An Analysis of Pollution Prevention Opportunities and Impediments in the Transportation Equipment Manufacturing Sector in Georgia

Table of Contents

• Introduction
• Methodology
• Summary
• Aircraft Pollution Prevention Workshop
• Common Sense Initiative – Automobile Manufacturing
• Profile of the Transportation Equipment Manufacturing Sector in Georgia
• Transportation Equipment Manufacturing Processes
• Waste Streams and Generation Characteristics of Georgia’s Transportation Equipment Manufacturers
• Pollution Prevention in the Transportation Equipment Manufacturing Industry – Barriers, Assistance, and Waste Reduction
• Key Pollution Prevention Issues
  • Limited In-House Resources
  • Waste and Air Emissions from Painting Operations
  • Waste and Air Emissions from Metal Cleaning Operations
  • Waste and Air Emissions from Aircraft Paint Removal
  • Waste Generated by Metal Plating Processes
• Pollution Prevention Assistance Needs of the Transportation Equipment Manufacturing Sector
• Meeting Organizational and Technical Needs
• References for More Information on Pollution Prevention
• Summary and Conclusions
• Appendix I — Survey Form
• Appendix II — Pollution Prevention Successes – Biennial Report
• Appendix III — Pollution Prevention Impediments – Biennial Report
• Appendix IV — Identifying Pollution Prevention Assistance Opportunities

Introduction

The purpose of this report is to identify specific causes of waste generation and cost-effective solutions that will reduce waste in the transportation equipment manufacturing sector in Georgia. The benefits of reducing waste can be reduced pollution and decreased operating costs to business. Releases of high-priority toxic chemicals are the primary focus of this report, but other significant waste streams will be included. Often, there are barriers that limit the implementation of pollution prevention projects and technologies. Barriers and strategies to overcome them will also be discussed in this report.

Methodology

The Georgia Manufacturing Directory was used to determine the demographics of the transportation equipment manufacturing sector in the state. A survey of the manufacturers was undertaken in 1995 to enhance existing literature on pollution prevention in this industry. To expedite completion of the survey questionnaire, the fabricated metals products industry, Standard Industrial Classification (SIC) 34, and the transportation equipment manufacturing industry, SIC 37, were combined. A review of environmental publications and trade journals indicated that much of the wastes generated by these industries came from common processes, primarily cleaning, surface preparation , and finishing operations. Within each of the these sectors, not all SIC sub-sectors were surveyed. Only those meeting the following requirements were selected:

• Sectors producing significant toxic and hazardous wastes based on Toxic Release Inventory (TRI) reports and biennial report data
• Sectors represented by a significant number of manufacturers in Georgia
• In SIC 37, the aircraft/airline industry was not surveyed due to P²AD’s previous in-depth exposure in this industry. Boat manufacturers were also excluded and will be addressed under the rubber and plastic miscellaneous products sector based on the similarity of materials and processes.

Review of existing environmental databases and literature combined with a survey of Georgia manufacturers was chosen to identify industry problems and solutions that are most significant in the state. The survey also documented processes employed, waste reduction activity, sources of waste reduction assistance, and barriers to pollution prevention encountered by these businesses. The survey, selection of manufacturers to participate in the survey, and survey results were prepared by Georgia State University, School of Urban Studies. A copy of the survey is located in Appendix I. One hundred manufacturers were surveyed representing 9.8% of the 1014 Georgia manufacturers in the two sectors. Follow-up phone calls and plant visits were made to manufacturers and Biennial Reports Hazardous Waste Reduction Plans were reviewed to obtain added detail. The results of the study are provided in this document.

Summary

The following key issues were identified as a result of this study through the survey contacts with transportation equipment manufacturers. This data was supplemented by reviewing biennial reports, TRI data, and various trade/environmental publications.

• Limited in-house resources to address pollution prevention problems
• Waste and air emissions generated by painting operations
• Hazardous emissions and waste streams from metal cleaning and degreasing
• Waste and air emissions generated by aircraft paint removal
• Waste from metal plating processes

The Georgia Pollution Prevention Assistance Division (P²AD) will assist Georgia transportation equipment manufacturers in addressing these key issues by developing programs, identifying information resources, and assisting companies with technical and organizational issues. The approach that P²AD will take is to identify existing resources that address organizational, technical, and research needs. Georgia transportation equipment manufacturers can benefit by developing pollution prevention programs, which can result in significant waste and cost reductions. P²AD can help manufacturers in developing P2 programs, providing information on new technology, coordinating technology demonstrations, and providing on-site assistance. Through P²AD’s assistance, companies can be helped in meeting their organizational and technical needs in reducing wastes and becoming more competitive in the market place.

