Prepared by: Goodrich Landing Gear Services 5415 Service Rd N, Burlington ON L7L 5H7 December 2013
Contents Statement of Intent... 2 2.0 Identification of Stages and processes... 4 3.0 Estimated Direct and Indirect Costs... 8 4.0 Identification of Options for Reduction in Usage of... 8 5.0 Analysis of Technical Feasibility... 8 7.0 Analysis of Economic Feasibility... 9 8.0 Options that will be Implemented... 9 9.0 Planner Recommendations... 9 10.0 Certification... 10 1
Statement of Intent Goodrich Landing Gear Services works to reduce our impact on the environment and invest in technologies that set new standards for efficiency. We invest in the communities where we live and work around the world. We are committed to reducing the environmental impact of our manufacturing operations by implementing the principle of pollution prevention in daily activities. Key activities include continually seeking ways to reduce the usage of toxic substances. Objective Goodrich Landing Gear Services has prepared this toxic substance reduction plan for copper to investigate options to reduce the usage of copper while supplying customers with products that meet their needs. The facility will continue to monitor options to replace copper to determine whether they become technically and economically feasible. 2
1.0 Facility Information Toxic Substance CAS# 7440-50-8 Number of full-time equivalent employees 144 NAICS 481110 NPRI ID 5642 UTM NAD83 coordinates (entrance) 600436, 4805243 Canadian Parent Company Legal name n/a Street address n/a % owned by parent n/a CCRA business number n/a Contact info Owner and operator of facility Highest ranking employee Person who coordinated preparation of plan Person who prepared plan Public contact Goodrich Landing Gear Services 5415 Service Rd N, Burlington ON L7L 5H7 Greg Watson Site Director Goodrich Landing Gear Services 5415 Service Rd N, Burlington ON L7L 5H7 905 319-3006 Greg.watson@goodrich.ca Michael Rau EHS Specialist Goodrich Landing Gear Services 5415 Service Rd N, Burlington ON L7L 5H7 905 319-3006 Michael.rau@goodrich.ca Wendy Nadan Nadan Consulting Ltd 151 Montgomery Blvd Orangeville ON L9W 5C1 519 940 4724 wendy@nadanconsulting.com Greg Watson Site Director 3
Goodrich Landing Gear Services 5415 Service Rd N, Burlington ON L7L 5H7 905 319-3006 Greg.watson@goodrich.ca Technical contact Wendy Nadan Nadan Consulting Ltd Planner License number of planner 151 Montgomery Blvd Orangeville ON L9W 5C1 519 940 4724 wendy@nadanconsulting.com Wendy Nadan Nadan Consulting Ltd 151 Montgomery Blvd Orangeville ON L9W 5C1 519 940 4724 TRSP 0092 2.0 Identification of Stages and processes Receiving stage Disassembly stage Refurbishing stage Shipping stage Receiving raw materials Disassembly destressing Cad plating Paint QC Media blast Non-destruct test Deburr Storage raw materials Degreasing Machining Shot peen Packaging and shipment Chrome/cad strip Nital etch Bushings 4
Manufacturing processes A number of processes are undertaken to repair and overhaul individual landing gears and other aeronautic components, including machining, media blast, plating, grit blasting, solvent degreasing, shot peening, testing and painting operations. Depending on the particular component, a used aircraft part will undergo the above-mentioned processes in different combinations depending on the degree of repair necessary. Each of these processes is described in the following text. is received into the plant as bushings on the landing gears to be refurbished and as raw material to manufacture new bushings. Disassembly/Inspection All parts arriving on-site are disassembled. Tools are used to remove components contained within an aircraft gear/part. Engineers visually inspect and measure parts to determine the subsequent refurbishing processes to be undertaken. Media Blast Painted parts are exposed to a media blast, plastic beads, that bombard the used parts at high velocities, removing paint from the part. The particulate released from this process is comprised of the dry paint components removed during blasting and small fragments of the plastic beads. The exhaust is vented to a baghouse, which vents directly to outside environment. Vapour Degreasing Parts require degreasing at various points during the refurbishing process. In vapour degreasing n-propyl bromide is heated to the boiling point, producing a vapour zone into which parts are lowered. The vapour condenses on the part, leaving a layer of pure solvent, which removes grease and grime. The solvent vapour is mostly recovered in the top of the unit by condensing coils and recycled. Some of the vapor escapes however and is vented directly to the atmosphere through a stack. Connected to the vapour degreaser are small distillation units that are used to remove the solvent from the dirt and sludge that accumulates in the vapour degreaser. The solvent is then recycled back into the degreaser unit. This process is closed looped and thus, does not release emissions to air. Stress Relief Heat Oven Parts are placed in a de-stressing heating oven to remove any residual stresses within the metal. De-stressing occurs before and after machining operations. The oven is heated using natural gas. Cadmium/Chrome Stripping Depending on the particular part, chrome or cadmium stripping may be required. In anodic stripping, the chrome or cadmium is drawn off of the part using an electric current. Stripping operations are undertaken in the plating area, any emissions released from the 5
