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etV
Concurrent
C7TS ! Technologies
Corporatism
U.S. ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL TECHNOLOGY VERIFICATION PROGRAM
FOR METAL FINISHING POLL UTION PREVENTION
TECHNOLOGIES
VERIFICA TION TEST PLAN
Evaluation ofBioClean USA, LLC Biological Degreasing System
For the Recycling of Alkaline Cleaners
Revision 0
February 4, 2000
Concurrent Technologies Corporation is the Verification Partner for the EPA E1VMetal
Finishing Pollution PreventionTechnologies Pilot under EPA Cooperative Agreement No.
CR826492-01-0.
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etV
CPC
Concurrent
Technologies
Corfwmlum
U.S. Environmental Protection Agency
Environmental Technology Verification Program
For Metal Finishing Pollution Prevention Technologies
Verification Test Plan
Evaluation of BioClean USA, LLC Biological Degreasing System
For the Recycling of Alkaline Cleaners
February 4, 2000
Prepared by: ETV-MF Program and
BioClean USA, LLC
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TITLE: EVALUATION OF BIOCLEAN USA, LLC BIOLOGICAL DEGREASING
SYSTEM FOR THE RECYCLING OF ALKALINE CLEANERS
ISSUE DATE: February 4, 2000
DOCUMENT CONTROL
This document will be maintained by Concurrent Technologies Corporation in accordance with the EPA
Environmental Technology Verification Program Quality and Management Plan for the Pilot Period 1995-2000
(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 Dan Groseclose, Marion Rideout, and Karrie Jethrow for their help in preparing this
document.
Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
Finishing Pollution PreventionTechnologies Pilot under EPA Cooperative Agreement No.
CR826492-01-0.
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Environmental Technology Verification Program For Metal Finishing Pollution Prevention Technologies
Verification Test Plan for the Evaluation of BioClean USA, LLC Biological Degreasing System for the
Recycling of Alkaline Cleaners.
PREPARED BY:
A. Gus Eskamani, CAMP, Inc.
ETV-MF Project Manager
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Date
APPROVED BY:
Clinton Twilley
CTC QA Manager
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Date
Donn W. Brown
CTC ETV-MF Program Manager
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Date
Alva Daniels
EPA ETVPilot Manager
lirtitttjiy C.'altufian
BioClean USA, LLC
(S*
Richard Hall
National Manufacturing Company
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Date
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Date
Vll
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TABLE OF CONTENTS
1.0 Introduction 1
1.1 Background 2
2.0 TECHNOLOGY DESCRIPTION 2
2.1 Theory of Operation 2
2.2 Commercial Status 4
2.3 Pollution Prevention Classification 4
2.4 Environmental Significance 4
3.0 Process Description 4
3.1 Equipment and Flow Diagram 4
3.2 Testing Site 6
4.0 Experimental Design 8
4.1 Test Goals and Objectives 8
4.2 Critical and Non-Critical Measurements 8
4.3 Test Matrix 9
4.4 Operating Procedures 10
4.5 Sampling, Process Measurements, and Testing Procedures 10
4.5.1 Sampling Responsibilities & Procedures 10
4.5.2 Process Measurements 13
4.5.3 Testing Parameters & Procedures 14
4.5.3.1 pH/Buffer Control 14
4.5.3.2 Temperature 14
4.5.3.3 Oil Concentration (content and type) 14
4.5.3.4 Related Parameters of Interest 14
4.5.3.5 Sludge Composition 15
4.5.3.6 Biological Testing 15
4.5.3.6.1 Biological Concentrations Sampling & Analysis 16
4.5.3.6.2 Bulk Bacteria Sampling & Analysis 16
4.5.3.6.3 Bulk Fungi Sampling & Analysis 17
4.5.3.6.4 Airborne Biological Sampling & Analysis 18
4.5.4 Test Procedures 20
4.5.4.1 Solvent Extraction 20
4.5.5 Nonstandard or Modified Test Methods 21
4.5.5.1 EPA Method 8015, Modified 21
4.5.6 Calibration Procedures & Frequency 23
5.0 Quality Assurance/Quality Control Requirements 23
5.1 Quality Assurance Objectives 23
5.2 Data Reduction, Validation, and Reporting 24
5.2.1 Calculation of Results 24
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5.2.2 Internal Quality Control Checks 25
5.2.3 Calculation of Laboratory Data Quality Indicators 26
5.2.3.1 Precision 26
5.2.3.2 Accuracy 29
5.2.3.3 Comparability 29
5.2.3.4 Completeness 29
5.2.3.5 Representativeness 29
5.2.3.6 Sensitivity 30
5.3 Quality Audits 30
6.0 Project Management 31
6.1 Organization/Personnel Responsibilities 31
6.2 Schedule/Milestones 31
6.3 Documentation/Records 32
7.0 Equipment 32
7.1 Equipment List and Utility Requirements 32
7.2 Monitoring/Sampling Equipment 32
8.0 Health and Safety plan 32
8.1 Hazard Communication 33
8.2 Emergency Response Plan 33
8.3 Hazard Controls Including Personal Protective Equipment 33
8.4 Lockout/Tagout Program 33
8.5 Material Storage 33
8.6 Safe Handling Procedures 33
9.0 Waste Management 33
10.0 TRAINING 33
11.0 References 34
12.0 DISTRIBUTION 34
APPENDIX A - National Manufacturing Plating Process Flow
APPENDIX B - Organic Soil Analysis Chromatograms
APPENDIX C - ETV-MF Operation Planning Checklist
APPENDIX D - Job Training Analysis Form
APPENDIX E - ETV-MF Project Training Attendance Form
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... 7
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11
13
13
18
20
20
28
32
32
LIST OF FIGURES
BioClean Separator Module I
Biological Degreasing System (Module I) Schematic
National Manufacturing Company Cleaning Process Schematic
Test Data Collection Form
Fundamental Material Balance Equation
Material Flow Diagram for BioClean System
LIST OF TABLES
Test Matrix
Aqueous Samples
Sludge Samples
Bulk Bacteria & Fungi Sampling & Analysis
Airborne Bacteria Sampling & Analysis
Airborne Fungi Sampling & Analysis
QA Objectives
BioClean Equipment List and Utility Requirements
Monitoring/Sampling Equipment
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1.0 INTRODUCTION
The purpose of this test plan is to document the objectives, procedures, equipment, and other
aspects of testing that will be utilized at National Manufacturing Company, during verification
testing an aqueous biological degreasing and recycling system manufactured by BioClean USA,
LLC. BioClean's Biological Degreasing System is a pollution prevention technology designed
for conventional soak or spray cleaning operations in the metal finishing industry. This test plan
has been prepared to evaluate the performance of the technology in conjunction with the U.S.
Environmental Protection Agency's (EPA's) Environmental Technology Verification for Metal
Finishing Pollution Prevention Technologies (ETV-MF) Program. The objective of this program
is to identify promising and innovative pollution prevention technologies through EPA-supported
performance verifications. The results of the verification test will be documented in a verification
report which will provide objective performance data to metal finishers, environmental permitting
agencies, and consultants.
BioClean USA, LLC, Bridgeport, Connecticut, distributes an alkaline cleaning solution and
control system that utilizes microbes in the solution to consume the organic soils that are removed
from parts during the cleaning process. This technology is used in soak or spray cleaning
operations. The BioClean technology was developed in Europe, and is now being distributed in
the US, Canada, and Mexico. Installed applications include cleaning operations for powder
coating, plating and anodizing lines (barrel and rack), metal stamping, and forming operations.
National Manufacturing Company, where the technology has been installed and operating for
approximately 13 months, was selected by BioClean as the test site for this technology. The
National Manufacturing Company designs and manufactures hardware, such as doorknobs,
hinges, staple plates, coat and hat hooks, bolts, chest handles, and numerous others. Their
operations virtually contain the entire supply chain, beginning with the design of the product with
computer aided tools, fabrication operations (stamped, die cast, or formed), plating, painting,
galvanizing, and packaging. Their metal finishing operations consist of rack and barrel production
lines for the plating of the following metals: zinc, brass, nickel, and chromium.
This project will evaluate the ability of BioClean's system to extend the bath life in National
Manufacturing's alkaline cleaning operation. Evaluating and verifying the performance of
BioClean's system will be accomplished by collecting operational data and in-process samples
for analysis. The resultant test data will be used to prepare a mass balance and determine the
efficiency of oil removal under specific operating conditions. An important component of the
verification testing of a microbiological alkaline cleaner recycling system is the quantification of
the biological populations (bacteria and fungi) at selected locations within the aqueous system.
The characterization of the microbial population (to assess microbial response to the oil) along
with the quantification of bio-aerosol generation within the work area (to assess potential health
and safety risks) during various stages of the BioClean process provides important information to
project managers, technicians, operators, and risk assessors regarding the process variables. Also
important to evaluate is the environmental benefit of each verified technology. The benefit of an
alkaline cleaner recycling system can be quantified by determining the reduction of bath dumps
over a period of time. The BioClean system was installed prior to initiation of verification testing
so this benefit will not be verified but will be obtained from historical data collected by National
Manufacturing.
