Pollution Prevention in Fruit and Vegetable Food Processing Industries - Prepared by Washington State Department of Ecology Hazardous Waste and ...

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Pollution Prevention in Fruit and Vegetable Food Processing Industries - Prepared by Washington State Department of Ecology Hazardous Waste and ...
Pollution Prevention in
      Fruit and Vegetable
Food Processing Industries

                Prepared by
   Washington State Department of Ecology
Hazardous Waste and Toxics Reduction Program

                March 1994
             Publication #94-56
Pollution Prevention in Fruit and Vegetable Food Processing Industries - Prepared by Washington State Department of Ecology Hazardous Waste and ...
The Hazardous Waste and Toxics Reduction Program is responsible for the management and
reduction of hazardous waste and toxic substances in Washington State. We're available to
answer your questions. Contact your nearest regional office and ask for a Toxics Reduction
Specialist for information on reducing or recycling hazardous waste. And if you are uncertain
about your responsibilities as a hazardous waste generator, ask for a Hazardous Waste Specialist.

Eastern Regional Office                                           Central Regional Office
N. 4601 Monroe, Suite 202                                         106 S. Sixth Ave.
Spokane, WA 99205-1295                                            Yakima, WA 98902-3387

Southwest Regional Office                                         Northwest Regional Office
5751 Sixth Ave SE                                                 3190 160th Ave SE
P.O. Box 47775                                                    Bellevue, WA 98008
Olympia, WA 98504-47775

The Department of Ecology is an Equal Opportunity and Affirmative Action employer and shall not
discriminate on the basis of race, creed, color, national origin, sex, marital status, sexual orientation, age,
religion or disability as defined by applicable state and/or federal regulations or statues.

If you have special accommodation needs, please contact Dave Dubreuil at (206) 407-6721 (Voice) or (206)
407-6006 (TDD)

Pollution Prevention in Fruit and Vegetable Food Processing Industries
About the document

This document is not intended to be regulatory guidance. It will, however, address many of the
environmental regulations that affect the Fruit and Vegetable Food Processing Industry. Contact
the following Ecology Programs in your region to receive more information on the regulations:

       Air Quality

       Solid Waste Services

       Water Quality

       Hazardous Waste and Toxics Reduction

       Toxic Clean Up Program in your region.

The vendors, products and businesses presented in this document are offered as a public service
to the reader. This does. not represent an endorsement by the Department of Ecology. For each
particular application, alternative procedures and materials should be examined closely to
determine their usefulness and to examine any compliance implications with environmental
regulations.

                                    Pollution Prevention in Fruit and Vegetable Food Processing Industries
Table of Contents
Introduction .......................................................................................................1

Process Overview ..............................................................................................3

Why reduce waste ..............................................................................................5

Getting Started ..................................................................................................7

General Recommendations...............................................................................9

Hazardous Substances .....................................................................................11

Hazardous Wastes ............................................................................................15

Solid waste ........................................................................................................19

Water Quality and water Conservation.............................................................23

Energy Conservation ........................................................................................25

Environmental Regulations, Permits, and Plans ............................................29

Bibliography .......................................................................................................37

Appendix A ........................................................................................................39

Appendix B ........................................................................................................41

Pollution Prevention in Fruit and Vegetable Food Processing Industries
Introduction

Purpose of the plan

The purpose of this plan is to identify a "tool box" of usable ideas about cost incentives,
pollution prevention, and waste management techniques that are available to the Food
Processing Industry, Industry Group Number 203. The Plan will not only benefit the Food
Processing Industry, but also local governments responsible for moderate risk waste.

Need for the plan

Washington State legislatively mandated a goal of reducing the generation of hazardous waste
by 50% by 1995 and recycling 50% of the solid waste stream by 1995. To reach this goal,
Ecology is preparing industry-specific materials to help identify methods to reduce the amount
of waste generated. This guide is specifically for the Food Processing Industry.

Plan objectives

         •   Reduce hazardous substance use.
         •   Reduce hazardous waste generation.
         •   Reduce solid waste generation.
         •   Reduce use of other resources, including water.
         •   Reduce energy consumption.
         •   Educate clients in the concepts and methodology of pollution prevention.

Scope of the plan

This document was developed primarily for facilities using Standard Industrial Classification
codes 2033 and 2037. However, the Plan may have elements applicable to all of the SIC codes
listed below:

Industry Group Number 203:             Canned, Frozen and Preserved Fruits,
                                       Vegetables and Food Specialties

        2032 Canned Specialties
        2033 Canned Fruits, Vegetables, Jams, Preserves and Jellies
        2034 Dehydrated Fruits, Vegetables and Soups
        2035 Pickles, Sauces and Salad Dressings
        2038 Frozen Specialties (NEC)

To help scope the plan, an informal needs assessment was conducted. Ecology worked with
members of the food processing industry and their trade groups.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                          1
Number of Facilities

Estimated statewide Food Processing Facilities, SIC code 203:

    SIC Code PLANNERS      TOTAL CLIENTS            CRO ERO           SWRO NWRO

2032          0                  1                   0      1           0            0
2033          3                 27                  21      4           1            1
2034          1                  3                   3      0           0            0
2035          0                  1                   0      0           0            1
2037          9                 26                   6     10           4            6
2035          1                  1                   1      0           0            0
Totals        14                59                  31     15           5            8

Trade associations

Northwest Food Processors Association, Portland Oregon (503) 639-7676

2                                 Pollution Prevention in Fruit and Vegetable Food Processing Industries
Process Overview

The following list includes the fundamental processes for the food processing industry:

 ¾ Preliminary cleaning and preparation.

 ¾ Canning fruits, vegetables and juices.

 ¾ Processing and freezing fruits, vegetables and juices.

 ¾ Concentrating and freezing juices.

 ¾ Drying fruits and vegetables.

 ¾ Pasteurizing and sterilizing fruits, vegetables and juices.

 ¾ Irradiating fruits, vegetables and juices.

 ¾ Packaging.

 ¾ Shipping or storing.

These processes use several techniques common to manufacturing, and other techniques
developed exclusively for this industry. The processes used in the food processing industry are
oriented towards providing marketable fruit, vegetables and juices throughout the year, .both
nationally and internationally. Food processing has become even more important as growers
steadily increase their productivity, as routes of transportation and distribution mature and as
women continue to move into the workforce.

