A Pollution Prevention Assessment and Guidance · A Pollution Prevention Assessment and Guidance Washington State Department of Ecology Hazardous Waste and Toxics Reduction Program

A Pollution Prevention Assessment and Guidance

Washington State Department of EcologyHazardous Waste and Toxics Reduction Program

June, 1999Publication #99-412

printed on recycled paper

For a copy of this document, please contact:

Department of EcologyPublications

P.O. Box 47600Olympia, WA 98504-7600

Please include your street address for UPS delivery

The Department of Ecology is an equal opportunity agency and does not discriminate on the basis ofrace, creed, color, disability, age religion, national origin, sex, marital status, disabled veteran’s status,Vietnam Era veteran’s status or sexual orientation.

If you have special accommodation needs or require this document in alternative format, please contactthe Hazardous Waste and Toxics Reduction Program at (360) 407-6700 (voice) or (360) 407-6006 (TDD).

METAL MACHINING INDUSTRY SECTOR PROJECT 1

TTTTTaaaaabbbbble ofle ofle ofle ofle of Contents Contents Contents Contents Contents

IIIII ExExExExExecutivecutivecutivecutivecutive Summarye Summarye Summarye Summarye Summary 33333

IIIIIIIIII OvOvOvOvOvererererervievievievieview & Site Vw & Site Vw & Site Vw & Site Vw & Site Visitsisitsisitsisitsisits 44444

IIIIIIIIIIIIIII PPPPPollution Prollution Prollution Prollution Prollution Preeeeevvvvvention Summaryention Summaryention Summaryention Summaryention Summary 55555

A. Baseline Pollution Prevention Practices 55555B. Recommended Additional P2 Practices 66666

IVIVIVIVIV Metal WMetal WMetal WMetal WMetal Worororororkkkkking Fing Fing Fing Fing Fluid Maintenanceluid Maintenanceluid Maintenanceluid Maintenanceluid Maintenance 88888

A. Metal Working Fluid Maintenance Program 88888B. Selection Criteria 99999C. Metal Working Fluid Recycling 1010101010

VVVVV Spent Metal WSpent Metal WSpent Metal WSpent Metal WSpent Metal Worororororkkkkking Fing Fing Fing Fing Fluid Disposalluid Disposalluid Disposalluid Disposalluid Disposal 1414141414

A. Designation under Existing Regulations 1414141414B. Designation under Proposed New Regulations 1717171717C. Managing as Dangerous Waste 1717171717D. Managing as Used Oil 2121212121E. Evaporator Issues 2121212121

VIVIVIVIVI Chip ManaChip ManaChip ManaChip ManaChip Managggggementementementementement 2424242424

A. Chip Recycling 2424242424B. Stormwater Issues 2424242424C. Stormwater Regulations 2525252525

VIIVIIVIIVIIVII FFFFFloor Cleaningloor Cleaningloor Cleaningloor Cleaningloor Cleaning 2626262626

A. Routine Maintenance 2626262626B. Mop Water Disposal Options 2626262626C. Spills—Absorbent Waste Disposal 2727272727

VIIIVIIIVIIIVIIIVIII Health ConcernsHealth ConcernsHealth ConcernsHealth ConcernsHealth Concerns 2828282828

IXIXIXIXIX AppendixAppendixAppendixAppendixAppendixeseseseses 3030303030

A. Glossary 3030303030B. Pollution Prevention Opportunities List 3131313131C. Vendor Directory 3434343434D. Interim Used Oil Policy 3737373737E. Map of Air Pollution Control Authorities 3939393939F. Treatment by Generator 4141414141G. Resources 5050505050H. Bibliography 5151515151

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

2 WASHINGTON STATE DEPARTMENT OF ECOLOGY

AcAcAcAcAcknowledgknowledgknowledgknowledgknowledgementsementsementsementsements

“The sector team would like to thank all of the individuals who helped us in completing thisproject. We are especially appreciative of the time and information provided by the facilities wevisited.

We are grateful for the support and guidance that King County and L&I provided us. The inputprovided by Alice Chapman, Tracee Mayfield and Steve Whittaker was exceptional. We also wouldlike to thank all our peer reviewers, especially Dean White from AllFab and Chuck Copple fromFatigue Technology.

Lastly, I’m privileged to have worked with a great group of dedicated and inspiring people(Holly Cushman, Jim Hanley, Laura Schleyer, and Rolfe Parsloe), who helped make the last year flyby. Thank you for being you!!”

James DeMay


ExExExExExecutivecutivecutivecutivecutive Summarye Summarye Summarye Summarye Summary

In 1999, the Washington State Department of Ecology’s Hazardous Waste and Toxics Reduc-tion Program conducted a technical assistance project for the metal machining industry sector. Thisreport serves to provide this technical and regulatory information to the industry sector as a whole.The report is based on research by the sector team and on site visits to 12 metal machining facili-ties in Spring 1999.

The scope of the project included:

l Researching the environmental and regulatory issues in this industry sector.

l Conducting site visits at a cross-section of metal machining facilities.

l Evaluating current industry pollution prevention (P2) practices to identify technical assis-tance needs.

l Highlighting the most significant P2 opportunities and providing resources for future P2actions.

The site visits revealed that a significant amount of pollution prevention is already beingachieved at metal machining facilities. Common P2 practices include fluid monitoring, sumpmaintenance, and draining metal chips to recover fluids. The report highlights recommendedadditional P2 practices. These recommendations include using way oil that easily separates frommetal working fluid, using centralized recycling stations, and using high quality coolants toincrease fluid life span.

The report also discusses the compliance issues involved with the disposal of waste metalworking fluid. The key issues are the designation of spent metal working fluids as either used oilor dangerous waste and the management requirements for these wastestreams. The Department ofEcology is in the process of adopting new used oil regulations, which will change this designationprocess. These proposed changes are discussed in the report.

This document summarizes the Metal Machining Sector Project’s findings as well as recom-mendations, information and resources for metal workers.


OvOvOvOvOvererererervievievievieviewwwww

Since 1995, Department of Ecology(Ecology) has conducted sector projects withthe electroplating, fiberglass, printed circuitboard manufacturing, national security, andpaint manufacturing industries. In 1999, themetal machining sector project was selectedbecause the industry placed high on the rankinglist due to hazardous waste generation, ToxicRelease Inventory (TRI) emissions, and thenumber of facilities that prepare pollutionprevention plans.

Sector projects are short-term projects thatfocus on a particular industry type. Theseprojects provide Washington businesses withstatewide industry-specific pollution prevention(P2) assessments and technical assistance. Thisis achieved through a two step process. First,information is collected through research andsite visits; the data is then combined and ana-lyzed. Secondly, Ecology distributes the resultsto businesses within the sector. Sector projectsare multi-media (i.e. air, water and land) andcover the environmental issues pertaining to theindustry sector.

Currently, other agencies are conductingparallel work with this industry sector. KingCounty is working on technical assistance forthis sector, including site visits to all small andmedium quantity hazardous waste generators inthe county. In addition, Labor & Industry hasdone substantial work with health concerns withthis industry (See Health Section).

Of the various processes associated withmetal fabrication, metal machining was selectedas the primary focus of this project. The metalmachining industry comprises facilities thatshape a vast array of metal products, fromairplane spars to nuts and bolts. A wide varietyof shaping techniques are used, includingdrilling, boring, milling, broaching, grinding,and turning. The main wastestreams from theseprocesses are metal working fluids, used oil,cleaning wastes, metal chips and grinding swarf(metal residue from grinding).

Site VSite VSite VSite VSite Visitsisitsisitsisitsisits

Department of Ecology conducted 12 site visits to metal machining facilities during the monthsof February and March, 1999. The purpose of these visits was to:

1. Assess the current pollution prevention activity level2. Identify new pollution prevention opportunities3. Ascertain other important issues relating to this industry category including compliance

issues4. Identify additional research needs

TTTTTaaaaabbbbble 1: Site Vle 1: Site Vle 1: Site Vle 1: Site Vle 1: Site Visitsisitsisitsisitsisits

Facility Name Location Type of ProductsAllFab Aerospace Everett AerospaceBoeing Corporation - Plant 2 Tukwila AerospaceExotics Metals Forming Co. Kent AerospaceFatigue Technology Tukwila Metal Fatigue ReductionGear Works Seattle Gear ManufactureHansen Machine Corporation Auburn AerospaceHexcel Structures Kent Aerospace componentsJorgenson Forge Seattle Destroyer ShaftsModine Western Seattle Radiator partsPioneer Industries Seattle AerospacePrecision Machine Company Tacoma AerospacePrecor Woodinville Health/Exercise Equipment

Pollution Prevention (P2) is any practice thatreduces, avoids, or eliminates the generation ofwastes or the toxicity of wastes, prior to generation,without creating substantial new risks to humanhealth or the environment.


PPPPPollution Prollution Prollution Prollution Prollution PreeeeevvvvventionentionentionentionentionSummarySummarySummarySummarySummary

The following is a summary of the keypollution prevention practices that are dis-cussed in further detail in the chapters of thisreport. The purpose of this summary is:

l To identify baseline pollution prevention(P2) practices that should be common toevery facility.

l To identify 10 additional P2 practices thatare highly recommended by Ecology.

These practices are presented in twoseparate lists, with the baseline practicespresented first. See the appendix for a fulllisting of P2 practices for metal machiningfacilities.

Baseline PBaseline PBaseline PBaseline PBaseline Pollution Prollution Prollution Prollution Prollution Preeeeevvvvventionentionentionentionention

The following is a list of basic P2 prac-tices that, in Ecology’s view, should already betaking place in every metal machine shop dueto their basic nature and ease of implementa-tion.

List I: Baseline P2 PrList I: Baseline P2 PrList I: Baseline P2 PrList I: Baseline P2 PrList I: Baseline P2 Practicesacticesacticesacticesactices

Metal Working Fluid Testing

1. Monitor Concentration:Keeping the concentration of themetal working fluid (MWF) in thecorrect range will ensure that onlythe right amount of concentrate is used.It will also help control any gumming,sticking or smearing left on workpiecesdue to excess concentrate. Refractom-etry and titration are the most commontechniques for measuring fluid concen-tration.

Sump Maintenance

2. Sump and Trench Maintenance:Periodically cleaning out the MWFsumps and trenches will keep them freeof solid matter that can hamper fluidflow. Solid materials provide excellentareas for microbe growth and may clogup MWF lines. Disinfect sumps andtrenches when MFW fluid is removed.

Disinfectant options include alcohol orsteam cleaning. Without the disinfect-ing step, new MWF fluid will beinoculated with leftover bacteria whenit is added to the sump.

Metal Working Fluid Maintenance Plan

3. Daily Inspections:Conducting daily inspections of eachmachine will help identify problemsand trends, and speed up machine repairthrough early identification of prob-lems. This contributes to less downtimeand less fluid waste.

Recycling Systems

4. Tramp Oil Skimmers:These come in several different typesincluding rope, belt and disk skimmers.Skimmers remove the oil that makes itsway into the MWF and floats on thesurface of the fluid. Oil removal helpskeep the fluid aerated with dissolvedoxygen, and reduces the food source formicroorganisms.

Chip Management

5. Chip Filters:Filters keep the chips and grit created inthe machining process from contaminat-ing the MWF sump. The high amountof surface area created by the chipsprovides an excellent area for microbegrowth. Thus, filtering helps to lowerthe bacteria count.

6. Drain Metal Chips to Recover Fluid:One way of draining metal chips is toplace them into a perforated containerwith a catch basin and reuse the col-lected metal working fluid. Anotheroption is to manually shut off the chipconveyor for a period of time and allowthe fluids to drain back into the ma-chine sump. A chip wringer or centri-fuge can be used to get even more fluidfrom the chips.These processes alsocreate higher quality chips for recy-cling.


7. Recycle the Metal Chips and Scrap:Many, but not all, metal recyclers willtake chips. They will usually requirechips to be segregated by metal type andfree of oil. A higher price can usually beobtained if chips are compressed intobriquettes through the use of abriquetting machine.

Spills

8. Pumps, Spigots, and Funnels:Using pumps, spigots and funnels whentransferring MWF will reduce theamount of lost fluid and the risk ofspilling fluids.

Other

9. Fix Leaking Seals and Gaskets:This keeps the fluid where it belongs,instead of on the floor or all over themachine and operator. Even small leakscan waste a surprising amount of fluidover time.

10. Tramp Oil Separation:Tramp oils and MWF should be thor-oughly separated before skimming thetramp oils off the top. This will reducethe amount of MWF that is wasted withthe removal of the tramp oil.

RRRRRecommended Additional P2ecommended Additional P2ecommended Additional P2ecommended Additional P2ecommended Additional P2PrPrPrPrPracticesacticesacticesacticesactices

The following is a list of pollution preven-tion practices that Ecology’s Metal MachiningSector Team highly recommends to all facili-ties. These practices are recommended because,in general, companies that are already usingthem are enjoying cost-savings and decreasedwaste generation.

List II: RList II: RList II: RList II: RList II: Recommended P2ecommended P2ecommended P2ecommended P2ecommended P2PrPrPrPrPracticesacticesacticesacticesactices

Metal Working Fluid Maintenance Plan

1. Keep a Log of Monitoring Data:Keeping a log of fluid characteristics,such as pH and concentration, will helpidentify trends, solve problems, andkeep the fluid in the proper condition.

2. Operator Responsibility:The maintenance of metal workingfluids (MWF) should be limited to onlyone person or a team of people who aretrained and knowledgeable about fluidmaintenance. This will reduce fluidproperty variances and help cut downon the overuse of MFWs.

Metal Working Fluid Selection

3. Use High Quality MWFs to Get theLongest Life:

The use of high quality MWFs isrecommended because these fluids aremore resistant to biological attack andadditive breakdown. This resistanceallows them to be used many timeswithout a loss of performance.

4. Look at the Compatibility of Way Oilsand MWFs:

Ensuring that way lubricants andMWFs easily separate will help in thetreatment and recycling process. Selecta way oil that does not cause foamingproblems or impair the separationcharacteristics of the two fluids. High-grade way oils typically separate easilyfrom MWF. In addition, they containlittle or no sulfur compounds that are afood source for bacteria.