The test plan described in this document has been structured to allow the above objectives to be
met using sound scientific principles. This document explains testing plans with respect to areas
such as test methodology, procedures, parameters, and instrumentation. Section 5.0 describes
Quality Assurance/Quality Control requirements of this task that will ensure the accuracy of data.
Also presented within this document are data interpretation procedures and hypothesized results.
Worker health and safety considerations are covered in Section 8.0.
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This test plan will be maintained at the test site, and verification testing will be conducted in strict
adherence to the test plan requirements.
1.1 Background
The surface finishing and assembly industries require that oils, coolants, and other metal-
working fluids be removed from parts prior to finishing, assembly, or packaging.
Cleaning stamped, diecast, or formed parts prior to subsequent processing has become
increasingly difficult and expensive due to more stringent environmental requirements
and a dramatic rise in waste treatment and disposal costs. For example, environmental
protection authorities are continuously strengthening regulations concerning the use and
disposal of trichloroethylene and chemicals containing nonylphenol etoxylate, which the
cleaning and finishing industry uses to clean organic soil off stamped, formed, and
mechanical parts prior to finishing (e.g., plating, painting, and powder coating). Until
recently, waste reduction in surface preparation operations focused on conserving these
organic solvent cleaners, because for years the metal finishing industry relied on organic
solvents for cleaning metal parts. During the 1980's, however, environmental concerns
for health and disposal consequences increased, and metal finishers began to turn to other
options for their cleaning operations. With the metal finishing industry moving away
from solvent technology, aqueous cleaning has emerged as a viable alternative [Ref. 1].
The tank life of alkaline cleaners is limited by the buildup of oil, grease, and other
contaminants in the bath. When contaminants in the bath begin to sacrifice product
quality, it becomes necessary to discard the cleaning solution. Although the alkaline
cleaners do not carry all of the risks and liabilities associated with the disposal of waste
organic solvents, most cleaners are difficult to treat, because they contain components
that can be difficult to break down. Periodic replacement of the bath results in high costs
due to disposal and replacement chemicals. Hence, an efficient and environmentally
friendly cleaning and recycling system that can extend the usable life of the cleaning bath
will have the desirable effects of consistent performance, life extension of solutions
down-line, waste reduction, reduction in labor costs, reduction in raw material costs, and
ultimately, lower costs of operation.
2.0 TECHNOLOGY DESCRIPTION
2.1 Theory of Operation
The idea of using microbes to consume oil is not revolutionary. For over 40 years they
have been utilized to consume oil from oil spills. BioClean's system combines this idea
with a cleaner. Most conventional alkaline cleaning solutions would immediately kill the
oil-consuming microbes, because of high operating temperatures or high pH. BioClean's
chemistry was constructed around the characteristics of the microbe.
The BioClean system employs a mild alkaline bath or spray that operates at relatively low
temperatures (104°F - 131°F) (40°C - 55°C) and a pH range of 8.8 - 9.2, which is a viable
habitat for these microorganisms. The cleaning solution contains biodegradable
compounds (nonylphenol-free), which help to keep the cleaner stable. The cleaning
process actually takes place in two separate operations. When parts come in contact with
the solution, the oil and impurities are emulsified into micro-particulates. The particulates
are then consumed by microorganisms, which are present in the bath or spray. The
microbe consumption of the oil present in the bath, as its food source, results in the
production of a CO2 and water as by-product.
The primary equipment component of the BioClean system is the separator module,
which is a self-contained system that provides an environment conducive to microbial
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growth. BioClean's Separator Module I is the unit that will be utilized during verification
testing (Figure 1). Within the separator module the solution temperature, pH, and
biodegradable compounds are controlled. The cleaning solution is circulated continually
between the cleaning tank and the separator module. The separator's automated control
system constantly monitors and maintains the bath solution at a preset concentration, by
adding chemical solution as needed.
The chemical solutions include the BioClean 20/100 cleaner, BioClean T-Booster, and
pH+/pH- buffer solutions. The BioClean 20/100 cleaner is used to break the bond
between the part and the oil and then forms a molecule around the oil particle. The
BioClean T-Booster is a surfactant that aids the cleaning process. The pH- contains
phosphoric acid and nutrients for the microbes. The pH+ contains sodium hydroxide and
nutrients for the microbes. The pH-/pH+ solutions are used to maintain the cleaning
solution pH, as well as supply nutrients for the microbes. The microbes ingest the organic
soils first, but if the oil concentration in the cleaning solution is low, the microbes eat
what is available. To prevent the microbes from eating the BioClean 20/100 cleaner or T-
Booster, nutrients are added in the buffer solutions as a supplementary food source.
Figure I: BIOCLEAN SEPARATOR MODULE I
The separator control system also uses a blower to aerate the solution to provide oxygen,
which is needed by aerobic microorganisms. The microbial population is naturally
occurring, and its living habitation is maintained in the biological degreasing system. The
microbes are also self controlling. As the volume of oil increases, the organisms multiply
in direct proportion.
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2.2 Commercial Status
BioClean's system has reportedly been operating for more than 20 years in Europe. The
microbiological cleaning technology was originally developed in Sweden, a known
leader in environmental reform. This technology is now being sold and installed in the
US, Canada, and Mexico.
2.3 Pollution Prevention Classification
BioClean's system is a bath maintenance technology. Bath maintenance refers to a range
of pollution prevention practices and technologies that preserve or restore the operating
integrity of metal finishing process solutions, thereby extending their useful lives. Due to
the rising costs of chemicals, energy, and treatment/disposal, and increasingly more
stringent environmental requirements, bath maintenance has become a greater priority to
metal finishing companies, and the methods and technologies they employ have increased
in sophistication. Today, firms are willing to expend significant amounts of capital and
operating funds for equipment and methods that primarily reduce the disposal frequency
of their baths. In addition to extending bath life, solution maintenance often improves the
operating efficiency and effectiveness of a process solution and therefore has a positive
impact on production rates and finish quality [Ref 2].
2.4 Environmental Significance
BioClean's system employs microbes to consume oils and grease found in aqueous
cleaning operations. The technology reportedly increases the life of the cleaner baths.
The cleaner's chemistry breaks the bond between the part and oil and then forms a
molecule around the oil particle. This reduces or eliminates the presence of oil floating on
the surface of the cleaners or sequential tanks. Destruction of the organic soil can
eliminate other cleaning steps or at least significantly increase their life and reduce the
bath disposal frequency.
The microbiological degreasing system is mostly used as the first cleaning step, and it
can be used in dip, spray, or ultrasonic applications. Conventional cleaning systems
require scheduled maintenance, which entails line shut down, loss of production time,
and hazardous chemical disposal. BioClean's cleaning solution contains nonylphenol-
free, biodegradable compounds, which eliminates the posed toxicity concern found in
some industrial detergents. Also, its systems have reportedly been operating for more
than 20 years without bath dumping, producing only small amounts of non-hazardous
residue.
3.0 PROCESS DESCRIPTION
3.1 Equipment and Flow Diagram
Figure 2 shows a schematic of the BioClean Separator Module I. The module is self
contained and consists of a process tank, lamella separator, blower, transfer pump,
primary heat control with a temperature controller, relay and temperature probe, a back-
heater, four chemical metering pumps, a high level guard, pH-meter and electrode and
control panel.
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Figure 2: Biological Degreasing System (Module 1) Schematic
20/100 T-Booster pH+ pH-
Cleaning Tank
Pump
©
High pressure fan
<8>
Levelguard
Heater
H
pH-meter
Valve
~
Thermostat
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The pH-/pH+ metering pumps can be run in AUTO or MANUAL. The separator control
panel also has ON and OFF switches for the blower, circulation pump, and BioClean
20/100 and T-Booster up heater, four chemical metering pumps, a high level guard, pH-
meter and electrode, and control panel.
The temperature and pH of the solution are controlled in the separator. The temperature
set point is selected on the separator control panel and automatically maintained with
either steam or electric heating. The steam and electric heaters can be run in AUTO or
MANUAL. The desired pH is also set on the control panel and metering pumps. The
level guard, if tripped, has an audible alarm, which can be disabled on the control panel.
The separation module not only controls pH and temperature, but also the amount of
BioClean 20/100 and T-Booster added. The flow-rates of these chemical metering pumps
are set based on production (type of parts being cleaned and rate at which they are
processed). The flow-rate for these metering pumps, at varying production rates, was
established during the installation and start-up of the BioClean system at National
Manufacturing. Subsequently, National Manufacturing has developed standard operating
procedures for setting these metering pumps for varying production demands.
The desired concentration of 20/100 cleaner in the separator is 5 percent. As a result, a
chemical analysis is performed monthly to determine the 20/100 cleaner concentration.
The make-up solutions are added manually into the separator. The manufacturer
recommends a 4:1 20/100 cleaner to T-Booster ratio.
