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Waste Minimization: Ways To Reduce, And Even Eliminate, Hazardous Wastes From Your Cleaning Process

By Ed Sunkin

Managing your shop's wastes shouldn't be hazardous to your business. Although there is a lot involved with managing wastes from cleaning operations including operating costs to disposal requirements, the good news for rebuilders is that there are ways to reduce, and even eliminate, hazardous wastes from your cleaning process.

According to the Environmental Protection Agency (EPA), materials and wastes of most concern to rebuilders are organic solvents - ignitable, corrosive and or toxic materials, and wastes that contain heavy metals, especially lead. It should be noted, though, that material isn't considered hazardous waste until it is ready to be disposed of. For example, a caustic cleaning solution that contains heavy metals in a hot tank is not considered hazardous waste until it is ready for removal.

Once the shop is ready to dispose of the solution, it must be handled accordingly to EPA guidelines. For example, if your shop generates 100 kilograms (220 lbs. or about half of a 55-gallon drum) or more of hazardous waste per month you must fill out a Uniform Hazardous Waste Manifest when you ship hazardous waste off your property. The manifest requires the proper Department of Transportation (DOT) description for each waste.

Although the EPA says it is the owner's responsibility to determine whether the waste is hazardous, the owner must have adequate test results to provide the EPA. The testing of hazardous wastes can be performed by any qualified laboratory that tests drinking water. Rebuilders should contact the lab to determine how samples should be taken and shipped for accurate test results.

Wayne Andersen of Andersen Metal Products, Adelento, CA, said it's important for rebuilders and machine shops to keep up with waste disposal guidelines. "The requirements for waste removal depend on the city or county where the shop's located," he said. "Rebuilders definitely need to contact their local waste water treatment facility for specific waste removal requirements. If you don't adhere to EPA requirements, you can spend a lot of money in fines."

Rebuilders who produce any wastewater should contact their municipal sewerage agency regarding hook-ups to a municipal waste water treatment facility. Shops also may need to contact their state agency with responsibility for the Underground Injection Control (UIC) Program or EPA regional office covering their state. EPA prohibits the discharge of wastewaters into separate storm sewers and permits certain storm water discharges under the authority of the Clean Water Act. Depending on what is in the wastes your shop generates, your facility may also be subject to regulation under the Resource Conservation and Recovery Act (RCRA), also known as the hazardous waste regulations.

Andersen explained waste disposal procedures and costs will vary by what area of the country a shop is located. Some states are more strict when it comes to disposal procedures and costs. "In Northern California, you can't dump mop water down the drain, and you have to recycle the used water after washing your company's vehicles," Anderson said. "That's why when it comes to wastewater, we recommend reusing it by recycling."

Gus Enegren, president of Viking Corp., Wichita, KS, said disposal costs are the major reasons shops should look toward creating a hazardous waste minimization process. "The costs rebuilders face to dispose of wastes are out of hand," Enegren said. "In states like California, Florida and New York, rebuilding shops get hammered for disposal costs. Some of my customers say they're paying about $1,500 a barrel to dispose of waste."

Enegren said that in many cases the waste removal technology of the rebuilding industry is stuck in the 1950s and that there needs to be more research done by manufacturers on waste reduction processes and procedures. "For the most part, what we're seeing now is boiling off the water to reduce wastes to a clay form, then letting someone dispose of it. There's so much more we could do than what's happening today," he said.

Doug Anderson, vice president of Grooms Engines, Parts, Machining, Inc., Nashville, TN, said because of the high costs and the responsibilities associated with hazardous waste disposal, his shop spent five years on a hazardous waste reduction plan. Anderson said after carefully analyzing cleaning processes and making a number of changes, Grooms Engines was able to totally eliminate the need to ship any hazardous wastes off-site for disposal. "We started out looking for ways to minimize our hazardous wastes and ended up with nothing," Anderson said.

Anderson said although the results may vary depending on the cleaning processes your shop uses, the basics of a waste minimization plan should work for any machine shop or rebuilding operation.

One of the simplest ways to reduce wastes is through on-site filtering processes. When the cleaning solution gets dirty, rebuilders can separate the liquid cleaning agent from the sludge using a variety of equipment offered by manufacturers.

Derek DuVall, sales manager for Steelabrator Cleaning Systems, San Antonio, TX, said the addition of filtration systems has improved waste management in shops. "When you can filter the grime out, you can extend the life of your cleaning solution, which will save a shop money," DuVall said. "Of course you still need to dispose of the filtered waste properly, but filtration can double and even triple the life of the cleaning agents."

DuVall said during the past year, Steelabrator developed a portable filtration unit that can be moved to washers or hot tanks throughout the shop. "We've seen that using a filtration unit on cleaning equipment that wasn't designed with one originally can help shops reduce their costs of removing what may have been 50 to 150 gallons of wastewater to about three or four pounds of sludge."

