EPA/600/R-94/156
                                       September 1994
POLLUTION PREVENTION OPPORTUNITY ASSESSMENT
          UNITED STATES COAST GUARD
           AVIATION TRAINING CENTER
                MOBILE, ALABAMA
                       by
           TRC Environmental Corporation
            EPA Contract No. 68-D2-0181
  Prepared Under Subcontract No. 1-645-999-222-004 by:
          Pacific Environmental Services, Inc.
               Herndon, Virginia 22070
     RISK REDUCTION ENGINEERING LABORATORY
      OFFICE OF RESEARCH AND DEVELOPMENT
      U.S. ENVIRONMENTAL PROTECTION AGENCY
              CINCINNATI, OHIO 45268
                                       Printed on Recycled Paper

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                                       DISCLAIMER
      The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under Contract 68-D2-0181 to TRC Environmental Corporation,
under subcontract to Pacific Environmental Services, Inc..  It has been subjected to the Agency's peer
and administrative review, and it has been approved for publication as an EPA document.  Mention of
trade names or commercial products does not constitute endorsement or recommendation for use.

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                                        FOREWORD

      Today's rapidly developing and changing technologies and industrial products and practices
frequently carry with them the increased generation of materials that, if improperly dealt with, can
threaten both public health and the environment. The U.S. Environmental Protection Agency is
charged by Congress with protecting the Nation's land, air, and water resources. Under a mandate of
national environmental laws, the Agency strives to formulate and implement actions leading to a
compatible  balance between  human activities and the ability of natural systems to support and nurture
life.  These laws direct the EPA to perform research to define our environmental problems, measure
the impacts and search for solutions.

      The Risk Reduction Engineering Laboratory is  responsible for planning, implementing,  and
managing research, development, and demonstration programs to provide an authoritative, defensible
engineering basis in support of the policies, programs, and regulations of the EPA with respect to
drinking water, waste water, pesticides, toxic substances, solid and hazardous wastes, pollution
prevention, and Superfund-related activities. This publication is one of the products of that research
and provides a vital communication link between the  researcher and the user community.

      The Pollution Prevention Research Branch of the Risk Reduction Engineering Laboratory has
instituted the Waste Reduction Evaluations  At  Federal Sites (WREAFS) Program to identify, evaluate,
and demonstrate pollution prevention  opportunities in industrial, military, and other Federal facilities.
EPA believes the  WREAFS Program will show pollution prevention to be  a cost-effective tool in
reducing the generation and disposal  of hazardous and non-hazardous wastes. This report
summarizes a pollution prevention opportunity assessment of the U.S. Coast Guard (USCG)  Aviation
Training Center in Mobile, Alabama, which maintains the readiness and airworthiness of
Dauphin HH65 and Jayhawk HH-60 helicopters and Falcon HU-25 jets used in training and search
and rescue missions.
                                                  E. Timothy Oppelt, Director
                                                  Risk Reduction Engineering  Laboratory

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                                         ABSTRACT
      This report summarizes work conducted at the U.S. Coast Guard (USCG) Aviation Training
Center (ATC) in Mobile, Alabama under the U.S. Environmental Protection Agency's (EPA's) Waste
Reduction Evaluations at Federal Sites (WREAFS) Program.  This project was funded by EPA and
conducted in cooperation with U.S. Coast Guard officials.

      The purposes of the WREAFS Program are to identify new technologies and techniques for
reducing wastes from processes operations and other activities at Federal sites, and to enhance the
implementation of pollution prevention/waste minimization through technology transfer.  New
techniques and technologies for reducing waste generation are identified through waste minimization
opportunity assessments and may be further evaluated through joint research, development, and
demonstration projects.

      A pollution prevention  opportunity assessment was performed during the fall of 1993 which
identified areas for waste reduction at the ATC.  The study followed procedures in the EPA Facility
Pollution Prevention Guide.  Although the ATC has made substantial progress to date, opportunities
were identified for further action. This report identifies potential procedural initiatives as well as
technology options to achieve further pollution prevention progress.

      Several waste generating processes were initially screened including flight simulators, aircraft
maintenance, aircraft fuel management, and aircraft cleaning.  Opportunities to  reduce wastes in each
area were identified and evaluated.

      This report was submitted in fulfillment of Contract No. 68-D2-0181 by TRC Environmental
Corporation, under the sponsorship of the U.S. Environmental Protection Agency. This report covers a
period from October 15, 1993 to September 30, 1994; work was completeded as of September 30,
1994.
                                              IV

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                                      CONTENTS

 Section                                                                        Page

 DISCLAIMER	ii
 FOREWORD  	  Hi
 ABSTRACT 	  iv
 ACKNOWLEDGEMENTS 	viii

1      INTRODUCTION	   1
       PURPOSE  	   1
       APPROACH	   3

2      SITE ACTIVITY DESCRIPTIONS	   5
       FLIGHT SIMULATORS  	   5
       AIRCRAFT MAINTENANCE SHOPS  	   7
             Aircraft Survival Shop	  16
             Paint, Composites, and Metal Shops	  17
             Battery Shop	  20
             Avionics Shop	  21
       AIRCRAFT FUELING	  22
       AIRCRAFT WASHING .	  23

3      OPPORTUNITY ASSESSMENT	  25
       FLIGHT SIMULATORS  	  26
             Flight Simulator Contract Incentives 	  26
             Flight Simulator Hydraulic Fluid Recovery  	  29
       AIRCRAFT MAINTENANCE	  31
             Centralized Material Control	  31
             Alternative Cleaning Solvents	  32
             Alternative Aerosol Dispensing Systems  	  35
             Condition-Based Oil Replacement	  36
             Aircraft Survival Shop	  37
             Paint/Composites and Metal  Shops	  37
             Battery Shop	  38
       AIRCRAFT FUELING	  39
             Fuel Spill Recovery 	  39
             Eliminate Rainwater Entry to Bowser	  40
             Bowser Waste Segregation	  41
             Fuel Transfer Spill Prevention	  41
             Spill Containment	  42
             Reduce Fuel Sample Size	  43

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                                 CONTENTS (continued)

 Section                                                                        Page

             Alternative to "Clear and Bright" Analysis	  44
      AIRCRAFT WASHING	  44
             Environmentally Friendly A/C Washing Soaps 	  44
             Aircraft Washing Specifications	  46
             Optimize Oil/Water Separation System  	  46
      POTENTIAL DEMONSTRATION PROJECTS  	  47

APPENDIX A PPOA WORKSHEEETS	48
                                          VI

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                                        FIGURES
Number

 1

 2
Pollution Prevention Program Overview	2

Typical Absorbent Wringer	30
                                         TABLES
Number

  1           Flight Simulator Materials Usage List	6
  2           Air Frame and Engine Shops Material Usage Rates	8
  3           Aircraft Maintenance Shops Waste Streams  	15
  4           Aircraft Survival Shop  Materials Usage List	17
  5           Paint/Composite/Metal Shops Materials Usage List  	18
  6           Paint/Composite/Metal Shops Waste Streams 	20
  7           Battery Shop Wastes	21
  8           Avionics Repair Shop  Materials Usage List  	22
  9           Summary of Recommended Pollution Prevention Options	27
  10         Summary Chart of Aircraft Maintenance Cleaning Applications and Feasible
              Alternative Cleaning  Methods	33
                                             VII

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                                   ACKNOWLEDGEMENTS


       The authors wish to acknowledge the help and cooperation provided by Lieutenant
Commander Michele Fitzpatrick, Chief Warrant  Officer Robert Siggins, and Chief Aviation Machinist's
Mate Ric Peri of the U.S. Coast Guard. Other Coast Guard employees and officials at the facility
were also very helpful and cooperative. In addition, information provided to us by vendors of
equipment and services, and the useful project  guidance and review comments of the EPA Project
Officer, James Bridges, and Prime Contractor Task Manager. Jan Smith of TRC Environmental
Corporation, are appreciated.

       This report was prepared for EPA's Pollution Prevention Research Branch by Bill Burch and
Al Memon,  Pacific Environmental Services, Inc., under subcontract to TRC Environmental Corporation
for the U.S. Environmental Protection Agency under Contract No. 68-D2-0181.
                                            VIII

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                                        SECTION 1
                                      INTRODUCTION

PURPOSE

       The purpose of this project was to conduct a Pollution Prevention Opportunity Assessment
(PPOA) of the United States Coast Guard (USCG) Aviation Training Center (ATC) in Mobile,
Alabama.  The assessment was conducted for the EPA's  Risk Reduction Engineering Laboratory
(RREL) and the USCG's Research and Development Center under the purview of the Waste
Reduction Evaluations at Federal Sites (WREAFS) Program of the Pollution Prevention Research
Branch in RREL. The study was conducted using the procedures outlined in the  EPA manual, Facility
Pollution Prevention Guide (EPA/600/R-92/088), which provides a methodology for assessing
operations to identify, evaluate and implement pollution prevention opportunities.

       Pollution prevention  in environmental management requires the development of a comprehen-
sive program which continually seeks opportunities to implement cost-effective strategies to reduce
waste generation.  PPOAs provide detailed assessments of waste  streams, options for reducing waste
generation or preventing pollution, and analyses of alternatives identified.  Figure  1 identifies the key
elements of a pollution prevention program showing the interrelationship of the PPOA to the program.
The elements of the pollution prevention program are discussed in detail in the Facility Pollution
Prevention Guide.

       The approach for conducting a PPOA at the ATC is described in this section.  Section 2
describes activities that generate wastes for each of several process areas identified.  Possible
alternative practices to minimizing these wastes are discussed in Section 3.  Recommendations on
potential follow-up activities are also included in Section 3. The PPOA worksheets are included in the
Appendix.

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                   Establish the Pollution Prevention Program
                          - Executive Level Decision
                          - Policy Statement
                          - Consensus Building
                             Organize Program
                              - Name Task Force
                              - State Goals
                       Complete Preliminary Assessment
                             - Collect Data
                             - Review Sites
                             - Establish Priorities
                             Write Program Plan
                          - Consider External Groups
                          - Define Objectives
                          - Identify Potential Obstacles
                          - Develop Schedule
                                   ±
                        Complete Detailed Assessment
                       - Name Assessment Team(s)
                       - Review Data and Site(s)
                       - Organize and Document Information
                                   I
                      Define Pollution Prevention Options
                              - Propose Options
                              - Screen Options
                                   i
                         Complete Feasibility Analyses
                               - Technical
                               - Environmental
                               - Economic
                           Write Assessment Report
                                   1
                              Implement the Plan
                               - Select Projects
                               - Obtain Funding
                               - Install
                              Measure Progress
                               - Acquire Data
                               - Analyze Results
                                   I
                      Maintain Pollution Prevention Program
Figure 1.  Pollution prevention program overview.
                                    2

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APPROACH

       The USCG Aviation Training Center is located at Bates Field, adjacent to the Mobile,
Alabama Municipal Airport.  The ATC was commissioned in 1966 to provide centralized
comprehensive training to USCG personnel in the operation of fixed-wing and rotary-wing aircraft.
The facility also has fixed-wing search and rescue responsibilities. Five hundred personnel operate
the facility on a 24-hour basis.  Three types of aircraft are maintained in operation:  the Dauphin
Helicopter (HH-65), the Jayhawk Helicopter (HH-60) and the Falcon Jet (HU-25). Duties performed
include cleaning, maintenance and repair of structural, mechanical, and electrical aircraft components,
and rescue and survival gear. The aircraft are also fueled onsite.  Approximately 20 aircraft are
operated at this facility.

       The ATC has ongoing activities to reduce waste generation at the facility.  Each activity or
process area has a lead "Point Manager" who, under the direction of the Environmental Safety
Manager, works with the operating personnel to identify and implement approaches to reduce  waste
generation.  In preparation for this PPOA,  a pre-assessment was conducted by USCG Environmental
Safety personnel from the ATC in Mobile with the assistance of staff from the USCG's Research and
Development (R & D) Center in Groton,  Connecticut and the Civil Engineering and Aeronautical
Engineering Divisions of USCG Headquarters in Washington, DC.  The pre-assessment identified the
following four activity areas as candidates  for further review in the PPOA:

       1.      Flight simulators
       2.      Aircraft maintenance
       3.      Aircraft fueling
       4.      Aircraft washing

The pre-assessment report served to identify priority waste streams for further consideration during
the detailed PPOA.  The pre-assessment report included information on the volume of waste
generation in each process and the current cost of handling off-site disposal of the wastes.

       The PPOA process includes developing a work plan for the  PPOA;  identifying the assessment
team; conducting the site visit for data collection and observation of waste generating activities;
identifying and analyzing waste reduction alternatives; and developing the PPOA assessment report.

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The PPOA assessment team included USCG representatives from the ATC, the R & D Center and
the Aeronautical Engineering Division of USCG Headquarters, in addition to an EPA representative
from RREL and EPA contractor personnel. A protocol for the site visit was prepared and discussed
by the assessment team in advance of the site visit.  The site visit opened and closed with briefings of
the Commanding Officer and staff who showed strong interest in the goals of the PPOA.  During the
site visit, operating personnel were interviewed to gain their perspectives on alternative practices
which could lead to reduced  waste generation.  The operating personnel provided important input into
the characterization of potential  alternatives. They expressed an understanding of the importance of
minimizing waste while meeting  performance needs.  The site visit concluded with a "brainstorming"
session which allowed the  assessment team to interact and exchange ideas on the waste reduction
alternatives and identify areas for follow-up activities. Following  the site visit, selected waste reduction
options were investigated further as described in Section 3.

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                                         SECTION 2
                               SITE ACTIVITY DESCRIPTIONS

FLIGHT SIMULATORS

       The Mobile, Alabama ATC houses three flight simulators in the Flight Training Systems
Building which are used for training USCG aviators.  The flight simulators each function as
sophisticated trainers for instrument, cockpit, operational, and emergency flight procedures.  The
simulators are dynamic replicas of the HH-60, HU-25A, and the HH-65A aircraft.

       Each  simulator is equipped with a "six degrees of freedom motion" system and an
independent single purpose digital computer.  The HU-25A and the HH-65A are also equipped with
SP-1 night/dusk visual systems.  The ATC has a maintenance and engineering support services
contract with Simtech for these simulators.  The contractor  is responsible for all maintenance activities
including safety and environmental protection.  The simulators must be available during training
periods from 0700-2300, Monday through Friday. The ATC also uses a contractor to recycle or
dispose of the waste from the  simulator activities.

       The simulators utilize hydraulic equipment, the fluid for which is pumped from a fluid reservoir.
The degree of leakage resulting from pipe and pump joints failures is primarily a function of the age of
the simulators and  associated  piping and pumping systems.  Hydraulic fluid spill cleanup accounts for
the major portion of the waste  generated from the simulators.

       The simulators are subject to operational readiness (daily) and housekeeping (weekly)
maintenance and to major maintenance at predetermined periods. In these maintenance activities,
several materials are used, which are listed in Table 1.

       The operation and maintenance of the simulators produces very little waste except as a result
of cleanup of  hydraulic fluid spills as described above. Normal maintenance produces  very little

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                    TABLE 1.  FLIGHT SIMULATOR MATERIALS USAGE LIST
Description
Adhesive, Rubber Cement
Anti Seize
Avionic Cleaner, Texwipe HCFC Cleaner
Avionic Cleaner, Texwipe HCFC Cleaner
Chlorinated Cleaner
Chlorinated Cleaner
Chlorinated Cleaner
Chlorinated Cleaner, Safety Kleen #609
Circuit Cooler, Spraytec
Grease, Lubrimatic
Hydraulic Fluid
Solid Lube
Specification
MMM-A-121
Loctite 767
TX132
TX124
AP-20 Remover
Spray Kleen
Spraytec Flux-A-Way
Cleaner 601
SPC34N610
11380
Brayco Micro nic 745
Yellow 77
hazardous waste, mostly in the form of aerosol cans with residue products (less than 60 Ibs per year).
Most of the solvent residues are HCFCs.  The hydraulic fluid reservoir pump filters are changed semi-
annually, and the spent filters are discarded.  Leaked/spilled hydraulic fluid is absorbed on absorbents
or collected in drip pans placed under the leaking joints.  Hydraulic fluid collected in the pans and the
absorbents and the spent filters are regularly transferred to two 55 gallon drums which are stored in a
satellite collection area located at the back of the simulator building. One drum receives liquid waste
and the other receives solid waste.  Any saturated rags from cleaning operations are also stored in
the solid waste drum.  The ATC waste contractor removes the 55 gallon drums when full for offsrte
disposal or recycling.  The waste contractor pays ATC $0.03 per gallon of hydraulic fluid and charges
$0.50 per gallon for any water mixed with the fluid.  The contractor charges $0.46 per pound for
disposal of the spill-cleanup absorbents, cleaning rags, discarded filters, etc. In 1992-1993,
approximately 790 pounds of such material were disposed of at  a cost of $359.50. This included
about 220 gallons of hydraulic fluid collected during the same period.

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AIRCRAFT MAINTENANCE SHOPS

       The ATC operates three different aircraft or airframes in training activities, the Dauphin and
Jayhawk Helicopters and the Falcon Jet. The Falcon Jet is also utilized for search and rescue
missions.  Each type of aircraft has its own maintenance and repair shop, which operate continuously,
with assigned staff to maintain the aircraft's readiness and airworthiness.  Engine repair shop facilities
are shared.  The evening shift (4 p.m. to midnight) is utilized for scheduled maintenance, with some
maintenance needs carrying over into the mid-shift (midnight to 8 a.m.).  The day shift (8 a.m. to 4
p.m.)  prepares and services aircraft in support of the day's scheduled training activities.

