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Hazardous Wasfe Reduction Checklisf & Assessmenf Manual for Pesticide Formulators

CALIFORNIA DEPARTMENT OF HEALTH SERVICES

TOXIC SUBSTANCES CONTROL PROGRAM

ALTERNATIVE TECHNOLOGY DIVISION

TECHNOLOGY CLEARINGHOUSE UNIT

ACKNOWLEDGEMENTS

This document was prepared by Daniel Q. Garza, under the direction of David C. Hartley, M.P.H., Kim Wilhelm, P.E. and James T. Allen, Ph.D., of the California Department of Health Services, Toxic Substances Control Program, Altemative Technology Division, Technology Clearinghouse Unit. The Department expresses appreciation to Environ- mental Science and Engineering, Inc. for preparation of the Waste Audit Study for the Pesticide Formulating Industry. Additionally, the Department would like to thank Dave Lewis, FMC Corporation, and George Donaldson, Wilbur-Ellis for their review of this document. Designed by Merle Rae Hopkins, Bruce Clarke and Nancy S. Ostrom.

DlSCLAlMER

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 en- dorsement of -such products or services.

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TABLE OF CONTENTS

I NTRO D UCTlO N

PESTICIDE FORMULATORS CHECKLIST

SOURCE REDUCTION Employee Training Laboratory Practices Material Storage and Handling Storage

RESOURCE RECOVERY AND RECYCLING Reuse Reclamation

TREATMENT A1 TERNA TlVES Bench Scale Treatment AItematives

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EVALUATION OF WASTE REDUCTION OPTIONS

ECONOMIC WORKSHEET

APPENDIX A: TABLES OF WASTE REDUCTION OPPORTUNITIES

FURTHER INFORMATION

1

2

2 2 3 4

6

8 8 8

9 9

10

1 1

17

18

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TABLES AND FIGURES

Table I : How do You Store Your Hazardous Waste or Materials Table 2: Source Reduction Options Evaluation Table 3: Recycling and Resource Recovery Options Table 4: Treatment Alternufives Options Table 5: Annual Operating Cost Savings Table A I : Waste Reduction Opportunities

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13 15 16 17

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INTRODUCTION Waste reduction has become an important component of hazardous waste management. Instead of trying to develop new technologies to treat the hazardous wastes being gener- ated, emphasis must now be placed on preventing the generation of these wastes. Waste reduction involves a three part strategy; 1) source reduction, 2) resource recovery and recycling, and 3) altemative treatment methods, which are listed in the preferred hierarchy. These can involve simple and easily implemented techniques or complex and state-of-the- art technologies. The extent to which you implement a hazardous waste reduction program wholly depends upon your plant’s particular operational procedures and management commitment.

Waste reduction can help you achieve compliance with regulatory requirements and lessen the time spent with government inspectors. In some instances it might even allow small quantity generators to drop out of the regulatory loop altogether. Using waste reduction techniques, you may also be able to reduce fees and fines assessed by the local sewer district by reducing the loads on their treatment systems.

Therefore to assist Califomia’s industry, the Department of Health Services has started to develop industry specific waste reduction documents. Currently there are two documents available describing waste reduction techniques for pesticide formulators. The waste audit study for pesticide formulators and a waste reduction fact sheet for pesticide formulators. This manual is a continuance of this effort.

This checklist and assessment manual was developed by the Technology Clearinghouse of the Altemative Technology Section, to aid pesticide formulators in evaluating their plants for waste reduction opportunities and is intended to stimulate your thinking about waste reduction options within your operations.

The manual contains three sections. The first section is a checklist to aid you when con- ducting an audit of your facility. Tables summarizing the waste reduction options dis- cussed in the checklist are contained in Appendix A. (NOTE: The waste reduction options in this checklist are only those found by the authors, you may develop your own which you may want to explore. This list is not all inclusive.) Completing the tables as you read through the checklist will allow you to evaluate an option’s potential for implementation into your shop. Implementation Potential (IP) can be rated as “High, Medium, Low, or None”; the ratings are designated by you. They will be used in Section 2 of this manual. Section 2 is comprised of tables listing the waste reduction options from the checklist and four areas for evaluation;

Waste Reduction Hierarchy (WRH) Implementation Potential

‘Type of Option” “Cost of Option”.

Each of these areas have different point values which will be explained in section 2. The total scores will allow you to prioritize each option. The final section contains an econom- ics worksheet to help you decide the options most cost effective for implementation

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PESTICIDE FORMULATORS CHECKLIST a

Employee Training Training employees in proper storage and handling procedures for hazardous waste will help you reduce your waste generation. It is also required by regulation.

