E AP Project Summary

United States

Environmental Protection

Agency

Parts Washing Alternatives Study

United States Coast Guard

Brad Montgomery

Risk Reduction

Engineering Laboratory

Cincinnati, OH 45268

Research and Development

This study was conducted to provide

guidance for the United States Coast

Guard (USCG) industrial managers in

choosing cost-effective parts cleaning

chemicals that have minimum environmental and safety impacts. The three

facilities chosen for the study were

Aviation Training Center (ATC), Mobile,

AL; Air Station Cape Cod (ASCC),

Falmouth, MA; and Support Center NY

(SCNY), Governors Island, NY. ATC and

ASCC parts washing applications focused on cleaning contaminated parts

from aviation operations; SCNY parts

washing applications were directed at

cleaning contaminated parts from seafaring vessels. The evaluation of alternative parts cleaners included the

following categories: process description; environmental, safety and health

(ESH) impacts; cost analysis; and material usage and emission reduction opportunities. The following parts cleaners

were evaluated; Penatone 724, Bio

Seven, Safety Kleen 105, and Brulin

815 GD*. All four cleaners are effective

cleaners for the specific applications

described in this evaluation. Penatone

724 is a non-recycled petroleum distillate that has been qualified to military

specification PD 680 type II for a parts

cleaner but possesses potential personnel and environmental concerns.

Bio Seven is an on-site recycled aqueous parts cleaner that has minimal ESH

impacts and is currently being tested

to qualify to military specifications.

Safety Kleen 105 is a full service recycled petroleum solvent that has also

been qualified to military specification

PD 680 type II but has potential longterm hazardous waste liability concerns. Brulin 815 GD is a non-recycled

aqueous alkaline parts cleaner that has

apparent minimal ESH impacts but must

be maintained at a temperature of 140°F

to 160°F for effective cleaning.

This Project Summary was developed

by the U.S. EPA’s Risk Reduction Engineering Laboratory, Cincinnati, OH, to

announce key findings of the research

project that is fully documented in a

separate report of the same title (see

Project Report ordering information at

back).

Introduction

Four parts cleaners were chosen for

the alternatives study. The cleaners were

selected from three different Coast Guard

facilities consisting of two aviation centers, ATC Mobile, AL, and ASCC

Falmouth, MA; and one marine and ground

support facility, SCNY Governors Island,

NY. The different functions of the sites

selected allowed for a broad study of the

alternative parts cleaners.

Aviation cleaning requirements are different from those of a marine and ground

support facility. Because of the complexities of an aircraft, it is necessary to divide

aviation cleaning into three distinct categories. Category one includes tires and

wheels of the aircraft. Category two includes engine components, and category

three is general aviation equipment. A

EPA/600/SR-95/006 February 1995

* Mention of trade names or commercial products does

not constitute endorsement or recommendation for

use.
2

cleaner must be qualified by the USCG

within a specific category for aviation cleaning.

The alternatives in the study include a

full-service recycled cleaner (Safety Kleen

105), an on-site recycled cleaner (Bio

Seven), and two non-recycled cleaners

(Penatone 724 and Brulin 815 GD). These

cleaners were selected because of their

high usage level and different chemical

constituents. Safety Kleen 105 and

Penatone 724 have been qualified by the

USCG to military specification PD 680 type

II for parts cleaning in all three aviation

categories. Bio Seven is used to clean

category two and three aviation parts and

is currently being tested for qualification

to military parts cleaning specifications.

These cleaners are classified by category

and application in Table 1.

The detailed report presents each parts

washing cleaner in a similar format to

provide a consistent approach for evaluating impacts and developing comparison

trends. The format is divided into two main

sections: (1) a discussion and (2)

worksheets. The discussion presents (1)

the step-by-step procedure used in parts

cleaning, (2) environmental impacts or possible health and safety risks associated

with the cleaner, (3) identifiable costs associated with using the cleaner, (4) a material and emission reduction opportunity

assessment, and (5) summarized conclusion of the parts cleaning process. The

worksheets describe the parts cleaning

activity in quantitative terms and are composed of a process description, process

flow diagram, material balance, calculations used to derive numerical data, cost

analysis, and material and emission reduction options for the process.

Labor cost associated with the cleaning

process is not presented in this report.

There were no significant deviations in

the amount of effort expended on the task

above. This procedure can be used for

future evaluations on other parts washing

alternatives.

Discussion of Results

Process Description

The contaminated parts were divided

into two areas: (1) aviation operations and

(2) seafaring vessels. The USCG facilities

ATC and ASCC provided information regarding the cleaning of contaminated parts

from aviation operations. The aviation parts

cleaned were from Dauphin Helicopters

(HH-65), Jayhawk Helicopters (HH-60),

and Falcon Jets (HU-25). SCNY provided

information regarding the cleaning of contaminated parts from seafaring vessels.

