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RE: Parts Washers


Thank you for the follow-up.  You offer a lot of insight into the project
that does not come across in the available reports.  Perhaps the IRTA study
should be lauded based on the available funding and the political
constraints they had to work under.  However, I do have concerns with
several of your statements.

I do not need to measure solvent and brake cleaner use.  This was not my
study.  My question regarding brake cleaner use was based on an interest in
knowing what was required to produce a visually clean part.  If the shop
felt it was necessary to pre-clean parts, then this should be counted
against the aqueous cleaner.

If you don't, you are changing the test conditions.  Without pre-cleaning,
you are saying that less than clean parts are acceptable.  And if you take
this position, why clean at all ?  Many parts can be wiped off with a rag
and you can get rid of all cleaning sinks.

Regarding trade-offs, the EDF/MWD LCA study was conducted in 1991.  It was
funded because all of the draft reports developed by the original SRRP team
vaguely talked about trade-offs and the need to look at the full life-cycle.
Hell, some of these draft reports even touted the use of TCA over aqueous
cleaners because its use did not switch impacts from one medium to another.
So much for their assessment.

When Jacobs took over the project, we wanted to move off the dime.  Rather
than talk about how complex it was to do a life-cycle assessment and throw
up our hands, we decided to just do it and see how far we could get.  We
weren't looking to prove the superiority of aqueous cleaners over
chlorinated solvents, we just wanted to account for as many tradeoff issues
as possible and try to conduct a rational assessment.  Now it is 1998, and
the quality of assessment hasn't improved.

And as a last point, did you read the public comments issued by the L.A.
County Sanitation District regarding Rule 1177 ?  They were against aqueous
cleaners because of past practices involving sewer dumping.  They are under
strict discharge limits and any increased loading could trigger the need to
install costly treatment systems.  The handling of the spent baths as
hazardous waste and the educational component of Rule 1177 was added in
response.  The EIR for the rule basically found that aqueous cleaners had to
be mandated in order to meet Federal air quality goals and that the AQMD
would work with the District if their discharge created a problem.  The AQMD
was silent when asked if this included the millions needed to upgrade the
POTW.  This hardly sounds like glowing support.

Guess this makes my four cents worth.


