vvEPA
              United States
              Environmental Protection
              Agency
                 Office of Pollution
                 Prevention and Toxics
                 7403
EPA745-K-95-009
November 1995
EPA's 33/50 Program
Company Profile
                                       > Printed on Recycled Paper

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                              EPA's 33/50 PROGRAM
                                COMPANY PROFILES
                                                     BY THE 33/50 PROGRAM ,
                                                           CHLOROFORM
                                                     'CHROMIUM & COMPOUNDS
                                                        %              '
                                                      MERCURY & CWMKJUNDS
                                                       &iK)3& COMPOUNDS
                                                -  - * Aiso referred JQ as metliytens cfioride
 This Company Profile is part of a series of reports
 being developed by EPA to highlight the accom-
 plishments of companies participating in the 33/50
 Program. The 33/50 Program is an EPA voluntary
 pollution reduction initiative that promotes reduc-
 tions in direct environmental releases and offsite ,
 transfers of 17 high-priority toxic chemicals.  The
 program derives its name from its overall goals 
 an interim goal of a 33% reduction by 1992 and
 an ultimate goal of a 50% reduction by 1995. The
 program uses 1988 Toxics Release Inventory (TRI)
 reporting as a baseline. In February, 1991, EPA
 began contacting the parent companies of TRI
facilities that reported using 33/50 Program
 chemicals since 1988 to request their participation
 in the 33/50 Program.:  As of November, 1995,
 nearly 1,300 companies had elected to participate
 in the Program, pledging to reduce emissions of
 the 17 target chemicals by more than 380 million
 pounds by 1995.  Companies set their own reduc-
 tion targets, which may vary from the Program's
 national 33% and 50% reduction goals.

 Industry exceeded the 33/50 Program's interim 33%
 reduction goal by more  than 100 million pounds in
 1992.  National emissions of Program chemicals
 were reduced by an additional 100 million pounds
 in 1993, bringing total reductions since 1988 to
 more than.685 million pounds (46%). ^Facilities' TRI projections suggest that the Program's ultimate 50%
 reduction goal will be observed to have been achieved or exceeded in the 1994 TRI data, a full year ahead
 of schedule. The. 1,300  companies enrolled in the 33/50 Program have accounted for most of the Progra-
 m's pollution reductions. Representing just 15% of eligible companies and owning only a third of the facil-
 ities reporting Program chemicals to TRI, participants are responsible for 78% of the reductions since
 1988 and 98%-of the 100 million pounds reduced in 1993.

 EPA is committed to recognizing companies for their participation in the 33/50 Program and for the
 emissions reductions they achieve.  The Program issues periodic Progress Reports, in which participat-
 ing companies are listed and highlighted.  In addition,  Company Profiles,  such as this one, are being
prepared to provide more detailed information about how companies have achieved their emissions
 reductions. Information presented in these profiles is drawn from a number of sources, including the
 company's written communications to the 33/50 Program, extensive interviews with company representa-
 tives, the annual TRI reports submitted by the company's facilities (including Pollution Prevention Act
 data reported to TRI in Section 8 of Form R), and, in many, cases, site visits to one or more of the com-
pany's facilities. 'Mention of trade names, products,-or services in this document does not convey, and
 should not bejnterpreted to convey, official EPA approval, endorsement, or recommendation.

 Copies of other 33/50 Program Company Profiles, as well as Reductions Highlights documents
 summarizing all of these Profiles, may be obtained by contacting the Program as specified in the box
 below. In addition, all  written company communications to EPA regarding the 33/50  Program are avail-
 able to the public upon request.
Far inf&rmdtion on the 3J/5# Program, coiitact tk&TSCM 260-6907 yr ty, matt at Mail C6M 740$ 'O$&
                                                                     '
                 33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION

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 SUMMARY

       etween   1988  and  1993,  Eaton
       Corporation reduced releases arid
       transfers of 33/50 Program chemicals
 by 1,791,000 pounds, an 80 percent reduction
from the 1988  level of 2,242,121 pounds.
 These reductions included the complete elim-
 ination of releases and transfers of methyl
 ethyl ketone, tetrachloroethylene,- and xylene
 (mixed isomers).   Data provided by  the
 Company detailing 1994 releases and trans-
fers includes an additional reduction  of
 approximately 49,000 pounds, bringing the
 1994 total for the company to 401,000 pounds.
                                             . Of the many projects implemented at Eaton
                                              facilities throughout the U.S., four are pre-
                                              sented in this company profile:
                                                Metals reduction from grinding swarf

                                                Elimination of the use of chlorinated
                                                 degreasing solvents

                                                Establishment of a chromium waste
                                                 exchange program
                                                Substitution of powder coatings for, sol-
                                                 vent.based paints.