Common waste streams

Typical waste streams from this industry include large volumes of solid wastes and process
waste waters heavily laden with organic matter, dissolved solids, suspended solids and
biochemical oxygen demand. In addition to conventional waste streams, the industry also
generates waste streams from:

         ¿ cleaning                                     ¿ packaging

         ¿ sanitizing                                   ¿ printing

         ¿ equipment maintenance                        ¿ laboratory analysis

Pollution Prevention in Fruit and Vegetable Food Processing Industries                         3
Dangerous Waste Designation

The processing chemicals used in this industry do not typically designate as dangerous waste in
the dilute forms they are used. Exceptions to this are addressed in this document under
"Hazardous Substances" and "Hazardous Wastes"If the chemicals are discarded in a concentrated
form, many of them designate as dangerous wasteIt is important to note that diluting wastes to
change the designation from dangerous waste to non-dangerous waste is not allowed.
    Please contact an Ecology toxics reduction specialist or hazardous waste specialist in
your region to assist with identifying appropriate disposal options.

SARA Title III

Hazardous substances and chemicals used in atmospheric control (refrigeration),
maintenance of the process equipment, cleaning, disinfection and sanitization, and treatment
of waste waters are often found in section 313 SARA Title III list, as are other Community
Right-to-Know chemicals.

Pollution Prevention Opportunities

Historically, resources have been used on a once-through basis and sent off for treatment or
disposal. The cost of chemicals, energy, water and disposal are significant. There appear to be a
number of cost-effective reduction and recycling opportunities in this industry. They include the
following:

    ¿ reducing use of acids and bases for      ¿ upgrade existing refrigeration sytems
      Clean In Place (CIP) systems,              (ammonia),
    ¿ pretreating and/or using different       ¿ replacing existing refrigeration
      chlorine compounds or ozone substi-        systems with new more advanced
      tution for disinfection,                   systems,
    ¿ pre-washing prior to chemical            ¿ ink and solvent substitution for
      treatments,                                printing processes,
    ¿ substituting with new cleaning           ¿ maintenance shop waste reduction
      technologies (NaHCO3)                      opportunities,
    ¿ recycling "non-contact" and waste        ¿ energy savings, and
      waters,
    ¿ using waste exchanges for food           ¿ reduction of environmental fee costs,
      starch and sugar by-product                (i.e. wastewater discharge permitting
      marketing,                                 fees).

4                                  Pollution Prevention in Fruit and Vegetable Food Processing Industries
Why reduce waste?

Increased Profits

Waste reduction improves efficiency, reduces raw materials costs, lowers disposal costs and
reduces insurance liabilities.

Lower Disposal Costs

The most immediate benefit of waste reduction is lower disposal costs. These can be signi-
ficantly reduced when less solid waste is discarded to the dumpster and less hazardous waste,
requiring proper management and disposal, is generated.

Lower Water and Wastewater Treatment

Costs associated with water usage and wastewater treatment or disposal continue to increase,
so water conservation and recycling will save money.

Reduced Liability

Hazardous waste generators are responsible for properly managing their waste. Appropriate
waste management practices can result in lower insurance premiums. Some regulatory
requirements can also be minimized when regulated wastes are reduced.

Public Relations

Environmental protection through waste reduction is a positive program to set in motion.
Waste reduction and recycling programs project a positive image to employees and the
community, and can be used as a marketing tool.

Employee Safety

Waste reduction reduces employee and community exposure to industrial waste, both during the
use of the substance and when managing the waste. Therefore, the health and safety of
employees is improved through waste reduction.

Property Value

Inappropriate management or disposal of wastes can result in site contamination, decreased
property value and the inability to secure loans.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                          5
Notes

6       Pollution Prevention in Fruit and Vegetable Food Processing Industries
Getting Started

Get a Commitment from Management

Start at the top. A successful waste reduction/recycling program begins when the administration
and management make a commitment to the program. A corporate commitment gives priority
and authority for a pollution prevention program. If there is not visible support from
management, employees will have little incentive to look for waste reduction opportunities.

Find a "Champion" to Head up the Program

The person in charge should be committed to waste reduction and recycling. Select a person with
enthusiasm, creativity, and the ability to coordinate details. Give this person the authority
necessary to implement the program.

Form a Team

Include on your team people from purchasing, environmental management, and someone
familiar with the processes that use or generate hazardous substances and/or hazardous
wastes.

Set Waste Minimization Goals

It is important to choose goals that are realistic and achievable. Develop a plan that is
meaningful for your facility. Develop cost-effective solutions. Employee incentive
programs, such as awards for cost saving, raw material and waste reduction ideas, can help
foster awareness of policies, goals and benefits.

Conduct Annual Waste Audits

Survey the materials entering your waste stream. Determine which materials can be recycled,
reduced, or eliminated from the waste stream. Determine the source of these materials. Assign
the costs associated with waste management to the specific processes that generate the waste.
Conduct cost accounting for all waste streams. Encourage those who are generating these wastes
to participate in finding a waste reduction solution. For more information about conducting waste
audits, contact an Ecology Toxics Reduction Specialist in your region.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                        7
Work with Other Businesses in Your Industry

Research, identify and promote solutions collectively with other businesses in your association.
There is often power and safety in numbers. Waste recycling opportunities and markets are often
more accessible and economical to larger groups.

Dedicate Adequate Financial and Technical Resources

A waste reduction program can save money in the long run through lower disposal costs and
savings in raw materials purchases. However, a good program needs the commitment of some
resources to get started.

Communicate

The progress, goals and rationale of the program should be shared with employees at all levels.
Education will be necessary to teach employees the "new" methods of materials ordering,
handling and disposal.

8                                  Pollution Prevention in Fruit and Vegetable Food Processing Industries
General Recommendations

1.      Determine your hazardous waste generator status. How much hazardous waste do
        you generate each month or batch? Are you a regulated generator or a conditionally
        exempt small quantity generator?

        If you are uncertain about your status or responsibilities as a hazardous waste generator,
        call your nearest Ecology regional office and ask for a Hazardous Waste Specialist. For
        information on reducing or recycling hazardous waste, ask for a Toxics Reduction
        Specialist. See the introduction section of this document for regional office numbers and
        locations.

2.      Determine your status under the Toxic Release Inventory reporting under SARA Title
        III, Section 313 (Form R).

3.      Clearly identify and properly label all chemicals and waste containers. Keep containers
        closed, except when adding to or removing the contents.

