p2infohouse.orgProceedings The 1995 Carpet, Apparel and Textiles Environmental Conference Industry...

The 1995 Carpet, Apparel and Textiles Environmental

Conference

Industry Perspectives on Pollution Prevention and Environmental Compliance

eorgia Center for tion, Athens, Georgia

'

Proceedings

The 1995 Carpet, Apparel and Textiles Environmental Conference

Industry Perspectives on Pollution Prevention and Environmental

Compliance

Editor Karen K. Leonas, Ph.D.

Sponsored by CCACTI - Consortium for Competitiveness in the

Apparel, Carpet and Textile Industries

in cooperation with

GTMA - Georgia Textile Manufacturers Association

The University of Georgia College of Family and Consumer Sciences

Department of Textiles, Merchandising and Interiors Georgia Center for Continuing Education

Georgia Institute of Technology School of Textile and Fiber Engineering

February 1-2, 1995

TheUniverSityof Georgia

CCACTI Committee Members

Karen K. Leonas, Chair The University of Georgia

Ian R. Hardin The University of Georgia

Wayne Tincher Georgia Institute of Technology

Planntng Session Committee Members

Mr. Ronald Beegle Mount Vernon Mills, Inc.

Mr. Tony Cutrer Georgia Environmental Protection Division

Dr. Ian Hardin .

The University of Georgia

Ms. Mary Margaret Heaton Oxford Industries, Inc.

Mr. Larry Hedges Georgia Environmental Protection Division

Mr. John Hightower Thomaston Mills

Mr. Tom Huntebrinker Amoco Fabrics and Fibers

Dr. Karen Leonas The University of Georgia

Dr. Wayne Tincher Georgia Institute of Technology

Mr. Bil l Whitmire Shaw Industries

i

C * A * T * E * C '95 The 1995 Carpet, Apparel and Textiles

Environmental Conference A G E N D A

Febnrary 1, 1995

8:OO - 1O:OO

GENERAL SESSION ........................................................................................ Masters Hall Presiding - Karen Leonas

1O:OO - 10:25 Welcoming Comments

Conference Registration ........................................... Conference Landing Continental Breakfast ........................................................... Ambulatory

Dr. Sharon Nickols, Dean College of family and Consumer Sciences The University of Georgia

"What i s CCACTI?" Dr. Ian Hardin, Department Head Department of Textiles, Merchandising and Interiors The University of Georgia

"Federal Water Quality and Regulatory Directions" fritz Wagener, Chief, Water Quality Standards Section US €PA District IV

"Encouraging Environmental Excellence" Don Huffman, Dixie Yarns, Vice Chairman of Encouraging Environmental €xce/lence for ATMI

"How Pollution Prevention Can Assist the Carpet, Apparel, and Textile Industry in Addressing Environmental Problems" Mr. Bob Donaghue, Assistant Director Georgia Pollution Prevention Assistance Division

Lunch ............................................................................... Banquet Area

10:25 - 1 1 :00

11 :00 - 1 1 :30

11:30 - 12:OO

12:oo - 1 :oo

CONCURRENT SESSION A WASTE WATER QUALITY ....................................... Room Q Moderator - Warren Perkins

ROO - 1 :25 "Georgia's Approach to Metals Limits in NPDES Permits" Lawrence Hedges, Program Manager, Industrial Waste Water Program Georgia Environmental Protection Division

"Regulatory Issues and Alternatives" Sue Wagner, Director of Environmental Technologies CIBA-GI€ GY Corporation, Textile Products Division

"$325 - 1 :50

.. I I

i

i s15 - 2~40

2~40 - 2:55

:55 - 3 ~ 2 0

3 ~ 2 0 - 3:45

3:45 - 4 ~ 0 5

"Treatment and Disposal of Textile Industry Waste Waters by Land Application" Philip D. Freshley, Soil Scientist Earth Systems Associates, LTD

"Ozone Treatment of Textile Mill Effluent" Mr. Jeffery Langley, Business Manager, and Greg Leist Henkel Corpora tion

Break ..................................................................................... Concourse

"Use of a Simple Modeling Procedure to Minimize Refractory Toxicity Effects in Textile Chemicals'' David N. Dawe, Technical Development, Burlington Research and Sam Moore, President, Burlington Research

"Slasher Waste Water Elimination" Don Alexander, Director of Technology Transfer Center institute of Textile Technology

"Toxicity Reduction Evaluations" Don Deemer, PE ERM - Southeast, Inc.

CONCURRENT SESSION B: CLEAN AIR ACT ....................................................... Room R Moderator - Theresa Perenich

1:OO - 1:35 "Clean Air Act: Title V and Title 111" Tony Cutrer, Head, Stationary Source Compliance Program Georgia Air Protection Division

"Clean Air Act Operating Permits: A Key Input to Production Decisions" Tom Devine, Corporate Vice President, Regulatory Affairs RMT, Incorporated

Break ..................................................................................... Concourse

"Planning for Life After Your Title V Application" David Dunn, Project Manager ERM - Southeast, Inc.

"Coprolactan: A Study of a Hazardous Air Pollutant" lohn Torrence, Manager of Environmental Technology A /lied-Signal

INFORMAL DISCUSSIONS WITH PRESENTERS 4:lO - 4 ~ 4 5

1 :35 - 2 ~ 2 5

2:25 - 2:55

2 ~ 5 5 - 3:30

3 ~ 3 0 - 4:OO

Air Quality .......................................................................... Room Q Water Quality ...................................................................... Room R Other Issues ....................................................................... Room I/$

SociaVDinner ....... Callaway Building, State Botanical Garden of Georgia --..-"-I

I ."c*

6:OO - 8 ~ 3 0

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February 2, 199s

7:OO - 8:OO Breakfast Buffet ................................................................. Banquet Area

GENERAL SESSION ........................................................................................ Masters Hall

8:OO - 8:30

I Moderator - George Baughman !

"The Emerging Role of the Citizen-Prosecutor in Citizen Suits" Greg Blount, Esq., Environmental Partner Constangy, Brooks, and Smith

"The Role of Comprehensive Environmental Compliance Management Systems in the Textile and Carpet Industry" Brian A. Rindt, Esq., Pf, President Rindt-McDuff Associates

8 ~ 3 0 - 9~45

9:45 - 1o:oo 1O:OO - 10:50

Break ................................................................................... Ambulatory

"How to Develop and Maintain an Effective Environmental Training Program for Your Company" Mary Margaret Heaton, Esq., Corporate Counsel Oxford Industries, Inc.

CONCURRENT SESSION A WATER SOURCE REDUCTION ............................... Room Q Moderator - Garnett Grubb

g:OO - 1 1 :30 "Source Reduction for Environmental Benefits" David Lamb, Plant Manager Dundee Mills

"Financing Opportunities for Industry Environmental Improvements for Georgia" Larry Warner, CH&FA

12:oo - 1 :oo Lunch/Round Table Discussions ........................................ Banquet Area

CONCURRENT SESSION, continued .................................................................... Room Q

a00 - 1 :30

:30 - 12:OO

"Engineered Solutions for Resource Recovery and Environmental Compliance" Mike Brewster, CSK Technical, Inc. Matt Kennedy, Environmental Protection Technologies, Inc.

"Use of Ozone to Renovate Dyebath Water" Ed Fouche, EPRI Textile North Carolina State University

1 :30 - 2:OO

/ . 2:00-2:30 "Membrane Filtration Application in Water Recycling for Reactive Dyeing" Len Farias Cotton, Inc.

"Toward Zero Discharge Dyeing" Wayne Tincher, Professor Georgia institute of Technology

0 - 3:OO

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CONCURRENT SESSION B: SOLID WASTE MINIMIZATION .............................. Room R Moderator - Svea Bogue

:00 - 11 :30 “An Overview of CCACTI Solid Waste Minimization Projects” Sutish Kumar, Professor Georgia Institute of Technology

“Retrieva: The PET Generation” Linda Bavaro, President Global Green, Inc.

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1 - :30 - 12:OO

12:oo - 1:oo Lunch/Round Table Discussions ........................................ Banquet Area

CONCURRENT SESSION, continued ..................................................................... Room R

1 :OO - 1 :30 “AT&T’s Process of Waste in the Work Place” Gerald Lightsey, Project Manager, AT& J Recycling AT&J

R30 - 2:OO “Practical Approaches to Solid Waste Disposal” Chuck McPherson, Vice President KlSER Environmental Services

“Returnable Packaging in the Textile Industry” Stephen Powel, Vice President of Marketing and Sales T.H.E.M. hternational

00 - 2 ~ 3 0

2:30 - 3:OO “Customer Core Recycling Program: A Case Study to Recover Packaging Material” Ron Beegle, Director of Environmental Affairs Mt. Vernon Mills

Break ..................................................................................... Concourse 3:OO - 3 ~ 5

INFORMAL DISCUSSIONS WITH PRESENTERS 3 ~ 1 5 - 3~45 Solid Waste Minimization ................................................... Room Q

Water Quality ...................................................................... Room R Other issues ....................................................................... Room l/S

SPONSORS: CCACTl - Consortium for Competitiveness in the Apparel, Carpet and Textile Industries

in cooperation with

CTMA - Georgia Textile Manufacturers Asswiation + ?Re University of Georgia / College of Family and Consumer Sciences / Department of Textiles, Merchandising and Interiors /Georgia Center for Continuing Education Georgia Institute of Technology / School of Textile and Fiber Engineering

The Georgia Center for Continuing Education, a full-service residential conference center on the campus of The University of Georgia, has as its mission to serve the learning needs of adults and organizations and to provide leadership in developing the theory and practice of continuing education. The University of Georgia is an equal opportunitylaffirmative action institution. 1 7 8 5

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TABLE OF CONTENTS

GENERAL SESSION

Foreward ................................................................................................................... ix

What is CCACTI? Ian Hardin .................................................................................................................. 1

Federal Water Quality and Regulatory Directions Fritz Wagener ............................................................................................................ 7

Encou ragi n g Envi ron men tal Excel lence John Eapen ............................................................................................................... 9

How Pollution Prevention Can Assist the Carpet, Apparel and Textile Industry in Addressing Environmental Problems Robert Kerr; presented by Bob Donaghue .............................................................. 19

CONCURRENT SESSION - A WASTE WATER QUALITY

Georgia’s Approach to Metals Limits in NPDES Permits Lawrence Hedges ................................................................................................... 29

Regulatory issues and Alternatives Sue Wagner ............................................................................................................ 53

Treatment and Disposal of Textile Industry Wastewaters by Land Application Philip Freshley ......................................................................................................... 85

Ozone Treatment of Textile Mill Effluent Jeffery Langley ........................................................................................................ 87

Use of a Simple Modeling Procedure to Minimize Refractory Toxicity Effects in Textile Chemicals Samuel Moore; presented by David Dawe .............................................................. 89

Slasher Wastewater Elimination Don Alexander ......................................................................................................... 93

Toxicity Reduction Evaluations Don Deemer .......................................................................................................... 103

vi

CONCURRENT SESSION - 6 CLEAN AIR ACT

Clean Air Act: Title V and Title 111 Tony Cutrer ............................................................................................................ 1 19

Clean Air Act Operating Permits: A Key Input to Production Decisions Tom Devine ........................................................................................................... 121

Planning for Life After Your Title V Application David Dunn ............................................................................................................ 169

Coprolactan: A Study of a Hazardous Air Pollutant John Torrence ........................................................................................................ 171

GENERAL SESSION

The Emerging Role of the Citizen-Prosecutor in Citizen Suits Greg Blount ........................................................................................................... 173

The Role of Comprehensive Environmental Compliance Management Systems in the Textile and Carpet Industry Brian Rindt ............................................................................................................. 187

How to Develop and Maintain an Effective Environmental Training Program for Your Company Mary Margaret Heaton ............................................................................................ 221

CONCURRENT SESSION - A WATER SOURCE REDUCTION

Source Reduction for Environmental Benefits David Lamb ........................................................................................................... 223

Financing Opportunities for Industry Environmental Improvements for Georgia Larry Warner ......................................................................................................... 225

Engineered Solutions for Resource Recovery and Environmental Compliance Mike Brewster ........................................................................................................ 237

vi i

i I CONCURRENT SESSION - A (continued)

WATER SOURCE REDUCTION

Use of Ozone to Renovate Dyebath Water Ed Fouche ............................................................................................................. 239

Membrane Filtration Application In Water Recycling for Reactive Dyeing Len Farias ............................................................................................................. 263

Toward Zero Discharge Dyeing Wayne Tincher ...................................................................................................... 265

CONCURRENT SESSION - B SOLID WASTE MI N IMlZATlON

An Overview of CCACTI Solid Waste Minimization Projects Sutish Kumar ......................................................................................................... 267

Retrieva: The PET Generation Linda Bavaro ......................................................................................................... 269

AT&T’s Process of Waste in the Work Place Gerald Lightsey ..................................................................................................... 271

Practical Approaches to Solid Waste Disposal Chuck McPherson ................................................................................................. 273

Returnable Packaging in the Textile Industry Stephen Powel ...................................................................................................... 275

Customer Core Recycling Program: A Case Study to Recover Packaging Material Ron Beegle ............................................................................................................ 291

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Foreword

The carpet, apparel and textiles industries in Georgia face major issues related to pollution prevention and environmental compliance. it is important for representatives from industry, consulting firms, academia and regulatory agencies to come together to address these important issues in order to achieve and maintain acceptable standards through cost-effective measures.

The Consortium for Competitiveness in the Apparel, Carpet and Textile industries conducted a conference entitled "Industry Perspectives on Pollution and Environmental Compliance" to focus attention on issues of water quality, air quality, solid waste minimization, water source reduction, environmental management and solid waste minimization. The Clean Air Act, including discussions on Title V and Title ill and identification of emission sources from typical textile processes, was also addressed.

A major goal of this conference was to provide a forum whereby participants would receive current information on regulations pertaining to environmental compliance, discuss environmental issues facing the industry and share procedures that have proven to be effective in pollution prevention. The papers presented at that conference are in this publication.

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GENERAL SESSION FEBRUARY 1,1995

1o:oo - 12:oo

Presider: Dr. Karen K. Leonas

Associate Professor of Textile Science The University of Georgia

What is CCACTI?

Ian R. Hardin The University of Georgia

1

2

WHAT IS CCACI’I?

Ian R. Hardin, Head Department of Textiles, Merchandising and Interiors

The University of Georgia

Simply put, CCACTI is the effort to assist Georgia’s most important industry segment. Georgia’s apparel, carpet and textile industries directly employ 22 percent of Georgia’s workers and 30 percent of manufacturing workers, with an annual payroll that exceeds $2.5 billion. The 160,000 workers in these industries constitute Georgia’s largest manufacturing sector. At least 140 of the state’s 159 counties have one or more of these enterprises, and in some rural areas these industries are the primary employers.

The impact that the apparel, carpet and textile industries make on Georgia’s economy is much larger than the primary employment they provide. Industries such as fibers, chemicals, utilities, equipment and retail serve the manufacturers. According to a recent University of Georgia study, the total economic impact of the “big three” industries on the state is $8-10 billion.

Given the obvious importance of the apparel, carpet and textile industries in Georgia, it is essential that the state seek ways to assist them in remaining competitive in the global market that they are part of. The Consortium on Competitiveness for the Apparel, Carpet and Textile Industries (CCAmI) is a true industry, government, and academia consortium. At its core is the belief that the talents and expertise of the University System’s faculty can be brought to bear on the issues that affect the global competiveness of the apparel, carpet and textile industries. The consortium is a partnership between state government, members of Georgia’s apparel, carpet and textile industries, and seven academic institutions. These are:

Columbus College Dalton College Georgia Institute of Technology Georgia Southern College

Southern College of Technology The University of Georgia Valdosta State University

These seven institutions are working with industry partners to address critical needs in five major areas as identified through surveys, industry meetings and a planning retreat:

watedair quality issues solid-waste disposal and recycling programs technology adoption and process automation industry-specific scientific education for employees access to technical assistance, training resources, and research and development results

3

In the 1994-95 fiscal year there have been seven major CCACTI projects active. These projects are:

I.

11.

111.

IV.

V.

Washington, Georgia

In this project scientists from The University of Georgia and Georgia Tech are working with the City of Washington, Standard-Coosa-Thatcher, and Concord Fabrics to answer questions involving effluent and biotic toxicity, and to lower salts/dissolved solids, and color in dyeing effluent. Columbus College will assist in economic evaluation of proposed modifications in processing.

Dundee Mills

Scientists from Georgia Tech and The University of Georgia are working with Dundee Mills in Griffin, Georgia, on the development of closed-loop processes to reduce wastewater through minimization, recycling and direct reuse. Economic evaluation will be done by Columbus College.

Thomaston Mills

T h i s project, at Thomaston, Georgia, is aimed at reducing heavy metals in dyehouse effluent and in identifying means of complying with provisions of the Clean Air Act Amendment. The team consists of scientists from The University of Georgia and Georgia Tech. Economic evaluation will be done by Valdosta State University.

Chipman Union

A team from Georgia Tech and The University of Georgia is helping in conversion of existing processes to chemicals other than sodium hypochlorite for bleaching. Valdosta State will assist with economic evaluation.

Solid Waste Disposal/Recycling

The CCACI'I team from Georgia Tech and The University of Georgia will survey the best available technologies to utilize fibrous material wastes, conduct comparative research, and run cost-benefit analyses on final technology candidates. Scientists will identify potential markets for scrap, evaluate scrap as fuel sources, and devise process changes to reduce production of scrap at poimt sources. Economic evaluation is by Columbus College.

4

VI.

VII.

Demand-Activated Manufacturing (DAM)

The project team from Southern Tech, Georgia Southern, The University of Georgia and Columbus College will assist partner firms in acquiring information and technical expertise to enable them to implement Demand-Activated Manufacturing Architecture systems between their supplier and customers.

Technology Assistance to Industry

CCAclTI is holding three symposia this year to disseminate information about current concern, regulations, emerging technologies, and global trade changes. The 1995 Carpet, Apparel and Textile Environmental Conference (CATEC '95) will address pollution prevention and environmental compliance issues specific to Georgia's carpet, apparel and textiles industries. Water and air quality, and solid waste management will be examined within a Georgia context.

Two other symposia will be presented later this year. One, organized by Dalton College, will examine the impact of the new GA'IT agreement on the carpet industry. The other symposium, organized by Valdosta State, will deal with product quality for the apparel, carpet and textile industries.

Other assistance to industry includes help to industry in improving denim fabric yarns, establishing an information exchange service, and creating databases of companies to assist in disseminating information and research results.

5

6

Fritz Wag ener U.S. Environmental Protection Agency

7

8

Encouraging Environmenta

Don Huffman Dixie Yarns

Excellence

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ENCOURAGING ENVIRONMENTAL EXCELLENCE Environmental leadership in the domestic textile industry

John Eapen, Chairman Encouraging Environmental Excellence Task Force American Textile Manufacturers Institute

what is E3? The Encouraging Environmental Excellence (E3) program was created by the American Textile Manufacturers Institute in 1992 to hrther the domestic textile industry's already strong environmental record.

E3 is a voluntary initiative for ATMI member companies that calls for textile companies to adopt a 10-point plan. The program is managed by M. L. Cates, CEO of Arkwight Mills, Inc. and a seven member task force fiom the industry. I serve as the Chairman of the Task Force which is responsible for the day to day operations of the program. We set the criteria, organize educational seminars and publications, and implement the policy recommendations of the E3 Advisory Board.

The E3 Advisory Board consists of seven representatives Erom business, trade associations, the Institute of Textile Technology, Tufts University and the South Carolina Wildlife Federation. They are independent and responsible for reviewing the programs criteria and the companies' environmental records.

Rule Number One of the program is that an E3 company must be in compliance with all federal, state and local environmental statutes and regulations. In our opinion, there is nothing "excellent" about compliance. It is expected.

We're not perfect But, that's not to say that an E3 member company is environmentally perfect. Each company faces an array of environmental challenges. To date, two of our companies have had spills at one of their facilities. What distinguishes an E3 company is its willingness to work with its employees, government regulators and community groups to address environmental problems quickly. At ATMI, we like to emphasize the word "Encouraging." To be recognized as an E3 member, a textile manufacturer has to continuously strive to be more environmentally responsible.

Any E3 company found in violation of any federal, state or local environmental statute is required KO provide ATMI with a letter explaining the violation and the company's corrective action plan. Should an E3 member company fail to comply with any environmental statute, the ten program guidelines or its recommendations, ATha reserves the right to remove the company from the E3 program.

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A voluntary initiative The success of the program is due in large part to the fact E3 is a voluntary initiative. As a voluntary initiative, E3 encourages a company to get out in fiont of the regulations and set the standards for other industries to follow. Through voluntary initiatives like E3, companies can voluntarily reduce the amount of environmentally-sensitive materials in their facilities and minimize the impact of reactive regulatory mandates. Companies are creating value -- both for themselves and their customers by maximizing its resources and eliminating waste.

The criteria - Environmental policies The E3 guidelines start with a requirement by each company to adopt a corporate environmental policy. By adopting a set of environmental objectives, companies are h'eld responsible by employees, customers and the general public for their actions. Most E3 companies have published their environmental policies in their employee newsletters and the company's a annual reports. Policies are also posted on employee bulletin boards around E3 textile facilities.

Senior management commitment The E3 program guidelines require senior management to monitor the company's environmental progress and encourage greater environmental awareness around their facilities. Many E3 member companies have formal environmental departments with clear responsibilities for dealing with environmental matters.

For example, at Milliken & Company in Spartanburg, South Carolina, the Corporate Environmental Section is responsible for all environmental permitting, training, environmental audits, and new chemical approvals.

-

In addition, Milliken's senior management has company-wide environmental meetings on a quarterly basis with the management of all manufacturing locations. These meetings are used to communicate direction on current environmental issues as well as to review progress by each location on the company's environmental objectives.

One of the benefits of adopting corporate environmental policies and involving senior management in the day to day decision making processes at E3 companies is that environmental matters are now brought to the attention of the company's CEO without the threat of legal repercussions.

With the support of senior management environmental engineer has the opportunity to be innovative, work to minimize waste and maybe cut some of the company's overhead all at the same time.

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Environmental audits Under the criteria, E3 companies are required to perform systematic, documented, periodic and objective environmental audits at each facility operation to ensure the facility is in compliance with all federal, state and local environmental laws and regulations and to identify potential waste minimization areas.

E3 companies regularly review external audit results with plant managers and engineers and some companies send a report of the findings is to senior management, Boards of Directors, county emergency response centers, local fire departments and state environmental agencies.

In addition, last year ATMI'S Board of Directors recommended that E3 companies perform third-party audits of their facilities once every five years.

Supplier/customer relations E3 also requires companies to work with suppliers as well as customers to address environmental concerns. Working with suppliers and customers, ATMI member companies are able to identify a variety of solutions for difficult environmental problems. Many of these ideas have resulted in substantial savings for our companies.

My own company, American & Efird, is the second largest industrial sewing thread company in the world, In 1992, the company launched the National Recycling program" in partnership with its customers.

This program allows customers to return ME'S empty thread cones, spools and packaging to any one of the 10 recycling service centers A&E has established throughout the country. M E consolidates these plastic products. They are later reprocessed into dye tubes, battery casings and automobile splash guards.

