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 is
file:///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: Honda
file:///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.