                                              These four projects have resulted in significant
                                              reductions  in  releases  and  transfers of
                                              chromium, nickel, 1,1,1-trichloroethane,  and
                                              trichloroethylene.
COMPANY  BACKGROUND

      Eaton Corporation is an original equipment manufacturer of engineered prod-
      ucts for the automotive, industrial, commercial, and military industries.  The
      company is divided into five business groups, each manufacturing and mar-
keting a number of products:

     Cutler Hammer:  AG Drives, torque brakes and press drives, motor control
      centers, safety switches and panel boards;
     Automotive Components: viscous fan'drives, hydraulic lifters, air control prod-
      ucts and engine valves;
     Semiconductor Specialty Systems: military and commercial aircraft, aircraft
      components, relays, switches, high performance switches and keyboards, pres-
      sure and temperature transducers, navy and marine motor controls;
                                                                           -T
            33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION

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                                         Controls & Hydraulics: industrial clutches, golf club' grips, molded rubber
                                           products, electrochemical controls, thermostatic controls, load cells, hydraulic
                                           motors, and air conditioning control components;

                                         Truck Components: medium and heavy truck axles, medium to large steel
                                           forgings, medium and heavy trucjc transmissions.
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 Exhibit 1 shows the Company's five business groups, including the major classes
 of products manufactured, but is however, not a comprehensive list of Eaton's prod-
 ucts or divisions.

 Established in 1911, Eaton employs 50,000 individuals in 17 countries. The company
 is headquartered in Cleveland, Ohio and has approximately 80 manufacturing facilities
 across the United States, Canada, and Mexico. In addition to these manufacturing facil-
 ities, Eaton has one manufacturing center and three research centers which are involved
 in technical research for the company including building prototypes'and providing man-
 ufacturing consulting.  The research centers are: Greentree, PA, which is engaged in
 heavy-duty electrical switch research; Milwaukee, WI, which is involved in medium-
 duty electrical controls research;  and Southfield, MI, which conducts automotive
 research. The manufacturing technology center in Willoughby, OH performs hands-on
 engineering technology research. The Willoughby, OH facility also has an on-site training
 qenter where company-wide training programs are conducted.                  .

 Eaton's revenues for 1994 were $6.1 billion and are expected to increase beyond $6.5
 billion in 199.5. Eaton's acquisition of Westinghouse Electric Corporation's $1.1 billion
 Distribution and Control .Business Unit in January 1994 resulted in an increase in
 Eaton's revenues of about 25 percent.

 ENVIRONMENTAL  STRATEGY

    In addition to participation in the 33/50 Program, Eaton Corporation is involved
    in numerous other activities aimed at protecting the environment. The Eaton
    Environmental Strategic Initiative (EESI), officially begun in 1993, is a waste
 minimization program designed to identify technological alternatives to reduce or
 eliminate releases of hazardous chemicals to the environment. By reviewing reg-
 ulatory requirements and examining the large quantity of chemicals released at its
 facilities, Eaton has identified specific processes  which may be altered to reduce
 or eliminate releases of certain chemicals. As part of this program, Eaton is funding
 in-house as well as external environmental research to develop alternatives for selected
 chemical processes. The budget for this program was $700,000 in 1994, and is pro-
jected to be $745,000 in  1996.

 In 1993, Eaton adopted Worldwide Environmental, Health, and Safety Guidelines
 which are designed to  provide environmental guidance for Eaton's facilities.  The
 guidelines contain a list of recommendations for improving environment, health, ,and
 safety in and around Eaton facilities.  The recommendations include:  methods for
 improving materials and industrial  waste management handling, design of a strategic
plan demonstrating a proactive approach to waste minimization, and guidelines for con-
ducting industrial hygiene surveys on a regular basis. To encourage facilities to comply
with the guidelines, Eaton conducts audits of its facilities to ensure they are in compliance
with environmental regulations. Each facility is audited every three years;,the first audits.
began in 1990. These initial audits were conducted by outside consultants hired by Eaton,
but the Company is now training  plant environmental managers to conduct future
audits.  The facilities that did not meet compliance requirements, were required to come
into compliance as rapidly as possible. Eaton is now beginning its second round of audits,
focusing initially on those facilities with significant releases and transfers of 33/50 Program
chemicals. This second round of audits is designed to identify means by which compa-
nies can reduce or eliminate their use of 33/50 and other potentially hazardous chemicals.
 Eaton Corporation is
 an original equip-
 ment manufacturer
 of engineered prod-
 ucts for the automo-
 tive, industrial, com-
 mercial, and military
 industries.
The Eaton
Environmental
Strategic Initiative
(EESI) is a waste
minimization pro-
gram designed to
identify technological
alternatives to
reduce or eliminate
releases of haz-
ardous chemicals to
the environment.
           33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION

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                approval for
                                    ittontofe