Waste minimization goals In E3, companies are required to set annual environmental goals with targeted achievement dates. These goals are reviewed by each E3 company and ATMI staff on an annual basis.

Last year, Collins & Aikman in Charlotte North Carolina, set a goal to decrease SARA emissions by 15 percent using 1987 as a baseline. As of January 1993, the company had decreased SARA emissions by over 50 percent.

Employee education Education is another important component of the E3 program. E3 requires companies to develop and manage a corporate environmental employee education programs.

Employees of E3 companies receive company newsletters on a quarterly basis that publicizes many recycling and environmental tips for home and at work. Employees are encouraged to bring recyclable materials to their plants for collection.

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At Burlington Industries, an E3 committee made up of employees from purchasing, marketing, manufacturing and environmental divisions come together on a quarterly basis to discuss environmental concerns. In addition, Burlington highlights the environmental achievements of one of its facility in every issue of its newsletter. "the Burlington Look."

At Springs Industries, in Fort Mill, South Carolina, employees recycle PVC shrink film, polyethylene film and corrugated board, dye drums, cloth scraps, paper and other waste products. Recycling and waste minimization programs led by Springs employees, has helped the company cut its waste shipments to community landfills by 60 percent. In fact, one facility in Aileen, North Carolina is currently recycling 95 percent of its wastes.

Spill controlplans Each E3 company also must submit the company's emergency response plans -- both formal (e.g., Spill Control and Containment Plan) and informal (e.g., Plant Manager's Accident Plan) to ATMI: for review. Companies select and train employees for spill prevention and emergency activities at each facility. One company held an unannounced emergency drill with local emergency response teams. The fact that the mock situation was known to only a few key management people, the local fire and police chiefs and some hospital personnel enabled the company to closely duplicate a real emergency situation . After the drill, the company reviewed the results with its employees and altered some procedures to correct potential problems that could occur in a real emergency.

Community involvement Community involvement is another important component to the E3 program. To become an E3 company, a textile manufacturer must demonstrate how it relates its environmental interests and concerns to the local community - its residents and policy makers. The company must also offer environmental assistance to other groups and citizens within its local community.

Since most textile facilities are located in small towns and cities across America, most textile companies take this responsibility very seriously. Often, they are the county's largest employer.

In Alexander City, Alabama, the Russell corporation, the nation's leading manufacturer of athletic and leisure wear, built a new recycling facility for its wastes. Russell employees are also responsible for getting the city's cardboard recycling effort underway six years ago. Currently, the Russell Corporation Recycling Center also bales and ships plastic, aluminum, paper and cardboard for the Alabama State Highway Department. Russell employees helped the local fire department establish a fire services master plan and HAZMAT team and are now teaching high school and elementary students how to set up their own recycling prop".

Program oversight As you can see, the criteria is not that easy to meet. However, E3 requires strict compliance with the rules and policies. Under E3, member companies must submit annual reports to ATMI. The reports include a status report of the company's progress in achieving their individual waste minimization goals for the previous year. If they have not achieved their goals, they must

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explain why. If the company has achieved its goals, ATMI asks the company to explain how the goal was achieved. With permission from the individual companies, this information may be passed on to other E3 member companies.

While the criteria is strict and enforcement is necessary to make the program credible, there are a number of advantages in joining the E3 program. ATMI provides E3 member companies with audit manuals, E3 case studies and sponsors annual education seminars. We are currently preparing a progress report for its member companies.

E3 logo A logo has been created for participants of the E3 program to use on their products. The E3 member company can use the E3 logo on its products or contract with its customers to use the logo on their products as long as the customers specify that the cloth, the yam or thread was produced by an American Textile manufacturer that encourages environmental excellence.

The logo is registered with the federal government as a certification mark. For the environmentally-minded American consumer, an E3 hang tag indicates that the product is made by a U.S. textile company with an environmental conscience.

"Changing the way we do business" Through the E3 guidelines companies are improving their manufacturing processes.

One company is working with a dyestuffs company to purchase reactive dyes that use almost no salt and have very little dyestuff left in the effluent after the dyeing process.

Fabric printing is most companies is now done with water-based dyes instead of solvent based. Environmentally, water-based dyes lower air emissions, use less water in clean-up and are more easily treated by a wastewater treatment facility, Operations costs are also lower.

A r M g h t Mills reduced water use fiom 4.3 million gallons per month to around 1 million gallons per month at the same time it increased productivity about 30 percent.

Another company has introduced a new finish that will completely eliminate one entire wash cycle. This helps conserve water, reduce energy usage and improves manufacturing efficiency.

One plant installed a caustic recovery unit to recycle spent caustic which resulted in a savings of about $1 million dollars a year.

Cone Mlls Corporation is one ofthe few textile companies in the world that is recovering and reusing indigo dyes. This process not only recycles the dyestuffs but improves waste treatment plant operation. It saves money and reduced pollution at the same time.

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Recycling Textile companies have found new outlets for our waste products.

One E3 company established a solid waste committee to find new outlets for waste generated through the company's operations. The company is now recycling cardboard, aluminum cans, wooden pallets, paper cloth, cloth rags, polyethylene plastic, polypropylene wrapping, plastic tubes, and cones, burlap. Boiler ash is converted into cement products and the committee is selling obsolete machinery and machinery parts to scrap metal dealers.

Another company expanded its recycling program to include office paper, newsprint, cardboard, and magazines fiom its general office. These materials are now used as feedstock to make cones and tubes for yarn and cloth.

At several E3 companies, biosolids fiom wastewater treatment plants are being land applied on nearby farms as a substitute for fertilizer.

Textile manufacturers have also found new uses for recycled textiles. Our denim manufacturers are working with stationery companies to use denim fabric scraps to make top quality stationery, business cards and now pencils.

Collins & Aikman have devised a recycling system that uses discarded vinyl-backed carpeting to produce a broad range of usable products, such as park benches, bird houses, and picnic tables, was recently introduced at one textile company. Instead of sending material to a landfill, this system uses it to create products that companies can use with no krther depletion of natural resources.

Environmental product lines Some E3 companies have introduced new environmental product lines.

Avondale Mills and Doran Textiles are offering organically grown, naturally colored cotton in specialty lines. These products are grown fiee of pesticides and reduced pollution resulting fiom the dyeing process because the cotton is grown with its own natural colors.

Burlington Industries has introduced the new Stone Free denim. It greatly reduces the amount of pumice stones and chemicals necessary to achieve the stonewashed look. Stonewashed jeans achieve their worn, faded look after hours of washing with pumice stones and bleach. Long wash cycles, stones and chemicals added to production costs.

Mdden Mills in Lawrence , Massachusetts is manufacturing its Polartec fleece fabric f i ~ m 58 percent post-consumer recycled polyester fiber. The fleece is a recycled polyester processed fiom post-consumer PET (polyethylene terephtalate) soda bottles. Now, Swift Textiles in Georgia is manufacturing denim fiom the PET soda bottles.

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SCT Yams is offering a line of dyed yam that has been colored using environmentally sensitive dyes. Those dyes are derived from natural ingredients such as bemes, tree bark and other organic material, generally containing less copper than conventional dyes and require less salt to process. The colors are limited at this point, but SCT is looking at ways to expand the number of colors dyes in this manner. SCT is working with its suppliers to come up with difficult to match dyes containing less copper and requiring less salt than is now available in conventional dyes.

This natural, unbleached cotton, 100 percent linen, no finish comforter is made by Springs Industries. And since 1935, Wamsutta sheets are made from 100 percent cotton, 200 thread count, all natural, no dyes, chemicals, resins, formaldehyde, bleached with hydrogen peroxide which degrades to oxygen and water. Last month, Springs introduced a new line of Liz Claibome comforters using the PET bottles for insulation.

Strengthening the customer relationship These new processes and products have strengthen our relationship with our customers who care about environmental protection. L.L. Bean, Levis, the Gap, Wal Mart, J.C. Penney, Esprit, Patagonia and Wrangler have all adopted environmental policies. Some have instituted environmental assessment programs for their suppliers.

E3 is recognized and participation is encouraged by many of these companies. Last April, Dave Mention, Product Manager at L.L. Bean, addressed the ATMI Annual meeting and encouraged all textile manufacturers to join the program. According to Mention, L.L. Bean places environmental manufacturing on the same scale as quality, delivery and price when selecting suppliers.

Consumer opiniondattitudes: While all of this sounds wonderfbl to those of us in the environmental area. What does it mean to the consumer? Will environmental protection enhance our company's sales? Last September, ATMI commissioned a study to look at consdmer's interest in purchasing environmentally responsible products. According to survey's results, more than 8 out of 10 consumers are inclined to purchase apparel and home hrnishings fiom a company that adheres to environmental practices, and 50% say they are willing to pay more for that product.

Yet, environmental concerns are not expected to replace the traditional purchasing considerations of product quality, price or effectiveness. Achieving "par" quality is a prerequisite to sustaining consumers conversion to a new environmentally-improved" product. Likewise, a manufacturer must educate the consumer through the use of a product label or advertising to convince the consumer to buy their products.

F:\DAfA\JAXE\ENVEXCEL\SPEECHES\UCEORGIA.JE 17

The domestic textile industry recognizes that there is a growing green market out there and through its E3 program, is reaching out to educate the consumer on why it is important to purchase textiles made by E3 member companies.

Conclusion At ATMI, we believe that encouraging environmental excellence and the E3 program is an important business opportunity for our member companies..

By joining E3, companies interested in pursuing environmental excellence can enhance ecological protection, lower costs, reduce risk, obtain positive publicity and possibly, forge new sales opportunities.

And because textile products from may other countries can't begin to match the environmental efforts of the U.S. Textile manufacturers, much less the dollars spent, the American textile industry has a unique opportunity to move ahead of its foreign competition.

18 F : \DATA\ JANE\ENVEXCEL\SPEECHES\lJGEORGI A. JE

How Pollution Prevention Can Assist the Carpet,

Apparel, and Textile Industry in Addressing Environmental Problems

Bob Donaghue Georgia Pollution Prevention

Assistance Division

19

20

Pollution Prevention Assistance Division

im$tizz& Dhision

Georgia Department of Natural

IViIdlife Raourca Coastal Rrsowca Division Division R o t d o n

Dhision

Resources

Georgia Department of Natural Resources

Mission

Develop programs and activities to facilitate reduction of pollution at the source, and instill a pollution prevention ethic.

Waste Management Hierarchy

b Reduce

Recycle

t Treatment

b Disposal

22

Pollution Prevention Activities

b Product reformulation Process modification

b In-line recycling b Inventory management t Raw material substitution b Source segregation of wastes b Good housekeeping t Employee training

Pol 1 ut ion Prevent ion I ncen t ives

Reduce waste management costs

t Improve operational efficiency

i Reduce liability I

t Improve corporate image

t Ease regulatory burdens i I !

23

Pollution Prevention Impediments

+ Lack of upper management support t Shortage of capital t Competing priorities t Lack of technical resources t Inflexible regulations t Single media permitting

Basic Steps In Pollution Prevention Programs t

t

t

t

t

b

‘ t

t

t

Management commitment Set goals Involve employees Train employees Conduct asssessments A C C Q U ~ ~ for waste costs Implement plan Monitor progress Transfer technology

24

Critical Elements of Pollution Prevention Proarams

b Mission or vision statement t Waste stream identification b Pollution prevention goals

b Management support Cause champion

Important Elements of Pollution Prevention Programs

t P 2 integrated into business plan t Priorities assigned to waste streams t Cross-functional teams t P2 programs cost effective b P2 progress tracked and communicated

b P2 programs reflect facility culture Accountability for P2 results

. ._-

25

Pol I ut ion Prevent ion Assistance Division

..... .........-.......

,.--........

~ - . . . - - - - I *.

............................ ..A .....&.I.

Information Manager

b Initial point of contact for assistance t Responds to telephone inquiries t Assesses need for more in-depth review + Maintains technical library b Prepares quarterly newsletter b Conducts technical and psiicy research

26

U n iversity Alliances

= Georgia Tech Research Institute - technical support

Georgia State University - survey support - economic analysis

University of Georgia - small business outreach - agricultural P2 opportunities

Special Projects

NICE3 (Shaw Industries)

Industrial sector assessments

Action Grants

Intern program

-_

27

Outreach Activities t Work Groups

provide policy guidance foster public involvement

t Surveys identify desired services identify educational needs

Education improve public awareness

Core Strategies

b Public Involvement + Public Awareness b"Teach To Fish" b Technical Assistance - Responsive b Technical Assistance - Targeting + Financial Assistance b Maximize Use of histing Resources

28

Georgia's Approach to Metals Limits in NPDES Permits

Lawrence W. Hedges Georgia Environmental Protection Division

29

30

CONCURRENT SESSION - A

WASTEWATER QUALITY

Moderator: Mr. Warren Perkins

Consultant 721 Dawn Drive

Auburn, Alabama

WATER QUALITY STANDARDS

AND

NPDES PERMIT LIMITATIONS

FOR

HEAVY METALS

RULES AND REGULATIONS FOR WATER OUALrrV CONTROC

CHAPTER 397-3-6

RmjSEb - MAY 29,1994

32

GEORGIA'S WATER QUALITY STANDARDS

* Regulate 130 Toxic Pollutants

w w * 127 Priority Pollutants

* 3 Additional Toxic Pollutants

* Chemical Specific or Whole Effluent

l i

FOR PROTECTION OF AQUATIC LIFE

* 34 Toxics with Numeric Standards

* 7Q10 and Higher Stream Flow

* Paragraphs 391-3-6-.03(5)(d)(i) and (ii)

W .P

I I I

FOR PROTECTION OF HUMAN HEALTH

* 90 Toxics with Numeric Standards

* Annual Average and Higher Stream Flow

* Paragraphs 391-3-6-.03(5)(d)(iii), (iv) and (v)

LJ cn

OTHER REGULATED TOXIC POLLUTANTS

* 20 Toxics without Numeric Standards

w m * Controlled through Whole Effluent

* Paragraph 391-3-6-.06 (4)(d)5(ii)(3)

Biomonitoring

NUMERIC INSTREAM WATER QUALITY STANDARDS REGARDING HEAVY METALS

* PARAGRAPH 391 -3=6-.03(5)(d)(ii)

W w

NARRATIVE INSTREAM WATER QUALITY STANDARD REGARDING TOXICS

IN TOXIC AMOUNTS

* PARAGRAPH 391-3-6-.03(5)(d)

I !

w 03

CHEMICAL SPECIFIC EFFLUENT LIMITATIONS:

* NUMERIC WATER QUALITY STANDARD X DILUTION FACTOR

* PARAGRAPH 391 =3=6-.06(4)(d)5(ii)( b)(2)

SITE SPECIFIC EFFLUENT LIMITATIONS:

* WATER EFFECT RATIO, RECALCULATION, BIOMONITORING, STREAM STUDY, OTHER

* PARAGRAPH 391 -3-S-.06(4)(d)S(ii)(d)(2)

I I

Interim Guidance on Determination and Use of Water-Effect Ratios for Metals

39

WER Implementation /---

Preliminary Analysis Site Definition Study Plan Development

Effluent Considerations Receiving Water Considerations

Lab Procedures c. 0

Testing Organisms

WER Calculation

Site Specific Criteria

Monitoring Requirements

I I

U. S. EPA LIST OF WATER EFFECT RATIO "MUSTS"

* 54 Items With Page References

GEORGIA EPD WATER EFFECT RATIO PROCEDURES

* 13 Steps To Be Followed

I I

* Pre=Qualification for Site-Specific Metals Limits - Facility conducts 2 WET definitive chronic tests within one calendar quarter using 2 species in the first test to establish WER eligibility - EPD conducts WET definitive chronic test for confirmation of no instream toxicity

* Toxicity in IWC - Eliminate toxicity - Toxicity eliminated, plan development

* Definition of Site Water = Waterbody type

P h)

EPD advises to proceed with study

- Number of discharges to consider

* Review of Metals Data Clean sampling techniques encouraged Clean lab techniques encouraged Assess total vs. dissolved metals (optional)

I I I ' '

'CI C m

L

n U a u) (II

L .y

w

s Qs 0 C 0 0

e n Lu 0' n

z 0 L c,

m- € € I u) m - U

m fa 3

'D C a Q

9$ U E 9 L Q

E L

G= L 0 0

Q,

e' 0 c, .r

0

a e,

43

* Review of WEWSite-Specific Study Report = EPD review of WER report - EPD submits copy of WER report to EPA for review and,

- Include recalculation procedure, if applicable, along with

- Include proposed site-specific metals limits

commentlconcurrence

other supporting documentation

* Permit Modified if WER Report Approved by EPDIEPA

CI CI * Quarterly Chronic Biomonitoring (definitive) - Performed by facility using most sensitive species for the

- If effluent passes all four chronic tests, then frequency

- Results to EPD for review

first year after permit limit modification

reduced to annually

* Level 3 (macroinvertebrate) & 5 (fish) Rapid Bioassessments - Performed by facility within 3 years of permit limit

= Results to EPD for review modifications

WATER EFFECT RATIO IMPLEMENTATION IN GEORGIA

* Study Undennray: (1) Industry and (1) POlW

cn * * Study Plan Submitted: (4) POTW'S

* Toxicity Testing: (2) Industries

* Potential Candidates: Several Others

I I I

PraQurlificniorr for Sb-SgeCifk Metals UmiU - Facility conducts 2 WET definitive chronic tests within one calendar quam using 2 spocios

- EPD conduct8 WEt definitivo chronic test for confirmation of no i n s t " to%i&y in the fim test to establish WER eligibility.

Toxicity in IWC - Eiiminrta toxicity , Em "8 to proceed widl mdv plan d0Wr-t - loxicity ehnwutd . .

46

I .*"

A-1

WER OUInArJCEs LOCATION Page 21

Page 22

Page 36 Page 48 Page 43

Page 45

Page 45

Page 46

r

Page 47 Page 59

Once the percent effect is uelected for a particular test (e-g., u 48-hr LClo with 2-day-old fathead minnow), the 8ame percent effect mst be used whenever that test is used to determine a WgR for that affluent. Two different endpofnts with the same 8pede6 pu8t not be used as the prhnary and secondary t e s t s , even i f on. endpoint is lethal and the other is 8ublethal- A t lea8t three weeks gbu8t be available between sampling events. For metals whooe critoria are hardness-dependent, the WER used in the derivation of the EWER pa be that one that is calculated using a hardness equation to be comprtible with the hardness of the site water. A t least 3 wBR'8 must be dettrPrined with the primary test One WER m s t be dotesmined with the secondary species.

laboratory dilution water should be as precise a8 possible, but it must not be below, the CMC and/or CCC to which the WER is to be applied. If both the recalculation pracedur8 and a wER are to be used i n the derivation of the sits-specific criterion, the recalculation proerdure be completed f i r a t because the recalculated CMC and/or CCC gau8t be used in the

The primary and secondary tests -ut lk conducted with speci80 b different t a x o n d c order8 and at least one

-0 t m r t e mur+ bo conducted for which data are available on the metal of concern in a laboratory dilution w a t e r from at least one other laboratory.

The atLdpht (Oog., LC,,, ECso) Of tho primary t88t in the

selection of thr primary and secondary t e 8 t B 0

species be an animal. qg,&

47

A-2

If the ptiauary and/or secondary testa are ones for which no results are already available for the metal of concern from another laboratory, the first or second time a WER is determind at least two additional tests pst be conduotad in the laboratory dilution water i n addition to the tests that ure conducted for the determination of WBR's.

All test organisnu W s t be acceptably acclimated to a laboratory dilution water that satisfier the requirements given in section F.3 and F.4 of the WER Guidance. When upstream watek is used to prepare simulated dawnstream water the samples for uputreem water must be representative and m t not be unduly affected by recent runoff events. The sample of effluent usod fn the detezmhation of a WER v e t , be representative and it must be collected during a period when the discharger is operating normally. Samples of upstream water and effluent pust be collected, transported, handled, and stored as reco"nded by the U.S. EPA (1993r). Sanrples ~ 8 % be stored at 0 to the dark with no air space in the sample container. The f l o w of both the upstream water and the effluent p s t be 8ither measured or estimated by means of correlation with a nearby U.S.G.S. gauge. At the t h of collection or preparation, the effluent, upstream water, simulated and/or actual downstream water, and laboratory dilution water must; be measured for hardness (in fresh water) or 8alinity (in salt water), TSS, TOC, alkalinity, pH and total recoverable and dissolved metal. A t the t h e of collection, any other water quality ChaEaCteEflrtiC8 that are monitored monthly or more often by the pedttee and reported in the Dischurge Monitoring R e p o r t must be measured in the effluent and upstream w a t e r .

48

A-3

WER OOIDANCB WER GUIDANCE REQUIREMENT LOCATION I Page 49 Page 52 Page 54

Page 49

Tests grust begin within 36 hours except when transportation to the laboratory would require an inordinate amount of resources. The site water gaust be filtered through a 37-u sieve or screen to remove predators i f WBR tests are to be conducted with daphnids. The laboratory dilution water mt oatisfy the requir-ats given by U.S. EPA (1993a, b,c) or ASTM (1993a,b,c,d,s). The laboratory dilution water concentration for TOC and TSS must be less than 5.0 mg/l.

Page 49

Page 50

Page 50 The hardness of the laboratory dilution water g ~ ~ t be between 40 and 220 mg/l total h s e ae CaCO,.

Page 50 If the criterion for the metal is hardness-dependent, the

above the hardnea8 of the site water, unleus the hardne6s of the site watar is below 5 0 - 0 mg/l. The alkalinity and pH of the laboratory dilution water mast bo appropriate for its hardness. There m s t be no differences between the side-by-side tests other than the compositioa of the dilution water, the concentrations of metal tested, and possibly the water

which the t e s t organiums are accliplated just prior to the beginning of the test.

The same stock solution e be used to add metal t o all

hUdne68 of th8 laboratory dilution water must n ot be

Page 50

Page 50

Page 51 te8t8 conducted at one t h e

I

Page 51

Page 51

The renewal technique gnuat &e used for tests that last longer than 48 hours, If the comaantration of dis8olved -tal decruors by more than 501r i n 48 hours in static or ronwal tests, the test solution pa be renewed every 24 hours. concentration of =tal -at no% hava decreaoed by more than 508 from the beginning to thm end of a static test or from t h e beginning to the end of a renewal in a renewal test i n teut concentrations that -re u u d in the calculation of the results of the tests fog solutions

The

49

A-4

WER GUIDANCE LOCATIO# Page 51

~

Page 5 1

Page 51

Page 53 Page 53

Paga 5s

Page 55

Page 56

OQER GUIDANCE RSQUIREMENT

If the concentration of dissolved oxygen homes too low, the test solutions pust be renewed every 24 hour80 ,

If one test in a pair of tests i 8 a renewal t€!8t, both tests pnrcrt be a renewal test. Recommendation8 concerning temperature, loading, feeding, di8SOlVcrd o%ygen, aeration, disturbance, and controls given by the U.S. BPA (1993a,b,c) and/or ASTM (1993a,b,c,d,e) pust be followad and procedures that are used past be used in both of the side-by-side tests. Each WER test mu8t contain a dilution-wrter control. The number of test organism8 intended to be exposed to each treatment, including control., must be at least 20. If test organisms are not randomly a8signed to the t e s t chambers, they mst be assigned impattially (P.S. EPA 1933a, ASTM 1993a) between all test c h a d " for a pair of sid8-bv-side tests.

