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Cleaning up the environment.

You can't look at metalworking's materials and processes any more without considering their impact on the human operator and on the environment-whether inside or outside of the manufacturing facility. And the closer you look, the more complicated government regulations have made the business life of metalworking companies.

"Four or five years ago metalworking managers had to worry about four of five regulations; today there may be 20 or more that affect their manufacturing operations," says Randy Junkins, president, Junkins Engineering Inc, a Morgantown, PA-based environmental engineering consultant.

And the heat is on as the Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA), increase monitoring and enforcement of regulations, especially on small and medium-sized companies, says Mr Junkins. Last year, for example, OSHA fines jumped 700% and instances of substantial fines for not submitting the right paperwork by smaller companies occurred. And the threat of criminal prosecution for management and supervisory personnel is a real possibility.

Finding out what to do

The impact of environmental regulation on smaller and medium-sized companies isn't unexpected. They are least able-in terms of human and financial resources-to deal with the proliferation of regulations aimed at cleaning up the environment's twin streams: 1) ambient in-plant air and exhaust air; 2) fluids used in metalworking processes and outfall wherever run-off leaves a manufacturing property site.

The problem is often one of simply knowing what the regulations are, what they require, when and how to comply, and how to get help in complying. That's why the National Tooling & Machining Association, Ft Washington, MD, devotes a considerable amount of its resources to translating the complicated rules into plain English and developing responsible compliance strategies. The principal body of law that will affect most tooling and machining companies, for example, is the "small quantity generator (SQG)" provision of RCRA (the Resources Conservation and Recovery Act) as enforced by the EPA, says NTMA.

Though SQG provisions may relieve smaller companies of some of RCRA's burdens, others can pose major problems. Because these firms work in batches of only a few parts at a time, and each job is usually of dissimilar material, material safety data sheets (MSDS) or chemical analysis specifications are usually not available, particularly for small lots on a subcontract basis. Waste hauler's fees and required chemical analysis costs can easily outstrip revenues for small batch work, says NTMA.

NTMA feels that simply publishing complicated proposals and final rules in the Federal Register and requiring compliance and repetitious reporting and record-keeping are onerous and unreasonable for smaller companies.

"The EPA is just doing what it knows how to do best-writing regulations hand-over-fist," says William E Ruxton, NTMA's manager/technical department. He says that one of the most important single issues facing companies today is compliance with EPA storm water regulations.

NTMA expects the cost of compliance for small companies to be "considerably higher" than EPA estimates. A major factor is the cost of consultant services to prepare applications. Another factor is that a more flexible general permit (one of three permit options open to companies) was not available in many metalworking states before the deadline for group or individual permits was reached. NTMA says that this affected more than half of the industry's small manufacturing companies.

Airborne pollutants

What's in the air is equally of concern both inside and outside of plants. While EPA deadlines for final phase-out of certain chemicals important to metalworking processes have been set, their replacements are in the process of being evaluated. Materials will have to meet the rigid test of their ozone depleting potential (ODP) and global warming potential (GWP) under EPA's Significant New Alternatives Policy (SNAP) program.

Under the EPA's current timetable, chlorofluorocarbons (CFCs), halons, carbon tetrachloride, and methyl chloride will be phased out by the year 2000 and methyl chloroform by 2002-unless these dates are advanced by more dire reports on the rate of ozone depletion. All, at one time or another, have been important to metalworking and machining processes.

Airborne contaminants are very much a part of machine-tool operation and accompanying processes and can be generated as gases, vapors, fumes, and dusts, according to Gary M Hutter PhD, president of Triodyne Environmental Engineering Inc, Niles, IL:

From machine tools, they include oil mists, coolant mists, metal particles (e.g. tungsten carbide, cobalt, beryllium, lead, chromium, cadmium, tin, vanadium, nickel), fibers such as fiberglass and asbestos, and bioaerosols;

From accompanying operations, they include carbon monoxide, carbon dioxide, hydrocarbons, nitrogen oxides, volatile organic chemicals (VOC) such as trichloroethylene and toluene, welding fumes, and respirable dust.

