Pollution Reduction Opportunity Evaluation (PROE) for Degreasers State of New Jersey Department of Environmental Protection Office of Pollution Prevention and Right to Know Table of Contents Section Page Number 1.0 Purpose of the PROE 3 2.0 Types of Degreasers 3 3.0 Pollution Reduction Opportunities 4 4.0 Questions to Ask and Decision Tree 5 5.0 Case Studies 7 6.0 Benefits of the Pollution Reduction method 9 7.0 Definitions 9 8.0 References 10 9.0 Contact Information 10 2 1.0 Purpose of the PROE Report The Pollution Reduction Opportunity Evaluation (PROE) report identifies alternative methods to reduce releases to the environment. It is a tool to facilitate discussions between regulators and the regulated in order to implement pollution reduction methods in areas where there are potential health concerns. The goal of the PROE program is to promote pollution prevention, which is reducing or eliminating the need for hazardous substances per unit of product, or reducing or eliminating the generation of hazardous substances where they are generated within a process. This report identifies methods that can be used by a specific industry in order to make measurable reductions in the amount of pollutants generated or discharged by the facility. There are five Pollution Prevention Categories: 1. Input Substitution: Switch from a hazardous input to a non-hazardous one. 2. Product Reformulation: Alter the product, but not necessarily its function, so it requires less hazardous substance. 3. Efficiency Improvement: Change production processes so they use necessary hazardous substances more efficiently. 4. In-Process Recycling: Send hazardous materials back into a process, directly. 5. Housekeeping: Find fugitive leaks, prevent spills, control losses from tanks, etc. The benefits of implementing the recommendations in the PROE report may include fewer requirements in permits, exemptions from reporting such as Community Right to Know and the Release and Pollution Prevention Reporting, and less inspection oversight. This benefits not only the environment but also the industry since there can be substantial cost savings in pollution prevention. 2.0 Types of Degreasing Operations A degreaser is a cleaning machine used to physically remove soils from the surface of materials. There are two types of vapor degreasers. One is a vapor immersion unit, which usually has two solvent-filled sumps (the boil sump and the cold sump, which is filled with clean, distilled condensate solvent and is often used for rinsing). The other type of degreaser is a vapor/spray unit in which the solvent is boiled in the very bottom of a one-sump degreaser. A perforated metal stand is just above the boiling solvent and a metal basket filled with dirty parts is usually placed on this stand. The basket or parts are not immersed in solvent. Instead the vapor made by the boiling solvent encompasses the parts completely and removes the oils and soils. The oils and soils, now diluted into the condensing liquid, will drip back into the boiling solvent below. There is a manual spray wand, which is sprayed under the cooling coils directly on hard-toremove soil (Murphy, 2000, ¶ 1). Near the top of either type of degreaser is a set of cooling coils that catches the vapor before it escapes from the unit. The vapor cools and condenses back to its liquid form, flows back to a clean condensate tank and finally goes back to the boil sump or the rinse tank. (Murphy, 2000, ¶ 2) Cold Cleaning is the process of removing contaminants from the surface of metal parts at room temperature. The parts are sprayed, brushed, flushed, or immersed and soaked into a cold 3 cleaner (typically a spray sink or a dip tank) containing a non-boiling solvent degreaser (ICF, 2004, Box 1-1). Open Top Vapor Degreasing is an immersed cleaning process using hot vapors and liquid solvent in a boiling sump to remove soils, particularly oils, greases and waxes. An open-top vapor degreaser consists of an open steel tank with a heated solvent reservoir, usually referred to as a sump, and a cooling zone near the top. The sump is heated to boil the solvent and generate a solvent vapor blanket that covers the liquid solvent in the tank. The solvent vapor condenses when it reaches the cooling zone; this clean liquid solvent condensate flows to rinse tanks which overflow back to the boil sump (ICF, 2004, Box 1-1). Conveyorized Vapor Degreasing is a less frequently used cleaning method involving the use of