separate cost centers, each
accountable, they may not be willing to work together. While this sounds ridiculous, since
they all work for the same company, it is a reality in many companies. Employee behaviors
fit into this same category, where workers may be resistant to change. In unionized
facilities, this can sometimes be a big challenge.

And finally, even though WM/PP is an overall benefit t the environment, regulations exist
that do not make is simple to change some processes, particularly if regulatory permits are
in place. In addition, a hazardous waste may be produced after a change, where one was
not formed before the change. As we will see when we get to lectures on universal waste
and e-waste, the EPA is trying to overcome some of these hurdles and make management

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requirements for many wastes simpler.

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So let’s say that your boss has agreed to let you investigate whether a pollution prevention
evaluation of a process will yield results. Where do you start?

Before you run out to the plant to see what is going on, sit down and develop a plan. Set
your goals up front so that the project can be easily defined, and so you know when your
project has been completed. Understanding the need behind WM or PP for a particular
process can help you to better see opportunities to improve. Also, make sure you
understand what the boundaries are for your investigation and potential solutions. There is
no sense proposing a multi-million dollar solution if you are limited to spending $200,000.

And finally, you can never have enough data. Gather it, analyze it, and use it to tell you
what is going well, and what needs to be improved.

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Here are just a few examples of the types of data and information that would be helpful for
conducting a WM/PP audit of a process that generates wastewater.

This is a perfect opportunity to put those mass-balance skills to work! Everything that goes
into the process must come out somewhere. Draw a process flow diagram to help you
trace the material flows. On the next two slides, I’ll give you a quick example of how this
can help.

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They say a picture is worth a thousand words. When looking at complicated processes, this
couldn’t be more true. This diagram is for an electroplating operation. The part is rinsed in
counter-current flow baths before its final wash. The water from the first plating bath is
treated to remove metals, then sent to the sanitary sewer, as is the water from the final
wash.

Before going to the next slide, spend a minute or two on this slide thinking about how you
could reduce water consumption and waste disposal.

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Here are a few potential ways of reducing water use and the amount of waste sent to the
landfill. If the filter cake was previously disposed of as a hazardous waste, the savings with
metals recovery could be substantial.

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We are fortunate at RIT to have a lot of resources available to us at the New York State
Pollution Prevention Institute. If your company or business is within New York State you
may be eligible for support or some of the programs that are offered through P2I. The EPA
is also a great resource for pollution prevention information.

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