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Article # 0048

 

Source Reduction and Waste Minimization Plan for a Fiberglass Manufacturing Facility

 By Karen M. Bullard, P.E. 

Introduction

 

All large and small quantity generators of hazardous waste who report to the Texas Commission on Environmental Quality (TCEQ) on the Annual Waste Summary, as well as all facilities required to file a Toxic Release Inventory with the Environmental Protection Agency, are required to develop a (SRWM) Source Reduction and Waste Minimization Plan to minimize the use of toxic chemicals and the production of hazardous waste.  This article is an example of a plan that might be used for a fiberglass manufacturing facility.  The TCEQ requires submittal of an Executive Summary of the plan to their pollution prevention program and maintenance on-site of the complete plan.  The executive summary is shown below first, with the complete plan following.  This article follows the TCEQ guidance concerning the format and content of a SRWM plan.

 

EXECUTIVE SUMMARY OF SOURCE REDUCTION AND WASTE MINIMIZATION PLAN

 

Facility:                     ABC Manufacturing, Inc.

                                    Main Plant

                                    1234 HWY 56

                                    City, TX  78700

 

Contact:                    Mr. Fiberglass Client

                                    P.O. Box 123

                                    City, TX  78700

                                    (800) 234-5678

                                    (800) 910-1112 (fax)

 

Date:                          June 29, 2009

 

Description:

           

ABC Manufacturing, Inc. manufactures and assembles units at the Main plant.  Operations include application of resin and gelcoat materials by both spray and hand lay-up techniques.

 

TCEQ Account ID:             AB-1234-C                                                   

 

TCEQ Air Quality:   12345

Permit Nos.

 

Solid Waste No:      87645

(TCEQ NOR)

 

EPA ID No:               TXR000001234

 

TRI ID No:                 78700ABC123HWY45

 

SIC:                            3089

 

Hazardous Waste Generated (2008) :

 

            Waste:                        0001605H Clabbered Resins/Gelcoats

            Amount:          2400 lbs

           

            Waste:                        0002203H - Waste Acetone Solvent

            Amount:          600 lbs

 

TRI Chemicals and CAS Number:

 

            Chemical:       Styrene

            CAS:               100-42-5

            Amount:          1100 lb

 

Prioritized Pollution Reduction List:

1.  Styrene:     From clabbered resin

2.  Acetone:   Waste solvent

 

 

Reduction Goals:

 

The goal is to eliminate routinely-generated hazardous waste at this plant site by the end of 2010 through a combination of source reduction and waste treatment strategies.

 

Environmental and Human Health Risks Considered:

 

The acetone and styrene used in production, as well as the hazardous waste currently produced at this plant pose greater environmental and human health risks than if the plant did not exist.  Therefore, reduction of the use of raw materials and elimination of all hazardous waste streams will be a reduction in these risks.

 

Implementation Milestones:

 

January 2010 Techniques for reducing amount of acetone will be fully implemented, as will controlled spray techniques to reduce overspray of resin and gelcoat. 

 

January 2010 Techniques for reducing amount of clabbered resins will be implemented, as well as treatment strategies to eliminate all hazardous waste streams.

 

Future Reduction Goals:

 

Techniques for reducing amount of clabbered resins will be reviewed by July 2010 to determine feasibility of anticipated reductions by plan goal date of December 2010.

 

Pollutants Changed or Shifted:

 

All routinely-generated hazardous waste will be eliminated by treating the clabbered resin/gelcoat stream to convert it to non-hazardous solid waste that can be disposed of in a landfill.  Acetone waste will be sent to the still for recycling.

 

SOURCE REDUCTION AND WASTE MINIMIZATION PLAN

 

A.        Activities That Generate Hazardous Waste

 

 

B.        Prioritized List of Source Reduction (SR) and Waste Minimization (WM)           Projects

 

I.          Acetone Solvent

            a.         Reduce amount used for cleaning (SR)

            b.         Send to still for recycling (WM)

 

II.          Clabbered resin and still bottoms

            a.         Reduce overspray of resin and gelcoat (SR)

            b.         Improve utilization of materials in bottom of tanks (SR)

            c.         Polymerize still bottoms and other clabbered resin (WM)

 

C.        Discussion of Projects

 

I.a. - The usage of acetone solvent can be reduced by controlling the amount of solvent distributed, the method by which it is used, and the method by which waste solvent is consolidated. 

