Revision 0 -11/07/01
ElV
arc
Concurrent
Technologies
Corporation
U.S. Environmental Protection Agency
Environmental Technology Verification Program
For Metal Finishing Pollution Prevention Technologies
Verification Test Plan
Evaluation of KCH Services, Inc. Automated Covered Tank
System for Energy Conservation (ACTSEC)
Concurrent Technologies Corporation is the Verification Partner for the EPA ETVMetal
Finishing Pollution Prevention Technologies Center under EPA Cooperative
Agreement No. CR826492-01-0.
Revision 0
November 7,2001
-------
Revision 0 - 11/07/01
ejY
CPC
Concurrent
Technologies
Corporation
U.S. Environmental Protection Agency
Environmental Technology Verification Program
For Metal Finishing Pollution Prevention Technologies
Verification Test Plan
Evaluation of KCH Services, Inc. Automated Covered Tank
System for Energy Conservation (ACTSEC)
Revision 0
November 7, 2001
i
-------
Revision 0 - 11/07/01
TITLE: Environmental Technology Verification Program for Metal Finishing
Pollution Prevention Technologies Verification Test Plan for the Evaluation
of KCH Services, Inc. Automated Covered Tank System for Energy
Conservation (ACTSEC).
ISSUE DATE: November 7, 2001
DOCUMENT CONTROL
This document will be maintained by Concurrent Technologies Corporation (CTC) in accordance
with the EPA Environmental Technology Verification Program Quality and Management Plan
for the Pilot Period 1995-2001 (EPA/600/R-98/064). Document control elements include unique
issue numbers, document identification, numbered pages, document distribution records,
tracking of revisions, a document MASTER filing and retrieval system, and a document
archiving system.
ACKNOWLEDGMENT
This is to acknowledge Joe Candio, Rick Hall, Tom Lopresti, P.E., David Allen, Jim Totter,
Marvin South, and Valerie Whitman for their help in preparing this document.
Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
Finishing Pollution Prevention Technologies Center under EPA Cooperative
Agreement No. CR826492-01-0.
li
-------
Revision 0 - 11/07/01
Environmental Technology Verification Program for Metal Finishing Pollution Prevention
Technologies Verification Test Plan for the Evaluation of KCH Services, Inc. Automated
Covered Tank System for Energy Conservation (ACTSEC).
PREPARED BY:
Kin Hunktnjon
KCH Services, Inc.
it - i 3 - 200 /
I 'sm Eskamani Date
k / 'K-Atf Project Manager
Smttmmmr ' DSte
CTC Project Manager
APPROVED BY:
——— / */iC/& /
Clinton Twlley / " ' Date
CTC (M Manager
' ^/tWK /// S) 0 /
Dimn Brawn / Dfffc
CTC F71 -.'W/Vogrtw? Ma»Jog
-------
Revision 0 - 11/07/01
TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 Background 1
1.2 Data Quality Objectives (DQO) 3
2.0 TECHNOLOGY DESCRIPTION 4
2.1 Theory of Operation 4
2.2 Description of KCH System 6
2.3 Commercial Status 9
2.4 Environmental Significance 9
2.5 Local Installation 9
3.0 EXPERIMENTAL DESIGN 10
3.1 Test Goals and Objectives 10
3.2 Critical and Non-Critical Measurements 10
3.3 Test Matrix 10
3.4 Testing and Operating Procedure 11
3.4.1 Set-up and System Initialization Procedures 11
3.4.2 System Operation 12
3.4.3 Sample Collection and Handling 12
3.4.4 Process Measurements and Information Collection 12
3.4.4.1 Electrical Power Requirement Test #1 12
3.4.4.2 Electrical Power Requirement Test #2 13
3.4.4.3 Electrical Power Requirement Test #3 13
3.4.4.4 Electrical Power Requirement Test #4 13
3.4.4.5 Electrical Power Requirement Test #5 14
3.4.4.6 Ventilation Flow Rate Test #6 14
3.4.4.7 Ventilation Flow Rate Test #7 15
3.4.4.8 Energy and Cost Data 15
3.5 Analytical Procedures 16
4.0 QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS 16
4.1 Quality Assurance Objectivies 16
4.2 Data Reduction, Validation, and Reporting 16
iv
-------
Revision 0 - 11/07/01
4.2.1 Internal Quality Control Checks 16
4.2.2 Calculation of Data Quality Indicators 17
4.2.2.1 Precision 18
4.2.2.2 Accuracy 18
4.2.2.3 Completeness 19
4.2.2.4 Comparability 19
4.2.2.5 Representativeness 19
4.2.3 Other Calculations 20
4.2.3.1 Energy and Cost Savings 20
4.2.3.2 Environmental Benefit/Credit 23
4.3 Quality Audits 24
5.0 PROJECT MANAGEMENT 24
5.1 Organization/Personnel Responsibilities 24
5.2 Test Plan Modifications 24
6.0 EQUIPMENT AND UTILITY REQUIREMENTS 25
7.0 ENVIRONMENTAL SAFETY AND HEALTH (ES&H) REQUIREMENTS 25
7.1 Hazard Communication 25
7.2 Emergency Response Plan 25
7.3 Hazard Controls and Personal Protective Equipment 25
7.4 Lockout/T agout Program 26
7.5 Material Storage 26
7.6 Safe Handling Procedures 26
8.0 WASTE MANAGEMENT 26
9.0 TRAINING 26
10.0 REFERENCES 27
11.0 DISTRIBUTION 28
v
-------
Revision 0 - 11/07/01
LIST OF FIGURES
Figure 1. Landing Gear 2
Figure 2. KCH ACTSEC Technology at Goodrich 3
Figure 3. Vented Tanks with Covers 4
Figure 4. Diagram of Vented Tanks 5
Figure 5. Ductwork for Exhaust System 6
Figure 6. KCH ACTSEC Electrical Control Cabinet 7
LIST OF TABLES
Table 1. Tank Volume & Contents 5
Table 2. Goodrich Titanium Wash and Etch Line Ventilation 9
Table 3. Test Matrix 11
Table 4. Test Objectives and Related Test Measurements 11
Table 5. QA Objectives 16
Table 6. Reliable Power Meter 1600 Tolerances 18
Table 7. Alnor AXD MicroManometer Tolerances 19
LIST OF APPENDICES
APPENDIX A: Goodrich Aerospace, Landing Gear Division O&M Manual A-l
APPENDIX B: Test Plan Modification Request B-1
APPENDIX C: ETV-MF Operation Planning Checklist C-l
APPENDIX D: Job Training Analysis Form D-1
APPENDIX E: ETV-MF Project Training Attendance Form E-1
APPENDIX F: Field Data Collection Worksheet F-l
vi
-------
Revision 0 - 11/07/01
ACRONYMS & ABREVIATIONS
°c
Degrees Celsius
°F
Degrees Fahrenheit
ACGIH
American Conference of Governmental Industrial Hygienists
ACTSEC
Automated Covered Tank System for Energy Conservation
AMCA
Air Movement and Control Association
amp
Ampere
BHP
Brake Horsepower
CFM
Cubic Feet per Minute
cm
Cubic Meter
CS
Cost Savings
CSA
Canadian Standards Institute
CTC
Concurrent Technologies Corporation
DQO
Data Quality Objectives
EHS
Environmental, Health and Safety
EPA
U.S. Environmental Protection Agency
ERP
Emergency Response Plan
E.S.
Energy Saved
ES&H
Environmental Safety and Health
ETV
Environmental Technology Verification
ETV-MF
Environmental Technology Verification Program Metal Finishing
Technologies P2
FCC
Federal Communications Commission
fpm
Feet per Minute
fs
Full Scale
ft
Foot
ft2
Square Foot
gal
Gallon
GB
Gigabyte
HP
Horsepower
hr
Hour
HV
Heating and Ventilation
Hz
Hertz
ID
Identification
JTA
Job Training Analysis
kHz
Kilohertz
kpa
Kilopascals
kW
Kilowatt
kWh
Kilowatt-hour
L
Liter
MB
Megabyte
min
Minute
MSDS
Material Safety Data Sheet
O&M
Operation and Maintenance
OSHA
Occupational Safety & Health Administration
vii
-------
Revision 0 - 11/07/01
ACRONYMS & ABREVIATIONS (continued)
p
Percent Recovery
PARCCS
Precision, Accuracy, Representativeness, Comparability,
Completeness, Sensitivity
PEL
Permissible Exposure Limit
PLC
Programmable Logic Controller
POTW
Publicly Owned Treatment Works
PPE
Personal Protective Equipment
psi
Pounds per Square Inch
QA
Quality Assurance
QC
Quality Control
QMP
Quality Management Plan
RMS
Root Mean Square
SOP
Standard Operating Procedure
SR
Sample Result
SSR
Spiked Sample Result
STEL
Short Term Exposure Limit
TCS
Total Cost Savings
TLV
Threshold Limit Value
TSA
Technical Systems Audit
TWA
Time Weighted Average
UL
Underwriters Laboratory
U.S.
United States
V
Volt
VAC
Volts Alternating Current
VDC
Volts Direct Current
wg
Water Gauge
viii
-------
Revision 0 -11/07/01
1.0 INTRODUCTION
The purpose of this test plan is to document the objectives, procedures, equipment, and
other aspects that will be utilized at the Goodrich Aerospace, Landing Gear Division,
Tullahoma, Tennessee, facility during the verification testing of the KCH Services, Inc.
