Minnesota Pollution Control Agency (MPCA)
US Filter Proposal
U.S. Filter Recovery Services, Inc.
2430 Rose Place
Telephone 612-638-1300
Roseville, MN 55113
Facsimile 612-633-5074
March 6, 1996
Mr. Joseph P. Carruth Engineer,
Permit and Review Unit Regulatory Compliance Section Hazardous Waste
Division
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-3898
Dear Joe:
Enclosed is our revised Project XL Permit application. The changes we have made include:
· Added estimated environmental impact numbers for both the acid recovery project and the water re-use project;
· More detailed project descriptions (including basic schematics); and
· Added proposed timing for project execution. As we discussed in our meeting, Project #2 "Product Stewardship/Life-cycle Management" was not changed.
We look forward to moving ahead with this project. If you have any questions or require further information, please contact Greg Weisjahn or me.
Yours truly,
Greg E. Norgaard, P.E. Vice President and General Manager GEN/ll
Enclosures
cc: Andrew Ronchak, MPCA Raymond Bissonnette,
MPCA Draft Beyond Compliance Permit U.S. Filter Recovery Services, Inc.
Background
"Beyond Compliance" is Minnesota's proposal to conduct a "State of Minnesota"
project under the "Project XL" priority action item outlined in President
Clinton's and Vice President Gore's March 16, 1995, document titled,
Reinventing Environmental Regulation and noticed in the May 23, 1995
Federal Register. "Beyond Compliance" provides an exciting opportunity
to change the way we conduct our business, resulting in a " cleaner,
cheaper, and smarter" approach to environmental regulation. This innovative
approach will be beneficial for the following reasons:
· Environmental Results
· Cost Savings and Paperwork Reduction
· Stakeholder Support
· Innovative/Multi-Media Pollution Prevention
· Transferability
· Feasibility
· Monitoring, Reporting, and Evaluation
The incentive for a company to participate in "Beyond Compliance" would primarily be increased operating flexibility in adding storage or process equipment. The regulatory flexibility will result in resource savings and ability to quickly react to changing market conditions. The resource savings would result in less paperwork requirement, through combining and streamlining regulations. Secondly, resource savings would result from eliminating the need for obtaining permit modifications. Another benefit of this approach would be to give the company the flexibility to determine how to best implement changes at the source without increasing environmental pollution above an agreed-upon limit.
As a result of less regulatory oversight and the streamlining of procedures, the MPCA and EPA would save resources while obtaining a significant improvement in the quality of the environment. The primary source savings would be in elimination of previously required reviews and actions on reports and applications. Assuming success in the early pilots, as the "Beyond Compliance" multi-media approach is used on a larger scale, the MPCA and EPA should also begin to see resource savings through the combining of overlapping programs.
U.S. Filter Recovery Service's "Beyond Compliance" permit will focus on incorporating the "Beyond Compliance" philosophy into their RCRA Part B Permit, with the intent of reducing the amount of chemicals purchased and to facilitate the recovery of chemicals for all parties within the bubble of the pilot project.
Pursuant to the provisions of the MPCA "Beyond Compliance
Pilot Program" granted under the authority of the EPA, permission is
hereby granted to:
U.S. Filter Recovery Services, Inc.
2430 Rose Place
Roseville, MN 55113
for participating in MPCA's "Beyond Compliance" program. While the pilot project is in effect, MPCA enforcement action will not be taken against persons who manage hazardous waste in compliance with the specified pilot project requirements, even though persons may not be in compliance with the hazardous waste management requirements in Minn. Rules ch. 7045. Hazardous waste not managed in compliance with the pilot project must be managed in accordance with all applicable hazardous waste management requirements in Minn. Rules ch. 7045.
Concepts used by USFRS in "Beyond Compliance" include: product stewardship, product life-cycle management, and eco-industrial park to facilitate a reduction in chemical purchases and to maximize the recovery of chemicals. By employing these concepts this allows companies other than USFRS using these chemicals to indirectly participate in the "Beyond Compliance" program. With this indirect involvement of other companies, this will make "Beyond Compliance" more accessible to companies and make participation available for small business.
Project #1
RCRA Permit Flexibility for Recovery Projects
Introduction
USFRS would like to have the ability to implement RCRA-regulated activities
associated with new recycling operations without having to go through
a "major" permit modification. In return, USFRS will:
1. Pursue only those projects under this project which
show measurable, definable recovery.
2. Comply with all applicable hazardous waste regulations including:
· Basic Tank/Process Design
· Secondary Containment
· Inspection of Treatment/Recovery/Storage Areas
· Compatibility
· Aisle Space
3. Remain subject to all other current enforcement
authority over all aspects of the operation, regardless of "Beyond Compliance"
permit status.