 

Distribution will be controlled by centralizing the distribution point and limiting the amount distributed.  At the beginning of each day, each employee working at spraying operations and each two-man team working at hand-layup operations will be given one gallon of acetone.  Each individual will be responsible for minimizing the use of solvent for equipment and tool clean-up throughout the day.  Each container of solvent will have a lid to minimize evaporation.  Tools will be left in the containers overnight to soak until morning.  Soaking reduces the amount of solvent needed to flush the tools clean.

 

Each morning, the spent acetone will be transferred to the waste collection drum.  When the drum is full, it may be transported to the acetone still for recycling.  Authorization has been obtained from the TCEQ for the recycling of the spent acetone waste at still. 

 

Technically, this strategy will present no difference in the quality of the end product and the time spent on cleanup would be similar to the time spent prior to implementation of the strategy.  Economically, the strategy would reduce costs of both purchasing raw materials and disposing of spent acetone.  Environmental risk would decrease from present practice because the amount of solvent sent to disposal facilities would decrease. Human health risks would be the same since workers would still be exposed to the same hazardous solvent.

 

I.b. - The waste acetone solvent can be recycled.  Each morning, the spent acetone will be transferred to the waste collection drum.  When the drum is full, it may be transported to the acetone still for recycling.  Authorization has been obtained from the TCEQ for the recycling of the spent acetone waste at the plant.  This will eliminate the spent acetone hazardous waste stream.

 

Technically, this strategy will present no difference in the quality of the end product and the time spent on cleanup would be similar to the time spent prior to implementation of the strategy.  Economically, the strategy would reduce costs of both purchasing raw materials and disposing of spent acetone.  Environmental risk would decrease from present practice because the amount of solvent sent to disposal facilities would decrease. Human health risks would be the same since workers would still be exposed to the same hazardous solvent.

 

II.a. The overall usage rate of resin and gelcoat affects the number of times clabbered resin will need to be removed from tanks and totes.  It also affects the usage rate of acetone solvent.  Implementation of controlled spray techniques will reduce the amount of overspray and, consequently, the amount of resin and gelcoat raw materials needed to produce the same amount of product.

 

Controlled spraying is accomplished by three means:

 

            1.  Operation of spray guns at the lowest practical tip pressures.

 

All of the spray guns will operate at pressures between 20 and 25 psi as compared to many guns that operate at pressures of between 60 and 70 psi.  These are the lowest pressures that can feasibly be used with these spray guns to achieve a good spray pattern.

 

            2.  Proper spray gun handling techniques. 

 

Employees have been or will be trained in the most         efficient procedures to reduce overspray.  In addition, all of the spray guns at the mandrel stations operate on a track that prevents the spray guns from spraying beyond the end of the tank or pipe.

 

            3.  The use of mold flanges to reduce overspray.

 

            The use of these flanges will be implemented to reduce overspray.

 

In addition to meeting the criteria above for controlled spray, the use of Magnum Venus Products fluid impingement tips will be implemented on all spray guns.  Test results using these types of tips show a reduction in emissions to below the levels used for the UEF emission factors and therefore may provide an additional reduction in overspray.

 

Technically, this strategy will present no little or no difference in the quality of the end product.  Production time will increase by a negligible amount.  Economically, the strategy would reduce costs of both purchasing raw materials and disposing of spent still bottoms.  (The amount of acetone used is assumed to be proportional to the amount of gelcoat and resin used.)  Environmental risk will decrease from present practice because the amount of styrene emitted into the atmosphere would be decreased and hazardous waste would be decreased. Human health risks would be the same since workers would still be exposed to the same hazardous materials.

 

II.b. Procedures for reducing the amount of clabbered resin that becomes waste will be implemented.  Economically, the strategy would reduce costs of both purchasing raw materials and disposing of clabbered resin.  The environmental risk will decrease from present practice because the amount of styrene emitted into the atmosphere will be decreased and hazardous waste will be decreased. Human health risks are also expected to be the same since workers will be exposed to the same hazardous materials.