                              j'ronrrientai conference every 18 montEswEere environmental managers from Eaton's
                              .'.^facilities	convene	to	obtain	training and to share their ideas concerning environmental.
                               issues affecting the company and new technologies. Eaton staff have also developed
                                              processes for eliminating solvent usage in the cleaning of metal parts
                                    water in place of traditional solvents.
I'..,'  ' ''"  '-'that would"increase "
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            ses or transfers
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         sheets {MSDS) that
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                               Because of the Company's commitment to environmental protection, Eaton and its
                               facilities have received numerous awards for their efforts in pollution prevention.
                               Recognition that the Company has received include, Governor Awards for Pollution
                               Prevention in Ohio, Tennessee, North Carolina, Illinois, Nebraska, and Oklahoma, as
                               well Is tfie Presidential Environmental and Conservation Award in 19911
                               As part of its effort to meet its' 33/50 Program goals, Eaton has adopted a policy of denying
                               approval for the introduction of any new processes or process changes into their facil-
                                                                                          This policy was orig- _
                               jnally established to prevent processes that generate hazardous waste from
                                      '- ..... EuTKas sine e" Been ..... grinded to include 33/50 Program" chemical releases and
                               transfers as well. The policy is enforced through financial controls, as a corporate envi-
                               ronmental manager must approve all appropriations for new equipment or other acqui-
                               sitions. The 'policy has been  strictly enforced not only in the U.S., but also at Eaton
                               facilities abroad.
                                    company has used this policy'on several occasions to prevent increases in
                               releases and transfers of 33/50 chemicals.  For example, an Eaton facility in Mexico
                               mil  ii 11  i n n i illinium	ii	in	n	i	yum	ii	n	ii	n	iiiiigiiiiiiiuii	in	i	IKII		M	unn^	HI	inn	IM	> ^		H.Q	,	n	^	^	.,	^	^	^	> ^ ^	
                               Was  refusedTinancial backing for the installation of a new painting line that would
                               utilize solvent Based paints coritEning 33/50  chemicals. The facility was informed
                               that  it would not receive funding for this project until it developed a process that did
                               not involve the use of paints containing 33/50 chemicals. In another instance, one of
                               Eatpn's competitors, Rockwell, began selling painted truck transmissions.  Eaton, which
                               until this time sold unpainted truck transmissions,' decided that it was imperative to
                               stai^t painting Its truck transmissions to remain competitive. Because of the Company's
                               jjolicy of not introducing 33/50 chemicals into new processes, Eaton  chose to develop
                               a durable water-based paint with a salt spray in excess of 500 hours. Researchers at
                                     worked on this problem for many months and eventually developed a water-
                                     JIHMii|iiiM|^ withstand-severe conditions. As a result of these efforts, truck
                               transmissions are now being coated using a water-based.paint at Eaton's Shenandoah,
                               Iowa; Kings Mountain, North Carolina; and Shelby, Tennessee facilities.
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                               Eaton has created a database containing material safety data sheets (MSDS) that will
                               allow the company to track chemical use at  each of its facilities.  Eaton feels that
                               "the	creation	oTEEe	HataBase	will	ease	reciof3k"eeping and reporting, help managers
                               to anticipate potential c^mpliahce probTerns^ and facilitate prompt and effective
                               responses to emergencies. Eaton intends to expand this database to include chem-
                               ical purchases as well.
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                                            33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION
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EATON'S RELEASES AND TRANSFERS. \ . ' ,. ;
OF TRI
33/50 Chemicals (1, 000 Ibs.) 1988
Chromium & Compounds . v 536
Dichloromethane 76
Lead & Compounds . 1
Methyl ethyl ketone** . NR
Nickel & Compounds 239
Tetrachloroethylene 106
Toluene 159
1,1,1-Trichloroethane 669
Trichloroethylene 402
Xylene , 54
33/50 Subtotal"* 2,242
Other TRI Chemicals 1,117
' Total*" 3.359
NR = Not reported
NA= Not Available
CJHEMICALS
-1993
'.- : , ,-- 183
32
8 ' .
NR
68
NR
 20 . .
: -  99 ,
28
11
450
. 232
682



1994*
.,,. 212
NR
22 '
NR '
49 .
NR
13 x
69 .  .
, 20
16
401
NA
NA


' 1994 Data was supplied by the company and is considered unofficial. . ', 
"Approximately 59,000 Ibs. & 14,000 Ibs. of methyl ethyl ketone were reported as
respectively. ' .. 
*" Columns may hot sum to total due to rounding.


"Air Emissions" in 1989 and 1991,

m^^^
Exhibit 2

Releases and Transfers
of TRI Chemicals
(1,000 Pounds) '


















OVERVIEW OF 33/5O A^ND TRI CHEMICAL
RELEASES  AND TRANSFERS
     :
     Iince 1988, Eaton has reported releases and transfers of 10 of the 17 33/50 chem-
     icals.  Exhibit 2 presents company data on releases and transfers of TRI
     chemicals for 1988, 1993, and 1994. Exhibits 3 and 4 provide a breakdown
of the company's 1988 TRI data by release media and by chemical. Additional data
are provided in Appendices A through D at the end of this Profile.
          1,1,1-Trichloroethane
              29.84%
                                         Trichloroethylene
                                            17.92%
 Tetrachloroethylene
     4.72%
    Nickel/Nickel Compounds
         10.64%
                                                  Xylene (mixed isomers) p-Xylene
                                                         2.41%

                                                   Dichloromethane
                                                      3,40%
                                               :hromium/Chrornium Compounds
                                                      23.92%
                                           I/Lead Compounds
                                             0.06%
                                                                         Exhibit 3
                                                                         Percentage Breakdown
                                                                         of 33/50 Program
                                                                         Chemical Releases and
                                                                         Transfers for 1988
                                                                         (by Chemical)
          33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION


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 33/50  PROGRAM  GOALS  AND  REDUCTION
 PROJECTS

          When Eaton Corporation joined the 33/50 Program in May  1991, .the
          Company established a goal of a-50% reduction in releases and transfers
          of 33/50 chemicals by 1995 using 1988 levels as the baseline.   This
 translates to a reduction of 1,121,060 pounds. The Company stated an intention to
 rely on source reduction measures rather than treatment methods to the maximum
 extent possible to achieve these reductions. Implementation of the 33/50 Program
 at Eaton is conducted in a decentralized manner.  The Manager of Corporate
 Environmental Engineering works with the environmental managers of each facility
 to assist in making decisions regarding target chemicals.and the means by which
 reductions in releases and transfers should be achieved.

