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
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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
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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
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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
1 2 quarts
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
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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
-------
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
-------
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.
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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.
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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
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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.
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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.
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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.
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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)
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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
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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.
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Figure 2. Typical absorbent wringer.
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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
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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)
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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).
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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.
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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.
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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
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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.
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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
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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
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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
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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 PivMttton 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
3_-.T._ .
Process Unit/Ooeration: FLIGHT SIMULATOR COMPLEX
Pn
Ch
Sh
oared Bv Mem0n
edcedBv Burch
eet 1 of fl Paoe of
Operation Type: D Continuous Q Discrete
D Batch or Semi-Batch Q Other
Document
Process Flow Diagram
Material/Energy Balance
Design
Ooerating
Flow/Amount Measurements
Stream
Analyses/Assays
Stream
Process Descriotion
Ooerating Manuals
Equipment List
Equipment Soecifications
Piping and Instrument Diagrams
Rot and Elevation Plan(s)
Work Flow Diagrams
Hazardous Waste Manifests
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
NA
Y
N
NA
Y
N
N
N
N
to
N
N
N
Y
N
N
N
N
Y
Y
N
N
Current?
(Y/N)
Y
Y
Y
Y
Y
Last
Revision
Y
Y
V
Y
Used in this
Reoort (Y/N)
Y
Document
Number
Location
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
Pr
a
Sri
soared By Rnrrh
eclced Bv Memon
eet'
-------
r,,m USCG ATC
site Mobile, Alabama
Date November 3-5, 1993
WORKSHEET
3
Process Unit/Ooeration:
Operation Type:
Document
Pollution Prevention
Assessment Worksheets
TRC-001
Proi. No. PES T003.001
Preoared BY Mpoion
ChecktdBv Burch
Sheet 3 of 8 Paae of
PROCESS INFORMATION
AIRCRAFT FUELING
D Continuous C
D Batch or Semi-Batch C
Process Flow Diaaram
Material/Enerqy Balance
Design
Ooeratino
Flow/Amount Measurements
Stream
Analvses/Assavs
Stream
Process Descriotion
Ooeratinq Manuals
Eouioment List
Equioment Soecifications
Poina and Instrument Diagrams
Rot and Elevation Plants)
Work Flow Diagrams
Hazardous Waste Manifests
Emission Inventories
Annual/Biennial Reoorts
Environmental Audit Reoorts
Permit/Permit Aoolications
Batch Sheet(s)
Materials Aoolication Diagrams
Product Comoosition Sheets
Material Safety Data Sheets
Inventory Records
Ooerator Loqs
Production Schedules
iDisc
lOlhi
rete
r
Status
Complete? (
(Y/N)
NA
NA
Y
N
NA
Y
N
N
N
IN
N
fi
N
N
N
Y
N
N
N
N
Y
Y
N
N
"urrent?
(Y/N)
Y
Y
Y
Y
Y
Last
Revision
Jsed in this
Reoort (Y/N)
Y
Document
Number
Y
Y
Y
Y
Location
1
53
-------
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
rm--
Pre
Ch
Sh
soared BY Rnrrh
ecked BY Mpmon
eet 4 of ft Paoe of
Process UnityOoeration: AIRCRAFT SURVIVAL SHOP
Operation Type: D Continuous D
D Batch or Semi-Batch D
Document
Process Flow Diaaram
Material/Eneray Balance
Design
Ooeratinq
Flow/Amount Measurements
Stream
Analyses/Assays
Stream
Discrete
Other
Status
Complete?
(Y/N)
NA
NA
Y
N
NA
Process Descriotion
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
N
N
iN
N
N
N
N
N
Y
N
N
N
N
Y
Y
N
N
Current?
(Y/N)
Y
Y
Y
Y
Y
Last
Revision
Y
Used in this
Reoort (Y/N)
Y
Y
V
Y
Document
Number
-
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
-------
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
-------
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
-------
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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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