 

II.c. Elimination of the hazardous waste characteristics the clabbered resin and gelcoat will be accomplished.  Both materials consist primarily of resin and gelcoat materials with unreacted styrene.  This waste stream can be treated with catalyst to cross-link the unreacted styrene.  During this process, small amounts of styrene and acetone may also be emitted into the atmosphere.  However, these emissions have already been accounted for in the authorizations obtained for air emissions from the Texas Commission on Environmental Quality (TCEQ).  The treatment of these waste streams will occur in closed containers, and a waste treatment permit will not be required to implement this waste reduction strategy.

 

Technically, this strategy is simple to implement and has been shown to be effective in eliminating the hazardous characteristics of the still bottoms and other clabbered resin.  Economically, the strategy will eliminate the cost of hazardous waste disposal.  Environmental risk would decrease from present practice because there would no longer be a stream of hazardous waste from the plant.  A slight increase in styrene air emissions will occur, but the risk of these emissions has already been considered in the existing air permit. Human health risks would be the same since workers would still be exposed to the same hazardous materials used in resin production.

 

D.        Reduction Anticipated

 

I.a. and I.b. - Year 2008 usage of acetone was over 22 tons.  It is estimated that the final results of this source reduction strategy will reduce the usage of acetone by a total of approximately 10% versus year 2008 usage.  Due to increasing production rates, the actual lbs of acetone used may increase.  However, the proportion of acetone required for a given amount of resin or gelcoat is expected to decrease.  Recycling of acetone is expected to eliminate this hazardous waste stream.

 

II.a. The reduction in usage of resin and gelcoat needed to produce the same amount of product will be related to the reduction of overspray.  The emission factors for controlled spraying versus non-controlled spraying predict that styrene emissions from resin spraying operations will be reduced by 23% and that styrene emissions from gelcoat spraying operations will be reduced by 27%.  If it is conservatively assumed that the reduction in gelcoat and resin usage corresponds to one-half of the emissions reduction, the resin and gelcoat usage from spraying operations will be reduced by 11.5% and 13.5%, respectively.  Due to increasing production rates, the actual lbs of resin or gelcoat used may increase.  However, the proportion of resin or gelcoat needed to create a given amount of product is expected to decrease.

 

II.b.and c The increased utilization of clabbered resins will reduce the amount of waste resins produced.  It is estimated that better usage techniques will reduce this source of waste by approximately one-third.  Polymerization of the resulting waste will completely eliminate this routinely-generated hazardous waste stream from the plant.  This is a reduction of approximately 2400 lb based on year 2008 waste data.


 

E.        Implementation Schedule

 

I.a. and I.b.  Partial implementation is already in progress.  Training and implementation of plan is expected to be complete no later than December 2010.

 

II.a.  January 2010 - Partial implementation is already in progress.  Spray guns are already going through testing and employees are currently being trained in the use of proper spray techniques.  Full implementation including installation of mold flanges is expected to be complete no later than December 2010.

 

II.b.  January 2010 -  Investigation of methods to improve utilization are underway with a goal of placing new techniques into practice by December 2010.

 

II.c.  January 2010 Clabbered resins and gelcoats are routinely treated to polymerize the waste and eliminate the hazardous properties of the material.  Treatment of all waste streams and elimination of hazardous waste is expected to be accomplished by December 2010.

 

F.         Facility Goals

 

The goal for this plant is to eliminate all routinely-generated hazardous waste by December 2010.  Sources of air emission and non-hazardous waste will also be reduced as a side benefit of this plan.

 

G.        Employee Awareness and Training

 

1.         All employees have been provided with a copy of the Corporate Environmental Policy.

 

2.         The manager of each department that generates hazardous waste, as well as the     employees directly associated with hazardous waste generation will be given        instruction in the following areas:

 

 

I.          Pollutant Shift to Another Media

 

Polymerization of clabbered resin will convert all hazardous waste to non-hazardous waste. 

 

Biography 

Karen M. Bullard, P.E. is an Engineering Partner and the President of Bullard Environmental Consulting, Inc.   She has over 15 years experience in environmental engineering, compliance, and permitting.  She worked for the Texas Commission on Environmental Quality (TCEQ) for four years as an Air Permit Specialist in the Coatings and Combustion Section, where she developed a thorough understanding of the governmental procedures and policies in Texas.    Karen has a Bachelors of Science Degree in Chemical Engineering from the University of Texas at Austin.

 

Karen M. Bullard, P.E. No. 88449

Final Edition Completed June 29, 2008 from Previously Composed Material

 
 


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