~

Thermometers and probes for amaauring pa and disoolved QxyPn =st no t be placed in test chambers that will provide data concerning effects on test organisms or data concerning the concentration of the metal. Heasurewnte of pH, diraolvd oxygen, and tqrature before or during a test must be performed either on achemiotry controls" that contaia test organisnu that are fed the 8- as the other te8t chamber8 or on aliquots that are renKsved from the test &ambers.

Di880lV.d oxygen, pH, and temperature be measured during the test at the the8 sgecifhd by the U.S. SPA (1993a,b,c) and/or ASTM (1993a,b,cd,e). The measurements

be perfoxnwd on the s a " schedule for both of the 8ide by side te8ts. Me88uren1ents be performed on both the chemistry controls and actual test solution8 at tho end of the test. A l l measurements of metals must be performed using QA/QC trchniquer,

50

A-5

For dichotomous

ffect curve gnust

of each atatic test; in a renewal test, the dissolved metal & be measured at the beginning of the test and just before the solution is renewed the first time. When dissolved metal is measured in a test chamber, t h e whole solution in the test chamber mu8t be adxed before a sufficient amount is removed for f i l trat ion; the solution in the test ohamber nntst no t be acidified before the sample is taken. The sample must be filtered within one hour after it i o taken , and the fiatrate must be acidified after Filtration.

in subsequent calculation, at its be retained in all

5 1

A-6

WER GUIDANCE LOCATION Page 57

Page 58

Page 58

Page 38

Page 59

Page 60

Page 60

Page 60

Page 60

Page 62 Page 63

- WER GUIDANCS REQUIREMENT

In evaluating the acceptability of each toxicity test for calculating an LC,, or EC,,; a)the percent of the organisma that were adversely affected pgsr8t have been less than SO8, b)in laboratory dilution water the percent of the organisma that ware advermely affected greater than So%# a)if there was an inversion in the data it m s t not have involved more than t w o concentrations that killed or affected between 20 and 80 percent of the test organisms. If the data for the lnost san8itive effect are dichotomous, the endpoint must tie calculated as a LC,,, ECIo, etc,, using method6 described by U.S. EPA (1993a) or ASTM (1993al.

have h e n

Probit analysis must bo used to calculate results of both side-by-side tests if the data for the mort sensitive effect are diehotamas. If probit analysis cannot be used, computational interpolation must be used and qraphical interpolation paus t not be used. If the data for the moet sensitive effect are diChOtolnoU6, the same endpoint (E,,, EC,,, etc.) and the same computationa must be used for both tests used in the calculation of the WER. If the data for the most sensitive effect are not dichotontoue, the endpoint must be calculated using a regression-type method, The endpoints in the side-by-side tests must be based on the sama amount of the same adverse effect eo that the" is a ratio of identical endpoints and the same computational method must be used for both testa. A WER m s t be calculated by dividing the endpoint obtained using site water by the endpoint obtained using laboratory dilution water. If both a primary test and a 8.COndary test w e r e conducted using laboratow dilution water and site water, WBR's must be calculated for both tests. Both total recoverable and Dissolved WBR's must be calaulated, If the detection limit of the analytical method used to ~~easure the metal is above the endpoint in laboratory dilutien %mtBr, the detectierr limit must be used as the endwint . R report of the experimental determination of a WER to the appropriate regulatory authority gust include all itam under section J on Page 62 and 63 of the WER Guidance.

I

52

Regulatory Issues and Alternatives

Sue Wagner CIBA-GEIGY Corporation

53

. 54

56

cn

I '

I .

Metals = Regulatory Background

Metals8

~I

1986 = EPA Issued "Quality Criteria for Water"

Called the "Gold Book"

Guidance on Allowable Metals

Based on Lab Data / Ionic Metals

Limit Based on Most Sensitive Specie

I I I

Metals = Regulatory Background

State Implementation

Stringent Limits </= Federal Guidelines

Limits Based on Most Sensitive Specie

Analytical Method - Total Recoverable Metal

7QlO Stream Flow

Metals9

~l

Heavy Metals Naturally Occurring in Soils

Metals4

C. 0

m m E 0 X 0 I-

m m

n

60

,

(Values PPB)

QI c

Metals1 1

* At Hardness of 50 mg/l *+ Acute Cruteria, No Chronic Available

62

_ -

I

Metal Speciation & Aquatic Toxicity

There is a relationship between Chemical speciation and Environmental Toxicify.

Total Metal = [Ionic Metal] + [Complexed Metal] + etc ....

Toxicity [T!onic? ] + [TComplexed e Com plexed ] + etc,,,,

Metals5

A A A

64

EPA Guidance for Aquatic Life Metals Criteria s

Expression of Aquatic Life Criteria

Dissolved vs Total Recoverable Metals

Dissolved Criteria

Site-Specif ic Criteria Modifications

Recalculation Procedure

@ Indicator Species Procedure (WER)

Resident Species Procedure

Metals15

I I

0 0 cy

0 u)

0 0 r

0 m

0

p3 c

66

Metals - Criteria vs Water Hardness Levels

Metals7

Criteria in PPB

Hardness in mg/l

i i

... .

68

Toxicity of Metals - Bioavailability Assumptions

ECG023

1000 903

800

600

400

200

0 Total Recoverable Dissolved Whole Effluent

Metals Toxicity

Source: Water & Environment Technology, March 1992

Final Acute Value (FAV) for Cadmium

Metals16

~i

40

5 30

m Q 20

f!

..I - -

10

0 Fresh Water Warm Water

I I

Sources of Metals ~~

ECG024

I I

b Incoming Water

B Fiber

I9 Plumbing (Copper Pipes/Acid Water)

b Dyestuffs

Q Processing Chemicals

Dye Class

Direct Dyes Fiber Reactive Dyes Vat Dyes S uIfur/S u If u r-Vat Dyes Disperse Dyes Basic Dyes Acid Dyes Premetallized Dyes Mordant Dyes

Typical Metal in Structure"

~

Copper Copper,Nickel None (Zinc?) None (Zinc?) Copper, Chrome, Colbalt Copper, Chrome, Colbalt Chrome

* Does not imply all dyes in class have metal * Other tramp metals may be detected

ECG021

I I

General Fixation Characteristics of Major Dyeclasses

Basic Dyes

Metal Complex Dyes

Azoic Dyes

Acid Dyes

Disperse Dyes

Vat Dyes

Direct Dyes

Reactive Dyes

Sulphur Dyes -

0 20 40 60 80 100

General % Fixation

ECGOl7

I I I ' '

Main Source of Copper and Other Heavy Metals in. Dyehouse Effluent

Wool I PA dyeing with 1:l or 2:l metal complex dyes (chromium, cobalt, ...) (but high degree of exhaustion -------> low contamination of effluent)

CO dyeing with metallized direct dyes (copper, ...) ( here again: fairly high degree of exhaustion)

Metal catalysts carried over into the commercial form of the dye (copper, mercury,.. .)

Chemicals for the improvement of light fastness of PA dyeings (copper, ...)

I I I I

Main Source of Copper and Other Heavy Metals in Dyehouse Effluent

. (continued)

PAN dyeing with some cationic dyes (zinc)

older generation of some finishing chemicals (zinc)

and in particular:

CO dyeing with some reactive dyes (turquoise, blues, greens, navies,...). The problem is intensified by the large volume of cotton presented for dyeing and the rather low degree of fixation of many commercially available reactive dyes.

Environmental Aspects of Metal Complex Dyes

Main source of copper in the effluent of dyehouses using reactive dyes:

bright turquoise reactive dyes

navy reactive dyes

neutral blue reactive dyes

(copper-phthalocvanine chromophore, there is no alternative for this shade)

(polyazo chromophores; shade can also be obtained with similar dyes that are copper-free, drawback: poorer light fastness)

(formazan chromophore; shade can also be obtained with copper-free dyes: dioxazine brilliant blue chromophores: drawbacks: AOX carriers, often poor washing off anthraquinone brilliant blue chromophores: drawbacks: poor build-up, expensive, mercury carry-over possible polyazo blue chromophores: drawbacks: too dull, low light fastness

I I

Environmental AsDects of Metal Complex Dyes

Typical copper-contain

Phthalocyanine

iOsJH-R

(stable complex)

ing chromophores of reactive dyes for CEL:

Formazan

(stable complex)

AZO

NH-R

(rather unstable complex)

I '

,

Dyestuff Metal Concentration at LC50

Cr(lll)

cu

Ni

Log Scale r -

Minimum Average Maximum

I 1 2 3 t r-’ T o

(Ppm) om!1 I 4 0.0 100 1000 p.’ Ilm0 ppb 6.5 11 88 120 €PA

Cu Cr+6 Ni Cf+3 f.--. Water Quality Criteria

Metals4 Source: ATMl May 1992

W

Environmental Aspects of Reactive BIuelGreen Shades

Based on phthalocyanine bright turquoise only way to achieve really bright turquoise and green shades contains copper, aggravated by: - poor fixation - weak chromophore

also negative: - poor washing off (water !) - poor diffusion (energy 1)

Based on dioxazine bright blue

no copper, but AOX strong chromophore, satisfactory fixation but: trend to: poor washing Off

Based on anthraquinone

bright blue

no copper, no AOX but possible carry-over of traces of mercury/copper (catalyst) aggravated by: -weak chromophore

-trend to low fixation in particular in exhaust (affinity)

~~

Based on fonnazan

blue

contains copper,

rather high fixation and strong chromophore (thus reducing the problem)

Based on copper-azo

dull blue / navy

contains copper,

dull shade and limited shade spectrum, azo-copper complex rather fragile (free copper ions 3)

Based on bisazo

dull blue / naw

no copper,

- strong chromo-

- economical phores

but:

- very dull - very poor LF (not for pale - medium shades)

v) W ti n X W I n E 0 o a I- W z % I- o a n E - W

I cn

n a

b - I '

80

Environmental Aspects of Reactive BlueIGreen Shades

phthalocyanine based dioxazine based anthraquinone based same as for very turquoise dyes bright blues bright blues and medium bright

or Af x

formazan azo dull blueshavies

comsrcontaininq possible problems: -solubility -diffusion - levelness -dichroism - build-up -cost

AOXcontaininq problems with either: -chlorine fastness -washing off or: - solubility - reproducibilify - compatibility

comer-free possiblv mercury traces comer-containinq comer- problems with either fairly economical , containinq poor light fast- cost and: excellent dyes poor shade ness (only for - low affinity stability deep shades) - build-up (fragile azo- -not suited for exhaust or: -solubility -reproducibility

metal complex)

Environmental Aspects of Reactive Blue/Green Shades

00 N

phthalocyanine (some) anthraquinone dioxazine formazan azo / polyazo or

same as for very and medium bright

for greenish shades for reddish shades

x x corwer-containinq possible problems:

- diffusion - levelness - build-up - cost

- solttbility

comer-free problems with either cost and: problems with either: no particular problems containinq poor light fastness

-low affinity - chlorlne fastness to be expected poor shade (only for deep - build-up -washing off - not suited for exhaust or: (fragile azo- or: -solubility metal complex) -solubility - reproducibility - reproducibility - compatibility

possiblv mercury traces AOXeontaininq comer-contalninq corrper-

stability shades)

.

_ -

Copper in the dyehouse effluent

* *

03 w

I ! I I

Coping with Stringent Metals Limits

€PA may officially recognize the lower toxicity of metals in Textile Mill effluent 1-9 but don't count on it!l

Minimize Metal Discharges Wherever Possible Q Product Selection @ Contaminated Stream Segregation and Treatment

Take Advantage of Available Options to Obtain More Reasonable Limits 0 Recalculation Procedure Q . Indicator Species Procedure (WER)

0 Resident Species Procedure Metals17

Treatment and Disposal of Textile Wastewaters by Land Application

Philip Freshley Earth Systems Associates, LTD

85

86

Ozone Treatment of Textile Mill Effluent

Jeffery Langley Henkel Corporation

87

Use of a Simple Modeling Procedure to Minimize Refractory Toxicity

Effects in Textile Chemicals

David N. Dawe Burlington Research, Inc.

89

90

Use of a Simple Modeling Procedure to Minimize Refractory Toxicity Effects in Textile Chemistry

Samuel B. Moore, Jay Madren and Rick Diehl

ABSTRACT

Compliance with pretreatment, NPDES and other State standards is a complex problem and, as stricter standards are imposed, becoming more difficult. As standards become more restrictive, data required to determine compliance have increased in complexity to the point where data management and understanding is next to impossible without advanced training. Burlington Research, Inc., through years of first hand experience, realized the difficulties of data interpretation and developed a software tool to deal with both reactive toxicity elimination and pro- active selection of wet process chemicals which reduce the aquatic toxicity impact on the POTW and can eliminate pretreatment requirements. Using results from Standard OECD tests 209,301 and 202 the program generates an environmental impact index based on algorithms developed within Burlington Research. Development and use of this expert software, Aquato?, are reported and examples of its application are discussed.

91

92

Slasher Wastewater El im inat ion An Industry Case Study

Don Alexander Institute of Textile Technology

93

94

"Slasher Wastewater Elimination - An Industry Case Study"

Don A. Alexander Institute of Textile Technology

Institute of Textile Technology

Applications Research, Education, Information

Privately Funded by the Textile Industry Since Organization Serving the Textile Industry

1944

95

96

ITT Member Companies Alice Manufacturing Co. Amoco Fabrics & Fibers Co. Arkwright Mills Armtex, Inc. Avondale Mills Becton Dickinson Blumenthal Mills, Inc. Central Textiles, Inc. Clinton Mills, Inc. Collins & Aikman Corp. Cone Mills Corp. Dan River, Inc. Dyersburg Corp. Fieldcrest Cannon, Inc. Flint River Textiles, Inc. Glen Raven Mills, Inc. Grover Industries, Inc. Hamrick Mills, Inc. Harriet & Henderson Yarns, Inc.

lnman Mills Jackson Mills, Inc. Liberty Fabrics, Inc. Malden Mills Industries Mayfair Mills, Inc. Milliken & Company National Spinning Company, Inc. The New Cherokee Corporation New River Industries, Inc. Opp & Micolas Mills, Inc. Pillowtex Corporation Russell Corporation Shuford Mills, lnc. Spartan Mills Spray Cotton Mills Thomaston Mills, Inc. Tultex Corporation

ITT Supporting Companies S?UfiSWS Ciba-Geigy Corp. Courtaulds Cytex Industries, Inc. Duke Power Company Du Pont Hoechst Celanese Monsanto Wellman Fibers

. ~ ~ . ~ ~ ~ ~ ~ ~ ~ ~ . A ~ ~ ~ ~ ~ ~ ~ Byk-Gardner Lawson-Hemphill Mayer Wildman Muratec Vanguard Supreme Zweigle

Bran & Luebbe Marzoli Perstorp Rieter Sulzer-Ruti Zellweger Uster

97

Slasher Wastewater Problem

cs@.&? ITT Member Company Called IIT for Assistance in Solving Plant Problem

Problem Plant Wastewater Discharge Permit Limits Were Being Exceeded - Caused by Slasher Wastewater Plant was in Violation of Permit

Slasher Wastewater Concerns

Slashing Operations Typically Not Located Near

Most Slashing Operations Discharge to P O W Waste Load From Slashing

Major S tream/La ke

- High BOD (Starch) - High COD (PVA) Slashing Wastewater Discharge Highly Variable

98

ITT Response

Tra dr'tiunal A mxua ch Hold All Slasher Wastewater In Tank Meter Discharge (Avoid Spikes) Pretreat Slasher Wastewater

ITT Response

Polltation Preventkm A~oruach Involve Process Specialist

Environmental Expertise -Versus Solving the Problem with Traditional

Focus on Process Oriented Solution

L

99

Pollution Prevention Approach

= I T Process Specialist Involved w Marty Ellis - Solved Problem

Facts About Spun Yarn Slasher Wastewater 9 Normally Contains Less Than 3 Percent Solids = Operation ,and Cleaning of a Typical Slasher will

Produce About 5,000 Gallons.of Effluent Per Week Lab and Plant Trials Suggested This Water Could be Filtered and Reused

100

Slasher Wastewater Sources I #

(Heated and Agitated) - Collection Tank

1

1

1

I

1

1

Filter - Solids to Landfill

Reclaimed Water Holding Tank

Valve and Meter +- Virgin Water - Size Cooking Kettle

Size Storage Tank

Slasher - Steam

Slasher Wastewater Elimination

Findings from P\nnf Tist Plant Went to Zero Slasher Effluent on March 25,

No I l l Effects on Weaving Stop Levels or 1992

Finishing Quality

......... Curren .. .................... f .. use ...................... ox .. system .... .. ................. Over 25 Installations Operating

101

Costmenefit

Simple System, Low Cost Minimum Savings From Water Fees, Sewer Fees, Sewer Surcharges - Approximately $2,500.00/Year for this Study

with Regulatory Agencies Huge Reduction in Man-Hours Lost in Dealing

Industrial Discharge Permit Canceled

Slasher Wastewater Elimination

Lessons Learned Pollution Prevention is Better than Waste

Successful Pollution Prevention Must Come Treatment

From Process Specialist - Process Knowledge is I m pe rat i ve Try to Make the Solutions Simple

102

Toxicity Reduction Evaluations

Don Deemer ERM-Southeast, Inc.

103

104

TOXICITY REDUCTION EVALUATIONS

Required when biomonitoring tests fail

Triggered by I987 Clean Water Act Amendments

c--’

Biomonitoring authorized 0 Ln

States required to adopt water quality standards

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106

I- O

PHASE I TIE TESTING (cont'd)

'Individual Test Methods

- Baseline - pH adjustment - Filtration - Aeration - Solid phase extraction - Oxidation reduction - EDTA chelation

PHASE I TIE TESTING (con’d)

Individual Test Methods

- Surfactant recovery - Zeolite resin - Cationic/Anionic exchange resin - Disinfection


Chemical Testing

- PH - Alkalinity - Hardness - Specific conductance - Dissolved oxygen - Other (e.g. ammonia, metals, TOC)

i


Results identify specific toxicant or class of toxicants

If results not conclusive, Phase II and 1 1 1 TIE testing required

c c c

EXAMPLES OF TIE RESULTS

Ammonia

Metals

Chlorine

Total dissolved solids/salts

Detergents/surfactants

Organic compounds

TRE STEPS (cont'd)

2. Locate Source

3. Identify reduction/removal alternatives

Source reduction/elimination Waste minimization Treatment Dilution/ln-stream controls

4. Select Alternative

5. Implement and Verify

I I I l l

c-l c-l w

ALTERNATIVES FOR MODIFYING STANDARDS

Use dissolved metals rather than total recoverable

Develop site-specific criteria

- Water Effects Ratio - Recalculation Procedure - Representative Species Procedure

Use Attainability Analysis

.

WATER EFFECTS RATIO

Local water characteristics differ from national " a ve ra g e " c h a r a c t e r i s t i c s

Organic acids and minerals can chelate, and thus detoxify certain metals and organic pollutants

RECALCULATION PROCEDURE

Sensitive organisms used to develop the national criteria do not occur in all receiving streams

Eliminating species not present in receiving stream could result in allowable higher constituent concentrations

REPRESENTATIVE SPECIES PROCEDURE

Actual bioassay testing utilizing representative species and receiving stream water

USE ATTAINABILITY ANALYSIS

Certain bodies may have been incorrectly classified as to their designated use

EPA has published guidelines for challenging a given designated use classification

I I I

118

CONCURRENT SESSION - B

CLEAN AIR ACT

t o o - 4:45

Moderator: Dr. Theresa A. Perenich

Professor The University of Georgia

i

Clean Air Act: Title V and Title 111

Tony Cutrer Georgia Environmental Protection Divison

119

120

Clean Air Act Operating A Key Input to Production

Permits: Decisions

Thomas W. Devine RMT, Inc.

121

1-

I

t

122

What Is the Clean Air Act?

ARE YOU READY FOR TITLE V?

Thomas W. Devine end John Sudnick RMT, Inc.

January 1995

The clock is ticking as the countdown continues toward the submittal deadline for the most comprehensive air-permitting regulations ever implemented in the United States. Title V of the Clean Air Act Amendments of 1990 will have a profound effect on American industry and the way it does business. Owners and operators of textile mills, chemical plants, durable-goods manufacturing facilities, fumiture manufacturing facilities - in short, any commercial or industrial facility that emits something into the air - may be subject to this new regulation.

Historically, factories that used processes or devices that produced air pollutants were required by state law to have an air permit to operate the process or device. These included such things as steam boilers, furnaces, dyeing and finishing processes, curing ovens, paint booths, and storage tanks. The federal government required states to adopt a State Implementation Plan (SIP) to serve as the primary mechanism for regulating and controlling sources of air pollution. Some of the less-industrialized states have implemented the SIP in name only. In these states, the requirements for Dermitting air pollution sources were marginally mplemented and weakly enforced.

b the Clean Air Act evolves, however, the permitting Irocess for these sources of air pollution will change. llore than ever, individual states will find themsetves esponsible to the federal govemment for how air ermits are issued and requirements are enforced.

itle V is the provision under the Clean Air Act that will ffect these permitting changes. Title V will not !place the SIP concept; however, it will detail specific )quirements that will apply to individual air pollution wrces.

le original deadline for the states to have a Tile V ackage submitted to the federal Environmental otection Agency (EPA) was November 15,1993. ,me states met the deadline; others did not. At this ty moment, some states are scrambling to submit a

By the early 1960s. the steadily deterio- nring air q u a l i m much d dn country brought about chc need for fedenl m n - dards and goals aimed at controlling and minimizing air pollution. The result WIS

the Clean Air Act (CAA). Originally as+ nblished to provide funding and mining to state and local agencies, the W a l s o ahorixedthe US. PubiicHealthService to swdy air pollution and Eo de-. Amended in 1970. the year in which, coincidentally. the cwnayako obsemd the first Earth Day celebntion.the CAA fell under the jurisdiction of the newly

(EPA) and set sundards for six major air pollutants: particulate matter. sulfur oxides. carbon monoxide (CO), nitrogen oxides (NO,). hydrocarbons, and pho- tochemical oxidana. The EPA now had the responsibility of serting National Ambient Air Quality Standards (NAAQSs) for the emission of substances deemedtopresentagenenlthructoair quality. In addition. chc EPA had to set National Emissions Standards for H u - ardous Air Pollutants (NESHAPs) for ceruin hazardous air pollutants (such as arsenic. asbestos. benzene, beryllium, mercury. ndionuclides. vinyl chloride. and the emissionsfromcokeovens),and New Source Performance Standards (NSPSs) that established minimum emissions standards for new sources of pollutants.