(KCH) Automated Covered Tank System for Energy Conservation (ACTSEC) Project.
This test plan has been prepared in conjunction with the U.S. Environmental Protection
Agency's (EPA's) Environmental Technology Verification Program for Metal Finishing
Pollution Prevention Technology (ETV-MF). The results of the verification test will be
documented in a verification report that will provide objective performance data to metal
finishers, environmental permitting agencies, and industry consultants.
The objective of this test plan is to verify whether this technology lowers the power
consumption compared to a system with open tanks. Goodrich Aerospace, Landing Gear
Division, has implemented a plan to reduce both the energy consumed and the employee
exposure to contaminants from the washing and acid etching lines.
This project will evaluate the effectiveness of the energy conservation system.
Evaluating and verifying the performance of the KCH ACTSEC technology will be
accomplished by collecting operational data and electrical and ventilation measurements.
The resultant test data will be used to determine the power consumption of the various
motors, fans, and immersion heaters associated with the process.
This test plan has been structured on a format developed for ETV-MF projects. This
document describes the intended approach and explains testing plans with respect to areas
such as test methodology, procedures, parameters, and instrumentation. Also included in
this plan are Quality Assurance/Quality Control (QA/QC) requirements of this task that
will ensure the accuracy of data, the use of proper data interpretation procedures, and an
emphasis on worker health and safety considerations.
1.1 Background
Goodrich Aerospace, Landing Gear Division, is a part of the Goodrich Aerospace
Corporation. It has a distinguished history dating back to 1926, when the Cleveland
Pneumatic Company, now part of Goodrich, introduced the industry's first air-oil landing
gear strut. Goodrich merged with Menasco in 1999 to become the world's largest supplier
of landing systems. The Tullahoma facility manufactures components for landing gear
for various aircraft including Boeing, Lockheed Martin, and Bombardier. The material of
choice is aircraft-quality titanium. Titanium is stronger than steel and is considerably
lighter. This metal is well suited for this application.
The parts processed on the wash and etch line are designated as 777 Landing Gear Truck
Beams. Due to the nature of the use of this part, it is critical that the part be thoroughly
checked to ensure hat it will not fail in service. The part is washed and etched to aid in
checking for cracks and fissures of any size. After the wash and etch process, a dye is
applied to the part. The dye helps to more readily identify component cracking as part of
the QC process. If the part passes this QC check, it then proceeds to heat treat. After
1
-------
Revision 0 -11/07/01
heat treat, the part is etched again and checked for cracks and fissures that may have
developed during the further processing. The first etch removes approximately .001 of an
inch of material all over the part. The second etch removes approximately .002 - .003 of
an inch. Pictures of the finished product are shown in Figure 1.
Power is consumed to energize the fans that provide the negative air movement to
remove the air contaminants coming from the wash and etch baths. Also, a scrubber fan
that moves exhaust through the scrubber consumes power. Additional power is
consumed during the opening and closing of the lids over the wash and acid etching
baths, to maintain the required temperature of the baths, and to operate the crane utilized
to move the parts on racks to and from the various wash and acid etching line baths.
When operating etch process tanks with the lids closed, there is a leduction in the amount
of air required to ventilate contaminates given off by process chemicals. This results in a
reduction in makeup air required to balance the system. The makeup air reduction results
in a smaller fan and lower heating and cooling cost to properly temper the makeup air.
A reduction in the power demand for this operation will result in energy savings and less
natural resources used. This type of savings is the primary claim of KCH for their
ACTSEC technology, shown in Figure 2.
Figure 1. Landing Gear
2
-------
Revision 0 -11/07/01
Figure 2. KCH ACTSEC Technology at Goodrich
The Occupational Safety and Health Administration (OSHA) has specific standards for
situations where employees may be exposed to harmful materials. The standard requires
that calculations or monitoring be done to ascertain the levels of contaminants that an
employee will be exposed to in correlation to an eight-hour typical work shift. If the
level of the contaminant is above the Permissible Exposure Limit (PEL), the facility must
provide engineering controls such as ventilation, restrict the time the worker is exposed to
the contaminant, or provide personal protective equipment (PPE) that will decrease the
exposure level to the employee below the PEL. Evaluating the exposure to employees is
not the focus of this verification test plan.
Goodrich Aerospace, Landing Gear Division, commissioned an industrial hygiene survey
by their insurance carrier, Liberty Mutual. [Ref. 1] Mr. Mchael A. Schepige, CIH, CSP,
conducted the industrial hygiene survey for the entire facility on March 29, 2001. The
survey concluded that the calculated 8-hour time weighted average (TWA)
concentrations of airborne contaminants were below their respective 8-hour TWA OSHA
PELs, ACGIH-Threshold Limit Value (TLVs), and 15-minute TWA Short Term
Exposure Limit (STEL). There are no activities within the scope of verification testing
that would necessitate ETV-MF staff to be in close vicinity of the Titanium Wash and
Etch process. For purpose of implementing the KCFI verification test, all project
personnel shall adhere to Goodrich safety guidelines and procedures.
1.2 Data Quality Objectives (DQO)
The systematic planning elements of the data quality objectives process identified in
"Guidance for the Data Quality Objectives Process" (EPA QA/G-4, August 2000), were
specifically utilized during preparation of this verification test plan. The project team is
composed of representatives from CTC, the testing organization, the technology vendor,
the host site, and EPA. Each assisted in preparing the test plan, which includes test
objectives; critical and non-critical measurements; test matrix; sample quantity, type, and
3
-------
Revision 0 -11/07/01
frequency; analytical methods; and QA objectives. The result is an optimized test
designed to verify the performance of the technology.
2.0 TECHNOLOGY DESCRIPTION
2.1 Theory of Operation
The KCH ACTSEC technology is a system designed to provide an efficient removal of
air contaminants from the work place at a reasonable cost and at a level that minimizes
the overall power consumption and exhaust volume to the air pollution control device.
This installation is set up as one semi-automated process control system. The process is
wash and etch of titanium parts. The lids and exhaust are automated. All vented tanks
are fitted with covers that open and close (see Figure 3) as the hoist moves over the tank
to load or unload parts for washing or etching. The line is exhausted via its own exhaust
system, comprised of a scrubber and blower.
Closed Lids Open Lid
Figure 3. Vented Tanks with Covers
Each vented tank (see diagram in Figure 4) has two lateral exhaust hoods, each with its
own volume damper. The volume dampers are interlocked with the tank covers and open
and close at the same time. This allows for an increase in airflow through the hoods as
required when the covers are in the open position.
The exhaust system has one bleed-in air control damper located between the line hoods
and the scrubber that opens and closes as required to compensate for the fluctuation in
static pressure due to the opening and closing of the tank covers and hood dampers. This
maintains a constant volume and static pressure through the scrubber and fan.
The system provides a constant volume with a slight negative airflow in the room.
Makeup air is brought in from the outside, tempered, and distributed in the room along
the length of the line.
4
-------
Revision 0 -11/07/01
Heated tanks: 911,913 and Hot Rinse
Tanks are 4 ft wide x 14 ft long x 8 ft deep
Ventilation to Scrubber
Figure 4. Diagram of Vented Tanks
Tank#
Contents
Volume
913
Nitric Acid
40 gal
Hydrofluoric Acid
4 gal
Water
2896 gal
914
Deionized Water
Tank Fill
918
Nitric Acid
10 gal
Hydrofluoric Acid
3 gal
Water
2927 gal
Table 1. Tank Volume & Contents
5
-------
Revision 0 -11/07/01
2.2 Description of KCH System
One automated metal wash and acid etch line in a layout that spans approximately fifty
feet was installed at Goodrich Aerospace, Landing Gear Division, during the course of
the fall and winter of 2000. The line consists of process tanks with a ventilation system.
The process system is intended to meet EPA Method 9 Visible Emissions, Tennessee Ar
Pollution Control Board Permit, and OSHA requirements. Each process tank dimension
is 14 ft long by 4 ft wide by 8 ft deep. OSHA requirements for ventilation are derived
from the American Conference of Governmental Industrial Hygienists (ACGIH)
Industrial Ventilation design manual [Ref. 2], Conventional ventilation would require a
total exhaust flow rate of 50,120 cubic feet per minute (CFM). With the addition of the
lids and semi-automated control to coordinate the opening and closing operation, the
ventilation requirements drop down to 17,612 CFM. This reduces the air volume of the
exhaust system and its equipment. The external ductwork for the systems exhaust is
shown below (see Figure 5).
Figure 5. Ductwork for Exhaust System
The scrubber was designed to remove pollutants so that the facility maintains compliance
with its Construction Air Permit that was issued by the state of Tennessee, Department of
Environment and Conservation, Division of Air Pollution, Permit Number 953204P. The
exhaust system and its equipment are sized smaller for this system than for a similar
system without the benefit of the lids. This is due to the fact that the air volume is lower.
Scrubber differential pressure is manually monitored at the scrubber transitions via a
magnahelic pressure gauge.
