A Pollution Prevention Assessment and Guidance

Transcription

1 A Poution Prevention Assessment and Guidance Washington State Department of Ecoogy Hazardous Waste and Toxics Reduction Program June, 1999 Pubication # printed on recyced paper

2 For a copy of this document, pease contact: Department of Ecoogy Pubications P.O. Box Oympia, WA Pease incude your street address for UPS deivery The Department of Ecoogy is an equa opportunity agency and does not discriminate on the basis of race, creed, coor, disabiity, age reigion, nationa origin, sex, marita status, disabed veteran s status, Vietnam Era veteran s status or sexua orientation. If you have specia accommodation needs or require this document in aternative format, pease contact the Hazardous Waste and Toxics Reduction Program at (360) (voice) or (360) (TDD).

3 Tabe of Contents I II III IV V VI VII VIII IX Executiv ecutive e Summary 3 Over ervie view & Site Visits 4 Poution Prevention ention Summary 5 A. Baseine Poution Prevention Practices 5 B. Recommended Additiona P2 Practices 6 Meta Wor orking Fuid Maintenance 8 A. Meta Working Fuid Maintenance Program 8 B. Seection Criteria 9 C. Meta Working Fuid Recycing 10 Spent Meta Wor orking ing Fuid Disposa 14 A. Designation under Existing Reguations 14 B. Designation under Proposed New Reguations 17 C. Managing as Dangerous Waste 17 D. Managing as Used Oi 21 E. Evaporator Issues 21 Chip Management 24 A. Chip Recycing 24 B. Stormwater Issues 24 C. Stormwater Reguations 25 Foor Ceaning 26 A. Routine Maintenance 26 B. Mop Water Disposa Options 26 C. Spis Absorbent Waste Disposa 27 Heath Concerns 28 Appendixes es 30 A. Gossary 30 B. Poution Prevention Opportunities List 31 C. Vendor Directory 34 D. Interim Used Oi Poicy 37 E. Map of Air Poution Contro Authorities 39 F. Treatment by Generator 41 G. Resources 50 H. Bibiography 51 METAL MACHINING INDUSTRY SECTOR PROJECT 1

4 Acknowedg knowedgements ements The sector team woud ike to thank a of the individuas who heped us in competing this project. We are especiay appreciative of the time and information provided by the faciities we visited. We are gratefu for the support and guidance that King County and L&I provided us. The input provided by Aice Chapman, Tracee Mayfied and Steve Whittaker was exceptiona. We aso woud ike to thank a our peer reviewers, especiay Dean White from AFab and Chuck Coppe from Fatigue Technoogy. Lasty, I m privieged to have worked with a great group of dedicated and inspiring peope (Hoy Cushman, Jim Haney, Laura Scheyer, and Rofe Parsoe), who heped make the ast year fy by. Thank you for being you!! James DeMay 2 WASHINGTON STATE DEPARTMENT OF ECOLOGY

5 Executiv ecutive e Summary In 1999, the Washington State Department of Ecoogy s Hazardous Waste and Toxics Reduction Program conducted a technica assistance project for the meta machining industry sector. This report serves to provide this technica and reguatory information to the industry sector as a whoe. The report is based on research by the sector team and on site visits to 12 meta machining faciities in Spring The scope of the project incuded: Researching the environmenta and reguatory issues in this industry sector. Conducting site visits at a cross-section of meta machining faciities. Evauating current industry poution prevention (P2) practices to identify technica assistance needs. Highighting the most significant P2 opportunities and providing resources for future P2 actions. The site visits reveaed that a significant amount of poution prevention is aready being achieved at meta machining faciities. Common P2 practices incude fuid monitoring, sump maintenance, and draining meta chips to recover fuids. The report highights recommended additiona P2 practices. These recommendations incude using way oi that easiy separates from meta working fuid, using centraized recycing stations, and using high quaity cooants to increase fuid ife span. The report aso discusses the compiance issues invoved with the disposa of waste meta working fuid. The key issues are the designation of spent meta working fuids as either used oi or dangerous waste and the management requirements for these wastestreams. The Department of Ecoogy is in the process of adopting new used oi reguations, which wi change this designation process. These proposed changes are discussed in the report. This document summarizes the Meta Machining Sector Project s findings as we as recommendations, information and resources for meta workers. METAL MACHINING INDUSTRY SECTOR PROJECT 3

6 Over ervie view Since 1995, Department of Ecoogy (Ecoogy) has conducted sector projects with the eectropating, fibergass, printed circuit board manufacturing, nationa security, and paint manufacturing industries. In 1999, the meta machining sector project was seected because the industry paced high on the ranking ist due to hazardous waste generation, Toxic Reease Inventory (TRI) emissions, and the number of faciities that prepare poution prevention pans. Sector projects are short-term projects that focus on a particuar industry type. These projects provide Washington businesses with statewide industry-specific poution prevention (P2) assessments and technica assistance. This is achieved through a two step process. First, information is coected through research and site visits; the data is then combined and anayzed. Secondy, Ecoogy distributes the resuts to businesses within the sector. Sector projects are muti-media (i.e. air, water and and) and cover the environmenta issues pertaining to the industry sector. Site Visits Currenty, other agencies are conducting parae work with this industry sector. King County is working on technica assistance for this sector, incuding site visits to a sma and medium quantity hazardous waste generators in the county. In addition, Labor & Industry has done substantia work with heath concerns with this industry (See Heath Section). Of the various processes associated with meta fabrication, meta machining was seected as the primary focus of this project. The meta machining industry comprises faciities that shape a vast array of meta products, from airpane spars to nuts and bots. A wide variety of shaping techniques are used, incuding driing, boring, miing, broaching, grinding, and turning. The main wastestreams from these processes are meta working fuids, used oi, ceaning wastes, meta chips and grinding swarf (meta residue from grinding). Poution Prevention (P2) is any practice that reduces, avoids, or eiminates the generation of wastes or the toxicity of wastes, prior to generation, without creating substantia new risks to human heath or the environment. Department of Ecoogy conducted 12 site visits to meta machining faciities during the months of February and March, The purpose of these visits was to: 1. Assess the current poution prevention activity eve 2. Identify new poution prevention opportunities 3. Ascertain other important issues reating to this industry category incuding compiance issues 4. Identify additiona research needs Tabe 1: Site Visits Faciity Name Location Type of Products AFab Aerospace Everett Aerospace Boeing Corporation - Pant 2 Tukwia Aerospace Exotics Metas Forming Co. Kent Aerospace Fatigue Technoogy Tukwia Meta Fatigue Reduction Gear Works Seatte Gear Manufacture Hansen Machine Corporation Auburn Aerospace Hexce Structures Kent Aerospace components Jorgenson Forge Seatte Destroyer Shafts Modine Western Seatte Radiator parts Pioneer Industries Seatte Aerospace Precision Machine Company Tacoma Aerospace Precor Woodinvie Heath/Exercise Equipment 4 WASHINGTON STATE DEPARTMENT OF ECOLOGY

7 Poution Prevention ention Summary The foowing is a summary of the key poution prevention practices that are discussed in further detai in the chapters of this report. The purpose of this summary is: To identify baseine poution prevention (P2) practices that shoud be common to every faciity. To identify 10 additiona P2 practices that are highy recommended by Ecoogy. These practices are presented in two separate ists, with the baseine practices presented first. See the appendix for a fu isting of P2 practices for meta machining faciities. Baseine Poution Prevention ention The foowing is a ist of basic P2 practices that, in Ecoogy s view, shoud aready be taking pace in every meta machine shop due to their basic nature and ease of impementation. List I: Baseine P2 Practices Meta Working Fuid Testing 1. Monitor Concentration: Keeping the concentration of the meta working fuid (MWF) in the correct range wi ensure that ony the right amount of concentrate is used. It wi aso hep contro any gumming, sticking or smearing eft on workpieces due to excess concentrate. Refractometry and titration are the most common techniques for measuring fuid concentration. Sump Maintenance 2. Sump and Trench Maintenance: Periodicay ceaning out the MWF sumps and trenches wi keep them free of soid matter that can hamper fuid fow. Soid materias provide exceent areas for microbe growth and may cog up MWF ines. Disinfect sumps and trenches when MFW fuid is removed. Disinfectant options incude acoho or steam ceaning. Without the disinfecting step, new MWF fuid wi be inocuated with eftover bacteria when it is added to the sump. Meta Working Fuid Maintenance Pan 3. Daiy Inspections: Conducting daiy inspections of each machine wi hep identify probems and trends, and speed up machine repair through eary identification of probems. This contributes to ess downtime and ess fuid waste. Recycing Systems 4. Tramp Oi Skimmers: These come in severa different types incuding rope, bet and disk skimmers. Skimmers remove the oi that makes its way into the MWF and foats on the surface of the fuid. Oi remova heps keep the fuid aerated with dissoved oxygen, and reduces the food source for microorganisms. Chip Management 5. Chip Fiters: Fiters keep the chips and grit created in the machining process from contaminating the MWF sump. The high amount of surface area created by the chips provides an exceent area for microbe growth. Thus, fitering heps to ower the bacteria count. 6. Drain Meta Chips to Recover Fuid: One way of draining meta chips is to pace them into a perforated container with a catch basin and reuse the coected meta working fuid. Another option is to manuay shut off the chip conveyor for a period of time and aow the fuids to drain back into the machine sump. A chip wringer or centrifuge can be used to get even more fuid from the chips.these processes aso create higher quaity chips for recycing. METAL MACHINING INDUSTRY SECTOR PROJECT 5

