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 140F
to 160F 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 96F  to 104F 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 140F to 160F. 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  140F 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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