PARTS WASHING ALTERNATIVES STUDY
       UNITED STATES COAST GUARD
                    !by
              Brad Montgomery
Lockheed Environmental Systems and Technologies
           980 Kelly  jJohnson Drive
           Las Vegas,: Nevada 89119
        EPA Contract No. 68-C4-0020
     Pollution Prevention  Research Support
           Work Assignment  0-03
               Project Officer
              James IS. Bridges
     Pollution Prevention Research Branch
     U.S. Environmental Protection Agency
     Risk Reduction Engineering Laboratory
           Cincinnati!  Ohio 45268

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                                    DISCLAIMER
       The information in this document has been funded by the United States Environmental
Protection Agency under Contract No. 68-C4-0020 to Lockheed Environmental Systems and
Technologies company.  It has been subjected to the Agency's peer and administrative review, and
it has been approved for publication as an EPA document.  Mention of trade names or commercial
products does not constitute endorsement or recommendation for use.
                                           11

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                                        ABSTRACT
       This report has been written to assist the United States Coast Guard (USCG) industrial
managers in determining the most cost effective and environmentally acceptable parts washing
alternatives for their specific applications.  An; evaluation was conducted on four different
cleaners from  three different Coast Guard facijities to determine economic and environmental
impacts for the parts washing applications. This evaluation considered only USCG related
impacts, with the  USCG facilities as the analysis boundary.  The three facilities chosen for the
study were Aviation Training Center (ATC), Mobile, Alabama; Air Station Cape Cod (ASCC),
Falmouth, Massachusetts; and Support Center Slew York (SCNY), Governors Island, New York.
ATC and ASCC parts washing applications focused on cleaning contaminated parts from aviation
operations; SCNY parts washing applications were directed at cleaning contaminated parts from
seafaring vessels. The evaluation of alternative parts cleaners included the following categories:
process description; environmental, safety and; health impacts; cost  analysis; and the material
and emission reduction opportunities.  The methodology used in this study can be employed to
complete evaluations on other parts cleaners. [The following parts  cleaners were evaluated; Bio
Seven,  Penatohe  724, Safety-Kleen 105, and prulin 815 GD. All  four cleaners are  effective
cleaners for the specific applications described in this evaluation.  Bio Seven is an on-site
recycled aqueous parts cleaner that has minimal apparent health effects and is currently being
tested to qualify to military specifications.  Penatone 724 is a non-recycled petroleum distillate
that meets the military classification of a PD 680 type II parts cleaner but possess potential
personnel and environmental concerns. Safety-Kleen  105 is  a full service  recycled petroleum
solvent; but has potential long term hazardous; waste liability concerns.  Brulin 815 GD has
apparent minimal  health and environmental concerns, but must be heated to  140°F - 160°F  for
effective cleaning.                           j

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INTENTIONALLY LEFT BLANK
           IV

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                                     CONTENTS
                                        |   •• .                                   Page

DISCLAIMER  	1	      ii
ABSTRACT    	1	      i i i
ACKNOWLEDGEMENTS	i	    viii
INTRODUCTION	[	      1
APPROACH	|	      2
   LCA Procedure for Parts Cleaning    	j	      2
          Background	i	"..'	      2
          Procedure	i	      4
PARTS  CLEANING ASSESSMENTS	i	      1 6
ATC-MOBILE, ALABAMA  	.....j.......	     1 8
   Bio Seven
          Process  Description	I	     1 8
          Environmental, Safety and Health Isjsues	     1 9
          Cost Analysis  	1.......J	,	     1 9
          Material and Emission Reduction Opportunities	     20
          Conclusions	     2 0
   Penatone 724                         j
          Process  Description	!	     30
          Environmental, Safety and Health Issues	     3 1
          Cost Analysis  	.....i	     32
          Material and Emission Reduction Opportunities	.„..     32
          Conclusions   	i	,	     32
AIR STATION CAPE COD, MASSACHUSETTS..-!	     4 2
   Safety-Kleen                •      .    i
          Process  Description  	I	     42
          Environmental, Safety and Health issues	     43
          Cost Analysis	I	     44
          Material and Emission Reduction Opportunities	     44
          Conclusions   	:	     4 4
SUPPORT CENTER NEW YORK-GOVERNORS ISLAND, NEW YORK	     55
   Brulin 815 GD                        !
          Process  Description  	j	     5 5
          Environmental, Safety and Health Issues	     56
          Cost Analysis	...I	     56
          Material and Emission Reduction Opportunities	     57
          Conclusions   	i	     5 7
REFERENCES	I	'„	     70

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                                   WORKSHEETS

Number                                                                      .Page

   1  Parts Washing Process Description  	       5
   2  Flow Diagram for Parts Cleaners	       6
   3  Material Balance Sheet   	       8
   4  Cost Analysis for Cleaners	      1 0
   5  Option Generation    	      1 1
   6  Option  Description   	      12
   7  Option Cost Evaluation	      1 4
   8  Option  Evaluation	      1 5

Bio Seven
   BI-1   Parts Washing Process Description 	      21
   BI-2   Flow Diagram for Parts Cleaners	      22
   BI-3   Material Balance Sheet   	      23
   BI-4   Calculations  	      24
   BI-5   Cost Analysis for Cleaners   	      26
   BI-6   Option Generation     	      27
   BI-7   Option Description	;	      28
   BI-8   Option Evaluation 	      29

Penatone 724
   PE-1   Parts Washing Process Description 	      33
   PE-2  Flow Diagram for Parts Cleaners	      34
   PE-3  Material Balance Sheet	      35
   PE-4  Calculations  	      36
   PE-5  Cost Analysis for Cleaners   	      38
   PE-6  Option Generation	      39
   PE-7  Option Description    	      40
   PE-8  Option Evaluation 	      41

Safety-Kleen 105
   SK-1   Parts Washing Process Description 	     46
   SK-2  Flow Diagram for Parts Cleaners	     47
   SK-3  Material Balance Sheet   	     48
   SK-4  Calculations	     49
   SK-5  Cost Analysis for Cleaners   	     51
   SK-6  Option Generation     	     52
   SK-7  Option Description    	     53
   SK-8  Option Evaluation 	     54
                                         VI

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                            WORKSHEETS  (continued)
                                       ]          . •    '
Number                               i                                       Page
Brulin 815 GD                          |
   BR-1 Parts Washing Process Description	     58
   BR-2 Flow Diagram for Parts Cleaners..:	     59
   BR-3 Material Balance Sheet  	I	     60
   BR-4 Calculations	j.	     61
   BR-5 Cost Analysis for Cleaners    	j.	     66
   BR-6 Option Generation    	I	     67
   BR-7 Option  Description   	1	     68
   BR-8 Option  Evaluation	L...	     69
                                     TABLES
                                       |     '          '...'",'."
Number                                                                      P
   1     Chemical Type and Application   ..;	.....      1
   2     Cleaner Category and Usage   	I..	     16
   3     Penatone 724 Regulatory Requirements 	     31
   4     Safety Kleen 105 Regulatory Requirements 	,.......„-.     43
                                       1 vn

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                                ACKNOWLEDGEMENTS
   The authors wish to acknowledge the help and cooperation provided by Lieutenant Commander
Michele Fitzpatrick, Chief Warrant Officer Robert Siggins, Bob Cannon, Chief Warrant Officer
Frank Libby, and Aviation Machinist Mate Chief Ric Peri of the United States Coast Guard. The
authors also wish to recognize James Bridges, EPA Work Assignment Manager, for his guidance  in
completing this project.

   This report was prepared for EPA's Pollution Prevention Research Branch by Brad
Montgomery, Lockheed Environmental Systems and Technologies, Co., for the  U.S. Environmental
Protection Agency under Contract No. 68-C4-0020.
                                          viii

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                                     INTRODUCTION
   An evaluation was conducted on techniques and chemicals used to clean parts at Coast Guard
facilities located at the Aviation Training Center (ATC), Mobile, Alabama; Air Station Cape Cod
(ASCC)., Falmouth, Massachusetts; and Support Center New York (SCNY), Governors Island, New
York. The objective of this evaluation was to provide decision-making guidance for the United
States Coast Guard industrial managers to choose cost effective parts cleaning chemicals that have
minimum environmental and safety impacts. The alternative chemicals  evaluated were
categorized for each location:                {
                       TABLE 1.   CHEMICAL TYPE AND APPLICATION
CHEMICAL
Bio Seven
Penatone 724
Safety-Kleen 105
Brulin 815 GD
LOCATION !
ATC '
l
ATC !
ASCC |
SCNY !
j
CATEGORY
On-Site Recycle, Aqueous - Mild
Non-Recycle, Petroleum Distillate
Full Service Recycle, Petroleum Solvent
Non-Recycle, Aqueous Alkaline
   The evaluation includes a limited inventory analysis, impact analysis, improvement analysis,
and cost analysis for each alternative. The inyentory analysis identifies and quantifies energy,
process material requirements, atmospheric emissions, waterborne emissions, solid and
hazardous waste, and other releases from the parts cleaning process.  The impact analysis
addresses environmental and human health impacts from the use of the parts cleaners.  The
improvement analysis introduced opportunities to reduce environmental  releases, energy
consumption and material use in the parts cleaning process. A cost analysis of the cleaning
alternative evaluated provides a financial descriptive report that can aid in cleaner selection.

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                                       APPROACH


PROCEDURE FOR EVALUATING USCG PARTS WASHING ALTERNATIVES

A. BACKGROUND

    A system evaluation is a too! for identifying the environmental burdens and evaluating the
associated impacts caused by a product, process, or service. The decision to perform a system
evaluation  usually is based on the following objectives:

    •   Establish a baseline of information on a system's overall resource use, energy
       consumption, and environmental impacts

    •   identify stages within the process where a reduction in resource use and
       emissions might be achieved

    •   Compare the system inputs and outputs associated with alternative products,
       processes,  or  activities

    •   Guide the development of new activities, processes, or products toward a net reduction of
       resource requirements and emissions

    A system evaluation  should provide independent determinations  of environmental arid
economic impacts for each product, process, or service evaluated. The level of that
determination will be dependent on available information and desired results.  A basic system
evaluation should include:

       Process Description: Identification and quantification  of energy and resource use and
       environmental  releases to air, water, and land.

       Environmental, Safety and Health Issues: Characterization and assessment of the
       environmental  impacts.

       Material and Emission Reduction Opportunities and Cost Analysis: The evaluation of
       opportunities to reduce environmental and economic burdens.

