March/April 1994
Miller Compressing Co. saw the handwriting on the wall and decided to turn its environmental obligations into meaningful investments. Here’s a look at the company’s comprehensive environmental control efforts.
By Joseph R. Kovacich
Joseph R. Kovacich is a vice president of Miller Compressing Co. (Milwaukee).
Scrap is our livelihood, but it’s not without its trouble. Turnings, for example, can be contaminated with cutting oils and lubricants laced with heavy metals, while automobiles present potential problems in the form of motor oil, antifreeze, brake and transmission fluid, and other toxic liquids. And other common types of scrap present similar challenges.
Since improper handling of such items can mean environmental damage and, consequently, potentially crippling financial exposure, the future of any scrap business could be decided by its ability to properly control potentially hazardous substances that may enter its facility.
At Miller Compressing Co., we’ve tried to stay ahead of environmental problems as well as future government regulations by taking a broad and critical look at the environmental implications of our operations and figuring out what kinds of operational changes and environmental controls can best minimize the threats. Though the cost of some of these controls--but certainly not all of them--is high, we see them as investments rather than obligations. Not only will our effort today limit our future exposure to environmental liability, but we see it as a way to give our suppliers confidence that selling scrap to us is the safest way for them to operate. After all, if a scrap plant is contaminated, cleanup requirements could apply not only to the processor, but also to scrap generators that did business with the plant, so suppliers are carefully watching where their materials go and how they are handled.
A Systematic Approach
Miller Compressing has been a leading Milwaukee industrial scrap and automobile recycling facility for more than 90 years, and we intend to keep the record going. Thus, with the assistance of technical consultants and guidance from the Institute of Scrap Recycling Industries (ISRI) (Washington, D.C.), we've instituted a series of companywide "best management practices"--a combination of techniques ranging from simple operational changes to sophisticated control systems--to minimize or eliminate environmental problems across all of our operations, from our 55-acre processing facility in the heart of Milwaukee's industrial Menomonee Valley to our two docks on Lake Michigan and a few small feeder facilities nearby.
Controlling storm water runoff is probably our single largest environmental concern since rainwater gives oil, small metal particles, and other pollutants present in outdoor storage and processing operations the ability to migrate. So, in anticipation of pending federal and state requirements, we recently made a move to aggressively manage our storm water runoff.
We had already begun to develop and implement various operational-based runoff control procedures, such as capturing runoff from our block-breaking operation and paying about $100,000 per year to dispose of it at a commercial wastewater treatment plant, but we decided we needed to take a broader look and design comprehensive controls for our processing facility as a whole. In order to do so, it was necessary to come up with a plan to monitor runoff from various operations and portions of the plant so individual sources of contamination could be identified and their effects studied. The idea was to identify cause-and-effect relationships, matching pollutant concentrations in runoff samples with particular recycling activities and/or scrap materials exposed to storm water. The ultimate goal was to determine which areas of the facility and/or which recycling processes required control/treatment to maintain the quality of storm water discharged. The following steps were taken.
Surveying the Plant. A series of site inspections were conducted by a team of Miller Compressing operations/management personnel plus technical consultants to evaluate possible storm water runoff concerns. The site inspections were designed to identify potential source areas, operational procedures, or other site activities that could influence storm water runoff quality, with particular attention paid to both our property tine discharge points and to discharge drainage areas within our facility. If we had any discharge problems, we figured we should begin by containing them within our facility.
Based on the site inspection, 13 potential source areas were identified:
- Shredder receiving area
- Shredded scrap storage area
- Auto shredder residue storage area
- Gas tank crushing/storage area
- Stainless steel turnings storage area
- Block-breaker operations area
- Block-breaker processed scrap storage area
- Baler area
- Shear area
- Baler/shear processed scrap storage area
- Nonferrous outdoor storage area
- Wire incinerator preparation area
- Railroad spur/lines
Developing a Monitoring Strategy. Next, we established sampling locations for each of these potential source areas. These spots were determined based on a need to acquire data as close as possible to a source area to avoid dilution from adjacent runoff and to identify which grades of scrap caused contamination, if any.
Samples were collected during what the consultants call a "runoff event”--a rainstorm. We then analyzed the samples for a number of contaminants addressed by our local sewerage district and Wisconsin pollution discharge permit parameters, plus other constituents determined likely to be liberated from the recycling operations.