In the 1980s. the Reagan administration sought a relaxation of environmental standards. believing they placed an unnecessary burden on industry. The CAA came brckinfull force.hwcver.as the I990 Clean Air Act Amendmenu. a substantial. wide-qnging set of reforms. It IS the I990 amendments to which chis issue of P+C addresses itself. Briefly. the eleven amendmmu-or titles-cover the following ground

f o d E n v i m e n m l ~ , rUcncr

Title I: Provisions for attainment and maintenance of NAAQSs. “At- tainment” (as opposed to ”nonattainment”) refers tothc condition of meeting fedenl or other pollution control standards for 8 spciftc pollutant l i e l deals wirh ozone; sources of NO, and whrk organic compounds (VOCs); sanctions; Con- trol Techniques Guidelines (CTGs); Fedenl Impkmemtion Plans VIPs): “ p o r t CO; and PH-IO. a new standard for measuring psrtitisuiare mamr in the amosphcre.

Title 11: Provisions relating to mobile soyrces. Covers oilpipe standards: cold-tempenwre C O clean fucls; refonnuhtedgrdincoxyfuelr; prban buses: refuelins whdl i , de- sulfurizatiomairtoxiw mm-rorden- gines: and lead in prdine.

Title 111:Aircoxics.The EPAdefines “airtoxics“uthoseair polluuna for which a NAAQS does not exist (Le.. excluding ozone, CO. PM-IO. sulfur dioxide, and nitrogen dioxide) that may reasonably be anticipated to cause ancer. developmenml effects. reproductive dysfunctions. nwdogi- - cal disorders. heritable gene muo- tions. or other serious or imven- iMe chronic or acute health effecu in humans. Title 111 deals with the list of pollutants and source categories; - Maximum Achievable ControlTech- nology (MACT) regulations: residual risk accidental releases; and other issues.

ntk ff Acid deposition (“rcid nin”). Dealt with the reduction of sulfur dioxide (SO,); allowances; Phase I and Phase II of SO, reduction; NO. reductions: repowering; energy con- remtionand renewable enem clean coal technologies (CCTs):and monitoring.

Title V: Operating permits. Title V details the permit process and is covered in derail in chis issue of P,SC.

Title VI: Stratospheric ozone and global climate protection. Deals with the listing of ozone-depleting substances; the phase-out of chose substances: exchange; recycling and use limits: mobile air condtuoners; non- essential products: labeling: safe al- ’

tematives; procuremenr; and meth- ane.

Title VII: Enforcement. Covers en- forceability; violations; new criminal sanctions: penalties; scope; restrictions; ciuzen suiu: oversighr punish- menr and contractors.

Title VIII: Miscellaneous provisions. DealswkhrheMner continenolshelf; the establishment of a prognm to monitor and improve air quality in regions along the border b e e n the United States and Mexico: viribil- ky; international border areas; and other key provisions.

Title I X Clean-air research. Cov- ers monitoring and modelinp. health effecu; the ecosystem; accidental releases; pollution prevention and emissions control: the acid precipier- Pion nrearchprogrrm;clunrlte~- tive fuels; and other studies.

TItlcX Concerns of diudnnaged businesses.

Title XI: Tnnsition w imnce for clean-air employment

Hv

123 I

Tnle V package that will be approved in time to meet the federal deadline of November 15, 1995.

How does this affect you? If you are the owner or operator of a "major" source of air pollutants, you are required to submit a Title V permit application no later than within one year of the date of approval of the state Part 70 permitting program; or any industry specific state permit call date, whichever comes first. In those cases where a state permit program has not been approved by November 1995, EP;. may implement a federal permit call. The feoeral program would then control the permit shield date. The next question IS what determines if you are a major source. First, it depends on whether your facility is in an attainment or nonattainment area. For facilities in a nonattainment area, the major source threshold varies by pollutant and area classification. Table 1 summarizes the major source threshold criteria. In addition, sources that emit ten tons per year (tpy) or more of a single hazardous air pollutant (HAP) or twenty-five tons per year or more of any combination of HAPS is considered a major source regardless of area classification.

EMISSIONS INVENTORY

Whether you already know you are a major source or need to determine if you are a major source, the first step in the Title V process is an emissions inventory. An emissions inventory lists all sources of air pollutants in your facility. These include discrete sources, such as process vents, boiler stacks, hood vents, storage tank vents, as well as fugitive emissions from such sources as open storage tanks and wastewater ponds. Once ell the sources have been identified, estimates of the emission quantities have to be made. The summation of the results of these inventories will determine whether or not you are a major source. Remember, the determination of whether you are a major source depends upon your "potential" to emit. For example, a coating process in your plant emits twenty-three pounds per hour of volatile organic compounds (VOCs). The process is run eight hours per Qy, five days per week, fifty weeks per year. Therefore, the actual emissions from the coating ~racess are as follows:

23 lbmr x 6 hrdday x 5 days/woek = 46.OOO Ib or 23 tpy

H blossary ofTerrr Related to the Clean Air Ac

Amendments and Air Pollutiol

AS with any specialty, the subject of air pollution and (o associated replattons carries i ts own vocabulary. Here are just a few ofthe terms you might encounter, oken from the South Grolina Depm- ment of Health and Environmental Conuol's Regulation 6 162.70. These are abbreviated definitions only.md you are advised to check with DHEC. an aomey. a consultant or other specialist for the specific rquirements anddefini- tionsrcbtedtothe CleanAirAct(CA4).

Affected source: A source that includes one or more affected units dut are subject to the acid n i n provisions under Title IV of the CAA.

Affected unit: A unit that is subject to the acid rain emission reduction requirements or limiutionsand reguhtionspro- mulgaced under Title IV of the CAA.

Draft permit: The version of a permit for which DHEC offers public parcicipa- tion under 570.7(h) or affected State review under 570.8.

Final permit: The version of a P~K 70 permit issued by DHEC that has completed all review procedures required by 55970.7 and 70.8.

Fugitive emissions: Emissions hac could not reasonably pass through a suck. chimney. vent or other function. ally-equivalent opening.

Major source: Any stationary source (or any group of stationary sources chat are located on one or more contiguous or adjacent propenies. and are under common control of the same perion (or persons under common control)) be- longingtor singlcrrujw industrirlgroup ing and that emirs - or has the potential to emit-air pdluuno ofthe types and quantities defined in detail in the Regula- tion. Forthe purposes ofdefining "major source." a scationary source o r group of stationary s ~ r c e s shall be considered pan of a single industrial grouping H all of the pollutant-emitting activitk at such source or pup of sources on contip- ous w adjacent pmpnics Wongto the psme~erGrwp(i.e..allhavclrhcsame wo-dii code) as described in the Son-

latest mbi. dardlndurtriJuurKKnion(slc)MMurl.

potential to emit: The maximum pcity of a sationav source to emit a air pollutant under its physical and c entioml design. Any physical or ope tional limitation on the capacity of source to emit an air polluunt includii air pollution comrol equipment and r, nrictions on hwn of operation or t the type or amount of material cor- busted, stored. or processed. dull t treated as pn of its design if the limit; tion is federally enforceable by the A i ministmtor of the Environmenol Prc tection Agency (EPA). This term doe notaltcroraffecttheuseofthistermfo any other purposes under the CAA. o the term "capacity hctor"as used in thl Title IV acid rrin requirements of t h c CAA or the regulations promulgated thereunder.

Proposed permit: The version of a permit t h a t DHEC proposes to issue and forwards to the EPA Administrator for review in compliance with g70.8.

Regulated air pollutant: A term that includes:

.Nitrogen oxides or any volatile organic compounds; .Any polluunt for which a Na- tional Ambient Air Quality Stan- dard (NAAQS) has been promulgated .Any polluunc that is subject to any sundard promulgated under Section I I I of the CAA; .An: Class I or II substance subject to a standard promulgated under or established by T itlc VI of the CAA; or .Any pollutant subject to a sun- drrd promulgated under Section I 12 or other requirements csub- lished under Section I12 of the CAA, including Sections I12 (g). 0). and (r).

St.tiony~rcc:Anybuilding.svuc- wre. hcilie).. or installation that emirs or may emit any regulated air pollutant or my polluunt listed under Secuon I 12 (b) ofthe W.

- Adaptedfrom materials supplied by Grl Richardson, director of Engineering kr- vices, DHEC Bureau of Air Quality Con- rrol.

HV

124

However, the potential emissions from that coating process are as follows:

23 lb/hr x 24 hdday x 365 dayshear = 201,480 Ib or 100.74 tpy

Therefore, you are a major source.

CAPPED MAJOR (Synthetic Minor)

There are many facilities that only operate eight hours per day, five days per week. So, even though they may have the potential to emit enough pollutants to make them a major source, they will never reach the threshold. For these types of operations, many states are offering a permit status known as a “capped major or equivalent language.” This type of permit will be less comprehensive in scope and content than a full Tile V permit and will require less “work“ in order to apply. However, it does limit the operations of the facility to those conditions that make it a synthetic minor.

FEDERALLY ENFORCEABLE

One of the features of the new Title V air permits is that they are federally enforceable. Taken at face value, this in essence means that the federal EPA will review the air permit applications and have the power to enforce the applicable regulations. One of the legal criteria required to make a law federally enforceable is a review-and-commem period by the general public. What this means to you as a manufacturer is that for the first time, the air permit applications for equipment in your facility will be subject to a thirty-day comment period by the general public. Although this provision provides a valuable communication tool between industry and its neighbors, it will slow down the permitting process. Consequently, any major changes in an air permit will take, on the average, eighteen to twenty-four months.

ALTERNATE OPERATING SCENARIOS

Permit changes requiring eighteen to twenty-four months can seriously impede a company’s ability to keep pace with a changing marketplace. Thankfully, the legislators realized this and provided a means for a plant to change its operation with little or no change to the permit. This flexibility vehicle is the “altemate operating scenario.” Attemate operating scenarios are anticipated changes in production rate, addition of new squipment, or product changes that are specified in

Table 1

“MAJOR SOURCE” EMISSION RATE

THRESHOLDS FOR N O N A H A I N M E N T AREAS

Polluant &ea ClurHiution Threshold (tpy) Ozone MWgiNl 100 VOCs or NO.

Moderate 100VOCsor NO. serious SO VOCs or NOn

severe 25 VOCs or NOn Exweme I O VOCs or NO, - Transport Regions 50 VOCs

Grbon Monoxide S e r i O U S 50 co -

70 Particulate Maner (PM,J’ Senour ’ Less than I O microns in the

“MAJOR SOURCE” EMISSION RATE

THRESHOLDS FOR ATTAINMENT AREAS

100 cpy of any Criteria Air Pollutant as defmed in CAA Section 302(g)

---

“MAJOR SOURCE” THRESHOLDS FOR

HAZARDOUS AIR POLLUTANTS (HAPs)

Potential to emit IO tpy of any one HAP

Potential to emit 25 cpy of any combinaoon of HAPs

---- --__-

(HAP is defined as any of the I89 substances listed in Sacrion I I 2 of CAA)

References Quarles, John and William H. Lewis, Jr. 1990. The New Clean Air

Act, A Guide to the Clean Air Program as Amended in 1990. Washington, DC: Morgan, Lewis & Bockins.

The CAA Operating Permit Progrant: A Guide to Compliance. 1993. Lakewood, CO: McCoy & Associates, Inc.

Henderson, Ely L. 1994. Hazardous Air Pollutant Issues and Clean Air Act Operating Permits: It Pays IO Pay Attervtiort Early. Journal of Environmental Permitting, Vol. 3, No. 2.

John Sudnick is manager of Air Quality Services with RMT. Inc.. a consulting firm located in Greenville. South Grolina.

125

the original permi: application. These potential changes become part of the permit and can be implemented with written notification to the agency. This facet of the Title V permitting process is crucial to the flexibility of a facilii. All phases of the company - management, sales, operations, and maintenance - should be involved in developing altemate operating scenarios that reflect potential changes in the five year l i b of the Tttle v permit.

COMPLIANCE

Up until Title V, most permitted sources of air pollutants were tested soon after they were installed. Further testing to prove compliance was usually not done unless the unit's performance came into question. Title V will require monitoring, recording, and reporting data that will prove continuous compiiice of each source. This monitoring can be done directly, as in the case of a continuous emissions monitor (CEM) on a boiler, or parametrically, as in the case of recorded operational data, such as the feed rate, temperature, and product weight from a chemical batch reactor. In all cases, the correctness and accuracy of the compliance data must be certified each year by an afficer or owner of the company.

ENFORCEMENT

Enforcement of the Clean Air Act requirements will include civil and criminal sanctions. Facility owners and designated company officials will be personally responsible for attesting to the validity and accuracy of the permit application. In addition, the EPA administrator can impose penalties of up to $25,000 per day for violation of any requirement, restriction, or rule of the permit.

The continuing implementation of the Clean Air Act will have a tremendous influence on how America does business. The Tile V permitting process will provide detailed information to the EPA and the public on a facility's operations, processes, and air emission sources. This changing climate will require a greater involvement by management in environmental issues. Waste minimization, process redesign, reuse, and recycling will become attractive altematives to the rend of the pipe" solutions.

126

ntlevpermitting Process

W E DATE e-7 I I 1 60 DAYS I

I- -A

t I I

I I I

L-,,

0 LEAN

Key steps toward obtaining an Operating Permit

for your facility. h) W

Steps to PermittingYour Facility "A"' 1. Description of Applicable State and Federal APC

Requirements Include those which would come into effect during the term of the permit.

2. Determine/Locate Point Source Emissions Fugitive Emissions

Steps to PermittingYour Facility 0.. continued

3. Characterize Emissions Qualitative Determine if potentially subject to regulation Quantitative (mass balance, chemistry of process, emission tests)

4. Compare to historical reporting Existing Permits Form R's

C . 5 Resolve Differences Accumulate Documentation

Irc

I I I I

LEAN

Steps to PermittingY0u.r Facility 0.. continued

-K A"'

6. For each Emission Point For those not regulated - List any way and document basis for no

permit = List insignificant activities

i I

c.' w N

(l LEAN

-+)y Steps to PermithingYour Facility A"' 0.. continued

For regulated emissions: = c I D and Description for each point = e Emission Rates = Supporting Information = Identify Air Pollution Control Equipment = Where subject to existing requirements,

= Enhanced Monitoring (CEM's/PEM's) certify compliance

I I

C LEAN K A"' Steps to PermittingYour Facility 0.. continued

7. Provide description of process and products Limitations on source operation to be in permit Requirements for operational flexibility - Internal offsets (equivalency demonstration)

Emissions Cap Request for alternative emissions limits

i I I I

t

0

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8- L

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134

- - - -

CLEAN K A"' Preparing the Permit Applications

0

I

0

0

0

Document all findings, computations, and assumptions in a report for your files Document computations and assumptions in a report for the agency Fill out permit application forms using the data documented in your reports Collect plot plan, process flow diagrams, data on alternative operating scenarios, and other required graphics

CLEAN K KT Preparing the PermitAppUcations 0.. continued

Check assumptions with operations, remembering that the assumptions are likely to become permit conditions Prepare "permit shield" language Get the CEO or plant manager to sign the package Submit a complete package 3 months early

I I

T Remember: Remember: T

To get a "permit application shield" your package must be both timely and complete. The agency must make a completeness determination in 60 days

An incomplete but timely package can later become complete A late package, no matter how complete, can never become timely

I I

LLAN

?lK' SupportingA P e d t Application

Expect questions on your application, even after it is deemed complete Answer questions quickly and honestly to protect your "completeness" determination Be patient with the agency; they are just getting to know your plant Be patient and open with the public. Take their concerns seriously.

I I

CLEAN K SupportlngA Permit Application

A"' 0.. continued

Get help quickly if you do not know the answer to a question from the agency or the public Pay attention to the progress of your permit application and document each step of the way Review each permit condition carefully with operations Plan a celebratory dinner when the permit is issued: You and your colleagues will deserve it.

I I

EXCERPTS FROM

TITLE V AIR PERMIT APPLICATION

Textile Facility (Example only, does not represent an actual facility.)

140

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EXCERPTS FROM OPERATINQ PERMlTApeucAtK)N

TEXTILE FINISHINO M l U

(Example Only - Ooea not mpaeni M .clwl hclllly)

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195 x Id Bt*

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6. 6.

D I I O 0- Inrtrned Modmd

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EXCERPTS FROM OPERATINO PERMIT APPLICATION

rrXnlE FINISHING MU

(&"e Only - Doea not mpmamt an actual tbc///fyJ

4. Emhalon Polnt(a)

Number(a)

1

2 - 4

5 - 7

5.

Scenrrk Identlfler

N/A

N/A

N/A

6.

DveRanse I 2 - 4

FlnbhkrgRange s - 7

I

3.

Treated Fabric

1.86 x id ?Em

8.

0 5 60

L

EXCERPTS FROM OPERATlNQ PERMIT APPLICATION

TD(T1LE FINISHINO 1111111

(€Jr8mp!e only - me8 nof "enf M " 1 mmy]

8.

No

No

EXCERPTS FROM OPERATING PERMIT APPUCATlON

TEXTILE FINISHINQ MlU

( h / ? t @ O o q - -8 "WS! 8tl .ch#l hCm)

SECTION 4: R e J W o " between Non-Exempt Emkrlon Unltr md Stack@, Vent@, or Control EqdpmwWa strdr..

1. 2 I 7- 8.

Rdn crp or

H- PowerBdler .

~

No 30 I 1.5 No 294 27

294 27 ..

No

No No

53 I 2 7

45 I 20 Yezl

i I

EXCERPTS FROM OPERATlNQ PERMIT APPUCAllON

TEXllL€ FINISHINO MILL

(&"!e onv - Doe. nd "en! (In .cluu/ "y)

~

1. 1 0.

51 0.597 3.840.742 138 850 475

s10,649 3,840,392 104 850 25

510,659 101 25 475

1 07 25 475 510,eeS

cs) F-1 3,840,527 83 1 8 5 0 40 475 51 0.101

1 510,708 8,840,529 86 I 8 5 0 40 475

' 510*711 3,840,!31 81 40 475

EXCERPTS FROM OPERATINO PERMfT APPUCATION

TuCnlE FINISHINO M l U

(Exumph Ow- Utn8 no( rspmonf an mtml hctllly)

EXCERPTS FROM OPERATING PERMIT APPUCATlON

rrxflll FINISHINO MILL

(Example On& - D m not mpm8ent an rcturl hcltlly)

2 3. EIlbldOn

POlM

I

7.

Date 1. cotltrol

. -..e

1 0.

E8tlmrlEon Method

EXCERPTS FROM OPERATINO PERMIT APPUCATION

UAAQS and I t-1000 NESHAP

I I 6* 1. 6. a.

Yrwlmum M o t h o d d k t Ulowrbk Emkrionr

117 Whr I AP=42 4 3 Ib/hr

18.8 lwhr

111 lwhr N/A I AP=42

6lMv

VinVlChlorlde I I

I I I I

Radon I I + Note: Attach calculatlon8

149

DCCERPTS FROM OPERAllNQ PERMIT APPUCATlON

TExnLE FINISHINO MILL

(Example Only Doe8 NOT Represent and Actual Faclllty)

sedkn 6: Emission Data - NAAQS and pre-1990 NESHAP

Usethis form to -the emissions (based on potential to emit) of each air pollutant emitted from e emission point or group described in Section 2 U s e a separate form for each point or group.

Whlh.rm opudng pulnltb mqukrd Ir baaed on -to .m# d.hpdlutMb. Pdanualb.mftb bmd on- - only a- lknltdkn ir (rcknl)y .nlororrbk. m" oqmellylo .mltdafadUty mdor L phyoiad and 0p.nbknrl Wgn. U" on- mobnum - Y,

I NAAQS and pre-1990 NESHAP

I s= 6. 0. 7. 8.

Mlludmum Murlmum Controlled Allowrble

Maxlmum Uncontrolled

particulate M e r I 0.019 lbhr 0.019 lbhr 1 NIA 0.019 lbhr AP = 42

0.023 Ib/hr 0.023 Ibhr I N/A AP = 42

0.076 lbhr 0.076 Ib/hr 1 N/A A? = 42 co 0.076 b/hr

NO, 0.381 Whr 0.381 lbhr 0.381 lbhr I N/A A? = 42

voc's(t0tan I 0.029lbhlr 0.029 Ibhr + 0.029 Ibhr

Benzene I

Bervlkm I + Radon I

150

EXCERPTS FROM OPERATING PERMIT APPUGATION

TEXTILE FINISHINQ MILL

Section 6; Emiosion D8ta - WQS and pre-1990 N E S W

_-

Note: Attach calculatiom

15 1

EXCERPTS FROM OPERATING PERMIT APPUCAmON

t#T1LE FINISHINO MILL

Note: Attach calculation8

152

EXCERPTG FROM OPERATING PERMIT APPUCAllON

TMTllE FINISHING MllL

Sectin 7 Emission Data - AIR TOXlCS

Use this form to show the e" (based on potenrial to mit) d each air porrcaant emlttedfrwn each mission point or group described in section2 Lkeasepamefom\foreach point or-.

Emission Rates in units d (IbEyr):

pte: Attach calculation8

153

EXCERPTs FROM OPERATING PERMIT APPUCATION

Methand

Formaldehyde

Ethylene Glycol

TMnLE flNlSHlNG MILL

67561 025 Ib/hr 0.25 lwhr 0.73 lbhr Massbalance soo00 1.1 x 1 P Ib/hr l . l x W b / h r 6.1x1091Whr Mass balance

107211 0.- Ibm 0.039 lwhr 0.619 lbmr Mass balance

Note: Attach calculations

154

4.

(e) NSPS Subpart Ob

(e) Standard No. 1

(Bl Standard No. 2

(e) Standard No, 7

I I 2 - 4 I OStandardNo.4

(B) Standard No. 5

mi stmaad NO. a

5 - 7 (e) standard No. 4

(e) Standard No. 5

(Bl Standard No. 8

1. 2

ts) 0-1.23

tmlsalan Polnl

Number(a)

1

5 - ?

6.

Appllcabh E m b h Standard

(e) NSPS S m Ob

(B) Standard No. 1

(e) standard No. 2

(6) Standard No. 7

(e) Standard No. 4

(e) Standard No. 6

(e) Standard NO. 8

(8) Standard No. 4

(e) Standard No. 5

(6) Standard NO. 8

7.

cabmr IS FROM OPERA. .do PERMIT APPLICATION lE)(fllE FlNlSHlNQ MILL

1 I

6 - ? -- I

i I '-

EXCERPTS FROM OPERATINO PERMIT APPUCATION

TEXTILE FINISHINQ MILL

(€x"O only - "8 no( m$ment M .cturl hclll(y)

SECTIONO; Compll~Pknlc)dnduk(Canthruc6d)

IdeMy, as listed In Section 8, theamphcestm d a! e" unltswlth any federal w state mgubabm and pavfde sc?mcMed a)"e, I applicable. WA-M~dbourrentlykrcompliance.

F c n , 03

I '-

(6)standardNo.t

mRanse 2 - 4 (e) S t " d No. 4

(e) Standard No. 5

I' I"

I I I o S t " o . 1

I I I (e) Standard No. 2

I I I OstandardNo.8

I I I 0 Standard No. 8

I I I

I x 4. I **

€XCERPTS FROM OPERATING PERMIT APPLICATION

rrXnlE FINISHING MI11

(Exrmpl. Onw - Does not m p ” t an actual hcU/fy)

SECnONll; R e c a r d R m

Thkeectbn I d m M i e s ~ e m l s s b n ~ as listed lnSection8,thatare Mlbjectedtomcodkwping.

