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Core Cleaning: A Closer Look at the Issues and Regulations That Are Driving Today’s Market
By Tom Glover
On the list of hot button issues in the engine rebuilding business, the disposal of waste usually takes a backseat to supplier consolidations, market share position, profitability and other topics. On the other hand, the amount of time, effort and money that rebuilders spend, all of it non-productive, in meeting regulatory requirements can be significant. The bottom line is, sound waste disposal practices can save money and keep people in this business out of trouble.
Compared to many other industries, the nature of the waste generated in rebuilding internal combustion engines and other auto components is not highly toxic or hazardous in the quantities typically produced. But it can be both, and one should never assume that the EPA and various state environmental agencies, not to mention local water treatment facilities, aren’t watching the rebuilders’ waste stream very carefully.
But exactly what are the EPA, state agencies and municipalities monitoring in any particular company’s waste stream? Such a list can’t be made in the space we have, as permissible part-per-million (PPM) levels of various cleaning chemicals vary between states and even between municipalities within states.
Don Jennings of Memphis, TN-based Interchem Corporation, a supplier of chemicals used in spraywashers and dip tanks, said he is often asked about allowable ways to discharge the spent chemicals he supplies, to sewer systems. "We encourage our customers to contact their local wastewater authority to find out what their local rules are," he said. "We’ve found that in some areas, as long as it’s a neutral solution, they don’t care. In other cases, they insist that it be tested because of concern about heavy metals that may be in the solutions."
That being said, there is a source of information for the rebuilder who wants to know what’s hazardous and what’s not, and many of the rules and regulations regarding environmental issues. The Coordinating Committee for Automotive Repair (CCAR) offers a web site at www.ccar-greenlink.org which has a wealth of environmental information compiled especially for those in the automotive industry. "We’re really a very narrowly focused site," said Sherman Titens, executive director of the CCAR-Greenlink program. "We get about one million hits on our website a year, and we also provide information by telephone (913-498-2227) of fax (913-498-1770).
The website describes CCAR as a partnership of industry, education and government with more than 200 members. Babcox Publications is one of them, as is the Engine Rebuilders Association (AERA) and the Automotive Parts Rebuilders Association (APRA). "The federal government funds us, so we can provide all of this information to the industry without their having to pay for it," said Titens. "As far as I know, we’re the only authorized repository of federal environmental information, so the information is current and comprehensive."
Generally, what waste there is in rebuilding is generated in cleaning operations. The first and most obvious wastes are petroleum products like grease and oil. They can be handled relatively easily by being burned off, skimmed or encapsulated, and despite the bad things that crude oil does to beaches, fish and seabirds, the EPA has ruled that used oil and grease is not hazardous.
However, the chemicals used in helping to get the oil and grease off of used automotive parts, such as highly caustic sodium or potassium hydroxides used in spraywashers typically carry a pH factor of about 12, and are thus considered hazardous in an untreated state. Some of the larger rebuilders treat the spent spraywash liquids onsite to bring their pH levels down to "sewerable" levels.
The main concern from an environmental standpoint is focused on some of the metals that are removed from ferrous and non-ferrous auto components through baking, blasting and spraying.
The material that’s really on the EPA’s radar screen are the trace amounts of chromium, lead, mercury and other metals that can be classified as hazardous, depending upon their concentrations. These are commonly referred to as RICRA (pronounced "rick’-ra") metals, so named because they appear on the Resource Conservation Recovery Act’s list of potentially hazardous metals.
No matter what cleaning method is used – soaking, baking, spraywashing, blasting or even submersion in molten salt – metals that are washed out of or leached from automotive components in the process of being cleaned will eventually have to be disposed of. As one cleaning equipment supplier put it, "Once you get rid of the water, you end up with the same material, whether you’ve heat cleaned or chemically cleaned your parts. The same waste is just in different forms at different times."
Generally, suppliers offer three types of cleaning machines: ovens; spraywashers; and blast cleaning cabinets, as well as dip tanks. Most machines also incorporate ancillary devices such as afterburners on the ovens, sludge scrapers on the jet washers and filters on blast cabinet exhausts to make it easy to keep the waste in it’s place, if not get rid of it altogether.
