EPA/600/R-95/120
August 1995
DEMONSTRATION OF
ALTERNATIVE CLEANING SYSTEMS
Dean M. Menke
Gary A. Davis
Lori E. Kincaid
Rupy Sawhney
University of Tennessee
Center for Clean Products and Clean Technologies
Knoxville, Tennessee 37996-0710
Project Officer
Diana R. Kirk
Sustainable Technology Division
National Risk Management Research Laboratory
Clean Processes and Products Branch
Cincinnati, Ohio 45268
NATIONAL RISK MANAGEMENT RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
Printed on Recycled Paper
-------
FOREWORD
The U.S. Environmental Protection Agency is charged by Congress with protecting the
Nation's land, air, and water resources. Under a mandate of national environmental laws, the Agency
strives to formulate and implement actions leading to a compatible balance between human activities
and the ability of natural systems to support and nurture life. To meet this mandate, EPA's research
program is providing data and technical support for solving environmental problems today and
building a science knowledge base necessary to manage our ecological resources wisely, understand
how pollutants affect our health, and prevent or reduce environmental risks in the future.
The National Risk Management Research Laboratory is the Agency's center for investigation
of technological and management approaches for reducing risks from threats to human health and the
environment. The focus of the Laboratory's research program is on methods for the prevention and
control of pollution to air, land, water and subsurface resources; protection of water quality in public
water systems ; remediation of contaminated sites and ground water, and prevention and control of
indoor air pollution. The goal of this research effort is to catalyze development and implementation
of innovative, cost-effective environmental technologies, develop scientific and engineering
information needed by EPA to support regulatory and policy decisions, and provide technical support
and information transfer to ensure effective implementation of environmental regulations and
strategies.
This publication has been produced as part of the Laboratory's strategic long-term research
plan. It is published and made available by EPA's Office of Research and Development to assist the
user community and to link researchers with their clients.
E. Timothy Oppelt, Director
National Risk Management Research Laboratory
in
-------
TABLE OF CONTENTS
Page
DISCLAIMER ii
FOREWORD iii
ABSTRACT iv
LIST OF TABLES viii
LIST OF FIGURES xi
ACRONYMS xii
ACKNOWLEDGMENT xiv
CHAPTER 1: INTRODUCTION 1
33/50 PROGRAM 1
OBJECTIVES OF THIS RESEARCH 2
METHODOLOGY 5
CHAPTER 2: MATERIALS AND PARTS CLEANING 6
MATERIALS AND PARTS DECREASING DESCRIPTION 6
Cold Cleaning 6
Vapor Degreasing 7
Conveyorized Degreasing 7
Hybrid Degreasing Systems 7
PROPERTIES OF CHLORINATED DEGREASING SOLVENTS 8
Degreasing Properties 8
Health, Safety and Environmental Properties 8
REGULATORY BACKGROUND 10
SAFE SUBSTITUTES FOR THE 33/50 DEGREASING SOLVENTS 10
Aqueous Wash Systems 10
No-Clean Technologies 12
CHAPTER 3: CALSONICS CHLORINATED SOLVENT SUBSTITUTES
PROGRAM 14
BACKGROUND INFORMATION ON CALSONIC 14
THE RADIATOR LINE AND AQUEOUS WASH SYSTEM 15
THE CONDENSER LINE AND NO-CLEAN TECHNOLOGY 17
THE CONVERTER LINE AND HOT WATER WASH SYSTEM 22
CHAPTER 4: TECHNICAL EVALUATIONS 25
TECHNICAL BACKGROUND 25
CMC TECHNICAL EVALUATION 26
The Evaluation of the Process Cycle Time 26
The Evaluation of Part Reject Rates 27
SUMMARY OF THE TECHNICAL EVALUATION 29
Aqueous Wash System of the Radiator Manufacturing Line 29
Evaporative Lubricant System of the Condenser Manufacturing Line 29
CHAPTER 5: ENVIRONMENTAL, EVALUATION 30
ENVIRONMENTAL BACKGROUND 30
continued
-------
Table of Contents continued
REFERENCES 120
APPENDIX A: RAW DATA IN DATA REQUEST TABLES 126
APPENDIX B: SCREENING TEST RESULTS FOR THE AQUEOUS
WASH SYSTEM 140
APPENDIX C: STATISTICAL EVALUATIONS 144
APPENDIX D: CONVERSION TABLE 149
APPENDIX E: CALSONIC CORPORATION'S ENVIRONMENTAL PROGRAM .151
APPENDIX F: ANALYSIS RESULTS OF PRETREATED WASTEWATER
EFFLUENT 162
APPENDIX G: UNIQUE BILLS OF ACTIVITIES 163
vn
-------
List of Tables continued
TABLE 24 COMPARISON OF HYBRID AND TRADITIONAL
ANALYSES - RADIATOR MANUFACTURING LINE 64
TABLE 25. HYBRID COST ANALYSIS OF THE PROCESS CHANGES
TO THE CONDENSER MANUFACTURING LINE 65
TABLE 26 COMPARISON OF HYBRID AND TRADITIONAL
ANALYSES - CONDENSER MANUFACTURING LINE 65
TABLE 27 SUPPLY AND DEMAND OF THE CHLORINATED
DECREASING SOLVENTS 70
TABLE 28. TRI RELEASES AND TRANSFERS OF CHLORINATED
DECREASING SOLVENTS FROM PRODUCTION FACILITIES 71
TABLE 29. CHLORINATED SOLVENT CONSUMPTION BY DECREASING
APPLICATIONS 73
TABLE 30 PRODUCERS OF ETHOXYLATED ALCOHOL SURFACTANTS 76
TABLE 31 RELEASES AND TRANSFERS FROM ETHOXYLATED
ALCOHOL PRODUCTION FACILITIES 77
TABLE 32 PRODUCERS OF ETHOXYLATED NONYLPHENOL
SURFACTANTS 79
TABLE 33 TRI RELEASES AND TRANSFERS FROM ETHOXYLATED
NONYLPHENOL PRODUCTION FACILITIES 82
TABLE 34. PRODUCERS OF DODECYLBENZENE SULFONIC ACID 85
TABLE 35 TRI RELEASES AND TRANSFERS FROM DODECYLBENZENE
SULFONIC ACID PRODUCTION FACILITIES 86
TABLE 36. TOTAL RELEASES AND TRANSFERS FROM SURFACTANT
AND SOAP/DETERGENT MANUFACTURERS 87
TABLE 37 PRODUCERS OF TETRAPOTASSIUM PYROPHOSPHATE 88
TABLE 38. TRI RELEASES AND TRANSFERS FROM TETRAPOTASSIUM
PYROPHOSPHATE PRODUCTION FACILITIES 91
TABLE 39. PRODUCERS OF SODIUM TRJPOLYPHOSPHATE 90
TABLE 40 TRI RELEASES AND TRANSFERS FROM SODIUM
TRJPOLYPHOSPHATE PRODUCTION FACILITIES 92
TABLE 41. PRODUCERS OF ETHYLENEDIAMINETETRAACETIC ACID ...... 93
TABLE 42. TRI RELEASES AND TRANSFERS FROM
ETHYLENEDIAMINETETRAACETIC ACID PRODUCTION
FACILITIES 95
TABLE 43. TRI RELEASES AND TRANSFERS FROM THE PRODUCTION
OF NTA - W.R. GRACE AND COMPANY 96
TABLE 44. TOTAL TRI RELEASES AND TRANSFERS FROM INDUSTRIAL
INORGANIC CHEMICAL PRODUCERS 97
TABLE 45. NATIONAL BASELINE AIR RELEASES 99
TABLE 46. TRI RELEASES AND TRANSFERS OF CHLORINATED
DECREASING SOLVENTS FROM TOP INDUSTRY SECTORS 100
TABLE 47. COMPARISON OF 1()92 TRI EMISSIONS AND NESHAP
BASELINE EMISSION ESTIMATIONS 102
IX
continued
-------
LIST OF FIGURES
Page
FIGURE 1. CHLORINATED ORGANIC CHEMICALS 4
FIGURE 2 CURRENT RADIATOR MANUFACTURING LINE WITH
THE AQUEOUS WASH SYSTEM 16
FIGURE 3. PAST RADIATOR MANUFACTURING LINE WITH THE
SOLVENT DECREASING SYSTEM 18
FIGURE 4 CURRENT CONDENSER MANUFACTURING LINE WITH
THE NO-CLEAN TECHNOLOGY 19
FIGURE 5. PAST CONDENSER MANUFACTURING LINE WITH THE
SOLVENT DECREASING SYSTEM 20
FIGURE 6. CURRENT CONVERTER MANUFACTURING LINE WITH
THE HOT WATER WASH SYSTEM 23
FIGURE 7. PAST CONVERTER MANUFACTURING LINE WITH THE
SOLVENT DECREASING SYSTEM 24
FIGURE 8 PART REJECT RATES (NORMALIZED) OVER TIME FOR
THE RADIATOR MANUFACTURING LINE 28
FIGURE 9. TCA RELEASES AND TRANSFERS FROM THE RADIATOR
AND CONDENSER MANUFACTURING LINES - 1990 TO 1994 33
FIGURE 10. SUMMARY OF RADIATOR LINE EMISSIONS OVER TIME 45
FIGURE 11. SUMMARY OF CONDENSER LINE EMISSIONS OVER TIME 46
FIGURE 12. SIMPLIFIED MANUFACTURING SCHEME FOR
1,1,1-TRICHLOROETHANE 68
FIGURE 13. SURFACTANT MANUFACTURING 74
FIGURE 14. SIMPLIFIED MANUFACTURING SCHEME FOR
NONYLPHENOL ETHOXYLATES 80
FIGURE 15. SIMPLIFIED MANUFACTURING SCHEME FOR
DODECYLBENZENE SULFONIC ACID 84
FIGURE 16. SIMPLIFIED MANUFACTURING SCHEME OF
TETRAPOTASSIUM PYROPHOSPHATE 89
FIGURE 17. EDTA MANUFACTURING SCHEME 94
FIGURE 18. DISTRIBUTION OF DOCUMENTED NEEDS 109
FIGURE C1. REPRESENTATION OF STATISTICALLY DIFFERENT
DATA SETS 147
XI
-------
DISCLAIMER
The information in this document has been funded wholly by the United States
Environmental Protection Agency under Cooperative Agreement CR821848 to the University
of Tennessee's Center for Clean Products and Clean Technologies. It has been subject to peer
and administrative review, and has been approved for publication as an EPA document.
Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
-------
Acronyms continued
Pa-sec pascal second
Pb lead
PCE tetrachloroethylene or perchloroethylene
PEL permissible exposure limit
POTW Publicly Owned Treatment Works
ppm parts per million
SAGE Solvent Alternatives Guide
STPP sodium tripolyphosphate
TC A 1,1,1 -trichloroethane
TCE trichloroethylene
TRI Toxic Release Inventory
TSD treatment, storage, and disposal
TURI Toxics Use Reduction Institute
VOC volatile organic compound
Xlll
-------
ABSTRACT
Widespread use of toxic chemicals in all segments of industry and commerce has
created the need to deal with burgeoning waste streams containing toxic chemicals emitted
into the air and water and buried in the soil. Two decades of pollution control regulations
have not been completely effective in reducing environmental releases of toxic chemicals, nor
in mitigating the human health effects from toxic chemical use. The United States
Environmental Protection Agency's 33/50 Program is one example of a new generation of
voluntary programs that focus directly on pollution prevention to reduce toxic chemical
releases. The 33/50 Program encourages industry to enter agreements to reduce emissions of
17 toxic chemicals.
This report represents the first demonstration of cleaner technologies to support the
goals of the 33/50 Program under the EPA Cooperative Agreement No. CR821848. It
focuses on substitutes for solvent degreasing processes that eliminate the use of chlorinated
organic chemicals in the automotive parts sector. The substitute technologies demonstrated
were: 1) an aqueous wash system, 2) a no-clean technology, and 3) a hot water wash system.
Technical, environmental, and economic evaluations were performed to determine the merits
of the substitutes as they were implemented by the project's industry partner, Calsonic
Manufacturing Corporation. A national environmental impact evaluation was also performed
to estimate the potential impacts on the nation's environment if entire industrial sectors were
to implement the substitutes.
The evaluations were supportive of the implementation of the alternative technologies.
The aqueous wash system reduced cycle time by 50 percent and part reject rates by nearly 77
percent with improved cleaning characteristics as compared to the 1,1,1-trichloroethane
(TCA) solvent degreasing system. The no-clean alternative had no effect on either cycle time
or part reject rates. The environmental evaluation identified a shift in waste stream releases
and transfers. The traditional processes released TCA to the air, as well as generating a TCA
hazardous waste stream; the substitutes generates either a significant wastewater discharge
(aqueous and hot water wash systems), or a volatile organic compound air emission (no-clean
technology). The wastewater and VOC releases created by the alternatives, however, do not
contain 33/50 chemicals or chemicals that can cause ozone depletion, and are relatively less
toxic than the chlorinated solvents. Each alternative offered significant financial advantages
when economically evaluated using activity-based cost accounting and compared to the
traditional solvent degreasing systems.
The national environmental impact evaluation compared the life-cycle environmental
merits of traditional solvent systems and the alternatives. Chlorinated solvents, produced
from petroleum feedstocks, result in significant emissions during the manufacturing and use of
the products. The aqueous wash systems utilize detergents which include surfactants,
builders, and chelating agents, all of which are produced from various raw materials and
generate waste streams which must be compared to traditional attributes. The nation's
infrastructure for wastewater treatment was then evaluated, and the potential impact
estimated.
IV
-------
CHAPTER 1
INTRODUCTION
The hazardous waste problem and many of the persistent air and water pollution
problems are primarily toxic chemical problems. Widespread use of toxic chemicals in all
segments of industry and commerce has created the need to deal with burgeoning waste
streams containing toxic chemicals emitted into the air and water and buried in the soil. Two
decades of pollution control regulations have not been completely effective in reducing
environmental releases of toxic chemicals. Nor have regulations always protected workers
from the effects of toxic chemicals used in the workplace or consumers from the effects of
toxic chemicals found in consumer products. However, a new generation of programs and
policies are emerging which have a greater potential to reduce toxic chemical releases. The
United States Environmental Protection Agency's (EPA) 33/50 Program is one such new
generation program.
33/50 PROGRAM
The 33/50 Program is a voluntary pollution prevention initiative to reduce national
releases and off-site transfers to the environment of 17 toxic chemicals. The Program asks
industry to voluntarily develop their own reduction goals that contribute toward national
reduction goals of 33 percent by the end of 1992 and 50 percent by the end of 1995.
Reductions are measured against a 1989 baseline of information reported to EPA under the
Toxic Release Inventory (TRI). The 17 chemicals or chemical groups included in the 33/50
Program are as follows:
Benzene Methyl Ethyl Ketone (MEK)
Cadmium and Cadmium Compounds Methyl Isobutyl Ketone (MIBK)
Carbon Tetrachloride (CTC) Nickel and Nickel Compounds
Chromium and Chromium Compounds Tetrachloroethylene (PCE)
Chloroform (CFM) Toluene
Cyanide and Cyanide Compounds 1,1,1 -Trichloroethane (TCA)
Lead and Lead Compounds Trichloroethylene (TCE)
Mercury and Mercury Compounds Xylenes
Methylene Chloride (DCM)
EPA selected these compounds for the voluntary pollution prevention initiative based
on a number of factors including their high production volume, high releases and off-site
transfers relative to their production, opportunities for pollution prevention, and their
potential for causing health and environmental effects.1
EPA's National Risk Management Research Laboratory (NRMRL, formerly Risk
Reduction Engineering Laboratory) has funded research in support of the 33/50 Program.
The goal of the NRMRL-funded research is to evaluate the performance and cost of pollution
prevention options and to disseminate that information through reports, technical meetings,
seminars, and other media While this research was originally funded by NRMRL to support
-------
Table of Contents continued
RELEASES AND TRANSFERS TO LAND (OFF-SITE TRANSFERS) 34
Radiator Manufacturing Line 35
Condenser Manufacturing Line 36
RELEASES AND TRANSFERS TO AIR 36
Radiator Manufacturing Line 37
Condenser Manufacturing Line 37
RELEASES AND TRANSFERS TO WATER 38
Radiator Manufacturing Line 38
Condenser Manufacturing Line 39
Converter Manufacturing Line 39
TOXICITY, EXPOSURE, AND RISK 39
Toxicity 40
Exposure Potential 41
Risk 42
SUMMARY OF THE ENVIRONMENTAL EVALUATION 43
CHAPTER 6: ECONOMIC EVALUATION 47
ECONOMIC BACKGROUND 47
TRADITIONAL COST EVALUATIONS 48
Traditional Cost Evaluation of the Radiator Manufacturing Line 49
Traditional Cost Evaluation of the Condenser Manufacturing Line 52
ACTIVITY-BASED COST ACCOUNTING 56
ABC Analysis of CMC 56
ABC Analysis of the Radiator Manufacturing Line 57
ABC Analysis of the Condenser Manufacturing Line 61
HYBRID ACCOUNTING SYSTEM 63
Hybrid Analysis for the Radiator Manufacturing Line 63
Hybrid Analysis for the Condenser Manufacturing Line 63
CHAPTER 7: NATIONAL ENVIRONMENTAL IMPACT EVALUATION 66
NATIONAL ENVIRONMENTAL IMPACT BACKGROUND 66
CHEMICAL PRODUCTION PROCESSES 67
Production of Chlorinated Solvents 67
Production of Detergent Ingredients 73
CHEMICAL USE AND DISPOSAL PROCESSES 98
Use and Disposal of Chlorinated Degreasing Solvents 98
Use and Disposal of Detergents in Metal and Parts Cleaning Applications 103
SUMMARY OF NATIONAL ENVIRONMENTAL IMPACT EVALUATIONS ... 112
CHAPTER 8: CONCLUSIONS 114
TECHNICAL EVALUATION 115
ENVIRONMENTAL EVALUATION 115
ECONOMIC EVALUATION 117
NATIONAL ENVIRONMENTAL IMPACT EVALUATION 118
vi continued
-------
TART F 1. PRIORITY USES OF THE 33/50 CHEMICALS
batteries
metal finishing
plastics and resins
paints and coatings
degreasing
dry cleaning
paint stripping
33/50 Chemicals
Cd, Hg, Ni, Pb
Hg
Cd, Cr, Ni
cyanides
benzene, toluene, cyanides
Cd, Cr
xylene, toluene, MEK, MIBK,
Cd, Cr, Pb
benzene, toluene, cyanides
TCE TCA, PCE (CFCs), DCM
PCE, TCA
DCM
Function
electrode
additive
metal plate
plating bath
chemical intermediate
stabilizer
solvent
pigment
intermediates of paint resins
solvent
solvent
solvent
Key: DCM - methylenc chloride
PCE - perchloroethylene
TCE - trichloroethylene
Cd - cadmium
Ni - nickel
Cr - chromium
MEK - methyl ethyl ketone
MIBK - methyl isobutyl ketone
TCA- 1,1,1 -trichloroethane
CFC - ehlorofluorocarbon
1 Ig - mercury
Pb - lead
Source: "The Product Side ofPollution Prevention: Evaluating the Potential for Safe Substitutes," EPA, 1994.
Priority uses are defined as those products and/or processes that consume a significant
portion (weight fraction) of the 33/50 chemicals. "The Product Side ofPollution Prevention:
Evaluating the Potential for Safe Substitutes," used chemical use trees as the analytical tool to
evaluate the priority uses of the four classes of 33/50 chemicals. The process of metals and
parts degreasing uses four of the six chlorinated organic chemicals (DCM, PCE, TCA, TCE),
and was selected as a priority use of these chemicals as illustrated by the Chlorinated Organic
Chemicals chemical use tree, Figure 1:3
In this study the Center worked directly with an industry partner to demonstrate
substitute feasibility and to gain actual industrial information for the technical, environmental,
and economic evaluations. Calsonic Manufacturing Corporation (hereafter referred to as
CMC) is aggressively pursuing less polluting alternatives to solvent degreasing and agreed to
participate as the Center's industrial partner to demonstrate solvent degreasing alternatives.
-------
LIST OF TABLES
Page
TABLE 1. PRIORITY USES OF THE 33/50 CHEMICALS 3
TABLE 2. SELECTED PROPERTIES OF THE CHLORINATED
DECREASING SOLVENTS 9
TABLE 3. CHRONOLOGY OF CHANGES AT CMC 15
TABLE 4. COMPARISON OF LUBRICANT PROPERTIES 21
TABLE 5. GOALS OF WASTE MANAGEMENT PLAN BY WASTE STREAM ... 31
TABLE 6. 1,1,1 ,-TRICHLOROETHANE TRI RELEASES AND TRANSFERS
REPORTED BY CMC 32
TABLE 7. CMC TRI OFF-SITE TRANSFERS OF TCA 35
TABLE 8. SUMMARY OF INFORMATION USED TO CALCULATE CMC AIR
EMISSIONS OF TCA 36
TABLE 9. POTENTIAL EXPOSURE TO WASTE STREAMS AND
ASSOCIATED RISK 43
TABLE 10. EPAS EXPANDED COST INVENTORY 48
TABLE 11. TRADITIONAL COST ANALYSIS OF THE RADIATOR
MANUFACTURING LINE 50
TABLE 12. RETURN ON INVESTMENT AND COMPARISON OF NET
PRESENT VALUES - RADIATOR 52
TABLE 13. COMPARISON OF CAPITAL COSTS FOR THE SOLVENT
DECREASING AND EVAPORATIVE LUBRICANT SYSTEMS 53
TABLE 14. TRADITIONAL COST ANALYSIS OF THE CONDENSER
MANUFACTURING LINE 54
TABLE 15 RETURN ON INVESTMENT AND COMPARISON OF
NET PRESENT VALUES - CONDENSER 55
TABLE 16. COST DRIVERS FOR THE PRIMARY ACTIVITIES 57
TABLE 17. PRIMARY ACTIVITIES UNIQUE TO THE SOLVENT
DECREASING AND AQUEOUS WASH SYSTEMS OF TFffi
RADIATOR LINE 58
TABLE 18. DETAILED EXAMPLE OF THE SUPPORTING ACTIVITIES
FOR THE ASSEMBLY AND CLEANING OF RADIATOR CORES .... 59
TABLE 19. SUMMARY OF ABC RESULTS FOR THE RADIATOR
MANUFACTURING LINE 60
TABLE 20. PRIMARY ACTIVITIES UNIQUE TO THE SOLVENT
DECREASING AND EVAPORATIVE LUBE SYSTEMS OF
THE CONDENSER LINE 61
TABLE 21. SUMMARY OF ABC RESULTS FOR THE CONDENSER
MANUFACTURING LINE 62
TABLE 22. COMPARISON OF OPERATING AND MAINTENANCE
COSTS - CMC ESTIMATES VERSUS ABC RESULTS 63
TABLE 23. HYBRID COST ANALYSIS OF THE PROCESS CHANGES
TO THE RADIATOR MANUFACTURING LINE 64
Vlll
continued
-------
METHODOLOGY
The goals of this research were to technically, environmentally, and economically
evaluate the changes in materials and parts degreasing which CMC has employed. If entire
industrial sectors were to implement similar changes, the national environmental impacts of
these changes were estimated from the knowledge of CMC's process changes, and other
literature sources.
Data required to perform the technical, environmental, and economic evaluations were
collected through data request tables, site visits, and interviews with CMC employees. Data
request tables, completed by CMC and during site visits, collected process information
including capital costs, operating and maintenance costs, utilities consumption, and production
data. Similar data were requested for both the solvent degreasing systems (historic data) and
alternative systems (current data). Questions concerning generation rates and disposal costs
of waste (hazardous and non-hazardous) and wastewater accompanied the data request tables,
as well as questions concerning permitting requirements and costs. These questions were also
directed at operations both before and after the process changes. Appendix A presents the
completed data request tables and questions for the radiator and condenser lines.
Site visits and interviews served two purposes for the project's evaluations. First, they
allowed Center staff to become familiar with the operations of CMC, ask specific questions to
complete and clarify the data request tables, and maintain a working contact with CMC. An
extended site visit near the completion of this project was conducted to observe the day-to-
day operations of the process lines under investigation. These observations were used to
extend a traditional economic evaluation by using activity-based cost accounting.
The national impact evaluation utilized the knowledge of CMC's process changes to
identify and evaluate potential changes on a national scale if entire industrial sectors were to
implement solvent degreasing alternatives similar to CMC's. TRI data and information from
various literature sources were used to develop a life-cycle perspective for chlorinated solvent
degreasing and its alternatives.
Chapter 2 discusses materials and parts cleaning processes. Chapter 3 introduces
CMC, the industry partner for the project, and their solvent substitution program. Chapters 4,
5, and 6 present the technical, environmental, and economic evaluations of this research,
respectively, and Chapter 7 presents the national impact evaluation.
-------
List of Tables continued
TABLE 48 TOTAL TRI RELEASES AND TRANSFERS OF CHLORINATED
DECREASING SOLVENTS FROM OTHER INDUSTRY SECTORS . . 104
TABLE 49. CAPACITY OF NATION'S TREATMENT FACILITIES 106
TABLE 50. LEVEL OF TREATMENT FOR THE NATION'S TREATMENT
FACILITIES 107
TABLE 51 SUMMARY OF DOCUMENTED NEEDS FOR YEARS
1988, 1990 AND 1992 108
TABLE 52. SUMMARY OF THE TECHNICAL EVALUATION RESULTS 115
TABLE 53 SUMMARY OF ENVIRONMENTAL EVALUATION RESULTS 116
TABLE 54 SUMMARY OF ECONOMIC ANALYSES RESULTS - RADIATOR
MANUFACTURING LINE 117
TABLE 55. SUMMARY OF ECONOMIC ANALYSES RESULTS - CONDENSER
MANUFACTURING LINE 118
TABLE Al COMPLETED DATA REQUEST TABLES - RADIATOR
MANUFACTURING LINE 126
TABLE A2 COMPLETED DATA REQUEST TABLES - CONDENSER
MANUFACTURING LINE 130
TABLE B1. AQUEOUS WASH TRIALS
BLACK LIGHT CONTAMINATION CHECK 141
TABLE B2 AQUEOUS WASH TRIALS
BRAZED CORE CHECK 142
TABLE Cl. SAMPLE DATA 145
TABLE C2. RESULTS OF CHI SQUARE ANALYSES 145
TABLE C3 PARAMETER FOR DATA SETS AND ANALYSES 146
TABLE C4. RESULTS OF STUDENT T ANALYSES 146
TABLE C5 RESULTS OF PRODUCTION RATE STATISTICAL ANALYSES .... 148
TABLE Dl. CONVERSION FACTORS 149
TABLE F1 ANALYSIS RESULTS OF WASTEWATER DISCHARGES
TOPOTW 162
TABLE G1 RADIATOR MANUFACTURING LINE - OLD, TCA
DECREASING SYSTEM'S BOA 163
TABLE G2 RADIATOR MANUFACTURING LINE - NEW, AQUEOUS
DETERGENT SYSTEM'S BOA 167
TABLE G3 CONDENSER MANUFACTURING LINE - OLD, TC A
DECREASING SYSTEM'S BOA 171
TABLE G4 CONDENSER MANUFACTURING LINE - NEW,
EVAPORATIVE; LUBRICANT SYSTEM'S BOA 174
-------
Vapor Degreasing
The vapor degreasing process uses the vapor of the cleaning solvent to remove
contaminants from materials or parts. The vapors, generated by boiling the solvent, condense
on the relatively cold parts, dissolving and displacing the contaminants and soils, thus cleaning
the surface. Cleaning ceases when the parts and vapor temperatures are at equilibrium.
The open-top vapor degreaser is a large tank with three distinct zones: the solvent
reservoir, vapor zone, and freeboard. The solvent reservoir, which contains the cleaning
solvent, is equipped with electric or steam heater coils to create the vapor zone by boiling the
solvent. The vapor zone, directly above the solvent reservoir, is the zone into which the
relatively cold parts are lowered causing vapor condensation and thus parts cleaning. The
vapor zone height is controlled by cooling coils located near the top and on the inside
perimeter of the tank. The coils condense the solvent vapors and return them as liquid to the
reservoir.8'9 The density of the solvent vapors also assists in maintaining a vapor zone and
containing the vapors within the tank. The freeboard is the vacant space above the vapor
zone which minimizes solvent drag-out when the parts are removed from the vapor zone after
cleaning. The freeboard space allows condensed solvent vapors to drip from the cleaned
parts, as well as offering drying time for the parts. Much of the solvent vapors and liquid in
this zone fall back to the vapor zone and reservoir.10'n
Vapor degreasing is frequently more advantageous than cold cleaning because the cold
solvent bath becomes increasingly more contaminated during the cleaning process. As the
cold bath becomes more and more contaminated, the relative cleanliness of the parts may
decrease because the parts are in direct contact with the contaminated liquid solvent. In vapor
degreasing, although the boiling liquid solvent in the reservoir contains the contaminants from
previously cleaned parts, the solvent usually boils at lower temperatures than the
contaminants, resulting in the formation of essentially pure solvent vapors. In addition, the
high temperature of vapor cleaning aids in wax and heavy grease removal and significantly
reduces the time it takes for cleaned parts to dry.
Conveyorized Degreasing
Conveyorized, or in-line, degreasers have automated, enclosed conveying systems for
continuous cleaning of parts. Conveyorized degreasers clean by either the cold solvent
process or the vaporized solvent process. While these units tend to be the largest degreasers,
they actually produce less emissions per part cleaned than other types of degreasers. This is
due primarily to the enclosed design of the conveyor systems.
Hybrid Degreasing Systems
Combinations of immersion and vapor degreasing systems can be employed to aid in
the cleaning of problematic soils (e.g., waxes), or highly soiled parts. These hybrid units can
utilize agitated solvent baths, spray units and/or ultrasonics in conjunction with vapor
degreasing processes. Ultrasonics apply energy to a cleaning solution to induce cavitation, or
the collapse of millions of tiny bubbles produced in the solution by the applied energy. It is
the collapse of these bubbles that create a scrubbing effect to clean the immersed parts.1
12
-------
ACRONYMS
J Joules
ABC activity-based costing
ABS alkylbenzene sulfonate
ASTM American Society of Testing and Materials
atm atmosphere
BOA bill of activities
BOD biological oxygen demand
BTU British thermal unit
Cd cadmium
CFC chlorofluorocarbon
CFM chloroform
CMC Calsonic Manufacturing Corporation
CNS central nervous system
Cr chromium
CTC carbon tetrachloride
DCM methylene chloride or dichloromethane
DOE Department of Energy
EDTA ethylenediaminetetraacetic acid
FOG fats, oils, and greases
g grams
g/L grams per liter
gpd gallons/day
Hg mercury
HSDB Hazardous Substances Data Bank
K2HPO4 dipotassium hydrogen phosphate
L liter
LAB linear alkylbenzene
LAS linear alkylbenzene sulfonate
m meter
MACT maximum achievable control technology
MEK methyl ethyl ketone
mgd million gallons per day
MIBK methyl isobutyl ketone
MSDS Material Safety Data Sheet
NESHAP National Emissions Standards for Hazardous Air Pollutants
Ni nickel
NPDES National Pollutant Discharge Elimination System
NPV net present value
NRMRL National Risk Management Research Laboratory
NTA nitrilotriacetic acid
ORNL Oak Ridge National Laboratory
P poise
Pa pascal
xn
continued
-------
TABLE 2. SELECTED PROPERTIES OF THE CHLORINATED DECREASING
SOLVENTS
Property
Chemical Formula
CAS No.
Molecular Weight
Boiling Point, at 101.3 kPa, °C
Freezing Point, °C
Specific Gravity, at 20°C
Density, at 20°C, kg/m3
Viscosity, at 20°C, cP
Heat of Vaporization, at 20°C,
kJ/kg
Heat Capacity, at 25°C, kJ/kg K
Heat of Combustion, MJ/kg
Vapor Pressure, at 25°C, kPa
Solubility in Water, at 20°C, g/kg
Flash Point (ASTM), °C
Critical Temperature, °C
Critical Pressure, °C
Critical Density, kg/m3
log Kow
DCM
CH2C12
75-09-2
84.92
39.8
-96.7
1.320
1,315.7
0.43
329.23
0.6369
1.1175
53. 3C
13.2
none
245.0
6.171
472
no data
PCE
C?C14
127-18-4
165.83
121.20
-22.7
1.62260
1,622.4
0.870
209. 2a
0.85
5.051598b
2.5
1.40
none
347.1
9.74
—
3.40
TCA
C2H,C13
71-55-6
133.05
74.00
-33.00
1.325
1,324.9
0858
248.11
1.004
6.69
16.5
0.95
none
311.5
4.48
—
2.49
TCE
C?HC1,
79-01-6
131.39
86.7
-87.1
1.465
1,460.0
0.58
240a
0.94
7.325
7.7d
1.07
none
271.0
5.02
—
2.29
a latent heat of vaporization at the boiling point
h heat of combustion, liquid at constant volume, 18.7°C
c vapor pressure at 24.1 °C
d vapor pressure at 20°C
Sources: Kirk-Othmer Encyclopedia of Chemical Technology, 1978
Hazardous Chemical Desk Reference, 1987
Hazardous Substance Data Bank
-------
ACKNOWLEDGMENT
The authors of this report would like to acknowledge the following individuals who
contributed their time, expertise, and information to the completion of this report. Without
their involvement this report and its contents could not have been possible.
• Michael McWilliams - Environmental Engineer, Calsonic Manufacturing Corporation:
Mike's daily involvement and patience offered the basic information for the report.
• Special thanks is extended to the project's industry partner, Calsonic Manufacturing
Corporation of Shelbyville, Tennessee. As a leading industry in the application of cleaner
technologies and processes, Calsonic's role in the project was immeasurable. Information
and expertise were shared openly. The involvement and support of engineers, supervisors,
and management offered the information and expertise required for this project to
succeed.
• Jack Geibig - Research Associate, and Andrew Core - Student Research Assistant, Center
for Clean Products and Clean Technologies: Their assistance with data collection and
analysis was greatly appreciated.
xiv
-------
Types of Aqueous Wash Systems. Aqueous cleaning systems can include alkaline solutions
and detergents to enhance their soil removal capabilities, or consist of solely hot water
washes. These systems are often used with pressurized sprays, agitation, ultrasonics,
filtration, heat, or some other physical process to further provide effective cleaning in many
industrial cleaning applications. Water-based cleaners have little or no volatile components,
which means that cleaning cannot take place in the vapor phase. Therefore, immersion tanks
are most commonly used for these applications in conjunction with heat and agitation.
Agitation can be accomplished with ultrasonics or by mechanically rotating the parts and/or
circulating the solution.
Because they apply immersion rather than a vapor phase process for cleaning, aqueous
cleaning systems are not usually drop-in replacements for chlorinated degreasing solvents.
