[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]

RE: Parts Washers



Robert,

Thanks for the reply.  I did read the report but did not see detailed
answers to my specific questions.  I'll have to go back and recheck.

As you said, IRTA recommended that brake cleaners not be used. But they
were.  And if they were being used to preclean the parts, their emissions
must be accounted for.  It also occurs to me that brake cleaners may be used
to dry the parts.  I'm not saying they were, only that they might be.  This
is something that needs further investigation.

I also see the handling and disposal of the spent baths as an issue.  With
mineral spirits, the spent bath may be recycled for reuse.  Chlorinated
solvents due to brake cleaner use will either be recovered with the solvent
or be sent off for incineration with the still bottoms.  Except for air
emissions, the handling of the waste tends to be closed loop.

The treatment of a spent aqueous bath may or may not adequately address the
presence of VOCs such as PERC depending on the treatment system employed.
The corrosion inhibitors may also cause a problem. Someone on P2TECH
reported how Moly concentrated in bio sludge and rendered it unsuitable for
land application.  The full disclosure of formulation becomes much more
important when something is used in an open system. 

I agree that one should look at the health and safety risks of using
solvents versus aqueous cleaners and do the trade-off analysis before
picking one over the other.  That is why I proposed to include regional
water quality impacts and regional solid waste management impacts into the
state's certification protocol for alternative cleaning chemistries.

My concern with the IRTA study and the SCAQMD rulings is that the trade-off
analysis is incomplete.  The difficult questions are dismissed out of hand
while all importance is placed on the elimination of air emissions.  This
creates a bias against solvents that has no place in a fair assessment.
Perhaps my concerns are unfounded, but the documentation that these issues
have been adequately addressed is just not there.  It is one thing to say
it's ok, it's another thing to prove it.

Just my two cents.

Mike.callahan@jacobs.com

> ----------
> From: 	RLUDWIG@HW1.cahwnet.gov[SMTP:RLUDWIG@HW1.cahwnet.gov]
> Sent: 	Wednesday, August 05, 1998 10:25 AM
> To: 	Callahan, Mike
> Subject: 	RE: Parts Washers
> 
> *** Reply to note of 08/04/98 16:49
> FROM: Robert Ludwig__P (916) 324-2659  FAX (916) 327-4494
> OPPTD/DTSC  P.O. Box 806  Sacramento, CA 95812-0806
> E-Mail:  HW1.RLudwig@ HW1.CAHWNET.GOV
> Subject: RE: Parts Washers
> Michael,
> Have you read the report, Parts Cleaning in Auto Repair Facilities:  The
> Conver
> sion to Water? Many of the questions you asked are answered in detail.
> HOwever,
> here are some quick/general answers.
> 
> How much (?) brake cleaner was used to preclean the parts?  No
> pre-cleaning of
> parts was ever recommended by IRTA during the study.  Parts were soaked
> before
> cleaning just like they are when using mineral spirits. As for the use of
> brake
> cleaners, all participants in the study were encouraged not to use brake
> cleaners over and in the equipment because of H&S issues, air quality, and
> the
> likelihood of contaminanting the aqueous bahts.  However, there is no way
> to
> keep them from using the material.  As aerosol cans of brake cleaners are
> now
> used on parts being cleaned on sink-on-a-drum units filled with mineral
> spirits
>  the amount of brake cleaner may be more. During the study, workers were
> encouraged to pre-soak the parts in the aqueous cleaner.  Just as they did
> when
> using mineral spirits.
> 
> As for SCAQMD downplaying the use of brake cleaners, from the meetings and
> work
> shops I have attended with SCAQMD,  SCAQMD has strongly recommended that
> shops
> not use brake cleaners because they are VOCs and will impact the air
> quality.
> SCAQMD cannot ban the use of brake cleaners but CARB may be evaluating the
> use
> of brake cleaners containing PERC.  SCAQMD agrees with you that it doesn't
> make
>  any sense to replace a high VOC cleaner, i.e., mineral spirit, with a
> system
> that "needs"  a VOC cleaning agent.  Parts are being cleaned with aqueous
> cleaners and alternatives to brake cleaners are being developed.  SCAQMD
> made
> an effort to work with the POTWs and DTSC to address the multi-media
> issues
> before Rule 1171 was passed.  AGain, this is covered in the report.
> 
> How are the spent baths handled, with or without brake cleaners?  By the
> same
> hazardous waste treatment businesses that now manage water and oily wastes
> that
> most likely contain organic compounds similar to VOCs. The mineral spirits
> contaminated with brake cleaners, dirt, and metals were a hazardous waste
> too and manifested and transported as a hazardous waste to a recycler
> which
> also involved hazardous waste treatment, so some aspects have not changed.
> 
> As to the corrosion inhibitors, I do not know what the specific components
> are.
> During the study all participants were encouraged to wear protective gear
> when
> using the equipment.  But, let's get real.  What auto repair person that
> you
> know of or when you when into an auto repair shop was wearing gloves while
> washing a part with mineral spirits?  Ever?  Katy and Mike also
> recommended
> that the cleaners used were at or   near a neutral pH because they knew
> the
> employees would not wear gloves. Also, the recommended temperature in the
> baths
> was 110 degrees F to protect workers hands as well.  Again, unless the
> unit is
> designed to limit the water temperature, workers will probably set the
> tempera-
> ture at level the is not good for their hands.
> 
> If you are interested, you could contact the manufacturers of aqueous
> cleaners
> and request their MSDS's.  I would also hope you research for health and
> safety
> issues the myriad of "environmentally-friendly" alternatives to aqueous
> based
> cleaners.
> 
> 
> Hope the above is useful.
> Robert
> 
> Best regards,
> Robert Ludwig
> E-Mail:  HW1.RLudwig@ HW1.CAHWNET.GOV
>