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.
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