5. Use Chlorine Free MWFs:Chlorine has a large impact on wastedesignation and thus effects disposalcosts, management options, andmanagement requirements. Theproposed regulations, if adopted, willprohibit waste MWF formulated withchlorinated compounds from beingdesignated as used oil.

Sump Maintenance

6. Cover Sumps:By covering the MWF sumps inmachines, airborne microorganisms arekept out of the fluid. This is importantbecause a large number of the mi-crobes that contaminate fluids areairborne. Covers also keep out trashsuch as dust, cigarette butts and food.

Recycling Systems

7. Aerate/Ozonate the MWF to Keepthe Dissolved Oxygen Level Up:

By aerating the MWF or using anozone generator to bubble oxygenthrough the fluid, the anaerobicmicrobe count will be kept low.Dissolved oxygen in the water keepsanaerobic bacteria from growing andcreating the “Monday morning stink.”MWF treated with dissolved ozonereduces the microbe count. Ozone ishighly toxic to microbes and killsthem.

8. Central Recycling Systems:Central recycling systems allow a largevolume of fluid to be treated at once.Small, wheeled versions (about thesize of a large shopping cart) areavailable. A good recycling systemincludes a settling tank, oil skimmer,coalescer, and an aeration device.

Spills

9. Reuse Absorbent Pads:Using absorbent pads that can be wrungout and reused will cut down on theamount of absorbent material that mustbe discarded as hazardous waste, andsave money in fresh absorbent andwaste handling costs. Another option isto dedicate a mop for the clean up ofoily spills.

Other

10. Use Distilled or Deionized Water:Using distilled or deionized water keepsdissolved minerals out of the MWF.These contaminants can build up in thefluid as the water in the fluid evapo-rates, causing separation of the concen-trate from the water.


In the early 1970’s, metal working fluids(MWFs) were designed for a relatively short lifespan prior to disposal. Since then, the cost forfluid disposal has rapidly increased, along withliability concerns and regulations. As a result, agrowing importance has been placed on fluidmaintenance.

The key element of maintaining an efficientmetal working fluid system is a fluid maintenanceprogram. No matter what type of fluid you use, thelife of the fluid can be extended through the use ofa maintenance program.

The goal of a MWF maintenance pro-gram is to optimize fluid performance, reduceoily wastewater volume, and reduce fluidconcentrate and disposal costs. Contaminatedand spoiled fluids are the largest source ofwaste from machining operations. An estab-lished maintenance program allows correctiveactions to be taken before fluids becomerancid.

A written maintenance plan should becreated to document your MWF maintenanceprogram. This plan should include the follow-ing elements:

T T T T Taaaaabbbbble 2: Kle 2: Kle 2: Kle 2: Kle 2: Keeeeey Elements ofy Elements ofy Elements ofy Elements ofy Elements of a F a F a F a F a Fluid Maintenance Planluid Maintenance Planluid Maintenance Planluid Maintenance Planluid Maintenance Plan

Operator responsibilities List all the employees that implement the maintenance plan and theirresponsibilities.

Monitoring / Fluid testing Fluids can be monitored to predict or anticipate problems. Physicalcharacteristics such as product concentration, pH, fluid odor, and colorare good indicators of fluid degradation. Examples:

Product concentration can be measured by using a refracto-meter or by titration.

The pH of the fluid can easily be measured with litmuspaper or a pH meter. If the pH of a fluid in a sump fallsbelow 8.5, the fluid loses efficiency, is prone to rusting,and biological activity will increase significantly.

Data tracking system Keep a log of observations and test data.

Sump change out criteria Setting criteria for change out reduces unnecessary disposal of MWFfluid and creates a standard for fluid reuse.Examples: odor, appearance (milky appearance is normal), length ofuse, pH (usually between 8.5 – 9.4 is normal), residue or film left onparts.

Change-out procedures Document how to handle and process the fluid through your recyclingsystem.

Sump cleaning The purpose is to remove biological growth in the sump. Regularcleaning reduces health risks and improves fluid life. Examples: steamcleaning or use of a disinfectant solution.

Removal of chips Regular removal of chips reduces the habitat for biological organismsin your sumps.

Training program The written maintenance plan should be used to educate employeesabout MWF management and is an excellent source of training mate-rial for new employees.

Metal WMetal WMetal WMetal WMetal Worororororkkkkking Fing Fing Fing Fing Fluid Maintenanceluid Maintenanceluid Maintenanceluid Maintenanceluid Maintenance


High-grade way oils are a good choice becausethey separate easily and contain very littlesulfur, which serves as a food source formicrobes.

Another important element to considerwhen selecting a metal working fluid is whetheror not it is chlorinated (e.g. contains chlorinatedparaffins) or non-chlorinated. Chlorine has alarge impact on waste designation and thuseffects disposal costs, management options, andmanagement requirements (See section - SpentMetal Working Fluid Disposal). Chlorinatedmetal working fluids should only be selectedwhen high-pressure or high-speed conditionsare critical to the machining operation.

A final consideration is whether one typeof metal working fluid can be used for the entirefacility. Having only one fluid simplifies themaintenance and treatment of the fluid, requir-ing a facility to operate only one recyclingsystem.

TTTTTaaaaabbbbble 3: Tle 3: Tle 3: Tle 3: Tle 3: Types ofypes ofypes ofypes ofypes of Metal W Metal W Metal W Metal W Metal Worororororkkkkking Fing Fing Fing Fing Fluidsluidsluidsluidsluids

Fluid Type Composition Advantages DisadvantagesStraight oils Fluids that consist Resistant to biological Higher cost, difficult

of solvent-refined or degradation. Good rust to clean, fire hazardhydro-treated petroleum oil protection. Very little and health hazard.or other oils of animal or maintenance required.vegetable origin.

Water soluble oils Fluids that contain approx- Good cooling capacity Tramp oil removalimately 50%- 90% water, and lubricity. required. A main-with refined base oil and tenance programemulsifiers to mix the oil and to minimize bacterialwater. Other additives com- growth is necessary.monly found in soluble oils arebiocides, soaps, softeningagents, and rust inhibitors.

Semi-synthetic fluids Synthetic fluids that contain Good cooling capacity. Difficult to treat. Maysmall amount of refined base Average lubricity. Longer emulsify tramp oil.oil (5 –20%) that is micro- sump life. High foaming poten-emulsified, water and a solu- tial.tion of additives. These fluidstend to be similar to solubleoils.

Synthetic fluids Aqueous solutions that Excellent cooling properties. Poor lubrication and do not contain refined oil. Longer sump life. Good rust difficult to treat. Similar additives as seen in protection. Clear fluid allowssemi-synthetic fluids. workpiece to be visible

Selection CriteriaSelection CriteriaSelection CriteriaSelection CriteriaSelection Criteria

Selecting which metal working fluid(MWF) to use is a very important decision withmany considerations. Some of the main factorsto consider are lubricity, cooling properties, rustprotection, metal type, toolbit type, fluid life,and disposal costs. For more examples ofselection criteria and information about metalworking fluids, see “Metalworking Fluids” byJerry P. Byers or “Lubricants and Lubrication inMetalworking Operations” by Eliot S. Nachtmanand Serope Kalpakjian.

One factor that often gets overlooked is theseparation characteristics between way oils andmetal working fluids. It is very important toselect a way oil that easily separates from theMWF. Way oils that are not separated from themetal working fluid promote the degradation ofthe fluid’s properties and thus reduce the lifespan of the fluid. Furthermore, the better theseparation of these two fluids, the easier it is totreat and/or recycle the metal working fluid.


MetalMetalMetalMetalMetalwwwwworororororkkkkking Fing Fing Fing Fing Fluid Rluid Rluid Rluid Rluid Recececececyyyyyccccclinglinglinglingling

A good fluid recycling system extends theuseful life of metalworking fluids (MWFs) andhas both economic and environmental advan-tages such as:

l Improving product quality.l Decreasing the amount of new fluids

purchased.l Decreasing costs of disposal for spent

fluids.l Decreasing downtime for machine clean

outs and recharges.

Recycling systems remove contaminantssuch as tramp oil, dirt, and bacteria; andreadjust the fluid concentration before the fluidis returned to an individual sump. There are twoclasses of recycling systems, central recyclingsystems and individual recycling systems.

CentrCentrCentrCentrCentral Ral Ral Ral Ral Recececececyyyyycccccling Syling Syling Syling Syling Systemstemstemstemstem(inc(inc(inc(inc(including porluding porluding porluding porluding portatatatatabbbbble syle syle syle syle systems)stems)stems)stems)stems)

A central system is a large reservoir thatsupplies fluid to several individual machines.The major advantage of a centralized system isthat contaminants (solids, oil, and bacteria) canbe controlled at one location. This eliminatesthe need for many different systems on eachmachine, which overall will reduce the timeneeded to monitor and maintain the fluids. Withproper fluid controls and management tech-niques, the typical fluid in a central system canhave a life of one to three years (or evenlonger). Table 4 is a list of the types of contami-nant removal equipment used in central sys-tems.

T T T T Taaaaabbbbble 3: Tle 3: Tle 3: Tle 3: Tle 3: Types ofypes ofypes ofypes ofypes of Metal W Metal W Metal W Metal W Metal Worororororkkkkking Fing Fing Fing Fing Fluids(continluids(continluids(continluids(continluids(continued)ued)ued)ued)ued)

Fluid Type Composition

High pressure High pressure additives found in MWFs are chlorine, sulfur and phosphorusadditives compounds. These compounds are sometimes referred to as EP (extreme

pressure) agents, and are most commonly found as halogenated organiccompounds (e.g. chlorinated paraffins). Halogenated EP fluids should notbe used unless they are critical to the operation. In addition, sulfur andphosphorus are a food source for microbes and sulfur can stain metals.If you use any fluids with these compounds, remember to recycle and reusethem as much as possible.

Portable recycling systems are a cost-effective alternative to centralized recyclingsystems. The fluid from an individual sump ispumped into a portable unit that removescontaminants. The fluid is then returned to thesump and the portable system is moved to thenext machine. If the fluid from each machine istreated according to a prescribed maintenanceschedule, daily fluid monitoring may not berequired.

TTTTTaaaaabbbbble 4: Centrle 4: Centrle 4: Centrle 4: Centrle 4: Central Ral Ral Ral Ral Recececececyyyyycccccling Syling Syling Syling Syling Systemsstemsstemsstemsstems

Removes:

Oil Dirt/Metal BacteriaChips

Settling/ XDragout

Flotation X X

PositiveFilters Gravity X Pressure X Vacuum X

Centrifuge X X

Oil Skimmer X

Coalescer X X

Pasteurization X

Byers, Jerry P. (editor), Metal Working Fluids, MarcelDekker, Inc., NY,NY, 1994, page 346.


Individual RIndividual RIndividual RIndividual RIndividual Recececececyyyyycccccling Syling Syling Syling Syling Systemsstemsstemsstemsstems

Unlike central recycling systems, individual recycling systems tend to control only one type of contami-nant. For example, a milling machine might only have a skimmer to remove any excess tramp oil. The benefitsof using individual systems are their low capital costs, and ability to focus on one particular problem for a givenmachine.

There is a wide variety of recycling systems for individual machines. Table 5 lists some of the morecommonly used recycling systems for individual machines.

Removes:

Oil Dirt/Metal BacteriaMEDIA-BASED SYSTEMS

Filtration XPressure XVacuum XGravity X

NATURAL FORCE SYSTEMSSettling/Gravity XOil Skimmers XCoalescers X XFlotation/Aeration X

MECHANICAL SEPARATIONSYSTEMS

Centrifuges X XOTHER

Pasteurization XOzonation X

Byers, Jerry P. (editor), Metal Working Fluids, Marcel Dekker, Inc., NY,NY, 1994, page 347.

Table 6 on the following pages describes the recycling/maintenance components listed in the two previoustables and also identifies possible benefits for each.

The following are some possible combinations for portable, individual, and central batch recycling sys-tems.

l A combination of settling tank, skimmers, and aeration devices will remove coarse particles by settlingand fine particles and tramp oil by skimming.

l A high efficiency sump cleaner will remove fluids and solids from sumps. The fluid is passed through acentral batch-recycling unit utilizing a coalescer, pasteurization, and filtration technique and then returnedto the sump. Other central batch combinations include: skimmers/filtration/ozonators; skimmers/coalescer; skimmer/fluid concentration adjuster.

l A portable unit equipped with a skimmer and ozonator for treating individual sumps.l A portable unit equipped with a coalescer, filter, and fluid concentration adjuster.l Portable sump cleaner, or “brown cow”, is used to transfer used fluid to a 3 stage separation tank. Particu-

late settles out and tramp oil is skimmed off in the first 2 stages. “Clean Cows” are used to return treatedfluid to individual sumps.

l Portable units that act only as filtration units.l A settling tank, ozonation/aeration, tramp oil skimmer and a filter.

TTTTTaaaaabbbbble 5: Individual Macle 5: Individual Macle 5: Individual Macle 5: Individual Macle 5: Individual Machine Rhine Rhine Rhine Rhine Recececececyyyyycccccling Syling Syling Syling Syling Systemsstemsstemsstemsstems


Ta

ble

6

: G

en

era

l D

es

crip

tio

ns

o

f C

om

mo

n R

ec

yc

lin

g C

om

po

ne

nts

a

nd

C

on

sid

era

tio

ns

Eq

uip

men

t D

escr

ipti

on

C

on

sid

erat

ion

s

Set

tlin

g/D

ragout

Par

ticu

late

s in

man

y m

etal

work

ing f

luid

syst

ems

are

oft

en a

deq

uat

ely r

emoved

by i

nst

alla

tion o

f a

sim

ple

gra

vit

y/s

ettl

ing t

ank. S

uch

a t

ank i

s en

han

ced w

hen

an

auto

mat

ic b

ar, ra

ke

dev

ice,

or

convey

er b

elt

syst

em i

s ad

ded

to

rem

ov

e m

etal

sh

avin

gs

and

oth

er

sett

led

so

lid

s.

