United States
                          Environmental Protection
                          Agency
            National Risk Management
            Research Laboratory
            Cincinnati, OH 45268
                          Research and Development
            EPA/600/S-95/013   August 1995
                          ENVIRONMENTAL
                          RESEARCH   BRIEF
                 Pollution Prevention Assessment for a Manufacturer
                                      of Locking Devices

                                 Richard J. Jendrucko*, Brian T. Hurst*,
                                         and Gwen P. Looby
Abstract
The U.S. Environmental Protection Agency (EPA) has funded
a pilot project to assist small and medium-size manufacturers
who want to minimize their generation of waste but who lack
the expertise to do so. In an effort to assist these manufactur-
ers Waste Minimization Assessment Centers (WMACs) were
established at  selected universities and procedures  were
adapted from the EPA Waste Minimization  Opportunity As-
sessment Manual (EPA/625/7-88/003, July 1988). That docu-
ment has been superseded by the Facility Pollution Prevention
Guide (EPA/600/R-92/088). The WMAC team at the University
of Tennessee performed an assessment at a plant that fabri-
cates and finishes metal components that are assembled into
several types of locking devices. Raw materials are machined
and then shipped offsite for heat-treating,  stored until needed,
or buffed and cleaned.  Then, all parts other than those made
of stainless steel are electroplated,  electrostatically powder
coated, or lacquer coated.  The various component  parts are
then  assembled into the locking devices.  The  assessment
team's report,  detailing findings and  recommendations,  indi-
cated that the vapor degreasers generate  a significant amount
of waste and that vapor degreasing could  be replaced with an
aqueous cleaning system for intermediate  cleaning.

This Research Brief was developed by the principal investiga-
tors and EPA's  National Risk Management Research Labora-
tory, Cincinnati, OH,  to announce key findings of an ongoing
research project that is fully documented  in a separate report
of the same title available from University City Science Center.
 University of Tennessee, Department of Engineering Science and Mechanics
" University City Science Center, Philadelphia, PA
Introduction
The amount of waste generated by industrial plants has be-
come an increasingly costly problem for manufacturers and an
additional stress on the environment.  One solution to the
problem of waste generation is to reduce or eliminate the
waste at its source.

University City Science Center (Philadelphia, PA) has begun a
pilot project to assist small and medium-size  manufacturers
who want to minimize their generation of waste but who lack
the in-house expertise to do so. Under agreement with EPA's
National Risk Management Research  Laboratory,  the Science
Center has established three WMACs. This assessment was
done by engineering faculty and students at the University of
Tennessee WMAC.  The assessment teams have  consider-
able direct experience with process operations  in  manufactur-
ing plants and also have the knowledge and skills needed to
minimize waste generation.

The pollution prevention assessments are done for small and
medium-size  manufacturers at no out-of-pocket  cost to the
client.  To qualify for the assessment,  each client must fall
within Standard Industrial Classification Code 20-39, have gross
annual sales not exceeding $75 million, employ no more than
500 persons, and  lack in-house expertise in pollution preven-
tion.

The potential benefits of the pilot project include minimization
of the amount of waste  generated  by manufacturers, and
reduction of waste treatment and disposal costs for participat-
ing plants. In  addition, the project provides valuable experi-
ence for graduate and undergraduate students who participate
in the program, and a cleaner environment without more regu-
lations and higher costs for manufacturers.

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Methodology of Assessments
The pollution prevention opportunity assessments require sev-
eral site visits to each client served.  In general, the WMACs
follow the procedures outlined in the EPA Waste Minimization
Opportunity Assessment Manual (EPA/625/7-88/003, July 1988).
The WMAC  staff locate the sources of waste in the plant and
identify the  current disposal or treatment methods and their
associated costs.  They then identify and analyze a variety of
ways to reduce or eliminate the waste.  Specific measures to
achieve that goal are recommended and the  essential support-
ing technological and economic information  is developed.  Fi-
nally,  a confidential report  that details  the  WMAC's findings
and recommendations (including cost savings, implementation
costs, and payback times) is prepared for each client.


Plant Background
This plant fabricates and finishes metal components which are
assembled into several types of  locking devices.   Approxi-
mately one  million units are produced annually by this plant
during 5,880 hr/yr of operation.


Manufacturing Process
The operations used by this plant are  described below.


Component Parts Manufacturing
The major raw materials used by the plant include zinc die
castings and carbon and  stainless steel, brass, and bronze in
bars, coils, and rods.  Raw materials are  moved  by forklift to
the metal fabrication area where cutting, bending and shaping,
drilling, milling, screwing, and tapping operations are performed.

Prior to subsequent finishing operations,  residual machining
lubricant  is  removed  from the parts in  one  of two vapor
degreasers utilizing trichloroethylene.  Contaminated trichloro-
ethylene is distilled onsite and reused.

After cleaning, the parts are processed in one of three ways.
Some of the steel  parts are shipped offsite for heat treatment
and then  returned to the plant for further processing. A portion
of the parts is placed into storage until needed for production at
a later time.  The majority of parts  which  become external
locking device parts are buffed to improve  their appearance,
either by  hand  or in  an automatic system.   Parts  that have
been buffed  are cleaned in a third vapor degreaser.