4.      Isolate liquid wastes from solid wastes. Never mix different types of waste together.
        Mixing wastes may make recycling impossible, or make waste disposal much more
        expensive. If non-hazardous waste becomes contaminated with a hazardous waste, it
        may need to be disposed of as a hazardous waste. Often times, wastes can be re-
        cycled only if they have been kept segregated.

5.     Minimize the amount of each waste being generated at its source by identifying
       where hazardous materials are used and determining the best source reduction
       method. Substitute less hazardous or non-hazardous substances for hazardous
       substances whenever possible.

6.     Recycle all wastes where practical. Identify the source of all recyclable materials, then
       provide conveniently located containers for these recyclables.

7.     Tighten inventory control. Inventory all substances. Rotate stock to reduce chances of
       outdated material. Avoid over-purchasing by instituting "just-in-time" purchasing. The
       benefits include: less waste, more efficient supply procedures and ready access to stored
       goods.

8.     Provide employee training in hazardous materials management and waste minimization.
       This will reduce the likelihood of excess waste being generated and increase employee
       safety.

9.     Implement a facility-wide waste reduction program. Form a waste reduction team to
       conduct annual waste audits.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                             9
10.   Properly dispose of obsolete and surplus stock. Investigate waste exchanges or
      selling surplus goods and wastes.

11.   Apportion waste management costs to the departments that generate the wastes.
      Allow disposal savings from the waste reduction/recycling programs to be used to
      support the waste reduction/recycling effort.

12.   Reduction methods should be prioritized in the following order:

      a. hazardous materials or hazardous waste reduction,

      b. waste recycling, and

      c. waste treatment. This should be considered only after reduction and recycling are
         found to be inappropriate.

10                                Pollution Prevention in Fruit and Vegetable Food Processing Industries
Hazardous Substances

The most common processes that use hazardous substances in the Food Processing Industry
include:

♦        Process water treatment: Disinfection and water softeners.

♦        Wastewater treatment in aerated lagoons: Disinfection and ammonia.

♦        Non-contact cooling waters (cooling towers): Biocides.

♦        Processing equipment maintenance: Solvents, oils, caustics, acids and disinfectants.

♦        Refrigeration cooling systems: Freon, ammonia and glycols.

Reduction opportunities for the following hazardous substances include:

♦        Chlorine (Gas)

The following discussion will focus on chlorine gas used to treat and disinfect preliminary
process waters, cooling water (i.e. can cooling), wastewaters and cleaning waters for process
equipment and facility floors.

        Reduction Opportunities

        ¾ Convert from gas to hypochlorite solution.

        ¾ Measure water in-flow and out-flow from each process to control water usage and the
          amount of chlorine used.

        ¾ Use automated valving and mixing to control use of chlorine.

        ¾ Use counter current rinsing techniques to reduce wastewater.

        ¾ Use ozone and ultraviolet technologies as substitutes for chlorine wherever
          practical and economically feasible.

        ¾ Recycle waters if possible to reduce treatment of wastewater with chlorine.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                          11
♦      Acids and Caustics

The following discussion will focus on acids and caustics used for internal cleaning of tanks,
piping, boilers and Clean In Place systems.

       Reduction Opportunities

      ¾ Use a three-tank, five cycle Clean In Place system to allow reuse of acids and
        caustic substances.
      ¾ Use softened water in Clean In Place systems to eliminate the amount of mineral
        scale after rinsing.
      ¾ Reduce the amount of acid used during Clean In Place cycles by raising the pH of
        the make-up tank.
      ¾ Use reliable automated control systems to properly measure and prevent overuse of
        Clean In Place substances.
      ¾ Evaluate the possibility of substituting citric acid for nitric, sulfuric and phospheric
        acids used in scale removal in Clean In Place systems.
      ¾ Use soft water in boiler systems to reduce the amount of scale in piping. This
        reduces the amount of caustic needed for cleaning, and decreases the amount of
        acids needed for neutralization.
      ¾ Use physical or automated devices instead of caustic cleaning.
♦      Ammonia, Chlorofluorocarbons (CFC's), and Ethylene Glycol used as
       Refrigerants

       Reduction Opportunities

      ¾ Keep cooling systems maintained properly to avoid emissions. Keep the nuts and
        bolts tightened.
      ¾ Minimize releases when performing maintenance on ammonia systems, as well as
        freon systems.
      ¾ Recycle CFC's properly.
      ¾ Recycle the ethylene glycol used in refrigeration systems.
      ¾ Convert glycol systems to propylene glycol systems.

12                                  Pollution Prevention in Fruit and Vegetable Food Processing Industries
¾ New systems should be free of chlorofluorocarbons.

♦       Amonia used as Fertilizers in Wastewater Treatment

        Reduction Opportunities

      ¾ Reduce effluent by recycling as much process, cleaning and rinse water as
        possible. This will reduce the amount of water that needs to be treated in aerated
        lagoons, and also will decrease the amount of ammonia fertilizer needed to
        maintain the treatment system. There are many variables to consider, such as
        biological oxygen demand, dissolved and suspended solids, pH and the economic
        costs associated with filtration and recycling systems.
      ¾ Reduce the pollutant loading on effluent water significantly by incorporating dry
        cleaning methods like compressed air, vacuum systems, shop vacuums and brooms.
      ¾ Determine the minimum nutrient addition rate that will allow the treatment system
        to function within normal limits.

       Biological oxygen demand, suspended solids and solid wastes vary considerably from one
       product to another, so different options or combinations could apply to a particular waste
       stream.

♦        Biocides and Corrosion Inhibitors used for Cooling Water Treatment,
         Cooling Towers

        Reduction Opportunities

        ¿ Use automatic bleed/feed systems to more efficiently use biocidal chemicals.
        ¿ Substitute a biodegradable compound for the commonly used toxic biocides.
        ¿ Substitute less toxic inhibitors for hexavalent chromium.