Aircraft Pollution Prevention Workshop – October 5, 1994

Prior to conducting the transportation equipment manufacturing sector analysis, a workshop was held to address pollution prevention issues that affect businesses in the aircraft industry throughout Georgia.¹ The workshop, sponsored by P²AD and hosted by Delta Airlines, was attended by 70 representatives from 25 companies and military installations. Key issues discussed during the one day workshop included the use of handwipe solvents, spot cleaning/avionic maintenance, and low VOC painting/paint stripping technologies. Presentations were also made covering Boeing’s corporate pollution prevention program and Lockheed’s materials management/inventory control system.

Problems were identified with finding alternative environmentally friendly solvents for handwipe, spot, and avionics maintenance cleaning. Several solutions were offered ranging from the use of simple hydrocarbon solvents to operation changes reducing or eliminating the need to clean. Discussions on painting/paint stripping identified a wide range of problems. The application of new low-VOC paint may require new equipment, tighter control of the painting environment, and operator training. Hazardous strippers containing methylene chloride are still widely used to remove paint from entire airframes. However, alternate methods are being tried that include alkaline and acidic-base strippers and mechanical blasting using a variety of media (plastic pellets, wheat starch, baking soda, and dry ice). Options for depainting aircraft are covered in detail later on in this paper.

Attendance at the workshop represented a broad cross section of the aircraft/airline industry. The presentations were informative and the participation in group discussions was active. The exchange of information and suggestions during the one day workshop will assist the participants in their pollution prevention efforts.

1. Hatcher, Jancie, From the Source, Georgia Pollution Prevention Assistance Division – Fall 1994

EPA’s Common Sense Initiative – Automobile Manufacturing Sector

In 1994 the U.S. Environmental Protection Agency introduced the Common Sense Initiative (CSI) in an effort to bring industry, government, and environmental groups together to find a better way to protect the environment that all parties can live with.² The six industries selected for CSI were iron and steel, electronics and computers, metal plating and finishing, printing, oil refining, and automobile manufacturing. Collectively these industries reported one-eighth of the total toxic substances released nationwide in 1992. Also, these sectors include many of the Georgia industry sectors being analyzed by P²AD.

Because pollution prevention is one of the central ethics of CSI and Georgia has a large presence of automobile manufacturing, Bob Kerr, Director of P²AD, was selected to represent the state on the CSI Automotive Manufacturing Sector Team. The team is considering the following issues:

• Regulations – Review regulations to identify opportunities for improvement having cost benefits.
• Pollution Prevention– Promote pollution prevention as a standard business practice.
• Reporting – Make it easier to distribute, access, and use environmental information
• Compliance – Develop a system to assist companies that want to comply and/or exceed requirements while enforcing the law against those that don’t.
• Permitting – Improve permitting so it is more efficient, promotes innovation, and gives the public more opportunity to participate.
• Environmental Technology– Structure regulations to give industry incentives and flexibility to develop new technologies to meet or exceed standards.

The Alternative Regulatory System Project Team, whose objective is to find ways to make the regulatory system work more efficiently and give companies more flexibility in meeting regulations, has scheduled a pilot project for late in 1996. The location selected for the pilot project is Louisville, Kentucky with Ford Motor Company as the participating facility. The idea of the project is to have Ford and the community work together to set objectives to meet the goals of all stake holders. This is a project that has the potential to have a win-win outcome for industry and the community.

2. Kerr, Robert, Director P²AD, From the Source, Georgia Pollution Prevention Assistance Division – Winter 1994/95

Profile of Transportation Manufacturing Sector in Georgia

The primary businesses of the transportation equipment manufacturers within the Standard Industrial Classification (SIC) code 3700 are listed in Table 1. While the products are diverse, ranging from bicycle wheels to aircraft, the businesses use similar processes and materials. Operations such as cleaning, painting, and coating, which are common to these businesses, are likely to result in the release of high-priority chemicals to the environment. The Georgia boat manufacturers are not included in this sector, but will be grouped with the miscellaneous plastics products industry sector due to their comparable processes and materials.

