United States
Environmental Protection
Agency
Risk Reduction
Engineering Laboratory
Cincinnati, OH 45268
Research and Development
EPA/600/SR-95/006 February 1995
^ EPA Project Summary
Parts Washing Alternatives Study
United States Coast Guard
Brad Montgomery
This study was conducted to provide
guidance for the United States Coast
Guard (USCG) industrial managers in
choosing cost-effective parts cleaning
chemicals that have minimum environ-
mental and safety impacts. The three
facilities chosen for the study were
Aviation Training Center (ATC), Mobile,
AL; Air Station Cape Cod (ASCC),
Falmouth, MA; and Support Center NY
(SCNY), Governors Island, NY. ATC and
ASCC parts washing applications fo-
cused on cleaning contaminated parts
from aviation operations; SCNY parts
washing applications were directed at
cleaning contaminated parts from sea-
faring vessels. The evaluation of alter-
native parts cleaners included the
following categories: process descrip-
tion; environmental, safety and health
(ESH) impacts; cost analysis; and ma-
terial usage and emission reduction op-
portunities. The following parts cleaners
were evaluated; Penatone 724, Bio
Seven, Safety Kleen 105, and Brulin
815 GD*. All four cleaners are effective
cleaners for the specific applications
described in this evaluation. Penatone
724 is a non-recycled petroleum distil-
late that has been qualified to military
specification PD 680 type II for a parts
cleaner but possesses potential per-
sonnel and environmental concerns.
Bio Seven is an on-site recycled aque-
ous parts cleaner that has minimal ESH
impacts and is currently being tested
* Mention of trade names or commercial products does
not constitute endorsement or recommendation for
to qualify to military specifications.
Safety Kleen 105 is a full service re-
cycled petroleum solvent that has also
been qualified to military specification
PD 680 type II but has potential long-
term hazardous waste liability con-
cerns. Brulin 815 GD is a non-recycled
aqueous alkaline parts cleaner that has
apparent minimal ESH impacts but must
be maintained at a temperature of 140°F
to 160°F for effective cleaning.
This Project Summary was developed
by the U.S. EPA's Risk Reduction Engi-
neering Laboratory, Cincinnati, OH, to
announce key findings of the research
project that is fully documented in a
separate report of the same title (see
Project Report ordering information at
back).
Introduction
Four parts cleaners were chosen for
the alternatives study. The cleaners were
selected from three different Coast Guard
facilities consisting of two aviation cen-
ters, ATC Mobile, AL, and ASCC
Falmouth, MA; and one marine and ground
support facility, SCNY Governors Island,
NY. The different functions of the sites
selected allowed for a broad study of the
alternative parts cleaners.
Aviation cleaning requirements are dif-
ferent from those of a marine and ground
support facility. Because of the complexi-
ties of an aircraft, it is necessary to divide
aviation cleaning into three distinct cat-
egories. Category one includes tires and
wheels of the aircraft. Category two in-
cludes engine components, and category
three is general aviation equipment. A
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cleaner must be qualified by the USCG
within a specific category for aviation clean-
ing.
The alternatives in the study include a
full-service recycled cleaner (Safety Kleen
105), an on-site recycled cleaner (Bio
Seven), and two non-recycled cleaners
(Penatone 724 and Brulin 815 GD). These
cleaners were selected because of their
high usage level and different chemical
constituents. Safety Kleen 105 and
Penatone 724 have been qualified by the
USCG to military specification PD 680 type
II for parts cleaning in all three aviation
categories. Bio Seven is used to clean
category two and three aviation parts and
is currently being tested for qualification
to military parts cleaning specifications.
These cleaners are classified by category
and application in Table 1.