large, enclosed mechanical systems that handle a large workload capacity. Also known as in-line vapor degreasers, these units operate similarly to open top vapor degreasers with the exception that parts are continuously moved into and out of the cleaning zone (vapor or solvent liquid) and rinse zones on a conveyor belt (ICF, 2004, Box 1-1). Aerosol Solvent Cleaning is a specialized spot cleaning process for confined areas of machinery and parts. Contrary to other equipment and processes where the part being cleaned is immersed into a cleaning tank, aerosol solvents are contained typically in an aerosol can and are dispensed onto the parts being cleaned. A spray tube inserted into the valve of the can or a flexible tube ending in a small brush assists in the discharge of the cleaning solvent. This process is 100 percent emissive in nature with essentially no reuse possible (ICF, 2004, Box 1-1). Aqueous Cleaners range from pure water to exotic combinations of water, detergents, saponifiers, surfactants, corrosion inhibitors and other additives. When combined with heat, pressure, agitation, etc., they can be an effective alternative for most cleaning applications (Carter, 1999, Aqueous Cleaner section, para. 1). Terpenes are chemical compounds extracted from the bark of trees or citrus fruit skins. They have been used in household cleaners, pharmaceuticals, deodorizers and other commercial products (Carter, 1999, Semi-Aqueous Cleaner section, para. 1). Mechanical Cleaning uses materials such as sand, plastic beads, glass beads, steel shot, walnut shells, frozen CO2 cereal, baking soda, etc., to clean various substrates (Carter, 1999, Mechanical Cleaning section, para. 1). 3.0 Pollution Reduction Opportunities There are a number of options available for facilities that are looking to switch to a less hazardous cleaning solvent. However, there is no “one size fits all” replacement for solvents in any cleaning operation. Some of the alternatives such as aqueous or semi-aqueous processes may require new equipment or the addition of multiple cleaning steps. Other options such as terpenes, alcohols, and petroleum distillates may have disposal concerns. In addition, a facility has to consider what types of oils and soils need to be removed from the object being cleaned before choosing an alternative cleaning method to ensure that the product will meet quality specifications. This is because the make-up of the oils and its chemical composition can 4 influence what type of cleaner used. For example, halogenated oils, in which a halogen ion (e.g., fluorine, chlorine, bromine, or iodine) has been attached, are removed using halogenated solvents, whereas, non-halogenated oils are removed using non-halogenated solvents. There are a number of resources available such as the Office of Pollution Prevention and Right to Know, the New Jersey Program for Manufacturing Excellence and internet web sites that can help determine which alternative cleaning process is best for a given situation. Listed below are some common halogenated solvent cleaners, which are regulated by MACT requirements, and some web sites that might be helpful in determining alternative methods to using halogenated solvent cleaners. Also included are some questions that can be asked about the product being cleaned and the quality of the finished product. Lastly included are two case studies of facilities in New Jersey that have successfully switched from halogenated solvents to a less hazardous cleaner. Common Halogenated Solvent Cleaners Carbon Tetrachloride Chloroform Perchloroethylene 1,1,1 Trichloroethane Trichloroethylene Methylene Chloride Carcinogen, Ozone Depleting Carcinogen Carcinogen Ozone Depleting Carcinogen Carcinogen Use and production banned Production banned Alternative Solvent Resources Safe Solvent Alternatives Guide: http://clean.rti.org Waste Reduction Resource Center: http://wrrc.p2pays.org/ Surface Solutions Laboratory: www.cleanersolutions.org/SimpleSolutions Halogenated Solvent 1,1,1 Trichloroethane 1,1,1 Trichloroethane and Trichloroethylene 4.0 1. 2. 3. 4. 