    The process description begins with a conceptual goal definition phase to define both the
purposes for performing the evaluation and the scope of the analysis. An inventory procedure is
then employed and data are gathered.  The data are incorporated into a model to determine the
environmental, safety and health impacts and to assist in the cost analysis. Finally,  results are
analyzed to determine improvements that  will reduce material usage, environmental burdens
and the associated cost.
                                                                                                     ,

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   The main focus of the USCG parts washing alternatives study was to develop a procedure for
assessing and comparing parts cleaners. This was accomplished by evaluating the chemical
cleaners selected by the USCG and detailing the method used to obtain the operating practices and
cost for each.                               I

   The first step in initiating the  study is  to identify the evaluation team.  It is  imperative that
the goals, scope, and all assumptions inherent Jin the evaluation be clear to the participants. The
evaluation team should  have technical knowledge of the process, as well as knowledge of the
current production operations and the personnel  involved.  Team members for this evaluation
included engineers, machinists, technicians, repair maintenance personnel, knowledgeable
department personnel such  as production  opefator(s), and  material experts.

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B. PROCEDURE

   The following outline was used to collect the information for the evaluation of the parts
washing alternatives.  The outline is presented in a format that allows for further evaluations to
be conducted on other parts washing processes and is divided into the following sections: process
description; environmental, safety and health; cost analysis;  material and emission reduction;
and conclusion.

PROCESS DESCRIPTION:

   The main elements of the process description are the process location, summary of
operations performed, equipment, process controls, products, input materials, and the waste
streams affected.

   Preliminary information for the parts washing process is developed using worksheet  1.
Information on the process location should include:

       •   Geographical location of the Facility or Base
           Principal function  of the Facility or Base
       •   Duties performed at the Facility or  Base
           Location of the Parts Cleaning Stations within the  Facility or Base

   Obtaining information on the parts washing station  will allow the evaluation team to assess
possible state or local regulatory concerns, understand  the needs of the process technician, and
define the process boundary.  The process boundary should be based on the objective of the
evaluation.  The boundary may be established  around the parts washing station, or the boundary
could extend to the building where parts washing is conducted, or the USCG facility.

   The process description should include a chronological sequence of the parts washing process
that begins from the time the contaminated parts come into the washing station until the clean
parts  leave the washing station.  A detailed description of the cleaning procedure used by the
technician will be important in identifying potential areas for operation improvements.  The
"product"  in this evaluation is the cleaned part.

   After the completion of worksheet 1, a  process flow  diagram should be developed. The flow
diagram should track  all input and output materials from the time they enter the process
boundary  until they leave.  A sample flow diagram is shown in worksheet 2 for the parts
washing process.

   Inputs should include the  cleaner for the station and all physical factors that go into the
cleaning of the part.  Some of these factors are the energy to heat the solution, personal
protective equipment, dilution materials,  rinses, wipe down  material, air drying, etc.

   Outputs are the direct result of the inputs.  Outputs should be divided into separate groups.
These groups could include air emissions  released through the process, liquid effluent and solid
waste that cross the designated  boundary, personal protective equipment (i.e., gloves, face

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               Parts Washing Process
               Preliminary Information
Location:
Process Boundary:
Process  Description:
 Product of Process:
            Worksheet 1.    Parts Washing Process Description


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shields, respirators, etc.) used to complete the task, recycled material(s), and the product.
                                           |                -
    After the flow diagram has been developed! a material balance can be tabulated. Worksheet 3
is an example of a tabular material balance ofjthe inputs and outputs for all streams associated
with the parts washing process. The first step! in developing a material balance is determining a
"basis" to be  used, which is a unit of measurejto ensure equal comparison of alternatives. A
basis may be a period of time, or a given mass of material associated with the process.  In the
selection of a basis, it is important to consider! the material being processed, the questions to be
answered from the evaluation, and the type an|d quality of available data.

    The annual mass of parts decontaminated was used for the basis in the USCG parts washing
evaluation. The material balance is a summation of the total quantity of input material to a
process and the output to the environment, another process, or conversion into product.  The
total inputs should equal the total outputs for the process.

ENVIRONMENTAL. SAFETY AND HEALTH IMPACTS:
    After completing the description of the patfs washing process, it is important to evaluate the
potential environmental, safety and health (ES,H) impacts, and associated regulatory
requirements of the chemical cleaner.        >

    A good source of information regarding the jESH impacts in using the cleaner can be found on
the material safety data sheet (MSDS). The MSDS details hazardous ingredients contained in the
cleaning solutions, flammability/combustibility,  corrosiveness,  exposure limits,  required
protective equipment, and other factors that must be addressed when using the cleaner.

    The state and local regulatory requirements should be verified with appropriate  agency
offices.   State regulatory requirements as a  nriinimum must conform to federal regulations, but
can be more restrictive. Typical areas to che6k for increased state requirements include:
                                           i _          .         .
       • •  Definitions of a hazardous waste   !
       •   Requirements for manifesting before  shipment
           Allowable emission rates or effluenjt discharges for the process
           Permitting  requirements for emissions to the various media (air,
           water, and soil)                  j
                                           i     -  -       .   ...',-..'.  ......
    Each state has its own guidelines that detail the requirements necessary to maintain
regulatory compliance.  These guidelines could include provisions to obtain an operating permit
for the cleaning station. The MSDS may  also contain some possible federal and state regulatory
requirements for  using the cleaner.

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TOTAL RELEASES (Units: Ibs

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Material
Description
TOTAL

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COST ANALYSIS:                            I
                                    - •   5   I      >•  'i-     '.-•'-.              -
   With the quantified numbers from the material balance and ESH impacts identified, a cost
for using the cleaner can be determined.  In worksheet 4, the cost analysis is divided into the
following sections:                          '

              •  Material Acquisition - The  actual chemical purchases  and any initial start-up
                 cost should be included. The costs for these acquisitions are typically derived
                 from purchase records or  receipts.

              •  Identify and Quantify Inputs land Outputs - Items from the material balance
                 should be addressed.  Include energy usage and water consumption.  Certain
                 items (i.e., parts, air emissions, etc.) may not have a cost factor.

              •  ESH Impacts - Include the  cost for  personal protective  equipment, sewer
                 discharge costs, operating  permits, physical examinations," etc.

If assumptions or calculations were used in the! cost analysis, the documentation should be
attached to the  worksheet.  For aqueous cleaners a sewer discharge cost would normally be
accounted for in the cost section.  In this evaluation we were unable to obtain direct sewage cost
and found that most sewage cost were incorporated into the price of the water.

MATERIAL AND EMISSION REDUCTION OPPORTUNITIES:

   A diagramming tool for option identification  helps generate pollution prevention ideas.  It is
useful to  conduct a brainstorming  session with people who know the parts washing process to
group ideas under similar pollution prevention!categories.  It also ensures that all pollution
prevention categories are considered.  Worksheet 5 is a diagraming tool for option generation
that list the six  primary categories to consider, j The categories  may change according Jo specific
requirements.                              j
                                           |     .   ,      ...,...,.

   After  pollution prevention options have been generated, the options are described in
worksheet 6.   Multiple pollution prevention options may be  identified  in a successful
evaluation. At  this point, it is necessary  to identify those options that offer real potential to
minimize waste and reduce costs. Since detailed evaluation of technical and economic feasibility
is usually costly, the  proposed options should be screened to identify those that deserve further
evaluation. The screening process serves to eliminate suggested options that appear marginal,
impractical, or  inferior without a  detailed andjmore costly feasibility  study.
                                           .!
                                           ' \
   The preliminary screening procedure  should consider the following questions:
                                           i
          Is implementation of the option cost effective?
       •   What is the principal benefit of the' option?
          What is the expected change in the type or amount of waste generated?
          Does it use existing technology?   j
       •   What kind of development effort is 'required?
       •   Will  implementation be constrained  by time?

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            COST ANALYSIS FOR CHEMICAL CLEANERS
DESCRIPTION
COST PER UNIT
TOTALCOST
Material Acquisition START-UP RECURRING
















Identify and Quantify Inputs and Outputs




































ESH Impacts









•-






Total Start-Up Cost
Total Annual Recurring Cost


                 Worksheet 4.   Cost Analysis for Cleaners
                                 10

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                 Material  and Emission Reduction
                           Option  Description
Option Name and Description
(Include input materials and products affected)
Option No.
Consider:    ° Yes
                                                                No
       Practices & Procedures D
         Material Substitution D
    New Product &/or Process D
      Waste Segregation/Hazard Reduction D
                 Equipment Modification D
          Recycling, Reuse, & Reclamation n
 Option  No.
Consider:    O  Yes   O NO
       Practices & Procedures rj
         Material Substitution rj
     New Product &/or Process
       Waste Segregation/Hazard Reduction rj
                  Equipment Modification rj
           Recycling, Reuse, & Reclamation p
Option  No.
Consider:    O Yes
                        No
       Practices & Procedures  n
         Material Substitution  p
    New Product &/or Process  rj
       Waste Segregation/Hazard Reduction
                  Equipment Modification
          Recycling, Reuse, & Reclamation
                          Worksheet 6.     Option Description
                                         12

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       •   Does the option have a dependablejperformance record?
       •   Will the  option affect product, employee health, or safety?
       •   What are the upstream or downstream  impacts if implemented?
                                           i      -               -
The results of the screening process will be ajlist of options that are candidates for more
detailed technical and economic evaluations,   i
                                           i               '

   Cost evaluation of the pollution prevention options  identified in worksheet 6 is  listed in
worksheet 7.  The cost evaluation is beyond the scope of this study, but is presented to provide a
method to compare and contrast the pollution prevention options.  The three major cost
categories  in  worksheet  7 are: Implementation'Costs, Incremental Operating Costs, and
Incremental Intangible Costs.                j

   An evaluation of the options considered is most easily accomplished and documented by using
a simple matrix for scoring and ranking.  Thej evaluation matrix listed in worksheet 8 provides
a means to quantify the important criteria that:affect the parts washing process and is a quick
visual representation of the factors affecting  Various waste minimization and pollution
prevention  options.  These considerations include: economic viability, including capital cost,
operating cost, waste management cost and return on investment; change in the type or amount
of waste generated liability issues; technical feasibility; avoided costs; effect on product;
employee health and safety; permits, variances, and regulatory compliance; releases and
discharges  to all media; and implementation feasibility.  The options should be prioritized for
implementation based on  their ranking within!the matrix.  The rational for selection or
weighing of scores should be included.        j
                                           i
CONCLUSION:
           ,                                !     -          . •         '-'''.-
       The procedure used in developing, assessing and choosing a waste minimization and
pollution prevention option can be used to compare similar processes. A summarization of the
information  obtained from the worksheets should be presented in a brief report.  Decisions on
improvement  options should be based on the conclusions developed in the evaluation.  It is
important to attempt to gather all the data that can  affect the process and clearly summarize
recommendations.
                                           13

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Material and Emission Reduction
         Option Cost Evaluations
CATEGORY
Option No.