The lines are serviced by a semi-automated hoist system. A Programmable Logic
Controller (PLC) controls the lid opening and closing. The hoist movement is under the
6
-------
Revision 0 -11/07/01
control of the operator. In normal operation the PLC activates the opening/closing of
cover and dampers. As the lids open, the bleed-in air damper closes and the hood
dampers open. The operator can manually open or close the cover with a push button
switch, if need arises. The KCH ACTSEC system is fed and controlled from the
Electrical Control Cabinet shown below (see Figure 6).
Figure 6. KCH ACTSEC Electrical Control Cabinet
Volume dampers located in each hood are operated via a pneumatic actuator and adjusted
in the closed position to provide minimal airflow through the hoods when the tank covers
are closed. The bleed-in air control damper is controlled via a pneumatic actuator that
will change the position of the damper to open or closed as required. This is
accomplished with the PLC.
The tanks are maintained at a constant temperature. Additionally, the tanks are
maintained without stratification due to an air sparger system laid out on the bottom of
each tank. This helps to lower the heating costs of the tanks in conjunction with the lid
usage. The lids also minimize the chemical exposure to employees working in the
general vicinity.
KCH claims that this installation has been designed to accommodate one lid opening for
entiy or exit of the processing parts while maintaining sufficient ventilation for
Goodrich's Titanium Etch Process.
KCH has completed calculations to determine the necessary airflow on the tanks when
the lids are both open and closed. KCH used engineering calculations to determine the
appropriate airflow to properly control the emission of various pollutants so they will not
7
-------
Revision 0 -11/07/01
be detrimental to the employees or the environment. That basic design concept follows
as shown below.
Ventilation Design Concept
1. All covered tanks are normally closed except when parts are being lowered into or
being lifted from the tank. The exhaust of the covered tanks will, therefore, need
only to be sufficient to prevent fumes from escaping around the perimeter of the
tank. In practice, only 10-25 percent of the total CFM normally required to exhaust
an uncovered or conventional open process tank. This range is based on previous
experience and is calculated by evaluating the actual gaps in square feet along a
tank perimeter versus open tank ventilation requirements.
2. When the tank covers open, the exhaust volume is increased to full industrial
ventilation flow rate, by the automatic opening of the exhaust damper(s) located on
the outlet of the exhaust hood(s).
3. The velocity of the air traveling through the fume control device (horizontal
scrubber) must remain constant in order to ensure proper operation and control.
Therefore, a secondary device, an automatic relief damper, is needed to maintain a
constant flow rate through the control device. The relief damper is installed
upstream of the control device and downstream of the tankline exhaust manifold.
The relief damper serves to maintain constant velocity by introducing bleed-in air
when all tanks are closed.
4. The total exhaust system sizing is based upon the assumption that all covers are in
the closed position except one tank, the worst-case tank. In this case, the worst case
tank is Tank 913, with a hazard rating of Al. The reasoning for this assumption is
that, since the covers are automatically interlocked to the hood damper(s), and since
our example system has only one hoist, only one cover will be open at any one
time. If the tank line is serviced by two hoists, then two covers could be open at
any one time, and the system would be sized accordingly. Therefore, the system
size is dependent upon the number of hoists on the tankline, assuming that the
worst-case tanks could be open simultaneously, with work being lifted or lowered
into the tanks.
5. The system for Goodrich Aerospace, Landing Gear Division, is sized at
approximately 10 percent of the full open top flow with the addition of the worst-
case exhaust volume of one tank. Therefore, the exhaust for four of the five tanks is
sized at 10 percent of the full tank exhaust rate. The worst-case tank requires
14,000 CFM. The system total becomes 17,612 CFM. Compared against the open
top exhaust flow rate of 50,120 CFM, a savings of 32,508 CFM is realized, which
represents approximately 65 percent energy savings (see Table 2).
8
-------
Revision 0 -11/07/01
Tank
Hazard
Rating*
Area
Sq. Ft.
CFM/
Sq. Ft.
Open Cover
CFM
KCH System Design
CFM
913
A-l
56
250
14000
14000
911
C-l
56
175
9800
980
914
D-l
56
130
7280
728
918
A-l
56
250
14000
1400
H.R.
D-2
56
90
5040
504
Total CFM
50120
17612
* Rating taken from ACGIH, Industrial Ventilation,
Pages 10-96 to 10-98, Table 10.70.1 & 10.70.3, 24th Ed, 2001
Table 2. Goodrich Titanium Wash and Etch Line Ventilation
2.3 Commercial Status
The KCH ACTSEC System is in commercial use in this facility as well as at two similar
facilities. The automated covered tank system was first placed in service in 1997 for a
metal finishing line. This system is readily available for purchase from KCH upon
facility assessment and engineering review.
2.4 Environmental Significance
The KCH ACTSEC technology is employed to:
1. Reduce power consumption compared to a metal finishing system without covers
2. Reduce the evaporation rate of the bath
3. Improve the air quality for the employees working in the area
4. Improve the overall worker safety
5. Reduce the overall pollution from utility sources (e.g. power plants) due to
reduction of the energy requirements
6. Reduce the makeup air required which reduces the size of the makeup air blower
These reductions are due to the efficient use of the lids in conjunction with the
introduction and removal of various parts that are treated. By keeping the lids closed
when there is no need to have them open, the aforementioned environmental significant
issues are achieved.
2.5 Local Installation
The KCH ACTSEC technology is installed at the Goodrich Aerospace, Landing Gear
Division, in Tullahoma, Tennessee. The KCH system was installed to accompany the
new wash and acid etch line at Goodrich. The facility has been utilizing the KCH
ACTSEC technology since startup of this line at the end of 2000. Elie to the new process
configuration at Goodrich, there is no process data available without the KCH ACTSEC
technology. The Operations and Maintenance Manual for the KCH ACTSEC
technology, as installed at Goodrich, is shown as Appendix A.
9
-------
Revision 0 -11/07/01
EXPERIMENTAL DESIGN
3.1 Test Goals and Objectives
The overall goal of this ETV-MF project is to evaluate the ability of the KCH ACTSEC
technology to lower the power consumption needs for the system, and the overall exhaust
flow rate, thereby lowering the overall costs.
The following is a summary of specific project objectives. These will be monitored
under normal operating conditions, with lids open and closed.
• Conduct verification testing to determine the electrical power consumption
1) Monitor the power consumption of the induced draft fan for ventilation
2) Monitor the power consumption of the lid motors
3) Monitor the power consumption of the electric immersion heaters in the baths
• Conduct verification testing to determine the ventilation of the tanks
1) Monitor the ventilation duct for air flow
2) Record and verify the static pressure in duct
• Conduct verification testing to determine operating cost and environmental benefit
3.2 Critical and Non-Critical Measurements
Measurements that will be taken during testing are classified as either critical or non-
critical. Critical measurements are those that are necessary to achieve project objectives.
Non-critical measurements are those related to process control or general background
readings.
Critical Measurements:
• Energy consumed (kilowatt hours (kWh), volts (V) and amperes (amps))
• Airflow (fpm)
• Static pressure in ductwork (wg)
Non-Critical Measurements:
• Temperature of baths (° F)
• O&M observations
3.3 Test Matrix
Tests will be conducted over the course of five days. The conditions for each test are
outlined in Table 3, while test objectives and measurements are summarized in Table 4.
10
-------
Revision 0 -11/07/01
Test Uun
Duration
Conditions
Test Run 1
Six Runs - 60 Minute Test Each
Lids open
Test Run 2
Six Runs - 60 Minute Test Each
Lids closed
Test Run 3
Two Runs - 60 Minute Test Each
Lids closed
Test Run 4
Two Runs - 4 Minute Test Each
Lid actuation cycle
Test Run 5
Two Runs - 60 Minute Test Each
Lids closed
Test Run 6
As Required
Lids closed
Test Run 7
As Required
Lids closed
Table 3. Test Matrix
Test objectives and measurements are summarized in Table 4.
1 est
Test Objectives
Test .Measurement
Test #1
Power Consumption
simulating no KCH
system (Lids open)
Determine power consumption
of immersion heaters for each
the three heated tanks
Amperage draw of heaters
Voltage of heaters
Temperature of bath
Test #2
Power Consumption
Normal operations
Determine power consumption
of immersion heaters for each
of the three heated tanks
Amperage draw of heaters
Voltage of heaters
Temperature of bath
Test #3
Typical Power
Consumption
Determine power consumption
of scrubber water pump motor
Amperage draw of motors
Voltage of motor
Test #4
Typical Power
Consumption
Determine power consumption
of lid motors
Amperage draw of motors
Voltage of motors
Test #5
Typical Power
Consumption
Determine power consumption
of induced draft fan
Amperage draw of motors
Voltage of motor
Test #6
Ductwork Airflow
Determine volumetric airflow
rate compared to reported by
KCH
Air velocity in fpm
converted to volumetric
airflow rate in CFM
Test #7
Ductwork Static Pressure
Determine static pressure
compared to reported by KCH
Water gauge for static
pressure inside exhaust
ductwork
Table 4. Test Objectives and Related Test Measurements
3.4 Testing and Operating Procedure
3.4.1 Set-up and System Initialization Procedures
The maintenance department at Goodrich Aerospace, Landing Gear Division, will
be responsible for assisting in the hookup and removal of the testing device for
electric power evaluation. The operational personnel at Goodrich Aerospace,
11
-------
Revision 0 -11/07/01
Landing Gear Division, will be responsible for assisting with the operation of the
system.