Weekly

I !

I

EXCERPfS FROM OPERATING PERMIT APPLICATION

TEXTILE FINISHING MILL

(Example Only - Does not represent an actual facility)

SECTION 13: Reporting

This section identifies all mm-exempted emission units, as listed in Section 8, that are subject to reporting.

1.

Emblon Unll (ProceWEqulpment)

Power Boiler

2.

Emlaah Polnt Number@)

1

2 - 4

5 - 7

3.

Beglnnlng Date of Reportlng

1 1/95

~

11/95

11/95

11/95

4.

Frequency of Reportlng (Every 6 moa. quarterly)

Daily

Weeklv

Daily

Weekly

Daik

5.

Describe whrt b reported

Fuel Usage. Hold for 3 years and make available to the Department upon request.

Raw material usage. Report quarterly.

Hews of operation. Report quarterly.

Raw material usage. Report cluasterly. Hoursofoperation. Reportqua~terfy.

EXCERPTS FROM OPERATING PERMIT APPUCATION

TEXTILE FINISHING MILL

(Ex" only-Do.8 n d n p n u n ( M rcturlhcflhy)

1. company Name. ABCTextiIes

2 ScheduleforSub"d-CertlAcatKms ' DuringtheTermdthePumk

Frequency: Annual Beginning: 11/95

3. Statement d Compliance with Enhanced Monltoting and compliance CwUhtbn Requirements

The air contaminant sources identified inthisapplication are in Y0S NO compliance with applicable enhanced monitoring and cmpliiance certification requirements (tf no, complete Section l!j)

4. Statement d Methods Used for Datemining compliance

Attach a statement d methods used for determining compliance, induding a description d monitoring, recordkeeping, reporting requirements, and test methods. The resporrsible dficial must sign his or her initials on eachpagedtheattachedstatement.

5. Ceruficati d C o m p l i i with all Applicable Requirements:

This certification must be signed by a remcmsl Me official (see in"). Applicauons wlthout a signed CertifidOfl Will be returned 8s -8.

Except for requirements idenwied h section K, whkh compwwe b notachleva I hereby cennythst, based on irrfonnation and belief formed adter "abk inquiry, all air cornaminant sou- identified in this application am In compliance with all applicable requiremerbs.

A (Signed): 8. Date:

- C. Name(typed): -

163

EXCERPTS FROM OPERATING PERMIT APPLICATION

TEXTILE FINISHINO MILL

(€xample Only - Does nor represent an actual faci/@)

SECTION 15: Enhanced Monltorlng and Compllance Certltlcatlon Requlrement

Identify and list all emission units which must comply with 40 CFR Part 64 (Enhanced Monitoring) and the methods which will be used to demonstrate compliance.

Nde: List each item per emissiOn unit separately. I

1. 2

Embalon Unit Emlsslon Point (ProceWEqulpment)

I

Finishing Range 5 - 7

3.

Identlfy Any Applicable Compliance Date Requlrements Method of Compllance Expected

NSPS Db CEM 7/24/88

SC Regulation 62.1, Standard No. 1 6/2/81

SC Regulation 62.1, Standard No. 2 Annual stack test 6/2/81

SC Regulatlon 62.1, Standard No. 7 Annual stack test 7/24/88

SC DHEC Regulation 62.1, Std. No. 4 9/8/83





Fuel usage recordkeeping, CEM

p- m k d n g , reportins

p- monftorlng, reportins

p- moring, "hrs Process mltoring, "g

Process monitoring, ceporting

SC DHEC Regulation 62.1. Std. No. 8 I Process mitorim, m i m I 12/15/84

EXCERPTS FROM OPERATING PERMIT APPLICATION

TMnU FINISHING MILL

$ECrrON 16: Exempt Emisskn Ufalts

165

.

1. A B C T d h

s . . a t ~ ~ ~ ~ ~ ~ p w d l n ~ m : Bdlercan fire natural 488. No.6tueloilcontai nina 0.5% Sulfur or coal.

6. Promu Product SIC

NIA

Ab" Compliance Mrthod

0. Gmorally do8crlk tho rppllcrbk rmqulromont (..et NEO)(AP kr ywnlo kr nrrwka~rrr):- continue ODaCitv tTW8SUrement. PM-IO and SO. throwhm limits. ambient air aualitv standards, p" of sianificant deterkraHon

10. CltO tlw rpplicrbk roquirmmrS (a@., IC R.gul.lbn WaW.endud #I, -10 CFR Mkr mm) NSPS S u W Ob. S C Reauktion 62.R Standatd No. 1. Standard No. 3 Standard No. 7

166

167

168

Planning for Life After Your Title V Application

David Dunn ERM-Southeast, Inc.

169

170

Coprolactan: A Study of a Hazardous Air Pollutant

John Torrence Allied-Signal

171

172

The Emerging Role of the Citizen-Prosecutor in

Citizen Suits

Gregory W. Blount Constangy, Brooks €k Smith

173

174

CITIZEN SUITS

By: Gregory W. Blount Constangy, Brooks & Smith

I. Introduction

Any person having an interest, which is or may be adversely

affected by a violation of certain environmental statutes enacted

by the federal government, may sue in federal court any company or

person for violations of such environmental statutes under certain

conditions. A suit against the government to enforce non-

discretionary duties under these environmental statutes is

authorized under what are known as "citizen suit" provisions. The

federal statutes which contain such citizen suit provisions are as

follows :

1.

2.

3.

4.

5 .

6.

Section 505 of the Federal Water Pollution Control Act

(33 U.S.C. $1365);

Section 304 of the Clean Air Act (42 U.S.C. $7604);

Section 7002 of the Solid Waste Disposal Act (42 U.S.C.

$6972) ;

Section 310 of the Comprehensive Environmental Response,

Compensation and Liability Act of 1980 (42 U.S.C. $9659);

Section 326 of the Emergency Planning and Community

Right-to-Know Act of 1986 (42 U.S.C. $11046);

Section 20 of the Toxic Substances Control Act (15 U.S.C.

S2619) ;

b

e:\gwb\articlea\chapZ

175

176

7. Section 12 of the Noise Control Act of 1972 (42 U.S.C.

S4911) ;

8. Section 11 of the Endangered Species Act of 1973 (16

U.S.C. $1540(g));

Section 520 of the Surface Mining Control and Reclamation

Act (30 U.S.C. S1270); and

Section 1449 of the Public Health Service Act (42 U.S.C.

9 .

10.

S300 j - 8 )

Each of the citizen suit provisions in the foregoing statutes

are very similar. In Georgia, although there are no citizen suit

provisions under state environmental statutes, individuals are free

to use these federal statutes to enforce environmental laws either

administered by U.S. EPA or the state of Georgia, under appropriate

circumstances. Because these federal provisions do not expressly

limit cases to Federal court, it is arguable that Georgia courts

have concurrent jurisdiction to hear these actions. Thus, exposure

to liability for any violation of an environmental requirement

includes exposure to a potential lawsuit from an adversely affected

individual, or group of individuals.

11. Risk of Liability

A. Penalties

Since the citizen who properly files under any citizen

suit provision steps into the shoes of the government to

enforce the statutory penalties as if such person is a private

attorney general, then any company facing a potential citizen

177

suit is faced with exposure to the entire panoply of civil

penalties authorized by law, which in a number of statutes is

up to $25,000 per day per violation. Under the holding of the

11th Circuit (Southeastern United States) Court of Appeals in

Jitlantic States Leaal Foundation v. Tvson Foods, 897 F.2d 1128

(1990), a federal court must assess penalties in a citizen

suit by first determining the maximum fine for which the

company may be liable, then reduce such fine only in

accordance with the mitigating factors allowed by law. All

penalties levied are paid to the United States Treasury and

are not tax-deductible. IRC S162(f).

Enforcement of permits under Title V of the Clean Air Act

will have the added feature of statutorily mandated penalty

assessment criteria. These criteria are found in Section

313(e) and take into account the size of the business, the

economic impact of the penalty, the full compliance history,

the good faith efforts to comply, the duration of the

violation, the payment of penalties for the same violation in

the past, the economic benefit of the violation, and the

seriousness of the violation.

B. Attornevs' Fees

Another significant risk in defending against a citizen

suit is the likelihood that if the citizen prevails or

substantially prevails in the case, then you will owe to the

other side their costs of litigation, including attorneys'

178

fees, consultants' fees, etc. In some limited cases these

fees may be enhanced by a factor to be determined by the court

under the circumstances of the case. Attorneys' fees can, in

some cases, exceed the liability for penalties.

C. Injunctive Relief

As part of enforcing environmental statutes, plaintiffs

often seek injunctive relief in addition to penalties. Such

injunctive relief often includes a request to the court to

prevent the further discharge or release of pollutants to

which the plaintiff objects in the complaint. Such injunctive

relief can force a company to cease operations or severely

curtail its production. An injunction may be sought from the

court as soon as the case is filed.

D. Bountv

U.S. EPA has proposed regulations defining its $10,000

reward program for enforcement of Section 313 of the Clean Air

Act. 59 Fed. Reg. 22795 (May 3, 1994). This new bounty

program will relate only t o violations of Section 313, U.S.

EPA enforcement of air permit violations. Thus, enforcement

by the state of either state operating permits or federally

enforceable Title V permit conditions will not qualify. The

proposed rule sets forth eligibility criteria, as well as

providing addresses for receipt of tips.

informants is assured.

Confidentiality to

179

E. 1. Proaram Chanaes

An additional dimension of the c i t izen s u i t re la tes t o

t h e r igh t of ac t iv i s t s t o sue U.S. EPA t o s tep i n and enforce

a state program. T h i s type of action has been commenced i n

Georgia t o force U.S. EPA t o ident i fy Water Quality L i m i t e d

Segments (WQLSs) i n Georgia and establish Total Maxi" Daily

Loads (TMDLs) f o r each such stream segment w h e r e t h e state has

allegedly f a i l ed t o perform these functions under Section

303(d) of the Clean Water A c t . See Alaska Center for t h e

]Environment v. Browner, 20 F.3d 981, 38 ERC 1345 ( 9 t h C i r .

1994) . 111. Defenses

A. Notice

Under c i t i zen s u i t provisions, no s u i t m a y be f i l e d by an

individual u n t i l notice has first been provided t o t h e

government. Each s t a tu t e has notice provisions which are

substant ia l ly the same, e.g. t he Clean Air A c t a t 40 C.F.R.

P a r t 54; the Federal Water Pollution Control A c t a t 40 C.F.R.

P a r t 135; the Solid Waste Disposal A c t a t 40 C.F.R. Part 254;

and the Emergency Planning and Community Right-to-Know Act a t

40 C.F.R. P a r t 374. Notice provisions typical ly require a t

least 60 days' p r ior notice of t he alleged violation t o the

Administrator of U.S. EPA, the state i n which the alleged

violat ion occurs, and the alleged violator . The notice period

m a y be waived and an action may be brought immediately, where

180

there is a violation of Section 306, relating to the National

Standards of Performance, 'and Section 317(e), relating to

toxic pollutants, under the Federal Water Pollution Control

Act. Also, an action may be brought immediately in the case

of a violation of the hazardous waste management provisions of

the Solid Waste Disposal Act and violation of an air pollution

compliance schedule for existing sources or an order issued by

the Administrator of U.S. EPA to comply with a State Implemen-

tation Plan under the Clean Air Act.

Besides meeting the procedural requirements set forth by

regulation for notice under the various citizen suit

provisions, the notice should be filed during a %on-

adversarial period . SuDDorters to OpDose Pollution v.

Heritacre cor^., No. 91-1247 (7th Cir. 1992). This principle

means that, according to the 7th Circuit Court of Appeals, if

there is an ongoing dispute between the parties in the courts

in a related matter, the notice period does not run during an

adversarial setting.

B. - Bond

Most citizen suit provisions provide that the court may,

as part of a temporary restraining order or preliminary

injunction, require the filing of a bond or equivalent

security. This provision may require plaintiffs to post a sum

sufficient to cover any damages caused a company by a

meritless claim which injures the company.

e:\gwb\articleo\chapZ

181

C. Gwaltnev Defense

The most common defense asserted by persons faced with a

citizen suit is the defense that, at the time the complaint

was filed, the alleged violation was not ongoing or likely to

continue. This is based on the decision of the United States

Supreme Court in Gwaltnev of Smithfield, Ltd. v. ChesaDeake

Bav Foundation, 484 U.S. 49 (1987). Since sampling results

andmonitoring reports are presumptively valid as evidence in

a citizen suit case, then any negative report filed by a

permittee or company could be used against such company at any

time in the future, if there was no limitation for there being

an ongoing pollution problem. Thus, the requirement that any

plaintiff engaged in citizen suit show the continuing nature

of the violation is important in many cases. One notable

exception to this defense lies in the Clean Air Act and its

Section 304. In that k t 8 it is clear that citizens can bring

Suit for purely past, reDeated violations, and there is no

requirement that the permittee be engaged in an ongoing

violation at the time suit is filed. Enhanced monitoring

under Title V of the Clean Air Act poses greater exposure

under this citizen suit provision.

D. Permit Shield

Several recent cases have held that permits may act as

shields to enforcement actions and citizen suits. Under

environmental statutes which have permitting requirements and

182

Arkansas, Arkansas Wildlife Federation v. IC1 Americas, Inc.,

29 F.3d 376 (8th Cir. 1994), addressed this question and held

that a state administrative action can, under certain

circumstances, be equivalent to federal enforcement so as to

block a citizen suit. That court looked at the big picture of

not allowing citizen suits to disrupt the governing state

agency's discretion, even if the means of enforcement used by

the state were not identical to federal procedures. Other

courts have viewed the issue differently and there is no

decision yet by the appellate courts in the southeastern

United States.

F. Abstention

Since citizen suits begin in federal court, there is a

doctrine known as abstention which may allow a federal court,

in its discretion, to abstain from interfering with state

administrative efforts to require defendants' compliance with

its permit. In a clear case of hardship or inequity, the

existence of concurrent state proceedings may warrant the

application of the Colorado River doctrine of abstention to

avoid piecemeal litigation. Colorado River Water Consemation

Pistrict v. U.S., 424 U.S. 800 (1976). Burford abstention

applies in cases where a federal court is asked to resolve

difficult questions of state environmental law and federal

review of such questions would be disruptive of state efforts

to establish a coherent policy with respect to matters of

183

limitations associated with such permits, an argument can be

made that so long as a permittee is in compliance with its

permit, then a citizen suit will not lie. See Atlantic States

Leaal Foundation v. Eastman Kodak ComDany, No. 93-7091 (2nd

Cir. 1993). Since some citizen suits relate to conditions of

pollution not addressed by a permit, then a defense to the

citizen suit action may be that the citizen can only enforce

permit violations, not general conditions of pollution. See

Northwest Environmental Advocates v. Portland, 847 F. Supp.

389 (9th Cir. 1993). To that extent, the citizen does not

step fully into the shoes of the agency.

E. Diliaent Prosecution

Another defense to a citizen suit action is the defense

that either the state or federal government has commenced and

is diligently prosecuting a civil action in a court to require

compliance. The exact nature of the compliance effort by the

state or federal government may be an issue for the court to

decide whether diligent prosecution either is occurring or has

occurred . The question of what constitutes diligent equivalent

prosecution has been much debated in the federal courts. This

issue is important in Georgia because many times an industry

is able to satisfy the State and reach agreement under .the

terms of an Administrative Consent Order, but neighbors or

environmental activists remain unsatisfied. A recent case in

o:\gwb\articlee\chapZ

184

substantial public concern. Burford v. Sun Oil Companv, 319

U.S. 315 (1943). Also, the courts are able to abstain from

technical and scientific questions which are better left to

agency decisions under the doctrine of primary jurisdiction.

Montcromerv. etc. v. Washinuton Suburban San. Com'n, 607 F.2d

378 (D.C. Cir. 1979).

G. Standinq

Because citizens capable of bringing a citizen suit are

defined to only include persons adversely affected by the

complained-of violation, a defense may arYse on this issue.

The question of whether a citizen has "standing" to bring an

environmental action has generally been addressed by the

United States Supreme Court in its decision entitled Luian v.

Defenders of Wildlife (112 S. Ct. 2130). In that decision,

the Court held that a citizen must show injury in fact, fairly

traceable to the complained-of action.

H. Indimensable Partv

Under the Federal Rules of Civil Procedure, all parties

whose interests may be affected by an action must be joined in

that action if possible. In at least one case, a federal

district court has dismissed a portion of a citizen suit where

the state agency responsible for permitting was not joined

with the alleged violator. Georaia Environmental Project v.

Citv of Atlanta, No. 1-90-CV-2403-CAM (N.D.Ga. Order Granting

Motion to Dismiss dated March 22, 1991).

e:\gwb\articlaa\chap2

185

IV. Conclusion

Once a citizen suit action is initiated, it is either resolved

by a court or a settlement. If the matter is litigated, the

Defendant will retain all defenses otherwise available, such as

bypass, upset, impossibility, etc. If settled, the protection of

the interests of the United States may require submitting any

consent judgment to the U.S. Department of Justice for review under

the Federal Water Pollution Control Act and, in all cases, the

United States may intervene in the action to protect its interests.

Regardless of whether the U.S. Department of Justice intervenes in

a citizen suit, that agency continues to encourage citizens to organize and prosecute citizen suits as part of the federal

government's overall enforcement strategy. Therefore, it is

important for the regulated community to understand this

enforcement remedy.

186

The Role of Comprehensive Environmental Compliance

Management Systems in the Textile and C&pet Industry

Brian A. Rindt Rindt-McDuff Associates, Inc.

187

THE ROLE OF COMPREHENSIVE ~

ENVIRONMENTAL COMPLIANCE MANAGEMl3NT SYSTEMS ~

IN THE TEXTILE AND CARPET INDUSTRY

paper presented by:

Brian A. Rindt, P.E., Esq. Rindt-McDuff Associates, Inc.

Marietta, Georgia

Industry Perspectives on Pollution and Environmental Compliance

Athens, Georgia February2,1995

189

EPA Enforcement Policy New Administration Investigators more than doubled by 1995 Budget more than doubled

~

Two new enforcement offices

191

Strict Liability

"What you know CAN you"

192

193

...

Aggravating Factors Absence of documented compliance program Attempts to conceal an offense

194

Mitigating Factors Auditing, monitoring and tracking programs Compliance training and evaluation Integrated use of policies, standards and procedures Self-reporting and cooperation with government

195

196

,

COMPANY "A"

197

7

Company "A" Conducts regular comprehensive audits Discloses violations Disciplines employees Corrects deficiencies Supplies government with information

COMPANY "Z"

198

Company "2" Doesn't cooperate with

Attempts to hide violations Ignores weaknesses in compliance program

0 Ignores possibility of violations

prosecutors

199

Enhanced Company Image

200

Compliance

An integrated program of corporate policies, organization a1 stu ctu re, objectives, procedures, and materials that serve to meet the compliance requirements faced by an entity.

Characteristics Integrated Comprehensive Systematic Specific Continual

201

COMPLIANCE PROGRAM AT A GLANCE

202

A” *us I

Commitment 1. Make a corporate

2.

3.

commitment Draft statement corporate commitment Publicize statem

of

.ent

203

Evaluate your company's (or a particular facility's) status regarding compliance with Environmental Regulations

204

What compliance-related records exist, and are they accurate, complete and up to-date?

205

Does the organization currently use any compliance-related materials such as training workbooks, manuals or videos?

Are there any current compliance policies and, if so, what are they and how were they developed?

206

What measures, if any, has the organization already taken to comply with local, state and federal laws?

Which managers or workers are engaged in activities which may give rise to compliance questions?

207

Has the organization ~

experienced any compliance related problems in the past?

~

If so, how were they resolved?

Water pollution control Wastewater disposal

Oil and Grease COD BOD

208

Underground Storage Tanks

Water Runoff

SIC Major Groups.,

0 22 - Textile Mill Products

0 23 . Apparel...

are "non-p resomp t ively " covered.

209

Bulk Stored Oil

1320 gallons (facility) 660 gallons (container)

2 10

Asbestos PCB

Community Right-to-Know (SARA, Title 111)

TPQ MSDSs - above 10,000 Ib Store hazardous chemicals

302 - 311 - 312 - 313 - 304 -

above 10,000 lb (annual) Use or manufacture (annual) Spills

Ammonia (EHS, RQ, 313, MSDS) CO, (MSDS) Some freons (313, RQ, RCRA, MSDS)

211

Air Pollution Control

212

213

Develop Policies 1. Review impacts 2. Define target areas 3. Draft policy statements 4. Review by impacted parties 5. Finalize poli

2 14

-

evelop Procedures 1. Draft procedures for aZZ

2. Review procedures with

3. Revise procedures as required 4. Management review

5. Draft final procedures

objectives ~

personnel

procedures

215

Why Review? Regulations change Processes change Improve efficiency Prevent obsolescence

216

Methods of Review a a e a a

Employee interviews review records Read existing program Check for new regulations Consult with outside experts as necessary

++11'11/,

Topics for Review I)?lPPh

J Policies J Procedures J Program performance J Employee performance

217

Policy Review

J Were policies "aggressive"

J Were policies ''too

J Have policies been developed

enough?

aggressive 11 3 . for all topic areas?

Procedure Review

J Are all policies workable? J Are procedures

comprehensive? d Are procedures clear? pf Are all employees familiar

with procedures?

218

Performance Review

J Has compliance been achieved?

Objectives Regulations

satisfied? J Have regulating agencies been

Employee Review

J Have personnel performed adequately?

J Have causes of inadequate performance been isolated?

J Have employees been notified of perfomance review?

J Have rewards been utilized?

219

220

How to Develop and Maintain an Effective Environmental Training

Program for Your Company

Mary Margaret Heaton Oxford Industries, Inc.

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22 1

222

CONCURRENT SESSION - A

WATER SOURCE REDUCTION

1 t O O - 3:OO

Moderator: Mr. Garnett Grubb

Industrial Accounts Manager Georgia Power

David Lamb Dundee Mills

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224

Financing Opportunities for Industry Environmental Improvements for Georgia

Larry Warner Georgia Housing and Finance Authority

225

226

GEORGM HOUSING & FINANCE AUlHORrrY

financing assistance include those engaged principally in commercial retail, service and certain agricultural activities. Geographic restrictions apply to some programs.

An important feature of these new financing tssistance programs is the incentives they pro- Tide to banks to increase business lending. 3ankers may now look to GHFA to help them neet the financing needs of eligible business 'ustomers, giving them more opportunities to

NEW ECONOMIC DEVELOPMENT

Bankers imately 60 percent of Prime, plus the cost of now look to the stand-by letter of credit. Fixed rate and GHFA to help taxable financing are also available. Program them meet the coverage is statewide. Contact John Kingery financin needs at (404) 679-5277 for assistance. of eIigib e bustl LOANS FOR RURAL INDUSTRY (LFRI) ness customers, giving them offers medium term, low-cost gap financing more opportuni- for businesses located outside Georgia's ties to say dyes^^ major metropolitan areas and cities of popu-

lation less than 25,000. Interest rates are

Q

FINANCING PROGRAMS AVAILABLE TO GEORGIA BUSINESSES

227

amounts ranging from $20,000 to $3OO,OOO for terms of up to ten years, and require a minimum match of two to one. ILFI loans may be used for a variety of purposes, including fixed-asset and working capital financing. Contact Larry Wamer at (404) 679-5279 for assistance.