Ad

van

tag

es i

ncl

ud

e n

o m

edia

rep

lace

men

t o

r dis

posa

l re

quir

ed. O

ne

dis

advan

tage

is t

hat

cla

rity

is

dep

end

ent

on

ret

enti

on

tim

e an

d c

hip

wei

gh

t.

Als

o, th

is s

yst

em i

s not

effe

ctiv

e w

ith a

lum

inum

ch

ips

or

swar

f w

hic

h t

end

to

flo

at.

Flo

tati

on

/Aer

atio

n

A d

evic

e th

at u

ses

aera

tio

n t

o f

loat

so

lid

s an

d t

ram

p

oil

to t

he

surf

ace.

A

dv

anta

ges

in

clu

de

no

med

ia r

epla

cem

ent

or

dis

posa

l re

quir

ed. It

work

s on f

ine

par

ticl

es.

Dis

advan

tages

incl

ude

gre

ater

flo

or

spac

e re

qu

irem

ents

an

d i

ncr

ease

d u

sag

e o

f p

lan

t co

mp

ress

ed a

ir.

Posi

tive

Fil

ters

G

ravit

y F

ilte

rs

Bec

ause

of

gra

vit

y, th

e w

eight

of

the

met

alw

ork

ing

fluid

is

suff

icie

nt

to p

rovid

e th

e fo

rce

requir

ed t

o

pen

etra

te t

he

filt

er m

ediu

m. M

ost

com

mon f

ilte

r m

edia

are

clo

th, pap

er, org

anic

, poly

mer

s, o

r w

ire

scre

ens.

Ad

van

tag

es i

ncl

ud

e lo

w c

ost

an

d e

ase

of

op

erat

ion

.

Dis

adva

nta

ges

incl

ude

gre

ater

flo

or

spac

e re

qu

irem

ents

an

d i

ncr

ease

d m

edia

dis

po

sal.

P

ress

ure

Fil

ters

A

dev

ice

that

co

nta

ins

two

ho

rizo

nta

l co

mp

artm

ents

; a

mo

vab

le t

op

co

mp

artm

ent

and

sta

tio

nar

y b

ott

om

co

mpar

tmen

t. D

uri

ng o

per

atio

n, ai

r pre

ssure

sea

ls

the

two

co

mp

artm

ents

to

get

her

. T

he

filt

er m

ediu

m

may

be

a co

nti

nu

ou

s n

ylo

n b

elt

use

d a

s is

or

on

e co

ated

wit

h a

dis

po

sab

le m

ediu

m.

Advan

tages

incl

ude

abil

ity t

o r

emove

smal

l par

ticl

es e

ffic

ientl

y. A

lso, la

rge

volu

mes

can

be

han

dle

d w

ithin

min

imal

flo

or

spac

e.

Dis

advan

tages

incl

ude

pre

mat

ure

ly p

lugged

fil

ters

if

tra

mp o

il i

s not

rem

oved

fir

st.

V

acuum

Fil

ters

T

he

com

mon p

osi

tive

filt

er s

yst

em i

s dri

ven

by a

v

acu

um

. F

luid

is

pu

lled

by

vac

uu

m t

hro

ug

h a

per

man

ent

roll

or

cyli

nder

.

Advan

tages

incl

ude

low

cap

ital

cost

s, e

ffic

ient

filt

rati

on, an

d n

o m

edia

rep

lace

men

t or

dis

posa

l re

quir

ed. D

isad

van

tages

incl

ude

gre

ater

flo

or

spac

e re

qu

irem

ents

.


Cen

trif

uge

A r

ota

ting b

ow

l th

at u

ses

centr

ifugal

forc

es t

o

sep

arat

e o

il, w

ater

, an

d s

oli

ds.

L

ow

-sp

eed

ce

ntr

ifu

ges

rem

ov

e su

spen

ded

so

lid

s fr

om

mo

st

liquid

s. H

igh

-sp

eed

un

its

bo

th r

emo

ve

tram

p o

ils

and

so

lids.

The

goal

is

to s

epar

ate

free

tra

mp o

il a

nd

loose

ly e

muls

ifie

d o

il (

such

as

mec

han

ical

ly

emuls

ifie

d o

il.)

C

hip

Wri

nger

s, a

var

iati

on, se

par

ate

chip

s fr

om

cu

ttin

g f

luid

s by a

lter

nat

ing h

igh t

o l

ow

-sp

eed

cy

cles

.

Ad

van

tag

es i

ncl

ud

e h

igh

th

rou

gh

pu

t ra

te (

abo

ut

2

gp

m)

and

go

od

su

spen

ded

so

lid

an

d t

ram

p o

il

separ

atio

n. D

isad

van

tages

incl

ude

hig

h

mai

nte

nan

ce w

hen

so

lid

s an

d g

reas

e re

qu

ire

freq

uen

t cl

ean

ing

an

d s

epar

atio

n o

f p

rod

uct

co

mp

on

ents

.

Co

ales

cer

Use

s th

e p

rop

erty

of

oil

att

ract

ion

to

po

lyp

rop

yle

ne

med

ia (

or

ole

ophil

ic, "o

il-l

ovin

g"

mat

eria

ls)

for

rem

oval

of

tram

p o

il.

Advan

tages

incl

ude

its

appli

cabil

ity t

o e

ither

ce

ntr

al o

r port

able

syst

ems.

C

oal

esce

rs a

re n

ot

effe

ctiv

e fo

r re

movin

g w

ater

-mis

cible

hydra

uli

c oil

s or

emuls

ifie

d l

ubri

cati

ng o

ils,

how

ever

. P

aste

uri

zati

on

A

hea

tin

g p

roce

ss t

hat

im

pro

ves

sep

arat

ion

of

soli

ds

and r

educe

bio

logic

al g

row

th.

Under

cer

tain

condit

ions,

this

pro

cess

succ

essf

ull

y

contr

ols

mic

robia

l gro

wth

. T

his

pro

cess

can

red

uce

a

fluid

’s l

ubri

city

and c

orr

osi

on i

nhib

itio

n

pro

per

ties

. F

iltr

atio

n

Flu

id i

s pas

sed t

hro

ugh a

dis

posa

ble

fil

ter

to r

emove

soli

d p

arti

cles

F

iltr

atio

n u

nit

s en

han

ce p

art

finis

h, to

ol

life

, bac

teri

a co

ntr

ol,

and l

ubri

city

pro

per

ties

. T

hey

are

m

ost

ad

van

tag

eou

s w

hen

use

d w

ith

cen

tral

re

cycl

ing s

yst

ems

or

port

able

rec

ycl

ing u

nit

s.

Unit

s on i

ndiv

idual

mac

hin

es t

end t

o b

e la

bor

inte

nsi

ve.

O

il S

kim

mer

s D

evic

es t

hat

skim

tra

mp o

il f

rom

flu

id r

eser

voir

s in

m

ach

ine

sum

ps.

T

he

mo

st c

om

mo

n a

re b

elt

and

dis

c sk

imm

ers.

For

indiv

idual

syst

ems,

a c

om

bin

atio

n o

f se

ttli

ng

tank a

nd s

kim

mer

s w

ill

rem

ove

coar

se p

arti

cles

and

tram

p o

il. T

his

rel

ativ

ely i

nex

pen

sive

com

bin

atio

n

oft

en p

rovid

es s

uff

icie

nt

clea

n l

ubri

cant

read

y f

or

reu

se.


Spent Metal WSpent Metal WSpent Metal WSpent Metal WSpent Metal WorororororkkkkkingingingingingFFFFFluid Disposalluid Disposalluid Disposalluid Disposalluid Disposal

Once a metal working fluid (MWF) isdetermined to be no longer usable, it must bedesignated and disposed accordingly. Thissection of the report discusses:

l Designating spent MWF as either used oilor dangerous waste under existing regula-tions.

l Designation changes under proposed newregulations.

l Management requirements for used oiland dangerous waste.

l Evaporator requirements.

DesignaDesignaDesignaDesignaDesignation oftion oftion oftion oftion of Spent MWF Spent MWF Spent MWF Spent MWF Spent MWFunder the Existing Dangunder the Existing Dangunder the Existing Dangunder the Existing Dangunder the Existing DangerererererousousousousousWWWWWaste Raste Raste Raste Raste Reeeeegulagulagulagulagulationstionstionstionstions

The first step in designating spent metalworking fluid is to determine whether it is usedoil or dangerous waste. A series of questionsmust be answered in order to make this determi-nation. The following seven steps and theflowchart on page 15 explain how this determi-nation is made.

In order to use the flowchart, a businessneeds to determine the total halogen content oftheir spent metal working fluid, preferably bysending a sample out to a laboratory for testing.If chlor-detects or “sniff” tests are used instead,businesses should keep a written record of thename and telephone number of the personperforming the test along with the sampling dateand equipment calibration date. All written testrecords should be kept onsite for 3 years.

Note: Not all MWFs are formulated fromcrude oil or synthetic oil, and therefore do notmeet the definition of used oil.

Step 1: Is the spent MWF to be re-refinedinto oil/MWF?

Spent metal working fluid that will be re-refined into oil or reformulated into metalworking fluid is not dangerous waste and is notsubject to dangerous waste designation ormanagement requirements (reference WAC 173-303-120(2)). Spent MWF to be re-refined ismanaged as used oil and is subject only to WAC173-303-050, 120(b), 145, 515 and 960. Thesesections require that the fluids be managed in amanner that does not pose a threat to humanhealth or the environment.

Note: Not all metal working fluids can bere-refined. Some contain metals, such as copper,zinc, or lead, which interferes with the refiningprocess. Consult with your vendor for furtherinformation.

Step 2: Is the MWF formulated withchlorinated compounds?

This step is the proposed change to themetal working fluid designation process thatEcology may adopt under the new used oilrules. This issue is discussed below in thesection, “Designation of Spent MWF underProposed New Regulations.”

Step 3: Has the spent MWF been mixedwith other wastestreams?

If spent MWF is mixed with anotherwastestream (such as mop water), the resultantmixture becomes subject to the designationprocess under WAC 173-303-070, -080, -090and -100. It is illegal to mix dangerous wastewith non-dangerous wastestreams. A largenumber of dangerous waste constituents can befound in spent MWF, including lead, cadmium,


Flow Chart: Spent Metal Working Fluid (MWF) Designation Process

Step 5: HOCS > 10,000 ppm. YesSpent MWF designates as an extremely hazardous waste.

It must be counted, labeled, accumulated, and disposed as

a dangerous waste. If it is burned, it must be burned as a

dangerous waste fuel in accordance with WAC 173-303-

510.

Step 6: Total halogens > 1,000 ppm.

NO

Yes Spent MWF is assumed to be mixed with another waste. It

is presumed to be dangerous waste and must be managed

accordingly. This presumption can be rebutted. If rebutted

successfully, manage the spent MWF as used oil.

Step 7: Total halogens < 1,000 ppm.

NO

YesSpent MWF can be managed as used oil. The oil is not

considered a dangerous waste and has no special time or

storage requirements. It does not count toward generator

status.

Step 1: Is spent MWF to be re-refined into

oil/MWF? WAC 173-303-120 (2)Yes

* If spent MWF is not re-refined, it must be managed as

a dangerous waste. If it is burned then it must be

managed under WAC 173-303-510.

Step 3: Has spent MWF been mixed with any

other waste stream (except for used oil)

Yes Spent MWF subject to full designation under 173-303--070,

080, 090, and 100. Depending on metals being machined, test

for lead, cadmium, selenium, zinc, copper, total halogens and

any other possible DW constituents. If any regulatory level is

exceeded, the MWF must be managed as dangerous waste,

otherwise manage as solid waste.

NO

Step 4: Does the spent MWF contain animal

or vegetable oils?Yes

Spent MWF subject to full designation under 173-303--070,

080, 090, and 100. If any regulatory level is exceeded, the

MWF must be managed as dangerous waste, otherwise manage

as solid waste.

NO

* Step 2 (Proposed): Is the spent MWF

formulated with chlorinated compounds?

NO

Yes

NO

Spent MWF is not dangerous waste and can be managed

as used oil. Manage according to 173-303-050,

120(2)(B), 145, 515 and 960.

* This step is the proposed change to the metal working fluid designation process that Ecology may adopt under the

new used oil rules.


chromium, selenium, copper and zinc. Thesemetals typically enter the MWF via the machin-ing process. For example, when zinc plated orzinc bearing metals such as brass are machined,zinc, copper and lead can be present. It isnecessary to use process knowledge and materialsafety data sheets (MSDS) to develop a com-plete list of elements and compounds to test for.

Businesses can avoid the problems associ-ated with mixed wastestreams by trainingemployees to separate wastestreams, properlylabeling waste containers and restricting con-tainer access to trained employees.

Step 4: Does the MWF contain animal orvegetable oils?

“Used oil means any oil that has beenrefined from crude oil, or any synthetic oil, thathas been used and, as a result of such use, iscontaminated by physical or chemical impuri-ties” (WAC 173-303-040). This definitionexcludes animal and vegetable oils (lard, canola,etc.). Spent MWF’s that contain animal orvegetable oils do not meet the definition of usedoil and therefore are subject to designationunder WAC 173-303 (see previous paragraph forcommon waste constituents to test for).

Step 5: Does the spent MWF have >10,000 parts per million (ppm)halogenated organic compounds (HOC)?

Metal working fluid with more than 10,000parts per million HOC is considered extremelyhazardous waste. If it is burned, it must bemanaged as dangerous waste fuel under WAC173-303-510. However, water-soluble MWFstypically contain less than 10,000 ppm HOC’sunless they are evaporated or mixed with otherhalogenated wastestreams (e.g. chlorinatedcompounds). Evaporator residues from chlori-nated MWFs will typically exceed the 10,000ppm HOC limit.

WAC 173-303-100 states that wastestreamsthat have more than 10,000 ppm polycyclicaromatic hydrocarbons (PAH) must be managedas extreme hazardous waste. Most MWF’s havenot had significant PAH concentrations in theirformulations for many years.

Step 6: Does the MWF have >1,000 ppmtotal halogens?

