1 lec6wastemin&pollutionprevention92117lec

1Lec 6: Waste Min & Pollution Prevention
9/21/17
Lec 6: Waste Min & Pollution Prevention 2
9/21/17
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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9/21/17
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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9/21/17
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.
9/21/17
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.
9/21/17
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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.
8
9/21/17
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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9/21/17
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.
9/21/17
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.
9/21/17
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.
9/21/17

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 leadsto
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.
9/21/17
9/21/17

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.
9/21/17

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.
16
9/21/17
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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9/21/17
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.
9/21/17
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

9/21/17
requirements for many wastes simpler.
9/21/17
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.
9/21/17
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.
9/21/17
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.
9/21/17
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.
9/21/17

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.
9/21/17
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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