Applicat ion of Technology to Si tuat ionsmPart I by John B. Durkee, II

T his is our eleventh column about technical aspects of cleaning. Doesn't t ime fly when . . . This month I want to change direction a bit.

The first ten columns have covered the basic funda- mentals of solvent and aqueous cleaning technology, how to purchase a system, what its costs should be, new products found in the marketplace, and new technology to come.

Now, I am going to shift emphasis to applications, solving of practical problems, and avoiding prob- lems. This may sound like a switch to a "Q & A" column, but I intend it not to be that. I intend this change to be a natural , cyclical one--from theory to practice. In "X" months we'll re turn to the funda- mentals. I see my mission with this column as edu- cational and I am jus t shifting from one type of information to another.

I'll write from my experience and tha t of my clients (unidentified). I'll write from my perspec- t i v e - a n unbiased industry consultant. I'll avoid questions better addressed to suppliers ("at what pH should my XX cleaning system be maintained if the temperature is YY°F?). You will be able to read and learn in this column about situations where cleaning technology is employed.

Readers of previous columns have told me they don't like the "Q & A" approach because it is too application specific. I th ink they mean tha t their specific problem wasn ' t covered in tha t column or tha t the lag time between submission of a question by E-mail and reading an answer was longer than their boss allowed for solution of the problem.

THE B IASED BOSS

How do I deal with an organization tha t won't con- sider use of solvent (or aqueous) cleaning technol- ogy? They say tha t Corporate Management won't allow solvents because the union doesn't want work- ers exposed to toxic chemicals, Corporate Legal doesn't want any lawsuits, and Corporate Technical doesn't like any of the solvents available. They say Corporate Production doesn't like aqueous because

John Durkee is President of Creative Enterprizes, a consulting firm located in Rockford, Ill. E-mail, jdurkee@precisioncleaning.com

it isn't consistent or doesn't work, Corporate Ac- counting says it costs too much to operate, and that Corporate QC says the parts rust in t ransi t to the customer. I know tha t my choice will be agreeable to some in my corporation, but others will strongly op- pose it. Which do I choose, or do I update my resume?

Neither. Sharpen your educational skills. Remove the above emotional bias from your heart and mind. Find what others have successfully done in this situation. Focus on those three actions.

First, s tar t with facts. Read past Cleaning Times columns about the fundamentals of each cleaning technology. Read Dave Peterson's Refer- ence book published in 1998 by Gardner, my Hand- book published in 1994 by Gardner, or Barbara Kanegsberg's Encyclopedia now being published by CRC. These volumes are described accurately by their names; Dave wrote a reference book, Barbara enlisted multiple authors to write chapters about topics where they have expertise, and I tried to write a book about solving problems. These three books are our industry's library. You can buy all three for around $200. That cost is dwarfed by the cost of a mistake or smaller than a day of consulting time!

Take each of the six concerns addressed by Cor- porate. Write in some detail what is meant by each concern. Then, using your knowledge of the facts, write similarly about how all six concerns can be addressed with technology, operating procedures, equipment, chemistry, or prayer.

Second, use this exercise to purge the bias from your mind.

Now you must do that for your boss and the 6+ persons representing a Corporate point of view. This is the first of two crucial steps. How do I change opinions in my corporation? Do that, as successful predecessors have done. But I'll bet your tactics will be based on facts, hence the above. One tactic might be to write and present a research report about the six concerns and how they can be addressed. The presentation is the key point because it allows open discussion. Remember, your at t i tude must be that of an external consultant--unbiased.

Third, get some more facts. Enlist competitive suppliers to provide you with successful references

52 Metal Finishing

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Number of Customers Customer Location Promotion of Services

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H A Z A R D O U S PROCESS S U B S T I T U T I O N

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where their offering has been used. Ask competitive suppliers to provide references to where their com- petitor's offering wasn' t used successfully.

Contact them. Make a friend. Invite them to speak to the group who heard your research report. Cleaning technology isn't generally considered pro- prietary, so their management might value the op- portunity to show off their staff 's expertise. At the least, ask your new friends to edit and sharpen your research work and conclusions.

Don't ignore the references about lack of success. They may be of the most value because you can learn what caused the lack of success.

Finally, jus t do it! Assemble your knowledge and tha t of your new friends. Make a decision. Write a report about the decision and send a copy to file. Don't broadcast your decision as you did your re- search report. Act as if your decision had been ap- proved by your Chairman of the Board. Follow the advice of one of my heros: Gifford Pinchot. He wrote in his book "Entrepreneuring" in 1984 that "it is always easier to ask for forgiveness than to ask for permission."