All parts except those made of stainless steel require a surface
coating.   Most of the  parts  require  one or more layers of
electroplating.   The second  major type  of coating used is
electrostatic coating, and the third type is lacquer application to
prevent tarnishing.

After the  necessary coating process is complete, the  compo-
nent parts are transported  to  the assembly area where  the
different locking devices are assembled and  packaged.


Electroplating Operations
Because  the electroplating  operations generate a  significant
amount of waste they are described in  more detail  in this
section.

Parts that are to be plated that have not been buffed are first
placed into vibratory devices for removal of any surface irregu-
larities. Those parts are then conveyed through a small vapor
degreaser, washed in a series of two wash tanks,  and  rinsed.
Three different  plating  lines  are used by the  plant.  A small
quantity of special parts is plated in a small-scale hand-plating
line.   Typical plating runs include  chrome-or  black  chrome-,
bronze-, or brass-plating  and hot water rinsing between each
plating stage and at conclusion.

Smaller parts that are used on the majority  of the locking
devices are placed into barrels for plating in the barrel-plating
line.   For corrosion  protection, typical plating includes copper
striking and plating,  dull and  bright  nickel  plating, and chrome
plating with hot water rinsing  between each stage and at a final
rinsing station.

Larger parts are placed onto racks and mechanically carried
through the rack-plating line.  These parts  are plated with zinc,
copper strike and plating,  bronze, brass, nickel, and chrome for
decoration.

After parts have been processed through the appropriate plat-
ing line, they are removed from the conveying devices, allowed
to air  dry, and carried to the assembly area.

An abbreviated  process flow  diagram for this plant is  shown in
Figure 1.


Existing Waste Management Practices
This plant already has implemented the following techniques to
manage and minimize its  wastes.

  • A filter press and a drying oven are used to reduce the volume
    of hazardous wastewater treatment sludge shipped offsite.

  • Each vapor degreaser is  served by a distillation unit for the
    recycle and reuse of spent trichloroethylene.

  • Counterflow rinsing is used in the plating operations.

  • Flow restrictors have been installed on the water removal
    lines of the electroplating  rinse tanks to reduce the volume of
    wastewater generated.

  • A compactor is used to reduce the volume of nonhazardous
    solid waste shipped to the municipal landfill.

  • Water-based coolant  and cutting oil is removed from metal
    shavings using a centrifuge and returned to the metal fabri-
    cation units.

  • Scrap metal shavings are recycled offsite.

  • Canvas coverings have been installed over the openings of
    the vapor degreaser units to reduce evaporative  losses of
    solvent.

Pollution Prevention Opportunities
The type of waste currently generated by the plant, the source
of the waste, the waste management method,  the quantity of
the waste, and the annual treatment and disposal cost for each
waste stream identified  are given in Table 1.

Table 2 shows  the  opportunities for pollution  prevention that
the WMAC team recommended for the plant. The opportunity,
the type of waste, the possible waste reduction and associated
savings, and the  implementation cost along with  the  simple
payback time are  given in the table.  The quantities  of waste

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currently generated  by the plant and possible waste reduction
depend on the production level of the plant. All values should
be considered in that context.

It should be noted that the economic savings of the opportu-
nity,  in most cases,  results from the reduction in raw  material
and costs associated with waste treatment and disposal.  Other
savings not quantifiable by this study include a wide variety of
possible future costs related to changing emissions standards,
liability, and employee health.  It also should be noted that the
savings given for each opportunity reflect that pollution preven-
tion opportunity alone and do not reflect duplication of savings
that  may result when the opportunities are implemented in  a
package.

Additional Recommendations

In addition to the opportunities recommended and analyzed by
the WMAC team, two other measures were considered. These
measures were not  analyzed  completely because of a lack of
sufficient  information for analysis  or  an anticipated  lengthy
payback period.  Since these approaches to pollution  preven-
tion  may, however,  increase in attractiveness  with changing
conditions in the plant, they were brought to the plant's atten-
tion for future consideration.
  • Install rinse devices above each plating and wash tank to
    spray water onto each part as it is removed from the tank in
    order to return  plating  and  wash solutions to their tanks
    before  drag-out  occurs.  In order to  compensate  for the
    increased  amount of water being added to the tanks,  it is
    proposed that fan units be used to blow air across the surface
    of each tank to promote  evaporation of excess water.  Drag-
    out boards should be installed on each tank.

  • Implement electrostatic application of lacquer coating to
    component surfaces to reduce the current level of overspray
    and raw material purchases.

This research  brief summarizes a part of the work done under
Cooperation Agreement No. CR-814903 by the University City
Science Center under the sponsorship of the U.S. Environmen-
tal Protection  Agency.   The EPA Project Officer was  Emma
Lou George.

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                     Metal
                     stock
Storage
^

Metal
fabrication
^

Vapor
degreasing
^
^
                   Finished locking
                   devices stored
                   until shipped
                                                                               Electroplating
 Electroplating
powder coating
                                                                              Spray laquer
                                                                               application
Figure 1. Abbreviated process flow diagram for locking device fabrication.

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United States
Environmental Protection Agency
National Risk Management Research Laboratory (G-72)
Cincinnati, OH 45268

Official Business
Penalty for Private Use
$300
     BULK RATE
POSTAGE & FEES PAID
        EPA
   PERMIT No. G-35
EPA/600/S-95/013

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