3.2 Testing Site
The metal finishing site selected for testing the BioClean system is the National
Manufacturing Company. National Manufacturing has two facilities that utilize
BioClean's systems, Rock Falls, Illinois (704,000 square feet), and Sterling, Illinois
(550,000 square feet). National's Sterling facility utilizes BioClean's Separator Module I,
and Rock Falls utilizes Module II. The Sterling facility was chosen as the test site
because it employs Module I, which is the larger of the two units and also more
automated.
The Sterling facility has four plating lines that use a combination of rack and barrel
plating technologies (see Appendix A for plating process flow). Three of the four lines
are zinc barrel plating, and the fourth is a multi-purpose (rack and barrel) line. Materials
plated on the fourth line include nickel, brass, and chromium.
The rack/barrel production lines at Sterling clean a variety of parts. The base metals
include zinc die cast, cold rolled steel, stainless steel, and solid brass. The cleaning cycle
for the four plating lines includes the following steps: degrease, electroclean, rinse, rinse,
acid, and rinse, rinse. This is also the cleaning cycle for most plating lines. The cleaning
solutions from the four separate cleaning baths are pumped continuously into a holding
tank that feeds the BioClean system. After BioClean treatment the cleaning solution is
returned, by gravity, into a holding tank and then pumped back into the cleaning tanks
(see Figure 3). This operation is run in a continuous mode with level guards on the
cleaning tanks that prevent overfilling. If the level guard in the cleaning tank is tripped, a
solenoid valve will shut off flow to that particular tank. Also, each cleaning tank has a re-
circulation tank that is used to re-circulate the bath solution. The bath solution is pumped
from the re-circulation tank to the BioClean holding tank. The re-circulation tank can also
be used to isolate a bath from the BioClean separator for a short period of time.
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Fig ure 3: National Manufacturing Company Cleaning Process Schematic
Cleaning Tank Cleaning Tank Cleaning Tank Cleaning Tank
Plating Line #1 Plating Line #2 Plating Line #3 Plating Line #4
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Isolation of the cleaning tank will play an important role in the BioClean verification at
National Manufacturing. National Manufacturing's plating line plates the parts that are in
demand at that particular time, which consequently means that there is not a consistent
method of obtaining a steady oil load into the BioClean system. The advantage of
isolating the cleaning tanks from each other, during the BioClean verification, is that it
gives an opportunity to control, as much as possible, the soil load into the BioClean
Separator.
4.0 EXPERIMENTAL DESIGN
4.1 Test Goals and Objectives
The overall goal of this project is to establish the technical and economic performance
parameters that will enable a potential user to determine if the BioClean Biological
Degreasing System is appropriate and feasible under their specific operating conditions.
The objective of testing is to generate the analytical data and performance observations
required to support these technology verification efforts.
The following are statements of specific project objectives:
• Determine the cleaning effectiveness and organic soil removal efficiency of the
BioClean system when processing specific types of soiled parts, with known oil
load, at manufacturer recommended process conditions.
• Determine the addition rate of BioClean cleaner, T-Booster, and pH buffer
solutions during observed operating conditions. This information will be used to
estimate operating costs for the BioClean system.
• Quantify the biological populations (bacteria and fungi) at selected locations within
the BioClean system. This information will be used to assess the microbial
response to the oil loading, as well as the potential health and safety risks in
various stages of the BioClean process.
• Quantify the energy required to operate the system. Primary energy users include
the bath heater, transfer pumps, and the air blower. This information will be used to
help estimate operating costs for the BioClean system.
• Quantify the environmental benefit by determining the reduction in bath disposal
frequency.
These objectives will be used to determine the system mass balance, the efficiency of
organic soils removal, operation and maintenance requirements, and cost effectiveness
for a given set of operating conditions.
4.2 Critical and Non-Critical Measurements
Measurements that will be taken during testing are classified below 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.
Operational data will be collected on the unit's performance during treatment of solutions
of known alkaline cleaner solution concentrations, and organic soil load. The following
operational data will be collected:
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Critical Measurements:
• Chemical additions: Quantity and frequency
> BioClean cleaner (volume (mL) of each addition, time of each addition)
> BioClean T-Booster (volume (mL) of each addition, time of each addition)
> pH+ and pH- solutions (volume (mL) of each addition, time of each addition)
• Biological (bacteria and fungi) concentration (colony forming units, CFU)
• Organic soil on parts (incoming & outgoing)
• Metal concentration (Cu, Zn)
• Total Suspended Solids (TSS)/Total Solids (TS)
• Total Organic Carbon (TOC)
• Production throughput rates (parts/hour, pounds/hour, surface area/unit of time)
• Bath aeration rate (air in cubic feet per minute (CFM))
• O&M labor requirements
• Solution processing rate & chemical characteristics of feed & product solutions
(cleaning chemical & contaminants)
• Waste volumes, characteristics, & costs
• Separator flow rate to the holding tank (volume/time)
• Cleaning bath flow rate to the holding tank (volume/time)
Non-Critical Measurements:
• Temperature (°F) and pH
> BioClean separator
> Cleaning tanks
• Fresh water usage (volume/time)
These data will be used to determine the system mass balance, the efficiency of organic
soil removal, operation and maintenance requirements, and cost effectiveness for a given
set of operating conditions.
Historical Data:
National Manufacturing historical data on alkaline cleaner bath disposal frequency prior
to installation of the BioClean system will be collected and provided in the verification
report to determine the environmental benefit.
4.3 Test Matrix
The Bioclean System will be evaluated on its ability to efficiently remove oil at three
specific soil-loading rates. The specific tests planned are described below and listed in
Table 1.
Initial Testing
Representative part samples (five) will be collected at each soil load rate (low, medium,
and high). Part samples will be taken directly from the process point (barrel and/or rack).
In order to quantify oil content on the representative part samples the oil from the parts
will be removed through solvent extraction (immersion into a known volume of acetone)
and the acetone rinse analyzed using a modified organics and hydrocarbon gas
chromatographic method (EPA Method 8015, modified). The acetone rinse will be
collected and transferred into one-liter amber glass sampling containers and returned to
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the analytical laboratory. At the lab, the acetone rinse will be evaluated for the indicated
initial control parameters in Table 1. The initial part sampling process will be performed
three times and an average oil quantity calculated for each soil load rate category. This
average oil quantity will be used as the soil feed rate (by category) into the system.
The three soil load rates correspond directly to the type of part being cleaned. Some parts
manufactured at National Manufacturing contain more oil than others because of threads
and surface grooves. Only three types of parts will be processed during testing, and they
will be classified as low, medium, or high soil load. National Manufacturing will
determine the testing schedule.
Another set of representative part samples (five) will be collected to determine the
residual oil remaining after the BioClean system. The same test methodology stated
above will be used.
Verification Testing at Low. Medium and High Soil Loads
Each test will be conducted at normal operating parameters recommended by BioClean,
USA. The key operating data, as discussed in Section 4.2, will be recorded onto the form
shown in Figure 4 at hourly intervals. Analytical and microbiological testing of samples
will be conducted to evaluate the indicated parameters in Table 1.
4.4 Operating Procedures
National Manufacturing personnel will perform normal operation and maintenance
activities during testing. These activities will be observed and noted by an ETV-MF
representative.
The BioClean System will be operated 24 hrs/day for 5 to 7 days per week. The exact
number of days is dependent on the schedule at National Manufacturing. Each test run
will consist of a minimum of 3 days.
4.5 Sampling, Process Measurements, and Testing Procedures
4.5.1 Sampling Responsibilities & Procedures
Samples will be taken at the frequency listed in Table 1 for each location. The
appropriate sampling container will be used as outlined in Tables 2-6 for each
test parameter. Each laboratory sample bottle will be labeled with the date,
time, sample ID number, and test parameters required. Sampling will begin
once the unit has been operating normally for a period of at least one-hour.
Sample preparation methods are described in each individual analytical
method.
Samples to be analyzed at an off-site laboratory will be accompanied by a
chain of custody form. The samples will be transported in appropriate sample
transport containers (e.g., coolers with packing and blue ice) by common
carrier. The transport containers will be secured with tape to ensure sample
integrity during the delivery process to the analytical laboratory. The Project
Manager or designee will perform sampling, labeling, and ensure that samples
are properly secured and transported to the appropriate laboratory. AMTest,
Inc. in Redmond, WA, will perform analytical testing, and U.S. Micro-
Solutions in Greensburg, PA, will perform microbiological testing.
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SAMPLE
LOCATION
SOIL LOAD
NUMBER OF
SAMPLES
FREQUENCY
TEST
DURATION
TEST
PARAMETERS
Before BioClean (feed)
(low, medium and high load)
Initial Control
5 (for each soil load)
3 times (for each soil
load)
N/A
Oil Concentration
Total Suspended Solids
(TSS)/Total Solids (TS)
Metals
After BioClean (product)
(low, medium and high load)
Initial Control
5 (for each soil load)
3 times (for each soil
load)
N/A
Oil Concentration
TSS/TS
Metals
Cleaning Tank
Low
Medium
High
4 (for each soil load)
2/day (for each soil
load)
3 days (for each soil
load)
Oil Concentration (for each soil
load)
TSS/TS
Metals
Separator Effluent
(BioClean Unit)
Low
Medium
High
1 (for each soil load)
2/day (for each soil
load)
3 days (for each soil
load)
Oil Concentration (for each soil
load)
TSS/TS
Metals
Separator Effluent
(BioClean Unit)
Low
High
1 (for each soil load)
1/hr. for 10 hrs.