Conditions can be dramatically altered, says Dr Hutter, by changes in the formulation of fluids and coolants by manufacturers, by the mechanical action of machines on oil-creating mists, and even by making buildings more air-tight, thus altering the amount of dilution of air contaminants. Simply adding machine tools-each with its own exhaust hood- to an existing air-handling system without increasing its air-handling capacity may drop exhausting efficiency below needed levels.

The greatest impact, however, could be felt if the exhaust levels of a plant-for hydrocarbons, for examplereaches the threshold level. Once subject to compliance guidelines, the cost of compliance can be substantial as emissions must be reduced by 90%, not just enough to come in under the threshold levels.

Materials management

The key to compliance often will be controlling processes or changing materials used in the processes. Here are two examples of how:

At Pfauter-Maag Cutting Tools, Loves Park, IL, environmental considerations continue to impact fume-producing salt baths used to control the rate of cooling in hardening gear hobs and milling cutters. "There is the possibility that salt baths for which there is no acceptable commercial alternative today will be eliminated in the future," says James Hursh, vice president-manufacturing. Similarly, no acceptable substitute exists for Freon, which is used as a highly efficient cleaning solvent and is slated for phase-out in the mid-1990s, Mr Hursh says. Using Freon carries with it a substantial cost because about $900 of the $1400 per barrel cost is for disposal.

An agreement by Dow Chemical to promote new ultra-low-emission solvent cleaning equipment in the US underscores the importance of changing equipment, as well as materials. Designed to tougher European standards, the closed-top vapor degreasing equipment from Durr Industries is said to reduce solvent emissions by up to 99% when using chlorinated solvents such as methyl chloroform, trichloroethylene, perchloroethylene, and methylene chloride. Two of the units handle small parts in baskets; the third can handle parts up to 14 ft long weighing up to 3300 lb.

Fluid management

Metalworking managers have to take a global view of their usage of metalworking fluids, says William H Vickers, manager of metalworking marketing, EF Houghton & Co, Valley Forge, PA. Selection of fluids cannot be made without considering all aspects of use, including the potential liabilities to operator health and safety and the environment, Mr Vickers says. His company, for example, doesn't use any "high liability" materials in its own manufacturing processes.

A little attention to the potential of pollutants can avoid problems in treatment. There are two general types of pollutants-physical and chemical- encountered in fluids used for such diverse metalworking operations as cutting, grinding, quenching, forming, rolling, cleaning metal, and preventing rust, says Mr Vickers.

Physical pollutants include temperature, color, suspended solids, and turbidity. Chemical qualities of greatest concern include fat, oil, and grease (FOG); pH; toxic substances; priority pollutants; chemical and biochemical oxygen demands; heavy metals; and radioactive materials.

His guidelines for fluid management:

* Keep the fluid where it belongs and eliminate equipment seal leaks;

* Avoid disposal of fluids and adhere to a prescribed maintenance program-solution life can be extended by keeping sumps clean and free of bacteria;

* Reclaim the fluid's oil content which can be reused, sold, or added to heavier fuel oil to generate heat or power;

* Use biodegradable water-soluble products that do not contain priority pollutants;

* Check with the fluid supplier to determine whether it has a waste treatment or technical service group that can assist in solving fluid-disposal problems;

Ensure that supplier's products have evaluated Chemical Oxygen Demand (COD) and Biological Oxygen Demand (BOD) values-important in determining their impact on water and wastewater systems.

TQM needed

"The approach that is needed is a far cry from the old practice of delivering a drum of coolant, lubricant, drawing fluid or metal-cleaning compound, and walking away, leaving the customer to cope with monitoring the performance, life, inventory, and disposal of the fluid," says Alan Jarrard, business manager-metalworking, Oakite Products Inc, Berkeley Hts, NJ.

The rising prices of fluids, soaring costs of disposal of spent fluids, and the higher costs of the labor for cleaning fluid systems have put a premium on increasing service life of fluids, Mr Jarrard says. Also, customers are more quality conscious and worker environments are under more intense scrutiny by the EPA and OSHA.

Mr Jarrard believes that what is needed is the application of total quality management (TQM) and SPC techniques in the management of fluids. Oakite's surveys of metalworking operations have revealed that each type has its own set of problems:

In metal stamping and drawing, the primary concerns are production, die life, cost effectiveness, cleanability of parts, and disposal of spent fluids. In grinding and machining, the chief considerations are production costs and the emphasis on environmental concerns. Machine downtime because of short tool life, parts finish problems, frequent sump cleanout, operator discontent, and high volumes of effluents are the most costly elements.

