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:
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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 SUMMARY
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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: 300

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.
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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.