(for each soil load)
3 days (for each soil
load)
Biological Population
Waste Solids - Sludge
(BioClean Unit)
Low
Medium
High
1 (for each soil load)
1 sample at the end of
each soil load
3 days (for each soil
load)
Oil Concentration
Metals
Weight
Total % Solids
Total Organic Carbon (TOC)
Waste Solids - Sludge
(BioClean Unit)
Low
High
1 (for each soil load)
1/hr. for 10 hrs.
(for each soil load)
3 days (for each soil
load)
Biological Population
Cleaning Tank
Low
High
1 (for each soil load)
1/hr. for 10 hrs.
(for each soil load)
3 days (for each soil
load)
Biological Population
Table 1: TEST MATRIX
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TEST # OPERATION Parts Cleaning
DATE: BATH TYPE: Alkaline Cleaner
SAMPLE DATA
BIOCLEAN SEPARATOR
PARAMETERS
CLEANING TANK
PARAMETERS
Sample #
Time
Sample
Location
Temp.
(°F)
pH-
(mL)
pH+
(mL)
20/100
(mL)
T-Booster
(mL)
Flowrate
(L/hr)
H20
(L/hr)
Flowrate
(L/hr)
pH
Temp.
(°F)
Figure 4: TEST DATA COLLECTION FORM
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ANALYTE
METHOD
SAMPLE BOTTLE
PRESERVATION
METHOD
Oil
EPA Method 8015, modified
1 liter Glass
Cool to 39°F (4°C)
TSS/%TS
EPA Method 160.2/160.3
500 ml High Density
Polyethylene (HDPE)
Cool to 39°F (4°C)
Metals
EPA Method 200.7/200.9
500 ml HDPE
pH<2
Table 2: AQUEOUS SAl
MPLES
ANALYTE
METHOD
SAMPLE BOTTLE
PRESERVATION
METHOD
Oil
EPA Method 8015, modified
16 ounce glass
Cool to 39°F (4°C)
%TS
EPA Method 160.4
16 ounce glass
Cool to 39°F (4°C)
Metals (Cu, Zn)
EPA Method SW846 6010
16 ounce glass
Cool to 39°F (4°C)
TOC
EPA Method SW846 9060
16 ounce glass
Cool to 39°F (4°C)
Table 3: SLUDGE SAMPLES
4.5.2 Process Measurements
Monitoring of the tests will be accomplished by recording key operating
data on the Test Data Collection Form (Figure 4). Monitoring
instrumentation will be calibrated by National Manufacturing, according
to the frequency required by the manufacturer. See Section 4.5.6 for
specific calibration procedures and frequency.
Electricity use will be measured by determining the power requirements
and cycle times of pumps and other powered devices. National
Manfacaturing will provide the cost of labor, electricity, and other data
needed for cost analysis.
Separator and cleaning bath flow rates for this demonstration will be
measured by allowing the BioClean holding tank influent solution fill a
graduated cylinder or beaker while monitoring with a stopwatch. The
same procedure will be used to measure the separator effluent stream, as
well as the BioClean 20/100 and T-Booster flow rates. Flow rate will
then be calculated using the following equations:
Volume (milliliters') = Flow rate (mL/sec.) (a)
Time (second^
Flow rate (mL/sec.) x 60 sec./min. = Flow rate (mL/min.) (b)
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4.5.3 Testing Parameters & Procedures
4.5.3.1 pH/Buffer Control
The pH of the cleaning solution and the separator effluent is
continuously monitored and automatically controlled. The pH-
increasing chemical (pH+) contains sodium hydroxide, and the
decreasing chemical (pH-) contains phosphoric acid.
4.5.3.2 Temperature
Temperature is continuously monitored by the BioClean
control system. An immersion heater typically maintains the
bath temperature at 120°F (49°C) and can be adjusted as
desired.
BioClean does not recommend bath temperatures exceeding
135°F (57°C), as higher temperatures will pasteurize the bath,
killing the bacteria.
4.5.3.3 Oil Concentration (content and type)
The amount and type of oil coating the parts to be cleaned
could affect the performance of the BioClean system. A
representative sample of oil on the parts will be collected and
analyzed using the modified organics and hydrocarbon gas
chromatographic method, EPA Method 8015 (modified).
A one-liter sample will be collected for oil analysis in aqueous
and sludge samples using Method 8015 (modified). Typically,
a one-liter volume is extracted prior to Method 8015 analysis
because of the presumption of low level concentration.
Preliminary samples were taken to verify the efficacy of
Method 8015 to be used during the BioClean Verification Test.
The samples under consideration have been observed to
contain extremely high concentrations upon receipt at the
laboratory. Laboratory sample splits (duplicates) were also
analyzed and internal QA/QC matrix spikes were run from the
sample splits. Approximately 100 mLs per sample aliquot
proved to be sufficient (500 mLs were used in assaying less
highly impacted samples).
4.5.3.4 Related Parameters of Interest
Other parameters may also be of interest in evaluating the
relative performance of the BioClean System. Specifically, the
amount of total solids suspended in solution (TSS) and total
solids (TS) in the effluent stream will be determined (TSS by
EPA Method 160.2, TS by EPA Method 160.3). Certain
metals are known to inhibit the viability of microbial
populations, specifically copper (Cu) and zinc (Zn), among
others. Both metals may be present as an artifact of the
manufacturing and/or plating process. Subsequently, copper
and zinc were selected as target analytes of interest. Copper
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and zinc will be measured, using EPA Method 200.7/200.9, to
determine if their presence correlates with lower than expected
microbial population or oil removal efficiency. Method 200.7
utilizes a charge injection device (CID) capable of
simultaneous analysis and Method 200.9 utilizes a graphite
furnace (GF) detector that is capable of individual metal
analyses. Depending on the metal under consideration and/or
the concentration range in the samples one method may be
more sensitive than the other method. Due to the complex
nature of the samples collected matrix interference may
possibly affect analyses. Consequently, the 200.7 method will
be performed first followed by the 200.9 method, should
analytical sample conditions so warrant. If this happens, the
laboratory will indicate the reason(s) for use of Method 200.9
in the data package.
4.5.3.5 Sludge Composition
The quantity and composition of the sludge, which forms in
the bottom of the BioClean Separator, will enable the ETV-MF
team to determine the operating costs of the BioClean system.
Sludge samples will be taken before and after each soil-
loading test. If a sufficient sludge quantity is collected then it
will be characterized according to the test parameters in Table
1. If there's not a sufficient quantity of sludge collected for
each individual soil load then a composite sample will be
prepared for characterization that will be comprised of the
entire volume of sludge collected. The analytical laboratory
results will determine if individual samples are sufficient or if
a composite sample is required. Before sludge samples are
collected in sampling containers the piping from the conical
shaped separator will be drained as much as possible in order
to ensure a representative sample. The sludge quantity will be
determined by simply dewatering and weighing it, expressed
as percent total solids (EPA Method 160.4). Organic soil
concentration will be determined (EPA Method 8015,
modified). Total organic carbon (TOC) content (EPA Method
9060, SW846) and specific metals (copper, zinc) concentration
(EPA Method 6010, SW846) will be determined.
4.5.3.6 Biological Testing
The presence of surface biological contamination (bacteria
and/or fungi) or airborne biological contaminants in indoor air
(bio-aerosols), may affect product quality as well as worker
health. The assay of the microbial content of the workplace
(ambient air, work surfaces, raw materials, etc.) has become
increasingly more significant in the past decade as the need for
"contamination-free" environments has become more
apparent.
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The ASHRAE (American Society for Heating, Refrigerating
and Air-Conditioning Engineers) defines acceptable indoor air
quality as "air in which there are no known contaminants at
harmful concentrations and with which a substantial majority
(usually 80%) of the people exposed do not express
dissatisfaction." Bio-aerosols have been conclusively
associated with hypersensitivity syndromes and sick building
syndrome (SBS). These hypersensitivity syndromes result
from exposure to materials in the environment (antigens) that
stimulate a specific immunologic response. Most of these
workplace/building-related antigens are assumed to be of
fungal or bacterial origin.
An important component of the verification testing of an
aqueous biological degreasing system is the quantification of
the biological populations (bacteria and fungi) at selected
locations within the aqueous system. The characterization of
the biological population (to assess response to the oil loading)
along with the quantification of bio-aerosol generation within
the work area (to assess potential health and safety risks)
during various stages of the BioClean process provides
important information to project managers, technicians,
operators, and risk assessors regarding the process variables.