chrome/cadmium strip tanks are captured and vented to a scrubber. The scrubber exhausts directly to the atmosphere through a stack. Machining Operations There are a variety of CNC machines used to drill, lathe, grind and bore parts to remove defects in the metal. These operations utilize cooling and cutting fluids during this process. Large metal pieces removed during these machining processes are captured in the cutting and cooling fluids. Bushings are also manufactured in house to replace bushings that are removed and discarded during disassembly. Bushings contain copper. Non-Destruct Testing Non-destructive testing (NDT) is conducted in an oil-based bath by magnetic particle penetration to detect any cracks or porosity. NDT can be undertaken throughout the refurbishing process when deemed necessary. There are no emissions to air during testing. Deburring Any sharp edges present on the part after machining are removed using flat wheels and sanding belts. As the burrs are removed from the parts, particulate matter is released. There are three deburring booths in which deburring operations are undertaken. Each of these booths is equipped with a particulate capture system that exhausts air through a HEPA filter back into the room. Nital/Brush Etching Nital/Brush etching is a non-destructive, in-process inspection method that detects surface tempering and/or rehardening in all grinding processes. Etching is typically undertaken after deburring and machining operations. The etching process does not release emissions to air. Cadmium Plating Some parts require cadmium plating, depending on the part and its use. Mists from the surface of the plating baths are captured at the source and routed through a wet scrubber before being discharged outside. Shot Peening In the shot peen process, the part is bombarded with steel shot to introduce a residual compressive stress to the surface of a part to increase the fatigue life of that part. Some of the metal shot is destroyed in the process and passes through a baghouse to remove the particulate. A HEPA filter is installed as an afterfilter. The air is discharged outside. Media Blasting In some instances parts require media blasting to prepare the surface for painting. The surface is bombarded with plastic beads. Media blasting is undertaken in small-enclosed booths. The particulate released during media blasting vents directly from the booths into a cyclone dust collector that exhausts to a baghouse unit. Particulate laden air enters the baghouse, travels through a series of filters and exhausts to the outside environment. Painting 6
Painting is conducted in a paint booth using HVLP paint guns. The solvent used in the painting process evaporates from the part and is emitted outside. The overspray from the guns passes through a filter. After painting, the part is moved to an enclosed flash-off area, and then to a curing room, where curing lamps expedite the curing process. Material Accounting Calculations is found in the bronze used to make the bushings. Bushings are removed from the incoming part and discarded. Some of the new bushings are manufactured on site, some are purchased ready made. The quantity of copper found in the used bushings has not been counted as these parts are considered a manufactured article. Mass balance was used as the method of quantification as the data is readily available and quantities are based on measured weights. The quantity of raw material is obtained from purchasing records. The quantity of scrap shipped off site is measured and the company paid for the metal value. The difference is assumed to be contained in product. All the metal used exits the process either as a finished good or as waste that is shipped off-site for recycling. The weight shipped off-site as waste is measured and recorded on shipping manifests. The balance of the material used is assumed to be contained in finished goods. It is considered that the inputs and outputs are approximately equal. Bushings bronze U = 35,640 kg DQL = high Machine bushings and install P = 33,344 kg DQL = high TR = 2,296 kg DQL = high Legend U Use of toxic substance P Toxic substance contained in product TR Off site transfer for recycling DQL data quality level 7