Metal working fluid that contains morethan 1,000 ppm total halogens is presumed tohave been mixed with a dangerous waste and isrequired to be managed as dangerous waste.However, the presumption that mixing hasoccurred can be rebutted. In order to rebut thispresumption, the business must demonstrate thatthe MWF does not contain halogenated danger-ous waste constituents as a result of intentionalmixing. The halogenated dangerous wasteconstituents are listed in WAC 173-303-9903and –9904.

Rebutting the presumption that dangerouswaste has been mixed into MWF can be assimple as:

4 Demonstrating via a material safety datasheet that the source of the halogens is themetal working fluid itself (soluble MWF’stypically contain chlorinated paraffins)AND:

4 Demonstrating that care is taken to avoidusing products that introduce chemicalslisted in WAC 173-303-9903 and -9904into the MWF AND:

4 Demonstrating that other wastestreams aremanaged so as to prevent mixing.

Step 7: Does the MWF have < 1,000 ppmtotal halogens?

If the spent MWF contains less than 1,000ppm total halogens it can be managed as usedoil. See section below on “Managing SpentMFW as Used Oil”.


DesignaDesignaDesignaDesignaDesignation oftion oftion oftion oftion of Spent MWF Spent MWF Spent MWF Spent MWF Spent MWFunder Prunder Prunder Prunder Prunder Proposed Neoposed Neoposed Neoposed Neoposed NewwwwwRRRRReeeeegulagulagulagulagulationstionstionstionstions

The Department of Ecology is in theprocess of adopting the Federal Used OilManagement Standards (UOMS), with finaladoption anticipated in 2000.

What will change?

One of the proposed changes to the ruleaffects spent soluble metal working fluids(MWFs) that are formulated with chlorinatedparaffins (see Step 2 above). Under the proposedrule, spent MWFs formulated with chlorinatedparaffins can be managed as used oil, only ifthey are sent to be re-refined. Otherwise, thesespent MWFs must be managed as dangerouswaste. Furthermore, spent metal working fluidsthat designate as dangerous waste and are sent tobe burned, must be managed under “SpecialRequirements for Dangerous Wastes Burned forEnergy Recovery” (WAC 173-303-510). Thepurpose of this rule change is to eliminate thepotential for spent chlorinated MWFs to beburned in inappropriate combustion units, whichmay generate dioxins.

Note that the terms “chlorinated paraffins”and “chlorinated alkanes” are synonymous andare used interchangeably on material safety datasheets (MSDS). Also note that some chlorinatedparaffins are not required to be listed on MSDSsheets but still might be present in MWFs. SeeAppendix G (Resources) for help using MSDSsheets in determining whether the fluid isformulated with chlorinated compounds.

ManaManaManaManaManaging Spent MWF asging Spent MWF asging Spent MWF asging Spent MWF asging Spent MWF asDangDangDangDangDangerererererous Wous Wous Wous Wous Wasteasteasteasteaste

To properly manage dangerous waste,businesses need to determine their generatorstatus. Generator status depends on the totalamount of dangerous waste generated permonth and the amount of waste stored on site.Management requirements differ depending ongenerator status. The following reference guideoutlines the management requirements basedon generator size.


TTTTTaaaaabbbbble 7: Guide fle 7: Guide fle 7: Guide fle 7: Guide fle 7: Guide for Dangor Dangor Dangor Dangor Dangerererererous Wous Wous Wous Wous Waste Generaste Generaste Generaste Generaste Generaaaaatortortortortors in WAs in WAs in WAs in WAs in WA




ManaManaManaManaManaging Spent MWF as Usedging Spent MWF as Usedging Spent MWF as Usedging Spent MWF as Usedging Spent MWF as UsedOilOilOilOilOil

To determine if a spent metal workingfluid meets the definition of used oil see thedesignation section. For example, some MWFsdo not meet the definition of used oil becausethey are not formulated from crude oil orsynthetic oil.

Businesses are required to manage theirused oil according to WAC 173-303-050, -145, -515, -960, and -120(2)(b). The following arekey aspects of these regulations:

l Businesses must manage used oil in amanner that does not threaten humanhealth or the environment. Businesses areliable for the mismanagement of used oiland are required to report spills that are athreat to human health or the environ-ment.

l Businesses are required to dispose of usedoil properly. For example, the use of usedoil as dust abatement or to control weedsis considered to be improper disposal.

Proposed Additional Used OilRequirements

There are two proposed rule changes thataffect businesses that manage spent workingMWF as used oil. The first proposed changerequires that used oil containers be kept closedexcept when contents are being added orremoved. The second change requires that usedoil containers not be opened, handled, managed,or stored in a manner that could cause thecontainer to leak or rupture.

EvEvEvEvEvaaaaaporporporporporaaaaator Considertor Considertor Considertor Considertor Consideraaaaations andtions andtions andtions andtions andCompliance IssuesCompliance IssuesCompliance IssuesCompliance IssuesCompliance Issues

Considerations

Businesses that generate spent water-basedmetal working fluid (MWF) may wish toevaporate water from this wastestream to reducewaste volume and disposal cost. Water-basedMWFs include soluble, synthetic or semi-synthetic fluids but not straight oils. Thesewater-based fluids usually contain non-volatilesubstances and therefore are amenable toevaporation. However, care must be used inbuilding and operating an evaporator to preventexceeding air quality standards.

Exceeding air quality standards is undesir-able due to health concerns as well as the poten-tial worker and/or neighbor complaints that willdraw undesired regulatory attention to a facility.Water from spent metal working fluids can beevaporated without evaporating toxic air pollut-ants by implementing the following six sugges-tions:

1. “Clean” the solution to be evaporated asmuch as possible prior to evaporation. Thiswill minimize the evaporation of toxic airpollutants and prevent fouling of pipes andthe evaporator itself. For spent metalworking fluid, this means using an oil-water separator prior to the evaporator.Skim oil from the oil-water separator andcollect it for disposal.

2. Do not evaporate to dryness. Soluble spentmetal working fluid is typically 95% waterand 5% additives (oil, surfactants, etc.)that are emulsified in water. The waterportion can be evaporated. However, if youevaporate to dryness, the emulsion portionwill be evaporated as well and toxic airpollutants may be emitted. To avoidevaporating to dryness, evaporate only95% of the water (see example). At theend of the evaporation process the concen-trated emulsion must be removed anddisposed of properly. Note: Oil-waterseparators do not remove emulsifiedadditives from your metal working fluids.

3. Service the evaporator at regular intervals.Keep a service log. Make one personresponsible for seeing that the log is keptcurrent and work performed as required.

4. Carefully regulate the operating tempera-ture of the evaporator. Use the lowesttemperature possible to avoid vaporizingtoxic air pollutants. The water in solubleMWF boils at 212° F at sea level and atslightly lower temperatures at higherelevations. Temperature controls should beset and “locked” at or below 212° F, asappropriate.


Evaporator Use Example:

100 gallons of spent soluble machine coolant needs to be disposed. The spent coolantcontains:

- 5% tramp oil,- 5% emulsified napthenic oil, chlorinated paraffins, metals, etc.- 90% water

In this example, the spent coolant contains 5 gallons of tramp oil, 5 gallons of emulsi-fied compounds and 90 gallons of water. This spent coolant is placed into an oil-waterseparator, which removes the 5 gallons of tramp oil. The remaining 5 gallons ofemulsified compounds and 90 gallons of water are placed into an evaporator. Only95% of the total amount of water should be evaporated. In other words, leave 5% ofthe water in the evaporator (in this scenario ~ 4.5 gallons). Otherwise, compoundswill be volatilized, creating toxic air pollution. Excessive evaporation also leads toformation of a baked on residue that is very difficult to clean off the evaporator unit.At the end of the evaporation process, remove the resulting concentrated solution anddispose of properly. In this example 9.5 gallons would be removed (5 gallons emulsi-fied compounds and 4.5 gallons water).

5. Make sure the evaporator has emergencytemperature and water level shutoffs. Theemergency high temperature shutoffshould be set no more than 230° F. Thelow level water shutoff should be set at5% of capacity. This seems redundant toeveryone except those people who havehad their facilities catch fire.

6. Properly size mist eliminators. Highvelocity airflows create water droplets thatsuspend metals and other toxic air pollut-ants in the exhaust air stream. Suspendedpollutants will be carried out the stackunless trapped by a mist eliminator. Agood vendor will make sure that yourevaporator has a properly sized misteliminator.


Compliance Issues—Air

Air pollution control authorities regulateevaporation processes that emit toxic airpollutants. Some of the toxic air pollutants ofconcern that might be found in spent metalworking fluids include:

— cadmium compounds— lead compounds— aluminum— borates— chromium (II, III, VI, & metal)— iron oxide fume (Fe2O3)— copper— tin— oil mist (mineral)— iron salts— selenium— zinc

There currently is no minimum level fortoxic air pollutants that will exempt a businessfrom regulatory review. If a business determinesthat they wish to evaporate a wastestream thatcontains or could contain a toxic air pollutant,they should contact their local air authority (SeeAppendix E for contact numbers).

The following are possible outcomes of aregulatory review:

l Not Regulated—Evaporators do notrequire regulation if the liquid evaporateddoes not contain a toxic air pollutant.

l Registered—Evaporators that generatesmall amounts of toxic air pollutants mustbe registered with the local air authority.

l Permitted—Businesses with evaporatorsover a certain size may need to obtain anair operating permit. Businesses thatgenerate more than 10 tons of a singletoxic air pollutant or 25 tons of toxic airpollutant (combined) are required toobtain a Title V air operating permit.

Compliance Issues—Hazardous Waste

Businesses that choose to evaporate spentmetal working fluid that designates as hazardouswaste, are performing what is known as “Treat-ment by Generator.” Treatment by generatorrequirements include the following (see Appen-dix F for more information):

l Hazardous waste management rules apply.For example, containers used to holddangerous waste MWF must have second-ary containment and be labeled “Danger-ous Waste” and “Toxic”. (See Table 7 onpage 18-20 )

l The spent metal working fluid must becounted before and after placement intothe evaporator. Businesses that evaporatedangerous waste must log the pounds ofdangerous waste being evaporated. Thecounting rules are explained in moredetail in Ecology’s “Counting DangerousWaste Under the Dangerous WasteRegulations” publication (# 98-414).

NOTE: Evaporating spent MWF that does notdesignate as dangerous waste may generate residuethat is dangerous waste.


Chip ManaChip ManaChip ManaChip ManaChip Managggggementementementementement

Metal chips are one of the two mainwastestreams generated at metal machiningfacilities. Because such large volumes of wastemetal are generated, most metal machiningfacilities find that it makes economic sense torecycle their waste chips. Recycling is thestandard industry practice for managing wastemetal chips.

Chip RChip RChip RChip RChip Recececececyyyyyccccclinglinglinglingling

The key pollution prevention issue inrecycling metal chips is separating the metalworking fluids from the chips. This separationachieves two benefits simultaneously. As morefluid is recovered, more can be recycled andreused, thereby reducing the amount needing tobe purchased by the facility. Separating the fluidsfrom the chips also reduces the potential con-tamination of stormwater when the chips arestored outside, or during loading and transporta-tion. Furthermore, most metal recyclers requirethat chips be well drained prior to pick-up.

A number of different methods for drainingchips are used at metal machining facilities.Some facilities manually shut off the chipconveyor for a period of time and allow thefluids to drain back into the machine sump.Centrifuges and chip wringers are also com-monly used to drain chips. At low RPMs, centri-fuges can also be used for separating tramp oilsfrom metal working fluids. A more passive chipdraining system consists of drums, with screenson top, set at the end of the conveyor belt. In thissystem, the fluid coated chip falls off the con-veyor belt onto the screen. Over time, the fluidwill drain through the screen and the dry chipscan be transported to waste chip storage contain-ers and the collected fluids can be recycled.

Overall , the best method is one that allowsthe fluid to drain from the metal chip as soon aspossible before the fluid has a chance to beginevaporating. This prevents chemical residuesfrom drying on the chips. These residues havethe potential to contaminate stormwater.

MarMarMarMarMarkkkkketing Issueseting Issueseting Issueseting Issueseting Issues

Facilities normally separate their chips bymetal type in order to get the highest price fromtheir metal recycling company. Metal recyclersmay also offer a higher price to a facility if the

chips are compressed into a briquette throughthe use of a briquetting machine. (See AppendixC: Vendor Directory). The cost/benefit analysisfor purchasing such a machine includes theprice of the machine, the price offered forbriquettes versus loose chips, and the volume ofchips the facility generates.

StormwStormwStormwStormwStormwaaaaater Issuester Issuester Issuester Issuester Issues

Inside storage of waste chips is highlyrecommended, if enough space exists at thefacility. Outside storage introduces the possibil-ity that stormwater will become contaminatedfrom contact with the metal working fluidresidues on the waste chips. Depending on thefluid used, these residues may contain metals,oils and/ or chlorinated paraffins. Inside storagevirtually eliminates this potential stormwatercontamination problem. However, if chips needto be stored outside, use the following precau-tions to avoid stormwater contamination:

4 Be sure fluid has completely drainedbefore placing chips in storage contain-ers. Any fluids or fluid residues have thepotential to contaminate stormwater eitherat your facility or when stored at therecycling company.

4 Cover outside chip storage containers.This will eliminate the possibility thatclean rainwater will become contaminatedby contact with residues on the chips.

4 Place chip storage containers on con-crete or asphalt surface to prevent spillsand leaks to bare ground. Installing aperimeter berm or curb further reduces thepossibility of contaminating soils.

4 Continue draining fluids, if necessary.If it is necessary to place chips outsidebefore they are completely drained besure that your outside storage containersallow drainage to continue. Many facili-ties simply tilt the waste chip dumpstertowards one end and excess fluids to drainthrough a hole into a residue container.

4 Check often for leaks. Be sure thatoutside storage containers and/or residuecontainers do not have holes them.

4 Monitor and maintain containers on aregular basis. Empty storage or residuecontainers and do not allow them tooverflow.