4.5.3.6.1 Biological Concentrations Sampling & Analysis
The concentrations of biological populations (bacteria
and fungi) shall be evaluated by collecting
representative samples (50-100 ml) from a number of
locations in the BioClean Separator Module I,
including bulk samples of the separator waste solids,
separator effluent, and cleaning tank. The bulk
samples of solid and liquid process materials shall be
collected in sterile 50-ml vials, sealed and then
shipped overnight to an approved microbiology
laboratory for analysis. The holding period for
biological samples is 24-hours. U. S. Micro-Solutions
(Greensburg, PA) shall analyze samples for the
predominant genera and concentration of bacteria and
fungi.
4.5.3.6.2 Bulk Bacteria Sampling & Analysis
Bulk samples of the alkaline cleaning solution shall be
collected in sterile 50-ml screw-cap vials from a series
of sampling points. The sampling points for the bulk
bacteria samples (Table 4) shall include the separator
inlet, separator effluent, and separator waste sludge.
Twenty samples shall be collected from each sampling
point at a rate of one sample per hour with
approximately ten samples collected at each location
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during low oil-grease loads in the BioClean system
and ten bulk samples collected at each sampling
location during high oil-grease loads on the system.
Sampling during the low and high oil-grease loads will
provide a good minimum and maximum biological
characterization representation in the BioClean
system. Assuming the bacterial population response is
linear, collecting samples at high and low oil loading
is sufficient to characterize the bacterial population
response. For this reason samples will not be taken
during medium oil-grease loading. Two bulk sample
"blanks" shall be collected prior to beginning each
series of bulk samples of high and low oil-grease loads
on the system: one bulk sample of the makeup water
for the aqueous cleaner and one bulk sample of the
organic soil coating on the parts to be cleaned. These
blanks shall provide the concentrations of
bacteria/fungi present at background levels in the
BioClean system. The organic soil coating on the parts
to be cleaned will be analyzed for biological
contamination by swabbing the part(s) with a sterile
swab. The swab collecting the sample is placed in a
sterile tube and stored prior to analysis.
The bulk solution samples shall be collected in sterile
50-ml vials, sealed and then shipped overnight to U.S.
Micro-Solutions for analysis. Serial dilutions (i.e.,
1:10, 1:100, 1:1,000) of the bulk samples shall be
made with sterile water, and tryticase soy agar (TSA)
plates shall be inoculated with the serial dilutions for
the isolation and identification of the bacteria. The
agar plates are incubated at 95°F (35°C) for three days
and 81°F (27°C) for two days. Bacteria counts shall be
performed, and colony-forming units (CFU)/gram of
bulk sample and/or CFU/ml of liquid sample shall be
calculated.
4.5.3.6.3 Bulk Fungi Sampling & Analysis
Bulk samples of the alkaline cleaning solution shall be
collected for the identification and quantification of
fungi following the aforementioned protocol. The
bulk samples of the alkaline cleaning solution
analyzed for fungi shall be collected in sterile 50-ml
screw-cap vials from the separator inlet, separator
effluent, and separator waste sludge (Table 4). The
twenty samples collected (10 samples during low oil-
grease loads and 10 samples during high oil-grease
loads) shall
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SAMPLE STREAM
LOCATION
TEST TYPE
(Oil Load)
NUMBER
OF
SAMPLES
FREQUENCY
TEST
PARAMETER
TEST
METHOD
Separator Inlet
Low
10 low
10 high
1 sample/hour
CFU/ml
Serial Dilutions:
TSA
YMA
High
Separator Effluent
Low
10 low
10 high
1 sample/hour
CFU/ml
Serial Dilutions:
TSA
YMA
High
Separator Waste Sludge
Low
10 low
10 high
1 sample/hour
CFU/ml
Serial Dilutions:
TSA
YMA
High
Makeup Water
(for aqueous cleaner)
Blank
1 low
1 high
1 sample/load
1 sample/load
CFU/ml
Serial Dilutions:
TSA
YMA
Oil Coating
Low
1 low
1 high
1 sample/load
1 sample/load
CFU/ml
Serial Dilutions:
TSA
YMA
High
CFU - colony forming units TSA - tryticase soy agar YMA -yeast malt extract
agar
Table 4: BULK BACTERIA & FUNGI SAMPLING & ANALYSIS
be sealed, shipped, and handled as previously
described. Bulk samples for fungal analysis shall be
serially diluted with sterile water (i.e., 1:10, 1:100,
1:1,000), and yeast malt extract agar (YMA) plates
shall be inoculated with the different serial dilutions
for the isolation of the fungi. The YMA plates are
incubated at 81°F (27°C) for five days. Fungal counts
shall be performed and CFU/gram or CFU/ml of
sample shall be calculated.
4.5.3.6.4 Airborne Biological Sampling & Analysis
The on-site investigation of biological populations
begins outdoors. The outdoor air is never sterile and
often contains in excess of 105 fungal spores per cubic
meter. Fungal spores usually dominate the outdoor air
spora, although pollen, bacteria, algae, and insect
fragments also are present. It is essential to carefully
examine the outdoor environment adjacent to the
aqueous cleaning operation for potential sources and
to sample the ambient air, as controls for all indoor
samples collected during the verification testing.
Outdoor air will be sampled for airborne bacteria and
fungi according to the frequency shown in Tables 5
and 6.
Airborne microbes (biological aerosols) include viable
biological contaminants occurring as particles in the
air. These particles can vary in size from viruses less
than 0.1 micron in diameter to fungal spores 100 or
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more microns in diameter. They occur as single,
unattached organisms or as aggregates. Air particle
samplers have been generally used to collect and assay
aerobic species of bacteria and fungi. Even though
many samplers will collect some virus particles, there
is no convenient, practical method for the cultivation
and enumeration of these particles. The survey shall
focus on the quantification and identification of
predominant bacteria and fungi and will not address
the presence of viral particles in the ambient air
surrounding the workplace.
The airborne bacterial and fungi samples shall be
collected at three locations (Tables 5-6) within the
BioClean Separator Module system. The airborne
samples shall be collected on sterile agar collection
plates using an Andersen N-6 particle sampler. The
Andersen sampler is a single-stage, size-selective
impactor sampler designed to separate bio-aerosol
particles from the air. A vacuum pump draws ambient
air over an agar collection plate at the rate of 28.3
liters per minute (1/min). The airborne bacteria are
collected on an agar medium appropriate to the
microorganisms that may be encountered (TSA). The
TSA plate is then removed from the sampler, inverted,
incubated, and counted by an accepted method.
Sampler stages are disinfected with isopropyl alcohol
before and after each impact sample is collected. The
TSA air plates are incubated at 95°F (35°C) for three
days and 81°F (27°C) for two days. The YMA air
plates are incubated at 81°F (27°C) for five days.
Microbial counts are then made and the colony
forming units per cubic meter of air (CFU/m3) are
determined.
The sampling time for airborne biological
contaminants using the Anderson N-6 particle sampler
is 2 minutes for outdoor air (control) and 4 to 6
minutes for the process environment (indoor air).
Sampling time is recorded and multiplied by the
sampling rate to determine the volume of air sampled.
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SAMPLE STREAM
LOCATION
TEST TYPE
(Oil Load)
NUMBER
OF
SAMPLES
FREQUENCY
TEST
PARAMETER
TEST
METHOD
Separator
Low
High
10 low
10 high
1 sample/hour
(10 hours x 2)
CFU/m1
TSA
Holding Tank
Low
High
10 low
10 high
1 sample/hour
(10 hours x 2)
CFU/m1
TSA
Cleaning Tank
Low
High
10 low
10 high
1 sample/hour
(10 hours x 2)
CFU/m1
TSA
Outside Air
Control
2
1 : test onset
1 : test end
CFU/m3
TSA
CFU - coloi
ny forming units
Table 5: AIRBO
RNE BACTER
rSA - tryticase soy
IA SAMPLING & A
agar
NALYSIS
SAMPLE STREAM
LOCATION
TEST TYPE
(Oil Load)
NUMBER
Of
SAMPLES
FREQUENCY
TEST
PARAMETER
TEST
METHOD
Separator
Low
High
10 low
10 high
1 sample/hour
(10 hours x 2)
CFU/m3
YMA
Holding Tank
Low
High
10 low
10 high
1 sample/hour
(10 hours x 2)
CFU/m3
YMA
Degreasing Tank
Low
High
10 low
10 high
1 sample/hour
(10 hours x 2)
CFU/m3
YMA
Outside Air
Control
2
1 : test onset
1 : test end
CFU/m3
YMA
CFU - colony-forming units YMA - yeast malt extract agar
Table 6: AIRBORNE FUNGI SAMPLING & ANALYSIS
4.5.4 Test Procedures
4.5.4.1 Solvent Extraction
Organic soil load on each particular part will be different as a
function of the part's surface area, machining detail, and
application rate on each part's line. The three soil load rates
correspond directly to the type of part being cleaned. Some
parts manufactured at National Manufacturing contain more
organic soil than others because of threading and surface
grooves. For example, parts that have blind holes contain more
organic soil than small smooth parts.
Only three types of parts will be observed during this testing
and they will be classified as low, medium, or high soil load.
Each of the four plating lines may receive one and/or several
parts over a given time period. So to better understand the
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relative organic soil loading contribution from a particular
series of parts, representative "clusters" of parts will be used as
characteristic of the range of parts loads to these plating lines.
