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NPEP Success Story: Federal-Mogul
Federal-Mogul Eliminates Lead and Changes Regulatory Status
The Federal-Mogul facility in Boyertown, Pennsylvania, has been manufacturing sealed beam headlights in its current location since 1956 when the original plant was replaced to allow for growth. Boyertown is located about 50 miles northwest of Philadelphia. The present location is over 250,000 square feet and employs about 270 people, making it one of the largest employers in the immediate area. Our customers are primarily in the automotive domestic aftermarket, although we also manufacture specialty lamps for commercial, industrial, military, railroad, and aviation applications. We have been involved with the Pennsylvania Department of Environmental Protection (PA DEP) in their Pollution Prevention and Energy Efficiency programs and roundtables.
 EPA officials present an NPEP Achievement Award to Paul Ramirez of Federal-Mogul on October 25, 2005. |
Federal-Mogul's NPEP Goal Through the PA DEP, Federal-Mogul was introduced to NPEP and quickly determined that there was a good fit between NPEP's goals and our environmental commitment. Boyertown has been ISO 14001 certified since 2001 and just received our initial certification for ISO 14001:2004. Boyertown chose to work on reducing lead in our production operations. Previously, lead had been a key component in the three different types of solder used in sealed beam manufacturing. In 2002, the plant used almost 20,000 pounds of solder, which included over 13,000 pounds of lead. Lead was also the source of one of our two hazardous waste streams (as a contaminant in an aqueous ultrasonic cleaner used to clean soldering fixtures). In 2002, Boyertown generated 9,000 pounds of this hazardous waste. The goal was to eliminate the use of leaded solder in our manufacturing process. If leaded solder were removed from the manufacturing process, the lead hazardous waste stream would automatically be eliminated. |
Solder has historically been used to fasten brass terminals to the body of the sealed beam headlight. This allows the headlight to be incorporated into a vehicle's electrical/lighting system. It was not practical to change the connection system, so Boyertown was restricted to modifying the method of connecting the terminals. Clearly, the obvious choice was to look at a connecting method that did not involve lead. Even though Boyertown had historically used wire solder, we also considered changing to a paste solder. Although the paste solders were able to give adequate connections, the paste solder was so much more expensive than the wire solder that it was not a viable alternative. Conductive epoxies were also considered. They were ruled out both because of their cost and the cost of new dispensing equipment that would have been required.
Hurdles Faced
There were a number of hurdles to be addressed and finances were undoubtedly the most significant. Even the least expensive alternatives were significantly more expensive than the traditional leaded solders. And initially, the quality of the solder joints using any of the potential replacements was far inferior to the traditional methods. This led to increased scrap and rework costs. Soldering fires had to be adjusted and repositioned and in some cases new burners or burner locations were required. Many different "recipes" were tested before the proper tin-copper mix was found and integrated into our manufacturing operation.
Waste Minimization Results
The Boyertown facility is no longer using leaded solder in any of our
production processes. We went from over 13,000 pounds of lead in 2002
to 8,700 pounds of lead in 2003, to 350 pounds of lead in 2004, and to
our ultimate goal of zero lead in 2005. The lead hazardous waste stream
went from 9,000 pounds in 2002/2003 to 3,300 pounds in 2004, to zero in
2005. This elimination was a strong factor in the plant's recent change
from a Large Quantity Generator to a Small Quantity Generator of hazardous
waste. In June, 2005, Boyertown filed its TRI Form R (Section 313 EPCRA),
reporting on lead usage. Thanks to the change to unleaded solder, this
is a report Boyertown should never have to file again. Through continued
modifications to existing soldering operations, addition of some modified
preheat and soldering fires, and operator training, Federal-Mogul has
been able to improve soldering quality to the level typically achieved
with leaded solder.
The success of this NPEP partnership led Boyertown to apply for participation in the EPA's Performance Track Program. Boyertown was accepted and is now a member of that program.
Lessons Learned
Not every environmental enhancement is going to save money. Sometimes,
it's just the right thing to do to meet Federal-Mogul's commitment to
continual environmental improvement.