♦        Solvents used for Lubrication and De-sticking Agents, generally as
         Aerosol Sprays

        Reduction Opportunities

       Use non-chlorinated substitutes for cleaning, lubricants and de-sticking agents. See
       Hazardous Waste Section below.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                        13
Notes

14      Pollution Prevention in Fruit and Vegetable Food Processing Industries
Hazardous Wastes

The most common processes generating hazardous waste at food processing facilities in-
clude:

♦        Maintenance Shop: Waste solvent from parts baths, waste oil, antifreeze, batteries
         and shop rags;

♦        Refrigeration: Waste antifreeze and freon from cooling systems;

♦        Printing: Waste inks, solvents and shop rags from presses;

♦        Grounds Keeping:
         • paint wastes including sand blasting and sanding wastes, waste paint,
            contaminated tape and paper;
         • pesticide waste containers, unused or leftover pesticides, rinsates and pesticide
            spills;

♦        Laboratory: waste acids, metals from chemical oxygen demand and solvents;

♦        Printer Cartridges.

The following discussion focuses on reduction and recycling opportunities for the above
waste streams.

♦        Solvents used in Parts Baths and General Process Equipment Cleaning

        Reduction Opportunities

        ¿ Replace parts-bath solvents with non-hazardous substitutes.
        ¿ Use a filtrating parts bath to extend the life of the solvents. Filters may be
          hazardous wastes. If the solvent is used only for removing greases and oils from
          parts and a non-hazardous solvent is being used, the filters should not designate as
          hazardous.
        ¿ Substitute hazardous cleaning agents with less hazardous alternatives.
        ¿ Substitute aqueous-based solvents for petroleum solvents.
        ¿ Substitute non-halogenated solvents for halogenated solvents.
        ¿ Use steam cleaning instead of solvent-based cleaning.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                           15
Recycling Opportunities

      ¿ Segregate the solvents from other waste so the solvents can be recycled.

      ¿ Use a vendor service which provides recyclable solvent substitutes.

      ¿ Use on-site or off-site distillation for recovering solvents.

♦     Oils, Antifreeze, Batteries and Shop Rags used in Maintenance Shops

      Reduction Opportunities

     ¿ Use cloth rags which, when contaminated with oils, greases and solvents, are
       exempt from the Dangerous Waste Regulations if they are sent to a legitimate
       laundry for cleaning. Remember, paper towels need to be managed and
       disposed of according to the Dangerous Waste Regulations if they contain
       any hazardous substances.

     Recycling Opportunities

     ¿ Used motor oil, generated at your own facility, is exempt from the Dangerous
       Waste Regulations if it is segregated from other waste streams and recycled.

     ¿ All lead acid batteries are recyclable through your battery supplier or an
       authorized recycler. Lead acid batteries are exempt from the Dangerous
       Waste Regulations if they are recycled.

     ¿ Use on-site or off-site recycling options for spent antifreeze.

♦ Inks, Solvents and Shop Rags used in Printing Operations

      Reduction Opportunities

     ¿ Use non-hazardous substitutes for inks and solvents, such as water-based inks
       for paper and cardboard labeling and glycol ethers as cleaning solvents.

     ¿ Use cloth shop rags in place of paper towels. Dirty cloth shop rags are
       exempt from the Dangerous Waste Regulations if laundered at a legitimate
       commercial laundry.

     Recycling Opportunities

     Use on-site or off-site distillation for solvents.

16                                 Pollution Prevention in Fruit and Vegetable Food Processing Industries
♦       Facility Lighting

        Reduction Opportunities

        Replace all capacitors and ballasts containing PCB. Contact Ecology's Hazardous
        Waste and Toxics Reduction Program in your region to help you identify appropriate
        disposal options.

♦       Painting used for Grounds Maintenance

        Reduction Opportunities

        ¿ Use non-hazardous, water-based paints.

        ¿ Use leftover paint for areas where the color is not critical.

        ¿ Find people who can use the leftover paint.

        ¿ Purchase only the amount needed to do the job.

        ¿ Completely empty all paint cans containing paints with hazardous substances
          before discarding.

♦        Pesticides Used for Grounds Maintenance

        Reduction Opportunities

        ¿ Purchase and use only the amount needed for the job. A Provide adequate storage
          to avoid damaging the products.
        ¿ Use the oldest material first from inventory.
        ¿ Find a legitimate user for the excess product for its intended purpose.
        ¿ Minimize change-overs from one spray solution to another.
        ¿ Dedicate equipment to compatible spray activities. This will reduce equipment
             cleaning.
        ¿ Use rinsates from tanks and containers as make-up for the next batch or on the target.
          Follow the labeling requirements.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                       17
¿ When liquid containers are triple rinsed and fiber containers are completely emptied,
       they are considered empty and a solid waste. Empty the fiber containers by
       thoroughly shaking and rinsing them.

     ¿ Manage banned or damaged pesticides appropriately by disposing of them at a
       permitted treatment, storage or disposal facility, or through a Washington State
       Department of Agriculture/county-sponsored collection event for waste pesticides.

♦     Corrosives, Solvents and Metals used in Laboratory Analysis

      Reduction Opportunities

     ¿ Use premixed, containerized kits for testing.

     ¿ Use analytical equipment, such as on-line chemical oxygen demand analyzers, to
       reduce hazardous substance use and to minimize the generation of hazardous waste.

♦    Decrease the volume of samples to reduce hazardous substances used in testing.

     Recycling Opportunities

     ¿       Recycle mercury or silver wastes from chemical oxygen demand analysis, if
             possible.
     ¿       Use on-site or off-site distillation of solvents.

♦     Laser Printer Cartridges

     Laser printer cartridges may designate as a dangerous waste when spent.

     Reduction Opportunity

     Recharge spent printer cartridges so they can be reused instead of throwing them out.

18                                Pollution Prevention in Fruit and Vegetable Food Processing Industries
Solid waste
General Reduction Opportunities

        Reduction Opportunities

        ¿ Eliminate disposable products wherever possible.
        ¿ Use ceramic coffee mugs to eliminate disposable cups.
        ¿ Return or reuse wooden pallets.
        ¿ Donate used or discarded goods and equipment to charitable organizations.
        ¿ Ensure that containers are completely emptied and sent off for recycling or proper
          disposal. Empty drums and containers in facility bone yards have caused many
          public complaints.

        Recycling Opportunities

        ¿ Recycling markets vary in each community. Find out what recycling services are
          available before starting your program.
        ¿ Paper, cardboard, aluminum cans, glass, metals and plastics can all be recycled.
        ¿ Coordinate group recycling events when possible.
        ¿ Call 1-800-RECYCLE or your county solid waste department for assistance.

♦        Sludge from Wastewater Treatment

The following discussion focuses on sludge, determined by the facility to be non-dangerous
waste.