8 Recommended Additiona P2 Practices 7. Recyce the Meta Chips and Scrap: Many, but not a, meta recycers wi take chips. They wi usuay require chips to be segregated by meta type and free of oi. A higher price can usuay be obtained if chips are compressed into briquettes through the use of a briquetting machine. Spis 8. Pumps, Spigots, and Funnes: Using pumps, spigots and funnes when transferring MWF wi reduce the amount of ost fuid and the risk of spiing fuids. Other 9. Fix Leaking Seas and Gaskets: This keeps the fuid where it beongs, instead of on the foor or a over the machine and operator. Even sma eaks can waste a surprising amount of fuid over time. 10. Tramp Oi Separation: Tramp ois and MWF shoud be thoroughy separated before skimming the tramp ois off the top. This wi reduce the amount of MWF that is wasted with the remova of the tramp oi. The foowing is a ist of poution prevention practices that Ecoogy s Meta Machining Sector Team highy recommends to a faciities. These practices are recommended because, in genera, companies that are aready using them are enjoying cost-savings and decreased waste generation. List II: Recommended P2 Practices Meta Working Fuid Maintenance Pan 1. Keep a Log of Monitoring Data: Keeping a og of fuid characteristics, such as ph and concentration, wi hep identify trends, sove probems, and keep the fuid in the proper condition. 2. Operator Responsibiity: The maintenance of meta working fuids (MWF) shoud be imited to ony one person or a team of peope who are trained and knowedgeabe about fuid maintenance. This wi reduce fuid property variances and hep cut down on the overuse of MFWs. Meta Working Fuid Seection 3. Use High Quaity MWFs to Get the Longest Life: The use of high quaity MWFs is recommended because these fuids are more resistant to bioogica attack and additive breakdown. This resistance aows them to be used many times without a oss of performance. 4. Look at the Compatibiity of Way Ois and MWFs: Ensuring that way ubricants and MWFs easiy separate wi hep in the treatment and recycing process. Seect a way oi that does not cause foaming probems or impair the separation characteristics of the two fuids. Highgrade way ois typicay separate easiy from MWF. In addition, they contain itte or no sufur compounds that are a food source for bacteria. 6 WASHINGTON STATE DEPARTMENT OF ECOLOGY

9 Spis 5. Use Chorine Free MWFs: Chorine has a arge impact on waste designation and thus effects disposa costs, management options, and management requirements. The proposed reguations, if adopted, wi prohibit waste MWF formuated with chorinated compounds from being designated as used oi. Sump Maintenance 6. Cover Sumps: By covering the MWF sumps in machines, airborne microorganisms are kept out of the fuid. This is important because a arge number of the microbes that contaminate fuids are airborne. Covers aso keep out trash such as dust, cigarette butts and food. 9. Reuse Absorbent Pads: Using absorbent pads that can be wrung out and reused wi cut down on the amount of absorbent materia that must be discarded as hazardous waste, and save money in fresh absorbent and waste handing costs. Another option is to dedicate a mop for the cean up of oiy spis. Other 10. Use Distied or Deionized Water: Using distied or deionized water keeps dissoved mineras out of the MWF. These contaminants can buid up in the fuid as the water in the fuid evaporates, causing separation of the concentrate from the water. Recycing Systems 7. Aerate/Ozonate the MWF to Keep the Dissoved Oxygen Leve Up: By aerating the MWF or using an ozone generator to bubbe oxygen through the fuid, the anaerobic microbe count wi be kept ow. Dissoved oxygen in the water keeps anaerobic bacteria from growing and creating the Monday morning stink. MWF treated with dissoved ozone reduces the microbe count. Ozone is highy toxic to microbes and kis them. 8. Centra Recycing Systems: Centra recycing systems aow a arge voume of fuid to be treated at once. Sma, wheeed versions (about the size of a arge shopping cart) are avaiabe. A good recycing system incudes a setting tank, oi skimmer, coaescer, and an aeration device. METAL MACHINING INDUSTRY SECTOR PROJECT 7

10 Meta Wor orking Fuid Maintenance In the eary 1970 s, meta working fuids (MWFs) were designed for a reativey short ife span prior to disposa. Since then, the cost for fuid disposa has rapidy increased, aong with iabiity concerns and reguations. As a resut, a growing importance has been paced on fuid maintenance. The key eement of maintaining an efficient meta working fuid system is a fuid maintenance program. No matter what type of fuid you use, the ife of the fuid can be extended through the use of a maintenance program. The goa of a MWF maintenance program is to optimize fuid performance, reduce oiy wastewater voume, and reduce fuid concentrate and disposa costs. Contaminated and spoied fuids are the argest source of waste from machining operations. An estabished maintenance program aows corrective actions to be taken before fuids become rancid. A written maintenance pan shoud be created to document your MWF maintenance program. This pan shoud incude the foowing eements: Tabe 2: Key Eements of a Fuid Maintenance Pan Operator responsibiities Monitoring / Fuid testing List a the empoyees that impement the maintenance pan and their responsibiities. Fuids can be monitored to predict or anticipate probems. Physica characteristics such as product concentration, ph, fuid odor, and coor are good indicators of fuid degradation. Exampes: Product concentration can be measured by using a refractometer or by titration. The ph of the fuid can easiy be measured with itmus paper or a ph meter. If the ph of a fuid in a sump fas beow 8.5, the fuid oses efficiency, is prone to rusting, and bioogica activity wi increase significanty. Data tracking system Sump change out criteria Change-out procedures Sump ceaning Remova of chips Training program Keep a og of observations and test data. Setting criteria for change out reduces unnecessary disposa of MWF fuid and creates a standard for fuid reuse. Exampes: odor, appearance (miky appearance is norma), ength of use, ph (usuay between is norma), residue or fim eft on parts. Document how to hande and process the fuid through your recycing system. The purpose is to remove bioogica growth in the sump. Reguar ceaning reduces heath risks and improves fuid ife. Exampes: steam ceaning or use of a disinfectant soution. Reguar remova of chips reduces the habitat for bioogica organisms in your sumps. The written maintenance pan shoud be used to educate empoyees about MWF management and is an exceent source of training materia for new empoyees. 8 WASHINGTON STATE DEPARTMENT OF ECOLOGY

11 Seection Criteria Seecting which meta working fuid (MWF) to use is a very important decision with many considerations. Some of the main factors to consider are ubricity, cooing properties, rust protection, meta type, toobit type, fuid ife, and disposa costs. For more exampes of seection criteria and information about meta working fuids, see Metaworking Fuids by Jerry P. Byers or Lubricants and Lubrication in Metaworking Operations by Eiot S. Nachtman and Serope Kapakjian. One factor that often gets overooked is the separation characteristics between way ois and meta working fuids. It is very important to seect a way oi that easiy separates from the MWF. Way ois that are not separated from the meta working fuid promote the degradation of the fuid s properties and thus reduce the ife span of the fuid. Furthermore, the better the separation of these two fuids, the easier it is to treat and/or recyce the meta working fuid. High-grade way ois are a good choice because they separate easiy and contain very itte sufur, which serves as a food source for microbes. Another important eement to consider when seecting a meta working fuid is whether or not it is chorinated (e.g. contains chorinated paraffins) or non-chorinated. Chorine has a arge impact on waste designation and thus effects disposa costs, management options, and management requirements (See section - Spent Meta Working Fuid Disposa). Chorinated meta working fuids shoud ony be seected when high-pressure or high-speed conditions are critica to the machining operation. A fina consideration is whether one type of meta working fuid can be used for the entire faciity. Having ony one fuid simpifies the maintenance and treatment of the fuid, requiring a faciity to operate ony one recycing system. Tabe 3: Types of Meta Wor orking Fuids Fuid Type Composition Advantages Disadvantages Straight ois Fuids that consist Resistant to bioogica Higher cost, difficut of sovent-refined or degradation. Good rust to cean, fire hazard hydro-treated petroeum oi protection. Very itte and heath hazard. or other ois of anima or maintenance required. vegetabe origin. Water soube ois Fuids that contain approx- Good cooing capacity Tramp oi remova imatey 50%- 90% water, and ubricity. required. A mainwith refined base oi and tenance program emusifiers to mix the oi and to minimize bacteria water. Other additives com- growth is necessary. mony found in soube ois are biocides, soaps, softening agents, and rust inhibitors. Semi-synthetic fuids Synthetic fuids that contain Good cooing capacity. Difficut to treat. May sma amount of refined base Average ubricity. Longer emusify tramp oi. oi (5 20%) that is micro- sump ife. High foaming potenemusified, water and a sou- tia. tion of additives. These fuids tend to be simiar to soube ois. Synthetic fuids Aqueous soutions that Exceent cooing properties. Poor ubrication and do not contain refined oi. Longer sump ife. Good rust difficut to treat. Simiar additives as seen in protection. Cear fuid aows semi-synthetic fuids. workpiece to be visibe METAL MACHINING INDUSTRY SECTOR PROJECT 9