4. Incorporate any modifications into the RCRA permit at the next renewal.
Specific Projects
1. Acid Recovery:
USFRS hereby requests the authority to install and operate a hydrochloric
acid recovery system under Project XL. The technology employed is vacuum
distillation and is described in Appendix A. Inbound waste acid (D002
hazardous waste) destined for recycling would be stored in one of two
6,000 gallon storage tanks and then routed to the recovery system. Under
ordinary circumstances, the waste acid storage tanks would require a
major modification to our Part B Permit. We are requested that these
tanks be considered under Project XL, incorporating the stipulations
indicated above. Additionally, to encourage generator participation
in Project XL, participants should be subject to a lesser level of regulation
for these specific recovery streams under the pilot program. USFRS will
provide the waste tracking data to the agency as a part of the verification
process.
Benefits to USFRS
· Time: major permit modifications take a long time until completion
· Staff time: the time it takes to modify the permit is significant
· Fees: it costs approximately $12,000 to do a major modification
Benefits to the Environment
· Reduced "importation" and usage of virgin HC1 (due to recovery)
· Reduced usage of neutralization chemicals
· Closed loop system (metals, acid and water are all recovered)
· Lower acid concentration for safer transport and handling
· Reduced discharge to the POTW (hydraulic, metal and salt)
· Pollution prevention is available even to the smallest generator
· Sufficient regulatory control is still maintained
Estimated Environmental Impact If the system is operated at full capacity
(250 gph, 7 days/wk., 24 hrs./day, 10% downtime), the following environmental
impact could be expected:
· Recover 1.54 million pounds of HC1/year
· Save 498,800 gal/year of purchased acid (20 degree Be' HC1)
· Save 1.69 million pounds/year of purchased neutralization chemical
· Recover 263,000 pounds/year of heavy metal
· Prevent 2.72 million lbs/year of salt from being sewered
· Recover 883,000 gal/year of distilled water
Verification of Beyond Compliance
Results The success of this project would be gauged by
USFRS tracking and reporting the following data:
· Pounds of recovered material and quality
· Volume of incoming waste
· Estimate of cost and time savings in permit modifications
Project Timing
USFRS proposes to install and commence operating the proposed storage
tanks on or before July 1, 1996.
2. Water Re-use
USFRS hereby requests the authority to install and operate the equipment
necessary to regenerate spent ion exchange resins used for water re-use.
These resins are typically classified as F006 hazardous waste. Under
its existing permit, USFRS operates a large regeneration pad, currently
processing several thousand cubic feet/month strictly for metals and
cyanide removal/recovery. The proposed system would expand these capabilities
to enable our clients to use ion exchange technology to re-use water
from "hazardous waste" rinsing operations. The system is described more
thoroughly in Appendix B. Under ordinary circumstances, the systems
to store and regenerate these resins would require a major modification
to our Part B Permit. We are requesting that this system be considered
under Project XL, incorporating the stipulations indicated above. Additionally,
to encourage generator participation in Project XL, participants should
be subject to a lesser level of regulation for these specific recovery
streams under the pilot program. USFRS will provide the waste tracking
data to the agency as a part of the verification process.
Benefits to USFRS
· Time: major permit modifications take a long time until completion
· Staff time: the time it takes to modify the permit is significant
· Fees: it costs approximately $12,000 to do a major modification
Benefits to the Environment
· Total amount of water consumed by water re-use clients is significantly
reduced.
· Total amount of wastewater discharged by water re-use clients is significantly
reduced.
· Total cation resin usage (therefore hazardous waste generation) is
reduced significantly due to elimination of water hardness (calcium)
in reused stream
· Total hazardous waste generation from the regeneration process is
reduced significantly due to the elimination of calcium hardness
· The recycled water is generally of higher quality (better rinsing,
fewer rejects, therefore less waste)
· Large reduction in salt load to POTW
· Pollution prevention is available even to the smallest generator
· Sufficient regulatory control is still maintained
Estimated Environmental Impact
If the system is operated at full proposed capacity and the average
client is able to reuse 80% of their water (influent water at 18 grains
total hardness), the following environmental impact could be expected:
· Reduce sewer discharge by 31.4 million gal/year
· Reduce water usage by 31.4 million gal/year
· Reduce hazardous waste generation (cation resin) by 630,000 pounds/year
· Prevent 151.400 lbs/year of salt from being sewered
Verification of Beyond Compliance Results
The success of this project would be gauged by USFRS tracking and reporting
the following data:
· Volume of inbound water re-use resin
· Estimate of water savings, sewer savings, hazardous waste reduction
and salt discharge reduction
· Estimate of cost and time savings in permit modifications
Project Timing
USFRS proposes to install and commence operating the proposed storage
tanks on or before July 1, 1996.