This will entail understanding the manufacturing process and
parts loads over the testing period, then defining one or several
"characteristic clusters" for each plating line. Once defined,
these "part clusters" will be aggregated by randomly sampling
parts. National Manufacturing will assist the project team in
determining which parts will be sampled, based on their
production schedule.
By nature of the experimental conditions and distance from the
manufacturing test site and the analytical laboratory, the
organic soil on these part clusters will be extracted at the test
site. The parts clusters will be rinsed in a solvent such as
acetone. Acetone is readily available, stable, and under well-
ventilated conditions relatively safe for properly trained
personnel to use. Representative aliquots of both the straight
acetone and extraction medium will be sent to the analytical
laboratory for analysis. At the lab, the acetone rinse will be
evaluated for the indicated test parameters in Table 1 using a
modified organics and hydrocarbon gas chromatographic
method (EPA Method 8015, modified).
The solvent extraction procedure consists of the following
steps:
1. Remove five part samples from the barrel/rack finishing
line.
2. Put part in a container (beaker or erlenmeyer flask) with a
known quantity of acetone. If the part is too large for a
beaker or flask then rinse a clean laboratory pan with
acetone and place the part in the pan. Using a volumetric
beaker and/or flask fill the pan with acetone until the part
is covered.
3. Record the amount of acetone used into the laboratory
logbook.
4. Let the part lay immersed in the acetone for two minutes.
5. Remove part and place the extraction medium in a
properly labeled sampling container (1 L jar) for shipment
to the analytical laboratory.
4.5.5 Nonstandard or Modified Test Methods
4.5.5.1 EPA Method 8015, Modified
A gravimetric method for measuring organic soils in aqueous
and sludge samples was not chosen for analytical testing.
Concerns about possible interference's and "false positives"
for organic soil concentration from surfactants and/or
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proprietary chemicals within the system under evaluation led
to consider alternative analytical methods, or at least to
demonstrate the efficacy of standard methods to these
materials and sample matrices.
"Neat" samples of the exact formulated lubrication products,
which are used on the parts themselves, will be characterized
and used as calibration standards in these quantitative
analyses. Therefore, by using known dilutions of "neat"
standards, calibration curves and reference solutions can be
drawn (reference solutions were used for quantification
purposes). EPA Method 8015 can then be used to quantify the
organic soil in the cleaner separate from the BioClean cleaner
compounds.
An initial characterization and evaluation of these "neat"
formulated products using the modified Method 8015 was
performed by the analytical laboratory (AMTest, Inc. of
Redmond, WA). Modifications to the standard 8015 method
involved slight changes in the ramp time within the gas
chromatographic program, which were within the proscribed
acceptable method modifications. Each type of organic soil
evaluated yielded a characteristic chromatographic signature
(see Appendix B for chromatograms). Based on the
information received, no one particular organic soil product is
known to dominate over the others. Using the aliquots from
the neat solutions of the different formulated products, a mixed
reference standard was created and a range of calibration
concentration standards derived. Results are reported in
milligrams/liter (mg/L).
Analyses of the BioClean proprietary biological enhancement
(T-Booster) and cleaning (20/100) solutions were also
performed. When compared to the prepared organic soil
reference calibration standards, neither sample solution
exhibited "false positive" signatures for organic soil
concentration. Thus, reported organic soil concentration should
be expected as directly related to the formulated organic soil
content.
Another reference step evaluated the efficacy of the modified
Method 8015 test method for these samples and matrices.
Aliquots were analyzed using the modified Method 8015, the
conventional freon extraction-gravimetric method, as well as
the recently approved EPA Method 1664 (hexane extract). The
modified Method 8015 and freon methods yielded comparable
results. Although the freon method yielded acceptable results,
freon has been phased out as an acceptable material under the
Montreal Accord, and hence will not be in use within
analytical methods in the very near future. The hexane
extraction method did not yield successful extraction results.
The aqueous matrix turned milky (akin to liquid gelatin),
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requiring several cleanup steps and resulting in poor sample
recovery (un-reproducibility of results). Due to the arduous
sample preparation that would have been required, these test
samples were not carried through to analyses. The cost for
such analyses would be prohibitively expensive, so the method
was discounted from further consideration in this study.
4.5.6 Calibration Procedures and Frequency
The following procedures will be used to calibrate the
instruments/equipment that will be used to collect critical measurements:
1. Instruments used to perform analytical methods will be calibrated
according to the analytical laboratory's quality assurance plan.
2. The bioaerosol sampler, Andersen N-6 Single Stage Particulate
Sampler, will be calibrated by the equipment manufacturer once
before the start of verification testing.
3. An air flow meter will be installed in the piping from the blower to
the separator. The meter will be calibrated according to the
procedures and frequency of the equipment manufacturer
requirements.
4. Although pH and temperature are non-critical measurements and are
automatically controlled by the separator module, these
measurements will be checked daily with a digital pH and
thermometer. The digital pH reader will be calibrated daily before
taking the bath reading. If the manual and controlled pH readings are
off by + 5 percent than the pH controller will be calibrated. If the
digital thermometer and temperature controller readings are off by +
5 percent than the separator's backup temperature controller will be
used for the duration of the testing.
QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS
Quality Assurance/Quality Control 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],
5.1 Quality Assurance Objectives
One QA objective is to ensure that the process operating conditions and test
methods are maintained and documented throughout each test and laboratory
analysis of samples. Another QA objective is to use standard test methods for
laboratory analyses. The analytical methods that will be used for analyzing the
baths and product and/or waste samples are standard EPA methods.
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5.2 Data Reduction, Validation, and Reporting
5.2.1 Calculation of Results
The conservation of mass/energy in any isolated system is one of the most fundamental laws in
science and engineering. The mass/energy balance can account for the inputs, outputs,
consumption, and accumulation in a system. To determine system efficiency, measuring or
quantifying all of the elements for a mass balance in an industrial setting is very difficult. The
greatest challenge is generally defining the system boundaries and what degree of accuracy is
required. Sampling, measurement, and analytical errors preclude absolute precision; however, the
mass/energy balance provides us with a fundamental tool for evaluating the performance of
environmental technologies where we are generally evaluating some form of efficiency. Figure 5
illustrates the most fundamental form of the material balance equation. Batch systems and
continuous systems can both be modeled using this general form. Figure 6 illustrates the material
flow into and out of the BioClean separator
Mass
Accumulation
within the
System
Equals
Mass Input
Through System
Boundaries
less
Mass Output
Through System
Boundaries
plus
Mass Generated
Within the
System
less
Mass Consumed
Within the
System
Figure 5: FUNDAMENTAL MATERIAL BALANCE EQUATION
The consumption term in this fundamental material balance equation
warrants further discussion because of the complexity of the BioClean
technology. Because the technology presented includes biological
chemistry, microbial kinetics would need to be evaluated in order to
accurately quantify the mass consumed within the system. Some of the
parameters that go into the microbial kinetics are oxygen uptake, carbon
dioxide and water production. These parameters will be impossible to
measure because the BioClean technology is an open system. Since the
microbes consume oxygen as they metabolize hydrocarbons to produce
carbon dioxide and water, dissolved oxygen must be continuously
replenished in the cleaning bath. Dissolved oxygen analysis will
Cleaning Tank
BioClean
Separator
Sludge
Holding Tank
Figure 6: MATERIAL FLOW DIAGRAM FOR BIOCLEAN SYSTEM
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determine if the bath contains enough oxygen (as supplied through
aeration) to support the microbial population, and also the effect of
dissolved oxygen on system performance (or oil consumption/removal
efficiency). Dissolved oxygen data will not be accurate enough to
calculate microbial kinetics. In addition, it might turn out that microbial
growth would not show first-order-kinetics with respect to oil loading or
consumption. For example microbial growth may be due to a
combination of oil degradation as well as nutrients and surfactants, thus
it becomes hard to determine which had the major influence. Focusing on
the microbial kinetics that will be needed to quantify the mass consumed
within the BioClean system will launch efforts into an R&D path, which
deviates from the ETV Program goals. Consequently, quantifying the
consumption term is not a project objective, but every attempt will be
made to measure it indirectly, if feasible in order to report the mass
balance as accurately as possible.
The goal of the BioClean project is to verify performance, and this can
generally be measured in terms of the BioClean Separator oil removal
(digestion) efficiency. QA objectives will be satisfied if the mass balance
is between 50 and 150 percent.
To determine oil removal efficiency, the fundamental material balance
equation for the BioClean separator can be simplified to:
Xs + Xh = Xi, where
Xs = Mass of oil leaving the separator in the sludge
Xh = Mass of oil leaving the separator and entering the
holding tank
Xi = Mass of oil leaving the cleaning tank and entering
the separator
Separator oil removal efficiency is determined by:
Efficiency % = Xs + Xh x 100%
Xi
5.2.2 Internal Quality Control Checks
Raw Data Handling. Raw data is generated and collected by laboratory analysts
at the bench and/or sampling site. These include original observations, printouts,
and readouts from equipment for sample, standard, and reference QC analyses.