The detailed report presents each parts
washing cleaner in a similar format to
provide a consistent approach for evaluat-
ing impacts and developing comparison
trends. The format is divided into two main
sections: (1) a discussion and (2)
worksheets. The discussion presents (1)
the step-by-step procedure used in parts
cleaning, (2) environmental impacts or pos-
sible health and safety risks associated
with the cleaner, (3) identifiable costs as-
sociated with using the cleaner, (4) a ma-
terial and emission reduction opportunity
assessment, and (5) summarized conclu-
sion of the parts cleaning process. The
worksheets describe the parts cleaning
activity in quantitative terms and are com-
posed of a process description, process
flow diagram, material balance, calcula-
tions used to derive numerical data, cost
analysis, and material and emission re-
duction options for the process.
Labor cost associated with the cleaning
process is not presented in this report.
There were no significant deviations in
the amount of effort expended on the task
Table 1. Parts Washing Cleaners
Chemical
of cleaning the parts, therefore labor would
not be a deciding factor for the selection
of an alternative cleaner in this study.
A comparison of total costs among the
cleaners should be avoided. The total cost
for a specific cleaner will vary depending
on the materials and surface area of the
contaminated parts being cleaned, geo-
graphical location, and facility preferences.
Procedure
The following is a condensed version of
the categories evaluated for the selected
USCG parts washing alternatives:
Process Description
Process location, summary of the
operations performed, equipment,
process controls, and a material
balance to include products, input
materials, and the waste streams
affected.
ESH Impacts
Associated regulatory requirements
and impacts of using the cleaner at
the facility.
Cost Analysis
Divided into the following sections:
(1) material and equipment ac-
quisition, (2) inputs and outputs such
as utilities and effluents, and (3) ESH
cost-related impacts.
Material and Emission Reduction
Opportunities
Identify opportunities that offer real
potential to minimize waste and
reduce costs. A detailed evaluation of
technical and economic feasibility is
labor intensive, therefore the proposed
opportunities should be screened to
identify high priority opportunities.
Conclusion
Decisions on improvement options
should be based on the conclusions
developed in the evaluation.
The detailed report contains an outline
with worksheets for each category listed
Category
Application
Safety Kleen 105
Penatone 724
Bio Seven
Brulin 815GD
Full Service Recycle:
Petroleum Distillates
Non-Recycle:
Petroleum Distillates
On-Site Recycled:
Aqueous - Mild
Non-Recycle:
Aqueous - Alkaline
Aviation:
Categories one, two, and
three
Aviation:
Categories one, two, and
three
Aviation:
Categories two and three
Marine and Ground Support:
No restrictions
above. This procedure can be used for
future evaluations on other parts washing
alternatives.
Discussion of Results
Process Description
The contaminated parts were divided
into two areas: (1) aviation operations and
(2) seafaring vessels. The USCG facilities
ATC and ASCC provided information re-
garding the cleaning of contaminated parts
from aviation operations. The aviation parts
cleaned were from Dauphin Helicopters
(HH-65), Jayhawk Helicopters (HH-60),
and Falcon Jets (HU-25). SCNY provided
information regarding the cleaning of con-
taminated parts from seafaring vessels.
The marine parts cleaned were from high
endurance cutters, buoy tenders, bay class
icebreakers, harbor tugs, search and res-
cue utility boats, and ferry boats. The parts
cleaned were from periodic maintenance
or routine repair operations. The contami-
nants that were typically removed from
the parts consisted of grease, oil, dirt, and
hydraulic fluid.
The ATC uses a petroleum distillate,
Penatone 724, and an aqueous surfac-
tant, Bio Seven, to clean aviation parts.
Penatone 724 is currently being used in
two separate parts cleaning processes:
(1) an aerosol canister to spot-clean vari-
ous contaminated parts and (2) the com-
plete immersion and saturation of the
contaminated part with the cleaning sol-
vent in an open container. Approximately
80% of the Penatone 724 is used for the
immersion and saturation procedure with
the remaining 20% used for aerosol clean-
ing. The parts are typically wiped down
after cleaning with a disposable hand towel
or an absorbent cloth to remove traces of
contaminants and solvent. The cleaned
parts are allowed to air dry.