       The ATC has the capability to address the majority of repair needs for each airframe design.
Each  aircraft's needs are tracked by the specific airframe shop which conducts the majority of the
routine maintenance activities.  Routine maintenance is scheduled and tracked for each individual
aircraft by an Aviation Computerized Maintenance System (ACMS).  The ACMS provides a systematic
mechanism to insure each aircraft is receiving required maintenance on schedule and to identify
trends in maintenance and  repair needs across similar aircraft.  The ACMS's role is currently being
expanded to provide information on specific chemicals approved for use on each airframe.  The
ACMS's  Authorized Chemical Use List (ACUL) has been completed for the Dauphin helicopter and
Falcon Jet and is under development for the Jayhawk Helicopter.

        The airframe shops are responsible for interior and exterior cleaning; lubrication of moving
parts; and disassembly, repair and reassembly or replacement of aircraft parts and engines. The
airframe shop personnel also refuel the aircraft and conduct daily analyses of the fuel for water and
sediment content.  Written Technical  Information  Maintenance Instructions (TIMIs) are  used to identify
the specific requirements for each task.  Specialty aircraft repair needs that cannot be  addressed by
the general airframe shops are referred to the specialty  maintenance shops such as the Avionics,
Metal, Paint, Composite, and Engine  shops described in other sections of this report.

        Many chemical  materials are used by the airframe shops. The majority of these materials  are
stored in individual shop lockers for use by  shop personnel. Table 2 identifies the materials used by
the airframe shops and the engine shop and ATC's estimated annual usage rates for  each.  Many of
the same or similar materials are used  for the same function and application in each of the shops.
 For several functions, such as cleaning, corrosion control, and lubrication, several different products

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are used for the same function.  The selection of different products for similar applications has
evolved over time based on the experience of the individuals performing the tasks. The materials are
centrally purchased for the ATC, stored at the Aviation Materials Office's supply building and then
dispersed to each shop upon request.

        Waste streams resulting from the operation of the airframe shops include aircraft fuel, used
lubricants and hydraulic fluids, waste solvents, expired materials, containers, and used rags and ab-
sorbents.  Table 3  identifies the estimated volumes of these waste streams. Waste aircraft fuel
results from the daily analysis of fuel from each aircraft (one to two gallons per day per aircraft) to
check for moisture and sediment, as well as fuel drained from aircraft fuel cells, fuel pumps and
engines prior to repair work in order to complete repairs.  Fuel spills  may also  result from these
activities.  Fuel wastes are collected and stored in an aboveground 1,500 gallon  storage vessel or
"bowser" used to collect waste oil and fuel.  The materials stored in the bowser are collected for off-
site disposal by a waste management contractor.  Fuels will be discussed further in the section on
Aircraft Fueling.


                TABLE 3.  AIRCRAFT MAINTENANCE SHOPS WASTE STREAMS
Waste Stream
Waste Fuel3
Used Lubricating Oilb
Used Hydraulic Fluid6
Coldcleaner Spent Solvent0
Mixed Spent Solvents
Materials with Expired Shelf-life
Material Containers
Estimated Annual Quantity
12,000 gallons
937 gallons
744 gallons
180 gallons
24 gallons
24 gallons
600 pounds
     a Includes all fuel losses
     b Based on 1992 usage
     0 Includes metal shop Usage
        Also collected in the bowser are spent lubricating oils and hydraulic fluids from the servicing
of aircraft engines, gearboxes and hydraulic systems. The used oils are drained during maintenance
                                              15

-------
activities and then transferred to the bowser.  Virgin oils are generally received in quart cans.  After
the oil is dispensed, the empty quart cans are crushed and allowed to drain for 24 hours before being
transferred to the municipal waste stream. The drained  oil is transferred to the bowser.   Engine and
gearbox oil replacement is typically prescribed by the engine manufacturer based on hours of engine
operation, and the Falcon Jet and Dauphin Helicopter are maintained this way. The approach
followed with the Jayhawk Helicopter,  however, is based on the condition of the oil, which is analyzed
on a regularly scheduled basis.  Each year an  estimated 1,680 gallons of waste lubricating, oil and
hydraulic fluids are generated from servicing the aircraft.  Over 6,700 quart containers must also be
disposed of each year.

        Waste organic solvents are generated from cleaning activities.  Organic solvents  have  been
used in parts washers for immersing and manually cleaning parts.   The ATC has recently reduced
the number of organic-solvent-based parts washers to a single unit located in the metal shop which
can be used in aircraft maintenance activities.  The parts washing unit is serviced by Safety-Kleen on
a bi-weekly basis when the spent solvent is collected for recycling and fresh solvent added,
approximately 30 gallons per month.  To compensate for the lost cold cleaning capability, a water-
based parts washing unit is being evaluated. The unit has the potential to reduce the volume of
waste  organic solvents from parts cleaning activities.  In addition, a variety of organic solvents  is used
for wipe and spot cleaning,  typically with rags.  The waste organic solvents are collected  and stored in
55 gallon drums for pickup by the waste management contractor.

        Waste materials are also collected from containers with spent shelf-life. Containers are
drained and liquids transferred to the appropriate waste stream. Containers are then crushed for
disposal.  In addition,  rags and absorbents in cleaning activities and spill containment are collected in
drums for off-site disposal by the waste management contractor.

Aircraft Survival Shop

       The aircraft survival shop inspects and repairs all of the life support equipment maintained on
the aircraft used in rescue activities. This includes parachutes, rafts, life preservers, lines, signal
devices and inflation devices. All equipment is subject to regular inspections.  Any defects identified
are corrected and the  equipment is then placed back in service. The materials used in the  aircraft
survival shop and their estimated consumption  rates are  shown in Table 4. The rubber adhesive used

                                              16

-------
in raft repair has a six-month shelf-life which is monitored closely.  Toluene is used to clean surfaces
prior to application of the glue. Dispensed glue which is not used is allowed to set before disposal
with municipal waste.  Empty containers are disposed of with those from the other shops.
                TABLE 4.  AIRCRAFT SURVIVAL SHOP MATERIALS USAGE LIST
Description
Adhesive, Rubber
Cleaner, CPC
Floor Wax
Grease, General Purpose
Grease
Insecticide
Oil, 30W Motor
Solvent, Toluene
Specification
8040-00-290-4301
8030-00-546-8637
7930-01-184-3905
9150-00-273-8663
9150-00-754-2595
6840-01-067-6674
9150-00-231-6689
6810-00-281-2002
Annual Usage
by Unit Size
40 quarts
64 pints
1 2 gallons
48 pints
1 6 quarts
48 pints
72 quarts
1 2 gallons
Paint, Composites, and Metal Shops

       The ATC has two shops which serve to build, repair and coat aircraft components. The paint
and composites shop manages the supply, distribution and application of paints for coating aircraft
components. It also has the capability to construct and repair components made from composite
materials which are used in aircraft construction, particularly the interior and exterior skins. The metal
shop has the capability to fabricate and repair metal components of the aircraft. The metal shop also
conducts non-destructive testing of aircraft wheels to identify potential for metal fatigue and wheel
failure. Material consumption rates for these shops are shown in Table 5.

       The paint and composite shop utilizes high-pressure compressed air spray paint guns for
application of surface coats.  Aerosol cans are also used for some paint application requirements.
Painting can be conducted in a spray  paint booth with a drying oven or in the hanger. The spray
booth is ventilated through a water curtain to collect overspray. Aircraft components  are painted in
the spray booth, while small sections of the aircraft surface are painted in the hanger. Quart- and
pint-sized  spray guns are typically  used.  Painting in the booth is typically one or two hours per day.
Painting in the hanger is limited to  weekends when maintenance personnel are routinely off duty and
the hanger is unoccupied.  A paint mixing room is used to mix paints, setup application guns, store
                                             17

-------
TABLE 5.  PAINT/COMPOSITE/METAL SHOPS MATERIALS USAGE LIST
Description
Adhesive
Adhesive
Adhesive
Adhesive
Adhesive, Epoxy
Adhesive, Epoxy
Alodine
Dye Penetrant
Fluid, Layout
Edge Dressing
Grease
Grease
Grease, Lubriplate
Lacquer, Gray (Deck)
Machine Oil
Mold Release
Paint, Aerosol
Paint, Poly (Various Colors)
Paint Remover
Lubricant Solid Film, Perma Silk
Grease, Petrolatum
Plastic Face Coat
Primer, Epoxy
Resin
Sealant
Solvent, Acetone
Solvent, MEK Peroxide
Solvent, Methyl Ethyl Ketone
Solvent, Naptha, Aliphatic
Walkway Compound
Specification
1751 A/B
Epocast 169A
Cho Bond 360-20
8040-00-165-8614
RP 1257-3
Atacs 5103
MIL-C-81706
ZL-17
Dykem
8030-00-936-9940
MIL-G-3545C
MIL-G-81322
630AA
Deck Paint
Rando HD 32
Freekote 33
Various Colors
MIL-C-83286
8010-00-181-7568
MIL-G-23398D
VV-P-236B
RP 1118
MIL-P-23377E
9309.3
MIL-S-8802
O-A-51


TT-N-95
Non-skid
Annual Usage
by Unit Size
10 2-oz. kits
24 quarts
4 2-oz. kits
1 2 quarts
1 2 quarts
12 2-02. kits
2 16-02. cans
12 2-02. kits
6 16-O2. cans
4 16-02. cans
1 0 gallons
2 quarts
2 gallons
30 gallons
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24 16-02. cans
85 16-02. cans
36 2-02. kits
4 gallons
2 quarts
4 quarts
1 2 quarts
8 2-02. kits
1 2 quarts
2 2-02. kits
100 gallons
4 gallons
60 gallons
2 gallons
6 gallons
                           18

-------
and dispense coating materials and clean application equipment.  Preparation of surfaces for painting
may require paint removal using chemical-based paint strippers or blasting media.  Also located in the
paint mixing room is a Safety-Kleen paint-gun cleaning unit which is serviced by Safety-Kleen once a
month.  The cleaning unit includes storage of used and virgin solvent and has the capability to spray
either solvent during gun cleaning.  Spent solvent  is  used to remove the majority of the paint,  followed
by virgin solvent, which is sparingly used to rinse the gun.

        Centralized distribution of painting materials  was initiated  in 1991 using the paint locker in the
paint mixing room. The locker also serves as the  ATC's centralized point for dispensing bulk  solvents
such as MEK and acetone. This approach has resulted in a significant reduction in solvent use from
three to five drums per month to one  to two drums per year.  Efforts are made to match the volume of
paint formulated with the job at hand  and to clean  the paint guns  immediately after application,
facilitating cleaning.

        The paint and composite shop also repairs aircraft components made from composite
materials by constructing similar compositions. Composites are use for helicopter skins and interior
components of the Falcon Jet. The composites are  typically a structural material, such as a
honeycomb matrix, wrapped with a synthetic fiber  coated with resin skin. In the layout of composite
repairs, the skin material used consists of a woven mat of synthetic fibers (e.g., fiberglass or carbon)
which is impregnated with a partially-cured resin formulation.  The "pre-preg" material is kept from
curing by storing it at reduced temperatures.  Both the structural material and pre-preg materials are
cut to size, set in place and allowed to cure at room temperature.  The repair area is usually sealed
and connected to a vacuum pump to volatilize and remove any unreacted resin. Molds are used for
constructing entire components such  as an aircraft interior headliner.

        The metal shop operates metalworking equipment to repair and fabricate metal aircraft
components. Parts under repair may require paint removal using chemical-based paint strippers, or
cleaning using the organic solvent parts washer described in the aircraft maintenance shops.  The
metal shop also conducts non-destructive testing of  aircraft wheels using dye penetrants.  Dye
penetrant, containing a fluorescent dye in a solvent with good penetrating properties, is  applied to the
metal surface of the wheel  and allowed to  soak into  any potential cracks.  After wiping residual
penetrant from the surface, a fluorescent light is used to identify cracks.
                                              19

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        Waste streams associated with the paint and composite shop include the masking material and
rags from painting, paint slops from the watercurtain in the paint booth, spent solvent from the paint
gun cleaner, contaminated paint thinning solvents, paint blasting media, and empty containers.  The
estimated volumes of these waste streams are identified in Table 6.  The spent solvent from the
operation of the Safety-Kleen paint gun cleaner is replaced twice a month and recycled offsite.  A
55 gallon drum is kept in the paint mixing room for collecting the waste paint thinning solvents for
removal by the waste management contractor.  A separate container is used to collect paint rags and
masking materials. Wastes from the metal shop include the spent solvent from the parts washer
shared with the maintenance shops and contaminated rags.
                TABLE 6. PAINT/COMPOSITES/METAL SHOPS WASTE STREAMS
Waste Stream
Rags and Masking Materials
Paint Shops
Paint Gun Cleaning Solvent
Spent Paint Thinning Solvents
Mixed Spent Solvents
Paint Blasting Media
Paint Containers
Estimated Annual Quantity
600 pounds
452 pounds
360 pounds
36 gallons
24 gallons
1,042 pounds
120 pounds
Battery Shop

       The battery shop is located in the hangar with the other aircraft maintenance shops. This shop
is responsible for discharging, recharging, and disposal of the following four types of aircraft batteries.
       Nickel-Cadmium (NiCd) dry battery cells
       NiCd wet battery cells
       Mercury batteries
       Lithium batteries
                                             20

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The battery shop uses a small supply of new NiCd, mercury, and lithium batteries for replacement of
discharged batteries which are not rechargeable and are discarded.  No lead or acid batteries are
handled at the battery shop.
       The waste generated from the battery shop includes discarded batteries and potassium
hydroxide from wet NiCd battery maintenance. Table 7 lists the wastes generated annually from the
battery shop.

                              TABLE 7. BATTERY SHOP WASTES
Waste
Lithium Batteries
Mercury Batteries
NiCd Batteries
Potassium Hydroxide
Quantity (Ibs)
10
9
30
240
Cost ($)
60.00
27.00
36.00
280.00
        In addition to the above aircraft batteries, there are waste auto batteries from support
vehicles, the auto hobby shop, and satellite service areas on the base.  The auto batteries are
discarded when discharged and replaced with new batteries.

        The automotive batteries are collected from the base as a separate waste stream. Auto
batteries from the satellite services are exchanged for new batteries at a reduced cost depending on
the battery life.  The auto batteries from the other areas are consigned to the Defense Reutilization
and Marketing Office (DRMO) for recycling.  If DRMO locates a buyer/recycler, ATC will be
compensated for the batteries. To date, no sales have occurred.  It is estimated that about 20
batteries per year are wasted from these areas.

Avionics Shop

        The avionics shop also supports the aircraft maintenance activities.  Avionics equipment from
the aircraft is cleaned and/or soldered  in this  shop. Table 8 lists the materials and quantities used.
                                              21

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The waste generated from the avionics shop is limited to empty cans, bottles, or containers with
product residue.

                  TABLE 8. AVIONICS REPAIR SHOP MATERIALS USAGE LIST
Description
Aerosol, Block Buster
Aerosol, Selig EMC 13
Aerosol, Selig Super CSC
Avionics Cleaner
Expo Cleaner
General Purpose Cleaner
Grease, Instrument
Isopropyl Alcohol
Leak Tec
RTV Sealant
Sealant
Solder Flux
Specification
Block Buster
EMC 13
Super CSC
MIL-C-81964A
White Board Care
P.O. 1747
MIL-G-23827B
Isopropanol
MIL-I-25567D
MIL-A-461068
MIL-S-8660C
Laco Brite
Annual Usage
by Unit Size
24 16-oz. cans
48 16-oz. cans
16 16-oz. cans
96 16-oz. cans
4 gals
48 pints
4 quarts
4 gallons
8 pints
16 10-oz. tubes
8 10-oz. tubes
4 gallons
AIRCRAFT FUELING

       Aircraft fuel used at the ATC is JP-4, which is stored in three 34,000 gallon vaulted tanks at
the fuel farm.  JP-4 is received from tanker trucks and loaded into the fuel farm holding tanks.  The
aircraft refuelers are then filled at the JP-4 loading station.  As a result, the fueling process has three
potential spilling  opportunities.  About two million gallons per year of fuel are transferred into each
aircraft. This totals to six million gallons of fuel per year handled in the fueling process.  Fuel transfer
is not equipped with spill containment.  Spills normally occur at the fuel farm from overfilling/valve
malfunction,  primarily due to unsupervised or unattended fuel transfer activities or mechanical failures.
Soil contamination at the fuel farm was observed during the site visit  and possible groundwater
contamination cannot be ruled out due to sandy soils in this area.
                                             22

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       The fuel farm is equipped with a 2,500 gallon vaulted stripping tank for collecting the fuel/water

mixture stripped from the holding tanks. Fuel from aircraft defueling is recycled back into the holding
tank for reuse. The defueling is performed as an aircraft maintenance activity in order to drain fuel
from lines clearing, fuel cell, and pump repair activity.


       As part of the daily preflight inspection, fuel samples of one quart per fuel tank are taken for

"Clear and Bright" analysis. Approximately two gallons of fuel samples per aircraft are taken.