Data is collected both manually and electronically. At a minimum, the date,
time, sample ID, instrument ID, analyst ID, raw signal or processed signal,
and/or qualitative observations will be recorded. Comments to document unusual
or non-standard observations also will be included on the forms, as necessary.
The Test Data Collection Form presented in Figure 4 will be used for recording
data on-site. The on-site Project Team member will generate chain of custody
(C.O.C.) forms and these forms, which will accompany samples during shipment
to the respective labs. Raw data will be processed manually by the analyst,
automatically by an electronic program, or electronically after being entered into
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a computer. The analyst will be responsible for scrutinizing the data according to
laboratory precision, accuracy, and completeness policies. Raw data bench
sheets and calculation or data summary sheets will be kept together for each
sample batch. From the standard operating procedure and the raw data bench
files, the steps leading to a final result may be traced. The ETV-MF Program
Manager will maintain process-operating data for use in report verification
preparation.
Data Package Validation. The generating 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, conclusions, and
laboratory sample tracking information. A second 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, sample treatments, and
calculations are correct. After the package is reviewed in this manner, a
preliminary data report will be prepared, initialed, and dated. The entire package
and final report will be submitted to the Laboratory Manager.
The Laboratory Manager shall be ultimately responsible for all final data released
from the laboratory. The Laboratory Manager or designee will review the final
results for adequacy to task QA objectives. If the manager or designee 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 generating and reviewing analysts queried. If suspicion about
data validity still exists after internal review of laboratory records, the manager
will authorize a re-test. If sufficient sample is not available for re-testing, a re-
sampling shall occur. If the sampling window has passed, or re-sampling is not
possible, the manager will flag the data as suspect. The Laboratory Manager
signs and dates the final data package. The data analyzed shall be evaluated
through and will ensure
Data Reporting. A report signed and dated by the Laboratory Manager 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 laboratory sample ID, date reported, date analyzed, the
analyst, the SOP used for each parameter, the process or sampling point
identification, the final result, and the units. The ETV-MF Program Manager
shall retain the data packages as required by the ETV-MF QMP [Ref 3].
5.2.3 Calculation of Laboratory Data Quality Indicators
Analytical performance requirements are expressed in terms of precision, accuracy,
representability, comparability, completeness, and sensitivity (PARCCS).
Summarized below are definitions and QA objectives for each PARCCS parameter.
Duplicates and spike duplicates will be performed on one out of every ten samples.
Sample splitting will occur in the analytical laboratory.
5.2.3.1 Precision
Precision is a measure of the agreement or repeatability of a set of replicate
results obtained from duplicate analyses made under identical conditions.
Precision is estimated from analytical data and cannot be measured directly.
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The precision of a duplicate determination can be expressed as the relative
percent difference (RPD), and calculated as:
RPD = {(|Xi - X2|)/(Xi + X2)/2} x 100 =
|x,-x2
(X, +X2)
x 100
where, Xi = larger of the two observed values and X2 = smaller of the two
observed values.
Multiple determinations will be performed for each test on the same test
specimen. The replicate analyses must agree within the relative percent
deviation limits as specified in Table 7.
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Table #7: QA OBJECTIVES
Method of
Precision
Accuracy
Critical Measurements
Matrix
Method
Reporting Units
Determination
MDL
(RPD)
(% Recovery)
Completeness
O&G Concentration
Water
8015, modified
mg/L
GC-FID
200
<30
50-150
95
Sludge
8015, modified
mg/L
GC-FID
200
<30
50-150
95
Metals (Cu, Zn)
Water
200.7/200.9
mg/L
ICP-CID or ICP-
0.001
<35
80-120
95
Sludge
3050, 6010
mg/L
GF
0.001
<35
80-120
95
TSS/TS
Water
160.2/160.3
mg/L
Gravimetric
1.0
<30
80-120
95
Sludge
160.2/160.4
mg/L or % solids
Gravimetric
1.0
<30
80-120
95
TOC
Sludge
9060
mg/L
Conventional
1.0
<30
80-120
95
Water
Serial Dilutions
CFU/ml
Serial dilutions by
< 1.0
<75
75-125
90
Microbial Concentration
(TSA, YMA)
agar streak method
Sludge
Serial Dilutions
CFU/ml
Serial dilutions by
< 1.0
<75
75-125
90
(TSA, YMA)
agar streak method
Air
Visual
CFU/ m3
Visual
< 1.0
<75
75-125
90
Chemical Additions:
BioClean 20/100
Water
Stop watch
ml/min
-
-
< io
+5
90
BioClean T-Booster
Water
Stop watch
ml /min
-
-
< io
±5
90
pH+
Water
Flow meter
ml /min
-
-
-
±5
90
pH-
Water
Flow meter
ml/min
-
-
-
+5
90
Separator Flow rates:
Influent
Water
Stop watch
ml/min
_
_
< 10
+5
90
Effluent
Water
Stop watch
ml/min
-
-
< 10
+5
90
Temperature
Water
Thermocouple
°F (°C)
-
-
-
36(2)
100
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5.2.3.2 Accuracy
Accuracy is a measure of the agreement between an experimental determination and
the true value of the parameter being measured. Accuracy is estimated through the
use of known reference materials or matrix spikes. It is calculated from analytical
data and is not measured directly. Spiking of reference materials into a sample
matrix is the preferred technique because it provides a measure of the matrix effects
on analytical accuracy. Accuracy, defined as percent recovery (P), is calculated as:
P =
(SSR-SR)
SA
x 100
where: SSR = spiked sample result
SR = sample result (native)
SA = the concentration added to the spiked sample
Analyses will be performed with periodic calibration checks with traceable
standards to verify instrumental accuracy. These checks will be performed
according to established procedures in the contracted laboratory(s) that have been
acquired for the BioClean verification testing. Analysis with spiked samples will be
performed to determine percent recoveries as a means of checking method accuracy.
QA objectives will be satisfied if the average recovery is within the goals described
in Table 7.
5.2.3.3 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 the BioClean technology verification by
the use of consistent methods during sampling and analysis and by traceability of
standards to a reliable source.
5.2.3.4 Completeness
Completeness is defined as the percentage of measurements judged to be valid,
compared to the total number of measurements made for a specific sample matrix
and analysis. Completeness is calculated using the following formula:
Completeness = Valid Measurements x 100
Total Measurements
Experience on similar projects has shown that laboratories typically achieve about
90 percent completeness. QA objectives will be satisfied if the percent completeness
is 90 percent or greater as specified in Table 7.
5.2.3.5 Representativeness
Representativeness refers to the degree to which the data accurately and precisely
represents the conditions or characteristics of the parameter represented by the data.
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For the purposes of this demonstration, representativeness will be achieved by
presenting identical analyte samples to the specified lab(s) and executing consistent
sample collection and mixing procedures.
5.2.3.6 Sensitivity
Sensitivity is the measure of the concentration at which an analytical method can
positively identify and report analytical results. The sensitivity of a given method
is commonly referred to as the detection limit. Although there is no single
definition of this term, the following terms and definition of detection will be
used for this program.
Instrument Detection Limit (IDL) is the minimum concentration that can be
measured from instrument background noise
Method Detection Limit (MDL) is a statistically determined concentration. It is
the minimum concentration of an analyte that can be measured and reported with
99 percent confidence that the analyte concentration is greater than zero as
determined in the same or a similar matrix [because of the lack of information on
analytical precision at this level, sample results greater than the MDL but less
than the practical quantification limit (PQL) will be laboratory qualified as
"estimated"] MDL is defined as follows for all measurements:
MDL = t(n_isi_oc = 0.99) x S
where: MDL = method detection limit
s = standard deviation of the replicate analyses
t(n-u-a = o 99) = students t-value for a one-sided 99% confidence
level and a standard deviation estimate with n-1
degrees of freedom
Method Reporting Limit (MRL) is the concentration of the target analyte that
the laboratory has demonstrated the ability to measure within specified limits of
precision and accuracy during routine laboratory operating conditions [This value
is variable and highly matrix dependent. It is the minimum concentration that
will be reported as "unqualified" by the laboratory].
Quality Audits
Technical System Audits. An audit will be performed during verification testing by the
CTC QA Manager according to Section 2.9.3 Technical Assessments of the ETV-MF
QMP [Ref 3] to ensure testing and data collection are performed according to the test
plan requirements. In addition to the CTC Technical System Audit, the EPA Quality
Assurance Manager may also conduct an audit to assess the quality of the verification
test.
Internal Audits. In addition to the internal laboratory quality control checks, internal
quality audits will be conducted to ensure compliance with written procedures and
standard protocols.