 The remainder of this section describes four projects that resulted in significant decreases
 in releases  and transfers of 33/50 chemicals at Eaton facilities,  the first two projects
 focus on implementation of new technologies at Eaton's facilities  in Kearney, Nebraska,
 and Spencer, Iowa, respectively. The remaining two projects describe smaller changes
 made at several Eaton facilities. Specifically, the projects discussed in this case study are:

      Metals reduction from grinding swarf
     Elimination of the use of chlorinated degreasing solvents       ,
     Other reduction projects.

 Project #1: Metals reduction from grinding swarf

 In early 1993, as a result of both the 33/50 Program and Eaton's Environmental Strategic
 Initiative, the Company identified the need to develop a means of reducing off-site trans-
 fers of metal-containing waste generated from the grinding of intake and exhaust valves
 at its facility in Kearney, Nebraska. At the time, 10,000 pounds of grinding swarf (metallic
 waste) were being shipped to a landfill each day from this facility. The grinding swarf
 was comprised of metal, filter aid paper (on which the swarf collected), oil, and water.
 The metal, composed of  fine particles ranging from less than 200 micrometers to
 approximately 300 micrometers in diameter, made up 30 percent of the total waste stream.
 Of the metal in the waste, between one and seven percent was nickel and less than one
 percent was chromium.  Because of the valuable metals contained in the waste, and in
 an effort to reduce transfers of these 33/50 chemicals to landfills, Eaton  began an
 investigation of methods to remove the metal from the grinding swarf prior to disposal.
 The company investigated several different alternatives for processing the grinding swarf,
 including: washing the swarf to remove the metal from the filter aid paper, using vacuum
 distillation to remove the oil. and water from the swarf, and incinerating the waste to burn
 the oil and filter aid paper. Each of these alternatives had drawbacks that prevented them
 from being adopted:  washing the swarf produced additional wastewater  treatment
 needs, vacuum distillation failed to sufficiently separate the metal and the filter aid paper,
 and incineration produced hazardous air emissions. As a result,  Eaton ruled out each
 of these techniques as options for removing metal from the grinding swarf.

Eaton next began investigating compression technologies to reduce the volume of the
waste sent to the landfill.  Specifically, the company considered an ultra-high-compression
device to compact the grinding swarf into briquettes approximately two inches in diameter.
During the investigation of this technology, Eaton learned, through discussions with other
 The major environ-
 mental benefit asso-
 ciated with Eaton's
. guiding swarf metals
 reduction project is
 the avoidance of
 landfilling large
 quantities of toxic
 metals, thereby
 reducing releases
 and transfers of
 33/50 chemicals.
           33/50 PROGRAM COMPANY PROFILE:  EATON CORPORATION

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          e wasre
     by $150,000
       	Eaton
 eves mat. in
ong run, It'w
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  | individuals in the industry, of a smelter that was interested in purchasing the grinding swarf
   generated by Eaton. The smelter planned to process the swarf into low grade stainless steel
   "pigs" that would be sold to premium stainless steel smelters for use as raw material.

   Before purchasing the grinding swarf from Eaton, the smelter required that the grinding
   sWarf be formed into seven-inch cubes using low-pressure briquetting. Producing the
   briquettes was relatively simple for Eaton, since the Kearney facility already had low-
   pressure briquetting equipment on-site.  In addition, briquetting the grinding swarf elim-
   inated the need to separate the metal materials from the filter paper, since the smelter
  I accepts the material as a mixture.		'	

  ' To test the process, the smelter asked that Eaton ship 156 tons' 6f"tnegYmcling swarf
   by rail car in August 1994 to be processed^  The test proved successful and Eaton con-
   tinued to send the briquettes to the smelter. Following this successful trial at the Kearney
   .feality, two of Eaton's other plants (those in Belmorid, Iowa and "Westminster, South
   pijro}ina) began shipping their grinding swarf to the smelter as well. As a result, in
   j\pril 1995, the smelter was receiving more than 15,000 pounds of briquettes per day
   from the three Eaton facilities.  Due to these efforts, approximately 450 pounds of nickel
   and 150 pounds of chromium  per day from the three facilities combined are now pro-
   ductively used as product inputs rather than being landfilled.
   II ' i I	I : : I  i :<:  ;"T-" i ~''  i !i	 ;V,'Ti:'	:	J': i 'T 	I iTgfSirX'i rTj.r7,;::;;3i|i	si|,:v:;:;,= jr; ;;T i,,,^,- rl:,r	i:7j: ^T	 ir;	iirr: :	,  ;:j	T
   According to Eaton, there are no significant environmental, health, or sarety concerns
   associated with the implementation  of this metal recycling program.  Because the
   grinding swarf is formed into briquettes using a wet process that is fully automated, worker
   exposure is mipiiriizedl  The major environmental benefit associated with the project
   ls the avo|dance of landfillingtfiese large quantities of toxic metals, thereby reducing
                      	rwMIlIIi2^2Li!!l?'	^H	^eir primary
   reason For briquetting the grinding sw:
   Briquetting the'grinding swarf and sending it to the smelter increased Eaton's costs for
   managing the waste stream by $150,000 per year. This increase resulted primarily from
   transportation costs to the smelter, which is located much farther from the facilities than
   the landfills used  by each facility.  The company is willing to incur this  expense,
   however^	because jtforesees a trend in landfill closureand	ajrefasalby_	other landfills _
IJ! "fp	cSptmue	to	Sept	grinding swarf.  Such" closures	wit!	result	in	mcreaseS trans-
   portation and dumping costs. Thus, Eaton believes that, in the long run, it will be less
   expensive to send the grinding swarf to the smelter than to landfill the waste.