12 Tabe e 3: Types of Meta Wor orking ing Fuids(contin uids(continued) ued) Fuid Type High pressure additives Composition High pressure additives found in MWFs are chorine, sufur and phosphorus compounds. These compounds are sometimes referred to as EP (extreme pressure) agents, and are most commony found as haogenated organic compounds (e.g. chorinated paraffins). Haogenated EP fuids shoud not be used uness they are critica to the operation. In addition, sufur and phosphorus are a food source for microbes and sufur can stain metas. If you use any fuids with these compounds, remember to recyce and reuse them as much as possibe. Metawor orking Fuid Rec ecycing A good fuid recycing system extends the usefu ife of metaworking fuids (MWFs) and has both economic and environmenta advantages such as: Improving product quaity. Decreasing the amount of new fuids purchased. Decreasing costs of disposa for spent fuids. Decreasing downtime for machine cean outs and recharges. Recycing systems remove contaminants such as tramp oi, dirt, and bacteria; and readjust the fuid concentration before the fuid is returned to an individua sump. There are two casses of recycing systems, centra recycing systems and individua recycing systems. Centra a Rec ecycing System (incuding porta tabe e systems) stems) A centra system is a arge reservoir that suppies fuid to severa individua machines. The major advantage of a centraized system is that contaminants (soids, oi, and bacteria) can be controed at one ocation. This eiminates the need for many different systems on each machine, which overa wi reduce the time needed to monitor and maintain the fuids. With proper fuid contros and management techniques, the typica fuid in a centra system can have a ife of one to three years (or even onger). Tabe 4 is a ist of the types of contaminant remova equipment used in centra systems. Portabe recycing systems are a costeffective aternative to centraized recycing systems. The fuid from an individua sump is pumped into a portabe unit that removes contaminants. The fuid is then returned to the sump and the portabe system is moved to the next machine. If the fuid from each machine is treated according to a prescribed maintenance schedue, daiy fuid monitoring may not be required. Tabe 4: Centra Rec ecycing Systems Setting/ Dragout Removes: Oi Dirt/Meta Bacteria Chips X Fotation X X Positive Fiters Gravity Pressure Vacuum X X X Centrifuge X X Oi Skimmer X Coaescer X X Pasteurization Byers, Jerry P. (editor), Meta Working Fuids, Marce Dekker, Inc., NY,NY, 1994, page 346. X 10 WASHINGTON STATE DEPARTMENT OF ECOLOGY

13 Individua Rec ecycing Systems Unike centra recycing systems, individua recycing systems tend to contro ony one type of contaminant. For exampe, a miing machine might ony have a skimmer to remove any excess tramp oi. The benefits of using individua systems are their ow capita costs, and abiity to focus on one particuar probem for a given machine. There is a wide variety of recycing systems for individua machines. Tabe 5 ists some of the more commony used recycing systems for individua machines. Tabe e 5: Individua Machine Rec ecycing Systems Removes: Oi Dirt/Meta Bacteria MEDIA-BASED SYSTEMS Fitration X Pressure X Vacuum X Gravity X NATURAL FORCE SYSTEMS Setting/Gravity X Oi Skimmers X Coaescers X X Fotation/Aeration X MECHANICAL SEPARATION SYSTEMS Centrifuges X X OTHER Pasteurization X Ozonation X Byers, Jerry P. (editor), Meta Working Fuids, Marce Dekker, Inc., NY,NY, 1994, page 347. Tabe 6 on the foowing pages describes the recycing/maintenance components isted in the two previous tabes and aso identifies possibe benefits for each. The foowing are some possibe combinations for portabe, individua, and centra batch recycing systems. A combination of setting tank, skimmers, and aeration devices wi remove coarse partices by setting and fine partices and tramp oi by skimming. A high efficiency sump ceaner wi remove fuids and soids from sumps. The fuid is passed through a centra batch-recycing unit utiizing a coaescer, pasteurization, and fitration technique and then returned to the sump. Other centra batch combinations incude: skimmers/fitration/ozonators; skimmers/ coaescer; skimmer/fuid concentration adjuster. A portabe unit equipped with a skimmer and ozonator for treating individua sumps. A portabe unit equipped with a coaescer, fiter, and fuid concentration adjuster. Portabe sump ceaner, or brown cow, is used to transfer used fuid to a 3 stage separation tank. Particuate settes out and tramp oi is skimmed off in the first 2 stages. Cean Cows are used to return treated fuid to individua sumps. Portabe units that act ony as fitration units. A setting tank, ozonation/aeration, tramp oi skimmer and a fiter. METAL MACHINING INDUSTRY SECTOR PROJECT 11

14 Tabe 6: Genera Descriptions of Common Recycing Components and Considerations Equipment Description Considerations Setting/Dragout Particuates in many meta working fuid systems are often adequatey removed by instaation of a simpe gravity/setting tank. Such a tank is enhanced when an automatic bar, rake device, or conveyer bet system is added to remove meta shavings and other setted soids. Fotation/Aeration A device that uses aeration to foat soids and tramp oi to the surface. Positive Fiters Gravity Fiters Because of gravity, the weight of the metaworking fuid is sufficient to provide the force required to penetrate the fiter medium. Most common fiter media are coth, paper, organic, poymers, or wire screens. Pressure Fiters A device that contains two horizonta compartments; a movabe top compartment and stationary bottom compartment. During operation, air pressure seas the two compartments together. The fiter medium may be a continuous nyon bet used as is or one coated with a disposabe medium. Vacuum Fiters The common positive fiter system is driven by a vacuum. Fuid is pued by vacuum through a permanent ro or cyinder. Advantages incude no media repacement or disposa required. One disadvantage is that carity is dependent on retention time and chip weight. Aso, this system is not effective with auminum chips or swarf which tend to foat. Advantages incude no media repacement or disposa required. It works on fine partices. Disadvantages incude greater foor space requirements and increased usage of pant compressed air. Advantages incude ow cost and ease of operation. Disadvantages incude greater foor space requirements and increased media disposa. Advantages incude abiity to remove sma partices efficienty. Aso, arge voumes can be handed within minima foor space. Disadvantages incude prematurey pugged fiters if tramp oi is not removed first. Advantages incude ow capita costs, efficient fitration, and no media repacement or disposa required. Disadvantages incude greater foor space requirements. 12 WASHINGTON STATE DEPARTMENT OF ECOLOGY

15 Centrifuge A rotating bow that uses centrifuga forces to separate oi, water, and soids. Low-speed centrifuges remove suspended soids from most iquids. High-speed units both remove tramp ois and soids. The goa is to separate free tramp oi and oosey emusified oi (such as mechanicay emusified oi.) Chip Wringers, a variation, separate chips from cutting fuids by aternating high to ow-speed cyces. Coaescer Uses the property of oi attraction to poypropyene media (or oeophiic, "oi-oving" materias) for remova of tramp oi. Pasteurization A heating process that improves separation of soids and reduce bioogica growth. Fitration Fuid is passed through a disposabe fiter to remove soid partices Oi Skimmers Devices that skim tramp oi from fuid reservoirs in machine sumps. The most common are bet and disc skimmers. Advantages incude high throughput rate (about 2 gpm) and good suspended soid and tramp oi separation. Disadvantages incude high maintenance when soids and grease require frequent ceaning and separation of product components. Advantages incude its appicabiity to either centra or portabe systems. Coaescers are not effective for removing water-miscibe hydrauic ois or emusified ubricating ois, however. Under certain conditions, this process successfuy contros microbia growth. This process can reduce a fuid s ubricity and corrosion inhibition properties. Fitration units enhance part finish, too ife, bacteria contro, and ubricity properties. They are most advantageous when used with centra recycing systems or portabe recycing units. Units on individua machines tend to be abor intensive. For individua systems, a combination of setting tank and skimmers wi remove coarse partices and tramp oi. This reativey inexpensive combination often provides sufficient cean ubricant ready for reuse. METAL MACHINING INDUSTRY SECTOR PROJECT 13