However, some vapor degreasers and other solvent cleaning processes can be modified to
accommodate water-based cleaners. Large vapor degreasing units can be converted to
multiple tanks, and modified to incorporate spray rinsing, immersion, ultrasonics, mechanical
agitation, filtration, or other methods Immersion tanks that have a means for adequate
skimming of floating oils are the most useful aqueous method of cleaning blind holes and
complex geometries. Aqueous cleaning alternatives usually require the addition of rinsing and
drying steps after cleaning to accomplish comparable solvent degreasing results.
Aqueous Cleaning Ingredients. Some additives of aqueous cleaning systems include
synthetic detergents and organic surfactants, saponifiers, acids and alkalies, and corrosion
inhibitors. The combination of additives selected alter the foaming, wetting, and soil removal
properties of the solution.17 Detergents and surfactants are surface-active agents that emulsify
insoluble solids into solution. Saponifiers change water-insoluble fats and fatty acids into
water-soluble soaps. Oxidants may be added to loosen rust and stains for easy removal. Other
additives are used to penetrate the soils and wet the surface of the materials to be cleaned, to
precipitate or float the soils, and to neutralize the material. Depending on the requirements of
subsequent operations, rinsing may be required to remove residual films left by these additives
in the cleaning process.1X Large suppliers will typically formulate cleaners designed for the
particular soils to be cleaned and the subsequent production process.
Aqueous cleaners must be carefully evaluated for their compatibility with the materials
being cleaned and the cleaning equipment. Acid and alkaline cleaners may attack some metal
substrates. Caustics or strong alkalies will aggressively attack aluminum and zinc. Strong
acids will attack steel. Strong oxidizing acids like nitric acid and chromic acid will attack
copper. The application of ultrasonics in an aqueous system can also increase the
corrosiveness of the solution.19 In addition, alkaline cleaning systems sometimes have
problems with surface oil recontamination of the parts, rapid fluid depletion, long cleaning
time, and high maintenance.
An alternative approach to aqueous cleaning is the elimination of the detergent
additives and the application of only hot water to clean the soiled parts. Cutting oils, cooling
fluids, and other soils can be effectively removed by a hot water spray, and the issue of
additive compatibility is eliminated. Ease of operation can also be an added benefit of a hot
water spray system; the oils and greases separate more quickly from the water phase (float to
the water's surface) than would be observed with detergents that emulsify the oils. This
allows for skimming of the oils and grease and easy water recirculation minimizing or
eliminating the need for pretreatment Eliminating the need for monitoring and adjusting the
11
-------
the 33/50 Program, the technologies that will be evaluated have a broad range of applications
within industry. This should offer pollution prevention benefits beyond the reduction of
national pollution releases and off-site transfers of the 33/50 chemicals.
OBJECTIVES OF THIS RESEARCH
The "Cleaner Technology Demonstrations for the 33/50 Chemicals" project is a
cooperative agreement between EPA and the Center for Clean Products and Clean
Technologies funded by NRMRL in support of the 33/50 Program. The overall objective of
this project is to demonstrate substitutes for the 33/50 chemicals in order to encourage
reductions in their use and release. For the substitutes that will be evaluated, this study has
objectives in the areas of technical, environmental, economic and national impact evaluations.
The following are the specific objectives in each area:
1. technical evaluation
° evaluate the effect of a substitute on process and product performance
as compared to the 33/50 chemicals
2. environmental evaluation
n evaluate the potential for reduction in releases and off-site transfers of
the 33/50 chemicals in the production process or product stage in
which the 33/50 chemicals are used and released
° compare the overall life-cycle environmental attributes of the 33/50
chemicals and the substitute for the same use
3. economic evaluation
° evaluate the total cost of the substitute as compared to the 33/50
chemicals
4. national environmental impact evaluation
° evaluate the environmental impact of replacing the 33/50 chemicals
with the substitute on a national scale
This report represents the first such demonstration project to be completed under the
EPA NRMRL project. It focuses on substitutes for solvent degreasing processes that
eliminate the use of chlorinated organic chemicals. This subject was selected from seven
priority uses of the 33/50 chemicals identified in "The Product Side of Pollution Prevention:
Evaluating the Potential for Safe Substitutes," a report by the Center for Clean Products and
Clean Technologies (hereafter referred to as Center).2 These seven priority uses are shown in
Table 1.
-------
cases, cleaning may not be required at all. Furthermore, the manufacturing processes can
sometimes be rearranged to require fewer cleaning steps.
Developing alternative methods that do not require cleaning means reevaluating the
steps in the manufacturing process which introduce materials that must be cleaned. For
example, the printed circuit board industry has developed no-clean flux technologies that
eliminate the need to clean flux from some printed circuit boards. Unfortunately, use of new
technologies is often stymied by their lack of working history. Industries that are required to
comply with government specifications may have difficulty introducing no-clean technologies
that require process modifications or product redesign. Specifications for manufacturing parts
for the military often dictate the type of cleaning solvent and the cleaning process to be used.
Unfortunately, changing government specifications is a long and arduous process that may
slow progress in the use of safe substitutes.
No-clean processes require innovative, optimized manufacturing to eliminate cleaning.
They save time and chemicals and reduce the regulatory burden and potential liability that
results from using hazardous chemicals. The disadvantages of no-clean technologies are that
they may require process modifications and even product redesign.
13
-------
! »^r— "i
.31 ^
-^->j AEROSOLS 1
r ^J POT vr
-K-W PL....™,, ^^^POLYC
i - - ^^J
14 "^i TRIACI
-^— ->j URETHANE FOAM BLOWING AGENT L
.11 ^J
*] PHARMACEUTICALS
TSJjk"TAL °R PARTS OEGREASINCrV
^ *] ELECTRONICS
' Jt BBVBTr
HYDROCHLORINATION Hrpwi 98 ^J ™ I— -""" ' '
nv MPTUAVnT [CPMJ >H FLUOROCARBON 22 L
Or METHANOL i ' L ._ p\ JQ
' >[~CTc] ^^ FLUORO1
V
r " " — f 1
HYDROCARBON > CTC f l-LUOROCARBONS | •
1 CHLORINOLYSIS peg
CHLORINATION f — 1
OF EDC OR >• r*06
OF EDC
.49
11 and 12 L — _______^
- - — r^\^ — *• AI
^~^~-.^
^"^^ HEA
ARBONATE
TATE FIBER
JERANTS
•OLYMERS
RKJERANTS
EROSOLS
r TRANSFER
50 I " ~ "~~ " 1
—- >) DRY CLEANING & TEXTILE PROCESSING |
27 I - — - 1 ^H*™
>| FLUOROCARBON F-l 13 r'
^^H s
H^^ MFTAL OR PARTS DECREASING J^N
--* *• »•- -»-.^k '^- j^>. -~%,-j^.A^k_^fc_ _^ •^ ^ ^ ^ •^.^W^^.^W^W^
.63
LfAj | •--->! AEROSOLS
UGERANTS
OLVENT
VAPOR DECREASING
VAPOR DECREASING
COLD CLEANING
NEOPRENE ADHESIVES
COATINGS AND INKS
DRYCI EANING AND TEXTILE PROCESSING
FIGURE 1. CHLORINATED ORGANIC CHEMICALS
Key: DCM = methylene chloride, CFM = chloroform, CTC = carbon tetrachlonde
PCE = perchloroethylene, TCE = tnchloroethvlene, TCA = 1,1,1 -tnchloroethane
Notes: 1.
2.
Reliable data were not available to estimate weight fractions along some branches of the
chemical-use tree.
The numbers along each branch are weight fractions of the usage of the chemical or product u
the first box to produce the chemical or product in the second box. Where there is a box that i
divided, the chemicals or products are co-products.
in
is
-------
TABLE 3. CHRONOLOGY OF CHANGES AT CMC
Year
1991
1992
1993
1994
Radiator
installation of aqueous
wash system eliminating
five vapor degreasers
(October, 1991)
installation of in-house
tube manufacturing mill
(August, 1992)
no pertinent changes
no pertinent changes
Condenser
no pertinent changes
no pertinent changes
installation of no-clean
fin corrugation system
eliminating two vapor
degreasers
(June, 1993)
no pertinent changes
Converter
no pertinent changes
no pertinent changes
installation of hot water
wash; elimination of one
vapor degreaser
(December, 1993)
no pertinent changes
Radiators are designed to hold a large volume of water and antifreeze in proximity to a
large volume of air to allow efficient heat transfer from the fluid to the air. The radiator core
consists of two parts, one for the passage of liquid and the other for the passage of air. CMC
manufactures the tube-and-fm type of radiator core, consisting of a series of long tubes
extending between a top tank and bottom tank of the radiator. In this type of configuration,
fins are placed between the tubes; air passes between the fins and around the outside of the
tubes, absorbing heat from the fluid in the tubes.
Figure 2 is a process flow diagram of CMC's radiator line. Rolls of aluminum are
lubricated with a forming (napthenic) oil, placed through fin corrugators, and cut to length.
Once formed and cut, the fins are sent to assembly. There are five fin corrugators in the
radiator line. Aluminum is rolled into tubes at a rolling station, cut to length and sent to
assembly. Excess coolant used in the rolling process is manually rinsed from the completed
tubes with a small amount of water. EJidplates are supplied by another company.
The fins, tubes and endplates are assembled in a jig to complete the radiator core.
After assembly, a conveyorized aqueous wash is used to remove forming oils, cutting oils, and
the remaining coolant from rolling the tubes. The conveyorized aqueous wash process begins
with a water wash, intended to remove the majority of the contaminants, followed by a heated
detergent bath, and completed by a hot water rinse. Effluent from the aqueous wash process
is sent to a wastewater treatment plant at the facility for pretreatment prior to discharge to the
local sewer system. After the aqueous wash, flux is applied, followed by drying, brazing,
assembly of the radiator core with the nylon fluid tanks (also manufactured at CMC), and leak
testing.
15
-------
CHAPTER 2
MATERIALS AND PARTS CLEANING
Within several industrial sectors, solvents and solvent blends of halogenated and
nonhalogenated organic chemicals are employed as solvents to clean organic materials, water-
insoluble soils, inorganic salts, and foreign particles from manufactured materials or parts.
Methylene chloride, perchloroethylene, trichloroethylene, and 1,1,1-trichloroethane (hereafter
referred to as the chlorinated degreasing solvents) have been the traditional chlorinated
solvents used in degreasing processes due to their physical and chemical properties. In recent
years, however, increased awareness of the health, safety, and environmental issues
surrounding their use has stimulated research into substitutes for the chlorinated degreasing
solvents. This chapter reviews the processes of materials and parts degreasing, briefly
discusses the regulations concerning the solvent degreasing chemicals and processes, and then
identifies and discusses safe substitutes for chlorinated solvent degreasing.
MATERIALS AND PARTS DEGREASING DESCRIPTION
Materials and parts degreasing is an integral part of many industrial processes,
including the manufacturing of automobiles, electronics, furniture, appliances, jewelry, and
plumbing fixtures. Degreasing is also frequently used in the textiles, paper, plastics, and glass
manufacturing industries. It is most often employed as a surface-preparation process to
remove contaminants and prepare raw materials and parts for subsequent operations like
machining, painting, electroplating, inspection, and packaging. In 1991, it was estimated that
24,500 chlorinated solvent degreasers were operational within the United States.4 The variety
of solvent degreasing equipment falls within three basic configurations: cold cleaners, open-
top vapor degreasers, and conveyorized degreasers.5'6 These systems, and a hybrid of them,
are briefly discussed below.
Cold Cleaning
Cold cleaners are usually the simplest and least expensive of the three types of
degreasing equipment. Parts are cleaned by being immersed and soaked, sprayed, or wiped
with solvent. A typical cold cleaner consists of a tank filled with solvent and a cover for
periods of nonuse. More sophisticated cold cleaners are equipped with solvent sumps, spray
nozzles, drains, and automatic controls.
In the basic cold cleaning process, soiled objects are dipped into the solvent bath to
dissolve the contaminants from their surface. This cleaning process can be enhanced by
agitating the solvent, or by brushing or spraying the solvent onto the soiled objects. Cold
cleaning is usually conducted at room temperature and ambient pressure, although in some
cases the solvent may be heated, but not above its boiling point. When the parts are removed
from the immersion bath, solvents are allowed to drain and evaporate from the parts.7
-------
In 1991, CMC converted the cleaning step in the radiator line from a vapor degreasing
process to the current aqueous wash system. Previously, five batch vapor degreasers were
used to clean the assembled radiator core, one located at each fin corrugation and assembly
station. Under this process scheme the radiator core was an assembly of corrugated fins
(process above) and prefabricated tubes and endplates supplied by another company. These
assemblies were then cleaned in one of the five vapor degreasers. CMC used TCA as the
degreasing solvent. The use of TCA resulted in releases of TCA to the air from the process,
releases to water (wastewater) from solvent carryover on parts to subsequent process units,
and a hazardous waste stream of spent TCA. CMC sent this hazardous waste stream to an
off-site recycling facility. Figure 3 shows the location of the vapor degreasing step and
potential sources of TCA releases in the previous radiator process. CMC switched from
prefabricated tubes to in-house formation after the aqueous wash system became operational.
No other changes have been made in the radiator manufacturing process or operating
conditions since that time.
Radiators are leak-tested using a Freon-based (R-22) pressure-decay system. In this
system each completed radiator is pressurized using a mix of R-22 and nitrogen. To pass the
test procedure, the pressure must be maintained for a dwell-time specified in the Radiator
Process Control Plan.
THE CONDENSER LINE AND NO-CLEAN TECHNOLOGY
CMC manufactures condensers for use in automobile air conditioning systems. The
condenser consists of a serpentine tube on which fins have been mounted. Compressed vapor
passes through the tube; air passing around the fins and between the tubes removes heat from
the compressed vapors. The cooled vapor condenses and runs into a receiver-dryer.
Figure 4 is a process flow diagram of CMC's condenser line. In 1993, Calsonic
converted its fin manufacturing process from a conveyorized solvent degreasing process using
TCA (Figure 5) lubricant to remove a petroleum-based lubricant to a no-clean process using
an "evaporative lubricant" (also called vanishing oils). In this no-clean system, rolls of
aluminum are lubricated with a low-boiling-point oil and placed through a fin corrugator. The
fin then passes through fin driers to evaporate the oils, resulting in a no-clean process for fin
manufacturing. CMC operates four fin corrugator stations in the condenser line. In the
current system, the corrugated fin is still conveyed through the now empty vapor degreasing
chambers, then cut to length and sent to assembly. A comparison of the petroleum-based
lubricant and the evaporative lubricant is presented in Table 4.
17
-------
A good degreasing solvent should have excellent solvency for a broad range of organic
materials, particularly oils and greases. The solvent should preferably be nonflammable
especially m vapor degreasing applications, and be noncorrosive to the metals or parts being
cleaned and the degreasing equipment. A good degreasing solvent should also have low
toxicity. Additional properties desired in a degreasing solvent include a low heat of
vaporization, a high vapor pressure that allows evaporative drying of cleaned parts and
chemical stability. '
Degreasing Properties
The chlorinated degreasing solvents have been extensively used in industrial
applications of cleaning, primarily because of their excellent solvency, nonflammability, and
high vapor pressures. Additionally, their vapors are heavier than air and thus can be
somewhat contained within the degreasing equipment. Only recently have health, safety, and
environmental issues concerning their use and disposal contributed to a decrease in their use
as degreasing solvents and to a search for substitutes.
DCM, PCE, TCA, and TCE share several common physical features. They are
volatile, colorless, nonflammable liquids characterized by a sweet or ether-like odor. Their
high chlorine content gives their liquids and vapors relatively high density and also reduces
their ability to support combustion. They are subject to decomposition by hydrolysis with
water and by high temperatures, oxygen, and sunlight. They are only slightly soluble in water
and are miscible with most organic liquids. Table 2 shows selected physical properties and the
chemical formulae of these compounds.
Health, Safety, and Environmental Properties
Just as the chlorinated degreasing solvents have similar physical properties, they also
have similar health, safety, and environmental issues associated with their production and use
Low level and short duration exposure to these chemicals causes irritation and inflammation
of the nose, throat, eyes, and respiratory tract. All but TCA are classified as possible or
probable human carcinogens by EPA. All four compounds are central nervous system (CNS)
and respiratory depressants. Exposure to DCM, PCE, and TCE is associated with liver and
kidney problems.13 TCA is an ozone depleting chemical.
The major routes of exposure to these compounds are through inhalation or ingestion,
although dermal exposure may occur from absorption through the skin. Air emissions
account for the largest environmental releases of these compounds, due to their high volatility
Land disposal of these chemicals is prohibited under the Hazardous and Solid Waste
Amendments of 1984. The chlorinated degreasing solvents are also highly mobile in soil and
groundwater and are common groundwater contaminants.14
-------
19
-------
REGULATORY BACKGROUND
Regulations, recently enacted and expected, for the chlorinated degreasing solvents
and the degreasing process could promote the application of alternative cleaners and cleaning
systems for degreasing. Among the most recent regulations for chlorinated degreasing
solvents is National Emissions Standards for Hazardous Air Pollutants (NESHAP)
promulgated under the Clean Air Act.
The NESHAP, finalized by EPA in November 1994, sets maximum achievable control
technology (MACT) standards for owners and operators of halogenated solvent cleaning
machines. The MACT standards cover batch vapor solvent cleaning machines and in-line
solvent cleaning machines, and are designed to regulate the emissions of methylene chloride,
perchloroethylene, trichloroethylene, carbon tetrachloride, and chloroform. Publication of '
these standards occurred on December 2, 1994 in the Federal Register. NESHAP
enforcement is expected by mid-1995.] 5
Furthermore, as a result of the Montreal Protocol and the subsequent Presidential edict
by President Bush, the manufacture of TCA and carbon tetrachloride (two Class I ozone
depleters) must cease by the end of 1995 within the U.S.16
SAFE SUBSTITUTES FOR THE 33/50 DEGREASING SOLVENTS
Several viable alternatives for the chlorinated degreasing solvents and the degreasing
process exist. Substantial pollution prevention progress is being made in metal and parts
cleaning by using these alternatives. Safe substitute approaches to reducing the use of
chlorinated organic chemicals in the degreasing process include the following:
n using no-clean manufacturing methods;
n substituting safe, aqueous, or semi-aqueous degreasing solvents for the
chlorinated organic solvents,
° substituting safe, non-aqueous degreasing solvents for the chlorinated organic
solvents; and
° substituting non-liquid cleaning technologies for the degreasing process.
Many of these approaches are already seeing widespread use because of pending or potential
regulations affecting the chlorinated solvents and their potential to contribute to
photochemical smog or ozone depletion. This demonstration project will focus on two of the
above process alternatives which have been implemented by CMC: an aqueous degreasing
process and a no-clean manufacturing option. These alternatives to solvent degreasing are
discussed below.
Aqueous Wash Systems
Aqueous cleaning systems, or parts washing, have been used for years to remove salts,
rust, scale, and other inorganic soils from ferrous metals. In recent years, the metal parts and'
metal finishing industries, such as CMC, have identified and applied aqueous cleaners and
cleaning systems as substitutes for solvent vapor degreasers.
10
-------
TABLE 4. COMPARISON OF LUBRICANT PROPERTIES
Property
Hazard Composition
Boiling Point (°F)
Vapor Pressure
(mmHg)
Vapor Density
(air=l)
Specific Gravity
(water = 1 )
Melting Point
Evaporation Rate
(butyl acetate = 1)
Solubility in Water
Flash Point (°F)
LEL
UEL
Petroleum-based Lubricant
"not considered hazardous"
520
<0.01
>5
0.88
not applicable
<0.01
negligible
320
1%
6%
Evaporative Lubricant
"none"
323. 6 (IBP)
< 10
> 1.0
0.764
__
negligible
negligible
127.4 (PM)
__
—
Source: Material Safety Data Sheets of each product
To make the serpentine tube, rolls of purchased extruded aluminum are placed in a
bender, bent to shape, and then cut to length. CMC operates two bending stations in the
condenser line, with three aluminum rolls per bender. Tubes are sent to a conveyorized vapor
degreaser to remove cutting and hydraulic oils from the bending operations. Following this
step the tubes are coated with zinc oxide to inhibit corrosion and improve the paintability of
the aluminum substrate, and assembled with the fins to form the condenser core. After
assembly of the condenser core, flux is applied, followed by brazing and leak testing with
helium. After leak testing, the core is painted, followed by final assembly of the condenser
core with the receiver-dryer, and final leak testing using R-22.
The helium leak testing procedure is also a pressure-decay type method but is
complicated by the small size of the helium molecule which makes it easier to leak. As with
the radiator line, leak testing is accomplished by pressurizing each part with helium and then
measuring the rate of pressure decay. Acceptable parts must maintain pressure for a specified
dwell time outlined in the Condenser Process Control Plan. Prior to helium leak testing, CMC
used R-22 and nitrogen for both leak testing steps for the condenser line. The procedure
follows that outlined in the radiator line.
21
-------
concentration of additives in the aqueous solution can also free operator time for other
activities. These simplified management and waste disposal issues, discussed below, can be
advantages of the hot water systems.
Effects on Wastewater Treatment Capacity. Significant changes in the characteristics of
wastewater and wastewater flow rate are also issues that must be considered when changing
to aqueous cleaning systems. The treatment and disposal of the aqueous cleaning solutions is
an important consideration when changing to an aqueous system. Some additives create new
health and safety or treatment and disposal issues. Detergents and surfactants may not be
readily biodegradable; the solution's pH may be unacceptable for direct discharge; cleaning
solutions containing saponifiers tend to have high biochemical oxygen demands (BODs) which
may exceed limits in National Pollutant Discharge Elimination System (NPDES) permits and
Publicly Owned Treatment Works (POTW, or municipal wastewater treatment plants)
pretreatment permits. As a result, pretreatment prior to discharge to the sewer system may be
required to meet local, state, or federal requirements.
As a response to these disposal issues, "closed-loop" aqueous cleaning systems have
been developed which minimize the process water that must be treated, and concentrate the
oils and other contaminants for disposal. These closed-loop systems can include filtration
(micro or ultra), gravity separation, adsorption, and chemical treatment units which recirculate
the water back to the cleaning system and concentrate the contaminants.20 The hot water
wash system may increase the application of closed loop systems. The elimination of additives
for the aqueous wash may simplify oils and soils separation from the water. Furthermore, the
filtrations and adsorption systems will not be fouled by the present of detergent products.'
No-Clean Technologies
The most fundamental technique for eliminating the use of degreasing solvents is to
design processes and/or use materials that do not require cleaning. This is most readily
achieved when designing new products or new manufacturing processes. Still, existing
facilities, such as CMC, may realize cost savings and dramatically decreased potential
environmental liabilities by reconsidering their existing processes and developing alternative
methods that do not require cleaning.
Reconsidering an existing process means evaluating the present cleaning operation, as
well as the process line, both up-stream and down-stream of the cleaning step. Up-stream of
the cleaning step, processes that introduce the soils (oils, greases, etc.) that must later be
removed should be evaluated to determine whether alternative materials can be substituted
that do not require cleaning, or whether the soil material can be eliminated completely. An
example of a no-clean technology is the replacement of lubricating oils with a mineral spirit-
based vanishing oil. Due to its relatively high vapor pressure, the mineral spirit-based oil can
be removed using flash-drying or other technologies such that the substitute does not require
cleaning prior to subsequent operations. This process still results in an air emission, but one
of the objectives of this study was to evaluate the relative amount and toxicity of the air
releases from the TCA vapor degreaser as compared to the evaporative lubricant system.
Considering process requirements down-stream, the current degree of cleanliness
specified may not be required to satisfactorily perform the next manufacturing step. In some
12
-------
w
H
X
tf
I
i
bO
•s g
£ §
f §
11
(U
ta
tn
^
" £P
=5 S
w
H
H
O
W
w
X
H
Pd
S
^
w
23
-------
CHAPTER 3
CALSONIC'S CHLORINATED SOLVENT SUBSTITUTES PROGRAM
The Center for Clean Products and Clean Technologies worked with an industry
partner to evaluate the technical, environmental, and economic merits of alternative cleaners
and systems for the chlorinated degreasing solvents. This industry partner, Calsonic
Manufacturing Corporation (CMC , had initiated a number of changes to eliminate TCA from
their manufacturing process. The background of CMC and a brief overview of the process
changes pertinent to this project are presented in this chapter.
BACKGROUND INFORMATION ON CALSONIC
CMC is a Japanese-owned, American-managed company located in Shelbyville,
Tennessee, with several sister companies throughout the U.S. and the world. In Shelbyville
CMC employs approximately 800 persons and has more than 430,000 ft2 of manufacturing
area divided between two sites and three buildings. CMC manufactures automotive parts,
including heaters, blowers, cooling units, motor fans, radiators, auxiliary oil coolers and
exhaust systems.
The automotive parts manufactured by CMC are composed of a variety of materials
including nylons, polypropylenes, aluminum, and stainless steel. Part configurations range
from complex extruded metal parts and serpentine parts to flat-surfaced injection-molded
plastic parts. Part cleanliness requirements vary and are dependent on subsequent process
steps.
Over the past four years, CMC has begun to evaluate and implement a number of
environmental improvements in its manufacturing processes. An internal schedule set by
CMC to eliminate all TCA cleaning operations by the end of 1994 was met in November of
that year. This phase-out was accomplished through the application of aqueous cleaning and
no-clean technologies. This research focuses on three CMC process lines which utilize
substitutes for solvent degreasing: 1) the aqueous wash system in the radiator line; 2) the no-
clean technology in the condenser line; and 3) the hot water wash of the converter line. A
chronology of these changes is presented in Table 3. The following sections describe the
manufacturing lines which employ these processes.
14
-------
CHAPTER 4
TECHNICAL EVALUATIONS
The technical evaluation of CMC's process alternatives to solvent degreasing revealed
positive merits of their implementation. The aqueous wash system cleaned parts 80 percent
faster than the solvent system, and improved parts' cleanliness resulting in a 76.8 percent
decrease in part reject rates. The no-clean system had no effect on cycle time or part reject
rates as compared to the solvent systems. The management, supervisors, and line personnel
believe both alternatives create a more efficient production process.
TECHNICAL BACKGROUND
Several basic questions must be asked of any industry/business to simplify the switch
from a solvent degreasing system to a safe and effective alternative. These basic questions
include subjects such as cleanliness desired and required (desired levels may not be required
for subsequent processing), substrate characteristics, soils (source and characteristics), and
process/facility specifications. Research Triangle Institute has developed the Solvent
Alternatives Guide (known by the acronym of SAGE) to answer many of these questions. By
entering information about the current solvent cleaning process and cleaning requirements,
SAGE recommends a variety of solvent alternatives. SAGE is an electronic handbook
designed to work on a PC-AT (or better) computer system, and is distributed by the EPA. In
addition to this computer program, there are also a number of literature sources which address
similar issues; "It's Time to Panic," by Robert B. Aronson21 and "Solvent Cleaning
(Degreasing), An Assessment of Emission Control Options," by the Center for Emissions
Control are only two specific examples.22
A significant number of studies are also being conducted, or have been completed,
which evaluate the effectiveness of cleaning alternatives. Some studies evaluate the
effectiveness of various alternative solvents and cleaning solutions for removing specific soils.
Such studies are being conducted by the Department of Energy, Oak Ridge National
Laboratory (ORNL), in Oak Ridge, Tennessee, and the Toxics Use Reduction Institute
(TURI) at the University of Massachusetts, Lowell, Massachusetts. In the ORNL study, a
variety of pure solvents are evaluated for their ability to remove specific standard soils (e.g.,
lubricating oils, fingerprints, etc.) from metal substrates; the cleanliness of each tested part is
determined at a molecular-layer level TURI operates the Surface Cleaning Laboratory
designed to assist companies in the transition away from solvent-based technologies by
providing objective information and testing services. This study differs from other research
because it brings information on the technical, economic, and environmental impacts of
alternatives together, using a life-cycle perspective and actual industrial experiences.
The procedure taken by CMC' to determine which alternatives to employ included
extensive vendor consultation, initial performance screenings, and pilot testing of the
promising alternatives. Identifying and contacting vendors of available alternatives were the
responsibilities of the line engineers for each process. These vendor contacts were used to
identify applicable alternative cleaning systems and to perform initial screening tests to
determine the alternatives' effectiveness. Vendor contacts and screening tests for the radiator
25
-------
1
1
**
'£
I
If
f
!
assembly of
core with tanks
A
t
nylon tanks
^
f
1
^
i
distribution
-------
reliability of the aqueous wash system allows CMC to focus attentions to other units, further
optimizing the entire process.
Condenser Manufacturing Line. Similar production rate data were not available for the
condenser manufacturing line. However, interviews with line and quality control personnel
indicated that the implementation of the evaporative lubricant system to replace the solvent
degreasers did not affect the cycle time for fin production.
The Evaluation of Part Reject Rates
The second parameter used to evaluate the technical feasibility of the alternatives was
the core reject rate. For CMC, cores are either recorded as production or scrap based on the
results of leak tests performed on each and every unit manufactured. The cleanliness of the
assembled core before fluxing and brazing directly affects the quality of the braze. Brazing of
the radiator or condenser cores not only protects the product from corrosion, but also seals all
tube-to-tank joints to create a leak-proof product. When the core is not adequately cleaned,
the aqueous solution of flux cannot properly penetrate all areas of the core. This, in turn,
results in a poor braze and potential leaks.
Radiator Manufacturing Line. The current radiator line, using a petroleum-based lubricant
in processes prior to cleaning, accomplishes the required level of cleanliness by detergent
cleaning within the aqueous wash system. The lubricant, if not sufficiently removed from all
areas of the radiator core, will repel the aqueous flux and result in a poor braze and possibly a
rejected core due to leaks. Cleaning was previously accomplished by the five solvent
degreasers.
Identical data sets as those used for the analysis of the production rate were used here
for the analysis of the part reject rate. Specifically, a data set prior to October 1991, and a
data set between October 1991 and August 1992 were analyzed to capture the potential
effects of the cleaning process. Statistical analyses of this part reject rate data indicate that the
aqueous wash system improved the level of cleanliness when compared to the solvent
degreasing system. Comparing the mean of each data set shows that the radiator core reject
rate decreased 76.8 percent after the aqueous wash system was implemented. This decrease is
apparent in Figure 8 which presents normalized radiator reject rate data for the time periods
statistically analyzed. Historic data are not presented in this report in raw form, however.
Analyses summaries and normalized values are given to ensure confidentiality. The methods
and results of the statistical evaluations performed ("chi square" and "student T") are
presented in Appendix C
The availability of these data were due to an on-going "Radiator Task Force"
established by CMC to reduce the reject rates for the radiator line. Established in early 1991,
this Radiator Task Force analyzed the factors that resulted in rejected cores and improved
process parameters to minimize reject rates. Through the efforts of this Task Force, and its
support of the aqueous wash system the reject rate of the radiator line was decreased 76.8
percent after the aqueous wash system was implemented.
Condenser Manufacturing Line. The condenser line, by using an evaporative lubricant,
eliminated the need for additional cleaning to achieve adequate flux penetration and a high-
27
-------
18
-------
SUMMARY OF THE TECHNICAL EVALUATION
The elimination of the solvent degreasing units from the radiator and condenser
manufacturing lines was accomplished by the implementation of the aqueous wash system and
application of the evaporative lubricant. The technical merits of these alternatives were
determined by evaluating the cycle time and product reject rate for each manufacturing line.
Based on these parameters, the technical merits of the alternatives were either neutral (no
discernable effects), or positive (processing improvements).
Due to the historic dates of the process changes, portions of the part reject rate data
were not available. To accommodate for these data, interviews with process-line employees,
line supervisors, and management were used Discussions with line supervisors regarding
process control plans for each manufacturing line supplied cycle time data. Radiator reject
rate data were available for periods prior to and after the process change to the aqueous wash
system. Statistical analyses of these data were performed. Reject rate data for the condenser
line were gathered through interviews with CMC employees; line personnel, supervisors, and
quality control personnel. Using the available information and employee interviews, the
following conclusions can be made.
Aqueous Wash System of the Radiator Manufacturing Line
The cycle time per manufactured part was decreased by 50 percent with the
implementation of the aqueous wash system. Two characteristics of the aqueous wash system
contribute to this decrease in cycle time. First, the aqueous wash system is a continuous
process, as compared to the batch system of the solvent degreasers. Second, the aqueous
system is a more reliable system requiring less down time and maintenance when compared to
the solvent systems.
The aqueous wash system also reduce the part reject rate, significantly. When
compared to the previous degreasing operation, a reduction of over 76 percent in the rate of
part rejects was observed after the aqueous wash system replaced the five vapor degreasers
previously used to clean the radiator cores prior to subsequent processing.
Evaporative Lubricant System of the Condenser Manufacturing Line
The evaporative lubricant, which replaced a petroleum-based lubricant in the fin
corrugation process of the condenser line, showed no impact on either the rate of production
or part reject rate of this manufacturing line.
29
-------
«rj
§
8
^
H
1 1
GQ P
o
u
— —
i
i
^^
— i
r_:ril
, .__!_ 1 v
«
13 S
^ *
a '
*j
i.
i
i
••3
A
a
|
"S"
8
tt
&
u
oo
I
20
-------
1993 condenser line vapor degreasers and the utilization of petroleum-based
lubricants operational for five (5) months, evaporative oils utilized the
remaining seven (7) months (i.e., elimination of vapor degreasers); and
1994 first full year evaporative lube system was operational.
TABLE 5. GOALS OF WASTE MANAGEMENT PLAN BY WASTE STREAM
Waste Stream
1,1,1-trichloroethane3
flammable liquid
CFCs
methylene chloride
chromic acid
sodium hydroxide
flammable solid
petroleum naphtha
hazardous waste solid
Waste Generation,
1989(lb/yr)
168,000
9,480
36,755
8,338
7,815
13,327
2,981
1,224
66,549
Goal
90% reduction by 1995
80% reduction by 1995
no numeric goal set
100% reduction by 1992
100% reduction by 1995
100% reduction by 1994
(condenser line only)
60% reduction by 1995
100% reduction by 1995
no numeric goal set
a 1,1,1 -tnchloroethane is the chemical associated with the cleaning processes and the focus of this
evaluation.
Source: CMC's Waste Management Plan
Table 6 presents CMC's TCA release and transfer data from the TRI database for the
five years of interest. CMC maintains manifest records and reports TRI emissions on a
facility-wide basis, not line-by-line. Therefore, a variety of information to supplement Table 6
is given to estimate the impacts of each process change. TCA consumption, hazardous waste
generation, and air release estimates lor the radiator and condenser manufacturing lines are
presented in Figure 9.
