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.
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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
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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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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.
.!
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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
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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.
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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. !
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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
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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
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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
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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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41
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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
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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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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
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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
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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
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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
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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
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R = Bst/KstA +; Bf/KfA
Calculate losses from tank sides:
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A = 119 ft2 |
Bst = 0.0625 ft |
Kst = 26.2 Btu/ft-h-°F I
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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
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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 = $751
64
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Step 4: Calculate losses from tank top
Follow the same procedure used for the tank sides and the tank bottom
q = 1.94kWh j
Cost = (1.94 kWh) * ($ 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
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