Testing Our Controls. Our existing runoff controls were based on internal operations policies, guidance provided by ReMA in its environmental operating guidelines, and the best management practices listed in the association's group storm water permit application. Although we had confidence in these controls, there was a natural tendency to expect the worst. And, indeed, the results did show us some problems, but they weren't as bad as we had feared. There were solutions.
Of the 13 potential areas identified, five were targeted for various control measures. In some cases, this simply meant adopting new operating procedures, such as moving our nonferrous turnings operations indoors. But a few operations, including the shredder infeed area where automobiles are preprocessed and the ferrous turnings holding areas, were targeted for substantial new control systems.
Capturing Potential Pollutants From Automobile Processing
Automobiles delivered to our facility go through various initial processing steps before they are shredded. We had examined our automobile preprocessing facility very closely, knowing runoff from the area can involve many contaminants. And our storm water runoff samples detected oil constituents migrating from this suspected source area.
To deal with this issue, we designed and installed a comprehensive containment system for the shredder infeed area, based on three goals: contain and collect potential automobile fluid contaminants to prevent runoff water degradation, divert unaffected sheet runoff from around the processing area to minimize the volume of wastewater, and withstand the destructive activities associated with preprocessing automobiles without affecting the containment integrity of the system. What we came up with was simple, albeit ambitious-a shredder containment system with specifications like those currently required for hazardous waste facilities.
It has three main design elements:
A 12-inch thick (minimum) reinforced-concrete pad with an approximate working area of 100 by 200 feet was designed to withstand the heavy point loading typical of automobile preprocessing operations.
Reinforced concrete berms were built surrounding the working surface to divert runoff from around the outside of the area while containing automobile fluids and rainwater falling within the preprocessing area.
A concrete reservoir was installed adjacent to the containment area to store fluids and rainwater collected on the pad. The reservoir was designed to be big enough to contain more water than is expected in the "25-year, 24-hour design storm" falling on the pad--22,000 gallons.
The entire working surface of the pad is sloped toward the containment reservoir, and a double layer of high-density polyethylene (HDPE) liner protects against leakage of any fluid that may migrate through the concrete pad or reservoir. The critical part of this liner system is composed of a 40-mil (or 40/1,000 of an inch) primary layer overlying a drainage system of piping and a secondary 40-mil-thick HDPE liner. The two layers are about 1/4 inch apart, separated by a waffle mesh layer that allows fluid captured between the layers to drain. The drainage system slopes toward a series of sumps for system monitoring and fluid extraction.
A Pad for Turnings
Our company purchases a large volume of turnings from industrial facilities as well as other scrap dealers. Because of the cutting oils, lubricants, and coolants that are on most turnings--including those that have supposedly been spun dry-this material is carefully managed at our plant.
While many of our suppliers use sealed lugger and roll-off containers for scrap storage in an effort to contain potential pollutants on the turnings as part of their own storm water pollution prevention plans, some of the containers arriving at our facility have accumulated storm water. As a result, when the containers are dumped so the scrap can be processed or transferred into railcars, an emulsified oil/water mixture may be released, potentially affecting storm water runoff, underlying soil, and shallow groundwater. To handle these liquid pollutants and others that can migrate with rainwater from the turnings area, we constructed a containment pad and reservoir system, similar to that controlling our shredder infeed area, to capture contaminants from the turnings and the liquids in their containers while preventing unaffected storm water runoff from entering the control system.
The system includes a containment pad measuring just more than 7,000 square feet in size. The pad is constructed of 12inch-thick reinforced concrete and, like the shredder system, this area is underlain by two 40-mil-thick HDPE liners, with a mesh monitoring system sandwiched between the liners and four monitoring wells to ensure integrity. The perimeter of the pad area is bermed to prevent storm water runoff from entering the containment area from adjacent sectors of the plant and to contain waste fluids within the system.
It also features an adjacent collection reservoir, also constructed of 12-inch reinforced concrete and designed to hold 6,500 gallons of wastewater. This tank's integrity is maintained by a heavy-duty, 300-mil HDPE liner and a second 60-mil liner, which are separated by a waffle-like material and a monitoring system including two wells. The liquids collected on the pad flow into a sump, then through distribution pipe to the reservoir.
In addition to these two major new control systems, which are now in operation, we have installed a steel-lined pit to contain oily punchings and control the runoff. Furthermore, we are now in the process of designing a lined washing facility to collect the oily contaminants that may accumulate on our trucks, forklifts, and containers.
These control systems have also been accompanied by operational adjustments that take best advantage of them. For example, we now often hold engine blocks temporarily on the shredder or turnings pads, preventing any trouble from latent oils dripping from the scrap.
