Page 1 of 49 Memorandum From: Carey A. Johnston, P. E. USEPA/ OW/ OST ph: ( 202) 566 1014 johnston. carey@ epa. gov To: Public Record for the Final Rule: Streamlining the General Pretreatment Regulations for Existing and New Sources of Pollution EPA Docket Number OW 2002 0007 ( www. epa. gov/ edockets/)

Date: June 3, 2005 Re: The Impacts of Industrial Water Re Use and Reduction Technologies on End Of Pipe Pollutant Concentrations and Loadings This memorandum evaluates the impacts of water re use and reduction technologies and pollution prevention practices on end of pipe pollutant concentrations ( e. g., mg/ L) and the mass of wastewater pollution ( e. g., pounds/ day) in discharged industrial wastewater. This memorandum also presents case studies documenting the use of these water re use and reduction technologies and pollution prevention practices. The memorandum is divided into three sections:

Overview of Water Conservation and Wastewater Management;

Examples of Industrial Pollution Prevention and Water Reduction Technologies; and

Case Studies of Industrial Pollution Prevention and Water Reduction Technologies.

I. Overview of Water Conservation and Wastewater Management As demonstrated by the technology descriptions and case studies presented in this memorandum, implementing water re use and reduction technologies and pollution prevention practices can reduce the amount of wastewater pollution discharged by industrial facilities, especially for those facilities that have on site wastewater treatment systems. Many of these technologies and pollution prevention practices can also reduce the amount of wastewater pollution discharged by industrial facilities that do not have on site wastewater treatment systems. In general, water re use and reduction technologies and pollution prevention practices fall into one of two general classes:

Technologies and pollution prevention practices that only reduce the wastewater volume discharged from an industrial operation ( i. e., no decrease in the mass of wastewater pollutants resulting from an industrial operation); and

Technologies and pollution prevention practices that reduce the amount of wastewater volume and mass of wastewater pollutants resulting from an industrial operation. 1Eckenfelder, W. Wesley, 1989. Industrial Water Pollution Control, McGraw Hill, Inc., New York, New York, Page 60.

2Ibid. Page 53.

Page 2 of 49 Technologies and pollution prevention practices that only reduce the wastewater volume discharged from an industrial operation There are a number of technologies and pollution prevention practices that only reduce the amount of wastewater volume discharged from industrial operations. Flow reduction can offer the following example benefits: ( 1) increased pollutant concentrations to on site wastewater treatment systems which increase the efficiency of the wastewater treatment system; ( 2) decreased wastewater treatment system equipment sizes, resulting in reduced treatment system capital and operating and maintenance costs; and ( 3) decreased water and energy usage. In general, there is an economic incentive for facilities to use as little water as possible in their industrial operations.

Water volume reduction technologies and practices usually increase the pollutant concentrations in the wastewater resulting from the industrial operations prior to wastewater treatment and management. For facilities with on site wastewater treatment systems, the combination of water reduction technologies and practices and well operated wastewater treatment will reduce the volume and mass of discharged wastewater pollution ( i. e., after treatment). This is due to the fact that wastewater treatment technologies operating within their design specifications are limited solely by physical/ chemical properties of the pollutants in the wastewater, and not necessarily by influent concentrations. Increasing influent pollutant concentrations to a properly designed and operated wastewater treatment system generally leads to increased wastewater treatment efficiency. 1 Consequently, a properly managed wastewater treatment system operating within its design specifications can produce a consistent effluent despite fluctuations or increases in influent concentration. For example, a facility might discharge 100,000 liters of wastewater per day to a treatment system that treats pollutant X to 10 milligrams/ liter. The post treatment pollutant loading is 1,000 grams per day. If the facility reduces flow to 50,000 liters per day, the system will still treat pollutant X to 10 milligrams/ liter, resulting in a new loading of 500 grams per day.

The assertion that decreasing the volume of wastewater generated from industrial operations ( and the resulting increase in influent pollutant concentrations) leads to greater efficiency in the wastewater treatment system is well documented in literature and supported by various examples. For example, the performance of a settling tank is directly related to its overflow rate and detention time which in turn are directly related to the size of the settling tank and the rate of the flow through the settling tank. 2 Lowering the flow through an existing settling tank will increase the performance of the settling tank ( i. e., better pollutant removals). Moreover, wastewater sampling data collected for many EPA effluent guidelines also demonstrate that reducing wastewater flow to a treatment system will allow the system to more successfully treat the increased pollutant concentrations. For example, information supporting the Organic Chemicals, Plastics and Synthetic Fibers ( OCPSF) point source category effluent guidelines states: 3U. S. EPA, 1983. Development Document for Effluent Limitations and Guidelines and Standards for the Organic Chemicals and Plastics and Synthetic Fibers Point Source Category, EPA 440 1 83 009 b, Page IX 3, February 1983.

4For example, the January 2004 edition ( Vol. 111, No. 1) of Chemical Engineering highlighted a Dow OCPSF facility in Freeport, Texas, that successfully applied water reuse concepts to reduce water usage and wastewater generation ( Page 30 41).

5For example, the Shipley Company in Marlborough, MA ( FRS ID No. 110000309522) is regulated by the metal finishing effluent guidelines ( Part 433) and is part of EPA's Performance Track program. This facility was able to reduced water consumption in its printed wiring board and other metal finishing operations via water conservation from 8,870,000 to 3,610,000 gallons ( in one year 2001 to 2002).

6For example, between 1997 and 2001, Artistic Plating Company in Anaheim, CA, reduced its sludge volume by 40% by installing flow restrictors and conductivity sensors. Source: U. S. EPA, 2004. " Sector Strategies Performance Report," EPA 100 R 04 002, June 2004.

7See: http:// www. p2pays. org/ water/ success. htm.

8U. S. EPA 2000. Final Development Document For Effluent Limitations Guidelines and Standards for the Transportation Equipment Cleaning Category, EPA 821 R 00 012, Page 7 8, June 2000.

Page 3 of 49 For example, a good activated sludge plant will usually discharge 20 to 40 mg/ L of BOD whether the influent BOD concentration is 100 mg/ L or 500 mg/ L, if the plant is well designed and the design loadings are not exceeded. Similarly, activated carbon effluent concentration over a wide range of influent concentrations as long as the contact time is adequate and the carbon capacity has not been exhausted. 3 Reducing water use will also reduce costs associated with water use. Numerous examples exist in the literature of facilities maintaining or increasing their production and their efficiency ( through lower production costs) through use of water conservation. 4 EPA's Performance Track voluntary initiative program also documents numerous examples of facilities demonstrating compliance with concentration based ELGs and significant reductions in water use. 5 Another EPA voluntary program, the Strategic Goals Program, also highlight successes with water conservation, compliance with concentration based standards, and the reduction of wastewater pollution. 6 State environmental programs are also documenting water conservation success in voluntary partnerships with industrial facilities. 7 EPA's effluent guidelines rulemakings also document numerous example of facilities employing water conservation. For example, data gathered for the Transportation Equipment Cleaning point source category effluent guidelines ( 40 CFR 442) show that approximately 45% of transportation equipment cleaning facilities practiced flow reduction/ water conservation. Flow reduction technologies applicable to the transportation equipment cleaning industry serve to reduce the amount of fresh water required for tank cleaning through cleaning process modifications and/ or recycling and reusing process wastewaters in transportation equipment cleaning or other operations. 8 9Eckenfelder, 1989. Page 21.

10Cartwright, Peter, 2005. " Process Water Supply   The Big Picture," Chemical Engineering, May 2005.

Page 4 of 49 EPA can directly correlate water conservation and production in some industrial sectors. In such cases it is possible to directly incorporate water conservation into the calculation of production based effluent guidelines. Specifically, EPA uses a production normalized flow ( volume of wastewater/ unit of production) and the concentration of the regulated pollutant in the discharged wastewater that corresponds to the performance of BAT or BADT technology to calculate the applicable production normalized mass based effluent guidelines:

Production normalized mass based ELGs = ( mass pollutant)/ production unit) BAT or BADT pollutant concentration X ( mass pollutant)/ vol. discharged) Production normalized flow ( vol. discharged/ production unit)

Mass based permit limits based on production normalized mass based effluent guidelines are different from mass based permit limits based on concentration based effluent guidelines in that the permit writer must identify a reasonable measure of the facility's regulated actual long term production, and not facility flow, in order to convert production normalized mass based effluent guidelines to mass based permit limits.

Technologies and pollution prevention practices that reduce the amount of wastewater volume and mass of wastewater pollutants resulting from an industrial operation Many of the water re use and reduction technologies and pollution prevention practices allow for chemical recovery and reuse, thereby reducing both the flow and the pollutant concentrations and loadings. In some cases, these technologies eliminate the generation of wastewater altogether. These technologies will reduce the amount of discharged wastewater pollution regardless of whether or not a facility has a wastewater treatment system on site. There are many industrial applications of this type of water re use and reduction technologies. 9 Industry Trends in Water Conservation The main incentives for industry to reduce or eliminate water use and the related wastewater generation include water source restrictions ( e. g., drought or other limitations on the water supply) and economics ( e. g., lower water consumption leads to lower costs as a result of less water usage and potential less sludge generation and disposal costs). For most of the industrial era, water has been viewed as a free or very low cost commodity and until recently industries have tended to be very poor stewards of water conservation. 10 This perception of a plentiful resource is rapidly changing, however, as communities across the country begin to face water supply limitations. Awareness of this issue is heightened as a result of recent developments such as: ( 1) widespread drought; ( 2) increasingly strict standards for both withdrawal and discharge of water; ( 3) more rigorously enforced water rights limitations; and ( 4) increasing water 11U. S. DOE, 2003. " Water Use in Industries of the Future," http:// www. oit. doe. gov/ pdfs/ 100903_ news. pdf, July 2003.

12National Science and Technology Council, 2004. " Science and Technology To Support Fresh Water Availability In the United States, http:// www. ostp. gov/ nstc/ html/ swaqreport_ 2 1 05. pdf, November 2004.

13Hinrichsen, Don, 2004. Water Pressure, National Wildlife, http:// www. nwf. org/ nationalwildlife/ article. cfm? articleId= 928& issueId= 69, Vol. 42, No. 5, Aug/ Sep 2004.

14GAO, 2004. " Freashwater Supply: States' Views of How Federal Agencies Could Help Them Meet the Challenges of Expected Shortages," GAO 03 514, July 2003.

15See http:// www. worldwatercouncil. org/.

16Seidel, Andrew, 2002. " Turbulent Waters," Environmental Protection, Vol. 13, No. 1, Page 26, January 2002.

Page 5 of 49 demands of urban populations. 11 Water supply shortfalls have become increasingly severe during drought periods   raising the costs of water access and threatening the integrity of aquatic systems. As demand for limited water supplies increase, the need for economic efficiency in water storage, delivery, treatment, and use becomes more critical. 12 The need to measure, control, and record water usage, neglected in the past, is starting to be addressed. Industry, a significant user of water, is becoming aware of the importance of measuring and managing water use. Energy intensive industries, especially, are finding water scarcity to be a limit to growth. The U. S. Geological Survey ( USGS) reported in 2004 that the nation withdrew 408 billion gallons of freshwater every day from surface and groundwater, about a 2 percent decrease from 1990 and a 10 percent drop compared to 1980. Nationwide, per capita water use has dropped 25 percent from its peak in the 1970s. As might be expected, water conservation drives this trend as " the downward trend in water withdrawals is a function of widespread water conservation measures, especially in industry and municipalities and to a lesser extent in agriculture." 13 Additionally, a recent GAO survey of state water managers indicated that, even under normal or non drought water conditions, 36 states anticipate water shortages in localities, regions or statewide within the next 10 years. Under drought conditions 46 states expect shortages over the next decade. 14 Finally, the World Water Council15 predicts that between 1995 and 2025, U. S. residential water consumption will increase 100 percent, while industrial water use will increase by 33 percent. As water costs increase and supplies dwindle, more and more industries are turning to high tech water treatment systems that recycle and reuse water within plant production processes. 16 II. Examples of Industrial Pollution Prevention and Water Reduction Technologies Many industrial pollution prevention and water reduction technologies are currently in use across the United States. This section focuses on common technologies found in the Metal Finishing ( MF) and Metal Products and Machinery ( MP& M) industries, and describes how these technologies reduce water usage and pollutant discharge concentrations. This section discusses some examples of these technologies by the two classifications listed in Section I of this memorandum. Page 6 of 49 Technologies and pollution prevention practices that only reduce the amount of wastewater volume generated by the industrial operation MF facilities apply flow reduction practices to process baths or rinses to reduce the volume of wastewater discharged. Flow reduction practices consist of optimizing rinse tank design and configuration, and installing flow reduction technologies such as flow restrictors or timers. These technologies tend to reduce wastewater flow and increase pollutant concentrations; however, after consideration of end of pipe wastewater treatment these technologies will also reduce the amount of discharged wastewater pollution. The following subsections discuss these flow reduction practices in greater detail.