1. Are employees trained in the proper proceduresfor handling hazardous wastes?

OYes U N O

d Personnel properly trained to handle hazardous wastes will reduce the amount of spills and employee accidents.

2. Are employees aware of haz- ardous waste reduction?

OYes U N O

3. Are job functions defined for each employee?

0 Yes 0 No

4.Doywgiveemployeesrnanuals thatoutlinespecifc methodsfor handling thelypeof materialsat youplant?

OYes UNO

SOURCE REDUCTION Source reduction techniques are usually the easiest and cheapest methods of waste reduction. They consist mainly of improving procedures and good housekeeping.

d Introducing employees to waste reduction con- cepts will allow them to develop, innovative waste reduction ideas that may be implemented into your operations.

b' Identifying specific duties for personnel can help you reduce the incidence of employees handling hazardous waste without the proper training. Com- municate to the employees what their job entails and make sure they understand what is expected of them.

v' Manuals or material safety data sheets can give employees valuable information on the materials they are handling. This will improve worker safety and reduce chances of improper handling. If no manuals are availabe utilize your safety program to distribute information.

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5. Do you have good house- keeping procedures in place?

0 Yes 17 No

6. Are incentive programs offered to employees to pro- mote good housekeeping practices?

0 Yes 17 No

7. Do new employees receive training in waste reduction prior to beginning work?

Yes 0 No

8. Are your firm and your em- ployees aware of the different regulations that affect the pesticide industry?

Yes 17 No

d The easiest and least costly waste reduction options involve good housekeeping.

d Incentive programs encourage employees to follow good housekeeping procedures. Incentive programs do not have to be monetary programs, but can involve other items such as dinners or gifts.

d Training new employees in hazardous waste management is required. Waste reduction, to include good housekeeping procedures, should be included in this training program.

d Many Federal, State and local regulations govem the pesticide industry and the wastes it produces. Regulations cover the storage, transport, production, and handling of pesticides. To find out about the various laws, contact your regional DHS office. (Phone numbers are listed in the back of the manual.)

Laboratory Practices If you have a laboratory onsite it can be another source of hazardous waste generation within the pesticide formulating industry.

1. Do you conduct laboratory tests of materials on a regular basis?

OYes 0 No

d Regular testing will allow you to quantify and qualify the types of hazardous materials present in the workplace, and establish the proper handling and storage procedures.

2. Are laboratory wastes handled with the other wastes from the plant?

UYes U N O

d If both lab and plant wastes are the same they can be handled together, but if they are not the same they must be handled and stored in separate contain- ers.

3

Material Storage and Handling Many wastes are generated by degradation of raw materials due to prolonged storage, improper storagehandling and by spills.

1. Are liquid materials trans- porfed using pumps and pip- ing? transfer. Dyes U N O

d Transporting liquids using pipes can help you reduce the amount of chemicals spilled during

2. Do you transport materials in bulk containers?

OYes 0 No

d Using bulk containers can reduce the amount of 55 gallon drums that you need for storing or trans- porting materials.

3. Are the materiais stored close to the process areas where they are used?

OYes U N O

d Storing materials near the process areas where they are used will reduce the distance you need to transport them and therefore reduce your handling and spillage.

4. Do you have procedures in place to handle leaks or spills?

OYes U N O

d Initiating procedures for emergency situations (which are required by regulation) can help you reduce wastes generated by the cleanup of spills. Keep the plan available and educate your employees in its use.

5. Do you inspect raw materials before you accept them?

d If you do not inspect materials when they are delivered you may inadvertently accept materials in

OYes U N O containers that are unsuitable and may leak before you use them.

6. Do you use a “first-in first-out” material usage policy?

OYes U N O

d A “first-in first-out” policy ensures that materials received first are the ones that are used first. This will prevent materials from exceeding their shelf life and requiring disposal as hazardous waste.

7. Do you conduct periodic inpections of materials in storage?

OYes U N O

d Conducting periodic inventories will allow you to identify materials that are near the end of their shelf life, and also check for containers which may leak in the near future.

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8. Are material inventories computerized?

0 Yes 0 No

9. Do you limit raw material access?

0 Yes 0 No

10. Do you track the usage of raw materials?

0 Yes 0 No

1 1. Do y ~ u have safeguards in place to prevent spilled materi- als from spreading?