   Project #2: Elimination of the use of chlorinated dTefeasmj^solvents
   Eaton's Spencer, Iowa facility, which manufactures light and heavy duty hydrostatic trans-
   missions, has traditionally used 1,1,1 -trichloroethane in dip tanks and in vapor degreasing
   to remove residual lapping grit (oil and silica carbide/silica oxide) from metal surfaces
   pnorto	transmission assembly. The lapping compound is used to grind the surface of
   the swash plates, end covers, valve plates, bearing plates, and bronze seals to produce
   a perfectly flat surface, so that the two metal surfaces can be fit together precisely during
   final assembly of the transmissions. Failure to achieve a precise fit would require that
   both parts be discarded, resulting in significant costs to the company. Use of 1,1,1-
   trichloroethane in this application at the facility resulted in approximately  14,760
   "pounds of'air emissions in" 1988.        '
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                     i PROGRAM COMPANY PROFILE: KATON CORPORATION"
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 In the late 1980's, an accidental release of trichloroethylene occurred at the Kearney,
 Nebraska facility.  Because of the awareness of the risks of solvent releases raised by
 this accident, the plant manager and environmental, health, and safety managers at the
 .Spencer, Iowa facility decided to pursue the elimination of the use of 1,1,1-trichloroethane
 at their facility.            '        .   '";"..

 Eaton began testing a number of different detergents that might clean the transmission
 parts in an aqueous (water-based) process.1 The facility sent the transmission parts to
 the Manufacturing Technology Center in Willoughby, Ohio where researchers tested 30
 to "35 detergents to clean the metal parts.  After extensive testing however, it was
 evident that none of the detergents were successful in adequately removing the lapping
 compound from the transmission parts.

 During this testing the researchers concluded that the time delay in, sending the parts
 from Spencer, Iowa to  Willoughby,.Ohio may be contributing to the difficulty in
 removing the lapping compound from the parts, believing that the longer the parts sat
 before cleaning, the harder they.were to clean.  To address this problem, Eaton began
 transporting the transmission parts by overnight air from Spencer, Iowa to Willoughby,
 Ohio to reduce the time that the lapping compound remained on the parts.  The water-
 based cleaning system cleaned more effectively  under these circumstances, but the
 researche'rs felt that the cleaning still was not adequate.

 In 1988, after numerous failures with the water-based detergents, the researchers at the
 Manufacturing Technology Center experimented with adding the detergent to the
 lapping compound prior to lapping. When the researchers blended a detergent mixture
 consisting of petroleum sulfonate and deodorized kerosene with the lapping com-
 pound, it was discovered that the lapping compound could be easily removed using an
 aqueous process. The addition of the detergent to the lapping compound also improved
 the quality of the lapping since the petroleum sulfonate in the detergent acted as a rust
 inhibitor to protect the metal surfaces.    .,:.,..

 In late 1989, the Spencer, Iowa facility installed two large aqueous washers to clean trans-
 mission parts following application of the detergent/lapping compound mixture. These
 in-line conveyorized washers operate on a five-stage cycle  two washes,  two rinses,
 and hot air drying.  The process uses DuBois Chemical's ISW 29 at a 3% concentration
 in the wash baths, and DuBois 200 in the rinse baths. The active ingredient in ISW 29
 is potassium hydroxide (<25 percent) and DuBois 200 is a rust preventive based on borate
 complex salts (<20 percent). The rinse leaves a slight amine residue on the parts following
 the cleaning process that facilitates painting as the amine residue binds with the paint as
.a compatible material, thereby increasing paint adhesion to the metal .surface.

 The major environmental issue associated with the change from 1,1,1-trichloroethane
 cleaning to aqueous cleaning was  the impact on the facility's wastewater stream and
 resulting wastewater treatment needs. While many facilities had on-site wastewater treat-
 ment capabilities, the nature of the treatment associated with aqueous cleaning required
 that a number of facilities upgrade their treatment processes from chemical treatment
 to ultrafiltration. Making this switch in treatment methods where needed has ensured
 that Eaton's change to aqueous cleaning has not resulted in additional water pollution.

 Although the impetus for eliminating 1,1,1-trichloroethane at the Spencer, Iowa facility
 was reducing the risk of exposure to the chemical, implementation of the detergent
 In 1988, after
 numerous failures
 with the water-based
 detergents, the
 researchers at the
 Manufacturing
 Technology Center
 experimented with
 adding the detergent
 to the lapping
 compound prior
 to lapping.
In late 1989, the
Spencer, Iowa facility
installed two large
aqueous washers to
clean transmission
parts following appli-
cation of the deter-
gent/lapping
compound mixture.
           33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION

-------
  	I'!1"	
                                                                    I'jiMii1
 11" I1!, tl
i .  ." i
                                                                               i!
                     '*,!
                     4
          'Ion of
     'oroeWane
         11	I'l'iiii!	Lftiit;:' "
	i!	.jw,f.jfiiaoniK
,j'. "figi!	,  -"' II1 ^IliiHJ	taiii. '	TIT	I,	I,
    jwed the Spencer,
    F-VlT'*	'	:--'^'SS	
                           facturing plant owned and operated by Monroe Shock Absorbers! Through discussions
                           with employees "at the Monroe plaht^ it was discovered that Eaton's waste chromium
                           was a more valuable solution, having more usable chromium than the chromium used
                           at Monroe as raw materials.  A program was devised that would allow Eaton to ship its
                           waste chromium to Monroe, thereby eliminating both waste disposal costs for Eaton and
                           chromium purchases for Monroe.