Rinse Tank Design and Innovative Configurations Rinsing follows many MF operations to remove dirt, oil, or chemicals remaining on parts or racks from a previous unit operation. In general, rinses generate the most wastewater flow at MF facilities. Rinsing improves the quality of the surface finishing process and prevents the contamination of subsequent process baths. Rinse tank design and rinsing configuration greatly influence water usage. The key objectives of optimal rinse tank design are to quickly remove drag out solution from the part and to disperse the drag out throughout the rinse tank.

MF facilities uses various rinsing configurations. The most common are countercurrent cascade rinsing, drag out rinsing, and spray rinsing.

Cascade Rinsing. Cascade rinsing is a method of reusing water from one rinsing operation to another, less critical rinsing operation before being discharged to treatment. Some rinse waters acquire chemical properties, such as low pH, that make them desirable for reuse in other rinse systems. For example, water from an acid treatment rinse may be reused in an alkaline treatment rinse. In this case, the rinse water both removes drag out from the work piece and neutralizes the drag out.

Countercurrent Cascade Rinsing. Countercurrent cascade rinsing refers to a series of consecutive rinse tanks that are plumbed to cause water to flow from one tank to another in the direction opposite of the work flow. Fresh water flows into the rinse tank located farthest from the process tank and overflows ( i. e., cascades) into the rinse tank that is closest to the process tank. Over time, the first rinse becomes contaminated with drag out solutions and reaches a stable concentration of process bath constituents that is lower than the concentration in the process bath. The second rinse stabilizes at a lower concentration, which enables less rinse water to be used than if only one rinse tank were in place. The more countercurrent cascade rinse tanks ( three stage, four stage, etc.), the less rinse water is needed to adequately remove the process solution. This differs from a single, overflow rinse tank where the rinse water is composed of fresh water that is discharged without any recycle or reuse. Under complete mixing conditions, each additional rinse stage can reduce rinse water use by 90 percent. Page 7 of 49 Flow Reduction Technologies Facilities can reduce water use by coordinating and closely monitoring rinse water requirements ( e. g., rinse water use is optimized based on drag out rates so that the rinse quality is consistent). Matching water use to rinse water requirements optimizes the quantity of rinse water used for a given work load and tank arrangement.

Many MF facilities use some form of rinse water control. Three common methods are flow restrictors ( these can be used with other methods to regulate the rate at which water is dispensed), conductivity controls, and timer rinse controls. These are discussed below.

Flow Restrictors. A flow restrictor prevents the flow in a pipe from exceeding a predetermined flow rate. Flow restrictors are commonly installed on a rinse tank's water inlet. These devices contain an elastomer washer that flexes under pressure to maintain a constant water flow regardless of pressure.

Conductivity Controllers. Conductivity controllers use conductivity probes to measure the conductivity ( total dissolved solids ( TDS)) of water in a rinse tank to regulate the flow of fresh rinse water into the rinse system. Conductivity controllers consist of a controller, a meter with adjustable set points, a probe that is placed in the rinse tank, and a solenoid valve. As parts are rinsed, dissolved solids enter the water in the rinse tank, raising the conductivity of the water. When conductivity reaches a set point where the water can no longer provide effective rinsing, the solenoid valve opens to allow fresh water to enter the tank. When the conductivity falls below the set point, the valve closes to discontinue the fresh water flow.

Rinse Timers. Rinse timers are electronic devices that control a solenoid valve. The timer usually consists of a button that, when pressed, opens the valve for a predetermined time period, usually from 1 to 99 minutes. After the time period has expired, the valve automatically closes. The timer may be activated either manually by the operator or automatically by the action of racks or hoists. Rinse timers installed in conjunction with flow restrictors can provide precise control when the incoming water pressure may rise and fall.

By using a combination of optimized rinse tank designs and flow reduction technologies, the MF industry is able to reduce the volume of rinse water required. Options such as using dragout tanks in conjunction with counter current cascade rinsing also help to reduce the concentration of pollutants that are discharged from the rinse.

Technologies and pollution prevention practices that reduce the amount of wastewater volume and wastewater pollution generated by an industrial operation Facilities also can implement several technologies or practices that will either reduce or prevent pollution from processes or recover pollutants for re use. These technologies will reduce both wastewater discharge rates and pollutant concentrations and loadings at the process level. Page 8 of 49 Modify Process Bath Operating Parameters Facilities can modify process bath operating parameters to reduce drag out. Examples of these practices are increasing bath temperature, operating at lower batch concentration, and using wetting agents, as discussed below:

Temperature and viscosity are inversely related; therefore, operating a bath at the highest possible temperature will lower process bath viscosity and reduce drag out.

Operating at the lowest possible concentration reduces the mass of chemicals in a given volume of drag out. Also, viscosity and concentration are directly related; therefore, lower process bath concentration will result in lower process bath viscosity and less drag out volume.

Adding wetting agents or surfactants to some process baths reduces viscosity and surface tension, thereby significantly reducing drag out.

Drag out Recover Rinsing A drag out rinse is a stagnant rinse, initially filled with fresh water, positioned immediately after the process tank. Work pieces are rinsed in drag out tanks directly after exiting the process bath. The drag out rinse collects most of the drag out from the process tank, thus preventing it from entering the subsequent flowing rinses and reducing the amount of wastewater pollution in those rinses. Gradually, the concentration of process chemicals in the drag out tank rises. In the most efficient configuration, a drag out tank follows a heated process tank that has a moderate to high evaporation rate. A portion of the fluid in the drag out tank returns to the process tank to replace the evaporative loss. The level of fluid in the drag out tank is maintained by adding fresh water. Electrolytic recovery, discussed below, is commonly used to remove dissolved metals from drag out tanks.

In Process Pollution Prevention Technologies This section describes several in process pollution prevention technologies used to reduce the amount of wastewater pollution to the wastewater treatment system. Process baths become contaminated with impurities that affect their performance. If not properly maintained, process baths become prematurely unusable and require disposal. Regeneration and maintenance techniques help keep baths in good operating condition, thereby extending the useful lives of process solutions. Using these technologies reduces the frequency of process bath discharges, and therefore reduces the amount of wastewater pollution to the wastewater treatment system. This, in turn, reduces wastewater treatment requirements and sludge disposal costs.

This section describes the following technologies used to treat and reuse process solutions:

Centrifugation and pasteurization of machining coolants;

Centrifugation and recycling of painting water curtains; Page 9 of 49

Electrodialysis;

Electrolytic recovery;

Evaporation;

Ion exchange; and

Reverse osmosis.

Centrifugation and Pasteurization of Machining Coolants. Most machining coolants contain water soluble oil in water. The water soluble coolant typically is pumped from a sump, over the machining tool and work piece during machining, and back to the sump. Using a centrifugal separator and pasteurization unit can extend the useful life of machining coolants. The separator is a rotating chamber that uses centrifugal force to push the coolant through a mesh chamber, leaving behind solid contaminants of sludge. Sludge is scraped from the centrifuge and collected in a sludge hopper. Some high speed centrifuges also can perform liquid liquid separation to remove tramp oils. The coolant undergoes pasteurization after separation to kill the microorganisms that cause bacterial growth. Adding a biocide can also control bacterial growth.

Centrifugation and pasteurization can be used in conjunction with oil skimming and biocide addition to reduce coolant discharge and pollutant generation at the source. Oil skimming using a vertical belt system ( described below) removes large amounts of tramp hydraulic oils floating on the surface of the machine coolant. Oil skimming and biocide addition can further extend the life of water soluble coolant, thereby reducing the amount of coolant and wastewater requiring treatment and disposal, and minimizing fresh coolant requirements.

Centrifugation and Recycling of Painting Water Curtains. Water curtains are a continuous flow of water behind the work piece being spray painted in a paint booth. The water traps paint overspray and is continuously recirculated in the paint curtain until the solids content in the wastewater necessitates either in process treatment and recycling or discharge.

Wastewater from painting water curtains commonly contains organic pollutants as well as certain metals. Eliminating the discharge of wastewater from painting water curtains may eliminate the need for an end of pipe treatment step for organic pollutants at certain facilities. Moreover, if a facility uses only painting water curtains and continuously recycles the water, the facility would not need end of pipe wastewater treatment.

Centrifugal separators remove the solids and recycle the water curtain, eliminating the need for discharge. This system can recycle, the paint curtain water continuously. The system pumps the water curtain from the paint curtain sump to a holding tank, then through the centrifugal separator, which separates the solids from the wastewater. Solids from the centrifuge are hauled for off site disposal, while the treated wastewater is returned to the paint booth. Centrifugation of the paint curtain proceeds until all wastewater is treated and only sludge remains in the paint curtain sump. Make up water is added to the system to compensate for evaporation.

Electrodialysis. Electrodialysis is a process in which dissolved colloidal species are exchanged between two liquids through selective semipermeable membranes. The technology applies a direct current across a series of alternating anion and cation exchange membranes to remove dissolved metal salts and other ionic constituents from solutions. Facilities typically use Page 10 of 49 electrodialysis to remove metal ions from electroplating wastewater. By using the electrodialysis cell, facilities remove impurities from the process bath, extending its life. Facilities can treat the removed concentrate stream on site, or haul it off site for disposal, treatment, or metals reclamation.

Electrolytic Recovery. Electrolytic recovery is an electrochemical process used to recover metal contaminants from many types of process solutions and rinses, such as electroplating rinse waters and baths. Electrolytic recovery removes metal ions from a waste stream by processing the stream in an electrolytic cell, which consists of a closely spaced anode and cathode. Facilities typically apply electrolytic recovery to solutions containing either nickel, copper, precious metals, or cadmium. Drag out rinses and ion exchange regenerant are solutions that commonly are processed using electrolytic recovery. Some solutions require pH adjustment prior to electrolytic recovery. The recovered metals may then be used to " feed" the plating baths or may be recovered for profit.

Evaporation. Evaporation is a volume reduction and water recovery technology applicable when raw water costs are high or discharge to either a receiving stream or the local sewerage district is not permitted. Evaporators have the potential to recover 95 percent of the water in a waste stream for reuse in the process. MF facilities use two basic types of evaporators: atmospheric and vacuum. Atmospheric evaporators are more prevalent and are relatively inexpensive to purchase and easy to operate. Vacuum evaporators are mechanically more sophisticated and are more energy efficient. Facilities typically use vacuum evaporators when evaporation rates greater than 50 to 70 gallons per hour are required. MF facilities use evaporators to recover metals from ion exchange regenerates, to reduce the volume of oily wastes that require off site transfer, and to recover and reuse rinse water from plating operations. Residue from evaporators can be recycled if sufficiently pure, disposed of off site, or used for energy recovery if the material has a sufficient BTU content.

Ion Exchange. Ion exchange is a commonly used technology within MF facilities. In addition to water recycling and chemical recovery applications, ion exchange is used to soften or deionize raw water for process solutions. Ion exchange is a reversible chemical reaction that exchanges ions in a feed stream for ions of like charge on the surface of an ion exchange resin.

MF facilities use ion exchange for water recycling and metal recovery. Many process wastewaters are excellent candidates for ion exchange, including the rinse water from plating processes of chromium, copper, cadmium, gold, lead, nickel, tin, tin lead, and zinc. Ion exchange resins usually are regenerated using inexpensive chemicals such as sulfuric acid and sodium hydroxide. Cyanide rinse waters are amenable to ion exchange; cation resins can break the metalcyanide complex and the cyanide is removed in the anion column. The metals in the cation regenerant can be recovered electrolytically and the cyanide present in the anion regenerant can be returned to the process or discharged to treatment.

Reverse Osmosis. Reverse osmosis is a membrane separation technology used by MF facilities for chemical recovery and water recycling. The system pumps dilute rinse water to the surface of the reverse osmosis membrane at pressures of 400 to 1,000 pounds per square inch gauge ( psig). The membrane separates the feed stream into a reject stream and a permeate. The 17U. S. EPA, 2004, " Sector Strategies Performance Report," EPA 100 R 04 002, http:// www. epa. gov/ sectors/ pdf/ performancebw. pdf, June 2004.

Page 11 of 49 reject stream, containing most of the dissolved solids in the feed stream, is retained by the membrane while the permeate passes through. The permeate stream usually is of sufficient quality to be recycled as rinse water, despite the small percentage of monovalent ions ( commonly potassium, sodium and chloride) that pass through the membrane.

A sufficiently concentrated reject stream can be returned directly to the process bath. Recycling the stream through the unit more than once or increasing the feed pressure can increase the reject stream concentration. In multiple stage units containing more than one membrane chamber, the reject stream from the first chamber is routed to the second, and so on. The combined reject streams from multistage units may, in some cases, have high enough concentrations to go directly back to the bath. Reverse osmosis is most applicable to electroplating rinse waters, including electroplating of Watts nickel, bright nickel, brass cyanide, copper cyanide, and zinc cyanide.

III. Case Studies of Industrial Pollution Prevention and Water Reduction Technologies The following section highlights several case studies and studies of industrial applications of the technologies identified above. These case studies cover the following industries: MF and MP& M; Chemicals Manufacturing; Pesticides Manufacturing; Pharmaceuticals Manufacturing; and Petroleum Refining. Each of these facilities are regulated by concentration based effluent guidelines or are required to convert concentration based standards to mass based standards by the facility's flow. This memorandum also includes case studies from facilities located outside of the United States. Note that the case studies vary in length and detail based on the information provided by each of the referenced data sources.

