For well over four decades many of us have been drawing attention to the problems associated with traditional motor repair practices and their impact on operating costs, energy efficiency, reliability and other impacts on you, the user of the machines that can be subjected to some truly awful methods that have not changed in over a Century. Over the past year, it appears that attention is being brought to this issue by the US Department of Energy and US Environmental Protection Agency as well as environmental protection and energy lobbyists (industrial energy driven) and motor manufacturers due to the understanding of this impact. Several of us have been writing about this issue since the 1970s and many supporters, many in the motor repair industry in particular, have been ensuring that I receive information that I may miss. This is an exciting time to have returned after having fought for moving the motor repair industry out of the early 1900s methodologies that are still in practice today! The battles have been fast, furious, and on-going.
Things have been extremely busy this summer. With last summer and winter being mild and this season being much warmer, and that many companies are running to failure, it seems that one unplanned plant outage is being followed by the next. We have been firmly in the middle of such situations at Dreisilker from emergency repairs to field service support to even being contracted to oversee the repairs of machines at other motor repair shops. This started even the past two years resulting in such challenges as having to be extremely flexible (reactive) to customer requirements which has even had me cancel speaking engagements – not something that I enjoy doing. The good news is that observations on conditions and issues both support my past observations and are beginning to identify solutions, many of which I will be discussing in the future.
At this time, however, I get to discuss my ‘I told you so!’ experiences.
In a project I was involved in this year, I had to deal with an 8000 horsepower electric motor (actually, I have had to deal with a great many 8000 hp issues this year. I didn’t know there were so many!). In one case, it was communicated that the burnout (alternately the ‘burn-off’ process, or incinerator process) would have an impact of up to an increase of 50% in core losses by the equipment manufacturer IN HEAVILY CONTROLLED CONDITIONS with a core temperature not to exceed 670F (in new core steel)! As part of the review, we determined this would reduce the efficiency to 96.5% at full load costing an additional $22,000 per year and emitting an additional 123 Tons of CO2, alone, as well as other greenhouse gasses per year.
This condition came to mind after receiving multiple emails from associates in the motor repair industry concerning an Environmental Protection Agency (US EPA) announcement and information from the motor repair trade association to oppose, or “in vehement opposition” to the air quality, energy and environmental regulations. The document was released on Friday, June 4, 2010, for review and opposing remarks by the US EPA under 40 CFR Part 60 entitled “Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Commercial and Industrial Solid Waste Incineration Units; Proposed Rule,” where the US EPA emphasized that there would be less of an impact by the regulation on only 126 such burn-off ovens than land filling all such equipment for reconditioning. It was identified that the purpose for the opposition was that there are over 10,000 such units in the United States, alone, and that the average cost of compliance through modernizing equipment would be $146,777 per oven with an incremental annual cost of $88,861.
Not one mention of methods to reduce emissions, just opposition to altering operations to reduce emissions!
In the proposed letter to the US EPA that was sent to motor repair shop owners to oppose the rules, it even put in a bullet point to argue against alternate processes that have been proven in THIRD PARTY studies to not only maintain equipment condition with no increase in losses, but to also not be able to harm equipment EVEN WHEN OPERATED INCORRECTLY!! The process was also found to have virtually zero measureable emissions! (Cite: Canadian Electrical Association Motor Repair Study).
Yes folks, now for the details.
A few of the key points made by the US EPA proposed changes, which are being made because such equipment was held exempt for a number of reasons including lobbying. The US EPA has determined that such time is over and that these exemptions are having a direct impact on the environment. I will, of course, place a few editorial comments in between.
I suppose we should start with the US EPA’s question: “What are the primary sources of emissions and what are the emissions and current controls.” It is noted that most motors are put into burn-off ovens without contaminants, oils, greases, etc. removed from the windings:
“… and burn-off ovens that combust residual materials off racks, parts, drums or hooks so that those items can be reused in various production processes.”
“Combustion of solid waste causes the release of a wide array of air pollutants, some of which exist in the waste feed materials and are released unchanged during combustion and some of which are generated as a result of the combustion process itself. These pollutants include particulate matter (PM); materials including lead (Pb), cadmium (Cd) and mercury (Hg); toxic organics, including chlorinated dibenzo-p-dioxins/dibenxofurans (dioxin furans); carbon monoxide (CO); nitrogen oxides (Nox); and acid gasses, including hydrogen chloride (HCl) and sulfur dioxide (SO2).”
I would note that in the motor repair shops that I worked in and operated in Virginia in the early 1990s, the work areas had to be ‘clean’ due to the amount of particulate put out by the burn-off oven(s). In one case, the motor repair shop that I worked at in the low income area of Richmond, VA, would get complaints from the neighbors because of the amount of ash on their vehicles, gardens, windows, etc. This is one of the reasons I truly took up the torch for the method that I had and do use at Dreisilker Electric Motors and the forming of the Dreisilker R&D group.
Table: Findings and Average Existing Compared to Proposed Limits for Burn-off
Note: burn-off ovens were found to be some of the worst compared to such equipment as incinerators. Alternate repair processes DO EXIST.