       The following waste streams are generated from the aircraft fueling operations:


(1)     Discarded fuel samples from the aircraft, tanks, and trucks. These are dumped in the waste
        bowser located west of the hangar.  The bowser is manually filled by transfer through a large
        funnel.  Frequently, the funnel is left  unattended, and was observed collecting rain, adding
        moisture to the bowser contents. The bowser also receives waste oils from aircraft
        maintenance activities.  The bowser  contents are emptied by a local contractor for recycling
        periodically or when full.

(2)     Fuel/water  mixture stripped from the holding tanks at the fuel farm is collected in the
        2,500 gallon tank. The tank is emptied by a local contractor when full for recycling.

(3)     JP-4  fuel spills occur at fueling transfer locations as described above, at defueling, at sampling,
        and at other places where the JP-4 is handled.  Absorbent materials are used to clean spills
        and saturated waste is disposed of through  DRMO Keesler.


        It has been estimated that about 12,000 gallons of fuel/water mixture are generated from the

first two waste streams.  The base receives $0.03 per gallon for recyclable fuel and pays $0.50 per

gallon for the water.


        Approximately 2,767 pounds of saturated waste is generated per year, which is disposed of at

a cost of  $1.00 per pound.


AIRCRAFT WASHING


        Aircraft must be washed after the last flight of the day as part of the corrosion prevention

program.   The aircraft washing is performed to clean the aircraft surface from any soil, grime, salt, etc.
accumulated on the aircraft.  There are two wash racks located east and west of the hangar.  Different

kinds of soaps are  used to wash the aircraft. The soap, available in liquid form,  is intended to be

                                               23

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measured and mixed with the appropriate quantity of water.  During the site visit, however, ATC
personnel were observed preparing the soap and water mixture without measuring either component.
The soap and water mixture is manually applied to the aircraft with brush scrubbers:  the aircraft is
then hose-sprayed with water to remove the soap. ATC uses about 3,300 gallons of aircraft soap per
year.  The following soaps are used in the aircraft cleaning:

              Soap                           Spec                              Use
         Aircraft Soap Type 1                 MIL-C-85570 TY1                 A/C Cleaner of General Use
         Aircraft Soap Type 4                 MIL-C-85570 TY4                 Rubbing Compound
         Aircraft Soap Type 5                 MIL-C-85570 TY5                 Spot Cleaner for H25/H60
         Aircraft Soap Type 2                 MIL-C-85570 TY2                 A/C Soap for H65A
        Aircraft cleaning produces a waste stream of rinsate which contains the soap and dirt, oil and
grease which were cleaned from the aircraft surfaces. The wash rack located west of the hangar
drains into an oil/water separator and then into the sanitary sewer. The State of Alabama does not
require a State Industrial Permit for this discharge because of its relatively small volume and the
characteristics of the soap water rinsate.  The new wash rack located east of the hangar drained into a
settling and skimming tank and into the stormwater sewer during the site visit.  The discharge has now
been directed to the sanitary sewer.  Sludge is periodically removed from the settling tank and no
appreciable skimmed material  has been observed as a result of its operation.  This discharge has
received a permit from the State of Alabama which requires monthly testing for several parameters
(BTEX, total suspended solids, oil/grease, pH,  phosphates, and naphthalene) to demonstrate
conformance with the permit conditions.  Several chemical constituents have been identified in the
MSDSs for the aircraft soaps which could also be present in the rinsate including naphtha,
2-butoxyethanol, hexylene glycol, dipropylene glycol monomethyl ether and morpholine.  The presence
and potential concentrations of these compounds in the rinsate have not been determined.
                                               24

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                                         SECTION 3
                                OPPORTUNITY ASSESSMENT

       During the site visit to the ATC, the Assessment Team observed evidence of a concerted
effort to reduce wastes at the facility.  Additional opportunities to further progress in waste reduction
were also identified. This section will discuss the ongoing successes identified and the feasibility of
the additional options considered for reducing wastes for each shop.  Recommendations will also be
made regarding implementation of these options.

       Several ongoing practices at the ATC facility support a pollution prevention ethic and reduced
waste generation. The policy for hazardous material procurement centralizes purchasing authority for
hazardous materials. Only authorized materials for aircraft are purchased, with exceptions requiring
approval of the Hazardous Material Control Officer.  The ATC is working to reduce the inventory of
on-site materials to a three to six month supply. These  practices will limit the purchase of
unnecessary hazardous  materials, and reduce the loss rate due to expired shelf-life. The  "Point
Managers" in each shop serve to increase the awareness of the procurement policies and identify
hazardous material use issues at the operating level.  All personnel have been advised by
memorandum  of the importance of eliminating duplicate purchases of materials authorized for the
same function and application.  The development of the Authorized Chemical Use Lists in the Aviation
Computerized  Maintenance System will further limit the purchase and use of unauthorized materials.

        At the ATC, increasing awareness of the concept of pollution prevention will be critical in
making further improvements in waste reduction.  At the ATC, high quality performance and efficient
task completion may be  viewed as incompatible with limiting the use  of necessary materials.
Improving the  understanding of the benefits of waste reduction at the task level will reduce the
potential for this conflict  and lead to the incorporation of waste reducing practices as an integral part
of each job. At the ATC, the operating personnel appear to be highly motivated and well trained in
carrying  out their duties.  Their duties need to reflect the responsibility for reducing waste  generation
in their job function.

                                              25

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        At the ATC, several alternatives were identified which could serve to facilitate communicating
 how a pollution prevention ethic can relate to specific job requirements.

        Management  Policy - Written policy by the ATC management establishing the importance of
        pollution prevention  in operation of the facility.
        Training Material - Tailored specifically to USCG aviation activities.
        Staff Briefings - Information exchange on the progress made at the ATC in waste reduction on
        a continuing basis.
        Recognition Programs - Encourage the identification of new ideas and, on a periodic basis,
        acknowledge  significant achievements of individuals or units in waste reduction.
        Operating Procedures - Incorporate waste reduction practices with user-friendly language into
        task instructions such as the Aviation Computerized Maintenance System (ACMS) work cards
        and the Technical Information Maintenance Instructions (TIMIs).
        Measures of Progress - Develop measures to record and track progress in  reducing the
        quantity and toxicity of waste streams and costs of waste management.

        The ATC will  need to gain the support and  "buy-in" of the operating staff in the development
 and implementation of waste reduction activities.  All material will need to be prepared in terminology
 which the appropriate staff can understand.  Information provided on Material Safety Data Sheets
 (MSDSs), for example, cannot always  be easily interpreted by the operating personnel.

        Because of the diversity of waste streams, further progress in waste reduction at the ATC will
 require  many small steps over time resulting from a concerted effort toward identifying, developing
 and implementing pollution prevention  alternatives and tracking progress made.  Specific options
 recommended for consideration in each process area are identified in Table 9 and discussed below.
 A summation of potential demonstration projects identified as a result of this PPOA  is presented at the
 end of this section.

 FLIGHT SIMULATORS

 Flight Simulator Contract Incentives

        The flight  simulators  are subject to  maintenance at regular intervals.  This effort is mainly
directed at keeping the simulators available for training purposes  as dictated by the  Simtech contract.
Therefore, very little attention is given to maintenance of the pipes or pumps where  hydraulic fluid is
leaked or spilled.  This area could benefit from a waste minimization effort.
                                             26

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                        TABLE 9. SUMMARY OF RECOMMENDED
                           POLLUTION PREVENTION OPTIONS
Waste Stream
Pollution Prevention Option
Flight Simulators

 Hydraulic Fluid
Contract incentives for waste minimization

Recovery of liquid hydraulic fluid using pans and wringer for
absorbents

Investigate reuse of recovered hydraulic fluid
Aircraft Maintenance
 Maintenance Materials
 Engine/Gearbox Oil

 Survival Raft Wipe
   Cleaner

 Paint Application and
   Cleaning Solvents
 Used Batteries
Centralize control of material distribution

Assess lifecycle benefits of alternative cleaning agents

Replace solvent-vehicle aerosol dispensing cans with recharge-
able compressed air or manual pump dispensers

Investigate conditioned-based oil maintenance scheduling

Replace toluene with less toxic wipe  cleaner
Increase use of high volume-low pressure (HVLP) paint spray
guns

Match size of HVLP gun with job coating requirements

Replace aerosol can application with HVLP spray guns whenev-
er possible

Recycle/exchange program for lead-acid (automotive) batteries

Negotiate battery reclamation agreements with suppliers of
aircraft batteries
                                       (continued)
                                           27

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 Waste Stream
 Aircraft Fueling

  Fuel Spills
  Recovered Fuel
  Fuel Samples
Aircraft Washing
                                   TABLE 9.  (continued)
 Pollution Prevention Option
 Use wringer on absorbents for spill containment and recovery

 Construct containment barriers in fuel farm transfer area

 Improve instructions and training for fuel transfer activities

 Eliminate rainwater entry into bowser for waste fuel storage

 Segregate waste fuel from waste oils, solvents, etc.

 Investigate reuse of recovered fuel

 Adhere to fuel sample size requirements

 Investigate alternatives to "clear and bright" analysis
 Rinsate
Investigate potential use of more "environmentally friendly"
soaps

Standardize soap mixing and cleaning procedures

Assess effectiveness of oil water separator
                                            28

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       ATC should consider modifying the Simtech contract to provide incentives for prevention of
leaks and spills.  The contract should also require implementation of a maintenance program directed
specifically at eliminating or preventing hydraulic fluid leaks/spills.

       Although this approach would require additional labor hours for the leak prevention/
maintenance program, time will be saved which would otherwise be used in spill response and waste
management activities.  Furthermore, there will be benefits realized in the form of less consumption of
hydraulic fluid, much reduced waste disposal cost and reduce  potential for environmental
deterioration.

Flight Simulator Hydraulic Fluid Recovery

       The simulator operations produce a significant waste stream from hydraulic fluid leakage and
spill cleanup.  Hydraulic fluid from leaky piping  joints is collected in pans placed under the joints.
Approximately 50-60 percent of the hydraulic fluid leaked/spilled is directly collected as liquid;
absorbents are used for the remainder.  Previously, the leaked fluid was captured by absorbents,
which were then disposed of at cost as hazardous waste.  With the recovery of liquid hydraulic fluid,
ATC has been able to sell the spent material at $0.03 per gallon to an off-site  fuel recycling
contractor. Overall, this has reduced the cleanup absorbent waste load by about 50 to 60 percent,
thereby halving absorbent purchase and disposal cost. This effort also produces some revenue from
the sale of fluid.  It is strongly recommended that this effort continue.

       The absorbents are disposed of as hazardous waste.  This hydraulic fluid can be recovered
by  using a wringer to recover the fluid from the absorbents. Figure 2 shows a typical wringer. ATC
already uses a spill cleanup cart with a wringer for fuel spills.  The same can be used for recovering
the hydraulic fluid. An estimated 90 percent of the absorbed hydraulic fluid can be recovered through
wringing out the used absorbents.

        The use of a wringer will reduce simulator spill cleanup solid waste by approximately half,
thereby reducing the corresponding waste disposal cost.  The recovered waste hydraulic fluid volume
will increase, resulting in additional revenue from sales of the  waste hydraulic  fluid at $0.03 per gallon.
In addition, the absorbent material can be reused with an average 75 percent  absorption capacity.

                                               29

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Figure 2. Typical absorbent wringer.




               30

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This will limit future absorbent material purchases and further reduce waste disposal costs.  The labor
hours required in the wringing process should be minimal and will likely be compensated by the
savings realized in waste management labor hours.  Overall, this option not only offers savings in
purchase of raw materials and waste disposal costs, but also offers additional revenue from waste
fluid sale and environmental benefits from less waste disposal.

        As an extension of this option, the recovered hydraulic fluid should be investigated for
possible on-site reuse potential, either for the original purpose or any other purposes such as fuel for
an on-site boiler. The increased volume may justify steps to make reuse viable.

AIRCRAFT MAINTENANCE

Centralized Material Control

        Each airframe shop and the engine  shop have their own material lockers.  The use of  these
 lockers is monitored by the  respective Point Manager.   As indicated in Section 2,  many of the
 materials used  in each shop are the same or similar.  This option would combine the four material
 lockers and establish a centralized control point for management of maintenance materials.

        Table 2 identified the commonality between materials used  and stored in each of the lockers.
 Most of these materials  are in pint or quart  cans or aerosol cans.  Material usage rates  vary
 significantly, from less than one to over 100 cans per year. By combining the material lockers with
 centralized control, several benefits will be realized. The  similarities between maintenance activities
 and materials used point toward more effective use of resources if control of materials for
 maintenance activities is centralized. A centralized management responsibility can more effectively
 work with procurement to match purchasing rates with use rates.  Policies can be more  easily
 implemented which will  result in elimination of duplicate materials and better inventory control, thereby
  reducing shelf-life losses.  Material management responsibilities would include tracking material shelf-
  life extension dates based  on re-inspection information sought from the appropriate supply organiza-
  tion. This option should result in reduction of  material usage and loss rates at  little or no cost in
  personnel resources. The increased efficiency in material management would  more than offset any
  perceived expansion in responsibilities currently split between  Point Managers.
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  Alternative Cleaning Solvents

         Numerous cleaning materials are used in maintenance activities.  Most of these products use
  organic solvents which either evaporate or are collected as hazardous wastes.  This includes use of
  pure solvents, aerosol formulations and liquid cleaners.  In an effort to reduce the cleaning solvent
  waste  stream, the ATC has recently terminated the use of  several organic solvent-based parts
  washing units.  One unit  remains in operation in the maintenance area and a new unit has been
  added which uses a water-based formulation.

         In many industrial settings, alternatives to the use of organic solvents have been found
  resulting in reduced waste generation.  Emphasis has been placed on replacing chlorinated-fluorocar-
  bons (CFCs), chlorinated hydrocarbons, and volatile organic compounds in general. Alternative
  approaches range from process changes, to eliminating the need for cleaning altogether, to use of
  aqueous and semi-aqueous based approaches.  A recent EPA report, Eliminating CFC-113 and
  Methyl Chloroform in Aircraft Maintenance Procedures (EPA-430-B-93-006) identified alternative
 cleaning approaches for the full range of aircraft cleaning requirements.  Table 10 lists the alternatives
 identified for aircraft cleaning in the EPA report.  Many of these alternatives would be directly applica-
 ble to the ATC cleaning needs.

        MIL-SPECs  have  been established for cleaning materials which authorize the use of
 alternatives to organic solvents. For example, MIL-C-87936A applies to cleaning aircraft surfaces with
 water-dilutable compounds, authorizing alkaline based cleaners (Type I) and non-halogenated organic
 solvents-based cleaners (up to 45 percent organic solvent by volume, Type II).  Cleaning of
 aerospace equipment including aircraft, engines, and ground vehicles is addressed by MIL-C-87937A
 which authorizes terpene-based cleaners (Type I)  and alkaline-based cleaners (Type II).

        The ATC has taken positive steps toward  reducing waste generation from aircraft mainte-
 nance cleaning activities.  Further progress wiil require careful consideration of the available options
 and the specific  needs of each application, which is beyond  the scope of this report.  A detailed
 assessment of cleaning alternatives should be conducted. The assessment should characterize the
 specific  cleaning applications and needs in aircraft maintenance at the ATC, the cleaning  alternatives
 available (inventory analysis), and the  life cycle implications  of each alternative (impact analysis).
Consideration should be given to the waste streams generated, the environmental media impacted
                                              32

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TABLE 10. SUMMARY CHART OF AIRCRAFT MAINTENANCE CLEANING
 APPLICATIONS AND FEASIBLE ALTERNATIVE CLEANING METHODS
Cleaning
Application
Aircraft Exterior
Landing Gear
Engine or Engine
Modules
Engine or Engine
Modules:
Assembled and
Semi-Assembled
Parts
Flight Control
Surfaces
Electrical Equipment
Hydraulic Lines
Aircraft Seat Covers
and Curtains/
Draperies
Current Cleaning Method
Aerosol Spray or Hand-Wipe
In-Shop Overhaul: Vapor Degreas-
ing or Aerosol Spray
On-the-Aircraft Maintenance: Aero-
sol Spray
Vapor Degreasing
Vapor Degreasing
Vapor Degreasing or Hand-Wipe
Vapor Degreasing or Hand-Wipe
Vapor Degreasing
Immersion
Immersion
Aerosol Spray or Hand-Wipe
Aerosol Spray or Hand-Wipe
Aerosol Spray
Hand-Wipe or Vapor Degreasing
Dry Cleaning
Alternative Cleaning Method1
Aqueous Cleaning - Alkaline (Light Soil
Removal)
Semi-Aqueous Cleaning - Alkaline & Aliphatic Naphtha
(Moderately Heavy Soil Removal)
Semi-Aqueous Cleaning - Alkaline & Aliphatic Naphtha
(Heavy Soil Removal)
Semi-Aqueous Cleaning - Terpene
Aqueous Cleaning - Alkaline
Semi-Aqueous Cleaning - Mineral Spirits
Aqueous Cleaning - Alkaline
Aqueous Cleaning - Hot Tank
Aqueous Cleaning - Alkaline, Hot Tank
Aqueous Cleaning - One Step Heavy-Duty Alkaline
Aqueous Cleaning - Alkaline
Blasting - High Pressure Steam/Water
Aqueous Cleaning - Alkaline, Hot Tank
Aqueous Cleaning - Four Step Heavy-Duty Alkaline
Aqueous Cleaning - Alkaline
Aqueous Cleaning - Alkaline
Organic Solvent Cleaning - Acetone
Aqueous Cleaning - Alkaline, Ultrasonic
Organic Solvent Cleaning - Isopropyl Alcohol
Aqueous Cleaning - Water-Base Soap Solution
Wet Cleaning Technologies
                         (continued)
                            33

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                                          TABLE 10.  (continued)
Cleaning
Application
Prior to Coating:
Polyurethane
Chromate
Conversion
Other
Prior to Adhesive
Bonding
Fluorescent
Penetrant Inspection
Prior to
Reassembly
Prior to Welding
Prior to Painting
Current Cleaning Method
Hand-Wipe
Spray or Hand-Wipe
Hand-Wipe
Aerosol Spray or Hand-Wipe
Hand-Wipe or Immersion
Hand-Wipe or Immersion
Aerosol Spray or Hand-Wipe
Alternative Cleaning Method1
Semi-Aqueous Cleaning - Alkaline and Aliphatic
Naphtha
Organic Solvent Cleaning - Isopropyl Alcohol
Semi-Aqueous Cleaning - Terpene
Organic Solvent Cleaning - Isopropyl Alcohol, or
Acetone
Organic Solvent Cleaning - Isopropyl Alcohol or
Acetone
Organic Solvent Cleaning - Isopropyl Alcohol or
Acetone
Organic Solvent Cleaning - Acetone
Derived from EPA Publication:  Eliminating CFC and Methyl Chloroform in Aircraft Maintenance Procedures (EPA-430-B-93-
006).