Case Studies of the MF and MP& M Industries Numerous examples exist of metal finishing facilities complying with their concentrationbased effluent guidelines standards, reducing water consumption, and generating less wastewater volumes and pollution amounts ( e. g., pounds per day). EPA's voluntary initiative program, the Strategic Goals Program, tracked some of these success in this industrial sector. Between 1998 and 2002, more than 500 metal finishers, 20 states, and 80 local regulatory agencies ( primarily publicly owned treatment works) participated with EPA in the Strategic Goals Program. Participating metal finishers pursued facility specific environmental targets for resource inputs and waste outputs, including: ( 1) 25% reduction in energy use; ( 2) 50% reduction in water use; ( 3) 50% reduction in land disposal of hazardous sludge; ( 4) 50% reduction in emissions of metals to water; and ( 6) 90% reduction in organic chemical releases reported to EPA's Toxics Release Inventory ( TRI). 17 An independent third party, the National Center for Manufacturing Sciences, tracked the progress of 150 participating metal finishers that consistently reported their environmental progress. Through 2001, cumulative improvements for these facilities included: ( 1) 7% reduction in energy use; ( 2) 38% reduction in water use; ( 3) 23% reduction in land disposal of hazardous 18Ibid, Page 32.

19Ibid, Page 34.

Page 12 of 49 sludge; ( 4) 62% reduction in emissions of metals to water; and ( 5) 62% reduction in organic chemical releases reported to TRI. 18 In many cases, metal finishers implemented more effective and efficient rinsing techniques, such as concurrent flow rinsing, which reduce the need to treat and dispose of plating baths. These techniques result in less water use, less chemical use, and less sludge generation. The findings from this voluntary industry program fully document that, " Water use and sludge generation go hand in hand for the metal finishing industry. Reducing water use at metal finishing facilities can reduce sludge generation and allow wastewater treatment systems to more successfully treat the wastewater." 19 Harley Davidson Motor Company ( York, PA) http:// www. dep. state. pa. us/ dep/ deputate/ polycomm/ update/ 09 20 96/ 09209605. htm Pollution prevention is an organized, comprehensive, continual effort to reduce or eliminate pollution and wastes at their source. Using this philosophy and a zero discharge goal, Harley Davidson installed a new nickel/ chrome plating machine in 1995. Full production began last November. Since November, re use of water in the plating operation has resulted in a 75 percent decrease in the amount of city water used. Control of rinse water flows and re use of rinses has resulted in a 60 percent drop in average daily flow to the on site industrial wastewater treatment system. Hazardous wastes shipped off site for treatment and disposal have been reduced by 80 percent  a 45,000 gallon reduction. Many of these wastes are generated during wastewater treatment; therefore, a reduction in waste generation indicates a reduction in pollutant loading from the facility. Installation of a three scrubber system to control air emissions translates into reduced discharges into the atmosphere and, therefore, cleaner air.

Hyde Manufacturing Corporation ( Southbridge, MA) http:// www. state. ma. us/ ota/ cases/ hyde. htm Quench Oil Recycling at Hyde Manufacturing Corporation Summary Hyde Tools, a division of Hyde Manufacturing Corp., installed a filtration system to recycle the quench oils used in its heat treating process. This system reduced the firm's water consumption, cut back on testing and permitting costs, and eliminated the need for out of house reclamation of quench oils. The project cost $ 25,805 to implement, and it yielded a favorable net present value in excess of $ 15,000 over its ten year economic lifetime. Page 13 of 49 Background Hyde Tools of Southbridge, Massachusetts is a 300 employee firm with two lines of products: an industrial tool line featuring machine blades, saw blanks and hand knives; and a trade line of knives, scrapers and other surface preparation tools designed for do it yourself home improvement projects.

Hyde's knife and scraper blades are stamped out of high carbon steel, sent through a vibratory degreaser, loaded into racks, then propelled via robotics through a heat treatment process. In the heat treatment process, the blades are submerged in a molten salt tank at temperatures ranging from 1600 to 1800 degrees, then plunged into a 500 gallon tank of quench oil. The quench oil is removed from the parts in a wash tank and two rinse tanks. The blades are then ground and polished, and the tools are assembled, packaged and shipped.

Prior to the implementation of in house quench oil recycling, the heat treatment process generated approximately 12 drums of oily water every six weeks. These were sent out for reclamation and water removal.

In 1988, the firm instituted a systematic plan to attain zero discharge of water pollution within three to five years. At that time, company management realized that eliminating the use of toxic chemicals in Hyde's processes would not only be cost effective, but would also help ensure the health and safety of workers and the public, while guaranteeing that the firm would exceed compliance requirements.

With the help of plant engineers, Hyde Environmental Manager Douglas DeVries drafted a plan for attainment of the zero discharge goal. DeVries decided to deal first with discharge from the heat treatment process. After considerable analysis, he determined that in process recycling was the answer.

After collecting and reviewing proposals from various vendors of filtration and wastewater recycling systems, DeVries chose a filtration model capable of recycling the wash and rinse water as well as the quench oil. The new system is composed of a transfer pump, a bag filter for capturing excess dirt, and two heated cone bottom reclamation tanks in which suspended solids and water can be separated from the quench oil. This new system eliminates the need to pump oil into drums and send them out for reclamation, reduces the total cost of reclaiming quench oils, and conserves wash and rinse waters by filtering and recirculating them.

The purchase cost of Hyde's oil recycling system was $ 20,055. The vendor trained Hyde employees to use and monitor the system at no additional cost. In house installation costs amounted to approximately $ 5,000.

Results Reductions Achieved: Hyde was able to reduce the amount of oil sent off site for reclamation by 1,730 gallons per year. The project also reduced water usage in the wash process by 19,200 gallons per year. Page 14 of 49 Economics: Purchase and installation costs for Hyde's new filtration and recycling system totaled $ 25,055. Hyde also installed an alarm system that automatically shuts off the unit's pump when the oil/ water combination in the sump nears capacity. The purchase and installation cost of this safety system was $ 750, bringing the total up front cost to $ 25,805.

The new system has reduced Hyde's purchases of quench oil by $ 4,844 every year. In addition, Hyde saves $ 8,760 in water bills, $ 4,200 in NPDES permits and $ 300 in laboratory testing costs each year. The only new expenditures associated with the system are the filtercake purchase and disposal costs, which total $ 2,800 per year. Thus, the payback period for the investment is about 2.5 years. This does not take into account the potential $ 2,500 per day fines or the potential liability associated with discharging into the sewer.

Poly Plating, Inc. ( Chicopee, MA) http:// www. state. ma. us/ ota/ cases/ polyplating. htm Chemical Wastes and Water Use Reduced More Than 90% at Poly Plating, Inc., Summary Poly Plating designed and installed integral repurification equipment which filters, recycles and concentrates wastes for reclamation. This equipment reduced acid purchases to 1% of 1989 levels. Reclaiming and recycling has cut disposal costs by 98%. Additionally, water use has been reduced to 880 gallons per day, down from 78,000 gallons per day.

Background Poly Plating Incorporated, of Chicopee, Massachusetts, employs 16 people in the production of nickel plated parts. A variety of hazardous and toxic chemicals, in addition to water, are used in baths to prepare and plate nickel onto metal substrates.

The nickel plating process consists of up to eight steps. Surface preparation prior to plating includes degreasing, baking ( depending on substrate hardness), masking ( if necessary), chemical cleaning, rinsing, and descaling. The part is then chemically activated and immersed in a nickel solution. Finally, the part is hot rinsed, dried and sometimes baked.

In 1983, the City of Chicopee announced a program of significant future annual increases in water rates, plus the addition of sewer use charges. Material purchase prices for acids and nickel were increasing at 7 10% yearly. Motivated by a desire to cut operational costs and to benefit the environment, Ed Ondrick, president of Poly Plating, instituted a research and development program on waste reduction for his plating lines.

Attempts to use turn key equipment proved unsuccessful. The acids and other chemicals involved in nickel plating were too aggressive on the equipment components. Ondrick then began to modify and develop the technology for new applications, some of which have been patented. All plating employees participated in the monitoring of the new equipment, and offered suggestions as to how the process might run more efficiently. The six year project led to the Page 15 of 49 establishing of a second company. This firm, Zero Discharge Technologies, manufactures and sells repurification and acid reclamation equipment for the plating industry.

All equipment design and construction or modification was performed in house. Two workers were trained to operate, monitor and maintain all key pieces of equipment. These workers follow specific maintenance schedules and regularly meet with Ondrick to discuss equipment status. The plating production lines have 12 integral repurification units that remove contaminants and retrieve metals and acids for re use. Additionally, plating water is recycled through a closed loop system.

Results Reductions Achieved: Acid purchases have been reduced 96% while production has increased 20% during the same period. Disposal costs are 91% less as a result of the reclaiming and recycling of acids and other chemicals. Water use and sewage fees have been reduced by 98%.

Economics: Savings from reduced water use and sewage fees total more than $ 74,000 annually. Reduced purchase of new acid saves $ 15,000. The closed loop design of the system has saved $ 14,630 in disposal costs. The elimination of water discharges from the plating process saves $ 4050 in water testing costs. Overall, the project saves Poly Plating more than $ 107,000 annually. While total costs for R& D on the project were $ 755,000, the replacement cost of the system currently in use at Poly Plating is $ 225,000. The payback period is 25 months. The Robbins Company ( Attleboro, MA) http:// www. state. ma. us/ ota/ cases/ robbins. htm Elimination of TURA Chemical Reporting at The Robbins Company, Summary By refining its manufacturing operations over a number of years, the Robbins Company eliminated or significantly reduced all chemicals previously reported for the Massachusetts TURA Form S and the EPA's Form R. Robbins' ongoing commitment to continuous improvement has helped to foster an environment open to progressive ideas and new technologies. In 1987, the company replaced its traditional wastewater treatment system with a state of the art closed loop ion exchange system. In 1994, Robbins updated and refined this process by replacing the ion exchange equipment with a reverse osmosis system that uses minimal quantities of maintenance chemicals and produces less waste. To eliminate the use of chlorinated solvents, Robbins switched in 1993 to a closed loop aqueous cleaning system. The new system uses ultrafiltration to recycle and extend the life of cleaning baths by 300%, reducing costs associated with the purchase and disposal of the cleaner. Further, to eliminate the use of dissociated ammonia in annealing ovens, the company converted to a system that blends hydrogen and nitrogen gases. The ovens' noncontact cooling water which was once discharged to the sewer is now chilled and recirculated back to the process. Since 1986, through these changes and other toxics use reduction strategies, Robbins has reduced chemical use in wastewater treatment by 99%, reduced hazardous waste generation by 99% and cut water use by 98.5%. All told, these reductions have created an annual savings of more than $ 100,000, and the company no longer has to report chemical usage under TURA or chemical releases under EPCRA. Page 16 of 49 Background The Robbins Company is a 350 employee manufacturing company located in Attleboro, Massachusetts. The major processes performed at the facility include casting, stamping, grinding, polishing, annealing, plating, coloring and coating. Before the company began to investigate ways to conserve water, reduce its use of chemicals and cut back on its generation of hazardous wastes, Robbins had a conventional wastewater treatment system. The company's plating line was without countercurrent rinses or flow restrictors, and water poured into rinse tanks at a rate of 1.8 gallons per minute. With this arrangement Robbins used 100,000 gallons of water per day, multiple chemicals, including trichloroethylene ( TCE) and Freon, and was a large quantity generator of hazardous waste. Robbins was also using dissociated ammonia in the annealing ovens to remove oxides and brighten the surface of jewelry manufactured at the facility.

In the mid 1980s, the Office of Technical Assistance's predecessor agency  known as the Office of Safe Waste Management ( OSWM)  offered workshops to jewelry manufacturers in the Attleboro area on in process metals management and water conservation. Robbins participated in these workshops and subsequently in the OSWM sponsored Southeast Jewelry Platers Project ( SJPP). On site environmental audits by OSWM staff aided the Robbins Company in identifying:

Chemical use and waste generation at the facility;

Additional water conservation strategies;

Alternatives to chlorinated solvent use in parts drying and cleaning; and

Metal recovery technologies.

After receiving detailed reports from the audits, Robbins used a variety of source reduction techniques to reduce the metal content of its rinse water. The company installed counter current rinsing, and drag out ( i. e., dead rinse) tanks after plating tanks; used ion exchange to recapture metals from the cyanide process, returning clean water to the plating process tanks; changed the way that parts were racked to ensure more efficient drainage; and increased part drainage times.

In 1994, OTA again visited the Robbins Company and identified alternatives to the ammonia used in the annealing step. Robbins then took the initiative to reengineer their annealing process and to eliminate the use of ammonia, the only TURA reportable chemical still used. Additionally, noncontact cooling water from the annealing furnaces is now recirculated through a chiller and returned to the process.