Table 1

Primary Businesses of the Transportation Equipment Manufacturers

nec – not otherwise classified

According to the Georgia Manufacturing Directory there are 207 transportation equipment manufacturers spread throughout 71 Georgia counties employing over 38,000 workers. The work force for these companies ranges between 1 and 4,000, with the exception of one facility having 11,000 employees. While there are some large transportation equipment manufacturers in Georgia, 68 percent of the facilities have a work force of less than 50 employees. Table 2 lists the number of facilities and employees by county.

Table 2

Transportation Equipment Manufacturing Sector SIC 3700

Number of Facilities and Employees by County and Region

The Metropolitan Atlanta Area consists of thirteen ozone non-attainment counties, eleven of which are home to 70 companies representing over 34% of Georgia’s transportation equipment manufacturers. While these companies employ over 19,000 workers, an aircraft manufacturer in Cobb County accounts for the majority of the work force with 11,000 employees. Eighty-three percent of the transportation equipment manufacturers located in the Atlanta metropolitan area have 50 or less employees. The Atlanta metropolitan counties with the number of facilities and employees are highlighted in Table 2.

Southeastern Georgia transportation equipment manufacturers classified within SIC code 37 have 25 facilities in 10 counties with a cumulative employment of 6,226 workers. The southeastern facilities account for 12 percent of the Georgia’s transportation equipment manufacturers representing 16 percent of the employment. Seventeen of the facilities (68%) have less than 100 employees, but only account for 5 percent of the work force. Over half of these manufacturers produce motor vehicle parts and acessories. The others produce vans, air foils, truck and bus bodies, trailers, campers, and perform railroad equipment repair. The largest employer manufactures business jet airplanes with 3,700 workers. Seven other manufacturers, with 100 to 540 employees, produce aircraft parts and equipment, repair aircraft, rebuild heavy hauling trucks, remanufacture trucks, and manufacture golf carts.

Southwestern Georgia transportation equipment manufacturers are present in twenty-three counties with 54 facilities having a total work force of approximately 6,300 employees. These facilities represent 26 percent of Georgia’s transportation equipment manufacturers while employing only 16 percent of that work force. Thirty-nine of these facilities (72%) have less than 100 employees, but like the southeast manufacturers they only account for 15 percent of the employment. Approximately half of these facilities supply parts and equipment to either the automotive or aircraft industry, with an equal number of manufacturers supplying each. Most of the other smaller employers produce a variety of trailers, truck bodies, and vans. There are fifteen manufacturing facilities with 100 or more employees, employing a total of approximately 5,300 workers. Half of these manufacturers produce equipment and components for the aircraft industry and the other half for the automotive industry.

North Georgia transportation equipment manufacturers, excluding those in the Atlanta metropolitan counties, operate in 27 counties with 58 facilities employing approximately 6,200 workers. These facilities make up 28% of Georgia’s transportation equipment manufacturers with 16 percent of the employees. Nineteen of the facilities (33%) produce equipment and components for the automotive industry with an aggregate work force of 2,100 employees. The largest employer in north Georgia operates two bus body manufacturing facilities employing approximately 1,600 workers. There are 15 manufacturing facilities with 100 or more workers that employ a total of 5,400 employees. Facilities with less than 100 employees total 43, and employ 780 workers. The primary business of 29 of the small facilities is either automotive components, van conversions, or miscellaneous trailers.

Table 3 gives a breakdown of the number of transportation equipment manufacturers by size of work force for each region.

Table 3

Number of Transportation Equipment Manufacturers by Size of Work Force

Transportation Equipment Manufacturing Processes

Georgia’s transportation equipment industry consists of manufacturers that form, cast, machine, assemble, and finish coat primarily metal parts and assemblies. The end product of the industry is the manufacture or repair of any personal or commercial vehicle. The Georgia products include aircraft, automobiles, buses, trucks, bicycles, railroad cars, and a variety of recreational vehicles. Since common processes are used by the transportation equipment and fabricated metal industry sectors, the survey data was combined for analysis. Table 4 lists the common processes that result in the generation of toxic, hazardous, and non-hazardous wastes. The percentages shown represent the combined survey results from 100 companies, 21 of which are transportation equipment manufacturers.