3.4.2 System Operation
The processing line will be operated both with and without parts during
verification testing. For Test #1 and Test #2 each tank will be operated without
parts with both open and closed lid configurations, respectively. For remaining
Tests #3 to #8, the system will be operated with parts whenever possible and
operating conditions will be noted in the Field Data Collection Worksheet or
logbook.
3.4.3 Sample Collection and Handling
There is no chemical sample collection and handling required for this verification
test.
3.4.4 Process Measurements and Information Collection
Process measurements and information collection will be conducted to provide
data on electrical power consumption, ventilation exhaust characteristics, and bath
temperatures. The methods that will be used for process measurements and
information collection are discussed in the following sections. Measurements are
to be recorded on the Field Data Collection Worksheet (see Appendix F).
Electrical measurements will be monitored for a minimum of 60 minutes to
account for variability in the supply. Upon site identification of the most readily
accessible power panel, a properly trained journeyman electrician from Goodrich
Aerospace, Landing Gear Division will perform connection and disconnection for
the monitoring of electrical consumption. Instantaneous measurement and time-
averaged measurement will be recorded
The static pressure and velocity traverse will be taken in two directions across the
duct and averaged. A bath temperature reading will be collected from KCH
display panel during each 60-minute immersion heater test.
3.4.4.1 Electrical Power Requirement Test #1
During the first test, the electric power draw for the immersion heaters
will be monitored for power usage. One tank at a time will be tested to
ensure quality of analysis and to ease work restrictions on the facility.
Three tanks have immersion heaters. They are tanks #911, #913, and Hot
Rinse. Work parameters will be checked with the facility to verify that
this will be considered to be a typical level of usage. The test will run a
minimum of 60 minutes. The test may continue to run longer if the
heaters do not cycle at least two times. These tests will be run in
duplicate. Lids will be kept open for this test.
12
-------
Revision 0 -11/07/01
The analysis will utilize a Reliable Power Meter 1600 Series Power
Recorder or an approved equal to collect data for each test. The data will
be downloaded to a portable computer for compilation.
3.4.4.2 Electrical Power Requirement Test #2
During the second test, the electric power draw for the immersion heaters
will be monitored for power usage. One tank at a time will be tested to
ensure quality of analysis and to ease work restrictions on the facility. As
in Test #1, tanks #911, #913, and Hot Rinse will be used for testing.
Work parameters will be checked with the facility to verily that this will
be considered to be a typical level of usage. This test will be conducted as
the process normally operates. Each test will run the same length as Test
#1 for each heated tank. Each test will be run in duplicate.
The analysis will utilize a Reliable Power Meter 1600 Series Power
Recorder or an approved equal to collect data for each test. The data will
be downloaded to a portable computer for compilation.
3.4.4.3 Electrical Power Requirement Test #3
During the third test, the electric power draw on the scrubber water pump
motor will be monitored for power usage. The scrubber water pump
motor runs continuously, so a sample of 60 minutes will be sufficient to
determine the power consumption. This test will be run in duplicate.
The analysis will utilize a Reliable Power Meter 1600 Series Power
Recorder or an approved equal to collect data for each test. The data will
be downloaded to a portable computer for compilation.
3.4.4.4 Electrical Power Requirement Test #4
During the fourth test, the electrical power draw on the lids will be
monitored for power usage. The lids run the same cycle every time they
open and close. The open and close cycle is relatively brief,
approximately two minutes. The test will be run from the moment that the
lids begin to open, to allow entry of the part, until they close after the exit
of the part. Due to the similarity in lid actuation for all tanks, Tank #911
is selected for testing. This test will be run in duplicate on the tank.
The analysis will utilize a Reliable Power Meter 1600 Series Power
Recorder or an approved equal to collect data for each test. The data will
be downloaded to a portable computer for compilation.
13
-------
Revision 0 -11/07/01
3.4.4.5 Electrical Power Requirement Test #5
During the fifth test, the electrical power draw on the induced draft fan
will be monitored for power usage. This fan runs continuously. The test
will be conducted for 60 minutes. This test will be run in duplicate.
The analysis will utilize a Reliable Power Meter 1600 Series Power
Recorder or an approved equal to collect data for each test. The data will
be downloaded to a portable computer for compilation.
3.4.4.6 Ventilation Flow Rate Test #6
During the sixth test, the airflow in the 32-inch diameter round ventilation
ductwork to the scrubber will be monitored using a manometer in feet per
minute (fpm). The test will be conducted at a point in the ductwork where
there is minimal to no turbulence, which can cause erratic readings.
According to ACGIH the velocity and velocity pressure measurement
ideally are taken at least seven duct diameters downstream from elbows,
duct entries, or other major obstructions to straight-line airflow.
Measurement should be taken at least one duct diameter upstream from
the same obstruction. If it is not possible to find or use a location that
meets those restrictions, one must make do with the best available
location.
Based on this guidance the ductwork will have two sets of holes drilled at
a 90° angle to each, at a distance of approximately 17 ft 8 ^ inches off of
the floor. This will provide an upstream distance of 12 ft 4 inches from
the relief damper to the measurement point. There is a 90° elbow
downstream at 2-ft 8 V2 inches from this measurement point. Ten
measurement points will be taken in each direction with the middle point
thrown out and the remainder points averaged to obtain the reading (see
section below).
The ventilation flow rate Q is obtained by the following formula:
Q = VA
where:
Q = Ventilation Flow Rate (volumetric), CFM
A = Cross-sectional area of duct at the measurement location,
ft2
V = Average velocity normal to the cross-section, fpm
It is important to measure the velocities at several locations chosen to be
representative, and compute the average of those values to estimate the
true average velocity normal to the cross section.
14
-------
Revision 0 -11/07/01
Representative sampling for velocities is specified in the ACGIH
Industrial Ventilation Manual on page 9-9 to page 9-12 [Ref. 2],
For the 3 2-inch diameter round duct the following sample points are
recommended:
TRAVERSE POINTS FOR INSERTION OF PROBE
Probe
Insertion
Point
No. 1
No. 2
No. 3
No. 4
No. 5
MID
No. 6
No. 7
No. 8
No. 9
No. 10
0U
0.61
2.46
4.90
6.9
11.55
16.00
20.45
25.1
27.1
29.5
31.4
90u
0.61
2.46
4.90
6.9
11.55
16.00
20.45
25.1
27.1
29.5
31.4
Traverse points in inches (in) from the inside diameter in two directions at 90 to each
other.
3.4.4.7 Ventilation Flow Rate Test #7
During the seventh test, the static pressure to the scrubber will be
measured using a manometer. Measurements will be recorded in units of
water gauge (wg). The location of the static pressure opening is usually
not too important in obtaining a correct measurement, except that one
should avoid pressure measurement at the heel of an elbow or in areas
where the direction of the velocity component is not parallel with the duct
wall. Two to four holes will be drilled at uniform distances around the
duct for insertion of the probe. This will be done in order to obtain an
average and to detect any discrepancy in value. For field measurement,
one leg of the manometer is open to the atmosphere and the other leg is
connected with tubing held flush and tight against a small opening in the
side of the pipe. The data will be compared with the reported static
pressure as stated by KCH.
Representative sampling for static pressure is described in the ACGIH
Industrial Ventilation Manual on page 9-2 to page 9-3 [Ref. 2],
3.4.4.8 Energy and Cost Data
Due to the absence of historical electricity metrics for the Goodrich
Aerospace, Landing Gear Division a sound method of estimating cost
savings due to energy reductions is described in detail later. The lids open
configuration shall serve to generate baseline data for calculations
pertaining to energy and cost savings.
3.4.4.9 Nameplate Data
Record and compare nameplate data with process measurements to check
for completeness. Data to be collected shall include current draw for fan,
15
-------
Revision 0 -11/07/01
pump, tank heaters, and lid opener/closer. This information shall be
recorded on the Field Data Collection Worksheet (Appendix F).
3.5 Analytical Procedures
No chemical analysis of the samples is required to evaluate the effectiveness of the KCH
ACTSEC technology. The tests involve airflow measurements and electrical
consumption. No chemical samples will be taken.
4.0 QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS
QA/QC activities will be performed according to the applicable section of the
Environmental Technology Verification Program Metal Finishing Technologies Quality
Management Plan (ETV-MF QMP) [Ref. 3],
4.1 Quality Assurance Objectivies
The QA objective is to ensure that the process operating conditions and test methods are
maintained and documented throughout each test. The test methods to be used are listed
in Table 5.
Critical
Measurements
lest Method
Reporting
I nils
Method ol'
Determination
Precision
Accuracy
Completeness
Energy
consumption
I Equipment
Manual
Amps (A)
Reliable Power
Meter 1600 Series
.001A
+2% lull scale
(0 to 5A)
75%
Volts (V)
.1 V
+1% full scale
(0 to 1000V)
Airflow
ACGIH
Industrial
Ventilation Page
9-3 Section 9.2
Feet/Min
(fpm).
MicroManometer
<100 fpm.
+1%
75%
Static Pressure
ACGIH
Industrial
Ventilation Page
9-3 Section 9.2
Water gauge
(wg)
MicroManometer
.005 wg
+1%
75%
* For the Reliable Power Meter, full-scale amperage is 5 Amps and full-scale voltage is 1000 Volts.