StormwStormwStormwStormwStormwaaaaater Rter Rter Rter Rter Reeeeegulagulagulagulagulationstionstionstionstions

Ecology’s stormwater regulations requiremost industrial facilities to have a stormwaterpermit. Any facility that discharges stormwaterto surface water, or into a storm sewer whichleads to a surface water, must apply for astormwater permit. If all of the stormwater froma facility discharges to the ground and/or to acombined storm/sanitary sewer, a permit is notrequired. Facilities that need a stormwaterpermit and fail to apply for one could be subjectto legal actions.

The permit requires industrial facilities todevelop a Stormwater Pollution Prevention Plan.These plans should identify existing and poten-tial sources of stormwater pollution, and de-scribe how the facility will reduce or eliminatethat pollution. Additional specific planningrequirements are detailed in the permit.

Contact an Ecology staff person in yourregion if:

l You are uncertain if your facility needs astormwater permit

l You have any questions about currentpractices and possible stormwater impactsat your facility

See the inside front cover for a regionalmap to identify your region

Northwest Regional Office - BellevueRon Devitt (425) 649-7028Bob Newman (425) 649-7046Bob Wright (425) 649-7060

Southwest Regional Office - OlympiaDick Schroeder (360) 407-6273

Eastern Regional Office - SpokanePaul Turner (509) 625-5181

Central Regional Office -YakimaPam Perun (509) 454-7869


FFFFFloor Cleaningloor Cleaningloor Cleaningloor Cleaningloor Cleaning

RRRRRoutine Maintenanceoutine Maintenanceoutine Maintenanceoutine Maintenanceoutine Maintenance

In the metal machining industry thepresence of spilled or leaked metal workingfluids, hydraulic oils, or tapping fluids can causefloor mop water to designate as a dangerouswaste. This is especially true if these fluidscontain chlorinated paraffins.

Mop water from floor cleaning should betested and designated to verify whether or not itis dangerous waste. Testing must be done inaccordance with the requirements under theState Dangerous Waste Regulations (WAC 173-303-090 and -100). Common dangerous wasteconstituents to test for include: lead, cadmium,chromium, selenium, copper and zinc. Zincbearing metals (i.e. brass) and zinc-plated partsthat are machined often contain lead. If themetal working fluid or hydraulic oils being usedcontain chlorinated paraffins, the mop watershould be tested for total halogens. Also, de-pending on the chemical make-up of somecleaning agents and/or cleaning solvents, mopwater may designate as a hazardous waste.

Mop WMop WMop WMop WMop Waaaaater Disposal Optionster Disposal Optionster Disposal Optionster Disposal Optionster Disposal Options

The following management options applyto mop water depending on whether or not it isdangerous waste:

Mop water that is NOT a dangerouswaste:

l May be discharged to a sewer systemafter receiving the local sewer district’sapproval. Mop water may exceed thesewer district’s limits for oil and greases.

l Must not be discharged to storm drains,dry wells, or septic systems. Businessesmust know where drains lead before usingthem.

l Should not be mixed with spent metalworking fluid. See Step 3 on page 14.Has the spent MWF been mixed withother wastestreams?

Mop water that IS a dangerous waste:

l Must be managed as dangerous waste.Management requirements depend on thegenerator status of the business. For moreinformation on management require-ments, reference Table 7, titled “Guidefor Dangerous waste (DW) Generators inWashington.”

l Must not be mixed with any other non-dangerous wastes; otherwise the entirewastestream becomes a dangerous wasteand must be managed as such.

l Small quantity generators may treat themop water onsite or ship it offsite to apermitted temporary storage disposalfacility, local moderate risk waste facility,or other permitted solid waste facility(WAC 173-303-070 (8) (b)(iii).

l Mop water must meet two conditions inorder to be discharged to a sewer system.It must be treatable by the local sewerdistrict and must be either a state-onlywaste or a highly diluted federally listedwaste. Before discharge, a business needsto obtain an appropriate permit issued bythe Department of Ecology or local sewerdistrict (WAC 173-303-071(3)(a)). Thismop water is excluded from dangerouswaste counting requirements unless it istreated before discharge. See EcologyPublication #94-136, Revised 6/97,Domestic Sewage Exclusion for moreinformation.

l Mop water that is a characteristic wastemust be managed as a dangerous waste.Furthermore, the Domestic SewageExclusion does not apply to mop waterthat is a characteristic waste. You maywish to consider using treatment-by-generator options, such as evaporation, asa means of minimizing the volume ofwaste. See Appendix F: Treatment ByGenerator.


The following suggestions will help keepmop water from becoming dangerous waste:

l Don’t use mop water to clean up solventor oily spills.

l Don’t mix normal mop water with waterthat is used during the clean up of spilledsolvent or chlorinated fluids and oils.

l Prevent leaks by properly maintainingequipment.

Spills-Absorbent WSpills-Absorbent WSpills-Absorbent WSpills-Absorbent WSpills-Absorbent WasteasteasteasteasteDisposalDisposalDisposalDisposalDisposal

The same constituents that can cause mopwater to become dangerous waste can alsocause floor absorbent to become dangerouswaste. These constituents include lead, chro-mium selenium, zinc, copper, chlorinatedparaffins, solvents, etc. Testing must be done inaccordance with the requirements under theState Dangerous Waste Regulations (WAC 173-303-090 and -100).

Absorbents are often used to clean upwastes that are managed as used oil, such asway oils and spent MWF. It is often incorrectlyassumed that these contaminated absorbents canalways be managed as used oil. Ecology’sproposed policy concerning used oil states that:

“Materials that are not dangerous waste andthat contain or are otherwise contaminatedwith used oil in recoverable quantities canbe managed as used oil.”

Under normal conditions, spent absorbentsused to cleanup oil spills do not contain recov-erable quantities, therefore, they are not subjectto the used oil standards. If the spent absorbantdoes not contain hazardous constituents, theymay be managed as a solid waste. Disposaloptions for waste absorbents depend on whetheror not they are dangerous waste.

Waste absorbent that is NOT dangerouswaste:

l Can be disposed in a dumpster upon theapproval of the local landfill or solidwaste hauler. Sufficient absorbent must beused to prevent the presence of freeliquids.

WWWWWaste aaste aaste aaste aaste absorbent thabsorbent thabsorbent thabsorbent thabsorbent that ISt ISt ISt ISt ISdangdangdangdangdangerererererous wous wous wous wous waste:aste:aste:aste:aste:

l Must be managed as a dangerous waste(See Table 7).

l Small quantity generators may treat thiswaste onsite or ship it offsite to a permit-ted temporary storage disposal facility,local moderate risk waste facility or otherpermitted solid waste facility (WAC 173-303-070 (8) (b)(iii)).

The following suggestions may decreasethe amount of absorbents needed or preventabsorbents from designating as dangerous waste:

l Contain leaks in catch basins or spill pansin place of pads. Liquid can be reused,recycled, or properly disposed.

l Vacuum spills and reuse, recycle, orproperly dispose the recovered liquid.

l Use rags that can be wrung out andlaundered for reuse. Recovered liquid canbe reused, recycled, or properly disposed.


Health ConcernsHealth ConcernsHealth ConcernsHealth ConcernsHealth Concerns

Department of Labor and Industry hasdone substantial work with health concerns inthe metal fabrication industry through theirSHARP program. Key information from thisprogram is excerpted below from the fact sheettitled, “Metal Working fluids: A Fact Sheet forWorkers” (#46-1-1997). The entire fact sheetand additional information can be found ontheir website at http://www.wa.gov/lni/sharp/ orby phone at (888) – 66 – SHARP.

Who is Exposed to MWFs?Who is Exposed to MWFs?Who is Exposed to MWFs?Who is Exposed to MWFs?Who is Exposed to MWFs?

According to the National Institute forOccupational Safety and Health (NIOSH), over1 million workers in the United States areexposed to MWFs. Here at the Safety & HealthAssessment & Research for Prevention(SHARP) program, we have estimated thatapproximately 20,000 workers in WashingtonState use MWFs. While machinists, machinerymechanics, metalworkers, and other machineoperators and setters have the greatest contactwith MWFs, workers performing assemblyoperations can also be exposed if MWFs remainon the machined product. Workers can beexposed to MWFs by skin contact, or by in-haling (breathing in) or ingesting (swallowing)particles, mists, and aerosols.

WhaWhaWhaWhaWhat art art art art are MWFs’ Healthe MWFs’ Healthe MWFs’ Healthe MWFs’ Healthe MWFs’ HealthEfEfEfEfEffffffects?ects?ects?ects?ects?

Although recent changes in MWF formu-lations have resulted in safer products, it isimportant to realize that MWFs can still containsubstances that are harmful to your health. Themost commonly observed illnesses associatedwith MWF use are:

SkSkSkSkSkin Prin Prin Prin Prin Proboboboboblemslemslemslemslems

Skin contact with MWFs is very common,since MWFs are often applied to the machinetool in large volumes. Workers’ skin can becovered with mist or spray while machining, orhandling parts and tools covered with residualfluid.

MWF-soaked rags and clothing canprolong the length of time that the MWF is incontact with the skin. MWFs have been shownto cause numerous skin problems, ranging fromdermatitis due to irritation or allergy (verycommon) to skin cancer (relatively rare).NIOSH has observed that between 14% and67% of workers using MWFs have dermatitis.

CancerCancerCancerCancerCancer

There is evidence to suggest that expo-sures to some MWFs can increase workers’ riskfor cancer of the skin, esophagus, stomach,pancreas, larynx, colon, rectum, and otherorgans. However, the link between MWFexposure and cancer is controversial, since theepidemiological studies were performed onworkers who were exposed to MWFs as long as20-30 years ago. Before the 1950s and 1960s,some MWFs contained relatively high concen-trations of substances suspected to cause cancer(mostly polycyclic aromatic hydrocarbons andnitrosamines).

Since then, industry actions have resultedin substantially reduced concentrations of thesesubstances in MWFs. However, it is unclearwhether these changes have eliminated thecancer risk because it is not known if thecancer-causing substances are present in theMWFs themselves, or whether they are con-stituents of MWF additives or contaminants.

Lung DiseaseLung DiseaseLung DiseaseLung DiseaseLung Disease

Inhaling the aerosols, particles, and mistsgenerated by MWFs while machining is acommon source of exposure. Several lungdiseases are associated with inhaling MWFs,including asthma, acute airway irritation,hypersensitivity pneumonitis, lipid pneumonia,chronic bronchitis, and possibly lung cancer.NIOSH researchers suggest that machinists facean increased risk of asthma at concentrationsbelow the current permissible exposure limits(PELs).


WhaWhaWhaWhaWhat Occupat Occupat Occupat Occupat Occupational Standartional Standartional Standartional Standartional StandardsdsdsdsdsApply Apply Apply Apply Apply to MWFs?to MWFs?to MWFs?to MWFs?to MWFs?

The two most important occupationalstandards that apply to MWFs are those for“particulates not other-wise regulated” and “oilmists”. In Washington State, the PEL for “total”particulates is 10 milligrams of total particulateper cubic meter of air (10 mg/m3), based on an8-hour time weighted average (TWA). Thismeans that exposures to total particulates canlegally exceed 10 mg/m3 at times, but only ifconcentrations are below 10 mg/m3 at othertimes, so that the average exposure for any 8-hour workshift is 10 mg/m3 or less. The PEL foroil mists is an 8-hour TWA of 5 mg/m3.

NIOSH is concerned that workers mayexperience adverse respiratory effects if they areexposed at the current PELs. NIOSH recom-mends that occupational safety and healthprograms that include medical monitoringshould be established at MWF-using work-places. As of summer 1997, NIOSH is finalizingits “Criteria Document” (see sidebars on page 3)and OSHA (the Occupational Safety and HealthAdministration) is convening a committee ofnational experts to develop a proposal for a newstandard to lower workplace exposures andincrease worker protection. PELs also exist forcertain additives and other MWF Constituents.”


Appendix A: GlossaryAppendix A: GlossaryAppendix A: GlossaryAppendix A: GlossaryAppendix A: Glossary

Biocide A chemical additive used to kill organisms in metal working fluids. Biocides includebactericides and fungicides. Bactericides kill bacteria and fungicides kill fungus.

Coalescer Porous-media seperators which use oil attracting media beds to attract oil in preferenceto water.

Extra Pressure These additives are commonly composed of halogenated paraffins. The halogen in the(EP) Additives compound complexes with the metal workpiece and adds extra lubrication for in-

creased tool life.

Halogenated A compound containing any one of the halogen series of elements. These are com-monly chlorine, bromine, and iodine in metal working fluids.

Metal Working Metal Working Fluid is used in machining metal parts to cool and lubricate the toolFluid(MWF) pieces, thus prolonging the life of the tool.

Oil Skimmers Oil skimmers remove the tramp oil and debris from the surface of the metal workingfluid. They use either a rotating disk, a moving belt, or a moving rope that dips into thetank, and attracts the tramp oil to it’s surface. The tramp oil is then scraped off the disk,belt, or rope and into a container.

Paraffin Paraffins are long, straight carbon chain organic molecules with no cyclic or ringstructures in their molecular makeup. They are primarily composed of carbon andhydrogen and may have halogens attached for extra properties.

Semi-Synthetic This fluid is the same as the synthetic fluid (below) but has a small amount of oil addedFluid (2-20%).

Soluble Oil Fluid A concentrate of severely hydro-treated oils combined with large amounts of emulsifi-ers. This combination allows the fluid to mix with water into a solution.

Straight Oil Fluid A fluid that consists of solvent-refined or hydro-treated petroleum oil or other oils ofanimal or vegetable origin.

Sump A tank that holds metal working fluid.

Synthetic Fluid A concentrate that is added to water to form an aqueous metal working fluid. Theconcentrate does not contain crude oil, or oil of any other kind. This fluid is commonlymade up of amines, nitrites, nitrates, phosphates, soaps, and glycol.

Tramp Oil: Tramp oil is most commonly made up of way oil (the lubrication used for the slidingparts of the machine) and hydraulic oils that fall, or are carried into the metal workingfluid.