        Reduction Opportunities

        ¿ Use field cleaning to reduce the amount of cleaning required at the plant and to
          reduce the amount of sludge generated.
        ¿ Use cleanable filter media in place of disposable filters for process waters and
          filtration systems.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                         19
¿ Use screens, hydro sieves, filtration and other efficient systems to recover solids.
       ¿ Compost on-site, if possible.

      Non-hazardous sludges can be used as animal feed supplements, or used as a
      composting component by some county solid waste programs. Contact the nearest
      Ecology regional office or your local health department for more information.

♦      Office Paper

The following discussion focuses on paper wastes generated in facility offices.

      Reduction Opportunities

       ¿ Reduce the use of paper by making double-sided copies.
       ¿ Reuse paper with a free side (single sided) for draft copies.
       ¿ Circulate information rather than making several copies.
       ¿ Use electronic mail messages.
       ¿ Reuse envelopes, boxes and file folders.
       ¿ Centralize files.

       ¿ Store documents on floppy disk rather than making paper copies.

        Recycling Opportunities

       ¿ White office paper is readily recyclable in most communities. It must be kept
         separate from other paper waste.

       ¿ Colored paper is not as easily recycled, therefore its use should be limited.

       ¿ Provide individual containers for collection of newsprint, white, colored and
         computer paper at convenient locations.

       ¿ Support recycling efforts by using recycled paper products.

20                                 Pollution Prevention in Fruit and Vegetable Food Processing Industries
♦       Cardboard

        Reduction Opportunities

        ¿ Request that deliveries be shipped in returnable containers and reuse boxes for
          shipping goods.

        Recycling Opportunities

        ¿ Most corrugated cardboard can be recycled. Contact your local recycler for
          details. There can be substantial savings in garbage fees when the cardboard is
          removed from the waste stream.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                      21
Notes

22      Pollution Prevention in Fruit and Vegetable Food Processing Industries
Water Quality and Water Conservation

Water is used in the following processes: cleaning equipment, washing fruits and vegetables,
conveyance, cooling, peeling, blanching, pasteurization and boiler feed. For information on
how to properly dispose of wastewater, call Ecology's regional Water Quality Program for
assistance.

♦       Wastewater

The following discussion focuses on wastewater generated from process and cleaning waters.

        Reduction and Recycling Opportunities

        ¿ Set water conservation goals.
        ¿ Make water conservation a management priority.
        ¿ Install water meters and monitor water use.
        ¿ Train employees how to use water efficiently.
        ¿ Use automatic shut-off nozzles on all water hoses.
        ¿ Use high-pressure, low-volume spray washes during clean-up to conserve water.
        ¿ Use automatic valves on spraybars to shut off water flow when equipment is not
          running.
        ¿ Eliminate once-through cooling water usage by recycling or reusing whenever
          possible.
        ¿ Minimize spilling ingredients and product on floors; always clean up the spills before
          washing.
        ¿ Don't let water run continuously unless necessary.
        ¿ Use dry (waterless) cleaning methods prior to water clean-up. Don't let people use
          water as a broom.
        ¿ Survey systems for leaks and repair. Heat exchangers and other "non-contact"
          water systems, in particular, need to be inspected routinely. Conductivity or pH
          monitors on cooling lines can positively detect leaks.
        ¿ Use automatic controls to keep cooling waters in correct temperature range.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                         23
¿ Install lock out valves for proper process water flow levels.
     ¿ Segregate wastewater streams according to level and type of contamination, and
       investigate the potential for recovery.
     ¿ Keep storm waters out of wastewater. Manage storm waters separately.
     ¿ Recover starch from wastewaters. It is possible to reduce half of the suspended
       materials in the water and reduce the consumption of clean water.
     ¿ Use mechanical peeling to reduce water usage, chemical pollution and energy
       consumption.
     ¿ Use dedicated process or mixing lines for certain products to reduce change over
       clean-ups.
     ¿ Reuse process waters to clean equipment when technically and regulatorily feasible.
     ¿ Filter process and cleaning water to remove particulates; reuse the water.
        •   screening
        •   hydro sieves
        •   membrane filtration: micro-filtration, ultrafiltration, reverse osmosis.

     ¿ Use compressed air to clean equipment or parts when appropriate.
     ¿ Install multiple rinse tanks in a counter-current series system to reduce waste-
       water.
     ¿ Clean with steam to reduce the volume of water used for cleaning.
     ¿ Reuse process water to the maximum extent possible.
     ¿ Reuse compressor cooling water.
     ¿ Reuse water-cooled condenser water as process or clean-up water.
     ¿ Use a cooling tower or reuse cooling water to conserve water.
     ¿ Use water extracted from juice as boiler make-up, when possible.
     ¿ Use a dry extraction process, if applicable.
     ¿ Use warm process water as defrost water.
     ¿ Use process waters to wash trucks.

24                               Pollution Prevention in Fruit and Vegetable Food Processing Industries
Energy Conservation

Energy is used in specific process equipment and general equipment in the food processing
industry. Water conservation compliments energy conservation in many of these processes.
The following is a list of processes or areas where the food processing industry can conserve
energy:

™ General Ancillary Equipment such as: refrigeration, heat recovery, insulation, pumps,
  compressed air, high efficiency motors, variable speed drives, power factor (harness-
  ing energy from processes for reuse to reduce overall energy consumption) and
  lighting.

™ Specific Process Equipment such as pasteurizers, evaporators, peelers, blanchers/ cookers,
  fryers, dryers, ovens and conveyors.

♦        Energy Conservation Opportunities

         Frozen Food Processes – refrigeration

        ¿ Reduce condensing pressures.

        ¿ Increase suction pressures.

        ¿ Use effective evaporator fan cycling.

        ¿ Reduce defrost time.

        ¿ Use thermosyphon oil cooling.

        ¿ Purge non-condensibles.

        ¿ Properly sequence compressors.

        ¿ Properly maintain cooling towers.

        ¿ Preheat clean-up water with hot refrigerant gas.

        ¿ Resequence compressors.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                     25
Steam and heat generating processes – boilers

     ¿ Preheat dryer make-up air using dryer exhaust heat.

     ¿ Preheat boiler combustion air using boiler exhaust.

     ¿ Preheat dryer/roaster product using exhaust.

     ¿ Preheat boiler make-up water using boiler exhaust.

     ¿ Preheat process water using oven exhaust.

     ¿ Preheat blancher or cooker make-up with overflow water.