31
-------
THE CONVERTER LINE AND HOT WATER WASH SYSTEM
CMC installed a hot water wash system to replace a third application of solvent
degreasers. The process flow diagram of CMC's current catalytic converter assembly line
which utilizes this hot water wash system is pictured in Figure 6. The catalytic converter shell
and flanges, the ceramic substrate and wire mesh separator are supplied by other
manufacturers. After receipt, the catalytic converter shell and flanges are cleaned in a
conveyorized hot water wash system to remove cutting and lubricating oils left by the
manufacturer. The wash system consists of a hot water spray zone, followed by a second hot
water spray (rinse) zone and a drying oven. After cleaning, the ceramic substrate and wire
mesh separator are inserted in the two shell halves, which are then welded together with the
flanges. Each catalytic converter is leak-tested using an air-based pressure-decay system. The
converters then continue along the process train to be incorporated into the exhaust system.
Until December 1993, Calsonic used a conveyorized vapor degreaser with TCA as the
degreasing solvent (Figure 7). The current equipment used in the hot water wash system was
converted by CMC from an obsolete muffler washing system and a defunct paint spray booth
and curing oven. Although in operation, this system is still in the development stage; CMC
has not yet completed equipment conversions. For this reason, this process is not
quantitatively evaluated in this study.
22
-------
350
300
275
250-
225
200
,75-
150
125
100
"
50
25
1990
Estimated line contributions to
TCA quantities purchased
r Estimated line contributions to
J TCA hazardous waste generation
Estimated line contributions to
TCA air emissions
121.5
1992
Year
000
1994
FIGURE 9. TCA RELEASES AND TRANSFERS FROM THE RADIATOR AND
CONDENSER MANUFACTURING LINES - 1990 TO 1994
1990 chemical purchase and emission quantities represent estimates from the radiator and condenser
manufacturing lines. Air releases were determined by subtracting TCA hazardous waste generation
estimates from TCA consumption quantities.
1992 chemical purchase and emission quantities represent estimates from the condenser manufacturing
line. Air releases were determined by subtracting TCA hazardous waste generation estimates from TCA
consumption quantities.
33
-------
f I
s
•a
h
i
T3
g <
2
u
i
^ >
•3
I
1
to ^
^ |
iJS *^3
CQ 2
0 S
k §-
a
1
s
•a
o
24
-------
TABLE 7. CMC TRI OFF-SITE TRANSFERS OF TCA
Year
1990
1991
1992
1993
1994
Off- Site Transfers
(lb/yr)
233,530
338,525
206,345
194,975
109,000a
Percent Change
_
45.0%
-39.0%
-5.5%
-44.1%
a Extrapolated for 1994 based on 11 months of TCA purchase and hazardous waste manifest records.
Source: TRI, 1992
Radiator Manufacturing Line
While the aqueous wash system of the radiator line eliminated the use of TCA and thus
the waste streams generated from that use, additional land-disposed waste streams are created
by this alternative process. The first such waste stream is a non-hazardous, oily waste
generated in the first rinse tank of the aqueous wash system. Designed to remove the majority
of oils and soils to reduce the burden on the detergent wash step, this first rinse tank
accumulates oils and solids. The oils float to the top of the water reservoir, and are skimmed
off and periodically (once every two or three weeks) collected in a 55 gallon drum. The
solids, which settle to the bottom of the water reservoir, are collected weekly when the tanks
are drained and cleaned. These solids, the volume of which is minimal, are also collected in
the 55 gallon drum. The quantity of non-hazardous, oily waste generated yearly is
approximately 1,320 gal (or 11,000 Ib at 8.2 Ib/gal) and is processed for fuel at an off-site fuel
blending facility. This oily waste stream, segregated by the aqueous wash system, does not
represent a new waste stream. These oils and greases were dissolved by the TCA of the
solvent degreasing systems and disposed of off-site in the spent solvent.
The second additional land-disposed waste stream generated from the aqueous wash
system is the solids generated at the industrial wastewater pretreatment facility operated on-
site by CMC. The manufacturing processes of CMC, including the aqueous wash system,
generate nearly 25,000 gal/d of wastewater which CMC pretreats prior to sewer discharge.
This pretreatment process, discussed in more detail in the "Releases and Transfers of Water,"
generates a non-hazardous, solids waste stream. The rate of solids generation for the entire
facility was approximately 26,400 gal/yr. The average wastewater flow rate from the aqueous
wash system (explained below) represents approximately 30 percent of the total wastewater
flow treated by CMC. If it is assumed that sludge generation is directly proportional to the
wastewater flow rate, approximately 30 percent of the solids generated during wastewater
pretreatment, or 7,900 gal/yr (or 64,700 lb/yr at 8.2 Ib/gal), may be attributed to the aqueous
wash system of the radiator line. This assumption may not reflect the true influence of the
35
-------
line lasted eight months; the aqueous wash system was considered the most effective and
feasible alternative after that time. Approximately one month was required for condenser line
alternatives' screenings; the evaporative lube alternative was previously documented in the
screening tests for the radiator line. Initial performance screenings included black light tests
of cleaned parts, as well as leak tests and braze-bond efficiencies; example test results are
included in Appendix B. Finally, full-scale trial runs were conducted to test alternative
process performance with the rest of the manufacturing process. Both the aqueous wash
system (radiator) and the evaporative lubricant (condenser) were implemented at CMC
following these procedures.
CMC TECHNICAL EVALUATION
The objective of the technical evaluation was to determine the effects the substitutes
had on process and product performance compared to the 33/50 chemicals. For this study,
process and product performance were used as the two parameters to evaluate the technical
merits of the alternative cleaning systems. As part of a continuous manufacturing line, the
cleaning process (or no-clean alternative) has the potential to influence both of these
parameters. Process performance of the alternative processes was defined as the cycle time
required to clean a single unit. As a potential bottle-neck in the process, the cleaning step can
limit the quantity of parts manufactured. Cycle times were established from available process
data, equipment capacity and employee interviews. Product performance was based on part
reject rates per unit of production; the degree of cleanliness a part has prior to flux application
and brazing greatly effects the quality of the braze, thus the quality of the final product. Part
reject rates were established using the results of leak testing described in Chapter 3. The
production and part reject rates when the solvent degreasing processes were on-line were
used as the baseline for comparisons with the alternative processes.
The Evaluation of the Process Cycle Time
Radiator Manufacturing Line. Process control plans specifying equipment capacities and
employee interviews identified significant differences in the cycle times between the solvent
degreasers and aqueous wash system. The chlorinated solvent degreasers, when on-line,
represented the bottle-neck of the radiator manufacturing process, according to the
supervisors and line personnel interviewed. Standard operating procedures for these units
involves assembling a core, placing it into the degreasing unit, and assembling a second core
while the first was automatically cleaned. This cleaning step, a batch process, was the single
limiting factor of the radiator production rate. Furthermore, maintenance and down-time of
these units caused normal manufacturing hours to be consumed by non-productive down-time,
resulting in work schedules beyond normal operating hours to fulfill production quotas.
The aqueous wash system, on the other hand, has a cycle time capable of
processing/cleaning cores at a rate 50 percent faster than the degreasing processes, thus
changing the process line bottle-neck away from the cleaning operation. Within the two years
of operation, the aqueous wash system, a continuous conveyor system, has required one
maintenance repair which was remedied during a shift switch. Down-time due to mechanical
failure or operating difficulties has not been experienced with this unit. The efficiency and
26
-------
Radiator Manufacturing Line
The elimination of the chlorinated solvent degreasers from the radiator manufacturing
line eliminated all reportable air releases associated with the cleaning of the radiator cores. In
1988 air releases represented over 66 percent of CMC's total TCA releases and transfers; by
1992 this percentage had decreased to 46 percent. From discussions with CMC employees,
reasons for this percentage decrease include elimination of the least efficient solvent
degreasers which contributed the greatest amount of air releases, and better operating/control
procedures on remaining degreasers. The five solvent degreasers of the radiator line were
examples of low-efficiency cleaning systems. The reduction of 54.3 percent in air releases
between 1990 and 1991 in part reflects the elimination and replacement of these inefficient
degreasers by the aqueous wash system.
Condenser Manufacturing Line
The elimination of the chlorinated solvent degreasers from the condenser
manufacturing line also eliminated TCA air releases associated with the cleaning of the
condenser corrugated fins. The significant percent decrease in air releases of TCA observed
between 1992 and 1993 corresponds to the elimination of the condenser's solvent degreasing
processes.
However, the evaporative lubricant utilized in the new condenser processing line
generates an air emission not present when the solvent degreasers were operational. The
evaporative lubricant is a volatile organic compound (VOC) that is vaporized by flash driers
prior to subsequent processing. Consumption of the lubricant was recorded as 2 gal/d per
corrugation unit. With this, and assuming that 100 percent of the lubricant evaporates within
the flash driers, air emissions of VOC were estimated to be nearly 12,200 Ib/yr (specific
gravity is 0.764). Interviews with the line supervisors and engineers, however, indicate that
only a fraction of the lubricant is actually evaporated by the flash driers, and that some of the
lubricant remains on the corrugated fins as they are assembled with the tubes and enter the
flux and braze processes. Therefore, the estimate of 12,200 Ib/yr sets the upper boundary of
air releases from the alternative process of the condenser line.
Though not required under TR1 to be reported, this VOC release of lubricant is
regulated by the Tennessee Department of Environment and Conservation Division of Air
Pollution Control. Under the requirements of this Division, VOC emissions must be
permitted, and release quantities over one ton must be reported yearly. This reporting
requirement, and concerns about potential employee exposure to the VOCs, prompted CMC
to look for alternatives. During the six-month course of this research project, CMC began
testing alternative synthetic, water-based lubricants to replace the evaporative lube. Because
of the water-based nature of the new alternatives, removal of the lubricant before subsequent
processing (i.e., fluxing and brazing) would not be required, thus eliminating the need for the
flash driers. Trial tests are still underway at CMC to determine the applicability of these
alternative lubricants. Pilot studies for testing the lubricity and effects on subsequent
processes have shown positive results, and full implementation of a synthetic, water-based
lubricant is expected by early 1995. CMC management and line supervisors see this synthetic,
water-based lubricant as the ultimate solution to eliminate solvent degreasing, even over
aqueous wash alternatives.
37
-------
quality braze. Residuals from the flash drying of the lubricant do not interfere with flux
application. The original processes of these lines employed solvent degreasing to achieve the
required level of cleanliness. Interviews with CMC quality control employees indicated that
there was no change in core reject rates after the evaporative lubrication system was
operational when compared to the reject rates of the degreasing process.
II
i i
1.7-
.6
1 5~
1.4
1 3—
1 ? H
i i
1.1
.0
.9-
.8
.7-
6
.4
.3-
.2
.1
x
x
X
X
x * x
x x x x
h X
— — ) 1 1 1 — 1 1 — f- — ( 1 1
6/24 7/8 7/22 8/5 8/19 9/2 9/16 9/30
i4i|
iJiiiJiu; " •
j Ttttt: jj
ijj±h: j
{ 1 - JC - - !
; ;~43X " 3
„ ,. * r4-J- 1
'^t1^: j
j, 'Iffl: i
.i'M
T -ip£
' T -^
}• j£[- - - -
I- it a
•^ _ :
, *^j
i '""
10 —
H
f$Jrr
• '^fci^
Ttl^
7^1 , t
^ C!T
!n:iHr
j---i4n.
i|Ht»
^id
Ettqs-^:
fe
lltrfl
n"j"°i !
4_n".(^4 '
stm1-!
ftt! : , \
PI' :
-^ 12
Legend
x degreaser
• aqueous
%
t
• * t •• •
ill i I i 1 .
i 1 i i | i | i i f--|
1/13 1/27 2/10 2/24 3/9 3/23 4/6 4/20
1991
Time Line
1992
FIGURE 8. PART REJECT RATES (NORMALIZED) OVER TIME FOR
THE RADIATOR MANUFACTURING LINE
28
-------
the aqueous wash system and discharged to the on-site treatment facility. The other process
changes which offset the additional aqueous wash wastewater consisted of inert aqueous flux
solutions and electroplating rise baths, neither of which contribute to the wastewaters BOD
load. The treatment scheme, as discussed above, is not intended to biologically remove these
contaminants. A limited amount of oil can be removed during flocculation due to entrainment
and adsorbtion of the oils on the solid particles. The majority of the oil and soil contaminants,
however, pass through the pretreatment facility essentially unchanged. The potential impact
this waste stream has on the POTW is presented in the national environmental impact
evaluation of Chapter 7.
Condenser Manufacturing Line
The implementation of the evaporative lubricant alternative to the condenser
manufacturing line, while eliminating the TC A water contamination due to carry over, does
not generate wastewater. Therefore, the condenser line does not directly affect the releases
and transfers to water. However, the subsequent processes of the condenser manufacturing
line include the application of an aqueous flux to the condenser core. Lubricant residual
remaining on the corrugated fins of the condenser core could contaminate the aqueous flux
solution, which in turn could contaminate the pretreated wastewater discharge to the POTW
when the flux solution is treated by CMC's on-site treatment facility. This potential
contamination is considered insignificant for this CMC-specific evaluation due to the small
quantities of lubricant used, and its evaporative characteristics. However, this issue is
addressed in the national environmental impact evaluation of Chapter 7 where impacts on
POTWs and synthetic lubricants are developed.
Converter Manufacturing Line
The hot water wash system of the converter line generates wastewater while
eliminating the use and hazardous waste disposal of TCA (approximately 27,100 Ib/yr
hazardous waste and unknown air releases). Due to the details of their POTW discharge
permit at this site, and other managerial considerations, CMC has chosen to drum this
wastewater and dispose of it as an oil-contaminated, non-hazardous waste. Twelve drums
every three months are filled with the contaminated water and disposed of off-site. The
longevity of the hot water wash reservoir, when compared to the radiator detergent reservoir,
is due to the elimination of the detergent and the ability to periodically remove oily residues
from the reservoir surface. The advantages of this reservoir longevity and the elimination of a
detergent from aqueous cleaning are more fully explained in Chapter 7, National
Environmental Impact Evaluation.
TOXICITY, EXPOSURE, AND RISK
Accompanying the shifts in environmental emissions presented above are changes in
the toxicity and potential risk to human health and the environment from chemical exposure.
An assessment of toxicity and exposure potential associated with the waste shifts is presented
39
-------
CHAPTER 5
ENVIRONMENTAL EVALUATION
The objectives of this evaluation were to analyze the releases and transfers of the
chlorinated degreasing solvents from CMC's manufacturing facilities, and to compare these to
the chemical releases and transfers associated with the alternative cleaning or no-clean
processes. Though the chlorinated degreasing solvents and their emissions were eliminated by
the implementation of the alternative processes, releases and transfers of other chemicals now
exist. Therefore, a multimedia approach, evaluating releases and transfers to land (off-site
transfer), air, and water, were used to capture the full benefits and costs of the changes to the
alternative processes. Both hazardous and nonhazardous wastes were also included in the
analysis. Data obtained from CMC and TRI were maintained in English units. Conversion
tables to metric units are supplied in Appendix D.
The replacement of the solvent degreasing systems of the radiator and condenser
manufacturing lines with the alternative technologies eliminated approximately 293,000 Ib/yr
of TCA releases and transfers to the air and soil. The aqueous wash system, while eliminating
the emissions of TCA, created an additional wastewater stream equalling over two million
gal/yr, and a nonhazardous oily waste stream totalling 1,320 gal/yr. The pretreatment of the
wastewater stream also generates an estimated 7,900 gal/yr of nonhazardous solid waste. The
no-clean alternative technology implemented on the condenser line generated volatile organic
compound air emissions totalling about 12,200 Ib/yr while eliminating all TCA emissions.
These results of the environmental evaluation are presented in detail in the following sections.
ENVIRONMENTAL BACKGROUND
Calsonic Corporation, in 1991, established an Environmental Program "to properly
manage and reduce usage and emissions of pollutants and hazardous materials ..." This
Program (Appendix E) states that each Calsonic operation must designate a person to be
responsible for environmental compliance. The responsibilities of this environmental designee
are then listed in twelve additional statements. In response to this corporate program, CMC
established a "Waste Management Plan" in 1992. In this Plan, also presented in Appendix E,
hazardous waste reduction goals were specifically defined, goals that were to be achieved by
1995. These goals, outlined in Table 5, below, have been aggressively pursued by CMC. The
application of alternative processes to eliminate TCA and solvent degreasing has been one
step towards achieving these goals.
Based on the information of Table 3 of Chapter 2, the years of interest for data
interpretation are as follows:
1990 last full year radiator vapor degreasers were operational;
1991 radiator vapor degreasers operational for nine (9) months of the year, aqueous
wash system installed and running the remaining three (3) months;
1992 first full year aqueous wash system was operational, and the last full year in
which petroleum-based lubricants were utilized on the condenser line (i.e., the
last full year condenser line vapor degreasers were operational);
30
-------
two such detergent builders Ingestion of excess quantities of these phosphate salts are toxic.
Effects include upset mineral balance in the body and prevention of mineral nutrient
utilization. LD50 values for STPP include 3.02 g/kg in mice, and 519 g/kg in rats.29
The primary industrial chelators are essentially environmentally benign and nontoxic
under normal handling and use conditions.30 Bioconcentration values suggest EDTA will not
bioaccumulate in aquatic organisms. However, the strong chelating characteristics of EDTA
mobilize heavy metals, including lead and cadmium, in wastewater streams, sewer sludge, and
soils. This mobilization of metals causes treatment problems for POTWs (discussed further in
Chapter 7), and has the potential to create situations in which aquatic organisms are exposed
to a toxic environment. LD50 values for EDTA for fish is 159 mg/L in a 96 hour test; no
adverse effect level is 100 mg/L. EDTA is not metabolized by the human body and is readily
excreted in the urine. The FAO/WHO Acceptable Daily Intake for EDTA in humans is 0 to
2.5 mg/kg body weight.31
Nitrilotriacedic acid (NTA) is another chelating agent commonly used in detergent
formulation. Laboratory findings in the later 1960s suggested that NTA was a potential
teratogenicide, and in 1970, the U.S. Surgeon General requested the withdrawal of NTA from
the market. However, since that time, further studies supporting its safety have encouraged
the EPA to drop its opposition to NTA Currently, NTA is beginning to reappear in some
nonphosphate consumer laundry detergents.32
Exposure Potential
To evaluate the exposure potential for the various waste streams, potential exposure
pathways must be identified. Exposure pathways are the physical courses chemicals take from
the source to the organism exposed. An example of an exposure pathway might be worker
inhalation of volatile organic compounds that have evaporated from a solvent to the air; the
inhalation of solvent in air is the exposure pathway. Potential exposure pathways for each of
the waste streams generated by the solvent degreasing and alternative processes, exposure
pathways and routes will be assessed.
1,1,1-Trichloroethane. Chlorinated alkanes (e.g., TCA) readily vaporize, and consequently
distribute primarily to air. TCA releases from point sources such as vapor degreasers disperse
into the environment and contribute to the concentrations of the chemical in the ambient
environment. Therefore, the primary exposure pathway of TCA as a degreasing solvent is
expected to be inhalation of TCA in air
However, a hazardous waste stream of spent TCA was also generated by the solvent
degreasers. This waste stream was drummed by CMC employees and transferred off-site to a
recycling facility. Dermal contact with liquid TCA and inhalation of TCA vapors are possible
during drumming activities, although appropriate standard operating procedures can minimize
their potential. Additional air releases could occur at the recycling facility as well as
hazardous waste generation of residues contaminated with TCA.
Wastewater. The containment, pretreatment, and POTW treatment of wastewaters from the
aqueous wash system minimizes the potential pathways and routes of exposure to detergent
constituents. The primary pathway is via water, and dermal contact with or ingestion of
contaminated water would be the potential routes.
41
-------
u
u
.
r*
CO
Q
U
H
O
P-
C/5
U
fc
5
£•«
Q
52;
^
^
C/)
W
W
^
NH
fcd
2
2
H
u
^
pd
H
O
O
J
B
U
2
H
*"J>
SO*
W
.J
M
H
^
?*•>
j3
^t/T
CD
<-HH
en
03
T3
C
CD
03
13
(U £
•— " ."tn f jj
-»_. CO ^
° «*H fi
H
(U ^
fD '""^ ^M
"S 2 c
O Js? P
° H
^ en
O |
(X H
to &
— — i <-3 U
•*- > OO 03
O ' _O
O «>
^-^ PH
•o
c -
3 C iu
O O en
H '13 03
00 o
fe .Si, 13
D ~"
-o jg
^ 1
j_ (U
"c3 _U
^ <
o o o in 'n in o
o o m (N Tf t^ o
O O in in ro ON O
O oo r»^ oo >sD ^ ON
O ^o m m o ON o
— — r^ m ^4 ^ ^
o o o >n >n >n o
o o r<^ (N -f r^ o
O o in >n m ON o
o oo m oo o ^f ON
O \o m m o ON o
o o o o o o o
O O \O (N ON ^O O
O o >n (N m TJ- o
o o r-« o r^j 'xj- oo
f~H O in ^~ o ON *o
Tf r~- c--) ON t~-» oo ^o
(N r^i rf ^-i — i
O O O O O O O
o o o o o o o
o o o o o o o
O O \O (N O'N O O
O o in fN r<"j Tt o
o o r-^ o n Tt oo
•— c o >n T^- ^c ON \o
*3~ r~~ o~) os t~~ oo v>o
(N rn rj- — i — i
oo os o — ' o) £-, •£+.
00 00 Os OS O- QS as
ON Os ON Os O ON ON
U
u
6
Ja
^4—I
O
-o
U
c o
c 6
.2 —
S3
6
£
O
c/o
32
-------
TABLE 9. POTENTIAL EXPOSURE TO WASTE STREAMS
AND ASSOCIATED RISK
Waste Stream
TCA
Wastewater
(Detergent)
voc
(Evaporative Lube)
Primary Exposure
Pathway
Air and Inhalation
Water and Irigestion
or Dermal Contact
Air and Inhalation
Potential Risk
Uncontrolled point source creating the
highest potential for exposure and risk
Contained and treated point source reducing
potential for exposure and risk
Uncontrolled point source (small volume)
creating high potential for exposure and risk
SUMMARY OF THE ENVIRONMENTAL EVALUATION
A quantitative evaluation of the impacts the alternatives have on releases and transfers
was performed based on available data, such as limited TCA consumption data and CMC
employee estimates. The implementation of the alternative processes to solvent degreasing
within the radiator and condenser manufacturing lines significantly affected the releases and
transfers from CMC's facility, both in chemical composition and quantity. The TCA air and
hazardous waste streams associated with the operation of solvent degreasers were eliminated
from both the radiator and condenser manufacturing lines. The alternative processes,
however, introduced additional waste streams unique to their application.
The aqueous wash system of the radiator line introduced three additional waste
streams, all of which are classified as non-hazardous. The wastewater generated by the
aqueous system contributed more than two million gal/yr of wastewater to CMC's on-site
pretreatment facility. This pretreatment facility, in turn, generates nearly 26,400 gal/yr of
wastewater treatment solids, 7,900 gal of which may be attributed to the aqueous wash
system. An additional non-hazardous, oily waste stream is also generated by the aqueous
wash system. These emissions, compared to the TCA emissions are presented in Figure 10.
The application of the evaporative lubricant to the fin corrugation process of the
condenser line, while eliminating all TCA waste streams, generated one additional waste
stream. The VOC emissions of the lubricant, resulting from the flash driers of the fin
corrugation units, is a regulated air release. Based on lubricant consumption data, 12,200 Ib
of VOC are emitted to the atmosphere each year from this process. This represents the only
direct release or transfer from this alternative process. Figure 11 compares the emissions from
the old and new condenser processes
These shifts in waste stream composition and media must be coupled with a
consideration of toxicity and potential risk to human health and the environment. For the
aqueous wash of the radiator line, releases of the toxic, ozone-depleting chemical TCA were
eliminated, but a larger volume, low toxicity wastewater stream was generated. Although
hazardous waste reporting requirements have been eliminated for this line, pretreatment
requirements must still be met. For the condenser line, hazardous waste and TCA were once
43
-------
Based on TCA chemical use logs of each manufacturing line, the yearly consumption
of TCA was estimated; 171,500 Ib of TCA were consumed in 1990 by the degreasers of the
radiator line, and 121,500 Ib of TCA were consumed in 1992 by the degreasers of the
condenser line. The hazardous waste disposal values identified in Figure 9 are estimates from
line personnel; air releases represent the difference between consumption and hazardous waste
disposal estimates. By 1992 TCA use by the radiator manufacturing line was eliminated, and
therefore the hazardous waste stream associated with the TCA use. Similarly, by 1994 the
use and hazardous waste disposal of TCA by the condenser fin corrugation process were
eliminated. The changes in releases and transfers to land (off-site transfer), air, and water are
evaluated for each process line. Included in this multimedia analysis is the consideration of
hazardous, toxic, nonhazardous, and nontoxic releases and transfers.
RELEASES AND TRANSFERS TO LAND (OFF-SITE TRANSFERS)
The use of TCA for solvent degreasing resulted in a hazardous waste stream of spent
solvent. Periodically, to maintain optimal cleaning potential, the reservoirs of the solvent
degreasers would be drained of TCA, which was contaminated with moisture and soils
removed from the parts. The reservoir would be filled again with fresh solvent, and the
collected TCA would be disposed of off-site in 55 gallon drums as hazardous waste. Calsonic
chose off-site solvent recovery/recycling as the most desirable method to manage this
hazardous waste stream. The alternative processes which replaced the solvent degreasers of
the radiator, condenser, and converter manufacturing lines eliminated this TCA waste stream
from these lines.
Disposal quantities of hazardous waste containing TCA, retrieved from the TRI for the
years 1990 through 1992, are presented in Table 7. Within TRI, this waste stream was
reported under "Other Off-Site Transfers" which can include treatment and licensed land
disposal. This TCA hazardous waste stream was completely eliminated from the radiator and
condenser manufacturing lines by the aqueous wash and no-clean alternatives. Table 7 also
presents the percent change of the total TCA hazardous waste stream from year to year. The
increase in hazardous waste from 1990 to 1991 was due to the addition of a new product line
manufactured by CMC. This new product manufacturing line introduced two new TCA vapor
degreasing processes. The hazardous waste streams from the new degreasers mask the
elimination of TCA waste from the radiator line. The 44 percent reduction in these hazardous
waste transfers from 1993 to 1994, however, can be predominantly attributed to the full
implementation of the evaporative lubrication system and the elimination of the vapor
degreasers of the condenser manufacturing line.
34
-------
16,900
16,800
16,700
200
190
180
170
160
150
§ 140
1 1? 130
£~5* 12°
c/3 £
•so no
'S o^ 100
^^90
80
70
60
50
40
30
20
10
TCA
jg« Chemicals purchased
L/"J Hazardous waste generation
[XJ Air releases
Non hazardous waste generation
Wastewater generation
WW Solids
Oily
1990
1992
Year
FIGURE 10. SUMMARY OF RADIATOR LINE EMISSIONS OVER TIME
45
-------
aqueous wash system on wastewater treatment solids generation, but the information to
establish a direct relationship was not available.
Condenser Manufacturing Line
The elimination of the chlorinated solvent degreasers from the condenser line
eliminated all off-site transfers of either hazardous or non-hazardous waste associated with fin
corrugation and the cleaning process. The evaporative lubricant now utilized is removed by
flash driers after fin corrugation; the waste stream is thus in a vapor phase and is discussed in
the following section, Releases and Transfers to Air.
RELEASES AND TRANSFERS TO AIR
Releases to air from the radiator and condenser process lines also changed significantly
due to the application of alternative systems for solvent degreasing. Standard operating
procedures of the solvent degreasers can result in solvent vapor losses; drag-out on cleaned
parts, air drafts through the units, and poorly maintained operating conditions are only some
of the possible reasons for solvent losses. On-site emissions to air, reported each year in the
TRI database, were estimated by CMC using TCA purchase records and TCA hazardous
waste disposal data from manifest records. Table 8 summarizes the information used for these
calculations. Also presented in Table 8 is the percent change of air releases from year to year
TABLE 8. SUMMARY OF INFORMATION USED TO CALCULATE CMC AIR
EMISSIONS OF TCA
Year
1990
1991
1992
1993
1994b
Total TCA
Purchased
Ob/yr)
659,286
533,147
382,584
284,421
175,800
TCA Disposed
(Manifest)
(lb/yr)
233 530
338.525
206,345
194,975
109.000
TCA Air
Releases3
(lb/yr)
425,756
194622
176239
89,446
66,800
Percent Change
-54.3%
-9 4%
-49 8%
25 3%
a Reported in the TRI.
b Extrapolated for 1994 based on 11 months of TCA purchase and hazardous waste manifest records.
36
-------
CHAPTER 6
ECONOMIC EVALUATION
The final results of the economic analyses of CMC's manufacturing lines supported the
implementation of the pollution prevention alternatives. Though traditional analyses identified
returns on investment within ten years, a typical time horizon for pollution prevention
investments, activity-based cost accounting methods more accurately identified the savings
associated with the alternative processes, and resulted in return on investments within five
years, a typical time horizon for all investments by industry Hybrid analyses, which combined
traditional and activity-based costing methods, offered return on investments in as short as
three months, therefore fully supporting the implementation of the alternative processes.
The radiator line, with the aqueous wash system, resulted in a return on investment of
11.6 years using traditional cost evaluation methods. Typical industrial practices require a
return on investment of five years; if cost was the only metric considered, the aqueous wash
system would not be supported using traditional accounting methods. Activity-based cost
accounting methods more accurately evaluated the benefits of the aqueous wash system and
resulted in a 2.4 year return on investment, therefore supporting the implementation of the
aqueous system even when a typical 5-year time horizon is used. The 5-year net present value
calculation resulted in a positive net flow of $1,069,890 when compared to the solvent
degreasing system. A four percent interest rate (typical of a low risk investment) was used to
calculate the time value of money.
The no-clean technology of the converter line identified even greater savings due to
the elimination of the solvent degreasers and limited added costs. A 0.45 year return on
investment and 0.27 year return on investment were calculated using traditional and activity-
based cost accounting methods, respectively. A 5-year net present value for the evaporative
lube system was calculated to be $869,890 when compared to the solvent degreasing system.
ECONOMIC BACKGROUND
The objective of the economic evaluation was to analyze the total cost of the
substitutes as compared to the chlorinated solvent degreasers. This analysis of total cost was
accomplished in two steps The first step was a traditional analysis evaluating direct costs.
Direct costs are traditionally used in the analyses of most financial statements, and are
therefore part of the accounting systems of most companies. As noted in recent literature,
however, direct costs may not capture all the benefits of a pollution prevention project. These
benefits fall into the categories of indirect costs (overhead), potential liabilities, and less-
tangible costs. Therefore, the second step taken to economically evaluate the benefits and
costs of the alternative systems, when compared to the solvent degreasing systems, was to
more accurately capture these additional costs. Activity-based costing (hereafter referred to
as ABC) was the analytical tool applied to perform this second cost analysis step.
The four categories of cost identified above (direct costs, indirect costs, potential
liabilities, and less-tangible costs) are the four tiers of data the EPA calls the 'expanded cost
inventory1.33 These tiers, designated "Tier 0" through "Tier 3" are presented in Table 10. The
more accurately the costs within each of these tiers are accounted for and quantified, the more
47
-------
RELEASES AND TRANSFERS TO WATER
CMC reported no releases to water of TCA, whether under an NPDES permit (on-
site) or off-site to a POTW, when the solvent degreasers of either process were on line. Air
releases and hazardous waste transfers of TCA were the only reported waste stream by CMC
as shown in Table 8. Water releases of TCA that were possible under these degreasing
operations may have resulted from solvent carry-over on the cleaned cores into the aqueous
flux application system. This flux solution is periodically drained and treated by CMC's on-
site wastewater pretreatment facility, which is discharged to the sewer (i.e., POTW) after
treatment. It was assumed by CMC that any TCA reaching the flux solution by carry-over is
volatilized either during the flux application process, or in the aerated equalization basin of the
pretreatment facility. This volatilization contributes to the TCA air releases and is already
accounted for by CMC's method used to calculate this waste stream. Sampling and analysis of
the pretreated wastewater entering the sewer system, required under CMC's discharge permit,
support this assumption. Even at the highest concentration of TCA detected (0.41 mg/L on '
December 28, 1992) in sample analyses, only 0.068 Ib/d, or 16.4 Ib/yr, of TCA would have
been discharged to the POTW (data presented in Appendix F).
Radiator Manufacturing Line
The aqueous wash alternative of the radiator line introduces an additional water waste
stream not associated with the original solvent degreasing system. The operation of this
aqueous wash system generates an average of 8,400 gal/d (over two million gal/yr) of
wastewater which must be treated by CMC's existing pretreatment facility. This discharge to
the pretreatment facility includes a continuous discharge from the first rinse tank, and a batch
discharge from all three tanks which occur weekly. Pretreatment of this waste stream includes
separately shocking the detergent bath wastewater by extreme pH variations to minimize
foaming in subsequent treatment steps, and treatment of the continuous wastewater stream,
along with other wastewaters from CMC, with varying pH, polymer addition, flocculation and
settling, solids dewatering, and final sand/coal filtration of the water prior to discharge to the
sewer. Reporting of this wastewater stream is not required under TRI. However, the
discharge to sewer requires periodic sampling and analysis.
The existing wastewater pretreatment facility of CMC treats wastewaters from all
manufacturing operations. The treatment scheme of this wastewater pretreatment operation is
primarily designed to remove metals and suspended solids from the wastewater; biological
treatment of organics is not possible by the current system. Other changes in CMC
manufacturing processes off-set the additional 8,400 gal/d of wastewater generated by the
radiator aqueous wash system; the average flow rate of the pretreatment facility actually
decreased even with the addition of the aqueous system.
Although the flow rate has not increased due to the implementation of the aqueous
wash system, pretreated effluent analysis results indicate a significant increase in the
wastewater's biological oxygen demand (BOD). CMC is required by their industrial discharge
permit to quarterly analyze the pretreated wastewater effluent to the sewer system. The
results, presented in Appendix F and statistically analyzed in Appendix C, indicate the average
BOD has increased over 700 percent (from 3.8 to 27.8 mg/L) after the implementation of the
aqueous wash system. This increase can largely be attributed to the oils and soils removed by
38
-------
degreasers for zero salvage value. Both assumptions result in a conservative estimate in favor
of the solvent degreasing systems. The capital investment for each of the alternative processes
was supplied by CMC in the data request tables of Appendix A.
Also included in the traditional cost analyses are the raw materials, waste disposal,
and energy costs for both the old and new manufacturing processes. The Environmental
Evaluation of Chapter 5 offers the chemical use rates for each process, old and new, as well as
the waste generation rates. Combining this information with chemical purchase costs, waste
disposal fees, and energy consumption/costs completes the data required for the traditional
cost analysis. These costs for each manufacturing line are presented below. Using these
values for direct cost, return on investment, and net present values, typical economic
parameters employed by industry, were calculated and are also included in the following
discussion.