APPENDIX B 31

Appendix B: List ofAppendix B: List ofAppendix B: List ofAppendix B: List ofAppendix B: List ofPPPPPollution Prollution Prollution Prollution Prollution PreeeeevvvvventionentionentionentionentionOpporOpporOpporOpporOpportunities btunities btunities btunities btunities byyyyyOperOperOperOperOperaaaaationtiontiontiontion

Sump MaintenanceSump MaintenanceSump MaintenanceSump MaintenanceSump Maintenance

1. Cover Sumps:By covering the metal working fluid

(MWF) sumps in machines, airborne microor-ganisms are kept out of the fluid. This is impor-tant because a large number of the microbes thatcontaminate fluids are airborne. Covers alsokeep out trash such as dust, cigarette butts andfood.

2. Sump and Trench Maintenance:Periodically cleaning out the MWF sumps

and trenches will keep them free of solid matterthat can hamper fluid flow. Solid materialsprovide excellent areas for microbe growth andmay clog up MWF lines. Disinfect sumps andtrenches when MWF fluid is removed. Withoutthe disinfecting step, new MWF fluid will beinoculated with left over bacteria when it isadded to the sump.

3. Leave Machine MWF Pumps On duringDowntime:

While the machine is not in operation,leave the MWF circulating through the machineto help aerate the fluid and keep it from becom-ing stagnant.

4. Movement of Fluid in Sump:A small pump can be used to circulate fluid

in a sump, preventing stagnation and anaerobicmicrobial growth in the fluid.

5. Sump Size:By keeping the sump size as small as

possible, the fluid has a greater flow-throughrate, and will not become stagnant.

Metal WMetal WMetal WMetal WMetal Worororororkkkkking Fing Fing Fing Fing Fluid Selectionluid Selectionluid Selectionluid Selectionluid Selection

6. Use Chlorine Free MWFs:The proposed regulations, if adopted, will

prohibit waste MWF formulated with haloge-nated compounds from being designated as usedoil. Halogenated compounds include chlorine,bromine, and iodine (see glossary).

7. Number of MWFs:Use the smallest number of different

MWFs as possible. This simplifies the variabil-ity in MWF management and minimizes theoverall amount of management required.

8. Use High Quality MWFs:The use of high quality MWFs is recom-

mended because these fluids are more resistantto biological attack and additive breakdown.This resistance allows them to be used manytimes without a loss of performance.

9. Look at the Compatibility of Way Oils andMWF’s:

Ensuring that way lubricants and MWFseasily separate will help in the treatment andrecycling process. Select a way oil that does notcause foaming problems or impair the separationcharacteristics of the two fluids. High-grade wayoils typically separate easily from MWF. Inaddition, they contain little or no sulfur com-pounds that are a food source for bacteria.

Metal WMetal WMetal WMetal WMetal Worororororkkkkking Fing Fing Fing Fing Fluid Maintenanceluid Maintenanceluid Maintenanceluid Maintenanceluid MaintenancePlanPlanPlanPlanPlan

10. Daily Inspections:Conducting daily inspections of each

machine will help identify problems and trends,and speed up machine repair through earlyidentification of problems. This contributes toless downtime and less fluid waste.

11. Operator Responsibility:The maintenance of metal working fluids

(MWF) should be limited to only one person or ateam of people who are trained and knowledge-able about fluid maintenance. This will reducefluid property variances and help cut down onthe overuse of MWF.

Metal WMetal WMetal WMetal WMetal Worororororkkkkking Fing Fing Fing Fing Fluid Tluid Tluid Tluid Tluid Testingestingestingestingesting

12. Monitor Concentration:Keeping the concentration of the MWF in

the correct range will ensure that only the rightamount of concentrate is used. It will also helpcontrol any gumming, sticking or smearing lefton workpieces due to excess concentrate.Refractometry and titration are the most com-mon techniques for measuring fluid concentra-tion.


13. Monitor pH:By monitoring the pH of the MWF, prob-

lems with the fluid can be spotted. A drop in pHmay mean that there is a high microbe count inthe fluid, or that impurities are building up.Keeping the pH in the correct range will helpcontrol microbial growth, and help reducefoaming and separation of the fluid.

14. Keep Log of Monitoring Data:Keeping a log of fluid characteristics, such

as pH and concentration, will help identifytrends, solve problems, and keep the fluid in theproper condition.

RRRRRecececececyyyyycccccling Syling Syling Syling Syling Systemsstemsstemsstemsstems

15. Tramp Oil Skimmers:These come in several different types

including rope, belt and disk skimmers. Skim-mers remove the oil that makes its way into theMWF and floats on the surface of the fluid. Oilremoval helps keep the fluid aerated withdissolved oxygen, and reduces the food sourcefor microorganisms.

16. Aerate/Ozonate:By aerating the MWF or using an ozone

generator to bubble oxygen through the fluid, theanaerobic microbe count will be kept low.Dissolved oxygen in the water keeps anaerobicbacteria from growing and creating the “Mondaymorning stink.” MWF treated with dissolvedozone reduces the microbe count. Ozone ishighly toxic to microbes and kills them.

17. Central Recycling Systems:Central recycling systems allow a large

volume of fluid to be treated at once. Small-wheeled versions (about the size of a largeshopping cart) are available. A good recyclingsystem includes a settling tank, oil skimmer,coalecser, and an aeration device

Chip ManaChip ManaChip ManaChip ManaChip Managggggementementementementement

18. Chip Filters:Filters keep the chips and grit created in the

machining process from contaminating the MWFsump. The high amount of surface area createdby the chips provides an excellent area formicrobe growth. Thus, filtering helps to lowerthe bacteria count.

19. Drain Metal Chips to Recover Fluid:One way of draining metal chips is to place

them into a perforated container with a catchbasin and reuse the collected metal workingfluid. Another option is to manually shut off thechip conveyor for a period of time and allow thefluids to drain back into the machine sump. Achip wringer or centrifuge can be used to geteven more fluid from the chips. These processesproduce higher quality chips for recycling.

20. Recycle the Metal Chips and Scrap:Many, but not all, metal recyclers will take

chips. They will usually require chips to besegregated by metal type and free of oil. Ahigher price can usually be obtained if chips arecompressed into briquettes through the use of abriquetting machine.

21. Store Chips Under Cover:By storing metal chips and shavings inside

or under cover, the risk of contaminatingstormwater is reduced, and the chips are kept at abetter quality. Store chips on an impervioussurface to prevent soil contamination from leaksand spills.

SpillsSpillsSpillsSpillsSpills

22. Pumps, Spigots, and Funnels:Using pumps, spigots and funnels when

transferring MWF will reduce the amount of lostfluid and the risk of spilling fluids.

23. Reuse Absorbent Pads:Using absorbent pads that can be wrung out

and reused will cut down on the amount ofabsorbent material that must be discarded ashazardous waste, and save money in freshabsorbent and waste handling costs. Anotheroption is to dedicate a mop for the clean up ofoily spills.

APPENDIX B 33

24. Use Catch Basins:Contain leaks in catch basins instead of

using absorbent pads.

25. Vacuum Spills:Vacuum spills instead if using absorbent

pads or catch basins. The recovered fluid can bereused, recycled, or properly disposed.

OtherOtherOtherOtherOther

26. Fix Leaking Seals and Gaskets:This keeps the fluid where it belongs,

instead of on the floor or all over the machineand operator. Even small leaks can waste asurprising amount of fluid over time.

27. Gasket and Seal Compatibility:Make sure that the gaskets and seals on

machine equipment are not degraded by eitherthe way oil or the MWF.

28. Use Distilled or Deionized Water:Using distilled or deionized water keeps

dissolved minerals out of the MWF. Thesecontaminants can build up in the fluid as thewater in the fluid evaporates, causing separationof the concentrate from the water.

29. Tramp Oil Separation:Tramp oils and MWF should be thoroughly

separated before skimming the tramp oils off thetop. This will reduce the amount of MWF that iswasted with the removal of the tramp oil.

30. Biocide AdditionIf other methods do not work, the addition

of a biocide/fungicide can help extend the life ofMWFs. These additives should be used spar-ingly, and only as a last resort. When fluids withbiocides are spent, they should be tested todetermine if they are a hazardous waste. Somebiocides contain chlorinated compounds.

31. Wash hands to reduce bacteria:Machinists frequently come in contact with

metal working fluids and humans are a primarysource of bacteria. Washing hands regularly willreduce the spread of bacteria.

32. Cooling of the MWF:Keeping the MWF cool will help slow the

growth of microbes in the sumps and fluid areas.


Appendix C: VAppendix C: VAppendix C: VAppendix C: VAppendix C: VendorendorendorendorendorDirDirDirDirDirectoryectoryectoryectoryectory

EquipmentEquipmentEquipmentEquipmentEquipmentMost of the following vendors were taken

from the Thomas Register and are samples ofvendors in each category that serve the metalmachining industry. For a complete listing ofvendors, see the Thomas Register atwww.thomasregister.com.

Coolant RCoolant RCoolant RCoolant RCoolant Recoecoecoecoecovvvvvery Syery Syery Syery Syery Systems:stems:stems:stems:stems:

Cecor, Inc., Verona, WI(800) 356-9042

Como Industrial Equipment, Inc.,Janesville, WI(800) 451-0028 x25www.comoindustrial.com

Coolant Wizard, Inc., Indianapolis, IN(317) 545-5380 or (888) 476-5959

Deer Path Industrial Technology, Inc.,Issaquah, WA(425) 391-9223

Edjetech Services, Wellington, OH(888) 856-4865

Hyde Products, Inc., Cleveland, OH(800) 999-0009 or (440) 871-4885www.hydeweb.com

Hydroflow, Inc., Salem, NH(603) 898-3388

Lakos Filtration Systems, Fresno, CA(559) 255-1601www.lakos-laval.com

Monlan/Chemaperm, Kalamazoo, MI(616) 382-6348

Sanborn Technologies, Medway, MA(800) 343-3381 or (503) 533-8800www.sanborntech.com

Chip Briquetting SyChip Briquetting SyChip Briquetting SyChip Briquetting SyChip Briquetting Systems:stems:stems:stems:stems:

Counselor Engineering, Inc., Hudson, OH(800) 783-6567

Deer Path Industrial Technology, Inc.,Issaquah, WA(425) 391-9223

Gensco America Inc., Decatur, GA(800) 268-6797www.genscoequip.com

Komar Industries, Inc., Groveport, OH(800) 311-9068 or (614) 836-2366www.komarindustries.com

Lewis Corp., Pocatello, ID(800) 658-5122www.lewiscorporation.com

Multipress, Inc., Columbus, OH(614) 228-0185www.multipress.com

Scanrec, Waco, TX(800) 577-3766www.scanrec.com

Chip WChip WChip WChip WChip Wringing Equipmentringing Equipmentringing Equipmentringing Equipmentringing Equipment(Centrifug(Centrifug(Centrifug(Centrifug(Centrifuges)es)es)es)es)

Barrett Centrifugals Inc., Worchester, MA(800) 228-6442

Chip Systems International, Scotts, MI(616) 626-8000

Prab Conveyors, Kalamazoo, MI(800) 252-9730www.prab.com

Inter-Source Recovery Systems,Kalamazoo, MI(800) 334-1470www.Inter-Source.com

National Conveyors Co. Inc., EastGranby, CT(800) 945-9139 x12www.nationalconveyors.com

Rousselet Centrifuge, Inc., Bethesda, MD(888) 776-5923

APPENDIX C 35

EvEvEvEvEvaaaaaporporporporporaaaaation Sytion Sytion Sytion Sytion Systems:stems:stems:stems:stems:

Equipment Manufacturing Corp, Whittier,CA(888) 833-9000www.equipmentmanufacturing.com

Environmental Hydrotech, Inc., Croton,NY(914) 736-0200

Hyde Products, Inc., Cleveland, OH(800) 999-0009 or (440) 871-4885www.hydeweb.com

Landa Water Cleaning Systems, Camas,WA(800) 547-8672 or (360) 833-9100www.landa-inc.com

Nordale Environmental Engineering,Clinton, IA(800) [email protected]

Patterson Industries LTD, Ontario,Canada(800) 336-1110 x1078www.pattersonindustries.com

TTTTTrrrrramp Oil Seamp Oil Seamp Oil Seamp Oil Seamp Oil Separparparparparaaaaatortortortortors:s:s:s:s:

Edjetech Services, Wellington, OH(888) 856-4865

Environmental Protection Associates,Inc., Seattle, WA(800) 299-3721

Hyde Products, Inc., Cleveland, Ohio(800) 999-0009 or (440) 871-4885www.hydeweb.com

Stouder Engineering & Machine,Hagerman, ID(208) 837-4663

World Chemical USA, Inc., Torrance, CA(888) 860-3364www.worldchemusa.com

SerSerSerSerServicesvicesvicesvicesvices

Recycling of Metal Chips/Shavings/Borings(also call Ecology’s Hotline, 1-800-RECYCLE)

City Junk Inc., Tukwila,WA(206) 763-3024

Independent Metals Co., Seattle(206) 763-9033

Pacific Iron and Metal, Seattle(206) 628-6232

Riverside Salvage and Metal Co.(206) 932-7262

Seattle Iron and Metals Corp., Seattle(206) 682-0040

West Seattle Recycling Ctr., Seattle(206) 935-4255

WWWWWaste Metal Waste Metal Waste Metal Waste Metal Waste Metal Worororororkkkkking Fing Fing Fing Fing Fluid Disposalluid Disposalluid Disposalluid Disposalluid Disposal

Metal Working Fluid Recovery (fornon-hazardous, water soluble fluids)

Basin Oil, SeattlePhilip Services, Renton(800) 439-2948(800) 228-1130

Keep it Clean Recycling, RedmondSeaport Petroleum(425) 868-3535(206) 228-7872


For Disposal of MWF as used oil orhazardous waste:::::

Advanced Environmental Tech Svs,Tukwila(800) 334-2387

Amalgamated Services, Inc., Sumner(800) 273- 9248

Clean Care Corp., Federal Way(800) 282-8128

Envirotech, Seattle(800) 922-9395

FBN Environmental, Kirkland(425) 820-8115

Front Water Services, Seattle(800) 545-3520

Keep It Clean Recycling, Redmond(425) 868-3535

Philip Services, Renton(800) 228-7822

Protective Environmental Svcs, Seattle(206) 624-5503

Romic Environmental Technologies,Tacoma

(253) 627-7790

Safety-Kleen, Lynnwood(425) 775-7030

Shultz Distributing, Seattle(800) 286-0896

APPENDIX D 37

Appendix D: Interim Used Oil PAppendix D: Interim Used Oil PAppendix D: Interim Used Oil PAppendix D: Interim Used Oil PAppendix D: Interim Used Oil Policolicolicolicolicyyyyy