"A lot of the older cleaning equipment that's used in shops today was developed without filtration systems, so the technology provided in a portable unit is very helpful," DuVall said.

Oil skimmers are another popular option for removing sludge, contaminates and floating tramp oils from parts washers, tanks or other aqueous equipment. Designs include rotating disks that attract oils to belt-type devices and movable "arms" that skim oils from the solution surface.

Another process to reduce wastes is recycling. Delores Shaver, industrial services manager for Ecolink, Tucker, GA, said her company often receives inquiries from customers who have purchased parts cleaning solvent wanting to know if the solution can be recycled.

Shaver said there are three issues a shop needs to address for recycling, the first being, "Is the solvent able to be recaptured?" Shaver said if it is sprayed or wiped on a surface, it may be too hard to recapture enough to recycle. But material used in dip tanks or washers where runoff can be recaptured, makes recycling sense.

Second, determine if the used solvent can be decanted, filtered or distilled. Shaver said many rebuilders only think of distilling when they think of recycling. "In fact, solvent life can be extended dramatically through the proper application of mechanical separation technology," she said. "Further, if separation technology can be used, the economic return factors may be much more attractive."

The final issue is the boiling point of the spent solvent. Shaver said if the solvent has a high boiling point, greater than 200¡ F, which is the case for most environmentally preferred solvents, distillation will need to be performed under vacuum to minimize thermal decomposition of the material. "Obviously, the equipment required to perform distillation costs more money, hence the return on investment may be longer," Shaver said.

There is a simple test to determine if a mechanical separation method (decanting, centrifuge or filtration) is applicable for your shop. Take a pint sample of the spent solvent and place it in a glass jar where it won't be disturbed. Observe how long it takes for the "soil" to begin to settle out of the liquid. Shaver said if you can see a separation (the more pronounced the better) within 24 hours, a mechanical method of solvent recycling may work for your shop.

"If the liquid remains cloudy without pronounced separation, you are probably going to need to use a traditional distillation process to recycle the solvent," Shaver said. This will require an investment in distillation equipment if you wish to recycle on-site, or use of an off-site supplier of distillation services."

Many rebuilders and machine shops have taken advantage of these off-site distillation services. For a monthly fee, solvent service companies will pick up dirty solvent, clean and maintain the solvent sink, and refill the sink with clean solvent. Depending on the arrangement, solvent sinks may be owned by the shop or leased from the solvent service company. The cost for contracting with a solvent company for "cradle-to-grave" services is often less than the combined cost of solvent purchase, tank maintenance and waste disposal.

David Simon, of Euro-Drive Clutches, Inc., a Burlington, Ontario, Canada, clutch rebuilding facility, said because of the asbestos materials used in clutch facings, cleaning and waste removal is the highest production cost for clutch rebuilders. "Instead of reclaiming the used solvent at our shop, we use one of those solvent service recyclers who pump out used cleaning solvent and replenishes our equipment," Simon said.

Simon said his company spends about $350 a month for the service. "If we recycled the solution ourselves, I'm sure we could save large amounts of money. But for our shop, it's just more practical to let someone else deal with it. Waste disposal is becoming very complicated."

To help rebuilders and machine shops get a better understanding of requirements in waste disposal, many manufacturers" and suppliers" service-related businesses offer hazardous waste disposal information. Safety-Kleen, the Elgin, IL, industrial service company that provides fluid waste recycling for rebuilders, for example, offers free half-day regulatory compliance seminars at its home office. According to Safety-Kleen, the seminars help companies deal with complex OSHA, EPA and DOT regulations. Up to four people from the same facility may attend the seminar, which is included with the purchase of the company's, Introduction to Regulatory Compliance: A Guide to OSHA, EPA and DOT Regulations Kit. The kit includes a 400-page reference guide; update bulletins are issued to kit owners every six months to address timely issues and newly enacted regulations.

Richard Bravieri, manager of marketing services for Safety-Kleen, said simplifying waste disposal is an important issue for rebuilders. Bravieri said while a rebuilder or machine shop can hire separate firms to transfer, store and dispose of wastes, managing all of those companies can take up valuable time. "There's just too much activity going on in today's automotive facilities," Bravieri said. "People get so busy that what happens is that 'islands of automation' are created that develop independently of each other. Despite the need to be linked electronically to maximize efficiency, they remain islands and create inefficiencies and lost opportunities for the shop."

Bravieri said often these separate companies become many more islands, often operating independently, and sometimes offering the shop a premium in the form of paying for overlapping services not used or services overlooked. He said rebuilders looking for a waste management service should look to one that can provide expert environmental management. "The expert company not only knows and understands all the federal and state environmental permits and regulations required for the shop's operations, it should provide hands-on help in keeping the facility in compliance," he said.