The marine parts cleaned were from high

endurance cutters, buoy tenders, bay class

icebreakers, harbor tugs, search and rescue utility boats, and ferry boats. The parts

cleaned were from periodic maintenance

or routine repair operations. The contaminants that were typically removed from

the parts consisted of grease, oil, dirt, and

hydraulic fluid.

The ATC uses a petroleum distillate,

Penatone 724, and an aqueous surfactant, Bio Seven, to clean aviation parts.

Penatone 724 is currently being used in

two separate parts cleaning processes:

(1) an aerosol canister to spot-clean various contaminated parts and (2) the complete immersion and saturation of the

contaminated part with the cleaning solvent in an open container. Approximately

80% of the Penatone 724 is used for the

immersion and saturation procedure with

the remaining 20% used for aerosol cleaning. The parts are typically wiped down

after cleaning with a disposable hand towel

or an absorbent cloth to remove traces of

contaminants and solvent. The cleaned

parts are allowed to air dry.

ATC has three separate parts cleaning

stations using the cleaner Bio Seven. Each

station contains a polyethylene parts washing tank that is designed to hold approximately 36 gal of cleaning solution, which

is a 50/50 mixture of Bio Seven and potable water. The cleaning solution is heated

in the holding tank to the temperature

range of 96°F to 104°F and is continuously recirculated as parts are being

washed. The contaminants are removed

from the parts by manual brushing. The

contaminants are washed away with the

cleaning solution into the enclosed section of the tank. The parts cleaning process is followed by a water rinse to remove

any residual cleaner and contaminants

from the parts. The parts are then wiped

dry.

Table 1. Parts Washing Cleaners

Chemical Category Application

Safety Kleen 105 Full Service Recycle: Aviation:

Petroleum Distillates Categories one, two, and

three

Penatone 724 Non-Recycle: Aviation:

Petroleum Distillates Categories one, two, and

three

Bio Seven On-Site Recycled: Aviation:

Aqueous - Mild Categories two and three

Brulin 815 GD Non-Recycle: Marine and Ground Support:

Aqueous - Alkaline No restrictions

of cleaning the parts, therefore labor would

not be a deciding factor for the selection

of an alternative cleaner in this study.

A comparison of total costs among the

cleaners should be avoided. The total cost

for a specific cleaner will vary depending

on the materials and surface area of the

contaminated parts being cleaned, geographical location, and facility preferences.

Procedure

The following is a condensed version of

the categories evaluated for the selected

USCG parts washing alternatives:

Process Description

Process location, summary of the

operations performed, equipment,

process controls, and a material

balance to include products, input

materials, and the waste streams

affected.

ESH Impacts

Associated regulatory requirements

and impacts of using the cleaner at

the facility.

Cost Analysis

Divided into the following sections:

(1) material and equipment acquisition, (2) inputs and outputs such

as utilities and effluents, and (3) ESH

cost-related impacts.

Material and Emission Reduction

Opportunities

Identify opportunities that offer real

potential to minimize waste and

reduce costs. A detailed evaluation of

technical and economic feasibility is

labor intensive, therefore the proposed

opportunities should be screened to

identify high priority opportunities.

Conclusion

Decisions on improvement options

should be based on the conclusions

developed in the evaluation.

The detailed report contains an outline

with worksheets for each category listed
3

The ASCC has three parts washing stations located in the aircraft maintenance

hanger that use Safety Kleen 105. Each

parts washing station has approximately

30 gal of the cleaning solvent in a holding

tank located below the parts washing basin. The cleaning solvent is pumped from

the holding tank, through a discharge tube,

onto the part, and drains back into the

holding tank. The technician removes the

contaminants by holding the part under

the discharge tube and scrubbing or rubbing the part with a brush or gloved hand.

The contaminants drain into the holding

tank along with the cleaning solution. The

parts do not require any rinsing or further

use of different chemicals to complete the

cleaning process. The parts are typically

wiped down with a disposable hand towel

or an absorbent cloth to remove traces of

contaminants and solvent and then allowed to air dry.

Brulin 815 GD is currently being used in

the industrial motor repair shop at SCNY.

The parts cleaning solution is a mixture of

20-50% Brulin 815 GD in potable water

and is contained in an insulated 1,200 gal

capacity tank. The percentage of Brulin

815 GD in the potable water is important

in that the higher the concentration the

better removal efficiency of heavy contaminants (grease, high viscosity oil). The

cleaning solution is maintained at a temperature of 140°F to 160°F. The contaminated parts to be cleaned are placed in a

metallic basket and then lowered into the

tank by a mechanical hoist. The cleaning

solution is not agitated in the tank and

there is no manual brushing of the contaminated parts to stimulate the removal

of the contaminants. The contaminated

parts soak in the cleaning solution for

periods of 4 to 12 hours. The parts cleaning processes is followed by a steam rinsing to remove any residual cleaner and

contaminants from the parts. The cleaned

parts are then hand wiped to quicken the

drying time.