Use your facts, new knowledge, local and topical case histories, and new friends to guide you and answer the objections from Corporate.

THE USED V A P O R DEGREASER I have an old (1989) XXXXXX vapor degreaser. I would like to use it and not have to spend large sums for a vacuum vapor degreaser. Our site is not in a nonattainment area. Can we do this and be compliant with recent regulations? What should be our concerns?

This is an answer to your stated questions. I'll avoid comment on two statements about which there are other points of view. I'll bet aqueous could be made to work, and I'll bet full book-kept costs of operating a vacuum vapor degreaser aren't nearly what you have been led to expect.

Be concerned about three items: (1) condition of the old vapor degreaser; (2) the EPA's NESHAP, which covers control of emissions; and (3) training of your operators to use what is to them a new technology.

You can deal with the first two items by having a representative of XXXXXX visit your site (or review digital photographs).

Most vapor degreasers are made of aluminum. Your major concern is at tack of the a luminum by the inorganic acid produced by hydrolysis of the organic chlorinated solvent. This will be apparent in pitting, scratching, or possibly holes through the body or tube walls. If there is a still, and there should be, pay particular at tention here. Since the stabilizer is not normally volatile it won't be present in the

tubing, which feeds hot vapor to the cooling surface. Look for stabilizer/scale deposits in the boiler area.

Is the unit suitable for your proposed job? You probably want liquid immersion. Are there two sumps--one for soaking immersion and one to pro- duce vapor for cleaning/drying?

Ask the representative of XXXXXX to provide you with a quote for conversion of your degreaser to one that meets the standards of the 1994-1997 National Emission Standard for Hazardous Air Pollutants (NESHAP) for chlorinated solvents. Here is the key point--emphasize tha t you want the design to cover the "engineering approach" or "alternative method." They are the same.

The EPA's NESHAP allowed a great deal of free- dom in choice of emission controls. The "engineering approach" proscribed tha t the degreaser have emis- sion rates no larger than certain amounts (pounds per month) without regard to the methods used for emission control. If you won't use the degreaser for but a few hours per day ask the representative of XXXXXX to provide use of the "idling approach." This choice will save money for a unit only used slightly.

Either the engineering or idling approaches are easy to do, more cost effective because they save solvent, and involve the least amount of record keep- ing and reporting of performance to the EPA. If you want a checkpoint contact me by E-mail and I will provide you with the identity of another firm who only retrofits vapor degreasers and has very success- fully used these two methods of emission control.

Having chosen the engineering approach, you should have no trouble obtaining a new permit to emit a Hazardous Air Pollutant (HAP).

Finally, your crew will find this t ransi t ion much easier than the reverse one. But there are a couple of areas where t ra ining must be obtained and followed: (1) addition and monitoring of stabilizer (unless you want an old and leaky unit); (2) per- sonal exposure to the contents emanat ing from the cleaning bath and measur ing/document ing of the concentration of solvent represent ing tha t expo- sure over time; (3) dealing with f lammabil i ty if a nonhalogenated solvent is selected; (4) measur ing and calculating monthly solvent use to main ta in your environmental permit in force; and (5) in- creased concern about spills.

THE CLEANING TEST I have the age-old problem. I th ink my cleaning system is performing okay but, since there are no standards, I really don't know tha t this is so! Some- times my customers complain about something tha t

May 2001 55

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Table I. Example for Setting Standards

Next Use of Parts Possible Standard Inspection

Application of rust inhibitor More precise cleaning Assembly Packaging Painting

Visual examination using a cotton swab or rag. Perhaps wash the part in a solvent and look for change of color or settled particles.

A test for surface corrosion. A test for whatever is to be removed in the next cleaning step. Test that the assembled product does what it is expected to do. Does the appearance of this product make you proud? A peel test showing whether paint adheres to the surface. Or do the next painting step

and examine parts for paint failure.

might be related to cleaning quali ty but I don't know if it is or not.

If I don't have a problem I certainly don't want to waste any time on my cleaning system, but if I do, I want to fix the problem to some degree as I can't afford to lose customers.

How can I get past this concern and get on to really impor tant operating problems?

The honesty in your words is commendable. But if you can make money through improved cleaning isn't tha t important , too?

Unfortunately, you are going to have to help your- self (assuming you don't want to hire a consultant). Since you have been doing cleaning work for some time, your equipment is probably out of war ran ty and there is no evidence you need new.