0 Yes 0 No

12. Do you have set procedures for handling spills?

0 Yes 0 No

13. Do you conduct practice drills for major spills?

OYes ONo

d Computerizing your inventory will allow you to keep track of the materials you use and how much is remaining. This will allow you to keep the material levels at a point where you use up your materials just as new materials are arriving. Personal comput- ers to allow you to computerize your inventory are relatively inexpensive.

d Limiting access to raw materials to designated personnel will help you reduce the amount of raw materials wasted.

d Computerizing your inventory will allow you to keep track of the materials you use and how much is remaining. This will allow you to keep the material levels at a point where you use up your materials just as new materials are arriving. Personal comput- ers to allow you to computerize your inventory are relatively inexpensive.

d Use of a work order approach can help you track the usage of raw materials and production, by increasing interaction and communication between production personnel and inventory control person- nel. It will also help identify processes which may be wasteful.

d Spill containment around storage mas will minimize the spread of any spilled material. This is also required by Federal and State regulations.

d A spill or emergency response plan is required by Federal and State regulations, but beyond being a requirement, a thorough spill plan will help you effectively deal with emergency situations, protect- ing your employees and minimizing damage to your plant. Periodic drills can improve the readiness and effectiveness of employees in dealing with emer- gency situations. You can reduce wastes generated by spills and their cleanup with a quick response to a spill.

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14. Do stored solid materials generate dust in the storage areas?

0 Yes 0 No

15. Are materials stored in reus- able containers?

O Y e s UNO

16. Are hazardous materials stored separately from nonhaz- ardous materials?

O Y e s U N O

17. Do you segregate your waste streams?

O Y e s U N O

Storage You may generate additional hazardous waste if you store raw materials or hazardous wastes improperly. Store hazardous wastes in covered containers. A locked, covered, indoor area with a concrete floor and curbs for spill containment is ideal for storage. Inspect the storage area ofen, at least once a week to look for leaky containers or improper storage. Some of these suggestions are also required by law.

d Dust f” solid stored materials may contaminate other stored materials which will then have to be disposed of as hazardous waste. Therefore use a dust recovery system if this is a problem in the storage areas.

d Storing materials in reusable containers will d o w you to return the empty container to the supplier and reduce the amount of waste you must dispose. Ensure single-trip containen and non- reusable containers are handled according to the regulations.

Storing hazardous and nonhazardous materials separately will reduce the risk of waste being gener- ated due to a hazardous waste leaking and contami- nating a nonhazardous waste. Also keep materials and wastes stored away from high traffic areas to reduce the chance of accidental damage or tipping.

J Segregation of your waste streams will make them more amenable to recycling and resource recovery techniques.

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’ TABLE 1 : How do you store your hazardous waste or materials?

Hazardous Storage Wastes

Raw Materials Comments

Indoors

outdoors

Covered

Surface

Concrete

Asphalt

Dirt or Gravel

Locked

Unlocked

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

Covered storage is important be- cause rain water can increase your waste volumes or contami- nate raw materials. Also, expo- sure to sunlight can change the characteristics of raw materials or dangerously increase the pressure inside sealed contain- ers. You should also keep individual containers covered to prevent evaporation and spills.

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

Without secure storage facilities unauthorized persons may enter the storage area and harm them- selves or spill the waste, or even dump their waste into your containers.

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RESOURCE RECOVERY AND RECYCLING In the context of waste reduction, resource recovery and recycling usually involve applying “treatment” to a waste stream to recover a beneficial “use”. But this is not always true. If a waste stream can be used as a feedstock for a different process without first being treated, it is then considered resource recovery. The different process does not have to be within the same industry, it can be in an altogether different industry. There are two categories which describe recycling and resource recovery, namely use/reuse and reclamation. Both of these produce a usable substance from a waste.

Reuse Reuse of waste streams in different processes can help you reduce the amount of hazardous waste needing disposal.

1. Do you use the rinsing/flushing media fromwashing formulating equipmentasmake-upforsub quent pesticide formulations?

OYes ONo

2. Do you use the dust collected by vacuum systems in new for- mulations?

OYes U N O

1. Do you collect floor wash water or stormwater runoff from process areas?

OYes UNO

Wade

* * * . .

d Often solvents or wastewater from equipment washing can be used in formulations without treatment. This is a possibility if they do not contain any contaminants.

d Dust collected by vacuum systems dedicated to certain formulation areas can be reused in subse- quent formulations without undergoing treatment.

Reclamation Reclamation is using a waste stream after you have applied a treatment to it. For example, collecting wash water and treating it to reuse somewhere else in the process.

d Collected wash water or stormwater runoff can be treated and reused as floor wash water or equip- ment rinse water. This may be less costly than disposing of them as hazardous waste.

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2. Do you generate empty pes- ticide ingredient containers?