Elimination of Cleaning Solvents: Robbins made it a priority to eliminate ozone depleting substances and trichloroethylene ( TCE), a hazardous air pollutant, from its manufacturing processes. The company has three critical points in its manufacturing process where parts require cleaning: after coloring/ plating, after stamping, and after the polishing step. In the coloring/ plating department, Robbins once used Freon to dry parts to a mirror finish, to ready them for packaging and shipping. TCE was used to remove oils from the stamping operation and to remove the polishing compound remaining from the buffing operation. At each of these cleaning steps, Robbins evaluated and successfully installed an aqueous alternative. Page 17 of 49

Coloring/ Plating: Deionized water and a hot air drying step have replaced the Freon once used following these operations. Robbins focused particularly on eliminating Freon because of the requirement from the 1987 Montreal Protocol that requires parts processed with ozone depleting substances to be labeled after 1994. Freon was eliminated in 1991, three years before the labeling requirement took effect.

Stamping: A three step aqueous cleaning station, consisting of an aqueous wash, deionized still water rinse and a hot air dry, has replaced the TCE degreaser at this process step. After the new parts washing equipment was installed, Robbins switched to lighter stamping oils to increase the effectiveness of this cleaning operation.

Polishing: An aqueous, ultrasonic wash followed by several heated deionized water rinse tanks has replaced the TCE once used to remove polishing compound from the parts. After reviewing the polishing process, unnecessary cleaning between polishing steps was eliminated and parts are now only cleaned after the final polish. Robbins has installed an ultrafiltration unit that has tripled the life of the cleaning solutions used in this process.

Elimination of Ammonia in Annealing Ovens: In Robbins' annealing ovens, metal jewelry parts are heated and treated to remove metal oxides and shine the surface of the part. Ammonia is dissociated into elemental hydrogen and nitrogen to create a reducing atmosphere to prevent the formation of oxides. By 1992, ammonia was the single chemical for which Robbins was required to file reports to both the EPA's TRI program and the Massachusetts TURA program. In 1994, with the aid of a detailed report developed through on site technical assistance by OTA, the Robbins company devised a plan to eliminate its ammonia usage entirely.

The ammonia dissociation process generally results in an oven atmosphere of 75% hydrogen and 25% nitrogen gas. Through trial and error, the company determined that its annealing process requires significantly less hydrogen to produce the same desired brightened finish. The company decided to take the existing ammonia dissociator out of service and install a new system where pure hydrogen and nitrogen gases are blended to produce the desired oven atmosphere. Robbins eliminated the use of approximately 14,000 lbs. of ammonia, and no longer reports any chemicals to the EPA TRI program or the Massachusetts TURA program. Page 18 of 49 Closed Loop Water Recycling and Reuse System Once the company had reduced water usage and metal bearing rinse water, the flow rates were low enough to make a closed loop water treatment system economical. In 1987, Robbins replaced the traditional metal hydroxide precipitation system with a closed loop system incorporating ion exchange to remove metals and salts from the rinse water.

This system worked well, decreasing water usage, chemical use and hazardous waste generation. It produced water that was 40 times cleaner than city water, contributing to greater plating quality. Yet Robbins found that ion exchange still required a fair amount of supervision and that acids and bases were needed to regenerate the resin columns. The ion exchange closedloop system still generated significant amounts of liquid waste for evaporation.

In 1994, the company replaced the ion exchange treatment system with a state of the art reverse osmosis system. Robbins recognized some significant benefits in switching to reverse osmosis, including:

Less operator involvement ( the system requires little maintenance or monitoring);

Minimal amounts of acid required to clean the reverse osmosis filters;

Lowered worker exposure risks;

Reductions in quantities of water requiring evaporation;

Improved water quality; and

Less hazardous waste generated.

Robbins realized significant reductions in the use of sodium hydroxide and muriatic acid as a result of this change. The company's usage of sodium hydroxide was reduced from 500 gallons in 1993 to 20 gallons in 1994. Chemical use in the new system is limited to filter cleaning/ maintenance only.

Results Summary of Reductions Achieved: Through toxics use reduction strategies, Robbins eliminated annual use of 6,000 lbs. of Freon, 21,000 lbs. of trichloroethylene, 14,000 lbs. of ammonia and 3,000 lbs. of sodium hydroxide and 2,500 lbs. of sulfuric acid used in wastewater treatment. Sludge generation was cut by 99.8%, from 4,000 gallons to 7 gallons per year, reducing the company's status from a large quantity generator ( LQG) of hazardous waste to small quantity generator ( SQG). In addition, by using in process water conservation techniques, Robbins reduced its daily water consumption from 100,000 gallons in 1984 to 5,000 gallons in 1986, to just 156 gallons in 1994. City water is needed by the closed loop system only to compensate for evaporation. These reductions continue to save the company more than $ 100,000 annually. These savings are derived only from lowered chemical purchase costs and lowered hazardous waste disposal costs. Page 19 of 49 V. H. Blackington & Co., Inc. ( North Attleboro, MA) http:// www. state. ma. us/ ota/ cases/ blackinton. htm Freon Elimination, VOC and Metals Reduction at V. H. Blackinton & Co., Inc.

In order to eliminate both the health concerns and increasing environmental compliance costs associated with the toxic chemicals used to manufacture its metal insignia, novelties and jewelry  and because the Clean Air Act will end production of some of those chemicals  V. H. Blackinton began a program to find ways to replace and reduce the use of those materials. Working on their own and with the help of the Office of Technical Assistance, V. H. Blackinton installed a deionized water rinse and hot air dryer to replace Freon parts drying. The company has decreased use of trichloroethylene ( TCE) by substituting an aqueous cleaner for most degreasing as well as by ending some parts cleaning and bright dipping steps. A 50 percent reduction in zinc and copper in wastewater have been achieved through improved process management of bright dip chemicals; this has also resulted in reduced use of chemicals for wastewater treatment. The hot air drying system and aqueous cleaning process cost approximately $ 23,000 to install. To purchase in 1994 the quantity of Freon that was used in 1989 could cost upwards of $ 60,000. There have also been significant annual savings realized from reduced chemical purchases, water and sewer charges and energy usage. Product quality and productivity are unchanged or improved.

Background V. H. Blackinton & Co., Inc., North Attleboro, Mass., is the largest manufacturer in the United States of metal uniform insignia   badges, medals, service pins. The company also makes jewelry and other metal plated novelties. V. H. Blackinton's staff of 190 people manufacture products from start to finish   artwork and raw materials to packaged products ready to be shipped. The manufacturing operation includes blanking, stamping, punching and machining raw stock prior to enameling, brazing, polishing and plating. Five thousand gallons of water is used daily for noncontact cooling of brazing furnaces in addition to that used for rinsing. Copper and zinc contaminate the rinse water required to wash off the acids used to etch the badges.

In 1989, V. H. Blackinton began to research and make plans to reduce or eliminate:

Freon used for parts drying;

TCE degreasing;

Sulfuric acid used in brite dipping;

Waste from a 60 gallon cyanide activation tank, and

The 25,000 gallons of water used each day   including the 5,000 gallons of noncontact cooling water, which the North Attleboro wastewater treatment plant no longer allows to be discharged directly into the sewer system. Page 20 of 49 V. H. Blackinton moved to its present location in 1982 and as the company streamlined its processes to meet increased demand they also tested and implemented source reduction and conservation techniques. TCE and Freon emissions were reduced and the company was able to reduce water usage from five million to one million gallons a year. V. H. Blackinton participated in the Department of Environmental Management Southeast Jewelry Platers Project ( SJPP), which provided technical assistance from 1986 to 1989 to metal finishers and platers in southeastern Massachusetts. V. H. Blackinton's Emilio Abatecola attended SJPP workshops and seminars and had on site consultations from OTA and its predecessor, the Office of Safe Waste Management ( OSWM). A number of toxics use reduction and resource conservation opportunities were identified in a 1989 OSWM audit.

Emilio, who took over as finishing manager in 1990, saw that concerns over the environmental impact of toxic chemicals would lead to increased fees, costs and regulations. He sought input and assistance from the company's workers, and began implementing a program to use less chemicals and reduce water consumption. Emilio first focused on substitutes for Freon and TCE and then introduced additional water conservation and pollution prevention techniques. He also carefully assessed the need for each cleaning, degreasing and brite dipping step.

In 1990, Blackinton replaced the Freon dryer used to dry finished work pieces with a deionized water rinse and a hot air dryer. The new dryer, heated with inplant steam, requires five to eight minutes instead of 45 seconds with Freon, but because production is done in batches the increased drying time has had no significant effect on quality or productivity.

All but one of the TCE degreasing procedures have been replaced by a basic aqueous cleaning system with four countercurrent rinse tanks. At the brite dipping station, Emilio added a conductivity probe to the fourth and final countercurrent rinse tank so that fresh water is no longer added continuously, but only when needed. Careful monitoring of the chemistry in the aqueous bath has reduced the amount of cleaner used by half. Removing solids from the cleaning system by decanting from the bottom doubles the time between bath replacements and countercurrent flow in the rinse tanks substantially reduces water use. Addition of a small intank filter, an oil skimmer, and conversion to compatible aqueous based pressing and stamping oils also facilitated the changeover and made the new cleaning system more efficient. V. H. Blackinton's priority goal is to eliminate all use of TCE within a year; at present one small tank of TCE with increased freeboard and a cover to prevent evaporation is still used to remove buffing compound.

Decreased concentration of the cyanide bath and reducing the size of the tank from 60 gallons to 10 gallons resulted in an 80 percent decrease in the chemicals needed for those operations.

The badge clasps, which used to be loosened in a separate brite dipping step are now freed during the aqueous cleaning. The unnecessary brite dipping added copper and zinc metals to the waste water treatment system, generating large quantities of waste sulfuric acid which then required the addition of sodium hydroxide to neutralize the spent acid. Page 21 of 49 Results Reductions Achieved: In 1989, the dryer used 6,900 pounds of Freon, which escaped into the atmosphere. With the installation in 1990 of the hot air dryer, Freon emissions have been completely eliminated. The workers had routinely degreased everything, sometimes treating the same piece several times during its production; reducing cleaning operations to the minimum continues to reduce the amount of TCE used. In 1989, V. H. Blackinton used over 30,000 pounds of TCE; in 1993, 6,000 pounds of TCE were used. Unnecessary brite dipping steps, like that used for loosening clasps, have also been eliminated. The reduced brite dipping has cut H2SO4 and sodium hydroxide ( used to neutralize the H2SO4 before discharge) respectively from 20,000 pounds per year to 8,500 pounds and 16,000 pounds per year to 8,000 pounds.

Through careful monitoring of chemistry and redesign of the cyanide activation tank and the cleaning bath in the plating line, the cyanide and sodium hypochlorite used in these two operations have been reduced by 80 percent.

In 1989, V. H. Blackinton used over 20,000 gallons of water a day in its plating operations. Aggressive conservation efforts including installation of flow restricters, downsizing tanks and implementing counter current rinses, had cut use to 5,000 gallons per day in 1993. Additional implemented conservation efforts include shutting off rinse tanks during lunch, the careful monitoring of chemistry, modernization and regular preventative maintenance of valves and piping.

Economics: The cost to purchase and install the hot air dryer was $ 11,400, and the deionized water rinse cost $ 1,500. The aqueous cleaning system and four rinse tanks cost a net of $ 9,384   a small profit was realized from disposal of the old unit. The savings realized from the reduced and alternative chemical purchases for these two processes over the amount the original materials would cost today comes to at least $ 70,000 per year. Initial payback on the capital costs for new equipment, based on the savings in chemicals and waste management, was achieved in less than a year.

Watkins Johnson Company ( Palo Alto, CA) http:// www. city. palo alto. ca. us/ cleanbay/ pdf/ wj1. pdf Pollution Prevention and Wastewater Recycling at Watkins Johnson Company Building 1 Watkins Johnson Company eliminated its process discharge to the sewer from its Building 1 metal finishing operations in May 1993. Watkins Johnson now treats and reuses the wastewater generated from its plating operations. Installation of a wastewater treatment system to reduce cyanide and metals discharge to the sanitary sewer, was required by a compliance agreement with the Palo Alto Regional Water Quality Control Plant ( RWQCP) in February 1992. Watkins Johnson went beyond the requirements of the compliance agreement by implementing pollution prevention measures including consolidating plating operations, improving rinsing, waste handling, and treatment techniques; and recycling treated wastewater for use in its metal finishing process. Page 22 of 49 Watkins Johnson's metal finishing operations are conducted by three employees. The shop manager is also responsible for maintenance of the wastewater treatment and recycling system. In the Building 1 metal finishing operation, parts are plated with metals such as copper, nickel, and gold. These specialized parts are then used in semiconductor applications.

Waste Generating Activities The metal containing wastewater generated at the site is from the process rinses. When parts are removed from process baths to rinses, they carry metals out of the concentrated baths into the rinse water.

Spent process baths are also a source of waste. As contaminants build up in the baths they become less effective and must be replaced. Watkins Johnson treats most of its spent baths with the distillation treatment system. Concentrated cyanide solutions and the gold plating bath are both sent offsite for treatment.