From ACGIH Industrial Ventilation Page 9.3, Section 9.2 [Ref. 2]
Table 5. QA Objectives
4.2 Data Reduction, Validation, and Reporting
4.2.1 Internal Quality Control Checks
Raw Data Handling. Raw data are generated and collected by field analysts at the
sampling site. These include original observations, printouts, and readouts from
equipment for sample, standard, and reference QC analyses. Data are collected
both manually and electronically. At a minimum, the date, time, sample
16
-------
Revision 0 -11/07/01
identification (ID), raw signal or processed signal, and/or quantitative
observations will be recorded. Comments to document unusual or non-standard
observations also will be noted.
Raw data will be processed manually by the analyst, automatically by an
electronic program, or electronically after being entered into a computer. The
analyst will be responsible for scrutinizing the data according to precision,
accuracy, and completeness policies. Raw data bench sheets and calculation or
data summary sheets will be kept together for each test. From the standard
operating procedure and the tests, the steps leading to a final result may be traced.
The CTC ETV-MF Program Manager will maintain process-operating data for use
in verification report preparation.
Data Package Validation. The field analyst will assemble a preliminary data
package, which shall be initialed and dated. This package shall contain all QC
and raw data results, calculations, electronic printouts, and conclusions. The field
analyst will review the entire package and check sample and storage logs,
standard logs, calibration logs, and other files, as necessary, to ensure that all
tracking and calculations are correct. After the package is reviewed in this
manner, a preliminary data report will be prepared, initialed, and dated. The QA
Manager will perform data verification and validation following data collection.
The ETV-MF Project Manager shall be ultimately responsible for all final data.
The ETV-MF Project Manger will review the final results for adequacy to task
QA objectives. If the ETV-MF Project Manager suspects an anomaly or non-
concurrence with expected or historical performance values, or with task
objectives for test specimen performance, the raw data will be reviewed, and the
field analyst queried. If suspicion about data validity still exists after internal
review of field records, the ETV-MF Project Manger will authorize a re-test.
Data Reporting. A report signed and dated by the field analyst will be submitted
to the ETV-MF Project Manager. The ETV-MF Project Manager will decide the
appropriateness of the data for the particular application. The final report
contains the field sample ID, date reported, date analyzed, the analyst, the
Standard Operating Procedure (SOP) used for each parameter, the process or
sampling point identification, the final result, and the results of all QA/QC
analysis. The CTC ETV-MF Program Manager shall retain the data packages as
required by the ETV-MF QMP [Ref. 3],
4.2.2 Calculation of Data Quality Indicators
Analytical performance requirements are expressed in terms of precision,
accuracy, representativeness, comparability, completeness, and sensitivity
(PARCCS). Summarized below are definitions and QA objectives for each
PARCCS parameter.
17
-------
Revision 0 -11/07/01
4.2.2.1 Precision
In instalment measurements, precision refers to the smallest change in the
quantity being measured that the instrument will detect. Precision is
ensured by making the proper choice of instruments to make
measurements and by proper maintenance and calibration.
4.2.2.2 Accuracy
Accuracy is a measure of the agreement between an experimental
determination and the true value of the parameter being measured. For the
Reliable Power Meter and Alnor MicroManometer, accuracy will be
ensured by proper maintenance and calibration of the equipment.
The power meter and manometer have tolerances shown in (Tables 6 & 7).
Paramcler
Tolerance
Voltage Range
0-707 volts RMS
Voltage Peak
1000 volts
Voltage Accuracy
1 percent fs, 0.5 percent typical
Sampling Frequency
7.8 kHz, 128 samples/cycle
Frequency Measurement
45-65 Hz, resolution 0.0 Hz
Event Memory
6000 simultaneous voltage and current events
Operating Power
85-264 VAC, 47-440 Hz
120-370 VDC, 40 VA
Thresholds
Automatic, adaptive to activity
No. of Channels
9 (4 voltage, 5 current)
Certification
FCC, UL, CSA, CE
Size
21.25 cm x 30 cm x 7.5 cm
Table 6. Reliable Power Meter 1600 Tolerances
The power meter monitors and records voltage, current, imbalance, frequency,
harmonics, flicker; power quality: sags, swells, impulse; power consumption:
energy, demand, power factor, and reactive power. The unit has a 1-megabyte
(MB) cache, 4 MB RAM, and a 2.1-gigabyte (GB) hard drive for data retention.
This power meter shall be calibrated annually by the factory or an approved
source. The meter will be accompanied with a calibration certificate.
The MicroManometer used for the ventilation airflow measurement shall be
calibrated once a year according to the manufacturer's recommendation. The
calibration of the unit will be verified with the supplier of the unit in writing and
included with the test plan verification information. Unit specifications for the
Alnor AXD 550 MicroManometer are included in Table 7.
18
-------
Revision 0 -11/07/01
Paramcler
Tolerance
Resolution
0.002 inches H20 (-0.998 to 0.998)
Pressure Range
-4 to 20 inches H2O
Velocity Range
179- 17,910 fpm
Volume
Velocity x 78.8 ft max. area
Operating Temperature
14- 122UF
Accuracy
+(1% of indicated reading + 0.01 + resolution)
Display Resolution *
0.01 (0 to 99.99)
(100 to 999.99)
1 (1000 to 9,999)
Over Pressure Limit
20 psi or 137 kpa
* Measured values are stored with better precision
Table 7. Alnor AXD MicroManometer Tolerances
4.2.2.3 Completeness
Completeness is defined as the percentage of measurements judged to be
valid compared to the total number of measurements made for a specific
property under study. A valid measurement is a measurement made by a
properly operating instrument on a properly operating piece of equipment.
As a rule, if the instrument reading is within 25 percent of the equipment
nominal value, the measurement is valid. Completeness is calculated
using the following formula:
Completeness = Valid Measurements x 100%
Total Measurements
QA objectives will be satisfied if the percent completeness is 75 percent or
greater as specified in Table 4.
4.2.2.4 Comparability
Comparability is another qualitative measure designed to express the
confidence with which one data set may be compared to another. Sample
collection and handling techniques, sample matrix type, and analytical
method all affect comparability. Comparability is limited by the other
PARCCS parameters because data sets can be compared with confidence
only when precision and accuracy are known. Comparability will be
achieved in this technology verification by the use of consistent methods
during sampling and analysis.
4.2.2.5 Representativeness
Representativeness refers to the degree to which the data accurately and
precisely represent the conditions or characteristics of a particular
19
-------
Revision 0 -11/07/01
parameter. For the purposes of this cfemonstration, representativeness will
be determined by testing identical points.
For Test #1 through #5, one duplicate electrical measurement will be taken
for each test run component, to determine the representativeness of the
sample. Electrical measurement data will be considered representative if
the relative percent difference between the original measurement and the
field duplicate is 25 percent or less. If the discrepancy is greater than 25
percent, than another measurement will be taken within 30 minutes, under
similar test conditions and matched with the most comparable data point.
For Test #6 and #7 the procedure for representative sampling of airflow
velocity and static pressure is described in section 3.4.4 and the ACGIH
Industrial Ventilation Manual.
4.2.3 Other Calculations
4.2.3.1 Energy and Cost Savings
The energy and cost savings will be evaluated by considering several
system energy and cost components. The components include a reduction
in size of pump and fan motor, reduction in air volume, and reduction in
bath heating requirements. Additionally, operations and maintenance
(O&M) costs shall consider scrubber chemicals, materials (packing,
filters, etc.), and labor. Cost will be annualized and an estimated payback
period calculation will be presented in the verification report.
a) Ventilation fan horsepower
Evaluation of the horsepower required for ventilation of a process
line with the KCH ACTSEC technology as compared to a process
line without the KCH ACTSEC technology is shown below.
Sample Fan Horsepower Calculation:
With the static pressure assumed to be 5.5" water gauge (wg), Air
Movement and Control Association (AMCA) certified KCH data
tables [Ref. 4] can be used to estimate the brake horsepower (BHP)
required for each operating condition using KCH size 60 and size 33
NH fans respectively.
Standard Design BHP:
50,120 CFM = 62 HP (all six tank covers open)
KCH Design:
17,612 CFM = 26 HP (one tank cover open five closed)
20
-------
Revision 0 -11/07/01
This is a reduction of 36 HP.
To estimate the amount of power saved it is necessary to estimate the
amount of time the fan runs. The fan is kept running 24 hours a day/
7 days per week.
The amount of energy savings (ES) for the fan can be determined by:
ESfan = power
time
Sample Annual Energy Savings Calculation for fan:
HP
0.746 kW
24 hours
365 day^
J*
/'
year
Sample Annual Cost Savings Calculation for fan:
The amount of annual cost savings (CS) for the fan can be
determined by:
CSfan =
ESfan
energy cost
time
CSfan =
ESfan
year
Reduction in scrubber size
As the scrubber decreases in size, due to lower CFM throughput, the
amount of water recirculated over the packed bed decreases as well.
A 50,000-CFM scrubber would require a 10 HP pump motor. A
reduction of 5 HP is anticipated based on lower CFM throughput.
The energy savings due to pump size can be calculated in the same
manner as the energy savings for the fan motor shown above. The
same rational holds true for calculation of the cost savings
anticipated for the pump.