16 Spent Meta Wor orking Fuid Disposa Once a meta working fuid (MWF) is determined to be no onger usabe, it must be designated and disposed accordingy. This section of the report discusses: Designating spent MWF as either used oi or dangerous waste under existing reguations. Designation changes under proposed new reguations. Management requirements for used oi and dangerous waste. Evaporator requirements. Designation of Spent MWF under the Existing Danger erous Waste Regua guations The first step in designating spent meta working fuid is to determine whether it is used oi or dangerous waste. A series of questions must be answered in order to make this determination. The foowing seven steps and the fowchart on page 15 expain how this determination is made. In order to use the fowchart, a business needs to determine the tota haogen content of their spent meta working fuid, preferaby by sending a sampe out to a aboratory for testing. If chor-detects or sniff tests are used instead, businesses shoud keep a written record of the name and teephone number of the person performing the test aong with the samping date and equipment caibration date. A written test records shoud be kept onsite for 3 years. Note: Not a MWFs are formuated from crude oi or synthetic oi, and therefore do not meet the definition of used oi. Step 1: Is the spent MWF to be re-refined into oi/mwf? Spent meta working fuid that wi be rerefined into oi or reformuated into meta working fuid is not dangerous waste and is not subject to dangerous waste designation or management requirements (reference WAC (2)). Spent MWF to be re-refined is managed as used oi and is subject ony to WAC , 120(b), 145, 515 and 960. These sections require that the fuids be managed in a manner that does not pose a threat to human heath or the environment. Note: Not a meta working fuids can be re-refined. Some contain metas, such as copper, zinc, or ead, which interferes with the refining process. Consut with your vendor for further information. Step 2: Is the MWF formuated with chorinated compounds? This step is the proposed change to the meta working fuid designation process that Ecoogy may adopt under the new used oi rues. This issue is discussed beow in the section, Designation of Spent MWF under Proposed New Reguations. Step 3: Has the spent MWF been mixed with other wastestreams? If spent MWF is mixed with another wastestream (such as mop water), the resutant mixture becomes subject to the designation process under WAC , -080, -090 and It is iega to mix dangerous waste with non-dangerous wastestreams. A arge number of dangerous waste constituents can be found in spent MWF, incuding ead, cadmium, 14 WASHINGTON STATE DEPARTMENT OF ECOLOGY

17 Fow Chart: Spent Meta Working Fuid (MWF) Designation Process Step 1: Is spent MWF to be re-refined into oi/mwf? WAC (2) NO * Step 2 (Proposed): Is the spent MWF formuated with chorinated compounds? NO Yes Yes Spent MWF is not dangerous waste and can be managed as used oi. Manage according to , 120(2)(B), 145, 515 and 960. * If spent MWF is not re-refined, it must be managed as a dangerous waste. If it is burned then it must be managed under WAC Step 3: Has spent MWF been mixed with any other waste stream (except for used oi) NO Step 4: Does the spent MWF contain anima or vegetabe ois? NO Yes Spent MWF subject to fu designation under , 080, 090, and 100. Depending on metas being machined, test for ead, cadmium, seenium, zinc, copper, tota haogens and any other possibe DW constituents. If any reguatory eve is exceeded, the MWF must be managed as dangerous waste, otherwise manage as soid waste. Yes Spent MWF subject to fu designation under , 080, 090, and 100. If any reguatory eve is exceeded, the MWF must be managed as dangerous waste, otherwise manage as soid waste. Step 5: HOCS > 10,000 ppm. NO Step 6: Tota haogens > 1,000 ppm. NO Yes Yes Spent MWF designates as an extremey hazardous waste. It must be counted, abeed, accumuated, and disposed as a dangerous waste. If it is burned, it must be burned as a dangerous waste fue in accordance with WAC Spent MWF is assumed to be mixed with another waste. It is presumed to be dangerous waste and must be managed accordingy. This presumption can be rebutted. If rebutted successfuy, manage the spent MWF as used oi. Step 7: Tota haogens < 1,000 ppm. Yes Spent MWF can be managed as used oi. The oi is not considered a dangerous waste and has no specia time or storage requirements. It does not count toward generator status. * This step is the proposed change to the meta working fuid designation process that Ecoogy may adopt under the new used oi rues. METAL MACHINING INDUSTRY SECTOR PROJECT 15

18 chromium, seenium, copper and zinc. These metas typicay enter the MWF via the machining process. For exampe, when zinc pated or zinc bearing metas such as brass are machined, zinc, copper and ead can be present. It is necessary to use process knowedge and materia safety data sheets (MSDS) to deveop a compete ist of eements and compounds to test for. Businesses can avoid the probems associated with mixed wastestreams by training empoyees to separate wastestreams, propery abeing waste containers and restricting container access to trained empoyees. Step 4: Does the MWF contain anima or vegetabe ois? Used oi means any oi that has been refined from crude oi, or any synthetic oi, that has been used and, as a resut of such use, is contaminated by physica or chemica impurities (WAC ). This definition excudes anima and vegetabe ois (ard, canoa, etc.). Spent MWF s that contain anima or vegetabe ois do not meet the definition of used oi and therefore are subject to designation under WAC (see previous paragraph for common waste constituents to test for). Step 5: Does the spent MWF have > 10,000 parts per miion (ppm) haogenated organic compounds (HOC)? Meta working fuid with more than 10,000 parts per miion HOC is considered extremey hazardous waste. If it is burned, it must be managed as dangerous waste fue under WAC However, water-soube MWFs typicay contain ess than 10,000 ppm HOC s uness they are evaporated or mixed with other haogenated wastestreams (e.g. chorinated compounds). Evaporator residues from chorinated MWFs wi typicay exceed the 10,000 ppm HOC imit. Step 6: Does the MWF have >1,000 ppm tota haogens? Meta working fuid that contains more than 1,000 ppm tota haogens is presumed to have been mixed with a dangerous waste and is required to be managed as dangerous waste. However, the presumption that mixing has occurred can be rebutted. In order to rebut this presumption, the business must demonstrate that the MWF does not contain haogenated dangerous waste constituents as a resut of intentiona mixing. The haogenated dangerous waste constituents are isted in WAC and Rebutting the presumption that dangerous waste has been mixed into MWF can be as simpe as: 4 Demonstrating via a materia safety data sheet that the source of the haogens is the meta working fuid itsef (soube MWF s typicay contain chorinated paraffins) AND: 4 Demonstrating that care is taken to avoid using products that introduce chemicas isted in WAC and into the MWF AND: 4 Demonstrating that other wastestreams are managed so as to prevent mixing. Step 7: Does the MWF have < 1,000 ppm tota haogens? If the spent MWF contains ess than 1,000 ppm tota haogens it can be managed as used oi. See section beow on Managing Spent MFW as Used Oi. WAC states that wastestreams that have more than 10,000 ppm poycycic aromatic hydrocarbons (PAH) must be managed as extreme hazardous waste. Most MWF s have not had significant PAH concentrations in their formuations for many years. 16 WASHINGTON STATE DEPARTMENT OF ECOLOGY

19 Designation of Spent MWF under Proposed New Regua guations Managing Spent MWF as Danger erous Waste The Department of Ecoogy is in the process of adopting the Federa Used Oi Management Standards (UOMS), with fina adoption anticipated in What wi change? One of the proposed changes to the rue affects spent soube meta working fuids (MWFs) that are formuated with chorinated paraffins (see Step 2 above). Under the proposed rue, spent MWFs formuated with chorinated paraffins can be managed as used oi, ony if they are sent to be re-refined. Otherwise, these spent MWFs must be managed as dangerous waste. Furthermore, spent meta working fuids that designate as dangerous waste and are sent to be burned, must be managed under Specia Requirements for Dangerous Wastes Burned for Energy Recovery (WAC ). The purpose of this rue change is to eiminate the potentia for spent chorinated MWFs to be burned in inappropriate combustion units, which may generate dioxins. Note that the terms chorinated paraffins and chorinated akanes are synonymous and are used interchangeaby on materia safety data sheets (MSDS). Aso note that some chorinated paraffins are not required to be isted on MSDS sheets but sti might be present in MWFs. See Appendix G (Resources) for hep using MSDS sheets in determining whether the fuid is formuated with chorinated compounds. To propery manage dangerous waste, businesses need to determine their generator status. Generator status depends on the tota amount of dangerous waste generated per month and the amount of waste stored on site. Management requirements differ depending on generator status. The foowing reference guide outines the management requirements based on generator size. METAL MACHINING INDUSTRY SECTOR PROJECT 17