Mr Jarrard recommends a team concept approach to fluids management. For an engine maker, a typical program assigned a specialist to each area: machine tools, coolants and lubricants, cleaners and coatings, laboratory analysis, metering equipment, traffic management for inventory control, and disposal management.

Other considerations

While a final decision is awaited from EPA on the status of oil, i.e. is it a hazardous waste or not, or only when mixed with hazardous materials, synthetic coolants continue to make headway. According to Robert Rauth, president of Pillsbury Chemical & Oil Div, Novamax Technologies (US) Inc, Detroit, synthetics eliminate the use of sulfur and chlorine and alleviate environmental impact/discharge concerns as well as potential operator health and safety problems.

Although coolant manufacturers are working hard to eliminate all use of chlorine (two types have been identified as potential carcinogens), it will be some time before these additives are completely replaced. Similarly, coolant producers are looking for replacements for sulfur which generates unpleasant odors.

Mr Rauth contends that synthetic fluids contain no toxic or hazardous substances and no irritants, offer 90% biodegradability, and can be easily broken down in conventional plant waste treatment systems. Because they last much longer (due to rejection of tramp oil), there is much less waste fluid to dispose of.

Changes that are coming to metalworking may be coming a little slower than other industries, however. The phase-out of CFC-113 and methyl chloroform for use as cleaning solvents is still challenging the industry to find alternatives.

"While the electronics industry has been able to move quickly to alternative cleaning products or processes, changes in metal cleaning products or processes may take longer," says Steve Risotto, executive director of the Center for Emissions Control, Washington, DC. "It's not that alternatives are not available, but the cleaning applications for these two solvents are so many and varied that alternatives almost have to be evaluated on a case-by-case basis."

The Center is developing a control option document for solvent cleaning emission control.

To stay on top of environmental regulations, Randy Junkins suggests that metalworking companies work closely with their trade associations, get their trade associations involved in environmental matters, if they aren't already, and have a preliminary environmental audit done of their plant operations.

Hazard communication checklist

Rate your hazard communications program required under OSHA's Right-to-Know rules by this checklist from NTMA:
DO YOUR EMPLOYEES:
 - understand labels and other warnings used?
 - know how to read MSDS?
 - know where the MSDS are kept?
 - understand your hazard communication plan?
 - know how to recognize hazards and protect against them?
 DO YOU:
 - have a hazard communication program in writing?
 - keep MSDS on file and readily accessible to employees?
 - contact suppliers when MSDS are missing?
 - use labels and others warnings?
 - have a procedure to review and update labels and other warnings?
 - have your labeling and other warning methods
 described in your hazard communication plan?
 - have a training plan for hazard communication?
 - have the training plan described in your written hazard
 communication program?
 - have a list of hazardous chemicals used in your plant?
 - have a provision to inform outside contractor employees
 in your plant of hazards?
 Source: NTMA
 ENVIRONMENTAL REGULATIONS
 * RCRA-Hazardous Waste
 * OSHA-Hazard Communication Standard
 * SARA Title III-Hazardous Chemicals
 * UST-Underground Storage Tanks
 * Clean Water Act-Wastewater
 * Clean Air Act-Air Pollution
 * OSHA In-Plant Air Quality Standards
 * OSHA Lockout/Tagout
 * Stormwater Discharge Regulations
 * SPCC-Spill Prevention Control & Countermeasure Plan
 * OSHA Confined Space Entry
 * OSHA HAZWOPER Regulations
 * OSHA Lab Safety Plan
 * OSHA Respirator Maintenance Program
 Source: Junkins Engineering, Morgantown, PA.


ENVIRONMENTAL PRODUCTS:

Wastewater analysis kits allow field measurement of chlorinated hydrocarbons, i.e. perchloroethylene (tetrachloroethylene), trichloroethylene, and 1,1,1-trichloroethane (methyl chloroform) using direct reading, length of stain detector tubes. Sensidyne Inc, Clearwater, FL, circle 312.