These equations and assumptions are taken from "Energy
Conservation & Process Control Utilizing Covered Tanks" by
Kenneth C. Hankinson. [Ref. 5]
Heating and Ventilation (HV) Cost Savings
The facility is climate controlled to maintain uniform process
conditions and uniform working conditions for employees. This
21
-------
Revision 0 -11/07/01
requires that any air drawn in for makeup air must be heated during
the facilities heating season.
One way to estimate annual cost data for airflow is shown on pages
7-18 & 7-19 of the ACGIH Industrial Ventilation Manual [Ref. 2]
and is based on the degree day method. The formula is given as
follows:
CSHv= 0.154 (Q) (dg) (T) (c)
q
where:
CShv =
Q
dg
T
c =
q
Bath Heating Calculations
Electric immersion heaters are provided in three of the tanks to
maintain a temperature above ambient. As the bath cools down, the
PLC will signal the immersion heaters to energize until the
temperature set point is reached in the bath. The Reliable Power
Meter can measure the power consumed while the heater is
energized.
When the lids are open, simulating a tank without lids, the power
consumed by the immersion heaters will be monitored for one hour.
The lids will be closed, and after waiting one hour, the immersion
heater power usage for one hour will be checked. The difference in
the power consumed can be calculated for the year at the electric rate
to determine the savings.
The formula is given as follows:
Ct = {(Pi-P2)(Ce)}{8760}
where:
Ct
Annual cost savings for bath heating
Pi
Power consumed with the lids open
p2
Power consumed with the lids closed
Ce
Cost for electricity in $ per kWh
8760
Hours/year conversion factor
22
Annual Cost Savings
Airflow Rate, CFM
Annual Degree Days
Operating Time, hours/week
Cost of Fuel, $/unit
Available heat per unit of fuel
-------
Revision 0 -11/07/01
Sample Bath Heating Cost Savings Calculation:
Ct =
$
8760 Herfrs
kwjfcKxirs
year
e) Total Cost Savings (TCS)
The TCS represents total savings associated with energy savings due
to the reduction in size of pump and fan motor, reduction in the
volume of air, and reduced heating requirements.
The TCS will be calculated by summing the annualized individual
cost elements including O&M costs and dividing by the total
production capacity, 24 x 7 per year. The TCS will be expressed in
dollars per square feet processed ($/sf).
Capital costs will be considered, with the understanding that they
will vary depending on each KCH ACTSEC application.
TCS = (CSfan+ CSpUmp + CShV+ Q + Co&m)/Pii
where:
CSfan = Cost Savings associated with fan ($)
CSpUmp = Cost Savings associated with pump ($)
CShv = Cost Savings due to ventilation ($)
Ct = Cost Savings for bath heating ($)
Co&m = Cost Savings due to O&M activities ($)
Pn = Production capacity per year, (sf)
4.2.3.2 Environmental Benefit/Credit
As electric power is generated by traditional means, certain pollutants are
emitted to the air. For each kW of power at a power generating plant,
pollutants are emitted at a given level. Any quantified decrease in power
derived from this technology multiplied by a pollutant emission estimate
from a power generation plant will furnish a calculated value for the
amount of pollutant emissions avoided. The following relationship is
valid for calculation of pollutant emissions avoided at a given power plant:
Pollutant saved = kW hour saved x Amount of pollutant
kW
Additionally, as the amount of ventilation is decreased due to the usage of
the lids, the amount of pollutants discharged to the scrubber system will
also decrease. The water that scrubs out the pollutants will have a
corresponding decrease of contaminates that would enter the environment.
23
-------
Revision 0 -11/07/01
4.3 Quality Audits
Technical System Audits. The CTC QA Manager will perform a technical systems audit
(TSA) on this verification test. The EPA QA Manager may conduct an audit to assess the
quality of the verification test.
Corrective Action. Corrective action for any deviations to established QA and QC
procedures during verification testing will be performed according to section 2.10,
Quality Improvement of the ETV-MF QMP [Ref. 3],
PROJECT MANAGEMENT
5.1 Organization/Personnel Responsibilities
The ETV-MF Project Team that is headed by CTC will conduct the evaluation of the
KCH ACTSEC technology. The CTC ETV-MF Program Manager, Donn Brown, will
have ultimate responsibility for all aspects of the technology evaluation. The ETV-MF
Project Manager assigned to this evaluation is Dr. A. Gus Eskamani. Dr. Eskamani or his
designee will be on-site throughout the test period and will conduct or oversee sampling
and related measurements.
Goodrich Aerospace, Landing Gear Division, personnel will assist, as needed, by
providing historical data and identifying the components. Goodrich Aerospace, Landing
Gear Division, will be responsible for the disposal of all residuals generated during the
verification test. The ETV-MF Project Manager or staff member will record samples and
record data from process measurements.
KCH will be on-call during the test period for response in the event of equipment
problems. Goodrich Aerospace, Landing Gear Division, personnel will be responsible
for operation of the KCH ACTSEC equipment, related lines, and ancillary equipment
such as motors, heaters, scrubbers, and blowers/suction systems. Goodrich Aerospace,
Landing Gear Division, personnel will also provide safety training as described in section
9.0 of this test plan.
The ETV-MF Project Manager and Goodrich Aerospace, Landing Gear Division, have
the authority to stop work when unsafe or unacceptable quality conditions arise. The
CTC ETV-MF Program Manager will provide periodic assessments of verification testing
to the EPA ETV Center Manager.
5.2 Test Plan Modifications
In the course of verification testing, it may become necessary to modify the test plan due
to unforeseen events. These modifications will be documented using a Test Plan
Modification Request (Appendix B), which must be submitted to the CTC ETV-MF
Program Manager for approval. Upon approval, the modification request will be
assigned a number, logged, and transmitted to the requestor for implementation.
24
-------
Revision 0 -11/07/01
6.0 EQUIPMENT AND UTILITY REQUIREMENTS
Subcontractors or the ETV-MF Project Manager or his staff will supply test equipment
for all tests. Goodrich Aerospace, Landing Gear Division, will supply necessary power
for test equipment. Goodrich Aerospace, Landing Gear Division, will provide a properly
trained licensed journeyman electrician to perform all electrical supply connections and
disconnects.
7.0 ENVIRONMENTAL SAFETY AND HEALTH (ES&H) REQUIREMENTS
This section provides guidelines for recognizing, evaluating, and controlling health and
physical hazards during the verification test. More specifically, this section specifies the
training, materials, and equipment necessary for assigned personnel to protect themselves
from hazards created by acids and any waste generated by the process.
7.1 Hazard Communication
All personnel assigned to the project will be provided with the potential hazards, signs
and symptoms of exposure, methods or materials to prevent exposures, and procedures to
follow if there is to be potential contact with a hazardous substance. The host facility's
Hazard Communication Program and safety requirements will be reviewed during the
training session described in section 9.0. The training session will be completed prior to
the start of any work and will be practiced throughout the test period. All appropriate
Material Data Safety Sheet (MSDS) forms will be available for chemicals encountered
during testing.
7.2 Emergency Response Plan
Goodrich Aerospace, Landing Gear Division has a contingency plan, (Consolidated
Emergency Response Plan (ERP)) to protect employees, assigned project personnel, and
visitors in the event of an emergency at the facility. This plan will be ised throughout the
project. All assigned personnel will be provided with information about the emergency
response plan during the training session described in section 9.0. The plan will be
accessible to project personnel for the duration of the test.
7.3 Hazard Controls and Personal Protective Equipment
The Goodrich Titanium Wash and Etch process and KCH ACTSEC technology are
located in a secure area within the facility. The wash and etch tanks are covered by the
tank lids, and the KCH Control Panel and associated ductwork are located in the secure
area.
Assigned project personnel will be provided with appropriate PPE and any training
required for its proper use, considering their assigned tasks. The use of PPE will be
covered during a job training analysis (JTA) as indicated in section 9.0.
25
-------
Revision 0 -11/07/01
While in the Goodrich Aerospace, Landing Gear Division, manufacturing facility, PPE
such as eyeglasses with side shields, face shield, hard hat, "rain suit," earplugs, and safety
shoes shall be worn as required.
7.4 Lockout/Tagout Program
The Goodrich Aerospace, Landing Gear Division, Lockout/Tagout Program will be
reviewed prior to testing, and relevant lockout/tagout provisions of the program shall be
implemented. All power testing and measurement to be performed at electrical panels
will be completed by, a properly trained and certified journeyman electrician supplied by
Goodrich Aerospace, Landing Gear Division.
7.5 Material Storage
In accordance with the Goodrich Aerospace, Landing Gear Division, Hazard
Communication Program, any materials used during the project will be kept in proper
containers and labeled according to Federal and state law. Proper storage of the materials
will be maintained based on associated hazards. Spill trays or similar devices will be
used as needed to prevent material loss to the surrounding area. No material storage is
anticipated as part of this project.
7.6 Safe Handling Procedures
All chemicals and wastes or samples will be transported on-site in non-breakable
containers used to prevent spills. Spill kits shall be strategically located in the project
area. These kits contain various sizes and types of sorbents for emergency spill cleanup.
Emergency spill clean up will be performed according to the Goodrich Aerospace,
Landing Gear Division, consolidated ERP. No chemicals, wastes or samples are
anticipated as part of this project.