20 Tabe e 7: Guide for Danger erous Waste Generator tors s in WA 18 WASHINGTON STATE DEPARTMENT OF ECOLOGY

21 METAL MACHINING INDUSTRY SECTOR PROJECT 19

22 20 WASHINGTON STATE DEPARTMENT OF ECOLOGY

23 Managing Spent MWF as Used Oi To determine if a spent meta working fuid meets the definition of used oi see the designation section. For exampe, some MWFs do not meet the definition of used oi because they are not formuated from crude oi or synthetic oi. Businesses are required to manage their used oi according to WAC , -145, - 515, -960, and -120(2)(b). The foowing are key aspects of these reguations: Businesses must manage used oi in a manner that does not threaten human heath or the environment. Businesses are iabe for the mismanagement of used oi and are required to report spis that are a threat to human heath or the environment. Businesses are required to dispose of used oi propery. For exampe, the use of used oi as dust abatement or to contro weeds is considered to be improper disposa. Proposed Additiona Used Oi Requirements There are two proposed rue changes that affect businesses that manage spent working MWF as used oi. The first proposed change requires that used oi containers be kept cosed except when contents are being added or removed. The second change requires that used oi containers not be opened, handed, managed, or stored in a manner that coud cause the container to eak or rupture. Evapor porator Considerations and Compiance Issues Considerations Businesses that generate spent water-based meta working fuid (MWF) may wish to evaporate water from this wastestream to reduce waste voume and disposa cost. Water-based MWFs incude soube, synthetic or semisynthetic fuids but not straight ois. These water-based fuids usuay contain non-voatie substances and therefore are amenabe to evaporation. However, care must be used in buiding and operating an evaporator to prevent exceeding air quaity standards. Exceeding air quaity standards is undesirabe due to heath concerns as we as the potentia worker and/or neighbor compaints that wi draw undesired reguatory attention to a faciity. Water from spent meta working fuids can be evaporated without evaporating toxic air poutants by impementing the foowing six suggestions: 1. Cean the soution to be evaporated as much as possibe prior to evaporation. This wi minimize the evaporation of toxic air poutants and prevent fouing of pipes and the evaporator itsef. For spent meta working fuid, this means using an oiwater separator prior to the evaporator. Skim oi from the oi-water separator and coect it for disposa. 2. Do not evaporate to dryness. Soube spent meta working fuid is typicay 95% water and 5% additives (oi, surfactants, etc.) that are emusified in water. The water portion can be evaporated. However, if you evaporate to dryness, the emusion portion wi be evaporated as we and toxic air poutants may be emitted. To avoid evaporating to dryness, evaporate ony 95% of the water (see exampe). At the end of the evaporation process the concentrated emusion must be removed and disposed of propery. Note: Oi-water separators do not remove emusified additives from your meta working fuids. 3. Service the evaporator at reguar intervas. Keep a service og. Make one person responsibe for seeing that the og is kept current and work performed as required. 4. Carefuy reguate the operating temperature of the evaporator. Use the owest temperature possibe to avoid vaporizing toxic air poutants. The water in soube MWF bois at 212 F at sea eve and at sighty ower temperatures at higher eevations. Temperature contros shoud be set and ocked at or beow 212 F, as appropriate. METAL MACHINING INDUSTRY SECTOR PROJECT 21

24 Evaporator Use Exampe: 100 gaons of spent soube machine cooant needs to be disposed. The spent cooant contains: - 5% tramp oi, - 5% emusified napthenic oi, chorinated paraffins, metas, etc. - 90% water In this exampe, the spent cooant contains 5 gaons of tramp oi, 5 gaons of emusified compounds and 90 gaons of water. This spent cooant is paced into an oi-water separator, which removes the 5 gaons of tramp oi. The remaining 5 gaons of emusified compounds and 90 gaons of water are paced into an evaporator. Ony 95% of the tota amount of water shoud be evaporated. In other words, eave 5% of the water in the evaporator (in this scenario ~ 4.5 gaons). Otherwise, compounds wi be voatiized, creating toxic air poution. Excessive evaporation aso eads to formation of a baked on residue that is very difficut to cean off the evaporator unit. At the end of the evaporation process, remove the resuting concentrated soution and dispose of propery. In this exampe 9.5 gaons woud be removed (5 gaons emusified compounds and 4.5 gaons water). 5. Make sure the evaporator has emergency temperature and water eve shutoffs. The emergency high temperature shutoff shoud be set no more than 230 F. The ow eve water shutoff shoud be set at 5% of capacity. This seems redundant to everyone except those peope who have had their faciities catch fire. 6. Propery size mist eiminators. High veocity airfows create water dropets that suspend metas and other toxic air poutants in the exhaust air stream. Suspended poutants wi be carried out the stack uness trapped by a mist eiminator. A good vendor wi make sure that your evaporator has a propery sized mist eiminator. 22 WASHINGTON STATE DEPARTMENT OF ECOLOGY

25 Compiance Issues Air Air poution contro authorities reguate evaporation processes that emit toxic air poutants. Some of the toxic air poutants of concern that might be found in spent meta working fuids incude: cadmium compounds ead compounds auminum borates chromium (II, III, VI, & meta) iron oxide fume (Fe 2 O 3 ) copper tin oi mist (minera) iron sats seenium zinc There currenty is no minimum eve for toxic air poutants that wi exempt a business from reguatory review. If a business determines that they wish to evaporate a wastestream that contains or coud contain a toxic air poutant, they shoud contact their oca air authority (See Appendix E for contact numbers). The foowing are possibe outcomes of a reguatory review: Compiance Issues Hazardous Waste Businesses that choose to evaporate spent meta working fuid that designates as hazardous waste, are performing what is known as Treatment by Generator. Treatment by generator requirements incude the foowing (see Appendix F for more information): Hazardous waste management rues appy. For exampe, containers used to hod dangerous waste MWF must have secondary containment and be abeed Dangerous Waste and Toxic. (See Tabe 7 on page ) The spent meta working fuid must be counted before and after pacement into the evaporator. Businesses that evaporate dangerous waste must og the pounds of dangerous waste being evaporated. The counting rues are expained in more detai in Ecoogy s Counting Dangerous Waste Under the Dangerous Waste Reguations pubication (# ). NOTE: Evaporating spent MWF that does not designate as dangerous waste may generate residue that is dangerous waste. Not Reguated Evaporators do not require reguation if the iquid evaporated does not contain a toxic air poutant. Registered Evaporators that generate sma amounts of toxic air poutants must be registered with the oca air authority. Permitted Businesses with evaporators over a certain size may need to obtain an air operating permit. Businesses that generate more than 10 tons of a singe toxic air poutant or 25 tons of toxic air poutant (combined) are required to obtain a Tite V air operating permit. METAL MACHINING INDUSTRY SECTOR PROJECT 23