ESH Impacts

Penatone 724 is composed of aliphatic

hydrocarbons (classified as 100% volatile

organic compounds) and is a combustible

material. Safety Kleen 105 is also a combustible material that contains petroleum

distillates and trace quantities of perchloroethylene and 1,1,1-trichloroethane. The

volatility of the two cleaning solvents requires personal protective equipment

(gloves, glasses, etc.). Hand towels that

contain residual Penatone 724 or Safety

Kleen 105 are not considered hazardous

waste in the state of Alabama or Massachusetts. The used towels should be put

into a proper waste disposal container with

the lid tightly covered. Penatone 724 and

Safety Kleen 105 vapors are heavier than

air. Local fire codes may also restrict use

of these cleaners. There are a multitude

of potential health hazards associated with

the use of the two cleaning solvents. Eye

contact with liquid or exposure to vapors

may cause mild to moderate irritation. Skin

contact may cause redness, dryness,

cracking, burning, or dermatitis. Inhalation

or ingestion may cause central nervous

system effects and cause nausea, vomiting, and in severe cases, death.

Bio Seven is a clear, free-flowing surfactant that contains no listed hazardous

ingredients. Brulin 815 GD is a blue-green

blend of detergents, alkaline builders and

inhibitors that contains no phosphates and

has no listed hazardous ingredients. Both

Bio Seven and Brulin 815 GD are soluble

in water, biodegradable, nonflammable,

and will not support combustion. Bio Seven

and Brulin 815 GD are considered to have

minimal health hazards associated with

their usage.

Cost Analysis

The annual cost of each cleaner (Table

2) was based on information provided by

the USCG facility and was geographically

dependent. Costs were divided into three

separate sections: (1) material acquisition,

(2) inputs and outputs, and (3) ESH impacts. Material and equipment acquisition

includes initial start-up costs and annual

costs. The input and output costs included

items that were identified through a material balance on each of the parts cleaning

processes (e.g., energy, water, hand wipe

towels, hazardous waste disposal). Certain input and output items did not have

any identified cost for this evaluation.

Material and Emission

Reduction Opportunities

Penatone 724 contains volatile organic

compounds (VOCs) at a concentration

level of 780 g/L of solution. Because of

the volatility of the cleaning compound,

much of the solution is lost through evaporation. VOCs are not an issue with the

ATC since the state of Alabama does not

currently restrict the amount of VOCs allowed to be dissipated into the environment from this type of parts cleaning

process. Other locations may have regulations to reduce VOC emissions such as

(1) best available control technology requirements or (2) a usage permit with

fees based on the amount of releases into

the atmosphere. An alternative to the current immersion cleaning procedure used

at ATC would be to use an enclosed parts

cleaning station for the cleaning solvent.

The station would be designed for the

containment of the solvent with a cover to

reduce losses through evaporation. The

parts cleaning station could extend the

usage life of the cleaning solvent and significantly reduce environmental releases.

The annual loss of the Bio Seven cleaning solution is about 25%, primarily due to

“drag-out” and evaporation. Drag-out is

the liquid residual on the part after it has

been removed from the cleaning station.

The water and cleaning solution from the

rinsing process could be captured and

utilized as makeup for the losses incurred

by drag out and evaporation.

Safety Kleen 105 and Penatone 724

have environmental and heath risks associated with their usage. Efforts should be

taken to find a viable cleaner that would

reduce these risks for the parts cleaning

operations. Potential candidates to replace

the petroleum distillates could be Bio

Seven and Brulin 815 GD.

A material reduction opportunity for the

Brulin 815 GD parts cleaning process

would be to establish a continuous filtration system to separate the contaminants

from the cleaning solution. Approximately

575 lb (64 gal) of Brulin 815 GD is used

as makeup for the losses incurred through

the removal of the sludge from the parts

washing tank. This is about 47% of the

total annual usage of the Brulin 815 GD

parts cleaner. A cost savings of $600

would result from the elimination of Brulin

815 GD in the sludge. The total weight for

the sludge could be reduced by 75% with

the separation of the cleaner from the

contaminants. This reduction would have

a cost savings of $458 annually. The

“mucking” out the tank and removal of the

sludge would be reduced to every 3 yr.

The total savings associated with the use

of a continuous filtration unit, including

any water losses, would be almost $1,100

annually.

Conclusions

Penatone 724 is qualified to military

specification PD 680 type II as a parts

cleaner. Penatone 724 can clean in all

three aviation parts cleaning categories

(engine components, general aviation

equipment, and tires and wheels). Concerns about using the cleaning solvent

focus on the potential ESH impacts.