Option No.

Option No.
Implementation Costs
Purchased Equipment
Installation
Materials
Utility Connections
Engineering
Development
Start up / Training
Administrative
Other.
Other
Total Implement. Cost























































Incremental Operating Savings / (Costs)
Change in Raw Mat'ls
Change in Utilities
Change in Labor
Change in Disposal
Other
Other
Annual Operating
Savings / (Costs)



































Incremental Intangible Savings / (Costs)
Permits and Fees
Future Liabilities
Other
Other
Annual Intangible
Savings / (Costs)
TOTAL ANNUAL
SAVINGS/ (COSTS)
PAYBACK PERIOD



































   Worksheet 7.  Option Cost Evaluations
               14

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PARTS CLEANING  ASSESSMENTS
GENERAL FORMAT

    Four parts cleaners were chosen for the alternatives study.  The cleaners were selected from
three different Coast Guard facilities. The facilities chosen consisted of two aviation centers; ATC
Mobile, Alabama and ASCC Falmouth, Massachusetts, and one marine and ground support
facility; SCNY Governors Island, New York.  The different functions of the sites selected allowed
for a broad study of the alternative parts cleaners.

    Aviation cleaning requirements are different from those of a marine and ground support
facility.  Because of the complexities of an aircraft, it is necessary to divide aviation cleaning
into three  distinct categories.  Category one includes tires and wheels of the aircraft. Category
two includes engine components, and category three is general aviation equipment. A cleaner
must be qualified by the USCG within a specific category for aviation cleaning.

    The alternatives in the study include a full-service recycled cleaner  (Safety-Kleen  105),
an on-site recycled cleaner (Bio Seven), and two non-recycled cleaners (Penatone  724 and
Brulin 815 GD).  These cleaners were selected because of their high usage level and different
chemical constituents. Safety-Kleen 105 and Penatone 724 have been qualified by the  USCG to
military  specifications for parts cleaning in all  three aviation categories. Bio Seven is used to
clean category two and three aviation parts and is currently being tested to qualify to military
parts cleaning specifications.  Table 2 delineates these cleaners and classifies them by category
and usage.

                     TABLE 2.   CLEANER CATEGORY AND APPLICATION
CHEMICAL
Safety-Kleen 105
(SK)
Penatone 724
(PE)
Bio Seven
(Bl)
Brulin 815 GD
(BR)
CATEGORY
Full Service Recycle:
Petroleum Distillates
Non-Recycle:
Petroleum Distillates
On-Site Recycled:
Aqueous - Mild
Non-Recycle:
Aqueous - Alkaline
APPLICATION
Aviation:
Category one, two and three
Aviation:
Category one, two and three
Aviation:
Category two and three
Marine and Ground Support:
No restrictions
    This report presents each parts washing cleaner in a similar format.  This type of
information provides a consistent approach to studying the alternative cleaners and developing
comparison trends.  The format is  divided into two main sections: (1) a discussion and (2)
supporting documentation. The discussion provides a qualitative approach to analyzing the
alternative cleaners.  This  section presents: (1) the step-by-step procedure used in parts
                                           16

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cleaning, (2) environmental impacts or possible health and safety risks associated with the
cleaner, (3) identifiable costs associated with!using the cleaner, (4)  a material and emission
reduction opportunity assessment, and (5) summarized conclusion of the parts cleaning
process. The supporting documentation describes the parts cleaning activity in quantitative
terms and is comprised of a process description, process flow diagram, material balance,
calculations used to derive numerical data, cost analysis, and material and emission reduction
options for the process.            •      -    '
                                            i   •     .-••-••-.     - -    -     '  •      .
    Labor cost associated with the cleaning process is not presented in this report.  It was the
opinion of the review team that there were no; significant deviations in the amount of effort
expended on the task of cleaning the part; therefore,  this parameter would not be a deciding
factor for the selection of an alternative cleaner in this study.
                                            i                  '                  -
    Each of the four cleaners evaluated had different  applications, therefore a comparison of
total costs for the cleaners should be avoided.^ The total cost for a specific cleaner will vary
depending on the type and quantity of parts that are cleaned, geographical location, and facility
preferences.                                !
                                           117

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USCG AVIATION TRAINING CENTER
MOBILE,  ALABAMA
   The USCG Aviation Training Center is located at Bates Field, adjacent to the Mobile, Alabama
Municipal Airport.  The ATC was commissioned in 1966 to provide centralized comprehensive
training to USCG personnel in the operation of fixed wing and rotary wing aircraft. The facility
also  has fixed wing search and rescue responsibilities.  Five hundred personnel operate the
facility on a 24-hour basis.  Three types of aircraft  are maintained in  operation: the  Dauphin
Helicopter  (HH-65), the Jayhawk  Helicopter (HH-60), and the Falcon  Jet (HU-25).   Duties
performed include cleaning, maintenance and repair of structural, mechanical, and electrical
components, and rescue and survival gear.  There are approximately 20 aircraft operated at
this  facility.
                                                                     i
   The ATC has the capability to address the majority of repair needs  for each airframe design.
Each type of aircraft has its own maintenance and repair shop.  The engine repair shop facilities
are shared by multiple types of aircraft.

   The maintenance, repair and engine shop facilities have the capability to clean a wide
variety of aircraft and engine parts.  Bio Seven, a mild aqueous cleaner, and Penatone 724, a
petroleum distillate,  are routinely used in the parts  cleaning process at these facilities.
BIO SEVEN

PROCESS DESCRIPTION:

    The ATC has three separate parts cleaning stations using the cleaner Bio Seven.  Each station
contains a 55-gallon polyethylene parts washing tank that is designed to hold approximately 36
gallons of cleaning solution. These solutions are 50/50 mixtures of Bio Seven and potable
water.  The  cleaning solution is heated in the holding tank to the temperature range of 96°F to
104°F and is continuously recirculated as parts are being washed.  The contaminants that are
typically cleaned from the parts consist of grease, oil, dirt, and hydraulic fluid.  These
contaminants are removed from the parts by vigorous manual brushing. As the contaminants
are removed from the parts, they are washed away with the cleaning solution into the enclosed
section of the tank.  After cleaning, the parts are rinsed with clean potable water to remove any
residual cleaning solution.  Rinsing is done at a separate location, and rinsate is discharged to
the sewer. The parts cleaning procedure is complete when the technician dries the part with a
hand wipe cloth or disposable wipe towel.

    The contaminants separate from the cleaning solution in the holding tank due to density
differences.  Petroleum products float to the top of the cleaning solution where they can then be
easily removed. Dirt and other contaminants that are heavier than  water sink to the bottom  of
the holding tank.  In theory, the operator would not have to change out the cleaning solution since
the contaminants being cleaned from the parts are immiscible.  In practice,  the contaminants


                                            18

-------
may dissolve in the cleaning solution or could >become entrained with the contaminants, reducing
the potential cleaning capability. Bio Seven has been used for 10 months and ATC maintenance
personnel indicate that the solution has maintained cleaning effectiveness and has not yet been
changed out.                                j
                                           i      ,       .   ""   -'"'.-.."
    The petroleum waste generated from the parts cleaning process is collected by a private
contractor. The contractor comes on site every month and extracts the waste from the three
stations.   Approximately one half of an inch (H/2 gallon) of petroleum contaminants are
removed from the cleaning solution at each station.  The contractor discharges the waste into a
holding tank located on-site, known as the oil bowser.  The waste is characterized as ignitable
hazardous waste  by RCRA regulations (40 CFR section 261.21).  This jgnitibility gives the
waste a high fuel value that can be used for heat recovery.  The ATC has an existing contract with
a hazardous waste disposal company for removal and incineration of waste fuels from the oil
bowser.  The waste is then shipped to a cemejit kiln were it is used as an alternative fuel source
for heat generation. The ATC receives 3 cents for  every gallon that is shipped off for fuel
burning.                                    |
ENVIRONMENTAL. SAFETY AND HEALTH ISSUES:
                                           |  -          •
    Bio Seven is a clear, free-flowing surfactant with a slight rose odor.  The material safety
data sheet (MSDS) for the solution does  not list any hazardous ingredients.  Bio Seven is
comparable  to petroleum-based solvents in cleaning versatility and possesses high  solubility in
water.  Bio Seven is biodegradable,  non-toxic and under normal use there are no apparent health
hazards.  It is non-flammable and will not support combustion.  In Alabama, hand wipe towels
with Bio Seven and contaminants are disposed jas a non-hazardous solid waste. The liquid
effluent  is discharged  to the sewer.           j

    There are no requirements in  the MSDS calling for personal protective equipment when the
Bio Seven solution is used.  However, the USGG requires that all technicians wear protective
gloves and eye glasses whenever they are engaged in the process of cleaning parts.
                                           i       .                      ..
                                           i                  • •      "       "        ..  '  r "
COST ANALYSIS:                            i
                                           i           .   ,        .              -
                                           i                 ,
    The  total  purchase cost for the three  Bio Seven cleaning stations at the ATC was $2,538
($846 each). Purchase  of the stations included the installation and start-up. Once the station
is purchased, it becomes the property of the purchaser.  Efforts are underway to qualify the Bio
Seven parts cleaning  process to a military specification.  A specification is important in  that it
informs a user that the chemical substance to b|e employed for a specific job has been found to be
satisfactory in its cleaning ability  and that the|re will be no harmful side  affects to the material
being cleaned.  Station ownership becomes a rpinor issue for the USCG in the event that the Bio
Seven does  not qualify with the military specifications  necessary to clean parts.  In the event
Bio Seven does not qualify, the tanks could us0 cleaners that have the necessary military
specifications for parts cleaning.      '       i  " '

    The  cost of the Bio Seven solution is $15 per gallon and is purchased in a 55-gallon drum at


                                           119

-------
a total cost of $825.  On average, the total annual electrical cost for heating the three wash
stations is estimated at $198. The water usage for the process consists of general washing,
rinsing the part, and makeup for the working solution.  The cost of the annual water usage for
the three stations is less than $100.  Annual contract cost for the monthly removal of
petroleum contaminants is $1440.