Indeed, better ways to isolate and remove waste is a value-added feature that cleaning equipment manufacturers use to help sell their products. The MART Corporation St. Louis, MO, for example, a manufacturer of powerwasher systems, recently introduced its EQ-1 machine that can be used on MART-manufactured or any other washer or dip tank to remove oils and debris from liquid cleaning solution charges, thus extending their useful life. As MART president, Gary Minkin, explained, the dirty cleaning solution is pumped into the freestanding EQ-1 wastewater treatment system.
Two or three pounds of a proprietary, application specific flocculent, which the company refers to as "magic dust" is added and mixed in resulting in an "explosion" that captures everything that is not water or chemical. It then ties it up so that it either drops to the bottom or floats to the top where it’s easy to remove.
"The waste then gets rolled up like a burrito which cures and dries out," Minkin said. He went on to explain that the dried chunk of waste has no trouble passing the TCLP (Toxicity Characteristic Leachate Procedure) test, a procedure that ultimately determines where certain kinds of waste can be landfilled by simulating exposure to acid rain and measuring how much of certain elements leaches out of solid materials.
Most shops have contracts with waste haulers (they prefer to be called environmental services companies) who call on rebuilder’s shops on a scheduled basis to pick up their barrels of sludge, dust, or solidified waste. It’s the service company’s responsibility to decide where it will be taken, and whether to bury it, incinerate it, or in the case of hazardous wastes, subject it to some secondary treatment before it’s buried or burned. Since they’re responsible for what happens to your waste after it leaves your premises, they’re most interested in its contents.
Typically, such organizations charge fees to develop a profile of the nature of your waste, based on a laboratory analysis which you, as a waste generator, are required to provide. Beyond that point, they will take over most of the work, including making up the manifest of what’s being shipped out. They will also, within certain limitations, take over the responsibility for what happens to your waste.
Clean Harbors Environmental Services is one of several such waste haulers and processors that operate on a nationwide basis. David Proud, manager of marketing, spoke of his company’s services, as you would expect a marketing manager to do. But he also pointed out that it’s the waste generator’s responsibility to know what their waste contains.
"The waste generator customer supplies us with the analytical information, and we assign profiles for them based on the content of their waste," Proud said. "Then they sign the profile sheets attesting that what these profile sheets say is true." Proud went on to explain that the profiles have to be recertified on an annual basis, but if the process hasn’t changed, there’s no need for reanalysis or retesting.
Proud said that while the EPA set up the environmental regulations, the federal government has pushed the enforcement of the regulations out to the states. "Some states have taken the EPA regulations as they are, but others have added their own regulations to them, or modified them to fit their own needs," he said, adding that the states haven’t watered down any of the EPA regulations. "If anything, the changes the states make beef them up."
One of the scary things about environmental laws is the concept of "cradle-to-grave responsibility" on the part of the generator of hazardous waste. In short, it means that the generator of the waste, not the party that hauls it away or decides where to bury it, is responsible for damages it may cause to the environment or to humans.
Attorney Larry Johnson of the EPA’s Region Five office in Chicago, IL, explained that the concept grew out of the infamous Love Canal issue, and was later incorporated into the Resource Conservation and Recovery Act.
We’ve all heard the horror stories about companies who complied with environmental laws that existed at the time the wastes went into the ground, but years later were forced to pay fines and clean up costs even though they didn’t choose how and where the wastes were buried.
However, Johnson pointed out that although the generator is ultimately liable under the law, it’s common practice for the generator and the waste hauler to make legal agreements about who is going to pay any fees, fines and court costs involved should the waste cause environmental problems.
"That’s the way a lot of transporters get business," Johnson said. "They go to their customers and say, "You give me your waste. I know what I’m doing, and if the government comes after you, I’ll stand in front of you and protect you.’"