Table 4

Transportation Equipment and Fabricated Metal Manufacturers Processes

Surface coating processes are used by 66% of the companies surveyed with 57% of the companies having painting operations. While solvent-based paint is used in the majority of the painting processes, 20% of the companies apply both solvent and water-based paints. Plating, anodizing, and oxide finishes are applied by 15% of the companies.

Surface preparation, according to the survey, is being performed by 52% of the companies. Degreasing operations, using both solvents and aqueous solutions, are used by 28% of those surveyed. The exclusive use of aqueous solution for degreasing was reported by 11% of the companies.

Fabrication, employing one or more of the types listed in Table 4, is performed by 94% of the surveyed companies. Assembly and welding are the major methods of fabrication with 63% of the companies doing both.

While the transportation equipment and the fabricated metal manufacturers use the same basic processes, the survey results showed differences in degree of application for coating and surface preparation operations. Solvent-based paint is applied 35% more by the transportation equipment manufacturers, with the metal fabrication companies having 14% more water-based painting operations. Surface preparation using mechanical processes and aqueous washing are dominant in the transportation equipment manufacturers with up to 40% using these methods. Each of the surface preparation methods listed in Table 4 are used by between 15% and 19% of the metal fabrication manufacturers. The most common processes reported by the transportation equipment and fabricated metal manufactures are listed below:

• Assembly 79%
• Welding 74%
• Solvent-based painting 47%
• Machining 44%
• Forming 40%
• Water-based painting 31%

Waste Streams and Generation Characteristics of Georgia’s Transportation Equipment Manufacturers

The 1993 Toxic Release Inventory (TRI) and the hazardous waste Large Quantity Generator (LQG) reports gives an approximation of the toxic releases and hazardous waste generation by Georgia manufacturers. This information is listed in Table 5 for the transportation equipment manufacturing sector.

Table 5

1993 TRI reports were submitted by 15% of the companies with 14% providing LQG reports. Some of the results from the analysis of TRI and LQG report data is listed below.

• 80% of the TRI submissions and 90% of the LQG reports were provided by companies with more than 100 employees.
• TRI releases reported by the transportation equipment manufacturers represented 10% of Georgia’s total for 1993 with 94% of the sector’s releases emitted to the air.
• TRI emissions and hazardous waste generated were primarily the result of painting, degreasing and cleaning operations.
• LQG and TRI reporters employ 79% of the 38,423 employees in the sector’s work force.

Criteria requiring a company to annually submit a TRI report include use of TRI chemicals above a threshold quantity and a work force of 10 or more employees. In 1993 the number of transportation equipment manufacturers with 10 or more employees totaled 138. However, only 31 companies filed TRI reports. This leaves 69 small companies using similar process and materials while generating lower levels of unaccounted quantities of TRI emissions. In addition to TRI releases companies with waste streams containing hazardous substances above threshold levels are required to report as Large Quantity Generators (LQG) regardless of work force size. Out of the 207 companies covered in this analysis 30 reported being LQG’s.

Toxic Releases

The 1993 releases of TRI chemicals, above 25,000 pounds, for the subject industry sector are listed in Figure 3. These chemical releases represent 98% of the total for that year. Paint solvents, xylene and toluene, accounted for 36% of the releases. Almost all of these solvents were generated by companies in SIC 3711 through 3715. These companies manufacture vehicles, trailers, and associated parts requiring the extensive use of paint. Solvents used in degreasing and cleaning operations represent the other main contributor to the TRI releases at 34%. Half of these come from the same manufacturers generating the paint solvents and the remaining half from the airline industry.

Figure 3

Survey of Georgia’s Transportation Equipment and Metal Fabrication Industry – Barriers, Assistance, and Waste Reduction

The following represents survey results from one hundred Georgia transportation equipment and metal fabrication companies in SIC codes 3700 and 3400. The survey asked the companies prepared questions concerning barriers to implementing pollution prevention, sources of pollution prevention assistance, and methods of waste reduction employed. Tables 6 through 8 give the percentage of responses by category.

Table 6

Barriers to Pollution Prevention