    Another incurred cost is  the purchase of personal protective equipment.  The approximate
annual cost for the gloves and eye protection for the three stations is $241.
MATERIAL AND EMISSION REDUCTION OPPORTUNITIES:

   The annual loss of the cleaning solution is about 25%, primarily due to "drag-out" and
evaporation.  Drag-out is the liquid residual on the part after it has been removed from the
cleaning station.  The water and cleaning solution from the rinsing process could be captured
and utilized as make-up for the losses incurred by drag out and evaporation.
CONCLUSIONS:

   The ATC is presently using Bio Seven as a test solution for cleaning engine components and
general aviation parts.  Bio Seven is designated as a test solution because at the time of this
report it does not have a military specification.  Plans are in progress to classify the cleaner as
a Navy soap.  This classification would qualify the cleaner to the Mil-C-85570, type II
specification when approval has been granted.

   One concern with the use of Bio Seven is the potential to cause hydrogen embrittlement.
Hydrogen embrittlement is the degradation of high strength steels, such as aluminum and
magnesium, that are used as bearings and bolts on aircraft wheels.

   Bio Seven is a viable cleaner for aviation parts cleaning  categories two and  three (engine
components and general aviation equipment). Bio Seven should not be used to clean category one
(tires and wheels) aviation  parts until its  potential to cause hydrogen embrittlement has been
determined.
                                            20

-------
                            BIO  SEVEN
                   Preliminary  information
 Location:                           j
   USCG Aviation Training Center (ATC),| Mobile, Alabama. There are
approximately twenty fixed wing and rotary wing aircraft that include; HH-65, HU-25.
Each of the aircraft has its own maintenance and repair shop facilities.
                                   •  !  '   ' -'          .    "           -
                                     f  -                      '-
 Process  Boundary:                 i
                                     J  -           :      i    . .
   The system boundary for the evaluation was established around the parts
washer.                              I
 Process  Description:

   The ATC has three separate parts cleaning stations using the cleaner Bio Seven.
Each station contains a 55-gallon polyethylene parts washing tank that is designed
to hold approximately 36 gallons of cleaning solution. These  solutions are 50/50
mixtures of Bio Seven and potable water.: The cleaning solution is heated in the
holding tank to the temperature range of 96 °F to 104 °F and is continuously
recirculated as parts are being washed, the contaminants that are typically cleaned
from the parts consist of grease, oil, dirt, atid hydraulic fluid. These contaminants are
removed from the parts  by vigorous manual brushing. As the  contaminants are
removed from the parts, they are washed jaway with the cleaning solution into the
enclosed section of the tank. After cleaning, the parts are  rinsed with clean potable
water to remove any residual cleaning solution.  Rinsing is done at a separate
location, and rinsate is discharged to the siewer. The parts cleaning procedure is
complete when the technician dries the part with a hand cloth.
Product of Process:                 !
   Clean Aviation Parts (Category two and three)
                                     t       ..  ..
             Worksheet BI-1.    Parts Washing Process Description


                                     j2i

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BIO SEVEN  -      SUPPORTING CALCULATIONS
Calculations for the annual liquid and air emissions from the Bio Seven parts washing process:


       1.  Approximately  0.25 inch petroleum waste level accumulation every month for each
          cleaning station

          (0.25  inch/month) * (12 months/year) = 3  inches per year


          (3  parts washing stations) * (3 inches/year) = 9 inches per year


2.     Determine the volume:
                                        Drum  Area = nr*  = n(0.75 feet)2 = 1.767 ft2
                    I- 1.5 ft. - I

       Volume  = (0.75 ft)  *  (1.767 ft2) = 1.33 fts

       Volume  = (1.33 ft3) * (7.48 gallons/ft3) = 9.9 gallons « 10 gallons


       3.  Specific gravity for the petroleum waste is 0.85

       (10  gal.) * (0.85 sp. gr.)  * (8.34 pounds/gal.) = 70.89 = 71  pounds  (sent to  oil
          bowser)

       4.  Based on operational information, 2 pounds of contaminants are entrained
          in the hand wipe towels



Total Contaminants per year = (71 + 2)  pounds = 73  pounds
                                          24

-------
Air emissions are the results of two processes: (1) Make-up for the Bio Seven parts washing

solution, and (2) the rinsing of the part after using the Bio Seven parts washing solution.
                                          !       -           -

The following breakdown of air emissions is based on information obtained from the operators at
ATC.                                .      j     •-..-.
      .(1) Make-Up for the Parts Cleaner duq to drag-out and evaporation losses:
                                          i
                                          i
                                          i...
                                          i                       .

          Bio Seven Air Emissions = 25% of the annual usage


              488 Ibs * 0.25 = 122 Ibs air emissions
                                          i
                                          i
                                          i  .  " •   .       .    •
          Water  air emissions =  40%       j
                                          i       •        '  '
                                          !'••'•     • '  •            '
              688 Ibs * 0.40 = 275 Ibs air Emissions

                    '                      i         .
                                          I,    • - ,   .           ..  -    ; .

       (2) Rinse  Water evaporation         |

                                          !
          Water  air emissions =  0.06%     '

                                          i             :
              (30,034  -  275) *  0.06 =  1895  Ibs
                                          125"

-------
                    COST ANALYSIS FOR CHEMICAL CLEANERS
                                       BIO SEVEN
  DESCRIPTION

Material Acquisition
  Cleaning Stations
  Bio - 7 Initial Acquisition
  Bio - 7 Annual Usage
COST PER UNFT
3 Stations at $846 each
488 pounds at $1.69 per pound
136 pounds per year Bio-7
    TOTAL COST
START-UP  RECURRING

  $2,538
    $825
               $225
Inputs and Outputs
  Energy
  Water Usage
  Parts Processed
  Recycled Cleaner
  Atmospheric Emissions
  Liquid Effluent
      Petroleum Contaminants
  Solid Waste
     Hand Wipe Towels
      Petroleum Contaminants
  Contract Cost
2640 kWh @ $0.075/KWH for Mobile, Alabama
3,600 gallons ($0.03/gallon)
300 pounds per year
802 pounds per year
2,290 pounds per year* (no permit required)

10 gallons  (71 Ibs) per year sold at $0.03/gal.

200 pounds per year (Non-Hazardous)
2 pounds per year (trapped in the towel)
$120 per month
  * Calculated from make-up requirements
Ecological and Human
Health/Safety Impacts
  PPE (Gloves)
  PPE (Eye ware)
  Special Precautions
500 pairs per year (50 pounds/year)
12 pairs per year (2.5 pounds/year)
N/A
               $198
               $100
                 N/A
                 N/A
                 N/A

             (-$0.30)

               $400
                 N/A
             $1,440
               $140
                $20
                 N/A
  Total  Start-Up Cost
  Total  Annual  Recurring Cost
  Start-Up Cost per Cleaning Station
  Annual Recurring Cost per Cleaning Station
                         Worksheet Bl - 4.
                                           $3,363

                                           $1,121
             $2,523

               $841
               Cost Analysis for Cleaners
               26

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                                BIO SEVEN
                  Material  and Emission Reduction
                           Option Description
Option Name  and  Description
(Include input materials and products affected)

Option No.    ONE                     Consider:    * Yes   ° No
 Insert a filtration system into the existing cleaning unit to remove the heavier
 contaminants, i.e. dirt.

       Practices & Procedures D                   Waste Segregation/Hazard Reduction
        Material Substitution Q                              Equipment Modification
    New Product &/or Process D                       Recycling, Reuse, & Reclamation
Option No.      TWO                   Consider:    • Yes   O No

 Capture effluent loses in drag-out using a recovery system. Return the drag-out to
 the cleaning system to serve as make-up.

       Practices & Procedures rj                    Waste Segregation/Hazard Reduction rj
        Material Substitution rj                               Equipment Modification rj
    New Product &/or Process n                        Recycling, Reuse, & Reclamation •
                     Worksheet BI-6.     Option Description


                                      28

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PENATONE  724
PROCESS DESCRIPTION:

    Penatone 724 is currently being  used in two separate parts cleaning processes.  The first
process uses Penatone 724 in an aerosol canister to spot clean various contaminated parts; the
second process is the complete immersion or saturation of the contaminated part with the
cleaning  solvent. Approximately 80  percent of the Penatone 724 is in the immersion and
saturation procedure with the remaining 20 percent  used for aerosol  cleaning.  Typical
contaminants that are cleaned from  the parts consist of grease, oil, dirt, and hydraulic fluid.
The Penatone 724 is distributed from a single  location. This centralization allows for a
controlled chemical distribution and  less waste of the cleaning solvent.

    In the aerosol cleaning process, an aerosol canister is filled with the cleaning solvent from
the distribution area.  The aerosol canister, known  as "Sure-Shot®", comes in two different
sizes, 32 ounce and 16 ounce. Once the aerosol  canister has been filled with the cleaning
solvent, it is then charged with compressed air that  has been filtered  to remove any paniculate
matter.  The portable canister allows cleaning while the parts are installed on aircraft or after
minor disassembly.  The cleaning solvent is sprayed directly on the contaminated part and then
wiped clean with a disposable hand wipe towel. The  aerosol canisters can be refilled and reused
indefinitely.  About 98 percent of the Penatone  724 used in the aerosol process evaporates and
becomes an air emission. The remainder is assumed to be mixed with the contaminants on the
hand wipe towels. These emission numbers are based on operator experience.

    In the immersion cleaning process, the contaminated part is completely immersed or
saturated with the Penatone 724.  Larger volumes of the cleaning solvent (1  to 2 gallons) are
placed into a container and then transported from the chemical distribution center to the
cleaning area.  The contaminated part is dipped into the container for complete immersion or the
cleaning solvent is cascaded over the part. The cleaned part is then dried with a hand wipe towel.
About 17 percent of the Penatone 724 is evaporated  or dragged out during the cleaning and
drying process.  A small amount (approximately 2 percent) is assumed to be mixed with the
contaminants on the wipe towel.

    There are two primary wastes that are generated when  using Penatone  724; hand wipe
towels and spent liquid waste. The used hand wipe towels are landfilled as a non-hazardous
waste.  Under the Federal Resource  Conservation and Recovery Act (RCRA)  laws and the State of
Alabama RCRA laws, the hand wipe towels do  not exhibit characteristics of a hazardous waste
(40 CFR Part 261, Subpart C). The towels would be a hazardous waste if saturated with the
solvent, but the towels normally do  not contain a significant quantity of the solvent  due to
operational practices and evaporation.  The second waste generated is the spent Penatone 724
from the cleaning process. The spent cleaning solvent containing the waste oils from aircraft
engines, gear boxes, and hydraulic  fluids is disposed of in the same holding tank (oil bowser) as
the petroleum waste from the Bio Seven process.

