Parts Cleaning Systems

There are many different types of parts cleaning systems. Some utilize a pump to circulate cleaning solvent/solutions that clean parts. These machines can be managed by the facility or contracted to a service that maintains the system and hauls away any generated waste. The type of system and the solvent/solution (organic based, aqueous, citrus based, etc.) used in the system will determine regulatory management requirements and P2 opportunities. Some systems have a distiller to clean the solvent and a reservoir tank to hold the waste that is "cooked" out, while others utilize filters to extract impurities. Protecting the integrity of the cleaning solvent/solution in order to extend its life and reduce disposal quantities is P2. For example, by managing your own system that utilizes filters, you can change the filters based on the system's use before they reach a regulated threshold and not because of a pre-set contracted service. Also, there are aqueous, semi-aqueous, and citrus-based systems that offer unique opportunities for P2. With any of these types of systems, it is important not to introduce any non-compatible solvents/solutions into them that would cause them to become regulated hazardous waste.

Some factors of a filtered system to look for:

• Utilizes non-chlorinated solvents in the system.
• High flash point solvent of 143 degrees or higher.
• Can meet all regulatory requirements regarding disposal of filters.>143
• Closing the lid when the system is not being used to reduce evaporation.
• OSHA safety requirements for use are minimal.

Some factors for aqueous solution systems:

• The system cleans to the standard required for the part to function properly.
• There will be minimal regulatory restrictions if disposal of the solution is required.
• A balance can be maintained for the bioremediation in the system to work properly.

Key Tips:
Maintain the solution/solvent integrity to extend its life and increase frequency of filter replacement to reduce disposal costs of solvent/solution. Let the part sit in the wash basin and drip dry to reduce solvent "drag out" loss. Choosing aqueous systems may reduce regulatory requirements all together.

Pressurized/Aerosol Cleaners

Never use chlorinated solvents/solutions in any application to clean parts. Avoid using any aerosol cleaning products that are not RCRA approved. The use of these types of solvents/solutions can cross contaminate fluids and make them regulated under RCRA and increase OSHA requirements. Solvent/solutions purchased in bulk and applied with self-pressurizing applicators will reduce the use of the product and waste containers. Pre-cleaning with a putty knife and wire brush and utilizing recyclable shop rags will also reduce disposal cost and excess use of solvents/solutions. Verify compatibility of the solvent/solution with the parts washer's solvent/solution. Aqueous solutions may be the best option when utilized properly. There are pre-cleaning solvents/solutions that can affect the parts washing tank if, after use, further cleaning of a part is required in that system. Eliminate overuse and set standards on the amount of cleaning required for the particular part to function properly.

Some factors to look for in a self-pressurizing system:

• Use non-chlorinated solvents.
• Choose a solvent/solution compatible with the parts washer.
• Verify solvent/solution content with RCRA/OSHA regulations.
• Does the manufacturer/supplier offer system product support and/or training?

Key Tips:
Utilizing a scraping device and/or wire brush, recyclable shop towels, and a non-regulated RCRA solvent/solution will reduce usage and hazardous waste regulatory requirements. Low VOCs and the reduction of potentially toxic vapors will be less harmful to the employee.

Anti-freeze/Coolant

Using manufactured specified anti-freeze/coolant is required to maintain warranties and extend the life of the vehicle/equipment. There are some ways to recycle anti-freeze/coolant to manufacture specifications and reuse on-site. Verify the vehicle/equipment warranty will be honored if this re-used anti-freeze/coolant is utilized. One method to recondition used anti-freeze/coolant is to utilize a mobile service to perform on-site recycling at your facility. Verify that the service is licensed and has a neutral third party laboratory's test results to prove the system works and they guarantee the system's product. Another approach is to purchase your own on-site recycling machine. This allows you to fully manage the systems use and the quality of the product it produces. Either one of these will reduce new product purchases, RCRA disposal costs, and insure a readily available product.

Some factors to look for in choosing the best method for the facility:

• Verify warranty coverage of the vehicle/equipment for the system/service chosen.
• Verify disposal approval for filters generated from recycling system.
• See if bulk containers for used/recycled anti-freeze are available and proper storage can be achieved.

Key Tip:
Whatever method is chosen, make sure testing and warranties of the system's product is backed and the manufacturer of the vehicle/equipment allows for the use of the reconditioned anti-freeze/coolant.

Shop Rags

Do not use disposable shop rags. Contract with a service to provide reusable rags for the facility as needed. Provide mechanics with a certain amount to perform the job. Require them to bring back and exchange used rags for new rags. Verify the service provider has an approved method and facility for recycling the rags. The only exception to utilizing a service is if the facility's non-regulated waste is disposed at a Waste-to-Energy plant that can incinerate waste rags. Remember to never use chlorinated solvents regardless of the recycling/disposal method.

Some factors to look for in selecting a service:

• A regulatory approved method for the facility where the rags will be recycled.
• Will set a pick-up schedule for the used rags as required by your facility.
• Offers different rag selection based on the use for the facility.

Key Tip:
Use as few rags as possible and always utilize a service to recycle them at an approved facility.