26 Chip Management Meta chips are one of the two main wastestreams generated at meta machining faciities. Because such arge voumes of waste meta are generated, most meta machining faciities find that it makes economic sense to recyce their waste chips. Recycing is the standard industry practice for managing waste meta chips. Chip Rec ecycing The key poution prevention issue in recycing meta chips is separating the meta working fuids from the chips. This separation achieves two benefits simutaneousy. As more fuid is recovered, more can be recyced and reused, thereby reducing the amount needing to be purchased by the faciity. Separating the fuids from the chips aso reduces the potentia contamination of stormwater when the chips are stored outside, or during oading and transportation. Furthermore, most meta recycers require that chips be we drained prior to pick-up. A number of different methods for draining chips are used at meta machining faciities. Some faciities manuay shut off the chip conveyor for a period of time and aow the fuids to drain back into the machine sump. Centrifuges and chip wringers are aso commony used to drain chips. At ow RPMs, centrifuges can aso be used for separating tramp ois from meta working fuids. A more passive chip draining system consists of drums, with screens on top, set at the end of the conveyor bet. In this system, the fuid coated chip fas off the conveyor bet onto the screen. Over time, the fuid wi drain through the screen and the dry chips can be transported to waste chip storage containers and the coected fuids can be recyced. Overa, the best method is one that aows the fuid to drain from the meta chip as soon as possibe before the fuid has a chance to begin evaporating. This prevents chemica residues from drying on the chips. These residues have the potentia to contaminate stormwater. Marketing Issues Faciities normay separate their chips by meta type in order to get the highest price from their meta recycing company. Meta recycers may aso offer a higher price to a faciity if the chips are compressed into a briquette through the use of a briquetting machine. (See Appendix C: Vendor Directory). The cost/benefit anaysis for purchasing such a machine incudes the price of the machine, the price offered for briquettes versus oose chips, and the voume of chips the faciity generates. Stormwater ter Issues Inside storage of waste chips is highy recommended, if enough space exists at the faciity. Outside storage introduces the possibiity that stormwater wi become contaminated from contact with the meta working fuid residues on the waste chips. Depending on the fuid used, these residues may contain metas, ois and/ or chorinated paraffins. Inside storage virtuay eiminates this potentia stormwater contamination probem. However, if chips need to be stored outside, use the foowing precautions to avoid stormwater contamination: 4 Be sure fuid has competey drained before pacing chips in storage containers. Any fuids or fuid residues have the potentia to contaminate stormwater either at your faciity or when stored at the recycing company. 4 Cover outside chip storage containers. This wi eiminate the possibiity that cean rainwater wi become contaminated by contact with residues on the chips. 4 Pace chip storage containers on concrete or asphat surface to prevent spis and eaks to bare ground. Instaing a perimeter berm or curb further reduces the possibiity of contaminating sois. 4 Continue draining fuids, if necessary. If it is necessary to pace chips outside before they are competey drained be sure that your outside storage containers aow drainage to continue. Many faciities simpy tit the waste chip dumpster towards one end and excess fuids to drain through a hoe into a residue container. 4 Check often for eaks. Be sure that outside storage containers and/or residue containers do not have hoes them. 4 Monitor and maintain containers on a reguar basis. Empty storage or residue containers and do not aow them to overfow. 24 WASHINGTON STATE DEPARTMENT OF ECOLOGY

27 Stormwater ter Regua guations Ecoogy s stormwater reguations require most industria faciities to have a stormwater permit. Any faciity that discharges stormwater to surface water, or into a storm sewer which eads to a surface water, must appy for a stormwater permit. If a of the stormwater from a faciity discharges to the ground and/or to a combined storm/sanitary sewer, a permit is not required. Faciities that need a stormwater permit and fai to appy for one coud be subject to ega actions. The permit requires industria faciities to deveop a Stormwater Poution Prevention Pan. These pans shoud identify existing and potentia sources of stormwater poution, and describe how the faciity wi reduce or eiminate that poution. Additiona specific panning requirements are detaied in the permit. Contact an Ecoogy staff person in your region if: You are uncertain if your faciity needs a stormwater permit You have any questions about current practices and possibe stormwater impacts at your faciity See the inside front cover for a regiona map to identify your region Northwest Regiona Office - Beevue Ron Devitt (425) Bob Newman (425) Bob Wright (425) Southwest Regiona Office - Oympia Dick Schroeder (360) Eastern Regiona Office - Spokane Pau Turner (509) Centra Regiona Office -Yakima Pam Perun (509) METAL MACHINING INDUSTRY SECTOR PROJECT 25

28 Foor Ceaning Routine Maintenance In the meta machining industry the presence of spied or eaked meta working fuids, hydrauic ois, or tapping fuids can cause foor mop water to designate as a dangerous waste. This is especiay true if these fuids contain chorinated paraffins. Mop water from foor ceaning shoud be tested and designated to verify whether or not it is dangerous waste. Testing must be done in accordance with the requirements under the State Dangerous Waste Reguations (WAC and -100). Common dangerous waste constituents to test for incude: ead, cadmium, chromium, seenium, copper and zinc. Zinc bearing metas (i.e. brass) and zinc-pated parts that are machined often contain ead. If the meta working fuid or hydrauic ois being used contain chorinated paraffins, the mop water shoud be tested for tota haogens. Aso, depending on the chemica make-up of some ceaning agents and/or ceaning sovents, mop water may designate as a hazardous waste. Mop Water ter Disposa Options The foowing management options appy to mop water depending on whether or not it is dangerous waste: Mop water that is NOT a dangerous waste: May be discharged to a sewer system after receiving the oca sewer district s approva. Mop water may exceed the sewer district s imits for oi and greases. Must not be discharged to storm drains, dry wes, or septic systems. Businesses must know where drains ead before using them. Shoud not be mixed with spent meta working fuid. See Step 3 on page 14. Has the spent MWF been mixed with other wastestreams? Mop water that IS a dangerous waste: Must be managed as dangerous waste. Management requirements depend on the generator status of the business. For more information on management requirements, reference Tabe 7, tited Guide for Dangerous waste (DW) Generators in Washington. Must not be mixed with any other nondangerous wastes; otherwise the entire wastestream becomes a dangerous waste and must be managed as such. Sma quantity generators may treat the mop water onsite or ship it offsite to a permitted temporary storage disposa faciity, oca moderate risk waste faciity, or other permitted soid waste faciity (WAC (8) (b)(iii). Mop water must meet two conditions in order to be discharged to a sewer system. It must be treatabe by the oca sewer district and must be either a state-ony waste or a highy diuted federay isted waste. Before discharge, a business needs to obtain an appropriate permit issued by the Department of Ecoogy or oca sewer district (WAC (3)(a)). This mop water is excuded from dangerous waste counting requirements uness it is treated before discharge. See Ecoogy Pubication #94-136, Revised 6/97, Domestic Sewage Excusion for more information. Mop water that is a characteristic waste must be managed as a dangerous waste. Furthermore, the Domestic Sewage Excusion does not appy to mop water that is a characteristic waste. You may wish to consider using treatment-bygenerator options, such as evaporation, as a means of minimizing the voume of waste. See Appendix F: Treatment By Generator. 26 WASHINGTON STATE DEPARTMENT OF ECOLOGY

29 The foowing suggestions wi hep keep mop water from becoming dangerous waste: Don t use mop water to cean up sovent or oiy spis. Don t mix norma mop water with water that is used during the cean up of spied sovent or chorinated fuids and ois. Prevent eaks by propery maintaining equipment. Spis-Absorbent Waste Disposa The same constituents that can cause mop water to become dangerous waste can aso cause foor absorbent to become dangerous waste. These constituents incude ead, chromium seenium, zinc, copper, chorinated paraffins, sovents, etc. Testing must be done in accordance with the requirements under the State Dangerous Waste Reguations (WAC and -100). Waste absorbent that is NOT dangerous waste: Can be disposed in a dumpster upon the approva of the oca andfi or soid waste hauer. Sufficient absorbent must be used to prevent the presence of free iquids. Waste absorbent that t IS danger erous waste: Must be managed as a dangerous waste (See Tabe 7). Sma quantity generators may treat this waste onsite or ship it offsite to a permitted temporary storage disposa faciity, oca moderate risk waste faciity or other permitted soid waste faciity (WAC (8) (b)(iii)). The foowing suggestions may decrease the amount of absorbents needed or prevent absorbents from designating as dangerous waste: Absorbents are often used to cean up wastes that are managed as used oi, such as way ois and spent MWF. It is often incorrecty assumed that these contaminated absorbents can aways be managed as used oi. Ecoogy s proposed poicy concerning used oi states that: Materias that are not dangerous waste and that contain or are otherwise contaminated with used oi in recoverabe quantities can be managed as used oi. Under norma conditions, spent absorbents used to ceanup oi spis do not contain recoverabe quantities, therefore, they are not subject to the used oi standards. If the spent absorbant does not contain hazardous constituents, they may be managed as a soid waste. Disposa options for waste absorbents depend on whether or not they are dangerous waste. Contain eaks in catch basins or spi pans in pace of pads. Liquid can be reused, recyced, or propery disposed. Vacuum spis and reuse, recyce, or propery dispose the recovered iquid. Use rags that can be wrung out and aundered for reuse. Recovered iquid can be reused, recyced, or propery disposed. METAL MACHINING INDUSTRY SECTOR PROJECT 27