Pollutants (Units) --- Existing --- Proposed
HCl (ppmv) --- 130 --- 18
CO (ppmv) --- 80 --- 74
Pb (mg/dscm) --- 0.041 --- 0.029
Cd (mg/dscm) --- 0.0045 --- 0.0032
Hg (mg/dscm) --- 0.014 --- 0.0033
PM Filterable (mg/dscm) --- 33 --- 28
Dioxin, furans, total (mg/dscm) --- 310 --- 0.011
Dioxin, furans, TEQ (mg/dscm) --- 25 --- 0.00086
NOx (ppmv) --- 120 --- 16
SO2 (ppmv) --- 11 --- 1.5
Opacity --- 2% --- 2%
(Opacity relating to the fact that you cannot see these gasses coming out of the stack. So, if you cannot see it, why the problem? Other than research that such emissions can trigger health problems including mercury and the other heavy metals and toxins being linked to the autism spectrum, cancer and other issues - http://www.autism-society.org/site/PageServer?pagename=research_envirohealth_faq).
The above units are considered on the high side of emissions as compared to the equipment that has been previously regulated and burn-off ovens rate on the high side of the equipment that was under review by the proposal and report (note that you can contact me directly at howard@motordoc.com for a copy of the US EPA proposal).
Because of the findings of the US EPA: “… the proposed revisions to the CISWI rule would remove the exemptions for: agricultural waste incinerators; cyclonic barrel burners; cement kilns; rack, part and drum reclamation units (ie: burn-off ovens).”
“Existing incinerators, burn-off ovens and small, remote incinerators would have annual emissions testing for opacity, HCl and PM.” (Minor compared to other requirements).
“We have determined that most facilities with units in the incinerators, small remote incinerators or burn-off ovens subcategories will choose to cease operations once the proposed MACT floor limits are promulgated and that all units in these three subcategories will cease combusting waste if beyond-the-floor levels are adopted.”
To paraphrase the lengthy discussion that follows, it is the intention that the proposed regulations would cause these groups to utilize alternate means. These do exist, from mechanical stripping to water blasting, and other methods that have been found not to harm equipment through independent studies. I have heard arguments that the alternate methods are ‘more labor intensive’ or ‘potentially harmful,’ I have even heard a reference to a non-third party reviewed UK motor repair study stating that “it proves that the alternate methods harms motors,” when, in fact, the alternate processes were NEVER REVIEWED in that study. Talk about misrepresentation!! The times to perform the mechanical methods are the exact same in labor as burn-off ovens AND they are far shorter in LINEAR HOURS meaning that the length of time to return a repair is reduced often by a whole DAY! In fact, Dreisilker, who uses a mechanical stripping method and is one of the highest volume repair facilities in the USA, could not function effectively with the restrictions of burn-off oven process time! It turns out that the mechanical process is far more LEAN than incinerating piles of motors.
Burn-off ovens and cement kilns had previously been exempt but it was determined that many cement kilns would continue to be exempt but that it made more sense to remove the exemption from burn-off ovens.
“In fact, sources operating incinerators, burn-off ovens and small, remote incinerators where energy recovery is not a goal, may find it most cost effective to discontinue use of their CISWI unit altogether.”
The US EPA found it more beneficial (less environmental impact) to landfill materials rather than use burn-off ovens! That is a highly unique position for the US EPA to hold!
The US EPA felt that just turning off 126 burn-off ovens would have more of an environmental positive impact than if the waste from all of the burn-off ovens were land filled (over 10,000 units). The average cost of compliance, per the trade association proposed letter, would be $146,777 per oven and $88,861 in annual costs. The cost for alternate methods that have low to zero environmental impact, produce a faster turnaround for end-users, do not generate a motor repair half-life, operates a more lean repair process, and maintains end user energy costs following repair, would cost far less than that in an initial investment.
I am disturbed by such activity when warnings were being produced by multiple organizations since the 1960s (and before) related to energy and environment impact through traditional electric motor repair practices. The choice to fight change in an industry while all other industries are requiring to change to maintain competitiveness around them has been amazing. In fact, in an article I wrote many years ago discussing the changes in the industry, we ended up changing the position of the article citing how the industry HAS NOT CHANGED in over a CENTURY! Processes used in the repair of machines have not changed since the days that my Great Grandfather Henry Bulbrook and Grandfather Howard Bulbrook repaired motors during the turn of the 20th Century, in a few cases, the equipment used today being almost that old.
Shouldn’t it be time for the motor repair industry to move forward and improve to the benefit of the end user instead of fighting to maintain 100 years of traditional repair that does not benefit the environment, end user costs, or reliability of machines?
Go to http://www.motordiagnostics.com in the archive section for more articles on motor repair.
email a-and-r-docket@epa.gov with Attention Docket ID No. EPA-HQ-OAR-2003-0119 and tell them that you support the regulation on burn-off ovens!
Sunday, July 25, 2010
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