Additional operation and maintenance costs which would include maintenance labor
and materials, as well as supervision, are not included in the traditional analyses. This is due
to the fact that the implementation of the aqueous wash and evaporative lube systems did not
effect the direct labor hours of the radiator and condenser manufacturing lines. The same
number of employees currently work on the lines as did for the vapor degreasing systems;
therefore, direct labor costs have not changed. The labor differences that do significantly
change are those of supporting activities (maintenance and supervision). The costs associated
with these activities, not traditionally included in direct cost analyses, will be accounted for in
the ABC analysis which follows.
Traditional Cost Evaluation of the Radiator Manufacturing Line
The implementation of the aqueous wash system removed five solvent degreasers, one
from each assembly station, and centrally located the cleaning process for the radiator line. As
established in Chapter 4, the rate of production was not changed significantly due to the
implementation of the alternative cleaning process. Therefore, the only raw material costs
included in the analysis are those associated with the cleaning process; specifically the cost of
TCA for the solvent systems, and the costs of detergent and water for the aqueous system.
These costs are presented in Table 11, below. The waste disposal and energy costs of each of
these processes are also presented in the table.
49
-------
in this section. From this information, conclusions about the relative risks these wastes have
on the environment and human health are drawn.
Toxicity
The term toxicity describes the various adverse human health and environmental
effects possible as a result of chemical exposure. These effects can be described as toxic (e.g.,
acute, chronic, or subchronic), neurotoxic, carcinogenic, mutagenic, or teratogenic.23 An
assessment of toxicity is the characterization of the toxicological properties and effects of a
chemical with specific emphasis on the identification of a dose-response relationship. Some of
the various toxicological characteristics of each waste stream and their constituents are
presented below.
1,1,1-Trichloroethane. TCA is readily absorbed through the lungs and the gastrointestinal
tract. It is considered to be poorly absorbed through the skin. Metabolic conversion of TCA
within the body is nearly non-existent; most of the dose is expired, predominately by
exhalation, unchanged regardless of the route of administration. TCA does not accumulate in
the tissues. Under EPAs weight-of-evidence classification, TCA has been placed in Group D
unclassified as to human carcinogenicity. 4 TCA is a CNS and respiratory depressant;
exposure to concentrations greater than 5,000 to 10,000 parts per million (ppm) can be lethal
due to cardiac arrest or respiratory failure.25 Recommended maximum workplace
concentrations of solvents have tended to decrease with time, consistent with available
information identifying potential adverse effects from exposure to these chemicals, and with
technological improvements for their use The occupational permissible exposure'limit (PEL)
to TCA established by Occupational Safety and Health Association is 350 ppm. TCA readily
vaporizes into the air, thus the potential for adverse effects on the aquatic environment would
not be a primary concern. Though not a direct toxic effect, TCA has a half-life of six months
to 25 years in the atmosphere and therefore can travel long distances. Furthermore, TCA is
listed as an ozone depleting chemical.26
Surfactants. Commonly used surfactants are relatively non-toxic to humans; some cause
skin, mucous membrane, and eye irritation. Acute oral toxicity is low, typically in the range of
several hundred to several thousand mg/kg of bodyweight. The LD50 in rats for linear
alkylbenzene sulfonate (LAS), for instance, is 650-2,480 mg/kg. LD50 is the lethal dose of a
chemical taken by mouth, absorbed by the skin, or injected that causes death in 50 percent of
the test animals. Experiments studying the carcinogenicity of surfactants provided no
indication of increased risk of cancer after oral ingestion.27
Surfactants, however, do exhibit toxic effects toward aquatic organisms. Acute
toxicity tests of LAS show that LC50 values for aquatic organisms range from 3-10 mg/L for
fish and 8-20 mg/L for daphnia. LC50 is the concentration of a chemical in air or water which
is expected to cause death in 50 percent of the test animals exposed to that air or water. The
no-observable-effect-concentration for algae was determined to be 30-300 mg/L.28
Builders and Chelators. Some of the commonly used builders can be particularly irritating
to skin, eyes, mucous membranes, and the lungs Tetrapotassium pyrophosphate, the primary
ingredient in CMC's detergent formulation, and sodium tripolyphosphate (STPP)'represent
40
-------
The direct costs associated with the solvent degreasers include TCA consumption
costs, energy costs, and the disposal of TCA hazardous waste. As presented in Table 11,
TCA consumption costs equalled $76,000; this cost is based on the 1990 TCA consumption
estimate of 15,820 gal at a 1990 TCA cost of $4.62/gal, which has been adjusted to 1991
equivalent dollars for comparison with the aqueous wash system. Also in 1990, an estimated
10,600 gal of TCA hazardous waste were disposed of off-site at a cost of $1.84/gal, or a 1991
equivalent cost of $20,300. Energy requirements for each of the five vapor degreasers
includes four reservoir heaters and a motor which moves the soiled part into and out of the
cleaning zone. The total energy requirement for these electrical units was estimated to be 156
kW-hr/hr (599,404 kW-hr/yr), or $20,970 equivalent 1991 dollars. These figures represent a
yearly direct cost for the radiator solvent degreasers of $117,270.
The aqueous wash system, though eliminating the use and hazardous waste disposal of
TCA, has associated with it other direct costs. These include the consumption costs of
detergent, water, and energy. Detergent consumption in 1992 was approximately 11 gal/d
(2,640 gal/yr) at a cost of $7.70/gal, or $20,330. Water consumption by the aqueous wash
system is approximately 8,400 gal/d (2,016,000 gal/yr) at an annual cost of $2,700 (a
$0.00134/gal surcharge is levied by Shelbyville for water use and disposal to the city's
POTW). Energy requirements of the aqueous wash system include three pumps and a natural
gas heater. The pumps agitate the water and detergent reservoirs, as well as spray the
radiator cores passing through the unit; the natural gas heater heats the detergent reservoir.
These direct costs total $62,400.
Though the wastewater treatment costs would traditionally represent an overhead
cost and thus be excluded from this analysis, it is included here to compare waste disposal
costs for each process scenario. The treatment of the aqueous wash waste stream required
the use of treatment chemicals and process units which consume energy. The treatment
chemicals include acid and lime to shock the detergent bath, and sulfuric acid, sodium
hydroxide, and polymer to treat the full waste stream. The cost of an acid or base solution is
approximately $1.35/gal, and the cost of lime is approximately $0.09/lb. Process units which
consume energy within the wastewater pretreatment train include acid, base, and polymer
addition pumps, circulation pumps within each treatment basin, and the sludge plate-and-
frame press. The total energy requirement for these units was determined to be insignificant.
The flow rate of 8,400 gal/d from the radiator line's aqueous system represents approximately
one-third of the wastewater flow of CMC's treatment facility. Therefore, for the purposes of
this analysis, one-third of the costs accrued by treating this waste stream are associated with
this alternative process. Adjusting these costs to represent the fraction of the waste stream
represented by the aqueous wash wastewater establishes a yearly chemical cost of $10,800.
In addition to the raw materials costs associated with the aqueous wash system, the
disposal of the nonhazardous, oily waste stream and the wastewater solids waste stream
represent other costs associated with the alternative system. The generation rate of the oily
waste stream was approximately 1,320 gal/yr. Disposal costs for this material to an off-site
nonhazardous fuel-blending facility is approximately $840.00/yr ($0.64/gal). Wastewater
treatment solids generation is approximately 11,880 gal/yr (adjusted to represent 30 percent),
creating a $3,220/yr disposal costs ($0.27/gal). As previously stated, the assumption that the
aqueous wash wastewater contributes one-third of the wastewater solids may not reflect the
true influence of the system on wastewater treatment solids generation, but the information to
establish a direct relationship was not available.
51
-------
The detergent used by CMC is 20 percent builder (tetrapotassium pyrophosphate), and
less than 5 percent each of ethoxylated alcohol surfactant and chelator. In addition, the
detergent is diluted during use to a ratio of 1 part detergent to 54 parts water. The addition of
detergent to the cleaning bath could involve possible dermal exposure, but standard operating
procedures would minimize this potential. Pretreatment at CMC of aqueous wastewaters
further dilutes detergent constituents to nearly 1 part detergent to 830 parts water.
Furthermore, pretreatment and biological treatment at Shelbyville's POTW have the
capabilities to destroy most of the detergents constituents prior to release to surface waters
(the treatability of detergent constituents are discussed further in the National Environmental
Impact Evaluation of Chapter 7). Potential direct releases of untreated wastewaters are
possible if the POTW's design and/or treatment capacities are exceeded. Once discharged to
surface waters, exposure would primarily be limited to dermal contact and incidental ingestion
of contaminated waters.
Volatile Organic Compounds. VOC emissions from the flash drying of the evaporative
lubricant represent the only environmental release or transfer from the condenser
manufacturing line (concerning parts cleaning). Therefore, the primary pathway for exposure
is inhalation of VOCs in air.
Risk
Risk is defined as the probability of injury, disease, or death under specific
circumstances. In the context of this report, risk is a qualitative expression of the likelihood
of adverse health or environmental effects considering both toxicity and potential exposure.
Definitive conclusions of risk require experience in human health and environmental risk
assessment. Furthermore, peer-review of the completed risk characterization is
recommended. The discussion below only presents the most basic conclusions.
Air releases of TCA and VOC from the solvent degreaser and evaporative lubricants,
respectively, represent the most significant direct exposure to workers and the environment.'
All other releases, if properly managed, are contained prior to treatment and disposal. TCA
recycling and fuel blending of waste oils minimize the potential for contamination of soils and
groundwater; pretreatment and municipal wastewater treatment of effluent waters from the
aqueous wash system greatly minimizes the potential for aquatic organism exposure and
contamination. The solids from the wastewater pretreatment facility are relatively inert, and
when disposed of in a properly designed and maintained landfill, the potential for
environmental and human exposure is low. These comparisons are summarized in Table 9.
42
-------
TABLE 13. COMPARISON OF CAPITAL COSTS FOR THE SOLVENT
DECREASING AND EVAPORATIVE LUBRICANT SYSTEMS
Cost
Equipment/Materials
Installation3
Instrumentation3
Plant Engineering3
TOTAL
Solvent Degreasing Units
(1993b$)
$64,900
$5,400
$27,000
$10,800
$108,100
Evaporative Lube System
(1993 $)
$22,000
$880
$17,600
$3,520
$44,000
a Costs were provided by CMC as a percentage of equipment cost and converted into dollars in this table.
b 1984 capital investment dollars were converted to equivalent 1993 dollars used the following equation:
(future value) = (present value) x (1 f i)", with i = inflation rate = four percent, and n = years = (1993 -
1984).
The analysis used to compare the direct costs of these systems will again consider only
the capital costs of the flash driers. It is assumed that the cost of the solvent degreasers were
fully depreciated by 1992, and the salvage value of the units is insignificant. This analysis will
include costs of raw materials, waste disposal, and energy for both systems. This information
is summarized in Table 14, and discussed below.
The direct costs associated with the condenser line include raw materials costs (TCA
and lubricant), energy costs, and the costs of waste management (hazardous waste disposal
and VOC emission permit fees). Within the Environmental Evaluation of Chapter 5, the 1992
rates of TCA consumption and disposal for the condenser line were estimated to be 11,200
gal (121,500 Ib), and 7,000 gal (75,400 Ib), respectively. The cost of virgin TCA in 1992
increased from the 1990 value of $4.62/gal to $6.60/gal. The cost of TCA hazardous waste
disposal did not change from the 1990 figure of $1.84/gal.
53
-------
again eliminated. Air releases decreased substantially, suggesting less potential employee
exposure. Complete data on the toxicity of the VOCs emitted by the flash drying of the
evaporative lube, however, are not available. This is one reason given by CMC for their
interest in a water-based synthetic lubricant which can remain on the fin for subsequent
processing (fluxing and brazing).
44
-------
Energy costs are the final operating and maintenance costs included in the traditional
analysis of the condenser manufacturing line. As with the radiator line, labor and supervisory
costs will be omitted; there are no differences in direct labor requirements between the old and
new processes and the activity-based accounting method will account for those costs. The
unique energy requirements for the solvent degreasers are the heaters for each reservoir. The
flash driers of the evaporative lube system are the unique units for the alternative system
which require energy. These rates of energy consumption and costs are presented in Table 14.
Finally, as stated in the Environmental Evaluation of Chapter 5, the evaporative
lubricant system generates a VOC air emission. Yearly emissions reporting and fees are a
result of this air release. Yearly emission fees, based on quantities emitted, were $4.00/ton
emitted for 1994. Therefore, the use of evaporative oil on the condenser line resulted in a fee
of approximately $24.00 in 1994. Calsonic's total VOC emissions fee for 1994 was
approximately $140. Until 1994, CMC was considered a large quantity hazardous waste
generator by the EPA. As such, CMC paid a $900 fee each year. The elimination of the
solvent degreasers from the condenser manufacturing process, in conjunction with the
accomplishments of the radiator and other manufacturing lines, changed CMC's status from a
large quantity to a small quantity hazardous waste generator, and therefore eliminated this
yearly fee.
The return on investment and net present values of these direct costs are presented in
Table 15. Both economic analyses strongly support the investment into the evaporative
lubricant system. The return on investment would be experienced within the first year of
evaporative lubricant operation. This conclusion is consistent with the 0.3 year return of
investment reported by CMC for the implementation of this alternative system. For
comparison, the 5-year NPV is also presented in Table 15. The cost to continue the operation
of the solvent degreasing system, based solely on direct costs, is substantially greater than the
costs accrued by the operation of the evaporative lubricant system.
TABLE 15. RETURN ON INVESTMENT AND COMPARISON OF
NET PRESENT VALUES - CONDENSER
Analysis
Payback
NPV (5-vear)
Solvent System
$619,750
Evaporative Lubricant System
0.45 years
$99,930
Notes: 1. i = interest rate per interest period =: four percent.
2. the capital investment of the aqueous wash system was depreciated (straight-line) over seven
years.
3. assumptions: inflation rate of zero and equal costs per year.
4. dollar values represent costs.
55
-------
200 -
190 -
180 -
170 ~
160 -
150
140 -\
130
120 H
110
100 H
90
80
70
60
50
40 H
30
20
10
Chemicals purchased
Hazardous waste generation
Air releases
Q~] Non hazardous waste generation
[ ] Wastewater generation
TCAand
Petroleum
Lubricant
Evaporative
Lubricant VOC
1992
1994
Year
FIGURE 11. SUMMARY OF CONDENSER LINE EMISSIONS OVER TIME
46
-------
BOAs were developed from a knowledge of CMC's process lines, and revised during a two-
day site visit. During this site visit, three researchers observed the various steps of each
process; one process line was observed per day. Observations included standard core
assembly procedures, maintaining the supply of materials, product testing procedures, and
some basic support activities. Activities were recorded for every step of the manufacturing
process, with particular detail given the cleaning (or lack there of) step. To record activities
which may not have been observed (eg., those that occur intermittently), line personnel and
supervisors were extensively interviewed during the observation period, and at the end of each
day. Interviews were also used to develop BOAs for the nonexistent solvent degreasing
processes.
The analysis of this information began by comparing the old, solvent degreasing
activities with those of the new, alternative processes. Differences between the old and new
activities were drawn from each BOA and recorded for further analysis. Examples of differing
activities would be activities that were eliminated by the implementation of the alternative
processes, or additional activities that were a result of the new processes. Frequencies and
durations, also identified during the site visit, as well as the cost drivers for each activity, were
then added to each BOA. Table 16, below, summarizes the cost drivers used in the analysis
and explains the costs included in each. ABC analysis of each manufacturing line was
accomplished following these procedures. The BOAs, cost drivers, and results of the analyses
are presented in the sections that follow.
TABLE 16. COST DRIVERS FOR THE PRIMARY ACTIVITIES
Cost Driver
$/labor hr
$/machine hr
$/receipt
$/order
$/core
Explanation of Included Costs
labor costs to perform a task
operating costs of a process unit, including utilities
labor costs to perform a task, and the cost of equipment utilized
costs include person hours to follow and fulfill paperwork requirements
(purchasing, accounting, manufacturing, inventory, supervisory,
management)
labor costs to perform a task, and the cost of the equipment utilized
ABC Analysis of the Radiator Manufacturing Line
Table 17 presents the primary activities which differ between the old, solvent
degreasing units and the new, aqueous wash system for the radiator line. Also presented in
this table are the cost drivers used to evaluate activity-based costs. A list of supporting
activities for each of these primary activities are presented in Appendix G. The frequency and
duration of these activities are not given in these tables, or in the appendices, to maintain
confidentiality of CMC proprietary information.
57
-------
accurate are the final analyses. As a result, the conclusions and decisions which are made
from the final analyses are more accurate.
TABLE 10. EPA'S EXPANDED COST INVENTORY
Tier
TierO
Tier 1
Tier 2
TierS
Included Costs
direct costs including
raw materials, waste disposal, operating and maintenance
hidden costs such as monitoring expenses, reporting, records keeping,
permit requirements
and
future liability costs
less tangible cost such
image
as consumer response, employee relations, and
corporate
Many industry accounting practices focus primarily on the direct costs to evaluate
capital budgeting projects. These data, included in the analysis of most financial statements,
are readily available, and interpretation is simplified due to familiarity. Unfortunately, this
practice may not accurately assess the costs and benefits of pollution prevention projects.
When applied in a cash flow analysis (e.g , net present value, internal rate of return, etc.), the
inaccuracies of these cost assessments are compounded, and the benefits of pollution
prevention projects are lost. As a result, many pollution prevention projects are not funded.
ABC attempts to solve this limitation of traditional analysis by identifying and evaluating
additional costs and benefits (Tier 1). The results of both analyses are presented in this
chapter. The results of the traditional cost analyses, below, will be followed by a discussion of
ABC, the results of the ABC analyses, and final analyses that combines the two accounting
methods into a hybrid system.
TRADITIONAL COST EVALUATIONS
Cost analyses performed by businesses for capital budgeting purposes traditionally
include those costs identified in Tier 0 of Table 10: capital expenditures, operation and
maintenance costs, and expenses or revenues from raw materials, waste disposal, energy, and
recovered materials.34 Therefore, for the analyses of CMC's processes, the following data
were used.
It was assumed that the capital costs of the original solvent degreasing units were
completely depreciated at the time of replacement. Therefore, the only capital costs included
in the analyses are those for the alternative processes. Considering the age of the radiator line
degreasers (installed in 1983) and condenser line degreasers (installed in 1984), this
assumption is valid; depreciation is typically based on a 7-year schedule for industrial
equipment. The salvage value of these units were also omitted from the traditional cost
analysis; this is consistent with the experience of CMC, who scrapped the obsolete solvent
48
-------
TABLE 18. DETAILED EXAMPLE OF THE SUPPORTING ACTIVITIES FOR THE
ASSEMBLY AND CLEANING OF RADIATOR CORES
Old, Solvent Degreasing Process
assemble core
turn and place core in solvent degreaser
close degreaser door
push button to begin degreasing process
turn and begin assembling a second core
oven degreaser door
remove cleaned core and place of wheeled
cart
place newly assembled core into degreaser
repeat activities above
wheel full cart (40 cores) to flux and brazing
conveyorized line
remove cores, one by one, and place on
conveyor for fluxing and brazing
New, Aqueous Wash Process
assemble core
place core on wheeled cart
repeat activities above
wheel full cart (40 cores) to cleaning, fluxing,
and brazing conveyorized line
remove cores, one by one, and place on
conveyor for cleaning, fluxing, and brazing
The number of steps required for the assembly and cleaning of a radiator core under
the process scenario of the solvent degreasing system, as presented in this table, are greater
than the number of steps needed to accomplish the same goal under the aqueous wash
scenario. The inclusion of the aqueous cleaning system into the conveyorized line of fluxing
and brazing, not only simplified the responsibilities of the assembly personnel, but also
eliminated a core transfer step (from assembly to degreaser, and from degreaser to wheeled
cart). This simplification also shortened the time required to assemble and clean a radiator
core. As presented in the Technical Evaluation of Chapter 4, core cleaning time has been
reduced by 50 percent by the implementation of the aqueous wash system. These
activity and time variations are essential to the results of ABC, and will be discussed for each
primary activity within the ABC economic evaluation.
ABC analysis is completed when the bill of differing activities are combined with the
appropriate cost drivers to calculate a cost of activities. The ABC analyses for the solvent
degreasing and aqueous wash processes are presented in Table 19. As can be seen in this
summary of results, the changes in activities due to the implementation of the aqueous wash
system result in significant activity-based cost savings. The frequency at which activities
59
-------
TABLE 1 1 . TRADITIONAL COST ANALYSIS OF THE
RADIATOR MANUFACTURING LINE
Cost Category
Capital Investment
Annual Costs
Depreciation of Capital
Raw Materials
TCA
Detergent
Water
Wastewater Chemicals
Energy Requirements
Electricity
Natural Gas
Waste Management
TCA Disposal
Wastewater Treatment
Solids Disposal
Oily Waste Disposal
TOTAL ($/yr)
quantityAr
15.820 gal
2,640 gal
2,000,000 gal
$/quantity
$4.62/gal
$7.70/gal
$0.00134/gal
Sec footnote c
7,800,000 SCF
10,600 gal
11,880 gal
1,320 gal
$0.035/kW-hr
S3.60/SCF
$1.84/gal
$0.27/gal
$0.64/gal
Solvent
Degreasers
0
$/yr
(1991b)
$76,000
0
0
0
$20,970
0
$20,300
0
0
$117,270
Aqueous
Wash
$463,594
$/yr(1991)
$66,230a
0
$20330
$2 700
$10,800
$ 1 1 290
$28,080
0
$3 220
$840
$143,490
The capital investment of the aqueous wash system is depreciated over seven (7) years using a straight-line
method. The yearly depreciation cost of the- aqueous wash system is therefore' $463 594/7 years =
$66,230.
Values from 1990 were brought to equivalent dollars (1991) using a 4 percent interest rate.
The cost of Wastewater chemicals includes K) percent of the sulfunc acid, sodium hydroxide, and polymer
used to treat the mil water waste stream, as well as 100 percent of the costs for the acid and lime required
for detergent bath shocking.
Wastewater solids disposal costs represent K) percent of the total generation rate of wastewater solids.
50
-------
on-line. Other employees included in these maintenance activities include two or three line
personnel. The aqueous wash system, for the past two years of operation, has had zero down
time due to maintenance problems. Scheduled yearly maintenance of the degreasers was also
more time consuming and labor intensive when compared to the new, aqueous wash system.
Therefore, an additional savings of $84,500 can be attributed to the aqueous wash system due
to reduced maintenance.
The activities associated with aqueous wash wastewater treatment were the only
significant additional activities resulting from the implementation of the alternative cleaning
method. The treatment of this wastewater resulted in activity-based costs of $23,600. This is
an additional cost that must be attributed to the new system.
ABC Analysis of the Condenser Manufacturing Line
Tables 20 presents the primary activities which differ between the old, solvent
degreasing systems and the new, evaporative lubricant alternative for the condenser line. The
activity of these processes are quite different and unique. The implementation of the
alternative system eliminated a number of activities associated solely with the degreasing
process. Also presented in Table 20 are the costs drivers used to evaluate the costs of each
activity.
The ABC economic evaluation of the condenser line activities are presented in Table
21 A savings of $62,150/yr was calculated based on activity-based costing due to the
implementation of the evaporative lubricant system. The contributions to this savings by the
primary activities are discussed below
TABLE 20. PRIMARY ACTIVITIES UNIQUE TO THE SOLVENT DEGREASING
AND EVAPORATIVE LUBE SYSTEMS OF THE CONDENSER LINE
Solvent Degreasing System
paperwork for ordering and
receiving TCA
receipt of TCA
maintaining solvent
degreasing units - daily
maintaining solvent
degreasing units - yearly
permitting and monitoring of
hazardous waste generation
facility
Cost Drivers
$/order
$/receipt
$/labor hr
$/labor hr
$/labor hr
and fees
Evaporative Lube System
Primary Activities
maintaining flash driers
permitting and monitoring of
VOC emissions
Cost Drivers
$/labor hr
$/labor hr
and fees
61
-------
The direct cost analysis, as presented in Table 12, does not support the investment into
the aqueous wash system to replace the solvent degreasing system using typical industrial time
horizons and if cost is the only factor influencing the decision. Though the raw materials and
waste disposal costs of the alternative system are significantly less than comparable costs for
the solvent degreasing system, the $463,594 capital investment costs, depreciated over seven
years, overshadow these benefits. The return on investment was determined to be 11.6 years.
The use of a 5-year time horizon, typical of most industrial capital investment analyses,
supports the continued operation of the solvent system. As shown in Table 12, the solvent
degreasing system has a 5-year net present value (hereafter referred to as NPV) which is
$147,700 better in relation to the NPV of the aqueous wash system. Only when the full cost
of the aqueous wash capital investment is depreciated are the benefits of the alternative
financially observed. This is also shown in Table 12 where the aqueous wash system is
$294,160 better in relation to the solvent system when a 15-year NPV calculation is used.
TABLE 12. RETURN ON INVESTMENT AND COMPARISON OF
NET PRESENT VALUES - RADIATOR
Analysis
Payback
NPV (5-year)
NPV(lO-vear)
NPV(15-vear)
Solvent System
$660,580
$1,464,270
$2,442,090
Aqueous Wash System
11.6 years
$808,280
$1,508,720
$2,147,930
Notes: 1.
2.
3.
4.
i = interest rate per interest period = four percent.
the capital investment of the aqueous wash system was depreciated (straight-line) over seven
years.
assumptions: inflation rate of zero and equal costs per year.
dollar values represent costs.
Traditional Cost Evaluation of the Condenser Manufacturing Line
The two solvent degreasers of the condenser manufacturing line were made obsolete
with the implementation of the evaporative lubricant system. The installation of the flash
driers represents the capital expenditure required to eliminate the solvent units and implement
the alternative system. Capital costs for both the solvent degreasing units and the evaporative
lubricant flash driers were available. As a point of comparison, these costs are presented in
Table 13; the cost for the solvent system is presented in 1993 equivalent-year dollars, the year
the flash driers were installed. As shown by these values, solvent degreasing systems require a
significantly greater capital expenditure (more than twice as much for this particular example)
than do the flash driers utilized in evaporative lubricant system.
52
-------
TABLE 22. COMPARISON OF OPERATING AND MAINTENANCE COSTS -
CMC ESTIMATES VERSUS ABC RESULTS
Process
Solvent Degreasers
Evaporative Lubricant
CMC Estimate3
($/yr)
$5,620
$660
ABC Results
($/yr)
$37,400
$1,250
Estimates base on multiplication factors of capital investment costs.
HYBRID ACCOUNTING SYSTEM
Combining the traditional, direct cost economic analyses with the expanded cost
analyses of ABC will more accurately represent the costs and benefits of the alternative
processes implemented by CMC. As previously stated, the analysis of direct costs, as
performed in traditional cost analyses, does not capture the benefits and costs hidden in
overhead expenses. The application of ABC was the analytical tool used to allocate unique
overhead costs to the appropriate processes and products. A hybrid of these analysis methods
will more fully capture the costs and savings of pollution prevention projects. The hybrid
analyses for the radiator and condenser manufacturing lines are presented in the following
sections.
Hybrid Analysis for the Radiator Manufacturing Line
The traditional economic analysis for the process changes of the radiator
manufacturing line did not support CMC's investment into the aqueous wash system if cost is
the only factor considered. Over a five-year time horizon the solvent system would have been
less expensive to operate. However, by accounting for the overhead costs through ABC, the
economic incentives of the aqueous wash system are revealed. The traditional cost system did
not account for the administrative cost savings due to less raw materials being received, less
operating and maintenance costs, and simplified permitting and reporting requirements
associated with the aqueous wash system when compared to the solvent degreasing system.
The hybrid analysis is presented in Table 23. The payback and NPV calculations utilizing the
values of Table 23 are presented in Table 24. Also included in this table, for comparison, are
similar results from the traditional analysis.
Hybrid Analysis for the Condenser Manufacturing Line
The investment into the flash driers required for the evaporative lubricant system was
supported by the traditional analysis. The $44,000 capital investment, and the increased cost
of the evaporative lubricant, were off-set by the savings attributed to the elimination of TCA
purchase and disposal costs. The application of ABC to this system, however, further
accentuates the benefits of the alternative system by allocating unique overhead costs to the
63
-------
TABLE 14. TRADITIONAL COST ANALYSIS OF THE CONDENSER
MANUFACTURING LINE
Cost Category
Capital Investment
Annual Costs
Depreciation of Capital
Raw Materials
TCA
Petro. Lubricant
Evap. Lubricant
Energy Requirements
Electricity
Waste Management
TCA Disposal
Permits and Fees
VOC Emissions
TOTAL ($/yr)
quantity/yr
11, 200 gal
480 gal
480 gal
7,000 gal
12,200 Ib
$/quantity
$6.60/gal
$5.20/gal
$9.84/gal
$0.035/kW-hr
$1.84/gal
$4.00/ton
Solvent
0
$/yr
(1994b)
$80,040
$2,700
0
$12,580
$13,800
$900
0
$110,020
Evap. Lube
$44,000
$/yr(1994)
$6,286a
0
0
$4,720
$6,710
0
$24
$17,740
a The capital investment of the evaporative lubricant system (flash driers) is depreciated over seven (7)
years using a straight-line method. The yearly depreciation costs of the flash driers is therefore' $44 000/7
years = $6,286.
b Values from 1992 were brought to equivalent 1994 dollars using a four percent inflation rate.
The rates of lubricant consumption for the old, petroleum-based lubricant and the new,
evaporative lubricant are identical, 480 gal/yr. However, the rate of consumption and cost of'
each lubricant are included in Table 14 due to the difference in lubricant costs. The
petroleum-based lubricant, at a cost of $5.20/gal, generates a consumption cost of $2,500/yr;
the evaporative lubricant, at a cost of $9.84/gal, creates a consumption cost of $4,720/yr.
This cost difference must be accounted for in this direct cost analysis.
54
-------
TABLE 25. HYBRID COST ANALYSIS OF THE PROCESS CHANGES TO THE
CONDENSER MANUFACTURING LINE
Cost Categories
Annualized Capital Investment
Raw Materials
Energy Requirements
Waste Management
ABC Costs
TOTAL
Solvent Degreasing
System
($/yr)
0
$82,740
$12,580
$14,700
$83,400
$193,420/yr
Evaporative Lubricant
System
($/yr)
$6,290a
$4,720
$6,710
$24
$21,250
$38,994/yr
The annualized capital cost is based on a 7-year, straight-line depreciation schedule.
TABLE 26. COMPARISON OF HYBRID AND TRADITIONAL ANALYSES -
CONDENSER MANUFACTURING LINE
Analysis
Payback
NPV (5-year)
Hybrid Analysis
Solvent System
$1,089,550
Evaporative
Oil System
0.27 years
$219,660
Traditional, Direct Cost Analysis
Solvent System
$619,750
Evaporative
Oil System
0.45 years
$99,930
Notes: 1. i = interest rate per interest period = four percent.
2. the capital investment of the aqueous wash system was depreciated (straight-line) over seven
years.
3. assumptions: inflation rate of zero and equal costs per year.
4. dollar values represent costs
65
-------
Traditional economic evaluations such as that presented above utilize categories of
cost that are fairly easy to identify and which are readily available from most financial
accounting systems. These cost categories include capital investments, direct materials, direct
labor, and waste disposal costs. Overhead costs, which can represent a significant portion of
an industry's costs, are typically ignored, or allocated to processes or products using an
arbitrary and easily measured parameters such as labor hours or machine hours. This
approach for economic analyses has limitations when evaluating pollution prevention projects.
Many of the economic benefits of pollution prevention projects occur in reduced overhead
expenses, and arbitrarily distributing these costs may not reflect the true benefits of a pollution
prevention project. Even though each of the analyses above seem to support the
implementation of the alternatives, the full benefits of the new systems were not identified and
accounted for. If the traditional cost analysis of the old and new processes were much closer,
the additional benefits/costs associated with a pollution prevention project could have been the
pivotal set of data to support the investment in the alternatives. For this reason, the basic
economic evaluation presented above is supplemented by an activity-based cost'analysis. A
definition of ABC, a description of the approach taken for this project, and the results of the
analysis are presented below.
ACTIVITY-BASED COST ACCOUNTING
The analysis of direct costs, presented above, is traditionally used by industry to
evaluate capital budgeting projects. As previously stated, however, this analysis of direct
costs may not capture all the benefits of a project, specifically pollution prevention projects
such as the alternatives implemented by CMC. A system to define and allocate the costs and
benefits of Tiers 1, 2 and 3 of Table 10, would more accurately represent the costs and
benefits of such pollution prevention projects. ABC was the tool applied in this second
economic analysis to allocate costs and benefits beyond Tier 0.
Simply stated, ABC allocates overhead costs to products or processes based on the
activities which result from the production of the product or the operation of the process.
Overhead costs (denoted indirect costs in Tier 1) include administrative costs, regulatory
compliance costs, quality control costs, training, and workman's compensation. Associated
with each overhead cost are indirect activities which support the production process. These
activities can include supervision, materials handling, records keeping, permitting, monitoring,
and product testing. The allocation of each indirect activity to the product or process which '
creates it, will more accurately represent the costs and benefits of the alternative systems.
Once allocated, the frequency, duration, and cost driver of each activity is determined. Cost
drivers, the key to ABC, are systematic linkages between activities and costs. These
procedures, as they apply to this project, are presented below.
ABC Analysis of CMC
The approach taken in this project for ABC began with a clear understanding of the
various steps associated with the process lines of interest. To develop this clear understanding
of all the steps in the manufacturing process of a radiator or condenser, a bill of activities
(BOA) for each process line (radiator and condenser, old and new) was developed. The
56
-------
CHEMICAL PRODUCTION PROCESSES
The chemical production process is the first stage of the life-cycle evaluated for this
research. The production processes for the chlorinated degreasing solvents and components
of industrial detergents result in chemical emissions to the environment. Portions of these
emissions must be attributed to the industrial processes which utilize the chemical products
(i.e. solvent degreasers or detergents) when life-cycle principals are applied. Therefore, the
following sections evaluate the environmental releases and transfers from the chemical
production processes of degreasing solvents and detergent components. The fraction of these
emissions which may be attributed to their use in parts cleaning, or alternatives to parts
cleaning, is also assessed.
Production of Chlorinated Solvents
There are a variety of processes utilized to produce the chlorinated degreasing
solvents. Many of these chemicals are co-produced with other 33/50 chlorinated organics.
The chemical processes include the following:
1. DCM is predominantly produced through the hydrochlorination of methanol
(co-produced with chloroform and carbon tetrachloride). Raw materials
include hydrogen chloride and methanol.37
2. PCE is produced either by the hydrocarbon chlorinolysis (60 percent) or
oxychlorination of ethylene dichloride (40 percent) processes. Feed stocks for
the chlorinolysis process include propane, propylene, acetylene, naphthalene,
ethylene dichloride, crude chloroform, and chlorine gas. Oxychlorination feeds
include ethylene dichloride, chlorine gas, and oxygen. TCE is a co-product of
the oxychlorination process.38
3. The production of TCE (co-produced with PCE) is accomplished using the
chlorination of ethylene dichloride. Ethylene is the primary feed with chlorine
gas, which reacts through the chlorination process to form ethylene dichloride.