8.0 WASTE MANAGEMENT
The KCH ACTSEC technology will be tested on processes already in place and operating
at Goodrich Aerospace, Landing Gear Division. This equipment currently generates a
liquid waste, due to rinse water overflow and the scrubber effluent. This rinse water and
the scrubber effluent are treated on-site in a wastewater treatment system. The treated
water is then discharged to the local Publicly Owned Treatment Works (POTW). Any
waste from the baths is treated off-site.
During testing, no additional waste is anticipated to be generated other than the normal
operational waste. Therefore, no special or additional provisions for waste management
will be necessary.
9.0 TRAINING
Environmental, Safety and Health (ES&H) training will be coordinated with Goodrich
Aerospace, Landing Gear Division, and staff. All ETV-MF personnel will undergo
26
-------
Revision 0 -11/07/01
ES&H training provided by Goodrich Aerospace, Landing Gear Division, prior to
initiating the verification test.
Also, the ETV-MF JTA Plan [Ref. 6] will be utilized to identify additional training
requirements relating to QC and worker ES&H. The purpose of this JTA Plan is to
outline the overall procedures for identifying the hazards and quality issues and training
needs. This JTA Plan establishes guidelines for creating a work atmosphere that meets
the quality, environmental, safety, and health objectives of the ETV-MF Program. The
JTA Plan describes the method for studying ETV-MF project activity and identifying
training needs. The ETV-MF Operation Planning Checklist (Appendix C) will be used
as a guideline for identifying potential hazards, and the JTA Form (Appendix D) will be
used to identify training requirements. After completion of the form, applicable training
will be performed. Training will be documented on the ETV-MF Project Training
Attendance Form (Appendix E).
10.0 REFERENCES
1. Liberty Mutual Industrial Hygiene Evaluation conducted March 29, 2001 by Mr.
Michael A. Schepige, CIH, CSP, Sr. Industrial Hygienist
2. American Conference of Governmental Industrial Hygienists, Industrial
Ventilation, 24th Ed., 2001
3. Concurrent Technologies Corporation (CTC), "Environmental Technology
Verification Program Metal Finishing Technologies (ETV-MF) Quality
Management Plan" Revision 1, March 26, 2001.
4. KCH Services, Inc., "Corrosion Resistant Fans," per AMCA Certified Ratings
Program by Kenneth C. Hankinson, November 2001.
5. KCH Services, Inc., "Energy Conservation & Process Control Utilizing Covered
Tanks" by Kenneth C. Hankinson, Tom Brady & Adam Chmielewski, October,
1997
6. Concurrent Technologies Corporation, "Environmental Technology Verification
Program Metal Finishing Technologies (ETV-MF) Pollution Prevention
Technologies Pilot Job Training Plan," May 10, 1999
27
-------
Revision 0 -11/07/01
11.0 DISTRIBUTION
Alva Daniels, EPA (3)
Ken Hankinson, KCH
Rick Hall, KCH
Tommy Stewart, Goodrich Aerospace, Landing Gear Division
David Allen, Goodrich
Gus Eskamani, CAMP, Inc.
Joe Candio, CAMP
Donn Brown, CTC (2)
Scott Maurer CTC
Clinton Twilley, CTC
28
-------
APPENDIX A
Goodrich Aerospace, Landing Gear Division,
KCH ACTSEC Operation & Maintenance (O&M) Manual
-------
144 Industrial Drive
Forest City, N.C. 28043
,r , t rt r , 828-245-9836
' ' FAX: 828-245-1437
Operation and Maintenance
Manual
BF GOODRICH LANDING GEAR DIVISION
TULLAHOMA, TENNESSEE
A-l
-------
m
144 Industrial Drive
Forest City, N.C. 28043
828-245-9836
FAX: 828-245-1437
PACKED BED/COLUMN FUME SCRUBBERS
Fume scrubber's work by using a chemical phenomenon of mass transfer, also called
absorption, which allows gas phase chemicals in the air stream to transfer into a liquid
scrubbing medium. This action will continue as long as the concentration in the liquid is
low enough so that the chemical vapor pressure of the liquid phase is below the vapor
pressure of the chemical in the air stream.
Gas absorption is a mechanism whereby one or more constituents are removed from a
gas stream by dissolving them in a liquid solvent. This is one of the major chemical
engineering unit operations and is treated extensively in all basic chemical engineering
textbooks. Absorption is practiced in industrial chemical manufacturing as an important
operation in the production of a chemical compound. For example, in the manufacture
of hydrochloric acid, one step in the process involves the absorption of hydrogen
chloride gas in water.
From an air pollution standpoint, absorption is useful as a method of reducing or
eliminating the discharge of air contaminants to the atmosphere.
The gaseous air contaminants most commonly controlled by absorption include sulfur
dioxide, hydrogen sulfide, hydrogen chloride, chlorine, ammonia, oxides of nitrogen, and
light hydrocarbons.
A packed tower, or packed bed scrubber, is a unit that is filled with one of many
available packing materials. The packing is designed so as to expose a large surface
area. When this packing surface is wetted by the solvent, it presents a large area of
liquid film for contacting the solute gas.
The flow through a packed column is countercurrent, with the liquid introduced at the
top to trickle down through the packing while gas is introduced at the bottom to pass
upward through the packing.
The flow through a packed bed unit is cross-flow with liquid introduced at both the top &
front of the packed bed, while the gas stream flows horizontally through the unit.
Once through the packed section the airflow enters a mist-elimination section, usually
chevron type baffles, which removes mist particles from the air stream before discharge
to the atmosphere.
A-2
-------
m
144 Industrial Drive
Forest City, N.C. 28043
828-245-9836
FAX: 828-245-1437
STARTUP AND OPERATING PROCEDURE FOR A KCH
SCRUBBER SYSTEM ON A TANK LINE WITH HOODS
AND TANK COVERS
1.
2.
3.
4.
5.
6.
7.
8.
9.
10
11
12
13
Check tank levels and chemical composition.
Inspect the tank covers and operators prior to operation. Check the condition of
mounting pins and all electrical connections.
Open the water supply valve that feeds the scrubber.
Flush out pipe lines and clean any water line strainers that may be installed.
Fill the scrubber to its operating or overflow level.
Open all ball valves to spray headers.
Turn on the "Control Power" to the Manual Wash and Etch Line Hoist Motor
Control Console.
Turn on the "Three Phase Power" on the control panel.
Start the "Fume Scrubber Recalculation Pump".
Start the system "General Exhaust Fan".
Recheck the unit. Inspect spray nozzles to verify liquid flows and proper
operation.
Turn on the Electric hfeaters for tanks No. 2, No. 5 and No. 7 and allow tanks to
heat up.
Turn on Air Agitation Blower and set air rates using manual valves at each tank.
A-3
-------
&//
«KCH
«• » In*..
:-m ,i- tt. rt ', - r- ¦, ,
14. The hoist line operation mode switch (Semi-Auto/Manual Control) can be placed
in the "Auto", "Off' or "Manual" positions for controlling the operating sequence of
the KCH Transport system
a. In the "Off' position the transporter will not move, but the tank covers will
operate by use of the "Open/Close" push buttons at each covered tank
station.
b. In the "Manual" position the transporter will move under the direction of the
operator's control of the joystick mounted on the transporter frame. "Up"
and "Down" control of the lift arms and "Forward" and "Reverse"
movement are in direct response to the joy stick position, but at a constant
speed. The tank covers operate manually and are not interlocked with
any of the transporter controls or location.
c. In the "Semi-Auto" position the transporter will operate as a semi-
automatic system. Note: This system was not designed or programmed to
be fully automatic. With a vertical tilt of the joystick it will automatically
open the tank covers, raise and remove the load and close the covers. A
horizontal tilt of the joystick will automatically relocate the transporter b
the next station using variable speeds (slow starts and stops). A vertical
tilt will open the tank covers, lower the load and close the covers.
15. The ventilation system is designed for a constant volume of air whether the tank
covers are open or closed. By design the hoods will pull about 10% of their
volume with the tank covers closed and 100% with them open. Note that the
normal position of the bleed in air damper is open to the room and all of the hood
dampers are closed. Whenever a tank cover opens, whether in the "Manual" or
"Semi-Auto" mode, the bleed in air damper will close and the hood dampers at
that tank will open, so that all of the air is drawn from the hood on the tank with
the open covers.
PUMP REMOVAL
FOLLOW STANDARD COMPANY PRACTICES FOR LOCKOUT/TAGOUT
144 Industrial Drive
Forest City, N.C. 28043
828-245-9836
FAX: 828-245-1437
A-4
-------
m
144 Industrial Drive
Forest City, N.C. 28043
828-245-9836
FAX: 828-245-1437
1. If the scrubber is operating reset the pH to 7 or drain the sump prior to removing
the pump so there is minimal exposure to any chemicals.
2. LOCKOUT AND TAGOUT the electrical power circuits to the pump being
removed and disconnect the wiring to the pump motor.
3. Disconnect the recycle piping.
4. Remove the pump.
During the installation and or operation of a pump situations may arise such that the
pump unit does not perform as per design or as it did when first installed. To assist you
here are some tips that may help you in identifying a condition or a problem that may
exist.