    Penatone 724 is classified as a combustible  (not flammable) liquid. The difference between


                                            30

-------
flammability and combustibility is temperature.  Flammable liquids have flash points below
100°F and combustible liquids flash pdints at lor above 1006F.  The flashpoint is simply the
temperature at which a liquid gives off vapors; that can be ignited under specified laboratory
conditions. The flashpoint of Penatone 724 is 160°F compared to the more flammable cleaner
methyl ethyl ketone (MEK), which has a flashpoint of 28°F.
ENVIRONMENTAL SAFETY AND HEALTH ISSUES:
              :  ,          .        ,        j:   -"." '..•-;  ;.-'    '   •'.' •  *.+,'..,   >•    . '•'•'-  V    ,  "•
    Penatone 724 is a clear water-white blend of aliphatic hydrocarbons (classified as 100%
volatile organic compounds) and is a combustible material.  Regulatory agencies respond two
these two conditions by requiring a system of warnings and controls.  The Occupational Safety
and Health Administration (OSHA) has classified the ingredients in Penatone 724 as a hazardous
combustible material.  Penatone 724 contains! no reportable Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) materials and  is considered non-hazardous
under RCRA.  In the Superfund Amendments and Reauthorization Act (SARA) Title III, sections
311 and 312, Penatone 724 is categorized as $n acute health and fire hazard and is not a
reportable chemical under section 313.      i                      '"•''...
                  TABLES.   PENATONE 724 REGULATORY REQUIREMENTS
   OSHA
   RCRA
   TSCA
   CERCLA
   SARA, Title III
    section 311, 312
    section 313
29 CFR 1910.1200;  Combustible Material
40 CFR 260,|Subpart D; Non-Hazardous Waste
Ingredients are listed on the inventory
Contains no jreportable  materials
            i  .
Hazard Categories: Acute Health, Fire
Contains no reportable  ingredients
The company recommends that the user of thi'$ product contact local authorities to determine if
there  may be other local reporting requirements.
                                          j ,   .  ,
   The exposure limits for the use of Penatone 724 have not been established by OSHA or any
other  regulatory agency.  The supplier recommends that an  exposure limit be set at 300  ppm
for an 8-hour timeframe. The volatility of the cleaning solvent requires personal protective
equipment (gloves, glasses, etc.) be utilized.  Small amounts of the liquid could be drawn into
the body by handling , inhalation, or swallowirjg resulting in  adverse health  effects. Solvent
resistant gloves are recommended  for situations in which prolonged skin exposure is expected.
Ventilation is not needed under normal use conditions.  For enclosed areas, or where large
amounts of the product are being used, the use of fans or other mechanical ventilation is
recommended.
                                          131

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COST ANALYSIS:

   The cost of the Penatone 724 solvent is $5.55 per gallon. ATC purchases one hundred
gallons of the cleaning solvent at a cost of $555 on an annual basis. The aerosol dispensing
canisters, "Sure Shot®", were a one time purchase for total cost of $1,390. This purchase
included twenty 16 oz aerosol canisters at $43 per canister and ten 32 oz aerosol  canisters at
$53  per canister.

   The cost of the hand wipe towels used to dry the parts is $1,200 annually.  This includes the
purchase and disposal of the towels.  Penatone 724 emissions released into the  atmosphere at the
ATC do not have an associated cost factor. ATC is paid 3 cents per gallon for the spent solvent.

   The total  annual cost for personal protective  equipment is approximately $268.  This cost
includes the purchase and disposal of solvent resistant gloves, eye protection,  and respirator
cartridges when necessary.
MATERIAL AND EMISSION REDUCTION OPPORTUNITIES:

    Penatone 724 contains volatile organic compounds (VOC) at a concentration level of 780
grams per liter of solution.  Because of the volatility of the cleaning compound, much of the
solution is lost through evaporation.  Alabama does not currently restrict the amount of VOCs
allowed to be dissipated into the environment from this type of cleaning process. States such as
California and New Jersey have regulations to reduce  VOC emissions such as: (1) best available
control technology (BACT) be implemented to control emissions or (2)  a  usage permit with fees
based on the amount of releases into the atmosphere.

    An alternative to the current immersion cleaning procedure  would be  to employ a parts
cleaning station for the cleaning solvent. The station would  be designed for the containment of
the solvent with a cover to reduce losses through evaporation.  The parts  cleaning station would
give the cleaning solvent a longer usage life and significantly reduce  environmental  releases.
CONCLUSIONS:

    Penatone 724  is qualified to PD 680 type II military specifications as a parts cleaner.
Penatone 724 can clean in all three aviation parts cleaning categories (engine components,
general aviation  equipment, and tires and wheels).

    Concerns about using the cleaning solvent focus on the potential environmental, safety and
health impacts.
                                           32

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                        PENATONE  724
                   Preliminary  Information
 Location:                          |
   USCG Aviation Training Center (ATC)j, Mobile, Alabama. There are
 approximately twenty fixed wing and rotafy wing aircraft that include; HH-65, HU-25.
 Each of the aircraft has its own maintenance and repair shop facilities.
                                    I..           .. ,,       ..... .    ......
                                    !             ...'..
 Process  Boundary:                j       •
   The system boundary was defined as two separate beginning points, one for the
 aerosol cleaner and the other for the immersion process, but both having the same
 ending point with the outputs contained wjithin the facility.
 Process  Description:              j
   Penatone 724 is currently being used in two separate processes. The first
process uses the cleaner in an aerosol canister to spot clean various contaminated
parts; the second cleaning process is thelcomplete immersion of the contaminated
parts in the cleaner.             .      j
                                    |     •  • -     :...-.......=-_.

   Typical contaminants consist of grease, oil, dirt, and hydraulic fluid

   The aerosol canister is filled with the cleaning solvent and the pressurized with
compressed air that has been filtered to remove paniculate. The cleaning solvent is
sprayed directly on the contaminated parts then wiped clean with a disposable
towel.  The canister can be reused after the solvent has been completely dissipated.

   In the immersion process the contaminated parts are completely immersed or
saturated with the cleaning solvent.  The bleaned part is dried using disposable
towels.                              !   .'
Product of Process:                '
   Clean Aviation Parts (All Categories)  ;
                                    |             .    -'
              Worksheet PE-1.     Parts!Washing Process Description
                                    I
                                    33

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CE FOR CHEMICAL CLEANERS
ENATONE 724
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-------
PENATONE  724    -      SUPPORTING CALCULATIONS
Based on 100 gallons of Penatone usage per year Calculate the chemical breakdown per media
i.e. air, land, and water:

1. Calculate  pounds (Ibs) per year:
       given: Specific Gravity of Penatone 724 =  0.78

   (100 gallons)  *  (0.78 Sp. Gr.)  * (8.34 Ibs/gallon) = 650.52  Ibs « 651  Ibs

2. Usage between aerosol and immersion process was obtained from maintenance personnel at
   ATC Mobile, Alabama

          Aerosol      =  (0.20)  * (651 Ibs)  =  130.2 Ibs
          Immersion    =  (0.80)  * (651 Ibs) =  520.8 Ibs
   Penatone 724 Annual Usage                  651  Ibs
3.  Air Emissions were based on operational experence

          Aerosol      =  (0.98) * (130.2 Ibs) =   127.6  Ibs
          Immersion   =  (0.15) * (520.8 Ibs) =   78.1 Ibs
    Penatone724 Annual Air Emissions              205.7  Ibs
4.  Liquid Effluent was based on operational experence

          Aerosol      =  (0.00) * (130.2 Ibs) =      0 Ibs
          Immersion   =  (0.83) * (520.8 Ibs) =   432.3  Ibs
    Penatone 724 Annual Liquid effluent             432.3  Ibs
                                          36

-------
5. Solid Waste was based on operational experence
                                         i
                              '    .     '!•••-
          Aerosol      =  (0.02) * (130.2 IDS)  =   2.6  Ibs
          Immersion   =  (0.02) * (520.8 jbs)  =   10.4 Ibs
   Penatone 724 Annual solid Waste        j         13 Ibs
                                         37

-------
                    COST ANALYSIS FOR CHEMICAL CLEANERS
                                    PENATONE 724
  DESCRIPTION
COST PER UNIT
    TOTAL COST
START-UP  RECURRING
Material Acquisition
  Penatone 724  Acquisition
  Penatone 724 Annual Usage
  Aerosol Canisters (reusable)
Ecological and Human
Health/Safety Impacts
  PPE (Gloves)
  PPE (Eye ware)
  PPE (Respirators)
651 pounds at $0.85 per pound
651 pounds at $0.85 per pound
twenty 16 oz at $43 per canister
ten 32 oz at $53 per canister
Input and Output
  Parts Processed
  Atmospheric Emissions
  Liquid Effluent
      Penatone 724
      Contaminants
  Solid Waste
     Hand Wipe Towels
      Penatone 724
      Contaminants
1,000 pounds per year
206 pounds per year (no permit required)

66 gallons (432 Ibs) per year sold at $0.03/gal.
21 gallons (142 Ibs) per year sold at $0.03/gal.

600 pounds per year (Non-Hazardous)
13 pounds per year (trapped in the towel)
8 pounds per year  (trapped in the towel)
700 pairs per year (70 pounds per year)
12 pairs per year (2.5 pounds per year)
Organic Vapor Cartridges (6 cartridges/year)
    $555

    $860
    $530
$555
  Total Start-Up Cost
  Total Annual Recurring Cost
                 N/A
                 N/A

             (-$1.98)
             (-$0.63)

             $1,200
                 N/A
                 N/A
               $200
                $20
                $48
                                           $1,945
                                                      $2,020
                         Worksheet PE - 4.    Cost Analysis for Cleaners
                                            38

-------
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                           PENATONE  724
                  Material and  Emission  Reduction
                           Option  Description
Option  Name and Description
(Include input materials and products affected)
Option  NO.    ONE                     Consider:    • Yes  O NO
Employ a parts washing station that would reduce losses of the solvent. The parts
cleaning station would give the cleaning solvent a longer usage life and significantly
reduce  environmental releases.
      Practices & Procedures D                    Waste Segregation/Hazard Reduction d
         Material Substitution D                              Equipment Modification •
    New Product &/or Process D                       Recycling, Reuse, & Reclamation p
Option No.     TWO                   Consider:    • Yes   O No
Switch to a more environmentally benign parts cleaning solvent
       Practices & Procedures rj                    Waste Segregation/Hazard Reduction rj
         Material Substitution |                              Equipment Modification rj
    New Product &/or Process pj                        Recycling, Reuse, & Reclamation pj
                     Worksheet PE-6.    Option Description
                                      40

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USCG AIR STATION
CAPE COD,  MASSACHUSETTS
   The USCG Air Station Cape Cod is part of a multi-service group located at the Otis Air Force
Base, Massachusetts.  The ASCC was established in 1970 and is blended within the confines of a
base that supports elements of the Air Force, National Guard, Army Reserve Units, and various
other Federal Agencies.