Project #2
Product Stewardship
Life-cycle Management Product stewardship is the second project USFRS
proposes for the pilot project. This project would include ammoniacal
and cupric chloride etchants and other similar chemicals that USFRS
can manage the life-cycle of the product. These etchants are managed
as by-products; however, the paperwork involved to manage these materials
is as cumbersome as manifesting hazardous waste. USFRS proposed to take
on the responsibility of tracking these wastes and reporting to MPCA
the amount received from each generator. USFRS would have blanket approval
of all material that fits into the product stewardship program. For
example, the MPCA would approve that ammoniacal etchants and their management
by USFRS fit into the product stewardship category and that USFRS can
manage all ammoniacal etchants under this program. This would reduce
the paperwork for the generator, USFRS, and the state. USFRS will comply
with the following hazardous waste regulations:
· Basic Tank/Process Design
· Secondary Containment
· Inspection of Treatment/Recovery/Storage Areas
· Compatibility
· Aisle Space
MCPA will maintain its existing enforcement authority over all aspects of the operation, regardless of "Beyond Compliance" permit status. In addition, any modification will become part of the RCRA permit at the next renewal.
Benefits to USFRS
1. Paperwork reduction
2. Increased recycling
3. Uniformity in handling inbound waste products
Benefits to Environment
1. Encourage recycling (compared to existing system)
2. Assured proper management of chemicals throughout their life-cycle
3. Paperwork reduction
4. Pollution prevention is available even to the smallest generator
5. Minimize metals discharged to sewer
6. Eliminate treatment chemicals used by clients
7. Copper and ammonia are recovered
Verification
1. Documentation of recovery, track pounds of recovered
material and quality
2. Track volume of incoming waste
3. Compare data between amount recovered to amount of waste generation
4. Track chemical savings due to beneficial recycling
· Note reduction in virgin chemical purchases
· Note reduction in treatment chemical purchases
5. Track the cost savings due to recovery
6. Track the cost savings in permitting and regulatory compliance
APPENDIX A
ACID RECOVERY SYSTEM DESCRIPTION
A. PROGRAM DESCRIPTION Hydrochloric acid use and waste generation in
the metal finishing industry : Hydrochloric acid (HC1) is used in the
electroplating and metal finishing industries as a "pickling" liquid.
That is, as a preparatory treatment to various metal plating and conversion
coating processes. It is usually made up at 16-20% (by weight) strength,
and a process bath will last anywhere from 2-10 weeks. During the life
of the pickling bath, metal ions from the parts are etched or dissociate
from the base metals. Thus the bath ends up with part per million to
part per thousand levels of iron, zinc and various other toxic metals,
and 50-75% of the starting HC1 levels.
Historically, once a pickling bath was "spent", it was typically treated
in a batch-wise process where alkalinity is added (usually sodium hydroxide
(NaOH)) to increase the pH and precipitate the metals as metal hydroxide
and metal oxides. The metal sludges are then filtered out of the alkaline
wastewater, the pH is adjusted to discharge standards, and the sludge
is sent for stabilization and landfilling. A significant amount of salt
(sodium chloride) is formed during neutralization and is discharged
to the sewer.
The remaining acidity in the bath, some 50-75% of the initial bath make-up is wasted by the required neutralization, never to be recovered. The metal sludges may also end up in a landfill, instead of feeding a recovery process which utilizes them again. In addition, the generator must purchase and handle the NaOH for neutralization, and also the fresh acid to make up the new pickling bath. These baths are sources of high metals loads to the waste treatment systems, and create potential metals discharge difficulties for the generator.
If some method could be implemented whereby the acid could be recovered, much discharge to the sewer system and chemicals usage could be reduced. If the metals in the wastes could also be more effectively handled in this new process, even more pollution could be prevented.
Innovation, Industry Partnerships and Project Initiation:
The concept of an attempt to recover this waste HC1 was first discussed by U.S. Filter and several of its metal finishing "founders" in the spring of 1994. At that time, USFRS had been operating its copper etchant recovery process for over a year with great environmental and economic success. The local metal finishing industry knew that it was neutralizing and discharging millions of pounds of hydrochloric acid each year, and that the technology to recover the acid was too expensive and complex for any single metal finisher to implement alone. Led by Denny Donaldson, President of NICO, they asked USFRS to evaluate the potential technologies to accomplish recovery of this spent acid.