 Organic solvents such as aliphatic naphtha, terpenes, acetone, and isopropyl alcohol may be regulated as volatile organic
compounds (VOC).
                                                      34

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(air, water and land or solid waste), the costs (purchase, operating, and waste management costs)
and other concerns such as health and safety. Opportunities to reduce environmental releases,
energy consumption, and material use should be evaluated (improvement analysis). The principles
for conducting a life  cycle analysis are described in EPA report Life-Cycle Assessment: Inventory
Guidelines and Principles (EPA/600/R-92/245).

Alternative Aerosol Dispensing Systems

       The ATC purchases several products in aerosol cans which are used in relatively large
quantities. For example, over a thousand cans per year of spray cleaners are used in aircraft
maintenance.  Aerosol products typically contain  10 to 25 percent of the material to be applied and 75
to 90 percent propellant or dispersing agent.

       Agents are typically organic compounds,  gases or fast evaporating liquids.   The application of
an aerosol product results in the release of the agent to the atmosphere.  Relative to non-aerosol
material packaging,  many more containers are needed to deliver the same volume of applied material.
This option recommends considering alternative dispensing systems to the aerosol cans.

       Although aerosol cans offer a unique, controllable delivery  system, the same performance
requirements can frequently be met using refillable aerosol dispensers which are charged with
compressed air.  Manual pump sprays can  also meet the needs in certain applications. Both
approaches allow for the purchase of the material to be applied in  bulk form, eliminating the need for
agents in the purchased material  and significantly reducing the volume of containers which must be
managed. Reduced use of aerosol cans will also result in reduced release of volatile organic
compounds to the atmosphere, reduced occupational exposure to these compounds and reduced
shelf-life losses.  The ATC airframe maintenance shops are currently using compressed air charged
dispensers, "Sure-Shots", to a limited degree.  Increased emphasis should be placed on the use of
these dispensers. Each function/application currently supplied by aerosol can dispensing systems
should be evaluated to determine the potential for use of alternative dispensing systems. First
preference should be given to non-aerosol dispensing techniques.  Manual and/or compressed air
charged dispensers  should then be evaluated to determine the effectiveness of these delivery
systems for the specific application.
                                             35

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 Condition-Based Oil Replacement

        Currently, preventative maintenance of the airframe engines in the Dauphin Helicopter and the
 Falcon Jet require replacing the engine oil every 150 hours of operation and gearbox oil every
 450 hours of operation. For the Jayhawk Helicopter, however, replacement is based on the condition
 of the oil.  This option would establish a similar practice of replacing the engine and gearbox oil in the
 Jayhawk Helicopter and Falcon Jet on the basis of oil condition.

        The benefits of this option would be a function of the extended life of the oil. Savings would
 result from reduced maintenance  personnel time associated with fewer oil changes and reduced
 purchases of fresh oil.  A 10 percent increase in the life of the oil, for example, would reduce oil
 consumption by an estimated 200 to 300 gallons per year at the ATC.  Costs to implement this
 approach would be associated with the periodic analyses  required to track the oil condition.  Currently,
 oil analyses are conducted on a regular basis for each aircraft to identify metal content as an indicator
 of engine wear.  Additional analyses would  likely be necessary to insure the desired properties of the
 oil are maintained.  For example,  MIL-SPEC requirements for new oil include  analyses of viscosity,
 corrosion  and oxidation stability, sediment, acidity and other parameters, in addition to metal content.
 The condition analyses would require testing a sufficient set of parameters to  track any excessive
 changes in performance characteristics.

        Contacts were  made with  personnel of the U.S. Air Force and Navy and two commercial
 airlines, USAIR and Northwest Airlines, to determine whether they had preventative maintenance
 procedures in place for oil changes based on oil condition.  All of the operations contacted indicated
 oil changes were based on engine operating hours, and no procedures for tracking oil condition were
 found.

       In order to investigate this option further, the current practices with the Jayhawk Helicopter
 should be examined. Information  should be collected on the frequency and variability of oil
 replacement and the cost associated with the analyses to track the oil condition. The applicability of
these specific analyses to the Falcon Jet and Dauphin Helicopter should then  be assessed.
                                             36

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Aircraft Survival Shoo

Alternative Wipe Cleaner-
        The aircraft survival shop currently uses an estimated 12 gallons per year of toluene to clean
rubber surfaces prior to the application of glues.  This option recommends replacing toluene with an
alternative wiping compound.

        Toluene is a very effective aromatic solvent, but is potentially more toxic than other solvents
which may be effective in this application.  Acetone, for example, may provide the same cleaning
potential on rubber as toluene, and has reduced exposure concerns.  For example,  the occupational
exposure limit for toluene set by the American Conference of Industrial Hygienists (ACGIH) is 50 ppm
for an 8-hour time  weighted  average (TWA); the 8-hour TWA exposure limit for acetone is 750 ppm.
EPA's voluntary pollution prevention initiative, the 33/50 Program, has also targeted toluene for
reductions in use.

        The aircraft survival  shop should conduct a study of the effectiveness of alternative solvents,
such as acetone, in providing the degree of cleaning and surface preparation necessary for raft repair
work.  Isopropyl alcohol (400 ppm 8-hour TWA) and terpene-based cleaners have also been identified
as effective in cleaning substrates prior to adhesive use (see Table 10).  Any of these alternatives, if
effective, would result in reduced use  of toxic materials.

Paint/Composites and Metal Shops

Paint Application Alternatives-
        The paint  and  composites shop currently uses a number of approaches to applying paints.
Aerosol cans are used for a variety of coating activities for smaller surface areas. Conventional
 compressed air spray guns  with different size reservoirs, such as pint and quart size, are used for
 coating applications within the on-site  paint spray booth.  High volume-low pressure (HVLP) paint
 spray guns are used for coatings applied to aircraft in the hangar. This option recommends greater
 use of HVLP spray guns and centralized control of paint application.

         The aerospace industry is relying increasingly on HVLP application guns to increase transfer
 efficiencies and reduce solvent emissions to the atmosphere. The lower pressure results in less

                                                37

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 random paint particles and better control of the spray pattern.  HVLP has been found to be effective in
 most aerospace applications.  An EPA Section 114 Clean Air Act survey of HVLP users found
 increased transfer efficiency estimates from 25 to 80 percent.  Increased transfer efficiencies result in
 savings in coating usage and solvent emissions.  The use of HVLP in the hangar has been driven
 largely by the need to reduce paint drift.  However, using this approach in all coating applications
 including those in the paint booth would reduce air emissions, volume of paint slops, and overall paint
 usage in proportion to the improved transfer efficiencies.

        The use of HVLP guns is also recommended to replace a portion of  the aerosol can paint
 usage.  To affect this change, all paint application should be controlled by the paint and composite
 shop. The shop should determine which applications can reasonably be addressed with HVLP guns.
 Aerosol cans offer the convenience of immediate availability and portability.   However, the paint and
 composite shop staff are able to prepare paint application volumes using appropriate sized  paint gun
 reservoirs to match application sizes of aerosol cans.  Coating needs that cannot be reached by
 compressed air units will continue to  require the use of aerosol cans.  Decreased aerosol can use will
 result in a decrease in shelf-life losse0, particularly from  partially used cans, and decreased container
 disposal.  The increased use of HVLP in favor of aerosol cans will result in an increased frequency of
 use of the paint gun cleaning unit.  In addition, the purchase of additional HVLP spray paint guns may
 be necessary to address any increase in frequency and  size of application.

 Battery Shop

Automotive Battery Exchange-
       ATC discards approximately 20 auto batteries per year at an expense of $0.70 per pound
through DRMO.  Satellite Services exchanges old automotive batteries for new ones at a reduced cost.
Therefore, Satellite Services not only saves in waste disposal cost, but also in rebates on new batteries
for the exchange of old ones. ATC should start a similar battery exchange program independent of or
in concert with Satellite Services.  Consequently, ATC will also be able to save on battery disposal cost
and receive rebates on the purchase of new batteries in exchange for the old ones.
                                              38

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Aircraft Battery Reclamation--
       Aircraft batteries from the battery shop disposed of as waste are NiCd, Lithium and Mercury
batteries.  Many battery manufacturers offer reclamation programs, where they accept waste batteries
from buyers.  Some manufacturers may even pay a nominal fee for them. ATC has indicated that
since it does not directly buy these batteries from manufacturers but works through suppliers, it can
not directly negotiate with the manufacturers. In order for this option to be effective, ATC must work
with its suppliers to establish a process that allows waste batteries to be shipped back to the
manufacturers for reclamation.

        Different manufacturers have their own  requirements with  respect to their reclamation
programs.  ATC, therefore, would have to tailor its battery collection, segregation and  shipping
accordingly. At present ATC spends approximately $403.00 per year on battery waste disposal.  It is
anticipated that the only expense incurred by ATC with respect to  manufacturer battery reclamation
would be shipping the waste batteries. This may be offset by nominal fees paid by the
manufacturers.  In addition, some manufacturers offer rebates on  new battery purchases.  The
opportunity exists for the ATC through one mechanism or another to eliminate this waste stream from
waste disposal and  save in disposal costs.  Since these batteries  are already collected and disposed
of separately,  there should not be a significant labor hour increase by switching to  manufacturer
reclamation programs. Overall, there appears to be a potential for a net savings from adoption of this
option.  The most significant benefit, however, is in the prevention of waste battery disposal.

AIRCRAFT FUELING

Fuel Spill Recovery

        ATC  has acquired a Wringer to recover JP-4 fuel from the fuel spill cleanup absorbents.  The
wringer is on a 55 gallon drum in the spill cleanup cart and is brought to the  spill site  during cleanup
operation. The fuel spill absorbents are  squeezed by the wringer, and the fuel drops  are collected in
the 55 gallon drum  on which the wringer is attached.  The wringer absorbents are  collected in an
accompanying 55 gallon drum. The wringer can reclaim up to 90 percent of the fuel from the
absorbents.  The absorbents can be reused with about 75 percent of their original absorption
capacity.
                                              39

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       The absorbents are discarded when their absorption capacity falls below about 50 percent
which usually occurs after about two to three times of use.  The discarded absorbents are about 50
percent to 60 percent lighter than the unsqueezed absorbents, depending on how often they have
been reused. The cost of disposing of the spill cleanup waste is thus reduced by at least half. The
fuel recovered from spill cleanup is dumped  into the waste bowser and sold at $0.03 per gallon minus
$0.50 per gallon of water  that is mixed with the fuel. Overall, this procedure has allowed ATC to
reduce the  waste  management cost of the fuel spill cleanup.

       It is not clear, however, that this practice is currently used at all of the fuel spills at ATC.  It is
recommended that this  practice continue and be  formalized as a required spill response technique.

Eliminate Rainwater Entry to Bowser

       The waste bowser receives waste oil and fuel from maintenance activities. During waste
transfer to the bowser, the inlet and funnel remain unattended for a considerable period of time.
During rainfall, rain can enter the bowser under these conditions, increasing the water content of the
bowser waste.  The bowser waste is sold at $0.03 per gallon minus $0.50 per gallon of water mixed
with the waste.  Therefore, the value of the waste oil can be increased if the water content of the
bowser can be eliminated/reduced.

       This option recommends that the bowser opening be covered when waste transfer activity is
not being performed, especially during  rainfall.  This can be accomplished by merely placing a cover
over the funnel  and inlet opening.  Alternatively, a funnel with a  hinged cover at the top could be used
to allow closure when not in use.  Waste transfer personnel should also be required to keep the
bowser closed when not in use.  Adopting these  measures should eliminate  rainwater entry  into the
bowser.

       The ATC  should develop written instructions for the waste transfer operations. These
instructions should include procedures for limiting water contamination of the bowser. All waste
transfer personnel should  be trained and familiarized with the procedures before being authorized to
handle waste transfer.  Increased supervision and reporting requirements should also be included in
the instructions  to ensure  adherence to the required procedures.
                                             40

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Bowser Waste Segregation

       The Bowser receives waste JP-4 fuel, waste oils, and other petroleum-based products.  By
combining these wastes, recovery alternatives are limited.  The wastes can not be recovered for
usage on-site for original or even lower-quality purposes.  Therefore, in order to consider such
possibilities, the waste streams must  be segregated.  This option recommends that two bowsers be
used, one for fuel, one for other petroleum-based wastes.  This will limit degradation of the quality of
one stream by the other.  This option can be further extended to segregate the different types of oils
such  as hydraulic fluid, engine oil, turbine oil,  etc.  Separately collected waste steams can be
potentially  reused for original purposes after cleaning or for lower-quality purposes.  For example,
segregated JP-4 could be refiltered at the tank farm for reuse in aircraft or mixed with diesel fuel for
use by ground support vehicles.  Similarly, waste oils can continue to be sold for off-site recycling.
Further guidance on reuse of fuels and oil is found in Technical Manual T.O. 428-1-23, Management
of Recoverable and Waste Liquid Petroleum Products, issued by the Air Force.

        With this option, as a minimum, it is expected the waste fuel can be used on-site in diesel fuel
resulting in savings in the form of less diesel consumption.  A unit saving rate higher than the $0.03/
gallon received from selling waste fuel for off-site recycling would be realized.

Fuel Transfer Spill Prevention

        The Assessment Team was  informed that most spills from fuel transfer activities occurred due
to unsupervised or unattended fuel transfer, especially at the fuel farm. Additionally, failure of shut-off
valves resulted in overfill spills.  This option, therefore, recommends that overfill protection systems in
 all fuel transfer facilities and equipment be installed correctly, examined carefully, and tested periodi-
 cally to ensure reliability.

        At the ATC, most transfer facilities and equipment are equipped with mechanical automatic
 valves.  As stated above, malfunctions of these valves have contributed to overfill spills. To avoid this,
 regular testing and maintenance of these valves is necessary.  As an alternative, electronic automatic
 valve systems with self-checking routines are available; these  should reduce the risk of an overfill
 caused by a malfunctioning mechanical valve.  The effect of vibration and  erosion from humid or
                                               41

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marine environments on contact switches should also be considered.  Regular testing and
maintenance of overfill protection systems should reduce the risk of such problems.


        In summary, the following procedures are recommended to avoid or minimize fuel spills during
fuel transfer activities:
1.      Follow National Fire Protection Association (NFPA) and American Petroleum Institute (API)
        recommendations when selecting, installing, and testing overfill protection systems.

2.      Have written operating instructions available for specific locations describing orderly, simple
        shutdown and emergency procedures

3.      Each fuel transfer activity should be planned, monitored, and completed in accordance with
        the written instructions.

4.      All fuel transfer activities must be performed by an adequate number of operators, and at no
        time should the fuel transfer be performed unattended or unsupervised.

5.      All personnel involved should be adequately trained and be familiar with all aspects of fuel
        transfer activities and emergency procedures before assignment to fuel transfer activities.

6.      A testing, inspection, and maintenance program should be incorporated for fuel transfer
        facilities and equipment,  including overfill protection systems.  This program should  include an
        account of manufacturer recommendations.  Industry organizations, government regulations,
        and ATC policies may necessitate additional tests and maintenance  procedures.  This
        program should include written instructions, a regular schedule, and  recording procedures.
        In adopting this option, fuel spills occurring during transfer activities should be minimized,
resulting in a reduction in spill cleanup and disposal cost and in fuel consumption/purchase.  It is
anticipated that a slight increase in labor hours will be necessary for the rigorous implementation of
the maintenance program; this increase will be more than balanced by the savings in labor hours
used in spill cleanup operations. An additional benefit derived from this will be the prevention of soil
and groundwater contamination from fuel spills, especially at the fuel farm.