   The ASCC operates six Falcon Jets (HU-25) and four Jayhawk Helicopters (HH-60) out of
two large hangers.  The mission of the ASCC is to provide enforcement of the federal laws and
treaties upon the high seas and waters subject to the jurisdiction of the United States.  The ASCC
has the capabilities to  respond to medium range search and rescue missions, support short
range navigational aid, and provide surveillance in marine environmental protection.

   The ASCC has the capability to address the majority of repair needs for each airframe design
and ground support equipment. The maintenance, repair and engine shop facilities  have the
capability to clean  a wide variety of aircraft and engine parts.  Safety-Kleen  105 cleaning
solvent  is the predominant choice for the parts washing process.
SAFETY-KLEEN  105

PROCESS DESCRIPTION:

   The ASCC has five separate parts washing stations using the cleaner Safety-Kleen 105.
Three of the cleaning stations are located in the aircraft maintenance hanger, one cleaning
station is in the ground services equipment garage, and one cleaning station is located at the base
auto hobbies shop.

   Each parts washing station has approximately 30 gallons of the cleaning solvent in a holding
tank located below the parts washing basin.  The cleaning solvent is pumped from the holding
tank, through a discharge tube, onto the part, and drains back into the holding tank.  The
technician removes the contaminants by holding the part under the discharge tube and scrubbing
or rubbing the part with a brush or gloved hand. Typical contaminants consists of grease, oil,
dirt, and hydraulic fluid.  The contaminants drain into the holding tank along with the cleaning
solution.

   The part does not require any rinsing or further use of different chemicals to complete the
cleaning process.  The part is wiped down with a disposable hand towel or an absorbent cloth
material to remove traces of contaminants and solvent. The towels and cloths are disposed of by
the USCG in a designated 55 gallon container for waste rags. The State of Massachusetts
considers that the waste generated from this cleaning process is hazardous. This classification
includes the cleaning solvent and the towels or cloths that are used to remove the contaminants,


                                           42

-------
 requiring a hazardous waste manifest for disposal.
                                  -  • •    ,  t     ..,-,.. -^-
    ASCC has an existing contract with the Safety-Kleen Corporation for the parts cleaning
 stations. Safety-Kleen Corporation is responsible for the handling of the cleaning solvent  and
 the liquid waste resulting from the cleaning process.  They are also responsible for the
 maintenance of the cleaning stations,  which injcludes periodic checks of the operability of the
 station and the replenishing or complete exchange of the cleaning solvent.  Safety-Kleen comes
 on-site every ten weeks to meet the requirements of the contract.  A Safety-Kleen
 repersentative personnel complete the hazardous waste manifest and transfer the waste off the
 ASCC .facility to a Safety  Kleen recycling faciljty.
ENVIRONMENTAL. SAFETY AND HEALTH ISSUES:

    Safety-Kleen  105 is a clear-green liquid With a characteristic hydrocarbon odor.  The
chemical ingredients of this cleaning solvent include petroleum distillates, and trace quantities
of perchloroethylene (PCE) and 1,1,1-trichlor6ethane (TCA).  According to  the MSDS, Safety-
Kleen 105 is a combustible cleaner with a flash point of 105°F. The decomposition and
combustion  products of Safety-Kleen 105 may! be toxic. Safety-Kleen 105 vapors are heavier
than air and may travel great distances to ignition sources and flash back.  The material may be
sensitive to  static discharge, which  could result in fire  or explosion.
          - •     .   -    .              .   . -(''' '  .   : "-•••  .. • -. •:;.••.••••,-' ..   ".'   •'.    • •"  '  .'•
    Regulatory information states that the product poses the following physical and health
hazards as defined in 40 CFR Part 370:      '

                  Immediate (Acute) health hazard
                  Delayed (Chronic) health hazard
                  Fire hazard              !
                                          !

       Safety  Kleen  105 is subject to the requirements of section 311 and 312 of Title III of
the Superfund  Amendments and Reauthorizatipn Act (SARA) of 1986.  It is not subject to
requirements of Title III of SARA Section 313 because the PCE and TCA are  present in trace
quantities only.  Safety Kleen 105 is considered to be  a hazardous material in Massachusetts and
is not for sale or use in California.           !
                  TABLE 4.  SAFETY KLEEN jl 05 REGULATORY REQUIREMENTS
  OSHA

  TSCA

  CERCLA

  SARA, Title III

    section 311, 312

    section 313
29 CFR  1910.1200;  Combustible Material
Ingredients are listed on the inventory
Contains no importable materials
            i
            i
Hazard Categories: Acute Health, Fire
Contains  De Minimis amounts of PCE and TCA
                                           !43

-------
    Eye contact with liquid or exposure to vapors may cause mild to moderate irritation.  Skin
contact may cause  redness, dryness, cracking, burning, or dermatitis.  Inhalation or ingestion
may have central nervous system effects and cause nausea, vomiting, and in severe cases, death.

    Personal protective equipment should include gloves to prevent contact with skin and
chemical goggles.  The cleaning station should provide process enclosure or local ventilation to
maintain concentration of the vapor or mist below  applicable exposure limits.
COST ANALYSIS:

    The contract with Safety-Kleen Corporation is $4,000 per year.  The contract provides the
cleaning solvent, maintenance of the cleaning stations and disposal of the spent solvent.  A
separate cost is incurred for hand wipe towels, $400 per year for purchase and disposal.
Emissions released into the atmosphere from the use of  Safety-Kleen 105 do not result in a cost
at the ASCC because the emissions are not regulated by Massachusetts.

    Another cost associated with the use of this product  is the personal protective equipment;
glasses and gloves, which is approximately $340 per year for purchase and disposal.


MATERIAL AND EMISSION REDUCTION OPPORTUNITIES:

    Safety Kleen 105 has environmental and heath risks associated with usage.  Aqueous cleaners
could be a viable candidate for this cleaning operation based on the findings in this study. ASCC
should use the experience gained at ATC and SCNY to implement aqueous cleaners such as Bio
Seven  and Brulin 815 GD.

    Attempts by the technician should be  made to limit the  amount of splashing or spilling of the
cleaning solvent.  This can be  accomplished by allowing  the clean part to drip dry above the
parts washing basin  and using only enough Safety-Kleen 105 to  remove the contaminants for the
part.

    Efforts should be taken to  extend the operational life of Safety-Kleen 105.  By extending the
life of the solvent, ASCC can revise the existing contract with Safety Kleen Corporation to reduce
solvent change-out and decrease the annual cost for the  cleaning solvent. A review of parts
cleaned should be conducted to reduce the contaminant load on the solvent.
 CONCLUSIONS:

    Safety-Kleen  105 is qualified to clean all three aviation categories (engine components,
 general aviation equipment, and tires and wheels).

    Potential long-term liability  for the Coast Guard could result with continued use of this
 parts cleaner.  If Safety-Kleen  Corporation uses poor practices in the recycling process, under
 the Comprehensive Environmental ResponseTCompensation, and Liability Act (CERCLA), the


                                            44

-------
                                          I  .                                      -
United States Coast Guard could be responsible for paying any incurred cost to remediate the
resulting environmental contamination. Even though Safety Kleen Corporation completes the
hazardous waste manifests, USCG is on record for the purchase and generation of the solvent
waste.                                    •
                                          r      ''-'.- :
   The single source for the product and service, Safety-Kleen Corporation, could potentially
lead to product cost increases or product shortages.  If Safety-Kleen Corporation decides to stop
production, ASCC would incur the cost associated with accelerated replacement with a new
product.                                   '
                                          ;45

-------
                    SAFETY  KLEEN  105
                  Preliminary Information
Location:
The USCG Air Station Cape Cod (ASCC) is located at Otis Air National Guard Base,
Falmouth, Massachusetts. The ASCC operates six HU-25 Falcon jets and four
HH-60 Jayhawk helocopters.  The ASCC has the capabilities to respond to medium
range search and recue and provide law enforcement.
Process Boundary:
The boundary was established around the Safety Kleen parts washing station.
Process Description:
The ASCC has five separate parts washing stations using Safety Kleen 105. Each
station has approximately 30 gallons of the cleaning solvent in a holding tank
located below the parts washing basin. The non-heated cleaning solvent is
continuously recirculated via a pump into the parts washing basin when in
operation. The technician removes the contaminants (grease, oil, carbon, etc.) by
scrubbing or rubbing with a brush or gloved hand. The contaminants become
suspended in the solution.  The part is wiped down with disposable towels or
absorbant cloth material.
Product of Process:
   Clean Aviation Parts (All Categories)
              Worksheet SK-1.    Parts Washing Process Description
                                  46

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-------
SAFETY-KLEEN  105
SUPPORTING  CALCULATIONS
Calculations for Safety-Kleen 105 based on information from Hazardous Waste Manifests
                                          i
Known:                                   I
          (1 )   Amount of Safety-Kleen 105 manifested  = 4381 pounds (Ibs) per year
          (2)   Safety-Kleen Corporation visited the site every 10 weeks
          ( 3 )   Safety-Kleen parts cleaning,stations contain a 30 gallon tank for the solvent
                                        -  \.-  •-•-,.:•-•-..-
          ( 4 )   Specific gravity of cleaner is 0.8
                                          I     '        \                 :  .
Based on Operational Experience             I
                                          i
          (1 )   Tanks have an average volume of 25 gallons of solvent
          (2)   5 % solid waste       .    j
          (3)   Losses of cleaner are: 2% entrapment in hand wipe towel, and
                 98% by evaporation       j
                                         • |  '  • ..  .   -    •.••:•...   ;  :   -
                                       ."  I"  •  -   ,-   ,   '    .'  •  ,   ' -.. ' I,.   '      '
Total  Safety-Kleen:
[(5  stations * 25  gallons per  station)/(10 weeks)]  *  [(52 weeks)/(year)]  = 650  gallons/yr