A. At start up the pump performance does not meet the design conditions.
1. Check liquid level in sump or tank.
2. Verify actual RPM
3. Verify rotation is correct.
4. Check for vortices in sump
5. Check for adequate clearance between pump and bottom of sump or tank
B. While running a vibration is noticeable.
1. Verify that pump is setting level.
2. Check alignment between pump and motor.
3. Check for vortices.
4. Check flow rate to insure pump is operating on curve.
5. Check flow for pulsing that is synchronized with vibration.
C. Flow performance is less than previously experienced.
1. Verify that sufficient liquid is in tank or sump.
2. Insure that suction is free from debris.
3. Check coupling to be sure that shaft coupling is not spinning on shaft.
4. Check discharge valves for position or blockage.
5. Pull pump and inspect impeller.
D. Pump is running rough.
1. Check motor and thrust bearing for grease levels.
2. Disconnect coupling, rotate shaft to check bottom-bearing condition.
PUMP TROUBLESHOOTING TIPS
A-5
-------
m
144 Industrial Drive
Forest City, N.C. 28043
828-245-9836
FAX: 828-245-1437
PACKING MEDIA MAINTENANCE
The packing media should be checked periodically once the scrubber has been put into
operation for scaling or build-ups of solids. If plugging appears evident, the packing
may be flushed with a chemical solution or removed through the packing access door
provided on the side of each unit and cleaned or replaced. Refer to the cleaning section
of this manual.
In general most of the cleaning done around the PVC scrubber will require the use of a
mild soap (liquid dish washing soap), warm water and a soft rag. Soft Scrub and
Windex can also be used. The only place that a solvent should be used is to clean the
grease and dirt around the fan and motor bearings. When cleaning items like the
chevron mist eliminator blades the use of a kitchen bottlebrush, that can be bent, may
be required to get between the blades.
To remove and clean organic matter, try soap first. If the problem is organic scum and
algae then a bleach or caustic solution should be used. A bleach solution of 10% to
15%, or a strong caustic solution of 5% to 10%, may be required.
Internal cleaning may be required to remove hard scale build-up and solids that have
settled to the bottom. In order to remove the scale an acid wash (2% muriatic Acid)
may need to be used.
If the above solutions fail to do the job, then the packing should be removed and
cleaned or replaced.
GENERAL CLEANING
CHEMTCAL CLEANING
A-6
-------
APPENDIX B
Test Plan Modification Request
-------
Test Plan Modification
In the course of verification testing, it may become necessary to modify the test plan due to
unforeseen events. The purpose of this procedure is to provide a vehicle whereby the necessary
modifications are documented and approved.
The Test Plan Modification Request form is the document to be used for recording these
changes. The following paragraphs provide guidance for filling out the form to ensure a
complete record of the changes made to the original test plan. The form appears on the next
page.
The person requesting the change should record the date and project name in the form's heading.
Program management will provide the request number.
Under Original Test Plan Requirement, reference the appropriate sections of the original test
plan, and insert the proposed modifications in the section titled Proposed Modification. In the
Reason section, document why the modification is necessary; this is where the change is
justified. Under Impact, give the impact of not making the change, as well as the consequences
of making the proposed modification. Among other things, the impact should address any
changes to cost estimates and project schedules.
The requestor should then sign the form and obtain the signature of the project manager. The
form should then be transmitted to the CTC Program Manager, who will either approve the
modification or request clarification. Upon approval, the modification request will be assigned a
number, logged, and transmitted to the requestor for implementation.
B-l
-------
TEST PLAN MODIFICATION REQUEST
Date: Number: Project:
Original Test Plan Requirement:
Proposed Modification:
Reason:
Impact:
Approvals:
Requestor:
Project Manager:_
Program Manager:
B-2
-------
APPENDIX C
ETV-MF Operation Planning Checklist
-------
ETV-MF Operation Planning Checklist
The ETV-MF Project Manager prior to initiation of verification testing must complete this form. If a
"yes" is checked for any items below, an action must be specified to resolve the concern on the Job
Training Analysis Form
Project Name: Expected Start Date:
ETV-MF Project Manager:
Will the operation or activity involve the following: Yes No Initials &
Date
Completed
Equipment requiring specific, multiple steps for controlled shutdown? (E.g. in case
of emergency, does equipment require more than simply pressing a "Stop" button to
shut off power?) Special Procedures for emergency shutdown must be documented
in Test Plan.
Equipment requiring special fire prevention precautions? (e.g. Class D fire
extinguishers)
Modifications to or impairment of building fire alarms, smoke detectors, sprinklers
or other fire protection or suppression systems?
Equipment lockout/tagout or potential for dangerous energy release? Lockout/tagout
requirements must be documented in Test Plan.
Working in or near confined spaces (e.g., tanks, floor pits) or in cramped quarters?
Personal protection from heat, cold, chemical splashes, abrasions, etc.? Use
Personal Protective Equipment Program specified in Test Plan.
Airborne dusts, mists, vapors and/or fumes? Air monitoring, respiratory protection,
and /or medical surveillance may be needed.
Noise levels greater than 80 decibels? Noise surveys are required. Hearing
protection and associated medical surveillance may be necessary.
X-rays or radiation sources? Notification to the state and exposure monitoring may
be necessary.
Welding, arc/torch cutting, or other operations that generate flames and/or sparks
outside of designated weld areas? Follow Hot Work Permit Procedures identified in
Test Plan.
The use of hazardous chemicals? Follow Hazard Communication Program, MSDS
Review for Products Containing Hazardous Chemicals. Special training on
handling hazardous chemicals and spill clean-up may be needed. Spill containment
or local ventilation may be necessary.
Working at a height of six feet or greater?
C-l
-------
ETV-MF Operation Planning Checklist (continued)
The ETV-MF Project Manager prior to initiation of verification testing must complete this form. If a
"yes" is checked for any items below, an action must be specified to resolve the concern on the Job
Training Analysis Form.
Project Name:
ETV-MF Project Manager:
Will the operation or activity involve the following: Yes No Initials &
Date
Completed
Processing or recycling of hazardous wastes? Special permitting may be
required.
Generation or handling of waste?
Work to be conducted before 7:00 a.m., after 6:00 p.m. and/or on weekends?
Two people must always be in the work area together.
Contractors working in CTC facilities? Follow Hazard Communication
Program.
Potential discharge of wastewater pollutants?
EHS aspects/impacts and legal and other requirements identified?
Contaminants exhausted either to the environment or into buildings? Special
permitting or air pollution control devices may be necessary.
Any other hazards not identified above? (e.g. lasers, robots, syringes) Please
indicate with an attached list.
The undersigned responsible party certifies that all applicable concerns have been indicated in
the "yes" column, necessary procedures will be developed, and applicable personnel will receive
required training. As each concern is addressed, the ETV-MF Project Manager will initial and
date the "initials & date completed" column above.
ETV-MF Project Manager:
(Name) (Signature) (Date)
C-2
-------
-------
APPENDIX D
Job Training Analysis Form
-------
JOB TRAINING ANALYSIS FORM
ETV-MF Project Name:
Basic Job Step
Potential EHS Issues
Potential Quality Issues
Training
ETV-MF Project Manager:
Name Signature
Date
D-l
-------
APPENDIX E
ETV-MF Project Training Attendance Form
-------
ETV-MF Project Training Attendance Form
ETV-MF Project:
Date
Training
Completed
Employee Name
Last First
Training Topic
Test
Score
(If applic.)
ETV-MF Project Manager:
Name Signature
Date
E-l
-------
APPENDIX F
KCH ACTSEC Verification Test
Field Data Collection Worksheet
-------
KCH ACTSEC Verification Test - Field Data Collection Worksheet
l osl 1 l ank \umlvr
Molor \":il no
Toni|ioriihii'o
" 1 "osl 2 l ank \umlvr
Molor \ nlno
Tom|vialuio
911
Amps
Volts
°F
911
Amps
Volts
°F
911 Duplicate
Amps
Volts
°F
911 Duplicate
Amps
Volts
°F
913
Amps
Volts
°F
913
Amps
Volts
°F
913 Duplicate
Amps
Volts
°F
913 Duplicate
Amps
Volts
°F
Hot Rinse
Amps
Volts
°F
Hot Rinse
Amps
Volts
°F
Hot Rinse Duplicate
Amps
Volts
°F
Hot Rinse Duplicate
Amps
Volts
°F
Comments:
Comments:
l ost 3 Pump Molor
Molor Viiluo
Pump
Amps
Volts
Pump Duplicate
Amps
Volts
" 1 "osl 4 l ank \umlvr
Molor \ aluo
911
Amps
Volts
911 Duplicate
Amps
Volts
Comments:
Comments:
" 1 "osl 5 - Fan
Molor Vuluo
Fan
Amps
Volts
Fan
Amps
Volts
1 os l <¦>
Air Volocilx (I'lmin)
Traverse 1
Traverse 2
Average
Comments:
Comments:
" 1 "os l 7
Sialic Prossuro
7(a)
wg
7(b)
wg
7(c)
wg
7(d)
wg
Average
wg
Tank \umlvr
\amo|iliilo \ aluo
Olhor 1 pnionl
\amo|iliilo \ aluo
911 Element
Amps
Fan
Amps
913 Element
Amps
Pump Motor
Amps
Hot Rinse Element
Amps
Tank opener /closer
Amps
Comments:
Comments:
ETV-MF Project Manager:
Date:
F-l
------- |