Ethylene dichloride is further chlorinated to produce TCE.39
4. The most widely used process for producing TCA involves the
dehydrochlorination of ethylene dichloride to vinyl chloride, which is then
hydrochlorinated to 1,1-dichloroethane. The 1,1-dichloroethane is thermally or
photochemically chlorinated to produce TCA. In another important process,
hydrogen chloride is added to 1,1-dichloroethylene in the presence of an iron
chloride catalyst to produce TCA.40 Figure 12 shows the life-cycle flow
diagram for TCA which traces the process for manufacturing TCA back to raw
materials.41
67
-------
TABLE 17. PRIMARY ACTIVITIES UNIQUE TO THE SOLVENT DECREASING
AND AQUEOUS WASH SYSTEMS OF THF R AniATrvR T nvrir
Solvent Decreasing System
Primary Activities
paperwork for ordering and
receiving TCA
receipt of TC A
assembly and cleaning of
radiator cores
maintaining solvent
degreasing units - daily
maintaining solvent
degreasing units - yearly
leak testing
permitting and monitoring of
hazardous waste generation
facility
Cost Drivers
$/order
$/receipt
$/core
$/labor hr
$/labor hr
$/core
$/labor hr
and fees
Aqueous Wash Sy
* f
Primary Activities
paperwork for ordering and
receiving detergent
receipt of detergent
assembly and cleaning of
radiator cores
maintaining aqueous wash
system - daily
maintaining aqueous wash
system - yearly
leak testing
wastewater treatment
activities
permitting and monitoring of
wastewater treatment facility
stem
— — — — — ^__
Cost Drivers
$/order
$/receipt
$/core
$/labor hr
$/labor hr
$/core
$/labor hr
$/labor hr
and fees
As can be seen in this table, there are similar activities between the solvent degreasing
and aqueous wash processes. These similarities include ordering and receiving raw materials
assembling and cleaning radiator cores, and leak testing of the completed cores. Though the'
definition of these primary activities are identical, the supporting activities, frequency and
time required for each activity vary. An example of such variations is presented in Table 18
in which a portion of the full BOA for the assembly and cleaning steps is presented for the old
and new processes of the radiator line. An explanation of the differences follows the table
58
-------
Emissions of the chlorinated solvents from production processes can originate from
the intermittent or continuous purging of inert gases from reactor vessels, drying beds,
finishing columns, and other process vessels. Fugitive air emissions can result when process
fluids leak from plant equipment such as pumps, compressors, and process valves. Air
emissions from storage and handling operations also occur at production facilities. Other
sources of environmental releases or transfers include the following:
n wastewater discharges directly from the plant into rivers, streams or other
bodies of water, or transfers to a POTW;
n on-site release to landfills, surface impoundments, land treatment, or other
modes of land disposal;
n disposal of wastes by deep well injection; and
n transfers of wastes to off-site facilities for treatment, storage or disposal.
In 1992 there were four major companies at six locations within the U.S. that
produced the chlorinated degreasing solvents. Table 27 lists these producers, their products,
and their annual production capacity. The environmental releases and transfers of the
chlorinated degreasing solvents from these producers were retrieved from the 1992 TRI.
These data are presented in Table 28. Many of the facilities reported multiple SIC codes
under TRI, indicating the data may include releases and transfers from internal use of the
chemicals after production.
The six chlorinated solvent production facilities released or transferred nearly 1.3
million pounds of chlorinated solvents in 1992. On-site air releases represent the vast majority
of these production releases and transfers, nearly 94 percent. Off-site transfers, mainly to
facilities other than POTWs, represent only 2.2 percent of all production emissions.
Not only are releases and transfers a result of the production of the degreasing
solvents, but also of their distribution. Almost all of the DCM and TCE sold, and
approximately 70 to 75 percent of the PCE sold, are distributed through distribution
facilities.42 No information was available on the amount of TCA distributed through these
facilities or the amount of TCA emissions from distribution facilities. Distribution facilities are
not required to report their emissions in TRI. However, using the concepts of life-cycle
assessment, some of the halogenated organic emissions from distribution facilities should be
associated with their distribution to degreasing facilities.
In 1992, solvent degreasers consumed approximately 36 percent of chlorinated
degreasing solvents produced in the U.S. The rate of consumption for each solvent in
degreasing applications is presented in Table 29. These values are based on the demand
figures of Table 27 and the chemical use tree diagram, Figure 1 of Chapter 1. When
considering environmental impacts from a life-cycle perspective, some fraction of the
production releases and transfers presented above must be associated with their use in solvent
degreasing. Designating which emissions from the production facilities were a result of
manufacturing a specific solvent is not possible from the data of Table 28. However, direct
application of the average solvent consumption fraction for degreasing (36 percent), to the
total TRI production releases establishes that over 460,000 Ib/yr of the chlorinated degreasing
solvents emitted by their production may be attributed to solvent degreasing.
69
-------
occurred, as well as the elimination of very costly activities (i.e., machine and labor intensive
activities), contribute to these savings. The alternative cleaning system eliminated many
activities and added very few. An ABC-savings of $215,770/yr was calculated due to the
implementation of the aqueous wash system. The contributions from each group of activities
is discussed below.
TABLE 19. SUMMARY OF ABC RESULTS FOR THE RADIATOR
MANUFACTURING LINE
Primary Activities
paperwork for ordering and
receiving
receipt of materials
assembly and cleaning
maintenance - daily
maintenance - yearly
wastewater treatment
permitting and fees (labor)
TOTAL
SAVINGS
Costs ($/yr) of Solvent
Degreasing Process
$5,000
$7,000
$175,300
$87,500
$32,300
0
$34,000
$341,100
-
Costs ($/yr) of Aqueous
$2,500
$3 500
$58,430
$5,400
$29 900
$23 600
$2,000
$125,330
$215 770
The number of materials received for each process remained the same; the elimination
of TCA resulted in the need for a detergent product. However, the frequency of receipt and
the quantity of chemicals required to maintain the aqueous wash system decreased
significantly when compared to the solvent degreasing system. Thus, a $6,000 savings was
attributed to the aqueous wash system based solely on the activities (direct and supporting) to
maintain the materials inventory (including paperwork and receipt).
As stated in the Technical Evaluation of Chapter 4, the solvent degreasing process
represented the bottle-neck of the radiator manufacturing line. Time requirements to clean
each core have been reduced by the aqueous wash system by 50 percent. The activities
associated with the cleaning process, however, have been reduced by two-thirds and
represents a cost savings based on employee time and equipment operation. Accounting for
these costs result in a $116,870 activity-based cost saving for the aqueous system (or cost to
the solvent system). Also stated in the technical evaluation, and identified in Table 19, are the
considerable differences of process maintenance. The solvent degreasers were down due to
maintenance problems nearly five percent of the time. During these down times, the line
supervisor, lead, and technician spent their entire time trying to get the degreasers back
60
-------
C/2
jr
Eg
O
en
O
NN
cn
O
w
Q
O
5 S
Z H
1|
5 fa
r_. Jj<
o 2
gg
C/2 O
5 g
H §
O °
2 £
^^
en
W
i
2
H
oo
-J
«
^^
H
*-^~^
^•^
t
on
§
H
1
on
0)
c$
"o
- -S IS
"o t*i« 3
H o £
b|j
"S <^!d C
O 5 §
t™^
i_i
^ <*H
s 1
OH H
«i ^
— i *3 1>
H ^ -S
^
-g
3 S 4>
?-S a
5b o
1 1
J cS
-
*^D ^^ CO ^^"
^^ C^4 ^~^
fS -—I (N
O O O O
O O O O
(N
— Tf Tf O
~-| n
o o o o
cs
O O O — '
o o o t~~
T" H
oC
o o o o
o o o o
O O O f>-
•~H
»n
o o o o
00
'S^N
oo
VD
R
s
1)
1
"u
OH
1^ ^
^w ^J< ^^
'3 ^ S U U U
o
-------
TABLE 21. SUMMARY OF ABC RESULTS FOR THE CONDENSER
MANUFACTURING LINE
—•
Primary Activities
^""^••^•^^"i^—^^™^^^^
paperwork for ordering and
receiving
receipt of materials
Costs ($/yr) of Solvent
Degreasing System
$5,000
$7,000
Costs ($/yr) of Evaporative
Lubricant System
maintenance - daily
$31,800
$750
maintenance - yearly
$5,600
$500
permitting and fees (labor)
TOTAL
$34,000
"•••••••••I
$83,400
$20,000
—n^—n^^^^«
$21,250
SAVINGS
$62,150
As presented above, the areas of activity change for the condenser line include
materials receipt and maintenance. The elimination of the solvent degreasers eliminated the
need to receive TCA on a regular basis. The substitution of one lubricant for another, with
identical rates of use, does not change the materials receipt activities. Therefore, a savings of
$12,000 attributed to the new system due to the decreased materials receipt was'identified
Standard maintenance of solvent degreasers added additional activities to the solvent
degreasing systems that are not present in the new alternative system. The flash driers, added
to the process to evaporate the new lubricant, require little to no maintenance. Therefore the
maintenance differences resulted in a $36,1 50 savings for the new system.
The data table for the condenser manufacturing lines presented in Appendix A also
include estimates for operating and maintenance costs for the parts cleaning units These
estimates are multiplication factors used by CMC based on the capital cost of the equipment.
Table 22 presents these estimates and compares them with the results of Table 21.
Maintenance labor for the solvent and evaporative oil systems were reported by CMC as a
percentage of the capital costs of each unit: three percent for the solvent system and 0.5
percent for the evaporative oil system. Maintenance materials were also estimated by CMC as
an estimate of capital costs: two percent for the solvent systems and one percent for the
evaporative oil systems. A 1992 equivalent value for the solvent degreasing units was used to
determine these costs. From the results presented in Table 22, it is apparent that standard
accounting practices for determining maintenance costs based on capital expenses or other
parameters do not accurately represent the true costs of a system. Estimates of the
maintenance costs of the solvent degreasers were 6.7 times lower than the costs determined
using ABC. The evaporative oil systems costs estimates using CMC's methodology was
nearly half the costs established using ABC
62
-------
TABLE 29. CHLORINATED SOLVENT CONSUMPTION BY DECREASING
APPLICATIONS
Solvent
DCM
TCA
TCE
PCE
TOTAL
Total 1992 Demand
(million Ib/yr)
390
600
145
250
1,385
Percentage Consumed
in Degreasing
11
49
90
13
36.1a
Annual Degreasing
Consumption
(million Ib/yr)
42.9
294.0
130.5
32.5
499.9
Weighted average calculated from total 1992 demand figures and annual consumption percentages of
columns 2 and 4, respectively.
Production of Detergent Ingredients
Industrial detergents are mixtures of a variety of chemical components, the most
significant of which are surfactants, builders, and chelators. The possible combinations of
these components are huge when it is considered that there are over 500 anionic or nonionic
surfactants commercially available, and 42 chelating chemicals.43 For this reason, typical
product ingredients were evaluated instead of specific product formulations. Included in the
evaluation are the two specified ingredients of CMC's detergent: tetrapotassium
pyrophosphate and an ethoxylated secondary alcohol To cover the potential range, additional
ingredients which represent a significant portion of the market are also evaluated. Production
releases and transfers are evaluated for the manufacturing processes of these chemicals to
determine the environmental impacts associated with the production of detergent ingredients.
Surfactants. Commercially available surfactants are not single-component products; rather,
they are 'polydispersed mixtures of molecules which are all the same type (i.e. identical
functional groups), but which vary only in chain length or in some other structural detail.'44
Figure 13 shows the production routes for several of the major surfactant polydispersion
mixtures.45 The complexity of surfactant polydispersions makes it difficult to specifically
identify an isolated chemical species to represent all surfactants. Therefore, the
polydispersions evaluated in this report are alcohol ethoxylates, ethoxylated nonylphenol, and
alkylbenzene sulfonates.
73
-------
activities that create them. Table 25 presents the hybrid analysis for the condenser
manufacturing line. Table 26 compares the payback and NPV calculations using the hybrid
analyses of Table 25 to the results of the traditional analyses.
TABLE 23. HYBRID COST ANALYSIS OF THE PROCESS CHANGES TO THE
RADIATOR MANUFACTURING LINE
Cost Category
Annualized Capital Investment
Raw Materials
Energy Requirements
Waste Management
ABC Costs
TOTAL
Solvent Degreasing System
($/yr)
0
$76,000
$20,970
$20,300
$341,100
$458,370/yr
Aqueous Wash System
($/yr)
$66 230a
$33,830
$39370
$4,060
$125,330
$268 820/yr
a The annualized capital cost is based on a 7-year, straight-line depreciation schedule.
TABLE 24. COMPARISON OF HYBRID AND TRADITIONAL ANALYSES -
RADIATOR MANUFACTURING LINE
Analysis
Payback
NPV (5-year)
NPV(lO-vear)
NPV(15-vear)
Hybrid Analysis
Solvent System
$2,584,150
$5,725,530
$9,547,510
Aqueous Wash
System
2.4 years
$1,514,260
$3,073 640
$4,762,870
Traditional, Direct Cost Analysis
Solvent System
$660 580
$1,464,270
$2,442 090
Aqueous Wash
1 1.6 years
$808 280
$1 508 720
$2,147930
Notes
i - interest rate per interest period = four percent.
the capital investment of the aqueous wash system was depreciated (straight-line) over seven
years.
assumptions: inflation rate of zero and equal costs per year.
dollar values represent costs.
-------
Alcohol ethoxylates are the general class of surfactants which includes the secondary
ethoxylated alcohol surfactant identified by CMC's detergent's Material Safety Data Sheet.
Various sources identify ethoxylated nonylphenol as a primary nonionic industrial
surfactant,46'47 and discussions with the Specialty Chemicals Manufacturing Association
identified linear alkylbenzene sulfonates (hereafter referred to as LAS) as an example of an
anionic industrial surfactant.48 Dodecylbenzene sulfonic acid will represent the general LAS
class of industrial surfactants.
Ethoxylated Alcohols: Figure 13 shows that ethoxylated alcohols can use petroleum, natural
gas, animal fat, or plant oils as primary raw materials. The ethoxylation of secondary alcohols
with ethylene oxide is the manufacturing scheme for ethoxylated secondary alcohols.
Ethylene oxide is manufactured by the oxidation of ethylene over a silver catalyst. The source
of secondary alcohols is either natural gas, petroleum, or natural feed stocks. Primary
alcohols react in the ethoxylation reaction more readily than do secondary and tertiary
alcohols. The ethylene chain build-up reaction occurs at a rate similar to the ethoxylation of
the alcohol. As a result, the ethylene oxide chain is built up before all alcohol has been
reacted, and a polydispersed mixture containing nominally eight ethylene oxides will contain
significant amounts of other ethoxylates containing from 0 to 20 ethylene oxide units.49
Eleven manufacturers at fifteen facilities produced the general category of ethoxylated
alcohols within the U.S. in 1992. These facilities and their locations are presented in Table
30. No data were available on whether these were primary, secondary, or tertiary ethoxylated
alcohols. Each of these manufacturers reported under multiple SICs to TRI indicating the
manufacture of a variety of chemical products. Therefore, the 1992 TRI releases and transfers
from these facilities, presented in Table 31, do not exclusively represent emissions from the
production of ethoxylated alcohols. An evaluation of the TRI data indicates a variety of toxic
chemical emissions. The chemical raw materials for the production of ethoxylated alcohols;
ethylene, ethylene oxide, ethylene glycol, and methanol, were common chemicals released or
transferred from these facilities. Emissions to air dominated on-site releases (more than 98
percent), while 'other' transfers dominated off-site emissions from these facilities (nearly 70
percent).
The basic raw materials for the production of ethoxylated alcohols; alcohols and
ethylene oxide, result in additional chemical emissions during their production processes. The
TRI releases and transfers presented in Table 31 may not reflect these emissions, and
therefore, the following qualitative evaluation is given.
75
-------
CHAPTER 7
NATIONAL ENVIRONMENTAL IMPACT EVALUATION
The extraction of raw materials, manufacturing processes, use, reuse and disposal
represent the basic stages of a product's life-cycle. Each stage within this life-cycle emits a
variety of wastes to the environment. The national environmental impact evaluation
qualitatively assessed the life-cycle stages of chemical manufacturing, use, and disposal for
solvents and their use in solvent degreasing applications, and detergent chemicals and their
application in parts cleaning.
Within the U.S. there are an estimated 24,500 solvent degreasers which consume
nearly 500 million Ib/yr of chlorinated degreasing solvents.35 Production processes, as well as
the use and disposal of chemicals, result in significant chemical releases and transfers to the
environment. The analyses of this project identified the use stage as the major contributor to
the life-cycle releases and transfers of chlorinated solvents. EPA estimated over 283 million Ib
in air releases alone occur each year from solvent degreasing operations.36
In contrast, aqueous wash systems consume less chemicals by volume in the use life-
cycle stage. Based on order-of-magnitude calculations, this reduced chemical use probably
reflect less chemical releases and transfers from production facilities. The predominant
environmental emission from aqueous wash systems is wastewater. An assessment of the
nation's municipal wastewater treatment infrastructure suggests that its treatment capacity and
capabilities will be adequate to accommodate a large shift from solvent degreasing to aqueous
wash systems.
NATIONAL ENVIRONMENTAL IMPACT BACKGROUND
The objective of this analysis is to identify and evaluate the national environmental
impacts which are possible if entire industrial sectors were to replace chlorinated degreasing
solvents with alternative cleaners and/or cleaning systems similar to those implemented by
CMC. Data from the Environmental Evaluations of Chapter 5 are supplemented in this
analysis with additional data from literature, on-line databases, and other sources.
Releases and transfers of chemicals to the environment occur throughout their life-
cycles; from their production, use, and disposal. The replacement of chlorinated degreasing
solvents with alternative cleaning systems by entire industrial sectors can greatly influence the
releases and transfers from each of these life-cycle stages. Therefore, for this national
environmental impact evaluation, the releases and transfers associated with the production of
chemicals, as well as the releases and transfers due to their use and disposal, are evaluated A
multimedia approach for these evaluations, analyzing releases and transfers to land, air and
water, is applied.
66
-------
en
H
MM
U
^^
u.
z
o
p
^J
o
o
o.
O
K
O
u
^
H
•^
^j
>.
X
o
E
u
o
ON
u.
fa
C/2
z
2
H
CO
W
^2
^
w
-j
!*
f)
TABLE
'g
i,
i/j
i— i
i/i
i_
H
C
03
co
I/I
C3
JU
c2
D i^
— - .tn U
-t-> ^ CO
O f . . f— 1
H ca g
0 £
CO
*"" -"^ Js
1^ f t ^ r^
o « «3
0 £
i—
^~>.
H 1
O 2
^ ) r ^
— , " "
•4— > cio cd
O " ^W
H O ^
T3
3 S n
m'
T^
O
m'
T^
O
O
r^
^^
t^
O
O
o
CN
r^_
_'
U
P-( j3
< 0.
CQ oo
(N
r— I
Tf^
. — T
o
(N
.— i
2>
,_,.
^n
^_i
o
0
o
(N
in
in
^-i
. OH
Q
| =
iis
^__
ps)
r^l
oc"
r*"~i
o
,
f^l
oc"
«r,
r-'
0
o
^
o
oc
t~--'
6
k— 1
cn
C-> OO
CO
O ^2
03 o3
^
in
in^
t^T
(N
IN"
CN
ON
5"
t^
m'
o
o
o
5
(N^
co"
r— i
0 ^
- .S
13 "3
u =2
3C 2
in oo
ON r-
VD^ ^
oo" CN"
O oc
O (N
^ J
>n o
ON in
in CN
m"
\o m
CN ON
O O
o o
o o
CN ON
in CN
_'
d
Rhone-Poulenc In
Winder, GA
Baltimore, MD
O 00
^t" '-~l
oo O
t^-" CN"
l/*j CO
1 — 1
O OO
OO O
m m
O O
r^i oo
00 CN
o" CN"
m
i™H
o o
o o
ON O
ON
rt 00
oo CN
' 'r, ' ^
oo" CN"
m
m
— "
»>->
l™~] ^ ^
O ' *™H CO
*™H .. |_. j
CO W OH
O
in
t*>-
CN"
in
^
o
in
r--
*^1
3-
o
o
ro
'O
*^o
0
?— H
ro
"
o
J*
^ p
r5
t~-~-_
>n
>n
^o
Id
o „,-
u -^
.*-» '^
l
ON
O^
i — r
i/^
1-H
ON
3
*-/^)
^
O
OO
oo
ON
^^
O
"*^"
>n
o"
oc
o
o
oo
»n"
o
>n
^vC"
00
ON
d
C_)
Texaco Chemical
Port Neches, TX
77
-------
O
68
-------
Nonylphenol Ethoxylates; Nonylphenol ethoxylate is manufactured by the ethoxylation of
nonylphenol with ethylene oxide. Ethylene oxide is a widely used ethoxylating compound,
and is manufactured by the oxidation of ethylene over a silver catalyst, as explained above.
Nonylphenol is produced by the alkylation of phenol using propylene trimer, a derivative of
the (alpha)-olefm propene. Phenol can be made by several oxidation processes which utilize
toluene and derivatives of benzene as a feed stock. The most common feed stock in the
phenol production process is cumene, which is manufactured by the alkylation of benzene with
propene.53 Figure 14 is a simplified process diagram for the manufacturing process of
nonylphenol ethoxylate.54 In 1980, nonylphenol ethoxylates accounted for 73.6 percent of
U.S. production of alkylphenol ethoxylates.53 The fifteen facilities that produce nonylphenol
ethoxylate are listed in Table 32.
TABLE 32. PRODUCERS OF ETHOXYLATED NONYLPHENOL
SURFACTANTS
Producer
Harcros Organics
Inc.
Henkel of America,
Inc.
Kao Corp. of
America
Milliken & Co.
PPG Industries, Inc.
Rhone-Poulenc Inc.
Rohm and Haas
Company
Location
Kansas City, KS
Charlotte, NC
Mauldin, SC
High Point, NC
Inman, SC
Gurnee, IL
Winder, GA
Deer Park, TX
Producer
Stepan Company
Texaco Inc.
Union Carbide
Company
Witco Corporation
Location
Millsdale, IL
Winder, GA
Port Neches, TX
Texas City, TX
Harahan, LA
Houston, TX
Santa Fe Springs,
CA
Source: 1992 Directory of Chemical Producers, United States of America, SRI International
79
-------
TABLE 27. SUPPLY AND DEMAND OF THE CHLORINATED DECREASING
SOLVENTS
Producer
Dow Chemical, USA
Freeport, TX
Plaquemine, LA
Occidental Petroleum Corp.
Belle, WV
PPG Industries, Inc.
Lake Charles, LA
Vulcan Materials
Geismar, LA
Wichita, KS
TOTAL SUPPLY
1991 Demand
1992 Demand
1996 Demand
1992 Capacity (million Ib/yr)
DCM
110
120
111
—
80
130
551
400
390
345
PCE
__
90
__
200
150
50
490
250
250
350
TCA
500
350
200
1050
640
600
Oa
TCE
120
200
320
160
145
140
a U.S. production of TCA must be phased out by 1995.
Source: Chemical Marketing Reporter
70
-------
Table 33 presents the 1992 TRI reported emissions from the production facilities of
nonylphenol ethoxylate listed in Table 32. Due to the production of multiple products, and
multiple SICs reported by some of these facilities, the releases and transfers of Table 33
cannot be wholly attributed to the production of nonylphenol ethoxylate. However, from a
life-cycle perspective, some portion of the appropriate production emissions are the result of
surfactant use in industrial detergents, and therefore, must be attributed to that use. Off-site
transfers represent near three-quarters of all releases and transfers reported by these facilities.
Air releases represent 98 percent of on-site emissions; 'other' transfers represent the vast
majority of the off-site emissions (72 percent).
The production of nonylphenol ethoxylate, as stated above, relies upon phenol,
propylene, and ethylene (ethylene oxide), all of which are distillation products of crude oil or
natural gas. Phenol is produced from toluene and benzene, and propylene and ethylene are
produced from straight-chain hydrocarbons from the distillation of crude oil or natural gas.56
Again, the potential emissions from these chemical production processes must be evaluated
when evaluating life-cycle environmental impacts. Toluene, benzene, phenol, propylene,
ethylene, and other hydrocarbons must all be considered. As before, the release of several
other hazardous air pollutants from petroleum refining processes must be considered, and
their environmental impacts evaluated.
Linear Alkylbenzene Sulfonate: LAS is produced by the sulfonation of dodecylbenzene
(commonly referred to as linear alkylbenzene, LAB) with sulfuric acid or sulfur trioxide.
Almost 90 percent of the LAB made is consumed in the manufacturing of LAS. LAB is
produced by the alkylation of benzene with dodecene in the presence of an aluminum chloride
catalyst. Dodecene can be produced by the thermal cracking of wax paraffins to (alpha)-
olefms.57 Figure 15 is a simplified process diagram for the manufacturing process of LAS.58
Dodecylbenzene sulfonic acid and its salts account for the majority of alkylbenzene sulfonates
produced.59
Three companies at six different locations manufacture dodecylbenzene sulfonic acid.
These facilities are presented in Table 34. The releases and transfers reported by these
producers of dodecylbenzene sulfonic acid, presented in Table 35, were retrieved from the
1992 TRI. On-site air releases represent nearly 95 percent of all releases and transfer, on-site
and off-site, from these facilities. Evaluation of the chemicals emitted by these facilities
identified an interesting fact; aromatic chemicals such as toluene or benzene were not among
the chemicals reported. Benzene emissions from these facilities are probably regulated by the
benzene NESHAP, which requires leak detection and repair, and stack emissions to be
captured and destroyed. LAB, which is not required to be reported under TRI, may also be
the raw material used to produce dodecylbenzene-sulfonic acid.
81
-------
o
3
d
',£>
£^i
0
O
OO
CN
^
H
|
CO
<£
CO
CO
OO
cd
c5
fll ^
— ( .-£ <3
•*— ' f^ c/5
E— H <-t-H Cd
*|!
i? 5*H S
O ££ 2
H c
O 2
OH [— i
3 S i
o ' oo m •— i
Tt r~- t-- m
vo ro -— i
^O r*") CN
O O O O
m 'O ^O
rn
O O O O
(N ON —i r<~>
t^~- ^ ON ro
m ro Tf oo
C^l t^— ^^ f^*i
^*O ^O
vo t^ m o
^o NO */~) oo
(N of
»O
•^ m
to"
Id
* ^
I2
§igg3«
> ^ H H ^
^0
^^
vo^
00
1-H
oo"
^
o
oo"
fS|
1-H
i
<*>
Tf
r^
00^
•s
o
^^
^
g
o
H
ON
ON
c
X)
00
(N
oo
d
T3
Ci
cd
CN
ON
ON
2
1
C/3
72
-------
x-v
1)
£2
_g
o
o
m
m
25
H
'E
,0
CO
1— 1
kO co
f— i <4-i 53
0 £
4> ^
W rr^ *+-<
j t/p co
-*-J f | ! C
°o S
H ^
0 2
IS -ti co
^2 OO CO
O ' Jj
T3
§ C ai
° -2 J2
o"b tj o>
T3 'H1 D^
CH ' — '
D
(L)
"^ CO
C
B
T3
O
VH
OH
i— I
ON
O^
^
1—1
ON
r-T
O
oo
00^
of
ON
'~~<
O
»n
o"
oo
o
o
oo
ol
0
oo
ON
o
0
*rt \s
1^
(11 CO*
Texaco Chi
Port Neche
m
ON
t»
®v
04
OO
ON"
of
oo
0
ON
OO
o"
^
0
o
o
oo
!— H
cT
t — .
5
&1
o
-a |— i
U CJ
O ^3
'2 G
D H
^D O O
i^~j
^D
i/~)
O O O
\O O O
i/^)
^o
C4 O4 O
in 04 >n
01
O O O
O 01 O
VO
CN^
, — T
01
0 0 O
r4 »n o
<
U
^
CO
00
• <^ Jx^ ^
o ^ ^ J
r ^ fH r"! CJ
CO O *^
-t-> 1-, 3 "c
•^ CO O cO
C> ffi K c/3
TT
00
Tt^
oo"
ON
''is
0,
00
vo
oo"
oo"
vo
FH
^H
•V
0
00
r-
oo"
•N
^
ON
00^
00
00
TT
00
cT
vo^
oo"
vo
00
cT
TT
VO
TOTAL
(N
ON
ON
iu
I
83
-------
1
cu
«3
-------
TABLE 34. PRODUCERS OF DODECYLBENZENE SULFONIC ACID
Producer
The Greyhound Dial Corp.
Unilever United States, Inc.
Witco Corp.
Location
Chicago, IL
St. Louis, MO
South Gate, CA
Baltimore, MD
Hammond, IN
Blue Island, IL
Source: 1992 Directory of Chemical Producers, United States of America, SRI International
The chemical structure of LAS, the most widely used surfactant, is based upon
benzene. Benzene is predominantly produced from a petrochemical feed stock which is a
distillation product of crude oil. In addition to the emissions during the production of benzene
(presented under nonylphenol ethoxylates), the use of benzene in the production of linear alkyl
benzene, the chemical intermediate in the formation of LAS, can result in further benzene
emissions. In addition to benzene, petroleum refineries also release several other hazardous
air pollutants, as previously discussed. These releases and transfers to the environment must
be evaluated when applying a life-cycle perspective.
Overall TRI Releases and Transfers: Surfactant Manufacturers: Manufacturers of surfactants
report TRI releases and transfers under SICs 2841 (soaps and detergents) and 2843 (surface
active agents). Chemical Products, SIC 2800, is the general category of which these two
manufacturing classes are found. The total emissions from SICs 2841 and 2843 were also
retrieved from TRI 1992. These data are presented in Table 36. As previously mentioned
with the producers of the surfactants discussed above, many of the manufacturing facilities
reported multiple SIC codes in TRI 1992. For this reason, the emissions from these facilities
may not specifically represent surfactant production emissions.
85
-------
TABLE 30. PRODUCERS OF ETHOXYLATED ALCOHOL SURFACTANTS
Producer
BASF Corp.
Croda, Inc.
Harcros Organics
Inc.
Henkel of
America, Inc.
Rhone-Poulenc
Inc.
Shell Oil
Company
Location
Spartanburg, SC
Mill Hall, PA
Kansas City, KS
Mauldin, SC
Baltimore, MD
Winder, GA
Geismar, LA
Reserve, LA
Producer
Stepan Company
Texaco Chemical
Company
Union Carbide
Corp.
Vista Chemical
Company
Witco Corp.
Location
Millsdale, IL
Port Neches, TX
Texas City, TX
Lake Charles, LA
Harahan, LA
Houston, TX
Santa Fe Springs, CA
Source: 1992 Directory of Chemical Producers, I Jniled States of America, SRI International.
The source of alcohol raw materials can either be vegetable oils or a petroleum feed
stock, as presented in Figure 13. Most alcohols derived from vegetable oils are made by first
converting the fatty acid in the triglyceride to its methyl ester by alcoholysis with methanol.
The methyl ester is then hydrogenated to the fatty alcohol and methanol.50 Therefore,
potential chemical releases to the environment can include methanol and methyl ester.
Petroleun-based alcohols may result in the release of several hazardous air pollutants,
including aldehydes, ammonia, benzene benzo(a)pyrene, biphenyl, carbon monoxide, ethyl
benzene, formaldehyde, naphthalene, and xylene. They also add to the volatile organic
compound loading in the lower atmosphere contributing to photochemical smog, are sources
of significant water pollution including oil, phenols, BOD, COD, and ammonia, and generate
significant quantities of solid waste.51
Ethylene oxide is produced from ethylene, which is a distillation product of either
crude oil or natural gas.52 Potential environmental releases of chemicals from this process
include ethylene oxide and releases of benzene, ethylene, and hydrocarbons from the
production of ethylene.
These life-cycle environmental emissions of carcinogenic and/or toxic chemicals are
presented to acknowledge chemical releases and transfers from the production of chemical
intermediates, beyond the TRI reported releases and transfers from ethoxylated alcohol
production facilities shown on Table 31. Estimates of the chemical emissions from various
production sources are published by EPA in "Toxic Air Pollution Emission Factors - A
Compilation for Selected Air Toxic Compounds and Sources." Selected environmental
emissions can be drawn from this document.
76
-------
H H
1
Relea
-t-> ".J c/o
(
g
H c
0 2
OH [—
oo «i
o • o>
I-1 X 1*
O O to
bk '-C to
oi) o
-------
T3"
|
O
O
m
H
-^~^
If*"*!
VJ
C/3
1-
1
cd
13
tti
1) ^
•g £? |2
H j*^ §
H
^
^ •"-* J§
•5 2 d
uo£
^ <+H
^ ^
o g
2 C/} C3
O i JJ
Ho^
•o
1 .§ g
& S —
•^ 'd1 c^
d h~4
D
•^ eg
-<2
U
C/3
UH ^
< -S
S2
0)
1
2
OH
m
ON
£•*»*
Q\
j
^o o o
v^
^o
!^
o o o
VO O O
v£>
i/-,
O) <^1 O
o o o
O n o
r*"i Tf ro
<;
U
00
d
&JH^
r9 c d w
U e3 0 (JH
I1H
^ ffi I t/5
^
8.
o
SO
^J
^
-------
a a
•?H O
0 *
ffi
O
I
8-
a o
o cs
OH ^
89
-------
.1
•so
O
._J
^^
&
o
W
J
O
fc
w
X
PM
O
fc
w
S
w
=
u
CO
O
i a
lo
£
DQ
U
SS
P
fc
Q
H
6
j
&H
CO
TT
•3
o
s
80
-------
H
H
£
c^
K
0-
O
§5
0.
1
{/}
^^
'^^
H
O
^ W3
H H
S3
HH
3 ^J
^^H ^^(
^^ ^^
f& ^
tfa r i
c^ O
* H
e|
05 g
^ Q
5 o
« ?
HQ^
HH
C
fc
"^
s
C/5
U.
H_J
U.
ON
NM
H
06
U
-i
PQ
^*
H
^
iz
s^-^
C/l
<|
C
1_
-o
C3
CO
(U
CO
C3
JJ
Cci
CO
(U U,
— r ."ti ,QJ
-2 co oo
O f i i C
[— > ^-H cd
jU
g|
u ^
ii D
"is •"• ^
j_J J/5 C3
O i
o 2 ^
GO O 0>
UM QJ ^"^
O • ^^ ^
"O C Qci
D "
CD
-O ^
CO _
&
i_ ^
ta ^
^
<
B-Z u
o +.T _-
U g ^
O u >
2 C3
-------
fc
o
MM
H
P
Q
O
B
u
^«
u
NM
J^
O
to
p
^0
£J
fc
U
N
fc
U
03
J>H
u
WC/3
f^,"^
C5 iZd
O H
MM .1
S Ej
O <<
5] ^^
OS
u
to
t/3
5
ON
H
G
c«
to
c«
•<
to
MM
H
.