[(650  gallons)/yr]  * [(0.8)/(1)]  *  [(8.34  lbsj)/(galloh  water)] »   4,337  Ibs  per year
                                         •j.  •/..:-.:-   .-  ,.  - -..-./  -;.  .   .  . ,:   .
Solid Waste Calculation:                    j
From  waste manifest  [(4381  lbs)/(yr)] * ( 0*.05 solid  waste) = 219 Ibs/yr solid waste
                                         • i
                                   -      ' I.   .                    .     '   •
Safety-Kleen Recycled:             .        j   .
   4,337  Ibs/yr -  219 Ibs/yr  = 4,162 Ibs/yr  recycled
                                          49

-------
Change Out   4,337  Ibs/yr
Recycled  -  4.162  Ibs/yr
Losses           175  Ibs/yr (this is a combination of 146 Ibs/yr evaporation  and 26 Ibs/yr
dragout)

Towel losses      -  (175  Ibs/yr)  *  (0.02) =  3  Ibs/yr
Air Emissions    =  (175  Ibs/yr)  *  (0.98) =   172  Ibs/yr
                                           50

-------
                     COST ANALYSIS FOR CHEMICAL CLEANERS
                                  SAFETYHKLEEN105
  DESCRIPTION
COST PER UNIT
    TOTAL COST
START-UF
Material Acquisition
  Safety-Kleen 105 Recycled
  (5 Cleaning Stations included)
  Safety-Kleen 105 Recycled
Identify and Quantify
  Contaminated Parts Processed
  Atmospheric Emissions

  Liquid Effluent
     Safety-Kleen 105
     Contaminants
  Solid Waste
     Hand Wipe Towels
     Safety-Kleen
     Contaminants
Under Contract with Safety-Kleen
Under Contract with Safety-Kleen
 $4,000
           $4,000
2,000 pounds pe|r year
146 Ibs/yr Safety  Kleen 105 (no permit required)
26 Ibs/yr Safety JKIeen 105 (drag-out losses)
                       '
4,162 pounds pe'r year (recycled)
21 9 pounds per year
              !  • -
300 pounds per ^ear (Non-Hazardous)**
3 pounds per ye£r (trapped in the towel)
4 pounds per year (trapped in the towel)
               N/A
               N/A
               N/A
             $400
               N/A
               N/A
Ecological and Human
Health/Safety Impacts
  PPE (Gloves)
  PPE (Eye ware)  -
 &&&£&&&&m
  Total  Start-Up  Cost
  Total  Annual Recurring Cost
60 pairs per year (100 Ibs/yr) @ $4/pair**
              i          .     ~
10 face shields per year (5 Ibs/yr) @ $8/pair**
             $240
             $100
  Start-Up Cost per Station
  Annual Recurring Cost per Station
                                           $4,000
                                             $800
                                            I,-
           $4,740


             $948
  Cost are covered in the contract with Safety Kleeri
  Purchase and Disposal                        !
                         Worksheet SK - 4.   i Cost Analysis for Cleaners
                                                            '

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                           52

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                        SAFET^ KLEEN 105
               Material and  Emission  Reduction
                         Option Description
Option  Name and Description
(Include input materials and products affected)
Option  No.
ONE
                       Consider:
              Yes
Employ a parts washing station that woulp! reduce the losses of the solvent through
evaporation or drag-out.              ,
      Practices & Procedures D
        Material Substitution Q
    New Product &/or Process D
                             Waste Segregation/Hazard Reduction d
                                       Equipment Modification •
                                Recycling, Reuse, & Reclamation rj
Option No.
 TWO
Consider:    • yes
                                             No
Switch to a more environmentally benign cleaning solvent.
      Practices & Procedures rj
        Material Substitution g
    New Product &/or Process
                             Waste Segregation/Hazard Reduction rj
                                       Equipment Modification rj
                                 Recycling, Reuse, & Reclamation pj
                     Worksheet SK-6. |    Option Description
                                   !  53
                                   l,  ....

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                                     "••.  r.    "  •*•
U.S. COAST GUARD SUPPORT CENTER N^W YORK
GOVERNORS ISLAND, NEW YORK        |
    Governors Island is located off the southern tip of Manhattan and is accessible primarily by
a Coast Guard operated ferry.  The island encompasses 175 acres and consists solely of Coast
Guard facilities which are grouped together uncJer the name Support Center New York. The
island, which  serves as a support center for Coast Guard activities conducted within the New
York area and for tenant commands located on | the island, is the home port for a number of Coast
Guard vessels. There are 22 different commands represented on the island which are given
support  from the center.  A total of 20 Coast Guard ships are tended  to at the support center.
The list  of ships includes high endurance  cutters, buoy tenders, bay class icebreakers, harbor
tugs, search and rescue utility boats, and  ferry boats.

   The industrial facility located within the confines of the base is responsible for the majority
of the parts from the tenant ships and ground support vehicles being cleaned.  The facility also
has an internal contract with the Coast GuardjSupply Center at Baltimore, Maryland, to inspect
and rebuild patrol boat engines.  Brulin 815 G,D parts cleaner is the predominant choice for the
parts washing process.                     '
BRULIN 815 GD

PROCESS DESCRIPTION:

   Brulin 815 GD is currently being used in ithe industrial motor repair shop for the removal
of contaminants from ship and ground support! vehicle parts.  The parts cleaning solution is a
mixture of 20 to 50 percent Brulin 815 GD in potable water and is contained in an insulated
1,200 gallon capacity tank.  The percentage cjf Brulin 815 GD in the potable water is important
in that the higher the concentration the better! removal  efficiency of heavy contaminants
(grease, high viscosity oil).  The cleaning solution is maintained at a temperature of 140°F to
160°F by use of an electrical coil located inside the tank.
                                          I   '" i -.'-.-•-.•   :   -.-.,:
                                          \        '    :       -             '-   ',
   The contaminated parts to be cleaned are placed in a metallic basket and then lowered into the
tank by a mechanical hoist.  The cleaning solution is not agitated in the tank and there is no
manual brushing on the contaminated parts by the technician to stimulate the removal of the
contaminants.  The contaminated parts soak iri the cleaning solution for periods of four to twelve
hours.

   Common contaminants removed from the parts include scale, carbon, grease, and paint.
There is no filtration device  used for the separation of the contaminants from the cleaning
solution.  The contaminants  are usually entrained in the cleaning solution and tend to settle to
the bottom of the tank forming a sludge.  The accumulated sludge is removed from the tank on an
annual basis. The waste sludge is considered hazardous in the State of New York and is
                                          .i                 •                  .
                                          I
                 . '                        !55

-------
transferred off-site  by contracted personnel.

    Cleaned parts are removed from the tank and steam cleaned with a water and surfactant
(Blue Giant) mixture to further enhance cleanliness.  This process generates contaminant waste
(approximately  27 pounds per year), which  is collected in an  oil-water separator.  The
contaminant waste is placed in a designated  container for storage and then transferred off the
island. The liquid effluent from the steam cleaning is allowed to be discharged into the sewer
system without a permit.

    After the cleaning procedure, the part is  allowed to  air dry or is dried using a disposable
cloth. The cloth towel may be disposed of as  non-hazardous waste.
ENVIRONMENTAL SAFETY AND HEALTH ISSUES:

    Brulin 815 GD is a blue-green blend of detergents, alkaline builders and inhibitors that
possesses a mild odor.  It is distributed as a concentrate with a pH level of 12, with a typical
dilution pH of 9.  Brulin 815 GD is bio-degradable, contains no phosphates, and is completely
soluble in water.  Blue Giant is considered a non-toxic water soluble cleaner.  Both formulations
list no hazardous  ingredients in the MSDS and are non-flammable.  Direct eye contact  and
prolonged or repeated skin contact may cause irritation. The use of personal protective
equipment consisting of gloves and protective eye ware should be utilized.

    Brulin 815 GD is considered by environmental agencies to be  a relatively benign  solution
and requires minimal  environmental monitoring.  The working solution  posses no significant
health threats and is relatively safe to use.  Efforts should be taken to ensure that the  discharge
of the cleaner into the sewer system does not require any pretreatment by local water treatment
facilities.
COST ANALYSIS:

   The start-up cost for the Brulin 815 GD parts washing alternative was approximately
$3,448.  This cost included modifications to the existing tank in the industrial motor repair
shop and all chemical acquisitions.  Included in the start-up was the energy cost for heating the
tank to its  working temperature of 150°F.

   The total annual cost for the purchase of the Brulin 815 GD cleaner at Governors Island was
$1,293  ($9.40 per gallon).  The majority of the Brulin 815  GD losses were incurred from the
removal of  the sludge.  Other losses of the cleaner were from evaporation and drag-out. The
Blue Giant  surfactant used in the steam cleaning process cost $800 ($8 per gallon). Governor
Island  used approximately 3,600 gallons of water are used annually at a cost of $216 ($0.06
per gallon). Water consumption for parts cleaning includes the losses through evaporation,
drag-out, and sludge removal and use for the rinsing procedure. The cost to heat the Brulin 815
GD solution throughout the year has been estimated through engineering calculations. These
calculations incorporate conductive heat losses.  Energy cost for maintaining the cleaners heat at
150°F  was estimated at $6,849 for the yeaTr


                                           56

-------
    Disposal of the sludge from the island costs $0.61  per pound for a total cost of $610.
Emissions released into the atmosphere from the use of Brulin 815 GD and Blue Giant are
assumed not to result in a cost.  Other incurred costs include the use of personal protective
equipment, consisting of gloves and face shields at $96 per year and three bales of the
disposable cloth towels used to dry the parts a't a cost  of $99 per year.
                                          |  .    .    . .    ,   V • •      - ' -       • - •
                                          I  -" '-:- - •      -      -                ....-•"-'
MATERIAL AND EMISSION REDUCTION OPPORTUNITIES:

    A possible material  reduction opportunity 'for the Brulin 815 GD parts cleaning process
would be to establish a  continuous filtration system to  separate the contaminants from the
working solution. Approximately 575 poundsj  (64 gallons) of Brulin 815 GD  is used to make-
up the losses incurred through the removal  of ithe sludge from the parts washing tank. This is
about 47 percent of the total annual usage of the Brulin 815 GD parts cleaner.  A cost savings of
$600 would result from  the elimination of Bru'lin 815 GD in the sludge.  The total weight for
the sludge could be reduced by 75 percent with the separation of the cleaner from the
contaminants. This reduction would have a cost savings of $458 annually. The "mucking" out
the tank and removal of the sludge would be reduced to every three years.  The total savings
associated with the use of a continuous filtration unit,  including any water losses,  would be
almost $1,100 annually.                                      .             .        .