The Safety-Kleen seminars are held each month throughout the year at local hotels around the country. For more information on the seminars, contact Safety-Kleen at 800-669-5740, ext. 2497.

As more stringent EPA and OSHA regulations develop, some cleaning chemicals are becoming harder, as well as more expensive, to dispose of. Of the types of solvents used in today's cleaning systems, water-based solutions are the easiest to dispose of because much of the waste volume can be evaporated. "Water-based solvents greatly reduce the disposal costs of chemical cleaners associated with many parts washers," Andersen Metal Products" Andersen said.

Duane Howard of A.R.E. Industries, Wichita, KS, said more rebuilders are switching to less hazardous detergent-based cleaners, adding that aqueous cleaning technology available for today's parts is very reliable. "If you have the right temperature and the correct cleaning time, you really don't need those harsh chemicals," Howard said.

Operators should check that the type of cleaner used consists of surfactants that are good detergents but are poor emulsifiers (stable oil emulsions limit reuse of the cleaner and hasten its disposal).

The industry is also seeing an increase of thermal cleaning equipment in the shop as a way to reduce wastes. Manufacturers of thermal and bake-off ovens, which are designed to pyrolize the dirt and grease, say their equipment creates much less waste than wet cleaning. Wastes are essentially limited to the residual "tars" that are left in the oven. Dennis Marble, product manager for Sunnen Products Co., St. Louis, MO, said his ovens (as with many thermal oven manufacturers) are even fitted with an afterburner to reduce the volume of hydrocarbons that are emitted into the air.

Although thermal ovens produce a small volume of dry solid wastes, a disadvantage of bake-off ovens include the need for abrasive blasting equipment. Mike Wilkes of Arrow Industrial Equipment, a supplier of Georg Fischer Disa Goff cleaning equipment, said no matter which type of cleaning methods are used, wet or dry, some type of wastes will be created. "Shot blasting and heat cleaning will generate wastes, too," Wilkes said, adding blasters create wastes that are composed of the contaminants from the part, a portion of the base metal used in the part itself, and the spent abrasive material. "Shot blasting creates wastes in the form of dust, and the difference in your shot quality will constitute the amount of dust generated," he said.

Wilkes said as with any type of waste generated in the shop, the materials from blasting should be analytically tested to determine what heavy metals or hazardous wastes are generated. Results from these tests should be maintained on file indefinitely. "Most rebuilders have a waste management company dispose of the blast waste, though it depends on what they're blasting," Wilkes said. "So keep accurate records."

Wilkes said another way some rebuilders have rid their shops of blast waste and dust from steel or aluminum shot is through fireworks manufacturers. "Some rebuilders are able to sell the spent shot to fireworks manufacturers, who in turn, use this material in fireworks production," he said.

Ovens are being used today for more than just cleaning parts, too. Duane Price, sales manager for Bayco, Irvine, CA, explained some rebuilders also use their bake ovens to evaporate waste water that's generated from their wet cleaning equipment in a shop. "Why pay to have gallons of wastewater removed when you can just heat it away?" he asked.

Price said one large rebuilding operation that uses ovens as evaporators reduced 1,000 gallons of sludgewater into a 22 lbs. cake-like material in 32 hours. "Even when you factor in the costs of the energy used to operate the ovens, you're still saving a tremendous amount of money in disposal fees by evaporating waste water," Price said. "And now you're only paying to dispose of a small amount of residue."

Like the ovens, evaporators are another equipment choice for waste reduction. J.C. Bianchi, of B & G Machine, Inc., Seattle, WA, said his diesel shop purchased an evaporator to reduce disposal costs of contaminated solution from the shop's caustic hot tanks and spray jet washers. "We pump our wastewater to an evaporator using two oil/water separators,Ó Bianchi said. "The water is evaporated into a sludge which reduces the volume, and thereby reduces our disposal costs." Bianchi said although it was a large initial cost for the equipment, it has saved the shop money in waste disposal.

Guspro's CTO-50 (continuos thermal oxidizer) is yet another option to reduce waste. Using a primary burner and an oxidizer burner, liquid waste and sludge are converted into dry dust that can be removed for disposal. The manufacturer also claims gases and smoke generated by the heating of the wastes are also destroyed, assuring compliance with EPA and regional air pollution requirements.

Which brings us to our final point - improper waste disposal is the most frequent criminal charge from regulatory and enforcement agencies. Rebuilders should keep in mind that no matter which cleaning process they use, hazardous waste will be generated. Only through proper planning, and seeking advice from manufacturers and suppliers, as well as regulatory agencies, can waste management be cost effective and performed within the parameters of the law. AR