Rinse Water Use Reduction Prior to installing the wastewater recycling system, Watkins Johnson reduced its process water use through a series of rinse water reduction measures. Reducing wastewater generation allowed installation of a significantly smaller wastewater treatment and recycling system, significantly reducing the treatment and recycling system installation and operational costs.

During the plating process, parts are dipped into tanks that contain various solutions. Postplating rinse procedures now follow the minimal water use steps described below. After the part is plated it is rinsed with a spray rinse over the heated plating solution. This keeps the metals in the plating solution and reduces drag out. The part is then suspended in a tank where the rinse water is activated by an operator controlled knee switch. Water only flows when a part is present. Parts that need further rinsing, due to their shape, can then be submerged in the rinse tank and a timer can be activated allowing the rinse water to flow for a given period of time.

Each rinse is discharged entirely only twice daily, thus reducing the overall volume of discharge rinse water and concentrating the metals. Implementing these special rinse procedures reduced the rinse water used in the plating shop from 5,000 gallons to 1,000 gallons per day.

Wastewater Treatment and Recycling Watkins Johnson installed an advanced wastewater treatment system to purify process wastewater prior to re use of that water in its plating process. The plating line rinse waters are treated on site to remove metals and cyanide. Cyanide is first destroyed in a two stage alkaline chlorination treatment process and then combined with the heavy metal waste streams from the non cyanide rinses. Under vacuum, the combined wastestreams are vaporized at 21 27 degrees Celsius. The water vapor is then condensed, deionized, and returned to the plating shop to be reused in the rinse tanks. The vacuum distillation unit is also used for on site treatment of spent Page 23 of 49 baths. The concentrated metal slurry waste resulting from this process is hauled offsite for disposal. The treatment system has the capacity to treat 1,500 gallons per day. The cost to treat one gallon of water is approximately $ 0.05.

Cost Analysis These projects involved the installation of equipment and changes in operating procedures. These changes reduced materials and water use, thereby reducing company's operating costs. The treatment system cost approximately $ 500,000. Watkins Johnson believes the installation cost was recovered within 28 months.

Wastewater Metals Discharge These projects eliminated process related sewer discharges from Watkins Johnson Building 1. The table below shows a comparison of Watkins Johnson's discharge and disposal data before and after completion of its pollution prevention projects. The rinse water use reduction projects together reduced process wastewater generation from 5,000 gpd to 1,000 gpd. These same process changes dramatically reduced wastewater nickel loads, which fell 80% from 10 grams/ day before the changes to 2 grams/ day upon completion of the rinse water use reduction projects. Installation of the wastewater recycling system eliminated the remaining 1,000 gpd of wastewater discharge, and eliminated nickel discharges to the sewer from Building 1 plating process.

Discharge/ Disposal Data Item Before Projects 1991 After Projects 1993 % Reduction Nickel 10 grams/ day 0 grams/ day 100%

Flow 5,000 gpd 0 gpd 100%

Total Facility Waste Disposal 500,000 250,000 50%

Tin Originals Inc. ( Gastonia, NC) http:// www. p2pays. org/ ref/ 07/ 06139. pdf Tin Originals Incorporated is a small manufacturer and wholesale distributor of gift and home decorating items, specializing in tin ware with a decorative finish. Most material is completely manufactured in house, and processing involves cutting, folding, assembly, finishing and shipping. The finishing process consists of baths of phosphates, acids, baking soda, and sealer. Each bath is followed by a rinse. In 1995, the facility was having difficulty meeting its permitted discharge limits for zinc. While investigating treatment alternatives, a solution was discovered that not only ensured compliance, but also eliminated the need for their discharge permit altogether and significantly reduced water consumption. Page 24 of 49 Two in line filters, a 25 micron bag filter followed by a five micron cartridge filter, were installed to remove solids so that free flowing rinsing stations could be replaced with re circulating rinse baths. Re circulating rinse water significantly reduced the volume of wastewater generated and also worked to greatly increase the concentration of zinc in the rinse. The company then began looking at systems to reduce the concentrations of zinc in the rinse baths so that it would not build to concentrations that could adversely affect the finish quality. Traditional chemical precipitation processes were determined to be too expensive and labor intensive, and required space that was not available at the small facility. The facility sought a simple, low cost, compact method of treating waste in small, discrete batches.

The company installed an ion exchange unit containing 1 cubic foot of loose, chemical specific ion exchange media, both after and in line with the two previous filters. The original purpose of the ion exchange unit was to treat the rinse water prior to discharge. However, the company discovered that after treatment through the unit, the rinse water could be re circulated back into use. Since the installation of the ion exchange unit there has been no discharge of process wastewater. Additionally, the ion exchange media only needs replacement once every three to four months. The maintenance of the system has proven quite simple. Once each week, the in line bag filters are allowed to dry and the solids are shaken off into the regular waste receptacles. Cartridge filters are allowed to dry and the solids are discarded in the same way. The ion exchange media is emptied into a container and allowed to dry before it is disposed of as solid waste also. Occasionally a biocide is added to the rinse baths to reduce biological activity.

During 1995, Tin Original consumed approximately 100,000 gallons of process water each month. In 1996, the total consumption decreased to 13,000 gallons each month, a reduction of 87%. Additionally, because Tin Originals no longer discharges process water to the sewer, they no longer have the liabilities associated with an Indirect Discharger Permit. Zinc emissions in wastewater have decreased by 100%.

During the first year of operation, the entire installation and maintenance cost was approximately $ 1100 with installation costs of approximately $ 1000 ( including all additional plumbing and filter purchases) and the replacement cost of the ion exchange cartridge media and filters. However, with the drastic decrease in water consumption came a corresponding decrease in utility bills. In 1995, the average monthly sewer bill was $ 455.65; in 1996, after the installation of the recycling system, the average monthly bill was $ 61.98, an annual savings of over $ 4,500. The payback time on the project was less than 3 months.

East Side Plating ( Portland, OR) http:// www. epa. gov/ sectors/ pdf/ performancebw. pdf By installing two cooling towers and adding sludge dryers, East Side Plating in Portland, OR, was abl to: ( 1) reduced water use by 64% ( between 1997 and 1999); ( 2) reduced sludge discharge by 67% ( between 1997 and 1999); and ( 3) reduced permitted copper, nickel, chrome, and zinc discharges by almost 50% ( between 1997 and 2002). Page 25 of 49 SWD, Inc., ( Addison, IL) http:// www. epa. gov/ sectors/ pdf/ performancebw. pdf SWD, Inc., in Addison, IL, adopted an EMS in 1997 and became the first metal finisher in the U. S. to certify its EMS to the ISO 14001 standard in 1998. Through its EMS, SWD, Inc. was able to identify the environmental impacts of molybdenum and barium as areas for improvement and took steps to eliminate both substances from all incoming raw materials. Through implementation of pollution prevention practices this facility was able to: ( 1) reduced sludge by 50% between 1996 and 1998 by changing its chemical process; and ( 2) reduced water discharge by 28% between 1996 and 2000 by reusing water in non critical rinses.

Case Studies of the Chemicals Manufacturing Industry OxyChem ( Corpus Christi, TX) http:// www. utep. edu/ success/ story. cfm? ID= 148 Wastewater at this facility is treated in a biodegradation unit. After determining that the treated effluent was of higher quality than the cooling tower make up water, OxyChem decided to reroute the effluent to the cooling tower system. The wastewater effluent was previously discharged at a rate of 184 gallons per minute. Rerouting the effluent stream resulted in reduced blowdown rate and lower water usage requirements. The water demand on the City of Corpus Christi has been reduced by over 200 gallons per minute.

The return on investment for this process change was less than 30 days due to reduced annual water costs.

DuPont http:// www. dupont. com/ corp/ news/ publications/ aboutdup/ 02Excbro. pdf Engineering Polymer's Savli compounding operation in India is located in an arid region where water consumption and water effluent are critical aspects of the right to operate. To meet the strict water requirements, a team consisting of Savli personnel, EP Japan compounding technical experts, and an Indian environmental consultant redesigned the entire vacuum extraction system for the DuPont   Zytel ® GRZ process to essentially eliminate water consumption and ensure that the small amount of water effluent met requirements for site general purpose use. Overall water consumption was reduced by > 99.5% that drove savings of $ 5,000 per year in potable water purchases. Without this innovation, it is likely that the business would not have been able to produce in India, and alternative sourcing of polymer would have seriously jeopardized the health of the business. Engineering Polymers has 70 similar processes worldwide that could benefit from this new design.

ChemTex Laboratories, Inc. http:// www. p2pays. org/ ref/ 26/ 25001. pdf Chem Tex Laboratories, a producer of specialty chemicals in Concord, N. C., requested the assistance of the N. C. Division of Pollution Prevention and Environmental Assistance Page 26 of 49 ( DPPEA) to assess various alternatives for reducing its water usages following the institution of mandatory water use restrictions by the City of Concord. The plant uses about 26,000 gallons per day of city water, a major portion of which is used as noncontact cooling water. The plant operates 10 12 hours per day, five days per week. The plant has eight water jacketed reactors varying from about 165 gallon to about 5,500 gallon capacities. A couple of the reactors are equipped with solenoid valves in the cooling water lines but most of the cooling has been done with the lines wide open. The plant is also equipped with a 10 ton chiller which cools two storage tanks. Based on a four month average, the plant uses about 26,500 gpd for process purposes. The company estimates about 4,000 gpd end up in the products and about 3,000 gpd are used to " boil out" the reactors. The effluent meter shows about 16,800 gpd go to the sewer, with about 2,600 gpd remaining used in the 150 HP boiler and for miscellaneous purposes around the plant.

The cost of the incoming water at this average rate would be about $ 23,400 per year, and the sewer charge would be about $ 25,900 per year, for a total water/ sewer bill of about $ 49,300 per year.

Water Reduction Activities Chem Tex is installing two new tanks, pumps, and a small cooling tower to cool and reuse the water formerly sewered after cooling the reactions. The plant also plans to recycle the water used to clean out the reactors. Other alternatives considered included installing additional control valves on the reactors, geothermal cooling of the water, and drilling water wells on the plant property. Their management decided water conservation was the best long term approach. It took a surprisingly small cooling tower and tank system costing less than $ 15,000 to produce these savings, and thus will also produce a good financial return on the invested capital.

Water Conserved Chem Tex's water conservation program will reduce the use of water by about 60 percent ( by about 20,000 gpd), and also reduce the plant's waste water effluent to the Concord Waste Water Treatment Plant by about 85 percent. The savings should be between $ 35,000 and $ 40,000 per year.

Advantis Technologies, Inc. http:// www. state. ga. us/ dnr/ p2ad/ advantis. html Located in Alpharetta, Georgia, Advantis, was the recipient of the 2001 GW& PCA Industrial Award for Pollution Prevention. This facility is focusing on wastewater generation and water conservation.

Wastewater Generation As with many chemical companies, water was used to rinse out chemical tanks after the manufacturing process was complete. Advantis established a program to re use all rinse water generated when cleaning a mix tank. After rinsing for a particular chemical, the rinse water is stored and then re used as make up water the next time that chemical is prepared. As a result, Page 27 of 49 Advantis no longer discharges any industrial wastewater to the city sewer system. The end result was a reduction in wastewater generation of approximately 70,000 gallons per year since 1998.

Water Conservation Advantis also made a concerted effort to conserve the amount of water used at the facility and in the manufacturing process. Some examples of their water conservation efforts are:

Establishing a manufacturing plan to run similar chemicals back to back in order to reduce the number of cleanups and thus reduce the amount of water needed for rinsing.

Modifying several formulations to make them fall into existing chemical groups to avoid special runs with unique waste streams.

Installing a programmable irrigation timer with multiple time and zone settings.

Case Studies of the Pesticides Manufacturing Industry DuPont http:// www. dupont. com/ corp/ news/ publications/ aboutdup/ 02Excbro. pdf Eliminating By Products Generated in Process Creates Business Value A Crop Protection team on the Griffin site in Brazil discovered that the by product generation of 2,3 dicholoronitrobenzene, dichloronitrobenzene, and chloronitrophenols during the production of the DuPont   Diuron ® and DuPont   Propanil ® herbicides could be significantly reduced or eliminated by making process modifications. Using teamwork and Six Sigma methodology, the process changes were introduced into the plant. The total economic benefit of the program exceeds $ 1 million per year while also significantly reducing storage, people exposure, and environmental containment issues.

This team demonstrated that their vision to drastically reduce residual by product production generated significant value for shareholders and the local community. The use of Six Sigma methodologies also demonstrates the value of integration of sustainable growth and productivity improvements. The team's commitment to the goal is zero is obvious through their focus on continuous process, practices, and products improvements.

Du Pont La Porte Plant ( La Porte, TX) http:// p2. utep. edu/ success/ story. cfm? ID= 64 In an effort to comply with new regulatory requirements on herbicides, a Heinkel centrifuge unit was installed at this facility to decrease uracil herbicide releases to wastewater. This technology will not only recover herbicides from wastewater, but will also recycle a large portion of the water discharged from the process, reducing the need for fresh make up water. The centrifuge process reduces releases of one herbicide by 8,900 lb/ yr, and is expected to reduce Page 28 of 49 releases of another uracil herbicide by 119,000 lb/ yr. In addition, TOC loadings to the wastewater treatment plant will be reduced by 41 percent, and hydraulic loadings will be reduced by 51 percent.