    An evaluation should be conducted to assess the need to use the surfactant Blue Giant as a
follow-up cleaner to the Brulin 815 GD parts washing  procedure.  Steam rinsing bnly should
have the same cleaning effects as steam cleaning with the surfactant mixture, resulting in an
annual cost savings of $800.                I
CONCLUSIONS:                              !
                                           I •  ..      . • .    -•••  •     .      ' .  •   •
                                           j
   The industrial motor repair shop at Governors Island has cleaned over 60,000 pounds of
contaminated parts with the Brulin 815 GD solution.  The cleaner has proven to be effective at
removing contaminants from the various ship and ground support parts located on the  island.

   Important factors in  using the Brulin 815 GD as a parts cleaner  is  the solution
temperature, concentration, and soaking time.) Operational  experience indicates that  the Brulin
815 GD to be an efficient parts cleaner at SCNY, the temperature must be at least 150°F with
the concentration of Brulin greater than 20 percent and a soaking time of at least 4 hours if
there is no agitation.

   According to tests performed by Scientific Material International Inc., Brulin 815  GD
showed no hydrogen embrittlement, no visible j cracking to titanium alloys, and was proven to be
safe on most.metals including steel and aluminum.  Brulin 815 GD contains no "butyl" or
petroleum solvents and is effective as a hot tank degreaser.
                                           57

-------
                        BRULIN S15  GD
                   Preliminary Information
Location:
SONY, Governors Island is located off the southern tip of Manhattan and is
accessible primarily by a Coast Guard operated fairy.  Nine Coast Guard Cutters, 4
Ferry Boats, and 7 small boats are home ported at this facility.
Process Boundary:
The industrial facility located within the confines of the base is responsible for
cleaning the majority of marine parts. The boundary was established within this
facility and dealt specifically with the cleaning tank and the secondary steam
cleaning  for marine parts.

Process Description:
The parts cleaning solution is a mixture of 20 to 50 percent Brulin in potable water
that is contained in an insulated 1,200 gallon capacity tank. The cleaning solution is
heated to 150 degrees Fahrenheit. The contaminated part is placed into the tank by
a mechanical hoist and left for periods of four hours or greater.  There is no manual
brushing on the contaminated parts by the technician. The cleaning solution is not
agitated.  Common contaminants removed from the marine parts include scale,
carbon, grease, and paint. There is no filtration device used for the separation of the
contaminants from the cleaning solution.

After the parts are removed from the cleaning tank they are steam washed with a
surfactant (Blue Giant) and water mixture.  The parts are allowed to air dry or dried
using a disposable paper towel.
Product of Process:
Clean Marine Parts (No restrictions)
               Worksheet BR-1.     Parts Washing Process Description
                                    58

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-------
 BRUL1N 815 GD
SUPPORTING CALCULATIONS
HEAT LOSS CALCULATIONS:
                (1 )   Specific Heat of cleaning solution = Cp= 1 Btu/lb -°F
                (2)   Ambient air temperature 72°F
                                        I'. •.-.'.:••   •;  '   .  ..••.-•
                (3)    Tank size 1,200 gallon capacity
 Tank Calculations
         50 inches
                   66 inches
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      a.  Total Tank Area
         (50") |* (66")  * (91 ")*  (1  ft3/1728")  =  174 W
      b.  Total Tank Volume
         (174 jft3)  / (0.1337 -fts/gal) = 1,300. gal
      c.  Clearance  of 5  inches from top of tank to the cleaning
         solution
             11
              I       5 inches
                                   Clearance Volume = 98.5 gallons
Volume of Brulin 815 Gd in Tank = (1,300 - J98.5) = 1,200 gallons

-------
Stepl:    Heat tank from ambient temperature ( 72°F) to working temperature  (150°F)
             q = mCpAT
                       q  = heat
                       m = mass
                       Cp = Specific Heat
                       AT = Change in Heat
(1,200 gal)*(8.34  Ibs/gal)  - 10,008  Ibs
1  Btu/lbs-°F
(150°F - 72°F) =  78°F
             q =  780,624 Btu
          1 Btu » 2.93071  * 10  -4  kWH
          kWh = (780,624 Btu) * (2.93071  *  10 -4  kWH/Btu)  = 228.78  kWH
          Cost  = (228.78 kWH) * ($0.17)/(kWH) =  $38.82
Step 2:    Conduction losses from operations
       Tank is constructed of two materials: (1) Steal .75 inch thick, and (2) foam insulation
       1 inch thick
                                                     I     I  Steal
                                                            Foam
                                          62

-------
    q  = heat
    A  = Area
    AT = Temperature change
    R  = Thermal Resistance
    B  = Thickness of Material
    K  = Thermal Conductivity
    q  =  AT/R
    R  =  Rst +
                       Where    st  = Steel
                                 t   = Foam
              R  =  _B_    therefore
                    KA        I
                               i
                               |-
              R  =  Bst/KstA  +;  Bf/KfA
Calculate losses from tank sides:
                               i
                               I
   A     =    119 ft2          |
   Bst    =  0.0625 ft         |
   Kst    =  26.2  Btu/ft-h-°F I
                               I
   Bf     =  0.08333 ft       i
   Kf.     =  0.08  Btu/ft-h-°F j
Assume AT =  70° F             i

   Rst    = 2 *10-5 °F/Btu
   Rf     =  8.75*10-3 °F/Btu
          = 8.77*10-3°F/Btu
                               |63

-------
         q  o  (70°F)/(8.77*10-3°F/Btu)=  7979 Btu = 2.33 kWh

      Hours per year (Tank is not heated for two weeks for sludge removal)

   (2.33  kWh)  *  ($0.17)  *  (8400 hours/yr)   =   $3.327  per year
Step 3:  Calculate losses from tank bottom

      Assume concrete thickness of 1 foot

          BO  =  1  ft                              c = concrete
          Kc  =  0.54  Btu/ft-h-°F
          Bst=  0.0625 ft
          Kst=  26.2  Btu/ft-h-°F
          A  =  40 ft2
      Assume AT =  70° F

             q  =1725 Btu

          Annual kWh cost   =  $751
                                     64

-------
Step 4:  Calculate losses from tank top
       Follow the same procedure used for the tank sides and the tank bottom
          q = 1.94kWh                  j
   Cost = (1.94 kWh)  *  ($ 0.17) * (8400 j hrs/yr) = $2.770  per year
Total cost to heat tank per year = $ 6.887
                                         65

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                    COST ANALYSIS FOR CHEMICAL CLEANERS
                                     BRULIN815GD
  DESCRIPTION
COST PER LMT
Material Acquisition
  Cleaning Station
  Brulin 815 GD Acquisition
  Brulin 815 GD Usage
  Blue Giant Usage
150 gallons {1,345 Ibs) @ $9.40 per gallon
137 gallons (1,228 Ibs) @ $9.40 per gallon
100 gallons (900 Ibs) @ $8.00 per gallon
Identify and Quantify
  Energy
  Water Usage
  Parts Processed
  Atmospheric Emissions
  Solid Waste
     Sludge*
     Disposable Cloth Towels
     Petroleum Contaminants
     Petroleum Contaminants
40,512 kWh @ $0.17/kWh
Estimated 3,600 gallons ($0.06/gallon)
60,000 pounds per year
3049 pounds per year (no permit required)

1000 pounds per year $.61/Ibs (Hazardous)
3 Bales per year @ $33 per bale
27 pounds per year (oil/water seperator)
3 pounds per year  (trapped in the towel)
Ecological and Human
Health/Safety Impacts
  PPE (Gloves)
  PPE (Eye ware)
12 pairs per year (20 Ibs/yr) @ $4/pair
6 face shields per year (2.5 Ibs/yr) @ $8/pair
    TOTAL COST
START-UP  RKXIRRNG

  $2,000
  $1,410
             $1,293
               $800
  Total  Start-Up Cost
  Total  Annual  Recurring Cost
     $38
$6,849
  $216
    N/A
    N/A

  $610
   $99
    N/A
    N/A
                $48
                $48
                                           $3,448
                                                      $9,963
 Mixture of contaminants (250 Ibs), Brulin 815 GD (450 Ibs), and Water (300 Ibs)

                         Worksheet BR - 4.    Cost Analysis for Cleaners
                                            66

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                            BRULIN  815 GD
                Material  and Emission  Reduction
                          Option  Description
Option Name and  Description
(Include input materials and products affected)
Option No.
ONE
                                        Consider:
                                       Yes
 Establish a continuous filtration system to separate the contaminants from the
 working  solution.
       Practices & Procedures O
         Material Substitution D
    New Product &/or Process D
                              Waste Segregation/Hazard Reduction  d
                                         Equipment Modification  •
                                  Recycling, Reuse, & Reclamation  Q
 Option  No.
 TWO
                                        Consider:
                                       Yes
Increase the amount of insulation surrounding the cleaning tank to reduce heat
loss.
       Practices & Procedures rj
         Material Substitution rj
     New Product &/or Process
                               Waste Segregation/Hazard Reduction rj
                                          Equipment Modification g
                                   Recycling, Reuse, & Reclamation g
Option No.
                  THREE
                        Consider:
Yes
No
 Investigate the necessity of steam cleaning the parts following the Brulin 815 GD
 parts washing procedure.
       Practices & Procedures •
         Material Substitution rj
    New Product &/or Process rj
                               Waste Segregation/Hazard Reduction
                                         Equipment Modification
                                   Recycling, Reuse, & Reclamation
                                                                            D
                      Worksheet BR-6.     Option Description
                                        68

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                                    REFERENCES
1. Vigon, B.W., et al., Life Cycle Assessment: Inventory Guidelines and Principles, EPA -
   600/R-92/245,  U.S. Environmental Protection Agency, Cincinnati, Ohio,  1993

2. Perry, J.H. (ed): "Chemical Engineers Handbook," 6th ed.,  McGraw-Hill, New York, 1984

3. McCable, Smith, and Harriott (ed): "Unit Operations of Chemical Engineering," 4th ed.,
   McGraw-Hill, New York, 1985

4. Himmelblau, D.M. (ed): "Basic  Principles and Calculations in Chemical  Engineering," 5th
   ed., Prentice Hall, New Jersey,  1989
                                          70

-------