ATC has three separate parts cleaning
stations using the cleaner Bio Seven. Each
station contains a polyethylene parts wash-
ing tank that is designed to hold approxi-
mately 36 gal of cleaning solution, which
is a 50/50 mixture of Bio Seven and po-
table water. The cleaning solution is heated
in the holding tank to the temperature
range of 96°F to 104°F and is continu-
ously recirculated as parts are being
washed. The contaminants are removed
from the parts by manual brushing. The
contaminants are washed away with the
cleaning solution into the enclosed sec-
tion of the tank. The parts cleaning pro-
cess is followed by a water rinse to remove
any residual cleaner and contaminants
from the parts. The parts are then wiped
dry.
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The ASCC has three parts washing sta-
tions located in the aircraft maintenance
hanger that use Safety Kleen 105. Each
parts washing station has approximately
30 gal of the cleaning solvent in a holding
tank located below the parts washing ba-
sin. The cleaning solvent is pumped from
the holding tank, through a discharge tube,
onto the part, and drains back into the
holding tank. The technician removes the
contaminants by holding the part under
the discharge tube and scrubbing or rub-
bing the part with a brush or gloved hand.
The contaminants drain into the holding
tank along with the cleaning solution. The
parts do not require any rinsing or further
use of different chemicals to complete the
cleaning process. The parts are typically
wiped down with a disposable hand towel
or an absorbent cloth to remove traces of
contaminants and solvent and then al-
lowed to air dry.
Brulin 815 GD is currently being used in
the industrial motor repair shop at SCNY.
The parts cleaning solution is a mixture of
20-50% Brulin 815 GD in potable water
and is contained in an insulated 1,200 gal
capacity tank. The percentage of Brulin
815 GD in the potable water is important
in that the higher the concentration the
better removal efficiency of heavy con-
taminants (grease, high viscosity oil). The
cleaning solution is maintained at a tem-
perature of 140°F to 160°F. The contami-
nated parts to be cleaned are placed in a
metallic basket and then lowered into the
tank by a mechanical hoist. The cleaning
solution is not agitated in the tank and
there is no manual brushing of the con-
taminated parts to stimulate the removal
of the contaminants. The contaminated
parts soak in the cleaning solution for
periods of 4 to 12 hours. The parts clean-
ing processes is followed by a steam rins-
ing to remove any residual cleaner and
contaminants from the parts. The cleaned
parts are then hand wiped to quicken the
drying time.
ESH Impacts
Penatone 724 is composed of aliphatic
hydrocarbons (classified as 100% volatile
organic compounds) and is a combustible
material. Safety Kleen 105 is also a com-
bustible material that contains petroleum
distillates and trace quantities of perchlo-
roethylene and 1,1,1-trichloroethane. The
volatility of the two cleaning solvents re-
quires personal protective equipment
(gloves, glasses, etc.). Hand towels that
contain residual Penatone 724 or Safety
Kleen 105 are not considered hazardous
waste in the state of Alabama or Massa-
chusetts. The used towels should be put
into a proper waste disposal container with
the lid tightly covered. Penatone 724 and
Safety Kleen 105 vapors are heavier than
air. Local fire codes may also restrict use
of these cleaners. There are a multitude
of potential health hazards associated with
the use of the two cleaning solvents. Eye
contact with liquid or exposure to vapors
may cause mild to moderate irritation. Skin
contact may cause redness, dryness,
cracking, burning, or dermatitis. Inhalation
or ingestion may cause central nervous
system effects and cause nausea, vomit-
ing, and in severe cases, death.
Bio Seven is a clear, free-flowing sur-
factant that contains no listed hazardous
ingredients. Brulin 815 GD is a blue-green
blend of detergents, alkaline builders and
inhibitors that contains no phosphates and
has no listed hazardous ingredients. Both
Bio Seven and Brulin 815 GD are soluble
in water, biodegradable, nonflammable,
and will not support combustion. Bio Seven
and Brulin 815 GD are considered to have
minimal health hazards associated with
their usage.