     ¿ Preheat boiler make-up water using continuous blowdown.

     ¿ Perform regular maintenance on boilers (i.e. tuning).

     ¿ Preheat boiler combustion air.

     ¿ Preheat boiler make-up water.

     ¿ Recover boiler stack heat.

     ¿ Minimize boiler blowdown.

     ¿ Recover heat from boiler blowdown.

     ¿ Use softened water to reduce boiler scaling and deposits.

     ¿ Reuse blancher, cooker or cooler make-up water as peeler rinse water.

     ¿ Insulate piping and equipment to conserve energy.

     ¿ Recirculate steam-mixed sterilizer water.

     ¿ Reuse process water after removing feed and commercial starch.

     ¿ Use pasteurizer cooling water as boiler make-up water.

     ¿ Use condensate from steam blanchers as pre-wash water to preheat product.

     ¿ Recompress vented steam for reuse in the process.

     ¿ Switch from steam to air atomization.

26                              Pollution Prevention in Fruit and Vegetable Food Processing Industries
¿ Perform periodic pump inspections.

        ¿ Control constant flow by methods other than throttling, such as utilizing flow
          equalization, reducing impeller diameter and reducing pump speed.

        ¿ Install air leak test devices on compressors.

        ¿ Fix compressed air leaks.

        ¿ Install no-load controls.

        ¿ Add vortex blow-off nozzles.

        ¿ Use dry fire systems.

        ¿ Use blowers rather than compressed air to dry conveyor belts and other equip-
          ment.

        ¿ Use heat recovery from cooling water.

        Electricity dependent equipment - motors, lights, etc.

        ¿ Replace working motors with high-efficiency equipment on a group basis.

        ¿ Specify high efficiency motors for burn out replacements.

        ¿ Specify high efficiency motors rather than rewinding.

        ¿ Replace oversized motors with properly sized high efficiency motors.

        ¿ Correct motor part load performance with individual capacitors located at the
          motors or motor control centers for better cost/performance ratios.

        ¿ Use variable speed motors in boiler induced and forced draft fans, condenser fans,
          compressor cooling water pumps and well pumps.

        ¿ Use low energy fluorescent lighting.

ELECTRIC IDEAS

Pollution Prevention in Fruit and Vegetable Food Processing Industries                         27
Notes

28      Pollution Prevention in Fruit and Vegetable Food Processing Industries
Environmental Regulations, Permits, and Plans

Along with many Food and Drug Administration (FDA) regulations and Occupational Health
and Safety Administration (OSHA) regulations, the Food Processing Industry must comply with
any number of the following environmental permits, plans, or requirements. The telephone
numbers for these and other agencies are listed in Appendix B of this publication.

♦       Water Resources

        Water Right Permit

        A water right permit is required for withdrawal of water from surface and ground
        sources for any reason other than domestic use. The domestic exclusion applies to
        industrial and domestic use of less than 5000 gallons per day, and outside irrigation
        limited to less than one-half acre for lawn and garden use. A water right application is
        required. Public notice is required for water right applications. Changes of water
        rights must also be reviewed and approved.

        Contact: Ecology's regional Water Resources Program.

        Public Water Supply Approval

        New public drinking water systems and alterations or additions to existing systems
        require approval for planning, preliminary design, final plans and specifications, and
        as-built drawings (showing the structure after completion).

        Contact: Washington State Department of Health or local Health District.

♦       Water Quality

♦       State Waste Discharge Permit (individual or general)

        This permit is required for industrial, commercial or municipal wastewater discharges of
        any volume into the state's ground waters or for industrial or commercial wastewater
        discharge into a municipal sewer system. A permit application is required.

          Contact: Ecology's regional Water Quality Program.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                           29
National Pollutant Discharge Elimination System (NPDES) Permit (individual
    or general)

    This permit is required for point source wastewater discharges of any volume into the
    state's surface waters. A permit application is required and takes from 180 days to
    one year to process. A public hearing may be required.

    Contact: Ecology's regional Water Quality Program

    On-Site Sewage Disposal Permit (applies to septic systems for domestic sewage only)

    Businesses that require on-site sewage systems will need permits from the appropriate
    agency for the following design flows:

¿        If less than 3,500 gallons per day the local health departments/districts issue permit.
¿        If 3,500 to 14,500 gallons per day the State Health Department issues the permit but
         can be contracted to local health.
¿        When over 14,500 gallons per day for on-site systems and over 3,500 gallons per
         day for mechanical treatment or lagoon systems, Ecology issues State or NPDES
         permits.
    Contacts: local Health Department,
              Washington State Department of Health, or
              Ecology's Water Quality Program.

    Storm Water Permit

    Facilities which have areas where material handling equipment or activites, raw
    materials, intermediate products, final products, waste materials, by-products, or
    industrial machinery are exposed to storm water, and which discharge either directly
    or indirectly to surface water through a municipal or private storm sewer, must apply
    for coverage under the baseline general permit, or submit an application for an
    individual permit. Facilities which have conditions addressing management or
    treatment requirements for all of their industrial storm water in an existing NPDES
    permit should not apply for coverage under the general baseline permit. For existing
    facilities operating on or before November 18, 1992, a notice of intent should have
    been filed as of February 18, 1993.

    Contacts: Ecology's regional Water Quality Program; or
              Environmental Protection Agency, Region 10

    30                                    Pollution Prevention in Fruit and Vegetable Food Processing Industries
Storm Water Pollution Prevention Plan

A storm water pollution prevention plan is required to be developed by permitted
facilities. The storm water pollution prevention plan is to be retained on-site for
inspection by Ecology, and must include:

¿ an assessment and description of existing and potential pollutant sources,
¿ a description of the storm water management controls selected for the facility, and
¿ an implementation schedule for Best Management Practices.

At facilities in operation as of November 18, 1992, the deadline for developing a plan
was November 18, 1993. The deadline for implementation of the plan at existing
facilities is November 18, 1994 for non-capital expense and November, 1995 for
those requiring capital expenditures.

Contacts: Ecology's Headquarters Water Quality Program, or the
          Environmental Protection Agency, Region 10.

Spill Prevention Plan

Under a state or National Pollution Discharge Elimination System discharge permit, a
facility is required to prepare and submit a spill plan to Ecology. The plan shall
include all information provided in the facility's discharge permit.

Contacts: Ecology's regional office Water Quality Program.