Solvo Clean 60-EWT is a concentrated-liquid, alkaline cleaner that removes heavy, high-viscosity oils, greases, carbonaceous soils, shop grit, and other tenacious soil contaminants from production-line equipment and floors in auto and truck plants. Quaker Chemical, Conshohocken, PA, circle 310.

Clean Machine[TM] removes solids, heavy metals, emulsified oils, and similar wastes from industrial process wastewater rendering it "guaranteed legally sewerable" using a chemical flocculation process. Midbrook Industries, Rochester Hills, MI, circle 307.

Ultrafiltration system, the UF 250 T, provides waste minimization membrane technology to meet the needs of customers who wish to process up to 250 gal of oily wastewater a day without using chemical additives. Sanborn Inc, Wrentham, MA, circle 309.

Cutting fluid brochure details factors affecting selection and includes information on monitoring and controlling parameters of concentration, pH, microbiological growth, tramp oil, and product degradation. EF Houghton, Valley Forge, PA, circle 311.

Gas and liquid sample filters operate at 99.9999% efficiency and protect analyzers from sample impurities which are the most frequent cause of maintenance problems for instruments in an industrial environment. Balston Inc, Haverhill, MA, circle 313.

Oil skimmer removes up to 1 1/2gal of floating oil per hour from the surface of fluids in cleaning system tanks. Advanced Curing Systems Inc, Chicago, IL, circle 317.

ENVIRONMENTAL PRODUCTS:

Portable filtration system is based on flex tube filtration and uses "Diamataceous Earth" as the filtering medium to constantly replenish costly dielectrics, machine-tool coolants, or cutting oils. Solution Engineering Corp, Trumbull, CT, circle 308.

Acro Kut 9050, a new synthetic cutting fluid for use in cutting and grinding steel and cast iron where a fine surface finish is required, is formulated for easy waste treatability using conventional chemical/biological methods as well as 90% biodegradability. Pillsbury Chemical & Oil Div, Detroit, MI, circle 314.

Alternative metal cleaning system called PartsPrep[TM] replaces CFCs, solvents, and vapor degreasing with a system that consists of spray or immersion cleaners, a two-stage rinse cycle and drying stage to remove deposits of carbon, smut, grease, lubricants, drawing and buffing compounds, and epoxy resins from most metals. ISP Management Co Inc, Wayne, NJ, circle 316.

Tramp trap is a patented material that absorbs up to 32 times its weight in tramp oils from synthetic coolants. The trap can be cleaned using any common degreasing agent and reused for three to six months. Pace Technologies, Comstock Park, MI, circle 321.

The Barrett Sludge Extractor recovers up to 85% of the oils or coolants present in wet sludge leaving the user with reusable fluids and easy-to-dispose dry sludge. Available in six models and able to handle loads up to 425 lb. Barrett Centrifugals Inc, Worcester, MA, circle 315.

Brochure describes capability in metalworking fluids, recycling equipment and technology, and TIRIM[R] Brand metalworking products including cutting and grinding fluids, specialty cutting oils, rust preventatives, washing compounds, EDM oils, tapping and honing oils, and stamping and drawing compounds. Master Chemical Corp, Perrysburg, OH, circle 320.

For more information:

The National Tooling & Machining Association has excellent Business Management Aids on Hazardous Waste Management and OSHA's Hazard Communications Rules available. Write NTMA, 9300 Livingston Rd, Ft Washington, MD 20744; FAX: 301-248-7104.

Triodyne has published a useful monograph on Airborne Contaminants in the Machine Tool Industry and a booklet on OSHA's Permissible Exposure Limits for Air Contaminants. Write Triodyne Environmental Engineering Inc, 5950 W Touhy Ave, Niles, IL 606484610; Telecopier: 708-647-2047.

The Center for Emissions Control is publishing a control option document. Write CEC, 1225 19th St, Suite 300, Washington, DC, 20036; FAX: 202-223-5979.

The Independent Lubricant Manufacturers Association has published a 180-page book, titled Waste Minimization and Wastewater Treatment of Metalworking Fluids. Available to non-members for $25.00 plus $4.00 s&h. Write ILMA, 651 S Washington St, Alexandria, VA 22314.
COPYRIGHT 1992 Nelson Publishing
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Title Annotation:includes related article
Author:Lorincz, James A.
Publication:Tooling & Production
Date:Feb 1, 1992
Words:2811
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