GEORGIA EXPORT ASSISTANCE PROGRAM provides access to export working capital loan guarantees offered through the Georgia Export Finance Fund and the CityBtate Program. In addition, CityBtate offers referral services for assistance provided by the Export- Import Bank of the United States (Eximbank) and the U.S. Small Business Administration.

GEORGIA EXPORT FINANCE FUND (GEFF) provides direct access to working capital guarantees of up to $500,000 to Georgia’s small and medium-size businesses. Guarantees are transaction-specific. GEFF operates in partnership with Georgia’s banks, to give the State’s smaller exporters improved access to affordable working capital needed to support export sales. With all decision making at the state level, this program offers quick tum- around and flexibility in dealing with business needs and circumstances. GEFF guarantee parameters include: guarantee maximum of lesser of $500,000 or 90% of cost of goods sold; no guarantee minimum: s u p port for loans or standby letters of credit: support for pre-export working capital, post-export receivables financing or a combination: maximum guarantee term of 180 days for pre or post-export and 360 days for combination: export product must have at least 5 1% Georgia

content; Georgia exporter must have been in business at least one year; firm export order required. For assistance, contact Susanne Keough at (404) 679-5276.

CITYBTATE PROGRAM offers Georgia businesses easy access to export assistance programs offered by The Export-Import Ehnk of the United States (Eximbank) and the Small Business Administration (SBA). Services include packaging and expedited processing of applications for the Errport Wo- (EWCP) operated jointly by Eximbank and SBA. This service includes assembling required information in a standard format, submitting the application for consideration and providing necessary follow up. Citystate guarantee parameters include: 90% guarantee of principal and interest: support for specific transactions or revolving lines of credit: no minimum or maximum amount (amount requested will determine which agency providing guarantee); exporter must have been in business at least one year; exporter must demonstrate financial strength to support loan: export must be to country included on Eximbank‘s Country Limitation Schedule: exporter must have business operations in U.S.. Guarantees offered by Eximbank and SBA differ in term and content requirements. Services also include matching exporter needs to other assistance provided by Eximbank. The following types of assistance are avaii- able: working capital guarantees: medium-term guarantees: direct loans: foreign credit insurance. For assistance, contact Jean Prasher at (404) 679-5278.

“GEORGIA’S FINANCIAL PARTNER” SUKE 250 - 6 0 EXECUTIVE PARK SOUTH, NE AUNTA, GEORGIA 3 0 3 2 9-2 2 3 1

P H O m ( 4 0 4 ) 6 7 9 - 5 2 7 3 FAX(404)679-0563 * T O L L FREE INSIDE GEORGlA(800)736-1155 228

..... .. ......

.. ...... ... GEORGIA'S FINANCIAL PARTNER .....

BONDS FOR INDUSTRY Summary For businesses seeking to expand, modemize, or locate in Georgia, long-term tax-exempt bond financing featuring a low cost of issuance is available through the Bonds for Industry (BFI) program. This program is offered by the Georgia Housing and Finance Authority (GHFA).

The Bonds for Industry program provides affordable access to tax-exempt bond financing for amounts as low as $500,000. Affordable tax-exempt bond financing is achieved through the use of a streamlined issuance process, standardized documents and a composite structure. The composite structure allows several borrowines to be combined into a single issue with a minimim size of $5 million. This economy of scale results in a low cost of issuance to borrowers. With a low cost of issuance and an effective interest rate significantly below the Prime Rate, Bonds for Industry financing provides an important new incentive for industrial expansion in Georgia.

Project Eligibility The central focus of the Bonds for Industry program is to offer businesses tax-exempt Private Activity Bond financing for manufacturing and related activities. Financing is also available for certain "exempt facilities" and the fixed asset needs of SOl(c)(3) non-profit corporations as permitted under the U.S. Intemal Revenue Code.

Program Structure and Credit Requirements The principal financing vehicle of the Bonds for Industry program is a composite tax-exempt variable rate demand bond (VRDB) with a rating of "AA" or better. Fixed-rate financing is also available. The VRDB composite issues are made up of several individual project financings totaling at least $5 million in the aggregate.

Letters of credit (LCs) supplied by banks are used to achieve a rating of "AA" on composite issues. Each borrower is required to supply a Stand-By LC as security. Individual borrowings backed by Stand-By LCs are, in tum, wrapped by a Master LC provided

The Bonds for Industry program provides affordable access to tax-exempt bond financing for amounts as low as $500,000. With a low cost of issuance and an erective interest rate significantly below the Prime Rate, Bonds for Industry financing provides an important new incentive for industrial expansion.

Key limitations placed on Private Activity Bond financings include a maximum capital expenditure for the overall project (whether or not financed) of $10 million. Other limitations include a 25% maximum use of bond proceeds for land purchase. Also, when proceeds are used to purchase an existing facility, the rehabilitation expenditures must exceed 15% of the cost of buildings and equipment financed with the proceeds of the issue.

by a bank-with a "AA" or better rating. The composite issue will then be rated by a national rating agency.

The interest rate on BFI loans is subject to weekly fluctuation based on changes in the demand for VRDBs. Borrowers have the option to fix their interest rate during the life of the loan by converting to a fixed-rate demand bond. Conversion costs will be paid by the borrower.

Program VRDBs may be redeemed by the borrower at any time subject to 45 days notice.

Time Frame and Interim Financing It is anticipated that Bonds for Industry will issue a comDosite bond at least

twice each year. Completed ipplications should be submitted two months in advance of a scheduled issue. A borrower wishing to begin a project in advance of the sale of bonds will be encouraged to seek interim financing from the bank committed to supply the Stand-By LC.

Cost Of Borrowine The cost of borrozng under the Bonds for Industry program may be grouped into two categories: issuance costs and effective interest rate. The program offers an "all-in" issuance cost of between 3% and 4% of the amount borrowed. This all-in issuance cost includes all items except the cost of borrower's counsel and the cost of establishing a

A BFI-financed project must also meet the job cre- atiodpreservation requirements of the Internal Revenue Code. Additional requirements imposed by GHFA are that the minimum amount that may be financed through the program is $500,000, and the project must have the support of the city or county in which it is located.

SUITE 250 - 6 0 EXECUTIVE PARK SOUTH, NE ATLANTA, GEORGIA - 303 2 9-2 2 3 1 PHONE ( 4 0 4 ) 6 7 9-5 2 7 3 * FAX ( 4 0 4 6 7 9-05 6 3 * TOLL FREE INSIDE GEORGIA ( 8 00) 7 3 6- 1 1 5 5

229

Stand-By LC. Variation within the 3% to 4% range will be driven by the overall size of the composite issue rather than the size of individual borrowings. Up to 2% of issuance costs may be financed as a part of the issue.

The effective interest rate on BFI loans is determined by several factors: *Floating (VRDB) interest rate for “AA+”-rated, tax- exempt bonds adjusted weekly in response to market demand. *Annual cost of maintaining Master LC. *Annual cost of administration including remarketing, rating and trustee services. *Annual cost of maintaining Stand-By LC.

The combined costs of the VRDB interest rate, the Master LC and the program administration fee will typically yield a borrower cost of approximately 60% of Prime. Addition of the annual Stand-By LC fee will increase the effective interest rate accordingly.

Borrower Benefits The program offers interest costs of approximately 60% of Prime. When the borrower‘s annual Stand-By LC cost

is added, the effective interest rate will be 70% to 80% of Prime. This low cost financing will be accomplished by generating loan funds through the sale of tax-exempt bonds and by employing a streamlined bond issuance- structure designed to provide economies of scale. The savings are passed along to the borrower in the form of lower interest rates. Other BFI benefits include: OLong-Tem Financing: Available loan terms range from ~

5 to 30 years. The actual term of a loan will be based on the life of the asset to be financed and the financial needs of the borrower. *No Pre-Payment Penalty: No penalty will be charged borrowers for pre-payment of outstanding loan principal set at a variable interest rate. *Assumable Lwns: In the event a participant business is sold, debt owed under the original loan is wholly assumable by the new ownership.

~

How to Apply Businesses contemplating a project that may be suitable for tax-exempt financing through the Bonds for Industry program are encouraged to contact John Kingery at (404) 679-5277.

230

GEORGIA’S FINANCIAL PARTNER

LOANS FOR RURAL INDUSTRY

Summary The Loans for Rural Industry (LFRI) program offers low- cost, medium-term financing to businesses located in Georgia’s rural areas. LFRI loans may be made to businesses engaged in manufacturing, production, ware- housing, distribution and other “value-added” activities for a variety of purposes. Loans range in size from $10,000 to $150,000 and carry a 50% matching investment requirement. The LFRI program is operated by the Georgia Housing and Finance Authority (GHFA) with capital provided by the Rural Development Administration, a division of the United States Department of Agriculture.

Available Financing The central focus of the LFRI program is to encourage job creation and preservation by helping to meet the financing needs of Georgia’s small to medium-size existing businesses. These loans may also be used to finance the establishment of new businesses. LFRI loans carry a fixed interest rate. The actual rate is set at closing, typically at or below the prevailing prime rate. Loan terms range from one to seven years with repayment schedules available on a monthly or quarterly basis. At least 10% of the total number of jobs created or retained as a result of an LFRI financed project must go to persons of low or moderate income.

Project Eligibility The program is targeted to businesses located or seeking :o locate outside the state’s major metropolitan areas. LFRI loans may not be made within cities with a popu- ation exceeding 25,000.

The central focus of the LFRI program is to encourage job creation and preservation by helping to meet the financing needs of Georgia’s small to medium- size existing busi- n esses .

Within the context of these requirements, LFRI funds may be used for the following purposes:

*Construction, enlargement, repair or

*Purchase and development of land, easements, or

*Purchase of equipment, machinery or supplies. *Pollution control or abatement. *Acquisition or conversion of a business where there is a strong possibility of that business closing or relocating.

*Feasibility studies, loan packaging, environmental data collection and other professional services.

*Limited agricultural purposes, including aquacul- ture, forestry, livestock and poultry processing, mushroom cultivation and hydroponics.

*Working capital.

modernization.

rights of way.

LFRI funds may not be used for the following purposes: .Agricul tural production. .Lines of credit. *Retail enterprises. *Tourist facilities. Charitable institutions.

Program Costs *Application fee of $250, payable upon application. This fee is applicable to the facility fee.

*Facility fee of 1% of the amount borrowed, payable at closing. This fee may be financed as a part of the LFRI loan.

*Closing and related costs, payable at closing. *Interest rate typically at or below Prime, fixed at closing.

How to Apply Businesses contemplating a project that may be suitable for financing through the Loans for Kurai Industry program are encouraged to contact Lany Warner at (404) 679-5279.

SUITE 250 - 6 0 EXECUTM PARK “NE * /ULANTA,GEORCLA - 303 2 9-2 2 3 1 PHONE ( 4 0 4 6 7 9-5 2 7 3 * FAX ( 4 0 4 6 7 9-05 6 3 * TOLL FREE INSIDE GEORGIA ( 6 0 0 ) 7 3 6- 1 1 5 5

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INCENTIVE LOANS FOR INDUSTRY

Summary The Incentive Loans for Industry (ILFI) program provides low-interest interim or medium-term loans to manufacturing and other specific “value added” businesses. Loan proceeds may be applied to fixed asset financing, real estate or working capital. The loan purposes are critical to the creation or preservation of jobs provided by those businesses.

Loan amounts can range from a minimum of $20,000 to a maximum of $300,000. At least a two to one ratio of direct private investment to the ILFI loan will be required of borrowers. As an example, a $150,000 commitment will leverage a project costing at least $450,000.

Loans will have a term that closely matches the life of the asset financed ranging from one year to ten years. The interest rate is fixed at the time of loan closing, typically at or below the prevailing Prime lending rate. Loans are collateralized and may be in a shared posi- tion with a private lender.

Project Eligibility Qualified businesses located or seeking to locate in counties identified by the US. Economic Development Administration as “economically distressed” as well as counties declared to be disaster areas by the state and/or federal governments are eligible to apply for ILFI financing. ILFI loans are made by GHFA directly to private industries. Prospective borrowers must comply with all applicable federal statutory and regulatory requirements.

Although the interest rate on ILFI loans typically is set at or below Prime at the time of loan closing, the minimum interest rate allowed may not fall below 4%. No [LFI funds may be used to relocate jobs from one labor market area to another. A borrower is not eligible for [LFI financing if suitable credit arrangements are available elsewhere. An exception to this requirement entails ising ILFI financing as an incentive for attracting new msiness or business expansion.

The Incentive Loans for Industry fund is capitalized at $2 million. These funds were provided in equal amounts by the State of Georgia and the U.S. Economic Development Administration.

Program Costs .Application fee of $250, payable upon application. This fee is applicable to the facility fee. *Facility fee of 1% of the amount borrowed, payable at closing. This fee may be financed as a part of the ILFI loan. Closing and related costs, payable at closing. .Fixed interest rate typically set at or below the Prime rate at closing.

How to Apply Businesses contemplating a project that may be suitable for financing through the Incentive Loans for Industry program are encouraged to contact Larry Warner at (404) 679-5279.

(ILFI ELIGIBLE GEORGIA COUNTIES Listed on Back Page)

... businesses located or seeking to locate in counties identified by the U.S. Economic Development Admin- istration as “economically distressed as well as counties declared to be disaster areas b the emmen& are eligible. state and/or federa Y gov-

S U m 250 * 60 EXECUTNE PhRK SOUTH, NE * PJLAmGEORClh * 3 0 3 2 9-2 2 3 1 PHoNE(404) 6 79-52 73 * FAX(404) 6 79-0563 - TOLL FREE INSIDE CEORClA ( 8 0 0 ) 736-1 1 5 5

233

.

ILFI ELIGIBLE GEORGIA COUNTIES

Appling Atkinson Bacon Baker Barrow Ben Hill Bibb Brantley Brooks Bryan Bulloch Burke Butts Calhoun Camden Candler Carroll* Charlton Chatham* Chattahoochee Chattooga Clay Clayton* Clinch Coffee Colquitt Cook Coweta* Craw ford

Da e Decatur Dodge Dooly Dougherty Early Echols Effingham* Elbert Emanuel

Evans Fannin Fayette Floyd Franklin Fulton Greene Gilmer Grady Hancock Haralson Heard Henry* Houston* Irwin

;::/Eivis Jefferson Jenkins Johnson Jones* Lamar* Lanier Lee* Liberty Long Macon Madison Marion McDuffie McIntosh Meriwe ther Miller Mitchell Monroe Montgomery Morgan Muscogee Newton* Oglethorpe

Peach Pierce Pike* Polk Pulaski* Quitman Randolph Rockdale * Schley Screven Seminole Spalding* Stewart Sumter Talbot Taliaferro Tattnall Taylor Telfair Terrell Thomas Tift* Toombs Treutlen Troup* Turner Wiggs Union Upson* Walker Walton Washington Ware Warren Wayne Webster Wheeler Wilcox Wilkinson Worth

* Eligible as of 11/94 due to FederaVState disaster declaration. Check with rogram

staff to determine current eligi E ility.

234


giving them improved access to affordable working capital. With all decision making at the state level, this program offers a shorter tum around time and greater flexibility in dealing with business needs.

Available Financing *Loan guarantees for the lessor of 90% of cost of goods sold or $500,000. *No minimum guarantee size.

EXPORT FINANCE ASSISTANCE FOR GEORGIA COMPANIES

offered by The Export-Import Bank of the new program, Oper- United States (Eximbank) and the Small in partnersh@ wrrh Business Administration (SBA). Services

Georgia3 banking COm- include: 1) packaging and expedited pro- mUnifJ’, is designed to cessing of applications for Eximbank and better serve the needs of SBA export working capital guarantees, the State’s smaller and 2) referral to other programs offered exporters by giving them by these agencies. im roved access to a&rdable working capi- Federal Guarantee Packaging Services

Financing assistance provided by the tal.

Program Eligibility Referral Services *Export product must be of at least 51% Georgia origin. *Georgia exporter must have been in business at least one year. *Georgia exporter must have firm export order prior to seeking guarantee.

Program Costs

for Additional Federal Assistance GHFA staff maintains up-to-date knowledge ~f exporter assistance programs offered by these federal agencies, as well as working relationships with their staffs. With this combination, GHFA staff is equipped to recommend the best match between an exporter’s financial need and available assistance and provide quick access to that

S U m 250 * 60 EXECUThE P M K WLITH, NE - “u GEORGIA * 3 0 3 2 9-2 2 3 1 PHONE(404) 6 79-5 2 7 3 * FAX(404) 6 79-05 6 3 * TOLL FREE INSIDE GEORGIA ( 8 0 0 ) 736-1 ’1 5 5

235

best watch between an exporter‘s financial need and available assistance and provide quick access to that assistance.

Eximbank offers the following export financing assistance products: *Working capital guarantees. *Medium-term guarantees. *Direct loans. *Foreign credit insurance.

SBA offers working capital guarantees in support of export sales.

Financing Available Under EWCP Though the Export Working Capital Program is operated by Eximbank and SBA in a complementary fashion, certain features of the program are unique to each agency. The financing needs of the exporter, the nature of their business and the products being exported will determine which of the agencies will make the guarantee.

The EWCP offers the following features for both Eximbank and SBA guarantees: 090% guarantee.

*Exporter must have proven need for financing. *Maximum term of financing is 1 year. *Unavailable for support of sales to foreign military. *Export product must be of at least 51% U.S. origin. *Preliminary commitment is good for 6 months.

Unique SBA features .Entertains all applications for loan guarantees of up to $750,000 (equivalent to loans of less than $833,333). *Exporter must be a small business as defined by SBA. *Maximum term of financine is 3 Years.

GHFA staff is e uip ed to recommend t % E e est match between an exporter’s financial need and available assistance and provide quick access to that assistance.

*Guarantees to support specific transactions or a revolving line. *No minimum or maximum amount (though the amount requested will determine which agency will provide the guarantee). *Exporter must have been in business at least one year. *Exporter must be able to demonstrate financial strength to support loan. *Export transaction must involve a country approved by Eximbank’s Country Limitation Schedule. *Exporting company must have business operations in U.S..

Unlqlre Eximbank Features *Entertains all applications for loan guarantees over $750,000 (equivalent to loans of greater than $833,333).

*Military d e s aie allowed. *No U.S. content requirement. *Preliminary commitment is good for 60 days.

Program Costs: Eximbank EWCP *GHFA Packaging Fee: 0.5% of guarantee amount,with $250 payable upon engagement and balance payable upon closing. .Eximbank Application Fee: $100 payable upon submission of application to Eximbank.

*Eximbank Facility Fee: 0.75% of guarantee amount for up to six months, or 1.50% of guarantee for up to one year. *No charge for referral to other Eximbank programs.

Program Costs: SBA EWCP *GHFA Packaging Fee: $50 per hour up to 0.5% of guarantee amount, with $250 payable upon engagement and balance due at closing. *SBA Application Fee: $100 payable upon submission of application to SBA. *SBA Facility Fee: 0.25% of guarantee for up to one year or 2% of guarantee for over one year.

How to Apply Businesses contemplating a project that may be suitable for financing available through the City/State Program are encouraged to contact Jean Prasher at (404) 679- 5278.

236

Mike Brewster CSK Technical, Inc.

237

Use of Ozone to Renovate Dyebath Water

Ed Fouche North Carolina State University

239

. 240

Use of Ozone to Renovate Dyebat h Water

1. EPRl Research Project 3329-04

Princioal lnvestiaators Warren S. Perkins and W.K. Walsh Auburn University

Sponsors Southem Company Services Electric Power Research Institute

2. EPRl Plant Demonstration Project TC 4813

Princioal lnvestiaator Liz Philpot Southem Company Services

SDonsors Southern Company Services Russell Corporation Electric Power Research Institute Carolina Power and Light Company Duke Power Company Tennessee Valley Authority Cotton Incorporated

Presented by Ed Fouche Electric Power Research Institute (EPRI) Textile Office

Presented to CATEC’95 Georgia Center for Continuing Education The University of Georgia Athens, Georgia

February 2,1995 24 1

EPRl Research Project 3329-04

Background

The objective of this project was to evaluate the technical and economic feasibility of renovating spent reactive dyebath wastewater with ozone.

Color is a pollutant in textile wastewater. Color in textile wastewater results from incomplete fixation of dyes to textile materials in dyeing and finishing processes. Dye that is not fixed is washed from the fabric at the end of the coloration process and enters the wastewater from the plant. Color is a special problem in waste treatment because biological waste treatment systems do not remove color well. Elimination of color from textile wastewater is of both immediate and long term interest to textile manufacturers. Textile manufacturers either currently or will in the future have to limit the discharge of color from their plants. The ability to economically eliminate or lower the amount of color in textile wastewater will have a major influence on the continued viability of many textile manufacturing plants. Historically, most textile plants have favored treating wastewater after it leaves the plant rather than eliminating pollutants at their source in the manufacturing process.

Reduction or elimination of pollutants at their source presents textile companies an opportunity for recycle and recovery of resources. Technology needs to be developed for removal of color at its source (dyeing processes) before it has been diluted by wastewater from other parts of the textile manufacturing plant. Elimination of color from dyebath water after dyeing may make the water suitable for reuse in the dyeing process or in some other process in the manufacturing plant. Dyebath wastewater also contains valuable chemicals and heat which can possibly be recycled if the color in the water is destroyed.

Ozonation and Dyebath Reuse Study

A dyebath reuse study was done using dye formulations provided by Russell Corporation for ten [IO] commercial dye shades. A schematic diagram of the experimental process is shown in Figure 1. The 10 shades comprised a range of hues across the spectrum ana depths ranging from very dark to pastel colors. The effect of dyebath additives used at Russell Corporation on the rate of color removal by ozone was studied in batch

242

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RP3329-04

ozone. However, the silicone-type antifoam decreased the rate of color removal by ozone.

DYEBATH REUSE MATERIAL BALANCE (ONE DYEING, POUNDS)

5004 WATER X DYE

lo00 FABRIC I . I 3336 WATER MACHINE

27 CAUSTIC 833 SALT

[AM TO pH = 10.5)

500 SALT _____)

.24x DYE _____)

CAUSTIC .____)

60%

.16x DYE 1 3336 WATER

SPENT DY EBATH

40% CAUSTIC 1000 FABRIC .8x DYE 333 SALT

TREATED WATER

5004 WATER

500 SALT BUFFERS

5004 WATER 500 SALT DYE DECOMP PRODS ORGANIC SALTS (BUFFERS)

Figure 1 Schematic Diagram of the Dyebath Reuse Process

Dyeings were performed in a Unimac Tumbler type dye machine. The scale of the machine was about 1/100th of a commercial machine Batches ob fabric weighing 18 pounds each were dyed. West Point Foundry and Machine Company equipped the machine with a system to collect spent dyebath water and recharge the ozonated (decolorized) water to the dye machine on demand. A single, packed column ozone contactor was used to decolorize spent dyebaths for the dyebath reuse experiments. Operation was with downflow of dyebath waste and upflow of ozone.