Spill Containment


        The fuel farm has no containment available during the fuel transfer operations.  From past
spills, soils in this area appear stained, and depending on the spill size and frequency, possible
groundwater contamination cannot be ruled out. Therefore, containing and cleaning fuel spills at the
                                              42

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fuel farm is of paramount importance. Also, temporary containment measures are needed at spills on
paved areas to avoid the spread of contamination and enable maximum cleanup.

       This option recommends that fuel transfer stations at the fuel farm be encompassed by
permanent containment.  This will allow containment of any spills within these structures for cleanup
or recovery, and contamination of soils or groundwater will be prevented.

       Apart from the fuel farm, where a permanent containment structure is recommended, this
option recommends temporary containments be utilized at all fuel transfer activities on paved areas.
Before performing the actual transfer, spaghetti absorbents should  be placed around the transfer
area and absorbent pads placed under the  transfer equipment.

       Once the spilled fuel is contained, it should be recovered by using the wringer/squeezer,
which is available at the ATC on the spill cleanup cart.  Recovered fuel should be reused  or recycled
as described under the Bowser Waste Segregation option.  Similarly, the absorbent material should
be reused as described under the  Simulator Hydraulic Fluid Recovery option.

       This option does  not incur any additional cost except the permanent containment structure at
the fuel farm. ATC already uses a wringer to recover spilled fuel; therefore, there should be no
measurable increase in the labor hours. Savings will be realized due to fuel recovery and absorbent
reuse.  An additional benefit from this option will be increased prevention of soil and water
contamination and potentially reduced environmental cleanup cost.

       In implementing this option, the ATC should prepare  written instructions for performing spill
containment and cleanup/recovery operations. All concerned personnel should be trained and
familiarized with the relevant procedures for continuous success of this option.

Reduce Fuel Sample Size

       The sample size for fuel analysis is specified in the TIMI (T-203-92 September 3,  1993) for
Aircraft Fuel Surveillance. In actual practice,  however, this is not being followed. The sample size in
practice is typically larger than necessary.
                                             43

-------
        This option explored ways to reduce the size of the fuel samples.  Alternative methods were
 considered as described in the next option for fuel surveillance, but no proven technique was
 identified. Therefore, the only way to minimize waste from fuel samples is to strictly adhere to the
 required sample size and prevent taking larger than required samples. The above mentioned TIMI
 requires the taking of approximately one pint of fuel sample. Adherence to this  requirement should  be
 implemented through training, supervision, recordkeeping, and worker performance evaluations.  It is
 estimated that present samples are approximately two to three times the required sample size.
 Therefore, the quantity of fuel sample waste could be reduced by between one third and two thirds by
 strict adherence to the required sample size.

        No extra labor hours should be required to implement this option, while waste handling labor
 hours may be reduced due to less waste generated.  Also, lower waste disposal costs and fuel
 savings should occur.

 Alternative  to "Clear and Bright" Analysis

        The current "clear and bright" analysis is used to visually observe fuels for water and
 sediment. Alternative techniques for fuel surveillance were considered to replace the "Clear and
 Bright" analysis, allowing for a minimum sample of fuel  to be taken. There are indicators of new and
 alternative techniques, such as lasers, to be used for fuel surveillance that might require smaller
 samples.  No proven alternative techniques, however, could be identified. The Defense Fuel Supply
 Center,  which manages Air Force fuel supply, requires visual testing of fuels  as a part of fuel
 surveillance.  It appears that "Clear and Bright" analysis is an industry norm and should continue to
 be used until new and improved techniques are identified.

 AIRCRAFT WASHING

 Environmentally Friendly A/C Washing Soaps

        ATC uses Aircraft Soap Types 1, 2, 4,  and 5. Rinsate from aircraft washing is discharged to
the publicly owned  (wastewater) treatment works (POTW) through the sanitary sewer from the new
wash rack and at the stormwater sewer from the old wash rack.  According to the ATC, the POTW is
satisfied with the discharge and requires no permits.  Similarly, the ATC has determined that

                                             44

-------
discharge to stormwater sewer is also not environmentally threatening based on the test results.  This
information indicates no apparent need to consider replacing the current soaps with any alternative
"environmentally friendly" soaps.

       The Material Safety Data Sheets (MSDSs) of the soaps being used indicate that the following
compounds are present:

       Type 1          Dipropylene Glycol Methyl Ether, Hexylene Glycol, Morpholine
       Type 2          Dipropylene Glycol Methyl Ether
       Type 4          Mineral Spirits, 2-Butoxyethanol, Hexylene Glycol
       Type 5          Naphtha, 2-Butoxyethanol, Hexylene Glycol

       The measurement of these constituents in the discharge from aircraft washing is beyond the
requirements of the permit for the new wash rack. In the future,  additional chemicals such as these
found in aircraft soaps may be of concern in wastewater discharges.  Consideration should be given
to conducting a limited sampling program to determine the concentration of soap constituents in
discharged washwater. Target  chemicals could be measured and their use quantities tracked to allow
for development of a predictor  for all soap species.  It is likely that future concerns may develop by
the  POTW, local or state environmental agencies  for the rinsate discharge to the sanitary or
stormwater sewer.

       The U.S. Air Force  was contacted to identify soaps they were using for aircraft washing.
Information received is summarized as follows:

       Soap                 Hazardous Ingredients
       Megapower 1000-66    Petroleum Aromatic Distillate,  Diethyl Glycol Monobutyl Ether
       AVIAWASH 4000      None
       AVIAWASH 5000      Sodium Metasilicate Pentahydrate, Quaternary Ammonium Sulphate
       Turboclean            None
                                            45

-------
        AVIAWASH Green     Sodium Metasilicate Pentahydrate
         Gel
        Megapower Cleaner meets the requirements of MIL-C85570A Type I (QPL).  No information
could be obtained on the specifications of the other soaps.  These soaps are also not devoid of the
ingredients which may raise concern with the exception of AVIAWASH 4000 and TURBOCLEAN.  The
ATC personnel should investigate whether these soaps would be effective in meeting their needs and
consider replacing the existing soaps to reduce discharges of potentially toxic materials.

Aircraft Washing Specifications

        During the aircraft washing observations and conversations with the ATC personnel, it was
determined that the  soap is mixed with water without employing required measurements.  In addition,
the cleaning crew sometimes uses unauthorized soaps which are brought from outside of the base,
especially when the crew is unsatisfied with the results of the specified soaps.  Due to these
practices, the constituents and their concentrations in the rinsate may not be as insignificant as in
previous waste streams.

       This option recommends that aircraft cleanup operations be standardized with clearly written
specifications regarding the type and quantity of soaps to be used, measurement and mixing
procedures, soap application procedures, rinsing procedures, absorbent use procedure, etc.  It is
understood that such standard specifications exist but are often ignored.  In order to overcome this,
increased supervision, training, environmental awareness and task reporting should be considered.
Failure to follow proper procedures  and use authorized materials may result in water quality problems
in the future and the required change to a closed system for aircraft washing.

Optimize Oil/Water Separation System

       ATC personnel indicated the oil/water separator associated with the west wash rack was not
meeting performance expectations.  The separator was believed to be either inadequately designed or
improperly installed. The ATC should initiate an effort to evaluate the performance of the unit and
determine whether any oil and grease is currently being discharged and what alternatives are
available to mitigate this problem and gain satisfactory performance.
                                             46

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POTENTIAL DEMONSTRATION PROJECTS


       Several projects were identified as a result of this PPOA which, if successful, would improve

the understanding of pollution prevention alternatives with broader applicability than the ATC.  The

most significant projects are:


1.      Lifecycle Analysis of Aircraft Cleaning. Conduct an indepth assessment of the cleaning needs
       and alternatives available from a lifecycle perspective in order to identify the preferred
       approach for each cleaning need in aircraft maintenance and repair.  Consideration should be
       given to chemical species, application technology, unit size, etc.

2.      Conditioned-Based Oil Replacement.  Assess the costs and benefits of tracking oil condition,
       rather than flight or operating hours, as the criteria for changing engine and gearbox oil.

3.      Fuel Sampling and Analysis.  Investigate alternative approaches to demonstrating on a
       continuous basis that onboard fuel supplies meet the expectations of the current "clear and
       bright" criteria for aircraft operation. The alternatives available for allowing fuel samples to be
       returned for reuse should also be identified.


       The Assessment Team believes additional work in each of these areas could  identify pollution

prevention alternatives which could be directly applied at other facilities with flight missions.
                                               47

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   APPENDIX A
PPOA WORKSHEETS
       48

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Finn  USC6 ATC
Site  Mobile, Alabama
Date November  3-5,  1993
      Pollution Privintlon
   Assessment Worksheets
          TRC-001
Proj. No.  PES  T003.001
Prepared By  Burch
Checked By
Sheet J	of
                                                                                  Memon
J,	of J	  Page	of
   WORKSHEET
        1
                                    ASSESSMENT OVERVIEW
                                      UutUtJt tw PvUuUon Pi•vMttton Program
                                           • Etacuta Uv4 Dwaiion
                                           • PeTcy Sakm«nt
                                           • CoriMmiM Buidng

                                              Orgutix* h
                                                      »*««4m*nt
                                                Ccfect OtS»
                                               • Eibbisk PriorilM
                                               Writ* Pretram PUn
                                             Coniidw EiUmil Group*
                                              D«vWep Sehtduli
                                                tla tnd SiSt(»)
                                                «nd Oeeuimnt Inkmnaion
                                              PoButlo* PrtvMtUoA OpU«M
                                               • Prspott Option*
                                              D« FatalbBlty AnaiytM
                                                •Technical
                                                • Emtonmcntai
                                                • Eoortomic
                                             Writt AiMttmtnt Rrport
                                               Imptomvnl ih« PUn
                                                • S«UctProj»cTi
                                                • Obtain Fundng
                                                 Mwr* Pregrcu
                                                Analyze fewlu
                                         Htlntoln PoHutton Pr>v>n
                                                 49

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F,rm  USCG ATC
site  Mobile, Alabama
Date  November 3-5,  1993
                    Pollution Pravantion
                  Assttsiment Workihwti
                       TRC-001
               Proj. No.  PES TQ03.0Q1
Prepared By Burch
          Memon
Checked By
Sheet  1 of J-  Page	of	
  WORKSHEET
                                SITE DESCRIPTION
       "  S   Toast KnarH
Plant:  Aviation Training
Deoartment:
Area:
Street Address:  Bates  Field
City:
Mobile
State/Z5o Code:  Alabama   36608
Teleohone:  (205) 639-6451
Major Products:—Basic  operational training units  for fixed and  rntarv wino
aircraft and a fixed  wing search and  rescue unit	

SIC Codes;	
EPA Generator Number AL3690307910

Major Unit:	
Product or Service;	
Operations:   Flight and search and rescue training including  use of flight
            simulators
            Aircraft  maintenance and  repair  including structural  mechanical
            and  electronic components
 Facilities/Equipment Age:   Facility corrmissioned  in 1966; formerly Air Force  Reserve
 Facility adjacent to Mobile Municipal  Airport
                                      50

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Firm USCG ATC A,
Site Mobile, Alabama
Date November 3-5, 1993 Proj. r-
Pollution Prevention
sessment Worksheet!
TRC-001
Jo. PES T003.001

WORKSHEET PROCESS INFORMATION
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Equipment Soecifications
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Emission Inventories
Annual/Biennial Reports
Environmental Audit Reoorts
Permit/Permit Applications
Batch Sheet(s)
Materials Aoolication Diagrams
Product ComoosKion Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules

Status
Complete?
(Y/N1
NA

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51

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Firm USCG ATC AI
Site Mobile, Alabama
Date November 3-5, 1993 Pmj. h
Pollution Pravantion
isessment Worksheets
TRC-001
to. PES T003.001

WORKSHEET PROCESS INFORMATION

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site Mobile, Alabama
Date November 3-5, 1993
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Operation Type:
Document


Pollution Prevention
Assessment Worksheets
TRC-001
Proi. No. PES T003.001

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PROCESS INFORMATION


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Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reoorts
Environmental Audit Reoorts
Permit/Permit Aoolications
Batch Sheet(s)
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Product Comoosition Sheets
Material Safety Data Sheets
Inventory Records
Ooerator Loqs
Production Schedules















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Complete? (
(Y/N)
NA

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53

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Firm USCG ATC A,
Site Mobile, Alabama
Date November 3-5. 1993 Proj. r>
Pollution Pravtntion
jassmant Worksheets
TRC-001
Jo. PES T003.001

WORKSHEET PROCESS INFORMATION
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Flow/Amount Measurements
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Analyses/Assays
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Discrete
Other
Status
Complete?
(Y/N)
NA

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Y
N




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Ooeratinq Manuals
Equioment List
Equipment Soecifications
Piping and Instrument Diagrams
Plot and Elevation Plants)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reoorts
Environmental Audit Reoorts
Permit/Permit AooHcations
Batch Sheet(s)
Materials Aoolication Diagrams
Product Comoosition Sheets
Material Safety Data Sheets
Inventory Records
Operator Loqs
Production Schedules


Y
N
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Y
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(Y/N)



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-















Location


































54

-------
nrm USCG ATC
Site Mobile, Alabama
Date November 3-5, 1993 Proj. N
Pollution Prevention
stssmant Worksheets
TRC-001
o. PES T003.0D1

WORKSHEET PROCESS INFORMATION

Pre
Ch
Sh



oared Bv Burch
ecked Bv Memon
eet 5 of f\ Paae of

Process UnityOoeration: PAINT, COMPOSITES AND Mf-TAL WlPS
Operation Type: Q Continuous C
D Batch or Semi-Batch C

Document
Process Flow Diagram
Material/Energy Balance
Desiqn
Ooeratinq
Flow/Amount Measurements
Stream



Analvses/Assavs
Stream



Process Descriotion
Ooeratinq Manuals
Eauioment List
Equioment Specifications
Pioina and Instrument Diaorams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reports
Environmental Audit Reoorts
Permit/Permit Aoolications
Batch Sheet(s)
Materials Aoplication Diagrams
Product Comooshion Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules

Discrete
Other
Status
Complete?
(Y/N)
NA

NA
Y
N




NA




Y
N
N
N
N
rt
N
N
N
N
Y
N
N
N
N
Y
Y
N
N

Current?
(Y/N)



Y










Y









Y




Y
Y



Last
Revision














Y









Y




Y
Y



Used in this
Reoort (Y/N)



Y






























Document
Number


































Location


































55

-------
R,m USCG ATC A.'
site Mobile, Alabama
Date November 3-5, 1993 Proi. N
'Dilution Prevention
1 1 j sm ant Work sh a ets Pr e
TRC-001 Ch
o. PFS T003.001 Sh

WORKSHEET PROCESS INFORMATION

oared Bv Memon
iCkfid BV Burch
set 6 of 8 Pane of

Prnc,« UnitttatratteK AIRCRAFT WASHING
Operation Type: D Continuous Q Dis(
D Batch or Semi-Batch D Oth

Document
Process Flow Diagram
Material/Energy Balance
Desian
Ooeratinq
Flow/Amount Measurements
Stream



Analvses/Assavs
Stream



Process Descriotion
Ooerating Manuals
Eauioment List
Equioment Soecifications
Pioino and Instrument Diagrams
Plot and Eevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reoorts
Environmental Audit Reoorts
Permit/Permit Aoplications
Batch Sheet(s)
Materials Aoolication Diagrams
Product Comoosition Sheets
Material Safety Data Sheets
Inventory Records
Operator Loqs
Production Schedules

:rete
er


Status
Complete?
(Y/N)
NA

NA
Y
N




MA




Y
N
N
N
N
N
rt
N
N
N
Y
N
N
N
N
Y
Y
N
N

urrent?
IY/N)



Y










Y









Y




Y
Y



Last
Revision









Used in this
Reoort (Y/N)



Y






I



Y

















Y




Y
Y















Document
Number


































Location


































56

-------
R,m USCG ATC
sit*. Mobile, Alabama
Dat* November 3-5, 1993
WORKSHEET
3
Process Unit70 Deration:
Operation Type:
Document


Pollution Prevention
Assessment Worksheets
TRC-001
Proi. No. PES T003.001

Prej
Che
She

PROCESS INFORMATION

jared BY Nje.Tip.n
eked BY Bur^h
et 7 of 8 Paae of

BATTERY SHOP
D Continuous Q Disc
D Batch or Semi-Batch D Oth<



Process Flow Diaoram
Material/Energv Balance
Desiqn
Ooeratinq
Flow/Amount Measurements
Stream



Analyses/Assays
Stream



Process Descriotion
Ooeratinq Manuals
Equipment list
Eauioment Soecifications
Pioino and Instrument Diagrams
Plot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reoorts
Environmental Audit Reoorts
Permit/Permit Aoolications
Batch Sheet(s)
Materials Aoolication Diagrams
Product Comoosttion Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules

rete
:r


Status
Complete?
(Y/N)
NA

NA
Y
N




NA




Y
N
N
N
N
a
f(
N
N
N
w
N
N
N
N
Y
Y
N
N

Current?
(Y/N)



Y










Y









Y




Y
Y



Last
Revision
Jsed in this
Reoort (Y/N)



Y





1






I
Y 1


1






1


Y










Y
Y










Document
Number


































.ocation


































57

-------
Firm USCG ATC
Site Mobile, Alabama
Date November 3-5, 1993 Proi.
Pollution Prevention
isessmant Worksheets
TRC-001
No. PES T003.0Q1

WORKSHEET PROCESS INFORMATION
0
P
C
S



reoared By Memon
hedced BY Burch
heet 8 Of 8 Paoc of

Process Unit/Ooeration: AVIONICS SHOP
Operation Type: D Continuous D Discrete
D Batch or Semi-Batch Q Other
Document
Process Flow Diagram
Material /Energy Balance
Desiqn
Ooeratinq
Flow/Amount Measurements
Stream



Analvses/Assavs
Stream



Process Descriotion
Ooeratinq Manuals
Equioment List
Eouioment Soeciffcations
Rpinq and Instrument Diaqrams
Pot and Elevation Ran(s)
Work Flow Oiaqrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reoorts
Environmental Audit Reoorts
Permit/Permit Aoolications
Batch Sheet(s)
Materials Aoolication Diaqrams
Product Comoosition Sheets
Material Safety Data Sheets
Inventory Records
Operator Logs
Production Schedules

Status
Complete?
(Y/N)
NA

NA
Y
N




MA




Y
N
N
N
N
N
if
N
N
N
Y
N
N
N
N
Y
Y
N
N

Current?
(Y/N)



Y










Y









Y




• Y
Y



Last














Y









Y




Y
Y





Used in this
Reoort fY/N)



Y






























Document
Number


































Location


































58

-------
F.rm USCG ATC AfP,
sue Mobile, Alabama
Date November 3-5, 1993 p^. Ne
oflution Prevention
essment Worksheets
TRC-001
. PES T003.001
Prepared Bv Btirr^h
Checked By MeirjQn
Sheet 1_ of JL Paoe , of

WORKSHEET ,NPUT MATERIALS SUMMARY
** SEE SECTION 2 OF WMOA


Name/ID
Source/Supplier

Component/Attribute of Concern

Annual Consumption Rate
Overall
Componcm(s) of Concern

Purchase Price, $ per
Overall Annual Cost

Delivery Mode1
Shipping Container Size &. Type2
Storage Mode3
Transfer Mode*
Empty Container Disposal Management5
Shelf Life
Supplier Would
— accept expired material? {Y/N}
— accept shipping containers? (Y/N)
— revise expiration date? (Y/NJ
Acceptable Substitute(s), if any
Alternate Supplier(s)


Description
Stream No.

























