file:///J|/INITENG/P12%20cases/p120560.eng.txt[11/7/2012 2:47:36 PM] INITIAL REVIEW ENGINEERING REPORT PMN: 12-0560 Focus Ready Draft 10/11/2012

ENGINEER: Prothero \ AG PV (kg/yr): 438,000 YX

SUBMITTER: Honda of America Mfg., Inc.

USE: Feedstock to provide mineral content for cement manufacturing. Analog is used as a feedstock replacement in cement kiln production.

OTHER USES: No other uses were found.

MSDS: No Label: No

TLV/PEL:

CRSS : Chemical Name: Slimes and Sludges, aluminum and iron casting, wastewater treatment, solid waste Definition: The waste solids produced from the treatment of wastewaters during aluminum and iron casting, machining and finishing operations. It may contain aluminum, barium S-H20: 0.001 g/L @ VP: 1.0E-6 torr @ MW: 27.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Solid Mfg: Solid: 50% solids with water in wet cake Proc/Form: Solid: 0.02% PMN material End Use: Destroyed. The PMN material is precipitated from wastewater with metal precipitant polymers and anionic polymers, and is expected to be complexed or chelated with them. The polymers are not considered to be part of the PMN material. The structure shown on page 1 of this report does not include the anions because they are not part of the PMN material. The molecular weight shown above is calculated for Al, the lowest atomic weight component. Submitted Properties: None. Estimated Properties: VP < 0.000001 torr (Salt); WS < 0.001 g/L (Precipitated from water). While the metal ions by themselves are very water soluble, they are expected to be bound to polymers, and the resulting complexes are not soluble.

Consumer Use: No

SAT (concerns) (10/02/2012): Related Cases and Related Cases and Misc SAT Info:file:///J|/INITENG/P12%20cases/p120560.eng.txt[11/7/2012 2:47:36 PM] Ecotox Related Cases: Analog: Migration to groundwater: Slow PBT rating: P3B1T2 . Health: 1-2 Drinking Water, Inhalation Eco: 1 No releases to Water

OCCUPATIONAL EXPOSURE RATING: 0-1

NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER. A same-submitter, similar-use case was found and used for assumptions (transport container info and cleaning): (cement kiln feedstock). The past case IRER has no notable inconsistencies with key assumptions in this IRER.

POLLUTION PREVENTION CONSIDERATIONS: P2 Claim: Landfill avoidance. The metal constituents in the engine wastewater treatment sludge act as a replacement for metal content in raw material feedstock.

EXPOSURE-BASED REVIEW: Yes (0 criteria met)

1) # of workers exposed: 0 >1000? No 2) >100 workers with >10 mg/day inhalation exposure: No 3) (a) >100 workers w/1-10 mg/day inh. exp. & >100 days/yr: No (b) Routine Dermal Cont: >250 workers & >100 days/yr: No

INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 12-0560

Manufacturing: Sludge from Treating Wastewaters Produced from Al/Fe Casting/Machining/Finishing

Number of Sites/ Location: 1 Honda of America Mfg., Inc. - Anna Engine Plant Anna OH 45302 Days/yr: 313 Basis: Per submission, PV of 438,000 kg/yr, 1 MFG site, 313 bt/yr, and 1400 kg/bt. CEB assesses 313 bt/yr and ChemSTEER calculates 1399 kg/bt. PMN is 50% solids in wet cake.

Process Description: Wastewater from Aluminum and Ferrous Parts Manufacture --> Collection Sump --> Batch Treatment Tanks --> Gravity Settler (PMN formed; 50% solids in wet cake) --> Sludge Tank --> Filter Press (dewatering) --> Engine Wastewater Treatment Sludge (PMN; 50% solids in wet cake) -> 15-ton boxes (assume same as P-12-501) (per submission)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARYfile:///J|/INITENG/P12%20cases/p120560.eng.txt [11/7/2012 2:47:36 PM] Water, Land, Incineration - not expected after wet cake formation; Air - negl (low VP NCS in wet cake)

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:

Inhalation: negligible (VP < 0.001 torr); Wet cake (50% solids) is not expected to generate dust.

Dermal: Dermal not required per SAT.

INITIAL REVIEW ENGINEERING REPORT CBI: Yes PMN: 12-0560

Use: Mineral Feedstock for Cement Manufacturing

Number of Sites/ Location: 1 Unknown Site Greencastle IN Days/yr: 30 0 Basis: Per submission, 1 USE site, 300 exposure days/yr. CEB assesses 300 operating days/yr and ChemSTEER calculates 1460 kg/bt PMN.

Process Description: Unload 15-ton boxes (PMN; 50% solids in wet cake) --> Wastewater Treatment Sludge Storage --> Processing Raw Materials/Raw Material Loading --> Processing Raw Materials/Primary and Secondary Crushing/Screening (0.02% PMN) --> Raw Material Preparation (Proportioning and Grinding) --> Slurry Mixing and Blending --> Rotary Kiln (PMN destroyed) (per submission and CRSS)

ENVIRONMENTAL RELEASES ESTIMATE SUMMARY IRER Note: The daily releases listed for any source below may coincide with daily releases from the other sources to the same medium. 15-ton boxes dedicated and not normally cleaned (assume same as P-12-501). Water - not expected for this site.file:///J|/INITENG/P12%20cases/p120560.eng.txt [11/7/2012 2:47:36 PM] Air Subm est: 5.3E-2 kg/site-day over 300 days/yr from 1 site to: air (<1% per subm) and uncertain (> 99% capture in baghouse, waste disposal not specified, assume land) from: Emissions from process basis: User-Defined Loss Rate Model. Subm est < 0.4% loss to baghouse.

Incineration Typical: 1.5E+3 kg/site-day over 300 days/yr from 1 site or 4.4E+5 kg/yr to: Incineration in a Cement Kiln (submission) from: Cement Kiln basis: User-Defined Loss Rate Model. 100% of PMN used as feedstock for a cement kiln (incineration), with 0.4% lost in emissions = 0.996 to kiln.

Landfill Subm est: 5.2E+0 kg/site-day over 300 days/yr from 1 site or 1.6E+3 kg/yr to: air (<1% per subm) and uncertain (> 99% capture in baghouse, waste disposal not specified, assume land) from: Emissions from process basis: User-Defined Loss Rate Model. Subm est < 0.4% loss to baghouse.

RELEASE TOTAL 4.4E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 0 Basis:

Inhalation: negligible (VP < 0.001 torr); Wet cake (50% solids) is not expected to generate dust.

Dermal: Dermal not required per SAT.