243

RP3329-04

2% Ozone from air

Dyeing in recycled water required using a standard dye formulation. The formulation used in the study was derived from common procedures used in commercial practice by Russell Corporation. The quantities of dyes used were provided by Russell Corporation and were exactly the same in dyeings in fresh water and ozonated water.

- MACHI NE S MACH IN E S MACHINES

1.34 .88 .82

The dyeing and reuse experiments were designed to simulate as closely as possible the reuse of dyebath water in a commercial dyehouse. Each of the ten dye shades was dyed using procedures and dye formulations provided by Russell Corporation. The spent dyebath water from each of these dyeings was saved and mixed together. A portion of the mixed spent dyebath water was filtered through Whatman Number 1 filter paper to remove dye particles and lint. The filtered water was ozonated to remove 60 - 99% of the color, and this water was used to dye the first shade. The water from this dyeing was collected, filtered, ozonated, and used to dye the next shade. This sequence was repeated until all ten of the shades were dyed in recycled water. Color reproducibility in ozonated water was good. The pastel colors required a high degree of color removal from spent dyebath water in order to achieve brightness equivalent to the shade dyed in fresh water. Fastness of the dyeings to light and washing was equivalent for dyeings done in fresh water and ozonated water.

~

~

Economics of Dyebath Renovation Using Ozone

An economic analysis of renovation of spent reactive dyebaths was done. The reuse of salt in the renovated dyebath provides most of the savings associated with dyebath reuse. Significant savings also come from reductions in water, alkali, energy, and effluent treatment requirements. A summary of payback times for several situations is shown in Table 1. Payback time is shorter for a larger number of dye machines because larger systems have lower equipment costs and lower operating costs per unit of ozone produced. Payback time is shorter for systems based on liquid oxygen (LOX) than for systems based on air even though operating costs are higher for systems using LOX. Operating costs for systems based on LOX are higher because of the high cost of LOX itself. Equipment costs are higher for systems based on air because air preparation equipment must be included in the system.

Table 1 Before Tax Payback Time. for Dyebath Reuse Systems Using Ozone for Color

Removal

SYSTEM f PAYBACK TIME (YEARS) FOR PROCESS USING: 11 t 5 DYE I 10 DYE I 20 DYE II

4% Ozone from LOX 1.12 .64 .56 I 244

RP3329-04

Kinetics

Kinetic studies and decolorization optimization studies were done to aid in designing the dyebath reuse system. These studies were done in a batch ozone contactor. The effects of variables such as temperature, pH, and ozone concentration in the gas stream on decolorization of dyes were studied. The reaction rates were first order with respect to dye. Therefore, the decolorization rate and efficiency of the contactor decreased as the concentration of color in the water decreased. All of the water soluble dyes studied decolorized rapidly when treated with ozone. Temperature and pH variation had only small effects on the reaction rates. The amount of ozone required to decolorize a given dye depended on the quantity of dye decolorized and the extent of color removal achieved. Side reactions of ozone with the dye molecule that do not result in color removal caused higher ozone consumption at high levels of color removal.

Reaction Mechanism of Ozone with Dyes

A study of reaction products of ozonation of dyes was done in order to increase our knowledge of the mechanisms of reaction of ozone with dyes. Two disperse dyes were selected for this study. One was a monazo structure and the other an anthraquinone type. These two dyes were selected for study of reaction products of ozone with dyes because they are simple in molecular structure and representative of the two largest structural classes of dyes used in textiles. Pure samples of the dyes were available from previous studies. The ozonated solutions were analyzed with gas chromatography and mass spectroscopy (GC/mass spec). More than thirty [30] reaction products were separated by gas chromatography from ozonated solutions of the two dyes. Some of the products probably came from the ethanol which was used as a solvent for the dyes in the ozonation treatment. The fact that so many products were formed by ozonation shows the complexity of studying reactions of dyes with ozone. The two dyes were highly purified for this study, and both are relatively simple dye structures. Even though efforts were made to simplify the study, ozonation produced a complex mixture of reaction products.

Effect of Oxidation on Aquatic Toxicity of Dyes

The effect of decolorizing with chlorine and ozone on the toxicity of selected reactive dyes was measured using duckweed as the test organism. The growth rate of duckweed was determined as a function of the concentration of reactive dye present. The untreated dyes were nontoxic to duckweed except at very high concentrations which almost entirely blocked penetration of light into the dye solutions. Decolorization of these dyes with either chlorine or ozone increased their toxicity to duckweed. Furthermore, decolorizing with chlorine caused a greater increase in toxicity than did decolorization with ozone.

245

RP3329-01

These results suggest that use of chlorine or ozone for color removal from textile wastewater has the potential to increase aquatic toxicity of the wastewater. However, the effect from the use of ozone for source reduction of color on toxicity of wastewater from textile manufacturing plants will be limited in commercial application for the following reasons:

1. The test dye solutions used in this work contain only the dye products themselves and none of the auxiliaries that are commonly used in dye formulations.

2. The dye solutions used in this study were designed to approximate the dye concentrations that would be present in spent dyebath. Therefore, the dye concentrations were many times higher than would ever be the case in actual textile wastewater.

3. Dyes comprise only a small fraction of the chemical content of textile finishing plant wastewater. Textile wastewater is complex, and other pollutants such as electrolytes and heavy metals are probably more important contributors to its toxicity than are the organics contributed by dyes and dye decomposition products.

4. Published studies have reported that ozonation of waste before biological treatment actually makes the waste more amenable to biodegradation (1). The concept in dyebath reuse puts decolorization treatment before biological waste treat men t .

Perkins (2) and coworkers reported that biological reactors performed well on chlorinated and ozonated spent dyebath water with high BOD and COD removals and good sludge settleability. Bioassay studies revealed that chlorinated and ozonated waste was no more toxic to catfish fingerlings than was untreated waste. Matsui (3) also reported that solutions of ozonated dyes were more biodegradable than the same untreated dyes. Even though the present study indicates that ozonation increases aquatic toxicity of the dyes studied, it does not logically follow that ozonation would have an adverse affect on toxicity if the ozonated dye were subsequently biologically treated.

Conclusions

1. Use of ozone to renovate spent dyebaths from reactive dyeing of cotton is technically feasible.

2. Reuse of ozonated water saves chemicals (mainly salt), water, wastewater treatment expense, and energy. __

3. The savings achieved by reuse of ozonated dyebath water provide before tax payback of the capital investment in approximately .64 years for a system using 10 jet dye machines and ozone generated from liquid oxygen. Payback for other systems

246

RP3329-04

depends on size of the system, ozone generation method, and the fraction of dyebath water that can be collected for ozonation.

4. Ozone decolorizes dyes mainly by breaking double bonds such as azo, -N=N-, groups in the dye molecules. Ozonation of dyes also forms organic acids, such as oxalic acid which partially neutralize residual alkali in spent reactive dyeing water.

5. Reactive dye solutions decolorized by ozone are toxic to duckweed at about one- third to one-twentieth the concentration of the untreated reactive dyes themselves.

6. The higher toxicity of ozonated reactive dyes (compared to untreated dyes) does not necessarily imply that the total plant effluent will be significantly more toxic before or after tvpical biolooical treatment.

Decolorization of reactive dyes by ozonation was slightly faster at 24°C than at 50°C. The reaction rate constant for color removal from a solution of C.1. Reactive Red 195 with ozone was 17% higher at 24°C than at 50°C.

7.

8. The effect of pH on rate of color removal from reactive dye solutions with ozone was small. The difference in color removal rate from a solutions of C.I. Reactive Red 195 with ozone was less than 5% over the pH range from 2.5 to 11.25.

9. Presence of dyebath lubricant and a chelating agent used in reactive dyeing did not affect rate of color removal with ozone or amount of ozone consumed. A defoamer used in reactive dyeing decreased the rate of decolorization of the dye by ozone by about 50%. However, the ozone reauirement to achieve >90% color removal was not affected by the presence of the defoamer.

10. Quality of dyeings done in spent dyebath water renovated by ozonation was equivalent to that of dyeings done in fresh water.

Recommendations

1. Perform a large scale demonstration of reuse of spent reactive dyebath water using ozone.

2. Study economic feasibility of use of ozone for source reduction of color pollution in systems using dye classes other than reactive dyes.

3. Do additionai studies of economic and technical feasibility of renovation of spent reactive dyebath water using ultraviolet IighVhydrogen peroxide technology.

247

References

1.

2.

3.

M. Matsui, K. Kobayashi, K. Shibata, and Y. Takase, Ozonation of Dyes VI: Reaction of Chrysophenine G with Ozone in Water, American Dyestuff Reporter, Vol. 10, No. 1983, p. 40-41

Warren S. Perkins, Joseph F. Judkins, and William D. Perry, Renovation of Dyebath Water by Chlorination or Ozonation, Part 3: Waste Water Treatment, Textile Chemist and Colorist, Vol. 12, p. 262-272, October, 1980.

M. Matsui, K. Tsuboto, K. Shibata, and Y. Takase, Reaction of Water Soluble Dyes with Ozone, Journal of the Society of Dyers and Colourists, Vol. 100, No. 4, 1984, p. 125-1 27.

248

EPRI Plant Demonstration Project TC 4813 Industrial Technologies for Improving the Competitiveness and Environmental Stewardship of the Textile Industry (Fiber Mfg., Textile Mfg., AppareVFabricated Products Mfg. Textile Machinery Mfg.)

Part 2 - Commercial Demonstration of Ozone Dye Bath Renovation

Project Scope and Deliverables

Three of the most critical issues facing the Textile Industry are effluent color, salt discharge and aquatic toxicity. The cost of any effluent treatment system emphasizes the need to eliminate raw material waste at the point of use and to recover as much as possible for reuse. Fiber reactive exhaust dyeing results in an estimated discharge of effluent that contains 1,500 million pounds of salt per year and the recovery and reuse of salt from this process would have significant economic and environmental impact. Pilot studies at Auburn, sponsored by EPRI and Southern Company Services (RP 3329-04), indicate that ozonation of spent fiber reactive dye baths effectively removes color and allows acceptable dyeing with the recovered water and salt. A commercial demonstration of this process is needed to confirm the pilot results in a production setting.

This project will scale up the Auburn pilot study to evaluate ozone renovation and reuse of spent fiber reactive dye baths from one or more exhaust dyeing machines in a production setting over a six month period and provide participants the following deliverables:

1. Participation in the project’s Technical Advisory Committee and (a) provide inputs to the detailed project work plan, (b) periodically review the project results, (c) provide guidance as the work progresses.

2. Observe the operation of the ozone equipment and the recovery/reuse process.

3. Final report and periodic progress reports.

Evaluate shade matching, shade reproducibility and dyed fabric performance.

Quantify the potential economic and environmental benefits for the industrial participants.

Quantify the potential energy impact for the utility participants.

249

4. Be provided with equipment and process specifications that will allow duplication of the results by the industrial participants.

5. Establish a basis for continuation of funded research to evaluate alternative advanced oxidation methods, membrane separation and other applicable electrotechnologies.

6. Promote the transfer of beneficial new electric based technology to industry.

R&D Issues/Content

Identification of Reaction Products of Ozonation - Gas chromatography and mass spectroscopy will be used to separate and identify reaction products.

Toxicity - Aquatic toxicity of the reaction products will be studied using duckweed.

Kinetics of Ozonation - Rate isotherms will be determined for each dye.

Effect of Temperature - The effect of temperature on the ozone reaction rate will be determined.

Effect of pH - The effect of pH on the ozone reaction rate will be determined.

Effect of Dyeing Auxiliaries - The effect of each chemical additive in the dyeing formulation on the ozone reaction rate will be determined.

Effect of Ozone Dosing Rate - The most cost effective ozone concentration and feed rate will be determined.

Shade Matching/Reproducibility - Results obtained with the ozonated dye baths will be compared to results achieved using fresh water.

Color Fastness - Color fastness of samples dyed in ozonated water will be evaluated for light fastness, washing fastness and crocking fastness in comparison to fresh water dyeings.

250

EPRI TEXTILE OFFICE SLIDES

Presented by Ed Fouche EPRI Textile Office

Presented to CATEC’95 Athens, GA February 2,1995

25 1

2

EPRI ELECTRIC POWER

RESEARCH INSTITUTE ~

~

Founded in 1973 Funded by 700' Member Utilities 350+ Scientists Manage 1600+ Projects Process Industry Offices - Chemical tk Petroleum (Houston, TX) - Food & Agriculture (Walnut Creek, CAI - Pulp &Paper (Atlanta, GA) - Textile (NCSU- COT Raleigh, NC)

Electotechnologies - Environmentally Responsible Solutions For a Competitive Industry - Ozone Benign Refrigerants - Recover tk Reuse Raw Materials - Cleaner Emissions - Effluent Reduction & Treatment - Improved Produstivit). - Cost-effective Use of Electricity

EPRl TEXTILE OFFICE 1 I1 2/95

252

EPRI TEXTILE OFFICE

II .

I

MISSION - To improve the competitiveness and environmental stewardship of the Textile Industry through the development and ,

application of benefitial electrotechnologies

V12/9 5

\ A

EPRI / TEXTILE OFFICE

FOCUS Collaborative R& Technical Support Communication

>>

>>

>>

Publications Workshops Conferences

D Projects

1/12/95

EPRl TEXTILE OFFICE Electric Power Research Institute

UTlLlTlES 1. 2. 3. 4. 5. 6. 7.

Alabama Power Company - C. Frederick Will Carolina Power & Light Company - Terry Hatcher Duke Power Company - Bany Batson Georgia Power Company - Garnett Grubb New England Electric- Margaret Campbell South Carolina Electric & Gas - Steve Adams Tennessee Valley Authority - Vernon R. Knight, Jr.

TEXTlLElNDUSTRY 8. 9. 10. 11. 12. 13. 14.

Cone Mills Corporation - Mather Whitehead Cranston Print Works - Leonard Rudolph Glen Raven Mills - Charles McKeller Milliken Corporation - David Beard Mt. Vernon Mills - Ray Mabry Russell Corporation - Sam Patterson Springs Industries - Ben Knott

UCATION AL INSTITUTIO NS 15. Institute of Textile Technology - Don Alexander

STATE AL NC NC/SC GA MAJRI sc TN

NC MA NC sc GNSI AL sc

VA

GOVERNMENT 16. Department of Energy - Brian Volintine - 17. American Textile Manufacturers Institute - Jerome D. Hayes

fl 18. 19.

Gaston County Dyeing Machine Co. - Gordon Hacker West Point Foundry and Machine Co. - Don Cotney

IC10 20. 21. 22.

Electric Power Research Institute - K. R. Amarnath EPRl Textile Office - Ed Fouche NCSU College of Textiles - Perry L. Grady

National

National

NC GA

National National NC

255

Electric Power Research lnsti tute

WASTEWATER COMMllTEE

UTILITIES 1. Duke Power Company - Barry Batson 2. Southern Company Services - Liz Philpot

TEXTILE INDUSTRY 3. Cone Mills Corporation - Arthur Toompas 4. Ciba Geigy - Sue Wagner 5. Milliken Corporation - Dr. Jeff Sillman

EDUCATIONAL INSTITUTIONS 6. Auburn University - Warren Perkins 7. Georgia Institute of Technology - Dr. Wayne Tincher 8. Institute of Textile Technology - Mike Bahorsky

TRADE ASSOCIATION 9. American Textile Manufacturers Institute - Jerry Hayes

EX-OFFICIO 10. EPRl Textile Office - Ed Fouche

STATE NC/SC

AL

NC NC sc

AL GA VA

National

National

256

i

EPRl TEXTILE OFFICE CURRENT PROJECTS

I

IIUIW DRYING SIZED YARNS - Increased Productivity - Eliminate Boilers/Storage Tanks

ULTRASONIC WET PROCESSING - Improved Quality - Increased Productivity - Increased Energy Efficiency - Reduced Dye/Chemical Use - Cleaner Effluent

WASTEWATER TREATMENT/REDUCTION - Effluent Color Removal Evaluated - Source Reduction

N Ozone Dyebath Renovation

ENERGY MANAGEMENT SOFTWARE

FABRIC DRYING / CURING OPTIMIZATION - Increased Productivity - Lower Energy Costs - Reduced Emissions

25 7 1/12/95

OZONE RENOVATION FIBER REACTIVE EXHAUST DYEING

DYEBATH

x DYE - 1000 FABRIC - 333 6 WATER - 333 SALT -

27 CAUSTIC (50%) _____+L

'

I f (AOIJ TO pH = 10.5:

DYE

MACHINE

8340 WATER

x DYE

loo0 FABRIC

633 SALT

5004 WATER -T

500 SALT ---T

.24x DYE - CAUSTIC -

6OY.

.16x DYE 3336 WATER

loo0 FAORIC .6x DYE 333 SALT

40Y1 CAUSTIC

5OCZ VIAT E F l

500 SAL1

BUFFERS

SPENT

WATER 5004 WATER

500 SALT

DYE DECOMP PRODS

OnCANlC SALTS (BUFFERS)

I ,

0

0

0

0

1

OZONE RENOVATION FIBER REACTIVE DYE BATHS BASIS FOR 20 JET MACHINES

Fabric (lb dyr) 16,000,000 Dye Bath Ozonated (lbs/yr) 80,000,000

Ozone From LOX (lbdyr) 60,000 Operating Costs

- Salt @ $0.05/lb - Caustic Soda (50%) 63 $0.05/lb

- Soda Ash @ $0.133/lb - Energy @ $4,3O/MBTU - Fresh Water - Effluent Treatment

@ $1.25/1,000 gallons @ $1.85/1,000 gallons

,259

.OZONE RENOVATION FIBER REACTIVE DYE BATHS

PAYBACK FOR 20 JET MACHINES

Savings

L

- Salt - Alkali - Water - Energy - Effluent Treatment

costs - Oxygen - Electricity - Cooling Water - Labor, Maint., Ins., Taxes

Total Annual Savings * Capital Required

Payback Before Tax

( $/year ) 400,000 75,000 12,000 17,000 18,000

( $/year) 88,000 15,000 8,000 4,000

$407,000 $240,000

7 Months

4/12/94

260

\

OZONE DYE BATH RENOVATION PLANT DEMO PROJECT

OBJECTIVE - TRANSFER TECHNOLOGY TO INDUSTRY BASIS (984 OPERATING HOURS) - 2 JET DYEING MACHINES - 180,000 LBS FABRIC - 900,000 LBS DYE BATH OZONATED - 675LBS OZONE

ESTIMATED COSTS - EQUIPMENT (44 LBS 03/DAY FROM 0 2 ) - SITE PREPARATION - OPERATING COSTS - TECH SUPPORT - REPORTING - PRQJECT MANAGEMENT TOTAL

$130,000 58,000 15,000 21,000 l0,OOO 11,000

$245,000

9/12/94

1 I OZONE RENOVATION FIBER REACTIVE EXHAUST DYEING

I/ II

INDUSTRY SAVINGS ( $20 MILLION/YEAR ) - $14 MILLION SALT SAVINGS - $ - $

3 MILLION ALKALI SAVINGS 1 MILLION ENERGY SAVINGS

h) - $ 1 MILLION WATER CONSUMPTION SAVINGS Q\ h) - $ I MILLION EFFLUENT TREATMENT SAVING

ENVIRONMENTAL IMPACT - COLOR REMOVAL FROM EFFLUENT (10 MIL. LBS OF DYE) - TOXICITY REMOVAL FROM EFFLUENT (280 MIL. LBS OF SALT)

UTILI Y IMPACT - 20 MILLION kWH /YEAR

9/12/94

Len Farias Cotton, Inc.

263

264

Toward Zero Discharge Dyeing

Wayne Tincher Georgia Institute of Technology

265

266

CONCURRENT SESSION - B

SOLID WASTE MINIMIZATION

11:oo - 3:45

Moderator: Ms. Svea Bogue

Executive Director Athens-Clarke County

Clean and Beautiful Commission

An Overview of CCACTI Solid Waste Minimization Projects

Sutish Kumar Georgia Institute of Technology

267

. --

Retrieva: The PET Generation

Linda Bavaro Global Green, Inc.

269

2 70

AT&T's Process of Waste in the Work Place

Gerald Lightsey AT&T

271

272

Practical Approaches to Solid Waste Disposal

Chuck McPherson KIBER Environmental Services, Inc.

273

274

-

Returnable Packaging in the Textile Industry

Stephen Powel T.H.E.M. International

2 75

276

RETURNABLE PACKAGING INNOVATIONS FOR THE TEXTILE INDUSTRY

Stephen S. Powel, President T.H.E.M. of Carolina, Inc.

The purpose of this presentation is to give textile executives an overview of the present status and future directions for returnable packaging systems in the textile industry. for packaging its yarn products, this topic is appropriate for anyone who is concerned about waste minimization, company finances and the use of returnable packaging.

I will present a brief background on packaging in the textile industry, with a discussion of innovations in the design process and in the development of returnable packaging systems.

While a company may have some unique requirements

Backaround

This presentation is based upon twenty years' experience in the packaging industry. During this time we have witnessed incredible changes in packaging for the textile industry. There have been fundamental changes in the materials used, how packages are designed and how packages are used. have gone from packages composed of simple wooden pallets and corrugated paper to systems which use one hundred percent recyclable plastics and result in no landfill waste.

We

This evolution has been greatly facilitated by changes both within and without the packaging industry. manufacturers have needed to reduce packaging waste, as well as reduce packaging and handling costs, and to have a standardized package throughout their system.

The packaging industry itself has been greatly facilitated by rapid development in the technology of plastics, advances in design technology for mechanical engineers, and improvement in methods for making tools and molds for packaging. engineer and design packaging to fit the specific and unique needs of a textile producer at a time when pressure is on the industry to change their traditional packaging methods.

I. Innovations In The Enaineerina And Desian Process

Textile

These advances allow packaging companies to

A. A Returnable Desian PhilosoDhv

Several trends are noticeable in the packaging of yarn product: manufacturing and handling costs, and robotic packing to

an increase in package and carton size to reduce

277

protect yarn quality. These changes require close tolerances, tight spacing and excellent package stability during shipping, creeling and beaming. These requirements are difficult to achieve with conventional corrugated designs. returnable systems, and should maximize savings in packaging costs, by using returnable packaging in place of disposable packaging.

They are easy to achieve with injection molded

Returnable packaging is being engineered and designed to accomplish multiple benefits for the textile manufacturer. It maximizes protection of the yarn product, by protecting yarn during packout, shipping and creeling. It maximizes quality assurance, by making packages capable of being part of an automated, no touch, system. It maximizes handling ergonomics, by making easy access packages which require minimum operator effort.

Packaging is also being designed to minimize packaging costs. Since the costs of a reusable package are directly related to the length of the package's useful life, the longer the package can be used, the lower the packaging cost per pound of yarn shipped. Experience suggests that a six year life expectancy with fifty trips is not unusual for a returnable POY package. Informal cost comparisons suggest that returnables usually break even at twelve to fifteen trips (1 1/2 to 2 years), which means substantial cost savings can be anticipated over the life of a reusable system.

Or, from another perspective, a returnable system costing $2.5 million with a six year life expectancy is clearly less expensive than buying $1.6 millon worth of corrugated annually.

(See Appendix B for further cost comparisons on reusable packaging.)