5. Alternative n-Propyl Bromide HFE-72DA Examples See Case Study 1 See Case Study 2 Questions to Ask and Decision Tree to Guide Evaluation What is being cleaned? What is being removed? How are soils removed? Can the process be improved? Do you have to meet military or other specifications? What kind of oils do you use? Can you use a different kind? 5 Decision Tree to Guide Evaluation No Discontinue Degreasing Do parts need to be cleaned? Yes No Evaluate Oil Usage Is the amount of oil applied controlled? Yes Do the parts have to be cleaned to meet specifications? Yes Consider Process Modification No No Evaluate Alternatives (See Section 3.0) Have solvent substitution options been considered? Yes Are oils and solvents recycled? No Evaluate Recycling Options Yes Implement Feasible Changes 6 5.0 Case Studies Case Study #1 Durex, Inc. Durex, Inc. (Durex) is a 120-employee manufacturing company located in Union, New Jersey. The major processes at the facility include metal stamping, sheet metal fabrication, assembly and finished product. Durex operates an open-top vapor degreaser, equipped with a closed cover and a freeboard chiller, to remove oils from metal parts. Prior to1998, the main solvent used in the degreaser was 1,1,1-Trichloroethane. However, new regulations, safety concerns and cost prompted Durex to investigate other options. Their first option, a non-HAP solvent called Techtride NPB DG which consist of n-propyl bromide (CAS 106-94-5), 1,2 Butylene Oxide (CAS 106-88-7) and 1,3-Dioxolane (CAS 646-06-0) was found to clean as well as 1,1,1-Trichloroethane. Also, they found that this non-HAP solvent could be used in their existing equipment. Durex decided to use Techtride NPB DG, manufactured by Parts Cleaning Technologies (PCT), in their degreasing unit. The driving forces to make the switch were the environmental, safety and cost aspects. These included no emissions to the atmosphere, less harmful exposure to employees, and reduced purchasing costs. Durex also implemented other pollution prevention methods in their degreasing unit, which includes collecting the oil after it is removed from the metal parts and shipping it back to the manufacturer, and recycling Techtride NPB DG back into the degreaser unit. As a result, Durex does not have any waste shipped off-site from their degreasing operation. Below is a graph from the Release and Pollution Prevention Reports (RPPR) that show the reduction of 1,1,1 Trichloroethane through the years 1994 to 1998. After 1998, Durex, Inc. stopped reporting this chemical completely. NPO (Lbs/yr) 1,1,1-TRICHLOROETHANE 7 1998 1997 1996 1995 CalculatedNPO 1994 90,000.00 80,000.00 70,000.00 60,000.00 50,000.00 40,000.00 30,000.00 20,000.00 10,000.00 0 Case Study #2 Bihler of America, Inc. Bihler of America, Inc. (Bihler) is a 150-employee manufacturing company located in Alpha, New Jersey. Bihler used 1,1,1-Trichloroethane and Trichloroethylene up to the mid 1990’s, where their primary product at the time was slide doors for computer discs. As their product line changed, they used the opportunity to change their cleaning processes from those using HAPs. Since the mid 90's Bihler has continued to look for improvements in its cleaning processes and has used Abzol , (N-Propyl Bromide), 3M's HFE, water and detergent washes, and pressurize hot water. Abzol had some maintenance and employee exposure issues. Essentially if it was not monitored and changed properly, it could turn acidic. HFE was expensive, but was a non-HAP with minimal VOC (Volatile Organic Compounds) and with no ozone depleting chemicals. Water and detergent did the job, but because of the detergent there were still pollution and waste removal issues. Anything other than air and water vapor emitted from a stack is a pollutant. Bihler now has one degreaser, which uses HFE 72DA, and several pressurized hot water cleaners. Bihler operates an open-top vapor degreaser with a passive control system using refrigeration to limit emissions and employee exposure. A mechanical arm lowers the basket into and out of the system and once the parts are degreased, the basket is held in the refrigerated zone so that all VOCs condense back into the tank. The used solvent is changed out periodically and returned to the supplier. With the water cleaning systems, the dirty, oil- contaminated water first goes through a filtering system and then to an oil/water separator. The water is then recirculated back to the cleaning system and reused. Some water is evaporated as part of the process and replaced and the separated oils are shipped off-site as petroleum waste. The major products currently produced at this facility include surgical needles (unfinished), electrical supplies (outlets, switches) and small metal fabricated parts. Bihler uses HFE-72DA in their degreaser, manufactured by 3M, which consist of 1,2-trans-dichloroethylene (CAS 156-605), ethyl nonafluoroisobutyl ether (CAS 163702-06-5), ethyl nonafluorobutyl ether (CAS 163702-05-4), methyl nonafluoroisobutyl ether (CAS 163702-08-7), methyl nonafluorobutyl ethyl ether (CAS 163702-07-6), and isopropyl alcohol (CAS 67-63-0). The HFE-72DA was an expensive choice for Bihler, but it was determined that the switch was worth it, not only from an environmental perspective, but because there are reduced permitting requirements, storage and handling costs, and permit fees. In addition to the solvent substitution methods described above, Bihler conducts an evaluation of the products to be cleaned. Bihler asks key up-front questions of themselves and their clients such as: “How clean does the product need to be?" or " What standard for cleanliness applies?" and “What is the most efficient oil application?” Bihler realizes that some products do not have to be cleaned to the highest quality because these products will be cleaned or undergo further processing by their clients. Also, Bihler instituted a computerized system to control the amount 8 of oil put onto the metal parts. These up-front efforts not only reduce cleaning efforts, but also minimize oil consumption and emissions issues for a more cost efficient operation. Bihler has been able to address environmental improvements because the management recognizes the relationship that good environmental and safety efforts have on the financial bottom line. Additional pro-environmental initiatives at Bihler include using low energy lighting, automatic sensors that dim or turn off warehouse lighting during periods of inactivity, and using variable frequency drives on air compressors. Below is a graph from the Release and Pollution Prevention Reports (RPPR) that show the reduction of 1,1,1 Trichloroethane and Trichloroethylene through the years 1994 to 1996. After 1996, Bihler stopped reporting these chemicals completely. NPO (Lbs/yr) 140,000.00 120,000.00 100,000.00 80,000.00 60,000.00 40,000.00 20,000.00 TRICHLOROETHYLENE 6.0 7.0 1997 1996 1995 CalculatedNPO 1994 0 1,1,1-TRICHLOROETHANE Benefits of the Pollution Reduction method Comply with federal and state regulations Eliminate solvent storage and handling Eliminate potential for accidental releases Create safer working conditions Eliminate air regulation compliance costs Eliminate solvent purchase and disposal costs Eliminate emissions of ozone-depleting, global warming, and hazardous compounds Definitions Applicable VOC: any volatile organic compound (VOC) which has a vapor pressure or sum of partial pressures of organic substances of 0.02 pounds per square inch (1.0 millimeters of mercury) absolute or greater at standard conditions. 9 Consume: to change or alter the molecular structure of a hazardous substance within a production process. Hazardous Air Pollutant (HAP) solvent: any hydrocarbon compound listed in the Clean Air Act, Title III, section 112, subsection b. (42 USC 7412). Nonproduct Output (NPO): all hazardous substances or hazardous wastes that are generated prior to storage, out-of-process recycling, treatment, control or disposal, and that are not intended for use as a product. NPO includes fugitive releases. Soils: contaminants that are removed from the parts being cleaned. Soils include, but are not limited to grease, oils, waxes, metal chips, carbon deposits, fluxes and tars. 8.0 References New Jersey Department of Environmental Protection (1997). State of the Art (SOTA) Manual for Degreasers and Other Solvent Based Metal Surface Cleaners, 3.6-3 – 3.6-4. ICF Consulting (2004). The U.S. Solvent Cleaning Industry and the Transition to Non Ozone Depleting Substances, Retrieved December 2005 from United States Environmental Protection Agency Website: http://www.epa.gov/spdpublc/snap/solvents/EPASolventMarketReport.pdf New Jersey Department of Environmental Protection (1995). Industrial Pollution Prevention Planning, Trenton, NJ, 2nd Ed, 9. Carter, B. (1999). Solvents - The Alternatives. Retrieved December 2005, from North Carolina Department of Environment and Natural Resources Website: http://www.p2pays.org/ref/01/00023.htm Murphy, R.P. (2000). How a Vapor Degreaser Works. Retrieved December 2005 from Degreasing Devices Co. Website: http://www.users.interport.net/r/o/rod.ma.ultranet/www.degreasingdevices.com/ebook.htm 9.0 Contact Information For more information on the PROE Report or the case studies, contact the Office of Pollution Prevention and Right to Know at 609-777-0518. 10