0 Yes 17 No

3. Are empty pesticide ingredi- ent containers cleaned for reuse or waste disposal?

0 Yes 0 No

4. Do you collect wastewater used for triple rinsing empty pesticide containers?

0 Yes 0 No

d Containers which previously contained pesticide ingredients must be disposed of as hazardous waste unless they are first triple rinsed, which would then allow for disposal as nonhazardous waste, or for sale to a scrap dealer.

d Containers which are not cleaned may be re- turned to the pesticide supplier for refilling with the same pesticide, or used to store and dispose of other wastes such as pesticide contaminated dusts and empty paper bags and cartons. The wastes to be stored in the previously used drums must be com- patible with the former drum contents.

d The collected wastewater may also be treated and reused as floor wash water.

TREATMENT ALTERNATIVES Wastewater treatment minimizes waste by reducing the toxicity of the wastewater. Treating the wastewater can also facilitate its reuse for formulation applications, mixing equipment rinsing, and floor washing.

Bench Scale Testing of samples on a bench-scale basis can help you reduce your waste from the labora- tory.

1. Do you perform bench-scale treatability tests on wastes before you attempt to treat them on a full scale basis?

d Performing treatability bench scale tests will reduce the amount of waste that must be disposed if your treatment test does not work.

0 Yes 0 No

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2. Do you attempt to reuse treated wastewaters elsewhere in your process before dis- charging to the local sewer district?

0 Yes 0 No

d If you cannot treat the wastewater to levels that make them nonhazardous, investigate the possibility of using the treated water elsewhere in the process, such as in formulation or for washwater. Reducing the volume that is discharged can save you the cost of disposal.

Treatment Alternatives There are currently many treatment methods available for treating your waste. To find the least costly method requires knowledge of your wastestreams and the processes which produce them and also the capabilities of your current treatment system. Consult with your suppliers or trade association.

1. Do you investigate the available technology for ing your wastes?

0 Yes 0 No

latest treat-

d There are currently many technologies available for treatment of your waste streams. Some of the technologies are listed below.

* chemical precipitation * hydrolysis resin adsorption

biological treatment activated carbon

chemical oxidation

steam/air stripping

absorption

For more information on these technologies, please refer to the Third Biennial Report on treatment Technology for Recycling and Treatment of Hazardous Wastes (DHS, 1986), it is available from the Technology Clearinghouse

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EVALUATION OF WASTE REDUCTION OPTIONS

After completing the checklist and identifying your waste reduction options, you can use the following tables to evaluate your options. Each option will be evaluated in four areas; 1) Waste Reduction Hierarchy (WRH), 2) Implementation Potential (IP), 3) type of option, and 4) cost of option.

1. The Waste Reduction Hierarchy consists of the following, which are in the preferred order, 1) source reduction, 2) resource recovery and recycling, and 3) treatment. (Note: The Waste Reduction Fact Sheet for Pesticide Formulators can help you identify an op- tion’s place within the waste reduction hierarchy.)

SR = Source Reduction = 5 pts. RR= Resource Recovery = 4pts. 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.

2. The Implementation Potential is the chance that you believe this option has of being implemented in your shop.

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

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

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 breakdowm is necessary. You may want to establish your own classes to reflect your particular shop practices. The four classes are:

P/p = Policy or Procedural Change = 4 pts. PM = Process Modification EM = Equipment Modification = 2 pts. NE = New Equipment

= 3 pts.

= 1 pt.

4. The “Cost of option” refers to what you feel it will cost to implement this waste reduc- tion option.

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

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Waste Reduction Technique

Example: Evaluate the following two options to determine the Waste Reduction option that would be the most attractive.

WRH' IP'

Scored H (4) by M (3)

authors L(2) N (0)

1) First-in first-out material usage policy. 2) Install Chemical Oxidation Treatment Process.

,/,, TABLE 2: Source Reduction Options

1. First-in First-out Material Policy I SR (5) I H (4)

Option Total

After totaling the scores you can see that implementing a first-in first-out policy should be implemented before installing a chemical oxidation unit. The next step is further evaluation of the economic feasibility and associated payback period using the worksheet in section IV.

After evaluating each option in the four areas, add up their scores and complete the table. After completion, a prioritization or order in which to further explore the options should result.

This is a preliminary analysis to quickly identify usable options for your shop. A more detailed cost study of each option should be conducted to see exactly how the option will affect your shop financially and the option's payback period. The EPA Waste Minimiza- tion Opportunity Assessment Manual' can help you complete a more through examination into costs.

The above classes and point values for each area were determined by the authors; they are not hard and fast rules, only guidelines. You can develop additional options unique to your operation and score them accordingly.

USEPA, April 1988. The EPA Manual for Waste Minim'zation Opportunity Assessments. EPA/600/2-88- 025. Environmental Protection Agency, Hazardous Waste Engineering Research Laboratory, Cincinnati, OH.