Disposing of Dirty Water
OK, now that we were corralling all this potentially polluted water, what would we do with it? To answer that question, we put a substantial amount of effort into comparing various wastewater treatment technologies available to the information we had collected about the contaminants in our storm water runoff. We decided on an integrated approach for collecting, treating, and disposing of wastewater collected from various parts of our facility, including water-soluble metal-working fluids from dumped containers of borings and turnings, process wastewater from scrap metal washing, and the storm water runoff collected from the containment pads. (The truck/container washing system will also add to the mix when it's completed.)
It begins with regularly transporting liquids collected to the central water treatment facility at our plant using a 2,300-gallon vacuum tank truck. The mixture of incoming fluids--which may include emulsified oil, cutting oils, water soluble coolants, heavy metals, and various suspended solids--is then separated in a comprehensive wastewater treatment/disposal process that has several stages:
- Consolidation, initial separation, and settling of wastewater in holding tanks.
- Phase-separated oil removal (belt skimming).
- Destruction of oil/water emulsification.
- Removal of emulsified oils, metals, and suspended solids.
- Clean water discharge to city combined sewer system.
Before building the full-scale system, we conducted a laboratory pilot test to determine its feasibility. Wastewater from discrete source areas was analyzed for sewerage district constituents before and after the pilot tests. Then, similar, additional testing was conducted to evaluate the performance of the full-scale treatment plant during the system-start-up phase. The results of full-scale testing are presented in the figure on the following page.
The system has the capability of processing 3,000 gallons per day of contaminated water. Once treated, the water is discharged into our municipal combined sewer system under a permit from the Wisconsin Department of Natural Resources (DNR), with the treated wastewater easily surpassing the influent quality limitations. Meanwhile, the oil with the other constituents separated from the water are sold to an oil recycler.
Clearing the Air
Though storm water runoff control is certainly a major issue for us and it's very much on the minds of other scrap recyclers today, it's certainly not the only environmental issue demanding immediate attention. Another major issue coming down the pike, and one we feel we've gotten a jump on, is air emissions rules, which will soon affect many more recyclers than ever before (see "A Clean Air Caution," on this page).
At Miller Compressing, many of our efforts in this area came about in the late 1980s, when we drew up plans to put in a new, larger shredding operations 6,000-horsepower (hp) system. When we approached the DNR about a permit for the new shredder, we got a bit of a surprise: The agency wanted our Permit to cover not just the new shredder, but all of our existing operations that involve air emissions.
The DNR had determined that under federal Clean Air Act rules, our plant could qualify as a "major source" of air pollutants if equipped only with minimal pollution controls. This presented a problem: If identified as a major source in an area like Milwaukee (which currently does not meet federal air-quality standards), the company would have to face a number of restrictions that would have compromised our future expansion and made increases in production almost impossible. For example, we would be forced to obtain air emissions offsets--air emissions credits from the surrounding industrial community--to more than equal the amount of emissions we had projected we would release with the new shredder given our proposed production schedule--potential annual emissions total of more than 200 tons.
We saw only one viable option--to really attack the problem and cut our potential emissions. And to protect ourselves into the future, we felt we had to go after air quality in the same comprehensive fashion we took on storm water runoff. In fact, we aimed beyond the initial demands of the DNR and our permit to prepare for the far-stricter controls that will kick in in 1995 under federal rules.
What we developed was a comprehensive clean air plan that included installation of several state-of-the-art air pollution control systems to address the six sources of air emissions in our main facility subject to regulations under Wisconsin Administrative Code-the new 6,000-hp damp shredder (which went into operation in May 1990), the older 4,000-hp shredder (now operated mainly as a backup unit), a wire-reclamation furnace, two rotary drum furnaces, and a hearth furnace.
The new shredder, for instance, was fitted with a high-efficiency venturi/cyclone filtration system capable of removing more than 90 percent of the airborne particulate matter from the shredder exhaust and a significant fraction of the entrained oils emitted as mist. Although this system was part of our initial shredder purchase, when the shredder was installed we decided to add an additional piece of air-emission-control equipments traveling bed filter system.
Each furnace inlet, meanwhile, was equipped with hoods to capture fugitive emissions and direct them to a cyclone/fabric filter system to remove entrained particulates, and each furnace outlet was fitted with an exhaust capture system that directed the captured gas streams to afterburners to combust organic vapors. In addition, a system was added to combine the effluent streams from all the furnaces following the afterburners. This stream is routed to an air-to-air heat exchanger and finally through an additional fabric filter.
