Office of Technical Assistance Executive Office of Environmental Affairs Commonwealth of Massachusetts

Summary

Hampden Papers reformulated a brass-based coating used on paper products and eliminated its copper discharges from this coating application. The Holyoke, Massachusetts company avoided both potential U.S. Environmental Protection Agency fines of $5,000 per day for wastewater discharge violations, and an alternative solution - construction of a $250,000 to $500,000 waste treatment plant.

Background

Hampden Papers is a 118-year-old specialty manufacturer of converted paper, film, foils and boards. The company employs 180 workers and has 64 production machines in a 300,000 square foot facility. Its printed, coated, laminated and embossed products are sold in more than 80 markets.

In one operation, 15,000 to 20,000 pounds per year of a brass-based coating chosen for its aesthetic qualities was applied by gravure and air knife coating machines. The wastewater generated during cleanup of these machines contained copper above allowable limits and was discharged to the Holyoke POTW (publicly owned treatment works).

Copper and zinc (components of brass) precipitate out in the sludge during wastewater treatment. At the Holyoke POTW, the sludge is analyzed periodically for toxic metals (copper and zinc are two of these metals) to ensure that the levels meet state requirements and to classify the sludge. Type 1 sludge can be used for beneficial agricultural applications (due to the low metals content), and disposal is relatively inexpensive. The higher copper content - which the Holyoke POTW could positively attribute to Hampden Papers - meant the facility could have been forced to landfill the sludge as Type 3 sludge (hazardous waste) at substantial additional cost, which would have been passed back to Hampden Papers. Hampden Papers, as an alternative, could have installed its own treatment system to precipitate metals from washwater at a cost of $250,000 to $500,000.

Toxics Use Reduction Planning

Ken Scott, Vice-President of Research and Development, quickly realized that the benefits of using the brass-based coating were offset by the added costs about to be imposed by the POTW. He began an effort to reformulate the coating with a program of laboratory experimentation and production testing that resulted, five months later, in the introduction of a mica-based alternative.

Toxics Use Reduction Modifications

Hampden Papers’ substitution of a mica-based coating for a brass-based coating had a dramatic effect on sludge toxicity numbers. Prior to the change, the sludge at the POTW averaged 1090 parts per million (ppm) of copper; after the substitution, copper averages 703 ppm. Sludge with less than 1000 ppm copper content is classified Type 1 and can be used in land applications.

While product quality has not been affected by introduction of the new coating, chemical costs were initially 60 percent greater. Hampden Papers is continually refining the formulation and has reduced the differential to 20 percent.

Results

Reductions Achieved: Type 3 sludge is a hazardous waste that must be landfilled in 55 gallon drums. In addition to filling large amounts of limited landfill space, burial would also pose long term liability concerns for both the POTW and Hampden Papers. On the other hand, Type 1 sludge can be used as compost. Hampden Papers’ reformulation means the sludge can now be used in a beneficial manner, providing compost for agricultural needs. Over 31 million pounds a year of sludge will not be landfilled.

Economics: If the POTW had been required to landfill Type 3 sludge, the average cost would have been a $17 per ton shipping fee - $265,000 - for the nearly 16,000 tons generated annually.

The cost to Hampden, had the company opted to install a wastewater treatment system, would have been $250,000 to $500,000. Hampden would also have had additional costs for labor, overhead, and hazardous waste disposal. Thus, while the new coating has increased production cost, comparison of total costs more than justifies the use of mica-based coating.