IT)
PO
to
MM
03
2
x-s
^^
f^
1/5
D
CO
C
2
H
"O
c
CO
1)
co
Q^
"TT
oi
CO
jj *"!
"*3 c/5 C*-'
o c^i, e
L_H C^H C3
° H
... t/1
U/ (•«
•£ ^ 1i
°0^
>-». S
^ 'to
H c
O 2
2^ U*
0. H
fl» CO
_ H w
O i 1>
H .£ (u
^ 0^
T3
i c u
o .2 °2
tob o _u
a3 eS
"S £
^ (U
(U
CO
<1
u.
(U
O
3
T3
2
C±
in o o
o o o
in O O
O O O
c/T cS
.2 Sj'50
Q co o j=
o> •- ^ ^
f— U t/5 oo
0 0
O 00
in rf
*-*
O O
0 0
O 00
m Tf
^^
NO m
m m
O O
o o
0 0
NO in
•n m
01 r-
6
U
eiz
-C *^
Lever Broti
Baltimore,
Hammond,
o
0
o
4
(N
r*
oo
m
O
o
o
(N
oo"
d
H"
O •— '
O u
•^ 3
^ 5
IT)
00
ON^
^M"
O
IT)
00
ON^
T*H
fS
00
^r^
o
Tf
O
o
«s
o
PO
00^
oT
PO
| TOTAL
t:
o
ex
3
O
cn
86
-------
Ethylenediaminetetraacetic Acid: EDTA is a chelating agent made by reacting
ethylenediamine with chloroacetic acid. Ethylenediamine is produced along with other mixed
amines from ethylene dichloride and ammonia. Ethylene dichloride used in the EDTA
manufacturing process is produced by the chlorination of ethylene. Chloroacetic acid is
produced by the chlorination of glacial acetic acid in the presence of a sulfur or red
phosphorus catalyst. More than 90 percent of the acetic acid used in this process is derived
from either the direct liquid-phase oxidation of butane or the oxidation of acetaldehyde.
Acetaldehyde, typically used in the same plant in which it is produced, is produced by the
direct oxidation of ethylene.62 A simplified schematic of this process is presented in Figure
17.63 The three producers of EDTA are listed in Table 41.
TABLE 41. PRODUCERS OF ETHYLENEDIAMINETETRAACETIC ACID
Producer
Ciba-Geigy Corp.
Dow Chemical U.S. A.
W.R. Grace and Company
Location
Mclntosh, AL
Freeport, TX
Nashua, NH
Source: 1992 Directory of Chemical Producers, United States of America, SRI International
The TRI releases and transfers from these production facilities were obtained for
reporting year 1992. These emissions are presented in Table 42. On-site releases to air and
'other1 off-site transfers represent 99 percent of all emissions from these production facilities.
Air releases at 9,740,907 Ib/yr contributed 97.6 percent of all on-site releases. With no
reported releases to POTWs, other off-site transfers represented 100 percent of off-site
emissions. As with the other production facilities identified above, multiple products are
produced by these facilities, and TRI reporting is done under multiple SIC. Therefore,
directly attributing a fraction of these emissions to the use of chelators and builders in
industrial detergents is not possible.
Nitrilotriacetic Acid: Two processes, the alkaline process and the acid process, are currently
used to manufacture NTA. In the alkaline process, aqueous sodium cyanide solution is fed
into a reactor system along with a formaldehyde solution to produce NTA. Ammonia is
liberated during the synthesis, one-third of which is consumed in the chain of reactions. The
remaining ammonia produced must be removed from the reactor to suppress side reactions.
By-products of the reaction include glycolic acid, hexamethylenetetramine, and amino acid.64
93
-------
C/5
—
H
U
u.
t
O
^
Q
O
Pd
Cu
X
co
o
CU
^
-J
O
0.
2
H
£
D
S
0
en
O
u.
en
Of!
r_
wt.
f-,
^
H
en
U
en
S
j-p
H
TABLE 40.
-p
^^
||^^
^^
c/a
<£>
C/5
TO
I-H
H
T3
oo
C/3
c3
o£
0) ^
C"3 I-X-J ^H
"S i ^
L-H ^H C^
°^
H o §
T3
C
o o "
V— i ' |^ TO
^ ^ -^
T3 C1 Q^
D ^
0
11
*
*— So
^j K3
^ "S
CAl
O
\o in
•""I
d
o t-- o
1 — ;_
r^i
o o o
in r\i r«~i
ON ' — i oc
in Tt CN
^^ ^
d
0
g
3 -J
o ^
CX o"
ON
00
p:
Tt
^
f-J^
1^.^
vo
^^
r5
TT^
5
vo
i/^
t^-
tt
O
o
in
00
o
rf
m
•v
00
1 TOTAL
(N
ON
ON
92
-------
HH
U
•^
u
H
U
s
H
H
W
NH
s
•^
s
w ft
J S
>" H
£3
H d
w u
n *
A> 5^
to O
Sg
go
«< c*
5 ^
H
Q
J2^
^j
on
W
C/2
U
-J
U
K
2
H
W
j
CO
H
'P
<'
Z2/
t/2
C/J
c
u-
H
C
1/5
(D
C/5
C3
(U
13
»i
C/3
— .-§ 53
-2 oo Hn
O ti g
Ho^
l_ ,-y ^0)
•§ 2 I
o g §
^ *i
2 ^
Q- [—
to
13 -"^ "
"^ c -^
T3
3 S u
O O C/3
i— I ',^ C^
bi) o ^
i) .i-, i>
|5«
"^ (S
^ s
!_^ "^
S 8
^ iV
CO
> . c3
• S (U
< 13
U
^
f
M
(X
m
•o
i~~.
o"
r--
rN
-'
^
o"
oo'~
{^
S1
t
o
o
-------
94
-------
^^
e
p
Q
O
C*
Cu
J
<
U
NM
S
W
K
U
U
y
[±
O
z
NM
-J
^
S
H
V3
P
Q
Z
s
§
tu
u
U.
H
O
Z
on
U
C/5
ON
(N
O
OH
H
C
T3
o.l
O
IT)
ON
OO
ON
(N
H
Q)
p
Q
VD
00
H
O
H
Tf
rf
-J
CO
Csl
m'
00
o
2
H
g
a:
97
-------
The acid process used to manufacture NTA was originally designed to avoid the by-
products produced in the alkaline process. The two-stage acid process begins by reacting
formaldehyde with ammonia to give hexamethylenetetramine. This product is then reacted
with hydrogen cyanide, another 33/50 chemical, in a sulfuric acid solution to yield
tncyanomethylamine, which is a solid prec.pitate. This solid removed from the reactor chain
18 ' S° hydroxide to Pr°duce Na3NTA. Acidification to a pH of 1 to 2 '
B
ur- 3. a p o
yields NTA. Both processes, alkaline and acid, are associated with stringent safety
requirements due the use of hydrogen cyanide." W.R. Grace and Company, in Nashua NH
was the only producer of NTA in 199, « The .992 TRI reported releases and transfer from
this facility are presented in Table 43.
TABLE 43. TRI RELEASES AND TRANSFERS FROM THE PRODUCTION OF
NTA - W.R. GRACE AND COMPANY
Release or Transfer
Water Releases
Underground Injection Releases
Total On-Site Releases
Other Off-Site Transfers
Total Off-Site Transfers
Overall TRI Releases and Transfers Builders and rhplatn
The producers of
pro
builders and chelators report TRI emissions under the SIC 2819, industrial inorganic
chemicals. Though multiple SICs are reported by these facilities, the releases and transfers
from the entire industrial class were retrieved, and the data are presented in Table 44
96
-------
TABLE 45. NATIONAL BASELINE AIR RELEASES
db/yr)
Type of Degreaser
Batch, Vapor
small (4.3 ft2)
medium (8.6 ft2)
large (16. 1ft2)
very large (37.7 ft2)
In-line, Vapor
Batch, Cold
TOTAL
DCM
485,020
1,146,400
1,785,740
3,328,980
10,075,130
2,358,950
19,180,220
PCE
1,212,540
2,843,960
4,409,250
8,223,240
7,054,790
_
23,743,780
TCA
7,716,180
18,188,140
28,241,220
52,602,300
52,381,830
-
159,129,670
TCE
4,232,880
9,986,940
15,520,540
28,902,600
22,773,750
-
81,416,710
Source: NESHAP
Note: Total estimated chlorinated solvent air releases equals 283,470,370 Ib/yr.
Five major industry groups use chlorinated solvents in degreasing operations. These
groups are furniture and fixtures (SIC 25), fabricated metal products (SIC 34), electric and
electronic equipment (SIC 36), transportation equipment (SIC 37, which includes CMC), and
miscellaneous manufacturing industries (SIC 39).69 The chlorinated solvent releases and
transfers to the environment from these facilities are presented in Table 46. These releases
and transfers of chlorinated solvents can not be directly attributed to their use in degreasing,
since the reporting facilities could use the solvents in other applications.
99
-------
en
0.
O
H
5?
O
fc
en
W
O
en
O
z
en
ON
O
Q
£ en
ii
id
o w
K
U
u.
o
w
u.
en
Z
H
Q
5
en
en
£j
H
Tf
u
-J
CO
<
H
^
*
H c
o g
OH E-H
— i -22 <8
•«— > CO O3
O ' — i i— < ^
>n o ON \o o
\O oo C — ro ^O
t^ ON ^f r^
-H — 1 TJ-
o o o o o
ON ON
ON ON
OO O Tf O CJ
CN O m ^ o
""IN °i ^r, ^.v °X
ON — H (~s) T^- t~-
m TT
o o o o o
o o o o o
o o
OO^ 00
•/") ID
o o o o o
00 O Tt O »N
fN o m Tt o
r, V « ^,, *"!
ON ^ n co O
1-H
•— < NO >— i ^ r^i
•^t CN O ON NO
n "— i \o ^o
Tf
00 fs) ON O ON
' — ' (N ' — i »O ©
lO NO CN ^^ 00
ON «n NO ON ©
NO NO *sD VD 1?)
r^ r*") ON ON NO
r— ! ff)
O O O O ©
O O OO O 00
ON t-- O NO
*n t~~- in oo
m ON rs) m
f~j T^-
NO o -rf (N n
*— H ^.Q psj f^i
^H NO 00
n (N M
1-H
NO c^ ON in r-~
•— ' ON o ^ NO
•— i ON ON oo o\
rs| oo CN o Tf
ON NO oo »n ON
f-H fsl in (N «S
^
oo ON O ON NO
NO O t-^ t~^ fS
(N m oo^ ^
t^ oo o r^- r^
t^*" ^ t*^ (N) C^
co >n co */~i oo
O ON •rj- ON fj
-------
^rT
a
c
^
|g|
^ MH
o!
CU H
^rt -tn Crt
5 OO 03
Ho«2
T3
§ £
VH ' r^ c3
OO o ~H
NO O
NO O OO ON ^
•-H rf oo «n ON
OO O CO "— ' fi
i^i r-^ ^^ ^N r^
^^ m m NO r^
CN <^i
S pq < w ^
£ u u u u p
So H
^H ^, r-H m JOG
»n «— i CN CN O
ON *n OO CN VI
CN ^ OO CN «/^
^H _H ^H m oo
in •"* ON t*^ f^l
ON in ^1" ON ON
oo ^ in o ON
NO in NO c*** if)
CN — 00 CN »/^
o o o o o
o ro in oo
r— I 1-H
in o CN \o f>
O oo co oo O
o t~- in o Tf
OO OO CO CO O
<— ' in NO Tf
rj ro NO
o o o o o
0 0 O O O
o o
ON ON
O vo •— i in
-------
On-site emissions to air of the chlorinated degreasing solvents represent the majority
of releases and transfers, just over 74 percent, for the industry sectors shown in Table 46
The NESHAP baseline air emissions and the industry sector air emissions are compared in
Table 47. As shown by this comparison, the baseline emissions of the NESHAP seem to
underestimate the potential air releases for DCM as a degreasing solvent as compared to the
other chlorinated solvents. The 1992 TRI data represents 76.2 percent of the estimated
baseline emissions, while TRI data represents 38.7, 39.9, and 26.7 percent of PCE TCA and
1 Ch baseline estimates, respectively.
TABLE 47. COMPARISON OF 1992 TRI EMISSIONS AND NESHAP BASELINE
EMISSION ESTIMATIONS
Chemical
DCM
PCE
•^•i^^H^^Hi
TCA
TCE
TOTAL
1992 TRI Data3
(Ib/yrJ
14,617,716
9,194,298
^•••^"^^"^^•^—^••••^
63,454,599
^™^^"^^™^^—«•»—«^»B
21,713,540
^•'^^•^•^••^•^••H
108,980,153
NESHAP Baseline
(lb/vr]
19,180,220
23,743,780
159,129,670
81,416,710
Releases and transfers represent TRI reported atr releases for each chemical from Tables 45 and 46.
Transfers to off-site treatment and disposal facilities from the industrial sectors
presented m Table 46 represent nearly 26 percent of all emissions. Though not comparable to
the present distribution of CMC releases and transfers, these percentages are consistent with
CMC historic data for the years 1988 through 1990. Therefore, the direct extrapolation of
CMC s experience to represent the national environmental impacts of solvent degreasing
applications, and alternative processes, is appropriate.
Transfers to POTWs, contributing less than one-tenth of one percent, correspond to
I on^Sf u° ^C'S environmental valuation. The national releases of chlorinated solvents
to POTW, though small in relation to other releases and transfers, may create adverse
™r?tal impaCtS- Th°Ugh the chlorinated solvents are readily vaporized into the air at
POTWs, they are not readily biodegradable. Their release to POTWs is restricted by federal
regulations due to their toxicity to POTW operations and receiving waters Therefore the
chlorinated solvent discharges presented in Table 46 may contribute to POTW treatment
problems and receiving water contamination.
, f n °ther inrdustry SrouPs identified by the EPA which use degreasing processes include
the following: food and kindred products (SIC 20), primary metals (SIC 33), nonelectrical
machinery (SIC 35), instruments and clocks (SIC 38), and plastics (SIC 30)70'71 Total
releases and transfers from these industry sectors of chlorinated degreasing solvents are
102
-------
presented in Table 48 Again, these releases and transfers of chlorinated solvents can not be
directly attributed to their use in degreasing, since the reporting facilities could use the
solvents in other applications. For example, the plastics industry (SIC 30) uses DCM in the
extraction of certain polymers.
Use and Disposal of Detergents in Metal and Parts Cleaning Applications
As an alternative to chlorinated solvent degreasing, aqueous wash systems, if
implemented by entire industry sectors, have the potential to eliminate the releases and
transfers which occur during the use and disposal of the solvents. The potentially problematic
solvent transfers to POTWs would also be eliminated. However, while eliminating these
chlorinated solvent emissions, the aqueous wash alternative would result in the generation of
additional waste streams unique to this process.
The aqueous wash system of CMC, while replacing five solvent degreasers and
eliminating their associated solvent emissions, generated an average of 8,400 gallons of
wastewater per day. This aqueous wash system consumed approximately 2,640 gal/yr of
detergent. This new waste stream must be properly managed. When an individual industry
implements an aqueous wash system such as this, regulatory and permit compliance are
important management issues. These issues include prohibited discharges and categorical
standards under national pretreatment standards (40 CFR, Part 403.5), as well as state/local
restrictions. When entire industrial sectors implement aqueous wash systems, the issues, as a
whole, shift from individual industry compliance issues, to national issues of POTW
capabilities and the potential impacts such sector-wide changes would have on the POTW
infrastructure and the environment.
As presented in the Environmental Evaluation of Chapter 5, the additional wastewater
flow rate of 8,400 gal/d from the aqueous wash system did not impact CMC's pretreatment
facility. Changes within other manufacturing process lines, to reduce water consumption and
wastewater generation, more than compensated for this increase. However, the treatment
scheme of CMC is primarily designed to remove metals and suspended solids from the
wastewater; biological treatment of organics is not possible by this system. For this reason,
treatment considerations concerning Shelbyville's POTW must be addressed. These concerns
will be similar for other facilities implementing aqueous wash alternatives, and include the
following:
a the additional wastewater flow rate to the POTW and the POTW's existing
capacity; and
n regulated discharges to the POTW, and the POTW's capabilities of treating
these discharges.
103
-------
C/3
i
o
o
g
c/5
a
K
O
W
Q
w
H
CHLORINA
Y SECTORS
s *
O H
NSFERS
R INDUS
^ W
K a
H H
0 0
!o
H 0^
W
3
K
2
H
J
o o oo
00^ 10 ^ 00
•^t t--" r-T
^
O •— i n
o oo" Tt" Tt"
^ OO O ON
o NO m oo
v~> <-H rn »/-)
"•^ •"" ' t"~ ON
*/~) t — • ON f^
O OvJ t — • fN
co co cxf irT
CO fNj
»— i i— i OO ^O
'— ' CO CN X>
oo^ oo ON >n
*n ro" »n »n"
•^ CN O ON
CN^ O Tj- -H
CsT CN" NO" rj-"
co in CN o
t-- CN r~-
°\ *""• ^
ON ON
OO r-H
S m << w
6 |S k! £ £
j^«
oc
«^>
^
»
fS
IT)
"I
rf
°X
i/i
00
ON
•v
Tf
|^J
I^J
i
S
o
•^
00
1-H
Q
5
^^ ^^
CO C6
„ «3 fe
d < a
5S!
H S H
22
o3
^
0
,c3
g
6
O
00
"a,
C
-------
These issues are addressed in the following sections. Using the knowledge of CMC's process
changes and waste streams, the impact of replacing existing solvent degreasers with aqueous
wash systems are estimated. CMC information are used as an example to identify and
evaluate potential national environmental impacts.
Shelbyville POTW Capacity. The design capacity of Shelbyville's POTW is 4.9 million
gallons per day (hereafter referred to as mgd) with an average flow rate of 3 mgd.72 The
treatment facility employs eight people, two of whom are part-time. The receiving waters for
the discharge from the POTW is the Duck River which has an average flow rate of 2,000
mgd.73 Shelbyville's POTW treatment train includes bar racks to screen out large solids, a
primary settling tank to remove gravel, sand, and similar materials, activated sludge for
biological treatment, final clarifiers, and chlorine contact chambers for disinfection. Solids
handling operations include an aerobic solids digester and sand-lined drying beds.
Over the past 20 years the flow rate to this treatment facility has tripled. To
accommodate for this increase, the POTW has been expanded twice. Expansions included the
following: doubling aeration basin and clarifier capacities; adding a grit chamber, the aerobic
digester, and the sand-lined drying beds; and expanding the chlorine contact basins.
Information from the South Central Development District and the State Department of
Economic and Community Development show that the population of Shelbyville has not
tripled in the last 20 years, and the industrial wastewater component to the POTW may
constitute the majority of the increase identified by the POTW. Data available indicates that
population growth averaged nearly one percent (1 percent) per year for the last 25 years,
while industrial growth was over three percent (3 percent) per year. This reported population
growth rate would not represent an increase in domestic wastewater equalling nearly 20,000
gal/d.
This discussion represents one company's potential impact on a single POTW. If
entire industry sectors were to implement aqueous wash systems to replace solvent degreasing
operations, the carrying capacity of the nation's POTW infrastructure must be evaluated, and
the potential impacts identified and, if possible, quantified. The following is an evaluation of
the nation's POTW capacity, treatment capabilities, and treatability of the potential aqueous
wash wastewater.
National POTW Capacity. The "1992 Needs Survey Report to Congress" completed by the
EPA states that there were 15,613 operational treatment facilities within the U.S. in 1992.74
The total flow rate of these facilities was established at 29,490 mgd, with a total design
capacity of 39,380 mgd. When the range of flow rates for individual treatment facilities is
analyzed, as presented in Table 49, the majority of facilities (more than 80 percent) have an
average flow rate of 1 mgd or less. Once the documented needs are met (by year 2012),
18,966 operating treatment facilities within the U.S. are expected. The design capacity of
these facilities will be 45,542 mgd, a 15.6 percent increase from the 39,380 mgd 1992
treatment capacity. The new distribution of design flow ranges are also presented in Table 49;
nearly 77 percent of the treatment facilities still have flow rates of 1 mgd or less.
105
-------
—^—^————————_____________
TABLE 49. CAPACITY OF NATION'S TREATMENT FACILITIES
^
Existing POTWs
0.00 to 0.10
0.11 to 1.00
1.01 to 10.00
> 10.00
Other
^^mt^^^^m
TOTAL
Number of
Facilities
Source: 1992 Needs Survey Report to Congress
(mgd)
10
00
.00
)
]
15,613
This dominance of small facilities may represent a problem with treatment capacity if
entire industrial sectors were to implement aqueous wash systems as an alternative to solvent
degreasmg. Using CMC's aqueous wash system as an example of a typical system discharging
to a small POTW, an additional wastewater flow rate of 8,400 gal/d would represent nearly
one percent of the POTW treatment capacity. With the smaller POTWs, such a wastewater
flow increase from several industrial facilities could potentially exceed the POTWs treatment
capacity resulting in inadequate treatment prior to discharge. Occurrences of inadequately
treated discharges to surface waters could result in human health concerns and adverse
environmental impacts. The presence of fecal coliform and other bacteria could cause
increased health problems among persons who come in contact with this inadequately treated
wastewater. The composition of a waste stream which represents one percent of the total
wastewater flow could also cause adverse consequences even if the POTW is able to
accommodate the increased flow. These consequences include treatment capabilities which
are discussed in the following section.
POTW Treatment Capabilities. The "1992 Needs Survey Report to Congress " also
presents the treatment capabilities of the 15,613 national facilities. These capabilities are
presented in Table 50. This table also presents the level of treatment accomplished by the
treatment infrastructure expected by 2012 if the documented needs are met. Note the
significant change in the projected level of treatment from 1992 to 2012. Currently 82 percent
of the existing facilities accomplish secondary treatment or greater If the needs by the
surveyed facilities are met, by 2012 'secondary1, and 'greater than secondary' treatment levels
will increase 14.6 percent, and 61.2 percent, respectively. 'Less than secondary' treatment
levels will decrease more than 92 percent.
106
-------
TABLE 50. LEVEL OF TREATMENT FOR THE NATION'S TREATMENT
FACILITIES
Level of Treatment
Less Than Secondary
Secondary
Greater Than Secondary
No Discharge
Other3
TOTAL
Existing POTWs
Number of
Facilities
868
9,086
3,678
1,981
0
15,613
Design
Capacity
(mgd)
3,724
17,928
16,408
1,320
0
39,380
Expected by 20 12
Number of
Facilities
68
10,410
5,929
2,491
68
18,966
Design
Capacity
(mgd)
390
19,086
24,210
1,825
31
45,542
a Level of treatment data were unavailable for these facilities.
Source: 1992 Needs Survey Report to Congress
As federal and state treatment requirements continue to increase, the level of treatment
for these facilities must also increase. EPA's estimates (1988, 1990, and 1992) of the
investment necessary to address the nation's municipal wastewater treatment needs are
presented in Table 51. The dollars needed to meet the national needs are estimated at $111.9
billion; treatment needs alone represent $41.8 billion. The total monetary needs increased
$28.2 billion from $83.7 billion in the 1990 Needs Survey. In general, these increases are
caused by one or more of the following five factors: 1) continued population growth and
redistribution; 2) deterioration of older sewers and facilities; 3) more stringent standards to
protect water quality; 4) newly eligible activities identified in the survey and funding sources;
and 5) use of different methodologies for reporting 1990 needs.
Advanced treatment needs grew by $10 billion between 1988 and 1992. This increase
has occurred primarily because the installation of secondary treatment controls has proved to
be insufficient in many cities to meet water quality standards. It is likely that this category of
needs will continue to grow in the future as more states address the new water quality
standards. The increases in secondary treatment and new collector sewers are attributable to
population growth and population redistribution since 1990. Figure 18 presents a
geographical distribution of the total documented needs.75 Needs are generally concentrated
in the highly populated northern and Sunbelt states, a generality that applied to past needs
surveys. The less populated states have lower levels of documented needs.
107
-------
TABLE 51. SUMMARY OF DOCUMENTED NEEDS
FOR YEARS 1988, 1990, AND 1992
(January 1992 dollars in billions)
Needs Category
Secondary Treatment
Advanced Treatment
Infiltration/Inflow Correction
Replacement/Rehabilitation
New Collector Sewers
New Interceptor Sewers
Combined Sewer Overflows
Storm Water
Nonpoint Source
Ground Water, Estuaries,
Wetlands
Total Need
1988 Survey
29.1
5.5
3.1
4.0
14.9
16.2
17.7
_
_
-
90.5
1990 Survey
25 9
4.9
2.9
3.7
14.4
14.7
17.2
—
.
-
83 7
1992 Survey
31.3
15.5
2.8
3 6
17.9
14.7
22 4
1.8
07
1.2
111.9
Notes: 1
2
Costs for operation and maintenance are not included in figures.
The 1990 estimates were derived using a methodology different from that used in 1988 and 1992.
EPA simply adjusted the 1988 needs estimates for grant and loan awards and inflation.
Source: 1992 Need Survey Report to Congress
108
-------
CQ
9
o
V
00
O
109
-------
Effects of Detergent Components on Receiving Waters. The introduction of detergent
components into the environment, as part of the manufacturing process or after the use of
detergents, is regulated by the Clean Water Act, the Clean Air Act, and the Resource
Conservation and Recovery Act. Two areas of specific relevance to surfactants, builders and
chelators are biodegradability and eutrophication. Though these issues first accompanied
laundry detergents in the late 1940s (biodegradability) and 1960s (eutrophication), they must
be addressed as detergent use grows beyond the traditional consumer market.
In early 1947, foam blankets on bodies of water were attributed to synthetic
surfactants. These surfactants were less readily degraded than soap, which they replaced, by
naturally occurring microorganisms. Studies used to confirm these facts concluded that the
branched hydrophobic portion of a surfactant impedes the rate and extent of degradation by
microorganisms. The most immediately apparent remedy was to replace the branched
hydrophobe with a more degradable hydrophobe. Alkylbenzene sulfonate (ABS), the
predominant surfactant in the 1940s and 50s, was replaced by linear alkanebenzene sulfonate
(LAS). LAS replaced the tetramer alkyl group of ABS with a straight-chain hydrocarbon.
The degradability of LAS, as well as other alternative surfactants (e.g., alcohol ethoxylates
and alkylphenol ethoxylates), has been studied intensively under sewage-plant operation
conditions. Results show that these surfactants readily degrade to carbon dioxide and water.76
Eutrophication is a natural aging process of lakes and reservoirs. These waters
become organically enriched, leading to the increased domination by aquatic weeds, the
transformation of open waters to marshlands, and eventually to dry land. This natural aging
process can be accelerated, however, by human input of nutrients. Phosphorous is typically
the limiting nutrient in lakes and reservoirs, although the presence of nitrogen is also
important. Detergent constituents containing phosphorous or nitrogen can impact the
receiving waters causing excessive algal growth, which in turn contributes to oxygen
depletion. Oxygen depletion can be detrimental to marine life, and eutrophication can
eventually lead to the death of the body of water.
Detergent phosphates (builders and chelators) which reached receiving waters were
singled out as the cause of incidents of eutrophication in the U.S. and Europe in the 1960s.
For this reason, the concentration of phosphates in consumer laundry formulations has been
restricted by many states and local jurisdictions. Though specifically designated for consumer
laundry detergents, these restrictions may effect the use of detergents in industrial
applications, particularly if large industrial sectors convert cleaning processes to aqueous
cleaning. Phosphate substitutes applicable in industrial applications include sodium
compounds such as NT A.
An advantage of the hot water wash system of the converter manufacturing line is
apparent in the context of the above discussion of biodegradability and eutrophication. By
eliminating the use of all chemical additives in this system, the hot water wash application
eliminates eutrophication problems associated with detergent formulations. The oils and soils
remaining in the wastewater from the hot water wash system represent potential
treatability/biodegradability problems; their elimination from the wastewater, however is
simplified with the absence of detergent. The oils, without the emulsification action of a
detergent, float to the waters surface and can be skimmed off. This skimming greatly
decreases the quantity of fats, oils and greases (FOG) leaving the process for treatment.
Furthermore, ultrafiltration equipment can be utilized to create a closed loop system - all soils
can be removed by the filtration process and the process water can be indefinitely reused.
110
-------
Though ultrafiltration and closed loop systems are possible in all aqueous systems (e.g., with
or without detergents), a hot water wash system simplifies the process.
Treatability of Detergent Components. In addition to the issues of surfactant
degradability, eutrophication, and toxicity, regulated discharges to POTWs include prohibited
discharges and categorical standards included in the National Pretreatment Standards of 40
CFR § 403.5 and 403.6. The following are two of eight prohibited discharges which may
apply to parts cleaning:
1. "any pollutant, including oxygen demanding pollutants (BOD, etc.) released in
a discharge at a flow rate and/or concentration which will cause interference
with the POTW;"
2. "petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin
in amounts that will cause interference or pass through."
Accompanying these federally regulated industrial discharges, POTW discharges have become
subjects of federal and local standards, leading POTWs to exert even tighter controls upon
industrial generators. The applicable prohibited discharges presented above are discussed in
more detail below, with a focus on CMC-specific examples.
The constituents of CMC's detergent solution include tetrapotassium pyrophosphate
and an ethoxylated secondary alcohol. Tetrapotassium pyrophosphate is the builder of the
detergent. A builder normally represents the largest additive of detergents and augments the
cleaning ability of the detergent's surfactant by removing hardness ions from the wash
solution.77'78 The discharge of cleaning solutions containing phosphates such as this are
subject to regulation.79 These regulations are intended to control eutrophication of the
POTWs receiving waters; eutrophication, the uncontrolled overgrowth of plant matter may be
caused by the insufficient removal of nutrients (e.g., phosphorous) by the POTWs1 treatment
train. The ethoxylated secondary alcohol is the surfactant of the detergent and gives the
detergent its cleaning capabilities. Though most surfactants are easily biodegraded by the
standard treatment methods of POTWs, the oxygen demand of these constituents must be
considered.
POTW wastewater treatment predominantly relies upon the biodegradation of organic
contaminants to achieve adequate levels of treatment (secondary and greater than secondary
treatment levels). This biological decomposition is an aerobic process; one which requires
oxygen. An increase in the biological oxygen demand of wastewaters entering a POTW may
disrupt the oxygen level in the treatment process. This disruption may cause a decreased level
of treatment, and, in turn, result in contaminants reaching receiving waters and advertently
impacting the environment.
The significant increase in effluent BOD accompanying CMC's aqueous wash system
represents such a potential wastewater disruption. To maintain adequate POTW treatment
levels the transfer of oxygen to the wastewater must be increased as the BOD increases.
Many POTWs may have the treatment capabilities to maintain oxygen levels in the
wastewater. For those POTWs, however, that do not have the capabilities, the transfer of
oxygen can be increased by the following methods: increase the oxygen transfer efficiency by
increasing the mixing characteristics of the treatment vessel; install additional aerators or
mixtures which circulate greater quantities of oxygen; or cover the treatment vessel and
111
-------
transfer pure oxygen to the wastewater rather than the oxygen present in ambient air. Each of
these methods require increasing capital investments, investments that may exceed the EPA
estimates of Table 51.
The lubricating and hydraulic oils used by CMC fall within the petroleum oil class of
chemicals addressed in the second prohibited discharge listed above. These constituents,
often referred to as FOG (i.e. fats, oils, and greases) either float on the surface of the
wastewater, or are suspended in the wastewater as an emulsion or on particulates. FOG, both
floating and suspended, interferes with the POTW's biological action and cause maintenance
problems. Fats are among the more stable of organic compounds, and are not easily
decomposed by bacteria; pipes and moving parts of the POTW treatment train may also be
clogged with FOG.80 FOG are included in "prohibited discharge standards" for this reason;
limits are traditionally specified in the discharge permits for industry, limits that may be
exceeded when an aqueous system is implemented and the discharge is not pretreated. A
metals tooling facility in W. Lafayette, Indiana, which changed their solvent degreasing
operations to aqueous cleaning, encountered such permit violations. Without an existing
pretreatment facility, this company had to install FOG removal units to treat the aqueous
wastewater before discharging to the sewer and POTW.
The hot water wash system of the converter line possesses another advantage over
aqueous wash (detergent) applications. Though the hot water wash system removes oils and
greases from materials and parts, these impurities are easily separated from the aqueous phase
by simple separation equipment (e.g., weirs, filtration processes, skimmers). The absence of a
detergent simplifies the oil/water separation process by eliminating the oil emulsification
properties characteristic of detergents. The simple separation of the oils from water minimizes
potential FOG problems. Furthermore, if the separation process is of an adequate level, a
closed-loop system may be possible. A closed-loop system is one in which the impurities are
periodically removed while the water remains circulating in the unit. This system would result
in zero water discharges to the sewer, a concentrated oily waste that would be disposed of
off-site (e.g., fuel blended, recycled, landfilled), and make-up water added to the water
reservoir to accommodate evaporative losses. Such as system eliminates not only the
biodegradation, eutrophication, toxicity, and regulated discharge issues presented above, it
greatly reduces the use of water and its associated costs.
SUMMARY OF NATIONAL ENVIRONMENTAL IMPACT EVALUATIONS
If entire industrial sectors change to aqueous systems similar to CMC's, the life-cycle
national environmental releases and transfers would change significantly. While reducing the
production, use and disposal releases and transfers of chlorinated degreasing solvents, such
process alternatives produce other life-cycle releases and transfers that must be considered.
As presented above, air releases of the chlorinated degreasing solvents dominate
environmental emissions throughout their life-cycles. This is in contrast to the predominant
off-site transfers presented for detergent ingredient production and use.
The evaluation of the life-cycle releases and transfers of the chlorinated degreasing
solvent indicates that the use and disposal of these chemicals represent the vast majority of
environmental emissions associated with solvent degreasing processes. As presented in the
"Production of Chlorinated Solvents" section, an estimated 460,000 Ib/yr of chlorinated
112
-------
solvents were emitted from production facilities in 1992 that may be attributed to the use of
these chemicals in degreasing applications. The use of chlorinated degreasing solvents from
1992 figures was estimated to be nearly 500 million Ib/yr. This use resulted in significant air
releases and hazardous waste transfers. EPA established an air emission baseline of 283.5
million Ib/yr of chlorinated degreasing solvents emitted from degreasing applications. The
five major industrial sectors which use solvent degreasers reported 147,144,099 Ib of
chlorinated solvent released or transferred in 1992.
These releases and transfers of chlorinated degreasing solvents were then contrasted to
the releases and transfers associated with the life-cycle stages of detergent production and use.
Information establishing the fraction of surfactants, chelators and builders used in industrial
parts cleaning applications was not available. Therefore, directly comparing life-cycle
emissions of the two alternative systems is not possible. Crude, order-of-magnitude estimates,
however, can be drawn from the information of CMC's aqueous wash system. Relative
chemical use rates between chlorinated solvents and detergents can then be established.