                           Jhe transfer of chromium takes place four times each year, with each transfer consisting
          ; fSpiA	;::;:	r;	^ ip;	^approximately 14,000 gallons' of chromic acid solution. Prior to each transfer, Eaton
           |||^	:	i-i"	ji.>T	|!'i|i |fi-i;!^|ads_a. Jg^rtoj^.E^ inforrning them of the impending transfer. A dedicated truck
i;;	r^i|i//remems
                                                                                                     i.'fl
                                                                                                      1  ll	!"
                   iiil"jji'   |      'IN             i  i- i  	   j-   j	,1 jj   i ,  j ,
                   cleaning system resulted in a cost savings for the facility as well. In addition, the elim-
                   ination of 1,1,1-trichloroethane allowed the facility to be reclassified from a large
                   quantity generator of 1,1,1-trichloroethane to a conditionally exempt generator (CESQG),
                   thereby making the facility exempt from RCRA filing requirements.

                   Project $3: Other Reduction Projects
                           This section includes a discussion of two projects implemented by Eaton that,
                           together, substantially reduced the company's releases  and transfers of 33/50
                           Program chemicals,  most importantly chromium, 1,1,1-trichloroethane, and
                           trichloroethylene.  The two projects presented are:  establishment of a chromium
                                           program	and	guksgfuj;iori Qf solvent-based "paints  with powder
                           coatings at Eaton's Lincoln, IL facility.

                           Establishment of a Chromium Waste Exchange Program
                                                                                   1:.
                           T,he Eaton facility in Kearney, Nebraska uses large amounts of chromic acid annually
                                                         '. "In 1988, ..... the use of chromic acid in this application
                           "re|ulted' in off-site ....... transfers ........ of ...... 335J2? ....... Pun3s ........ oF ...... chToliniurn ........ compounds from the
                           facility! ............ Tn'e ..... quantrty"oFoff^site" transfers "at Kearney ...... is ...... very ...... High Because the
                           'requires an extremely clean plating bath to achieve the necessary adhesion, appearance,
                           and thickness criteria required by the Company. Traditionally, the Kearney facility treated
                           its waste chromic acid bath in its on-site wastewater treatment system prior to shipping
                           t;he material to a recycler in Texas.
                                         ^ME	Ban 'S'aatHoff, the Environmental, Health, ancl Safety Manager for
                           Eaton's	Kearney	TahX'	develoed the idea	of a waste	exchange" with a nearby manu-
                                                                           '
                                                     environmental staff follows the truck until the waste is
                                                   :fc	a'F'Monroe. In total, thecTiroirauH^a^teexcharigeprogram
                           glirninates approximately $25,000 per year in waste disposal costs for Eaton.
                                                              1   ,   ;       '        '[;     '       ';  '   '"
                                                        Paints with Powder Coatings at Eaton's Lincoln,
                              Facility

                           The Eaton facility in Lincoln, Illinois is a manufacturer of electrical breakers and
                           enclosures for residential and industrial use.  In its traditional painting operations, the
                           facility used a high-solids solvent-based paint in a liquid dip system. Due to the rela-
                           tively low surface protection capabilities of the liquid paint used in the dip system, a
                                  "    '' '                                    "
                         ;;;  hrorrie " seal'' 'anH^zinc^ phosphate pretreat stage had "to be used during the painting
                           BF5cesi; This pretreat stage resulted in the generation o
                                                                            icant quantities of haz-
                                                                                             ,;:;? , :,':
                                                                   :!	i
                                                                                                              i
                                                           =*t	m	~
                                             PROGRAM, "COMPANY PRpFiLiEi/'

-------
               COMPARISON OF WASTE FROM LIQUID
                  PAINTING AND POWDER COATING
               Liquid Dip
Powder Coating
  Hazardous
               35 drums flammable liquids
               2 drums 1,1,1-trichloroethane waste
           ,    4 drums chrome sludge
               4 drums wet spray booth water waste

  Non-Hazardous
               20 sacks paint cleaning waste
               85 drums paint drip papers
               3 drums oven ash
None
18 drums waste powder
6 drums oven ash
 ardous waste, although chromium and zinc quantities were below TRI reporting thresh-
 olds. Iri the liquid dip process, the part to be painted was dipped into the liquid using an over-
 head hoist, after which it was removed and transported to a cure oven. During this transport,
 excess paint would drip off the part and gather on paint drip papers placed on the floor beneath
 the overhead conveyor. These papers were also a significant source of painting-related waste.

