file:///J|/INITENG/P12%20cases/p120501.eng.txt[10/3/2012 9:42:32 AM] INITIAL REVIEW ENGINEERING REPORT PMN: 12-0501 Focus Ready Draft 9/24/2012 ENGINEER: Prothero \ JAS PV (kg/yr): 415,000 YX
SUBMITTER: Honda of America Mfg., Inc. USE: Feedstock replacement in cement kiln production. The PMN material is used as a substitute for shale. OTHER USES: No other uses were found. MSDS: No Label: No
TLV/PEL: no information provided.

CRSS : Chemical Name: Slimes and Sludges, automotive coating, wastewater treatment, solid waste Definition: The waste solids produced from the treatment of wastewaters from automotive pretreatment processes, electro-deposition coating processes, surface coating processes and S-H20: 0.001 g/L @ VP: 1.0E-6 torr @ MW: 40.00 %<500 %<1000 Physical State and Misc CRSS Info: Neat: Solid Mfg: Solid: 50% PMN material with water in wet cake Proc/Form: Solid: 0.02% PMN material End Use: Destroyed. The PMN material is precipitated from wastewater with coagulants and polymers, and is expected to be complexed or chelated with them. The coagulants and polymers are not considered to be part of the PMN material. The molecular weight shown above is calculated for MgO, the lowest molecular weight component. Submitted Properties: None. Estimated Properties: VP < 0.000001 torr (Salt); WS < 0.001 g/L (Precipitated from water). While the metal oxides and hydroxides by themselves are very water soluble, they are expected to be bound to coagulants and polymers, and the resulting complexes are not soluble.
Consumer Use: No SAT (concerns) (09/18/2012): Related Cases and Related Cases and Misc SAT Info: Ecotox Related Cases: None // Human Health Related Cases:file:///J|/INITENG/P12%20cases/p120501.eng.txt[10/3/2012 9:42:32 AM] Migration to groundwater: Slow PBT rating: P3B1T1 . Health: 1-2 Inhalation Eco: 1 No releases to Water
OCCUPATIONAL EXPOSURE RATING: 1B
NOTES & KEY ASSUMPTIONS: Generated by the 06/07/2005 version of ChemSTEER.

POLLUTION PREVENTION CONSIDERATIONS: P2 Claim: Landfill avoidance and reduction in mining of native earthen materials. The metal constituents of the wastewater treatment sludge undergo a chemical reaction with the calcium oxide present in the kiln and act as a replacement for constituents of shale and other native earthen materials. EXPOSURE-BASED REVIEW: Yes (0 criteria met) 1) # of workers exposed: 30 >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 PMN: 12-0501 Manufacturing: Batch Number of Sites/ Location: 1 Honda Manufacturing of Indiana, LLC Greensburg IN 47240 Days/yr: 346 Basis: Submission identifies 1 site and indicates 346 batches/yr, 1,200 kg/batch, 8 hr/batch. Process Description: Wastewater is stored in wastewater sump --> Metals treatment tank --> Water flows to flocculation tank and polymer is added --> Solids settling tank --> Solid bottoms are sent to sludge holding tank --> Filter press --> Wet cake sludge (~50% solids) sent to cement kiln (per submission).
ENVIRONMENTAL RELEASES ESTIMATE SUMMARY CEB did not assess air releases from the PMNs solid because it is in wet cake form, per submssion and technical contact. CEB assumed that 100% of the PMN isfile:///J|/INITENG/P12%20cases/p120501.eng.txt[10/3/2012 9:42:32 AM] sent to the cement kiln and incinerated (consistent with technical contact), because of inhalation exposure concerns. CEB did not address water or landfill releases because triggers were not met: WATER - not required, per SAT // LAND - drinking water exposures not required.

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 18 Basis: The submission estimates up to 18 workers potentially exposed. Inhalation: Inhalation not expected - VP < 0.001 torr and PMN is in wet cake form.

Dermal: Exposure to Solid at 50.00% concentration High End: 1.6E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 18 Basis: Loading Solid Product into Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.
INITIAL REVIEW ENGINEERING REPORT PMN: 12-0501 Use: Feedstock for Cement Kiln Number of Sites/ Location: 1 unknown site Greencastle IN Days/yr: 300 Basis: The submisison identifies 1 use site, and estimates 300 exposure days/yr. The PMN arrives in wet cake with 50% solids. CS calculates 1383.3 kg PMN/day. Process Description: Wastewater treatment sludge (50% solid PMN) unloaded from trucks into bunker --> PMN combined with other raw materials --> Primary and Secondary Crushing --> Screening --> Proportioning and Grinding --> Slurry Mixing and Blending --> Rotary Kiln (PMN is destroyed) (per technical contact and submission).
ENVIRONMENTAL RELEASES ESTIMATE SUMMARY Per the technical contact, the PMN is shipped as wet cake;file:///J|/INITENG/P12%20cases/p120501.eng.txt[10/3/2012 9:42:32 AM] therefore CEB does not assess air releases from solid particulate. CEB assumed that 100% of the PMN is sent to the cement kiln and incinerated (consistent with technical contact), because of inhalation exposure concerns. CEB did not address water or landfill releases because triggers were not met: WATER - not required, per SAT // LAND - drinking water exposures not required. Incineration Output 2: 1.4E+3 kg/site-day over 300 days/yr from 1 site or 4.1E+5 kg/yr to: incineration in cement kiln (submission) from: Cement Kiln basis: User-Defined Loss Rate Model. The PMN is used as a feedstock for a cement kiln (incineration)
RELEASE TOTAL 4.1E+5 kg/yr - all sites

OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Tot. # of workers exposed via assessed routes: 12 Basis: The submission estimates up to 12 workers potentially exposed. Inhalation: Inhalation not expected - VP < 0.001 torr and PMN is in wet cake form.

Dermal: Exposure to Solid at 50.00% concentration High End: 1.6E+3 mg/day over 250 days/yr Number of workers (all sites) with dermal exposure: 12 Basis: Unloading Solid Raw Material from Transport Containers; EPA/OPPT Direct 2-Hand Dermal Contact with Solids Model.

MEMORANDUM of CBI TELEPHONE CONVERSATION
CALL BY:

CALL TO: Organization: Hondafile:///J|/INITENG/P12%20cases/p120501.eng.txt[10/3/2012 9:42:32 AM] Date: 09/19/2012 Time: 9:30 AM

PMN: 12-0501

Q1: What is the transfer method for the PMN? Is it packaged into containers? Are they cleaned? A1: The filter press is on an upper level - after it finishes pressing, it dumps the wet cake into a "roll-off" box (~15 tons) that is covered then trucked to the cement facility. The roll-off boxes are dedicated and not typically cleaned, but can be rinsed with water. //| Q2: Are the sludge tanks at the WWT or cement facility get cleaned? How is the waste disposed?| A2: They are typically not cleaned - 100% of the sludge goes through the system to the cement kiln. // | Q3: How does the feedstock processing at the cement kiln work? Does the sludge become dry during processing? (Is there potential for dust releases?)| A3: The wet cake is added to the dry materials at the front end. It still has about 60% solids and is clay-like, so I do not see it drying out before it is combined and turned into slurry.