This technology improves herbicide yield and reduces wastewater treatment costs, resulting in an estimated savings of $ 40,000 per year.

Organika Azot ( Poland) Reference: Environmental Management Centre. Waste Minimization at a Pesticide Manufacturing Plant. Mumbai, India, 1992. http:// www. emcentre. com/ unepweb/ tec_ case/ chemical_ 24/ process/ p23. htm.

The Organika Azot plant in Poland produces insecticides, herbicides, and fungicides. In 1992, as part of the Industrial Waste Minimization Program in Poland, cleaner production measures were evaluated. Three of these measures resulted in the reduction of wastewater discharge and are detailed below.

Recycle of Process Wastewater The site previously purchased 50,000 cubic meters of water per year for its production processes. The site treated its wastewater through primary and biological treatment systems. As part of the cleaner production measures, the reuse of treated effluent was evaluated. The results found that approximately 150,000 cubic meters of effluent per year could be reused at specific operations rather than discharged.

The implementation of the project saved money for the site by decreasing the amount of water purchased, amount of wastewater discharged, and amount of environmental fees.

Investment: 1,050 US$

Savings: 1,600 US$/ year

Payback Period: < 3 weeks Reuse of Washing Water As part of the production of Brilane ( an insecticide), a benzene organic phase containing the intermediate chemical dichloroacetophenone ( DCAP) undergoes a three step washing process. The washing processes generate wastewater containing aluminum salts. The site previously sold a portion of the spent wash water as a 25 percent solution of aluminum chloride; however, the majority of the spent wash water was discharged to the treatment plant.

Experiments performed during the clean production measures evaluation showed that the spent wash water from the second and third washings could be reused in the hydrolysis process ( eliminating the need to purchase fresh water).

The implementation of the project saved money for the site by decreasing the amount of raw material purchased, amount of wastewater discharged, and amount of environmental fees. Page 29 of 49

Investment: 1,100 US$

Savings: 13,000 US$/ year

Payback Period: 1 month The clean production measures evaluation included a review of the site's hot and fresh water distribution and usage. The evaluation showed that the use of proper monitoring equipment would significantly decrease the consumption of hot water and industrial water at the site. The monitoring also helps to identify leaks throughout the pipelines.

The implementation of the project saved money for the site by decreasing the amount of hot water, fresh water, and industrial water required for the site.

Investment: 5,965 US$

Savings: 11,900 US$/ year

Payback Period: < 4 months Case Study of a Pesticide Manufacturing Facility Reference: Matthew J. Barcaskey. An Analysis of Pollution Prevention Opportunities and Impediments in the Chemical and Allied Products Sector in Georgia. Georgia Department of Natural Resources, http:// www. ganet. org/ dnr/ p2ad/ pblcations/ chemical/ pest_ ch. htm.

The case study site formulates pesticide products using a batch process. The site pipes raw materials from storage tanks into its mixing kettles. The resulting pesticide formulations are then sent to a container filler line for packaging and distribution.

The site generates most of its wastewater from equipment cleaning between batches. The cleaning process involves spraying water or solvent into the kettle, circulating the rinsate through the pipes and filters, and pumping the rinsate to a holding tank. The site then sends the rinsate through the filler lines and out of the process. The kettle, pipes, and filters are then blown dry.

Source reduction practices implemented by the site include the following:

Air blowing of lines before and after system cleaning to reduce the amount of rinsate generated.

Reuse of rinsate for future batches ( when possible). Reuse of water rinsate for next water based product and reuse of solvent rinsate for next solvent based product.

Use of absorbent pads rather than clay for spills. Pads are then wrung out and reused, resulting in reduction of hazardous waste to be disposed. Page 30 of 49 DuPont http:// www. dupont. com/ corp/ news/ publications/ aboutdup/ 02Excbro. pdf Eliminating By Products Generated in Process Creates Business Value A Crop Protection team on the Griffin site in Brazil discovered that the by product generation of 2,3 dicholoronitrobenzene, dichloronitrobenzene, and chloronitrophenols during the production of the DuPont   Diuron ® and DuPont   Propanil ® herbicides could be significantly reduced or eliminated by making process modifications. Using teamwork and Six Sigma methodology, the process changes were introduced into the plant. The total economic benefit of the program exceeds $ 1 million per year while also significantly reducing storage, people exposure, and environmental containment issues.

This team demonstrated that their vision to drastically reduce residual by product production generated significant value for shareholders and the local community. The use of Six Sigma methodologies also demonstrates the value of integration of sustainable growth and productivity improvements. The team's commitment to the goal is zero is obvious through their focus on continuous process, practices, and products improvements.

Case Studies of the Pharmaceuticals Manufacturing Industry An award winning P2 success in the pharmaceutical industry http:// www. nywea. org/ clearwaters/ 301050. html Seeking to overcome its notoriety as one of New York's largest industrial sources of chemical releases, a major pharmaceutical manufacturer undertook a massive pollution prevention program. This strategic effort included contributions from the facility's chemical development, manufacturing, and environmental divisions and was focused on solvent substitution and process modifications.

Facility researchers succeeded in developing a penicillin V isolation procedure that combined whole broth filtration with solvent substitution after they assessed potential pollution prevention opportunities and pilot tested alternative methods and materials. Their efforts have reduced reportable releases from the facility by more than 1 million lb/ yr.

The pharmaceutical complex consists of manufacturing, quality control and research laboratories, pilot plants, and administrative offices. Manufacturing activities include production of several pharmaceutical intermediates including 6 aminopenicillanic acid ( 6 APA) which is used worldwide in the production of anti infectives such as amoxycillin and ampicillin.

The manufacturing process for 6 APA begins with the fermentation of penicillin V in a nutrient rich aqueous broth. Next, the penicillin V is extracted in a solvent based isolation process. After isolation, the penicillin V extract is enzymatically hydrolized to produce 6 APA.

Long known to be a significant source of fugitive and point source air emissions, the 6 APA manufacturing process was a ready pollution prevention target. Several obstacles, however, Page 31 of 49 had to be overcome. For instance, in the highly regulated pharmaceutical industry, even the simplest process modifications often require extensive pilot testing and lengthy regulatory approvals to confirm that the effectiveness and safety of the drug produced is not compromised.

Process Description The manufacture of 6 APA was a complicated multi step process involving fermentation, extraction, concentration, crystallization, filtration, washing, and drying. The former isolation process used:

1. Methyl isobutyl ketone ( MIBK) to perform whole broth extraction of the penicillin V from the fermentation process;

2. Concentration of the penicillin V extract with six Merco centrifuges ( manufactured circa 1970);

3. Crystallization of penicillin V slurry by a series of filtrations and washes using acetone; and 4. Drying of the crystallized penicillin V product to ready it for further processing ( for example, 6 APA production).

Fueled by safety and environmental concerns associated with these processes, the facility organized a pollution prevention task force consisting of engineers and scientists from the facility's chemical development and manufacturing divisions. Their goal was to develop a process that would eliminate or materially reduce the use of toxic solvents used in the production of penicillin V.

Following a series of evaluations and pilot studies, the team identified three significant opportunities for pollution prevention:

Replacement of the whole broth extraction step with an ultrafiltration system;

Substitution of n butyl acetate for MIBK as the extraction solvent and completion of the extraction following filtration; and

Replacement of the outdated centrifuges with more technologically advanced centrifuges.

The ultrafiltration system separates the penicillin V from the fermented broth by passing the broth tangentially over a membrane at high velocity and pressure. Membrane surfaces are kept clean by the high velocity profile, and the pressure differential forces a clear liquid solution of the product through the membrane. This effectively filters the biomass and other insoluble impurities in the broth. The permeate is sent to a surge tank for further processing; the retentate, containing primarily mycelium, may be safely discharged to the process sewer system. Page 32 of 49 Risks of MIBK and n butyl Acetate Hazardous Characteristic MIBK   butyl Acetate OSHA 8 hr limits Exposure limits ( ppm) Biological limits ( mg/ L) 50 2 150 not identified Toxicity ( ACGIH) Time weighted average ( ppm) 20 75 150 200 Biodegradability ( BOD) 2.72 2.21 Flash point ( deg F) 62.6 72 TRI listed chemical? yes no Another innovation in the new isolation process was substitution of n butyl acetate as the extraction solvent rather than MIBK. MIBK is defined as a hazardous air pollution under the Clean Air Act and is a toxic chemical subject to reporting under community right to know laws such as SARA Title III. N butyl acetate is nearly three times less toxic than MIBK and is not a SARA reportable chemical.

Since the extraction now occurs after filtration, less solvent is involved. The efficiency of the extraction is also enhanced by the whole broth filtration process because the number of centrifuges required for concentration is reduced. Furthermore, since the solvent extraction procedure is now physically isolated from the filtration system, the extraction process has been equipped with a separate collection system. Wastewater discharges from the new centrifuges are directed to an existing stripper system. Since this wastewater discharge no longer contains broth solids, the stripper is able to treat the effluent more efficiently, improving the effectiveness of solvent recovery operations.

Centrifuge operations were previously conducted in six Merco centrifuges  encased metal bowls suspended on a high speed drive shaft and operated under atmospheric conditions. They were known to be a significant source of fugitive emissions of MIBK. These centrifuges were replaced with two enclosed units which reduce fugitive losses of MIBK and lower worker exposure. The new centrifuges also allow nitrogen blanketing of the equipment. The only emissions from this equipment now are from conservation vents that are directed to an existing carbon adsorption VOC recovery system.

Cost/ Benefit Analysis Costs to Implement Changes Capital item Cost Civil work $ 100,000 Building 740,000 Equipment 4,820,000 Mechanical work 720,000 Page 33 of 49 Electrical work 1,200,000 Automation and instrumentation 660,000 Engineering 820,000 Subtotal $ 9,060,000 Contingency ( 10%) 910,000 Total $ 9,970,000 The estimated capital costs to implement these changes were $ 10 million. New process equipment and advanced electrical controls made up 60% of this total. The $ 10 million of capital costs are offset by a 10% increase in production capacity. This increase is largely attributable to removal of the bottleneck that was the extraction process. This increased efficiency helped the facility realize additional cash flow of $ 4.9 million/ yr resulting in an undiscounted payback period of 2.7 yr for this project.

Environmental Benefits Releases: 1994 and 1997 ( lb/ yr)

Environmental Media 1994 MIBK 1994 n butyl Acetate 1997 MIBK 1997 n butyl Acetate Net Reduction Air ( point and fugitive) 1,000,000 0 0 250,000 75.0%

Wastewater 230,000 0 0 35,000 84.8%

Hazardous waste 20,000 0 0 5,000 75.0%

Total facility TRI releases 1,900,000 860,000 54.7%

Environmental benefits of the new isolation process include across the board reductions in chemical releases to the air, water, and land. Despite the 10% increase in production that accompanied this pollution prevention project, the facility has reduced actual solvent air emissions from this process by 75%. Furthermore, since n butyl acetate is not a SARA reportable chemical, the facility has reduced reportable releases by more than 1 million lb/ yr.

Wastewater discharges of solvents have also been drastically reduced. Since extraction is now performed after filtration and the discharge from the new centrifuges has a dedicated collection system, the recovery efficiency of the stripper system is no longer inhibited by the presence of broth solids in the effluent. Furthermore, since less solvent is required to effect the extraction, there is a corresponding reduction in wastewater loadings.

Hazardous waste generated from the process has been reduced by 75%. The efficiency of the new isolation system is such that it has allowed the facility to remove the polish filtration step at the end of the process. Reduced usage of cartridge filters, filter paper, and other solid wastes have led to a 15,000 lb/ yr reduction in off site hazardous waste disposal. Page 34 of 49 Other Benefits The company has garnered social rewards and improved safety conditions from this P2 initiative. The facility has benefitted from improved public perception and better community relations. Indeed, having been awarded the 1996 New York State Governor's Award for Pollution Prevention, the facility has gained a great deal of positive press both in New York and nationally.

Abbott Laboratories ( Coyoacan, Mexico) http:// abbott. com/ citizenship/ ehs/ highlights. shtml Water Conservation: Coyoacan, Mexico Our Coyoacan water recycling team implemented a conservation project that included the recirculation of cooling water for the sterilization process at our nutritionals plant. The team installed a cooling tower, heat exchangers and filters, which enable the recycling of cooling water up to 30 times. This resulted in an overall reduction in water use of 46 percent, or 30.5 million liters annually, saving approximately $ 110,000 per year. The new process also markedly increased the productivity of the sterilization cycle, with one sterilization process increasing production capacity by 54 percent ( from 29,250 to 45,000 bottles per shift).

Abbott Laboratories ( Granada, Spain) http:// abbott. com/ citizenship/ ehs/ highlights. shtml Waste Reduction: Granada, Spain Our Granada facility has made significant progress on its aggressive nonhazardous waste reduction goals, while cutting costs, reducing liability and decreasing our regulatory burden. Since 1999, the facility has reduced the volume of nonrecycled waste by 73 percent; reduced disposal costs by 70 percent; and is now generating income from the sale of recyclable waste to third parties.