APPENDIX E 39

Appendix E: MaAppendix E: MaAppendix E: MaAppendix E: MaAppendix E: Map ofp ofp ofp ofp of Air P Air P Air P Air P Air Pollution Controllution Controllution Controllution Controllution Control Authoritiesol Authoritiesol Authoritiesol Authoritiesol Authorities


If you have special accommodation needs, please contact Ecology’s Air Quality Program at (360) 407-6800 (Voice) or (360) 407-6006 (TDD),

Ecology is an Equal Opportunity and Affirmative Action Employer

Publication # 93-106 July 8, 1999

Sources of Information about Air Pollution in Washington State

1. Olympic Air Pollution Control Authority(Clallam, Grays Harbor, Jefferson, Mason, Pacific,

Thurston Counties)

909 Sleater-Kinney Road SE, Suite 1

Lacey WA 98503-1128

Charles E. Peace, Executive Director

Telephone: (360) 438-8768 or 1-800-422-5623

Fax: (360) 491-6308; E-mail: [email protected]

Internet: http://www.wln.com/~oapca

2. Department of Ecology Northwest Regional Office(San Juan County)

3190-160th Avenue SE,

Bellevue, WA 98008-5452

Telephone: (425) 649-7000

Fax: (425) 649-7098, TDD: (425) 649-4259

3. Northwest Air Pollution Authority(Island, Skagit, Whatcom Counties)

1600 South Second Street

Mount Vernon, WA 98273-5202

Terry Nyman, Air Pollution Control Officer

Telephone: (360) 428-1617

Telephone: 1-800-622-4627 (Island & Whatcom)


Internet: http://www.nwair.org

4. Puget Sound Clean Air Agency(King, Kitsap, Pierce, Snohomish Counties)

110 Union Street, Suite 500

Seattle, WA 98101-2038

Dennis J. McLerran, Air Pollution Control Officer

Telephone: (206) 343-8800 or 1-800-552-3565

1-800-595-4341 (Burn Ban Recording)


Internet: http://www.psapca.org

5. Southwest Air Pollution Control Authority(Clark, Cowlitz, Lewis, Skamania, Wahkiakum

Counties)

1308 NE 134th Street

Vancouver, WA 98685-2747

Robert D. Elliott, Executive Director

Telephone: (360) 574-3058 or 1-800-633-0709


Internet: http://www.swapca.org

6. Department of Ecology Central Regional Office(Chelan, Douglas, Kittitas, Klickitat, Okanogan Counties)

15 West Yakima Avenue, Suite #200

Yakima, WA 98902-3401

Telephone: (509) 575-2490

Fax: (509) 575-2809, TDD: (509) 454-7673

7. Yakima Regional Clean Air Authority6 South 2nd Street, Room 1016

Yakima, WA 98901

Les Ornelas, Director

Telephone: (509) 574-1410 or 1-800-540-6950


8. Department of Ecology Eastern Regional Office(Adams, Asotin, Columbia, Ferry, Franklin, Garfield, Grant,

Lincoln, Pend Oreille, Stevens, Walla Walla, Whitman

Counties)

4601 N. Monroe Street, Suite 202

Spokane, WA 99205-1295

Telephone: (509) 456-2926

Fax: (509) 456-6175, TDD: (509) 458-2055

9. Spokane County Air Pollution Control Authority1101 West College Ave, Suite 403

Spokane, WA 99201

Eric Skelton, Director

Telephone: (509) 477-4727


Internet: http://www.scapca.org

10. Benton Clean Air Authority650 George Washington Way, Richland, WA 99352

Dave Lauer, Director

Telephone: (509) 943-3396

Fax: (509) 943-0505 or 943-2232; E-mail: [email protected]

Telephone: (509) 946-4489 (Burn Ban Recording)

Internet: http://www.bcaa.net

Other Sources of Information about Air Pollution in Washington State

Washington State Department of EcologyAir Quality Program

PO Box 47600, Olympia, WA 98504-7600

Telephone: (360) 407-6800

Fax: (360) 407-6802, TDD: (360) 407-6006

Internet: http://www.wa.gov/ecology/air/airhome.html

Pulp Mills, Aluminum SmeltersDepartment of Ecology - Industrial Section

PO Box 47600, Olympia, WA 98504-7600

Telephone: (360) 407-6916

Fax: (360) 407-6902

Department of Ecology Southwest Regional OfficePO Box 47775

APPENDIX F 41

Appendix F:Appendix F:Appendix F:Appendix F:Appendix F:

Hazardous Waste and Toxics Reduction Program 1

S A F E W A S T E M A N A G E M E N T

Technical Information Memorandum Publication Number 96-412Revised May, 1999

Treatment by Generator

PurposeThis Technical Information Memorandum contains treatment by generator

(TBG) guidance on how generators may treat their own dangerous waste(s)on-site, in accumulation tanks or containers, without a dangerous wastetreatment permit. This document replaces Technical Information Memoran-dum, #86-3, Revised July 1993.

Section One explains previous guidance for treatment by generator. Sec-tion Two provides information on treatment by generator background. Sec-tion Three describes the guidance that generators can now use to proceedwith treatment by generator. Section Four provides general standards (in-cluding definitions) that apply to all generators performing treatment bygenerator. These sections are followed by a list of Ecology contacts.

Section One: Previous GuidanceEcology first provided guidance on treatment by generator in TIM 86-3,

dated September 22, 1986. The initial guidance, while useful, also generatedquestions on treatment by generator. These questions showed a need foradditional guidance and clarity on the subject. This is particularly apparentwhen Ecology and the generator must decide between on-site treatment typesor processes, versus off-site treatments or processes at a permitted treatment,storage, or disposal facility (TSD) or a recycling facility.

This revised TIM offers the following benefits for generators:

� more options for utilizing treatment by generator;

� less coordination with Ecology, since case-by-case approval is no longerrequired; and

� better guidance on how to properly treat hazardous waste so that humanhealth and the environment are protected.

The Department of Ecology actively promotes treatment by generatoroptions for several reasons. The Hazardous Waste Management Act (RCW70.105.150) lists a waste management hierarchy where treatment is preferred


Technical Information Memorandum 96-412: Treatment by Generator2

over disposal of waste. By encouraging proper on-site treatment, Ecologyis working towards the goals of that hierarchy. It should be noted thatwaste reduction is the ultimate goal.

The Washington State Hazardous Waste Plan (January, 1992) recom-mends a “close to home” policy. The goal of this policy is “self-sufficiencyon the part of individual generators and TSDs, the state as a whole, and thePacific Northwest region.” Part 2.3 of the Plan states that “The managementof wastes on-site should be more actively promoted, to the extent this isenvironmentally desirable and economically feasible. If other environmen-tal factors are equal, on-site or local management is preferred because itminimizes transportation risks, limits the transfer of risk to other communi-ties, and results in the application of appropriate, waste-specific technolo-gies.”

Lastly, the Ecology Regulatory Impediment Study (February, 1993) foundthat treatment by generator “is not being used to full advantage.” Thestudy states that rules governing treatment by generator lack clear author-ity, are not self-implementing, and do not describe treatment by generatoradministrative procedures. This revised TIM solves those problems.

This guidance document is to be used in conjunction with the stateDangerous Waste Regulations, Chapter 173-303 WAC, which were amendedin 1993 to clarify generator treatment.

Section Two: Treatment by Generator BackgroundCurrently, generator treatment of hazardous wastes is not directly

addressed in the federal hazardous waste regulations. However, the stateDangerous Waste Regulations were amended in 1993 to address treatment bygenerator at WAC 173-303-170(3)(b). EPA provided their treatment bygenerator interpretation in a Federal Register preamble statement on March24, 1986.

The position set forth in that preamble, 51 FR 10168, reads as follows:“Of course, no permitting would be required if a generatorchooses to treat their hazardous waste in the generator’s accu-mulation tanks or containers in conformance with the require-ments of subsection 262.34 and Subparts J or I of Part 265.Nothing in subsection 262.34 precludes a generator from treat-ing waste when it is in an accumulation tank or container cov-ered by that provision. Under the existing Subtitle C system,EPA has established standards for tanks and containers whichapply to both the storage and treatment of hazardous waste.These requirements are designed to ensure that the integrity ofthe tank or container is not breached. Thus, the same standardsapply to a tank or a container, regardless of whether treatmentor storage is occurring.Since the same standards apply to treatment in tanks as appliesto storage in tanks, and since EPA allows for limited on-site

APPENDIX F 43


storage without the need for a permit or interim status (90 daysfor over 1000 kg/mo generators and 180/270 days for 100-1000kg/mo generators), the Agency believes that treatment inaccumulation tanks or containers is permissible under theexisting rules, provided the tanks or containers are operatedstrictly in compliance with all applicable standards. Therefore,generators of 100-1000 kg/mo are not required to obtain in-terim status and a RCRA permit if the only on-site managementwhich they perform is treatment in an accumulation tank orcontainer that is exempt from permitting during periods ofaccumulation (180 or 270 days).”

Early guidance from the EPA confirmed that treatment by generatorapplies to all generators who accumulate waste in compliance with 40 CFR262.34 (WAC 173-303-200 and -201). By deduction, therefore, it does notapply to Conditionally Exempt Small Quantity Generators (CESQGs), whoare referred to as Small Quantity Generators (SQGs) in this state. However,Ecology believes that treatment by generator is an appropriate manage-ment technique for SQGs and encourages SQGs to manage hazardouswastes by an appropriate treatment by generator method according to thisguidance and all applicable local requirements (if any).

There are some restrictions on the type of wastes that may be treated,and what treatment methods are allowed. For example, detonation andopen burning are not considered treatment by generator since they arerecognized as a method of disposal, that is not allowed under 40 CFRSection 262.34. Treatment by generator in ways other than in tanks orcontainers (for example, by incineration, open burning, land treatment, ortreatment in surface impoundments) still requires a TSD facility permit (forexception, see “Solid State-Only Dangerous Wastes Treated in Units OtherThan Tanks or Containers”).

Section Three: Treatment Specific GuidanceEcology encourages treatment by generator when waste reduction

possibilities have been exhausted, under certain conditions. A generatorconducting treatment by generator does not need to obtain a TSD permit,or comply with interim status requirements. The following guidance doesnot apply to generators recycling materials on-site. This is because thereclamation process itself is generally exempt from treatment by generatoror treatment permitting requirements.

By following the guidance in this TIM, the generator may use a specificwaste treatment method, a treatment method that is not one of the specificFact Sheet options, or treat a solid state-only waste in a unit other than atank or container, without Ecology review, written approval or a permit.However, the department may determine, on a case-by-case basis, thatspecific waste management practices pose a threat to public health or the



environment. If this occurs, Ecology may require the generator to stoptreatment and/or apply for a treatment permit. In rare circumstances agenerator may need to enter into a consent order, which is a written agree-ment, with Ecology to proceed with a specific treatment process.

This TIM describes the self-implementing guidance which is as follows:

Fact SheetsEcology believes that many generators may be able to treat their own

wastes on-site, in containers or tanks, by using guidance contained in FocusSheets that discuss specific types of treatment. The treatment may beperformed by a person other than the generator (e.g., a contractor with amobile treatment unit); however, it must be done at the site where thewaste is generated. In addition to the guidance found in the appropriateFocus Sheet (and for treatment methods that are not one of the specificoptions), the standards in Section Four of this TIM apply and the ruleamendment at WAC 173-303-170(3).

The Fact Sheets are self-implementing tools that generators can use forspecific treatment methods. The following treatment methods are coveredby six separate Fact Sheets:

Filtration Carbon adsorptionSeparation Elementary neutralizationEvaporation Solidification

These types of treatment must be performed in the generator’s danger-ous waste accumulation tank or container (see definitions below). Multi-stage, multi-vessel treatment (for example, treatment using more than oneprocess in a series of vessels) is allowed.

Solid State-only Dangerous Wastes Treated in Units other than Tanksor Containers

Treatment of solid state-only wastes (e.g., salt cake) may be performedin units other than tanks or containers. Such wastes must not contain freeliquids as determined by the Paint Filter Liquids Test, Method 9095 of theEPA Publication Number SW-846, prior to treatment. In this situation, thestate is not constrained by the federal regulations, since the wastes are notregulated under RCRA. For the same reason, Ecology is not constrained byEPA guidance (i.e., preamble language) for such wastes. However, Ecologyencourages generators to use units other than tanks or containers as a “lastresort” and after the option of using a tank or container has been thor-oughly examined.

Generators may treat solid state-only dangerous waste in units otherthan tanks or containers, provided it is completed within the applicableaccumulation time frame (either 90 or 180 days). The treatment unit mustbe designed, constructed and operated in a manner that prevents a releaseof waste and waste constituents. The treatment must not adversely affectthe health of employees or the public. In addition, excessive noise is not

APPENDIX F 45


allowed. Negative aesthetic impact on the use of adjacent property must beprevented. Lastly, inspections must be routinely performed and repairsconducted promptly.

Section Four: Standards that Apply to All GeneratorsPerforming Treatment by Generator

The following standards apply to all generators who wish to performtreatment by generator, except small quantity generators [SQGs; see WAC173-303-070(8)].

SQGs are encouraged to follow the General Performance and SafetyStandards (see below), Ecology’s recommended best management prac-tices, any other standards contained herein that protect human health andthe environment, and all applicable local regulations. Any situation thatposes an actual or potential threat to public health or the environment mayaffect the conditional exemption of a SQG and cause them to become fullyregulated under Chapter 173-303 WAC. Also, see below for applicability oftreatment by generator at TSDs.

Some of these standards will not be relevant to the particular treatmentby generator situation. For example, tank standards will not apply forthose treating in containers only; cleanup standards will only apply if thereis a release to the environment.