Corrective Action. Corrective action for any deviations to established quality assurance
and quality control procedures during verification testing will be performed according to
section 2.10 Quality Improvement of the ETV-MF QMP [Ref 3],
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Laboratory Corrective Action. Examples of non-conformances include invalid
calibration data, inadvertent failure to perform method specific QA, process control data
outside specified control limits, failed precision and/or accuracy indicators, etc. Such
non-conformances will be documented on a standard laboratory form. Corrective action
will involve taking all necessary steps to restore a measuring system to proper working
order and summarizing the corrective action and results of subsequent system
verifications on a standard laboratory form. Some non-conformances are detected while
analysis or sample processing is in progress and can be rectified in real time at the bench
level. Others may be detected only after a processing trial and/or sample analysis is
completed. Typically, the Laboratory Manager detects these types of non-conformances.
In all cases of non-conformance, the Laboratory Manager will consider sample re-
analysis as one source of corrective action. If insufficient sample is available or the
holding time has been exceeded, complete re-processing may be ordered to generate new
samples if a determination is made by the Task Leader that the non-conformance
jeopardizes the integrity of the conclusions to be drawn from the data. In all cases, a non-
conformance will be rectified before sample processing and analysis continues.
6.0 PROJECT MANAGEMENT
6.1 Organization/Personnel Responsibilities
The ETV-MF Project Team that is headed by Concurrent Technologies Corporation
(CTC) will conduct the evaluation of BioClean's system. The ETV-MF Program
Manager, Donn Brown, will have responsibility for all aspects of the technology
verification, including appointment of a Project Manager, making ETV-MF Project Team
personnel assignments, and coordination of technology testing. The Project Manager
assigned to the BioClean verification is Dr. A. Gus Eskamani of CAMP, Inc. Dr.
Eskamani and/or his staff will be on-site throughout the testing period and will conduct or
oversee all sampling and related measurements.
A BioClean representative will assist in operating the system and will be on-call during
the test period for response in the event of equipment problems. AMTest Laboratories is
responsible for performing chemical analysis of verification test samples. AMTest
Laboratories is accredited by the state of Washington Department of Ecology for the
analyses identified in this Test Plan. U.S. Micro-Solutions will perform the biological
analysis of verification test samples. U.S. Micro-Solutions is accredited by the American
Industrial Hygiene Association Environmental Microbiology Proficiency Analytical
Testing Program. The Laboratory Manager or designee will be the point of contact.
The ETV-MF Project Manager and National Manufacturing 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 Pilot
Manager.
6.2 Schedule/Milestones
The schedule and milestones will be determined mutually by CTC and National
Manufacturing.
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6.3 Documentation/Records
All original documentation generated during verification testing (chain of custody forms,
data collection forms, analytical results, etc.) will be maintained at the CTC regional
office in Largo, FL.
7.0 EQUIPMENT
7.1 Equipment List and Utility Requirements
Equipment and utility requirements are identified in Table 8.
EQUIPMENT
Number Req'd
Type of Equipment
Comments
One (1)
Stress relieved polypropylene tank
Stainless steel frame (volume is 1780 liters)
One (1)
Lamella filter
Made of PVC
One (1)
Blower
One (1)
Transfer pump
1" internal thread pipe connection
One (1)
Primary heat control
Temperature controller, relay, temperature probe,
and level guard
Four (4)
Metering pumps w/ adjustable flow rates
For BioClean cleaner, tensides, pFl-, and pFl+
One (1)
pH meter and electrode
SPARE PARTS
One (1)
Electric supplemental heater
5000 Watts
Required Utilities
Utilities to include:
Electrical
• BioClean separator module 220 Volt, Single Phase, 30 Amp.
Air
• 3-5 cubic feet
per minute
Table 8: BIOCLEAN EQUIPMENT LIST AND UTILITY REQUIREMENTS
7.2 Monitoring/Sampling Equipment
All monitoring/sampling equipment to be used during testing is identified in Table 9.
Table 9: MONITORING/SAMPLING EQUIPMENT
Equipment
Purpose
Andersen N6 Single Stage Viable Particulate Sampler
Bio-aerosol sampling
8.0 HEALTH AND SAFETY PLAN
This Health and Safety Plan provides guidelines for recognizing, evaluating, and controlling
health and physical hazards that could occur during verification testing. More specifically, the
Plan specifies for assigned personnel, the training, materials, and equipment necessary to protect
them from hazards, and any waste generated. The National Manufacturing Hazcom/PPE
Plan/Program will be used throughout the BioClean verification testing.
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8.1 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 contact with a particular substance during verification testing. Hazard
communication will take place during training and will be reinforced throughout the test
period. All appropriate MSDS's will be available for the chemical solutions used during
the testing.
8.2 Emergency Response Plan
National Manufacturing has a contingency plan to protect employees, assigned project
personnel, and visitors in the event of an emergency at the facility. This plan will be used
throughout the project. All assigned personnel will be provided with information about
the plan during training.
8.3 Hazard Controls Including Personal Protective Equipment
All assigned project personnel and visitors will be provided with appropriate personal
protective equipment (PPE) and any training needed for its proper use, considering their
assigned tasks. The use of PPE will be covered during training.
8.4 Lockout/Tagout Program
National Manufacturing's lockout/tagout procedure will be implemented if necessary and
will be explained prior to performing such duties.
8.5 Material Storage
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.
8.6 Safe Handling Procedures
All chemicals and wastes or samples will be transported on-site in appropriate covered
containers. Emergency spill clean up will be performed according to National
Manufacturing procedures.
9.0 WASTE MANAGEMENT
The equipment will be tested on processes already in place and operating at National
Manufacturing. Any wastes that may be generated will be no different than those already
generated. Therefore, no special or additional provisions for waste management will be
necessary.
10.0 TRAINING
It is important that the verification activities performed by the ETV-MF Program be conducted
with high quality and with regard to the health and safety of the workers and the environment. By
identifying the quality requirements, worker safety and health, and environmental issues
associated with each verification test, the qualifications or training required for personnel
33
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involved can be identified. Training requirements will be identified using the Job Training
Analysis (JTA) Plan [Ref. 4].
The purpose of this JTA Plan is to outline the overall procedures for identifying the hazards and
quality issues and training needs for each verification test project. This JTA Plan establishes
guidelines for creating a work atmosphere that meets the quality, environmental, and safety
objectives of the ETV-MF Pilot. 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 Job Training
Analysis 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).
11.0 REFERENCES
1. US EPA Office of Research and Development, "Waste Reduction in the Metal Fabricated
Products Industry" EPA/600/SR-93/144, September 1993.
2. George C. Cushnie Jr., CAI Engineering, "Pollution Prevention and Control Technology for
Plating Operations " NCMS/NAMF, 1994.
3. Concurrent Technologies Corporation, "Environmental Technology Verification Program
Metal Finishing Technologies (ETV-MF) Quality Management Plan" December 9, 1998.
4. Concurrent Technologies Corporation, "Environmental Technology Verification Program
Metal Finishing Technologies (ETV-MF) Pollution Prevention Technologies Pilot Job
Training Analysis Plan" May 10, 1999.
12.0 DISTRIBUTION
Alva Daniels, EPA (3)
Timothy Callahan, BioClean USA
Dick Hall, National Manufacturing Company
Jackie Molina, National Manufacturing Company
A. Gus Eskamani, CAMP, Inc. (2)
Donn Brown, CTC (3)
Clinton Twilley, CTC
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Appendix A
National Manufacturing Plating Process Flow
NATIONAL MANUFACTURING STERLING, ILLINOIS
PLATING LINE PROCESS FLOW
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Appendix B
Organic Soil Analysis Chromatograms
36
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Appendix C
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
1. 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.
2. Equipment requiring special fire prevention precautions? (e.g. Class D
fire extinguishers)
3. Modifications to or impairment of building fire alarms, smoke
detectors, sprinklers or other fire protection or suppression systems?
4. Equipment lockout/tagout or potential for dangerous energy release?
Lockout/tagout requirements must be documented in Test Plan.
5. Working in or near confined spaces (e.g., tanks, floor pits) or in
cramped quarters?
6. Personal protection from heat, cold, chemical splashes, abrasions, etc..
Use Personal Protective Equipment Program specified in Test Plan.
7. Airborne dusts, mists, vapors and/or fumes? Air monitoring,
respiratory protection, and /or medical surveillance may be needed.
8. Noise levels greater than 80 decibels? Noise surveys are required.
Hearing protection and associated medical surveillance may be
necessary.
9. X-rays or radiation sources? Notification to the state and exposure
monitoring may be necessary.
10. 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.
11. 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.
12. Working at a height of six feet or greater?
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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:
ETV-MF Project Manager:
Will the operation or activity involve the following: Yes No Initials & Date
Completed
13. Processing or recycling of hazardous wastes? Special permitting may
be required.
14. Generation or handling of waste?
15. 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.
16. Contractors working in CTC facilities? Follow Hazard Communication
Program.
17. Potential discharge of wastewater pollutants?
18. EHS aspects/impacts and legal and other requirements identified?
19. Contaminants exhausted either to the environment or into buildings?
Special permitting or air pollution control devices may be necessary.
20. 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)
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Appendix D
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
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Appendix E
ETV-MF Project Training Attendance Form
ETV-MF Pilot Project:
Date
Training
Completed
Employee Name
Last First
Training Topic
Test
Score
(If applic.)
ETV-MF Project Manager:
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