Stream No.

























Notes: 1. e.g. pipeline, tank car, 100 bbl tank truck, truck, etc.
2. e.g. 55 gal drum 100 Ib paper bag, tank, etc.
3. e.g. outdoor, warehouse, underground, aboveground, etc.
4. e.g. pump, forkfift, pneumatic transport, conveyor, etc.
5. e.g. crush and landfill, dean and recycle, return to supplier, etc.
Stream No.


























59

-------
F1rm USCG ATC J.
Site Mobile, Alabama
Date November 3-5, 1993 p^. Nc
Dilution Prevention
easment Worksheets
TRC-001
. PES T003.001
Prepared Bv Rnrrh
Checked Bv M^HIQn
Sheet 1 of 1 Paae of

WORKSHEET PRODUCTS SUMMARY
rj* .._._...,..
° NO PRODUCTS FROM OPERATION

Attribute
Name/ID

Component/Attribute of Concern

Annual Production Rate
Overall
Componentls) of Concern

Annual Revenues. $

Shipping Mode
Shipping Container Size & Type
Onsite Storage Mode
Containers Returnable fY/N)
Shelf Life
Rework Possible (Y/N)
Customer Would
— relax specification (Y/N)
— accept larger containers (Y/N)








Description
Stream No.


























Stream No.


























Stream No.


























60

-------
FirmUSCG ATC
sue Mobile, Alabama
DateNovember 3-5, 1993
Pollution Prevention
Assessment Worksheets
TRC-001
Proi. No. PES T003.001
Prepared By Memon
Checked By Burch
. Sheet 1 of 11 Page of

WORKSHEET WASTE STREAM SUMMARY
b
AIRCRAFT SIMULATORS
Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate {units )
Overall
Component(s) of Concern


Cost of Disposal
Unit Cost ($ pen )
Overall (per year)
^U.bU/gal tor water
Method of Management1

Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. (W)









Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
Hvd. Fl. lin
Leak/Spill
Simulator
LIU qa





703/ga


)ft-s1te
recyc e
Rating
180

)ff-site
recovery
Rating
(R) R x W









Z(RxW)

Stream No.














Rating
(R) R x W









I(RxW)

Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with neat recovery, distillation, dewatering. etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
61

-------
FlrmUSCG ATC
site Mobile, Alabama
DateNovember 3-5, 1993
Pollution Prevention
Assissment Worksheets
TRC-001
Proi. No. PES T003.001
Prepared BY Burch
Checked BY Memon
. Sheet ^ Of 11 paae Of

WORKSHEET WASTE STREAM SUMMARY
AIRCRAFT MAINTENANCE
Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate {units )
Overall
Component(s) of Concern


Cost of Disposal
Unit Cost ($ per: ba 1 }
Overall (per year)

Method of Management1

Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. (W)









Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
Mixed solvent
C oaninrj
Haz Waste
24 Gal





13 gal
^i?

Dtfsite
Recovery
Rating
(R) R x W









X(RxW)

Stream No.
> Shelf life
M-fc^
Haz Waste
24 Gal





13 qal
^12

Off site
Recovery
Rating
(R) R x W









I(RxW)

Stream No.

Misc

600 ibs








Lanaf i 1 1

Rating
(R) R x W









IlRxW)

Notes: 1. For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
62

-------
HrmUSCG ATC i*£i
SUB Mobile, Alabama T
DateNovember 3-5, 1993 Proi. NO. P
ion Pravtntlon
nan i Worksheets
RC-001
ES T003.001

Prepared BY Burch
Checked Bv Memon
Sheet 3 of 1 1 Page of

WORKSHEET WASTE STREAM SUMMARY
6 —
AIRCRAFT MAINTENANCE
Attribute

Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate {units Ga i S )
Overall
Components! of Concern


Cost of Disposal
Unit Cost ($ per fip i_ )
Overall (per year)
$0.50/aa for watpr
Method of Management1

Relative
Priority Rating Criteria2 Wt. (W)
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
)il
Eng/Gear Box
Haz Waste
937





Ln.n?
fc28
sn
leat Recovery

Rating
tRJ R x W









HRxW)

Stream No.
Hydraulic Flu-
Hydr Systems
Haz Waste
744





-n m
522
Zn
^at Recovery

Rating
(R) R x W









ZIRxW)

Stream No.
d SAF-Kleen Sc
Cold Uleanpr
Haz Waste
180





9 fln
$50»

Off site Recvrlp

Rating
(R) R x W









IIRxW)

Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
63

-------
iicrr ATP Pollutl
FlrmUbLb AIL A«**«tn
site Mobile, Alabama Tr
DateNovember 3-5, 1993 proi. No. Pf
on Prevention
lent Worksheets
IC-001
IS T003.001

Preoared Bv Memon
Checked Bv BuTCh
Sheet 4 Of 11 paae of


WORKSHEET WASTE STREAM SUMMARY
D AIRCRAFT FUELING


Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern


Cost of Disposal
Unit Cost ($ per: )
Overall [per year)
$0.bO/gal for water
Method of Management1

Relative
Priority Rating Criteria2 WL (W)
Regulatory Compliance
TreatmemVDisposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recover/
Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
uel JP-4
amp. /Strip Tk
angar/F. .Farir
*,OUO qals





-0.03/aal


off site/
recyc is
Rating
(Rl R x W









X(RxW)

Stream No.
uel Absorbent
Soills
Fuel Trans.
2,767 Tbs





l.uo/ib*


off site
recovery
Rating
(R) R x W









I(RxW)

Stream No.














Rating
(RJ R x W









KRxWl

Notes:   1.  For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration,  combustion
            with heat recovery, distillation, dewatering, etc.

         2.  Rate each stream in each category on a scale from 0 (none) to 10 (high).
                                             64

-------
F,rmUSCG ATC
Site Mo bile, Alabama
DateNovember 3-5, 1993
Pollution Prevention
Assessment Worksheets
TRC-001
Proi. No. PES T003.001
Prepared By Memon
Checked BY Burch
. Sheet 5 of 11 paae Of

WORKSHEET WASTE STREAM SUMMARY
0
AIRCRAFT SURVIVAL SHOP
Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Component^ of Concern


Cost of Disposal
Unit Cost {$ pen )
Overall (per year)

Method of Management1

Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Lability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. (W)









Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
^Adhesivps
Shelf lifP
Haz. Waste
b qts








Landfill

Rating

-------
FlrmUSCG ATC
site Mobile, Alabama
DateNovember 3-5, 1993
Pollution Pravintlon
Aijeijmem Worksheets
TRC-001
Proi. No. PES T003.001
Prepared Bv Burch
Checked BY Mem°n
. Sheet 6 of H Page of

WORKSHEET WASTE STREAM SUMMARY
6
PAINT/COMPOSITES/METAL SHOPS
Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern


Cost of Disposal
Unit Cost ($ pen }
Overall {per year)

Method of Management1

PrioritY Hating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
WL (W)









Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
SafKleen Sol .
Paint Guns
Haz. Waste
360 gals





b.80/gal
W , U88

off sitP
recycle
Rating
(R) R x W









KRxW)

Stream No.
Paint Sloos
Painting
Haz. Waste
452 Ibs





O.ZO/lb
$91

.andfm

Rating
(R) R x W









I(RxW)

Stream No.
Containers
Paints

120 Ibs








i anrtf i i 1

Rating
(R) R x W









Z{RxW)

Notes: 1. For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
66

-------
FirmUSCG ATC
Site Mobile, Alabama
DateNovember 3-5, 1993

WORKSHEET yy
Pollution Prevention
Assessment Worksheets
TRC-001
Proi.No. PES T003.001
Preoared By BuTCh
Checked Bv Memon
Sheet 7 of 11 Pace of

ASTE STREAM SUMMARY

PAINT/UOMPOSITES/METAL SHOPS
Attribute


Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Component(s) of Concern


Cost of Disposal
Unit Cost ($ per: )
Overall (per year)

Method of Management1

Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery

Relative
Wt. (W)









Sum of Priority Rating Scores
Priority Rank
Description
Stream No.
Blast. Media
Pt. Removal
Haz. Waste
1,04* Ibs





0.20/lb
5.205



Rating
(R) R x W









Z(RxW)

Stream No.














Rating
(R) R x W









KRxWJ

Stream No.














Rating
(R) R x W









IlRxW)

Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).
67

-------
FlrmUSCG  ATC
site Mobile, Alabama
DateNovember  3-5,  1993
     Pollution Pravtntion
   Assessmant Worksheet*

        TRC-001
Proj. No. PES T003.001
                  Prepared By   Memon

                  Checked By
                      Burch
                  Sheet  8  of 11  Page	of	
  WORKSHEET
                              WASTE STREAM SUMMARY
                                   BATTERY SHOP
                  Attribute
 Waste ID/Name:
                                                               Description
                                           Stream No.
                                            ICad Rat.t.
                           Stream No.
                            Mprr.  Ratt
                                Stream No.

                                  itMiim
 Source/Origin
           ircraft
 Component or Property of Concern
           att. Shop
                 Batt.  Shop
                        Batt.  Shop
 Annual Generation Rate (units
           0  IbS
                 9 IbS
                        10 IDS
  Overall
  Component(s) of Concern
                                           ;OH
 Cost of Disposal
   Unit Cost ($ per
                             3,3.00/lb
                                $6.00/1b
   Overall (per year)
           36
                                $60
 Method of Management1
          •iaz.  Waste
                 Haz.  Waste
                       Haz.  Waste
  Priority Rating Criteria2
  Relative
  Wt. (W)
Rating
  IR)
Rx W
Rating
  (Rl
Rx W
Rating
 (R)
RxW
   Regulatory Compliance
   Treatment/Disposal Cost
   Potential Liability
   Waste Quantity Generated
   Waste Hazard
   Safety Hazard
   Minimization Potential
   Potential to Remove Bottleneck
   Potential By-product Recovery
   Sum of Priority Rating Scores
            ZIRxW)
                 I(RxW)
                         I(RxW)
  Priority Rank
  Notes:   1.  For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
             with heat recovery, distillation, dewatering, etc.

          2.  Rate each stream in each category on a scale from 0 (none) to 10 (high).
                                           68

-------
R,mUSCG ATC
sue Mo bile, Alabama
Dat*November 3-5, 1993 i

WORKSHEET VVj

Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units
Pollution Prevention
Assessment Worksheets
TRC-001
*0j. NO. PES T003.001
Reared Bv Mem°n
Checked Bv BlJrCh 1
Sheet 9 of 11 Pace of 1

ASTE STREAM SUMMARY
BATTERY SHOP

1 Description
1 Stream No.
JAuto Batt.
(Automobiles
(Basewide
) |20 Batteries
Overall 1
Component(s) of Concern 1


Cost of Disposal I
Unit Cost ($ per: )
pU.7U/lb
Overall (per year) I

Method of Management1 j

Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores

Relative i Rating
Wt. (W) 1 (R)









| I(RxW)
RxW










Priority Rank I
tream No.














Rating
(R)









Z(RxW)
RxW











Stream No.














Rating
{R} RxW









I(RxW)

Notes:   1.  For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
            with heat recovery, distillation, dewatering, etc.

         2.  Rate each stream in each category on a scale from 0 (none) to 10 (high).
                                              69

-------
FirmUSCG ATC
Site Mobile, Alabama
DateNovember 3-5, 1993

Pollution Prevention
Assessment Worksheets
TRC-001
Proi. NO. PES T003.001

Prepared Bv Burch
Checked Bv Memon
Sheet 10 of 11

WORKSHEET WASTE STREAM SUMMARY
f* _,_. 	 	
D AVIONICS SHUP
Attribute


Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Components} of Concern


Cost of Disposal
Unit Cost ($ pen )
Overall (per year)

Method of Management1

Priority Rating Criteria2
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Relative
Wt. fWl









Sum of Priority Rating Scores
Priority Rank
Pace of


Description
Stream No.
Containers
Clean/Solder
Haz. Waste











Rating
(R) R x W









I(RxW)

Stream No.














Rating
(R) R x W









I(RxW)

Stream No.














Rating
(R) R x W









ZIRxW)

Notes: 1 . For example, sanitary landfill, hazardous waste landfill, on-site recycle, incineration, combustion
with heat recovery, distillation, dewatering, etc.
2. Rate each stream in each category on a scale from 0 (none) to 10 (high).

-------
ncrr ATP Pollutl
FirmUblb AIL A.tmrr
site Mobile, Alabama TC
DateNovember 3-5, 1993 Proj. No. PE
on Prevention
em Worksheets
£-001
.S T003.001

Preoared Bv Memon
Checked Bv Bu^ch
Sheet 11 of 11 Paae of

WORKSHEET WASTE STREAM SUMMARY
AIRCRAFT WASHING

Attribute
Waste ID/Name:
Source/Origin
Component or Property of Concern
Annual Generation Rate (units )
Overall
Components! of Concern


Cost of Disposal
Unit Cost {$ per )
Overall (per year)

Method of Management1

Relative
Priority Rating Criteria2 Wt. (W)
Regulatory Compliance
Treatment/Disposal Cost
Potential Liability
Waste Quantity Generated
Waste Hazard
Safety Hazard
Minimization Potential
Potential to Remove Bottleneck
Potential By-product Recovery
Sum of Priority Rating Scores
Priority Rank

Description
Stream No.
Wash Rinsate
A/C Washinq
West W Rack









Stormwater
Sewer
Rating
{RJ R x W









Z(RxW)

Stream No.
Wash Rinsatp
A/C Washina
East W Rack









Sanitary
Sewer
Rating
(R) R x W









I{RxW)

tream No.
hsnrhPnts
/C Washina
ash Racks
?n Ihs

il



0.46/lb *
5b

ff site
Recovery
Rating
(R) R x W









KRxWl

* Assumed same cost of disposal as  for  simulator spill  clean up waste.
                                   71

-------
                           USCG AVIATION TRAINING CENTER
                                   MOBILE, ALABAMA
                            PPOA BRAINSTORMING SESSION
                                         11/4/93

I.     GENERAL OPPORTUNITIES TO REDUCE WASTE GENERATION

A.    INPUT MATERIALS

      Limit variety of products for same function/application
      Reduce quantities purchased and stored
      Manage shelf life criteria for material purchase and use
      Match unit sizes with usage patterns
      Investigate alternative which are more environmentally friendly
      Consolidate distribution to control variety and quantities of materials
      Management of "Homer" materia use and waste generation

B.    WASTE MANAGEMENT

      Eliminate rain water entry to Bowser
      Segregate waste to improve value of components for reuse
      Recover spills for reuse rather than  disposal with adsorbents
      Containment of spills to allow for recovery
      Sample reuse
      Recycle/recover batteries rather than disposal
      Automotive battery exchange

C.    AWARENESS

      Communication of environmental information and objectives
      Reducing stress between job completion and safety/hazardous material management
      User friendly language
      Alternative communication methods  such  as:
             Computerized  maintenance system job  sheets  (CMS)  to  document environmental
             information and procedures
             Management policy
             Maintenance instructions (TIMI)
             Briefings
             Recognition programs
             Hazardous material training  program tailored to USCG Aviation
             Supervisory inspection programs (material, wastes, procedures, etc.)
                                             72