Waste Minimisation in a Bulk Drug Manufacturing Unit  A Case Study http:// www. cleantechindia. com/ eicnew/ successstories/ bulk. html Introduction The pharmaceutical industry, which manufactures a large variety of products uses a huge amount of resources in terms of energy, water and various utilities, besides utilizing in large quantities a whole range of chemicals. Both domestic and multinational companies are engaged in manufacturing bulk drugs in India. They employ advanced technologies in the production processes, yet scope exists in minimizing wastes being generated in these industries.

The case presented here describes waste minimisation potential explored in one such bulk drug manufacturing industry. The study was aimed at reducing aqueous load to the incinerator of Page 35 of 49 the unit. The aqueous wastes being generated during the manufacture of an anti helminthic drug called Albendazole is the focus of the study.

Production Process: Anti Helminthic Drug ( Albendazole)

Albendazole © H N O S) with the chemical name: methyl 5  ( propyl thio) 2  benzimidazole carbamate is an anti helminthic drug prescribed for humans.

The base chemical used in the manufacture of the drug Albendazole is ( ortho)  Nitro Aniline which is converted to ABZ Thiocyano in an independent process, or purchased by the plant. Through a sequence of chemical reactions under specified process conditions, ABZ Thiocyano ( molecular wt. 195 gms.) is converted to the final product Albendazole ( molecular wt. 265 gms.).

The reactions in the production process are carried out in reactor vessels ( or kettles) made of stainless steel ( in some cases they are glass lined) with necessary infrastructure apparatus for monitoring and controlling process conditions and using the various utilities. The various steps in the manufacturing process ( depicted for reaction process at each stage) are numbered as per sequence of operations observed. A brief description is given below.

In Stage 1 conversion of ABZ Thiocyano to ABZ PT occurs through steps 1  5. Intermittent tests using Thin Layer Chromatography' technique for samples extracted from the reactor is carried out to check status of the reaction and its completion, other quality assurance tests are also carried out. Upon completion of reaction n propanol solvent is recovered by distillation ( step 6). The product mass is washed by water and brine solution to remove impurities ( steps 7 and 10). The product is extracted by toluene ( step 8) and the toluene containing product is separated from other aqueous mass in the reactor by simple decantation/ separation of the immiscible layers owing to density difference ( steps 9 and 11). Toluene is also used to recover washed out product from aqueous/ mother liquor ( step 14). Thereafter toluene is separated from the product by distilling it out by raising temperature to 105C 130 C ( step 17). The recovered product ABZ PT is next charged to reactor in stage 2. Similarly in stage 2, ABZ DA is produced from ABZ PT in a suitable reaction mass charged in a reactor under suitable process conditions. In stage 3 pure ABZ DA is distilled out by high vacuum distillation ( vacuum maintained between 0.1  0.5 torr) at 180 250 degree C. Stage 4 involves preparation of Sodium Ester ( in situ) and allowing it to react with ABZ DA under suitable reaction conditions in the reaction mass. The final product mass is obtained after refluxing out acetone solvent. The product is then recovered through centrifuge where from the separated mother liquor ( aqueous wastewater) is despatched to the incinerator. The product undergoes several washings at the centrifuge before being sent for drying, quality testing, micronising and packing. Page 36 of 49 Reactant Addition in Excess of Stoichiometric Requirements Stage Chemical/ Reactant % Excess Stage 1 NaOH 99%

CHBr 25%

Stage 2 NaHS 97%

Stage 4 Cyanamide 135%

Sodium Ester ( produced in situ) 107%

CH( 3) COOCI ( MCF) 120%

NaOH 107%

Waste Assessment and Process Audit A detailed study of the process chemistry under each stage of the manufacturing process ( Albendazole Manufacture) and analysis of mother liquors/ aqueous waste waters led to the following observations:

Observations ( A) Several active ingredients were added in excess in the various reaction stages in comparison to stoichiometric requirements as depicted in the table above. The unit attributed the addition of excess chemical inputs in the process as a requirement to ensure optimum product yield.

( B) The aqueous waste water generated contained large quantities of salt and impurities besides residual solvents like n propanol, methanol etc. The aqueous generated in Stage 1 averaged 450 ltrs. per batch of ABZ Propyl Thio ( ABZ PT) manufactured, and in Stage 2 averaged 650 ltrs. per batch of ABZ Diamine ( ABZ DA) manufactured. Thus in order to manufacture 3 batches of final product ( Albendazole), where two batches of ABZ PT and one batch of ABZ DA are required, a total of 1550 ltrs. of aqueous waste water ( Mother Liquor) is generated which is sent for incineration. The burden on the incinerator thus was found to be immense where Liquid Diesel Oil ( LDO) was consumed at the rate of 15 ltrs/ hr to incinerate the above mother liquor and other aqueous streams fed to the incinerator. The various aqueous streams were found to be fed to the incinerator at the rate of 37 ltrs/ hr in addition to 15 ltrs/ hr of organic effluent ( organic effluent received from antibiotics producing unit). The cost of operating the incinerator ( furnace temperature maintained above 950 C requiring the above feed rate of LDO) and the associated air pollution control system was considered to be a huge drain on the resources of the organization.

( C) The quality of aqueous when analyzed revealed that they were strong effluents with a BOD/ COD ratio of less than 0.3. These malodorous waste waters are highly alkaline ( pH > 12) and contain solvents such as n propanol, methanol etc., between 3.5% to 11% respectively. Page 37 of 49 Moreover the inorganic salts contained were very high such that the aqueous from ABZ PT and ABZ DA manufacture had TDS in the range of 217000 mg/ l to 362000 mg/ l respectively.

( D) Approximately 35 40 kg of solid organic residue ( solid waste) was generated during Stage 3 ( purification process by High Vacuum Distillation) which was indicative of heavy product loss per batch.

Load Reduction at the Incinerator   Waste Minimisation Option( s)

The waste assessment study led to the exploration of waste minimisation options for reducing aqueous load at the incinerator.

( A) In Stage 1 Step 10 Hot Water + NaCI is used to wash organic layer ( toluene solvent + product) to remove impurities. Subsequently aqueous layer separated at Step 9 and aqueous salt water wash separated in Step 11 are recharged into the reactor tank for recovery of washed out product from the aqueous layers by extraction of organic product using toluene solvent in Step 14. It was determined that the product concentration in aqueous salt water wash was negligible. Moreover, this waste water was suitable to be discharged to solar evaporation pond ( SEP). The unit was therefore advised/ recommended that Step 11 aqueous need not be recharged to the reactor, and instead this aqueous ( approx. 130 ltrs.) be sent to the SEP, and thus be eliminated from further steps so that it is not mixed with the wastewater stream ( mother liquor) that is currently sent for incineration. Similar to Stage 1, in Stage 2 the aqueous salt water wash of Step 8 ( approx. 265 ltrs.) was analyzed and found suitable to be discharged to SEP without having to be recharged to the reactor in Step 10. The above measures therefore would ensure that for every three batches of Albendazole produced, a total of 525 ltrs of aqueous salt water wash stream ( 2* 130 ltrs of Stage 1 + 1* 265 ltrs of Stage 2) could be sent to SEP and not burnt at the incinerator.

( B) The remaining aqueous wastewater ( mother liquors) generated during production of 156 kg of Albendazole ( 3 batches of Albendazole), through 2* Stage 1 and 1 * Stage 2 ( i. e. 640 ltrs of Stage 1 + 385 ltrs of Stage 2 of mother liquor( s)) could be sent for solvent recovery. It was assessed that the recovery of n propanol and methanol from these mother liquors as analyzed through the laboratory tests amounted to approx. 80% of the concentration of these solvents in the discharged mother liquors. Therefore it was estimated that at the Solvent Recovery Unit ( SRU) at least 50% of these solvents in the mother liquor could be recovered in about 25% of the distillate. The recovered distillate at the SRU could then be subject to incineration ( having thus an enhanced calorific value). Balance 75% volume of aqueous wastewater ( mother Liquor) would thus be suitable for discharge to SEP or taken to ETP for further treatment. Thus the load to the incinerator would further be reduced by 765 1trs.

Results The above measures focused on reducing aqueous load to the incinerator resulted in 260 ltrs of aqueous waste water being sent for incineration instead of 1550 ltrs ( a reduction of 83% in volumetric load to the incinerator) from the Albendazole manufacturing process. This was estimated to result in reduction of LDO consumption at the incinerator by 30%. The overall Page 38 of 49 benefits taking into account fuel savings, savings in treatment cost at ETP ( due to diversion of some effluent streams to SEP) and savings in terms of reduced manufacturing time in Stages 1 and 2 ( thus leading to increased production capacity per annum) was estimated to be approx. Rs. 10 lakhs per annum.

Conclusion The Waste Assessment study strengthened the resolve of the management to undertake resource conservation measures especially focused on reducing inputs of reactive ingredients to optimal levels. Further the unit initiated exploration of potential improvements in high vacuum distillation process ( Stage 3).

The unit initiated feasibility studies for waste heat recovery from the flue gases discharged from the incinerator. The waste minimisation study led to a new initiative in the industry to explore resource conservation measures in its bulk drug and other units through focused R& D efforts.

Source : National Productivity Council ( NPC)

Genentech ( Vacaville, CA) http:// ateam. lbl. gov/ cleanroom/ doc/ Genentech_ Final. doc Genentech: New Energy Efficient Pharmaceutical Manufacturing Cleanroom Facility,

Project Benefits Summary Estimated Annual Energy Cost Savings $ 552,800/ y Actual Incremental Project Cost $ 1,783,360 Utility Incentive $ 842,400 Project Payback ( after incentive) 1.7 years Facility Description The Genentech Vacaville facility is made up of six buildings in Vacaville California. This is the second site for Genentech, the first site is located in South San Francisco, CA. Genentech is a leading biotechnology company that discovers, develops, manufactures and markets human pharmaceuticals for significant unmet medical needs.

The site's six buildings include:

1. 180,000 ft2 Bulk Manufacturing Building with class 10K and 100K cleanroom areas and 10 air handling units ( approx. 400,000 cfm); Page 39 of 49 2. 18,000 ft2 Central Utility Plant with 3,400 tons of chilled water, 3,000 scfm of compressed air, 14,000 gpm of tower water ( process and HVAC), and 70,000 lb/ hr of high pressure steam;

3. 40,000 ft2 Lab/ Administration Building;

4. 30,000 ft2 Warehouse;

5. 20,000 ft2 Facilities Service Building; and 6. A " spine" connecting all of the buildings together.

The energy saving measures for the site were aimed at the entire facility. However, this study focuses only on measures that affect the cleanroom areas. In addition to internal production requirements, these areas are required to comply with Food and Drug Administration ( FDA) regulations for cleanliness because the facility is intended for the production of pharmaceuticals.

Project Description A total of twenty two separate energy efficiency measures were performed at the Vacaville site. These measures are summarized below with a mention of estimated energy savings. The estimated savings were calculated by Genentech's energy consultant, Southern Exposure Engineering based upon baseline and enhanced energy consumption models. No measured data is currently available for these measures.

Key Aspects of the Energy Efficiency Project Discharge Air Temperature Reset ( Makeup Air Handlers)

Control logic was implemented to reset the discharge air temperature up from 55 ° F to 60 ° F when the demand for cooling decreases. This leads to a reduction in energy use because the makeup air is not cooled all the way down to 55 ° F. All of the cleanrooms are regulated by the FDA, which requires that they be supplied with a constant volume of makeup air. This temperature reduction prevents overcooling and subsequent unnecessary reheating of the supply air to the space, thereby saving chilled water and steam plant energy. This measure is expected to have annual energy cost savings of about $ 155,000/ y and a reduction in peak electrical load of about 19 kW.

Variable Speed Drives for the Variable Volume Air Handlers Instead of inlet vanes for the supply and return fans, variable speed drives ( VSDs) were installed on the six variable volume air handlers throughout the building including one serving the cleanroom. The VSDs reduce the horsepower of the fans to reduce flow, whereas inlet vanes reduce the flow by increasing pressure drop while the fans are still running full speed. VSD operation reduces fan motor energy use more than vanes do at low flow conditions. The annual Page 40 of 49 energy cost savings are expected to be about $ 23,000/ y with a reduction in peak load of about 40 kW.

High Efficiency Boilers and Boiler Economizers High efficiency boilers were installed as well as boiler economizers. The boiler stack economizers recover waste heat out of the flue gas, allowing more steam generation using the same amount of fuel. Together these measures are expected to have annual energy cost savings of about $ 48,700/ y.

Tower Water for Process Cooling Water from the cooling towers is being used for high temperature processes that do not need the low temperatures provided by the comparatively less efficient chillers, which operate at 0.5 kW/ ton efficiency, at best. The cooling towers are able to provide cooling at about 0.04 kW/ ton ( an order of magnitude improvement in efficiency). The cooling towers provide 75 ° F water for processes that do not require 40 ° F chilled water such as pasteurizing and cooling for the water for injection ( WFI). This measure is expected to save about $ 62,700 annually and reduce peak load by about 455 kW.