Accumulation Time Limit StandardsThe tank or container in which the treatment occurs must be appropri-

ately marked with the date the accumulation period began. It must beemptied every 90 days (or 180 days for generators of 220-2200 lb/mo) andoperated in compliance with certain portions of WAC 173-303-630 andWAC 173-303-640. There is no accumulation time limit for wastes beingappropriately accumulated at satellite accumulation areas prior to treat-ment as long as the volume limit for satellite areas is not exceeded.

Exceeding the 90 (or 180) day limit constitutes storage which requires astorage permit. Any residues removed from a 90-day treatment unit re-main subject to the 90-day accumulation time limit of the original wasteplaced in the unit. This means that a new 90-day limit does not begin forthe residue when it is removed from a 90-day unit. The time limits alsoapply for multistage, multi-vessel processes.

Tank Definitions and Standards“Tank” means a stationary device designed to contain an accumulation

of dangerous waste, and which is constructed primarily of non-earthenmaterials to provide structural support (see WAC 173-303-040). It is not tobe confused with, and is not the same as a surface impoundment, wastepile or containment building.



“Tank system” means a dangerous waste storage or treatment tank andits associated ancillary equipment and containment system (see WAC173-303-040).

The following requirements for generators with accumulation tanksapply to treatment by generator processes in tanks (for generators of be-tween 220 and 2200 pounds per month, the tank management standards inWAC 173-303-202 apply, instead):

1) WAC 173-303-640 sets treatment standards for tanks. Gen-erators should pay special attention to the limitations of WAC173-303-640(3),(9),(10), and (11). According to WAC173-303-200, if the waste is placed in tanks, the generator mustcomply with WAC 173-303-640 (2) through (10) except for WAC173-303-640 (8)(c) and the second sentence of WAC 173-303-640(8)(a) (closure plan, cost estimate for closure, financial responsi-bility).

2) Owners or operators of new tank systems or componentsmust obtain a written assessment. The assessment must bereviewed and certified by an independent, qualified registeredprofessional engineer, attesting that the tank system has suffi-cient structural integrity and is acceptable for the treatment ofdangerous waste. The assessment must show that the founda-tion, structural support, seams, connections, and pressurecontrols (if applicable) are adequately designed and that thetank system has sufficient structural strength, compatibilitywith the waste(s) to be treated, and corrosion protection toensure that it will not collapse, rupture, or fail. Existing accu-mulation tanks that will be used for treatment will need to bereassessed if the proposed treatment will place stresses on thetank beyond what it was certified for, or if a major modificationis performed. Also, in such cases the integrity assessmentschedule may need to be modified.

Container Definition and Standards“Container” means any portable device in which a material is stored,

transported, treated, disposed of, or otherwise handled (see WAC 173-303-040).

The following requirements for generators with accumulation contain-ers also apply to treatment by generator in containers:

1) The generator must comply with all applicable parts of WAC173-303-630, Use and Management of Containers, as referencedin WAC 173-303-200 or -201.

2) Generators must ensure that containers have sufficientstructural integrity and are acceptable for the treatment of

APPENDIX F 47


dangerous waste. This determination is based on applicablefactors such as the container composition, structural support,type of cover, seam strength, etc. The container must be com-patible with the waste(s) to be treated such that it will notcorrode, collapse, rupture, or otherwise fail to contain thedangerous waste during treatment.

General Performance and Safety StandardsThe performance standards of WAC 173-303-283 (3) apply to all genera-

tors who treat their waste on-site.In addition, whenever any generator chooses treatment by generator as

a waste management option the treatment process may not, under anycircumstances:

(1) Generate extreme heat or pressure, fire or explosion, orviolent reaction;

(2) Produce uncontrolled toxic mists, fumes, dusts, or gases insufficient quantities to threaten human health or the environ-ment;

(3) Produce uncontrolled flammable fumes or gases in suffi-cient quantities to pose a risk of fire or explosions;

(4) Damage the structural integrity of the facility or devicecontaining the waste; or

(5) Through other similar means, threaten human health or theenvironment.

Reporting Standards and RecordkeepingNotification on Form 2, and Annual Reporting on Ecology’s Dangerous

Waste Annual Report Forms is required. Notification requirements arefound in WAC 173-303-060 and the reporting requirements are in WAC173-303-220. When notifying on the Form 2, generators must complete theform by following the instructions and note in the comment section:

(1) Whether the process is treatment by generator.

(2) Whether the treatment is a multistage and/or multi-vesselprocess.

(3) Whether it is being done in accordance with a specific FactSheet (or if not, that the TIM and applicable rules are beingfollowed).



The Form 2 must be submitted prior to beginning the treatment process.If the generator already has a RCRA ID#, a revised Form 2 must be submit-ted. Those generators that have received written Ecology approval fortreatment by generator prior to the date of this revised TIM are also re-quired to submit a Form 2.

For annual reporting and generator status determinations, the totalquantity (as wet weight) of waste generated prior to treatment and theweight of any remaining material that designates after treatment, must becounted.

The waste prior to treatment and residuals (material remaining after theprocess) must be designated and managed appropriately. Also, the “de-rived from” rule [see WAC 173-303-070(2)] applies for listed wastes.

Generators must maintain a written log of the quantity of each danger-ous waste managed on-site, the treatment methods, and dates of treatment.

Personnel Training, Preparedness and Prevention,Contingency Plan and Emergency Procedures, andEmergencies

Generators who treat on-site must meet the requirements for facilityoperators contained in WAC 173-303-330 through 173-303-360. In lieu ofthe contingency plan and emergency procedures required by WAC173-303-350 and 173-303-360, if a person generates between 220 pounds(100 kg) and less than 2200 pounds (1000 kg) per month and does notaccumulate on-site more than 2200 pounds (1000 kg) of dangerous waste,the reduced standards in 173-303-201(2)(c) apply.

Cleanup StandardsCleanup of releases at generator sites must include any releases of

hazardous waste that pose a threat to human health and the environment.Such cleanups are covered under the “imminent hazard” provisions ofRCRA Section 7003, WAC 173-303-050 and -145.

Closure StandardsClosure of 90/180 day generator accumulation units must be done in

accordance with applicable closure (and post-closure, if necessary) perfor-mance standards.

For tanks, the closure requirements are found in WAC 173-303-640(8),except for (8)(c) and the second sentence of (8)(a). Containers must beclosed in accordance with 40 CFR 265.111 and 265.114. These activities mayinclude removal of waste residues with proper disposal and/or decontami-nation of equipment, structures and soils. Requirements for a closure plan,closure activities, cost estimates for closure, and financial responsibilityspecified in WAC 173-303-610 and 173-303-620 do not apply. The closurestandards for generators of between 220 (100 kg) and 2200 pounds (1000kg) per month who treat their dangerous waste in tanks must comply withthe closure standards in WAC 173-303-202(4).

APPENDIX F 49


TSD StandardsTSDs that treat dangerous waste received from off-site may not treat

that waste or any waste(s) derived from it according to the treatment bygenerator provisions. Generators that treat only their own dangerouswaste on-site in tanks or containers (or other unit if solid state-only waste)and who have obtained interim status, a full permit, or have a Part B appli-cation pending may find it preferable to use treatment by generator ratherthan continue with the TSD permit process. Such facilities will need tocomply with withdrawal of permit and/or closure requirements.

Land Disposal Restriction StandardsFederal land disposal restriction (LDR) requirements (40 CFR 268 which

is incorporated by reference at WAC 173-303-140(2)(a)) apply. The genera-tor must develop a Waste Analysis Plan (WAP) for on-site treatment intanks or containers not subject to permit requirements (i.e., Treatment byGenerator) if the treatment is for the purpose of meeting the LDR standardsor to make the waste nonhazardous. Compliance with the treatment stan-dards for ignitable and corrosive wastes requires that hazardous constitu-ents “reasonably expected to be present” in the waste be treated to speci-fied standards. The WAP must be maintained as a facility record and filedwith Ecology 30 days prior to beginning the treatment activity.

Permit-by-Rule StandardsThe permit-by-rule (defined at WAC 173-303-040) provisions of WAC

173-303-802(5) may apply in cases that would seem to qualify as treatmentby generator. For example, a generator may treat wastes in a wastewatertreatment unit, elementary neutralization unit or totally enclosed treatmentfacility, thereby discharging a wastewater. When this occurs, the permit byrule regulatory provisions in WAC 173-303-802(5) apply instead of thetreatment by generator rules and guidance.

Future Changes and Additional InformationShould EPA or Ecology later decide to modify the accumulation rules or

specific standards for treatment in tanks or containers, the generator re-quirements may change.

For more information on treatment by generator options, contact ahazardous waste specialist at the appropriate phone number providedbelow, or the Hazardous Waste Technical Assistance and Policy Section at(360) 407-6700.

Northwest Region 425-649-7000 Southwest Region 360-407-6300Central Region 509-575-2490 Eastern Region 509-456-2926Industrial Section 360-407-6916 Nuclear Waste 360-407-7100

Ecology is anequal opportunityagency. If youhave specialaccommodationneeds, or requirethis document inan alternateformat, pleasecall theHazardous Wasteand ToxicsReductionProgram at (360)407-6700 (Voice)or (360) 407-6006(TDD).


Appendix G: RAppendix G: RAppendix G: RAppendix G: RAppendix G: Resouresouresouresouresourcescescescesces

The Organization Resources Counselorsand the Metalworking Fluid Stewardship haveco-published a report titled “Metal RemovalFluids: A Guide to their Management andControl.” This report is an excellent resource forany company using metal working fluids. A freeof this report can be downloaded at http://www.mwfpsg.org/.

The Institute of Advanced ManufacturingSciences (IAMs) has done substantial work withthe metal machining industry sector. Currentlythey are working on developing a test method tocompare metal working fluids. For more infor-mation visit their website at http://www.iams.org.

Another good source for information aboutmetal fabrication can be found on the PacificNorthwest Pollution Prevention ResourceCenter’s website. Their web address is http://pprc.pnl.gov/pprc/.

Material Safety Data Sheets (MSDS) andChlorinated Compounds

MSDS sheets are a good starting pointwhen trying to find out if a metal working fluid(MWF) contains chlorine. However, not allchlorinated compounds are required to be listedon a MSDS sheet. Therefore it cannot be as-sumed that chlorinated compounds are notpresent in the MWF merely because they aren’tlisted in the MSDS. In order to be certain thatthe MWF is chlorine free, you need to call themanufacturer or supplier. Ask for written docu-mentation that verifies that there are no chlori-nated compounds in the MWF.

There are two parts of an MSDS sheet thatmay contain information about chlorinatedcompounds. Below is some general guidanceabout MSDS sheets. Please note that all MSDSsheets are NOT in the same format.

1. First, find Section 2 of the MSDS. Thissection is sometimes titled “Product Composition,Hazardous Ingredients Information, or HazardIdentification.” Look through the ingredients listfor the words “Cl, chloro, chlorine, or chlori-nated.” If it contains any of these words then theMWF contains chlorinated compounds.

2. If chlorinated compounds have not beenfound in Section 2, next look in Sections 4 or 5,which are usually titled “Fire and ExplosionHazard Data” or “Reactivity Data.” Find the lineitems titled “Hazardous Decomposition Productsor By Products.” Look for any chlorinatedcompounds in the list. Some examples includehydrochloric acid (HCl) or oxides of chlorine.

APPENDIX H 51

Appendix H: BibAppendix H: BibAppendix H: BibAppendix H: BibAppendix H: Bibliogliogliogliogliogrrrrraaaaaphyphyphyphyphy

Byers, Jerry P. (editor), Metal Working Fluids, Marcel Dekker, Inc., NY,NY, 1994

Elliot S. Nachtman, Serope Kalpakjian, Lubricants and Lubrication in Metalworking Operations, Marcel Dekker,Inc., NY 1985

Davis, JR (editor), ASM Materials Engineering Dictionary, materials Information Source ASM International,Metals Park, OH, 1992

Todd, Robert H., Allen, Dell K., Manufacturing Processes reference Guide, Industrial Press Inc., NY, NY, 1994

Metal Removal Fluids-A Guide to their Management and Control, Organization Rescources Counselors, Inc.,1997

Waste Minimization and Wastewater Treatment of Metalworking Fluids, Research and Development Committee,Independent Lubricant Manufacturers Assoc., Alexandria, VA. 1990

Bennet, E. O., ASLE, The Biology of Metalworking Fluids, Journal of the American Society of LubricationEngineers, May 1972, Volume 28.

Guides to Pollution Prevention: The Fabricated Metal Products Industry, EPA, EPA /Office of R&D, WashingtonD.C., 1990

Guides to Pollution Prevention: The Metal Finishing industry, EPA, EPA/Office of R&D, Washington D.C., 1992

Metal Working Fluids: A Resource for Employers and Health & Safety Personnel in Washington State, Washing-ton State Labor & Industries SHARP, WA Oct. 1997

Successful Coolant management in Metalworking, University of Tennessee Center for Industrial Services, work-shop notes 1993

Kennedy, Judy, Andy Sutedja, Background Document and Technical Assistance Strategy for the Metal Fabrica-tion Industry, Washington State Department of Ecology, HWTR, Dec. 1993

Cutting Fluid Management in Small Machine Shop Operations, Iowa Waste Reduction Center, University ofNorthern Iowa, Aug. 1990

Pollution Prevention Options in Metal Fabricated Products Industries, US EPA, Office of Pollution Preventionand Toxics, Cincinnati OH, Jan. 1992

Bierma, Thomas, Francis Waterstraat, Promoting P2 Among Small Metal Products Fabricators, Pollution Preven-tion Review, Autumn 1995, p. 27-39

NIOSH, Occupational Exposure to Metalworking Fluids, US Department of Health & Human Services, Jan. 1998

NIOSH, What You Need to Know About: Occupational Exposure to Metalworking Fluids, US Department ofHealth & Human Services, Mar. 1998

Documents

A Pollution Prevention Assessment and Guidance · A Pollution Prevention Assessment and Guidance Washington State Department of Ecology Hazardous Waste and Toxics Reduction Program