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II.     OPPORTUNITIES TO INVESTIGATE BY PROCESS

A.     FUEL HANDLING ISSUES

      Fuel samples:
             Fuel samples are estimated at 1 gal/plane/day (approximately 12,000 gal/yr)
             Alternatives to "clear and bright" analysis and sample size reduction
             Reuse samples in diesel fuel or possibly return to fuel tanks
      Spills:
             Containment at tank farm
             Equipment to recover spills rather than adsorbents
             Prevention - eliminate "stuck valve" on truck leading to overflow
             Provide supervision of filling operation all shifts
             Recycle  fuel drained during  maintenance  (defueling) from  lines clearing,  fuel  cell
             and pump repair

B.     PLANE WASHING

      Environmentally friendly soaps that meet performance expectations
      Soap/water mixing and application specifications
      Oil/water separation before discharge

C.    COMPOSITE/PAINT SHOP

      Current successes:
             Material distribution -  quantities and control
             Paint gun cleaning - solvent reuse, timing (before hardening)
      Paint application  opportunities:
             Low pressure/high volume paint gun use  in booth and hanger reducing pain usage
             rate
             Using smaller paint guns, application, etc.
             Electrostatic application?
             Effectiveness of water wall - uneven curtain, disposal of water, solids, etc.
             Re-formulation of coatings
             Consolidation and control of paint activities across ATC
             Use of pain gun rather than aerosol cans
D.    RAFT-ASM SHOP

      Reduce variety of glues
      Change wipe/cleaning solvent from toluene
 E.    NON-DESTRUCTIVE INSPECTION WHEELS

      Frequency of analysis
      Alternative solvents
                                               73

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F.    FLIGHT SIMULATORS

      Current Successes
      + Recovery of oil for reuse elsewhere
      Leak prevention program
      Use of vacuum pickup & wringing out pads
      Use of reconditioned rags for cleanup
      Awareness training
      Contract incentives for waste minimization

G.    AIRCRAFT MAINTENANCE

      Current success
      + CMS - computerize maintenance system with authorized chemical use list
      Locker consolidation for all airframe shops
        Centralized management of hazardous materials
      Shelf life
        Lot extension verification
        Inventory control:  "almost in time" - FIFO
      Variety reduction
      Unit size matching to use rates
      "Sure shot" vs. aerosols product delivery system
      Alternative cleaning solvents
        Safety Kleen 105 Mineral Spirits vs. BIO-7 aqueous cleaner
        Parts washing - develop life cycle analysis to evaluate alternatives
        MIL Spec's 87936 and 87937 - alternative cleaners {aqueous & semi-aqueous)
        Waste oil - segregation of fuel from oil & other wastes (segregated can
          drain/crush)
        Replace oil based  on oil analysis rather than fixed timeline
        Oil change life vs.  commercial stds. for acid viscosity metal, acidity, viscosity,
          metals content, etc.
        Current required oil replacement schedule:
          Air Frame                 Engine Oil                    Gearbox Oil
          Falcon                          150 hrs                       450 Mrs
          Dauphin (H65)                    150 hrs                       450 Hrs
          Jay Hawk (H60)           On condition of oil             On condition of oil
      Containment and recovery of  hydraulic fluids for reuse
      Investigate environmentally friendly antifreezes
                                              74

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-------
Firm.

Site .

Date
       USC6 ATC
Mobile, Alabama
November  3-5, 1993
                             Pollution Prevention
                           Assessment Worksheets
                        Proj. No.
TRC-001
PES T003.001
Prepared By   Surch	

Checked Bv   Memon

Sheet	of	  Page	of
  WORK SHEET
      8
                                OPTION DESCRIPTION
Option Name:
           Pollution Prevention  Awareness
Briefly describe the option:   Increased communication of  pollution prevention	
  policy and  objectives  --  in information  distributed,, training courses,  etc
Waste Stream(s) Affected:    All
 Input Material(s) Affected:     All
 Product(s) Affected:
 Indicate Type:       Q Source Reduction
                      	Equipment-Related Change
                        X  Personnel/Procedure-Related Change
                      <—__ Materials-Related Change
                      Recycling/Reuse
                      	Onsrte
                      	Off site
                                  Material reused for original purpose
                                  Material used for a lower-quality purpose
                                  Material sold
 Originally proposed by:

 Reviewed by:	
                        Assessment Team
                                                     Date:
                                                             11/4/93
                                                     Date:
 Approved for study?
                                     , no   By:.
                                                      Assessment  Team
 Reason for Acceptance or Rejection,
                                      16

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      USC6  ATC
Firm	
s;te   Mobile, Alabama

Data  November 3-5,  1993
       Pollution Prevention
      Assessment Workxheetx

            TRC-001
   ftpi.no.   PES T003.001
Prepared By

Checked By
             Memon
9urch
                              Sheet	of	  Page	of	
  WORKSHEET
      8
    OPTION DESCRIPTION
Option Name:    Simulator Contract  Incentives for Waste Minimization	

Briefly describe the option:   Changes  in  the  Simtech contract to  implement leak
     prevention and  maintenance  program  on the same lines as  the simulator
     availabil ity.	
 Waste Smam(s) Affected:    Hydraulic  fluid  spill  clean up,
 Input Mattrialts) Altecied:     Hydraulic fluid
 Product(s) Affected:
                       N/A
 Indicate Type:        13 Source Reduction
                     	Equipment-Related Change
                          , Personnel/Procedure-Related Change
                          , Materials-Related Change
                   D  Recycling/Reuss
                      	Onslte
                      	Offsita
            , Material reused for original purpose
            , Material used for a lower-quality purpose
            . Material sold
 Originally proposed by:

 Reviewed by: _____
                       Assessment Team
                               Date:

                               Date:
                                        11/4/93
  Approved for study?,
.yes,
                     Bv:   Assessment  Team
  Reason for Acceptance or Rejection
                                Reduced  spil I  clean  up
                                        77

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Ftrm   USCG ATC	
Site   Mobile, Alabama
Date   November 3-5,  1993
                                  Pollution Praventlon
                                Assessment Worksheet*

                                      TRC-001
                                           TOQ3.0Q1
Prepared By

Checked By,
             Memon
Burch
                                                         Sheet	of	  Page	of	
  WORKSHEET
      8
                               OPTION DESCRIPTION
Option Name:     Flight Simulator Hydraulic  Fluid  Recovery

Briefly describe the option:  Use  a  wringer to recover  hydraulic fluic!  from spill
	clean up absorbents and reduce the  weight of discarded absorbent  and
      reuse the  absorbents.   Also,  this  will allow waste liquid  hydraulic
      fluid collection  for reuse/recycle.
Waste Stream(s) Affected:   Hydraulic  fluid  spill clean up
Input Material^) Affected:   Hydraulic  fluid
Productls) Affected:
Indicate Type:       Q  Source Reduction
                       X   Equipment-Related Change
                       v   Personnel/Procedure-Related Change
                     __ Materials-Related Change

                  Q  Recycling/Reuse
                     J!— Onsfte   _X	Material reused for original purpose
                      *  , Offsite   	Material used for a lower-quality purpose
                                   Y   Material snM
                                     , Material sold
 Originally proposed by:

 Reviewed by:	
                      Assessment Team
                                                        Date:

                                                        Date:
                                                                 li/4/93
                                              By.   Assessment Team
Approved for study?      X    ye$	,       	

R«ason for Acceptance or Rejection   Reduction in  waste  disposal
                                       78

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Firm

Site
      USCG  ATC
Mobile, Alabama
Date   November 3-5,  1993
                            Pollution Prevention
                           Assessment Worksheets
                        Proj. No.
                                TRC-001
                                PES T003.001
               Prepared By

               Checked By.
Surch
Memon
                                                         Sheet ___ of...    Page   . of __.
  WORKSHEET
      8
                         OPTION DESCRIPTION
                                 AIRCRAFT  MAINTENANCE
Option Name:
         Centralized  Material  Control
Briefly describe the option;   Combine material lockers  for tnree  air  frame and
   and  engine shops to  Improve control  of materials — monitor shelf  life,
    imit  use of  duplicating materials,  control  purchasing to  "just-in-fime"
   and  quantity  and size  matching usage  rates.
Waste Stream(s) Affected:
                         All
 Input Material(s)
       Affected-     Reduce  variety  of materials;  Reduce shelf-life  losses
 Product(s) Affected:
 Indicate Type:        0 Source Reduction
                     ____ Equipment-Related Change
                     	Personnel/Procedure-Related Change
                       X   Materials-Related Change
                   D  Recycling/Reuse
                      	Onsite
                      	Off site
                                 . Material reused for original purpose
                                 . Material used for a lower-quality purpose
                                 . Material sold
 Originally proposed by:

 Reviewed by:.
                       Assessment Team
                                                    Date:

                                                    Date:
                                                            11/4/93
 Approved for study?
                     .Yes
.no   By:..
                                                     Assessment Team
 Reason for Acceptance or Rejection
                                       79

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Firm USCG ATC
Site Mobile, Alabama
Date November 3-5, 1993
Pollution Prevention
Assessment Worksheets
TRC-001
PTOJ.NO. PES T003.001
Prepared Bv Surch
Checked Bv Memon
Sheet . of . Page of
  WORKSHEET
      8
                               OPTION DESCRIPTION
                         AIRCRAFT MAINTENANCE
Option Name:     Alternative Cleaning  Sol vents
Briefly describe the option:   Investigate replacement of organic  solvent cleaning
 with  alternative cleaners  such as  current Bio-7  semi-aqueous terpene
 cleaner.   Conduct life-cycle analysis of  materials and  cleaning  needs.
Waste Stream(s) Affected:    Cold cleaner  spent solvent,
Input Materialls) Affected:	Cleaning  solvents
Productls) Affected:
N/A
Indicate Type:       Q  Source Reduction
                       X   Equipment-Related Change
                     ____ Personnel/Procedure-Related Change
                       Y   Materials-Related Change
                  0  Recycling/Reuse
                     	Onsite
                     	Offsite
                , Material reused for original purpose
                 Material used for a lower-quality purpose
                 Material sold
Originally proposed by:

Reviewed by:	
                      Assessment  Team
                                   Date:

                                   Date:
                                           11/4/93
Approved for study?
    yes
no   Bv;   Assessment Team
Reason for Acceptance or Rejection
                                      80

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Firm

Site
      USCG  ATC
 Mobile, Alabama
Date   November 3-5,  1993
                             PoButJoo Prevention
                            Axsassment Worksheets
                         Proj. No.
                                  TRC-001
                                  PES T003.001
         Prepared By

         Checked By

         Sheet	of
Surch
Memon
                                                             	of	 Page  ;  of
  WORKSHEET
      8
                              OPTION DESCRIPTION
                                AIRCRAFT MAINTENANCE
Option Name:     Alternative  Dispensing System Aerosols
Briefly describe the option;    °ver 1QUQ  Aerosol  containers  are dispensed  each year
   in  the application  of cleaners  and other products; each can contains  botn
  active ingredient and vehicle.   Volume filled  by vehicle and  vehicle
  itself are  waste.
       Compressed air  filled dispensers,  "sure  shots," would accomplish
   same delivery.
Waste Stream(s) Affected:      Containers, air emi ssions
Input
LJ . • ii t  AM . j      Aerosol products  reduced
Material(s)  Affected:    .	[_	
Product(s) Affected:
                      N/A
Indicate Type:       Q  Source Reduction
                     	Equipment-Related Change
                     	Personnel/Procedure-Related Change
                       X  Materials-Related Change
                  0 Recycling/Reuse
                     	Onshe
                     	Off site
                                 . Material reused for original purpose
                                  Material used for a lower-quality purpose
                                  Material sold
 Originally proposed by:

 Reviewed by:	
                      Assessment  team
                                                    Date:

                                                    Date:
                                                            11/4/93
 Approved for study?
                     .Y"
                                         .no
Bv;   Assessment Team
 Reason for Acceptance or Rejection
                                      81

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i icpr ATP
Firm uowu t\ \ v>
Pollution Prevention
Atf Mtmflnt Workthittt
Site Mobile, Alabama Tor_nm
Date November 3-5,
WORKSHEET
8
1993 p^ita. PES T003.001

OPTION DESCRIPTION
Prepared Bv Surch
Checked Bv Memon
Sheet , of Paae of


AIRCRAFT MAINTENANCE
Option Name: Condition-Based Oil Reolacement
Briefly describe the option:
Currently, enaine and aearbox oils are reolar.ed ha<;pH
on frequency of use.. Uolphin helicopter relies
oil 's condition.
on periodic analysis of
Consider approach for all aircraft.





Waste Stream(s) Affected:
Input Material(s) Affected:
Waste oi 1

Engine and gearbox oil





Product(s) Affected: N/A

Indicate Type: Q
D
Originally proposed by:
Reviewed by:
Approved for study?
Source Reduction
_ Equipment-Related Change
______ Personnel/Procedure-Related Change
X Materials-Related Change
Recycling/Reuse
_ Onshe 	 Material reused for original purpose
	 Offshe 	 Material used for a lower-quality purpose
	 Material sold
Assessment Team 11/4/93
	 . Date:

Date:
X ves no BY: Assessment Team
Reason for Acceptance or Refection



82

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Firm

Site
      USCG ATC
     Mobile,  Alabama
Date  November 3-5,  1993
     Pollution Prevention
   Aisessment WorkjhMtt

         TRC-001
PTOJ.NO.  PES  T003.001
Prepared Bv   Surch	

Checked BY   Memon

Sheet	of	 -Page __ of
  WORKSHEET
      8
                               OPTION DESCRIPTION
                                  AIRCRAFT MAINTENANCE
Option Name:    Alternative Container Sizes
Briefly describe the option:     Large  volume  use of hydraulic fluid  and lubricating
   oil  indicates replacement  of quart cans with  gallon  containers  (or	
   other size) should be considered.
 Waste Stream(s) Affected:  Containers, waste oil
 Input Material!*) Affected:  Lubricating  oils and hydraulic  fluids
 Product(s) Affected:
 Indicate Type:       0  Source Reduction
                      _     Equipment-Related Change
                      	Personnel/Procedure-Related Change
                      ,  X_ Materials-Related Change
                   D  Recycling/Reuse
                      	Onsite
                      	Off site
                                      . Material reused for original purpose
                                      , Material used for a lower-quality purpose
                                      , Material sold
 Originally proposed by:

 Reviewed by:	
                       Assessment  Team
                                                         Date:

                                                         Date:
                                                                 11/4/93
Approved for study?
                            yes ,
                                           no   Bv;   Assessment Team
  Reason for Acceptance or Rejection
                                       83

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Firm
Site
Date
USCG ATC
Mobile, Alabama
November 3-5, 1993
Pollution Prevention
Auassment Worksheets
TRC-001
PTOI.NO. PES T003.001
Prepared By
Checked By
Sheet . of
Memon
Burch
Page _ .


of
  WORKSHEET
      8
                               OPTION DESCRIPTION
Option Name:
Fuel Transfer  Spill  Prevention
Briefly describe the option:     Prevent spillage of fuel  in transfer activities  by
    strict  supervision of transfer  activities, stuck valve maintenance,  and
    overfill  prevention.  This will  allow a reduction  in  spill  waste and
    fuel consumption.
Waste Stream(s) Affected:    Fuel  soills
Input Material(s) Affected:    JP"4  fue1
 Product(s) Affected:
                      N/A
 Indicate Type:       Q Source Reduction
                         _ Equipment-Related Change
                     _.X	Personnel/Procedure-Related Change
                     ___ Materials-Related Change
                     Recycling/Reuse
                       X  Onsite     X
                     	Offsite   	
                      , Material reused for original purpose
                      , Material used for a lower-quality purpose
                      , Material sold
 Originally proposed by:

 Reviewed by: _____
                       Assessment Team
                                         Date:
                                                  11/4/93
                                         Date:
 Approved for study?
          .yes.
, no   By:.
                                                    Assessment Team
 Reason for Acceptance or Rejection,
                Prevention  of spills, tfterby JP-4  could  be used

                for  its original  purpose  or diesel.
                                        84

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      USCG ATC
g;»»   Mobile. Alabama
n,».  November 3-5» 1993
  Pollution Prevention
 Assessment Worksheets

       TRC-001
,. Mn   PES T003.001
Prepared By,

Checked By,
                                                                       Memon
                                                                       3urGh
                                                          Sheet    of      Paae    of
  WORKSHEET
      8
                                OPTION DESCRIPTION
Option Name:,
                Reduce Fuel  Sample Size
Briefly describe the option:  Fuel  samples arethe major fuel waste strean.  The
     reduction of  fuel  sample  size will accordingly reduce  the waste





Waste Stream(s) Affected:

Input Matwialls) Affected:



Fuel samples

JP-4 fuel

N/A

 Indicate Type:       0 Source Reduction
                          .. Equipment-Related Change
                        X   Personnel/Precedure-Related Change
                      	Materials-Related Change
                    13  Recycling/Reuse
                            Onsite
                            Offsite
                                          Material reused for original purpose
                                          Material used for a lower-quality purpose
                                          Material sold
  Originally proposed by:

  Reviewed by:,
                        Assessment Team
                                                            Date:

                                                            Date:
                                                                     11/4/93
  Approved for study?
                                             no   BV;   Assessment Team
  Reason for Acceptance or Rejection
                                          85