Returnable packaging is also being designed to maximize outbound shipping density, by making efficient use of the trailer cube while minimizing time required to load and unload; it maximizes return shipping density, by reducing the empty package density to minimize warehouse space and maximize the number of return units per truckload; it maximizes package life expectancy, by minimizing the stress loading of the package and by designing for easy forklift handling.

Finally, returnable packaging is being designed to minimize waste, by using recyclable resins for the package components, and by using a minimum of one trip components such as banding or film.

278

A well designed returnable system dramatically reduces or totally eliminates packaging waste. Additionally, by providing a superior degree of product protection, a returnable system dramatically reduces waste resulting from damaged yarn product.

For example, consider the experience of Hoechst Celanese when it implemented "C-Pack" returnable packaging at two plants in 1987. The '@C-Pack'' plastic container eliminated over 5,000 tons of corrugated waste annually.

As another example, a recently designed seventy pound carton which transports 48 textured yarn packages uses about two pounds of shrink film per trip. Both the shrink film and the basic plastic package are totally recyclable. simply is no landfill waste.

Even when returnable packages have reached their six year average life expectancy, they do not create waste or landfill problems. Reputable packaging suppliers buy back their spent components or customers are given credit for the value of their recycled components towards the cost of purchasing replacement packages.

There

B. Preliminam Desian Issues

Before a returnable packaging system can be designed, packaging engineers first detail and define the parameters for the particular package. These parameters include determining the number of packages needed (based on the producer's cycle and inventory time), package size, yarn package size and weight, truck density and weight limits, aisle width for the producer and customer, future requirements and applications of the package, quality assurance, and the producer's prioritized objectives.

Several factors are reviewed in some detail in Appendix C to demonstrate why these parameters can be important to the design process.

C. Enaineerina Of The Textile Packase

After gathering the producer's input and prioritized objectives, engineers design the package using a process we call llconcurrent engineering." Mechanical engineers make sophisticated full color 3-D solids models, using state-of- the-art C.A.E. (computer aided engineering) software on high speed work stations. Then, they run F.E.A. (finite element analysis) on the models, which is the best predictor of performance of a package. After looking at the results, the computer models are modified and redesigned as needed. After satisfactory F.E.A. testing, a full scale working model is then produced that can be loaded and tested by the producer and their customers. We then go to final

279

production molds and production of parts. Finally, we subject the production parts to further testing, such as strain gauging, to verify the F.E.A.

Before these computer advances, designs were based primarily on the knowledge and experience of the designers. models had to be built for prototype, tested, and redesigned as needed.

Actual

It was a time consuming process.

The present engineering system allows for multiple customer benefits: changes to the package if required: it enables the engineer to optimize the package for a variety of load situations: it enables the engineer to optimize mass distribution, which reduces component cost: it enables the engineer to computer simulate performance of the package under various conditions; it enables the engineer to generate prints for automators and plant personnel responsible for implementing the package; it enables the engineer to forecast the structural properties of a part prior to tooling: and it enables great improvements in the mold making operation.

This electronic information helps to produce the molds rapidly and without the mistakes often caused by a mold engineer misinterpreting a 2-D blue print. This process also eliminates most of the manual programming once required by the mold maker. delivered to a textile customer 6 to 8 weeks sooner than with standard methods.

It enables relatively fast and inexpensive

It enables returnable packaging to be

11. Innovations In The Manufacture Of Packaainq

A. Materials For Returnable Packaaina Svstems

The industry increasingly favors returnable packaging components made from plastics. (See Appendix D for the different materials which can be used for returnable packaging.) We use plastics most often because they offer the greatest freedom of design and generally produce the best cost/performance package, and they can be completely recyclable.

Some of the more innovative systems are using plastic exclusively. For example, HDPE (high density polyethylene) is being used for system components (pallets and separators), with the properties and dimensions of the components designed to fit the particular needs of the textile manufacturer and its customers. Plastic shrink or stretch wrap film is then used to cover the components and provide protection and stability for the overall package.

280

B. Manufacturina Process

The package designer makes choices related to the processing of the packaging material. properties of the resin with an appropriate processing method to develop the best package.

(See Appendix E for the principal processing methods along with their particular strengths, weaknesses, and recommended applications.)

In our opinion, the manufacturing process for most textile pallets and separators is structural foam injection molding. The process has great flexibility of design. Wall thickness can be varied and virtually any reinforcing configuration can be incorporated. It is well suited to rational design refinement with tools such as F.E.A. It works best when loads are relatively high, yarn package stability is critical, and volumes are at least five thousand parts.

The designer matches thg

111. Conclusion

Obtaining a functional package is not what it once was. package is no longer "just a boxt1 to carry yarn, decided upon between the producer's staff and the corrugated supplier. by the yarn producer, its customers, the automator and the package designer/supplier. the expectations from 'Ithe boxt1 are so much more.

For a place in the future of the industry, a package must be environmentally sound, cost effective, user friendly, and capable of being part of an automated system and assisting the movement of yarn from its creation to its use by the customer. It must have a long-term useful life.

A well designed reusable package is capable of fulfilling all these requirements and more. A high performance package not only carries the yarn safely but also enhances the image of the fiber producer as an innovative and progressive company. It provides the producer and its customers with financial advantages while preserving the environment for future generations.

A

A package now requires planning and coordination

This effort is required because

28 1

ApDendix A: Definition Of Terms Used In Paper

1. , llPackagell

llPackagell refers to any container designed for the transport of multiple yarn packages.

2. "Yarn Package"

"Yarn package" refers to a yarn carrier with yarn on it; whether on a tube, cone, or cheese.

3 . llReturnablell versus llReusablell Package

The term llreturnablell and the term llreusablell are used interchangeably. repeated use.

They refer to a package capable of

Germany now mandates that many forms of consumer packaging can be returned to the retailer for disposal. Some textile producers are essentially doing the same with some of their packaging waste. This involves return and sometimes recycling, but it is not what we mean when we talk of a I1returnabletl package which is one capable of repeated use.

4 . llRecycl ingV1

llRecyclingll refers to the process of taking a reclaimed waste and converting it into a usable product.

282

1. f

at f

I

1

IIIII

"r t

A?mendix C: Discussion Of Preliminary Desisn Issues

Several factors influencing the design of a returnable packaging system are viewed in some detail to demonstrate why it is important to define the parameters for a particular package at the outset of the design process.

1. Yarn Tubes

2.

Tolerances, orientation, saddling, bulging, and sloughing all need to be known at the outset of the design process. to carry some load, tube compression data is needed. If sloughing is a problem, good dimensional data on the package shape is needed. products will be packed and shipped with the tube in a vertical orientation, but this is not always the case. There are a few products which slough badly and whose delivery can be improved by shipping horizontally.

If the yarn producer relies on tubes

We tend to assume that most

Carton Layout

Most designs require extensive testing and modification to get a carton layout which optimizes handling and density. The designer usually does a number of layouts of possible configurations and applies judgement and experience about how the carton will handle and stack. While there are no absolute standards or rules as to carton layout, one generally avoids textile packages with a width under 30" for stability reasons.

3. Carton Stability

A new system should be engineered for package stability based on the yarn producerls requirements. requirements involve package handling and limits in shipping density. Reusable corrugated side panels provide great stability, but they cannot always be returned in the package. If that is the situation, or shipping density is an issue, one prefers to use film.

The structural stability of designs are checked with Finite Element Analysis (F.E.A.) or by dynamic modeling.Prototypes also help the packaging engineer and the yarn producer get a feel for carton stability and handling, and are a must if one is considering a complex system.

These

4. Automation

Ideally, the packing carton and the system for handling the packing of the yarn are designed in parallel. If a producer is planning to automate the packing operation,

284

the automation and carton designers should coordinate handling concepts. For example, if a producer's automation is geared toward handling separate components in magazines, it does not make sense to devise a clam-shell style return system which doubles handling labor. Conversely, if that is the most practical packaging system, the automator should have the flexibility to cope with it. both suppliers are involved as early as possible.

In reality, the operations of the textile producer and the producer's customers. Therefore, the package designer will need to know carton conveyor dimensions, special pallet truck requirements, and limitations on trailer size. This data provides key boundary dimensions in the package's design. know the "choke points" which may unduly constrain a new design.

All this is easier if

the carton usually must be compatible with

The package designer also should

Automated storage and retrieval systems impose serious constraints on package dimensions with few options for change. They may pose severe performance requirements for any carton system structurally.

5 . Life Expectancy of the Reusable Package

While there is no definitive answer as to the life expectancy of a returnable package, we can give some general guidelines.

Most plastics exhibit creep or stress relaxation. The package should be designed to minimize these effects. That usually means a package design must incorporate a safety cushion, because a six year life cycle exceeds the 10,000 hour creep data most resin manufacturers provide . With proper design, package failure from stress relaxation can be eliminated. But handling damage can also cause package failure. Data on failure rates from Hoechst Celanese shows loss rates of about 3.5% annually. There are indications that damage rates may vary by user such that operator training and attitudes can be as big a factor as is initial design, and suggest that close cooperation between the producer and customer should result in reducing overall costs. Even the best designs can fail when abused.

285

Jhmendix D:

Returnable packaging components can be made of a number of different elements. While the trend is toward making components from plastic, alternative compositions for packaging with their respective advantages and disadvantages are listed below:

1. Cellulosic materials (wood, pressed board, corrugated

Materials For Returnable Packaaina Svstems

paper)

The wood pallet has low initial costs and short lead times; it is easy to repair when damaged and can be chipped for eventual disposal. The down side is a high damage rate with a life expectancy of five to ten trips and the possibility of serious safety hazards. Perhaps the greatest liability is the limitations a wood pallet place on the design concept.

Paper products can have a large role in a returnable design. Corrugated side panels protect yarn packages and add stability to the package. returned inside the package, the side panels enjoy an eight to twelve trip life expectancy.

Corrugated and pressed board separator pads can be used for low volume internal components when one cannot justify the higher tooling costs for plastic components.

If they can be

2. Metals

Metals have been used in returnables, particularly in folding wire containers. They present many safety hazards when damaged and are difficult to repair. better use in current designs is as an internal reinforcement within twin-sheet or rotationally molded parts which will have to handle high stresses. A drawback to metal reinforcement is that it adds cost to the recycle process, but it is sometimes possible to salvage the frames intact for reuse.

A

3. Plastics

Plastics offer the greatest freedom of design and generally produce the best cost/performance package. They are the materials most often used in contemporary designs. Most packages use some form of nigh or low density polyethylene. Polypropylene or recycled nylon or polyester may be used for some more demanding applications.

286

Jitmendix E: Processina Methods For Moldina Plastics

Most often a designer will have to make choices related to processing the plastic, and there are about six principal methods with which they deal. below in approximate order of increased tooling cost:

These methods are listed

Extrusion Rotational Molding Single Sheet Vacuum Forming Twin Sheet Vacuum Forming Blow Molding Structural Foam Injection Molding High Pressure Injection Molding Hybrid Injection Molding

1. Extrusion

Both shrink and stretch films are the most widely used extruded products in packaging textiles. It is almost certain that one of these materials will be considered for any new package design. could use about two pounds of shrink film for product protection and package stabilization.

A textured yarn package

Plastic corrugated is another extruded product which is finding uses in returnables. We believe this is an interim solution for eliminating landfill waste while developing a more cost effective long term solution.

2. Rotational Molding

Rotational molding essentially consists of tumbling LDPE powder in a closed, heated mold until you have a near uniform distribution of material on all of the mold surfaces. You then cool the mold and remove the part. Mold costs are low, production is slow and tolerances must be large. It is relatively simple to add metal reinforcement so rotational molding is most competitive in low volume rackable applications; it is not suitable for high volume packages not requiring metal reinforcement.

3. Single Sheet Vacuum Forming

Vacuum forming consists of first extruding sheet to the starting gauge. to near the melting point and formed using a combination of vacuum and positive pressure over or into a single sided mold. are necessary and the vacuum former is able to vary the part characteristics through a trial and error process. Since only one side of the part is formed by the mold, the tooling costs are low but it is not possible to

In a second step the sheet is heated

Often a variety of assists

28 7

vary the thickness of the part at will.

The process finds application in light and medium duty nestable pallets and in low performance separator pads. We have generally not been satisfied with the ability of the process to form high accuracy locators; however, if yarn package stability is not critical the process can be very cost effective, The inability to control wall thicknesses creates problems in verifying designs reliably, a defect shared by all non-injection processes.

4. Twin Sheet Vacuum Forming

As the name implies, this is vacuum forming using two sheets. Essentially, two single sheet molds are used to form and weld two halves of the part together in one process. costs are about twice that of single sheet. In return you get a hollow structure with considerably greater stiffness for the weight. In fact, if one could control wall thicknesses and form complex detail twin sheet would be an almost ideal process. Unfortunately, these problems are compounded by the twin sheet process so there are some real limitations.

Since there are two mold halves, tooling

One experiences fairly long development cycles with twin sheeting. can spend more time refining a part than it took to tool it. at deep draw points so your design must take this into account .

It is as much art as science and you

All forming operations suffer from thinning

5. Blow Molding

Blow molding uses an extruded or injection molded tube called a parison which is clamped between two halves of a mold and forced to conform to the contours with high pressure air injected into the parison. Injection blow molding is used only for very high volume applications such as PET soft drink bottles. Conventional blow molding is used to make bottles, drums, gas tanks or almost any other parts that can be made with twin sheet vacuum forming. Currently there are few large machines available and the process has most of the same limitations as twin sheet molding as well as higher mold costs. We know of no active systems in the textile trade at present.

60 Structural Foam Injection Molding

Structural foam injection molding is a low pressure injection molding process which uses a two part closed mold to form both sides of a single wall part. It has

288

great flexibility of design. is usually about 5 m , it can be varied from 3mm to 15mm as required. needed. The foam is produced by either nitrogen gas injected into the polymer or through a chemical blowing agent; nitrogen is preferred because it has no adverse environmental or safety factors to deal with. result in dense skins with a cellular core.

While the wall thickness

Ribs and bosses can also be added as

Both

Injection pressures in the molds are about 300 PSI so the molds must be much more robust than twin sheet. Also the mold controls not just the part shape but also volume so accuracy is much more critical. Consequently mold costs are two to three times the costs for comparable twin sheet molds.

Since wall thickness can be varied and virtually any reinforcing configuration can be incorporated, the process is very suited to rational design refinement with tools such as Finite Element Analysis. This is very important advantage because it allows the packaging engineer to guarantee the structural properties of a part prior to starting tooling. we are able to use F.E.A. to optimize mass distribution which allows our designs to approach the minimum feasible mass which of course reduces cost. experience suggests that the process competes best when loads are relatively high, yarn package stability is critical, and volumes are at least five thousands parts

Also

Our past

7. High Pressure Injection Molding

High pressure injection molds are similar to structural foam molds but they must be much more robust since pressures approach 2000 P S I . These permit the process to produce parts with the greatest accuracy and detail but demand relatively large and expensive machines to handle these pressures. With some exceptions, the process is reserved for small separators and for small yarn package locators laminated into corrugated or fiberboard separator pads.

8. Hybrid Injection Molding

There is considerable effort being expended to develop hybrid injection molding processes which combine the detail of the high pressure process with the ability of structural foam to produce variable wall thicknesses. One process, called gas-assist injection, holds the promise of flat skins with integral tubular reinforcing members. Currently this work is confined to applications such as automotive and computer housings because of high initial costs but it should become

289

competitive in the next decade.

The foregoing is a brief description of the available manufacturing processes. We can summarize them by a few simple guidelines which are subjective and based on our experience only; there are no absolute rules.

1.

2.

3.

4 .

5 .

6 .

Light duty, low complexity pallets and separators can be vacuum formed.

Heavy duty pallets and separators will require twin sheet vacuum forming or structural foam.

High performance locators will require structural foam or inj ection molding . Projects with volumes over 3 to 5 thousand parts should be priced using several competing processes because tooling costs become a less critical factor versus part costs . The predictability of package performance is directly related to the degree to which the manufacturing .process can be controlled.

The process with the shortest tooling lead time is not always the fastest means to a successful product.

290

Customer Core Recycling Program

A Case Study to Recover Packaging Materials

Ronald J. Beegle Mount Vernon Mills, Inc.

29 1

292

CUSTOMER CORE RECYCLING PROGRAM

A CASE STUDY TO RECOVER PACKAGING MATERIALS

RON BEEGLE DIRECTOR OF ENVIRONMENTAL AFFAIRS

MOUNT VERNON MILLS, INC. W O N OPERATIONS

CARPET, APPAREL AM) TEXTILES ENVIRONMENTAL CONFERENCE FEBRUARY 2,1995

293

L

294

BACKGROUN D

b SOLID WASTE DISPOSAL IS A CONCERN OF EVERYONE. -

b OUR CUSTOMERS OFTEN DON'T HAVE AVENUES FOR RECYCLING PACKAGING MATERIALS THAT COME FROM THEIR SUPPLIERS, SUCH AS VENDOR RELATIONSHIPS, OR EVEN HAVE ENOUGH VOLUME TO MAKE OUTSIDE RECYCLING ECONOMICALLY FEASIBLE.

b IT IS DIFFICULT TO PREDICT SAVINGS WITH A TRIAL LIKE THIS BECAUSE YOU DON'T KNOW HOW M A N Y CORES YOU'LL RECOVER AND WHAT THE LABOR WILL BE TO HANDLE THEM, OR HOW MATERIAL FLOW WILL BE MANAGED LOGISTICALLY.

b THE CUSTOMER IS UNABLE TO SEPARATE OUR CORES FROM THOSE OF OTHER SUPPLIERS.

b WE WERE ABLE TO JUSTIFY BRINGING BACK ALL OF THEIR CORES BECAUSE:

A. A SIGNIFICANT VOLUME OF THE FABRIC CUT AT THE CUSTOMER LOCATION IS FROM OUR OPERATIONS IN TFUON.

B. INSPECTION OF CORES AT THE CUSTOMER LOCATION REVEALED COMPETITORS CORES TO BE SIMILAR TO OURS.

C. TRUCKS ARE RUNNING REGULARLY ANYWAY, RETURNTNG EMPTY BACK TO TRION TO PICK UP FABRIC.

D. OUR VENDOR OF CORES RECYCLES ALL DAMAGED CORES AT A PREMIUM TO US, REGARDLESS OF SOURCE, AND AN INTERNAL PROGRAM IS AIJ3.EmY IN EFFECT.

b ALL COSTS INCURRED ARE ABSORBED BY MOUNT VERNON MILLS.

295

DETAILS OF MATERIAL FLOW

t

c

CORES ARE RETURNED ONCE A MONTH FROM HOPKINSVILLE, KY (CUSTOMER) ON AN EMPTY TRAILER RETURNTNG TO TRION FOR ROUTTNE FABRIC PICKUP. (240 MILES)

TRUCKING IS BY AN INDEPENDENT CARRIER.

A FLAT FREIGHT CHARGE IS INCURRED EACH MONTH.

RETURNED CORES ARE UNLOADED AND STAGED IN A DESIGNATED AREA NEAR THE NEW CORE STAGING AREA.

CORES ARE INITIALLY SORTED IN THE STAGING AREA TO SEPARATE USABLE CORES BY SIZE FROM DAMAGED CORES. USABLE CORES ARE ADDED TO NEW CORE INVENTORY.

DAMAGED CORES ARE TRANSPORTED TO A CUTTING AREA WHERE THEY ARE CUT TO LENGTH AS REQUESTED BASED ON THE NEEDS OF THE PACKINGLNSPECTION DEPARTMENT THAT DAY. CORES DAMAGED BEYOND USABLE LENGTH ARE SEPARATED FOR RETURN TO VENDOR FOR RECYCLING. THIS "CUSTOM CUTTING" HAS ELIMINATED THE BACKLOG WHEN THE CORES ARE ONLY CUT TO STANDARD LENGTHS AND ADDED TO THE NEW CORE INVENTORY.

THE "CUTS" ARE BOXED UP AND RETURNED TO THE VENDOR FOR RECYCLING ALONG WITH DAMAGED CORES.

ADDITIONAL LABOR IS INCURRED IN THE INITIAL SORTING, THE CUTTING, AND THE TRANSPORTING BETWEEN SORTING AND CUTTING. ALL OTHER OPERATIONS ARE EXISTING RESPONSWILImS (OF M-4TEWI-M HANDLERS, ETC.) AND RESULT IN NO ADDITIONAL MEASURABLE LABOR EXPENSE.

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DATA

CUSTOMER LOCATION: HOPKINSVILLE, KY

SUPPLER LOCATION: W O N , GA

CORES RETURNED, 1994: 45,407

CORES SORTED: REUSABLE: 41,533 (9 1.5”/0) DAMAGED: 3,874

CORES CUT: REUSABLE: 2,828 (73.0%) UNUSABLE: 1,046

CUTS, LBS: 707 (0.4 TONS) (1.6 TONS @ 3 LBICORE)

A. TOTAL, REUSABLE CORES: 44,3 6 1 (97.7%)

REUSE

B. AVERAGE NEW COST PER CORE: $0.79

C. RETURN FREIGHT COST: ( $ 3,847)

D. LABOR COST TO SORT & CUT: ( $ 6,246)

E. TOTAL COST OF REUSING CORES: ( $10,093) (C+D)

F. COST PER REUSED CORE: $0.23 @/A)

G. SAVINGS PER REUSED CORE: $ 0.56 (B-F)

H. SAVTNGS OF REUSING CORES: $24,842 (A x G)

RECYCLING

I. CREDIT FOR RECYCLING UNUSABLE CORES: $ 52 (@$32.50/TON)

297

J. CREDIT FOR RECYCLING CUTS: $ 1 1 (@$32.5OnON)

K. CRE DITS FROM RECYCLING: $ 63 (I+J) ~

DISPOSAL

L. CUSTOMER SAVINGS FROM DISPOSAL COST: $ 2,384 (@$35/TON)

TOTAL PROGRAM SAVINGS OF PARTNERSHIP: $27,289 (H+K+L)

298

SUMMAR Y

b CORE RECOVERY FOR REUSE IS 97.7%

b OVERTIME LABOR WAS USED DURING THIS STUDY. STRAIGHT TIME LABOR CAN REDUCE THE COST OF A REUSED CORE TO AS LITTLE AS 18 CENTS VERSUS 79 CENTS FOR A NEW ONE.

b A SAVINGS OF 61 CENTS PER CORE IS POSSIBLE BY REUSING IT ONCE.

b THE NUMBER OF TIMES A CORE CAN BE REUSED AND HOW MUCH ADDITIONAL SAVINGS WOULD BE POSSIBLE FROM USING IT MORE THAN TWICE CANNOT BE DETERMINED FROM THIS STUDY.

299

FUTURE PLA NS

EXPAND PROGRAM WITH THIS CUSTOMER TO INCLUDE OTHER PACKAGING MATERIALS THAT WE RECYCLE INTERNALLY, SUCH AS POLYETHYLENE, KRAFT PAPER AND CORRUGATED CARDBOARD.

. INVITE ADDITIONAL CUSTOMER(S) TO PARTICIPATE WHERE FEASIBLE IN ORDER TO SCALE UP PROGRAM TO EMPLOY FULL TIME STRAIGHT LABOR.

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