Spill Prevention Control and Countermeasure Plan (SPCC)

Applies to facilities engaged in drilling, producing, gathering, storing, processing,
refining, transferring or consuming oil and oil products with an above ground storage
capacity of a single container in excess of 660 gallons, or aggregated above ground
storage capacity of 1,320 gallons, or total below ground storage of 42,000 gallons.

Contacts: Environmental Protection Agency, Region 10

Pollution Prevention in Fruit and Vegetable Food Processing Industries                   31
Environmental Compliance Plan (ECP)

  If a facility is issued either a National Pollutant Discharge Elimination System
  (NPDES) or State Waste Discharge Permit, an Environmental Compliance Plan
  (ECP) must be developed by the facility. The original must be submitted to Ecology
  and a copy must be retained on-site. Any ECP must include information about
  Treatment/Disposal Operations Method (TDOM), Solid Waste Management Method
  (SWMM), Spill Prevention Method (SPM), and Storm Water Pollution Prevention
  Method (SWPPM). The deadline for development and implementation of the plan is
  July 31, 1996 for existing facilities, and no later than one year after commencement
  of any process discharge for new facilities.

  Contact: Ecology's regional Water Quality Program.

♦ Air Quality

  Notice of Construction

  A notice of construction is required for new source construction and/or modifications
  to existing sources releasing contaminants into the ambient air.

  Contacts: local Air Authority or
             Ecology's regional Air Program

  Air Quality Permit

  An air quality permit is required for open burning of any kind.

  Contacts: local Air Authority or
             Ecology's regional Air Program.

  Air Contaminant Source Registration

  Major air contaminant sources in Washington State must be registered. As sources and limits
  change, the food processing industry may be required to register contaminant sources.

  Contacts: local Air Authority or
             Ecology's regional Air Program.

  32                                 Pollution Prevention in Fruit and Vegetable Food Processing Industries
♦ Hazardous / Dangerous Waste

   Notification of Spills or Discharges to the Environment

  The following applies to any person responsible for any spill or discharge of a hazard-
  ous substance or dangerous waste into the environment except when such a release is
  otherwise permitted under state or federal law. For spills or discharges onto the
  ground or into groundwater or surface water, notify all local authorities in accordance
  with the local emergency plan. For spills or discharges which result in emissions to
  the air, notify all local authorities in accordance with the local emergency plan. Also,
  notify the appropriate regional office of the Department of Ecology.

  Contact: Ecology's regional Hazardous Waste and Toxics Reduction Program.

  Notification - Dangerous Waste Designation, Generator and/or Transporter,
  Identification Number/Reporting

  A person who generates a solid waste is responsible for determining if it is a danger-
  ous waste. An EPA/State identification number is required for persons who generate
  and/or accumulate 220 pounds or more of dangerous waste per month, per batch or
  on-site at any one time. This requirement is met by submitting a Form 2, "Notifica-
  tion of Dangerous Waste Activities", to the Department of Ecology. Additionally, the
  following activities must be reported using the Form 2:

          ¿ Transportation of dangerous waste generated by a regulated generator to a permitted
            Treatment, Storage or Disposal Facility.

          ¿ Regulated dangerous waste generators that recycle dangerous waste on-site.

          ¿ Generators who market used oil or dangerous waste to be used as fuels.

          ¿ Facilities acting as a Treatment, Storage or Disposal Facility for dangerous wastes
            generated by off-site generators.

          ¿ Burners of off-specification used oil.

          Contact: Ecology's regional Hazardous Waste and Toxics Reduction Program.

  Pollution Prevention in Fruit and Vegetable Food Processing Industries                          33
Generator Annual Reports (Forms 4 & 5)

    An Annual Report (Form 4), detailing hazardous waste activities for the past year, is
    required of the owner/operator of a facility that has an active EPA/State identification
    number. If a waste stream is characterized as hazardous prior to on-site wastewater
    treatment, then the facility may also be subject to "Permit By Rule" requirements
    under the Washington State Dangerous Waste Regulations. If a facility is subject to
    permit by rule, then the quantity of wastewater flowing into the treatment unit must
    be counted and reported on Form 4. A Form 5 (Annual Report for generators who
    treat dangerous waste on-site) must also be submitted to Ecology.

    Contact: Ecology's regional Hazardous Waste and Toxics Reduction Program.

    Pollution Prevention Plan

    Pollution Prevention Plans must be prepared and submitted to Ecology by all hazard-
    ous substance users subject to SARA Title III, and hazardous waste generators that
    generate more than 2,640 pounds of hazardous waste per year. The plans are to be
    developed to stimulate voluntary implementation of opportunities to reduce toxic
    substances used and hazardous wastes generated according to a hierarchy that gives
    first priority to reduction, then recycling and finally treatment.

    Contact: Ecology's regional Hazardous Waste and Toxics Reduction Program.

    Pollution Prevention Plan Annual Progress Report

    Facilities required to prepare Pollution Prevention Plans are required to report annu-
    ally about their progress with hazardous substance and hazardous waste reduction
    opportunities identified in their plan.

    Contact: Ecology's regional Hazardous Waste and Toxics Reduction Program.

♦   Hazardous Substances

    Emergency Planning and Community Right-to-Know

    Emergency Planning and Community Right-to-Know is also known as Title III of the
    Superfund Amendments and Reauthorization Act (SARA). Reports may be required under the
    following Sections of SARA Title III:

    Section 302: Facilities with substances listed on the Extremely Hazardous Substance List in
                  quantities above the Threshold Planning Quantity onsite at any time must
                  report the presence of these substances.

    34                                  Pollution Prevention in Fruit and Vegetable Food Processing Industries
Section 304: Facilities with spills above reportable quantities of hazardous sub-
             stances must notify state and local Emergency Response and Planning
             Commissions.

Section 311 Facilities must have Material Safety Data Sheets (MSDS) on hand in
            order to comply with Occupational Safety and Health Administrative
            requirements, and are required to submit either the MSDS sheets or a
            list of substances which have MSDS.

Section 312: Annually, a facility must submit a chemical inventory report with
             information about the chemicals reported under section 311.