And that’s exactly what happens when rebuilders make contracts with environment service companies. It’s also the reason why the generator of the waste needs to have it tested so that both parties know exactly what’s in the waste. "The RCRA guidelines say that a generator of hazardous waste is responsible for their material, from cradle to grave," noted Proud of Clean Harbors."But when we pick up the waste, we take title to it, and indemnify the customer from responsibility. We will then protect them from future liabilities."
Not surprisingly, volume determines whether the disposal of waste from parts cleaning operations is a cost or labor burden. The attitude of rebuilders we talked to ranged from those who are hardly aware that there are rules, to those who have environmental managers on staff to keep track of what the regulatory agencies require and make sure they don’t violate any of their rules and protocols.
At a four-employee rebuilding shop such as The Able Company, Wyoming, MI, waste management isn’t a front and center concern. "We have a bake and blast procedure and a jet cleaner, but the jet cleaner is really the only thing that generates any waste," said manager, Ray Krebill. "I think we can run it for about two years before we have a waste hauler come in and suck it out, and then we start over," he said, adding that "we had to get a disposal number from the Michigan Department of Natural Resources (DNR) when we started the operation, but we’ve never yet had anybody come in and inspect anything."
This is in marked contrast to another large Midwest remanufacturer, Jasper Engines, which now has two facilities in southwest Indiana, and a five-person environmental staff. The company’s main remanufacturing plant is located in Jasper, and another two-year old facility in nearby Crawford County, IN. Both have extensive floor drain systems and in-house pre-treatment facilities where the pH levels of the spent cleaning solutions are brought down from 12 to between two and three. Coagulating agents are also added to make the waste form into chunks and a filtration and clarifier system allows them to dump clean water into their sewers.
Jasper Engines is primarily a high volume engine and transmission remanufacturer that has gone to a molten salt cleaning procedure as an alternative to baking ovens. "With the Kolene Salt Bath system, we’re cycling parts through in 15 to 20 minutes instead of six to eight hour oven cycle times. When you pull the parts out of the salt, there’s no ash on the products at all," explained Jasper Engines’ production manager, Mike Schwenk.
But the waste created in molten salt cleaning is somewhat different in that the dried-out sludge has a lot of salt in it, which Jasper has been able to recycle. "Because we’re using a lot of soaps, the liquids have a relatively high pH," Schwenk said, "so we use the salt waste from the Kolene machines to neutralize the pH, after which we filter and clarify the waste water before it goes into the local municipal drain."
Aarons Automotive Products Springfield, MO, another production rebuilder with an environmental compliance manager on staff, has spraywashers, ovens and shotblasters, as well as heated soak tanks that use minerals spirits. As in many rebuild shops, the soak tanks are the first stop for dirty used parts, and that’s where the majority of metals on the RICRA list of hazardous materials are removed from the parts.
"The residue from the solvent still-bottoms is the only hazardous waste we have here," said Aaron’s environmental compliance manager, Leejean Hobbs, adding that their still allows them to recycle 400 gallons of mineral spirits in a 24-hour period. "We de-water our sludges, and have everything tested to make sure it’s non-hazardous," she said. We’ve also learned that if we clean out the machines more often and more thoroughly, we don’t have a lot of sludge build-up."
Waste disposal concerns for some people in the rebuilding business, such as core suppliers who store engines, transmissions and other component cores outdoors, often center around storm water runoff. The cores that come into Enginequest’s, Las Vegas, NV, facility have already served one useful life, during which time they’ve accumulated a lot of oil and grease which washes off whenever it rains (which it does in the desert, although not as often as at Enginequest’s Chicago, IL, location).
"Our storm water discharge cannot be more than 10 parts per million because we have separate storm and sanitary sewers here," said Enginequest president, Scott Stolberg. "The entire outside storage is on concrete, and it all drains to one point," he explained. "The first step is a filter system of six, 55-gallon drums full of activated carbon. Then it goes into a triple trap system, meaning that it has three chambers. In the final chamber, there’s some oil absorbent pillows in case any petroleum does get through."
Stolberg remembers that "we went through hell before we designed this system that works to where our test results every month are so good that the state of Nevada uses us as the example of what other people should be doing."