The ATC is presently using Bio Seven

as a test solution for cleaning engine components and general aviation parts. Bio

Seven is designated as a test solution

because at the time of this report it does

not have a military specification. Plans
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Table 2. Regulatory and Cost Factors

Penatone 724 Bio Seven Safety Kleen 105 Brulin 815 GD

Regulatory Requirements

 OSHA Combustible None Combustible None

 RCRA Hazardous Waste None Hazardous Waste None

 TSCA Listed Ingredients None Listed Ingredients None

 SARA, Title III

 section 311,312 Listed Ingredients None Listed Ingredients None

Cost

 Material & Equipment Acquisition

 Start-Up $1,945 $3,363 1 $4,000 $3,410

 Annual Contract Fee None $1,440 $4,000 2 None

 Annual Operating $555 $225 None $2,093

 Inputs and Outputs

 Energy None $198 None $6,887

 Water Usage None $100 None $216

 Atmospheric Emissions 3 None None None None

 Liquid Effluent ($3) 4 None None None

 Solid Waste $1,200 $400 $400 $709

 Environmental, Safety & Health

 Personal Protective Equipment $268 $160 $340 $96

Total Start-UP Cost $1,945 $3,363 $4,000 $3,410

Total Annual Operating Cost $2,020 $2,523 $4,740 $10,001

Annual Contaminated Parts 1,000 300 2,000 60,000

Cleaned (pounds) 5

1 Includes three cleaning stations.

2 Contract cost for five cleaning stations.

3 here was no identifiable cost for the atmospheric emissions.

4 ATC Mobile, AL, sells the waste solvent at $0.03/gal to an Energy Recovery Company.

5 Due to the differences in materials and surface area of the contaminated parts being cleaned by the USCG facilities, the annual weight should not be used

as a comparison between facilities. It is presented in this chart to provide an approximation of cost/lb of contaminated parts within a specific facility.

are in progress to classify the cleaner as

a Navy soap. This classification would

qualify the cleaner to the Mil-C-85570,

type II specification when approval has

been granted. One concern with the use

of Bio Seven is the potential to cause

hydrogen embrittlement. Hydrogen

embrittlement is the degradation of high

strength steels, such as aluminum and

magnesium, that are used as bearings

and bolts on aircraft wheels. Bio Seven is

a viable cleaner for aviation parts cleaning categories two and three (engine components and general aviation equipment)

but should not be used to clean category

one (tires and wheels) aviation parts until

its potential to cause hydrogen

embrittlement has been determined.

Safety Kleen 105 is also qualified to

clean all three aviation categories (engine

components, general aviation equipment,

and tires and wheels). Potential long-term

liability risks for the Coast Guard are increased with continued use of this parts

cleaner. If Safety Kleen Corporation uses

poor practices in the recycling process,

the USCG could be responsible for paying any cost incurred to remediate the

resulting environmental contamination.

Safety Kleen Corporation completes the

hazardous waste manifests, but the USCG

is on record for the purchase and generation of the solvent waste.

The industrial motor repair shop at

SCNY has cleaned over 60,000 lb of contaminated parts with the Brulin 815 GD

solution. The cleaner has proven to be

effective at removing contaminants from

the various ship parts located on the island. Important factors in using the Brulin

815 GD as a parts cleaner are the solution temperature, concentration, and soaking time. Operational experience indicates

that for the Brulin 815 GD to be an effective parts cleaner at SCNY, the temperature must be at least 140°F with the

concentration of Brulin greater than 20%

and a soaking time of at least 4 hr if there

is no agitation. Brulin 815 GD is considered to be a relatively benign solution and

requires minimal environmental monitoring. The cleaning solution possesses no

significant ESH concerns. Efforts should

be taken to ensure that the discharge of

the cleaner into the sewer system does

not require any pretreatment by local water treatment facilities.

The full report was submitted in fulfillment of Contract No. 68-C4-0020, Work

Assignment 0-03, by Lockheed Environmental Systems and Technologies, under

the sponsorship of the U.S. Environmental Protection Agency.
5

Brad Montgomery is with Lockheed Environmental Systems and Technologies,

Las Vegas, NV 89119.

James Bridges is the EPA Project Officer (see below).

The complete report, entitled “Parts Washing Alternatives Study United States

Coast Guard,” (Order No. PB95-166146; Cost: $19.50, subject to change)

will be available only from

National Technical Information Service

5285 Port Royal Road

Springfield, VA 22161

Telephone: 703-487-4650

The EPA Project Officer can be contacted at

Risk Reduction Engineering Laboratory

U.S. Environmental Protection Agency

Cincinnati, OH 45268

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EPA/600/SR-95/006