The aqueous wash system of CMC consumes 2,640 gallon of detergent per year. To
clean identical parts at a comparable rate, TCA consumption by CMC was 170,000 Ib/yr.
Assuming CMC's aqueous wash system is representative of most aqueous wash systems, a
simple comparison of these chemical consumption rates suggests that the life-cycle chemical
emissions from aqueous wash systems are considerably less than those from solvent
degreasing systems. The total TRI releases and transfers from the manufacturers of chosen
detergent ingredients were significantly less than the releases from solvent producers, further
supporting the conclusion that aqueous wash chemical emissions from production and use
processes are less when compared to degreasing solvents.
However, the quantity of chemicals used (or released) by the aqueous wash systems is
only part of the national environmental impacts that must be evaluated. The impact on the
nation's POTW infrastructure is also an issue. This issue was also evaluated above. From the
EPA's "Survey of Needs" publication, the capacity and treatment capabilities within the
nation's POTW infrastructure can be considered adequate to accommodate entire industrial
sectors replacing solvent degreasing systems with aqueous wash systems and the resulting
water waste streams.
The relative toxicity and risk to the environment and human health were evaluated in
Chapter 5, Environmental Evaluation. In general, if the various waste streams are managed
according to current regulatory requirements, direct exposure to toxic air releases of TCA
dominate human exposure potentials. Proper management of waste residuals (hazardous and
nonhazardous) and the treatment of wastewaters from aqueous wash systems, represent
limited risk to humans and the environment.
113
-------
CHAPTER 8
CONCLUSIONS
In 1989 the management of Calsonic Manufacturing Corporation of Shelbyville,
Tennessee established a goal to eliminate 1,1,1-trichloroethane from all cleaning processes by
1995. This goal was achieved by November 1994 with the implementation of a variety of
parts cleaning alternatives. Two process changes which contributed to the accomplishment of
this goal were the replacement of solvent degreasers with an aqueous wash system (detergent)
on a radiator manufacturing line and a hot water wash system on a converter manufacturing
line. A third alternative was the application of an evaporative lubricant that does not require
cleaning for subsequent processing, therefore eliminating the need for solvent cleaning. These
three specific process alternatives were the focus of this research.
The technical, environmental, and economic evaluations performed in this study were
completed using CMC's historic records, information obtained from site visits and interviews
with CMC employees, the on-line TRI data base, and literature searches. The radiator and
condenser manufacturing lines were the main focus of the research. The merits of the hot
water wash system were presented as supplemental information to the aqueous wash
alternative. The environmental analysis of the substitutes was expanded to evaluate the
national environmental benefits possible if entire industry sectors were to implement similar
process changes.
The following conclusions were drawn from the analyses completed for this project:
1. The implementation of the cleaning process alternatives either improved or did
not affect the performance of subsequent process steps or the quality of the
products.
2. The process changes eliminated the toxic emissions of TCA while creating new
waste streams of wastewater, in the case of the aqueous wash system, and
VOCs, in the case of the evaporative lubricant. The quantity of chemicals
consumed by the alternative processes is significantly less than that of the
solvent systems.
3. Activity- based cost accounting showed that the alternative cleaning processes
were considerably less expensive to operate and maintain than the TCA
degreasing systems. The capital costs for the alternatives were more than
justified by the savings in operations with payback periods ranging from 0.27
to 2.4 years.
4. The national environmental impact evaluation suggests that significant
reductions in life-cycle chemical emissions will occur with implementation of
alternative cleaning systems. Generally, for the aqueous wash systems, the
shift would mean increased wastewater loads and oily pollutant discharges to
POTWs. The nation's POTW infrastructure, in aggregate, can handle these
increased loads, however, the shift in waste stream composition must be
evaluated on a case-by-case basis
A discussion of these conclusions follows
114
-------
TECHNICAL EVALUATION
The technical evaluation analyzed the merits of the alternative cleaning systems (both
the aqueous wash and the no-clean, evaporative lubricant systems) by comparing the
production rate (e.g., the cleaning cycle time per unit manufactured) and the part reject rates
between the old and new processes. Both historical data and interviews with CMC quality
control staff established the results summarized in Table 52.
TABLE 52. SUMMARY OF THE TECHNICAL EVALUATION RESULTS
Line
Radiator
Condenser
Cycle Time
50% reduction in cycle time
due to aqueous wash
implementation
no significant change
Reject Rate
76% reduction in part reject
rate due to aqueous wash
system
no significant change
Interviews with line personnel and management indicated that the solvent degreasing
units represented the bottle-neck of the radiator manufacturing process. The aqueous wash
system eliminated that bottle-neck by reducing the cleaning process time by half compared to
that of the solvent system The parts reject rates for the radiator line also decreased,
significantly, after the implementation of the aqueous wash system. The decrease of 76
percent in part reject rates can be predominantly attributed to the improved cleaning
characteristics of the aqueous wash system. The implementation of the aqueous wash process
had been supported by an internal task force which was responsible for decreasing radiator
rejects through process improvements.
The production and part reject rates for the condenser line were evaluated through
employee interviews. Through these interviews it was established that the implementation of
the no-clean process alternative had little effect on either rate.
ENVIRONMENTAL EVALUATION
The changes in chemical releases and transfers to the environment from CMC's
manufacturing facilities due to the implementation of the alternative processes included the
following:
elimination of TRI reporting requirements of TCA releases and transfers from
each process line;
the creation of a state-regulated VOC air emission for the condenser line; and
the creation of a wastewater stream for the radiator line and the separation and
disposal of the oily waste removed from the parts.
115
-------
These changes are summarized for the radiator and condenser manufacturing lines in the
following table. Although it eliminated the use and disposal of TCA, the hot water wash
system of the converter line was not quantitatively evaluated in this analysis. A qualitative
evaluation of the advantages of this system are presented throughout Chapter 5, as well as in
the national environmental impact evaluation of Chapter 7.
TABLE 53. SUMMARY OF ENVIRONMENTAL EVALUATION RESULTS
Line
Total Waste Generation per Year
Solvent Degreasing Operations
Alternative Systems Operations
Radiator
171,500 Ib TCA consumed
114,900 Ib TCA haz. waste transfers
56,600 Ib TCA air releases
(1990)
22,100 Ib detergent consumed
2.0 million wastewater generated
gal
10,800 Ib non-haz., oily waste
transfers
64,780 Ib non-haz. wastewater
treatment solids transfers
(1992)
Condenser
121,500 Ib TCA consumed
14,400 Ib petroleum lub. consumed
75,400 Ib TCA haz. waste transfers
46,100 Ib TCA air releases
(1992)
12,200 Ib evap. lub. consumed
12,200 Ib VOC air releases
(1994)
Though the aqueous wash system of the radiator line generates two million gallon of
wastewater per year, chemical consumption, when compared to the solvent degreasing
system, has greatly decreased. The consumption rate of detergent, 2,640 gal/yr per year
(22,100 Ib/yr), is minimal when compared to the 15,840 gal/yr (171,700 Ib/yr) of TCA
previously consumed. The evaporative lubricant system of the condenser line has similar
advantages; the release of 12,200 Ib/yr of VOCs is significantly less than the 121,500 Ib/yr of
TCA released by the degreasers.
These data clearly show the trade-off issues that must be considered when choosing
between alternative cleaning systems. For the radiator line, releases of the toxic, ozone-
depleting chemical TCA were eliminated, but a larger volume, lower toxicity wastewater
stream was generated. Although hazardous waste management requirements have been
eliminated for this line, pretreatment requirements for discharge into the local POTW must
still be met. For the condenser line, hazardous waste and TCA were again eliminated. Air
116
-------
releases decreased substantially, suggesting less potential employee exposure; complete data
on the relative toxicity and risk of exposure to TCA and the mineral-spirit-based VOCs
emitted by the evaporative lube, however, are not available. This is one of the reasons CMC
is now switching to a non-petroleum based evaporative lube.
ECONOMIC EVALUATION
Two economic evaluations were completed for the analyses of the alternatives. The
first evaluation used a traditional method focussing on direct costs. The second method
utilized activity-based costing (ABC) to more accurately allocate overhead costs to the
appropriate products and processes. Finally, a hybrid of these methods was used to fully
represent the costs and benefits of the alternatives. The hybrid analyses resulted in the most
accurate assessment of costs for both the solvent degreasing operations and the alternatives.
The results of the hybrid analyses are discussed below. Tables 54 and 55 compare the hybrid
analysis results with the traditional economic evaluation results for the radiator and condenser
lines, respectively.
The analysis shows that the hybrid method identified additional direct costs associated
with the solvent degreasing units of the radiator line that would have been part of an overhead
cost factor in a more traditional analysis. Though the results of the traditional analysis of the
evaporative lubrication system are positive, the benefits of the radiator's aqueous wash system
were only apparent with the hybrid economic analysis method. The presentation of these
results in Chapter 6 illustrate very clearly that traditional cost analyses are not adequate to
fully estimate the benefits of pollution prevention projects. By properly allocating costs
through ABC that would normally be part of an overhead factor, benefits beyond traditional
costing techniques are realized.
TABLE 54. SUMMARY OF ECONOMIC ANALYSES RESULTS - RADIATOR
MANUFACTURING LINE
Analysis
Payback
NPV (5-year)
NPV(lO-vear)
NPV (15-year)
Hybrid Analysis
Solvent System
$2,584,150
$5,725,530
$9,547,510
Aqueous Wash
System
2.4 years
1,514,260
$3,073,640
$4,762,870
Traditional, Direct Cost Analysis
Solvent System
$660,580
$1,464,270
$2,442,090
Aqueous Wash
System
11.6 years
$808,280
$1,508,720
$2,147,930
Note: dollar values represent costs.
117
-------
TABLE 55. SUMMARY OF ECONOMIC ANALYSES RESULTS - CONDENSER
MANUFACTURING LINE
Analysis
Payback
NPV (5-year)
Hybrid Analysis
Solvent System
$1,089,550
Evaporative Oil
System
0.27 years
$219,660
Traditional, Direct Cost Analysis
Solvent System
$619,750
Evaporative Oil
System
0.45 years
$99 930
Note: dollar values represent costs.
NATIONAL ENVIRONMENTAL IMPACT EVALUATION
This evaluation utilized the life-cycle concept to evaluate the potential environmental
impacts which could result throughout the life-cycle of the chemicals used in the traditional
and alternative processes. The environmental evaluation of CMC's process changes was used
to estimate the potential national environmental impacts if entire industrial sectors were to
implement the alternatives to solvent degreasing. The elimination of chlorinated solvents for
materials and parts degreasing could significantly impact the national emissions of these
chemicals from their production, use and disposal. The implementation of the alternative
systems, though having associated releases and transfers of other chemicals, could
significantly decrease the environmental impacts now associated with the life-cycle of solvent
degreasers and the solvents used.
Materials and parts degreasing systems consume an estimated 499.9 million Ib/yr of
chlorinated solvents, based on 1992 figures. This use results in significant air releases and
hazardous waste transfers. In addition to these direct use and disposal emissions, solvent
emissions as a result of chlorinated solvent production processes must also be attributed to
materials and parts degreasing An estimated 460,000 Ib of chlorinated solvent from
manufacturing emissions (1992 TRI) may be attributed to solvent degreasing processes based
on current production rates and degreasing application figures.
The implementation of aqueous wash alternatives, though eliminating the production,
use, and disposal emissions of the chlorinated degreasing solvents, has unique emissions of its
own. Detergents, a mixture of surfactants, builders, chelators, and other ingredients, have
associated chemical production releases and transfers. Emissions from commonly used
ingredients (e.g., ethoxylated alcohols, alkylbenzene sulfonates, EDTA, and tetrapotassium
pyrophosphate) include ethylene, ethylene glycol, benzene, glycol ethers, and a variety of
acids. An estimate of the quantity of detergent ingredients applied to industrial applications
was not available, and therefore an estimate of the amount of production releases which could
be allocated to the industrial use of detergents was not possible. However, order-of-
magnitude calculations show that life-cycle releases and transfers could be significantly
reduced with the implementation of the aqueous alternative.
A second issue to address when considering the life-cycle attributes of aqueous wash
systems is the water waste stream that must be properly managed. Pretreatment of the
118
-------
wastewater from aqueous systems may be required to adequately remove oils, greases, BOD,
and suspended solids. The evaluation of the POTW infrastructure suggests that both the
nation's capacity and treatment capabilities are adequate to accommodate changes to aqueous
systems by entire industrial sectors, but the capacity and pretreatment requirements of local
POTWs must be taken into account for specific applications.
119
-------
REFERENCES
1 U.S. Environmental Protection Agency, Office of Pollution Prevention, "Pollution
Prevention Fact Sheet: EPA's 33/50 Program," (Washington: GPO, August 1991).
2 U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
3 U.S. Environmental Protection Agency, Office of Research and Development, "The Product
Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub. No.
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
U.S. Environmental Protection Agency, "Survey of Trichloroethylene Emission Sources,"
Pub. No. EPA-450/3-85-021, (Research Triangle Park, North Carolina), July 1985.
6 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
7 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
8 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
9 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub. No.
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub. No.
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
12 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
120
-------
14 U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes," Pub. No.
EPA/600/R-94/178, September 1994.
15 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub. No.
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
16 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub. No.
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
17 Pollution Engineering, "Aqueous Cleaners Challenge Chlorinated Solvents," December
1991.
18 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
19 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
20 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
21 Aronson, Robert B., "It's Time to Panic," Manufacturing Engineering, September 1993.
22 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
23 Water Quality and Treatment, 4th Edition, American Water Works Association, 1990.
24 "Regulatory Toxicology and Pharmacology," International Society of Regulatory
Toxicology and Pharmacology, Vol. 20, No. 1, May 1994.
25
1,1,-Trichloroethane, Hazardous Substances Data Bank (HSDB), October 1990.
26 "Regulatory Toxicology and Pharmacology," International Society of Regulatory
Toxicology and Pharmacology, Vol. 20, No. 1, May 1994.
27 Bartnik, F. and K. Kunstler, "Biological Effects, Toxicology and Human Safety,"
Surfactants in Consumer Products, 1987.
28 Bartnik, F. and K. Kunstler, "Biological Effects, Toxicology and Human Safety,"
Surfactants in Consumer Products, 1987.
29 Sodium Tripolyphosphate, Hazardous Substances Data Base (HSDB), May 1995.
121
-------
30 Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1991.
Ethylenediamine Tetraacetic Acid, Hazardous Substances Data Base (HSDB), May 1995.
32 Kirk Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1991.
33 Spitzer, Martin A. "Calculating the Benefits of Pollution Prevention," Pollution
Engineering, September 1, 1992.
34 Spitzer, Martin A. "Calculating the Benefits of Pollution Prevention," Pollution
Engineering, September 1, 1992.
35 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub No
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
36 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document," Pub No
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
37 U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
38 U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
39 U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
U.S. Environmental Protection Agency, Office of Research and Development, "The
Product Side of Pollution Prevention: Evaluating the Potential for Safe Substitutes " Pub No
EPA/600/R-94/178, September 1994.
42 U.S. Environmental Protection Agency, "Survey of Methylene Chloride Emission Sources,"
National Emission Standards for Hazardous Air Pollutants, EPA-450/3-95-015, June 1985.
SRI Directory of Chemical Producers United States. SRI International, 1992.
Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1993.
122
-------
45 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
46 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
47 Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1993.
48 Phone conversation with Speciality Chemical Manufacturing Association.
49 Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1993.
50 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
51 Pittinger, Charles A., et. al., "Environmental Life-Cycle Inventory of Detergent - Grade:
Sufactant Sourcing and Production," 1991
52 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
53 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
54 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
55
56
Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1993.
Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
57 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
58 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
123
-------
Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
Ullmann's Encyclopedia of Industrial Chemistry, Vol. A17, 1985.
61 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
62
66
Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
63 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
Ullmann's Encyclopedia of Industrial Chemistry, Vol. A10, 1985.
Ullmann's Encyclopedia of Industrial Chemistry, Vol. A10, 1985.
SRI Directory of Chemical Producers United States. SRI International, 1992.
67 Davis, Gary, et. al. , "Household Cleaners: Environmental Evaluation and Proposed
Standards for General Purpose Household Cleaners," University of Tennessee, Center for
Clean Products and Clean Technologies, prepared for Green Seal, Inc., July 1992.
68 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document " Pub No
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
69 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document" Pub No
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
70 U.S. Environmental Protection Agency, "National Emission Standards for Hazardous Air
Pollutants: Halogenated Solvent Cleaning - Background Information Document" Pub No
EPA-453/R-93-054, (Research Triangle Park, North Carolina).
71 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
Interview with Shelbyville, Tennessee's wastewater treatment operators.
124
-------
73 United States Geological Survey, "Water Resources Data Tennessee Water Year 1993,"
Water-Data Report TN-93-1, 1994.
74 U.S. Environmental Protection Agency, Office of Wastewater Exposure and Compliance,
"1992 Needs Survey Report to Congress," Pub. No. EPA 832-R-93-002, September 1993.
75 U.S. Environmental Protection Agency, Office of Wastewater Exposure and Compliance,
"1992 Needs Survey Report to Congress," Pub. No. EPA 832-R-93-002, September 1993.
76
77
Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 5, 1991.
Kirk-Othmer Encyclopedia of Chemical Technology, 4th Ed., Vol. 7, 1993.
78 Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
79
Center for Emission Control, "Solvent Cleaning (Degreasing), An Assessment of Emission
Control Options," November, 1992.
80 Wastewater Engineering in Treatment, Disposal and Reuse, Metcalf and Eddy, Inc., 3rd
Ed., McGraw Hill Publishing Co., 1991.
125
-------
APPENDIX A
RAW DATA IN DATA REQUEST TABLES
CMC was asked to complete the following data request tables. These tables allowed
for the collection of process information including capital costs, operating and maintenance
costs, utilities consumption, and production data. Similar data were requested for both the
solvent degreasing systems (historic data) and alternative systems (current data). Table Al
presents the data requested and received for the radiator manufacturing line; and Table A2
presents condenser manufacturing line data.
TABLE Al. COMPLETED DATA REQUEST TABLES - RADIATOR
MANUFACTURING LINE
Data Request
Equipment type
Equipment model number
Number used
Capital Cost - Cleaning Equipment
Equipment (indicate total cost if more than one unit)
Year purchased
Installation (% of equip, cost or specify units)
Year installed
Instrumentation (% of equip, cost or specify units)
Plant Engineering (% of equip, cost or specify units)
Materials (% of equip, costs or specify units)
Floor area required (sq ft)
Floor area cost ($/sq ft)
Estimated pay-back period
Solvent Cleaning
System
not available
not available
5
not available
not available
not available
not available
not available
not available
not available
385
30
not applicable
Aqueous Wash
System
Ransohoff
H-2144
1
$463,595.24
1991
$38,979.24
1991
included above
included above
included above
470
30
not calculated
126
continued
-------
Table A1 continued
Data Request
Capital Cost-Ultrafiltration Unit
Equipment
Year purchased
Installation (% of equip, cost or specify units)
Year installed
Instrumentation (% of equip, cost or specify units)
Plant engineering (% of equip, cost or specify units)
Materials (% of equip, cost or specify units
Floor area required (sq. ft.)
Estimated pay-back period
Operating Cost
Operators/shift
Hrs/shift/operator
Shifts/day
Operating days/year
Average wage rate, $/hr
1,1,1-trichloroethane $/lb or $/gal (specify units)
1,1,1-trichloroethane Ib or gal used/shift
Aqueous cleaner $/lb or $/gal (specify units)
Aqueous cleaner Ib or gal used/shift
Supervision (as % of O&M cost or specify units)
Maintenance Cost
Labor (as % of capital costs or specify units)
Materials (as % of capital costs or specify)
Cleaning equipment down time/year
Effect of cleaning method on downstream equip, maint.
Solvent Cleaning
System
not applicable
not applicable
not applicable
not applicable
not applicable
not applicable
not applicable
not applicable
not applicable
1
8
2
237
$13.65
$7.90/gal
65 gal/day
not applicable
not applicable
5%
not available
not available
5%/day plus
2 wks/yr
not applicable
Aqueous Wash
System
An ultrafiltration
system for the
aqueous wash
system to reuse
spent water was a
future plan of
CMC's. No data
on these units
were currently
available.
1
8
2
237
$13.65
not applicable
not applicable
$7.70/gal
5.5 gal
0
not available
not available
3 days/year
not available
127
continued
-------
Table A1 continued
Data Request
^
Operating Parameters
Initial hot water wash temperature (degrees F)
• __
Initial hot water wash chamber size (L x W x H in ft)
Aqueous wash or degreasing chamber temp (degrees F)
^^^^™*^"">^^''^^'''^"" ^••^••^••^^^••••.^ii i^^i^^^
Aqueous wash or degreasing chamber size (L x W x H in ft)
^^^^^^"^^^"^""^^"^^^^""^^•^"•^^^^^^^^""^••I^—B^™^
Hot water rinse no. 1 temperature (degrees F)
• ——•
Hot water rinse no. 1 chamber (L x W x H in ft)
Hot water rinse no. 2 temperature (degrees F)
Hot water rinse no. 2 chamber (L x W x H in ft)
Drying method
•^^•^^••^••M
Drying temperature (degrees F)
Drying chamber size (L x W x H in ft)
Number of parts cleaned per batch
Residence time of parts in cleaning system (in minutes)
Conveyor speed (ft/min)
Nozzle flow rate (gam)
Nozzle pressure (psi)
Utilities consumption (please indicate units)
Power consumption (nameplate capacity, specify units)
1 .—.
Power consumption (% of capacity or specify units)
Power cost ($/kW-hr)
Fuel consumption (nameplate capacity, specify units)
Fuel consumption (% of capacity or specify units)
Fuel cost ($/unit)
—^—————————
Water consumption (nameplate capacity, specify units)
Water consumption (% of capacity or specify units)
Water cost ($/gal)
128
Solvent Cleaning
System
not applicable
————«——__
not applicable
——•———^__
not available
——^_
not available
——————^—
not applicable
~—^—————__
not applicable
—•——^—^—^———.
not applicable
—•—^—^——^——_
not applicable
^"«^—^—^—•—^—^i«^^».
not available
not available
—^———1^-^——
not available
2
2.6 min
""^^™^™^^™^™»
not applicable
•™~-—^—^^—
not applicable
i
not applicable
—'^—•—^——^—m
—^—•—^—_——.
4 heaters/unit
—^—
,248 kW-hr/shift
0.035
—^••^™!^™.B
not available
—^—^—^—^—^—i.^
not available
—^^^>^^i^^.^^
not available
• —^••^^•-••^•^
not available
• ••^•^^•^^^•^^
not available
~~~^—^———__—
not available
Aqueous Wash
System
145
1.0x3.5x1.5
not applicable
not applicable
not applicable
-—-^—^—^^»™
continuous
process
375
40
not available
•~"~——^—•—i^-«—
672 kW-hr/shift
0.035
not available
•~—•~™——i^——
16240SCF/shift
—^—^—!•—^-^»^™«
$58.46/shift
3710 gal/shift
•~—~——•^——^—^—
$0.00134/gal
continued
-------
Table Al continued
Data Request
Production Data
Name of part or assembly cleaned
Size of part (L x W x H in ft)
material of construction
Part configuration
Upstream manufacturing process
Downstream manufacturing process
Sensitivity of downstream process to cleanliness
Soil (e.g., oil, coolant, etc.) being removed (attach MSDS)
Cleanliness test methods
Frequency of cleanliness testing
Production rate (parts/hour)
% of parts cleaning capacity being utilized
Average part reject rate (%)
Cost of rejected part ($/part)
Solvent Cleaning
System
Radiator Core
2.3x2.3x0.17
Aluminum
Aqueous Wash
System
Radiator Core
2.3x2.3x0.17
Aluminum
Fine welded tubes, side and end plates
stamping, fin
forming
brazing
high
Oils and coolant
black light and
leak tests
monthly/daily
not available
not available
5%
not available
stamping, fin
forming
brazing
high
Oils and coolant
black light and
leak tests
monthly/daily
not available
67%
0.5 - 1%
not available
129
-------
^
TABLE A2. COMPLETED DATA REQUEST TABLES - CONDENSER
MANUFACTURING LINE
Number used
Capital Cost - Ultrafiltration Unit
Equipment (indicate total cost if more than one unit)
Year purchased
—
Installation (% of equip, cost or specify units)
Year installed
Instrumentation (% of equip, cost or specify units)
Plant engineering (% of equip, cost or specify units)
Materials (% of equip, costs or specify units)
Floor area required (sq ft)
Floor area cost ($/sq ft)
———————-^—_——
Estimated pay-back period
—
Operating Cost
———•——i——^_
Operators/shift
Hrs/shift/operator
•»••••»••••••••••••»•••••
Shifts/day
i^——•—••».
Operating days/year
—————————____
Average wage rate, $/hr
——————————
Supervision (as % of O & M cost or specify units)
1,1,1-trichloroethane $/lb or $/gal (specify units)
—————————_______^_____
1,1,1-trichloroethane Ib or gal used/shift
• .
Previous oil cost $/gal or $/lb
—————— —___
Previous oil Ib or gal used/shift
Evaporative lube cost $/gal or $/lb
Solvent Cleaning
System
———«^««
Conveyorized
Vapor
$76,000
1984
$30
not applicable
$7.90/gal
-^—^—^-—^-^MI
38 gal/shift
^^—^™»^-i^—^—•
$5.22/gal
Igal
•^^•^•••H
not applicable
Aqueous Wash
System
^^™«^—^^«
Conveyorized
Vapor
OffpitOS-1337 | In-house design
4
0.3 years
$13.65
3%
not applicable
not applicable
•~-"•—^——^—
not applicable
not applicable
•M^^H^^B^^Bi^H
9.84/gal
130
continued
-------
Table A2 continued
Data Request
Evaporative lube Ib or gal used/shift
Maintenance Cost
Labor (as % of capital costs or specify units)
Materials (as % of capital costs or specify)
Cleaning equipment down time/year
Operating Parameters
Vapor degreasing chamber temp, (degrees F)
Vapor degreasing chamber size (L x W x H in ft)
Post vapor degreasing drying method
Post vapor degreasing drying temperature (degrees F)
Post vapor degreasing drying chamber size (L x W x H in
ft)
Fin dryer drying temperature (degrees F)
Fin dryer length (ft)
Residence time of parts in cleaning system (in minutes)
Conveyor speed (ft/min)
Utilities Consumption (please indicate units)
Power consumption (nameplate capacity, specify units)
Power consumption (% of capacity or specify units)
Power cost ($/kW-hr)
Fuel consumption (nameplate capacity, specify units)
Fuel consumption (% of capacity or specify units)
Fuel cost ($/unit)
Water consumption (nameplate capacity, specify units)
Water consumption (% of capacity or specify units)
Water cost ($/gal)
Solvent Cleaning
System
not applicable
3%
2%
200 hrs
160
20 x 6 x 6
Air
100
6x6x2
not applicable
not applicable
1.6
12
124.8kW-hr/hr
62.4 kW-hr/hr
$0.035/kW-hr
not applicable
not applicable
not applicable
not applicable
not applicable
not applicable
Aqueous Wash
System
Igal
0.5%
1%
12 hrs
not applicable
not applicable
not applicable
not applicable
not applicable
392
2ft
0.167
12
83.2kW-hr/hr
33.28 kW-hr/hr
$0.035/kw-hr
not applicable
not applicable
not applicable
not applicable
not applicable
not applicable
131
continued
-------
Table A2 continued
Data Request
Production Data
•^H"^H^—i«^-^^-«>^—«^M_I
Name of part of assembly cleaned
~" ^-^—^—i-^^-^^^^™*,^^
Size of part (L x W x H in ft)
Material of construction
———^——^—-^—^^-^—
Part configuration
•^——^—^—^—^——^_
Upstream manufacturing process
———————^—______
Downstream manufacturing process
Sensitivity of downstream process to cleanliness
Soil (e.g., oil, coolant, etc.) being removed (attach MSDS)
Cleanliness test methods
Frequency of cleanliness testing
Production rate (parts/hour)
% of parts cleaning capacity being utilized
Average part reject rate (%)
Cost of rejected part ($/part)
Solvent Cleaning
System
Aqueous Wash
System
Corrugated fin
0.0531x0.0851x31
aluminum
•—^—^-—•—
horizontal continuous
assembly
•^—•—«^——^—i
furnace braze
high
30 wt spindle oil
^^^•^^Hi^^Mi
visual
^•I^MBmHMM
2/shift visual
^"•^"•^^•^^~^«^^«^-«
not available
^^••^^^^••B
100%
0
not available
Daphne AF2AU
visual
2/shift visual
^•^^••^•^••M^^V^^^^H
not available
^^•(^••^^•^H
100%
0
not available
132
-------
The following information was requested from CMC outside of the data request
tabular form. These forms appear as they were presented to CMC. Data supplied by CMC
are presented in bold style font.
WASTE DATA: WASTEWATER TREATMENT FACILITY
What is the wastewater treatment design capacity? 30.000 gal/day
What is the wastewater treatment normal flowrate? 25.000 gal/day
Has this normal flowrate changed due to process changes to cleaning systems
(i.e. change to aqueous)? D yes • no
If yes, by how much has the flowrate changed? NA gal/day
Is this flow rate
measured
estimated?
5.
In the table below, please list required permits (operating, discharge, etc.)
associated with the treatment facility, including permit fees, permit renewal
fees, and frequency of permit renewal. Please attach copies of each permit
identified below.
Permit
Industrial Discharge
Permit
Permit Fee ($)
0.00
Renewal Fee ($)
0.00
Frequency
every 2
years
6. Have these permits required revisions to accommodate the changes to aqueous
cleaning systems? D yes • no
If yes, what type of revisions were required, and how were they identified?
133
-------
7.
In the table below, list the treatment chemicals (acidsftases, polymers, etc.)
used in the wastewater treatment and solids handling processes. Please include
a description of the chemical application/deliverance system, quantity of
chemicals used, and prices Please attach MSDS sheets for each chemical
identified below.
Chemicals used in treatment operations and a
description of their application/delivery
Chemical Sodium Hydroxide
Quantity
Used/Day
— ^-— B-^LM.
25 gal
Description pH adjustment - metering pumps
Chemical: Sulfuric Acid
45 gal
Description pH adjustment - metering pumps
Chemical: Anionic Polymer
5
Description: flocculent
Chemical:
Description:
Price
($/gal)
1.40
1.24
$2.74/Ib
8. Please indicate power consumption for the wastewater treatment system in the
table below. Unknown
D
D
Specific Process Unit
(check appropriate box on left)
Power consumption of the system as a whole
OR
Separate Process Units (please identify the number
of units used):
Pumps
Mixers
Solids Press
Other (please specify)
Power Consumption (name
plate or metered, kWhr.)
134
-------
9. Please identify additional requirements and costs associated with the wastewater
treatment facility, including the following items:
a. operating and maintenance
number of employees: 2
time/employee/day devoted to treatment plant: 12 hr/day
b. testing and analysis
parameters tested: see permit requirements
frequency of testing: every 4 months
Is this testing traditionally done D in house
• contracted out?
cost of analyses: $300.00 $/test series
wastewater surcharges and/or disposal costs: $0.00134 $/gal
solids disposal costs: $14.90 $/drum, 30 drums/2 weeks
Please attach waste manifest sheets/data if applicable.
c. Have the aqueous cleaning systems resulted in an increased volume of solids to
be disposed of from the treatment facility? If yes, what is the volume of, and
the possible reasons for the increase. No
d. other (please specify)
135
-------
WASTE DATA: AQUEOUS CLEANING SYSTEM - RADIATOR LINE
1. Wastewater generation:
both
4.
continuous
batch/intermittent
2. If continuous, at what flowrate is it generated? 7800 gal/day
3. If batch, please answer the following questions. NA
a. frequency of discharge: once/week (specify units)
b. volume of wastewater per discharge: approx. 3000 gal
c. duration of discharge (e.g. hours, minutes, etc. please specify): 2 hrs.
c. discharge triggered by: D chemical analysis of stream
D parts cleanliness/performance
• other shut down
d. please indicate specific parameters triggering discharge (e.g. black light test,
oil/water ratio, etc.) Wash tanks are emptied weekly, approximately 3000
gallon total. Weekly dumps show best results for product cleanliness.
What other waste streams are generated from the radiator aqueous cleaning system
(e.g. oil residual from skimmer, manual wash of tubes, etc.)?
Waste
oil and water
Volume (gal/day)
5.5
Classification
non-hazardous
disposal facility
(fuel blending)
What analyses are performed on the wastewater and other waste streams presented
above? Please attach any results of tests that have been performed. NA
On a separate page, please explain the procedures used to drain the aqueous
cleaning unit including number of employees involved, electrical/mechanical
equipment required, and the time required. One employee opens valves on each
tank. The tanks are emptied by in-line pump which discharges to on-site
wastewater treatment plant. Time is approx. 2 hours.
136
-------
WASTE DATA: HAZARDOUS: 1,1,1 TRICHLOROETHANE WASTE -
RADIATOR, CONVERTER AND CONDENSER LINES
(Please return by March 28, 1994)
1. Total volume of 1,1,1 trichloroethane disposed of as hazardous waste from
Buildings 1 and 2 for 1990, 1991, 1992, and 19931?
1991 = 338,525 Ib 1992 = 206,345 Ib 1993 = 194,975 Ib
2. Total volume of 1,1,1 trichloroethane disposed of as hazardous waste from
Building 3 for 1992 and 1<>93?
1992 = 3,480 Ib 1993 = 11,140 Ib
3. What permit(s) are required for these waste streams (please attach copy of permit
(or application) and parameters)?
None, RCRA regulated; large quantity generator status.
a. are permits facility specific?
b. frequency of renewal?
c. cost of permit application and/or renewal?
$900.00 annual haz. waste generation fee.
4. If available, please list the 1,1,1 TCA waste volume contributions from specific
lines (see table below).
5.
Year
1990
1991
1992
1993
Radiator
10,600 gal
8,000 ga.
not applicable
not applicable
Converter
2,500 gal
2,500 gal
unknown
unknown
Condenser
6,960 gal
6,960 gal
unknown
unknown
Waste disposal operations
a. How frequently was 1,1,1 TCA drained from degreasing units?
- radiator line as needed
- converter line as needed
- condenser line as needed
b. How was this frequency determined (e.g. buildup of soils, parts failed
cleanliness tests, smoking at welding operations, etc.)?
- radiator line build up of soils, parts did not braze
- converter line build up of soils, parts did not weld
- condenser line build up of soils, parts did not braze
137
-------
c. Please list in table below the personnel responsible for 1,1,1 trichloroethane
disposal operations (designate either line operator or corporate environmental
engineer and the time required for each step).