> ----------
> From: 	RLUDWIG@HW1.cahwnet.gov[SMTP:RLUDWIG@HW1.cahwnet.gov]
> Sent: 	Thursday, August 06, 1998 12:03 PM
> To: 	Callahan, Mike
> Subject: 	RE: Parts Washers
> *** Reply to note of 08/05/98 13:37
> 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,
> Thanks for your comments.  Since our "correspondence", John Sparks of
> USEPA has
> introduced some interesting information.  Here are some comments/answers
> to
> your latest message.
> As for accounting for brake cleaners, I believe that the Air Toxics Group
> of
> CARB is researching the use of brake cleaners, in auto repair shops along
> the
> same lines that they did for Perc in dry cleaners.         As for the use
> of
> brake cleaners for pre-cleaning, yes, that was not measured---how would
> you go
> about doing it?  An issue that has surfaced since SCAQMD passed rule 1171,
> actually before it actually passed, and is now being discussed in the Bay
> ARea
> as the BAAQMD looks into a similar rule, is the concern by major suppliers
> of
> mineral spirits and services and proponents of mineral spirits and other
> non-
> water based formulations for the health and safety of employees in auto
> repair shops and the environment who will be using water-based systems,
> with or
> without cans of brake cleaners.  I find this ironic since using mineral
> spirits
> where most workers do not wear gloves and are breathing the material every
> time
> they clean a part is not good for their health.  Yet, it's use is
> promoted. And
> as far as I have observed, there has not been a concentrated effort by
> these
> same "concerned" businesses and individuals to halt or decrease the use of
> brake cleaners with PERC in order to protect worker health and safety.
> Curious
> isn't it?  The fact that the dry cleaning industry has been mandated to
> capture
> as much perc as possible due to a variety of health and safety and
> environmen-
> tal issues makes one beg the question as to why perc brake cleaners are
> allowed
> at all.  And, why major suppliers of mineral spirits don't educate their
> clients as much as they are doing now to inform them of the cons of using
> water based cleaners.  The fact that spent mineral spirits can be
> "treated" w/
> or w/o brake cleaners seems to be irrelevant if the issue is air emissions
> and
> concommitant health and safety of people using the material.  Again, where
> has
> the discussion been for the measurement of brake cleaners with the
> existing
> mineral spirit systems?  Perhaps you should write a letter to S-K and ask
> them
> the same questions you are asking me.  I would be interested on their
> reply.
> Obviously the management, i.e., manifesting, handling, storage, and
> treatment
> of aqueous cleaners is an issue.  It was thoroughly discussed at the
> meetings
> held by SCAQMD with DTSC, Regional Water Quality Control Boards, local
> and environmental health departments before Rule 1171 was passed.  These
> trade-
> offs were discussed.  And, as in most waste minimization, source
> reduction, and
> / or p2 options, a choice was made that was not perfect, especially in
> terms of
> all the media.  HOwever, with rule 1171, there should be a substantial
> decrease
> in smog-generating VOCs &  improved worker health and safety from not
> placing
> their hands and not breathing mineral spirits.  Yes, there will be
> problems
> using water-based cleaners.  However, no one stepped forward during the
> rule
> 1171 hearings or provided SCAQMD any documentation as to major adverse H&S
> effects of using water -based cleaners or why they should not be allowed.
> The business practice of recycling mineral spirits to me is still a form
> of
> treatment and like pollution prevention involves trade-offs.  The fact
> that
> spent mineral spirts containing oil and w/ or w/o brake cleaners still
> removes
> the oil and then treats the contaminants does not make it closed loop.
> And if
> you track/measure/document the use of mineral spirits in the units to the
> recyling unit through the disposal of the still bottoms, it is not closed
> loop
> because you are always losing mineral spirits through evaporation &
> generat-
> ing smog.  And, you  are still treating the mineral spirits in the
> process.
> A major plus of using water cleaners is you can use them longer because
> you can
> remove the oil, unlike mineral spirits.  And yes, you do have to treat the
> spent baths which means they have to be manifested and cannot be
> milk-runned at
> this time.  that will probably be changing soon to allow the pick up in a
> manner similar to the pick up of mineral spirits.  The statutes and
> regulations
> are now being scrutinized to determine how best to handle these wastes to
> allow
> businesses using water based cleaners options similar to those now in
> place to
> companies that pick up recycled materials, i.e. mineral spirits.
> Addressing the issue of whether  a manufacturing process, in this case,
> the use
> of water based cleaning sludge in terms of it not being acceptable for
> land
> application and using this as a criteria for whether or not its use is
> accept-
> able strikes me as odd if the alternative is to use mineral spirits that
> generate  smog and exposes workers to it but, it is acceptable because it
> can
> be recycled and re-used.  What part am I missing here?
> As for doing trade-off analysis, what group/agency do you recommend?  I
> don't
> seem to recall this level of required analysis, measurement, health and
> safety
> requirements and scientifically-based peer reviewed documentation on the
> EDF-
> Metropolitan Water District SRRP study that looked at the use of
> alternatives
> to chlorinated solvents. If the same standards applied for that study that
> you
> want for the trade-off analysis of water based cleaners, than it never
> would
> have been written.As for incomplete trade-off analysis by IRTA and SCAQMD,
> I thought they did an adequate job considering the political climate and
> staff-
> ing at SCAQMD.  As for IRTA,   considering the amount of money they
> received
> from USEPA via the Environmental Justice grant, they did an excellent job
> bringing together the multi-media issues, costs to businesses, and
> real-time
> regulations as they would affect auto repair shops.  I disagree that the
> hard
> questions were dismissed out of hand.  Decisions were made by SCAQMD  and
> wrote their report based on available information.  One could argue that
> more
> research should have been done and more analysis should have been
> completed
> and it should have addressed more issues in more depth.  Yes, that would
> have
> been admirable but unrealistic.  Yes, SCAQMD made a decision to go with
> water.
> Other state agencies addressed their concerns and supported the measure.
> And, along the same lines, I would be interested in learning how you
> adequately addressed and documented fairly the use of mineral spirits in
> terms
> of air quality, worker health and safety and to the surrounding community,
> and
> the distillation/recycling, and incineration of the still bottoms
> containing
> metals.  Land farming of baghouse wastes is also a consideration.  And to
> quote
> you, it is one thing to say its ok, its another thing to prove it.  So, as
> your
> corresponce was sent and received in terms of information sharing, I am
> open
> to hear how you are going to prove it using the same high and fair
> standards.
> Best regards,
> Robert Ludwig
> E-Mail:  HW1.RLudwig@ HW1.CAHWNET.GOV