30 Heath Concerns Department of Labor and Industry has done substantia work with heath concerns in the meta fabrication industry through their SHARP program. Key information from this program is excerpted beow from the fact sheet tited, Meta Working fuids: A Fact Sheet for Workers (# ). The entire fact sheet and additiona information can be found on their website at or by phone at (888) 66 SHARP. Who is Exposed to MWFs? According to the Nationa Institute for Occupationa Safety and Heath (NIOSH), over 1 miion workers in the United States are exposed to MWFs. Here at the Safety & Heath Assessment & Research for Prevention (SHARP) program, we have estimated that approximatey 20,000 workers in Washington State use MWFs. Whie machinists, machinery mechanics, metaworkers, and other machine operators and setters have the greatest contact with MWFs, workers performing assemby operations can aso be exposed if MWFs remain on the machined product. Workers can be exposed to MWFs by skin contact, or by inhaing (breathing in) or ingesting (swaowing) partices, mists, and aerosos. What t are e MWFs Heath Effects? Athough recent changes in MWF formuations have resuted in safer products, it is important to reaize that MWFs can sti contain substances that are harmfu to your heath. The most commony observed inesses associated with MWF use are: Skin Prob obems Skin contact with MWFs is very common, since MWFs are often appied to the machine too in arge voumes. Workers skin can be covered with mist or spray whie machining, or handing parts and toos covered with residua fuid. MWF-soaked rags and cothing can proong the ength of time that the MWF is in contact with the skin. MWFs have been shown to cause numerous skin probems, ranging from dermatitis due to irritation or aergy (very common) to skin cancer (reativey rare). NIOSH has observed that between 14% and 67% of workers using MWFs have dermatitis. Cancer There is evidence to suggest that exposures to some MWFs can increase workers risk for cancer of the skin, esophagus, stomach, pancreas, arynx, coon, rectum, and other organs. However, the ink between MWF exposure and cancer is controversia, since the epidemioogica studies were performed on workers who were exposed to MWFs as ong as years ago. Before the 1950s and 1960s, some MWFs contained reativey high concentrations of substances suspected to cause cancer (mosty poycycic aromatic hydrocarbons and nitrosamines). Since then, industry actions have resuted in substantiay reduced concentrations of these substances in MWFs. However, it is uncear whether these changes have eiminated the cancer risk because it is not known if the cancer-causing substances are present in the MWFs themseves, or whether they are constituents of MWF additives or contaminants. Lung Disease Inhaing the aerosos, partices, and mists generated by MWFs whie machining is a common source of exposure. Severa ung diseases are associated with inhaing MWFs, incuding asthma, acute airway irritation, hypersensitivity pneumonitis, ipid pneumonia, chronic bronchitis, and possiby ung cancer. NIOSH researchers suggest that machinists face an increased risk of asthma at concentrations beow the current permissibe exposure imits (PELs). 28 WASHINGTON STATE DEPARTMENT OF ECOLOGY

31 What t Occupationa Standards ds Appy to MWFs? The two most important occupationa standards that appy to MWFs are those for particuates not other-wise reguated and oi mists. In Washington State, the PEL for tota particuates is 10 miigrams of tota particuate per cubic meter of air (10 mg/m 3 ), based on an 8-hour time weighted average (TWA). This means that exposures to tota particuates can egay exceed 10 mg/m 3 at times, but ony if concentrations are beow 10 mg/m 3 at other times, so that the average exposure for any 8- hour workshift is 10 mg/m 3 or ess. The PEL for oi mists is an 8-hour TWA of 5 mg/m 3. NIOSH is concerned that workers may experience adverse respiratory effects if they are exposed at the current PELs. NIOSH recommends that occupationa safety and heath programs that incude medica monitoring shoud be estabished at MWF-using workpaces. As of summer 1997, NIOSH is finaizing its Criteria Document (see sidebars on page 3) and OSHA (the Occupationa Safety and Heath Administration) is convening a committee of nationa experts to deveop a proposa for a new standard to ower workpace exposures and increase worker protection. PELs aso exist for certain additives and other MWF Constituents. METAL MACHINING INDUSTRY SECTOR PROJECT 29

32 Appendix A: Gossary Biocide Coaescer Extra Pressure (EP) Additives Haogenated Meta Working Fuid(MWF) Oi Skimmers Paraffin A chemica additive used to ki organisms in meta working fuids. Biocides incude bactericides and fungicides. Bactericides ki bacteria and fungicides ki fungus. Porous-media seperators which use oi attracting media beds to attract oi in preference to water. These additives are commony composed of haogenated paraffins. The haogen in the compound compexes with the meta workpiece and adds extra ubrication for increased too ife. A compound containing any one of the haogen series of eements. These are commony chorine, bromine, and iodine in meta working fuids. Meta Working Fuid is used in machining meta parts to coo and ubricate the too pieces, thus proonging the ife of the too. Oi skimmers remove the tramp oi and debris from the surface of the meta working fuid. They use either a rotating disk, a moving bet, or a moving rope that dips into the tank, and attracts the tramp oi to it s surface. The tramp oi is then scraped off the disk, bet, or rope and into a container. Paraffins are ong, straight carbon chain organic moecues with no cycic or ring structures in their moecuar makeup. They are primariy composed of carbon and hydrogen and may have haogens attached for extra properties. Semi-Synthetic This fuid is the same as the synthetic fuid (beow) but has a sma amount of oi added Fuid (2-20%). Soube Oi Fuid Straight Oi Fuid Sump Synthetic Fuid Tramp Oi: A concentrate of severey hydro-treated ois combined with arge amounts of emusifiers. This combination aows the fuid to mix with water into a soution. A fuid that consists of sovent-refined or hydro-treated petroeum oi or other ois of anima or vegetabe origin. A tank that hods meta working fuid. A concentrate that is added to water to form an aqueous meta working fuid. The concentrate does not contain crude oi, or oi of any other kind. This fuid is commony made up of amines, nitrites, nitrates, phosphates, soaps, and gyco. Tramp oi is most commony made up of way oi (the ubrication used for the siding parts of the machine) and hydrauic ois that fa, or are carried into the meta working fuid. 30 WASHINGTON STATE DEPARTMENT OF ECOLOGY

33 Appendix B: List of Poution Prevention ention Opportunities by Operation Sump Maintenance 1. Cover Sumps: By covering the meta working fuid (MWF) sumps in machines, airborne microorganisms are kept out of the fuid. This is important because a arge number of the microbes that contaminate fuids are airborne. Covers aso keep out trash such as dust, cigarette butts and food. 2. Sump and Trench Maintenance: Periodicay ceaning out the MWF sumps and trenches wi keep them free of soid matter that can hamper fuid fow. Soid materias provide exceent areas for microbe growth and may cog up MWF ines. Disinfect sumps and trenches when MWF fuid is removed. Without the disinfecting step, new MWF fuid wi be inocuated with eft over bacteria when it is added to the sump. 3. Leave Machine MWF Pumps On during Downtime: Whie the machine is not in operation, eave the MWF circuating through the machine to hep aerate the fuid and keep it from becoming stagnant. 4. Movement of Fuid in Sump: A sma pump can be used to circuate fuid in a sump, preventing stagnation and anaerobic microbia growth in the fuid. 5. Sump Size: By keeping the sump size as sma as possibe, the fuid has a greater fow-through rate, and wi not become stagnant. Meta Wor orking Fuid Seection 6. Use Chorine Free MWFs: The proposed reguations, if adopted, wi prohibit waste MWF formuated with haogenated compounds from being designated as used oi. Haogenated compounds incude chorine, bromine, and iodine (see gossary). 7. Number of MWFs: Use the smaest number of different MWFs as possibe. This simpifies the variabiity in MWF management and minimizes the overa amount of management required. 8. Use High Quaity MWFs: The use of high quaity MWFs is recommended because these fuids are more resistant to bioogica attack and additive breakdown. This resistance aows them to be used many times without a oss of performance. 9. Look at the Compatibiity of Way Ois and MWF s: Ensuring that way ubricants and MWFs easiy separate wi hep in the treatment and recycing process. Seect a way oi that does not cause foaming probems or impair the separation characteristics of the two fuids. High-grade way ois typicay separate easiy from MWF. In addition, they contain itte or no sufur compounds that are a food source for bacteria. Meta Wor orking Fuid Maintenance Pan 10. Daiy Inspections: Conducting daiy inspections of each machine wi hep identify probems and trends, and speed up machine repair through eary identification of probems. This contributes to ess downtime and ess fuid waste. 11. Operator Responsibiity: The maintenance of meta working fuids (MWF) shoud be imited to ony one person or a team of peope who are trained and knowedgeabe about fuid maintenance. This wi reduce fuid property variances and hep cut down on the overuse of MWF. Meta Wor orking Fuid Testing 12. Monitor Concentration: Keeping the concentration of the MWF in the correct range wi ensure that ony the right amount of concentrate is used. It wi aso hep contro any gumming, sticking or smearing eft on workpieces due to excess concentrate. Refractometry and titration are the most common techniques for measuring fuid concentration. APPENDIX B 31