Cost Analysis
The annual cost of each cleaner (Table
2) was based on information provided by
the USCG facility and was geographically
dependent. Costs were divided into three
separate sections: (1) material acquisition,
(2) inputs and outputs, and (3) ESH im-
pacts. Material and equipment acquisition
includes initial start-up costs and annual
costs. The input and output costs included
items that were identified through a mate-
rial balance on each of the parts cleaning
processes (e.g., energy, water, hand wipe
towels, hazardous waste disposal). Cer-
tain input and output items did not have
any identified cost for this evaluation.
Material and Emission
Reduction Opportunities
Penatone 724 contains volatile organic
compounds (VOCs) at a concentration
level of 780 g/L of solution. Because of
the volatility of the cleaning compound,
much of the solution is lost through evapo-
ration. VOCs are not an issue with the
ATC since the state of Alabama does not
currently restrict the amount of VOCs al-
lowed to be dissipated into the environ-
ment from this type of parts cleaning
process. Other locations may have regu-
lations to reduce VOC emissions such as
(1) best available control technology re-
quirements or (2) a usage permit with
fees based on the amount of releases into
the atmosphere. An alternative to the cur-
rent immersion cleaning procedure used
at ATC would be to use an enclosed parts
cleaning station for the cleaning solvent.
The station would be designed for the
containment of the solvent with a cover to
reduce losses through evaporation. The
parts cleaning station could extend the
usage life of the cleaning solvent and sig-
nificantly reduce environmental releases.
The annual loss of the Bio Seven clean-
ing solution is about 25%, primarily due to
"drag-out" and evaporation. Drag-out is
the liquid residual on the part after it has
been removed from the cleaning station.
The water and cleaning solution from the
rinsing process could be captured and
utilized as makeup for the losses incurred
by drag out and evaporation.
Safety Kleen 105 and Penatone 724
have environmental and heath risks asso-
ciated with their usage. Efforts should be
taken to find a viable cleaner that would
reduce these risks for the parts cleaning
operations. Potential candidates to replace
the petroleum distillates could be Bio
Seven and Brulin 815 GD.
A material reduction opportunity for the
Brulin 815 GD parts cleaning process
would be to establish a continuous filtra-
tion system to separate the contaminants
from the cleaning solution. Approximately
575 Ib (64 gal) of Brulin 815 GD is used
as makeup for the losses incurred through
the removal of the sludge from the parts
washing tank. This is about 47% of the
total annual usage of the Brulin 815 GD
parts cleaner. A cost savings of $600
would result from the elimination of Brulin
815 GD in the sludge. The total weight for
the sludge could be reduced by 75% with
the separation of the cleaner from the
contaminants. This reduction would have
a cost savings of $458 annually. The
"mucking" out the tank and removal of the
sludge would be reduced to every 3 yr.
The total savings associated with the use
of a continuous filtration unit, including
any water losses, would be almost $1,100
annually.
Conclusions
Penatone 724 is qualified to military
specification PD 680 type II as a parts
cleaner. Penatone 724 can clean in all
three aviation parts cleaning categories
(engine components, general aviation
equipment, and tires and wheels). Con-
cerns about using the cleaning solvent
focus on the potential ESH impacts.
The ATC is presently using Bio Seven
as a test solution for cleaning engine com-
ponents and general aviation parts. Bio
Seven is designated as a test solution
because at the time of this report it does
not have a military specification. Plans
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Table 2. Regulatory and Cost Factors
Penatone 724
Bio Seven
Safety Kleen 105
Brulin 815 GD
Regulatory Requirements
OSHA
RCRA
TSCA
SARA, Title III
section 311,312
Cost
Material & Equipment Acquisition
Start-Up
Annual Contract Fee
Annual Operating
Inputs and Outputs
Energy
Water Usage
Atmospheric Emissions3
Liquid Effluent
Solid Waste
Environmental, Safety & Health
Personal Protective Equipment
Total Start-UP Cost
Total Annual Operating Cost
Annual Contaminated Parts
Cleaned (pounds)5
Combustible
Hazardous Waste
Listed Ingredients
Listed Ingredients
$1,945
None
$555
None
None
None
($3)"
$1,200
$268
$1,945
$2,020
1,000
None
None
None
None
$3,363'
$1,440
$225
$198
$100
None
None
$400
$160
$3,363
$2,523
300
Combustible
Hazardous Waste
Listed Ingredients
Listed Ingredients
$4,000
$4,000 2
None
None
None
None
None
$400
$340
$4,000
$4,740
2,000
None
None
None
None
$3,410
None
$2,093
$6,887
$216
None
None
$709
$96
$3,410
$10,001
60,000
11ncludes three cleaning stations.