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TABLE 2: Source Reduction Options

Waste Reduction Technique

Source Reduction

Employee training: employee training and

job fimctions identified distribute manuals to

good housekeeping in place incentive programs

s aware of regulations

awareness of waste reduction

employees

Laboratory practices: laboratory testing handling laboratory wastes

Material Storage: use pumps/piping store materials close to work areas spill procedures outlined inspect raw materials weekly first-in first-out policy periodic inspections

WRH'

Scored by

authors

* WRH = Waste Reduction Hierarchy * IP = Implementation Potential

Option Total

13

7-

L'

7

1

e

7” TABLE 2: Source Reduction Options (Continued)

Waste Reduction Technique

Material Handling: computerized material

limit access to materials track material usage conduct emergency drills dust recovery system. reusable containers material segregation hazardous waste segregatic

inventory

WRH’

Scored by

authors

* WRH = Waste Reduction Hierarchy * IP = Implementation Potential

Option Total

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,/,, TABLE 3: Recycling and Resource Recovery Options

Waste Reduction Technique

Recycling and Resource Recovery

Reuse/Reclamation: rinsing/flushing media

reuse dust collected collect washwaterl

triple rinse empty containers reuse rinse water

reused

stormwater

WRH'

Scored by

authors

* WRH = Waste Reduction Hierarchy * IP = Implementation Potential

Option Total

6 i

I+

1

L i

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TABLE 5: Treatment Alternative Options

Waste Reduction Technique

Treatment Alternatives

Bench-scale treatability studies: render wastes nonhazardous allow reuse of treated water investigate latest treatment technology

WRH"

Scored bY

ElUthOrS

* WRH = Waste Reduction Hierarchy * IP = Implementation Potential

Option Total

16

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Material or Service

Water

ECONOMIC WORKSHEET

Estimated cost Savings per unit

(units) (1) ($/unit) (2)

This worksheet can be used to calculate rough estimtes of projected costs, savings, and payback periods associated with each waste reduction option. These worksheets do not take into account amoritization, depreciation, or tax factors.

Waste Reduction Option: Capital Costs

Equipment Payback period =

Capital Investment Installation

Annual Operating Cost Savings Utilities Production Down Time Construction Materials

Other

Implementation Costs

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

Sewer I I Power Chemicals

Waste Handling

FeesPenalties

Labor I I ~~ ~~ ~

Misc. Total Annual Savings:

Total Savings (1) x (2)

n 3 1

i!

P-

i f L

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APPENDIX A: TABLE OF WASTE REDUCTION OPPORTUNITIES

,/,, TABLE Al: Waste Reduction Opportunities

Waste Reduction Techniques

Source Reduction Employee training:

employee training and awareness of waste reduction job functions identified distribute manuals to employees

e good housekeeping in place incentive programs . aware of regulations

Laboratory practices: e laboratory testing

handling laboratory wastes

Material storage and handling: e use pumps/piping e store materials close to

a spill procedures e inspect raw materials

work areas

Currently Used

(Yes/No)

implementation Potential

High Medium Low None

,/,, TABLE A1 : Waste Reduction Opportunities (Continued)

Waste Reduction Techniques

Source Reduction Continued

Material storage and handling:

first-in first-out policy periodic inspections computerized material

limit access to materials track material usage conduct drills dust recovery system reusable containers material segregation hazardous waste

inventory

segregation

Recycling and Recource Recovery

Reuse/Reclamation: rinsing/flushing media

reuse dust collected collect washwater/

triple rinse empty

reuse rinse water

reused

stormwater

containers

Currently Used

WWNo)

Implementation Potential

High Medium low None

h P

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TABLE A1 : Waste Reduction Opportunities (Continued)

Waste Reduction Techniques

Treatment Alternatives Bench-scale treatability studies: . renderwastes

nonhazardous . allow reuse of treated water investigate latest treatment technology

Currently Used

CleslNo)

implementation Potential

High Medium low None

FURTHER INFORMATION For more information, contact the Technology Clearinghouse in the Alternative Technology Division at:

Department of Health Services Toxics Substances Control Program Altemative Technology Division 714/744 P Street P.O. Box 942732 Sacramento, CA 94234-7320 (916) 324-1807

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

Region 1 - Sacramento (916) 855-7700

Region 2 - Berkeley (415) 540-2122 Region 3 - Burbank (8 18) 567-3000 Region 4 - Long Beach (213) 590-4868

Fresno (209) 445-5938

To get an EPA ID number, call:

DHS, Toxics Program, Program and Administrative Support Division (916) 324-1781

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