34 Chip Management 13. Monitor ph: By monitoring the ph of the MWF, probems with the fuid can be spotted. A drop in ph may mean that there is a high microbe count in the fuid, or that impurities are buiding up. Keeping the ph in the correct range wi hep contro microbia growth, and hep reduce foaming and separation of the fuid. 14. Keep Log of Monitoring Data: Keeping a og of fuid characteristics, such as ph and concentration, wi hep identify trends, sove probems, and keep the fuid in the proper condition. Rec ecycing Systems 15. Tramp Oi Skimmers: These come in severa different types incuding rope, bet and disk skimmers. Skimmers remove the oi that makes its way into the MWF and foats on the surface of the fuid. Oi remova heps keep the fuid aerated with dissoved oxygen, and reduces the food source for microorganisms. 16. Aerate/Ozonate: By aerating the MWF or using an ozone generator to bubbe oxygen through the fuid, the anaerobic microbe count wi be kept ow. Dissoved oxygen in the water keeps anaerobic bacteria from growing and creating the Monday morning stink. MWF treated with dissoved ozone reduces the microbe count. Ozone is highy toxic to microbes and kis them. 17. Centra Recycing Systems: Centra recycing systems aow a arge voume of fuid to be treated at once. Smawheeed versions (about the size of a arge shopping cart) are avaiabe. A good recycing system incudes a setting tank, oi skimmer, coaecser, and an aeration device 18. Chip Fiters: Fiters keep the chips and grit created in the machining process from contaminating the MWF sump. The high amount of surface area created by the chips provides an exceent area for microbe growth. Thus, fitering heps to ower the bacteria count. 19. Drain Meta Chips to Recover Fuid: One way of draining meta chips is to pace them into a perforated container with a catch basin and reuse the coected meta working fuid. Another option is to manuay shut off the chip conveyor for a period of time and aow the fuids to drain back into the machine sump. A chip wringer or centrifuge can be used to get even more fuid from the chips. These processes produce higher quaity chips for recycing. 20. Recyce the Meta Chips and Scrap: Many, but not a, meta recycers wi take chips. They wi usuay require chips to be segregated by meta type and free of oi. A higher price can usuay be obtained if chips are compressed into briquettes through the use of a briquetting machine. 21. Store Chips Under Cover: By storing meta chips and shavings inside or under cover, the risk of contaminating stormwater is reduced, and the chips are kept at a better quaity. Store chips on an impervious surface to prevent soi contamination from eaks and spis. Spis 22. Pumps, Spigots, and Funnes: Using pumps, spigots and funnes when transferring MWF wi reduce the amount of ost fuid and the risk of spiing fuids. 23. Reuse Absorbent Pads: Using absorbent pads that can be wrung out and reused wi cut down on the amount of absorbent materia that must be discarded as hazardous waste, and save money in fresh absorbent and waste handing costs. Another option is to dedicate a mop for the cean up of oiy spis. 32 WASHINGTON STATE DEPARTMENT OF ECOLOGY

35 24. Use Catch Basins: Contain eaks in catch basins instead of using absorbent pads. 25. Vacuum Spis: Vacuum spis instead if using absorbent pads or catch basins. The recovered fuid can be reused, recyced, or propery disposed. Other 26. Fix Leaking Seas and Gaskets: This keeps the fuid where it beongs, instead of on the foor or a over the machine and operator. Even sma eaks can waste a surprising amount of fuid over time. 27. Gasket and Sea Compatibiity: Make sure that the gaskets and seas on machine equipment are not degraded by either the way oi or the MWF. 28. Use Distied or Deionized Water: Using distied or deionized water keeps dissoved mineras out of the MWF. These contaminants can buid up in the fuid as the water in the fuid evaporates, causing separation of the concentrate from the water. 29. Tramp Oi Separation: Tramp ois and MWF shoud be thoroughy separated before skimming the tramp ois off the top. This wi reduce the amount of MWF that is wasted with the remova of the tramp oi. 30. Biocide Addition If other methods do not work, the addition of a biocide/fungicide can hep extend the ife of MWFs. These additives shoud be used sparingy, and ony as a ast resort. When fuids with biocides are spent, they shoud be tested to determine if they are a hazardous waste. Some biocides contain chorinated compounds. 31. Wash hands to reduce bacteria: Machinists frequenty come in contact with meta working fuids and humans are a primary source of bacteria. Washing hands reguary wi reduce the spread of bacteria. 32. Cooing of the MWF: Keeping the MWF coo wi hep sow the growth of microbes in the sumps and fuid areas. APPENDIX B 33

36 Appendix C: Vendor Directory Equipment Most of the foowing vendors were taken from the Thomas Register and are sampes of vendors in each category that serve the meta machining industry. For a compete isting of vendors, see the Thomas Register at Cooant Reco ecovery ery Systems: Cecor, Inc., Verona, WI (800) Como Industria Equipment, Inc., Janesvie, WI (800) x25 Cooant Wizard, Inc., Indianapois, IN (317) or (888) Deer Path Industria Technoogy, Inc., Issaquah, WA (425) Edjetech Services, Weington, OH (888) Hyde Products, Inc., Ceveand, OH (800) or (440) Hydrofow, Inc., Saem, NH (603) Lakos Fitration Systems, Fresno, CA (559) Monan/Chemaperm, Kaamazoo, MI (616) Sanborn Technoogies, Medway, MA (800) or (503) Chip Briquetting Systems: Counseor Engineering, Inc., Hudson, OH (800) Deer Path Industria Technoogy, Inc., Issaquah, WA (425) Gensco America Inc., Decatur, GA (800) Komar Industries, Inc., Groveport, OH (800) or (614) Lewis Corp., Pocateo, ID (800) Mutipress, Inc., Coumbus, OH (614) Scanrec, Waco, TX (800) Chip Wringing Equipment (Centrifuges) es) Barrett Centrifugas Inc., Worchester, MA (800) Chip Systems Internationa, Scotts, MI (616) Prab Conveyors, Kaamazoo, MI (800) Inter-Source Recovery Systems, Kaamazoo, MI (800) Nationa Conveyors Co. Inc., East Granby, CT (800) x12 Rousseet Centrifuge, Inc., Bethesda, MD (888) WASHINGTON STATE DEPARTMENT OF ECOLOGY

37 Evapor poration Systems: Equipment Manufacturing Corp, Whittier, CA (888) Environmenta Hydrotech, Inc., Croton, NY (914) Hyde Products, Inc., Ceveand, OH (800) or (440) Landa Water Ceaning Systems, Camas, WA (800) or (360) Nordae Environmenta Engineering, Cinton, IA (800) Patterson Industries LTD, Ontario, Canada (800) x Tramp Oi Separ parator tors: Edjetech Services, Weington, OH (888) Environmenta Protection Associates, Inc., Seatte, WA (800) Hyde Products, Inc., Ceveand, Ohio (800) or (440) Services Recycing of Meta Chips/Shavings/ Borings (aso ca Ecoogy s Hotine, RECYCLE) City Junk Inc., Tukwia,WA (206) Independent Metas Co., Seatte (206) Pacific Iron and Meta, Seatte (206) Riverside Savage and Meta Co. (206) Seatte Iron and Metas Corp., Seatte (206) West Seatte Recycing Ctr., Seatte (206) Waste Meta Wor orking Fuid Disposa Meta Working Fuid Recovery (for non-hazardous, water soube fuids) Basin Oi, Seatte Phiip Services, Renton (800) (800) Keep it Cean Recycing, Redmond Seaport Petroeum (425) (206) Stouder Engineering & Machine, Hagerman, ID (208) Word Chemica USA, Inc., Torrance, CA (888) APPENDIX C 35

38 For Disposa of MWF as used oi or hazardous waste: Advanced Environmenta Tech Svs, Tukwia (800) Amagamated Services, Inc., Sumner (800) Cean Care Corp., Federa Way (800) Envirotech, Seatte (800) FBN Environmenta, Kirkand (425) Front Water Services, Seatte (800) Keep It Cean Recycing, Redmond (425) Phiip Services, Renton (800) Protective Environmenta Svcs, Seatte (206) Romic Environmenta Technoogies, Tacoma (253) Safety-Keen, Lynnwood (425) Shutz Distributing, Seatte (800) WASHINGTON STATE DEPARTMENT OF ECOLOGY

39 Appendix D: Interim Used Oi Poic oicy APPENDIX D 37

40 38 WASHINGTON STATE DEPARTMENT OF ECOLOGY

41 Appendix E: Map of Air Poution Contro o Authorities APPENDIX E 39