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Firm,

Site.
      USCG ATC
      Mobile, Alabama
Date.  November 3-5, 1993
                                   Pollution Prevention
                                 Assessment Worksheets
                              Pro]. No.
                                       TRC-001
                                       PES  T003.001
Prepared By    Memon

Checked By,

Sheet	of	  Page	of	
9urch
  WORKSHEET
      8
                               OPTION DESCRIPTION
Option Name: - Alternative to  "
                                         and  Bright"  Analysis
Briefly describe the option:   This analysis  requires large  quantities of  fuel
     saopling.   Incorporation of new technology  such as  laser technology
     _mav allow performing  this analysis  without  taking  samples  or a
     many samples.
Waste Stream!*} Affected:        PUP!  samples
Input Mattrial(s) Affected:
                           OP-4 fuel
Product(s) Affected:
                      N/A
Indicate Type:        El  Source Reduction
                     X    Equipment-Related Change
                     JS	Personnel/Procedure-Related Change
                     	Materials-Related Change
                     Recycling/Reuse
                          Onstte   _.. X   Material reused for original purpose
                          ~"~ ~     — Material used for a lower-quality purpose
                                   	Material sold
                          Offsite
OriginaDy proposed by:,

Reviewed by:	
                      Assessment  Team
Approved for study?
Reason for Acceptance or Rejection
                                                         Date:

                                                         Date:
                                                                 11/4/93
                                          no   BV;   Assessment Team
                                       86

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Firm USCG ATC
Site Mobile, Alabama
DatR November 3-5, 1993
Pollution Prevention
Aisassmant Worksheets
TRC-001
Pmt. No. PES T003.001
Prepared By
Checked By
Sheet of

WORKSHEET
OPTION DESCRIPTION


Memon
Burch
Page



of

Cotton Name: Recover Fuel From 2bOO Tanks at Fuel Farm
Briefly describe the notion: Fuel and water stripped from the holding
tanks at
the
    fuel  farm are  collected in  this  tank.   Hater could be  separated and
    fuel  filtered  to recycle fuel  back to  the  holding tanks.
Waste Stream(s) Affected:      Strip  tank  fuel
Input Material^ Aitected:       JP"4  fuel
Produces) Affected:
Indicate Type:        Q  Source Reduction
                        X  Equipment-Related Change
                        X  Personnel/Procedure-Related Change
                      ____ Materials-Related Change

                   0  Recycling/Reuse
                        X  Onsfte    X   Material reused for original purpose
                      	Offsite   ..   . Material used for a lower-quality purpose
                                   	Material sold
 Originally proposed by:

 Reviewed by: _
                       Assessment Team
                                Date:

                                Date:
                                         11/4/93
 Approved for study?
.Y",
                     Bv.   Assessment Team
 Reason for Acceptance or Rejection
      Avoid  sale  of  waste  fuel at low  revenue, and
      use  the fuel for the original purpose.
                                         87

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Firm,

Site
      USCG  ATC
Mobile,  Alabama
November 3-5,  1993
         Pollution Prevention
        Assessment Worksheets
                              Proj. No.
                                      TRC-001
                                      PES  T003.001
                            Memon
               Prepared By

               Checked By.

               Sheet	of	 Page	of	
                                             Burch
  WORKSHEET
      8
                              OPTION DESCRIPTION
Option Name:  Sowser Waste  Segregation
Briefly describe the option:   Bowser waste  includes  two waste  streams,  i.e.,  oils
   and  fuel.   These two  streams  should be  segregated  and collected	
   separately  in two bowsers, allowing opportunity  for reuse after cleaning
   or  increase waste quality for sale..   JP-4 can  be used as  dlesel on
   support vehicles on  base.	
Waste Smam(s) Affected:
Waste oils
                         Waste JP-4  Fuel
Input Matwiai(s) Affected:
Waste oiI
                         JP-4 fuel
Productfs} Affected:
                      N/A
Indicate Type:        0  Source Reduction
                     	Equipment-Related Change
                       X   Personnel/Frocedure-Related Change
                     	Materlals-Ptelated Change
                  D  Recycling/Reuse
                       Y   Onstte
                     	Off site
             Material reused for original purpose
             Material used for a lower-quality purpose
             Material sold
Originally proposed by:

Reviewed by:	
                      Assessment Team
                               Date:

                               Date:
                                        11/4/93
Approved for study?
 .Yes,
no   Bv:   Assessment Team
Reason for Acceptance or Rejection
      Avoid sale  of waste  oil/fuel  at low  revenue.
      Increase  in waste oil/fuel quality.   Reuse of
      waste fuel  as diesel.
                                      88

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Firm
Site
Date
USCG ATC
Mobile, Alabama
November 3-5, 1993
Pollution Prevention
Assessment Worksheets
TRC-001
ftoLNo. PES T003.001
Prepared By
Checked By
Sheet of
Memon
Burch
Pane


of
  WORKSHEET
      8
                              OPTION DESCRIPTION
Option Name;   Eliminate  Rainwater  Entry  to Bowser
Briefly describe the option:    Eliminate  rainwater entry  to bowser by covering it when
        nppn  unattended.  Also  estimate  water  by dipstick in the  bowser
   and remove any settled water.   This  will eliminate or drastically reduce
   water content of  waste oil/fuel stored, thereby Increasing the waste oil/
   fuel  sal-e value  as  well as  offer opportunity for usage .for  lower quality
   purposes.
Waste Stream(s) Affected:
                        VJaste  oil
                        Waste  fuel JP-4
Input Materialist Affected:
                        JP-4  fuel
                        Oils
Product(s) Affected:
                      N/A
Indicate Type:
                    Source Reduction
                     X    Equipment-Related Change
                     X    Personnel/Procedure-Related Change
                    _ Materials-Related Change

                    Recycling/Reuse
                      X   Onsite     X  Material reused for original purpose
                      X   Offsite     Y  Material used for a lower-quality purpose
                                   v  Material sold
 Originally proposed by:

 Reviewed by: _______
                      Assessment Team
                                                        Date:

                                                        Date:
                                                                11/4/93
                          .Y"
                                        .no  By:.
                                                   Assessment  Team
Approved for study?     X

Reason for Acceptance or Rejection   Increase  in waste  fuel/oil  quality  for sale
                              or reuse/recycle.
                                       89

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_ I ic re ATP
Firm uouo r\ i o
site Mobile, Alabama
Date November 3-5,
WORKSHEET
8
Option Name: Sol 11
Briefly describe the option:
1993



Pollution Prevention M
Assessment Worksheets Prepared BY Memon
TRC-001 Checked By Burcn
ftoKNe,. PES T003.001 Sh,,t A, .... „,

OPTION DESCRIPTION

Containment
Construct a permanent containment around transfer station
at the fuel farm, and
activities everywhere
use temporary containments at fuel transfer
else. This will prevent contamination of the
environment and will allow easy recovery of the spilled fuel either by
vacuum or by absorption. The recovered fuel can ei-ther be reused
after cleaning
or used as diesel .


Waste Stream(s) Affected:
Input Material(s) Affected:
Product(s) Affected:
JP-4

JP-4

N/A
fuel spill

fuel



Indicate Type: Q
Oriolnally proposed by:
Reviewed bv:
Approved for study?
Source Reduction
__X_ Equipment-Related Change
X Personnel/Procedure-Related Change
	 Materials-Related Change
Recycling/Reuse
— X — Onslte X Material reused for original purpose
____. Offsite X Material used for a lower-quality purpose
	 Material sold
Assessment Team 11/4/93
DatA-

	 _ Date.
X yes no BV Assessment Team
Reason for Acceptance or Rejection


Prevention of clean up cost -of environmental
deterioration and reuse of the spilled
material .
90

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Firm.

Site_

Date
      USCG ATC
Mobile, Alabama
November 3-5, 1993
                             Pollution Prevention
                           Atsessment WorkshMts
                        Proj. No.
TRC-001
PES T003.001
                               Surch
                               Memon
                                                          Sheet	of .     Page   . of _
  WORKSHEET
      8
                         OPTION DESCRIPTION
                                AIRCRAFT SURVIVAL  SHOP
Option Name:    Alternative Wipe  Solvents
Briefly describe the option:    Replace  Toluene witn acetone for  preparation  of
   raft  surface  material  prior to gluing.
Waste Stream(s) Affected:    Air emissions
Input Material Affected:    Toluene. Acetone
 Product(s) Affected:
 Indicate Type:        0  Source Reduction
                      ____ Equipment-Related Change
                      	   Personnel/Procedure-Related Change
                        X  Materials-Related Change
                   D  Recycling/Reuse
                      	OnsHe
                      	Offsite
                                  Material reused for original purpose
                                  Material used for a lower-quality purpose
                                  Material sold
 Originally proposed by:

 Reviewed by: _  _
                       Assessment Team
                                                     Date:

                                                     Date:
                                                             11/4/93
 Approved for study?
                     .yes.
   , no   By:.
                                                      Assessment  Team
 Reason for Acceptance or Rejection
                                        91

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Firm,

Site .

Date
      USCG ATC
Mobile, Alabama
November  3-5, 1993
     Pollution Prevention
   Assessment Worksheets

         TRC-001
Proi. NO.  PES  TQ03.001
Prepared By

Checked By.
                                                                 Surch
Memon
                                                          Sheet	of	  Pace	of	
  WORKSHEET
      8
                                OPTION DESCRIPTION
                            PAINT7COMPOSITE/METAL SHOPS
Option Name:    Paint Application Alternatives
Briefly describe the option:    Greater reliance  on HVLP systems; reduced  size of
 application  gun when feasible; replace aerosol  use  with  HVLP.
Waste Streamfs) Affected:      Spent solvents
Input Material(s) Affected:,
                            Paints
Product(s) Affected:
Indicate Type:        0  Source Reduction
                      	Equipment-Related Change
                           Personnel/Procedure-Related Change
                        X  Materials-Related Change
                   0  Recycling/Reuse
                      	Onsrte
                      	Offsite
                                  Material reused for original purpose
                                  Material used for a lower-quality purpose
                                  Material sold
 Originally proposed by:

 Reviewed by:.
                       Assessment  Team
                                                    Date:
                                                             11/4/93
                                                    Date:
 Approved for study?
                                          Bv;
                                                     Assessment Team
 Reason for Acceptance or Rejection
                                       92

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Firm
Site
Date,
USCG ATC
Mobile, Alabama
November 3-5, 1993
Pollution Prevention
Asiessmam Workshaets
TRC-001
PR.I.NO. PES T003.001
Prepared By
Checked By
Sheet , of
Memon
Burch
P3Q«_


Of
  WORKSHEET
      8
    OPTION DESCRIPTION
Option Name:   Aircraft Battery Reclamation
Briefly describe the option:	Investigate manufacturer reclamation program whereby old
     batteries  are accepted  by the manufacturer for recycling/recovery.	
     NiCad, Mercury, and  Lithium batteries  can be reclaimed  by .-ithis	
     method.   Some manufacturers even offer small payment or rebate on  new
     battery  purchases  in exchange.
Waste Stream(s) Affected:	Aircraft  batteries  iNiCad.  Lithium, Mercury)
Input Materialist Affected:    NiCad, Lithium, and  Mercury  batteries
 Product(s) Affected:
                      N/A
 Indicate Type:       0  Source Reduction
                     .     Equipment-Related Change
                       X  Personnel/Procedure-Related Change
                        .- Materials-Related Change

                  Q  Recycling/Revue
                          Onslte   __ Material reused for original purpose
                       X  Offsite   ____ Material used for a lower-quality purpose
                                  _J	Material sold
 Originally proposed by:,

 Reviewed by:	
                       Assessment Team
                              Date:

                              Date:
                                      11/4/93
 Approved for study?,
.Yes.
                    By.
                                                    Assessment  Team
 Reason for Acceptance or Rejection   Saving  of battery disposal  cost:
                               Saving  in new  battery purcnase.
                                        .93

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Firm
Site
Date ,
USCG ATC
Mobile, Alabama
November 3-5, 1993
Pollution Prevention
Assessment Worksheets
TRC-001
PTOJ.NO. PES 7003,001
Prepared By
Checked By
Sheet of
Memon
Burch
Pace


of
  WORKSHEET
      8
                              OPTION DESCRIPTION
Option Name:   Automotive Battery Exchange
Briefly describe the option:   Instead  of disposal of  automotive batteries through
     DRMO  a.t cost,arrangements with the auto supplier should  be made  to
     exchange old  batteries with new ones  at reduced  cost for  the new  ones

     and  saving of the waste  battery disposal.	
Waste Stream(s) Affected:    Waste  automotive batteries
Input Material) Attested:    Automotive  batteries
Prcduct(s) Affected:
Indicate Type:       Q Source Reduction
                    __ Equipment-Related Change
                      X  Personnel/Procedure-Related Change
                    	Materials-Related Change
                 0 Recycling/Reuse
                    	Onsrte
                    	Offslte
            , Material reused for original purpose
            , Material used for a lower-quality purpose
             Material sold
Originally proposed by.

Reviewed by:.
                      Assessment Team
                               Date:

                               Date:
                                       11/4/93
Approved for study?
.yes.
BY:
                          Assessment Team
 Reason for Acceptance or Rejection Saying  in disposal  cost and reduction in  Input
                          'material  cost.     	•——————————
                                        94

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Flrm   USCG ATC	

site   Mobile, Alabama

Date, November  3-5, 1993
                 Pollution Prevention
               Aaiessmem Workshtttt

                     TRC-001
            Pro!. No.   PES T003.0Q1
             Memon
Prepared By

Checlced By.

Sheet	of	  Page
Burch
                                                                                  of
  WORKSHEET
      8
                               OPTION DESCRIPTION
Option Name:
Aircraft Washing  Spec Adherence
Briefly describe the option:  Follow measurement  procedures  before  mixing  liquid

     soap  with water to minimize  use of soap.   AlsoT  use  specified pro<

	of applying the soap  and rinsing  in order to  prevent streaking.
Waste Stream(s) Affected:    '-/ashing rinsate
Input Materials) Affected:    Soaps
Product(s) Affected:       N/A
Indicate Type:       Q  Source Reduction
                     	Equipment-Related Change
                       X  Personnel/Procedure-Related Change
                     	Materials-Related Change

                  0  Recycling/Reuse
                     	Onslte   	Material reused for original purpose
                     	Offsite   	Material used for a lower-quality purpose
                                  	Material sold
Originally proposed by:

Reviewed by:...
                      Assessment  Team
                                       Date:

                                       Date:
                                                li/4/93
Approved for study?     X     ye$

Reason for Acceptance or Rejection _
                       ,no   BY;   Assessment  Team
                                        95

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Firm USCG ATC
Site Mobile, Alabama
Date November 3-5, 1993
Pollution Prevention
Assessment Worksheets
TRC-001
PmLNo. PES T003.001
Prepared Bv Memon
Checked Bv Burch
Sheet 	 of , Pace of
  WORKSHEET
      8
                                OPTION DESCRIPTION
                     Optimize  Oil/Water Separation System
Option Name:	                         	

Briefly describe the option;  Look Into the  design  and placement  of  the existing
    oil/water  separator in  order  to evaluate whether any  changes  are
    required  that will  optimize the operation.	
Waste StreamW Affected:     Washing rinsate
Input Material(s) Affected:
                          Soaps
Product(s) Affected:
Indicate Type:       Q Source Reduction
                       Y   Equipment-Related Change
                     ___ Personnel/Procedure-Related Change
                     ____ Materials-Related Change
                  D Recycling/Reuse
                     	Onsite
                     	Offsite
                                       . Material reused for original purpose
                                       . Material used for a lower-quality purpose
                                       , Material sold
Originally proposed by:

Reviewed by: _  _ .
                       Assessment Team
                                                          Date:

                                                          Date:
                                                                   11/4/93
Approved for study?
                           .ye*,
,no   By:.
                                                     Assessment  Team
Reason for Acceptance or Rejection
                                         96

-------
Firm.

Site .

Date
      USCG ATC
Mobile, Alabama-
November 3-5, 1993
        Pollution Prevention
       Aasessment Worksheet*

             TRC-001
    PTOJ.NQ.   PE$ T003.001
                                                           Prepared By    Memon	

                                                           Checked By    9urch	

                                                           Sheet	of	  Page	of
  WORKSHEET
      8
                                OPTION DESCRIPTION
Option Name:     Environmentally Friendly  Aircraft Washing
Briefly describe the option;  Recommend alternative  soaps which are more
    environmentally friendly and  that do the  same  or better .job,
Waste Stream(s) Affected:	Washing  rinsate
Input Matwial(s) Aff ecied:,
                            Soaps
Produces) Affected:
                       N/A
Indicate Type:        D  Source Reduction
                      _____ Equipment-Related Change
                           Personnel/Procedure-Related Change
                        X   Materials-Related Change
                   D  Recycling/Reuse
                      	Onsite
                      	Offsite
             , Material reused for original purpose
             Material used for a lower-quality purpose
             Material sold
 Originally proposed by:

 Reviewed by: ______
                       Assessment Team
                                Date:

                                Date:
                                         11/4/93
 Approved for study?
.Y"
                                           ,no   By:.
                                                      Assessment Team
 Reason for Acceptance or Rejection
                                         97
                         .S. GOVERNMENT PRINTING OFFICE:  1994 - 550-001/00186

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