Air Conditioning

There are several manufacturers that have different machines that will recover freon from a system for off-site recycling. Other machines recover and recycle the freon and then place the recycled freon back into the repaired unit. These types of machines reduce new freon purchases and disposal cost associated with the management requirements of the waste stream. If repair of this type of equipment is performed off-site, verify their practice for handling generated waste.

Some factors to look for in selecting a machine:

• It is regulatory approved and registered.
• Backed by third party test results verifying efficiency.
• Has factory warranty and supplier training.

Lubricating Oils

There are several types of lubricating oils in the various types of vehicles/equipment in use today. Changing these oils should be performed as determined by the use and not specific timed dates. If the vehicle/equipment is underutilized and/or is only needed for a specific task, changing the oils by a timed date is a waste of resources. Synthetic oils generally have a longer span of time for use before a change is required. When choosing the correct lubricant, verify warranty approval and track the miles/hours of use of the product in the vehicle/equipment. Check various options of disposal to see if refining of the waste oils is available over fuel blending for incineration. Keep non-compatible oils separate from one another to reduce possible cross contamination and increased disposal cost.

Metal Recycling

Most parts replaced are made of metal. Some metal parts must be exchanged for the new part when purchased. However, there are many that can be recycled thereby saving the facility from disposal cost. Lead tire weights, broken engine brackets, nuts and bolts, and body parts are just a few that have value for recycling. Set up places to store the recyclable metal, preferably out of the weather, and contract with a scrap dealer to pick-up what is recycled at the facility on an as needed basis. Some scrap dealers will supply the container to the facility for the storage of the metal to be recycled. The scrap dealer may require separation of the different metal types.

Conclusion

Pollution prevention (P2) will have a positive effect on procedures/processes and regulated waste generated at the facility when the P2 concept is initiated. When product use is reduced and/or eliminated, the reduction of manufacturing, transporting, and handling are all affected. This allows the need for energy and raw material reductions to occur. Although the facility may not benefit entirely from this occurrence, the entire scope of pollution prevention for the industry does. Changing procedures and incorporating new technology to reduce or eliminate waste is true pollution prevention and must be encouraged from top management to every employee. The major key to incorporate a successful P2 plan is to utilize current funds and available resources to implement the changes required in the plan. Inventory control, product research, operational procedures, and regulatory compliance requirements all must be evaluated before implementation occurs. Evaluate and document current product uses and procedures to verify the extent of the P2 plan's success at the facility.

Success Story

The purpose of this case study was to evaluate and eliminate violations and the potential to violate the Resource Conservation and Recovery Act (RCRA) at Lee County's Fleet Management Facility, to reduce associated liabilities regarding the Facility's employees' health and safety, to implement and utilize Best Management Practices (BMP's), Pollution Prevention (P2) technologies and Preferable Purchasing Techniques (PPT) where possible and to perform research and institute Recycling Procedural Requirements (RPR) where profitable.

The Fleet Management Facility maintains over 1600 pieces of equipment from lawn mowers to heavy equipment utilized by various departments in Lee County. Several violations of RCRA were discovered in 1992 and Lee County was required by the Board of County Commissioners to fix the situation so violations did not occur again. A corrective plan was the first task, and later another operations plan was written to include Pollution Prevention (P2), Best Management Practices (BMP's), and Reduce, Reuse, and Recycle (R3). The later plan initiated a three-year phased process that covered product substitution and/or elimination, equipment/chemical purchasing requirements, and employee training.

Equipment Specifications/Models Purchased to Promote P2, BMP's and R3:
Parts Washer: Zep Dyna Clean Parts Washing System - A three staged filter system which utilizes Zep Dyna 143ºÔ Cleaner Degreaser. Utilizing this system allowed for the total elimination of hazardous waste that was being generated and then shipped off-site for disposal.

Anti-freeze Recycler: FPPF Gly Clean Anti-freeze Recycling System Model ARS 100. Used to filter impurities from used anti-freeze before chemically balanced to manufacturer specifications. This closed loop approach is the only way to insure compliance is achieved and product integrity. As long as filters are changed appropriately, they do not accumulate regulated heavy metal amounts. Also, performing on-site recycling of the anti-freeze saved money required for new product purchase, testing to determine if it was a hazardous waste and transportation/disposal cost.

Air Conditioning Reclaimed/Recycler: Refrigerant Technology Inc. Model # RRC-751 and RRC770-R134A. Copeland Inc. Model # PC-1. This machine cut the cost of freon purchases by 82%, with zero waste to dispose.

Self-Pressurizing Solvent Sprayer: Zep Model B Pressure Sprayer. Utilize Zep Brake Wash Product Number 0505. In conjunction with recyclable rag service, no regulated hazardous waste. Also, changing to manual pressurizing dispensers eliminated use of chlorinated solvents.

Cost Savings Estimate:
The cost for hazardous waste disposal was reduced 100% for savings of $16,800 per year for an average year's cost. This includes solvent disposal contracts, anti-freeze disposal, and freon disposal. Recycling of fluids such as anti-freeze, used oil, parts cleaning solvent, and freon also reduced the facility's liability and saved in new product purchases. For more information contact Dale Nottingham (see below).

Additional References:

Local, State, and National Vehicle Trade Associations

National Pollution Prevention Roundtable

State Pollution Prevention Roundtables

National Association of Counties

EPA Website