2 Contract cost for five cleaning stations.
3 here was no identifiable cost for the atmospheric emissions.
4 ATC Mobile, AL, sells the waste solvent at $0.03/gal to an Energy Recovery Company.
5 Due to the differences in materials and surface area of the contaminated parts being cleaned by the USCG facilities, the annual weight should not be used
as a comparison between facilities. It is presented in this chart to provide an approximation ofcost/lb of contaminated parts within a specific facility.
are in progress to classify the cleaner as
a Navy soap. This classification would
qualify the cleaner to the Mil-C-85570,
type II specification when approval has
been granted. One concern with the use
of Bio Seven is the potential to cause
hydrogen embrittlement. Hydrogen
embrittlement is the degradation of high
strength steels, such as aluminum and
magnesium, that are used as bearings
and bolts on aircraft wheels. Bio Seven is
a viable cleaner for aviation parts clean-
ing categories two and three (engine com-
ponents and general aviation equipment)
but should not be used to clean category
one (tires and wheels) aviation parts until
its potential to cause hydrogen
embrittlement has been determined.
Safety Kleen 105 is also qualified to
clean all three aviation categories (engine
components, general aviation equipment,
and tires and wheels). Potential long-term
liability risks for the Coast Guard are in-
creased with continued use of this parts
cleaner. If Safety Kleen Corporation uses
poor practices in the recycling process,
the USCG could be responsible for pay-
ing any cost incurred to remediate the
resulting environmental contamination.
Safety Kleen Corporation completes the
hazardous waste manifests, but the USCG
is on record for the purchase and genera-
tion of the solvent waste.
The industrial motor repair shop at
SCNY has cleaned over 60,000 Ib of con-
taminated parts with the Brulin 815 GD
solution. The cleaner has proven to be
effective at removing contaminants from
the various ship parts located on the is-
land. Important factors in using the Brulin
815 GD as a parts cleaner are the solu-
tion temperature, concentration, and soak-
ing time. Operational experience indicates
that for the Brulin 815 GD to be an effec-
tive parts cleaner at SCNY, the tempera-
ture must be at least 140°F with the
concentration of Brulin greater than 20%
and a soaking time of at least 4 hr if there
is no agitation. Brulin 815 GD is consid-
ered to be a relatively benign solution and
requires minimal environmental monitor-
ing. The cleaning solution possesses no
significant ESH concerns. Efforts should
be taken to ensure that the discharge of
the cleaner into the sewer system does
not require any pretreatment by local wa-
ter treatment facilities.
The full report was submitted in fulfill-
ment of Contract No. 68-C4-0020, Work
Assignment 0-03, by Lockheed Environ-
mental Systems and Technologies, under
the sponsorship of the U.S. Environmen-
tal Protection Agency.
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Brad Montgomery is with Lockheed Environmental Systems and Technologies,
Las Vegas, NV89119.
James Bridges is the EPA Project Officer (see below).
The complete report, entitled "Parts Washing Alternatives Study United States
Coast Guard,"(OrderNo. PB95-166146; Cost: $19.50, subject to change)
will be available only from
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Telephone: 703-487-4650
The EPA Project Officer can be contacted at
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency
Cincinnati, OH 45268
United States
Environmental Protection Agency
Center for Environmental Research Information
Cincinnati, OH 45268
Official Business
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