Combined, these and other emission-control steps reduced our airborne emissions by more than 95 percent--not bad!
But we've gone a step further, implementing a comprehensive air emissions inventory and analysis program. We collect emissions samples from our smokestacks under numerous operating scenarios at each Process. These data are then used in conjunction with computerized atmospheric dispersion modeling to determine how we can optimize production while minimizing airborne emissions to the surrounding community. For example, in one extreme case, the data convinced us to simply stop processing a small quantity of a specific material because of the air emissions produced. In other cases, we might use the information to alter the way allowable emissions--which are set facilitywide under our permit-can be best allocated amongst our operating departments. (This latter scenario can require complicated permit alterations.)
The emissions-control program, now in its third year, has been a resounding success. We've been able to maintain a designation as a "synthetic minor source," rather than a major source. In fact, we now emit less than 20 tons per year of particulate and still have been able to maintain production at acceptable levels. Furthermore, not only are we well within regulatory standards, but we've also effectively given ourselves the breathing room necessary to boost production and expand.
Simple Best Management
In addition to our large-scale control projects such as the shredder and turnings pads and our clean air systems, we've instituted a variety of other basic operational controls that were much easier--and involved much less expense--but also provide environmental security. For example, we designed a simple motor block oil collection system that consists of two lugger boxes with drains cut in them set on top of a scaled container measuring approximately 12 by 20 by 2 feet. Motor blocks are placed in the lugger boxes, and oil from them collects in the large container below.
Other examples of simple controls we have instituted include an incinerator ash-water collection system that recycles water used to wash ash from burned wire, a battery storage/containment area consisting of a small roofed shelter with a leak-proof recessed floor to prevent environmental contamination in the event of spills or leaks, a separate capacitor storage/containment facility, and crane fueling overfill protection.
We have also implemented an extensive spill prevention control and countermeasure plan, codified in a concise, easy-to-use document. Among other things, it details controls necessary to prevent spills where petroleum products are stored in large quantities and describes procedures workers are to follow, including who they must contact, if a spill occurs.
Turning Obligations Into Investments
Recycling firms that have significant environmental impacts but that have not kept up with their environmental obligations may find themselves in a tough spot with respect to new compliance standards for storm water and air emissions: They may either have to spend a lot of money and effort on analysis and implementation of controls-the price of which may grow with the length of their delay--or they may have to limit production.
At Miller Compressing, we've invested heavily in environmental controls, spending more than $1 million on storm water runoff systems alone. But we consider this an investment as opposed to an expense because of its direct benefit: reduced risk, both to us and to our suppliers. And that's how we present it to our suppliers. They've picked up on it, too-they are vitally interested in what we have done and are doing environmentally because it reduces their downstream risk.
And because of the quality of this investment, we are confident enough to provide qualified industrial suppliers with a unique benefit: indemnification against liability and expense with respect to claims, demands, and judgments arising under Superfund according to the terms of a written agreement. Our suppliers might consider it a form of free insurance.
We consider it good business: They gain confidence, we secure future business, and we both have that much less to worry about when it comes to keeping up with environmental regulations.
A Clean Air Caution
Scrap recyclers may be in for a surprise if they are not yet planning for their application for an operation permit under federal Clean Air Act rules. By November 1995, many industrial facilities with any source of air emissions--even a bakery if it has a heating boiler and a smoke stack--will need to apply for a permit.
The real key to avoiding trouble is to not be considered a “major source,” which could put you in danger of serious operating limits, fines, or even shutdown. A substantial number of scrap recyclers, especially those operating shredders and furnaces, are at risk of being labeled “majors.” Plants located in federal air quality nonattainment zones--areas whose air quality fails to satisfy federal minimum standards for ozone and/or particulates--will be particularly hard-hit. (I’m told that if Miller Compressing qualified as a “major,” our permit application would be about a foot thick!)
Most recyclers will probably need at least six months to collect the data to prepare their permit applications--which makes May 1995 a key date. But the most important thing to do is to cut your emissions down as far as possible, and instituting controls like those we have requires building in even more time for study and implementation. Recyclers with air emissions, especially those in nonattainment zones, should be starting on this project yesterday. •
Miller Compressing Co. saw the handwriting on the wall and decided to turn its environmental obligations into meaningful investments. Here’s a look at the company’s comprehensive environmental control efforts.