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RE: Parts Washers -Reply



John,

Thanks much for your informative reply.  Changes in regulations always pose
opportunities for new business and a shift in the status quo.  Let's hope
its for the better.

You're right about PERC and METH.  I didn't mean to imply they were VOCs.
However, I am concerned about the whole concept of delisting.  Users tend to
be lax when something is removed from regulation.  I also find it
interesting that the cleaning industry is pushing for delisting so that some
solvents can still be used.  Acetone as a wipe cleaner in the aerospace
industry comes to mind.  This is the complete opposite to the coating
industry that pushed to treat almost all organics as reactive VOCs to reduce
material tracking and reporting complexity under the old Rule 66.  The
pendulum swings.

I'm also interested in the use of boric acid as a corrosion inhibitor.  As
anyone looked at the long term impact to bearings ?  Brake drums are
designed to wear so a trace film of boric acid wouldn't cause harm.  But a
bearing is greased after cleaning.  This would trap the acid and place it in
contact with the roller.  I believe the DoD requires multiple rinses with DI
water following aqueous cleaning.  They then subject the bearing to
extensive testing.  This goes way beyond a "visually clean" test.

I'm sure there will be more to follow on this topic.  Maybe we do need a P2
chat room.  Regards.

Mike.callahan@jacobs.com

> ----------
> From: 	JOHN SPARKS[SMTP:SPARKS.JOHN@epamail.epa.gov]
> Sent: 	Thursday, August 06, 1998 7:57 AM
> To: 	RLUDWIG@hw1.cahwnet.gov; Callahan, Mike
> Cc: 	p2tech@great-lakes.net
> Subject: 	RE: Parts Washers -Reply
> 
> I have been following this ongoing discussion of parts washers with
> great interest.  I am beginning to think that this would make a great
> topic
> to start a P2 "CHAT ROOM ".  I believe there are several hundred
> thousand parts washers in small and medium sized businesses across
> the country and eventually all will be affected by regulations. 
> 
> The disruption of the classical sink on a drum degreasers is also
> providing opportunities for the new entrepreneurial startup firms.  The
> enzymatic and bioactive aqueous units look very interesting as do the
> low maintenance membrane aqueous technologies. It seems that the time
> has come to  introduce cleaner technologies to these small/medium
> businesses, especially if it is at a reasonable cost.  
> 
> Some solvent vendors are  offering "closed loop " solvent parts cleaners
> that reduce a facilities VOC emissions.  These systems also have build in
> solvent recycling abilities that extends the working life of the original
> solvent charge.  
> 
> In terms of tradeoffs, I think the traditional sink on a drum business was
> dominated by a few major companies that bundled reverse distribution
> with their service offering - picking up the used  solvent for recycling
> and reclaiming the greases/oils etc for re-refining or use as fuel
> additives
> and proper disposal of hazardous residuals.  Assuming that this solvent
> driven, reverse distribution network will deteriorate, alternative
> disposal
> management schemes that service these small businesses are needed.
> The tradeoff being : switching to low/no voc degreasers, but losing the
> established solvent driven reverse distribution network.  Both offer
> significant environmental benefit.
> 
> A few technical comments:
> 
> Of the common chlorinated solvents, PERC is not a VOC (at least on the
> Federal level) because it was delisted in the last few years.  Likewise,
> methylene chloride is exempt. TCE is a VOC. All are HAPs and OSHA has
> issues with them as well.   I don't think many - if any - aqueous cleaners
> use sodium or ammonium molybdate as a rust inhibitor, but  Moly/NO2 is
> used for this purpose in cooling towers.   The most common rust
> inhibitors in aqueous formulas are amines of carboxylic acids and boric
> acid.  
> 
> The typical aqueous cleaner will have surfactants, water conditioners,
> rust inhibitors and coupling agents.  Some contain water soluble solvents
> like glycol ethers and terpenes.  I think ingredients to be discouraged
> include:
>       - alkyl phenol ethoxalate surfactants
>       - water soluble organic solvents.  These are VOCs too.
>       - phosphates.
>       - some glycol ethers are problematic worker exposure/human health  
>          issue.
>       - EDTA and other strong chelates.  These tend to hold heavy metals
> 
>         over a wide pH range, alkaline and acid, and interfere with
> 
>          precipitation in waste treatment. Gluconates may be a better
> 
>          choice.
>        - in direct discharge to lakes, river and streams terpenes may not
> 
>         volatilize and could create a aquatic toxicity problem. Hopefully,
> no   
>          one discharges their degreasers in this manner.
> 
> Other concerns and  local issues could expand this list.
> 
> My contribution. end.
> 
>  
> John O. Sparks
> USEPA
> Design for the Environment
> MC 7406
> 401 M St. , SW
> Washington, DC 20460
> Telephone 202-260-1682
> FAX 202-260-0981
> e-mail sparks.john@epamail.epa.gov
>