Process Chiller with a Surge Tank A dedicated process chiller was installed in manufacturing building to provide the low temperature processes with 40 ° F water instead of using the chilled water from the central utility plant. A surge tank was also installed for chilled water storage to reduce the peak electric demand. The surge tank holds 15,000 gallons and provides approximately 600 ton hours of thermal storage. Large energy savings also come from this separation of low temperature loads from the higher temperature loads. This allows the central plant to operate at 44 ° F, instead of 40 ° F, resulting in a significant improvement in its efficiency. The low temperature chiller and surge tank are expected to save about 152,000 kWh annually and reduce peak loads by about 560 kW, results in cost savings of about $ 36,000/ y.

High Efficiency Equipment and Unequal Chiller Sizing A high efficiency process chiller and high efficiency central plant chillers, vacuum pumps, and motors were installed. In an effort to operate the chillers as close to full load as possible, where they are most efficient, a 600 ton chiller and two 1,400 ton chillers were selected instead of three 1,134 ton chillers. This unequal sizing method saves energy by allowing the chillers to stage up in smaller steps and operate much closer to full load. The two large chillers are run at full load while the smaller one can be run to supply any additional cooling that is needed. By selecting high efficiency equipment and unequal sized chillers, about $ 113,250 will be saved annually with a reduction in peak load of 296 kW. Page 41 of 49 Low Approach Cooling Towers Large cooling towers were installed to reduce the approach from 14 ° F to 8 ° F above the design wet bulb temperature of 71 ° F. In addition, the spray nozzles were reconfigured to spread the condenser water more evenly over the fill while allowing the flow to better match the required flow for the chillers. This modification of the nozzles allowed the approach to drop even further down to 4 ° F. There was an increase in cooling tower fan power from 102 kW to 167 kW, however, much more energy was saved by providing the chillers with cooler condenser water, which improves the ability of the chiller to reject heat. This reduction in condenser water temperature in expected to improved the efficiency of the large chillers from 0.62 kW/ ton to 0.49 kW/ ton ( 0.013 kW/ ton per ° F decrease in condenser water supply temperature). This measure is expected to save about $ 24,000 annually with a decrease in peak load of 70 kW.

Pump Variable Speed Drives VSDs were installed on the condenser water pumps, primary chilled water pumps, secondary chilled water pumps, tertiary chilled water pumps, and heating water pumps. The VSDs save energy by precisely matching the flow and the pressure requirements of the system to minimize pump energy. These drives will save approximately $ 36,900 annually and will reduce the peak demand by 140 kW.

Applicability to the Cleanroom Industry These efficiency measures have not inhibited Genentech from complying with strict FDA regulations for pharmaceutical plants. The plant it is expected to operate and more reliably with these modifications and, because the project had an excellent payback of 1.7 years, after the utility incentive, it will be more profitable to operate in the long run. One example of improved reliability is the surge tanks, which guarantee that process chilled water will be available when needed in case of a shutdown.

Part of the reason that this project was so successful was that the measures could be implemented in the development phases of the plant before any equipment was purchased or installed. Energy efficiency measures implemented in a new building can achieve greater and more cost effective savings than retrofit measures implemented in existing buildings.

Project Challenges Genentech encountered a number of challenges while trying to implement energy saving measures for this project. In a concerted effort to maintain the goal of efficient operation, Genentech worked through solutions to most problems they encountered. Some of these problems are common in the cleanroom industry and their solutions should be instructive for other facility operators and planners. The first problem was that no review period was scheduled for analysis of the energy saving alternatives. These reviews were to be included in the overall design review period, where they would probably fall through the cracks. To solve this problem, the energy consultant was integrated with the design team to provide quick feedback on ideas and recommendations to improve energy use during the design process. Secondly, no defined budget Page 42 of 49 was allocated for development of energy saving ideas at the beginning of the project. However, money for actual projects was included in the overall project budget. The solution was to obtain utility funding for idea development and analysis and with utility incentives for ideas that resulted in a payback of greater than two years. A third challenge to successfully capturing the savings from energy efficiency measures lies with the building operations staff. This is being addressed through education, training and awareness of the original design intent.

Merck & Company Inc.  Cherokee Plant ( Northumberland County, PA) http:// www. dep. state. pa. us/ dep/ deputate/ pollprev/ pdf/ fact_ sheets/ fs1580. pdf Background Merck & Company Inc. established a pharmaceutical manufacturing facility in Riverside, Northumberland County, in 1950. Since 1984, this facility has used methylene chloride, a volatile organic solvent, to synthesize imipenem, a component of the broad spectrum antibiotic drug PRIMAXIN. Methylene chloride is an animal carcinogen and is listed as a priority pollutant by the federal Environmental Protection Agency ( EPA). Changes in the use of these chemicals can reduce environmental emissions of suspected carcinogens.

In April 1989, Merck voluntarily established environmental policy goals to reduce air emissions of carcinogens or suspect carcinogens by the end of 1991, then to eliminate or reduce air emissions by the end of 1993. Another goal was to reduce all environmental releases of toxic ( SARA) chemicals, including transfers of materials offsite for treatment or disposal, by the end of 1995. Although manufacturing operations have grown, Merck met its 1991 goal.

The federal Clean Air Act Amendments of 1990 address methylene chloride emissions in the pharmaceutical industry through the Hazardous Organic National Emission Standards for Hazardous Air Pollutants ( HON) regulations, which were proposed on Dec.! 31, 1992. More regulations are due from EPA in November 1997.

Process Change Methylene chloride was the major solvent used in the synthesis of imipenem. In order to meet its air emissions goals, Merck chemists and engineers developed a new manufacturing chemistry process that eliminated the use of methylene chloride in the synthesis of imipenem at a cost of $ 34 million. As part of this change, Merck substituted smaller amounts of solvents which are viewed to have fewer environmental effects than methylene chloride. This new process was implemented at Merck ¹ s Cherokee plant in 1992.

Some of the other chemistry process modifications include:

1. Computer controlled ultrafiltration technique to filter extremely small particles. This method increases product yield and improved quality of imipenem; and 2. Solvent recovery to reuse solvent, which reduces solvent consumption and disposal. Page 43 of 49 Equipment Change When the new process was installed, the factory area was upgraded with a computerized distributed control system ( DCS) and equipment modularity. The number of imipenem processing operations was reduced by almost 50percent with the DCS automated and sequenced chemical reaction steps. Key measurements are continuously monitored by a computer that operates valves, pumps and motors on the equipment to provide control of the chemical process. The DCS reduces the potential for human error.

Environmental Results Reduced VOC Management With the new process, Merck eliminated not only the purchase of significant quantities of methylene chloride, but also the storage and disposal of hazardous waste. According to Merck, the new chemistry process has also resulted in a 75percent reduction of biological oxygen demand ( BOD) load to the onsite waste water treatment plant. BOD is the amount of oxygen used by microrganisms in the breakdown process of pollutants in polluted water and waste water.

Also, best available technology end of pipe controls were added with the installation of a fume incinerator. Toxic ( SARA) air emissions were decreased more than 300,000 pounds a year in the antibiotic production area by this incinerator.

Bonuses from the new process were decreased risk of accidental spills of hazardous materials, increased employee protection, and ease of achieving compliance with more stringent environmental regulations. Additionally, Merck reduced its environmental liability by implementing pollution prevention into its manufacturing process.

Cost Savings The improved process lowered production costs of imipenem. At an estimated savings of more than $ 14 million per year, Merck & Company expects a short term payback of their $ 34 million investment for the new process.

Pollution Prevention Goal The goal of pollution prevention is to reduce the quantity or toxicity of waste generated within the production process. To achieve this goal and protect the environment, Merck ¹ s Cherokee Plant personnel developed an innovative manufacturing process that eliminated the use of methylene chloride, increased product yield and added manufacturing flexibility for future process changes.

These efforts were recognized when Merck won the Governor's Waste Minimization Award in 1990 and 1992. 20CO2 emission reduction could also be achieved by switching to alternative fuels or purchasing steam, without reducing energy consumption.

Page 44 of 49 This case study illustrates how industry can use innovation to protect the environment by preventing pollution before it is created, contain costs and boost productivity.

Novartis ( Rovereto, Italy ) http:// www. novartis. com/ downloads_ new/ news/ AR03_ HSE. pdf Health, Safety and Environment This section summarizes the Group's Health, Safety and Environmental ( HSE) performance in 2003. Our HSE targets focused once again on reducing the number of accidents, lowering energy use/ CO2 emission, safely disposing of the hazardous waste we produce, and successfully integrating recently acquired partners and newly founded organizations. This report describes the most important measures undertaken to fulfill our ambitious targets, and discusses our achievements as well as areas in which we intend to improve. The full Novartis HSE report is available on our website at www. novartis. com/ hse. There you will also find additional information on all the issues mentioned in this report.

Strong Commitment Protection of the environment has a high priority in all our activities. We strive to make efficient use of natural resources and minimize the environmental impact of our activities and products.

Between 2001 and 2003, we set ourselves the target of reducing our direct CO2 emission by 3% ( based on 2000 emission levels). As can be seen in our report on Air Emission ( see page 66) we achieved a reduction of 2.8%, in spite of a 4.8% growth in production. The reduction was facilitated by a move to more energy efficient facilities, and has resulted in a CO2 emission level, relative to sales, that is well below the industry average.

In light of these achievements and with the goal of further improvement, we have proposed individual energy efficiency targets for the Pharmaceuticals and the Consumer Health Divisions for 2004 2006. We will continue to report our absolute CO2 emission and will also include indirect emission ( e. g. from electricity and purchased energy).

Our focus on energy efficiency as opposed to absolute CO2 emission better reflects our commitment to the sustainable use of natural resources20. Energy efficiency improvement targets for each Business Unit will be 2% per year, based on their most representative denominator ( e. g. sales, production, employees). Moreover, each Business Unit must report energy saving projects that amount to a total reduction of 1% of the previous year's energy consumption. 21ISO issued the international standard ISO 14001 for environmental management systems in 1996.

Page 45 of 49 Enough Water for a Small City When Sandoz, our generic pharmaceuticals Business Unit, originally acquired the Roferm S. p. A. plant at Rovereto in Italy in 1995, there was considerable room for improvement both economically and environmentally. Following the acquisition, the product portfolio was adapted to the needs of Sandoz and focused on the production of antibiotics. Investments worth approximately USD 170 million were also made in new technologies and equipment, together with logistical and environmental improvements.

In 2002, Rovereto achieved a reduction of more than 50% in halogenated VOC emission by cryocondensation, a major first step towards an HSE performance that is inline with the highest environmental standards. During 2003, further progress was made through energy conservation and groundwater saving initiatives.

To reduce energy consumption, two new air compressors were fitted with heat recovery exchangers. The compression heat generated ( 2x360 kW) is now recovered and used to preheat the feed water for the plant's steam generators. This process has increased efficiency, reduced CO2 emission by approximately 800 tonnes per year, and provided a cost saving of around USD 90 000 per year.

Rovereto's reduction of approximately 40% in its groundwater consumption during 2003 is an equally important achievement. Cooling water at the plant was previously used only once, before being discharged into the River Adige. Thanks to the investment in new technology, a recycling system has been installed that allows the water to be reused for cooling condensers and solvent recovery processes. The new system has resulted in an overall saving in groundwater consumption of around 510 m3/ h, equal to the hourly water consumption of an Italian city of 50, 000 inhabitants.

Now Rovereto is looking to go further and formalize its commitment to environmental management by applying for ISO 14001 and OHSAS 18001 certification in 200421. Kurt Gstrein, Head of HSE, Sandoz is delighted with what has been achieved at the plant: " Rovereto's success shows how HSE management can combine with top level engineering at acquired sites to bring about exceptional improvements in HSE performance. It is an excellent model for the integration of new partners in the future".

Case Studies of the Petroleum Refining Industry Refinery Expansion Reference: Giesbrecht, Gary. Water Use in Industries of the Future: Petroleum Industry. CH2M Hill. Prepared for the U. S. Department of Energy's Office of Energy Efficiency and Renewable Energy ( under contract to the Center for Waste Reduction Technologies). July 2003.

A petroleum refinery, originally built in the 1950s, expanded overall capacity and modified its operations to accept a higher American Petroleum Institute ( API) gravity feedstock and reduce Page 46 of 49 the sulfur in gasoline and diesel fuel products. The planned expansion would result in an increase in the steam rate and cooling load, therefore the refinery modifications included a new water management plan with the following objectives:

Maintain pre expansion water withdrawal volumes ( i. e., no additional make up water);

Do not increase capacity of existing subsurface injection well; and

Be able to obtain wastewater discharge permit.

To minimize the use of river water and the amount of deepwell disposal, the refinery modified water management operations as follows:

Demineralize all boiler feedwater, via a reverse osmosis ( RO) system;

Re use the RO reject stream from boiler feedwater treatment as cooling tower makeup;

Use deepwell disposal for high TDS ( total dissolved solids) wastewater only;