3.0 Estimated Direct and Indirect Costs The use of copper at the facility is expected to significantly decline as replacement bushing are purchased rather than fabricated on site. Replacement bushings are considered manufactured articles and the copper content is not counted for the purposes of quantifying the amount of material used. Hence, a cost estimate has not been quantified at this time. 4.0 Identification of Options for Reduction in Usage of The following options were identified to reduce the usage of copper. Category Material substitution Product Design Process Modification Spill and leak prevention Reuse or recycling Inventory management Training Description Option 1: Use a different metal instead of copper. This option would result in the reduction in use of 35.64 tonnes of copper or 100%. Option 2: Reduce the thickness of copper used in the bushings. Reduction in thickness is estimated to reduce the quantity of copper used by 3.5 tonnes or 10%. Losses of copper in the manufacturing process are due to material removed to form the final shape of the bushing. Due to the high cost of copper, waste is monitored very closely and the minimum size material to make the bushing is used. In addition, most of the bushings are now purchased pre-made so there is less copper used on site. The toxic substance is a solid metal and hence there is no potential for a spill or leak. All metal waste is currently collected and recycled off-site and hence there is no additional option available in this category. It is not practical to recycle metal on site. Purchase just-in-time for orders as they are received. This option ensures that exact quantities are purchased and there is minimum waste as scrap. As copper has no limit to shelf life if it is stored properly, and the facility currently uses an automated ordering process, this option is not expected to result in any reduction in the use of copper. This option will not be pursued further. Train employees in techniques to minimize waste. A number of improvements have been made in the past several years with employees trained in methods to reduce waste. Employee training is an ongoing process as opportunities are identified to improve the manufacturing process. 5.0 Analysis of Technical Feasibility Each of the options identified above were screened for technical feasibility using the following criteria: Availability and reliability of technology Impacts on quality, reliability, functionality Impact on production rate Compatibility with customer requirements 8
Availability of employee training Compatibility with existing processes Space within facility Time required for change The results are recorded in the following table: Option Technical Feasibility Feasible Option 1: Use Specifications for refurbishment are provided by the customer. alternate metals Changes in the process used must undergo an exhaustive No Option 2: Reduce thickness of copper. qualifying process by the original equipment manufacturer. Specifications for refurbishment are provided by the customer. Changes in the process used must undergo an exhaustive qualifying process by the original equipment manufacturer. No 7.0 Analysis of Economic Feasibility No technically feasible options were identified and hence no economic feasibility has been conducted. 8.0 Options that will be Implemented No technically or economically feasible options have been identified. Existing processes that focus on reducing waste will continue with the goal of driving down costs and using raw materials more efficiently. 9.0 Planner Recommendations The licensed planner has worked with staff at the facility throughout the plan, has conducted a site visit to identify stages and processes and been provided with data by the facility. The nature and method of use of the toxic substance in this plan is such that there is little opportunity to reduce usage of copper and due to the high cost of this raw material, waste is constantly evaluated in an effort to reduce associated costs. Hence, there are no recommendations in this plan. 9
10.0 Certification As of December 12, 2013, I, Greg Watson, certify that I have read the toxic substance reduction plan for copper and am familiar with its contents, and to my knowledge the plan is factually accurate and complies with the Toxics Reduction Act, 2009 and Ontario Regulation 455/09 (General) made under that Act with the exception of the regulatory deadline. Greg Watson, Site Director Date As of December 3, 2013, I, Wendy Nadan certify that I am familiar with the processes at Goodrich Landing Gear Services that use copper, that I agree with the estimates referred to in subparagraphs 7 iii, iv and v of subsection 4 (1) of the Toxics Reduction Act, 2009 that are set out in the plan dated November 30, 2013 and that the plan complies with that Act and Ontario Regulation 455/09 (General) made under that Act with the exception of the regulatory deadline. November 29, 2013 Wendy Nadan, Toxic Substance Reduction Planner Date 10