Operation
draining tanks
and filling
drums
labeling and
sealing drums
drum transport
to storage
manifest
completion
Radiator
who
tech.
tech.
tech.
env.
eng.
time per
occurrence
various
various
various
various
Converter
who
tech.
tech.
tech.
env.
eng.
time per
occurrence
various
various
various
various
Condenser
who
tech.
tech.
tech.
env.
eng.
time per
various
various
various
various
6. How are these hazardous wastes disposed of?
D incinerated9
• recycled?
D other (please specify)
7. Where are they disposed of?
8. If incinerated, is it for energy conversion? • yes D no
9. If recycled, do you receive the material back for reuse? • yes
no
10. What are the costs of disposal (incineration, recycling, other) including disposal
fees, transportation fees, taxes, etc.?
$1.80 per gal, price includes transportation, recycling, but not resale revenue.
138
-------
WASTE DATA: AIR EMISSIONS: 1,1,1 TRICHLOROETHANE WASTE -
RADIATOR, CONVERTER AND CONDENSER LINES (Please return by March 28,
1994)
1. Total volume of 1,1,1 TC A air emissions reported for 1990 and 1991 for Buildings
1 and 2. 1990 = 425,756 Ib 1991 = unknown
How are these volumes determined? mass balance
2. Total volume of 1,1,1 TCA air emissions reported for 1992 and 1993 for Building
3 1992 = 13,840 Ib 1993 = 9,000 Ib est.
How are these volumes determined? mass balance
3. What permit(s) are required for this stream (please attach copy of permit (or
application) and parameters)? air permit
a. are these permits facility specific? yes
b. are these permits line specific? no
c. what is the cost of permit application and/or renewal? NA
d. how frequently are renewals required? various
4. Volume of 1,1,1 TCA air emissions from radiator line reported for 1990 and
1991? unknown - emissions are building specific
5. Volume of 1,1,1 TCA air emissions from converter line reported for 1992 and
1993? 1992 = 14,011 Ib 1993 = unknown, approx. 6,000 Ib est.
6. Volume of 1,1,1 TCA air emissions from condenser line reported for 1992 and
1993? unknown - emissions are building specific
139
-------
APPENDIX B
SCREENING TEST RESULTS FOR THE AQUEOUS WASH SYSTEM
Two screening tests were employed by CMC to determine the applicability of viable
cleaning alternatives; a black light contamination check and a brazed core check. The black
light contamination check, sample results presented in Table B1 for various detergent
products, inspects cleaned parts (e.g., radiator cores) for remaining soils after washing. Table
B2 is an example of results from a brazed core check. In these tests the assembled cores are
cleaned using the alternative method under investigation, brazed, and finally tested for leaks.
The results of Table B2 show leak occurrences and the reason for each leak.
140
-------
*
U
"§
C/3 H
SI
|8
* 53
PQ O
W J
PQ
o>
o
0
N
GO
•si
0>
0
O
O
H
GO
on on GO
(N
en
PQ 03
o
CQ
o o *r> »n
(N (N ^f (N
O
H
— , GO c/) on
Z > > >
CO
in
GO
> >
n m
H-, GO GO
Z > >
H
O
GO GO
GO GO GO GO
> >
(N
Q Q
^
S
a,
OJ
U
ex
vo oo _^ _2
"5 "S "S "§
'S 'S 'S 'O
OH Q | p i p t
O to O */1
CO
>
141
-------
2
H ^
ffl U
23 &
^< EC
£ u
C/3 U
0 0
5, ft
:?w
•< to
2 g
U
J
ca
H
C/5
i
|
o
U
in
3
C/2
0)
tti
C/2
H
CD
J
^
^ DQ ^
A"
S
CD
_N
=*fc
CD
O
U
H
U,
CD
"B-
ex
00
13
o
6
CD
^
C/1
CD
H
O
^p1
a
H
^o
CD
O
U
1 oooooooooo
O^ ^ xO sO
ON ' ' O ' ' i O i i O
ON ON ^^ r— i
3<<<
-------
§
(N
CQ
u
1
H
-»— '
s
o
u
3
C/i
C/T)
0)
H
0?
-If
6
^
•I
=«:
i_
o
T3
•c
H
<5
ex
ex
oo
Chemical
ooooooooooooo
xO
i i i lOi i lOi i i QC
0 ° ON
^ "* ON
vo^o^o^o^o^o^or4r^(N(S(Sp
\P O^
O V,^
'§ '5
ON
VO ^O CN (S
>— | CS (N Tt
LL] UQ U tQ
U ^
U H
143
-------
APPENDIX C
STATISTICAL EVALUATIONS
This appendix presents the methods and calculations of the three statistical evaluations
performed on CMC's production and part reject rate data. The source of the calculation
methods was "Experimental Statistics Handbook 91," United States Department of
Commerce, National Bureau of Standards, 1966.
REJECT RATE STATISTICAL ANALYSIS
Two analysis were used to evaluate the difference in reject rates both before and after
the aqueous wash system was installed to replace the solvent degreasers. The chi squared test
determined if the data sets were statistically different, and the student t test calculated
confidence intervals around each data set.
Chi Squared Test - Comparing Two Proportions when the Sample Sizes are Large.
The chi square test was used to evaluate whether the data sets were statistically
different. The general methodology and calculations are presented below, followed by the
final results of the analysis using CMC data.
Question: Does the characteristic proportion for Product A differ from that for Product B?
The characteristic of concern for this analysis was failure rate; is there a
statistical difference between the failure rate of Product A (radiator before process
change) and the failure rate of Product B (radiator after process change). The
following calculations were made to determine statistical differences.
The following procedure was used to perform a chi squared analysis of proportions:
1. Choose a, the significance level of the test.
For the analysis, a = 0.1 and 0 025.
2. Look up x2,., for one degree of freedom in a 'Percentiles of the x2 Distribution1
table.
For the analysis, x2,.. - 2.71 ( for a = 0.1) and 5.02 (for a = 0.025).
3. Compute: x2 - [n(|ra*sb - rb*sa - n/2)2]/(na* r * nb* s)
Parameters are defined in Table C1.
144
-------
TABLE Cl. SAMPLE DATA
Product
A
B
Total
Failures
ra
rb
r
Passes
sa
sb
s
Total
na
nh
n
4. If x2 > x2!.., conclude that the two types of products do differ with regard to the
proportion of the characteristic (i.e., failures).
The results of this test are presented in Table C2. When using chi square analysis, if
x2(caicuiated) ^ XV«)' ^ can ^Q concluded that the two data sets are statistically different. In the
analysis performed on the radiator part reject data, x2(calculated) » x2(i.»), thus the two sets are
statistically different.
TABLE C2. RESULTS OF CHI SQUARE ANALYSES
Significance Level, a
0.1
0.025
x2
* (i-«)
2.71
5.02
x2
n (calculated)
1621.37
Note: If X2(1.B) < x2(calculated), the data sets are statistically different.
Student T - Confidence Intervals for the Population Mean when Knowledge of the
Variability Cannot be Assumed - Two-Sided Confidence Interval.
Once established that these sets were statistically different from one another, student T
tests were used to establish confidence intervals around the means of each sample set. The
question the analysis answers and the calculation procedure are as follows:
Question: What is a two-sided 100( 1 - a) percent confidence interval for the true mean m?
The following procedure was used to calculate confidence intervals around each data set.
1. Choose the desired confidence level, 1 - a.
For the analysis of Chapter 4, a = 0.1 and 0.05, thus the intervals around the mean
will be 90 percent and 95 percent confident.
145
-------
2. Compute: X= arithmetic mean = (l/n)*(E Xj)
and: s = standard deviation = [(nEX2 - (EX)2)/(n2 - n)]1/2
with: n = number of data points in each sample set
Xj = data points
3. Look up t = t^ 5a for n-1 degrees of freedom in a 'Percentiles of the t Distribution1
table.
4. Compute: Xy = upper limit = X + t * sA/n
XL = lower limit = X -1 * s/Vn
TABLE C3. PARAMETER FOR DATA SETS AND ANALYSES
Parameter
n
t-0.95
^0.975
Before Change
13
1.782
2.179
After Change
16
1.753
2.131
The reject rate means and intervals, both before and after the process changes are
normalized to maintain confidentiality and presented in Table C4. The means represent the
average percent of production that was recorded as rejects for the sample sets. Comparing
the mean of each data set shows that the radiator core reject rate decreased 76.8 percent after
the aqueous wash system was implemented. Figure Cl graphically depicts these statistically
different data sets.
TABLE C4. RESULTS OF STUDENT T ANALYSES
Confidence Level,
1-B
0.90
0.95
standard deviation, s
Averages and Ranges
Solvent Degreasing
1 +0.145
1 +0.177
0.293
Aqueous Wash
0.232 + 0057
0.232 + 0.072
0.135
Notes: 1. All values normalized to average solvent degreaser reject rate.
2. solvent degreasing data set: 6/24/91 through 10/6/91,13 data points.
3. aqueous wash data set: 1/13/92 through 5/3/92, 16 data points.
146
-------
Average "•" = 0.23
Standard Deviation = 0.13
Average "x" = 1.0
Standard Deviation = 0.29
• aqueous
x degreaser
XXX
X X
X X
.1 .2 .3 .4 .5 .6 .7 .8 .9 1.0 1.1 1.2 1.3 1.4 1.5 1.6
Percent Rejects
(normalized)
FIGURE Cl. REPRESENTATION OF STATISTICALLY DIFFERENT DATA SETS
147
-------
STATISTICAL EVALUATION OF WASTEWATER ANALYSIS BOD RESULTS
A two-sided t-test was used to determine whether the average BOD of the pretreated
wastewater after the aqueous wash system was implemented differs from the average
wastewater BOD while the solvent degreasing systems were operational. The evaluation
method and the results of the analysis are presented below.
Question: Does the average of the new product differ from the standard (o unknown)?
The following procedure was employed to analyze the data sets.
1. Choose a, the significance level of the test.
For the analysis, a = 0.1 and 0.05
2. Look up t^j. for n - 1 degrees of freedom from a 'Percentiles of the t Distribution1
table.
For the analysis, t^ 5(t = 2.92 (for o = 0.1) and 4.303 (for a = 0.05).
3. Compute: Xave = arithmetic mean = (l/w)*(E XJ
and: s = standard deviation = [(«EX2 - (EX)2)/(w2 - n)]m
with: n = number of data points in each sample set
Xj = data points
4. Compute: u = t^ 5lt s/Vn
5. If | Xave -m0 > u, then the averages of the two sets differ; you have tow distinct sets.
where: m0 = the average of standard material
The results of this analysis are presented in Table C5.
TABLE C5. RESULTS OF PRODUCTION RATE STATISTICAL ANALYSES
Significance Level, a
0.1
0.05
Computed u
36.0
53.1
XM - mn
23.9
Note: If | Xave - mo \ < u, the average of the new data set differs from that of the standard (i.e., the average
wastewater BOD while the aqueous wash system was operational differs from the wastewater BOD while
the solvent degreasers were operational).
148
-------
APPENDIX D
CONVERSION TABLE
TABLE Dl. CONVERSION FACTORS
pascals (Pa)
grams (g)
meters (m)
poise (P)
Joules (abs.)
Watt-hours (w-hr)
liter (L)
grams per liter (g/L)
mmHg @ 0°C
Joules per kilogram
pounds (Ib)
tons, short
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
9.86924 xlO'6
0.101972
1.450377 xlO'4
0.0075
0.002205
0.035274
3.28084
1
0.1
9.4845 x 10-4
1
0.23901
3.414426
3600
0.035315
0.001
0.26417
1000
0.0083452
0.0013158
1.35951
133.3224
43021xlO'4
453.5923
16
2000
= atmospheres (arm)
= kilograms per square meter (kg/m2)
= pounds per square inch (lb/in2)
= millimeter of mercury @ 0°C (mmHg)
= pounds, avdp (Ib)
= ounces, avdp (oz)
= feet (ft)
= grams per centimeter second (g/cm-sec)
= pascal seconds (Pa-sec)
= British thermal Units (BTU)
= Watt-seconds (W-sec)
= gram calories (cal.)
= British Thermal Units (BTU)
= Joules (J)
= cubic feet (ft3)
= cubic meters (m3)
= gallons, U.S. liq. (gal)
= parts per million (ppm)
= pounds per gallon (Ib/gal)
= atmospheres (atm)
= grams per square centimeter (g/cm2)
= pascals (Pa)
= British Thermal Units per pound (BTU/lb)
= grams (g)
= ounces, avdp (oz)
= pounds (Ib)
149
continued
-------
Table Dl continued
gallons (gal)
pounds per gallon
(Ib/gal)
x 907.1847
x 0.1605436
x 1.200949
x 119.826
= kilograms (kg)
= cubic feet (ft3)
= gallons, U.S. liq. (gal)
= grams per liter (g/L)
°F =1.8°C + 32
k =Kilo=10?
c =centi = 10'2
M = mega = 10s
m =milli=10-3
Source: "Avogadro's Numbers," Indelible Ink
150
-------
APPENDIX E
CALSONIC CORPORATION'S ENVIRONMENTAL PROGRAM
A. OBJECTIVE
To properly manage and reduce usage and emissions of pollutants and hazardous
materials, and to ensure strict compliance with all Federal, State and Local Environmental
Regulations.
B. SCOPE
All Calsonic operations will minimize, where economically feasible, pollutants
released to the air, land and water, and reduce generation and properly dispose of all
hazardous and non-hazardous waste. Environmental compliance is a Calsonic
Corporation objective at all company locations.
C. REFERENCES
Applicable Federal, State and Local Law and Ordinances.
D. RESPONSIBILITIES:
1. Each Calsonic operation will designate a person to be responsible for
environmental compliance. This person will be given the authority to enforce
environmental regulations at that location through the management organization.
2. The environmental designee at each location shall be responsible for
identification, classification and reporting requirements regarding emissions, waste
generation, hazardous material usage and disposal operations.
3. The environmental designee shall establish and monitor effective hazardous
materials management programs at each location.
4. The environmental designee shall maintain usage logs, records, permits, etc. to
ensure compliance to each applicable regulation.
5. The environmental designee shall develop expertise and understanding of
environmental compliance as required within the Calsonic organization. The
environmental designee shall keep current on any changes in the regulations that
could effect the Calsonic organization. The designee shall communicate to
151
-------
Calsonic's management any new legislation or regulation that could effect the
Calsonic organization in the future.
6. The environmental designee shall interface with any Federal, State or local
representatives concerning compliance to applicable regulations.
7. The environmental designee shall report to management any areas of non-
compliance. Any areas of non-compliance shall be corrected as soon as possible.
8. The environmental designee shall perform an environmental audit of his or her
facility(s) at least annually. The audit report is to be submitted to the top executive
at that location. The top executive shall be responsible to coordinate proper follow-
up.
9. The environmental designee shall develop, where feasible, ways to minimize or
eliminate emissions of pollutants to the land, air and water. The environmental
designee shall develop and manage a waste reduction program at each facility.
10. The environmental designee shall evaluate and approve hazardous waste
trucking companies and treatment, storage, and disposal (TSD) facilities that are
properly permitted, have adequate liability insurance, and appropriate operating
procedures. Calsonic shall only use those transporters and TSD facilities so
approved.
11 The environmental designee shall provide and document employee training as
required in the handling and management of hazardous waste, and in requirements of
environmental compliance.
12. The environmental designee shall be responsible to complete and submit all
reports, notices, and permit applications required by environmental regulations.
13. The environmental designee shall relay, through the proper channels, Calsonic's
commitment to being an environmentally conscious company.
152
-------
WASTE
MANAGEMENT
PLAN
CALSONIC
MANUFACTURING
CORPORATION
153
-------
I. Management Policy
Calsonic Manufacturing Corporation's policy is to reduce all hazardous and non-hazardous
waste to the minimum levels economically and technically feasible. Also to be in full
compliance with all federal and state waste regulations.
As both a responsible citizen and Calsonic employee, each individual is responsible for
reducing waste, for complying fully with all waste reduction programs established by the
company, and for not violating any federal or state waste regulations.
Employees are urged to come forth with suggestions for further reducing waste in their
own work area and in other areas about which they may have ideas.
In order to obtain full cooperation at all levels of the company in implementing the waste
reduction policy, the Corporate Engineering Manager has been assigned overall company
responsibility for establishing training programs and operating procedures required to
implement Calsonic's written policy
Bob Hofner
Executive Vice President
154
-------
II. Objectives and Goals
The objective of Calsonic's waste reduction plan is to reduce or eliminate, where
economically feasible, all generation of hazardous and non-hazardous waste.
Calsonic's goal is to reduce the total of all waste generation by at least thirty percent by
the year 1995. The year 1989 will be used as a baseline.
Calsonic will review historical and current technologies as to how they can be applied to
Calsonic's operations today and for the future.
III. Scope
Calsonic's waste reduction activities will involve all areas in which waste may be
generated. Each area of waste generation will be identified and recommendations made as
to reductions that can be achieved.
Waste reduction activities will involve all employees of Calsonic. Training will be
provided, where needed, to all employees to aid in achieving the goals established.
155
-------
Waste Generation (1989)
F001
F003, F005
F001
F002
D002, D007
D002
D002
F005
D001
F019
1,1,1 Trichloroethane
Flammable Liquid
Trichlorotrifluroethane
Methylene Chloride
Chromic Acid
Sodium Hydroxide
Sodium Hydroxide
Flammable Solid
Petroleum Naptha
Hazardous Waste Solid
76,169 kilograms
4,300
16,672
3,782
3,545
4,818
1,227
1,352
555
30,186
156
-------
Waste Reduction Activities
F001 Trichloroethane and F001 -1,1,1 Trichloroethane - are generated by degreasing
of metal parts prior to assembly. 92,841 kilograms of this waste was generated in 1989.
Goal - Ninety percent reduction of this waste stream by the year 1995.
Alternative Technologies -
(1). Aqueous wash units to replace vapor degreasers.
(2). Alternative replacements for degreasing.
(3). Possible assembly of units without degreasing.
F003, F005 Flammable Liquid - is generated by painting of condensers, oil coolers and
radiators. 5,652 kilograms of this waste was generated in 1989.
Goal - Eighty percent reduction by the year 1995.
Alternative Technologies -
(1). Powder paint systems
(2). Water based paints.
157
-------
F001 - Methylene Chloride - is generated by stripping paint from hooks used to carry
parts through the painting operation. 3,782 kilograms were generated in 1989.
Goal - One hundred percent reduction in the year 1992.
Alterative Technologies - Pyrolysis Oven
D002, D007 - Chromic Acid - is generated by chrome conversion coating of aluminum
evaporator cores. 3,545 kilograms of this waste was generated in 1989.
Goal - One hundred percent reduction by the year 1995.
Alternative Technologies - At present time there is no replacement for chrome
conversion coatings. Future technology will be evaluated.
158
-------
D002 - Sodium Hydroxide - is generated by preparing aluminum for conversion coatings
(chrome and zinc). 6,045 kilograms of this waste was generated in 1989.
Goal - One hundred percent elimination on the condenser line by the year 1994.
Elimination on the evaporator line is dependant on future technologies.
Alterative Technologies - (1) Redesign of condenser unit.
(2) Material substitution.
F005 Flammable Solid - is generated by the painting of condensers, radiators and oil
coolers. 1,352 kilograms of this waste was generated in 1989.
Goal - Sixty percent reduction by the year 1995.
Alternative Technologies - (1) Powder paint
(2). Water based paints.
159
-------
D001 - Petroleum Naptha - is generated by the cleaning of small parts. 555 kilograms of
this waste was generated in 1989.
Goal - One hundred percent reduction by the year 1995.
Alternative Technologies - Material substitution.
F019 Hazardous Waste Solid - is generated by the treatment of chrome conversion
coating waste. 30,186 kilograms of this waste generated in 1989.
Goal - Numeric goal unavailable at present due to no available technology.
Alterative Technologies - At the present time there is no acceptable replacement for
chrome conversion coatings Future technology will be evaluated.
160
-------
D002 - Sodium Hydroxide - is generated by preparing aluminum for conversion coatings
(chrome and zinc). 6,045 kilograms of this waste was generated in 1989.
Goal - One hundred percent elimination on the condenser line by the year 1994.
Elimination on the evaporator line is dependant on future technologies.
Alternative Technologies - (1). Redesign of condenser unit.
(2). Material substitution.
F005 Flammable Solid - is generated by the painting of condensers, radiators and oil
coolers. 1,352 kilograms of this waste was generated in 1989.
Goal - Sixty percent reduction by the year 1995.
Alternative Technologies - (1) Powder paint
(2). Water based paints.
161
-------
APPENDIX F
ANALYSIS RESULTS OF PRETREATED WASTEWATER EFFLUENT
TABLE Fl. ANALYSIS RESULTS OF WASTEWATER
Analysis
ph
BOD
TSS
TDA1
Cd
Tcr
Cu
Pb
Ni
Ag
Zn
F-
CN
TCA
Temp.
Flow
DISCHARGES TO POTW
8/2/90
9.1
5.4
24
12.4
0.21
0.09
0.06
<0.05
0.09
0.007
0.99
58.75
<0.01
0.0013
28
17,500
Date
11/30/90
8.2
4.4
18
2.9
0.09
0.01
-
<0.05
0.08
0.004
0.11
15.1
-
0.0082
20
19,000
6/20/91
6.8
1.7
3
1.9
0.12
<0.04
0.13
<0.05
0.12
<0.002
0.66
14.2
<0.01
0.0008
23
22,000
12/12/91
8.4
3.6
5
1.8
0.09
0.02
0.12
0.05
0.13
0.003
0.52
0.3
<0.01
0.0097
26
20,500
7/15/92
10
19
1
21.8
<0.005
<0.02
0.07
<0.002
<0.02
<0.01
0.22
21
<0.01
<0.01
_
18,500
12/10/92
8.2
52
9
1.9
<0.005
0.12
0.17
<0.002
0.06
<0.01
0.22
17.5
<0.01
0.41
26
22,000
9/8/93
9.4
12
9
12.3
<0.005
<0.02
0.08
0.004
0.03
<0.01
0.4
29.1
<0.01
0.24
-
Note: 1. All values given in mg/L unless otherwise stated.
2. Temperature is recorded in degrees Celsius.
3. Flow rate is recorded in gallons/day (gpd).
162
-------
APPENDIX G
UNIQUE BILLS OF ACTIVITIES
Unique bills of activities (BOA) were created for the radiator and condenser
manufacturing lines to economically evaluate the processes using activity-based cost
accounting. Table Gl and G2 present the unique BOAs for the old and new radiator
manufacturing lines, respectively. Tables G3 and G4 present the unique BOAs for the old
and new condenser manufacturing lines, respectively.
TABLE Gl. RADIATOR MANUFACTURING LINE -
OLD, TCA DECREASING SYSTEM'S BOA
Tier
I
A
1
2
3
a
b
c
d
B
1
2
3
a
b
c
4
II
III
A
B
Activity
Process paperwork for order/receipt of TCA
Manufacturing dept. determine materials needs
Fill out material needs paperwork
File copy of paperwork
Forward paperwork to purchasing
Purchasing reviews paperwork
Fill out proper order forms
Locate and contact proper materials vendor
File purchase order paperwork
Distribution dept. manages inventory
Locate order form
Verify incoming materials with order form
Forward paperwork to accounting
Accounting reviews papei-work
Accounting processes paperwork (pays bills)
accounting files paperwork
Input incoming inventory into computer system or management file
remove TCA from truck to storage area by forklift
clean radiator cores using vapor degreasers
When core is assembled, place in rack of degreaser (one unit/clean)
Close door and press button to start cleaning process (automated)
Cost Driver
$/receipt
(included labor hrs
throughout paper
chase)
$/receipt
$/core
(includes machine
and labor hrs.)
163
continued
-------
Table Gl continued
Tier
Activity
Cost Driver
while cleaning, assemble another core
D
Open door and press button to start cleaning process (automated)
Stack radiator core on wheeled cart for further processing
Wheel carts, once full, to flux and braze unit
Remove cores from carts and place on Conveyonzed flux/braze machine
Place second core in rack of degrcaser and repeat the process
IV
Maintain five (5) batch degreasing systems -DAILY
$/labor hr.
A
Monitor TCA reservoir level
B
Fill reservoir with TCA (replenish)
Determine reservoir is low
Transport 55 gal drum from outdoor storage to process line
(drum is dept at degreasers, so this step is only periodically)
utilize pump and tube to fill reservoir
Return remaining TCA (or empty drum) to storage, or store
short-term at process line
Change-out TCA from degreasers - PERIODICALLY
Shut down degreaser
Allow solvent reservoir to cool
Move empty drums from storage to line
Dram reservoir with pump and tube (fill drums)
Call environmental engineer
$/shipment
Properly label drums
insure 90-day limit is not exceeded for haz. waste storage
Transfer labeled drums to outdoor storage area by forklift
Call contractor to pick up hazardous waste shipment
Waste management paperwork
'roperly complete manifest
'ill out other in-house paperwork (accounting
c-
lend paperwork to accounting
164
continued
-------
Table Gl continued
Tier
9
a
b
c
10
V
VI
A
B
C
D
E
F
1
2
a
b
c
d
i
li
iii
IV
c
i
li
iii
3
Activity
Contractor picks up shipment
Shipping verifies manifest with drums
Transfer drums from storage to truck
Shipper signs manifest
Manifest files are maintained by environmental engineer for 5 yrs
Operational maintenance on five batch degreasers
Leak Testing
Cores with plastic tanks are delivered one by one to test station
Connect radiator to tester
Push foot peddle to begin automated leak test
Move to next of four test units and perform same activities for next rad.
Disconnect tested radiator
Determination of test
Good radiators are individually moved onto packaging station
Rejected radiators are placed on separate rack
Water testers remove rejects four at a time
With water test, confirm leak and determine if it can be reworked
For rework, mark lead
Send to reworking
Remove two plastic tanks by manually folding back teeth
Straighten teeth using machine
Determine if tanks can be reused, place in box for reuse or dumpster for
scrap
Mark unit and leak area
Send to rebra/.e
Reflux leaking area
Resubmit pail to braze ovens
Retest for leaks, pass = production, fail = scrap (place in scrap recycle
bin)
Complete report on number of rejects
Cost Driver
$/labor hr.
$/core
(includes labor and
machine hrs)
165
continued
-------
Table Gl continued
Tier
VII
A
1
2
3
a
h
c
4
B
1
2
3
a
b
c
C
D
E
Activity
Apply for and maintain permits
Air permits
Monitor air releases (Calsonic uses eng. judgment rather than
measurements)
Maintain TCA use logs (purchasing records
Report air releases
TRI Reporting requirements
Forward report to I 'PA
Retain copy for company records
Re-apply for permit
Hazardous waste generation
Maintain spill containment around hazardous materials storage
Maintain manifest records
Report hazardous waste transfers (disposal)
TRI Reporting requirements
Forward report to EPA
Retain copy for company records
Train personnel on hazardous materials management and OSHA
Maintain records on every employee of training
Maintain files of Material Safety I )ata Sheets for every chemical in
facility
Cost Driver
$/labor hr.
166
-------
TABLE G2. RADIATOR MANUFACTURING LINE -
NEW, AQUEOUS DETERGENT SYSTEM'S BOA
Tier
I
A
1
2
3
a
b
c
c
B
1
2
3
a
b
c
4
II
A
B
C
III
A
B
1
2
IV
A
1
Activity
Process paperwork for order/receipt of detergent
Manufacturing dept. determine materials needs
Fill out material needs paperwork
File copy of paperwork
Forward paperwork to purchasing
Purchasing reviews paperwork
Fill out proper order forms
Locate and contact proper materials vendor
File purchase order paperwork
Distribution dept. manages inventory
Locate order form
Verify incoming materials with order form
Forward paperwork to accounting
Accounting reviews paperwork
Accounting processes paperwork (pays bills)
Accounting files paperwork
Input incoming inventory into computer system or management file
Receipt of detergent shipment
Line forklift operator is informed of shipment
Remove detergent from truck to staging area by forklift
Move detergent from staging area to storage by forklift
Assembly of cores
Line personnel combine cut fins and tubes into jib
Stack radiator core on wheeled cart for further processing
Wheel carts, once full, to aqueous cleaning, flux, and braze unit
Remove cores, one by one, from carts and place on conveyor
Maintain aqueous detergent wash system
Operation and maintenance - DAILY
Blowers
Cost Driver
$/receipt
(includes labor hrs
throughout paper
chase)
$/receipt
(includes labor hrs)
$/core
(includes labor and
machine hrs.)
$/labor hr.
167
continued
-------
Table G2 continued
Tier
2
3
a
4
5
B
1
2
3
4
5
6
7
8
a
b
c
9
10
11
a
b
c
d
C
1
2
3
Activity
Spray nozzle pressure
Chemical tests (detergent)
Detergent is added from drum a! line, & system is allowed to
equilibrate
Temperature
Scim oil from first rinse reservoir
Periodically dram the three tanks
Open valves of first rinse tank and turn on pump
Wait for tank to drain
Close valves and turn off pump
Repeat B 1-3 for second rinse tank
Inform wastewater treatment of detergent wastewater flow
Wastewater treatment switches \vater flow to separate tank
Repeat B 1-3 for detergent tank
Clean aqueous cleaning system
High pressure water spray
Vacuum
Change filters
Fill each tank with fresh water
Turn on heater coils in detergent/rinse bath
Add detergent to detergent bath
Periodically transfer detergent from storage area to process line
Measure detergent
Pour detergent into tanks
Circulate tank to mix detergent (may be accomplished with spray
system)
Operation and maintenance of aqueous system
Grease mechanisms of blowers
Pump oil from holding tank
Check spray pressures
Cost Driver
168
continued
-------
Table G2 continued
Tier
V
A
1
2
a
b
c
d
i
ii
iii
iv
3
VI
A
1
2
3
4
5
6
a
b
c
d
B
1
a
Activity
Leak testing
Determination of test
Good radiators are moved onto packaging station
Rejected condensers are piaced on separate rack
Water testers remove rejects four at a time
With water test, confirm leak and determine if it can be reworked
For rework, mark leak
Send to reworking
Remove two plastic tanks by manually folding back teeth
Straighten teeth using machine
Determine if tanks can be reused, place in box for reuse or dumpster
for scrap
Mark unit and leak area
Complete report on number of rejects
Wastewater treatment activities
continuous processes
Drain equilization basin into treatment train
Lower pH
Raise pH
Add polymer and mix
Allow to settle
Filter sludge/solids
Prepare plate-m-frame filter press
Flow water/slurry through press by pumping from bottom of settling
tank
Open plates and scrap off solid, dropping them on the floor
Collect solids in 55 gal dnim
Batch processed
Shock detergent waste water in separate tank
Add acid
Cost Driver
$/core
(includes labor &
machine hrs)
$/labor hr.
169
continued
-------
Table G2 continued
Tier
b
c
C
D
E
VII
A
1
B
Activity
Add lime
Pump pretreated wastewater into mam equilization basin
Maintain polymer and acid inventories
Maintain base inventory
Maintain pumps for these delivery systems
Apply for and maintain permits
Water/wastewater treatment and discharge
Sample wastewater quarterly
Maintain files of Material Safety Data Sheets for every chemical in
facility
Cost Driver
$/labor hr.
170
-------
TABLE G3. CONDENSER MANUFACTURING LINE -
OLD, TCA DECREASING SYSTEM'S BOA
Tier
I
A
1
2
3
a
b
c
d
B
1
2
3
a
b
c
4
II
III
A
1
2
a
b
c
d
3
B
Activity
Process paperwork for order /receipt of TCA
Manufacturing dept. determine materials needs
Fill out material needs papeiwork
File copy of paperwork
Forward papei-work to purchasing
Purchasing reviews paperwork
Fill out proper order forms
Locate and contact proper materials vender
File purchase order paperwork
Distribution dept. manages inventory
Locate order form
Verify incoming materials with order form
Forward paperwork to accounting
Accounting reviews paperwork
Accounting processes paperwork (pays bills)
Accounting tiles paperwork
Input incoming inventory into computer system or management file
Remove TCA from truck to storage area by forklift
Setup fin corrugation machine
Maintain vapor degreasing system - DAILY
Monitor TCA reservoir level
Fill reservoir with TCA (replenish)
Determine reservoir is low
Transport 55 gal drum from outdoor storage to process line
Utilize pump and tube to fill reservoir
Return remaining TCA (or empty drum) to storage, or store short-term at
process line
adjust for proper cleaning
Change-out TCA of degreaser - PERIODICALLY
Cost Driver
$/receipt
(includes labor hrs
throughout paper
chase)
$/receipt
$/labor hr.
171
continued
-------
Table G3 continued
Tier
1
2
3
4
5
a
b
c
d
e
i
ii
iii
f
i
ii
iii
g
IV
V
VI
A
1
2
3
a
b
c
4
Activity
Shut down degreasers
Allow solvent reservoir to cool
Move empty drums from storage to line
Drain reservoir with pump and tube (fill drums)
Call environmental engineer
Properly complete drum labels (date, identification, etc.)
Ensure 90-day limit is not exceeded for haz. waste storage
Transfer labeled drums to outdoor storage area by forklift
Call contractor to pickup hazardous waste shipment
Waste management paperwork
Properly complete manifest
Fill out other in-house paperwork (accounting)
Send paperwork to accounting
Contractor picks up shipment
Shipping verifies manifest with drums
Transfer drums from storage to truck
Shipper signs manifest
Manifest files are maintained by environmental engineer for 5 yrs
Operational maintenance on corrugator and vapor degreaser-DAILY
Operational maintenance on comigator and vapor degreaser- YEARLY
Apply for and maintain permits
Air permits
Monitor air releases (Calsonic uses eng. judgment rather than
measurements)
Maintain TCA use logs (purchasing records)
Report air releases
TRI Reporting requirements
Forward report to EPA
Retain copy for company records
Re-apply for permit
Cost Driver
$/labor hr.
$/labor hr.
$/labor hr.
172
continued
-------
Table G3 continued
Tier
B
1
2
3
a
b
c
C
D
E
Activity
Hazardous waste generation
Maintain spill containment around hazardous material storage
Maintain manifest records
Report hazardous waste transfers (disposal)
TRI Reporting requirements
Forward report to EPA
Retain copy for company records
Train personnel on hazardous materials management and OSHA
Maintain records on every employee of training
Maintain files of Material Safety Data Sheets for every chemical in
facility
Cost Driver
173
-------
TABLE G4. CONDENSER MANUFACTURING LINE -
NEW, EVAPORATIVE LUBRICANT SYSTEM'S BOA
Tier
I
II
III
A
1
2
a
b
c
3
Activity
Operational maintenance on dryers (DAILY or PERIODICALLY)
Maintain files on Material Safety Data Sheets for every chemical in
facility
Apply for and maintain permits
Air permits
Monitor air releases (Calsonic uses eng. judgment rather than
measurements)
Report air releases
State requirements
Forward report to state
Retain copy for company records
Re- apply for permit
Cost Driver
$/labor hr.
$/labor hr.
174
»O.S. GOVERNMENT PRINTING OFFICE: 1995-650-006/22066
------- |