 To reduce hazardous waste containing chromium and zinc, the Lincoln facility converted
 in late 1991 to electrostatic powder coating.  Electrostatic powder coating applies a dry
 powder film to the product through a spray process, with overspray being collected and
 recycled through the powder booth system for reuse. Use of the powder coating system
 results in no waste paint and the elimination of.paint drip papers.  Perhaps most impor-
 tant, however, is the fact that the powder paint provides a much better protective coating
 than the liquid paint. As a res.ult, the chrome seal and zinc phosphate pretreat stages are
 no longer needed. Instead, an iron phosphate and non-chrome seal with a deionized water
 rinse is ^used, but the new phosphate  and ,npn-chrqrne seal are both classified as non-
 hazardous wastes. Furthermore, as use of the solvent-based paint resulted in significant
 emissions of solvent, the switch to powder coatings virtually eliminated these emissions.

 While the switch'to the powder coating system has generally reduced waste generation,
 there have been increases in certain types of waste. For example, with continuous recy-
 cling  of the powder, the material  will eventually break down to a  level where the
 powder particles are too small for proper operation in the  system.  When this occurs,
 the booth must be cleaned and the excess fine powder disposed of. In addition, the hooks
 and hangers  used to transport the parts being painted are themselves coated with
 powder each time they pass through the spray booth, thereby reducing the effectiveness
 of the electrostatic system. Therefore, they must be cleaned much more frequently than
 in the liquid  dip system.  The old system  was cleaned quarterly, while the powder
 coating system requires daily cleaning.  One option has been a "burn-off" process that gen-
 erated ash residue that is collected, placed in drums, and disposed of. Both the excess powder
 and the oven ash are classified as nonhazardous materials. A comparison of the waste gen-
 erated by the liquid dip and the powder coating processes is shown in Exhibit 5.

Due to the success of the powder coating process at the Lincoln, Illinois facility, Eaton
elected to switch to the same technology at a number of its other facilities.  Currently,
the other major Eaton facilities using this type of powder coating system are located in
Grand Prairie, TX, Fayetteville, NC, Arden, NC, and Greenwood, SC.              '
                                    Exhibit 5
Comparison of Waste
from Liquid Painting
and Powder Coating
                                    Due to the success
                                    of the powder coat-
                                    ing process at the
                                    Lincoln, Illinois facil-
                                    ity, Eaton elected to
                                    switch to the same
                                    technology at a
                                    number of its other
                                    facilities.
                                    11
           33/50 PROGRAM COMPANY PROFILE:  EATON CORPORATION

-------
                                  ; '"I'll ins1'!'11!*1 ', i]]1	"I"1!'" jfi' Iff I'!!!111! '"ffi!1' iiliiiii1 ll!l"' "i1 "i fll"!!:!' T 'v I'!'! i" liiiil	'HI Ilillillll" "li Hi" -I V'i if JI|P ""j "ill 'IV'' 'I lf I \ wftiSlm 1} "I'Biiili'! i1''iil'lfiii i Si" ;i' i'L'!' iillliiill1" flifi1 n!i" i"  "I1" 'ill1 I ''llii'i'1!!! I1 '1 if' i'"ntltt'n 'illii"'iiiii 'i iii"n ii'l i1' i ''ii!i lllliiil'iiiliiiiiil1 ii i r'l	II1" 1I1''"'li1 lii i 'iEI'li'Fi1'IKIB!1 T
                                  	:!;	il!	i:	:	!	 	;;;;; i	ii;;;;;!	;;;	i	S	i	ii:	S&*	:	a I	:	: i	i! 	i	Is	    	 ills	Ill:	 ;	i;isi	::ll;:i	ME	;i;s	!	;;:   	:	 ;;;	
                                                                                          	
                   i	i	i	i	i!	i	ii
                                                                                                                         :' d
     of33/SO cti&mtcals py
         i,79ii()00 pounds
        from 1&8S to
          	IniiL;	;IM;	i
              ^ M
              i	!	i	:	l|	;!:;;
              'ijljv,	I	'	;	;|	jij;1'^
      Rrcentfise "Breakdown^
       	>  :--'f..1!r:
	,':	I,'  .'"'   '   s.r   .   i -  ;,-'
                                                                            Non-33/50 Chemicals

                                                                            33/50 Chemicals
                                                   1988     1989     1990     1991     1992     1993
                                          33/50 Goal: 50% Reduction in releases and transfers of 33/50 chemicals by 1995
                              33/5Q PROGRESS

                                     Eaton has been successful in reducing releases and transfers of 33/50 chemicals
                                     by over 1,791,000 pounds between 1988 and 1993 - an 80% reduction from
                                     2,242,121 pounds to 450,211 pounds. As shown in Exhibit 6, the company has
                              surpassed its 33/50 goal of a 50% reduction in releases and transfers of 33/50 chem-
                              teals,.  This reduction included a complete elimination or" releases and transfers of
                              methyl ethyl ketone, tetrachloroethylene^ and xylene (mixed isomers only). Other
                              major reductions in releases and transfers of 33/50 chemicals through  1993 included
                              the following:
Chromium & chromium compounds
Dichloromethane
Nickel & nickel compounds
Toluene
1,1,1-frichloroethane
Trichlorpethylene
352,969 pounds (66 percent reduction)
44,650 pounds (59 percent reduction)
17d,05i3 pduri9s(7T percent reduction)
139'250 pounds (8_8 percent reduction)
569^783	pounds	^SSpercenTreduction)
373,375 pounds (93 percent reduction)
                                                                                 II Ilillillll II III I III   IIIIIII I III IIII
                                                                          J I. Ill
                                                                          1,1,1-Trichloroethane
                                                                           '  22.06%
                                      Nickel/Nickel Compounds
                                           15.21%
                                Chromium/Chromium Compounds
                                        40.75%
             Trichloroethylene
                 6.33%
                                                                                             Dichloromethane
                                                                                                7.02%
                                                                                                Xylene/p-Xylene
                                                                                                   2.40/<
                   Lead/Lead Compounds
                        1.88%
                                                                  - 12
                                                                                                       iiiiiiiiiiii 111 in iiiiiiiiii i ipn 11 <| iji i|i ii||i|ii i i i||iiii|i
                                     !'!	I	
                                            33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION

-------
      Transfers Off-Site
       for Treatment/
       Disposal/Other
         61.29%
   Surface Water Discharge:
         0.06%
      Transfers to POTW
          0.37%
 Exhibits 7 and 8 show the percentage breakdown of 1994 releases and transfers of 33/50 chem-
 icals by chemical and by'release media, respectively. In addition, Exhibits 9 and 10 illustrate
 the Company's 33/50 Chemical reductions from 1988-1993, by chemical and release media,
 respectively. According to data provided by the company, Eaton achieved nearly 50,000 pounds
 of additional reductions in 1994, primarily due to the complete elimination of dichloromethane
 and further reductions in 1,1,1-tricriloroethane releases and transfers.

 Although not part of the 33/50 Program, Eaton has also made progress in reducing releases
 and transfers of TRI chemicals not targeted by the 33/50 Program. Releases and transfers
, of non-33/50 TRI chemicals have decreased 79% from 1-,116,731 pounds in" 1988 to 232,015
 pounds in 1993. The largest reductions in releases and transfers at Eaton occurred for acetone,
 copper, nitric acid, Freon-113, hydrochloric acid, and propylene, each of which decreased
 by more than 85%.

 FUTURE EFFORTS

        Despite Eaton's success in reducing the use of 33/50 chemicals, the Company
        continues to investigate other means of reducing its use of TRI chemicals.
        Eaton believes that since it has been successful in virtually eliminating the
 use of solvents in vapor degreasing and in paints, a remaining obstacle is the
 recovery of waste oil.  Recently, Eaton established,a closed loop oil recovery
 system at its Glascow, Kentucky facility which removes the water from the waste
, oil and purifies the oil. Additional projects in which the company is involved include:
  1,1,1-Trichlor.oethane
      31.67%.
   Trichloroethylene
      20.78% ^
    Xylene
    2.39%
 Tetrachloroethylene
    . 5.89%

Nickel/Nickel Compounds
     9.50%

    Dichloromethane 2.44%
                                                    .Chromium/Chromium
                                                       Compounds
                                                        19.61%
                                                                                    Exhibit 8
Percentage Breakdown
0/33/50 Program    '
Chemical Releases and
Transfers for 1993
(by Media)
                        Despite Eaton's
                        success in reducing
                        the use of 33/50
                        chemicals, the
                        Company continues
                        to investigate
                        other means of
                        reducing its use of
                        TRI chemicals.
                                                                                   Exhibit 9
                        Contribution of
                        Reductions of each
                        Chemical to Total
                        Reductions
                                     13
            33/50 PROGRAM COMPANY PROFILE: EATON CORPORATION

-------
                                            1^^
                                            	I		1		II	i!	i'i	"
!	!!	I!	!	I	\	!	I	!	l	II	1
'" !'('"	!	    ' (ft1	"-'"',:'-%  "
!ii"S l.'H !'	I'"'      "f!y ':   ''>>  'I,?!?'!"  	
                                 Total industrial water (non sanitary) reuse through reverse osmosis.
                               ft  Development of advanced oxidative techniques for the reduction of biological oxygen
                             jjj-ja-jj  demand (BOD) and'cliemical oxygen 3eman3 (COD) in waste WafeE For example,
  ^Z	gfjjh^ggmpany's Henderson, Kentucky facility, a nanofiltration system (with a 250
       molecular weight cutoff) to purify th"e water will Be operational by July 1995.
       Emulsion failure study to investigate the emulsion degradation by contact by zinc
       dialkyl dithiophosphate (ZDDP). (2DBP is a common ingredient in hydraulic
       oils, used in industrial manufacturing operations.)
      Elimination of lead in brass compounds through the use of different alloying
  II  ,       |  ,J|  ,      	I	                    L  I    ,'
       compounds.
                 i                        i       11      i |  |
  CJONTACT FOR  FURTHER  INFORMATION
                            For additional information on this case study please contact:
                               Steve Schachameyer
                               Senior Technology Leader   [
                               Eaton Corporation
                               Corporate Research and Development
                               4201 North 27th Street
                               Milwaukee, WI53216
                               Tel: (414) 449-6917
                               Fax:(414)449-7519
                               Chris Teeley
                               Chemical Engineer
                               Corporate Environmental Engineering
                               Eaton Corporation
                               32500 Chardon Road
                               Willoughby Hills, OH 44094
                               Tel: (216) 523-6785
                               Fax: (216) 523-6784
                                            John Burke
                                            Manager,
                                            Corporate Environmental
                                            Engineering
                                            Eaton Corporation
                                            32500 Chardon Road
                                            Willoughby Hills, OH 44094
                                            Tel: (216) 523-6775
                                            Fax:(216)523-6784

                                         33/50 PROGRAM COMPANY PROFILE: EATON
                                                                                    ,   ,

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