Your supplier of cleaning "juice" can probably provide operat ing set points (composition, tempera- ture, pH, conductivity, etc.). S tar t there. Have your supplier of "juice" t ra in your staff in control of ap- plication of their products. Develop a database and periodically review it with tha t supplier. On a time sequence basis, compare outages in this database with any customer complaints.

Next, hire a representa t ive of the firm who made your cleaning equipment for a one-day inspection. Have them do the following: (1) inspect for condition and operability; (2) compare to specifications of your unit when new; (3) have them provide suitable test pieces and do a field test with your equipment and chemistry; (4) review cleanliness of these test pieces in their labs compared to pieces cleaned in their new equipment under war ran ty using a cleaning test they provide; and (5) ask the representat ive for a wri t ten list of checkpoints to be monitored on a periodic basis.

Next, develop a cleaning test based on your needs. This will take a little research. But tha t can have a big payoffi Remember, there is a reason why you are spending resources to clean these parts.

Likely, tha t reason is to enable the next operating step to go well (especially if tha t step is used by your customers). Your next step may be inspection, appli-

cation of a rust inhibitor, more precise cleaning, assembly, packaging, or painting. For this step I like ASTM-- they have a s tandard for everything. Search the index for a s tandard tha t covers your next use of the cleaned parts. See Table I for an example.

Pick something simple. Only choose a more com- plex test if the simple one proves unsatisfactory. As you can see in Table I, cleaning tests don't have to require an analytical workforce, distillation column, and testing lab!

Finally, implement tha t cleaning test as you would implement any other element of process con- trol. As a rule, allow initially one person to perform the test. This will ensure standardizat ion of technique and possibly enhancement of credibility. Later on, have one train many. Occasionally, test some parts tha t haven' t passed through the cleaning system.

Let the test results tell you what to do next.

INTERESTING NEW STUFF What's the exposure limit for n-propyl bromide (n- PB)? Should you care?

I don't know, and yes. You have read here, and in other places, tha t the

EPA is waiting for the results of some "toxicity tests" before they give n-PB some sort of SNAP approval. The test is a two-generation reproduction toxicity study of the effect of n-PB on rats. Informed rumor has it tha t there is a flaw in the test protocol and it may have to be redone. This would add years and dollars to the qualification path for SNAP approval.

So, if you are waiting for SNAP approval before putt ing n-PB in your vapor degreaser, don't hold your breath for less than multiple years. Alternately, it is perfectly legal to fill your vapor degreaser with it now- -many have done so. Should you?

For many, tha t answer depends on the exposure limit and whether or not you think your facility can meet it; however, the exposure limit has become a moving target!

The EPA will set a recommended exposure limit when they have a complete toxicological evaluation. Since that won't be done tomorrow, suppliers have

56 Metal Finishing

Table II. Corporate Exposure Limit for n-Propyl Bromide

Corporate Exposure Limit Implied Safety

Corporation (CEL), ppm Factor Albemarle 25 10 Amity 50 5 Enviro-Tech 100 2.5 Great Lakes No longer sells to NA

cleaning market Petrofirm 25 10 Poly Systems 100 2.5

had their toxicological depar tments study the same data and recommend Corporate Exposure Limits [CELs]. Apparently, all toxicologists agree on what the no-effect level is: 250 ppm. What safety factor does a toxicologist use to convert tha t value in a test with rats to a safe limit for humans? Traditionally, tha t value is 10. Table II shows what the CELs are at this writing.

We have recommended to our clients tha t they use n-PB in enclosed systems where a 25-ppm limit can be easily achieved. Said another way, we don't

recommend n-PB for use as a cold-cleaning or wipe- cleaning solvent where the exposure would likely be 10 > 100 ppm. Data we have seen, and the opinions of vendors we respect, suggest tha t 25 ppm can be met in a NESHAP-qual i ty vapor degreaser.

But that 's not the whole story. The real concern should now be handling of the solvent from the loading dock to inside the vapor degreaser, and the reverse. Some suppliers say "no problem" because the drums are sealed. We say "not so fast, my friend!" Most sites aren' t chemical plants, which are experienced in low-emission t ransfer of solvents. Spills do happen, part icularly when the unit is being flushed out.

As customers, insist on wri t ten t ransfer proce- dures, wri t ten recommendations about needed t ransfer equipment, wri t ten procedures about spill containment from the point of view of inhalation (not liquid containment), and some training in these procedures. With those procedures in place and with a NESHAP-quali ty vapor degreaser, you could switch to n-PB today. MF

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May 2001 57