Section 313: Annually, a facility that meets the following criteria must complete a
             Toxic Release Inventory Report (Form R) for the previous calendar year
             by July 1:

               ¿ Conducts manufacturing operations that fall under Standard
                 Industrial Classification (SIC) Codes 20 - 39.
               ¿ Has 10 or more full-time employees.
               ¿ Manufactures, imports, processes or otherwise uses any of the toxic
                 chemicals listed on the Section 313 Toxic Chemicals List in excess
                 of the thresholds listed below:

                    • Annually, manufactures or imports any of the toxic chemicals in
                      quantities of 25,000 pounds or more per toxic chemical or
                      category.

                    • Annually, processes any of the listed toxic chemicals in
                      quantities of 25,000 pounds or more per toxic chemical or
                      category.

                    • Annually, uses any of the listed toxic chemicals (without incor-
                      porating it into any product or producing it at the facility) in
                      quantities of 10,000 pounds or more per toxic chemical or
                      category.

Facilities must report emissions of these listed substances (both routine and accidental) to air,
land or water.

Contact: EPA Region 10, and
          Ecology Headquarters - Hazardous Substances Information Office.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                              35
Underground Storage Tank Notification Requirement

     Notification is required 30 days prior to installation of a new underground storage
     tank or closure of an existing underground storage tank. Tanks existing prior to the
     federal regulations were to have been reported by May 8, 1986. Any of these tanks
     where a notification form has not been completed should be reported immediately.

     Contact: Ecology's regional Toxic Cleanup Program

♦     Solid Wastes

      Solid Waste Permits

     Solid waste permits may be required for land application of food processing sludges
     for beneficial uses.

     Contact: local Health Department

     Solid Waste Management Plan

     A facility required to have a State or NPDES wastewater discharge permit must
     submit a solid waste management plan. The plan shall include all solid wastes with
     the exception of those solid wastes regulated by Chapter 173-303 WAC, Dangerous
     Waste Regulations. The plan at a minimum shall include; a description, source,
     generation rate, and disposal methods for these solid wastes.

     Contact: Ecology's regional Solid Waste Services Program.

36                               Pollution Prevention in Fruit and Vegetable Food Processing Industries
Bibliography

Austin, George T., Shreve's Chemical Process Industries, McGraw-Hill, 1984.

Chemical Engineering, The Nalco Water Handbook, Second Edition, McGraw-Hill.

Eckenfelder, W. Wesley, Jr., Industrial Water Pollution Control, Second Edition.

EPA Pollution Abatement in the Fruit and Vegetable Industry - Basics of Pollution Control,
Volume 1, 1975.

EPA Reuse of Treated Fruit Processing Wastewater in a Cannery, EPA-600/2-78-203,
September, 1978.

EPA Dry Caustic Peeling of Tree Fruit for Liquid Waste Reductions, project number 12060
FQE, December, 1970

EPA Liquid Waste from Canning and Freezing Fruits and Vegetables, program number 12060
EDK, August, 1971

Esvelt, Larry A. & Hart, Herbert H., for EPA, The Health Effect Potential of Reusing Fruit
Processing Wastewater, May 1984.

Federal Water Quality Administration, U.S. Department of Interior, The Cost of Clean
Water, Vol.I11, Industrial Waste Profiles No. 6 - Canned Frozen Fruits and Vegetables,
FWPCA Pub. No. I.W.P.-6, September, 1967.

Jaca Corp., EPA Technology Transfer Seminar, Upgrading Fruit and Vegetable
Operations to Reduce Pollution, Choosing the Optimum Financial Strategy for Pollution
Control

Joslyn, Maynard A., & Heid, J.L., Food Processing Operations: Their Management,
Machines, Materials, and Methods, Vol. One 1963, Vol. Two 1963, Vol. Three 1964, The
AVI Publishing Company, Inc.

Overcash, Michael R., Techniques for Industrial Pollution Prevention - A Compendium for
Hazardous and Nonhazardous Waste Minimization, Lewis Publishers, Inc., 1986.

Riikonen, Nancy, Industrial Wastewater Source Control - An Inspection Guide, Technomic
Publications, 1992.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                       37
U.S. Department Of Health, Education, and Welfare, An Industrial Waste Guide to the Fruit
Processing Industry, Public Health Service Publication No.952, 1962.

Washington State Department of Ecology, Commercial Waste Reduction and Recycling Manual,
September, 1990.

Washington State Department of Ecology, Commonly Required Environmental Permits for
Washington State, 90-29, September, 1990.

Washington State Department of Ecology, Hazardous Waste Pesticides, Publication 89-41,
revised September, 1990.

38                               Pollution Prevention in Fruit and Vegetable Food Processing Industries
AppendixA
               Implementation of Technical Assistance to Food Processing Facilities

The following implementation schedule will be for the next one and one half years, with
workshops being scheduled approximately every six months.

Implementation Schedule:
9/1 - 9/21, 1993    Draft plan review by representatives of the Food Processing Industry.

9/7 - 9/30, 1993          Draft plan review and comments by Ecology staff.

1/26, 1994                Final plan complete.

2/1-2/10, 1994            Notice to Industry about Workshops.

2/21 - 2/25, 1994         Follow up contacts to industry to establish workshop dates below.
                          Notice to industry about workshops.
                          LITERATURE AVAILABLE AT WORKSHOP:
                          * Why Reduce Waste?                  * Getting Started
                          * Environmental Regulations, Permits, and Plans

April, 1994               Workshop: Hazardous Wastes and Hazardous Substances
                          Workshop #1 - Agenda Mail out.
                          LITERATURE AVAILABLE AT WORKSHOP:
                          * Tip sheets on reduction and recycling
                          * Hazardous Waste Generator Checklist
                          * Community Right-to-Know information
                          * Vendor information

Fall, 1994                Workshop: Solid Waste and Water Conservation
                          Workshop #2 - Agenda Mail out.
                          LITERATURE AVAILABLE AT WORKSHOP:
                          * Tip sheets on reduction, recycling, & conservation
                          * Publication addressing " Economic Incentives For Wastewater
                           Treatment & Environmentally Compatible Disposal."
                          * Other applicable literature available upon request.

Spring, 1995              Workshop: Energy Conservation
                          Workshop #3 - Agenda Mail out.
                          LITERATURE AVAILABLE AT WORKSHOP:
                          * Tip sheets on conservation
                          * Other applicable literature available upon request.
The workshops are planned as a learning tool both for Ecology and the Food Processing
Industry. Additional issues and/or projects may be identified and included for implementa-
tion in this plan.

Pollution Prevention in Fruit and Vegetable Food Processing Industries                        39
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