As mentioned in the Company Background section, USFRS is the CTRF for the local metals industry. As such, it can leverage technology and capital investment across many company's waste volumes, and thus provide new approaches and capabilities that no single company could individually. This cooperation with local industry is one of the primary keys to USFRS's success. So, a request like the one made in 1994 was not unusual, but actually typical of the 8+ year working relationship.
After extensive technical investigations and thorough economic evaluations, it was decided to recover the waste hydrochloric acid via vacuum distillation. Although never attempted on this scale before, this innovative approach had the advantages of recovery of two streams (HC1 and water), and leaving a metals rich remainder for further recovery at the facility. It also reduced the need for process water, and could be used to recover USFRS's own HC1 streams that come from our ion exchange resin regeneration process.
Outreach methods employed to promote and achieve the significant acid recovery and metal reclamation include a press release, a 15 minute video (included with this application), various brochures, and numerous facility tours and training sessions (some attended by MPCA staff members).
System and process description:
(Note: A Process Flow Sheet is included in the attachments.)
The hydrochloric acid recovery system is constructed of completely non-metallic
materials.
The process consists of reboiler, vacuum distillation column, reflux
and cooling condensers, and associated plumbing and tanks. It is computer
controlled via a central control panel for ease of operation. It is
unique in the U.S., and the only commercial scale HC1 vacuum distillation
system in the world.
The process flow is as follows:
· Waste acid is pumped through activated carbon filters to remove trace
organics.
· If the waste acid is high in sulfates, phosphoric acid is added to
control scaling on the reboiler heating surfaces.
· The waste is then introduced into the reboiler loop, where it is heated,
under vacuum (125 mm Hg absolute) to the boiling point.
· Water and HC1 vapors the travel up the column, which is packed with
an inert material which aids the separation.
· At a point about 75% up the column, the pure 18-20% hydrochloric acid
is pumped off through a cooler and into fresh acid storage.
· The distilled water vapor exits the top of the column, where it is
condensed. Some is returned as liquid to the top of the column (reflux),
and some is further cooled and pumped to clean water storage.
· The concentrated undistilled liquids are periodically removed from
the reboiler loop and the metals recovered elsewhere in the USFRS plant.
· The repurified acid is sold back to the metal finishers, in bulk tank
truck loads, 330 gallon totes or 55 gallon drums.
· The distilled water is used for various rinsing operations in other
recovery processes elsewhere in the plant, which is part of our overall
water use reduction program.
APPENDIX B
WATER RE-USE SYSTEM DESCRIPTION
Appendix B: Ion Exchange Regeneration Systems for RCRA Hazardous Waste
Water Re-Use Resin
Ion exchange for water re-use is similar to ion exchange used to treat
rinse water for discharge. The main difference is that ion exchange
used for re-use consists of both cation and anion resins to purify the
rinse water for return to the process. By contrast, only cation resin
is needed to remove regulated metals from the rinse water so that it
can be sewered in compliance with discharge regulations. Separate canisters
of cation and anion resins are used for water reuse; however, it is
more common to use mixed bed resins. As the name implies, mixed bed
canisters contain a mixture of cation and anion resin in the same canister.
This fact improves the purity of water treated by the canister and,
at the same time, complicates the regeneration process since the mixed
resin must first be separated. Referring to the process flow diagram,
canisters of spent mixed and separate bed ion exchange resins are brought
to the U.S. Filter Recovery Services facility. Most of these spent resins
are considered RCRA hazardous wastes because they are pretreatment residuals
(F006) or fail the TCLP for one or more RCRA metals (the D-code wastes,
e.g. chromium, D007).
Separate resins are removed from the canisters and put into hoppers for storage. Mixed bed resins are removed from canisters and placed into the mixed separation vessel. Back washing the resin separates the resins by gravity, heavier cation resins settling in the bottom of the vessel and lighter anion resin above. From the separator or the hoppers, the resins are sent to the cation and anion regeneration vessels for treatment. Acid is used to regenerate the cation resin and caustic soda for the anion resin. Water is used to rinse the resins and then the resins are sent to regenerated anion and cation resins hoppers or the mixed bed resin mixing vessel where the regenerated cation and anion resins are re-mixed. The final step in the process returns the regenerated resin to canisters for return transportation to clients.
Acid and caustic soda used for resin regeneration contains the RCRA regulated metals or carry the F006 listing and so must be dealt with as RCRA wastes. These regenerants are handled in USFRS processes for metal and acid recovery.